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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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Can a gallon of ethanol generate more than 1.0 RIN in RFS2?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The number of RINs that can be generated for each gallon of renewable fuel are determined by the Equivalence Values. See 80.1415 and 80.1426(f)(2)-(6). Equivalence Values are based on energy content in the renewable fuel in comparison to…
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If I produce biodiesel using waste vegetable oil, can I generate more RINs per gallon than if I use virgin soy oil? Would the use of solar panels as a heat source for our process help with our RIN number per gallon?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The number of RINs that can be generated for each gallon of renewable fuel is determined by the Equivalence Values. See regulations at 80.1415(b) and 8.1426(f)(2)(i), for example. Equivalence Values are based on energy content in the renewable…
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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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What are the recordkeeping requirements for a renewable fuel producer that uses used cooking oils and fats as feedstocks for renewable fuel?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Renewable fuel producers using used cooking oils or animal wastes as feedstocks are required under 40 CFR 80.1454(d)(3) to obtain from their feedstock supplier, and maintain in their records, documents which certify that the feedstock meets the definition…
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What is the operational tolerance for denaturant in ethanol to meet the definition of Renewable Fuel? The RFS2 definition calls for a maximum of 2% denaturant. What if the lab results come back higher or lower than 2%? For example, what if the lab results
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The definition of renewable fuel in 80.1401 specifies that the maximum amount of denaturant in ethanol that can be treated as renewable fuel is 2 volume percent. If lab results indicate that the concentration of denaturant is higher…
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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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How does the "active management" requirement in the definition of renewable biomass apply to land that changes status in the future?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In RFS2, EPA has interpreted the EISA requirement that existing agricultural land be "cleared or cultivated at any time prior to [December 19, 2007] and actively managed or fallow and nonforested" to apply to land that existed as…
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If a producer is able to change its D code, can it make retroactive changes in the D code of the RINs it has issued previously during the year or earlier if the production during the previous period would meet the newly classified D code criteria?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Once a RIN is generated and transferred to another party, it cannot be changed. Thus, retroactive changes to D codes in RINs are not allowed.
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What materials from non-federal forestlands meet the definition of renewable biomass in RFS?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Slash and pre-commercial thinnings from non-federal forestland that is not ecologically sensitive forestland qualify as renewable biomass for purposes of RFS. Slash is defined in 40 CFR 80.1401 as the residue, including treetops, branches and bark, left on…
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Does a renewable fuel producer have to report and maintain records on the feedstocks for every batch of renewable fuel they produce?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . All renewable fuel producers must report and maintain records concerning the type and amount of feedstocks used for each batch of renewable fuel produced (see 80.1451(b)(1)(ii)(K) and 80.1454(b)(3)(vi)). With regard to the renewable biomass recordkeeping and reporting requirements…
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How does a renewable fuel producer document that the MSW feedstock that they are using to produce cellulosic ethanol meets the definition of separated MSW as defined in Section 80.1426(f)(5)(i)(C )? How does the producer quantify the portion of the final
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The renewable fuel producer using separated MSW feedstock to produce renewable fuels such as cellulosic ethanol, cellulosic diesel, cellulosic naphtha, etc. must document that their feedstock meets the definition of separated municipal solid waste (MSW), which is "material…
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Does ethanol derived from cellulosic feedstock or sugar have the same Equivalence Value as ethanol derived form corn starch, i.e. 1.0?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Equivalence Values are based on energy content in the fuel, adjusted for renewable content in comparison to denatured ethanol. See 80.1415(c). Ethanol from starch, sugar, and cellulose is all chemically identical, and is all 100% renewable (none…
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How does the "active management" requirement in the definition of renewable biomass apply to land that changes status in the future?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In RFS2, EPA has interpreted the EISA requirement that existing agricultural land be "cleared or cultivated at any time prior to [December 19, 2007] and actively managed or fallow and nonforested" to apply to land that existed as…
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Are palm oil plantations considered agricultural land or tree plantations under RFS2?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Palm oil trees are planted and managed for the purpose of harvesting palm fruit and not for harvesting the trees themselves, in the same way that a fruit orchard is planted and managed to yield fruit and not…
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