Under the regulation the terminal must sample and test its gasoline subsequent to the receipt of the transferred gasoline into the terminal storage tank in order to qualify the gasoline in the tank as S-RGAS.
However, it is a common industry practice for terminals to supply gasoline from a storage tank at the same time the tank is also receiving product from a pipeline. Where a load of gasoline that is classified by the pipeline as S-RGAS is being received into the terminal storage tank, until full receipt of the load, a sample that meets the requirements of the regulation cannot be obtained from the tank.
Even when a sample is ultimately taken and tested subsequent to full receipt of the load from the pipeline, the sample may not actually be representative of the gasoline that had previously been loaded into the truck, because in many situations the gasoline is being bottom-loaded into the terminal storage tank and is also being supplied to the truck rack from the bottom.
Therefore, the truck may have received gasoline that would not have the same sulfur test result as would a sample that was obtained from the completed mixture. Since parties will not encounter this issue until January, 2004, we are studying the situation, and will address it through appropriate later guidance, either through a Q&A response or through regulatory action prior to that time.