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Draft Quality Assurance Plan
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- Informal Pre-Registered Pathways List: EcoEngineers
- Informal Pre-Registered Pathways List: RINPlus™ by EM Biofuels
- Informal Pre-Registered Pathways List: First Environment
- Informal Pre-Registered Pathways List: Genscape
- Informal Pre-Registered Pathways List: RINtrust
- Informal Pre-Registered Pathways List: Weaver and Tidwell, L.L.P. - RIN-tegrity®
RFS Quality Assurance Plans
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The Renewable Fuel Standard (RFS) program requires the use of Renewable Identification Numbers (RINs) to demonstrate compliance with the RFS volume obligations. RINs are generated by renewable fuel producers and importers and represent volumes that meet the requirements for renewable fuel under the RFS program. Once RINs have been generated, they can be transferred between parties and used by petroleum refiners and importers (obligated parties) to show compliance with their volume obligations. However, only RINs that were validly generated by the renewable fuel producer may be transferred or used for compliance purposes. Because of this, in some cases parties in the RFS program spend considerable time and effort in evaluating whether RINs were validly generated. EPA has issued a Notice of Proposed Rulemaking, which details a voluntary program geared towards providing a more structured way to assure that RINs entering commerce were validly generated. EPA expects the program to promote greater liquidity in the transfer and use of RINs, especially for smaller producers, helping to make the RFS program more efficient and effective. As the program is voluntary, there would be no required costs. The NPRM does not affect the volumes of renewable fuel required to be produced or the associated greenhouse gas or energy security benefits of the RFS program.
The NPRM proposes the use of voluntary third-party QAPs that could be used to verify that RINs have been validly generated. The proposal provides a recognized means for independent third-parties to audit the production of renewable fuel and the generation of RINs. The QAPs include such things as verification of type of feedstocks, verification that volumes produced are consistent with amount of feedstocks processed, and verification that RINs generated are appropriately categorized and match the volumes produced.
We are proposing two options that would be available for the verification of RINs through a QAP. The more stringent QAP A (PDF) (2 pp, 39K, EPA-420-B-13-007, January 2013) requires ongoing monitoring for many of the components, while the less stringent QAP B (PDF) (2 pp, 67K, EPA-420-B-13-008, January 2013) requires more infrequent quarterly monitoring. These options would provide flexibility in how parties choose to manage the risk of transferring or using invalid RINs and costs.
EPA is ready to facilitate the verification of RINs generated in 2013 prior to the final rule’s effective date through an informal “pre-registration (PDF)” (1 pp, 68K, EPA-420-B-13-006, January 2013) process. EPA will review auditors’ registration information and proposed QAPs, and provide guidance on whether the plans appear to satisfy the proposed requirements. The names of those auditors and QAPs whose submissions are consistent with the requirements in the proposed regulations will be published on EPA’s website. This will not signify a final agency decision or approval of any auditor or QAP and EPA will not be legally bound by this initial evaluation. It would instead be guidance to an auditor as to whether EPA has any concerns about its registration and QAP plan and whether they appear to be consistent with the requirements in the proposed regulations.
RINs audited prior to the effective date of the final rule through a QAP which EPA had published on its website would not necessarily be deemed “verified” under the terms of the final rule. RINs could only be deemed “verified” after the final rule goes into effect, and after EPA approved the QAP that was used in the audit process. EPA’s intention, however, is that the provisions and requirements proposed in this NPRM would apply to RINs verified prior to the final rule, and any changes in the final rule to the proposed provisions would apply only to RINs verified after the final rule is effective.
QAP’s Pre-registered by EPA as of May 1, 2013**
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Informal Pre-Registered Pathways List: EcoEngineers
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| Fuel type | Feedstock | Production process requirements | D-Code | QAP Type | Production Location |
|---|---|---|---|---|---|
| Biodiesel, and renewable diesel | Soy bean oil; Oil from annual covercrops; Algal oil; Biogenic waste oils/fats/greases; Non-food grade corn oil |
One of the following: Trans-Esterification Hydrotreating Excluding processes that co-process renewable biomass and petroleum |
4 | A,B | US |
| Biodiesel | Canola oil | Trans-Esterification using natural gas or biomass for process energy | 4 | A,B | US |
| Renewable diesel and naphtha | The non-cellulosic portions of separated food waste | Any | 5 | A,B | US |
| Biogas | Landfills, sewage waste treatment plants, manure digesters | Any | 5 | A,B | US |
| Ethanol | Corn starch and/or grandfathered feedstock | Grandfathered: Dry Mill, Natural Gas Fired |
6 | A,B | US |
| Ethanol | Corn starch and/or grandfathered feedstock | Grandfathered: Dry Mill, Coal Fired |
6 | A,B | US |
| Ethanol | Corn starch and/or grandfathered feedstock | Grandfathered: Dry Mill, Biomass Fired |
6 | A,B | US |
| Ethanol | Corn starch and/or grandfathered feedstock | Grandfathered: Wet Mill, Natural Gas Fired |
6 | A,B | US |
| Ethanol | Corn starch and/or grandfathered feedstock | Grandfathered: Wet Mill, Coal Fired |
6 | A,B | US |
| Ethanol | Corn starch and/or grandfathered feedstock | Grandfathered: Wet Mill, Biomass Fired |
6 | A,B | US |
|
Informal Pre-Registered Pathways List: RINPlus™ by EM Biofuels
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| Fuel type | Feedstock | Production process requirements | D-Code | QAP Type | Production Location |
| Biodiesel, and renewable diesel | Soy bean oil; Oil from annual covercrops; Algal oil; Biogenic waste oils/fats/greases; Non-food grade corn oil |
One of the following: Trans-Esterification Hydrotreating Excluding processes that co-process renewable biomass and petroleum |
4 | A,B | US |
| Biodiesel | Canola oil | Trans-Esterification using natural gas or biomass for process energy | 4 | A,B | US |
| Ethanol | Grain Sorghum | All of the following: Dry mill process, using only biogas from lanfills, waste treatment plants, and/or waste digesters for process energy and for on-site production of all electricity used at the site other than up to 0.15 kWh of electricity from the grid per gallon of ethanol produced, calculated on a per batch basis |
5 | A,B | US |
| Biodiesel, and renewable diesel | Soy bean oil; Oil from annual covercrops; Algal oil; Biogenic waste oils/fats/greases; Non-food grade corn oil |
One of the following: Trans-Esterification Hydrotreating Includes only processes that co-process renewable biomass and petroleum |
5 | A,B | US |
| Ethanol | Non-Cellulosic Portions of Separated Food Waste | Any | 5 | A,B | US |
| Ethanol | Corn starch | All of the following: Dry mill process, using natural gas, biomass, or biogas for process energy and at least two advanced technologies from Table 2 to this section |
6 | A,B | US |
| Ethanol | Corn starch | All of the following: Dry mill process, using natural gas, biomass, or biogas for process energy and at least one of the advanced technologies from Table 2 to this section plus drying no more than 65% of the distillers grains with solubles it markets annually |
6 | A,B | US |
| Ethanol | Corn starch | All of the following: Dry mill process, using natural gas, biomass, or biogas for process energy and drying no more than 50% of the distillers grains with solubles it markets annually |
6 | A,B | US |
| Ethanol | Corn starch | Wet mill process using biomass or biogas for process energy | 6 | A,B | US |
| Ethanol | Starches from crop residue and annual covercrops | Fermentation using natural gas, biomass, or biogas for process energy | 6 | A,B | US |
| Ethanol | Grain Sorghum | All of the following: Dry mill process, using biogas from landfills, waste treatment plants, and/or waste digesters, and/or natural gas, for process energy |
6 | A,B | US |
|
Informal Pre-Registered Pathways List: First Environment
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| Fuel type | Feedstock | Production process requirements | D-Code | QAP Type | Production Location |
| Biodiesel, and renewable diesel | Soy bean oil; Oil from annual covercrops; Algal oil; Biogenic waste oils/fats/greases; Non-food grade corn oil |
One of the following: Trans-Esterification Hydrotreating Excluding processes that co-process renewable biomass and petroleum |
4 | B | US |
| Biodiesel | Canola oil | Trans-Esterification using natural gas or biomass for process energy | 4 | B | US |
| Biogas | Landfills, sewage waste treatment plants, manure digesters | Any | 5 | B | US |
| Biodiesel and renewable diesel | Soy bean oil; Oil from annual covercrops; Algal oil; Biogenic waste oils/fats/greases; Non-food grade corn oil |
One of the following: Trans-Esterification Hydrotreating Includes only processes that co-process renewable biomass and petroleum |
5 | B | US |
| Ethanol | Corn starch | All of the following: Dry mill process, using natural gas, biomass, or biogas for process energy and at least two advanced technologies from §80.1426 Table 2 |
6 | B | US |
|
Informal Pre-Registered Pathways List: Genscape
|
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| Fuel type | Feedstock | Production process requirements | D- Code | QAP Type | Production Location |
| Biodiesel, and renewable diesel | Soy bean oil; Oil from annual covercrops; Algal oil; Biogenic waste oils/fats/greases; Non-food grade corn oil |
One of the following: Trans-Esterification Hydrotreating Excluding processes that co-process renewable biomass and petroleum |
4 | A,B | US |
| Renewable Diesel | Soy bean oil; Oil from annual covercrops; Algal oil; Biogenic waste oils/fats/greases; Non-food grade corn oil |
Triton Process, Dedicated Renewable Biomass Facility; Viesel Process, Dedicated Renewable Biomass Facility | 4 | A,B | US |
| Biodiesel | Canola oil | Trans-Esterification using natural gas or biomass for process energy | 4 | A,B | US |
| Biodiesel, and renewable diesel | Soy bean oil; Oil from annual covercrops; Algal oil; Biogenic waste oils/fats/greases; Non-food grade corn oil |
One of the following: Trans-Esterification Hydrotreating Includes only processes that co-process renewable biomass and petroleum |
5 | A,B | US |
| Renewable diesel, heating oil | The non-cellulosic portions of separated food waste | Any | 5 | A,B | US |
| Ethanol | Grain Sorghum | Dry mill process, using only biogas from landfills, waste treatment plants, and/or waste digesters for process energy and for on-site production of all electricity used at the site other than up to 0.15 kWh of electricity from the grid per gallon of ethanol produced, calculated on a per batch basis | 5 | B | US |
| Ethanol | Corn starch and/or grandfathered feedstock | Grandfathered: Production process based on 1403(c) |
6 | B | US |
| Ethanol | Corn starch and/or grandfathered feedstock | Grandfathered: Production process based on 1403(d) |
6 | B | US |
| Ethanol | Corn starch | All of the following: Dry mill process, using natural gas, biomass, or biogas for process energy and at least two advanced technologies from §80.1426 Table 2 |
6 | B | US |
| Ethanol | Corn starch | All of the following: Dry mill process, using natural gas, biomass, or biogas for process energy and at least one of the advanced technologies from §80.1426 Table 2 plus drying no more than 65% of the distillers grains with solubles it markets annually |
6 | B | US |
| Ethanol | Corn starch | All of the following: Dry mill process, using natural gas, biomass, or biogas for process energy and drying no more than 50% of the distillers grains with solubles it markets annually |
6 | B | US |
| Ethanol | Corn starch | Wet mill process using biomass or biogas for process energy | 6 | B | US |
| Ethanol | Corn starch | Fermentation using natural gas, biomass, or biogas for process energy | 6 | B | US |
| Ethanol | Grain Sorghum | Dry mill process using biogas from landfills, waste treatment plants, and/or waste digesters, and/or natural gas, for process energy | 6 | B | US |
|
Informal Pre-Registered Pathways List: RINtrust
|
|||||
| Fuel type | Feedstock | Production process requirements | D- Code | QAP Type | Production Location |
| Biodiesel, and renewable diesel | Soy bean oil; Oil from annual covercrops; Algal oil; Biogenic waste oils/fats/greases; Non-food grade corn oil |
One of the following: Trans-Esterification Hydrotreating Excluding processes that co-process renewable biomass and petroleum |
4 | A,B | US |
| Biodiesel | Canola oil | Trans-Esterification using natural gas or biomass for process energy | 4 | A,B | US |
|
Informal Pre-Registered Pathways List: Weaver and Tidwell, L.L.P. - RIN-tegrity®
|
|||||
| Fuel type | Feedstock | Production process requirements | D- Code | QAP Type | Production Location |
| Ethanol | Cellulosic Biomass from crop residue, slash, pre-commercial thinnings, tree residue, annual cover crops; cellulosic components of separated yard waste; cellulosic components of separated food waste; and cellulosic components of separated MSW | Any | 3 | B | US |
| Biodiesel and renewable diesel | Soy bean oil; Oil from annual covercrops; Algal oil; Biogenic waste oils/fats/greases; Non-food grade corn oil |
One of the following: Trans-Esterification Hydrotreating Excluding processes that co-process renewable biomass and petroleum |
4 | B | US |
| Biodiesel | Canola oil | Trans-Esterification using natural gas or biomass for process energy | 4 | B | US |
| Ethanol | Grain Sorghum | All of the following: Dry mill process, using only biogas from lanfills, waste treatment plants, and/or waste digesters for process energy and for on-site production of all electricity used at the site other than up to 0.15 kWh of electricity from the grid per gallon of ethanol produced, calculated on a per batch basis |
5 | B | US |
| Biodiesel and renewable diesel | Soy bean oil; Oil from annual covercrops; Algal oil; Biogenic waste oils/fats/greases; Non-food grade corn oil |
One of the following: Trans-Esterification Hydrotreating Includes only processes that co-process renewable biomass and petroleum |
5 | B | US |
| Naphtha, Ethanol | Non-Cellulosic Portions of Separated Food Waste | Any | 5 | B | US |
| Biogas | Landfills, sewage waste treatment plants, manure digesters | Any | 5 | B | US |
| Ethanol | Corn starch | All of the following: Dry mill process, using natural gas, biomass, or biogas for process energy and at least two advanced technologies from §80.1426 Table 2 |
6 | B | US |
| Ethanol | Corn starch | All of the following: Dry mill process, using natural gas, biomass, or biogas for process energy and at least one of the advanced technologies from §80.1426 Table 2 plus drying no more than 65% of the distillers grains with solubles it markets annually |
6 | B | US |
| Ethanol | Corn starch | All of the following: Dry mill process, using natural gas, biomass, or biogas for process energy and drying no more than 50% of the distillers grains with solubles it markets annually |
6 | B | US |
| Ethanol | Corn starch | Wet mill process using biomass or biogas for process energy | 6 | B | US |
| Ethanol | Starches from crop residue and annual covercrops | Fermentation using natural gas, biomass, or biogas for process energy | 6 | B | US |
| Ethanol | Grain Sorghum | All of the following: Dry mill process, using biogas from landfills, waste treatment plants, and/or waste digesters, and/or natural gas, for process energy |
6 | B | US |
| Cellulosic diesel, jet fuel, and heating oil | Cellulosic Biomass from crop residue, slash, pre-commercial thinnings, tree residue, annual cover crops; cellulosic components of separated yard waste; cellulosic components of separated food waste; and cellulosic components of separated MSW | Any | 7 | B | US |
| **EPA will continue to review pre-registration materials and will update this table as needed with any new pre-registered company information. |
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Pre-Registration documentation can be submitted to support@epamts-support.com
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