Jeff
Herzog
12/
11/
2003
02:
48
PM
To:
stewart.
byrnes@
faa
cc:
Paul
Machiele/
AA/
USEPA/
US@
EPA
Subject:
EPA's
pro
fuel
marker
requirements
for
heating
oil
Skip,
I
am
sorry
we
missed
the
recent
CRC
conference
call.
I
was
in
the
hospital
with
the
flu
(
and
not
sufficiently
mindful
of
my
calendar),
and
the
time
did
not
show
up
on
my
bosses
calendar
because
the
time
had
not
been
confirmed.
I'm
fine
now.
I
talked
to
Tim
Belian
of
CRC
about
the
call.
He
related
that
CRC
was
going
to
hold
off
on
doing
any
work
towards
evaluating
the
compatibility
of
markers
for
use
in
jet
fuel
until
FAA
has
a
clear
picture
about
what
resources
it
might
have
to
contribute
to
the
effort.
From
talking
to
Tim,
I
gathered
that
you
would
our
point
of
contact
with
FAA
on
the
marker
issue.

The
course
EPA
is
currently
following
in
our
off­
highway
diesel
rulemaking
effort
would
allow
the
point
of
marker
addition
to
be
moved
to
the
terminal
level.
The
most
substantial
concerns
re
the
potential
for
contamination
of
jet
fuel
with
the
proposed
heating
oil
marker
pertained
to
bulk
shipments
of
marked
heating
oil
(
by
pipeline).
If
the
point
of
marker
addition
is
moved
to
the
terminal
level,
we
believe
that
the
potential
for
contaminating
jet
fuel
with
the
proposed
heating
oil
marker
would
be
minimal.
Both
the
CRC
and
EPA
received
input
from
large
and
small
terminal
operators
and
bulk
plant
operators
re
the
potential
for
jet
fuel
to
be
contaminated
with
the
proposed
heating
oil
marker.
They
related
that
they
maintain
stringent
controls
to
prevent
the
contamination
of
jet
fuel
with
red
dye
and
that
these
controls
should
also
proven
the
contamination
of
jet
fuel
with
the
proposed
fuel
marker.
In
most
cases,
the
systems
for
handling
heating
oil
and
jet
fuel
at
the
terminal
level
and
below
are
segregated.
In
certain
instances,
small
operators
sometimes
use
the
same
tank
wagon
to
alternately
transport
heating
oil
and
jet
fuel
(
to
small
airports).
However,
industry
input
indicates
that
they
are
always
careful
to
flush
the
tank
prior
to
its
use
for
jet
fuel.

If
the
marker
is
added
to
heating
oil
at
the
terminal
(
as
we
currently
envision),
the
IRS
red
dye
would
always
be
present
in
heating
oil
when
the
marker
is
present.
This
would
allow
the
current
"
white
bucket
test"
to
serve
as
an
indicator
of
contamination
of
jet
fuel
by
both
red
dye
and
the
proposed
heating
oil
marker.
Based
on
the
above
discussion,
we
do
not
expect
the
instances
of
jet
fuel
contamination
to
increase
due
to
the
addition
of
the
proposed
fuel
marker
to
heating
oil.
In
cases
where
heating
oil
might
contaminate
jet
fuel,
the
presence
of
red
dye
will
allow
for
ready
detection
of
such
contamination
as
it
does
today.
Therefore,
we
do
not
expect
that
the
presence
of
the
proposed
fuel
marker
in
heating
oil
would
exacerbate
concerns
re
jet
fuel
purity.

In
FAA's
written
comments
to
the
public
docket
for
the
proposed
off­
highway
rule,
FAA
requested
that
EPA
delay
finalizing
the
proposed
fuel
marker
requirements
until
further
research
of
the
potential
impact
of
these
provisions
can
be
conducted.
Would
FAA's
concerns
be
satisfied
if
EPA
were
to
move
the
point
of
marker
addition
to
the
terminal
level?
In
such
a
case,
would
FAA
would
withdraw
its
request
for
EPA
to
delay
finalization
of
the
proposed
marker
requirements?

Thanks
for
your
consideration.

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
