Office of Transportation EPA420-R-06-015 

and Air Quality October 2006 

Summary and Analysis of the 

2006 Nonroad Diesel Fuel 

Pre-Compliance Reports 
EPA420-R-06-015 

October 2006 

Summary and Analysis of the 2006 

Nonroad Diesel Fuel Pre-Compliance Reports

Assessment and Standards Division

and

Transportation and Regional Programs Division

Office of Transportation and Air Quality 

U.S. Environmental Protection Agency 

NOTICE 

This Technical Report does not necessarily represent final EPA decisions or positions.

It is intended to present technical analysis of issues using data that are currently available.

The purpose in the release of such reports is to facilitate an exchange of 

technical information and to inform the public of technical developments. 
Table of Contents 

I. Executive Summary................................................................................................................................................i

II. Nonroad Diesel Program Overview ................................................................................................................1

III. Nonroad Pre-Compliance Reporting Requirements ........................................................................................3

IV. NRLM Summary Statistics .............................................................................................................................4

A. Nationwide Analysis .......................................................................................................................................4

1. Refineries and Importers – Numbers and Volumes....................................................................................4

2. Projected Credit Generation and Use .........................................................................................................6

3. Project Scope and Timing...........................................................................................................................8

4. Small Refiner Options ................................................................................................................................9

B. PADD Analysis ........................................................................................................................................10

1. PADD 1 ....................................................................................................................................................13

2. PADD 2 ....................................................................................................................................................14

3. PADD 3 ....................................................................................................................................................15

4. PADD 4 ....................................................................................................................................................16

5. PADD 5 ....................................................................................................................................................17

C. Comparison of 2005 and 2006 NRLM Pre-Compliance Reports..................................................................18
I. Executive Summary 

I. Executive Summary 

Any refiner or importer planning to produce or import nonroad, locomotive, or 

marine (NRLM) diesel fuel containing 15 ppm sulfur or less after June 1, 2010 is required to 

submit to the U.S. Environmental Protection Agency (“EPA” or “the Agency”) annual precompliance reports. Reports are due from 2005 through 2011 by June 1 of each year under 

the nonroad diesel sulfur regulations. This report summarizes the results of refiners’ June 

2006 pre-compliance reports. 

Refiners’ nonroad pre-compliance reports must contain estimates of total (highway + 

NRLM) 15 ppm diesel fuel and total (highway + NRLM) 500 ppm diesel fuel produced or 

imported from June 2010 through December 2014. For those refiners and importers planning 

on participating in the credit trading program, the reports must contain a projection of how 

many credits will be generated or used by each refinery or importer. The pre-compliance 

reports must also contain information outlining each refinery’s timeline for complying with 

the 15 ppm sulfur standard and provide information regarding engineering plans (e.g., design 

and construction), and capital commitments for making the necessary modifications to 

produce 15 ppm NRLM diesel fuel. 

The 2006 nonroad pre-compliance reports showed that: 1) 117 refineries are planning 

to produce 15 ppm diesel fuel by 2014; 2) 23 refiners are either undecided as to their plans, 

or are choosing to remain in the high sulfur diesel market; 3) refiners have projected an 

increase in diesel production from 2010 through 2014; 4) refiners are taking advantage of the 

flexibilities offered by the regulations (23 refineries plan to generate early credits in 2006 and 

2007, 9 refineries plan to generate early credits in 2009 and 2010, small refiners are utilizing 

all of the options available to them); 5) all diesel fuel volumes in all PADDs are projected to 

grow or remain constant; and 6) refiners project an increase in expected production and 

importation of total highway + NRLM diesel fuel (“total diesel fuel”) beginning June 1, 

2010, compared to the 2005 nonroad pre-compliance reports. 

Many refiners have developed firmer plans to produce 15 ppm NRLM diesel fuel by 

June 1, 2010 than what they indicated in their 2005 pre-compliance reports, although these 

plans are still subject to change. EPA expects that next year’s nonroad pre-compliance 

reports will contain more definite information on refiners’ plans to produce 15 ppm NRLM 

diesel fuel by June 1, 2010. 

i 
 II. Nonroad Diesel Program Overview

II. Nonroad Diesel Program Overview 

The Nonroad Diesel final rule (69 FR 38958, June 29, 2004) contains a twostep approach to reducing the sulfur content of nonroad, locomotive, and marine 

(NRLM) diesel fuel from uncontrolled levels down to 15 ppm. Beginning June 1, 

2007, refiners and importers are required to produce or import NRLM diesel fuel with 

a maximum sulfur content of 500 ppm. Beginning June 1, 2010, refiners and 

importers are required to produce or import nonroad (NR) diesel fuel with a 

maximum sulfur content of 15 ppm. Beginning June 1, 2012, refiners and importers 

are required to produce or import locomotive and marine (LM) diesel fuel with a 

maximum sulfur content of 15 ppm.

This rule includes provisions for refiners and importers to generate credits for 

early NRLM diesel sulfur reduction efforts. “High sulfur” credits may be generated 

for early production of 500 ppm NRLM diesel fuel between June 1, 2006 and June 1, 

2007. Similarly, “500 ppm” credits may be generated for early production of 15 ppm

NRLM diesel fuel between June 1, 2009 and June 1, 2010. “High sulfur” credits 

could be used to comply with the 500 ppm NRLM standard beginning June 1, 2007, 

while “500 ppm” credits could be used to comply with the 15 ppm NR standard 

beginning June 1, 2010 and the 15 ppm LM standard that begins June 1, 2012. For 

both high sulfur credits and 500 ppm credits, one credit is equivalent to one gallon of 

diesel fuel that meets the respective standard earlier than required. In addition, “high 

sulfur” credits can be converted into “500 ppm” credits for use in 2010 and later. 

NRLM sulfur credits may be transferred nationwide. No credit trading area 

restrictions exist such as those found in the Highway Diesel rulemaking. 

Small Refiner Flexibilities

Additional compliance flexibilities are provided for small refiners in the 

nonroad diesel sulfur regulations. The definition of an NRLM small refiner is similar 

to the definition under the Tier 2/Gasoline Sulfur and Highway Diesel rules. A small 

refiner is defined as a refiner who: 1) processes NRLM diesel fuel from crude oil; 2) 

employs no more than 1,500 people corporate-wide, based on the average number of 

employees for all pay periods from January 1, 2002 to January 1, 2003; and, 3) has a 

corporate crude oil capacity less than or equal to 155,000 barrels per calendar day 

(bpcd) for 2002. 

The small refiner relief options provide additional time for compliance and, 

for small refiners that choose to comply earlier than required with the NRLM 

requirements, the option of either generating diesel fuel sulfur credits or receiving a 

limited relaxation of their Tier 2/Gasoline Sulfur standards. These small refiner 

options are described in more detail below. 

 1
 II. Nonroad Diesel Program Overview

Option 1 – Delay 500 ppm NRLM production 

This option allows approved small refiners to delay compliance with the

NRLM diesel fuel sulfur standards as follows. Instead of a 500 ppm NRLM 

compliance date of June 1, 2007, small refiners have a compliance date of June 1, 

2010. Production of high sulfur (greater than 500 ppm) NRLM diesel fuel from a 

small refiner’s refinery between June 1, 2007 and June 1, 2010 is limited to 105 

percent of the refinery’s average NRLM diesel fuel production from 2003 through 

2005. 

Option 2 – Delay 15 ppm NRLM production 

This option allows approved small refiners to delay compliance with the

NRLM diesel fuel sulfur standards as follows. Instead of separate 15 ppm NR and 

LM compliance dates of June 1, 2010 and June 1, 2012, respectively, small refiners 

have a single 15 ppm NRLM compliance date of June 1, 2014. Production of 500 

ppm sulfur NRLM diesel fuel from a small refiner’s refinery between June 1, 2010 

and June 1, 2014 is limited to 105 percent of the refinery’s average NRLM diesel fuel 

production from 2006 through 2008. 

Option 3 - NRLM Credit Option 

An approved small refiner may choose to use the NRLM Credit Option in 

combination with the NRLM Delay Option. The NRLM Credit Option allows 

approved small refiners the opportunity to generate nonroad diesel sulfur credits for 

early production of compliant NRLM diesel fuel. These credits can be banked for 

future use or traded to another refiner. Small refiners could generate “High Sulfur” 

credits for producing any volume of 500 ppm NRLM diesel fuel prior to June 1, 

2010. Small refiners could also generate “500 ppm” credits for producing any 

volume of 15 ppm NRLM diesel fuel prior to June 1, 2014. 

Option 4 - NRLM Diesel/Gasoline Compliance Option 

This option is available to small refiners that produce greater than 95 percent 

of their NRLM diesel fuel at the 15 ppm sulfur standard by June 1, 2006 and elect not 

to use the NRLM Credit Option described above. Production of 15 ppm sulfur 

NRLM diesel fuel from a refinery using this option must be at least 85 percent of the 

refinery’s 2003 through 2005 baseline NRLM production. Refiners choosing this 

option will receive a modest relaxation in their interim gasoline sulfur standards 

beginning January 1, 2004. Specifically, the applicable small refiner annual average 

and per-gallon cap would be increased by 20 percent for the duration of the interim

program. The interim program is through 2010 if the refiner elected to extend the 

duration of its interim gasoline sulfur standards by producing 15 ppm highway diesel 

fuel by June 1, 2006, and through 2007 if the refiner did not produce 15 ppm highway 

 2
II. Nonroad Diesel Program Overview

 3

diesel fuel by June 1, 2006. However, in no case may the per-gallon gasoline sulfur 

cap exceed 450 ppm.

Other Flexibilities

Unlike the Highway Diesel rulemaking, the nonroad diesel sulfur regulations do 

not provide any specific flexibilities for refineries located in the Geographic Phase-in

Area (GPA). Refiners located in the Rocky Mountain States (ID, MT, ND, 

WY, UT, CO and NM) must comply with the 500 ppm and 15 ppm NRLM sulfur 

standards within the compliance deadlines discussed above. NRLM diesel fuel in 

rural areas of the state of Alaska (a GPA state in the gasoline sulfur rulemaking) is 

exempt from the 500 ppm NRLM diesel fuel sulfur standard beginning June 1, 2007, 

but must meet the 15 ppm sulfur standard beginning June 1, 20101

. This fuel is 

regulated under a special rule for Alaska which was finalized in June 2006 (71 FR 

32450, June 6, 2006). 

Transmix processors distill off-specification interface mixtures of petroleum 

products from pipeline systems into gasoline and distillate fuel and are considered 

refiners by EPA. Their simple refinery configuration does not make it cost effective 

for them install and operate a hydrotreater to reduce distillate fuel sulfur content. As 

a result, they have been provided with additional flexibility to comply with the diesel 

sulfur standards. Transmix processors may choose to continue to produce all of their 

highway diesel fuel to the 500 ppm sulfur standard until 2010. They may further 

choose to continue to produce all of their NRLM diesel fuel as high sulfur diesel fuel 

until June 1, 2010, all of their NRLM diesel fuel to meet the 500 ppm sulfur standard 

until June 1, 2014, and all of their LM diesel fuel to meet a 500 ppm sulfur limit 

indefinitely. 

III. Nonroad Pre-Compliance Reporting Requirements 

The Nonroad Rule requires that any refiner or importer planning to produce or 

import 15 ppm NRLM diesel fuel after June 1, 2010 must submit annual precompliance reports to EPA. The first pre-compliance report was due on June 1, 2005 

and subsequent reports are due annually through 2011, or until the production of 15 

ppm sulfur NR and LM diesel fuel commences, whichever is later. 

The pre-compliance reports must contain the following information: 

1. Any changes in the refiner's or importer's basic company or facility 

information since registration. 

2. Estimates of the average daily volumes (gallons) of each sulfur grade of 

highway and NRLM diesel fuel produced or imported at each refinery 

1

 Rural areas are defined as areas of Alaska not served by the federal aid highway system (FAHS)
III. Nonroad Pre-Compliance Reporting Requirements

 4

(facility). The volume estimates must include both fuel produced from crude 

oil and other sources for the periods of June 1, 2010 through December 31, 

2010, calendar years 2011-2013, January 1, 2014 through May 31, 2014, and 

June 1, 2014 through December 31, 2014. 

3. For refiners or importers expecting to participate in the NRLM credit 

program, estimates of the number of credits generated and/or used during the 

periods above. 

4. Information on project schedule by known or projected completion date (by 

quarter) for each stage of the project. For example strategic planning, frontend engineering, detailed engineering and permitting, procurement and 

construction, and commissioning and startup. 

5. Basic information regarding the selected technology pathway for compliance 

(e.g. conventional hydrotreating versus other technologies, revamp versus 

grassroots, etc.). 

6. Whether capital investments have been made or are projected to be made. 

7. An update of the progress in each of these areas. 

We recognize that the pre-compliance reports contain preliminary information 

and that final decisions on desulfurization plans may not have been made in all cases 

as of the reporting deadline. Accordingly, the information in this summary and 

analysis is based on the best available refinery information as of June 1, 2006. The 

information presented here will be updated with more current analyses as subsequent 

pre-compliance reports are received annually in 2007 through 2011. 

IV. NRLM Summary Statistics 

A. Nationwide Analysis 

1. Refineries and Importers – Numbers and Volumes 

According to the Energy Information Administration (EIA), 140 refineries 

reported producing either high or low sulfur (or both) distillate fuels in 2003. This 

reported production includes data from four refiner/importers that are located outside of 

the continental United States (i.e., in the U.S. Virgin Islands, Puerto Rico, and Eastern 

Canada) whose production is targeted to the U.S. market. We received 2006 precompliance reports for 124 refineries, all of which produced high and/or low sulfur diesel 

fuel in 2003. The 16 refineries which did not send pre-compliance reports may be 

planning to produce high sulfur distillate fuel for the heating oil market, or may be 

planning to sell their high sulfur distillate fuel to other refineries that can desulfurize it. 

Refiners indicated that, for most of their refineries, they have made decisions 

whether or not to produce 15 ppm NRLM diesel fuel. Table 1 shows that a total of 117 

refineries reported they anticipate producing 15 and/or 500 ppm diesel fuel beginning 

June 1, 2010. The remaining 7 refineries that sent pre-compliance reports said they either 
III. Nonroad Pre-Compliance Reporting Requirements

plan to produce only high sulfur distillate for the heating oil market, or are still deciding 

whether to produce 15 ppm NRLM diesel fuel.

Table 1. 

U.S. Aggregated Report Information 

Highway and NRLM Diesel Fuel Refinery Statistics 2010-2014 

Year 2010 2011 2012 2013 2014a2 2014b

# refineries producing diesel fuel 117 117 117 117 117 117

# refineries at 100% 15 ppm 104 104 106 111 111 117

# refineries at 100% 500 ppm 2 2 1 1 1 0

# refineries with 15/500 ppm mix 11 11 10 5 5 0

The 2006 nonroad pre-compliance reports indicated that production of 15 ppm

and 500 ppm total diesel fuel beginning June 1, 2010 is projected to be 4.15 million 

bbls/day, as shown in Table 2 below. The reported information does not allow for any 

distinction between highway and NRLM volume. However, the 2005 highway diesel 

pre-compliance reports projected that production of 15 ppm and 500 ppm highway diesel 

fuel from January 1, 2010 through May 31, 2010 would be 3.26 million bbls/day. Thus, 

by comparing the 2006 reports with the 2005 reports, the reporting refiners appear to be 

planning to produce approximately 890 thousand bbls/day total 15 ppm and 500 ppm

NRLM diesel fuel beginning June 1, 2010. 

Table 2 and Figure 1 also illustrate that production of total 15 ppm diesel fuel is 

projected to increase by 250 thousand bbls/day from 2010 to 2014. However, this 

projected increase is offset by a projected decrease in 500 ppm NRLM diesel fuel 

production of 110 thousand bbls/day from 2010 to 2014. Half of the projected decrease 

in 500 ppm production occurs by June 1, 2012 as some refiners begin producing 15 ppm 

sulfur LM diesel fuel. The remaining 500 ppm diesel fuel production ends by May 31, 

2014, when the flexibilities for small refiners and NRLM credit use end. 

As mentioned previously, 140 refineries reported to EIA that they produced low 

and/or high sulfur distillate fuel in 2003. Twenty three of these refineries either reported 

that they have no plans at present to produce 15 ppm diesel fuel, or did not send an 

NRLM pre-compliance report to EPA in 2006. In 2003, these 23 refineries produced a 

total of 97 thousand bbls/day of diesel fuel containing less than 500 ppm sulfur, and 174 

thousand bbls/day of distillate fuel containing more than 500 ppm sulfur. We cannot tell 

at this time if or when these refineries might choose to produce 15 ppm diesel fuel, or 

whether they will simply choose to continue to serve the heating oil market indefinitely. 

 5

2

 Data from the pre-compliance reports is divided into two sections for 2014 throughout this report. In all 

tables and figures, data for the first five months of 2014 is labeled 2014a, and data for the last seven months

of 2014 is labeled 2014b. 
IV. NRLM Summary Statistics

 6

Table 2. 

U.S. Aggregated Report Information 

Diesel Fuel Volume 2010-2014

Year 2010 2011 2012 2013 2014a 2014b

Total 15 ppm (highway + NRLM), bbls/day 4,038,441 4,100,439 4,201,618 4,240,251 4,243,655 4,290,045

Total 500 ppm NRLM, bbls/day 110,529 110,568 70,067 54,864 54,864 0

15 + 500 ppm total (highway + NRLM), bbls/day 4,148,970 4,211,008 4,271,685 4,295,115 4,298,519 4,290,0453

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

3,000,000

3,500,000

4,000,000

4,500,000

2010 2011 2012 2013 2014a 2014b

Year

T

otal (

Highway + N

R

L

M) Diesel Fuel,

b

bls/d

a

y

15 ppm sulfur 500 ppm sulfur

Figure 1. Projected (Highway + NRLM) Diesel Fuel Production by Type, 2010-2014 

2. Projected Credit Generation and Use 

Table 3 shows total reported nonroad diesel sulfur credits generated and used for 

each year of the nonroad diesel sulfur credit program. High sulfur credits are shown in

equivalent bbls/day for the last 7 months of 2006 (refiners could not begin generating 

high sulfur NRLM credits until June 1, 2006), the full calendar years 2007 through 2009, 

and the first 5 months of 2010. 500 ppm credits are shown for the last 7 months of 2009, 

the full calendar years 2010 through 2013, and the first 5 months of 2014. Twenty-three 

3

 Total 15 + 500 ppm production decreases slightly during the last 7 months of 2014 because some

refineries plan to shut down for maintenance during this time. 
IV. NRLM Summary Statistics

refineries indicated they plan to generate 263 thousand bbls/day of high sulfur credits 

during the high sulfur early credit generation period from June 1, 2006 through May 31, 

2007, including three refineries owned by small refiners who plan to continue generating 

4 thousand bbls/day of high sulfur credits after May 31, 2007. Nine refineries indicated 

that they plan to use 70 thousand bbls/day of high sulfur credits in 2007, including seven 

refineries that plan to continue using 46 thousand bbls/day of high sulfur credits through 

May 31, 2010. 

Nine refineries indicated they plan to generate 65 thousand bbls/day of 500 ppm

credits during the credit generation period from June 1, 2009 through May 31, 2010, 

including three refineries owned by small refiners who plan to continue generating 7 

thousand bbls/day of 500 ppm credits through December 31, 2009. One refinery 

indicated that it plans to use 3 thousand bbls/day of 500 ppm credits from June 1, 2010 

through May 31, 2012. 

 7

Table 3. 

U.S. Aggregated Report Information 

Nonroad Diesel Fuel Credits 2006-2014

Year 2006 2007 2008 2009 2010

# refineries generating high sulfur credits 23 23 3 3 2

# refineries using high sulfur credits 9 7 7 7

High sulfur credit generation, bbls/day 263,079 105,415 3,557 3,557 3,092

High sulfur credit usage, bbls/day 70,371 46,063 46,047 46,047

Year 2009 2010 2011 2012 2013 2014

# refineries generating 500 ppm credits 9 9 3 3 3 

# refineries using 500 ppm credits 1 1 1 0 0

500 ppm credit generation, bbls/day 65,340 30,923 6,758 6,771 6,943 

500 ppm credit usage, bbls/day 3,000 3,000 1,500 0 0

Figures 2 and 3 illustrate cumulative projected generation and usage of high sulfur 

credits and 500 ppm credits by year. Both figures show that based on current plans, 

refiners should generate more than enough of each type of credit to meet the demand for 

each type of credit. 
IV. NRLM Summary Statistics

 8

0

500

1,000

1,500

2,000

2,500

3,000

3,500

4,000

4,500

Millio

n Cre

dit

s

2006 2007 2008 2009 2010

Year

cumulative HSC generated cumulative HSC used

Figure 2. Total U.S. High Sulfur Credits 

0

200

400

600

800

1,000

1,200

1,400

Millio

n Cre

dit

s

2009 2010 2011 2012 2013 2014

Year

cumulative 500 ppm credits generated cumulative 500 ppm credits used

Figure 3. Total U.S. 500 ppm Credits 

3. Project Scope and Timing 

In addition to providing diesel fuel volume and credit projections, refineries must 

also include information outlining both their timeline for compliance with the 15 ppm

sulfur standard and their engineering plans (e.g., design and construction) in their pre- 
IV. NRLM Summary Statistics

 9

compliance reports. We requested that refineries report their progress according to the 

following five stages: 1) strategic planning, 2) planning and front-end engineering, 3) 

detailed engineering and permitting, 4) procurement and construction, and 5) 

commissioning and start-up. In last year’s nonroad pre-compliance reports, most 

refineries indicated they were either just starting to develop their plans to produce 15 ppm

NRLM diesel, or did not plan to produce any more 15 or 500 ppm diesel than indicated in 

their highway pre-compliance reports. 

In the 2006 NRLM pre-compliance reports, it was indicated that there are plans to 

install new desulfurization capacity at 21 refineries specifically to produce 15 ppm

NRLM diesel fuel by June 1, 2010. All of these refineries are generally in the early 

stages of their projects to produce 15 ppm NRLM diesel fuel. They reported that they 

have completed their strategic planning, and are just beginning their front-end 

engineering design work. 

All 21 refineries indicated that they would either be revamping existing 

hydrotreating or hydrocracking units, or installing new hydrotreating or hydrocracking 

units. Thirteen of these refineries indicated specific project scopes to produce 15 ppm 

NRLM diesel. Of those thirteen refineries, five are planning to install a new 

desulfurization unit, four are planning to revamp an existing desulfurization unit, and four 

refineries are planning to both install at least one new desulfurization unit and revamp at 

least one existing desulfurization unit. The other eight refineries did not report detailed 

project information. 

4. Small Refiner Options 

As discussed in greater detail above, the Nonroad Diesel fuel regulations contain 

four options which provide qualified small refiners with flexibilities regarding production 

of 15 ppm NRLM diesel fuel. Option 1 allows a refinery owned by an approved small 

refiner to delay production of 500 ppm sulfur NRLM diesel fuel until June 1, 2010. 

Option 1 was chosen by six refineries. These six refineries produced 35 thousand 

bbls/day high sulfur distillate fuel in 2003. 

Option 2 allows a refinery owned by an approved small refiner to delay 

production of 15 ppm NRLM diesel fuel until June 1, 2014. Option 2 was chosen by six 

refineries. These six refineries produced 24 thousand bbls/day high sulfur distillate fuel 

in 2003. (As Options 1 and 2 are not mutually exclusive, there are some small refiners 

that chose both Options 1 and 2.) 

Option 3 allows a small refiner utilizing Option 1 to generate credits for any 500 

ppm sulfur NRLM diesel fuel produced between June 1, 2006 and May 31, 2010, and/or 

allows a small refiner utilizing Option 2 to generate credits for any 15 ppm sulfur NRLM 

diesel fuel produced between June 1, 2009 and December 31, 2013. Option 3 was 
IV. NRLM Summary Statistics

osen by six refineries. These six refineries produced 24 thousand bbls/day high sulfur 

istillate fuel in 2003. 

Lastly, Option 4 allows a refinery owned by a small refiner the ability to increase 

s gasoline sulfur standards by 20 percent, provided that the refinery begins producing 15 

pm NRLM on June 1, 2006 and the refinery’s 15 ppm NRLM production is at least 85 

ercent of the refinery’s NRLM baseline production. Option 4 was chosen by five 

fineries. These five refineries produced 48 thousand bbls/day high sulfur distillate fuel 

 2003. 

The volumes reported by refineries regarding the small refiner options, and the 

umber of refineries by option chosen, are shown in Table 4 below. 

 10

ch

d

it

p

p

re

in

n

Table 4. 

Intended Small Refiner Compliance Options by Number of Refineries and 

High Sulfur Distillate Fuel Production Capacity 

Option Description Number of 

Refineries

2003 High Sulfur Distillate 

Fuel Production 

(thousand bbls/day)

1. Delay 500 ppm NRLM Production 6 35 

2. Delay 15 ppm NRLM Production 6 24 

3. NRLM Credit Option 6 24 

4. NRLM Diesel/Gasoline Compliance Option 5 48 

B. PADD Analysis 

This section presents information specific to each PADD. Tables 5 and 6 show, 

by PADD, the number of refineries producing 15 and/or 500 ppm diesel fuel for 2010 

(from June 1 through December 31) and 2014 (from June 1 through December 31). The 

total number of refineries remains constant at 117 from 2010 to 2014. In 2010, thirteen 

refineries are still using flexibilities in the rules (producing 500 ppm LM diesel fuel, 

producing 500 ppm NR diesel fuel using NRLM credits, small refiner flexibilities) to 

produce some or all 500 ppm diesel fuel. However, by 2014 all of these refineries will be 

producing only 15 ppm diesel fuel. 

Tables 7 and 8 show, by PADD, anticipated production rates of 15 ppm and 500 

ppm total diesel fuel for 2010 (from June 1 through December 31) and 2014 (from June 1 

through December 31), and Figure 4 illustrates the average anticipated production of 15

ppm and 500 ppm total diesel fuel by PADD from June 1, 2010 through December 31, 

2014. Tables 7 and 8 show that the projected total diesel fuel production in PADDs 3 and 

5 increases by 115 thousand bbls/day, and 22 thousand bbls/day, respectively, while 

projected total diesel fuel production remains nearly constant in PADDs 1, 2, and 4. 
IV. NRLM Summary Statistics

 11

More detailed information for each PADD is shown below in Tables 9 through 

13. 

Table 5. 

Projected Number of Highway and NRLM Diesel Fuel Refineries by PADD for 2010

PADD 1 2 3 4 5 Total U.S.

# refineries producing diesel fuel 13 25 42 14 23 117

# refineries at 100% 15 ppm 12 22 37 12 21 104

# refineries at 100% 500 ppm 0 0 2 0 0 2

# refineries with 15/500 ppm mix 1 3 3 2 2 11

Table 6. 

Projected Number of Highway and NRLM Diesel Fuel Refineries by PADD for 2014b

PADD 1 2 3 4 5 Total U.S.

# refineries producing diesel fuel 13 25 42 14 23 117

# refineries at 100% 15 ppm 13 25 42 14 23 117

# refineries at 100% 500 ppm 0 0 0 0 0 0

# refineries with 15/500 ppm mix 0 0 0 0 0 0

Table 7. 

Projected Volumes of (Highway + NRLM) Diesel Fuel by PADD for 2010

Total 

PADD 1 2 3 4 5 U.S. 

Total 15 ppm (highway + NRLM), bbls/day 461,843 1,001,381 1,920,020 166,439 488,758 4,038,441

Total 500 ppm (highway + NRLM), bbls/day 71 9,936 78,920 14,054 7,548 110,529

15 + 500 ppm total (highway + NRLM), bbls/day 461,915 1,011,317 1,998,940 180,492 496,306 4,148,970

Table 8. 

Projected Volumes of (Highway + NRLM) Diesel Fuel by PADD for 2014b

Total 

PADD 1 2 3 4 5 U.S. 

Total 15 ppm (highway + NRLM), bbls/day 465,822 1,006,079 2,113,326 186,615 518,202 4,290,045

Total 500 ppm (highway + NRLM), bbls/day 0 0 0 0 0 0

15 + 500 ppm total (highway + NRLM), bbls/day 465,822 1,006,079 2,113,326 186,615 518,202 4,290,045
IV. NRLM Summary Statistics

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

3,000,000

3,500,000

4,000,000

4,500,000

2010 2011 2012 2013 2014a 2014b

Year

T

otal (Hig

h

way 

+ N

R

L

M) Diesel F

uel,

bbls/d

a

y

PADD 5

PADD 4

PADD 3

PADD 2

PADD 1

Figure 4. Projected (Highway + NRLM) Diesel Fuel Production by PADD, 2010-

2014 

 12
IV. NRLM Summary Statistics

 13

 1. PADD 1

Reported totals for all PADD 1 refineries and importers are summarized below in 

Table 9. Table 9 shows that for 2010, 13 refineries anticipate producing 462 thousand 

bbls/day of 15 ppm + 500 ppm sulfur total diesel fuel. Twelve refineries reported that 

they intend to produce 100 percent of their diesel fuel at 15 ppm or less of sulfur, and one 

refinery reported they intend to produce a small amount of 500 ppm NRLM diesel fuel 

through May, 2014. Table 9 also shows that total diesel fuel production in PADD 1 is 

projected to increase slightly from 2010 to 2014. 

Table 9 

PADD 1 Diesel Fuel Statistics 2010-2014 

Year 2010 2011 2012 2013 2014a 2014b

# refineries producing diesel fuel 13 13 13 13 13 13

# refineries at 100% 15 ppm 12 12 12 12 12 13

# refineries at 100% 500 ppm 0 0 0 0 0 0

# refineries with 15/500 ppm mix 1 1 1 1 1 0

Total 15 ppm (bbls/day) 461,843 461,811 465,805 465,822 465,520 465,822

Total 500 ppm (bbls/day) 71 71 71 71 71 0

Total 15 + 500 ppm (bbls/day) 461,915 461,883 465,877 465,894 465,591 465,822
IV. NRLM Summary Statistics

 14

2. PADD 2

The reported totals for all PADD 2 refineries are summarized below in Table 10. 

Table 10 shows that for 2010, 25 refineries anticipate producing 1.01 million bbls/day of 

15 ppm + 500 ppm sulfur total diesel fuel. Twenty two refineries reported that they 

intend to produce 100 percent of their diesel fuel at or below 15 ppm sulfur, and three 

refineries reported that they intend to produce a small amount of 500 ppm sulfur diesel 

fuel. Table 10 also shows that total diesel fuel production in PADD 2 is projected to 

remain essentially constant from 2010 through 2014. 

Table 10. 

PADD 2 Diesel Fuel Statistics 2010-2014 

Year 2010 2011 2012 2013 2014a 2014b

# refineries producing diesel fuel 25 25 25 25 25 25

# refineries at 100% 15 ppm 22 22 22 23 23 25

# refineries at 100% 500 ppm 0 0 0 0 0 0

# refineries with 15/500 ppm mix 3 3 3 2 2 0

Total 15 ppm (bbls/day) 1,001,381 1,007,568 1,007,234 1,008,865 1,009,852 1,006,079

Total 500 ppm (bbls/day) 9,936 9,936 9,634 9,420 9,420 0

Total 15 + 500 ppm (bbls/day) 1,011,317 1,017,505 1,016,867 1,018,285 1,019,272 1,006,079
IV. NRLM Summary Statistics

 15

3. PADD 3

Reported totals for all PADD 3 refineries are summarized below in Table 11. 

Table 11 shows that 42 refineries anticipate producing 2.0 million bbls/day of 15 ppm

and 500 ppm sulfur total diesel fuel in 2010. Thirty seven refineries reported they intend 

to produce 100 percent of their diesel fuel at or below 15 ppm, and five refineries 

reported that they intend to produce some amount of 500 ppm diesel fuel. 

Table 11. 

PADD 3 Diesel Fuel Statistics 2010-2014 

Year 2010 2011 2012 2013 2014a 2014b

# refineries producing diesel fuel 42 42 42 42 42 42

# refineries at 100% 15 ppm 37 37 38 40 40 42

# refineries at 100% 500 ppm 2 2 1 1 1 0

# refineries with 15/500 ppm mix 3 3 3 1 1 0

Total 15 ppm (bbls/day) 1,920,020 1,958,460 2,042,068 2,066,399 2,068,501 2,113,326

Total 500 ppm (bbls/day) 78,920 78,920 52,656 44,825 44,825 0

Total 15 + 500 ppm (bbls/day) 1,998,940 2,037,380 2,094,724 2,111,224 2,113,326 2,113,326
IV. NRLM Summary Statistics

 16

4. PADD 4

Reported totals for all PADD 4 refineries are summarized below in Table 12. 

Table 12 shows that 14 refineries anticipate producing 180 thousand bbls/day 15 ppm and 

500 ppm sulfur total diesel fuel in 2010. Twelve refineries reported that they intend to 

produce 100 percent of their diesel fuel with 15 ppm or less of sulfur and two refineries 

reported that they intend to produce some amount of 500 ppm diesel fuel. Table 12 also 

shows that the projected total diesel fuel production in PADD 4 remains relatively 

constant from 2010 through 2014. 

Table 12. 

PADD 4 Diesel Fuel Statistics 2010-2014 

Year 2010 2011 2012 2013 2014a 2014b

# refineries producing diesel fuel 14 14 14 14 14 14

# refineries at 100% 15 ppm 12 12 12 14 14 14

# refineries at 100% 500 ppm 0 0 0 0 0 0

# refineries with 15/500 ppm mix 2 2 2 0 0 0

Total 15 ppm (bbls/day) 166,439 168,842 175,753 186,486 187,104 186,615

Total 500 ppm (bbls/day) 14,054 14,093 7,158 0 0 0

Total 15 + 500 ppm (bbls/day) 180,492 182,934 182,911 186,486 187,104 186,615
IV. NRLM Summary Statistics

 17

5. PADD 54

Reported totals for all refineries in PADD 5 are summarized below in Table 13. 

Table 13 shows that 23 refineries anticipate producing 496 thousand bbls/day 15 ppm and 

500 ppm sulfur total diesel fuel in 2010. Twenty one of these refineries indicated that 

they expect to produce 100 percent of their diesel fuel with 15 ppm sulfur or less, and two 

refineries reported that they intend to produce some amount of 500 ppm diesel fuel. Table 

13 also shows that the projected total diesel fuel production in PADD 5 increases by 22 

thousand bbls/day from 2010 through 2014. 

Table 13. 

PADD 5 Diesel Fuel Statistics 2010-2014 

Year 2010 2011 2012 2013 2014a 2014b

# refineries producing diesel fuel 23 23 23 23 23 23

# refineries at 100% 15 ppm 21 21 22 22 22 23

# refineries at 100% 500 ppm 0 0 0 0 0 0

# refineries with 15/500 ppm mix 2 2 1 1 1 0

Total 15 ppm (bbls/day) 488,758 503,758 510,758 512,678 512,678 518,202

Total 500 ppm (bbls/day) 7,548 7,548 548 548 548 0

Total 15 + 500 ppm (bbls/day) 496,306 511,306 511,306 513,226 513,226 518,202

4

 Alaska refineries are included in this analysis 
IV. NRLM Summary Statistics

 18

C. Comparison of 2005 and 2006 NRLM Pre-Compliance Reports 

Total production of 15 ppm and 500 ppm diesel fuel increased significantly in the 

2006 NRLM pre-compliance reports, compared to the 2005 NRLM pre-compliance 

reports. Table 14 shows the projected volumes of 15 ppm and 500 ppm diesel fuel from 

the 2005 and 2006 NRLM pre-compliance reports for 2010 (in bbls/day, from June 1 to 

December 31). Total reported production of diesel fuel in the 2006 reports was 472 

thousand bbls/day greater than total reported production in the 2005 reports. Several 

refineries in each PADD reported increases in anticipated production, most significantly 

in PADDs 1, 2 and 3. 

Table 14. 

Projected Volumes of (Highway + NRLM) Diesel Fuel by PADD for 2010

Total 

PADD 1 2 3 4 5 U.S. 

2005 NRLM reports

Total 15 ppm, bbls/day 300,822 866,782 1,700,533 149,667 470,176 3,487,980

Total 500 ppm, bbls/day 71 1,083 173,265 11,510 3,100 189,029

Total (15 + 500) ppm , bbls/day 300,893 867,865 1,873,798 161,176 473,276 3,677,008

2006 NRLM reports

Total 15 ppm, bbls/day 461,843 1,001,381 1,920,020 166,439 488,758 4,038,441

Total 500 ppm, bbls/day 71 9,936 78,920 14,054 7,548 110,529

Total (15 + 500) ppm , bbls/day 461,915 1,011,317 1,998,940 180,492 496,306 4,148,970

Increase in reported production, bbls/day 161,021 143,452 125,143 19,316 23,030 471,962
IV. NRLM Summary Statistics

 19

Table 15 shows the projected volumes of 15 and 500 ppm diesel fuel from the 

2005 and 2006 NRLM pre-compliance reports for 2014 (from January 1 to May 31). 

Total reported production of diesel fuel in the 2006 reports was 676 thousand bbls/day 

greater than the total reported production in the 2005 reports. Several refineries in each 

PADD reported increases in anticipated production, most significantly in PADDs 1, 2 and 

3. This includes one PADD 3 NRLM refinery which reported in 2005 that it was not 

planning to produce any 15 ppm diesel fuel after May, 2012, but is now planning to begin 

producing 15 ppm diesel fuel in 2012. 

Table 15. 

Projected Volumes of (Highway + NRLM) Diesel Fuel by PADD for 2014a

Total 

PADD 1 2 3 4 5 U.S. 

2005 NRLM reports

Total 15 ppm, bbls/day 364,589 875,424 1,709,876 158,722 485,176 3,593,787

Total 500 ppm, bbls/day 71 0 27,461 767 100 28,399

Total (15 + 500) ppm , bbls/day 364,661 875,424 1,737,338 159,489 485,276 3,622,187

2006 NRLM reports

Total 15 ppm, bbls/day 465,520 1,009,852 2,068,501 187,104 512,678 4,243,655

Total 500 ppm, bbls/day 71 9,420 44,825 0 548 54,864

Total (15 + 500) ppm , bbls/day 465,591 1,019,272 2,113,326 187,104 513,226 4,298,519

Increase in reported production, bbls/day 100,931 143,848 375,989 27,615 27,950 676,333
V. Appendix

 20

Appendix - List of Acronyms 

bbls/day barrels per day 

bpcd barrels per calendar day 

EIA Energy Information Administration 

EPA (or, “the Agency”) U.S. Environmental Protection Agency 

FR Federal Register 

LM Locomotive and Marine 

NR Nonroad 

NRLM Nonroad, Locomotive, and Marine 

PADD Petroleum Administrative Districts for Defense 

ppm parts-per-million 

ULSD Ultra Low Sulfur Diesel