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TO: BOARD OF SUPERVISORS WJIa
<.,
FROM:
Ad Hoc Committee on Industrial Safety
County
Supervisor Jeff Smith
Supervisor Mark DeSaulnier
DATE: June 25, 1996
SUBJECT: Report on Shell Oil Company's Compliance with Land Use
Permit No. 2009-92
SPECIFIC REQUEST(S) OR RECOMMENDATION(S) & BACKGROUND AND JUSTIFICATION
RECOMMENDATIONS
FIND that Shell Oil Company is in compliance with Land Use permit
No. 2009-92 (Conditions 2C, 22, 23, 80 and 81) ;
FISCAL IMPACT
None.
BACKGROUND/REASONS FOR RECOMMENDATIONS
On April 23, 1996, the Board referred to this committee
consideration of Shell Oil Company's compliance with land use
permit conditions 2C, 22, 23,- 80 and 81. The addition of a safety
officer from the Oil, Chemical and Atomic Workers (OCAW) , an
accident review and audit implementation plan, and an air
monitoring procedure would be used to make the decision regarding
Shell 's compliance with these conditions.
A. Safety Officer: Shell presented their plans for appointing a
Health and Safety Representative from OCAW (refer to
Attachment 2) . Shell and OCAW have discussed this issue since
1993 when it was raised as a National Oil Policy item during
the contract negotiations. The Company expects to have an
agreement signed within two weeks.
CONTINUED ON ATTACHMENT: YES SIGNATURE
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
APPROVE OTHER
SIGNATURE(S) :
/4f Smith Mark DeSaulnier
ACTION OF BOARD ON June 25, 1996 APPROVED AS RECOMMENDED X�y Oil-HER X
IT IS BY THE BOARD ORDERED that the recommendation as set forth above, regarding
Shell Oil Company's Land Use Permit 42009-92 is APPROVED; and Coprunity Development staff
is DIRECTED to report back to the Board on July 9, 1996, on concerns raised today, including
the status of implementing the presence of a safety inspector.
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.
Orig: Catherine Kutsuris, CDD (5-1235) ATTESTED June 25, 1996
cc: Community Development Department
Shell Oil (via CDD) PHIL BATCHELOR, CLERK OF
THE BOARD OF SUPERVISORS
AND CO NTY ADMINISTRATOR
BY � , DEPUTY
COK\aw
J:\6-25SHEL.B0
Shell Oil Company
June 25, 1996
Page Two
B. Accident Review and Audit: Shell reviewed their accident
review and audit practices. The Committee requested Shell to
expand the use of the Community Advisory Panel and
notification to the public following an accident (refer to
Attachment 1) .
C. Air Monitorina: Shell reported on their air monitoring program
(refer to Attachment 3) . The one year pilot program will
operate through the end of 1996. Since the program is still
in the pilot stage, the Committee did not request any changes
at this time.
j:\6-25shel.bo
Attachment 1
SHELL MARTINEZ REFINING COMPANY
INCIDENT INVESTIGATION/AUDIT PRACTICES
INCIDENT INVESTIGATION
The Incident Investigation for the April 1 fire serves as an example of our current
practice. This investigation included a broad range of very qualified people, including
three persons selected by OCAW to serve on the team along with a number of Shell
Martinez engineers and experts from Shell's Westhollow Technology Center in
Houston. The investigation required over a week of intensive study to assure that the
true cause of the incident was identified. After the initial investigation a Root Cause
Analysis Team was formed to be certain we understand all of the 'why' behind this
failure. CalOSHA and the County Health Services Department have been apprised of
the progress of the investigation teams and have interviewed some of the team
members. The results of the investigation were also presented to the Shell Community
Advisory Panel (CAP).
A critique of the emergency response was conducted with firefighters and with the
responding agencies. In addition, a public workshop is scheduled on June 12 at the
City Council Chambers in Martinez that will provide the public an opportunity to make
known their concerns.
INTERNAL AUDITS
A number of internal audits are conducted at the Shell Martinez Refining Company in
the area of Process Safety. An OSHA PSM (Process Safety Management) Self Audit is
conducted every three years under the direction of the Refinery PSM Steering
Committee. This committee includes one member from IBEW and one member from
OCAW. The actual audit team includes one member of OCAW and one member of
IBEW. In addition, quarterly audits are conducted that include compliance with PSM
along with compliance with other safety related standards. The audits are rotated
around the departments in the refinery and are chartered by the joint
Union/Management Health and Safety Committees. Every three to four years, a Shell
Oil Company Corporate audit team comes to the Refinery to assure our compliance
with both regulatory standards and Shell policy.
AGENCY AUDITS
The County Health Services Department conducts an annual inspection of compliance
with the requirements of AB2185. The County can currently conduct audits that are
process safety related through the auspices of the RMPP Program.
PENDING REGULATION
The Federal EPA RMP regulation was signed on May 24, 1996. This regulation is
essentially a mirror of the OSHA Process Safety Management (PSM) regulation. It
does add additional requirements for Off-site Consequence Analyses and a Risk
Management Plan. The Administering Agency for this regulation in Contra Costa
County will be the Health Services Department.
EXPANSION OF INVOLVEMENT
Shell commits to the continued inlcusion of Union representatives in the investigation of
major incidents. Members of the Shell CAP are routinely updated on all Health and
Safety Activities in the Complex. These updates will include results of incident
investigations and audits. Shell also commits to conducting or participating in a public
meeting following all major incidents with significant off-site impact to discuss results of
the incident investigation and other appropriate issues related to the incident.
Attachment 2
Shell Martinez Refining Company
OCAW Health & Safety Rep Overview
Background
• Initially raised as National Oil Policy item by OCAW for 1993 contract negotiations
• Many competitors of Shell, all with poorer safety records, reached agreement during
or subsequent to 1993 negotiations
Agreement in 1993 was for companies "to attempt to develop a plan for utilizing the
union represented employees from the local bargaining unit toward the objective of
improving health and safety in the plant."
• Most competitors have reached an agreement for a Health & Safety Rep and have
followed basic model acceptable to OCAW
Covered areas include-
- Employee Selection
- Length of Assignment
- - Job Duties
- Pay
- Training
• Shell/OCAW had many follow-up discussions, including making formal offers,
regarding the topic subsequent to 1993 negotiations, however, the parties could not
reach formal agreement
1996 Negotiations
• Brought forward by OCAW as negotiation item
• Significant discussions took place trying to reach resolution on a couple of issues
• Could not reach resolution at negotiating table
• Agreed to resolve all other matters in negotiations and continue discussions after
contract settlement and after formation of new company and appointment of CEO
Recent Developments
• Formation of_Shell Martinez Refining Company-4/1/96
• Discussions delayed due to April 1 incident
• Informal discussions with local Union officials last few weeks
• Talks are progressing well, expect to make a formal proposal soon
• Optimistic that formal agreement will be reached
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Intentionally Blank
Attachment 3
HIGHLIGHTS OF SHELL MARTINEZ REFINING COMPANY PILOT REMOTE
OPTICAL MONITORING PROGRAM
• The most probable material to be involved in an accidental release from a refinery is a
hydrocarbon mixture.
• The Hawk infra-red monitoring system is capable of detecting low level (less than 1 ppm)
concentrations of hydrocarbon mixtures along a 257 meter path.
• The pilot monitoring system was installed adjacent to Shell's fenceline near the residential
area north of Pacheco Boulevard, in the Ace Hardware area.
• Typical "background" levels monitored at the fenceline are in the same range as those
monitored in the grassy area at the Martinez Waterfront Park. This area is typically upwind
of the refinery.
• Details of this fenceline monitoring system were presented by Shell Research at the Air
and Waste Management Association's conference on Optical Remote Sensing for
Environmental Monitoring held in San Francisco in September, 1995.
• BAAQMD reviewed Shell's monitor installation, and verified its operability by testing its
response to a controlled propane release in the monitoring path.
• Shell has agreed to pilot the monitor for 12 months. Since some difficulties were
encountered in the initial quarter, Shell plans to extend the monitoring program through the
3rd quarter, 1996. A report of the results will be issued when the pilot period is concluded.
• This monitoring system supplements an existing ground level monitoring network consisting
of 4 HzS and 1 SO2. monitors. The existing ground level monitoring network has been in
service for a number of years.
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Contra Costa County
Community Development
651 Pine Street
North Wing, 4th Floor
Martinez, CA 94553
THE MARTINEZ REFINERY FENCE LINE MONITOR
Background
In a 1994 agreement with Communities for a Better Environment and Communities for a Safe
Environment, all parties agreed that Shell would install a Hawk infra-red pilot remote sensing
monitoring system along the refinery fenceline. Its purpose was the rapid detection of an
accidental release of hydrocarbons. Its installation would supplement the existing network of 5
ground level monitoring stations which currently measure sulfur dioxide and hydrogen sulfide.
The information gathered by the ground level monitoring network is summarized and provided
to the BAAQMD on a monthly basis.
Why We Chose the Siemens"Hawk"
In choosing the Hawk system we were guided by the types of chemicals present at our facility
and the ability of the various monitoring techniques to detect individual compounds. The
refinery processes crude oil in order to manufacture gasoline and other fuels. As a result,
complex hydrocarbon mixtures containing paraffins (straight chain and branched) and
aromatics (benzene, toluene, and xylenes) are present throughout the refinery.
Several chemical plants have perimeter monitoring systems which feature Fourier transform
infrared instruments (FTIR). While FTIR is very good at detecting less than 20 ppb of
chemicals containing oxygen, chlorine, or nitrogen atoms bonded to hydrocarbons ( such as in
acetone, vinyl chloride , or ammonia) it is not particularly sensitive toward aromatics such as
benzene. While lower detection levels for aromatics are possible with open path ultraviolet
monitoring systems, these are just now (1996) becoming available and have not been fully
evaluated.
Consequently, we believed that the best way to demonstrate the integrity of our processing
operations and detect accidental releases was to install an open path remote sensing system
for hydrocarbons. Detecting trace levels of hydrocarbons as a chemical class serve as a
surrogate for sensing releases of particular members of the class of concern, e.g. benzene
and other aromatics, or odorous compounds, e.g. the organic mercaptans. These species are
always accompanied by the presence of larger amounts of other hydrocarbons.
The system that was selected was one developed in Great Britain by researchers at the
National Physical Laboratory (similar to our National Institute of Standards and Technology)
and manufactured by Siemens as the "Hawk". Numerous units are in place at European
refineries and ours was the first in the US. It operates in the infrared region using a selective
filter at a wavelength absorbed by all hydrocarbons and is a very sensitive monitor, capable of
detecting 9 ppb of propane across a 350 meter path.
17
6
Installation
The system was installed in April, 1995 several hundred meters, predominantly downwind,
from the major Light Oil Processing Unit along the refinery fence line near Pacheco Blvd.
Hydrocarbon concentrations are measured along a 257 meter path at an elevation of 13 feet
above ground level (to avoid interference from parking lot activities). Both the optical module,
containing the infrared source, filter element; and detector, and the retro- reflector unit are
mounted on steel I-beams set in concrete to minimize vibration and ensure stability. A multi-
point continuous strip chart recorder with a time/date stamped output is located in an adjacent
instrument shelter (containing ground level ambient air monitors) is used to check diagnostic
signals.
Concentration values are digitally displayed and stored once a minute in the Light Oil
Processing control room to provide a data history that will enable computation of daily average
and maximum levels. An action level is triggered when the signal is above 1/2 full-scale,
equivalent to an average fence line concentration of 2.9 ppm (propane equivalents) for fifteen
minutes or more. In the event of such an excursion, data on wind speed and direction from a
nearby meteorological station will be reviewed along with refinery operations to determine if
the source could be located within the refinery. Concentration data are also reviewed
periodically in order--to see if any increases above normal background have occurred.
Normal Background Levels
The purpose of the fenceline monitoring system was to provide real-time data to facilitate early
detection and response by the refinery staff in the event of an accidental hydrocarbon
release. It was not expected to function as an ambient air analysis system for background
hydrocarbon concentrations. However, a brief comparison between the hydrocarbon levels
found at the fence line and those present at a local "green field" site provided some
perspective on the impact of the Martinez Refinery upon local hydrocarbon levels.
In June 1995 a portable "Hawk" monitor was used by Shell research staff to measure "green
field" background hydrocarbon levels at the Martinez Waterfront Park, adjacent to a local bird
sanctuary. These values were then recorded and the portable system set up at the refinery
fence line site and the measurements repeated along this path. The results from both sites
were within the normal background or noise level of the instrument, indicating that under
standard operating conditions hydrocarbon levels at the refinery fence line are at the baseline
for the surrounding area.
Operating History
After a successful startup in April 1995, the operating problems in July and August (traced to
defective filter motors) led to the replacement of the original optical module. in September.
Since that time the instrument has operated satisfactorily. The baseline was consistent with
levels detected at the Martinez Waterfront Park. The Action level was exceeded five .times
between October, 1995 and April, 1996. In each of theses instances the wind direction
indicated that the sources were offsite and that offsite hydrocarbons were being directed
toward the refinery. The monitoring system was in operation during the fire on April 1, 1996.
No significant changes to the baseline concentrations could be detected during the event.