In the development of the Complex Model, EPA investigated the possibility that two complying batches, when mixed, may not comply with the RFG standards. This "fungibility" issue arises out of the model's nonlinear character. Based on a Monte Carlo simulation, EPA concluded that fungibility problems would not occur. The downstream standards adopted by EPA apply to each gallon of gasoline, including fungibly mixed gasoline.(11/10/97)
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 11/10/97 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)
For downstream compliance, has EPA addressed the issue that two complying batches mixed downstream may not comply when tested downstream?
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