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PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified Hydrogen Fluoride (HMF) Catalyst TUESDAY, OCTOBER 13, 2015 CITY OF TORRANCE

PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

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Page 1: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

PUBLIC WORKSHOP Regarding ExxonMobil’s use of ModifiedHydrogen Fluoride (HMF) Catalyst TUESDAY, OCTOBER 13, 2015

CITY OF TORRANCE

Page 2: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Workshop AgendaOVERVIEW OF WORKSHOP: M. Giordano, Assistant City Manager

ELECTROSTATIC PRECIPITATOR SYSTEM & STATUS: B. Ablett, ExxonMobil Plant Manager

HISTORY OF CONSENT DECREE TO ALLOW USE OF MHF: J. Fellows, City Attorney

PRESENTATION BY COURT APPOINTED SAFETY ADVISOR: S. Maher

OVERVIEW OF SEPTEMBER 6, 2015 INCIDENT: D. Dumais, Deputy Fire Chief

REGULATORY CONTROLS OVER REFINERY: M. Serna, Assistant Fire Chief

GOING FORWARD: L. Jackson, City Manager

CLOSURE: ◦ Discussion by Mayor and City Council

◦ Public Input◦ Summary of Follow-up

CITY OF TORRANCE

Page 3: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

ELECTROSTATIC PRECIPITATORSYSTEM & STATUSAND REFINERY CURRENT STATUSBRIAN ABLETT, EXXONMOBIL PLANT MANAGER

EXXONMOBIL TORRANCE REFINERY

Page 4: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

FCCs take hydrocarbons and break apart the large, complex molecules in them to make them suitable for blending gasoline.

Fluid Catalytic Cracking (FCC) Operation

REACTOR

REGENERATOR

AIR

OLDESPS

NEWESPS

Hydrocarbon

Gasoline

Catalyst is like fine dust, and is called “Particulate Matter (PM)”.

Simplified Flow Diagram – not all Equipment Shown4

Page 5: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

PM that leaves the FCC Regenerator must be controlled to meet the Rule 1105.1 PM limit before being discharged from the FCC stack.

Electrostatic Precipitation

5

Electrostatic Precipitator (ESP)

AQMD Rule 1105.1 imposed stricter PM limit

on FCCs in Southern CA

Page 6: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

• New ESPs placed in service in early 2009 and replaced the Old ESPs. • The New ESPs’ performance resulted in PM emissions below the stringent Rule 1105.1

PM limit.

New ESPs Installed to Comply with Rule 1105.1 PM Limit

Picture – Old ESP

Picture – New ESP

Average PM Emissions, FY 2008

(last operation)

~21 lb/hr

Average PM Emissions, 2009 - 2014

~9 lb/hr

6

Old ESPs New ESPs

Page 7: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

By reducing PM emissions from other refinery sources, the increased PM from the use of the Old ESPs can be offset.

Proposed Interim Operations

Picture – Old ESP

Picture – New ESP

Cooling Towers

Furnaces & Boilers

Interim Operations Proposal is

Emissions Neutral

<~15> lb/hr

reduction

<~9> lb/hr

reduction

Contingency if needed

7

Page 8: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Current Refinery Operation w/o Interim Operations

• Operating well below full refinery capacity Normally run ~155,000 barrels of crude oil per day and produces 1.8 billion

gallons of gasoline per year

• Impact to California energy supply 3rd largest refinery in Southern CA with 20% of the region's FCC capacity Gasoline, Jet fuel, Diesel, Liquefied Petroleum Gases (LPG)

• Significant reduction of tax revenue for City of Torrance ~$5M less in YTD 2015 vs. 2014

• 650 refinery employees and 550 contractors

• Local vendors and businesses supporting the Refinery

8

Page 9: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

HISTORY OF CONSENT DECREE TO ALLOWUSE OF MHFJOHN FELLOWS, CITY ATTORNEY

CITY OF TORRANCE

Page 10: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

1987 1989 1990

TIMELINE OF CITY REVIEW

City takes action

Mobil and City arrive at a settlement involving a Consent Decree which is under court supervision

Significant fire at Mobil Refinery involving HF unit

• Cause: Alkylation Unit where Hydrofluoric acid is used

• Incident occurred November 1987

April 1989 Public Nuisance lawsuit filed to eliminate use of HF by refinery.

• Agreed to Judge Harry Peetris

• Oct 19,1990: Consent Decree entered

CITY OF TORRANCE

Page 11: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Judge appoints Safety Advisor (cost is reimbursed by refinery) per court order on June 27th 1991 of a budget of $360,0000.

The invoices submitted at the end of the agreement totaled $1,351,199 (increased to $1,735,199 in 1994).

Final report supports modified HF over Sulfuric Acid and puts in place a series of recommended actions.

Safety Advisor does safety audit, comparing risk assessments of proposed MHF process and alternative of Sulfuric acid.

Advisor sets forth required safety steps and procedures.

19911991 1991

TIMELINE OF CITY REVIEW - CONTINUED

CITY OF TORRANCE

Page 12: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

• Detection equipment and warning systems

• Closed circuit monitoring of Alkylation Unit by City

• Refinery perimeter improvements

• Fire water system

• Safety training for employees and contractors

• Safety programs for handling of hazardous materials

• Seismic safety• Traffic control

systems

• Firefighting capabilities and procedures

• Emergency response program

• Environmental and safety practices

• Audit procedures of safety and environmental practices and procedures

ADVISOR SETS FORTH REQUIRED SAFETY STEPS AND PROCEDURES

19911991 1991

TIMELINE OF CITY REVIEW - CONTINUED

CITY OF TORRANCE

Page 13: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

TIMELINE OF CITY REVIEW - CONTINUED

Final closeout:The last open items of the Consent Decree were completed in December 2008

After all actions completed:Consent decree sunsets HF to be phased out by December 31, 1997

1997 2008 2010

Final closeout:Final SA report to Court 2010

CITY OF TORRANCE

Page 14: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Purpose of the Consent Decree

Phase out AHF Catalyst by December 31, 1997

Phase in MHF Catalyst if Safety Advisor satisfied that released MHF would not form an aerosol or dense vapor cloud

Court to retain jurisdiction over phase out of AHF Catalyst and implementation of Safety Advisor recommendations

CITY OF TORRANCE

Page 15: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Primary Function of Safety Advisor

Investigate, Evaluate and Make Safety Recommendations Related to the Alkylation Unit

Recommendations become binding on the City and Mobil unless objected to or modified by the Court

CITY OF TORRANCE

Page 16: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Safety Advisor Reporting

Monthly status reports to Judge

Accepted as final by Judge

All initial Consent Decree objectives completed by end of 2000

Final Safety Advisor recommendation completed May 2010

CITY OF TORRANCE

Page 17: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Post Consent Decree Protocol

Objectives

Scope

Ongoing Obligations

CITY OF TORRANCE

Page 18: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

PRESENTATION BY COURT APPOINTEDSAFETY ADVISORSTEVEN T. MAHER, PE CSPDR. GEOFFREY D. KAISER

RISK MANAGEMENT PROFESSIONALS CORP.

Page 19: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Briefing to Torrance City CouncilConsent Decree Background &

MHF Alkylation Unit Risks (October 13, 2015)

Steven T. Maher, PE CSP &Dr. Geoffrey D. Kaiser (presenters)

Risk Management Professionals949/282-0123

www.RMPCorp.com

Page 20: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Steven T. Maher, PE CSP

• 35-Year Engineer – 31 in Process Safety Consulting Specializing in Hazard Analysis and Quantitative Risk Assessment (QRA)

• Mechanical Engineering– BS – Duke University– MS – Carnegie-Mellon University

• Professional Engineer – Mechanical & Chemical Engineering

• “Certified Safety Professional” by the Board of Certified Safety Professionals (www.BCSP.org)

• Center for Chemical Process Safety (CCPS) Technical Steering Committee – mid-1980s

• Past-President Southern CA Society for Risk Analysis• Paper & Book Publications – See www.RMPCorp.com

Page 21: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Geoffrey D. Kaiser, PhD

• 47 Years Experience – 41 in Risk Assessment/Risk Management

• Degrees from Cambridge University, UK– BA and MA in Natural Sciences (Physics)– PhD in Theoretical Elementary Particle Physics

• Well Known for Atmospheric Dispersion and Consequence Modeling of Hazardous Materials

• 30 Years Experience in Process Hazards Analysis in Chemical Plants and Refineries

• Trained in Security Vulnerability Analysis by the American Institute of Chemical Engineers (AIChE)

• Over 100 publications – list available on request

Page 22: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Key Topics

• Role of the Safety Advisor (SA)• Consent Decree Guidelines for the SA• Evaluation Focus• Timeline• Safety Advisor’s Conclusion & Court

Ruling• Alkylation Unit Release Phenomenology

(Why outcomes can appear counterintuitive)

Page 23: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Consent Decree Framework for Torrance Refinery

Modified Hydrogen Fluoride (MHF) Alkylation Unit

Risk Assessment

Page 24: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Role of the Safety Advisor

• Key MHF Alkylation Unit Assessment Team Members– Steven T. Maher – Hazard Scenario Evaluation & QRA

Assembly– Geoffrey D. Kaiser – Consequence Modeling &

Release Phenomenology Expert

• Team Function– Thorough & Defensible Technical Assessment on

Behalf of the Court– Advise the Court

• Other Objectives– Address Questions/Concerns from the Community, the

City, & Mobil

Page 25: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Role of the Safety Advisor

• Even though the Safety Advisor worked with the Community, the City, and Mobil, it is important to note:– THE SAFETY ADVISOR REPORTED ONLY TO THE

COURT, AND ITS ONLY RESPONSIBILITIES WERE TO THE COURT.

Bold, blue lines represent important day-to-day interaction.

Page 26: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Consent Decree Guidelines for the Safety Advisor

• The Torrance Refinery’s requirements under the Consent Decree and the Safety Advisor’s (SA’s) Evaluation Criteria were Defined by October 19, 1990 Consent Decree & September 30, 1994 Stipulation and Order.

• Objective - Determine if the Torrance Refinery was able to demonstrate to the satisfaction of the Safety Advisor that– “the catalyst as modified would not form an aerosol

or dense vapor cloud upon release.”, or– “the modified HF catalyst (including mitigation)

presents no greater risk than a sulfuric acid alkylation plant producing a comparable amount of alkylate.”

Page 27: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Evaluation Focus

• Thus, a focus of the SA’s evaluation was a Quantitative Risk Comparison of the proposed Modified HF (MHF) Alkylation Unit with a Sulfuric Acid Alkylation Unit of like capacity (i.e., consideration of both the potential consequences and the likelihood of an event) through:– Review of Mobil’s Analysis Details and Results– Performance of Independent Calculations to

Evaluate Mobil’s Proposed MHF System– Benchmarking Against the Risk Assessment

Results of Other Refinery Alkylation Units– Use of a Societal Risk Index (SRI) for

Comparisons

Page 28: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Evaluation Focus

• Specific Topics for the Quantitative Risk Comparison Review:– Accident Scenario Identification– Accident Scenario Frequencies – Consequence Analysis – Accident Scenario Quantification and Risk

Assembly– Uncertainty Characterization and Simplifying

Assumptions– Transportation and Regeneration Risks – Comparison with Other Published and

Unpublished Risk Results– Emergency Response

Page 29: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Timeline

• 1990 – Consent Decree Process Initiated (with Initial Alkylation Unit Evaluation Criteria Established)

• 1994 – Initial MHF Evaluation Completed by the Safety Advisor

• 1997 – Anhydrous HF (AHF) Phase-out

• 1998 – Evaluation by the SafetyAdvisor of Revised MHFOperational Parameters withSeveral Changes Made toEnhance Mitigation:– Settler Pans– Acid Circulation Pump Barriers– Flange Shrouds

Page 30: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Timeline

• 1998-2001 – Safety Advisor Evaluation of the Impact on Risk Associated With:– Changes in Additive Concentration– Storage Tank Inspections– Various Temporary Operations (also resulting in the

establishment of criteria for addressing the acceptability of minor design and operational modifications to the Alkylation Unit)

• All of these efforts involved significant interaction with Mobil and the City, including review and comment of technical reports and conclusions, prior to submittal to the Court for approval and enforcement.

Page 31: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Safety Advisor’s Conclusion & Court Ruling

• Two Key Safety Advisor Reports– December 31, 1994 (Updated May 1995) – “EVALUATION OF

MODIFIED HF ALKYLATION CATALYST (In Support of Consent Decree Section 4)”

– October 1999, “EVALUATION OF MODIFIED HF ALKYLATION CATALYST (ANALYSIS OF PROPOSED ADDITIVE CONCENTRATION CHANGES)”

• Release Characterization – Releases of Modified HF from the Torrance Refinery MHF Alkylation

Unit would not form an off-site aerosol, and plume density is nearly identical to that of air.

• Results of the Quantitative Risk Comparison– “The best estimate risk and phenomenology results clearly identify

MHF and sulfuric acid as being of comparable risk, with alkylation using a modified HF catalyst showing lower calculated best estimate risk values.” This is a long way of saying that, based on the Safety Advisor’s 1994 evaluation, MHF Alkylation is no worse, and in fact is slightly less risk, than Sulfuric Acid Alkylation.

Page 32: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Safety Advisor’s Conclusion & Court Ruling

• Technologies Other Than MHF and Sulfuric Acid Alkylation– In 1994, when the Safety Advisor’s evaluation was

completed, although other alkylation technologies were being developed in laboratories (e.g., solid alkylation catalysts), there were no viable alternatives to MHF or Sulfuric Acid Alkylation at that time.

• After carefully reviewing the Safety Advisor’s report, City of Torrance Staff presented the SA’s findings to the City Council, which upon Staff’s recommendation, concurred with the Safety Advisor’s Report to the Court.

• On April 21, 1995, the Court issued an Order identifying that "The Honorable Harry V. Peetris ... hereby APPROVES the Safety Advisor's Evaluation of Modified HF Alkylation Catalyst ...,“ thus ruling on the acceptability of applying Mobil’s MHF Alkylation Technology at the Torrance Refinery.

Page 33: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Alkylation Unit Release Phenomenology

(Why outcomes can appear counterintuitive)

Page 34: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Important PhenomenologyAHF/MHF

• Atmospheric Boiling Points Differ– AHF 67.1 oF: Typical MHF 88 oF (depends on additive

concentration)• Vapor Pressures at Typical Settler Temp. of 105 oF

– AHF 2 Atm; MHF 1.3 Atm. • Influence on Airborne Rate of Release from Settlers

– Rate of evaporation of HF from airborne droplets and from pools on ground reduced for MHF

– MHF not susceptible to flash atomization, AHF is (both verified by experiment)

– Amount of HF vapor remaining airborne after a release of MHF generally much less than from an equivalent AHF release

• Depends on several factors such as additive concentration, water concentration, temperature

• 65% reduction chosen as a conservative value in 1994 QRA• Biggest single factor driving reduction in MHF risk vs AHF risk

Page 35: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Key Health Effects Assumptions

• Consequence Assessment: – Used ERPG-3 as Representative Endpoint

for both hydrogen fluoride and sulfuric acid– Assumed Haber’s Law to Extrapolate to

Small Durations of Release (based on experiments for HF and a literature review for sulfuric acid):

• (airborne concentration)x (exposure duration) = constant

• e.g., 10 minute ERPG-3 = 6x(I-hr ERPG-3)

Page 36: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Illustrative MHF Single Release Analysis

• 2” diameter orifice in bottom of settler• With 65% release rate reduction factor, 22.3 kg/s

(49.0 lb/s) HF vapor remains airborne• Two scenarios considered:

– Unmitigated: all MHF droplets travel until they fall to the ground, settler emptied in about 7 minutes

– Mitigated: activation of water sprays at 1 and 2 minutes; acid evacuation system at 2 minutes

• Weather conditions: atmospheric stability category F, windspeed 1 m/s (~ 2.2 mph).

Page 37: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Single MHF Release Scenario Representative Results

• Airborne HF concentrations calculated at closest housing (400 m/1,300 ft)

• Results presented as “Fence-line Dose Ratio”: = (predicted airborne concentration)/(ERPG-3)

• Ratio Results– Mitigated release ~ 6– Unmitigated release ~ 18

Page 38: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Sulfuric Acid• Properties of Sulfuric Acid

– Atmospheric Boiling Point (BP) 639 oF (cf AHF 67.1 oF)– Vapor Pressure (VP) @68 oF ~0.001 mmHg (cf AHF 783

mmHg, cf Atmospheric Pressure 760 mmHg = 1 Atm.)– Vapor Pressure at Typical Settler Temperature (105 oF) < 1

mmHg (cf AHF ~ 1500 mmHg ~ 2 Atm.)• Conclusion 1: sulfuric acid alone cannot evaporate as

quickly as HF if spilled during transportation or from storage• Conclusion 2: sulfuric acid alone will not flash atomize even

at typical settler temperatures• Why Is Sulfuric Acid Alkylation Risk Not Very Small?

– In the settler, sulfuric acid is mixed with hydrocarbons– e.g., propane, BP -44oF, VP @ 105 oF ~ 13 atm– The hydrocarbons can flash and fragment the sulfuric acid into

fine droplets that remain airborne

Page 39: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Sulfuric Acid (Cont.)• Is There Experimental Verification of Airborne Sulfuric Acid Droplet

Scenarios?– Yes. Experiments performed by Quest Consultants circa 1992

using hydrocarbon/sulfuric acid mixtures– 2.8%-3% of sulfuric acid remains airborne

• Release from 2” hole in bottom of settler– Predicted airborne sulfuric acid release rate for 2.8% case: 1.32

kg/s (2.90 lb/s)– Release duration 35 minutes (unmitigated) or 15 minutes (limited)

• Results of Atmospheric Dispersion Calculations (Fence-line dose ratio)– Mitigated release: ~6– Unmitigated release: ~ 14

• Comparison with MHF– Mitigated release ~ 6– Unmitigated release ~18

Page 40: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Brief Summary

• The Consent Decree and the Safety Advisor served the Torrance Community well through 2000, shepherding significant advances that resulted in significant improvements in safety at the Torrance Refinery.

• The SA also established methods for evaluating changes to design and operations.

• Type of Changes within the Alkylation Unit:– Variations in Operating Parameters and Configuration– Maintenance of Important Mitigation Features

• Types of Changes in Alkylation Technology– Testing/Inspection/Maintenance Best Practices– Knowledge of Health Effects of HF and Sulfuric Acid– Viable Catalysts

• The methods established by the Safety Advisor will continue to be a valuable contributor to Community safety.

Page 41: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

OVERVIEW OF SEPTEMBER 6, 2015 INCIDENTDAVID A. DUMAIS, DEPUTY FIRE CHIEF

CITY OF TORRANCE

Page 42: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Presentation OverviewIncident SummaryIncident Timeline / NotificationsResponse / Hazard MitigationImpactsNext Steps

CITY OF TORRANCE

Page 43: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Incident Summary

Approximately 2:19 am leak of Hydrogen Fluoride (HF) vapor from acid storage vessel.

Safety systems activated: • Alarm system• 2,500 gallons / minute water spray• Nitrogen purge- acid neutralized• Product sent to flare

CITY OF TORRANCE

Presenter
Presentation Notes
Early on the morning of September 6th, at approximately 02:19, the HF laser detection system at ExxonMobil’s Torrance Refinery alarmed, indicating a potential leak in the Alkylation unit. At the time of the incident, the Alkylation unit was shut down for turnaround and all of the unit’s Modified HF (MHF) was stored in acid evacuation system (AES) . Refinery personnel investigated, confirmed a leak from a clamp on top of one of the storage vessels in the AES. Upon making this determination, Refinery personnel activated the water safety systems to the area of the leak, to capture the leak in the water phase, prevent further vaporization and contain the HF. While water safety systems were deployed, Refinery personnel depressured the vessel and established a nitrogen purge to neutralize it. Shortly after 06:00, Refinery personnel took measurements and confirmed that the vessel was no longer leaking. Later that day, Refinery personnel began applying a power coating and wrap to the affected area and isolated vessel.
Page 44: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Incident Summary

Reporting Protocols by

XOM employees were not

followed due to active leak.

CITY OF TORRANCE

Presenter
Presentation Notes
Early on the morning of September 6th, at approximately 02:19, the HF laser detection system at ExxonMobil’s Torrance Refinery alarmed, indicating a potential leak in the Alkylation unit. At the time of the incident, the Alkylation unit was shut down for turnaround and all of the unit’s Modified HF (MHF) was stored in acid evacuation system (AES) . Refinery personnel investigated, confirmed a leak from a clamp on top of one of the storage vessels in the AES. Upon making this determination, Refinery personnel activated the water safety systems to the area of the leak, to capture the leak in the water phase, prevent further vaporization and contain the HF. While water safety systems were deployed, Refinery personnel depressured the vessel and established a nitrogen purge to neutralize it. Shortly after 06:00, Refinery personnel took measurements and confirmed that the vessel was no longer leaking. Later that day, Refinery personnel began applying a power coating and wrap to the affected area and isolated vessel.
Page 45: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Incident Timeline and Notifications

02:00 03:00 04:00

02:19 Laser

detector alarm 02:34

Water safety system deployed 2500GPM

CITY OF TORRANCE

Presenter
Presentation Notes
As I stated, at approximately 02:19 the morning of September 6th, ExxonMobil Torrance Refinery’s laser detection system alarmed, indicating a potential leak. Two minutes later one of the Refinery’s HF Point Detectors alarmed at 2 ppm. Two minutes after that, at approximately 02:24 the same HF Point Detector alarmed at 6ppm; and Refinery’s Remote Terminal Unit sent an electronic notification to SCAQMD. In the meantime, Refinery personnel had been sent to investigate and subsequently confirmed at approximately 02:30 there was a leak in the unit’s AES. Within the next three minutes, by approximately 02:33, Refinery personnel activated the Refinery Emergency Notification System (02:33), and identified the leak as coming from a clamp on top of a vessel in the AES, vessel 5C31. Within the next two minutes, Refinery personnel deployed the Refinery’s water safety systems (2500 GPM) to the 5C31 area and within the hour Refinery incident commander called. At approximately 02:55, Refinery personnel began de-pressuring the vessel. Refinery Incident Commander called the Torrance Fire Department Dispatch on the radio channel ten minutes later, at approximately 03:06, and indicated there was an on going acid leak. He did not activate XOM Hazmat and did not call for HM TFD Response. Per protocol In next thirty minutes, SCAQMD called and spoke to the Refinery Shift Superintendent and other personnel. By 03:45, SCAQMD inspectors were onsite.
Page 46: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Incident Timeline and Notifications

02:00 03:00 04:00

03:06 EOM requests

incident number for email report regarding

on-going small acid leak

CITY OF TORRANCE

04:15Refinery Incident

Commander emails incident report to

TFD

Presenter
Presentation Notes
As I stated, at approximately 02:19 the morning of September 6th, ExxonMobil Torrance Refinery’s laser detection system alarmed, indicating a potential leak. Two minutes later one of the Refinery’s HF Point Detectors alarmed at 2 ppm. Two minutes after that, at approximately 02:24 the same HF Point Detector alarmed at 6ppm; and Refinery’s Remote Terminal Unit sent an electronic notification to SCAQMD. In the meantime, Refinery personnel had been sent to investigate and subsequently confirmed at approximately 02:30 there was a leak in the unit’s AES. Within the next three minutes, by approximately 02:33, Refinery personnel activated the Refinery Emergency Notification System (02:33), and identified the leak as coming from a clamp on top of a vessel in the AES, vessel 5C31. Within the next two minutes, Refinery personnel deployed the Refinery’s water safety systems (2500 GPM) to the 5C31 area and within the hour Refinery incident commander called. At approximately 02:55, Refinery personnel began de-pressuring the vessel. Refinery Incident Commander called the Torrance Fire Department Dispatch on the radio channel ten minutes later, at approximately 03:06, and indicated there was an on going acid leak. He did not activate XOM Hazmat and did not call for HM TFD Response. Per protocol In next thirty minutes, SCAQMD called and spoke to the Refinery Shift Superintendent and other personnel. By 03:45, SCAQMD inspectors were onsite.
Page 47: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

04:00 06:00 08:00

06:00 Nitrogen purge; Refinery

confirmed vessel no longer leaking

08:31Refinery Incident

Commander emails first incident

update to TFD

Incident Timeline and Notifications, cont.

CITY OF TORRANCE

Presenter
Presentation Notes
Around 04:00, vessel 5C31 had been de-pressured. At approximately 04:15, Refinery Incident Commander emailed a report on the incident to TFD. Approximately 06:00, a nitrogen purge was established from vessel 5C31 to the neutralization vessel. Shortly thereafter, Refinery personnel confirmed vessel no longer leaking At approximately 08:31, Refinery Incident Commander emailed an updated report on the incident to TFD. At approximately 08:35, Refinery Incident Commander called TFD and spoke to the on Duty Platoon Commander to update earlier reports. At approximately 08:38, TFD Engine 93 onsite to investigate the incident. Affected area was power wrapped and coat affected area later that day, continuing into Sept. 7th. at approximately 12:08 on September 7th, Refinery sent ending notification to TFD.
Page 48: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

08:00 10:00

12:08Notification

received by TFDon 9/07/15 that refinery incident

ended 9/6/15 @ 6 p.m.

Incident Timeline and Notifications, cont.

08:38TFD Engine 93

onsite to investigate

12:00

CITY OF TORRANCE

Presenter
Presentation Notes
Around 04:00, vessel 5C31 had been de-pressured. At approximately 04:15, Refinery Incident Commander emailed a report on the incident to TFD. Approximately 06:00, a nitrogen purge was established from vessel 5C31 to the neutralization vessel. Shortly thereafter, Refinery personnel confirmed vessel no longer leaking At approximately 08:31, Refinery Incident Commander emailed an updated report on the incident to TFD. At approximately 08:35, Refinery Incident Commander called TFD and spoke to the on Duty Platoon Commander to update earlier reports. At approximately 08:38, TFD Engine 93 onsite to investigate the incident. Affected area was power wrapped and coat affected area later that day, continuing into Sept. 7th. at approximately 12:08 on September 7th, Refinery sent ending notification to TFD.
Page 49: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

ImpactsIncident was contained onsite.

No off-site release into the community.

No reported injuries or exposures.

CITY OF TORRANCE

Presenter
Presentation Notes
The Alkylation Unit’s mitigation measures and Refinery personnel quickly and effectively controlled and fully contained the incident onsite. As a result, there was no offsite release into the community or other offsite impacts. There were no: Injuries to anyone – employees, contractors or the community; Property damage on or offsite; or Other offsite consequences.
Page 50: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

SummaryWhat Happened?

HF vapor leaked from a clamp on the MHF storage tank

Did Safety Systems work? Yes Alarms activated, 2,500 gpm water

applied, nitrogen purge- acid neutralized, product sent to flare

CITY OF TORRANCE

Page 51: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Questions

Number of MHF incidents

to date 2010 – present

• 22 Incident involving MHF/ HF all consistent with the Sept. 6 incident

• 2 injuries

CITY OF TORRANCE

Why Letter of Improvement? Reporting protocols were not followed by refinery personnel

Page 52: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

What is being done to enhance communications in the future?

Training of XOM Employees and TFD members in reporting protocols

CITY OF TORRANCE

Page 53: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Next Steps Investigation ExxonMobil TFD Cal OSHA, SCAQMD

Repairs Pre-start up Safety Checks

CITY OF TORRANCE

Presenter
Presentation Notes
Investigation: ExxonMobil has commenced an incident investigation. ExxonMobil is cooperating with TFD and Cal/OSHA’s investigations into the incident. Repairs: ExxonMobil will make permanent repairs to the affected leak area.
Page 54: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Regulatory Controls Over Refinery MARTIN A. SERNA, ASSISTANT FIRE CHIEF

CITY OF TORRANCE

Page 55: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Brief History of Hazardous Waste Management

• Safe handling• Storage• Transportation• Disposal of hazardous

materials and wastes

1970s & early 1980s National & LA County

Focus

CITY OF TORRANCE

Presenter
Presentation Notes
Speak about the 1979 incident and the alky fire in 1987 hazmat team formed
Page 56: PUBLIC WORKSHOP Regarding ExxonMobil’s use of Modified

Brief History of Hazardous Waste Management

CITY OF TORRANCE

1982L.A. County Board of Supervisors

established the Hazardous Materials Control Program in the Department of Health Services.

1986 City adopted the health and safety

code.

Presenter
Presentation Notes
Speak about the 1979 incident and the alky fire in 1987 hazmat team formed
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Brief History of Hazardous Waste Management

CITY OF TORRANCE

Early 90’s LA County Fire Department was granted

the authority to provide oversight Underground Storage Tank, California

Accident Prevention, and Hazardous Material Disclosure

1991Program merged into the Fire

Departments and it became the Health Hazardous Materials Division (HHMD)

Presenter
Presentation Notes
Speak about the 1979 incident and the alky fire in 1987 hazmat team formed
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Certified Unified Program Agency

CITY OF TORRANCE

Certified Unified Program Agencies (CUPAs) and Participating Agencies (PAs)

Form California CUPA Forum

CUPA Forum Members and representatives of local, state and

federal agencies established the Unified Program Administration and Advisory

Group (UPAAG)

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Certified Unified Program Agency

Aboveground Petroleum Storage Act

Hazardous Waste Program

California Accidental Release Prevention (CalARP) program

Hazardous Materials Program

Underground Storage Tank Program

CITY OF TORRANCE

Presenter
Presentation Notes
How many UST’s Haz-Mat inspections and CalArp sites?
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Unified Program Administration and Advisory Group (UPAAG)

CITY OF TORRANCE

State Agency Partners Responsibilities

• Setting program element standards• Working with CalEPA to ensure

program consistency• Provide technical assistance to CUPAs

and PAs

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Unified Program Administration and Advisory Group (UPAAG)

State Agencies Involved with the Unified Program

• California Environmental Protection Agency (CalEPA) • Department of Toxic Substances Control (DTSC)• Governor’s Office of Emergency Services (Cal OES)• Office of the State Fire Marshal (CAL FIRE-OSFM)• State Water Resources Control Board (SWRCB)

CITY OF TORRANCE

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Background of Refinery Task Force

CITY OF TORRANCE

AUGUST 2012 Serious chemical release and fire at Chevron’s Richmond oil

refinery

Governor Brown formed an Interagency Working Group to:• Examine ways to improve public and worker

safety through enhanced oversight of refineries• Strengthen emergency preparedness in

anticipation of any future incident

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Background of Refinery Task Force

CITY OF TORRANCE

The Working Group consists of:• Participants from 13 agencies and

departments• The Governor’s Office

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Background of Refinery Task Force

CITY OF TORRANCE

Over an eight-month period the Working Group met internally and with:

• Industry• Labor• Community• Environmental

• Academic• Local emergency

response • Other

stakeholders

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Background of Refinery Task Force

CITY OF TORRANCE

• Local governments• Industry stakeholders• Non-governmental and

labor representatives• Members of the public

Draft report was issued July

2013 and received comment

from:

*Copies available in the back

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Findings

CITY OF TORRANCE

Oversight and Coordination

Emergency Response and Preparedness

Safety and Prevention of

Hazardous Events

Community Education

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Oversight and Coordination

An Interagency Refinery Task Force has been created within the

California Environmental Protection Agency

(CalEPA)

CITY OF TORRANCE

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Emergency Response and Preparedness:

CITY OF TORRANCE

• Area Plans • Alignment of Radio

Communications Between Response Agencies

• Establishment of a Unified Incident Command and Joint Operation Center

The Governor’s

Office of Emergency

Services (OES)

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Emergency Response and Preparedness:

CITY OF TORRANCE

• Plans and Protocols to Protect Persons Outside of a Refinery

• Drills and Exercises Preparation for Airborne Releases

• Assessment Plan for Monitoring of Toxic Air Contaminants

• Early Notification of Release or Threatened Release of a Hazardous Material

The Governor’s

Office of Emergency

Services (OES)

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Safety and Prevention of Hazardous Events:

CITY OF TORRANCE

Strengthen CalARP and PSM Programs

Require Refineries to Implement Inherently Safer Systems

Require Refineries to Perform Periodic Safety Culture Assessments

Require Refineries to Conduct Damage Mechanism Hazard Reviews

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Safety and Prevention of Hazardous Events:

CITY OF TORRANCE

Require Root Cause Analysis after Significant Accidents or Releases

Require Refineries to Explicitly Account for Human Factors

Require Structured Methods to Ensure Safeguards in Process Hazard Analysis

Strengthen Enforcement Capacity and Reporting

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Community Education and Alerts: Emergency Alerts and Public Education

Public Involvement in Emergency Planning

Public Access to Data and Information

California Air Response Planning Alliance

Improve Emergency Alerts and Public Education

Improve Public Involvement in Air Monitoring

CITY OF TORRANCE

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Proposed Regulatory Highlights

CITY OF TORRANCE

• Process Hazard Analysis (PHA) The application of management systems to ensure the safety of petroleum refinery processes.

• Hierarchy of Hazard Controls Analysis (HCA) Use a structured approach known as the Hierarchy of Hazard Controls to eliminate or minimize hazards in refinery processes whenever possible

Steps to Improve

Public and Worker Safety:

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Proposed Regulatory Highlights

CITY OF TORRANCE

• Implementation The recommendation is infeasible; however, a determination of infeasibility shall not be based solely on cost.

The Governor’s Interagency Working Group on Refinery Safety submitted their latest draft for review September 24th 2015 with a goal for adoption 2nd

or 3rd quarter of 2016

Steps to Improve Public and Worker Safety:

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The Governor’s Interagency Working Group Members

CITY OF TORRANCE

California Environmental Protection Agency

California Air Resources Board

Department of Toxic Substances Control

State Water Resources Control Board

Department of Industrial Relations Division of Occupational Safety

Health Governor’s Office of Emergency Services California Department of Public Health California Emergency Medical ServicesAuthority Office of the State Fire Marshal

U.S. Environmental Protection Agency Region 9

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The Governor’s Interagency Working Group Members

Certified Unified Program Agencies with Refineries

• Contra Costa County Environmental Health• El Segundo Fire Kern County • Environmental Health Los Angeles County Fire City of Los Angeles Fire

(Torrance)• San Luis Obispo County Environmental Health • Solano County Environmental Health Local Air Pollution Control Districts

with refineries • Bay Area Air Quality Management District• San Joaquin Valley Air Pollution Control District • San Luis Obispo County Air Pollution Control District South Coast Air

Quality Management District

CITY OF TORRANCE

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Going ForwardLEROY J. JACKSON, CITY MANAGER

CITY OF TORRANCE