Learn the Issues
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A refinery has two product tanks in series; a 10,000 gallon tank in which blendstocks are combined to produce gasoline (a blend tank), followed by a 50,000 gallon tank which feeds directly to the rack. Customers pull product from the rack. There are no blend streams going into the 50,000 gallon tank. Can we just certify the 10,000 gallon tank for all the properties for a specific volume (batch), without actually sampling any product from the larger tank?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The refiner should certify the properties of each batch produced in the 10,000 gallon blend tank based on a sample of gasoline collected after all the blending components have been added and mixed. The volume of each batch would…
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Refiners or importers producing or importing RBOB must blend the proper amount of oxygen with the RBOB and test it for the regulated parameters pursuant to § 80.69(a)(2). Since they are not responsible for the oxygen content, must they test for oxygen, and, if they do test, must they report the results of the test for oxygen?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.69(a)(2) requires an RBOB producer or importer to add the specified type and amount of oxygenate to a representative sample of the RBOB and to determine the properties and characteristics of the resulting gasoline using the methodology specified…
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Regarding the requirement in § 80.69(a)(2) that refiners and importers blend a representative sample of an RBOB batch with refinery-specified oxygenate, the composition of specified oxygenate blended in the laboratory is likely to differ from the composition of oxygenate arriving at the blender terminal, in that smaller amounts of oxygenates may be present. May these smaller amounts of oxygenates be included for meeting the refiner's blending instructions where a particular oxygenate type has been specified by the refiner or importer?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. EPA will not consider the refiner's blending instructions to be compromised where the specified oxygenate contains de minimis amounts of other oxygenates resulting in the RFG produced to contain other oxygenates in amounts no more than: 0.4 vol% ethanol…
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What business activity should producers and marketers register under?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Producers and marketers should register as RIN owners and, as appropriate as an ethanol producer/importer, biodiesel producer/importer, and under any other category that applies to them. Registration is available on-line at Registration for Fuel Programs. If a party is…
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What is the definition of oxygenated fuels program control area and oxygenated fuels program control period?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. As per section 80.2 of the regulations, an oxygenated fuels program control area means a geographic area in which only oxygenated gasoline may be sold or dispensed during the control period. An oxygenated fuels program control period means the…
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What is the definition of sulfur in gasoline?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The sulfur portion of all sulfur forms and compounds. (7/1/94) This question and answer was posted at
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How can a marketer transfer RINs with a K code of 1 and fulfill the requirement that "No person may transfer a RIN that has a K code of 1 without transferring an appropriate volume of renewable fuel to the same person on the same day" ?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. A party may transfer any volume of renewable fuel to any other party without simultaneously transferring any assigned RINs to that same party. However, assigned RINs can only be transferred to another party in association with the transfer of…
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How do owners of the ethanol account for product samples taken at the plant and downstream relative to RINs? Likewise, how is standard product shrinkage (i.e. when ethanol is transferred to a terminal) handled relative to RINs?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. In general, the RINs associated with small volumes removed for sampling and testing, or lost due to evaporation, leakage, or metering imprecision, remain valid for RFS compliance purposes. Small volume losses can be accommodated through the regulatory provision which…
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I have not seen a reference to the EPA CDX system. Is the CDX system already established or can we submit reports in our choice of electronic formats?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The Central Data Exchange (CDX) is an established portal through which electronic data are submitted. All registered parties will have to first register with CDX in order to receive a CDX registration number. More information may be found at…
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How should a party producing reformulated gasoline or RBOB make the designation of per gallon or average for the appropriate fuel parameters?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. If filing by paper, the party should submit the Annual Compliance Designation with its first quarter batch reports. If filing electronically, the first batch report transmitted must include the designations which will apply to each subsequent batch for that…
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I will be making ethanol from both cellulosic feedstocks and corn in my plant. How do I know what Equivalence Value to use, and how do I assign RINs to batches?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The batches of each type of ethanol (cellulosic or corn) should be measured independently and precisely, according to the separate processes used to produce them in the plant. Once separate batch numbers are created and RINs are generated, the…
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I will be making renewable gasoline from renewable crude. Section 80.1115(b)(6) of the regulations says I must use an Equivalence Value of 1.0 even though renewable gasoline clearly warrants a higher Equivalence Value. Can I submit a petition?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes. See regulation Section 80.1115(c)(2). However, for renewable fuels other than renewable diesel which are made from renewable crudes, information on the energy content and/or renewable content may be difficult to obtain. This is why we designated the Equivalence…
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Why are credits and allotments expressed in ppm-gallons and not in ppm-barrels, since barrels or thousand barrels are the commercial units used by refiners?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Consistent with the requirements under the RFG program, § 80.195(a)(2) provides that, for purposes of sulfur compliance and reporting, volumes are expressed in gallons. Accordingly, credits and allotments are required to be calculated and reported in units of ppm-gallons…
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Section 80.1164(a)(1)(ii) of the regulation states that the CPA conducting the attest engagement must obtain documentation of any volumes of renewable fuel used in gasoline during the reporting year; compute and report as a finding the volumes of renewable fuel represented in these documents. What does this mean?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. This provision is intended to require the CPA to include in his or her report any volume of renewable fuel actually used in gasoline produced at the refinery or imported by the importer, but is not intended to include…
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Where in the final anti-dumping regulations are oxygenate blenders excluded from the antidumping requirements?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Although oxygenate blenders have been considered refiners under previous EPA programs, they have been defined separately from refiners under § 80.2 for the purpose of specific requirements under the RFG program. The regulations specify that only refiners and importers…
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Where a company is both an obligated party and an importer of renewable fuel, the company will generate RINs in its importer capacity and separate the RINs from the volume of imported fuel in its capacity as an obligated party. Is this activity considered
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No transaction report is required for internal company transfers as all RINs are owned at the corporate level. The company would submit a RIN generation report for the RINs it generated for the imported renewable fuel and a compliance…
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Where is it required in the regulations that the PTD's for RFG must designate the finished gasoline as meeting the oxygenate standard on the per-gallon or average? Would it not be sufficient to infer the average standards from the listings of min/max's on the PTD? This requirement is not found in § 80.77.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The PTD requirements for RFG do not require that gasoline be designated as meeting the standards, including the oxygenate standard, per-gallon or average. Section 80.77 does require that PTD information include the minimum and maximum downstream standards with which…
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Where should registrations and reports be sent?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. U.S. Environmental Protection Agency Attn: REFGAS (6406J) 1200 Pennsylvania Ave., NW Washington, DC 20460 (7/1/94) This question and answer was originally posted at
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Why must oxygen and benzene credits pass only from creator to user? Why can't a blender or importer buy credits in advance as a safety measure, and then sell or resell them if/when (within the averaging period) it is established that it has performed better than expected?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The regulations do not provide for the reselling of credits. However, there may be ways for businesses to provide some flexibility, such options to buy credits which extend to the end of the averaging period. (8/29/94) This question and…
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Will the Complex Model for NOx emissions take additive effects into account?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. However, the Complex Model can be augmented through the vehicle testing procedure outlined in the final rule to include the emission effects of an additive. (7/1/94) This question and answer was posted at