Yes. However, it is the total number of gallon-RINs, not the total volume, that must be less than 100 million. See regulation Section 80.1126(c).
Question and Answer was originally posted at http://www.epa.gov/otaq/renewablefuels/420f07041a.pdf
A refinery can produce non-ester renewable diesel by processing renewable feedstock through a distillate hydrotreater. In this situation, the refinery must assign RINs based on the feed volume. I assume the refinery can follow the rules for defining a bat
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