Submission Number: 627
Submission ID: 8941
Submission UUID: 97609202-6397-43af-af9a-16f0b9ea695d

Created: Tue, 03/05/2024 - 21:48
Completed: Tue, 03/05/2024 - 21:48
Changed: Wed, 03/06/2024 - 07:12

Remote IP address: 69.62.230.105
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes


Submitted Comment
Joshua Kehoe
California Resident
Application No. B0441

See my comments regarding Asian UCO for the pathway application B0440. The same comments apply here. The naphtha from the UCO hydrotreating is complete garbage for gasoline blending, so additional processing will be necessary. I would ask if there is any petchem options for this renewable naphtha? You have a saturated hydrocarbon naphtha product that is best utilized by petchem plants cracking naphtha, so it seems a shame to push this hydrocarbon stream into the gasoline blending pool after whatever secondary reactions are necessary to meet spec. I assume the P66 plant will eventually veer towards SAF over RD, which will result in even more renewable naphtha and other light ends, so it is reasonable to look for the best use of the naphtha-range product.

Thank you,
Josh Kehoe MD

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