An airplane manufacturer uses JP4, a jet fuel, to move the planes around the facility. Can this fuel be considered exempt under the "maintenance of motor vehicles used at the facility" exemption?
Amounts of fuel used only at the facility to transport vehicles on the facility's property do not have to be counted towards thresholds and can be included under the motor vehicle exemption. If the jet fuel is in the planes when they leave the site to be sold or distributed in commerce, then the facility is considered to be processing the jet fuel and the listed chemicals in the fuel are subject to threshold determinations and release and other waste management calculations. Additional information on the motor vehicle exemption can be found in Directive #3 of the Revised 1998 EPCRA Section 313 Questions and Answers Document.