1
Mark
Morgan
<
ptsa@
erols.
com>
10/
27/
2003
10:
36
AM
To:
Jeff
Herzog/
AA/
USEPA/
US@
EPA
cc:
Subject:
Re:
Request
for
PTSA's
input
on
the
potential
for
contamination
of
jet
fuel
with
the
proposed
heating
oil
marker
Good
Morning
Jeff:

I
would
be
happy
to
provide
you
with
the
input
you
requested.
I
will
talk
to
some
of
my
members
and
see
what
they
are
doing
and
thinking
about
this
issue
and
get
back
to
you
next
week.
Thanks
for
seeking
our
input.

Mark
Mark
S.
Morgan,
Esq.
Executive
Director
Petroleum
Transportation
and
Storage
Association
4200
Wisconsin
Avenue,
N.
W.,
Suite
106
Washington
D.
C.
20016
(
202)
364­
6767
Herzog.
Jeff@
epamail.
epa.
gov
wrote:

>
>
Mark,
>
This
note
is
to
request
your
input
on
whether
the
safeguards
taken
>
by
smaller
fuel
distributors
which
handle
both
jet
fuel
and
heating
oil
>(
such
as
those
represented
by
PTSA)
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
likely
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
2
>
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
>
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
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.
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.
>
>
Thanks
for
consideration,
>
>
Jeffrey
A.
Herzog,
Mechanical
Engineer
3
>
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
