The Baker Panel Report - ABSA

Turnaround deferral procedure (Carson). During a turnaround, a process unit is shut down in a planned fashion so that refinery workerscan perform necessary maintenance, inspection, refurbishment, and replacement of equipment within the unit. Some operating units haveannual turnarounds, although most units have multi-year cycle turnarounds. Sometimes a refinery desires to defer a turnaround because ofoperational needs. However, for safety reasons, the effects of a proposed delay of an otherwise planned turnaround must be assessed. TheCarson refinery has a formal procedure for deciding whether it is acceptable to defer a turnaround. This procedure involves the evaluation ofvarious factors, including known equipment conditions, operational needs, the availability of material and personnel, and the risk impact of thedelay itself. Having a formal procedure with specified issues that knowledgeable personnel must address helps ensure that the risk of aproposed turnaround deferral is fairly evaluated before the turnaround is deferred.The Panel commends the BP refineries for adopting these notable practices and encourages BP to consider these practices for possibleimplementation in refineries in which such practices or comparable practices have not yet been implemented.Process safety minimum expectations. As described in Section V, BP has developed a set of internal standards called process safetyminimum expectations (PSMEs). These PSMEs establish minimum design conditions and operational performance requirements for somespecific types of process units, such as hydrofluoric acid alkylation units and fluid catalytic cracking units; certain generic chemical hazards,such as hydrogen sulfide and nitrogen; and specific classes of process safety-related equipment and instrumentation, such as isolationsystems and critical alarms. The PSMEs, which are periodically reviewed and revised, contain BP-imposed requirements for process or hazardspecificitems, such as safety analysis issues beyond the normal types of studies performed as a part of the process safety management system; operating, safety, and emergency procedures; emergency preparedness and emergency response; special training; safe operating limits; minimum engineering design conditions, including those for safety systems and critical alarms; and equipment mechanical integrity program activities, including testing frequencies, materials of construction, maintenance practices,and spare parts.When BP completes a new PSME, the refineries perform an analysis to determine the gap between current practices and the minimumexpectations and then develop a plan to close the gap. The technical consultants checked some of the PSMEs to verify that a gap analysis hadbeen performed and that the identified gaps were closed or were being closed. The technical consultants noted that the PSME program was anexcellent process safety management practice that appeared to be followed and monitored rigorously.Process Safety Management Systems C 178