Jeff
Herzog
10/
30/
2003
03:
28
PM
To:
"
dgilligan@
pmaa.
org"
<
dgilligan@
pmaa.
org>
cc:
"
Holly
Tuminello
(
E­
mail)"
<
htuminello@
pmaa.
org>
Subject:
Re:
Heating
oil
marker
Dan,
Following
are
my
responses
to
the
questions
that
you
posed.
Let
me
know
if
you
have
any
other
questions.
Thanks
for
your
help.

Q:
Are
you
aware
that
heating
oil
marketers
frequently
purchase
500ppm
offroad
diesel
and
sell
it
as
"
extra
clean
burning
heating
oil"?
A:
Yes.

Q:
If
a
heating
oil
marketer
had
30,000
gallons
of
1000ppm
heating
oil
(
with
a
marker)
in
storage
and
added
200,000
gallons
of
500
ppm
offroad
diesel
(
without
marker)
to
that
storage,
would
that
matter?
A:
There
would
be
no
limitation
on
the
amount
of
500
ppm
NRLM
diesel
fuel
that
could
be
downgraded
to
heating
oil.
Under
the
scenario
described
above,
all
of
the
contents
of
the
storage
tank
would
need
to
be
marketed
as
heating
oil.

Q:
If
the
marketer
uses
the
same
truck
to
haul
500ppm
offroad
and
heating
oil
(
with
marker),
will
it
matter
that
a
trace
level
of
the
marker
shows
up
in
offroad
fuel?

A:
We
proposed
that
a
level
of
0.1
milligrams
per
liter
would
be
used
as
a
threshold
level
to
identify
heating
oil.
Below
this
level,
incidental
contamination
would
be
assumed
to
have
occurred
and
the
prohibition
on
use
of
marker­
containing
fuels
in
highway,
nonroad,
locomotive,
or
marine
applications
would
not
apply.
(
68FR
28405)
i.
e.:
#
0.1
mg/
liter
would
be
considered
a
"
trace"
marker
level
and
would
not
trigger
an
enforcement
action.
This
parallels
the
heating
oil
marker
requirements
in
the
European
Union.
If
you
have
contacts
in
the
European
counterpart
to
PMAA,
I
would
be
interested
in
hearing
about
their
experiences
in
using
the
same
tanker
truck
compartment
to
alternately
transport
marked
heating
oil
and
unmarked
distillate
fuels.
I
expect
that
the
experience
in
the
EU
in
this
regard
might
be
similar
to
your
current
experience
in
alternately
transporting
red
dyed
diesel
fuel
and
highway
diesel
fuel
in
the
same
tank
truck
compartment.
...
although
the
sensitivity
to
contamination
from
the
solvent
yellow
124
marker
may
be
less
than
that
for
red
dye
given
that
the
color
that
the
marker
imparts
to
the
fuel
will
likely
not
be
noticeable
and
is
not
an
issue
with
respect
the
regulatory
requirements.

Q.
With
an
abundance
of
15ppm
projected
for
2007,
it
is
a
certainty
that
heating
oil
marketers
will
be
buying
15ppm
(
dyed)
to
blend
with
their
heating
oil
stocks
to
offer
a
cleaner
product.
Will
that
matter?
A:
No,
not
as
long
it
is
marketed
as
heating
oil
(
and
meets
all
the
associated
dye
and
marker
requirements).
Q:
It
is
almost
a
certainty
that
some
farmers
will
use
offroad
diesel
for
heating
oil
and
visa­
versa
if
the
price
has
an
advantage.
Will
that
matter?
A:
Farmers
would
be
prohibited
from
using
heating
oil
in
their
offroad
equipment.

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
Dan
Gilligan
<
dgilligan@
pmaa.
org>
Received
Date:
10/
27/
03
12:
01:
32
PM
Transmission
Date:
10/
27/
03
12:
01:
32
PM
Please
respond
to
"
dgilligan@
pmaa.
org"

To:
Jeff
Herzog/
AA/
USEPA/
US@
EPA
cc:
"
Holly
Tuminello
(
E­
mail)"
<
htuminello@
pmaa.
org>
Subject:
Heating
oil
marker
Hi
Jeff.....
Holly
Tuminello
is
working
to
see
how
common
it
is
for
marketers
to
use
the
same
trucks
to
haul
"
non­
dyed"
aviation
fuel
and
dyed
offroad
diesel.
We
suspect
in
rural
areas
it
may
be
happening
on
occasion.

Are
you
aware
that
heating
oil
marketers
frequently
purchase
500ppm
offroad
diesel
and
sell
it
as
"
extra
clean
burning
heating
oil"?
If
a
heating
oil
marketer
had
30,000
gallons
of
1000ppm
heating
oil
(
with
a
marker)
in
storage
and
added
200,000
gallons
of
500
ppm
offroad
diesel
(
without
marker)
to
that
storage,
would
that
matter?
If
the
marketer
uses
the
same
truck
to
haul
500ppm
offroad
and
heating
oil
(
with
marker),
will
it
matter
that
a
trace
level
of
the
marker
shows
up
in
offroad
fuel?

With
an
abundance
of
15ppm
projected
for
2007,
it
is
a
certainty
that
heating
oil
marketers
will
be
buying
15ppm
(
dyed)
to
blend
with
their
heating
oil
stocks
to
offer
a
cleaner
product.
Will
that
matter?

It
is
almost
a
certainty
that
some
farmers
will
use
offroad
diesel
for
heating
oil
and
visa­
versa
if
the
price
has
an
advantage.
Will
that
matter?
Just
curious
how
these
circumstances
might
effect
a
marker
system.

I
look
forward
to
your
response.

Best
Regards,

Dan
Gilligan
PMAA
