What Can We Make Now Motor Fuels Regulations Update - Presentation Transcript
What Can We Make? “Retooling” for Renewables Transportation Fuels Regulations Update and Tutorial
Session Overview Regulations Tutorial
U.S. Regulations current status
Gasoline fuels
Diesel fuels
Rise of renewables – regulations recap
The rest of the world – Euro 5 and Asia
On the horizon – MARPOL (Bunker Fuel Regs)
Summary and outlook
Implications for the future
Session Overview “What Can We Make?”
Regulations Tutorial Overview of Current Regulatory Environment
Rationale for regulations
Concern over air quality and impact of increasing numbers of automobiles on public health
Legislation gives U.S. Environmental Protection Agency (EPA) authority to regulate emissions into the atmosphere
Fuels regulations are designed to improve air emissions from “mobile sources” (vehicles)
Background information – regulatory framework
Requires product registration for all gasoline, diesel and fuel additives
Applies to manufacturers (refiners), blenders and importers
EPA requires testing of some fuels and additives
EPA required certified detergent additives for gasoline
Current Regulations – U.S.
Enforcement
Customer complaints and random sampling of fuels can result in litigation and imposition of fines
Fuel producer, blender, importer can be required to produce records showing compliance with the regulations
If out of compliance, responsible party can be fined up to $32,500 per day for each violation found
Current Regulations – U.S.
EPA and State Interface
States must file a “State Implementation Plan” (SIP) with the EPA telling how they will meet Federal clean air standards for certain pollutants within a specified time
EPA sets a standard for the state or certain geographical areas within it that must meet specific targets
Example “Severe Non-Attainment” area means an area subject to the most stringent regulations
States can “opt” to meet more stringent standards than the EPA requires if they choose
Current Regulations – U.S. Federal vs. State
Why states agree to Federal regulation
States that do not meet compliance targets for air quality by designated target dates are not eligible for Federal highway funding
Populations of large states like Texas would face significant costs to build and maintain roads without this money
Current Regulations – U.S. Penalties for Noncompliance
Current Regulations – U.S. Gasoline
1973 – ban on lead
Initial regulations targeted elimination of TEL (tetraethyl lead)
Complete ban - 1995
Operations changes – round 1
Blend changes to replace octane loss
Arco (BP) introduces “EC-1” with MTBE in California
Use of ethanol in U.S. PADDII (“Gasohol”)
RVP not an issue until 1989
Current Regulations – U.S. Gasoline – Lead Leaves the Pool
1989 Regs – Summer Volatility Standards
Imposed to reduce ozone formation in summer
Phase I – 1989 to 1991
Phase II – 1992 and later
Current ranges are 7.0 to 9.0 depending on the regulated area outside California
California standards are more stringent
Gasoline blended with ethanol can exceed these limits by 1.0 even though it reduces the benefit of lower RVP
Operations changes
Increases in low RVP blending components
Reduced ability to blend butane
Current Regulations – U.S. Gasoline – RVP Reductions
Oxygenated fuels programs
Begun by states to reduce formation of carbon monoxide in winter
Original RFG was “EC-1” introduced in California by Arco (BP) in the late 1980’s to replace leaded gasoline; contained MTBE
Resulted in the first reformulated gasoline (RFG) standards at the federal level in 1995
Required in areas considered “severe” non-attainment for ozone
Other areas can “opt in”
RFG Phase I and II – 1995 to 2000 and 2000 to 2005
Established fuel performance standards
Required 2% to 2.7% oxygenate by weight
Initially allowed ethanol or MTBE to be used
Current Regulations – U.S. Gasoline – Oxygenates/RFG
Current Regulations – U.S. Gasoline – Pre and Post RFG Fuel Parameter Values (national basis) Conventional Gasoline Pre RFG Regs Gasohol Oxyfuel (2.7 wt% oxygen) Phase I RFG Phase II RFG 2005 Conventional Gasoline 2005 Range2 Avg Avg Avg Avg Avg RVP3 6.9-15.1 9.7-S 8.7-S 7.2/8.1-S 6.9 S 8.3 - S (psi) 11.5-W 11.5-W 11.5-W 11.5-W 11.9 W 12.1 - W T50 (øF) 141-251 202 205 202 202 – S 181 - W 211 – S 200- W T90 (øF) 286-369 316 318 316 330 331 – S 324 - W Aromatics (vol%) 6.1-52.2 23.9 25.8 23.4 20.7 – S 19.2 - W 27.7 – S 24.7 - W Olefins (vol%) 0.4-29.9 8.7 8.5 8.2 11.9 – S 11.2 - W 12 – S 11.6 - W Benzene (vol%) 0.1-5.18 1.60 1.60 1.0 (1.3 max) 0.66 1.21 – S 1.15 - W Sulfur (ppm) 10-1170 305 313 302 (500 max) 71 – S 81 - W 106 – S 97 - W MTBE4 (vol%) 0.1-13.8 -- 15 11 (7.8-15) 7.02 – S 6.63-W 1.66 – S 1.41 - W EtOH4 (vol%) 0.1-10.4 10 7.7 5.7 (4.3-10) 3.03 - S 2.86 – W 1.75 – S 2.19 – W
Dramatic reduction in sulfur in total pool
From 1170 to 106 ppm in conventional by 2005
From 313 in “oxyfuel” to 71-81 in RFG by 2005
RVP reductions
From as high as 15.9 in conventional to 8.3 (summer)
From 8.7 for “oxyfuel” to 6.9 for Phase II RFG
Reduction in benzene
From as high as 5.18% to 1.21% in conventional and from 1.6% to .66% in RFG
Current Regulations – U.S. Gasoline – Changes with RFG
“ Tier 2 and Gasoline Sulfur Program”
Required changes in vehicles for model year 2004 and later
Required another “ratchet” downward on sulfur in motor gasoline
Major changes in sulfur limits for gasoline and diesel
Per gallon cap of 80 ppm (gasoline)
Average of 30 ppm (gasoline)
Diesel regs discussed in next section
“ Phase in” period began January 2004
Special rules for small refiners to extend transition period
Current Regulations – U.S. Tier 2 – More Sulfur Reductions
The “MSAT” Regulations
Establishes an Exhaust Toxics Standard for conventional gasoline
Establishes a Total Toxics Standard for RFG
Requires refiners to maintain at least their average 1998-2000 performance levels for 5 types of toxics considered probable human carcinogens
Benzene
Formaldehyde
Acetaldehyde
1-3 Butadiene
POM
Current Regulations – U.S. Gasoline – Toxics
Also known as the “anti backsliding” regulation
Performance in 2000 was better than what the current regulations actually required at the time
Set a baseline for future performance at the 1998-2000 level
Producers had to file their baselines and demonstrate they were at those levels or better (further reduction from baseline) in the future
Established a default baseline for refiners without a 1998-2000 history
Current Regulations – U.S. Gasoline – Toxics – MSAT 1
Followed a review of toxics in fuels as of mid decade
Affects gasoline, passenger vehicles, and gas cans
Applies to both conventional and reformulated gasoline
Sets a new annual average benzene content limit of .62% nationwide
New standard goes into effect 2011
Current Regulations – U.S. Gasoline Toxics – MSAT 2
Other provisions of MSAT 2
Refiners/blenders can meet the standard by buying credits until 2012
After July 1, 2012, actual volume ceiling of 1.3% is effective for all
California is exempt; its standards are already lower
Special compliance flexibility for approved small refiners
Current Regulations – U.S. Gasoline Toxics – MSAT 2
Forecast impact
Refiners/blenders in Pacific NW, AK and Rockies, others with higher than average benzene will have to make additional investments
Refiners/blenders who reduce benzene early, can generate and trade “early credits” if using specific technologies approved by EPA
Current Regulations – U.S. Gasoline Toxics – MSAT 2 Impact
Early credits
Early credits can be generated from 2007 through 2010
5 types of benzene control technologies qualify for early credit generation:
Reformer feed treating (light naphtha splitting or isomerization)
Reformate treating (benzene extraction or benzene saturation)
Treating other streams not used as reformer feed (other naphtha)
Treating benzene streams other than reformate
Benzene alkylation
Current Regulations – U.S. Gasoline Toxics MSAT 2 – Credits
20 years after the Clean Air Act
Elimination of lead
The rise and fall of MTBE as a gasoline blendstock
Dramatic reductions in sulfur (from 1000+ ppm to virtually none today)
Major reductions in RVP ceilings
To meet summer ozone standards
To accommodate mandated increases in ethanol blending
Stringent caps on benzene
Summary Current Regulations – U.S. Gasoline
Current Regulations – U.S. Diesel
Diesel fuel quality
Has been regulated since 1993 with introduction of “LSD” (Low Sulfur Diesel)
Highway sulfur diesel program finalized in 2001
Required transition from low sulfur diesel to ULSD (Ultra Low Sulfur Diesel) by 2006 for on road vehicles
New sulfur limit for ULSD is 15 ppm
Limit is measured at the point where the fuel is delivered to the consumer
Refiners upstream in the distribution system have to deliver at less than 15 ppm
“ Non Road”, Locomotive, and Marine (NRLM) diesel sulfur content reduction targets are staged between 2007 and 2012
Current Regulations – U.S. Diesel
Source: U. S. Environmental Protection Agency (EPA) Distillate Regulations – Regulated Categories (to date)
Source: U. S. Environmental Protection Agency (EPA) Diesel Regulations – On Road Fuel Performance Targets
Source: U. S. Environmental Protection Agency (EPA) Diesel Regulations – Off Road Fuel Performance Targets
“ NR” = Non Road “LM”= Locomotive/Marine Source: U. S. Environmental Protection Agency (EPA) Diesel Regulations Summary and Timeline
Billions in hydrotreating investments
Needed to produce initial LSD (Low Sulfur Diesel) and remove gasoline sulfur (RFG program) in mid 1990’s
Significant investments since 2000 to accommodate Tier 2 sulfur reductions and ULSD (Ultra Low Sulfur Diesel) programs
Some new refineries will treat whole crude stream vs. intermediates
Investment in testing & instrumentation
ULSD standards require test methods able to detect very low concentrations of sulfur
Repeatability is important to document compliance with specs when shipments are transferred
New lab equipment needed at terminals; increase in transmix volumes due to “trail back” of sulfur in batch systems
Impact of Diesel Rules to Date
Dramatic reductions in allowable sulfur content beginning with low sulfur diesel in 1993
Reduction in allowable sulfur in most engine fuels to 15 ppm by 2014
Further restrictions on sulfur in residual fuels due to new limits in the marine markets (MARPOL VI standards)
Requirements for blendstocks to accommodate mandated use of biofuels (Renewables standards)
Summary Current Regulations – U.S. Diesel/Distillate Fuels
http://www.dieselnet.com
Technical research library on diesel fuels emissions and control technologies
U.S. Environmental Protection Agency
Office of Transportation & Air Quality (OTAQ)
http://www.epa.gov/otaq/
Reference Diesel/Distillate Fuels
Current Regulations – U.S. The Rise of Renewable Fuels
A new type of regulation
Energy Independence and Security Act of 2007
Gives EPA the power to revise and implement regulations to “ensure that gasoline sold in the United States contains a minimum volume of renewable fuel.”
Departs from air quality mission - this goal NOT based on air quality issues
Designed to promote increased use of U.S. based renewable fuels
Renewable Fuels
Current regulations “RFS 1”
“ Renewables” defined as produced from plant or animal products or wastes
Target total volume of renewables to be blended into gasoline
From a minimum of 7.5 billion gallons by 2012 (489,000 BPD) to 36 billion gallons (2.3 million BPD) by 2022
2012 target has been met; 2008 volume was 9 billion gallons
Target post 2012 adjusted depending on gasoline demand – if gasoline demand actually peaked in 2007 the target could potentially fall
Refiners “obligated” to either blend the required volume or buy “RIN’s” (Renewable ID Numbers) to make up the difference
Refiners must file reports demonstrating compliance on a corporate level
Small refiners exempt through 2010
Alaska and Hawaii exempt indefinitely
Renewable Fuels – “RFS 1”
“ RFS 1” impacts to date
Consumer resistance in some regions due to lowered mileage
Unsufficient consideration given to total lifecycle emissions of renewable production
High cost of RIN’s has changed the relationship between refiners and third party blenders
Issues over difficulty with biodiesel “gelling” in cooler regions
2009 “standard” is 10.21% - this exceeds the warranty tolerance for many automobiles
Renewable Fuels – “RFS 1”
“ RFS 2” rules proposed early 2009
Resets the minimum gallon target from 5.4 billion in 2008 to 9.0 billion (vs. previous target of 7.5 billion by 2012)
Adds mandated renewables requirement for diesel (both on and off-road)
Sets new, specific volume standards for:
Cellulosic biofuels
Biomass based diesel
Advanced biofuel
Total Renewables
Renewable Fuels – “RFS 2”
Source: U.S. Environmental Protection Agency (EPA) RFS 2 – Volume Targets 2015-2023+ New Targets for “Nonconventional” Biofuels Renewable Fuel Volume Requirements for RFS2 (billion gallons) Year Cellulosic biofuel requirement Biomass-based diesel requirement Advanced biofuel requirement Total renewable fuel requirement 2008 n/a n/a n/a 9.0 2009 n/a 0.5 0.6 11.1 2010 0.1 0.65 0.95 12.95 2011 0.25 0.80 1.35 13.95 2012 0.5 1.0 2.0 15.2 2013 1.0 a 2.75 16.55 2014 1.75 a 3.75 18.15 2015 3.0 a 5.5 20.5
a – target not yet known; minimum 1 billion gals. b – not yet determined Source: U.S. Environmental Protection Agency (EPA) RFS 2 – Volume Targets 2008-2015 New Targets for “Nonconventional” Biofuels Renewable Fuel Volume Requirements for RFS2 (billion gallons) Year Cellulosic biofuel requirement Biomass-based diesel requirement Advanced biofuel requirement Total renewable fuel requirement 2016 4.25 a 7.25 22.25 2017 5.5 a 9.0 24.0 2018 7.0 a 11.0 26.0 2019 8.5 a 13.0 28.0 2020 10.5 a 15.0 30.0 2021 13.5 a 18.0 33.0 2022 16.0 a 21.0 36.0 2023 + b b b b
Renewables producers must determine lifecycle GHG impact of their fuels
Lifecycle includes production and transport of feedstock used in fuels production
Renewables must demonstrate a specified reduction in lifecycle GHG as compared to a 2005 baseline for the diesel or gasoline displaced to qualify for the “quota” in the regulations
Ethanol plants in operation before December 2007 are exempt from this requirement
“ RFS 2” Introduction of Lifecycle GHG Standards
Source: NPRA Summary of Regulatory Impacts
Current Regulations The Rest of the World Euro V and Asia
Applies to vehicles sold and emissions standards applicable to European Union member states
Retrofits not required for older vehicles but new ones must comply
“ Euro” standards are a series of European Union directives
Standards have grown progressively more restrictive
Other countries (non member European states, Australia, parts of Asia) are harmonizing their requirements with these
European Fuels Specifications “Euro” Standards
European Fuels – Gasoline/Petrol “Euro” Standards
European Fuels – Diesel “Euro” Standards
Current standard for 2009 is Euro 5
Sulfur cap - gasoline
From 500 ppm for “Euro 2” fuels to 10 ppm for “Euro 5”
Sulfur cap – diesel
From 500 ppm for “Euro 2” to 10 ppm for “Euro 5”
European Fuels – Sulfur “Euro” Standards
http://www.dieselnet.com/standards/eu/fuel.php
European Standards References
Began emissions regulations in 1983
Imposes fuel economy standards on new vehicles
Major fuel types addressed
Gasoline
Diesel
Biodiesel (B100)
Compressed natural gas
Methanol (M15 and M85)
LPG
Asia - China Fuels Regulations Ministry of Environmental Protection
Vapor pressure controls imposed during summer season Mandatory detergent additives Future reductions in sulfur and toxics Source: Chinese Ministry of Environmental Protection Presentation Asia China - Gasoline
Currently not compliant with U.S. and Euro V Sulfur standards for on road fuel Source: Chinese Ministry of Environmental Protection Presentation Asia China - Diesel
Association of Southeast Asian Nations
Includes
Brunei, Cambodia, Indonesia, Laos, Malaysia, Myanmar, Philippines, Singapore, Thailand, Viet Nam
Promotes increase in interregional and international trade, economic growth
Concerned about GHG, sustainability, and increasing use of biofuels
Other Asia ASEAN
Targeting agreement on emissions reductions as a bloc by 2012
Promoting common standards for vehicles
Hydrocarbon fuels standards likely to track Euro V
Export refineries (Singapore) already in compliance with CARB for components exported to U.S. West Coast
Concerned about GHG, sustainability, and increasing use of biofuels
Other Asia ASEAN – Fuels Issues
On the Horizon Marine Bunker Fuels Changes MARPOL VI
Regulations developed by “MARPOL”
Discharge into the air and water from marine vessels in the open seas subject to agreements made by and between members party to the International Convention for the Prevention of Pollution from Ships (MARPOL 73/78)
All parties to this “convention” must agreed to be bound by Annexes I and II; others are optional
Affects pollution liability insurance
Violators subject to inspection and fines
Diesel Regulations Marine Fuels
MARPOL
International MARine POLlution Convention (document) created by the United Nations in 1973
Subscribers to the MARPOL rules are members of the International Marine Organization (IMO)
IMO is a UN agency that oversees the shipping industry
Has 167 international government members
Diesel Regulations Marine Fuels – “MARPOL”
Annexes I and II – applies to all subscribers
Set agreed limits on discharges of oil/oily waste
Contains standards for double hull tankers
Forbid discharges of chemicals dangerous to marine life
Governs discharges of “noxious liquid substances” in Baltic and Black Seas
Annexes III through VI – optional
Annex VI governs air pollution from ships at sea
Diesel Regulations Marine Bunkers MARPOL VI
Annex VI – air pollution controls
Covers emissions of SoX, NoX & VOC’s from marine vessels
Applies to fixed and floating drilling rigs and vessels above 400 tons
Provides for issuance of an International Air Pollution Prevention Certificate to vessels and rigs inspected and in compliance
NoX controls on engines installed or overhauled after January 2000
Limits of 4.5% sulfur in marine bunkers on the seas and 1.5% in designated SoX control areas
Diesel Regulations Marine Bunkers MARPOL VI
Limits already imposed on sulfur in many ports
Baltic Sea and North Sea established as Sulfur Emission Control Areas (SECA’s) with 1.5% limits
U.S. EPA recently imposed a 1.5% limit on marine fuels within 200 miles of U.S. coasts
Diesel Regulations Marine Bunkers MARPOL VI – Issues to Date
Pressure is mounting for a global reduction from 4.5% to 1.5% on all marine fuels
Proposed reduction from 1.5% to .5% in the Baltic Sea and North Sea SECA’s
Proposed outright ban on marine bunkers
New regulations on particulates and GHG’s
Diesel Regulations Marine Bunkers MARPOL VI – On the Horizon
EU fuels standards already more stringent than U.S. on sulfur; fewer restrictions on RVP and aromatics
Export refiners already comply with U.S. standards for components coming here due to certification and registration requirements
Chinese standards following Europe – sulfur too high for export to U.S.
Middle East exporters targeting Euro V specs
Still have flexibility to market “non compliant” components outside these boundaries
Latin, Central, South America are still relatively “unregulated” markets
All consuming markets interested in renewables
Asia, Europe, Other Current Regulations - Summary
Summary and Outlook “What Can We Make?” Scenario for the Future
Continued pressure to remove sulfur from transportation fuels
“ Nowhere to run, nowhere to hide” in fuels pool
Coke, asphalt last refuge for sulfur
Need for low sulfur kerosene in biodiesel blends
Increased octane giveaway potential due to need for low RVP “BOB’s” (blendstocks for oxygenate blending) to accommodate increased ethanol use
Replacing energy lost from increased use of ethanol
Outcome of “debate” over automobile warranties as ethanol content increases
Facing the Future – Issues
Low sulfur fuels
Low RVP blendstocks for oxygenate blending
Asphalt (considered a CO2 reduction since it’s not transformed in refining)
Heating oil (higher sulfur still allowed for now)
Low sulfur distillate
Overall Outlook What Can We Make?
Outcome of GHG regulations for motor fuels – ongoing status of the Sept 2009 proposal for carbon emissions limits
Whether EPA will continue to require increasing volumes of renewables regardless of overall gasoline/diesel market growth
Pushback from consumers and car makers on requirements for higher ethanol volumes above warranted levels
Adoption of programs to increase use of E85 in regions with high ethanol production
Overall Outlook What to Watch
Presenter Bio Anne B. Keller
President of Midstream Energy Group, consultancy and asset development company specializing in transportation, processing, and distribution of natural gas, gas liquids, and transportation fuels
20+ years’ experience with Conoco and DuPont in finance and operations support for refining, LPG, and petrochemical feedstock logistics
Managed fuels reporting software service for Pace/Jacobs Consultancy to handle compliance with gasoline regulations
Developed and deployed new software system to handle reporting and “tracking” of movements of ULSD from refinery gate to customer
Midstream Energy Group, Inc. 12 Greenway Plaza, Suite 1100 Houston, TX 77046 Office: 713.425.4932 Cell: 713.582.2579 Email: abk@midstreamenergygroup.com
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