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Criteria for selecting alternative release scenarios
As part of the hazard assessment, owners and operators of Program 2 and Program 3 covered processes must identify and analyze alternative release scenarios (40 CFR §68.28). What criteria should be used when selecting an alternative release scenario? The owner or operator of a stationary source subject to the risk…
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Does the distance to endpoint start at the process or stationary source boundary?
When selecting the worst-case release scenario for Program 2 and 3 processes as required by 40 CFR §68.25, a stationary source owner or operator must analyze the release scenario that results in the greatest distance to an endpoint. Does the "greatest distance to an endpoint" refer to the greatest total…
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Using meteorological station data for off-site consequence analyses
For the purpose of the offsite consequence analyses required under 40 CFR Part 68, Subpart B, there are several instances in which data gathered at a local meteorological station may be used to establish the modeling parameters of wind speed, atmospheric stability, temperature, and humidity for the stationary source. How…
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Underground storage tank off-site impacts to groundwater, drinking water, or soil
For the worst-case and alternative release scenarios of an underground storage tank, should I consider any impact on groundwater, drinking water, or soil? No. As part of the worst-case and alternative release scenarios, you need to define the offsite impacts to the environment (40 CFR §68.33) by listing the environmental…
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Administrative controls considered when determining worst-case release quantity
For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity…
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Are Mechanical Controls Considered Administrative Controls?
For the purpose of analyzing the worst-case release scenario required as part of the hazard assessment at 40 CFR Part 68, Subpart B, the worst-case release quantity is identified as the greatest amount held in a single vessel or pipe, taking into account administrative controls that limit the maximum quantity…
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Worst-case release from smaller process with larger distance to endpoint
The owner or operator of a stationary source covered by the risk management program regulations must conduct a worst-case release scenario analysis as part of the required hazard assessment (40 CFR §68.25). The worst-case release is defined as the release of the largest quantity of a regulated substance from a…
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Can I use any previous three year meteorological data for worst case scenario?
I am trying to complete my worst case release scenario for the Risk Management Plan under §68.25. I understand that I am required to use a wind speed of 1.5 m/s and F atmospheric stability class as specified in §68.22(b), unless I can prove that at no time over the…
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All I do is produce corn ethanol and sell it all to X Company, which is an ethanol marketer. Do I have to do anything, or can X Company generate the RINs for me?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Each producer of renewable fuel is responsible for generating the RINs that represent that renewable fuel. This function cannot be delegated or assigned to any other party, including a party to whom a producer sells its product. Question…
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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…
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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 curre
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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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
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"…
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If a specific refinery is the producer of renewable diesel, I assume they need a facility ID number, but we can use the RINs for aggregate company compliance.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. The facility ID number is used to generate the RIN, but the RIN can be separated and used for compliance on a company-wide aggregate basis, subject to any applicable restrictions in the regulations such as regulation Sections…
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A tank of ethanol has become contaminated and must be disposed of. How would we treat this situation for RIN reporting under the RFS program?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The RFS regulation envisions various scenarios under which RINs might be retired. The reporting section in the regulation names a few examples: retirement in satisfaction of enforcement action, spill, and use in a boiler or heater. We recognize…
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What metering system does the plant use to measure gallons? Is it a production meter, a load-out meter, etc.?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA regulations provide flexibility in terms of the specific mechanisms through which producers and importers measure volumes for purposes of generating RINs. However, the approach should ensure that gallons are neither systematically ignored nor systematically double-counted. Also, approaches…
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