Saturday, December 6, 2008
Alternative SVA Problems
According to a notice posted this week on the SOCMA web site, some facilities that used the SOCMA SVA tool to produce a Alternative SVA for submission to DHS had some problems with DHS accepting the SVA. No real details have been provided. Thanks to Brandon Williams for pointing me at this notice.
CFATS allows Tier 4 facilities to submit an Alternative SVA in lieu of using the DHS SVA. The SOCMA SVA is one of a number of alternative SVA methodologies approved by the Center for Chemical Process Safety (CCPS). While DHS has never specifically stated that they would accept CCPS approved SVA methodologies in lieu of a CFATS SVA, it has been assumed by most observers that this is what DHS intended when they allowed for the submission of Alternative SVAs.
I am trying to track down what types of problems that facilities have experienced with these alternative SVA submissions. I am looking for general information about the types of issues that have been flagged by DHS. If anyone has more information please let me know (PJCoyle@aol.com). PLEASE, NO CVI information.
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