UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX A "a 75 Hawthorne Street Saw 7 San Francisco, CA 94105 dq?PRd?? OCT 2 5 2015 Delivered Via certified mail: 7014 1820 0000 4722 5188 RETURN RECEIPT REQUESTED In Reply Refer to: Torrance Refining Company, Torrance, CA Steve Steach, Refinery Manager PBF Energy Western Region LLC d/b/a Torrance Refining Company 3700 West 190*11 Street Ton'ance, CA 90509?2929 RE: Request for Information Torrance Refining Company Dear Mr. Steach: The United States Environmental Protection Agency Region IX has scheduled an inspection of PEP Energy?s Torrance Refinery (the ?Facility?), located at 3700 West 190th Street, Torrance, CA 90509?2929, which is owned and operated by PBF Energy Western Region LLC (the ?Company?), to evaluate the Company?s compliance at the Facility with Section 103 of the Comprehensive Environmental Response, Compensation, and Liability Act 42 U.S.C. 9603; Sections 302 through 312 of the Emergency Planning and Community Right-to? Know Act 42 U.S.C. 11002 11022; and Section 112(1?) of the Clean Air Act 42 U.S.C. 7412(r). The inspection is scheduled to begin at 9:00 am. on November 1, 2016 and continue through November 4, 2016. The enclosed request for information (?Information Request?) is authorized pursuant to: - CERCLA, as amended, 42 U.S.C. 9601 et seq. 0 EPCRA, 42 U.S.C. 11001 et seq. 0 CAA, as amended, 42 U.S.C. 7401 et seq. Please note that the Company?s compliance with this Information Request is mandatory. Failure to respond fully and truthfully may result in enforcement action by EPA pursuant to Section 104(c)(5) of CERCLA, 42 U.S.C. 9604(e)(5), or Section 113(a)(3) of the CAA, 42 U.S.C. ?7413(a)(3). These statutory provisions authorize EPA to seek penalties up to $53,907 or higher for each day of noncompliance. Please be further advised that provision of false, fictitious, or fraudulent statements or representations may subject you to criminal penalties under 18 U.S.C. 1001. If you have questions about the legal aspects of this Information Request, please contact Mr. Andrew Helmlinger, US. EPA Assistant Regional Counsel, at (415) 972?3904 or Helmlinger.Andrew@epa. gov. The Region IX technical contact for this Information Request is Jeremy Deyoe, Compliance Officer. Mr. Deyoe can be reached at (415) 972?3081 or Deyoe] eremy@epa. gov. We thank you in advance for your cooperation. Sincerely, Enrique Manzanilla, Director Superfund Division Enclosures Information Request (Instructions, Definitions, Requests) cc: M. Sema, Torrance Fire Department C. Trombettas, W. Nastri, SCAQMD ENCLOSURE INSTRUCTIONS 1. For each request, identify each response by the number of the request to which it corresponds. For each document produced, identify the request to which it is responsive. Knowledge or information that has not been memorialized in any document, but is nonetheless responsive to a request, must be provided in a narrative form. . The scope of this Information Request includes all information and documents obtained or independently developed by the Company, its attorneys, consultants or any of their agents, contractors, or employees. The Company may not withhold any information from EPA on the grounds that it is confidential business information. EPA has promulgated regulations, under 40 CPR. 2, Subpart B, to protect confidential business information that it receives. The Company may assert a business confidentiality claim (in the manner specified in 40 C.F.R. for all or part of the information requested by EPA. However, business information is entitled to confidential treatment only if it satisfies the criteria set forth in 40 C.F.R. 2.208. EPA will disclose business information entitled to confidential treatment only as authorized by 40 C.F.R. 2, Subpart B. If no claim of confidentiality accompanies the information at the time EPA receives it, EPA may make it available to the public without further notice. Notice is hereby given, pursuant to 40 CPR. 2.301(h) and that EPA may disclose confidential information provided by the Company to authorized representatives, including its contractors, Eastern Research Group, Inc. Confidential information may be disclosed to authorized representatives for the following reasons: to assist with document handling, inventory and indexing; to assist with document review and analysis for verification of completeness; and to provide expert technical review of the contents of the response. Pursuant to 40 CPR. and the Company may submit, along with its response to this Information Request, any comments regarding disclosure of confidential information to its authorized representatives. If information or documents not known or available to the Company at the time of its response to this Information Request later become known or available to it, it must supplement its response to EPA. Moreover, should the Company find at any time after the submission of its response that any portion of the submitted information is false or misrepresents the truth, the Company must notify EPA as soon as possible and provide EPA with a corrected response. If information responsive to a request is not in the Company?s possession, custody, or control, identify the persons or entities from whom such information may be obtained. For each individual or entity that possesses responsive information, please provide the following: name, last known or current address, telephone number, and affiliation with the Company or the Facility. If you believe there are grounds for withholding information or documents that are responsive to this request, e. attorney~client privilege, you must identify the information or documents and state the basis for withholding. . Electronic data should not be provided as an image format or in a restricted format, such as locked Microsoft Excel spreadsheet cells. The format should allow for data to be used in calculations by a standard spreadsheet program such as Excel. For example, if the document was created as a Microsoft Excel file, do not print out the results and send EPA print-outs. Rather, send EPA a copy of the Microsoft Excel file. DEFINITIONS The following definitions apply to the following terms (words or phrases) as they appear in this Information Request. Defined terms are enclosed in quotation marks: 10. 11. 12. 13. 14. ?You? or the ?Company? shall mean PBF Energy, or its officers, managers, employees, contractors, trustees, partners, successors, assigns, and agents. ?Facility? means all buildings, equipment, structures, installations, pipes, or stationary items owned, leased, or operated by PBF Energy, at the Torrance Refinery property or properties located at 3700 West 190th Street, Torrance, CA 90509?2929, or contiguous or adjacent to that address. ?Document? or ?documents? shall mean any printing, typing, writing, photostat, or any other copy, microfilm, film record, video record, CD, sound recording, tape, disc, or other type of memory associated with computers, including any instructions necessary to read such material, and any other tangible item recording information. All terms not defined herein shall have their ordinary meaning, unless such terms are defined in the CAA, 40 C.F.R. Part 68, in which case the statutory or regulatory definitions shall apply. ?Alkylation Unit? shall include any alkylation process and all related equipment and controls which are in hydro?uoric acid service, including but not limited to the alkylation reactors, acid settlers, the Fresh Acid Tank 5031, and the Acid Evacuation System (AES). INFORMATION REQUEST REQUESTS REGARDING THE CLEAN AIR ACT SECTION 112(1?) RISK MANAGEMENT PROGRAM -The following documents must be readily available during the inspection beginning November 1, 2016. Please provide piping and instrumentation diagrams described below as 11 inch by 17 inch sized paper?during the inspection. 1.. Provide a copy of both the Company and Facility policies that define, describe, and provide responsibilities for implementing the overall Risk Management Program Provide an organizational chart for the Facility that indicates the position or title responsible for each RMP element. Provide all Management of Organizational Change documents for the transition from ExxonMobil to PEP Energy. Provide the schedule for completing Process Hazard Analysis indicating which will be re?do?s and which will be revalidations. Provide a list of all Alkylation Unit operating procedures. Provide a list of all ?aring system(s) Operating procedures. For the Alkylation Unit, provide the following: a. Design manuals provided by the organization which designed the process, such as for example UOP, Phillips, Exxon, etc.; Operating manuals used for operator training; All All process flow diagrams; The safe operating limits; The most recent completed A copy of Facility?s current policies and procedures used to conduct any A list and description of all of the safeguards, to include, permissive controls and systems, automatic shutdowns and systems, loading and unloading safeguards, pressure relief devices, water curtains, trips and related systems, and safety instrumented systems Please identify equipment with the same identifiers found on the i. A list of all Alkylation Unit safeguards and safety equipment currently using the same identifiers found on the j. The inspection, testing, and preventative maintenance history since and including the last planned turnaround and required frequencies for all of the safeguards to include, permissive controls and systems, automatic shutdowns and systems, loading and unloading safeguards, pressure relief devices, water curtains, trips and related systems, and and tract-banned? 10Management of Change document packages since and including the last planned turnaround related to bypasses of safety equipment and safety systems to include the loading and unloading equipment. Provide a list of all clamps currently installed in the Alkylation Unit. For each clamp include the installation date, the associated Management of Change number or reference, and the reason for the clamp?s installation. Provide a copy of strategies used by the Facility during Facility-wide or partial power outages. Provide the emergency operating procedure from each process unit that addresses power outages. Since taking ownership of the Facility, describe in detail options that the Company has identified to avoid future power grid interruptions. Provide a list and description of all without uninterruptable/universa1 power supply systems. the covered process units For each of the covered process units with uninterruptableluniversal power supply system, provide the following: - a. The ITPM history since and including the last planned turnaround; and b. The required frequencies for ITPM. Provide a list and narrative description of ?aring events due to power outages that have occurred at the Facility, from January 2012 to present. For each of the ?aring events described in response to question 15 of this letter, provide a copy of the incident investigations conducted by the Facility and the notifications and/or reports submitted by the Facility-to EPA, state and local agencies. For each ?are system (knock out drums, compressors, ?are) at the Facility, provide the following: A description of the ?are system design; The safe Operating limits; The maximum design capacity ?ow rate in pounds per hour of gas and of liquid; A process ?ow diagram that identifies the unit pressure relief devices associated with the ?are system; The most recent completed hazard review; that identifies the unit PRDs associated with the ?are system; and A list of the process unit PRDs associated with the ?are system, including the design case ?ow rates in pounds per hour of gas and of liquid for each PRDs. Please identify the PRDs using the same identifiers found on 999?s term 17. Describe any agreements that the Company and ExxonMobil Corporation made, if any, regarding environmental liability at the Facility when the Facility was sold to the Company in 2016. Please provide any supporting documentation.