The July 1, 1994 Question and Answer Document indicates that sulfur, T90, and olefins are the only simple model RFG standards that can be seen on a refinery aggregated basis. We interpret this clarification to apply only to simple model RFG compliance and

All simple model anti-dumping standards can be met on a refinery-aggregate basis pursuant to § 80.101(h).(11/28/94)

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)