What Do the New Ultra Low Sulfur Diesel Specifications Mean to Your Business?

It's 3 p.m. on Friday and I'm getting ready to knock off early for the Memorial Day weekend. I'm looking
forward to spending time with family and friends. Then my phone rings and it's my V.P. of Sales, Steve Brewer, CLS, telling me he has a great opportunity for me. For those of you who have a vice president of sales in your company, you know that a phone call like this usually involves some sort of effort on your part. His opportunity was writing this article addressing the new Ultra Low Sulfur Diesel (ULSD) specifications. I know all of you have read articles on ULSD and probably had several conversations
with people who are bound to have several different view points and opinions. I promise to do my best ingiving you more information that you may find useful when such conversations arise.

First of all, beginning this month, June '06, refiners are required to startmproducing diesel fuel for use in highway vehicles with a sulfur content of no more than 15 parts per million (ppm). That's a 97 percent decrease over the past 500 ppm sulfur fuel. At the terminal, highway diesel fuel sold as ULSD will be required to meet the 15 ppm sulfur standard as of September 1, 2006. However, in January of
'06, the EPA issued an extension which extended the deadline for terminal and retail compliance
until October 15, 2006 to provide a longer period to decrease the potential for contamination of fuel in the handling and distribution of ULSD. What this means is that it's going to take some time for all of the
pipes in the distribution system to get cleaned out. Just moving the ULSD fuel through the network of pipes can cause ULSD to pick up enough sulfur to become non-compliant (have >15 ppm sulfur).

Due to the EPA's Clean Air Act, ULSD is necessary because 2007 vehicles cannot operate properly on anything but ULSD. The emission control systems which will be standard equipment starting in 2007 necessitates this lower sulfur fuel. Use of 500 ppm sulfur fuels in 2007 vehicles can poison the catalysts and particulate filters, causing them to be ineffective in reducing targeted emissions. Pre-2007 vehicles can use the new ULSD and see small emissions reductions, but some of the problems we saw back in '94 when we moved from 5000 ppm sulfur to 500 ppm sulfur may have to be re-addressed. We'll discuss diesel fuel additives in the next few paragraphs.

An Explanation
We've already established that in order for a fuel to be labeled as ULSD, it can contain no more than
15 ppm sulfur. This does not mean that there won't be 500 ppm sulfur content fuel available, it just can't
be labeled as ULSD. (The labels in the picture are what you'll see on the pumps). By October 15, 2006, 80 percent of the diesel fuel for on-road use produced by U.S. refineries must meet the 15 ppm ULSD sulfur limit. This leaves 20 percent of fuel that can be produced containing up to 500 ppm sulfur for use in off-road equipment. The current on-road specifications will get us ready for the year
2010, which is when off-road diesel fuel specifications also moves to a maximum of 15 ppm sulfur content. For now, the good news is that when the fuel is tested for sulfur content, "the EPA has allowed a 3 ppm testing tolerance for a period of two years so laboratories downstream of the
refinery will have greater assurance that their procedures are adequate without fear of compliance
challenges. This 3 ppm temporary margin will allow time for the industry to transition to improved test procedures and instrumentation while minimizing the potential for fuel to be downgraded simply because of the test procedure." (Ref. (1) EPA 40 CFR Part 80) After two years, the tolerance for testing will be 2 ppm.

Guilty Until Proven Innocent
So now you've got your load of ULSD and you are asking yourself, what if this fuel tests as having >15 ppm sulfur? Well, there's a thing called presumptive liability, which simply means you are considered
guilty until proven innocent. Whoever is in possession of the non-compliant fuel and everyone upstream of where the fuel is found will have a chance to prove their innocence. For those of you handling fuel, your best defense against non-compliance is the Product Transfer Document as well as good record keeping. Noncompliance can get quite expensive as you could potentially get fined up to $32,500 per day per incident. So it is important that you maintain good records and have your fuel supplier or blender provide you with Product Transfer Documents that show the ULSD is compliant with the 15 ppm maximum sulfur limit.

Now we need to consider diesel fuel additives. The finished product has to contain no more than 15 ppm sulfur. A diesel fuel additive that can be used at the maximum recommended treat rate without causing the ULSD to be non-compliant will be labeled like this: "This diesel fuel additive complies with the federal low sulfur content requirements for use in diesel motor vehicles." This is the responsibility of the additive supplier and means that you can use this additive without concern of making your ULSD non-compliant. I can't speak for other additives, but Schaeffer's Diesel Treat 2000 line of additives will be labeled like this and can be used in ULSD without fear of non-compliance.

A diesel fuel additive that is noncompliant will be labeled like this: "This diesel fuel additive does not
comply with federal low sulfur content requirements for use in model year 2007 and newer diesel motor
vehicles." This means that this additive contains more than 15 ppm of sulfur and could possibly make an ULSD non-compliant, especially if used at more than its recommended treatment rate. However, the additive can still be used in ULSD subject to the 15 ppm cap as long as it doesn't make the finished product non-compliant.

Does anyone understand?
To figure this out, we need to understand ppm. Let's say we have an additive with a treat rate of 1:2000. To figure the ppm of this additive in the fuel, we divide 1 by 2000 and multiply by 1 million to get 500 ppm of additive in that fuel. What if this gallon of additive itself contains 30 ppm of sulfur? Won't its use in ULSD be noncompliant? Well, we simply divide the 30 ppm of sulfur in the gallon of
additive by the 2000 gallons of fuel the gallon will treat and we know this additive will contribute 0.015 ppm of additional sulfur to the treated ULSD. This amount of sulfur would not be detectable based upon the repeatability of the current EPA approved test methods used to detect the amount of sulfur in ULSD. As a result it would take 70 times over treatment of the additive to contribute even 1 ppm of additional sulfur to the ULSD. Remember to make sure you are staying compliant with the ULSD specifications as there are potentially 32,500 reasons per day per incident to make sure you are doing the right thing!

It's common knowledge that when we remove sulfur from fuel, we remove some of the fuel's
natural lubricating qualities. The new test method for testing the lubricity in fuel is the ASTM D6079 High Frequency Reciprocating Rig (HFRR) test. This replaces the former ASTM D6078 Scuffing Bocle test. Besides taking into account that the fuel has undergone deeper hydro-desulfurization to meet the ULSD specs, the HFRR also takes into account that the fuel injection equipment will run at higher pressures to meet the new emissions standards. (Please refer to the diagram of the HFRR test)

A ball submerged in diesel fuel at 60 Deg. C (140 Deg. F) with a 200 gram load is rotated on a pad at a frequency of 50 Hz for 75 minutes. According to the Engine Manufacturers Association (EMA), in
order to pass, the resulting scar diameter on the pad must be no greater than 520 microns (1 micron = 1 millionth of a meter). Based on testing conducted on ULSD fuels, fuel injection equipment manufacturers have required that ULSD fuels have a maximum wear scar diameter of 460 microns. The EMA recommends that the lubricity specifications be consistent with the fuel injection equipment manufacturers' recommendation.

It is my opinion that never before has the use of diesel fuel additives been more important or
easier to justify, especially with today's fuel prices! When looking at using a diesel fuel additive, there
are many attributes to consider, but with the new ULSD, lubricity could be one of the most important.

Schaeffer 's Diesel Treat 2000 line of diesel fuel additives contains a proprietary product called Synshield ™, which has a wear scar diameter of 454 microns in the HFRR test. Synshield also is the
only synthetic based lubricity additive available and does not contain any sulfur. The lubricity insurance
an additive like Diesel Treat 2000 can provide can easily justify the cost of the additive when taking into
account the potential repair bills of a fuel injection system.

Additives can also help you get better fuel economy. While researching this article, I've found two schools of thought on the energy content of the ULSD. According to a paper by the American Association of Equipment Manufacturers, the ULSD will have a reduction in fuel density resulting from the hydrotreating process. Though no one seems to know exactly how much, this translates into a slight lowering of the energy content and subsequent increase in fuel consumption. However, some industry experts told me their initial testing on ULSD has shown no difference between the energy content of ULSD and the previous on-road fuel. While this subject may still be under review, in either case the detergent package in an additive can improve fuel economy by helping keep the fuel system clean. This allows better spray patterns and more complete combustion of the fuel. Additives also have components for cetane improvement, emission reduction, and better cold weather operability in the winter months.

Math 101
When looking at the math, let's say you own a truck and put on 120,000 miles per year. You don't currently use a diesel additive and you are getting 5.5 mpg and are paying $2.80 per gallon for fuel. Now you start using a premium additive that adds $0.02 to your fuel cost. To break even and cover the additional $0.02 cost at the $2.82 per gallon price, your mileage has to increase 0.71 percent, or go to 5.54 miles per gallon. For your bottom line fleet savings, a 1 percent fuel economy increase will save you $173.00 per year, a two percent increase will save you $770.00 per year, and a three percent increase will save you $1,356.00 per year. Remember that these numbers are for one truck. What if your fleet is larger?

Also, tests have shown fuel economy increases of five percent and higher. By the way, a five percent fuel economy increase using the numbers above would save you $2,494.00 per year using the fuel prices listed above.

Additional costs = Increased profits
The whole point I'm trying to make is that we know the ULSD is here, and though there are several different opinions as to what that means as far as lubricity is concerned, you shouldn't look at a diesel fuel additive as just being another expense. The additional cost of the additive can actually mean increased profits