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The National Renewable Energy Laboratory's (NREL) Office of Deployment and Industry Partnerships and the Center for Transportation Technologies and Systems' Fuels Performance Group are responsible for addressing the hurdles to commercialization of fuels and fuel blends, such as ethanol, that are derived from biomass. One such hurdle is the unknown compatibility of new fuels with current infrastructure, such as the equipment used at service stations to dispense fuel into automobiles. We know that the infrastructure now in use consists of equipment from various manufacturers (some of which are no longer in business), of varying ages, and maintained to varying degrees using different processes. What nobody fully understands are the effects on the legacy base of installed fuel dispensing equipment to different fuel compositions, such as E15.    

A project was established to help the Department of Energy (DOE) and NREL better understand what might happen to the legacy equipment if E15 is introduced into commerce. Underwriters Laboratories (UL) was selected to test used equipment harvested from the field, as well as new equipment. The new and harvested equipment was UL-listed for up to E10. Testing was performed according to the requirements of UL Subject 87A (Outline of Investigation for Power-Operated Dispensing Devices for Gasoline and Gasoline/Ethanol Blends With Nominal Ethanol Concentrations up to 85 Percent [E0-E85]), but using a CE17a test fluid.

The primary focus of the tests was to identify leakage and assess other safety-related equipment performance issues as addressed by applicable UL requirements. Equipment tested included dispensers, meter/manifold/electric valve assemblies, breakaways, a flow limiter, hose/hose assemblies, nozzles, shear valves, a submersible turbine pump, and swivels. Manufacturers of the tested equipment were not identified.

The 29-page report prepared by UL states that "the overall results of the program were not conclusive insofar as no clear trends in the overall performance of all equipment could be established." Some new and used equipment performed well. According to UL, "shear valve and flow limiter test items produced compliant results, the submersible turbine pump performed well, and hoses generally yielded compliant results."

Unfortunately, some new and used equipment demonstrated "a reduced level of safety or performance, or both, during either long-term exposure or performance tests." When the report refers to "safety" of the equipment, it focuses on the "loss of fuel containment and other safety-critical performance such as loss of ability to stop fuel flow or failure of breakaway couplings to separate at appropriate forces."
 

Study: Effect of E15 on Dispensing Equipment

EPA Proposes Guidance for UST Fuel Compatibility

EPA To Delay E15 Decision for 2001-06 MY Autos

PEI Young Executives Move Conference to San Antonio

2011 Young Executives Winter Conference
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February 3-5, 2011
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UL specifically identified some E10-listed dispensing equipment that did not fare well in its tests: "Dispenser meter/manifold/valve assemblies in particular demonstrated largely noncompliant results. Nozzles, breakaways, and swivels, both new and used, experienced noncompliant results during performance testing. Leakages are largely attributed to effects of exposure on the gasket and seal materials. The only exceptions were cases in which a polymeric component of a breakaway coupling was degraded and the damage resulted in a consequential leakage." In the UL study, there were "no noted effects on metallic parts of equipment."

UL concluded its report by suggesting that "testing of other items to establish a larger sample size may provide additional insights. Further detailed analysis of the equipment that produced compliant results may establish best practices; conversely, further detailed analysis of the equipment that produced noncompliant results may further identification of root causes of equipment design that may lead to leakages or other potential risks. This work is ongoing and will be reported separately."

After reading the report, we wonder why petroleum marketers would use equipment listed only for up to E10 and run E15 through it. Why take a chance that a dispenser will leak and/or not give a fair measure, that a nozzle will leak and/or not shut off when it should, or that a breakaway coupling will not separate under the right circumstances? The liabilities are simply too great. With dispensing equipment listed for E15 currently available, the decision to use E15-listed equipment appears to be a no-brainer.

EPA PROPOSES GUIDANCE FOR UST FUEL COMPATIBILITY
The Environmental Protection Agency's (EPA) Office of Underground Storage Tanks (OUST) has proposed new procedures for tank owners to use in demonstrating compatibility of their underground storage tank (UST) systems with gasoline containing biofuels.

The proposal, which appeared in the November 17 Federal Register, notes that federal UST law (40 CFR 280.32) specifically requires compatibility of stored substances with UST system components. As the country moves toward an increased use of biofuels, such as ethanol and biodiesel, compliance with the UST compatibility requirement becomes even more important, because ethanol and biodiesel can compromise the integrity of some UST system materials. This proposal solicits comments on the proposed guidance and associated issues that EPA hopes will clarify how owners/operators of UST systems storing fuels containing greater than 10 percent ethanol and certain volumes of biodiesel can demonstrate compliance with the UST compatibility requirement.

EPA's proposed guidance is meant to provide greater flexibility for owners and operators of UST systems who intend to store E15, including those whose equipment may not be certified (listed) by an independent testing laboratory (i.e., Underwriters Laboratories). EPA proposes three methods as effective options for the tank owner/operator to determine compatibility:

• Certification or listing by a nationally recognized independent laboratory;
• Equipment manufacturer approval; or
• Another method determined by the implementing agency (the states) to sufficiently protect human health and the environment.

It will be interesting to see if EPA's proposed "effective" options are also practical. UL has already gone on record stating that it will not list legacy equipment for compatibility, so that leaves owners and operators of UST system components that have not been tested by UL for compatibility with E15 out in the cold.

Equipment manufacturer approval―as proposed by EPA―should be in writing, indicate affirmative statements of compatibility, and be from the manufacturer itself and not another entity―such as an installer or equipment distributor. EPA is considering numerous forms for manufacturer approvals. For example, EPA is evaluating items such as product warranties, brochures, or letters from manufacturers as acceptable equipment manufacturer approvals. It seems to us that the trouble with this option will be to find manufacturers willing and able to stick their necks out and produce this approval. EPA, in its proposal, asks for comments on that issue.

It is important that PEI manufacturers understand what UST equipment EPA is planning to include in its list of components that must be compatible with E15, and respond to EPA with their comments. Some of these components may or may not come into contact with fuel or lead directly to a release. EPA proposes to list the following equipment, at a minimum, and asks if other components should be added or removed from the list:

• Tank or internal tank lining
• Piping
• Pipe adhesives and glues
• Line leak detectors
• Flexible connectors
• Fill pipe
• Spill and overfill prevention equipment
• Submersible turbine pump and components
• Fittings, gaskets, bushings, couplings, and boots
• Containment sumps (including submersible turbine sumps and under-dispenser containment)
• Release detection floats, sensors, and probes

If UL and the equipment manufacturers will not certify or approve legacy UST system components, the proposal permits implementing agencies to determine other acceptable methods for demonstrating compliance with the compatibility requirement, as long as they sufficiently protect human health and the environment. EPA indicates it will work with state offices to develop other acceptable standards.     

Comments to the proposed guidance will be accepted through December 17, 2010. After reviewing comments, EPA intends to issue the final guidance in early 2011. Contact Andrea Barbery (barbery.andrea@epa.gov) of EPA's Office of Underground Storage Tanks for more information.

EPA TO DELAY DECISION ON E15 IN 2001-2006 CARS
The Environmental Protection Agency (EPA) will delay its decision on whether gasoline blended with up to 15 percent ethanol is safe for vehicles built during the 2001 to 2006 model years. That decision was expected in December but will now be delayed until January, 2011. EPA wants up to one more month of testing on the effects of E15 gasoline on engines.

PEI YOUNG EXECUTIVES 2011 WINTER CONFERENCE MOVED TO SAN ANTONIO
Due to concerns about safety in Mexico, PEI's Young Executives Committee has moved the Young Executives Winter Conference, scheduled for February 3-5, 2011, from Cancun to San Antonio, Texas. The 2011 conference will be held in the Omni La Mansión del Rio Hotel in San Antonio. It will feature Dr. Julie Bell, founder and president of The Mind of a Champion, an executive coaching and training firm based in Dallas. For more information and to register for the conference, go here.   

WOMAN KILLED DRIVING OVER TANKER TRUCK DELIVERY HOSE
A woman was killed November 16 in Jackson, Tennessee, when she drove her car over a gasoline tanker truck's delivery hose that was transferring fuel at a convenience store.  An eyewitness said the tanker's driver ran out of the store trying to warn the woman to stop as the car headed towards the hose, but got her attention too late to stop her. The flames engulfed the car and burned the wheels of the tanker truck. The fire marshal could not comment on the exact cause of the fire because the Jackson police were handling the investigation.

PETROLEUM MARKETING NOTES
Cooperative Elevator Company opened its newest fueling facility north of Sebewaing, Michigan, on November 10. The facility features a blender pump, one of three in use throughout the State of Michigan, that offers E10, E30, E40, E50 and E85.
BP plans to sell its interests in five southern-African fuel marketing businesses to Puma Energy, Geneva, Switzerland. BP will sell its 100 percent ownership interest in Namibia and Botswana, its 75 percent interest in Zambia, and its 50 percent interest in fuel marketing in Malawi and Tanzania.
ExxonMobil Corporation reached an agreement with Alliance Energy in October to sell its real estate interests for 89 Mobil-branded retail stations located in Connecticut.

STATE REGULATORY ACTIONS
The South Carolina Department of Health and Environmental Control (DHEC) has banned Duncan Environmental Associates from doing more work at sites polluted by leaking underground storage tanks. DHEC has cited Duncan 55 times since 2008 for questionable work, officials said, prompting the one-year ban.―The State, Columbia, South Carolina.  
The New York State Department of Environmental Conservation (DEC) has proposed language to amend 6 NYCRR Part 230 "Gasoline Dispensing Site and Transport Vehicles." The changes are proposed to update and clarify testing requirements for gasoline dispensing sites and to conform more closely with new federal requirements and guidance. A summary of the proposed rulemaking changes is available here. A stakeholder meeting on the proposed changes is scheduled for December 7, 2010, in Albany. Contact Debie Donohue at (518) 402-8403 or dxdonohu@gw.dec.state.ny.us by December 3 to register for this meeting.

ADMITTED TO PEI

• Northwest RCI, Inc., Mountain Home, ID (S&C)
• All-American Pride, LLC, Oak Grove, MO (S&C)
• HMI USA, Inc., Mequon, WI (aff)
   

 

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Petroleum Equipment Institute
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The TulsaLetter (ISSN 0193-9467) is published two or three times each month by the Petroleum Equipment Institute. Robert N. Renkes, Executive Vice President, Editor. Opinions expressed are the opinions of the Editor. Basic circulation confined to PEI members.