Support the Consumer – Require 10-Micron Diesel Fuel Filter, Energy API, Dispenser Filters at retail (flow rate less than 15 gallons per minute)

  (Section 4.3 (237-3))

Letter in opposition to 10 micron filters for diesel dispensers

  • Reported problems: plugged fuel filters, fuel pump failure due to overheating, internal wear of engine components (pistons, seats), sticking injectors
  • Cause of problems: particulates and water contamination, corrosion of steel components of storage system, salts
  • 10 micron filter will address particulates and water contamination
  • Industry research: corrosion in ULSD systems (EPA), salts and diesel cleanliness (CRC), individual company research
    • Review of various studies & findings related to use of 10-micron filters
      • PMAA testing program; CRC-667; Clean Diesel Fuel Alliance Guidance for Underground Storage Tank Management at ULSD Dispensing Facilities; Caterpillar, Bulk Fuel Filtration for Off-Road Applications (IFC10-019); SAE, Internal Injector Deposits in High-Pressure Common Rail Diesel Engines (2010-01-2242) (Afton Chemical Corp.)

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