ULSD does not have the same cold-flow properties as #1 fuel. ULSD will still require winter blending. Be reminded that if you are blending in a #1 fuel into a load of ULSD, then the #1 must be ULSD also. This may cause some disruption depending on the supply of #1 ULSD fuel. Read More About ULSD Cold Properties

Reports from various sources suggest that USLD is more prone to microbial growth due to its low sulfur content. Bacteria was historically not able to thrive in high sulfur fuel.

2007 engines have to work harder to heat ULSD. This can cause problems with mileage and has already been known to cause filter issues. Some filters have been found to have a high amount of asphaltine, or black suit, due to higher degrees when heating the fuel.

EPA, IRS and RFGSA inspectors may:

• Perform retail inspections, take samples and perform testing. (tank and nozzle samples)
• Inspect and take samples at other points (terminals and transports).
• Review Designtate and Track reports - check for non-matching hand-offs and failure to meet balances.

The regulations do not specify frequency of sulfur testing. You are not required to test, but if you don’t, you are not allowed to raise a defense in an EPA enforcement action.

Testing every batch of diesel fuel for sulfur content is not required. Once a month testing or even less frequently may be acceptable if you have a strong quality assurance program in place that insures against downstream contamination while the fuel is in your custody.

PMCI has the tools available to help you comply: a written Fuel Quality Assurance Plan and fuel testing services to document your diligence in complying with the phase in of ULSD.