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The South Coast Air Quality Management District (SCAQMD) recently issued another notice about an unplanned flaring event at the Torrance Refinery, containing the following SCAQMD Link. According to the website:
A gas flare, also known as a flare stack, is a gas combustion device used in a variety of industrial plants. In petroleum refineries, flares are used as safety devices to prevent over pressure of equipment via planned and unplanned flaring.
– Planned Event: Used for scheduled maintenance, plant startup/shutdown, or other activities where the refinery can reasonably anticipate the need to dispose of excess combustible gas.
– Unplanned Event: Used for emergencies caused by equipment failure, power outage, or other unanticipated event which requires the refinery to dispose of the gases in order to prevent harm to workers, the community, or to the environment.
The link also led to a list of all the flaring events at the Torrance Refinery, and showed that, so far this year, there have been 10 Planned and 23 Unplanned events. That means that there are about 2 emergencies per month at this refinery! And another planned event has just been announced.
With a safety record like this, how can we feel safe living so near, when they use massive quantities of the deadly hydrogen fluoride (HF)? There were 5 small HF releases between 2017 and 2019. The AQMD has not revealed how many HF releases have occur in the last 3 years. Why not?
The following are the key highlights, as seen by TRAA, from a powerful 70-page document submitted by 21 Attorney Generals across the United States, including California AG Rob Bonta. This document focuses on the 11 pages directly related to the use of HF in refineries. The special focus put on HF by the AGs comments is both a reflection of the chemical’s extreme risk to frontline communities, and of the decades-long effort to eliminate the use of HF in favor of a vastly safer alternative.
The bottom line of this Comment Letter is stated on page 43: “It is EPA’s responsibility to pave the way for the elimination of hydrofluoric acid alkylation.”
The Comment Letter submitted to EPA is extremely dense and heavily footnoted with powerful support for each of the points. While selecting most (but not all) of the key points, this summary is still 6 Pages! We added the numbering for clarity, but did not add wording or change the order of the arguments.
Read More to see the full TRAA Comments.
We urge readers to review the entire document with its extensive supporting arguments and footnotes. Link to full AG document.
From the California Attorney General’s Press Release on November 1st:
“California Attorney General Rob Bonta, as part of a multistate coalition, announced the filing of a comment letter in support of the U.S. Environmental Protection Agency’s (EPA) proposal to strengthen chemical accident prevention regulations. . . .
“In the letter, the coalition expresses their support for the EPA’s proposal to strengthen the federal chemical accident prevention program, particularly the provisions addressing refineries that use hydrofluoric acid, commonly referred to as ‘HF,’ in their alkylation processes. HF is a uniquely hazardous chemical that when released can form a toxic, ground-hugging cloud that can travel far outside refinery boundaries that irritates the eyes, nose, and respiratory tract, and at high exposure levels can cause cell damage and even death. Two refineries in California use HF in their alkylation processes: the former ExxonMobil refinery in Torrance, now owned by the Torrance Refining Company, and the former Ultramar refinery in Wilmington, now owned by Valero Energy Corporation. Both HF-using refineries are adjacent to disadvantaged communities. . . .”
As oil refineries reported their 3rd quarter profits, it became clear that there is no excuse for not converting their alkylation processes from HF to a much safer proven alternative.
PBF Energy, California’s third biggest oil refiner, made a whopping $2.26 billion off refining gasoline, tripling its profit in the third quarter. That indicates they could make us all much safer, and modernize their refinery, for about twelve days PROFIT.
And Valero’s third-quarter financial report showed that the San Antonio company made $2.82 billion from July to September. This caused Governor Newsom to renew his call for a price-gouging penalty “to put these profits back in the pockets of Californians.” per an LA Times Article.
Yet they continue to operate with “business as usual” despite general concerns about the environment and specific concerns about the safety of the surrounding community. And we wonder why gas prices are so high!
During the EPA’s public comment period for August 2022, three TRAA members participated by speaking on the rule. President Steve Goldsmith, Vice-President Jane Affonso, and member Zach Badaouie each spoke to the clear shortfalls of the revised rule. Each used the time to highlight the well known dangers of HF to public health and national security, while also calling on other environmentalists to organize around the issue. Even if our efforts fall upon deaf ears, it was certainly well worth the allotted three minutes to speak on such a critical issue. In addition to the live comments, TRAA is going to submit a written comment along with a deluge of files and videos on the need for action on HF. We hope that they fall on the right eyes and ears..
TRAA issued a Press Release on Sept. 29 about the EPA Hearings. It told that National Security experts led by Former Governor and EPA Administrator Christie Todd Whitman submitted their third letter, warning of terrorist attacks on refineries and chemical facilities using chemicals that can cause mass causalities and called for conversion to commercially proven safer alternative technology.
Joining scores of environmental and chemical disaster prevention organizations and over 100 speakers in the course of the three-day EPA Public Comment hearings ending Wednesday evening, the experts that included General Russel Honore of Katrina recovery fame stated ” as individuals with extensive experience in national security and environmental protection, we must tell you that the rule is not nearly strong enough to protect Americans from chemical disasters.”
TRAA member Laurie Armer has created a petition to require HF-using refineries to convert to a safer alternative. It is in conjunction with the EPA hearings to remove the most hazardous chemicals from the workplace. Follow this link:
The LA Times reported on a new study from Harvard University that unveiled a new interpretation of the previously known Palos Verdes Fault System. The study concluded that what was previously thought to be a network of small segmented faults is actually a system of interconnected fractures. When triggered, the result would potentially be a more widespread earthquake than previously thought, capable of unleashing energy comparable to that which would be released by a rupture on the famed San Andreas fault with magnitude up to 7.8.
Like the San Andreas Fault, which cuts through Northern California’s densely populated Bay Area, the Palos Verdes Fault passes underneath the densely populated regions of Long Beach, Torrance, and the Beach Cities, and within four miles of the Torrance Refinery and three miles of the Wilmington Valero Refinery.
Regardless of design mitigation steps taken by the refineries, the experience at Fukushima Nuclear Power station in 2011 demonstrated that natural disasters in excess of design limits can occur, and can have catastrophic results.
While scientists estimate the Palos Verdes Fault to be relatively inactive and slow moving, they also estimate damage and death from a rupture without considering the implications of potential release of HF. The high cost of such a release must be considered.
Janice Hahn placed the attached official motion on the agenda for the Tuesday September 13th Board of Supervisors meeting. The motion calls for a letter from the County of Los Angeles Board of Supervisors to the EPA calling for the strengthening of the proposed new rule. Specifically calling for the required conversion from HF to a safer alternative.
The motion passed unanimously – Thank You Janice Hahn!
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. The draft Rule, while having some good points, falls short in too many ways as we heard in Genna Reed’s presentation at our meeting on Wednesday, September 14th.
TRAA is asking community members to write to EPA Administrator Regan to urge him to adopt a stronger 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. Or post it directly on the Comments page on the EPA Website. (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.