P.1 

OAR Box 1834 

Prepped by Keeia Richards 

Document Number: 

39) IV-E-12 

Docket Number: 

A-90-07 

Printed 11/10/2008 2:14:35 PM Sheet 39 of 61 
P_J__ 

. -" osr-v. 

m 

\mf*C V 

/)-?o-o7 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR, MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

ialis t / ^ 

MAY 2 0 1994 

MEMORANDUM 

SUBJECT: Conversations with Representatives of Witco 

Corporation 

FROM: Robert Johnson, Environmental Protection Spec 

Special Regulatory Projects Branch 

THRU: Judith Gray, Senior Project Manager/*f//p''*'^\ 

Special Regulatory Projects Branch / / / / 

TO: Air Docket A-90-07 / 

On May 18, 1994, I contacted Mr. Howard Cunningham of Witco 

Corporation, Woodcliff Lake, NJ, regarding comments (Docket Item 

IV-D-21) that Witco had submitted in response to the Notice of 

Proposed Rulemaking entitled Fuels and Fuel Additives Registration 

Regulations, 57 FR 13163 et. seg. (April 15, 1992) . In those 

comments, Witco had stated that "Diesel fuels from napthenic crudes 

cannot meet certain test parameters of ASTM D-975...," which EPA 

had proposed as necessary criteria in order to be included in the 

category of baseline diesel fuel. Since the Witco comments were 

not specific as to which parameters of ASTM D-975 were being 

referenced, I contacted Mr. Cunningham, whose signature appeared on 

the comments. Mr. Cunningham could not provide an immediate 

response to my question, and referred me to Mr. Jerry Baker, of 

Witco's Golden Bear Division in Oildale, CA. 

Upon contacting Mr. Baker, I learned that the parameter in 

question was the requirement for a minimum cetane index of 40, 

which Witco felt it could not meet due to inherent differences in 

diesel fuel produced from napthenic crude oil. This issue had also 

been raised in EPA's earlier rulemaking pertaining to sulfur 

content of diesel fuel (55 FR 34131, August 21, 1990) and EPA had 

provided an alternate parameter of 35 percent (vol.) maximum 

aromatic content in that final rule. Since this latter option has 

subsequently been incorporated in the latest version of ASTM D-975, 

(October 25, 1993) it appears the issue is no longer an obstacle to 

Witco's product being grouped with baseline diesel fuel. 
P.3 

5asy 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

ANN ARBOR. MICHIGAN 48105 

OFFICE OF 

AIR AND RADIATION 

MAY 2 01994 

MEMORANDUM 

SUBJECT: 

FROM: 

THRU: 

TO: 

Conversations with Representatives of Witco 

Corporation 

Robert Johnson, Environmental Protection Specialist 

Special Regulatory Projects Branch 

Judith Gray, Senior Project Manager/ £f/r/^ } 

Special Regulatory Projects Branch/ If I ] 

Air Docket A-90-07 uv/ 

On May 18, 1994, I contacted Mr. Howard Cunningham of Witco 

Corporation, Woodcliff Lake, NJ, regarding comments (Docket Item 

IV-D-21) that Witco had submitted in response to the Notice of 

Proposed Rulemaking entitled Fuels and Fuel Additives Registration 

Regulations, 57 FR 13163 et. seg. (April 15, 1992) . In those 

comments, Witco had stated that "Diesel fuels from napthenic crudes 

cannot meet certain test parameters of ASTM D-975...," which EPA 

had proposed as necessary criteria in order to be included in the 

category of baseline diesel fuel. Since the Witco comments were 

not specific as to which parameters of ASTM D-975 were being 

referenced, I contacted Mr. Cunningham, whose signature appeared on 

the comments. Mr. Cunningham could not provide an immediate 

response to my question, and referred me to Mr. Jerry Baker, of 

Witco's Golden Bear Division in Oildale, CA. 

Upon contacting Mr. Baker, I learned that the parameter in 

question was the requirement for a minimum cetane index of 40, 

which Witco felt it could not meet due to inherent differences in 

diesel fuel produced from napthenic crude oil. This issue had also 

been raised in EPA's earlier rulemaking pertaining to sulfur 

content of diesel fuel (55 FR 34131, August 21, 1990) and EPA had 

provided an alternate parameter of 35 percent (vol.) maximum 

aromatic content in, that final* rule,:^Sincazthia. latter, optipn has 

• '" ' "^ _ «^ #*v^ _r^5B^IF_"U^_H?^ * 

subsequently^been incorporated* i»tfi_E4i&i»t_^ Or975,? (October; 25/|l993)^1^appearil^Kpiss' 

Witco's product' beingygroupec!^ifch?' 1 H 
P.4 

Corooraticn 

FROM: PvCbert Johnson, Environmental Protection Specialist .""''' 

Special Regulatory Projects Branch 

THRU: I Judith Gray, Senior Project Manager • / ;' -• 

Special Regulatory Projects Branch .• / 

TO: Air Dockec A-90-0 7 

On May 18, 1994, I contacted Mr. Howard Cunningham of Witco 

Corporation, Woodcliff Lake, NJ, regarding comments (Docket Item 

IV-D-21) that Witco had submitted in response to the Notice of 

Proposed Rulemaking entitled Fuels and Fuel Additives Registration 

Regulations, 57 FR 13163 et. sec. (April 15, 1992) . In those 

comments, Witco had stated that "Diesel fuels from napthenic crudes 

cannot meet certain test parameters of ASTM D-975...," which EPA 

had proposed as necessary criteria in order to be included in the 

category of baseline diesel fuel. Since the Witco comments were 

not specific as to which parameters of ASTM D-975 were being 

referenced, I contacted Mr. Cunningham, whose signature appeared on 

the comments. Mr. Cunningham could not provide an immediate 

response to my question, and referred me to Mr. Jerry Baker, of 

Witcc's Golden Bear Division in Oiidaie, CA. 

Upon contacting Mr. Baker, I learned that the parameter in 

cuestion was the requirement for a minimum cetane inde:: of 40, 

which Witco felt it could not meet due to inherent differences in 

diesel fuel produced from napthenic crude oil. This issue had also 

been raised in EFA's earlier rulemaking pertaining to sulfur 

content of diesel fuel (55 FR 34131, August 21, 1990) and EPA had 

provided an alternate parameter of 35 percent (vol.) maximum 

aromatic content in that final rule. Since this latter option has 

subsequently been incorporated in the latest version of ASTM D-975, 

(October 25, 1993) it appears the issue is no longer an obstacle to 

Witco's product being grouped with baseline diesel fuel. 
I > P.5 

I 

. .L. =;_.t . _ . 

-'ROL-: I'.obert uchnscn, Environmental Protection Specialist .

/w,i"' 

Special Regulatory Projects Branch 

THRU: Judith Gray, Senior Project Manager -' j ''' 

Special Regulatory Projects Branch j 

On May IS, 1994, I contacted Mr. Howard Cunningham of Witco 

Corporation, Woodcliff Lake, NJ, regarding comments (Docket Item 

IV-D-21) that Witco had submitted in response to the Notice of 

Proposed Rulemaking entitled Fuels and Fuel Additives Registration 

Regulations, 57 FR 13163 et. sec. (April 15, 1992) . In those 

comments, Witco had stated that "Diesel fuels from napthenic crudes 

cannot meet certain test parameters of ASTM D-975...," which EPA 

had proposed as necessary criteria in order to be included in the 

category of baseline diesel fuel. Since the Witco comments were 

not specific as to which parameters of ASTM D-975 were being 

referenced, I contacted Mr. Cunningham, whose signature appeared on 

the commentc. Mr. Cunningham could not provide an immediate 

response tc my question, and referred me to Mr. Jerry Baker, of 

'•'i-;cr: Goider. Bear Division in Oildale, CA. 

"jpor. contacting I.r. Baker, I learned that the parameter in 

ejection was the requirement for a minimum cetane inde:-: of 40, 

which Witco felt it could not meet due to inherent differences in 

diesel fuel produced from napthenic crude oil. This issue had also 

beer, raised in EPA' s earlier rulemaking pertaining to sulfur 

content of diesel fuel (55 FR 34131, August 21, 1990) and EPA had 

provided an alternate parameter of 35 percent (vol.) maximum 

aromatic content in that final rule. Since this latter option has 

subseauentiy been incorporated in the latest version of ASTM D-975, 

•er 25- 1993' it appears the issue is no longer an obstacle to 

s product beinc grouped with baseline diesel fuel. 

/ ,• . ~ -