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Comment 7 for Fuels Guidance Document (fuels-guidance-ws) - 1st Workshop.


First Name: Scott
Last Name: Negley
Email Address: scott.negley@dresser.com
Affiliation: Dresser Wayne

Subject: Comments on Fuels Guidance Document
Comment:
On behalf of Dresser Wayne I offer the following comments to the
referenced document,

-The fuels matrix listed on p.13 has many elements that we
question including showing vapor recovery for diesel, CNG, LPG and
other alt fuels for which there is either no need or significant
technical or regulatory requirements remaining.  

-The section for vapor recovery for electricity and urea should be
N/A. 
-We question the green dot for ARB specification pertaining to
E100 and electricity 
-Not sure why E85 is listed as red for fueling issues when FFVs
are designed accordingly to use a legal fuel.
-E100 should be referenced as N/A for fueling issues since this
will not be offered as a retail motor fuel
-Concerned about the green dots in the vapor recovery & dispenser
section under Fire Marshal; why is E30 different than E20?  Why is
diesel with B5 different than without B5? Why are the higher
bio-diesels and other alt fuels green on this row?  
-Electricity relating to VR and Tanks should be N/A.
-Does the isobutanol category also represent biobutanol?
P.14
-Question the allowable range for E85 considering ASTM is
considering lowering the current 70 to 68%.  Would like
clarification on the 79%-83% window.
-E100 does not necessarily need to be mixed with gasoline.  The
reference to E100 should be changed to denatured fuel ethanol.
-On specific fuel definitions the precentage noted should include
qulaifier 'by volume'. 
P.19
-Under Metering Systems, the reference to prototype fuel
dispensing is not accurate as there are established, approved
products for some alt fuel technologies.
P.22
- Under Dispensing Device, indicates that this consists of a
power-operated pumping unit which in most cases is not true in CA.
-Under Dispensing Nozzle, reference to gasoline should change to
fuel or liquids and not all nozzles return vapors to underground
tank.
-Under Impact Valve, it mentions that all such devices have a
fusible link when there are some which only feature a mechanical
shutoff.
P.23
-Given the changing nature of the fuel supply gasoline vapors
should be referenced as hydrocarbon vapors
-Under vapor assist and balance there is no defition as to whether
this includes Phase I or Phase II recovery or both.  If Phsae II
'dispensing operations' should be replaced with 'vehicle
refueling'. 
-Under Vapor Processing Unit, the term 'construed interpreted is
misleading.
P.24
-Under Vapor Recovery System, the term 'processing' is used which
is an active term and probably does not apply to the Healy bladder
or small sites which do not require.
P.28
-Under Vapor Recovery, do not understand what 'Phase 3' system
means. 
-Under Vehicle Issues, FFVs are designed to run on any E85 and any
higher blend ethanol.
-Under CAL FIRE -OFSM, E85 product cannot meet CA...should be
changed to E85 product has not met CA...
P.29 
-Under SWRCB, what is meant that various manufacturers have opted
to not obtain such approvals?
P.32
-Under ARB Specifications, it should be noted that ARB had
approved the Healy System for E15 so the protocol does exist.
P.33
-Under Vehicle Issues, correct typo of E10 to E20.
P.38
-Under Vehicle Issues, there is no plan to run vehicles on
denatured fuel ethanol (E97)...there is a future possibility if
approved, of storing underground for blending at dispenser but not
to run in vehicles.



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Date and Time Comment Was Submitted: 2010-04-21 09:23:20



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