EPA Has Released Its Proposed Chemical Safety Rule and the News Is Not Good

On Friday August 19 the Environmental Protection Agency released revisions to the RMP rule entitled, “Accidental Release Prevention Program Requirements under the Clean Air Act; Safer Communities by Chemical Accident Prevention.” Among other things, the proposal does not require refineries to phase out HF, but leaves it up to them to determine the need.


What has happened? The EPA has issued a revised rule

The effort to bring about conversion from HF in refineries to one of several commercially proven alternatives took a bad turn with the recent release of the EPA revised rule to “Achieve safer communities through chemical accident prevention”.

While the rule has some advances like confirmation of the exceptional danger of HF and the availability of proven alternative safer technology, it regresses in its solutions.

Here’s what’s wrong with EPA proposed rule

  1. It does not provide a pathway for replacement of dangerous chemicals like HF even though safer alternatives are practically available. “EPA contends that the practicability of these potentially safer alternatives are situation-specific…operators are usually in the best position to make these determinations” EPA uses the term “potentially” while even the American Petroleum In Association says there are “commercially proven alternatives”. This is a shocking statement that abandons the EPA’s General Duty to protect the community by leaving the decision to the owners.
  2. Facilities using chemicals that can cause mass casualties can merely state that it’s not practical to convert. California regulation already requires a safer technology alternative assessment for the last five years with little to no effect. Like California, the EPA rule does not require any third-party audit of the refinery’s assessment nor does it require conversion, if the inherently safer technology is practicable.
  3. It does not consider at all the national security threat of “Soft Targets”. Despite receiving many statements from nationally recognized leaders on the security concerns from HHCs, there is nothing to require greater security attention for such facilities.
  4. It does not consider at all the risk from transportation of chemicals capable of mass casualties. Despite stating EPA collaborates with Departments of Transportation and Homeland Security who are the primary oversight for transportation, there are no provisions for involvement of those departments in this rule to prevent such catastrophes.
  5. It does not even require informing the public about the presence of Highly Hazardous Chemicals (HHC) – Individuals in the six mile radius can request information, but no systematic information distribution is required to the residents of the surrounding communities.

For those of us who lived within the end point for death and serious injury in 40+ communities, we have tested the EPA proposals method to make communities safe from HF/MHF.

It has failed.

See the TRAA response to the proposal.

The EPA requested comments from the public and scheduled public hearings on Sept 26,27, 28 where the public can respond. Perhaps with enough pressure from many quarters, we can force changes in that rule.

Director of Policy Analysis at the Union of Concerned Scientists to Headline TRAA Meeting on September 14 at 7:00 p.m. Pacific Time

Genna Reed, a leader in the Coalition for the Prevention of Chemical Disasters, will speak about the new EPA Proposed Chemical Safety Rule, its strengths and weaknesses, and how to respond.

Genna Reed is the director of policy analysis in the Center for Science and Democracy at the Union of Concerned Scientists. In her role, she leads research on political and corporate influences on science-informed decision making—working to inform the public about issues where science is stifled or obscured, and to ensure that federal, state, and local policies are based on rigorous, independent science.

Genna Reed is the director of policy analysis in the Center for Science and Democracy at the Union of Concerned Scientists.

Before joining UCS, Ms. Reed was a researcher at the public interest non-governmental organization Food & Water Watch, where she studied the effects of genetically engineered foods and other technology on farmers, consumers, and the environment. Ms. Reed also served as a National Network for Environmental Management Studies fellow for the Environmental Protection Agency, where she conducted research on state and federal functional assessment tools to preserve the biological integrity of streams and wetlands.

Ms. Reed earned an M.A. in environmental policy design and a B.A. in biology and psychology from Lehigh University. She has been quoted in E&E News, The Hill, The Intercept, Newsweek, NPR, Politico, Science, and The Washington Post, among other outlets.

To attend the virtual meeting, RSVP with an e-mail request for a Zoom link to TRAA President Steven Goldsmith at info@TRAA.website.

“Hydrofluoric Acid Endangers the Harbor Area” – Random Lengths News

San Pedro’s Random Lengths News is adding its voice to TRAA’s in asking readers to write to EPA Administrator Michael Regan and urge him to adopt a strong rule that requires facilities using chemicals like HF, which pose catastrophic hazards to workers and the community, to convert to an inherently safer chemical when one is available.

Do you live, work, or play in Wilmington, San Pedro, or Long Beach? You are in an Environmental Protection Agency risk circle for death or serious injury from a release of deadly hydrogen fluoride (HF). Wilmington Valero and Torrance PBF refineries use HF for alkylation to make primarily premium gasoline at the pump. Only these two refineries use HF in California. They are vulnerable to accidents, earthquakes, or terrorism. . . .

ToRC - Valero EPA WCS
The United States Environmental Protection Agency (EPA) uses Emergency Response Planning Guidelines (ERPGs) to assess worst-case scenarios. Residents inside the black circles below are at risk of serious and irreversible health effects (ERPG-⁠2). Those inside the red circles are at risk of life-threatening health effects (ERPG-⁠3). Those downwind of an HF release are exposed. Many in the highly dangerous regions close to the refineries rank high for Environmental Justice burden. 

At the direction of President Joe Biden, the EPA is revising their toxic chemical rules in September. Now is the time for you to write the EPA a letter. . . .

Click to read the full article on Random Lengths News.

TRAA’s Monthly Zoom Meeting on Wednesday, August 10 at 7:00 p.m. Pacific Time

TRAA President Steve Goldsmith writes, “I hope to see you at this Wednesday’s Zoom meeting. We’ll be reporting on some important recent developments listed below.”

  1. A report from the County Board of Supervisors Working Group, established with the objective of providing the County with a plan to bring about conversion away from HF. Expected before August 15.
  2. EPA to announce proposed revisions to the Risk Management Plan Rule, which could provide a pathway to bringing about conversion from HF to a vastly safer alternative at all U.S. HF refineries. Expected before September 30.
  3. Five-year deadline for refineries to report on alternatives to HF, which is a California Air Resources Board requirement. Expected before October 30.

To attend the virtual meeting, RSVP with an email request for a Zoom link to TRAA President Steven Goldsmith at info@TRAA.website.

TRAA Asks Community Members to Urge the EPA to Adopt an RMP Rule Requiring HF Refineries to Convert to a Vastly Safer Process

Elimination of HF will provide safety from death — as well as day-to-day peace of mind — for hundreds of refinery workers, their families, and for thousands of others at risk in the community.

The Environmental Protection Agency (EPA), under the leadership of Administrator Michael S. Regan, is in the critical phase of making a long-overdue update to the Risk Management Plan (RMP) rule for facilities that use extremely hazardous substances. EPA’s proposed rule is due this September.

EPA Administrator
Michael S. Regan

TRAA is asking community members to write to EPA Administrator Regan to urge him to adopt a strong RMP rule that requires facilities using chemicals like HF, which pose catastrophic hazards to workers and the community, to convert to an inherently safer chemical when one is available. For refineries using HF, there are proven commercially available alternatives.

TRAA has prepared a letter that can be used as a model. Personalize it and email to Administrator Reagan at Regan.Michael@EPA.gov — or print and mail in an envelope with a stamp. (A copy emailed to info@TRAA.website is kindly requested.)

TRAA’s model letter to EPA Administrator Regan: here

Also, find a letter to Administrator Reagan from 31 Congressmembers and ten Senators here, and a letter from former EPA Administrator and New Jersey Governor Christine Todd Whitman, cosigned by 17 prominent experts, here.

Congressmembers & Senators Call for Strong Risk Management Plan Rule by EPA

“EPA should require hazard reduction and best practice prevention measures, such as transitioning to inherently safer chemicals and processes . . .”

Thirty-one Congressmembers, including Southern California Congressmembers Nanette Barragán, Alan S. Lowenthal, and Karen Bass, and ten Senators call for a strong Risk Management Plan rule by the EPA requiring conversion to inherently safer technology for exceptionally dangerous chemicals (like HF).

Read the letter by clicking here

Congresswoman Nanette Barragán


Documentary Filmmaker Olivia Rosenbloom to Headline TRAA’s Monthly Zoom Meeting on Wednesday, July 13 at 7:00 p.m. Pacific Time

TRAA will screen Olivia Rosenbloom’s documentary Near Miss at the meeting, followed by a short Q&A session.

writer and filmmaker Olivia Rosenbloom is passionate about telling stories that explore the humanity at the root of our most pressing social, political, and environmental issues.

Olivia is director and producer of the 26-minute documentary Near Miss. It tells the story of the infamous 2015 explosion at the Torrance refinery, which local activists discovered almost led to a catastrophic release of a massive amount of highly toxic hydrogen fluoride into the community. Near Miss sheds light on the politics of public safety, environmental health, and environmental racism. Watch a one-minute intro to Near Miss by clicking here.

Documentary Filmmaker Olivia Rosenbloom

Olivia Rosenbloom graduated from Brown University with honors in English Nonfiction Writing in May 2020. Previously, she graduated from the Crossroads School for Arts & Sciences in Santa Monica, California.

To attend the virtual meeting, RSVP with an email request for a Zoom link to TRAA President Steven Goldsmith at info@TRAA.website.

A link to watch the screening of Near Miss will be supplied at the meeting. After watching in the virtual company of fellow meeting attendees, the TRAA meeting will resume on Zoom with a Q&A with Olivia Rosenbloom led by Jane Affonso and other important meeting announcements.

TRAA Voter Advisory Panel’s Recommendation for the June 7 Election – Assembly District 65 Democratic Primary

Click Figure for a Full-Size Version
As of 5/11/2022.

The TRAA Voter Advisory Panel submitted the following three questions to the candidates Mike Gipson and Fatima Iqbal-Zubairc for the Assembly District 65 Democratic Primary on Tuesday, June 7, 2022:

  1. Do you support the phase out of hydrofluoric acid (HF), including modified hydrofluoric acid, at the two South Bay refineries that use it — Torrance Refining Company and Valero Refinery in Wilmington?
  2. A) If an incumbent: What did you do to further the cause of phasing out HF at either one or both South Bay refineries that use it?
    B) If a candidate: What will you do to further the cause of phasing out HF at either one or both of the South Bay refineries that use it?
  3. When elected, what do you commit to doing to help achieve the goal of phasing out HF at the two South Bay refineries that use it?

The Panel compiled the answers and graded the candidates on how closely they aligned with TRAA’s mission of bringing about the conversion of the two Southern California refineries that use massive amounts of highly dangerous hydrogen fluoride (HF) — Torrance Refining Company and Valero in Wilmington — to a modern, vastly safer process, as a growing number of HF refineries in the nation have successfully done or are currently doing. Candidates who didn’t respond were given an F. The results are displayed in the scorecard above.

California’s Assembly District 65 is of high importance because it could be catastrophically impacted by an HF release from both the Torrance Refining Company and Valero Refinery in Wilmington. Assembly District 65 includes Carson, Compton, Watts, Rancho Rancho Dominguez, Willowbrook, Wilmington, North Long Beach, North Harbor Gateway, Broadway Manchester.

“Meet the Candidates” for Torrance’s Upcoming Election at TRAA’s Monthly Zoom Meeting on Wednesday, May 11 at 7:00 p.m. Pacific Time

The TRAA Voter Advisory Panel submitted a questionnaire to the candidates for Torrance Mayor, City Council, and Treasurer in the upcoming election on Tuesday, June 7, 2022 and scored them. The top-scoring candidates have been invited to speak at the start of TRAA’s May 11 meeting.

The following Torrance candidates have confirmed:

  • Cliff Numark – Torrance Mayor
  • Jimmy Gow – Torrance City Council, District 1
  • Jon Kaji – Torrance City Council, District 1
    (joining later if schedule permits)
  • David Zygielbaum – Torrance City Council, District 1
  • Asam Sheikh – Torrance City Council, District 3
    (joining later if schedule permits)
  • Jean Adelsman – Torrance City Council, District 5
  • Tim Goodrich – Torrance Treasurer

Click here to see the scorecard and other important election information.

To attend the virtual meeting, RSVP with an e-mail request for a Zoom link to TRAA President Steven Goldsmith at info@TRAA.website.

L.A. County Supervisor Janice Hahn Receives Sierra Club Environmental Service Award

Janice Hahn has been a leader in the efforts to safeguard the community from a catastrophic release of HF from the two South Bay refineries that use it.

Sierra Club leaders presented LA County Supervisor Janice Hahn with the Sierra Club’s Environmental Service Award. Supervisor Hahn has been a Sierra Club-endorsed candidate since she served in the United States Congress from 2011-2016, and also while standing for election twice for Los Angeles County Supervisor. Hahn also served 10 years on the Los Angeles City Council before she was elected to Congress.

As a Los Angeles County Supervisor and as a SCAQMD Board Member, Janice Hahn has been a leader in numerous important environmental issues, including removal 0f massive amounts of highly dangerous hydrogen fluoride from two Southern California refineries: — Torrance Refining Company and Valero in Wilmington . In February, 2022, she spearheaded a motion, which passed unanimously, for the Los Angeles County Board of Supervisors to send a five-signature letter to Governor Gavin Newsom and Attorney General Rob Bonta urging them to “take all possible actions to require refineries in California to convert from Modified Hydrofluoric Acid (MHF) to safer alternatives.”

The local Sierra Club, and its members as well, have been an active partner of TRAA in its effort to bring about refineries’ conversion from HF to a vastly safer safer alternative technology.

Read the Sierra Club’s press release on Supervisor Hahn Sierra receiving its Environmental Service Award by clicking here.