Mayor and Members of the City Council:
This is a status report regarding Chevron’s permit applications relating to repair of the crude unit, and, in particular, damaged process piping.
As you will recall, following the public meeting this past Wednesday (December 19th), staff concluded that the City’s technical consultants needed to be in a position to specifically state that the pipe material proposed by Chevron as part of their proposed crude unit repair represents best technology and is inherently safer than other pipe material options that are suitable per code. At that time, the consultants’ reports simply stated that the proposed pipe material is consistent with industry practices and consistent with the Fire Code.
Staff also believed that Chevron needed to provide the City with responses to the interrogatories provided to them from the Chemical Safety Board (CSB) as they relate to the selection of pipe material, and the City’s technical consultants needed to have an opportunity to review these responses.
Late on Friday, December 21st, based on staff’s request, the City’s consultants, James McLaughlin and David E. Hendrix, each provided a supplemental technical report as to whether 9-chrome (9Cr) pipe, the material proposed by Chevron, is the most appropriate high temperature sulfidation (HTS) piping material. Their supplemental reports were based in part on (1) review of the two subpoenas issued by the Chemical Safety Board to Chevron; (2) Chevron's response to the subpoena questions that are relevant to the composition of replacement HTS piping material; and (3) review of other documentation provided by Chevron including submittals to the City. The supplemental technical reports have been posted to the City’s website at:
As indicated in their reports, each consultant determined that:
- The selection of 9Cr for replacement piping in the No. 4 Crude Unit represents best available technology, and that
- The selection of 9Cr vs. the other available materials represents an inherently safer design. Mr. Hendrix specifically states that 9Cr is more resistant to high temperature sulfidation than the lower chromium containing materials and “mitigates the risk of introducing another, more unpredictable damage mechanism, based on uncertainty in the location of failure and in the increased inability to detect the damage mechanism before failure with the selection of 18Cr/8 for the high sulfur process streams in the No. 4 Crude Unit associated with the rebuild project.”
In their reports, the consultants stress the importance of an ongoing, rigorous inspection program to monitor the condition and remaining life of a component in corrosive service, and of monitoring changes to the crude slate processed by the refinery.
Based on these supplemental technical reports, staff concluded that the fire permits could be issued by the Fire Marshall, and this has now been done.
All material related to the Chevron Refinery fire can be found at http://www.ci.richmond.ca.us/index.aspx?nid=2628.
We will keep you informed as this process moves forward. In the meantime, please feel free to contact me if you have any questions or require any additional information.
City of Richmond