The Baker Panel Report - ABSA

Although the Panel recognizes that the December 2006 data may be more accurate, it remains evident that at various times, the refinery’smaintenance database showed large numbers of overdue thickness measurement location inspections. BP’s after-the-fact determination thatthe numbers were better than initially believed is relevant but raises questions about whether BP has effective measurement criteria andsystems for monitoring process safety performance.The Cherry Point refinery data also warrant specific discussion. BP’s data for Cherry Point show almost no overdue inspections. Based on theCherry Point technical review, however, the Panel believes that the data provided do not accurately reflect conditions at Cherry Point.Specifically, the Panel’s technical consultants identified several deficiencies regarding the inspection and testing program at the Cherry Pointrefinery, especially as the program relates to testing intervals and inspection tracking. The report from the Panel’s technical consultantsattached as Appendix E discusses these matters in more detail. Although the Panel has included the Cherry Point data in the above-table, thePanel questions their validity and comparability to the data for the other refineries.The number of overdue inspections that BP tracked was not the only indication of problems with respect to this leading indicator. As shown inthe following table, every year from 2000 through 2005, a BP audit team identified findings relating to the timeliness of mechanical integrityinspection and testing at one or more BP refineries in the United States: 2000 (Whiting); 2001 (Texas City and Toledo); 2002 (Carson and CherryPoint); 2003 (Whiting); 2004 (Texas City and Toledo); and 2005 (Carson): 37Table 58U.S. Refinery Process Safety Review Findings onMechanical Integrity Inspection and Testing (2000—2005)Year Refinery Process Safety Audit Finding2000 Whiting: Priority 1 38 finding for mechanical integrity testing. More than ten percent of relief valves were out ofcompliance past due dates.2001 Texas City: Priority 1 findings on mechanical integrity testing: “a large number of the required inspectionintervals for relief and vent systems are not in compliance.” Similar Priority 1 findings were made with respectto inspection intervals for “a large number” of emergency shut-down systems; critical alarms; trip systems;pump and compressor systems; pressure vessels; storage tanks; and piping systems.Toledo: Numerous pressure safety valves (44) were overdue for testing.2002 Carson: 62 pressure vessels and 650 pressure relief valves were past inspection due dates.Cherry Point: Several mechanical integrity Priority 1 findings because numerous pressure safety valves (89),tanks (37), and vessels (81) were past due for inspection.2003 Whiting: Priority 1 findings for mechanical integrity, finding that 534 critical alarms components and 100 reliefvalves were overdue for testing. An unspecified quantity of stationary equipment, including pressure vessels,tanks, furnaces, and piping, also were out of compliance for testing. 392004 Texas City: Priority 1 findings on mechanical integrity and inspection due dates. Unspecified quantities of thefollowing types of equipment were overdue for mechanical integrity inspection and testing: on-stream andturnaround critical instruments; rotating equipment; piping, pressure vessels, and storage tanks; and relief valves.Toledo: Numerous pressure safety valves (54) and personnel protection monitors (77) were overdue for inspectionand testing. Priority 1 findings on mechanical integrity testing deficiencies.2005 Carson: Priority 1 findings because numerous pressure relief valves (134) and pressure vessels (166) were pastdue for inspection.Performance Evaluation, Corrective Action, and Corporate Oversight C 191