Learn the Issues
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Superfund Sites with Industrial Reuse
Industrial use of formerly contaminated properties refers to traditional light and heavy industrial uses - processing, manufacturing, fabrication, assembly, and treatment.
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Confirm that ASTM method D-1319, Fluorescent Indicator Adsorption (FIA) can be used to determine aromatic and olefin levels until January 1, 1997.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes, the current version, ASTM method D-1319-93, is the regulatory method for olefins and may be used as an alternate for aromatics until January 1, 1997. For aromatics, it must also be correlated to the GC-MS method. Correlation to…
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Confirm that the only specification for a blendstock being added to finished gasoline in early use of the Simple Model is a per gallon specification not exceeding the antidumping baseline exhaust benzene level, (per Section 80.101(g)(3)), and later the exhaust toxic and exhaust NOx baseline levels in 1998 and beyond. This is very important to clearly understand as regular CBOB is not a fungible grade of gasoline. Component blending with finished regular and ethanol is a very important option to blending regular CBOB with ethanol in terminals. This option is critical whenever the refinery that feeds the CBOB terminals requires maintenance or has operational problems, and no other refinery that feeds that terminal makes regular CBOB.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Under the simple model for 1995-1997, refiners and importers are required to meet standards for exhaust benzene, sulfur, olefins and T90 on an annual average basis for conventional gasoline and, under certain conditions, applicable blendstocks as specified in §…
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Confirm that an RFG property measured from a sample collected during an EPA inspection is in technical violation if that property exceeds an applicable standard, but that no enforcement action will be brought by EPA unless the property exceeded the standard in question by at least the enforcement tolerance for that property.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. As stated in the preamble to the RFG final rule, at 59 FR 7764 (February 16, 1994), EPA will not initiate an enforcement action on the basis of a test result from a gasoline sample collected at a facility…
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For conventional gasolines, the annual compliance report is based on all gasolines. Can one monthly composite be made up of all grades of gasolines and all seasons produced in that month, rather than one composite for each grade and season when compliance is demonstrated with the simple model? the complex?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. For the criteria for using composite samples for compliance calculations, see § 80.101(i)(2). (10/17/94) This question and answer was posted at
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Do all properties have to be analyzed on-line to get an exemption from the independent laboratory sampling and testing requirement?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. However, EPA would prefer that in-line blending operations at least be capable of analyzing benzene, oxygen, and RVP on line. If the operation does not have the capability to analyze all properties on-line, the refiner must indicate in…
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Do I have to register to use CDX and is this a separate registration process?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. You will have to register with CDX. (Registering with CDX is not the same as registering under regulation Section 80.1150.) Instructions are available via our Reporting for Fuel Programs web site. Question and Answer was originally posted at: Questions…
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Do common carriers have any requirements or potential liability pertaining to the anti-dumping provision for conventional gasoline?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Common carriers (like all other regulated parties) are prohibited from distributing conventional gasoline for use in an RFG covered area, and must comply with the product transfer document requirements of § 80.106. (8/29/94) This question and answer was posted…
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Do terminals need to register?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Terminals do not need to register. However, terminals that engage in activities that require registration must be registered. For example, if the terminal takes ownership of RINs, then it must be registered as a RIN owner. Question and Answer…
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Do the sample handling requirements for oxygen and oxygenate content apply to the analysis of other fuel parameters?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The sample handling procedures must comply with the requirements of their individual testing methods. Aromatics, oxygen and oxygenate, benzene, olefins, and sulfur samples should be at room temperature, although aromatics samples for GC-MS analysis are measured gravimetrically and are…
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Do batch numbers have to be sequential? Do they have to correspond to the month that they represent (i.e. 1 - 12)?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Batch numbers need not be sequential and need not represent a full month. They need only be unique within a calendar year. Each producer or importer of renewable fuel can define a batch in whatever way it chooses, so…
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Do third party marketers like X Company need to track RINs from the ethanol plant to the buyer?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. If X Company takes ownership of ethanol along with assigned RINs, it would be required to register with the EPA and would be subject to the recordkeeping, reporting, product transfer document and attest engagement requirements of regulation Sections 80.1151(d)…
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Does blending oxygenate in conventional gasoline at a terminal require the terminal operator to be registered as an "oxygenate blender?"
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The downstream blender of oxygenates exclusively into conventional gasoline is not subject to the anti-dumping requirements and therefore does not require registration by the operator. (7/1/94) This question and answer was posted at
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Ethanol is imported on an undenatured basis. Do we assign the RINs to the denatured volume or the undenatured volume?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Denatured. See regulation Sections 80.1101(d)(3) and 80.1115(b)(2). Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (pdf) (55 pp, 221 KB, EPA420-F-07-041a, August 2007)
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Does EPA agree that the California Exemption section of the RFG rule facilitates using the complex model for anti-dumping with the Commencement of CARB Phase 2 RFG effective 3\1\96?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section § 80.41(i) of the federal regulation requires that during each calendar year 1995 through 1997 any refinery or importer shall be subject to the simple model standards or the Phase I complex model standards, at the option of…
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Since ethanol use is expected to surpass the mandated EPAct levels, is there any mechanism available to EPA to allow compliance on a national collective basis, as was done under the 2006 default rule?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. The Energy Policy Act included a specific default provision for 2006 that was to go into effect if the RFS program regulations were not in place. That provision was expressed in general terms, allowing EPA to structure the…
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EPA has stated that the transferor "must provide to the transferee... product transfer documents." On an import the transferor is a foreign entity presumably not subject to our laws. How do we ensure that the foreign refiner provides all information? As importers are we to generate it ourselves?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Foreign refiner are not subject to the PTD requirements, unless they are also importers. Importers are required to provide PTD information to all parties to whom they transfer title or custody of RFG, RBOB or Conventional gasoline. (8/29/94) This…
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Explain the volume determination requirement for independent labs.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.65(f)(3)(i)(B) requires the independent lab to determine the volume of each RFG batch that is sampled. EPA expects the independent lab will determine the volume of a RFG batch in the same manner gasoline volumes currently are determined…
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The final rule on page 23909 (Federal Register, volume 72) states that any non-obligated party that takes ownership of the renewable fuel with RINs will be required to transfer those RINs with a volume of renewable fuel. Does this refer to oxygenate blenders?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No, as long as the blender actually blends the renewable fuel into gasoline or diesel. In that case, the blender would be required to separate the assigned RINs from the blended renewable fuel, and could then transfer the RINs…
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The following is a two-part question: a. We are a petroleum refiner and recognize that we are an obligated party under the regulation. We are considering importing ethanol that has not been denatured. We will hold title to the un-denatured ethanol. Title and custody will pass to another party who will denature the ethanol and transfer title back to us. We will sell it for use as a motor fuel. Are we an importer of renewable fuel under the RFS program? b. How would RINs be generated?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. A. Un-denatured ethanol is not a renewable fuel. See 80.1101(d)(3). Under the described scenario, the party to whom custody is transferred and who denatures the ethanol would be producer of the renewable fuel. B. Under the described scenario, RINs…