1
David
Doane
<
DDoane@
ILTA.
org>
10/
24/
2003
09:
32
AM
To:
Jeff
Herzog/
AA/
USEPA/
US@
EPA
cc:
Subject:
RE:
Request
for
input
from
ILTA
on
the
potential
for
contamination
of
jet
fuel
with
the
EPA
proposed
heating
oil
marker
Jeff,
Thank
you
for
providing
ILTA
with
the
opportunity
to
provide
you
with
information.
I
will
forward
your
request
to
a
number
of
our
terminal
members
who
meet
the
criteria
you
specified.
Please
let
me
know
the
deadline
for
our
response.
We
will
work
within
whatever
timeframe
you
have.
Best
regards,
David
­­­­­
Original
Message­­­­­
From:
Herzog.
Jeff@
epamail.
epa.
gov
[
mailto:
Herzog.
Jeff@
epamail.
epa.
gov]
Sent:
Thursday,
October
23,
2003
3:
21
PM
To:
David
Doane;
Renita
Gross
Subject:
Request
for
input
from
ILTA
on
the
potential
for
contamination
of
jet
fuel
with
the
EPA
proposed
heating
oil
marker
Importance:
High
David,
This
note
is
to
request
your
input
on
whether
the
safeguards
taken
at
smaller
terminal
facilities
which
handle
both
jet
fuel
and
heating
oil
(
such
as
those
represented
by
ILTA)
to
prevent
jet
fuel
contamination
by
heating
oil
and
the
IRS
red
dye
would
also
be
sufficient
to
prevent
the
contamination
of
jet
fuel
with
the
marker
that
we
proposed
be
added
to
heating
oil
under
the
nonroad
diesel
fuel
proposed
rule.

As
you
are
aware,
the
Coordinating
Research
Council
(
CRC)
fuel
marker
task
force
was
formed
to
address
concerns
regarding
the
potential
contamination
of
jet
fuel
with
the
proposed
heating
oil
marker.
Under
our
proposal,
the
fuel
marker
would
be
needed
in
heating
oil
to
ensure
that
heating
oil
would
not
be
diverted
into
the
nonroad,
locomotive,
and
marine
(
NRLM)
diesel
pool
because
we
could
not
rely
on
the
measurement
of
sulfur
content
to
differentiate
NRLM
diesel
from
heating
oil.
This
is
because
in
the
early
years
of
the
program
we
proposed
to
allow
small
quantities
of
high
sulfur
fuel
destined
for
the
NRLM
market
to
continue
to
be
manufactured
by
small
refiners
and
under
the
proposed
refiner
credit
provisions.
We
proposed
to
allow
this
high
sulfur
NRLM
fuel
to
be
blended
downstream
with
other
NRLM
fuel
that
was
manufactured
to
the
proposed
500
ppm
sulfur
standard.

We
proposed
that
the
fuel
marker
be
added
to
heating
oil
at
the
refinery.
The
majority
of
concerns
voiced
about
potential
marker
contamination
of
jet
fuel
pertain
to
shipments
of
marked
heating
oil
in
2
pipelines
that
also
carry
marked
heating
oil.
If,
as
we
hope,
we
are
able
to
finalize
a
designate
and
track
system
of
ensuring
refiner
compliance
with
the
proposed
desulfurization
requirements
(
in
place
of
the
proposed
baseline
approach),
we
may
be
able
to
move
the
point
of
marker
addition
to
the
terminal
level
(
when
red
dye
is
injected
per
IRS
requirements).
Moving
the
point
of
marker
addition
to
the
terminal
might
alleviate
the
majority
of
jet
fuel
contamination
concerns.

The
CRC
task
force
has
received
input
from
a
number
of
larger
terminals
which
indicates
that
their
fueling
hardware
and
practices
would
essentially
preclude
any
potential
for
contaminating
jet
fuel
with
heating
oil
containing
the
proposed
marker
(
or
with
the
marker
itself).
However,
there
remains
some
concern
within
the
CRC
group
that
this
may
not
be
the
case
for
smaller
terminals
and
other
entities
that
would
distribute
both
jet
fuel
and
marked
heating
oil.

I
would
appreciate
any
input
that
you
may
be
able
to
provide
regarding
situations
at
your
member
facilities
(&
operations)
where
there
may
be
a
risk
of
contaminating
jet
fuel
with
the
fuel
marker
that
we
envision
would
be
added
to
heating
oil
(
at
the
time
the
IRS­
required
red
dye
addition
takes
place
at
the
terminal),
and
what
measures
would
be
necessary
to
mitigate
such
risks.
I
am
particularly
interested
in
cases
where
the
same
equipment
would
be
used
for
handling
jet
fuel
and
marked
heating
oil,
and
what
measures
that
are
already
in
place
to
prevent
red
dye
(
and
heating
oil)
contamination
of
jet
fuel.
Also
of
interest
are
the
safeguards
currently
in
place
to
prevent
the
accidental
injection
of
red
dye
into
jet
fuel,
and
the
quality
control
measures
that
might
be
implemented
to
ensure
the
proper
functioning
of
injection
equipment
used
to
add
the
fuel
marker
to
heating
oil
(
to
prevent
accidental
overuse
of
the
marker).
I
believe
that
the
presence
of
a
fuel
marker
in
addition
to
the
red
dye
downstream
of
the
terminal
would
not
make
the
task
of
limiting
contamination
of
jet
fuel
more
difficult
than
it
is
today,
and
request
your
input
on
this
assessment.
I
would
also
appreciate
your
input
on
how
your
members
would
handle
injecting
the
fuel
marker
into
heating
oil,
including
what
additional
hardware
might
be
needed.

Thanks
for
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
