PHMSA wants comments on biofuel pipeline transport

The Pipeline Hazardous Materials and Safety Administration (PHMSA) is looking at ways to transport biofuels via pipelines, and is seeking comments on the agency's efforts to identify and address the short-, medium-, and long-term opportunities and challenges that are associated with transporting those products, according to information in the Federal Register August 10.

The notice points out that most ethanol in use today is transported from production or import locations by highway, rail, and/or barge and blended with gasoline at or near the point of retail distribution. To sustain market growth needed to meet current targets, PHMSA believes that pipelines must be an option for high-volume transportation of biofuel products, according to the Federal Register information.

PHMSA said in the notice that it considers all biofuel-gasoline blends to be petroleum products, within the meaning of 49 CFR 195.2, regardless of their relative biofuel/gasoline content. Accordingly, any pipeline used to transport such blends, whether in batches or in dedicated infrastructure, would be subject to PHMSA's existing standards for hazardous liquid pipelines.

Unblended ethanol and other biofuels produced by biological fermentation and vegetable- and animal-oil based biodiesel products are not petroleum products, as PHMSA has defined the term (49 CFR 195.2). However, based on their physical properties, these substances clearly meet the alternative definition of hazardous liquid under 49 USC 60101(a)(4)(B), PHMSA stated.

PHMSA is considering whether it is necessary to amend the definition of hazardous liquid in 49 CFR 195.2 to expressly include ethanol and biofuels. Such an amendment would confirm that the transportation of pure ethanol or biofuels by dedicated biofuel pipelines is subject to Part 195. If biofuels will always be denatured by blending them with petroleum products prior to transporting them by pipeline, however, amending this regulatory definition may be unnecessary. Accordingly, PHMSA invites comments on whether the agency should amend 49 CFR Part 195 to expressly include (non-blended) ethanol and biofuels in the definition of hazardous liquid. The PHMSA also seeks comments on whether any of the existing requirements for hazardous liquid pipelines in Part 195 should not apply to ethanol and biofuel pipelines and if not, why not. The agency also invites comments on whether there is a need for any requirements to specifically address pipelines transporting ethanol and biofuels.

PHMSA stated in the notice that a large pipeline can transport roughly two million barrels of gasoline per day. By way of comparison, 9,375 tank trailers are required to transport two million barrels of product. It takes 24 100-car unit trains extending three miles each, or 10 15-unit barge tows, to transport two million barrels. Trucks, vessels, and trains consume diesel or other liquid fuels and also contribute to traffic congestion. Pipeline transportation has a consistently lower accident rate than other modes.

Design Standards

PHMSA is working with other federal agencies and a broad enterprise of stakeholders--including industry, standards organizations, and emergency responders--to ensure that adequate design and operating standards for biofuel pipelines are in place or, if necessary, can be further developed in accordance with current pipeline data and technology.

The American Petroleum Institute (API) and the Association of Oil Pipe Lines (AOPL) have provided PHMSA with information on their progress analyzing safety and integrity issues associated with biofuel pipelines and shared a proposed research agenda with PHMSA and other agencies.

The PHMSA has begun a technical assessment with the Pipeline Research Council International on the potential for ethanol induced stress corrosion cracking in existing pipeline infrastructure used to transport ethanol and various ethanol blended fuels. PHMSA also noted operational issues, including the performance of seals, gaskets, and internal coatings.

The risk of product contamination is also a significant factor, according to the information. PHMSA said it understands that the industry is concerned about the ability of transported gasoline-ethanol blends to meet the ASTM specification for gasoline, D 4814--Standard Specification for Automotive Spark-Ignition Engine Fuel due to ethanol's sensitivity to water. The US pipeline system is a "wet system" with moisture introduced from the transport of various products. Unless measures are undertaken to remove or control moisture in the system, ethanol and ethanol blends could potentially absorb water and arrive at destination off specification.

Additionally, many pipeline segments may need to undergo preparatory cleaning to remove built up lacquers, gums, and deposits in the system. Otherwise, the solvency effect of ethanol could remove such deposits, potentially contaminating the ethanol and trailing products in the system.

However, PHMSA said that the issues are challenging, but they are not insurmountable. Research and development focusing on metallurgical, operational, and maintenance issues should aid in their resolution and will build confidence in the use of pipelines as the primary carrier of large volumes of gasoline-ethanol blends.

PHMSA said it would partner with other agencies, standards organizations, and private industry to coordinate research projects to avoid redundant efforts. The research strategy put forward by API and AOPL, for example, suggests an approach that:

• Identifies which blends can be moved in existing systems with little or no modification to the system;

•Identifies which blends can be moved in existing systems with appreciable modifications;

•Identifies which blends cannot be practically moved in existing systems but could be moved in specially designed new transmission or short-haul distribution systems.

PHMSA also wants to know what pipeline system modifications are needed that address the unique risks associated with biofuels without rendering the pipeline unsuitable for transporting traditional energy commodities and which blends cannot be practically transported in pipelines without a major overhaul.

Response Issues

In addressing emergency response issues, PHMSA pointed out in the notice that it had issued a Safety Alert in June 2006 to provide emergency responders with guidance on appropriate procedures for responding to incidents involving fuel mixtures containing ethanol. (Click here to see that alert). In addition, PHMSA will publish and distribute an updated Emergency Response Guide in early 2008. The updated guide will include appropriate guidance for the initial response to incidents involving ethanol-gasoline mixtures and also will include information on pipeline markers.

PHMSA said that ethanol is a highly flammable liquid with explosive limits in the range of 3.5 percent to 19 percent in air and a flash point of 54 degrees Fahrenheit. (By comparison, the explosive range for natural gas varies between five and 15 percent in air. Substances with a flash point lower than 100 degrees Fahrenheit are considered flammable.) The flash point of an ethanol-water mixture increases as ethanol is diluted with water. The flash point of an 80 percent ethanol/water mix is about 75 degrees Fahrenheit, and for 70 percent ethanol-water mix is about 84 degrees Fahrenheit. Ethanol vapors are also combustible, heavier than air, and may form an explosive mixture when combined with air. Similar to highly volatile liquids, ethanol vapors may travel considerable distances to sources of ignition and flash back.

Deadline for submitting comments is September 10, 2007, and should also include comments on technical issues, adequacy of standards, and research and development needs associated with the transportation of biofuels by pipeline.

To see this notice in the Federal Register,, click here.

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