Learn the Issues
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For the purposes of the RFG sampling and testing requirements under § 80.65(e) and (f), may a refiner use the option under which the independent lab samples and tests 100% of the batches for some parameters, and use the option under which the refiner tests 100% of the batches and the independent lab samples 100% of the batches and tests 10% of the batches for other parameters?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Refiners and importers may not use the 100% independent lab analysis option for certain parameters and the 10% independent lab analysis option for other parameters, but must use the same option for all RFG parameters. However, a refiner…
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A procedure has been outlined by the EPA for the certification of oxygen content by meter for the oxyfuel program. Can this method be used for certification of oxygen content in reformulated gasoline? Is an exemption for in-line blending required?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. The regulatory method for oxygen testing, or the approved temporary method discussed in question 39, must be used for certification of reformulated gasoline produced at the refinery and also for blending oxygenate with RBOB. For further discussion…
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The preamble states: "As with all parameters, there will be only one regulatory distillation test method. However, other suitable methods may be used for defense purposes (but not to meet mandatory testing requirements) as long as they are properly correlated with the regulatory test method." Does this mean that for testing downstream of the refinery or import facility for quality assurances purposes, other methods may be used by a refiner for defense assuming they are correlated to the regulatory method?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. (7/1/94) This question and answer was posted at
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Prior to the RFS rule, industry has used an equation for standardization of ethanol volumes that carries the correction factor out to 5 digits rather than 7 digits as in the formula given in the RFS rule at 80.1126(d)(7)(i). Will use of the equation currently in practice suffice for purposes of compliance with the RFS rule?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Because the difference between the five-digit and seven-digit factors is extremely small, regulated parties may find that it makes no practical difference whether they use the shorter factor for batches of a certain size . If it makes…
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Please confirm that a terminal can blend complying grades of gasoline to form another grade of gasoline and the terminal would not be considered to be a refiner. An example would be the blending of premium unleaded and unleaded regular to provide mid-grade unleaded.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The blending of two certified RFG gasolines to make a mid-grade gasoline is permitted provided that the segregation restraints specified in section 80.78 are not violated. The terminal or gasoline station will not be considered a refiner provided…
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Please clarify and resolve the significant digit differences existing between the standard and enforcement tolerance specified, i.e. 8.3 psi RVP with a 0.30 psi enforcement tolerance.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The significant digit differences between the RVP standard and the enforcement tolerance arise from EPA's desire to resolve any questions about rounding of RVP measurements when an enforcement tolerance has been applied. Accordingly, for example, the 0.30 psi…
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Please define any restriction in the RFG program on mixing ethanol and ether fuels.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Under § 80.78(a)(8), no person may combine VOC-controlled RFG produced using ethanol with VOC-controlled RFG produced using any other oxygenate during the period of January 1 through September 15 of each year. This prohibition applies at all locations…
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Please describe the survey areas which are currently applicable.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Attached to this document as Attachment II is a list of the presently applicable survey areas including opt-in areas. This list is current as of June, 1994. (The Agency has promulgated a "corrections notice" which defines these areas.)…
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Please comment on how laboratories can discard erroneous test results. Also, please comment on the example of a test result which is clearly an outlier, but without a discernible cause.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Suspect test results should not be discarded, but should be treated according to the laboratory's quality assurance plan covering the test method. At a minimum, the plan should include steps to document that a result is suspect, the…
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Please clarify what is meant by industry standard.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . API has assisted EPA in determining industry standard by preparing a list of alternate test methods in use in 1990. Other test methods may also be considered, but there must be concurrence from the auditor that such test…
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The petition process referred to in § 80.65(f)(4) references RFG. Will in-line blenders of RBOB also be allowed to become exempt from the independent sampling/testing requirements through EPA approval of a petition?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes, refiners who blend RBOB using a computer-controlled in-line blending process are allowed to petition for exemption from the independent sampling and testing requirements. (7/1/94) This question and answer was posted at
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Please clarify how the facility aggregation option would work. Would the facility aggregation apply only to simple model RFG sulfur, T-90 and olefins compliance?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . A refiner may aggregate its refineries for anti-dumping compliance purposes under § 80.101(h). This aggregation option must be exercised for the 1995 averaging period, and may not thereafter be changed. In addition, under § 80.41(i) the refiner must…
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Develop or Update an Emergency Response Plan
For use by community water systems serving a population between 3,301 and 99,999 as they develop or revise emergency response plans.
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At our terminal, we transfer ownership of ethanol to our customers simultaneously with blending that ethanol into gasoline. Who owns the RINs?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . A RIN assigned to a volume of renewable fuel is separated by the party that owns that volume of renewable fuel at the time of blending. If a downstream customer is the owner of the volume of renewable…
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One pipeline has notified all shippers and suppliers that their metering ticket will be the official transfer document for all shipments. This appears to be appropriate for a transfer whereby the pipeline is delivering (or transferring custody to a party) but how can it be appropriate when the pipeline is receiving (or being the transferee) product from a shipper? Isn't the shipper required to provide its own document? Or can we rely on the pipeline's ticket which memorializes the transaction?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA does not require that there be an "official" transfer document. While the approach described in the question seems appropriate, the enforcement liability still remains with the transferor. As a result, the transferor should verify that the transferee…
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Electronic Reporting Requirements for Certain Information under the Toxic Substances Control Act
Describes TSCA eReporting guidance and information.
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Many states have adopted a 1.0 psi waiver for ethanol blends during the RVP control period. In areas where RFG is required, do states need to amend that regulation in any fashion in order to not be in conflict with RFG requirements?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In areas where RFG is required, states are preempted from having RVP requirements which are different from the RFG simple model requirements unless those requirements are approved by EPA as a SIP amendment which is necessary to attain…
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May batch numbers be used to identify petroleum products other than gasoline or gasoline blendstocks thereby causing gaps in the batch numbering sequence?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. (7/1/94) This question and answer was originally posted at
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Many refiners currently make a jet fuel meeting <500 ppm requirements. If refiners make a jet fuel meeting 15 ppm requirements, there may be compatibility (safety or performance) issues for jet engine manufacturers. Have these manufacturers been consulted in this rulemaking process? If so, what is their position on use of 15 ppm jet fuel?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The highway and nonroad diesel programs do not require that refiners produce 15 ppm sulfur jet fuel and do not set sulfur limits for jet fuel that is not designated as motor vehicle diesel fuel. This would be…
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Mold Remediation in Schools and Commercial Buildings Guide: Chapter 3
The content on this page is based on the guide by the same name. However, updates have been made to some resources and links. Here you can find information on mold prevention and remediation.