TRAA Science Advisory Panel Blog

by Daniel Horowitz, an organic chemist and former managing director of the U.S. Chemical Safety Board.

A fiery refinery blast in Philadelphia could be just the beginning.

Last month’s spectacular explosions at a large Philadelphia oil refinery complex injured five workers, terrorized city residents and drove up gasoline prices. But the impact could have been vastly worse had the explosions triggered a release from the refinery’s huge inventory of toxic hydrogen fluoride — up to 420,000 pounds’ worth, according to information the company filed with the Environmental Protection Agency in 2017. That disaster, had it occurred amid the chaos on the morning of June 21, would have imperiled hundreds of thousands of people living within a few miles of the plant. …

Continue reading on the New York Times website by clicking:
This Chemical Kills. Why Aren’t Regulators Banning It?

By the Torrance Refinery Action Alliance Science Advisory Panel

A Performance Standard Must Be Designed to Protect the Community, Not Tailored to What the Refineries Are Able to Meet with Enhanced Mitigation

Executive Summary

A Performance Standard, with hydrogen fluoride (HF) phase-out if it cannot be met, has become the central approach adopted by the South Coast Air Quality Management District Staff for either a regulation or a memorandum of understanding (MOU) with Valero in Wilmington and PBF’s Torrance Refining Company, the only two refineries in California that use HF. SCAQMD welcomes community input, and the TRAA Science Advisory Panel of six South Bay scientists and engineers is providing expert professional advice with A Rule 1410 Performance Standard to Protect the Community. Its three parts are: 1) A Benchmark, which must be met to ensure the community remains safe if a major HF release occurs, 2) Release Scenarios, which could be caused by Earthquakes, Accidents, or Terrorists (EAT), and 3) Ground rules for the refineries’ attempt to Demonstrate by analysis, modeling, and testing that they can meet the Benchmark. Interim measures are also specified to increase community protection until HF is phased out.

The Performance Standard is summarized below and given with full rationales in the following sections.

• BENCHMARK TO PROTECT THE COMMUNITY
  The general population, including susceptible individuals, shall not experience “irreversible or other serious, long-lasting adverse health effects, or an impaired ability to escape,” as proscribed by Acute Exposure Guideline Level 2 (AEGL 2). All points from the refineries’ fenceline and beyond, shall not exceed any of the AEGL 2 threshold concentrations for exposure durations of 10 minutes, 30 minutes, 60 minutes, 4 hours, and 8 hours.
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• RELEASE SCENARIO
  A rupture of any of the refinery’s HF Containment Subsystems releasing the entire amount of HF: 1) in any duration from 5 seconds to 4 hours or, 2) from the break of any size subsystem pipe.
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• DEMONSTRATION BY ANALYSIS & MODELING
  Only passive mitigation measures, defined by the EPA as “equipment, devices, or technologies that function without human, mechanical, or other energy input,” shall be allowed in the demonstration attempt. In accordance with the EPA’s RMP Guidance for Offsite Consequence Analysis for worst-case releases, active mitigation measures such as water spray shall not be allowed because they can be deactivated by the same calamitous event that causes the rupture.
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  No proprietary data shall be allowed in the analysis or modeling. If after six months the refineries can show they have a creditable plan that can meet the Benchmark, three years shall be allowed for the refineries to carry out a full-scale experimental demonstration to validate their analysis and modeling. Failure of the modeling or experimental verification shall mean all HF shall be removed from the refinery grounds within four years from the initial approval of Rule 1410.
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• INTERIM ENHANCED MITIGATION

1. To protect the public from HF releases in the interim, the refineries shall enhance their mitigation system as much as feasible as determined by the SCAQMD.
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2. The refineries shall have a SCAQMD-approved emergency plan in place within six months, and then institute it, at their expense, to remedy the shocking lack of medicine and facilities to treat victims of a major HF release.
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3. The refineries shall certify within six months, to the satisfaction of SCAQMD, that their operations are safe from a cyber-attack.
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4. The refineries shall demonstrate within six months that they have financial resources in place — through liability insurance, bonds, or corporate resources — to cover claims against them from 15,000 deaths (the estimated fatalities in the 1987 Bhopal, India catastrophe, which released a similar amount of toxic chemical found in one Torrance refinery settler tank). Bankruptcy is not an acceptable response.

Continue reading . . . 

Click the image above to watch TRAA’s short six-minute video of experts testifying on the extreme health and safety danger from a major release of hydrofluoric acid.

View all of the TRAA Videos by clicking here.

Presented by TRAA Member Cliff Heise:

We’re here because two refineries in the South Bay use massive quantities of one of the world’s most dangerous industrial chemicals, “hydrogen fluoride.” An additive touted by refineries for decades as the community’s primary safeguard has been unmasked as completely ineffective. As Congressmember Ted Lieu has stated, the community has been “hoodwinked.” Elimination of hydrogen fluoride is the only measure that will ensure community safety.

Performance Standards

The AQMD has adopted a Performance Standard approach. If the refineries fail to demonstrate that they can protect the public from a major release, then hydrogen fluoride must be phased out.

A Performance Standard Must Be Designed to Protect the Community, Not Tailored to What the Refineries Are Able to Meet with Enhanced Mitigation

We respectfully implore the Refinery Committee to give direction to Staff to create a Performance Standard to protect the community.

Continue reading “TRAA Community Response at the June 22 SCAQMD Refinery Committee Meeting”

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.”

Read the full article by clicking:
HF and MHF – Equivalent Ground Hugging Fog Hazards (Wonkish)

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 out 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.

Click the image above to watch TRAA’s short five-minute video of Los Angeles County Board of Supervisor and AQMD Board Member Janice Hahn speaking at the Board’s February 1, 2019 Meeting.

View all of the TRAA Videos by clicking here.