Renewable Diesel Technology

Renewable Diesel Subcommittee of the WSDA Technical Work Group

July 25, 2007

Table of Contents
INTRODUCTION......................................................................................................................... 3 EXECUTIVE SUMMARY .......................................................................................................... 4 BIODIESEL AND RENEWABLE DIESEL DEFINITIONS................................................... 8 RENEWABLE DIESEL TECHNOLOGIES ............................................................................. 8 THERMAL HYDROTREATING ........................................................................................................ 8 Co-processing with Petroleum................................................................................................ 8 Bio-only Hydrotreating .................................................................................................... 10 BIOMASS-TO-LIQUID (BTL) ....................................................................................................... 11 PYROLYSIS/RAPID THERMAL PROCESSING ................................................................................ 13 REGISTRATION AND STANDARDS DEVELOPMENT .................................................... 13 EPA REGISTRATION .................................................................................................................. 13 ASTM STANDARD DEVELOPMENT ............................................................................................ 14 NATIONAL CONFERENCE ON WEIGHTS AND MEASURES ............................................................ 15 FEDERAL GOVERNMENT DEFINITIONS OF RENEWABLE DIESEL ........................ 15 DEPARTMENT OF ENERGY.......................................................................................................... 15 ENVIRONMENTAL PROTECTION AGENCY ................................................................................... 15 INTERNAL REVENUE SERVICE .................................................................................................... 16 REFERENCES............................................................................................................................ 17

Tables
Table 1. Summary of Renewable Diesel Technologies .................................................................. 5 Table 2. Comparative Fuel Specifications for ConocoPhillips Renewable Diesel Blends............. 9 Table 3. Summary of Emission Comparisons for Various Blends of NExBTL with Two Base Petro-diesel Fuels on Light-Duty Diesel Vehicles................................................................ 10

Introduction
Over the past year, questions have been raised by members of the Executive Branch and the Legislature regarding non-ester renewable diesel or renewable diesel. This product is a petroleum diesel fuel substitute that is distinctly different than biodiesel and, with regard to the Washington State Renewable Fuel Standard, is not encompassed by the definition of biodiesel in current Washington state law. The Renewable Diesel Subcommittee of the WSDA Biofuels Technical Workgroup was created to review and summarize the technical information regarding renewable diesel. As part of this effort, the Subcommittee has attempted to: identify a working definition for renewable diesel, address technical issues pertaining to production technologies, describe the feedstock utilized by each technology, delineate potential fuel registration and standard development processes, and summarize available fuel emissions, life-cycle information, and toxicity and biodegradability data. The Subcommittee attempted to provide the best available and most up to date information. Because some of the processes used to produce the fuel have been developed by and are under the control of private industries, some information is not yet publicly available. The Subcommittee has purposely refrained from entering into the public policy debate regarding this fuel and has made no recommendations regarding actions. At the same time, we have attempted to address those technical issues that may impact potential public policy. This topic, due to both ongoing technical advancement and public policy debate, is in a state of continual development. In the technical arena, ongoing research and process development will likely have an impact on the potential feedstocks for and future sources of renewable diesel fuel. In addition, considerable discussion is currently taking place on the national stage regarding renewable diesel, especially in regard to an April 2007 ruling by the Internal Revenue Service that expanded the definition of renewable diesel in the Energy Policy Act of 2005. The IRS ruling appears to allow fuel produced by multiple processes to qualify for the one-dollar per gallon tax credit. Legislation has been introduced in the current congressional session to clarify what fuels are eligible for the tax credit. We note this as a reminder that the contents of the current paper are a review of the topic at one point in time and any use of its contents should be supplemented with information that might have arisen or become available since the date of this submission. Mark Brady, Puget Sound Clean Cities Coalition Todd Ellis, Imperium Renewables Ken Kimura, BP John Kim Lyons, Washington State University Extension Energy Program H. Daniel Sinks, ConocoPhillips Jeffrey R. Stephens, Washington Biodiesel

Executive Summary
The State of Washington has recently adopted a Renewable Fuel Standard. Beginning on December 1st, 2008, 2% of the diesel fuel sold in the State by volume will be biodiesel. If certain criteria are satisfied, the required percentage of biodiesel sold in the state would be increased to 5%. The State has defined biodiesel as the monoalkyl esters of long chain fatty acids . Questions have arisen regarding the suitability and applicability of other diesel fuel substitutes that do not meet this definition. We define here renewable diesel as any of several potential diesel fuel substitutes, produced from renewable feedstocks, that chemically are not esters and thus are distinct from biodiesel. The following points regarding renewable diesel alternatives can be ascertained from this report. Several technologies, some in early stages of commercialization, some still in the precommercialization stage, produce diesel substitutes from a variety of renewable plant and/or animal feedstocks. Preliminary performance and emissions testing has been performed on these renewable diesel fuels and, in general, show favorable results. Independent toxicity and biodegradability data, however, are not generally available. Only one of the products has been registered by the EPA as a fuel or fuel additive, a specific requirement prior to introduction as a commercial product. Additional products will likely be introduced as developing technologies are commercialized.

The timeline for deployment of these technologies in the U.S. is open ended. One company is already producing a bio-oil in the U.S. while several other companies have made announcements of their intentions to produce a renewable diesel in the U.S. Changing World Technologies is currently producing a renewable fuel oil substitute at their commercial scale pilot facility in Missouri, with a stated capacity of 10 million gallons/year. Conoco-Philips, in a partnership with Tyson Foods, announced that it would begin production of renewable diesel fuel in the U.S. in 2007, with the stated objective of producing up to 175 million gallons of fuel by 2009. Recently, Dynamic Fuels LLC, a joint venture between Tyson Foods and Syntroleum, announced their intention to build a 75 million gallon per year renewable diesel facility with production commencement targeted for 2010. While other commercial entities have stated an interest in deploying technology in the U.S., no other formal announcements have been made. Table 1 below, provides a summary of the technologies, companies, and important issues, regarding renewable diesel.

Table 1. Summary of Renewable Diesel Technologies Technology Hydrotreating Feedstock Animal fats/vegetable oils co-processed with petroleum diesel Product Hydrocarbon mixture meets ASTM D975 Commercial Entity ConocoPhillips/ Tyson Commercial Status Ireland refinery producing since Dec. 2006. Announced U.S. production to begin in 2007 175 million gals/yr expected by 2009. Australian refinery producing 5% renewable blend. Outstanding Commercial Issues EPA Registration Toxicity and biodegradability testing

Animal fats/vegetable oils co-processed with petroleum diesel

Animal fats/ vegetable oils

Hydrocarbon mixture Meets national fuel quality standards in Australia Hydrocarbon mixture meets ASTM D975

BP

EPA Registration Toxicity and biodegradability testing

Neste Oil

First plant (58 MGPY) opened in Finland in May 2007. Two other EU plants in planning.

EPA Registration Toxicity and biodegradability testing Marketplace use i.e. blend ratio, cetane enhancer, etc.

Animal fats/ vegetable oils

Hydrocarbon mixture

Petrobras (Brasil, H-Bio Technology)

Animal fats

Hydrocarbon mixture

Commercial production to begin at several refineries in Brasil by the end of 2007. Dynamic Fuels Commercial pilot to start (Syntroleum/Tyson) construction in 2008, production in 2010.

Standards Development EPA Registration Economics

GHG life-cycle analysis Toxicity and biodegradability testing

Vegetable oils

Hydrocarbon mixture Hydrocarbon mixture

ENI (UOP Technology) JV with Choren/DaimlerChrysler/VW

Biomass-to-liquid (via gasification/ Fischer-Tropsch)

Cellulosic biomass

Plant to be constructed in Italy, 95 million gals/yr production in 2009. Pilot plant (4.7 MGPY) to open in late 2007.

Cellulosic biomass

Hydrocarbon mixture

Neste Oil/Stora Enso

Pre-commercialization

Cellulosic biomass

Hydrocarbon mixture

Syntroleum

Pre-commercialization

Standards Development EPA Registration Economics GHG life-cycle analysis Toxicity and biodegradability testing Standards Development EPA Registration Economics GHG life-cycle analysis Toxicity and biodegradability testing Standards Development EPA Registration Economics GHG life-cycle analysis

Pyrolysis-Rapid Thermal Processing

Cellulosic biomass, municipal or industrial solid waste

Hydrocarbon mixture

In Research Stage

In Research Stage

Hydrocarbon mixture meets ASTM D 396, can be refined to ASTM D975 ASTM D396 Standard Specification for Fuel Oils

Slaughterhouse waste, other carbon-containing solid waste

Changing World Technologies

Commercial-scale pilot plant in Missouri is producing ~250,000 gallons/mo of fuel from slaughterhouse waste.

Toxicity and biodegradability testing Standards Development EPA Registration Economics GHG life-cycle analysis Toxicity and biodegradability testing 1. Marketplace use i.e. heating fuel, refining to transportation fuel.

ASTM D975 Standard Specification for Diesel Fuel Oils

Biodiesel and Renewable Diesel Definitions

While there is considerable discussion about renewable diesel, there is no universally accepted definition or technical standard that exists for this emerging fuel. There are multiple technologies that produce a product that has been called renewable diesel fuel. While some of these technologies are in commercial production, others are still in the research and development phase, years away from producing commercially available product. The different technologies use widely different feedstocks, including wood biomass, slaughterhouse waste, tallow, and recycled or virgin vegetable oil. One commonality of these fuels is that they are not biodiesel, which is defined in Washington State law as the monoalkyl esters of long chain fatty acids derived from plant or animal matter that meet the registration requirements for fuels and fuel additives established by the federal environmental protection agency and standards established by the American society of testing and materials. Biodiesel is produced via a reaction of vegetable oil or animal fat with an alcohol (usually methanol) and a catalyst. Biodiesel is chemically distinct from petroleum diesel and has a separate ASTM standard (D6751), which specifies the standard for biodiesel for use as a blend component with petroleum diesel. Biodiesel has passed the EPA Tier I and Tier II health-effects testing, and is registered with the EPA as a fuel additive. For the purposes of this discussion, renewable diesel will refer to any of several diesel fuel substitutes, produced from renewable feedstocks, that chemically are not esters and thus are distinct from biodiesel.

Renewable Diesel Technologies

Thermal Hydrotreating Hydrotreating is a process traditionally used by petroleum refineries to remove sulfur impurities from diesel fuel. Renewable diesel produced using this process can either be produced in a bio-only unit that uses only vegetable oils or animal fats as feedstock or where oils or fats are co-processed with the distillate fractions (diesel fuel) derived from petroleum. Both processes produce a mixture of hydrocarbons that has been reported to meet the ASTM standard for petroleum diesel (D975). The renewable diesel fuel produced through these processes, consequently, could utilize the existing infrastructure currently used for blending and transporting petroleum fuels. Any fuels containing the products produced from either process must be registered with the EPA as a fuel or fuel additive before being sold as diesel fuel in the U.S. Co-processing with Petroleum Producing a renewable diesel fuel by co-processing fats/oils with petroleum is exemplified by the process developed by Conoco-Phillips (COP). COP has been hydrotreating a soy oil/diesel fuel combination at a conventional crude oil refinery in Ireland since late 2006.1 Recently, the company announced plans to bring this process to the US and has entered into a partnership with Tyson Foods to use tallow in several of its refineries to produce up to 175 million gallons of renewable diesel per year.2 According to Tyson Foods, the current uses of the tallow

expected to be used to produce renewable diesel are cosmetics, soaps, candles, and some pet food. The companies expect to begin producing the fuel in 2007 and be at a capacity of 175 million gallons by early 2009. The locations of the refineries that will produce the fuel have not been announced. The renewable diesel fuel produced by the COP hydrotreating process is a mixture of saturated hydrocarbons, with properties similar to diesel fuel, that meet ASTM D975. The process also produces propane, carbon dioxide, and water from the oil/fat feedstock. The cetane number of the fuel is higher than petroleum diesel and the sulfur and aromatics content are essentially zero. As with biodiesel, however, it appears to have less desirable cold flow properties, which may be improved through alternative processing. Additional benefits assigned to the fuel include: a high level of quality control; meets ASTM D975; can be blended with biodiesel; and can be used in existing pipelines and trucking infrastructure. Unlike biodiesel and similar to petroleum-based ultra-low sulfur diesel (ULSD), the COP renewable diesel requires a lubricity additive. Table 2. Comparative Fuel Specifications for ConocoPhillips Renewable Diesel Blends
Base 5% Ren 10% Ren 20% Ren Property ASTM D975 Fuel Content Content Content T90, F 540-640F 559 565 568 571 Visc. (mm2/s at 20C) 1.9-4.1 2.3 2.3 2.4 2.4 Ash, mass % 0.01 max <0.001 <0.001 <0.001 <0.001 Sulfur (ppm) 15 max 5 6 6 8 Copper Strip 3 max 1A 1A 1A 1A Corrosion Cetane number 40 min. 41.2 45.8 47.4 51.2 Ramsbottom Carbon 0.35 %max <0.1 <0.1 <0.1 <0.1 Lubricity 520m max. 591 598 603 597 Cloud Point, F Seasonal/Regional -9 3 8 14 Pour Point, F Seasonal/Regional -24 -6 0 6 Note 1: Renewable diesel fuels shown here are not commercially optimized for illustration only Note 2: Feedstock is soy oil, results for non-soy feedstocks are similar. Source: Kaufman, J., Cononco Phillips, SAE Government/Industry Meeting, May 15, 20073 30% Ren Content 577 2.4 <0.001 5 1A 54.2 <0.1 586 17 9

COP has completed some preliminary environmental testing. EPA Transient Cycle tests were completed on a 2006 International 6.0 L V8 engine. In these tests non-optimized, low concentration renewable diesel blends (5%-30%) produced from soy oil showed reductions in most of the criteria pollutants. For a 20% blend, non-methane hydrocarbon (NMHC) emissions were reduced by about 50%, NOx emissions were about 8% lower, and CO emissions dropped by about 60% when compared to the base diesel fuel. PM emissions showed only a slight decrease over the base diesel fuel, and did not improve with higher blend concentrations. Emission testing of non-soy renewable diesel (beef tallow, canola, poultry fat and yellow grease) was also conducted. While the emissions from these feedstocks varied, (both up and down) when compared to the soy renewable diesel, they all showed lower emissions when compared to the baseline diesel fuel.3 Relative CO2 lifecycle emission analysis was also performed, although the specific analytical technique used was not available. In the analysis, relative lifecycle emissions for the soy based

R100 COP fuel was estimated at 44%, as compared to petroleum diesel at 100%. B100 fuel was estimated at 59% in this analysis. The GREET model, which is currently the industry standard for completing lifecycle analysis was not used in this analysis because at the time the GREET model did not have a renewable diesel pathway. Work is underway, however, by Argonne National Labs to complete a lifecycle analysis using the GREET model with the capability to analyze renewable diesel. Additionally, in Brasil, Petrobras has what it calls the H-BIO process, which blends vegetable oil with petroleum distillate in hydrotreating units to make renewable diesel.4 BP also has a project in Australia to produce renewable diesel with 5% renewable content via hydrotreating of tallow.5 Neither company has announced plans for construction of plants in the U.S. Bio-only Hydrotreating Neste Oil, a company that is 50% owned by the Finnish government, has developed a bio-only process that produces non-ester renewable diesel fuel through its NExBTLTM technology, a thermal/hydrotreating process.6 The process uses vegetable oils and/or animal fats as sole feedstock. The fuel, which is a mixture of hydrocarbons similar to petroleum diesel fuel, is essentially sulfur, oxygen, nitrogen and aromatic free. It can be combined with petroleum diesel at any blend level but requires a lubricity additive, as do very low sulfur petroleum diesels. The production process can apparently be adjusted to produce a fuel with a cloud point anywhere between -5o C and -30o C. The following table is a summary of the results of a study of the regulated emissions in three different light-duty vehicles using blends (5%-85%) of the NExBTL fuel with and relative to a European diesel fuel (6 ppm sulfur) and a Swedish diesel fuel (1 ppm sulfur).7 Table 3. Summary of Emission Comparisons for Various Blends of NExBTL with Two Base Petro-diesel Fuels on Light-Duty Diesel Vehicles Emission Type 85% CO HC PM NOx average -30% average -40% no sig. difference no sig. difference Blend Level with Euro Diesel 20% average -15% average -20% minor to no reductions no sig. difference Blend Level with Swedish Diesel

5% 5 & 15% minor to no 5%: no sig. difference reductions 15%: ~ - 5% no sig. difference no sig. difference no sig. difference no sig. difference no sig. difference no sig. difference

sig. = significant

These results suggest that using blends at 20% or above could result in reductions of CO and HC, but not PM or NOx. Additional testing on heavy-duty truck engines, however, showed a NOx reduction of 15% and PM reduction of more than 25%, along with a 20% HC reduction and a 5-10% CO reduction for a 100% NExBTL fuel when compared to Euro Diesel. Because

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of the high cetane number and low sulfur content of the NExBTL fuel, Neste is suggesting that the fuel might be used to upgrade off-specification petroleum diesel. It is unknown what air quality benefits, if any, would result should the NExBTL fuel be used for this purpose. A relative life cycle analysis, commissioned by Neste and performed by the Institute for Energy and Environmental Research in Heidelberg, reported a 35%-60% decrease in CO2equivalent greenhouse gas (GHG) emissions relative to petroleum diesel.8 Neste inaugurated its first commercial-scale plant in Porvoo, Finland in May 2007. The plant has a capacity of about 170,000 metric tons (~ 53 million gallons) of fuel per year. A second plant has been approved for Finland and a third is planned for Austria. The company has said it is looking for a potential location and collaborators in the U.S. Neste has reported that the fuel meets ASTM D975, claims that the fuel thus will not need a separate ASTM standard and that no action is required of The National Conference of Weights and Measures. It appears they will elicit a comment from the National Conference stating that the standard practices apply. The company also states that it intends to comply with EPA testing and registration prior to introduction of the fuel into the U.S. market. The length of the EPA registration process is not expected to be problematic since, according to the company, permitting and construction of a facility would likely be the limiting factor to introduction into the U.S. market. No announcements have been made regarding plant construction in the U.S. Consequently, using realistic expectations the earliest the fuel might be available in the U.S. would be 2010 or 2011. Dynamic Fuels, a joint venture between Tyson Foods and Syntroleum, has recently announced plans to construct a 75 million-gallon per year facility to produce renewable diesel using catalytic hydrotreating of fats and oils feedstock, with production expected in 2010.9 The fuel produced from this process is presumably similar in composition to the NExBTL fuel produced by the Neste process. UOP, a Honeywell company, also recently announced that ENI, an Italian refining company intends to build a production facility at an existing refinery in Italy using UOP catalytic hydrotreating technology to convert vegetable oils to renewable diesel. It is expected to begin production in 2009, at a capacity of about 95 million gallons per year.10 Biomass-to-liquid (BTL) Another process for making a renewable diesel fuel is to convert biomass (predominantly cellulosic material) through high-temperature gasification into synthetic gas or syngas, which is a gaseous mixture rich in hydrogen and carbon monoxide, and then use a FischerTropsch process to catalytically convert the syngas to liquid fuel. This technology has been applied to coal (coal-to-liquids, or CTL, fuel) and natural gas (gas-to-liquids, or GTL, fuel)11, and can also be applied to biomass (biomass-to-liquid, or BTL, fuel).12 DOEs National Renewable Energy Laboratory (NREL) is working extensively on BTL fuel. The BTL

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renewable diesel product has not yet been recognized as an alternative fuel under the Energy Policy Act (EPAct). Technologies to produce BTL fuel are, for the most part, still in the research and development stages, and thus further from commercialization than renewable diesel made by processing oils and/or fats via hydrotreating. The most commercially advanced BTL process is probably from Choren, which is working with Shell, Daimler-Chrysler and VW on a BTL fuel it calls SunDiesel.13 The process uses cellulosic materials to produce a diesel-like fuel. Choren plans to open an industrial-scale 15,000 ton/yr (4.7 million gallons/yr) pilot plant later this year in Freiberg, Germany. Neste Oil and Stora Enso, a Finnish paper products company, have recently announced a joint venture with the intention of building a pilot facility to convert forest product residue into renewable fuel.14 Syntroleum, which has a long history of Fischer-Tropsch research, is also working on BTL processes from cellulosic feedstock. Researchers from DOE compared how the BTL fuel SunDiesel performed relative to conventional diesel.14 The tests were done on a light-duty 1999 Mercedes sedan as well as a Caterpillar heavy-duty, single-cylinder research engine. The technical highlights are that SunDiesel, when compared to petroleum diesel, has much lower aromatics and sulfur (although this analysis was completed before the introduction of ultra-low sulfur diesel) less odor and some drivability improvement very similar pour point and cloud point significant reductions in most exhaust emissions hydrocarbons (HC), carbon monoxide (CO) and particulate matter (PM) for the light duty engine varying reductions of nitrogen oxides (NOx) in almost all of the data for the lightduty engine (see further discussion of SunDiesel and NOx emissions in the paragraph below) reductions of NOx and PM for the heavy-duty, single-cylinder engine 10% less CO2 tailpipe emissions less energy per unit volume slightly lower fuel economy As with biodiesel, SunDiesel shows complicated results when it comes to NOx emissions. In this study, SunDiesel generally shows a NOx reduction (~3.5% to 18%) when compared to conventional diesel. The testing, however, shows a consistent NOx increase in the range of 4.4% in the urban portion of the European Drive Cycle (NEDC). The authors state that their results are intriguing, in particular because of the results of an earlier study. This study, which the authors say was a more complete study of a Fischer-Tropsch diesel with fuel properties very similar to SunDiesels, showed a slight increase in NOx emissions compared to conventional diesel. Furthermore, yet another study, an earlier literature review conducted by NREL, showed declines on average in NOx emissions from Fischer-Tropsch diesels. As the authors of this paper note, additional testing, especially with a variety of engines and vehicles, is needed to validate whether or not SunDiesel reduces NOx emissions. 12

Pyrolysis/Rapid Thermal Processing Yet another technique for producing renewable diesel uses pyrolysis or other thermal conversion process (TCP) to convert biomass or other carbon-containing material (municipal solid waste, plastics, industrial residue etc.) to a bio-oil that is then refined into diesel-like fuel. Pyrolysis/TCP uses a thermal decomposition process with high heat transfer rates and a short residence time to convert the large polymers, i.e. cellulose, hemicellulose, lignin, and proteins of biomass or organic waste streams into smaller molecules. Under these conditions, organic vapors, pyrolysis gases, and charcoal are produced from biomass. The vapors are condensed to produce pyrolysis oil (often referred to as bio-oil). Yields of liquid products, as high as 79 % of the initial dry weight of the biomass, can be achieved. Federal labs are involved in research on Pyrolysis/TCP processes.16 Changing World Technologies has a TCP facility in Carthage, Missouri that produces bio-oil from turkey and pig slaughterhouse waste.17 The bio-oil produced by the Changing World Technology process purportedly meets ASTM D396, the standard for petroleum fuel oil and has been approved as a diesel fuel additive, but must be further refined to meet ASTM 975, the standard for transportation fuel.18 Although gasification and pyrolysis technologies are still striving for commercialization, they offer the potential to convert large volumes of cellulosic biomass or organic waste into liquid fuels and feeds. As a result, the federal labs are focusing the majority of their efforts on helping to commercialize these technologies and have significantly reduced their support of biodiesel research, which they consider technologically mature

Registration and Standards Development

EPA Registration Because renewable diesel products are not derived from petroleum, they will require EPA registration. The Clean Air Act provides EPA with the authority to regulate fuels and fuel additives in order to reduce the risk to public health. The regulations at 40 CFR Part 79 require that each manufacturer or importer of gasoline, diesel fuel, or a fuel additive, have its product registered by EPA prior to its introduction into commerce.18, 19 Registration involves providing a chemical description of the product and certain technical, marketing and health-effects information. This allows EPA to identify the likely combustion and evaporative emissions. In certain cases, health-effects testing is required for a product to maintain its registration or before a new product can be registered. EPA uses this information to identify products whose emissions may pose an unreasonable risk to public health, warranting further investigation and/or regulation. The registration requirements are organized in a three-tier structure. In general, standard mandatory requirements are contained in the first two tiers, while the third tier provides for additional testing on a case-by-case basis. As part of the requirements of Tier 1, fuel and fuel

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additive (F/FA) manufacturers are to perform a literature search on the health and welfare effects of their product. Tier 1 also includes emission characterization requirements. Manufacturers are responsible for generating, collecting, and sampling the combustion emissions and, if applicable, the evaporative emissions of their F/FAs, and for conducting tests to determine the identity and concentration of individual emission products. The Tier 1 process can take up to 6 months, but is generally completed in less time. As soon as an applicant submits Tier 1 data to EPA, the registration becomes public. Tier 2 consists of testing requirements designed to detect potential adverse health effects related to the inhalation of F/FA emissions. Typically this requirement involves exposure of laboratory test animals to the product emissions and an evaluation of the effects of this exposure. The test requirements of Tier 2 also include a 90-day subchronic inhalation study with additional tests to screen for possible carcinogenicity, mutagenicity, teratogenicity, reproductive toxicity, and neurotoxicity effects. Tier 2 testing can take upwards of 18 months. An applicant can petition EPA to waive the requirements for Tier 2 testing if the emissions products identified in Tier 1 are the same as emission products obtained from testing/registration of a previous fuel and or fuel additive. In this instance, the applicant would argue that the Tier 2 results from the earlier registration tests would yield similar results. This is a probable pathway for applicants registering renewable diesel. When Tier 1 and Tier 2 are complete, manufacturers submit the results to EPA for evaluation. EPA will then determine whether further testing and/or analysis for the subject F/FA is needed under the provisions of Tier 3. ASTM Standard Development ASTM is an international standards development organization that publishes standards that are developed through an industry-voluntary consensus process. An ASTM Standard Specification defines the requirements for a specific product. While the ASTM Standard Specification development is a voluntary process, ASTM Standard Specifications have been adopted, by incorporation or reference, in many municipal, state, and federal government regulations and are mandatory. Currently there are ASTM Standard Specifications for petroleum diesel fuel (ASTM D975), petroleum fuel oil (ASTM D396), and biodiesel used as a blend component (ASTM D6751). Several of the renewable diesel products have been reported to meet ASTM D975, and thus their producers will not likely petition for a separate standard. Should a separate Standard Specification be requested, the process requires an ASTM Task Group to draft documents that define the Standard Specification. The drafted Specification is peer-reviewed by one of the ASTM Technical subcommittees, the Main Subcommittee, and the entire Society through a rigorous, tiered balloting process. If approved at each level, the Specification would be adopted, following a final review by the Committee on Standards. The entire process can be time consuming depending on whether redrafting of the Specification is required. Generally the Main Subcommittees have balloting about twice a year, so any redrafting would result in lags of several months to a year before re-balloting would occur.

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National Conference on Weights and Measures If a new fuel is introduced and an ASTM standard is developed and approved by ASTM, then that standard is sent to National Conference of Weights and Measures (NCWM) petroleum subcommittee for review. Once they have completed their review they can pass it out of committee, reject it, or sit on it. Once passed out of committee, it is then voted on by the National Conference. If passed, the new standard is placed into the NIST Handbooks. The process works almost identical to our federal legislative process. The National Conference of Weights and Measures meets once a year, thus the minimum time for the process would be approximately 1 year.

Federal Government Definitions of Renewable Diesel

Department of Energy The Department of Energy (DOE) appears to support a broad definition of renewable diesel when it comes to tax credit purposes. DOE staff indicated as much in responses to inquiries about renewable diesel. This is supported by the position taken by the Internal Revenue Service (IRS), described below, at which the IRS says it arrived through consultation with DOE. A definition of and tax credit for renewable diesel were included in Energy Policy Act (EPAct) of 2005. The definition is repeated here:20
The term renewable diesel means diesel fuel derived from biomass (as defined in section 45K(c)(3)) using a thermal depolymerization process which meets (A) the registration requirements for fuels and fuel additives established by the Environmental Protection Agency under section 211 of the Clean Air Act (42 U.S.C. 7545), and (B) the requirements of the American Society of Testing and Materials D975 or D396.

When this bill was initially considered, the tax credit was only to apply to a particular process of one company. After passage of the act, there were discussions about broadening the definition of renewable diesel and thermal depolymerization to include processes of other companies. Although no formal position has been announced, DOE appears to have recommended that the broad definition be used. Environmental Protection Agency The Environmental Protection Agency (EPA) recently issued its final rule on the federal renewable fuel standard (RFS).21 Ultimately, EPA decided to include renewable diesel as one of two parts of its definition of biodiesel. One part of the definition corresponds to the common definition of biodiesel as a monoalkyl ester; the other part is for non-ester renewable diesel. (References to the page numbers of the final rule that are most relevant to this discussion can be found in the reference list.22) As part of rulemaking for the RFS, EPA had to define what it considers to be a renewable fuel. EPA wanted to use a broad definition so that todays fuels as well as potential future fuels, provided they met certain requirements, would count as renewable fuels. EPA did specifically list several renewable fuels in its rule and included both biodiesel (mono-alkyl esters) and 15

non-ester renewable diesel in this list. In addition, EPA made a distinction between traditional biodiesel and renewable diesel in terms of equivalence values, which are used to determine how to add volumes of different fuels together for purposes of RFS tracking. Biodiesel (mono-alkyl esters) has an equivalence value of 1.5; non-ester renewable diesel has an equivalence value of 1.7. This reflects the fact that EPA contends that renewable diesel has a higher energy content than traditional biodiesel. EPA elaborates on its definition of biodiesel in section III. B. 2. (p. 23917) of the final rule. In that section, entitled What is Biodiesel?, the agency says it chose a two-part definition in order to adhere to the definition of biodiesel in EPAct of 2005 while still recognizing the unique history and role of mono-alkyl esters meeting ASTM D-6751 EPAs sub-definition of nonester renewable diesel in this section states that the term refers to a motor vehicle fuel or fuel additive that: 1) meets the registration requirements for fuels and fuel additives established by the Environmental Protection Agency under section 7545 of this title (Clean Air Act Section 211); 2) is not a mono-alkyl ester; 3) is intended for use in engines that are designed to run on conventional, petroleum-derived diesel fuel, and 4) is derived from nonpetroleum renewable resources. Current examples of a non-ester renewable diesel include: renewable diesel produced by the Neste or UOP process, or diesel fuel produced by processing fats and oils through a refinery hydrotreating process. Nonpetroleum renewable resources are plant oils, animal fats, waste and other waste materials, municipal solid waste, and wastewater sludge and oils. Lastly, EPA discusses renewable crude and renewable crude-based fuels in the RFS rule. Renewable crude refers to liquid feedstocks that are derived from biological sources for processing in refineries. This processing is expected to happen in one of three ways. First, the refineries or a portion of a refinery could be dedicated solely to processing renewable crude; e.g., the Neste process. Next, the refineries could be traditional petroleum refineries in which the renewable crude is coprocessed with petroleum-based feedstocks. Third, the processing could mean running fats and/or oils through a refinerys hydrotreater (see ConocoPhillips partnership with Tyson Foods). The fuels resulting from these processes are called renewable crude-based fuels and are considered to be essentially the same as petroleum gasoline and diesel. EPA counts these fuels toward the RFS requirements. In the case that a renewable crude is processed with petroleum-based feedstocks, EPA counts the volume of renewable crude that was input into the process rather than trying to account for the volume of renewable fuel that resulted from the process. Internal Revenue Service The Internal Revenue Service (IRS) has issued a notice on renewable diesel that basically puts it on par with agri-biodiesel in terms of the blenders tax credit. That is, renewable diesel is eligible for the same $1/gal tax credit as agri-biodiesel. The IRS says it relied on input from DOE to reach its decision and came to the conclusion that the process of thermal depolymerization

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should be broadly defined. This broad definition would include any process that uses heat and pressure with or without catalysts to convert long-chain polymers into short-chain hydrocarbons. Thus, fuel derived from biomass using thermal depolymerization, even if it is co-processed with petroleum fuel, is considered renewable diesel by the IRS. Under this definition traditional petroleum refineries might be eligible for the tax credit on the portion of the finished fuel that can be traced back to a biomass feedstock. The IRSs full definition of renewable diesel is provided below.23 Section 2. RENEWABLE DIESEL; RENEWABLE DIESEL MIXTURE (a) Renewable diesel--(1) In general. Renewable diesel means diesel fuel that-(i) Is derived from biomass (as defined in 45K(c)(3)) using a thermal depolymerization process; (ii) Meets the registration requirements for fuels and fuel additives established by the Environmental Protection Agency (EPA) under section 211 of the Clean Air Act (42 U.S.C. 7545); and (iii) Meets the requirements of the American Society of Testing and Materials (ASTM) D975 or D396. (2) Thermal depolymerization is a process for the reduction of complex organic materials through the use of pressure and heat to decompose long-chain polymers of hydrogen, oxygen, and carbon into short-chain hydrocarbons with a maximum length of around 18 carbon atoms. A process may qualify as thermal depolymerization even if catalysts are used in the process.

References 1) ConocoPhillips Begins Production of Renewable Diesel Fuel at Whitegate Refinery in Cork, Ireland, http://www.conocophillips.com/newsroom/news_releases/2006+News+Releases/121906. htm 2) ConocoPhillips and Tyson Foods Announce Strategic Alliance To Produce Next Generation Renewable Diesel Fuel, http://www.conocophillips.com/newsroom/news_releases/2007+News+Releases/041607. htm 3) Kaufman, J., Manager Fuel & Vehicle Trends, Conoco-Philips Renewable Diesel, SAE Government/Industry Meeting, May 15, 2007 4) Petrobras H-Bio Process, http://www2.petrobras.com.br/tecnologia/ing/hbio.asp 5) BP Renewable Diesel project in Australia, http://www.bp.com/sectiongenericarticle.do?categoryId=9012389&contentId=7017889 6) Neste Oil NExBTLTM technology, http://www.nesteoil.com/default.asp?path=1,41,535,547,3716,3884

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7) Rantanen, Leena and Raimo Linnaila, Neste Oil Corporation, and Paivi Aakko and Tiina Harju, Technical Research Centre of Finland. NExBTL Biodiesel fuel of the second generation. SAE Technical Paper 2005-01-3771. 2005. 8) Reinhardt, G., S. O. Grtner, G.H. Helms, G.N. Rettenmaier. An Assessment of Energy and Greenhouse Gases of NExBTL. June, 2006. 9) Tyson Foods and Syntroleum Launch Renewable Fuels Venture, http://www.syntroleum.com/proj_rba_biofining.aspx 10) UOP and ITALYS ENI S.p.A. announce plans for facility to produce diesel fuels form vegetable oil, http://www.uop.com/pr/releases/PR.EniEcofiningFacility.pdf 11) National Renewable Energy Lab, gas-to-liquid technology, http://www.nrel.gov/vehiclesandfuels/npbf/gas_liquid.html 12) National Renewable Energy Lab, biomass gasification technology, http://www1.eere.energy.gov/biomass/gasification.html 13) Choren SunDiesel, http://www.choren.com/en/energy_for_all/sundiesel/ 14) Stora Enso and Neste Oil to join forces in biofuel development, http://www.storaenso.com/CDAvgn/main/0,,1_EN-8276-17221-,00.html 15) Ng, Henry and Munidhar Biruduganti, Argonne National Laboratory, and Kevin Stork, US DOE. Comparing the Performance of SunDiesel and Conventional Diesel in a Light-Duty Vehicle and Heavy-Duty Engine. SAE Technical Paper 2005-01-3776. October 2005. 16) Department of Energy, Pyrolysis and other Thermal Processing, http://www1.eere.energy.gov/biomass/pyrolysis.html 17) Changing World Technologies, http://www.changingworldtech.com/ 18) EPA listing of approved fuels and fuel additives http://www.epa.gov/otaq/regs/fuels/additive/web-dies.htm 19) Title 40--Protection of Environment, Chapter 1 Environmental Protection Agency, Part 79 Registration of Fuels and Fuel Additives, http://www.access.gpo.gov/nara/cfr/waisidx_01/40cfr79_01.html 20) EPAct 2005 http://frwebgate.access.gpo.gov/cgibin/getdoc.cgi?dbname=109_cong_public_laws&docid=f:publ058.109 21) (EPA) final rule on the federal renewable fuel standard (RFS) http://www.epa.gov/otaq/renewablefuels/rfs-finalrule.pdf.

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22) EPA final rule on federal renewable fuel standard, http://www.epa.gov/otaq/renewablefuels/rfs-finalrule.pdf

Most relevant sections from EPAs final RFS rule with page numbers: II. B. 3. What Qualifies as a Renewable Fuel? (p. 23909) II. B. 4. Equivalence Values of Different Renewables Fuels (p. 23909) III. B. 2. What is Biodiesel? a. Biodiesel (Mono-Alkyl Esters) b. Non-Ester Renewable Diesel (p. 23917) III. B. 3. Does Renewable Fuel Include Motor Fuel That is Made From Coprocessing a Renewable Feedstock With Fossil Fuels? (p. 23917-8) 80.1101 Definitions. (p. 23993) 80.1115 How are equivalence values assigned to renewable fuel? (p. 23995)

23) IRS Renewable Diesel, Notice 2007-37; http://www.irs.gov/pub/irs-drop/n-07-37.pdf.

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