BOARD MEETING DATE: February 7, 2003
AGENDA NO. 25
Authorize Executive Office to Execute MOU between AQMD and Valero Wilmington Refinery to Replace the Use of Concentrated Hydrogen Fluoride with Modified Hydrogen Fluoride
SYNOPSIS:
Valero Wilmington Refinery (Refinery) proposes to modify the alkylation process at its refinery in Wilmington to eliminate the use of hydrogen fluoride (HF), an acutely hazardous material, in this process and replace it with modified hydrogen fluoride (MHF). MHF contains additives that reduce volatility and aerosol formation properties of HF. In addition, the refinery plans to upgrade the existing mitigation system that includes leak detection, process isolation, water spray and the HF deinventory facility. The use of MHF in combination with the mitigation system will significantly reduce the quantity of airborne HF in the event of an emergency release. Parties to this MOU would agree to expedite the construction of equipment required for conversion to MHF by dedicating sufficient resources for timely submittal, preparation and review of both CEQA documents and permit applications, as well as the actual design, procurement and construction, accordingly.
COMMITTEE:
Stationary Source January 24, 2003
RECOMMENDED ACTION:
Authorize Executive Officer to execute the attached Memorandum of Understanding with Valero Wilmington Refinery.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
On September 14, 2002, the Board approved Implementation of Environmental Justice Program Enhancements for FY 2002-03. These proposed program enhancements include re-initiation of rulemaking similar to the former Rule 1410 – Hydrogen Fluoride Storage and Use, or achieving the same end result through an enforceable mechanism, such as an MOU and associated permit requirements.
In 1988, following a 1987 Hydrogen Fluoride (HF) release incident in Torrance, AQMD formed an HF task force, which recommended phasing out use of the acid in the South Coast AQMD. On April 5, 1991, the Board voted unanimously to adopt Rule 1410 prohibiting the oil refineries from using or storing HF after January 1, 1998, unless physical characteristics of HF are reduced to levels specified in the rule. Additionally, Rule 1410 required interim control measures ranging from leak detection to containment systems. However, Rule 1410 was subsequently suspended by the Los Angeles Superior Court in June 1992 after legal findings of a photocopy error in the rule’s CEQA process.
Valero Wilmington Refinery is proposing to execute an MOU with the AQMD committing to, among other things, using modified HF in its alkylation process and expeditiously making equipment modifications to accommodate the use of modified HF at its Wilmington refinery. MHF contains additives that reduce volatility and aerosol formation properties of HF. Currently, the refinery is equipped with a mitigation system that includes 26 HF leak detection devices, surveillance video cameras allowing operators to zoom into an area of concern within the unit, a remote automated process isolation system, water curtain and cannon spray equipment capable of delivering about 21,000 gallons per minutes, and 12 automated valves to deinventory HF from the process system. To further minimize public exposure to potential HF releases, the refinery is proposing to use modified HF in the alkylation process and upgrade its mitigation system to include deflector barriers for HF pumps and flanges. This proposed change meets the intent of the former Rule 1410 and will significantly reduce the potential for public exposure to this hazardous chemical in the event of an emergency release. The MOU, with the refinery’s voluntary cooperation, represents a commitment to install the new system more quickly than could likely be accomplished if the AQMD were to adopt a rule.
During the development of the Environmental Justice Program, some environmental and community representatives asked AQMD to evaluate the feasibility of using a solid catalyst instead of modified HF. As part of this effort, staff conducted a literature review of the solid catalyst technology that does not rely on HF. Research in the area of a solid catalyst for alkylation has been ongoing for many years. However, earlier attempts by many companies such as Catalytica, Haldor Topsoe, Mobil, University Corporation for Atmospheric Research Office of Programs (UOP), Lummus/Akzo, and Idaho National Engineering and Environmental Labor (INEEL) to develop a viable solid acid alkylation process have not yet led to commercial availability. Numerous patents exist for different catalysts, catalyst supports, and processes. Currently, the two main hurdles solid catalyst processes have to overcome include catalyst life and catalyst regeneration. Several companies are engaged in active research in this area, but no one has yet commercialized a new solid catalyst technology.
Early this year, ABB Lummus Global and Akzo Nobel Catalysts announced that they have jointly developed a new solid acid catalyst (SAC) process called AlkyClean. This new technology is now entering its demonstration phase at Fortum Oil and Gas’s facility in Porvoo, Finland. This group hopes to be in the position to offer the product commercially in 2004. Other companies such as UOP LLC of the U.S. and Halder Topsoe of Denmark, have also developed alkylation processes that use a solid catalyst process. However, their demonstration units for the process are not yet on the same scale as the one running for Alkyclean. ABB Lummus and Akzo Nobel estimate it will take up to two and a half years after full commercialization to engineer a unit for a new customer. Therefore, waiting for a solid catalyst technology would delay efforts to reduce toxic risks at the refinery.
Under the proposed MOU, the refinery is committed to continue to review alternative alkylation technologies until such time as the permits to construct the ReVAP process are issued by AQMD. If an alternative technology is commercially demonstrated and technically and economically feasible, the AQMD and the refinery may mutually agree to reassess the commitments under the MOU for the purpose of implementing alternative technologies
Proposal
Consistent with the Board’s directive to complete implementation of the Environmental Justice Program Enhancements for FY 2002-03 by June 2003; the Executive Officer requests approval to execute an MOU with the refinery to expedite the construction of equipment necessary to accommodate the use of modified HF in the alkylation process by committing both parties to dedicating sufficient resources for timely submittal, preparation and review of both CEQA documents and permit applications, and for design, procurement and construction of equipment. This MOU will require engineering design of this new process to begin within two months of the effective date of the MOU, with procurement of the associated equipment to begin immediately after a permit to construct is issued by the AQMD. Construction of equipment necessary to accommodate the use of modified HF will begin within 7 months of permit issuance date with the final implementation date no later than December 31, 2005 unless there are permit delays or other delays due to unforeseen circumstances.
Draft MOU
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