Jeff
Herzog
04/
09/
2004
08:
54
AM
To:
BBrown@
ColPipe.
com,
MELeister@
MAPLLC.
com,
Andrea.
Grant@
piperrudnick.
com,
mjoy@
aopl.
com
cc:
Subject:
Potential
Adjustment
to
Southern
Boundary
of
Draft
Exclusion
Area
Under
NR
Final
Rule
Gentlefolk,
At
the
meeting
in
Washington
D.
C.
on
April
5,
2004,
Buster
Brown
of
Colonial
Pipeline
questioned
whether
the
proximity
of
fuel
distribution
terminals
in
Charlotte
North
Carolina
to
the
North
Carolina­
South
Carolina
boundary
of
the
exclusion
area
suggested
that
we
might
consider
adjusting
the
Southern
boundary
of
the
exclusion
area.
I
re­
evaluated
the
fuel
distribution
pathways,
and
patterns
of
heating
oil
use
in
the
Southern
end
of
the
current
draft
exclusion
area
(
Virginia,
and
North
Carolina)
and
in
the
adjacent
states
(
Tennessee,
and
South
Carolina).
Based
on
this
re­
evaluation,
I
continue
to
think
that
it
is
most
appropriate
to
draw
the
Southern
boundary
of
the
exclusion
area
on
the
North
Carolina
­
South
Carolina
border.
The
decision
to
draw
the
boundary
there
was
primarily
based
on
the
sharp
drop
off
in
heating
oil
use
in
moving
South
from
North
Carolina
(
113,
584,
000
gal/
yr)
to
South
Carolina
(
15,585,000
gal/
year).
I
tried
looking
at
heating
oil
use
by
county
in
North
Carolina
(
I
received
from
data
from
the
North
Carolina
Petroleum
Marketers
Association),
but
this
didn't
necessarily
suggest
there
is
a
more
appropriate
place
to
draw
the
boundary
(
let
me
know
if
you
would
like
to
see
this
data).
I
talked
to
Buster
on
April
6th,
and
he
also
come
to
the
conclusion
that
the
North
Carolina
­
South
Carolina
border
is
as
good
a
place
as
any
to
draw
the
Southern
boundary
of
the
exclusion
area.
Unless,
I
hear
back
from
you­
all,
I'll
consider
this
issue
closed
and
that
there
isn't
substantial
room
for
improvement
on
the
current
draft
boundary
of
the
exclusion
area.

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
