! !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! · pdf...
TRANSCRIPT
Ensyn, Honeywell UOP and the refining constituency that is working with us on FCC biocrude co-‐processing would like to take this opportunity to formally respond to the outcomes and conclusions of the California Air Resources Board (ARB) co-‐processing working group, particularly on the recommendations to adopt carbon or mass balancing to calculate volumetric yields of biogenic renewable gasoline and diesel. These recommendations are contained in two specific ARB reports that were products of the co-‐processing working group meetings:
1. “Co-‐Processing of Low Carbon Feedstocks in Petroleum Refineries” dated May 30, 2017
2. “Low Carbon Fuel Standard (LCFS) Guidance 17-‐03” (Draft Guidance) dated October 2017 First, we would like to thank and commend the ARB staff for the outcomes and recommendations arising from the deliberations of the co-‐processing working group. As you are aware, we have participated in the co-‐processing working group meetings, have submitted our own comments as workers and experts in the field of FCC biocrude co-‐processing, and have listened to, and reviewed, the expert opinion of others who have made written and oral presentations.
Based on the expert opinion of key participants in the group including: two distinct groups at the National Renewable Energy Laboratory (NREL, the pre-‐eminent US National Laboratory in the field of bioenergy), CanmetENERGY (a pre-‐eminent Canadian National laboratory in the bioenergy field), Honeywell UOP (the world’s premier petroleum processing technology company) and Petrobras (a refiner with vast experience in commercial-‐scale FCC biocrude co-‐processing), all of whom have direct hands-‐on experience with co-‐processing mass/carbon balancing and C-‐14 yield methodologies, we strongly believe that the two yield methodologies, mass or carbon balancing, as prescribed by the California ARB to date, are practical, reliable, accurate and compatible with FCC refinery operations.
Furthermore, we believe that the published information and data dealing with the application of C-‐14 methodologies raises significant concerns regarding their reliability, accuracy and suitability, particularly for FCC co-‐processing operations using 5% or less biocrude addition, and precludes them for use as valid yield methodologies in this application There is sufficient credible public domain data to raise questions on both the actual and perceived validity of C-‐14 yield methods as applied to FCC co-‐processing which could seriously compromise public and private sector confidence in the results of these methods should they be applied determine yields for this application. On the other hand, mass and carbon balance have been routinely used to determine the yields of renewable gasoline and diesel produced via FCC co-‐processing, with consistently high reliability, and there is a broad consensus supporting the accuracy and suitability of such mass and carbon balance yield methods By way of summary, there is broad consensus, based on systematic review and comparison, advocated by highly reputable and credible agencies that C-‐14 methodologies are unsuitable when applied to FCC biocrude co-‐processing, and a broad consensus supporting the accuracy, reliability and suitability of mass/carbon balance for FCC biocrude co-‐processing operations. In the very best case, there would be confusion, lack of confidence, and doubts about the validity of C-‐14 results in the market place. If such
methods were used, and in the worst case, as the evidence suggests, yields of renewable fuels would be inaccurate, impractical, and unreliable where determined by C-‐14 techniques. We concede that C-‐14 may be reliable for some (non-‐co-‐processing) blending operations where the renewable biocarbon content is relatively high (say, well above 20%) or in co-‐processing operations where biointermediate materials are added in high proportions (again, above 20%), but firmly assert, along with public and private sector technical evidence, that this is irrefutably inaccurate for biocrude co-‐processing under 10% biocrude addition. Please note that we have assembled a cross-‐sectional compendium of key public and private sector documents that strongly support the positions in favor of mass or carbon balance methodologies and against the application of C-‐14 methods when applied to FCC biocrude co-‐processing. An explanation of the relevance and significance of each document is summarized as follows, and the actual documents are given in the Appendices. Respectfully submitted,
James Rekoske Robert Graham, Ph.D. Chief Technology Officer Chairman Honeywell UOP Ensyn Corporation 25 E Algonquin Rd 61 Broadway, Suite 1905 Des Plaines, IL 60016 New York, NY 10006
Appendix 1
Honeywell UOP Co-‐Processing Yield Methodology Publication and Expert Opinion
1. FCC Co-‐processing: Observations on the Production Method for Low Carbon Fuels. James E. Rekoske. Ph.D. California Air Resources Board (ARB) Co-‐Processing Working Group. December 13, 2016
a. Slides 9. C-‐14 errors are +/-‐ 3% absolute; unacceptable for co-‐processing b. Slide 10. Mass balance is best method for determining yields in refinery units
2. Mass Balance Approach for Co-‐Processing. James E. Rekoske, Ph.D. California Air Resources
Board (ARB), Co-‐Processing Working Group. February 7, 2017 a. An accurate and reliable mass balance methodology for co-‐processing yield
determination is given with statistical validation
Appendix 2
National Renewable Energy Laboratory (NREL) Publication and Expert Opinion on Co-‐Processing Yield Methodologies
1. Expert opinion of Dr. Robert M. Baldwin. Letter to the California Air Resources Board (ARB).
July 6, 2017 a. Expresses support of mass balance methodology for co-‐processing as proposed by the
California ARB and “the exclusion of (yield) allocation by 14C tracking”
2. Analysis for co-‐processing fast pyrolysis oil with VGO in FCC units for second-‐generation fuel production. Mike Talmadge, Ph.D. et.al. California Air Resources Board (ARB) Co-‐Processing Working Group. December 13, 2016
a. Slide 2 explicitly supports mass balance procedures as “accurate, reliable and appropriate” for co-‐processing to determine renewable gasoline and diesel yields and rejects 14C as inaccurate and unreliable
b. Slide 8 highlights the accuracy of mass and elemental (carbon) balance c. Slide 9 repeats Slide 2 conclusion d. Slides 11-‐13 characterize the uncertainty and errors associated with 14C when applied to
co-‐processing
Appendix 3
NRCAN CanmetENERGY (a Canadian national energy laboratory) Expert Opinion on Co-‐processing Yield Methodologies
1. Expert opinion of Dr. Siauw Ng. Letter to Ensyn Corp. February 14, 2017
a. Dr. Ng presents the credentials of the CanmetENERGY laboratory and his own credentials as an expert scientist with direct co-‐processing experience
b. “Mass balance is the industry standard and … the best and most accurate method for determining the contribution of RFO (biocrude) to the yields of gasoline and light cycle oil or LCO (diesel/kerosene/ jet fuel) cuts during co-‐processing in an FCC unit”
c. “the errors associated with 14C analytical methodologies are prohibitive when applying them to the determination of yields from the pyrolysis oil components in co-‐processing”
d. “mass balance methods for FCC co-‐processing applications are accurate, practical and inexpensive, and the paramount way to determine cellulosic product yields”
Appendix 4
California Air Resources Board (ARB) Regulatory Precedent: Co-‐processing mass/carbon balance
methodology guidelines and recommendations
1. Co-‐processing of Low Carbon Feedstocks in Petroleum Refineries. California Air Resources Board. May 30, 2017
a. “the approaches presented in this discussion paper … address the feedback from stakeholders and experts from co-‐processing work group meetings.” p.3
b. While determining low carbon fuel content/yield … applicants may choose to estimate low carbon fuel yields using:
i. A mass balance approach based on observed yields, or ii. A carbon balance method (p.3)
c. The formulae for both proposed methods are given on pages 3 & 4
Appendix 5
Refiner and Petroleum Technology industry expert opinion on the determination of co-‐processing yields
1. Honeywell UOP. Expert opinion of Dr. James E. Rekoske. Comments on the proposed EPA Renewables Enhancement and Growth Support (REGS) Rule. February 8, 2017
a. Comments specifically on the ASTM D6866 14C methodologies and concludes “the level of accuracy of these methods is not sufficient to determine the renewable content of coprocessed fuel”
b. Comments on the accuracy and suitability of mass balance and concludes “the mass balance approach will provide a much more accurate representation of the renewable content of co-‐processed fuel, particularly … at a level of 5% or less”
2. Honeywell UOP. Expert opinion of Christopher D. Gosling, P.E. Letter to Ensyn Corp. April 29, 2016
a. “The level of accuracy of the (14C) method is not sufficient to determine the renewable product content”
b. “It is more suitable to use a material balance approach at the low level of pyrolysis oil addition envisaged during an FCC co-‐processing operation”
3. Petrobras CENPES. Expert opinion of Dr. Andrea de Rezende Pinho. Summary Report to Fibria. 2016
a. This document is particularly useful since it clarifies earlier Petrobras publications on the renewable gasoline and diesel yields as determined by 14C methodologies.
b. “Because of the low amount of 14C in organic material, it becomes increasingly difficult to quantify biocarbon at the lowest ranges of bio-‐oil addition” (ie. 5% or less – Petrobras explored 5 to 20%)
c. “standard mass balance procedures can accurately predict the amount of liquids produced from RFO (biocrude)-‐petroleum co-‐processing”
d. Note: this letter taken together with the NREL papers cited earlier (which were co-‐authored by Petrobras) firmly establish the view of Petrobras towards the accuracy of 14C methodologies, even though earlier Petrobras papers included preliminary 14C yield data
4. Tesoro Corp. Expert opinion of Rick Weyen. Comments on the proposed EPA Renewables Enhancement and Growth Support (REGS) Rule. February 15, 2017
