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TO: BOARD OF SUPERVISORS : -
Costa
p County
FROM: HARVEY E. BRAGDON
DIRECTOR OF COMMUNITY DEVELOPMENT
DATE: May 31, 1.994 _Uxr.i"
SUBJECT: Ratification of Zoning Administrator Decisions Regarding Shell Oil
Company's Compliance with Conditions of Approval (LUP 2009-92)
SPECIFIC REQUEST(S) OR. RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION
RECOMMENDATIONS
1. Ratify__th-e--Zoning Administrator's decision that Shell Oil has
complied with Condition of approval #35 .A. for the Cooling
Water Tower, the Flare System, the Isomerization Unit, and the
Hydrogen Plant.
2 . Ratify the Zoning Administrator's decision approving the noise
monitoring plan submitted by Shell Oil Company as required by
Condition of approval #35 .B.
3 . Ratify the Zoning Administrator's decision that Shell Oil
Company has provided adequate evidence that the total hydrogen
<, sulfide concentrations will not exceed the odor thresholds as
required by Condition of Approval #25 .
4 . Ratify the Zoning Administrator's decision that Shell Oil is
complying with the mitigation measures of the project's Final
EIR addressing selenium as required by Condition of Approval
#12 .
FISCAL IMPACT
None.
BACKGROUND/REASONS FOR RECOMMENDATIONS
When the Board of Supervisors approved the Land Use Permit for
Shell Oil Company's Clean Fuels Project (County LUP 2009-9.2) , the
Board specified that the Zoning Administrator's decision regarding
several conditions of approval must be placed on the Consent
Calendar for ratification. C�Q-.�. (,o pt
CONTINUED ON ATTACHMENT: X YES SIGNATURE HAav�ti
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
APPROVE OTHER
SIGNATURE(S) :
ACTION OF BOARD ON ,Tune 1:4.1994 APPROVED AS RECOMMENDED x OTHER x
On recommendation of Supervisor Smith, IT IS BY THE BOARD ORDERED that the above recommendations
are APPROVED; and IT IS FURTHER REQUESTED that the next time an item such as this is
presented to the Board, that staff include a memo commenting on what future process would
maximize participation without causing delays or problems.
VOTE OF SUPERVISORS
I HEREBY CERTIFY THAT THIS IS A
x UNANIMOUS (ABSENT I. V TRUE AND CORRECT COPY OF AN
AYES: NOES: ACTION TAKEN AND ENTERED ON THE
ABSENT: ABSTAIN: MINUTES OF THE BOARD-OF
SUPERVISORS ON THE DATE -SHOWN.
Contact:Catherine Kutsuris - 646-2091
Orig: Community Development Department ATTESTED Jump 14,1994
cc: GNEDA PHIL BATCHELOR, CLERK OF
County Counsel THE BOARD OF SUPERVISORS
AND COUN Y ADMINISTRATOR
BY , DEPUTY
2 .
Shell Oil Company has submitted information documenting their
compliance with three of the Conditions of approval which address
noise standards, odor control and selenium.
Condition of Approval #35.A. - Noise Calculations
This condition requires Shell Oil to submit noise level
calculations which demonstrate that project units will comply with
the noise performance standard of 77 dBA when measured five feet
above the ground and 100 feet from the equipment. This noise
performance standard will assure that the project will not increase
noise levels at the nearby residences.
On May 25, 1994 Shell Oil Company submitted Noise Calculation
Reports for the Isomerization Unit, the Hydrogen Plant, the Flare
System and the Cooling Water Tower. As required by the Conditions
of Approval, the reports were prepared by an engineer who is a
member of the Institute of Noise Control Engineering with at least
five years in noise control engineering. Each of the analyses
found that the units would comply with the noise performance
standard.
Condition of Approval #35 .B. - Noise Monitoring Plan
This condition requires Shell Oil to submit a noise monitoring plan
which specifies requirements for certifying the project's
compliance with the nose performance standard, identifies
procedures for handling remedial noise control if required, and
specifies annual reporting requirements.
The "Protocol for Verifying Noise Emissions From Individual Process
Units" (refer to attached) meets these requirements.
Condition of Approval #25 - Odor Control
This condition requires Shell Oil to provide adequate evidence that
the total hydrogen sulfide concentration will not exceed the 42 . 0
micrograms per cubic meter threshold.
Modeling conducted by Shell Oil found that the maximum one hour
project hydrogen sulfide concentration would be 29 . 7 micrograms per
cubic meter., Recent monitoring for hydrogen sulfide around the
refinery found existing concentrations of 1 . 2 micrograms per cubic
meter, with a maximum concentration of 7 . 2 micrograms per cubic
meter. Using the conservative method of adding the worst case
background (7.2) to the project concentration (29.7) yields a
concentration of 36. 9 micrograms per cubic meter. This is below
the threshold used in the Final EIR and the conditions of approval.
Condition of Approval #12 - Selenium
This condition requires Shell Oil to submit a report to the Zoning
Administrator which details the project's compliance with the
mitigation :measures addressing selenium in the Final EIR. This
includes conducting a pilot study to demonstrate to the
satisfaction of the Regional Water Quality Control Board, the
effectiveness of the chosen combination of recycling and treatment
processes in achieving a no net increase in selenium discharge.
Shell Oil submitted their selenium reduction plan to the Regional
Water Quality Control Board (RWQCB) on March 30, 1994 (refer to
March 30, 1994 letter from Shell Oil and the March 28 , 1994 Shell
Oil Interoffice Memorandum) . Shell also completed the pilot study
as required, and submitted the study summary and results to the
RWQCB for approval (refer to the April 27 , 1994 letter from Shell
Oil) . The RWQCB confirmed that the use of a 5. 8 lb/day standard
for the Martinez Manufacturing Complex during construction and
3 .
operation will satisfy the "no net increase" requirement of the
land use permit (refer to the April 11, 1994 letter from the
RWQCB) . The Board also reported their satisfaction that the
measures employed by Shell;, " . . .will be an effective means of
reducing the amount of selenium contributed by the Clean Fuels
projects" (refer to the May 4 , 1994 letter from the RWQCB) .
CK/aa
BDI/Shell.CK
i
` DATE:
REQUEST TO SPEAK FORM
' (THREE (3) MINUTE LIMIT)
Complete this foam and place it in the box near the speakers' rostrum before
addressing the Board.
NAME: V�h � �ZW� PHONE:
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6 i
DATE: v r1 2 74 y 1
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Complete this form and place it in the box near the speakers' rostrum before
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NAME: �(�� G Y Mi)n PHONE: Sl0 -31 3 -3705
ADDRESS: rl p U_na r(A m K 0, CITY: �b z°n�'e�� C4
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DATE: S ur
REQUEST TO SPEAK FORM .
(THREE (3) MINUTE LIMIT)
Complete this form and place it in the box near the speakers' rostrum before
addressing the Board.
�cr
NAME: S L7 Y, p J PHONE:
ADDRESS: l���C 7 1 1 CITY: M G /`�► h e Z
I am speaking formyself OR organization: ` D co
(NAME OF ORGANIZATION)
Check one:
I wish to speak on Agenda Item # d
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I do not wish to speak but leave these comments for the Board to consider.
Shell Oil Company
P O Box 711
Martinez CA 94553
Telephom:(510)313-3000
March 30, 1994
Mr. Steve Richie
Executive Officer
California Regional Water Quality Control Board
San Francisco Bay Region
2101 Webster Street, Suite 500
Oakland, CA
94612
Dear Mr. Richie:
Shell Oil Company's Martinez Manufacturing Complex is in the
process of restructuring old facilities and constructing new ones
to produce reformulated gasoline as required by federal and
state regulations. Through conversations with you and your staff,
and as a condition of the project's Environmental Impact Report, . we
understand that no increase in selenium discharged from the complex
will be allowed. We are currently operating under a 5.8 lb/day running
annual average and this limit will remain in place until a more
restrictive 50ppb is implemented. Thus, during -and after
construction and operation of the new units, the maximum amount
of selenium discharged from the refinery may not exceed the applicable
limit.
In order to comply with the above requirements, we have developed
and tested methodologies for . insuring that -the level discharged
remains at or below the 5.8 lb/day running annual average. The
details of our plan are discussed in the attached memo. In order
to better understand our technology, attached is a copy of Shell's
pending patent application for a Process for the Removal of Selenium
From Selenium Containing Streams. As indicated by the stamp "Trade
Secret", Shell considers this application to be confidential,
proprietary, and valuable. As in the past, we would expect this
material will be maintained as confidential and not disclosed to
the public, at this time. I've additionally added a copy of our
current schedule for the project. This schedule is updated every six
months and future copies can be provided if you desire.
Shell Oil Company
P O Box 711
Martinez CA 94553
Telephone:(510)313-3000
It is my understanding that after reviewing our material,
you will submit written confirmation to us if you agree with our plan.
If I can be of further assistance please contact me at 510-313-3705.
Very Truly Yours,
AJ- C. armon
Manager, Environmental Conservation
Martinez Manufacturing Complex
cc: Ms_ Lila Tang SFBRWQCB
56-32(.R.v•3'78)
Shell Development Company
Interoffice Memorandum
March 28, 1994
FROM: J. B. Rodden
TO: J. C. Harmon
SUBJECT: REPORT OF TECHNICAL PROGRESS RELATED TO THE MMC
CLEAN FUELS PROJECT SELENIUM-DRIVEN EIR REQUIREMENTS
Summary
This memorandum outlines our progress relative to the requirements of the Clean Fuels
Project EIR, as related to selenium. Based on the success of experiments, pilot studies, and
detailed design efforts, we can now confidently assert that a 5.8 Ib/day running annual
average can be maintained through and beyond the Clean Fuels Project (CFP) start-up.
EIR Selenium Related Requirements
Specifically, EIR Mitigation Measure 6-4 required Shell to develop a detailed design to mitigate
the impact of selenium, according to the following approaches;
1) Maximize the recycle of stripped sour water around the hydrotreaters in order to conserve
refinery water demands and to generate a concentrated selenium stream.
2) Reuse the concentrated stream for the cutting/s!unying of coke. The stripped sour water
recycle would simply replace the make-up water that would be needed in a conventional
Delayed Coker Unit design to make up for water losses from evaporation and from coke,
saturation.
3) Treat a remaining stream, if necessary, either
a) upstream of biotreating facilities (using one of a number of methods Shell is presently
investigating, including ion exchange and ion-pairing reagents), or if necessary,
b) downstream of a CFP biotreater treating the segregated stream(using an adsorption or
co-precipitation process).
4) Design and implement a sampling program approved by the RWQCB to monitor the
effectiveness of these design features.
5) A pilot study shall be undertaken prior to completion of the final design to demonstrate to
the satisfaction of the RWQCB the effectiveness of the chosen combination of processes in
achieving no net increase in selenium discharge.
Progress and Status Related to the CFP EIR Selenium Requirements
Consistent with the approaches outlined in the CFP EIR Mitigation Measure 6-4, we have
confirmed the following through experimentation, piloting, and process engineering design
work;
a) Refer to EIR Mitigation Measure 6-4-(1). Selenium containing sour water from the
Catalytic Feed Hydrotreater (CFH) and the Distillate Hydrotreater (DHT) can be stripped,
and recycled back to the CFH and DHT, in a recycle loop that concentrates selenium
into a 10-60 gpm blowdown stream. This design is possible due to the relatively low
levels of organics in hydrotreater sour waters relative to other refinery sour waters. The
CFH and DHT were chosen based on the fact that these will be the only hydrotreaters
receiving heavy selenium-rich hydrocarbon streams. The 10-60 gpm flowrate estimate"
for the blowdown stream is based on a calculated estimate of the maximum tolerable
concentration for certain ions (eg. chlorides and carbonates) in the circulating recycle
loop. A greater degree of recycle could cause corrosion and/or a precipitate. In order to
reach such a low blowdown rate (10-60 gpm), a specific stripper design and appropriate
metallurgy have been selected. The system is now undergoing detailed design and ionic
modeling as part of the Clean Fuels Project, which will result in determination of the
actual blowdown rate.
b) Refer to EIR Mitigation Measures 64-(2) and 64-(5). This water(above) may then be
used at the Delayed Coker (DCU) for the quenching, cutting, and slurrying of coke,
making up for water losses from evaporation and from coke product saturation (Shell
patent pending). Detailed design of this system is proceeding, following confirming batch
pilot experiments using coke from a delayed coker, and concentrated stripped sour water
spiked with additional selenium. •In the batch tests, even at 850 F, no appreciable
selenium was driven overhead during the simulated quench (nearly 100% bonded to the
coke). We are purposefully leaving the option open to design the system to allow for
use of selenium containing water other than that from the CFH/DHT recycle loop, in case
another outlet for the concentrated CFH/DHT blowdown stream is identified. This
strategy allows for full use of the DCU's selenium removal potential.
NOTE: A combination of (a) and (b) above allows us to assert that we will achieve the No
Impact EIR condition. In order to confidently assure maintaining the more restrictive 5.8
pound per day numeric requirement through and beyond the Clean Fuels Project start-up, we
are also considering applying;
c) Refer to EIR Mitigation Measures 64-(3b), and 64-(5). Ferric chloride addition applied
to a segregated stream flowing from the new biotreater. The new biotreater will treat
Clean Fuels Project process streams, and some streams which are currently routed to
the existing biotreater. The biotreater flow rate will average approximately 1000 - 1500
gpm, and will have provisions to flow to Pond 5D. Detailed design of the new biotreater
is underway. The Pond 5D pilot has been completed, removes ^-70% of the influent
selenium, and would complement the near complete removal obtained on the most
concentrated selenium sources in the refinery (CFH and DHT). The new biotreater
design has been revised, following the success of the pilot, to include.provisions to reach
Pond 5D, in case another preferable upstream process solution is not identified. Since
CFP process streams (and some other non-('FP streams) will be routed to the new
biotreater, treatment of the new biotreater effluent in Pond 50 would provide added
assurance that the 5.8 lbs/day running annual average can be maintained.
or,
d) Refer to EIR Mitigation Measure 6-4-(3a). An alternate aqueous treatment method or in-
process reuse applied to an upstream selenium source. Such an option could result
from the suite of possibilities being investigated with the goal of reaching our ultimate
goal of 50 ppb. For more details regarding our ongoing work, please refer to Selenium
Field R&D progress reports (D. M. Prett to Distribution; dated November 22, 1993,
December 22, 1993, and February 18, 1994). The Clean Fuels Project is being
designed, wherever possible, to allow incorporation of a newly developed process that
may result form this effort.
Given that experimentation, field piloting (where possible), and design calculations, have
confirmed our design approaches, and allowed us to move into detailed design, this
memorandum has thus far addressed all of the EIR requirements, except for Mitigation
Measure 6-4-(4). This item required Shell to develop a sampling program for approval by the
RWQCB, to demonstrate that the No Impact objective is met following CFP start-up.
In order to assure that the No Impact condition is met, we propose that we commit to
maintaining 5.8 lbs/day (running annual average) in the final effluent discharge, through and
beyond the CFP start-up. Even though we have thus far been unsuccessful with regulatory
and legal arguments to revise the 5.8 numeric limitation, we continue to contend that 5.8
lbs/day effluent selenium is approximately 2 lbs/day LESS than a true representation of
routine operation for the EXISTING refinery. Therefore committing to this objective eliminates
any concern regarding the definition of what the existing refinery selenium level base line is
without the Pond 5D pilot facility. In order to simplify monitoring and reporting requirements,
the requirement should be identical to the 5.8 Ib/day numeric requirement outlined by Order
91-099 issued by the RWQCB. This would obviate all concerns related to defining and
measuring a less restrictive No Impact target with CFP start-up.
Start-Up Strategy
Start-up plans for the Clean Fuels Project will be consistent with maintaining a 5.8 Ib/day or
less running annual average through start-up. Current plans, subject to change, ars.. to start
up the new CFH/DHT sour water stripper (see previous section; Item (a)) in conjunction with
the new Sulfur Recovery Unit. Initially, and for a period of about three months, the CFH alone
will feed the new stripper, using the recycle loop. This may provide an opportunity to test any
alternative treatment technology developed between now and start-up, as noted in Item (d) of
the previous section. Approximately three months after the new CFH/DHT sour water stripper
start-up, the DHT will start up, and its sour water will also be routed to the new stripper.
Current plans are for the DCU to start up only one month following DHT start-up, at which
time the blowdown from the recycle loop will be routed to the DCU, as described in item (b).
Assuming another alternative treatment technology is not identified, as described in Item (d),
the 5.8 lbs/day average will be maintained during the iterim period either through use of Pond
5D; or by storing the water until DCU start-up.
Please call me at SSN 433-8959 if you have any questions regarding this memorandum or
any other aspect of our ongoing selenium work.
J. B. Rodden
cc:
Martinez Manufacturing Complex
R. F. Andrews
Westhollow Research Center
D. M. Prett
-------------------
.4
Shell Oil Company
P.O.Box 711
Martinez,California 94553
Telephone: (510)3133000
April 27, 1994
California Regional Water Quality Control Board
San Francisco Bay Region
ATTN Mr. Steve Ritchie, Executive Officer
2101 Webster Street, Suite 500
Oakland,CA. 94612
SUBJECT: Request for Review of Delayed Coker Selenium Removal Pilot Study
As you are aware, the Martinez Manufacturing Complex Clean Fuel Project
Environmental Impact Report(EIR)was certified by the Contra Costa County Board of
Supervisors on October 12, 1993. This approval included a condition(No. 12 under
"Water Quality")that Shell conduct a pilot study "prior to completion of final design, to
demonstrate to the satisfaction of the RWQCB, the effectiveness of the chosen
combination of recycling and treatment processes.in achieving no net increase in selenium
discharge".
In our letter dated March 31, 1994 we submitted information related to Shell's plans to
meet the EIR's "no net increase" condition. Your review and comment on this letter
provided concurrence that if compliance with 5.8 lbs/day is maintained during construction
and operation of the new units, Board staff will consider the no net increase to be
r satisfied.
This letter is to request your additional review of the attached Shell Westhollow Research
Center Technical Memo, dated April 26, 1994 entitled "Summary of Experiments
Conducted in July 1993 to Determine Fate of Selenium in Coker Drum Quench Water".
This technical memorandum summarizes pilot study work done, among other reasons, to
satisfy the approved EIR requirement mentioned above. Our March 31 letter and
attachments provide detailed information regarding the significance of the technology
piloted in this study to Shell's "no net increase" compliance plan.
We also request that you provide written technical concurrence with the validity of the
reported pilot study results as required by the EIR condition. We believe the report
provides conclusive evidence that selenium is effectively removed by the proposed
technology utilizing selenium laden stripped sour water in the Delayed Coker Unit
quenching system.
As indicated by the stamp "Trade Secret" on the pages of the attached report, Shell.
considers this information to be confidential, proprietary and valuable. As in the past,we
would expect this material to maintained as confidential and not disclosed to the public at
this time.
As indicated in telephone discussions with Ms. Lila Tang of your staff, our requested
review of the attached report may be critical to securing county building permits necessary
to maintain construction of the Clean Fuels Project on schedule. Accordingly, your
prompt attention to this matter would be appreciated.
If your have any questions or concerns regarding this matter please contact me at 313-
3705 or Dan Glaze at 313-3348.
Very truly yours,
J..C. Hhrmon, Manager
Environmental Conservation
Martinez Manufacturing Complex
Attachment
STATE OF CALIFORNIA PETE WILSON, Go.emor
CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD
SAN FRANCISCO BAY REGION
2101 WEBSTER STREET, SUITE 500
OAKLAND, CA 94612
(510) 286.1255 1
File No. 2119.1042 (LWT)
Mr. Joel Harmon
Manager, Environmental Conservation
Shell Oil Company
Martinez Manufacturing Complex
P.O. Box 711
Martinez, CA 94553
Subject: Proposed Plan for No Net Increase in Selenium Discharge from Clean Fuels
Project
Dear Mr. Harmon:
In your letter of March 30, 1994, you requested our written agreement of Shell's plan for
achieving no increase in selenium discharge from the Clean Fuels Project. We agree with
your proposal to use the 5.8 lb/day limit established in Order No. 91-099 as the final criteria
on whether no increase has been achieved. In other words, if compliance with 5.8 lb/day is
maintained during construction and operation of the new units, we will consider the no
increase requirement to be satisfied.
We should point out that the above agreement does not extend to the specific actions
proposed. This is partly because the actions have been described in a general nature without
supporting data. Also, we cannot specify the method of compliance with effluent limitations.
It is the ultimate responsibility of Shell to do what is necessary to maintain compliance with
the 5.8 lb/day limit. If the actions outlined in your plan turn out to be insufficient to keep
the discharge at or below 5.8 lb/day, we will consider it as failure to achieve the no net
increase standard and a violation of Order No. 91-099.
If you have any questions, please contact Lila Tang at (510)286-0911.
Sin I;�l ,
111
Steven R. Ritchie
Executive Officer
STATE OF CALIFORNIA PETE WILSON, Govemor
CALIFORNIA REGIONAL WATER QUALITY CONTROL. BOARD
SAN, FRANCISCO BAY REGION „ a
2101 WEBSTER STREET, SUITE 500
OAKLAND, CA 94612
(510) 2861255
M AY 4 1994
File No. 2119.1042 (LWT)
Mr. Joel Harmon
Manager, Environmental Conservation
Shell Oil Company
Martinez Manufacturing Complex
P.O. Box 711
Martinez, CA 94553
Subject: Delayed Coker Selenium Removal Pilot Study
Dear.Mr. Harmon:
We have reviewed the memo transmitted in your letter of April 27th. The memo
summarizes the pilot studies Shell performed on the use of the delayed coker quench cycle to
remove selenium from concentrated stripped sour water. Based on the information
presented, we are satisfied that this will be an effective means of reducing the amount of
selenium contributed by the Clean Fuels Project. Of course, as we have stated in previous
correspondence, depending on the degree of effectiveness of this measure, other measures
may have to be implemented to achieve the requirement for no net increase of selenium in
the discharge.
If you have any questions, please contact Lila Tang at (510)286-0911.
S' ce' y,'
it
Steven R. Ritchie
Executive Officer
SHELL MMC CLEAN FUELS 27 April 1994
' Job 22500-600
PROTOCOL FOR VERIFYING NOISE EMISSIONS
FROM INDIVIDUAL PROCESS UNITS
SHELL MMC CLEAN FUELS PROJECT
1.0 INTRODUCTION
1.1 Purpose
The purpose of this document is to define the requirements for verifying that the
noise emitted by the equipment in each operating Unit of the Clean Fuels Project
(Unit) complies with the applicable Contra Costa County Community
Development Department's noise limit (County Limit). The reference documents
cited in Section 10 will be considered as part of this Protocol. In case of conflict,
the provisions of this Protocol will prevail.
1.2 The Noise Criteria
The Project Environmental Basis for Design commits to designing the facility to
meet the County Limit established in the Land Use Permit Number 35 of the
Contra Costa County Community Development Department. The County Limit
requires that the noise from each operating Unit shall not exceed 77 dBA, when
measured at 5 feet above the ground and at a distance of 100 feet from the Unit
equipment. For the purpose of this Protocol, the distance shall be measured from
the Unit equipment perimeter. The Unit equipment perimeter is defined as the
surface of a vertical rectangular prism that circumscribes all the equipment items,
including intra-unit piping, that constitute the Unit. The faces of the prism will
run parallel to the plant grid lines or to the Unit boundary lines as shown in the
plot plans. Henceforth, the circuit at 100 feet from the equipment perimeter will
be referred to as the 100-foot circuit. The relationship of the 100-foot zircuit to
the Unit equipment perimeter is illustrated in Figure 1.
2.0 INSTRUMENTATION REQUIREMENTS AND PERSONNEL
QUALIFICATION
2.1 Instrumentation
The primary instruments required to verify compliance will include, as a
minimum, an instantaneous reading sound level meter or an integrating sound
level meter capable of providing statistical and energy-averaged sound level
readings. Instruments used in the noise verification measurements will satisfy the
following requirements:
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o Sound level meter system including microphone will be Type 1 per
ANSI SIA (Reference 1)
o Octave-band filter set will be Type E, Class II per ANSI-S1.11
(Reference 2).
2.2 Calibration of Instruments
The sound level meter system will be calibrated before and after each set of
measurements using a sound level calibrator. All sound measuring instruments
will have current certification of NIST traceable calibration.
2.3 Personnel Qualification
Measurements will be performed by an individual who is a registered
Professional Engineer (PE) or a member of the Institute of Noise Control
Engineering (INCE) and who has at least five years' experience in noise control
engineering, or by an individual trained and experienced in performing noise
verification measurements in refinery facilities and supervised by a PE or an
INCE Member with the requisite experience.
3.0 CONDUCTING MEASUREMENTS
3.1 Sound Level Readings
All sound pressure level measurements will be made in accordance with the ANSI
S 1.13 (Reference 3). When taking sound level readings, the meter will be placed
in the A-weighting and "slow" response mode. A suitable windscreen over the
microphone of the sound level meter will be used at all times. No measurement
data will be taken when the wind speed exceeds 10 mph.
3.1.1 Direct Readings
If a direct-reading meter is used, the recorded reading will be taken as the mean
position of the indicator needle (for an analog meter) or by the central tendency
reading of a meter that provides a digital readout.
3.1.2 Statistical or Integrated Readings
If an integrating sound level meter is used, the readings will be expressed in
terms of a L5o level. The L5o is the A-weighted sound level that is exceeded 50
percent of the time. The readings in dB will be carried to one decimal place.
3.2 Measurement Locations
A minimum of 20 measurement locations will be used to confirm compliance of
each Unit with the County Limit. These locations will be distributed more or less
evenly around the 100-foot circuit as defined in Section 1.2. Six locations will
be located on each of the two long sides and 4 locations, on each of the two short
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sides of the circuit. However, if one side of a Unit is exempt from measurement
under the provisions of Section 6.4, then only 16 or 14 locations would be
required, depending on whether a short side or a long side is exempt. In general,
the measurement locations can be located away from areas of high background
noise level in order to yield more reliable data on the Unit operating noise.
3.3 Operating Conditions
Unit operating noise measurements will be conducted as soon as feasible after the
Unit has reached a sustained and stable operation. Measurement will made while
the Unit is operating normally and as near its normal operating capacity as
feasible.
4.0 BACKGROUND NOISE MEASUREMENTS
4.1 Baseline Background Noise Measurement
With existing.MMC facilities in normal operation, the baseline background noise
will be measured before the startup of the first Unit at measurement locations
around and between the new process Units. A minimum of 15 measurement
locations will be used. To the extent feasible, these locations will be defined so
that repeat measurements can be made at the same locations.
4.2 Incremental Background Noise Measurements
The background noise around each Unit will be updated before each adjacent Unit
is brought into to normal operation. The incremental background noise level will
be used to correct the operating noise readings as described in Section 5.2 and
section 5.3 as needed.
5.0 METHODS FOR VERIFYING COMPLIANCE
Noise from adjacent Units is likely to affect making measurements to verify
compliance with the 77 dBA limit at 100 feet from equipment. If a level is
measured above 77 dBA, the normal approach would be to shut down all adjacent
units and repeat the measurements. Unfortunately, it is virtually impossible to
shut down process Units while noise measurements are made. The measurement
approach involves providing a series of measurement methods; if one method
doesn't work or isn't applicable, then the next method is to be used.
5.1 Direct Measurement Method
Direct measurement of the normal operating noise will be made at the locations
described in Section 3.2.
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5.2 Correction for Background Noise Method
The. effect of the background noise will be removed from the Unit operating
noise readings. To use this method, it will be necessary to record the current
background noise readings prior to start-up of the subject Unit as described in
Section 4. The measured background noise level at each measurement point will
be subtracted logarithmically from the total. (operating and background) Unit
noise level measured at the same point.
5.3 Measurements Made at Reduced Distance Method
In situations where the Unit equipment perimeter is too close to adjacent facilities
or the background noise level is too high, the measurement circuit may be chosen
to be at less than 100 feet, but more than 25 feet from the Unit equipment
perimeter. The measured noise level will be adjusted for the background noise
and extrapolated to 100 feet using the EEMUA procedure (Reference 4).
5.4 Noise Modelling Method
When a Unit is flanked on two or more sidles by facilities that are less than
100 feet away or when the background noise level around the Unit is too high
for determination of noise emission from the Unit, compliance with the County
Limit will be substantiated by calculation using a validated noise model for the
Unit. The data measured near equipment (usually 3 feet) will be. used to refine
the noise model to accurately reflect the as-built condition. The model will be
validated by comparing the predicted and the measured levels at several locations
where the background level is low. The validated noise model will then be used
to calculate the noise level on the 100-foot circuit and thereby confirm that the
noise levels from the Unit comply with the County Limit.
6.0 MEETING THE NOISE LIMIT
6.1 Separate Side Consideration
Compliance of the Unit operating noise levels with the County Limit will be
considered on a side-by-side basis. This means that each side may be verified by
the methods of Section 5 without consideration of how noise on the other sides is
being verified.
6.2 Logarithmic Averaging of Noise Level
For each side of a Unit, the measured noise levels will be logarithmically aver-
aged according to the EEMUA procedure (Reference 4) to generate the represen-
tative operating noise level for that side. This averaging method will be applied
after the operating noise levels have been corrected for the background noise if
such correction is justified. If the average sound pressure level for that side is 77
dBA or below, then the County Limit is considered to be met for that side.
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6.3 Order of Verification
The methods of compliance verification described in Section 5 are to be
attempted according to the order presented. This means that the method of
Section 5.1 should be attempted first, then that of Section 5.2 second, etc.
6.4 Waiver of Verification Requirement
Verification of compliance is not required for the side of a Unit when the separa-
tion between the subject Unit equipment perimeter and an adjacent Unit equip-
ment perimeter is less than 100 feet. In such a case, demonstration of compliance
is still required by measurements on the other three sides. If the said condition
exists on two or more sides of a Unit, then the methods of Section 5 will be used
to substantiate compliance.
7.0 REMEDIATION PROCEDURE
7.1 Additional Measurements
If the result of the measurements indicates that the operating noise from a Unit
exceeds the County Limit, the cause of the exceedance will be determined by
conducting additional measurements. Such measurements will be used to identify
and characterize the major noise emitters.
7.2 Retrofit Noise Mitigation
Based on the data from Section 7.1, appropriate noise mitigation measures will be
selected. The design of the retrofit noise controls will adhere to the established
Project engineering design standards. The verification measurements will be
performed after the noise controls have been implemented.
8.0 NOISE CERTIFICATION REPORTS
A brief noise certification report for each Unit will be issued following comple-
tion of the field measurements for that Unit. The report will contain a descrip-
tion of the measurements and the results and will-substantiate compliance with the
County Limit.
9.0 ANNUAL REPORTING
An annual report will be submitted until all of the new Process Units meet the
County Limit. This annual report will summarize the status of each new Process
Unit in meeting its noise limit.
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• P ,
r
10.0 REFERENCES
1) ANSI S 1.4, Specification for General Purpose Sound Level Meters
- 2) ANSI S1.11, Specifications for Octave-band and Fractional Octave-band
Analog and Digital Filters
3) ANSI S1.13, Methods for the Measurement'of Sound Pressure Levels
4) EEMUA Publication No. 140, Noise Procedure Specification,
(formerly OCMA Specification NWG-1)
Measurement Circuit
(5 feet above ground)
Unit Boundary
F Z----- --------1
100 feet i Unit Equipment Perimeter
(Typical) I 1
I
�— Equipment Footprint I
1 (Typical) I
I
i 1
1 I
1
I
1 ❑ I
1 1
1 1
I---------- -------------
Figure 1 - Layout of a fictitious unit used to illustrate the definition of
the equipment perimeter planes and the measurement circuit.
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06%111/94 16: 15 $ F. 02
t;OM d TVi, A'"A�i/ce,6-, CITIZENS
FOR
6/13/94 A
Menlo to: Contra Costa County Supervis(irs BETTER
From: Citizens.for a Better EnvironmentENVIRONMENT
Fie: Shell Reformula ed Fuels imtation
Shell is providing design'plans and future monitoring plans in order to show that
they.will be,in Compliance with their permit conditions on certain issues such as
Noise, Odors, and Selenium. - Given the short time for re0ewing theseissues, we
have the following brief comments:
• Shell's plans need to show that their designs will not preclude compliance with
other environmental recluircln.ents which are outside the County permit
For example, on Selenium:
--> if Shell builds too little capacity for evaporation of selonium laden water in
the coker, .Shell may be designing non-compliance into the project.
-> Shell -is currently out of compliance. with their selenium discharge'
requirements.
>.While-the new designmay not cause an increase it. selenium discharge, the
design must also show lhGat they will .not preclude,Shell from making reductions
in selenium.in the future so. that Shell can collie Into compliance with water
quality starndards.
--5The County should mistilt the innununity groups (such as C:alpirg) currently
involved in the lawsuit on Shell's selenium discharge violations,-aid should
wait for the 'court decision of June 20 before considering approving Shell's plan. ..
• Shell. must show that they will remain in compliance during construction,
startup, and non-steady state operations that cause upset conditions.
-->' For example, on Odor issues, we saw no information indicating that odors
were evaluated for-refinery upset condition. releases, rather than for ongoing
emissions.
--> Upset conditions are probably the main source of odors and must be
evaltlaied.
We urge the 13oard of Supervisors to require that Shell provide plans and
documentation to prevent these problems, and provide at least2 weeks' time for
public review before considering approval.
State Headquarters: 501 Second Street, Suite 305 San Francisco, CA 94107 (415) 243-8373
88 First Street, Svlte 203 122 Lirwoh;Blvd:, Suite 201