To: Teresa Sabol Spezio

From: Anthony Shing

Date: December 15, 2022
Final Position Paper on the Chevron Richmond Refinery Modernization Project

1. Executive Summary
While infrastructure improvements proposed by the Modernization Project would increase the
refinery’s capacity to process crude oil imports and produce hydrogen outputs, environmental and
public health concerns were noted in the EIR and during public comment periods. The proposed
Reduced Sulfur Processing / No Increase in Greenhouse Gas Emissions Alternative is the best
alternative to address these concerns. It balances economic considerations while accounting for
environmental concerns, following through with the modernization project, while limiting the
intake of the sulfur removal units and establishing a net greenhouse gas emission threshold. The
two main environmental concerns noted in the alternative are the additional emissions generated
from refinery operations and the potential for increased accidental releases of hazardous waste
from pipe corrosion. Through the implementation of emissions reduction technology and the
reduction of sulfur removal unit emissions, the annual emissions generated through this alternative
would be 13.6% lower than the proposed modernization project. In addition, increased emissions
from hydrogen plant operations would be offset by overall net reductions in refinery emissions.
Increased hydrogen sulfide gas inputs into the sulfur removal units would potentially lead to
increased corrosion rates on pipe infrastructure. This alternative reduces potential corrosion
impacts and the subsequent risk of pipe leaks and failure by reducing the daily intake of hydrogen
sulfide into the units. While this alternative would successfully reduce emissions and pipe corrosion
risks, it does not consider environmental justice concerns of the surrounding community and does
not include sufficient safety and management strategies that ensure the continued wellbeing of
workers and the public. To address these concerns, Chevron and the city of Richmond must invest
more into targeted community benefit programs and develop transparent pipeline corrosion
response policies.

2. Your Preferred Alternative

The firefighters and refinery workers had little time to react before the gas ignited, barely managing
to escape the flames. On August 6, 2012, a small leak from a corroded pipe resulted in a plume of
highly flammable light gas oil that ignited, forming a large black cloud that spread toxic air
pollutants across the city of Richmond. In the following weeks, over 15,000 residents sought
medical attention, making this leak and fire the most serious recent incident at the Chevron
Richmond Refinery (U.S. Chemical Safety and Hazard Investigation Board, 2015). With this tragedy
in mind, Chevron proposed a new Modernization Project to retrofit and modernize the facility, with
new safety procedures and mechanisms recommendations.

The Modernization Project sought to replace an existing hydrogen plant and retrofit sulfur removal
units, expanding the crude oil processing capabilities of the refinery while aiming for no net
increases in greenhouse gas emissions. With these infrastructure improvements, the refinery would
be able to produce higher quality hydrogen outputs as well as process additional crude oil inputs
with higher sulfur contents. Given these considerations, the preferred alternative would be the
Reduced Sulfur Processing / No Increase in Greenhouse Gas Emissions Alternative. While the
modernization project would be implemented, processing and production capacities of crude oil
would be scaled back. The amount of sulfur recovered would be reduced to 750 long tons per day,
instead of the 900 long tons per day capacity increase proposed under the existing project.
Greenhouse gas emissions would be limited to 4,602,947 metric tons per year, to prevent a net
increase of emissions over this baseline. While additional hydrogen production and exports are
projected to increase emissions above the allocated baseline, proposed mitigation measures would
reduce emissions to compliance levels (City of Richmond, 2015).

3. Environmental Context
The Chevron Richmond Refinery is a 2,900 acre refinery located in Richmond, California. The
community boasts a population of over 115,000, and it is a predominantly minority community,
with Black and Asian populations making up the majority. Around 1,200 workers are employed by
the refinery, and they help produce numerous petroleum derived products. With such heavy
chemical and industrial processes, the area surrounding the refinery has higher rates of pollution,
leading to a lower quality of life and potential negative health outcomes for Richmond residents.

Within the preferred alternative, the two main environmental impacts are air quality and hazardous
waste concerns that may impact the public health of the surrounding community. Potential
emissions stem from the operation of the modernization project, which includes the new hydrogen
plant as well as the sulfur removal units. Hydrogen is essential in the petroleum refining process
because it helps lower the sulfur content in diesel fuel. Lower sulfur content fuels are sought after
because they contain less particulate matter that can lead to soot, meaning a cleaner energy source.
However, emission reductions are balanced out because natural gas is used in the steam methane
reformers (SMRs) that create the hydrogen fuel (U.S. Energy Information Administration, 2016).
Based on emission analysis of the hydrogen plant operations, there is an anticipated increase in
emissions if no mitigation measures are taken. Criteria Air Pollutants (CAPS), consisting of six
common air pollutants defined by National Ambient Air Quality Standards (NAAQS), would
increase. Nitrogen oxides, particulate matter, and ground level ozone are the primary pollutants
from the hydrogen plant highlighted within the EIR. While the preferred alternative proposes the
newly constructed hydrogen plant to be at 100% operational capacity leading to increased
emissions, this new plant is slated to be 20% more efficient than the older plant and has additional
emission and safety mechanisms. This alternative seeks to limit these potential sources of emissions
by setting a baseline emissions standard on greenhouse gasses.

Sulfur compounds are found in all forms of crude oil. Sulfur content is heavily regulated in finished
petroleum products, requiring sulfur to be removed through the refining process. In terms of the
modernization project, improvements have been made to the existing sulfur removal units,
including the installation and modification of existing components such as heat exchangers, pumps,
storage tanks, and piping. These improvements allow higher levels of oxygen to be fed into the units,
allowing them to efficiently process hydrogen sulfide gas (H2S) inputs into elemental sulfur, sold for
agricultural and industrial purposes. With higher sulfur removal efficiency, the refinery is able to
take in more crude oil inputs, and crude oil inputs with higher sulfur concentrations. This may
result in an increase in emissions of sulfur compounds and Toxic Air Contaminants (TACs) that
negatively impact human health (City of Richmond, 2015). The increased stress from higher sulfur
crude oil inputs may also lead to potential pipe corrosion, with the risk of an accidental hazardous
waste release similar to the 2012 refinery fire incident. The pipe rupture and subsequent fire was
caused by sulfidation corrosion that degraded the steel pipe over time. The constant flow of sulfur
compounds and high temperatures degraded the pipe to a point of rupture, and a combination of
inadequate management and safety mechanisms led to this public health crisis (Final Investigation
Report, 2015). Changes in refinery infrastructure that take in sulfur crude oil inputs, like pipes and
sulfur removal units, have the potential to increase the amount of sulfur compound traveling
through pipes, allow inputs with higher sulfur content to be processed, as well as increase the
temperature of the overall system. Given that pipe corrosion is influenced by these factors,
construction or changes in refinery infrastructure can lead to increased rates of pipe corrosion. In
the case of the modernization project, changes in the sulfur removal unit and surrounding pipes
have the potential to amplify degradation risks. By reducing the daily crude oil capacity of the sulfur
removal units, the Reduced Sulfur Processing alternative reduces sulfur compound emissions as
well as reduces the risk of potential pipe corrosion and hazardous waste releases.

4. Environmental Aspect Analysis

The Reduced Sulfur Processing / No Increase in Greenhouse Gas Emissions Alternative would
increase the processing capacity for sulfur based crude oil and hydrogen outputs while resulting in
fewer greenhouse gas emissions in comparison to the proposed management plan without reduced
sulfur unit processing. There would be fewer CAPs and TACs overall. Despite increased emissions
generated from the hydrogen plant, new equipment and retrofits of older equipment would lead to
emission reductions offsetting the increased emissions from refinery operations. While there would
be no net change in overall emissions, the community would still be impacted. There is a lack of
analysis surrounding environmental justice impacts in the EIR. There would be increased sulfur
corrosion of refinery pipes due to the new sulfur removal units, but reduced crude oil inputs and
safety mechanisms proposed in the alternative would reduce pipe failure risk. Safety protocols and
policy are defined in a Risk Management Plan (RMP) given to the state with more specific local
requirements. Training programs and third party inspections are suggested, but there is not much
policy related to addressing pipe degradation from sulfur compound exposure.

This alternative was able to substantially reduce projected annual emissions incurred through the
operation of the refinery. Annual emissions from several emission types were analyzed for three
treatment groups in Table 6-22 of the EIR. The three groups consisted of the Baseline group
encompassing emissions from the refinery before the modernization project, emissions if the
modernization project was implemented, as well as emissions from the preferable Reduced Sulfur
Processing / No Increase in Greenhouse Gas Emissions Alternative.
As shown in the table, this alternative would result in substantially fewer emissions in comparison
to the proposed modernization project at 93% utilization, with a 13.6% reduction in annual
greenhouse gas emissions. Through its emission mitigation measures, it would successfully
generate annual emissions below the established baseline statistics, with the exception being
carbon monoxide with an additional one ton per year being generated in the preferred alternative.
Given these reduced emission levels, the refinery operations would not exceed emission thresholds
set by the Bay Area Air Quality Management District (BAAQMD) and CEQA. In addition, emissions
would be limited because the facility would not be able to operate at 100% utilization, as this would
lead to greenhouse gas emissions that exceed the threshold of 4,602,947 metric tons per year set in
this alternative. Instead, the facility would operate at 93% utilization.

The new hydrogen plant was projected to contribute to the majority of net emission increases;
however, these increases are offset by reduced emissions in other areas of the refinery. Under this
alternative proposal, the hydrogen plant would continue to operate at 100% capacity, leading to
greenhouse gas emissions that exceed the outlined threshold. These additional emissions are shown
in Table 6-24 of the EIR.

Increases in the listed CAPs from an average production of 66.9 million standard cubic feet of
hydrogen per day resulted in additional greenhouse gas emissions that total over 555,000 tons of
carbon dioxide annually. Despite this emission increase, reductions in CAPs, TACs, and greenhouse
gasses through interventions found in this alternative lead to an overall net decrease in greenhouse
gas emissions in comparison to the modernization proposal and baseline levels.

Emission reductions are facilitated through equipment replacements and modernizations outlined
in the modernization project and continued through the proposed alternative. There were
significant emission reductions resulting from new mechanical safeguards and technologies
focusing on the new hydrogen plant and improved sulfur removal units. New technology in the
hydrogen plant would make the process more fuel efficient, and less natural gas would be used. As a
result, each hydrogen product would be generated with less fuel and result in fewer emissions. New
low nitrous oxide burners and catalytic reduction units are further able to reduce nitrous oxide,
carbon monoxide, and sulfur dioxide emissions. Low nitrous oxide burners are also present in the
sulfur removal units. Improvements in stack heaters would lead to increased efficiencies in the
sulfur removal process, and help recirculate emissions back into the incoming fuel stock. In
addition, the installation of wet electrostatic precipitators would reduce particulate pollution and
sulfur acid mist.

While the area surrounding the refinery was examined for environmental impacts, there is a lack of
environmental justice considerations within the EIR. Despite mitigating air pollution impacts to be
below the set baseline, emissions from the operation of the facility remain. This means that
although overall emissions may be below the measured emissions from the 2008-2010 baseline
years, air pollution from the refinery still impacts vulnerable populations in Richmond. The specific
vulnerable impacted populations are not examined thoroughly in the report, with only a small
section about environmental justice briefly mentioning that the modernization project fulfills EJ
requirements established in the city of Richmond’s General Plan 2030, the city’s long term
development plan for sustainable growth. Instead of highlighting specific impacted communities
and neighborhoods, the report focused on a more general background of the community. It
mentions how the city is known for high TAC pollutant levels, but that the project itself would not
contribute to cumulative impacts that would necessitate mitigation. Targeted mitigation measures
such as air quality monitoring in certain neighborhoods and examinations of TAC emission sources
are suggested, but there is not much information present in the report about how these targeted
solutions would be implemented (City of Richmond, 2015).

Sulfidic corrosion is the most significant process leading to pipe corrosions and failures in a
petroleum refinery. With proposed upgrades to existing sulfur removal unit infrastructure under
the preferred alternative, potential increases in temperatures within these pipes as well as crude oil
blend with higher sulfur contents may exacerbate corrosion problems that can contribute to the
leakage of hazardous materials into the surrounding environment. Sulfur removal units take in
hydrogen sulfide and convert it into elemental sulfur. Through the Claus process, hydrogen sulfide is
combined with oxygen gas to form sulfur dioxide and water in a combustion chamber. These sulfur
dioxide outputs are then recombined with hydrogen sulfide to create the elemental sulfur outputs.
(EPA, 2015). Like many other sulfur inputs, the hydrogen sulfide that enters the sulfur removal units
is highly coercive. Scientific studies have shown that when hydrogen sulfide is combined with
oxygen and carbon dioxide, this speeds up corrosion reactions (Asmara, 2018). With improvements
to the sulfur units increasing the amount of oxygen being mixed with the hydrogen sulfide inputs,
corrosion rates of surrounding pipes will increase as a result of this project alternative. As a result,
the reduced capacity of these units would lead to less hydrogen sulfide inputs to flow through the
surrounding pipes, reducing corrosion and leading to less chances for pollution and community
harm. In addition, safety mechanisms meant to mitigate the impacts of sulfur compound related
corrosion are suggested under the preferred alternative. Hydrogen sulfide absorbers would be
installed throughout the refinery to remove these corrosive sulfur compounds from the gas stream.
Emergency scrubbers placed near the sulfur recovery units would provide a safeguard in
emergency situations where the recovery units are unable to process the hydrogen sulfide,
providing more time for this corrosive compound to be diverted.

While the increased risks of sulfur compound related corrosion are noted in the EIR, there is not
much insight into solutions to address this increased risk, with a focus on more generalized safety
mitigations. The main policy focus details federal, state, and local requirements for safety
procedures. Under the EPA’s Spill Prevention, Control, and Countermeasure (SPCC) Rule, it sets
standards for the owner of an oil operation to have an on hand policy detailing interventions in the
case of a potential oil spill. More specific guidelines are defined in California’s Accidental Release
Prevention Program (CalARP), requiring businesses like Chevron to have a Risk Management Plan
(RMP) submitted to local counties and governmental bodies. For RMPs, a thorough engineering
analysis is implemented, studying any potential accident risk factors and suggesting mitigation
measures to reduce risk. For the refinery modernization project, Chevron will submit an RMP to
Contra Costa County detailing hydrogen plant and sulfur removal unit operations, and providing an
amended list of potential hazardous material sources. There are additional safety mechanisms
required by the City of Richmond called Industrial Safety Ordinances (RISO) that supplement the
CalARP requirements, requiring additional safety measures and audits. This safety plan calls for
public input and review of audit results to foster community collaboration. When citing the
potential for corrosion risks related to increased crude oil inputs, several mitigation measures were
suggested. Given changes in refinery infrastructure, Chevron plans on reviewing existing
procedures and programs anticipating potentially changes and increases in hazards . More training
will be provided to refinery workers to ensure they are able to operate the new equipment, and
updated emergency procedures will be taught in coordination with the Richmond Fire Department.
There would specifically be more training focused on leak response protocols and shutdown
decisions. In addition, the fire protection plan will be updated to train the fire department on
response methods to potential vegetation fires near refinery buildings. There would be additional
funds to third party experts that would work with the county to review the refinery’s RMP and
regularly audit the facilities. To inform the surrounding community about hazardous waste release
incidents, Chevron has established a Community Warning System (CWS) that informs the
surrounding community about immediate threats in a four level alert system. For sulfidation
corrosion safety policies, the facility completed a 100% component inspection of all steel piping in
2015. To prevent pipeline failures in the future, Chevron plans on implementing regular inspections
to identify degraded pipes with insufficient thickness. After identifying at-risk pipes, they will be
able to implement established engineering practices to reinforce or replace them (City of Richmond,
2015).
5. Recommendation
By incorporating emission reduction mechanisms and policies, the Reduced Sulfur Processing / No
Increase in Greenhouse Gas Emissions Alternative proposed under the Chevron Richmond Refinery
Modernization Project is able to ensure economic benefits and modernization for the refinery and
Chevron while also acknowledging the health of the surrounding environment and the community.
The alternative proposes the completion of the hydrogen plant replacement and improvements to
the sulfur removal units, allowing the production of hydrogen and sulfur outputs that are essential
to the refining process and are potential sources of income for the refinery. Despite a reduction in
the capacity of the sulfur removal units, this alternative would still allow the refinery to achieve a
greater amount of hydrogen sulfide inputs and increased sulfur outputs over pre-project limits. By
proposing equipment improvements, this alternative would make the operations of the refinery
more efficient, safer, and environmentally friendly. Specific emission reductions mechanisms
implemented on the hydrogen plant and sulfur removal units would lead the project to generate
fewer annual emissions in comparison to the proposed modernization project as well as pre-project
refinery production. As fewer emissions would be generated through this alternative, it would meet
overarching air quality and environmental standards that meet regulatory policies and meet its own
emissions goals as well. Despite these mitagations in the alternative , there is a lack of focus on the
public safety of the surrounding community within this alternative. While annual emissions may not
exceed pre modernization project levels, the community is still impacted by the air pollution and
risks associated with the daily operation of the Chevron refinery. More must be done to support the
community through investment programs and more must be done to safeguard the community
against the risk of hazardous waste releases caused by pipe corrosion.

While this construction project would economically benefit and modernize the refinery, the
surrounding community should be able to receive benefits from this project as well. Within the EIR,
there is a lack of analysis into who in the community would be the most impacted and marginalized
by the project. Targeted investment programs in public services and public health would help
address these environmental justice and equity concerns. After the final EIR was approved, the City
of Richmond and Chevron agreed to an Environmental Community Investment Agreement (ECIA)
which would provide $90 million dollars of community investment over ten years. There were
several public meetings to gauge what types of programs community members were interested in.
Local emission reduction projects were encouraged and spearheaded with projects that include air
quality studies conducted by local highschool science departments and solar panel installations.
Public safety was emphasized through investments in training programs that trained the fire
department and county sheriff, and equipped local schools and community areas with emergency
response procedures. The local community was supported through investment in nonprofits, a
youth education scholarship, professional development funding, and a grant program for
community projects. In terms of public health, investments would focus on diagnosing and
addressing health inequities, by establishing direct community health care centers and asthma
prevention programs. Annual reports would be published by the City of Richmond detailing ECIA
project outcomes, greenhouse gas reductions, and expenditures. Having these annual reports would
provide transparency on whether these programs are actually benefiting the community and how
the money is being spent (City of Richmond, 2014). This investment program is able to directly
reinvest in the community through targeted programs. While the negative health impacts associated
with refinery operations remain, community health programs and local emission reduction projects
all come together to mitigate the most serious impacts.

Learning from the 2012 fire incident, this alternative seeks to provide safeguards against sulfidic
corrosion as well. In addition to reducing emissions, the reduction of the sulfur removal units’
capacity to take in crude oil will reduce the potential of pipe corrosion and failure that can lead to
air pollution and hazardous waste risks to both workers at the refinery and the Richmond
community. While safety mechanisms such as hydrogen sulfide absorbers and emergency scrubbers
are proposed, this alternative does not include enough concrete policy and management related
proposals that can provide safeguards against risks to human health. There must be more defined
protections to ensure that refinery staff and management are prepared for potential pipe leakages.
To ensure that the refinery does not have any future incidents, robust safety and emergency
response policies must be defined, implemented, and communicated to the public. Thorough
inspections on all refinery components, not just pipes, should be regularly implemented by trained
personnel and engineers to identify potential areas of corrosion and pipe leakage. In addition, a
thorough analysis of the collected data from inspection is necessary to provide up to date
recommendations surrounding pipe integrity and potential necessary replacements. In order to
ensure the effective implementation of these policies, the refinery should hire additional workers
and third party inspection experts. In addition to inspection improvements, there must be a more
robust safety response protocol to potential safety incidents. While Chevron operates an online
dashboard called Operational Excellence and Reliability Intelligence (OERI) that accounts for and
defines 26 safety indicators for their refineries, a lack of site-specific policy has led to confusion and
mismanagement during emergency incidents. By establishing guidance and protocol for pipe leaks
surrounding the roles of operations personnel, refinery management, emergency responders
(firemen), and Contra Costa County, this would allow for immediate and effective delegation and
response (U.S. Chemical Safety and Hazard Investigation Board, 2015). In addition to training
workers on these safety policies, these policies must be communicated to the public as well to
ensure transparency and a more informed and prepared citizens in cases of emergency. This can be
facilitated through town hall meetings that inform the public on up to date safety procedures and
publicized annual compliance reports to the city.
 References
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