Tennessee Department of Agriculture

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Tennessee Department of Agriculture

• Regulatory Services Division
• Diesel Lubricity Status Report
• January 26, 2005

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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.

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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.

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Historical Perspective

• ASTM Internationals 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

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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 Colonials
  Negative found non-persuasive at 12/03 meeting.

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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.

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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 Departments lack of
  authority to issue a policy that would be in
  conflict with legislative mandate.

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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.

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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.

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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.

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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

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Rule ChangesBiodiesel

• 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.

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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

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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 jurisdictions 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.

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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.