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HomeMy WebLinkAboutMINUTES - 11021993 - IO.5 TO: BOA`'RD OF SUPERVISORS h O -5 Contra INTERNAL OPERATIONS COMMITTEE l Costa FROM: _ 15 �A 4 County October 25, 1993 DATE: rrq-coi K� SUBJECT: QUARTERLY REPORT ON HAZARDOUS MATERIALS PROGRAMS SPECIFIC REQUESTS)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION RECOMMENDATIONS: 1 . ACCEPT the report from the Health Services Director dated October 25, 1993 providing the Department' s second quarterly report on the status of the County's Hazardous Materials . Programs . 2 . DIRECT the Health Services Director to provide his third quarterly report on Hazardous Materials Programs to the Internal Operations Committee on January 3, 1994 . 3 . REQUEST ` the Health Services Director to determine the feasibility of establishing a framework within the Risk Management - and Prevention Program (RMPP) whereby the Department can focus its attention on those industries which have a demonstrated track record of safety violations or other problems which would justify closer scrutiny and can provide more frequent inspections of those firms and report his conclusions and recommendations to our Committee on January 3, 1994 . 4 . DIRECT the Health Services Director to prepare a letter from the Board of .Supervisors to the Governor of California, and this County' s legislative and congressional delegations, urging that additional steps be taken to improve and integrate the oversight by all levels of government of those firms which manufacture or use hazardous materials in their industrial processes; AUTHORIZE the Chair, Board of Supervisors to sign such letters . CONTINUED ON ATTACHMENT: YES SIGNATURE: RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD M ITTE APPROVE OTHER SIGNATURE SqM_In_r fly TrPH ACTION OF BOARD ON NnvPmher 90 1 9 9 3 APPROVED AS RECOMMENDED X— OTHER X The Board APPROVED the above recommendations, and in addition, added Assemblyman Tom Bates to the legislative and congressional.delegations listed in Recommendation # 4 to receive letters urging that additional steps be taken to improve and integrate the oversight by all levels of government of those firms which manufacture or use hazardous materials in their industrial processes. VOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE —X UNANIMOUS(ABSENT ) 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. ATTESTED November 2, 1 99.1 Contact: PHIL BATCHELOR,CLERK OF THE BOARD OF cc: See .Page 3 SUPERVISORS AND COUNTY ADMINISTRATOR BY ,DEPUTY i • I.O.-5 5 . At the time he makes his third quarterly report to the Internal Operations Committee on January 3, 1994, REQUEST the Health Services Director to outline for our Committee the steps which are needed in order to enhance the ability of the various local, regional, state and federal agencies to coordinate their oversight of firms which manufacture or handle hazardous materials in their industrial processes . 6 . DIRECT the Health Services Director to prepare a letter similar to the attached draft letter and AUTHORIZE the Chair, Board of Supervisors, County Administrator and Health Services Director to sign the letter, addressed to the Chief Executive Officers and senior managers of the major industrial firms in Contra Costa County which manufacture or use hazardous materials in their industrial processes, inviting these industrial leaders to a meeting with members of the Board of Supervisors to discuss ways in which risks to the community from industrial plants and similar issues can be discussed and a framework designed to improve the communication between the private sector and government. BACKGROUND: On August 17, 1993, the Board of Supervisors approved the first quarterly report from our Committee on hazardous materials programs and directed that the Health Services Director provide another quarterly report to our Committee. Our Committee received and considered the attached second quarterly report at our meeting on October 25, 1993 . We continue to be very pleased with the progress which has been made in completing the tasks which were undertaken in response to the Board' s April 20, 1993 directions . Our Committee will continue to provide oversight to insure the completion of all tasks in a timely manner. In order to focus the energy and resources of the Hazardous Materials Division staff, we are asking that the Health Services Director consider the feasibility of using the RMPP process to target firms which have a demonstrated record of problems with hazardous materials releases, safety problems or other issues which indicate that they should receive closer scrutiny that other firms . This appears to us to be a reasonable way in which to meet all current statutory requirements for RMPP reviews and at the same time, provide a mechanism to target firms which appears to have particular problems which may cause a special concern for the community. Health Services has undertaken an excellent effort to meet with and coordinate their efforts with those of other local, regional, state and federal agencies which each have an element of jurisdiction in overseeing the hazardous materials scene in Contra Costa County. We would like to see whether additional effort in this direction can result in increased inspections where needed, improved use of resources and reduced overlapping jurisdiction for hazardous materials issues . Finally, we want to schedule a meeting with the Chief Executive Officers or senior managers of the major firms in Contra Costa County which manufacture or use hazardous materials in their industrial processes to purge a more responsible management philosophy toward communication with the community, with government and improved attitudes toward safety considerations. The experience over the past two years would lead one to believe that such a meeting or series of meetings is overdue. -2- I .O.-5 cc: . County Administrator Health Services Director William B. Walker, M.D. , County Health Officer Wendel Brunner, M.D. , Public Health Director Lewis Pascalli, Deputy Director-Hazardous Materials Environmental Health Division, HSD Barbara Masters, Executive Assistant to the Hazardous Materials Commission -3- Contra Costa County The Board of Supervisors HEALTH SERVICES DEPARTMENT OFFICE OF THE DIRECTOR Tom Powers, 1st District Mark Finucane, Director Jeff Smith,2nd District Gayle Bishop,3rd District 20 Allen Street Sunne Wright McPeak,4th District s L Martinez, California 94553-3191 Tom Torlakson,5th District ?'-- = •0� (510)370-5003 FAX(510)370-5098 County Administrator _ Phil Batchelor County Administrator srA•coo DATE: October 25, 1993 TO: Internal Operations Committee Supervisor Sunne Wright McPeak Supervisor Jeff Smith FROM: Mark Finucane Health Services Director SUBJECT: Hazardous Materials Program This is the second quarterly report to the IO Committee following the Committee's consideration of the January 31 Grand Jury report on the management of the Hazardous Materials Program. I. Oversight of the Hazardous Materials Program Hazardous Materials Program Update: As I reported last August, the majority of administrative and management issues raised by the Grand Jury have been addressed and the Plan of Correction is nearly fully implemented. Since February 23, Mr. Lewis Pascalli, has been Acting Director of the Hazardous Materials Program. Because of the outstanding job he has done in implementing the Plan of Correction and his familiarity with the staff and the HSD in general, I have initiated action to reclassify Mr. Pascalli as Deputy Director on a permanent basis. That action will be coming before your Board within the next few weeks. I continue to meet weekly with Mr. Pascalli, Drs. Walker and Brunner, and Barbara Masters as part of our ongoing Hazardous Materials Management Team coordination. The Hazardous Materials Council and Hazardous Materials Commission also continue to receive updates and provide oversight. Mr. Howard Hatayama, former regional director of the Department of Toxics Substances Control and now overseeing environmental issues for the UC labs, has agreed to conduct a review of the program. As you may recall, one year ago, he conducted an assessment of our program and made numerous recommendations, many of which have been implemented. It will be helpful to have his perspective once again. Merrithew Memorial Hospital&Clinics Public Health • Mental Health • Substance Abuse Environmental Health Contra Costa Health Plan Emergency Medical Services • Home Health Agency Geriatrics A-345 (2/93) 2 The following is a status report of the issues which remain unresolved: A. ISSUE C: There are no established andeg nerally understood standards for the number or We of inspections which should be conducted by a staff member during the year. STATUS: Planned completion 8/31/93. This issue continues to be evaluated. SB 1082 (Calderon) which was passed and signed by the Governor this summer has changed the approach we will take on inspections. The law calls for regulatory agencies to coordinate their inspections for various programs to reduce the burden on businesses. Rather than having inspections for our three programs done at different points in time, we are embarking on a unified inspection format which will have each of our inspectors trained to perform all inspections needed for a site at one time. During August and September,we conducted cross training for our inspectors to give them the required background in the law and procedures for each program. Inspections are being conducted with experienced inspectors to monitor those who are new to a program or who may not have been in a particular program for a period of time. This training and monitoring will be completed in November. In August, our inspection schedule was revamped to implement a 'one stop shopping" format. The setting up of a standard number of inspections to be done by each inspector will be evaluated as we gain experience with this new approach. Our operative criteria in the interim will be to assure that all site inspections meet the legal mandates. B. ISSUE D: The anticipated data management system required by the State Law is not yet in place. STATUS: Completion due 12/10/93. Progress on the new Management Information System (MIS) modules 3, 4 and 5 is proceeding on schedule. Mr. Pascalli meets with the MIS programmers once a week to review the project's weekly progress and to help resolve any issues that may arise. New equipment needed to support the program has been ordered. Training sessions are being developed for the Administrative Support Team who will input the data; inspection staff will use the data and management will generate reports. The 12/10/93 due date will be met. C. ISSUE K: Determining the most appropriate organizational staffing_pattern for the Hazardous Materials Program. STATUS: Planned completion 8/31/93. The organizational staffing pattern is complete. Mr. Pascalli has proposed that an on-site manager be appointed to assure the day-to-day operation of the Hazardous Materials Programs. These programs include the Administrative Support Team, the AB 2185 Business Plan Team, the 3 ° Hazardous Waste Program Team, the Underground Tank Team, the Risk Management Prevention Program Team, the Incident Response Team and the Household Hazardous Waste Program. These organizational elements will have supervisory positions reporting to the on-site manager. The supervisors will be responsible for day-to-day supervision of team members and program oversight. With the passage of SB 1082, specific program elements may be melded into geographic districts which will make inspectors responsible for all inspections in an identified area. As experience is gained with the combined inspection protocols, the geographic boundaries will be established. Status of discussions with Fire Districts regarding organizational issues of emergency response: We are progressing on the analysis to identify and evaluate various options to carry out our responsibility to provide the most cost-effective and efficient organizational structure for carrying out our Incident Response for hazardous materials spills and releases. At our meeting held with representatives of the Richmond, Contra Costa and San Ramon Fire Districts to discuss the modeling, a number of issues arose which require additional development. The issues involve cost and billing to provide response; a determination that police and Emergency Medical Services responsibility be added; a review of other responders in various jurisdictions of the County; and addition of investigations, prosecution and public education responsibilities. There are also discussions of the need to review the various fire responder's capacity to handle or backup basic level responses. We will keep the committee advised for our progress. Interagency Coordination: The Hazardous Materials Interagency Task Force that Dr. Walker initiated one year ago has evolved into a standing organization. They continue to meet monthly, which laid the ground work for good cooperation during the General Chemical incident. They have developed documents describing the roles and responsibilities for each agency, and, most importantly, have planned a multi jurisdictional inspection for next month. This approach is being piloted to try and help streamline inspection activities for industry as well as to make the inspection more effective since agencies will be participating together and can learn from each other. Finally, a Safety Award is being developed for the facility that the agencies determine collectively has done the most outstanding job in safety and public protection. Dr. Walker is also participating on a Governor's Interagency Work Group formed in the aftermath of the General Chemical incident. Among other things, the Work Group will be reviewing hazardous materials planning and response and, in particular, how state and regional resources can be integrated and maximized. For example, RAPID -- the Railway Accident Prevention and Immediate Deployment plan -- will be reviewed for potential applicability to other types of accidents. The Task Force is also focusing on rewriting the State Hazardous Materials Incident Contingency Plan and how to implement the Standardized Emergency Management System, which would formally integrate the Incident Command System into all fire and haz mat response agencies. 4 Community Notification: We are continuing to explore ways to enhance our notification system. I want to recap some recent improvements in CAN and update you on efforts to develop a siren system for the industrial areas. First, in late September, the Governor signed into law legislation you sponsored and Senator Boatwright authored, SB 222, which will enable Community Alert Network to access all unlisted phone numbers and phone numbers with unlisted addresses in the county. With as many as 50%unlisted phone numbers in the county, this action will significantly enhance our ability to reach residents during an emergency. During the recent Tosco incident, a number of Clyde residents called because they were not notified. After researching their numbers and addresses, all but one either was not listed or lived outside of the notification area. Second, CAN is doubling their calling capacity on January 1 from 50 simultaneous lines to 100. That will speed notification time significantly. Finally, an intensive effort is underway to develop a comprehensive audible warning system for the county. A committee, which grew out of a CAER committee, has been formed that is made of 4 agency, 4 industry and 8 community or city representatives, and meets weekly to design the system. They will produce, by early December, recommendations for the hardware,placement, community education and funding so that any community that chooses to implement sirens will be part of a consistent, countywide system. These will be presented to the Hazardous Materials Commission on December 8. I want to stress that we believe that each community (the industrial areas were loosely divided into four regions: Richmond, Crockett/Rodeo/Hercules,Martinez,and Antioch/Pittsburg)with their industrial neighbors should make the final decision regarding implementation. We are encouraging local committees, in coordination with facilities' Community Advisory Panels, to take the lead on this issue. II. Initial Response and Follow up to General Chemical and Tosco Incidents General Chemical Update: The investigation is continuing into the General Chemical accident of July 26. The tank car has not yet been opened so that a final determination can be made of how much material was released; the protocol is still being developed. The car is under the Coast Guard's jurisdiction. Some agencies have assessed penalties against General Chemical: U.S. EPA, $65,625; Cal-OSHA, $106,000; and the BAAQMD, 3 nuisance violations (amounts to be determined). The DA is continuing discussions with HSD and the other agencies regarding any additional actions. October 5 Tosco Incident: Shortly before 5:00 a.m. on October 5, a pipe containing oleum at the Tosco Refinery in Martinez developed a leak. Sulfuric trioxide was released creating a sulfur acid mist. Although this is the same compound that was released in the General Chemical accident in July, early estimates are that this release was of a significantly smaller quantity and lower concentration. An "All Clear" was sounded at 8:00 a.m. As a precautionary measure, the Community Alert Network (CAN) was activated to warn residents in Clyde and other nearby areas to Shelter-In-Place. The areas that were notified were potentially those that could be the most affected. 1,505 calls were placed, beginning i i 5 at 5:30 a.m.: 1,275 messages were delivered, 1,020 of which were delivered within the first 50 minutes. People were told to stay in doors, close and lock all doors and windows and turn off ventilation systems. No roads were closed. Parents and schools in the immediate area were asked to delay opening until the All Clear was given. This was communicated primarily through the media;we are looking into ways to improve communication to schools and other sensitive receptors in the off-hours. CAN placed a second call announcing the All Clear. Area hospitals have reported only four walk-in patient. Evaluation of Emergency Response: Since quick and effective hazardous materials incident response was of particular concern to the Grand Jury, I believe it is appropriate to evaluate or system in light of these incidents. Both the General Chemical and the Oct. 5 Tosco incidents began before the normal work day. Our staff were notified by beeper and responded both to the scene and to the Haz Mat EOC from home. Communications with the facility began immediately by phone. The most urgent needs in these types of situations is communication -- with the public, the media, the facility and, if appropriate, other agencies. That process is set in motion immediately. While those communications are being made, the Incident Response team is en route to the scene. For example, in the case of General Chemical, where Richmond Fire responded first and the HSD team arrived shortly thereafter, the time differential was immaterial, since it took time to assess the scene and wait for the tank car to stabilize before any action could be taken. -Although we continue to explore with the fire departments alternative structures for providing hazardous materials response, I believe that these incidents demonstrate that our system works well and that we are able to respond timely and effectively when a release has the potential to affect the public. III. Response to Issues Raised by Citizens for a Better Environment in its August 10 Testimony On August 17, the Board requested the HSD in its Quarterly Report to respond to issues raised by CBE in its August 10 Testimony to Congressman George Miller. I believe that their concerns, as they apply to the HSD, fall into two main areas: Accident Prevention and Public Participation. 1. Accident Prevention Programs:ams: CBE contends that "existing chemical disaster prevention programs are grossly deficient." I believe that this program has resulted in significant and tangible risk reduction, such as the reduction of the volumes of AHMs being used and stored on site and the implementation of measures, like emergency shut-down systems, to reduce the likelihood and consequence of potential accidents. There are more than 100 facilities in the county that eventually will be required to prepare a Risk Management and Prevention Plan. Many of these facilities are small and some are phasing out use of their Acutely Hazardous Materials (AHMs). At this time, 26 facilities either have prepared or are in the process of preparing RMPPs. We are requesting about 10 new facilities to prepare RMPPs per quarter,which will.enable all facilities to be brought under the program by December 1995. i 6 Because we conduct thorough reviews of the RMPPs and began the program with the largest facilities, however, the process often take many months to complete. Facilities are then allowed 60 to 90 days to implement our recommendations. Additional review then occurs. Thus far, the Tosco, Unocal and Chevron RMPPs have been accepted; four other major facilities RMPPs are in the final review stages. At the same time, our staff are also conducting on-site reviews and working with facilities in performing their hazard and operability. We have three highly-qualified chemical engineers to carry out the RMPP program. Because one will be going on maternity leave shortly, we are recruiting for an additional position. By the spring (when the engineer on maternity leave returns), we will have four staff people dedicated to the program, which should enable us maintain an aggressive approach. We will need to reevaluate our fee structure at that time to support the new staff person and will also review if additional staffing is needed. There are flaws in the RMPP program, however. The HSD identified some gaps in state law and presented testimony about those issues at the September 23 Richmond hearing, chaired by Assemblyman Umberg. Current law requires a revision of the RMPP to be submitted 60 days after a modification of an operation is completed that would materially affect the handling of the acutely hazardous material. However, starting up a new operation or making a significant change to an existing process pose the most serious safety hazards, and requiring a safety review after the operation has begun defeats the purpose of the RMPP law. We are recommending that the law be changed so that a revised RMPP must be submitted 30 daysrp for to the implementation of a modification. In that way, the facility will have gone through the a detailed review of the modification, including a review of the new or revised standard operating procedures and a determination of whether adequate training has been conducted, to ensure that all safety issues are taken into account before start-up. We believe that if this had been done prior to the unloading of the oleum from tankcars, the accident at General Chemical could very well have been prevented. We are recommending additional changes to make explicit in state law that two concepts -- a management of change process and inherent safety -- are integral to the RMPP. (Management of change means that any proposed procedural or process change is reviewed against the hazard analysis to make sure that it doesn't pose any new risks; if it does the hazard analysis is revised. Inherent safety means that the risks of a new process are evaluated during the conceptual stage so that alternative equipment designs or materials may be considered that would reduce the long term risks of accident.) Although these are part of our local guidelines and administration of the RMPP program, our efforts would be enhanced by strengthening state law. The HSD recommends that the Board formally sponsor legislation to address.the above-described issues. CBE requests that "worst case" modelling be included in the RMPP. Although state law requires only the most likely scenario, we require "worst credible case" -- that is, the worst I 7 accidents for which a cause or source can be identified -- so that appropriate preventive measures can be taken as well as appropriate emergency planning. In both the General Chemical and recent Tosco incidents, the release scenarios that were modeled provided valuable information for the areas to be notified with CAN. For your information, I have attached a memo from staff to the Hazardous Materials Commission on this issue. 2. Public Participation: CBE contends that the public is "being shut out of chemical disaster prevention and emergency response planning." We have established and participate in numerous forums for providing information to the public and opportunities for them to participate in accident prevention and emergency response planning. First, the HSD holds community meetings in each community where interest is expressed when the RMPP for a facility in that community is first being reviewed. This enables residents to ask questions and learn about the process. All written comments are responded to in writing. We have held such meetings for the Chevron, Rhone-Poulenc, Shell and Pacific RMPPs, and they have been well attended (30 to 50 people). Upcoming meetings for General Chemical and, possibly Dow, are being planned. In addition, we will be holding a meeting in Richmond within 6 weeks now that we have concluded the review of the Chevron RMPP to let residents know what was found. As part of the Interagency Task Force mission, we are committed to holding a community meeting with other participating agencies following a major accident. We held such a meeting in Richmond on September 30. It was co-chaired by the Air District and the HSD, and seven additional agencies sent representatives to answer questions. The Hazardous Materials Commission began sponsoring meetings last spring to bring together all of the Community Advisory Panels (CAPs) throughout the county to facilitate them sharing ideas and concerns on issues common to all communities. (CAPs have been established at 7 industrial facilities in the county to improve communication between the company and their neighboring community.) The "all-CAP" meetings are staffed by the HSD and provide another forum for discussion about regulatory and other hazardous materials issues. Following the General Chemical accident, efforts to develop an audible warning or siren system accelerated. A county-wide committee that includes 8 community and city representatives has been meeting weekly to develop a proposal for consideration by early December. Finally, Dr. Walker, as a member of the Technical Advisory Committee on Oil Refinery and Chemical Plant Safety Preparedness, recommended that funding collected under that program be made available to Community Advisory Panels to enable them to contract for technical expertise in order to evaluate reports, such as the RMPP, Toxic Hot Spots, etc. That recommendation was included as one of four priority areas for which funding may be available. == Contra Costa County Health Services Department ENVIRONMENTAL HEALTH DIVISION ST'S-COON -- OCCUPATIONAL HEALTH/HAZARDOUS MATERIALS To: Hazardous Materials Commission From: Randall L. Sawyer, RMPP Specialist Date: August 21, 1993 Re: Issue Paper On the Risk Management and Prevention Program and the July 26, 1993 oleum Release At General Chemical. Introduction There have been a number of issues, comments and questions that have been raised since the release of oleum from General Chemical's Richmond Plant on July 26, 1993, about the Risk Management and Prevention Program (RMPP) , while others are more generic. A number of the questions deal directly with General's Chemical RMPP. This paper is, intended to address these questions. Please note that the Health Services Department has not reviewed the General Chemical RMPP. To summarize this paper will show, that even though the Health Services Department was unaware that General Chemical was loading and unloading oleum into tank cars and the Health Services Department has not reviewed General Chemicals RMPP, the oleum release scenarios in General Chemical's OSCA were for larger releases then what occurred on July 26. Enclosed with this paper is a general description for the Risk Management and Prevention Program, which includes information on Off-Site Consequence Analysis. Questions, Comments and Issues About the RMPP A number of questions, comments and issues dealing with the RMPP were generated, as a result of the release on July 26. Listed below are some of these items: 1. Were tank cars looked at in General Chemical's RMPP? 2 . Is a release of oleum for only five minutes credible? 3. Why doesn't the plume shown in General Chemical's OSCA go off-site? 4. Why does the isopleth from Lawrence Livermore Labs, as printed in the newspaper, seem to be larger than the isopleth in General Chemical's OSCA. 5. Why does the Health Services Department use worst credible case scenarios instead of worst case scenarios? 1 The following paragraphs will address all of the above concerns and we believe the RMPP (when it is followed) is an effective tool to reduce the risk at a facility that handles AHMs. Were Tank Cars Looked At In General Chemical's RMPP? When the RMPP was submitted to the Health Service's Department tank cars were not used in oleum service at General Chemical and thus were not included in the RMPP. The Health and Safety Code Chapter 6.95, Article 2, section 25534 (h) states: "The handler shall review the risk management and prevention program, and shall make necessary revisions to the RMPP at least every three years, but, Ln any event. within 60 days following a modification which would materially affect the handling of an acutely hazardous material ." Unloading/loading oleum into tank cars is a modification which would materially affect the handlipg. of an AHM. The RMPP has not been revised by General Chemical to reflect this modification. If a facility uses tank cars for storage of AHMs -- and many do -- the accident potential of loading and unloading the tank cars is looked at. The relief system on the tank car and the mitigations to capture the release from a relief device (e.g. scrubbers, flares) are also reviewed. Is A Release Of Oleum For Only Five Minutes Credible? The five minute release scenario is credible if there are monitors with automatic controls that would shutdown pumps or close valves, or if there are other devices that would shut off the flow of material. If stopping the leak is dependent on human interaction, then ten minutes is considered credible by the Center for Chemical Process Safety of the American Institute of Chemical Engineers as stated in the Guideline's for Safe Storage and Handling of High Toxic Hazard Materials. The Health Services Department recommends that release scenarios use a minimum of fifteen minutes if operator intervention is required. In General Chemical's OSCA the release time for oleum was assumed to be five minutes. However, the actual effective release time for the release of sulfur trioxide from the oleum pool would be for a far longer time than five minutes. When an oleum leak occurs, it forms a pool and sulfur trioxide is released from the pool to the atmosphere as a gas. When sulfur trioxide is released to the atmosphere it reacts with the moisture in the air to produce a sulfuric acid mist. The release plume or isopleth in General Chemical's RMPP (that was reported in the press) is for a release of oleum that occurred while loading oleum into a tank truck. That release scenario involved a- release of oleum lasting for five minutes and formed a pool on the ground. A total of 27, 060 pounds of oleum was released, of which 9,471 pounds of the oleum were in the form of 2 sulfur trioxide. (The actual amount of sulfur trioxide that was released on July 26 is estimated to be 7,800 pounds. ), Table I shows the size of the isopleth that would be formed for three different meteorological conditions. Figure I is the graphic illustration for the. isopleth with the most pessimistic meteorological conditions that would occur, assuming the wind coming from the east. This is for a concentration of oleum that would result in significant health effects. Although five minutes seems likea short period of time, the volume of oleum and the rate of release is actually larcrer than- what occurred on July 26. Why Doesn't The Plume Shown In General Chemical's OSCA Go Off-Site? The isopleth/plume shown in General Chemical's OSCA is shown with the wind coming from the east. This is an example of only one set of conditions. During an emergency this isopleth would be rotated in the -direction the wind was coming from at the time of the emergency. The Health Service's RMPP and OSCA Guidelines directs the isopleth be shown in the predominate wind direction. For that area of Richmond' the predominate wind direction is out of the west/southwest. If the isopleth was shown in the predominate wind direction it would have shown that the plume does go off-site and does impact the residential neighborhoods. This issue will be taken up during the review of the RMPP. Why Does The Isopleth From Lawrence Livermore Labs Seem To BE Larger Than The Isopleth In General Chemical's OSCA? When the Lawrence Livermore Lab first ran it's dispersion model they made some assumptions base on what was known at the time. It was first assumed that all 100 tons of oleum in the tank car was released within ninety minutes into the air, and that all of it was converted to sulfuric acid mist. General Chemical has estimated the actual amount of oleum that was released was only 3.9% of this 100 tons or 3 .9 tons of sulfur trioxide. (This estimate has not been confirmed. ) The actual time of release was over three and half hours. With the longer release time (approximately 2 .5 times longer) the rate of release is 'far smaller then what Lawrence Livermore used in their dispersion model. With the longer release time' and the smaller amount of sulfur trioxide being released the effective release rate was only 1. 6% of what Lawrence Livermore used for their modelling. Therefore Lawrence Livermore's original dispersion model assumed a release rate that was sixty-four times greater than actual estimates of the average release rate on July 26. Furthermore, Lawrence Livermore's isopleth area was for a concentration of 0.1 mg/m3 or 0. 025 parts per million of sulfuric - acid mist, which is one tenth of the threshold limit value (TLV) for an eight hour exposure to workers. This value is also 300 times smaller then the Emergency Response Planning Guideline level 3 3 (ERPG 3) of 30 mg/m3 or 7.5 parts per million. ERPG 3 is defined as the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing life-threatening health effects.. (This is . the level that is shown in the RMPP isopleth, because it represents the areas potentially most affected in- the release. ) On July 28, Lawrence Livermore ran another dispersion model assuming a release of half the contents of the tank car (50 tons) in three hours and forty-five minutes. There were three isopleths drawn for three separate levels of concern. The three levels of concern are ERPG 3 of 30 mg/m3, ERPG 2 of 10 mg/m3, and the TLV for an eight hour exposure of 1 mg/m3. The results of this model are shown in Figure II. Even this dispersion model is for a much larger release, than what actually occurred. This is because the average rate of release of sulfur trioxide on July 26 was 35 pounds per minute. Where the rate of release of sulfur trioxide in General Chemical's OSCA is 488 pounds per minute. (The rate of release used by Lawrence Livermore in the second dispersion model run was 444 pounds per minute. ) We are working with Lawrence Livermore Labs to do one final dispersion model using all of the actual data that we know. This will be complete within the next couple of weeks. The isopleth shown in General Chemicals OSCA rotated to. the direction that the wind was blowing on the morning of July 26 is compared to the ERPG 3 isopleth that Lawrence Livermore calculated on their second run in Figure III. As this illustration indicates there is very little difference between the two isopleths. General Chemical's OSCA provided information for accurate emergency response for the July 26 accident. Why Does The Health Services Department Use Worst Credible Case Scenario Instead Of Worst Case Scenario? The Health and Safety Code Chapter 6.95, Article 2, Section 25531. 1 The Legislature finds and declares that the public has a right to know about acutely hazardous materials accident risks that, may affect their health and safety, and that this right includes full and timely access to hazard assessment information, including offsite consequence analysis for the most likely hazards, which identifies the offsite area which may be required to take protective action in the event of an acutely hazardous materials release. The Health Services Department goes beyond what is required and not only requests most likely hazards, but the worst credible hazards. The. Health Services Department requires industry to use the worst credible scenario identified in the hazard and operability studies or from the seismic analysis to determine the potential impact on neighboring communities. In the Offsite Consequence Analysis this 4 is done for two reasons. First, the purpose of the RMPP process is accident prevention. Accident scenarios should be based on an identified potential source of the accident so that appropriate mitigation and prevention actions can be identified. Modeling a worst case scenario for which no cause can be found will not result in improvements. The worst credible scenarios are prepared to enable the public and emergency response agencies to plan for the possibility of such an accident to the greatest extent possible. The zones identified in the OSCA refer to those areas that may be exposed to the greatest extent if a large release of an Acutely Hazardous Material occurs. It will also enable emergency responders to notify residents who are most at risk ,to take appropriate action. Using the worst case scenario as defined by the loss of the largest container in- ten minutes does not necessarily assist in an emergency situation that is at all likely to occur. The Hazard and Operability Studies and the seismic analysis have been used to identify all credible releases at the facility. The Health Services Department needs realistic information to plan for an emergency that could actually occur The release that occurred on July 26 has been described as one of the worst chemical accidents in Contra Costa County's history. Yet, this release was smaller than the release scenario indicated as the worst credible case scenario in General Chemical's OSCA. Conclusion The Health Services Department believes that when followed the RMPP is an effective tool in the prevention of Acutely Hazardous Materials accidents and that the OSCA gives the public and emergency responders accurate information to determine the areas that may be required. Even though General Chemical did not take into consideration the release of oleum from a tank car, the oleum release that occurred at General Chemical on July 26 was smaller then the other scenarios that were defined in General Chemical's OSCA. RLS:HAZMATCO.GEN 5 N Ot. N l 3 o g - N 3 N co 1' e 1 t`. 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V t R � .� .;4 �a M,y,a. rt r a, wQ y�.e::rf'••-' �1 '" � ��•."v�sf ,,,,, �� • 4t�.;�moi" , r 'r"" ,fid P1t5h �Q �! ra►i ti; � ,f.a� •/ ( �• .. t � it om K YIY/�}•• yµp�� �' tom}^ � j. -` .• Y a Y. �� ..t r..� ti Lim�«,,..G -,o!, 1.r�;ir_v af""Iwrc i = ♦ R K .M 4•yaaw �t� !t b a } l '� 1 F '� •i t _ �•�. . r� «,a,�, £«un. a Y� _ rb "�Ko �-L t tt 4 � / 'rax 1 .�� +Y. Fy.•` � � ~ c •" c "�`Na.a,,� � s'� �'� �;r:,L 5 V • ,,. ' .-. 11IA•a �1.. \.. M �.. _ DRAFT DRAFT DRAFT DRAFT [To be sent to Contra Costa Council, Industrial Associations, and all major industrial facilities CEOs.] Dear , Over the last couple of years, there has been a number of serious accidents at industrial facilities throughout the county. This has, understandably, caused great public concern and wariness of industry. The Chevron catalyst release, the Rhone-Poulenc fire, and the recent General Chemical oleum release are three such examples. Regardless of where the individual incidents occurred, all industry is affected when accidents occur. This level of accidents is simply unacceptable, and we must find better ways to prevent these releases from occurring. It is critical for the public well-being as well as for the economic well-being of our county. In addition, in the next year or so, many of the refineries will be undergoing significant expansions to implement the reformulated fuels projects. There will be a great deal of new construction and handling of hazardous materials. Start-ups of new activities often present the greatest potential for mishaps. We want to begin discussions now about how to minimize that risk, particularly in light of recent events. I would like to invite you to attend a meeting on [DATE] to discuss this issue with Supervisors and the Health Services Department. We are requesting that the highest levels of management -- CEOs and plant managers -- attend as this is the most serious of matters. There are other items that I would like to discuss as well, such as recent work by the Hazardous Materials Interagency Task Force, particularly with regard to an upcoming multijurisdictional inspection. There may be additional issues that you would like to raise. I want to stress that the Board fully recognizes the contributions industry makes to the county and community -- in terms of jobs, revenues and charity. Nevertheless, unless this recent spate of accidents ceases, the public will become increasingly skeptical that industry and people can coexist in our county. Improving relations between business, the government and the public is essential. Many industries have taken positive steps to reduce tensions and develop good community relations with their neighbors. We have also seen many improvements through the RMPP and other regulatory programs. These are important steps,which we would like to build on, beginning at the meeting. Please let know if you will be able to attend. I look forward to seeing you. Sincerely,