NOTE:

DATE:	January 15, 2010

TO:		Docket EPA-HQ-OAR-2005-0161

FROM:	Jeff Herzog, Mechanical Engineer, U.S. EPA

SUBJECT:	Department of Energy (DOE) / Environmental Protection Agency
(EPA) / Underwriters Laboratories (UL) Conference Calls on Renewable
Fuels Retail Distribution Infrastructure

May 13, 2009 Conference Call:

Participants:

Wendy Clark, National Renewable Energy Laboratory (NREL)

Kristi Moriarty, NREL

Marc Goodman, Department of Energy (DOE)

Dennis Smith, DOE

Douglas Horne, Clean Vehicle Education Foundation (CVEF)

Ken Boyce, Underwriters Laboratories (UL)

Jeff Herzog, EPA, Office of Transportation and Air Quality (OTAQ)

Discussion Items:

•        	The actions needed to propose changes to the International
Code Council (ICC)  

International Fire Code to accommodate the presence of a mid-level
ethanol blend 

at fuel retail facilities should a waiver be granted by EPA for a
mid-level ethanol blend.

•           Recent press articles regarding the potential introduction
of a mid-level ethanol 

blend at retail facilities.

May 27, 2009 Conference Call:

Participants:

Kristi Moriarty, National Renewable Energy Laboratory (NREL)

Marc Goodman, Department of Energy (DOE)

Dennis Smith, DOE

Douglas Horne, Clean Vehicle Education Foundation (CVEF)

Ken Boyce, Underwriters Laboratories (UL)

Jeff Herzog, EPA, Office of Transportation and Air Quality (OTAQ)

Discussion Items:

•          Proposal to amend the International Code Council (ICC)
International Fire Code 

to accommodate the potential presence of mid-level ethanol blends at
fuel retail 

facilities.

•          Evaluation by manufactures of on-highway fuel tankers
regarding the 

compatibility of aluminum tank vessels for transport of E85.

•          Testing plans to evaluate the compatibility of retail fuel
dispensers for use with 

mid-level ethanol blends.

June 10, 2009 Conference Call:

Participants:

Wendy Clark, National Renewable Energy Laboratory (NREL)

Kristi Moriarty, NREL

Marc Goodman, Department of Energy (DOE)

Dennis Smith, DOE

Douglas Horne, Clean Vehicle Education Foundation (CVEF)

Tim Theiss, Oakridge National Laboratory (ORNL)

Thomas Chapin, Underwriters Laboratories (UL)

Andrea Barbery, EPA, Office of Underground Storage Tanks (OUST)

Fran Kremer, EPA, Office of Research and Development (ORD)

Jeff Herzog, EPA, Office of Transportation and Air Quality (OTAQ)

Discussion Items:

•           April 28, 2009 DOE/NREL call with the Petroleum Equipment
Institute (PEI), 

update on harvesting PEI retail fuel dispenser equipment, and status of
mid-level 

ethanol test blends.

•           Upcoming DOE/NREL meetings with industry associations such
as the American 

Petroleum Institute (API), and PEI, regarding testing plans to evaluate
the 

suitability of retail fuel dispenser/storage hardware with mid-level
ethanol blends 

•           History of replacement of retail fuel dispensers, storage
tanks etc. 

•           Public testimony given at June 9, 2009 at the EPA public
hearing on proposed 

increase in the renewable fuel standard

•           Recent DOE/NREL call with the Clean Cities Coordinators re
testing of retail 

fuel dispenser/storage hardware with mid-level ethanol blends.

July 8, 2009 Conference Call:

Participants:

Teresa Alleman, National Renewable Energy Laboratory (NREL)

Wendy Clark, NREL

Kristi Moriarty, NREL

Michael Cass, Oakridge National Laboratories (ORNL)

Tim Theiss, ORNL

Marc Goodman, Department of Energy (DOE)

Douglas Horne, Clean Vehicle Education Foundation (CVEF)

Ken Boyce, Underwriters Laboratories (UL)

Clare Kammer, UL

Andrea Barbery, EPA, Office of Underground Storage Tanks (OUST)

Fran Kremer, EPA, Office of Research and Development (ORD)

Joseph Sopata, EPA, Office of Transportation and Air Quality (OTAQ)

Jeff Herzog, EPA, OTAQ

Discussion Items:

•        	Testing plans for above and below ground retail fuel
handling 

components to help evaluate the suitability of their use with a
mid-level ethanol 

blend.

•        	Ethanol stakeholders discussion on E15 vs. E85

August  12, 2009 Conference Call:

Participants:

Teresa Alleman, National Renewable Energy Laboratory (NREL)

Wendy Clark, NREL

Kristi Moriarty, NREL

Michael Cass, Oakridge National Laboratories (ORNL)

Tim Theiss, ORNL

Marc Goodman, Department of Energy (DOE)

Alicia Lindor-Thomson, DOE

Douglas Horne, Clean Vehicle Education Foundation (CVEF)

Ken Boyce, Underwriters Laboratories (UL)

Clare Kammer, UL

Thomas Chapin, UL

Andrea Barbery, EPA, Office of Underground Storage Tanks (OUST)

Fran Kremer, EPA, Office of Research and Development (ORD)

Jeff Herzog, EPA, Office of Transportation and Air Quality (OTAQ)

Discussion Items:

•        	Relationship of August 10th announcement by UL of a new
certification pathway 

for retail fuel dispensers to cover ethanol blends up to E25 to existing
UL 

certification requirements that cover up to an E10 blend and those that
cover up to 

an E85 blend.    HYPERLINK
"http://www.ul.com/global/eng/pages/corporate/newsroom/newsitem.jsp?n=ul
-announces-new-certification-path-for-ethanol-fuel_20090810122400" 
http://www.ul.com/global/eng/pages/corporate/newsroom/newsitem.jsp?n=ul-
announces-new-certification-path-for-ethanol-fuel_20090810122400 

•        	Status of test program to evaluate the compatibility of
retail dispensers and UST 

systems for use with an E15 ethanol blend that were originally certified
to handle 

up to an E10 blend

September 2, 2009 Conference Call:

Participants:

Teresa Alleman, National Renewable Energy Laboratory (NREL)

Wendy Clark, NREL

Kristi Moriarty, NREL

Michael Cass, Oakridge National Laboratories (ORNL)

Tim Theiss, ORNL

Marc Goodman, Department of Energy (DOE)

Dennis Smith, DOE

Alicia Lindor-Thomson, DOE

Douglas Horne, Clean Vehicle Education Foundation (CVEF)

Andrea Barbery, EPA, Office of Underground Storage Tanks

Ken Boyce, Underwriters Laboratories (UL)

Clare Kammer, UL

Thomas Chapin, UL

Fran Kremer, EPA, Office of Research and Development

Joe Sopata, EPA, Office of Transportation and Air Quality

Jeff Herzog, EPA, Office of Transportation and Air Quality 

Discussion Items:

•        	Status of test program to evaluate the compatibility of
retail dispensers and UST 

systems for use with an E15 ethanol blend that were originally certified
to handle 

up to an E10 blend.

•        	Status requirements for ethanol blender pumps

September 17, 2009 Conference Call:

Participants:

Kristi Moriarty, National Renewable Energy Laboratory (NREL)

Marc Goodman, Department of Energy (DOE)

Douglas Horne, Clean Vehicle Education Foundation (CVEF)

Ken Boyce, Underwriters Laboratories (UL)

Joe Sopata, EPA, Office of Transportation and Air Quality

Jeff Herzog, EPA, Office of Transportation and Air Quality 

Discussion Items:

•	September 16, 2009 meeting between DOE and the American Petroleum 

Institute’s (API’s) Mid-Level Ethanol Blends Research Coordination
Group.  API 

further discussed the continued uncertainty regarding how test data on
the 

compatibility of exiting retail fuel equipment with E15 might be used to
help satisfy Authorities who Have Jurisdiction (AHJ), Occupational
Safety and Health (OSHA), insurance, and other authorities concerns in
the absence of a Underwriter’s Laboratories (UL) certification which
is normally required.   API discussed their plans to evaluate the
compatibility of in-use Stage I vapor recovery equipment, storage tanks,
and flame arrestors with E15.  API also discussed their plans to
evaluate potential measures to prevent misfueling equipment that may not
be tolerant of E15 if a partial waiver for E15 is granted.   API
contacted OSHA regarding whether OSHA might be able to accept something
other than a UL certification to satisfy their requirements for fuel
retail equipment. 

September 30, 2009 Conference Call:

Participants:

Teresa Alleman, National Renewable Energy Laboratory (NREL)

Kristi Moriarty, NREL

Tim Theiss, Oakridge National Laboratory (ORNL)

Marc Goodman, Department of Energy (DOE)

Kevin Stork, DOE

Douglas Horne, Clean Vehicle Education Foundation (CVEF)

Andrea Barbery, EPA, Office of Underground Storage Tanks (OUST)

Ken Boyce, Underwriters Laboratories (UL)

Thomas Chapin, UL

Clare Kammer, UL

Joe Sopata, EPA, Office of Transportation and Air Quality (OTAQ)

Jeff Herzog, EPA, OTAQ

Discussion Items:

•	Underground storage tank leak detection protocols

•	Update on testing of materials used in retail dispenser equipment
for 

compatibility with mid-level ethanol blends

•	Marathon’s decision to discontinue sales of E85.  DOE/Marathon 
evaluation of 

potential safety concerns with E85 blends containing 68% ethanol. 
Implications 

if butane blending is needed to meet minimum ASTM volatility
specifications for E85.  Potential to reduce to the minimum ethanol
concentration of ethanol in E85 below 68%.  Potential need for judgement
by DOE/FTC that this would be necessary/appropriate.

October 14, 2009 Conference Call:

Participants:

Kristi Moriarty, National Renewable Energy Laboratory (NREL)

Tim Theiss, Oakridge National Laboratory (ORNL)

Marc Goodman, Department of Energy (DOE)

Douglas Horne, Clean Vehicle Education Foundation (CVEF)

Clare Kammer, Underwriters Laboratories (UL)

Andrea Barbery, EPA, Office of Underground Storage Tanks (OUST)

Jeff Herzog, EPA, Office of Transportation and Air Quality (OTAQ)

Discussion Items:

•	Underground storage tank system mid-level blends compatibility
testing plans 

•	Update on testing of materials used in retail dispenser equipment
for 

compatibility with mid-level ethanol blends

•	ASTM plans to ballot a change to minimum ethanol specification in
ASTM E85 standard.  Current ballot would adjust minimum ethanol
specification from 70% to 68%.  A further adjustment to a lower minimum
ethanol concentration is expected to be discussed at the upcoming ASTM
meeting in December. 

October 28, 2009 Conference Call:

Participants:

Kristi Moriarty, National Renewable Energy Laboratory (NREL)

Tim Theiss, Oakridge National Laboratory (ORNL)

Marc Goodman, Department of Energy (DOE)

Douglas Horne, Clean Vehicle Education Foundation (CVEF)

Joseph Sopata, EPA, Office of Transportation and Air Quality (OTAQ)

Jeff Herzog, EPA, (OTAQ)

Discussion Items:

•	Update on testing of materials used in retail dispenser equipment
for 

compatibility with mid-level ethanol blends

•	Potential impacts on emissions and equipment durability of
misfueling non-flex fuel vehicles with E85.  DOE related that wrt the
short term effects, the vehicle can be hard to start and the on-board
diagnostics code for misfire or fuel trim may be activated.  In the long
term, fuel level senders and fuel pumps could experience reduced
durability.  Some catalyst failures were experienced at high speed when
the fuel pump started to loose flow capacity. 

•	 Results of International Code Council (ICC) Association meeting
regarding changes to the International al Fire Code (IFC) were
discussed.  The industry proposal to allow something other than
standards body listing to suffice for retail fuel dispensing/storage
equipment failed.  Thus, if a waiver is granted for a mid-level ethanol
blend, Authorities who Have Jurisdiction (AHJs) would need to grant a
waiver of the (IFC) requirement in order for existing retail fuel
handling equipment (originally certified for E10) to be used for a
mid-level ethanol blend.

•	Interaction of Energy Policy Act (EPACT) definition of an
alternative fuel with ASTM minimum ethanol specification for E85.   The
Department of Energy (DOE) interprets the definition of an alternative
fuel as specified under the EPACT.  The current ASTM International
ballot regarding the minimum ethanol concentration for E85 would adjust
the minimum ethanol concentration to 68% from the current specification
of 70% to assist in meeting the minimum volatility specification for
E85.  This proposed change would be consistent with the minimum ethanol
concentration for to meet the definition of an alternative fuel under
the EPACT as interpreted by DOE.  If it is determined the ASTM minimum
ethanol specification needs to be further reduced, then the resulting
fuel may fall outside of the definition of an alternative fuel as
defined by the EPACT and may not benefit from the requirements regarding
the use of alternative fuel by fleets as provided in the EPACT.

January 6, 2010 Conference Call:

Participants:

Wendy Clark, National Renewable Energy Laboratory (NREL)

Teresa Alleman, NREL

Kristi Moriarty, NREL

Marc Goodman, Department of Energy (DOE)

Dennis Smith, DOE

Michael Cass, Oakridge National Laboratories (ORNL)

Tim Theiss, ORNL

Andrea Barbery, EPA, Office of Underground Storage Tanks (OUST)

Jeff Herzog, EPA, Office of Transportation and Air Quality (OTAQ)

Discussion Items:

•        	The results of the Coordinating Research Council (CRC)
Testing on E85 fuel quality, with focus on the prevalence of
noncompliance with minimum ASTM International vapor pressure
specifications.

•        	The recent meeting of the ASTM committee that is considering
changes to the minimum ethanol content specification for E85 to
facilitate compliance with ASTM minimum vapor pressure specifications.  

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