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How do the changes in the 2006 Amendments apply to mobile refuelers?
Mobile refuelers are now exempt from the following sized secondary containment provisions that still apply to all other bulk storage containers and mobile/portable bulk storage containers: • Sections 112.8(c)(2) and (11) for petroleum oils • Sections 112.12(c)(2) and (11) for animal fats and vegetable oils These provisions previously required sized…
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By our reading of the regulations, the only reporting required of the oxygenate blender who elects to comply with the oxygen standard on a per gallon basis is a yearly report due the last day of February of each year (beginning in 1996) that states the total volume of RFG produced along with the certification statement. Is our interpretation correct? Are we correct in assuming that batch numbers and individual batch data are not required as part of the report?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Your interpretation is correct. (10/31/94) This question and answer was originally posted at
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What is the definition of a responsible corporate officer (RCO) who is required to certify some of the submissions involved?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Under § 80.75(n), reports to EPA must be signed and certified as correct by the owner or a responsible corporate officer of the refiner, importer, or oxygenate blender. "Owner" means the person who is the principal owner of…
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Question 14, Section VI.C., of the July 1, 1994 Question and Answer Document provides an example of the creation and addition of two different batches to form a composite mixture. All or a portion of this composite is shipped as RFG. How will the refinery account for this shipment under recordkeeping and averaging requirements (assuming the refinery is averaging), based on the scenario outlined in Question 14?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Question 14 relates to in-line blending operations that have petitioned EPA for and received an exemption from the independent sampling and testing requirements of the RFG regulations. In such petitions, refiners often define a "batch" of in-line blended…
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SPCC Rule schedules for inspections, tests, and evaluations
The SPCC rule requires inspections, tests, and evaluations of above ground containers (40 CFR §112.8(c)(6)). Does the rule set schedules for how often these need to be conducted? The SPCC Rule does not prescribe a specific frequency or methodology for performing the required inspections, evaluations, and tests for aboveground containers…
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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…
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Regulation Section 80.1131(b)(4) states that, in the event that the same RIN is transferred to two or more parties, "all such RINs will be deemed to be invalid, unless EPA in its sole discretion determines that some portion of these RINS is valid." What’s the process to determine if a portion of RINs are valid?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In many circumstances, EPA will be able to determine whether any of the RINs (or particular gallon-RINs within a batch-RIN) are valid from the information submitted to EPA in the RIN generation and transaction reports. Through these reports…
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Are mobile refuelers exempt from integrity testing requirements?
Pursuant to 40 CFR §112.8(c)(2), mobile refuelers are exempt from the secondary containment requirements for bulk storage containers. Are mobile refuelers also exempt from the requirements for integrity testing in §112.8(c)(6)? Since mobile refuelers are mobile or portable bulk storage containers, the other provisions of §112.8(c) still apply. Therefore, mobile…
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What is EPA's intent on requiring the location of off-site records on the facility registration?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA needs to know where records are stored so that EPA inspectors may inspect those records. If a facility keeps some or all of its records off-site EPA needs to know the address of the primary off-site storage…
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Does the ratio of feedstock quantity used to volume of renewable fuel produced have any significance in the RFS program? Would it impact the qualification of a renewable fuel's pathway or the equivalence value of the fuel?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The amount of feedstock used to produce a biofuel is one of many factors that EPA takes into consideration in its assessment of the lifecycle GHG performance of a particular fuel pathway. However, once EPA establishes the lifecycle…
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I haven't 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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Regarding a batch for which the blend completion date is on the last day of the EPA reporting quarter, what if shipments, as EPA defines them, are not complete by the time reporting for that quarter is required? Is there going to be any facility to allow
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Sections 80.65(c) and 80.101(d)(1) require refiners to include in compliance calculations each batch of gasoline that is "produced." As a result, a batch of gasoline should be included in the averaging period when the batch is produced, rather…
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When reporting compliance parameters to EPA on the batch reports we are asked to report to a greater degree of precision than the regulations indicate for the standard. An example would be that the per-gallon oxygen content standard is supposed to be 2.0 weight percent. The EPA form asks for two places to the right of the decimal. Would we still be in compliance for the oxygen content if the reported value was 1.95 weight percent?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . You would be in compliance for the example described above. In order to determine compliance EPA will round all values to the appropriate decimal place for the applicable standard. If the digit immediately to the right of the…
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We assume that a terminal operator who stores gasoline for a terminalling customer is responsible for receiving transfer documentation on RFG and conventional gas moved into the terminal for the customer. The terminal then records and stores copies of the
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. (9/12/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf) (18.2 MB, July 2003, EPA420-R-03-009).
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