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

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. 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. Diesel fuel functions as a lubricant in certain components of fuel injection equipment, such as fuel pumps and injectors.

Importance of Lubricity Insufficient lubricity can lead to a reduction in the normal service life of fuel injection equipment. 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. 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. Fuel injection equipment will run at higher pressures to meet new emissions standards.

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

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. 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. 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. Colonial Pipeline raised issues regarding pipelines and lubricity additive – Colonials Negative found non-persuasive at 12/03 meeting.

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… 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, Decision at the 12/03 meeting – Ballot an effective date of Jan. 1, 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. 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.

API Request Waiver from TN October of 2004 API contacts TDA requesting a waiver to the law. 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. 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. 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.

ASTM Ballots Revised Spec Fall of 2004, ASTM issues a ballot to revise the effective date for lubricity. 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. 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.

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

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

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 Currently proposing rules changes pursuant to the Kerosene and Motor Fuels Quality Inspection Act for Biodiesel and Premium Diesel

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 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 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. 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.

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 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

Revised Model Definition for Premium Diesel Cetane Number A minimum cetane number of 47.0 as determined by ASTM Standard Test Method D 613. 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. 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 Thermal Stability A minimum reflectance measurement of 80 percent as determined by ASTM Standard Test Method D Lubricity – A maximum wear scar diameter of 520 microns as determined by ASTM D 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. Lubricity – A maximum wear scar diameter of 520 microns as determined by ASTM D 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.

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