CSB draft report about Chevron Richmond Refinery

posted Apr 26, 2013, 2:46 AM by Webadmin Safepark Consultancy   [ updated Apr 26, 2013, 2:51 AM ]
Last Monday the Chemical Safety Board (CSB) released a draft report on the pipe rupturing event at Chevrons Richmond Refinery last August. This report is scary reading about a company that goes through the motions, a public inspection service that don't see the problems and company management not listening to either local or corporate experts. The picture of the vapor cloud is courtesy of CSB.
Chevron Refinery Vapor Cloud

The most surprising is paragraph #57 where a Chevron employee recommended replacement of the pipe, which ruptured last August, in the 2007 turnaround because in had just 4 years life left until it reached refinery throwaway thickness. Unfortunately this employee was to correct about his predictions.

Apparently Chevron perform PHA (HAZOP) just because it has to. One example from the draft report is that the HAZOP of the crude unit did not include corrosion. Another is that Chevron after the rupture event ruched to replace some carbon steel piping in the crude unit without first considering what would be the best replacement material. Or when a unit to remove hydrogen sulfide from the #4-sidecut was removed a MoC was not performed. Neither was a MoC performed when switching to feeding more sulphur rich crudes to the unit.

This draft report is also richly illustrated and with many references to relevant literature from both CCPS, API and others. There is a good explanation of abbreviations at the start, and many explanatory footnotes, which makes the report very informative for non-experts.

Unfortunately the draft report does not clearly identify the root causes of the release and fire. I hope this will happen in the final report, although it seems clear, that among the root causes are an insufficient mechanical integrity program at the refinery. At another refinery I had the opportunity to visit with a group of university professors about 10 years ago we were told that corrosion measurement points were moved if a particular point did not indicate any corrosion during 3 measurement periods.

The draft report contain 14 (or 20 depending on how one count them) recommendations of which only two are to the company. Of the remaining one is to US EPA and the remaining to authorities in the City of Richmond, the Contra Costa County and the State of California. This distribution of recommendations concerns me. A recommendations usually means that the receiving part have to do some new or extra work. For authorities already under significant economic pressure this is unsustainable. We need to find an approach, to the burden of work after a process safety event is on the company, and not the authorities.

Furthermore any regulation should use shall, and be as broad and general as possible. After all the purpose is simple enough: to ensure no employees or members of the public are harmed by the activities of the company. This is not that different from requiring, that drugs produced and marketed by pharmaceutical companies are safe to use for their intended purpose. After all the purpose of physical design of a refinery is to keep the hydrocarbons inside the process, and the purpose of maintenance is to ensure this continues to be the case.