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A#l� Contra
TO: BOARD OF SUPERVISORS Costa
FROM: HARVEY E. BRAGDON County
DIRECTOR OF COMMUNITY DEVELOPMENT
DATE: April 25, 1995
SUBJECT: Ratification of the Zoning Administrator's Decision Regarding Shell Oil
Company's Compliance with Conditions of Approval (LUP 2009-92)
SPECIFIC REQUEST(S) OR RECOMMENDATIONS) & BACKGROUND AND JUSTIFICATION
RECOMMENDATIONS
Ratify the Zoning Administrator's decision that Shell Oil Company
has complied with Condition of Approval #22 for the
Decyclohexanizer and the FLARE Units.
FISCAL IMPACT
None.
BACKGROUNDIREASONS FOR RECOMMENDATIONS
When the Board of Supervisors approved the Land Use Permit for
Shell Oil Company's Clean Fuels Project (County LUP #2009-92) , the
Board specified that the Zoning Administrator's decision regarding
several conditions of approval be placed on the consent calendar
for ratification. As directed by the Board at the October 4, _ 1994
meeting, the Zoning Administrator's decisions discussed herein have
been placed on the Zoning Administrator's agenda for April 24,
1995. Any comments received at the meeting will be forwarded to
the Board.
CONTINUED ON ATTACHMENT: XX YES SIGNATU 9
/ RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION F OARD COMMITTEE
APPROVE OTHER
SIGNATURE(S) :
ACTION OF BOARD ON April 25-, 1995 APPROVED AS RECOMMENDED x OTHER
VOTE OF SUPERVISORS
I HEREBY CERTIFY THAT THIS IS A
x UNANIMOUS (ABSENT 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 Person: Catherine Kutsuris - 646-2036
Orig: Community Development Department ATTESTED April 25 , 1995
cc: Health Services Department: RMPP PHIL BATCHELOR, CLERK OF
Shell Oil (via CDD) THE BOARD OF SUPERVISORS
I-AND UNTY MINISTRATOR
BY , DEPUTY
Ratification of decision on Shell Oil Company
April 25, 1995
Page Two
Condition of Approval #22 : Hazard and Operability Study
This condition requires Shell Oil to prepare a Hazard and
Operability Study and accident consequence analysis for all
elements of the Clean Fuels Project with the exception of the
office building, the control rooms and the maintenance/warehouse
buildings.
Shell Oil Company completed the required study for the
Decyclohexanizer and the FLARE Units. This information was
evaluated by the Risk Management and Prevention Program Team of the
Health Services Department. Their review included a detailed
examination of the hazard analyses and off-site consequences as
well as scrutiny of all the programs or aspects of the Company
(e.g. , operating procedures, preventive maintenance programs and
operator training) which are designed to prevent or mitigate
accidents or process anomalies. The review included document
assessments, management and operations personnel interviews and
process "walk through" to verify documentation. In addition,
Health Department staff inspected the units to verify that the
construction conforms to the design specified.
The Health Services Department made several recommendations to
reduce the probability or severity of accidents (refer to the
attached HSD memorandums) . These recommendations were accepted by
the Zoning Administrator and will be required of Shell Oil. The
Health Services Department will conduct follow-up field inspections
to ensure that all recommendations have been followed.
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4/12/95
=s `=° Contra Costa County
Department
Health Services De
p
•. �� ENVIRONMENTAL HEALTH DIVISION
OS,T'q,COU
HAZARDOUS MATERIALS/OCCUPATIONAL HEALTH
DATE: 4/11/95
.TO: Catherine Kutsuri , ounty Zoning dministrator, Community Development
Department
FROM: Lewis G. Pascalli,
Deputy Director '
Health Services Depart ent azardous Materials Division
SUBJECT: CONSENT ITEM FOR SHELL REFINERY CLEAN FUELS PROJECT
CONDITION#22
Executive Summary:
The Contra Costa County Health Services Department(CCCHSD)Hazardous Materials Risk
Management and Prevention Program team has completed the Clean Fuels Project reviews for Shell
Refinery's flare unit, scheduled for start-up on May 9, 1995.
Flare Unit Description:
A new flare system is being installed to service the Clean Fuels Project (CFP) units. The CFP
flare system consists of a collection header, liquid knockout facilities, two flare gas recovery
compressors, a seal drum, seal drum liquid handling facilities, and a multi-point gas oxidizer.
The normal function of the flare gas collection header is to direct vent gases to the suction of the
flare gas recovery compressors for recycle to the process. In emergencies, when the flow of gases
or vapor in the flare header exceeds the capacity of the flare compressors, the excess gases and
vapors are directed to the multi-point gas oxidizer for combustion with any liquid being removed
in the liquid knockout facilities. Combustion reduces odors and converts hydrocarbons to carbon
dioxide and water.
The vapors and gases recovered by the flare gas recovery compressors are eventually directed to
the fuel gas system.
My staff has performed a detailed line-by-line examination of the Process Hazards Analysis performed
for flare system mentioned above. Design of safety systems has been addressed. Additionally, my
staff has inspected each ofthe'units to verify that each conforms to the design developed.
4833 Pacheco Bo ulevard Martinez"Califomia 94553 G (510) 646-2286
Page 2
As a result of the review performed by the Risk Management and Prevention Program Engineers, the
following action item is recommended. This recommendation is consistent with sound engineering and
common practice, and would ensure a high degree of reliability in the key instrumentation of the flare
systems:
1. Since the flare system is the an important feature in preventing an offsite
consequence and ensuring system safety during an emergency situation, several
key instrumentation and control systems associated with the flare system shall
be tested and calibrated.
For these flare system components which have been identified as benefiting
from enhanced reliability, Shell shall perform a quantitative analysis to
demonstrate the frequency of testing and calibration required to ensure a 95%
minimum confidence level of device availability and reliability. This frequency
shall be proposed to CCCHSD for review and acceptance within 6 months of
the date of this letter:
a) 2 process oxygen analyzers at Flare Gas Recovery Compressors.
b) 4 high temperature and 2 low suction pressure shutdowns of Flare Gas
Recovery Compressors
c) high-level detection on the Flare Gas Recovery Knock Out Drums to the
Flare Gas Recovery Compressor(s)inlet
d) low pressure detection/alarm on the Clean Fuels Flare natural gas supply to
the pilots
e) pressure detection on the Flare Gas Header
The testing frequency for any other Clean Fuels Flare instrument or control system that meets the
criteria for designation as a key process parameter should be consistent with the proposed testing
procedure currently under development by Shell staff.
My staff will perform a follow up review, consistent with Condition#23 of the Land Use Permit,to
ensure that all mitigations identified by Shell, as well as those listed in No. 1 (above), have been
implemented. A report of the follow up review will be submitted to the Zoning Administrator.
Conclusion:
CCCHSD,Hazardous Materials Division Staff has completed the review of the flare system units at the
Shell Martinez Refinery. With the exception of the above mentioned recommendation,we have
concluded that identified hazards and items of concern have been resolved. Once each unit is
functional, my staff will perform a follow-up review to ensure that outstanding recommendations have
been implemented.
Contra Costa County
„H :4 Health Services Department
ENVIRONMENTAL HEALTH DIVISION
ST”COlJN�
HAZARDOUS MATERIALS/OCCUPATIONAL HEALTH
DATE: April 11, 1995
TO: Catherine Kutsuris, County Zoning Administrator,
Community velopmen�' ,partment
FROM: Lewis G. Pa
Ili, J
Deputy Director
Health Services Dep me , Hazardous Materials Division
SUBJECT: CONSENT ITEM FOR SHELL REFINERY CLEAN FUELS
PROJECT, CONDITION #22, DECYCLOHEXANIZER (DCH) UNIT
Executive Stonmary:
The Contra Costa County Health Services Department (CCCHSD) Hazardous
Materials Risk Management and Prevention Program team has completed the
Clean Fuels reviews for the Shell Martinez Manufacturing Complex
Decyclohexanizer (DCH), scheduled for start-up on May 16, 1995. Shell submitted
a summary of the DCH/ISOM Hazop to your office on January 17, 1995 with a copy
to CCCHSD.
Process Descriptio»:
The DCH is located in the northeast section of the C5/C6 Isomerization Unit (ISOM).
The purpose of the ISOM will be to reduce benzene while increasing the octane of
light gasoline components. The ISOM is being reviewed separately from the DCH.
The Decyclohexanizer Unit consists of feed preparation and a distillation column
that separates cyclohexanes and other benzene precursors (C6 napthenes) from
heavier naphtha. Benzene, benzene precursors, and lighter material go the
Isomerization Unit. The heavier naphtha is Catalytic Reformer Feed.
The Feed Preparation Section provides preheat for the DCH feed streams (Naphtha
from Sats Gas Plant, Gasoline Column Bottoms, and Naphtha from Naphtha
Hydrotreater Stabilizer Bottoms) and also provides reboil heat input for the DCH
column.
4333 Pacheco Boulevard • Martinez, California 94553 • (510) 646-2286
2,1 Block Flow Diagram (Figure 1)
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Isom/DCH HAZOP Summ Page 10
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CCCHSD FIndines:
My staff has performed a detailed line-by-line examination of the Hazard and
Operability performed for the DCH Unit. Design of safety systems as well and
operational and maintenance issues have been addressed. Additionally, my staff
has inspected the unit to verify that the construction so far conforms to the design
specified.
As a result of the review performed by the Risk Management and Prevention
Program Engineers, the following changes are required to reduce the probability or
severity of accidents to less than significant:
1. A "check valve" was installed to prevent backflow through the ISOM feed
line. Backflow could result in a hydrocarbon release. The installation of the
check valve reduced the accident scenario to "less than significant".
However, the check valve can not be expected to be reliable unless it is
regularly inspected. Shell has agreed to inspect this check valve at least as
frequently as "Class 1" critical service check valves.
2. Shell has installed tandem seal systems in the DCH pumps. Tandem
seals provide a back-up seal in the event that the primary seal fails, thus
reducing fugitive emissions and the potential for hydrocarbon releases due to
pump leaks. Shell has agreed to perform a hazard analysis of the tandem
seal system prior to DCH start-up to ensure tandem seal reliability.
3. Shell has provided emergency isolation (XV-940 and 941)) valves in case of
a significant hydrocarbon release (e.g., piping break). Shell has agreed to
test the valves frequently enough to ensure a minimum of 95% availability of
the emergency isolation valves and associated shut-downs.
Shell has also agreed to inspect all Protective Instrument Systems frequently
enough to ensure a minimum reliability of 95%.
According to the Guidelines for Engineering Design for Process Safety,
published by the American Institute of Chemical Engineers' Center for
Chemical Process Safety (CCPS), "No safety system can be presumed
to perform its intended function under abnormal conditions every time.
In a normally operating continuous process, the safety components
remain in one position over an extended period of time and may
become fixed. It is therefore mandatory to conduct regularly scheduled
testing to exercise these components periodically and thus ensure
operation."
Shell DCH, Page 2
4. Shell has not provided automatic low flow recycle lines for the DCH
pumps because the pumps are not expected to run below the minimum design
flow rates. Shell has provided low flow alarms to alert the operators to
potentially damaging low flow rates so that they can manually increase flow
to protect the pumps. Shell has agreed to test the alarms/flow indicators
routinely, at least during every turnaround, to ensure that adequate flow is
not lost to the pumps.
My staff will perform a follow-up review, consistent with Condition #23 of the Land
Use Permit, to ensure that all mitigations identified have been implemented.
condusiom
CCCHSD, Hazardous Materials Division Staff, has completed the review of the
Decyclohexanizer Unit at the Shell Martinez Manufacturing Complex. With the
exception of the above-mentioned recommendations, we have concluded that
identified hazards and items of concern have been resolved. Once construction is
complete, my staff will perform a follow-up review to ensure that outstanding
recommendations have been implemented.
Shell DCH, Page 3