TRAA Member sends Citizen Petition to EPA regarding Title-V Permit

Dr. Genghmun Eng submitted a Formal Petition to the EPA Administrator at the US EPA National Headquarters (HQ), objecting to the Region 9 US EPA acceptance of the Title-V Permit Renewal from the SCAQMD as-is for the Valero Ultramar HF Refinery in Wilmington. Although the Region 9 Staff accepted the SCAQMD Permit Renewal version, they suggested that Gengh submit a Formal Petition to the US EPA HQ about his concerns. However, he was warned that US EPA Formal Petitions have a lot of additional requirements, as compared to a simple Public Comment.
Gengh completed his Formal Petition to the US EPA HQ within the limited timeframe allowed, citing numerous deficiencies and outright errors in the permit and its processes, as well as requesting specific needed permit additions and modifications, both being required by the Petition process. He showed that many documents submitted by the refinery operator, which were the basis of the SCAQMD and US-EPA acceptance of the Permit Renewal, were either incomplete or deliberately misleading.
In addition, the US EPA Region 9 Staff sent Gengh a formal letter, stating: “Please note that we cannot object to a permit based on concerns about health and safety that are not related to a Clean Air Act {CAA}”. The CAA was passed in 1970, and the US EPA was also created in 1970 to enforce the CAA.
However, the HF-Alkylation systems were only installed at the Torrance Refinery in 1966, at the Valero Ultramar Refinery in 1969. As ‘new technology’ back then, the refinery industry also created models where even a massive HF release was deemed nearly 100% ‘safe’, because their models claimed that the HF would just fall to the ground as ‘rainout’, and be rendered harmless by means unspecified and unknown. This assumption that HF was nearly 100% ‘safe’ is probably why HF risks are not prominent in the CAA. This ‘rainout’ model was the universal industry belief, and the 1987 Koopman ‘Goldfish’ tests in the Nevada desert released 1000 gallons (about 8000 pounds) of pure HF were conducted to prove that this model was correct. So the Koopman test had collection pans all along the HF release path, to collect the ‘rainout’.
Unfortunately, those tests showed ZERO ‘rainout’. Instead, a massive ground-hugging HF cloud formed, which would have been toxic within minutes to humans 2-3 miles away. So HF went from being nearly 100% ‘safe’ by assumption, to being nearly 100% ‘unsafe’ by test.
As a result, Gengh’s Formal Petition claims that the US EPA erred in 1987, by not demanding an HF phaseout back then, when those Koopman test data first became known. His Petition also requests that the US EPA now correct this historical error by requiring an HF/MHF Phase-Out at the Valero Ultramar Wilmington HF Refinery, as part of their Title-V Permit Renewal. We, the Public, will see what happens next in the coming months. Here is the complete Document.