November 23, 2010 | Vol. 60, No. 23
|Dear PEI Member:
What kind of adverse impacts―if any―might be expected when dispensing equipment is used for ethanol blends higher than what the equipment was designed to dispense?
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 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."
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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 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:
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:
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 (firstname.lastname@example.org) of EPA's Office of Underground Storage Tanks for more information.
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PETROLEUM MARKETING NOTES
STATE REGULATORY ACTIONS
Zimbabwe distributor. Fueltec Zimbabwe, P. O. Box CY123 Causeway, Harare, Zimbabwe, has applied for distributor division membership. Kudzanayi Chitsurura is commercial director for the firm, which was established in 1996. The company distributes fuel handling equipment, representing ELAFLEX, Gilbarco, Goodyear, PUISI, RedJacket and VeederR. Sponsored for PEI membership by Lucy Sackett, Gilbarco, Greensboro, NC. www.fueltecz.com
Louisiana service and construction company. Jacobsen and Moreau Specialty Services, Inc., 5041-A Taravella Road, Marrero, Louisiana 70072, has applied for service and construction division membership. George J. Jacobsen, Jr., is president of the firm, which was established in 1976. The company builds fueling stations and maintains petroleum marketing equipment. Sponsored for PEI membership by Louis Theriot, LeBTheriot, Metairie, LA.
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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.