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Parent Category: Safety Info Posts

Category: PSM and RMP Citations/Analysis

Published: 22 July 2017

Hydrogen Fluoride (HF) is a regulated substance listed as a toxic substance. The refinery uses 250,000 lbs of HF at its facility as part of the processes, and if released, could affect 220,000 people within a fifteen (15) mile radius of the facility, according to the Risk Management Program submittals. The refinery uses a water cannon system, which activates upon detection of HF vapor, to suppress releases of HF from the Alkylation unit. On March 5, 2012 300 to 400 lbs of HF vapor released from the Alkylation/Mole Sieve unit at the facility. The release occurred over the course of several hours until the HF vapor mitigation system activated. On March 10 and 11, 2012 an unknown quantity of HF was released from the Alkylation/Mole Sieve unit. Although exact quantity is unknown, both releases were significant enough to activate the HF vapor mitigation system. On May 15, 2012 330 lbs of HF were released from two bleeder valves in the Alkylation/Mole Sieve unit while operators were introducing HF from the storage tank into the unit. The HF vapor water mitigation system activated as a result of the release. Despite the activation of the mitigation system, HF was detected downwind of the Alkylation/Mole Sieve unit within the perimeter of the facility.  As a result of these series of HF releases, on May 21, 2012 the United States Chemical Safety and Hazard Investigation Board sent a letter to EPA Region 6 requesting that EPA perform a comprehensive RMP inspection at the facility. On June 11 through 15, 2012, EPA Region 6, along with EPA headquarters and contract investigators, conducted an unannounced IZMJJ inspection at the facility.

FACTUAL BASIS OF VIOLATIONS

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