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Determining frequency of coordination activities
The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). Are stationary sources responsible for determining if coordination activities should occur more often than annually? Ultimate responsibility…
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In the past, EPA has, with the assistance of industry trade associations, produced fuels brochures for use at retail outlets explaining new fuel programs and addressing performance and air quality issues. Is EPA planning a similar effort with respect to t
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In November 2005, the Clean Diesel Fuel Alliance was formed. Many public and private organizations are collaborating through the Clean Diesel Fuel Alliance to facilitate the introduction of ULSD. The U.S. Department of Energy (DOE), EPA, engine, vehicle…
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Who Must Develop an Emergency Response Program?
The risk management program regulations require the owner or operator of a covered stationary source to develop and implement an emergency response program as described in 40 CFR §68.95, which must include an emergency response plan, emergency response equipment procedures, employee training, and procedures to ensure the program is up-to-date…
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Does an ethanol producer who sells undenatured ethanol to a U.S. importer who denatures it at the port need to register with EPA under RFS?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The RFS regulations specify that foreign producers of ethanol for use in transportation fuel, heating oil or jet fuel for import to the US who do not add denaturant to their product, must register under RFS. See 80.1450(b)…
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A tank truck common carrier picks up a load of ULSD at a Shell terminal and delivers it to a Flying J truckstop. The carrier only provides a transportation service, does that carrier have any registration or reporting duties?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No, the carrier does not have registration or reporting duties as long as taxes were assessed (in the case of highway fuel) or dye was added (in the case of NRLM) at the terminal. There are recordkeeping and…
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Will refiners produce No. 1 diesel fuel at 15 ppm sulfur? What other cold weather-gelling strategies are available to the end-user?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes, some refiners will produce No. 1 diesel fuel. There are also various other cold-flow improver additives currently on the market as well. Question and Answer was originally posted at Questions and Answers on the Clean Diesel Fuel…
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Many refiners currently make a jet fuel meeting <500 ppm requirements. If refiners make a jet fuel meeting 15 ppm requirements, there may be compatibility (safety or performance) issues for jet engine manufacturers. Have these manufacturers been consulted
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The highway and nonroad diesel programs do not require that refiners produce 15 ppm sulfur jet fuel and do not set sulfur limits for jet fuel that is not designated as motor vehicle diesel fuel. This would be…
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Remote coordination with local authorities
The Risk Management Program regulations require owners and operators of stationary sources to coordinate their response needs annually, or more frequently if necessary, with local emergency planning and response organizations (40 CFR §68.93(a)). If a stationary source is in a remote location and in-person annual coordination is deemed impractical, can…
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If a terminal imports off-spec kerosene (higher than 15 ppm), terminal operators are planning to blend the kerosene with diesel fuel so that the ultimate diesel fuel leaving the terminal gate and entering into commerce meets the 15 ppm standard.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The regulations at § 80.525(d) state that kerosene that a kerosene blender adds, or intends to add, to motor vehicle diesel fuel subject to the 15 ppm sulfur standard must meet the 15 ppm sulfur standard. Section 80.521(b)…
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What are the requirements for a foreign producer who wishes to generate RINs for the renewable fuel they produce?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Foreign producers who plan to generate RINs must register and conduct a third-party engineering review pursuant to section 80.1450. Additionally, such foreign producers must meet the requirements in section 80.1466 prior to generating any RINs for their fuel…
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Section 80.600(a)(10) says, Any refiner or importer shall maintain copies of all product transfer documents required under §80.590. If all information required in paragraph (a)(6) of this section is on the product transfer document for a batch, then the
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.600(a)(10) first requires that product transfer documents under § 80.590 be maintained by refiners and importers. It then states that if such product transfer documents contain all the information required under paragraph (a)(6) of § 80.600 for…
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Emergency Response Coordination Activities Effective Date
The RMP Amendments finalized on January 13, 2017 included a requirement for owners or operators of a stationary source to engage in emergency response coordination activities (40 CFR §68.93). The regulatory text in 40 CFR §68.10(b) states that compliance with these activities must be completed by March 14, 2018. Because…
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Are exercises required as a part of the emergency response program requirements under 40 CFR Part 68, Subpart E?
Yes. At least once each calendar year, the owner or operator of a stationary source with any Program 2 or Program 3 process must conduct an exercise of the stationary source's emergency response notification mechanisms per 40 CFR 68.90(b)(3) or 68.95(a)(1)(i), as appropriate, before December 19, 2024, and annually thereafter…
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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…
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Types of Information Relevant for Response Planning
The Risk Management Program emergency response coordination activities require the owner and operator of a stationary source to provide to the local emergency planning and response organizations: the stationary source’s emergency response plan if one exists; emergency action plan; updated emergency contact information; and any other information that local emergency…
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