Comment Log Display

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.