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Fact

Check: The Torrance Refining Companys Toxic


Lies about MHFa
Sally Hayati, PhD
President, the Torrance Refinery Action Alliance
August 4, 2016

TEXT OF THE TRCS DAILY BREEZE AD, PRINTED AS FACT BY THE CITY OF TORRANCEb

The use of modified hydrofluoric acid (MHF) at the Torrance Refinery has been the subject of articles in this
newspaper over the past several months. As the new owner of the refinery, the management of the Torrance Refining
Company understands the communitys interest in the risks associated with MHF and would like to share more
information on the numerous measures we have in place to operate safely, reliably, and protect the community.
The Torrance Refinery Hydrofluoric Acid (HF) Alkylation Unit was originally installed in 1966. Over 50 years of
operation, many controls, specialized equipment, and mitigation measures have been added to further improve safety of
the unit.
Two MHF studies have also been completed for the Torrance Refinery. An independent, court-appointed Safety
Advisor conducted the original, multi-year study of HF Alkylation at the Torrance Refinery. The Safety Advisors report
concluded that use of MHF would be as safe or safer than using sulfuric acid. This report was reviewed and approved
by an experienced, senior judge for the Los Angeles Superior Court in 1995. Consequently, in 1997, the refinery initiated
use of a modified HF licensed by Honeywell Universal Oil Products that will also help suppress vapors from HF in the
event of a release.
A few years later, the court-appointed Safety Advisor was asked to conduct another study as a result of a need to
make modifications to the unit, in keeping with the refinerys commitment to operate reliably with continuous improvement
and safety in mind. This research project carefully tested different concentrations of MHF in a strictly controlled and safe
environment to determine optimal levels of MHF additive. The court-appointed Safety Advisor recommended approval of
the change in additive concentration to the 10-15% range, indicating the overall protective systems that had been added
to the unit, along with the adjustment of the concentration, assured the same level of safety. That 1999 Safety Advisor
Report was also reviewed and approved by the same Los Angeles Superior Court judge. In addition to using the
proprietary additive in MHF catalyst to significantly reduce volatility versus conventional HF, we have many other safety
measures and mechanisms in place at the Torrance Refinery Alkylation Unit that help us monitor, prevent, control and
respond to a release, including:

Real-time video camera surveillance that can be used with remotely-controlled aim-and-shoot water
cannons to suppress HF vapors
Fixed Water Spray System and Fixed Water Monitors also suppress vapors
Unit shutdown, equipment isolation, and rapid de-inventory systems are used to move HF to a safe location
Highly specialized equipment, including a protected storage drum, are used to minimize vaporization
Laser Sensor System on unit perimeter provides 360 coverage for leak detection
HF leak detectors located throughout the unit
If a sensor detects HF, an automatic signal is sent directly to the refinerys Central Control Building that is
monitored 24/7 and the SCAQMD office
Acid pumps are equipped with double mechanical seals to prevent leaks
Acid sensitive paint helps detect leaks on flanges
Safeguarded fresh acid unloading system can be shut down and isolated by personnel from the delivery truck,
unit control house, or Central Control Building
Specialized training and emergency response drills for operators, engineers, and others, including the
Torrance Fire Department
Comprehensive audits are conducted by company experts, third-party consultants, and government officials

In summary, we recognize the communitys interest in our operations. We are confident that the many layers of
protection, mitigation steps, and safety systems we have in place allow us to operate the MHF Alkylation Unit safely,
reliably, and in an environmentally and in an environmentally responsible manner.


This document can be found at this link: http://bit.ly/2aOOw12
TRCs ad can be found on the Daily Breeze, without markings to indicate it is an advertisement, and here: 2016-07-28, City of Torrance
eNewsletter, Facts About Modified Hydrofluoric Acid From The Torrance Refining Company, <http://www.torranceca.gov/PDF/PBF-
9.89x21-Ad4-MHF.pdf?utm_source=eNEWSLETTER+%7C++Thursday%2C+July+28+-
+Wednesday%2C+August+3%2C+2016++&utm_campaign=Torrance+eNewsletter+193&utm_medium=email>.
a

LINE BY LINE FACT-CHECK


This report was reviewed and approved by an experienced, senior judge for the Los Angeles
Superior Court in 1995.
Retired Judge Peetris served as the final authority in the decree's implementation and decided "all
disputed enforcement matters" between the city and Mobil.1 But Peetris had no technical
knowledge or experience, having a bachelors degree in accounting and legal experience in
personal injury, business law, traffic court, and mental health court.2,3 Peetris relied on Mobil and
the Safety Advisor for technical advice, as did the City of Torrance. On June 27, 1991,4 Peetris set
an unrealistic $1 million spending limit for the entire Safety Advisor program, over vehement
objections from the city.5 This set the scene to select the company with the lowest bid.

An independent, court-appointed Safety Advisor


As part of the Decree Mobil agreed to pay for an impartial safety advisor [SA] to monitor the
refinery and report unsafe conditions to a hired judge through 1997.6 Although the SA was meant
to be independent, Judge Peetris selected Westinghouse Electric Corp., Mobils recommendation.7
Westinghouse also held other contracts with Mobil for services and supplies. Steve Maher was the
project manager for Westinghouse.8 Councilman Dan Walker compared Westinghouse's role as
safety adviser protecting the public interest to "a fox watching the chicken coop."9 This choice was
a fatal blow to the integrity of the Consent Decree. Torrance officials, who had spent $1.4 million
on the Public Nuisance lawsuit that was settled by the decree, were disappointed, angry, and
worried. They had lobbied in favor of the nonprofit research firm SRI International of Menlo Park,
which had estimated the project's first stage alone would cost Mobil up to $1 million.
Westinghouse, on the other hand, gave a laughable estimate of $350,000 for the entire job. City
Councilman Dan Walker pointed out that to properly evaluate MHF, "such an unproven and
potentially innovative technology, far more will be required than [Westinghouses planned] cursory
review of a few Mobil documents and the drafting of two $7,500 reports to the Court."10 [SH: that is
exactly what the SA did.] Torrance responded to the choice of Westinghouse by naming Torrance
Fire Department Chief R. Scott Adams, the city's liaison for implementation of the Mobil Oil
refinery Consent Decree, to act as a check on impartial Safety Advisor Steve Maher.11
Unfortunately Adams was not up to the task. Steve Maher, who was a mechanical engineer, hired
chemist and HF apologist Dr. Geoffrey Kaiser as his expert. In 1990, Allied Signal had hired
Kaiser to defend their use of HF against SCAQMDs Rule 1410 banning HF use at its El Segundo
plant.12 Kaiser was the only expert cited by Allied Signal in their report, An Analysis of the Safe
Use of Hydrogen Fluoride at the Allied-Signal Facility in El Segundo. Thus, two pro-industry HF
advocates played the role as Safety Advisor, the sole evaluators of MHF, and the only ones given
access to industry data.

Two MHF studies have also been completed for the Torrance Refinery [conducted by the SA]
The Safety Advisor only performed a pen and paper evaluation of Mobils Quantitative Risk
Analyses (QRA) in 1994 and of the modified QRA in 1998. He did no MHF study or testing. Mobil
and Phillips did all the MHF testing, using different additives and concentrations. This testing was
complete by the early 1990s. The European patent for Mobils MHF brand, ReVAP, was filed in
1992.13 A MHF demonstration unit was started at Mobils Paulsboro NJ Refinery in July 1993; the
Safety Advisor visited the unit for observation but had no other role.14,15 His main technical exertion
was to perform independent justifications and verification calculations so that he could support
Mobils QRA. No MHF study has been done specifically for the Torrance Refinery. A 1991 South
Coast Air Quality Management District (SCAQMD) report clearly stated the MHF problem: HF

concentration has to be greater than 88% to be used as a catalyst in the alkylation unit.16 Yet more
than 50% additive is needed for MHF to safely fall to the ground upon release,17 leaving an HF
concentration of 50%, far too low for alkylation. As SCAQMD said, no MHF additive was found
that could reduce the formation of airborne acid without also making MHF a lousy catalyst. Even in
2007, nine years after the additive concentration was reduced to a mere 10%, ExxonMobil filed yet
another patent for a technique to overcome additive problems.18 The only study Mobil did for
Torrance was to devise a plan to sell dangerous MHF. The outcome was a three-stage bait and
switch strategy. In 1990, Mobil pledged to use a safe MHF with 50% additive. In 1994, Mobil
pledged to use a dangerous MHF with 30% additive, which was significantly safer than HF. In
1997, Mobil secretly switched to 10% additive, leaving a MHF that is 90% HF and nearly as deadly.

An independent, court-appointed Safety Advisor conducted the original, multi-year study of HF


Alkylation at the Torrance Refinery.
The Safety Advisor (SA) never did a single study of MHF or HF Alkylation for the Torrance Refinery.
His role was to evaluate Mobils claims regarding MHF along with all other safety issues at the
refinery. Out of the 168 recommendations the SA imposed on Mobil during the Consent Decree,
only 10 (6%) were related to the alkylation unit or MHF,19 barely more than the number of SA
recommendations for perimeter landscape improvement. This is revealing, considering that HF was
the top concern leading to the Consent Decree. MHF was a proprietary R&D project that was
unproven, not commercialized, independently tested or subjected to open peer review, upon which
the lives of hundreds of thousands of people depended. Yet the SA directed his efforts elsewhere.

Consequently, in 1997, the refinery initiated use of a modified HF licensed by Honeywell


Universal Oil Products that will also help suppress vapors from HF in the event of a release.
Mobil began using a MHF it developed with Phillips, ReVAP. Honeywell didnt acquire ownership of
(and a monopoly on) MHF until years later. MHF was not a commercial product in 1997.

A few years later


TRC skipped right over an inconvenient truth: the moment the brand new MHF unit became
operational (if it ever became operational at all), near the end of 1997, it was a failure. This fact has
never been officially acknowledged or revealed to the press or the public. TRC obviously intends to
continue the tradition of deception. Early in 1998, the LA Times reported that the Consent Decree
had ended in triumph on December 31, 1997 and that the new MHF successfully began operations
by New Years Day.20 But unknown to the public or the press, the Consent Decree had not ended
and the MHF unit was not operational.21
The Safety Advisors second report dated October 1999 was undisclosed until 2015 when this
author got a copy of it from Steve Maher via a request to Councilman Tim Goodrich. According to
that report, when the MHF unit with 30% additive became operational at the end of 1997,22 the
additive made the unit dangerously unstable and produced too little product and of low quality.23
MHF had, predictably, failed again.24 Remember, HF must be greater than 88% concentration by
weight to function well as an alkylation catalyst. MHF with 30% additive has only 70% HF by
weight. The MHF additive concentration would have to be slashed by a factor of three, to 10%.25
Inconveniently, at that concentration MHF gives no real safety improvement over HF. HF expert Dr.
Ron Koopman states that only 10% of the released MHF would fall to the ground. 90% would
become airborne in a dense vapor cloud.26 This is nearly identical to HF, 100% of which becomes
airborne and travels downwind. MHF is not a safe or even a less deadly HF alternative.

A few years later, the court-appointed Safety Advisor was asked to conduct another study as a
result of a need to make modifications to the unit, in keeping with the refinerys commitment to
operate reliably with continuous improvement and safety in mind.
Plans to slash the additive began immediately followed the start of MHF operations. Cuts in
concentration were in place within 3 months, not a few years later. This action was motivated by
chemistry, the pursuit of profit, and contempt for public safety, not by the refinerys commitment to
operate reliably with continuous improvement and safety in mind. Safety would have required the
replacement of HF with sulfuric acid, not with barely modified HF. The Safety Advisor was not asked
to do another study. His role was to speed-read Mobils QRA updated from 1994, evaluate it,
and rubber stamp Mobils new plans as fast as possible. In March it took him just four days to
validate and approve Mobils interim and final operating configurations. He also agreed, as the
impartial and independent Safety Advisor, sole evaluator of Mobils performance, representative of
the Court, and guardian of the public interest, to keep everything hidden from the public. He didnt
even bother to document the events until October of 1999, the date of his second report.

This research project [by the Safety Advisor] carefully tested different concentrations of MHF in a
strictly controlled and safe environment to determine optimal levels of MHF additive.
This claim is utter rubbish. The Safety Advisor has never done research on MHF or testing of MHF.
He was not and is not qualified or equipped to do so. All performance testing of MHF was done by
Mobil and Phillips and was finished years before 1998. A reading of both Safety Advisor report
shows that this is the case. The industry determined from those tests that their preferred
concentration (not the same as optimal from the point of view of safety) was between 20% to 40%
additive.27 MHF test data is never even seen for less than 20% additive in patents or reports,
because the industry recognized that such a low level conferred no safety advantage. But now MHF
has only 10% additive. The AQMD has also informed us that pure HF is used during processing, a
statement we have not been able to verify but suspect is true.

The court-appointed Safety Advisor recommended approval of the change in additive


concentration to the 10-15% range, indicating the overall protective systems that had been added
to the unit, along with the adjustment of the concentration, assured the same level of safety.
According to the Safety Advisor himself, Mobil identified its own desired target additive
concentration by January 1998.28 It is a complete fabrication that the Safety Advisor did it based on
additional research and testing, years after the MHF unit became operational. It is true that the
Safety Advisor immediately went along with Mobils claim that the unit had the same level of safety.
But that was a judgment made with unusual haste and insufficient time to properly evaluate a
complex QRA. It is interesting that TRC chooses not to name or describe the overall protective
systems added to the unit. The refinery, City of Torrance, and the SCAQMD continue to hide the
fact that refinery safety claims rely almost wholly on a proprietary, untested, and extremely
questionable barrier technology, not MHF.

That 1999 Safety Advisor Report was also reviewed and approved by the same Los Angeles
Superior Court judge.
This is the same judge who appointed an industry consultant recommended by Mobil to be the
independent Safety Advisor. We have found no written record or evidence that the court ever
approved the 1999 Safety Advisor report or knew about the MHF unit failure, additive cuts, or
introduction of a new and untested mitigation technique to replace MHF. I have a 2000 Consent
Decree court document that states the SAs 1995 report is a record of the court, but it does not
mention the SAs 1999 report.29 In fact, there is no mention in any court document from 1997 and

later that I have found that mentions the additive reduction or installation of the proprietary barrier
technology. I asked Torrance Mayor Patrick Furey and former Torrance refinery manager Brian
Ablett of ExxonMobil to provide the evidence that the city and court were informed about and
approved the MHF failure, additive reduction, and addition of barriers to replace MHF, but they
declined. Four of the six city councils members at the time, Dan Walker, Don Lee, Marcia Cribbs30
and George Nakano,31 say they have no memory of MHFs operational failure or the reduction in
additive. City Manager LeRoy Jackson has admitted to knowing about the change, but accepts no
responsibility.32 It is unknown what role Mayor Dee Hardison (1994-2002) played, but after the
2/18/2015 explosion Ms. Hardison came through for ExxonMobil, writing a letter to a Senate hearing
committee editor attesting to ExxonMobils largesse to the Torrance. In March 2016 she abbreviated
this letter and sent it to the Daily Breeze saying that it was time for the community to return
[ExxonMobils] favor by supporting their plan to exceed normal start-up emissions.33

In addition to using the proprietary additive in MHF catalyst to significantly reduce volatility
versus conventional HF
This is deliberate deception. A 10% additive concentration reduces MHFs volatility by only 10%
compared to HF. That is NOT a significant reduction. HF expert Dr. Ronald Koopman, HF expert
and Test Director for the 1986 Goldfish HF Release Tests has said that Quest Consultants modeled
the proprietary properties of Mobils MHF and determined it reduces the distance a toxic cloud would
travel by only 7.9% over an equivalent HF release34 (9.2 miles instead of 10 miles, for example).
Valero also gave 7.9% as the level of MHF reduction in toxic distance in a 2004 EIR for their MHF
alky unit.35 That is NOT a significant reduction.

we have many other safety measures and mechanisms in place at the Torrance Refinery
Alkylation Unit that help us monitor, prevent, control and respond to a release, including
This long list of emergency systems gives a feel for how terrifyingly dangerous MHF is. Ask
yourself: if MHF were as safe as or safer than sulfuric acid as TRC claims, why should the Torrance
MHF unit bristle with so many expensive mitigation measures to detect and knock down airborne
HF? Sulfuric acid alkylation units dont have systems like these, because it doesnt form a vapor
cloud upon release.36 It is a liquid up to temperatures of 638.6F37 and falls to the ground upon
release. MHF is a gas above ~80F; 90% of it becomes a dense vapor cloud that drifts at ground
level outside of the refinery and into our homes.
Industry tests show that at best, no more than 80-90% of airborne acid can be knocked down by fully
functioning water suppression systems.38, 39, 40, 41 ExxonMobils EPA report admits that a 3.2 mile
radius of death or serious and irreversible injury for most with short-term exposure could occur from
the release of 5,200 lb. of MHF, if emergency systems fail. 42 But even If 80-90% of that airborne
acid were knocked down by water systems, there would still be a 1.01.4-mile radius of death or
serious and irreversible injury.43 Over 20,000 residents live in that zone.
But mitigation systems dont always function optimally, and may fail completely. They are vulnerable
to human error, deferred maintenance, non-compliance with regulations and best practices,
mechanical failure, and damage from refinery explosions, fires, or earthquakes. During an
ExxonMobil Community Advisory Panel tour of the refinery, I asked the top firefighter what measures
they would take if the emergency water systems were damaged by an earthquake, fire, or explosion.
He said the refinery fire department would drag and connect hoses to get to the alky unit and hose
down airborne HF, but it sure would be a challenge, he acknowledged. During the 2009 Corpus
Christi, TX Citgo Refinery Explosion and fire 42,000 pounds of HF acid were released, at least 4200
lb. of which exited the refinery despite emergency measures.44,45 It could have been worse: HF
suppression systems ran out of water because there wasnt enough to fight both fire and HF.
Fortunately, engineers and workers were able to jury-rigged a system to use nearby ocean water.

The original cause was the unthreading of a single internal plug from a valve stem, creating a
cascade of events and released HF. Community injuries and fatalities were averted only because
prevailing winds carried the acid cloud over the water instead of over inhabited areas. Conditions
are different here: the Torrance refinery cant access ocean water, and there is no safe direction for
the wind to blow in Torrance. Residents surround the refinery.
The community doesnt want TRC to monitor, control, and respond to MHF releases. It wants MHF
and HF to be finally gone, forever.


1 1991-06-06, The 'Even-Handed' Judge in Mobil Case: Torrance: Retired Superior Court Judge Harry V. Peetris, DEBORAH SCHOCH, LA Times,

<http://articles.latimes.com/1991-06-02/local/me-374_1_superior-court-judge>
2 2014-09-05, Services Set for Former Presiding Judge Harry V. Peetris, MetNews Staff Writer,

<http://www.metnews.com/articles/2014/obit090514.htm>.
3 2014-09-06, Passings: Harry Peetris, LA Times, <http://www.latimes.com/local/obituaries/la-me-passings-20140907-story.html>.
4 Consent Decree Stipulation & Order, September 30, 1994, Filed with the Superior Court of the State of California for the County of LA, Case No.

C719 953. <https://drive.google.com/file/d/0B0sm-0cQ1vDqemttc3ZsaGdsXzg/view?usp=sharing>


5 1994-11-17, Mobil, Torrance Alter Refinery-Safety Agreement: Safety: The firm appointed by a judge to monitor conditions at the work site

has been replaced. Costs had exceeded the program's budget ceiling, DEBORAH SCHOCH, LA Times, <http://articles.latimes.com/1994-11-
17/news/cb-63642_1_refinery-safety>
6 1991-10-24, Court Filing by Torrance Shows Strain With Mobil: Industry: Frustrated over the slow pace of Westinghouse's safety inspection
of Mobil's refinery, city officials seek more formal court supervision, JANET RAE-DUPREE and DEBORAH SCHOCH, LA Times,
<http://articles.latimes.com/1991-10-24/local/me-117_1_court-supervision>
7 1991-05-31 Judge Picks Mobil Nominee as Safety Firm for Refinery: Torrance: Proposal by Westinghouse is ruled 'clearly superior.' City
officials who backed another firm are dismayed, JANET RAE-DUPREE and DEBORAH SCHOCH, LA Times, <http://articles.latimes.com/1991-
05-31/local/me-2687_1_torrance-refinery>
8 1994-11-17, Mobil, Torrance Alter Refinery-Safety Agreement: Safety: The firm appointed by a judge to monitor conditions at the work site
has been replaced. Costs had exceeded the program's budget ceiling, DEBORAH SCHOCH, LA Times, <http://articles.latimes.com/1994-11-
17/news/cb-63642_1_refinery-safety>
9 1991-06-06, The 'Even-Handed' Judge in Mobil Case: Torrance: Retired Superior Court Judge Harry V. Peetris, DEBORAH SCHOCH, LA Times,
<http://articles.latimes.com/1991-06-02/local/me-374_1_superior-court-judge>
10 1991-03-28, Wide Gap Divides Mobil, Torrance on Adviser Choice : Safety: Selection of a refinery watchdog will be left to a court-appointed
overseer if the two sides can't agree, DEBORAH SCHOCH, LA Times, <http://articles.latimes.com/1991-03-28/local/me-1219_1_torrance-
refinery/2>
11 Workshop regarding ExxonMobils use of MHF catalyst, October 13, 2015, City of Torrance Staff Report, op cit., Page 21, Attachment B, City
Council Meeting Jan 31, 1995.
12 Kaiser, Geoffrey D., Quantitative Risk Assessment of the Use of Hydrogen Fluoride at Allied-Signals El Segundo Facility (August 1990).
Reference from Allied-Signals October 1990 report to the SCAQMD, An Analysis of the Safe Use of Hydrogen Fluoride at the Allied-Signal
Facility in El Segundo. Kaiser was hired by Allied Signal to defend them against Rule 1410. REF: PAGE 249 of Rule 1410, South Coast Air Quality
Management District, Draft Environment Assessment (EA) for proposed Rule 1410, Hydrogen Fluoride Storage and Use, February 22, 1991,
Director of Planning Barry Wallerstein, D. Env., <ftp://ftp.aqmd.gov/outgoing/R1410/>.
13 Alkylation catalyst containing hydrofluoric acid and a sulfone, European Patent 0796657 B1, Applicant: Phillips Petroleum Company, June
18, 1992, <http://www.google.com/patents/EP0796657B1?cl=en>.
14 Alkylation Current Events, Pam Pryor, STRATCO Inc., November 2001, [MHF demonstration unit Paulsboro 1993]
<http://www2.dupont.com/Clean_Technologies/en_US/assets/downloads/AlkyCurrentEvents2001.pdf>
15 Alternative Alkylation Technologies in a Refinery - A Case Study in Risk-Based Decision Making, Geoffrey Kaiser and Steve Maher,
Probabilistic Safety Assessment and Management, European Safety and Reliability Conference (ESREL) 96 PSAM-III June 24-28 1996, Crete,
Greece. <https://drive.google.com/file/d/0B0sm-0cQ1vDqYUJpMVRYM1ZoamM/view?usp=sharing>.
16 Rule 1410, Resolution Number 90, South Coast Air Quality Management District, April 1991, <ftp://ftp.aqmd.gov/outgoing/R1410> p. 31.
17 See data table in this patent, showing that 50% HF concentration (50% additive) results in only a 64% rainout of airborne acid, unless
Mobils proprietary barriers (impact plate and pad) are used. The MHF performance numbers claimed by Mobil, in reducing airborne HF,
required the use of Mobils proprietary barrier technology. The 1995 MHF alky unit design had no barriers; only in 1998 were barriers
introduced. Thus the rainout claimed for 30% additive in 1994 would have been far lower than the 65% claimed by Mobil. US Patent, 1992,
Mobil Oil Corporation, Containment of an Aerosolable liquid jet, US5286456, filing date 24 Sep 1992.
<http://www.google.com.sv/patents/US5286456>.
18 US Patent, 2007, HF alkylation process with acid regeneration, US Patent 7847142 B2, ExxonMobil Research and Engineering Company,
2007 (filing date), <http://www.google.com/patents/US7847142>. ForMHF units using sulfolane additive, the problems encountered in the
removal of the water [during acid regeneration] are compounded by the fact that the distillation properties of sulfolane are similar to the heavy
polymer so that the additive will be removed from the unit and so lost from the unit together with excessive amounts of acid.
19 Adams analysis stated there were a total of 168 SA recommendations during the Consent Decree. But Attachment 3, the Recommendations
Status Summary lists only 154, none of which are characterized as for MHF or the alkylation unit. Either those 10 recommendations were
omitted from the summary or were described nondescriptly as Evaluation Performed. Not one recommendation noted as remaining open
after 1997 pertained to MHF or the alkylation unit.


20 1998-01-11, SPECIAL REPORT * Torrance residents, once worried by facility in their midst, can now breathe more easily. As eight-year effort

to improve safety winds up . . . : Mobil Refines Its Image, DEBORAH BELGUM, Accessed on May 31, 2015 at
<http://articles.latimes.com/1998/jan/11/local/me-7318>. According to this contemporary LA Times report, the Torrance-Mobil Consent
Decree expired on this date, as per the original 1990 Consent Decree agreement. But, unknown to the public or the press, the Consent Decree
didnt expire as scheduled.
21 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 by email November 23, 2015,
9:56pm]
22 The MHF unit most likely began operations in late 1997, rather than on January 1, 1998, because the SA states in his 1999 report that Mobil
decided on a plan to switch to 10% additive at the beginning of January. But perhaps the MHF unit was never started up at all with 30%
additive. Mobil knew it wouldnt work. See Footnote 20.
23 The Court approved additive concentration of 30% resulted in [alkylation] unit operational instabilities compromising product quality
and preventing unit operation at full production capacity. Torrance Refinery Safety Advisor Project, Steve Maher, Evaluation of Modified HF
Alkylation Catalyst (Analysis of proposed additive concentration changes), October 1999. <http://bit.ly/1Nzic8W>. This Consent Decree
report had never been publicly released until this author made a request for it in October 2015. Torrance Council member Tim Goodrich
acquired a copy from the Safety Advisor and emailed it to this author.
24 By 1994 Mobil was doubtless aware that a MHF compound with 30% additive (70% HF) by weight would NOT be viable. They would have
known this from the MHF testbed that began operating in 1993. [Alternative Alkylation Technologies in a Refinery - A Case Study in Risk-Based
Decision Making, Geoffrey Kaiser and Steve Maher, Probabilistic Safety Assessment and Management, European Safety and Reliability Conference
(ESREL) 96 PSAM-III June 24-28 1996, Crete, Greece. Author received a digital copy from Mr. Fred Millar.
<https://drive.google.com/file/d/0B0sm-0cQ1vDqYUJpMVRYM1ZoamM/view?usp=sharing>.] Also recall the 1991 report by the SCAQMD that HF
strength must be kept above eighty eight (88) percent by weight to prevent undesired reaction products in the alkylation unit. An HF
concentration of 70% is too low. Ref: Rule 1410, Resolution Number 90, South Coast Air Quality Management District, April 1991,
<ftp://ftp.aqmd.gov/outgoing/R1410> p. 31. The City of Torrances decision to accept MHF was either an ill-informed blunder or a conscious
decision to accept dangerous MHF rather than confront Mobil.
25 Honeywell admitted in a document given to PBF Energy, new refinery owners, shared by PBF during a meeting with the Torrance Refinery
Action Alliance (TRAA): Honeywell only sells MHF with 10% or 15% additive. Also shown by the Honeywell MHF Material Safety Data Sheets,
<http://bit.ly/21T6yAt>. Also by Valero Refinerys Risk Management Program report: 10% Sulfolane (name of ReVAP MHF additive).
<http://www.rtknet.org/db/rmp/rmp.php?reptype=f&database=rmp&facility_name=valero&parent=&combined_name=&city=wilmington&co
unty=&state=CA&zip=&district=&execsum=&all_naics=&chemical_id=&detail=3&datype=T&sortp=F>. Valero uses the same ConocoPhillips
MHF as ExxonMobil, as discussed in Ultramar Valero Wilmington Refinery, Alkylation Improvement Project, Final EIR Ch 1, 2004.
<http://webcache.googleusercontent.com/search?q=cache:gyi7M-bYjy4J:www.aqmd.gov/docs/default-source/ceqa/documents/permit-
projects/2005/2005appa.doc%3Fsfvrsn%3D4+&cd=1&hl=en&ct=clnk&gl=us&client=safari>.
26 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 the author, Sally Hayati, that same day. Industry patent data also show that test results for
this level of additive were never reported (or tests were never done), as being too low to confer a meaningful safety advantage.
27 ReVAP European Patent EP 0796657 B1, Alkylation catalyst containing hydrofluoric acid and a sulfone, Phillips Petroleum Company, 1992,
Page 4.
<http://worldwide.espacenet.com/publicationDetails/originalDocument?CC=EP&NR=0796657B1&KC=B1&date=&FT=D&locale=en_EP>.
28 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>. Page 5 (Exec Summary, ii).
29 Consent Decree 2000-08-09, Court Document, Stipulation and Order re: Termination of the Consent Decree, Filed with the Superior Court of
the State of California for the County of LA, Case No. C719 953. <http://bit.ly/1OJsWGW>.
30 2015-12-01 EPA investigating ExxonMobil for understating Torrance refinery risk, Nick Green, Daily Breeze,
<http://www.dailybreeze.com/general-news/20151201/epa-investigating-exxonmobil-for-understating-torrance-refinery-
risk#.Vl55GsnSVlY.email>.
31 2016-01-14, ExxonMobil manager rejects federal boards view of February refinery explosion as near miss, Nick Green, Daily Breeze,
<http://www.dailybreeze.com/government-and-politics/20160114/exxonmobil-manager-rejects-federal-boards-view-of-february-refinery-
explosion-as-near-miss>. [George Nakano, City Council from 1984 to 1998, does not recall hearing about the MHF operational failure or
approving the additive reduction. If I had known that, I would have gone though the ceiling, he said.]
32 2015-12-01 EPA investigating ExxonMobil for understating Torrance refinery risk, Nick Green, Daily Breeze,
<http://www.dailybreeze.com/general-news/20151201/epa-investigating-exxonmobil-for-understating-torrance-refinery-
risk#.Vl55GsnSVlY.email>.
33 2016-03-16, Support refinery workers as ExxonMobil restarts, Letters to the Editor, Dee Hardison, Daily Breeze.
<http://www.dailybreeze.com/opinion/20160316/exxonmobil-refinery-needs-an-independent-safety-monitor-letters>.
34 Dr. Ronald Koopman, HF expert and Test Director for the 1986 Goldfish HF Release Tests in the NV desert. Personal email sent to Fred Millar
2008-06-13 1:46 AM, forwarded to S. Hayati. Quest, using their Canary system, which contains an improved version of SLAB and what appears
to be the proprietary physical properties of ReVAP (MHF), has determined that the maximum hazard distance for a worst case release of MHF is
reduced by 7.9% over an equivalent HF release.
35 Ultramar Valero, 2004-12, Final Environmental Impact Report for: Ultramar Inc. - Valero Wilmington Refinery Alkylation Improvement
Project, App. C. Hazard Analysis, December 2004, <http://www.aqmd.gov/docs/default-source/ceqa/documents/permit-
projects/2004/ultramar-valero/appc252.pdf?sfvrsn=2>. Page 34.
36 The Safety Advisor noted this fact in his 1995 report. See page 115, V-25 for just one example. Consent Decree 1995-05-17 Safety Advisor
Report, Steve Maher, Evaluation of Modified HF Alkylation Catalyst (in Support of Decree Section 4), Final Report, Rev 1,


<http://psbweb.co.kern.ca.us/UtilityPages/Planning/EIRS/clean_fuels/Appendices/Appendix%20H_Torrance%20Report%2017May95FinalR
1_PUB.pdf>.
37 Contrary to what Mobil and the Safety Advisor claimed, sulfuric acid has a very high boiling point even when mixed with hydrocarbons. A
total of 1.1 million gallons of spent sulfuric acid with hydrocarbons were released at Motivas Delaware City Refinery. The CSB report has not
one mention of a vapor cloud because no vapor cloud at all formed. See: Chemical Safety and Hazard Investigation Board, INVESTIGATION
REPORT, Motiva Enterprises LLC, Delaware City Refinery, Delaware, July 17, 2011. <http://www.csb.gov/motiva-enterprises-sulfuric-acid-
tank-explosion/>.
38 US Chemical Safety And Hazard Investigation Board (USB), Urgent Recommendations to CITGO Corpus Christi East Refinery, August 2009,
<http://www.csb.gov/assets/1/19/Urgent_Recommendations_to_Citgo_-_Final_Board_Vote_Copy1.pdf>
39 For water to HF liquid ratios of 6:1 to 40:1, the [seminal ICHMAP] Study demonstrated HF removal efficiencies of
25% to 90%. HF Mitigation by Water Sprays, BETE 1991, [ICHMAP] <http://www.bete.com/pdfs/BETE_HF_mitigation.pdf>
40 1988-09-22, Safeguards for Hydrofluoric Acid Tested, GEORGE STEIN, <http://articles.latimes.com/1988-09-22/local/me-
3401_1_hydrofluoric-acid>
41 Refiners Discuss Hf Alkylation Process And Issues, Oil & Gas Journal, 04/06/1992, <http://www.ogj.com/articles/print/volume-90/issue-
14/in-this-issue/refining/refiners-discuss-hf-alkylation-process-and-issues.html>. at a volumetric water-to-acid ratio of about 40, HF
scrubbing efficiency approaches 90%. This was achieved during test scenarios in a carefully controlled setting. Operational systems are
expected, in general, to get less than this optimal level of efficiency.
42 Center for Public Integrity, Use of toxic acid puts millions at risk, 2011, <http://www.publicintegrity.org/2011/02/24/2118/use-toxic-
acid-puts-millions-risk>
43 232.
The Case Against MHF, Sally Hayati, <http://bit.ly/1OFiccH>. See Claim #3 on mitigation systems.
44 2009-07-24, Cost-cutting factor in Citgo refinery fire, Reuters, [CITGO, HF release], <http://in.reuters.com/article/2009/07/23/citgo-fire-
idINN2342110220090723>
45 According to CSB investigators, almost certainly more than 4000 lb. HF exited the refinery. But it is impossible to directly measure the exact
amount of acid knocked down by water systems during an emergency. CSB therefore gave CITGO maximum credit for an optimally functioning
water suppression system, which industry tests show can knock down at most 90% of airborne acid. Generally, operational systems are less
effective, knocking down 80% or less of the airborne acid, depending on the direction of the release stream, wind direction, and design features
of the water sprays, curtains, etc. REFERENCES: (1) US Chemical Safety And Hazard Investigation Board (USB), Urgent Recommendations to
CITGO Corpus Christi East Refinery, August 2009, [A final CSB report wasnt written, suppressed by industry supporters]
<http://www.csb.gov/assets/1/19/Urgent_Recommendations_to_Citgo_-_Final_Board_Vote_Copy1.pdf>
(2) For water to HF liquid ratios of 6:1 to 40:1, the [seminal ICHMAP] Study demonstrated HF removal efficiencies of
25% to 90%. HF Mitigation by Water Sprays, BETE 1991, [ICHMAP] <http://www.bete.com/pdfs/BETE_HF_mitigation.pdf>
(3) 1988-09-22, Safeguards for Hydrofluoric Acid Tested, GEORGE STEIN, <http://articles.latimes.com/1988-09-22/local/me-
3401_1_hydrofluoric-acid>. (4) Refiners Discuss Hf Alkylation Process And Issues, Oil & Gas Journal, 04/06/1992,
<http://www.ogj.com/articles/print/volume-90/issue-14/in-this-issue/refining/refiners-discuss-hf-alkylation-process-and-issues.html>. at a
volumetric water-to-acid ratio of about 40, HF scrubbing efficiency approaches 90%. This was achieved during test scenarios in a carefully
controlled setting. Operational systems are expected, in general, to get less than this optimal level of efficiency.