? Non-Road, Locomotive, and Marine Fuels
Non-Highway, Off-Road Diesel Fuels
As of June 1st,
2007 refiners and distributors of Non-Road or Off-Highway Diesel, which is
designated NRLM will be required by the US EPA to dramatically
reduce the sulfur content in these fuels.
Diesel Fuel which
is used for agricultural, power generation, construction, locomotives, and
marine will go from High Sulfur (HSD or S-5000) to Low Sulfur (LSD or S500).
This fuel will be
more expensive, have far less lubricity (the ability of the fuel to lubricate
pumps and injectors), will hold a higher percentage of dissolved water, will
have less thermal and oxidative stability, and will cause more
repair/maintenance problems for the end user.
There are further
compounding problems for distributors and end users of these fuels.
First we need to
understand how the law and regulations have been written by the EPA and ASTM
regarding sulfur content in fuels.
cases regarding these fuels the regulations regarding sulfur content are written
to limit the maximum amount of sulfur in each category. A High Sulfur Diesel
(HSD, S5000) is limited to a maximum of 5000 ppm of sulfur. A Low Sulfur Diesel
(LSD S-5000) is limited to a maximum of 500 ppm of sulfur. An Ultra Low Sulfur
Diesel Fuel (ULSD S-15) is limited a maximum of 15 ppm of sulfur. It is
important to note that there is no lower limit to these regulations or the
corresponding ASTM specifications. This means that a fuel
distributor or supplier can legally supply ULSD to a customer and call it ULSD,
LSD, or HSD. They are under no obligation to tell the customer the
sulfur content is lower.
Red dye indicates
that no federal highway use tax has been paid on a given fuel. Red dye tells a
used nothing about the grade or quality of any fuel. The idea that red dye
indicates heating fuel is mistaken. A red dyed fuel may be heating oil or it may
be any grade of diesel fuel.
To make things
even more complicated, the EPA believes that a significant number of off-highway
fuel users have in the past or may in the future attempt to purchase and use
heating fuel for NRLM purposes. To control this problem, the EPA is requiring
that starting in June of 2007 distributors in most of the US begin adding a
marker dye to heating fuels. This marker dye is referred to as Yellow Dye 124
and will be used at a very low level. The low level being used may not even be
visible to the naked eye; however detection devices will easily pick it up. The
EPA will then pursue and prosecute the offender(s).
The major refiners
in general, do not feel that the volume of NRLM fuel justifies production,
transportation, and storage of this fuel. Even if it is available from refiners,
most distributors do not have enough storage capacity to stock #2 ULSD, #2 LSD,
Heating Oil, #1HSD, #1ULSD, Jet-A, and so on. The result is that in most markets
LSD S-500 fuel will not actually be available.
The next surprise
is that in many markets, all this has already started. So you may well have been
getting ULSD for some time now.
You cannot tell
what level or grade of fuel you are getting by looking at it. The equipment
necessary to test things like sulfur content, lubricity, Cetane level, etc.
costs tens of thousands of dollars and is not practical for field use. There are
companies selling various devices that claim to be able to test Cetane level via
specific gravity. These devices are not accurate and should not be used.
The lowering of
sulfur content in these NRLM fuels will have the following effects:
The fuel will
have significantly lower lubricity. The current ASTM specification for
lubricity is HFRR 520 (a lower number is better). This specification is less
than is suggested by the Engine Manufacturers Association which is HFRR 460.
The engines that have been using HSD have in general been using fuel with HFRR
380-420. This huge change will cause engine seal, pump, and injector problems.
The older the engine the more likely it suffer a serious failure. It will
require the use of additives to allow the fuel to meet the engine
manufacturers required specification.
fuels will hold more dissolved water. This will lead to more corrosion, more
gum, varnish, and carbon deposits in the fuel system and combustion chamber.
This water will allow more bacterial and fungal growth in the fuel, it cause
more cold weather problems with icing of tanks, fuel lines, fuel filters, and
This is but a
partial list of changes and concerns. Off-Highway fuel users need to educate
themselves and make adjustments to their operations to protect their equipment
and to control costs.
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