Industrial Safety Ordinance 2010 Report 1

City of 

Richmond

Annual 

Performance 

Review & 

Evaluation 

Report

July 26, 2011

By Contra Costa Health Services Hazardous Materials Programs
Industrial Safety Ordinance 2010 Report 2

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

3

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 4

Education, Labor, and Pensions Subcommittee 

on Employment and Workplace Safety. The 

testimony was on the success of the Accidental 

Release Prevention Programs that are in place in 

Contra Costa County. The hearing was specific on 

two major incidents that occurred in Anacortes, 

Washington at a Tesoro Refinery and the Deepwater 

Horizon incident in the Gulf of Mexico.

Public Participation

The Hazardous Materials Programs has an 

established public outreach process and is 

constantly looking at ways for improvement. The 

following items have been implemented based on 

recommendations from interested stakeholders and 

the actions taken this year:

• Public outreach information booths at 

existing venues

» General Chemical Richmond Safety 

Plan and preliminary audit findings 

and Chevron Richmond Refinery Safety 

Plan were shared at the West County 

Emergency Preparedness Fair at Hilltop 

Mall in Richmond in September 2010.

• Most recent audit findings summarized 

in easily read format in both English and 

Spanish

• Information on regulated businesses in an 

easily read format in English and Spanish

• Industrial Safety Ordinance Information 

Sheet in English and Spanish

Audits

Audits of the regulated businesses are required 

at least once every three years to ensure that the 

facilities have the required programs in place and 

are implementing the programs. We did not perform 

audits in City of Richmond in 2010.

Major Chemical Accidents or 

Releases

Another measure of the effectiveness of the 

Industrial Safety Ordinance is by the number and 

severity of Major Chemical Accidents or Releases 

that have occurred. In the last year there were 

four Major Chemical Accidents or Releases with 

a severity Type I that resulted in a minor injury 

and impact to the community but none of these 

occurred from the two Richmond facilities. 

Conclusion

The number and severity of Major Chemical 

Accidents or Releases have been in a generally 

declining trend since the implementation of 

Industrial Safety Ordinance. The implementation 

of the Industrial Safety Ordinance has improved 

and, in most cases, is being done as required by 

the ordinance. It is believed that by continuing 

implementation of the Industrial Safety Ordinance 

and strengthening the requirements of the 

Ordinance the possibility of accidents that could 

impact the community has decreased.
Industrial Safety Ordinance 2010 Report 5

Introduction

The City of Richmond adopted the Industrial Safety 

Ordinance after the Contra Costa County Board 

of Supervisors passed the County Industrial Safety 

Ordinance because of accidents that occurred 

at oil refineries and chemical plants in Contra 

Costa County. The effective date of the Richmond 

Industrial Safety Ordinance was January 7, 2002. 

The ordinance applies to oil refineries and chemical 

plants with specified North American Industry 

Classification System (NAICS) codes that were 

required to submit a Risk Management Plan to the 

U.S. EPA and are program level 3 stationary sources 

as defined by the California Accidental Release 

Prevention (CalARP) Program. The ordinance 

specifies the following:

• Stationary sources must submit a Safety Plan 

to Contra Costa Health Services stating how 

the stationary source is complying with the 

ordinance, including the Human Factors 

program.

• Stationary sources must comply with the 

requirements of the Human Factor Guidance 

Document that was developed by Contra 

Costa Health Services and was adopted by 

reference. 

• For Major Chemical Accidents or Releases, 

stationary sources are required to perform a 

root cause analysis as part of their incident 

investigations (ongoing)

• Contra Costa Health Services may perform 

its own incident investigation, including a 

root cause analysis (ongoing)

• All of the processes at the stationary source 

are covered as program level 3 processes as 

defined by the California Accidental Release 

Prevention Program

• The stationary sources are required to 

consider Inherently Safer Systems for new 

processes or facilities or for mitigations 

resulting from a process hazard analysis

• Contra Costa Health Services will review 

all of the submitted Safety Plans and audit/

inspect all of the stationary sources’ Safety 

Programs within one year of the receipt of 

the Safety Plans and every three years after 

the initial audit/inspection (ongoing)

• Contra Costa Health Services will give an 

annual performance review and evaluation 

report to the City Council.

Annual Performance Review 

and Evaluation Report

The Industrial Safety Ordinance specifies that the 

contents of the annual performance review and 

evaluation report contain the following:

• A brief description of how Health Services is 

meeting the requirements of the ordinance as 

follows:

» Effectiveness of the department’s 

program to ensure stationary sources’ 

compliance with the ordinance

» Effectiveness of the procedures for 

records management

» Number and type of audits and 

inspections conducted by Health 

Services as required by the ordinance

» Number of root cause analyses and/or 

incident investigations conducted by 

Health Services

» Health Services’ process for public 

participation

» Effectiveness of the Public Information 

Bank

» Effectiveness of the Hazardous Materials 

Ombudsperson

» Other required program elements 

necessary to implement and manage the 

ordinance

• A listing of stationary sources covered by the 

ordinance, including for each:

» The status of the stationary source’s 

Safety Plan and Program

» A summary of all stationary sources’ 

Safety Plan updates and a listing of where 

the Safety Plans are publicly available

» The annual accident history report 

submitted by the regulated stationary 

sources and required by the ordinance

» A summary, including the status, of 

any root cause analyses and incident 

investigations conducted or being 

conducted by the stationary sources and 
Industrial Safety Ordinance 2010 Report 6

required by the ordinance, including 

the status of implementation of 

recommendations

» A summary, including the status, of any 

audits, inspections, root cause analyses 

and/or incident investigations conducted 

by Health Services, including the status 

for implementing the recommendations

» Description of inherently safer systems 

implemented by the regulated stationary 

source

» Legal enforcement actions initiated 

by Health Services, including 

administrative, civil and criminal actions

• Total penalties assessed as a result of 

enforcement of the ordinance

• Total fees, service charges and other 

assessments collected specifically for the 

support of the ordinance

• Total personnel and personnel years used 

by the jurisdiction to directly implement or 

administer the ordinance

• Comments from interested parties regarding 

the effectiveness of the local program that 

raise public safety issues

• The impact of the ordinance in improving 

industrial safety

Effectiveness of Contra 

Costa Health Services’ 

Implementation of the 

Industrial Safety Ordinance

Health Services has developed policies, procedures, 

protocols and questionnaires to implement both the 

California Accidental Release Prevention Program 

and the Industrial Safety Ordinance. The policies, 

procedures, protocols and questionnaires for these 

programs are listed below:

• Audits/Inspections Policy

• Conducting the Risk Management Plan/

Safety Plan Completeness Review Protocol

• Risk Management Plan Completeness 

Review Questionnaires

• Safety Plan Completeness Review 

Questionnaires 

• Conducting Audits/Inspections Protocol

• Safe Work Practices Questionnaires

• CalARP Program Audit Questionnaires

• Safety Program Audit Questionnaires

• Conducting Employee Interviews Protocol

• Employee Interview Questionnaires

• Public Participation Policy

• Dispute Resolution Policy

• Reclassification Policy

• Covered Process Modification Policy

• CalARP Internal Performance Audit Policy

• Conducting the Internal Performance Audit

• CalARP Internal Audit Performance Audit 

Submission

• Fee Policy

• Notification Policy

• Unannounced Inspection Policy

• Risk Management Plan Public Review Policy

Health Services has developed the Contra Costa 

County CalARP Program Guidance Document 

and the Contra Costa County Safety Program 

Guidance Document including the Safety Culture 

Assessment, which at this time is not required by 

the Richmond Industrial Safety Ordinance. An 

updated draft Contra Costa County Safety Program 

Guidance Document was issued September 30, 

2010 to the regulated facilities. The updated draft 

incorporated updates from the ISO amendments 

(the City of Richmond has not approved these 

amendments) and additional clarifications from all 

the audits, these documents give guidance to the 

stationary sources for complying with the Industrial 

Safety Ordinance. The policies, procedures, 

protocols and questionnaires, are available through 

Health Services. The guidance documents can be 

downloaded through Health Services’ website: 

www.cchealth.org/groups/hazmat/california_

accidental_release_prevention_guidance_

document.php and www.cchealth.org/groups/

hazmat/industrial_safety_ordinance_guidance.php 

Effectiveness of the Procedures 

for Records Management

Health Services has set up hard copy and computer 

files for each of the stationary sources. The files 

include the following folders:

1. Annual Status Reports
Industrial Safety Ordinance 2010 Report 7

2. Audits & Inspections

3. Communications

4. Completeness Review

5. Emergency Response

6. Incident Investigation

7. Trade Secret Information

The paper files for the stationary sources are kept 

in a central location. The Accidental Release 

Prevention Programs staff has files set up on the 

Health Services network where the files for each 

of the different stationary sources are found and 

are accessible to each of the Accidental Release 

Prevention Programs Engineers, Supervisor and 

the Chief Environmental Health and HazMat 

Officer. Portable document format of these files is 

also available at the Hazardous Materials Programs 

office for public access and viewing. The Accidental 

Release Prevention Programs files also contain 

regulations, policies, information from the U.S.

EPA, California Emergergency Management Agency 

(CalEMA), the U.S. Chemical Safety and Hazards 

Investigation Board and other information pertinent 

to the engineers. The risk management and safety 

plans received are kept at the Hazardous Materials 

Program offices.

Number and Type of Audits and 

Inspections Conducted

Hazardous Materials Programs was required to audit 

and inspect the two regulated stationary sources 

that were required to comply with the Richmond’s 

Industrial Safety Ordinance (RISO) within one 

year after the initial submittal of their Safety 

Plans. Health Services reviewed all of the Safety 

Plans and audited/inspected all of the stationary 

sources’ Safety Programs within that year (2003). 

The public comment period for these plans ended 

in January 2004. Public meetings held in 2004 in 

North Richmond and Richmond discussed Chevron 

and General Chemical West Richmond Works 

audit findings. The second Richmond Industrial 

Safety Ordinance/CalARP Program audits for these 

facilities occurred in 2006 and public meetings 

were held in June 2007 at Hilltop Mall at “Lessons 

from Katrina,” the 2007 Neighbor Works Week 

Homeownership Faire & Disaster Preparedness 

Expo.

Chevron Richmond Refinery was audited for the 

third time for RISO/CalARP program in April 

2008 and the final report has been finalized and 

results were available at the Recycle More Earth Day 

Event in Richmond in June 2009. Health Services 

performed an RISO/CalARP program audit at 

General Chemical Richmond in January 2009. 

The final report was shared at a public event in 

Richmond in September 2010. Copies of these audit 

results are available at the Richmond Library and a 

summary of the audit is also available on Hazardous 

Materials Programs’ website. The fourth round of 

RISO audits began in Febuary 2011 with Chevron. 

When Hazardous Materials Programs reviews a 

Safety Plan, a Notice of Deficiencies is produced 

to document what changes to a stationary source 

is required to make before Hazardous Materials 

Program determines that the Safety Plan is 

complete. The stationary source has 60 to 90 days 

to respond to the Notice of Deficiencies. When the 

stationary source has responded to this Notice of 

Deficiencies, Hazardous Materials Programs will 

review the response. Hazardous Materials Programs 

will either determine that the Safety Plan is complete 

or will work with the stationary source until the 

Safety Plan contains the required information for it 

to be considered complete. When the Safety Plan is 

deemed complete, Hazardous Materials Programs 

will open a public comment period on the Safety 

Plan and will make available the plan in a public 

meeting or venue. Hazardous Materials Programs 

will respond to all written comments in writing and 

when appropriate use the comments in the audit/

inspection of the regulated stationary sources.

Hazardous Materials Programs will issue 

Preliminary Audit Findings after an audit/inspection 

is complete. The stationary source will have 90 

days to respond to these findings. Hazardous 

Materials Programs will review the response from 

the stationary source on the Preliminary Audit 

Findings. When the stationary source has developed 

an action plan to come into compliance with the 
Industrial Safety Ordinance 2010 Report 8

regulations, Hazardous Materials Programs will 

issue the Preliminary Audit Findings for public 

comment and will make available the findings in 

a public meeting or venue. Hazardous Materials 

Programs will consider any public comments that 

were received during the public comment period 

and if appropriate will revise the Preliminary 

Audit Findings. When this is complete, Hazardous 

Materials Programs will issue the Final Audit 

Findings and will respond in writing to any written 

public comments received. The status of the reviews 

and all audits are discussed in Table I within the 

report.

Number of Root Cause Analyses 

and/or Incident Investigations 

Conducted by Health Services

The Hazardous Materials Programs has not 

performed any root-cause analyses or incident 

investigations in the last year. A historical listing of 

the Major Chemical Accidents or Releases dating 

back to 1992 can be found on the Health Services 

website at the following address: www.cchealth.

org/groups/hazmat/accident_history.php. This list 

includes major accidents that occurred prior to the 

adoption of the Industrial Safety Ordinance.

Health Services’ Process for 

Public Participation 

In 2005, Hazardous Materials Programs worked with 

the community and developed materials that would 

describe the Industrial Safety Ordinance using a 

number of different approaches. The community 

representatives suggested that Hazardous Materials 

Programs look at existing venues that are attended 

by the public that the Hazardous Materials 

Programs’ staff can share and receive comments 

on Preliminary Audit Findings and the stationary 

sources’ Safety Plans. 

Effectiveness of the Public 

Information Bank

The Hazardous Materials Programs section of 

Health Services website www.cchealth.org/groups/

hazmat/ includes the following information:

• Industrial Safety Ordinance

» Description of covered facilities

» Risk Management Chapter discussion

– Copy of the ordinance

» Land Use Permit Chapter discussion

– Copy of the ordinance

» Safety Program Guidance Document

» Frequently Asked Questions

» Public Outreach strategies

• California Accidental Release Prevention 

(CalARP) Program

» Contra Costa County’s California 

Accidental Release Prevention Program 

Guidance Document

» Program Level description

» Discussion on Public Participation for 

both CalARP Program and the Industrial 

Safety Ordinance

» A map locating the facilities that are 

subject to the CalARP Program and are 

required to submit a Risk Management 

Plan to Health Services. The map links to 

a description of each of the facilities and 

the regulated substances handled.

• Hazardous Materials Inventories and 

Emergency Response Program

» Descriptions

» Forms

• Underground Storage Tanks

» Description of the program

» Copies of the Underground Storage 

Tanks Health & Safety Code sections

» Underground Storage Tanks forms

• Green Business Program

» 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 9

• Hazardous Materials Incident Response 

Team

» Including information of the Major 

Chemical Accidents or Releases that 

have occurred

» The County’s Hazardous Materials 

Incident Notification Policy

» A link to the ConocoPhillips Fenceline 

Monitors

• Hazardous Materials Program Incident 

Search

» Online search of the hazardous materials 

incident database for incidents that have 

occurred since 1993 by entering a date 

range, address, city and/or facility name

• Facility Search

» Online search of the facilities that 

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 10

TABLE I

INDUSTRIAL SAFETY ORDINANCE STATIONARY SOURCE STATUS

name safety plan 

(sp) received

notice of 

deficiencies 

(nod) 

issued-sp

safety plan 

complete

sp public 

meeting 

date

audit/ 

inspection

audit 

public 

meeting

Chevron 1/21/03 4/23/03 10/10/03 10/14/03 1/11/01

(Non-RISO)

6/24/04

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 

Chemical 

Richmond 

Works

1/17/03 4/11/03 10/10/03 10/14/03 5/29/01 

(Non-RISO)

6/24/04

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 11

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 12

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 13

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. 

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

TABLE II

LOCATION OF SAFETY PLANS - LIBRARIES
Industrial Safety Ordinance 2010 Report 14

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.

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)

TABLE III

INHERENTLY SAFER SYSTEMS
Industrial Safety Ordinance 2010 Report 15

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 16

Status of the Incident 

Investigations, Including the 

Root Cause Analyses Conducted 

by the Regulated Stationary 

Sources

The Industrial Safety Ordinance requires the 

regulated stationary sources to do an incident 

investigation with a root cause analysis for each of 

the major chemical accidents or releases as defined 

by the following: “Major Chemical Accident or 

Release means an incident that meets the definition 

of a Level 3 or Level 2 incident in the Community 

Warning System incident level classification system 

defined in the Hazardous Materials Incident 

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

• Causes on- or off-site property damage 

(including cleanup and restoration activities) 

initially estimated at $500,000 or more. 

On-site estimates shall be performed by the 

regulated stationary source. Off-site estimates 

shall be performed by appropriate agencies 

and compiled by Health Services

• Results in a vapor cloud of flammables or 

combustibles that is more than 5,000 pounds 

The regulated stationary source is required to submit 

a report to Hazardous materials programs 30 days 

after the root cause analysis is complete. There have 

been no major chemical accidents or releases by a 

Richmond Industrial Safety Ordinance regulated 

stationary source, since January 15, 2007. 
Industrial Safety Ordinance 2010 Report 17

Major Chemical Accidents or 

Releases

Hazardous Materials Programs has analyzed the 

Major Chemical Accidents or Releases (MCAR) 

that have occurred since the implementation of the 

Industrial Safety Ordinance. The analysis includes 

the number and severity of the MCARs. Three 

different levels of severity were assigned:

• Severity Level III – A fatality, serious injuries, 

or major onsite or offsite damage occurred

• Severity Level II – An impact to the 

community occurred, or if the situation was 

slightly different the accident may have been 

considered major, or there is a recurring type 

of incident at that facility

• Severity Level I – A release where there was 

no or minor injuries, the release had no or 

slight impact to the community, or there was 

no or minor onsite damage 

Below are charts showing the number of MCARs 

from January 1999 through September 2010 for 

all stationary sources in Contra Costa County, 

the MCARs that have occurred at the the City of 

Richmond’s Industrial Safety Ordinance stationary 

sources, and a chart showing the MCARs that have 

occurred at the County and the City of Richmond’s 

Industrial Safety Ordinance stationary sources. The 

charts also show the number of severity I, II and III 

MCARs for this period. There were four severity 

type I MCAR events from Tesoro and Conoco 

Phillips in October and November this year that are 

not shown on the graphs. NOTE: The charts do 

not include any transportation MCARs that have 

occurred.

A weighted score has been developed giving more 

weight to the higher severity incidents and a lower 

weight to the less severe incidents. The purpose is 

to develop a metric of the overall process safety of 

facilities in the County, the facilities that are covered 

by the County and the City of Richmond Industrial 

Safety Ordinances, and the facilities that are covered 

by the County’s Industrial Safety Ordinance. A 

Severity Level III incident is given nine points, 

Severity Level II three points, and Severity Level I 

one point. Below is a graph of this weighted scoring.

County and Richmond ISO MCARs

0

2

4

6

8

10

12

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Year

Total MCARs

Severity Level III

Severity Level II

Severity Level I

* 4 Severity I incidents at County ISO facilities in Oct, Nov 2010 not shown

Major Chemical Accidents and Releases

0

2

4

6

8

10

12

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Year

Number of MCAR's

Total MCARs

Severity Level III

Severity Level II

Severity Level I

* 4 Severity I incidents at County ISO facilities in Oct, Nov 2010 not shown
Industrial Safety Ordinance 2010 Report 18

Legal Enforcement Actions 

Initiated by Health Services

As part of the enforcement of the Industrial Safety 

Ordinance and the CalARP Program, Hazardous 

Materials Programs issues Notice of Deficiencies 

on the Safety and Risk Management Plans and 

issues Audit Findings on what a stationary source 

is required to change to come into compliance 

with the regulations. Table I shows the action that 

has been taken by Hazardous Materials Programs. 

Hazardous Materials Programs has not taken 

any action through the District Attorney’s Office 

for noncompliance with the requirements of the 

Industrial Safety Ordinance.

Penalties Assessed as 

a Result of Enforcement

No penalties have been assessed this year for 

noncompliance with the Industrial Safety Ordinance.

Total Fees, Service Charges, and 

Other Assessments Collected 

Specifically for the Industrial 

Safety Ordinance

The fees charged for the Industrial Safety 

Ordinance are to cover the time that the Accidental 

Release Prevention Engineers use to enforce the 

ordinance, the position of the Hazardous Materials 

Ombudsman, outreach material and to cover a 

portion of the overhead for the Hazardous Materials 

Programs. The fees charged for administering this 

the County’s and the City of Richmond’s Industrial 

Safety Ordinances for the fiscal year 2009–10 is 

$713,631.

Total Personnel and Personnel 

Years Used by Health Services to 

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 

Major Chemical Accidents and Releases 

Weighted Score

0

5

10

15

20

25

30

199920002001200220032004200520062007200820092010

Total MCARs

County &

Richmond ISO

County ISO

* 4 Severity I incidents at County ISO facilities in Oct, Nov 2010 not shown
Industrial Safety Ordinance 2010 Report 19

Ordinance and did follow-up work after a Major 

Chemical Accident or Release. The following is 

a breakdown of the time that was spent on the 

County’s and the City of Richmond’s Industrial 

Safety Ordinances:

• One ISO/CalARP Program facility audit 

was done between November 2009 and 

October 2010. It takes five engineers four 

weeks to perform an ISO/CalARP Program 

on-site portion of the audit. The audit 

process encompasses off-site time that 

includes a quality assurance process, working 

with the facility to address any questions, 

posting public notices, attending public 

forum to share audit findings, addressing 

any questions from the public, and issuing 

the final report. The total time taken to 

perform this audit in 2010 was 950 hours. 

Approximately one-third of the time was 

dedicated to the Industrial Safety Ordinance 

for a total of 316 hours.

• Developing Safety Culture Assessment 

Guidance and establishing Process Safety 

Measurement – 200 hours

• Reviewing information for the website – 40 

hours

• Reviewing Safety Plans and following up 

with the facilities on any deficiencies – 200 

hours

• Health Services Communications Office or 

the Accidental Release Prevention Engineers 

prepare material for presentations and public 

meetings – total approximately 80 personnel 

hours.

• Working with Public Health Division 

to prepare meetings and material for 

the Spanish-speaking communities – 40 

personnel hours

• Total of 1,510 hours is the approximate 

personnel time spent on the Industrial Safety 

Ordinance.

This does not include the ombudsman time spent 

helping prepare for the public meetings, working 

with the engineers on questions arising from 

the Industrial Safety Ordinance, and answering 

questions from the public on the Industrial Safety 

Ordinance.

Comments From Interested 

Parties Regarding the 

Effectiveness of the Industrial 

Safety Ordinance

No comments were received on the County’s or the 

City of Richmond’s Industrial Safety Ordinances 

during the last year. 

The Impact of the Industrial 

Safety Ordinance on Improving 

Industrial Safety

Four programs are in place to reduce the potential 

of an accidental release from a regulated stationary 

source that could impact the surrounding 

community. The four programs are the Process 

Safety Management Program administered 

by Cal/OSHA, the federal Accidental Release 

Prevention Program administered by the U.S. 

EPA, the California Accidental Release Prevention 

Program administered locally by Hazardous 

Materials Programs, and the Industrial Safety 

Ordinance administered by Hazardous Materials 

Programs. Each of the programs is very similar in 

requirements, with the Industrial Safety Ordinance 

being the most stringent. The prevention elements 

of the program level 3 regulated stationary 

sources under the federal Accidental Release 

Prevention Program is identical to the Process 

Safety Management Program. The main differences 

between the federal Accidental Release Prevention 

and the CalARP Programs are as follows:

1. The number of chemicals regulated

2. The threshold quantity of these chemicals

3. An external events analysis, including 

seismic and security and vulnerability 

analysis, is required

4. Additional information in the Risk 

Management Plan

5. Health Services is required to audit and 

inspect stationary sources at least once every 

three years

6. The interaction required between the 

stationary source and Health Services

The differences between the CalARP and the 
Industrial Safety Ordinance 2010 Report 20

Industrial Safety Ordinance Safety Programs are as 

follows:

• Stationary sources are required to include 

a root cause analysis with the incident 

investigations for Major Chemical Accidents 

or Releases

• The stationary sources are required to 

consider inherently safer practices

• All of the processes at the regulated 

stationary source are covered 

• Managing changes in the organization for 

operations, maintenance and emergency 

response

• The implementation of a Human Factors 

Programs

The Accidental Release Prevention Engineers have 

participated with the Center for Chemical Process 

Safety on developing the second edition of the 

“Inherently Safer Chemical Processes” book that 

is referenced in the ordinance and with the Center 

for Chemical Process Safety on developing process 

safety metrics for leading and lagging indicators.

All of these requirements will lower and have 

lowered the probability of an accident occurring. 

Contra Costa County has been recognized in the 

Chemical Safety and Hazard Investigation Board 

Reports on the BP March 23, 2005 Texas City and 

the Bayer Crop Science, Institute, West Virginia 

August 28, 2008 Investigations as an alternative 

model for doing process safety inspections. The 

report states: “Contra Costa County and the U.K. 

Health and Safety Executive conduct frequent 

scheduled inspections of PSM and major hazard 

facilities with highly qualified staff.” This was 

done to compare to the number of OSHA process 

safety management audits. Carolyn W. Merritt, 

the Chemical Safety and Hazard Investigation 

Board Chair, at that time, also recognized Contra 

Costa County in testimony to the House of 

Representatives Committee on Education and Labor 

chaired by Representative George Miller. Senator 

Barbara Boxer, during a hearing to consider John 

Bresland’s nomination to the Chemical Safety and 

Hazard Investigation Board as the Chair (replacing 

Carolyn Merritt), asked Mr. Bresland about the 

Contra Costa County program for process safety 

audits of refineries and chemical companies. The 

Chemical Safety and Hazard Investigation Board 

also mentions Contra Costa County in a DVDs 

“Anatomy of a Disaster: Explosion at BP Texas City 

Refinery” and “Fire in the Valley” on the resources 

given to audit and ensure facilities are complying 

with the regulations.

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, Education, Labor, and Pensions 

Subcommittee on Employment and Workplace 

Safety. The testimony was on the success of the 

Accidental Release Prevention Programs that are 

in place in Contra Costa County. The hearing 

was specific on two major incidents that occurred 

in Anacortes, Washington at a Tesoro Refinery 

and the Deepwater Horizon incident in the Gulf 

of Mexico. A link to the testimony is posted on 

the Health Services website and can be found by 

using the following link: http://help.senate.gov/

hearings/hearing/?id=fe34048f-5056-9502-5d69-

2609a5d5501a.
Industrial Safety Ordinance 2010 Report 21

Attachment A

Hazardous Materials 

Ombudsman Report 

Hazardous Materials Ombudsman Evaluation 

October 2009 through September 2010

I.	 Introduction

On July 15, 1997 the Contra Costa County Board 

of Supervisors authorized the creation of an 

Ombudsman position for the County’s Hazardous 

Materials Programs. The first Hazardous Materials 

Ombudsman began work on May 1, 1998. The 

Contra Costa County Board of Supervisors adopted 

an Industrial Safety Ordinance on December 15, 

1998. Section 450-8.022 of the Industrial Safety 

Ordinance requires the Health Services Department 

to continue to employ an Ombudsman for the 

Hazardous Materials Programs. Section 450-

8.030(B)(vii) of the Industrial Safety Ordinance 

requires an annual evaluation of the effectiveness of 

the Hazardous Materials Ombudsman, with the first 

evaluation to be completed on or before October 31, 

2000.

The goals of section 450-8.022 of the Industrial 

Safety Ordinance for the Hazardous Materials 

Ombudsman are:

1. To serve as a single point of contact for 

people who live or work in Contra Costa 

County regarding environmental health 

concerns, and questions and complaints 

about the Hazardous Materials Programs.

2. To investigate concerns and complaints, 

facilitate their resolution, and assist people 

in gathering information about programs, 

procedures, or issues.

3. To provide technical assistance to the public.

The Hazardous Materials Ombudsman currently 

accomplishes these goals through the following 

program elements:

4. Continuing an outreach strategy so that the 

people who live and work in Contra Costa 

County can know about and utilize the 

program.

5. Investigating and responding to questions 

and complaints, and assisting people in 

gathering information about programs, 

procedures or issues.

6. Participating in a network of environmental 

programs for the purpose of providing 

technical assistance.

This evaluation covers the period from October 

2009 through September 2010 for the Hazardous 

Materials Ombudsman program. The effectiveness 

of the program shall be demonstrated by showing 

that the activities of the Hazardous Materials 

Ombudsman meet the goals established in the 

Industrial Safety Ordinance.

II.	 Program Elements

1. Continuing an Outreach Strategy

This period, efforts were focused on maintaining 

the outreach tools currently available. Copies of the 

Ombudsman Brochure were translated into Spanish 

and were distributed to the public at meetings, 

presentations, public events and through the mail. 

A contact person was also established in Public 

Health that could receive calls from the public in 

Spanish and serve as an interpreter to respond to 

these calls. In addition to explaining the services 

provided by the position, the brochure also provides 

the phone numbers of several other related County 

and State programs. The web page was maintained 

for the program as part of the Contra Costa Health 

Services website. This page contains information 

about the program, links to other related websites, 

and information about upcoming meetings and 

events. A toll-free phone number is published in 

all three Contra Costa County phone books in the 

Government section. 

2.	 Investigating and Responding to Questions

and Complaints, and Assisting in

Information Gathering
Industrial Safety Ordinance 2010 Report 22

During this period, the Hazardous Materials 

Ombudsman received 171 information requests. 

More than 95 percent of these requests occurred 

via the telephone, and have been requests for 

information about environmental issues. Requests 

via e-mail are slowly increasing, mainly through 

referrals from Health Services main web page. 

Most of these requests concern problems around 

the home such as asbestos removal, household 

hazardous waste disposal, pesticide misuse and lead 

contamination. 

Information requests about environmental issues 

received via the telephone were generally responded 

to within one business day of being received. Many 

of the information requests were answered during 

the initial call. Some requests required the collection 

of information or written materials that often took 

several days to compile. Telephone requests were 

responded to by telephone unless written materials 

needed to be sent as part of the response.

Complaints about the Hazardous Materials 

Programs can also be received via telephone 

and in writing. Persons that make complaints 

via telephone are also asked to provide those 

complaints in writing. During this period, the 

Hazardous Materials Ombudsman did not receive 

any complaints about the Hazardous Materials 

Programs. 

In September, the Ombudsman facilitated a 

workshop for business owners concerning their new 

permit fee structure.

3.	 Participating in a Network of

Environmental Programs for the Purpose

of Providing Technical Assistance.

Technical assistance means helping the public 

understand the regulatory, scientific, political and 

legal aspects of issues. It also means helping them 

understand how to effectively communicate their 

concerns within these different arenas. This year, 

the Ombudsman continued to staff a number of 

County programs and participate in other programs 

to be able to provide technical assistance to the 

participants and the public. 

• CAER (Community Awareness and 

Emergency Response)—This nonprofit 

organization addresses industrial accident 

prevention, response and communication. 

The Ombudsman participated in the 

Emergency Notification subcommittee of 

CAER. 

• Hazardous Materials Commission—In 2001, 

the Ombudsman took over as staff for the 

commission. As staff to the commission, the 

Ombudsman conducts research, prepares 

reports, writes letters and provides support 

for three monthly Commission meetings. 

During this period, the Ombudsman 

completed writing reports on Household 

Hazardous Waste and Brownfields for the 

Commission.

• Public and Environmental Health Advisory 

Board—As staff to the Environmental Health 

subcommittee of PEHAB, the Ombudsman 

keeps the committee informed on issues 

they are interested in such as refinery flaring, 

contaminated fish consumption, climate 

change and Integrated Pest Management.

• Integrated Pest Management Advisory 

Committee—During this period the 

Ombudsman represented Health Services 

on, and was elected to be chairperson 

of, the newly created County Integrated 

Pest Management Advisory Committee. 

This Committee brings department 

representatives and members of the public 

together to help implement the County’s 

Integrated Pest Management policy.

• Asthma Program—The Ombudsman 

participated in the Public Health 

Division’s Asthma Program as a resource 

on environmental health issues. The 

Ombudsman also participated in countywide 

asthma coalition meetings, and represented 

the Asthma Program at regional meetings 

pertaining to asthma issues, particularly 

diesel pollution. The Ombudsman gave 

presentations to nine high school classes on 

asthma and air pollution. The Ombudsman 

has also begun to provide technical support 

for efforts to address the impacts of climate 
Industrial Safety Ordinance 2010 Report 23

change on sensitive populations, and 

efforts to improve health outcomes through 

improvements to the built environment.

• East County Environmental Justice 

Collaborative—During this period the 

Ombudsman provided technical assistance 

to the East County Environmental Justice 

Collaborative, a Public Health Division 

project in Bay Point and Pittsburg. This 

project was funded by grants from the 

Federal EPA and the San Francisco 

Foundation that the Ombudsman helped 

secure. The Ombudsman helped develop 

research materials and gave presentations 

to residents as part of this project. The 

Ombudsman also talked to teachers, 

principals and parents in the Pittsburg 

Unified School District to encourage them to 

participate in the environmental education 

programs offered by the Contra Costa Water 

District.

• Bay Area Air Quality Management District’s 

Community Air Risk Evaluation Program —

During this period the Ombudsman 

represented the Public Health Division 

on the advisory board to this Air District 

program. This advisory board meets 

quarterly to discuss implementation of this 

program that identifies and creates strategies 

to address health risks in communities with 

high air pollution emissions in the Bay 

Area. Two of these areas are in Contra Costa 

County.

• Richmond General Plan Health Element —

During this period the Ombudsman 

provided technical assistance to the City of 

Richmond as part of an effort to evaluate 

the effectiveness of the implementation of 

the new Health Element of their updated 

General Plan. 

• National Conversation on Public Health and 

Chemical Exposure—

During this period the Ombudsman 

represented the Public Health Division in 

this yearlong nation-wide effort organized 

by the federal Environmental Protection 

Agency and Centers for Disease Control to 

create an agenda for reducing the public’s 

exposure to toxic chemicals. As part of this 

effort, the Ombudsman organized two local 

workshops to gather input from the public 

on these issues.

The Hazardous Materials Ombudsman also attended 

workshops, presentations, meetings and trainings 

on a variety of environmental issues to be better able 

to provide technical assistance to the public. Topics 

included Environmental Justice, Cumulative impacts 

assessment, emergency management practices, 

health mitigations for consumption of contaminated 

fish, community-based participatory research and 

land-use planning for greenhouse gas reduction.

 

III.	 Program management

The Hazardous Material Ombudsman continued 

to report to the Public Health Director on a dayto-day basis during this period, while still handling 

complaints and recommendations about the 

Hazardous Materials Programs through the Health 

Services Director. The Ombudsman also was a 

member of Health Services Emergency Management 

Team and participates on its HEEP management 

team. The Ombudsman also assisted the Asthma 

program in the writing of grants to fund ongoing 

programs. 

IV.	 Goals for the 2010/11 period

In this period, the Ombudsman will provide 

essentially the same services to Contra Costa 

residents as was provided in the last period. The 

Ombudsman will continue respond to questions 

and complaints about the actions of the Hazardous 

Materials Programs; answer general questions 

that come from the public and assist them in 

understanding regulatory programs; staff the 

Hazardous Materials Commission and the Public 

and Environmental Health Advisory Board; 

provide technical support to the Asthma program, 

and represent it on the Ditching Dirty Diesel 

Collaborative and the East County Environmental 

Justice collaborative; chair the Integrated Pest 

Management Advisory Committee, and participate 

on the CAER Emergency Notification committee, 

the Air District CARE Advisory Board and the 
Industrial Safety Ordinance 2010 Report 24

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 25

Attachment B

Regulated Sources 

Annual Performance 

with Accident History 

and Inherent Safety 

Implementation 

Annual Performance Review 

and Evaluation Submittal

June 30, 2010 *

Attach additional pages as necessary

1. Name and address of Stationary Source: 

Chevron Richmond Refinery, 841 Chevron 

Way, Richmond, California 94802 

 

2. Contact name and telephone number 

(should CCHS have questions):

Karen Draper , 510-242-1547 

 

3. Summarize the status of the Stationary 

Source’s Safety Plan and Program (450-

8.030(B)(2)(i)): 

City Ordinance 42-016.43.160 (B)(1): 

The September 2009 Safety Plan reflects 

the current program elements within the 

Refinery. 

4. Summarize Safety Plan updates (i.e., brief 

explanation of update and corresponding 

date) (450-8.030(B)(2)(ii)):

City Ordinance 42-01 §6.43.160(b)(2): The 

September 2009 Safety Plan update has not 

yet completed the public notice process. 

 

5. List of locations where Safety Plans are/will 

be available for review, including contact 

telephone numbers if the source will provide 

individuals with copies of the document 

(450-8.030(B)(2)(ii)): 

CCHS Office, 4585 Pacheco Boulevard and 

the Richmond Library. 

6. Provide any additions to the annual accident 

history reports (i.e. updates) submitted 

pursuant to Section 450-8.016(E)(2) of 

County Ordinance 98-48 (450-8.030(B)(2)

(iii)) (i.e., provide information identified 

in Section 450-8.016(E)(1) for all major 

chemical accidents or releases occurring 

between the last annual performance review 

report and the current annual performance 

review and evaluation submittal (12-month 

history)):

City Ordinance 42-01 §6.43.090(e)(2), 

§6.43.160(b)(3), and (§6.43.090(e)(1). The 

September 2009 Site Safety Plan includes 

required updates to the accident history 

section. 

7. Summary of each Root Cause Analysis 

(Section 450-8.016(C)) including the 

status of the analysis and the status of 

implementation of recommendations 

formulated during the analysis (450-8.030(B)

(2)(iv)):

City Ordinance 42-01 §6.43.090(c), 

and 42-01 §6.43.160(b)(4): There have 

been no Major Chemical Accidents or 

Releases(MCAR) or Near Miss incidents 

requiring investigations during this reporting 

period. 

8. Summary of the status of implementation 

of recommendations formulated during 

audits, inspections, Root Cause Analyses, 

or Incident Investigations conducted by the 

Department (450-8.030(B)(2)(v)): 

City Ordinance 42-01 §6.43.160(b)(5): There 

were no audits or unannounced inspections 

during this 12 month period. 

 

9. Summary of inherently safer systems 

implemented by the source including but 

not limited to inventory reduction (i.e., 

intensification) and substitution (450-

8.030(B)(2)(vi)):
Industrial Safety Ordinance 2010 Report 26

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 27

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 28

10. Summarize the enforcement actions 

(including Notice of Deficiencies, Audit 

Reports, and any actions turned over to the 

Contra Costa County District Attorney’s 

Office) taken with the Stationary Source 

pursuant to Section 450-8.028 of County 

Ordinance 98-48 (450-8.030(B)(2)(vii)):

There were no enforcement actions during 

this period. 

 

11. Summarize total penalties assessed as a 

result of enforcement of this Chapter (450-

8.030(3)):

No penalities have been assessed against this 

facility as a result of this Chapter. 

 

12. Summarize the total fees, service charges, 

and other assessments collected specifically 

for the support of the ISO (450-8.030(B)(4)): 

The total CalARP Program fees for these 

nine facilities was $595,000. The total of 

the County and the City of the Richmond 

Industrial Safety Ordinance fees for these 

nine facilities was - $304,000. 

 

13. Summarize total personnel and personnel 

years utilized by the jurisdiction to directly 

implement or administer this Chapter (450-

8.030(B)(5)): 

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(450-8.030(B)(6)): 

There have been no comments received in 

this period. 

 

15. Summarize how this Chapter improves 

industrial safety at your stationary source 

(450-8.030(B)(7)):

The Richmond Refinery has fully 

implemented and maintains the City of 

Richmond’s Industrial safety Ordinance 

program . Chevron is fully committed 

to achieving a incident and injury free 

operation, and the minimization of potential 

risk to the community and environment.

16. List examples of changes made at your 

stationary source due to implementation 

of the Industrial Safety Ordinance (e.g., 

recommendations from PHA’s, Compliance 

Audits, and Incident Investigations in 

units not subject to CalARP regulations; 

recommendations from RCA’s) that 

significantly decrease the severity or 

likelihood of accidental releases

Refer to the ISS Solutions implemented.

(Noted in question #9) 

17. Summarize the emergency response activities 

conducted at the source (e.g., CWS or TEN 

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 29

Annual Performance Review 

and Evaluation Submittal

June 30, 2010

*Attach additional pages as necessary

1. Name and address of Stationary Source:

General Chemical West, 525 Castro Street, 

Richmond, California 94801 

 

2. Contact name and telephone number 

(should CCHS have questions):

 Kevin O’Kelley 510-237-3869 

 

3. Summarize the status of the Stationary 

Source’s Safety Plan and Program (42-01 

§6.43.160(b)(1)): 

The Safety Plan was updated in 2009. Review 

by CCHS resulted in a revision, which was 

accepted in May, 2010. 

 

4. Summarize Safety Plan updates (i.e., brief 

explanation of update and corresponding 

date) (42-01 §6.43.160(b)(2)):

The Safety Plan was resubmitted, and 

reviewed. Modifications were completed in 

May, 2010. 

 

5. List of locations where Safety Plans are/will 

be available for review, including contact 

telephone numbers if the source will provide 

individuals with copies of the document (42-

01 §6.43.160(b)(2)):

4585 Pacheco Blvd., Martinez, and in 

the Richmond public library. 

 

 

6. Provide any additions to the annual 

accident history reports (i.e. updates) 

submitted pursuant to §6.43.090(e)(2) 

of City Ordinance 42-01 (§6.43.160(b)

(3) (i.e., provide information identified 

in §6.43.090(e)(1) for all major chemical 

accidents or releases occurring between the 

last annual performance review report and 

the current annual performance review and 

evaluation submittal (12 month history)):

None. 

 

7. Summary of each Root Cause Analysis 

§6.43.090(c) including the status of the 

analysis and the status of implementation 

of recommendations formulated during the 

analysis §6.43.160(b)(4):

None 

 

8. Summary of the status of implementation 

of recommendations formulated during 

audits, inspections, Root Cause Analyses, 

or Incident Investigations conducted by the 

Department §6.43.160(b)(5): 

The CCHS audit of January, 2009 resulted 

in 64 action items. 9 items remain 

uncompleted. 

 

 

9. Summary of inherently safer systems 

implemented by the source including but 

not limited to inventory reduction (i.e., 

intensification) and substitution §6.43.160(b)

(6):

1. Simplification of Absorption Tower piping; 

2. Reduciton of pressure in Superheater; 3. 

New design of neutralization system will 

reduce the volume of wastewater treated; 

4. Simplification of molten sulfur piping; 5. 

Installation of interlock on booster pump; 6. 

Reduce concentration of hydrogen peroxide 

from 35% to 25%. 

10. Summarize the enforcement actions 

(including Notice of Deficiencies, Audit 

Reports, and any actions turned over to 

the City Attorney’s Office) taken with 

the Stationary Source pursuant to City 

Ordinance 42-01 §6.43.160(b)(7):

The 2009 audit report has not yet completed 
Industrial Safety Ordinance 2010 Report 30

the public notice process. The NOD for the 

Safety Plan is being addressed by the Safety 

Plan being modified. 

 

11. Summarize total penalties assessed as a result 

of enforcement of this Chapter §6.43.160(c):

No penalities have been assessed against this 

facility. 

 

12. Summarize the total fees, service charges, 

and other assessments collected specifically 

for the support of the ISO §6.43.160(d): 

The total CalARP Program fees for the nine 

facilities was $595,000. The total the County 

and the City of the Richmond Industrial 

Safety Ordinance fees for the nine facilities 

was - $304,000. 

 

13. Summarize total personnel and personnel 

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. 

 

16. List examples of changes made at your 

stationary source due to implementation 

of the Industrial Safety Ordinance (e.g., 

recommendations from PHA’s, Compliance 

Audits, and Incident Investigations in 

units not subject to CalARP regulations; 

recommendations from RCA’s) that 

significantly decrease the severity or 

likelihood of accidental releases:

Numerous changes have been made due 

to recommendations from PHA’s, audits, 

etc. Some examples include revision of 

procedures, improved employee training, 

and improved management of change 

documentation. 

 

17. Summarize the emergency response activities 

conducted at the source (e.g., CWS or TEN 

activation) in response to major chemical 

accidents or releases: 

None