(Sept. 29, 2018, 1:30 p.m.) -- LBREPORT.com provides links below to extended VIDEO of the September 22, 2018 SCAQMD public hearing (reported by LBREPORT.com on Sept. 23 at this link) that addressed risks raised the use of Modified Hydrofluoric Acid (MHF) at the LB-adjacent Wilmington Valero refinery and the Torrance TORC refinery. HF and MFH are highly corrosive, and an expert on the substance told the SCAQMD Refinery Committee that a 1987 experiment showed that on release HF swiftly produced a ground-hugging cloud, roughly 8 feet high and traveling with prevailing winds, at HF concentrations that could likely cause deaths within 2.9 miles and serious health effects within 4.4 miles.
Dr. Koopman said release of 1,000 gallons of HF through a roughly one and a half inch orifice (nozzle) from a tanker produced HF concentrations at distances as follows:
Dr. Koopman stated: "Just to put that in perspective, the acute emergency response guideline for lethality is only 170 ppm, so we've exceeded that and if you extrapolate that downwind, it extrapolates out to about 2.9 miles. So the lethality threshold extends 2.9 miles downwind from that test." Dr. Koopman also indicated that "serious health effects" were extrapolated begin at 4.4 miles from the release site. Dr. Koopman indicated he's unaware of tests performed that have produced data on MHF (HF with a substance added to "dilute" it) and said he is unclear how much modification of HF's behavior the modifier produces, but said that with a 6% concentration of modifier he "would guess that would be a very small effect." Following the hearing, LBREPORT.com used Google Maps to find relative distances from the Valero Wilmington refinery to various LB reference points. (Long Beach, L.A. County's second largest city, wasn't specifically mentioned during the hearing.)
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VIDEO of the complete SCAQMD Committee hearing (5:41) is available on demand at this link and is also embedded below. LBREPORT.com recommends viewing the following salient items (scroll to location):
All Power Point slides from the SCAQMD Sept. 22 hearing are on SCAQMD's website at this link and Dr. Koopman's PPT presentation is on PPT pages 26-33. Public testimony begins on the VIDEO at 3:03:53.
Only two refineries in CA use MHF. One is the Valero refinery (owned by Ultramar) at 2402 E. Anaheim St. in Wilmington; the other is the ToRC (formerly ExxonMobil) refinery at 3700 W. 190th St. in Torrance. Tanker trucks bringing loads of MHF to the two refineries also travel along LB-area freeways. Residents in Torrance (where a 2015 refinery explosion resulted in a "near miss" that could have released a catastrophic amount of MHF) formed the Torrance Refinery Action Alliance.) It likens the risk of a release in the highly urbanized area to a Bhopal-level mass casualty event and urges a phase-out of the chemical (noting that SCAQMD staff has indicated the refineries could convert to a safer chemical, sulfuric acid, for roughly $300-$600 million.)
The refineries, their employee unions and area business groups oppose a phase-out of MHF and support a "memorandum of understanding" (contract with SCAQMD) agreeing to implement certain enhanced "mitigation measures." In a roughly nine minute Sept. 22 hearing statement, a Valero management representative cited multiple mitigation measures he said were already put in place -- including "water curtains," battery backups, and other containment and mitigation measures -- and said the company is willing to undertake further mitigation measures under an MOU. Supporting the refineries' position were their unionized workers plus a number of supportive regional unions. Also speaking in support of an MOU were representatives of a number of business associations (including the LB Area Chamber of Commerce according to one supportive business group) and some non-profit groups (who indicated the refineries had been supportive of their works.)
Over 800 people attended the Wilmington hearing with no presence of which LBREPORT.com is aware by Long Beach Councilmembers, their office staffs, city staff or LB community groups. Following more than six hours of staff, expert and public testimony (individual public speakers limited to one minute each; groups allowed one spokesperson for ten minutes), the SCAQMD's Refinery Committee directed agency staff to begin a formal rulemaking proceeding that will bring proposed Rule 1410 to the full SCAQMD Board for possible adoption in May 2019 that would implement a controlled phase-out of MHF at the two refineries over a period of years. However during the intervening months before the May 2019 Board action, if the refineries and manufacturer of MHF provide more technical information on the chemical and show that enhanced mitigation measures will adequately reduce the risk to the public, the Committee directed staff to consider bringing a Memorandum of Understanding (MOU) to the Board as a possible alternative to adopting a formal rule. In this case, an MOU would be a contract in which the refinery operators would agree to implement certain SCAQMD-agreed enhanced mitigation measures.
SCAQMD staff indicated that the agency sought data on MHF tests and technology documentation from Honeywell, which said it needed permission from ExxonMobil (the technology developer) to release them, and in August 2018 ExxonMobil indicated it doesn't consent to public disclosure in any form (redacted or not) on grounds the documents contain trade secret and confidential business information. Refinery Committee chair Dr. Clark Parker, Sr. publicly voiced displeasure with the firms' stance that prevented release of information they have on HF/MHF testing and he indicated this was a basis for his stance in supporting moving forward with a formal rulemaking unless additional information comes to light. SCAQMD Board Chair Dr. William Burke didn't take an explicit position on a formal rule vs. an MOU but supported continuing to seek information while the rulemaking process is underway. Two Board members, Joseph Lyou, PhD and Mayor Pro Tem Judith Mitchell supported a rulemaking, stating they believe the MHF risk is too great. Mayor Larry McCallon (Highland) and Ben Benoit (Wildomar) indicated [paraphrase] they consider the risk manageable and supported an MOU instead of a formal rulemaking.
On Sept. 21, LBREPORT.com inquired from City of LB staff if it has taken any position to date on proposed Rule 1410 or if SCAQMD had contacted the City about the issue; a response is currently pending. SCAQMD Media Relations Mgr. Sam Atwood told LBREPORT.com: "With regard to the city manager of Long Beach, they are on the mailing list for our Rule 1410 activities however I don't know whether we have had any direct contact with them on this rule proposal." Since at least 2017, SQAMD has had a "working group" discussing development of proposed Rule 1410. Its roster is visible at this link and indicates it included no representatives of the City of Long Beach or any Long Beach grassroots or neighborhood groups. One of the "working group" members -- representing the City of Los Angeles (Office of Petroleum and Natural Gas Administration) -- is Uduak-Joe Ntuk, who was elected earlier this year to LBCC's governing Board of Trustees. LBREPORT.com spotted Mr. Ntuk at the April 2018 Torrance meeting at which time he politely declined comment and noted his involvement was in the capacity as a representative of the City of Los Angeles. To date, the only LB entity that submitted written comments in the proceeding visible on SCAQMD's website has been the Long Beach Area Chamber of Commerce (August 2017) whose position in August 2017 can be viewed at this link. SCAQMD launched the proceeding after a Feb. 2015 explosion at the Torrance refinery (then owned by ExxonMobil) resulted in a potentially catastrophic "near miss" when "a large fragment struck scaffolding surrounding the MHF alkylation unit...within a few feet of the alkylation unit's settler tanks, each containing hydrofluoric acid (HF), water, hydrocarbons, and a chemical additive intended to reduce the amount of HF vaporized during a loss of containment event." (Source: U.S. Chemical Safety Hazard Investigation Board's investigation visible here.). On September 18, 2017, Valero submitted a letter to SCAQMD visible at this link in which it argued that SCAQMD "has yet to establish a need for any action at all, much less a complete ban" of MHF. In response to union members concerned that banning MHF might result in the refinery's closure costing them their jobs, TRAA said converting the plants to using the less dangerous chemical would maintain their jobs and produce jobs during the conversion. One TRAA speaker, who identified himself as a former long time union member, publicly challenged either of the refinery operators to state publicly whether a rule banning MHF would cause them to close down their operations...and received no public reply. At both the April 28 and Sept. 22 hearings, AQMD staff acknowledged that conversion would involve some down-time/supply reductions but noted these would be planned (possibly staggered) and should have less of an impact than unplanned events. AQMD staff said at the April 28 hearing that converting the Valero Wilmington plant posed additional challenges due to space constraints but didn't elaborate on this at the Sept. 22 hearing. At the April 2018 public hearing, AQMD staff estimated that converting the Wilmington and Torrance refineries to sulfuric acid would cost their operators could be roughly $300-$600 million. AQMD staff indicated in April that an estimate by Burns & McConnell [contracted by TORC] was $600 million if a post-alkylation unit and post processing equipment is included and AQMD staff said post processing replacement may not be needed, in which the is estimated at $300 million. AQMD staff further noted in April that under the new "Tax Cut & Jobs Act, a "full expensing" provisions allows a 100% deduction of the cost of investments from taxable income in every year for up to five years.
Among those previously on record (via letters) supporting a phase-out/ban on MHF are the L.A. County Board of Supervisors (unanimously), state Senator [and US Senate candidate] Kevin de Leon (D, L.A.), Assemblyman Al Maratsuchi (D, south bay), Assemblyman David Hadley (R, southbay). Congressmembers Ted Lieu (D, southbay/WLA) and Nanette Barragan (D, southbay/Carson) and the cities of Manhattan Beach, Hermosa Beach and Redondo Beach. A majority of the Torrance City Council (home to the TORC refinery) stopped short of supporting a phase-out, instead urging continued research for alternative solutions such as solid acid and liquid iontic catalyst processes; two Torrance Councilmembers strongly dissented and sent letters supporting a phase-out. Thus far, to our knowledge, the City of Long Beach has taken no position on the issue...and neither Mayor Robert Garcia nor any incumbent LB Councilmember(s) have agendized the issue for public discussion and possible Council action. Developing...with further to follow on LBREPORT.com
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