South Dakota Blender Pumps Guidelines Document

DEPARTMENT OF PUBLIC SAFETY
DIVISION OF INSPECTIONS AND LICENSING

State Inspection Program
Office of Weights and Measures

E85 BLENDER PUMPS

 

South Dakota has established itself as a national leader in the production, sales and usage of alternative fuels including E85, a blend of ethanol and gasoline in which the ethanol portion is nominally 70% to 85% denatured fuel ethanol (Reference ASTM D5798). To facilitate the availability of E85 and other ethanol blends to the public, several petroleum marketers in South Dakota have installed blender pumps capable of mixing regular unleaded gasoline with E85.  The customer then has the option of selecting regular unleaded gasoline, E85, E10 or other intermediate blends.  Media reports have detailed the advent of these blender pumps, and in the case of at least one marketer, their discontinuation based on concerns over acceptability of certain blends by the United States Environmental Protection Agency (EPA).  Several states have refused to allow these blender pumps for a variety of reasons.  In an effort to demonstrate leadership in this area, the South Dakota Department of Public Safety has compiled the following information to clarify questions and concerns and to provide guidelines for the use of these devices across the State.

 

Device Installation- As with any weighing or measuring device, the pumps need to be installed and calibrated by a service agent registered in the State of South Dakota (SDCL 37-21A-1).  It is important that the pump, tank and components are compatible with the product delivered. A good source of information and guidance in this area is found on the website of the National Ethanol Vehicle Coalition.

 

Device Accuracy- South Dakota has adopted the National Institute of Standards and Technology (NIST) Handbook 44- “Specifications, Tolerances and Other Technical Requirements for Weighing and Measuring Devices”. South Dakota also requires National Type Evaluation Program Certificates of Conformance (CoC) for weighing and measuring devices.  While there are valid CoCs for E85 pumps and for gasoline pumps, we don’t believe that the existing pumps have been type-evaluated to cover their current use. The Office of Weights and Measures intends to ensure that the pumps in use have a current CoC.  Even if not type-evaluated for their existing use, the pumps will be tested for accuracy in accordance with existing statute (SDCL 37-21-9) and will be sealed for use if found to be accurate.

 

EPA Fuels Registration- One of the primary concerns expressed by marketers is whether the blender pumps in question are dispensing fuel blends that have not been registered by the EPA and are therefore illegal under the Clean Air Act.  In a letter dated 11/28/2006, the Director of the EPA Office of Transportation and Air Quality stated that, with respect to blends between E10 and E85, “…such blends are covered under the emissions certification for an E85 FFV, and thus are not prohibited under the Clean Air Act.”   The letter also cautioned, however, that the use of ethanol blends greater than E10 in gasoline-only vehicles is prohibited under the Clean Air Act.  It is therefore important that any ethanol blend greater than E10 be accompanied by a label identifying it for use in Flex Fuel Vehicles (FFV) only.  Failure to clearly and properly identify ethanol blends in excess of E10 for FFV use only increases the chance of inadvertent mis-fueling and risks a violation of the Clean Air Act.

 

Underwriters Laboratories Listing-  On October 5, Underwriters Laboratories, Inc. suspended “…authorization to use UL Markings (Listing or Recognition) on components for fuel dispensing devices that specifically reference compatibility with alcohol blended fuels that contain greater than 15% alcohol (i.e. ethanol, methanol or other alcohols).”  This ruling impacted not only E85 blender pumps but stand-alone E85 devices as well.  While no field failures have been documented, UL took the action because of concerns about the compatibility of high concentrations of ethanol with materials used in fuel dispenser components.  UL subsequently met with interested parties in early November and announced that advancements have been made toward the development of appropriate standards.  While this is a problem that has yet to be overcome, it appears to be a high priority, and progress is being made.  The South Dakota Department of Public Safety suggests that, until UL appropriate standards are adopted, petroleum marketers utilizing devices dispensing ethanol blends in excess of E10 be cognizant of the issue and closely monitor their own devices for significant changes in operation or accuracy and for signs of fuel leakage or “weeping”.

 

Fuel Quality Standards- South Dakota has adopted the American Society for Testing and Materials (ASTM) standards for fuel quality (SDCL 37-2-6).  While ASTM standards exist for regular gasoline, for E85 and for E10, they do not exist for intermediate ethanol blends.  While the lack of standards may complicate complaint investigations, the Office of Weights & Measures intends to focus on those requirements present in State statute or administrative rule.  Like the requirement for any other motor fuel offered for sale, the octane or antiknock value must be displayed and must not differ from the actual value by more than 2 octane numbers (SDCL 37-2-13).  In addition, SDCL 37-2-30 requires any gasoline containing two percent or more by volume of ethanol be identified “… as to the specific type of oxygenate or combination of oxygenates in the gasoline.”  While not specifically required by statute, the Office of Weights and Measures highly recommends that each blend offered for sale be clearly identified as to ethanol content (e.g.  E10, E20, E30, E85, etc.).   This practice should minimize the chances of mis-fueling or confusion over the amount of ethanol in the blend.

 

Residual Fuel-   With any blender pump, "switch loading" or switching from one blend to another permits a certain amount of residual fuel in the hose (or in the manifold of certain pumps) to be dispensed to the next customer.  The amount of this residual depends on the age and model of the pump and on the hose length and diameter. In South Dakota, blender pumps have been both single and multi-hose configurations.  In the multi-hose configuration present in South Dakota, one hose is dedicated to regular, unleaded gasoline.  The second hose is used for all ethanol blends including E85.  In the single-hose configuration, all products are dispensed from the same hose.  Investigation by the Office of Weights and Measures has suggested that under specific circumstances, blender pumps could dispense fuel whose octane or ethanol content could differ significantly from the specifications of the product selected.  These incidents are most likely when a small quantity of fuel is dispensed following a customer who dispensed a significantly different blend.  For example, when a customer selects E85 and is followed by a customer who selects E10 and pumps two gallons for a motorcycle, tests have shown that the first gallon pumped for the motorcycle could contain as much as 27% ethanol.  While the incident described could occur with a multi-hose as well as a single-hose configuration, the Office of Weights and Measures believes that promoting the use of multi-hose dispensers and dedicated hoses could help reduce the potential for complaints and the potential liability for marketers.  For customers, multi-hose systems provide more assurance that they will receive the product selected.

 

 

 

01/02/2007

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