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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 a certified renovator is an employee of the certified firm, can the firm maintain all required records (those required of the firm and of the certified renovator); understanding that the certified renovator must also keep a copy of his certification as well as employee training records/documentation on the jobsite?
Answer: The renovation firm is the entity responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the RRP Rule for a period of three years following completion of the renovation. The certified renovator is responsible for preparing the records demonstrating that the renovation was…
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Under the RRP Rule, can the required records and documentation be stored electronically rather than as paper copies?
Answer: Yes. The renovation firm is responsible for retaining and making available to EPA all records necessary to demonstrate compliance with the Lead Renovation, Repair, and Painting (RRP) Rule for a period of three years following completion of the renovation. The RRP Rule does not specify the format in which…
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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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Under the RRP Rule, can the certified renovator comply with the rules by keeping records regarding his certification and employee training electronically, provided he can display them on a hand held device or laptop on the job site?
Yes. The Lead Renovation, Repair, and Painting (RRP) Rule does not specify the format in which these documents must be kept, but they must be available at the work site. Documents are not available if they cannot be viewed. Certified renovators must have with them at the work site copies…
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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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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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If a general contractor and one or more subcontractors are involved in a single renovation project, which persons or entities are responsible for preparing, retaining and making available the necessary records?
Answer: The certified renovator, whether assigned by a general contractor or subcontractor, is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including training provided to non-certified workers. All renovation firms involved in a project share the responsibility for retaining and…
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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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How can homeowners protect themselves and their families from exposure to lead dust if they plan on doing their own renovations?
The Lead Renovation, Repair and Painting Rule does not impose requirements on homeowners performing renovations in their own homes. If you do decide to do a renovation yourself, it's very important to take precautions to protect you and your family from exposure to lead dust. EPA recommends that you follow…
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What records must a subcontractor keep?
Answer: If the certified renovator assigned to the project is assigned by the subcontractor, the certified renovator is responsible for preparing the records demonstrating that the renovation was conducted in compliance with the work practice standards, including training provided to non-certified workers. All renovation firms involved in a project share…
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I hear new record keeping requirements will take effect soon. What are they and when must my firm begin to comply with them?
Answer: Beginning July 6, 2010, when the final invoice for the renovation is delivered, or within 30 days of the completion of the renovation, whichever is earlier, the renovation firm must provide information demonstrating compliance with the training and work practice requirements of the RRP Rule to the owner of…
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