Petrochemical industry standards are largely self-directed, so any pipes installed before the regulations were updated in 1995 were grandfathered in, despite the fact that the American Petroleum Institute’s own recommended practice for “Safe Operation of Hydrofluoric Acid Alkylation Unit,” last updated in May 2013, states: “HF corrosion has been found to be strongly affected by steel composition and localized corrosion rates can be subtly affected by local chemistry differences.”
The CSB report says the pipe did not meet the safety standards established in 1995. Despite this, evaluation of the pipe required by both OSHA and the EPA never occurred.
“To prevent catastrophic incidents companies and industry trade groups must ensure process safety when new knowledge on hazards is published,” said CSB Supervisory Investigator Lauren Grim.
Pipe maintenance and composition standards are set by industry groups, and refineries generally police themselves.
The report found that the refinery lacked remote emergency isolation valves that would have prevented the flow of HF through the ruptured pipe. Water pumps in place to suppress any accidental release of HF also failed due to the explosion and fire. Spraying water on a release of HF is the best way to minimize the damage. It took a worker 40 minutes to manually turn on a water pump that would lessen the amount of HF released.
The CSB is an independent federal agency that conducts investigations of major accidents and issues reports, but can only make recommendations to industry and regulators. It called on the American Petroleum Institute to update their safety standards.
An API spokesperson said the standards are “reviewed and updated on a regular basis.”
“We are reviewing the CSB’s recommendation and look forward to continuing to work collaboratively with the Board to ensure the safety of our nation’s refining infrastructure,” said API spokesperson Scott Lauermann.
Hydrofluoric acid is regulated by both the Environmental Protection Agency and the Occupational Safety and Health Administration.
OSHA does so under the Process Safety Management of Highly Hazardous Chemicals.
The EPA’s Risk Management Plan Rule governs public disclosures surrounding the use and accidental release of toxic chemicals, as well as emergency response.
Several safer alternatives to using hydroflouric acid as a catalyst have been developed, including the use of sulfuric acid. But there is no federal regulatory requirement for refiners to use or even consider these alternatives. The CSB recommends the EPA require refineries to conduct analysis of alternatives as part of the RMP rule.
It also urged the EPA to further study HF under the Toxic Substances Control Act. If the EPA determines it is a “high priority substance for risk evaluation” then it should “conduct TSCA risk evaluation of HF” and put in place policies to mitigate that risk, according to the report.