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On-Road ULSD Fuel Q & A


As most of you know, the use of ULSD fuel will soon be required for all 2007 and newer on-road diesel engines. Many are anxious to know how the new requirement will affect them. We have created the following list of frequently asked questions to educate your customers about what ULSD means to their business in response to this change.


What is ULSD?

ULSD is diesel fuel with a maximum sulfur content of 15 ppm (parts per million) and is
  often referred to as S15. S15, S500, and S5000 are designations for diesel fuels that
  meet 15 ppm, 500 ppm, and 5,000 ppm maximum sulfur content, respectively.
ULSD will be required for all 2007 and newer on-road diesel engines.

What is the timeline for the introduction of ULSD Fuel?

On-Road Diesel Fuel target dates (not required to convert to ULSD)
  o Refinery - June 1, 2006
  o Terminals - September 1, 2006 (California is July 15, 2006)
  o Retail - October 15, 2006 (California is September 1, 2006)
Non - Road/Construction conversion target is June 1, 2007 for S500 then June 1, 2010
  for S15
Marine and Locomotive ULSD conversion target is June 1, 2007 for S500 then June 1,
  2012 for S15


What are diesel dispenser pump labeling requirements?

All dispenser pumps must be labeled based on US Environmental Protection Agency
  (EPA) guidelines and indicate the sulfur level and designation of the fuel. For example,
  any dispenser with ULSD (S15) will state the fuel is required for use in all model year
  2007 and newer highway diesel vehicles and engines. It is also recommended for use in
  all other diesel vehicles and engines. Any dispenser with S500 (500 ppm of sulfur) diesel
  fuel will state that the fuel is not suitable for fueling model year 2007 and later vehicles.
  o The following EPA website provides more details on the dispenser labeling
  requirements:
  Retailer and Wholesale Labeling Requirements


What is the chemical difference in the ULSD fuel?

There is no major chemical difference between current diesel fuels and ULSD, but
  ULSD is further processed to remove additional sulfur, resulting in fuel that contains
  only 15ppm of sulfur. Certain fuel characteristics may be affected by this process,
  including:
  o LUBRICITY - Diesel fuel must adequately lubricate the fuel injection system
  components. The additional processing removes naturally occurring lubricity
  agents in diesel fuel. All ULSD fuel will meet the required lubricity specification.
  Lubricity additives will be used if needed.
  o FUEL DENSITY - Reduced density of the diesel fuel, resulting in a slight
  reduction in energy content (BTU/gal).
  o CETANE - Reduced aromatics content, resulting in an increase to the cetane
  number. Any improvement in cetane will vary with refinery source.
  o COLD FLOW - Potential effect on cold flow response. Cold flow requirements
  change seasonally and regionally and ULSD will meet the local requirements by
  use of appropriate additives and/or blending with No.1 ULSD.

Will the older engines require the new ULSD Fuel?

No, but older engines can use ULSD without modifications to the engines.


Why do I need to use the ULSD fuel in my new 2007 engines?

Primarily because use of higher sulfur fuels can damage the engine and after-treatment
  devices designed to reduce emissions.
EPA states these new regulations will significantly reduce nitrous oxide (NOx) and
  particulate emissions.
EPA has established a comprehensive program to regulate diesel fuel along with the
  production of diesel engines.
Model Year 2007 diesel engines will be required to meet more stringent emissions
  requirements that will likely result in the use of high-efficiency catalytic exhaust
  emission control devices.


What will be the cost of the new ULSD fuel?

There are no cost estimates available at this time, but the retail prices of ULSD will
  ultimately be market driven.


Will there be a fuel penalty for using the ULSD fuel?

Pre-2007 engines
  o Fuel density will decrease slightly and this may impact fuel economy.
2007 and later engines
  o These engines will have additional emissions control devices that, depending on
  design, may have an additional effect on mileage.


What is the process for changing our tanks over to the ULSD fuel?

The suggested practice is to minimize tank inventory during the transition period (June
through October) and also to inspect and clean tanks that are in need of servicing.
Particularly during ULSD transition, good housekeeping practices and removal of tank
sludge, sediment and other contaminants will be very important.
Each facility should demonstrate ULSD compliance prior to posting the ULSD label.
Contact your COP representative for guidance in developing a Quality Assurance Plan
  (QAP) for tank conversions and product handling at your facility.

Can the ULSD fuel be mixed with the 500PPM diesel fuel?

ULSD can be mixed with S500, however it will have to be downgraded to annual limits
  per facility. Downgraded product must be labeled accordingly and limited to S500 sales.

What can I do to make sure my tanks are free from bacterial growth?

Bacterial growth can occur at the water/oil interface. Without water, there is no growth.
  Because ULSD may be more susceptible to bacterial growth, good tank maintenance
  (housekeeping) practices are even more important. Routine water bottom draining and
  tank bottom sampling should be established to ensure a clean system and the efficacy
  of housekeeping measures.


If I already have bacterial growth how do I treat the tanks to eliminate the contamination?

Contact a tank cleaning or chemical company that specializes in tank remediation.
  Please contact your regional ConocoPhillips Lubricants representative for assistance.


What happens if a station is out of compliance?

The retailer must provide a quick response for remediation
  o Stop sales of ULSD immediately
  Re-label/downgrade to S500, remove product, etc.
  o Show documentation for receiving certified ULSD
  o Have a Quality Assurance Plan (QAP) in effect showing proper storage, handling
  and sampling etc.
  o Demonstrate no contamination at the site
EPA has established fines and damages for facilities found not to be in compliance. See
  EPA link below.


REFERENCE LINKS:

Heavy duty engine and vehicle standards and highway diesel fuel sulfur control
  requirements
  o http://www.epa.gov/otaq/regs/hd2007/frm/f00057.pdf
Clean diesel trucks and buses rule
  o http://www.epa.gov/otaq/diesel.htm#documents