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Hot Work Definition and Requirements
Facilities subject to the Program 3 Prevention Program requirements in 40 CFR Part 68 must include in their Risk Management Plan the date of the most recent review or revision of hot work permit procedures in Section 7.13. What is considered hot work and what are the requirements related to…
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Do I have to conduct incident investigations of releases resulting from theft?
The incident investigation provisions of 40 CFR Part 68 (§§68.60 and 68.81) require facilities to investigate incidents that resulted in or could reasonably have resulted in a catastrophic release. Are covered facilities required to perform incident investigations of releases resulting from theft of covered substances, such as anhydrous ammonia? If…
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Do Program 1 processes have to complete a process hazard analysis?
Do owners or operators of Program 1 processes have to complete a process hazard analysis? No. The Program 1 requirements do not include a process hazard analysis (40 CFR §68.12(b)). Program 3 processes require completion of a process hazard analysis (40 CFR §68.12(d)(3)) while Program 2 processes must complete a…
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Is a hazard review synonymous with a process hazard analysis (PHA)?
The prevention program requirements under 40 CFR Part 68, Subparts C and D, include hazard reviews and process hazard analyses. Is a hazard review synonymous with a process hazard analysis (PHA)? No. A hazard review is different from a PHA. A hazard review is part of the Program 2 prevention…
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How often must compliance audits be performed?
How often must owners or operators of stationary sources subject to the risk management program regulations perform compliance audits? The regulations at 40 CFR §§68.58(a) and 68.79(a) state that owners or operators must certify that they have evaluated compliance with the applicable prevention program provisions at least once every three…
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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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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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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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Who reports expired RINs?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Every party must report RINs owned that have expired as of the end of the fourth quarter of each year. This report is due on February 28 of the following year and will identify RINs that expired in…
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If I am registered for the RFS program, do I have to receive RINs with the renewable fuel I purchase?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Being registered for the RFS program does not mean that a party must receive RINs with the renewable fuel they purchase. Being registered for the RFS program means that a party is eligible under the regulations to receive…
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