Video of the 1986 “Goldfish” Release Test of hydrofluoric acid (HF) shows the formation and spread of a ground-hugging toxic cloud. In the test carried out by Lawrence Livermore National Laboratory research scientist Dr. Ronald R. Koopman, 8,300 lbs. of HF were released within 2 minutes. 100% of the acid became airborne in a dense, ground-hugging cloud of deadly HF. Two miles downwind, the HF cloud had more than twice the lethal concentration. Consider that each of the two settler tanks at the Torrance Refinery holds 50,000 lbs. of HF — six times more than the 1986 “Goldfish” Release Test.
Compare these “Goldfish” test results to the large-scale accidental release of the vastly safer alternative sulfuric acid at the Tesoro Refinery in Martinez, California, on February 12, 2014.
While the Torrance and Wilmington Valero refineries use Modified Hydrofluoric Acid (MHF) with 6-10% sulfolane to reduce volatility, the amount is far too little to prevent a toxic cloud, a fact that has been confirmed by the AQMD.
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.
TRAA Science Advisory Panel member Dr. George Harpoles’ seminal article on the equivalent behavior of HF and MHF in a catastrophic accidental release concludes with the paragraph:
“Dangerous concentrations of HF could persist miles away from the refinery. The typical layers-of-protection approach (barriers, water sprays, pumps to spare vessels, etc.) may save lives for certain smaller leaks. However, a more catastrophic rupture, simultaneous with failure or bypass of the protection systems, is easy to imagine – in large earthquakes, accidental or deliberate explosions, or fire. Moreover, the delivery trucks traveling to the refinery carry MHF in similar quantities, and are even more vulnerable. They have no spare vessel or water-spray system. They are exposed to the public and subject to crashes. There is clear danger to the community in the use of MHF at refineries in urban settings.”
Some Thoughts on the South Coast AQMD Rule 1410 Refinery Committee Meeting by the TRAA Science Advisory Panel
Several members of the TRAA Science Advisory Panel attended the AQMD Refinery Committee Meeting in Wilmington CA on September 22, 2018. This was a particularly important meeting because two of the world’s leading experts on the dangers of hydrogen-fluoride use in refineries gave presentations: Dr. Ronald Koopman on the large-scale HF release experiments — The Goldfish Tests — he conducted in the Nevada desert in 1987, and John Cornwell of Quest Consultants, conductor of the only field-scale MHF release tests in Quest’s Oklahoma facility in 1993.
The high point of the meeting was when these two experts answered the $64,000 Question: “Would 6-wt-% MHF act the same as pure HF?
Dr. Koopman expressed his profound skepticism that the additive would do much good — “I would guess that would be a very small effect.” (Watch:https://youtu.be/qwo08BtEQuM?t=7460)
John Cornwell emphasized the small amount of additive is unlikely to have much of an effect, and there’s no data to show that it does. He pointed that physical chemists use mole percent (molecule count), and states, “If MHF is 6% by weight and 1% by mole, and you are going to modify the vapor pressure or modify the characteristics of the fluid, you’ve got to have some data to show that’s true” (Watch:https://youtu.be/qwo08BtEQuM?t=8874).
This publicly-stated testimony by the world’s two leading experts expressed a high degree of skepticism of the refineries’ safety assertions for MHF. They are in line with the TRAA Science Advisory Panel and the SCAQMD Staff. MHF and HF behave the same and both form ground-hugging toxic clouds.