Do all properties have to be analyzed on-line to get an exemption from the independent laboratory sampling and testing requirement?
No. However, EPA would prefer that in-line blending operations at least be capable of analyzing benzene, oxygen, and RVP on line. If the operation does not have the capability to analyze all properties on-line, the refiner must indicate in his petition how he intends to determine the fuel properties for those parameters not analyzed on-line, and provide sufficient cross-checks of the results from a composite sample to warrant an exemption from the independent sampling and testing requirements. In-line blending petitions will be evaluated on a case-by-case basis with regard to the operation's capability to analyze all properties on-line. (7/1/94)
This question and answer was posted at List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf)