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HomeMy WebLinkAboutMINUTES - 11042003 - D2 Contra Costa TO: BOARD OF SUPERVISORS aunty i alker, M.D. Health Se `ices Dire t ' \ r FROM: William W , , ATE: November 4 2003 SUBJECT: Annual Industrial Safety Ordinance Report e,ort SPECIFIC REQUESTS) OR RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION RECOMMENDATIONS: Accept the Industrial Safety Ordinance Annual Report submitted by Health Services. FISCAL. IMPACT: No fiscal impact BACKGROUND/REASONS FOR RECOMMENDATIONS: Chapter 480-8 of the County Ordinance Code known as the Industrial Safety Ordinance Risk Management Chapter requires Health Services to submit annual reports to the Board of Supervisors. The ordinance outlines what is to be included in this report. Attached is a copy of this report. CONTINUED ON ATTACHMENT: OYES ❑ NO SIGNATURE RECOMMENDATION OF COUNTY ADMINISTRATOR ,RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER SIGNATURES : ACTION OF BOARD ON / P 00 APPROVED AS RECOMMENDED OTHER REFER FD exhibits A and B to the Internal Operations Committee for further discussion. VOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE AND UNANIMOUS(ABSENT .�z CORRECT COPY OF AN ACTION TAKEN AND AYES: NOES: ENTERED ON THE MINUTES OF THE BOARD ABSENT: ABSTAIN: OF SUPERVISORS ON THE DA'T'E SHOWN. Contact: Randy Sawyer((925)646-2879) ATTESTED cc: Randy Sawyer, Health Services Department J HN SWEETEN, CLERK OF THE BOARD OF SUPERVISORS AND COUNTY ADMINISTRATOR BY ,�- l,> > � -- , DEPUTY RLS K:/Industrial Safety Ordinance/Annual Report/Board Ceder 012803 �� INDUSTRIAL SAFETY ORDINANCE ANNUAL PERFORMANCE REVIEW AND EVALUATION REPORT NOVEMBER 4, 2003 f CONTR.A. COSTA HEALTH SERVICES By Contra Costa Health Services Hazardous Materials Programs Table of Contents Introduction..... ..........!...................................................................... 1 Annual Performance Review and Evaluation Report .....................................................2 Effectiveness of Contra Costa Health Services' Implementation of the Industrial Safety Ordinance .......................................................3 Effectiveness of the Procedures for Records Management.............................................4 Number and Type of Audits and:Inspections Conducted ...............................................5 Number of Root Cause Analyses and/or Incident Investigations Conducted by Health Services............................ ...........................................................................................7 Health Services Process for Public Participation............................................................7 Effectiveness of the Public Information Bank...... ....... ...................... ......................7 Effectiveness of the Hazardous Materials Ombudsman .................................................7 Other Required Program Elements Necessary to Implement and.Manage the Industrial SafetyOrdinance........<....................................................................................................8 Regulated Stationary Sources Listing..............................................8 The Status of the Regulated:Stationary Sources' Safety flans and Programs................8 Locations of the Regulated Stationary Sources Safety Plans..........................................8 Annual Accident History Report and Inherently Safer Systems Implemented as Submitted by the Regulated Stationary Sources.............................................................9 Status of the Incident Investigations, Including the Root Cause Analyses Conducted by the Regulated Stationary Sources.................................................................................. 12 Major Chemical Accidents and Releases...................................................................... 14 Legal Enforcement Actions Initiated by Health Services.............................................15 Penalties Assessed as a Result of Enforcement............................. 15 Total Fees, Service Charges, and Other Assessments Collected Specifically for the Industrial Safety Ordinance ........................... 15 "Total Personnel and Personnel Years Used by Health Services to Implement the Industrial Safety Ordinance................................... 15 Comments From Interested Parties Regarding the Effectiveness of the Industrial Safety Ordinance ..................................................... 16 The Impact of the Industrial Safety Ordinance on Improving IndustrialSafety ......... ................................................................. 16 General Chemical Richmond Mors Safety Evaluation............................................... 17 Health Services Proposed Changes in the Risk Management Chapter of the Industrial Safety Ordinance ................................... 18 Public Review Process for Proposed Changes.............................................................. 18 City of Richmond Industrial Safety Ordinance ............................. 1.8 Industrial Safety Ordinance Annual Report November 4, 2003 Introduction The Board of Supervisors passed the Industrial Safety Ordinance because of concerns of the accidents that have occurred at the oil refineries and chemical plants in Contra Costa County. The effective date of,the Industrial Safety Ordinance was January 15, 1999. The ordinance applies to oil refineries or 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 a program level 3 stationary source as defined by the California Accidental, Release Prevention (CaIARP) Program. The ordinance specifies the following: • Stationary sources had one year to submit a Safety Plan to Contra Costa .Health Services stating how thestationary source is complying with the ordinance, except the Human Factors portion (January 15, 2000) • Contra Costa Health Services develop a Human Factors Guidance Document • Stationary sources had one year to comply with the requirements of the Human Factor Guidance Document that was developed by Contra Costa Health Services (January 15, 2001) • For major chemical accidents or releases the stationary sources are required to perform a root cause analysis as part of their incident investigations • Contra Costa Health Services may perform it's own incident investigation, including a root cause analysis • 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 source's Safety Programs within one year of the receipt of the Safety Plans (January 15, 2001) and every threes after the initial audit/inspection • Contra Costa Health Services will give an annual performance review and evaluation report to the Board of Supervisors Seven stationary sources that are covered by the Industrial Safety Ordinance are: • Air Products at the Shell Martinez Refining Company • Air Products at the Tesoro Golden Eagle Refinery • Shell Martinez Refining Company • General Chemical Corporation in Bay Point • Polychemie • ConocoPhillips Rodeo Refinery • Tesoro Golden Eagle Refinery Contra Costa Health Services completed and issued the Contra Costa County Safety Program Guidance Document on January 15, 2000. The stationary sources were required to comply with the Human Factors section of this guidance document by January 15, 2001. Page 1 of 18 Industrial Safety Ordinance Annual Report November 4, 2003 Contra Costa .Health Services has reviewed all of the Safety Plans submitted to the department and has audited and inspected all of the stationary sources as required by the ordinance, including the human factors programs that have been established at the stationary sources. Contra Costa Health Services is now performing the second audits of the stationary source. The status of the reviews and audits are discussed within the report. Annual Performance Review and Evaluation Report The Industrial Safety Ordinance specified that the contents of the annual performance review and evaluation report contain the following: 1) A brief description of how Health Services is meeting the requirements of the ordinance as follows: a) Effectiveness of the Department's program to ensure stationary source's compliance with the ordinance b) Effectiveness of the procedures for records management c) Number and type ofaudits and inspections conducted by Health Services as required by the ordinance d) Number of root cause analyses and/or incident investigations conducted by Health Services e) Health Services process for public participation f) Effectiveness of the Public Information Bank g) Effectiveness of the Hazardous Materials Ombudsperson h) Other required program elements necessary to implement and manage the ordinance 2) A listing of stationary sources covered by the ordinance, including for each: a) The status of the stationary source's Safety Plan and Program b) A summary of all stationary sources' Safety Plan updates and a listing of where the Safety Plans are publicly available c) The annual accident history report submitted by the regulated stationary sources and required by the ordinance d) A summary, including the status, of any root cause analyses and incident investigations conducted or being conducted by the stationary sources and required by the ordinance, including the status of implementation of recommendations e) A summary, including the status, of any audits, inspections, root cause analyses and/or incident investigations conducted or by Health Services, including the status of implementation of recommendations f) Description of inherently safety systems implemented by the regulated stationary source g) Legal enforcement actions initiated by Health Services, including administrative, civil, and criminal actions 3) Total penalties assessed as a result of enforcement of the ordinance 4) Total fees, service charges, and other assessments collected specifically for the support of the ordinance 5) Total personnel and personnel years utilized by the jurisdiction to directly implement or administer the ordinance Page 2 of 18 Industrial Safety Ordinance Annual Report November 4, 2003 6) Comments from interested parties regarding the effectiveness of the local program that raise public safety issues 7) 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. These policies, procedures, protocols, and questionnaires for these programs are listed below: • Audits/Inspections Policy • Conducting the RMP/Safety Plan Completeness Review Protocol • RMP 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 CatARP .Program Guidance Document and the Centra Costa County Safety Program Guidance Document. These documents give guidance to the stationary sources for complying with the Industrial Safety Ordinance. The policies, procedures, protocols, questionnaires, and guidance documents are available through Health Services. Health Services is performing the second round of audits for the Industrial Safety Ordinance stationary sources. All Industrial Safety Ordinance stationary sources second round of audits will be completed by February 2004. Health Services hired a consultant to do public outreach and setup public meetings for the Industrial Safety Ordinance stationary sources that are located in Bay Point, Clyde, North Concord, Pacheco, and the Martinez areas of the County. The person hired to perform Page 3 of 18 Industrial Safety Ordinance Annual Report November 4, 2003 public outreach met with organizations and people in these communities. The purpose of the outreach is to help familiarize people that live and work close to the stationary sources that are subject to the Industrial Safety Ordinance on the ordinance and how they may be able to ask questions and comment on the stationary sources Safety Plans and Health Services Preliminary Audit Findings for these stationary sources. Three public meetings were held. Below is a listing of the different public meetings: • May 1, 2003 in Bay Point for Polychemie and General Chemical Bay Point Works • May 6, 2003 in Pacheco for the Tesoro Golden Eagle Refinery and Air Products at the Golden Eagle Refinery'.: • May 8, 2003 in Martinez.for the Shell Martinez Refinery and Air Products at the Martinez Refinery Attachment A is a report on the public outreach that was performed for the Industrial Safety Ordinance. Effectiveness of the Procedures for Records Management Health Services has setup hard copy and computer files for each of the stationary sources. The files include the following folders: • Annual status reports • Audits &Inspections • Communications • Completeness Review • Emergency Response • Incident Investigation • Trade Secret Information The paper files for the stationary sources are kept in a central location. The Accidental Release Prevention Program has a file setup 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 Program Engineers. The Accidental Release Prevention Program files also contain regulations, policies, information from the U.S. EPA, the Governor's Office of Emergency Services, the Chemical Safety and Hazards Investigation Board, and other information pertinent to the engineers. The risk management and safety plans received are kept at two different Health Services locations: the Hazardous Materials Program Offices and the Accidental Release Prevention Program Offices. Health Services revised the existing database that is used to track the status of each of the stationary sources, including the status of each of their root cause analysis reports. This revision allows for easier access for inputting and reading the data that exists in the databases. Health Services has also expanded the amount of data that is kept through this database. Page 4 of 18 Industrial Safety Ordinance Annual Report November 4,2003 Number and Tyre of Audits and Inspections Conducted Health Services was required,to audit and inspect all seven regulated stationary sources that are required to comply with the Industrial Safety Ordinance 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 (2000). Health Services performed focused audits of the stationary sources for their Human Factors Programs (this was not included in the original audit/inspection, since the stationary sources were not required to have their Human Factor Program in place until January 2001) and Inherently Safer Systems in 2001 and 2002. Additional focused audits were performed to look at how two stationary sources would manage the organizational change in case there was a strike and non-striking personnel were used instead of the striking personnel (2002). Health Services has completed the second round of audits for the following stationary sources: General Chemical Bay Point Works, ConocoPhillips Rodeo Refinery, and the Tesoro Golden Eagle Refinery. The remaining four stationary sources' audits will be completed by the end of February 2004. When Health Services reviews a Safety Plan, a Notice of Deficiencies is produced that documents what changes to their Safety Plan a stationary source are required to make before Health Services determines that the Safety Plan is complete. The stationary source has sixty to ninety days to respond to the Notice of Deficiencies. When the stationary source has responded to this`Notice of Deficiencies, Health Services will review the response. Health Services will state that the Safety Plan is complete or will work with the stationary source, until the Safety Plan is determined to be complete. When the Safety Plan is complete, Health Services will open a public comment period on the Safety Plan and hold a public meeting. Health Services will respond to all written comments in writing and when appropriate use the comments in the audit/inspection of the regulated stationary sources. Health Services will issue Preliminary Audit Findings after an audittinspection is complete. The stationary source will have ninety days to respond to these findings. Health Services will review the response from the stationary source on the Preliminary Audit Findings. When the stationary source has developed an action plan to come into compliance with the regulations, Health Services will issue the Preliminary Audit Findings for public commentand will hold a public meeting. Health Services will consider any public comments I that were received during the public comment period and if appropriate will revise the Preliminary Audit Findings. When this is complete, Health Services will issue the Final Audit Findings and will respond in writing to any written public comments received. Table I lists the status of Health Services review of the different stationary sources safety Plans and audit and 'inspections of their Safety Programs. Page 5 of 18 00 I r-+ cn C00 CN 00 w , U 00 N C? C, C) 0 C; 7 0 `•C7 ``"' u1 a � i 1 18 i � jtaio S � CO a `w l v0 cn j o *04 ' ' " Industrial Safety Ordinance Annual Report November 4, 2003 Number of Root Ouse Analyses andlor Incident Investigations Conducted by Health Services Health Services has not performed any incident investigations, including a root cause analysis within the last year. Health Services has had meetings on the status and the progress of the stationary sources own incident investigations and root cause analyses for Major Chemical Accidents or Releases and has reviewed the reports submitted to Health Services. Health Services Process for Public Participation Health Services hired a consultant to develop and implement a public outreach plan for the Bay Point, Martinez, Clyde, North Concord, and Pacheco areas of the County. The plan included giving presentations to many organizations in these communities from March to May 2003. The consultant also arranged three public meetings on the Safety Plans and the County's audit findings for the following stationary sources: • Shell Martinez Refinery • Tesoro Golden Eagle Refinery • Air Products at the Shell Martinez Refinery • Air Products at the Tesoro Golden Eagle Refinery • General Chemical Bay Point Works • Polychemie The consultants report of the outreach efforts and results are included in Attachment A of this report. Effectiveness of the Public Information Bank Health Services hired an intern this summer to work with the Hazardous Materials Programs for designing a web site for the Hazardous Materials Programs that will be a part of Health Services Web Site. The web site includes information on the different Hazardous Materials Programs: • Industrial Safety Ordinance • California Accidental Release Prevention Program • Hazardous Materials Inventories and.Emergency Response Program • Hazardous Waste Generators • Underground Storage Tanks • Above Ground Storage Tanks • Green Program • Major Chemical Accidents and Releases • Hazardous Materials Incident Response Team • Unannounced Inspection Program Effectiveness of the Hazardous Materials Ombudsman The 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 their concerns about how Hazardous Materials Programs personnel are performing their duties. Attachment B is a report from the Hazardous Materials Ombudsman on the effectiveness of the position.. Page 7 of 18 Industrial Safety Ordinance Annual Report November 4, 2003 Other Required Program Elements Necessary to Implement and Manage the Industrial Safety Ordinance The California Accidental Release Prevention (CalARP) Program is administered by Contra Costa Health Services, The Industrial Safety Ordinance expands on this program. Stationary Sources are required to submit a Risk Management Plan to Health Services that is similar to the Safety Plans that are submitted. Health Services reviews these Risk. Management Plans and performs the CalARP Program audit simultaneously with the Industrial Safety Ordinance audit. Health Services performs Unannounced Inspections of the stationary sources. 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 that are regulated by the Industrial Safety Ordinance were required to submit their Safety Plans to Health Services by January 15, 2000 and to have their Safety Programs completed and implemented. The stationary sources were also required to have a Human Factors Program in place that follows the County's Safety Program Guidance Document by January 15, 2001. 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 were revised + When the Notice of Deficiencies were issued for the Human Factors revised Safety Plan • When the Human Factors Safety Plan was determined to be complete • When the Audit/Inspection was completed + When the Human Factors Audit Findings 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 their Safety Plan to Health Services on January 15, 2000 and an updated Safety Plan that includes the implementation of the stationary source's Human Factors Program by January 15, 2001. These plans are available for public review at the Hazardous Materials Programs Offices at 4333 Pacheco Blvd., Martinez. When Health Services determines that the Safety Plan is complete and prior to going out for a forty-five day public comment period, Health Services 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. Page 8 of 18 Industrial Safety Ordinance Annual Report November 4, 2003 Table II Location of Safety Flaks - Libraries Air Products at Hazardous Materials Martinez Public Shell Pro ams Office Libr Air Products in Hazardous Materials Martinez Public Ultramar Programs Office Library Shell Refining— Hazardous Materials Martinez Public Martinez Pro ams Office Libr General Chemical Hazardous Materials Bay Point Public Bay Paint Programs Office Library Polypure Hazardous Materials Bay Point Public Programs Office Library Tosco San Hazardous Materials Rodeo Public Crockett Public Francisca Area Programs Office Library Library Refine Tesoro Golden Hazardous Materials Martinez Public Ea le Refinery Programs Office I Library 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 the accident history of the regulated stationary sources from their Safety Plans and how they have used inherently safer processes within the last year. Attachment C is copies of the updates from July 1, 2002 through June 30, 2003 from each of the stationary sources. 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. Table III Inherently Safer Systems Air Products at the Decreased the Inherent .Moderate Shell Martinez concentration of a Refinmy hazardous material Air Products— No new inherently Tesoro safer systems implemented this year Page 9 of 18 Industrial Safety Ordinance Annual Report November 4, 2003 ConcocoPhillips Elimination of a Inherent Minimization Rodeo Refinery hazard Elimination of a Inherent Minimization hazard Eliminated tankage Inherent Minimization reducing inventory Eliminated tankage Inherent Minimization reducing inventory Eliminating tankage Inherent Simplify that could cause an hazard Minimizing hazard Passive Simplify through equipment design Minimizing hazard Passive Simplify through equipment design Less hazardous Inherent Moderate process conditions Simplified the Passive Simplify rocess Simplified the Passive Simplify process Simplified the Passive Simplify process Minimizing hazard Passive Simplify through equipment design Minimizing hazard Passive Simplify through equipment design Minimizing hazard Passive Simplify through equipment design .Reduced inventory Inherent Minimization through the elimination of tanks e Elimination of Inherent Simplify tankage that could have caused an hazard General Chemical — No neve inherently Bay Point safer systems implemented this year Page 10 of 18 Industrial Safety Ordinance Annual.Deport November 4, 2003 Polychemie Substitute less Inherent Moderate hazardous chemical of a more hazardous chemical Shell Martinez Elimination of Inherent Simplify, Refinery unnecess i in Minimization Decommissioning Inherent Minimization unused piping Tesoro Golden Piping Passive Simplify Eagle Refinery modifications Upgrading piping Passive Simplify metallurgy capable of withstanding the highest temperature and pressure scenario Reduction of Inherent Minimization inventory by eliminating _iping Deduction of Inherent Minimization inventory by eliminating piping Piping Passive Simplify modifications Installing vessel Passive Simplify capable of withstanding a higher pre§sure Deduction of Inherent Minimization inventory by eliminatina piping Installing equipment Passive Simplify designed to withstand the highest expected pressure Removing Passive Simplify contaminants from the system to eliminate hazard to downstream units without an active device Process that runs a Passive Simplify lower pressure and temperature Page 11 of 18 Industrial Safety Ordinance Annual Report November 4, 2003 Intermediate storage Inherent Minimization reduction Siting of equipment Passive Simplify away from occupied buildings Designed for lower Inherent Moderate pressure steam Design was able to Inherent Simplify, eliminate a second Minimization distillation tower Used lower P'ass'ive Simplify temperature heating media 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 September 27, 1997 Contra Costa County guideline for the Community Warning System as determined by Contra Costa Health Services; or results in the release including, but not limited to, air, water, or soil of a regulated substance and meets one or more of the following criteria: 1. Results in one or more fatalities 2. Results in greater than 24 hours of hospital treatment of three or more persons 3. Causes on and/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 Service 4. Results in a flammable vapor cloud of more than 5,000 pounds The regulated stationary source is required to submit a report to Health Services thirty days after the root cause analysis is complete. The record of the major chemical accidents or releases that have occurred within the last year and the status of each of these incidents investigations are included in Table IV. Page 12 of 18 t rfs o -71 ' CU �C7 C M i� tiq y I Ota Pw i ( d Q cn coo a "C 'C� ++ +- tap•. T3 Gly 45 -08 o C) Scar+ d7 i vw a a� Q .14 rA 00 ch 1 a, a Industrial Safety Ordinance Annual Report November 4, 2003 Major Chemical Accidents and Releases Health Services has analyzed the Major Chemical Accidents and Releases (MCAR) that have occurred since the implementation of the Industrial Safety Ordinance. The analysis includes the number of MCAR's and the severity of the MCAR's. Three different levels of severity were assigned. • Serious---A fatality, serious injuries,or major onsite and/or offsite damage occurred • Medium—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 • Minor—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 MCAR's from January 1999 through September 2003 for all stationary sources in Contra Costa County MCAR's, the MCAR's that have occurred at the County Industrial Safety Ordinance stationary sources, and a chart showing the MCAR's that have occurred at the County and the City of Richmond Industrial Safety Ordinance stationary sources. The charts also show the number of serious, medium, and mirror MCAR's for this period. NOTE: The charts do not include any transportation MCAR's that have occurred. x # f ' g ' i--4- 1C3t�t1 MCAFts 8 -�—Serious i i! Medium _ ' . ;t+E—Minor k E 99 Page 14 of 18 Industrial Safety Ordinance Annual Report November 4, 2003 igQ1,11111 � s 5� St i—To#al MCAS „ 0-aTotal MGAR i—Serious fp Serious Medium Medium —X Minor W Minor � 4 Y � f 9 q9Y ��W+ x c �,, v' ^'k."' '� � $�� ni: �• `�m a T' Y �..: ���%�<. ! : r���f!�1 "�Y+ �t y k� uy�. u^2 ,y, ✓°� `�, ,€. ,:L `, s3 Legal Enforcement Actions Initiated by Health Services As part of the enforcement of the Industrial Safety Ordinance and the CalARP Program, Health Services 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 .health Services. Health Services 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 Specialist use to enforce the ordinance, the position of the Hazardous Materials Ombudsman, and to cover a portion of the overhead for the Hazardous Materials Programs. The fees charged for administering this ordinance for the fiscal year 2002—2003 is $200,376. 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, worked with the consultant that was hired for public outreach on the ordinance, performed audits of the stationary sources for compliance with both the California Accidental Release Prevention Program and Industrial Safety Ordinance and did Page 15 of 18 Industrial Safety Ordinance Annual Report November 4, 2003 follow-up work after a Major Chemical Accident or Release. The following is a breakdown of the time that was spent on the Industrial Safety Ordinance: • Accidental Release Prevention Programs Engineers Time: 983 personnel hours or 0.49 personnel years n The audits take three weeps to perform for a total of 1208 hours. Approximately 1/3 of the time is dedicated to the Industrial Safety Ordinance for a total of 403 hours. • It took approximately four weeks (160 hours) of work for preparing and giving public presentation for the different Safety Plans and preliminary audit findings. o Reviewing resubmitted Safety Plans took approximately four weeks (160 hours) to complete. • Working with the Hazardous Materials Commission and the Public and.. Environmental Health Advisory Board on proposed amendments to the Industrial Safety Ordinance took approximately 120 hours. o Preparing reports to the Board of Supervisors took approximately 100 hours. a Review and meeting with stationary sources on Root Cause Analysis Reports took approximately 40 hours. • Consultant of public outreach and preparing for public meetings took 1000 hours. • Total of 1983 hours is the approximate personnel time spent on the Industrial Safety Ordinance or 0.99 personnel years. This is not including the ombudsman time spent helping prepare for the public meetings, working with the engineers on questions arising from the Industrial Safety Ordinance, hiring and overseeing the work that was performed by the public outreach consultant, and answering questions from the public on the Industrial Safety Ordinance. Comments From Interested Parties Regarding the Effectiveness of the Industrial Safety Ordinance No Public comments outside of the public meetings have been received on any Safety Plans, Preliminary Audit Findings or the overall effectiveness of the Industrial Safety Ordinance in the last twelve months. 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 by Health Services, and the Industrial Safety Ordinance administered by Health Services. Each of the programs is very similar with differences in each of them. 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: • The number of chemicals regulated • The threshold quantity of these chemicals Page 16 of 18 Industrial Safety Ordinance Annual Report November 4, 2003 • An external events analysis, including seismic and security and vulnerability analysis, is required • Additional information in the Risk Management Plan • Health Services is required to audit and inspect stationary sources at least once every three years • The interaction required between the stationary source and Health Services. The differences between the CalARP and the 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 process at the regulated stationary source are covered • The implementation of a Human Factors Programs All of these requirements will and have made a changes in the probability of an accident occurring. The revised Guidance Document for Inherently Safer Systems will reduce the overall hazards at the stationary sources that will reduce the probability and the impact of having a Major Chemical Accident or Release. General Chemical Richmond Works Safety Evaluation The City of Richmond, Health Services, and the Board of Supervisors were concerned about the overall safety of the General Chemical Richmond Works facility and asked for a third-party safety evaluation of this site. General Chemical agreed to the safety evaluation. An oversight committee was formed consisting of General Chemical management, General Chemical employee union, the City of Richmond, Health Services, the Hazardous Materials Commission, and a representative from the community. The oversight committee developed the scope of work and a request for proposal and selected a third-party to perform the evaluation. MRS Environmental was hired as the third- party consultants to perform the safety evaluation. MRS conducted a Safety Climate Survey that was developed by the Health and Safety Executive from the United Kingdom. They did an onsite evaluation, held two public meetings to receive comments and questions from the community, submitted a draft report and a final report, and made oral presentation to the Board of Supervisors and the Richmond City Council. General Chemical has developed an action plan to address all of the recommendations and findings from the safety evaluation. MRS has reviewed their action plan to ensure that the actions being taken by General Chemical is addressing the findings from the safety evaluation. MRS has been hired to oversee the implementation of the General Chemical action plan, perform a second Safety Climate ,Survey, and to do an onsite follow-up evaluation at General Chemical Richmond Works. The survey has been completed, the onsite evaluation is scheduled for the week of November 10, and reports and presentations will be given to the Richmond City Council and the Board Supervisors in early 2004. Page 17 of 18 Industrial Safety Ordinance Annual Report November 4, 2003 Health Services Proposed Changes in the Risk Management Chapter of the Industrial Safety Ordinance Health Services gave the following recommendations to the Board of Supervisors in a report on March 18, 2003 on proposed changes to the Industrial Safety Ordinance that would improve the overall prevention of accidental releases. Below is a recapping of the report that was given at that time on the proposed changes. • Expand the Human Factors section of the Industrial Safety Ordinance to include the following: o Maintenance procedures • Management of Organizational Changes ■ Maintenance personnel ■ A job task analysis for each of the positions that work in operations, maintenance, and Health and Safety • Include temporary changes in the Management of Organizational Change • A requirement that the stationary sources perform a Security and Vulnerability Analysis and test the effectiveness of the changes made as a result of the Security and Vulnerability Analysis • The stationary sources perform a Safety Climate Assessment A copy of this section of the report is included in Attachment D. Public Review Process for Proposed Changes Health Services has worked with the Public and Environmental Health Advisory Board (PEHAB) and the Hazardous Materials Commission on the proposed changes. Some modifications and clarifications were made to the original proposal. PEHAB has endorsed the proposed Health Services amendments to the Industrial Safety Ordinance. The Hazardous Materials Commission did not have a quorum of yes votes to endorse the proposed amendments. A quorum is seven votes the vote was six yes votes and two abstentions. The Hazardous Materials Commission will consider this item at their next scheduled meeting in December. City of Richmond. Industrial Safety Ordinance The City of Richmond passed their version of the Industrial Safety Ordinance on December 18, 2001 that became effective on January 17, 2002. Richmond's Industrial Safety Ordinance mirrors the County's Industrial Safety Ordinance. Richmond's Industrial Safety Ordinance covers two stationary sources: Chevron and General Chemical Richmond Works. Chevron and General Chemical Richmond Works have submitted their Safety Plans to Health Services that have been reviewed by Health Services. Health Services opened up the Safety Plans for public comment. The public comment period is scheduled to end on November 24, 2003. A report was given to the City of Richmond on their Industrial Safety Ordinance on October 28, which included a report of the Safety Plans for Chevron and General Chemical Richmond Works. A second meeting is scheduled for November 18 to discuss the Safety Plans for these two stationary sources at the North Richmond MAC. Health Services have completed the second CalARP Program and the initial Industrial Safety Ordinance audit for these stationary sources. Page 18 of 18 ATTACHMENT A REPORT ON PUBLIC OUTREACH KAT.N ENCINEERMG 92E 754 eSZ4 10J2 ,fOS 12:L4pm P, 002 TIN ENGINEERING CONSUL TING P.0.Bax 4721 Antioch,CA 94531-4727 (923)755-1130 fax; (925)734»8524 ria' atm May 31,2003 Mr.1. wis G.Pascalb,Jr.,Esq. Director Contra Costa Hazardous Materials Programs 4333 Pacheco Boulevard Martinez.,California 94553-2295 Subject: Report of Public Avis=e^;ss Training on the County Industrial Safety Ordinance Dear Mr.Pascalli: This is a report of the public awareness training provided to Contra Costa County during the period December 1,2002 tb rough May 31,2003 on the Industrial Safety Ordinance. The United States Environmental Protection Agency(US EPA)imposes some of the strictest emirer—mental regulations over companies operating in the United States. California has its own environmental agencies,including the California Air Resources Board(CARR),Regional Water Quality Control Board(RWQM),the Depattmelnt.of Toxic Substances Control (DTSC),and the Bay Area Air Quality Management District('BAAQM D),which are inclined to make environmental regulations in California.more stringent than the rest of the United States. There are six ecrl(I6)chemical plants and petroleum refineries in Contra Costa County that are subject to the California Accidental Release Programa(CaIARP). (A summary of the company names is included in Appendix A.) Heeding the concerns of the community,the Board of Supervisors approved the Industrial Safety Ordinance(ISO)in December 1998 making Contra Costa County the totiglzest location in the world for environmental health and safety regulations. The ISG}applies only to chemical plants and petroleum refineries located in unincorporated portions of Contra Costa County that use or manufacture extrwriely bmtdous chemicals its a quantity above a specified threshold amount. Them are seven compalaies in Contra Costa County that ue tender the jurisdiction of the ISO,including: 1. Conoco Phillips Refinery in Rodeo 2. Shell.Refinery in Martinez 3. Air Products at Shell Refinery 4. Tesoro Refinery in Concord S. Air Products at Tesoro Refinery 6. General Chemical in Bay Point 7. Polyclle nie in Bay Poirot kAT I N ENG I NEER I NG S25 7E4 6S24 10?2a lb3 12:04pm P. ZOS Mr. Lewis G.Pascalls,Jr.Esq. May 31,2073 Public Awareness Training on the County IndunE al Safety Ordinan t Page 2 A map indicating the approximate location of these seven facilities is included in ikppe sciix 1'3. The goals of the Industrial Safety Ordinance(ISO)are: • Prevent accidental release of hazardous chemicals • Improve accident prevention by soliciting participation from industry and the community r Require industry to submit a Safety flan • Conduct audits of the Safety Plans and inspections of the industrial plants • Seek public comment on the Safety Plan A previous contract was issued by Contra Costa County to conduct a}pilot public awaresness- training program and obtain public comment on the Safety Plan submitted by Conocophillips Refinery. The contract was issued to the Paper,Allied-Industrial.Chemical&Energy Workers International Union(PACE)to conduct this training between September 2001 and April 2002. Their approach was to conduct one training session at one central location in Contra Costa County. Isdeeting attendance was not as sucomW as expo RESULTS CSF PUBLIC AVVA.RI� SS LR_AININC As a result of the knowledge gained by the public awareness training pilot program,my company took a new approach. From December 1,2002 through April 31,2003 we conducted community awareness training for the remaining six companies under tine jurisdiction of the ISO. Our approach was different dm that taken by PACE. We elected to hold multiple small meetings with the public in their own familiar surroundings. We contacted over 135 social,service,civic,church, school,and residezttW organizations, To aid in publicizing these meetings,the organizations were provided an attractive,eye-catching flier for their use. See Appendix C. Our program consisted of a 20-minute PowerPoint color slide pxesentation followed by a ten-minute question and answer sesskm. Also included was a showing of a National Cceanographic and Atmosphere Administration(NOAA)"fixed station weather radio"and a brief demonstmdon to show the public how they would hear an alert and how they could be advised of a chemical emergency. County and Community Awareness&Emergency Response(CAER)handouts on the"Community Warning System"and"Who Should You Call About Environmental Pollution in Contra Costa County"were distributed at the community meetings. We generated a directory of important phone numbers that could be used as a bandy reference for the public and these were also distributed. A copy of all three of these handouts is enclosed as Appendix D. Since the contract did not include ConocroPhiltips,the remaining six companies under the jurisdiction of the ISO were discussed in three separate presentations,which focused on companies in three geographical locations. The first set of meetings wus held in the Bay Point arta to discuss General Chemical and.Polychemie. A second set of meetings was held in the Concord area to discuss Tesoro Refinery and the Air Products plant located there. A third set of meetings was held in the Martinez area to discuss Shell Refutery and the Air Products plant located there. A copy of the Concord area PowerPoint presentation slides is included in Appendix E. As indicated in the presentation slides,I offered to meet with individuals,answer questions,and assist in providing feedback to this County after they reviewed Safety Plans. Throughout the six-month contract over 800 people were reached. To ensure that the Spanish speaking population in the County was reached,multiple presentations were made in Spanish. My PowerPoint slides were translated into KATIN ENGINEEPENG 926 Ica eS24 10/29r'QS 12:e4pm P. Oe4 Mr.Lewis G.Pascalli,Jr.Esq. May 31,2003 Public Awartness Training on the C".ounty Industrial Safety Orditlame Page 3 Spanish,and an interpreter was present to translate my comments,audience questions,and nay responses, Appendix.it is an example of two fliers that were distributed to the community for two of the presentations conducted in Spanish... In fact,one Environmental Spanish Foram was attended by approximately 85 people,during which two television crews were present,CCTV and a Spanish television.channel,Channel 49 Telemundo. A summary of the 135 different organizations that were contacted is included in Appendix G. Appendix 14 is a 42-page list of contacts that were made to more than 800 people. Some of the contacts did not result in meetings,however,729 people attended 67 meetings. The list of contacts made includes phone munbers,facsimile numbers,mailing addresses,and e-mail addresses. it allow for subsequent communication with the interested members of the community. A. compilation of 236 questions/comments raised during the presentations is enclosed as Appendix 1. The questions,raised were organized into 7 categories and made into an 180 Frequently Asked Questions(FAQs)section of the County Internet website. Contra Costes:Television(CCTV)made an in studio taping of the public presentation_ It was aired on CCTV ten(10)tunes between April 9 and May 17. Specific air dates and times are listed in Appendix J. The County made the announcement of public forums for final meetings scheduled for the three general geographical locations tW corresponded to the lotion of the industrial facilities. Information was promulgated on CCTV and in two newspapers,the San Francisco Chronicle and the Contra Costa Times. It was also advertised on the County website(cchealth.org), The County also seat a mailer to all attendees of previous community meetings. A copy is enclosed.as Appendix K. The three locations were: • Ambrose Community Center in Bao Point at 7 PM on May 1,2003(far General Chemical and Polychernie) • Pacheco Community Center in Pacheco at'7 P-M on May 6,20013(far Tesoro Refinery and the Air Products plant at Tesoro) • Martinez City hall Council Chambers in Martinez at 7 PM on May 8,2003(far Shell Refinery and the.Air Products plant at Shell) The announcement also listed the 45-day public comment period that ended on May 27,2003. As a result of the newspaper announcement,fduriournal3ists contacted me: * Peter Felsenfeld of the Contra.Costa Times • Leo Wallach of the Bay Cities News • Elizabeth Ball of the Richmond News Gszctte • Lupita Sigueiredo of Channel 48 Telemundo The format of the three final meetings was different than the community group presentations in order to provide variety and an opportunity for the public to address their questions directly to industry and the County. Instead of my 20-minute PowerPoint presentation with a subsequent question and answer period,a panel discussion was held, As Moderator,I began the presentation with a Met PowerPoint presentation of the ISO. Panelists were the industrial facility representatives and the County Hazardous Materials Program accidental release prevention engineers responsible for overseeing industrial facilities that were invited. The seven;panel KA`rtN ENGtNEERMG 926 7=54 6S24 2tL?26r'Qv 3'2,C4prr. P, 000 Mr..Lewis G.Pascalli,Sr_Psq. May 31,N63 Public rtwarenese Training on tlfe Cotenty Industrial Safety Ordinance Page 4 queslions were developed in 8 discussion with County staff based on questions raised at the 20 minute PowerPoint presentation. The panel questions were distributed to the panelists in advance. A copy of the questions is enclosed as Appendi% ;... Tables were set up as an Open Home and panelists were invited to display and provide any handouts they desired. A copy cif the agenda is enclosed as Appendix'1. To facilitate public participation,my display table held copies of the agenda,panel questions,a form for audience questions,and a meeting critique farm. I also had a supply of my business cards available in case attendees had questions arise subscqlent to the meeting. An announcement was made during the meeting to publicize my availability to answer questions regarding Safety Plans and provide assistance in generating feedback to the County. A total of fifty(50)pule attended the three final meeting paml discussions. A summary of the audience survey from the three panel discussions is enclosed as Appendix N. LESSQM LEARNED The final public meetings were not as well attended as the small community presentations. To ensure a better turnout,more advertising is required. This includes newspapers,radio,and a flier that quid be included with utility bills. For fliers to be effective,they must be short and visually attractive. A full-page text announcement is too long and wordy, The public will not spend the time to react it. There must be an eye-catching picture or a good headline. Participation is enbwwed by scheduling multiple-snrrall meetings and conducting them where and when people regularly attend(e.g. service,social,fraternal,community,school groups). People are more comfortable attending a meeting when they are familiar with the location and know other attendees. Even though it may be the morahly club meeting,participation was improved by providing a brief:,eye-catching flier to the organization.coordinator to use for publicizing the meeting. The beast-attended presentation was when a meal was provided at no cost to these attending. Partnering with organizations improved audience atterdance. The best attended presentation was held in conjunction with the Bary Point Partnership for the Public's Health. The request to schedule presentations was made individually by personally contacting organizations by phone. Although not all organizations contacted agreed to schedule a meeting,the personal touch of the phone call resulted in more positive responses than an anonymous., impersonal fax or letter. Keeping the presentation to less than one hour is critical to increasing attendance and uuaintaining the audience's attentioti. Although a ones-hour presentation will not make the pubhc experts in ISO nor allover them to critique a Safety Plan,it does however,give the community a much better indoctrination to ISO. Most people aged satisfied with.the 20-minute PowerPoint presentation followed by a ten- minute question and answer period. While i was able to subsequently address individual questions received by e-mail and phone calls,requests for group tours of facilities and detailed revielx of a specific facility's safety plans would require additional time not available in this contract. KATIN ENGINErEP'rNG 5.25 754 5524 10r2s/os izic4pm P. oeE W.Lewis G.Pasmlli,Jr Esq. May 31,2003 Public Avvueness Training on the County Industrial Safety Ordinance Page 5 A summary of Lessons Learned includes: i More advertisement is required for public forums. + Utilize all means of advertising (newspapers,radio,and a flier inserted with utility bills.) • Fliers must be short and visually attractive. + Fliers must be eye-catching(use a picture or a good headline), * Attendance is best at small meetings of service,social,fraternal,community,and school groups. + A brief,eye-catching flier allows an organization to publicize the meeting. • Attendance is improved when free food is provided. • Attendance is improved when meetings am held in conjunction with other groups. • Most people are satisfied with a short 20 to 30-minute presentation. + Special presentations require additional funding to coordinate + The personal touch of a phone call improves requests to conduct presentations. RECC�M--MFNI�ATI�I�� Contra Costa residents live in a heavy industrialized location. They are vocal regarding items that affect their health and do not distinguish amongst chemical plants and petroleum refineries. They do not distinguish between facilities under the jurisdiction of the ISO or not. `whenever there is a chemical release or accident at one of the plants,there is a public outcry. It is rec inmended that the County be more pro-active, Contact has been established with the community as a result of this project. It rvouJd be beneficial to both the County and the community to continue public awareness so that the effect of a minter event is not blowy out of proportion, The oontract expired just as public interest was beginning.to build. The public presentations should be expanded to include the entire County,not only the"industrial corridor"surrounding the six companies for which this contract was initiated. Multiple requests were made for presentations in the Rodeo and Richmond areas. Many attendees asked for presentations on.facilities not included in the ISO. In addition to public presentations,the County may want to consider a monthly or quarterly newsletter be distributed in order to build on the public interest that has been initiated through this contract, A one-page flier would keep the public informed on a regular basis and provide a point of contact so that they felt they could contact someone,if they had an environmental or industrial facility question., A database has been generated to facilitate communications. If the database is not maintained,the contact information may degrade. Rather Than wait for a crisis to occur, keeping the public regularly informed may benefit all concerned. KATIN ENGI EEPING SZE 7S4 eSZ4 10/28/ea 12:e4pm F. 007 Mt.Lewis G.Pascalli,Jr.Esq, May 31,2003 Public Awareness Trainir<g on the Chanty IflE usaial Safety Ordinance Page 6 A summary of recommendations includes: • The County should cmtinure public awareness training so that the efted of a minor event is not blown out of proportion. • Public outreach presentations should be expanded to include the entire County. Multiple requests were made for presentations in the Rodeo and Richmond areas. Many attendees asked for presentations on facilities not included in the ISO. • The County should regularly distribute a newsletter to build public interest on the ISO. • The database of person contacted should be maintained to facilitate communications. LC3 ING QQMME. Chis success was due to excellence in public speaking,use of good visual aids, and years of industrial and enviromental experience. By engaging the audience though question geared to promote group participation;attendees left the meetings with the benefit of knowing how to recognize a oh mueal release and what safety steeps they should take. Rather than lave a 1 wring lecture,the meeting format included a multi-media brief presentation followed by a question and answer period, Our technical expertise enabled us to respond to audience questions. Replies were not only technically correct but also understandable through use of everyday examples. To sura up,I am a local.Contra Costa County resident and:businessman. i am a licensed chemical professional engineer(PE)with approximately 30 years of industrial experience,own an engineering consulting and training company,and my company is a Disabled Veteran Business Enterprise(DVBE). We would be pleased to support the County in any engineering, environmental consulting,or public training needs. Sincerely, U ;Z;kL Robert A.Latin,PE Principal ATTACHMENT B HAZARDOUS MATERIALS OMBUDSMAN'S REPORT Hazardous Materials Ombudsman Evaluation for the Year 2003 I. Introduction On July 15, 1997 the Contra Costa County Board of Supervisors authorized 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, 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. 1) Continuing an outreach strategy so that the people who live and work in Contra Costa County can know about and utilize the program. 2) Investigating and responding to questions and complaints, and assisting people in gathering information about programs, procedures, or issues. 3) Participating in a network of environmental programs for the purpose of providing technical assistance. This evaluation covers the year 2003 for the Hazardous Materials Ombudsman program. The effectiveness of the program shall be demonstrated by describing that the activities of the Hazardous Materials Ombudsman meet the goals established in the Industrial Safety Ordinance. II. Program Elements 1. Continuing the Outreach Strategy This year, efforts were focused on continuing a maintenance-level of outreach. Copies of the Ombudsman Brochure were distributed to the public at meetings, presentations, public events, and through the mail. 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 Contra Costa Health Services web site.This page contains information about the program, links to other related web sites, and information about upcoming meetings and events. A toll- free phone number is still published in all three Contra Costa County phone books in the Government section. 2. Investigating and Responding to Questions and Complaints,and Assisting in Information Gathering A. Responding to Questions and Complaints This year, the Hazardous Materials Ombudsman has received 142 requests for assistance from the general public thus far, with an anticipated additional 28 by the end of the year. This would be an increase of 10%d over last year. Over 98 percent of these requests occurred via the telephone, and have been requests for information about environmental issues. 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 which 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 have been received via telephone and in writing. Persons that have made complaints via telephone have been also asked to provide those complaints in writing. This year, the Hazardous Materials Ombudsman received one complaint about activities or actions of the Hazardous Materials Programs. This complaint involved the County's response to a sewage spill and the role of the Hazardous Materials Programs Incident Responder in the response. The investigation determined that the Incident Responder took proper action and made proper notification in responding to the incident. B. assisting in Information Gathering Many of the environmental pollution issues that Contra Costa residents are concerned about are on-going regulatory programs or industrial activities. Helping people to participate in then;regulatory activities or to effectively advocate their interests about an industrial activity usually means providing them with more information or advice than can be dune with a single phone call. Often these issues are complex and can take months to resolve. Some of this is done through technical assistance, which will be covered in the next section. Another way of helping the public to gather information is to ensure the public has the opportunity to be informed about, and participate in, important decisions related to environmental protection. The Hazardous Materials Ombudsman has done this by organizing, promoting and facilitating public involvement in important hazardous materials issues. These are as follows. • Industrial Safety Ordinance Public Participation—The ordinance requires that public meetings be held at various stages of the process. The Hazardous Materials Ombudsman worked closely with the Hazardous Materials Programs staff and the Board of Supervisors to develop an intensive public outreach strategy for the Industrial Safety Ordinance. This effort was implemented in response to a community group's concern that there was not enough public involvement in the process.During 2001, a process was developed to create the type of public involvement desired and to hire an outside organization to conduct a pilot project in the communities surrounding the Philips refinery in Rodeo. This organization started the outreach program in November of 2001. This pilot program was completed in March of 2002. Based on the results of this pilot program, the Board of Supervisors directed the Hazardous Materials Ombudsman to hire and supervise an Industrial Safety Ordinance Public Participation facilitator to conduct outreach for six months to the remaining six facilities subject to the ISO.This position began work in December of 2002 and was continue to May of 2003. Presentations were made to over 700 people at over 60 public meeting as part of this outreach effort. The full report is attached. • Post- Chemical Incident Surveys —As a result of discussions held at a Protecting the Public conference in 1999, the Hazardous Materials Ombudsman took the lead in developing a telephone survey that would be administered to people in the area affected by a chemical accident.During 2001, funding was secured to develop the survey, a consultant was hired to create the survey, and the first survey was initiated after an incident at a refinery in October, 2001. In 2002, four additional surveys were conducted after level 2 and 3 incidents at facilities. In 2003 two additional surveys were completed after level 3 incidents, one at a refinery and one resulting from a railroad incident. The results of these surveys are being used to help improve the community outreach program for the Community Warning System. The Hazardous Materials Ombudsman also led the effort to develop a base-line survey that was administered county-wide in July, 2003 to evaluate residents knowledge of the Community Warning System. The results of this survey is also being used to help improve the community outreach program for the Community Warning System.The survey results can be used to treasure changes in the effectiveness of the outreach program by comparing these results to the results of future surveys. • Laotian Telephone Ring-down Project--As a result of a major fire at a refinery in Richmond in 1999, the Laotian community in the Richmond area was concerned about the lack of understanding of many Laotians about the Community Warning System and what to do in the event of a release.They requested the County to develop a way to send the automated telephone ring-down system message,which is part of the Community Warning System,to Laotian households in four Laotian languages. The Hazardous Materials Ombudsman worked with the Director of the Hazardous Materials Programs and the Laotian Organizing Project to develop this program. In 2001, $140,0010 of funding was secure to implement the project and a project coordinator was fired. In 2002 the Hazardous Materials Ombudsman hired 4 outreach staff and supervised all 5 staff people to implement this program. The pilot project was completed in Spring of 2003. At the direction of the Board of Supervisors, the Ombudsman is now participating in the evaluation of a new technology to provide automated telephone alerts in various languages. The Ombudsman has hired 2 Laotian staff to test this technology in 1010 Laotian homes. This pilot is anticipated to be completed in early 2004 at which time the two methodologies can be compared. Bay Area Air Quality Management District Workshops and Activities—In 2003, the Air District held a number of public meetings in Contra Costa County about the issues of developing a refinery flare measurement rule and updating the Bay Area's Ozone Attainment plan. At the direction of the Board of Supervisors, the Ombudsman assisted the Air District in the staging and public notification of these meetings. In addition, the Ombudsman assisted an organization called Community Focus in developing and implementing a community involvement project in the.Richmond area related to dissemination of information about the Chevron refinery's Title V air pollution permit. • Sierra-Crete---In May, 2002 the DuPont Company notified the County that a product they manufactured at their Oakely facility, sold as road bedding, and used under 36 miles of roads in east Contra Costa County, contained dioxins. Further, the roads where Sierra-Crete was used have extensively cracked and surface staining indicated that dioxins may have migrated to the road surfaces. From May to December of 2002 the Ombudsman assisted the Public Health Director in staffing a task force of government entities and members of the public to collect samples and conduct a risk assessment. In early 2003, the Ombudsman coordinated four public meetings to discuss the results of the risk assessment and take public comment. 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, as well as participate in other programs to be able to provide technical assistance to the participants and the public. • The Hazardous Materials Interagency Taskforce—This group of local, state and federal agency representatives meets every other month to share information and discuss issues of local importance concerning hazardous materials. This year the Hazardous Materials Ombudsman was the chairperson for this taskforce as they focused their efforts on sharing information about the site security and vulnerability programs being developed by various agencies. • CAER (Community Awareness and Emergency Response) -This non-profit organization addresses industrial accident prevention,response and communication. The Ombudsman participated in the Community Outreach and Emergency Notification sub-committees of CAER. The Ombudsman helped to develop and hosted a CCTV half hour presentation on the Community Warning System. • Hazardous Materials Conunission—In 2001, the Ombudsman took over as staff for the commission. In 2003,the commission focused its efforts on 2 issues - a review of the proposed amendments to the Industrial Safety Ordinance (ISO)by the Hazardous Materials Programs, and further development of the County's Environmental Justice Policy. As staff to the commission,the Ombudsman conducted research,prepared reports,staffed Commission meetings, and presented the Commission's recommendations to the Board of Supervisors. The Ombudsman hired and supervised an Environmental Justice analyst who began in March, 2002. She assisted County Departments in their efforts to implement the County's Environmental Justice Policy. This effort was completed in the spring of 2003, and a report was presented to the Board of Supervisors Ad Hoc committee on Environmental Justice. • Public and Environmental Health Advisory Board—As staff to the Environmental Health subcommittee of PEHAB, the Ombudsman completed a report on pest management issues in the County in March, 2001. In response to this report, the Board of Supervisors asked Health Services and the County Agricultural Commissioner to convene a Task Force to develop an Integrated Pest Management Policy for the County. The Ombudsman represented Health Services as co-chair of this Task Force. The policy was adopted by the Board of Supervisors in November of 2002. During 2003 the Ombudsman continued to represent Health Services on the Task Force as they began to implement the policy. In March, 2003 the Board of Supervisors asked PEHAB to analyze and develop recommendations on proposed amendments to the Industrial Safety Ordinance made by the Hazardous Materials Programs. The ombudsman led the Environmental Health Subcommittee through a rigorous review of the proposed amendments and presented their recommendations to the full board. These recommendations will be heard by the Board of.Supervisors when they review the proposed amendments. In addition to working on the pesticide issue and the review of the proposed amendments to the Industrial Safety Ordinance, the Ombudsman continued to track the development of several other issues for PEHAB.These issues were the Association of Bay Area Governments' efforts to develop dioxin reduction guidelines for Bay area cities, the State Department of Health Services' efforts to coordinate educational efforts about consumption of contaminated fish, and the Bay Area Air Quality Management District's review of the Ozone Attainment plan and development of flare measurement and control rules. • Asthma Management Team_The Ombudsman participated in the Public Health Department's asthma management team as a resource on environmental health issues. The Ombudsman also conducted one training to 10 community advocates about refinery flares. The Ombudsman also participated in both county-wide and west- county asthma coalition meetings. • Partnership for the Public's Health—The Ombudsman served in a technical assistance capacity in 2003 for implementing the workplan for this public Health Department Program. The Ombudsman helped the program's community partners understand the technical issues related to refinery flares and ozone attainment as they prepared to put on a Town Hall meeting on these topics. The Ombudsman also presented a case-study at a PPH workshop on public participation. • Emergency Communications—Since the events of September 11, 2001 the County, as well as the rest of the Country,has focused more attention on being prepared for emergencies related to weapons of mass destruction and terrorists attacks. In 2003 the Ombudsman was asked to join Health Services' Emergency Management Team and to participate in monthly meetings of Health Services' emergency communications work group. The Ombudsman also facilitated a half-day conference on emergency medical services activities during chemical incidents and functioned as an official observer for a county-wide disaster drill. The Hazardous Materials Ombudsman also attended workshops, presentations,meetings and trai.nings on a variety of environmental issues to be better able to provide technical assistance to the public.These were sponsored the Federal Environmental Protection Agency, the State Department of Health Services, the Bay Area Air Quality Management District, the Metropolitan Transportation Commission and the Centra Costa Council. III. Program management The Hazardous Material Ombudsman continued to report to the Public Health Director on a day-to-day basis in 2003, while still handling complaints and recommendations about the Hazardous Materials Programs through the Health Services.Director.The duties of the Hazardous Materials Ombudsman include direct supervision of three contract employees and indirect supervision of four others--the Laotian telephone ring-down project coordinator(who supervises four outreach workers),the Environmental Justice Analyst, and the Industrial Safety Ordinance Public Participation Facilitator. In addition, the Ombudsman is still managing the contract for the Industrial Safety Ordinance Post- Incident surveys, which began in 2001. IV. Recommendations In 2003 the Ombudsman was very involved in the development and implementation of the public participation program for the Industrial Safety Ordinance. This proved to be a very successful program and is intended to be repeated in the Richmond area next year for the two facilities subject to Richmond's ISO. This position should be made permanent within the Hazardous Materials Program, and should be implement county-wide for the facilities subject to the ISO when their Safety Plans are due to be reviewed again. Another related function that merits permanent status within the Hazardous Materials Programs is a Public Information position that would interface with other County Departments and outside entities to plan for emergency response situations, and would coordinate the release of public information during chemical, incidents. V. Goals for 2004 In 2004, the Ombudsman will provide essentially the same services to Contra Costa residents as was provided in 2003. The Ombudsman will continue respond to complaints about the actions of the Hazardous Materials Programs; answer questions that come from the public and assist them in understanding regulatory programs, staff the Hazardous Materials Commission,the Public and Environmental Health Advisory Board, and the Hazardous Waste Interagency Task Force; provide technical support to the Asthma program and the Partnership for the Public Health; and participate in the Integrated Pest Management Taskforce, CAER committees, and the Health Services emergency communications workgroup. The Sierra Crete project was completed in 2003, and the pilot project for the telephone ring-down system should be completed in early 2004. The Ombudsman will continue to manage the contract for the post chemical-incident surveys, but the Industrial Safety Ordinance public participation program will be managed by the Hazardous Materials Programs as part of their normal activities. In 2004, the Ombudsman will re-distribute brochures extensively throughout the County, and will repeat a large number of presentations to community groups and governmental agencies to promote the existence of the service. ATTACHMENT C STATIONARY SOURCES ANNUAL REPORTS 8.o ANNUAL PERFORMANCE REVIEW ANIS EVALUATION SUBMITTAL (Period 1/15/99 - 6/15/03) Update Annually (June *.Attach additional pages as necessary Flue tent Denotes updates/revisions for June 2003,submittal x .Name and address of Stationary Source: Air Products Mfg Corp -Shell H2 Facility lio '(Waterfront Road .Martinez, CA 94553 2. Contact name and telephone number(should CCHS have questions): .Michael Cabral, (925)372-9302 3. Summarize the status of the Stationary Source's Safety Plan and Program (450-8.030(B)(2)(i)): The Stationary Source's Safety Flan is complete per CCHS requirements and submitted to CCHSfor review. The Program has been implemented, as required. 4.Summarize Safety Flan updates(i.e.,brief explanation of update and corresponding date)(4 0-8.030(B)(2)(ii)): .Date. 26 June 2003 Summary:Annual Performance Review=and.Evaluation Submittal Update. Date: 14 June 2002 Summary:Annual Performance Review and Evaluation Submittal Update, Entire ISO Safety Plan submitted with changes initiated by.Human Factors and ISS audit. Date: 22 May 2001 Summary: Added human Factors Information in response to county deficiencies audit Date: S January 2001 Summary: Added human.Factors Information Late: 4 January 2001 Summary:Annual Accident History Update Date:4 January 20o0 Summary:Annual Accident History Update Date: 15 June,2000 Summary:Annual Performance Review and Evaluation Submittal Update .Date: 3o December,1994 Summary:Initial plan as required by Contra Costa County. 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(450-8.03o(E)(2)(ii)): • CCHS Office, 4533 Pacheco.Boulevard Martinez; local library closest to the stationary source('after CCHS states that the Safety Plan is complete) • Air Products--See contact in #2, above b. Provide any additions to the annual accident history reports(i.e.updates) submitted pursuant to Section 450-8.os6(E)(2)of County Ordinance 98- 48 (450-8.030(B)(2)(iii)) (i.e.,provide information identified in Section 450-8.oi6(E)(i)for all major chemical accidents or releases occurring between the last accident history report submittal(January 15)and the annual performance review and evaluation submittal(June 30)): None 7. Summary of each Root Cause Analysis(Section 450-8.o16(C))including the status of the analysis and the status of implementation of recommendations formulated during the analysis(450-8.03o(E)(2)(iv)): On of/lo/ol a fire occurred on a Nalco Portafeed installation at the Martinez Shell hydrogen facility.There were no injuries resulting from the fire, and no production curtailments,but the fire caused extensive damage to the chemical feed unit. The incident was thoroughly investigated by Nalco, and their detailed report is attached. Facilities using this type of equipment should ensure that their installation does not have the same potential for failure. The facility changed the amine product from CA 357 to Y 382 in the September/October timeframe of last year,to gain significant savings. The Y 382 is a generic 99% MEA solution and is much less expensive than the CA 357. The chemical is stared in a Nalco 400 gallon portafeed tank, which itself is housed in a containment tank. Chemical is delivered to the process using a small metering pump. The system worked well until the ambient temperature dropped, and the chemical started to freeze. MSDS shows the freeze temperature to be 5o deg F. A tank insulation and heating package was purchased from Nalco, and installed in December according to vendor instructions. Electrical heat tracing was installed on the suction and discharge piping of the metering pump in early January. The Nalco supplied heat tracing package included a power connection kit, which,when installed was situated in the lower part of the tank.This kit is rated for outdoor use,but should not be submerged. It appears that heavy rains created a level in the containment tank,which submerged the connection kit, causing a short. The resulting flames ignited the MEA solution that had been absorbed into the insulation,presumably from spillage during several re-filling operations. The fire was extinguished using a nearby fire monitor. Action items from this incident include; 1) Investigate using diluted MEA in future, which has lower freeze point. Meanwhile use steam hose in base of containment tank to keep product warm. 2) Nalco to inform other customers of this incident. 3) Carry out RCA with the site team. The root cause analysis was performed by John Cheater, Eddie McDonald, Otis Pleasant, Jason Redlin, and two Nalco employees. The cause of the accident was determined to be the termination unit being immersed in water and catching the MEA-soaked insulation on fire. The solution was to use 85%MEA which does not require insulation. Repeat situation is not likely. 8. Summary of the state of implementation of recommendations formulated during audits,inspections,Root Cause Analyses, or Incident Investigations conducted by the Department(450-8.030(EI)(2)(v)). ..Plant has switched to using 85%MEA. Insulation is no longer required. No fuel for afire. 9. Summary of inherently safer systems implemented by the source including but not limited to inventory reduction(i.e.,intensification)and substitution(450-8.03o(B)(2)(vi))s • Plant uses aqueous ammonia rather than anhydrous ammonia in its emission control system. This helps reduce the off-site consequence of an ammonia release. • Plant is designed without a liquid hydrogen backup system. This reduces the inventory of hazardous chemicals on-site. • Plant switched from 99% monoethanolamine to 85% monoethanolamine in order to eliminate the need for insulation around the water treatment tanks. This reduces the potential for afire. xo. 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 (450-8.03o(E)(2)(vii)): CCAS issued a Preliminary Determination Report on July 17,20o2, based on a Human Factors(IIF)and Inherently Safer Systems(ISS)audit/inspection of the AP Mfg Corp. at Shell Martinez Refinery(SMR). AP Mfg Corp has completed the action items identified in the Preliminary.Determination. CCHS also issued a Final.Determination on October 4,2oo3, based on the Unannounced Inspection at AP Mfg Corp.facility at Shell Martinez Refinery. AP Mfg. Corp, has completed the action items identified. A notice of deficiencies ciencies report was issuedfor r aur submission of the Human.Factors Program. Our program meets the requirements put forth by the county, but is not documented appropriately. Changes to our documentation were made. ii. Summarize total penalties assessed as a result of enforcement of this Chapter(450-8.030(3)): No penalties have been assessed against any facility 22.Summarize the total fees,service charges, and other assessments collected specifically for the support of the ISO(450-8.03o(B)(4)): CaL4RP Program fees for these nine facilities are- $419,522. Risk Management Chapter of the Industrial Safety Ordinancefees are-$2748,841. CaL4RP Program fees for these seven facilities are-$339,342, Risk Management Chapter of the Industrial Safety Ordinance fees are-$38,114 13. Summarize total personnel and personnel years utilized by the jurisdiction:to directly implement or administer this Chapter(.450- 8.030(B)(5)): 40oo hours were used to audit/inspect and issue reports on the Risk Management Chapter of the Industrial Safety Ordinance. 35oo hours were used to auditf 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(450-8.03o(B)(6)). None 15.Summarize how this Chapter improves industrial safety at your stationary source (450-8.030(8)(7)). Air Products is committed to the safe operation of ourfacility and had already implemented most of the requirements outlined in the ISO, as well as the CaL4RP regulation. The Human Factors program is implemented,and should have a positive impact on the safety of the facility. This Chapter has helped reinforce the need to maintain and follow a structured safety program to help ensure the safety of our employees and the communities in which we operate. 16.List examples of changes made at your stationary source due to implementation of the Industrial Safety Ordinance (e.g., recommendations from FHA's,Compliance Audits, and Incident Investigations in units not subject to CaIARP regulations; recommendations from RCA's)that significantly decrease the severity or likelihood of accidental releases. Air Products has developed and implemented a Human Factors Program as required by the Industrial Safety Ordinance. The site clarified issues associated with the Management of Change for Organizational Changes at the site. 17. Summarize the emergency response activities conducted at the source (e.g., CWS or CAN activation)in response to major chemical accidents or releases: There were no emergency response activities to this site. 8.o ANNUAL PERFORMANCE REVIEW AND EVALUATION SUBMITTAL (Period 1/15/99 - 6/15/03) Update Annuallu (June) Blue text Demotes updates/revisions for June 2003 submittal i .Name and address of Stationary Source: Air Products Tract 1, Tesoro Refinery Solano Way Martinez, CA 94553 2. Contact name and telephone number(should CCHS have questions): Michael Cabral,(925)372-9302 3. Summarize the status of the Stationary Source's Safety Plan and Program (450-8.030(B)(2)(i)): The Stationary Source's Safety Plan is complete per CCHS requirements and submitted to CCHSfor review. The Program has been implemented, as required. q.. Summarize Safety Plan updates (i.e.,brief explanation of update and corresponding date) (450-8.03o(B)(2)(ii)): Date: 26 June 2003 Summary:Annual Performance Review and.Evaluation Submittal Update. Date:14 June 2002 Summary:Annual Performance.Review and Evaluation Submittal Update. Bate:31 May 2001 Summary: Corrections to Human FactorsPlan .Date: 4 January 2001 Summary:Annual Accident History Update Date:4 January 2000 Summary:Annual Accident History Update Date: 15 June,2000 Summary:Annual Performance.Review and Evaluation Submittal Update Date: 3o December,1999 Summary;Initial plan as required by Contra Costa County. 5. Lust 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(11)(2)(ii))s • CCHS Office, 4333 Pacheco Boulevard Martinez; local library closest to the stationary source(after CCHS states that the Safety Plan is complete) • Air Products -See contact in #2, above 6. Provide any additions to the annual accident history reports( .e.updates) submitted pursuant to Section 450-8.0:t6(E)(2)of County Ordinance 98- 48 (450-8.03o(B)(2)(iii)) (i.e.,provide information identified in Section 450-8.0:.6(E)(:t)for all major chemical accidents or releases occurring between the last accident history report submittal(January 15)and the annual performance review and evaluation submittal.(June 30)): None 7. Summary of each Root Cause Analysis(Section 450-8.o16(Q) including the status of the analysis and the status of implementation of recommendations formulated during the analysis(450-8.030(11)(2)(N))s No events triggered this requirement 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(El)(2)(v)): APCI has completed the action items identified in the July 17,2002, Preliminary.Determination on Human Factors(HF)and Inherently Safer Systems (ISS)audit/inspection audit report, and the action items identified in the October 4,2003 CCHS Final Determination Unannounced Inspection report. Notice of Deficiencies was submitted in June. To date,no action has been taken. 9. Summary of inherently safer systems implemented by the source including but not limited to inventory reduction (i.e., intensification)and substitution(450-8.03o(B)(2)(vi)): • Plant uses aqueous ammonia rather than anhydrous ammonia in its emission control system. This helps reduce the off-site consequence of an ammonia release. • .Plant is designed without a liquid hydrogen backup system. This reduces the inventory of hazardous chemicals on-site. i.o. Summarize the enforcement actions(including Notice of Deficiencies, Audit Reports,and any actions turned over to the Contra Costa County istrictAttorney's Office)taken with the Stationary Source pursuant to Section 450-8.028 of County Ordinance 98-48 C450-8.080(B)(2)(vii)). CCS issued a Preliminary Determination.Report on July 17,2oo2, based on a.Human Factors (HF)and Inherently Safer Systems (ISS)auditjinspection of the APCI at Tesoro Golden.Eagle Refinery. APCI has completed the action items identified in the Preliminary Determination. CCIS also issued a.,Final Determination on October 4, 2oo3, based on the Unannounced Inspection at APCIfacility at Tesoro Refinery. APCI has completed the action items identified. A notice of deficiencies report was issued for our submission of the.Human.Factors Program. Our program meets the requirements put forth by the county,but is not documented appropriately. Changes to our documentation have been made.. rt. Summarize total penalties assessed as a result of enforcement of this Chapter(450-8.030(3)): No penalties have been assessed against any facility 12. Summarize the total fees,service charges, and other assessments collected specifically for the support of the ISO(4.50-8.030(B)(4)): CaL4RP Program fees for these nine facilities are -$419,522. Risk.Management Chapter of the Industrial Safety Ordinance fees are- $2748,841• CaL4RP Program fees for these seven facilities are-$339,342, Risk.Management Chapter of the Industrial Safety Ordinance fees are-$38,114 18.Summarize total personnel and personnel years utilized by the jurisdiction to directly implement or administer this Chapter(450- 8.080(B)(5)h 4000 hours were used to audit/inspect and issue reports on the Risk Management Chapter of the Industrial Safety Ordinance. 350o hours were used to auditfinspect 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(450-8.08o(B)(6)), None 15,Summarize how this Chapter improves industrial safety at your stationary source(450w8.030(B)(7)): Air Products is committed to the safe operation of our facility and had already implemented most of the requirements outlined in the ISO, as well as the CaURP regulation. The Human.Factors program is implemented, and should have a positive impact on the safety of the facility. This Chapter has helped reinforce the need to maintain and follow a structured safety program to help ensure the safety of our employees and the communities in which we operate. :L6.List examples of changes made at your stationary source due to implementation of the Industrial Safety Ordinance(e.g., recommendations from PKA's,Compliance Audits, and Incident Investigations in units not subject to CaIARP regulations; recommendations from RCA's)that significantly decrease the severity or likelihood of accidental releases. Air Products has developed and implemented a human Factors Program as required by the Industrial Safety Ordinance. 17. Summarize the emergency response activities conducted at the source (e.g., CWS or CAN activation)in response to major chemical accidents or releases Where were no emergency response activities to this site. Annual Performance Review and Evaluation Submittal June 30, 2003 *Attach additional pages as necessary 1. Name and address of Stationary Source: ConocoPhillips Company —Rodeo Facility 1380 San Pablo Avenue Rodeo, CA 94572 2. Contact name and telephone number(should CCHS have questions): John Driscoll at(510) 245-4466 or Chris Bowman at(510) 245-4669 3. Summarize the status of the Stationary Source's Safety Plan and Program(450-8.030(B)(2)(i)). The Safety Plan for this facility was updated on March 18, 2002 with the Human Factor section included within the Plan instead of beim attached as an admendment It was submitted to the County for review and comment at that time. The County opened a public comment period which ran from April 15, 2002 to May 29, 2002 to solicit comments from the public on our plan. The County hired a consultant to establish an outreach program to work with the community to explain our plan and to assist community members in preparing comments about our plan. The consulting group held a train-the-trainer class for interested community members and then provided a class for interested community members on the plan and solicitating of cormnents. In addition a CCHS required public meeting was held by the County on May 9h 2002, at the Rodeo Senior Center to discuss our Safety Plan, the Preliminary Audit findings and the RMP. Only two community members attended that meeting. On 6124/02 the County forwarded comments, made by the public, to our plan. These public comments were reviewed in detail. Since a factual basis for these comments could not be substantiated they were not included into the plan. 4. Summarize Safety Pian updates (i.e., brief explanation of update and corresponding date) (450- 8.o30(B)(2)(ii)): The original Safety Plan for this facility was filed with Contra Costa Health Services on January 14, 2000. A revised plan was filed on April 7, 2000 with the updated recommendations requested by CCHS. A Human Factors Amendment was submitted on January 15, 2001. In conjunction with CCHSs required 2"d public meeting on our plan and audit findings we revised our Safety flan on March 18, 2002 to reflect the change in ownership of our facility and to update accordingly. We took this opportunity to include Human Factors within the plan instead of having it as an amendment. The Safety Plan for this facility will be updated whenever a new covered process is added or on a 3 years cycle from the last update (March 18, 2002). In addition, the accident history of this facility will be updated every year after the orginal submittal. This submittal serves as the 2003 update. 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)): CCHUffice 4333 Pah oo lev d Martin z C oc e odea ibrar 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 accident history report submittal (January 15) and the annual performance review and evaluation submittal(June 30)): There have been no MCAR s since the last report. 7. summary of each Root Cause Analysis (Section 450-8.016(0)) including the status of the analysis and the status of implementation of recommendations formulated during the analysis (450- 8.030(B)(2)(iv)): Listed are the updates on the root causes for the accidents listed in the 2002 submittal: On 5/31/O2 between 5:oo AM and Too AM a process upset occurred at the Hydrogen Purification section of the Unicracker Unit 240.A spray of liquid catacarb solution(spproximately 388 lbs)was released in the form of aerosol droplets to the atmosphere from the B-401 stack.Wind direction was SSW at 7-15 MPH. Solution was detected within the refinery and trace amounts were found on vegetation in the area immediately north of the refinery. CCHS and Phillips H/S staff found no evidence to indicate any health or significant off- site impact. There were no injuries reported. The 72 hour report and 3o day report were submitted. A root cause analysis was performed using Reason Software. That analysis indicates that several factors contributed to the foaming event in the D-409 Regenerator. Two of those factors are related to a new,improved filtering system that was installed for the Catacarb solution during the recent unit maintenance turnaround. The new filtering system included the addition of two large mechanical filters and a carbon filter while the old mechanical filter was kept as a post filter downstream of the new carbon filter. These changes were designed to reduce the corrosivity and foaming tendency of the Catacarb solution by removing more suspended solids (larger mechanical filter with spare) and removing hydrocarbon contaminants (carbon filter). One of the issues that arose during the design of the new filter system was whether the new carbon filter would also remove the antifoazn chemical WBU. The Catacarb process Licensor represented to Phillips that the filter would not remove this chemical. When contacted after this incident, the Process Licensor slid some additional research on the WBU and acknowledged that the filter could have this unwanted effect. The WBU has an active half-life in the solution of 24 hours and is injected continuously to maintain a calculated 1-3 ppm concentration in the circulating Catacarb solution. With the new filtering system removing some of the WBU(the filtering system is a slip stream of the total circulating solution—220 gpm out of 3500 gpm), the WBU concentration was lower than expected. RECOMMENDATIONS/PREVENTIVE MEASURES 1. Change the refinery policy on P&IDs to ensure that the normal operating condition is clearly identified on instruments that have options. Complete 2. Revise the D-409 differential pressure indication to read across the top half of the tower. Complete 3. Improve monitoring of the D-409 tower differential pressure and set clear expectations of actions to take if the indication shows foaming -including shutdown if necessary. Complete 4. Develop and implement procedures for downwind monitoring of the vent stack if foaming in D-409 is suspected. The procedure should include instructions to shut down if carryover occurs. Complete 5. Revise the antifoam injection rate to account for the amount removed by the carbon filter. Complete 6. Improve monitoring of the antifoam injection rate. Complete 7. Replace the filter element in the F-408 post filter with a 5 micron size element. Complete 8. Use the new WBU injection point in the rich solution to D-409. Complete Root Cause for the foss of Steam on 7/10/02 On 7/10/02 at approximately 3:36 PM The A turbine located at the Steam Power Plant unexpectedly shutdown. This was followed by an unexpected shutdown of the C Turbine. The refinery's other Turbine B had shutdown unexpectly earlier in the morning and was being prepared for restart. The refinery's other source of steam, the B-1 Boiler, had previously been taken out of service to complete Nox Reduction project work. The outage of all 3 turbines in this situation resulted in a refinery-wide lass of steam production. When this occurred, a plant wide shut down of all operating units was initiated in accordance with. procedures. Due to limited steam availability, the remaining steam was diverted to the Sulfur Recovery Units to prevent release of sulfur compounds. This resulted in a lack of atomizing steam for complete combustion from the refinery flare. A CWS level 2 was initiated and notifications were made to Rodeo/Hercules Fire Department, BAAQMD, CCCHSD, County and State CIES, CC Sheriff, Crockett/Carquinez Fire Department, and NRC. As a preccautionary measure Phillips requested a upgrade of the CWS to a level 3 Shelter in Place for the Crockett area only due to the smoke direction from the flare.. No injuries were reported within 24 hours of the end of the flaring event.A 72 hour report and 30 day report have been submitted. An incident investigation team was formed to determine the root cause. A root cause analysis was performed using Reason Software. The data indicates that the cause of the Turbines A and C shutdowns (at 3:36 PM and 3:42 PM, respectively)was a flameout of both turbines due to a quenching of the flames. The quenching of the flame can be caused by the introduction of steam or other cooling medium. Steam injection was not in use (system blacked in)and was eliminated as a potential cause. Physical inspection of the equipment revealed that the fuel gas manifolds on all three turbines are equipped with a float trap to handle condensable liquids in the gas stream. The individual traps are connected to hydrocarbon blowdown lines, which are combined and then routed to the relief system via the F-35 Blowdown Drum. The physical configuration of the piping allows for liquid in the lines. It appears that this liquid was back-pressured into the fuel ring on both the A and C turbines. This conclusion is supported by data indicating the following sequence of events occurred: o During the start-up activities of SPP Turbine B (subsequent to maintenance trouble-shooting),the Turbine B gas vent valve was opened to the blowdown header to clear the high gas pressure permissive. o The gas vent valve and the fuel gas manifold/trap piping connect to the same header line leading out of SPP B to F-35 Blowdown Drum. o The individual unit header lines join into a common Deader upstream of the F-35 Blowdown Drum inlet. o During this gas venting step, it appears that a plug formed in the common header line restricting gas flow to the drum and back-pressuring the entire blowdown header to -100 to 185 pounds per square inch (psi). The plug formation is consistent with the outside operator's observation of unusual noise in the relief header(flow through a small opening/restriction) o This back-pressure began forcing the liquid back into the fuel gas manifolds. With a turbine down, the fuel gas ring pressure is essentially atmospheric pressure (0 psi). When a turbine is on-line, the pressure is approximately 100 psi (as demonstrated during a July 26, 2002 post- incident test of the fuel gas ring). • The back-pressuring of liquid was preferentially toward the B turbine, which was off-line at the time (light-off had not yet commenced). However, some liquid was back-pressuring into both Turbines A and C, as noted in the dropping combuster basket temperature. o During light-off of the B turbine,pressure inside the fuel gas ring increases on B turbine (to — 100 psi). • With the three fuel rings(SPP A,B, and C) at essentially the same pressure,given some minor variations due to configuration and settings, more liquid was back-pressured into A turbine. o At this point,Turbine A flameout occurs. o Concurrent with the shutdown of SPP A,the light-off of Turbine B is unsuccessful. o The flow of liquid backward into C turbine decreases, as noted in the slight recovery of eombuster basket temperatures, when the SPP A unit drops offline and turbine B light-off is unsuccessful. At this point,fuel gas ring pressures are SPP A @—0 psi; SPP B @— 0 psi; and SPP C @� 100 psi. o Personnel begin start-up activities on A turbine. • Turbine A gas vent valve is opened during the start-up,compounding the gas flow issue into the blowdown header. More liquid is pressured into C turbine. • At this point,Turbine C flameout occurs. o All three turbines are offline. Steam production interrupted, The above scenario is consistent with all available process data, observations made by personnel involved in the incident, timeline of events, and post-incident testing to validate specific issues involved in the above conclusion. The approximate six (6)minute delay between flameouts of Turbine A and C coincide exactly with the opening of the subject gas vent valves. Primary Root Cause—Preventive Measures (Steam Loss): ♦ The refinery immediately addressed the rout cause of the incident through specialized training and installation of pressure gauges within the blowdown lines. Complete NNEDIATB PREVENnVE MEASURES (as communicated in the 72-hour report). ♦ At this time, B-1 Boiler has been brought back into service and is operating reliably. Alla turbines have been in service since the incident and are operating reliably. Complete ♦ We have reviewed and updated our steam loss contingency plan. Complete ♦ Formalized minimum steam cushion/reserve Complete 0 Reviewed revised procedure with all operations personnel Complete ♦ Updated our steam system monitoring program to include on-=line steam cushion/reserve calculation. Complete 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(11)(2)(v)): See Question 7 above for the implementation of the root cause analyses for the MCARs shown on the 2002 submittal. Action items resulting Brom the Human Factor/Inherently Safer System audit conducted in 20oi have been completed. 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)): Attached is a table ( starting on page 9 ) summarizing the PHA and engineering design mitigations items that were closed during the period form July 1, 2002, to June 15, 2003. Per CCHSs request a brief description of the inherently and passive risk control strategies that were implemented is included. 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(13)(2)(vii)): No enforcement actions were taken durin this time period. 11. Summarize total penalties assessed as a result of enforcement of this Chapter (450-8.030(3)): No venalities have been assessed against any facility. 12. Summarize the total fees, service charges, and other assessments collected specifically for the support of the ISO (450-8.030(B)(4)): CalARP Program fees for these nine-facilities are- $419,521 the Risk Rana ginent Chap1pr of the Industrial Saf=Ordinance fees are-$274,841. 13. Summarize total personnel and personnel years utilized by the jurisdiction to directly implement or administer this Chapter(450-8.030(B)(5)): 4000 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)): The facility has not received any written comments. 15. Summarize how this Chapter improves industrial safety at your stationary source(450-8.030(B)(7)): This Chapter improves safety by extending the number of covered process covered by the Risk Management Program. Since all process units are treated as program level 3, recommendations generated via the PHA program are implementated in a shorter timeframe. Root cause analyses are being performed on any major chemical accidents or releases that occur. We continue applying the REASON RCA methodology to investigate any MCARs that have occurred. Sly. has developed and implement a human factors program. Human factors considerations have been incorporated into existing programs that include enhancement to our PHA process, building siting, procedure writing, incident investigation, management of orgizational change and field surveys. An aggressive approach for implementating inherently safer systems continues as part of the PHA recommendation implementation. 26. 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„ SFR has undertaken a major long term project to reformat its operating procedures. This project addresses audit recommendations, enhancement of capturing operating limits with consequences of deviation and the steps to correct in addition to the inclusion of human factor issues. Engineering projects to install double bottoms on tanks continues to move forward. As noted in Question 7, as a result of the 7/10/02 loss of steam incident, installation of pressure gauges within the blowdown lines on the turbines at the Stearn Power Plant was completed. The steam loss contingency plan was reviewed and updated. Revisions were made to procedures and corresponding training took place. Projects for piping upgrades, as determined by our Metallurgical Engineering and Inspection Department, are underway. A Building Siting survey has been conducted, a plan is in place and progress continues to be made on identified issues. FR continues to upgrade and modernize control systems. During 2002 a complete control modernization of the entire Unicracker was completed. A Safety Integrity Level evaluation was incorporated into this modernization. A control modernization plan for going forward has been created. 17. Summarize the emergency response activities conducted at the source (e.g., CWS or CAN activation) in response to major chemical accidents or releases: As there have been no MCARs,no emergency response activities have been required since the last report. ConocoPhillips Company-Rodeo Refinery inherently Safer Systems Report 7-1-02 to 6-15-03 Reference Primary Source Description Strate RTK224 Inherent New The inherent level of risk reduction was implemented by process/facility elimination of the hazard. RTK157 Inherent New The inherent level of risk reduction was implemented by process/facility elimination of the hazard. RTK 194 Inherent New The inherent level of risk reduction was implemented by process/facility reducing inventory on site by through elimination of tankage. R4on6/80/100 Inherent New The inherent level of risk reduction was implemented by process/facility elimination of equipment that may have caused the hazard. R248-3R Inherent PHA The inherent level of risk reduction was implemented by elimination of equipment which may have caused a hazard. R240-4-18R Passive PHA The passive level of risk reduction was implemented by minimizing the hazard thorough equipment design features, which protect equipment without active intervention. 8240-4-19R Passive PHA The passive level of risk reduction was implemented by minimizing the hazard thorough equipment design features, which protect equipment without active intervention. R240-1-IR Inherent PHA The inherent level of risk reduction was implemented by providing less hazardous process conditions. R240-1-2R Inherent PHA The inherent level of risk reduction was implemented by sim li in the system. R240-1-3R Inherent PHA The inherent level of risk reduction was implemented by simplifying the system. R240-1-4R Inherent PHA The inherent level of risk reduction was implemented by sialifying the system. R240-1-5 Passive PHA The passive level of risk reduction was implemented by minimizing the hazard thorough equipment design features, which protect equipment without active intervention R248-7R Passive PITA The passive level of risk reduction was implemented by minimizing the hazard thorough equipment design features, which rotect a ui ment without active intervention R100-2R Passive PHA The passive level of risk reduction was implemented by minimizing the hazard thorough equipment design features, which protect equipment without active intervention. R100-23R Inherent PHA The inherent level of risk reduction was implemented by reducing in entory on site through elimination of tankage. R 100-ISR Inherent PHA The inherent level of risk reduction was implemented by elimination ofui ment which may have caused a hazard. SPP-5R Passive PHA The passive level of risk reduction was implemented by replacement of equipment to minimize the hazard. Annual Performance Review and Evaluation Submittal June 1.5, 2043 *Attach additional pages as necessary 1. Name and address of Stationary Source: General Chemical Bay Paint Forks, 501 Nichols Road Bay Point California 945L5 2. Contact name and telephone number(should CCI-IS have questions): Kevin O'Kelley, (9251 458-7365 3. Summarize the status of the Stationary Source's Safety Plan and Program(42-01 §6.43.160(b)(1)): The S, dety Plan and Program was completed in November 2000. 4. Summarize Safety Plan updates (i.e., brief explanation of update and corresponding date) (42-01 §6.43.160(b)(2)): Updates were made to the Safety Plan in March 2001 based on comments received from.the County. 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)): CCHS Office 4333 Pacheco Boulevard Martinez Bay,Paint Libr libr closest to the stationer source 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 accident history report submittal (January 15) and the annual performance review and evaluation submittal(lune 30)).- There 0)):There have been no major,accidental chemical releases at this site durin,this time frame. 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): There have been nor of cause analyses during thiLpqriod. 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 Count com feted an audi of our facilit from June 2 throw h June 23 2003. An official re ort Las,not been received at this tune. Recommendations will be implemented in the near future. 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): No _PHAs have been conducted during thisperiod; therefore. there have been no inherently safer systems im lemented during this eriod. 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): No enforcement actions were taken during this time period. 11. Summarize total penalties assessed as a result of enforcement of this Chapter §6.43.160(c): No malities have been assessed against any facility. 12. Summarize the total fees, service charges, and other assessments collected specifically for the support of the ISO §6.43.160(d): CalARP Proaxam fees for these nine facilities are - $419,522. the Risk Mena ernent Cha ter of theIndustrial Safet Ordinance fees are- 274 841. 13. Summarize total personnel and personnel years utilized by the jurisdiction to directly implement or administer this Chapter §6.43.160(e): 4000 houls were used to audit/insmet and issue reports on the Risk Management Cha ter 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): The facility-has not received any comments regarding the effectiveness of the local 2Lograni that raise public saf 15. Summarize how this Chapter improves industrial safety at your stationary source §6.43.160(g): This Cha ter hell2s minimize potential risk and ex osure to employees,the cemmunit 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: No THAs or root cause analyses have been conducted dating this review Mriod. Chan es that have been made include Human Factors training for all em. toees. The County conducted a co liance audit frm lune 2 throu June 23. In ddition AcuT ch Consulting conducted an audit for ISO-only rocesses in January and March 200 Recommendations frorn these audi.s will be im lemented in the near future. 17. Summarize the emergency response activities conducted at the source(e.g., CWS or CAN activation) in response to major chemical accidents or releases: There have been no emeraen y response activities conducted at this site in response to maior chemical accidental releases during this_period. Annual Performance Review and Evaluation Submittal June 15,2003 *Attach additional pages as necessary 1. Name and address of Stationary Source: Shell Oil Products U.S. Ref nery 3485 Pacheco Blvd.,Martinez CA 94553 2. Contact name and telephone number(should CCHS have questions): Refer to cover letter. 3. Summarize the status of the Stationary Source's Safety Plan and Program (450-8.I13d(B)(2)(i)): SMR's Safety Plan is cernlete and the Safety ProgLam has been im lernented at SMR. Documentation of the Human Factors Pro am is described in this document, SMR's Human Factors-program has been develo ed and im lernented. 4. Summarize Safety Plan updates (i.e., brief explanation of update and corresponding date) (450- 8.030(13)(2)(ii)): SMR's initial Safety Plan was submitted in January 2000. An update to the Accident History section of the Safety Plan was submitted on April, 12th, 2000 and again in June 2002. A revised Safety Plan describing-SMR's Human. Factors Program was submitted in JanuM 2001. An additional revision was submitted in June 2003. 5. List of locations where Safety flans are/will be available for review, including contact telephone numbers if the source will provide individuals with copies of the document (450-8.030(13)(2)(ii)): CCHS Office 4333 Pacheco Boulevard Martinez • Martinez Public Library closest to,the stationary source 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 (450-8.430(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 accident history report submittal (January 15) and the annual performance review and evaluation submittal (,lune 30)): The Accident History section of the Safety Plan describes the MCARs that have occurred at SNR since June 1 1992. All MCARs that have occurred through June 25, 2003 are included in the most recent Safety Plan submittal. 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)): The Accident Historysection of the SNCR's Safety Plan includes Root Cause-Analysis RCA findings where available. The status for all recommendations resultinig from:RCAs perfomed on MCARs are included. 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)): 5 of 43 recommendations remain incorn lete followin CCHS on-site audit of SMR during the fall of 2000. Many of the recommendations were in fact not re aired but rather supmested enhancements to existing SNIR ro ams. All recommendations are cern lete following CCHS's unannounced insl2ection that occurred. in Januar 2002. 8 of 30 recommendations following CCHS's audit of SMR's Human Factors and Inherently Safer -Systems remain o en. There has been no RCA or Incident Investigations conducted by the Department at SMR. 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(13)(2)(vi)): No Inherently Safer Systems ISS were implemented that mitigated scenarios where a Major Chemical or Accidental Release could have reasonably occurred. However, in the spirit of sharia information SMR is reporting two ISM iml2lemented. One ISS was implemented that reduced inventm bremovin un-necesspiping. One ISS was implemented that reduced inventory by decoinrnissioning-unused Pi i . nty. 10. Summarize the enforcement actions (including Notice of Deficiencies, Audit Reports, and any actions turned over to the Contra Cosh County District Attorney's Office) taken with the Stationary Source pursuant to Section 450-8.028 of County Ordinance 98-48(450-8.030(I3)(2)(vii)): None 11. Summarize total penalties assessed as a result of enforcement of this Chapter (450-8.030(3)): No malities have been assessed ap, .ainst any f4cility 12. Summarize the total fees, service charges, and other assessments collected specifically for the support of the ISO (450-8.030(13)(4)): CalARP Program fees for these nine facilities are-$419.522. the Risk Management Cha ter of the Industrial Safet Ordinance fees are-$274,841. - 13. Summarize total personnel and personnel years utilized by the jurisdiction to directly implement or administer this Chapter(450-8.030(B)(5)): 4000 hours were used to auditlinsma and issue_reports on the Risk Mana ement Cha ter 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)): No written comments have been received regarding the effectiveness of the local program that raise public safety issues. 15. Summarize how this Chapter improves industrial safety at your stationary source (450-8.030(B)(7)): Industrial Safety has been improved at SMR by-mquiring PSM t ero ams for alI o erating_areas. 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: As indicated in item #15 above, PSM tone mograms- have been re aired for all processes at SMR as a result of the implementation of the Industrial Safety Ordinance. The uaht of the anal sis conducted as a result of organizational change has char ed for the better. In addition the degree of review of critical operating rocedures has also im roved. 17. Summarize the emergency response activities conducted at the source (e.g., CWS or CAM'activation) in response to major chemical accidents or releases: During the previous reporting taeriod ending June 30 2003 SMR had one MCAR occur on JanuM 11 2003. The CWS system was used for the event. The CAN system was not used for this Rarticular event however, it has been used in previous events outside of the current time frame. SMR notified the various regulatM a encies. CCHS's response for this incident was limited to res nse to SMR's Emergengy Emergency012eration Command center. SMR personnel mitigated this event. Annual Performance Review and Evaluation Submittal June 15, 2003 *Attach additional pages as necessary 1. Name and address of Stationary Source: Pol chemo e 501 Nichols Road Pittsbur CA 94565 2. Contact name and telephone number(should CCHS have questions): Kirk Thomas 1925) 458- 1643 3. Summarize the status of the Stationary Source's Safety Plan and Program(450-8.030(B)(2)(i)): Com late as of 41712003.Public notice and comment riod cam lets. 4. Summarize Safety Plan updates (i.e., brief explanation of update and corresponding date) (450- 8.030(13)(2)(ii)}: Revision A ril 2003—Added SP as an attachr mant to Revis`on Auust 2002—Address CCHS continents. 5. hist 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(11)(2)(ii)): CCHS ffice 4333 Pacheco Boulevard Mar`nez Bay Point Library 205 Pacifica Avenue, Riverview Middle School Ba Point 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 accident history report submittal (January 15) and the annual performance review and evaluation submittal(June 30)): None. 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)): None. 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(13)(2)(v)): None. 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(13)(2)(vi)): Substitution of Materials;Elimination of p1oce§ses 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(13)(2)(vii)): None 11. Summarize total penalties assessed as a result of enforcement of this Chapter (450-8.030(3)): No malities have been assessed against an facilit . 12. Summarize the total fees, service charges, and other assessments collected specifically for the support of the ISO (4513-8.030(8)(4)): CalARP Program fees for these nine facilities are- $419522, the Risk Management Cha ter of the Industrial Safer Ordinance fees are-_$,274,841. 13. Summarize total personnel and personnel years utilized by the jurisdiction to directly implement or administer this Chapter(450-8.030(13)(5)): 4000 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)): None. 15. Summarize how this Chapter improves industrial safety at your stationary source(450-8.030(8)(7)):_ This chanter has im roved i Au safer at our f cilit b_challenging us to consider safer alternatives in in both CgIARP and non CalARP covered processes. 16. List examples of changes trade 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 Substitution of Hazardous Materials, Devised MI Program,Discontinue o€Hazardous processes,Seismic Anal sis Rg o€its 17. Summarize the emergency response activities conducted at the source (e.g., CWS or CAN activation) in response to major chemical accidents or releases: O)n site training in emergent, roti 1 tion. 24 hr.Haz Mat Technician Training for all operators. Annual Performance Review and Evaluation Submittal July 7, 2003 *Attach additional pages as necessary 1. Name and address of Stationary Source: Tesoro Golden Eagle Refinery 150 Solano'Way Martinez,CA 94553 2. Contact name and telephone number(should CCHS have questions: Japes Da Hell at(9253 370?-3169 or Sabiha Gokcen at 0925)370-3620 3. Summarize the status of the Stationary Source's Safety Plan and Program (450- 8.030(B)(2)(i)): The original Safety Plan and two Safety Plan updates have been submitted see below).Contra Costa Health Services has com feted two audits of the safety ro ams. The first audit was in September, 2000 on the safely Proggams. The second audit was in December 2001 and focused on Inherently Safer Systems and Human Factors. All safety rc� am elements required by the ISO have been developed d and are being imleme ted. 4. Summarize Safety Plan updates (i.e., brief explanation of update and corresponding date) (450-8A30(B)(2)(ii)): The ori final Safety Plan for this facility was filed with Contra Costa Health Services on JanuM 14 2000. An amended plan, updated to reflect CCHS recommendations and ownership chane was filed on November 30 2000. A Human Factors Amendment was submitted on Januar 15, 2001. A Power Disruption Plan was submitted,.yer Board of Sgjnrvisor reguest, on June 1 2001. An amended Safety Plan updated to reflect ownership thane was submitted on June 17 2002, The Safe Plan for thig fagffijy will be updated whenever chap es at the facility warrant an ujadate or eve three ears from June 20032. In addition,the accident bistory aloewith other information is updated eve year on June o. This submittal serves as the 2002 update. 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, 4333 Pacheco Boulevard. Martinez-, local library closest to the stationn source. 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 accident history report submittal (January 15) and the annual performance review and evaluation submittal (June 30)): The accident history was updated in the 2002 update.Since that time there have been two incidents that meet the Ma'or Chemical Accident or Release criteria. On June 8 20 the #s Boiler was shutdown and a visible,viume of coke dust was emitted from the stack. This incident met be CWS level 2 criteria: for,a visible plume. This incident is still under investigation. On JUly2003, the #6 Bailer had a risible lume emitting-from its stack. This incident Met the CWS level 2 crit ria for a visib e plume. This,incident is under investigation. 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)): Root Cause Analysis information is included in answers to#6. 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)): "CCHS Information": CCHS completed an audit on Sg tember 15-2000 and December 2002. There are no RCA or Incident Investi &tions that have been conducted by the Department. 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)): Golden Eagle is submitting a list of the Inherently Safer Systems (ISS) that meet the criteria for Inherent or Passive levels only and that were completed within the last year(see attached). to. 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)): "CCHS Information": The response_ to the Audit PreliminM Determination was completed on March 13 2001 for Golden Eagle Refinery. The response to the ISS Human Factors audit was corn feted in July, 2002. An unannounced inspection was conducted in March. 2003. 11.Summarize total penalties assessed as a result of enforcement of this Chapter (450- 8.030(.3)): "CCHS Information": No 12enalties have been assessed against any faciliLy. 12. Summarize the total fees, service charges, and other assessments collected specifically for the support of the ISO (450-8.030(B)(4)): "CCHS Information": CalARP Program fees for these seven facilities were $419,522. The Risk Management Cha ter of the Industrial Safety Ordinance fees were$274,841— 13. Summarize total personnel and personnel years utilized by the jurisdiction to directly implement or administer this Chapter (450-8.030(B)(5)): "CCHS Information": 4000 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)): This facility has not received any comments to date regarding the effectiveness of the local program. 15. Summarize how this Chapter improves industrial safety at your stationary source (450.8,030(8)(7)): Chapter 450-8 improves industrial safety by expanding the safety programs to all units in the refinery. In addition,the timeframe is shorter to implement recommendations generated from the Process Hazard Analysis (PHA) safety program than state or federal lave. This has resulted in a faster implementation of these recommendations. Chapter 450-8 also includes requirements for inherently safer systems as part of implementing PHA recommendations and new construction. This facility has developed an aggressive approach to implementing inherently sayer systems in these areas. Chapter 450-8 has requirements to perform root cause analyses on any major chemical accidents or releases(MCAR). This facility has applied that rigorous methodology to investigate any MCARs that have occurred since January, xggg. Chapter 450-8 requires a human factors program. This facility has developed a comprehensive human factors program and is in the process of implementing the program. 16.Dist 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 RCAs) that significantly decrease the severity or likelihood of accidental releases. This question was broadly answered under question 15 above. Some examples of changes that have been made due to implementation of the ordinance are as follows. There are some units that were not covered by RMP, CalARP or PSM. Those units are now subject to the same safety programs as the units covered by RMP, WARP and PSM. They have had PHAs performed on them according to the timeline specified in the ISO and the PHA recommendations have been resolved on the timeline specified in the ISO. A list of inherently safer systems as required by the ISO for PHA. recommendations and new construction is attached to this filing as mentioned in the response to question 9. With respect to Compliance Audits, there was a compliance audit performed in September 2000 in addition to the CCHS audits of 2000 and 2002. All audit findings are being actively resolved. Root Cause Analysis findings and recommendations for MCARs are listed in the response under question 6. 17. Summarize the emergency response activities conducted at the source (e.g., CWS or CAN activation)in response to major chemical accidents or releases: "CCHS Information": none Al 1AHMEN 1 D CONTRA COSTA HEALTH SERVICES PROPOSED CHANGES TO THE INDUSTRIAL SAFETY ORDINANCE Contra Costa Health :Services Proposed Changes to the Industrial Safety Ordinance (March 1$, 2003) Human Factors Maintenance Procedures The maintaining of the covered processes has a direct correlation to the overall safety of a stationary source. Maintenance includes the procedures for the different requirements to maintain the equipment. The number of personnel that is required to maintain the different covered processes may determine how well the equipment in the different covered processes are being maintained. When the Industrial Safety Ordinance was written, there were discussions of requiring the consideration of Human Factors for maintenance procedures and management of organizational change for maintenance personnel. The ordinance requires many requirements for Human Factors at a stationary source that is not required by any other regulations. The stationary sources were required to implement these changes within one year after a guidance document was completed. Because of this concern over the time constraint, maintenance procedures and the management of changes requirements to the maintenance organization were not included in the Industrial Safety Ordinance as adopted by the Board. Field Analysis for Latent Conditions Before a source can manage human factors and error, it may be useful to understand where and how human factors and error initiate. Literature commonly refers to active failures and latent conditions in describing where human factors and error originate and occur. Active failures are errors and violations committed by people at the human--system interface such as operators and maintenance personnel. 'These failures are usually unique to a specific event and have immediate effects. Latent conditions arise due to decisions made throughout the organization (e.g., marketing personnel, designers, managers) and outside of the organization (e.g., regulating agencies). Latent conditions exist in all systems and may lie unrecognized until combining with active failures to result in an incident. The same latent condition may contribute to a number of different accidents. An example of active failures and latent conditions is "the design of a scrubbing system may not be adequate to handle all credible releases. If an active human error initiates the production of an excessive volume of product the system may allow toxic materials to be released to the environment." The stationary sources are looking for latent conditions that exist in the covered processes in different ways as part of their Process Hazard Analysis, in the operating procedures, and in doing incident investigations. Health Services has found that the stationary sources that do a field analysis for latent conditions at each of the covered processes has done a more thorough and complete analysis for determining where latent conditions may exist. Health Services is recommending that a field analysis for latent conditions be done for all covered processes. Management of Or anizational Changes The Chemical Process Industries, including petroleum refining, have gone through major changes in the last ten to fifteen years. The changes include "downsizing", "reengineering", "rightsizing,', etc. There also have been many corporate buyouts and mergers. In Contra Costa County the following companies have been involved with mergers, corporate buyouts,or spin offs. • Richmond Refinery- Chevron merged with Texaco to form ChevronTexaco • Rodeo Refinery - Unocal sold their refineries to Tosco including the Rodeo refinery. Tosco was then bought out by Phillips who now has merged with Conoco to form ConocoPhillips • Martinez Refinery—Shell and Texaco refineries were spun off to form a new company called Equilon. When Texaco merged with Chevron, Texaco sold their interest in Equilon back to Shell. • Avon/Golden Eagle Refinery — Tosco bought the Unocal refineries. Tosco sold the Avon Refinery to Ultramar Diamond Shamrock. Ultramar Diamond Shamrock was bought out by Velaro. Velaro were required to sell the Golden Eagle Refinery, which they did to Tesoro. • Rhone Poulenc spun off a new company called Rhodia that includes their Martinez plant • General Chemical parent company has been granted protection under the bankruptcy laws • Dow Chemical merged with Union Carbide The changes to these companies have affected the overall operations and management of the different stationary sources. When changes are made through mergers, buyouts, "downsizing", or "reengineering,,, experienced personnel leave their companies. The loss of this experience and historical knowledge can and does effect the overall operations and safety of a stationary source. The Industrial Safety Ordinance requires that the stationary sources manage any changes in their personnel that work in operations or health and safety. This will help to offset any potential safety concerns by"downsizing", "reengineering,', or the affects from mergers,buyouts,or spin offs. Health Services is recommending that the following changes be done to strengthen the managing of organizational changes. To be able to do an accurate and complete analysis of the change in personnel, a description of the responsibility of each job working in operations or health and safety be completed. Health Services is recommending that the Industrial Safety Ordinance be changed to require the stationary sources to develop and document a job description for all jobs that are responsible for operations, maintenance, and health and safety. This includes the following positions: • Operators • Maintenance personnel • Maintenance or operating positions that are filled by contract personnel • Engineers working in operations or health and safety or who are supporting operations and/or health and safety • Supervisors and managers who have responsibilities in operations or health and safety Health Services is also recommending that as part of the managing the change for organizational changes that new personnel be educated on the history of the process or processes that they will be involved with, including the accidents that have occurred in the different processes. The ordinance does not require that a management of change for organizational changes be done for temporary changes. Health Services is recommending that the management of change for organizational changes include temporary changes. Security and Vulnerability Analysis Health Services is recommending that the Industrial Safety Ordinance be changed to require stationary sources to perform a Security and Vulnerability Analysis. The terrorist acts that occurred on September 11, 2001 showed the vulnerability of the United States to terrorist attacks. Chemical plants and petroleum refineries are a potential target for terrorists, because of the potential effect of a release or fire and explosions that could occur at these sites. Chemical plants and petroleum refineries are also potential symbolic and economic targets. The American Chemistry Council has developed security guidelines for their member companies. Security and Vulnerability Analyses have been developed by Sandia Labs, the American Institute for Chemical Engineers Center for Chemical Process Safety, Synthetic and Organic Chemical Manufacturers Association, and by many companies. Health Services is recommending that a recognized Security and Vulnerability Analysis method be performed by the Industrial Safety Ordinance stationary sources and that Health Services will audit the process that has been developed for the analysis and the process for implementing the actions that are the result of the analysis. Safety Climate Survey As discussed earlier in this report, Health Services is recommending that the Industrial Safety Ordinance be changed to require the stationary sources to work with Health Services on performing a Safety Climate Survey that has been developed by the United Kingdom Health and Executive. It may be appropriate for Health Services to apply the Safety Climate Survey, instead of having the stationary sources applying the survey. The safety culture at a stationary source does have an effect on the overall safety at that stationary source. This includes management systems, reporting of near misses, and how people feel about the safety at their work place. The Safety Climate Survey will assist in determining the overall safety culture at a stationary source. The survey will also assist Health Services in performing Safety Program audits. Public Input to Proposed Changes The above proposed changes have not had any input from the public, industries, or other interested parties. Health Services is asking the Board to refer the proposed changes listed above for review by the Hazardous Materials Commission. This will allow a forum for public input in the proposed changes to the Industrial Safety Ordinance. When the review by the Hazardous Materials Commission is complete, Health Services is asking them to report to the Board with their recommendations on the proposed changes. r .. Number and Type of Audits and Inspections Conducted Annual Report on the _ Industrial Safety Ordinance Nr mwP N404 1^- W4+ , .tea _-..............:.... NrTr� NY05 WaGe l fa00e � t,vY 04. .n•. WNt W.Oi 60M NOS .rrrk m600 W100 i3M50 ip01 W14p Nw 4a Y91n itae0l [00'42 WXC CMetWUCM N.4a 4Au05 Randall L. Sawyer November 4,20103 P°""`"• '"`� a °P "�°° "•"°• "� "�' W091 SKOa T1.N4 W:W �I ift46D ]11.00 Yi4i 1prei +lie Yav fn 1A0 Vifrot 11105 WrOe. ]aaOk L21Atl W[IO] N4N0 W1O0 /.1.01 x4145 WSaO Y4.1 ill�p�Wi9t Y4r441 5Y10/ f11W Oyg111NHry SN]RE .4t0i Na ba 4,3083 Effectiveness of Contra Costa Health Services' Implementation Public Participation Process Effectiveness of the Depa/mems program to ensure stationary . Consultant was hired to do public outreach in source's compliance with the ordinance the Martinez,Pacheco,Clyde, North Concord, = Effectiveress of the procedures for records management and Ba Point areas o€the County * Number and type of aunts and inspections conducted by Health y ty services as requires!by the ordinance . Presentadons to 729 people attending 67 = Number of root cause analyses and/or incident investigations meetings conducted by Health services . Presentations were done in Spanish that was • Health Services'process for public participation broadcast over CCTV • Effectiveness of the Public Information Bank • Effectiveness of the Hazardous Materials Ombudsperson . Three public meetings were held on the • tither required program elements necessary to Implement and Safety Plans and Audit Findings for six manage the ordinance stationary sources N—ba 4,2W3 PipC 2 Nne'MW 4,2003 .•^��,J-.. Paq.6 Stationary Source Listing Website Information ..�... - _ ..e.+ . ata s re stat. any s�euree's safe'fy Plan and Program A summary of all stationary sources'Safety Plan updates and a Fisting . Unified Program Agencies Information of where the Safety Plans are publicly available . The annual awdent hl=repot Wombed by the regulated a CalARP Program stationary sources and rewired by the ordinance . Hazardous Materials Inventories Program A summary,including the status,oP any roe/cause analyses and ry . Hazardous Waste Generators axklent Investtgations wndutted lir betrq oondu by the statbna swr ccs and requaad try t3 a artitmance,i ctuding he stab s of . Underground Storage Tanks inlyterllrNi4twn Gt ICLOfrdfllirldatiun9 A summary,including the status,of any audits,inspections,root cause a Green Business Program analyses and/or incklent Investigations conducted or by Health Services,Including the status of Implementation of recommendations ■ Major Chemical Accidents and releases DescripWn of inherently safety systems implemented by the regulated to Hazardous Materials Incident response stabonary,source Legal enforcement actions initiated by Health Services,including a Unannounced Inspection Program administrative,dvii,and oiminai actions NOr.M-4.2003 Plpc 3 Nwanbr 4,2053 PrJ.6 f U.S. and California Accidental y Release Prevention Programs Inherently Safer Systems • Hazardous Assessment a thirty-four inherently safer design/systems ■ Prevention Programs were implemented that met the definitions for inherent or passive categories • Management System . Guidance was issued for performing . Emergency Response inherently safer system analysis for: . New processes . Mitigations from Process Hazard Analysis . Existing Processes ,k N-1AW 4,20M Dap*7 N—b.4,1005 Pape 3C Prevention Programs Status of Root Cause Analysis Proms safety Mechanical Integrity . Four Major Chemical Accident or Information Process H=rd Incident Release has occurred within the last Analysis Investigation year operating Management of .'two at County Industrial Safety Ordinance Procedures Change Stationary Source Training Pre-startup Safety Review . One at a Richmond Industrial Safety compliance Audits contractor safety Ordinance Stationary Source Hot work Permit Employee . One not covered under an Industrial Safety Participation Ordinance Nov4ntber 4,2AA7Dago 8 Non<1-4,2003 D1ps ii Levels of Major Chemical Industrial Safety Ordinance Accidents or Releases -- _ �.�. . The whole facility is covered " Serious-A fatality,serious Injuries,or major onsite r Human Factors Program and/or offsite damage occurred Medium-An impact to the community occurred,or if . Operating Procedures the situation was slightly different the accident may . Process Hazard Analysis have been considered major, or there is a recurring . Incident Investigations type of incident at that facility . Management of Organization Change ' Minor -- A release where there was no or minor injuries, the release had no or slight Impact to the r Root Cause Analysis community,or there was no or minor onsite damage . Inherently Safer Systems Dpe 9 x__1_4,200.1 Na—d-4,2w2 D4¢!12 Contra Costa County Major Chemical Proposed Changes to the County's Accidents or Releases Industrial Safety Ordinance k . Expand Human Factors to include: k,. i irys r3� e . Maintenance Procedures - , ' . Management of Organization Changes for: T..w. .Maintenance Personnel .health&safety Personnel «— .Define Permanent Changes .Include strike Contingency Pians d p 8 . Security and Vulnerability Analysis "aN. moa xnac ,s2os& r,rt s � Y ^ . Safety Climate Assessment Nmwnhu 4,2083 P.9e 13 Naernb.r 1,1003 �.9.kE County Industrial Safety Ordinance ;. Stationary Sources MCARS . Loafs for 2004____ . Complete second round of Industrial Safety Ordinance Audits Public outreach in the Richmond Area for the Richmond Industrial Safety Ordinance Hold public meetings on audit findings '� "' ■ Bring proposed changes to the Industrial Safety Ordinance to the Board of Supervisors •_VI 9+"''ria•'. +*Y� ��"-*pp w` Na4tbl,T i,2093 $ k; NL ptbN f,2003 Page I2 Richmond and County Industrial Safety Ordinance MCAR's ' wsTOOYAG% --–s-8ripus p:.44 :y N.Mwi )Nil f� YCOS 70 'ami ,ii�° N—t.i,2003 9.2.:s