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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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How will the volume of corn ethanol produced above the grandfathering threshold be treated?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . For grandfathered facilities, only the baseline volumes are exempt from the 20 percent GHG reduction requirement Thus, RINs may be generated for baseline volumes of fuel regardless of lifecycle greenhouse gas emissions performance. Volumes of fuel produced above…
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Do grandfathered facilities have an additional 6 months to submit their engineering reviews to EPA?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. In the preamble to the final RFS2 regulations at 75 Fed. Regs. 14709 (March 26, 2010), EPA stated that, in an effort to reduce demand on engineering resources in the interim between promulgation of the rule and…
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What is meant by "grandfathered" fuel?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Under the RFS2 regulations, renewable fuel produced from facilities that commenced construction before December 19, 2007 and which completed construction within 36 months without an 18 month hiatus in construction and thereby exempt from the minimum 20% GHG…
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How long will the grandfathering provision be effective? Once a grandfathered producer registers and completes their engineering review, will their baseline volume ever need to meet the 20% GHG reduction requirement?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . If a facility meets the requirements for exemption from the 20% GHG reduction requirement pursuant to 40 CFR 80.1403(c ) or (d), then the baseline volume of renewable fuel produced by that facility is exempt from the 20%…
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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 does a foreign grandfathered renewable fuel production facility processing a mixture of feedstocks with different D codes or no D codes classify its production into D code categories so RINs can be generated when the product is imported into the U.S.?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . If the importer is generating the RINs, the importer must obtain all the required information for registration from the foreign producer of the renewable fuel pursuant to 80.1426(a)(2) and 80.1450. In the case of a foreign producer using…
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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 do I have to do in preparation for the cleaning?
Cleaning crews will not move any of your personal belongings, including furniture or appliances. To ensure the most thorough cleaning of your home or place of business, please clear countertops and other surfaces, and limit excess clutter. Norfolk Southern will provide a few boxes if needed to allow for easy…
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If a facility is grandfathered, is it also exempt from the requirement that feedstocks must be renewable biomass?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Even if a facility is exempt from the 20% GHG reduction requirement, in order to generate RINs, the facility is still required to use feedstocks that meet the definition of renewable biomass. The definition of renewable fuel in…
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Are Canadian facilities included in the grandfathering provision? Does the grandfathering provision extend to facilities that commenced production up to December 31, 2009?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The grandfathering provisions apply equally to facilities inside and outside the RFS program area. Facilities that commenced construction (as defined in §80.1403(a)(4)) prior to December 19, 2007, and which satisfy the timely construction requirements of §80.1403(c)(1) and (2)…
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Will someone explain the process to me so that I can decide if I want cleaning?
During your pre-cleaning interview, representatives from EPA and Norfolk Southern will explain the cleaning process, assess time and resource needs, answer questions, and if desired schedule a cleaning date.
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Table 1 in 80.1426 does not include a coal fired ethanol plant. If a coal fired plant can be demonstrated as "grandfathered-in," can we assume the ethanol produced will have a D code of 6?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Per 80.1403(c), all facilities (including coal-fired facilities) for which construction commenced prior to December 19, 2007 and which completed construction within 36 months without an 18 month hiatus in construction may qualify for grandfathered status regardless of the…
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How will a cleaning date be scheduled?
A scheduling specialist will contact you to find a date and time for a pre-cleaning interview at your home or place of business.
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