­
Judy
Graham
<
judy_
graham@
bellsouth.
net>

12/
29/
2005
09:
52
AM
To
Erv
Pickell/
NEIC/
USEPA/
US@
EPA
cc
Subject
RFG
Amendements
12/
15/
05
70
FR74572
80.83(
g)(
3)

Erv,

My
clients
and
I
have
serious
concerns
regarding
this
paragraph.
It
requires
an
entity
to
use
their
independent
lab
on
a
ship
of
GTAB
if
they
are
going
to
use
the
GTAB
to
make
RFG
regardless
of
whether
the
ship
could
be
certified
as
GTAB.

One
concern
is
that
often
multiple
parties
are
on
ship
­
each
importing
an
amount
of
GTAB.
If
there
were
three
parties,
then
it
could
be
that
three
different
independent
labs
to
run
the
same
sample
­
a
very
costly
and
unnecessary
undertaking.

Secondly,
GTAB
often
goes
into
several
different
tanks.
Therefore,
it
could
be
that
a
small
portion
of
the
GTAB
end
up
in
an
RFG
batch
down
the
road
that
the
entity
did
not
anticipate.

Thirdly,
the
entity
probably
does
not
know
what
it
is
going
to
do
with
every
last
drop
of
GTAB
on
that
ship
ahead
of
time.
It
would
essentially
force
the
entity
to
use
its
independent
lab
on
all
GTAB
just
in
case
it
ended
up
in
an
RFG
batch.

I
have
often
told
my
clients
to
use
their
independent
lab
on
a
GTAB
batch
whose
properties
would
allow
it
to
be
certified
as
an
RFG
import
in
case
they
change
their
mind
and
would
like
to
have
the
batch
or
part
of
the
batch
as
an
RFG
import.
But
it
makes
absolutely
no
sense
to
require
a
GTAB
batch
to
be
sampled
and
tested
by
their
independent
lab
when
the
GTAB
properties
are
not
even
going
to
be
used
and
if
the
GTAB
is
used
to
produce
RFG,
the
blender/
refiner
portion
of
the
entity
will
have
to
use
its
blender/
refiner
independent
lab
to
certify
the
batch.

I
would
like
you
to
consider
revising
this
part.
You
can
consider
this
an
adverse
comment
prior
to
February
13,
2006
and
a
request
to
amend
this
portion.

Judy
Graham
