Learn the Issues
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If an ethanol producer imports a truckload of gasoline, they are an obligated party and have an RVO. Does this mean that they can separate RINs from all the ethanol they produce?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Not necessarily. Obligated parties can only separate RINs they generated for renewable fuel they produced or imported up to the level of their RVO. They are not allowed to separate additional RINs that they generated. However, obligated parties must…
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If blenders either opt not to trade or are not allowed to trade, who will be responsible for tracking these RINs through the system?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The blender must submit quarterly RIN transaction reports to EPA that will document all RIN transactions, including RIN purchases, RIN sales, and expired RINs. RINs that are reported purchased and thereafter are not sold will be identifiable through these…
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We are considering developing a PTD that lists ethanol and denaturant as separate items being transferred. RINs would be generated for the entire volume of denatured ethanol. If, for example, we transfer 950 gallons of ethanol and 50 gallons of denaturant, may we split the gallon- RINs between ethanol and denaturant? Or would we only indicate the number of gallon-RINs associated with the entire volume of denatured ethanol (i.e., 1000 gallons)?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The RINS should not be split between ethanol and denaturant. Section 80.1153(a) of the RFS rule refers to "the volume of renewable fuel that is being transferred" as necessary information for PTDs. Denatured ethanol is the "renewable fuel" in…
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Are the min/maxs that are required on the PTD's for RBOB, intended to address the pre-oxygenate blended RBOB or the post-oxygenate blended RBOB?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The post-oxygenate blended RBOB. (7/1/94) This question and answer was posted at
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Can you identify absolute minimum data requirements and margin for auditor judgments to minimize petitions for deficient data?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. The amount of data that is sufficient to develop a baseline will depend on the individual case. The baseline auditor does have some flexibility in using their judgment to determine what is appropriate, but the rationale and detailed…
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Section 80.1151(b)(3)(vii) requires retention of additional information related to the details of RIN generation. What does this mean?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Companies vary in their internal recordkeeping practices and not all similar records will take identical form. Therefore, in several places in the recordkeeping section (80.1151) we have required that "additional" information be retained. We certainly do not wish to…
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Section 80.41(h)(1) specifies that RFG may contain no heavy metals. What specifically does that mean, and is a refiner required to test for the presence of heavy metals?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The prohibition of heavy metals in RFG means that heavy metals may not be added, nor may it contain more than trace levels that may be picked up from the transportation/distribution system. In fact, no substantially similar unleaded gasoline…
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Must sampling be performed only from tank storage, or will pipeline sampling qualify?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. For a refiner, pipeline sampling is appropriate when performed according to the procedures outlined in 40 CFR part 80, Appendix D. Appendix D, section 11.4 describes how to collect a continuous or intermittent flow proportional sample, using automatic sampling…
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Must a terminal be registered as a refinery in order to blend transmix?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. EPA has described procedures for pipelines to blend transmix into conventional gasoline and RFG under certain situations. A pipeline that blends transmix into either conventional gasoline or RFG using the procedures described in these answers will not be treated…
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Section 80.65(e) lists properties that product must be tested for before shipment. Some of these do not have standards in the simple model. Is it necessary to test, and ultimately report, those parameters not required for the simple model? Is reporting of all tests required or just those required for the simple model?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Refiners and importers must test for each parameter listed in § 80.65(e) for RFG certified under the simple model with the exception of T-50 and, in the case of non-VOC controlled RFG, RVP. However, in the case of simple…
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Must the "specific language required," i.e., statement regarding conventional gasoline, be put on terminal truck Bills of Lading?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section § 80.106(a)(1) states that on each occasion "when any person transfers custody or title to any conventional gasoline," the transferor must provide to the transferee documents which include the statement contained in § 80.106(a)(1)(vii). Accordingly, the statement must…
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My company currently sells distillate blendstocks. Can we continue to sell blendstocks given the new regulations?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes, you may continue to sell blendstocks. In addition, it would also be in your best interest, for defense purposes, to identify any product that you ship. Question and Answer was originally posted at Questions and Answers on the…
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With no set procedure for declaring per gallon/averaging, it appears a refinery has until the first quarterly report to make a decision. As long as per-gallon standards were met up to the point the first quarterly report is filed, and the refiner meets the gasoline quality survey requirements, the option would remain open to go averaging for the year. Is this acceptable?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. It is true that EPA did not include in the RFG rule a process for regulated parties to notify EPA in advance of per-gallon versus averaging. As a result, the strategy described in the question would be appropriate. (7/1/94)…
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No Equivalence Value was provided for ETBE. What value do I use for generating RINs for ETBE?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The RFS program prohibits a party from generating RINs if the renewable feedstock used to make the renewable fuel was acquired from another party. Any RINs acquired with the renewable feedstock (e.g., ethanol) must be assigned to the renewable…
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Now that EPA has issued final regulations for reformulated and conventional gasoline, what if any state fuel controls are preempted?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. After EPA promulgates a federal fuel control or prohibition under section 211(c)(1) of the Act, state fuel controls respecting the same fuel characteristic or component as the federal regulation are preempted. A state may only adopt and enforce such…
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Where are the product transfer documents requirements found in the RFG regulations and what do they require?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The product transfer documents (PTD) requirements are found in § 80.77 of the regulations for reformulated gasoline and RBOB and in § 80.106 for conventional gasoline. These sections require that on each occasion when any person transfers title or…
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When is a RIN generated for ethanol that is imported into the U.S.?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Ethanol imported for use as motor vehicle fuel would typically be downloaded from a ship into on-shore tankage and then denatured. (Ethanol shipped to the United States from other countries is not typically denatured prior to or during shipment.)…
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Hazardous Waste Cleanup: Ortho-Clinical Diagnostics, Raritan, New Jersey
Ortho-Clinical Diagnostics (OCD) is an administration and manufacturing facility located at 1001 U.S. Route 202 North in Raritan Borough, Somerset County, New Jersey. The facility manufactures hospital and laboratory reagents used primarily for blood
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Resubmitting or correcting reports
This page provides information for resubmitting or correcting reports.
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Approved Alternate Phase 2 Compliance Deadlines
Table of approved alternative compliance Phase 2 deadlines.