Jeff
Herzog
09/
19/
2003
05:
40
PM
To:
"
Grant,
Andrea
­
DC"
<
Andrea.
Grant@
piperrudnick.
com>
cc:
Subject:

Andrea,

In
IFTOA's
and
NEFI's
comments
on
the
nonroad
diesel
proposed
rule,
it
is
stated
that
a
fuel
marker
would
not
be
needed
in
heating
oil
because
EPA
could
test
fuel
sulfur
content
to
distinguish
NRLM
from
heating
oil.
I
think
this
statement
might
indicate
a
misunderstanding
of
some
of
the
aspects
of
the
proposed
rule.

EPA
proposed
refiner
credits
and
small
refiner
provisions
that
would
allow
for
the
limited
production
and
use
of
high
sulfur
NRLM
fuel
for
some
time
after
most
refiners
would
be
required
to
produce
only
500
ppm
sulfur
NRLM
fuel.
Such
high
sulfur
NRLM
fuel
could
eventually
be
blended
with
500
ppm
NRLM.
Consequently,
EPA
could
not
use
a
sulfur
test
to
distinguish
heating
oil
from
NRLM
fuel
during
the
time
period
when
small
refiner
and
credit
high
sulfur
NRLM
could
be
used
in
NRLM
equipment.
Without
a
marker
for
heating
oil
during
this
period,
EPA
would
not
have
a
mechanism
to
ensure
that
heating
oil
is
not
used
in
NRLM
equipment.

I'll
supplement
your
comments
to
the
docket
with
what
ever
response
you
might
want
to
provide
to
this
e­
mail
Best
regards,

Jeffrey
A.
Herzog,
Mechanical
Engineer
United
States
Environmental
Protection
Agency
National
Vehicle
and
Fuel
Emissions
Laboratory
Assessment
and
Standards
Division
2000
Traverwood
Drive
Ann
Arbor,
Michigan,
48105
Phone:
(
734)
214­
4227
Fax:
(
734)
214­
4816
E­
Mail:
herzog.
jeff@
epa.
gov
