public workshop regarding exxonmobil’s use of modified
TRANSCRIPT
PUBLIC WORKSHOP Regarding ExxonMobil’s use of ModifiedHydrogen Fluoride (HMF) Catalyst TUESDAY, OCTOBER 13, 2015
CITY OF TORRANCE
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
ELECTROSTATIC PRECIPITATORSYSTEM & STATUSAND REFINERY CURRENT STATUSBRIAN ABLETT, EXXONMOBIL PLANT MANAGER
EXXONMOBIL TORRANCE REFINERY
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
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
• 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
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
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
HISTORY OF CONSENT DECREE TO ALLOWUSE OF MHFJOHN FELLOWS, CITY ATTORNEY
CITY OF TORRANCE
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
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
• 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
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
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
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
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
Post Consent Decree Protocol
Objectives
Scope
Ongoing Obligations
CITY OF TORRANCE
PRESENTATION BY COURT APPOINTEDSAFETY ADVISORSTEVEN T. MAHER, PE CSPDR. GEOFFREY D. KAISER
RISK MANAGEMENT PROFESSIONALS CORP.
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
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
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
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)
Consent Decree Framework for Torrance Refinery
Modified Hydrogen Fluoride (MHF) Alkylation Unit
Risk Assessment
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
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.
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.”
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
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
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
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.
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.
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.
Alkylation Unit Release Phenomenology
(Why outcomes can appear counterintuitive)
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
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)
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).
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
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
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
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.
OVERVIEW OF SEPTEMBER 6, 2015 INCIDENTDAVID A. DUMAIS, DEPUTY FIRE CHIEF
CITY OF TORRANCE
Presentation OverviewIncident SummaryIncident Timeline / NotificationsResponse / Hazard MitigationImpactsNext Steps
CITY OF TORRANCE
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
Incident Summary
Reporting Protocols by
XOM employees were not
followed due to active leak.
CITY OF TORRANCE
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
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
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
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
ImpactsIncident was contained onsite.
No off-site release into the community.
No reported injuries or exposures.
CITY OF TORRANCE
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
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
What is being done to enhance communications in the future?
Training of XOM Employees and TFD members in reporting protocols
CITY OF TORRANCE
Next Steps Investigation ExxonMobil TFD Cal OSHA, SCAQMD
Repairs Pre-start up Safety Checks
CITY OF TORRANCE
Regulatory Controls Over Refinery MARTIN A. SERNA, ASSISTANT FIRE CHIEF
CITY OF TORRANCE
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
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.
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)
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)
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
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
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
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
Background of Refinery Task Force
CITY OF TORRANCE
The Working Group consists of:• Participants from 13 agencies and
departments• The Governor’s Office
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
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
Findings
CITY OF TORRANCE
Oversight and Coordination
Emergency Response and Preparedness
Safety and Prevention of
Hazardous Events
Community Education
Oversight and Coordination
An Interagency Refinery Task Force has been created within the
California Environmental Protection Agency
(CalEPA)
CITY OF TORRANCE
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)
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)
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
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
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
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:
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:
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
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
Going ForwardLEROY J. JACKSON, CITY MANAGER
CITY OF TORRANCE