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Summertime E15 Approval, Now What?

 

In late May, the U.S. Environmental Protection Agency (EPA) published a final rule extending E15 a 1 psi RVP waiver during the summer ozone season, specifically June 1 – September 15. The final rule makes good on President Donald Trump’s promise during his presidential campaign to make year-round E15 a reality.

Although the result of the proposed rule put forward by EPA was largely pre-determined, tens-of-thousands of public comments were submitted indicating the public’s interest in the rulemaking. To rush the rule through its required process to accommodate finalizing the rule prior to June 1, EPA declined to address virtually all comments, amendments, and suggestions by interested parties. What interested parties were left with was a very clean rule that simply extended E15 a 1 psi waiver and brings parity between gasoline and gasoline-ethanol blends.

Since the announcement was made, FUELIowa members have a shown a strong interest in assessing their option to sell E15. Currently, approximately two hundred retail locations in the state of Iowa are marketing E15. The RVP parity provided by the EPA’s announcement has eliminated the uncertainty and confusion associated with E15 and its previous status as a nine-month fueling option. As FUELIowa members continue to assess their options for selling E15, there are a couple of steps to keep in mind prior to introducing E15 into your underground storage tank system.

The first step that FUELIowa members should undertake in assessing E15 is to analyze their UST system for compatibility with the gasoline blend. The compatibility of your system with E15 is important in that the EPA requires it and your insurance company requires that your UST system be operated and maintained in strict compliance with state and federal regulations. For a starting point, 40 CFR 280.32 states the compatibility requirements for substances stored in a UST system. Owners and operators are required to use an UST system made of or lined with materials that are compatible with the substance stored. Additionally, FUELIowa members with the intention of introducing ethanol blends greater than 10 percent by volume or biodiesel blends greater than 20 percent by volume, must notify the Iowa Department of Natural Resources (DNR) UST Section prior to introducing the product.

EPA regulations provide two pathways for owner/operators to prove compatibility with the product stored. The first pathway involves a system listed by a national recognized independent testing laboratory for the product stored. In this scenario, it’s highly likely that the system manufacturer will advertise the system components as compatible with E15 or similar language encompassing ethanol blends up to E85. Often this type of approval is referred to as a UL listed system although, UL is simply representative of a nationally recognized independent testing laboratory operating and Underwriters Laboratory.

The second compatibility pathway approved by EPA involves a retroactive compatibility determination on the components of a UST system. Often this type of in-use UST system is referred to as a legacy system. Owner/operators using this pathway must obtain equipment or component manufacturer approval for the components comprising their system. Approval must be documented by equipment or component manufacturer in writing. The Petroleum Equipment Institute has a UST system component compatibility library available on their website to assist owner/operators with a retroactive compatibility determination on a legacy UST system.

Iowa DNR Form 542-1336 is the form required to be submitted in Iowa for a legacy equipment compatibility determination. The following components must be confirmed for compatibility and supported by written statements of compatibility from the component manufacturer: tank, auto shut-off, submersible pump, o-rings, gaskets, seals, tank sump, ATG system components, ball float, sensors, thread sealants, piping, adhesive, flex connectors, LLDs, dispenser, hoses, nozzle, swivels, break-away, filter, and sumps.



After careful analysis of a UST system’s compatibility with E15, FUELIowa members must register their business with EPA before offering E15 to the public. Registering with the EPA prior to the introduction of E15 to the public is a federal requirement. EPA requires that retailers and jobbers supplying E15 to retailers through terminal blending (splash blending or pre-blended product) register their business with the EPA, adopt a misfuelling mitigation plan designed to prevent misfuelling, and participate in a gasoline survey testing program.

Registration with EPA and the adoption of a misfuelling mitigation plan can be accomplished by submitting a request to market E15 in the form of a letter to EPA on company letterhead requesting approval. The same letter can simply reference an EPA approved misfueling mitigation plan submitted to EPA by the Renewable Fuels Association. FUELIowa has a customizable draft letter template available to assist members with the registration process.

In addition to registering with the Agency, EPA also requires retailers to participate in a gasoline sampling and survey testing program. The requirements outlined by EPA covering a gasoline sampling and survey testing program require E15 retailers to participate in a testing consortium which arranges to have an independent survey association conduct a statistically valid program of compliance surveys pursuant to a survey program plan which has been approved by EPA.  The Reformulated Gasoline Survey Association (RFGSA) has received approval from EPA for their gasoline compliance survey program. The link above will take FUELIowa members to the RFGSA E15 Survey Program registration page.

Sampling through the RFGSA program is targeted toward retail outlets offering E15 but is not exclusive to those facilities. Any facility marketing gasoline is subject to RFGSA’s testing program through their association with the EPA and owner/operators should allow RFGSA employees to obtain samples after presenting their credentials. Employees of RFGSA will document the labeling practices employed at the retail facility and survey samples will be sent to the Southwest Research Institute motor fuels laboratory where samples will be analyzed for ethanol content and Reid Vapor Pressure. The fee to participate is $100 annually and only retail locations offering E15 are required to register and pay the fee.

Contact FUELIowa if you have questions or need assistance with any portion of the processes outlined in this article.

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