~Report ~PDVSA - Setty's notebook · This report follCM's ',(sits to the PDVSA Centro de Refinacl6n...

/'Risk E' .RJf:7 ng,neer'ng

~PDVSA

~QBE

Risk Improvement Recommendations Update~Report

r./

Centro de,B.efinaci61lE-<!r.aguana

Estado Falc6n

Venezuela

Recommendations Update Visit Made: March s th..gl h 2012Prepared on behalf of

~QBE

Marine and Energy Syndicate 1036Plantation Place

30 Fenchurch StreetLondon

EC3M 3BD

Prepared on be half Of:eby Roger Gregory4 Heath Vil lasPlumsteadLondon SE18 1PG

Ref.20121139,-Risk , . .

RJf7 rl!llneer'"9Phone +44 (0) rr 03 731 1 16k..mail roger kb§aol.com_

Contents1. Basic Inform ation 32. Values llt\d Estimated Maximum Loss 43. Summary 54. Company Administrative Strudure Changes 75. Operational status and Significant Events 76. Maintenance status and Signitcant Events 77. Inspection Status and Significant Events 98. 'recrmcasevces 139. Safety. Fire Protection & Securi ty 1410. Notable ~cidents 1511. Loss Estimates Update: 1712 Risk Improvement Recom mendations Update 18

12.1 . Recommenda~ons from 1993 Survey 2212.2. aeccmmencauces from 2002 Survey 2312.3. Recommendations from 2005 Survey 'ZT12.4. Recommenda~ons from 2007 Survey 3012.5. Recommendations from 201 0 Survey ..... .. 36

13. Observations 46Cgyer Picture: PVAY-5 at Amuay.

This report follCM's ',(sits to the PDVSA Centro de Refinacl6n Paraguana, (CRP) made at the request of Underwriters ,to assess and repat on progress made in complianoe with recommendations made by Uflderwriters' risk engineersduring thK sulVlly ',(sits in 1993, 2002, 2005, 2007 & 2010. • also contains infonnation on the reported operationalstatus of the various units. significant operational events, significant maintenanoeflOspectioo events , detal s of anynctable incidents 0( accidents reported to the risk engineers during Ihe survey, and an update to the estimatedmaximum loss. Forfurther tadual information on key details of the risk, referenoe should be made to the RiskEngineering Report from the last full sulVll y carried out on behalf of OBE in Odober 2010The authO( retains drawings. photographs and other documentation, acquired Vitlilst carrying out the SUlVlly, Yitlich canbe made ava~able should the need ari se. All enquiries should in the first instance be directed to:

The Engineering Manager,OBE Mame and Energy S~dlcate 1036.Plantation Plaoe.30 Fenchurch Street ,l ondon. EC3M 3BD

Disclaimer• should be noted that any liabil.y Vitlich .#-"" Enginttf'ing may incu- In tort (including but not l im ~ed tonegligence) arising out of 0( in connedion with this report shall be excluded absolutely.• is acknowledged that this repat is not intended to identify al hazards which may exist nor is it intended to bean exhaustive re',(ew afal possible eventUalities. Any recommendations fO( risk improvement contained in therepat are purely advisory and the decision and responsibilay fO( implementation rests with the site'smanagemefi. Responsibitity fa underwri1ing decisions rests with the underwriter in all cases. No responsibla ycan be taken for the accuracy of any inbrmation that has been provided by the client. (the assured. the broiler aIhe underwriter) fO( the purposes of this report.

a BE Disclaimer

This report hCl$ bu n provided solely to provide infr,"notkm to UndelWritel$ l7bout rllt /odUties referred to in the reportond rhe projed monogemenr $)Istems in operotion at the fodiitits. for tilt purposes oj rhe UndelWriters' risk=essmenf. The report gives the opinion oj a BE UndelWriting Limiredin resptd of tilt expawre to the inwred ptr~s, thequolityof rhe loss conrrol measures in ploce ondmoy olso make recommendarions forri5k improvemertf.

The recommendotions submitted in rhis report (if ony)ore purely odvisory and ore for rhe purpose of l7ssisting rhe Insuredin risk control ond soft ly ossessments. It 1$, howe..er, not irtfended re imply thot no other risks exist or rhor no otherprtcou!ioru need to tit roken. No guoronru is gillen as ro the occurory, viobUity or rompltt:entSS of ony oj tiltrecommendations proVl'ded Ol' os to the rontent of the report.

The report soes IIOt QUOronret,. assume or WOrTOnt in ony woy !hl7t the Ownel$/OptrotOI$ ore in compiionce with onyk1W$, reguklrions, code$ of procrice oronyorherlegolor Industty requirement or I}llidance opplying to the jocUitits.

QBEUnderwriting limited occepts 110 HobHiry whorsoeverfor ony erTOl]' or omissions in the report or rhe consequences ofreHonce on the inform ation provided.

I

~isk

PDVSA Centro de RefinaciOn ParaguanaRecommendations Update

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Basic InformalionCLIENT ORGANISATION caa Marine and Eller S odicate 1036COMPANY SURVEYED Petr6leos de VenezuelaLOCATION Centro de Refinilci6n Paraguam1 (CRP) Amuay and Card6n Refineries

These are essentially two refineries, operated as a combined system.Man~menl . maintenance. etc are common to the two.

VISIT DATES 5 108 Mardl2012VISIT LEAD BY: Roger Gregory liP- Engl"••r1n g for aae Marine & Energy Syndicate 1036A LSO A TTENDED BY David Dalla Costa Chartis, Madrid, e....c e ,PRINCIPAL COM PANY OmarJ Bravo CRP General ManagerPA RTICIPANTS jesUs Malpica Technical

Rcnald Pella Seguridad IndustrialRamal Uzcalegui Operations ManagementEddie Miguilene PDV MaintenanceElisaul MOlluslena SMC ManagementCarmelo L6pez Process Management AmuayRicardo J . Ramirez M. Process EngineerRuben Bos~n Manager Operations CardOn

IZoilo Rooan MaintenanceLuis Heredia Technica lWlliam Medina FinancesLuisauerc OperationsHector Martinez rscAlberto Rodriguez SIHOPedro Suarez GSA Card6nFelipe Semeoo Operations SMAFidel Fuenmay«e Manager ROI.tine Maintenance AmuayFrancisoo Montero OperationsNelly Rivllfo SIHORamon Cosi PCEJose Vargas Tectlni cal

I Oscar Salazar MaintenanceAngel Ouintero MaintenanceDenis Ruiz TectlnicalLuisa Lugo Industrial SafetyJuan Joe Ram irez Industrial SafetyAlexes Bracho a . PCE OperationsGennan Buslus Industrial SafetyJa~erGoi~a FinancesMarilza Vallejo PDVSA Caporale Insurancesarah Claffey Cooper Gay , LondonDiana Renfigo Cooper Gay , ColombiaContributions were made by othllfs during th e presentations onrecanmendations and the brief site tour.

Roger Gregory R#1II< En gineeri ng on behalf ofaBE Marine & EnergySvndicate 1036

SUPLEMENTED BY: Market Report by Roger GregoryR~Engi n eerin g on behalf of aBEMarine & Enerov Svndicate 1036 fran \.lsit dated octcbe- 2010

PLANT A DDRESS: Punto F-o, POI uana. Estado Falc6n, VenezuelaPLANT TY PE AND CAPA CITY: Amuay: 63S,()()())opd, 'Nith distillation, lubricants, hydrotreatment, FCCU ,

HF alkyta~on, delayed coker and flexi cok llf (FCCU ).;~~6n: 3OS,OOObopd, with distillation, lubes, hydrctreatment, FCCU, H FaJ lation, lscmerisetlcn. delayed ecee -.

LAn TU DE, LONGITUDE, Amuay: 11"37.8'N, 070 "13.3'W. Elevation 5 1021lTl amsl Area .. 38llha ,ELEVATi ON & AR EA: Card6n: 11"4S'N, 070"11.S'W, Elevation 5 to 21lTl amsl Area " 420haSITE SITUAnON Coastal sites, 14km apart , on south-west comer of Paraguana peninsula ,

on the Gafo de Venezuela, Ugh! populatioo, no significan t adjacentindustrial exposures. Nearest town , Punto Fijo, approximately midwaybetween the two sites.

PDVSA Centro de Refinaci6n ParaguanaReccmmendaacos U pdate

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2. Values and Estimated Maximum Loss

INSUREO VA LUES: US$x1 Comme....sProperty damage Card6n: 10 .625. From Febl\lary 2010 valuations by Advanced Appraisals

Nnuay: 11 .829. (Brazil) . Increased by 1.5% for 2011 . Includesequipm ent, construction, and Foundations, Vtrysign ifican t increases in value s since the 2007 valuationby the same company (Card6n USS 4,843 millions,Amuay US$ 5,843 millions). The recent valuations hawbeen accompan ied by a detailed site layou t showing thelocation of eacnuen.

Business Interru lion Not CoveredBoiler & Mach;,ery Damage AssllfTled included in Property Damape sumsinsured.

Contin ent BI Not Covered

~isk US$)(10 CommentsLoss EstlmMe:

Property damage Amuay 3 ,356 HF Alkylation Iscmerisalion Section DIB columnOverhead Receiver l00tonnes.

Cardon 1,408 Card6n Alkylation 21sornerisalion Section DIB columnOverhead Receiver 100 lomes. Similar estinale resultsfrom 37.1 tonne release In FCC Gas Plant,

61from PO Not CoveredMB 16 Major un-contained rotor fa ilure of one of the three ex-

"GENEVAPCA" cas turbo-aKemators61 from MB Net Covered

PDVSA Centro de Refinaci6n ParaguanaRecommendations Update

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3. SummaryThe main purpose of this vis~ was to obtain information on progress 'Nith respect to the risk improvementrecommendations mad e d~ng underwriters' risk engineering swveys in 1993, 2002,2005,2007 & 2010. In i1dd~ial .

we have included details of signi ficant changes or events in management stNcture, in operations, projects,maintenance and n scecrco. detals of reported incidents involving leaks. fires. or explosions. and an update of theestimated maximum loss based on any reported changes to insured replacement cost values.At the commencement of lhe survey there were 22 O\tstanding recom mendations comprised of a total of 46uncompleted action items, and oflhese items we are able 10 report 16 ( 35%) dosed, 19 (41%) in progress, and 11(24%) with no progress.Reference should be made to the October 20 10 underwriting report for further details of the risk . only cnanges andevents of~nific;ance in are reeceeee in the descriptive body of the report . In particular, details of values and thedevelopment of the Estim ated Maximum Loss are unchanged, wi th the except ion of a small "indexed" adjustment tovalues advised by the d ient.Overa l , we see some positive progress, aRhough we continue to rate this large refinery complex as "in need ofimprovement" as in 2010, A stronger "proactive" approach is necessary in our opinion ,

The oven JlI c ompany structure for Refining is essentially unchanged. A new Maintenance Organisation"Planificati6n y Oirecci6n Venezuelana de Mantenimienlo" has been set up to streamWne Ihe planning and executionof major mainlenance at the PDVSA fad lltles. This is based at Paraguana.

Prod.lct ion al the time of our visit was SOO.OOObid at Amuay (nameplate 635.000b/d). with all un~s op erating exceptthe A exicracker (FCCU ). Alkylation , Depentaniser , rscnetseucn and one Sulphur Recovery l ra in. There arethrough put lim~ations on Crude Un~ 1 vacuum feed fu rnace. Card6n is operating at 195,OOObJd (nameplate305,00llbId), with the largest Crude Un~ C[).4 and associat ed vacuum uni t shut down following Ihe February 5"'fire onCD4, these should re-start very shortly, Sulphur Unit PRA-3 is shut down, Jetty 1 is in repair ~Howing the October2010 fi re.

Major m aintenance (turnarounds) has been seen 10 be suffering from delays, typically of one or two years, supportedby "Technical Operation al Evaluations", These large refineries . wi th a multiplic~y ofun~s have many should giveoperat ional nexi bil~y to ta ke un~s out for maintenance. It is hoped that the new "PDV Mantellimiento" wi ll reverse thetrend of delays to major mailltella-oce .

ROlIine maintenance suffered a significant "low" in 2009, the effeds of'Hhich are still being felt. evidence d by amarked increase in the ratio of corrective to preventive maintenance . The effeds are also evident in the maintenancebacklog partiaJlarly for pumps and molors, and in a higher than larget proportion of "Emergency" and Urgent" workorders. Howevef. it is encouraging that these figures are being reported to management. Procurement remains asignificant challenge, aRhough proprie tary pump sea ls are avai lable.There is a continuing effort on the structural integrity pr09"lUTlmll , wi th good evidence of progress, however it isrecogn ised thai the scale oflhe problem on these "aging assets" remains a high priority. This inclu des thereroeeocree structures, steel structures and their passive fireproofing . It is noted that many uni ts yet to be treatedare making use of temporary support slnJctures, and thai these are nel fireproofed. I is also noted that the work oftemporary construction and replacement is carried out as "SIMOPs" (i e. simultaneous structural work on an 2el!ratinguni t).

Inspecti on rem ains organised as before, but wi th some add~ional own-hire staff. On stream inspection is by a localcontractor (Inspfalca ) who also provides scaffolding etc. Analysis remains by PDVSA staff. and "SILCO" is used forscheduling , recording and analysis. A ceresco Under Insulation plan has been commenced. prodUCW1g manuats ofCUI prone areas and inspection plans. There have been vertjca~ty and thermographic inspections oftJrnace sta cks.and this pl"ogramm e is aactually running ahead of schedule, Off-Process (Outside Battery LimM) pipewon< has nowbeen included in "Sll CO" . stornge tankS are inspected on "Risk Based " criteria . tan ks prioritised , and inspectionsbeing carried out on "High" and "Very High" risk tanks first . Typically 26 tan ks per year at Amuay and 34 per year atCard6n are to be inspected -this is intended - in lime - to eliminate the presen t Sl.lbstantial back-log, PresSl.lrevessel inspections are said to be fully up-to-date, and included in "SILCO".Pipework inspection records were viewed for the Amuay PVAY"4 v aensn Column Overhead circuit and Bottoms lines.These were easily found , and the inspection records were avai lable back to 1986. We were concerned however thatno basel ine inspection had been carried out following a significant replacement and change of steel alloy. tha t themaximum 2 year cyee had not always been kept to, and that fer the evemeae circuit, where there was knONnsignificant thinning of the pipe wal to the extent th at remaining useful ~fe was short and a "sp ecial watch" had beenscecaec. there was no attempt to check any of the many "dormant" TM L zones,


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Techni c al Services eeitnue to be involved in projects, monitoring of process "exa n sions" etc , an d there is a majorAlarm Management exercise underway. to address the knCMTI problem of alarm "ovel1oad". TNs project . in ouropinion , requires more formal~y.

Safely (SIHO) continues to aud~ permits towor1< and to carry out detailed audits . and repoo improvements il someareas of compliance. There has been ina-eased tra ining of issuers and receivers of permits and other topics includinghousekeeping. The "S1SA" database Is used to progress recommendations, and although there rem ains a largenumber of open items, it is reported that thi s has been reducing . There is a "DJpont" inspired "manual of lessons frompast events. with "Best Practice" exemplars as well as analyses of ilcidents. Includes process associated events.PTW. LoTo. etc .

Fire Protection: Organisation unchanged, firefighting equipment: now being added to "SA P" mainten ance schedulilg.Many r.ew fire trucks have been received. and old ones are being refurbished where economic. Fire pumps still do notcomply with annual crrve testing, and recent tests shcm lw<:I of the diesels at Card6n. afthough operating , havedeficiencies. There is a corporate initiative forthe inspection and maintenance offirefighling and detection apparatus.(SICOINE database). lMlen fuMy populated, this will replace the present paper system, which is being operated inpara llel

Security : has been moved from Operations to the Safety and Protection group. and there are investments inprogress to autanate the access control system , the ilter-s~e canmunications, to Improve perimeter lighting and tobuild the National guard a neN "Reaction Centre".

Incidents : DJring 2011 there were 222 incitlents reported, ilcluding some 100 fires, many of these being incontamin ated pipe trenches. At1hough there is a good procedure for incident ilvestigation , we were disappointed tonot that few had progressed past the stage of settilg up a study committee, and only 9 were "closed", wi threcommendations carri ed out. Specific ilcidents since~ 2010 visit described to us were:

• 11109/2010 Card6n Jetty 1 fire - Burst Kerosene Loading Hose.• 15/0312011 Amuay HDAY-4 86,ooObid Gasoil Hydrotreater Explosion - CUI on Hydrogen line• 2410512011 Card6n 77 ,OOObld FCC Fumace Explosion - Explosion during re-start following ilstrument air

loss.• 0610&2011 Amuay HYAY-2 9.Smmscf/d Hydrogen Plant (Reformer) Furnace F-SS1 Explosial - "Plugged"

tubes, not dried OI.lt, exploded and ruptured a~acent tubes.• 06r'01f2012 Cardon Platformer "Incipienf fire - radiant area leak following significant overtemperature.• 0910112012 Amuay PVAY 27,300bfd Vacuum Un~ Unsafe Caldition of Furnace F-100 - Collapsed re fi"actory

and carcase distortial• 05/0212012 Cardon CDU4 7O,0Cl0 bId Crude Distillation Unit Fire -faUure of small bore line al atmos. COIOOln

boltans pump suction.

There have been several furnace ilcidents in the past few years . but there is no apparent common cause.

PDVSA Centro tie Refinaci6n ParaguanaRecommendations Update

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4. Company Administrative Structure ChangesThe company structure as applies to refining is essentially unchanged.There is a new group ' PDV Mantenimiento' , (Planifical i6n y Direcci6n Venezu elana de Mantenimiento) intended 10have a national scope, 10 address the challenges of major maintenance in the Oil, Gas and Petrochemicals ad i,,;l iesof PDVSA ilod by extension, others in simHar fields. (See "Maintenance" below)A "Strategic geseve' of about 50 engineers representing all discip6nes. (especially electrical and plant) has beenfOllTl ed , on a two year trainilg cyde, and these are currently wortil'lg "..,der super'>1sion.There was iI rump of retirements in 2010, retirement can be at age 50 , but can extend to 65. and there are typicallyOeM' 20 to 25 retirements pre yearon an overall staffing level of 4360 (direct hired). This includes the power & steamgenera~ ion fac ~ity 'Genevapca" which was absorbed into the company structure, but does not include Ihe marineoperations or the "Bariven" staff seconded to CRP.

6. Operational Status and Significant EventsPresent operational status if; as foBows:

Amua~ is running SOOkbld cuoe rate (desi gn Is 635kbfd). wi th no change to the crude diet. Units are all operational'Nith the exeee nce of the Flexicracker (FCCU DCAY). the Al k~latiCW'l un~ (A LAY) and Depentanser (DPAY) .lsomerisation (ISAY) Ught Ends Recovery (GLAY) on maintenance since 21" January, 'Nith a planned oiI~ date of15t!l April . The CW'l1~ changes have been reliabilit~ improvements to large rotating machines. no changes to processesor tech nologies. Kerosene H~drotreater(HDAY- 1) was shut down last week to decoke the catalyst beds; SulphurRecovery 3 (SUAY-3) is not operating. Crude Distillat ion Unit PSAY~1 had a tube fa~ure in the F3 Vacuum Feedfurnace.liniting caP3cit~ to 55kbld (desigl 63kbl d). Furnace plam ed to be rep lace during Milich 20 12 .

Cardon is ope!1lling at a maximum of 195kbld crude rate (design is 305kbld), with th e largest distina~on unit CD-4 shutdown due to the February 5"' 2Q12 release and ire (see "Incidents" below), In consequ ence , Vacuum un~ AV-2 shutdown. These should re-start during March 2012. The PlatformerlHydrolreater developed a furnace F301 tube leakand was shu t down 6"' January, re-started 12"' January. The FCCU sull"ered a "steam valve" event 21)" Feb ruary, andwas shut down for 3-4 days. Alkyla~on unit 1 had been shut down for more than a year , and restarted end of JanuiIrY.The Feed/Product heat exchanger M 1001 has an internal leak , although this is reported not to be affecting productionrate or quality. Sulphur recovery un~ PRA -3 is not operational . Repairs to Jetty 1, l'<t1ich suffered a serious fire inOctober 2010 (See "Incidents" below) is planned to be completed to allow operation to resume by th e end of August2012.

6. Maintenance Status and Significant EventsThe principal change to the maintenance organisation has been the separation of Major Maintenance to be theresponsibility of a filial group "PDV Maintenimiento" (see below). Operational maintenance remains wi thin the CRPorganisation.There are 8 groups reporting to the manager of maintenance at CRP - Planning & Contracts, WorKshops, Rout ineMaintenance Card6n . Routine Mar.tenance Amuay, Instrumentation and Control . Special Equipment . Materials(stores), and Assistance I Management. aeeeteat Maintenance Is tceetee in the Operations Department, 'Nith theexcececn of Electric Motor maintenance, l'<t1ich has as own workshop in Maintenance Department.The 1oIa1 number of workers in the CRP maintenanc e organisation as at January 2012was 1139. We do not havefigures for vacancies.The maintenance ph ~osophy Is essentially unchanged, Preventive - calendar or cond~ion based, Corrective forfailures, maintenance projeds to optimise performance or eliminal e root causes of failures, ail within CRPmaintenance, and "major m aintenance" now with PDV Maintenimiento.

" PDV Mantenimienlo" , (Planificati6n y Direcci6n veoeeueteoe de Maintenimiento) is a sp ecia~st maintenance groupheaded by Sr. Jesus Luon go, head of Refining G roup . and as such comes under the overall management of CRP.The decision to form th is group was taken late in 2010. in response to concerns about delays to and costs of majormaintenance to th e PDVSA assets. Presently there is a staff of 134 engineers iII1d administrators, 'Nith a creo tcincrease evenlualy the head count to 800 or more. The motivation is to create and preserve expertise in the planning ,contracting and execution of major maintenance acti>Aties svdl as Tum-Around Maintenance , and the pro>Asion c r astock of necessary toots and accessories (cranes, welding sets, scaffolding etc. -investment in this areas staled to bein the order ofUS$ 25 millions). The group is run by a board level "Junta Directiva", and reporting to this aredepartments for Administration. Planning . Operations (i.e . responsible fOf execulion of major maintenance worK onPlant and Equipment. net plant operation), Technical . (who are responsible for standards, compl iance, engineeringtechnical disciplines), Contracts (10 manage third party works), Finances, Services & Logistics.

~is*


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The scope and timing of maja maintenance activities win remain with the individual refineries and operational groups,and hence "PDV Mantenim iento" will act very much as an internal contractor, In time ij will have branches at allPDVSA main sees. Note that "PDV" In the t ~le Is "Planlficati6fl y Direcel6n Yelezuelana" and not -seecrecs deVenezuela", and lt1at the long term aim Is for the organisation to be available for other industries in addition the oil , gasand petrochemicals secta. To putlt1e Major Maintenance challenge at CRP Into perspective, there are some 83process lIfl~S in the Card6n - Amuay refineries , plus offsites and cuutes. and je tties, In a typical year, there are about37 major maintenance interventions (turn-arounds) , and this may rise to a peak of 54 In some years.The contract award process Is stili essentially as before th ough, with a need to comply with the laws of Venezuela, and"Bariven" are still to be used for procurement.It is understood that "MG3P" software is to be employed for the plarming and managem ent ofturn-arounds, to controlthe oil-out to olj-in duration and to keep wilt1ln the maintenance objectives.Key Maintenance Perlormance Indicators are presented annuall y to man agement In a "Rendid 6n de cuentae'. ThefoUewing are extracted from recen t "Rendid ones",

Maja mainten ance (Turnarounds) costs since 2008 have been:

T • 2008 2009 2010 2011Partial Turn arOUnds 26 27 12 12General Turn arounds 2 12 , 3Cost (USS Millions) 477.85 388.66 432.91 314 .30

The emphasis in 2011 has been Amu ay, with Sulphur Recovery SUAY-2 & 3, Add Gas Recovery FMAY- l , SourWater Treatment SWAY-2 & 4, Gasoil Hydrotreater HDAY4 , Reformer HYAY-1, TSAY, and Jetty 2 at Amuay, plus SepTap 3, Separator 1, the CCR Platformer and the Jetty 1 repairs at Card6n.The origin al plan for 2011 was staled to be for 2J General Turnarounds and 2 Partial Turnarounds. The originalbudget for 2011 was reported to be in excess of US$ 1 billion .

ovear. compliance with lt1e declared turnaround intervals for lhe various plants has been variable, wilh plants set at 4years being run from 2OC6to 2011. Many of the unils thai were scheduled for turnaround In 2011 have beenpostponed Into 2012, wijh subsequent me-eases In run length , follewing a "Technical Operalional Evaluation". Thtsevaluation focuses on operational issues wilt1 the most oritical equipment , mostly concerned with Dynamic rather thanSlatic aems. A few examples of postponements are given below.

~.. '"" Oescl1ptlon TAM Last TAM "~.. Postponedlnt w s TAM TAM

c.""" CD--:VAV·3 Crude ~CU..., Units ,~"'" JunIl2011 ~2012c.",., HDT- l GIosoil H rClreat.... ,"" 2007 J~11 J 2012

""'. >JAY JlJ lOtion • 0" aoos Se 201 1 Feb 201 2

""'. OCCAY Cal Cfll~jg-IOc;k ",, 0''"'" S. 2011 JIII1 2012

""'. HOAY2 DistiIllltes rot reat. , 2007 Ma 2011 20"

Maja maintenance to the jetties al Am uay has been significantly Ialer than the 8 year interval speci fied, with Jetty 2having had ~s turnarounds in 1998 and 2011 . Jetty 4 at careen had ~s last turnaround in 2COD, and has lhe nextplanned fa Iale 2012. Fa Jetty 2, the last turnaround was in 2006, and the next will be planned for 2014 to 2016,atthougtl ~ Is ha~ng replacemen ts and upg rades to serne of ils fire-fig hting mains and apparatus.

The costs for routine mairtenilnee since 2008 have been :

Typ. 2008 2009 2010 2011Corrective 94.298 66.950 97.802 193.644Preventive 116.396 49.962 71.456 95.551Mixed 13.830 2.105 2.470 1.021Totals : US$ MiIliollS 224.526 119.017 171.727 290.215

Prior to 2009, lhe costs were relativety steady in the ranae US$ 220 to 280 minions.

From this dab, me asured on a cost basis, lt1e proportion of "Corrective" maintenance is clearly increasing, from about50% up to 2009 to 67% in 2011 . On a work cecer bests.uie proportion is 69% Corrective to 31% Corrective. ursInstructive to nole that the low maintenance spend in 2009 has been fofl~d by a mar1<:ed deleria<ltion In lhecorrective/Preventive ratio , The target figures often stated in PDVSA are 20% Corrective to 80% Preventive,

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ccmprence with maintenance programmes and backlog fof the whole of CRP is summarised below:

',,, "" "" '''' ""CompiOlflOll Pnl"""ti"" PlrnJlS end BI"",on Terget >90'lIo '" as '" "Complie""" Pre.",,1MI Sped... (T\rtXImeenne<Y1 T"'9"1 >9~ lwe_ 85%) 83 ,3 ee se seCompl" """ Pnl_~"" ...iI....."e.... T"'9"l >918% 98.22 96.12 9S 13 ss aCompl" noo Pnldlct"e PumJlS To'll<'l >90% ." '" '" U.-..Isble

BacId<>sI PumJlS in V'i<J<1<shop (Nos)Av..-_ T..-gel <1:l'5 "" '" '" asaBacId<>sI MOIors ,n Wor\«;hop INos ) AII""'9" T"'lJ'Il <75 ss ss M '"Backlog ExCll&noeo> (NoS)AII""'9" T8l'geI <20 " " " •Compl" """ wilIl VVe&l<ly P lein Tergel >8S'Mo (merHlO....D8Se<l) sa '" ss "Wlrk Orders by Pm nly( EmOfll8rl<y\Jrgo>rf.4'lol.trle) T"'lJ'Il <~<15->80 3-1lHl1 ~~ 9.5-1 5.5-15 s.as.seComplOl""" Ma rt"".""" Prog, Me;or EQl"pmert ('Mo l1"'9"185'llo " " " Ullll\lalsbl.

The principal reasons given for the worsening performance with respect to pumps and meters was insufficientresources , difficulties in placing and cont inuing contracts, and the procurement of spare parts . During 2011 . thecontract workforc e accounted for some 3 m~lion man-hours of waX, implying an average ecorract workforce in theorder of 1,500 for rouijne maintenance acti\'ities.

Spares procurement lead time for National purchases are typicaly average 30 weeks, whereas internationalpurchases average r:Nef 60 weeks. The operational inventory of spare parts is in the order of USS 45 m W~ons.

The most criijcal spares In this instance are typicany seals, redudng gears, and bearings. For pump seals, which arecritical to the integrity of contanment systems. there are technical support and supply contracts with proprietary sealmenutactwere, organise<! through ·Bariven" the PDVSA procurement organisation. The suppHer (John Crane) has abase at CRP as a first point of contact , and as a faBback Bariven will deal with John Cran e USA.

overar . there is closer compliance with the routine maloterence programme at CardOn Refinery than at Amuay.InstNmentatiorl is interesting hONeVer, in that a lower number of "op erational doubts' are being recorded , that is,wh ere an operator queries the ecrreeeiess of an instrument reading , and the instrument artificer called to check theinstrument finds ' oc fault " in the lnstrcmeot . Operators have been trained to recognise problems, and confidence inthe e seu meres on the part of operators is therefore seen to be growing .

There has been significant work on remediaticn of the structures both at Amuay lind Card On. This has includedreplacement of steel and ferroconcrete structures, and the remed iation of detatched fireproofing On steel structwes.TempOl'ili)' supports that had been tntrceuced as emergency measures have generally been lell in place, and areredundant, a~hough they are likely to be removed for use elsewhere on the refinei)' . We neee that whWst thetemporary structlXes were in place , they were nt1 fireproofed. At careen. work is completed on the Furfural ExtraetlonUn~ , vacwm Distillation 1, Vacuum Distmation 3, FCCU, and Asphalt BlCM'er, in progress 00 the Propane DeAsphalter 1, and Crude Oistination 3, planned to start October this year on the FCCU Fractionation pumphouse andaudiary pumphouse, the pipeway bridges. and Jetty 4 in March 2013. Significant ether repairs are planned in 2012for the Hydrt1reaters, MEK De-Wax ooit, croee Distillation 1 and Alkylation 2. At Amuay, work has prog ressed onPSAY-3 crude Ul'l it. PVAY-3 Vacwm unit , PVAY-5 Vacuum Unit , NFAY-5 Naphtha Fractionator, PSlFVAY-1CrudeNaaJum oo~ , HDAY-4 Kero Hydrt1reater, and waX is planned for the DCAY Flexiaacker.

We ncte hCM'ever that much of this waX Is carried cot as a "SIMOPS' actMty

7. Inspection Status and Significant EventsThere is no change to the organisation of Inspection . Establishment staffing is 46, and there are 40 in post . A"strategic Reserve" of 5 has been recru ited an d shoold commence here SOOn, plus a further 2 as Corrosion andMaterials specia~sts, The Stl1lltegic Reserve is sourced from nl!'W graduates, or people recru~ed from recognise<!contractors,

The Inspection schedu~ng and analysis tool used is "SILCO' and cxrrll1llctor-s (Inspfalca) carry out the field u~rasonic

measurements, the contract includes the measurements and the scaffold ing reqlired to do access the measurementpoints . The contract Is on a 2 year cycle , due to expire May this year, and CRP is in the process of negoijat ing thenl!'W contract wh ich (hopefull y) wil be in place before the expiry of the old ecneee. Analysis of the readings is carriedout by PDVSA staff.

PDVSA Centro <Ie Refinaci6n ParaguanaReccmmendaecos Update


Ref20121139 0f54

oQBE

ACorrosionUnder Insulation (CUI) plan was commenced inOctober 2011. Theaimis to produce aCUI Manualspecsk to each un ~ onthe refinery ,and there are 5phases tothe wort:

1. Technical Concepts (refereoce codes: API 571 ,NACEInternational, Shell DEP 30.46.00.31YPDVSA PI-D209-04)

2. Idenlificalioo andclassificalion of thermicaltt insulated lines3. Developmentof lecmetrc Drawings of H~h Consequence lines ~unclion of pressure, temperature and

malerial contained)4, Data Collection5, Consolidationof information and identification of inspection facil ~ies .

The planis to complete all the manuals by the endofMay 2013, To date,progress achieved is 14%against apla nof27%. The manuals specific to the Furfural Extraction andMEKDewax unjs (lUbricants) are reported tobe complete,and aplanhas been developedand executed (clamps added) for the three Hydrolreaters followingtheMarch2011HDAY-4 incident (see "Nolable Incidents" below)(Note, theHDAY4CUI incident was inMarch2011).

There has been aprogramme of Visual, "verticality" and thermographic inspections of thechimneys of thevariousfurnaces and fired heaters onthe refinery. There are approximatett 35 furnacesat Card6n and 50 at Amuay.Inspectionscoverthe carcase ofthe chimneys and lheir dueling, refractory linings where rtlled, painting, guys andother external supports,and produce comprehensive tabular database reports. (example below) The plan ,phasedover two years commenced November 201 1,and is running signirlCantly ahead of schedule currently (40%versus15%planned).

OPO...RES~TAOODE INSPECCKlN YlSUALDE CIIW£AS

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OutsideBattery Limit Pipework between unrts and storage wi1h in the Amuay andCard6n sjes,and servingthe;ellies have been indudedin the"SILCCW schedufing, recording and analysis tool. It is reported that all lines havenow beenincluded. The lines between the refineries aresurveyed by Security for interference or incursion.

Low PressureStorage Tanksare inspected on a"Risk Based"approach. There are 6phases:• External evaluation,

Visual inspectionand historical review• Repairs database

Actualisalion and development ofexistingdatabase, creationof dynamic tables

• Failure Consequence AnalysisBased on characteristics of storage, material stored,safelyand operational factors

• Failure Probability AnalysisCorrosion &Operational History, location &design.

•••"•"iil-- - - - - - ~~-.•••••· "

PDVSA centro de Refinaci6n ParaguanaRecommendationsUpdate

First Draft Date 03 0l/;.:u12

Ref20121139 0f54

oQBE R;ttisk

I

• Analyse Risk Lewlfailure probab~ity and consequence considered. 5 x 5 matrix , risks classified in 5 grades from "Very Low" to VeryHigh

• Develop maintenance plans for next 15 yearsSee table above.

The Risk Basis eetem ees the priority of tanks to be addressed , and initially the maJority"";l be the ' High" and 'VeryHigh" risk: lanks. There is no apparent equivalence to the -250 lanks overdue for inspectionhnaintenanee reported In2010. There remains t10wevef significant operational presswe on the availabll~y of these tanks for inspeetion andmaintenar.ce, and only time wil l tel if this initiative succeeds. A similar ph~osophy is appFied to the pressure storagespheres and bullets.

There is reported to have been 100% comp~ar.cewith Press....e Vessel lnspeclion s (drums. exchangers,columnskowers and reectcrsj, with a lotal of 1719 at Amuay and 1353 at Card6n inspected in 2011 . These are alsoscheduled and recorded using the ' SILCQIU software.

As a sample, we requested to see the inspection records of the Amuay PVAY-4 Vacuum Dis(illation Unit T-151 columnBcttoms line, Ihrough 10 the bottoms pumps. W e were informed thalln 2OO71his had been changed from carbon seerto 5% Cr Low Agoy carbon steel during a rout ine planned tum-around. No base-l ine wall thickness measurements hadbeen taken . First measurement was in March 2011 , and at that time 2 measurement points (multiple TMLs) wererece-ded. Reason given was thai it was a cosily exercise, and because an al oy s(eel had been used, the inspeclionswere not necessary. Inspedions at2 year intervals are reported to be required forthis duty, and this has not beencomplied with. Next turnaround is in 2013.

A second j ne requested was Ihe overhead j ne for the same vessel. This is a negative pressure line , and is fitted withS(iffening hoops and support clamps. Initially there were aboul20 inspection poirts. but these had been reduced to 5based on operational and corrosion experience. The other points. presen~y -frecuce ' in ' SILCO!>' do however havesome hiS(oric readings, and could be readivated . Poirt 8, an elbON, had been measured in 1988, 88, 91, 93 , 95, 98 ,2000, 01 , 04, 08 an d twice in 20 11. The graph presented shows little loss in wall thickness up to 1998, then asignificant loss in the period 1998 to 2000. bllowed by a continued slow reduction . The remai ning ~fe for the fiYepoirts measured varied from a maximum of 15 years, to a minimum of 1.8 years (for Point 8). and M's iI1speetioninterval has been reduced to 8 months. We would queS(ion whelherlh is finding should have justified the reac tivationof 'inadive' inspection points on this circu~? (See illustration s below) These and other lines are due for replacementin tile 2013 tum-afDund.



Ref20121139 of 54

~QBE

LINEA I} E CABECERA I} E VACIO (TOPEI} E LA T- ' SI )

ULTIMA INSP ECCI O N

ULTIMA INSPECCION

D "' -

---,""". MID: 1).111Es p. Mn: 0.234Esp, Holll: 0.U5Esp. Rot: O.I2S

•V.U '" -vce util ' (Usefl-i Life)

PQVSA centro de Refinaci6nParag..aanaRecomrnendiltlOn5 UfX1ate

First Draft Date 03 001," '1

Ref 20121139 of 54

:. ~;sk

8, Technical ServicesTechnical Services continue to monitor processes, process variables' deviations and excurs ions, feedstock changes inquality etc, consultation on maintenance planning. There Is a major project on the Lubricants units, involving anexpansion and adding emergency isolation valves etc. The drawings used for t he expansion are sti ll the ' Maraven"drawings from 1994, styled as "for detailed design". However, engineers walk the plant and confirm that the rerevantparts 01 the plant are realistically represented on the drawings. Technical are invot.-ed in the "HazOp" and "Whal lfstudies and the "Diadem PHAPRO' format is used for these.

Process Variables are mon~ored to initiate action or analys is when significant deviations in temperature, pressure ,composition, pH, Chlorine, iron content etc. take place. Fuel gas Is analysed by a gas chromatograph, and me LeanAm ine specttcauon is 100ppm tota l Sulphu r. There is presently no problem With amine supply. Any shortfa ll is said tobe countered by recocucns in rate. There has been a change in the supply of Natural gas lor the reformer andturtcaltematcrs, and afthough this was not carried out under the manage ment of change regime , an equivalentprocedure is said to have been used .

Alarm System Performance

,-

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There has been an Alarm Managementexercise, so lar on crude unit CD-4 Inaccordance With EEM UA 191-1999 al'ldANSIIlSA 18 .2-2009. Honeywell EventAnalys is is being used. Thecasercetens. In ascending order ofcriticality are:• ' Predictive" (avera9B :56 , maximum

:560 ala rms per hour),:• "Robust" (average :560, max imum

:5600 alarms per hour),• "Stable" (average :560, maximum

:56000 alarms per hour),• "Reaewe" (average :5600, maximum

:56000 alarms per hour)• "Ove rloaded", which is anywhere

more than "Reactive". (see diagramIrom EEMUA 191, j'4 edition).

Oth er criteria in the gllidance include thenumber and durat ion ct -sreveo-and"Standing" alarms, and the "Top 10 LoadPercentage".Using these criteria , it has been recognised that most systems are "Overloaded' according to the EEMUA definitions,and have been so since 2008. SOme action to rationalise the alarm systems has taken place , btlt not to the EEMUAphilosophy, and with no specific budget To a Iar9B extent the success of the present initiative depends on theaccuracy 01 the P&IDs, afthough the software In the Honeywell systems can be used to del lne the alarm loops loranalys is. 11 is instructive to note that the alarm management study was initiated. At least in part, as a response to theMay 201 1 careen Fluidised Catalytic Cracker lurnace explosion.In our opinion , the Alarm Management Programme requires to be formalised and adequately funded.

There is a plan to Instali lwo "Polyduetos" (multi- product batehlng pipel ines) 10"0 and 16"0 to supply progduets to theSajo Grande distribution centre nea r Maracaibo.

PDVSA centro de Rel inaciOn ParaguanaRecommendations Update

First Draft Date 03 OO'))l2

Re12012/139 0154

~QBE

9. Safely, Fire Proleclion & SecurilyThe organisation for the Industrial SafetylHealthiEnviroomenl (SlHO). Seoority (PCP) and Fire Intervention has had asmal l change, with Securty being moved in from Operations. Overall staff establishment for SlHO and pcp is 83, anda further 15 posts await approwl. Safety has an estabhhrnent of 17, 3 vacancies being Qmenlly fi ~ed by contractors,and additional safety analysts plus oocupalional hygierdsb are being recueee (part otthe 15 above). The Firefightershave an eslabtishmenl of 64, with vacancies for 2 supelVisoo; and 32 tremen.

SafelyThe 'SISA" database for recommendations arising from audits. investigations or safety reports by others (including theInSU"ers' recommendations) continues in use. In an, since its inception in 2004, there have been some 4,600 entries.roughly evenly distributed between Amuay & Cardlrl. On the database , these are recorded as ·CU· (completed) , "EP'<in progress). "CA" (cancelled), "SF" (long term),"NA" (Pending Response) or "SS' (selected for audij of comp letion ).There are reported to tie 621 of these In categories other than "Completed", and the num ber remaining to becompleted is said to be on a reducing trend.

There continue to be single top ic aud~s on the units and audits of Pennijs-to-wOl1<. The aim is to have 3 or 4 auditsper area per year - and wi th the increased num ber of Safety Analysts, this should become achi~ble. Detail auditscan take between 1 and 4 days. depending on the complexity of the area under study. Fi particular. considering au ditsof Permits-to-Work. which are in our opinion vital to management of safety on the refineries, the results show som eimprovement in th e period since 2009, especialy in work execution and dosure of the permits, although there hasbeen a deteriorafion in performance on permit issLing. The areas reqLirin g and receiving allention in 2011 have beenthe risk identification. Safety Analyses (ART), traini ng and authorisation of issuers, executors and receivers of permits.houseke eping, demarcat ion of work areas and closure issues. These concerns are being addressed by formaltraining, toolbox meetings , poster campaigns etc.

There is also a manual of lessons teamed from past events, This initiative started last year. "Dupont" materials werepurchased, includin g DVDs, on process , chemical hazards, driving, welding e1c, permit-to-work, LDTD, and shCM'sexamples of "Best Practices", and where these are not necessarily properly applied.

Fir e Protecl ionThe organisation of the fire irltervention forces is essentially unch anged . A pl;roned tom the fireprotection group is inthe Maintenance department to progress the addition of firefighting systems into SAP. This includes the fixedprotection systems located on the units and on storage (monitors. hydrants deluges, foam systems and the like).Detection systems for gas and fire remain by external contractors and are not included on SAP because they aremaintained on contract by external companies.24 new capital fire trucks have been received since 2004, and som e 26 "old" trucks are retained and are, or are to berefurbished. The new trucks all have 3 ,ooOusgpm pumps and 200Jsg foam tan ks , and are fully compatible wi th the5"0 Storch connectors used on the hydrants in the "high risk" areas of the site.

Fire Pump testing has not been carri ed out annually (2009 to 2012 Card6n Diesels, Eleclric pumps tested in 2011).Tests are prOlr-lmmed th rough SAP, so it is unclear wh y they qre na scheduled in accorda nce wi th the NFPArequirements. The results for Card6n showed the elecbi cal pumps to be satisfactory, but the diesels to need attention,one of them being 18% belCM' the curve, and another suffering from a pressure re~ef valve passing at low pump flCM'(high pressure), although this did not affect the performance at high flows. where the pressure is somewhat lower anddoes not open the reliefvalve. There are recommendations to remedy pump 22, recalibra te the re~ef valve on Pump23, and to replace pump 21. The Amu ay pumps had also been tested. but we did not review the results.

A new system "SICOINE" (Sistema para el Control de las osoecctcoes de Equipos Contra Incendio) was brought intouse last year. This Is a corporate initiative, and when fuHy populated wil indude all FIRE detection and praectionapp aratus. So far it is populated only by extingLishers, breathing apparatus sets. and fire trucks . For the firefightingveh icles, there is a status "li ck 1st", The old paper system remains in use however. but is being migrated to SICOINE.

0f54

oQBE

Ref 20121139


Secu rity (PCP)Security hilSan establishment of 159 to ccver the two refineries. th e marine facil ities and the pipelines between therefineries. They can cal on support from the armed servces (National Guard) and armed cont ractors . The sites arewei provided with access control and intrud er detection , wi th an outer cordon plus an inner III'VeI providi ng access tothe operating units and marine fa cilities. Access control has a database forvali dation of entry through the "badgecontrol led" access points. The security systems are in the process of being autom ated (CECON system), whichshould be compl eted by 2013. Improved communicafions (fibre-optic) between the two sites should be completed thisyear, imprC/\/ed perimetrallighting , and a new "Reaction Centre' for the National Guard. This represents a plannedinvestment of US$ 48millioos.PDVSA Centro de Refinaci6n ParaguanaRecommendations Update

10. Notable IncidentsIncidents are recorded on the "Meridium" database. These are broken OOwn l.7f area and by ty pe: Operational,Incident, Accidert, vehcuer, Electrical Failure, Fire, Spill, teak Emission or Other, and classified t:>,' risk as loW,rrecnm , or High.During 2011, - 100 fires were reported to reve ccccrec. Of these -60 we!"e said to be in o il cortaminaled"Trincheros' (pipe trenches) , There was a total of 222 incidents reported (including these fires). Of these 9 were saidto be 'completed (fully investigated and recorrsrercatcns carried out, and included on the SISA database), 11 hadbeen "d ivulged" (The Irwestqetc n completeand the relevant people informed}, 20 were being investigated, and 173were at the 'Comite" stage, i.e. a learn had been allocated. Rewrrmendations, where made, are progressed throughthe ' SISA' database.

Incidents described to us dlxing this visit are:

111091'2010 Card6n Jetty 1 fi reAviation Kerosene Jet A1 was being loaded via roses to a tanker. The roses had been installed in 2007, and had notbeen been inspected, although it is understood that some had been repaceo, A hose failed by' a combination offatigue and accumaaton of tension/compression in cUlVature, this resulted in a cut to the vuceraeeuco reyers. Therewere two loading PUfTllS started simultaneously, and the resu~ing pressure surge is thought to have cor1ributed to thecause of release. The resu~ing fire caused severe damage to the structure of the jetty, and it remains out of service.The regular strong wind is understood to have made the fire more intense. (See photographs below),Action item from the irddenl is the institution of Annual or 6 monthly inspection of loading hoses. Hoses areextensively used at both Card6n and Am.Jay, for a variety of products including LPGs.The Jetty 1 refurbishment features a reduced number of hose connections. (More Photos in ' Observations' below)

«Shows extent ofrepairs to jetty substructure.

And replacement of topworks, hose g<lntries

etc>

We commented that there was no obvious marking on the hoses to indica te that they had valid recenltests, shinkingin terms of stencilled obvious tag numbers and COIOlK codes, rather in the manner used for lifting apparatus in manycoo-nee. Following the meetings, we were given details of a stamped idenlifier on one flange of the rose, and wereshown a test certificate whch incidentally was rot dated.. This is not in our opinion 'obvious·. IdenliflCation or testingassurance.

1510312011 , Amuay HDAY-4 86,000 bJd Gasoi l Hydrolfeater - explosionOperation was reported to be normal. The overhead line to the recycle gas compressor fa iled (700psig@1 10"F} Thereeaee, mostly of I¥drogen i:lnd methane ignited and exploded, Release mecharisrn was extemi:ll corrosion, underinsUlation. There had been more ra infall than in the past, and a heat tracing line was leaking, causing condensate tobe trapped inside the insuli:llion.Because of the loWer rainfall in the past, this line had not been identified as a candidate for CUI, and the Shell DEPhad not therefore been fully applied,Mer the event, the CUI plan has been formalised, and similar symptoms have been discovered on the same circuit oftwo other Hydrolreaters HDAY-2 (Distillates) and HDAY-3 (Gasoil). Clamps have been added where required, and theCUI pran extended to i:l1I l.rits.This, in our opinion, is a reactive response to the problem, (See above · Inspection·)

POVSA Centro de Refinaci60 ParaguanaRecommendations update

First Draft Date 0300/20"

Ref20121139 0f 54l!lQBE

2410512011 Cardon n ,ooo bid FCC Furnace ExplosionLoss 01 Instrument air to a fuel gas varve was Klenlified as the RootCause, restored flow generated a Mmmablemixture in the combustion chamber, whk:h ignited and exploded, Supplementary causes were alarm Oooding - 350alarms in 50 minutes (Ihat's an averageot1 every 9 seconds), and the Re-Start procedure was out ot dale.Alarm rationalisation for thewhole of Centro de Refinaci6n Paraguana was recorrrrerced

0610812011 Amuay HYAY2 9.5mmscfld Hydrogen Plant (Reformer) Furnace F-851 ExplosionDoring a start-up after repairs to the furnace, there was an overpressure of tubes that had been "plugged', due 10steam condensate being sealed into lhe tubes, and there being no mechanism whereby the trapped steam pressurecolJd escape (The furnace temperature is - 1800°Fj The subsequent explosion ruptured other nearby reformer tubes,which escalated the incident to a tumace fire which pullhe uM out of action temporarily.Investigation revealed thai no management of change was carried 011 wRh respect to the plugging of the tubes. As apre-emptive measure, at least one nroe thai was not actually leaking was plugged, hence the overpressure andexplosion. Proper drying of the tubes prior to plugging has been recommended. we suggested that holesshould bedrilled Inlo tubes to be plugged, to remove any possibi lity of ccessotsenco

06101120 12 Cardon Platformer " Incipient" fireRadiant Area Header leak and small (incipient) fire. In October 2011 there had been an over-tereperanee (850"C vsdesign640"q on 5 tubes, operat ing temperature was lowered and thermography increased to daily and cleaningfrequency increased, Remaining lire (creep lire of lubes) assessed as very short, and visual rospecncos increased to 9per day plus 2 thermographic inspections each day. leak was esccvered at visual inspection"

09/0112012Amua.y P.-VAY 27,3OObJd Vacuum UniUJnsafe Condition of Furnace F"100Deformation discovered on carcase of F-100rcrrece. Low thk:kness of refractory noted on lower area of furnace,weight of upper refractory had crushed lower refractory, ShI1 down and repaired,

One of the new EIVs

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Ref2012/139

AS shown on the "redline" P&ID Notedate of "redline",

050'0212012 Cardon CDU4 70,000 bid Crude Distillat ion Unit Fire.«Column aoncrre Pumpssuction line small boredrainage connection failed.Subsequent fire causedsignificanl damage 10 unit,Remains out of action,Emergency tsctaton vevesbeing Installed as part ofrepa irs - ir installed soonerwoud have reduced theconsequences. Notedamage to t.Odel'Slde 01second level floor

we asked specirlcally to review the rcmace Inciderts that have recently occurred,and Rwas concluded that there was no significanl comrron causal factor -OIXinitial concem that this lXII"ortunate r!XI of incidents may have been connected withoperating heaters and fun-aces beyondthe usefu life of their tubes has not beenborne out bt experience.

POVSA Centrode Refinaci60 ParaguanaRecommendations Update


11 . Loss Estimates Update:The Estimated Maximum Loss. (EMl) br insurance purposes. can be defined as the largest loss anticipated (rom themost severe ecce-renee possible to a location, causing widespread damage th at renders fi re protection ilndemergency shutdown procedures iloperatiw, or the systems cceate without any changes in the final oulcane of theloss. Only passive physical features sum as spacing , fi reproofing , diking, and topography are effective in 'im~ing theloss.At this sile, the mechanism whim has been identified as the worst incident is "Vapour Cloud Explosion and FireFoIll7Ning", resulting from an uncontrolled release of namrn able volati le hydrocarbons foam process systemcontainment, subsequent Ignition , and combustion In the process unjts . Overpressures tom the initial explosion areassumed 10have disabled systems intended to prevent further release or to extinguish fires/eooI structures.We do not consider the probabmly oflhe incident - ~ is sufficient to say thal whatever design, construction, inspection,maintenance, operation or protection measures are t aken , the capacity for the WOfSl event remains, and th at there willexist the possibil~yof many pctentlallesser loss producing Incidents.

ValuesThe properties al CRP were revalued by Advanced Appraisals (Brazil) in February 2010. The total replacement costvalues for the two sites as of thai dale were dedared to be:

S"' Plant & Eq~ment COnsb\ldlon Fom oatlons 2006 Replaeement 2010 Replacementas New Value IllS New Value

~US$ 9,691B-llion US$ 825 Millon US$ 1.137 B-lIion US$ 5.902 Billion US$11 .654 Bilion

CW " US$ 8.4606i llion US$ 859 Millon US$ t.149 Billion US$ 4.843 Billion US$ 10,468 amen

The 2010 valu ation represents a vel)' large increase in the repl acement cost value forthe see. Underwriters areadvised to re'View the valuation ~ainst their conception of relative values for refineries of broadly simi lar scale andcomplex~y worldwide.Full delail of the valuallon WilS given in Appendix AS of lhe 2010 underwrit ing report . These were prlMded in ExcelWor1csneets, and reference the contents of each block In some detail. It has been possible to sum the contents ofeach block , and it is these block total values that have been used in the EML calculation

T he 20 11 values are merely indexed tom the 2010 values by 1.5% across the beard.

Site

A",::=¥.:=

21111 Replacement asNew valueUS$ 11 .829 BilUonsUS$ 111.625 Billions

We have therefore chosen to not re-run the EML calculations, and have innated the resulting estimated maxinum lossby the same factor. For further details please refer to the 20 10 underwriting report....


First Dr.In Dat e 03 0l1~ , ?

Estimated MaxlmunLM'US$ 3,356 millionsUS$ 1,408 millions

Ref20121139 of 54

~QBE

12. Risk Improvement Recommendations UpdateThere are on reccer reccemen cancos made ltJring Risk Engineering SUrveys cA ttle Centro de RefinadOll Paraguanamade dlling 1993. 2002. 2005, 2007 & 2010 . These were included in the 2010 underwriting repet in bolh Englistland Spanish. Progess on completion of these reccrnmendations has been reviewed, ba sed on reports and evidencemade available by CRPmanagement and ccseveecos made in the field by the two surveyors (Mr Roger Gregory.representing QBE. and Mr David Dalla Costa. representing Chartis~ Only reccmmendations thai had not beenrepeteo as dosed falowing past surveys reports lYe eocessee In this report Overall, at the cornmencernent of thesurvey there were 22 outstanding reccmmendations conpdsed of II total d 49 uncompleted action items. end of theseitems we are able to report 16( 33%) dosed, 19(45%) in progress. and 11 (22%)with no progress (See Pie Chartbelow)

'" prollf• • • . 22.~%

PDVSA centro de Refinad On PeraguaneRecommendations Update

Flrst Draft Date 03 04f201~

Ref 20 12/139 of54~

QBE R~isk

SUrrnlary of Recommendation Responses

• • f SIJfeet ....~ COrrnlent05.1993 Card6n Remery: Independent High In Progress E2 Sphere implemented, during present

Level Alarms (Pressunsed TAMstaaoe\ E1 s enere olanned for later th is V<!Iar

08.2002 CRP; P&lD memaandum In Slow Progress In Progress. Project progressing .(prE!\fioU5ly part of 05.1990 Technical (Long Term Examples of newly "actualised" P&IDsInformation in Control Project) were sha.vn to us, although those we sawRooms) in control roans were not "As Buift", not

authorised, some from 1997 (Maraven)issue drawings, and not "Autoplan" CADissues, Few "RedHn e" changes recorded.It is unclear whether these are the"Master" P&IDs, or whether the concept of"Master" P&IDs exists.

10.2002 CRP: Housekeeping improvements In Progress Amuay housekeeping falls far short ofc coueucue Effort expectations orl un~s we visited . PSAY-4,

PVAY-4.

Cardon housekeep ing was generally

much I~~t,er than befor~ ~n the un~svisited. FCC, PG2 . CD4

12.2002 CRP: Inspection program coverage of Closed Offsites Pipe systems on the refinery Nowoffsite oicewor1l. included in olanned orooramme

02.2005 Wafer Flanges I Long Bot Flanges In Progress N. Protection Jackets national suppl ierPhysical identified. Note these are not the usual

Pro~tSS (4 "Stainless Steel Sleeves" most usually

,," used fa' this eurc cse,06,2005 Pressurized LPG Storage at Card6n In Progress E2 Sphere i mPI~m~:ed , during present

Refinerv TAM E1 Sohere annedlaterthis vear11.2005 Emergency lsolat iorl Valves (EIVs): In Progress New EIVs at CD-4 have facil ~y to operate

Operation from the Contrd Bunker from external safe location panel and fromthe control bunker. Not presentlyoperable from control bunker (See AlsoRec2007.11\.

01.2007 In-process fixed gas detection In Progress but No addl~onal detectDrS installed sinceinstallation , plus maintenance and No Physical 2009 upgrade of PG2 system . This hasoperat or training on existing systems Progress not operated successfully. Cards on

order via Bariven , stil not received.Original card s were damaged by incorrectgrounding system. This issue said tohave been solved fa' the Gas DetectionSystem on this unit, although problemunderstood st~1 to exist on other units.(See also 05 2010 re Bypassing duringelectrical storms\.

08.2007 EIVs Operabil ity Closed Closed:Proottest ing regime now established.inclUding testing at planned shutdownsand other opportuni~es. ComprehensiveCheck~st now used for each valve.(example seen), No "Partial Stroke'resen " facilit has been instal ed,

09.2007 LPG Sphere best practice for In Progress Cardon Spheres reported to comply afterSamp~ng I Water draw-off aud~.

Amuay S 207 sphere being treated duringTAM . other spheres follow at their TAM-3 in 2012 and another 3 in 2013.



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11.2007 Improved provision of EIVs In Progress 328 valves origfnally identified. Scope(Slow) now reduced to 21, using PDVSA 1997

criteria of 25m3 inventory . Another ~2Owill be needed. Scope now includesovemeae drum sour water dr.I'N valves.5 valves installed at CD-4. Had this.beenimplemented $99!?6f, !htt oonseguencesof tm Ftlbnarr 2012 CD4 fire would havebeen sianif!£sntly ,-,duoed,Legacy issues Cardon EIVs are fall-setepneumatic, those at Amuay are electricaldrive.

12.2007 Floating Roof Tanks - Housekeepn g & In Progress Schedule estabhhed starting JanuaryGfounding 201 2, with checklist and register, however

frequency is only one check pel" year. Thiswe considel" to be low for a task consisting,, '" a visual cheel< ,

14.2007 Management of 'Safety Critical ' valves

"No Progress Still an inconsistent approach

2, No Progress Sane valves seen controlled using cable3, No Progress ties, however many others seen not to be,. No Progress controlled.5: No Proaress

01 .2010 Fire-Safe/Fire Protected EIVs. 1 Closed Gap Analysis canpleted and fireproofingPriority A Protection of Cables & General Cable plan prepared

Fireproofing 2 n Progress ImprOYements to power cable fireproofingmade on HDAY-4 (by PDV Maintenance)

3 Closed the four zooes identified by us in 2010 inHDAY4arerepaired. DKAY andALAYbei done durin resent TAM

02.2010 ATS (Assessm ent of Safe WOrk). to Closed Sane mOdification of ATS, to includePriority A consider process hazard s some considerations of process risk5.

But see Site Observation03.2010 Unconl.roled Bypasses 1 Closed The "block" on C351 governor did notPriority A disable the protection, .....t1ich is

independent.

2 C_ Blue Book appears to be properly usedand authorised.

3C_ Regular audit earned out on rotatingmaeunev orotection.

04.2010 Tank A7-2 Bund Contamination 1: Closed Cause found and eliminated.Priority B

2: Closed Conlamination remCNed

3: In Progress 2 other blocks of laoks identified withsimilar svmotoms. Planned to be treated.

05.2010 Long Duratioo Bypasses (e.g. For 1: In Progress Cause identified as grOl6lding of thePriority A Electrical Storm T tveats) protection system (Clean /Dny Earth

system), Varistors on order or beinginstalled.

2: In Progress Still some recent "Blue Book" entries oflong dosation bypasses for "AtmosphericCond~ia15" or "Rainstorms", even on unitswhere it has not been a problem,Mitigation measures remain vague -

3: In Progress "monitor the process" etc.

~isk


First Draft Date 03 0l/~ , ~

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00.2010 Control of Hazardous Energy during No Progress on FUll LOTO Is not in practice. DupontPriority A Maintenance: Positive Isolation, any of the 6 Training "Best Practice" taught , but not

Defin~ions, Identification , Tagg ing , etc, points, prad iced. The PDVSA Norm also cahfor full LOTO.

07.2010 Register of Firefighting Equipment

"In Progress Annua l Plan local , blJ: work entered into

Priority B SAPwhen required .2, In Progress Early Days : "SICOINE" inventory and

checkl ists etc . Are yet to be fullypopulated with all systems and apparatus.Only extinguishers, breathing apparatus,fire vehicles so far included.

08.2010 Sphere Deluge Detciencies 1: ClosedPriority A 2: Closed

3: In PrCKlfess See 07.2010 above09.2010 EIV Local Button Location , Label~ng , Closed At Amuay,nl!\¥ molorised valve panelsPriority A Integrity and Lamp Function. have been installed in some units,

installation con tinues in tum-aroondsAt Card6n, Pinars identified by Yel lowPaint, with push-buttons labelled bystenocil.

10.2010 Anomalous Piping T hldmess In Progress AKhough it was explained to us that thePriority Mea surement Readings in ' SILCO" although not problem arises only where there are small

much apparent differences in readings. ~ is important thatthe principal of assuming that the previousreading was "correct" is not satisfactory.(symptom - apparent increase in wanthicknessl



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12.1. Recommendations from 1993 SUlVey

05.1993 Cardon Refinery: Indep endent Hi ltl Level Alarms (Press uri sed Storage)05.1993 Afarmas Independlentes PO' alto nlvel

An independent high-level a1ann is recommended as a back-up to lhe exis~ng high level alarm on the gauging systemwhich Is already relayed to lhe control room .

2005 Status: Open / Ab/edaThis recommendation is completed for all spheres, except ED-111nd ED-02. Installation of the independed~ level

IIlarm n Eo-1 and Eo-2 wilJ be installed n 2006 during the shutdown of the LPG unit that wi/occur allhe same time d1118 CCU.

Apr~2007 AIG recorrrnendBnon (oflrNll-up visit: No physical progress. The SlIme explanation WIIS provided liS in2005 bU lhis t.me with a planned shutdown of the LPG storage for August 2007 which will agan coincicJe with a CCUshlJldoNn. No Progress I SIn progreso.

Nov.-2007 status: No progress I Sin progreso. Once again delayed, this time toa January 2008 combinad LPG ICCU shl1down.

2009 Status: Goodp rogress (to be installed Q4 2009) I Detailed engineeringdone

October 2010 Status: No Further Progress since 2009. Reported in April 2009 "to be instaUed in Q4 2009"

Marr;h 2012 Status: In Prog ress:E2 Sphere implemented, dl¥ing present TAM, E1 Sphere planned for later this year

PDVSA Centro de Refinaci6n ParaguanaReccmmendaecos Update

- .First Dr.s Dale 03 I'$J ' ~

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08.2002 CRP: P&lO m emorandum (was 199Q.05 Technicallnfonnation in Control Rooms)08.2002 Actua/~acl6nde los PIDs (ya efllUIl8 f8comendaci6n 05.1990)

The CRP practice is to have P&ID documents updated every six months. During the period in-between this regularupd ate P&IDs can be modified YJith a red pen to indicate any changes. A P&ID containing the red pen man<-ups iscomprehensively veri fied as representing existing process equipment before being made available for use. The m astercopies of P&ID documents are retained in the respective process area control rooms and the plant section heads havebeen designated as the persons responsible for ensum g their aCaJracy.

From a review of P&IDs in a number of control rooms the fonowing concerns were raised:.,F A large number of P&IDs do not contain an authorizing signature. Therefa e, it is not clear if the P&ID documents

have been reviewed to confirm technical aocuracy and authorized fa use..,F There is r.o indication on the P&IDs when red pen mark-ups were made and who authorized their addition to the

master copies and Iher use..,F Some "Como ConstnJdion" (As-Built), some "A.P. ConslnJoci6n" (Approved for Construdon) & "Original"

document versions were present.

Therefore, it is recom mend ed that only "As-buil " P&ID's be used which should possess authorisation signatures fromthe CRP approval engineer. Ftnhennore. similar authorisaton signatures should also aocompany any red pen mar1(ups.

2005 Status : Open. The renewal eX P&1Ds was !,farted in 2000 txA laterinlerrupted ~ 2002 because eX the strike. Atthe r.me eX the survey 78 P&1D were revitN/ed and approved at Catdon (40 in Conversbn, 28 ~ Deep COrIversion,etc.). The rest ofP&1Ds at CRPwill be updated in /he pB riod 2006-2007.

Apr~2001 AIG recommendBtlon fo llow-up visit: In Progress I En progresoCRP's anSWef is that some637 PlDsoul of a total eX -1200 dnJwings were updatedwlh the NoVlluser I ALtocadplatbfm during 2000-2006. In~ CRP opted for new sonwares from Bertley which have "in1e1ligent" ifiegrationapplications: these ateAlJIoPIant as df8Wing softwate and Projectwise as document visualization tool. The newapplications 8f8 being used on a pi/ol projed for actualizing the PlDs of the HDAY-3 plant. The project is planned forcompletion in Q3 2007 and witl be foJowed by a 4-yeerptOfJmm to actualiza to "as built"conditions 1~ eX CRP'sPlDs. CRP estimates complelion of this ffICO/'TImendarion for 2012,

Nov.-2007 stiltus: In (slow) Progress I En (lema) progresoDuring OUf visit eXthe cortrol rooms at both tefineries, we obs8fVed fhat some sets eX PID 's were kel1 on flICks and inlarge fofmat (AO}. HoNever, thete were marty missing PIDS; wlJ6n available, most drawings referring to a given unitand kart rogflth6r we te out eX sequence; the sequence was usualfy incomplele; drawings were uncontrolledc0pi8sand were missing teVision da tes forexampla as a result eX arty Process Safety Management action; some copies werealso fXXJras dates could nd be tead etc._A t Cardon, PlDs eX rhe Gas Plad PG-2 date bad<. to Apnl2002. At Amuay,PlDs d the light ends plad DCA Yand GLA Yshowed Oct-1999 and Feb-2OO2 dates.DiSCUSSions wlh the engineering depaffment conflf1Tled that inilitJlives on PlDs actuajzation a'" essentitJly containedwithin the pi/a project described in the Apr,2007 status. All PlDs (20 off} for Amuay hydrodasulfuriza/ion HDAY-3 havenoN been ufXJated using the Badley's AlJIopl8d applicat ion . These PlDs were being circulated for approval by a/ldisciplines before to be officially authorized and issued to end users like Operations teams. It was stated that theseupd8f.ed PlDs would be aVlliiabie in the conlrol room by Dec-2OO7 (note that the pilot project was initiated in May2(071) and/hal f6Plicaticn eXttis exercise had staffed on Cardon's DCU whichcoufis approx. 86 PIDs, AmuayHDAY-4, which is a twin unit ofHDAY-3, Is andh6r ""1'1 candidate plad for the dnJwings actualization.The Bngitlooring department is aware that progress is slow and that the amount eX work lalt is considBnJble. 7he targBIofupdating CRP's ci'ra1200 PlDs by 2!J12 appears uflf88li!,fic wlh the clJtTlNt lavelof txJman teSOUi"Ces andtheengitlooring depaffmed explained that it was looking for more support from managemefi. AI. the Wfll~1JP meeting, theSUf't'ley tNm reminded CRP manaf}fll'Tl&d dthe impoltlJnce eXthe PlDs actlJlJlization andcalledforCRP managamentto comml more fJiUJOUfC8 to this task ,

2009 Status: In progress (long t",",jab)

Status October 2010 In Progress (Long Term Project) Autop/an P&lDs slowly progressIn9, P&1Ds in codrol rooms,some widence eX "redlines" on dfllW!ngs, Of oth6r updatas, (e.g. on 1994 "Detailed enginee illg " issue drawing atCardon Lubricants unil- actua/ised in 2007 wlhout comment


Frst Draft Date 03 0l1~ , ~

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March 2012 Status; In (Slow) Progress:'rne so called "Master" copies of the P&IDs are kept as stick files in the control bunkers. "AetualiSation" is said to becarried out, as part of me HazOp process. and Itlis involves "walking me lines". About 80 are being done per year.and mese are not being put into ttle control buildings until ttle HazOps aredone. In our opinion. ltlis is not logical- ttle"Master"drawings sttould be available for operational purposes. we noted few red line changes on the drawings wereviewed in the control buildings, and some of those we saw were confused, witlltlle change "Clouds" not referencedto ttle euthonsetlcn or management of change number. There were also somechanges ltlat had been added veryrecently , for changes made in 2010, and tile new EIVs reennes had been added during our visit. (See below)

"New" Moe ,

-=->- p,operly,

". , • ,.Id.."intd, , \ I .,

(lOIIl<lO$l03112 ., 0..-

e.rlle< Moe • i .,\ •

No ,efe'ence .

\ HseV'er.lli~e lllisI •on ,1111 dr.wlng

• -• ,- I ", , l-, •... ' .. /' Wi,.... •~.;; -. ~~ " -.-.-< .- "...-.....

_. J..••••-- -'

.!'.PJI.I!_Tile condition of some "master" drawings on slick-files was questionable (left), altttougtl we nave been shewn'ec uansec' drawings, property approved (centre and rigtlt) .


First Draft Date 03()4/Kl'2

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10.2002 CRP: Housekeeping Improvements10.2002 Mejora$ de orden y IImpieza

Genera lly, process areas are kept clean and free of debris. However, three specific areas that could be improved are:.,/ Debris stored in vessel skirts found in a number of process cous..,/ Explosion proof boxes oomaining electrical circuits were loose, thus oompromising protection against hydrocarbon

vapour ingress.-/ The offsite pipe trench on the Cardon site cortained a significant quantity of oil and water covering the lower part

of pipelines located in the trench. There were also planks of wood (scaffold boards). riggers gloves, spare bolts,etc.

Therefore, it is recommended that these housekeeping situations be rectified as soon as possible. Furthermore,verification that these areas rerrejn clear in the future, their inspection should be incorporated into s~e safetywalkabouts.

200:5 Status: Open. No Progress I Ablerta. Sin fJI09reso.Despite me extensiveaudit ofprocess areas, the site tour has confirmed In few occasions that debris, trash and toolsare stored in ooIumn skirts (Lube Plant and CD3 at Cardal, Isomerization and DCAY(T2501) in Amuay). SimilarlyexplosiaJ proof boxes oonIainirY,J el6ctrical circlAls were found loose. At the aoeeon pr6S6fltalion, it wasrecommended to CRP to includB these topics in their check list dlXin:J the operation safely walk or HSE audit,

Apr.-2ooT AIG recommendation follow-up visit: No Progres$ / Sin progru oDtxlrY,J the site leu, sane debris am tools wwe foun:j in ooIumn skirts and explosionboxescontairin:J electriceqlApment were tara notproperly bolted.

Nov,-2007 $talU$: No Progre$$ I Sin progresoHousekeepin:J standard in many cI/he visited process lIYts at both refineries was stili inadequa /eam manyanomalies, often ee same as in previous visits. werewed: accumulations cJdebris from maintenance activities,piping insulatiaJ fallin:J apart, below average f!osf:Idiscipiine, some OCCllfflflCeS of missingcapslplugs for example onthe drainsa fuel gas lines to heatefSlfurnaces, pumps full cJsludge for exampleat Cardon FCCUam Amuay Crude(Xlit 5, HouSf;lkeepin:J in /hesf;l two units was disappa'ntin:J while credit sholJd be given to the much better and<KJequate tlous6J<eeping observed in Amuay light end recovery (Xlit (GLA \') and AmuayFle:x.icracker area (DCA \').Hc:NVeVer in DCAY, a blatantoccur~ of inadequateboItirfJ was observed on /he!Y.l:lelectrical boxes Z406/Z407(each box was onlyciosed with 2 bolls when 24 are normaliy req/ired).

Status 2009: In progress (improvements seen on integrity issues. but P5-J, VAC-4 still gives cause toC<JnCf:Jm)

Status October 2010 In Progress Some improvement seer on integriry issues. PDA1 & 2, Coker. Pipeways,t'I:1rNeNer, rubbish seen in vessel skirts in CON Cake..-, PSAY 5 coIalJn drain, numerous missirfJplugs in ISAY, missirfJbolts on electrical boxes, conduit CCNfWj missing, iuminaires without glass or guard etc.)

March 2012 Status : In ProgreS$: continuous effort remains necessary.Still below standard at AmJay, but much improved on cerccn Example below from Amuay.

PDVSA cenro de Refinaci6n ParaguanaRecorrmendations Update

First Draft Date 03 "'201l

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122002 CRP: Inspection program coverage of offsite pipework12.2002 Incorporacl6n de las llneas off-site aI programa de ItrSpecclon

eve- the past few years , there have been a numbel" of losses originating from off-de pipework that WilS nol sufticienllyecveree by iIIl Tispection progl"illTl . Accordingly, the indusion of off-site pipewor1< in any corrosion monitoring progl"ill11stlould be implemented as seen as possible. From dtscrsstcns with CRP inspection special ists they are consideringwh ether to indJde the monitoring of off-site pipework into their advanced SILCO program .

Thel"efore. it is reccmmended tha t the introdUdion of off-de pipework Wl to the SILCO progl"illTl shoold be implem entedat the eer test possible time.

2005 Status: Open I AblettaOnly 10% oflhe tctelworlf has been carried auf so far, CRP have lisled allAmuay's df-site pipe worl( (a l the jetty andat the process units) that netld to be pan of a corrosion monitoring program; this list still need to be dtlve/optKlforCardon. Once bolh lists will be available, CRP will stan worldn} on the isometrics and on the setting of an Inspectionfrequency, AI/these scI;"lies will be slJb.corlracled. Completion ~ llle system Is expected by December 2006.

Apr.-2007 AIG recommendation follow-up vis it: In Progress I En progresoOff-site pf)eworlffor 7 erees at Cardon have now also been identified Wl addijion to the piping systems alreadyselected at Amuay. CRP estim ates the overall progress at 31% and the 2008 as the ccm pletlon year.

Nov.-2oo7 status : In Progress I En progresoFor Cardon: physical conditioneveva!iofJ, isometrics, fepeirorcJers and inclusion In SILeO have been csrriedou forthe piping systems b6tween plaTts, bdween plans and stOf1lge and b6twoon stontges. "This worl< is pending for thelines connecting the stontge areas lind lhe jetties. CRP's own estimll te of progress is 90%.For Amuay: Lines had already been identified es per previous status reports, blJ e RP opfed fora recheck dtlleavailable information to proceed later on with lhe incvsion of information ino SILeO. eRP's own estimale ofprogressat Amuay is 26%.Note that CRP has reviewed 10 2009 the completion )l'98ron this recommendation.

Status 2009: Closed (Jetties dispatch lines lire still pending txA 10 be compltIt""nd 20(9)

Status October 2010 Re-Opened Jetties dispatch line inspections ere sfi. pendiflf1 despite commitment 10 completeby end of2009

March 2012 Status: ClosedThere are 59 manuals for Ine Wlspedion of all lines on site, with procedures and inspection points. Outside BatteryLim~ Unes and Jetty nnes are done.



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02.2005 Wafer R anges I Long Bolt Flang es02.2005 Bridas de tj)owafer l bridas CM es,»fT890S largos

DUlTlll the \!lsit of the process areas al CRP it was noticed that both refineries make an extensive use ofwaferflangesl loog bolt flanges. The long bolts will be receive direct flame contact if there is a fire in lhe area; the direct flamecontact causes the bolts to eKPal"ld ~idly and lengthen, allowing both gaskets to leak product. The leaking materiallhen adds fuel to the fire and if under pressure il causes a large spraying fire that resoll s in much more damage. It isrecommended the following :

• Identify Loog Boll Flanges• Assess Fire hazard from the contained material and location hazards.• To ~mil the problem offast fai~ng Long Bolt Range valves they should be replace with normal flange valves, bul

the hazard can be reduced by wrapping the loog bolts with a fi re resistant mateeat and lhen enclosing th e entireassembly with a stainless steel covering. In addition CRP should progress~y remove Long Bo~ Flange when inFlammable liquids or LPG servce.

• Update PDVSA engineering standard in order to ensure thaI every Of!Ni process unt wi l not have Long BoltFlange Joint installed any more,

2005 Cflem Comment: CRPwillCCl1duct a gap analysis across the site qy Febtvary 2006, and willpropose an aclionpJan in on:l8rlo upgrade all wafer flanges existing in the complex. By March 2006 it is expected tha! all wafer valvesare icmrtified. By Septembttr roOl5 CRP will revise PDVSA Engineering standard in adf!1r 10 avoid !m l1iliza!ion ofwafer valves in new projects. AccounlabJe: Mail1.enance.

Apr.-2007 A IG recommendillJon follow-up visit: No Progress I Sin progresoNoCCtlCfllte improvement on the pJaris, hence the given "no progress" status. CRP stated ht:1weverlha! I plans 10

idenlifylhe numbefof inappropri8le arrangements in 31 units panned for ma"'enance shl1dc1io1n in 2007 and 10 fittfltJSfJ valvt1s with thermal isol8liorl.ln sutRiflqUfmt main tum arounds, and where t«hnictJlly possibltJ, the valws will bereplaced by normal flanged systems. The.scc:pe ofwar#( for18 unls planned for tumarounds in 2008 is als:J beingdefined and wil/contempl8le the replacement a any long boled flanges identified in these units. CRP als:J agrees tono longer specify wafer type of valves for flammable liquids orLPG service. No inkxm8liotJ provided on whelherPDVSA Engineering Siandards have been formally revised ornoI.

Nov,-2oo7 s tatus: No Progress I Sin progresoMany iong boltedf/anges were observed across !he units and none was observed wlh a rreprcx:ting protection, hencetm 8/tributed "no Pf04ress" status. CRP stated 10 stiN btt in the identification phase (apparenlly 700 Jon;J boled flangeswere listed along with diameters and rat ings d8la j . CRP st8ted Ihallhe collected information was being reviewed by IsEngineering Department (GI/-IP and GII-IC) which will issue the technical specirlC8tions required for Ihe provision afireproofing blankets.For the units scheduled fortumaround in 2008, CRp·s exp/anafiotJ is as per/he Apri/2007 sf8lus repotf.. CRP alsostared that the relevant PDVSA Engineering S!aooard(s) wastwere under review (no specirlCS provided).

2009 Status: In Progress InvenloTy done, risk. ma/rix topriorlizedlhe ones to prriect, standard is written & beingculated, memo for new projects. But no acliotJ 00 site + unaware of t/me scale

October 2010 Status: No Progress since 2009

March 2012 Status: I" ProgressNothing physic al yet, blA local manufacturer of fire resistant jackets has been identifi ed. These are not the suggestedstanless steel band type, allhough if conscientiously replaced aIIer access need s. are believed to be adeq uate.


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06.2005 Pressu ri zed Storage at Cardon Refinery06.2005 Afmacenarriento de GPL en fa refiners eMdon

During the next CCU shutdown, CRP is planning to install ROV on spheres E-01 and E-02. It is recommended toinstall the ViIItves as closest to the bottom of the sphere and not at the current location that is outside the bund area. Inaddt ion the valve should be of fail close type and remotely operated from the control room .

It is also recommended 10 upd ate PDVSA engineering standard with the above recommendation and develop a pla"l toupgrade all other spheres with the above recommendation.

2005 Client Comment: A recommendation wi' be issued in order to in stall ROVs in both spheres during tm CCUturnaround that wiN occur in Man::h2007. CRP wiN mvise, by February 2006, tm PDVSA Engineering Standard inorr;Jer/o incllJde the change of the location for lm ROVs.

Apr.-2007 AIG recommemJatJon fo llow-up visit: In Progress I En prog~soCRP's engineftrirq department (GII-IC) issuedthe technical recommendation during 2006 for/he installing tm ROVsas reoommend8d. This will happen at tm LPG shutdown fION rescheduled for August2007. The f8VisionofthecotTeSpondirq PDVSA standard is still intend«J as is the modfication of any of CRP's LPG sk:>nJge that woufd not becomply wth the updated standard (ac:caurlabilty to GNJ. A first meeAirq wth INTEVEPin March 2007 is foreseen asa start#1g point.

Nov.-2007 status: In Prog~ss l En prog~so

The vaNes instaJlafion is now planned at lhe same time as the January 2008 CCU shudown.For tm romaining poirls, lhe only p rogress staled by CRP is the setting up d a leam 10 revi$8 the corporlJte standardwhich will be lhen be used in the e1abonJlion d CRp·s LPG s1ot"111ge modificat ion program.

2009 Status: Good Progress on an & E02 Spheres, EIVs operable from the bunker to be installed in October2009

October 2010 Status: No Progress since 2009

Marc h 2012 Status: In ProgressE2 Sphere implemented, dUling present TAM, E1 Sphere planned for laterthis year



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11.2005 Emergency Isolati on Valves (E1Vs)11.2005 V<itvulas de bloqueo de emerger1C/a (EfVs)

CRP has already filled a high numb~ of EIV's across the site. In add ~i on to the actuation device installed on the field(push button); it is normal pradice in the industry to hilVe valves isolating large inventories remctely operaled ecm Ih econtrol room; therefore. is recommended to instal a aduat ion device in the conlrol room for al Erv isolating criticalInventory and crilic al t1owtl, In order to ensure a prompt response.

The current PDVSA standard ind udes adualion d8\Aces in the control room only for compressors but n for criticalinventories. II is also recommended 10 upd ate the PDVSA engineering standard.

2005 Cflerrt Commerrt: In reference to the PDVSA's standard on Ell/; CRP wi/! evaluate the recommendation.Time Frame: Sap. 200lS

Apr.-lOOT AIG recommemJatJon (ollow-up visit: In Progress I En prog~so

Remde opet'8tbn (from the control room) ~ existitJ;1 EIVs currerllyfitedwith actuation device located inthe f/6kfwiHbe installed in Cardon FCC utliles pat! ~thec8p8cifyexpensiotlendlumeround carried 0iJ in HrIy 2008. FortheseEIVs, engineering and procurement are 100% are camp/sed.For the remaining urns, CRP states that the improvemeti is inctJded in/he normal ools lumeround scheduiewith anestimated completion yeara 2012. No details were provided.

Nov.-2ooT status: In Progress I En prog~so

Same sluatioo as in Apr. 200T for Carden FCC a1"88 with a camp1elioo dale estimated for May 2008.Plans for 200811150 inc~s carrying 0iJ the EIVs modification on Carden atm. CD-4 unit (5 EIVs - tags 40-HS V001l213l4I5) and CBrdon VItCtlunJ AV·2 unl (3 EIVs - tegs 6O-HSV.oo1/2/J) dJring the corresponding plant turnaroundscheduled for Q3-2008.CRP stated th81 a leam has been set up to revise the con'8sponding corportlte standard.VIV consider that the lInnounced EIVs modifICations on ClIrdon FCC and distillalion 1I1"88S should first mlllerilllized

lind be witnessed by inSVrer3, end that CRP sfDukJ provide the program a actions for the remaining EIV reItofltitJ;1worli., before to consider closing this recommendaOOn and tracking sepsrBIefy the progress for exsmp1e in the projectsection athe undttrwriting repotI.

2009 Status: In progress (GAP Malysis done, priorifisstion being done)

October 2010 Status: In Progress Total a 3J6 valves identif"1ed as needing oontrol room edUlltion. No physicalprogress so far.

March 2012 Status: In ProgressNew EIVs al CD-4 have fa cil~y to operate from extemal safe Iocalion panel and from the control bunker. Not presenllyoperable from conlrol bunker (See Also Rec 2007.11).


First Draft Dale 03 0l1~ , ~

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12.4. Recommendations from 2007 SUlVey01.2007In-proc llSs fi xed gas de(ection install i.'ll ion, plus maintenance and operator training on existingsystems

le-prccess flammable gas detectioo is either absent a- very l im~ed in most units at both refineries. Furthermore, wheninstalled, numerous gas eeteetces were found to be no looger operatiooal. There are numerous case studies in theindllStry , an example of which is the Phililps 66, Pasadena, USA, 1989 explosion. illustrating that early leak I gasdetection is essential to the initiation of rapid remedial actloo.The fol lowing improvements should be implemented :

1) Strategically insta l ftammable gas detectors . alarm ing in the oontrol room. in those process unts with significantinventory of ligt1 t hydrocarbons (particularty LPG holdups In process vessels such as reflux, feed and surge drums,collnl ns etc), and speci fically around those items <:A equipment handling Wght hydrocarbons. For implementing anetredive gas detection ceeraje. identify and risk assess the probable leak sources which oould lead to the formationofflammable gas clouds. e .g. high pressure equipment I joints. oompressor seals, pumps handling flammableliquidslvapours with an Op. temperature higher than the ir lash points, manifolds where many control valves aregrouped with multiple flanged com ections, letdown valve etc.•.The recommendation is appWcable as a first priority toprocess unas not already filled with gas sensors , but shOOd also be consi dered foc LPG storage for Yotlich theprovision of gas detection has already be the subject of other recommendatia'ls. Area detectia'l (tine-of sight devices)as well as pant detectors should be considered,

2) The operational status of gas detectors provided in unit 96 Reformer & HOT area at Cardon Is accessible 00 a plantmimic display In the main Ca'ltrol room. During the visit , it was observed thai this display showed 5 gas sensors in a"fault" mode and 2 others in "alarm" mod e out of a total of 10 installed detectors, l.e. at least 50% of lhe gas detectionecverase was not eosw ee. The following defi ciencies were also noted about the panel operator in charge:

I n ab~ity to provide any explanat ioo about this faulty and alarm mode sauatloo and Its dlIrat iooIssue not recorded in any of the operator logbookLack of knowledge about the functi on and field components oflhe gas detectioo systemNo particular remedial action had been taken to respond to the gas alarm

On tJrther investigation, maintenance also indicated that discrepancies may exist between the gas detectors shown onthe control room displays and the coes actually installed w~hin the units. The extent of such discrepancies is notknown by maintenance, oor Is it knO'M"l by operational staff .

It is therefore recomm ended to:

a) Audit other un~s filled with gas detection , at both refineries, to identify potential similar shortfalls and app lythe improvements llsted below.

b) Inspect, prcce and maintain existing gas detection systemc) Ensure that control room displays accurately reflect field instrumentationd) Regularly train operators on gas detection system and the required actions to take on the receipt of a gas

alarm (all possible alann scenarios snould be ecneeeree such as alarm tom a single detector, frommultiple detectors, pre-alarm only, higher alarm levels etc... )

2009 Status: In Progress overall1) Prqed ofonly halfway through the concept stage, hence very liffleJprogress2) Mairtain & l raining of Closed

Seen functiona l on DeS in CR + Cps instn.Jclion isSl.NiKi.

October 2010 Status: In Slow Progress1) Prc:fed of Units priottised 80cading to DoN/AIChernE rating. Upgrade done on Cardon PG2,

~ever not properly functioning. No specifics/ion yeI for other unls, Concept oriy. No prr:ject timeline established.

March 2012 Status: In Progress - No Physical Progress1) No addit ional deIectots installed since 2009 LpgnJrJe cf PG2 system. T1lis has net operated

.successfully. Cards an Older viii Bariven, still not received. Onginalcards were SIlk/ to have beend8maged by incorrect grounding system connection. T1lis issue said to h8ve been solved for the GasDelection System on this unit, aI/hough problem understood stil/to exist another unls. (See ezse 052010 IU Bypassing dun'ng electrical Storms).



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08.2007 EIVs Operability

Picture 5 here below sh0W5 the emergency Isolattce valve (EIV). HCV-432. installed in the suction ofa hydrocarbonpump. at Cardon's gas plarlt PG2. As it Carl be seen , the alTilllgement is such that the EIV actu ator arld remainingvalve assembly is horizoot al, but the actuator, which is sizeable, is not supported and because of ~s weight ~ appearsto put a lot of stress 00 the valve stem , v.tlich could impede the proper functlooing of the EIV v.t1en required . Pictures 6

a & b are close -.iewt:; of the stern and actuatoc and dearty sh0W5 significal"ll rusting and degraded physical conditioos,which adds further doubts OIl the EIV operabilly. The main concern from the survey team is that the EIV could bestuck open in case a demand 6-om the process ccccrs. Ttis example also raises the issue of EIV prool' testi ng. Also.during the -.isl of the Instaltatiorls, l was observed that many EIVs, nomatly fitted with fireproofing blan kets . had thefireproofing protectiorl not property in place oc remOYed following fa" example mao teiance wa1<: 00 the EIV . This wasobserved wlhin the process units but also in the LPG pressure storage spheres at Amuay.

It is recommended to:

1) PrO'o'ide adequate support to HCV-432 actuatoc at Cardoo's gas plant PG2 arld carry out any requred main ten anceand testll'lQ to ensure the valve opera.bil~yon demand.

2) Audit the installatioos to idel"lli fy other sizeable EIVs lacking adequate supports and/or in sim~ar unsatisfactoryphysical COI"lditiorls . as HCV-432 , and provide the remedial solutions as in point 1.

3) Re-.iew and strengthen CRP' s EIVs ma intenance and prooftesting pM osophy to reduce the occu rrence c:idangerous valve stuck fa~lXe conditions, as in HCV-432 case.For example:

o where spare EIVs are installed , for example where they are fitted to pairs of "spared" pumps, test thembetweentlXTlarounds and not only at tumaround

o consider implementing partial valve stro\(e testing, to ensure that the valves remain operable, without theneed fa" Stll.tting down the process.

4) Identify EIVs where fireproofing protection (blankets, jackets etc .. .) has been renccee and not adequately put back,and restore it where needed. Also, mak e the reinstal lation of these fireproofing items a reqlirement in the acceptan cestep of work permit activities and raise awareness about this point of personnel involved in those activities(contractors. plant operators etc.).

2009 StaWs: In progress, overall1) Carcim'sPG2vallll9 o7ExpirBd2J VelVe support & Operabillyeudits 7 Done, sekJ noimprov8l716rrts to support needed3J Meirt&ntlnce & proof testing improvement 7 No progress

October 2010 Status: In Progress3J In ProgreS$: Mali1tMance s: proof testing Improvement: Spered ElVs stili tested oriy at TAM.No l1IO\I8mert tONards Partial stroke Testing. Electric actuated VIIlves not lested al TAM.Spll d responsibilly for valve (mechanicaQ and Actual<r (InsfllJments)Memo (0711CV10) clarlying procedure, simple check.sheet produo8d, Intention to use as pert ofpre.startchecks alter TAM end other shu/.downs.

COili/leTlt: Make as mandatcxy pre..starl requirement4) Closed: Flre.proofjacl<.ets seen lo be improved 00 site, following memo. HcNIever Inconsistencies stillf'xist. rm,re am howevere llJdriaJl cabieslcondvits that am not tim protected. (See New RtIC 2010.01'

March 2012 Status: Clo sed3J CIos«J: Prodtes1ing regime f1CTW established, including testing at planned shc.tdCN/nS and dh&ropportunlies. Comprehensive Checkist nc>N used foreech VII/va. (exempie SfHfn). No 'Psrtial strokeTesting" facilly has been installed.



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09.2007 LPG Sphere best practice fo r Sam plin g I WlIIler draw-off

t eakape wren taking a sample or drawing water from LPG slorage,ln parti cular the failure 10 Isolate bllowing suchopefalion, has been recognised as one of the major LPG release cau se leading to accident. When \listIng the LPGsphere area ill Amuay, f was observed on sphere 209 that the willer drain line consists of a first Yo tum valw and asecond globe valve which are separated by only 1 foot . Thi s separation distance is considered to be Insufficient andlhe valves could freeze In lhe Ollen position fonewing sampling Of water draw-off ccerencoe. It was also observed thatlhe samp~ng point lennlnilles directly undemealh the spheres, which Is not lhe preferred layout. (Such a design wasa key factor In lhe Feyzin LPG sphere "BLEVE" In France. 4 th JiII"1uary 1966, see"http ://www.hse.gov.ukfcomahtsraglechfcasefel/l in66.htm")

It is recommended that :

1) the doubl e valve isolation on the LPG sphere 209 at Amuay water drain line be modffied to Introduce ill least1m between the valves. Ncte that INs Is also valid on any sample point.

2) the sampling point on the LPG sphere 209 at Amuay be relocated away from the shadow of lhe vessel.Samples could lOr example be taken of the water drain line. Note that water draw-olf lines should terminate alleast 3m (lot) cul side of lhe shadow of lile l ank.

3) an audit Is carried cut 10 check whether similar configurations exist elsewhere . at Amuay and Cardon . and aprogramme of improvem ents be deveiOlled.

Refer 10 API standard 2510 "Design and ConslnJctlon of LPG installalions" for best pract ices on LPG sample points.

2009 Statvs: In progressGAP analysis done, EIVs in walerdfllin lines wi' be insalled, etc.

October 2010 Status: #1, 10, #3 Overall, No Further progressS,:X1eTfl 209 sample point remains underthe vesse l tc:p valve was open. Sphere 208 sample pairt in bad stsre scsample taken from gauge connect.bn, top valve open. Distance bBtwfJfIn sample valves does net complywlh PDVSA1.5m criterion No progress on implementation 0If other spheres.

October 2010 Status: : #1, 1#2, #3 Overall, No Further progressS,:X1ere 209 sample point remains under the VElSse( tc:p valve was open. Sphere 208 sample pairt in bad sreresesample taken from gauge connection, top valve open. Distance bBtwfJfIn sample valves does net complywlh PDVSA1.5m criterion. No progress on implementation on other spheres.

March 2012 Status: In ProgressCardon Spheres reported to comply affer audl .AnlUay S 207 sphere being treated during TAM. Other spheres follow at their TAM - 3 in 2012 and andher' 3 in 20 13.

PDVSA Centro de Refinaci6n Parag uanaRecommendations Update

First Dr.IIl Dale 03 0l1~ , ~

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11.2007 Improved provision of ElVs

A number of emergency isolation valves are already installed across the cons at Amuay and Cardon, however it wasobserved that there are still sigrificant LPG inventories which are connected to pumps and for which the isolation ismanual between the vessel and the pump in case of an emergency at the pI.'Tlp e.g, seal failure. The gas plants atAmuay and cerocn are our principal concerns although other plantareas may also be invo/lJed. Furthermore, theinventory tty-eshold defining the vessels that should be protected by EIVs is now becoming more and more stringent inthe industry.

It is recommended to:1} Audit the lX'lits to identify all the inventories, connected to pumps with only manual isolation between the pump

and the vessel, and with normal liquid levels over 5 m3 of LPG type rreterle l or 10m' of other hydrocarbonsOp. at temperatureabove, at or close to their f1ashpoint or auto-ignition tempera ture, For the systems meetingthose criteria, install EIVs in the discharge lines of the vessels to the pumps. These velves should be installedas close as possible to the vessel or drum and be capable of being actuated from witl1in the appropriatecontrol room (see reccnerenceuce 05.11) and from a safe location within the process units, It is reminded toothat the valves, actuator and cabling should have a fi re raUng of 20 minutes,

Implement the insta ltation of EIVs not only in memain suction line of qualifying~drocarOOn inventories as described in point 1 but also in other lineswhich in case ofa pump seal tenere or other release situation, would be likely to release hydrocarbons,even where the normal now is of water. Particular examples seen include the sourwater line from the water boots or bottom of LPG vessels such as 02601, 02502 etc...at the GLAY gas plant at Amuay. The current design on these vessels is indeed suchthat remote isolation is provided on the main suction line but not on the sour waterlines (see picture 7).

Picture 7: EN s on main line but not on the secondary line - Vessel tag unknown!plant GLAY Anway, but thisIs to Illus trate the point made In the recommendation

2009 S tatus: In progressGAP analysis cbne, EI VS in water drain lines will be ins/ailed, etc.

October 2010 Status: Little Progress since 2009GAP analysis was cbne before 2009 visif. including agreemenf thai qualifying wafer boot draw would also have EIvs328 valves identified. Requirementspassed /0 Instrumentation for design, but no decisions on types (EJec orPneumatic). 1 spool inserted on CON FCC.

March 2012 Status: In Progress, although slow328 vafves original ly identified. Scope now reducedto 21, usirg POVSA 1997 criteria of 25m3 inventory. Another-20will be needed. Scope now includes ocerneeo drumsour water draw valves. 5 valves installed at CD-4, Had thiSDeen implemented sooner the conseQuences of the February 2012 CD4 fire would have been sianiOcanltv reduced(See pictures belgw) Legacy issues _ Cardon EIVs are fa il· safe pneumatic, thoseat Amuay are electrical drive.

---~-- -~ -- . - J

,,,,,,,,- ,•••

,- ----_. --------

: !~;T

POVSA Centro de Refinaci60 ParaguanaRecommendations Update


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12.2007 Floating Roof Tanks· Housekeeping & Grounding

The following anomalies were observed when visijing crude storage tanks 106 and 164 at Amuay:

Excessive vegetation growing out of control in tanks bunds (see picture 8 a).Roof seals excessively contarrinated with oil, which could be a contributing factor to hydrocarbon ignition and rimfires for exerrcre in case of a nearby lightning strikes (see picture 8 b).Some electrical shunt sections normally ensuring the electrical continuity between the floating roof and the tankshell were broken, hence increasing again potential secondary lightning effects s\X:h as bound charge andsecondary arc (see picture 8 b).Tafi(s grounding at the tank bottom not easily klertffi<lble because of excessive vege!<ltion and, in some cases.missing. (This is recognised by PDVSA, in that the Exxon design does not specify electrical grounding of !tietanks, but the Shell design does. PDVSA expressedan intention to grolXld all tanks.)

It is recommended to speciliCi:l11y address the type of ercrraues highlighted on tank 106 and 164 and by extensionestablish a programme to improve housekeeping and electrical grounding standards on all CRP's floating tank storagef<l cilities, l.e. est<lblish <I bund veget<ltion cortrol progr<lrmle, lT1CI int<l in roof seals in <I cean condition, ensure eoequeteelectrical continuity between floa ting roof seals and tank shell as well as ecequate tank grounding.

2009 Status : In progressNeed mae proactivity in repating seal conditions. shunts etc.

OCtober 2010 Status: In progressReported checklist in use, and archived. (Checklist not seen)Tank seen (A7, 2), Lagomar 5 Light Crooa, holes in weather seal, gapsbetween wall and seal, root seal nooxa. (Soo proto)

March 2012 Status: In ProgressSChedule established starting January 2012, w~h checklist and register; however frequency is only one check peryear. This we consider to be low for a task consisting of only a visual check.

POVSA Centrode Refinaci6n ParaguanaRecommendations Update


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14.2007 Management of 'Safety Critical ' valves

'Safely Cr itical' valves include alilhose valves reql.lred to be in the open or closed posjuon for safety reasons.Examples include, but are not limiled to, any valves in a pressu re re lief path, any valves in the firewater or other fireprotective system and any valves associated wrth the ESDIEDP system (eg. isolation and bypass valves).

It is recorrsreroec that these valves (Ire:

1) Identified in the field (e.g. pairted and tagged with lXli Q.lE! reference number}

2} Identified on the P&ID (eg. Safety Critical Valve Open (SCVO) or Safely Critical Valve Closed (SCVC)desigflCltion)

3} Locked or car-sealed in the required 'safe' position, as indicated on the PID

4) Usted on a register held in the Contro l Room and any operation irwolving closir19 ' SCVO" desigflClted valvesor opening designated ·scvc· valves to be corecsec using the cerme-tc-wcrk system or the safely interlockbypassing procedure as appropriate.

5) Periodically checked to ensure they (Ire in the correct 'safe' position

2009 Status : some progress. (Net all valves identified in our opinioo)

October 2010 Status: Some progress. Most valves Si:l6fl controlied using cable lies, however sene seen~oxwonea

March 2012 Sta tus: No Progres s - i f anything, some regressionStill an iooonsisteni approachSome valves seen COfJtrdled using cable ties. however many ethers seen net to be COfJtlOlled.


First Draft Dale 03 00/20"

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12.5. Recommendations from 2010 SUlVey01.2010 Fire-SafeiFire Protected ElVs, Protection of Cables, & General Cable Fireproofing

Pri ority A

There are many electrical ly driven Emel"gency Isolation Valves (EIVs) at CRP. These require areliable source of electrical enel"gy and signal to operate. For this reason. where they are located In afire zone , they are generally to a fire-safe design (actuator and valve body). or are filted with fireinsula tion jackets. Similarly, cables run thrOOJ gh a fire zone, are generally protected fl"om fire using ajacket or coating.During our site \Ois~ many cases were seen where the protection to the cables and thei r conduits waslncomplete. Most prevalent was failure to protect the lIexible conduh carrying the cables fl"0Il1 therigid conduit 10 the actuator body. a~hOOJgh cases also wllfe seen where the condu~was notprctecled. In such cases the cable could be expected to fail rapidly if exposed to fire.We also noted cases of highly significant electrical andlor instrument cable trays (e .g . in HDAY-4)wIlich were protected by a proprietary fire resistant jacket, which had degraded in the ambientconditions to the extent that ~ was essentially non-existent.

We Recommend:, That a gap analysis be carri ed ouI to determinewllere cables serving electrically ltiven EIVs arewithin a fire zone.

2

3

That cabl es found to require prot ection be fitt ed with protective jacketslcoatings.

That the condition of tire protection to imporlant instrumenl and electrical cable trays be assessed andprompt replacements made wIlere necessary.

Cl ient Comm ent :

None reeevee

Status March 2012:

1) Closed: Gap Analysis has b86rI completed. 11lere is a ' Fireproofing Plan" covering passive protection tostflJdUf9S and cables.

2) In Progress: Electrlcaf driven actuators are generally 'K-Mass'!>' protected. Cables are being treBled by acontractor during tum-arounds. HDA v- 4 said to ee eomp/8/ed. DCAY and ALA¥ will falloN during TAM.

3) Closed: tha four zones KJen/irled by us in 2010 in HDAY 4 are repaired. DKAY and ALA Y being done duringpresent TAM



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02201 0 "ATS" (Assessment of Safe Work used in Permit-to-Work) to consider Process HazardsPri ority A

The ' Identilcacion de Riesgos' and associated 'AdieslramientolCertificaci6n Requierdo en Pract icasde Trabajo Seguro' are job safety analysis used In conjunction with the Perm ~-to-Wor1< to Infonn allstaff and workers of the hazards which may be associated with the work to be undertaken and theappropriate procedures and crctecuve measures. This concentrates solely on risks to the workers,specificall y at the sije of the work itself. and does net consider broader process hazards. potenijaldamage to equipment, or hazards that may be introduced remote from the work site. Although inmany cases this will also protect the process, this is not always the case, and significant losses in thepast have resulted from fai lure to recognise process hazards.

We Recommend:

That a mUlti-disciplinary team should study generically the process hazards that may be introduced Inthe preparation and execution of the work, and subsequent return to sevtee of thllllquipment andsystems involved.

The study should consider the consequences of intended actions, unintended ad ions and omissionsin the work . to the immediate process. to ether connected systems or apparatus and to thesurrounding environment. It is suggested that a Wlal If?" formal of study would be suitable, with thetarget of including such hazards on the ATS check( st.

Client Comment;

None received

March 2012 Status: Closed

Some modmcation of A TS, to include some considerations of process risksHowever we not !hat items such 8s 'Lifti /1li1 Plans' for use ofcranes etc. are applied ratherQeneric811y andcoosidermostly weigftlbalaTlCfl and security d slinging issues. On these there is fIOlIppilmnt coosidttnJtiorl ofthecoosequences of cJropped load on spparatus and pipeworlc. over which the lilt is to lak.e place. (EXlImple seenon Amuay Jetty 2)


First Draft Date 03 0l11O ' ~

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03.2010 Uncontrolled BypassesPriority A

On the HDAY-4 unit at Amuay, the hydrogen recycle compressor (C-351) steam turbine governor wasseen to have an improvised ptfyslcal block placed to impede action of the governor On investigation,it was learned that ttlis, and a block to motion of the steam inlet veve to the tul'tline, had been used toprevent the compressor tripping w ring recurrent repairs of the hydraulic cortrolline on the governorsystem. This effectively disabled the over-speed trip. (See photos below).

At the time of the visit, the phy'sical block had been left in situ, bU the t¥pass was not recorded in the9tpass Register, and as far as we could make out was implemented wrtholA arlf approval. Also, thePermit-To-INorX (PTW) documentingthe last repair during which such unorthodox bypasswas appliedcoco not be found and staff recognized that, in the end, no PTW had been issued.

We Recommend:

1 To consciertiously rectify in the field the above described anomaly.

2 That no protective system bypass of any kind should be permitted wntou the appropriateassessmentand approval, recording a the reason for the t¥pass, its t ime of application, lime ofremovals etc, as required by the bypass regster book and bypassccmor procedure. This must applyto software, key switch, hand-switch, jumper wiring, physical blocks, valve movements, wedges, orany other means whereby a system in whole or part is disabled.

3 That regular site audits be carried out to identify and correct any deviations from properimplemertation of the bypass procedure and that perscore r involved in such audits must be briefed onwhat to look out for in discovering weurcnseo or wccrvenc rerbypassing activity.

Client Comment:

None Received

March 2012 status:

1) Closed: The "block' on C351 goyernot', although highly irregular practice, aa ra disable Itle protection.which is irdepenclant.

2) Closed: Blve Book (recording and aulhcx'ising of bypasses am their feffloyal) appears 10 be properly oseaam aIJItlorisecJ.

3) Closed: ReglJlar audit is carried ()(J/ on rotating machinery protection.




04.2010 Cardon tank A7·2 Bund ContaminationPrio rity B

During the survey it was noted that there was considerable contamination In tank A7-2 (Cardon) withcrude 041 and water, originating from the tank water draw.

The reason given for ths was associated wlth the piping system to the oily drain. It is appa rent thatthe sltuatioo has persisted for a considerable time.

This cooseues a significant fire risk, noting that crude 011 pipeworx and the fKiatlrg roof seal pipewo r'P<runs aoove grol.fid in the cont<lminaled area.

The above situation Is reminiscent of reoorrmendatlon 13,2007 (spill in ArmJay crude tank 164 b..Jndand nearby ground plpeway) .

During the visit, we also noted various pipe trenches h~1y conta rrinated w~h oily mixtures, howeverin this case, there is an orgoing see wide prograrrme to remedy this type of contamination.

We Ree:: ommend:

1

2

3

Urgent attention be given to the elimination of the cause of the contamination In tank A7·2 btIld,

The contamination be prorflllly removed.

Audit the pl<lnts to identify simila r tratarces elsewhere <lnd diligently remedy them

Client Comment:

None Received

1. Closed: The cause of this specific oonIaminalion - obstruction ofa drain line - has been eliminated

2. Closed: Oeconlaminathn is completed. Photographs sho.vn to the stIVeyo-s

3. In Progress: 2 other blceks of laMS (A5 a'ld A6. disriliates, net crIXiB oil or black product) identified withsimilarsymptoms, Planned to be treated, funds alicea/ed, .

POVSA Centro de Reflnaci60 ParaguanaRecommendations Update

First Draft Date 03 00/20"

Ref2012/139 0f 54l!lQBE

05.2010 L.ong Duration Bypasses of Protective Systems because of " Electr ical Storms"Prior ity A

The practice of bfpassing fired heater and other protection systems do.xirg (threatened) electri calsto rm activity should be ceased - typically 18 hours, or l4J to 345h (see extract from one of the controlroom "Blue BooK" below, used to record the overrides), Persistence of this undesirable practice,already noted at previous surveys, justifies the cresere recommendation,

Management of Change is also said to be not aopacebe,and mi~gation bf merely "rmnitoringconstantly operat ional variables" OIIef such a period is cortrary to good practice, particularly with thestaffing levels available, The consequent unavailability of the protective systems would certainly notcomply with the required Safety Integrity Level.

We Recommend:

1 The root cause of the instability during electrical storms should be sought and remedied, rather thanmerely masking the symptoms by disabling the protective systems. (We suspect tha t the source ofthe problem lies in electrical equipolen~ al grounding system).

2 "Managemert of Change" for irrportant issues such as isolation of protection should always beconsidered, including when r-cuveteo by concems Oller electrical storms,

3 M it iga~on measures should be clearly detailed, and realistically achievable, statirg a lternativeprotective rreaso es in place, or the parameters that must be rmnitored dlXing the outage of theprotective system.

Client Comment:

None Received

March 2012 Status:

1. In Progress: Cause has been identified to be the grOl.l lding of the protective system - improper segregationof the "Dirty" high current 9afth and the "Ciaan" retef8nC6 earth. ( this was our initial suspicion in 2010) Of1387 ·Varistors", 144 were found tobe fauffy and replacem6flts are Q'1 order or being installed.

2. In Progress: Stiil some recent "Blue Book · entries of long dilation bypasses for "Atmospheric Conditions · or"Rainstorms·, even Q'1 units wnere it has not bElen a problem,

3. In Progress: Mitigation meeswes remain vaglJe - "monitor the process"ao.



Ref2012/139 0f 54l!lQBE

06.2010 Control of Hazardous Energy during Maintenance: Posit ive isolation, Defi nitions,identification, Tagging, etc.

Prior ity A

Several 'terre of plart were seen isolated for maintenance purposes. It was noted that:

• 811ndinglsolation schedules and diagramswere not systematically used• Valves weregenerally tagged blA not physically locked.• Electrical Isolations were tagged b\..( not physically locked• Spades, blinds and blind flanges were not tagged.• Terminal flanges were secured I:7i less than half the flange ocee.• Spades were secured between flanges I:7i about half the flange bolls.• on a specific rercuer maintenance job, it was not clear whether Spades had been inserted between

flanges, or whether there was merely a spacer ring in place - there is lrdeeo no system of identificationof spades versus spacer rings.

(We are aware that this topic is underreviewby me Corporate multi diSfi;plinary commilfae on Industrial Sa/afy. andthai a "Draft" procedure 51-5-28 was issued in January 2010)

same pump -valvesnot taQlled or locked.

Pu~ Dischargeplat e used instead 01

bind flangeBreaker ...uh

tailS onlv

We Recommend:

1 The use of blindinglsolation schedules and diagramson all but the most sirrple of isolation tasks, forall sources of energy and lubrication etc.

2 In addition to tagging, locking of all valves used for isolation. Fulllock·Ol1Ilag-oul is industry bestpractice.

3 In addition to tagging, locking of all electrical breakers used for isolation. Fulllock-oUltag-oul isindustry best practice.

4 Tags to be attached to each and fNery blind, spade, spectacle plate or other means of isolation, crossreferenced to the permit to work.

5 To establ ish a site standard for pos~ive identification of "Spades" and "Spacers", A corrvnoncorventcn is to use a robust "T" shaped lifting lug, with a hole otaeo if it is a spacer, and no holedrilled if ~ is a spade. The shape of the spade or spacer lab should be unique and standardizedthroughootthe site. The appropriate scheduelrating should also be stamped on the lug.

6 Where isolation spades, spectacle blinds, spacers etc are Inserted between flanges, or terminal blindflanges are used, they should be secured using all the bolts, lightened In the correct order, to thecorrect torque Stricter acceptance criteria should be adopted so as to ensure shortcomings like poorbolting practice no longer persists. In short, process isolationsshould have the same integrity as thesystem In wtWch they are located.

Client Corrment:

None Received

March 2012 Status: No Progress on all six points.

FUll LOTO is not in practice, Dupoot Training "Best Practice"has been taught, but is not practiced. The PDVSANorm also calls for full LOTO



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1

2

07.2010 Register of Firefighting E~ipmenl Priority B

The Fire rntevenuco Team keeps an annual "Plan de Trabajo" (work plan) in which is contained theschedule for firefighting exercises and preventive maintenance and testing of the various fixed , mobileand portable fire intervention resources. Th is appears to be a comprehensive and well formatteddocument, which if properly applied , would give the firefighters and management valuable and rapidinformabon on the status at any time oflhe fire response capabHly and oflhe cornp~ancewith theplamed testing programme. It is hCM'evef only a "paper" plan. and is not incorporated into the "SAP"maintenance planning system . Also. many entries for past scheduled acthAties were noted to havebeen left blank in the work plan document , thus suggesting tnatthe schedule was not being followedcompletely. Specific examples were the "Programma de Simulaao Ario 201r:1', which listed monthlyfire exercises. only the March 2010 exercise (Jetty #1) had been recorded, storage tanks bi-monthlyprotection testing, none recorded since May 2010, MTBEfTAME deluges and monitors, tn-monthly,only recorded in January and July 2010. ~ may be that the work is being done, and not recorded.

We Recommend:

The annual "Plan de Trabajo" should be incorporated into the maintenance planning system .

Compliance with the plan shoi.lld be made a Key Performance Indicator for the Fire Intervenbondepartment and the work plan document should be maintained up-to-date.

Cliel'll Commer"ll :

None Received

March 2012 Status:

1. In Progess: Annual Pl8n is a local sand-8lone $praadsh8etkegiser, bl1 worll is enterfJd tao SAP whenrequired,

2, In progress : Eart; Days: "S1COINE" i1veriory and checklists etc. Are yet /0 be fully popu/81edwilh a/lsysems and app8f7ltus. Only extinguishers, bre8thing appanItus, fife vehicles so far included. Needs toexpand /0 capture all fixsd and mobile sysems d detection andprotection

PDVSA Centro de Refinaci6n ParaguanaRecommendabons Update


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08.2010 Sphere Deluge

During the survey we requested a test of the deluge on Sphere 210at Amuay, which has a single lop deluge water distributor. Duringthe demonstration, the 'Sombrero Chino" (Chinaman's hat) waterdistributor at the top of the sphere detached, leading to a verticalfountain of water mostly missing the sphere. (see photo rigtt)

A test of the delugeon Spheres E-01 & E-02 at Card6n revealedsome blocked nozzles and some nozzles not properly pointing atthe sphere, a~hoU!1J the overall cover of deluge water appeared tobe adequate. (see photo below)

Priority A

1

2

3

These are the only deluges for which we requested demonstrations, and defects were noted in eachcase (a"hough rather minor in the Cardon test case).

We Recommend:

That the "Sombreros Chino' of sphere 21 0 be promplly repa ired and that the attachment arrangementfor the "Sombreros Chinos' on other spheres at Amuay be inspected and any necessary rereoarmeasures be taken.

That the cause of the blockageto the deluge nozzles at ceroco be determined, and remedied,

That the preventive maintenance prograrrvne for the sphere deluges be reviewed to ensure thatproper eneoecn is given to the fo..oction of the systems.

Client Comment:

None Received

March 2012 Statua:

1. Closed: 'S Sanbrero Chino"has been replacedby a SupeflOf dssign. am other spheres also treated where-"."

2. Closed: Ttle dehlJe nozzles are reported to have been cleaned. scale flushed form the Jines, am regulatlytested. Any remediation is entered into "SAP.

3. In Progress: A paperplan fOf deluge lests and routine maintenance exists since 2011. being migrated to"SIC/ONE" See 07.2010 above..



Ref2012/139 0f 54l!lQBE

09.2010 EN Button L.ocation, L.abelllng, Integrity and L.ampsPriority A

Emergency Isolation veves are operated in some cases from the control bunker and locally by handswitches on the units, and in others solely from pushbuttons with indica tor rerros on the l,I"Iits Thesepushbutlons and lamps are located around concrete colurms, potentially in positions at risk from plantincidents. They are poorly labelled and not at all "otNious", There are also issues of integrity such asdamage to indicator li ~t, missing indicator Ii~t bJlbs etc.

In our opinion these critica l protectiondevices might be difficult to locate in an emergency, and oncelocated, the appropriate pushbutton might not be immediately apparent (see pIlolographs below)

."

, .• •I '. ,

We Recommend :

1 The safe location 01 EIV pushbUton stations be reviewed in the context of riSk from process incidents.

2 The EIV pushbutton stat ions be clearly designated, by means 01 conspicuous colouring r::l theconcrete column on which they are located.

3

4

That each individual EIV pushbutton module be clearly identified by tag number and the equipmentserved by the EIV.

That all EIV pust'bullons be reguarty tested and maintained in optimal operable conditions.

Client Conwnent:

None Received

March 2012 Status: CIO$d: All 4 parts,

AI Cardon, pillalS idefllified by Ya/Iow Paint, with push-but/ens labelled bystencil. »»>

AI Amuay, new motorisad valve panels have boon installed in some units,installation continlJeS in tum-arounds. (below)


Rrst Draft Date 0300/>0"

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10.2010 Anomalous Piping Thickness MeasU"ement Readings in " SILCO"Pri ority B

"SILCO' is PDVSA proprietary ilspection data managem ent so1lware used for eeercsen monitoringand predictive inspection scheduling.

It was nded that ilthe "SILCO" database, there were many instances where there had been norecorded change in the recorded p",ing wall thickn ess for two or three measurement cycles. It wasexplained that w here a reading greater than the previous record was obtained , the previous value wasretained, rather than recording the measuremenl taken . This is desp~e ' SILCO" automatically issuinga recomm endation to check the reading whenever a reading larger than the previous recorded valu efor the same measurement is input.

The cause of lhe higher reading could be catbratlon error, operator error, non-repealablemeasu rement points, recording error , or the (In our opinion more ~kel y) possi bi~t y that the previousreadilg had in fact been erroneously made and recorded as a lower than actual value.

The consequence of such Instances Is that the rate of carosion is either net possible to calculat e, or ifcalculated, might be lower than actual, leadilg to poten~aly unsafe errors in the estimation ofremainilg life.

We Recommend:

That whenever an anomalous wal thickness reading is observed, whether it be larger than theprevious value, or nd in accordance with the existing Trend: of change in the wall thickness, themeasurement be checked by repea~ng the measurement using the same measurem ent instrumentand a second measurement inslnJment that has been check calibrated. This shwd preferably bedone by a senior ilspeclor.

Client Comment:

None received

March 2012 Status: I,., Progress, although not tfflch apparent

Although I was axplained to us tha! the probl8m arises only where there are small differe~ in readings, IIs importart to realise that the principal d assl#7lirlg that the previotJs reading was #COf'I'l'd " is netsatisflJdory. (symptom - applIrert IfJCffNlSfJ I,., wall thicknltss}



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13. ObservationsThe following observations were meoe to the MarlClgement of Centro de RelirlClciOn P,uagU<lna, ffiCl i~ during theclose-out meeting. It was not our purpose to rrake new recommendations, anhough CRP rrerecerreot wereencolXaged to act on these observations,

Unsafe Conditions at Amuay J etty 3.We noted an instance of a (heavy) rose bearirg on a small bore relief line (1)- on LPG dLty. (see below), This lineserves botha thermal relief valve and a Nitrogen Purge point. It is also noted that thrs LPG line uses no hoist, and thatthere is an lX1suppClrted srmll radil.l5 bend, which must act as a signifICant stress raiser (2)

Two LPG leaks were also noted on the same system, one on the Nrtrogen Purge Point, and one on a valve packing(see below ,



Structura l Integrity Programme - good evidence of progress, but a long way to go,These pictures from Amuay PS/PVAY1

A<:t M ' IIl..... l!Je<:utl d l ",1".11_ $Qpon.. E.lrUCI\It.lo. Tompor. lo.' P-,,,lNCIU' "'" Rewnplozadol lR_'~11ing I Pinlur.,Fi ep OOl" 1I

The ' sooct e Temporal' was instal led to allow operation to continue until the structure was renovated. Note that it wasnot fireproofed, hence the structu re was not etrectively protected against failure during a fire. The renovated structurerestores the necessary fire-proofing. Note also that the repairs (tempora ry and renovations) were carried out as' SIMOPS' - i e. on the run.

Ac,lYId. _ !jOCUlI" ' '' '. ....._ Soponoo EIIN<lUrII.. T__• R... ' 10. " 41_......'__'*'9 I Pmn·F·"",oo611

Planta PStPvay-1

~I<_ ""....d••.............,

PDVSA Ce ntro de Refinaci6n ParaguanaRecommendations Update

First oaa Date 03 01/2012

• II

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Ref2012/139

New StructlXalFireproofing on scccots to

feed to almosphericool~

vacoom BottomsLine - pipe hangerfrom unprotected beam, bolt on sccoct

clamp nol secure, no cercrceem. andas ye~ no EIV on column bottom.

PVAY-4 v acccrn Unit, Compromised structural fire protection and temporarysupport in place pending repairs 10structure.

PVAY·4 Corrosion undermsuaucn There is a programme

10 remedy this,

Much still to be oone, especially at Amua.y

Structural Fireproofing on lhe structure of PSAY4, advanced degradation ofstructural fireproofing - to say nothing of lhe probable condition of thesteelworlc it encases,

POVSA Centro de Refinaci60 ParaguanaRecommendalions Update

First Draft Dale 0300/20"

Card6n C04 Fire Repairs

Highly congested and confined area of pumps, re-eers exposed l:¥concrete spalling on underside of upper (exchanger) deck, not clearwhen (if) these are to be repaired.

New pipesupports - not fireproofed

Emergency Isolation Valve added to baseof column.


First Draft Date 0300/>0"


Jett ies

Amuay Jetties: Compact, Congested, incident on one likely to affect neighbour, in addition to the vessel on theadjacent berth,

Relatively narrow jetty, ships close together.

POVSA Centro de Refinaci60 ParaguanaRecom mendations Update


Hose handling Gantry - LPG hose (nearest) has not beensupported l::¥ rotst, LPG line has motorised vatve, locallyoperated.

Ref 2012/1

Mari fold valves for most products are manual,

Adjacent jelly 4 has creesen Arms rather than hoses. Recentlyupgraded.

There are 2 clamps on the Kerosene line, to be elim inated at next TAMin 2013

Many clamps on fire-water line, being replaced now (see new P'pes)

POVSA Centro de Refinaci60 ParaguanaRecom mendations Update


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Card6n Jetties: \Nell separated, ships berth both sides, wider access ways and jetty heads than at Amuay.

Emergency Isolation valve,failsa fe, (air 10 open, spring toclose) some confusion ebcutag ~, fireproof cover notreplaced, actuation f rom localswitch only.

Complex manifold, some motorised varves, most manual.

r-------"""----, Mix of hoses for whiteproducts and articulatedarms for LPG


First Draft Dale 03 00/20"

Ref2012/139 0f 54l!lQBE

Remote operated steerable elevated foamlwater «crecr.

Foam sokncn rnamolds and air ventcns rounder-deck foam curtian

Hose w~h spl~ outer vulcanised layer,and rose to replace it (see test dale00-

Rflf'lskPOVSA Centro de Refinaci60 ParaguanaRecom mendations Update


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Terrp;wary 5I.... o;.-..ts '" l jed 10 original steel stru::tln, restW1l onnew ccocrete sU>stNctU"e whle corICl"ete repaced.

Under-dede structure e~lensively repecec

Slbstarnal sections ofUpper Hose Handling Structure replaced.

FOVSA Centro de RefinaciOn Pal1lgJlln&Recommendations Update

First Draft Date ro "" 2OU

Ref20121139

~Report ~PDVSA - Setty's notebook · This report follCM's ',(sits to the PDVSA Centro de Refinacl6n...

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Transcript of ~Report ~PDVSA - Setty's notebook · This report follCM's ',(sits to the PDVSA Centro de Refinacl6n...