Section 80.70 lists for Virginia the county of Richmond as an opt-in and excludes the city of Richmond. Is this a typographical error?

Yes. The city of Richmond is considered opted-in, not the county of Richmond.(7/1/94)

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)