Quasi-Harmony and the EPA Wild Card

As the synchronization of biodiesel standards moves forward across the world-most notably between the ASTM D 6751 and EN 14214 protocols-a concerted effort is underway in the United States to improve D 6751 while keeping the U.S. EPA and its slow moving regulatory body at arm's length.
By Ron Kotrba | October 16, 2007
Developed as a mechanism to bring major renewable fuels players on the same page, the International Biofuels Forum (IBF) formally organized this spring with the seemingly daunting task of harmonizing the world's biofuels quality standards. The purpose is to jump-start the global commoditization of ethanol and biodiesel with minimal technical interference. Experts agree that European biodiesel specifications and quality standards have been tailored around specific feedstocks common in Europe-mostly rapeseed. Despite this Eurocentric flaw continental standards stand second to none. This is partly why those involved in shaping and improving ASTM standards have been working hard to close the technical gaps between D 6751 and EN 14214.

Experts are hesitant to predict exactly how this new set of international standards will look-whether ASTM will retain regional autonomy or if EN will prevail across the world or maybe a fused montage of elements borrowed from EN and ASTM will emerge with a distinctly international designation. "I wouldn't even begin to make a prediction," says Steve Westbrook, principal scientist with Southwest Research Institute and chair of the ASTM subcommittee E. Westbrook is also an IBF committee member. "It's going to come down to the few things that are not common to both specs, and really are probably based on feedstock differences for the most part," he says. "Whether it comes down to picking one or the other and making it an ISO spec or what, I just don't know." Westbrook and others say most countries already rely on either EN or ASTM quality standards in some form or another. Therefore the task is to weave together in an official and standardized manner what is essentially already being done to ensure original engine manufacturers (OEMs) and fuel purchasers that the product they're buying from Brazil or India resides within the same set of technical specifications as fuels purchased domestically.

In a presentation made to the 11th Annual Green Chemistry and Engineering Conference in late June, Steve Howell, the National Biodiesel Board's (NBB) technical director, indicated that foregoing the encompassing ASTM protocol simply isn't an option in the United States. Howell said ASTM fuel standards have become intimately entwined within federal and various state laws, tax regulations, product listings, safety regulations, EPA regulations, insurance listings, etc., so much so that a revision of those laws and regulations to "specify a new, non-ASTM standard would be very expensive, time consuming and difficult." Howell said it is therefore important that current and improved ASTM standards continue as the recognized standards to meet U.S. needs. Of the IBF and its goals, "Right now there's somewhat of a loose structure," Westbrook says. "I think we're trying to get the foundation laid."

Closing the Gaps
While Howell indicates that replacing ASTM standards with an international variety would be too costly to justify, the fact is ASTM D 6751 resembles EN 14214 more and more. One such recently closed gap is the inclusion of a trace metals spec in D 6751. A combined limit of 5 parts per million (ppm) of sodium and potassium-residual catalyst materials in the fuel-and a combined 5 ppm spec on calcium and magnesium mesh with EN 14538. Sources say this spec, much like many other addendums, inclusions or improvements to quality standards, is often spear-headed by the OEMs in rightful attempts to protect their assets-engine warranties.

Another measure taken to bring U.S. and European standards closer together is the adoption of EN 14112, a three-hour oxidative stability test commonly referred to as the "Rancimat test." Europeans have long relied on a six-hour Rancimat test to determine the stability of its often rapeseed-based biodiesel. The caveat with the three-hour test is that it's supposed to begin at the point of blending rather than at the point of production. While some experts agree three hours is not a long enough duration for this accelerated test, the Europeans have no concrete data to back up the need for a six-hour test. Sources involved in the effort to improve the shelf life of biodiesel tell Biodiesel Magazine that, when the three-hour oxidative stability test passed and became a part of D 6751, industry leaders were willing to vote it in because the need for some sort of mechanism to test the shelf life of U.S. biodiesel was widely recognized as the biodiesel industry's struggle with quality control became more apparent. The idea was to pass a three-hour test for starters and improve on it in the future. A subtler difference between ASTM and EN, which sources say will be tougher to reconcile, is the means of carbon residue testing-ASTM's test is done on B100 whereas in EN 14214 a test is run on a 10 percent distillation residue.

A final difference between American and European standards is the need for a method within D 6751 to test for particulate contamination. There is presently a particulate contamination specification in EN 14214 using method EN 12662 with a limit of 24 milligrams per kilogram. This is under consideration but not yet on the ballot for inclusion in ASTM D 6751. An additional measure being balloted in D 6751 addresses solids forming in the fuel above the cloud point-symptoms of which caused problems in Minnesota nearly two years ago and continue to plague the industry. This problem lit a fire under petroleum refiners and OEMs and essentially shaped the direction of biodiesel-related ASTM actions over the past year; and will continue to play a role in the future.

EPA Oversight
To recap events that led to the current volume of biodiesel-related standards activities within ASTM, last year at this time biodiesel industry analysts were still reeling from the disconcerting results of the National Renewable Energy Laboratory's B100 quality survey. Just as those disturbing results were settling in, winter was closing in again. Industry advocates feared the proliferation of gelling instances at temperatures above cloud point. Also, about one year ago, biodiesel industry members brought a measure to the balloting stage that they had been advocating for some time. The measure was to allow for up to 5 percent biodiesel in the petroleum diesel fuel spec, ASTM D 975, similar to Europe's EN 590 specification. If passed, this would allow without notice a blend of up to B5 in petroleum diesel fuel-a major victory for the industry. Unfortunately, fresh in the minds of refiners were the undesirable biodiesel quality results wherein half the collected samples failed to meet ASTM specs. The most common problem identified was too much bound glycerin manifesting in the formations of solids above the cloud point. Since refiners rely heavily on cloud point, this presented reasonable justification for negative votes blocking the passage of the measure; four out of five of which came from refiners.

As a result, the U.S. EPA-also an ASTM member-has become more involved than ever before in the ongoing evolution of biodiesel fuel quality standards, and is tightening its leash on the biodiesel industry to make sure all biodiesel produced meets ASTM D 6751. Some sources characterize the EPA's move as a "hostile takeover." Others say OEMs are rightfully using the EPA as an agent of enforcement. "I guess there's a concern that if a governmental body makes regulations that it will be difficult to change it if it comes time to change it," Westbrook says. An EPA source who wishes to remain anonymous admits that the agency's involvement in the regulatory and enforcement processes of biodiesel certainly would impede the industry's ability to adjust specs in an expeditious manner. Westbrook and others take EPA's charge seriously, but aren't stalled in discouragement-balloting and approving the necessary, technically sound specs as quickly as possible, which is the No. 1 mission for the industry.

To carry out this mission an Operability Task Force on biodiesel was formed in ASTM after the failed attempt to approve B5 in ASTM D 975. The task force consists of 30 people from a wide cross-section of petroleum refiners, biodiesel producers and fuel experts. The intent of the task force is to more visibly and concretely address biodiesel quality concerns; specifically the issue of precipitates forming above cloud point.

A man some call the "shepherd" due to his successful efforts to herd member support and corral precision data, BBI Biofuels Canada technical analyst and voting ASTM member Stu Porter, has been working hard to ballot a final version of a particulate contamination test method. It's the Cold Soak Filtration Test, which was developed by Magellan Midstream Partners LP's Rod Lawrence and Porter while assisting the National Biodiesel Board, where the fuel is chilled and goes through a timed filtration process. Porter says after the terrible winter experience in Minnesota with filter pluggings two years ago, this particular method was used to test all biodiesel coming into the state. Minnesota biodiesel has been given a "clean bill of health" ever since, Porter says. He tells Biodiesel Magazine that the Operability Task Force is cautiously optimistic regarding the measure's upcoming vote. He is also balloting an ASTM particulate contamination method. The method successfully went through the balloting process once before, but because of a lack of precision data-test data accompanying the ballot item to justify its passing-one member voted negative. "And rightfully so," Porter says. "It originally went through more quickly than I expected and I didn't have my round robin or precision ready, so someone correctly voted negative." At press time in early September, Porter says the precision data will be ready and the test method for particulate contamination, which doesn't even have a number yet, will go to ballot. Porter will also be balloting the Cold Soak Filtration method. This is the same method that will be balloted in the annex of D 6751 and was to be voted on electronically on the ASTM Web site at the end of September.

Since time is of the essence and ASTM meets only twice a year (June and December), Westbrook says a cover letter will accompany the upcoming ballot informing voters that, if they wish to vote negative, the possibility of electronic adjudication is in play and, therefore, ample and persuasive reasoning should be provided as to why their negative vote carries weight. This is being done to expedite the entire process before winter and the EPA closes in on the process.

The question then is what's to come of the previously failed attempt to incorporate B5 in D 975? "Because we're balloting the cold soak due to the prior negatives on B5, the intent is to [vote on it] at the same time at main committee and the negatives are being addressed," Porter says, adding that they adjudicated the B6 to B20 spec at the last subcommittee meeting so that too will be addressed in the next session. "There will be three ballots at subcommittee E, all related to biodiesel standards," Porter says. "I'm really amazed that we got the negatives for the B6 to B20 spec adjudicated." It is hoped that the Cold Soak Filtration Test method in the annex of D 6751 and the B5 vote at Main D2 Committee will pass. "I think the fear of the unknown made people a lot more cooperative than they would otherwise be," says Porter, referring to the EPA's pending regulatory oversight.

Ron Kotrba is a Biodiesel Magazine senior staff writer. Reach him at [email protected] or (701) 746-8385.
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