§ 80.101(i)(1) says that conventional gasoline cannot leave a refinery until testing is completed for all parameters used in the compliance calculation. (e)(2) of the same section says that for purposes of meeting (e)(1) a refiner may composite samples and treat that as one batch provided that the composite is not for materials produced or imported over more than one month. May material leave the refinery before analysis is run on the composite? Just a comment, is it really necessary to hold up a batch for at least three hours while an FIA is run for olefins especially since the results of an individual batch are irrelevant for conventional gasoline. Is it EPA's intention to preclude in-line blending of conventional gasoline by this requirement?
The regulations have been revised at § 80.101(i)(1) to allow conventional gasoline to leave a refinery or importer facility prior to the completion of sample testing. Note that there are additional constraints related to composite samples at § 80.101(i)(2) that must be followed for refiners that use composite sampling.
The volume and results of analysis of the composite sample should be treated as if applied to one batch for the purposes of §§ 80.104 and 80.105. Further, this revision to the regulation will allow the continued practice of in-line blending for conventional gasoline. See the "In-Line Blending" section for further discussion of this subject. (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)