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How do the changes in the 2006 Amendments apply to mobile refuelers?
Mobile refuelers are now exempt from the following sized secondary containment provisions that still apply to all other bulk storage containers and mobile/portable bulk storage containers: • Sections 112.8(c)(2) and (11) for petroleum oils • Sections 112.12(c)(2) and (11) for animal fats and vegetable oils These provisions previously required sized…
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Please clarify whether oxygenates blended into either conventional gasoline or Reformulated Blendstock for Oxygenate Blending (RBOB) downstream of the refinery need to be included in sulfur compliance calculations.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.205(c) provides that a refiner or importer may include oxygenates added downstream from the refinery or import facility if the requirements under § 80.69(a) or § 80.101(d)(4)(ii) of the RFG/CG regulations are met. Therefore, a refiner or…
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SPCC Rule schedules for inspections, tests, and evaluations
The SPCC rule requires inspections, tests, and evaluations of above ground containers (40 CFR §112.8(c)(6)). Does the rule set schedules for how often these need to be conducted? The SPCC Rule does not prescribe a specific frequency or methodology for performing the required inspections, evaluations, and tests for aboveground containers…
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In the NPRM, the sulfur standards were expressed without decimal places, but the final rule provides that the standards are expressed with two decimal places (§§ 80.195, 205). Why did EPA include this change?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA included the decimal places to ensure that the sulfur standards are not exceeded by rounding down actual average sulfur levels. We do not believe reporting the average sulfur level to two decimals creates any additional burden as…
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It is our understanding that, if a portion of the gasoline produced by a refinery located within the GPA is sold outside of the United States, that gasoline is not subject to the sulfur standards and it only has to meet the standards of the country to whi
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Gasoline that is exported for sale outside the United States is not subject to the requirements of the gasoline sulfur rule, including gasoline produced by a refiner located within the GPA. See § 80.200(c).
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In a situation where an importer leases tankage from another company, e.g., from a for-hire terminal, who must register such import facility, the company that owns the terminal, the importer that leases the tankage, or both?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Under § 80.2(r), an importer is defined as "a person who imports gasoline or gasoline blending stocks or components from a foreign country into the United States...." Accordingly, it is the importer of the gasoline, and not the…
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If my fuel is already registered with the Fuels and Fuel Additives program under 40 CFR Part 79, do I still need to register with the RFS2 program under 40 CFR Part 80?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Even if your fuel or fuel additive is already registered under 40 CFR Part 79, there are additional registration requirements for parties regulated under the RFS2 program, as specified in 40 CFR 80.1450.
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Once I register my fuel for the RFS2 program under §80.1450, do I still need to register my fuel under 40 CFR Part 79?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Renewable fuels intended for use or used in motor vehicles are required to be registered under 40 CFR part 79 prior to any introduction into commerce. Manufacturers of renewable fuels and fuel additives not registered under part…
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Are mobile refuelers exempt from integrity testing requirements?
Pursuant to 40 CFR §112.8(c)(2), mobile refuelers are exempt from the secondary containment requirements for bulk storage containers. Are mobile refuelers also exempt from the requirements for integrity testing in §112.8(c)(6)? Since mobile refuelers are mobile or portable bulk storage containers, the other provisions of §112.8(c) still apply. Therefore, mobile…
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6. Is commingling of different types of ethanol permitted? If so, what systems must be employed?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . With one exception, the RFS program places no restrictions on the mixing of ethanol produced in different facilities, by different feedstocks, or through different processes. Also, RINs assigned to ethanol are fungible, in that a specific assigned RIN…
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If a facility is grandfathered, is it also exempt from the requirement that feedstocks must be renewable biomass?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Even if a facility is exempt from the 20% GHG reduction requirement, in order to generate RINs, the facility is still required to use feedstocks that meet the definition of renewable biomass. The definition of renewable fuel in…
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Does EPA consider it a conflict of interest for a third-party company to assist a group of renewable fuel producers and importers of renewable fuel to help meet the requirements of the re-registration and engineering review pursuant to section 80.1450?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA does not restrict a renewable fuel producer or an importer of renewable fuel from seeking a third-party company to assist them in meeting the re-registration and engineering review requirements pursuant to section 80.1450. The renewable fuel producer…
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Will common carriers be required to register their transport trucks as oxygenate blending facilities?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Normally, only the owner of the gasoline produced at an oxygenate blending operation must register as an oxygenate blender. If a common carrier blends gas in trucks that it owns it must meet all of the requirements for…
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Is the licensed professional engineer conducting the engineering review required to perform the site visit in person, or can they delegate the site visit to another person who maybe assisting them in the engineering review?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Pursuant to §80.1450(b)(2), all verifications must be performed by the licensed professional engineer conducting the engineering review. This requirement includes conducting the site visits. The licensed professional engineer conducting the engineering review must perform the site visits to…
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Is corn oil extracted from distiller?s grains and solubles (DGS) eligible for RINs under RFS2?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Biodiesel or renewable diesel made from non-food grade corn oil extracted from DGS that is made from renewable biomass is eligible to generate RINs. See Table 1 to 80.1426.
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