SETTING NATIONAL FUEL QUALITY STANDARDS Proposed Fuel Quality Standard Ethanol (E85) Automotive Fuel POSITION PAPER June 2011 Executive Summary The Australian Government is proposing to set a fuel quality standard for Ethanol (E85) automotive fuel, a blend of petrol and between 70 and 85 per cent ethanol by volume. In preparing the proposed E85 automotive fuel quality standard the Department of Sustainability, Environment, Water, Population and Communities (the department) has consulted directly with fuel grade ethanol producers, ‘flexible fuel’ vehicle manufacturers and the Fuel Standards Consultative Committee (FSCC). The proposed standard also takes into account the overarching objectives of the Fuel Quality Standards Act 2000, as well as already established international standards for this type of fuel blend. Call for submissions Comments are requested on the position paper by no later than Friday, 29 July 2011 and should be submitted electronically to: fuel.quality@environment.gov.au or sent to: Fuel and Used Oil Policy Section Department of Sustainability, Environment, Water, Population and Communities GPO Box 787 CANBERRA ACT 2601 Street address: John Gorton Building, PARKES ACT 2600 Unless marked as confidential, all submissions will be treated as public documents and posted on the department’s website. The department will not post any personal details (such as email addresses) on the website. Please ensure that your submission is attached as a separate document when replying by email. 2 Purpose The objective of this position paper is to seek formal comment from stakeholders on a proposed Ethanol (E85) automotive fuel quality standard under the Fuel Quality Standards Act 2000. Stakeholders are invited to review the proposed fuel quality parameters and provide comments. Any additional information to support your position is welcome. This position paper also details the proposed test methods that will be used by the department to determine compliance. A detailed technical background to parameters and test methods is provided at Appendix A. Background Ethanol (E85) automotive fuel Internationally, ethanol has a long history of use as a petrol extender, octane improver and alternative fuel. Ethanol can be made from both renewable (biomass) and nonrenewable (petrochemical) sources. In Australia, renewable fuel grade ethanol is predominantly made from wheat starch and wheat grain. Other feedstocks include the by-products of sugarcane (molasses) and sorghum processing. Ethanol can be produced in two forms: hydrous and anhydrous. Hydrous ethanol is usually produced by distillation from biomass fermentation, and it contains some water residue. It is suitable for use as neat spark ignition fuel in warm climates such as that in Brazil. A further process of dehydration is required to produce anhydrous ethanol (100 per cent ethanol) for blending with petrol. Anhydrous ethanol can be used as an automotive fuel by itself or can be mixed with petrol in various proportions to form a petrol/ethanol blend. Anhydrous ethanol is typically blended up to 10 per cent by volume in petrol, known as E10, for use in unmodified engines. Historically, the US has supported the use of E10 blends and more recently Europe has adopted E10 blends. Certain materials in vehicles commonly used with petrol fuel are incompatible with alcohols and varying degrees of modification are required depending on the percentage blend of ethanol with petrol. For this reason in the European Union (EU) all member states are required to ensure that fuel grade E5 is available in the market as a protection grade for older vehicles that are not compatible to run on E10. Several automobile manufacturers have developed flexible fuel vehicles that can run on neat petrol or fuel that contains 85 per cent ethanol by volume, or any blend of ethanol and petrol from 0 per cent to 85 per cent ethanol. The main differences between ethanol flexible fuel vehicles and petrol vehicles are the materials used in the fuel management system and modifications to the engine calibration system.9 The corrosive effect of a fuel rises with increasing ethanol content. Materials that normally would not be affected by low percentage ethanol blends have been found to dissolve in the presence of higher ethanol concentrations, including aluminium, brass, zinc and lead. The interaction of the fuel with fuel system materials could also result in the formation of insoluble compounds, causing plugged vehicle fuel filters. Terne (lead-tin-alloy) plated steel, commonly used for petrol fuel tanks, and lead-based solder are also incompatible with high concentrations of fuel ethanol. Non-metallic materials that degrade when in contact with high concentrations of fuel ethanol 3 include natural rubber, polyurethane, cork gasket material, leather, polyvinyl chloride (PVC), polyamides, methyl-methacrylate plastics, and certain thermo and thermoset plastics. The swelling and embrittlement of rubber fuel lines and o-rings can, in time, lead to component failure.9 These problems are eliminated in dedicated ethanol vehicles and flexible fuel vehicles by using unplated steel, stainless steel, black iron and bronze, which have all shown acceptable resistance to ethanol corrosion. Non-metallic materials successfully used with E75 and E85 include thermoset reinforced fiberglass, thermo plastic piping, neoprene rubber, polypropylene, nitrile, Viton and Teflon materials.9 Petrol ethanol blends in Australia In Australia, fuel grade ethanol is currently allowed to be blended with petrol up to 10 per cent by volume under the Fuel Standard (Petrol) Determination 2001 – the petrol standard. This fuel is commonly referred to as E10. The petrol standard covers quality requirements for unleaded petrol and premium unleaded petrol, and can be found at: http://www.environment.gov.au/atmosphere/fuelquality/standards/petrol/index.html The petrol standard sets out the quality requirements for fuel grade ethanol used as a blendstock with petrol. These quality requirements for blending for E10 do not constitute an ethanol standard i.e. there is no standard for E100 under the Fuel Quality Standards Act 2000. Not all petrol vehicles in the Australian fleet are compatible with ethanol blended petrol. The Federal Chamber of Automotive Industries provides information on which vehicles can operate on ethanol blended petrol: http://www.fcai.com.au/publications/all/all/all/3/can-my-vehicle-operate-on-ethanolblend-petrol. Until recently, E85 has been supplied by independent fuel suppliers in a small number of locations, and only a small number of flex-fuel vehicles have been marketed in Australia. On 2 August 2010 Caltex Australia launched Bio E-Flex, an E85 fuel – a blend of between 70 - 85 per cent ethanol and 15 - 30 per cent petrol. This fuel is designed for use specifically in flex-fuel vehicles. It is not suitable for any other vehicle. Caltex state they will have Bio E-Flex available in 100 metropolitan and regional locations in 2011. On 3 August 2010 GM Holden Ltd announced that Bio-E Flex fuel would be suitable for vehicles within the new Holden Commodore VE Series II range, launched in September 2010. To ensure consumer confidence in biofuels, it is important to ensure only ethanol/petrol blends, including E85 automotive fuel, of the highest quality are available and that blends are fit-for-purpose. Stakeholder feedback The department has consulted relevant stakeholders on the proposal to set an Australian fuel quality standard for E85 automotive fuel. The department has consulted with the Fuel Standards Consultative Committee whose members include representatives from each state and territory, the Commonwealth, fuel and biofuel 4 producers, vehicle manufacturers, consumers and a group with an interest in environment protection. Most stakeholders agree that an E85 automotive fuel standard is needed. GM Holden Ltd and Caltex Australia are continuing to carry out assessment and field testing of E85. Labelling and safety concerns In Europe labelling regulations are the responsibility of individual nations. However, in order to harmonize these regulations, the European E85 automotive fuel technical specification, CEN/TS 15293:2011 Automotive fuels – Ethanol (E85) automotive fuel – Requirements and test methods, 2011, recommends pump marking requirements: Information to be marked on dispensing pumps used for delivering Ethanol (E85) automotive fuel, and the dimensions of the mark shall be in accordance with the requirements of national standards or regulations for the marking of pumps for Ethanol (E85) automotive fuel. Such requirements shall be set out in detail or shall be referred to by reference in a national annex to this European Standard. NOTE – The recommended designation for Ethanol (E85) automotive fuel and its seasonal derivatives is E85.1 There is no reference to labelling requirements in the United States (US) ASTM D5798 – 10a - Standard Specification for Fuel Ethanol (Ed70-Ed85) for Automotive Spark-Ignition Engines. The US National Institute of Standards & Technology (NIST) Handbook 130, Method of Sale Regulation, Section 2.30 sets out the labelling requirements for dispensing E85. It states, A label shall be posted which states ‘For Use in Flexible Fuel Vehicles (FFV) Only.’ This information shall be clearly and conspicuously posted on the upper 50% of the dispenser front panel… A label shall be posted which states, ‘Consult Vehicle Manufacturer Fuel Recommendations.’” The regulation sets out specific font/type height and stroke/width for these labels.2 Currently in Australia, fuel suppliers who supply petrol containing ethanol must comply with the ethanol fuel quality information standard (labelling standard). The labelling standard informs consumers that the fuel they are purchasing contains ethanol. The labelling standard is available at: http://www.environment.gov.au/atmosphere/fuelquality/standards/ethanol/labelling.ht ml. This labelling standard refers to ethanol blended fuel, meaning petrol has been tested in accordance with the Fuel Standard (Petrol) Determination 2001. There are concerns that misfuelling may occur in the marketplace due to the lack of consumer awareness and primarily because the price of Bio E-Flex and other E85 automotive fuel products will be significantly below (by approximately 20 cents per litre) that of regular unleaded petrol. Caltex are clearly labelling the supply of their E85 product Bio E-Flex. Caltex are training service station staff and implementing pump authorisation, vehicle identification and nozzle latch mechanisms to minimise the risk of misfuelling. 5 If other fuel retailers choose not to differentiate E85 bowsers in some significant way or take other steps to prevent misfuelling, there is a risk that consumers may inadvertently use E85 instead of petrol in vehicles not designed for the purpose. Misfuelling with E85 will cause serious damage to the engines of incompatible cars. E85 automotive fuel is not suitable for motorcycles, lawnmowers, boats or light aircraft. Proposed Information Standard (Labelling Requirement) The Government is proposing to require labelling of E85 automotive fuel under the Fuel Quality Standards Act 2000. The label will be required to state the following information: “Contains 70-85% ethanol” “For use in Flex Fuel Vehicles Only” “Not Petrol or Diesel” Additional housekeeping and monitoring of E85 automotive fuel is required at storage and dispensing sites. Ethanol blended fuels are highly water sensitive. Caltex have provided advice to their retail sites on housekeeping requirements for Bio E-Flex, including firefighting and emergency response procedures. International E85 standards United States The US ASTM D5798 – 10a - Standard Specification for Fuel Ethanol (Ed70-Ed85) for Automotive Spark-Ignition Engines was approved in December 2010 and published in January 2011. Changes from the 2009 version include lowering the minimum ethanol content to 68 per cent by volume for all volatility classes (see Table 1). Vapour pressure is the only parameter for which limits vary for the volatility classes, based on climatic conditions.3 Further, the ASTM specification for E85 requires that the ethanol component of the fuel conform to specification ASTM D4806 and the gasoline component of the fuel conform to ASTM D4814. European Union The European Automotive Fuels – Ethanol (E85) - Automotive fuel – Requirements and test methods has progressed from a ‘workshop agreement’ (CWA 15293:2005) to a published Technical Specification CEN/TS 15293:2011. This TS was approved by CEN (Comité Européen de Normalisation; European Committee for Standardization) Sept. 28, 2010 for provisional application. The period of validity of this standard is initially limited to three years. After two years, the members will be requested to provide comments on whether this standard can be converted into a European Standard. There are significant technical changes between this and the CEN Workshop Agreement. They include the inclusion of a density parameter, the allowance of the use of denatured and undenatured ethanol as a blending component 6 (depending on national legislation), indicative limits for RON/MON, a tightening in the inorganic chloride limit and changes to the climate-related requirements (see Table 1). Some of the determination test methods referenced are still being investigated to ensure correct application and precision. Due to this, and the fact that production processes need to be assessed for their capacity to achieve the required future limits, CEN have taken an intermediate step and designated this a Technical Specification.1 A Technical Specification does not have the status of an EN but may be adopted as national standard (http://www.cen.eu/cen/Products/TS/Pages/default.aspx). Harmonisation Australian Government policy is to harmonise fuel standards with international standards where appropriate. Table 1 compares the proposed E85 automotive fuel standard and standards already in place internationally. 7 Table 1 – Comparison of E85 fuel standards Parameter Proposed Australian E85 fuel standard Ethanol content – 70-85% v/v to meet vapour pressure classes. Ethanol content and vapour pressure Industry to determine which class to supply based on local climate, using the Table 3 below as a guide. Acidity (as acetic acid) 0.005 mass % (mg/L) max Appearance Visibly free of suspended or precipitated contaminants (clear and bright) at the ambient temperature or 21°C, whichever is higher. Copper Copper strip corrosion (3 h 50o C) Density Electrical conductivity Ethers (5 or more C atoms) Higher alcohols (C3C8) Inorganic chloride Methanol 0.10 mg/kg max EU CEN/TS 15293:2011 Classes: a: 70-85%, 35.0-60.0 kPa b: 70-85%, 50.0-80.0 kPa c: 60-85%, 55.0-80.0 kPa d: 50-85%, min 60.0 kPa Individual countries decide which classes apply in given regions at given times of year. US ATSM (D 5798-10a) Classes: 1: 68-83%, 38-59kPa @ 37.8C (min ambient temp > 5oC) 2: 68-83%, 48-65kPa (min ambient temp -5o to o 5 C) 3: 68-83%, 66-83kPa (min ambient temp ≤-5o C) 0.005% m/m max 0.005 mass % (mg/L) max 0.10 mg/kg max Product shall be free of suspended or precipitated contaminants (clear and bright). This shall be determined at ambient temperature or 21°C, whichever is higher. 0.07 mg/L max rating class 1 760.0 - 800.0 kg/m3 @ 15C 1.0% v/v max 11.0% v/v max 2% v/v max 6.0% v/v max (C3-C5) 2 v/v % max 1 mg/kg max 0.5% v/v max 1.2 mg/kg maxa 1.0% (v/v) Oxidation stability 360 minutes min 360 minutes min pHe 6.5 - 9.0 Phosphorus 0.0013 g/L max 0.15 mg/L max 1 mg/kg max 0.5 vol % max 240 minutes min (applicable only for the hydrocarbon blend component) 6.5 - 9.0 0.0013 g/L max and no intentional addition (refers to ASTM D 4814) 5 mg/100 mL max 4.0 mg/kg max 70 mg/kg max 1.0% m/m max targeting 104 minb targeting 88.0 minb 5 mg/100 mL max 4.0 mg/kg maxc 10.0 mg/kg max 0.400% m/m max RON, min MON, min Solvent washed gum Sulfate Sulfur Water 5 mg/100 mL max 80 mg/kg maxd 1.0% m/m max Note: in CEN/TS 15293:2011 ethanol volumetric content includes ethanol and higher saturated alcohols. The terms “% (m/m)” and “% (v/v)” are used to represent the mass fraction and volume fraction respectively. a This limit is to be validated in the future following test method, production and distribution assessment. These levels are indicative as the test method is yet to be assessed for application. c This limit is to be validated and might be lowered following production and distribution assessment. d Qualified small refineries have varying maximum sulfur limits for gasoline up to 450 ppm (0.0450 per cent), which are based on their 1997-98 sulfur level baseline. If gasoline from qualified refineries is used to blend Ed75-Ed85, the maximum sulfur level shall be for 134 mg/kg. The California Air Resources Board (ARB) proposes that sulfur be reduced to 20ppm (September 14, 2010, ‘ARB Workshop Regarding CaRFG, E10 Certification Fuel and E85’ reported in member area of www.globalbiofuelscenter.com) b 8 Table 2 - Summary of proposed E85 automotive fuel parameters and test methods It is proposed that Ethanol (E85) automotive fuel be defined as a fuel blend, nominally of fuel grade ethanol and petrol (that meets the requirements of the fuel quality standard for petrol set out in the Fuel Standard (Petrol) Determination 2001), that conforms to the limits specified below. Parameter Proposed specifications for Ethanol (E85) automotive fuel standard Test methods Ethanol 70-85% v/v to meet vapour pressure classes* ASTM D5501 (modified) Acidity (acetic acid) 0.005% mg/L max ASTM D1613 Appearance Visibly free of suspended or precipitated contaminants (clear and bright) at the ambient temperature or 21°C, whichever is higher. ASTM D4806 Copper 0.10 mg/kg max EN 15837 Ethers (5 or more C atoms) 1.0% v/v max ASTM D5501 (modified) Higher alcohols (C3-C8) 2% v/v max ASTM D5501 (modified) Inorganic chloride 1 mg/kg max Methanol 0.5% v/v max ASTM D5501 (modified) Oxidation stability 360 minutes min TBA pHe 6.5-9.0 ASTM D6423 Phosphorus 0.0013 g/L ASTM D3231 Solvent washed gum 5 mg/100 mL max ASTM D381 Sulfate 4.0 mg/kg ASTM D7319 Sulfur 70 mg/kg ASTM D5453 Water 1.0% m/m max ASTM E1064 *Vapour Pressure ASTM D7319 ASTM D7328 ASTM D5190 Industry (retailers and/or distributors) shall determine which class to supply in any given month, taking into account local climate and using Table 3 below as a guide. Class 1, Summer blend: (10th percentile min > 5oC) 38-59 kPa @ 37.8C Class 2, Winter blend: (10th percentile min -5o to 5oC) 48-65 kPa @ 37.8C The maximum vapour pressure shall be whichever is the lower of the limit stated above or that set by the State or Territory government. 9 Table 3 – Recommended classes of fuel for supply based on climate Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct NSW/ACT 1 1 1 2 2 2 2 2 2 2 Vic 1 1 1 2 2 2 2 2 2 2 Tas 2 2 2 2 2 2 2 2 2 2 SA 1 1 1 1 2 2 2 2 2 1 WA north 1 1 1 1 1 1 1 1 1 1 WA south 1 1 1 1 1 2 2 2 2 2 NT north 1 1 1 1 1 1 1 1 1 1 NT south 1 1 1 1 2 2 2 2 1 1 Qld north 1 1 1 1 1 1 1 1 1 1 Qld south 1 1 1 1 2 2 2 2 2 1 Nov 2 2 2 1 1 1 1 1 1 1 Dec 1 1 2 1 1 1 1 1 1 1 The boundary between north and south Queensland and the Northern Territory is set at 18S latitude, which runs just below the Gulf of Carpentaria. The boundary between north and south Western Australia is set at 20S latitude, which crosses north of Port Hedland. These regions are based on climatic data, and the latitudes chosen for simplicity. The values are necessarily conservative to allow engine starts on arrival in cooler areas after refuelling in warmer areas and allowing a margin at the beginning and end of each season. Values are established for each state or part thereof in Australia by viewing the Bureau of Meteorology’s Minimum Temperature 10th Percentile maps for each month of the year, which have been averaged over the years 1950 to 2005, and incorporating a 500 km buffer which represents the maximum distance that a typical vehicle could travel on a single tank of petrol. 10 APPENDIX A – Technical background to parameters and test methods 11 1. Ethanol content and vapour pressure The ethanol content of E85 automotive fuel is a critical parameter as it affects the capability of the fuel metering system of flexible-fuel vehicles to establish the proper air/fuel ratio for optimum vehicle operation.3 Ethanol content may also affect the lubricating properties of the fuel, the water tolerance of the fuel, and the ability to meet cold or cool area volatility requirements.3 E85 must be seasonally adjusted to ensure proper starting in colder climates. In the US, E85 sold during colder months contains a minimum of 68 per cent ethanol and a maximum of 32 per cent petrol to produce the vapour pressure necessary for cold temperatures. In Europe, ethanol content may be as low as 50 per cent to allow for operability under very cold conditions. International trends The European CEN/TS 15293:2011 defines E85 as “a mixture of nominally 85% (V/V) ethanol complying to EN 15376 and petrol complying to EN 228, but also including the possibility of having different ‘seasonal grades’ containing more than 50% (V/V) ethanol.”1 US ASTM D5798-10a specification “covers a fuel blend, nominally 70 to 85 volume % denatured fuel ethanol and 30 to 15 additional volume % hydrocarbons for use in ground vehicles with automotive spark-ignition engines.”3 Each standard specifies ethanol content and vapour pressure according to Table 4. Table 4. EU and US Ethanol content and vapour pressure EU CEN/TS 15293:2011 Classes: a: 70-85%, b: 70-85%, c: 60-85%, d: 50-85%, 35.0-60.0 kPa 50.0-80.0 kPa 55.0-80.0 kPa min 60.0 kPa US ATSM D 5798-10a Classes: 1: 68-83%, 38-59kPa @ 37.8C (min ambient temp > 5oC) 2: 68-83%, 48-65kPa (min ambient temp -5o to 5oC) 3: 68-83%, 66-83kPa (min ambient temp <-5o C) Individual countries decide which classes apply in given regions at given times of year. Note: in CEN/TS 15293:2011 ethanol volumetric content includes ethanol and higher saturated alcohols Options considered for Australian E85 Standard Following US and European practice, it is proposed that vapour pressure be used in conjunction with ethanol content to define volatility classes for this standard. The ethanol content range of 70–85 per cent, based on the draft European standard, is very close to the US standard (68–83 per cent) and will give suppliers freedom to match the exact ethanol content to local climatic conditions. Some states and territories restrict maximum vapour pressures of petrol in summer in urban areas to reduce air pollution from evaporation. Where such regulations exist 12 and apply to E85, the fuel will need to comply with both those standards and this proposed standard (that is, conform to the lower of the two). Two blends of E85 automotive fuel will probably be needed in Australia to guarantee that vehicles will start in all regions at all times of the year. During winter, where minimum temperatures fall below 5C, the fuel will need to contain less ethanol (closer to 70 per cent) and more petrol to allow cars to start. Where average minimum temperatures are above 5C, the fuel can contain a higher proportion of ethanol, up to the maximum of 85 per cent. The two volatility classes defined for this standard, similar to the US ASTM standard, are: Class 1 Summer blend Class 2 Winter blend 10th percentile minimum temperature >5C -5C to 5C Ethanol 70-85% 70-85% Vapour pressure 38-59 kPa 48-65 kPa Decisions on which of these blends should be sold in any month in a given area could be made by distribution companies or individual retailers, or be prescribed by the government. These two options are discussed separately below. It is proposed that the first option (industry decides) be adopted, based on the arguments presented, the size of the industry and the advice of the Fuel Standard Consultative Committee that safety risks are low. Option 1: Industry decides which blend is sold. Under this option, retailers would decide which of the two blends of E85 automotive fuel to sell at different times of the year, taking into account local climatic conditions, the advice of their distributor and using the climatic data in Table 5 below as a guide. The advantages of this approach are: Retailers and distributors have the flexibility to tailor their stocks to local climatic conditions and the needs of their customers. Compliance and regulatory costs are lower. The flexibility to use the higher petrol blend will assist in maintaining supply. The disadvantages of this approach are: Retailers and distributors may not take into account the driving range of customers. A motorist filling up in a warm region on summer blend fuel and driving on one tank of fuel to a cooler region may experience cold startability problems, especially in the case of temperatures below 5C (in the night or morning). This disadvantage could be avoided via consumer education, alerting owners of flex-fuel vehicles that they need to be mindful of driving from a 13 warm to a cold climate. Adding unblended petrol to the fuel tank to increase the vapour pressure should remedy cold startability problems. Retailers may not have a choice of blend type depending on how their fuel is supplied. Distributors may offer a single blend to a group of retailers based on geographical supply lines rather than climatic needs and/or climatic variations. This approach is inconsistent with both the US and the EU, where fuel specifications set the volatility class to be sold for any given time of year and geographical location. This approach is contrary to the EU and US approaches. Option 2: Government prescribes which blend is sold Under this option, the government would prescribe which blend is to be sold in which state/region and at which time. Both the US and EU have adopted this approach. A large table is included in the US ASTM D5798-10a, listing all states and months of the year, and which of the three classes applies. For example, in the state of Alabama in February, class 2 fuel must be supplied. The European CEN/TS 15293:2011 has four climatic classes, with the summer class mandated not later than from 1 May to not after 30 September and individual countries deciding which classes apply at other times of the year within their borders. Table 5 below proposes the times and places that the two volatility classes could apply in Australia. This draft table could be included in the determination if this option is adopted. Alternatively, it could be presented as a guide for industry if Option 1 is adopted. Volatility classes have been determined for each state or part thereof in Australia by viewing the Bureau of Meteorology’s Minimum Temperature 10th Percentile maps for each month of the year, which have been averaged over the years 1950 to 2005, and incorporating a 500 km buffer which represents the maximum distance that a typical vehicle could travel on a single tank of petrol. Table 5: Proposed E85 volatility classes for Australian climatic zones Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct NSW/ACT 1 1 1/2 2 2 2 2 2 2 2 Vic 1 1 1/2 2 2 2 2 2 2 2 Tas 2 2 2 2 2 2 2 2 2 2 SA 1 1 1 1/2 2 2 2 2 2 1/2 WA north 1 1 1 1 1 1 1 1 1 1 WA south 1 1 1 1 1/2 2 2 2 2 2 NT north 1 1 1 1 1 1 1 1 1 1 NT south 1 1 1 1/2 2 2 2 2 1/2 1 Qld north 1 1 1 1 1 1 1 1 1 1 Qld south 1 1 1 1/2 2 2 2 2 2 1/2 Nov 2 2 2 1 1 1/2 1 1 1 1 Dec 1/2 1/2 2 1 1 1 1 1 1 1 In Table 5, 1/2 means either class is allowed, so as not to penalise for any residual fuel from the previous season found in the supply tank at the beginning of the new 14 season. If this table is used a guide only (Option 1) rather than as a regulatory requirement, ‘1/2’ can be replaced with ‘1’ for simplicity, as in the version of this table presented on page 11 (Table 3) of the position paper. The boundary between north and south Queensland and the Northern Territory is set at 18S latitude, which runs just below the Gulf of Carpentaria. The boundary between north and south Western Australia is set at 20S latitude, which crosses north of Port Hedland. These regions are based on climatic data, and the latitudes chosen for simplicity The advantages of this approach are: Users of E85 are unlikely to find themselves with a car that will not start because they have been sold a summer blend in a winter region or have driven from a warm to a colder region. The table is conservative and allows for a large margin both geographically and between the seasons. There is no need to educate drivers, as the appropriate fuel will always be supplied. It is consistent with the approach taken in both the US and the EU, providing harmonisation. The disadvantages of this approach are: Conceptually, this is a more complex regime to explain, enforce, and implement, than Option 1. There is an increased cost to industry of supplying the correct class of fuel to each retailer, with climatic regions not always aligning with supply routes. There is an increased cost to government of regulation including compliance testing and enforcement. Neither approach requires the setting of a petrol limit in the standard, as the volume of petrol in the mix will be the remainder of the blend once the ethanol volume and vapour pressure parameters are met. The petrol used in the blend must meet the specifications of the Fuel Standard (Petrol) Determination 2001 (petrol standard). Test methods The European CEN/TS 15293:2011 specifies EN 1601 (modified) to determine ethanol and higher alcohol content. Work within CEN has revealed that the regular ethanol determination method (EN15721) cannot be applied to E85. The US ASTM D5798-10a specifies ASTM D5501 to determine ethanol content. The suitability of ASTM D5501 for high ethanol blended fuels is still being assessed. The European CEN/TS 15293:2011 specifies EN 13016-1 to determine vapour pressure. The US ASTM D5798-10a specifies ASTM 4953, ASTM D5190 or D5191. 15 Proposed standard It is proposed that the Australian E85 automotive fuel standard set an ethanol limit of 70-85 per cent and refer to test method ASTM D5501(modified) to determine compliance with the standard. Two climatic volatility classes of E85 are proposed to be used by industry: Class 1: 38-59 kPa @ 37.8C (summer blend) Class 2: 48-65 kPa @ 37.8C (winter blend) Industry (retailers and/or distributors) shall determine which class to supply in any given month, taking into account local climate and using Table 5 above, or the simplified version presented on page 11 (Table 3) of the position paper. The maximum vapour pressure shall be whichever is the lower of the limit stated above or that set by the State or Territory government. It is proposed that the Australian E85 automotive fuel refer to test method ASTM D5190 to determine compliance with the vapour pressure limit. 2. Acidity (as acetic acid) Very dilute aqueous solutions of low molecular weight organic acids, such as acetic acid, are highly corrosive to a wide range of metals and alloys. It is therefore necessary to keep such acids at a very low level.3 International trends The European CEN/TS 15293:2011 sets a total acidity (expressed as acetic acid) maximum limit of 0.005 per cent by mass, and specifies test method EN 15491.1 The US ASTM D5798-10a sets an acidity (as acetic acid CH3COOH) maximum content of 0.005 per cent by mass (mg/L), and specifies test method ASTM D1613.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard set a maximum acidity limit of 0.005 per cent by mass (mg/L) and refer to test method ASTM D1613 to determine compliance with the standard. 3. Additives Octane enhancing additives/products include, alcohols (such as ethanol, methanol, npropanol, isobutanol), ethers (for example methyl tertiary-butyl ether (MTBE), diisopropropyl ether (DIPE)), and organometallics (such as methylcyclopentadienyl manganese tricarbonyl (MMT) and ferrocene). International trends The European CEN/TS 15293:2011 states: 16 In order to improve the performance quality the use of additives is allowed. Suitable fuel additives without known harmful side effects are recommended in the appropriate amount, to help avoid deterioration of driveability and emissions control durability. Other technical means with equivalent effect may also be used. CAUTION – Ethanol (E85) automotive fuel shall be free from any adulterant or contaminant that may render the fuel unacceptable for use in petrol engine vehicles designed to run on unleaded petrol and ethanol (E85) automotive fuel. NOTE – Test methods for deposit forming tendency that are suitable for routine control purposes have not yet been identified and developed. The US ASTM D5798-10a does not directly refer to additives. In Appendix X1.1.2 it states: The inclusion of impurities, some denaturants, and contaminants, except for the deliberately added hydrocarbons or additives, or both, can impact adversely on the properties and performance of fuel ethanol (Ed70-Ed85) as an automotive sparkignition engine fuel. The quantities of some of these materials are controlled by specified property limits. The limits on water, higher molecular weight alcohols, and methanol and on types of denaturants as well as minimums on the amount of ethanol and hydrocarbons limit, but do not prevent, the presence of trace materials. Proposed standard The inclusion of an additives limit in the standard would create problems in enforcement and administration of the Fuel Quality Standards Act 2000. It is proposed that the Australian E85 automotive fuel standard does not set a limit for additives. 4. Appearance Turbidity or evidence of precipitation normally indicates contamination.4 International trends The European CEN/TS 15293:2011 does not refer to appearance.1 The US ASTM D5798-10a sets an appearance requirement that “This product shall be visibly free of suspended or precipitated contaminants (clear and bright). This shall be determined at ambient temperature or 21°C (70°F), whichever is higher.”3 Proposed standard It is proposed that the Australian E85 automotive fuel standard set the requirement, “Visibly free of suspended or precipitated contaminants (clear and bright) at the ambient temperature or 21°C, whichever is higher.” ASTM D4806 is the reference standard for appearance. 17 5. Copper content Copper is a very active catalyst for low-temperature oxidation of hydrocarbons, especially in the presence of water. Experimental work has shown that copper concentrations higher than 0.012 mg/kg in petrol may significantly increase the rate of gum formation.3 There has been some discussion on whether a copper parameter is still required given most ethanol production facilities do not use copper tubes and stills. CEN considers that a copper parameter is necessary as future ethanol supplies could come from a range of sources such as whiskey distilleries, which commonly use copper stills. In Australia CSR’s distillation columns are often made of copper, which is common practice in the food and beverage industry since copper assists with odour removal from the ethanol.9 International trends The European CEN/TS 15293:2011 specifies a maximum limit of 0.10 mg/kg copper content, and specifies test methods EN 15488 and 15837 (both modified).1 The US ASTM D5798-10a specifies a maximum limit of 0.07 mg/L copper content, and specifies the modified test method D1688 as outlined in specification D4806.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard set a maximum copper content limit of 0.10 mg/kg and refer to test method EN 15837 to determine compliance with the standard. 6. Copper strip corrosion The copper corrosion test serves as a measure of possible corrosion of copper, brass, or bronze fuel system components. It is currently specified as an operability parameter in the petrol determination (set at Class 1 (3 hours at 50°C) for all grades of petrol). International trends The European CEN/TS 15293:2011 specifies a limit of rating Class 1 (3 hours at 50°C).1 Technical Committee CEN/TC 19 ‘Gaseous and liquid fuels, lubricants and related products of petroleum, synthetic and biological origin’ reported in February 2010 that the copper strip corrosion requirement was merely a copy over from EN 228 (Automotive fuels – Unleaded petrol – Requirements and test methods) and the possibility that the copper strip corrosion requirement could be dropped in the future was accepted.5 The US ASTM D5798-10a does not set a copper strip corrosion limit. Proposed standard It is proposed that the Australian E85 automotive fuel standard does not set a limit for copper strip corrosion. 18 7. Density Density gives an additional measure of the purity of the blendstock.6 International trends The European CEN/TS 15293:2011 specifies a density range (at 15°C) of 760.0 – 800.0 kg/m,3 and test method EN ISO 12185.1 The US ASTM D5798-10a does not specify a density range.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard does not set a density range. 8. Electrical conductivity Electrical conductivity correlates closely with the amount of ions such as chlorides, sulfates, and ions of sodium and iron in the fuel. A higher electrical conductivity means the fuel contains a higher amount of corrosive and metallic ions that promote corrosion and failure in the vehicle fuel line and that also cause injector deposits.6 International trends The European CEN/TS 15293:2011 specifies an electrical conductivity limit of 1.5 µS/cm maximum (limit under consideration). Electrical conductivity can be affected by corrosion inhibitors. If a sample fails this test, a pHe between 6.5 and 9.0, determined by means of either EN 15490 or ATM D 6423, should be used to determine compliance.1 The US ASTM D5798-10a does not specify an electrical conductivity limit.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard does not set a limit for electrical conductivity. 9. Ether (5 or more C atoms) Examples of ethers include methyl tertiary-butyl ether (MTBE), di-isopropyl ether (DIPE), ethyl tertiary-butyl ether (ETBE), tertiary amyl methyl ether (TAME) and ethyl tertiary amyl ether (ETAE). Ethers are used as an oxygenate in petrol, increasing the octane level without requiring the use of tetraethyl lead, which was phased out due to health concerns.7 In Europe ethers can also be used as the denaturant added to fuel ethanol to differentiate it from alcohol that is intended for consumption.1 Two ethers, MTBE and DIPE, are limited in the Australian petrol standard to a maximum of 1 per cent by volume based on concerns about their potential to contaminate surface and ground water supplies. Their chemical affinity for water allows these ethers to travel through the ground and pollute aquifers if fuel should 19 leak from underground storage tanks or be lost during transport.7 MTBE can be tasted in water at the parts per billion level.8 International trends The European CEN/TS 15293:2011 sets a maximum limit on ethers with five or more carbon atoms of 11.0 per cent by volume, and specifies test method EN 1601 (modified).1 The US ASTM D5798-10a does not set a limit on ethers.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard align with the Australian petrol standard for this parameter, as the petrol component should be the only source of ethers. The Australian E85 automotive fuel standard should therefore limit ethers to 1.0 per cent by volume maximum and refer to test method ASTM D5501 (modified) to test compliance. 10. Higher alcohols (C3-C8) Higher alcohols in fuels can be defined as aliphatic alcohols of general formula CnH2n+1OH with N being 3 to 8.2 During the production of ethanol, trace quantities of higher alcohols are formed, including butanols that are also collectively known as fusel oil. There are processes to remove most of the fusel oils. Higher alcohols assist in maintaining water in solution and lowering the dry vapour pressure equivalent (DVPE) of ethanol blends to a certain extent.5 Little feedback has been received to date from Australian stakeholders on this parameter,, apart from general agreement on setting the limit at 2 per cent by volume which aligns with the US standard. International trends The European CEN/TS 15293:2011 sets a maximum limit on higher saturated (C3-C5) mono-alcohols of 6.0 per cent by volume, and specifies test method EN 1601 (modified).1 The US ASTM D5798-10a sets a maximum limit on higher alcohols (C3-C8) of 2 per cent by volume without specifying a test method.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard set a maximum limit for higher alcohols (C3-C8) of 2 per cent by volume and refer to test method ASTM D5501 (modified) to determine compliance with the standard. 11. Inorganic chloride The source of chloride in ethanol is related to the feedstock used to produce the ethanol and in some cases it may come from hydrochloric acid if that acid is used in 20 the production process. Inorganic chlorides are particularly likely to be present in Australian ethanol produced from wheat, as hydrochloric acid is often used to adjust acidity during enzyme conversion.9 Inorganic chlorides are corrosive to many metals, even in low concentrations, and it is desirable to minimise them in ethanol fuel. The contamination of ethanol fuel with metal ions, such as copper, iron, and sodium and inorganic anions such as chloride and sulfate can affect engine performance, since salts and sediments that are formed can block nozzles and filters and induce corrosion in the vehicle components in contact with the fuel. Chloride ions present in chemically polar motor fuels such as E85 are known to be one of the primary species involved in general pitting corrosion, galvanic corrosion, and stress corrosion cracking of automotive components.10 Even at concentrations as low as 2 mg/kg, one study has found significant durability concerns, such as failure of important components, wear, rust, abrasion and metal and salt deposits.10 This study cautions that not all the corrosion can be guaranteed to have occurred solely from the inorganic chlorides in the fuel, but that the concerns are significant enough to warrant caution and further investigation. Fuel Standard (Petrol) Determination 2001 The Australian fuel quality standard for petrol includes quality requirements for the fuel grade ethanol component of blends (blended with petrol up to 10 per cent E10). These quality requirements include a maximum inorganic chloride limit of 32 mg/L. In the case of E10, the final level of inorganic chlorides should never be more than 3.2 mg/L. This specification requires amendment to set a maximum limit of 10 mg/kg in fuel grade ethanol for blending, in line with the updated ASTM D 4806- 10b Standard Specification for Denatured Fuel Ethanol for Blending with Gasolines for Use as Automotive Spark-Ignition Engine Fuel. Australian fuel grade ethanol producers have advised that they can consistently meet an inorganic chloride level of 6 mg/kg or less. They have expressed concern that meeting a maximum limit of 1 mg/kg would require additional capital expenditure to alter current processes and testing procedures. Car manufacturers have advised that as the US, EU, Canada and Brazil have inorganic chloride limits of 1 mg/kg, E85 flex fuel vehicles are designed (globally) for fuel containing a maximum inorganic chloride limit of 1 mg/kg. Allowing a higher level may deter manufacturers from importing flex fuel vehicles into Australia and may lead to corrosion and component damage. General Motors have provided advice that flex fuel vehicle components are designed for 1 mg/kg maximum and companies considering supplying these vehicles to a market that allowed higher levels of chloride would have to re-evaluate their programs. International trends The European CEN/TS 15293:2011 limits inorganic chlorides to a maximum of 1.2 mg/kg, noting that the limit is to be validated in the future following the 21 assessment of test methods, production and distribution.1 CEN’s E85 workshop agreement set the limit at 1 mg/kg in 2005, 11 but this was revised to 6 mg/kg in 2009, recognising test method and distribution difficulties, and then revised again to the current level of 1.2 mg/kg. The test method currently specified is prEN 15492 (modified). The US ASTM D5798-10a limits inorganic chlorides to 1 mg/kg, and refers to test methods D7319 and D7328.3 Test method D512 is also referred to, but is not appropriate as it is described as suitable only for water, wastewater and brine, and cannot accurately detect chloride ions below 7 mg/kg. The US Department of Energy’s National Renewable Energy Laboratory sponsored the CRC Report No.E-85 - National Survey of E85 Quality of November 2009. 12 The goal of this project was to collect samples from each volatility class and analyse for key properties from D5798. The samples representing each volatility class were collected between summer 2008 and summer 2009 and tested against key properties in D5798 such as ethanol content, water content, sulfur, vapour pressure, acidity, pHe, inorganic chloride, and sulfate. Only three samples out of 157 tested exceeded the 1 mg/kg maximum level, with the highest level 5.4 mg/kg. More recent advice from General Motors in the US is that ethanol producers have virtually no issues with meeting the 1 mg/kg limit in the US or in Europe. Proposed standard The objects of the Fuel Quality Standards Act 2000 include “to regulate the quality of fuel supplied in Australia in order to facilitate the adoption of better engine technology and emission control technology, and allow the more effective operation of engines.” It is proposed that the Australian E85 automotive fuel standard set an inorganic chloride limit of 1 mg/kg and refer to ASTM D7319 or ASTM D7328 to determine compliance with the standard. This 1 mg/kg limit on inorganic chloride could be introduced: 1) at the same time as the rest of the standard, and the petrol standard amended soon after; or 2) at the same time as the rest of the standard, and the petrol standard amended concurrently. Industry applicants could seek a Fuel Quality Standards Act 2000 section 13 variation on this parameter to supply E85 with higher inorganic chloride for a limited period. The government may consider granting fee waivers for these applications; or 3) 12 months after the introduction of the ethanol (E85) standard, with a 6 mg/kg interim level, to allow industry to resolve issues, assessment and data collection. The petrol standard would also be amended after 12 months. Stakeholders are encouraged to provide detailed technical information on any issues, particularly relating to specific feedstock and pre-treatment processes, and concerns with meeting this requirement. 22 12. Methanol Methanol is naturally present in industrially produced ethanol in small quantities, and can contribute to combustion of the fuel as an oxygenate. Methanol is also toxic and corrosive, and can cause engine wear. The quality requirements for fuel grade ethanol that can be blended up to 10 per cent with petrol limits methanol to a maximum of 0.5 per cent by volume. International trends The European CEN/TS 15293:2011 limits methanol to a maximum 1.0 per cent by volume, and specifies test method EN 1601 (modified).1 The US ASTM D5798-10a limits methanol to a maximum of 0.5 per cent by volume, without specifying a test method.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard limits methanol to a maximum of 0.5 per cent by volume and refers to test method ASTM D5501 (modified) to determine compliance with the standard. 13. Oxidation stability Oxidation stability is an important parameter for the storage of ethanol fuel, describing its ability to resist degradation. International trends The European CEN/TS 15293:2011 requires that the fuel be stable under testing for a minimum of 360 minutes, using test method EN ISO 7536.1 The US ASTM D5798-10a does not include an oxidation stability parameter, but it does specify, under section 4.1.2, that hydrocarbons shall have oxidation stability of 240 minutes minimum by test method D525.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard set a minimum oxidation stability of 360 minutes. Further technical advice is being sought on suitable test methods to determine compliance with the standard. 14. pHe The pHe is a measure of the strong acidity of the fuel.5 The range of 6.5 to 9.0 ensures that the fuel is not corrosive to the engine.12 When pHe is below 6.5 fuel pumps can malfunction as a result of film forming, fuel injectors can fail from corrosive wear, and excessive engine cylinder wear can occur. When the pHe is above 9.0 fuel pump plastic parts can fail.9 23 Both pHe and electrical conductivity can be used to analyse the risks of corrosion. The quality requirements for fuel grade ethanol in Australia that can be blended up to 10 per cent with petrol states that the pHe value must be no less than 6.5 and no more than 9.0. International trends The European CEN/TS 15293:2011 no longer sets a pHe range. It now uses electrical conductivity (1.5 S/cm) as a measure of corrosive potential but also states that if the electrical conductivity limit is not met, pHe must then be tested and found to be in the range of 6.5 and 9.0, using either test method En 15490 or ASTM D6423.1 The US ASTM D5798-10a requires the pHe value to be between 6.5 and 9.0 and specifies test method D6423. It does not have an electrical conductivity parameter.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard require the pHe value to be no less than 6.5 and no more than 9.0, and refer to test method ASTM D6423 to determine compliance with the standard. 15. Phosphorus Phosphorus needs to be limited in order to protect automotive catalyst systems from deactivation.3 Sources of phosphorus in ethanol include fertilisers, nutrients used in the fermentation process and the feedstock itself if it is non-traditional.13 The Australian petrol standard sets a maximum limit of 0.0013 g/L for phosphorus content. International trends The European CEN/TS 15293:2011 sets a phosphorus maximum limit of 0.15 mg/L and specifies test methods EN 15487 and EN 15837 (modified).1 The US ASTM D5798-10a does not set a limit for phosphorus, however it does not allow phosphorus to be intentionally added to the fuel, and the appendix of the document, Non-mandatory information, recognises the effect on catalysts and limits phosphorus to trace amounts. The specification also notes that “EPA regulations limit their maximum concentrations in unleaded gasoline to … 0.0013 g/L.”3 Proposed standard It is proposed that the Australian E85 automotive fuel standard set a maximum phosphorus level of 0.0013 g/L, and refer to test method ASTM D3231 to determine compliance with the standard. 24 16. RON and MON The research octane number (RON) correlates with engine anti-knock performance under mild conditions of operation. The motor octane number (MON) correlates with engine anti-knock performance under severe conditions of operation. Low RON and MON numbers will result in low engine efficiency and therefore poor fuel economy. Minimum indicative octane levels are desirable to allow vehicle manufacturers to ensure that they maximise fuel economy and at the same time avoid engine knock and hence potential engine damage.3 Pure ethanol has a high octane rating, of 129 RON and 102 MON. Ethanol is a known octane enhancer for petrol. The Australian petrol standard has a minimum RON of 91.0 for unleaded petrol and 95.0 for premium unleaded petrol, and a minimum MON of 81.0 for unleaded petrol and 85.0 for premium unleaded petrol. As the proposed E85 standard requires the petrol used in the blend to comply with the petrol standard, the addition of ethanol can only raise the RON and MON numbers, ensuring they are at required operational levels. It may therefore be unnecessary to set levels for RON and MON in this standard. International trends The European CEN/TS 15293:2011sets only indicative targets for RON and MON. RON is targeted at a minimum of 104 and MON should be a minimum of 88.0, ‘which in the normal situation is achieved’. These limits are not mandated because of limited experience of E85 octane levels and test method issues with octane measurement above 100 RON. However, minimum octane levels are required by vehicle manufacturers for engine calibration so these indicative levels have been included.1 The US ASTM D5798-10a does not refer to RON or MON.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard not set minimum levels for RON and MON. 17. Solvent washed gum Even at ambient temperature, fuel can undergo an oxidation process which may lead to the formation of gums. These gums can cause engine fuel pump locking, nozzle obstruction, and piston ring sticking.6 The quality requirements for fuel grade ethanol that can be blended up to 10 per cent with petrol limits solvent washed gum to 5.0 mg/100mL (50 mg/L). International trends The European CEN/TS 15293:2011 sets a solvent washed gum limit of 5 mg/100 mL (50 mg/L) and specifies test method EN ISO 6246.1 25 The US ASTM D5798-10a sets a solvent washed gum limit of 5 mg/100 ml (50 mg/L) and specifies test method D381.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard set a maximum solvent washed gum level of 5 mg/100 mL (50 mg/L) and refer to test method ASTM D381 to determine compliance with the standard. 18. Sulfate Sulfate contamination in ethanol fuel can plug and corrode engines and inhibit catalysts. When the fuel is burned, sulfates may also contribute to sulfuric acid emissions.15 Increasingly stringent regulations and limits are being placed on sulfur compounds in order to reduce emissions. Hundreds of car engines were damaged in Sweden in 2010, the problem apparently due to high sulfate concentrations in the ethanol clogging fuel injectors.14 Sulfur dioxide can be used in the wet milling process of ethanol manufacture, which if not fully removed remains as sulfates in the final fuel. The quality requirements for fuel grade ethanol that can be blended up to 10 per cent with petrol limits sulfate to a maximum of 4 mg/kg. International trends The European CEN/TS 15293:2011 sets a maximum sulfate limit of 4 mg/kg, noting that the limit is to be validated and might be lowered following production and distribution assessment. It specifies test method prEN 15492 (modified).1 The US ASTM D5798-10a sets no sulfate limit.3 The US ASTM standard for denatured fuel ethanol that is intended to be blended into gasoline for use in non-flexfuel vehicles limits sulfates to a maximum of 4 mg/kg. Proposed standard It is proposed that the Australian E85 automotive fuel standard set a maximum sulfate level of 4.0 mg/kg and refer to test method ASTM D7319 to determine compliance with the standard. 19. Sulfur A limit on sulfur is required to protect against engine wear, deterioration of engine oil, corrosion of exhaust system parts, and exhaust catalyst deactivation, and to reduce emissions of sulfur dioxide, which leads to acid rain, and particulates.15 The quality requirements for fuel grade ethanol that can be blended up to 10 per cent with petrol limit sulfur to a maximum of 30 mg/kg. The Australian petrol standard 26 (unleaded petrol) has a maximum sulfur limit of 150 mg/kg. In the 70 per cent blended fuel, a maximum of 21 mg would be contributed by the ethanol component, and a maximum of 45 mg from the petrol, giving a possible theoretical maximum total of 66 mg. Most unleaded petrol in the Australian market is well below the 150 mg/kg maximum level, with an average of 63 mg/kg (based on data collected by the department between August 2004 and December 2010). International trends The European CEN/TS 15293:2011 limits sulfur content to a maximum of 10 mg/kg and specifies test methods EN 15485 and 15486, (both modified).1 European Directive 98/70/EC relating to the quality of petrol and diesel fuels and EN 228:2008 (the European unleaded petrol standard) set a maximum sulfur level of 10 mg/kg.16 The US ASTM D5798-10a limits sulfur content to 80 mg/kg, excepting some smaller refineries, and specifies test methods D1266, D2622 D3120, or D5453.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard set a maximum sulfur content of 70 mg/kg and refer to test method ASTM D5453 to determine compliance with the standard. 20. Water content Water contamination of ethanol (E85) fuel may affect the calibration of some types of composition sensors of flexible-fuel vehicles. It also reduces the energy content of the fuel and thus adversely affects fuel economy and power. At extreme levels, particularly in cold temperatures, it will cause the petrol to separate from the ethanol and cause starting problems.4 The quality requirements for fuel grade ethanol that can be blended up to 10 per cent with petrol limits water content to 1.0 per cent by volume. International trends The European CEN/TS 15293:2011 limits water content to a maximum of 0.400 per cent by mass and specifies test methods EN 15489 or EN 15692, (both modified).1 The US ASTM D5798-10a limits water content to a maximum of 1.0 per cent by mass and specifies test methods E203 or E1064.3 Proposed standard It is proposed that the Australian E85 automotive fuel standard set a maximum water content limit of 1.0 per cent by mass and refer to test method ASTM E1064 to determine compliance with the standard. 27 REFERENCES 1 European Committee for Standardization (CEN), CEN/TS 15293:2011 Automotive fuels – Ethanol (E85) automotive fuel – Requirements and test methods, 2011. National Institute of Standards and Technology –US Department of Customs, Uniform Laws and Regulations in the areas of legal metrology and engine fuel quality – NIST Handbook 130, 2009, http://ts.nist.gov/WeightsAndMeasures/Publications/upload/HB130-2009-PDFFullDoc.pdf, last accessed 11/11/2010. 2 3 ASTM International, D5798-10a - Standard specification for fuel ethanol (Ed70-85) for Automotive Spark-Ignition engines, USA, January 2011. 4 S J Rand (editor), Significance of tests for petroleum products, 8th ed, ASTM International, USA, 2010. 5 European Committee for Standardization (CEN), Technical Report - PD CEN/TR 15993:2010. Automotive fuels – Ethanol (E85) automotive fuel – Background to the parameters required and their respective limits and determination, February 2010. 6 Worldwide Fuel Charter, Ethanol Guidelines, March 2009. 7 W L Leffler, Petroleum refining, 3rd edition, PennWell, USA 2000. 8 Department of the Environment and Heritage, Setting national fuel quality standards – Paper 2A Proposed management of petrol octane enhancing additives/products, Canberra, 2000. 9 International Fuel Quality Centre, Setting a national standard for fuel ethanol, a report presented to the Department of the Environment and Heritage, Canberra 2004. 10 S Clarke & W Studzinski, Flex fuel vehicle performance and corrosion study of E85 fuel with chloride addition, Society of Automotive Engineers Powertrain Fuels and Lubricants Meeting, USA 2010, http://papers.sae.org/2010-01-2088/. 11 European Committee for Standardization (CEN), CWA 15293:2005 Automotive fuels – Ethanol (E85) automotive fuel – Requirements and test methods, 2005. 12 T L Alleman et al., CRC 2009, Report No. E-85 National survey of E85, Coordinating Research Council, USA, 2009, http://www.crcao.com/reports/recentstudies2009/E-85/E85%20Final%20Report%20_120609_.pdf, last accessed 2/11/10. 13 Tripartite Task Force: Brazil, European Union & USA, White paper on internationally compatible biofuel standards, 2007, http://ec.europa.eu/energy/res/biofuels_standards/doc/white_paper_icbs_final.pdf. last accessed 2/11/10. The Local: Sweden’s news in English, Payment row over ethanol car repairs, The Local Europe AB, 23 July 2010, http://www.thelocal.se/27948/20100723/, last accessed 2/11/10. 14 28 15 Department of the Environment and Heritage, Setting national fuel quality standards – Paper 2 Proposed standards for fuel parameters (petrol and diesel), Canberra, 2000. European Committee for Standardization (CEN), EN 228, Automotive fuels – Unleaded petrol - Requirements and test methods, 2008. 16 29