The Baker Panel Report - ABSA

Toledo RefineryArea of Overdue Inspections 2000 2001 2002 2003 2004 2005As of7/31/06Vessels N/A N/A N/A 34 0 0 0Tanks NA N/A N/A 11 0 0 0Piping systemsNot trackedPiping TMLs* N/A N/A N/A 5591 944 1803 1149PSVs ‡ N/A N/A N/A N/A 51 0 0Total overdue inspections N/A N/A N/A 5644 996 1804 1149Whiting RefineryArea of Overdue Inspections 2000 2001 2002 2003 2004 2005As of6/30/06Vessels N/A 1 0 0 0 0 0Tanks N/A 47 3 0 0 0 0Piping systems N/A 184 507 442 881 250 70Piping TMLs* N/A N/A N/A 68164 60030 51870 4060PSVs ‡ N/A 154 109 68 64 55 24Total overdue inspections 36 N/A 386 619 510 945 305 94* Thickness measurement locations (TMLs)‡ Pressure safety valves (PSVs)In considering this data, the Panel notes that the refineries track piping inspections differently. A piping system at a refinery may includehundreds, even thousands, of individual inspection points. At each of these points, which are referred to as thickness measurement locations(TMLs), BP periodically monitors pipe wall thickness. In tracking overdue inspections, some of the refineries count individual TMLs on a pipingsystem while other refineries count entire piping systems. The Whiting refinery tracks both.The use of different approaches makes comparison across the refineries difficult. As shown above, for example, the Toledo refinery tracksindividual TMLs as opposed to piping systems. At the end of 2005, Toledo reported 1803 overdue inspections for piping TMLs. The Carsonrefinery, on the other hand, reported 362 overdue piping system inspections. Each of these 362 systems, however, contained many individualoverdue TMLs.The Panel does not suggest that one of these approaches is better than the other. The Panel considers the lack of internal consistency acrossthe sites as a potential concern, however, especially given BP’s 2003 decision to use overdue inspections as a process safety metric. The lack ofconsistency reduces the effectiveness of this process safety indicator.The Panel’s review also identified concerns about the piping data for the Whiting refinery. On three occasions, BP provided inconsistent pipinginspection data to the Panel for this refinery. BP ultimately provided corrected data in December 2006, indicating that the number of overduepiping inspections at Whiting was actually less than the number that BP provided to the Panel’s technical consultants during the Whitingtechnical review in March 2006, as well as another number provided to the Panel in August 2006. According to BP, the December 2006 dataresulted from an exercise that Whiting undertook to correct errors in the refinery’s maintenance database, which had miscounted the number ofoverdue inspections.Performance Evaluation, Corrective Action, and Corporate Oversight C 190