MEMORANDUM
Subject:
Conference
Call
with
API
and
NPRA
to
discuss
possible
provisions
to
provide
an
outlet
for
offspec
product
in
the
nonroad
rule
From:
Paul
Machiele,
Fuel
Programs
Center
Director
Office
of
Transportation
and
Air
Quality
To:
Environmental
Protection
Agency
(
EPA),
Air
Docket
A­
2001­
28
Date:
April
21,
2004
A
conference
call
was
held
with
API
and
NPRA
on
March
26,
2004
to
discuss
possible
provisions
to
provide
an
outlet
for
offspec
product
should
EPA
finalize
the
15
ppm
standard
for
locomotive
and
marine
diesel
fuel
in
the
nonroad
rule.
Several
possible
flexibilities
were
discussed.
API
and
NPRA
representatives
expressed
concern
over
all
of
the
possible
flexibilities.
The
argued
that
a
possible
provision
to
allow
a
small
amount
of
offspec
product
produced
at
the
refinery
gate
to
continue
to
be
sold
into
the
locomotive
and
marine
market
was
not
necessary
or
helpful
and
that
other
flexibilities
raised
potential
enforcement
and
competitive
concerns.
In
order
to
address
the
needs
for
an
outlet
for
offspec
product,
their
recommendations
were
to
either
not
finalize
the
15
ppm
standard
for
locomotive
and
marine
diesel
fuel
at
all,
or
to
increase
the
downstream
test
tolerance
on
all
15
ppm
diesel
fuel
considerably.

The
following
industry
representatives
participated
in
the
call:
°
Ed
Murphy
­
API
°
Charlie
Drevna
­
NPRA
°
Peter
Lidiak
­
API
°
Gary
Schoenveld
­
ConocoPhilips
°
Mike
Leister
­
Marathon­
Ashland
°
John
Medley
­
Exxon/
Mobil
The
following
EPA
representatives
participated
in
the
meeting:
°
Margo
Oge
°
Chet
France
°
Paul
Machiele
°
Richard
Rykowski
°
Jeff
Herzog
°
Lester
Wyborny
°
John
Hannon
°
Maureen
Delaney
