The CSB issues safety recommendations to prevent the recurrence or reduce the likelihood or consequences of similar incidents or hazards in the future. Recommendations are issued to a variety of parties, including government entities, safety organizations, trade unions, trade associations, corporations, emergency response organizations, educational institutions, and public interest groups. Recommendations are published in CSB reports and are closed only by vote of the Board. The CSB tracks all recommendations and communicates regularly with recommendations recipients to ensure that the recommended corrective actions are implemented. For more information, see Frequently Asked Questions about CSB recommendations.
2004-9-I-GA-8
Establish, equip, and train a hazardous materials response team. Work with the Whitfield County Emergency Management Agency to update the Emergency Operations Plan, clearly defining the roles and responsibilities of the response team. Status: Closed - Acceptable Action
Establish, equip, and train a hazardous materials response team. Work with the Whitfield County Emergency Management Agency to update the Emergency Operations Plan, clearly defining the roles and responsibilities of the response team.
2004-9-I-GA-9
Revise fire department and police department procedures and training to clearly define facility and evacuation zone access control responsibilities when hazardous chemicals are involved or suspected in an emergency. Status: Closed - Acceptable Action
Revise fire department and police department procedures and training to clearly define facility and evacuation zone access control responsibilities when hazardous chemicals are involved or suspected in an emergency.
2004-9-I-GA-12
Clearly designate and define the roles of the agencies responsible for ensuring compliance with all sections of the SARA Title III (Emergency Planning and Community Right-to-Know Act) including review of Local Emergency Response Plans and accompanying attachments, such as standard operating procedures. Status: Closed - Acceptable Action
Clearly designate and define the roles of the agencies responsible for ensuring compliance with all sections of the SARA Title III (Emergency Planning and Community Right-to-Know Act) including review of Local Emergency Response Plans and accompanying attachments, such as standard operating procedures.
2004-9-I-GA-13
Designate a responsible agency and develop a system that will encourage and assist local authorities to obtain and use Risk Management Plans for those facilities that are required to develop this information to aid in the development of the site-specific emergency response plans. Status: Closed - Acceptable Action
Designate a responsible agency and develop a system that will encourage and assist local authorities to obtain and use Risk Management Plans for those facilities that are required to develop this information to aid in the development of the site-specific emergency response plans.
2004-9-I-GA-5
Implement written procedures for tolling agreements using resources such as the CCPS book Process Safety in Outsourced Manufacturing Operations. Ensure that tolling agreements provide for: - Direct GPC involvement in new process development, including the detailed process hazard analysis and emergency planning, - Active participation in the first production run, as appropriate. Status: Closed - Acceptable Action
Implement written procedures for tolling agreements using resources such as the CCPS book Process Safety in Outsourced Manufacturing Operations. Ensure that tolling agreements provide for: - Direct GPC involvement in new process development, including the detailed process hazard analysis and emergency planning, - Active participation in the first production run, as appropriate.
2004-9-I-GA-6
Revise the applicable sections of the Allyl Alcohol Product Safety Bulletin, appendices, and web page, to emphasize the applicability of the EPA Risk Management Program regulation and OSHA Process Safety Management standard. Clearly identify the threshold quantity of allyl alcohol applicable to each regulation. Status: Closed - Acceptable Action
Revise the applicable sections of the Allyl Alcohol Product Safety Bulletin, appendices, and web page, to emphasize the applicability of the EPA Risk Management Program regulation and OSHA Process Safety Management standard. Clearly identify the threshold quantity of allyl alcohol applicable to each regulation.
2004-9-I-GA-7
Revise the customer site safety assessment process, clearly addressing both PSM and Risk Management Program applicability before shipping allyl alcohol to a new customer. Include a requirement to review the customer's program documents, including the (draft) RMP, and internal and external safety audit or assessment records. Require that appropriate Lyondell health, safety, and environmental personnel review the written customer safety assessment before approving the shipment of allyl alcohol. Status: Closed - Acceptable Action
Revise the customer site safety assessment process, clearly addressing both PSM and Risk Management Program applicability before shipping allyl alcohol to a new customer. Include a requirement to review the customer's program documents, including the (draft) RMP, and internal and external safety audit or assessment records. Require that appropriate Lyondell health, safety, and environmental personnel review the written customer safety assessment before approving the shipment of allyl alcohol.
2004-9-I-GA-1
Develop written procedures that require a comprehensive hazard analysis of new processes, especially those involving reactive chemistry. Ensure the hazard evaluations address critical process controls, overpressure protection, alarms, and other equipment such as vent collection/containment devices to minimize the possibility and consequences of a toxic or flammable release. Status: Closed - Acceptable Action
Develop written procedures that require a comprehensive hazard analysis of new processes, especially those involving reactive chemistry. Ensure the hazard evaluations address critical process controls, overpressure protection, alarms, and other equipment such as vent collection/containment devices to minimize the possibility and consequences of a toxic or flammable release.
2004-9-I-GA-2
Provide EPA Risk Management Program regulation and OSHA Process Safety Management program training to affected personnel to ensure that the facility understands the scope and application of each regulation, and implements all requirements prior to receiving and using covered chemicals. Status: Closed - Acceptable Action
Provide EPA Risk Management Program regulation and OSHA Process Safety Management program training to affected personnel to ensure that the facility understands the scope and application of each regulation, and implements all requirements prior to receiving and using covered chemicals.
2004-9-I-GA-3
Create a comprehensive emergency response plan and provide equipment and training that is appropriate to the duties assigned to employees in the event of an emergency. Status: Closed - Acceptable Action
Create a comprehensive emergency response plan and provide equipment and training that is appropriate to the duties assigned to employees in the event of an emergency.
2004-9-I-GA-4
Implement written tolling procedures using resources such as the CCPS book Process Safety in Outsourced Manufacturing Operations. Ensure effective communication between the toller (MFG) and client throughout the process development, completion of a detailed process hazard analysis, creation of emergency procedures, and dissemination to all parties who would be involved in emergency response situations. Status: Closed - Acceptable Action
Implement written tolling procedures using resources such as the CCPS book Process Safety in Outsourced Manufacturing Operations. Ensure effective communication between the toller (MFG) and client throughout the process development, completion of a detailed process hazard analysis, creation of emergency procedures, and dissemination to all parties who would be involved in emergency response situations.
2004-9-I-GA-14
Revise the SOCMA website to simplify locating the link to the CSB website www.csb.gov, such as adding a link in "More Resources" on the SOCMA home page. Ensure that the CSB website and the report Hazard Investigation: Improving Reactive Hazard Management, Report No. 2001-01-H can be easily located using the SOCMA website search engine. Status: Closed - Acceptable Action
Revise the SOCMA website to simplify locating the link to the CSB website www.csb.gov, such as adding a link in "More Resources" on the SOCMA home page. Ensure that the CSB website and the report Hazard Investigation: Improving Reactive Hazard Management, Report No. 2001-01-H can be easily located using the SOCMA website search engine.
2004-9-I-GA-15
Develop a ChemStewards Management System Guidance Module that addresses tolling, including the best practices described in the CCPS book Process Safety in Outsourced Manufacturing Operations, and emergency planning involving new products. Status: Closed - Acceptable Alternative Action
Develop a ChemStewards Management System Guidance Module that addresses tolling, including the best practices described in the CCPS book Process Safety in Outsourced Manufacturing Operations, and emergency planning involving new products.
2004-9-I-GA-16
Develop a formal training module for the ChemStewards Management System Tolling Guidance Module and provide appropriate training to SOCMA member companies. Include in the training program a discussion on the tolling issues identified in the MFG report. Status: Closed - Acceptable Alternative Action
Develop a formal training module for the ChemStewards Management System Tolling Guidance Module and provide appropriate training to SOCMA member companies. Include in the training program a discussion on the tolling issues identified in the MFG report.
2004-9-I-GA-10
Establish a Local Emergency Planning Committee to assist the Whitfield County Emergency Management Agency to: - Develop site-specific agency emergency response plans and standard operating procedures, - Develop training programs and conduct drills for emergencies at fixed facilities, - Educate the community regarding proper protective actions, such as shelter-in-place and evacuation procedures. Status: Closed - Acceptable Action
Establish a Local Emergency Planning Committee to assist the Whitfield County Emergency Management Agency to: - Develop site-specific agency emergency response plans and standard operating procedures, - Develop training programs and conduct drills for emergencies at fixed facilities, - Educate the community regarding proper protective actions, such as shelter-in-place and evacuation procedures.
2004-9-I-GA-11
Work with the City of Dalton, representatives from local facilities, and relevant community representatives to review and revise the Emergency Operations Plan to: -Update the list of facilities handling hazardous chemicals, including those covered by the EPA Risk Management Program regulation, -Develop standard operating procedures addressing communication of emergency information, evacuation, and shelter-in-place, -Conduct community training and drills that involve operation of the emergency notification system and potential actions in the event of an emergency, -Implement an automated community emergency notification system. Status: Closed - Acceptable Action
Work with the City of Dalton, representatives from local facilities, and relevant community representatives to review and revise the Emergency Operations Plan to: -Update the list of facilities handling hazardous chemicals, including those covered by the EPA Risk Management Program regulation, -Develop standard operating procedures addressing communication of emergency information, evacuation, and shelter-in-place, -Conduct community training and drills that involve operation of the emergency notification system and potential actions in the event of an emergency, -Implement an automated community emergency notification system.
2017-01-I-KS-5
Coordinate planning and training activities to ensure emergency responders within Atchison County are prepared for future incidents involving hazardous materials. The Atchison County Local Emergency Planning Committee should do the following: a) Review facility Risk Management Plans as they are submitted or revised and conduct pre-planning at Risk Management Program covered facilities and all other facilities within the county that, based on annual Tier II reporting forms, store large amounts of hazardous chemicals. b) Conduct a full-scale hazardous materials exercise that involves an offsite chemical release scenario within the next three years. The exercise should include participants from local emergency response organizations, hospitals, schools, and fixed facilities. Identify and resolve coordination or communication issues identified during the exercise. c) Increase participation in state and regional emergency response training and programs. Work with the Kansas Department of Emergency Management to submit a Hazardous Materials Emergency Preparedness (HMEP) grant proposal to assist in funding additional training and pre-planning activities within the county. Status: Open - Acceptable Response or Alternate Response
Coordinate planning and training activities to ensure emergency responders within Atchison County are prepared for future incidents involving hazardous materials. The Atchison County Local Emergency Planning Committee should do the following:
a) Review facility Risk Management Plans as they are submitted or revised and conduct pre-planning at Risk Management Program covered facilities and all other facilities within the county that, based on annual Tier II reporting forms, store large amounts of hazardous chemicals.
b) Conduct a full-scale hazardous materials exercise that involves an offsite chemical release scenario within the next three years. The exercise should include participants from local emergency response organizations, hospitals, schools, and fixed facilities. Identify and resolve coordination or communication issues identified during the exercise.
c) Increase participation in state and regional emergency response training and programs. Work with the Kansas Department of Emergency Management to submit a Hazardous Materials Emergency Preparedness (HMEP) grant proposal to assist in funding additional training and pre-planning activities within the county.
2017-01-I-KS-3
Establish a refresher training program to ensure drivers know the location of various CTMV emergency shut-off devices, when to use them, and the effectiveness of those devices to stop the flow of chemicals during emergencies. The refresher training program should include drills for drivers to simulate the activation of all shut-off devices in defined incident scenarios (e.g., inadvertent mixing, chemical releases, etc.) during unloading operations. Establish a process to evaluate the effectiveness of the refresher training program. Status: Closed - Acceptable Action
Establish a refresher training program to ensure drivers know the location of various CTMV emergency shut-off devices, when to use them, and the effectiveness of those devices to stop the flow of chemicals during emergencies. The refresher training program should include drills for drivers to simulate the activation of all shut-off devices in defined incident scenarios (e.g., inadvertent mixing, chemical releases, etc.) during unloading operations. Establish a process to evaluate the effectiveness of the refresher training program.
2017-01-I-KS-4
Establish a process whereby the respiratory hazards associated with chemical unloading at customer sites are evaluated. The evaluations should, at a minimum, determine whether drivers need emergency escape respirators in the event of an accidental reaction and/or release of chemicals. If the results of the evaluations indicate that respiratory protection is needed, provide the equipment and training for such protection as appropriate. The equipment and training should be provided in accordance with OSHA’s Respiratory Protection Standard (29 C.F.R § 1910.134). The equipment should also be stored in an area that allows for immediate access. Status: Closed - Exceeds Recommended Action
Establish a process whereby the respiratory hazards associated with chemical unloading at customer sites are evaluated. The evaluations should, at a minimum, determine whether drivers need emergency escape respirators in the event of an accidental reaction and/or release of chemicals. If the results of the evaluations indicate that respiratory protection is needed, provide the equipment and training for such protection as appropriate. The equipment and training should be provided in accordance with OSHA’s Respiratory Protection Standard (29 C.F.R § 1910.134). The equipment should also be stored in an area that allows for immediate access.
2017-01-I-KS-1
Commission an independent engineering evaluation of the Mod B building and ventilation system and, based on the results of that evaluation, implement design changes and controls to protect occupants from a chemical release. At a minimum, the evaluation should assess the effectiveness of the building ventilation system, indoor and outdoor sources of chemicals, air intake locations, contaminant control methods such as filtration and removal, contaminant monitoring devices, and automation. The engineering evaluation of the ventilation system should consider airborne contaminants during normal operations as well as spills, releases, and chemicals produced from unintended reactions and inadvertent mixing. Status: Closed - Acceptable Action
Commission an independent engineering evaluation of the Mod B building and ventilation system and, based on the results of that evaluation, implement design changes and controls to protect occupants from a chemical release. At a minimum, the evaluation should assess the effectiveness of the building ventilation system, indoor and outdoor sources of chemicals, air intake locations, contaminant control methods such as filtration and removal, contaminant monitoring devices, and automation. The engineering evaluation of the ventilation system should consider airborne contaminants during normal operations as well as spills, releases, and chemicals produced from unintended reactions and inadvertent mixing.
2017-01-I-KS-2
Conduct an evaluation of the Mod B chemical transfer equipment (e.g., fill lines, transfer valves, transfer piping, tanks and other associated equipment) and install appropriate engineering safeguards to prevent and mitigate an unintended reaction, chemical release, or spill during bulk unloading. Where feasible, install safeguards, such as alarms and interlocks, to prevent personnel from opening the incorrect chemical transfer valves during deliveries. In addition, install mitigation measures to automatically shut down the transfer of chemicals into the facility based on process deviations or abnormal conditions (e.g., pressure, temperature, flow or level indications; gas detection). Status: Closed - Exceeds Recommended Action
Conduct an evaluation of the Mod B chemical transfer equipment (e.g., fill lines, transfer valves, transfer piping, tanks and other associated equipment) and install appropriate engineering safeguards to prevent and mitigate an unintended reaction, chemical release, or spill during bulk unloading. Where feasible, install safeguards, such as alarms and interlocks, to prevent personnel from opening the incorrect chemical transfer valves during deliveries. In addition, install mitigation measures to automatically shut down the transfer of chemicals into the facility based on process deviations or abnormal conditions (e.g., pressure, temperature, flow or level indications; gas detection).
1998-06-I-NJ-10
Communicate the findings of this report to your membership. Status: Closed - Acceptable Action
Communicate the findings of this report to your membership.
1998-06-I-NJ-9
Participate in a hazard investigation of reactive chemical process safety conducted by the CSB. The objectives of the special investigation will include: Determine the frequency and severity of reactive chemical incidents. Examine how industry, OSHA, and EPA are currently addressing reactive chemical hazards. Determine the differences, if any, between large/medium/small companies with regard to reactive chemical policies, practices, in-house reactivity research, testing, and process engineering. Analyze the effectiveness of industry and OSHA use of the National Fire Protection Association Reactivity Rating system for process safety management purposes. Develop recommendations for reducing the number and severity of reactive chemical incidents. Status: Closed - Acceptable Action
Participate in a hazard investigation of reactive chemical process safety conducted by the CSB. The objectives of the special investigation will include: Determine the frequency and severity of reactive chemical incidents. Examine how industry, OSHA, and EPA are currently addressing reactive chemical hazards. Determine the differences, if any, between large/medium/small companies with regard to reactive chemical policies, practices, in-house reactivity research, testing, and process engineering. Analyze the effectiveness of industry and OSHA use of the National Fire Protection Association Reactivity Rating system for process safety management purposes. Develop recommendations for reducing the number and severity of reactive chemical incidents.
1998-06-I-NJ-8
Issue joint guidelines on good practices for handling reactive chemical process hazards. Ensure that these guidelines, at a minimum, address the following issues: The evaluation of reactive hazards and the consequences of reasonably foreseeable and worst-case deviations from normal operations. The importance of reporting and investigating deviations from normal operations. The determination of proper design for pressure relief capability, emergency cooling process controls, alarms, and safety interlocks, as well as other good-practice design features for handling reactive substances. The appropriate use of chemical screening techniques such as differential scanning calorimetry. Status: Closed - Acceptable Action
Issue joint guidelines on good practices for handling reactive chemical process hazards. Ensure that these guidelines, at a minimum, address the following issues: The evaluation of reactive hazards and the consequences of reasonably foreseeable and worst-case deviations from normal operations. The importance of reporting and investigating deviations from normal operations. The determination of proper design for pressure relief capability, emergency cooling process controls, alarms, and safety interlocks, as well as other good-practice design features for handling reactive substances. The appropriate use of chemical screening techniques such as differential scanning calorimetry.
1998-06-I-NJ-2
Revalidate Process Hazard Analyses for all reactive chemical processes in light of the findings of the U.S. Chemical Safety and Hazard Investigation Board (CSB) report and upgrade, as needed, equipment, operating procedures, and training. Status: Closed - Acceptable Action
Revalidate Process Hazard Analyses for all reactive chemical processes in light of the findings of the U.S. Chemical Safety and Hazard Investigation Board (CSB) report and upgrade, as needed, equipment, operating procedures, and training.
1998-06-I-NJ-3
Evaluate pressure relief requirements for all reaction vessels using appropriate technology, such as the Design Institute for Emergency Relief Systems (DIERS)50 method and test apparatus and upgrade equipment as needed. Status: Closed - No Longer Applicable
Evaluate pressure relief requirements for all reaction vessels using appropriate technology, such as the Design Institute for Emergency Relief Systems (DIERS)50 method and test apparatus and upgrade equipment as needed.
1998-06-I-NJ-4
Evaluate the need for and install, as necessary, devices, such as alarms, added safety instrumentation, and quench or reactor dump systems to safely manage reactive chemical process hazards. Status: Closed - Acceptable Action
Evaluate the need for and install, as necessary, devices, such as alarms, added safety instrumentation, and quench or reactor dump systems to safely manage reactive chemical process hazards.
1998-06-I-NJ-5
Revise operating procedures and training for reactive chemical processes as needed, to include descriptions of the possible consequences of deviations from normal operational limits and steps that should be taken to correct these deviations, including emergency response actions. Status: Closed - Acceptable Action
Revise operating procedures and training for reactive chemical processes as needed, to include descriptions of the possible consequences of deviations from normal operational limits and steps that should be taken to correct these deviations, including emergency response actions.
1998-06-I-NJ-6
Implement a program to ensure that deviations from normal operational limits for reactive chemical processes that could have resulted in significant incidents are documented and investigated and necessary safety improvements are implemented. Status: Closed - Acceptable Action
Implement a program to ensure that deviations from normal operational limits for reactive chemical processes that could have resulted in significant incidents are documented and investigated and necessary safety improvements are implemented.
1998-06-I-NJ-7
Revise the Yellow 96 Material Safety Data Sheet (MSDS) to show the proper boiling point and National Fire Protection Association reactivity rating. Evaluate the need for and change, as necessary, the MSDSs for other Morton dyes. Communicate the MSDS changes to current and past customers (who may retain inventories of these products). Status: Closed - Acceptable Action
Revise the Yellow 96 Material Safety Data Sheet (MSDS) to show the proper boiling point and National Fire Protection Association reactivity rating. Evaluate the need for and change, as necessary, the MSDSs for other Morton dyes. Communicate the MSDS changes to current and past customers (who may retain inventories of these products).
1998-06-I-NJ-1
Establish a program that ensures that reactive chemical process safety information and operating experience are collected and shared with all relevant units of the company. Status: Closed - Acceptable Action
Establish a program that ensures that reactive chemical process safety information and operating experience are collected and shared with all relevant units of the company.
Issue joint guidelines on good practices for handling reactive chemical process hazards. Ensure that these guidelines, at a minimum, address the following issues: The evaluation of reactive hazards and the consequences of reasonably foreseeable and worst-case deviations from normal operations. The importance of reporting and investigating deviations from normal operations. The determination of proper design for pressure relief capability, emergency cooling, process controls, alarms, and safety interlocks, as well as other good-practice design features for handling reactive substances. The appropriate use of chemical screening techniques such as differential scanning calorimetry. Status: Closed - Acceptable Action
Issue joint guidelines on good practices for handling reactive chemical process hazards. Ensure that these guidelines, at a minimum, address the following issues: The evaluation of reactive hazards and the consequences of reasonably foreseeable and worst-case deviations from normal operations. The importance of reporting and investigating deviations from normal operations. The determination of proper design for pressure relief capability, emergency cooling, process controls, alarms, and safety interlocks, as well as other good-practice design features for handling reactive substances. The appropriate use of chemical screening techniques such as differential scanning calorimetry.
2001-05-I-DE-10
Work with NACE International (National Association of Corrosion Engineers) to develop API guidelines to inspect storage tanks containing fresh or spent H2SO4 at frequencies at least as often as those recommended in the latest edition of NACE Standard RP 0294-94, Design, Fabrication, and Inspection of Tanks for the Storage of Concentrated Sulfuric Acid and Oleum at Ambient Temperatures. Status: Closed - Acceptable Action
Work with NACE International (National Association of Corrosion Engineers) to develop API guidelines to inspect storage tanks containing fresh or spent H2SO4 at frequencies at least as often as those recommended in the latest edition of NACE Standard RP 0294-94, Design, Fabrication, and Inspection of Tanks for the Storage of Concentrated Sulfuric Acid and Oleum at Ambient Temperatures.
2001-05-I-DE-11
Revise API tank inspection standards to emphasize that storage tanks with wall or roof holes or thinning beyond minimum acceptable thickness that may contain a flammable vapor are an imminent hazard and require immediate repair or removal from service. Status: Closed - Acceptable Action
Revise API tank inspection standards to emphasize that storage tanks with wall or roof holes or thinning beyond minimum acceptable thickness that may contain a flammable vapor are an imminent hazard and require immediate repair or removal from service.
2001-05-I-DE-12
Ensure that API recommended practices address the inerting of flammable storage tanks, such as spent H2SO4 tanks. Include the following: - Circumstances when inerting is recommended. - Design of inerting systems, such as proper sizing of inerting equipment, appropriate inerting medium, and instrumentation, including alarms. Status: Closed - Acceptable Action
Ensure that API recommended practices address the inerting of flammable storage tanks, such as spent H2SO4 tanks. Include the following: - Circumstances when inerting is recommended. - Design of inerting systems, such as proper sizing of inerting equipment, appropriate inerting medium, and instrumentation, including alarms.
2001-05-I-DE-13
Communicate the findings and recommendations of this report to your membership. Status: Closed - Acceptable Action
Communicate the findings and recommendations of this report to your membership.
2001-05-I-DE-19
2001-05-I-DE-2
Ensure that regulations developed for the recently enacted Jeffrey Davis Above ground Storage Tank Act require that facility management take prompt action in response to evidence of tank corrosion that presents hazards to people or the environment. Status: Closed - Acceptable Action
Ensure that regulations developed for the recently enacted Jeffrey Davis Above ground Storage Tank Act require that facility management take prompt action in response to evidence of tank corrosion that presents hazards to people or the environment.
2001-05-I-DE-8
In light of the findings of this report, conduct periodic audits of storage tank mechanical integrity and design, Unsafe Condition Reports, hot work, management of change, and accountability systems at Motiva oil refineries. Ensure that the audit recommendations are tracked and implemented. Share the findings with the workforce. Status: Closed - Acceptable Action
In light of the findings of this report, conduct periodic audits of storage tank mechanical integrity and design, Unsafe Condition Reports, hot work, management of change, and accountability systems at Motiva oil refineries. Ensure that the audit recommendations are tracked and implemented. Share the findings with the workforce.
2001-05-I-DE-9
Communicate the findings and recommendations of this report to the workforce and contractors at all Motiva refineries. Status: Closed - Acceptable Action
Communicate the findings and recommendations of this report to the workforce and contractors at all Motiva refineries.
2001-05-I-DE-3
Implement a system to ensure accountability for mechanical integrity decision making. Include the following specific items: - Review of inspection reports by subject area experts, such as metallurgists or equipment design engineers, to ensure adequate analysis of failure trends and suitability for intended service. - Establishment of a planning system to ensure the timely repair of equipment. The Center for Chemical Process Safety (CCPS) publication, Plant Guidelines for Technical Management of Chemical Process Safety, Chapter 3, ?Accountability Objectives and Goals,? presents a model for such a system. Status: Closed - Acceptable Action
Implement a system to ensure accountability for mechanical integrity decision making. Include the following specific items: - Review of inspection reports by subject area experts, such as metallurgists or equipment design engineers, to ensure adequate analysis of failure trends and suitability for intended service. - Establishment of a planning system to ensure the timely repair of equipment. The Center for Chemical Process Safety (CCPS) publication, Plant Guidelines for Technical Management of Chemical Process Safety, Chapter 3, ?Accountability Objectives and Goals,? presents a model for such a system.
2001-05-I-DE-4
Review the design of existing tankage that contains or has the potential to contain flammables to ensure that, at a minimum:: - Inerting systems are installed where appropriate and are adequately sized and constructed. - Emergency venting is provided. Status: Closed - Acceptable Action
Review the design of existing tankage that contains or has the potential to contain flammables to ensure that, at a minimum:: - Inerting systems are installed where appropriate and are adequately sized and constructed. - Emergency venting is provided.
2001-05-I-DE-5
Ensure that management of change reviews are conducted for changes to tank equipment and operating conditions, such as: - Tank service and contents - Tank peripherals, such as inerting and venting systems. Status: Closed - Acceptable Action
Ensure that management of change reviews are conducted for changes to tank equipment and operating conditions, such as: - Tank service and contents - Tank peripherals, such as inerting and venting systems.
2001-05-I-DE-6
Revise the refinery hot work program to address the circumstances that require use of continuous or periodic monitoring for flammables. Status: Closed - Acceptable Action
Revise the refinery hot work program to address the circumstances that require use of continuous or periodic monitoring for flammables.
2001-05-I-DE-7
Upgrade the refinery Unsafe Condition Report system to include the following: - Designation of a specific manager with decision-making authority to resolve issues. - Establishment of a mechanism to elevate attention to higher levels of management if issues are not resolved in a timely manner. - Identification of a means to ensure communication of hazards to all potentially affected personnel. - Work with the Paper, Allied-Industrial, Chemical & Energy Workers International Union (PACE) Local 2-898 to design and implement the improved system. Status: Closed - Acceptable Action
Upgrade the refinery Unsafe Condition Report system to include the following: - Designation of a specific manager with decision-making authority to resolve issues. - Establishment of a mechanism to elevate attention to higher levels of management if issues are not resolved in a timely manner. - Identification of a means to ensure communication of hazards to all potentially affected personnel. - Work with the Paper, Allied-Industrial, Chemical & Energy Workers International Union (PACE) Local 2-898 to design and implement the improved system.
2001-05-I-DE-14
Work with the American Petroleum Institute to develop API guidelines to ensure that storage tanks containing fresh or spent H2SO4 are inspected at frequencies at least as often as those recommended in the latest edition of NACE Standard RP 0294- 94, Design, Fabrication, and Inspection of Tanks for the Storage of Concentrated Sulfuric Acid and Oleum at Ambient Temperatures. Status: Closed - Acceptable Action
Work with the American Petroleum Institute to develop API guidelines to ensure that storage tanks containing fresh or spent H2SO4 are inspected at frequencies at least as often as those recommended in the latest edition of NACE Standard RP 0294- 94, Design, Fabrication, and Inspection of Tanks for the Storage of Concentrated Sulfuric Acid and Oleum at Ambient Temperatures.
2001-05-I-DE-15
2001-05-I-DE-18
2001-05-I-DE-1
(Superseded by 2019-01-I-TX-R7 from the Intercontinental Terminals Company (ITC) report) Ensure coverage under the Process Safety Management Standard (29 CFR 1910.119) of atmospheric storage tanks that could be involved in a potential catastrophic release as a result of being interconnected to a covered process with 10,000 pounds of a flammable substance. Status: Closed - Reconsidered/Superseded
(Superseded by 2019-01-I-TX-R7 from the Intercontinental Terminals Company (ITC) report)
Ensure coverage under the Process Safety Management Standard (29 CFR 1910.119) of atmospheric storage tanks that could be involved in a potential catastrophic release as a result of being interconnected to a covered process with 10,000 pounds of a flammable substance.
2001-05-I-DE-16
Work with Motiva management on the design and implementation of an improved Unsafe Condition Report program. Status: Closed - Acceptable Action
Work with Motiva management on the design and implementation of an improved Unsafe Condition Report program.
2001-05-I-DE-17
2010-04-I-IL-1
Revise the ASME Boiler and Pressure Vessel Code to include specific material thickness limitations for the design of pressure-containing components to ensure proper heat treatment and avoid environmentally induced damage mechanisms. Clarify required vessel wall thickness limitations for SA-723 steel in the following code sections: a) ASME BPVC Section II, Part A, Material Requirements b) ASME BPVC Section VIII, Division III, Article KM-400, Material Design Data Status: Closed - Acceptable Alternative Action
Revise the ASME Boiler and Pressure Vessel Code to include specific material thickness limitations for the design of pressure-containing components to ensure proper heat treatment and avoid environmentally induced damage mechanisms. Clarify required vessel wall thickness limitations for SA-723 steel in the following code sections: a) ASME BPVC Section II, Part A, Material Requirements b) ASME BPVC Section VIII, Division III, Article KM-400, Material Design Data
2010-4-I-IL-3
Prohibit the use of the existing pressure vessels at the NDK facility for crystal growing operations. Status: Closed - Acceptable Action
Prohibit the use of the existing pressure vessels at the NDK facility for crystal growing operations.
2010-4-I-IL-4
Develop and implement state requirements and procedures to ensure the pressure vessel approval process accurately identifies vessels that may be subject to corrosion or similar deterioration mechanisms, and ensure regular inspections in accordance with these state requirements. Status: Closed - Acceptable Action
Develop and implement state requirements and procedures to ensure the pressure vessel approval process accurately identifies vessels that may be subject to corrosion or similar deterioration mechanisms, and ensure regular inspections in accordance with these state requirements.
2010-4-I-IL-2
Communicate the findings of this Case Study to pressure vessel inspectors in all 50 states. At a minimum: a. Send the information (such as an article summarizing the investigation) to each member who is a pressure vessel inspector; and, b. Post a direct link to the NDK Case Study on the National Board’s webpage. Status: Closed - Acceptable Action
Communicate the findings of this Case Study to pressure vessel inspectors in all 50 states. At a minimum:
a. Send the information (such as an article summarizing the investigation) to each member who is a pressure vessel inspector; and,
b. Post a direct link to the NDK Case Study on the National Board’s webpage.
2010-4-I-IL-5
For the design and operation of any new NDK Crystal facility using a hydrothermal or equivalent crystal growing process, ensure that the facility uses a process that is rigorously demonstrated to be inherently safer than the existing process (for example through using lower temperatures and pressures, and/or less corrosive conditions). Status: Closed - No Longer Applicable
For the design and operation of any new NDK Crystal facility using a hydrothermal or equivalent crystal growing process, ensure that the facility uses a process that is rigorously demonstrated to be inherently safer than the existing process (for example through using lower temperatures and pressures, and/or less corrosive conditions).
2010-4-I-IL-6
Implement a program to ensure the ongoing integrity of any coating used on the new process vessels. Employ an expert (e.g., a coatings expert certified by NACE International (National Association of Corrosion Engineers)) to design the program. Status: Closed - No Longer Applicable
Implement a program to ensure the ongoing integrity of any coating used on the new process vessels. Employ an expert (e.g., a coatings expert certified by NACE International (National Association of Corrosion Engineers)) to design the program.
2010-4-I-IL-7
Implement an annual inspection and corrective action program to ensure vessels remain resistant to environmentally induced damage mechanisms based on the inspection guidelines set forth in the American Petroleum Institute (API) Standard 510, Pressure Vessel Inspection Code. Status: Closed - No Longer Applicable
Implement an annual inspection and corrective action program to ensure vessels remain resistant to environmentally induced damage mechanisms based on the inspection guidelines set forth in the American Petroleum Institute (API) Standard 510, Pressure Vessel Inspection Code.
2010-4-I-IL-8
Commission a facility siting study of the NDK Crystal facility by an independent consultant. Identify all vessel failure scenarios prior to restarting the crystal growing process. The siting study should include the consequences, necessary preventive measures, and emergency planning and response programs relevant to each failure scenario for all surrounding points of concern. Provide a copy of this study to the City of Belvidere Building and Zoning Department and the Illinois Boiler and Pressure Vessel Safety Division. Status: Closed - No Longer Applicable
Commission a facility siting study of the NDK Crystal facility by an independent consultant. Identify all vessel failure scenarios prior to restarting the crystal growing process. The siting study should include the consequences, necessary preventive measures, and emergency planning and response programs relevant to each failure scenario for all surrounding points of concern. Provide a copy of this study to the City of Belvidere Building and Zoning Department and the Illinois Boiler and Pressure Vessel Safety Division.