Contractors need to be aware of upcoming changes in off-road diesel fuel standards and labeling requirements. Since June 1, 2010, large refiners and importers have been producing only ultra-low sulfur diesel (ULSD) fuel (fuel with less than 15 parts per million sulfur content) for use in off-road equipment (except marine and locomotive diesel fuel), per U.S. Environmental Protection Agency rules. By December 1, 2010, all off-road diesel fuel offered for sale must be ULSD fuel, with limited exceptions. EPA requires fleet operators to use ULSD in ALL highway diesel vehicles and in Model Year (MY) 2011 and later off-road diesel equipment. In addition, contractors who store and dispense their own diesel fuel must label their diesel fuel pumps, per EPA rules.
The switch to ULSD should not cause operational problems. In California, contractors have used ULSD exclusively since 2006. All diesel engines of any age can use ULSD fuels (per manufacturer's specifications), but they are required for use in newer construction equipment. Using anything else is illegal, may reduce power and fuel economy, and cause damage to engine components that may not be covered under warranty. In addition, diesel engines "retrofitted" with advanced emissions control devices must use ULSD, in most cases. Click here for more information from CAT, and click here for more information from John Deere.
Labeling Requirements
By December 1, 2010, all off-road (as well as highway) diesel fuel offered for sale must be ULSD. Both ULSD and Low Sulfur Diesel (LSD) will be available through 2010. Some retail outlets will sell ULSD, others Low Sulfur Diesel and some will sell both. EPA rules require all retailers and contractors who store and dispense their own diesel fuel (wholesale purchaser-consumers) to label their diesel fuel pumps with specific language to inform the user of the category of diesel fuel they are dispensing into their equipment or vehicle. See 40 C.F.R. § 80.572. The retailer or wholesale purchaser-consumer who owns or operates the dispenser is responsible for labeling. Civil penalties of up to $37,500 per violation per day can be assessed for non-compliance with EPA's ULSD fuel standards, or for misrepresentation of the sulfur level of diesel fuel.
The American Petroleum Institute (API) has developed a set of labels for fuel dispensers that are EPA approved. Click on links below to view/download appropriate fuel labels:
API Suggested Diesel Pump Labels
API Suggested Kerosene Pump Labels
Supply
Amidst the maze of dates and deadlines is the practical reality that 75 percent of all the distillate fuel finished products are now ultra-low sulfur, according to the Energy Information Administration. Since the majority of fuel consumption occurs in on-road highway vehicles, many refiners have been producing or supplying only ULSD products to simplify storage and handling. Since the transition to ULSD has been well underway for over three years now, it appears that June 1 has come and gone without any noticeable changes to off-road consumers.
Price
The average retail price of on-highway diesel fuel peaked at $4.76 per gallon in July 2008, according to a weekly survey by the Energy Information Administration. Prices fell to the low $2 range by early 2009 before rebounding to $3.12 in May 2010. By late July, prices were back down to $2.90. Diesel prices are influenced mainly by worldwide demand and supply of crude oil; changes in refining rules have had little or no effect. For the rest of 2010, it appears both oil and diesel prices will stay in a relatively narrow range, although past changes in either direction have often occurred suddenly.
Benefits
According to the EPA, switching to ULSD results in a 5 to 10 percent reduction in emissions, depending on the baseline fuel sulfur level. See EPA's report Cleaner Diesels: Low Cost Ways to Reduce Emissions from Construction Equipment, March 2007. ULSD provides an even greater benefit when it is paired with advanced diesel engine technology designed to further reduce exhaust emissions. The ULSD phase-in deadlines coincide with the new requirements for diesel engine manufacturers to produce cleaner technology diesel engines and vehicles/equipment (i.e., EPA's Heavy-Duty Highway "2007" Diesel Rule and EPA's Nonroad Diesel "Tier 4" Rule). Meeting the federal government's aggressive engine emissions standards means equipping newly manufactured engines with advanced emission control devices like particulate filters and traps. These new emissions devices are extremely sensitive to high sulfur levels in fuel and if exposed, can suffer loss of performance or be rendered completely ineffective, nullifying emissions control benefits. Evidence of misfueling (using higher sulfur fuel in new 2011 machines) can also impact manufacturers warranty coverage.
Additional Considerations
While ULSD fuel has many benefits, there are some challenges associated with its use. Some of these challenges are associated with the transition period of using and storing higher sulfur diesel fuel and then switching over to the new ULSD fuel.
According to information reported by a variety of diesel stakeholder groups-
- ULSD may form gums, varnishes, and carbon deposits more easily and quickly than LSD.
- ULSD shows a tendency to deteriorate or oxidize more quickly than LSD.
- ULSD is produced through a refining process known as severe hydro-treating. This process may cause the fuel to be harder to treat for cold flow improvement. It may require more #1 fuel or more or different additives to meet cold weather needs.
- ULSD is more hygroscopic than LSD. This tendency to hold more dissolved water may have negative effects on cold weather operations and may increase corrosion.
- ULSD may affect fuel system elastomers (e.g., o-rings), which could cause fuel system leaks. Any change will depend on the elastomer material and age, as well as the change in seal swell characteristics of the particular fuel being used, relative to the fuel the vehicle has been using.
- ULSD may loosen deposits in fuel tanks of older machines, which could cause premature fuel filter plugging.
- For more remote job sites and operations it will be important to check with local fuel distributors to assure access to the proper fuel for off-road use, based on your equipment needs.