First Name | Miles |
---|---|
Last Name | Heller |
Email Address | miles.t.heller@tsocorp.com |
Affiliation | Tesoro |
Subject | MRR comments on 15-day package |
Comment | Tesoro appreciates the work CARB has done in clarifying certain provisions in the proposed regulation. Tesoro has two substantive issues remaining - one new one based on the 15-day changes and one that we wish to reiterate. 1. The new issue related to reporting of CWB for ISOM units. This corrects an inconsistency with how the reactor feed is reported with Solomon surveys. Tesoro recommends the following language: 95113 (l) (5) (A) Should read: Reporting of CWB Throughputs Functions. The operator must report the annual throughput for each CWB unit listed in Table 1 of this section, using the appropriate units listed in column 3 of Table 1 of this section. With the exception of C4 Isomer Production and C5/C6 Isomer production, reported throughputs based on feed must include only fresh feed and exclude recycled streams. Throughputs for C4 Isomer Production and C5/C6 Isomer production should be based on reactor feed including recycle. 2. 95103 (h)(4): Tesoro does not agree with the elimination of best available methods for measuring by-product hydrogen. The by-product hydrogen is not currently incorporated into the CWB calculation and resultant allocations so it should not be subjected to the more stringent accuracy requirements; and therefore, subject to increased enforcement risk. Please retain the flexibility to comply with BAM for these meters consistent with this provision in the current regulation. |
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Date and Time Comment Was Submitted | 2014-10-17 07:19:31 |
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