Must sampling be performed only from tank storage, or will pipeline sampling qualify?
For a refiner, pipeline sampling is appropriate when performed according to the procedures outlined in 40 CFR part 80, Appendix D. Appendix D, section 11.4 describes how to collect a continuous or intermittent flow proportional sample, using automatic sampling apparatus, of an entire batch. Under § 80.65(e), however, refiners must have test results in hand before shipping RFG.
Therefore the only way a refiner could conduct pipeline sampling of an RFG batch, would be to collect the entire batch in tankage subsequent to the pipeline sampling and prior to shipping the batch out of the refinery, and to hold the batch in that tank until the requisite test results are complete.
In the case of downstream quality assurance sampling, pipeline sampling as outlined in Appendix D is appropriate, and tank collection is not an issue.
In the case of an independent laboratory collecting a pipeline sample at a refinery or import facility in fulfillment of the independent sampling and testing requirement, the automatic sampling equipment must be calibrated and operated by the independent laboratory during the entire period of time the pipeline sample is collected. See the Independent Sampling and Testing Section, Question 18, for further discussion of pipeline sampling and in-line blending. (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)