A Performance Standard Must Be Designed to Protect the Community, Not Tailored to What the Refineries Are Able to Meet with Enhanced Mitigation
The South Coast Air Quality Management District (SCAQMD) has proposed Rule 1410 to address the threat of a catastrophic major release of highly toxic hydrogen fluoride (HF) into the community from two refineries in the South Bay— Valero in Wilmington and PBF’s Torrance Refining Company in Torrance. The Torrance Refinery Action Alliance (TRAA) — a volunteer, grassroots, community group — is seeking a ban on the use of HF. TRAA’s goal is to have HF removed from the two South Bay refineries within four years from the time SCAQMD finalizes its rule-making process. It may take longer for the refineries to transition to one of the vastly safer alkylation processes; but no longer than four years into that process, the last of the HF must be removed from the refineries.
The Performance Standard approach, along with other approaches, was first presented by the SCAQMD Staff to the AQMD Board’s Refinery Committee on September 22, 2018. Since then, a Performance Standard, with HF phase-out if it cannot be met, has become the central approach adopted by the Staff for either a regulation or a memorandum of understanding (MOU) with the refineries. TRAA has a policy of not taking a position on a particular approach. However, given that the SCAQMD has adopted an approach based on a Performance Standard, TRAA’s Science Advisory Panel of six South Bay scientists and engineers with extensive and applicable academic training and career experience, while not endorsing this approach, has a vital interest in providing expert professional advice to ensure the approach is scientifically sound and leads to the elimination of HF from the refineries. The TRAA Science Advisory Panel’s Performance Standard was written with the Torrance refinery in mind; however, it also applies to Valero. The hyperlinks add important content — they should not be skipped over.