FAQ: Other ISO Questions

Contra Costa Health Services Hazardous Materials Programs has hired a consultant to do public outreach on the County's Industrial Safety Ordinance. The consultant is doing presentations explaining the requirements of the ordinance in preventing accidental releases from petroleum refineries and chemical plants. Many questions arise during these presentations about the impacts from accidental releases and emissions, emergency notification, public information, and other topics. The following are some of the common questions that have been raised during the presentations and the answers to these questions.

Why aren't Henkel, Criterion, and Acme Steel under the jurisdiction of the Industrial Safety Ordinance (ISO)? Is the Central Sanitary District part of the Industrial Safety Ordinance (ISO)?

The County's ISO only covers unincorporated areas of the County and the Richmond ISO covers the City of Richmond; petroleum refineries and chemical companies; and companies that make or use above-threshold quantities of specifically listed extremely hazardous chemicals.

Does Benicia have an Industrial Safety Ordinance?

Valero, the former Exxon Refinery is located in Benicia. Valero is not subject to the ISO since they are located in Solano County not Contra Costa County. Valero is however required to submit a Risk Management Plan under the California Accidental Release Program (CalARP). The ISO presentations given have focused on companies that fall under the jurisdiction of the Contra Costa County ISO. Information about Valero can best be obtained by contacting them directly at 707-745-7011.

Campora Propane has over 400,000 gallons of liquefied petroleum gas containing methyl mercaptans. They are within 1,000 feet of a mobile home park and residences. Why are they not regulated by the County Industrial Safety Ordinance?

The ISO presentation discussed companies submitting Safety Plans and Risk Management Plans (RMP). Companies that only sell, not make, flammables for fuel are exempt from the requirement to submit an RMP. Safety plans only need to be submitted by manufacturers such as chemical plants and petroleum refineries.

Since the ISO is a land use ordinance, how are Risk Management Plans (RMP) and Safety Plans related to land use?

The Industrial Safety Ordinance has two separate chapters. One chapter pertains to land use. The chapter that we are discussing with these questions and answers deal with the Risk Management Chapter, which does not pertain to land use requirements.

Has the County inspected the Concord Weapons Station?

Is there duplication and overlap between the requirements of the ISO and the California Accidental Release Prevention (CalARP) Program?

The ISO expands the CalARP program. CalARP only applies to regulated chemicals stored in quantities above threshold amounts. ISO applies the same CalARP standards to every unit on the site.

Why aren't incorporated cities requiring chemical plants and refineries to adhere to the ISO?

How does the County apportion their attention to small chemical plants versus large refineries?

The County is required to conduct an audit of all facilities under the jurisdiction of the ISO every three (3) years. The County might send a 2-person crew to audit a small site that might last 2-3 weeks. A large site may require an inspection team of 4 people and might last 3-4 weeks.

How is the public safety covered by the ISO in the transportation of chemicals in railroad tank cars and tank trucks on the freeways?

This is not in the jurisdiction of the County ISO. It is the responsibility of the Department of Transportation (DOT). Training operators in the proper loading and unloading of railroad tank cars and tank trucks is part of the ISO.

Should all maintenance staff have apprentice training?

The Industrial Safety Ordinance requires that the maintenance personnel are trained on how to perform their jobs for the appropriate skills and safety requirements.

Has there been any thought to making vessels double walled to reduce the likelihood of leakage?

The Industrial Safety Ordinance requires that the facilities maintain their equipment, including an inspection program. When there is an excess corrosion the facilities are required to replace these vessels. There are situations where double walled vessels are used, but mostly the facilities are required to ensure that the vessels are designed with the right materials of construction and the appropriate thickness.

The County reviews some of the Process Hazard Analysis (PHA) recommendations of the plants to ensure that industrial facilities implement them. Who determines which PHA recommendations are reviewed?

Contra Costa Health Services audits the facilities to ensure that they are following the requirements of the Industrial Safety Ordinance. The Process Hazard Analysis is an important element of the accident prevention program. We determine if the team who performs the PHA has the right expertise, experience, and the appropriate makeup. The PHA team is required to include someone who is knowledgeable in the PHA method that is being used, an operator from the unit that is being analyzed, the appropriate engineers, and other personnel with specific specialties as needed. Contra Costa Health Services personnel will then randomly select different PHA's to review to ensure that they are complete with the appropriate documentation. The number of PHA's reviewed is based on how many different processes there are at a facility and can range from 5% to 100% of the PHA's for a facility.

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