Gotta agree with the logic of Megaladon, the COTU unit worked well for the slopes needs for +40 years.  This small footprint distillation process has no waste by products.  Residue oil, after the diesel is distilled out is put back into the Slope production line.  COTU cannot meet the ultra low sulfur EPA requirements, needed for the lower 48.  Even if COTU could take the sulfur out, there is nothing the Slope can do with this by-product.  To use tankers going up the haul road from Nikiski or Valdez and returning empty is absolutely nuts.  I can assure you the Russian Arctic oil fields are not hauling diesel +800 miles and then sending tanker trucks back +800 miles to a refinery empty.  This is one EPA rule that some bureaucrat needs to issue a variance for North Slope's COTU.  Roll-overs and diesel air and ground spill pollution along the road from Valdez or Nikiski are going to continue until someone uses common sense.