Inherently Safer Technology (IST) not always that

Currently Congress is considering new regulations for chemical plants — Chemical Facility Anti-Terrorism Standards or CFATS — that will, if enacted, require substitution of technologies believed to be less vulnerable to terrorist attack.

These regulations would affect facilities in addition to those we usually picture when thinking of chemical plants. The Wichita water treatment plant, for example, could be affected.

The problem is that chemical manufacturing and processing is a complicated matter, and mandates that force the use of one chemical instead of another can have consequences that lead to less safety.

An example of this may be found in the study Petroleum Refiners & Inherently Safer Technology: The Realities of Hydrofluoric and Sulfuric Acid. (I recommend reading the executive summary.) It’s from the National Petrochemical & Refiners Association, a national trade association.

Proponents of IST would like oil refineries to switch to sulfuric acid as a safer alternative to hydrofluoric acid. This sounds like a reasonable measure, until you dig a little deeper. Then, you’ll find this:

The alkylation process takes roughly 250 times more sulfuric acid than hydrofluoric acid to achieve the same result; therefore, a forced switch to sulfuric acid would result in a significant increase in transportation and transfer of the substance. For a 10,000 barrel per day alkylation unit, this equates to one to two truckloads of hydrofluoric acid delivered to the refinery each month, compared to three to four truckloads of regenerated sulfuric acid coming in and three to four truckloads of spent sulfuric acid going out each day.

This is an example of how seemingly small shifts in technology can have a big impact. In this case, many more trucks carrying a still-dangerous acid would be on our roads and highways.

There’s also a cost consideration: “A mandate for a refinery to switch from hydrofluoric acid to sulfuric acid will result in capital and design costs between $45 and $150 million dollars per refinery and an increase in operating costs of between 200 and 400 percent.”

As all refineries would face these costs, it’s very likely that these costs would be passed on to consumers. Except: foreign refiners would not be subject to these expensive technology requirements. This raises the possibility of the United States importing gasoline in large quantities — an unintended consequence that I don’t believe Congress intends.


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