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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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