The Baker Panel Report - ABSA

PCMS to 8 years, the refinery failed to follow its written inspection and testingprocedure.In practice, the refinery does not rely on the schedules established in PCMS. CherryPoint instead determines relief valve inspection intervals based on turnaround schedules.Refinery personnel use their individual judgment to evaluate the need for inspectingindividual relief valves prior to a turnaround and then develop a turnaround inspectionwork list. Although the individuals making these judgments are very knowledgeable, thePSM Review Team has significant concerns regarding this practice, which has inherentlimitations. The team identified several examples where relief valve inspection datarepeatedly indicated a failed relief valve, but the inspection schedule was not changed torequire inspections on a more frequent basis.The PSM Review Team believes that this practice makes it more likely that the refinerywill fail to inspect a relief valve and not know it. A relief valve could be missed orconsciously omitted by the people making the turnaround schedule, and the valve wouldstill not show that it is past due for inspection because it would still satisfy the default 8year frequency in PCMS.The PSM Review team does not believe that establishing testing frequencies based onturnaround schedules conforms to BP policies or good engineering practices.Texas City384 pressure vessels, storage tanks, piping, relief valves, rotating equipment, andinstruments were overdue for inspection in six operating units evaluatedNumerous heat exchanger tube thickness measurements were not takenToledoBased upon a review of the past 2 years of records, nearly all of the rotatingequipment had at least one instance of overdue quarterly vibration analysisInstrument test intervals are based on turnaround schedules and not on anestablished frequency or on observed equipment conditionWhiting20% of over 250,000 thickness measurement locations were past due forinspection, although many locations were subsequently determined by BP to notbe needed or were not critical20 relief valves were past due for inspectionAbout 50% of small rotating machinery (pumps) were overdue for vibrationanalysisNo established management practice existed to authorize variances in inspectionschedules22