Under the simple model only oxygen and benzene, and RVP in the case of VOC-controlled RFG, will involve downstream EPA testing for enforcement purposes. EPA has not set enforcement tolerances for standards that apply at the refinery or importer level, such as sulfur, T-90, and olefins. Moreover, enforcement tolerances are only appropriate when measuring for per-gallon or min/max standards. Sulfur, olefins and T-90 are averaging standards. Therefore, EPA does not anticipate issuing enforcement tolerances for sulfur, T-90, or olefins.(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)