Safety Culture at Chevron’s Richmond, CA Refinery

The U.S. Chemical Safety and Hazard Investigation Board (CSB) released its final report* on the August 2012 fire at the Chevron refinery in Richmond, CA caused by a leaking pipe.  In the discussion around the CSB’s interim incident report (see our April 16, 2013 post) the agency’s chairman said Chevron’s safety culture (SC) appeared to be a factor in the incident.  This post focuses on the final report findings related to the refinery’s SC.

During their investigation, the CSB learned that some personnel were uncomfortable working around the leaking pipe because of potential exposure to the flammable fluid.  “Some individuals even recommended that the Crude Unit be shut down, but they left the final decision to the management personnel present.  No one formally invoked their Stop Work Authority.  In addition, Chevron safety culture surveys indicate that between 2008 and 2010, personnel had become less willing to use their Stop Work Authority. . . . there are a number of reasons why such a program may fail related to the ‘human factors’ issue of decision-making; these reasons include belief that the Stop Work decision should be made by someone else higher in the organizational hierarchy, reluctance to speak up and delay work progress, and fear of reprisal for stopping the job.” (pp. 12-13) 

The report also mentioned decision making that favored continued production over safety. (p. 13)  In the report’s details, the CSB described the refinery organization’s decisions to keep operating under questionable safety conditions as “normalization of deviance,” a term popularized by Diane Vaughn and familiar to Safetymatters readers. (p. 105) 

The report included a detailed comparison of the refinery’s 2008 and 2010 SC surveys.  In addition to the decrease in employees’ willingness to use their Stop Work Authority, surveyed operators and mechanics reported an increased belief that using such authority could get them into trouble (p. 108) and that equipment was not properly cared for. (p. 109) 

Our Perspective

We like the CSB.  They’re straight shooters and don’t mince words.  While we are not big fans of SC surveys, the CSB’s analysis of Chevron’s SC surveys appears to show a deteriorating SC between 2008 and 2010. 

Chevron says they agree with some CSB findings however Chevron believes “the CSB has presented an inaccurate depiction of the Richmond Refinery’s current process safety culture.”  Chevron says “In a third-party survey commissioned by Contra Costa County, when asked whether they feel free to use Stop Work Authority during any work activity, 93 percent of Chevron refinery workers responded favorably.  The overall results for the process safety survey exceeded the survey taker’s benchmark for North American refineries.”**  Who owns the truth here?  The CSB?  Chevron?  Both?    

In 2013, the city of Richmond adopted an Industrial Safety Ordinance (RISO) that requires Chevron to conduct SC assessments, preserve records and develop corrective actions.  The CSB recommendations including beefing up the RISO to evaluate the quality of Chevron’s action items and their actual impact on SC. (p. 116)

Chevron continues to receive blowback from the incident.  The refinery is the largest employer and taxpayer in Richmond.  It’s not a company town but Chevron has historically had a lot of political sway in the city.  That’s changed, at least for now.  In the recent city council election, none of the candidates backed by Chevron was elected.***

As an aside, the CSB report referenced a 2010 study**** that found a sample of oil and gas workers directly intervened in only about 2 out of 5 of the unsafe acts they observed on the job.  How diligent are you and your colleagues about calling out safety problems?

*  CSB, “Final Investigation Report Chevron Richmond Refinery Pipe Rupture and Fire,” Report No. 2012-03-I-CA (Jan. 2015).

**  M. Aldax, “Survey finds Richmond Refinery safety culture strong,” Richmond Standard (Jan. 29, 2015).  Retrieved Jan. 29, 2015.  The Richmond Standard is a website published by Chevron Richmond.

***  C. Jones, “Chevron’s $3 million backfires in Richmond election,” SFGate (Nov. 5, 2014).  Retrieved Jan. 29, 2015.

****  R.D. Ragain, P. Ragain, Mike Allen and Michael Allen, “Study: Employees intervene in only 2 of 5 observed unsafe acts,” Drilling Contractor (Jan./Feb. 2011).  Retrieved Jan. 29, 2015.

DNFSB Hearings on Safety Culture, Round Two

DNFSB Headquarters

On August 27, 2014 the Defense Nuclear Facilities Safety Board (DNFSB) convened the second of three hearings “to address safety culture at Department of Energy defense nuclear facilities and the Board’s Recommendation 2011–1, Safety Culture at the Waste Treatment and Immobilization Plant.”*  The first hearing was held on May 28, 2014 and heard from industry and federal government safety culture (SC) experts; we reviewed that hearing on June 9, 2014.  The second hearing received SC expert testimony from the U.S. Navy, the U.S. Chemical Safety and Hazard Investigation Board and academia.  The following discussion reviews the presentations in the order they were made to the board. 


Adm. Norton's (Naval Safety Center) presentation** on the Navy’s SC programs was certainly comprehensive with 32 slides for a half-hour talk (plus 22 backup slides).  It appears the major safety focus has been on aviation but the Center’s programs also address the afloat communities (surface, submarine and diving) and Marines.  The programs make heavy use of surveys and unit visits in addition to developing and presenting training and workshops.  Not surprisingly, the Navy stresses the importance of leadership, especially personal involvement and commitment, in creating a strong SC.  They recognize that implementing a strong SC faces a direct challenge from other organizational values such as the warfighter mentality*** and softer challenges in areas such as IT (where there are issues with multiple systems and data problems).

Program strengths include the focus on leadership (leadership drives climate, climate drives cultural change) and the importance of determining why mishaps occurred.  The positive influence of a strong SC on decision making is implied.

Program weaknesses can be inferred from what was not mentioned.  For example, there was no discussion of the importance of fixing problems or identifying hard-to-see technical problems.  More significantly, there was no mention of High Reliability Organization (HRO) attributes, a real head-scratcher given that some of the seminal work on HROs was conducted on aircraft carriers. 

Adm. Eccles' (Navy ret.) presentation**** basically reviews the Navy’s SUBSAFE program and its focus on compliance with program requirements from design through operations.  Eccles notes that ignorance, arrogance and complacency are challenges to maintaining an effective program.

Mr. Griffon's (Chemical Safety Board Member) presentation***** illustrates the CSB’s straightforward approach to investigating incidents, as reflected in the following quotes:

“Intent of CSB investigations are to get to root cause(s) and make recommendations toward prevention.” (p. 3)

While searching for root causes the CSB asks: “Why conditions or decisions leading to accident were seen as normal, rational, or acceptable prior to the accident.” (p. 4)

CSB review of incident-related artifacts includes two of our hot button issues, Process Safety Management action item closure (akin to a CAP) and the repair backlog. (p. 5)  Griffon reviews major incidents, e.g., Texas City and Deepwater Horizon.  For Deepwater, he notes how certain decisions were (deliberately) incompletely informed, i.e., did not utilize readily available relevant information, and thus are indicative of an inadequate SC. (p. 16)  Toward the end Griffon observes that “Safety culture study/change must consider inequalities of power and authority.” (p. 19)  That seems obvious but it doesn’t often get said so clearly.

We like the CSB’s approach.  There is no new information here but it’s a quick read of what basic SC should and shouldn’t be.

Prof. Meshkati's (Univ. of S. Cal.) presentation^ compares the cultures at TEPCO’s Fukushima Daiichi plant and Tohoku Electric’s Onagawa plant.  It is mainly a rehash of the op-ed Meshkati co-authored back in March 2014 (and we reviewed on March 19, 2014.)  The presentation adds something we pointed out as an omission in that op-ed, viz., that TEPCO’s Fukushima Daini plant eventually managed to shut down safely after the earthquake and tsunami.  Meshkati notes approvingly that Daini personnel exhibited impromptu, but prudent, decision-making and improvisation, e.g., by flexibly applying emergency operation procedures. (p. 37)

Prof. Sutcliffe (John Hopkins Univ.) co-authored an important book on High Reliability Organizations (which we reviewed on May 3, 2013) and this academically-oriented presentation^^ draws on her earlier work.  It begins with a familiar description of culture and how its evolution can be influenced.  Importantly it shows rewards (including money) as a key input affecting the link between leaders’ philosophy and employees’ behavior. (p. 6) 

Sutcliffe discusses how failure to redirect action (in a situation where a change is needed) can result from failure of foresight or sensemaking, or being overcome by dysfunctional momentum.  She includes a lengthy example featuring wildland firefighters that illustrates the linkages between cues, voiced concerns, search for disparate perspectives, situational reevaluation and redirected actions.  It’s worth a few minutes of your time to flip through these slides.

Our Perspective

For starters, the Naval Safety Center's activities may be too bureaucratic, with too many initiatives and programs, and focused mainly on compliance with procedures, rules, designs, etc.  It’s not clear what SC lessons can be learned from the Navy experience beyond the vital role of leadership in creating a cultural vision and attempting to influence behavior toward that vision.

The other presenters added nothing that was not already available to you, either through Safetymatters or from observing SC tidbits in the information soup that flows by everyone these days.

Subsequent to the first hearing we reported that Safety Conscious Work Environment (SCWE) issues exist at multiple DOE sites (see our July 8, 2014 post).  This should increase the sense of urgency associated with strengthening SC throughout DOE.  However, our bottom line remains the same as after the first hearing: “The DNFSB is still trying to figure out the correct balance between prescription and flexibility in its effort to bring DOE to heel on the SC issue.  SC is a vital part of the puzzle of how to increase DOE line management effectiveness in ensuring adequate safety performance at DOE facilities.” 


*  DNFSB Aug. 27, 2014 Public Hearing on Safety Culture and Board Recommendation 2011-1.  There is a video of the hearing available.

**  K.J. Norton (U.S. Navy), “The Naval Safety Center and Naval Safety Culture,“ presentation to DNFSB (Aug. 27, 2014).

***  “Anything, anywhere, anytime…at any cost”—desirable warfighter mentality perceived to conflict with safety.” (p. 11)

****  T. J. Eccles (U.S. Navy ret.), “A Culture of Safety: Submarine Safety in the U. S. Navy,” presentation to DNFSB (Aug. 27, 2014).

*****  M.A. Griffon (Chem. Safety Bd.), “CSB Investigations and Safety Culture,” presentation to DNFSB (Aug. 27, 2014).

^  Najm Meshkati, “Leadership and Safety Culture: Personal Reflections on Lessons Learned,” presentation to DNFSB (Aug. 27, 2014).  Prof. Meshkati was also the technical advisor to the National Research Council’s safety culture lessons learned from Fukushima report which we reviewed on July 30, 2014.

^^  K.M. Sutcliffe, “Leadership and Safety Culture,” presentation to DNFSB (Aug. 27, 2014).

Warning Shot for Chevron

White vapor and black smoke.  From CSB report.

On August 6, 2012 a leaking pipe at the Chevron refinery in Richmond, CA led to a fire that shut down a crude oil distillation unit and caused over 15,000 people to report to local hospitals seeking treatment for respiratory and other health issues.  This was not a Texas City.  About 20 of the 15,000 people were admitted to local hospitals and there were some minor injuries to employees in the area of the fire but no fatalities.  However, it should be a wake-up call for Chevron. 

The proximate cause of the leak was a pipe ("4-sidecut") that had corroded because of the fluids that flowed through it.  But the Chevron and Chemical Safety Board (CSB) investigations showed there was a ten-year trail of missed possibilities to identify and correct the problem, including the following: In 2002, an employee inspector had expressed concern about sulfidation corrosion in the 4-sidecut and recommended upgrading it but his recommendation was never implemented.  In the same year, an incident at another Chevron refinery led the company to recommend 100% inspection of pipes for corrosion but this was not implemented at Richmond.  In 2009 and 2010 Chevron promulgated new warnings about sulfur corrosion and reiterated the recommendation for 100% inspection but Richmond did not implement any remedial actions on the 4-sidecut.*  In 2011, after a fire in another pipe, Richmond employees complained to Cal/OSHA about the company ignoring corrosion dangers but Chevron rationalized their way out of the issue.**

Chevron's incident investigation, including a root cause analysis, resulted in multiple corrective actions that will ring familiar to our readers.  Summarized, they are: look harder for corrosion; upgrade the hardware reliability program and supporting procedures; increase oversight and training; implement new rules for evaluating leaks; and emphasize the importance of process safety in decision making.  In even fewer words, tweak the system and retrain.

There is no mention of safety culture (SC) but the odor of a weak or compromised SC wafts from the report.  In a strong SC, the 2002 inspector would have identified the potential problem, documented it in the corrective action program and monitored progress until the issue was resolved.  The corrective action program would have evaluated, prioritized and resourced the problem's resolution consistent with its safety significance.  Outside experience and directives (from other Chevron entities or elsewhere) would have been regularly integrated into local operating practices, including inspection, maintenance and process procedures.

We are not alone in recognizing the importance of SC.  The local county supervisor, who also chairs the Bay Area Air Quality Management District, said “We need to do a thorough review of the safety culture at the refinery.”***  The CSB's managing director said the company had a “tolerance for allowing piping to run toward failure” and “I think it points to a certain cultural issue.”****  The CSB's interim report says “After reviewing evidence and decisions . . . the CSB has determined that issues relating to safety culture are relevant to this incident. The CSB will examine the Chevron Richmond Refinery’s approach to safety, its safety culture and any organizational deficiencies, to determine how to best prevent future incidents.” (p. 61)

We'll see if Chevron gets the hint.


*  CUSA Richmond Investigation Team, “Richmond Refinery 4 Crude Unit Incident August 6, 2012” (April 12, 2013).  Attachment to letter from S. Wildman (Chevron) to R.L. Sawyer (Contra Costa County Health Services), “Seventh Update to the 30-Day Report for the CWS Level 3 Event of August 6, 2012” (April 12, 2013).  

U.S. Chemical Safety and Hazard Investigation Board, “Interim Investigation Report Chevron Richmond Refinery Fire” (April 15, 2013).  In addition to Chevron, the CSB also criticizes regulatory and other government agencies, particularly Cal/OSHA, for shortcomings in their oversight of refinery activities.

**  J. Van Derbeken, “Chevron ignored risk in '11, workers say” sfgate.com (Oct. 13, 2012).

***  J. Van Derbeken, “Chevron fire report shows troubled history” sfgate.com (April 13, 2013).

****  J. Van Derbeken, “Chevron fire sign of weak oversight” sfgate.com (April 15, 2013).

Nuclear Safety Culture Research

This is a subject that has been on our minds for some time.  Many readers may have eagerly jumped to this post to learn about the latest on research into nuclear safety culture (NSC) issues.  Sorry, you will be disappointed just as we were.  The painful and frankly inexplicable conclusion is that there is virtually no research in this area.  How come?

There is the oft-quoted 2002 comment by then ACRS Chairman, Dr. George Apostolakis:

"For the last 20 to 25 years this agency [the NRC] has started research projects on organizational-managerial issues that were abruptly and rudely stopped because, if you do that, the argument goes, regulations follow. So we don't understand these issues because we never really studied them."*

A principal focus of this blog has been to bring to the attention of our readers relevant information from academic and research sources.  We cover a wide range of topics where we see a connection to nuclear safety culture.  Thus we continually monitor additions to the science of NSC through papers, presentations, books, etc.  In doing so we have come to realize, there is and has been very little relevant research specifically addressing nuclear safety culture.  Even a search of secondary sources; i.e., the references contained in primary research documents, indicates a near vacuum of NSC-specific research.  This is in contrast to the oil and chemical industries and the U.S. manned space program.  In an August 2, 2010 post we described research by  Dr. Stian Antonsen of the Norwegian University of Science and Technology on “..whether it is possible to ‘predict’ if an organization is prone to having major accidents on the basis of safety culture assessments” [short answer: No].

Returning to the September 2012 DOE Nuclear Safety Workshop (see our Oct. 8, 2012 post), where nuclear safety culture was a major agenda item, we observe the only reference in all the presentations to actual research was from the results of an academic study of 17 offshore platform accidents to identify “cultural causal factors”. (See Mark Griffon’s presentation, slide 17.)

With regard to the manned space program, recall the ambitious MIT study to develop a safety culture simulation model for NASA and various independent studies, perhaps most notably Diane Vaughan's The Challenger Launch Decision.  We have posted on each of these.

One study we did locate that is on topic is an empirical analysis of the use of safety culture surveys in the Millstone engineering organization performed by Professor John Carroll of MIT.  He found that “their [surveys'] use for assessing and measuring safety culture...is problematic…”**  It strikes us as curious that the nuclear industry which has so strongly embraced culture surveys hasn’t followed that with basic research to establish the legitimacy and limits of their application.

To further test the waters for applicable research we reviewed the research plans for major nuclear organizations.  The NRC Strategic Plan Fiscal Years 2008-2013 (Updated 2012)*** cites two goals in this area, neither of which address substantive nuclear safety culture issues:

Promote awareness of the importance of a strong safety culture and individual accountability of those engaged in regulated activities. (p.9)

Ensure dissemination of the Safety Culture Policy Statement to all of the regulated community. [Supports Safety Implementation Strategy 7] (p.12)

DOE’s 2010 Nuclear Energy Research and Development Roadmap identifies the following “major challenges”:

- Aging and degradation of system structures and components, such as reactor core internals, reactor pressure vessels, concrete, buried pipes, and cables.
- Fuel reliability and performance issues.
- Obsolete analog instrumentation and control technologies.
- Design and safety analysis tools based on 1980s vintage knowledge bases and computational capabilities.****

The goals of these nuclear research programs speak for themselves.  Now compare to the following from the Chemical Safety Board Strategic Plan:

“Safety Culture continues to be cited in investigations across many industry sectors including the Presidential Commission Report on Deepwater Horizon, the Fukushima Daiichi incident, and the Defense Nuclear Facilities Safety Board’s recommendation for the Hanford Waste Treatment and Immobilization Plant. A potential study would consider issues such as how safety culture is defined, what makes an effective safety culture, and how to evaluate safety culture.”*****

And this from the VTT Technical Research Centre of Finland, the largest energy sector research unit in Northern Europe.

Man, Organisation and Society – in this area, safety management in a networked operating environment, and the practices for developing nuclear safety competence and safety culture have a key role in VTT's research. The nuclear specific know-how and the combination of competencies in behavioural sciences and fields of technology made possible by VTT's multidisciplinary expertise are crucial to supporting the safe use of nuclear power.#

We invite our readers to bring to our attention any NSC-specific research of which they may be aware.


*  J. Mangels and J. Funk, “Davis-Besse workers' repair job hardest yet,” Cleveland Plain Dealer (Dec. 29, 2002).  Retrieved Oct. 29, 2012.

**    J.S. Carroll, "Safety Culture as an Ongoing Process: Culture Surveys as Opportunities for Inquiry and Change," work paper (undated) p.23, later published in Work and Stress 12 (1998), pp. 272-284.

***  NRC "Strategic Plan: Fiscal Years 2008–2013" (Feb. 2012) published as NUREG-1614, Vol. 5.

****  DOE, "Nuclear Energy Research and Development Roadmap" (April 2010) pp. 17-18. 

*****  CSB, "2012-2016 US Chemical Safety Board Strategic Plan" (June 2012) p. 17.
  
#  “Nuclear power plant safety research at VTT,” Public Service Review: European Science and Technology 15 (July 13, 2012).  Retrieved Oct. 29, 2012.

DOE Nuclear Safety Workshop

The DOE held a Nuclear Safety Workshop on September 19-20, 2012.  Safety culture (SC) was the topic at two of the technical breakout sessions, one with outside (non-DOE) presenters and the other with DOE-related presenters.  Here’s our take on the outsiders’ presentations.

Chemical Safety Board (CSB)

This presentation* introduced the CSB and its mission and methods.  The CSB investigates chemical accidents and makes recommendations to prevent recurrences.  It has no regulatory authority. 

Its investigations focus on improving safety, not assigning blame.  The CSB analyzes systemic factors that may have contributed to an accident and recognizes that “Addressing the immediate cause only prevents that exact accident from occurring again.” (p. 5) 

The agency analyzes how safety systems work in real life and “why conditions or decisions leading to an accident were seen as normal, rational, or acceptable prior to the accident.” (p. 6)  They consider organizational and social causes, including “safety culture, organizational structure, cost pressures, regulatory gaps and ineffective enforcement, and performance agreements or bonus structures.” (ibid.)

The presentation included examples of findings from CSB investigations into the BP Texas City and Deepwater Horizon incidents.  The CSB’s SC model is adapted from the Schein construct.  What’s interesting is their set of artifacts includes many “soft” items such as complacency, normalization of deviance, management commitment to safety, work pressure, and tolerance of inadequate systems.

This is a brief and informative presentation, and well worth a look.  Perhaps because the CSB is unencumbered by regulatory protocol, it seems freer to go where the evidence leads it when investigating incidents.  We are impressed by their approach.
 
NRC

The NRC presentation** reviewed the basics of the Reactor Oversight Process (ROP) and then drilled down into how potential SC issues are identified and addressed.  Within the ROP, “. . . a safety culture aspect is assigned if it is the most significant contributor to an inspection finding.” (p.12)  After such a finding, the NRC may perform an SC assessment (per IP 95002) or request the licensee to perform one, which the NRC then reviews (per IP 95003).

This presentation is bureaucratic but provides a useful road map.  Looking at the overall approach, it is even more disingenuous for the NRC to claim that it doesn’t regulate SC.

IAEA

There was nothing new here.  This infomercial for IAEA*** covered the basic history of SC and reviewed contents of related IAEA documents, including laundry lists of desired organizational attributes.  The three-factor IAEA SC figure presented is basically the Schein model, with different labels.  The components of a correct culture change initiative are equally recognizable: communication, continuous improvement, trust, respect, etc.

The presentation had one repeatable quote: “Culture can be seen as something we can influence, rather than something we can control” (p. 10)

Conclusion

SC conferences and workshops are often worthless but sometimes one does learn things.  In this case, the CSB presentation was refreshingly complete and the NRC presentation was perhaps more revealing than the presenter intended.


*  M.A. Griffon, U.S. Chemical Safety and Hazards Investigation Board, “CSB Investigations and Safety Culture,” presented at the DOE Nuclear Safety Workshop (Sept. 19, 2012). 

**  U. Shoop, NRC, “Safety Culture in the U.S. Nuclear Regulatory Commission’s Reactor Oversight Process,” presented at the DOE Nuclear Safety Workshop (Sept. 19, 2012).

***  M. Haage, IAEA, “What is Safety Culture & Why is it Important?” presented at the DOE Nuclear Safety Workshop (Sept. 19, 2012).