The Baker Panel Report - ABSA

System Finding 3 – Equipment inspections. At all five refineries, BP did not establishappropriate inspection and testing frequencies or meet its internally establishedfrequencies, resulting in extensive backlogs of overdue inspections for important refineryprocess equipment. Some of these backlogs included hundreds of items overdue for longperiods (i.e., years).3.4 Facility Siting – Occupied Buildings in Hazard ZonesRefineries that process volatile hydrocarbons face the hazard of explosions and fires. Therefining and chemical manufacturing industries have experienced major accidents thatresulted in damage to occupied buildings near the explosion (e.g., process control rooms,operator shelters, maintenance shops) and injuries and fatalities to occupants. Theseaccidents led OSHA to require consideration of facility siting when assessing processhazards under the PSM standard.The API subsequently published a facility siting recommended practice (RP 752)providing a methodology for evaluating the hazards associated with process plantbuildings. 12 The Center for Chemical Process Safety (CCPS) has also publishedadditional guidance on how to conduct such a facility siting study using recognizedconsequence models, assumptions, and data. 13 Taken together, these publicationspropose (1) evaluating the risk to process plant building occupants from potential impactslike fires, explosions, or toxic releases and (2) taking steps to reduce identified risks (e.g.,imposing occupancy criteria, strengthening existing buildings, or constructing newbuildings that meet certain design criteria).As a performance-oriented regulation, the PSM standard does not (1) impose a specificmethodology for evaluating facility siting, (2) define a level of unacceptable risk, or (3)require a company to take specific steps to mitigate identified risks. OSHA, however,expects companies to follow reasonable and acceptable methodologies in evaluatingfacility siting. For this reason, many companies subject to the PSM standard rely on APIRP 752 or the CCPS facility siting guidelines.The PSM Review Team evaluated the facility siting practices at all five BP refineries –both for temporary portable buildings and for permanent buildings. The PSM ReviewTeam found that all five refineries met OSHA’s requirements for facility siting byconducting facility siting studies (and updating them) in accordance with API RP 752.In addition, the team noted that since the Texas City accident all five refineries hadreevaluated the location of portable trailers in accordance with a new BP EngineeringTechnical Practice. 14 BP has relocated all of the trailers from the zones representing thehighest hazard. BP plans to complete this process for the remaining zones by the end of2006. The PSM Review Team commends BP for moving expeditiously in response tofacility siting issues on temporary buildings identified after the Texas City accident. ThePSM Review Team understands that BP is developing a new Engineering TechnicalPractice on the construction of new permanent buildings.23