The Baker Panel Report - ABSA

Once a site specifies the frequencies for its inspection and testing program, the siteshould reliably execute the program at the designated frequencies to support the safeoperation of the refining processes. Not performing inspections and tests in a timelyfashion means the refinery is less able to monitor the fitness-for-service condition of itsprocesses. For example, equipment that begins to degrade more quickly than previouslypredicted or that experiences a hidden failure may go undiagnosed for an extendedperiod, thus increasing the risk of process operation. In addition, not following specifiedinspection and testing intervals may diminish the overall effectiveness of a site’s processsafety management systems by sending a signal to the workforce that it is not importantto follow established requirements.All five BP refineries had extensive inspection and testing programs implemented byqualified BP staff and augmented by qualified contractors, as necessary. In addition, allfive refineries had inspection scorecards maintained typically by the Inspection,Maintenance, or Reliability functional departments to highlight the status andperformance of the inspection and testing program. Nonetheless, the PSM Review Teamfound extensive inspection and testing backlogs for fixed equipment, rotating machinery,and instrumentation systems at all five refineries. Sometimes these backlogs reflectedinspections that were years past due. The following are examples of inspection andtesting deficiencies at the refineries:Carson29 relief valves were overdue for testing29 pressure vessels were overdue for inspection22 piping systems were overdue for inspectionQuarterly preventive maintenance and vibration analysis were overdue on severalmajor machinery itemsCherry PointSeveral vessels and numerous piping inspections were overdueDocumentation of external vessel and piping inspections was incompleteRelief valve testing frequencies were inadequate, as explained belowAt Cherry Point, data from the refinery supplied to the Independent Panel indicatednearly zero overdue inspections for vessels/piping and relief valves. For the reasonsdiscussed below, the PSM Review Team believes that information does not accuratelyreflect conditions at Cherry Point.Cherry Point uses a software system (called PCMS) to document relief valve testingintervals. The documented test intervals for many relief valves were initially 2 or 3years. The refinery subsequently changed, in a single step, most of the relief valve testintervals to 8 years, which is the maximum allowed by BP policy. Cherry Point’sinspection and testing procedure does not allow an extension of an inspection schedule tomore than double the previous test interval. By extending the scheduled intervals in21