HomeMy WebLinkAboutMINUTES - 11281989 - IO.4 4k k » I.0.4
TO: BOARD OF SUPERVISORS
_� Contra
_
FROM: INTERNAL OPERATIONS COMMITTEE Costa
s
of ,-
�. . Count
November 13 1989 y
DATE: �
SUBJECT: REPORT ON IMPLEMENTATION OF RISK MANAGEMENT
AND PREVENTION PROGRAMS DESIGNED TO REDUCE
THE RISK OF HAZARDOUS MATERIALS RELEASES
SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION
RECOMMMiDATION
1. Acknowledge receipt of the report of the Health Services
Director on the status of plans to implement Risk Management
and Prevention Programs (RMPP) pursuant to AB 3777 (Chapter
1260, Statutes of 1986) as subsequently amended.
2. Request the Health Services Director to work with the major
industries in the County which handle acutely hazardous
materials to develop a peer review system whereby teams of
industry experts can work with the Health Services
Department staff to conduct inspections of industry sites to
validate statements made by an industry regarding the safety
measures which have been taken to prevent spills and to
validate the quantities and types of chemicals which are
stored and handled on a given site.
3 . Request the Health Services Director to prepare a report to
the 1990 Internal Operations Committee by April 1, 1990
updating the Committee on the status of the RMPP Program at
that point in time and for that purpose refer this item to
the 1990 Internal Operations Committee.
4. Remove this item as a referral to our Committee.
BACKGROUND:
on October 3 , 1989 the Board of ,Supervisors referred to our
Committee the responsibility to oversee the implementation of the
Risk Management and Prevention Program which was mandated by
CONTINUED ON ATTACHMENTYeS YES SIGNATURE:
RECOMMENDATION O COUNTY AINISTRATO MMENDATIOIV.OF'90ARD COMMITTEE
APPROVE .H R RECO
SIGNATURE(S): TOM POWERS SUNNE WRIGHT McPEAK
ACTION OF BOARD ON NoveMMN APPROVED AS RECOMMENDED X
OTHER
VOTE OF SUPERVISORS
I HEREBY CERTIFY THAT THIS IS A TRUE
X UNANIMOUS(ABSENT I I ) AND CORRECT COPY OF AN ACTION TAKEN
AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD
ABSENT: ABSTAIN: OF SUPERVISORS ON THE DATE SHOWN.
Cc: County Administrator ATTESTED—
Health
TTESTED Health Services Director PHIL BATCHELOR,CLERK OF THE BOARD OF
William Walker, M.D. , SUPERVISORS AND COUNTY ADMINISTRATOR
Director of Environmental Health
M382 (10/88)
8Y DEPUTY
-2-
AB 3777 in 1986 . On November 13 , 1989 our Committee met with Dr.
William Walker, Director of Environmental Health and Ken Axe, who
has been doing most of the work on the RMPP Program.
Mr. Axe has identified 24 firms which handle acutely hazardous
materials on-site in sufficient quantity that they are required
to submit an RMPP. As the attached report indicates, all
industries which were required to submit an acutely hazardous
material registration form did so on time. From these forms a
database was assembled. Some 366 acutely hazardous materials are
handled in Contra Costa County. However, only 42 of these are
handled above the thresholds identified in State law. Of these
42 acutely hazardous materials, ten possess physical properties
such that dispersion is likely upon accidental release. One or
more of these ten chemicals is handled by each of the 24 firms
which have been identified as being required to submit RMPP' s.
The firms which handle these chemicals have been ranked in groups
based on the quantity and nature of the chemicals which are
handled on-site and the distance from the site to residential
areas. The firms will be asked to submit RMPP' s in the order of
their ranking on the attached Chemical Exposure Index Summary.
The first five firms will be notified by December 1, 1989 of the
need to submit an RMPP. The second five firms will be asked to
submit RMPP' s as soon as the Health Services Department gets a
second chemical engineer on staff, which should be early in 1990.
Staff will work closely with these first ten firms between
December 1, 1989 and December 1, 1990. This will consist of a
detailed on-site review of the firms manner of handling, storing
and use of the acutely hazardous materials and can actually
include a review of each and every joint and valve on site.
On December 1, 1990 the next ten firms will be asked to submit
RMPP. The last four firms will be asked to submit RMPP on
December 1, 1991. The review of all RMPP' s is scheduled to be
completed no later than December 1, 1992 and possible earlier if
the work goes more quickly than has been anticipated.
The review of the RMPP' s involves actual design, maintenance and
operational changes in the industrial plants, not simply the
submission of a paper document which then stays on the shelf.
We are asking the Health Services Department staff to advise the
1990 Internal Operations Committee if it appears that there is
any way to speed up the submission and review of the RMPP' s,
although we recognize and appreciate the fact that the Health
Services Department is trying to make these reviews as thorough
and scientifically sound as possible.
We have also recommended that the Health Services Department
staff work with the industries in the County to form peer review
teams which can help provide for a peer review of an industry' s
safety practices and help promote an industry-based social
conscience among their own members.
We are recommending that the 1990 Internal Operations Committee
continue to monitor and provide oversight to the development of
the RMPP Program.
CONTRA COSTA COUNTY
HEALTH SERVICES DEPARTMENT
ENVIRONMENTAL HEALTH DIVISION Contra Costa County
RECEIVED
OCCUPATIONAL HEALTH/HAZARDOUS MATERIALS
----- � NOV 81989
Office of
County Administrator
TO: Claude Van Marter
Assistant County Administrator
FROM: Mark Finucane
Director Health Services Department
SUBJECT: RMPP Report to the Internal Operations Committee
Due November 13, 1989
DATE: November 8, 1989
INTRODUCTION:
AB-3777 occupies Article 2 of Chapter 6. 95 of the Health and
Safety Code. It has been modified by AB-3205 and, most recently,
by AB-2132. EPA's list of 366 Extremely Hazardous Substances was
adopted as the list of Acutely Hazardous Materials (AHM' s) .
While acute toxicity is the primary listing criterion, several
compounds were added because of exceptionally high production and
physical properties that might pose a significant risk. The
statute defines, and may require, Risk Management and Prevention
Programs (RMPP' s) . Following are steps that have been taken to
implement the program.
AHM REGISTRATION FORMS:
Section 23-25532, required that facilities handling AHM' s in
excess of 200 standard cubic feet, 55 gallons or 500 pounds (as
appropriate) submit an AHM Registration Form. The registration
forms include amounts of AHM' s, and a brief description of the
processes that handle the materials. Registration was required
by January 1, 198(7) , with updates required within 30 days of
any significant increase in inventory. AB-2132 has changed the
reporting thresholds to the corresponding EPA Threshold Planning
Quantities (TPQ) . (This will result in the deletion of 19
inventory records out of 219..) Registration forms were received
by the Environmental Health Division on time.
AHM DATABASE:
A database was assembled from the information collected on the
AHM Registration Forms. Data can be sorted by chemical, by
facility, by city or region, or any of a variety of fields. This
was an essential step in screening facilities and materials for
RMPP inclusion. The database was completed in January, 1988.
• I
r"
PRESCREENING:
Of the 366 AHM' s, 42 are handled above thresholds in Contra Costa
County. "rdOT41-pie of these possess physical properties such that
dispersion is likely upon accidental release. There are 24
facilities that handle these compounds in quantities that could
pose--if not mitigated--an offsite risk.
ESTABLISH LEVEL OF CONCERN:
Emergency Response Planning Guidelines for each of the ten
compounds were designated as the "Level of Concern" . Facilities
were asked to pre-model releases of any of these materials if it
was felt that a release might be able to achieve a Level of
Concern at the nearest offsite receptor. Agreement has been
reached as to which compounds each facility shall consider in a
RMPP.
PRODUCE RMPP GUIDANCE:
Through the CAER Technical Subcommittee, a group of twelve
facility representatives was organized. Environmental Health
staff conducted a series of six four-hour workshops, during which
RMPP guidance was developed.
Guidance for Offsite Consequence Analysis output guidance for
Hazard and Operability Study output, and an outline for the RMPP
were developed, as well as significant supporting detail.
Included was an extensive review of dispersion modeling.
Guidance was completed on September 22, 1989 .
RANKING FACILITIES:
Facilities are being ranked in accordance with the modifications
made by AB-2132. Considerations included toxicity, physical
properties, quantity available for dispersion and distance to
nearest receptor. Facilities will be ranked in bands, rather
than sequentially. Bands, of up to five facilities, will be
simultaneously requested to produce RMPP' s. The first group of
facilities could be formally requested to "start" the RMPP
process by December 1, 1989. It is important to note that
significant work has already been undertaken by facilities as a
result of AB-3777 . The results of work to date include design
mitigations and inventory reduction.
RMPP REQUEST SCHEDULE:
Twelve of the facilities which will be requested to produce
RMPP' s first have already been notified as to which AHM' s must be
considered. They have also been provided with guidance for the
development of RMPP' s. While twelve facilities have been
prepared to begin the RMPP process immediately, current staffing
can accommodate five facilities at most. One additional staff
chemical engineer, if dedicated to the program, should more than
double the rate at which RMPP' s are generated.
t -1
RISK AND PREVENNTION PROGRAMS
RMPP DEFINITION: (H&SC 25532(g) ) " . . .administrative and
operational programs which are designed to
prevent acutely hazardous materials accident
risks, . including. . .design safety of new and
existing equipment, standard operating
procedures, preventive maintenance. . .emergency
response planning. . .audit programs to ensure
that these programs are being executed as
planned. "
BASIS OF RMPP: (H&SC 25534(d) , (e) )
* Hazard and Operability Study (HAZOP)
* Offsite Consequence Analysis
* Additional Supporting Technical Information
4/13/89
rmpp.ka
r
f
RMPP CONTENTS: (HSC . 25534(c) ) '
(1) 3 year accident history (involving *AHM's)
(a) describe underlying causes
(b) mitigations taken to prevent recurrence
(2) Condition/age/nature of AHM handling equipment
(3) Design, operating and maintenance controls to
minimize occurrence of AHM accidents
(4) Detection, monitoring and automatic control systems
to minimize magnitude/consequences of AHM release
(5) Schedule for implementing additional steps or
changes to minimize risk, pursuant to results of
HAZOP and offsite consequence analysis
(6) Auditing and inspection program to verify that RPP
is being effectively carried out
(7) Record keeping procedures
*AHM: Acutely Hazardous Material
4/13/89
rmpcts.ka
CHEMICAL EXPOSURE INDEX SUMMARY
Complete the following Table(See Note 1)by filling in and multiplying the appropriate Risk Factor Scale numbers
for each of the major Risk areas as identified in the following formula(See "Definitions of Scale Numbers" CEI,
page 6):
I. X ll. X III. X IV. X
ACUTE VAPOR DISTANCE MOLECULAR PROCESS CHEMICAL
HEALTH QUANTITY (RECIPROCAL) WEIGHT PENALTIES EXPOSURE
HAZARD SCALE SCALE SCALE SCALE INDEX
SCALE NO. NO. NO. NO.
NO.
Identification of Containment Vessels
being evaluated: 1. fl. Ill. IV. V. VI.
Name or Number (See Notes 2 & 3) CEI
Source #1
To (1) Public
F'
(2) Other in-company Facility
(3) Non-company Plant or Business
Source #2 (if needed)
To (1) Public
(2) Other in-company Facility
(3) Non-company Plant or Business
NOTE 1 —The distance scale number in column Ill is the only factor normally expected to change, so column
III and the corresponding CEI(column VI)are all that would normally be expected to differ from the first calculation
for each source.
NOTE 2—Only different sources of the same chemical should be evaluated on this sheet.Use a separate Chemical
Exposure Index for every different chemical.
NOTE 3 — Use additional sheets if additional sources with differing potential impact are present.
NOTE 4 — It is important to document the worst case scenarios for future reference. See "Review Procedure
c and Check List," page 7.
Back of Form G91 M
rrrr
5