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Eleme Petrochemical Company Limited 8th to 10th June 2009

88 Leadenhall Street London EC3A 3BA England Tel: +44 (0) 20 7623 1819 Fax: +44 (0) 20 7623 1817
Registered Office: Essex House, 12-13 Essex Street, London WC2R 3AA Registered in England No. 1994696 Charles Taylor technical Limited is an appointed representative of Charles Taylor Consulting plc which is authorised and regulated by the Financial Services Authority

A division of Charles Taylor Consulting plc

Insurance Survey of, Eleme Petrochemicals Company Limited, Port Harcourt, Nigeria

8th to 10th June 2009


Draft Charles Taylor technical

Revision
1

Date
October 2006 November 2006 December 2006 June 2009

Comments
Previous survey in March 2005 when the site was owned by NNPC Updated to comments include client

2 3 4

Revised to include new values and loss estimates Resurvey

Report for United Insurance Brokers, Mansell Court, 69 Mansell Street, London, E1 8AN

Insurance Survey of, Eleme Petrochemicals Company Limited, Port Harcourt, Nigeria

Main Contributors Doug Scott Issued by

8th to 10th June 2009


Draft

Eur Ing Doug Scott


B Tech C Eng CSci F I Chem E MEI

Charles Taylor technical

Reviewed by

Jeff Ashman BEng (Hon) C Eng MIEE Approved by

Richard Radevsky
BSc, CEng, CSci, CEnv, PEng, FICE, FCIWEM, MEI, MIFireE, FCIArb

Charles Taylor technical


88 Leadenhall Street London EC3A 3BA England Tel: +44 (0) 20 7623 1819 Fax: +44 (0) 20 7623 1817

Disclaimer This report has been prepared solely for the use of Eleme Petrochemical Company Limited (EPCL) and EPCLs insurance brokers and underwriters. Neither Charles Taylor technical nor its individual representatives shall in any circumstances be responsible to any other person for any loss or damage or liability however caused arising from the use of his report or the information it contains.

Executive Summary
Introduction Charles Taylor technical has been commissioned by United Insurance Brokers (UIB) to produce an underwriting risk survey report, for insurance purposes of the Eleme Petrochemical Company Limited facilities at Port Harcourt Nigeria. Significant Changes Since the Last Survey The site has undergone significant renovation since the last survey in 2006. There have been two further shut downs for refurbishment andf improvements after the low level of maintenance during the years of NNPC ownership. A small project has been undertaken to provide Virgin C5 feedstock to one of the furnaces. There has been an incident involving the Olefin plant cold box but this has been resolved without the need for an insurance claim. The plant is operating normally with the main limitation on production being the availability of feedstock. The Site Eleme Petrochemical Company Limited (EPCL) was originally a subsidiary of the Nigerian National Petroleum Organization Corporation (NNPC) but was sold to Indorama in May 2006. EPCL operates an olefins plant and downstream units, mostly polymers at Port Harcourt Nigeria. The facilities date from the mid 1990s. Natural hazards in the area are modest. The facilities are relatively modern with good spacing between the individual process units, utilities and the storage area. However, there is an element of congestion within some of the process facilities. The level of loss prevention features varies between process units, with only a limited number of remote isolation valves on large process inventories in the ethylene plant. Storage facilities are generally to modern standards but unusually, for a relatively new facility, do not have independent high level alarms. Administration Prior to the sale of EPCL to Indorama, NNPC maintained an unusually tight control over finances. This resulted in serious underfunding, particularly of the maintenance budget and no major overhaul of the site were undertaken between 1996 and 2006. The site organization generally follows accepted practice, with a direct reporting route from the safety manager to the site manager. There are currently no unusual features and a technical services group has now been established. Staffing levels have been significantly reduced from the approximately 1,200 present when NNPC ran the site and are now nearer 770. The previous NNPC management team have been replaced by ex-pat personnel and there are currently ex-pat personnel at all levels of the organization. However, future intensions are to employ and train Nigerian staff as far as possible.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

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Activities in most areas follow accepted industry practice but are, sometimes at an early stage. For example, the site will use the MAXIMO Computerised Maintenance Management System (CMMS) but this is still at an early stage of implementation, Whilst some updating of procedures and documentation has been undertaken, there is still room for improvement, even in some of the procedures which have already been updated. Fire Protection The fire detection and protection systems have been overhauled and are largely operational. However, a number of defective alarm systems were noted around the site. One of the electrical fire pumps was in continuous operation to supply water for wash down and a significant number of fire fighting hoses were being used for operational reasons. New investment includes a replacement fire alarm system in the polyethylene plant and a new fire truck. In summary, EPCL has vastly improved in terms of mechanical integrety as a consequence of the capital expenditure mantainence turnarounds since Indorma took over the facilities. The focus now needs to be in improving procedural aspects and ensuring all documentation at the site is updated. Insured Values The replacement values for the facilities were estimated by AVC (of the UK) in 2006 to be US$ 868 million. The property values have not been increased since. The business interruption sum insured is US$ 83 million with a 12 month indemnity period. Loss History Since Indorama took over the site, there have been two claims: May 2008 damage to cold box, this was subsequently withdrawn June 2009 loss of production as a consequence of lack of feedstock, currently estimated at US$ 4 million.

Loss Estimates
Property Damage (US$ million) 435 Business Interruption (US$ million) 166

Scenario

Combined (US$ million)

Property Damage

Vapour cloud explosion in the olefin plant following a release from the C2 splitter reflux drum Damage to the rotating elements of the olefin plant cracked gas compressor Complete destruction of the olefin plant cracked gas compressor

601

Machinery Breakdown

16.2

13.8

30.0

32.7

124.5

157.2

Note that underwriters exposure will be limited to US$ 83 million (the policy limit with a 12 month indemnity period) for business interruption losses

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

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Recommendations for Risk Improvement Ten recommendations were made as a result of the survey:
Recommendation
09-01 09-02 09-03 09-04 09-05 09-06 09-07 09-08 09-09 09-10

Description
Sampling Procedures Fire and Gas Alarm Systems Control Room Doors Urea Formaldehyde Foam (Cold Insulation) Document Control Operator Emergency Training Permit to Work (PTW) System Isolation for Maintenance Electrical Integrity Trip By-Pass Procedure

Category
Priority Priority CAPEX CAPEX Human Factor Human Factor Human Factor Human Factor Human Factor Human Factor

The status of the 58 recommendations from previous surveys is summarised below:

Recommendation Summary June 2009

Unknow n, 5 Withdraw n, 6 Com plete, 17

No Change, 7 In progress, 23

The key features of the site have been assessed using CTC Services Key Risk Rating Indicator System (KRRIS) for General Industry to determine the key risk features. For each of the key indicators (Hardware, Software, and Protections), a number of individual features have been identified and rated according to the KRRIS system. The higher the number (rated 0 to 4), the better the risk. The risks are also represented graphically (ranging from red for poor, to bright green for good). The results are shown below. Note that for some parameters, the rating appears to have been reduced. This is as a consequence of more information being available rather than a worsening of the risk which has improved overall since the 2006 survey.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

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2008 Charles Taylor technical

Overall Presentation Sheet


Printer Friendly Versi
Previous Assessment Latest Assessment 3.5 Previous Assessment Latest Assessment 2.8 Previous Assessment

Hardware
Natural Perils 3.5

Latest Assessment

Software
Management All senior management positions occupied by expats.

Protections
Fire and Gas Detection

Fire detection systems have been repaired and the system in the Polyethylene plant replaced.
4 3 2 1 4 3 2 1 0

4 3 2 1

4 3 2 1 0

However, a number of falied loops were noted in different systems around the site.

4 3 2 1

4 3 2 1 0

7 Parameters

5 2.6

5 Parameters

2 2.3

2 Parameters Water Supplies

0 3.0

External Exposures Minor exposure from other facilities. There has been previous unrest with the local community

Operating Procedures

Operating procedurs are a mixture of orginal and new procedures. Some operating manuals appear limitied and full information was not available.
4 3 2 1 4 3 2 1 0 4 4 3 2 1 0

Fire water system appears in good condition,. There is still a problem with use of fire water forwashdown, etc.
4 3 2 1 4 3 2 1 0 3 2 1

Some undesirable operating procedures were noted, for example the operation of flare drums on manual control 6 Parameters 0 1 2 2 1 2.9

9 Parameters Inherent Hazard

6 1.0

4 Parameters Drainage

1 3.0

Permit to Work System A new permit system has been introduced. And generally works well but some detailed improvements are possible..
4 3 2 1 4 3 2 1 0

No problems were noted with drainage during the survey.


4 3 2 1 4 3 2 1 0 4 3 2 1 4 3 2 1 0

6 Parameters

6 Parameters

3 Parameters

Layout

2.8

Maintenance

2.3

Layout between units is generally spacious. There are some congested areas within the units
4 3 2 1 4 3 2 1 0

A considerable amount of mainteance work has taken place since the take over by Indorama. The condition and reliability of the equipment is much improvied. Routine maintenance issues, such a s the full implenetation of the MAXIMO planning system needs

Process Area Fire Protection Systems have been repaired and are fully operational
4 3 2 1 4 3 2 1 0

1.9

4 3 2 1

4 3 2 1 0

2 Parameters

6 Parameters

6 Parameters

Control Systems DCS systems being replaced.

2.0

Engineering/ Technical Services A new technical serivces function has now been developed.
4 3 2 1 4 3 2 1 0

2.3

Offsites Fire Protection

1.7

Although control rooms are blastproofed, the doors are frequently left in the open position.

Systems examined were generally good. However some unsealed penetrations through dikes in the LPG area were noted.
4 3 2 1 4 3 2 1 0 4 3 2 1 4 3 2 1 0

3 Parameters

3 Parameters

7 Parameters

Process Safety Systems Limited process safety systems installed but upgrades being undertaken.

1.9

Management of Change

1.7

Utility Area Fire Protection Systems appear to be in good condition

2.0

A new management of change procedure has been developed but still has a number of drawbacks.
4 3 2 1 4 3 2 1 0 4 3 2 1 4 3 2 1 0

4 3 2 1

4 3 2 1 0

5 Parameters

3 Parameters

3 Parameters

Loading/ Unloading

N/A

Inspection Procedures

2.9

Most porducts are transported by truck in a non haardous form. A new road tanker unloading facility has been built with basic facilities.Pipeline systems were not reviewed in detail during the survey

4 3 2 1

Inspection Procedures are to a generally good standard with a well trained and enthusiastic workforce. Some aspects such as Positive Materials Indentification could be improved. The site is moving is considering a move to Risk Based Inspection 5 Parameters 0 1 1 1 3

Passive 1.8 Protection Level of passive protection varies between different process units
4 3 2 1 0 4 3 2 1 0 4 3 2 1 4 3 2 1 0

4 Parameters

4 Parameters

Storage

1.5

Safety Procedures and Practices

2.6

Foam Supplies

N/A

Storage areas need some refurbishment

Safety procedures are generally to a high stadard.

4 3 2 1

4 3 2 1 0

4 3 2 1

4 3 2 1 0

4 3 2 1

5 Parameters

5 Parameters

3 Parameters

Utilities

2.2

Further rehabilitiation of the utility systems has been done since the 2006 survey.
4 3 2 1 4 3 2 1 0

Emergency 2.4 Response A new fire training organization and emergency plan has been produced. Some further improvments are considered possible
4 3 2 1 4 3 2 1 0

Portable Equipment

3.2

Fire trucks are reported to be in good condition and a new fire truck has been purchased.
4 3 2 1 4 3 2 1 0

3 Parameters

6 Parameters

3 Parameters

Machinery

2.0

Security

3.2

Testing/Inspection Full details of testing were not obtained.

1.2

Much of the machinery has been overhauled recent, ecept gas turbines which are reported to be in a satisfactory condition+B25
4 3 2 1 4 3 2 1 0

Since a kidnapping incident there has been acontinuing improvemnts to security procedures and physical security systems.
4 3 2 1 4 3 2 1 0

However, it was determined that testing of the fire water pumps is not in line with NFPA standards.

4 3 2 1

4 3 2 1 0

2 Parameters

5 Parameters

6 Parameters

This sheet summaries the various parameters for each of the indicators shown above. For a full understanding of the individual parameters contributing to indicator, the individual hardware, software and protections worksheets should be consulted

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

Contents

1.

Introduction
1.1. 1.2. The Company The Location

1
2 2

2.

Background
2.1. 2.2. Insured Values Loss History

4
4 4

3.

Exposure to Perils
3.1. 3.2. 3.3. 3.4. 3.5. 3.6. 3.7. 3.8. 3.9. 3.10. 3.11. 3.12. 3.13. 3.14. 3.15. 3.16. Fire and Explosion Surrounding Exposures Subsidence and Collapse Earthquake Volcano Tsunami Lightning Flood Wind and Storm Vehicle Impact Vessel Impact Aircraft Impact Riot Strike and Civil Commotion Terrorism and Sabotage Machinery Breakdown Construction

6
6 6 7 7 7 8 8 9 9 10 10 10 10 10 10 11

4.

Loss Estimates
4.1. 4.2. 4.3. Definitions and Loss Scenarios Property Damage Business Interruption

12
12 12 14

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

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4.4. 4.5. 4.6.

Machinery Breakdown Machinery Breakdown Business Interruption Summary of Loss Estimates

15 15 16

5.

Description of Installation
5.1. 5.1.1. 5.1.2. 5.1.3. 5.2. 5.2.1. 5.2.2. 5.2.3. 5.3. 5.3.1. 5.3.2. 5.3.3. 5.3.4. 5.3.5. 5.3.6. 5.3.7. 5.4. 5.4.1. 5.4.2. 5.5. 5.5.1. 5.5.2. 5.5.3. 5.5.4. 5.6. 5.6.1. 5.6.2. 5.6.3. 5.6.4. 5.6.5. 5.6.6. Location Meteorological Information New Projects Turn Around Maintenance (TAM) Production Facilities Process Units Process Hazards Layout Control and Process Safety Systems Basis Control Room Design Emergency Shutdown Systems Remote Isolation, Depressurisation and Blowdown Pressure Relief Systems Combustion Safeguards Shaft Sealing Feedstock Supply and Product Transfer Road Pipeline Storage Facilities Atmospheric Storage Pressurised Storage Refrigerated Storage Warehousing Utilities Water Fuel Gas/Fuel Oil Steam Electricity Air Nitrogen

17
17 17 17 17 18 19 21 22 27 27 27 28 28 28 29 29 29 29 29 30 30 31 33 37 37 37 38 39 39 41 41

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

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5.6.7. 5.6.8. 5.7.

Flare Effluent Treatment Major Equipment Items

42 42 42

6.

Administration
6.1. 6.2. 6.3. 6.4. 6.5. 6.6. 6.7. 6.8. Organisation Operations Maintenance Engineering Inspection Safety, Health and Environment Emergency Response Security

44
44 44 49 54 56 59 63 64

7.

Fire Protection
7.1. 7.2. 7.3. 7.4. 7.5. 7.5.1. 7.5.2. Fire and Gas Detection Fire Water System Active Systems Passive Systems Mobile Equipment Fire Trucks Foam and Dry Powder Stocks

67
67 68 70 71 73 73 74

8.

Recommendations for Risk Improvement


8.1. 8.2.
Appendix A Appendix B Appendix C Appendix D Appendix E

75
75 80

New Recommendations Previous Recommendations


Plotplan Permit to Work Forms Management of Change Checklist Organizational Change Guidance Sample Fire Fighting Pre-plan

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

1. Introduction
Charles Taylor technical has been commissioned by United Insurance Brokers to produce an underwriting survey report for insurance purposes of the Eleme Petrochemical Company plant at Port Harcourt, Nigeria. Due to time limitations, not all parts of the site were visited and some information has been taken from other sources, including previous survey reports. The survey concentrated on Property Damage, Machinery Breakdown and Business Interruption risk to the facility. The following personnel were involved in the survey their assistance is acknowledged with appreciation.
United Insurance Brokers Marc Perrin Eleme Petrochemicals Co Ltd. Deepak Bang Subhash Chandra Sarkar S Dave A K Gupta Neerja Gupta V K Gurung B N Jha A Michinel A Mohapatra S Sadmanabham S B Sagdeo S H Sircar A Verma V K Gurung And others Head Commercial Head of Olefins Department Offsites Manager Power Plant Manager Utilities Manager Security Manager Projects Manager Technical Services Manager Polypropylene Plant Manager Polyethylene Plant Manager Instrument Maintenance Manager HSE Manager Inspection Manager Security Manager Senior Broker

This Underwriting Report is not intended to identify all hazards which may exist nor is it intended to be an exhaustive review of all possible eventualities. The recommendations for risk improvement contained in the report are advisory and the decision and responsibility for implementation rests with the site's management.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

1.1. The Company


Eleme Petrochemical Company Limited (EPCL) was originally part of Nigerian National Petroleum Corporation (NNPC) which is wholly owned by the Nigerian Government. However, in May 2006, EPCL was sold to Indorama, a multinational company based in Indonesia with interests ranging from petrochemicals, textiles and cement. Timeframe for the takeover is shown below:

The NNPC organization was centrally controlled, with individual subsidiaries having limited authority for expenditure and other decision making. This resulted in difficulties in planning, recruitment and maintenance of the major locations. The sale of EPCL to Indorama has loosened the constraints of central control and has allowed access to funds for long overdue maintenance at the site, as well as changes to the management structure and operating procedures. The senior management members at the site have all arrived since privatisation and are mostly Indian nationals. In addition, there are Indian expats at all levels within the organization. Most of the original Nigerian workforce has left EPCL for other parts of NNPC. Training programmes are being set up for Nigerian nationals with the long term intention of replacing Indian staff with Nigerian nationals.

1.2. The Location


Eleme Petrochemicals Company Limited (EPCL) operates a single petrochemicals site at Port Harcourt in the River Province of Nigeria. It consists of an ethylene cracker, polyethylene, polypropylene and a butene-1 plant, together with associated utilities, storage and infrastructure. The plant was commissioned in 1996 and had been operating continuously since then without a major shutdown for maintenance (Turn Around Maintenance or TAM) until 2006 when the management of EPCL was taken over by Indorama.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

Due to the lack of maintenance and feedstock limitations, the process units had seldom performed at anything like full capacity and were frequently shutdown. Since the take over by Indorama, there has been significant capital investment and a number of shutdowns for site wide maintenance and refurbishment. The plant is located near the town of Eleme, approx 15 minutes drive from Port Harcourt, the capital of Rivers State.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

2. Background
2.1. Insured Values
2.1.1. Property Values The replacement values for the facilities were estimated by AVC (of the UK) in 2006 to be US$ 868 million. A number of items commonly included in valuations such as office buildings, contingencies, debris removal and firefighting expenses have been excluded. Additionally, there is no value for stocks. A breakdown of the replacement value is given below:
Unit
Ethylene Cracker Polyethylene Butene-1 Polypropylene Polypropylene Bagging Polypropylene Bagging Storage Area (Including Pipeline to Refinery) Power Station Cooling Water Demineralised Water Air and Nitrogen Flare Area Effluent Treatment (Including Incinerator) Administration and General Refinery Tank Farm Total

US$
284,800,000 181,700,000 10,500,000 80,100,000 24,200,000 10,500,000 57,600,000 109,300,000 23,100,000 33,400,000 22,900,000 9,400,000 16,800,000 Excluded 3,700,000 868,000,000

The 2006 figures still reflect the insured values and reassessment would be advisable. 2.1.2. Business Interruption The business interruption sum insured is US$ 83 million with a 12 month indemnity period. A major Vapour Cloud Explosion (VCE) may result in rebuilding times well in excess of 12 months (24 months is commonly assumed) and therefore underwriters exposure is likely to be considerably less than the full business interruption figure.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

2.2. Loss History


Two claims have been reported since the 2006 survey:
Date Loss Amount US$
-

Details

Comments

May 2008

Damage to Olefin Plant cold box. The cause has not been positively identified but is probably due to thermal cracking of the cold box during start-ups and shutdowns since the plant was commissioned.

The claim was subsequently withdrawn. Repairs were made and a replacement cold box ordered. This has now arrived on site and will be installed at the next maintenance turnaround. The new cold box is of a more modern design to the original and is understood to be more robust. It is not clear if this loss is covered by the policy or not.

10 Jan 2009

4,000,000

Limitations of feedstock supply. This has reduced production at the plant and also caused an increased cost of working as a result of increased utility usage per unit of production.

A detailed loss history of the site prior to the take over by Indorama was not provided but the following information is available from previous survey reports and meetings during the survey. It is understood that there have been no significant insurance claims at the site since commissioning.
Date
10 Jan 98 03 Mar 98 23 Apr 98 13 Jan 98 22 May 98 17 Jun 98 11 Sept 98 20 Sep 98 25 Sep 98 25 Sep 98 Various Dates 1999 & 2003 Minor fire resulting from sparks from welding work, igniting gasoline from a flange being dismantled nearby Minor fire caused by leakages on Solution Absorber Unit at Polyethylene Plant Minor Fire from Major Leakage of Ethylene from Blanked Flange of Faulty Safety Valve Minor fire following leakage of hot oil from Polyethylene unit DTA Vaporiser Area Major Fire following Ignition and subsequent Explosion of Jerry-Can of gasoline in Natural Gas Liquids reception area control room Minor Fire: Catalyst leakage on flange of Polypropylene Plant Re-contacting Pot, Spontaneous combustion Minor Fire: Polyethylene plant IPS area, High Temperature in a Polymer Line ignited Insulating Material Small fires on process areas and extrusion plant, Minimal Property Damage, and Business Interruption in every case less than a few hours. Bush Fires following Flare Shoot-Outs

Event

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

3. Exposure to Perils
3.1. Fire and Explosion
Fire and explosion hazards are inherent in hydrocarbon facilities. The potential size of a loss will be determined by the inventories of hydrocarbon materials, spacing and fire protection facilities. The likelihood of a loss is related to operating and other procedures. These are discussed in detail in the main body of the report.

3.2. Surrounding Exposures


The nearest large industrial site is NNPCs Port Harcourt refinery (approximately 6 km away), there are also some oil production facilities (approximately 5 km away). There are no significant industrial activities around the EPCL site and exposure is considered low.

The Natural Gas Liquids (NGL) pipeline feeding the site terminates at a custody transfer point in a Nigerian Agip Operating Company (NAOG) terminal at the North West corner of the site. This terminal is operated separately but is understood to be insured under the same insurance policy as EPCL.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

Local communities extend to the outer perimeter fence in some places. In any event the process and storage facilities are located well away from the boundary fences and would not be exposed to small fires from shanty dwellings, car fires, etc.

3.3. Subsidence and Collapse


No signs of subsidence or collapse were noted during site visits, although there was very minor damage to some pipe support footings reportedly as a result of erosion from condensate drains noted in a previous survey.

3.4. Earthquake
The Munich Re World Map of Natural Hazards ranks the area as Zone 0 (on a scale of 0-4) equivalent to Modified Mercalli V or below.

In the unlikely event of an earthquake, there could be intensification for wet/loose sediments (sand and alluvial deposits) subsoil conditions in Port Harcourt.

3.5. Volcano
Approximately 400 km to the East of Port Harcourt is volcanic activity that stretches Southwest to Northeast in a line from the Gulf of Guinea to Cameroon. The Munich Re World Map of Natural Hazards provides the following information on volcanoes.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

3.6. Tsunami
The Munich Re World Map of Natural Hazards does not consider the area to be exposed to tsunami. In any event the plant is set well back from the sea.

3.7. Lightning
The Munich Re World Map of Natural Hazards ranks the area as Zone 1, with 2 6 lightning strikes per km2 per year. There are around 140 days per year and there have been numerous lightning strikes at the plant. At least two have resulted in minor fires. Actions taken to minimise the impact of lightning includes ground resistivity surveys.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

3.8. Flood
There is no history of flooding either from rainfall or sea water inundation.

3.9. Wind and Storm


The Munich Re World Map of Natural Hazards considers the area to have a medium exposure to hailstones and low exposure to tornado Whilst the region is prone to electrical storms, it is not generally subject to significant windstorm activity.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

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3.10. Vehicle Impact


Vehicles are free to travel on roads around the site and therefore vehicle impact is possible.

3.11. Vessel Impact


There is no jetty associated with the site and therefore marine impact is not possible.

3.12. Aircraft Impact


The Port Harcourt international airport handles both fixed wing and helicopter flights and is located approximately 25 km from the site. There is also a Chevron Texaco support base located around 5 km from the site. Flight paths are reported to avoid the EPCL site and no aircraft were noted overflying during the survey.

3.13. Riot Strike and Civil Commotion


There have been inter-tribal conflicts in the River State in recent years, together with a depressed economy. In consequence some serious anti-oil industry incidents, including theft, vandalism and sabotage have occurred. These have primarily affected the upstream oil industry but the downstream sector has also been affected. There has been previous resentment by the local community in the past but this has now eased following the increased deployment of armed police and troops within the site perimeter. This eventually culminated in the kidnapping of a number of Indorama employees and dependents (including women and children). The captives were released without loss of life and security has progressively increased ever since. In the near future, it is intended to house all Indoramas ex-pat staff and their families within the production site boundary.

3.14. Terrorism and Sabotage


There is considerable unrest in the Niger Delta region of Nigeria and the Nigerian Military are currently conducting operations against armed gangs in the region. There have been a number of incidents, including kidnapping, shootings attempted invasion of oil industry facilities, piracy and sabotage. A number of EPCL ex-pats and family members were kidnapped in a raid on the accommodation facilities but subsequently released unharmed. Security at the site, and in transit to/from the site has tightened considerably since that event. Much of the violence is financially motivated with kidnapping for ransom and theft of refined oil products (sometimes resulting in fires). The Products at EPCL cannot easily be resold and there are understood to have been no significant attacks or theft from EPCL facilities. The Aon Political and Economic Risk Map 2009 ranks Nigeria as High Risk, the second highest of six ratings. The Aon Political and Economic Risk Map 2006 ranks Nigeria as High Risk, the second highest ranking on a scale of five rankings.

3.15. Machinery Breakdown


Brief details of the machinery breakdown exposure are given in the table below.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

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Exposure
Boilers and Fired Heaters The major fired heaters are the cracking furnaces in the ethylene plant plus boilers.

Comments
The major risk associated with equipment of this type is tube rupture which will generally cause limited damage. However in extreme situations explosions can occur causing total destruction. A number of tubes have leaked and have been sealed off; there do not appear to have been any serious incidents associated with tube rupture.

Rotating Equipment

There are a large number of rotating equipment items, the key items being: HP compressors, particularly associated with the ethylene plant. Extruders associated with the two polymer plants. Gas turbines.

There is a wide range of incidents which can lead to damage of rotating equipment leading to varying levels of damage. Under most circumstances, damage will be limited to the rotating elements of the machine but, in extreme cases, total destruction can occur.

Transformers

There are a number of large transformers on the site Many transformers have fire walls between adjacent units but fixed fire protection is not installed. Catalysts

A fire involving a transformer is unlikely to spread to adjacent equipment, however, in the unlikely event of a transformer explosion, fire walls could fail resulting in additional damage to nearby units. In some situations, catalyst life can be reduced or destroyed as a result of process upsets or damage caused by fire or other perils.

Others

3.16. Construction
Whilst there is currently limited construction work at the site, there has been considerable activity as part of the TAMs which have now been completed. There have also been relatively modest capital projects such as the VC5 project to provide flexibility in the feedstock. Future TAMs and projects could result in construction type hazards such as crane collapse, excavation collapse, etc.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

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4. Loss Estimates
4.1. Definitions and Loss Scenarios
There are numerous definitions for defining levels of damage. Probable, Maximum Loss (PML), Estimated Maximum Loss (EML), Maximum Amount Subject (MAS) are amongst the terms in common usage. However, they are defined in different ways by different organizations. Definitions used in calculation of EML by Charles Taylor technical are given below: Probable Maximum Loss (PML) The loss that could occur if the installed process safety systems and fire protection systems operated as intended once the incident was identified. Such events would be typical process plant fires and explosions. Estimated Maximum Loss (EML) The loss that could occur if process safety systems and fixed fire protection systems were unable to function as a result of the incident. Such events would be the rare but highly destructive events that can occur in process facilities, such as detonations, Vapour Cloud Explosions (VCE) and High Pressure Vessel Ruptures. HPVR. Maximum Amount Subject (MAS) A catastrophic loss which could result in major damage, or total destruction of a site. Such an event would overwhelm the process safety systems and fixed fire protection systems. Such events would be natural perils, such as a major earthquake or extremely rare events such as aircraft impact.

In general, only the EML event has been calculated, as this is of the greatest significance to underwriters.

4.2. Property Damage


The following replacement values have recently been estimated by AVC and are used to calculate the size of loss below.
Unit
Ethylene Cracker Polyethylene Butene-1 Polypropylene Polyethylene Bagging Polypropylene Bagging Storage Area (including pipeline to Refinery) Power Station Cooling Water Demineralised Water Air and Nitrogen

US$
284,800,000 181,700,000 10,500,000 80,100,000 24,200,000 10,500,000 57,600,000 109,300,000 23,100,000 33,400,000 22,900,000

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Unit
Flare Area Effluent Treatment (Including Incinerator) Administration and General Refinery Tank Farm Total

US$
9,400,000 16,800,000 Excluded 3,700,000 868,000,000

The largest potential loss at the site is considered to be a vapour cloud explosion (VCE), the largest inventories of liquefied gas in the process area are:
Polyethylene Plant C3 Splitter Reflux Drum
D-35 Propylene/ Propane 18.1 Cyclohexane/Et hylene 110-140

Olefin Plant C2 Splitter Reflux Drum


D-32 Ethylene/ Ethane 23.8

Propylene Refrigeration Drum


Tag No. Contents D-44 Propylene

C2 Splitter Column
C-6 Ethylene/ Ethane 24.8

C2 Splitter Reboiler
E-59 Ethylene/ Ethane 27.8

C3 Splitter
C-8A/B Propylene/ Propane 19.3

C3 Splitter Reboiler
E-76 Propylene/ Propane 18.1

Cyclohexane Circuit

Pressure Kg/cm2 Temperature o C Diameter M Length T/T m Percent Full Volume M


3

1.3

-27

-22/2

-1

23

48

41

41

310

6.0 17.5 50% 247

4.6 61.65 144

2.914 12 90% 72

4.1 16.2 50% 107

4.65 104.4 180

2.49 4.88 90% 22

3.4 13.45 65% 122

Mass Kg Flash Fraction Mass of Cloud Modelled as:

151,905 0.12 18,229 Propylene

79,200 0.53 41,976 Ethane

39,600 0.85 33,660 Ethane

60,956 1.00 60956 Ethylene

104,400 0.64 66,816 Propane

12,540 0.61 7,649 Propane

75,030 0.57 42,767 Propylene

110,000 1.00 55,000 Cyclohexane

Note 1: 50% of cyclohexane assumed released (some parts of the circuit are at lower than maximum temperatures and pressures)

Using the Swiss Re ExTool method with an explosion efficiency of 6% for unsaturated hydrocarbons and 4% for saturated hydrocarbons, the worst case scenario is a release of ethylene from the C2 Splitter Reflux Drum (The largest release of olefins at the site) resulting in the following damage levels.

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80% Damage
Overpressure radius, M Static Loss, US$ Million Drift Loss US$, Million 125 29.46 76.07

40% Damage
283 238.68 231.23

5% Damage
448 4.89 3.30

Total

273.03 310.60

After making the following allowances, the loss estimates are given below: Fire following the initial explosion 10% Damage outside the plot areas 10% Debris removal 10 % Fire Fighting 1% Inflation 9% (based on 3 years at 3% per annum the loss occurring on the last day of the policy year, plus a two year rebuilding period).

The loss is estimated at approximately: US$ 435 million. Note that underwriters exposure might be reduced as some of the factors included in the calculation (e.g. debris removal and fire fighting expenses) have been excluded from the valuation. Damage contours are shown below:
Key 1 2 3 4 5 6 7 8 9 10 Polyethylene Warehouse Polyethylene Plant Butene-1 Olefins Cracking Furnaces Compressed Air/Air Separation Polypropylene Warehouse Polypropylene Plant Power Plant Water Treatment and Cooling Water

4.3. Business Interruption


A major vapour cloud explosion would result in large scale destruction of the plant involving a long period of downtime and replacement of major vessels and equipment. A repair time of around 24 months would normally be expected in this situation. The sum insured for Business Interruption is US$ 83 million for a 12 month indemnity period. The estimated loss is estimated to be: US$ 166 million but underwriters exposure would be limited to US$ 83 million.
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4.4. Machinery Breakdown


The largest machine at the site is understood to be the Olefin Plant cracked gas compressor. The replacement value for this unit was not obtained but by comparison with similar sized plants, a replacement value US$ 17 million in 2006. The well known Nelson-Farr cost index shows an increase of approximately 20% between 2006 and February 2009. A current replacement value of US$ 22 million has been assumed Whilst total destruction of a machine is rare, it may occur and two scenarios are postulated:
US$ Million Cost of Machine Damage to Rotating Elements (50% loss of machine value and 20% cost to strip the machine, replace the rotor and rebuild the machine) Synthesis Gas Compressor Additional Costs Inflation for 21 months at 5% per annum (incident on last day of policy year and 9 month replacement) Total Destruction of Machine (100% loss of machine value and 20% cost to strip the machine, replace the rotor and rebuild the machine) Additional Costs Inflation for 30 months (incident on last day of policy year and 18 month replacement) Total 22

15.4 12.6

3.6 16.2

26.4

6.3 32.7

4.5. Machinery Breakdown Business Interruption


The major machinery breakdown business interruption potential will result from a failure of one of the compressors in the ethylene plant. Using the same two scenarios as above, the following would apply: 1. Destruction of the rotating elements of the machine. Assuming spare parts are available, repairs and a resumption of production should be possible within a two-month period. The loss would therefore be: US$83/6 = US$ 13.8 million

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2.

Total destruction of the machine. The worst case scenario would be total destruction of the compressor with a replacement time in the range 12 to 18 months. The loss would therefore be: US$ 124.5 million

4.6. Summary of Loss Estimates


Scenario
Property Damage (US$ million) Business Interruption (US$ million) Combined (US$ million)

Property Damage

Vapour cloud explosion in the olefin plant following a release from the C2 splitter reflux drum Damage to the rotating elements of the olefin plant cracked gas compressor Complete destruction of the olefin plant cracked gas compressor

435

166

601

Machinery Breakdown

16.2

13.8

30.0

32.7

124.5

157.2

Note that underwriters exposure will be limited to US$ 83 million (the policy limit with a 12 month indemnity period) for business interruption losses

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5. Description of Installation
5.1. Location
The Eleme Petrochemicals Company Limited (EPCL) production facility is located approximately 15 km to the East of the centre of Port Harcourt. The site is elevated 15m to 18m above the level of the Bonny River, which runs 5km from the site, and there is no history of flooding in the area. 5.1.1. Meteorological Information Brief details of the meteorological conditions, when known are given below
Topology Lightning Temperature Humidity Rain Wind and Storm The area is flat and no terracing is necessary. There are around 140 lightning days per year and lightning strikes have affected the site. Maximum temperatures are approximately 32C to 33C, with minimum temperatures of approximately 22C to 20C. Humidity is typically in the region of 90%. Rainfall is approximately 3,000 mm per year, with the rainy season lasting from March to November. Prevailing wind from the Northeast in the dry season and Southwest in the wet season.

5.1.2. New Projects There are no new projects anticipated in the immediate future. However, in the longer term, it is anticipated that additional production facilities will be added in line with the original development schedule when the facilities were first constructed. These include an increase in the capacity of the ethylene plant and additional downstream units, possibly: Ammonia Chlor Alkali Ethylene Glycol VCM

The largest recent project was a modification to the plant to allow the cracking of Virgin C5 material in one of the cracking furnaces. This is now complete. 5.1.3. Turn Around Maintenance (TAM) A major concern at this location during the years of NNPC ownership was the lack of turnaround maintenance. Since then significant funds have been spent renovating the facilities in a series of TAMs. The total cost of TAM1 and TAM2 (split into TAM2A and TAM2B) were previously reported to be approximately US$ 130 million with: US$ 58 million being spent in TAM 1, and US$ 72 million being spent in TAM 2

Timing of the TAMs was:

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TAM1 2006 September 2006 TAM2A - May 2008 (26 days), the timing was adjusted to fit a window of opportunity caused by the failure of the Olefin Plant cold box. TAM2B - November 2008 (10 days), the timing was adjusted to coincide with a shutdown caused by interruptions of the NGL feedstock to the plant. Whilst a few activities are outstanding these are process rather than safety related.

Whilst the plants now appear in overall good condition, there are still some poor operational features, including the operation of flare systems in manual mode and the running of temporary connections in the polymer plants.
Polyethylene plant temporary connections note

5.2. Production Facilities


EPCL operate a modern petrochemical complex producing ethylene for the manufacture of polyethylene, polypropylene and butene1. Raw material is an ethane rich Natural Gas Liquids (NGL) feed from the Obiafu-Obrikom Natural Gas Liquids separation facilities operated by AGIP (as a NNPC Joint Venture). There are currently feedstock problems from the AGIP facilities which limit production. Further feedstock in the form of propylene from the Fluidised Bed Catalytic Cracker (FCC) at NNPCs Port Harcourt Refinery can be imported for use in the polypropylene plant. However the Port Harcourt Refinery FCC unit is often not operational and propylene cannot be supplied. Simple unloading facilities have been installed to unload Propylene Rich Feed (PRF) from NNPCs Warri refinery. A recent project has converted one of the cracking furnaces to operate on Virgin C5 feedstock. Pyrolysis gasoline, a by-product of the olefins plant is exported by pipeline to the refinery.

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A simple block diagram is given below:

5.2.1. Process Units Brief details of the production units are given in the table below.
Designation Capacity Tonnes/Year
300.000

Licensor

Contractor

Year

Comments

Olefins Plant

Kellogg "Millisecond" technology

Chiyoda Corporation

1995

Two of the cracking furnaces (including the one converted for Virgin C5 operation) have been upgraded with MERT tubes which increase cracking efficiency and increase the timing between shutdowns for decoking. Currently there is no polypropylene supply from the Port Harcourt refinery and the unit runs on propylene provided from the olefin unit. The unit will run continuously at 60% throughput or run for 3 weeks followed by a weeks shutdown whilst feedstock from olefin plant accumulates. The process of a VC5 stream and the import of PRF from Warri will increase the availability of feedstock and allow up to a month between shutdowns. It should be noted that start-up and shut down of units represent periods of greater hazard than normal operation.

Polypropylene

80,000

Montel (ex Himont)Spheripol technology

Technimont SpA and Japanese Gas Corporation (JGC)

1995

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Designation

Capacity Tonnes/Year

Licensor

Contractor

Year

Comments

There are 2 extruders each capable of 100% of production. 1 unit is operational, the other requires overhaul following a failure at some point in the past. An overhaul is planned for some point in the future. Polyethylene 270,000 Nova (Du-Pont) Sclairtech technology Kobe Steel 1995 This is a medium pressure unit, operating at approx 145 bar g. o 270 C. Twin extruders are installed Currently operating at approx. 60% capacity There are 2 extruders, each sized for approximately 75% of capacity, both are operational. Butene-1 22,000 Institut Franyais du Petrole (IFP) Alphabutol technology Kobe Steel 1995

Utilities and Offsites Infrastructure

Chiyoda Corporation Spie Batignolles

1995 1995

Current production figures for the polyethylene and polypropylene plants which consume all olefins from the olefin plant are shown below: Polyethylene Production

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Polypropylene Production

5.2.2. Process Hazards The main process hazards are associated with a flammable gas release or loss of containment of significant volumes of liquid hydrocarbons. Many of the processing steps involve handling of highly flammable and explosive gases at elevated temperatures and pressures. Transfer of gases and liquids requires the use of rotating machinery, often of high power, which is subject to mechanical breakdown and failure. Most materials in the process are light, flammable hydrocarbons (both gaseous and liquid). A potential exists for flash fires, jet fires and, in some areas of the plant, liquid pool fires. There are a number of spheres and other vessels with the potential for a Boiling Liquid Expanding Vapour Explosion (BLEVE). Sufficient quantities of volatile liquid hydrocarbons (predominantly ethane, ethylene and propylene) are present to form a vapour cloud explosion (VCE) in the unlikely event of a large-scale loss of containment. In addition, there are significant quantities of cyclohexane used as a diluent at high temperature and pressure in the polyethylene plant. In the polyethylene plant Tri Ethyl Aluminium (TEAL) is used as a catalyst, this material is pyrophoric and ignites in contact with air. Polyethylene and polypropylene plant extruders are heated using a thermal oil system. These units are relatively small and the hot oil system is heated by electrical heaters rather than a gas/oil fired heater. This reduces but does not remove the hazard. The cracking furnaces and boilers represent an ignition source. The polypropylene plant has the potential to undergo a runaway reaction and safe guards have been built in to the plant including a carbon monoxide catalyst kill system

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Refrigerated storage tanks can suffer rollover as a result of thermal layering with a warmer (less dense) layer below one that is colder (more dense). These layers can suddenly rotate or rollover with rapid vaporization of the warmer layer. High temperature hot oil systems are employed for process heating in the Polyethylene plant.

5.2.3. Layout The site is located on level ground totalling 440 ha and is bordered on the south and west by the Eleme-Okrika road. Brief details of the layout are given in the table below.
Details
General The existing process units are located to the south of the site.

Comments
There is plenty of space for future expansion and the new accommodation facilities constructed at the site are remote from operational and storage areas.

The Natural Gas Liquids (NGL) pipeline feeding the site terminates at a custody transfer point in a Nigerian Agip Operating Company (NAOG) terminal at the plant north west corner of the site. The process and utilities are arranged in 2 rows west to east in the following order: Row 1 (northerly row) Polypropylene warehouse. Polypropylene production. Power plant. Cooling Water Treatment. Systems, and Water Much of the area is open, particularly around the main administration building. This will limit the hazard faced by employees in the building in the event of a major explosion. Spacing between the various process, utility and storage facilities is also good, limiting the potential for domino effects from one area affecting adjacent areas. This is, in part, due to anticipated future expansion at the site, which has not so far taken place.

Row 2 (southerly row). Polyethylene warehouse. Polyethylene production. Olefin Unit. Vacant plot. Air separation and compressed air utilities.

These facilities are on individual plots approximately 150m by 250m, with separation by road, approximately 12 m wide. Storage facilities are located to the east of the site. Spacing within the process areas is congested in some locations. The flare-stacks and burn pits are located to the plant East of the currently unoccupied areas, with adequate sterile areas defined. Process areas are on concrete foundations surrounded by areas backfilled with stone. In some locations damage to the concrete pads supporting minor items of structural steelwork was noted. This could be a significant problem area with high earthquake potential but not in Nigeria where earthquake potential is low. This could limit access for maintenance and inhibit firefighting.

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Olefin Plant Cold Section

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Details

Comments

TEAL Preparation Area in the Polyethylene Plant

Piperacks

The level of fireproofing on piperacks is variable between process units. Generally pumps are not located under or partially under piperacks. Within the olefin plant, concrete around some of the minor steelwork supports was damaged, exposing the holding down bolts. Within the polyethylene plant fin fan coolers were not fireproofed to the full load bearing height. This will greatly minimise the potential for the fin fans to affect the extent of the fire. Whilst this does not appear serious, repairs should be instituted. The air flow from the fin fans will exacerbate flames from a pool fire. The provision of fireproofing almost to the top of the fin fan cooler will minimise the extent of damage caused by a pool fire under the fin fan. If the ground were sloped towards these drains, spills of burning liquid would run under the pipes and cabling, potentially causing significant damage. This provides a lower level of protection than cabling run underground. Cabling would be exposed to a fire under the piperack. A serious fire could result in lengthy re-cabling times, with resultant loss of production.

Within the olefin plant, drainage points are underneath the main piperacks.

Electrical Cabling

Cable routing in the olefin plant is partially below ground and partially above ground at the lowest piperack level. In a number of locations electrical or instrument cabling runs along the piperack at the lowest level.

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Overhead Cabling in the Olefin Plant

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Details
Compressor Houses Within the olefins plant, there are two separate compressor houses. Both refrigeration compressors are located within one building with a separate structure for the cracked gas compressor. The main compressor houses are roofed and walled around three sides at the upper level. The remaining side is left open to allow access for maintenance. The structures are open on all 4 sides at ground level. Within the olefin plant, the cracked gas and refrigeration compressors are in separate structures. Lube/seal systems are located to the side of the compressor, close to the plant. Fired Heaters The main fired heaters are the cracking furnaces and boilers are located at the Southern end of the olefin unit.

Comments

This will allow natural ventilation and prevent the build up of high levels of gas in the event of a release.

The close location of the lube/seal system to the compressor could result in damage in the event of a lube seal fire. The location of all the fired heaters in one location minimises the likelihood that a gas leak will find a source of ignition.

Cracking Furnaces and Boilers

A plotplan is shown in Appendix A.

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5.3. Control and Process Safety Systems


5.3.1. Basis Brief details are given below:
Details
Configuration: Each plant has a control system with separate hard wired ESD (Emergency Shut Down) system. DCS (Distributed Control Systems) are installed in all units. The original DCS systems installed when the plant was first commissioned are now becoming dated and a programme of updating is underway. So far the Polypropylene plant and the offsites systems DCS systems have been replaced. A number of companies have experienced problems, with alarm flood, during major incident. This results in literally hundreds of alarms being activated within a very short space of time. When this happens, the shear volume of alarms makes it difficult for operators to follow the exact sequence of events. Alarm management systems assist by filtering out the less important alarms

Comments

Type:

Neither the existing or new plants have alarm management functions

5.3.2. Control Room Design Brief details are given below:


Details
Location: Each of the process units has an independent control room; in addition there are control rooms for the power station and the storage area. Process control rooms are blast resistant structures but appear unpressurised. Whilst automatic door closers were originally fitted, these have, in some cases been removed or are ineffective, as in the polyethylene plant. Therefore doors may be left open, defeating the blast resistance. Some control rooms are located close to the process facilities The control rooms have fire detection systems. The control rooms have fixed fire protection systems covering the control system and adjacent instrument rack rooms. In some cases doors between the control and rack rooms are left open which will prevent the gaseous systems working effectively. This is believed to be due to problems with the air conditioning system and once repairs are made doors will be maintained in the closed position All the process control rooms had the doors in the open position which would negate the blast resistance of the structure.

Comments

Construction:

Smoke detection: Fire Protection:

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5.3.3. Emergency Shutdown Systems Brief details are given below:


Details
Type: All units have proper emergency control systems with critical safety related systems fully segregated from the control systems. These are hard-wired systems and these are not dependent upon computer software. In some cases, these are two out of three (2-O-O-3) voting systems. The polymerisation reactions in particular are exothermic, and have reaction inhibition systems, which inject chemicals into the reactors to kill the reaction immediately stopping reaction heat generation.

Comments

5.3.4. Remote Isolation, Depressurisation and Blowdown There are relatively few Remotely Operated Valves (ROVs) installed in the Olefins unit. ROVs are frequently installed in locations, such as pump suctions to prevent the contents of upstream vessels (such as drums and columns) being released to atmosphere in the event of a pump seal failure. This issue has been highlighted in previous survey reports and EPCL have identified 4 locations where ROVs are required. In 2 cases, they have now been installed. An ROV is installed on the feed drum in the polypropylene plant but the cabling is not fireproofed. ROVs are installed on the spheres and ethylene tank. 5.3.5. Pressure Relief Systems Brief details are given below:
Details
Configuration: With some exceptions single pressure relief valves have been installed on process duties. On a few duties, pressure relief valves are duplicated. Duplicated relief valves are installed on the spheres, complete with Castell key interlocks to ensure that a relief line is always open. In other cases, isolation valves associated with pressure relief systems are not sealed in the open position creating the potential for accidental isolation of the relief system.

Comments
It is difficult to test relief valves when the plant is operating when there are only single valves.

This will allow a valve to be removed for testing and inspection whilst the plant is in operation without the necessity of either taking the unit out of service or waiting for a shutdown.

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5.3.6. Combustion Safeguards Boilers, furnaces and direct-fired heaters have fuel gas management systems. Fuel gas isolation consists of a double block and bleed system. 5.3.7. Shaft Sealing Many of the pumps at the site handle liquefied gases and are fitted with double mechanical seals and seal failure protection.

5.4. Feedstock Supply and Product Transfer


5.4.1. Road The main products (polyethylene and polypropylene) are solids and packed in bags onto pallets and are exported by road. There are occasional road exports of liquefied gases from the site by a road tanker. Loading takes place in the offsite area by armoured hoses. A new installation for the import of propylene rich feed from Warri has been installed. This is a basic system with discharge via armoured hoses. A simple earthing system is installed. So far, this has only operated intermittently but in future, it is intended to import 2-3,000 tonnes per month and is shown below:

5.4.2. Pipeline There are a number of principle pipelines entering and leaving the site, brief details are given below.

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Product
Natural Gas Liquids (NGLs) Fuel Gas

From/To
Obaifu-Obrikom gas separation plant. Obaifu-Obrikom gas separation plant. 85 km 85 km

Length

Comments
The NGL and fuel gas line follow a common routing. The NGL and fuel gas line follow a common routing. Fuel gas from this line would be required for start-up but once continuous operation is underway, fuel gas for the site can be taken from the cracking furnace overheads.

Propylene Rich Feed Virgin C5+ Cracked C5+

Port Harcourt Refinery. Port Harcourt Refinery Port Harcourt Refinery

6 km 6 km 6 km

Currently out of use until the Port Harcourt refinery FCC is returned to service.

5.5. Storage Facilities


The site contains atmospheric, pressurised and refrigerated storage. 5.5.1. Atmospheric Storage Brief details of atmospheric storage are given in the table below.
No. Installed
2 2 1 1 2

Stored Material
Virgin C5+, Cracked C5+, Cyclohexane Ocene-1 Gas Oil

Capacity (M3)
4,630 1,671 2,000 2,000 2,050

Type of Roof
Cone Floating Cone Cone Cone

Further details are given below:


Details
Diking The tanks are grouped within main bund with around a diameter between the tanks. two floating roof tanks separated by a common wall. one tank The are This could allow overfilling, if the level gauging system failed. This will provide 2 independent readings and should avoid accidental overfilling. Radar type level gauging is considered very reliable.

Comments

Instrumentation

The tanks were not originally equipped with independent high level alarms. A programme of fitting radar type level gauges is underway. So far these have been fitted to 4 tanks and are in addition to the original level gauging systems.

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Details
Fire Protection All the tanks are fitted with semifixed foam systems and water deluge. Roof drains on the floating roof tanks are normally left open.

Comments

Drains

This will avoid a build-up of rainwater on the tank roof which could cause the roof to sink. However any leakage from the roof drain line could lead to the discharge of the tank contents into the diked area. This will avoid situations where almost empty tanks will float if there is a serious build up of rain water in the dike. However, it does raise the possibility that any spillage of hydrocarbons will not be contained, perhaps leading to running hydrocarbon fires along the drains system to the effluent treatment plant. Such fires could lead to ignition of nearby vegetation, this has happened in other locations.

The dike drains are also left open in the rainy period.

5.5.2. Pressurised Storage Brief details of pressurised storage are given in the table below.
No. Installed
3 NGLs

Stored Material

Capacity (M3)
3,809

Comments
These tanks operate -5 C and are thermally insulated. The insulation appeared in good condition. These were previously polypropylene tanks similar to those described below. They were o converted to operate at -5 C and have been thermally insulated
o

VC5

2,760

2 2 3

Propylene Refinery).

feed

(from

Port

Harcourt

2,760

Butene (Intermediate Product). Purified Propylene. 2,239

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Liquefied Gas Storage

Further details are given below:


Details
Diking The tanks are located in sloped concrete dikes with. The mastic used to seal the expansion gaps in some dikes has largely perished and, in its current condition, the dike may leak. Pumps are located remotely from the spheres. The tanks were not originally equipped with independent high level alarms. A programme of fitting radar type level gauges is underway. So far the 2 spheres converted to VC5 have radar level gauging in addition to the original level gauging systems. Gas detection is installed in some areas. Pressure Relief Duplicated relief valves are installed on the spheres, complete with Castell key interlocks to ensure that a relief line is always open. This could allow overfilling, if the level gauging system failed. This will provide 2 independent readings and should avoid accidental overfilling. Radar type level gauging is considered very reliable.

Comments
The dike however would allow liquid spillages to be contained under the sphere and a large spill, with subsequent ignition could result in a BLEVE.

Pumps Instrumentation

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Details
Motor Operated Valves ROVs, sample points etc. located on the outside of the dike wall, penetrations through the dike wall are generally well sealed but there are exceptions.

Comments

Dikes around Liquefied Storage Spheres

Fire Protection

All the spheres are equipped with deluge water sprays, operable from two locations. Sphere legs are fireproofed.

This should allow access to a valve under all wind conditions.

5.5.3. Refrigerated Storage Ethylene is stored in a 12,630m3 double skinned tank constructed by Entrepose of France to API 620.

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Brief details are given below:


Details
Construction Double wall tanks with a perlite filled annulus, constructed to API 620. There is a nitrogen purge through the annulus. Diking The tank is located in a sloped concrete wall dike, with drains leading to an impounding basin. Pumps are located remotely from the storage tank. The tanks were not originally equipped with independent high level alarms. Temperature is controlled via single Boil Off Gas (BOG) compressor, which returns ethylene gas to the olefin unit for re-liquefaction. When the ethylene plant is shut down temperature is maintained by venting gas to the flare. Fire Protection The tank itself is fitted with a water deluge system around its circumference. Medium expansion foam and water deluge systems are installed to cover the dike area. This could allow overfilling, if the level gauging system failed. An unusual feature of the tank is the fact that the flare vent control valve fails closed and in the event of a power failure or other interruption to the instrument air supply an operator needs to climb the tank and manually open the bypass. The mastic used to seal the expansion gaps in the dikes has largely perished and, in its current condition, the dike may leak.

Comments
There is reported to be some leakage of ethylene through the inner skin of the tank.

Pumps Instrumentation

At the time of the previous survey, the bellows on the fill/empty lines for the ethylene tank were distorted and a piping support was missing. Despite reports that the situation had been corrected, it was no different during the current survey.

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Piping Support with Rod Hanger Missing

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5.5.4. Warehousing

Bulk Polymer Storage Silos

The main products from the site are solids, with separate warehouses: Polypropylene - 19,000m2 warehouse Polyethylene - 42,000m2 warehouse.

Both warehouses are sprinklered.

5.6. Utilities
The site is designed to be self sufficient in utilities, further details are given in the sections below. 5.6.1. Water Brief details of the water systems are given in the table below.
Details
Raw Water: Sources Storage Treatment There are 8 boreholes of which 3 are normally 3 in use producing approximately 300m /hour. 2 tanks are installed, each of 55,000m capacity.
3

Comments

These tanks also provide the fire water supply.

Water treatment consists of 3 de-carbonators for carbon dioxide de-gasification and six sand filters to produce filtered cooling water.

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Details
There is also a demineralisation unit to remove sediment and ferric ions, plus 2 activated carbon filters for potable water. Cooling Water: A vent is installed in the cooling water return line. This is located on the return line itself rather than on the individual pipes to each cell.

Comments

Vents are often installed on the return lines of cooling water systems to avoid the entry of flammable gases (from heat exchanger leaks) from entering the cooling tower where they might ignite. The efficiency of the arrangement installed at the site is not clear, in the case of significant leaks; it may allow gas to be swept past the vent into the cooling towers.

The original cooling tower internals have now been replaced with polypropylene packing. Cooling tower fans are reported to have explosion proof motors. The gearboxes and motors have vibration alarms. No. of Cells There are 2 cooling towers, each with 5 cells. All cells are now operational and repairs to gearboxes and fans, reported defective in previous surveys have now been repaired. Packing in the cells is in relatively poor condition. Some has been displaced into the cooling water return line and blocked tubes in many of the exchangers. No. Normally in use No. of Pumps No. Normally in use 8 cells should be adequate for full operation but previously all 10 have been in use. 5 electrically driven pumps, 3 9,000m /hour are installed. each of .All are now operational. This will reduce the likelihood of flammable gas igniting.

The system is designed for 3 of the 5 pumps to normally be in use. However currently 4 of the 5 pumps are running to a degree of leakage in the cooling water system. Treatment consists of: 3 Activated carbon filters installed for condensate treatment. 2 Demineralisation beds. 3 mixed bed polishers. The Boiler Feed Water quality has previously been poor on occasions and this may have contributed to problems with the boiler tubes. Improved chemical dosing and monitoring are now in place.

Boiler Feed Water

In addition to provision of fresh Boiler Feed Water, there is significant condensate recycling. A new 2 bed unit with 100 m per hour is being constructed.
3

5.6.2. Fuel Gas/Fuel Oil Fuel gas is supplied by pipeline from the Obaifu Obrikom gas separation facility. This supply is used for start up or when the olefin plant is out of operation. Once stable operation of the olefin plant has been achieved, fuel gas is provided by the cracking furnaces. The gas turbines can operate on either natural gas or diesel fuel.

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5.6.3. Steam Brief details are given below.


Details Comments

No. of Boilers

All steam raising takes place on the olefins plant using the following: 3 Boilers each generating 120 tonnes/hour at 48 kg/cm2. 6 Cracking furnaces generating steam at 48 kg/cm2 and 109 kg/cm2.

The boilers have been refurbished as part of TAM 1.

Operating Configuration

Steam is provided by the cracking furnaces and the boilers. At low cracking rates all three boilers were required to meet steam demand. As demand increases, more heat from the cracking furnaces is recoverable as steam and 2 boilers will be adequate to meet demand. However normal practice is to keep all 3 boilers in operation at reduced flow rates to allow for the possibility of a boiler trip. During periods when boilers are taken out of service for statutory inspection, there will be no spare steam capacity.

Distribution

Steam is provided at 4 pressure levels: Ultra high pressure (109 kg/cm ). High Pressure (48 kg/cm ). Medium Pressure (11 kg/cm ). Low Pressure (5 kg/cm ).
2 2 2 2

5.6.4. Electricity Brief details are given below.


Details
No. of External Feeders There is a single feeder, owned by National Electrical Power Authority (NEPA) to connect EPCL to the Port Harcourt Refinery. However there have been problems of reliability and it is not now used. Previously following: EPCL exported power to the

Comments
Current status of this connect was not determined but the main power supply is from EPCLs gas turbines.

Pipeline and Products Marketing Company (PPMC), a NNPC subsidiary EPCLs housing colony.

The current situation is unknown but the small size of these loads by comparison with the installed gas turbine capacity is unlikely to affect plant operations.

In future EPCL might supply power to the Port Harcourt Refinery. On site Generation There are four GE Frame 6 power generators installed, each with a capacity of 33 MW. The units can be fired on gas, diesel fuel and it is understood, that they have been fired on propylene in the past. These units are reported to be in generally good condition.

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Details
The gas turbines are located within a large single building. The number of flanges on the fuel gas lines is limited. Operating Configuration Maximum demand is 35 MW, with current site demand at 19 MW. This is met by running 2 generators at approximately 50% capacity. Distribution Power is generated at 11 KV in the main generators, then stepped up to 33 KV. There are also 3.3 KV and 415 V distribution systems. Distribution system. is via a secondary selective

Comments
This will minimise the potential for a gas leak from a flange to generate an explosion within the building.

This will allow one machine to take over full load in the event that the other machine trips.

There is a load shedding system covering the site. High voltage switchgear is SF6 type, LV switchgear is vacuum type. Some simple, low voltage, extensions to the system have been made to assist with maintenance and routine work activities.

Temporary Electrical Fittings

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Details
Equipment Protection Emergency Generation Fire walls transformers. are installed between

Comments

Carbon dioxide systems are installed on the gas turbine generators.

Emergency power is provided by 4 diesel generators, each with a capacity of 2 MW. These have black start capability and feed the 3.3 KV system. The emergency generator provides power for: Control panel, lube system pumps and fin fan coolers for a gas turbine An instrument air compressor Hot flush system for the polyethylene plant Plus other critical duties.

5.6.5. Air Brief details are given below.


Details
No. of Compressors There are 4 electrically driven centrifugal, oil free, air compressors. The machines are each rated at 6,800 3 2 Nm /hour at 8 kg/cm g. 3 Units are required for full operation The air compressors supply plant and instrument air and also provide a feed to the nitrogen generation unit. Air Treatment: Back-up Facilities Air driers are installed for the instrument air system. Air receivers provide buffer 15 30 minutes capacity for the instrument air supply. In addition, some plants have small independent instrument air compressors. This represents a satisfactory level of backup. When all process units are in full production, there will be no standby machine.

Comments
A new unit is in operation to replace one of the original units which has been cannibalised for spares.

Capacity Operating Configuration

5.6.6. Nitrogen Brief details are given below.


Details
Type of Supply An Air Products cryogenic nitrogen unit is installed.

Comments
The air dryers for the unit have previously been ineffectual, allowing moisture to pass with subsequent freezing in the cryogenic unit. Since the takeover of the site by Indorama, the molecular sieve has been replaced and the unit is reported to be working satisfactorily

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Details
A new nitrogen unit has been ordered from the Suzhou Oxygen Plant Company (SOPC), China. Some equipment items for the unit have been purchased directly by EPCL rather than sourced through SOPC.

Comments
Whilst this may not be a company widely known in the West, they are reported to have built over 600 units worldwide. Further details can be found at: http://en.suyang.com.cn/newEbiz1/EbizPortal FG/portal/html/gysy.html?GeneralContentSho w_DocID=c373e9087b27eebd8f6bc4f684d8e 91b

Capacity Storage

Capacity is 3,400 Nm /hour of gaseous 3 nitrogen and 390 Nm /hour of liquid nitrogen There are 3 liquid nitrogen storage tanks each 3 with a capacity of 184 m .

5.6.7. Flare The plant has three main flare stacks and a burn pit, details of the flare stacks are given below: FS1 (76.2m high) covering the olefins plant and utilities (note that there do not appear to be separate cold and wet sections to the flare which could result in water rich streams in contact with cold streams freezing and causing blockage in the flare lines) FS2 (76.2m high) FS3 (25 m high) covering the polypropylene and polyethylene plants covering the ethylene storage tank

Flare drums are reported to be instrumented with automatic pump out on high level together with steam coils for evaporation of the drum contents. The flares and burn pit are located to the northeast of the site with limited potential for damage to the process or utility systems. 5.6.8. Effluent Treatment The system has segregation between the storm water and oily-water drainage systems with all oily drainage directed through to a proper drainage system in the water treatment area. The storm water system is largely open and underground sections have gas seals to prevent the movement of flammable gases through the drain system. The seals are vented to atmosphere with flame arrestors installed. Whilst the main drainage channels are largely clear of vegetation, in several locations small drains feed into the open drains and these are fitted with metal grids, presumably to prevent rodents, etc entering the system. Many of these are partially (in some cases almost totally blocked) with debris and could restrict discharge. Effluent clean up consists of corrugated plate oil separation, air flotation and biological treatment, plus the standard API separator.

5.7. Major Equipment Items


A full list of the main equipment items was not provided by EPCL but the major rotating machines are believed to be:

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Manufacturer
Olefin Plant Cracked Gas Compressor Olefin Plant Propylene and Ethylene Refrigeration Compressors Power Plant Gas Turbine Generators Elliot/Mitsubishi

Comments
The unit is currently operating with the spare rotor installed. An overhaul took place as part of TAM2. The units are currently operating with the spare rotor installed. . An overhaul took place as part of TAM2.. The units are understood to be in good condition with 2 units having hot gas path inspections in 2004. One unit was overhauled in TAM2 and then, I unit will be overhauled each year for the next three years. There are 2 extruders each capable of 100% of production. 1 unit is operational, the other requires overhaul following a failure at some point in the past. There are 2 extruders, each sized for approximately 75% of capacity. 1 is currently operational and the other is being overhauled.

Elliot/Mitsubishi

GE (Frame 6)

Polypropylene Plant Extruders

Polyethylene Plant Extruders

Further details of equipment maintenance is given in section 6.3.

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6. Administration
6.1. Organisation
Since the takeover of EPCL by Indorama, many of the original NNPC staff have left. The senior management now consists of Indian ex-pats. The staff at the time of the takeover by Indorama was around 1,000, currently, there are approx 600 local staff and 170 expats. The former NNPC staff who have left the site work in other NNPC business units and there were no significant redundancies that might have triggered resentment against the company management. EPCL intend to recruit local staff, as far as possible and training programmes are being established, the last ex-pat recruit arrived at the site around a year ago. The managing director of EPCL has three main reportees: Finance and Administration Commercial Site

The site head has reporting to him the key components of the site operations: Olefins Polymers Offsites/Utilities Maintenance Technical Service Health Safety and Environment (HSE)

The HSE function, in line with good practice, has direct reporting to the site manager. The previous EPCL management, under NNPC had limited financial authority and even relatively minor requests for expenditure had to be approved at a corporate or even Government level. The change of ownership has removed the previous financial restrictions, allowing much better access for funds for spare parts and other uses. This is demonstrated by the extent of work performed in the various TAMs since Indorama bought the site and increase in expenditure on new utilities, replacement olefin plant cold box, etc.

6.2. Operations
Brief details of the operations group are given below:
Details
Organisation and Staffing Levels The operational activities are split between three main groups: Olefins (sub dived into hot and cold sections)

Comments

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Details
Polymers (subdivided into Polypropylene and Polyethylene & Butene) Power Utility and Offsites.

Comments

Each unit has a plant manager and production manager (working days), plus shift teams as follows:

Polypropylene/ Butene 1

Polypropylene

Olefin Plant

Shift Engineer Panel Operators Field Operators

1 2 5

1 3 8 1 1

1 1 4

1 1 2
2

4 8

1 Shift engineer and assistant, the olefins plant is split into hot and cold sections. 2 Plus one field operator at NNPC Outside day working hours, there is a shift manager in charge of the site. This will ensure a good level of communication and control in the event of a major event. In the absence of a nominated individual, confusion can arise over who takes initial charge of an emergency and who has authority to shut down the plant. 8 hour as apposed to 12 hour shifts .will reduce the level of fatigue faced by shift personnel, particularly during hot weather. There will not therefore be a sudden large reduction in the overall level of operating experience in the near future. This is a common procedure in polymer and other plants with large solids warehouses.

The site has four shift teams working a three shift system. Most operators are understood to be in the age range of 20- 50. Warehouse activities (bagging, fork lift truck driving, etc.) will be largely performed by contractors under the supervision of EPCL staff. Budget Budgetary pressures were apparent when NNPC were the operators of the plant. There now appears to be significantly greater resources available. EPCL now have a training department which coordinates training across all parts of the organization. At field operator level, a mixture of experienced operators, plus some trainees will be deployed. Trainees will be college graduates with a science or chemical engineering diploma.

Training

Offsites Recruitment from the local area helps to reinforce good relationships with the local community.

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Utilities

Power

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Details
The recruitment process includes a written test. A number of experienced Nigerian operators, mostly with ammonia plant experience, have also been recruited. Trainees will undergo a mixture of classroom and on the job training lasting approx. 18 months. Progress is measured by a mixture of continuous assessment and interviews rather than by written examination Operators will initially be trained for a single operational role on one unit but as they gain experience will train in a number of positions. The recruits from 2006 are now fully trained field operators and are now learning panel operation. A process simulator is available but has not been fully configured. Experience Most, but not all, operators are graduates. For more senior positions, including panel operators and above, EPCL are appointing experienced process operators. These are ex-pats, NNPC secondees or Nigerian staff with experience in the process industries. Some of these will be recruits from NNPC but there have also been a number of recruits from NAFCON (fertilizer manufacturer). There are a number of Romanian nationals who have senior operating positions and have worked at the site for a number of years. Many of the NNPC secondees are understood to have been at the site since start up. Documentation: Standard Operating Procedures Completeness Operating procedures have been partially revised and updated since Indorama took over the site. Quality of procedures varies; those in the Olefin plant were limited with little information available in the folder examined with pages in the wrong order and some pages missing. Checklists have been developed for activities such as start up of fired heaters. Log sheets are being developed for the field operators to complete. Updating Instructions have been partially updated since Indorama took over the site. However those reviewed in the Polyethylene plant dated from the 1990s. P&IDs in the Polypropylene plant date from the time of construction; Up to date P&IDs are reported to have been produced but are not yet available in control rooms

Comments
This will ensure that all recruits have an adequate command of the English language.

However, there are still a number of areas for improvement.

Checklists

The use of checklists for start up can be useful and is widely practiced. For example to ensure that fired heaters and boilers are purged before firing and for ensuring that lube oil systems are functioning before compressors are started.

Out of date P&IDs can cause problems and mistakes by operating personnel.

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Details
Emergency Response Procedures Quality of emergency procedures is variable between units but, in most cases, there are no short form emergency procedures. Those in the Polyethylene plant were vague and not well formatted. Instructions were not in a step by step format.

Comments
Due to the defects defined below the preparation of short form emergency shutdown procedures is desirable and the site management are currently preparing them. The site management are currently reviewing the existing emergency shutdown procedures in the light of the comments made.

The particular set of emergency procedures examined had a number of defects, which reduce their value: The indexing is poor. The instructions are relatively densely written. Actions for all personnel appear to be written in the same part of the document with no split of the activities between the individual field operators. This would increase the time needed to find the appropriate instructions. Well laid out instructions ease understanding, particularly during an incident. It would be preferable for the tasks to be undertaken by each individual operator to be laid out separately to facilitate clarity of understanding. Under emergency conditions operators may react in unexpected ways and regular field simulations are often considered a helpful way of reducing operator error. Without this operators may be confused as to the location of the critical valves and other equipment.

Some emergency shutdown training takes place but this appears to be classroom based.

Process Upsets

A reporting procedure for process-upsets is being developed. The first stage is the completion of a First Information Report. After investigation a Facts and Analysis Report is produced with lessons learned. A previous survey recorded that all alarms are recorded on the DCS system and no problems with alarm flooding have been reported. A number of companies have experienced problems, with alarm flood, during major incident. This results in literally hundreds of alarms being activated within a very short space of time. When this happens, the shear volume of alarms makes it difficult for operators to follow the exact sequence of events. Alarm management systems assist by filtering out the less important alarms. This problem has been identified and will be addressed as part of the DCS upgrade.

Communications/Shift Handover

Shift logs are maintained by the shift engineer and panel operators. The condition of the plant is discussed by the oncoming and outgoing supervisors but only the outgoing supervisor signs the log book. In each plant, there is a log book for each area. Field operators hand over in their respective shelters.

It is often considered advantageous for both the outgoing and incoming supervisors to sign the log book to ensure that there has been a thorough exchange of knowledge. A better alternative, in most cases, would be for the field operators to walk round their area as part of the handover process.

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Details
Control of Maintenance: Types of Permit The permit to work system has been revised since the last survey. The Permit to Work System consists of the follows forms: Cold work (including excavation) Hot work (including radiography)

Comments
Copies of the permits are given in Appendix B. Whilst the main types of permit are covered, the use of cold work (to include excavation) and hot work (to include radiography) may result in difficulties. For example, before excavation work takes place, a check is required to ensure that there are no cables or piping in the area where the proposed excavation will take place. This is not a normal requirement of cold work permits. Permits contain a checklist of safety procedures, in line with accepted practice.

Vessel entry

The new vessel entry permit is basically a checklist and does not appear to contain the same requirements for approvals and hand backs as the hot and cold permits. It is used in conjunction with a hot or cold permit.

Electrical isolation permit

Excavation activities are covered under the management of change procedure. No. of Copies There are 3 copies of the permit, one each for: Operations department Maintenance supervisor A better alternative would be for the maintenance copy to be kept at the job site (in a plastic envelop for weather protection). This would allow operational and safety staff to check that the safety conditions required on the permit were being followed. The operations copy of the permit is available in the control room

Signatures

Safety department. Many of the permits examined in the olefins control room did not have a full set of hand back signatures. One disadvantage of the new permit form is the fact that the signatures at the start of work are on the front of the permit and the hand back signatures are on the back. This makes it difficult to determine if a particular activity has been completed at a glance. Validation of all permits after each shift would be advantageous as working conditions for colds permits may also change. These are still mostly permits in the old NNPC style. This can lead to confusion over the status of work and, possibly, attempts to operate equipment not yet fully repaired. Permits are not uniquely numbered and in some cases, several permits may be required for one task. Currently there is no way of linking the individual permits for a particular task and printing unique serial numbers on each of the permits would be beneficial.

Signatures are required from operations, maintenance and safety personnel both before work starts and after complete. Unusually, the handback signatures are on the reverse side of the permit form to the authorization signatures.

Validity

Permits can be valid for up to 1 day without validation. Hot work permits are understood to require validation after each shift. Copies of recent permits are filled in the control room. A common folder is used for filing all permits with no differentiation between continuing and completed work. Permits are individually numbered.

Filing

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Details
Isolation Procedures: Mechanical Reliance is placed on closing of valves and where pipework is opened blinds are installed.

Comments

The use of padlocks to ensure that valves are not opened by mistake would be useful. An isolation procedure defining appropriate levels of isolation should be established.

Electrical

Electrical isolation is achieved by racking out electrical equipment.

This will provide effective isolation but the use of a padlock on the isolator handle would represent an additional precaution against errors. The site management are currently reviewing the adequacy of the existing system.

Instrument

A trip bypass register exists and was originally set up by NNPC. For short term bypasses, approval is given by the head of the department. Longer term bypasses require a more senior level of approval. There is a trip bypass register for each unit. Bypasses are checked regularly as part of the regular technical services reports. The registers in some units, particularly the olefins plant, were confusing and not easy to follow.

Some undesirable features were noted during site visits such as the short term discharge of liquefied hydrocarbons in the plant when samples were being taken, the operation of flare drums on manual control rather than automatic pumpout and temporary connections in the polymer units.

6.3. Maintenance
Brief details of the maintenance function are shown below.
Details
Organisation and Staffing Levels The Engineering department is responsible for maintenance activity and has 2 main branches: Central Services: Workshop (includes: scaffolding and insulation) Condition monitoring Motor fleet Civils As in other areas, there are changes in staff numbers and recruitment of new personnel. The current staffing levels within the main process and utility facilities are shown below: Plant Maintenance: Olefins Polypropylene Polyethylene Power plant/ utilities Bagging

Comments

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Details
Ex-Pat Mechanical Electrical/ Instrument 9 13 Local 38 59

Comments

Previously an area based maintenance philosophy was used and the current maintenance organization suggests that a similar philosophy will be adopted in the future. Whilst plant start-ups are underway, there will be a small shift team of: Supervisor 4 mechanical technicians 2 electrical technicians 2 instrument technicians

This will allow personnel to become familiar with problems associated with particular types of equipment. This represents a good feature and will allow minor defects to be repaired quickly, avoiding the potential for them to escalate.

The shift team will be disbanded after the plants have been fully restarted and stable operation has been maintained. Budget Budget constraints were a problem when the plant was operated by NNPC with the plant operating for 10years without a maintenance turnaround. The total cost of the TAM1 and TAM2 is approximately US$ 130 million and these funds have been approved. Training EPCL now have a training department which coordinates training across all parts of the organization. There is a training facility at the site with an apprenticeship programme. Initially, EPCL recruited experienced personnel and many of these are still on site. Additional specialist training is provided where appropriate, for example for the new DCS systems. Experience EPCL has employed experienced maintenance personnel, either under secondment from the previous NNPC personnel or as ex-pats. There are also a number of Indian ex-pat personnel, generally at supervisor level and above. Experience levels are reported to be adequate and staff turnover levels are low enough to prevent a drain on the resources available. Philosophy Since the plant was taken over by Indorama, there have been 3 maintenance turnarounds: TAM 1 TAM 2A TAM 2B Major turnaround in 2006 26 day turnaround in May 2008 10 day turnaround in November 2008 . Funds for maintenance activities have a much greater availability than when NNPC operated the plant.

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Details
There are currently no firm plans for a further TAM but one is anticipated around March 2010 to install a replacement cold box in the olefin plant.

Comments
The current level of maintenance shutdowns since Indorama took over the site is much higher than would normally be expected and reflects a backlog of maintenance from the days of NNPC ownership. Once a satisfactory level of maintenance has been achieved, there is no need for TAMs to occur on an annual or twice annual basis.

Planning

Currently spreadsheets are being used for maintenance planning. The MAXIMO Computerised Maintenance Management System (CMMS) will be implemented and will initially be used on the polypropylene plant. Currently data is being collected for future implementation. Training in soft skills is being undertaken to assist personnel to use MAXIMO correctly. It is reported that future TAMs will be undertaken at a maximum of 4 yearly intervals. However a further shutdown is being planned to install a replacement cold box in the Olefin plant. At this stage, it is probably too early to determine TAM frequency. This will only become apparent after the unit has been operating in a steady state condition for some time. Non-intrusive techniques should give a general indication of the condition of the plant. Maintenance under NNPC suffered from lack of financial resources and the current situation is much improved.

Performance

EPCL have developed a system of KPIs (Key Performance Indicators) for the site. These show a current availability of 99% There currently appears limited overdue maintenance and these tasks which are overdue are understood to require maintenance shut down for completion.

Documentation

Most maintenance records are in hard copy and soft copy form. The soft copy is kept on EPCLs server. Vibration monitoring systems are installed on large rotating equipment items such as: Main compressors in the ethylene plant (Bentley Nevada 3500 series). Gas turbine generators. Instrument air compressors (4 units) Reactor feed pumps (3 units)

This situation will ensure that a fire or other incident in the records office will not destroy the entire maintenance history of the plant.

Mechanical

Bentley Nevada personnel visit EPCL every 3 months to monitor equipment and review result from the vibration monitoring equipment. New data capture type vibration monitoring and analyser (SKF CMX Series) equipment has been purchased and technicians trained in its use. Vibration monitoring is performed at intervals as shown below: Vibration Equipment Covered Monitoring A Equipment with: High capital cost Weekly This represents an expansion in the vibration monitoring programme since 2006.

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Details
Impact production on

Comments

Impact on safety/ environment B Equipment: On standby More than 22 kW, and Operating above 2,800 rpm C Equipment: On standby, More than 22 kW, and Operating between 1,400 and 2,800 rpm D Balance equipment of When required Monthly Fortnightly

Vibration trips are installed on the gearbox and motors of the cooling tower fans. An in house lube oil testing programme has being set up with regular checks on moisture, viscosity and particles. If problems are suspected, lube oil samples will be sent for ferrographic analysis. Dye penetrant testing was performed on the rotating elements of key equipment during TAM1. No problems were identified. There is some equipment balancing capability at the site but larger items would probably have to be returned to the manufacturer for balancing. There were initial problems with the olefin plant compressors as a result of solids deposition on the rotors. There were also initial problems of high bearing temperatures. All the rotors have been rebalanced and some replacement bearings installed. An additional injection system was installed to suppress polymer formation by the injection of Actrene and this appears to be successful. There has been a recent major overhaul of GT 4 and there are plans to overhaul GTs 2 & 3 within the next year. Previously, the machines have been operating at part load which is reported to increase the EOH (equivalent operating hours) of each machine. However this is, at least in part, compensated for by a relatively low number of starts. During TAM1, lube oil quality was found to be poor with significant contamination by water and solids. This has now been rectified.

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Details
Electrical The oil in all transformers underwent a Dissolved Gas Analysis (DGA) and dielectric test at TAM1 and no problems were identified. Further DGA is anticipated in the future and the transformer oil has been filtered. Dielectric testing task place every 6 months. Annual earthing checks are undertaken. To date a thermographic camera has not been used at the site.

Comments
DGA may be valuable for determining the early stages of transformer oil breakdown on large critical transformers.

Thermography is increasingly used as an economic non invasive method of detecting faults. This may be a useful technique for use prior to the TAM to identify equipment which might be in need of repair. Lack of suitable facilities could lead to long periods of downtime whilst a motor was shipped abroad to the manufacturer.

There are understood to be facilities for balancing large electric motors in the region. Some equipment is obsolete and replacement is taking place, including some DC machines and invertors. Instrumentation Full function tests on all trip systems were undertaken during TAM1.

Some components, particularly solenoid valves have required replacement. The previous CTt survey in 2006 reported a number of bypasses of trips in the olefin plant. Whilst the trip bypass register was reviewed during this survey, it was in a confused and the state of trips was not always clear.

There is no on line trip testing of the process trip systems. However tests will take place if a problem is suspected.

Some systems are partially duplicated which would allow partial testing online. However, many companies are often reluctant to perform on line testing to prevent an accidental shutdown of the plant. The trip systems on the polymer plants are considered less critical as they generally have frequent short shutdowns for cleaning and grade changes which would allow trip testing to be undertaken.

It is now current practice to regularly exercise the trip valves on the steam turbines. Some equipment is obsolete and replacement is taking place. For example, the fire detection system in the polypropylene plant has been replaced and a new system for the polyethylene plant is on order. Spares Insurance spares include rotors and diaphragms for rotors for the olefin plant compressors and turbines. Rotors are stored vertically and some are within nitrogen containers There have previously been problems with the supply of consumables stored but the new EPCL management do not consider that this will be a problem in the future.

In situations where there is poor steam quality, scale can build up across the valve seat preventing it from closing in an emergency.

Rotors for turbines and compressors have either been replaced or refurbished. Vertical storage will prevent distortion of the shaft in storage, and nitrogen will protect against corrosion. EPCL, through their new owners Indorama, have greater access to funds than NNPC and this assumption is likely to be correct.

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6.4. Engineering
Brief details of the engineering function are given below.
Details
Organisation and Staffing Levels Since the previous CTt survey there has been a reorganization and the creation of a technical service department with the following 3 sub groups: Projects Process Engineering Library The library currently contains 3 copies of the site documentation as hard copies and microfilm. Further copies are available in other departments. EPCL have started a process of scanning a documents and drawings into pdf format and storing them on a server. In the longer term, it is intended for all documents to be available on EPCLs intranet. Key documents and drawings, such as Process and Instrumentation Diagrams (P&IDs) will be controlled documents. The availability of documents on the intranet could lead to numerous copies being printed by members of the workforce, making it difficult to ensure that documentation is up to date. It would therefore be prudent to ensure that uncontrolled copies (those printed without authorization) are marked or water coloured in some way. Controlled documents need to be clearly marked and a distribution list kept, ideally with superseded documents being returned to document control for recording and destruction. Although software is available which will scan drawings and convert them directly to AUTOCAD format, EPCL have found that so much manual correction is necessary that it is easier to input data into AUTOCAD from scratch. . In theory it should be possible to recreate the library in the event of a fire in the document rooms but there could be difficulties in ensuring replacement documents are up to date.

Comments

All the site P&IDs are now reported to be updated and EPCL have started a process to redraw the P&IDs in AUTOCAD format. At the time of the survey, EPCL were investigating companies to undertake this process. Training EPCL now have a training department which coordinates training across all parts of the organization. In addition a number of trainees are trained as part of Nigerian government training programmes. Experience Most personnel currently working on site in a technical function are well experienced and there are no immediate training needs. The facilities appear to have been built to industry standards. Standards used appear to have been those of the licensor plus relevant industry standards such as ASME, TEMA, API codes etc. In some cases standards from the country of origin may have been substituted, for example DIN in Germany, BS for the UK.

Engineering Standards

Mixing of codes on pressure systems can lead to incompatibility. Whilst accepted industry standards appear to have been used at EPCL, there are some obvious differences between loss prevention philosophies between the different process units particularly with regard to fire fireproofing in the process facilities.

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Details
EPCL have developed technical agreements with the licensors of the major process units: Kellogg (olefins) Nova (polyethylene) Basell the successor to Technimont (polypropylene) IFP(now Axens) - the butane-1 plant EPCL have appointed SK Energy of Korea (who operate similar olefins plants) as technical advisors. In addition, EPCL have appointed Ingenero ( India) to provide real time monitoring and feedback of process operations Management of Change: Overview A management of change procedure has been developed by EPCL as part of the new safety manual and is being used in conjunction with the 144 changes that have been proposed since the takeover by EPCL.

Comments

A review of the procedure and some of the project files showed some weakness in the procedure: The safety implications of a change were generally made at an early stage in the specification of a change and may not adequately reflect the hazards which become apparent as the technical implications of the changes become clear. The requirements for a HAZOP are not clearly defined and could lead to an inconsistent approach. There is no requirement in the procedure to ensure that documentation is updated when the change is complete.

The procedure requires a Hazard and Operability (HAZOP) Study to be conducted in some circumstances. Hardware changes Process changes All physical changes to the site go through the MOC procedure. Process changes are covered in the MOC procedure. There is no requirement for a review of staffing levels or organizational changes. It is becoming increasingly common to review changes to staffing levels as part of the management of change procedures. This should identify situations where, for example, under reduced staffing levels a person might be required to be in 2 locations at the same time during start-up. It is prudent to repeat the HAZOP studies periodically and in some countries this is a legal requirement. As a pre-requisite an accurate set of P&IDs is required. An update of the studies would also be a useful training exercise for operators and might explain the basis of aspects of the design which appear strange, such as the action on air failure of the vent valve on the ethylene storage tank (see section 5.5.3)

Organizational changes

Hazard Analysis

HAZOP studies of all the units were performed at the design stage but have not been reviewed since. Whilst the more complex modifications undergo a HAZOP review, there has not been a comprehensive programme to re-HAZOP all the facilities.

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6.5. Inspection
Brief details of the inspection function are shown below.
Details
Organisation and Staffing Levels The inspection function now reports direct to the site management with the following staffing: Equipment: Radiography Radiographic work is contracted out but EPCL staff interpret the radiographic plates. It is common practice for radiographic activity to be performed by a third party company. EPCL staff are reported to check the radiographic plates produced by the third party inspectors. Probes for use at high temperature are available but EPCL consider them to have limited reliability at elevated temperatures and they are not generally used unless a problem is detected on operating equipment. This equipment has been purchased since CTts 2006 survey. Departmental manager Corrosion specialist 4 field inspectors

Comments

Ultrasonic

Panametrics ultrasonic thickness measurement equipment, A, B, C scan equipment with data capture facilities is available at the site.

Magnaflux Eddy current Dye penetrant Alloy Analyser

Magnaflux equipment is now available on site Contractors would be employed if eddy current inspection were necessary. Dye penetrant equipment is available. A Niton metals analyser has been purchased.

These are becoming increasingly popular by comparison with the better known Texas Nuclear Analysers because the radioactive source within the instrument has a longer half life requiring less frequent replacements. This detects defects in vessel and pipeline coatings. One use will be to detect the quality of painting systems under insulation to prevent Corrosion Under Insulation (CUI) This represents a high level of competence around the site and represents a significant improvement over the situation when NNPC managed the site

Other

A Holiday detector has been purchased.

Experience

The corrosion engineers will be graduate level appointments. The field inspectors will require a minimum of level 2 certification in 2 or more NDT subjects. Contractors are also used for work during TAMs and other busy periods

Documentation

Records previous to TAM1 are reported to be limited, often limited to situations where problems were anticipated. Record keeping is a mixture of hard copy and soft copies. The latter generally being scans of hard copy reports. Currently, there is limited trending of records but there are plans to instigate this in the future

These conflict with information previously supplied by EPCL (when part of NNPC) but are considered to be correct.

Pressure Vessels and Piping

Inspection philosophy is largely based on Indian practice, which generally requires an internal inspection every 2 years.

Future TAMs may take place at intervals of up to 4 years, which is longer than the 2 year figure understood to be required by Indian regulations. However a 4 yearly inspection interval is not out of line with practice in some areas and is a significant improvement on practice at the site in the past.

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Details
All statutory inspections required Nigerian Authorities are undertaken. by the

Comments

Pressure vessels are code stamped and there are no ASME VIII div 2 vessels on site. The site is currently investigating a Risk Based Approach to inspection but details have not yet been worked out. Whilst companies are increasingly moving to Risk Based Inspections (RBI), when Indorama originally took over the site, they did not consider that there was sufficient data available to implement RBI at the site. The fact that RBI is now being considered demonstrates the increased confidence that EPCL now have in the mechanical integrity of piping and pressure vessels by comparison with 3 years ago. The cold section of the olefin plant is considered as an area where corrosion is unlikely and has not so far been examined. Whist corrosion may be limited due to the operating conditions and the use of stainless steel, this is also the part of the plant which represents the greatest VCE hazard

A significant number of process vessels and tube bundles have been inspected during TAM1. Those considered less likely to suffer corrosion were inspected during TAM2.

Whilst there are a few vessels which have not been inspected since Indorama took over the site, all those considered most hazardous have been inspected and, generally, hydrostatically tested. These include: All vessels containing hydrogen, and All vessel with liquefied gas inventories A programme of inspection of areas where insulation is damaged is underway. This will identify areas where under insulation corrosion could exist and allow remedial action to be undertaken before the problem becomes serious.

Corrosion Under Insulation (CUI) work is progressing with priority being given to piping sections subject to thermal cycling. Spheres 7 of the 12 spheres at the site have now been internally inspected. In addition Magnetic Particle Inspection (MPI) has been conducted on the sphere legs. Each sphere inspection costs approx. Naira 2.5 million. Once each sphere has had an initial inspection a re-inspection is planned at 5 to 10 year interval in line with API 576. One of the spheres converted to VC5 use was hydrotested during the conversion work. Tanks Pressure Relief Valves Wall thickness measurements of tanks have been undertaken. All pressure relief valves at the site are now reported to have been inspected since Indorama took over the site. The bulk of these was done during TAM1 with the balance at TAM2. Valves that have been tested are colour coded before being reinstalled on the plant. . There have been cases where the sphere integrity has been adequate but corrosion of sphere legs has occurred, resulting in collapse of the sphere. Inspection of the legs is therefore prudent.

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Details
Pressure tests are conducted on a test bench with nitrogen used for pressures up to 140 bar and water used above that pressure.

Comments
Whilst the use of water for high pressure testing is understandable, it is desirable to use the correct medium for testing (water for valves on liquid duties and nitrogen for valves on vapour duties). Use of the wrong fluid could result in incorrect calibration

A hot set pressure correction is applied where necessary. Hoses There is currently no comprehensive programme for inspection of hoses. When inspections are required, they are requested by the unit where the hoses are located.

It is common practice to pressure test hoses and check for electrical integrity every 6 months. There are now more hoses at the site than at the time of the previous survey. These include hoses associated with the new propylene rich feedstock import. As plant managers main focus is likely to be on production rather than inspection activities, it would be prudent for coordination of hose inspection to be transferred to the inspection group.

Cranes Positive Materials Identification

All cranes slings, etc. are inspected by a third party inspection body. All piping materials, welding rods, etc. supplied to the site are subject to third party inspection. A Niton alloy analyser is available at the site but is only used on a random basis. However, there was 100% checking for materials involved in the VC5 project.

Crane inspection is a statutory requirement in Nigeria.

This procedure may have the potential to allow rogue sections of material to enter the site. Whilst it offers a reasonable level of protection, it would be preferable to test and colour code each individual alloy component entering the site .

EPCL also intend to perform some random checks on alloy material installed on the plant. Alloy materials entering the site are reported to be colour coded before entering the stores. Welders Welding is performed by a mixture of in house and contract welders. Generally welders are required to produce test pieces on site but previously issued certificates are accepted if they are less than 6 months old. Cathodic protection is installed on the NGL feed line from AGIP feed. Soil conditions on the propylene line from the Port Harcourt refinery do not require cathodic protection, except in one small section where a sacrificial anode is installed. EPCL are planning to install corrosion coupons in critical areas for future monitoring. Specific Problem Areas As would be expected in a process unit which had operated for 10 years without major overhaul, there have been some significant problems: Many heat exchanger tube bundles had either blocked or are leaking. Repairs or replacements have now been made Corrosion has occurred on a number of vessels. In some cases this appeared to have been severe. However, EPCL have

This differs slightly from common practice which generally requires the completion of test pieces from all welders who have not previously worked at the site on a regular basis. The line to the refinery is understood to be the property of EPCL, whilst the NGL feed line is the property of AGIP.

Corrosion Protection

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Details
determined that in all cases, the reduced wall thickness still allows safe operation and there has been no requirement for welding repairs on any of the vessels. Plans are in hand for the replacement of some vessels. Many furnace and boiler tubes have become defective and have been replaced. As stated above, checks are underway to check the extent, if any, of under corrosion insulation

Comments

6.6. Safety, Health and Environment


Brief details of the safety function are shown below.
Details
Organisation and Staffing Levels The safety function reports to the site manager. The department is headed by the site Head of HSE, with the following groups reporting to him. The safety department is split into 3 subgroups as shown below: . Environment (2 personnel). Safety Engineering (5 personnel, plus 1 vacancy) Occupational Health (15 personnel) This will include a safety representative on each shift team. Whilst the reporting route is to the safety department, there have been conflicts of interests in other locations. This has resulted in the shift safety officer sometimes being more concerned with production activities than safety.

Comments
This will allow a clear reporting route, with no conflicts of interest.

Training

Fire (see section 6.7). Once site operations are fully established, it might be appropriate to arrange a short period in the HSE function for young engineers as part of their career progression.

The site will generally be recruiting experienced personnel with little requirement for immediate training. The Head of HSE has extensive experience of process operations and process safety. All personnel at the site have a diploma in safety.

Experience

Performance/Accident Reporting

An accident reporting system, based on the previous NNPC system is in place. This included near miss reporting. The accident reporting, investigation system consists of a First Information Report followed by investigation to give a Fact and Analysis Report. Statistics for fires are shown below:

Only 1 or 2 near misses are reported each month, suggesting a degree of under reporting. EPCL are trying to encourage reporting by the provision of rewards to staff who make reports.

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Details
Employee Involvement Since taking over the site EPCL have worked energetically at the site and there is now collective consensus that safety is a line management responsibility with the safety function acting largely as an auditor and advisor. A new draft safety manual has been produced. There is an interlocking series of 4 safety committees, the most senior being the APEX committee, which is chaired by the EPCL chairman and involves the heads of departments. There are also individual plant committees and a contractors committee. There is a safety ambassador for each area.

Comments
This is in line with modern safety philosophy.

The ambassadors are Nigerian nationals, which should avoid the appearance of ex-pat personnel arriving on site and preaching.

All new recruits are provided with induction training by EPCL staff. The safety manual contains a procedure for Job Safety Analysis (JSA). This develops an analysis for the safe performance of many routine activities. This differs from the way that JSA is used at many locations where a JSA is undertaken prior to the issue of a permit to work. Whilst many activities will be routine, it helps to

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Details

Comments
identify usual situations with higher hazard. For example maintenance next to a new construction area or other maintenance activity where there could be interaction. It is not clear if this procedure has been fully implemented and if not it should be as a matter of priority. Some activities associated with start-up which were unnecessarily hazardous: The use of temporary flexible hoses and drums with screwed fittings and unions for transfer of liquefied gases. Fabrication work (including hot work) close to the cracking furnace area. This work could have been performed outside the plant boundary where there would be less chance of leaks.

Housekeeping

Housekeeping standard.

was

generally

to

good As part of the permit to work procedure, it would be prudent to ensure that all flanges, (including those on utility systems), plugs and bolts in electrical junction boxes are in place before permits are signed back. No evidence of smoking in unauthorized areas was noted during the site visit, indicating a good level of discipline. A number of infringements were noted. Whilst there is disagreement over the spark potential of a mobile phone, it would be prudent to enforce the existing rule. This not only removes a, possible, source of ignition but also avoids a situation where the safety rules start to lose their clarity and are more likely to be disobeyed. These provide potential, but unlikely, ignition sources in the event of a gas escape. Since the survey, fittings in vulnerable areas have been identified and replaced. Other defective fittings will be replaced in the near future.

There were relatively few missing blinds and plugs in the process areas. However a number of electrical panels had missing bolts.

Control of Ignition Sources

Smoking is only permitted in authorised areas throughout the site. Mobile phones are reported to be banned in the site but allowable in the control rooms (away from the DCS systems).

A number of electrical fittings were noted with bolts missing in the sphere area and many of the light fittings were damaged in the NGL sphere area.

All vehicles entering the process areas have flame arresters fitted. Hot work appeared to be adequately controlled.

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Electrical Junction Box Note missing bolts

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Details
Safety Auditing Internal safety audits take place twice per year. These use prepared checklists with reporting and follow up of any defects identified. Contractors have safety briefings when they first arrive on site. Some contractors have safety training before arriving on site. There is also a safety committee dedicated to contractor issues.

Comments

Contractors

6.7. Emergency Response


. Brief details are given below:
Details
Organisation and Staffing Levels The site fire team will consist of: A fire chief 5 shift fire leaders 6 fire fighters per shift

Comments
As in other areas recruitment is not complete and NNPC secondees are currently being used to cover the positions where permanent employees have not been appointed.

An organization chart is shown below:

Experience

All the fire fighters will have professional fire training, including fire fighting training prior to joining EPCL. The site has a fire training ground with facilities for both pool fire and jet fire training. Fire fighter competence is likely to erode without live firefighting experience and it would be desirable to resume regular training on both pool and jet fires as soon as possible to rebuild experience levels.

Training

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Details
The fire training ground is due to be relocated as a consequence of the changes in the site layout required by the decision to provide living accommodation within the EPCL boundary for ex-pat staff. Employee Involvement Mutual Aid An auxiliary fire team composed of security and maintenance personnel has been established. A mutual aid scheme is being developed involving: Emergency Planning Shell Petroleum. Agip. Mobil. Total/ELF Nigeria Ports Authority (NPA) Port Harcourt Refinery. River State Fire Authority municipal fire brigade). (the local

Comments

The inclusion of fire teams from other hydrocarbon facilities will ensure that many of the mutual aid personnel will be experienced in the specific dangers associated with hydrocarbon fires.

The level of equipment availability at Port Harcourt may be limited Local authority firefighters frequently have a limited understanding of oil industry fires Points noted in the previous CTt survey are understood to understand been incorporated in the lasted version of the emergency plan.

An emergency plan has been developed outlining roles and responsibilities have been defined and deputies nominated.

Emergency coordination centres have been established in the Plant shift Superintendents office and the fire station. These are reported to be fully equipped. So far no emergency pre plans have been prepared.

Well developed pre plans can assist in the early stages of emergency planning by providing firefighters with the basic information required to mount a fire attack quickly.

Emergency Drills and Simulations

Emergency simulations take place on an annual basis. The 2008 simulation was in the polypropylene plant and the 2009 one is planned for the tank farm.

6.8. Security
Since CTts 2006 survey, a kidnap event took place affecting a number of EPCLs ex-pat staff and family members. Security threats are seen as criminal rather than political. Since then there have been significant and ongoing increases in security. Brief details of the security function are given below.
Details
Organisation and Staffing Levels EPCL have a small security department, totalling 23, reporting to the site administration manager. They are supported be a much larger number of external security personnel, totalling approx 300, including police and army contingents based at the site:

Comments

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Details
Approx 160 of the personnel are unarmed and provide basic security at locations such as control of entry to buildings, etc. They are employed by two local security contractors: Pentagon Security - provide security in the outer perimeter and up to the inner fence to the process, utility and offsites. Bulwark - provide security within the inner fence containing the process, utility and offsites.

Comments

There are also a number of Nigerian state authorities involved in security at EPCL: Nigerian army Mobile police Regular police 2 State security intelligence officers.

Some of the security personnel operated within the site in plain clothes.

The army and mobile police, both armed have bases inside the site parameter. There are also 2 Israeli security specialists on site. In addition EPCL have undertaken a number of actions to limit tension between the company and the surrounding community, including the provision of training programmes and the use of local people, where possible, for unskilled work. Other miscellaneous activities include the running of security consciousness classes . Post Orders All the EPCL security personnel and external agencies have defined roles through a chain of command. Post orders define the requirements of the security section. These should include the chain of command, required duties, normal operating duties, and emergency responses to security incidents. This philosophy has proved successful as local people were instrumental in resolving the kidnap of EPCL employees and their families.

There are three levels of patrolling: Security Patrols Dematching/Search Policies Drug/Alcohol Abuse External to the site Within the site boundary By plain cloths personnel at the site the These are concerned with theft as much as security threats. There are reported to be no drug or alcohol problems at the site. However the situation with regard to alcohol might change once all EPCL personnel are located within the EPCL boundary. If alcohol is allowed in residential areas, care will be necessary to ensure there is no pilferage which might get into the hands of operators or others.

Security patrols take place involving contractors and the external agencies.

There is no dematching policy but random searches of vehicles entering and leaving the site take place. There are currently no drug or alcohol testing programmes

Employee Background Checks

Checks take place on new recruits and long term contractors

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Details
Weapons Experience and Training The soldiers and mobile police are armed. Many of the contract security personal are exmilitary or ex-police. Some training has been provided by security specialists from Israel. Control of access to the Site Since the kidnapping incident security precautions have been significantly increased. There is only one point of access to the site, through a well guarded gate An access control system featuring swipe cards in being installed There is an inner gate into the process area. Vehicles into this inner area are checked to ensure that flame arrestors are fitted. Physical Precautions The original wire fences topped with barbed wire have now been replaced by a 3m concrete wall topped with an electrified fence. A multi camera CCTV monitoring system is being installed In addition, All Ex-pat personnel and their families will soon be located from external accommodation to housing with the EPCL production site.

Comments

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7. Fire Protection
7.1. Fire and Gas Detection
In addition to the detection systems listed below, there are Manual Call Points (MCPs) throughout the site.
Details
Buildings Smoke detection is installed in buildings, including underfloor areas in control rooms. Detectors are also installed on the air inlets for air conditioning systems. Process Areas Gas detectors are installed through the process areas. Heat detection systems are installed in some process areas to activate water sprays. The level of detectors varies within the process facilities reflecting different design philosophies. Numbers of detectors are: Olefins 36.. Polypropylene 45. Butene 1 - 18

Comments
The smoke detection system in the main office building has not yet been renovated but the plant based systems are understood to be operational or under repair. See below. Set points for alarm and actuation also differ between the polypropylene plant and the other locations. A renovation project for the detection systems in the plant is well advanced. Details are given below. Gas detectors alarm at 25% and 50% of LEL but do not initiate any shutdown action.

A replacement fire alarm panel has been installed in the Polyethylene plant. Some equipment is obsolete and replacement is taking place. For example, the fire detection system in the polypropylene plant has been replaced and new system for the polyethylene plant is on order. Storage Areas Within the LPG and refrigerated storage areas gas detectors are installed. Smoke detectors are installed in the polyethylene and polypropylene storage facilities. Fusible plugs, activating sprinkler systems are also installed. Utilities The gas turbines are fitted with heat and flame detection systems. These activate carbon dioxide extinguishing systems. There are local fire panels around the site with a repeater at the fire station. Regular testing of the fire and gas system is undertaken by a specialist subcontractor. Gas detectors are reported to be tested by aerosol spray. The gas detectors are pelletizer type detectors which are relatively old technology. More modern designs, with increased reliability feature infra-red technology These systems are reported to be operational and set to trigger the associated carbon dioxide system. Defective alarm loops were noted in most of the alarm panels. Gas detectors alarm at 25% and 50% of LEL but do not initiate any shutdown action.

Signalling Testing

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7.2. Fire Water System


Brief details of the fire water system are given below.
Details
Design Basis Design fire water requirements for the site are given below: Olefins - 1,550 m /hour. Polypropylene - 1,470 m /hour. Polyethylene/Butene-1 - 1,350 m /hour. NGL storage - 1,717 m /hour (based on a fire affecting one sphere and cooling of others. Fire Pumps There are 4 main fire water pumps (2 diesel and 2 3 electric) each with a capacity of 900 m /hour. A further diesel driven support pump exists. Pressure in the fire main is designed to be maintained at 10.5 bar g by 2 jockey pumps (1 diesel and 1 electric) with a capacity of 105 3 m /hour. One of the main fire pumps is currently in continuous operation as the demand for fire water for duties such as flushing and wash down exceeds the capacity of the jockey pump. The diesel fuel tanks, which were largely full, are located close to the diesel pumps and could affect them if the contents spilled and ignited. Whilst there is diking around the tank, which would contain spillages, high thermal radiation levels could damage the fire pumps. In similar locations, it is common practice to install a firewall between the tanks and the pumps. The use of fire water for process cooling has diminished but 3 coolers are still using fire water to assist cooling. Whilst these are understood to be utility rather than hydrocarbon coolers, the use of fire water for this purpose is undesirable. There appears to be poor control over the use of fire water for purposes such as cooling or wash down and a stringently applied impairment system would be useful.
3 3 3 3

Comments

One of the electrically driven pumps is in continuous use to pressurize the fire main.

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Details

Comments

Fire Pumps

Fire Water Supply

Fire water supply is taken from the two 55,000 m 3 raw water tanks. With a minimum of 65,000 m reserved for fire water.

This supply would last for over 24 hours well in excess of normal fire water capacity.

The tanks are replenished from the boreholes described in section 5.6.1. Fire Main The fire water ring main is buried and consists of a looped grid. The main loop is 24 inches in diameter, with laterals and branches ranging between 18 inch and 8 inch. The fire main is externally coated for corrosion protection. There are approximately 280 twin connection hydrants and at 90 m or, in congested plant areas, 50 m. In addition, there are 51 monitors around the site. Fire hose cabinets and fire reels are installed around the site. Several cases were noticed where fire water hoses were being used for wash down of flushing. This is considered undesirable. Operations personnel generally do not replace fire fighting equipment after use. This can result in equipment being damaged or unavailable when required for firefighting. If firefighting equipment is required for other purposes, it should be under some form of impairment procedure. Many monitors are located within posts to prevent impact damage. The fire water lines are reported to have been flow tested and found to be in good condition with no serious corrosion.

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Details
In the Polyethylene plant the fire water system has been tied in to provide emergency cooling water for the process. Testing The diesel fire pumps were reported to be started for 30 - 40 minutes every 2 weeks. Head curves were reported to have been checked during TAM1 but appear not to have been checked since.

Comments
This should ensure a supply of cooling water in the event of a power cut, the temptation to use fire water for routine cooling must be resisted. The NFPA guidelines recommend 30 minute testing on a weekly basis and this period should be used in the future. It would also prudent to perform pump head curve tests on an annual basis as required by NFPA in the future.

7.3. Active Systems


Brief details of the active systems are given in the table below. Many of the systems were in poor condition when the plant was operated by NNPC but considerable renovation work has taken place since Indorama took over the site.
Details
Buildings A number of fixed systems are installed in various buildings: Laboratory sprinkler system with a 7.74 2 l/min/m density. Control and rack rooms (including underfloor areas) halon or carbon dioxide systems. The halon systems are reported to be interlocked with air conditioning equipment. Some of the underfloor systems in control rooms use carbon dioxide which is an asphyxiant. These are set for manual operation to allow personnel to evacuate the room before the system is triggered. Halon is now banned under the Montreal Protocol but some developing countries have a waiver for continuing use for a period. At some point the halon systems will need to be dismantled and EPCL propose to replace it with FM 200 or aragonite. In some locations, such as the instrument rack room in the olefins room, the doors are open and portable fans installed due to defects in the air conditioning system and this will prevent the extinguishing system working effectively. Whilst there will be considerable movement into and out of the rack rooms during start-up the normal practice should be to keep the doors shut. Process Areas In addition to hydrants, monitors and extinguishers, a number of systems are installed in the process areas: Fired heaters have manually operated steam snuffing systems. Actuation valves are located at a safe distance. A number of hand held steam lances are available. Automatically actuated foam/water deluge systems are installed on vessels and pump seals in the polyethylene plant, 16 in total Automatically actuated water deluge systems in the polypropylene plant, 4 in total. There is a significant variation in the level of protection between the olefin and polyethylene plants. During this survey, the polypropylene plant was not visited and the level of detection was not determined.

Comments

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Details
A manually operated deluge system is installed around the refrigeration compressors in the olefin plant.
2

Comments
A similar system may be installed around the cracked gas compressor but this was not visited during the survey.

Deluge rates are 10.2/l/min/m for most duties and 2 20.4 l/min/m for pumps Dry powder system is installed to protect the TEAL handling systems in the polypropylene plant. Discharge rates appear to be in line with API standards.

Storage Areas

All the major liquid storage facilities have fixed fire protection: Main atmospheric storage tanks water 2 deluge (varying from 6.5/l/min/m to 12.2 2 /l/min/m ) fixed foam systems. Spheres have water deluge rings covering the entire surface. The refrigerated ethylene tank has a water deluge system with a density of 10.2 2 1/min/m . In addition there is an impounding basin for containment of ethylene spillages which is equipped with water deluge and fixed foam systems.

The bladder tanks for the foam systems are reported to have been recently tested and found to be in good condition. The polypropylene and polyethylene warehouses have water deluge systems with water densities 2 2 varying between 7.8 1/min/m and 18.3 1/min/m depending on the area being protected. The catalyst storage facility has a deluge system 2 with a water density of 15.11/min/m . Utilities A number of fixed systems are installed in the utility areas: Motor Control Centres (MCCs) and switchrooms have fixed carbon dioxide extinguishing systems The provision of fixed systems again suggests a difference in design philosophies between the different plants. There are no fixed systems within the olefin unit, whilst MCCs and switchrooms in both the polypropylene and polyethylene plants have protection. Deluge isolation valves on the polyethylene warehouse were examined during the survey and found to be partially or fully open. It would be prudent to car seal these valves in the open position to prevent accidental isolation of the sprinkler systems.

Testing

Fixed carbon dioxide systems are installed in the 4 gas turbine cubicles.

Semi annual checking and maintenance of the systems takes place. In addition, there is quarterly visual checking of the foam systems on the storage tanks.

7.4. Passive Systems


Brief details of passive fire protection are given below

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Details
Buildings Control rooms for the process units are blast resistant without windows. However in all the process control rooms visited, the main doors were open.

Comments
The level of blast resistance was not determined. Despite the blast resistant design, the integrity of the control rooms is reduced if doors are left open. Again this suggests different fire protection philosophies between the different licensors and contractors. The requirement for fireproofing will be lower in plants handling hydrocarbons which will be in the gas phase after release rather than the liquid phase where pool fires might result.

Process Areas

The level of passive fire protection varies considerably with only limited protection in the olefins plant but a considerably higher level of protection in the polyethylene plant.

Vessel skirts are fire proofed. The level of fire proofing on piperacks is variable with some racks carrying predominantly hydrocarbon gases being fire proofed in the polyethylene plant. In other locations piping with liquid inventories is in un-fireproofed racks. Fin fan cooler are partially fireproofed but not to the full load bearing height.

Fire proofing has been applied to a number of vessels where it was previously missing. There is generally little value in fireproofing piperacks containing gases. Fireproofing is designed basically as protection from liquid pool fires. The air flow from the fin fans will exacerbate flames from a pool fire. The provision of fireproofing almost to the top of the fin fan cooler will minimise the extent of damage caused by a pool fire under the fin fan.

The TEAL (catalyst) storage areas in the polypropylene and polyethylene plants are constructed of concrete with dividing walls between the TEAL containers. Storage Areas Sphere legs are fireproofed. 2 hour rated fire walls are installed in some warehouses. Utilities Fire walls are installed between transformers with stone covered drainage at the base. In some cases, the height of the fire wall might not be sufficient to prevent a degree of thermal radiation exposure by the adjacent transformer.

2 hour rated fire doors are installed at all substations.

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Transformer Passive Protection

7.5. Mobile Equipment


7.5.1. Fire Trucks Brief details of the fire trucks are given in the table below.
No. of Trucks
Combination Truck 3

Details
3,0001/min water pump at 100m head. 4,000 l foam, 8,000 l water and 1,000kg dry chemical.

Comments
One of these is a new Tata fire truck purchased since Indorama purchased the EPCL.

Bronto Skylift

foam/water pump 3,000 capacity at 100 m head. 4,000 l foam.

1/min

Rescue Truck Water Tender Foam Trailer Dry Chemical Powder

1 1 1 1

250 Kg of dry powder with a discharge rate of 2.3 kg/sec. 7,000 l water 4,000 l foam. 4,000 l water

There are approximately 1,500 portable fire extinguishers throughout the site. These are dry powder, carbon dioxide, pressurised water and halon types. At some point the halon extinguishers will need to be replaced to comply with the Montreal Protocol.

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The fire station and fire-water pumps are remote from the process area. 7.5.2. Foam and Dry Powder Stocks Minimum foam stocks are: AFFF 6,000 litres AFFF (ATC) 5,000 litres FFFP 10,000 litres Dry chemical powder 4,000 litres

Care should be taken in the use of foam as mixing different foam types may reduce efficiency. Some foam is available in fire trucks and a 3,800 l overhead tank (see below) has been installed to provide rapid refilling of fire trucks, together with a limited stock in drums.

Bulk Foam Tank

All foam is reported to be new purchased from 3M.

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8. Recommendations for Risk Improvement


8.1. New Recommendations
At the conclusion of the survey a meeting was held with the site management and a number of recommendations made, these are given below. CTt prioritise recommendations with the following classification: 1. Priority: Major risk deficiency that requires prompt action. It is advised that capital expenditure be allocated to these recommendations in preference to other recommendations listed here. CAPEX: Recommendations requiring capital investment. Human Element: Recommendations requiring little capital investment. These recommendations require effort and commitment by staff and can make an important contribution to risk improvement. They should not be regarded as trivial items, and should be implemented within a reasonable timeframe.

2. 3.

Since the survey, EPCL have responded to all the recommendations made and their response is included below. After such a short period, it would be unrealistic to expect recommendations to be completed.

09-01

Sampling Procedures

Category
Recommendation

1
Review the current sampling procedures (and their operation in practice) for liquefied gases and, if possible, revise the procedure to avoid the release of process fluids during the sampling procedure. If not yet completed, a Job Safety Analysis (JSA) should be undertaken for sampling activities.

Reason

The current sampling procedures involve the release of process materials to atmosphere. If incorrectly operated, valves can freeze leading to an uncontrolled release of hydrocarbons. If ignited, a serious fire or explosion could occur. An example of this occurred at Feyzin in France in the 1960s (http://shippai.jst.go.jp/en/Detail?fn=2&id=CC1300001). Where necessary, provide appropriate training.

Examples EPCL Post Survey Comment

Liquefied gas sampling procedures in the olefins plant. We will review current procedure and ensure proper implementation to avoid release of hydrocarbon mixtures during sampling

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09-02

Fire and Gas Alarm Systems

Category
Recommendation Reason Examples

1
Review the adequacy of the existing fire and gas panels and make appropriate repairs and upgrades as necessary. Whilst considerable work has been done to repair and upgrade the fire and gas system, the system still appears to have a number of defects and its overall integrity may be low. Fault alarms were active on most of the fire alarm panels inspected in buildings and process areas Some of the equipment at the site may be obsolete, for example the site uses catalytic pelletizer type flammable gas detectors whilst newer, more reliable, infrared detectors are available.

EPCL Post Survey Comment

Last year, we changed the Fire & gas alarm system of PE plant. This year, we would do similar job in PP plant. For other plants, depending on requirement we may change phase wise. This would increase overall reliability.

09-03

Control Room Doors

Category
Recommendation Reason

2
Install automatic door closers on the external doors in the control room building. Large heavy doors, such as those on the control room, can be cumbersome to open and close manually and there is a temptation to leave them open, particularly in a warm climate. However the integrity of the control room is compromised when the doors are left open. In the, unlikely, event of a major explosion there would be casualties within the control room and damage to control equipment. All process control rooms Matching with the integrity of blast proof arrangement of control room, the main doors are made quite robust & heavy. Providing door closure may cause inconvenient. Anyway, we would review it.

Examples EPCL Post Survey Comment

09-04

Urea Formaldehyde Foam (Cold Insulation)

Category
Recommendation Reason Examples EPCL Post Survey Comment

2
Review the specification of cold insulation and, if necessary, modify the existing specification. The current insulation for use in cold applications appears to be Urea Formaldehyde foam which may char if exposed to heat. Insulation on cold liquefied gas lines in the offsite area. For the project of conversion of PRF spheres to NGL we used PUF (Polyurethane Foam) only in pipes. Sphere insulation was using cellular glass. The normal practice is to use cellular glass as cold insulation. We would follow same practice for new installation and for major revamping

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09-05

Document Control

Category
Recommendation

3
Develop a document control procedure to ensure that: Key documents are controlled with the latest versions being accessible to registered users and older versions destroyed. Uncontrolled copies can be clearly identified Documents are written in an approved style with information such as date, revision number, etc. clearly displayed.

Reason

Currently EPCL are largely working with documents inherited when the site was under NNPC operation. Some key documents, such as Process and Instrumentation Drawings (P&IDs) have been updated and, it is understood that many other documents are likely to be developed or revised now that the more urgent work of improving the plants mechanical integrity is completed. Unless well developed systems for the control of documents are developed, there is a danger of different versions of the same document being used by different people.

Examples

Currently the site P&IDs have been updated but the original as built drawings are the ones available for reference in the plant control rooms. It is intended that many of the drawings, procedures, etc. will be available on the company Intranet. Unless, appropriate checks are built into the system, it will be difficult to control downloading, printing and storage of uncontrolled documents.

EPCL Post Survey Comment

EPCL will work to develop a document control system where copies are controlled. Conversion of hard copies of P&IDs to CAD format and field verification is to start soon. These documents shall be also part of the controlled documents.

09-06

Operator Emergency Training

Category
Recommendation 1. 2.

3
Review the existing emergency shutdown procedures and revise/update where necessary. Instructions should be written in a simple, easy to read, format. short form emergency instructions should be prepared as a standalone document. These could be in the form of checklists so that operators can confirm that they have completed all the emergency actions required. Institute an emergency simulation program for process operators so that they are familiar with required actions in the event of a process upset. The following points are offered for consideration: Process upset conditions should be considered in turn (e.g. loss power, loss cooling water, etc.) Simulation training should be at the same time each week so that each shift has the opportunity to practice each specific scenario Field operators should place tags on the valves they would operate to ensure they know the correct location of the equipment Panel operators should list the actions they would take Field and panel operators actions can be checked and refresher training provide if necessary

3.

Reason

1. 2.

Whilst the operating instructions reviewed did contain emergency shutdown procedures, there were sometimes vague and in a difficult to follow format. Simple one page, step by step, instructions are easier for operators to understand than complex manuals.

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09-06
3.

Operator Emergency Training


In emergency situations, operators and supervisors are under increased stress and the potential for mistakes increases. Training will reduce the potential for error.

Examples EPCL Post Survey Comment

Current Emergency procedures examined are based on the original contractors operating instructions which are, in some cases, limited or out of date. This will be reviewed in plant level.

09-07

Permit to Work (PTW) System

Category
Recommendation

3
Review the design of the Permit to Work system to cover the following areas: 1. Revise the design of the permit form so that the authorizing signatures (required before work starts) and the hand back signatures (required on the completion of work) or on the same side of the permit form. 2. Keep a copy of the permit to work at the jobsite (usually encased in a plastic envelop to avoid damage) 3. Keep files for incomplete work separate from those for completed work. 4. Introduce a JSA (Job Safety Analysis) system for none routine work 5. Ensure that site visits take place to ensure that the site is left in a safe condition on the completion of maintenance work.

Reason

1. The current design of the form is unusual in having the authorizing signatures (required before work starts) and the hand back signatures (required on the completion of work) on opposite sides of the permit form. This could lead to confusion when filling in the form and makes auditing of the forms more difficult 2. Provision of a copy of the permit at the job site assists monitoring of the work by operations and safety personnel 3. It is common for maintenance activities to be incomplete when the PTW expires and is signed off. To avoid confusion over the status of maintenance activities, it is common practice, to separate PTWs for completed tasks from those for ongoing maintenance activities. Confusion over the status of maintenance work was a key factor in the Piper Alpha disaster in the UK North Sea in 1987. 4. EPCL currently have a JSA programme covering frequently performed activities, this should be expanded to cover non routine work, which may introduce unexpected hazards. 5. If hand backs take place in the control room, there is a danger that the site is left in an unsafe condition

Examples

1. The current work permit form has signatures on both sides of the form. 2. Currently PTWs are not available at the job site 3. there is only a single file of PTWs at each control room with no differentiation between completed and ongoing activities 4. There is currently no JSA required as part of the permit procedure 5. Explosion proof electrical junction boxes in several plants, particularly the olefins unit, had very few bolts on the covers

EPCL Post Survey Comment

Suggestion is good. We are reviewing it. Except one or two, most of the recommendation will be implemented.

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09-08

Isolation for Maintenance

Category
Recommendation

3
Review the existing Isolation standards for maintenance isolation as follows: Apply padlocks and tags to isolations on hazardous piping systems. Note that many companies have developed isolation procedures defining isolation requirements based on: fluid properties, flammability, toxicity, pressure and temperature. These are sometimes in the form of a Risk Matrix. Apply padlocks and tags to electrical isolations

Reason Examples EPCL Post Survey Comment

The existing practice requires only blinds on pipework and padlocks do not always appear to be fitted for electrical isolations. Various locations around the site. The existing practice is well established but we would review the merit of the recommendation.

09-09

Electrical Integrity

Category
Recommendation

3
Review Electrical integrity around the site and ensure that electrical work is completed to an acceptable standard. Where additional cabling is being installed on existing junction boxes, checks should be made to ensure that the capacity of the junction boxes is not being exceeded.

Reason Examples

Poorly installed or maintained electrical equipment is an ignition source. Many of the explosion proof junction boxes in the olefin plant have almost all of the bolts missing from the flanges. The same thing, to a lesser extent, is true in other plants. In many buildings the covers on low voltage junction boxes were open There are numerous examples where new low voltage cabling has been run from existing junction boxes without using existing cable trays.

EPCL Post Survey Comment

Completion of electrical job with full tightening of all bolts will be ensured. Work permit should not be closed until junction boxes are properly boxed up.

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09-10

Trip By-Pass Procedure

Category
Recommendation

3
Develop a trip bypass procedure covering the following: The level of authorization and checks required before isolation can take place The duration of the isolation Where isolations are likely to be for an extended period (more than a day or two whilst repairs are made). Some form of safety review should be undertaken to determine if additional, alternative, safety methods need to be undertaken.

Reason

The current system consists of a trip bypass register maintained in each of the plant control rooms. These are not always clearly filled in and, in some cases, it was difficult to determine if the dates on which bypasses had been established and when they were restored. Trip bypass register in the olefins control room. Procedures being revisited to include check list on completion and implementation of change. Check list shall ensure that changes are reflected in the related documents. Document control system will then ensure updating of all controlled copies.

Examples EPCL Post Survey Comment

8.2. Previous Recommendations


There have been numerous recommendations from a number of surveys dating back to 1996. At the time of the 2009 survey, there were a total of 58 outstanding recommendations. Of that total: 17 are complete 7 have no change 23 are in progress 6 are withdrawn 5 have an unknown status

Recommendations Prior to 2005


No.
96.03

Title
Control Building Pressurisation

Summary
Repair hinges on Polypropylene and polyethylene control room doors Improve fireproofing in the olefins plant

Status in 2006
Previously COMPLETE reported

Current Status (from EPCL)


-

96.05

Fireproofing

NO CHANGE

Pool fire prompt areas in Olefins were identified and fireproof was provided e I Skirt of de-ethanizer and depropanizer Columns. CHECK WORDING -

96.07

Fire Water Pumps

WITHDRAWN

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No.
96.08 96.10 96.12

Title
Fire Protection Control Valve Security Palette Storage Warehouse Practices

Summary

Status in 2006
Previously COMPLETE reported

Current Status (from EPCL)


-

Pallets in polymer warehouses. Wooden pallets stored close to TEAL containers. Replace halon with FM 200

UNKNOWN UNKNOWN

96.13

Halon System Status

NO CHANGE

Preliminary work and technical discussion is in progress. Would be implemented in phased manner from 2010. Out of 4 additional ROVs identified for installation 2 are already installed and 2 are procured waiting shutdown for installation

98.01

Remote Operated Isolation Valves

Install Remotely Operated valves for process isolation in emergency situations Stop unauthorized use of fire water. Update P&IDs to reflect current status of plant. Storage of wooden pallets in polymer warehouses. Various improvements to the Permit-to-work System.

IN PROGRESS

98.03 98.04

Fire-water Pumps Updating of Piping & Instrumentation Diagrams Wooden Pallets

NO CHANGE WITHDRAWN This is repeated in a later recommendation UNKNOWN -

98.06

99.01

Permit-to-Work System

IN PROGRESS A revised permit system has recently been introduced but further improvements are possible.

COMPLETE and being practiced. SOP is available on the intranet. Note that some issues were identified during the course of the current survey and a new recommendation relating to Permit-to-Work has been developed. -

99.02 00.01

Fire Pumps: Housekeeping Control of Valves on Fire-fighting Duty

Vegetation in the fire pump area Position of fire water valves

COMPLETE Reported COMPLETE

00.02

Status: Check-lists for Fire-fighting Pumps Repair of Diesel Fire Pumps

Produce daily inspection reports of the fire water pumps Repair of fire pump 42-P-D1

Reported COMPLETE

02.01

IN PROGRESS One diesel fire pump is still out of operation due to a faulty charger.

COMPLETE satisfactory.

and

running

02.02

Replace Missing PFEs/Hose Reels

Missing extinguishers fire hoses

fire and

IN PROGRESS Some extinguishers were still noted to be missing NO CHANGE In dialog with process licensor and waiting details from them.

02.03

Steam Curtain for Pyrolysis Furnaces

Install a steam curtain around the cracking furnaces.

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No.
02.04

Title
Gas Detection System

Summary
Repairs to the fire and gas detection system

Status in 2006
IN PROGRESS Repairs to systems within the process, utility ands storage areas are nearing completion. WITHDRAWN This recommendation repeated below. is

Current Status (from EPCL)


Fire and gas detection systems were working satisfactorily in all plants but PE. PE system was totally revamped and working fine. -

02.05

TAM Schedule

Undertake Turn Around Maintenance of the site

A TAM to complete urgent repairs has been completed with a further TAM in the first quarter of 2007 02.06 Extensions of PTW Limit valid of a work permit to one day. IN PROGRESS A revised permit system has recently been introduced but further improvements are possible. COMPLETE and being practiced. SOP is available on the intranet. Note that some issues were identified during the course of the current survey and a new recommendation relating to Permit-to-Work has been developed. -

02.07 02.08

Bolting l-K-3 (Ethylene Compressor) Oil Pan l-K-2 (Propylene Compressor) Static Bonding on Pneumatic Conveyor

Bolting on discharge flange Oil pan full of leaking oil under compressor Check continuity of earthling on Polypropylene plant pneumatic conveyor. Check fire breaks in cable routes.

Reported COMPLETE Reported COMPLETE

02.09

Reported COMPLETE

02.0

Power Plant Utilities Substation 3

IN PROGRESS Specifications checked and a scope of work is being prepared.

COMPLETED

02.12

Interlocking of Relief Valves

Lock relief valve isolations in the correct position if mechanical interlocks are not provided. Ensure that no nozzles are missing from the sprinkler heads on the spheres. Housekeeping warehouses in

IN PROGRESS CTC Note: Isolation valves without locks were noted during the survey.

The intent of mechanical interlock of safety system and through provision of chain lock. DONT UNDERSTAND

02.13

Audit of Sprinkler Heads

Reported COMPLETE

02.14 02.15 02.16

Warehouses (Offsites) Fire main Checks Inspection of Cold Fractionation Section

UNKNOWN Reported COMPLETE. IN PROGRESS Some inspection under insulation has taken place but COMPLETED and practiced as a routine.

Leakage of valves in fire main Check for under insulation corrosion

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No.

Title

Summary

Status in 2006
there is still considerable work to be done.

Current Status (from EPCL)

03.01

Routine Analysis of Olefins Cold Box Purge Olefins Plant Pipework & Bolting Corrosion

Routine analysis of the cold box nitrogen purge Corrosion pipework on

IN PROGRESS

03.02

COMPLETE TAM1 involved a review of the piping and vessels suffering from corrosion in the olefins plant

03.03

Liquid Ethylene Storage Tank

Various repairs to the ethylene tank.

IN PROGRESS Progress had been made in the area but some work still needs to be done. Examples are the rod hanger on one of the ethylene pipes to the tank and insulation around the liquid ethylene pumps.

Completed. Note that site visits indicated that the rod hanger has still not been replaced.

03.04

Use of Cellular Telephones within the Process Plant

Use of mobile phones within process plant.

NO CHANGE Personnel using phones were noted in several areas including adjacent to the DCS panels, where there is concern that the mobile phone signal could interfere with the DCS. WITHDRAWN This recommendation repeated below. is

04.01

Turn-Around Maintenance Delay

Instigate delayed TAM.

the

A TAM to complete urgent repairs has been completed with a further TAM in the first quarter of 2007.

04.02

Trip Bypass

Develop a trip bypass procedure requiring approval by senior staff.

COMPLETE A review of the register showed that it has just been updated and a considerable number of trips appear to have been previously bypassed with no authorization and still remain bypassed. IN PROGRESS Filing remains rudimentary, with no differentiation between completed and ongoing activities.

04.03

Work Permits

Institute a system of filing for the completed permit to work forms.

COMPLETE and being practiced. SOP is available on the intranet. Note that some issues were identified during the course of the current survey and a new recommendation relating to Permit-to-Work has been developed. COMPLETED in End August 2006.

05-01

Turn Around Maintenance (TAM)

Complete preparations

IN PROGRESS for

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No.

Title

Summary
TAM and execute as soon as possible.

Status in 2006
A TAM to complete urgent repairs has been completed with a further TAM in the first quarter of 2007. IN PROGRESS Most of the fire and gas systems in the process, utility and storage areas are reported to be operational. IN PROGRESS No procedures developed are being

Current Status (from EPCL)

05-02

Fire and Gas Detection and Protection Systems

Repair all Fire and Gas Detection and Protection Systems prior to the TAM.

05-03

Start-up and Shutdown Procedures

Critically review shutdown and start up procedures prior to the forthcoming TAM. Update all P&IDs to reflect the current state of the plant.

05-04

Process and Instrumentation Drawings (P&IDs)

IN PROGRESS EPCL are aware that this needs to be done and progress can be expected once the plants are operational following TAM1. IN PROGRESS Procedures appear to exist but do not extend to the use of padlocks to ensure that a positive isolation. Site visits showed a marked improvement in the quality of isolation compared with 2005. IN PROGRESS Over 900 Pressure relief valves have been tested, including most of those on critical duties.

As built drawing available in Library and distributed to HOFs. Drawings in PDF format expected end February 2009-06-10

05-05

Mechanical and Electrical and Isolation

Develop procedures electrical mechanical isolation.

formal for and

SOP for Electrical and mechanical isolation issued and being practiced.

05-06

Pressure Relief Valve Testing

Produce a register of pressure relief valves and progress the testing of valves.

System exists practiced

and

being

CTt 2006 Recommendations


06-01 Fire Detection/Protection Impairment System

Category
Recommendation

1
Develop an Impairment programme so that equipment which is out of service or being used for non-firefighting purposes is recorded and corrective action is taken as quickly as possible. Staff and contractors should be made aware of this requirement

Reason

Considerable effort and expense has gone in to the renovation of the site, including the fire detection and protection systems and whilst most equipment is in much better condition than at the start of 2006, there are many systems where repairs are not fully complete and there may be confusion over the operational status of equipment. In addition fire water is still being used for cooling and other non fire related purposes. Finally, an up to date report with the status of all fire detection and protection systems would be useful to insurance underwriters at the completion of TAM1 and the start-up of plants.

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06-01
Examples

Fire Detection/Protection Impairment System


Whilst the use of fire water for process cooling is much improved from the situation before TAM1, there are still some cases where fire water is used for cooling. In addition, there is considerable (uncontrolled) use of fire water for purposes, such as wash down of process areas. Fire hoses used for these purposes are evident in several parts of the site and the volume of water is such that the one of the main electrically driven pumps is operating continuously to supply demand. In addition a number of defects, which have not yet been repaired were noted, where these exist additional safety precautions will be necessary to ensure that safety of the facilities are not compromised. These include: One diesel fire pump is not operational Defects to the control system of a second system appear to exist The dry powder system protecting the catalyst area in the polypropylene plant is not fully functional. The trouble alarm on the gas panel in the olefins plant is illuminating Status of fire detectors in the office block is uncertain.

This is probably not a complete list. Status EPCL State that: With the revamp of the fire detection and protection system in PE the system now exist in all plants. CTt Comment Some defects were noticed in many of the plants, this recommendation is considered to be IN PROGRESS.

06-02

Job Safety Analysis (JSA)

Category

Recommendation Reason

Review and implement the Job Safety Analysis procedure as a matter of priority. It should be used to review the safety of all work, including temporary activities associated with start-up. The JSA procedure represents a structured procedure for reviewing the hazards associated with particularly activities. The lack of a structured approach may result in the introduction of unnecessary hazards. Some activities associated with start-up which were unnecessarily hazardous: The use of temporary flexible hoses and drums with screwed fittings and unions for transfer of liquefied gases. Fabrication work (including hot work) close to the cracking furnace area. This work could have been performed outside the plant boundary where there would be less chance of leaks. Uncontrolled use of fire water for cleaning of an elevated heat exchanger. This creates slippery conditions, possibly corrosion to un protected surfaces and continual soaking of personnel working under the water stream from the monitor could cause ill health.

Examples

Status CTt Comment

It is an ongoing process. One set of JSA done for all plant, being added as and when required. The JSA is being performed for routine tasks and should also be part of the permit issuing process. This recommendation is considered to be IN PROGRESS.

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06-03

Under Insulation Corrosion

Category
Recommendation

1
Increase the speed of the under insulation inspection programme. The programme should be prioritised so that the most hazardous piping (based temperature, pressure, contents and corrosion potential) is inspected first. The inspection programme has so far only considered a small proportion of the piping where under insulation could exist. A leak of hydrocarbon material from a corroded pipe could result in a serious fire or explosion. Currently approximately 10% of the pipework has been checked for under insulation. From visual inspection, there are many places where the external weather protection over the insulation has become damaged, with the potential for water to seep into the insulation, possibly causing corrosion. EPCL State that: Under insulation corrosion inspection is being done as a routine and during shutdown opportunities.

Reason

Examples

Status

CTt Comment

There is considerable inspection activity related to under insulation corrosion. recommendation is considered to be IN PROGRESS

This

06-04

Housekeeping

Category
Recommendation

1
As the plant start-ups progress, ensure that surplus construction material are cleared from the site together with any construction tools. In addition, all blinds and plugs should be reinstalled in piping and equipment. All bolts in electrical flanges should be reinstalled. Checks in offsite areas should also take place to ensure a good level of housekeeping around the site.

Reason

Poor house keeping inhibits the development of a safety culture, which the new EPCL wishes to promote. In addition, missing blinds and plugs on pipework and equipment, increases the potential for leakage of hazardous materials and lack of bolting on electrical equipment the explosion proof rating for use in hazardous areas.

Examples

Unchained cylinders were noted next to an analyzer house in the process area Plugs were missing from liquefied gas lines in the offsites area Some plugs and flanges were missing on utility lines in the olefins plant. Bolts were missing from electrical junction boxes in process areas

Note that in some cases, these defects may be due to start up conditions in the units but should still be rectified as soon as possible. CTt comment No information on status was provided by EPCL, however, with some exceptions housekeeping was relatively good and this recommendation is considered COMPLETE.

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06-05

Offsites Area

Category
Recommendation Reason Examples

2
Review Conditions in the offsites area and make appropriate repairs. Whilst the offsites areas are often considered to be low hazard by comparison with the process areas, they still contain large inventories of hydrocarbons with significant fire and BLEVE potential. Much of the lighting system is defective with explosion proof covers missing and electrical contacts exposed. From a visual inspection the system appears unusable, however as a temporary measure it would advisable to isolate the supply to the area at the appropriate substation. Pressure relieves require testing Plugs are missing from some liquefied gas lines The mastic installed in the expansion joints on the concrete dikes of both the refrigerated and pressurized storage has perished and is unlikely to provide an effective barrier to leakage.

Status

EPCL State that: Completed, Repairs done.

CTt Comment

No problems were noted in the offsite area and this recommendation is considered COMPLETE.

06-06

Organization Engineering Function

Category
Recommendation Reason

3
Review the site organization chart and consider the inclusion of a site engineering function, with the inspection group reporting to it. The source of technical support may not always be clear with some departments or individuals making decisions which are best taken by experienced project engineers. A technical services/ engineering group would provide a better home for the metals inspection function than the maintenance function. In the latter case, there may be a conflict of interest between the desire for maintaining equipment and keeping it in operation and removing it for inspection.

Examples Status

Currently there is a Technology Group, with individuals from separate departments rather than a clearly identifiable engineering/technical services function. EPCL State that: Complete.

CTt Comment

A separate technical services function now exists. COMPLETE.

This recommendation is considered

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06-07

Inspection - Hoses

Category
Recommendation

1
Review the inspection requirements for hoses and ensure they are inspected in line with accepted practice. This generally requires checks on electrical connectivity/isolation and a pressure test at six monthly intervals. Hoses should also be checked to ensure that they are fit for purpose.

Reason Examples CTt Comment

Use of poorly maintained hoses or the incorrectly specified hoses can lead to failure and subsequent leakage/fire. Temporary hoses used in the olefin and polyethylene plant had end connects which appear incompatible with use on liquefied gases. No response was received from EPCL but from discussions on site, it appears that inspection practices for hoses are UNCHANGED.

06-07

Positive Materials Identification

Category
Recommendation

3
Increase positive identification of alloy materials to every section of piping material, etc. Materials should be then colour coded before entry into the stores. As EPCL has purchased a Niton metals analyser this should not be problematic.

Reason

The current system relies on the manufacturers mill certificate being correct. Whilst this is usually the case, there are numerous examples where incorrect material has been supplied. This may result in rapid corrosion or failure due to the material being unable to withstand the pressure or temperature limits imposed in operation. If this occurs the pipe may rupture leading to a release of process materials. Currently reliance is placed on the manufacturers mill certificate with no additional inspection unless a problem is detected. No response was received from EPCL but from discussions on site, it appears that inspection practices for hoses are largely UNCHANGED.

Examples CTt Comment

06-08

Operator Emergency Procedures

Category
Recommendation

3
Provide short form emergency instructions in a separate folder to the main operating manual. These instructions should contain emergency shutdown instructions for credible situations in a clear and logical manner. Actions for the panel operators should be listed separately to those for field operators. To ensure that the instructions are understood, an emergency simulation program for process operators should be undertaken. The following points are offered for consideration: Process upset conditions should be considered in turn (e.g. loss of power, loss of cooling water, etc.) Simulation training should take place at least once for each shift team during each rotation Field operators should place tags on the valves they would operate to ensure they know the correct location of the equipment Panel operators should list the actions they would take

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

89

06-08
Reason Examples Status

Operator Emergency Procedures


Field and panel operators actions can be checked and refresher training provide if necessary

In emergency situations, operators and supervisors are under increased stress and the potential for mistakes increases. Training will reduce the potential for error. Currently, there is limited emergency training for process operators. EPCL State that: SOP for emergency procedures existing. completed and available on the intranet. On site Emergency Management Plan (OSEMP)

CTt Comment

Whilst there has been a revision to the site emergency plan, there has been no change to the emergency shutdown procedures. However a new recommendation has been made during this survey (09-06) and the recommendation is WITHDRAWN.

06-09

Permit To Work

Category
Recommendation

3
Review the permit to work system with regard to the follow points 1. 2. 3. Have all approval and hand-back signatures on the same side of the form Review the need for additional types of permits (for example excavation) Improve filing to ensure that permits for completed activities are filed separately to those for ongoing work. Ideally all copies of the permit should be reunited in the control room and signed off together.

Any changes made will need to be fully explained to both operational and maintenance personnel via appropriate training. Reason 1. 2. 3. This will increase the ease of auditing the procedure and ensuring that it works as designed Some activities, such as excavation, require particular checks which are not appropriate to most cold work activities and could be missed unless specifically noted on the permit form. A common file of permits can lead to confusion over the status of work, with the possibility that operators might try to start equipment which is still awaiting completion or maintenance. For example, where there are delays due to the absence of spare parts. The new style permits have authorization signatures on the front of the form and the hand back signatures on the back. The cold work permit is used for excavation and the hot work permit is used for radiography A single file for all permits is used in the olefins control room

Examples

1. 2. 3.

Status

EPCL State that: COMPLETE and being practiced. SOP is available on the intranet. Note that some issues were identified during the course of the current survey and a new recommendation relating to Permit-to-Work has been developed.

CTt Comment

There are still some issues with the permit to work system and a new recommendation (09-07) has been made. This recommendation is WITHDRAWN.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

90

06-10

Management of Change

Category
Recommendation

3
Review the management of change procedure to: 1. Provide clear guidance on the criteria by which changes are considered trivial and those which require a more detailed safety assessment, including a HAZOP study. A sample checklist which may prove useful is given in Appendix C Update the procedure to include changes to staffing levels and job functions. information is given in Appendix D and a sample method of is given in: 213.212.77.20/research/crr_pdf/2001/crr01348.pdf Further

2.

Reason

1. 2.

The lack of clear criteria to determine if detailed assessment is necessary could result in hazardous changes being approved without adequate assessment. The lack of an assessment procedure for staffing changes could result in the introduction of hazards in situations where staffing levels change, job descriptions are altered, etc

Examples Status

The aspects discussed above are not included in the current Management of Change Procedure. EPCL State that: MOC system implemented. SOP available on the internet.

CTt Comment

Some aspects of the MOC procedure still require improvement and this recommendation is IN PROGRESS.

06-11

Emergency Plan

Category
Recommendation

3
Review the existing Emergency plan to provide a greater level of detail in areas such as: 1. 2. 3. The provision of an adequately equipped emergency coordination centre in a safe and accessible location Review the format of the plan to see if it can be restructured for improved clarity Prepare fire pre-plans for likely fire situations.

To ensure that the practicality of the plan a full scale or desktop exercise should be performed. Reason 1. The current location of the emergency coordination centre is undecided. One option appears to be the use of the fire station control room. It is generally considered preferable to use a room without distractions close to the main entrance. The current emergency plan is comprehensive but the information is not always easily accessible. Key facts are hidden in complex paragraphs and may be overlooked during an emergency when staff will be in a highly stressful situation. Greater use of bullet points, flow charts, and shorter paragraphs would assist and some information aspects could perhaps be transferred to appendices. Currently there are no detailed plans for fire fighting in some of the areas with significant fire potential. Preplanning will allow a faster response to a fire, resulting in a lower level of damage. An example is given in Appendix E.

2.

3.

Examples Status

Site emergency plan. EPCL State that: SOP for emergency procedures existing. On Site Emergency Management Plan completed and available on the Intranet.

CTt Comment

Some aspects, such as pre-planning are still not complete. The recommendation is considered to be IN PROGRESS.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

91

06-12

Asset Ownership of Fire Fighting Equipment

Category
Recommendation

3
Review asset ownership of the fire protection and detection equipment. One department, ideally the fire department, should have overall responsibility for ensuring that the equipment is in good condition, regularly tested. This does not imply that the department should physically check the equipment but should be responsible for ensuring that it is tested. The same department should also be responsible for noting impairments and controlling the use of fire water by other uses. Firefighters could include in their duties regular checks on the state of equipment

Reason

At present ownership of the assets appears confused with assets generally being owned by the department where they are located. This can lead to confusion over who is responsible for checking equipment and ensuring that it remains in working order. If the firefighters take over ownership, it should also help ensure fire water is used correctly and that fire hoses, etc. are maintained in good condition and available for use.

Examples

Several examples were noted where the apparent status of equipment differed from that found in practice: Diesel fire pumps were in one case reported to be operational, when one requires a new battery. The weekly running tine for the diesel fire pumps was variously reported as 10 and 30 minutes (the latter is preferred practice). Fire water is being used for a number of purposes other than the three coolers which still require additional cooling.

CTt Comment

No information was provided, the status is UNKNOWN.

ARM Survey 2008


08-01
Recommendation

Vibration Monitoring
Regular monitoring and analysis of vibration of rotating equipment enables any problems to be identified quickly and rectified in a timely manner. Therefore, it is recommended that vibration monitoring be extended to include all items of rotating equipment. The frequency of the monitoring should be decided by the criticality of this equipment. The facility has good on-line monitoring of major items of rotating equipment and the ability to perform vibration monitoring and analysis of other items of rotating equipment. However, the monitoring is not as extensive as one would expect from a modern petrochemical plant. EPCL state that: Vibration monitoring has now been extended to all rotating equipment. Frequency is determined based on criticality (A, B, C, D).

Reason

Status

CTt Comment

This recommendation is considered COMPLETE.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

92

08-02
Recommendation

Analysis of Transformer Oil


The study of gases from transformer oils can be used to give and early indication of abnormal behaviour of the transformer and may indicate appropriate action that may be taken on the equipment before it suffers great damage. The frequency of the testing being determined by the nature of results obtained, with the interval being reduced depending upon the rate of rise of gas concentration. Therefore, it is recommended that the facility follows current industry best practice of sampling and testing transformer oil every 12-18 months. It was indicated that the transformers' oil was sampled and tested during TAM1 This included Dissolved Gas Analysis (DGA) and dielectric testing. It was reported that similar testing would be performed during TAM2 and subsequent turnaround. EPCL state that: Transformer oil analysis being done with in-house resource. purchased. Testing frequency is once every six months. Suitable testing kit has been

Reason

Status

CTt Comment

No further DGA analysis has been undertaken and the recommendation is considered to be UNCHANGED.

08-03
Recommendation

Structural Fireproofing
It is important that pipe and vessel supports are sufficiently fireproofed to ensure that further fuel is not fed to any fire due to the failure of pipe or vessel supports and the subsequent rupture of pipelines. In this respect it is recommended that the level of the fireproofing in all pool fire hazard areas be reviewed using AP1 Standard 2218 as a minimum. There appears to be several locations in pool fire hazard areas where the installed fireproofing does not provide complete fire protection to the pipeline supports. In addition there are several instances where vessel skirts have inadequate fireproof protection. EPCL state that: Fire proofing for structural steel exist in PE/PP and partially in Olefins. Additional pool fire prompt areas in Olefins were identified and fireproofing was provided i.e. skirt of de-ethanizer and de-propanizer columns.

Reason

Status

CTt Comment

No areas of defective fire proofing were noted. This recommendation is considered COMPLETE.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

Appendix A Plot Plan

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

Appendix B Permit to Work Forms

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Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

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Appendix C Management of Change Checklist

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

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SAFETY ASSESSMENT Plant Underline those factors which have been changed by the proposal. Process conditions temperature pressure flow level composition toxicity flash point reaction conditions Operating methods start up routine operation shutdown preparation for maintenance abnormal operation emergency operation layout and positioning of controls and instruments Engineering methods trip and alarm testing maintenance procedures inspection portable equipment Safety equipment fire fighting and detection systems means of escape safety equipment for personnel Environmental conditions liquid effluent solid effluent gaseous effluent noise Engineering hardware and design line diagram lighting protection wiring diagram radioactivity plant layout rate of corrosion design pressure rate of erosion design temperature isolation for maintenance materials of construction mechanical-electrical loads on or strength of: fire protection of cables foundations handrails structures ladders vessels platforms pipework/supports/bellows walkways temporary or permanent: tripping hazard pipework/supports/bellows access for valves operation slip-plates maintenance restriction plates vehicles fillers plant instrumentation and control fire fighting systems underground/overhead: trips and alarms services static electricity equipment What problem has been created which affects plant or Signed personnel safety and what action is recommended to minimise it & date Title Ref No

Within the categories listed below, does the proposal Relief and Blowdown 1. 2. 3.

Yes or No

Introduce or alter any potential cause of over/under pressuring (or raising or lowering the temperature in) the system or part of it? Introduce a risk of creating a vacuum in the system or part of it? In any way affect equipment already installed for the purpose of preventing or minimising over or under pressure? Introduce or alter the location of potential leaks of flammable material? Alter the chemical composition or the physical properties of the process material? Introduce new or alter existing electrical equipment? Require the provision of additional safety equipment? Affect existing safety equipment?

Area Classification 4. 5. 6. 7. 8.

Safety Equipment

Operating and Design 9. Introduce new or alter existing hardware? 10. Require consideration of the relevant Codes of Practice and Specifications? 11. Affect the process or equipment upstream or downstream of the change? 12. Affect safe access for personnel and equipment, safe places of work and safe layout? 13. Require revision of equipment inspection frequencies? 14. Affect any existing trip or alarm system or require additional trip or alarm protection? 15. Affect the reaction stability or controllability of the process? 16. Affect existing operating or maintenance procedures or require new procedures? 17. Alter the composition of, or means of disposal of effluent? 18. Alter noise level? Safety Assessor. ............................................................. date ....................................................................................................................................... Check by ................................................................. Plant Manager ........................... Checked by ...............................................................Engineer

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

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Appendix D Organizational Change Guidance

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Appendix E Sample Fire Fighting Pre Plan

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

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Reproduced with Permission of Resource Protection International Phone (44) (0) 1296 399311 Fax (44) (0) 1296 395669 Email ramsden@resprotint.co.uk

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

Eleme Petrochemical, Port Harcourt Nigeria Insurance Risk Survey

CTC Services Ref.: 463252/DSS/RAR

ERP- 7 EMERGENCY RESPONSE PLAN FOR:

ALL FLOATING ROOF TANKS GENERIC FULL SURFACE FIRE

Doc. ERP-7 doc. Approved: Rev: 0. Date: November 2002.

STRATEGY Site ESD - Halt ship loading operations - Deploy water monitors for cooling any adjacent tank or tanks affected by radiant heat Allow tank burn out whilst cooling adjacent exposures pump out of crude if possible - If foam attack decision is made, ensure all resources in place before attempting foam attack If foam attack fails all personnel to be evacuated from site and await boilover.

IMMEDIATE RESPONSE
[ [ [ [ [ [ [ [ [ [ [ ] ] ] ] ] ] ] ] ] ] ] Control Room/Technicians Control Room/Technicians Control Room Technicians Control Room Control Room Control Room Control Room OSC OSC OSC

ACTIONS
Investigate and confirm fire event. Stop tank and ship operations and Site ESD isolate tank Actuate site alarm and start fire pump. If safe and possible, ensure plant evacuation. Inform LAFB (Fire Brigade) and Refinery Fire Station Inform Refinery to halt pumping and advise Berth Supervisor Alert duty on-call, Asset Manager and Ops Engineer Check ballast rundown is in commission for firewater supply Ensure OSC jacket is on for recognition. Ensure this section actions are checked done. Make contact with arriving LAFB officer and handover ERP

EQUIPMENT / RESOURCES
Affected tank MOVs and Site ESD Valves Site alarm switch and fire pump start in CR Telephone 999, Refinery Fire Station xxxx Telephone or Radio Telephone, pager or radio.

INFO / COMMENTS

Any available technicians to act as Local Evacuation Officers (LEOs) and direct evacuees to a safe muster point. Team Leader to act as initial OSC until relieved.

This ERP

2nd RESPONDERS
[ [ [ [ [ [ [ ] Authorised Person/Security ] Security Guard ] Technicians ] Technicians ] Technicians/OSC ] Technicians/OSC ] OSC

ACTIONS
Establish evacuation status/any missing persons. Handover this ERP LAFB Fire Officer and direct all fire vehicles to incident scene. Respond with site fire vehicle Deploy water monitors for cooling adjacent tank. Establish a fire control point for oncoming fire brigade units to report. Line up available tanks to take affected tank pump out. Check all actions in this section are marked and give ERP to LAFB Officer on arrival.

EQUIPMENT / RESOURCES
Access Control Read Out/Print Out This ERP Site fire vehicle. 2 x 2500lpm portable water monitors, 24 x 70mm delivery hose. Control point to be at nearest/safest site telephone. Tank MOVs

INFO / COMMENTS

Inform LAFB Fire Officer that all listed actions have been carried out up to this point.

3rd RESPONDERS
[ [ [ [ ] LAFB Fire Officer ] LAFB Fire Officer ] LAFB Fire Officer ] LAFB Fire Officer

ACTIONS
Report to incident control point for incident information. Deploy water monitors for cooling adjacent tank. If decision is to attempt extinguishment, set-up/actuate foam monitors onto full surface fire. Delegate officers as Safety Observers to give advance warning of boilover event.

EQUIPMENT / RESOURCES
Control Point 4 x 2500 lpm portable water monitors, 48 x 70mm delivery hose. 4 x 15000 lpm foam monitors, 216,000 litres of 3% fluoroprotein foam, 240 x 70mm delivery fire hose. Total water demand for foam and water monitors is 75,000 lpm

INFO / COMMENTS
If extinguishment decision taken, site fire pumps can only provide 26,500 lpm approx. so other supply arrangements are required. Foam concentrate based on 3% Fluoroprotein at a rate of 10.4 lpm/m2 for 120 mins. Total foam stock on site is 20,000 litres, so additional foam supplies are required if foam attack is to be made.

Maintain foam application until fire is extinguished and thereafter until a secure foam blanket established. INCIDENT POTENTIAL HAZARDS Crude oil full surface fires in tanks, if left to burn freely, create a heatwave which sinks into the tank and on contacting a water layer causes a boilover with sometimes violent or severe ejection of burning crude. This event, in worst cases, may lead to burning crude flowing over an area of 300 metres diameter. Personnel should not work inside the tank bund after the initial stages of the fire due to boilover hazard. A boilover may occur at any time after the first few hours of the incident and no reliance should be placed on anticipating the heatwave reaching the base of tank before a boilover will occur. It is prudent to expect a boilover anytime after the first 2/3 hours of the incident.

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR

Eleme Petrochemical, Port Harcourt Nigeria Insurance Risk Survey

CTC Services Ref.: 463252/DSS/RAR

Resource Protection This Emergency Response (ERP) is provided as(RA) an example of format and content which / TOXIC HAZARDS RADIOACTIVE HAZARDS / ASBESTOS HAZARDS OTHER CONCERNS Foam should not be applied to a crude tank fire until there is sufficient freeboardPreplan in the tank Operator and Responder actions and has been found to workable and accepted by International 1 RA Instrument/Gauges on be Seal Water Drum V-511 on MVR Unit. It is Cs-137 since foam application without space in the tank to accommodate will leadcombines to slopovers and foam wastage. This is legislative authorities. It shell is an example and should be used as the basis for Emergency material with 2627not MBq. most important where overfill has caused incident and where crude oil is at or very near to the tank height. It only Phone (44) (0) 1296 399311 at a particular facility. It is vital that ERPs are site specific and reflect the selected strategy may be that the fire needs to burn for an hour or more before it is safe to Response apply foam. A check on the visual heat No asbestos is present. and available resources at that site ) Further information can be provide by Resource Protection No toxic materials. indications on the tank shell top will indicate where the level is at any time.

ERP-007

Pool fire e xtent in tank. Fla me drag down wind in any direction 12.5 kW/ m2 heat contour down wind In any direction 6.3 kW/m2 heat contour down wind In any direction

Doc: DAL-07.ppt Approved: Rev: 0 November 2002

Date:

NOTES 1. Steelwork in any flame impingement or within the 12.5 kW/m2 contour will need rapid and constant cooling except for involved tank shell 2. Fire responders may enter the 6.3 kW/m2 contour only if fully donned in PPE and only for very brief tasks.

ERP-07 CRUDE TANK FULL SURFA CE FIRE GENERIC FOR ANY CRUDE TANK
CDT

Eleme Petrochemical, Port Harcourt . Nigeria - Insurance Risk Survey - Ref.: 464057/DSS/JH/RAR