Industrial Safety Ordinance 2010 Report 1 

# City of 

# Richmond

Annual Performance Review & Evaluation Report

July 26, 2011

By Contra Costa Health Services Hazardous Materials ProgramsIndustrial 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

............................ 29Industrial 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 andIndustrial 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 ReportsIndustrial 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 theIndustrial 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 ProgramIndustrial 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

1/5/09Industrial 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 IndustrialIndustrial 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 wasIndustrial 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 - LIBRARIESIndustrial 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 SYSTEMSIndustrial 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

YearNumber 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 shownIndustrial 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

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

County & Richmond ISO County ISO

* 4 Severity I incidents at County ISO facilities in Oct, Nov 2010 not shownIndustrial 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 theIndustrial 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 GatheringIndustrial 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 climateIndustrial 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 continuedto 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 theIndustrial 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 wastesIndustrial 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-910Industrial 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 completedIndustrial 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