Renewable Diesel and its Effect on Tanks, Lines, and Equipment in the Tanks By Sam Gordji, Ph.D. Email: samgordji@egreenee.com Web: www.egreenee.com Environmental Consultant and Former University of Mississippi Assistant Professor Prepared for Neste Oil 1 Table of Contents List of Tables ................................................................................................................................................. 3 Abstract ......................................................................................................................................................... 4 Keywords....................................................................................................................................................... 5 About the Author .......................................................................................................................................... 7 I. The Fabric of Renewable Hydrocarbon Diesel ........................................................................................... 8 A. Summary ............................................................................................................................................... 8 B. Introduction ........................................................................................................................................ 10 C. Background ......................................................................................................................................... 12 D. Chemical Characteristics of Renewable Hydrocarbon Diesel ............................................................. 14 E. Naming of Renewable Hydrocarbon Diesel ....................................................................................... 17 II. Effect of RHD on Leak Detection Equipment .......................................................................................... 18 A. Impact of RHD on Leak Detection Equipment .................................................................................... 18 B. Leak Detection Equipment Testing ..................................................................................................... 27 C. Concluding Remarks............................................................................................................................ 35 III. References ............................................................................................................................................. 36 2 List of Tables Table 2.1: Properties and Requirements for Fuels ................................................................................ 20-21 Table 2.2: Comparative Fuel Properties...................................................................................................... 22 Table 2.3: N100 Fuel Properties.................................................................................................................. 24 Table 2.4: N100 Fuel Properties.................................................................................................................. 25 Table 2.5: N100 Element Analysis Data ...................................................................................................... 26 3 Abstract This paper investigates the effect of the renewable hydrocarbon diesel (RHD) on tank systems, the leak detection equipment installed in the tank and the pipelines associated with the tank systems. This report has two parts. In the first part the chemical characteristics of the RHD, its storage and distribution is explained. Several sources were reviewed and a few are mentioned here. Reports from these reliable federal, state, or non-profitable organizations indicate that the chemical texture of RHD is stable and contains fewer harmful chemicals than petro diesel or ULSD. It also can be stored for a long time. When samples of NEXBTL (Neste Oil’s trade name for their RHD) from 2005 were recently examined, their texture, color and chemical contents were the same as those of RHD that were recently produced. The second part of this report covers the compatibility of NEXBTL with the leak detection equipment that is installed in the tank. According to several reports from the California Air Resources Board (CARB), ASTM and others, RHD is compatible with leak detection equipment in the tank. The compatibility of these equipments with NEXBTL is studied and reported at the end of the second part of this report. 4 Keywords ARB/CARB California Air Resources Board ASTM ASTM International, American Society for Testing and Materials ATG Automatic Tank Gauging CARB Diesel California’s Ultra Low Sulfur Diesel CCR California Code of Regulations CRC Coordinating Research Council EGR Exhaust gas recirculation EPA Environmental Protection Agency Ex x is percent of ethanol in gasoline, e.g. E10 means 10% ethanol and 90% gasoline, and so on FAME Fatty Acid Methyl Esters GTL Gas to Liquid GTO Gas to Oil HDRD Hydrogenation-derived renewable diesel HVO Hydro-treated Vegetable Oil Iso-paraffin Saturated hydrocarbon (alkane) with carbon chain containing one or more branches MMWG Multimedia Working Group NWGLDE National Work Group Leak Detection Evaluation n-paraffin Saturated hydrocarbon (alkane) with straight carbon chain N100 Neste neat Renewable Hydrocarbon Diesel Nx x is percent of NEXBTL in diesel, e.g. N10 means 10% NEXBTL and 90% diesel, and so on NEXBTL Trade name for Neste neat Renewable Hydrocarbon Diesel 5 NREL National Renewable Energy Lab RD Renewable Diesel RD1-RD6 Six renewable diesel samples analyzed by CRC RHD Renewable Hydrocarbon Diesel Rx x is the percent of renewable diesel in diesel, e.g. R10 means 10% renewable diesel and 90% diesel, and so on Saturated Compound Is a substance in which the atoms are linked by single bounds. A fully saturated compound contains no double or triple bounds Tanks Both underground and aboveground storage tanks for storing fuels THC Total Hydro-Carbon ULSD Ultra Low Sulfur Diesel 6 About the Author A partial listing of Dr. Sam Gordji's academic and industrial publications and other technical achievements may be found on the webpage: www.egreenee.com. For a specific question on a particular topic please email Sam Gordji at: samgordji@egreenee.com 7 I. The Fabric of Renewable Hydrocarbon Diesel Summary This paper focuses on the effect of the renewable hydrocarbon diesel (RHD) on tank systems (underground storage tanks, above ground storage tanks, and equipment in the tank such as pumps, pipelines, and leak detection equipment, etc.). It does not address every fuel that someone might call renewable diesel. While the references cited may identify the product as simply renewable diesel or by various trade names, we believe the fuels being described are renewable hydrocarbon diesel. Currently most renewable hydrocarbon diesel is produced by hydro-treating vegetable oils or animal fats. Hydro-treating is a process used in the refining industry to convert traditional diesel fuel to the ultra-low sulfur diesel fuel (ULSD) that is required for use in today’s cleaner burning diesel engines. During hydro-treating, in addition to removing the sulfur compounds, the double carbon-carbon bonds in any olefins in the feedstock are saturated with hydrogen and some aromatic rings are opened to form more paraffins. When vegetable oils and animal fats that are typically branched or straight chain molecules are charged to a hydrotreater it de-oxygenates the fatty acids and saturates any double bonds to produce paraffinic hydrocarbons. Therefore RHD contains essentially no oxygen, sulfur or aromatics and generally burns more cleanly than diesel fuel that contains higher concentrations of sulfur and aromatics. Leak detection equipment measures the activities in the tank. Leak detection systems that are placed in the tank perform a variety of activities including: detecting a leak, sales, delivery and theft. These equipments have generally been working properly and reliably when tanks contain diesel. A report from Equipment World states that ultra-low sulfur diesel (ULSD) is not corrosive1. Furthermore, the report goes on to say renewable diesel is not corrosive. Detailed chemical analyses of renewable diesel in general and Neste Oil’s NEXBTL version of RHD in particular appears in many publications. Some analyses that are directly supported by Neste Oil have chemically analyzed RHD that Neste Oil has produced and other RHDs in various capacities to compare with other vegetable/petroleum fuels. For example, tests by NREL show the emissions of NEXBTL and renewable hydrocarbon oil typically contain smaller amounts of harmful chemicals than CARB diesel. This study uses data from publications supported by Neste Oil and independent sources having no vested interest in a particular oil company such as state and federal governments. Several states, including California, consider RHD comparable to or better than CARB diesel. Statements similar to the one below are frequently seen in their publications regarding renewable hydrocarbon diesel. The California Environmental Protection Agency stated in a white paper that a study “showed 1 http://www.equipmentworld.com/ethanol-a-suspect-in-corrosion-from-ultra-low-sulfur-diesel/ 8 that renewable and synthetic diesels have comparable or better emission characteristics as compared to conventional petroleum-based CARB diesel.” Also from the California Environmental Protection Agency: “Renewable diesel fuels can be expected to behave in the environment in a manner similar to CARB ULSD2” is a statement that appears in several publications from the states and federal government. Further, releases of RHD are said to be similar to CARB ULSD because of their chemical content and similarity in the formulations of the two substances. This study investigates how various leak detection equipments handle renewable hydrocarbon diesel and whether these equipments can correctly report possible losses that may occur in an underground or aboveground storage tanks due to a crack in a tank or faulty pipelines. The long term effects of renewable hydrocarbon diesel on the equipment in a tank such as probes, pumps, pipelines and other equipment that come in contact with renewable hydrocarbon diesel are also discussed. Because structured tank data on the effect of renewable hydrocarbon diesel on the tank and the equipments in the tank are not available, an analytical comparison is made with similar fuels and their effect on the equipments in the tank. Also, references are made to publications from states with more stringent environmental laws such as California who support the storage, distribution and the sales of RHD. They have indicated the similarities of renewable hydrocarbon diesel to other fuels that have no adverse effect on the tank and the equipments in the tank. Although at this time we may not know the effect of renewable hydrocarbon diesel on the leak detection equipment, as will be seen in this paper, there are many advantages associated with producing and burning the renewable hydrocarbon diesel that a routine check of some equipment is worth the cost. It should also be noted that diesel does not have a single formula. Diesel fuel meeting the ASTM D975 standard is a mixture of hydrocarbons and up to 5% esters. The hydrocarbon portion of diesel fuel has varying carbon counts and is a mixture of paraffins (alkanes), naphthenes (cyclic paraffins) and aromatics (cyclic hydrocarbons containing at least one benzene ring). The paraffins in traditional diesel are indistinguishable from the paraffins in renewable hydrocarbon diesel. 2 http://www.arb.ca.gov/fuels/multimedia/meetings/RenewableDieselStaffReport_Nov2013.pdf 9 Introduction Renewable hydrocarbon diesel is a relatively new fuel product. Commercial production began in 2007. Its nomenclature is still evolving. In the literature it is known by a variety of names including simply renewable diesel and others that represent production processes or brand names. While most renewable diesel fuels in commerce today consist mainly of hydrogen and carbon, the generic term renewable diesel could contain non-hydrocarbon molecules for which we have little experience and data. As renewable diesel’s reputation as a cleaner burning, low carbon, and environmentally friendly fuel has grown, some have applied the term to fuels that are substantially different from the hydrocarbon version. Because we simply do not know the composition or properties of these nonhydrocarbon products this paper focuses on renewable hydrocarbon diesel. While the fuels described in various literature sources may be identified as renewable diesel or by trade names we believe the sources cited are providing information and data about renewable hydrocarbon diesel. Renewable hydrocarbon diesel is environmentally friendly and there are many articles on its production and use. Several articles with different objectives and aims exist on renewable hydrocarbon diesel with some details. A few of them are published by: Coordinating Research Council (CRC), Cooperative Fuel Research (CFR), US Department of Energy (DOE), National Renewable Energy (NRE), Oak Ridge National Laboratory (ORNL), and Pacific Northwest National Laboratory (PNNL). A few states, federal agencies and some private entities have also studied alternative and renewable hydrocarbon diesel fuels. For example CRC has thoroughly analyzed renewable hydrocarbon diesel using various machines for analyzing chemical compounds and different testing methods including those suggested by ASTM and others to chemically analyze the renewable hydrocarbon diesel and ultra-low sulfur diesel (ULSD) in some details. The samples used by CRC were from six different brands of renewable diesel, four of the samples were ULSD; another four samples were advanced alternative fuels which consisted of compounds derived from gas-to-liquids (GTL), shale oils and oil sands. A total of sixteen samples were tested. Several more references may be copied and viewed from www.egreenee.com. Chemically, hydro-treated vegetable oils (HVOs) are mixtures of paraffinic hydrocarbons. They are free of sulfur and aromatics because of the method of production. Their carbon range is usually between C10-C20 depending on the manufacturers’ requirements and the feedstock selected. There are several methods of producing RHD. Most RHD is currently produced by hydrotreating vegetable oils, animal fats and waste greases. The hydrotreaters are very similar to those used by petroleum refiners to reduce the sulfur and aromatic content of traditional diesel fuel to produce ultra low sulfur diesel (ULSD) fuel. Hydrotreating these oily biomass feedstocks removes oxygen, double bonds and most trace contaminants and produces paraffinic hydrocarbons. A second method for producing RD involves a series of reactions of enzymes that results in the production of hydrocarbons. A third popular method is combusting a biomass source in order to yield carbon monoxide and hydrogen gas. These two products then undergo a series of reactions which yield liquid hydrocarbons3. There are several major companies that are currently involved in producing renewable hydrocarbon diesel while many more may begin to produce renewable hydrocarbon diesel in the near future. There is a need to educate both the public and public officials in charge of policy making concerning the behavior 3 Multimedia Working Group. "Multimedia Evaluation of Renewable Diesel." California Environmental Protection Agency., Nov. 2013 10 of this product and its possible use in a variety of diesel engines, from boats to trucks and trains. In 2012, the global renewable diesel production capacity was 0.74 billion gallons per year4. As stated previously, there are several methods to produce renewable hydrocarbon diesel (RHD). Therefore, different manufacturers will have a slightly different formula for their RHD. Because of this, each manufacturer will define their product by a slightly different name. One of the common and more widely known names is: hydrogenation-derived renewable diesel (HDRD) also known as renewable diesel (RD). RD is the product of fats or vegetable oils refined by a hydro-treating process. This fuel is sometime called “non-ester renewable diesel” because it does not contain esters and it helps to differentiate it from biodiesel that must contain esters and meet ASTM D6751 Specification for Biodiesel Fuel Blend-stock (B100) for Middle Distillates. Referring to renewable diesel (RD) as renewable hydrocarbon diesel (RHD) enhances that differentiation as well as differentiates RHD from other renewable products that are neither esters nor hydrocarbons that someone might want to use in a diesel engine. There are a few other definitions, and new ones are still evolving because manufacturers want to make a more precise definition that clearly distinguishes RHD from other fuels. At this time different agencies with different interests have slightly varying definitions for renewable diesel that typically require the product to consist mainly of hydrocarbons. The hydrocarbon requirement makes RHD more like traditional diesel fuel that consists mainly of hydrocarbon and no more than 5% biodiesel. Eventually a simple and clear definition will emerge for renewable hydrocarbon diesel representing its content and distinguishing it from other fuels, further a name that consumers would like and easily accept. The more quickly this occurs will increase the likelihood of RHD becoming more of a household name. However, because we are discussing its impact on transportation, storage and leak detection equipment we are focusing on renewable hydrocarbon diesel as a name and description because we have many years of experience with how hydrocarbons interact with this equipment, 4 Lambert, Natalie. "Study of Hydrogenation Derived Renewable Diesel as a Renewable Diesel Fuel Option in North America." Eco-Ressources Consultants, 30 Mar. 2012. Web. 11 Background In 1990, the Environmental Protection Agency (EPA) published seven documents regulating the leak detection and the sale of petroleum products5. The owners and operators of the fuel stations are required to check for leaks on a routine basis using one of a number of detection methods mentioned in the seven protocols originating from the EPA’s underground storage tank regulations6. In order to ensure the effectiveness of these methods, the EPA set minimum performance standards for equipment used to comply with the regulations. The seven protocols cover the test procedure to evaluate the release of the petroleum products from the USTs or from the pipelines connecting the tanks and carrying the fuels to the dispensing pumps and other locations. These documents also include a wide variety of leak detection testing requirements for tanks and pipelines. The test procedure is designed to evaluate these systems against the performance standards in EPA's underground storage tank regulations, which cover an hourly leak detection test, a monthly monitoring test, and a line tightness test. For example, after December 22, 1990, all automatic tank gauging (ATG) systems must be capable of detecting a 0.20 gallon per hour leak rate with a probability of detection of at least 95% and a probability of false alarm of no more than 5%. In order to comply with these regulations tank owners and operators installed a variety of leak detection systems to monitor the activities in the tank as well as the sales and the delivery of their petroleum products. Originally these leak detection equipments were required to report sales, delivery, and any possible leak. Later additional components were added to the leak detection equipments enabling them to report the amount of the water at the bottom of the tank as well. EPA recommends three methods for the manufacturer of the leak detection device to show their equipment meets or surpasses the detection limits set by EPA: 1. Evaluate the method using EPA's standard test procedures for leak detection equipment. 2. Evaluate the method using a national voluntary consensus code or standard developed by a nationally recognized association or independent third-party testing laboratory. 3. Evaluate the method using a procedure deemed equivalent to an EPA procedure by a nationally recognized association or independent third-party testing laboratory. Before a new leak detection technology is installed in a tank by the owner/operator, it should be tested by a third party and approved by the National Work Group on Leak Detection Evaluation (NWGLDE). There is a list of approved leak detection systems on the NWGLDE website. NWGLDE consists of a group of state and federal regulators that review leak detection evaluations and determine if each evaluation was performed in accordance with an acceptable leak detection test method and meets the EPA protocol. NWGLDE also examines new evaluation protocols and other issues affecting the leak detection and underground storage tanks (UST) industry. The new technologies require passing test protocol to ensure they comply with the standard set by the EPA. These could be some combination of the seven protocols mentioned or a new protocol for new 5 “Standard Test Procedures for Evaluating Leak Detection Methods," EPA/530 UST90/001-7, March to October 1990. 6 “40 CFR Part 280, Subpart D”. 12 fuels such as ethanol blends and ethanol, biodiesel blends and biodiesel, renewable hydrocarbon diesel and blends and potential fuel products that are simply unknown at this time. In the past, leak detection equipment has withstood a variety of fuels, from traditional gasoline and diesel that were essentially all hydrocarbons that had been derived from petroleum to fuel products that contain non-hydrocarbon (usually oxygenated) blend-stocks and hydrocarbons derived from nonpetroleum sources. Recently, there have been some reports that gasoline that contain more than 20% ethanol by volume may be damaging to the leak detection equipment. This has created the question, what impacts will higher concentrations of these and other non-traditional fuels have on leak detection equipment? Since RHD is fairly new, let’s address that question. “Renewable diesel is produced from non-petroleum renewable resources, but it is not a mono-alkyl ester. RD consists solely of hydrocarbons and meets the California Air Resources Board (ARB) motor vehicle fuel specifications under title 13, California Code of Regulations (CCR), section 2281 et seq. In fact, renewable diesel meets specified aromatic, sulfur, and lubricity standards, as well as ASTM International standard specification, ASTM D975-12a.7.”7 Because RD is fairly new, there is not much tank inventory data on how leak detection equipment measures the activities in the tank containing RD. Petroleum diesel has been widely used for many years in different climates and is chemically similar to renewable diesel. We look into similarities of the two fuels as well as their differences. A few specific characteristics we would like to investigate that differ between the two are the densities and the lack of sulfur content in RD and whether these could cause malfunctioning of the leak detection equipment and inaccurate reporting of the liquid level. If the lack of sulfur is a problem for existing equipment, the industry may have a significant problem as ultra low sulfur gasoline and diesel fuels are being mandated. In order to provide a compliance margin for the mandated sulfur levels at the consumer level there will be fuels and fuel components in the distribution infrastructure that contain essentially no sulfur. Equipment that requires sulfur contamination to function will need to be modified, replaced or dedicated to high sulfur fuel environments. While it would be interesting to measure the Volume Correction Factor (VCF) of renewable hydrocarbon diesel doing so may not significantly improve the accuracy of temperature correction factors for this fuel. Figure 1 illustrates how the VCF from ASTM table 54B for a 38 to 15o C (approx. 100 to 60o F) temperature correction. Low gravity distillate fuels like RHD typically contain little or no aromatics. As the aromatics content increases diesel fuel gravity increases because aromatics are denser than paraffins. The R2 (0.92) of a linear correlation of % aromatics Vs density is not bad when one considers that the there are multiple test methods to determine % aromatics and the gravity/aromatic data points were gathered from random multiple sources. The fact that gravity appears to be a function of composition and that VCF varies with gravity suggests that the existing volume correction factors are adequate. Figure 1 7 Multimedia Working Group. "Multimedia Evaluation of Renewable Diesel." California Environmental Protection Agency., Nov. 2013 13 Chemical Characteristics of Renewable Hydrocarbon Diesel There are many publications on renewable diesel by several national agencies such as National Renewable Energy Lab and Oak Ridge National Lab. There are also some publications on renewable diesel by universities and states, a partial list for these publications may be downloaded from www.egreenee.com. Those published by ASTM may be purchased from ASTM. Some partial ASTM publications may legally be downloaded from the internet. It seems that the most comprehensive and complete report on comparison and testing of different diesel fuels is reported by: “CRC Report No. AVFL-19-2”. All publications on RD, whether they are by a private entity or supported by individual oil companies promoting their product or published by different states or federal government, strongly support the production and the use of the renewable diesel. The agencies from the state of California that are in charge of clean air and water are supporting the production and the use of renewable diesel hoping to minimize the contamination damages that are caused by the release of the petroleum products, not to mention the emission of the harmful gases (NOx) from diesel engines. Renewable hydrocarbon diesel is closer to traditional diesel in chemical formulation than it is to biodiesel, because part of the fabric of biodiesel contains oxygen and double carbon-carbon bonds. The other two fuels contain a few if any molecules with double carbon-carbon bonds or oxygen atoms. Due to similarities that exist between diesel and renewable hydrocarbon diesel, for example, both follow Pascal's law, and their densities are similar to one another, renewable diesel should behave much like diesel when under pressure. Because the density of RHD is less than that of diesel, there may be need for some small adjustments to the probes measuring the activities in the tank. Due to the similarities in the formulation and the chemical structure of the two fuels, the coefficient of the thermal 14 expansion for RD should be close to that of diesel, which is about 0.00046 °F, or 0.000824 °C8. What differences there may be are probably taken into account in the ASTM Table 54B volume correction factors that are a function of product gravity and temperature. Because most analyses and tests show that RHD is chemically similar to CARB diesel, their effect on delicate tank equipments will be similar to traditional diesel, and they should not harm the sensitive equipments. Below is a summary of a few properties of RHD, as well as its storage, distribution, and dispensing. 1. RHD is compatible with existing fuel distribution systems9. RHD and blended RHD can be distributed through modern infrastructure and transported through existing pipelines for dispensing at fueling stations2. 2. RHD is considered alternative diesel fuel. Testing by some agencies indicates that RHD contains 99.97 wt% of hydrogen and carbon. This hydrocarbon content is greater than that of other ULSD’s that are presumed to be hydrocarbon oil as defined in and required by ASTM D975. 3. Over a dozen refineries in various countries such as Finland, Singapore and Ireland have been producing RHD commercially as early as 2006. In the US, several oil companies are producing or plan to produce RHD. Two joint ventures, one formed by Syntroleum and Tyson and another formed by Valero Energy and Darling have started up and several other have been announced. Worldwide, Neste Oil a Finnish refiner is the largest RHD producer. 4. Naming of RHD is similar to other fuels, for example R100 means the renewable hydrocarbon diesel fuel containing 100% RHD. 5. In the Energy Policy Act of 2005, the IRS ruling appeared to allow tax credit for production of renewable diesel that may or may not be renewable hydrocarbon diesel. 6. Renewable hydrocarbon diesel contains a higher cetane number than petro diesel. In North America, most states use ASTM D975 as their diesel fuel standard and the minimum cetane number is set at 40, with typical values in the 42-45 range. 7. The cetane values for the GTL and most renewable hydrocarbon diesels (RD1, RD2, RD4, Neste RHD) are greater than 70 and are significantly higher than other fuels. These high values are typically obtained for diesel fuels that have high concentrations of n- and/or iso-paraffin10. 8 This requires further studies for finding the exact coefficient of thermal expansion for RD for getting a precise volume reading in a UST 9 http://www.afdc.energy.gov/fuels/emerging_green.html 10 CRC Report No. AVFL-19-2 15 8. Some analyses indicate the amount of sulfur and aromatics in RDs are essentially zero, while others report the amount is close to zero. RHD can be easily blended with other fuels such traditional diesel or bio-diesel. 9. Testing showed emissions of gases (CO and NOx) from the exhausts of a 2006 international 6.0 liter V8 were significantly lower than conventional diesel for all varieties of beef, canola, poultry fat, etc. used to produce RD11. 10. Paraffin, also known as an alkane, is any saturated hydrocarbon having the general formula CnH2n+2. RHDs are a mixture of paraffinic hydrocarbons and can be arranged in either straight chains (n-paraffin, such as butane; see figure below) or branched out chains (iso-paraffin). (Hydrocarbon molecules are like Tinker-Toys one can draw diesel boiling range molecules just by simply inserting more H-C-H groups between two carbon atoms or between carbon and hydrogen atoms.) Most of the paraffin compounds in crude oils are normal paraffin, while isoparaffin (that has better cold weather storage and handling properties than n-paraffin) is frequently produced in refineries to enhance cold weather properties. While petroleum diesel contains mostly n-paraffin, diesel obtained from renewable sources is mostly made up of isoparaffin because the conversion processes are similar to those used in the refining industry to produce iso-paraffin and because better cold weather storage and handling properties are desirable. Both iso-paraffin and n-paraffin have good diesel engine combustion characteristics. Below are the chemical structure of n-paraffin and iso-paraffin12. 11 Renewable Diesel Subcommittee of the WSDA Technical Work Group https://www.google.com/search?q=plot+of+branched+chains+%28isoparaffin%29&source=lnms&tbm=isch&sa= X&ei=KR0iU9zEN4O42wXe0YDQBQ&ved=0CAgQ_AUoAg&biw=893&bih=536&dpr=0.9 12 16 Naming of Renewable Hydrocarbon Diesel Most of the literature, research and government approvals concerning renewable diesel have actually been addressing renewable hydrocarbon diesel. By defining renewable hydrocarbon diesel as: “Renewable hydrocarbon diesel n. - hydrocarbon oil derived from biomass that with the addition of chemicals to enhance performance, if required, conforms to the requirements of ASTM D975-14 Standard Specification for Diesel Fuel Oils, and meets the registration requirements under 40 CFR part 79.” The NWGLDE can rely upon the chemical similarities between traditional diesel fuel and renewable hydrocarbon diesel and various statements from EPA, ASTM, states, and national labs to allow renewable hydrocarbon diesel to be used with all equipment listed for diesel. 17 II. Effect of RHD on Leak Detection Equipment A. Impact of RHD on Leak Detection Equipment In the first part of this report the chemical structure and the production of RHD was explained. In these next few sections, the effect of RHD on tanks and the equipment in the tanks such as probes, pumps, as well as the peripheral parts which include pipelines will be discussed. These systems have been installed in tanks in the US since the beginning of the 1990s and have worked with a variety of fuels (gasoline, kerosene, jet fuel, diesel fuel, etc.). Originally, the predominant component of these fuels was hydrocarbon oil derived from petroleum. Probes were developed to accurately report water intrusion and/or any loss of product. Fuels other than petroleum-based hydrocarbons have been introduced to the market and different federal and state agencies are interested in their effects on tank equipment. These rather new fuels can be classified into two groups: hydrocarbon and non-hydrocarbon. Non-hydrocarbons include ethanol (an alcohol) derived from corn and sugar cane that is added to the gasoline-based fuels for consumption in spark ignition engines, biodiesel (a mixture of fatty acid esters) derived from vegetable oils and animal fats that is added to diesel fuel for use in compression ignition engines and some more recently developed fuel components such as bio-butanol and possibly others. The impact of these nonhydrocarbon fuels on tanks and the equipment in the tanks such as probes, pumps, as well as the peripheral parts which include pipelines is not addressed in this document. This document focuses on renewable hydrocarbon diesel that is produced from renewable resources and intended for use in diesel engines. The majority of the leak detection equipment is installed in tanks containing hydrocarbons derived from petroleum and there have not been many reports of equipment failures. Renewable hydrocarbon diesel has been in commerce since 2006 at concentrations ranging from a few percent to 100%. There have been no reports of equipment failures attributed to its presence. The leak detection equipment can accurately report the dispensing and delivery of the product if they are not affected by the content of the fuel or by the chemicals that might have been added to the fuel for various reasons. One cause for equipment malfunctioning in the tank is due to the chemical reactions that occur as a result of the different chemicals that are present in the tank. The accurate reporting of the leak detection system is assured when the tank has not corroded and the leak detection systems are not harmed in anyway. Corrosion in the tank, in the lines or on the leak detection equipment usually occurs when there is a sufficient presence of oxygen, water or alcohol in the tank. Water is the number one solvent and alcohol is the number two solvent. Since the molecular formula for RHD does not contain oxygen, it therefore contains no alcohol or esters. RHD does not have 18 affinity for water, so it can be concluded that leak detection equipment installed in a tank will not be adversely affected by disintegration and conversion of RHD to another substance In the following paragraphs, we have gathered short articles, tables, and data from various sources to compare RHD with other fuels such as petroleum diesel and bio-diesel. From every test conducted by federal, state agencies, or national testing centers, we have found that the amount of undesirable substances, chemicals that are harmful to the tanks and to the tank equipment’s, are rare in RHD. The analysis of RHD revealed the amount of harmful chemicals is less than those in petroleum diesel, bio-diesel or FAME. To save space, we have only reported a few of those findings obtained by different testing agencies. A few of those sources are mentioned here, but readers are referred to their original URL if they are interested in more detailed information for explaining the behavior of RHD.13 When stored samples of NEXBTL from 2005 were recently analyzed, the texture, the content and the color of NEXBTL were the same as those produced recently. Those samples will be kept and will be tested again in the future to ensure that the formula and the texture of NEXBTL remains the same. The chemical formulas for RHD are very similar to the petroleum diesel. Since there have not been any reports of equipment failures in Europe or elsewhere in tanks containing up to 100% by volume of RHD, it is enough to consider RHD environmentally safe without having an adverse impact on the tanks and on the leak detection equipment. Unlike traditional diesel, RHD, as mentioned in the first part of this document, is almost free of harmful chemicals such as sulfur, CO2, trace metals and a few other substances that are known to have some adverse effect on the leak detection equipment. Because of their similarities to traditional diesel and the lack of harmful chemicals in their formulas any leak detection equipment that is already installed in tanks carrying traditional diesel there is no RHD property based reason to limit RHD content in existing diesel tankage. Generally European regulators permit the use of new products before US regulators permit the use of the same or similar products for consumers to use. Neste Oil has been blending NEXBTL with petroleum diesel in pilot plant quantities since 2005 and in commercial quantities since 2007 at concentrations ranging from a few percent to 100%. In Europe the diesel fuel standard EN590 has a minimum gravity requirement that limits RHD content to the 50% to 60% by volume range. The US standard ASTM D975 does not have a minimum gravity standard which allows diesel fuel containing up to 100% RHD to meet the standard. During distribution, RHD concentration starts at 100% and then is usually diluted with conventional diesel fuel to levels as low as or less than 5%. There has not been any report of equipment failures or damages on the equipment due to corrosion caused by NEXBTL or changes in the chemical formulation of NEXBTL. We have no experience that indicates RHD blends that meet prevailing diesel fuel standards causes problems with existing distribution infrastructure. 13 www.egreenee.com 19 The similarities and the differences of petroleum diesel and NEXBTL were discussed in some details in part one of this document. As previously stated, neither petroleum fuel nor RHD contain oxygen nor have affinity for water. They also have similar chemical formulas.14 Table 2.1: Requirements for fuels and properties of biodiesels (From Table 3 of VTT-R-07049-08_GB) Diesel, summer FAME Data on analysis HVO grade (EN EN14214:2004 of an RME (NEXBTL) 590:2004) Ester content, %vol max 5 min 96.5 >98.7 Boiling point, °C to 360 Density / 15°C, kg/l Viscosity @ 40 °C, mm2/s 0.820-0.845 2.0-4.5 Cloud point, °C Max -5 0.860-0.900 3.50-5.00 Pour point, °C 347 250to 310 0.8835 4.5 0.7780 2.9 to 3.5 0 -5 to -30 -13 CFPP, °C Max -15 Flash point, °C >55 min. 120 >178 >60 Residue of combustion, %wt <0.30 max. 0,30 <0.1 <0.30 Ash, %wt <0.01 max. 0.02 <0.01 <0.001 Sulphur, mg/kg <50 max. 10,0 <1 0 Cetane number >51 min. 51.0 <51 84 to 99 Thermal value, gross, MJ/kg 44 40.54 44 Copper corrosion class 1 class 1 1 Water content, mg/kg max 200 max. 500 250 max 24 7 Oxidation resistance, 110oC, h min. 6 >6.3 Phosphorous, mg/kg max. 10.0 0.5 Acid value, mg KOH/g max 0,50 Iodine value max. 120 Contaminants, mg/kg Oxidation resistance, g/m3 14 max 25 <113 DynamicFuelsfaq.html 20 Acid number TAN, mg KOH/g max. 0.50 0.17 Free glycerol, %wt max. 0.02 <0.004 Glycerol, %wt max. 0.25 0.18 Monoglycerides, %wt max. 0.80 <0.01 Diglycerides, %wt max. 0.20 0.16 Triglycerides, %wt max. 0.20 0.07 Methanol, %wt max. 0.20 <0.01 Na+K, mg/kg max. 5.0 <2.6 Ca+Mg, mg/kg max. 5.0 <0.5 Linolenic acid ME max 12.0 <9.5 >4 double bonds max. 1 <1 Table 2.1 above represents some of the chemical makeup of diesel, FAME and NEXBTL. As reported in table 2.1 the presence of harmful substances to tank equipments and environment are smaller in NEXBTL than they are in diesel or FAME. Also, as noted above, NEXBTL is almost free of sulfur and its gross thermal value is higher in comparison15. Below is a phrase from a White Paper prepared by California Environmental Protection Agency on renewable diesel16: “Staff also recognizes that new innovative hydrocarbon-based diesel fuel substitutes, like renewable and synthetic diesels, are also available in the market and could be addressed in this rulemaking. However, the physical properties of renewable and synthetic diesels meet all applicable petroleum diesel fuel quality requirements under 13 CCR 2281-2285. Therefore, the staff believes that it would be appropriate to allow the use of compliant hydrocarbon-based renewable diesel and synthetic diesels either as neat fuels, or as blend-stocks in the production of conventional petroleum CARB diesel fuel under 13 CCR 2281-2285. The CARB biodiesel/renewable diesel study showed that renewable and synthetic diesels have comparable or better emission characteristics as compared to conventional petroleum-based CARB diesel.” Paragraph 2 and 3 below are also from the State of California Environmental Protection Agency: “2. Underground Storage Tank Material Compatibility and Leak Detection California statutes require that the underground storage tank systems be compatible with the substance stored, and the leak detection equipment be able to function appropriately with the substance stored. The multimedia 15 16 VTT-R-07049-08_GB RenewableDieselStaffReport_Nov2013 21 evaluation indicates that renewable diesel is chemically comparable to CARB diesel. Therefore, differences in compatibility and leak detection are not anticipated. 3. Biodegradability and Fate and Transport UC Davis and UC Berkeley researchers provided data on the impacts of fate and transport properties of renewable diesel compared to CARB diesel. Fate and transport, as well as biodegradability, are not expected to be significantly different given the similar chemical composition of renewable diesel and CARB diesel”. Table 2.2 below is also from California Environmental Protection Agency (CEPA) comparing the European ultra-low sulfur diesel fuel with NEXBTL (Table 4.2 of CEPA) Table 2.2 (from table 4.2 16): Comparative fuel properties for conventional low-sulfur diesel and a HRDF (NEXBTL) (Rothe, et al., unpublished document). Units EN590* NEXBTL Fuel Property Density @ 15°C Viscosity @ 40°C Sulfur Content kg/m3 833 783 mm2s-1 mg/kg 2.35 3.4 6 <1 1.86 2.1 CHx IBP** °C 171 216 FBP*** °C 364 321 %vol 24.9 <0.02 49.7 97.9 Total Aromatics Cetane Index *European ultra-low sulfur diesel fuel **Initial boiling point ***Final boiling point Table 2.2 shows that NEXBTL has lower sulfur than European ultra-low diesel fuel. Below are some quotes from the State of California Environmental Protection Agency that explain in detail the chemical composition of NEXBTL.17 “The chemical composition of the resulting pure R100 is a combination of straight and branched chain paraffins or alkanes. Neste has determined the chemical speciation of the pure R100 using gas chromatography and mass spectrographic analysis”. 17 RenewableDieselStaffReport_Nov2013 22 The carbon numbers range from C10 to C20 and the boiling point range are from 120°C to 320°C. These values are within the range of conventional diesel. Other analyses indicate Neste’s NEXBTL consists of n- and iso-parrafins (Rantanen, et al, 2005) and contains very low amounts of poly- aromatic hydrocarbons, oxygenated compounds and sulfur. In 2005, VTT Processes in Finland conducted physical properties characterization tests on Neste’s fuel (Rothe, et al., unpublished document). The fuel was produced from vegetable oils (canola/rapeseed or palm oil). Table 2.2 summarizes the reported fuel properties of R100 fuel produced by Neste, NEXBTL. The NEXBTL fuel was found to be similar to the European Union’s EN590 and Sweden’s EC1 ULSD equivalent fuels. EN590 does not have an aromatics requirement but Sweden’s EC1 has a maximum limit of 5% aromatics. Neste Oil Corporation has also conducted a life-cycle assessment of the energy and greenhouse gas balance of its R100 NEXBTL fuel (Gartner, et al., 2006). This assessment was conducted using an approach consistent with the ISO 14040-43 standard. During this analysis, the consumption of nonrenewable energy sources (i.e., non-renewable fossil fuels, natural gas, coal, etc.) and the production of greenhouse gases (i.e., carbon dioxide, methane, nitrous oxide) were considered. The feed-stocks considered were rapeseed (canola) and palm oil. “For all comparisons, scenarios and sensitivity analyses considered, the assessment found that use of NEXBTL R100 saves primary energy and greenhouse gas emissions over its entire life-cycle when compared to conventional fossil diesel fuel. The biggest variation in the results was associated with impacts from the production, transportation, and extraction of the crude plant oils used to make the R100. The rapeseed energy savings ranged from 30 to 33 giga-joule (GJ) primary energy per ton of NEXBTL. The rapeseed greenhouse gas savings ranged from 1.2 – 2.5 tons of CO2-equivalents per ton of NEXBTL.” Material Compatibility and Storage Stability for NEXBTL is copied from California Environmental Protection Agency (CEPA) “5.1. Material Compatibility and Storage Stability In general, the handling and storage of renewable diesel that meets ASTM D 975 standards is the same as for petroleum diesel including the needed protection from ignition sources. Tanks used for transport and storage must be suitable for combustible liquids and precautions must be taken to prevent product spills on to the ground, into drains, and into surface and ground waters. In the evaluation of the multimedia impacts of new diesel formulations, materials compatibility and storage stability are important considerations, but little information is available on pure renewable diesel materials compatibility. 5.2. Distribution and Blending of Renewable Diesel Blended HDRD can be transported via the same methods used for conventional diesel, including pipelines, rail cars, tank trucks and drums. The choice of transport vessel depends on the quantity of 23 renewable diesel being transferred and the cold flow properties of the fuel. R100 may be blended with conventional diesel at any volume having a blended product that contains R10 to R100 by volume. Tables 2.3-2.5 and the text below are copied from “National Renewable Energy Laboratory (NREL)18. “The NOx reduction is attributed to the higher EGR rate, due to the resulting increase in combustion temperature. The reduction in CO is attributed to the higher cetane value of the N 100 as this fuel has a shorter ignition delay time and thus less premixed combustion will occur, particularly at low load conditions as were applied during this test. Table 2.3 (from table 6 of NREL): N100 Fuel Property Data Percent ULSD N100 Change EGR rate NOx (ppm) CO (ppm) THC (ppm) Throttle (%) 0.26 251.83 67.44 8.79 27.63 0.27 215.83 58.96 9.85 28.70 2.5% -14.3% -12.6% 12.1% 3.9% Below are some fuel analysis and fuel testing as reported by NREL. “Fuel Properties Fuel properties covering the D975 specification for diesel fuels along with several other properties were determined for the N100 sample; the results of these tests are listed in Table 7. The Neste renewable diesel fuel met the requirements for No. 2 diesel in ASTM D975. The fuel also shows excellent thermal and oxidative stability, and is essentially 100% renewable carbon. The mass-basis net heating value was measured at 3.8% higher than that of the ULSD; however the volume-basis heating value was measured at 3.3% lower due to the relatively low density of the fuel. In addition to ASTM specification properties the fuel was tested for anticorrosion properties by N A C E TM 0172. This test is a pipelining requirement with a minimum rating of B +. The Neste renewable diesel was found to have a NA C E rating of E, the lowest rating, and would therefore require an anticorrosion additive to meet pipelining specifications.” 18 Doc 7 NRELT_2estSummaryReportFeb2012 24 Table 2.4 (table 7 from NREL): For N100 Fuel Property Data from NREL ASTM Test Method Property Derived Cetane Number Cetane Number Copper Strip Corrosion Aromatics Olefins Saturates Cloud Point Cloud Point LTFT CFPP Sulfur Water and Sediment Water Water Saturation Kinematic Viscosity Ash Carbon Residue Lubricity: Wear Scar Diameter Distillation (T-90) Flash Point Conductivity Heating Value (Net) Heating Value (Net) Density Carbon Hydrogen Oxygen Biobased Carbon Content Accelerated Stability Thermal Stability D6890 D613 D130 D1319 D1319 D1319 D2500 D5773 D4539 D6371 D5453 D2709 D6304 D6304 D445 (40°C) D482 D524_10% D6079 D86 D93 D4308 D240 D240 D4052 (15°C) D5291 D5291 FNAA D6866 D2274 D6468 (180 minutes) TM0172 D664 D7371 NACE Corrosion Acid Value FAME Content * Limits for No. 2 S15 diesel fuel § Units N100 ---% % % °C °C °C °C ppm vol% ppm ppm cSt wt% wt% 74 -1A <0.1 0.6 99.4 -27 -24.8 -24 -25 1.1 0.01 15 50 2.5 <0.001 0.04 -42.5 -33 1.6 65.4 -24 ---8 ---2.4 -0.07 ASTM D975 Limit* 40 min 40 min 3 max 35 max --Report Report --15 max 0.05 max --1.9 – 4.1 0.01 max 0.35 max µm 425 612 520 max °C °C pS/m btu/lb btu/gallon g/mL % % % % mg/100mL 287 65 113 19,108 123,604 0.7751 84.6 15.19 <0.01 100 0.2 300 76 106 18,413 127,840 0.8508 87.01 12.99 ---- 282 - 338 52 min 25 min --------- % Reflectance 100 -- -- -mg KOH/g % E 0.02 <0.5 ---- --5 max § Properties of the ULSD were supplied by the fuel producer 25 “Elemental analysis was conducted by inductively coupled plasma atomic emission spectrometry following ASTM method D5185. The results of this analysis are listed in Table 8. None of the elements included in this analysis were detected above the limit of detection for the method.” Table 2.5 (table 8 from NREL): N100 Elemental Analysis Data of NREL Element Result (ppm) Al Sb Ba B Ca Cr Cu Fe Pb Mg <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 Element Result (ppm) Element Result (ppm) Mn Mo Ni P Si Ag Na Sn Zn K <1 <1 <1 <1 <1 <1 <5 <1 <1 <5 Sr V Ti Cd S As Be Bi Co W <1 <1 <1 <1 <25 <5 <5 <5 <5 <5 26 B. Leak Detection Equipment Testing RHD is a relatively new fuel with less than 10 years of actual field use. e RHD consists primarily of paraffinic hydrocarbons that are known to be quite stable and have little affinity for water (a major cause of tank corrosion problems) and contains essentially no contaminants that are known to cause tank corrosion. Therefore, there does not appear to have been any direct testing of its compatibility with tanks and leak detection equipment. At this time all the data we have is that there have been no reports of storage problems that have been attributed to RHD. While there is no direct test data available on the effect of renewable hydrogenated diesel on the tanks and leak detection equipment in the tank, there is, however, a vast amount of references supporting the production and the use of RHD. Some of these references have been mentioned in the first part of this paper and they include governmental agencies, non-profitable organizations, universities, etc. Included below is more evidence that the state of California has evaluated and supports the production and the use of RHD19: “Renewable Diesel Multimedia Evaluation “Renewable diesel” is produced from non-petroleum renewable resources and is not a mono-alkyl ester. Renewable diesel consists solely of hydrocarbons and meets ARB motor vehicle fuel specifications under title 13, California Code of Regulations, section 2281 et seq. 2 completed their assessment of the renewable diesel multimedia evaluation and potential impacts on public health and the environment. The evaluation is a relative comparison between renewable diesel and CARB diesel. Based on the results of the multimedia evaluation and the information provided in the UC’s Renewable Diesel Final Tier III Report, the MMWG makes the overall conclusion that renewable diesel specifically evaluated within the scope of the evaluation will not cause a significant adverse impact on public health or the environment. Hard copies of the MMWG Biodiesel Staff Report and Renewable Diesel Staff Report, including the UC Biodiesel Final Tier III Report and Renewable Diesel Final Tier III Report, will be provided. Also, all references cited in each of the staff reports will be provided electronically on a compact disc. In summary RHD contains minimal harmful substances such as sulfur, ash, aromatic, COx and other chemicals and meets all the requirements that are placed on their production, transportation and use by regulatory agencies. These regulatory agencies have included their approval of the production of RHD in their publications. These papers include several publications by ASTM, federal and states governments who set limits on the production and use of various chemicals and fuels. While most of the publications have been scanned by author for preparing this report, not all the publications supporting the use and transportation of RHD are mentioned here. Hard copies of the MMWG Biodiesel Staff Report and Renewable Diesel Staff Report, including the UC Biodiesel Final Tier III Report and Renewable Diesel Final Tier III Report, will be provided. Also, all references cited in each of the staff reports will be provided electronically on a compact disc. 19 RenewableDieselStaffReport_Nov2013 27 Below are some of the findings of NREL: “Overall results show that the Neste renewable diesel was a high quality material which met or exceeded the minimum properties for ASTM D975 specification for diesel fuel oil in its neat form. ULSD blended with Neste showed decreased gravimetric fuel consumption due to the higher gravimetric heating value of N100. The mass-basis net heating value was measured at 3.8% higher than that of the ULSD, but the volume-basis heating value is 3.3% lower due to the low density of the fuel. Emission testing with a 2008 model year U.S. on-highway engine equipped with a DPF showed no effect of N5, N20, or N100 on tailpipe THC, CO, or PM. NOx decreased by 2.6% with N5, 4.0% with N20, and 9.5% with N100. Engine out smoke number showed no significant change for N20 but was reduced by 34.2% with N100. Engine combustion studies showed a decrease in ignition delay compared to ULSD due to the higher cetane value of the N100. At steady state low-load conditions NOx and CO emissions were decreased by 14.3% and 12.6% respectively. Percent throttle was increase by 3.9% due to the lower volumetric energy density which resulted in a 2.5% increase in EGR rate.” NWGLDE has a list of available technologies on their website. The order of the listing and the technology below is in the same order as the listing of NWGLDE. Below each technology is mentioned and its working environment under RHD is investigated. There are many leak detection technologies available in the market for detecting leaks and monitoring the activities in the tank and in the pipeline using different methods and technologies. Venders may choose a particular method such as Volumetric System, Non-Volumetric System, etc. for installation in their tank and monitoring the activities in the tank. In this part of the paper, each technology is reviewed and the impact of RHD like NEXBTL on it is investigated. Leak detection equipment is designed to report leaks from the tanks or the pipelines when some activities is going on in the tank such as delivery or sale and also during the quite times. During the delivery when the temperature of the product in the tank is different from the temperature of the delivery leak detection equipment make adjustment to the volume and correct for the temperature difference. EPA requires that any leaks or an unaccounted loss of product to be reported to the owners/operators of the UST. Below, each leak detection technology is mentioned and the effect of RHD is investigated on them. The order of technologies here follows closely the listing of these technologies in NWGLDE Website and in many cases the information is from the manufacturer’s website20. 20 http://nwglde.org/method_index.html 28 Above Ground Storage Tank Leak Detection Method (AST): There are two technologies listed under AST in NWGLDE, they are: mass based system manufactured by Mass Technology Corporation and Praxair Services, Inc. These build Tracer Tight for Large Aboveground Storage Tank Systems. Mass Technology Corp. builds IM-1000 and CBU-1000 which works with: Gas, diesel, aviation fuel, fuel oil #4. According to manufacturer’s website other liquids may be tested after consultation with them. Since the chemical composition of NEXBTL is similar to diesel without some of the undesirable chemicals, the technology should easily handle RHD. Praxair Services is the manufacturer of Tracer Tight for Large Aboveground Storage Tank Systems which works with gasoline, diesel, aviation fuel, fuel oil #4, waste oil, crude oil. Other fluids which are compatible and soluble with an acceptable tracer chemical may be tested after consultation with the manufacturer. The chemical composition of NEXBTL is similar to paraffins that have been in diesel fuel since it was first distilled from crude oil and are currently being produced in refineries to enhance cold weather properties and lower sulfur content. Therefore unless the tracer chemicals are not soluble in paraffins, this technology should be capable of managing NEXBTL. Should some minimal aromatics content be required to dissolve the tracer chemical the tracer manufacturer should advise the user and perhaps update their technology to make sure it still works with today’s diesel fuels that tend to contain fewer aromatics. Automatic Electronic Line Leak Detector (AELLD): There are at least fifteen manufacturer Automatic Electronic Line Leak Detectors. Many of the manufacturer claim that their detector may be installed in tanks carrying Gasoline, diesel, aviation fuel, fuel oil #4, solvents, waste oil, biodiesel B6-B20 meeting ASTM D7467, biodiesel B100 meeting ASTM D6751*, crude oil, petroleum distillates in liquid form, cooling fluids, and water or water soluble liquids. They indicate other liquids may be tested after consultation with the manufacturer. Other manufacturers claim their detectors may be installed in gasoline tanks and ethanol blends up to E100. With such a big variation in the chemical composition which includes B100 and knowing that most of these fuels contain more harmful chemicals than RHD, the detectors should easily handle RHD. Automatic Mechanical Line Leak Detector (AMLLD): There are at least five manufacturers of Automatic Electronic Line Leak Detectors. Some of the manufacturers claim that their detector may be installed in tanks carrying gasoline, gasoline-alcohol mixtures, aviation fuel, fuel oil #4, solvents, diesel, biodiesel blends B6-B20 meeting ASTM D7467, biodiesel, B100 meeting ASTM D6751*. With such a large range of fuels that AMLLD can handle including B100, AMLLD can cover RHD. 29 Automatic Tank Gauging Method (ATGM): There are more than twenty five manufacturers of ATG. Some of the major manufacturers claim that their detector may be installed in tanks carrying gasoline, diesel, aviation fuel, fuel oil #4. While coefficients of expansions specific to RHD have not been determined, the temperature correction factors currently in use are functions of both the product density and the temperatures. Because ATGM is widely used and tested with various fuels of varying densities, ATGM should cover diesel fuel containing up to 100% of NEXBTL. Bulk Underground Storage Tank Leak Detection Method (50,000 Gallons or Greater), (BUSTLDM): There are about nine manufacturers of BUSTLDM. They use various technologies such as mass balance, ATG or other technology to detect leak in the mostly single large tanks. These systems are used for variety of fuel such as: gasoline, diesel, aviation fuel, fuel oil #4, fuel oil #6 (if is between 60 to 150 degrees F), solvents, waste oil, liquefied petroleum gas, and natural gas. Since BUSTLDM are capable of storing such a varied group of fuels, they are capable of storing and handling diesel fuel containing up to 100% of NEXBTL in a single tank. Continuous In-Tank Leak Detection Method (Continual Reconciliation) (CITLDM): Technologies that use CITLDM are very similar to ATGs, and, therefore, the impact of NEXBTL on them will be the same as those of ATGs. Therefore, the ability of CITLDM is such that it easily can manage NEXBTL fuel up to 100%. Continuous Interstitial Monitoring Method (Liquid Filled) (CIMM): There are about four manufacturers of CIMM. These technologies are applied for testing the leaks on pipes and tanks. These methods should work for RHD containing up to 100% of NEXBTL. The space between the two tank layers ( or the pipe layers) of the tank is continuously monitored and alarm will go off if the level goes down when a leak is developing, or if it goes up meaning that fuel is intruding into the interstitial space. Because RHD consists mainly of iso and normal paraffins and essentially no aromatics and diesel fuel can contain up to 35% aromatics with the balance consisting mainly of iso, normal and cyclo paraffins (C3H6) the liquid that fills interstitial space may need to be tested for compatibility with ultra low sulfur, low aromatics content fuels. If the leak goes into the product a high sulfur content of low flash point interstitial fluid can cause both ULSD and RHD to go off specification. If the leak goes from the tank to the interstitial fluid the relatively low toxicity of the paraffinic RHD should be less of a problem than a ULSD leak containing aromatics. 30 Continuous Interstitial Line Monitoring Method (Pressure/Vacuum) (CILMM): There are not very many manufacturers of these systems and since these system use pressurized nitrogen gas to continuously maintain a pressure in the interstitial space of the pipelines, they should be accepted and used for pipelines carrying NEXBTL up to N100. Continuous Interstitial Tank System Monitoring Method (Pressure/Vacuum), (CITSMM): There are about eight manufacturer of CITSMM. These systems use an integral vacuum pump to continuously maintain a partial vacuum within the interstitial space of double-walled tanks and doublewalled piping. Since these systems are double-walled and they are under vacuum/pressure they should be able to manage RHD up to 100%. Continuous Pressurized Piping Leak Detection Method (Continuous Electronic Line Leak Detection) (CPPLDM): There is only one manufacture building CPPLDM. This system only reports passes or fails and its use are not wide spread. According to it manufacturer the system is capable of storing Gasoline, diesel, aviation fuel, biodiesel B6-B20 meeting ASTM D7467, biodiesel B100 meeting ASTM D6751. Since the system operates on pressure and NEXBTL follows the Pascal’s laws, it can handle up to 100% RHD. Interstitial Detector (Liquid-Phase) ID: The installation of Interstitial Detector is wide spread and more than twenty five manufacturers build this device and some are slightly different from the others with different liquid filled in the interstitial space. The alarm is activated when the product gets into the interstitial space. The manufacturer of Interstitial Space claims that Biodiesel blends B6-B20 meeting ASTM D7467 and biodiesel B100 meeting ASTM D6751 would also produce an alarm if the sensor threshold is exceeded. The alarm is also activated when gasoline, diesel or water entering in the interstitial space. With the approval of the manufacturers those same detectors that work with B100 can work with RHD up to N100. Interstitial Tank Tightness Test Method (ITTTM): There are three manufacturers of these ITTTM systems. Their technologies are based on either vacuum or liquid to fill the interstitial space. According to their manufacturers these systems are capable of handling gasoline, diesel, aviation fuel, fuel oil #4, motor oil, biodiesel blends B6-B20 meeting ASTM D7467, biodiesel B100 meeting ASTM D6751. Since these technologies don’t come in contact with the product in the tank and they are approved for B100, they are capable of managing RHD up to N100. 31 Large Diameter Line Leak Detection Method (6 Inches Diameter or Higher) (LDLLDM): There are about ten producers of these systems. According to their websites there are two distinct methods for detecting leaks. One is based on either pressure or vacuum; these systems should work with RHD. The other method is the “tracer”, or addition of special kind of chemical to the product in the pipeline. If the added tracer doesn’t dissolve in paraffins, then the tracer method will not work for neat RHD. If the tracer is dissolvable in traditional diesel fuel because traditional diesel fuel contains aromatics then, given the trend to lower aromatics content in cleaner burning diesel fuels, the tracer manufacturer should determine the minimum aromatics content at which the tracer dissolves and establish application guidance concerning the use of the tracer technology when paraffinic distillate fuels like RHD and Fischer-Tropsch fuels are present. Assuming the tracer works in cleaner burning diesel fuels like CARB ULSD and TxLED that encourage the use of diesel fuels containing less than 10% aromatics equivalent performance and that typical diesel fuel contains between 20 and 25% aromatics. Pipelines that rely on “tracer” that is not dissolvable in NEXBTL, can still manage blends of up to N50 or N60 of RHD. If the tracer chemical is soluble in paraffins the method should work for neat RHD. Line Tightness Test Methods (LTTM): There are about fifteen manufacturer of LTTM. The tightness of some these systems are tested by putting the pipeline under pressure. These systems should be acceptable for RHD. The other method for testing LTTM is by adding “tracers” in the pipeline. If the added tracer doesn’t dissolve in RDH, then the tracer method will not work for neat RHD. If the tracer is soluble in traditional diesel fuel because traditional diesel fuel contains aromatics then, given the trend to lower aromatics content in cleaner burning diesel fuels, the tracer manufacturer should determine the minimum aromatics content at which the tracer dissolves and establish application guidance concerning the use of the tracer technology when paraffinic distillate fuels like RHD and Fischer-Tropsch fuels are present. Assuming the tracer works in cleaner burning diesel fuels like CARB ULSD and TxLED that encourage the use of diesel fuels containing less than 10% aromatics equivalent performance and that typical diesel fuel contains between 20 and 25% aromatics. Pipelines that rely on “tracer” that is not dissolvable in NEXBTL, can still manage blends of up to N50 or N60 of RHD. If the tracer is soluble in paraffins the method should work for neat RHD Non-Volumetric Tank Tightness Test Method (Tracer) (NVTTTMT): There are three manufacturers of NVTTTMT. These are non-volumetric methods. Chemical tracers are added to the tank to check and see if the residue of the tracers is found in the ground around the tank. If the tracer used is not dissolvable in RHD, then the tracer method will not work for neat RHD. 32 If the tracer is soluble in traditional diesel fuel because traditional diesel fuel contains aromatics then, given the trend to lower aromatics content in cleaner burning diesel fuels, the tracer manufacturer should determine the minimum aromatics content at which the tracer dissolves and establish application guidance concerning the use of the tracer technology when paraffinic distillate fuels like RHD and Fischer-Tropsch fuels are present. Assuming the tracer works in cleaner burning diesel fuels like CARB ULSD and TxLED that encourage the use of diesel fuels containing less than 10% aromatics equivalent performance and that typical diesel fuel contains between 20 and 25% aromatics. Tanks that rely on “tracer” that is not soluble in NEXBTL, can still manage blends of up to N50 or N60 of RHD. If the tracer is soluble in paraffins, there does not appear to be a reason it would not work with neat RHD. Non-Volumetric Tank Tightness Test Method (Ullage) (NVTTTMU): There are seven manufacturers of NVTTTMU. These systems work on either pressure or vacuum in the ullage part of the tank and, therefore, the system is not in contact with the product in the tank. Since the RHD doesn’t come in contact with the product and methods works with several different petroleum products, it should handle RHD. Non-Volumetric Tank Tightness Test Method (Vacuum) (NVTTTMV): There are six manufacturers of NVTTTMV. These systems do not come in contact with the product and, therefore, they work with any kind of product including RHD. Out-Of-Tank Product Detector (Liquid-Phase) (OOTPDLP): There are seventeen manufacturers of OOTPDLP. As the name suggests these detectors are placed out of the tank and detect hydrocarbons and the presence of a wide range of petroleum fuels, e.g. gasoline, diesel, jet fuel, etc. In some cases the detector which is a special kind of wire may be reused after detecting petroleum fuel and hydrocarbons. If the detector is only sensitive to aromatic hydrocarbons RHD blends in the 50 to 60% range should be acceptable as long as the system works for cleaner burning diesel fuels like CARB ULSD and TxLED. As long as the detector is sensitive to hydrocarbons it should work for neat RHD. Out-Of-Tank Product Detector (Vapor-Phase) (OOTPDVP): There are sixteen manufacturers of OOTPDVP. These detectors are usually placed (in a well) near a tank to detect hydrocarbons. They generally work with fuels that have a high partial evaporation and are volatile. That is because the molecules quickly change from liquid to vapor and move about and reach the detector very quickly. Those fuels that are relatively more stable compared to alcohol and gasoline such as kerosene, diesel, and RHD are not suitable for these detectors. 33 Statistical Inventory Reconciliation Test Method (Qualitative) (SIRTMQ): There are not many vendors performing SIRTMQ on the customer’s tanks. SIRTMQ method reports pass or fail only. Probes and sometimes sticks are used to measure the product level. The probes should be fine for most hydrocarbon products and should work for neat RHD. A possible exception to this conclusion can occur when the probes rely on the presence of aromatics or some other contaminant to function. Probes makers should be contacted to see if probes are compatible with today’s cleaner diesel fuels and paraffinic fuels like RHD and Fischer-Tropsch fuels. Statistical Inventory Reconciliation Test Method (Quantitative) (SIRTMQ): There are about fifteen vendors selling SIR/Quantitative. Some vendors manufacture their own probes. Assuming the probes work for hydrocarbons the SIR/Quantitative method should be fine for RHD. Should the probes rely upon the presence of aromatics or some other contaminant to function the probe makers should be contacted to see if their probes are compatible with today’s cleaner burning diesel fuels and paraffinic fuels like RHD and Fischer-Tropsch fuels. Volumetric Tank Tightness Test Method (Overfill), (VTTTMO): There are about eight companies involved in VTTTMO. Their method is volumetric and tests the filled portion of the tank for leak. Assuming these methods are valid for hydrocarbons the methods should be accepted for RHD. Volumetric Tank Tightness Test Method (Underfill), (VTTTMU): There are about nine companies involved in VTTTMU. Some measure the mass instead of volume. They generally test the filled portion of the tank. Assuming these methods are valid for hydrocarbons they should be acceptable for RHD. 34 Concluding Remarks: The second part of this report investigates the impact of the RHD on tanks and the special equipment placed inside or outside of a tank. Most leak detection methods are conducive to renewable hydrocarbon diesel. For a few that are not the manufacturer of the product should be consulted. They may have a recommendation or even a substitute for that particular method that works with RHD. Since RHD is stable, has a low affinity for water and is essentially free of water, oxygen, alcohol and other contaminants known to cause corrosion, there is no technical reason that neat RHD cannot be stored in or dispensed from underground storage tanks or above ground storage tanks that are suitable for use with diesel fuel. While no direct test data has been found that indicates that RHD is or is not compatible with leak detection equipment, pipelines and storage tanks RHD has been distributed commercially since 2007 in concentrations ranging from less than 5% to up to 100% and no leaks or equipment failures have been attributed to its presence. Also, there is a vast amount of references supporting the production and the use of RHD. Some of these references have been mentioned in the first part of this paper and they include governmental agencies, non-profitable organizations, universities, etc. For example: California’s multimedia evaluation indicates that renewable diesel is chemically comparable to CARB diesel. Therefore, differences in compatibility and leak detection are not anticipated. While we would like to see some gravity-temperature correction factors that are specific to RHD, the typical gravity-temperature correction factors that are a function of the gravity of the fuel being measured and the temperature difference are probably adequate. One possible soft spot may be leak detection equipment or procedures that rely upon chemical tracers that that have to be dissolved in the diesel fuel. Leak detection vendors that rely on chemical tracers should verify that their tracers are soluble in paraffins and continue to work as aromatics content of diesel fuel is reduced to make it burn more cleanly. Because RHD is diesel fuel that emits very few volatile vapors relative to gasoline or alcohol, vapor emissions sensors that do not work with diesel fuel will not work with RHD either While my research has not found any technical reasons as to why RHD is not compatible with the existing leak detection and fuel transport and containment facilities it would still be prudent to be extra vigilant when handling diesel fuels containing high concentrations of RHD simply because it is still a relatively new fuel. 35 References Below are some related URLs. A few have been mentioned in the text and others although not mentioned in the text contain useful information: http://www.nwglde.org/method_index.html http://www.veeder.com/us/fuel-leak-detection/mechanical-line-leak-detection/fxv-mechanical-lineleak-detector Mass measurement EPA http://www.epa.gov/esd/chemistry/ice/ac1.htm http://www.arb.ca.gov/fuels/multimedia/meetings/RenewableDieselStaffReport_Nov2013.pdf http://www.arb.ca.gov/fuels/multimedia/meetings/BiodieselStaffReport_Nov2013.pdf http://www.egreenee.com/wp-content/uploads/2013/09/Doc-7NRELTestSummaryReportFeb2012they-belong-to-FED.pdf http://www.arb.ca.gov/fuels/diesel/altdiesel/20130212adfregconcept.pdf http://www.vtt.fi/inf/julkaisut/muut/2008/VTT-R-07049-08_GB.pdf http://www.equipmentworld.com/ Under the heading “ADVANCED ALTERNATIVE AND RENEWABLE DIESEL FUELS” there are a few good references. http://www.nrel.gov/docs/fy06osti/38834.pdf http://www.chevronwithtechron.ca/products/documents/Diesel_Fuel_Tech_Review.pdf 36