It is technically possible for a particular batch of RFG to meet all current ASTM and EPA volatility specifications and yet have an E200 value less than the 30% minimum specified in 40 CFR 80.45(f)(1)(ii). Does EPA consider it unlawful to produce and sell a particular batch of RFG with an E200 less than 30% even though the volume-averaged 18 parameters of the total RFG produced during the compliance period, including the E200 value, are well within the valid range of the Complex Model?
The valid range limits associated with the Complex Model are, in effect, per-gallon RFG standards. Thus it would be unlawful to produce RFG with an E200 value less than 30 vol%. The July 11, 1997 NPRM has proposed regulatory text to clarify this. (11/10/97)
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)