How does a refinery that in-line blends RFG generate a certificate of analysis (key RFG parameters) prior to shipment as required by the regulations?

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For the simple model, refiners who petitioned for an exemption from the independent sampling and testing requirements are required to specify their reasonable basis for knowing that the fuel meets the standards for benzene and oxygen, and RVP in the case of VOC-controlled RFG, before the gasoline leaves the refinery.

The on-line analyzers, coupled with the continuous measurement of component blend ratios and volumes, in approved in-line blending operations, are expected to provide an accurate characterization of the fuel during, and at the end of the blend. When the batch is complete, the composite sample will be tested to provide a report of the blend's certified properties. EPA has amended the final rule to allow exempted in-line blenders to release RFG in advance of receiving final test results. However, refiners who in-line blend, and who have not been exempted from the independent sampling and testing requirements, must blend to a tank and meet the independent sampling and testing requirements for certifying RFG as specified in§ 80.65(f).(7/1/94)

This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF)(333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About PDF)