The February 1, 2019 Southern California AQMD Staff presentation to the full Governing Board was an important milestone in Rule 1410 to deal with the threat of a catastrophic release of Hydrogen Fluoride (HF) into the community. The goal was for the Staff to inform the full Board on the background and need for Rule 1410, give a status on the Staff’s recommended approach, and seek guidance from the Board on the direction they wanted the Staff to take.
The SCAQMD’s Deputy Executive Officer for Planning, Rule Development & Area Sources, Dr. Philip Fine, made by all accounts an impressive presentation, while being mindful of the need to be evenhanded to both sides of the issue.
View the video of the Dr. Fine’s presentation by clicking here.
What is a Performance Standard?
It appears that Performance Standard is often being confused with and sometimes incorrectly equated to Enhanced Mitigation. (Note, for clarity in this discussion, the crucial terms are capitalized and bolded.) It should be clear from several posts on this blog that there is no Enhanced Mitigation that will protect the community from a catastrophic MHF release. A valid Performance Standard will make this all too apparent, as discussed below.
The Performance Standard concept for the current Rule 1410 was first introduced at Working Group #9 on November 16, 2018, and many may have seen it for the first time in the February 1, 2019 Staff presentation, where it is explained in the section What is a Performance Standard? starting on chart 34.
There are three key elements: 1) a Benchmark that ensures the community will be protected, 2) MHF Release Scenarios, that postulate realistic, catastrophic ruptures, and 3) an attempt at a Demonstration, by analysis, modeling, or testing, to show the Benchmark can be met. Failure means MHF would have to be phased out.
- A Performance Standard sets a Benchmark that refineries must meet for continued use of MHF. The Benchmark will ensure the community is protected. For example, the Benchmark could be “in the event of a catastrophic release, the airborne MHF at the fenceline will be well below the threshold for permanent health effects.” The Benchmark is set to what is needed to protect the community, not what the refineries are capable of with Enhanced Mitigation. There’s an enormous gulf between the two.
- Potentially catastrophic Release Scenarios are defined as part of the Performance Standard. The scenarios could be caused by Earthquakes, Accidents, or Terrorists (EAT), as Board Member Dr. Joseph Lyou commented. The TRAA Science Advisory Panel proposed a realistic catastrophic Release Scenario in Point II of the post:
Five Points TRAA Science Advisory Panel Members Would Have Liked to Make at the Rule 1410 Refinery Committee Meeting, namely:
An 80,000 lb object, hurled by an explosion from 12-stories high, rips off a 6-inch-diameter feed pipe from the bottom of a settler tank. This nearly happened at the Torrance Refinery on Wednesday, February 18, 2015. All 50,000 lbs of superheated MHF would have been expelled in about 1 minute and flash-atomized into a ground-hugging toxic cloud.
- If the refineries cannot Demonstrate, by analysis, modeling, or testing, that they can meet the Benchmark under the prescribed catastrophic Release Scenarios, then MHF would have to be phased out. In a break with the past, the refineries will not be allowed to use proprietary data, out of view of the public. For the realistic examples given above, any competent engineer would conclude the chances are zero that the Benchmark could be met with Enhanced Mitigation.
The AQMD Staff’s proposed use of a Performance Standard is central to its approach to a Rule or a Memorandum of Understanding (MOU). It is important to understand how it works, as the Rule 1410 proceeds toward its conclusion.
~ Jim Eninger, Ph.D.