The Baker Panel Report - ABSA

3.2 Equipment Deficiencies – Known Problems Not Corrected in a TimelyMannerRefining process equipment and instrument systems have safe operating envelopes andfunctional requirements. When process equipment, relief protection, and instrumentsystems are operating, it is sometimes difficult to know whether the item of equipment orthe system is in a degraded condition. For this reason, refineries perform inspections andtests on refining process equipment, control systems, and safety systems to (1) determinetheir current condition, (2) confirm their continued fitness-for-service, and (3) identifyany degraded conditions or incipient failures that warrant correction.Refineries typically have thousands of equipment items and instruments that undergoregularly scheduled inspections and tests over periods of up to several years. For largevessels or extensive hardware systems (e.g., long piping networks), hundreds ofindividual inspections may be performed. As a result, a refinery may have hundreds ofthousands of individual inspections to be performed during multi-year inspection cycles.When equipment and instrumentation fail or are inspected/tested and determined to beoutside of their operating/functional limits, repairs or corrections are required to restorethe items. Equipment that operates outside of its design envelope for extended periodsincreases process risk.The relevant requirements and guidance for identifying and correcting equipmentdeficiencies provide that a site should have an effective system to promptly evaluate andappropriately correct deficiencies. Alternatively, the site should impose less-demandingoperating conditions on the equipment to ensure the safe operation of the process until thesite can correct the deficiency.The PSM Review Team evaluated the systems for dealing with equipment deficiencies atBP’s five U.S. refineries. All the refineries had procedures for identifying and resolvingequipment deficiencies, and some refineries had risk-based decision-making approachesfor assessing responses to identified deficiencies. All five refineries had managementinformation scorecards for monitoring system performance, and some refineries haddeficiency backlog reduction goals as a part of their management/employee performancecontracts.Even though there had been some progress at all refineries in improving the timeliness ofcorrecting equipment deficiencies and reducing backlogs, the PSM Review Team foundthat a significant percentage of the equipment items sampled at the Carson, Texas City,and Whiting refineries had deficiencies and backlogs on corrective actions.Carson11 instances where vessel or piping thickness measurements indicated thatpotentially serious conditions had existed for as long as 3 yearsSeven vessel wall integrity issues that were 3 to 10 years old and four that wereolder than 10 years19