ExxonMobils

EPA Off Site Consequence Analysis1

Sally Hayati, PhD
Torrance Refinery Action Alliance
June 14, 2015. [Updated June 1, 2016]

Any facility that handles, manufactures, uses, or stores regulated toxic or flammable substance in amounts
greater that certain threshold quantities,2 is required to develop and implement an EPA risk management
program.4 ExxonMobil refinery contains a threshold quantity of four regulated flammable substances, and
two regulated toxic substances, hydrofluoric acid (HF) and anhydrous ammonia. As of 2014, ExxonMobil
reported they had 250,000 lbs. MHF, 14,000 lbs. ammonia, and 54,971,000 lbs. of flammable substances.5

The EPA requires an offsite consequence analysis for an accidental chemical release with two elements:

(1) Worst case (WC) release scenarios for all regulated toxic and flammable substances and the resulting
distance the toxic vapor cloud, heat from a fire, or blast waves from an explosion will travel before
dissipating to the point that serious injuries from short term exposures will no longer occur for most people.

For toxics, worst case is defined as the release of the largest quantity from a single vessel or process line
failure. The toxic endpoint is the maximum airborne concentration below which nearly all individuals can
be exposed for up to one hour without experiencing or developing irreversible or other serious health
effects or symptoms that could impair an individual's ability to take protective action6 (ERPG-2).7,8 The
distance to toxic endpoint is a radius defining a circle of death and irreversible serious health effects.
In a flammable worst-case scenario, the total quantity of a flammable substance forms a vapor cloud, 10%
of which detonates. The overpressure endpoint is the distance from the vapor cloud explosion to an
overpressure9 level of one pound per square inch (psi). The distance to overpressure endpoint is a
radius defining a circle of demolition of houses, which can result in skin laceration from flying glass or
serious injuries.

(2) Alternative release scenarios. Alternative release scenarios are scenarios that are more likely to occur
than the worst-case scenario and that will reach an endpoint offsite (unless no such scenario exists).

The EPA claims that its model will generally, but not always, overestimate the distance to endpoints.
According to EPA guidelines, the analysis should include a description of the vessel or pipeline and
substance selected, the assumptions and parameters used, and the rationale for selection. Assumptions
include any administrative controls and any passive mitigation systems that were used to limit the quantity
that could be released. The facility must document the anticipated effects of these controls and systems on
the release quantity and rate. Yet, this information was not among the materials I was allowed to examine
at the DoJ reading room. For flammables there was not even a description of the substance. Their WC toxic
scenario asserts that the largest quantity of MHF in a single vessel or pipe is 5,200 lbs, only 2% of total
inventiory. This is questionable. If true, the total inventory of 250,000 lbs. would require more than 49
separate vessels. The Valero Refinery in Wilmington, using the same MHF technology, gives 50,000 lbs. as
the size of their largest vessel. The larger the amount, the more catastrophic the consequences will be.

Regulatory agencies maintain that WC scenarios employ extremely conservative assumptions and
therefore should not be a basis for any specific actions or be considered a zone in which the public would
be in danger.10 But this is the voice of industry speaking, not the voice of science or reason. As HF expert
Dr. Ronald Koopman has pointed out, although industry insists on disclaimers to the contrary, An accident
could be this bad. An accident could look like this.11 EPA toxic scenarios are based on the failure of a single
vessel. But refinery explosions and fires could easily lead to multiple failures, as could earthquakes.
3

Furthermore, the EPAs focus is wrong. They emphasize not the death, irreversible health effects, and
suffering occurring within the endpoint radius, but on how a person beyond the radius might be ok.

Worst Case* Scenario for Toxic Material: Hydrofluoric Acid, 100004258112

Process description:
Alkylation and Light Ends


ID: 1000052230
Chemical name:

Hydrogen Fluoride/Hydrofluoric Acid (HF) ID: 100006337
Physical state of HF:
gas liquefied by pressure, modeled as a gas upon release
Model used:

RMP*Comp (EPA provided)
Wind speed and air stability: 1.5 m/sec & F EPA default, slow wind, stable air
Percentage weight of HF:
81%
(rest is MHF additive?)
Amount released:

5,200 lbs.
(largest single vessel,* 2% of the 250,000 lb. inventory)13
Duration of release:
10 min
(default, required value)
Rate of release:

520 lbs/min (calculated: amount released divided by duration)
Toxic endpoint value for HF: 0.016 mg/l14 (specified in Table of Toxic Endpoints15)
Distance to toxic endpoint: 3.2 miles
(found by extrapolating from EPA Reference Table 716)
Residential population at risk: 255,524
Public receptors:

Schools, residences, hospitals, commercial areas, industrial areas,
recreational areas, wildlife sanctuary
Active mitigation:

none
Passive mitigation:

Release barriers and use of modified HF (MHF)HF + vapor suppressant

ZONE OF DEATH and IRREVERSIBLE HEALTH EFFECTS: the HF vapor cloud will travel 3.2 mi before
dissipating to the point that serious injuries from short-term exposures will no longer occur for most people.
Outside, serious injuries could occur, esp. from exposures > 1hour, exposed would need medical attention.
WORST AFFECTED CITIES: Torrance, Redondo Beach, Hermosa Beach, Lawndale, Gardena, & Carson.

Sally Hayati, TRAA, June 8, 2015

Toxic HF cloud
will spread
from refinery
in the direction
of the wind. If
the wind shifts,
so will the
cloud. The
calmer the air
is, the less HF
dispersion
there is, the
slower the
cloud moves,
and the longer
the exposure is
to denser HF.

Authors Observations on the Worst Case Scenario for HF. UPDATED MAY 17, 2016

EPA Reference Table 7 can be used to determine the distance from the point of release to a toxic endpoint
concentration, given the toxic endpoint value and rate of release (conditions: 10 minute release of a dense
gas, urban conditions, F Stability, wind speed 1.5 meters/sec). F stability is the worst-case meteorological
condition, at night, when the air mass is stable and the toxic gas cloud is slow to disperse. This can occur in
our area during inversions, the optimum condition for an open-air chemical weapons release.17

Rows 1, 2, and 4 of the table below are taken from EPA Reference Table 7.18 The middle column contains
values extrapolated from adjacent Table 7 entries. It can be seen in Row 1. (in blue) that 3.2 miles
corresponds to a release rate of 150 lbs./minute for HF, 71% less than the scenario value, 520 lbs./minute
(Row 3, in red). This suggests the toxic distance should be 5.28 miles, instead of the 3.2 miles reported by
ExxonMobil in their EPA report.

Toxic Endpoint mg/L
0.01
0.016 for HF
0.02
Release Rate lbs/min
Distance to Toxic Endpoint, Miles
1. 150
3.6
3.2
2.5
2. 500
6.2
5.18
4.5
3. 520 WC scenario

5.28

4. 750
8.1

5.5

The reason for this discrepancy is twofold. First, ExxonMobil uses RMP*Comp, not Table 7 (which is based
on RMP*Comp). Refineries are given considerable latitude in the dispersion model used. Second, as the
Consent Decree Safety Advisors 1999 report makes clear, ExxonMobil takes credit for two passive
mitigation factors: use of modified HF (MHF) and a proprietary barrier technology secretly introduced
after the MHF operational failure and slashing of additive at the end of 1997: so-called release barriers.19
Based on Table 7 it can be estimated that ExxonMobil credits MHF plus release barriers with a 71%
reduction in airborne cloud formation compared to HF (given by the reduction of effective release rate from
520 to 150 lbs./minute.)

We cannot accept ExxonMobils word on MHF toxic cloud formation.

First, MHF testing and analysis has been conducted only on a small-scale and only by petrochemical
companies.20 Independent MHF testing has not been done, nor have a sufficient number of tests been
performed to allow statistical verification.
Second, the additive was reduced to only 10%. At that concentration, the amount of airborne acid can be
reduced by only 10% or so compared to HF.21
Third, Mobils proprietary barrier technology has never been tested, even by Mobil, for MHF with 10%
additive and barrier distances less than one foot. Instead Mobil relied on results given by a software
model that even they and the Safety Advisor admitted was inaccurate.22
Fourth, not every release will occur at a location that is protected by a barrier. The accident on
2/18/2015, for example, would have occurred on the un-barriered settler tank top or at the piping at the
front and at the foot of the settler tank.
According to the SCAQMD, the additive is removed from MHF during the alkylation process and remixed.23
A release during processing would therefore liberate HF, 100% of which becomes airborne. The release of
more than 1,500 lbs. of HF would result in a greater toxic endpoint radius than the worst-case scenario
for a release of 5,200 lbs. of MHF. It isnt clear that the EPA would notice this discrepancy.
This table shows that if MHF plus barrier mitigation is as high as ExxonMobil claims, the community still
faces a grave danger, even if emergency systems (active mitigation) work optimally at 90% suppression.

SCENARIO
1. Absolute Worst Case
2. Significant Release
3. ExxonMobils worst case
Sally Hayati, TRAA, June 8, 2015

lbs. released
250,000
25,000
5,200

% Inventory
100%
10%
2%

MHF TOXIC RADIUS (miles)

Active Mitigation

No Active Mitigation

6
2
~1

18
5.5
3.2
3

Worst Case Scenario Flammable Substance: Flammable Mixture 1000031266

Process description:
Chemical name:

Scenario


Model used:

Amount released:

Toxic endpoint value:
Distance to toxic endpoint:
Residential population:
Public receptors:

Oil Movements & Storage

ID: 1000052233
Flammable Mixture
ID: 1000063311
Vapor cloud explosion
RMP*Comp

(EPA provided)
10,140,000 lbs.
1 psi


(mandated by EPA)
1.7 miles
(found by extrapolating from EPA Reference Table 724)
54,524
Schools, residences, hospitals, commercial areas, industrial areas,
recreational areas
Dikes and fire walls

Passive mitigation:


CIRCLE OF DEATH & IRREVERSIBLE HEALTH EFFECTS: Radius is the distance past which heat from fire
or blast waves from explosion will travel before dissipating such that serious injuries wont occur for most.
WORST AFFECTED CITIES: Torrance, Redondo Beach, Carson.

Sally Hayati, TRAA, June 8, 2015

Worst Case Scenario Flammable Substance: Flammable Mixture 1000031874

Process description:
Chemical name:

Scenario


Model used:

Amount released:

Toxic endpoint value:
Distance to toxic endpoint:
Residential population:
Public receptors:

Passive mitigation:

Crude light ends

ID: 1000054765
Flammable Mixture
ID: 1000066676
Vapor cloud explosion
RMP*Comp

(EPA provided)
56,000 lbs.
1 psi


(mandated by EPA)
0.3 miles
(found by extrapolating from EPA Reference Table 725)
0
Commercial areas, industrial areas
Blast walls

Worst Case Scenario Flammable Substance: Flammable Mixture 1000031876

Process description:
Chemical name:

Scenario


Model used:

Amount released:

Toxic endpoint value:
Distance to toxic endpoint:
Residential population:
Public receptors:

Passive mitigation:

Hydroprocessing 2
ID: 1000055027
Flammable Mixture
ID: 1000067017
Vapor cloud explosion
RMP*Comp

(EPA provided)
2,400 lbs.
1 psi


(mandated by EPA)
0.1 mile
(found by extrapolating from EPA Reference Table 726)
0
?
Blast walls

Worst Case Scenario Flammable Substance: Flammable Mixture 1000031877

Process description:
Chemical name:

Scenario


Model used:

Amount released:

Toxic endpoint value:
Distance to toxic endpoint:
Residential population:
Public receptors:

Passive mitigation:

Flares, VR, & Fuel Gas

ID: 1000055028
Flammable Mixture
ID: 1000067022
Vapor cloud explosion
RMP*Comp

(EPA provided)
16,357 lbs.
1 psi


(mandated by EPA)
0.2 mile
(found by extrapolating from EPA Reference Table 727)
0
Commercial areas, industrial areas
Blast walls

Sally Hayati, TRAA, June 8, 2015

Alternative Scenario for Toxic Material: Hydrofluoric Acid, 1000045211

Process description:

Chemical name:


Scenario:




Physical state of HF:

Model used:


Wind speed and air stability:

Percentage weight of HF:

Release quantity:


Duration of release:

Rate of release:


Toxic endpoint value for HF:
Distance to toxic endpoint:
Residential population at risk:
Public receptors:


Active mitigation:


Passive mitigation:


CBI claims

Alkylation and Light Ends

ID: 1000052230
Hydrogen Fluoride/Hydrofluoric Acid (HF) ID: 100006337
Transfer hose failure
gas liquefied by pressure, modeled as a gas upon release
RMP*Comp (EPA provided)
3.0 m/sec and D stability (OCA guidance)
85%
different. Pure HF with hydrocarbons?
3,170 lbs.
SIZE OF VESSEL? THERE ARE DISCREPANCIES
1 min

IN MY HAND WRITTEN NOTES
674 lbs/min ?


OR ELSE IN THE RECORD
0.016 mg/L28
0.4 miles

500
Residences, commercial areas, industrial areas
Emergency shutdown
none (this scenario is for a release of HF, not MHF)
none

Alternative Scenario for Toxic Material: Ammonia (anhydrous), 1000066674

Process description:
Hydroprocessing 1

ID: 1000052229
Chemical name:

Ammonia (anhydrous)

ID: 1000066674
Scenario:


Vessel leak

Physical state of HF:
gas liquefied by refrigeration
Model used:

RMP*Comp (EPA provided)
Wind speed and air stability: 3.0 m/sec and D stability (OCA guidance)

Percentage weight:
100%

Release quantity:

4,400 lbs.

[SH: total amount 14,000 lbs. for this process]
Duration of release:
10 min

Rate of release:

440 lbs/min
Toxic endpoint value:
0.14 mg/l29

Distance to toxic endpoint: 0.2 miles

Residential population at risk: 0 [does not include industrial or commercial employees/customers]
Public receptors:

Commercial areas, industrial areas
Active mitigation:

none
Passive mitigation:

none
CBI claims


none

Sally Hayati, TRAA, June 8, 2015

Alternate Scenario Flammable Substance: Flammable Mixture 1000029317

Process description:
Oil Movements & Storage
ID: 1000052233
Chemical name:

Flammable Mixture
ID: 1000063311
Scenario


Vapor cloud explosion
Model used:

RMP*Comp

(EPA provided)
Amount released:

216,000 lbs.
Toxic endpoint value:
1 psi


(mandated by EPA)
Distance to toxic endpoint: 0.2 miles
(found by extrapolating from EPA Reference Table 730)
Residential population:
0 [does not include industrial or commercial employees/customers]
Public receptors:

Commercial areas, industrial areas
Passive mitigation:

none
Active mitigation:

sprinkler system, deluge system


ENDNOTES AND REFERENCES

1 Available at: <https://www.scribd.com/doc/272231537/2015-06-ExxonMobil-Torrance-EPA-Off-Site-Consequence-Analysis>. Data on all worst

case and alternate scenarios for toxics and flammables are based on hand-written notes taken by the author from materials provided by the
ExxonMobil Torrance Refinery to the EPA, during a 70 minute time period spent at the US Marshalls office in the Federal Courthouse building at 312
N Spring St, Los Angeles, CA on June 4, 2015 at 10am.
2 Code of Federal Regulations, 40 CFR 68.130 - List of [regulated toxic and flammable] substances, <http://www.gpo.gov/fdsys/pkg/CFR-2011-
title40-vol15/xml/CFR-2011-title40-vol15-sec68-130.xml>
3 US EPA, Risk Management Program Guidance for Offsite Consequence Analysis, 2009, <http://www2.epa.gov/sites/production/files/2013-
11/documents/oca-chps.pdf>
4 EPA, 40 CFR Part 68 App A & B (CFR=Code of Federal Regulations; Title 40=Protection of Environment (for EPA); part 68=Risk Management
Program; Appendix A=Technical Support Document; Appendix B=Selected NCAIS codes), <http://www2.epa.gov/sites/production/files/2013-
11/documents/w-apendab.pdf>
5 ExxonMobil Torrance Refinery Risk Management Plan Offsite Consequence Analysis 5-yr update, 2014-06-19, [amount of MHF 250,000 lbs.]
accessed July 22, 2015 at
<http://www.rtknet.org/db/rmp/rmp.php?reptype=f&database=rmp&facility_name=exxonmobil&parent=&combined_name=&city=torrance&coun
ty=&state=&zip=&district=&execsum=&all_naics=&chemical_id=&detail=3&datype=T&sortp=F>
6 http://www.epa.gov/ceppo/pubs/ammonia/achap-04.pdf
7 Emergency Response Planning Guidelines (ERPGs), NOAA, http://response.restoration.noaa.gov/erpgs
8 EPA, 40 CFR Part 68 App A & B (CFR=Code of Federal Regulations; Title 40=Protection of Environment (for EPA); part 68=Risk Management
Program; Appendix A=Technical Support Document; Appendix B=Selected NCAIS codes), <http://www2.epa.gov/sites/production/files/2013-
11/documents/w-apendab.pdf>
9 The pressure caused by a shock wave over and above normal atmospheric pressure
10 EPA, Guidance for Facilities on Risk Management Programs (RMP), < http://www2.epa.gov/rmp/guidance-facilities-risk-management-programs-
rmp>, Chapter 4: Offsite Consequence Analysis (April 2004), <http://www2.epa.gov/sites/production/files/2013-11/documents/chap-04-
final.pdf>
11 2011-02-24, ABC News Nightline, Toxic Threat, Thu, Feb 24, 2011, <http://www.hulu.com/watch/219062>
12 All scenarios assume rural topography
13 ExxonMobil Torrance Refinery Risk Management Plan Offsite Consequence Analysis 5-yr update, 2014-06-19, accessed June 8, 2015 at
<http://data.rtknet.org/rmp/rmp.php?facility_id=100000152504&detail=3>
14 EPA, Appendix A of 40 CFR Part 68 (CFR=Code of Federal Regulations; Title 40=Protection of Environment (EPA); part 68=Risk Management
Program; Appendix A=Technical Support Document), <http://www2.epa.gov/sites/production/files/2013-11/documents/w-apendab.pdf>
15 EPA, 40 CFR Part 68 App A & B (CFR=Code of Federal Regulations; Title 40=Protection of Environment (for EPA); part 68=Risk Management
Program; Appendix A=Technical Support Document; Appendix B=Selected NCAIS codes), <http://www2.epa.gov/sites/production/files/2013-
11/documents/w-apendab.pdf>
16 EPA, Risk Management Program Guidance for Offsite Consequence Analysis, 2009, Table 7 on p 64 (5-10),
<http://www2.epa.gov/sites/production/files/2013-11/documents/oca-chps.pdf>
17 Surface Transportation Security, A Guide to Transportations Role in Public Health Disasters, Volume 10, p. 13,
<https://books.google.com/books?id=Psx_mxEbYGQC&pg=PA13&lpg=PA13&dq=toxic+cloud+spread+and+wind+speed&source=bl&ots=C1f8_wRJx
c&sig=uNrAK42YY2H8MHcdTYFi-
oHn3b0&hl=en&sa=X&ved=0CB8Q6AEwAGoVChMIyt_d_86DxgIVAQOSCh38sQBU#v=onepage&q=toxic%20cloud%20spread%20and%20wind%20
speed&f=false>
18 EPA, Risk Management Program Guidance for Offsite Consequence Analysis, 2009, <http://www2.epa.gov/sites/production/files/2013-
11/documents/oca-chps.pdf>
19 Consent Decree 1999-10, Safety Advisor Report, Steve Maher, Evaluation of Modified HF Alkylation Catalyst (Analysis of proposed additive
concentration changes). <http://bit.ly/1Nzic8W>. [sent by Torrance City Councilman Tim Goodrich to Hayati, email November 23, 2015, 9:56pm]

Sally Hayati, TRAA, June 8, 2015


20 Smaller, laboratory scale testing was conducted to assess the effectiveness of passive mitigation measures such as the use of a less volatile

modified hydrofluoric acid (MHF) alkylation catalyst. Texaco/UOP HF Alkylation Additive Technology: Aerosolization Reduction Effect, September
26, 1995, presented at the International Conference and Workshop On Modeling and Mitigating The Consequences of Accidental Releases of
Hazardous Materials, AIChE/CCPS, G. A. Melhem, Arthur D. Little Inc., K. R. Comey and R. M. Gustafson, Texaco Inc.,
<https://www.scribd.com/doc/88446645/The-TexacoUOP-HF-Alkylation-Additive-Technology-Aerosolization-Reduction-Effects>
21 Dr. Ronald Koopman, HF expert and Test Director for the 1986 Goldfish HF Release Tests in the NV desert. Personal email sent to Nick Green, Dec
17, 2015 at 1:03 PM and forwarded to Sally Hayati that day.
22 Consent Decree 1999-10, Safety Advisor Report, Steve Maher, Evaluation of Modified HF Alkylation Catalyst (Analysis of proposed additive
concentration changes). <http://bit.ly/1Nzic8W>. [sent by Torrance City Councilman Tim Goodrich to Hayati, email November 23, 2015, 9:56pm]
23 Verbal communication from the AQMD during meeting with TRAA, May 28, 2015. Dr. Barry R. Wallerstein, Executive Officer and Mohsen Nazemi,
PE, Deputy Executive Officer for the Office of Engineering and Compliance. The initial promise of MHF was that the additive would be compatible
with alkylation. MHF would be used at every stage and whatever benefit it conferred would be constant. But problems were soon apparent,
especially during alkylation and HF regeneration in which HF is cleaned for reuse, often removing the additive. ExxonMobil took out a patent on
one method to deal with the additive: HF alkylation process with acid regeneration, US Patent 7847142 B2, ExxonMobil Research and Engineering
Company, 2007 (filing date), <http://www.google.com/patents/US7847142>
24 EPA, Risk Management Program Guidance for Offsite Consequence Analysis, 2009, Table 7 on p 64 (5-10),
<http://www2.epa.gov/sites/production/files/2013-11/documents/oca-chps.pdf>
25 EPA, Risk Management Program Guidance for Offsite Consequence Analysis, 2009, Table 7 on p 64 (5-10),
<http://www2.epa.gov/sites/production/files/2013-11/documents/oca-chps.pdf>
26 EPA, Risk Management Program Guidance for Offsite Consequence Analysis, 2009, Table 7 on p 64 (5-10),
<http://www2.epa.gov/sites/production/files/2013-11/documents/oca-chps.pdf>
27 EPA, Risk Management Program Guidance for Offsite Consequence Analysis, 2009, Table 7 on p 64 (5-10),
<http://www2.epa.gov/sites/production/files/2013-11/documents/oca-chps.pdf>
28 EPA, Appendix A of 40 CFR Part 68 (CFR=Code of Federal Regulations; Title 40=Protection of Environment (EPA); part 68=Risk Management
Program; Appendix A=Technical Support Document), <http://www2.epa.gov/sites/production/files/2013-11/documents/w-apendab.pdf>
29 EPA, Appendix A of 40 CFR Part 68 (CFR=Code of Federal Regulations; Title 40=Protection of Environment (EPA); part 68=Risk Management
Program; Appendix A=Technical Support Document), <http://www2.epa.gov/sites/production/files/2013-11/documents/w-apendab.pdf>
30 EPA, Risk Management Program Guidance for Offsite Consequence Analysis, 2009, Table 7 on p 64 (5-10),
<http://www2.epa.gov/sites/production/files/2013-11/documents/oca-chps.pdf>

Sally Hayati, TRAA, June 8, 2015