Post on 18-Apr-2018
transcript
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Presented at Public Meeting
April 19, 2013
Chevron Richmond Refinery
August 6, 2012 Fire
CSB Interim Report Findings and
Recommendations
• Received inquiry from Contra Costa County concerning
possible air monitoring support;
• OSC arrived at Chevron EOC to provide technical support
as needed.
• EPPS inspector onsite to begin investigation on 08/08/12.
• In collaboration with CSB, CalOSHA, County CUPA, City
and BAAQMD.
• EPA investigation conducted with support from HQ and
other Regions and covered processes other than 4Crude.
• EPA’s expanded investigation complete by June 30th.
4
US EPA Region IX’s
Response
Th
• Failure caused by sulfidation corrosion in low-silicon carbon steel.
Inherently Safer Materials of Construction
Low-Silicon Carbon
Steel >.1% Silicon
Carbon Steel 9-Chrome Stainless Steel
INHERENTLY SAFER
Thinning resulting from 15 years of operation (Estimated)
90 % Wall Loss 65% Wall Loss 9% Wall Loss < 1% Wall Loss
Chevron 4-sidecut
Material of Construction
Low-Silicon 4-Sidecut Component Not Monitored Measurement
Location
Weld High-Silicon
Elbow Component
Low-Silicon
Pipe Component
Low-Silicon 4-Sidecut Component Not Monitored
~2002
#3 CML
Many Chevron Recommendations to Inspect or Upgrade 4-Sidecut
2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Pipe Ruptures
Recommendations to 100 Percent Inspect 4-Sidecut
Recommendations to Upgrade Metallurgy of 4-Sidecut
Inspection of piping TML/CML location #3
Process Feed Changes
• These reviews:
– Analyze all process equipment failure mechanisms including:
• Corrosion
• Cracking
– Identify needed safeguards to control or eliminate hazard.
• Not required by regulations or by Chevron standards
– Review findings could have caused Process Hazard Analysis
(PHA) team to recommend 4-sidecut line replacement.
Damage Mechanism Hazard Reviews CSB’s Findings
• CSB recommendation:
⁻ Chevron should conduct damage mechanism reviews at
all their U.S. facilities.
⁻ State, County and local agencies should require this
review at all refineries as part of the
Process Hazard Analysis.
Damage Mechanism Hazard Reviews
Inherently Safer Systems (ISS) analysis is required in
Contra Costa County and City of Richmond’s Regulations
as part of PHAs and new construction.
The ISS analysis in PHA at Chevron was a “Check-the-
Box” activity not a detailed process-specific analysis.
Regulation only requires analysis be
considered “…shall consider the use
of inherently safer systems…”
Inherently Safer Systems Analysis CSB’s Findings
CSB’s Recommendations:
State, County and local agencies should require ISS
analysis at every opportunity in the process, including all parts
of the prevention program which generate recommendations.
Inherently Safer Systems Analysis
• Use of LOPA to achieve ALARP:
– LOPA can be used to reduce risk to “As Low
As Reasonably Practicable” or ALARP.
– Risk reduction continues to the practical limit.
• LOPA can confirm:
– Safeguards are adequate.
– Inherently safer design is optimally in place.
• Chevron is a member of CCPS and peer-reviewed
the LOPA publication.
Adequate Hazard Analysis Methodologies Drive Risk to As Low As Reasonably Practicable
• CBS Recommendation:
− Chevron should report leading and lagging indicators to
federal, state and local agencies for all California refineries.
− State and local agencies should require facilities to
report leading and lagging indicators studies and
LOPA information.
Adequate Hazard Analysis Methodologies Drive Risk to As Low As Reasonably Practicable
• Program will improve public accountability and process safety
performance.
• Sharing of data and operational coordination will help
regulators prevent major incidents.
• Regulators have cited the need for
greater multi-agency cooperation.
Multi-Agency Regulatory Approach Needed
• CBS Recommendation:
• State should develop and implement a multi-agency
program for regulation of PSM at refineries,
including information sharing and coordination
of compliance monitoring activities.
EPA should participate as well.
Multi-Agency Regulatory Approach Needed
Transparency Drives Process Safety • Transparency is the public disclosure of process safety
information.
• Minimal transparency exists between refineries, regulators, and
the public.
• Transparency allows local officials, regulators, the workforce, and
the public to work with industry to prevent major incidents.
• NOTE: Current laws, such as
those implemented by the
US Department of Homeland
Security, prohibit public disclosure
of some information.
• Failure caused by sulfidation corrosion
in low-silicon carbon steel.
• Chevron failed to shut down unit when
leak was found.
• Chevron never replaced 4-sidecut
despite many recommendations.
• Chevron Process Hazard Analysis
(PHA) process failed to identify
sulfidation corrosion hazard.
Many Factors Contributed to Incident
• Regulations did not require a damage
mechanism hazard review.
• Regulations did not require evaluation of
safeguard effectiveness.
• Regulations did not require rigorous
Inherently Safer System implementation.
• Multi-agency cooperation and
transparency needed in California
Many Factors Contributed to Incident
Questions? CSB Interim Report and additional resources
available at
http://CSB.gov