Recent Recommendation Status Updates

Open: 100% | Closed: 0%

Final Report Released On: December 06, 2023

2017-07-I-WI-1

Contract a competent third party to develop a comprehensive combustible dust process safety management system, such as OSHA’s Process Safety Management standard or the requirements in the 2019 edition of NFPA 652, Standard on the Fundamentals of Combustible Dust, Chapter 8, which includes, at a minimum, the following elements:

a. Management of Change for combustible dust;

b. Process Safety Information Management;

c. Management of Audits and Inspections;

d. Fugitive Dust Management;

e. Incident Investigation;

f. Dust Hazard Analyses;

g. Management of Engineering Controls for combustible dust

h. Personal Protective Equipment; and

i. Emergency Preparedness.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

2017-07-I-WI-2

Contract a competent third party to develop and implement modifications to the pneumatic conveying and dust collector ductwork systems in accordance with guidance such as NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, NFPA 652, Standard on the Fundamentals of Combustible Dust, and NFPA 654, Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids, to include, at a minimum:

a. Ensure minimum required transport velocity is maintained throughout the system.

b. Implement a periodic inspection and testing program for pneumatic conveying and dust collector ductwork systems, following industry guidance such as NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Particulate Solids, and FM Global guidance. The program should include cleaning on a set frequency and measuring transport velocities on a routine basis to ensure proper system function.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

2017-07-I-WI-3

Contract a competent third party to perform dust hazard analyses (DHAs) on all buildings and units that process combustible dust. Ensure that the DHAs are revalidated at least every five years. Implement pre-deflagration detection, deflagration venting, deflagration suppression, deflagration isolation, and deflagration pressure containment engineering controls identified in the initial and revalidation DHA in accordance with NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, NFPA 68, Standard on Explosion Protection by Deflagration Venting, NFPA 69, Standard on Explosion Prevention Systems, and NFPA 652, Standard on the Fundamentals of Combustible Dust.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

2017-07-I-WI-4

Contract a competent third party to assess and implement engineering controls for the structural design and venting requirements of the reconstructed facility to ensure they meet the requirements and guidance in NFPA 68, Standard on Explosion Protection by Deflagration Venting, for adequacy of venting capacity.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

2017-07-I-WI-5

Incorporate recording any paper-based process safety information into Didion’s existing electronic records management system so that the information can be reliably retained, retrieved, and analyzed in the event of a catastrophic incident.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

2017-07-I-WI-6

Contract a competent third party to perform personal protective equipment hazard analyses, such as those prescribed by NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Short-Duration Thermal Exposures from Fire, and require appropriate flame-resistant garments for all operations that handle combustible dusts during normal and upset conditions.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

2017-07-I-WI-7

Contract a competent third party to update the facility emergency response plan and train all employees on updated emergency response plan. The update should include the guidance in NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, and NFPA 652, Standard on the Fundamentals of Combustible Dust, Chapter 8 and Section A.8.10.1, which includes, at a minimum, the following elements:

a. A signal or alarm system;

b. Emergency shutdown procedures; 

c. Provide instructions for when and how to trigger emergency evacuations;

d. Provide instructions for when to notify emergency responders for need of assistance;

e. Response to potential fire scenarios, such as smoldering fires inside equipment; and

f. Prevent firefighting of process fires inside equipment.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

2017-07-I-WI-8

Contract a competent third party to assess and update the pre-deflagration detection and suppression engineering controls, such as those discussed in Chapter 9 of the 2019 edition of NFPA 69, Standard on Explosion Prevention Systems, for adequacy to detect and alarm employees of an emergency situation, such as a smoldering fire, and trigger an evacuation.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

2017-07-I-WI-9

Contract a competent third party to develop and implement a process safety leadership and culture program, based on the guidance of the CCPS’s Guidelines for Auditing Process Safety Management Systems and Process Safety: Leadership from the Boardroom to the Frontline. The program should include, at a minimum, the following elements:

a. A process safety policy;

b. A process safety leadership and culture committee;

c. Appropriate goals for process safety;

d. A commitment to process safety culture;

e. Leading and lagging process safety metrics;

f. Process Safety Culture Assessments; and,

g. Engagement with external process safety leadership and culture experts.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: July 29, 2022

2017-04-I-MO-8

Update NB-263 Rules for Commissioned Inspectors to include prescriptive elements in the boiler and pressure vessel repair and alteration inspection and acceptance process that would prevent the acceptance of a non-conforming repair.

Status: Closed - Exceeds Recommended Action
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: April 24, 2023

2020-05-I-LA-1

Evaluate the hazards to the Bio-Lab Lake Charles facility from hurricanes and accompanying wind, rainwater, floodwater, or storm surge forces. Implement processes and safeguards for protection against those hazards, such as through:

a. Constructing new and maintaining existing buildings and structures to withstand hurricane winds and flooding, with a particular focus on those containing hazardous materials;

b. Implementing safeguards and processes to ensure hazardous chemicals are not compromised and released during extreme weather events; and

c. Following the guidance presented in the Center for Chemical Process Safety Monograph Assessment of and Planning for Natural Hazards.

Status: Closed - Acceptable Action
Recommendation Status Change Summary

2020-05-I-LA-2

Develop and implement an improved Process Hazard Analysis (PHA) action item management system. At a minimum the PHA action item management system should:

a. Ensure that each PHA action item or recommendation is assigned to an appropriate person with a deadline for initial evaluation;

b. Document and maintain the rationale if the action item or recommendation is modified or rejected; and

c. Track the status of all PHA action items or recommendations until they are resolved.

Additionally, periodic audits must be conducted on the PHA action item management system to ensure its effectiveness.

Status: Closed - Acceptable Action
Recommendation Status Change Summary

Open: 0% | Closed: 100%

Final Report Released On: May 21, 2021

2020-01-I-TX-4

For all waterflood stations where the potential exists to expose workers or non-employees to H2S concentrations at or above 10 ppm, develop and demonstrate the use of a safety management program that includes a focus on protecting workers and non-employees from H2S. This program should include risk identification, assessment, mitigation, and monitoring of design, procedures, maintenance and training related to H2S. This program must be in compliance with 29 CFR 1910.1000 – Air Contaminants and 29 CFR 1910.147 – The Control of Hazardous Energy (Lockout / Tagout).

Status: Closed - Acceptable Action
Recommendation Status Change Summary

2020-01-I-TX-5

For all waterflood stations where the potential exists to expose workers to H2S concentrations at or above 10 ppm, ensure the H2S detection and alarm systems are properly maintained and configured, and develop site-specific detection and alarm programs and associated procedures based on manufacturer specifications, current codes, standards, and industry good practice guidance. The program must address installation, calibration, inspection, maintenance, training and routine operations.

Status: Closed - Acceptable Action
Recommendation Status Change Summary

2020-01-I-TX-6

For all waterflood stations where the potential exists to expose workers or non-employees within the perimeter of the facility to H2S concentrations at or above 10 ppm, ensure that the H2S detection and alarm system designs employ multiple layers of alerts unique to H2S, such as with the use of both audible and visual mediums, so that workers and non-employees within the perimeter of the facility would be alerted to a significant release. The system design must meet manufacturer specifications, current codes, standards, and industry good practice guidance.

Status: Closed - Acceptable Action
Recommendation Status Change Summary

Open: 100% | Closed: 0%

Final Report Released On: March 13, 2025

2024-01-I-CA-3

Implement changes to improve Walk the Line performance at the Martinez facility by ensuring that the facility’s practices are consistent with tools in the AFPM Safety Portal and guidance in Marathon Petroleum Corporation’s refining reference document titled Operations Excellence. At a minimum:

1. Require that operator field walkdowns ensure that valves are correctly aligned before all unit startup activities from planned or unplanned shutdowns, such as those due to non-normal operations, emergencies, turnarounds, and major maintenance;

2. Improve policies and practices for communications among and between shifts to ensure that operators understand abnormal line-ups in their units; and

3. Reinforce Walk the Line concepts, including the expectation for only trained operators to control valve line-ups at their units, through training for all levels of management in the Operations department.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

2024-01-I-CA-4

Complete a comprehensive gap assessment of the Martinez facility against Marathon Petroleum Corporation policies. At a minimum, address the following policies:

a. Operating Limits;

b. Process Hazard Analysis; and

c. PSM/RMP Refining Operating Procedures.

Develop and implement action items to effectively address findings from the assessment.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

Open: 100% | Closed: 0%

Final Report Released On: March 13, 2025

2024-01-I-CA-5

Update the corporate “Process Heater Not-to-Exceed (NTE) Limits and Alarms” standard with tube metal temperature alarming guidance to alert operators when safe operating limits are exceeded and to specify predetermined response actions, such as shutting down the fired heater remotely. The predetermined response actions must include actions that specify when to stop troubleshooting and remove personnel from the vicinity of the fired heater.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

2024-01-I-CA-6

Update the corporate “Heater Application Standard” with the following requirements:

1. Requirements for protecting fired heaters from low process flow where process piping diverges downstream of a flow meter. Requirements may include achieving proof of flow to the heater through valve position indicators and interlocks on branch connections downstream of flow meters to prevent backflow, reverse flow, or other diverted flow scenarios that could defeat the safety instrumented system; and

2. Engineering safeguard requirements to detect and prevent afterburning in fired heaters. The safeguards may include the use of instrumentation such as combustibles measurements, flame detectors, and/or thermocouples that measure tube metal, flue gas, and process fluid temperatures. The safeguards shall be capable of being monitored from the control room.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary

2024-01-I-CA-7

Confirm the results of the Martinez facility’s comprehensive gap assessment required in 2024-01-I-CA-R4. Upon completion, conduct an Operations Excellence full assessment on the Martinez facility. Develop and implement action items to effectively address findings from the assessment.

Status: Open - Acceptable Response or Alternate Response
Recommendation Status Change Summary