Question 8: How will the recently announced EPA regulations on emissions impact your refinery operation and specific technologies [FCC, hydroprocessing, coking, CDU/VDU (crude distillation unit/vacuum distillation unit), reforming, etc.]?

Refinery risk and technology rules were adopted last week on September 29th. They are expected to have a significant impact on the refining industry. The rules require additional control and monitoring of the emissions from the refineries and the emission reporting that is available to the public and other neighboring communities.

Question 6: Do LTOs contain higher concentrations of nitrogen? If so, how has this higher concentration effected gasoline processing units?

The LTOs generally do not contain a higher concentration of nitrogen. LTOs are typically characterized as light, sweet, low-sulfur, low-nitrogen crudes. For example, the Eagle Ford and the Bakken nitrogen typically contains less than 2 ppm. Nonetheless, the gasoline processing units are impacted when refineries process higher percentage of the LTOs because of the crudes.

Question 4: How will increased production of naphtha from light tight oil (LTO) and Tier 3 regulations affect the economics for alkylate and reformate production? Are there other options for processing light naphtha streams?

That was a great Keynote address this morning because it talked about the LTOs, and Ramón Loureiro described them in detail. A couple of other options are to take the light naphtha through an isomerization unit and separate out the C5s and C6s to possibly get the benzene precursor removed from the reformer.

Question 3: How have you developed integrity operating windows (IOWs) to follow American Petroleum Institute (API) Recommended Practice (RP) 584? How are the IOWs maintained and communicated to the operating staff?

Shell and Motiva have been on a journey, for well over 15 years, to educate our operators and provide them with the information necessary to operate their units within the safe operating window. The starting point is to define the unit operating window in terms of temperature, pressure, flows, etc.

Question 1: When preparing reformer or isomerization vessels for maintenance, do you measure the benzene content of the unit? If so, what methods and locations are monitored and what criteria are used to establish safe levels for work to begin?

The corresponding OSHA regulation 1910.1082 states that the actionable limit for contact with the airborne benzene is 0.5 ppm (parts per million) on an eight-hour time-weighted average (TWA) and 5 ppm for a 15-minute TWA basis. In our facility, we have set our practices to meet that standard.

Question 84: What effects, if any, have you observed concerning slurry pump-around exchanger fouling when processing shale oil/tight oil feeds?

Our expectation would be that there could be issues on both the slurry side (tube side) of the exchangers and the shell side in FCC feed preheat service. Of the two, we would expect fouling on the feed side of a slurry/feed exchanger to be most impacted due to the waxy nature of shale oils with the propensity of paraffins to undergo thermal cracking to form coke in high temperature services.