# A Comprehensive Analysis of

Current R esearch on E15

Dispensing Component Compatibility

March 201 2

Larry Gregory Consulting, LLC Snoqualmie, WA larry.r.gregory@gmail.com

## Table of Contents

Executive Summary 1

Project Scope of Work 3

Summary of Papers

1. ORNL Elast om ers, Metals and Sealants 4

2. NREL Dispensing Equipment Testing 7

3. GAO Challenges to the Use of Ethanol Blends 9

4. Ken Wilcox Stage I and Overfill Component s Testing 12

5. NREL Headspace Flammability Tests 2008 14

6. NREL Headspace Flammability Tests 2010 17

7. NREL Headspace Flammability Tests 2011 19

8. SwRI Flame Arrester Literature Review 20

9. USEPA Notice of Guidance on E

- 15 Compatibility 21

10. ORNL January 5, 2012 Webinar Presentation 23

Conclusion 2 5

Risk and Mitigation Summary 2 6

Appendices 30Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 1



## Executive Summary

Several r esearch p apers have been published on the effects of increasing the ethanol b l end ratio to E15
from the current E10 standard. The following information can be concluded from this research :

The Oak R idge National Laboratory (ORNL) issued a report on elastomers, metals and sealants that was designed to p rovide guidance and identify potential issues to service station equipment designers

. They found very little corrosion of metals while all elastomers ( i.e., gaskets, seals

, o

- rings, etc.) swelled and most lost important qualities which can result in leaks

. They concluded that s ome elas tomers are not suitable for E15, while others require expert design to function well. Thread sealant designed for higher
blends of ethanol work well while p ipe joints with o lder thread sealant leaked with E15. The
informat ion presented by ORNL may be useful to service station equipment designers.

The National Renewable Energy Laboratory (NREL) and Underwriters Laboratories (UL) test ed a number of samples of used and new service station equipment. All the equipment was listed for E10 but was tested with E17a, an aggressive laboratory test fluid, after soaking the equipment in the test fluid at a high temperature (140°F) for 105 days

. They found that 70% of the in

- use equipment and 40% of the new equipment failed compati bility tests. Their conclusion was that “no clear trend s in the overall performance of all equipment could be established

. ” However, the results from these tests are far from
inconclusive ; the se tests found a reduced level of safety from using equipment certified for E10.

The U

. S

. Government Accountability Office (GAO) reported on challenges related to E15 implementation. They noted that U.S. O ccupational S afety and H ealth A dministration (OSHA) regulations require all service station components from th e dispenser nozzle to the submersible turbine pump (STP) to be listed by a nationally

- recognized testing laboratory (NRTL)

. Despite this , “the vast majority of existing retail dispensers in the United States are not approved for use with intermediate ethanol blends under OSHA’s safety regulations

. ” 1 GAO was also concerned that many service stations
lacked the records required to verify compatibility with E15 as well as the limited amount of research
that has bee n conducted so far. Service station owners face challenges from using existing equipment
to sell E15 because, “ongoing federal research indicates potential problems with the use of intermediate
ethanol blends with some UST components. ” 2 These challenges include costs of equipment upgrades, logistical limitations on the types of fuel a retailer may be able to sell, and legal uncertainty about whether existing dispensing equipment can be lawfully used with intermediate ethanol blends.

Ken Wilcox Associa tes tested S tage I vapor recovery and overfill protection components in both E10 and

E17 a fuel samples. He found that fill swivel adapter s failed to pass UL tests after exposure to E17a

. One
overfill valve failed the E17 a tests, while all other equipment that included ball float valves, spill bucket drains and pipe caps passed all tests. Wilcox also noted that many of the gaskets between the devices and pipes they are mounted to failed after 30 days exposure to the test fuels.

NRE L and the Nexum Research Corp oration did three rounds of testing between 2008 and 2011 to determine the flammability of the headspace ( i.e., the area above the liquid) inside of underground storage tanks with various combinations of gasoline and ethanol. They found that there was little flammability difference between E10 and E20

- E30. They also found that storage of E85 and neat or fuel

1 GAO Report, p. 23.

2 Ibid ., p. 26.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 2

grade ethanol (E98

– E100) c ould have flammable headspace vapors during normal operating
temperatures.

The Southwest Res earch Institute (SwRI) conducted a literature search for the American Petroleum Institute ( API ) to determine if flame arresters or pressure/vacuum valves are useful with gasoline

ethanol blends. They found only one European recommendation for flame arrest ers when storing E30 or higher. They noted that properly designed flame arresters on tank openings would only add to overall safety , and that f ailure to use compatible materials may result in leaks and an increased risk of
fires.

The U

. S

. E nvironmental P rotection A gency (EPA) issued official guidance on how service station owners can determine and document equipment compatibility with E15. Owners can choose to follow the recommendations of API 1626 (2010) or:

 Use components that are certified or listed b y a nationally recognized independent test laboratory for use with the fuel stored.

 Use components approved by the manufacturer to be compatible with the fuel stored. EPA considers acceptable forms of manufacturer approvals to:

o Be in writing;

o Indicate an affirmative statement of compatibility ;

o Specify the range of biofuel blends the component is compatible with; and

o Be from the equipment manufacturer, not another entity (such as the installer or distributor;

 Use another method determined by the implementing agency to sufficiently protect human
health and the environment. The only alternative to these methods is to not store or sell E15 at sites with incompatible equipment.

In a January 2012 webinar, ORNL issued preliminary results on their study on plastics in mid

- level
ethanol blends. Subsequently a March 2012 draft report provided more detailed information on plastic compatibility but makes no specific product recommendations. The final report will be available in a
few months.



## Con clusion

Re tailers choosing to sell E15 are required by OSHA and fire codes 3 to use listed equipment, and EPA
rules require that equipment be proven compatible with E15. The result is that very few sites will be
able to sell E15 fuel with existing equipment. Equi pment modifications could be as little as new hanging hardware ( i.e., hose, nozzle, etc.) or as much as an entire ly new fuel dispensing system.

Additionally, s elling E15 may increase the risk for staff and customer safety, and present environmental

conse quences

. The possibility of customer misfueling and the adverse effects of E15 on vehicle engines
are also issues that should be considered. The only alternative is to not store E15 at the facility.

3 See Appendix 1

– E10+ and Biodiesel Compatibility Matrix

.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 3



## Project Scope

Complete a report summarizing the research results completed to date on the effects of storing and dispensing E15. The research completed so far has focused on individual components comprising the retail storage and dispensing system. It is necessary to draw a complete picture based on t he results of the current research in order for owners and operators of retail fuel dispensing facili ties to make informed judgments regarding whether to store and dispense E15 at their facilities.

Requirements:

1. Complete a report summarizing the research results completed to date on the effects of storing and dispensing E15 with the existing retail fuel distribution infrastructure.

2. Complete an analysis of the result s that determine what risks, if any, exist for fuel dispensing facility owners and operators wishing to store and dispense E15 using their existing fuel
distribution infrastructure. These risk s must address safety risks to consumers and fuel dispensing facility work er s as well as environmental risks.

3. Identify possible mitigation measures to addre ss those risks.

Existing research that will be analyzed and summarized includes:

1. Intermediate Ethanol Blends Infrastructure Materials Compatibility Study: Elastomers, Metals,
and Sealants (ORNL 2011)

. < www.pei.org/frg/ornl.pdf >.
2. Dispensing Equipment Testing with Mid

- Level Ethanol/Gasoline Test Fluid (NREL 2010)

.
< www.nrel.gov/docs/fy11osti/49187.pdf >.
3. Biofuels: Challenges to the Transportation, Sa le, and Use of Intermediate Ethanol Blends (GAO June 2011)

. < www.gao.gov/products/GAO

- 11

- 513 >.
4. Testing the Functionality of Stage I Vapor Recovery and Overfill Prevention Components (API September 2011)

. 5. Experimental and Modeling Study of the Flammability of Fuel Tank Headspace Vapors from High
Ethanol Content Fuels (NREL 2008)

. < www.nrel.gov/docs/fy09osti/44040.pdf >.
6. Experimental and Modeling Stud y of the Flammability of Fuel Tank Headspace Vapors from Ethanol/Gasoline Fuels, Phase 2: Evaluations of Field Samples and Laboratory Blends (NREL 2010)

. < www.nrel.gov/docs/fy11osti/52043 >.
7. Experimental and Modeling Study of the Flammability of Fuel Tank Headspace Vapors from Ethanol/Gasoline Fuels; Phase 3: Effects of Winter Gasoline Volatility and Ethanol Content on Blend Flammability; Flammability Limits of Denatured Ethanol (NREL July 2011)

.
< www.nrel.gov/docs/fy11osti/52043.pdf >.
8. Literature Review of the Usefulness and Efficacy of Flame Arresters and Pressure/Vacuum Valves

with Gasoline

- Ethanol blends (API 2010)

9. Guidance On Compatibility of US T Systems With Ethanol Blends Greater Than 10 percent and Biodiesel Blends Greater Than 20 percent (76 FR 39095, July 2011)

.
< www.gpo.gov/fdsys/pkg/FR

- 2011

- 07

- 05/pdf/2011

- 16738.pdf >.
10. Compatibility of Fueling Infrastructure Materials in Ethanol Blended Fuels. ( Webinar: ORNL January 2012 ; Draft Report: March 2012. ).Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 4



# Summary of Research

1. Intermediate Ethanol Blends Infrastructure Materials Compatibility Study: Elastomers, Metals a nd Sealants (ORNL 2011)

Background

ORNL was contracted by the U

. S

. Department of Energy to evaluate the impact of intermediate blends of ethanol and gasoline on metals, elastomers, plastics and sealants. This study used four different fuels
based on ASTM specifications: Fuel C, CE10a, CE17a and CE25 a

. Fuel C was representative of hig h ly aromatic gasoline. The others are blends of Fuel C with an aggressive ethanol. Accordingly

, Fuel CE10a
is 90% Fuel C and 10% aggressive ethanol. Ethanol is made a ggressive with the addition of water

, sodium chloride (salt), dilute acetic and sulfuric acids . All of these chemicals are within the bounds
allowable for fuel

- grade ethanol

.

Metals investigated were 1020 carbon steel, 304 stainless steel, 1100 aluminum, nickel 201, cartridge brass, phosphor bronze and terne

- plated steel. Corrosion was measured by weight loss. Additionally specimens of steel, brass and aluminum were coupled with lead, zinc, chromium and nickel to create galvanic corrosion conditions.

E lastomers classes included fluorocarbon, fluorosilicone, silicone, acrylonitrile butadiene rubber (NBR), styrene butadiene rubber (SBR), polyurethane and neoprene.

Two pipe thread sealants were evaluated in some of the fuel samples as part of the tests. One sealant has been used historically. The other was specifically designed for use with E10 and E85.



## Metal Results

Very little corrosion was found on any sample in any of the fuel types. While some slight discoloration was reported, n o corrosion was found on any sample exposed in the vapor regions of the test chambers. None of the plated specimens showed accelerated corrosion due to galvanic coupling between the
material and substrate.

1020 mild steel, 1100 aluminum, 201 nickel, and 304 stainless were found to be essentially immune to

corrosion. Accordingly, the se materials are suitable for use with intermediate ethanol blends used in this study. Cartridge brass, phosphor bronze, zinc

- plated (galvanized) steel and lead

- plated (terne) steel had some discoloration and minor corrosion film formation. They were considered to have a low rate of
corrosion in these test fuels. Additionally

, they found that there was no trend in the corrosion rate of
materials as a function of the ethanol concentration in the fuel. None of the plated materials coupons exhibited any discoloration or measurable corrosion or any accelerated corrosion from galvanic coupling
between th e plating material and substrate.



## Elastomer Results
Elastomers are used to seal equipment components so that they do not leak. Elastomers are also part of
flexible hose.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 5

All of the elastomers exhibit some level of volume swell that could lead to poss ible problems with some seal designs . Ethanol was found to further increase the amount of swell and produced softening. CE10a

or CE17 a produced more swell than Fuel C or CE25a. This suggests that the highest level of solubility for
elastomers occurs at a relatively low concentration of ethanol.

Fluoroelastomers (fluorocarbons and fluorosilicone) had the best retention of properties with volume
swell under 20%

.

Silicone rubber had volume swell over 120% bu t did not suffer any structural degradation from exposure to test fluids.

NBR and polyurethane showed pronounced increase in volume swell and softening. These two types of
elastomers were also the only samples showing embrittlement when dried. This indicates that plasticizer components were being rem oved by the test fuels. Polyurethane may not be useful in any sealing applications for fuel containing up to 25% ethanol.

The SBR sample had the highest combination of swell and softening . Nevertheless, appropriate formulations of the material may be su itable to meet some sealing specifications for fuel grade ethanol.

Neoprene had similar performance to NBRs. Exposure to fuel left the sample in a less durable condition.

Vapor

- only exposure to the test fluids exhibited similar results to those found with the wetted specimens.



## Sealant Results

Standard thread sealant did not pass exposure to either CE10a or CE25a. Combining Teflon tape with this standard sealant prevented leaks from occurring. The report failed to note that many manufacturers warn installers to never use Teflon tape in fuel system installations.

The ethanol

- resistant sealant prevented leakage in the CE10a and CE25 a fuels

.



## O ther

Appendix A of the report investigated the faceplate rubber cork seals that had been found leaking in the earlier UL/NREL testing. They found indications that the elastomer component of the seals was
effective ly dissolved by the test fue l and resulted in the leakage observed. The elastomer component is necessary for seal strength and elasticity. The selection of a proper rubber component for these seals is necessary to prevent leaks from exposure to ethanol blends.



## Additional Comments

Copper was not included in the test metals. Copper was used in the past in a significant number of dispensers. Internationally, some underground product piping is also copper.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 6

The information presented on materials may be useful to service station equ ipment designers . Owners or operators will have to rely on the methods identified by EPA and / or API 1626 (2 nd edition) to determine equipment compatibility.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 7



## 2. Dispensing Equipment Testing with Mid

- Level Ethanol/Gasoline

Test F luid (NREL 2010 )

Background

This report documents work done by Underwriters Laboratory ( UL ) and the National Renewable Energy Laboratory (NREL) to better understand any potentially adverse impacts from dispensing fuel with higher levels of ethanol than what the equipment was designed to dispense.

The project tested new and used equipment that was UL listed for E10 using the UL 87A standard for testing equipment for dispensing fuel with an ethanol content of up to 85%. The only change was the
use of CE17a test fluid. 4 The primary goal of the work was to identify leaks and assess other safety

re lated performance requirements. Work was conducted at a UL laboratory.

The overall assessment of the results was that they were inconclusive insofar as no clear trends in the overall performance of all equipment could be established. Some equipment perfo rmed well with the test fluids. Other equipment demonstrated a reduced level of safety. Problems with gaskets and seals in both new and used equipment were the primary issue found.

Results of the testing may be summarized as follows:

* Note that the values from Table 3 in the report were corrected in the table above. Table 3 did not accurately summarize the number of samples in the hose/hose assemblies and swivel categories. Additionally, the table counted incomplete submersible turbine pump (STP) and nozzle tests as compliant t est r esults. A test should only be compliant if the full test is passed.

4 See Appendix 2

– UL Rationale for Aggressive Test Fluids. Equipment New Equipment Used Equipment Total New and Used Total % Compliant

Meter Manifold Valve Assembly 0 of 2 0 of 4 0 of 6 0%

STP 0 of 1 None 0 of 1 0%

Nozzles 2 of 6 1 of 4 3 of 10 30%
Breakaway 2 of 5 1 of 4 3 of 9 33%

Swivels 2 of 3 0 of 2 2 of 5 40% Hose/hose Assemblies 8 of 9 4 of 6 12 of 15 80%

Flow Limiter 1 of 1 None 1 of 1 100%

Shear Valves 3 of 3 None 3 of 3 100%

Total 18 of 30 6 of 20 24 of 50 48%



## Compliant Test Results SummaryComprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 8

The same data may be re

- categorized as follows:

With 70% of used equipment failing the tests

, it is hard to understand how the report concluded that
there was no clear data trend

. At the extreme ends of results, shear valves and the flow limiter were the only equipment that always passed tests. Meter manifold and valve assemblies always failed. The single STP did not complete all tests. The rest of the equipment had mixed resu lts. Given that the UL standard for tests is that 100% of the equipment must pass all tests to be l ist ed , the results from these
tests are far from inconclusive.

In summary , some equipment that is UL listed for E10 may have immediate failures while other may have failures over a longer time or experience a shortened overall life. In either case, the E17a tests found a reduced level of safety from using equipment certified for E10 with E17a.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 9



## 3. Biofuels: Challenges to the Transportation, Sale and Use of Intermediate Ethanol Blends ( GAO June 2011)

Background

The U

. S

. Congress asked GAO to examine three issues regarding the increased use of ethanol:

1. Determine the challenges, if any, with transporting additional volumes of e thanol to wholesale
markets.

2. Determine the challenges, if any, associated with selling intermediate ethanol blends at retail

stores.
3. Examine research by federal agencies into the effects of intermediate ethanol on automobiles and stationary engines.

This summary of the GAO report only address es issue #2 regarding potential challenges to the retail fuel

store.



## Findings

There are implementation c hallenges due to regulations and technical issues :

1. Federal and state regulations governing health and environmental concerns must be met before blends can be sold. Fuel testing time to meet these regulations will take more than one year to complete

.

2. Federal safety standards (OSHA) do not allow ethanol bl ends over 10% to be dispensed at most retail facilities and federally sponsored research has indicated potential problems with compatibility of existing equipment with ethanol blends.

3. According to EPA and an industry representative, the compatibility of m any UST systems is uncertain and retailers will need to replace any components that are not compatible with
ethanol blends.

4. Trade groups report that fuel retailers may face significant costs such as upgrading or replacing equipment.

5. Industry representatives raised concerns that fuel retailers could expose themselves to lawsuits for negligence and invalidate important business agreements that may reference these safety requirements, such as tank insurance policies, state tank

- fund policies, and business loan
agreements.

6. F uel retailers have received conflicting or confusing messages from different authorities as to whether existing dispensing equipment can be lawfully used with intermediate ethanol blends.

E ven if state or local officials

— such as fire marshals

— approve the use of intermediate blends with existing dispensers, the retailers selling these blends would still be effectively ignoring OSHA’s regulations, which require the use of equipment that has been certified for safety by a

NRTL.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 10

Fe deral and Stat e regulations need to be met:

Specific industry standards from ASTM or NIST do not allow ethanol above E10. Either of these standards must be revised or the states will have to change their standards that reference these industry standards.

OSHA standards prohibit using existing equipment for intermediate ethanol blends unless it is UL listed
for the fuel

. OSHA

, however, has not yet taken any specific enforcement action or plans to educate the industry on requirements

.

Compatibility of m any UST s ystems with i ntermediate blends is u nclear :

The November 2010 NREL / UL compatibility study reported that some dispenser components demonstrated a reduced level of safety, performance

, or both when exposed to the test fluids.

In a December 2010 an nouncement based on this NREL research , UL stated that it advised against the use of intermediate ethanol blends in equipment certified for E10 and

, instead

, recommended the use
of new equipment designed and certified for use with intermediate ethanol blen ds. UL had concerns with degradation of gaskets

, seals , and hoses that could cause leaks.

In March 2011, ORNL subsequently published a report that stated

, while most metals are unaffected by the test fluid, all elastomers tested exhibited some level of swelling and the potential to leak.

Inadequate record keeping may make it difficult for retailer s with older stations to verify UST system compatibility wit h intermediate ethanol blends. There are also i ssues with information transfer
between multiple owners of UST systems. Many installation contractors and equipment manufacturers

may also have gone out of business.

Research so far has been limited to mate rials and a few unidentified UST components

. 5 The EPA has not developed a plan to do more research on components.

EPA required leak detection systems may not properly detect leaks of intermediate ethanol blends. The EPA has not yet completed tests that will determine if the ethano l content of fuel would affect the operability of this equipment.

Retailers may face significant costs and risks in selling intermediate blends :

Retailer margins are low for fuel and most retailers will not upgrade their UST systems without a significant opportunity. Cost for upgrades could range from nothing to the cost of entirely new systems. Some sites cannot install additional UST systems due to space constraints, permit requirements or cost

.

M any sites currently stor e only two products underground and blend a third mid

- g r ade . If a retailer wants to use one tank to store E15, then they could not offer fuel for vehicles made before 2001 or non

road engines.

5 This assessment by GAO was made prior to the completion of Ken Wilcox’s research, detailed on page 12

.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 11

There may be increased r isk from using existing equipment to s ell E15. While some local requirements may allow selling E 15 from existing dispensers, OSHA requires that dispensing systems be UL listed. According to GAO, w ithout this listing, retailers may expose themselves to lawsuits for negligence and
invalidate im portant business agreements such as tank insurance policies, state tank fund policies and business loan agreements.

In GAO’s opinion, m isfueling could raise liability issues, especially if engines have diminished performance or safety issues. Customers m ay not be aware of the distinction between fuels and may accidently misfuel. Some consumers will intentionally misfuel the vehicles if intermediate ethanol blends are cheaper.



## Conclusions

The EPA and OSHA are responsible for ensuring that fuels are compatible and safe for use with infrastructure at fueling locations. The DOE materials report found that materials commonly used in gaskets or seals can swell with E15, potentially causing leak s

.

While some of the latest equipment meets OSHA safety requirements for E15, most existing equipment at retail fueling locations is not approved for use with intermediate blends

. OSHA is currently clarifying requirements on how OSHA safety regulations o n fuel dispensing equipment should be applied to fuel retailers selling intermediate ethanol blends.

The EPA has reported that they plan to issue guidance for UST owners on how to determine the compatibility of the tank system if the y wish to store highe r blends of ethanol. Despite acknowledging
that additional research on the suitability of specific UST components with intermediate blends is
needed , EPA’s guidance will be based on information limited to experts’ views on the subject. 6

Those owners that cannot demonstrate compatibility of their systems with the higher blends of ethanol
cannot store those fuels.

6 T his guidance was issued in June 2011 , and is now a proposed regulation: EPA

- HQ

- UST

- 2011

- 0301

.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 12



## 4. KWA Report

– Testing the Functionality of Stage I Vap o r Recovery and Overfill Prevention Components

Background

The objective of this report for API w as to determine whether there are any adverse effects on the functionality of S tage I vapor recovery components and overfill protection systems when used in a higher alcohol blend. Equipment used successfully for many yea rs on E10 w as tested with E10 and E17a
blend s

.


## Approach

Equipment was first soaked in the E10 or E17a test fluid for 4 weeks at 140 ° F. Equipment was then mounted in test apparatus and cycled for up to 100,000 cycles. Identical equipment was tested in both
E10 and E17a.



## Results

Equipment tested :

Fill and vapor swivel adapters

- Six of eight tests failed.

Ball f loat valves

- All tests passed

.

Spill bucket drain valves

– All tests passed

.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 13 Flapper Valves

– One of the two valves tested failed the CE17A test. All other tests passed

.

Monitoring probe cap

– All tests passed

.



## Conclusion

T he primary failures observed were due to degradation of seals, gaskets or other material in the

c omponents under test. This raises a question about what condition these types of gaskets are currently

in at sites selling E10 fuel.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 14



## 5. An Experimental and Modeling Study of the Flammability of Fuel Tank Headspace Vapors from High Ethanol Content Fuels

– Oct ober

2008

Background

The p roject was to quantify the difference in headspace flammability hazards between E85 fuel and gasoline without ethanol (E0) inside of storage tanks. Headspace is the area inside of the tank that is not filled with liquid fuel

.

Headspace vapors are mixtures of hundreds of individual pure compounds that depend on ambient temperature and the amount of liquid fuel in the tank

. Gasoline is so volatile th at at most temperatures the vapors are too rich to burn.

Ethanol in a fuel tank has vapors that are flammable over a broad range of commonly encountered ambient temperatures.

Ethanol/gasoline blends have flammability characteristics somewhere between t he properties of the two fluids depending on the ratio of these two main fuel compone n ts.

Specific study goals can be summarized as foll o ws:

1. Develop the test apparatus and protocols required to conduct the study in a small

- scale laboratory.

2. Test a serie s of representative samples of E85, gasoline and denatured alcohol

. 3. Analyze results and draw conclusions

4. Develop mathematical models for the fuel tank tests. Evaluate the utility of modeling to assess
fuel tank combustion hazard scenarios.

5. Do a prelimina ry analysis of the flammability risk from vapor/air plumes emitted from fuel tanks during refueling

.

This summary report will not cover task 4.



## Tests

Test fluids were seven slightly different blends of E85, two types of gasoline and denatured ethanol

.

All tests were based on the flammability in a small test vessel ( i.e., an explosion proof junction box) that

was filled with 5% liquid and 95% vapors. Vapors were ignited by a spark plug. Temperature was also recorded by connected computer.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 15

T his picture of the test device was included in the report. The spark plug in the center is a good reference for gauging the size of the text vessel

.



## Results

T ank headspace vapors were measured to be flammable in the following ranges :

Gasoline: flammable at

- 2 ° F to

- 13 ° F or lower.

E85: flammable at 28 ° F to

- 8 ° F or lower.

Denatured ethanol: 22 ° F or higher. (Colder vapors are too lean to burn)

T hree E85 fuels had flammability behavior similar to the summer grade gasoline tested

.

A r isk identified was that when storing neat ethanol at service stations for on

- site blending , t he headspace vapor in the 100% ethanol tank would always be flammable above 22 ° F.

The report concluded that

, at any given temperature, the more volatile the fuel, the larger the flammable plume from the vent gets during UST refueling . This in turn increas es the risk of vent fires while filling the tanks with fuel. This larger plume also increases the risk of an external fire spreading
down the vent into the tank headspace under some circumstances.

The r eport did not include any information on intermediate ethanol blends. It was only about the test
fluids used. Accordingly, there is no information for retail service stations potentially selling E15 aside
from th e possible storage of neat ethanol in the future.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 16

Recommendations included :

1. The E85 fuels tested did not provide a blend matrix where critical components (such as ethanol content, vapor pressure and hydrocarbon composition) could be varied in a systematic method

.

2. The study used the strong spark plug ignition source. The hazards posed by weaker sparks that represent actual potential ignition sources should also be investigated.

3. The tests used a 5% fill level which is a worst

- case scenario for p otential flammability. The effect of fill level on flammability should also be investigated.

4. The test apparatus needs to be refined before it can be recommended as a standard.

5. A thorough quantitative assessment is needed of the various vapor flow regime s possible during refueling storage tanks under different fill rates, vent geometries and weather conditions, etc.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 17



## 6. An Experimental and Modeling Study of the Flammability of Fuel Tank Headspace Vapors from High Ethanol Content Fuels

– Phase 2: Evaluations of F ield S amples and Laboratory Blends

– April

2010

Background

This report follows up on the work done in 2008.

The goal of the study was to measure the flammability of fue l vapors from a variety of ethanol/gasoline

blends at low ambient temperatures and develop a mathematical model to predict the temperatures at which flammable vapors were likely to form.

Two set s of fuel were investigated. The first sets were sampled from a fuel dispenser. The second were laboratory fuels supplied by Marathon designed to simulate winter grade fuel.

Another goal was to improve the earlier modeling work . Comments are not provid ed on that work

.



## Tests

Test methods and apparatus were similar to those used in the 2008 work. The same test chambers and
5% fill level were used.



## Results, Conclusions and Recommendations

1. Some E85 tanks currently in use are likely to have flammable vapor conditions as high as 23°F ; at higher temperatures

, vapors are not flammable.

2. E20 and E30 blends were sampled from a blender pump that mixed E10 with E85. No significant
differences in fl ammability could be found between the E20

- E30 samples and the E10 sample that they were produced from. These results indicate that mid

- level blends in this range ar e unlikely to significantly increase the risk of producing flammable vapors over that of th e base gasoline used for
the blends.

3. Laboratory samples of E55

– E83 were produced to measure the change in flammability. Flammability changes from E85 decreased substantially down to E60. Lower concentrations of

e thanol below E60 reduced the flammabilit y at a lower rate.

4. Standards for winter gasoline and vapor pressure will probably limit the concentration of ethanol to
a maximum of about 65 %.

5. Flammability tests found that vapor pressure does not adequately predict the flammability of the
fuel. The hydrocarbon portion of the fuel must also be considered

.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 18

6. Additional testing is recommended to examine the effects of gasoline flammability on the vapor flammability of the ethanol/gasoline blends. Flammability results over a wider range of ethanol

conten t are needed to understand the interactions between ethanol content, gasoline volatility, blend vapor pressure and vapor flammability.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 19



## 7. Experimental and Modeling Study of the Flammability of Fuel Tank Headspace Vapors from Ethanol/Gasoline Fuels

- Phase 3: Effects of Winter Gasoline Volatility and Ethanol Content of Blend Flammability ; Flammability Limits of Denatured Ethanol

- July 2011.

Background

This project was comprised of a study to measure the flammability of fuel vapors at low ambient
temperatures an d develop a mathematical model to predict the temperatures at which flammable vapors were likely to form.

This summary does not include comments on modeling.



## Tests

Tests were very similar to the two previous studies.

The fuel used was produced in a laboratory to systematically investigate the effects varying ethanol content on the volatility and flammability of the blends. Three gasoline vapor levels were tested to simulate low, typical and high levels of winter gasoline.



## Results , Conclusions and Recommendations

Headspace vapor from E0 to E15 blends with winter gasoline vapor pressures were not flammable until temperatures were below

- 13F. With higher vapor pressure gasoline, the maximum et hanol content that would keep the same flammability level would have to be 40% or less

. Accordingly, E15 vs. E10 would not present a significant difference in flammability risk

.

Further experimental work is recommended to examine the headspace vapor flam mability of ethanol/gasoline blends made with base gasoline which have lower vapor pressure then the winter gasoline used so far.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 20



## 8. S w RI Literature Review of the U sefulness and E fficacy of F lame

A rresters and P ressure/ V acuum V alves with Gasoline

- Ethanol

B lends

- July 2, 2010

Background

SwRI conducted a literature review for API to determine the usefulness and efficacy of flame arresters and pressure/vacuum (PV) valves with gasoline

- ethanol blended fuels. SwRI used various online journal and reports data bases and reviewed relevant standards to conclude what guidance if any is available for

U

. S

. retail stations.

U

. S

. retail stations do not currently utilize flame arresters to protect fuel storage tanks from outside ignition sources. Some European countries do use flame arresters. The purpose of this review is to investigate if flame arresters are necessary for safety , especially for use with gasoline

- ethanol blends.



## Results, Recommendations and Conclusions

This review did not find any useful history of fire events in the U

. S. They also did not find any
recommendations for flame arrest e rs in the U

. S

. or anywhere else other than a UK IPEA
recommendation that flame arrest e rs be used on all openings to the underground storage tanks storing 30% to 90% blended gasoline ethanol fuel.

C onclusive evidence was not found that suggests flame arrest e rs be implement ed at U

. S

. retail stations

. H owever , if properly selected, flame arrest e rs would only add to overall safety. The report provides no estimate of how many fires there are today or h ow many fires could have been prevented with flame

arrest e rs

.

Stage I and II vapor recovery systems may also reduce the chance of fires, but there is no detailed data to support this theory. Stage I vapor recovery is now installed at nearly all U .S. stations

. For Stage II, t he

a uthors compared the frequency of fire incidents in California, where S tage II is ubiquitous, to incidents

in other states. They concluded that S tage II contributes to a lower risk of fire incidents at retail

stations.

The report also recites overall recommenda tions on materials that are recommended or not
recommended for E10 use. Failure to use compatible materials may result in leaks and an increased risk
of fires.

The study recommended another study be performed to investigate the efficacy of PV valves and flame arresters when used with gasoline and gasoline

- ethanol blends. The goals of this study would be to
determine : (1) if PV valves provide adequate fire safety

, (2) the risk of f lames propagating into the tank, (3) if flame arrest e rs designed for gasoline are still effective when used with gasoline

- ethanol blends, and (4) what role ethanol concentration plays in the efficacy of flame arresters.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 21



## 9. USEPA Notice of Guidance on E

- 15 Compatibility ; Federal Register Publication (EPA

- HQ

- UST

- 2010

- 0651; FRL

- 9428

- 8)

In January 2011, EPA approved a waiver to the Clean Air Act to allow the use of E15 gasoline in 2001 and newer light and medium duty motor vehicles which include s cars, small trucks and some s port u tility
vehicles.

In this document

, EPA issu es final guidance on how owners and operators of UST’s can demonstrate compliance with Federal compatibility requirements for UST systems storing gasoline containing greater than 10% ethanol or diesel containing great er than 20 % bio diesel.

This guidance a pplies to states and territories that do not have state program approval as well as Indian Country. It may also be useful for owners in states with approved programs because th ose programs also include compatibility requirements.

Because it is common for tank owners to use their tanks for 30 years or more, m any UST systems currently in use are likely to contain components not designed to store gasoline ethanol blends over

10%. Also, the report comments that studies so far have shown that mid

- levels o f ethanol (i.e., the 25%

range ) are likely to cause more compatibility problems than E85.

The guidance includes all components of the fuel system from the tank

, including the shear valve. It is noteworthy that the requirements do not apply to dispensers and vapor recovery equipment. Dispensers

, however

, are required to have a NRTL listing by Federal OSHA regulations. Vapor recovery equipment is not included because it does not routinely contain liquids. The EPA rationale is that any

i ncompatibility of vapor recovery equipment is not likely to result in a liquid release to the environment.

Additionally

, EPA has rule d that pipe adhesives and glues are not included because they are an integral part of the piping

. I nstallers d id not have discretion in the type of glue used. Additionally, owners are not likely to have records about what types of glues were used. Accordingly , adhesives and glues are covered under “piping”

.

Biodiesel blends are also partially covered by this guid ance

. Biodiesel concentrations ra nge from B100 ( a fuel that has documented problems degrading some hose, seals, gaskets, glues, plastics, etc. ) to B5

- B20 which ha ve no history of compatibility problems. Currently, there are few installations of greater than B20 so little is known about compatibility. Additionally, UL does not require special investigations for biodiesel up to B5 that meets all ASTM fuel quality standards. Accordingly, th is EPA guidance applies

to only biodiesel blends greater than B20.

The EPA notes that these recommendations are intended solely as guidance. Compatibility requirements are part of CFR 280.32. Since approved state programs have the same compatibility requirements as CFR 280.32, they may choose to use the new guidelines for compatibility as well.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 22

UST components that may be affected by b iofuel blends of greater than E10 or B20:

 Tank or internal lining

 Piping

 Line leak detector

 Flexible connectors

 Drop tube

 Spill and overfill prevent equipment

 STP and components

 Sealants (including pipe dope and thread sealant), fittings, gaskets, o

- rings bushings, couplings
and boots

 Containment sumps (including STP sumps and under dispenser containment)

 Release detection floats, sensors and probes

 Fill and riser caps

 Product shear valves

For newly installed equipment comprised of multiple component equipment like a ST P

, UST owners or operators may obtain a certification from the manufacturer documenting compatibility for the entire assembly. If the equipment requires maintenance and com ponents of that equipment such as sealants or gaskets are subsequently added or replaced, then manufacturer approval of the overall component is not sufficient to demonstrate compatibility

EPA recommended methods of demonstrating compatibility of UST systems with greater than E10 or
B20 fuels include:

 Use components that are certified or listed by a nationally recognized independent test laboratory for use with the fuel stored.

 Use components approved by the manufacturer to be compatible with the fuel stored. EPA considers acceptable forms of manufacturer approvals to:

o Be in writing ;

o Indicate an affirmative statement of compatibility ;

o Specify the range of biofuel blends the component is compatible with; and

o Be from the equipment manufacturer, not ano ther entity (such as the installer or
distributor ).

 Use another method determined by the implementing agency to sufficiently protect human
health and the environment.

The EPA also allows owners and operators to use API RP 1626 ( August 10, 2010 ; 2 nd E ditio n ) to demonstrate compatibility for UST systems storing biofuels.

There are no other alternative s to demonstrate compatibility. If the owner or operator is not able to demonstrate compatibility, then EPA ’s advice is not to store biofuels over E10 or B20.

State UST programs may be mo re stringent th a n EPA standards

, and additional Federal, state or local
standards ( such as OSHA, t he National Fire Protection Association, or the International Fire C ode ) may ha ve other requirements. UST owners and operators should check with state and local agencies to determine their requirements.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 23



## 10. 

## Compatibility of Fueling Infrastructure Mat erials in Ethanol
Blended Fuels (ORNL January 2012) & Draft Compatibility Study for Plastics, Elastomeric, and Metallic Infrastructure M aterials Exposed to Aggressive Formulations of Ethanol

- Blended Gasoline (0RNL March 2012 Draft)

Background

Th e PowerPoint document was used as part of a January 5, 2012 webinar on the research underway at ORNL to document the effects of ethanol blends on metals, elastomers and plastics. The report summarized the test methods and results included in research documents publish ed earlier (see testing specified on pgs. 4 and 7 )

, and revealed preliminary results on tests of different plastics that are used somewhere in fuel dispen sing equipment. The March Draft Report provided additional details on the plastic material testing at ORNL.

The ORNL conducted tests on 22 types of plastics. Tests were run for 16 weeks versus four weeks for
other materials. Fuels tested included Fuel C, CE25a, CE50a, and CE85a.

The goal of the testing was to measure critical plastic property changes such as volume swell, hardness,
or mass in ethanol

- blend fuels. The results are intended to be used by equipment designers (or users) when developing materials for ethanol

- blended gasoline dispensers. The report

, however, does not make specific product recommendations.



## Results, Recommendations and Conclusions

Results for plastic samples exposed to vapors were the same as those samples that were soaked in liquids.

Seven plastics were identified as having notable results.

Nylon 12 was the only plas tic that lost volume (shrunk) after being dried. Nylon 12 is most likely
to be used in hose.

The following plastics had the greatest amount of volume increase (swell) and hardness decrease after exposure to the test fluids.

Nylon 11 is used in some type s of flexible piping.

PP

– Polypropylene is a polymer used in a wide variety of consumer products and packages. No specific uses in fuel system equipment are known.

PETG

– Polyethylene terephthalate copolymer with cyclohexane dimethanol is used to make plastic parts or covers. No specific uses in fuel system equipment are known.

Vinyl ester resin may be used in tank linings.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 24

Terephthalic polyester resin is used in the construction of fiberglass underground storage tanks.

Four samples of isophthalic polyester (without fiber reinforcement) fractured during tests with CE25a
and CE50a test fluids. These plastics may be used in fiber reinforced plastic underground tanks, pipes or containment sumps.

Test fluid evaluations after the completion of sample soaking measured high levels of phthalates. These chemicals are generally components of plasticizers that may be used in hose or flexible membranes in nozzles, valves or other products.

The final report on plastics is expected in a few months.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 25



## Overall Conclusions & Recommendations

The N RE L report on equipment compatibility found that many service station components may not be compatible with E15.

The ORNL report on elastomers, metals and sealants alerted designers to elastomer issues that could be problems w hen designing equipment for E15. Older designs and materials may not be compatible with

E15.

The GAO reported that OSHA requires all components of a dispenser system be UL listed for the fuel grade sold. GAO has indicated that a dispenser system includes all components from the dispenser
nozzle to the STP. Earlier listings were only valid for up to E10. If retailers dispense E15, they should ensure that all equipment that comes into contact with the E15 is listed for com patibility with that fuel. Without this listing, retailers may possibly invalidate important business agreements such as tank insurance policies, state tank fund policies and business loan agreements. They also note that the E15 compatibility of many UST systems is uncertain.

Ken Wilcox found that many gaskets for fill and adapter swivel adapters may not be compatible with

E15 . He also found problems with one overfill flapper valve.

The N RE L reports on headspace flammability found that E15 flammabil ity is not significantly different
than E10.

EPA provides specific guidance on how to determine if existing equipment is compatible with E15. They also advise that some state programs may have more stringent requirements. The only alternatives to
their guidance are to either follow the recommendations of API 1626 or choose to not store and sell the
E15 fuel.

Accordingly, a store owner choosing to sell E15 will incur conversion expenses that could range from as little as hanging hardware to as much as th e need for a completely new fuel system with new tanks, sumps, piping, valves, fittings, dispensers and leak detection equipment.

A store owner that does not follow this guidance faces significant risks :

 Safety

 Environmental consequences

 Liability assoc iated with c ustomer vehicle or non

- road engine issues

 Possible litigation

 Financial impactsComprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 26



## Risk and Mitigation Summary

Increasing ethanol to E15 is likely to increase the risk of operating a retail store. Possible leaks from incompatibility are higher than they are with E10. Risks from these releases could affect personnel and customer safety, the environment and the pos sibility of litigation. A new issue also arises with the possibility of misfueling that could result in engine problems with pre

- 2001 vehicles and non

- road engines. Owners and operators should consider these risks and the possible financial effects on th eir business when judging whether to store and dispense E15 at their facility.

The following service station schematic and tables are intended to approximate and suggest possible mitigation measures for some of the risks associated with storing and disp ensing incompatible fuels at a

service station.Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 27 

# BASIC UNDERGROUND STORAGE TANK SYSTEMComprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 28Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 29Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 30



## Appendix 1: E10+ and Biodiesel Compatibility MatrixComprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 31Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 32Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 33Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 34Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 35Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 36Comprehensive Analysis of Current Research on E15 Dispensing Component Compatibility Page 37



## Appendix 2: UL Rationale for Aggressive Test Fluids

Excerpt from Dispensing Equipment Testing with Mind

- Level Ethanol/Gasoline Test Fluid 7 :

The tests were conducted using CE17a test fluid, as defined by NREL. The test fluid was
based on the same standard used to evaluate material compatibility for flexible

- fuel
vehicles. A 17% ethanol volumetric concentration was selected to address E15 use. This was not a commercial fuel, but rather a test fluid selected for research purposes. CE17a
test fluid consists of a mixture of 83% ASTM R eference Fuel C and 17% aggressive
ethanol. Reference Fuel C is a 50/50 v/v blend of isooctane and toluene. Aggressive

ethanol

, as defined in SAE Publication J1681, Gasoline, Alcohol, and Diesel Fuel Surrogates for Materials Testing

, is a mixture of synthetic ethanol and the following aggressive elements in defined amounts: deionized water, sodium chloride, sulfuric acid, and glacial acetic acid. The added elements are representative of contaminants found in
ethanol. (p. 2

- 3)

Excerp t from Underwriters Laboratories Research Program on Material Compatibility and Test Protocols for E85 Dispensing Equipment 8 :

Potential fuel contaminants include water, salts, acids, and other substances. These contaminants may be introduced to the fuel at different points and subsequently passed along through the distribution chain, although the fuel station level appears to present the highest risk point for fuel contamination. Water may be present in storage tanks
from sources such as condensation in atmospheric tanks, ground or surface water entering tank seals, settling out from petroleum products in previous use, and the like. Soluble road salts may also be present in surface water runoff and may end up in the
fuel. Salt air condensation during sea transport or in coastal areas presents an
additional risk of contamination from chloride compounds. Consideration of the fuel conductivity with absorbed water and salts is a key issue. Acids may also be introduced

to the fuel during the production proces s, through oxidation of the fuel, or via surface
water runoff. Using aggressive test fluids that include contaminants was identified as an important practical consideration. (p. 5)

7 Dispensing Equipment Testing with Mind

- Level Ethanol/ Gasoline Test Fluid . (NREL, November 2010).

< http://www.nrel.gov/docs/fy11osti/49187.pdf >.

8 Underwriters Laboratories Research Program on Material Compatibility and Test Protocols for E85 Dispensing Equipment . (UL, December 2007).

< http://www.ul.com/glo bal/documents/offerings/industries/energy/flammableandcombustiblefluids/developmen t/E85ResearchReport.pdf >.