Preventing Chemical Disasters Protects Workers, Communities and Creates Jobs

1. Preventing Chemical Disasters Protects Workers, Communities and Creates Jobs Clean Burning Gasoline – Where It All Begins • Refiners achieve high octane, clean burning gasoline by adding alkylate • Refining process of alkylation uses a chemical catalyst with petroleum feed materials

2. Alkylation in Refineries Extremely Hazardous Chemical Processes • Approximately 1/3 of U.S. refineries (50) use very large quantities of Hydrofluoric Acid (HF) in alkylation • Some have >1/2 million pounds on site • HF readily vaporizes in the atmosphere. A large release can form a vapor cloud that can travel great distances

3. Alkylation Catalyst HF – Extremely Toxic • OSHA & EPA regulate as highly toxic – a Toxic Inhalation Hazard (TIH) • Damages eyes, skin, nose, throat, respiratory system and bones • Fast acting, can cause deep, severe burns and can cause permanent damage • High concentrations are immediately dangerous to life and health (IDLH 30 ppm) • Serious exposures require a knowledgeable health practitioner to administer antidote – calcium gluconate – as soon as possible after exposure

4. Nevada HF Release Test August 1986, Industry Sponsored HF Dispersion Experiment: A seven minute controlled release of anhydrous HF at the Nevada Test Site. The test release created a hydrofluoric acid cloud over 10 feet high and visible from as far as ¾ of a mile

5. Metropolitan Areas at Great Risk from Refineries Using Hydrofluoric Acid

6. Recent Releases HF Related Oil Industry Incidents – Let the Record Speak for Itself: • Marathon Canton, OH (February 23, 2011) release of 145 pounds of HF • CITGO Corpus Christi, TX (July 19, 2009) explosion, fire, HF release critically injured one • Sunoco Philadelphia, PA (March 2009) HF release sends 13 workers to hospital • Giant Industries, Ciniza, NM (April 4, 2004) 4 workers seriously in fire on HF unit

7. Most Recent HF release in South Korea. Five workers killed, 18 injured, 3,000 treated for exposure. Numerous cattle and crops were affected.

8. CITGO Video Citgo, Corpus Christi, TX. July 2009 explosion and fire in the HF alkylation unit severely injured one worker and burned for two days. According to the CSB investigators, about 10% of the estimated 42,000 pound release traveled beyond the refinery fenceline.

9. Dangerous Industry Other Oil Industry Incidents – Let the Record Speak for Itself: • Deep Water Horizon (April 20, 2010) killed 11 workers, catastrophic environmental disaster • Tesoro Anacortes, WA (April 2, 2010) refinery explosion killed 7 workers • BP Texas City (March 23, 2005) killed 15 workers, injured 180

10. USW HF Report Selected Preliminary Findings: Quantities of HF at Refineries • The 23 refineries collectively have over 5 million pounds of HF on site • Per refinery range from 5,200 lbs. to 870,000 lbs. • Per refinery average of 233,000 lbs.

11. Preliminary Findings Selected Preliminary Findings: • High Number of OSHA Violations (since 2005). • 293 violations of Process Safety Management Standard: at 20 sites (plus 593 at BP Texas City) • Extraordinary 2010 gross operating profits • over $121 billion for eight oil companies operating 18 study refineries

12. Preliminary Findings Selected Preliminary Findings: • Ineffective Integrity of Alkylation Process Safety Systems • <50% rated 8 key alkylation safety systems as very effective: e.g., sewer systems, mechanical integrity of piping, pumps valves, seals, and maintenance

13. Preliminary Findings Selected Preliminary Findings: • Ineffective HF-related Process, Storage and Transfer Systems • <25% rated 3 systems as very effective. (e.g., audit programs; maintenance; and health hazard information). • <50% rated 6 systems as very effective. (e.g., operating manuals and procedures; utility systems; pre-start-up safety reviews). • >50% rated 2 systems as very effective. (e.g., control, relief and neutralization systems)

14. Preliminary Findings Selected Preliminary Findings: • Widespread Alkylation Unit Incidents and Near-Misses • >75% reported at least one HF-related incident or near miss in the past 36 months • 18 sites; 131 events; 2.4 per site per year • 83% spills or releases • 17% fires/explosions • All reported the events either did or could have caused injuries to workers on-site. • 50% re­ported events could have caused injuries to people in the community

15. Preliminary Findings Selected Preliminary Findings: • Unprepared to Respond. (Refinery’s on-site emer­gency responders, local off-site responders, sites nurs­ing/medical personnel, local hospitals). • Lowest levels of preparedness were for possible HF releases that could threaten community members (4% – 22% very prepared and 48% – 61% unprepared for the 4 groups)

16. Preliminary Findings Selected Preliminary Findings: • Ineffective HF Release Mitigation and Response Sys­tems. • <25% very effective for 5 systems. These in­cluded: off-site alarms and notification systems, utility back-up

17. Conclusions Conclusions • HF disaster potential at refining operations is so great that it may be impossible for refineries to be fully prepared to re­spond once a major incident is underway • Overall, HF-using refineries are not fully prepared to pre­vent or to respond to HF incidents especially those traveling off-site or involv­ing worst case scenarios

18. Conclusions Conclusions • Substituting safer processes using safer chemicals is the only real solution • Much, much safer alternative chemicals and processes are available. Examples • solid acid catalyst • ionic liquid catalyst

19. Recommendations Eight Steps to Safer Refineries (Preliminary) • USW is calling for refineries and other primary stakeholders to engage in the following:

20. Recommendations Eight Steps to Safer Refineries (Preliminary) 1. Educate Workers and the Public About the Dangers of HF 2. Investigate Safer Alternatives to HF • Explore sites using safer, alternative alkylation processes to develop competencies for transitioning to safer processes and operations.

21. Recommendations Eight Steps to Safer Refineries (Preliminary) 3. Test Alternative Solutions • Each refining company should test pilot alkylation operations using an existing safer alternative method including solid acid and liquid ionic processes. 4. Share Lessons to Speed Effective Transition • Share lessons learned from pilot operations to enlist all stakeholders in moving alternatives forward.

22. Recommendations Eight Steps to Safer Refineries (Preliminary) 5. Commit to Getting the HF Out • Commit to a goal of replacing all HF-using alkylation processes with safer alternatives as soon as possible (e.g., within 10 years). 6. Make Existing Processes & Operations Much Safer • Apply all necessary resources to ensure that HF processes and mitigation systems are in optimal working order, regularly inspected, and subject to rigorous audits and preventative maintenance. • Engage in an open process for developing, testing and critiquing prevention, preparedness and response capabilities including drills. • At least annually, appraise all stakeholders with a site-based record of significant operational up­sets and loss of primary containment incidents, equipment failures, etc.

23. Recommendations Eight Steps to Safer Refineries (Preliminary) 7. Comprehensively Inspect and Enforce Regulations During the Transi­tion to Safer Chemicals/Processes • Increase inspections and as­sessments to ensure full compliance with all applicable regulations, standards, laws and ordin­ances. 8. Ensure Staffing to Sufficiently Prevent, Prepare and Respond • Use nuclear industry and other models to ensure staffing (numbers, qualifications, experience and competencies) to ensure optimal safety during all operations including emergencies.