Yes. As long as no batches are assigned duplicate numbers this would be acceptable.(7/1/94)
This question and answer is posted at http://www.epa.gov/otaq/regs/fuels/rfg/qa/420r03009.pdf. The original was posted in the Q&A posted on 7/1/94 which can found at http://www.epa.gov/otaq/rfg_qa.htm" See Question ID 3857 for RFG (Taken from the first question on http://www.epa.gov/otaq/regs/fuels/rfg/qa/420r03009.pdf)
If an importer registers in a PADD, may the importer use a starting point other than zero, within the range of valid batch numbers, for generating the sequential batch numbers at each of its import facilities?
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