Will you continue to use HF?
The Refinery uses a process known as alkylation, with HF as the catalyst, to produce high octane gasoline. We will continue to use HF, which has been safely used at the Refinery for almost six decades and is widely used in the refining industry. Additional protective measures have been installed and the Refinery is evaluating others to further enhance the safety of the HF unit.
If the Refinery's HF unit was safe, why are you putting in additional safety measures?
The HF safety systems in place in April 2018 operated as designed during the incident. There was no release of HF. The Refinery is enhancing existing safeguards with state-of-the-art equipment as an additional precautionary measure, after listening to concerns from the community.
What additional safeguards will be added to the HF unit?
Additional safety measures for the HF Alkylation Unit are being completed as part of our Consent Decree and with regulatory oversight. Some of the key upgrades include:
- Installation of seven new remote-control water cannons which are a highly effective method of addressing hydrofluoric acid vapors, if needed.
- Installation of a new Rapid Acid Transfer System, which can quickly transfer HF to an independent secure holding tank within the unit in the event of an incident.
- Installation of a new HF storage tank.
- Enhanced HF leak detection, including additional HF detectors within the unit and a new laser detection system surrounding the unit.
- Installation of additional emergency isolation valves to quickly limit and isolate a potential leak, if needed.
- Installation of dedicated video cameras to provide continuous surveillance of the alkylation process and equipment and to facilitate a response to a potential leak, if needed.
What is alkylation and why does the Refinery need it?
To produce high octane gasoline, refiners use a process known as alkylation. HF is a catalyst used in the alkylation reaction to increase the rate of the chemical process, but is not consumed during the reaction. The HF alkylation unit gives the refinery the capacity to produce high octane gasoline which is an integral part of the Refinery's product slate.
Why not use sulfuric acid, ISOALKY or other alternatives?
Although HF is widely used in the refining industry, the Refinery explored possible alternatives and conducted a robust analysis of alternative alkylation technologies that do not use HF. After a thorough technology review, engineering analyses, risk assessments and discussions with subject matter experts, the Refinery concluded that alternative technologies involved significant technology risks and/or were not yet proven on a broad commercial basis.
Will the Refinery be willing to switch to a new alkylation technology that doesn't require HF, if one becomes available?
The use of alternative technologies will be monitored and evaluated as they develop and are tested.
Have you obtained approval of state and federal agencies to use HF?
All necessary permits will be in place prior to returning the Refinery to operation.
When will your HF upgrades be complete?
Some additional protective measures have already been installed. The further upgrades to the HF alkylation unit are part of the Refinery rebuild and will be implemented as the Refinery resumes operations.
The Refinery submitted its own risk analysis to the Environmental Protection Agency (EPA) showing how many deaths could result from an HF release. Shouldn't the community be concerned?
This refers to the Risk Management Plan (RMP) submitted to the EPA every five years. The EPA requests operators of refineries and other industrial plants to assess, for various chemicals including HF, theoretical risks for hypothetical worst-case scenarios, even if the scenarios are highly unlikely.
For the Refinery, the RMP documents the hypothetical potential impact of the release of the entire HF storage tank within 10 minutes. The analysis assumes an extremely unlikely worst-case scenario where the HF unit is full, is destroyed or substantially damaged during an incident, and where no safety systems are activated. It also assumes the weather pattern is stagnant (no wind).
The RMP is provided to emergency response agencies to assist in the development of procedures, training and programs which would be activated in the event of such an extreme incident, where none of the existing HF safety systems are operating. It is prudent to plan for worst-case scenarios, but they are unlikely.