MEMORANDUM
Subject:
Phone
calls
discussing
possible
downstream
downgrade
provisions
in
the
nonroad
final
rule
From:
Jeff
Herzog,
Mechanical
Engineer
Assessment
and
Standards
Division,
Office
of
Transportation
and
Air
Quality
To:
Environmental
Protection
Agency
(
EPA),
Air
Docket
A­
2001­
28
Date:
April
22,
2004
Phone
conversations
were
held
on
March
26,
2004
to
discuss
the
possibility
and
implications
of
a
provision
to
allow
downgraded
fuel
generated
from
contamination
and
mixing
in
the
distribution
system
to
continue
to
be
sold
into
the
locomotive
and
marine
diesel
market
beyond
2014.
The
purpose
of
the
possible
provision
was
to
respond
to
concerns
expressed
in
comment
regarding
the
need
for
an
outlet
for
offspec
product
and
the
difficulty
transmix
processors
would
have
in
hydrotreating
this
fuel
to
bring
it
into
compliance.
The
following
table
identifies
the
people
with
whom
conversations
were
held.

Who
Representing
Michele
Joy
Association
of
Oil
Pipelines
Mike
Vanderburg
Kinder
Morgan
Transmix
Processing
Robert
Woodruff
Explorer
Pipeline
