Tennessee Department of Agriculture

1. Tennessee Department of Agriculture Regulatory Services Division Diesel Lubricity Status Report January 26, 2005

2. Importance of Lubricity • Lubricity: a qualitative term describing the ability of a fluid to affect friction between, and wear to, surfaces in relative motion under load . • Diesel fuel functions as a lubricant in certain components of fuel injection equipment, such as fuel pumps and injectors.

3. Importance of Lubricity • Insufficient lubricity can lead to a reduction in the normal service life of fuel injection equipment. • Lubricity issues arise due to the severe processing required to reduce aromatics and sulfur. • Fuel injection equipment will run at higher pressures to meet new emissions standards.

4. Historical Perspective • ASTM International’s debates on lubricity requirements for all diesel fuels began in 1989. • During this time of debate, ASTM also developed test methods to rate lubricity. • 2002 Ballot for lubricity received numerous negatives – correlation to pump wear, poor precision, values proposed too low……

5. Historical Perspective • Again ballot in 2003 – Negatives & comments received: proposed limits not restrictive enough, only needed for light duty – not heavy duty, need an effective date. • Buckeye Pipeline – Negative based on ATF supply; non-persuasive at 12/03 meeting. • Colonial Pipeline raised issues regarding pipelines and lubricity additive – Colonial’s Negative found non-persuasive at 12/03 meeting.

6. Historical Perspective • ExxonMobil negative – an effective date was necessary in order to allow terminals across the country sufficient time to prepare to inject additive systems– the negative was persuasive, leading to… • Decision at the 12/03 meeting – Ballot an effective date of Jan. 1, 2005. • June 2004 – Negatives received on the ballot that set an enforcement date of Jan. 1, 2005 were adjudicated – including pipeline / Jet A issues – all found non-persuasive.

7. API Request Waiver from TN • October of 2004 API contacts TDA requesting a waiver to the law. • TDA Administrative and Legal staff evaluate the facts and review our statutory authority. • Commissioner Ken Givens issues statement to industry outlining the Department’s lack of authority to issue a policy that would be in conflict with legislative mandate.

9. ASTM Ballots Revised Spec • Fall of 2004, ASTM issues a ballot to revise the effective date for lubricity. • The ballot fails to secure enough votes in favor of the change to allow each negative the opportunity to be voted on individually at the 12/04 meeting.

10. Next Step… • TDA contacted each TN terminal – generally positive response regarding the progress being made to ensure conformance. • Meeting and discussions followed with various industry leaders. • Agreement – Industry sponsor legislation giving Commissioner authority to made ‘emergency’ deviations from ASTM. • Status of proposed legislation: HB 005, SB 127, passed first reading in the House.

11. Load Motion Ball Fuel on Test Pad What is the new requirement? • Diesel Fuel must show less than 520 m wear scar as measured by the ASTM D 6079, High Frequency Reciprocating Rig (HFRR) test.

12. Other Activities at TDA Related to Fuel Quality Currently proposing rules changes pursuant to the Kerosene and Motor Fuels Quality Inspection Act for Biodiesel and Premium Diesel

13. Rule Changes:Biodiesel • “Biodiesel” means a fuel comprised of mono-alkyl esters of long chain fatty acids derived from vegetable oils or animal fats, designated B100. • “Biodiesel Blend” means a fuel comprised of a blend of biodiesel fuel with petroleum-based diesel fuel, designated BXX. In the abbreviation BXX, the XX represents the liquid volume percentage of biodiesel fuel in the blend. • Biodiesel Fuel – Biodiesel (B100) intended for blending with diesel fuel shall meet the most recent version of ASTM D 6751, “Standard Specification for Biodiesel Fuel (B100) Blend Stock for Distillate Fuels.”

14. Biodiesel • Biodiesel Blends – Blends of biodiesel and diesel fuels shall meet the following requirements: the base diesel fuel shall meet the most current requirements of ASTM D 975, Standard Specification for Diesel Fuel Oils; the biodiesel blend stock shall meet the most current requirements of ASTM D 6751, Standard Specification for Biodiesel Fuel (B100) Blend Stock for Distillate Fuels, with the following exception: Biodiesel may be blended with diesel fuel whose sulfur or aromatic levels are outside specification ASTM D 975, Standard Specification for Diesel Fuel Oils, Grades 1-D, low sulfur 1-D, 2-D, or low sulfur 2-D, provided the finished mixture meets pertinent national and local specifications and requirements for these properties

15. Revised Model Definition for Premium Diesel • Cetane Number ‑ A minimum cetane number of 47.0 as determined by ASTM Standard Test Method D 613. • Low Temperature Operability - A cold flow performance measurement which meets the ASTM D 975 tenth percentile minimum ambient air temperature charts and maps . • Thermal Stability ‑ A minimum reflectance measurement of 80 percent as determined by ASTM Standard Test Method D 6468. • Lubricity – A maximum wear scar diameter of 520 microns as determined by ASTM D 6079. If an enforcement jurisdiction’s single test of more than 560 microns is determined, a second test shall be conducted. If the average of the two tests is more than 560 microns, the sample does not conform to the requirements of this part.

16. Fuel Violations This FY • YTD – 3.35% Violation Rate! – We have not seen violation rates at this level since 1991. • Notable Problems: Diesel Flash Point – 44 Violations Workmanship – 11 Violations Kerosene Saybolt Color – 47 Violations • Last FY: 5 Saybolt Color Violations for entire year – 850 total samples collected.