August 15, 2013 | Vol. 63, No. 16
Dear PEI Member:
The final fuel standard for 2013 surprised nobody by requiring 16.55 billion gallons of renewable fuels to be blended in the U.S. fuel supply. Specifically, the requirements are:
The big news was what EPA said about 2014 (emphasis is ours):
"A number of obligated parties and other stakeholders have communicated to EPA that while the E10 blendwall may be manageable in 2013, in 2014 compliance is expected to become significantly more difficult. We agree with that assessment. In 2014 the applicable volume of total renewable fuel set forth in the statute rises to 18.15 billion ethanol-equivalent gallons, of which 14.4 bill gal would be non-advanced biofuel comprised primarily of corn-ethanol, and 3.75 bill gal would be advanced biofuel. A significant portion of the fuel available to meet the advanced biofuel requirement would also likely be ethanol, including domestically produced cellulosic and advanced ethanol, along with advanced ethanol imported from Brazil. However, the maximum volume of ethanol that could be consumed as E10 in 2014 is projected to be just 13.2 bill gal. Given the history of the market and relevant constraints, EPA does not currently foresee a scenario in which the market could consume enough ethanol sold in blends greater than E10, and/or produce sufficient volumes of non-ethanol biofuels (biodiesel, renewable diesel, biogas, etc.), to meet the volumes of total renewable fuel and advanced biofuel stated in the statute.
"Given these challenges, EPA anticipates that in the 2014 proposed rule, we will propose adjustments to the 2014 volume requirements, including to both the advanced biofuel and total renewable fuel categories. We expect that in preparing the 2014 proposed rule, we will estimate the available supply of cellulosic and advanced biofuel, assess the E10 blendwall and current infrastructure and market-based limitations to the consumption of ethanol in gasoline-ethanol blends above E10, and then propose to establish volume requirements that are reasonably attainable in light of these considerations and others as appropriate."
For our money, it appears that EPA is signaling that the amount of conventional biofuels required for 2014 will come in under the 14.4 billion gallons mandated by the statute because it recognizes that figure simply can't be reached. But we also think that the historically ethanol-friendly EPA will want to exceed the 13.2 billion gallons expected to be reached in 2014. By acknowledging the reality of the situation but continuing to push the market toward alternative fuels, EPA could split the difference and make nobody happy―which may end up being the most palatable solution.
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PEI REVISES BULK PLANT INSTALLATION GUIDE
PEI has revised its Recommended Practices for Installation of Bulk Storage Plants (PEI/RP800-13). The comprehensive reference guide is used by the industry and regulators to maximize system efficiency, prevent surface and groundwater contamination, and minimize environment and safety hazards. To our knowledge, RP800 is still the only document in the world that addresses the installation of bulk plants.
The recommended practices apply to underground, aboveground, atmospheric, and shop-fabricated tanks; associated piping, diking and spill containment; and equipment intended for the bulk storage and transfer of petroleum, biofuels and related products to and from wheeled delivery-vehicle tanks. They apply to single- and double-walled horizontal and vertical tanks, as well as insulated and fire-protected tanks. Piping associated with the tanks covered in the recommended practices may be underground, aboveground or a combination of the two.
The document was revised by the PEI Bulk Plant Installation Committee: Terry D. Cooper (chairman), Acterra Group, Inc.; Georges Boyazis, Advantage Earth Products; Roy Creley, Lakes Region Environmental Contractors; Wayne Geyer, Steel Tank Institute; Mark L. Lipa, Neumayer Equipment Company; Dave McDonald, Prevent-A-Spill Inc.; Bill Morgan, Collins Equipment Corporation; Scott Richert, C. L. McBride Company, Inc.; Brian Savage, Savage Associates Inc.; David Vaughn, Liquid Controls LLC; Hansen Webel, Gorman-Rupp Company; and Rick Zillig, Morrison Bros. Co.
Copies of all recommended practices―paper or electronic―can be ordered online at www.pei.org/shopping. Price for members is $40; nonmembers, $95.
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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.