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  Response Opportunity to Industrial Safety Audit a Sham
November 23, 2003

The Richmond Industrial Safety Ordinance (RMC Chapter 6.43) requires an annual review, audit and inspection pursuant to Safety Plans submitted by stationary sources (ChevronTexaco and General Chemical). The public is supposed to have a 45-day response time. The materials are supposed to be available for review in the Richmond Public Library.


The public comment period for the current plans began on October 10, 2003, but no one told the public. On November 14, Contra Costa Health Services (CCHS) issued a press release about an obligatory public meeting to be held in North Richmond four days later on November 18. There was little or no press coverage. The public comment period ends tomorrow; 10 days after CCHS publicly announced the process. I have received complaints that the review materials are not available in the Richmond Public Library.


In both the press release and the CCHS website (http://cchealth.org/special/public_comment_oct_nov_2003.html), an email address was given to which to send responses. The address, ARPTeam@hsd.co.contra-costa.ca.us, apparently is not working.


I tried it, myself, and received the following message:


Your message did not reach some or all of the intended recipients.


      Subject:             CalARP and RISO Audit

      Sent:                 11/23/2003 8:58 AM


The following recipient(s) could not be reached:


      ARPTeam@hsd.co.contra-costa.ca.us on 11/23/2003 8:58 AM

            The e-mail system was unable to deliver the message, but did not report a specific reason.  Check the address and try again.  If it still fails, contact your system administrator.

            <hsd.co.contra-costa.ca.us #5.0.0 X-Notes; Error delivering to ARPTeam; File does not exist>


If I were a conspiracy advocate, I would be suspicious. But this is probably just government being government.


Under the circumstances, I have requested that the entire process be started anew, with adequate notification, adequate access to pertinent documents, and a working email address to which to send comments.


I donít know whether or not, my request will be considered, so I urge concerned citizens to send their comments immediately to the two addresses I do have that seem to work; rsawyer@hsd.co.contra-costa.ca.us and jfreesto@hsd.co.contra-costa.ca.us.


I have requested the following:


I demand that ChevronTexaco and General Chemical plan and implement Inherently Safer Systems in order to reduce the WCS and ARS radius in such a way as to exclude Point Molate, I-590, Point Richmond and inhabited areas of west Richmond.

I am specifically concerned about the release of ammonia and the explosion of a butane storage sphere.

To the extent that an oleum, sulfur dioxide or sulfer trioxide release from general Chemical remains a potential hazard, I include them.

I am also requesting an extension of time for comment on the CalARP and RISO Audit. The press release from the CCHS announcing the opportunity to respond was dated November 14, which was 1 Ĺ months after the comment period began, four days before the public meeting and only 10 days before it closed. I have also had complaints that the material was not available in the Richmond Public Library as required.

I do not believe that the provisions of RMC 6.43.100 have been complied with.