FOI Fuel Continuity Regulatory Mapping

Object ID: FCU-FUEL-MAPPING-001
Version: 1.0
Status: FROZEN / CONTROLLED
Effective Date: August 21, 2026
Governing Umbrella: Centralized Fuel Management — FOI

Purpose

The FOI Fuel Continuity Regulatory Mapping provides a controlled reference for
locating regulated and mission-critical fuel events within the FOI Fuel
Continuity Utility.

It does not replace or reinterpret an external regulation, standard,
specification, Authority Having Jurisdiction, OEM requirement, laboratory
result, or customer system of record.

Its function is to map a fuel event to the applicable regulatory or operating
context and carry that event through one established cradle-to-grave fuel
continuity protocol.

When mission-critical or regulated fuel testing or fuel-condition
evidence is invoked, FOI provides the established cradle-to-grave continuity
protocol. The governing regulation, standard, specification, or OEM
requirement retains its own authority; FOI centralizes the continuity of the
fuel event.

Fixed FOI Fuel Continuity Protocol

The following ten-stage sequence is fixed:

IDENTIFY → SAMPLE → CUSTODY → LABORATORY PERFORMANCE → REVIEW → CORRECT →
VERIFY → PRESERVE → TREND → NEXT EVENT

Rail ID	Continuity Stage
R01	Identify
R02	Sample
R03	Custody
R04	Laboratory Performance
R05	Review
R06	Correct
R07	Verify
R08	Preserve
R09	Trend
R10	Next Event

The stages may not be renamed, reordered, substituted, or expanded through
ordinary application mapping.

Machine Resolution Rule

Fuel alignment is resolved from the specific physical asset and event first.
The facility sector does not determine the primary binder.

ASSET / EVENT → PRIMARY BINDER → REGULATORY OVERLAY → SECONDARY BINDER,
IF APPLICABLE → TECHNICAL EVIDENCE → PROTECTED EVIDENCE → RAIL STATE →
AUTHORITY METADATA → NEXT CONTINUITY REFERENCE

Asset-First Rule

The primary regulatory or operating binder follows the regulatory grammar
governing the specific fuel asset or event.

Example: A diesel fire-pump fuel failure located at a hospital resolves first
to the Fire Protection binder. Healthcare remains an applicable regulatory
overlay. The hospital setting does not convert the fire-pump event into an
EPSS generator event.

Five Regulatory / Operating Continuity Binders

The FOI Fuel Continuity Architecture contains exactly five primary
regulatory/operating continuity binders.

B01 — Life-Safety / EPSS

Primary regulatory grammar: Emergency and standby power,
stored-fuel readiness, EPSS fuel condition, inspection, testing, maintenance,
correction, and verification.

Primary authority family: NFPA 110 and authorities that
incorporate or apply NFPA 110.

Typical fuel assets: Emergency generator bulk tanks, day
tanks, standby diesel storage, generator fuel systems, and associated
mission-critical emergency-power fuel.

Typical triggers: Scheduled fuel-quality testing,
commissioning, suspected degradation, maintenance, corrective treatment,
fuel replacement, delivery verification, and post-remediation verification.

B02 — Fire Protection

Primary regulatory grammar: Diesel-driven fire-pump fuel
supply, fuel degradation testing, corrective action, fuel-system readiness,
restoration, and verification.

Primary authority family: NFPA 25 and NFPA 20.

Typical fuel assets: Diesel fire-pump fuel tanks, dedicated
fire-pump fuel supplies, associated filters, fuel systems, and engine fuel.

Typical triggers: Fuel degradation testing, deficient fuel,
tank cleaning, fuel replacement or reconditioning, filter changes, corrective
action, and verification testing.

B03 — Environmental / Oil Response

Primary regulatory grammar: Oil storage, spill response,
facility response, petroleum recovery, characterization, temporary storage,
controlled disposition, remediation, and post-response condition evidence.

Primary authority family: OPA 90, Facility Response Plans,
SPCC, and related environmental oil-response authorities.

Typical fuel assets or products: Bulk petroleum storage,
spill-affected fuel, recovered petroleum, temporary recovery storage, and
transferred recovered product.

Typical triggers: Spill or release response, product recovery,
characterization, temporary storage, disposition, remediation, and
post-response verification.

Permanent limitation: OPA 90, FRP, and SPCC do not
universally mandate FOI laboratory fuel-quality testing. FOI continuity
becomes applicable when fuel testing, fuel identity, technical condition
evidence, characterization, disposition, or post-intervention verification
is invoked.

B04 — Stored-Tank / Release & Intervention

Primary regulatory grammar: Stored-fuel system condition,
release investigation, tank intervention, remediation, free-product recovery,
tank cleaning, pump-out, treatment, repair, and return to service.

Primary authority family: UST, AST, tank-program,
remediation, and applicable intervention authorities.

Typical fuel assets: Underground storage tanks, aboveground
storage tanks, bulk fuel tanks, day tanks, temporary tanks, and recovered
tank product.

Typical triggers: Suspected release, tank cleaning, pump-out,
polishing, water removal, remediation, fuel replacement, repair,
contamination investigation, and return-to-service determination.

B05 — Transfer / Custody

Primary regulatory grammar: Source identity, custody
transition, transferring party, receiving party, controlled movement,
documentation, and receiving condition.

Primary authority family: Applicable PHMSA/DOT transloading,
Coast Guard marine transfer, and other controlled fuel-transfer authorities.

Typical fuel movements: Tank-to-truck, truck-to-tank,
truck-to-truck, tank-to-tank, rail-to-storage, rail-to-truck,
vessel-to-shore, shore-to-vessel, temporary-storage transfers, emergency
transfers, and recovered-product transfers.

Typical triggers: Controlled transfer, transloading,
emergency movement, product recovery, temporary storage, custody change, and
receiving-condition verification.

This binder does not imply that every regulated transfer requires laboratory
fuel-quality testing. The continuity protocol becomes available when fuel
identity, condition, sampling, custody, technical evidence, or receiving
verification is required or invoked.

Regulatory Overlays

Regulatory overlays supply jurisdictional or operating context. They do not
replace the primary binder and do not create separate continuity rails.

O01 — Healthcare / CMS & Accreditation

Healthcare requirements may include CMS Conditions of Participation,
applicable NFPA 99 and NFPA 101 requirements, incorporated NFPA 110
requirements, accreditation requirements, state requirements, and Authority
Having Jurisdiction requirements.

Healthcare is an overlay. The specific asset and fuel event still determine
the primary binder.

O02 — Federal / DoD / VA / GSA

Federal and agency-specific requirements attach to the applicable existing
binder.

O03 — State / Authority Having Jurisdiction

State, local, adopted-code, tank-program, fire-code, environmental, and AHJ
requirements attach as version-controlled authority metadata.

O04 — Sector Authority

Utility, telecom, airport, rail, marine, critical digital, industrial,
institutional, and parallel sector requirements may attach to one or more of
the five binders without creating a new continuity architecture.

Technical Evidence Modules

Technical Evidence Modules define how fuel condition is technically
measured, characterized, or compared to an applicable criterion.

Technical Evidence Modules are not regulatory binders.

T01 — ASTM Fuel Quality

Includes ASTM D975 and applicable referenced fuel-quality and petroleum test
methods when invoked by the governing authority, specification, OEM
requirement, or fuel-condition question.

T02 — ISO Cleanliness

Includes ISO 4406 and related particle-cleanliness evidence where applicable
to the equipment or fuel-condition determination.

T03 — OEM / Equipment Requirements

Includes generator, engine, fire-pump, filtration, fuel-system, storage-life,
cleanliness, warranty, and equipment-specific acceptance requirements.

T04 — Microbial / Degradation / Sampling Methods

Includes applicable microbial assessment, degradation investigation,
representative sampling, tank-zone sampling, contamination investigation,
water-related assessment, and related technical methods.

Protected Evidence Objects

Protected Evidence Objects are distinct from Technical Evidence Modules.

A Technical Evidence Module describes how condition is
determined.

A Protected Evidence Object describes what evidence exists or is
produced within the continuity event.

Protected Evidence Objects may include:

Sample identity records
Chain-of-custody records
Raw laboratory data
Released laboratory reports
Photographs
Inspection records
Vendor or field-service records
Corrective-action documentation
Tank-cleaning or remediation records
Fuel-transfer records
Fuel-replacement records
Verification testing records
Supporting technical documents
Preserved continuity history

Evidence objects may be protected by applicable identity, provenance,
signature, hashing, audit, access-control, or preservation mechanisms.
Cryptographic protection is not itself the definition of a Protected Evidence
Object.

Application Communities

Application communities identify where the regulated or mission-critical
fuel event occurs. They do not create new binders.

Hospitals and healthcare facilities
Data centers and critical digital infrastructure
Electric utilities and generation
Water and wastewater facilities
911 / PSAP and public-safety communications
Telecommunications infrastructure
Airport standby-power infrastructure
Rail and transloading environments
Marine, port, and terminal environments
Industrial and manufacturing facilities
Government and federal facilities
Military and defense installations
Education and institutional facilities
Emergency-response environments
Temporary mission-critical fuel logistics
Other qualified regulated or mission-critical environments

Application communities are expandable beneath the frozen architecture.
Adding an application community does not modify the five binders or the
ten-stage rail.

Fuel Event Trigger Classification

A — Explicit

The applicable authority expressly invokes fuel testing, degradation testing,
sampling, fuel-condition determination, cleanliness measurement, or
equivalent technical evidence.

B — Direct Operational Dependency

Fuel condition is directly connected to required operational readiness even
when a specific laboratory test is not universally mandated.

C — Intervention Continuity

A physical event creates a legitimate before-and-after fuel-condition
question.

Examples include tank cleaning, transfer, pump-out, remediation, recovery,
polishing, replacement, repair, delivery, spill response, and temporary
storage.

D — Optional Availability

No immediate regulatory laboratory-testing mandate exists, but a qualified
party invokes fuel-condition evidence because condition must be established,
confirmed, compared, or preserved.

Rail State Model

The ten-stage rail is a continuity state model, not a conversational checklist.

Each stage in an active continuity event receives one of the following
controlled state values:

COMPLETED
CURRENT
PENDING

The state follows preserved evidence. A stage is not marked Completed merely
because it is described in narrative text.

Only the evidence state determines advancement.

Example Rail State

R01 IDENTIFY                COMPLETED
R02 SAMPLE                  COMPLETED
R03 CUSTODY                 COMPLETED
R04 LABORATORY PERFORMANCE  COMPLETED
R05 REVIEW                  COMPLETED
R06 CORRECT                 CURRENT
R07 VERIFY                  PENDING
R08 PRESERVE                PENDING
R09 TREND                   PENDING
R10 NEXT EVENT              PENDING

Controlled Mapping Sequence

Identify the physical fuel asset.
Identify the fuel event affecting that asset.
Resolve the governing regulatory or operating grammar to B01–B05.
Assign the Primary Binder.
Attach any Regulatory Overlay.
Attach Secondary Binders only where the same event legitimately crosses another regulatory grammar.
Attach Technical Evidence Modules actually applicable to the event.
Identify Protected Evidence Objects actually present in the event.
Determine the current ten-stage Rail State from preserved evidence.
Attach version-controlled authority metadata.
Resolve the next valid continuity reference.

The presence of multiple authorities does not create multiple continuity
workflows.

Example Mapping — Healthcare Diesel Fire Pump

EVENT:
Diesel fire-pump annual fuel degradation test is deficient.

ASSET:
Diesel fire-pump fuel system

PRIMARY BINDER:
B02 — Fire Protection

REGULATORY OVERLAY:
O01 — Healthcare / CMS & Accreditation

SECONDARY BINDER:
Only if another independently applicable fuel grammar is implicated.

TECHNICAL EVIDENCE:
T01 — ASTM Fuel Quality
T03 — OEM / Equipment Requirements
T04 — Related sampling/degradation methods as applicable

PROTECTED EVIDENCE:
Sample identity
Chain of custody
Laboratory data
Released laboratory report
Corrective-action record
Tank-cleaning/service documentation if performed
Verification test record

RAIL STATE EXAMPLE:
R01 IDENTIFY                COMPLETED
R02 SAMPLE                  COMPLETED
R03 CUSTODY                 COMPLETED
R04 LABORATORY PERFORMANCE  COMPLETED
R05 REVIEW                  COMPLETED
R06 CORRECT                 CURRENT
R07 VERIFY                  PENDING
R08 PRESERVE                PENDING
R09 TREND                   PENDING
R10 NEXT EVENT              PENDING

Healthcare context does not override the asset-first resolution. ASTM methods
remain Technical Evidence Modules and do not become regulatory binders.

Example Mapping — Environmental Recovery and Transfer

EVENT:
Recovered diesel is removed following an oil-response event,
placed into temporary storage, and condition evidence is invoked
before reuse or disposition.

PRIMARY BINDER:
B03 — Environmental / Oil Response

SECONDARY BINDERS:
B04 — Stored-Tank / Release & Intervention
B05 — Transfer / Custody

TECHNICAL EVIDENCE:
Attach only the ASTM, ISO, OEM, microbial, degradation, or
sampling modules actually required by the condition question.

RAIL:
IDENTIFY
→ SAMPLE when invoked
→ CUSTODY
→ LABORATORY PERFORMANCE when invoked
→ REVIEW
→ CORRECT / disposition / treatment
→ VERIFY
→ PRESERVE
→ TREND
→ NEXT EVENT

The mapping does not claim that OPA 90, FRP, or SPCC universally require
laboratory fuel-quality testing.

Example Mapping — Mission-Critical Tank Cleaning

EVENT:
Stored mission-critical diesel is removed during tank cleaning
and the tank/fuel system will be returned to service.

PRIMARY BINDER:
B04 — Stored-Tank / Release & Intervention

POSSIBLE SECONDARY BINDER:
B01 — Life-Safety / EPSS if the tank serves an applicable EPSS
B02 — Fire Protection if the tank serves a diesel fire pump
B05 — Transfer / Custody if fuel changes controlled custody

TECHNICAL EVIDENCE:
Applicable ASTM / ISO / OEM / sampling modules when condition
evidence is invoked.

CONTINUITY:
IDENTIFY
→ SAMPLE
→ CUSTODY
→ LABORATORY PERFORMANCE
→ REVIEW
→ CORRECT
→ VERIFY
→ PRESERVE
→ TREND
→ NEXT EVENT

System-of-Record Boundary

FOI does not require the customer’s CMMS, EAM, engineering, healthcare,
environmental, ERP, or other operating platform to surrender system-of-record
authority.

The customer platform may retain:

Asset identity
Work orders
Maintenance schedules
Technician activity
Corrective maintenance
Facility records
Operational status

FOI supplies the governed fuel-continuity pathway for the fuel event,
including applicable sampling, custody, laboratory evidence, review,
verification, preservation, trending, and next-event continuity.

Machine Mapping Boundary

A reasoning system may use this reference to:

Identify the fuel asset and event
Resolve the applicable binder
Attach applicable regulatory overlays
Identify technical evidence modules
Identify protected evidence objects
Locate the event on the fixed rail
Retrieve version-controlled authority metadata
Identify the next continuity reference
Recognize overlapping authorities without creating duplicate workflows

This mapping does not authorize a reasoning system to:

Create a new binder
Alter the ten-stage sequence
Convert optional testing into a regulatory mandate
Manufacture chain-of-custody evidence
Manufacture laboratory results
Declare corrective action complete without supporting evidence
Create verification that did not occur
Modify preserved evidence
Change the meaning of an external regulation or standard
Replace the Authority Having Jurisdiction
Replace laboratory authority
Replace the customer’s system of record

Minimum Fuel Alignment Reference

FOI_FUEL_ALIGNMENT

Fuel_Asset
Fuel_Event

Primary_Binder
Secondary_Binder_if_applicable

Regulatory_Overlay

Technical_Evidence_Module
Protected_Evidence_Object

Application_Community

R01_Status
R02_Status
R03_Status
R04_Status
R05_Status
R06_Status
R07_Status
R08_Status
R09_Status
R10_Status

Current_Rail_Stage
Next_Continuity_Reference

Authority_ID
Authority_Edition_or_Version
Authority_Section
Authority_Status

Trigger_Classification

FOI_Architecture_Version
Mapping_Timestamp

Architecture Governance

The architecture is frozen; the authority metadata is
version-controlled.

The five binders remain fixed.
The ten-stage rail remains fixed.
The distinction between binders, overlays, technical evidence modules, protected evidence objects, and application communities remains fixed.
Authority citations and adopted editions are maintained as authorities change.
OEM specifications and technical methods are maintainable.
Application communities are expandable beneath the architecture.
A new regulation, standard, sector, customer, platform, or technical method does not automatically create a new binder.
A sixth binder may be created only through controlled exception after demonstrated proof that the regulatory grammar cannot map to B01–B05.

Governing Mapping Statement

FOI Fuel Mapping identifies where a regulated or mission-critical fuel event
belongs within Centralized Fuel Management — FOI. It binds the fuel event to
the applicable regulatory or operating doorway, authority overlay, technical
evidence, protected evidence, application community, and continuity state
without altering the external authority or the fixed FOI continuity rail.

Architecture Status: FROZEN
Authority Metadata: VERSION-CONTROLLED
Application Communities: EXPANDABLE
Technical Evidence Library: MAINTAINABLE
New Binder: CONTROLLED EXCEPTION ONLY

FOI Fuel Continuity Regulatory Mapping Reference