Installation of a 9000-gallon liquid hydrogen storage tank by a lessee at a building has not been evaluated for effect on the Safety Authorization Basis (SAB) of nearby facilities.
During review of an Emergency Management Hazard Assessment document, a reviewer questioned whether the SAB of nearby facilities had been reviewed for the effect of the installed 9000-gallon liquid hydrogen tank. Reviews by the facility management and facility safety personnel confirmed the evaluations have not been performed.
The direct cause was determined to be a management problem, with policy not adequately defined, disseminated, or enforced to integrate potential lessee hazards into the facility safety program documentation on the 9000-gallon hydrogen tank and delivery. The existing policy intended that potential unidentified safety question related to lessee activities be proactively pursued by facility managers through existing procedures. However, the facility managers did not recognize the need to integrate potential lessee hazards into the facility safety program for any potential impacts to surrounding facilities. It was concluded that additional procedural guidance for facility management regarding these reindustrialization issues was required.
The root cause was determined to be a procedure problem. The infrastructure facility management, safety documentation procedures in place at the time of this occurrence did not address reindustrialization interfaces or the potential impact of reindustrialization on facility safety authorization basis documentation. This contributed to a presumed lack of authority and responsibility by facility management where reindustrialization activities were involved. The root cause of the occurrence indicates a need to revise the implementing procedures to clearly describe interfaces with the reindustrialization program.
- Hydrogen Storage Equipment
Whenever a new program or organization is created, management should ensure that program interfaces and new responsibilities are clearly defined. Effective program integration is necessary to ensure that all responsibilities and requirements are implemented. Facility safety is the focus of review on hazard evaluation documentation that is provided to the facility by the reindustrialization program.
Following receipt of hydrogen tank accident analysis and other data, develop an approved corrective action plan, identify applicable facilities "surrounding" the building, and review and update the authorization basis documents for those facilities, as necessary.