Reporte Amuay
Transcripción
Reporte Amuay
~ /'Risk E ' . RJf:7 ng,neer'ng QBE Risk Improvement Recommendations Update r ~ Repo rt ~PDVSA ./ Centro de,B.efinaci61lE-<!r.aguana Estado Falc6n Venezuela Recommendations Update Visit Made: March Prepared on behalf of s th..gl h 2012 ~ QBE Marine and Energy Syndicate 1036 Plantation Place 30 Fenchurch Street London EC3M 3BD Prepared o n be half Of : e by Roger Gregory 4 Heat h Vil las Plumstead London SE18 1PG Ref.201 21139 ,-Risk , . . RJf7 rl!llneer'"9 rr Phone +44 (0) 03 731 1 16 k.. mail roger kb§aol.com_ Contents 1. 2. 3. 4. 5. 6. 7. Basic Inform ation Values llt\d Estimated M aximum Loss Summary Company Administrative Strudure Changes Operational status and Significant Events Maintenance status and Signitcant Events Inspection Status and Significant Events 8. 'recrmcasevces 9. 10. 11. 12 12.1 . 12.2. 12.3. 12.4. 12.5. 13. Safety. Fire Protection & Securi ty Notable ~cidents Loss Estimates Update: Risk Improvement Recom mendations Update R ecomm enda~ons from 1993 Survey aeccmmencauces from 2002 Survey Recommendations from 2005 Survey R ecomm enda~ons from 2007 Survey Recommendations from 201 0 Survey ..... Observations Cgyer Picture: PVAY-5 at Amuay. 3 4 5 7 7 7 9 13 14 15 17 18 22 23 'ZT 30 36 46 .. 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 recom mendations made by Uflderwriters' risk engineers during thK sulVlly ',(sits in 1993, 2002, 2005, 2007 & 2010. • also contains infonn ation on the reported operational status of the various units. significant operational events, significant m aintenanoeflO spectioo events , detal s of any nctable incidents 0( accidents reported to the risk engineers during Ihe survey, and an update to the estimated maximum loss. Forfurther tadual information on key details of the risk, referenoe should be made to the Risk Engineering Report from the last full sulVll y carried out on behalf of OBE in Odober 2010 The authO( retains drawings. photographs and other documentation, acquired Vitlilst carrying out the SU lVlly, Yitlich can be made ava~ abl e 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 t o negligence) arising out of 0( in connedion with this report shall be excluded absolutely. • is acknowledged that this repat is not intended to identify al hazard s which may exist nor is it intended to be an exhaustive re',( ew afal possible eventU alities. Any recommendations fO( risk improvement contained in the repat are purely advisory and the decision and responsibilay fO( implementation rests with the site's managemefi. Responsibitity fa underwri1ing decisions rests with the underwriter in all cases. No responsibla y can be taken for the accuracy of any inbrmation that has been provided by the client. (the assured. the broiler a Ihe underwriter) fO( the purposes of this report. .#-"" a BE Disclaimer report hCl$ bu n provided solely to provide infr,"notkm to UndelWritel$ l7bout rllt /odUties referred to in the report ond rhe projed monogemenr $)Istems in operotion at the fod iitits. for tilt purposes oj rhe UndelWriters' risk =essmenf. The report gives the opinion oj a BE UndelWriting Limiredin resptd of tilt expawre to the inwred ptr~s, the quolity of rhe loss conrrol measures in ploce ondmoy olso make recommendarions for ri5k improvemertf. This The recom mendotions submitted in rhis report (if ony) ore purely odvisory and ore for rhe purpose of l7ssisting rhe Insured in risk control ond soft ly ossessm ents. It 1$, howe..er, not irtfended re imply thot no other risks exist or rhor no other prtcou!ioru need to tit roken. No guoronru is gillen as ro the occurory, viobUity or rompltt:entSS of ony oj tilt recommendations 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 ony k1W$, reguklrions, code$ of procrice or ony orherlegol or Industty requirement or I}llidance opplying to the jocUitits. QBEUnderwriting limited occepts 110 HobHiry whorsoever for ony erTOl]' or omissions in the report or rhe consequences of reHonce on the inform ation provided. PDVSA Centro de RefinaciOn Paraguana Recommendations Update 01 First Dr.IIl Date 03 ':lI'2 Ref201211 39 o QBE Page 2 0f54 ~isk I Basic Informalion CLIENT ORGANISATION COMPANY SURVEY ED LOCATION VISIT DATES VISIT LEAD BY: A LSO A TTENDED BY PRINCIPAL COM PANY PA RT ICIPANTS caa Marine and Eller S odicate 1036 Petr6leos de Venezuela Centro de Refinilci6n Paraguam1 (CRP) Amuay and Card6n Refineries These are ess entially two refineries, operated as a combined system. Man~menl . maintenance. etc are common to the two. 5 108 Mardl2012 liP- Rog er Gregory Engl"••r1n g for aae M arine & Energy Syndicate 1036 David Dalla Costa Ch artis, Madrid, e....c e , OmarJ Bravo C RP Gen eral Ma nager jesUs Malpica Te chnical Rcnald Pella Seguridad Industrial Ramal Uzcalegui Operations Management Edd ie Miguilene PDV Main tenance Elisaul MOllusl ena Carm elo L6p ez SMC Management Process Management Amuay Ricard o J . Ramirez M. Process Eng inee r Manager Operations CardOn Ruben Bos~n Zoilo Roo an I Maintenance Luis Heredia Wlliam Medina T echnica l Finances Operations Luis auerc Hector Martinez Alberto Rod riguez Pedro Suarez Felipe Semeoo Fidel Fuenmay«e Francisoo Montero Nelly Rivllfo Ramon Cosi Jose V argas Oscar Salazar Angel Ouintero Denis Ruiz Luis a Lugo Juan Joe Ram ir ez Alexes Bra cho a . Gennan Buslus rsc S IHO GSA Card6n Operations SMA Man ager ROI.tine Main tenance A muay Operations SI HO PCE Te ctlni cal Maintenan ce Maintenance Tectlnical Industrial Safety Industrial Safety PCE Operations Industrial Safety Ja~ erGoi~ a Finan ces Marilza Vallejo PDVSA Cap orale Insurance Coop er Ga y , London sarah Cl affey Coop er Ga y , Colombia Dian a Renfi go Con tributions were made by othllfs du ring th e presentations on recanmend ations and the brief site tour. I Rog er Gregory Svndicate 103 6 SU PLEM ENTED BY: PLANT A DDRESS: PLANT TY PE A ND CA PA CITY : LAn TU DE, LONGITUDE, EL EVA Ti ON & AR EA: SITE SI TUAnON PDVSA Centro de Refinaci6n Para gu ana Recc mmendaacos U pdate First Draft Date 03 0l11O ' ~ R#1II< En gi neeri ng on behalf ofaBE Marine & Energy Market Report by Roger Gregory R~ En gi n eerin g on behalf of aBE Marin e & Ener ov Svndi cate 1036 fran \.lsit dated octcbe- 2010 Punto F-o, POI uana. Estado Falc6n , Venezuela Amuay: 63S,()()())op d, 'Nith distillation, lubric ants, hydrotreatment, FCCU , HF alk yt a~on , delayed coker and flexi cok llf (FCCU ). ;~~6n: 3OS,OOObopd, with distillation , lubes, h ydrctr eat ment, FCCU, H F aJ lation , lscmerisetlcn. delayed ecee -. Amuay: 11"37.8'N, 070 "13.3'W. Elevation 5 10 21lTl am sl Area .. 38llha , Card6n : 11"4S'N, 070 "11.S'W, Elevation 5 to 21lTl am sl Area " 420ha Coastal sites, 14km ap art , on sou th-west comer of Paraguana peninsula , on the Gafo de V enezuel a, Ugh! popul atioo , no significan t adjacent industri al exposures. Ne arest town , Punto Fij o, ap proximately midway between the two sites. Re f 201 21139 o QBE Page 30f 54 2. Values and Estimated Maximum Loss IN SUREO VA LUES : US$x1 Property damage Comme....s Card6n: 10 .625. Nnuay: 11 .829. From Febl\lary 2010 valuations by Advanced Appraisals (Brazil) . Increased by 1.5% for 2011 . Includes equipm ent, construction , and Foundations , Vtry sign ifican t increases in value s since the 2007 valuation by the sam e company (Card6n USS 4,843 millions, Amuay US$ 5,843 millions). The recent valu ations haw been accompan ied by a detailed site layou t showing th e location of eacnuen. Business Interru lion Boil er & Mach;,ery Damage Not Covered AssllfTled included in Property Damape sumsinsured. Contin ent BI Not Covered US$)(10 ~isk Loss Estl mMe: Property damage Amuay 3 ,356 Comment s HF Alkylation Iscmerisalion Section DIB column Overhead Receiver l00tonnes. Cardon 1,408 61from PO MB 61 from MB PDVSA Centro de Refinaci6n Paraguana Recommendations Update 01 First Draft Dale 03 /101? 16 Card6n Alkylation 21sornerisalion Section DIB column Overhead Receiver 100 lomes. Similar estinale results from 37.1 tonne release In FCC Gas Plant, Not Covered Major un-contained rotor fa ilure of one of the three ex"GENEVAPCA" cas turbo-aKemators Net Covered Ref 201 211 39 o QBE Page 4 0f 54 3. Summary The main purpose of this vis~ was to obtain information on progress 'Nith respect to the risk improvement recomm endations mad e d~ng underwriters' risk engineering swveys in 1993, 2002,2005,2007 & 2010. In we have included details of signi ficant changes or events in management stNcture, in operations, projects, i1dd~ial . maintenance and n scecr co. detals of reported inci dents involving leaks. fires. or explosions. and an update of the estim ated maximum loss based on any reported changes to insured repl acement cost values. At the comm encement of lhe survey there were 22 O\tstan ding r ecom mendations comprised of a total of 46 uncompl eted action items, and oflhese item s we are able 10 report 16 ( 35%) dosed, 19 (41%) in progress, and 11 (24%) with no progress. Reference should be mad e to the October 20 10 underwriting report for further details of the risk . only cnang es an d events of ~ nific;ance in are reeceeee in the descriptive body of the report. In particular, details of values and the development of the Estim ated M aximum Loss are unchanged, wi th the except ion of a small "indexed" adjustment to values advised b y the d ient. Overa l , w e see some positive progress , aRhough we continue to rate this large refine ry complex as "in need of improvement" as in 2010, A stronger "proa ctive" approach is necessary in our opinion , The oven JlI c ompany struct ure for Refining is essentially unchanged. A new M aintenance Org anisation "Planificati6n y Oirecci6n Ven ezuelan a de Mantenimienlo" has been set up to stre am Wne Ihe planning and execution of m ajor m ainlenance at the PDVSA fad lltles. Th is is based at Paraguan a. Prod.lct ion al the time of our visit was SOO.OOObid at Amuay (nam eplate 635.000b/d ). with all un ~s op erating except the A exicrack er (FC CU ). Alkylation , Depentaniser , rscn et seucn and on e Sulphur Recovery l ra in. There ar e thr ough put lim~ations on Cru de Un ~ 1 vacuum feed fu rnace. Card6n is operating at 195,OOObJd (namepl ate 305,00llbId), with the largest Crude Un ~ C[). 4 and associat ed vacuum uni t shut down following Ihe February 5"'fire on C D4, these should re-start very shortly, Sulphur Unit PRA-3 is shut down, Jetty 1 is in rep air ~Howing the Octob er 2010 fi re . Major m aintenance (turnarounds) has been seen 10 be suffering from delays, typically of one or two years, supported by "Technical Operation al Evaluations", These large refineri es . wi th a multiplic~y ofun~s have many should give operat ional nexi bil~y to ta ke un~s ou t for maintenance. It is hoped that the new "PDV Mantellimiento" wi ll reverse the trend of delays to major mailltella-oce . ROlIi ne mai ntenance suffered a significant "low" in 2009 , the effeds of'Hhich are still being felt. evidence d by a m arked increase in the ratio of corrective to preventive m aintenance . The effeds ar e also evident in the maintenance backlog partiaJlarly for pumps and molors, and in a higher tha n larget proportion of "Em ergen cy" and Urgent" work orders. Howevef. it is encouraging that these figures are being reported to management. Procurem ent remains a significant challenge, aRhough proprie tary pump sea ls are avai lable. There is a continuing effort on the struct ural int egrity pr09"lUTlmll , wi th good evidence of progress, however it is recogn ised thai the scale oflhe problem on these "aging assets" rem ains a high priorit y. This inclu des the reroeeocree structur es, steel structures and their passive fireproofing . It is noted that many uni ts yet to be tr eated are making use of temporary support slnJctures , and thai these are nel fireproofed. I is also noted that the work of temporary construction and r eplacem ent is carried out as "S IM OPs" (i e. simultaneous structural work on an 2el!rating uni t). Inspecti on rem ains org anised as before, but wi th some add~ional own- hire staff. On stre am inspection is by a local contractor (Inspfalca ) wh o also provide s scaffolding etc. Analysis rem ains b y PDVSA staff. and "S ILCO" is used for scheduling , recording an d analysis. A ceresco Under Insulation plan has been commenced. prodUCW1g manuats of CUI prone areas and inspection plans. There have been vertjca~ty and thermog raphic inspections oftJ rnace sta cks. and this pl"ogra mm e is aactually running ahead of schedule, Off-Process (Outside Battery LimM) pipewon< has now been included in "S ll CO" . stornge tankS are inspected on "Risk Based " criteria . tan ks prioritised , and inspection s being carried out on "High" and "Very High" risk tanks first. Typically 26 tan ks per year at Amu ay and 34 per year at Card6n are to be insp ected -this is intend ed - in lim e - to elimin ate the presen t Sl.lbstantial back-log, PresSl.lre vessel inspections are said to be fully up-to-date, and included in "S ILCO". Pipework insp ection records were viewed for the Amuay PVAY"4 v aensn Column Overhead circuit and Bottoms lines. These w ere easily found , and the inspection re cords were avai lable back to 1986. We were concerned however that no basel ine insp ection had been carried out following a significant replacement and change of steel alloy. tha t the m aximum 2 year cyee had not always been kept to, and that fer the evemeae circuit, wher e there was knONn signific ant thinning of the pipe wal to the extent th at remaining useful ~fe was short and a "sp ecial watch" had been scecaec . there wa s no attempt to check any of the many "dorm ant" TM L zon es, PDVSA Centro de Refinaci6n Paraguana Recommendations Update First Draft Date 03 0l1~ , ~ Ref 201 21139 o QBE Pag e 50f54 Techni c al Services eeitnue to be involved in projects, monitoring of process "exa n sions" etc , an d there is a major Alarm Management exercise underway. to address the knCMTI problem of alarm "ovel1oad". TNs project . in our opinion , r equires more formal~y. Safely (SIHO) continues to aud ~ permits towor1< and to carry out detailed aud its . and repoo improvements il some areas of compli ance. There has been ina-eased tra ining of issuers and receivers of permits and other topic s including housekeeping. The "S1SA" datab ase Is used to prog ress recommendations, and although there rem ains a larg e number of open items, it is reported that thi s has been reducing . There is a "DJ po nt" inspired "manual of lessons from past events. with "Best Practice" exemplars as well as analyses of ilcidents. Includes process associated events . PTW. LoTo. etc . Fire Prot ection : Organisation unchanged, firefighting equipment: now being added to "SA P" mainten ance schedulilg . Many r.ew fire tru cks have been received . and old ones are being refurbished where economic. Fire pumps still do not comply with annual crrve testing, and recent test s shcm lw<:I of the diesels at Card6n . afthough operating , have deficiencies. There is a corporate initiative forthe inspection and m aintenance offirefighling and detection apparatus . (S ICOINE database). lMlen fuMy populated , this will replace the present paper system, which is being operated in para llel Security : has been m oved from Operations to the S afety and Protection group. and there are investments in progress to autanate the access control system , the ilter-s~e canmunications, to Improve perimeter lighting and to build the National guard a neN "Reaction Centre". Incidents : DJring 2011 there were 222 incitlent s reported , ilclud ing some 100 fires, many of these being in contamin ate d pipe trenches . At1hough there is a good procedure for incident ilvestigation , we were disappointed to not that few had progressed past the stag e of settilg up a study committee, an d only 9 w ere "closed ", wi th recommendations carri ed out. Specific ilcid ents since ~ 201 0 visit described to us were: • 11109/2010 Card6n Jetty 1 fire - Burst Kerosene Loading Hose. • 15/0 312011 Amu ay HDAY-4 86,ooObid Gasoil Hydrotreater Explosion - CUI on Hydroge n line • 2410512011 Card6n 77 ,OOObld FCC Fumace Explosion - Explosion during re-start following ilstrum ent air loss. 0610&2011 Amu ay HYA Y-2 9.Smmscf/d Hydroge n Plant (Reform er) Furnace F-SS1 Explosial - "Plugged" • tub es, not dried OI.lt, exploded and ruptured a ~acent tubes. • 06r'01f2012 Cardon Platformer "Incipienf fire - radiant area leak following significant overtemperature. • 0910112012 Amu ay PVAY 27,300bfd Vacuum Un~ Unsafe Caldition of Furnace F- 100 - Collapsed re fi"actory and carcase distortial • 05/0212012 Cardon CDU 4 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 ther e is no apparent common cause. PDVSA Centro tie Refina ci6n Paraguana Recommendations Update First Draft Dat e 03 0l1~ , ~ Ref20121139 Pag e 60f54 l!l QBE 4. Company Administrative Structure Changes The company structure as applies to refining is essentially unchanged. There is a new group ' PDV Mant enimiento' , (Planifical i6n y Direcci6n V en ezu elan a de Mantenimi ento) intended 10 have a national scope, 10 address the challenges of m ajor m aintenance in the Oil, Gas and Petrochem icals ad i,,;lies of PDVSA ilod by extension, others in simH ar fields. (See "Maintenance" below) A "Strategic geseve' of about 50 engineers representing all discip6nes. (esp ecially electrical and plan t) has been fOllTl ed , on a two year trainilg cyde , and these are currently wortil'lg "..,der super'>1sion. There was iI rump of retirem ents in 2010, retirement can be at age 50 , but can extend to 65. and there are typically OeM' 20 to 25 retirements pre year on an overall staffing level of 4360 (direct hired). This includes the power & steam g enera~ ion fa c ~ity ' Genevapca" which was absorbed into the company structure, but does not include Ihe marine operations or the "Bariv en" staff second ed to CRP . 6. Operational Status and Significant Events Presen t 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 (DPA Y) . lsomerisation (ISAY) Ugh t Ends Recovery (GLAY) on m aintenance since 21" January, 'Nith a planned oiI~ dat e of 15t!l April . The CW'l1~ changes have been reliabilit~ improvem ents to large rotating m achines. no changes to processes or tech nologies. Kerosene H~drotreater(H DAY- 1) was shu t down last w eek to decoke the catalyst beds; Sulphur Recovery 3 (SUA Y-3) is not operating . Crude Distillation Unit PSAY~1 had a tube fa~ure in the F3 V acuum Feed furnace .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 rat e (design is 305kbld), with th e largest distina~on unit CD- 4 shut down due to the February 5"' 2Q12 release and ire ( see "Incidents" be low), In consequ ence , V acuum un~ AV-2 shut down. These should re-start during March 2012. The PlatformerlHydrolreater developed a furnace F301 tube leak an d was shu t down 6"' January, re-sta rted 12"' January. Th e FCCU sull"ered a "steam valve" event 21)" Feb rua ry, and was shut down for 3-4 days. Alkyl a~on unit 1 had been shut down for more than a year , an d r estarted end of JanuiIrY. The Feed/Product heat exchanger M 100 1 has an intern al leak , although this is reported not to be affecting production rate or quality. Sulphur recovery un~ PRA -3 is not op erational . Rep airs to Jetty 1, l'<t1ich suffered a serious fire in October 2010 (See "Incidents" below) is planned to be completed to allow operation to resume by th e end of Aug ust 2012. 6. Maintenance Status and Significant Events The princip al change to the main tenance organisation has been the sep aration of M ajor Maintenan ce to be the responsibility of a filial group "PDV Ma intenimiento" ( see below) . Operational maintenance remains wi thin the CRP organisation. There ar e 8 groups reporting to the manager of maintenance at CRP - Planning & Contracts , WorKshops , Routine M aintenanc e Card6n . Routine M ar.tenance Amu ay, In strumentation and Control . Special Equipm ent . Materials (stor es), and Assistance I Management. aeeeteat M aintenance Is tceetee in the Operations Department, 'Nith the excececn of Electric Motor m aintenance , l'<t1ich has as own workshop in Mainten an ce Dep artme nt. The 1oIa1 number of workers in the CRP mainten anc e organisation as at January 2012was 1139. We do not have figures for vacancies. The ma intenan ce ph ~ osophy Is essentially unchanged, Preventive - calendar or cond~ion based, Corrective for failures, m aintenance projeds to optimise performance or eliminal e root causes of failures, ail within C RP m aintenance, and "major m aintenance" now with PDV Maintenimient o. " PDV Mantenimienlo" , (Planificati6n y Direcci6n veoeeu eteoe de M ain tenimiento) is a sp ecia~st mainten anc e group head ed by Sr. Jesus Luon go, he ad of Refining G roup . and as such comes und er the overall man ag em ent of CRP. The decision to form th is group was taken late in 201 0. in response to concerns about delays to and costs of major m aintena nce to th e PDVSA assets. Presently there is a staff of 134 engine ers iII1d administrat ors, 'Nith a creo tc increase evenlu aly the hea d coun t 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 M ain ten an ce , an d the pro>Asion c r a stock of necessary toots and accessories (cranes, wel ding sets, scaffolding etc. -i nvestment in this areas staled to be in the order ofUS$ 25 millions). The grou p is run b y a board level "Junta Directiva", and reporting to this are departments for Administration . Planning . Operations (i.e . responsible fOf execulion of maj or maintenance worK on Plant and Equipment. net plant operation ), Technical . (who are responsible for standards , compl iance, engineering techn ical disciplines), Contracts (10 m anage third part y works), Finances , Services & Logistics. PDVSA Centro de Refinaci6n Paraguana Recommendations Update First Draft Date 03 0l1~m Ref20121139 o QBE Page 70f54 ~is* 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 tim e ij will have branches at all PDVSA main sees. Note that "PDV" In the t ~le Is "Planlficati6fl y Direcel6n Yelezuelana" and not -seecrecs de Venezuela", and lt1 at the long term aim Is for the organisation to be availa ble for other industries in addition the oil , gas and petrochemicals secta. To putlt1e Major Mainten ance challenge at C RP Into perspective, there are some 83 process lIfl~S in the Card6n - Amuay re fineries , plus offsites and cuutes . and je tties, In a typical yea r, there are about 37 major maintenance interventions (turn -arounds) , and this may rise to a peak of 54 In some years. The contract awa rd process Is stili essentially as before th ough, with a need to comply with the laws of Venezuel a, 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 control the oil-out to olj-in duration and to keep wilt1ln the maintenance objectives. Key Maintenance Perlorm ance Indicators are presented annuall y to man agement In a "Rendid 6n de cuentae'. The foUewing are extracted from recen t "Rendid ones", Maja mainten ance (Turnaroun ds) costs since 2008 have been: • T Partial Turn arOUnd s General Turn arounds Cost (USS Millions) 2008 2 2009 27 12 477.85 388.66 26 2011 12 20 10 12 , 3 432.91 314 .30 The emphasis in 20 11 has been Amu ay, with Sulphur Recovery SUAY-2 & 3, Add Gas Recovery FMAY- l , Sour Water Tr eatment SWAY-2 & 4, Gasoil H ydrotreater H DAY4 , Reformer HYA Y-1, TSAY, and Jetty 2 at Amuay , plus Sep Tap 3, S eparator 1, th e CCR Platformer and the Jetty 1 rep airs at Card6n. The origin al plan for 2011 was staled to be for 2J General Turnar ounds and 2 Partial Turnarounds. The original budget for 20 11 was reported to be in excess of US$ 1 billion . ovear. compliance with lt1 e declared turnaround intervals for l he various plants has been variable, wilh plants set at 4 years being run from 2OC6to 20 11. Many of the unils thai were scheduled for turnaroun d In 20 11 have been postponed Into 2012, wijh subsequ ent me-eases In run length , follewing a "Technical Operalional Eval uation". Thts evalu ation focuses on operational issues wilt1 the most oritical equipment , mostly concerned with Dynamic rather than Sl atic aems. A few examples of postponements are given below. ~ . c.""" c.",., ""'. ""'. ""'. '"" CD--:VAV·3 HDT- l >JAY OCCAY HOAY2 Oescl1ptl on TAM lnt w s ,, ,,• Crude ~CU..., Units GIo soil H rClreat.... JlJ lOtion Cal Cfll~jg-IOc;k ", DistiIllltes rot reat. Last TAM ~"'" "" 2007 0" aoos 0''"'" 2007 "~ .. TAM JunIl2011 J~11 Se 201 1 Postponed TAM ~2012 J 2012 S. 2011 Ma 2011 Feb 201 2 JIII1 2012 20" Maja maintenance to the jetties al Am uay has been sig nificantly Ialer than the 8 year interval speci fie d, with Jetty 2 having had ~s turnarounds in 1998 and 2011 . Jetty 4 at careen had ~s last turnaround in 2COD, and has l he next planned fa Iale 2012. Fa Jetty 2, the last turnar ound was in 2006, and the next will be planned for 2014 to 20 16, atthougtl ~ Is ha~ng replacemen ts and upg rades to serne of ils fire-fig hting mains and apparatus. The costs for routine mairt enilnee since 2008 have been : Typ. Corrective Preventive Mixed Tot als : US$ MiIliollS 2008 94.298 116.396 13.830 224.526 2009 66.950 49.962 2.105 119.0 17 20 10 97.802 7 1.456 2.470 171.727 2011 193.644 95.551 1.021 290.215 Prior to 2009, l he 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 about 50% up to 2009 to 67% in 2011 . On a work cecer bests.uie proportion is 69% Corrective to 31% Corrective. urs Instructive to nol e th at the low maintenance spend in 2009 has been fofl~d by a mar1<:ed deleria<ltion In lhe corrective/Preventive ra tio , The target figures often stated in PDVSA are 20% Corrective to 80% Preventive, PDVSA Centro de Refinaci6n Paraguana Recommendati oos Update 0l First Draft Dal e 03 /:;,m Ref20 121139 o QOE Page 80f54 ccmp rence with maintenance programmes and backlog fof the whole of CRP is summarised below: ',,, CompiOlflOll Pnl"""ti"" PlrnJlS e nd BI"",on Terget >90'lIo Complie""" Pre.",,1MI Sped... (T\rtXImeenne<Y1 T"'9"1 >9 ~ lwe _ 85%) Compl" """ Pnl_~"" ...iI....."e.... T"'9"l >918% Compl" noo Pnldlct"e PumJlS To'll<'l >90% BacId<>sI Pu mJlS in V'i<J<1<shop (Nos)Av..-_ BacId<>sI MOIors ,n Wor\«;hop INos ) AII""'9" T..-gel <1:l'5 T"'lJ'Il <75 Backlog ExCll&noeo> (NoS)AII""'9" T8l'geI <20 Compl" """ wilIl VVe&l<ly P lein Te rgel >8S'Mo (merHlO.... D8Se<l) Wlrk Orders by Pm nly( EmOfll8rl<y\Jrgo>rf.4'lol.trle) T"'lJ'Il <~< 15->80 ComplOl""" Ma rt"".""" Prog , Me;or EQl"pmert ('Mo l 1"'9"1 85'llo '''' ee '" se "" "se 98.22 96.12 9S 13 ss a ." '" '" M '"• 3-1lHl1 "'" '" '" "ss U. -..Isble ~~ 9.5-1 5.5-15 s.as.se " " " Ullll\lalsbl. "" '" "" as 83 ,3 ""ss " sa ss asa " The principal reasons given for the worsening performance wi th respect to pumps and meters was insuffici ent resources , difficulties in placing and cont inuing contracts, and the procurement of spare parts . During 2011 . the contract wo rkforc e accou nted for some 3 m ~lion man-hours of waX , implying an average ecorract workforce in the order of 1,500 for rouijne maintenance acti\'ities. Spares procurement lead tim e for National purchases are typicaly average 30 weeks, whereas international purchases 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 are critical to the integrity of conta nment systems. there are technical support and supply contracts with proprietary seal menutactwere, organise<! throu gh ·Bariven " the P DVSA procurement organisation. The suppH er (John Crane ) has a base at CRP as a first point of contact , and as a fa B back Bariven will deal with John Cran e USA. overa r . there is clos er 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 the instrument finds ' oc fault " in the lnstrcmeot . Operators have been trained to recognise problems, and confidence in the e seu meres on the part of operators is therefore seen to be growing . There has been significant w ork on remediaticn of the structure s both at Amuay lind Card On . This has included repl acement of steel and ferroconcrete structures, and the remed iation of detatched fireproofing On steel structwe s. TempOl'ili)' supports th at had been tntrc euced as emergency measures have generally been lell in place , and are redundant, a~hough they are likely to be removed for use elsewhere on the refinei)' . We neee that wh Wst the temporary structlXes were in place , they were nt1 fireproofed. At care en. work is completed on the Furfural Extraetlon Un~ , vacwm Distillation 1, Vacuum Dist mation 3, FC CU , 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 pump house and audiary pumphouse , the pipeway bridges . and Jetty 4 in March 2013. Significant ether repairs are planned in 20 12 for the Hydrt1reaters, MEK De-Wa x ooit, croee Distillation 1 and Alkylation 2. At Amuay, wo rk has prog ressed on PSAY-3 crude Ul'lit. PVAY-3 Vacwm unit , PVAY-5 Vacuum Unit , NFAY-5 Naphtha Fracti onator, PSlFVAY-1 CrudeNaaJum oo ~ , HDAY-4 Kero Hydrt1reater, and waX is planned for the DCAY Flexiaack er. We ncte hCM'ever that much of this waX Is carried cot as a "SIMO PS' actMty 7. Inspection Status and Significant Events There 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 her e SOOn, plus a further 2 as Corrosion and Materials 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 th e field u~rasonic measurements, the contract includes the measurements and the scaffold ing reqlired to do access the measurement points . The contract Is on a 2 year cycle , due to expire May this year, and CRP is in the pr ocess of negoijat ing the nl!'W contract wh ich (hopefull y) wil be in place before the expiry of the old ecneee. Analysis of the readings is carried out by PDVSA staff. PDVSA Centro <Ie Refinaci6n Paraguana Reccmmendae cos Update First Draft Date 03 0l1~ , ~ Ref20121139 o QBE Page 90f54 ACorrosion Under Insulation (CUI) plan was commenced inOctober 2011. The aimis to produce aCUI Manual specsk to each un ~ onthe refinery , and there are 5 phases tothe wort: 1. Technical Concepts (refereoce codes: API 571 ,NACE International, Shell DEP 30.46.00.31 Y PDVSA PI-D2- 09-04) 2. Idenlificalioo and classificalion of thermicaltt insulated lines 3. Development of lecmetrc Drawings of H ~ h Consequence lines ~unc lion of pressure, temperature and malerial contained) 4, Data Collection 5, Consolidationof information and identification of inspection facil ~ies . The plan is to complete all the manuals by the endof May 2013, To date,progress achieved is 14%against a pla nof 27%. The manuals specific to the Furfural Extraction andMEK Dewax unjs (lUbricants) are reported to be complete, and a planhas been developedand executed (clamps added) for the three Hydrolreaters followingthe March2011 HDAY-4 incident (see "Nolable Incidents" below) (Note, the HDAY4CUI incident was inMarch201 1). There has been a programme of Visual, "verticality" and thermographic inspections of thechimneys of thevarious furnaces and fired heaters onthe refinery. There are approximatett 35 furnaces at Card6n and 50 at Amuay. Inspectionscoverthe carcase ofthe chimneys and lheir dueling, refractory linings where rtlled, painting, guys and other external supports, and produce comprehensive tabular database reports. (example below) The plan ,phased over two years commenced November 201 1, and is running signirlCantly ahead of schedule currently (40%versus 15%planned). OPO... R ES~TAOO DE INSPECCKlN YlSUALDE 'lAM Dl!TWlOGW\lsO!CilJf'IW WI~ Mom Dl! 1lW<viEs ElIt'10 2Q12 CIIW£AS ' 00Il1 ~ 'lUllI'U 0(0&1' IliCllltl _. - ..... - ..-. .. - -_. --- .-- .. - - _. _ . . _.- - - . ....-- -- ---_.'...__.. _....F~- r---:-__....._......_... - 1- 1-1- '- 1- 1 ~ ' •- •• w • , • • •• " ...:0...".: ,• • La< .,::,:- -:: . ,...,., fIlSlII. ' IDDIlIl ~-:.:.";"': F -·- - ··0ISl1NlD&S . _ - ~._ ... , ...._.- _'--~ .., __ r. •. .'- - " ," .. _ •• .,. ~ ._ .. _ _ .._ n Outside Battery Limit Pipework between unrts and storage wi1hin the Amuay and Card6n sjes, and servingthe ;ellies have been indudedin the "SILCCW schedufing, recording and analysis tool. It is reported that all lines have now beenincluded. The lines between the refineries are surveyed by Security for interference or incursion. Low PressureStorage Tanksare inspected on a"Risk Based" approach. There are 6 phases: • External evaluation, Visual inspectionand historical review • Repairs database Actualisalion and development of existingdatabase, creation of dynamic tables • Failure Consequence Analysis Based on characteristics of storage, material stored, safely and operational factors • Failure Probability Analysis Corrosion & Operational History, location & design. PDVSA centro de Refinaci6n Paraguana RecommendationsUpdate First Draft Date 03 0l/;.:u12 Ref20121139 •• • •" iil-- - - - - - -.•• ~~" •• • · " Page 100f54 o QBE R;ttisk • • Analyse Risk Lewl failure probab~ity and consequ ence considered . 5 x 5 ma trix , risks classified in 5 grades from "Very Low" to V ery High 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 'Very High" risk: lanks. There is no apparent equivalence to the -250 lanks overdu e for inspectionhnaintenanee reported In 2010. Th ere remains t10wevef significant operational presswe on the availabll~y of these tanks for inspeetion and maintenar.ce, and only time will tel if this initiative succeeds. A similar ph~osophy is appFied to the pressure storage spheres and bullets. There is reported to have been 100% comp~ar.ce with Press.... e V essel lnspeclion s (drums. exchangers, columnskowers and reectcrsj, with a lotal of 1719 at Amuay and 1353 at Card6n inspected in 2011 . These are also scheduled 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 column Bcttoms line, Ihrough 10 the bottoms pumps. W e w er e informed thalln 2OO71his had been changed from carbon s eer to 5% Cr Low Agoy carbon steel during a rout ine planned tum-around . No base-l ine wall thickness measurements had been taken . First measurement was in March 2011 , and at that time 2 measurement points (multiple TMLs) were rece-d ed. Reason given was thai it was a cosily exercise, and because an al oy s(eel had been used, the inspeclions were not necessary. Inspedions at2 year intervals are reported to be required forthis duty, and this has not been complied with. Next turn arou nd 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 with S(iffening hoops and support clamps. Initially there were aboul20 inspection poirts . but these had been reduced to 5 based on operational and corrosion experience. The other points. presen~y -frecuce ' in ' SILCO!>' do however have some hiS(oric re adings, 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 a significant loss in the period 1998 to 2000 . bllowed by a continued slow reduction . The remai ning ~fe for the fiYe poirts measured varied from a maximum of 15 years, to a minimum of 1.8 years (for Point 8). and M's iI1speetion interval has been reduced to 8 months. We would queS(ion whelherlh is finding should have justified the reac tivation of 'inadive' inspection points on this circu~? (See illustration s below) These and other lines are due for replacement in tile 2013 tum-afDund . I PDVSA Centro de Refinaci6n Paraguana Recommendations Update First Draft Date 03 0l1~ , ~ Ref20121139 Page 11 of 54 ~ QBE LINEA I} E CA BECE RA I} E VACIO (TOPE I} E LA T- ' SI ) ULTIMA INS PECCI ON D "' - --,""". MID : 1).111 ULTI MA INSP ECCI O N Es p. Mn: 0 .234 Esp, Holll: 0.U5 Esp. Rot: O.I2S • V.U '" -vce util ' (Usefl-i Life) PQVSA centro de Refinaci6n Parag..aana RecomrnendiltlOn5 UfX1ate First Draft Date 03 001," '1 Ref 20121139 Page 12 of 54 :. ~;sk 8, Technical Services Technical Services continue to monitor processes, process variables' deviations and excurs ions, feedstoc k changes in quality etc, consultation on maintenance planning. There Is a major project on the Lubricants units, involving an exp ansion and add ing emergency isolation va lves etc. The drawings used for t he expansio n are still the ' Marave n" drawings from 1994, styled as "for detailed desig n". However, engineers wal k the plant and confirm that the rerevant parts 01 the plant are realistically represented on the drawings. Tech nic al are invo t.-ed in the "HazO p" and "Whal lf studies 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 Lean Am ine specttcauon is 100ppm tota l Su lphu r. There is presently no problem With amine supply. Any shortfa ll is said to be co untered by recocucns in rate. There has been a change in the supply of Natural gas lor the reformer and turtcaltematcrs, and afthough this was not carried out under the manage ment of change regime , an equivalent procedure is said to have been used . There has been an Alarm Management exercise , so lar on crude unit C D-4 In acco rdance With EEM UA 191-1999 al'ld ANSIIlSA 18 .2-2009. Honeywell Event Analys is is being used. The casercetens. In ascending order of &rEB.l e r M U\18\TE ,"5 a n SIM '8 \1 B.lTE criticality are: ' Predictive" (avera9B :56 , maximum • :560 ala rms per hour),: "Robust" (average :560, max imum • :5600 alarms per hour), "St able" (average :560, maximum • ~ " :56000 alarms per hour), "Reaewe" (average :5 600, maximum • < :56000 alarms per hour) • "Ove rloaded", which is anywhere more than "Reactive". (see diagram Irom EEMUA 191, j'4 edition). Oth er criteria in the gllidance include the number and durat ion ct -sreveo- and E~\ IUA191R<~~' ~ "Standing" alarms, and the "Top 10 Load Percentage ". Using these criteria , it has been recognised that most systems are "Overloaded' according to the EEMUA defi nitions , and have been so since 2008. SOme action to rationalise the alarm systems has taken place , btlt not to the EEMUA philosophy , and with no specific budget To a Iar9B extent the success of the present initiativ e depends on the accuracy 01 the P&IDs, afthough the software In the Honeywell systems can be used to del lne the alarm loops lor analys is. 11 is instructive to note that the alarm management study was initiated. At least in part, as a response to the May 201 1 careen Fluidised Catalytic Cracker lurnace explosion. In our opinion , the Alarm Management Programme requi res to be formalised and adequately funded . Alarm System Performance .' ", ...... -,- ,- ......... - There is a plan to Instali lwo " Polyduetos" (multi- product batehlng pipel ines) 10"0 and 16"0 to supply progduets to the Sajo Grande distribution centre nea r Marac aibo. PDVSA centro de Rel inaciOn Paraguana Reco mmendations Update First Draft Date 03 OO'))l2 Re12012/139 Page 13 015 4 ~ QBE 9. Safely, Fire Proleclion & Securily The organisation for the Industrial SafetylHealthiEnviroomenl (SlHO). Seoority (PCP) and Fire Intervention has had a smal l change, with Securty being moved in from Operations. Overall staff establishment for SlHO and pcp is 83, and a further 15 posts await approwl. Safety has an estabhhrn ent of 17, 3 vacancies being Qmenlly fi ~ed by contractors, and additional safety analysts plu s oocupalional hygierdsb are being recueee (part otthe 15 above). The Firefighters have an eslabtishm enl of 64, with vacancies for 2 supelVisoo; and 32 tremen. Safely The ' SISA" database for recommendations arising from audits. investigations or safety reports by others (includi ng the InSU"ers' recomm endations) continues in use. In an, since its inception in 2004, there have been som e 4,600 entries. roughly evenly distributed between Amuay & Cardlrl. On the database , these are recorded as ·CU· (completed) , "EP' <in progress). "CA" (cancell ed), "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 be completed 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 audits per area per year - and wi th the increased num ber of Safety Analysts, this should become achi~ble. Detail audits can take between 1 and 4 days. depending on the complexity of the area under study. Fi particular. considering au dits of Permits-to-Work . which are in our opinion vital to management of safety on the refin eries , the results show som e improvement in th e period since 2009, especial y in work execution and dosure of the permits, although there has been a deteriorafion in performance on permit issLing. The areas re qLirin g and receiving allention in 20 11 have been the risk identification. Safety Analyses (ART), traini ng and authorisation of issuers , executors and receivers of permits. houseke eping, demarcation of work areas and closure issues. These concerns are being addressed by formal training, toolbox meetings , poster campaigns etc. There is also a manual of lessons teamed from past events, This initiative started last year. "Dupont" materi als were purchased, includin g DVDs, on process , chemical hazards, driving, welding e1 c, permit-to-work, LDTD , and shCM's examples of "Best Practices", and where these are no t necessaril y properly applied. Fir e Prot ecl ion The organisation of the fire irltervention forces is essentially unch anged . A pl;ron ed tom the fireprotection group is in the Maintenance departm ent to progress the addition of firefighting systems into SAP. This includes the fixed prot ection system s located on the units and on storage (monitors. hydrants deluges, foam systems and the like). Detection system s for gas and fire remain by extern al contractors and are not included on SAP because they are maintained 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 be refurbished. The new trucks all have 3 ,ooOusgpm pump s and 200Jsg foam tan ks , and are fully compatible wi th the 5"0 Storch connectors used on the hydrants in the "high risk" area s of the site. Fire Pum p testing has not been carri ed out annually (2009 to 2012 Card 6n Diesels , Eleclric pumps tested in 2011). Tests are prOlr-lmm ed th rou gh SAP, so it is unclear wh y they qre na schedul ed in accorda nce wi th the N FPA requirements. 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 and does not open the relief valve. There are recommendations to remedy pump 22, recalibra te the re~ef valve on Pump 23, and to replace pump 21. The Amu ay pump s 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 brou ght into use last year. This Is a corporate initiative, and wh en fuHy populated wil indude all FIRE detection and praection app aratus. So far it is populated only by extingLishers, bre athing appara tus sets. and fire trucks . For the firefighting veh icles, there is a status "li ck 1st", The old pap er system remains in use however. but is being migrated to SICOIN E. Sec u rity (PCP) Security hilS an establishment of 159 to ccver the tw o re fineries. th e marine facil ities and the pipelines between the refineries. They can cal on support from the arm ed servces (National Guard) and arm ed cont ractors . The sites are w ei provided with acc ess control and intrud er detection , wi th an outer cordon plus an inner III'VeI providi ng access to the opera ting units and marine fa cilities. Access control has a database forvali dation of entry through the "badge control led" access points. The security systems are in the process of being autom ated (CECON system ), wh ich should be compl eted by 20 13. Improved communicafions (fibre-optic) between the tw o sites should be completed this year, imprC/\/ed perim etrallighting , and a new "Reaction Centre' for the National Guard. This represents a planned investment of U S$ 48millioos. PDVSA Centro de Refinaci6n Para guana Ref 20121139 Page 14 0f54 Recommendations U pdate o First Draft Date 03 0l1~ , ~ QBE 10. Notable Incidents Incidents 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 , a nd 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 wa s a total of 222 incidents reported (including these fires). Of these 9 were said to be 'completed (fully investigated and recorrsrercatcns carried out, and included on the SISA database), 11 had been "d ivulged" (The Irwestqetc n complete and t he relevant people informed}, 20 were being investigated, and 173 were at the ' Comite" stage, i.e. a learn had been allocated. Rewrrmendations, where made, are progressed through the ' SISA' databa se. Incidents described to us dlxing this visit are: 111091'2010 Card 6n J etty 1 fi re Aviation Kerosene Jet A1 was being loaded via roses to a tanker. The roses had been installed in 2007, and had not been been inspected, although it is understood that some had been repaceo, A hose failed by' a combination of fatigue and accu maaton of tension/compression in cUlVature, this resulted in a cut to the vuceraeeuco reyers. There were two loading PUfTllS started simultaneously, and the resu~ing pressure surge is thought to have cor1ributed to the cause of release. The resu~ing fire caused severe damage to the structure of the jetty, and it rema ins 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 are extensively 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 of repairs 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, shinking in terms of stencilled obvious tag numbers and COIOlK codes, rather in the manner used for lifting apparatus in many coo-nee. Following the meetings, we were given details of a stamped idenlifier on one flange of the rose, and were shown a test certificate whch incidentally was rot dated.. This is not in our opinion ' obvious·. IdenliflCation or testing assurance. 1510312011 , Amuay HDA Y-4 86,000 bJd Gasoi l Hydrolfeater - explosion Operation was reported to be normal. The overhead line to the recycle gas compresso r fa iled (700psig@1 10"F} The reeaee, mostly of I¥drogen i:lnd methane ignited and exploded, Release mecharisrn was extemi:ll corrosion, under insUlation. There had been more ra infall than in the past, and a heat tracing line was leaking, causing condensate to be tra pped 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 DEP had not therefore been fully applied, Mer the event, the CUI plan has been formalised, and similar symptoms have been discovered on the same circuit of two other Hydrolreaters HDAY-2 (Distillates) and HDAY-3 (Gasoil). Clamps have been added where required, and the CUI 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 Paraguana Recom mendations update First Draft Da te 03 00/20" Ref20 121139 Page 15 0f 54 l!l QBE 2410512011 Cardon n ,ooo bid FCC Furnace Explosion Loss 01 Instrument air to a fuel gas varve was Klenlified as the Root Cause, restored flow generated a Mmmable mixture in the combustion chamber, whk:h ignited and exploded, Supplementary causes were alarm Oooding - 350 alarms in 50 minutes (Ihat's an average ot1 every 9 seconds), and the Re-Start procedure was out ot dale. Alarm rationalisation for the whole of Centro de Refinaci6n Paraguana was recorrrrerced 0610812011 Amuay HYAY2 9.5mmscfld Hydrogen Plant (Reformer) Furnace F-851 Explosi on Doring a start-up after repairs to the furnace, there was an overpressure of tubes that had been "plugged', due 10 steam condensate being sealed into lhe tubes, and there being no mechanism whereby the trapped steam pressure colJd 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 a pre-emptive measure, at least one nroe thai was not actually leaking was plugged, hence the overpressure and explosion. Proper drying of the tubes prior to plugging has been recommended. we suggested that holes should be drilled Inlo tubes to be plugged, to remove any possibility of ccessotsenco 06101120 12 Cardon Platformer " Incipient" fire Radiant Area Header leak and small (incipient) fire. In October 2011 there had been an over-tereperanee (850"C vs design 640"q on 5 tubes, operating temperature was lowered and thermography increased to daily and cleaning frequency increa sed, Remaining lire (creep lire of lubes) assessed as very short, and visual rospecncos increased to 9 per day plus 2 thermographic inspections each day. leak was esccvered at visual inspection" 09/0112012 Amua.y P.-VAY 27,3OObJd Vacuum UniUJnsafe Condition of Furnace F"1 00 Deformation discovered on carcase of F-100 rcrrece. Low thk:kness of refractory noted on lower area of furnace, weight of upper refractory had crushed lower refractory, ShI1 down and repaired, 050'0212012 Cardon CDU4 70,000 bid Crude Distillation Unit Fire. «Column aoncrre Pumps suction line small bore drainage connection failed. Subsequent fire caused significanl damage 10 unit, Remains out of action, Emergency tsctaton veves being Installed as part of repa irs - ir installed sooner woud have reduced the consequences. Note damage to t.Odel'Slde 01 second level floor One of the new EIVs AS shown on the "redline" P&ID Note date of "redline", we asked specirlcally to review the rcmace Inciderts that have recently occurred, and Rwas concluded that there was no significanl comrron causal factor -OIX initial concem that this lXII"ortunate r!XI of incidents may have been connected with operating heaters and fun-aces beyond the usefu life of their tubes has not been borne out bt experience. POVSA Centro de Refinaci60 Paraguana Recom mendations Update First Draft Date 03 00/20" Ref20 12/139 . ,, , -_un_ , , ... _~ n n. ~~ ,, __ ,u_ ~ u_ _ n .. n • 11 . Loss Estimates Update: The Estimated Maximum Loss. (EMl ) br insurance purposes. can be defined as th e largest loss anticipated (rom the most severe ecce-renee possible to a location, causing widespread dam age th at renders fi re protection ilnd emergency shut down procedures iloperatiw, or the systems cceate without any changes in the final oulcane of the loss. Only passive physical features sum as spacing , fireproofing , diking, and topography are effective in 'im~ing the loss. At this sile, the mechanism whim has been identified as the worst incident is "Vapour Clou d Explosion and Fire FoIll7Ning", re sulting from an uncontroll ed rel ease of namrn able volati le hydrocarbons foam process system containment, subsequent Ignition , and combustion In the process unjts . Overpressures tom the initial explosion are assumed 10have disabled systems intended to prevent further release or to extinguish fires/eooI structures. We do not consid er 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 will exist the possibil~y of many pctentlallesser loss producing Incidents. Val ues The properties al CRP were revalued by Advanced Appraisals (Braz il) in Februa ry 2010. The total replacement cost values for the two sites as of thai dale were dedared to be: S"' Plant & ~ CW " Eq~ment US$ 9,691B-llion US$ 8.4606i llion COnsb\ldlon Fom oatlons US$ 825 Millon US$ 859 Millon US$ 1.137 B-lIion US$ t.149 Billion 2006 Replaeement as New Value US$ 5.902 Billion US$ 4.843 Billion 2010 Replacement IllS New Value US$11 .654 Bilion US$ 10,468 amen The 2010 valu ation represents a vel)' large increase in the repl acement cost value forthe see. Underwriters are advised to re'View the valuation ~ainst their conception of relative values for refineries of broadly simi lar scale and complex~y worldwide . Full delail of the val uallon WilS given in Appendix AS of lh e 2010 und erwriting report . These were prlMded in Exc el Wor1csneets, and reference the contents of each block In some detail. It has been possible to sum the contents of each 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% acro ss the beard. Site A",::=¥.:= 21111 Replacement as New value US$ 11 .829 BilUons US$ 111.625 Billions We have therefore chosen to not re-run the EML calculations , and have innated the resulting estimated maxinum loss by the same factor. For further details please refer to the 20 10 underwriting report. ... Estimated Maxlmun LM' US$ 3,356 millions US$ 1,408 millions PDVSA Centro de Refinaci6n Paraguana Recommendations Update First Dr.In Dat e 03 0l1~ , ? Ref20121139 Page 17 of 54 ~ QBE 12. Risk Improvement Recommendations Update There are on reccer reccemen cancos made ltJri ng Risk Engineering SUrveys cA ttle Centro de RefinadOll Paraguana made dlling 1993. 2002. 2005, 2007 & 2010 . These were included in the 2010 underwriting repet in bolh Englistl and Spanish. Progess on completion of these reccrnmend ations has been reviewed, ba sed on reports and evidence made available by CRP management 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 been repeteo as dosed falowing past surveys reports lYe eocessee In this report Overall, at the cornmencernent of the survey there were 22 outstandin g reccmmendations conpdsed of II total d 49 uncompleted action items. end of these items we are able to report 16( 33%) dosed, 19(45%) in progress. and 11 (22%) with no progress (See Pie Chart below) '" prollf• • • . 22. ~% PDVSA centro de Refinad On Peraguane Recommendations Update Flrst Draft Date 03 04f201~ Ref 20 12/139 Page 18of54 ~ QBE R~isk .... SUrrnlary of Recommendation Respons es ••f 05.1993 08.2002 10.2002 SIJfeet Card6n Remery: Independent High Level Alarms (Pressunsed staao e\ CRP; P&lD memaandum (prE!\fioU5ly part of 05.1990 Techn ical Information in Control Rooms) CRP: Housekeeping improvements ~ In Progress In Slow Progress (Long Term Project) In Progress c coueucue Effort COrrnlent E2 Sphere implemented, during present TAM E1 s enere olanned for later th is V<!Iar In Progress. Project progressing . Examples of newly "actualised" P& IDs were sha.vn to us, although those we saw in control roan s w ere not "As Buift", not authorised , some from 1997 (Maraven) issue drawings , and not "Autoplan" CAD issues , Few "RedHn e" chang es recorded . It is unclear wh ether thes e are the "Master" P&I Ds, or whether the conc ept of "Master" P&ID s exist s. Amuay housekeeping falls far short of expectations orl un~s we visited . PSAY-4, PVAY-4. Card on housekeep ing wa s generally 12.2002 02.2005 CRP: Inspection program coverage of offsit e oicewor1l. Wafer Flanges I Long Bot Flang es Closed In Progress Physical N. Pro~tSS (4 06,2005 ,," Pressurized LPG Storag e at Card6n Refinerv Emergency lsolatiorl Valves (EIVs): Operation from the Contrd Bunker In Progress 0 1.2007 In-process fixed gas detection installation , plus maintenance and operat or training on existing systems In Progress but No Physical Progress 08.2007 EIVs Operabil ity Closed 09.2007 LPG Sphere best practice for Sa m p ~ng I Water draw-off In Progress 11.2005 In Progress much I~~t,er than befor~ ~n the un~s visited . FCC, PG2 . CD4 Offsites Pipe systems on the refinery Now included in olanned orooramme Protection Jackets national supplier identified. Note these are not the usual "Stainless Steel Sleeves" most usually used fa' this eurc cs e, E2 Sphere i mPI~m~:ed , during present TAM E1 Sohere annedlaterthis vear New EIVs at CD-4 have facil ~y to operate from external safe locati on panel and from the control bunker. Not presently operable from control bunker (See Also Rec2007.11\. No add l~onal detectDrS installed since 2009 upgrade of PG2 system . This has not operated successfully. Cards on order via Bariven , stil not received. Original card s were damaged by incorrect grounding system. This issue said to have been solved fa' the Gas Detection System on this unit, although problem understood st~1 to exist on other units. (See also 05 2010 re Bypassing during electrical storms\. Closed: Proottest ing regim e now established. inclUding testing at planned shutdowns and other opportuni~es. Comprehensive Check~st now used for each valve. (example seen), No "Partial Stroke 'resen " facilit has been instal ed, Card on Spheres reported to comp ly after aud~ . Amuay S 207 sphere being treated during TAM . other spheres follow at their TAM3 in 2012 and another 3 in 2013 . PDVSA Centro de Refinaci6n Paraguana Recommendati ons Update First Draft Date 03 0l1~ , ~ Ref20 121139 Page 19 0f 54 ~ QBE 11.2007 Improved provision of EIVs In Progress (Slow) 328 valves origfnally identified. Scope now reduced to 21, using PDVSA 1997 criteri a of 25m3 inventory . Another ~2O will be needed. Scope now includes ovemeae drum sour water dr.I'N valves. 5 valves installed at CD-4. Had this.been implemented $99!?6f, !htt oonseguences of tm Ftlbnarr 2012 CD4 fire would have been sianif!£sntly ,-,duoed, Legacy issues Cardon EIVs are fall-sete pneumatic, th ose at Amuay are electrical drive. 12.2007 Floating Roof Tanks - Housekeepn g & Gfounding In Progress 14.2007 Management of 'Safety Critical ' valves 01 .20 10 Priority A Fire-Safe/Fire Protected EIVs. Protection of Cables & General Cable Fireproofing No Progress 2, No Progress 3, No Progress No Progress 5: No Proaress 1 Closed Schedule estabhhed starting January 201 2, with checklist and register, however frequency is only one check pel" year. This we consi del" to be low for a task consistin g a visu al cheel< , Still an inconsistent approach San e valves seen controlled using cable ties, however many others seen not to be controll ed. " ,. 2 n Progress 3 Closed 02.2010 Priority A ATS (Assessm ent of Safe WOrk). consider process hazard s 03.2010 Priorit y A Unconl.roled Bypasses 04.201 0 Priority B 05.20 10 Priority A to Tank A7-2 Bund Contamination Long Duratioo Bypasses (e .g. For Electrical Storm T tveats) Closed 1 Closed the four zooes identified by us in 2010 in HDAY4arerepaired . DKAY andALAY bei done durin resent TAM Sane mOdification of ATS , to include some considerations of process risk5. But see Site Observation The "block" on C35 1 governor did not disable the protection, .....t1i ch is independent. Blue Book appears to be properly used and authorised . 3C_ 1: Closed Regular audit earned out on rotating maeun ev orotection. Cause found and eliminated. 2: Closed Conlamin ation remCNed 3: In Progress 2 other blocks of l aoks identified with similar svmotoms. Planned to be treated. Cause identified as grOl6lding of the protection system (Clean /Dny Earth system), Varistors on order or being installed. Still some recent "Blue Book" entries of long dosation bypasses for "Atmospheric Cond~ia15" or "Rainstorms", even on units where it has not been a problem, Mitigation measures rem ain vagu e "monitor the process " etc. 1: In Progress 3: In Progress First Draft Date 03 0l/~ , ~ Gap Analysis can pleted and fireproofing plan prepared ImprOYem ents to power cable fireproofin g made on HDAY-4 (by PDV Maintenance) 2 C_ 2: In Progress PDVSA Centro de Refinaci6n Paraguana Recommendations Update ,,'" Ref 201211 39 Page 20 of 54 o QBE ~isk 00.2010 Priority A Control of Hazardou s Energy during Maintenance: Positive Isolation, Defin~ions, Identification , Tagg ing , etc, 07.20 10 Priority B Register of Firefighting Equipment 08.20 10 Priority A Sphere Deluge Detci encies 09.2010 Priority A EIV Local Button Location , Label~ng , Integrity and Lamp Function. 10.2010 Priority Anomalous Piping T hldmess Mea surement Readings in ' SILC O" PDVSA Cen tro de Refinaci6n Parag uana Recommendati ons Update First Draft Date 03 0l1~ , ~ No Progress on any of the 6 points, In Progress "2, In Progress 1: Closed 2: Closed 3: In PrCKlfess Closed In Progress although not much apparent Ref2012/139 FUll LOTO Is not in practice. Dupont Training "Best Practice" taught , but not prad iced. The PDVSA Norm also cah for full LOTO. Annua l Plan local , blJ: work entered into SAPwhen required . Early Days : "SICOIN E" inventory and checkl ists etc . Ar e yet to be fully populated with all systems and apparatus . Only extin guishers, breathing apparatus, fire veh icles so far included. See 07 .2010 above At Amuay,nl!\¥ molorised valve panels have been installed in some units, installation con tinues in tum-aroond s At Card6n , Pinars identified by Yel low Paint, with push-button s labelled by stenocil. AKhough it was explained to us that the problem arises only where there are small differences in readings. ~ is important that the princip al of assu ming that the previous reading was "correct" is not satisfactory. (symptom - apparent increase in wan thickness l Page 21 of 54 G QBE 12.1. Recommendations from 1993 SUlVey 05.1993 Cardon Refi nery: 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 which Is already relayed to lhe control room . exis~ng high level alarm on the gauging system 2005 Status: Open / Ab/eda This 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 d 1118 CCU. Apr~2007 AIG recorrrnendBnon (o flrNll-up vi sit: No physical progress. The SlIme explanation WIIS provided liS in 2005 bU lhis t.me with a planned shutdown of the LPG storage for August 2007 which will agan coincicJe with a CCU shlJldoNn. No Progress I SIn progreso. Nov.-2007 status: No progress I Sin progreso. Once again delayed, this time to a January 2008 combinad LPG I CCU shl1down . 2009 Status: Good p rogress (to be installed Q4 2009) I Detailed engineeringdone October 2010 Status: No Fu rther Progres s 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 Paraguana Reccmmendaecos Update First - Dr.s Dal e 03 . I'$J ' ~ Ref20121139 Page 22 of 54 o QBE 12.2. Recommendations from 2002 SUlVey 08.2002 C RP: P&lO m emorandum (was 199Q.05 Techn icallnfonnation in Control Rooms) 08.2002 Actua/~acl6n de 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 regular upd ate P&IDs can be modified YJith a red pen to indicate any changes. A P&ID cont aining the red pen man<-ups is comprehensively veri fied as representing existing process equipment before being made available for use. The m aster copies of P&ID documents are retained in the respective process area control rooms and the plant section heads have been 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 sign ature. Therefa e, it is not clear if the P&ID docum ents 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 wer e made and who authorized their addition to the master copies and Iher use. .,F Some "Como ConstnJdion " (As-Built), som e "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 from the 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. At the r.me eX the survey 78 P&1D were revitN/ed and approved at Catdon (40 in Conversbn, 28 ~ Deep COrIversion, etc.). The rest of P&1Ds at CRPwill be updated in /he pB riod 2006-2007. AIG recommendBtlon fo llow-up vi sit: In Progress I En progreso CRP's anSWef is that some637 PlDsoul of a total eX -1200 dnJwings were updatedwlh the NoVlluser I ALtocad platbfm during 2000-2006. In ~ CRP opted for new sonwares from Bertley which have "in1e1ligent" ifiegration applications: these ateAlJIoPIant as df8Wing softwate and Projectwise as document visualization tool. The new applications 8f8 being used on a pi/ol projed for actualizing the PlDs of the HDAY-3 plant. The project is planned for completion in Q3 2007 and witl be foJowed by a 4-yeer ptOfJmm to actualiza to "as built"conditions 1 ~ eX CRP's PlDs. CRP estimates complelion of this ffICO/'TImendarion for 2012, Apr~2001 No v.-200 7 stiltus: In (slow) Progress I En (lema) progreso During OUf visit eXthe cortrol rooms at both tefineries, we obs8fVed fhat some sets eX PID 's were kel1 on flICks and in large fofmat (AO}. HoNever, thete were marty missing PIDS; wlJ6n available, most drawings referring to a given unit and kart rogflth6r we te out eX sequence; the sequence was usualfy incomplele; drawings were uncontrolledc0pi8s and were missing teVision da tes forexampla as a result eX arty Process Sa fety Management action; some copies were also 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 Y and GLA Y showed Oct-1999 and Feb-2OO2 dates. DiSCUSSions wlh the engineering depaffment conflf1Tled that inilitJlives on PlDs actuajzation a'" essentitJly contained within the pi/a project described in the Apr,2007 status. All PlDs (20 off} for Amuay hydrodasulfuriza/ion HDAY-3 have noN been ufXJated using the Badley's AlJIopl8d application . These PlDs were being circulated for approval by a/l disciplines before to be officially authorized and issued to end users like Operations teams. It was stated that these upd8f.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, Amuay HDAY-4, which is a twin unit ofHDAY-3, Is andh6r ""1'1 candidate pla d for the dnJwings actualization. The Bngitlooring department is aware that progress is slow and that the amount eX work lalt is considBnJble. 7he targBI of updating CRP's ci'ra1200 PlDs by 2!J12 appears uflf88li!,fic wlh the clJtTlNt lavelof txJman teSOUi"Ces andthe engitlooring depaffmed explained that it was looking for more support from managemefi. AI. the Wfll~1JP meeting, the SUf't'ley tNm reminded CRP manaf}fll'Tl&d dthe impoltlJnce eXthe PlDs actlJlJlization andcalledforCRP managament to 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 at Cardon Lubricants unil- actua/ised in 2007 wlhout comment PDVSA Centro de Refinaci6n Paraguana Reccmmendaecos Update Frst Draft Date 03 0l1~ , ~ Ref20121139 Page 23 of 54 o QBE March 2012 Sta tus; In (Slow) Progres s: 'rne so called "Master" copies of the P&IDs are ke pt as stick files in the control bunkers . "AetualiSation" is said to be carried 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 are done. 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 we reviewed in th e control buildings, and some of those we saw were confused , witlltlle change "Clouds" not referenced to ttle euthonsetlcn or management of change number. There were also some changes ltl at had been added very recently , for changes made in 2010, and tile new EIVs reennes had been added during our visit. (See below) ". , -=->e.rlle< Moe • No ,efe'ence . seV'er.lli~e lllis on ,1111 dr.wlng ,- ,• , .. ... ..-. ..... ~.;; "New" Moe , p,operly • ' .-.-< Id.."intd, (lOIIl<lO$l03112 .,i I ,\ • I\ ,• ., 0..- H • - . . , , \ • - _. J..• I" , l- /' • Wi,.. .- ~~ " " ...- ••• - -' - Tile condition of some "master" drawings on slick-files was questionable (left), altttougtl we nave been shewn ' ec uansec' drawings, property approved (centre and rigtlt). .!'.PJI.I!_ PDVSA Centro de Refinaci6n Paraguana Recommendations Update First Draft Date 03()4/Kl'2 Ref 20121139 Page 24 of 54 ~ QBE 10.2002 CRP: Housekeeping Improvements 10.2002 Mejora$ 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 safety walkabouts. 200:5 Status: Open. No Progress I Ablerta. Sin fJI09reso. Despite me extensive audit of process areas, the site tour has confirmed In few occasions that debris, trash and tools are stored in ooIumn skirts (Lube Plant and CD3 at Cardal, Isomerization and DCA Y ( T2501) in Amuay). Similarly explosiaJ proof boxes oonIainirY,J el6ctrical circlAls were found loose. At the aoeeon pr6S6fltalion, it was recommended 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 o DtxlrY,J the site leu, sane debris am tools wwe foun:j in ooIumn skirts and explosion boxes contairin:J electric eqlApment were tara not properly bolted. Nov,-2007 $talU$: No Progre$$ I Sin progreso Housekeepin:J standard in many cI/he visited process lIYts at both refineries was stili inadequa /eam many anomalies, often ee same as in previous visits. were wed: accumulations cJ debris from maintenance activities, piping insulatiaJ fallin:J apart, below average f!osf:Idiscipiine, some OCCllfflflCeS of missing capslplugs for example on the drains fuel gas lines to heatefSlfurnaces, pumps full cJsludge for example at Cardon FCCU am 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 Amuay Fle:x.icracker area (DCA \'). Hc:NVeVer in DCAY, a blatantoccur~ of inadequate boItirfJ was observed on /he!Y.l:l electrical boxes Z406/Z407 (each box was onlyciosed with 2 bolls when 24 are normaliy req/ired). a 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 missirfJ plugs in ISA Y, missirfJ bolts 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 Paraguana Recorrmendations Update First Draft Date 03 "'201l Ref 20121139 Page 25 of 54 o Q8E 122002 CRP: Inspection pr ogram coverag e of offsite pipework 12.2002 Incorporacl6n de las llneas off-site aI programa de ItrSpecclon eve- the past few years , th ere have been a numbel" of losses originating from off-de pipework that WilS nol sufticienlly ecveree by iIIl Tispection progl"illTl . Accordingly, the indusion of off-site pipewor1< in any corrosion monitoring progl"ill11 stlould be implement ed as seen as possible. From dtscrsstcns with CRP inspection special ists they are considering wh ether to indJde the monitoring of off-site pipework into their advanced SILCO program . Thel"efore. it is reccm mended tha t the introdUdion of off-de pipework Wl to the SILCO progl"illTl shoold be implem ented at the eer test possible time. 2005 Status: Open I Abletta Only 10% oflhe tctelworlf has been carried auf so far, CRP have lisled all Amuay's df-site pipe worl( (a l the jetty and at the process units) that netld to be pan of a corrosion monitoring program; this list still need to be dtlve/optKlfor Cardon. Once bolh lists will be available, CRP will stan worldn} on the isometrics and on the setting of an Inspection frequency, 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 progreso Off-site pf)eworlffor 7 erees at Cardon have now also been identified Wl addijion to the pipin g systems already selected at Amuay. CRP estim ates the ov erall progress at 31% and the 2008 as the ccm pletlon year. No v.-2oo7 status : In Progress I En progreso For Cardon: physical conditioneveva!iofJ, isometrics, fepeirorcJers and inclusion In SILeO have been csrriedou for the piping systems b6tween plaTts, bdween plans and stOf1lge and b6twoon stontges. "This worl< is pending for the lines 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 previo us status reports, blJ e RP opfed fora recheck dtlle available information to p roceed later on with lhe incvsion of information ino SI LeO. eRP's own estimale of progress at Amuay is 26%. Note that CRP has reviewed 10 2009 the completion )l'98ron this recommendation. S tatus 2009: Cl osed (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 complete by end of 2009 Ma rc h 2012 Status: Closed There are 59 manuals for Ine Wlspedion of all lines on site, with procedures and inspection points. Outside Batt ery Lim~ Unes and Jetty nnes are done. PDVSA Centro de Refinaci6n Paraguana Recommendations Update First Draft Date 03 0l1~ , ~ Ref 20121139 Page 26 of 54 o QBE 12.3. Recommendations from 2005 SUlVey 02.2005 Wafer R anges I Long Bolt Flang es 02.2005 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 ofwaferflanges l loog bolt flanges. The long bolts will be receive direct flame contact if there is a fire in lhe area; the direct flame contact causes the bolts to eKPal"ld ~idly and lengthen, allowing both gaskets to leak product. The leaking material lhen adds fuel to the fire and if under pressure il causes a large spraying fire that resoll s in much more damage. It is recommended 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 wi th normal flange valves, bul th e hazard can be reduced by wrapping th e loog bolts with a fi re resistant mateeat and lhen enclosing th e entire assembly with a stainless steel covering . In addition CRP should progress~y remove Long Bo~ Flange when in Flammable liquids or LPG servce. Update PDVSA engineering standard in order to ensure thaI every Of!Ni process unt wi l not have Long Bolt Flang e Joint installed any more, 2005 Cflem Comment: CRPwillCCl1duct a gap analysis across the site qy Febtvary 2006, and will propose an aclion pJan in on:l8rlo upgrade all wafer flanges existing in the complex. By March 2006 it is expected tha! all wafer valves are icmrtified. By Septembttr roOl5 CRP will revise PDVSA Engineering standard in adf!1r 10 avoid !m l1iliza!ion of wafer valves in new projects. AccounlabJe: Mail1.enance. Apr.-2007 A IG recommendillJon follow-up visit: No Progress I Sin progreso NoCCtlCfllte 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 fit tfltJSfJ valvt1s with thermal isol8liorl.ln sutRiflqUfmt main tum arounds, and where t«hnictJlly possibltJ, the valws will be replaced by normal flanged systems. The.scc:pe of war#( for18 unls planned for tumarounds in 2008 is als:J being any long boled flanges identified in these units. CRP als:J agrees to defined and wil/contempl8le the replacement no longer specify wafer type of valves for flammable liquids or LPG service. No inkxm8liotJ provided on whelher PDVSA Engineering Siandards have been formally revised ornoI. a Nov,-2oo7 s tatus: No Progres s I Sin progreso Many iong boltedf/anges were observed across !he units and none was observed wlh a rreprcx:ting protection, hence tm 8/tributed "no Pf04ress" status. CRP stated 10 stiN btt in the identification phase (apparenlly 700 Jon;J boled flanges were listed along with diameters and ratings d8la j . CRP st8ted Ihallhe collected information was being reviewed by Is Engineering Department (GI/-IP and GII-IC) which will issue the technical specirlC8tions required for Ihe provision fireproofing blankets. For the units scheduled fortumaround in 2008, CRp ·s exp/anafiotJ is as per/he Apri/2007 sf8lus repotf.. CRP also stared that the relevant PD VSA Engineering S!aooard(s) wastwere under review (no specirlCS provided). a 2009 Status: In Progress InvenloTy done, risk. ma/rix topriorlizedlhe ones to prriect, standard is written & being culated, 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" Progress Nothing physic al yet, blA local manufacturer of fire resistant jackets has been identifi ed. These are not the suggested stanless steel band typ e, allhou gh if conscientiously replaced aIIer acc ess need s. are believed to be adeq uate. PDVSA Centro de Refinaci6n Paraguana Recommendations Update First Draft Dal e 03 0l1~ , ~ Ref20121139 Page 27 of 54 o QBE 06.2005 Pressu ri zed Storage at Cardon Refine ry 06.2005 Afmacenarriento de GPL en fa refiners eMdon During the next CCU shutdown, C RP is planning to install ROV on spheres E-01 and E-02. It is recom mended to install the ViIItves as closest to the bottom of the sph ere and not at the current location that is outside the bund area. In addt 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 to upgrade 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 CCU turnaround that wiN occur in Man::h 2007. CRP wiN mvise, by February 2006, tm PDVSA Engineering Standard in orr;Jer/o incllJde the change of the location for lm ROVs. Apr.-2007 AIG recommemJatJon fo llow-up visit: In Progress I En prog~so CRP's engineftrirq department (GII-IC) issuedthe technical recommendation during 2006 for/ he installing tm ROVs as reoommend8d. This will happen at tm LPG shutdown fION rescheduled for August 2007. The f8Visionofthe cotTeSpondirq PDVSA standard is still intend«J as is the modfication of any of CRP's LPG sk:>nJge that woufd not be comply wth the updated standard (ac:caurlabilty to GNJ. A first meeAirq wth INTEVEPin March 2007 is foreseen as a 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, l he only p rogress staled by CRP is the setting up d a l eam 10 revi$8 the corporlJte standard which will be lhen be used in the e1abonJlion d CRp ·s LPG s1ot"111ge modificat ion program. 200 9 Status: Good Progress on an & E02 Spheres, EIVs operable from the bunker to be installed in October 2009 Oc tober 2010 Status: No Progress since 2009 Marc h 2012 Status: In Progress E2 Sphere implemented, dUling present TAM, E1 Sphere planned for laterthis year PDVSA Centro de Refinaci6n Paraguana Recommendations U pdate First Draft Date 03 0l1~m Ref 20121139 Page 28 of 54 o QBE 11.2005 Emergency Is ol ati 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 th e field (push button); it is normal pradice in the industry to hilVe val ve s isolating large inventories remctely operaled ecm Ih e control room ; therefore. is recom mended to instal a aduat ion device in the conlrol room for al Erv isolating critical Inventory 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 com pressors but n for critical inventories. 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 A IG r ecommemJatJon (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/6kfwiH be installed in Cardon FCC utliles pat! ~thec8p8cifyexpensiotlendlumeround carried 0iJ in HrIy 2008. Forthese EIVs, 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 an estimated completion yeara 2012. No details were provided. No v.-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 turnaround scheduled 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;1 worli., before to consider closing this recommendaOOn and tracking sepsrBIefy the progress for exs mp1e in the project section athe undttrwriting repotI. 2009 Status: In progress (GAP Malysis done, priorifisstion being done) October 2010 S tatus: In Progress Total a 3J6 valves identif"1ed as needing oontrol room edUlltion. No physical progress so far. Marc h 2012 Status: In Progress New EIVs al CD-4 have fa cil~y to operate from extemal safe Iocalion panel and from the control bunker. Not presenlly operable from conlrol bunker (See Also Rec 2007 .11). PDVSA Centro de Refinaci6n Paraguana Reccmmendae cos Update First Draft Dal e 03 0l1~ , ~ Ref20 121139 Page 29 of 54 o QBE 12.4. Recommendations from 2007 SUlVey 01.2007In-pro c llSs fi xed gas d e(ecti on i nstall i.'ll io n, plus maint enance and o perator training on existi ng systems le-prccess flam mabl e gas detectioo is either absent a- very l im~ed in most units at both refineries. Furthermore, when installed, numerous gas eeteetces were found to be no looger operatioo al. There are numerous case studies in the indllStry , an exa mple of which is the Phililps 66, Pasadena, USA , 1989 explosion . illustrating that early leak I gas detection is ess ential to the initiatio n 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 significant inventory of ligt1 t hydroca rbons (particularty LPG holdup s 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 impl ementing an etredive ga s detection ceeraje . identify and risk assess the probable leak sou rces which oould lead to the formation offlammable gas clouds. e .g. high pressure equipment I joints. oompressor seals , pu mps handling flammable liquidslvapours with an Op . temperature higher than the ir lash points, ma nifolds where many control valves are grouped with multiple flanged com ectio ns, letdown valve etc.•.The recommendation is appWcable as a first priority to process unas not already filled with gas sensors , but shOOd als o be consi dered foc LPG storage for Yotlich the provision of gas detection has already be th e subject of other recommen datia'ls. Ar ea detecti a'l (tine-of sight devi ces) as well as pa nt detectors shou ld be considered, 2) The operational status of gas detectors provided in unit 96 Reformer & HOT area at Cardon Is acce ssible 00 a plant mimic display In the main Ca'ltrol room. During the visit , it w as 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 detection ecverase wa s not eosw ee. The following defi ciencie s were also noted about the panel operator in charge: I n ab~ity to provid e any explanat ioo about thi s faulty and alarm mode sauatloo and Its dlIratioo Issue not recorded in any of the operator logbook Lack of knowledge about the functi on and field com ponents oflh e gas detectioo system No 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 on the control room displays and the coes actually installed w~hin the units. The extent of such discrepancies is not known 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 ly the improvements llsted below. b) Inspect, prcce and maintain existing gas detection system c) Ensure that control room displays accurately reflect field instrumentati on d) Regularly train operators on gas detection system and the required actions to take on the recei pt of a gas alarm (all possible alann scen arios snould be ecneeeree such as alarm tom a single detector, from multiple detectors, pre- alarm only, higher alarm levels etc... ) 2009 Status: In Progress overall 1) Prqed of only half way through the concept stage, hence very liffleJprogress 2) Mairtain & l raining of Closed Seen functiona l on DeS in CR + Cps instn.Jclion isSl.NiKi. October 2010 Status: In Slow Progress 1) 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 Progress 1) No additional 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 been d8maged by incorrect grounding system connection. T1lis issue said to h8ve been solved for the Gas Delection System on this unit, aI/hough problem understood stil/to exist another unls. (See ezse 05 2010 IU Bypassing dun'ng electrical Storms). PDVSA Cen tro de Refinaci6n Parag uana Recommendati ons U pdate First Draft Date 03 0l1~ , ~ Ref20121139 Page 30 of 54 ~ QBE 08.2007 EIV s Operability Picture 5 here below sh0W5 the emergency Isolattce valve (EIV) . HCV-432. installed in the suction ofa hydrocarbon pump . at Cardon's gas plarlt PG2. A s it Carl be seen , the alTilllgement is such that the EIV actu ator arld remaining valve assembly is horizoot al, but the actuator, which is sizeable , is not supported and because of ~s weight ~ appears to 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 be stuck 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 the fireproofing protectiorl not property in place oc remOYed followi ng fa" example mao teiance wa1<: 00 the EIV . This was observed 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 ance and testll'lQ to ensure the valve opera.bil~y on deman d. 2) Audit the installatioos to idel"llify other sizeable EIVs lacking adequate supports and/or in physical COI"lditiorls . as HCV-4 32 , and provide the remedial solutions as in point 1. sim~ ar unsatisfactory 3) Re-.iew and strengthen CRP ' s EIVs ma intenance and prooftesting pM osophy to reduce the occu rrence c:i dangerous valve stuck fa~lXe conditions, as in HCV-432 case. For example: o where spare EIVs are inst alled , for example where they are fitted to pairs of "spared" pumps, test them betweentlXTlarounds and not only at tumaround o consider implementing partial valve stro\(e testing, to ensure that the valves remain operable , without the need 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 wh ere needed. Also, mak e the r einstal lation of these fireproofing items a reqlirement in the a cceptan ce step of work permit activities and ra ise awareness about this poin t of personnel involved in those activities (contractors. plant operators etc.). 2009 StaWs: In progress, overall 1) Carcim 'sPG2vallll9 o7ExpirBd 2J VelVe support & Operabillyeudits 7 Done, sekJ noimprov8l716rrts to support needed 3J Meirt&ntlnce & proof testing improvement 7 No progress October 2010 Status: In P rogress 3J In ProgreS$: Mali1tMance proof testing Improvement: Spered ElVs stili tested oriy at TAM . No l1IO\I8mert tONards Partial stroke Testing. Electric actuated VIIlves not l ested 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 of pre.start checks alter TAM end other shu/.downs. COili/leTlt: Make as mandatcxy pre..starl requirement 4) Closed: Flre.proofjacl<.ets seen lo be improved 00 site, following memo. HcNIever Inconsistencies still f'xist. rm,re am however e llJdriaJl cabieslcondvits that am not tim protected. (See New RtIC 2010.01' s: March 201 2 Status: Clo sed 3J CIos«J: Prodtes1ing regim e f1CTW established, including testing at planned shc.tdCN/nS and dh&r opportunlies. Comprehensive Checkist Testing" facilly has been installed. PDVSA Centro de Refinaci6n Paraguana Recommendations Update First Draft Date 03 0l1~ , ~ nc>N used foreech VII/va. (exempie SfHfn). No 'Psrtial stroke Ref20121139 Page 3 1 of 54 ~ QBE 09.2007 LP G Sphere best pr actice fo r Sam plin g I WlIIler draw-off t eakape wren taking a sample or drawing wat er from LPG slora ge ,ln parti cular the failure 10 Isolate bllowing such opefalion , has been recognised as one of the major LPG release cau se leading to accident. When \listIng the LPG sphere area ill Amuay, f was observed on sphere 209 that the willer drain line consists of a first Yo tum valw and a second globe valve wh ich are separated by only 1 foot . Thi s separation distance is considered to be Insufficient and lhe valves could freeze In lhe Ollen position fonewing sampling Of water draw-off ccerencoe. It w as also observed that lhe samp~ng point lennlnilles directly undemealh the spheres , wh ich Is not lhe preferred layout. (Such a design was a 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 val ve isolation on the LPG sphere 209 at Amuay water drain line be modffied to Introdu ce ill least 1m 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 coul d lOr example be taken of the wa ter drain line. Note that water draw-olf lines should terminate al least 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 a programme of improvem ents be deveiOlled. Refer 10 API standard 2510 "Design and ConslnJctl on of LPG installalions" for best pract ices on LPG sample points . 2009 Statvs: In progress GAP analysis done, EIVs in waler dfllin lines wi' be insalled, etc. Octobe r 2010 Status: #1, 10, #3 Overall, No Further progress S,:X1eTfl 209 sample point remains underthe vesse l tc:p valve was open. Sphere 208 sample pairt in bad stsre sc sample taken from gauge connect.bn, top valve open. Distance bBtwfJfIn sample valves does net complywlh PDVSA 1.5m criterion No progress on implementation 0If other spheres. October 2010 Status: : #1, 1#2, #3 Overall, No Further progress S,:X1ere 209 sample point rema ins under the VElSse( tc:p valve was open. Sphere 208 sample pairt in bad srerese sample taken from gauge connection, top valve open. Distance bBtwfJfIn sample valves does net complywlh PDVSA 1.5m criterion. No progress on implementation on other spheres. March 201 2 Status: In Progress Cardon Spheres reported to comply affer audl . AnlUay S 207 sphere being treated during TAM. Othe r spheres follow at their TAM - 3 in 2012 and andher' 3 in 20 13. PDVSA Centro de Refinaci6n Parag uana Recommendati ons Update First Dr.IIl Dal e 03 0l1~ , ~ Ref2012f139 Page 32 of 54 l!l QBE 11.2007 Improved provision of ElVs A number of emergency isolation valves are already installed across the cons at Amuay and Cardon, however it was observed that there are still sigrificant LPG inventories which are connected to pumps and for which the isolation is manual between the vessel and the pump in case of an emergency at the pI.'Tlp e.g, seal failure. The gas plants at Amuay and cerocn are our principal concerns although other plant areas may also be invo/lJed. Furthermore, the inventory tty-eshold defining the vessels that should be protected by EIVs is now becoming more and more stringent in the 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 hydrocarbons Op. at temperature above, at or close to their f1ashpoint or auto-ignition tempera ture, For the systems meeting those criteria, install EIVs in the discharge lines of the vessels to the pumps. These velves should be installed as close as possible to the vesse l or drum and be capable of being actuated from witl1in the appropriate control room (see recc nerence uce 05.11) and from a safe location within the process units, It is reminded too that the valves, actuator and cabling should have a fi re raUng of 20 minutes, Implement the insta ltation of EIVs not only in me main suction line of qualifying ~drocarOOn inventories as described in point 1 but also in other lines which in case of a 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 sour water 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 such that remote isolation is provided on the main suction line but not on the sour water lines (see picture 7). Picture 7: EN s on main line but not on the secondary line - Vessel tag unknown! plant GLA Y Anway, but this Is to Illus trate the point made In the recommendation 2009 S tatus: In progress GAP analysis cbne, EI VS in water drain lines will be ins/ailed, etc. October 2010 Status: Little Progress since 2009 GAP analysis was cbne before 2009 visif. including agreemenf thai qualifying wafer boot draw would also have EI vs 328 valves identified. Requirements passed /0 Instrumentation for design, but no decisions on types (EJec or Pneumatic). 1 spool inserted on CON FCC. March 2012 Status: In Progress, although slow 328 vafves originally identified. Scope now reduced to 21, usirg POVSA 1997 criteria of 25m3 inventory. Another-20 will be needed. Scope now includes ocerneeo drum sour water draw valves. 5 valves installed at CD-4, Had thiS Deen 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, those at Amuay are electrical drive. ••• ,, ,, ,, ,, - J, ,- ----_. -------- ---~-- - ~ - - . - : ! ~;T POVSA Centro de Refinaci60 Paraguana Recom mendations Update First Draft Date 03 00/20" Ref20 12/139 Page 330f 54 l!l QBE 12.2007 Floati ng 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 conta rrinated with oil, which could be a contributing factor to hydrocarbon ignition and rim fires 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 tank shell were broken, hence increasing again potential secondary lightning effects s\X:h as bound charge and secondary 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 !tie tanks, but the Shell design does. PDVSA expressed an intention to grolXld all tanks.) It is recommended to speciliCi:l11y address the type of ercrraues highlighted on tank 106 and 164 and by extension establish a programme to improve housekeeping and electrical grounding standards on all CRP's floating tank storage f<l cilities, l.e. est<lblish <I bund veget<ltion cortrol progr<lrmle, lT1CIint<lin roof seals in <I cean condition, ensure eoequete electrical continuity between floa ting roof se als and tank shell as well as ecequate tank grounding. 2009 Status : In progress Need mae proactivity in repating seal conditions. shunts etc. OCtober 2010 Status: In progress Reported checklist in use, and archived. (Checklist not seen) Tank seen (A7, 2), Lagomar 5 Light Crooa, holes in weather seal, gaps between wall and sea l, root seal nooxa. (Soo proto) March 2012 Status: In Progress SChedule established starting January 2012, w~h checklist and register; however frequency is only one check per year. This we consider to be low for a task consisting of only a visual check. POVSA Centro de Refinaci6n Paraguana Recommendations Update First Draft Date 03 00/20" Ref20 121139 Page 34 of 54 l!l QBE 14.2007 Mana gement of 'Safety Critica l ' 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 fire protective 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) de sigflCltion) 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 valves or opening designated ·scvc· valves to be corecsec using the cerme-tc-wcrk system or the safely interlock bypassing procedure as appropriate. 5) Periodically checked to ensure they (Ire in the correct 'safe' pos ition 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 tu s: No Progres s - i f anything, some regression Still an iooonsisteni approach Some valves seen COfJtrdled using cable ties. however many ethers seen POVSA Centro de Refinaci60 Paraguana Recommendations Update First Draft Dale 03 00/20" Ref20 12/139 net to be COfJtlOlled. Page 35 of 54 l!l Q8E 12.5. Recommendations from 2010 SUlVey 01.201 0 Fire-SafeiFire Prot ected ElVs , Protectio n of Cables, & General Cable Fireproofing Pri ority A There are many electrical ly driven Emel"gency Isolation Valves (EIVs) at CRP. These require a reliable source of electrical enel"gy and signal to operate. For this reason . where they are located In a fire zone , they are generally to a fire-safe design (actuator and valve body). or are filted with fire insula tion jackets. Similarly, cabl es run thrOOJ gh a fire zon e, are generally protected fl"om fire using a j acket or coating . During our site \Ois~ many cases were seen where the protection to the cables and thei r conduits was lncomplete. Most prevalent was failure to protect the lIexibl e conduh carrying the cables fl"0Il1 the rigid conduit 10 the actuator body. a~hOOJgh cases also wllfe seen where the condu~ was not prctecled . 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 ambient conditions 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 are within a fire z one. 2 That cabl es found to require prot ection be fitt ed with protective jacketslcoatings. 3 That the condition of tire protection to imporlant instrumenl and electrical cable trays be assessed and prompt replacements made wIlere necessary. Cl ient Comm ent : None reeevee Status March 2012: Clo sed: Gap Analysis has b86rI completed. 11lere is a ' Fireproofing Plan " covering passive protection to stflJdUf9S and cables. 2) In Progress: Electrlcaf driven actuators are generally ' K-Mass'!>' protected. Cables are being treBled by a contractor during tum-arounds. HDA v- 4 said to ee eomp/8/ed. DCA Y 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 during present TAM 1) PDVSA Centro de Refinaci6n Paraguana Recommendations Update First Draft Date 03 0l1~ , ~ Ref20121139 Page 36 of 54 o QBE 02201 0 " ATS" (Asses sment of Safe Work used in Permit-to-Work) to c onsid er Proc es s Hazards Pri ority A The ' Identilcacion de Riesgos' and associated 'AdieslramientolCertificaci6n Requierd o en Pract icas de Trabajo Seguro' are job safety analysis used In conjunction with the Perm ~-to-Wor1< to Infonn all staff and workers of the hazards which may be associated with the work to be undertaken and the appropriate procedures and crctec uve measures. Thi s concentrates solely on risks to the workers , specificall y at the sije of the work itself. and does net consi der broader process hazards. potenijal damage to equipment, or hazards that may be introdu ced remo te from the work site. Althou gh in many cases this will also protect th e process, this is not always the case, and significant losses in the past have resulted from failure to recognise process hazards. We Recommend: That a mUlti-disciplinary team should study generically the proce ss hazards that may be introduced In the preparation and execution of the work , and subsequen t return to sevtee of thllllquipmen t and systems involved. The study should consider the consequences of intended actions, unintended ad ions and omissions in the work . to the immediate process. to ether con nected systems or ap paratus and to the surrounding environment. It is suggest ed that a Wlal If?" formal of study woul d be suitable, with th e targ et of including such hazards on the ATS check( st. Cli ent Comment; None received Marc h 2012 Status: Closed Some modmcation of A TS, to include some considerations of process risks However we not !hat items such 8s ' Lifti/1li1 Plans' for use ofcranes etc. are applied rat herQeneric811y and coosidermostly weigftlbalaTlCfl and security d slinging issues. On these there is fIOlIppilmnt coosidttnJtiorl of thecoosequences of cJropped load on spparatus and pipeworlc. over which the lilt is to l ak.e place. (EXlImp le seen on Amuay Jetty 2) PDVSA Centro de Refinaci6n Paraguana Recc mmendaecos U pdate First Draft Date 03 0l11O ' ~ Ref 20121139 Page 37 of 54 l!l QBE 03.2010 Uncon trolled Bypasses Priority A On the HDAY-4 unit at Amuay, the hydrogen recycle compressor (C-351) steam turbine governor was seen 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 to prevent the compressor tripping w ring recurrent repairs of the hydraulic cortrolline on the governor system. 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 the 9tpass Register, and as far as we could make out was implemented wrtholA arlf approval. Also, the Permit-To-INorX (PTW) documenting the last repair during which such unorthodox bypass was applied coco 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 appropriate assessment and approval, recording a the reason for the t¥pass, its time of application, li me of removals etc, as required by the bypass regster book and bypass ccmor procedure. This must apply to software, key switch, hand-switch, jumper wiring, physical blocks, valve movements, wedges, or any 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 proper implemertation of the bypass procedure and that perscore r involved in such audits must be briefed on what to loo k out for in discovering weurcnseo or wccrvenc re rbypassing activity. Client Comment: None Received Marc h 201 2 statu s: 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 osea am aIJItlorisecJ. 3) Closed: ReglJlar audit is carried ()(J/ on rotating machinery protection. POVSA Centro de Refinaci60 Paraguana Recom mendations update First Draft Date 03 00/20" Ref20 121139 Page 38 of 54 l!l QBE 04.2010 Cardo n tank A7·2 Bund Contamination Prio rity B During the survey it was noted that there was considerable co ntamination In tank A7-2 (Cardon) with crude 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 that the sltuatioo has persisted for a considerable time. This cooseues a s ignificant fire risk, noting that crude 011 pipeworx and the fKiatlrg roof seal pipewo r'P< runs aoove grol.fid in the cont<lm inaled area. The above situation Is reminiscent of reoorrme ndatlon 13,2007 (spill in ArmJay crude tank 164 b..Jnd and nearby ground plpeway) . During the visit, we also noted various pipe trenches h~1y conta rrinated w~h oily mixtures, however in this case, there is an orgoing see wide prograrrme to remedy this type of contamination. We Ree:: om men d : 1 Urgent attention be given to the elimination of the cause of the contamination In tank A7·2 btIld, 2 The contamination be prorflllly removed. 3 Audit the pl<lnts to identify simila r tratarces elsewhere <l nd diligently remedy them Client Comment: None Received 1. Closed: The cause of this specific oonIaminalion - obstruction of a 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 with similar symptoms, Planned to be treated, funds alicea/ed, . POVSA Centro de Reflnaci60 Paraguana Recom mendations Update First Draft Date 03 00/20" Ref20 12/139 Page 390f 54 l!l QBE 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 cal sto rm activity should be ceased - typically 18 hours, or l4J to 345h (see extract fro m one of the con trol room "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, a nd mi~ gation bf merely "rmnitoring constantly operational variables" OIIef such a period is cortrary to good practice, particularly with the staffing levels available, The conseq uent unavailability of the protective systems would certainly not comply with the required Safety Integrity Level. We Rec ommen d : 1 The root cause of the instability during electrical storms should be sought and remedied, rather than merely masking the symptoms by disabling the protective systems. (We suspect tha t the source of the problem lies in electrical equipolen~ al grounding syste m). 2 "Managemert of Change" for irrportant issues such as isolation of protection should always be considered, including when r-cuveteo by concems Olle r electrical storms, 3 M it iga~on measures should be clearly detailed, and realistically ac hievable, statirg a lternative protective rreaso es in place, o r the parameters that must be rmnitored dlXing the outage of the protective system. Client Comment: None Received March 2012 Status: 1. In Progre ss: Cause has been identified to be the grOl.l lding of the protective system - improper segregation of the "Dirty" high current 9afth and the "Ciaan" retef8nC6 earth. (this was our initial suspicion in 2010) Of 1387 · Varistors", 144 were found to be fauffy and replacem6flts are Q'1 order or being installed. 2. In Progre ss: Stiil some recent "Blue Book · entries of long d ilation bypasses for "Atmospheric Conditions · or "Rainstorms·, even Q'1 units wnere it has not bElen a problem , 3. In Progre ss: Mitigation meeswes remain vaglJe - "monitor the process" ao. POVSA Centro de Refinaci60 Paraguana Recom mendations Update First Draft Date 03 00/20" Ref20 12/139 Page 40 0f 54 l!l QBE Control of Hazardous Energy during Maintenance: Positive isolation, Defi nitions, identification, Tagging, etc. 06.2010 Prior ity A Several 'terre of plart were seen isolated for maintenance purposes. It was noted that: • • • • • • 811ndinglsolation schedules and diagrams were not systematically used Valves were generally 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 identification of spades versus spacer rings. (We are aware that this topic is underreview by me Corporate multi diSfi;plinary commilfae on Industrial Sa/afy. and thai a "Draft" procedure 51-5-28 was issued in January 2010) We Recommend: The use of blindinglsolation schedules and diagrams on all but the most sirrple of isolation tasks, for all sources of energy and lubrication etc. 2 In addition to tagging, locking of all valves used for isolation. Fulllock·Ol1Ilag-oul is industry best practice. 3 In addition to tagging, locking of all electrical breakers used for isolation. Fulllock-oUltag-oul is industry best practice. 4 Tags to be attached to each and fNery blind, spade, spectacle plate or other means of isolation, cross referenced to the permit to work. 5 To establish a site standard for pos~ive identification of "Spades" and "Spacers", A corrvnon corventcn is to use a robust "T" shaped lifting lug, with a hole otaeo if it is a spacer, and no hole drilled if ~ is a spade. The shape of the spade or spacer lab should be unique and standardized throughootthe 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 blind flanges are used, they should be secured using all the bolts, lightened In the correct order, to the correct torque Stricter acceptance criteria should be adopted so as to ensure shortcomings like poor bolting practice no longer persists. In short, process isolations should have the same integrity as the system In wtWch they are located. Client Corrment: 1 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 PDVSA Norm also calls for full LOTO Pu~ Breaker ...uh tailS onlv POVSA Centro de Refinaci60 Paraguana Recommendations Update First Draft Date 03 00/20" Dischargeplat e used instead 01 bind flange Ref20 12/139 same pump -valves not taQlled or locked. Page 41 of 54 l!l QBE 07.2010 Register of Firefighting E~ipmenl Priority B The Fire rntevenuco Team keeps an annual "Plan de Trabajo" (work plan) in which is contain ed the schedule for firefighting exercises and preventive maintenan ce and testing of the various fixed , mobile and portable fire intervention resources. Th is appears to be a comprehensive and well formatted document, which if properly appli ed , would give th e firefighters and management valuable and rapid informabon on the status at any time oflhe fire response capabHly and oflhe cornp~ance with the plamed 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 have been left blank in the work plan docum ent , thus suggesting tnatthe schedul e was not being followed completely. Specific examples were the "Programma de Simulaao Ario 201r:1', which listed monthly fire exercises. only the March 2010 exercise (Jetty #1) had been recorded , storage tanks bi-monthly protection 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: 1 The annual "Plan de Trabaj o" should be incorporated into the maintenance planning system . 2 Compliance with the plan shoi.lld be made a Key Performance Indicator for the Fire Intervenbon department and the work plan document should be maintained up-to-date . Cliel'll Commer"ll : None Received Marc h 2012 Status: a local sand-8lone $praadsh8etkegiser, bl1 worll is enterfJd tao SAP when 1. In Progess : Annual Pl8n is required, 2, In p rogress : Eart; Days: "S1COINE" i1veriory and checklists etc. Are yet /0 be fully popu/81edwilh a/l sysems and app8f7ltus. Only extinguishers, bre8thing appanItus, fife vehicles so far included. Needs to expand /0 capture all fixsd and mobile sysems d detection and protection PDVSA Centro de Refinaci6n Paraguana Recommendabons Update First Draft Date 03 0l1~m Ref20121139 Page 42 of 54 l!l QBE Sphere Del uge 08.2010 Priority A During the survey we requested a test of the deluge on Sphere 210 at Amuay, which has a single lop deluge water distributor. During the demonstration, the ' Sombrero Chino" (Chinaman's hat) water distributor at the top of the sphere detached, leading to a vertical fountain of water mostly missing the sphere. (see photo rigtt) A test of the deluge on Spheres E-01 & E-02 at Card6n revealed some blocked nozzles and some nozzles not properly pointing at the sphere, a~hoU!1J the overall cover of deluge water appeared to be adequate. (see photo below) These are the only deluges for which we requested demonstrations, and defects were noted in each case (a"hough rather minor in the Cardon test case). We Recommend: 1 That the "Sombreros Chino' of sphere 21 0 be promplly repa ired and that the attachment arrangement for the "Sombreros Chinos' on other spheres at Amuay be inspected and any necessary rereoar measures be taken. 2 That the cause of the blockage to the deluge nozzles at ceroco be determined, and remedied, 3 That the preventive maintenance prograrrvne for the sphere deluges be reviewed to ensure that proper 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 regulatly tested. Any remediation is entered into "SAP. 3. In Progress: A paper plan fOf deluge lests and routine maintenance exists since 2011 . being migrated to "SIC/ONE" See 07.2010 above.. POVSA Centro de Refinaci60 Para guana Recommendations Update First Draft Date 03 00/20" Ref2012/139 Page 43 0f 54 l!l QBE 09.2010 EN Button L.ocation, L.abelllng, Integrity and L.amps Priority 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 These pushbutlons and lamps are located around concrete colurms , potentially in positions at risk from plant incidents. They are poorly labelled and not at all "otNious", There are also issues of integrity such as damage to indicator li ~t, missing indicator Ii ~t bJlbs etc. In our opinion these critica l protection devices might be difficult to locate in an emergency, and once loca ted, 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 stations be clearly designated, by means 01 conspicuous colouring r::l the concrete column on which they are located. 3 That each individual EIV pushbutton module be clearly identified by tag number and the equipment served by the EIV. 4 That all EIV pust'bullons be reguarty tested and maintained in optimal operable conditions. C lient Conwnent: None Received March 2012 Status: CIO$d: All 4 parts, AI Cardon, pillalS idefllified by Ya/Iow Paint, with push-but/ens labelled by stencil. »»> AI Amuay, new motorisad valve panels have boon installed in some units, installation continlJeS in tum-arounds. (below) POVSA Centro de Refinaci60 Paraguana Recom mendations Update Rrst Draft Date 03 00/ >0" Ref20 121139 Page 44 0f 54 l!l Q8E 10.2010 Anomalous Pip ing Thi ckness MeasU"ement Readings in " SILCO" Pri ority B "SILCO' is PDVSA proprietary ilspection data managem ent so1lware used for eeercsen m onitoring and predictive inspection scheduling. It was nded that ilthe "SILCO" database, there were man y instances where there had been no recorded change in the recorded p",ing wall thickn ess for two or three measurement cycles. It was explained that w here a reading greater tha n the previous record was obtained , the previous value was retained, rather than recording the measuremenl taken . This is desp~e ' SILCO" automatically issuing a recomm endation to check the reading whenever a readi ng larger than the previous recor ded valu e for the sam e measur ement is input. The cause of lh e higher reading could be cat bratlon error, operator error, non-repeal able measu rement points, recording error , or the (In our opinion more ~kel y) possi bi~t y that the previous readilg had in fact been erroneously made and record ed 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 if calculated, might be lower than actual, leadil g to p oten~aly unsafe errors in the estimation of remainilg life. We Recommend : That whenever an anomalous wal thickness readi ng is observed, whether it be larg er than the previous value, or nd in accordance with the existing Trend: of change in the wall thickness, the measurement be checked by repea~ng the measurement using the same measurem ent instrument and a second measurement inslnJment that has been check calibrated. T his shwd preferably be done by a senior ilspeclor. Client Com ment: None received Marc h 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, I Is importart to realise that the principal d assl#7lirlg that the previotJs reading was #COf'I'l'd " is net satisflJdory. (symptom - applIrert IfJCffNlSfJ I,., wall thicknltss} PDVSA Centro de Refinaci6n Paraguana Recc mmendaecos U pdate First Draft Dat e 03 0l1~ , ~ Ref 2012/1 39 Page 45 of 54 o QBE 13. Observations The following observations were meoe to the MarlClgement of Centro de RelirlClciOn P,uagU<lna, ffiCli ~ during the close-out meeting. It was not our purpose to rrake new recommendations, anhough CRP rrerecerreot were encolXaged to act on these observations, Unsafe Conditions at A m uay 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 line serves both a therma l relief valve and a Nitrogen Purge point. It is also noted that thrs LPG line uses no hoist, and that there 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 packi ng (see below , POVSA Centro de Refinaci60 Paraguana Recom mendations Update First Draft Da te 03 00/20" Stru ctura l Inte grity Pro g ramme - good evidence of progress, but a long way to go, These pictures from Am uay PS/PVAY1 A<:t M ' IIl..... l!Je<:utl d l " ,1".11_ $Qpon.. E.lrUCI\It.lo. Tompor. lo. ' P- , ,,lNCIU' "'" Rewnplozadol l R _ '~11ing I Pinlur. ,Fi ep OOl" 1I The ' sooc t e Temporal' was installed to allow ope ration to continue until the structure was renov ated. Note that it was not fireproofed, hence the structu re was not etrectivel y protected ag ainst failure during a fire. The re novated structure restores the necessary fire-proofing. Note also that the repairs (tempora ry and renovations) were carried out as ' SIMOPS' - i e. on the run. Pla nt a PStPvay-1 Ac,lYId. _ ......_ !jOCUlI" ' ' ' ' Soponoo EIIN<lUrII.. T_ _ • '_ _'*'9 I Pmn R... ' 10. " 4 1 _...... ·F·"", oo611 ............. " . . ~I<_ , .. d•• • I I I " PDVSA Ce ntro de Refinaci6n Paraguana Recommendations Update First oaa Date 03 01/ 2012 Ref2012/139 "I " Pa{le 47 of 54 ~ QBE Much still to be oone, especially at Amua.y Structural Fireproofing on lhe structure of PSAY4, advanced degradation of structural fireproofing - to say nothing of lhe probable condition of the steelworlc it encases, New StructlXal Fireproofing on scccots to feed to almospheric ool~ PVAY-4 v acccrn Unit, Compromised structural fire protection and temporary support in place pending repairs 10 structure. v acoom Bottoms Line - pipe hanger from unprotected beam, bolt on sccoct clamp nol secure, no cercrceem. and as ye~ no EIV on column bottom. PV AY·4 Corrosion under msuaucn There is a programme 10 remedy this, POVSA Centro de Refinaci60 Paraguana Recom mendalions Update First Draft Dale 03 00/20" Ref20 12/139 Page 48 0f 54 l!l QBE Card 6n C04 Fire Repairs Highly congested and confined area of pumps, re-eers exposed l:¥ concrete spalling on underside of upper (exchanger) deck, not clear when (if) these are to be repaired. New pipe supports - not fireproofed Emergency Isolation Valve added to base of column. POVSA Centro de Refinaci60 Paraguana Recommendations update First Draft Da te 03 00/ >0" Ref20 121139 Pa ge 49 of 54 l!l QBE Jetties A mu ay J etties: Compact, Congested, incident on one likely to affect neighbour, in addition to the vessel on the adjacent berth, Hose handling Gantry - LPG hose (nearest) has not been supported l::¥ rotst, LPG line has motorised vatve , locally operate d. Relatively narrow jetty, ships close together. POVSA Centro de Refinaci60 Paraguana Recom mendations Update First Draft Date 03 00/20" Ref 2012/1 Mari fold valves for most products are manual, Adjacent jelly 4 has creesen Arms rathe r than hoses. Recently upgraded. The re are 2 clamps on the Kerosene line, to be elim inated at next TAM in 2013 Many clamps POVSA Centro de Refinaci60 Paraguana Recom mendations Update First Draft Date 03 00/20" on fire-water line, being replaced now (see new P'pes) Ref20 12/139 Page 51 of 54 l!l QBE Card 6n Jetties: \Nell separated, ships berth both sides, wider access ways and jetty heads than at Amuay. r - - - - - - -"""----, hoses Mix of for white products and articulated arms for LPG Complex manifold, some motorised varves, most manual. Emergency Isolation valve, failsa fe, (air 10 open, spring to c lose) some confusion ebcu tag ~, fireproof cover not replaced , actuation f rom local switch only. POVSA Centro de Refinaci60 Paraguana Recommendations Update First Draft Dale 03 00/20" Ref20 12/139 Page 520f 54 l!l QBE Foam sokncn rnamolds and air ventcns rounder-deck foam curtian Remote operated steerable elevated foamlwater «crecr. Hose w~h spl~ outer vulcanised layer, and rose to replace it (see test dale 00- POVSA Centro de Refinaci60 Paraguana Recom mendations Update First Draft Date 03 00/20" Ref20 12/139 Page 530f 54 l!l Q8E Rflf'lsk Under-dede structure e~lensively repecec Terrp;wary 5I.... o;.-. . t s '" ljed 10 original steel stru::tln, restW1l on new ccocrete sU>stNctU"e whle corICl"ete repaced. Slbstarnal sections of Upper Hose Handling Structure replaced. FOVSA Centro de RefinaciOn Pal1l gJlln& Recom mendations Update First Draft Date ro "" 2OU Ref20121139