Renewable Diesel White Paper Final

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Renewable Diesel Technology

Renewable Diesel Subcommittee of the WSDA Technical Work Group

July 25, 2007


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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

EPAREGISTRATION .................................................................................................................. 13

ASTMSTANDARD 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 BasePetro-diesel Fuels on Light-Duty Diesel Vehicles................................................................ 10

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Introduction

Over the past year, questions have been raised by members of the Executive Branch and theLegislature regarding non-ester renewable diesel or renewable diesel. This product is apetroleum 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 ofbiodiesel in current Washington state law. The Renewable Diesel Subcommittee of the WSDABiofuels Technical Workgroup was created to review and summarize the technicalinformation 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 underthe control of private industries, some information is not yet publicly available.

The Subcommittee has purposely refrained from entering into the public policy debate regardingthis fuel and has made no recommendations regarding actions. At the same time, we haveattempted 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 willlikely 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 regardingrenewable diesel, especially in regard to an April 2007 ruling by the Internal Revenue Servicethat expanded the definition of renewable diesel in the Energy Policy Act of 2005. The IRSruling appears to allow fuel produced by multiple processes to qualify for the one-dollar pergallon tax credit. Legislation has been introduced in the current congressional session to clarifywhat fuels are eligible for the tax credit. We note this as a reminder that the contents of thecurrent paper are a review of the topic at one point in time and any use of its contents should besupplemented with information that might have arisen or become available since the date of thissubmission.

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

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4

Executive Summary

The State of Washington has recently adopted a Renewable Fuel Standard. Beginning onDecember 1st, 2008, 2% of the diesel fuel sold in the State by volume will be biodiesel. Ifcertain 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 fattyacids . Questions have arisen regarding the suitability and applicability of other diesel fuelsubstitutes that do not meet this definition.

We define here renewable diesel as any of several potential diesel fuel substitutes, producedfrom 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 pre-commercialization 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 andbiodegradability data, however, are not generally available.

Only one of the products has been registered by the EPA as a fuel or fuel additive, aspecific requirement prior to introduction as a commercial product.

Additional products will likely be introduced as developing technologies arecommercialized.

The timeline for deployment of these technologies in the U.S. is open ended. One company isalready 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 WorldTechnologies is currently producing a renewable fuel oil substitute at their commercial scalepilot facility in Missouri, with a stated capacity of 10 million gallons/year. Conoco-Philips, ina partnership with Tyson Foods, announced that it would begin production of renewable dieselfuel in the U.S. in 2007, with the stated objective of producing up to 175 million gallons offuel by 2009. Recently, Dynamic Fuels LLC, a joint venture between Tyson Foods andSyntroleum, announced their intention to build a 75 million gallon per year renewable dieselfacility with production commencement targeted for 2010. While other commercial entitieshave stated an interest in deploying technology in the U.S., no other formal announcementshave been made.

Table 1 below, provides a summary of the technologies, companies, and important issues,regarding renewable diesel.


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Table 1. Summary of Renewable Diesel Technologies

Technology Feedstock Product Commercial Entity Commercial Status

Animalfats/vegetable oils

co-processed withpetroleum diesel

Hydrocarbonmixture

meets ASTMD975

ConocoPhillips/Tyson

Ireland refineryproducing since Dec

2006. Announced Uproduction to begin 2007 175 milliongals/yr expected by2009.

Animalfats/vegetable oilsco-processed withpetroleum diesel

Hydrocarbonmixture Meets nationalfuel qualitystandards inAustralia

BP Australian refineryproducing 5% renewblend.

Animal fats/vegetable oils

Hydrocarbonmixture meets ASTMD975

Neste Oil First plant (58 MGPopened in Finland inMay 2007. Two otheEU plants in plannin

Animal fats/vegetable oils

Hydrocarbonmixture

Petrobras (Brasil,H-Bio Technology)

Commercial productto begin at severalrefineries in Brasil bend of 2007.

Hydrotreating

Animal fats Hydrocarbonmixture

Dynamic Fuels(Syntroleum/Tyson)

Commercial pilot to construction in 2008production in 2010.


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Vegetable oils Hydrocarbonmixture

ENI (UOPTechnology)

Plant to be constructItaly, 95 million galsproduction in 2009.

Cellulosicbiomass

Hydrocarbonmixture

JV withChoren/Daimler-Chrysler/VW

Pilot plant (4.7 MGPto open in late 2007.

Cellulosicbiomass

Hydrocarbonmixture

Neste Oil/StoraEnso

Pre-commercializati

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

Cellulosicbiomass Hydrocarbonmixture Syntroleum Pre-commercializati


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Cellulosicbiomass,

municipal orindustrial solidwaste

Hydrocarbonmixture

In Research Stage In Research StagePyrolysis-RapidThermal Processing

Slaughterhousewaste, othercarbon-containingsolid waste

Hydrocarbonmixture meets ASTMD 396, can be

refined toASTM D975

Changing WorldTechnologies

Commercial-scale piplant in Missouri isproducing ~250,000gallons/mo of fuel fr

slaughterhouse wast

ASTM D396 Standard Specification for Fuel Oils ASTM D975 Standard Specification for Di


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Biodiesel and Renewable Diesel Definitions

While there is considerable discussion about renewable diesel, there is no universally accepteddefinition or technical standard that exists for this emerging fuel. There are multiple technologiesthat 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 developmentphase, years away from producing commercially available product. The different technologiesuse widely different feedstocks, including wood biomass, slaughterhouse waste, tallow, andrecycled or virgin vegetable oil.

One commonality of these fuels is that they are not biodiesel, which is defined in WashingtonState law as the monoalkyl esters of long chain fatty acids derived from plant or animal matterthat meet the registration requirements for fuels and fuel additives established by the federalenvironmental protection agency and standards established by the American society of testingand 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 blendcomponent with petroleum diesel. Biodiesel has passed the EPA Tier I and Tier II health-effectstesting, 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 renewablefeedstocks, 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 sulfurimpurities from diesel fuel. Renewable diesel produced using this process can either beproduced in a bio-only unit that uses only vegetable oils or animal fats as feedstock orwhere oils or fats are co-processed with the distillate fractions (diesel fuel) derived frompetroleum. Both processes produce a mixture of hydrocarbons that has been reported to meetthe ASTM standard for petroleum diesel (D975). The renewable diesel fuel produced throughthese processes, consequently, could utilize the existing infrastructure currently used forblending and transporting petroleum fuels. Any fuels containing the products produced fromeither process must be registered with the EPA as a fuel or fuel additive before being sold asdiesel fuel in the U.S.

Co-processing with Petroleum

Producing a renewable diesel fuel by co-processing fats/oils with petroleum is exemplified bythe process developed by Conoco-Phillips (COP). COP has been hydrotreating a soy oil/dieselfuel combination at a conventional crude oil refinery in Ireland since late 2006.1 Recently, thecompany announced plans to bring this process to the US and has entered into a partnershipwith Tyson Foods to use tallow in several of its refineries to produce up to 175 million gallonsof renewable diesel per year.2 According to Tyson Foods, the current uses of the tallow

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http://www.biodiesel.org/pdf_files/fuelfactsheets/Production.PDFhttp://www.biodiesel.org/pdf_files/fuelfactsheets/Production.PDF


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expected to be used to produce renewable diesel are cosmetics, soaps, candles, and some petfood. The companies expect to begin producing the fuel in 2007 and be at a capacity of 175million gallons by early 2009. The locations of the refineries that will produce the fuel havenot been announced.

The renewable diesel fuel produced by the COP hydrotreating process is a mixture of saturatedhydrocarbons, with properties similar to diesel fuel, that meet ASTM D975. The process alsoproduces propane, carbon dioxide, and water from the oil/fat feedstock. The cetane number ofthe 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 beimproved through alternative processing. Additional benefits assigned to the fuel include: a highlevel of quality control; meets ASTM D975; can be blended with biodiesel; and can be used inexisting pipelines and trucking infrastructure. Unlike biodiesel and similar to petroleum-basedultra-low sulfur diesel (ULSD), the COP renewable diesel requires a lubricity additive.

Table 2. Comparative Fuel Specifications for ConocoPhillips Renewable Diesel Blends

Property ASTM D975BaseFuel

5% RenContent

10% RenContent

20% RenContent

30% RenContent

T90, F 540-640F 559 565 568 571 577

Visc. (mm2 /s at 20C) 1.9-4.1 2.3 2.3 2.4 2.4 2.4

Ash, mass % 0.01 max


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R100 COP fuel was estimated at 44%, as compared to petroleum diesel at 100%. B100 fuel wasestimated at 59% in this analysis. The GREET model, which is currently the industry standardfor completing lifecycle analysis was not used in this analysis because at the time the GREETmodel did not have a renewable diesel pathway. Work is underway, however, by ArgonneNational 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 vegetableoil with petroleum distillate in hydrotreating units to make renewable diesel.4 BP also has aproject in Australia to produce renewable diesel with 5% renewable content via hydrotreatingof 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-onlyprocess that produces non-ester renewable diesel fuel through its NExBTLTM technology, athermal/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, isessentially sulfur, oxygen, nitrogen and aromatic free. It can be combined with petroleum dieselat any blend level but requires a lubricity additive, as do very low sulfur petroleum diesels. Theproduction process can apparently be adjusted to produce a fuel with a cloud point anywherebetween -5o C and -30o C.

The following table is a summary of the results of a study of the regulated emissions in threedifferent light-duty vehicles using blends (5%-85%) of the NExBTL fuel with and relative to aEuropean 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

Blend Level with Euro DieselBlend Level with

Swedish DieselEmission

Type85% 20% 5% 5 & 15%

CO average -30% average -15%minor to noreductions

5%: no sig. difference15%: ~ - 5%

HC average -40% average -20% no sig. difference no sig. difference

PM no sig. differenceminor to noreductions

no sig. difference no sig. difference

NOx 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 andHC, but not PM or NOx. Additional testing on heavy-duty truck engines, however, showed aNOx reduction of 15% and PM reduction of more than 25%, along with a 20% HC reductionand 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 suggestingthat the fuel might be used to upgrade off-specification petroleum diesel. It is unknown whatair 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 CO2-equivalent greenhouse gas (GHG) emissions relative to petroleum diesel.

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Neste inaugurated its first commercial-scale plant in Porvoo, Finland in May 2007. The planthas a capacity of about 170,000 metric tons (~ 53 million gallons) of fuel per year. A secondplant has been approved for Finland and a third is planned for Austria. The company has saidit is looking for a potential location and collaborators in the U.S. Neste has reported that thefuel meets ASTM D975, claims that the fuel thus will not need a separate ASTM standard andthat no action is required of The National Conference of Weights and Measures. It appearsthey will elicit a comment from the National Conference stating that the standard practicesapply. The company also states that it intends to comply with EPA testing and registrationprior to introduction of the fuel into the U.S. market. The length of the EPA registrationprocess is not expected to be problematic since, according to the company, permitting andconstruction 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 announcedplans to construct a 75 million-gallon per year facility to produce renewable diesel usingcatalytic 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 fuelproduced by the Neste process.

UOP, a Honeywell company, also recently announced that ENI, an Italian refining companyintends to build a production facility at an existing refinery in Italy using UOP catalytichydrotreating technology to convert vegetable oils to renewable diesel. It is expected to beginproduction 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 (predominantlycellulosic 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 Fischer-Tropsch process to catalytically convert the syngas to liquid fuel. This technology has beenapplied 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).

12DOEs 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 EnergyPolicy Act (EPAct).

Technologies to produce BTL fuel are, for the most part, still in the research and developmentstages, and thus further from commercialization than renewable diesel made by processing

oils and/or fats via hydrotreating. The most commercially advanced BTL process is probablyfrom Choren, which is working with Shell, Daimler-Chrysler and VW on a BTL fuel it callsSunDiesel.13 The process uses cellulosic materials to produce a diesel-like fuel. Choren plansto open an industrial-scale 15,000 ton/yr (4.7 million gallons/yr) pilot plant later this year inFreiberg, Germany.

Neste Oil and Stora Enso, a Finnish paper products company, have recently announced a jointventure with the intention of building a pilot facility to convert forest product residue intorenewable fuel.

14Syntroleum, 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 toconventional diesel.

14The 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 thatSunDiesel, when compared to petroleum diesel, has

much lower aromatics and sulfur (although this analysis was completed before theintroduction 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 light-duty engine (see further discussion of SunDiesel and NOx emissions in the paragraphbelow)

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 thisstudy, SunDiesel generally shows a NOx reduction (~3.5% to 18%) when compared toconventional 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 areintriguing, in particular because of the results of an earlier study. This study, which the authorssay was a more complete study of a Fischer-Tropsch diesel with fuel properties very similar toSunDiesels, showed a slight increase in NOx emissions compared to conventional diesel.Furthermore, yet another study, an earlier literature review conducted by NREL, showeddeclines on average in NOx emissions from Fischer-Tropsch diesels. As the authors of this papernote, additional testing, especially with a variety of engines and vehicles, is needed to validatewhether or not SunDiesel reduces NOx emissions.

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Pyrolysis/Rapid Thermal Processing

Yet another technique for producing renewable diesel uses pyrolysis or other thermalconversion 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-likefuel. Pyrolysis/TCP uses a thermal decomposition process with high heat transfer rates and ashort residence time to convert the large polymers, i.e. cellulose, hemicellulose, lignin, andproteins of biomass or organic waste streams into smaller molecules. Under these conditions,organic vapors, pyrolysis gases, and charcoal are produced from biomass. The vapors arecondensed to produce pyrolysis oil (often referred to as bio-oil). Yields of liquid products, ashigh as 79 % of the initial dry weight of the biomass, can be achieved. Federal labs areinvolved 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.

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The bio-oil produced by the Changing WorldTechnology process purportedly meets ASTM D396, the standard for petroleum fuel oil andhas 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, theyoffer the potential to convert large volumes of cellulosic biomass or organic waste into liquidfuels and feeds. As a result, the federal labs are focusing the majority of their efforts on helpingto commercialize these technologies and have significantly reduced their support of biodieselresearch, which they consider technologically mature

Registration and Standards Development

EPA Registration

Because renewable diesel products are not derived from petroleum, they will require EPAregistration. The Clean Air Act provides EPA with the authority to regulate fuels and fueladditives in order to reduce the risk to public health. The regulations at 40 CFR Part 79 requirethat each manufacturer or importer of gasoline, diesel fuel, or a fuel additive, have its productregistered by EPA prior to its introduction into commerce.18, 19 Registration involves providing achemical description of the product and certain technical, marketing and health-effectsinformation. 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 beforea new product can be registered. EPA uses this information to identify products whoseemissions may pose an unreasonable risk to public health, warranting further investigation and/orregulation.

The registration requirements are organized in a three-tier structure. In general, standardmandatory requirements are contained in the first two tiers, while the third tier provides foradditional 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 effectsof their product. Tier 1 also includes emission characterization requirements.

Manufacturers are responsible for generating, collecting, and sampling the combustion emissionsand, 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 cantake up to 6 months, but is generally completed in less time. As soon as an applicant submits Tier1 data to EPA, the registration becomes public.

Tier 2 consists of testing requirements designed to detect potential adverse health effects relatedto the inhalation of F/FA emissions. Typically this requirement involves exposure of laboratorytest animals to the product emissions and an evaluation of the effects of this exposure. The testrequirements of Tier 2 also include a 90-day subchronic inhalation study with additional tests toscreen for possible carcinogenicity, mutagenicity, teratogenicity, reproductive toxicity, andneurotoxicity effects. Tier 2 testing can take upwards of 18 months. An applicant can petitionEPA 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 fueladditive. In this instance, the applicant would argue that the Tier 2 results from the earlierregistration tests would yield similar results. This is a probable pathway for applicants registeringrenewable diesel.

When Tier 1 and Tier 2 are complete, manufacturers submit the results to EPAfor evaluation. EPA will then determine whether further testing and/or analysis for the subjectF/FA is needed under the provisions of Tier 3.

ASTM Standard Development

ASTM is an international standards development organization that publishes standards that aredeveloped through an industry-voluntary consensus process. An ASTM Standard Specificationdefines the requirements for a specific product. While the ASTM Standard Specificationdevelopment is a voluntary process, ASTM Standard Specifications have been adopted, byincorporation or reference, in many municipal, state, and federal government regulations and aremandatory. Currently there are ASTM Standard Specifications for petroleum diesel fuel (ASTMD975), petroleum fuel oil (ASTM D396), and biodiesel used as a blend component (ASTMD6751). Several of the renewable diesel products have been reported to meet ASTM D975, andthus their producers will not likely petition for a separate standard.

Should a separate Standard Specification be requested, the process requires an ASTM TaskGroup to draft documents that define the Standard Specification. The drafted Specification ispeer-reviewed by one of the ASTM Technical subcommittees, the Main Subcommittee, and theentire Society through a rigorous, tiered balloting process. If approved at each level, theSpecification would be adopted, following a final review by the Committee on Standards. Theentire process can be time consuming depending on whether redrafting of the Specification isrequired. Generally the Main Subcommittees have balloting about twice a year, so anyredrafting 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, thenthat standard is sent to National Conference of Weights and Measures (NCWM) petroleum sub-committee 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 NationalConference. If passed, the new standard is placed into the NIST Handbooks. The process worksalmost identical to our federal legislative process. The National Conference of Weights andMeasures meets once a year, thus the minimum time for the process would be approximately 1year.

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 inquiriesabout 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:

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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 ofone company. After passage of the act, there were discussions about broadening the definition ofrenewable diesel and thermal depolymerization to include processes of other companies.Although no formal position has been announced, DOE appears to have recommended that thebroad definition be used.

Environmental Protection Agency

The Environmental Protection Agency (EPA) recently issued its final rule on the federalrenewable fuel standard (RFS).21 Ultimately, EPA decided to include renewable diesel as one oftwo 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 befound 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 specificallylist several renewable fuels in its rule and included both biodiesel (mono-alkyl esters) and

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non-ester renewable diesel in this list. In addition, EPA made a distinction between traditionalbiodiesel and renewable diesel in terms of equivalence values, which are used to determine howto add volumes of different fuels together for purposes of RFS tracking. Biodiesel (mono-alkylesters) has an equivalence value of 1.5; non-ester renewable diesel has an equivalence value of1.7. 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. Inthat section, entitled What is Biodiesel?, the agency says it chose a two-part definition in orderto adhere to the definition of biodiesel in EPAct of 2005 while still recognizing the uniquehistory and role of mono-alkyl esters meeting ASTM D-6751 EPAs sub-definition of non-ester renewable diesel in this section states that the term refers to a motor vehicle fuel or fueladditive that:

1) meets the registration requirements for fuels and fuel additives established by theEnvironmental Protection Agency under section 7545 of this title (Clean Air Act Section211);

2)

is not a mono-alkyl ester;3) is intended for use in engines that are designed to run on conventional, petroleum-deriveddiesel fuel, and

4) is derived from nonpetroleum renewable resources. Current examples of a non-esterrenewable diesel include: renewable diesel produced by the Neste or UOP process, ordiesel 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 forprocessing in refineries. This processing is expected to happen in one of three ways. First, therefineries 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 therenewable crude is coprocessed with petroleum-based feedstocks. Third, the processing couldmean running fats and/or oils through a refinerys hydrotreater (see ConocoPhillips partnershipwith Tyson Foods). The fuels resulting from these processes are called renewable crude-basedfuels and are considered to be essentially the same as petroleum gasoline and diesel. EPA countsthese fuels toward the RFS requirements. In the case that a renewable crude is processed withpetroleum-based feedstocks, EPA counts the volume of renewable crude that was input into theprocess rather than trying to account for the volume of renewable fuel that resulted from theprocess.

Internal Revenue Service

The Internal Revenue Service (IRS) has issued a notice on renewable diesel that basically puts iton par with agri-biodiesel in terms of the blenders tax credit. That is, renewable diesel is eligiblefor the same $1/gal tax credit as agri-biodiesel. The IRS says it relied on input from DOE toreach 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 andpressure 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 withpetroleum fuel, is considered renewable diesel by the IRS. Under this definition traditionalpetroleum 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 isprovided 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 depolymerizationprocess;(ii) Meets the registration requirements for fuels and fuel additives established by theEnvironmental Protection Agency (EPA) under section 211 of the Clean Air Act (42U.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 materialsthrough 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 18carbon atoms. A process may qualify as thermal depolymerization even if catalysts areused in the process.

References

1) ConocoPhillips Begins Production of Renewable Diesel Fuel at Whitegate Refinery inCork, Ireland,http://www.conocophillips.com/newsroom/news_releases/2006+News+Releases/121906.htm

2) ConocoPhillips and Tyson Foods Announce Strategic Alliance To Produce NextGeneration 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, SAEGovernment/Industry Meeting, May 15, 2007

4) Petrobras H-Bio Process, http://www2.petrobras.com.br/tecnologia/ing/hbio.asp5) 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

17
http://www.conocophillips.com/newsroom/news_releases/2006+News+Releases/121906.htmhttp://www.conocophillips.com/newsroom/news_releases/2006+News+Releases/121906.htmhttp://www.conocophillips.com/newsroom/news_releases/2007+News+Releases/041607.htmhttp://www.conocophillips.com/newsroom/news_releases/2007+News+Releases/041607.htmhttp://www2.petrobras.com.br/tecnologia/ing/hbio.asphttp://www.bp.com/sectiongenericarticle.do?categoryId=9012389&contentId=7017889http://www.nesteoil.com/default.asp?path=1,41,535,547,3716,3884http://www.nesteoil.com/default.asp?path=1,41,535,547,3716,3884http://www.bp.com/sectiongenericarticle.do?categoryId=9012389&contentId=7017889http://www2.petrobras.com.br/tecnologia/ing/hbio.asphttp://www.conocophillips.com/newsroom/news_releases/2007+News+Releases/041607.htmhttp://www.conocophillips.com/newsroom/news_releases/2007+News+Releases/041607.htmhttp://www.conocophillips.com/newsroom/news_releases/2006+News+Releases/121906.htmhttp://www.conocophillips.com/newsroom/news_releases/2006+News+Releases/121906.htm


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7) Rantanen, Leena and Raimo Linnaila, Neste Oil Corporation, and Paivi Aakko and TiinaHarju, Technical Research Centre of Finland.NExBTL Biodiesel fuel of the secondgeneration. SAE Technical Paper 2005-01-3771. 2005.

8) Reinhardt, G., S. O. Grtner, G.H. Helms, G.N. Rettenmaier.An Assessment of Energyand 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 formvegetable 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 aLight-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, Part79 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/cgi-bin/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.

18
http://www.syntroleum.com/proj_rba_biofining.aspxhttp://www.uop.com/pr/releases/PR.EniEcofiningFacility.pdfhttp://www.nrel.gov/vehiclesandfuels/npbf/gas_liquid.htmlhttp://www1.eere.energy.gov/biomass/gasification.htmlhttp://www.choren.com/en/energy_for_all/sundiesel/http://www.storaenso.com/CDAvgn/main/0,,1_EN-8276-17221-,00.htmlhttp://www1.eere.energy.gov/biomass/pyrolysis.htmlhttp://www.changingworldtech.com/http://www.epa.gov/otaq/regs/fuels/additive/web-dies.htmhttp://www.access.gpo.gov/nara/cfr/waisidx_01/40cfr79_01.htmlhttp://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=109_cong_public_laws&docid=f:publ058.109http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=109_cong_public_laws&docid=f:publ058.109http://www.epa.gov/otaq/renewablefuels/rfs-finalrule.pdfhttp://www.epa.gov/otaq/renewablefuels/rfs-finalrule.pdfhttp://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=109_cong_public_laws&docid=f:publ058.109http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=109_cong_public_laws&docid=f:publ058.109http://www.access.gpo.gov/nara/cfr/waisidx_01/40cfr79_01.htmlhttp://www.epa.gov/otaq/regs/fuels/additive/web-dies.htmhttp://www.changingworldtech.com/http://www1.eere.energy.gov/biomass/pyrolysis.htmlhttp://www.storaenso.com/CDAvgn/main/0,,1_EN-8276-17221-,00.htmlhttp://www.choren.com/en/energy_for_all/sundiesel/http://www1.eere.energy.gov/biomass/gasification.htmlhttp://www.nrel.gov/vehiclesandfuels/npbf/gas_liquid.htmlhttp://www.uop.com/pr/releases/PR.EniEcofiningFacility.pdfhttp://www.syntroleum.com/proj_rba_biofining.aspx


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22)EPA final rule on federal renewable fuel standard,http://www.epa.gov/otaq/renewablefuels/rfs-finalrule.pdfMost 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 RenewableDiesel (p. 23917)III. B. 3. Does Renewable Fuel Include Motor Fuel That is Made From Coprocessing aRenewable 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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http://www.epa.gov/otaq/renewablefuels/rfs-finalrule.pdfhttp://www.irs.gov/pub/irs-drop/n-07-37.pdfhttp://www.irs.gov/pub/irs-drop/n-07-37.pdfhttp://www.epa.gov/otaq/renewablefuels/rfs-finalrule.pdf

Documents

Renewable Diesel White Paper Final