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City of
Richmond
Annual
Performance
Review &
Evaluation
Report
July 26, 2011
Industrial Safety Ordinance 2010 Report 1
By Contra Costa Health Services Hazardous Materials Programs
Table of Contents
Executive Summary ..........................................................................................3
Public Participation ...........................................................................................4
Audits ..................................................................................................................4
Major Chemical Accidents or Releases ..........................................................4
Conclusion .........................................................................................................4
Introduction .......................................................................................................5
Annual Performance Review and Evaluation Report ...................................5
Effectiveness of Contra Costa Health Services’ Implementation of the
Industrial Safety Ordinance .............................................................................6
Effectiveness of the Procedures for Records Management ..........................6
Number and Type of Audits and Inspections Conducted ...........................7
Number of Root Cause Analyses and/or Incident Investigations
Conducted by Health Services .........................................................................8
Health Services’ Process for Public Participation .........................................8
Effectiveness of the Public Information Bank ...............................................8
Effectiveness of the Hazardous Materials Ombudsman...............................9
Proposed Amendments to the Richmond Industrial Safety Ordinance. .11
Other Required Program Elements Necessary to Implement and
Manage the Industrial Safety Ordinance ......................................................11
Regulated Stationary Sources Listing ...........................................................12
Locations of the Regulated Stationary Sources Safety Plans......................13
Annual Accident History Report and Inherently Safer Systems
Implemented as Submitted by the Regulated Stationary Sources .............14
Status of the Incident Investigations, Including the Root Cause
Analyses Conducted by the Regulated Stationary Sources ........................16
Major Chemical Accidents or Releases ........................................................17
Legal Enforcement Actions Initiated by Health Services ...........................18
Penalties Assessed as a Result of Enforcement ............................................18
Total Fees, Service Charges, and Other Assessments Collected
Specifically for the Industrial Safety Ordinance ..........................................18
Total Personnel and Personnel Years Used by Health Services to
Implement the Industrial Safety Ordinance ................................................18
Comments From Interested Parties Regarding the Effectiveness of the
Industrial Safety Ordinance ...........................................................................19
The Impact of the Industrial Safety Ordinance on Improving
Industrial Safety ...............................................................................................19
Attachment A: Hazardous Materials Ombudsman Report .......................21
Attachment B: Regulated Sources Annual Performance with
Accident History and Inherent Safety Implementation .............................25
Annual Performance Review and Evaluation Submittal ............................25
Annual Performance Review and Evaluation Submittal ............................29
Industrial Safety Ordinance 2010 Report 2
Executive Summary
The Industrial Safety Ordinance requires regulated facilities to implement
safety programs to prevent chemical accidents from occurring that could have
a detrimental impact to the surrounding communities. The requirement of the
Industrial Safety Ordinance is one of the most stringent in the United States,
if not the world. Additionally, the Industrial Safety Ordinance is designed to
include participation from all of the stakeholders, from industry and agencies
to elected officials and the public.
Since the Richmond Industrial Safety Ordinance took effect in 2002,
there has not been a inconsistent capitalization of severity Type III Major
Chemical Accident or Release in the City of Richmond. The trend since
the adoption of the Industrial Safety Ordinance has been less severe and
fewer Major Chemical Accidents or Releases (MCAR ) each year. The
last MCAR Severity Type II event in the City of Richmond was more
than four years ago. Overall, this is an indication of the effect of the
Industrial Safety Ordinance, the regulated facilities implementation of the
requirements and the oversight from the Accidental Release Prevention
Programs Engineers.
The Accidental Release Prevention Programs Engineers are continuing
to develop ways to improve the overall implementation of the Industrial
Safety Ordinance and the prevention program elements. The Hazardous
Materials Programs Staff participated with the Center for Chemical
Process Safety in writing the second edition of the book “Inherently Safer
Chemical Processes”, that was published in spring 2009. The staff has
also been working with other agencies such as the U.S. Environmental
Protection Agency and California Occupational Safety and Health
Administration, for sharing of inspection results. Staff also worked with
the Contra Costa County regulated businesses in the development of
the Safety Culture Guidance Document. Currently, without the City of
Richmond’s adoption of the County’s 2006 amendment, both Chevron
and General Chemical Richmond are not required to perform a Safety
Culture Assessment or some of the expanded requirements in the
amendment.
The U.S. Chemical Safety and Hazard Investigation Board (CSB) has
recognized the efforts of Contra Costa County in ensuring that the
process safety requirements are being implemented by the County’s
regulated businesses in CSB’s DVD “Anatomy of a Disaster: Explosion
at BP Texas City Refinery” and the “Fire in the Valley.” The CSB has also
recommended that West Virginia or Kanawaha Valley set up a program
to inspect chemical facilities using Contra Costa County as a model.
Contra Costa Hazardous Materials Programs was asked to give testimony
at the hearing on "Work Place Safety and Worker Protections in the
Gas and Oil Industry" before the U.S. Senate Committee on Health,
Industrial Safety Ordinance 2010 Report 3
Audits
Education, Labor, and Pensions Subcommittee
on Employment and Workplace Safety. The
testimony was on the success of the Accidental Audits of the regulated businesses are required
Release Prevention Programs that are in place in at least once every three years to ensure that the
Contra Costa County. The hearing was specific on facilities have the required programs in place and
two major incidents that occurred in Anacortes, are implementing the programs. We did not perform
Washington at a Tesoro Refinery and the Deepwater audits in City of Richmond in 2010.
Horizon incident in the Gulf of Mexico. Major Chemical Accidents or
Releases
Public Participation Another measure of the effectiveness of the
The Hazardous Materials Programs has an Industrial Safety Ordinance is by the number and
established public outreach process and is severity of Major Chemical Accidents or Releases
constantly looking at ways for improvement. The that have occurred. In the last year there were
following items have been implemented based on four Major Chemical Accidents or Releases with
recommendations from interested stakeholders and a severity Type I that resulted in a minor injury
the actions taken this year: and impact to the community but none of these
occurred from the two Richmond facilities.
• Public outreach information booths at
existing venues
» General Chemical Richmond Safety
Conclusion
The number and severity of Major Chemical
Plan and preliminary audit findings
Accidents or Releases have been in a generally
and Chevron Richmond Refinery Safety
declining trend since the implementation of
Plan were shared at the West County
Industrial Safety Ordinance. The implementation
Emergency Preparedness Fair at Hilltop
of the Industrial Safety Ordinance has improved
Mall in Richmond in September 2010.
and, in most cases, is being done as required by
• Most recent audit findings summarized
the ordinance. It is believed that by continuing
in easily read format in both English and
implementation of the Industrial Safety Ordinance
Spanish
and strengthening the requirements of the
• Information on regulated businesses in an
Ordinance the possibility of accidents that could
easily read format in English and Spanish
impact the community has decreased.
• Industrial Safety Ordinance Information
Sheet in English and Spanish
Industrial Safety Ordinance 2010 Report 4
Introduction • Contra Costa Health Services will give an
The City of Richmond adopted the Industrial Safety annual performance review and evaluation
Ordinance after the Contra Costa County Board report to the City Council.
of Supervisors passed the County Industrial Safety
Ordinance because of accidents that occurred Annual Performance Review
at oil refineries and chemical plants in Contra
Costa County. The effective date of the Richmond
and Evaluation Report
The Industrial Safety Ordinance specifies that the
Industrial Safety Ordinance was January 7, 2002.
contents of the annual performance review and
The ordinance applies to oil refineries and chemical
evaluation report contain the following:
plants with specified North American Industry
• A brief description of how Health Services is
Classification System (NAICS) codes that were
meeting the requirements of the ordinance as
required to submit a Risk Management Plan to the
follows:
U.S. EPA and are program level 3 stationary sources
» Effectiveness of the department’s
as defined by the California Accidental Release
program to ensure stationary sources’
Prevention (CalARP) Program. The ordinance
compliance with the ordinance
specifies the following:
» Effectiveness of the procedures for
• Stationary sources must submit a Safety Plan
records management
to Contra Costa Health Services stating how
» Number and type of audits and
the stationary source is complying with the
inspections conducted by Health
ordinance, including the Human Factors
Services as required by the ordinance
program.
» Number of root cause analyses and/or
• Stationary sources must comply with the
incident investigations conducted by
requirements of the Human Factor Guidance
Health Services
Document that was developed by Contra
» Health Services’ process for public
Costa Health Services and was adopted by
participation
reference.
» Effectiveness of the Public Information
• For Major Chemical Accidents or Releases,
Bank
stationary sources are required to perform a
» Effectiveness of the Hazardous Materials
root cause analysis as part of their incident
Ombudsperson
investigations (ongoing)
» Other required program elements
• Contra Costa Health Services may perform
necessary to implement and manage the
its own incident investigation, including a
ordinance
root cause analysis (ongoing)
• All of the processes at the stationary source
• A listing of stationary sources covered by the
are covered as program level 3 processes as
ordinance, including for each:
defined by the California Accidental Release
» The status of the stationary source’s
Prevention Program
Safety Plan and Program
• The stationary sources are required to
» A summary of all stationary sources’
consider Inherently Safer Systems for new
Safety Plan updates and a listing of where
processes or facilities or for mitigations
the Safety Plans are publicly available
resulting from a process hazard analysis
» The annual accident history report
• Contra Costa Health Services will review
submitted by the regulated stationary
all of the submitted Safety Plans and audit/
sources and required by the ordinance
inspect all of the stationary sources’ Safety
» A summary, including the status, of
Programs within one year of the receipt of
any root cause analyses and incident
the Safety Plans and every three years after
investigations conducted or being
the initial audit/inspection (ongoing)
conducted by the stationary sources and
Industrial Safety Ordinance 2010 Report 5
required by the ordinance, including • Safe Work Practices Questionnaires
the status of implementation of • CalARP Program Audit Questionnaires
recommendations • Safety Program Audit Questionnaires
» A summary, including the status, of any • Conducting Employee Interviews Protocol
audits, inspections, root cause analyses • Employee Interview Questionnaires
and/or incident investigations conducted • Public Participation Policy
by Health Services, including the status • Dispute Resolution Policy
for implementing the recommendations • Reclassification Policy
» Description of inherently safer systems • Covered Process Modification Policy
implemented by the regulated stationary • CalARP Internal Performance Audit Policy
source • Conducting the Internal Performance Audit
» Legal enforcement actions initiated • CalARP Internal Audit Performance Audit
by Health Services, including Submission
administrative, civil and criminal actions • Fee Policy
• Total penalties assessed as a result of • Notification Policy
enforcement of the ordinance • Unannounced Inspection Policy
• Total fees, service charges and other • Risk Management Plan Public Review Policy
assessments collected specifically for the
support of the ordinance Health Services has developed the Contra Costa
• Total personnel and personnel years used County CalARP Program Guidance Document
by the jurisdiction to directly implement or and the Contra Costa County Safety Program
administer the ordinance Guidance Document including the Safety Culture
• Comments from interested parties regarding Assessment, which at this time is not required by
the effectiveness of the local program that the Richmond Industrial Safety Ordinance. An
raise public safety issues updated draft Contra Costa County Safety Program
• The impact of the ordinance in improving Guidance Document was issued September 30,
industrial safety 2010 to the regulated facilities. The updated draft
incorporated updates from the ISO amendments
(the City of Richmond has not approved these
Effectiveness of Contra amendments) and additional clarifications from all
Costa Health Services’ the audits, these documents give guidance to the
stationary sources for complying with the Industrial
Implementation of the Safety Ordinance. The policies, procedures,
Industrial Safety Ordinance protocols and questionnaires, are available through
Health Services has developed policies, procedures, Health Services. The guidance documents can be
protocols and questionnaires to implement both the downloaded through Health Services’ website:
California Accidental Release Prevention Program www.cchealth.org/groups/hazmat/california_
and the Industrial Safety Ordinance. The policies, accidental_release_prevention_guidance_
procedures, protocols and questionnaires for these document.php and www.cchealth.org/groups/
programs are listed below: hazmat/industrial_safety_ordinance_guidance.php
• Audits/Inspections Policy
Effectiveness of the Procedures
• Conducting the Risk Management Plan/
Safety Plan Completeness Review Protocol
• Risk Management Plan Completeness for Records Management
Review Questionnaires Health Services has set up hard copy and computer
• Safety Plan Completeness Review files for each of the stationary sources. The files
Questionnaires include the following folders:
• Conducting Audits/Inspections Protocol 1. Annual Status Reports
Industrial Safety Ordinance 2010 Report 6
2. Audits & Inspections Homeownership Faire & Disaster Preparedness
3. Communications Expo.
4. Completeness Review
5. Emergency Response Chevron Richmond Refinery was audited for the
6. Incident Investigation third time for RISO/CalARP program in April
7. Trade Secret Information 2008 and the final report has been finalized and
results were available at the Recycle More Earth Day
The paper files for the stationary sources are kept Event in Richmond in June 2009. Health Services
in a central location. The Accidental Release performed an RISO/CalARP program audit at
Prevention Programs staff has files set up on the General Chemical Richmond in January 2009.
Health Services network where the files for each The final report was shared at a public event in
of the different stationary sources are found and Richmond in September 2010. Copies of these audit
are accessible to each of the Accidental Release results are available at the Richmond Library and a
Prevention Programs Engineers, Supervisor and summary of the audit is also available on Hazardous
the Chief Environmental Health and HazMat Materials Programs’ website. The fourth round of
Officer. Portable document format of these files is RISO audits began in Febuary 2011 with Chevron.
also available at the Hazardous Materials Programs
office for public access and viewing. The Accidental When Hazardous Materials Programs reviews a
Release Prevention Programs files also contain Safety Plan, a Notice of Deficiencies is produced
regulations, policies, information from the U.S. to document what changes to a stationary source
EPA , California Emergergency Management Agency is required to make before Hazardous Materials
(CalEMA), the U.S. Chemical Safety and Hazards Program determines that the Safety Plan is
Investigation Board and other information pertinent complete. The stationary source has 60 to 90 days
to the engineers. The risk management and safety to respond to the Notice of Deficiencies. When the
plans received are kept at the Hazardous Materials stationary source has responded to this Notice of
Program offices. Deficiencies, Hazardous Materials Programs will
review the response. Hazardous Materials Programs
Number and Type of Audits and will either determine that the Safety Plan is complete
or will work with the stationary source until the
Inspections Conducted Safety Plan contains the required information for it
Hazardous Materials Programs was required to audit to be considered complete. When the Safety Plan is
and inspect the two regulated stationary sources deemed complete, Hazardous Materials Programs
that were required to comply with the Richmond’s will open a public comment period on the Safety
Industrial Safety Ordinance (RISO) within one Plan and will make available the plan in a public
year after the initial submittal of their Safety meeting or venue. Hazardous Materials Programs
Plans. Health Services reviewed all of the Safety will respond to all written comments in writing and
Plans and audited/inspected all of the stationary when appropriate use the comments in the audit/
sources’ Safety Programs within that year (2003). inspection of the regulated stationary sources.
The public comment period for these plans ended
in January 2004. Public meetings held in 2004 in Hazardous Materials Programs will issue
North Richmond and Richmond discussed Chevron Preliminary Audit Findings after an audit/inspection
and General Chemical West Richmond Works is complete. The stationary source will have 90
audit findings. The second Richmond Industrial days to respond to these findings. Hazardous
Safety Ordinance/CalARP Program audits for these Materials Programs will review the response from
facilities occurred in 2006 and public meetings the stationary source on the Preliminary Audit
were held in June 2007 at Hilltop Mall at “Lessons Findings. When the stationary source has developed
from Katrina,” the 2007 Neighbor Works Week an action plan to come into compliance with the
Industrial Safety Ordinance 2010 Report 7
regulations, Hazardous Materials Programs will Effectiveness of the Public
issue the Preliminary Audit Findings for public
comment and will make available the findings in Information Bank
a public meeting or venue. Hazardous Materials The Hazardous Materials Programs section of
Programs will consider any public comments that Health Services website www.cchealth.org/groups/
were received during the public comment period hazmat/ includes the following information:
and if appropriate will revise the Preliminary • Industrial Safety Ordinance
Audit Findings. When this is complete, Hazardous » Description of covered facilities
Materials Programs will issue the Final Audit » Risk Management Chapter discussion
Findings and will respond in writing to any written – Copy of the ordinance
public comments received. The status of the reviews » Land Use Permit Chapter discussion
and all audits are discussed in Table I within the – Copy of the ordinance
report. » Safety Program Guidance Document
» Frequently Asked Questions
» Public Outreach strategies
Number of Root Cause Analyses • California Accidental Release Prevention
and/or Incident Investigations (CalARP) Program
Conducted by Health Services » Contra Costa County’s California
Accidental Release Prevention Program
The Hazardous Materials Programs has not
Guidance Document
performed any root-cause analyses or incident
» Program Level description
investigations in the last year. A historical listing of
» Discussion on Public Participation for
the Major Chemical Accidents or Releases dating
both CalARP Program and the Industrial
back to 1992 can be found on the Health Services
Safety Ordinance
website at the following address: www.cchealth.
» A map locating the facilities that are
org/groups/hazmat/accident_history.php. This list
subject to the CalARP Program and are
includes major accidents that occurred prior to the
required to submit a Risk Management
adoption of the Industrial Safety Ordinance.
Plan to Health Services. The map links to
a description of each of the facilities and
Health Services’ Process for the regulated substances handled.
Public Participation • Hazardous Materials Inventories and
In 2005, Hazardous Materials Programs worked with Emergency Response Program
the community and developed materials that would » Descriptions
describe the Industrial Safety Ordinance using a » Forms
number of different approaches. The community • Underground Storage Tanks
representatives suggested that Hazardous Materials » Description of the program
Programs look at existing venues that are attended » Copies of the Underground Storage
by the public that the Hazardous Materials Tanks Health & Safety Code sections
Programs’ staff can share and receive comments » Underground Storage Tanks forms
on Preliminary Audit Findings and the stationary • Green Business Program
sources’ Safety Plans. » Description of the Green Business
Program with a link to the Association
of Bay Area Government’s website on the
Green Business Program
Industrial Safety Ordinance 2010 Report 8
• Hazardous Materials Incident Response • Hazardous Materials Program Incident
Team Search
» Including information of the Major » Online search of the hazardous materials
Chemical Accidents or Releases that incident database for incidents that have
have occurred occurred since 1993 by entering a date
» The County’s Hazardous Materials range, address, city and/or facility name
Incident Notification Policy • Facility Search
» A link to the ConocoPhillips Fenceline » Online search of the facilities that
Monitors handle hazardous materials by name of
the facility, street name, and city or any
combination of the three
• Unannounced Inspection Program
» Lists the facilities that are subject to
unannounced inspections under the
Unannounced Inspection Program
• Hazardous Materials Interagency Task Force
» Includes a matrix of who has what
hazardous materials and regulatory
responsibilities
» Minutes from past meetings
» Presentations from past meetings
• Incident Response
» Accident history that lists summaries of
major accidents from industrial facilities
in Contra Costa County from most
recent to 1992
• Additional resource links for more information
Effectiveness of the Hazardous
Materials Ombudsman
The Contra Costa County Board of Supervisors
created the Hazardous Materials Ombudsperson
position in 1997. This position was filled in April
1998. The Board believed that the ombudsperson
would be a conduit for the public to express
concerns about how Hazardous Materials Programs
personnel are performing their duties. Attachment
A is a report from the Hazardous Materials
Ombudsman on the effectiveness of the position.
Industrial Safety Ordinance 2010 Report 9
TABLE I
INDUSTRIAL SAFETY ORDINANCE STATIONARY SOURCE STATUS
name safety plan notice of safety plan sp public audit/ audit
(sp) received deficiencies complete meeting inspection public
(nod) date meeting
issued-sp
Chevron 1/21/03 4/23/03 10/10/03 10/14/03 1/11/01 6/24/04
(Non-RISO)
6/21/04 6/22/04 6/24/04 9/29/03 6/2/07
9/29/06 5/21/07 6/2/07 2/13/06 4/25/09
9/25/09 11/4/09 9/25/10 4/14/08
General 1/17/03 4/11/03 10/10/03 10/14/03 5/29/01 6/24/04
Chemical (Non-RISO)
Richmond
Works 6/21/04 2/18/10 4/17/06 6/2/07 4/24/06 6/2/07
4/17/09 5/26/10 9/25/10 8/18/03 9/25/10
1/5/09
Industrial Safety Ordinance 2010 Report 10
Proposed Amendments to the
Richmond Industrial Safety
Ordinance.
In 2006, the Contra Costa County Supervisors
adopted amendments to the Industrial Safety
Ordinance and required or expanded the following:
1. Expand the Human Factors Program to
included Maintenance
2. Expand the Management of Organizational
change to include Maintenance and all of
Health and Safety positions
3. Require the stationary sources to perform
Safety Culture Assessments one year after
the Hazardous Materials Programs develops
guidance on performing a Safety Culture
Assessment
4. Perform Security Vulnerability Analysis
Since the amendment, Hazardous Materials
Programs staff worked with the stationary sources
to develop Safety Culture Assessment Guidance
Document which was finalized and issued on
November 10, 2009. Staff began the review of these
Safety Culture Assessments in December 2010
that are subject to the County’s Industrial Safety
Ordinance. Additionally, staff is working with the
stationary source to revise the Safety Program
Guidance Document to reflect the ISO amendments,
and clarifications based on the audit findings.
The Hazardous Materials Programs staff encourages
the City Council to consider adoption of the 2006
ISO amendments for the Richmond Industrial
Safety Ordinance, as well to further improve upon
the safety programs that are in place at the two
facilities in the City of Richmond.
Other Required Program
Elements Necessary to
Implement and Manage the
Industrial Safety Ordinance
The California Accidental Release Prevention
(CalARP) Program is administered in Contra
Costa County by Contra Costa Health Services
Hazardous Materials Programs. The Industrial
Industrial Safety Ordinance 2010 Report 11
Safety Ordinance expands on this program.
Stationary sources are required to submit a Risk
Management Plan to Hazardous Materials Programs
that is similar to the Safety Plans that are submitted.
Hazardous Materials Programs reviews these Risk
Management Plans and performs the CalARP
Program audit simultaneously with the Industrial
Safety Ordinance audit.
Hazardous Materials Programs Performs
Unannounced Inspections of the stationary sources
that are part of the CalARP Program and are also
required to submit a Risk Management Plan to
the U.S. EPA . These inspections look at a focused
portion of the CalARP Program or Industrial Safety
Ordinance requirements, as well as elements from
the other Hazardous Materials Programs.
Regulated Stationary Sources
Listing
The Status of the Regulated Stationary
Sources’ Safety Plans and Programs
All of the stationary sources regulated by the
Richmond Industrial Safety Ordinance were
required to submit their Safety Plans to Health
Services by January 7, 2002 and to have their Safety
Programs including the Human Factors Program
completed and implemented. The status of each of
the regulated stationary sources is given in Table I
and includes the following:
• When the latest updated Safety Plan was
submitted
• When the Notice of Deficiencies were issued
• When the plan was determined to be
complete by Health Services
• When the public meeting was held on the
Safety Plan
• When the audits were complete
• When the public meetings were held on the
preliminary audit findings
• When the Human Factors to the Safety Plan
was revised
• When the Notice of Deficiencies was issued
for the Human Factors revised Safety Plan
• When the Human Factors Safety Plan was
Industrial Safety Ordinance 2010 Report 12
determined to be complete
• When the Audit/Inspection was completed
• When the Human Factors Audit preliminary
findings Public Meeting was held
Locations of the Regulated
Stationary Sources Safety Plans
Each of the regulated stationary sources was
required to submit a Safety Plan that includes the
implementation of the stationary source’s Human
Factors Program to Health Services on January 7,
2002. The regulated stationary sources are required
to update their Safety Plan at least once every three
years. These plans are available for public review
at the Hazardous Materials Programs Offices at
4585 Pacheco Blvd., Suite 100, Martinez. When
Hazardous Materials Programs determines that
the Safety Plan is complete and prior to going out
for a 45-day public comment period, Hazardous
Materials Programs will place the plan in the
library(ies) closest to the regulated stationary
source. Below in Table II is a listing of the regulated
stationary sources with the location of each of their
Safety Plans.
TABLE II
LOCATION OF SAFETY PLANS - LIBRARIES
regulated stationary source location 1 location 2
Chevron Hazardous Materials Richmond Public
Programs Office Library
General Chemical Richmond Works Hazardous Materials Richmond Public
Programs Office Library
Industrial Safety Ordinance 2010 Report 13
Annual Accident History Report and Inherently Safer Systems
Implemented as Submitted by the Regulated Stationary Sources
The Industrial Safety Ordinance requires the stationary sources to update the information on their accident
history in their Safety Plans and include how they have used inherently safer processes within the last year. Table
III is a listing of some of the inherently safer systems that have been implemented by the different stationary
sources during the same period. Attachment B includes the individual reports from the stationary sources.
TABLE III
INHERENTLY SAFER SYSTEMS
regulated stationary inherently safer system design category
source implemented strategy
Chevron Reduce the impact by using a less Inherent Moderate
concentrated hazardous chemical
(1 time)
Reduced potential of exposure by Passive Minimization
removing or modifying piping and
equipment design (12 times)
Reduced the potential of a hazard by Passive Moderate
equipment/process design change
(32 times)
Revised equipment metallurgy, Passive Simplify
components, controls features
(14 times)
Reduced potential of a hazard by Active Moderate
adding control measures or equipment
(4 times)
Reduced potential of a hazard by Active Simplify
simplifying equipment (3 times)
General Chemical Reduce the impact by using a less Inherent Moderate
Richmond Works concentrated hazardous chemical or
operating condition (2 times)
Simplified equipment (Absorption Inherent Simplify
Tower, molten sulfur) piping (2 times)
Reduced wastewater volume (1 time) Inherent Minimization
Reduced potential of a hazard by Active Simplify
installing interlocks (1 time)
Industrial Safety Ordinance 2010 Report 14
TABLE IV
MAJOR CHEMICAL AND ACCIDENT RELEASE INCIDENT STATUS
No MCAR Event in 2010 for City of Richmond Industrial Safety Ordinance facilities.
Industrial Safety Ordinance 2010 Report 15
Status of the Incident • Causes on- or off-site property damage
(including cleanup and restoration activities)
Investigations, Including the initially estimated at $500,000 or more.
Root Cause Analyses Conducted On-site estimates shall be performed by the
by the Regulated Stationary regulated stationary source. Off-site estimates
shall be performed by appropriate agencies
Sources and compiled by Health Services
The Industrial Safety Ordinance requires the • Results in a vapor cloud of flammables or
regulated stationary sources to do an incident combustibles that is more than 5,000 pounds
investigation with a root cause analysis for each of
the major chemical accidents or releases as defined The regulated stationary source is required to submit
by the following: “Major Chemical Accident or a report to Hazardous materials programs 30 days
Release means an incident that meets the definition after the root cause analysis is complete. There have
of a Level 3 or Level 2 incident in the Community been no major chemical accidents or releases by a
Warning System incident level classification system Richmond Industrial Safety Ordinance regulated
defined in the Hazardous Materials Incident stationary source, since January 15, 2007.
Notification Policy, as determined by Contra Costa
Health Services; or results in the release of a regulated
substance and meets one or more of the following
criteria:
• Results in one or more fatalities
• Results in greater than 24 hours of hospital
treatment of three or more persons
Industrial Safety Ordinance 2010 Report 16
Major Chemical Accidents or the MCARs that have occurred at the the City of
Richmond’s Industrial Safety Ordinance stationary
Releases sources, and a chart showing the MCARs that have
Hazardous Materials Programs has analyzed the occurred at the County and the City of Richmond’s
Major Chemical Accidents or Releases (MCAR) Industrial Safety Ordinance stationary sources. The
that have occurred since the implementation of the charts also show the number of severity I, II and III
Industrial Safety Ordinance. The analysis includes MCARs for this period. There were four severity
the number and severity of the MCARs. Three type I MCAR events from Tesoro and Conoco
different levels of severity were assigned: Phillips in October and November this year that are
• Severity Level III – A fatality, serious injuries, not shown on the graphs. NOTE: The charts do
or major onsite or offsite damage occurred not include any transportation MCARs that have
• Severity Level II – An impact to the occurred.
community occurred, or if the situation was A weighted score has been developed giving more
slightly different the accident may have been weight to the higher severity incidents and a lower
considered major, or there is a recurring type weight to the less severe incidents. The purpose is
of incident at that facility to develop a metric of the overall process safety of
• Severity Level I – A release where there was facilities in the County, the facilities that are covered
no or minor injuries, the release had no or by the County and the City of Richmond Industrial
slight impact to the community, or there was Safety Ordinances, and the facilities that are covered
no or minor onsite damage by the County’s Industrial Safety Ordinance. A
Below are charts showing the number of MCARs Severity Level III incident is given nine points,
from January 1999 through September 2010 for Severity Level II three points, and Severity Level I
all stationary sources in Contra Costa County, one point. Below is a graph of this weighted scoring.
Major Chemical Accidents and Releases
12
10
Number of MCAR's
Total MCARs
8
Severity Level III
6
Severity Level II
4 Severity Level I
2
0
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010
Year
* 4 Severity I incidents at County ISO facilities in Oct, Nov 2010 not shown
County and Richmond ISO MCARs
12
10
Total MCARs
8
Severity Level III
6
Severity Level II
4 Severity Level I
2
0
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010
Year
* 4 Severity I incidents at County ISO facilities in Oct, Nov 2010 not shown
Industrial Safety Ordinance 2010 Report 17
Major Chemical Accidents and Releases
Weighted Score
30
25 Total MCARs
20
County &
15 Richmond ISO
County ISO
10
5
0
99
00
01
02
03
04
05
06
07
08
09
10
19
20
20
20
20
20
20
20
20
20
20
20
* 4 Severity I incidents at County ISO facilities in Oct, Nov 2010 not shown
Legal Enforcement Actions Total Fees, Service Charges, and
Initiated by Health Services Other Assessments Collected
As part of the enforcement of the Industrial Safety
Ordinance and the CalARP Program, Hazardous
Specifically for the Industrial
Materials Programs issues Notice of Deficiencies Safety Ordinance
on the Safety and Risk Management Plans and The fees charged for the Industrial Safety
issues Audit Findings on what a stationary source Ordinance are to cover the time that the Accidental
is required to change to come into compliance Release Prevention Engineers use to enforce the
with the regulations. Table I shows the action that ordinance, the position of the Hazardous Materials
has been taken by Hazardous Materials Programs. Ombudsman, outreach material and to cover a
Hazardous Materials Programs has not taken portion of the overhead for the Hazardous Materials
any action through the District Attorney’s Office Programs. The fees charged for administering this
for noncompliance with the requirements of the the County’s and the City of Richmond’s Industrial
Industrial Safety Ordinance. Safety Ordinances for the fiscal year 2009 –10 is
$713,631.
Penalties Assessed as
a Result of Enforcement Total Personnel and Personnel
No penalties have been assessed this year for Years Used by Health Services to
noncompliance with the Industrial Safety Ordinance. Implement the Industrial Safety
Ordinance
The Accidental Release Prevention Programs
Engineers have reviewed resubmitted Safety Plans,
prepared and presented information for public
meetings, performed audits of the stationary sources
for compliance with both the California Accidental
Release Prevention Program and Industrial Safety
Industrial Safety Ordinance 2010 Report 18
Ordinance and did follow-up work after a Major Comments From Interested
Chemical Accident or Release. The following is
a breakdown of the time that was spent on the Parties Regarding the
County’s and the City of Richmond’s Industrial Effectiveness of the Industrial
Safety Ordinances:
• One ISO/CalARP Program facility audit
Safety Ordinance
No comments were received on the County’s or the
was done between November 2009 and
City of Richmond’s Industrial Safety Ordinances
October 2010. It takes five engineers four
during the last year.
weeks to perform an ISO/CalARP Program
on-site portion of the audit. The audit
process encompasses off-site time that The Impact of the Industrial
includes a quality assurance process, working Safety Ordinance on Improving
with the facility to address any questions,
posting public notices, attending public Industrial Safety
forum to share audit findings, addressing Four programs are in place to reduce the potential
any questions from the public, and issuing of an accidental release from a regulated stationary
the final report. The total time taken to source that could impact the surrounding
perform this audit in 2010 was 950 hours. community. The four programs are the Process
Approximately one-third of the time was Safety Management Program administered
dedicated to the Industrial Safety Ordinance by Cal/OSHA, the federal Accidental Release
for a total of 316 hours. Prevention Program administered by the U.S.
• Developing Safety Culture Assessment EPA, the California Accidental Release Prevention
Guidance and establishing Process Safety Program administered locally by Hazardous
Measurement – 200 hours Materials Programs, and the Industrial Safety
• Reviewing information for the website – 40 Ordinance administered by Hazardous Materials
hours Programs. Each of the programs is very similar in
• Reviewing Safety Plans and following up requirements, with the Industrial Safety Ordinance
with the facilities on any deficiencies – 200 being the most stringent. The prevention elements
hours of the program level 3 regulated stationary
• Health Services Communications Office or sources under the federal Accidental Release
the Accidental Release Prevention Engineers Prevention Program is identical to the Process
prepare material for presentations and public Safety Management Program. The main differences
meetings – total approximately 80 personnel between the federal Accidental Release Prevention
hours. and the CalARP Programs are as follows:
• Working with Public Health Division 1. The number of chemicals regulated
to prepare meetings and material for 2. The threshold quantity of these chemicals
the Spanish-speaking communities – 40 3. An external events analysis, including
personnel hours seismic and security and vulnerability
• Total of 1,510 hours is the approximate analysis, is required
personnel time spent on the Industrial Safety 4. Additional information in the Risk
Ordinance. Management Plan
This does not include the ombudsman time spent 5. Health Services is required to audit and
helping prepare for the public meetings, working inspect stationary sources at least once every
with the engineers on questions arising from three years
the Industrial Safety Ordinance, and answering 6. The interaction required between the
questions from the public on the Industrial Safety stationary source and Health Services
Ordinance. The differences between the CalARP and the
Industrial Safety Ordinance 2010 Report 19
Industrial Safety Ordinance Safety Programs are as done to compare to the number of OSHA process
follows: safety management audits. Carolyn W. Merritt,
• Stationary sources are required to include the Chemical Safety and Hazard Investigation
a root cause analysis with the incident Board Chair, at that time, also recognized Contra
investigations for Major Chemical Accidents Costa County in testimony to the House of
or Releases Representatives Committee on Education and Labor
• The stationary sources are required to chaired by Representative George Miller. Senator
consider inherently safer practices Barbara Boxer, during a hearing to consider John
• All of the processes at the regulated Bresland’s nomination to the Chemical Safety and
stationary source are covered Hazard Investigation Board as the Chair (replacing
• Managing changes in the organization for Carolyn Merritt), asked Mr. Bresland about the
operations, maintenance and emergency Contra Costa County program for process safety
response audits of refineries and chemical companies. The
• The implementation of a Human Factors Chemical Safety and Hazard Investigation Board
Programs also mentions Contra Costa County in a DVDs
“Anatomy of a Disaster: Explosion at BP Texas City
The Accidental Release Prevention Engineers have Refinery” and “Fire in the Valley” on the resources
participated with the Center for Chemical Process given to audit and ensure facilities are complying
Safety on developing the second edition of the with the regulations.
“Inherently Safer Chemical Processes” book that
is referenced in the ordinance and with the Center Contra Costa Hazardous Materials Programs was
for Chemical Process Safety on developing process asked to give testimony at the hearing on "Work
safety metrics for leading and lagging indicators. Place Safety and Worker Protections in the Gas and
Oil Industry" before the U.S. Senate Committee
All of these requirements will lower and have on Health, Education, Labor, and Pensions
lowered the probability of an accident occurring. Subcommittee on Employment and Workplace
Contra Costa County has been recognized in the Safety. The testimony was on the success of the
Chemical Safety and Hazard Investigation Board Accidental Release Prevention Programs that are
Reports on the BP March 23, 2005 Texas City and in place in Contra Costa County. The hearing
the Bayer Crop Science, Institute, West Virginia was specific on two major incidents that occurred
August 28, 2008 Investigations as an alternative in Anacortes, Washington at a Tesoro Refinery
model for doing process safety inspections. The and the Deepwater Horizon incident in the Gulf
report states: “Contra Costa County and the U.K. of Mexico. A link to the testimony is posted on
Health and Safety Executive conduct frequent the Health Services website and can be found by
scheduled inspections of PSM and major hazard using the following link: http://help.senate.gov/
facilities with highly qualified staff.” This was hearings/hearing/?id=fe34048f-5056-9502-5d69-
2609a5d5501a .
Industrial Safety Ordinance 2010 Report 20
Attachment A 4. Continuing an outreach strategy so that the
people who live and work in Contra Costa
Hazardous Materials County can know about and utilize the
Ombudsman Report program.
Hazardous Materials Ombudsman Evaluation 5. Investigating and responding to questions
October 2009 through September 2010 and complaints, and assisting people in
gathering information about programs,
I. Introduction procedures or issues.
On July 15, 1997 the Contra Costa County Board
6. Participating in a network of environmental
of Supervisors authorized the creation of an
programs for the purpose of providing
Ombudsman position for the County’s Hazardous
technical assistance.
Materials Programs. The first Hazardous Materials
Ombudsman began work on May 1, 1998. The
This evaluation covers the period from October
Contra Costa County Board of Supervisors adopted
2009 through September 2010 for the Hazardous
an Industrial Safety Ordinance on December 15,
Materials Ombudsman program. The effectiveness
1998. Section 450-8.022 of the Industrial Safety
of the program shall be demonstrated by showing
Ordinance requires the Health Services Department
that the activities of the Hazardous Materials
to continue to employ an Ombudsman for the
Ombudsman meet the goals established in the
Hazardous Materials Programs. Section 450-
Industrial Safety Ordinance.
8.030(B)(vii) of the Industrial Safety Ordinance
requires an annual evaluation of the effectiveness of
II. Program Elements
the Hazardous Materials Ombudsman, with the first
evaluation to be completed on or before October 31,
1. Continuing an Outreach Strategy
2000.
This period, efforts were focused on maintaining
The goals of section 450-8.022 of the Industrial
the outreach tools currently available. Copies of the
Safety Ordinance for the Hazardous Materials
Ombudsman Brochure were translated into Spanish
Ombudsman are:
and were distributed to the public at meetings,
presentations, public events and through the mail.
1. To serve as a single point of contact for
A contact person was also established in Public
people who live or work in Contra Costa
Health that could receive calls from the public in
County regarding environmental health
Spanish and serve as an interpreter to respond to
concerns, and questions and complaints
these calls. In addition to explaining the services
about the Hazardous Materials Programs.
provided by the position, the brochure also provides
the phone numbers of several other related County
2. To investigate concerns and complaints,
and State programs. The web page was maintained
facilitate their resolution, and assist people
for the program as part of the Contra Costa Health
in gathering information about programs,
Services website. This page contains information
procedures, or issues.
about the program, links to other related websites,
and information about upcoming meetings and
3. To provide technical assistance to the public.
events. A toll-free phone number is published in
all three Contra Costa County phone books in the
The Hazardous Materials Ombudsman currently
Government section.
accomplishes these goals through the following
2. Investigating and Responding to Questions
program elements:
and Complaints, and Assisting in
Information Gathering
Industrial Safety Ordinance 2010 Report 21
During this period, the Hazardous Materials participants and the public.
Ombudsman received 171 information requests. • CAER (Community Awareness and
More than 95 percent of these requests occurred Emergency Response) —This nonprofit
via the telephone, and have been requests for organization addresses industrial accident
information about environmental issues. Requests prevention, response and communication.
via e-mail are slowly increasing, mainly through The Ombudsman participated in the
referrals from Health Services main web page. Emergency Notification subcommittee of
Most of these requests concern problems around CAER.
the home such as asbestos removal, household • Hazardous Materials Commission —In 2001,
hazardous waste disposal, pesticide misuse and lead the Ombudsman took over as staff for the
contamination. commission. As staff to the commission, the
Ombudsman conducts research, prepares
Information requests about environmental issues reports, writes letters and provides support
received via the telephone were generally responded for three monthly Commission meetings.
to within one business day of being received. Many During this period, the Ombudsman
of the information requests were answered during completed writing reports on Household
the initial call. Some requests required the collection Hazardous Waste and Brownfields for the
of information or written materials that often took Commission.
several days to compile. Telephone requests were • Public and Environmental Health Advisory
responded to by telephone unless written materials Board —As staff to the Environmental Health
needed to be sent as part of the response. subcommittee of PEHAB, the Ombudsman
keeps the committee informed on issues
they are interested in such as refinery flaring,
Complaints about the Hazardous Materials contaminated fish consumption, climate
Programs can also be received via telephone change and Integrated Pest Management.
and in writing. Persons that make complaints • Integrated Pest Management Advisory
via telephone are also asked to provide those Committee —During this period the
complaints in writing. During this period, the Ombudsman represented Health Services
Hazardous Materials Ombudsman did not receive on, and was elected to be chairperson
any complaints about the Hazardous Materials of, the newly created County Integrated
Programs. Pest Management Advisory Committee.
This Committee brings department
In September, the Ombudsman facilitated a representatives and members of the public
workshop for business owners concerning their new together to help implement the County’s
permit fee structure. Integrated Pest Management policy.
• Asthma Program —The Ombudsman
3. Participating in a Network of participated in the Public Health
Environmental Programs for the Purpose Division’s Asthma Program as a resource
of Providing Technical Assistance. on environmental health issues. The
Ombudsman also participated in countywide
Technical assistance means helping the public asthma coalition meetings, and represented
understand the regulatory, scientific, political and the Asthma Program at regional meetings
legal aspects of issues. It also means helping them pertaining to asthma issues, particularly
understand how to effectively communicate their diesel pollution. The Ombudsman gave
concerns within these different arenas. This year, presentations to nine high school classes on
the Ombudsman continued to staff a number of asthma and air pollution. The Ombudsman
County programs and participate in other programs has also begun to provide technical support
to be able to provide technical assistance to the for efforts to address the impacts of climate
Industrial Safety Ordinance 2010 Report 22
change on sensitive populations, and exposure to toxic chemicals. As part of this
efforts to improve health outcomes through effort, the Ombudsman organized two local
improvements to the built environment. workshops to gather input from the public
• East County Environmental Justice on these issues.
Collaborative —During this period the
Ombudsman provided technical assistance The Hazardous Materials Ombudsman also attended
to the East County Environmental Justice workshops, presentations, meetings and trainings
Collaborative, a Public Health Division on a variety of environmental issues to be better able
project in Bay Point and Pittsburg. This to provide technical assistance to the public. Topics
project was funded by grants from the included Environmental Justice, Cumulative impacts
Federal EPA and the San Francisco assessment, emergency management practices,
Foundation that the Ombudsman helped health mitigations for consumption of contaminated
secure. The Ombudsman helped develop fish, community-based participatory research and
research materials and gave presentations land-use planning for greenhouse gas reduction.
to residents as part of this project. The
Ombudsman also talked to teachers, III. Program management
principals and parents in the Pittsburg
Unified School District to encourage them to The Hazardous Material Ombudsman continued
participate in the environmental education to report to the Public Health Director on a day-
programs offered by the Contra Costa Water to-day basis during this period, while still handling
District. complaints and recommendations about the
• Bay Area Air Quality Management District’s Hazardous Materials Programs through the Health
Community Air Risk Evaluation Program — Services Director. The Ombudsman also was a
During this period the Ombudsman member of Health Services Emergency Management
represented the Public Health Division Team and participates on its HEEP management
on the advisory board to this Air District team. The Ombudsman also assisted the Asthma
program. This advisory board meets program in the writing of grants to fund ongoing
quarterly to discuss implementation of this programs.
program that identifies and creates strategies
to address health risks in communities with IV. Goals for the 2010/11 period
high air pollution emissions in the Bay
Area. Two of these areas are in Contra Costa In this period, the Ombudsman will provide
County. essentially the same services to Contra Costa
• Richmond General Plan Health Element — residents as was provided in the last period. The
During this period the Ombudsman Ombudsman will continue respond to questions
provided technical assistance to the City of and complaints about the actions of the Hazardous
Richmond as part of an effort to evaluate Materials Programs; answer general questions
the effectiveness of the implementation of that come from the public and assist them in
the new Health Element of their updated understanding regulatory programs; staff the
General Plan. Hazardous Materials Commission and the Public
• National Conversation on Public Health and and Environmental Health Advisory Board;
Chemical Exposure — provide technical support to the Asthma program,
During this period the Ombudsman and represent it on the Ditching Dirty Diesel
represented the Public Health Division in Collaborative and the East County Environmental
this yearlong nation-wide effort organized Justice collaborative; chair the Integrated Pest
by the federal Environmental Protection Management Advisory Committee, and participate
Agency and Centers for Disease Control to on the CAER Emergency Notification committee,
create an agenda for reducing the public’s the Air District CARE Advisory Board and the
Industrial Safety Ordinance 2010 Report 23
Richmond Health Element Implementation Group.
During this period the Ombudsman will help the
Hazardous Materials Commission research and
develop policy recommendations on the following
issues:
• Pipeline Safety
• Industrial Safety and the Industrial Safety
Ordinance
• Nanotechnology
• Environmental and health impacts of
pharmaceutical wastes
Industrial Safety Ordinance 2010 Report 24
Attachment B CCHS Office, 4585 Pacheco Boulevard and
the Richmond Library.
Regulated Sources 6. Provide any additions to the annual accident
Annual Performance history reports (i.e. updates) submitted
with Accident History pursuant to Section 450-8.016(E)(2) of
and Inherent Safety County Ordinance 98-48 (450-8.030(B)(2)
Implementation (iii)) (i.e., provide information identified
in Section 450-8.016(E)(1) for all major
chemical accidents or releases occurring
Annual Performance Review between the last annual performance review
and Evaluation Submittal report and the current annual performance
review and evaluation submittal (12-month
June 30, 2010 history)):
*
Attach additional pages as necessary City Ordinance 42-01 §6.43.090(e)(2),
§6.43.160(b)(3), and (§6.43.090(e)(1). The
1. Name and address of Stationary Source: September 2009 Site Safety Plan includes
Chevron Richmond Refinery, 841 Chevron required updates to the accident history
Way, Richmond, California 94802 section.
7. Summary of each Root Cause Analysis
2. Contact name and telephone number (Section 450-8.016(C)) including the
(should CCHS have questions): status of the analysis and the status of
Karen Draper , 510-242-1547 implementation of recommendations
formulated during the analysis (450-8.030(B)
(2)(iv)):
3. Summarize the status of the Stationary City Ordinance 42-01 §6.43.090(c),
Source’s Safety Plan and Program (450- and 42-01 §6.43.160(b)(4): There have
8.030(B)(2)(i)): been no Major Chemical Accidents or
City Ordinance 42-016.43.160 (B)(1): Releases(MCAR) or Near Miss incidents
The September 2009 Safety Plan reflects requiring investigations during this reporting
the current program elements within the period.
Refinery.
8. Summary of the status of implementation
4. Summarize Safety Plan updates (i.e., brief of recommendations formulated during
explanation of update and corresponding audits, inspections, Root Cause Analyses,
date) (450-8.030(B)(2)(ii)): or Incident Investigations conducted by the
City Ordinance 42-01 §6.43.160(b)(2): The Department (450-8.030(B)(2)(v)):
September 2009 Safety Plan update has not City Ordinance 42-01 §6.43.160(b)(5): There
yet completed the public notice process. were no audits or unannounced inspections
during this 12 month period.
5. List of locations where Safety Plans are/will
be available for review, including contact 9. Summary of inherently safer systems
telephone numbers if the source will provide implemented by the source including but
individuals with copies of the document not limited to inventory reduction (i.e.,
(450-8.030(B)(2)(ii)): intensification) and substitution (450-
8.030(B)(2)(vi)):
Industrial Safety Ordinance 2010 Report 25
City Ordinance (42-01 §6.43.160(b)(6)):
The following table represents several of the
inherently safer solutions implemented in
the facility during this reporting period:
Strategy ISS Solution Employed
Minimize Demo of 4” dead leg on C-140’s 16” overhead line.
Minimize F-2201: Remove dead legs from firebox
Minimize 10 Tar Line removal of a dead leg and a set of flanges.
Minimize NG Purge to V-244 Piping Dead Leg Removal
Minimize T-200B—Remove Unused Dead leg Nozzles From Tank Shell
Minimize D-720 Bleach Loading Line Replacement and Removal of Dead Legs
Minimize Eliminate leaking dead leg to the 1686 manifold
Minimize C-1950 Bottoms Piping Dead Leg Removal (LNC and HNC 1 S/C Off Test Line)
Minimize DEMO PSV IX-10002 and Associated Dead legs
Minimize Removal of 150# steam supply line to E-350/351- no longer needed
Minimize Demolition of T-870 and associated injection equipment
Minimize Remove old MP-100 DWOP wash down pump.
Minimize Caustic Strength Change in V1431 from 6-10% wt down to 2-5% wt
Moderate K-1600 instrument upgrades, replace V-1605 with a Stainless lined vessel
Moderate Upgrade Mechanical Seal flush piping on P-1167
Moderate Upgrade Mechanical Seal flush piping on P-1168
Moderate P-1165A piping changes made to the lube oil skid for piping upgrades from CS to SS.
Moderate P-840 Mechanical seal upgrade
Moderate North Isomax Flare (V-281A) Molecular Seal Drain Line upgraded to schedule 160
Moderate N2 purge to V-1936, Replace temporary tubing with permanent hard pipe.
Moderate P-102/A/103 Seal Flush Piping Compliance Upgrade.
Moderate P-155, upgrade needed flanges/valves to AF1 Pipe Class
Moderate R-410/411 and R-420/421 Inter Reactor H2 Quench Injection Point Upgrade
Moderate Relining of C-2260 using Derakane 8084 as an upgrade to the existing Derakane 411-45
Moderate E-150A/B/C/D Piping Spools, Valves, & Flanges upgraded to RF from T&G.
Moderate Upgrade elbow on E-1820 run-down in to V-1820 to Hastelloy C276
Moderate Replace V-1000 & E-1000 & piping w/upgraded metallurgy
Moderate V-910—Upgrade Level Instrumentation Piping
Moderate E-3580A & B -upgraded to duplex stainless steel (2507) and the outlet piping upgraded to
Moderate R-410/R-411 quench pipe union upgrade to Grayloc connectors
Moderate E-440: Replace the 1” Drain Valve (347SS) with New Inconel 825 Drain Valve
Moderate P-246A Mechanical seal flush plan upgrade
Moderate P-133 Upgrade existing Pump seals and flush supply
Moderate P-481A upgrade existing Flowserve seal to a John Crane Type 319ST
Moderate P-254, P-260, Seal upgrades from existing Flowserve to John Crane.
Industrial Safety Ordinance 2010 Report 26
Strategy ISS Solution Employed
Moderate P-261, upgrade existing Flowserve mechanical seal to a John Crane Seal
Moderate P-133 upgrade outboard seal
Moderate P-3159 seal upgrade from Flowserve to John Crane type 561OQ single cartridge
Moderate 4Rhen—Upgrade 5 Bleeders and One Root Valve to Monel Trim
Moderate V-3217 / Replace corroded CS BFW Chemical piping with socket-welded stainless, class
GB1.
Moderate Replace 3” reflux nozzle (N21) on C-1820 with upgraded Hastelloy C liner
Moderate EOD Fire Water Line - 12”—SRU along Hill St. - Replace CS with Cement lined pipe.
Moderate Retube E-1905B seal oil cooler from CS to 70/30 CuNi alloy
Moderate E-1850: Coat channel & install anodes
Moderate Replace C.S. section of V-450 outlet piping from vessel nozzle to LV-4511 & LV-4512 with
Moderate Replace SS injection quills. Changing metallurgy on quills and some of the piping to
Hastelloy
Moderate F-2202 and F-2203 Burner Ring Replacement with 310 SS instead of 316 SS
Moderate 637 Line Relief Line PSV Installation
Moderate TKN-5 - E-551C/D—Tube Bundle Replacement upgraded to Incoloy 825
Simplify IX-808 upgrade to a balanced piston type PRD
Simplify V-325 Gage Glass Bridle Piping Repair, Flanges are being changed from T&G to raised face
Simplify V-501A,B,C replacement to coated code vessels with an MAWP of 250psig
Simplify V-601A,B,C replacement to coated code vessels with an MAWP of 250psig
Simplify E-803B Channel Chemical Cleaning Nozzle Flange Alteration upgraded to a 300# flange
Simplify C-730 Sample Piping Upgrade to solid piping
Simplify E-150A/B/C/D Piping Spools, Valves, & Flanges upgraded to RF from T&G.
Simplify Valve IX-10003 upgrade flange stg (small tongue and groove) to rf (raised face)
Simplify E-130A-F Flange & Gasket Upgrade
Simplify Avgas Marketing—new filters have a through bolt design as opposed the existing swing bolt
Simplify LT237 on V-1824 to relief - replace the 3/4” vent line with an upgraded 2” line.
Simplify V-3580—Replace V-3580 Outlet Piping from STANDARD to XS
Simplify 7-GRU—Replace FC-790 threaded/union style to flanged style
Simplify Retire PSV FC-211 and Replace with Piping
Simplify E-1030 Anode Attachment and Channel Coating
Simplify Changing union connections to Grey Loc Fittings for R-420 & R-421
Simplify Install New PRD to Protect V-910
Industrial Safety Ordinance 2010 Report 27
10. Summarize the enforcement actions 14. Copies of any comments received by the
(including Notice of Deficiencies, Audit source (that may not have been received by
Reports, and any actions turned over to the the Department) regarding the effectiveness
Contra Costa County District Attorney’s of the local program that raise public safety
Office) taken with the Stationary Source issues(450-8.030(B)(6)):
pursuant to Section 450-8.028 of County There have been no comments received in
Ordinance 98-48 (450-8.030(B)(2)(vii)): this period.
There were no enforcement actions during
this period.
15. Summarize how this Chapter improves
industrial safety at your stationary source
11. Summarize total penalties assessed as a (450-8.030(B)(7)):
result of enforcement of this Chapter (450- The Richmond Refinery has fully
8.030(3)): implemented and maintains the City of
No penalities have been assessed against this Richmond’s Industrial safety Ordinance
facility as a result of this Chapter. program . Chevron is fully committed
to achieving a incident and injury free
operation, and the minimization of potential
12. Summarize the total fees, service charges, risk to the community and environment.
and other assessments collected specifically
for the support of the ISO (450-8.030(B)(4)): 16. List examples of changes made at your
The total CalARP Program fees for these stationary source due to implementation
nine facilities was $595,000. The total of of the Industrial Safety Ordinance (e.g.,
the County and the City of the Richmond recommendations from PHA’s, Compliance
Industrial Safety Ordinance fees for these Audits, and Incident Investigations in
nine facilities was - $304,000. units not subject to CalARP regulations;
recommendations from RCA’s) that
significantly decrease the severity or
13. Summarize total personnel and personnel likelihood of accidental releases
years utilized by the jurisdiction to directly Refer to the ISS Solutions implemented.
implement or administer this Chapter (450- (Noted in question #9)
8.030(B)(5)):
4400 hours were used to audit/inspect and 17. Summarize the emergency response activities
issue reports on the Risk Management conducted at the source (e.g., CWS or TEN
Chapter of the Industrial Safety Ordinance. activation) in response to major chemical
accidents or releases:
During this period, there were no activations
of the CWS or TEN systems in response to
an MCAR event.
Industrial Safety Ordinance 2010 Report 28
Annual Performance Review in §6.43.090(e)(1) for all major chemical
accidents or releases occurring between the
and Evaluation Submittal last annual performance review report and
the current annual performance review and
June 30, 2010 evaluation submittal (12 month history)):
*Attach additional pages as necessary None.
1. Name and address of Stationary Source:
General Chemical West, 525 Castro Street, 7. Summary of each Root Cause Analysis
Richmond, California 94801 §6.43.090(c) including the status of the
analysis and the status of implementation
of recommendations formulated during the
2. Contact name and telephone number analysis §6.43.160(b)(4):
(should CCHS have questions): None
Kevin O’Kelley 510-237-3869
8. Summary of the status of implementation
3. Summarize the status of the Stationary of recommendations formulated during
Source’s Safety Plan and Program (42-01 audits, inspections, Root Cause Analyses,
§6.43.160(b)(1)): or Incident Investigations conducted by the
The Safety Plan was updated in 2009. Review Department §6.43.160(b)(5):
by CCHS resulted in a revision, which was The CCHS audit of January, 2009 resulted
accepted in May, 2010. in 64 action items. 9 items remain
uncompleted.
4. Summarize Safety Plan updates (i.e., brief
explanation of update and corresponding
date) (42-01 §6.43.160(b)(2)): 9. Summary of inherently safer systems
The Safety Plan was resubmitted, and implemented by the source including but
reviewed. Modifications were completed in not limited to inventory reduction (i.e.,
May, 2010. intensification) and substitution §6.43.160(b)
(6):
1. Simplification of Absorption Tower piping;
5. List of locations where Safety Plans are/will 2. Reduciton of pressure in Superheater; 3.
be available for review, including contact New design of neutralization system will
telephone numbers if the source will provide reduce the volume of wastewater treated;
individuals with copies of the document (42- 4. Simplification of molten sulfur piping; 5.
01 §6.43.160(b)(2)): Installation of interlock on booster pump; 6.
4585 Pacheco Blvd., Martinez, and in Reduce concentration of hydrogen peroxide
the Richmond public library. from 35% to 25%.
10. Summarize the enforcement actions
(including Notice of Deficiencies, Audit
6. Provide any additions to the annual Reports, and any actions turned over to
accident history reports (i.e. updates) the City Attorney’s Office) taken with
submitted pursuant to §6.43.090(e)(2) the Stationary Source pursuant to City
of City Ordinance 42-01 (§6.43.160(b) Ordinance 42-01 §6.43.160(b)(7):
(3) (i.e., provide information identified The 2009 audit report has not yet completed
Industrial Safety Ordinance 2010 Report 29
the public notice process. The NOD for the 16. List examples of changes made at your
Safety Plan is being addressed by the Safety stationary source due to implementation
Plan being modified. of the Industrial Safety Ordinance (e.g.,
recommendations from PHA’s, Compliance
Audits, and Incident Investigations in
11. Summarize total penalties assessed as a result units not subject to CalARP regulations;
of enforcement of this Chapter §6.43.160(c): recommendations from RCA’s) that
No penalities have been assessed against this significantly decrease the severity or
facility. likelihood of accidental releases:
Numerous changes have been made due
to recommendations from PHA’s, audits,
12. Summarize the total fees, service charges, etc. Some examples include revision of
and other assessments collected specifically procedures, improved employee training,
for the support of the ISO §6.43.160(d): and improved management of change
The total CalARP Program fees for the nine documentation.
facilities was $595,000. The total the County
and the City of the Richmond Industrial
Safety Ordinance fees for the nine facilities 17. Summarize the emergency response activities
was - $304,000. conducted at the source (e.g., CWS or TEN
activation) in response to major chemical
accidents or releases:
13. Summarize total personnel and personnel None
years utilized by the jurisdiction to directly
implement or administer this Chapter
§6.43.160(e):
4400 hours were used to audit/inspect and
issue reports on the Risk Management
Chapter of the Industrial Safety Ordinance.
14. Copies of any comments received by the
source (that may not have been received by
the Department) regarding the effectiveness
of the local program that raise public safety
issues§6.43.160(f):
None
15. Summarize how this Chapter improves
industrial safety at your stationary source
§6.43.160(g):
This Chapter helps minimize potential risk
and exposure to employees, the community,
and the environment.
Industrial Safety Ordinance 2010 Report 30
