HomeMy WebLinkAboutMINUTES - 06192001 - D.3 TO: 130:1liD OF SUPERVISORS
Contra
FROM: William Walker,M.D.,Ileal , ' ,ices D' ector
Costa
DATE: June 19,2001
Goo
� 3�
County
SUBJECT: Inherently Safer Systems Request
SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION
RECOMMENDATION: Accept the report from Health Services on the request from the Board of Supervisors on
additional information on Inherently Safer systems.
BACKGROUND: The Industrial Safety Ordinance requires "For all Covered Processes, the stationary
source shall consider the use of Inherently Safer Systems in the development and analysis of mitigation
items resulting from a process hazard analysis and in the design and review of new processes and
facilities."§450-8.016(D)(3). The Board of Supervisors requested from the regulated stationary sources
the inherently safer systems that were considered by each source. The Board of Supervisors also
requested that the regulated stationary sources submit for the inherently safer systems riot
implemented the justifications for not implementing that inherently safer system. Health Services
reported to the Board of Supervisors on April 3 the results of that request.
The Board of Supervisors asked for additional information at the April 3 Board Meeting on Inherently Safer
Systems that included the following:
• Estimated costs for the Inherently Safer Systems = implemented
• A description of all of the Inherently Safer Systems implemented
• For future Inherently Safer Systems considered a description of the Inherently Safer System and
the estimated costs for the Inherently Safer system
Health Services requested this information from the regulated stationary sources on April 6 and asked
for a response back by May 15.
FISCAL IMPACT: NONE
CONTINUED ON ATTACHMENT: YES SIGNATURE:
RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
' APPROVE OTHER
ACTION OF BOARD ��-�/L�I�' APPROVED AS RECOMMENDED _� OTHER
ACCE= the report and DIRFILTED staff to return to the Board with a legal opinion regarding access
to plant records pertaining to Inherently Safer Systems implemented/not implemented.
VOTE OF SUPERVISORS
I HEREBY CERTIFY THAT THIS IS A TRUE
UNANIMOUS (ABSENT�I1Z) AND CORRECT COPY OF AN ACTION TAKEN
AYES: NOES: AND ENTERED ON THE MINUTES OF THE BOARD
ABSENT ABSTAIN: OF SUPERVISORS ON THE DATE SHOWN.
Contact Person: /
CC: Health Services Administration ATTESTED
� v J 4SWEETEN,CL RK OF THE BOARD OF
PAND COUNTY ADMINISTRATOR
BY DEPUTY
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Report to the Board of Supervisors
On Inherently Safer Systems Information Request
Background
The Industrial Safety Ordinance requires "For all Covered Processes, the stationary
source shall consider the use of Inherently Safer Systems in the development and analysis
Of naitiga.ti.ora ite711s resulting frorn a process hazard analysis and in the design and review
of netiv processes and./acilities. " §450-8.016(D)(3). The Board of Supervisors requested
from the regulated stationary sources the inherently safer systems that were considered by
each source. The Board of Supervisors also requested that the regulated stationary
sources submit the justifications for not implementing an inherently safer system if
determined by the regulated stationary source to be infeasible. Health Services reported
to the Board of Supervisors on April 3 the results of that request (Attachment 1). _.
The Board of Supervisors asked for additional information at the April 3 Board Meeting
on Inherently Safer Systems that included the following:
• Estimated costs for the Inherently Safer Systems not implemented
• A description of all of the Inherently Safer Systems implemented
• For future Inherently Safer Systems considered a description of the Inherently
Safer System and the estimated costs for that Inherently Safer System
Health Services requested this information from the regulated stationary sources on April
6 and asked for a response back by May 15.
Response
The Industrial Safety Ordinance is applicable to seven regulated stationary sources:
• Air Products within Equilon
• Air Products within Ultramar
• Equilon
• . General Chemical Bay Point
• Polypure
• Tosco
• Ultramar
Attachment ? is General Chemical Bay Point response to the request from the Board of
Supervisors.
Air Products, Equilon, Tosco, and Ultramar submitted additional clarification on the
different categories for the different Inherently Safer Systems considered (Attachment 3).
These regulated stationary sources were concerned with submitting cost data, since it
could be construed to constitute a violation of state and federal anti-trust laws. These
regulated stationary sources also are concerned that the extremely complex and technical
information could be taken out of context and be confusing to the layperson. They go on
to say that this detailed information is best reviewed by your qualified staff, such as your
CalARP specialists, at their facilities. Copies of their letters are included in Attachment
4.
Health Services audited Polypure in November 2000 and discovered that they had not
considered Inherently Safer Systems for the recommendations that were developed as a
result of their process hazardous analyses. Health Services has required Polypure to
come into compliance with the requirements of the Industrial Safety Ordinance and is
closely monitoring their progress. They are scheduled to reevaluate all of their process
hazard analyses by the end of August 2001 and will consider inherently safer systems for
all of the recommendations that are.the result of the process hazard analyses.
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Industrial Safety Ordinance Report
To the Board of Supervisors
April 3, 2001
Introduction
Health Services presented the annual report on the Industrial Safety Ordinance to the
Board on December 12, 2000. The Board at that time requested more information on
how the regulated stationary sources were implementing the inherently safer systems as
required by the. ordinance. The Board also requested that the Hazardous Materials
Ombudsman work with the Hazardous Materials staff in developing an outreach program
that would improve the public participation in the Industrial Safety Ordinance.
Inherently Safer Systems
What is Inherently Safer Systems
What does inherently safer systems mean and how does the Industrial Safety Ordinance
define it? Section 450-8.014(g) of the County Ordinance Code states that "Inherently
Safer- Systems means Inherently Safer Design Strategies as discussed in the 1996 Center
for Chemical Process Safety (CCPS) Publication Inherently Safer Chemical Processes
and means Feasible alternative equipment, processes, materials, lay-outs, and
procedures meant to eliminate, nzin.irni.ze, or reduce the risk of a Major Chemical
Accident or Release by modifying a process rather tharz adding external layers of
protection. Examples include, but are not limited to, substitution of materials with lower
vapor pressure, lower flanzmability, or lower toxicity; isolation of hazardous processes;
arzd use of processes which operate at lower temperatures and/or pressures."
"Inherently safer design is a fundamentally different way of thinking about the design of
chemical processes and plants. It focuses on the elimination or reduction of the hazards,
rather than on manacrement and control. This approach should result in safer and more
robust processes, and it is likely that these inherently safer processes will also be more
economical in the long run (Trevor Metz)." Implementing inherently safer systems as
defined will reduce the risk of an accidental release from a facility that could have an
offsite consequence.
The CCPS publication Inherently Safer Chemical Processes has classified a strategy for
reducing risk into four categories. "These categories, in decreasing order of reliability,
are:
• Inherent — Eliminating the hazard by using materials and process conditions
which are nonhazardous; e.g., substituting water for a flammable solvent.
• Passive — Minimizing the hazard by process and equipment design features that
reduce either the frequency or consequence of the hazard without the active
functioning of any device; e.g., the use of equipment rated for higher pressure.
• Active — Using controls, safety interlocks, and emergency shutdown systems to
detect and correct process deviation; e.g., a pump that is shut off by a high level
Pane 1
switch in the downstream tank when the tank is 90% full. These systems are
commonly referred to as engineering controls.
• Procedural — Using operating procedures, administrative checks, emergency
response, and other management approaches to prevent incidents, or to minimize
the effects of an incident; e.g., hot-work procedures and permits. These
approaches are commonly referred to as administrative controls."
"Approaches to the design of inherently safer processes and plants have been grouped
into four major strategies by IChemE and IPSG (1995) and Trevor Klet.z:
• Minimize — Use of smaller quantities of hazardous substances (also called
Intensification)
• Substitute—Replace a material with a less hazardous substance
• Moderate — Use less hazardous conditions (e.g., process conditions operated at
lower temperatures or pressures), a less hazardous form of a material, or facilities
that minimize the impact of a release of hazardous material or energy (also called
Attenuation and Limitation. of Effects).
• Sinrplify — Design facilities which eliminate unnecessary complexity and make
operating errors less likely, and which are forgiving of errors that are made (also
called Error Tolerance)."'
Inherently safer design strategies can be applied to any of these risk management
strategies as illustrated below.
'Process*Risk-
Isk
ManageInherent Passive Active Procedural
Strategi
Minimize ...........................................`L.................................................. i
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Substitute ............................................ ..................................................
LModerate ..........................................4.................................................;
Q Simplify i
�.............................
"Finally, in considering inherently safer design alternatives, it is essential to remember
that there are often, perhaps always, conflicting benefits and deficiencies associated with
1Inherent1y Safer Chemical Processes -A Life Cycle Approach A COPS Concept Book., 1996
Page 2
the different options. Chemical processes usually have many potential hazards, and a
change that reduces one hazard may create a new one or increase the magnitude of
different existing hazard. It is essential that the process designer retain a broad overview
of the process when considering alternatives, that he/she remains aware of all hazards
associated with each process option, and that appropriate tools are applied to choose the
overall best option."'`
In the CCPS book Inherently Safer Chemical Processes they "adopt a broad definition.of
inherently safer. The discussion and examples range from basic process chemistry
through details of the design of hardware and procedures. The authors recognize that
some of these more detailed examples may arise in processes that would not be described
as "inherently safer" overall. However, we believe that it is important to encourage
inherently safer thinking at all levels of process and plant design, from the overall
concept through the detailed design of equipment and procedures."
Inherently Safer Systems Submittal
Health Services requested that the Industrial Safety Ordinance regulated stationary
sources submit to Health Services' a list of the inherently safer systems implemented.
Health Services requested that the list for each of the different inherently safer systems
considered to be categorized. Health Services also requested the regulated stationary
sources to list the inherently safer systems that were considered, but were not
implemented with the justification for why the inherently safer systems was not
implemented and not feasible. The request for this information was for PHA's and new
or modified projects that were completed between April 27, 2000 (the effective date of
the amendment to the Industrial Safety Ordinance, County Ordinance 2000-20) and
March 9, 2001.
The total inherently safer systems that were implemented are 565 and are listed in
Attachment A according to the category of the system implemented. The total inherently
safer systems that were not implement are 13. The inherently safer systems that were not
implemented and the justifications for not implementing them are listed in Attachment B.
Public Outreach
A public outreach policy was drafted and sent out for comment to an interested party list.
The draft policy was developed with input from Denny Larson and A. J. Napolis from
Communities for a Better Environment. Health Services received comments from seven
individuals or groups. The final public outreach policy proposal is included in
Attachment C.
The public outreach policy is a three-phase approach with the first phase being a pilot
program to work with the communities surrounding the Tosco San Francisco Refinery at
Rodeo. Health Services would hire an individual or a group to develop and implement a
program for this pilot project. If the pilot project were successful, the second and third
phases would be to implement similar programs in the Martinez and the Bay Point areas.
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Inherently Safer Chemical Processes - A Life Cvcle Approach A COPS Concept Book, 1996
Page 3
ATTACHMENT A
Inherently Safer Systems Implemented
Five hundred sixty-five inherently safer systems will be implemented as the result of
PHA's and new or modified facilities between April 27, 2000 and March 9, 2001. The
list below includes the following:
• The regulated stationary source
• Category for each of the inherently safer systems implemented
o Instrument and Electrical —Instrumentation or electrical modifications
o Piping Systems and Equipment —Evaluations/Modifications to equipment,
specifications, inspection programs/records, replacements, etc.
o Pressure Safety Valves —Installation of new relief valves, modifications to
existing relief valves, service, maintenance, etc.
o Human Factors — Evaluations/modifications to improve personnel and
equipment interface
o Facility Siting — Evaluations/modifications to equipment locations with
respect to processes and their surroundings
o Operational — Evaluations/modifications to improve operability (e.g.,
procedures, locking open valves, etc.)
o Fire Protection/Health and Safety — Evaluations/modifications to
emergency/health and safety equipment and procedures
o Environmental — Evaluations/modifications to address environmental
regulatory requirements
o Documentation —Evaluations/modifications to process safety information
• Process Hazard Analysis or New or Modified Project
• Number of inherently safer systems implement at each of the stationary sources that
are regulated under the Industrial Safety Ordinance
Regulated Process Hazard or Category Number of
Stationary Source New or Modified Inherently Safer
Project Systems
Implemented
Ultramar Inc. Process Hazard Instrument and 28 i
Analysis Electrical
Piping and Systems 41
and Equipment
Pressure Safety 6
Valves
Human Factors 8
Facility Siting 12
Operational 123
Fire 6
Protection/Health
and Safety
Environmental 1
Page 4
Ultramar Inc. Process Hazard Documentation 69
Analysis
New or Modified Instrument and 3
Facility Electrical
Piping Systems and 9
Equipment
Pressure Safety 1
Valves
Human Factors 1
Facility Siting 1
Operational 0
Fire 1
Protection/Health
and Safety
Environmental 0
Documentation 0
Air Products at Process Hazard Instrument and 2
Equilon Analysis Electrical
Piping and 1
Equipment Systems
Pressure Safety 0
Valves
Human Factors 1
Facility Siting 5
Operational 16
Fire 1
Protection/Health
and Safety
Environmental 0
Documentation 15
General Chemical at Process Hazard Instrument and 1
Bay Point Analysis Electrical
Piping and 1
Equipment Systems
Pressure Safety 0
Valves
Human Factors 0
Facility Siting 0
Operational 3
Fire 0
Protect]on/Heal th
and Safety
Environmental 0
Documentation 1
Page 5
Equilon Mai-tinez Process Hazard Instrument and 1
Refining Company Analysis Electrical
Piping and 3
Equipment Systems
Pressure Safety 0
Valves
Human Factors 2
Facility Siting 1
Operational 10
Fire 0
Protection/Health
and Safety
Environmental 0
Documentation 0
Tosco San Process Hazard Instrument and 7
Francisco Refinery Analysis Electrical
at Rodeo
Piping Systems and 76
Equipment
Pressure Safety 11
Valves
Human Factors 9
Facility Siting 8
Operational 37
Fire 8
Protect]on/Health
and Safety
Environmental 0
Documentation 1
Instrument and 0
Electrical
New or Modified Piping Systems and 8
Facility Equipment
Pressure Safety 6
Valves
Human Factors 0
Facility Siting 0
Operational 0
Fire 0
Protection/Health
and Safety
Environmental 0
Documentation 0
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Two regulated stationary sources reported no inherently safer systems considered in the
time that was requested. Air Products at Ultramar did not perform or revalidate any
process hazard analyses between April 27, 2000 and March 9, 2001. Polypure did not
consider inherently safer systems when process hazard analyses were performed. This
was discovered when Health Services audited them in November 2000 and is part of the
preliminary audit findings. Polypure has committed to redoing all of their process hazard
analyses to include inherently safer systems. They will submit the schedule to complete
this work when they respond to the preliminary audit findings that is due on May 14,
2001.
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ATTACHMENT C
Proposal for Improving and Increasing Public
Participation in the Industrial Safety Ordinance
Background
The Contra Costa County Board of Supervisors adopted the Industrial Safety Ordinance
because of concerns about accidents that have occurred at the oil refineries and chemical
plants in Contra Costa County. The ordinance went into effect. on January 15, 1999, and
was amended in March 2000. On December 12, 2000 the Hazardous Materials Programs
presented the first annual Performance Review and Evaluation Report for the ordinance
to the Board of Supervisors. At that meeting, in written and oral comments, Denny
Larson of Communities for a Better Environment complained that the public participation
component of the ordinance's implementation was inadequate. The Board requested that
the Ombudsman for the Hazardous Materials Programs work with staff from the
Hazardous Materials Programs and Communities for a Better Environment to improve
the public participation component. This proposal is the result of that effort.
Regulatory History
In regards to public participation, the Industrial Safety Ordinance states:
450-8.002(D) — Background and Findings — The County recognizes that regulatory
requirements alone will not guarantee public health and safer,, and that the public is a
key stakeholder in chemical accident prevention, preparedness, and response at the local
level. Preventing accidental releases of regulated substances is the shared responsibility
of.industry, government, and the public. The first steps toward accident prevention are
identifying the hazards and assessing the risks. Once information about chemical
hazards in the community is openly shared, Industrv, government, and the comrnu.nit)) can
work together towards reducing the risk to public health and safety.
("E) The success of a Safety Program is dependent upon the cooperation of industrial
chemical and oil refining facilities within Contra Costa County. The public must be
assured that measures necessary to prevent incidents are being implemented, including
changes or actions required by the Department or the Stationary Source that are
necessary to comply with this chapter.
And
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450-8.004(A) — Purpose and Goals — The purpose of this ordinance is to impose
regulations which improve industrial safety by the following:
(5)provide for public input into the Safety Plan and Safety Program and public review of
any inspections and audit results,
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The ordinance also provides for two specific opportunities for public participation:
450-8.018(A) — Review, Audit and Inspection — Upon submission of a Safety Plan by the
Stationary Source, the Department shall review the Safety Plan to determine if all the
elements required by Section 450-8.016 are included and complete. The Department
shall provide to the Stationary Source a written Notice of Deficiencies, if any. The
Stationary Source shall have 60 calendar day,;from receipt of the Notice of Deficiencies
to make any corrections. The Stationary Source may request, in writing, a one time 30
day.calendar(lay extension to correct deficiencies. By the end of the 60 calendar clays or
any extension period, the Stationary Source shall resubmit the revised Safety Plan to the
Department. After the Department determines that the Safety Platz is complete, the
Department shall schedule a public meeting on the Stationary Source's Safety Platt to
explain its contents to the public and take public comments. (emphasis added) The
Department shall make portions of the Safety Plan, which are not protected trade secret
information, available to the public for the pablic meeting.
And
450-8.018(B)(4) Review, Audit and Impection - After receiving the written response
from the Stationary Source, the Dep:_irtment shall issue a public notice per the
Department's Public Participation Policy and make portions of the Safety Plan, the
Preliminary Determination and the stationary Source's responses, which are not
protected trade secret information, avaiiable for public review. Public comments on the
Safety Plan shall be taken by the Depan ment for a period of 45 days after the Safety Plan,
the Preliminary Determination and the Stationary Sources responses are made available
to the public. The Department shall schedule a public meeting on the Stationary
Source's Safety Plan during the 45 day comment period. (emphasis added) The
public meetings shall be held in the effected community on evenings or weekends.
In addition, the Board of Supervisors approved the allocation of$50,000 for the purpose
of continuing the existing community education and outreach effort, including holding
community meetings to seek input on the Safety Plans required under the ordinance
(Board agenda item D.9.5, December 8, 1998).
Current Public Participation Efforts
The Hazardous Materials Programs has developed a written policy for conducting public
participation. That policy requires that when a Safety Plan is complete, Health Services
places a five-inch by four-inch advertisement in the appropriate Contra Costa Times
Newspaper and the San Francisco Chronicle announcing the opening of a forty-five day
public comment period and a public meeting. Health Services also sends letters to
approximately 150 individuals or organizations on an interested persons mailing list,
announcing the public comment period and the public meeting. Thus far, four public
Page 12
meeting for five of the regulated stationary sources' Safety Plans have been held. The
policy calls for the same process to be repeated for the second round of public meetings.
The format of these meeting has been for Health Services to give an overview of the
CaIARP Program and the Industrial Safety Ordinance followed by a presentation by the
stationary source. The stationary source presentations have consisted of overviews of the
facilities' operations, descriptions of their chemical release scenarios, and explanations of
how the accident prevention and emergency response elements required by the ordinance
are implemented. The meetings have concluded with question and answer periods. One
meeting was attended by 6 members of the public, 14 attended one, and two were
attended by no members of the public. The current method of public participation has met
the specific requirements of the Industrial Safety Ordinance as described in section 450-
8.018.
New Public Participation Proposal
The intent of this proposal is to develop a public involvement process that provides the
public the opportunity to participate in a manner that more fully .meets the intent
described in the Background and Findings section and Purpose and Goals section of the
ordinance. This proposal is based on the concept that the public must have access to
substantive information, and must be provided the support necessary to understand that
information, for them to provide meaningful input into the review process.
The type of information that the public can use to participate in this manner include:
• Already available Root Cause Analyses conducted for specific stationary sources, and
new Root Cause Analyses as they become available.
• The recommendations made from the Process Hazard Analyses conducted by the.
stationary sources, which can be requested from the stationary sources.
• Timelines for implementing Process Hazard Analyses developed by the stationary
sources, which can be requested from the stationary sources.
• Already available Incident Notification Reports prepared by Health Services, and new
Incident Notification Reports as they become available.
However, just having this information available to the public is not. enough; additional
support is necessary to help the public understand this information and to understand how
they can use this knowledge to participate in the process. To this end, the $50,000
allocated by the Board of Supervisors should be used to provide support personnel to the
community. This support would be responsible for:
• Promoting awareness of the opportunity to participate in the process to the public;
Page 13
• Meeting with members of the public who are interested in participating to help the
review and understand the available information; and
• Assisting the interested public in preparing comments and voicing their concerns
during the review process.
],his model for public involvement has recently been successfully demonstrated in
several collaborative projects between Health Services and local communities. In the
Crockett/Rodeo area Health Services is working with a local community group to help
residents understand and participate in the development of a refinery fence-line air
monitoring system. Community involvement was accomplished through a series of
meetings with community members in their homes and in small groups. In North
Richmond, environmental educators from Health Services are working with community
members to help them identify the environmental health risks of greatest concern to them
and implement a program to address these priorities. The key to the success of both these
projects has been significant support personnel and open access to relevant information.
To implement this process, we recommend starting with a pilot program in the
Crockett/Rodeo area. This facility will be the first to have their Safety Plan ready for the
second public comment period and public meeting. Health Services should contract with
a consultant or a community group to provide the necessary community support as
described above. Health Services would open the 45-day comment period on Tosco's
Safety Plan approximately six weeks after the support person was hired. This would give
the support personnel enough time to conduct outreach in the community, and to help
interested community members understand the relevant information and prepare to
participate in the public meeting. This process could then be replicated for the stationary
sources in the Martinez and Bay Point areas.
Page 14
EST 2
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General Chemical Corporation General
501 Nichols Road Chemical
Pittsburg, CA 94565-1098
(510)458-7300
APR 2 5 2001
Contra Costa Flealth
Ha=ardO-"s-r02,frria!s
Mr. Randy Sawyer
Hazardous Materials Programs
Contra Costa County Health Services Department
4333 Pacheco Boulevard
Martinez, CA 94553 April 23, 2001
Re: Inherently Safer Systems Lists
Dear Mr. Sawyer:
Enclosed please find the list of inherently safer systems implemented and the estimated
cost of the inherently safer systems not implemented for the Process Hazard Analyses
conducted between April 27, 2000 and March 9, 2001.
We trust this information is satisfactory. Please give us a call if you have any questions.
Sincerely,
P /
!f %
Douglas Eisner
Supervisor, Environmental, Health and Safety
Concise Description Scheduled Justification Estimated
of the Inherently Completion Date for Not Cost
Safer System for Implementing for
Considered Category Implementation (if applicable) Implementing
1. Nitric Acid Process
1. Confirm source of Piping Completed NA $ 3000.
water to heat exchanger System Jan 2001.
in Node 11 and address
safeguards for loss of
coolant flow to heat
exchanger.
2. Consider additional Piping NA Misdirected flow $ 1000.
safeguards if the tailings System through tailing
system block valve is system block valve
left open or is leaking. requires opening of
several valves and
operation of an air
pump.
It. Ammonia Process
1. Change unloading Operational Completed NA $ 250.
procedure to reflect 8/18/00.
proper wording for
ammonia.
2. Verify presence of Operational Completed NA $ 1500.
level alarm. Aug 2000.
3. Investigate remotely Operational. Scheduled NA $ 10,000
operating shut-off valve 6/30/01.
on top of the ammonia
storage tank.
4. Check SOPS to ensure Documentation Completed NA $ 250.
driver instructions are Aug 2000.
included.
5. Verify quantity of Instrumentation Completed NA $None
72" to determine actual Sep 2000.
mass in vessel.
6. Consider reinstalling Pressure Safety NA Liquid and vapor $ 1000.
thermal expansion relief Valves lines are closed at
valves between block valves the block valve, but
on liquid and vapor un- open to the tank. The
loading lines. tank has pressure
safety valves, pro-
viding relief and volume
for expansion.
7. Consider thermal Pressure Safety NA The space between the $ 500.
reliefs between block Valves block valves is open to
valves on liquid transfer the tank. Again, the
line. tank has volume for
expansion and pressure
safety valves.
8. Investigate the use Pressure Safety NA A remote emergency $ 3000.
of auto-flow valves Valves shutoff is in place. The
as isolation. tank is equipped with
excess flow valves. The
auto-flow valves may
introduce additional risk
by trapping gas.
9. Investigate emergency Operational NA Emergency shutdown $ 2500.
shutdown of system, based procedures are initiated
on the need for rapid through one of two
isolation. possible simple, one-step
documented procedures.
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ATTACHMENT 3
ATTACHMENT 1: MODIFIED WORDING TO ISS CATEGORIES
Categories Expanded Descriptions
Instrument and Instrumentation or electrical modifications. Some examples include
Electrical improvement or installation of- new reliability testing systems, alarms,
indicators and controllers,new or modified automatic shutdown devices and
conduct of electrical surveys and system changes.
Piping Systems and Evaluations modifications to equipment, specifications, inspection
Equipment programs/records, replacements, etc. Some examples include improvement or
installation of: pimp seal upgrades,tube bundle upgrades,pressure vessel
pressure or temperature design upgrades, upgrades to material classification
for piping and equipment,removal of out-of-service equipment, and
improvements to maintenance practices.
Pressure Safety Relief systems. Some examples include: installation of new relief valves,
Valves modifications to existing relief valves, changes to service and maintenance
intervals, and routing relief valves to safe locations.
Human Factors Evaluations/modifications to improve personnel and equipment interface.
Some examples include improvements to: communications, labeling,
walkways, lighting, location(or relocation)of valves and/or valve operators
for better accessibility, and alarm management and prioritization in the control
room.
Facility Siting Evaluations/modifications to equipment locations with respect to processes
and their surroundings. Some examples include: conduct of facility siting
studies, installation of barricades,ventilation improvements, improvements to
containment, and improvements walkways and lighting.
Operational Evaluationshnodifications to improve operability. Some examples include:
improvements to procedures and training, upgrades to equipment lists,
establishment of safe operating limits,and improvements to checklists for
operators.
Fire Evaluations/modifications to emergency/health and safety equipment and
Protection/Health procedures. Some examples include: installation of detectors, installation and
and Safety improvement of fire monitors, issuance of personal monitors, installation of
eye washes and safety showers, changing to a less hazardous chemical,
development of emergency response procedures and improvements to the
fireproofing of equipment.
Environmental Evaluationshnodifications to address environmental regulatory requirements.
Some examples include: installation of NOx reduction facilities, installation
of new or modified abatement devices, changing to a less hazardous chemical,
and installation of new or modified environmental compliance monitoring
devices
Documentation Evaluations/modifications to process safety information. Some examples
include: evaluation and verification of adequate equipment design,updates to
Process Flow Diagrams (PFDs)and Piping and Instrument Diagrams
(P&IDs), updating equipment records and updating Material Safety Data
Sheets (MSDSs).
ATTACHMENT 4
AUR Z
PRODU
.CTS 1=
Air Products Manufacturing Corp.
Martinez(MRC)Hydrogen Facility
110 Waterfront Road
Martinez,CA 94553
Telephone (925)372-9302
Fax (925)372-9229 R �'( 6 Y
MAY 1, 1 2001
CONTRA COSTA HEALTH
HAZARD011S MATERIALS
May 9th, 2001
Mr. Lewis Pascalli, Jr. Esq.
Director Hazardous Materials Program
Contra Costa Health Service-Depar4ment
4333 Pacheco Blvdi�'
Martinez, CA 94553
Re: Response to Inherently Safer Systems Request Dated April 6, 2001.
Dear Mr. Pascalli:
This letter is in response to your request of April 6, 2001 for additional information
related to the Industrial Safety Ordinance (ISO) and Inherently Safer Systems (ISS). Per
the original ISS report we submitted to you on March 6, 2001, our facility has
implemented or was planning to implement 42 ISS and rejected 0 ISS. .(One ISS which
was listed as "rejected" in our March 6, 2001 letter was subsequently implemented). The
ISS report we submitted to you contained the ISS categorized per your letter of February
13, 2001.
We have two major concerns regarding your latest request. Our first concern revolves
around the reporting of costs. The second concern is regarding the additional level of
detail for the ISS implemented.
Specific to the issue of cost, our review of the ISO regulation found no language where
cost was required to be reported to your agency. Nor is.there a requirement .to maintain
the costs of the ISS implemented. The ISO does require that we may not reject an ISS
based upon economic issues unless the financial impacts would be sufficiently severe. In
that case, we would be compelled to document the basis for the rejection. In our last
report to you, if an ISS was rejected, it was rejected based upon the technological reasons
listed in the document sent to you on March 6, 2001. Once an ISS has been rejected for
technological..reasons, cost estimates are.not.developed for it- Therefore, the rejected'ISS
items do not have an estimated cost associated with them because none of the ISS items
were rejected for cost reasons.
i
i
AIR ®.
PRODU
Air Products Manufacturing Corp.
Martinez(MRC)Hydrogen Facility
110 Waterfront Road
Martinez,CA 94553
Telephone (925)372-9302
Fax (925)372-9229
For the ISS implemented, in many cases the individual costs per item are not readily
available. These can be contained in the annual budgets for the various operating
departments whose budgets are designed to anticipate these needs. In addition, these
items could be rolled into larger scope capital projects, where their cost is not broken out
individually. To provide this information, would be time consuming and burdensome,
especially considering that this information does not add any value towards improving
safety at the facility.
Furthermore, internal legal review and discussions with industry-based trade
organizations has yielded the opinion that the communication of the costs of
implementing ISS may violate anti-trust laws. Anti-trust laws make the disclosure of
competitively sensitive information, including our operating costs, to competitors
suspect, even if the disclosure is through public channels. The cost of implementing ISS
items is an operating cost to comply with the ISO.
Our second concern is regarding the additional level of detail for the ISS implemented.
In our response to your previous request, we categorized the ISS implemented in a
manner that would provide some information about the type of ISS implemented. The
ISS information is extremely complex and technologically challenging. When taken out
of context, it can be very confusing to the lay.p.erson- This detailed information-is.best
reviewed by your qualified technical. staff, such as your CalARP specialists, at our
facility. We welcome their onsite review at any time.
However, to assist with providing some additional. detail, we have added additional-
wording to the original categories, which we.ar.e_hopeful provides the spirit of the request
of additional detail. We have included.the. modified wording in this letter along with a
copy of our original submittal of ISS categorized accordingly. Some of the items
categorized in the original submittal may fall into more than one category, but they are
categorized only once.
Categories:
Instrument and Instrumentation or electrical modifications. Some examples include
Electrical improvement or installation of: reliability testing systems, alarms,
indicators and controllers, automatic shutdown devices and conduct of
electrical surveys and system changes.
AIR ®•
PRODUCTS
Air Products Manufacturing Corp.
Martinez(MRC)Hydrogen Facility
110 Waterfront Road
Martinez,CA 94553
Telephone (925)372-9302
Fax (925)372-9229
Piping Systems Evaluations/modifications to equipment, specifications, inspection
and Equipment Programs/records,replacements, etc. Some examples include
improvemtent.or.installation of. pump.seat upgrades;tube.bundle.
upgrades, upgrades.to material classification for piping and removal of
out-of-service equipment, and improvements to maintenance practices.
Pressure Safety Relief systems. Some examples include- installation of new relief
Valves valves, modifications.to existing.relief.valves, service and maintenance,
and routing relief valves to safe locations.
Human Factors Evaluations/modifications to imp-rove.personnel and equipment
interface. Some examples include improvements to: communications,
labeling, walk-ways,.lighting,.location.of valves and valve operators, and_
alarm management and prioritization in the control room.
Facility Siting Evaluations/modifications to equipment locations with respect to
processes and their surroundings. Some examples include: conduct of
facility siting studies,installation of barricades, ventilation
improvements, improvements.to_nontainment, and improvements
walkways and lighting.
Operational Evaluations/modifications to improve operability. Some examples
include: improvements to procedures and training, upgrades to
equipment lists, establishment of safe operating limits, and
improvements to checklists for operators.
Fire Evaluations/modifications to emergency/health and safety equipment
Protectiora/Health and procedures. Some examples include- installation of detectors,
and Safety installation and improvement of fire monitors, issuance of personal
monitors, installation of eye washes and safety showers, development of
emergency response procedures and improvements to the fireproofing
of equipment.
AIR 1
PRODU
,CTS 1=
Air Products Manufacturing Corp.
Martinez(MRC)Hydrogen Facility
110 Waterfront Road
Martinez,CA 94553
Telephone (925)372-9302
Fax (925)372-9229
Environmental Evaluations/modifications to address environmental.regulatory
requirements. Someiexarnples include- installation ofNOx reduction
facilities,it staliation.of abatement.devices,and installation.of
environmental compliance monitoring devices
Documentation. Evaluations/modifications to process safety information.' Some
examples include: evaluation and verification of adequate equipment
design, updates to Process Flow Diagrams (PFDs)-and-Piping-and
Instrument Diagrams (P&IDs), updating equipment records and
updating Material Safety Data Sheets (MSDSs).
If you have any questions regarding this letter, please feel free to call me at (925)372-
9302 or Dennis Bernhard at (610)481-5990.
Respectfully yours,
� E &
John Cheater
Plant Manager
Attachment: original ISS report
Cc: Mr. Randy Sawyer
1
)
I
AIR •
4RODUCTS
Air Products and Chemicals,Inc.
P.O.Box 231
Martinez,CA 94553
March 6, 2001
Ms. Cho Nai Cheung
4333 Pacheco Boulevard
Martinez,CA 94553
Dear Ms. Cheung:
This letter contains the information which was requested in-the 13 February Contra Costa County
Health Services letter concerning inherently safer systems.— This letter requested a summary-44he
number of inherently safer practices which have been implemented as-a result of recommendations
made in process hazards analyses carried out since April-27, 200A: In-addition,the letter requested a
description of any inherently safer systems which were considered but.not implemented The
information in-this letter pertains to the process-hazard analysis-revalidation which was completed for .
the Air Products hydrogen plant at the Equilon refinery in June,2000.
Inherently Safety Systems Implemented(or Under Consideration)
Number of Inherently Safer Practices
Implemented or Under Consideration
Instrumentation and Electrical 2
Piping Systems 1
Pressure Safety Valves 0
Human Factors 1
-Facility Siting... 5
Operational 16
Tire Protection-Health and Safety I
Environmental 0
Documentation 15
Inherently Safer Systems Considered and Not Implemented
-To date,there-has been one inherently safer system which was considered and which will not-be
implemented. This recommendation is in the human factors category. The recommendation and
conclusion are listed below:
Recommendation Conclusion
Investigate installing larger monitor for alarms Operating staff reviewed and agreed that a
in control building. larger monitor is not needed Alarms are
visible as is. No further action required-
Sincerely,
equiredSincerely,
'`john Cheater .
AIMS teem v
PRODUCTS
Air Products Manufacturing Corp.
Martinez(MRC)Hydrogen Facility
110 Waterfront Road
Martinez,CA 94553
Telephone (925)372-9302
Fax (925)372-9229
May 9th, 2001
Mr. Lewis Pascalli,Jr. Esq.
Director, fiazardous.Mate.rials Program.
Contra Costa Health Service Department
4333 Pacheco Blvd
Martinez, CA 94553
Re: Response to Inherently Safer Systems Request Dated April 6, 2001.
Dear Mr. Pasoak.
This letter is in response to your request of April 6, 2001 for additional information
related to the Industrial Safety Ordinance (ISO) and Inherently Safer Systems (ISS). Per
the original ISS report we submitted to you on March 6, 2001, our facility has
implemented or was planning to implement 42 ISS and rejected 0 ISS. (One ISS which
was listed as "rejected" in our March 6, 2001 letter was subsequently implemented). The
ISS report we submitted to you contained the ISS categorized per your letter of February
13, 2001.
We have two major concerns regarding your.latest request. Our first concern revolves
around the, reporting of costs. The second concern is regarding the additional level of
detail for the ISS implemented.
Specific to the issue of cost, our review of the ISO regulation found no language where
cost was required to be reported to your agency. Nor is there a requirement to maintain
the costs of the ISS implemented. The ISO does require that we may not reject an ISS
based upon economic issues unless the financial impacts would be sufficiently severe. In
that case, we would be compelled to document the basis for the rejection. In our last
report to you, if an ISS was rejected, it was rejected based upon the technological reasons
listed in the document sent to you on March 6, 2001. Once an ISS has been rejected..for
technological reasons, cost estimates are not developed for it. Therefore, the rejected ISS
items do not have an estimated cost associated with them because none of the ISS items
were rejected for cost reasons.
AIR ®.
PRODUCTS
Air Products Manufacturing Corp.
Martinez(MRC)Hydrogen Faciiity
110 Waterfront Road
Martinez,CA 94553
Telephone (925)372-9302
Fax (925)372-9229
For the I$S implemented, in many cases the individual costs per item are not readily
available. These can be contained in the annual.budgets for the various operafing
departments whose budgets are designed to anticipate these needs: In.addition; these-
items could be rolled into larger-scope capital.-projects, where their cost is not broken out
individually. To provide this information, would be time consuming and:burdensome.
especially considering that tMs information does not add any value towards improving
safety at the facility.
Furthermore, internal legal review and discussions with . industry-based trade
organizations has yielded the opinion that the communication of the costs of
implementing ISS may violate anti-trust laws. Anti-trust laws make the disclosure of
competitively sensitive information; ' including- our operating costs, to .competitors
suspect, even if the disclosure is through public-channels. .The cost of implementing ISS
items is an operating cost to comply with the ISO.
Our second concern is regarding the additional level of detail for the ISS implemented.
In our response to your previous request, we categorized the ISS implemented in a .
manner that would provide some information about the type of ISS implemented. The
ISS information is extremely complex and technologically challenging. When taken out
of context, it can be very confusing to the lay person. This detailed information is best
reviewed by your qualified technical staff, such as your CalARP specialists, at our
facility. We welcome their onsite review at any time.
However, to assist with providing some additional detail, we have added additional
wording to the original categories, which we are hopeful provides the spirit of the request
of additional detail. We have included the modified wording in this letter along with a
copy of our original submittal of ISS categorized accordingly. Some of the items
categorized in the original submittal may fall into more than one category, but they are
categorized only once.
Categories:
Instrument and Instrumentation or electrical modifications. Some examples include
Electrical improvement or installation of: reliability testing systems, alarms,
indicators and controllers, automatic shutdown devices and conduct of
electrical surveys and system changes.
i
i
i
AIR A
PRODUCTS
Air Products Manufacturing Corp.
Martinez(MRC)Hydrogen Facility
110 Waterfront Road
Martinez,CA 94553
Telephone (925)372-9302
Fax (925)372-9229
Piping Systems Evaluations/madifrcations-to-equipment, specifications- inspection-
and
nspection and Equipment Programs/records, fn
replaceents, etc; de
Some examples include
improvement-or-installation of. pump.seal-upgrades,.tube.bundle
upgrades, upgrades to material classification for piping and removal of
out-of-service equipment, and improvements to maintenance practices.
Pressure Safety Relief systems. Some examples include: installation of new relief
Valves valves, modifications to existing relief valves, service and maintenance,
and routing relief valves to safe locations.
Human Factors Evaluations/modifications to improve personnel and equipment
interface. Some examples include improvements to: communications,
labeling, walkways,.lighting, location ofvalves and valve operators;and
alarm management and prioritization in the control room.
Facility Siting Evaluations/modifications to equipment locations with respect to
processes and their surroundings: Some-eKamples include: conduct of
facility siting studies, installation of barricades,,ventilation.
improvements, improvements to containment, and-improvements
walkways and lighting.
Operational Evaluations/modifications to improve operability. Some�exarnples
include: improvements to procedures and training, upgrades to
equipment lists, establishment ofsafe operating limits,and
improvements to checklists for operators.
Fire Evaluations/modifications to emergency/health and safety equipment
Protection/Health and procedures. Some examples include- installation of detectors,..
and Safety installation and improvement of fine monitors, issuance of personal
monitors, installation of eye washes and safety showers; development of.
emergency response proced4wes and improvements to the fireproofing,.
of equipment. j
i
i
AIR ®e
PRODUCTS
Air Products Manufacturing Corp.
Martinez(MRC)Hydrogen Facility
110 Waterfront Road
Martinez,CA 94553
Telephone (925)372-9302
Fax (925)372-9229
Environmental Evaluationslmodificabons to address environmental regulatory
requirements. Some examples include: installation of NOx reduction .
facilities, installation of abatement devices,and:installation of
environmental compliance monitoring devices
Documentation Evaluations/modifications to process safety information, Some
examples include: evaluation and verification of adequate equipment
design, updates to Process Flow Diagrams. (PFDs)and Piping and.
Instrument Diagrams (P&IDs),updating equipment.records and
updating Matvial Safety Data Sheets (MSDSs).
If you have any questions regarding this letter, please feel free to call me at (925)372-
9302 or Dennis Bernhard at (610)481-5990.
Respectfully yours,
John Cheater
Plant Manager
Attachmept: original ISS report
Cc: Mr. Randy Sawyer
V°r
AIR A
WDUC S
Air Products and Chemicals,Inc.
P.O.Box 231
Martinez,CA 94553
March 6,2001
Ms. Cho Nai Cheung
4333 Pacheco Boulevard
Martinez, CA 94553
Dear Ms. Cheung:
This letter contains the information which was requestedan..the 13 February Contra Costa County
Health Services letter concerning inherently safer systems.-- This letter requested a summary-61-the
number of inherently safer practices which have been implemented as-a result of recommendations
made in process hazards analyses carried out,since April-27;2000: In-addition,the letter requested a
description of any inherently safer systems which were considered but.not implemented The
information in-this letter pertains to the process-hazard analysis-revalidation which was completed for
the Air Products hydrogen plant at the Equilon refinery in June,2000.
Inherently Safety Systems Implemented for Under Consideration)
Number of Inherently Safer Practices
Implemented or Under Consideration -J.
Instrumentation and Electrical 2 .
Piping S ams 1
Pressure Sa e Valves 0
Human Feeters I
-Facility Shing.. 5
Operational— 16
Fire Pro 'on.-Health and Safety 1
Environmental 0
Documentation 15
Inherently Safer Systems Considered and Not Implemented
To date,there-has been one inherently safer system which was considered and which will not be
implemented. This recommendation is in the human factors category. The recommendation and
conclusion are listed below:
Recommendation Conclusion
Investigate installing larger monitor for alarms Operating staff reviewed and agreed that a
in control building. larger monitor is not needed Alarms are
visible as is. No further action required-
Sincerely, red.Sincerely,
I
,14ohn Cheater j
t e-
I
i
I
i
y I
I �
I
i
V
EQUILON
® ENTERPRISES LLC
Shell 6 Texaco Working Together
May 10, 2001
Lewis G. Pascatli, Jr. R E_C El\1 f^ D
Director— Hazardous Materials Programs
Contra Costa Health Services MAY � ._ ����
4333 Pacheco Blvd.
Martinez, CA 94553 CONTRA COSTA HEAL TFC
HAZARDOUS NATERIALS
Dear Mr. Pascalli:
This letter is in response to your request of April 6, 2001 for additional information related to the
Industrial Safety Ordinance (ISO) and Inherently Safer Systems (ISS). Per the original ISS report we
submitted to you on March 7, 2001, our facility has implemented 17 ISS and rejected 0 ISS. The ISS
report we submitted to you contained the ISS categorized per your letter of February 13, 2001.
We have two major concerns regarding your latest request. Our first concern revolves around the
reporting of costs. The second concern is the reporting of the additional level of detail for the ISS
implemented.
Our review of the ISO found no requirement to report an estimate of costs for the systems
implemented or not implemented to your agency. The ISO does not require that we report financial
information unless financial considerations are the basis for rejecting an ISS.
As stated above, in our report sent to you on March 07, 2001, we reported that 0 ISS were rejected. If
we would have rejected an ISS, we would have included the technological basis for the rejection as
was requested in your original letter of February 13, 2001. Once an ISS has been rejected for
technological reasons, cost estimates would not be developed. Therefore, the rejected ISS items
would not have an estimated cost associated with them because none of the ISS items would be
rejected for cost reasons.
For the ISS implemented, in many cases the individual costs per item are not readily available. These
can be contained in the annual budgets for the various operating departments whose budgets are
designed to anticipate these needs. In addition, these items could be rolled into larger scope capital
projects, where their cost is not broken out individually. We feel putting forth the tremendous effort
necessary in compiling this information into a report does not add any value towards improving safety
at this facility.
Furthermore, internal legal review and discussions with industry-based trade organizations has
yielded the opinion that the communication of the costs of implementing ISS may violate anti-trust
laws. We are prohibited by the anti-trust act from disclosing our operating costs publicly. The cost of
implementing ISS items is an operating cost.
I
Our second concern is reporting of the additional level of detail for the ISS implemented. In our
;
response to your previous request, we categorized the ISS implemented in a manner that would
Martinez Refining Company
a Division of
Equilon Enterprises LLC
P.O.Box 711
Martinez,CA 94553-0071
provide some information about the type of ISS implemented. The ISS information at the refinery is
extremely complex and technologically challenging. When taken out of context, it can be confusing or
misleading to the lay person. This detailed information is best reviewed by your qualified technical
staff, such as your CaIARP specialists, at our facility. We welcome their onsite review at any time.
However, to assist with providing some additional detail, we have added additional wording to the
original categories, which we are hopeful provides the spirit of the request of additional detail. We
have included the modified wording as an attachment to this letter along with a copy of our original
submittal of ISS categorized accordingly. Some of the items categorized in the original submittal may
fall into more than one category, but they are categorized only once.
If you have any questions regarding this letter, please feel free to call me at (925) 313-3312 or Wayne
Howard at (925) 313-3964.
Sincerely,
r
Laura Brown
Manager, Health & Safety
Martinez Refining Company
Attachments (2)
i
f
i
i
i
i
MnrP.IS.qrPmiPCt
ATTACHMENT 1: MODIFIED WORDING TO ISS CATEGORIES
Categories Expanded Descriptions
Instrument and Instrumentation or electrical modifications. Some examples include
Electrical improvement or installation of: new reliability testing systems, alarms,
indicators and controllers, new or modified automatic shutdown devices
and conduct of electrical surveys and system changes.
Piping Systems Evaluations/modifications to equipment, specifications, inspection
and Equipment programs/records, replacements, etc. Some examples include
improvement or installation of: pump seal upgrades, tube bundle
upgrades, pressure vessel pressure or temperature design upgrades,
upgrades to material classification for piping and equipment, removal of
out-of-service equipment, and improvements to maintenance practices.
Pressure Safety Relief systems. Some examples include: installation of new relief
Valves valves, modifications to existing relief valves, changes to service and
maintenance intervals, and routing relief valves to safe locations.
Human Factors Evaluations/modifications to improve personnel and equipment
interface. Some examples include improvements to: communications,
labeling, walkways, lighting, location (or relocation) of valves and/or
valve operators for better accessibility, and alarm management and
prioritization in the control room.
Facility Siting Evaluations/modifications to equipment locations with respect to
processes and their surroundings. Some examples include: conduct
of facility siting studies, installation of barricades, ventilation
improvements, improvements to containment, and improvements
walkways and lighting.
Operational Evaluations/modifications to improve operability. Some examples
include: improvements to procedures and training, upgrades to
equipment lists, establishment of safe operating limits, and
improvements to checklists for operators.
Fire Evaluations/modifications to emergency/health and safety equipment
Protection/Health and procedures. Some examples include: installation of detectors,
and Safety installation and improvement of fire monitors, issuance of personal
monitors, installation of eye washes and safety showers, changing to a
less hazardous chemical, development of emergency response
procedures and improvements to the fireproofing of equipment.
Environmental Evaluations/modifications to address environmental regulatory
requirements. Some examples include: installation of NOx reduction
facilities, installation of new or modified abatement devices, changing
to a less hazardous chemical, and installation of new or modified
environmental compliance monitoring devices
Documentation Evaluations/modifications to process safety information. Some
examples include: evaluation and verification of adequate equipment
design, updates to Process Flow Diagrams (PFDs) and Piping and
Instrument Diagrams (P&IDs), updating equipment records and
updating Material Safety Data Sheets (MSDSs).
MorelSSrequest 3
EC;LUILON
® ENTERPRISES LLC
Shell 6 Texaco Wor*dno Together
RECEIVED
March 7, 2001
_ MAR - 7 Zoos
Lewis G. Pascalli, Jr. CONTRA
�A��� COSTA MATERIALS
Director—Hazardous Materials Programs .
Contra Costa Health Services
4333 Pacheco Blvd.
Martinez, CA 94553
Dear Mr. Pascalli:
Martinez Refining Company is submitting to you and your staff a list, with brief description, of Inherently Safer
Systems recently implemented. This list was requested in your letter dated February 13,2001. This list was
compiled from items identified during the development and analysis of mitigation items resulting from a new or
revalidated process hazard analysis and in the design and review of new processes and facilities occurring after
April 27, 2000. Inherently Safer Systems practices implemented have been categorized in the attached table.
In addition, all Inherently Safer Systems that resulted from the development and analysis of mitigation items
from a new or revalidated process hazard analysis and in the design and review of new processes and facilities
were implemented.
If you should have any questions, please contact Wayne Howard of my staff. Wayne's number is 313-3964.
Sincerely;
cn yr o)
Laura Brown
Manager, Health & Safety Department
Martinez Refining Company
Martinez Refining Company I
e Division of
Equilon Enterprises LLC I
P.O.Boz 711
Martinez,CA 94553-0071 I
I
f
Table of Inherently Safer Syst s implemented since April 27, 2000
Inherently Safer System Category Quantity Identified
5;:•�r.
Instrumentation and Electrical 1
Piping and Equipment Systems 3
Pressure Safety Valves 0
Human Factors 2
Facility Siting 1
Operational 10
Fire Protection— Health and Safety 0
Environmental 0
Documentation 0
ISSscorecardforCCHS 2 02/22/01
_ Tosco Refining Company
pti t� ED A Division of Tosco Corporation
San Francisco Area Refinery
S � at Rodeo
E
v��1
.: 2001 1380 San Pablo Avenue
Rodeo,California 94572.1299
Contra Cost,HeP.Rh Telephone:(510)799-4411
'F®SC® ttazardoits fA?,terials
May 14, 2001
Mr. Lewis Pascalli, Jr. Esq.
Director, Hazardous Materials Program
Contra Costa Health Service Department
4333 Pacheco Blvd
Martinez, CA 94553
Re: Response to .Inherently Safer Systems Request Dated April 6,2001.
Dear Mr. Pascalli:
This letter is in response to your request of April 6, 2001 for additional information related to the
Industrial Safety Ordinance (ISO) and Inherently Safer Systems (ISS). Per the original ISS report
we submitted to you on March 8, 2001, our facility has implemented 191 ISS and rejected none.
The ISS report we submitted to you contained the ISS categorized per your letter of February 13,
2001.
We have two major concerns regarding your latest request. Our first concern revolves around the
reporting of costs. The second concern is the reporting of the additional level of detail for the ISS
implemented.
Regarding cost, the ISO does not contain any provision requiring that cost inforination be reported
to your agency. The ISO does require that we not reject an ISS based upon economic issues unless
the financial impacts would be sufficiently severe. In that case, we would be compelled to inform
your agency of the rejection.
Although we did not report any ISS's being rejected, if an ISS was rejected for technological .
reasons, cost estimates would normally not be developed for it. Therefore, rejected ISS items would
not have an estimated cost associated with them because none of the ISS items would be rejected for
cost reasons.
For the ISS implemented, in many cases the individual costs per item are not readily available.
These can be contained in the annual budgets for the various operating departments whose budgets
are designed to anticipate these needs. In addition, these items could be rolled into larger scope
capital projects, where their cost is not broken out individually. We feel putting forth the
tremendous effort necessary in compiling this information into a report does not add any value
towards improving safety at this facility.
In addition, internal legal review and discussions with industry-based trade organizations leads us to
conclude that communication of the costs of implementing ISS could be construed to constitute a
violation of state and federal anti-trust laws.
Our second concern is reporting of the additional level of detail for the ISS implemented. In our
response to your previous request, we categorized the ISS implemented in a manner that would
provide some information about the type of ISS implemented. The ISS information at the refinery is
extremely complex and technical. When taken out of context, it can be confusing to the lay person.
This detailed information is best reviewed by your qualified technical staff, such as your CalARP
specialists, at our facility. We welcome their onsite review at any time.
However, to assist with providing some additional detail, we have added additional descriptions to
the original categories, which we hope will help satisfy your request. We have included the
modified wording as an attachment to this letter along with a copy of our original submittal of ISS
categorized accordingly. Some of the items categorized in the original submittal may fall into more
than one category,but they are categorized only once.
If you have any questions regarding this letter, please feel free to call me at (510)245-4466 or (Chris
Bowman) at (510)245-4669.
Respectfully yours,
9
Jolui M. Driscoll
-Health and Safety Superintendent
JMD/av
Attachment: original TSS report
cc: W.C.W. Chiang
Mr. Randy Sawyer
Ms. Gayle Uilkema
I
' I
i
ATTACHMENT 1: MODIFIED WORDING TO ISS CATEGORIES
Categories Expanded Descriptions
instrument and Instrumentation or electrical modifications. Some examples include
Electrical improvement or installation of.- new reliability testing systems, alarms,
indicators and controllers, new or modified automatic shutdown devices and
conduct of electrical surveys and system changes.
Piping Systems and Evaluations/modifications to equipment, Specifications, inspection
Equipment programs/records, replacements, etc. Some examples include improvement or
installation of: pump seal upgrades,tube bundle upgrades, pressure vessel
pressure or temperature design upgrades, upgrades to material classification
for piping and equipment, removal of out-of-service equipment, and
improvements to maintenance practices.
Pressure Safety Relief systems. Some examples include: installation of new relief valves,
Valves modifications to existing relief valves,changes to service and maintenance
intervals, and routing relief valves to safe locations.
Human Factors Evaluations/modifications to improve personnel and equipment interface.
Some examples include improvements to: communications, labeling,
walkways, lighting, location (or relocation)of valves and/or valve operators
for better accessibility, and alarm management and prioritization in the control
room.
Facility Siting Evaluations/modifications to equipment locations with respect to processes
and their surroundings. Some examples include: conduct of facility siting
studies, installation of barricades, ventilation improvements, improvements to
containment, and improvements walkways and lighting.
Operational Evaluations/modifications to improve operability. Some examples include:
improvements to procedures and training, upgrades to equipment lists,
establishment of safe operating limits, and improvements to checklists for
operators.
Fire Evaluations/modifications to emergency/health and safety equipment and
Protection/.Health procedures. Some examples include: installation of detectors, installation and
and Safety improvement of fire monitors, issuance of personal monitors, installation of
eye washes and safety showers,changing to a less hazardous chemical,
development of emergency response procedures and improvements to the
fireproofing of equipment.
Environmental Evaluations/modifications to address environmental regulatory requirements.
Some examples include: installation ofNOx reduction facilities, installation
of new or modified abatement devices, changing to a less hazardous chemical,
and installation of new or modified environmental compliance monitoring
devices
Documentation Evaluations/modifications to process safety information. Sonic examples
include: evaluation and verification of adequate equipment design, updates to
Process Flow Diagrams (.PFDs)and Piping and Instrument Diagrams 1
(P&IDs), updating equipment records and updating Material Safety Data
Sheets(MSDSs).
I
I
Ultramar Inc.
150 Solano Way y _. a•.-• f
Martinez,CA 94553
(925)228-1220
MAY
CONTRA COS TA HEAI_TFI
May 10, 2001 HAZARDOUS MATERIALS
Mr. Lewis Pascalli, Jr. Esq.
Director, Hazardous Materials Program
Contra Costa Health Service Department
4333 Pacheco Blvd
Martinez, CA 94553
Re: Response to Inherently Safer Systems Request Dated April 6, 2001.
Dear Mr. Pascalli:
The Ultramar Golden Eagle Refinery is committed to working cooperatively with your
staff on matters regarding compliance with the Industrial Safety Ordinance (ISO). To
that end, this letter is our response to your request of April 6, 2001 for additional.
information related to the ISO and Inherently Safer Systems (ISS). We submitted an ISS
report to you on February 16, 2001, which showed that our facility has implemented 310
ISS and rejected 7 ISS. In that report, the ISS were categorized according to your letter
dated February 13, 2001.
There are two areas in your latest request that are of great concern to us. These areas are
the reporting of costs and the reporting of additional levels of detail for the ISS
implemented.
Our review of the ISO did not find any requirement for reporting estimates of costs for
the systems implemented or not implemented to your agency. However, the ISO does
require that we not reject an ISS based upon economic issues unless the financial impacts
would be sufficiently severe. Based on the requirements of the ISO, if that occurred, we
would be compelled to inform your agency of the rejection.
In our February 16, 2001 report, we reported the technological basis for the rejection of
any ISS that were rejected. When an ISS has been rejected for technological reasons,
cost estimates are not developed for it. Therefore, the rejected ISS items do not have an
estimated cost associated with them because none of the ISS items were rejected for cost
reasons.
In many cases for the ISS implemented, the individual costs per item are not readily
available. The costs may be contained in the annual budgets for the various operating
departments whose budgets are designed to anticipate these needs. The ISS may also be
BEACON
MI Qualify and Service
An Ultramar Diamond Shamrock Company
rolled into larger scope capital projects, where their cost is not broken out individually.
We feel putting forth the tremendous effort necessary in compiling this cost information
into a public report does not add any value towards improving safety at this facility.
However, if your technical CalARP staff should have any questions regarding costs for
particular ISS items during an onsite review, we would gather the necessary information
for their review. We welcome their onsite review of our programs at any time.
Furthermore, internal legal review and discussions with industry-based trade
organizations has yielded the opinion that the communication of the costs of
implementing ISS will violate anti-trust laws. We are prohibited by the anti-trust act
from disclosing our operating costs publicly. For our facility, the cost of implementing
ISS items is an operating cost to comply with the ISO.
We are also concerned about the rec,uest to report an additional level of detail for the.ISS
implemented. In our February 16` report, we categorized the ISS implemented in a
manner that would provide some information about the type of ISS implemented. The
information associated with each ISS is voluminous, extremely complex, and
technologically challenging. We are concerned that the further detail you request will
result in this information being interpreted out of context. Furthermore, due to its
technical nature, the detailed ISS information is best reviewed by your qualified technical
CalARP staff at our facility. Again, we welcome their onsite review of our programs at
any time.
However, in the spirit of cooperation, we are providing some additional wording to the
original ISS categories. This additional wording provides more detail about the types of
ISS that could be implemented under each category. We have included the modified
wording as an attachment to this letter along with a copy of our original submittal of ISS
categorized accordingly. Some of the items categorized in the original submittal may fall
into more than one category, but they are categorized only once.
If you have any questions regarding this letter, please feel free to call me at (925) 372-
3169 or Ms. Sabiha Gokcen at(925) 370-3620.
Res ec yo s,
ames Darnell
Health and Safe y Manager
Attachment: Modified definitions for ISS categories
original ISS report from February 16`}'.
Cc: Mr. Randy Sawyer
ATTACHMENT 1: MODIFIED WORDING TO ISS CATEGORIES
Categories Expanded Descriptions
Instrument and Instrumentation or electrical modifications. Some examples include
Electrical improvement or installation of: new reliability testing systems, alarms,
indicators and controllers, new or modified automatic shutdown devices and
conduct of electrical surveys and system changes.
Piping Systems and Evaluations/modifications to equipment, specifications, inspection
Equipment programs/records, replacements, etc. Some examples include improvement or
installation of: pump seal upgrades,tube bundle upgrades,pressure vessel
pressure or temperature design upgrades,upgrades to material classification
for piping and equipment, removal of out-of-service equipment, and
improvements to maintenance practices.
Pressure Safety Relief systems. Some examples include: installation of new relief valves,
Valves modifications to existing relief valves, changes to service and maintenance
intervals, and routing relief valves to safe locations.
Human Factors Evaluations/modifications to improve personnel and equipment interface.
Some examples include improvements to: communications, labeling,
walkways, lighting, location (or relocation)of valves and/or valve operators
for better accessibility, and alarm management and prioritization in the control
room.
Facility Siting Evaluations/modifications to equipment locations with respect to processes
and their surroundings. Some examples include: conduct of facility siting
studies, installation of barricades, ventilation improvements, improvements to
containment, and improvements walkways and lighting.
Operational Evaluations/modifications to improve operability. Some examples include:
improvements to procedures and training, upgrades to equipment lists,
establishment of safe operating limits, and improvements to checklists for
operators.
Fire Evaluations/modifications to emergency/health and safety equipment and.
Protection/Health procedures. Some examples include: installation of detectors, installation and
and Safety improvement of fire monitors, issuance of personal monitors, installation of
eye washes and safety showers, changing to a less hazardous chemical,
development of emergency response procedures and improvements to the
fireproofing of equipment.
Environmental Evaluations/modifications to address environmental regulatory requirements.
Some examples include: installation of NOx reduction facilities, installation
of new or modified abatement devices, changing to a less hazardous chemical,
and installation of new or modified environmental compliance monitoring
devices
Documentation Evaluations/modifications to process safety information. Some examples
include: evaluation and verification of adequate equipment design, updates to
Process Flow Diagrams (PFDs)and Piping and Instrument Diagrams
(P&IDs), updating equipment records and updating Material Safety Data
Sheets (MSDSs).
RECEIVED
Ultramar Inc. FEB 16 7
150 Soiano Way
Martinez,CA 94553 CONTRA COSTA f IEALTH
(925)372-3172 HAZARDOUS MATERIALS
J.W.Haywood
Refinery General Manager
February 15, 2001
Mr. Lew Pascalli, Esq.
Director, Hazardous Materials Division
Contra Costa Health Services
4333 Pacheco Blvd.
Martinez, CA 94553
Subject: List of Inherently Safer Systems
Dear Mr. Pascalli:
The enclosed document is the list of inherently safer systems requested by your department.
This list includes PHA recommendations as well as new projects for the period requested.
The implemented inherently safer systems are categorized according to the guidance issued
by Mr. Randy Sawyer. Those not implemented are also listed with a brief explanation of the
reasoning involved. As you can see from this documentation, the Ultramar Golden Eagle
Refinery has aggressively pursued the implementation of inherently safer system designs on
-both new projects and PHA recommendations.
Please do not hesitate to call me at (925) 228-1220 or Ms. Sabiha Gokcen (925) 370-3620, if
you have any questions regarding this document.
Sincerel
J. aywood
V.P., West Coast Refining
& General Manager
cc: Randy Sawyer
Enclosure
An Ultramar Diamond Shamrock Company
INHERENTLY SAFER DESIGN
ULTRAMAR - GOLDEN EAGLE REFINERY
SUMMARY TABLE
Inherently Safer Inherently Safer Percent with
PHA Program Design Design Not Total Inherently Safer
Implemented Implemented Design
Instrument and Electrical 28 0 28 100%
Piping Systems and Equipment 41 1 42 98%
Pressure Safety Valves 6 0 6 100%
Human Factors 8 3 11 73%
Facility Siting 12 1 13 92%
Operational 123 1 124 99%
Fire Protection/Health and Safety 6 1 7 86%
Environmental 1 0 1 100%
Documentation 69 0 69 100%
Total 294 7 301 98%
Inherently Safer Inherently Safer Percent with
New Projects Design Design Not Total Inherently Safer
Implemented Implemented Design
Instrument and Electrical 3 0 3 100%
Piping Systems and Equipment 9 0 9 100%
Pressure Safety Valves 1 0 1 100%
Human Factors 1 0 1 100%
Facility Siting 1 0 1 100%
Operational 0 0 0 —
Fire Protection/Health and Safety 1 0 1 100%
Environmental 0 0 0 —
Documentation 0 0 0 —
Total 16 0 16 100%
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Inherently Safer Action Project Report 02-01.xis-211512001
INHERENTLY SAFER SYSTEMS REPORT CATEGORY
DEFINITIONS
Instrument and Electrical: Instrumentation or electrical modifications.
Piping Systems & Equipment: Evaluations/Modifications to equipment,
specifications, inspection programs/records, replacements, etc.
Pressure Safety Valves: Installation of new relief valves, modifications to existing
relief valves, service, maintenance, etc.
Human Factors: Evaluations/modifications to improve personnel and equipment
interface.
r
Facility Siting: Evaluations/modifications to equipment locations with respect to
processes and their surroundings.
Operational: Evaluations/modifications to improve operability (e.g., procedures,
locking open valves, etc.)
Fire Protection/Health and Safety: Evaluations/modifications to emergency/health
and safety equipment and procedures.
Environmental: Evaluations/modifications to address environmental regulatory
requirements.
Documentation: Evaluations/modifications to process safety information.
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PROCESS HAZARD ANALYSIS (PHA) PROGRAM
INHERENTLY SAFER SYSTEMS IMPLEMENTED
UNIT REC. NO. DESCRIPTION
No. 4 Gas Plant A007-1999-287B Operational
No. 4 Boiler A008-1999-031 Fire Protection/Health and Safety
No. 1 HDA A010-1999-057 Piping Systems and Equipment
No. 1 HDA A010-1999-080 Operational
No. 1 HDA A010-1999-086 Documentation
No. 1 HDA A010-1999-088 Pressure Safety Valves
No. 1 HDA A010-1999-104 Operational
No. 1 HDA A010-1999-106 Documentation
No. 1 HDA A010-1999-133 Documentation
No. 1 HDA A010-1999-169 Documentation
No. 1 HDA A010-1999-187 Facility Siting
No. 1 HDA A010-1999-188 Facility Siting
No. 1 Feed Prep A011-1999-011 Documentation
No. 1 Feed Prep A011-1999-014 Pressure Safety Valves
No. 1 Feed Prep A011-1999-053 Documentation
No. 2 Feed Prep A013-1999-028 Operational
Avon Wharf A015-7511 Instrument and Electrical
Foul Water Strippers A018-1998-026 Human Factors
Foul Water Strippers A018-1998-063 Operational
Foul Water Strippers A018-1998-065 Piping Systems and Equipment
Foul Water Strippers A018-1998-066 Operational
Foul Water Strippers A018-1998-068 Piping Systems and Equipment
Foul Water Strippers A018-1998-070 Operational
Foul Water Strippers A018-1998-090 Operational
Foul Water Strippers A018-1998-229 Instrument and Electrical
Foul Water Strippers A018-1998-250 Instrument and Electrical
Foul Water Strippers A018-1998-255 Operational
Foul Water Strippers A018-1998-262 Operational
Foul Water Strippers A018-1998-264 Piping Systems and Equipment
Foul Water Strippers A018-1998-272 Operational
Foul Water Strippers A018-1998-273 Instrument and Electrical.
Foul Water Stri pers A018-1998-291 Operational
Foul Water Strippers A018-1998-308 Operational
Foul Water Strippers A018-1998-327 Piping Systems and Equipment
Foul Water Strippers A018-1998-345 Instrument and Electrical
Foul Water Strippers A018-1998-363 Operational
Foul Water Strippers A018-1998-366 Operational
Foul Water Strippers A018-1998-367 Operational
Foul Water Strippers A018-1998-375 Operational
Foul Water Strippers A018-1998-376 Piping Systems and Equipment
Foul Water Strippers A018-1998-388 Documentation
No. 6 Boiler A031-1999-071 Operational
No.6 Boiler A031-1999-091 Operational
No. 2 Water Treat A032-1999-045 Instrument and Electrical
No.2 Water Treat A032-1999-046 Instrument and Electrical
No. 2 Water Treat A032-1999-062 Human Factors
No. 2 Water Treat A032-1999-065 Operational
No. 2 Water Treat A032-1999-069 Piping Systems and Equipment
No. 2 Water Treat A032-1999-074 Operational
No. 3 Water Treat A033-1999-055 Operational '
PROCESS HAZARD ANALYSIS (PHA) PROGRAM
INHERENTLY SAFER SYSTEMS IMPLEMENTED
No. 5 Boiler A036-1999-033 Documentation
No. 5 Boiler A036-1999-036 Documentation
No. 5 Boiler A036-1999-055 Documentation
No. 5 Boiler A036-1999-067 Operational
No. 5 Boiler A036-1999-114 Facility Siting
No. 5 Boiler A036-1999-117 Fire Protection/Health and Safety
No. 5 Boiler A036-1999-119 Fire Protection/Health and Safety
No. 5 Boiler A036-1999-130 Environmental
No. 5 Boiler A036-1999-131 Instrument and Electrical
No. 5 Boiler A036-1999-133 Instrument and Electrical
Butane Spheres A054-5597 Piping Systems and Equipment
Tr 1 Gauging Area Tankage A054G-1999-006 Operational
Tr 1 Gauging Area Tankage A054G-1999-009 Documentation
Tr 1 Gauging Area Tankage A054G-1999-010 Documentation
Tr 1 Gauging Area Tankage A054G-1999-012 Piping Systems and Equipment
Tr 1 Gauging Area Tankage A054G-1999-014 Piping Systems and Equipment
Tract 1 LHP Area Tankage A054N-1999-060 Documentation
Tract 1 LHP Area Tankage A054N-1999-109 Facility Siting
Tract 1 LHP Area Tankage A054N-1999-138 Documentation
Tract 1 LHP Area Tankage A054N-1999-146 Facility Siting
Tract 1 LHP Area Tankage. A054N-1999-148 Documentation
Tract 1 LHP Area Tankage A054N-1999-149 Documentation
Tract 1 LHP Area Tankage A054N-1999-150 Documentation
Tract 1 LHP Area Tankage A054N-1999-152 Documentation
Tr 1 Thermal Cracking Area A055-1999-015 Documentation
Tr 1 Thermal Cracking Area A055-1999-017 Documentation
Tr 1 Thermal Cracking Area A055-1999-114 Documentation
Tr 1 Thermal Cracking Area A055-1999-123 Piping Systems and Equipment
Tr 1 Thermal Cracking Area A055-1999-244 Pressure Safety Valves
Tr 1 Thermal Cracking Area A055-1999-269 Documentation
Tr 1 Thermal Cracking Area A055-1999-270 Facility Siting
Tr 1 Thermal Cracking Area A055-1999-271 Facility Siting
Tr 1 Thermal Cracking Area A055-1999-273 Operational
Tr 1 Thermal Cracking Area A055-1999-276 Documentation
Tr 1 Thermal Cracking Area A055-1999-277 Documentation
Tract 2 Tankage A056-1999-001 Operational
Tract 2 Tankage A056-1999-003 Piping Systems and Equipment
Tract 2 Tankage A056-1999-004 Operational
Tract 2 Tankage A056-1999-005 Piping Systems and Equipment
Tract 2 Tankage A056-1999-007 Operational
Tract 2 Tankage A056-1999-008 Operational
Tract 2 Tankage A056-1999-009 Operational
Tract 2 Tankage A056-1999-012 Documentation
Tract 2 Tankage A056-1999-013 Operational
Tract 2 Tankage A056-1999-017 Operational
Tract 2 Tankage A056-1999-019 O erational
Tract 2 Tankage A056-1999-020 Operational
Tract 2 Tankage A056-1999-025 Operational
Tract 2 Tankage A056-1999-028 Operational
Tract 2 Tankage A056-1999-033 Instrument and Electrical
Tract 2 Tankage A056-1999-035 Operational
PROCESS HAZARD ANALYSIS (PHA) PROGRAM
INHERENTLY SAFER SYSTEMS IMPLEMENTED
Tract 2 Tankage A056-1999-036 Operational
Tract 2 Tankage A056-1999-037 Human Factors
Tract 3 Tankage A058-1999-007 Operational
Tract 3 Tankage A058-1999-009 Operational
Tract.3 Tankage A058-1999-010 Operational
Tract 3 Tankage A058-1999-011 Operational
Tract 3 Tankage A058-1999-013 Operational
Tract 3 Tankage A058-1999-015 Fire Protection/Health and Safety
Tract 3 Tankage A058-1999-020 Operational
Tract 3 Tankage A058-1999-022 Operational
Tract 3 Tankage A058-1999-023 Operational
Tract 3 Tankage A058-1999-026 Operational
Tract 3 Tankage A058-1999-027 Documentation
Tract 3 Tankage A058-1999-028 Piping Systems and Equipment
Tract 3 Tankage A058-1999-029 Operational
Tract 3 Tankage A058-1999-037 Documentation
Tract 3 Tankage A058-1999-039 Documentation
Tract 4 Offplot A059-1999-003 Documentation
Tract 4 Offplot A059-1999-004 Operational
Tract 4 Offplot A059-1999-005 Documentation
Tract 4 Offplot A059-1999-006 Operational
Tract 4 Offplot A059-1999-007 Operational
Tract 4 Offplot A059-1999-018 Pressure Safety Valves
Tract 4 Offplot A059-1999-019 Instrument and Electrical
Tract 4 Offplot A059-1999-021 Operational
Tract 4 Offplot A059-1999-022 Operational
Tract 4 Offplot A059-1999-023 Operational
Tract 4 Offplot A059-1999-024 O erational
Tract 4 Offplot A059-1999-029 Pressure Safety Valves
Tract 4 Offplot A059-1999-030 Documentation
Tract 4 Offplot A059-1999-033 Pressure Safety Valves
Tract 6 Tankage A060-1999-001 Piping Systems and Equipment
Tract 6 Tankage A060-1999-003 Operational
Tract 6 Tankage A060-1999-004 . Operational
Tract 6 Tankage A060-1999-005 Instrument and Electrical
Tract 6 Tankage A060-1999-006 Instrument and Electrical
Tract 6 Tankage A060-1999-007 Instrument and Electrical
Tract 6 Tankage A060-1999-008 Operational
Tract 6 Tankage A060-1999-009 Operational
Tract 6 Tankage A060-1999-013 Operational
Tract 6 Tankage A060-1999-015 Operational
Tract 6 Tankage A060-1999-016 Operational
Tract 6 Tankage A060-1999-019 Operational
Tract 6 Tankage A060-1999-020 Piping Systems and Equipment
Tract 6 Tankage A060-1999-021 Operational
Tract 6 Tankage A060-1999-025 Operational
Tract 6 Tankage A060-1999-026 Documentation
Tract 6 Tankage A060-1999-028 Operational
Tract 6 Tankage A060-1999-030 Operational
Tract 6 Tankage A060-1999-031 Operational
Tract 6 Tankage A060-1999-033 Instrument and Electrical
PROCESS HAZARD ANALYSIS (PHA) PROGRAM
INHERENTLY SAFER SYSTEMS IMPLEMENTED
Tract 6 Tankage A060-1999-034 Operational
Tract 6 Tankage A060-1999-035 Operational
Hydrocracker Stage 1 A067-1999-067 Documentation
Hydrocracker Stage 1 A067-1999-106. Operational
Hydrocracker Stage 1 A067-1999-111 Documentation
Hydrocracker Stage 1 A067-1999-139 Documentation
Hydrocracker Stage 1 A067-1999-148 Documentation
Hydrocracker Stage 1 A067-1999-179 Documentation
Hydrocracker Stage 1 A067-1999-180 Operational
Hydrocracker Stage 1 A067-1999-182 Piping Systems and Equipment
Hydrocracker Stage 1 A067-1999-195 Instrumentation and Electrical
Hydrocracker Stage 1 A067-1999-220 Operational
Hydrocracker Stage 2 A068-1994-5820 Facility Siting
Hydrocracker Stage 2 A068-1999-019 Documentation
Hydrocracker Stage 2 A068-1999-033 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-034 Operational
Hydrocracker Stage 2 A068-1999-064 Documentation
Hydrocracker Stage 2 A068-1999-082 Operational
Hydrocracker Stage 2 A068-1999-086 Operational
Hydrocracker Stage 2 A068-1999-090 Facility Siting
Hydrocracker Stage 2 A068-1999-092 Documentation
Hydrocracker Stage 2 A068-1999-093 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-125 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-152 Operational
Hydrocracker Stage 2 A068-1999-155 Operational
Hydrocracker Stage 2 A068-1999-180 Documentation
Hydrocracker Stage 2 A068-1999-182 Operational
Hydrocracker Stage 2 A068-1999-184 Documentation
Hydrocracker Stage 2 A068-1999-201 Instrumentation and Electrical
Hydrocracker Stage 2 A068-1999-216 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-265 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-332 Instrumentation and Electrical
Hydrocracker Stage 2 A068-1999-334 Documentation
Hydrocracker Stage 2 A068-1999-337 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-368 Documentation
Hydrocracker Stage 2 A068-1999-369 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-391 Documentation
Hydrocracker Stage 2 A068-1999-411 Instrumentation and Electrical
Hydrocracker Stage 2 A068-1999-441 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-459 Operational
Hydrocracker Stage 2 A068-1999-471 Instrumentation and Electrical
Hydrocracker Stage 2 A068-1999-473 Facility Siting
Hydrocracker Stage 2 A068-1999-486 Instrumentation and Electrical
Hydrocracker Stage 2 A068-1999-489 Operational
Hydrocracker Stage 2 A068-1999-492 Operational
Hydrocracker Stage 2 A068-1999-494 Operational
Hydrocracker Stage 2 A068-1999-495 Operational
Hydrocracker Stage 2 A068-1999-509 Operational
Hydrocracker Stage 2 A068-1999-512 Documentation
,Hydrocracker Stage 2 A068-1999-513 Facility Siting
Hydrocracker Stage 2 A068-1999-515 Operational
PROCESS HAZARD ANALYSIS (PHA) PROGRAM
INHERENTLY SAFER SYSTEMS IMPLEMENTED
Hydrocracker Stage 2 A068-1999-516 Facility Siting
Hydrocracker Stage 2 A068-1999-517 Operational
Hydrocracker Stage 2 A068-1999-519 Operational
Hydrocracker Stage 2 A068-1999-520 Operational
No. 1 Hydrogen Plant A069-1999-039 . Operational
No. 1 Hydrogen Plant A069-1999-051 Instrumentation and Electrical
No. 1 Hydrogen Plant A069-1999-086 Documentation
No. 1 Hydrogen Plant A069-1999-099 Documentation
No. 1 Hydrogen Plant A069-1999-108 Operational
No. 1 Hydrogen Plant A069-1999-183 Documentation
No. 1 Hydrogen Plant A069-1999-186 Documentation
No. 1 Hydrogen Plant A069-1999-196 Piping Systems and Equipment
No. 1 Hydrogen Plant A069-1999-228 Piping Systems and Equipment
No. 1 Hydrogen Plant A069-1999-240 Documentation
No. 1 Hydrogen Plant A069-1999-259 Documentation
No. 1 Hydrogen Plant A069-1999-269 Documentation
No. 1 Hydrogen Plant A069-1999-271 Documentation
No. 1 Hydrogen Plant A069-1999-280 Documentation
No. 1 Hydrogen Plant A069-1999-287 Documentation
No. 1 Hydrogen Plant A069-1999-303 Documentation
No. 1 Hydrogen Plant A069-1999-307 Documentation
No. 1 Hydrogen Plant A069-1999-320 Piping Systems and Equipment
No. 1 Hydrogen Plant A069-1999-349 Piping Systems and Equipment
No. 1 Hydrogen Plant A069-1999-373 Operational
Alkylation Unit A073-1999-236 Documentation
Alkylation Unit A073-1999-476 Piping Systems and Equipment
Alkylation Unit A073-1999-534 Piping Systems and Equipment
Waste Water Treatment Plant A074-1999-020 Operational
Waste Water Treatment Plant A074-1999-035 Operational
Waste Water Treatment Plant A074-1999-049 Documentation
Waste Water Treatment Plant A074-1999-064 Documentation
Waste Water Treatment Plant A074-1999-091 Documentation
Waste Water Treatment Plant A074-1999-107 Piping Systems and Equipment
Waste Water Treatment Plant A074-1999-123 Operational
Waste Water Treatment Plant A074-1999-128 Instrumentation and Electrical
Waste Water Treatment Plant A074-1999-151 Piping Systems and Equipment
Waste Water Treatment Plant A074-1999-153 Operational
SCOT Tailgas Unit A078-1999-043 Instrumentation and Electrical
SCOT Tailgas Unit A078-1999-069 Operational
SCOT Tailgas Unit A078-1999-113 Operational
SCOT Tailgas Unit A078-1999-124 Operational
SCOT Tailgas Unit A078-1999-153 O erational
SCOT Tailgas Unit A078-1999-192 Human Factors
SCOT Tailgas Unit A078-1999-201 Human Factors
Ammonia Recovery Unit A080-1999-031 Operational
Ammonia Recovery Unit A080-1999-054B Operational
Ammonia Recovery Unit A080-1999-179 Operational
Ammonia Recovery Unit A080-1999-187 Documentation
Ammonia Recovery Unit A080-1999-190 Piping Systems and Equipment
Ammonia Recovery Unit A080-1999-203 Operational
Ammonia Recovery Unit A080-1999-213 Operational !
!
i
I
PROCESS HAZARD ANALYSIS (PHA) PROGRAM
INHERENTLY SAFER SYSTEMS IMPLEMENTED
Ammonia Recovery Unit A080-1999-214 Operational
Ammonia Recovery Unit A080-1999-228 Documentation
Ammonia Recovery Unit A080-1999-236 Operational
Ammonia Recoveg Unit A080-1999-242 Piping Systems and Equipment
Ammonia Recovery Unit A080-1999-252 Documentation
Ammonia Recove Unit A080-1999-299 Operational
Ammonia Recovey Unit A080-1999-301 Piping Systems and Equipment
Ammonia Recove Unit A080-1999-302 Human Factors
Ammonia Recovery Unit A080-1999-324 Piping Systems and Equipment
Ammonia Recove Unit A080-1999-334 Operational
Ammonia Recovery Unit A080-1999-335 Piping Systems and Equipment
Ammonia Recove Unit A080-1999-336 Operational
Ammonia Recovey Unit A080-1999-337 Operational
Ammonia Recoveq Unit A080-1999-345 Piping Systems and Equipment
Sulfur Recovery Unit A081-1999-019 Instrumentation and Electrical
Sulfur Recovery Unit A081-1999-076 Documentation
Sulfur Recovery Unit A081-1999-112 Piping Systems and Equipment
Sulfur Recovery Unit A081-1999-130 Documentation
Sulfur Recovery Unit A081-1999-132 Fire Protection/Health and Safety
Sulfur Recovery Unit A081-1999-143 Fire Protection/Health and Safety
Sulfur Recovery Unit A081-1999-157 Human Factors
Benzene Saturation Unit A091-1999-001 Instrumentation and Electrical
Benzene Saturation Unit A091-1999-038 Operational
Benzene Saturation Unit A091-1999-058 Documentation
Benzene Saturation Unit A091-1999-096 Instrumentation and Electrical
Benzene Saturation Unit A091-1999-106 Operational
Benzene Saturation Unit A091-1999-113 Operational
Benzene Saturation Unit A091-1999-127 Operational
Benzene Saturation Unit A091-1999-148 Human Factors
Benzene Saturation Unit A091-1999-154 Operational
Benzene Saturation Unit A091-1999-155 Operational
Benzene Saturation Unit A091-1999-160 Operational
Benzene Saturation Unit A091-1999-183 Documentation
Benzene Saturation Unit A091-1999-184 Operational
Benzene Saturation Unit A091-1999-203 Instrumentation and Electrical
Benzene Saturation Unit A091-1999-211 Piping Systems and Equipment
Benzene Saturation Unit A091-1999-219 Facility Siting
Benzene Saturation Unit A091-1999-221 Operational
Benzene Saturation Unit A091-1999-222 O erational
Benzene Saturation Unit A091-1999-224 Operational
Benzene Saturation Unit A091-1999-225 Operational
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PROCESS HAZARD ANALYSIS (PHA) PROGRAM
INHERENTLY SAFER SYSTEMS IMPLEMENTED
No. 5 Boiler A036-1999-033 Documentation
No. 5 Boiler A036-1999-036 Documentation
No. 5 Boiler A036-1999-055 Documentation
No. 5 Boiler A036-1999-067 Operational
No. 5 Boiler A036-1999-114 Facility Siting
No. 5 Boiler A036-1999-117 Fire Protection/Health and Safety
No. 5 Boiler A036-1999-119 Fire Protection/Health and Safety
No. 5 Boiler A036-1999-130 Environmental
No. 5 Boiler A036-1999-131 Instrument and Electrical
No. 5 Boiler A036-1999-133 Instrument and Electrical
Butane Spheres A054-5597 Piping Systems and Equipment
Tr 1 Gauging Area Tankage A054G-1999-006 Operational
Tr 1 Gauging Area Tankage A054G-1999-009 Documentation
Tr 1 Gauging Area Tankage A054G-1999-010 Documentation
Tr 1 Gauging Area Tankage A054G-1999-012 Piping Systems and Equipment
Tr 1 Gauging Area Tankage A054G-1999-014 Piping Systems and Equipment
Tract 1 LIIP Area Tankage A054NA 999-060 Documentation
Tract 1 LHP Area Tankage A054N-1999-109 Facility Siting
Tract 1 LHP Area Tankage A054N-1999-138 Documentation
Tract 1 LHP Area Tankage A054N-1999-146 Facility Siting
Tract 1 LHP Area Tankage A054N-1999-148 Documentation
Tract 1 LIAP Area Tankage A054N-1999-149 Documentation
Tract 1 LHP Area Tankage A054N-1999-150 Documentation
Tract 1 LHP Area Tankage A054N-1999-152 Documentation
Tr 1 Thermal Cracking Area A055-1999-015 Documentation
Tr 1 Thermal Cracking Area A055-1999-017 Documentation
Tr 1 Thermal Cracking Area A055-1999-114 Documentation
Tr 1 Thermal Cracking Area A055-1999-123 Piping Systems and Equipment
Tr 1 Thermal Cracking Area A055-1999-244 Pressure Safety Valves
Tr 1 Thermal Cracking Area A055-1999-269 Documentation
Tr 1 Thermal Cracking Area A055-1999-270 Facility Siting
Tr 1 Thermal Cracking Area A055-1999-271 Facility Siting
Tr 1 Thermal Cracking Area A055-1999-273 Operational
Tr 1 Thermal Cracking Area A055-1999-276 Documentation
Tr 1 Thermal Cracking Area A055-1999-277 Documentation
Tract 2 Tankage A056-1999-001 Operational
Tract 2 Tankage A056-1999-003 Piping Systems and Equipment
Tract 2 Tankage A056-1999-004 Operational
Tract 2 Tankage A056-1999-005 Piping Systems and Equipment
Tract 2 Tankage A056-1999-007 Operational
Tract 2 Tankage A056-1999-008 Operational
Tract 2 Tankage A056-1999-009 Operational
Tract 2 Tankage A056-1999-012 Documentation
Tract 2 Tankage A056-1999-013 Operational
Tract 2 Tankage A056-1999-017 Operational
Tract 2 Tankage A056-1999-019 Operational
Tract 2 Tankage A056-1999-020 Operational
Tract 2 Tankage A056-1999-025 O erational
Tract 2 Tankage A056-1999-028 Operational
Tract 2 Tankage A056-1999-033 Instrument and Electrical
Tract 2 Tankage A056-1999-035 Operational
PROCESS HAZARD ANALYSIS (PHA) PROGRAM
INHERENTLY SAFER SYSTEMS IMPLEMENTED
Tract 2 Tankage A056-1999-036 operational
Tract 2 Tankage A056-1999-037 Human Factors
Tract 3 Tankage A058-1999-007 Operational
Tract 3 Tankage A058-1999-009 Operational
Tract 3 Tankage A058-1999-010 Operational
Tract 3 Tankage A058-1999-011 Operational
Tract 3 Tankage A058-1999-013 Operational
Tract 3 Tankage A058-1999-015 Fire Protection/Health and Safety
Tract 3 Tankage A058-1999-020 Operational
Tract 3 Tankage A058-1999-022 Operational
Tract 3 Tankage A058-1999-023 Operational
Tract 3 Tankage A058-1999-026 Operational
Tract 3 Tankage A058-1999-027 Documentation
Tract 3 Tankage A058-1999-028 Piping Systems and Equipment
Tract 3 Tankage A058-1999-029 Operational
Tract 3 Tankage A058-1999-037 Documentation
Tract 3 Tankage A058-1999-039 Documentation
Tract 4 Offplot A059-1999-003 Documentation
Tract 4 Offplot A059-1999-004 Operational
Tract 4 Offplot A059-1999-005 Documentation
Tract 4 Offplot A059-1999-006 Operational
Tract 4 Offplot A059-1999-007 Operational
Tract 4 Offplot A059-1999-018 Pressure Safety Valves
Tract 4 Offplot A059-1999-019 Instrument and Electrical
Tract 4 Offplot A059-1999-021 Operational
Tract 4 Offplot A059-1999-022 Operational
Tract 4 Offplot A059-1999-023 Operational
Tract 4 Offplot A059-1999-024 Operational
Tract 4 Offplot A059-1999-029 Pressure Safety Valves
Tract 4 Offplot A059-1999-030 Documentation
Tract 4 Offplot A059-1999-033 Pressure Safety Valves
Tract 6 Tankage A060-1999-001 Piping Systems and Equipment
Tract 6 Tankage A060-1999-003 Operational
Tract 6 Tankage A060-1999-004 Operational
Tract 6 Tankage A060-1999-005 Instrument and Electrical
Tract 6 Tankage A060-1999-006 Instrument and Electrical
Tract 6 Tankage A060-1999-007 Instrument and Electrical
Tract 6 Tankage A060-1999-008 Operational
Tract 6 Tankage A060-1999-009 Operational
Tract 6 Tankage A060-1999-013 Operational
Tract 6 Tankage A060-1999-015 Operational
Tract 6 Tankage A060-1999-016 Operational
Tract 6 Tankage A060-1999-019 Operational
Tract 6 Tankage A060-1999-020 Piping Systems and Equipment
Tract 6 Tankage A060-1999-021 Operational
Tract 6 Tankage A060-1999-025 Operational
Tract 6 Tankage A060-1999-026 Documentation
Tract 6 Tankage A060-1999-028 Operational
Tract 6 Tankage A060-1999-030 Operational
Tract 6 Tankage A060-1999-031 Operational
Tract 6 Tankage A060-1999-033 Instrument and Electrical
PROCESS HAZARD ANALYSIS (PHA) PROGRAM
INHERENTLY SAFER SYSTEMS IMPLEMENTED
Tract 6 Tankage A060-1999-034 Operational
Tract 6 Tankage A060-1999-035 Operational
Hydrocracker Stage 1 A067-1999-067 Documentation
Hydrocracker Stage 1 A067-1999-106 Operational
Hydrocracker Stage 1 A067-1999-111 Documentation
Hydrocracker Stage 1 A067-1999-139 Documentation
Hydrocracker Stage 1 A067-1999-148 Documentation
Hydrocracker Stage 1 A067-1999-179 Documentation
Hydrocracker Stage 1 A067-1999-180 Operational
Hydrocracker Stage 1 A067-1999-182 Piping Systems and Equipment
Hydrocracker Stage 1 A067-1999-195 Instrumentation and Electrical
Hydrocracker Stage 1 A067-1999-220 Operational
Hydrocracker Stage 2 A068-1994-5820 Facility Siting
Hydrocracker Stage 2 A068-1999-019 Documentation
Hydrocracker Stage 2 A068-1999-033 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-034 Operational
Hydrocracker Stage 2 A068-1999-064 Documentation
Hydrocracker Stage 2 A068-1999-082 Operational
Hydrocracker Stage 2 A068-1999-086 Operational
Hydrocracker Stage 2 A068-1999-090 Facility Siting
Hydrocracker Stage 2 A068-1999-092 Documentation
Hydrocracker Stage 2 A068-1999-093 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-125 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-152 Operational
Hydrocracker Stage 2 A068-1999-155 Operational
Hydrocracker Stage 2 A068-1999-180 Documentation
Hydrocracker Stage 2 A068-1999-182 Operational
Hydrocracker Stage 2 A068-1999-184 Documentation
Hydrocracker Stage 2 A068-1999-201 Instrumentation and Electrical
Hydrocracker Stage 2 A068-1999-216 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-265 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-332 Instrumentation and Electrical
Hydrocracker Stage 2 A068-1999-334 Documentation
Hydrocracker Stage 2 A068-1999-337 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-368 Documentation
Hydrocracker Stage 2 A068-1999-369 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-391 Documentation
Hydrocracker Stage 2 A068-1999-411 Instrumentation and Electrical
Hydrocracker Stage 2 A068-1999-441 Piping Systems and Equipment
Hydrocracker Stage 2 A068-1999-459 Operational
Hydrocracker Stage 2 A068-1999-471 Instrumentation and Electrical
Hydrocracker Stage 2 A068-1999-473 Facility Siting
Hydrocracker Stage 2 A068-1999-486 Instrumentation and Electrical
Hydrocracker Stage 2 A068-1999-489 Operational
Hydrocracker Stage 2 A068-1999-492 Operational
Hydrocracker Stage 2 A068-1999-494 Operational
Hydrocracker Stage 2 A068-1999-495 Operational
Hydrocracker Stage 2 A068-1999-509 Operational
Hydrocracker Stage 2 A068-1999-512 Documentation
,Hydrocracker Stage 2 A068-1999-513 Facility Siting
Hydrocracker Stage 2 A068-1999-515 Operational
PROCESS HAZARD ANALYSIS (PHA) PROGRAM
INHERENTLY SAFER SYSTEMS IMPLEMENTED
Hydrocracker Stage 2 A068-1999-516 Facility Siting
Hydrocracker Stage 2 A068-1999-517 Operational
Hydrocracker Stage 2 A068-1999-519 Operational
Hydrocracker Stage 2 A068-1999-520 Operational
No. 1 Hydrogen Plant A069-1999-039 . Operational
No. 1 Hydrogen Plant A069-1999-051 Instrumentation and Electrical
No. 1 Hydrogen Plant A069-1999-086 Documentation
No. 1 Hydrogen Plant A069-1999-099 Documentation
No. 1 Hydrogen Plant A069-1999-108 Operational
No. 1 Hydrogen Plant A069-1999-183 Documentation
No. 1 Hydrogen Plant A069-1999-186 Documentation
No. 1 Hydrogen Plant A069-1999-196 Piping Systems and Equipment
No. 1 Hydrogen Plant A069-1999-228 Piping Systems and Equipment
No. 1 Hydrogen Plant A069-1999-240 Documentation
No. 1 Hydrogen Plant A069-1999-259 Documentation
No. 1 Hydrogen Plant A069-1999-269 Documentation
No. 1 Hydrogen Plant A069-1999-271 Documentation
No. 1 Hydrogen Plant A069-1999-280 Documentation
No. 1 Hydrogen Plant A069-1999-287 Documentation
No. 1 Hydrogen Plant A069-1999-303 Documentation
No. 1 Hydrogen Plant A069-1999-307 Documentation
No. 1 Hydrogen Plant A069-1999-320 Piping Systems and Equipment
No. 1 Hydrogen Plant A069-1999-349 Piping Systems and Equipment
No. 1 Hydrogen Plant A069-1999-373 Operational
Alkylation Unit A073-1999-236 Documentation
Alkylation Unit A073-1999-476 Piping Systems and Equipment
Alkylation Unit A073-1999-534 Piping Systems and Equipment
Waste Water Treatment Plant A074-1999-020 Operational
Waste Water Treatment Plant A074-1999-035 Operational
Waste Water Treatment Plant A074-1999-049 Documentation
Waste Water Treatment Plant A074-1999-064 Documentation
Waste Water Treatment Plant A074-1999-091 Documentation
Waste Water Treatment Plant A074-1999-107 Piping Systems and Equipment
Waste Water Treatment Plant A074-1999-123 Operational
Waste Water Treatment Plant A074-1999-128 Instrumentation and Electrical
Waste Water Treatment Plant A074-1999-151 Piping Systems and Equipment
Waste Water Treatment Plant A074-1999-153 Operational
SCOT Tailgas Unit A078-1999-043 Instrumentation and Electrical
SCOT Tailgas Unit A078-1999-069 Operational
SCOT Tailgas Unit A078-1999-113 Operational
SCOT Tailgas Unit A078-1999-124 Operational
SCOT Tailgas Unit A078-1999-153 Operational
SCOT Tailgas Unit A078-1999-192 Human Factors
SCOT Tailgas Unit A078-1999-201 Human Factors
Ammonia Recovery Unit A080-1999-031 Operational
Ammonia Recovery Unit A080-1999-054B Operational
Ammonia Recovery Unit A080-1999-179 Operational
Ammonia Recovery Unit A080-1999-187 Documentation
Ammonia Recovery Unit A080-1999-190 Piping Systems and Equipment
Ammonia Recovery Unit A080-1999-203 Operational
Ammonia Recovery Unit A080-1999-213 Operational
i
i
PROCESS HAZARD ANALYSIS (PHA) PROGRAM
INHERENTLY SAFER SYSTEMS IMPLEMENTED
Ammonia Recovery Unit A080-1999-214 Operational
Ammonia Recovery Unit A080-1999-228 Documentation
Ammonia Recovery Unit A080-1999-236 Operational
Ammonia Recovery Unit A080-1999-242 Piping Systems and Equipment
Ammo nia.Recove ry Unit A080-1999-252 Documentation
Ammonia Recovery Unit A080-1999-299 Operational
Ammonia Recovery Unit A080-1999-301 Piping Systems and Equipment
Ammonia Recovery Unit A080-1999-302 Human Factors
Ammonia Recovery Unit A080-1999-324 Pi ing Systems and Equipment
Ammonia Recovery Unit A080-1999-334 Operational
Ammonia Recovery Unit A080-1999-335 Piping Systems and Equipment
Ammonia Recovery Unit A080-1999-336 Operational
Ammonia Recovery Unit A080-1999-337 Operational
Ammonia Recovery Unit A080-1999-345 Piping Systems and Equipment
Sulfur Recovery Unit A081-1999-019 Instrumentation and Electrical
Sulfur Recovery Unit A081-1999-076 Documentation
Sulfur Recovery Unit A081-1999-112 Piping Systems and Equipment
Sulfur Recovery Unit A081-1999-130 Documentation
Sulfur Recovery Unit A081-1999-132 Fire Protection/Health and Safety
Sulfur Recovery Unit A081-1999-143 Fire Protection/Health and Safety
Sulfur Recovery Unit A081-1999-157 Human Factors
Benzene Saturation Unit A091-1999-001 Instrumentation and Electrical
Benzene Saturation Unit A091-1999-038 Operational
Benzene Saturation Unit A091-1999-058 Documentation
Benzene Saturation Unit A091-1999-096 Instrumentation and Electrical
Benzene Saturation Unit A091-1999-106 Operational
Benzene Saturation Unit A091-1999-113 Operational
Benzene Saturation Unit A091-1999-127 Operational
Benzene Saturation Unit A091-1999-148 Human Factors
Benzene Saturation Unit A091-1999-154 Operational
Benzene Saturation Unit A091-1999-155 Operational
Benzene Saturation Unit A091-1999-160 Operational
Benzene Saturation Unit A091-1999-183 Documentation
Benzene Saturation Unit A091-1999-184 Operational
Benzene Saturation Unit A091-1999-203 Instrumentation and Electrical
Benzene Saturation Unit A091-1999-211 Piping Systems and Equipment
Benzene Saturation Unit A091-1999-219 Facility Siting
Benzene Saturation Unit A091-1999-221 Operational
Benzene Saturation Unit A091-1999-222 Operational
Benzene Saturation Unit A091-1999-224 Operational
Benzene Saturation Unit A091-1999-225 Operational
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REQUEST TO SPEAK FORM I
(THREE (3)MINUTE LIMIT)
Complete this form and place it in the box near the speakers' rostrum before addressing the Board.
Name: .J j , ?A Y�,J E • Phone:. 313 -0 > 0 -?
Address: PO F a K 3 -cl City: AA I'Z,
I am speaking for myself or organization: 7i-7 C
(name of organization)
CHECK ONE: Q
I wish to speak on Agenda Item# Date
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SPEAKERS
1. Deposit the"Request to Speak" form(on the reverse side) in the box next to the speaker's
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2. You will be called-onto make your presentation.
Please speak into the microphone at.the-podium.
3. Begin by stating your name, address and}whether you are speaking for yourself or as the
representative of an organization.
4. Give the Clerk a copy of.your presentation or support documentation if available before
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5. Limit your presentation to three minutes. Avoid repeating comments made by previous
speakers.
6. The Chair may limit the length of presentations so all persons may be hear.
REQUEST TO SPEAR FORM
(THREE (3) MINUTE LIMIT) r/
Complete this form and place it in the box near the speakers'
rostrum `before addressing the Board. a
Name: lyni ���L�J Phone: 7� 3��• /l tel"\
Address: „ZZ 5,044Y✓0 &e city: A�w�e--
I am speaking for myself or organization:
(name of organization)
CHECK ONE:
I wish to speak on Agenda Item # Date: !q F9
My comments will be: general for against
I wish to speak on the subject of
I do not wish to speak but leave these comments for the
Board to consider:
I
SPEAKERS
I
i
1. Deposit the "Request to Speak" form (on the reverse side) in
the box next to the speaker's microphone before your agenda
item is to be considered.
i
2. You will be called on to make your presentation.
Please speak into the microphone at the podium.
3. Begin by stating your name and address and whether
you are speaking for yourself or as the
representative of an organization.
4. Give the Clerk a copy of your presentation or
support documentation if available before speaking.
5. Limit your presentation to three minutes. Avoid
repeating comments made by previous speakers.
(The Chair may limit length of presentations so all
persons may be heard) .
s-
REQUEST TO SPEAR FORM�
(THREE (3) MINUTE LZMIT) h� � ,12� 1
Complete this form and lace it in the box near the s akersl Y` � J
P P P
rostrum before addressing the Board. Q
Name: yWdob Phone:
Address: � �QL� "Y City: A962a
I am speaking for myself or organization: � .
(name of organization)
CHECK/ONE:
1� I wish to speak on Agenda Item # ,� Date: �9 Of
My comments will be: general V for against
I wish to speak on the subject of
I do not wish to speak but leave these comments for the
Board to consider:
i
1 SPEAKERS
1. Deposit the "Request to Speak" form (on the reverse side) in
the box next to the speaker's microphone before your agenda
item is to be considered.
2. You will be called on to make your presentation.
Please speak into the microphone at the podium.
3. Begin by stating your name and address and whether
you are speaking for yourself or as the
representative of an organization.
4 . Give the Clerk a copy of your presentation or
support documentation if available before speaking.
5. Limit your presentation to three minutes. Avoid
repeating comments made by previous speakers.
(The Chair may limit length of presentations so all
persons may be heard) .
f
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