Dear Mr. Ting:…

Dear Mr. Ting:

This letter provides input from Suncor Energy Inc. regarding EBR Registry # 013-1374 Amendments to the Petroleum Refining and Petrochemical – Industry Standards. Suncor is supportive of the proposed changes contained in this EBR Posting with the exception of Paragraph 6. Based on current operation at the Suncor Sarnia refinery and other Suncor sites, we have the following comments and suggested edits regarding the use of travelling skimmers underneath an internal floating roof on a separation bay of a primary oil-water separator:
•An internal floating roof can be used on a separation bay occupied by a skimmer that is designed to travel along the separation bay providing the roof floats on the liquid at all times while in operation.
•An exception for an internal floating roof is required for the clearance of the travelling skimmer drive chain that travels between the drive motor, located above the floating roof, to the skimmer system which is located underneath the floating roof.

The opening for a travelling skimmer drive chain accounts for a small surface area compared to the internal floating roof on the main separation bay. At the Sarnia refinery, the travelling skimmer drive chain opening is 1.45 ft2 which accounts for 0.04% of the total floating roof surface area (3,200 ft2). This small opening is required to reliably operate the travelling skimmer system, operations needs to view the drive train to ensure that the travelling skimmers are functioning correctly and to allow for inspection. Additionally, the motor for the drive train cannot function underneath the liquid. Although a small amount of vapour would be expected out of this opening, an enclosure around the drive train could potentially form an explosion risk.

Aside from this opening being less than 0.05% of the total surface area of the main separator bay. It would be impractical to put an enclosure with an appropriate emission control around the drive chain for the following reasons:

•It would still need to be opened for monitoring purposes every shift (twice per day) to ensure the travelling skimmers are functioning.
•If there was an emission control it would likely be a nitrogen blanket, this would mean that when the enclosure was opened twice/day we would have to shut off the nitrogen as a safety mechanism for the operator and restart the nitrogen after the inspection.
•When the nitrogen is shut-off and the enclosure is opened there would be still be a small emission to the atmosphere.
•The amount of time it would take for the operator to perform these tasks would take his attention away from other priorities at the Waste Water Treatment Plant.

[Original Comment ID: 211288]