2012 Rec's

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3. Recommendations for Risk Improvement

3.1. New Recommendations
CTT categorises 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. These recommendations should be completed within three months of the survey report date.
2. CAPEX: Recommendations requiring capital investment. These recommendations should be completed within the next budget cycle unless a major shutdown is required for implementation.
3. Procedural: 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. These recommendations should be completed with 12 months of the survey report date.
12-01 Category Recommendation Priority
New Projects Risk Engineering Review CAPEX Procedural
Undertake a risk engineering review of the proposed new units. This will involve a review of the design to: Ensure that appropriate process safety features are installed. An adequate level of fire protection is installed. Time to react to and recover from incidents is minimised. Process safety and fire fighting systems are appropriate for staffing levels and maintenance regimes that will exist once the units are complete. The study is probably best conducted at the project contractors offices at a point in time where the findings can be incorporated in the final scope of work. A risk engineering review will ensure that appropriate process safety features are built into the new units. This, in turn, will result in a greater potential for the incidents to be more easily prevented or controlled. Ammonia, Urea and Ethylene plant upgrade projects.
Reason
Examples
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
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New Projects Consequence Modelling CAPEX Procedural
Perform a study using consequence modelling to determine the effects of an incident in one part of the site on other locations. The study should cover areas outside the process facilities, including: storage, utilities, offices, accommodation areas and residential areas outside the site boundary. The study should consider: Explosions (including VCE and BLEVE). Fire (both pool and jet fire). Toxic gas release. Terrorism and sabotage. Natural perils. Utility failures. Contingent failures such as loss of feedstock. The study should consider hazards at both the construction and operational stages. The results of the study would provide input into the detailed design and layout of the facilities (including the requirement for safe havens in the event of a major ammonia escape) and emergency planning. The new plants being constructed, plus planned expansion to the original facilities, will change the overall hazard profile at the site. The interrelationship of the hazards needs to be considered in detail, especially as there are now a significant number of people resident at the site something not envisaged at the design stage. Planned construction projects at the site, particularly the ammonia and urea plants.
Reason
Examples
Controlled Documents CAPEX Procedural
Develop a consistent procedure covering all parts of the site. The procedure should cover the format of documents (including the recording of revision numbers and dates of changes). There should also be a consistent approach to the storage and filing of master copies of documents and a register of holders for controlled documents. Unless there is a consistent approach to document control, there is a potential for confusion between the status of documents at different parts of the site. There are different approaches to controlling documentation at the olefins and polymer units. Within the Olefins plant, there is a "controlled" copy with a red stamp on each page. If photocopied the red stamp will appear as black and it will be clear that the document may not be up to date. Within the polymer units "original copies" are available which have no distinguishing stamps.
Reason Examples
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Permit to Work System Filing CAPEX Procedural
Revise the permit procedure to ensure that permits are filed for more than a week. The following points should be considered: If all copies of the permits are collected together and "signed back", there can be no confusion regarding the status of work which could occur if a loose copy of the permit was found. There should be separate files for completed and uncompleted work. In addition to the permit forms, supporting information should be included (Job safety analysis sheets, isolation certificates). There should be regular auditing of the permit system. Whilst filing in the control room for an extended period (beyond the normal auditing frequency) is not necessary it is common to file permits for a two year period. The current practice of filing a single copy of each permit for only a week gives limited opportunity for auditing. Files of permits in all units.
Reason Examples
Database of Recommendations CAPEX Procedural
Develop a central database of recommendations from accident investigations, safety audits and other sources. The database should be checked and reviewed regularly to ensure that recommendations are being progressed towards an end point for implementation. Ideally, the database should nominate a responsible individual for each recommendation, with a timeframe for implementation and automatic flagging of overdue actions. Unless a comprehensive set of recommendations is available together with a robust programme for implementation, there is a danger that many recommendations will not be completed. In addition a backlog of incomplete recommendations is likely to have a negative effect on the safety culture of the site. EPCL operated several databases for recommendations from different sources.
Reason
Examples
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12-06 Category Recommendation
Ethylene Storage Tank Area - Housekeeping Priority CAPEX Procedural
Clear vegetation from the dike area and make sure that the area, including the impounding basin is in good condition. Confirm that the foam system for the impounding basin is in good condition (both the equipment and the foam). There is currently significant vegetation growth within the ethylene tank dike. This could become a fire hazard during the dry season. In addition, there is stagnant water and small trees growing within the impounding basin. This could limit the capacity of the tank for ethylene spills and the water would provide a source of heat to assist vaporization of ethylene. In addition. tree roots might cause damage, to the basin and damage its integrity. The integrity of the foam system is unknown and may not be functional. Ethylene storage tank area.
Reason
Examples
12-07 Category Recommendation
Gas Detection Systems for Occupied buildings Priority CAPEX Procedural
Review the gas detection systems associated with HVAC systems. If the detectors are located within the air ducting, consider relocating them to a location near to the inlet of the HVAC system. EPCL has pellistor type gas detectors rather than alternative infra-red type. The principle of operation of pellistor type detectors is to measure the temperature rise when flammable gas is combusted on a catalyst pellet. If detectors are installed in a moving air stream, there will be a cooling effect which will counter the heat rise, possibly leading to false readings. Olefin plant control room.
Reason
Examples
Inspection of Fire Protection Equipment CAPEX Procedural
Ensure that regular inspections of ALL fire fighting equipment are made and recorded. Ideally there should be random spot checks by management to ensure that inspections are being correctly undertaken. This recommendation should be read in conjunction with recommendation 0601. Unless regularly inspected, it is difficult to ensure that equipment is in the correct location and in good condition. Whilst almost all extinguishers had inspection tags, the frequency of inspection varied from one location to another. In addition, some sprinkler systems in the Polyethylene warehouse had been isolated.
Reason Examples
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12-09 Category Recommendation Reason Examples Priority
Testing of fire fighting Foam CAPEX Procedural
Conduct regular checks on the stocks of fire fighting foam at the site. Foam which is not in good condition should be replaced. Defective fire fighting foam will perform effectively either in a fire fighting role or as a sealant for liquefied gas spillages. Fire fighting foam stocks.
3.2. Previous Recommendations

There have been a series of surveys of EPCL, dating back to the days when it was owned and operated by NNPC. During these surveys numerous recommendations were made and, during NNPCs ownership, there was little improvement. The recommendations below were those which were outstanding at the end of the 2011 survey. Of the 24 recommendations in 2011: 6 are complete 11 are In progress 2 are withdrawn 5 are Unchanged
11-01 SIMOPS (Simultaneous Operations)
Category Recommendation
3 Develop a procedure to control simultaneous construction and operation within the same area. The procedure should include, but not be limited to: Ensuring adequate separation between construction and operational areas, including the installation of fences and emergency exits A risk matrix to identify which construction/commissioning activities can be safety undertaken concurrently with operational activities. Communication between operating and construction personnel in areas such as: o Hot work o Emergency response A good description of SIMOPS activities at an onsite location is available from: http://www.onepetro.org/mslib/servlet/onepetropreview?id=IPTC-13705-MS&soc=IPTC Construction and commissioning activities can lead to hazardous situations, which, without careful control and communication, can result in hazardous situations occurring. The main value of the SIMOPS procedure will be in the future when construction of the LDPE, methanol and ammonia/urea plants takes place. There are some areas within the existing facilities where SIMOPS is currently applicable, for example in the construction work being undertaken in the PE plant. Where a portable concrete mixer with an internal combustion engine was in use. This appeared to be close to or within an electrically classified area with no evidence of a hot work permit. Procedure is under development, implementation by September 2011. It was not confirmed that this recommendation has been completed and it is considered IN PROGRESS. With construction work due to start at the site in a few months time, it is important that this recommendation is completed without delay.
Reason
Examples
EPCL Post Survey Comment 2011 Status October 2012
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Internal combustion driven concrete mixer close to process area in PE plant
11-02
Wafer Valves
2 Identify any wafer (long bolted) valves on hydrocarbon lines in the process units and storage areas. These should either be replaced with standard flanged valves or provided with insulation and a fire resistant covering. The longer bolts in wafer type valves have limited thermal inertia and will heat up quickly in a fire. They are also likely to suffer from direct flame impingement if there is a fire in the area. The direct flame contact causes the bolts to expand rapidly and lengthen, allowing both gaskets to leak hydrocarbons which will feed the fire and increase the level of damage. A wafer type valve was identified in the piping around the 1-C-5 column in the Olefin plant. We are reviewing the status of long bolted valves along with designer specs. Appropriate action will be taken for fire protection based on it. October 2011. Insulation has been installed to protect the long bolted flanges, an example was shown below. The recommendation is COMPLETE.
Reason
Examples EPCL Post Survey Comment 2011 Status October 2012
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11-03
Control of Maintenance
3 Conduct a fundamental review of the existing procedures for the control of maintenance to ensure compliance with existing good practice in the hydrocarbon processing industries. The review should include a full assessment of all aspects of the maintenance activities, including: The requirement for some form of risk assessment before the start of each activity (standard procedures could be used for frequent activities). Ensure that the job site is visited by operations and maintenance staff together prior to the issue of the permit and at the hand-back stage. Limit the validity of the permit to a single shift, with a maximum period of 24 hours with revalidation at each shift. Examination of equipment to be used for each activity to ensure that it is suitable for its purpose. Ensure that all personnel are aware of the activities currently taking place. This is often achieved with the use of plotplans mounted on a wall in the control room with markers showing the location and type of activity. In addition, a copy of the permit should be available at the job site. Permits should be filed for a period of at least three months to allow auditing of the system. There should be separate folders for filing permits for completed work and permits for work that is continuing (even when the permit has expired). Isolation and de-isolation of equipment, ideally using a Lock Out/Tag Out (LOTO) system. The permit system should be regularly audited. Guidance is available from a number of sources, including:
http://www.ogp.org.uk/pubs/189.pdf
http://www.hse.gov.uk/pubns/priced/hsg250.pdf Reason There have been a number of recommendations relating to the permit to work system and a fundamental review is considered desirable to ensure that safe working procedures continue to be to a high standard. As EPCL have an ambitious expansion programme over the next few years, now is considered to be the ideal time to review the permit system.
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Examples
A number of issues were identified during the survey: There is no indication that each activity has some form of safety assessment or risk review prior to work commencing (however standard risk assessments are available for some tasks). Equipment for use for maintenance appeared unsuitable: o Electrical cabling with taped connections in the PP plant o Internal combustion engine driving a concrete mixer, possibly in an electrically classified area, in the PE plant o A sandblasting skid with a non "Ex" rated motor in the Olefin plant. Whilst this may be intended for use during plant shutdowns, it is likely that in some cases it will be used for sandblasting whilst adjacent equipment is in operation. No permits were displayed at jobsites. Permits examined in the control rooms showed that permits were kept open over weekends with some permits being open for five days. The "sign-off" date by operations supervisors was often a day or two after the last day of validity of the permit, suggesting a gap between work being completed and checks at the jobsite. It should be noted that two of the four fires reported in 2011 were related to the control of maintenance. The existing procedure is effective and well established. However, we are reviewing it for further improvement based on some of the recommendation. The plot plan with location marking showing activities already exist in control room. (Auditor may have overlooked.) Most of the suggestions have already been implemented in our system. This is COMPLETE, an example is shown below:
EPCL Post Survey Comment 2011
Status October 2012
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11-04
Trip Bypass Procedure
3 Review the current trip bypass procedure and, if considered necessary, revise it to ensure: Trips which are bypassed for an extended period receive a higher level of scrutiny than trips bypassed for a short period of time. This is often achieved by requiring a higher level of authority to extend a bypass beyond a short period of time. Where bypasses are required to extend beyond a short period of, typically 24 48 hours, a Management of Change procedure is followed. The bypass procedure should require some form of risk assessment to identify any additional safety precautions required whilst the bypass is active. Ensure that procedure is followed rigorously. The trip bypass authorization forms should be filed (with separate files for completed and active forms). Regular auditing of the forms and bypass register should take place to ensure that the procedure is being followed as required. If a trip bypass register, in addition to the forms, is to be used each trip should be individually "signed off" and "signed back". It may be appropriate to modify the existing procedure so that multiple trips, on a single piece of equipment can be bypassed simultaneously when the equipment is out of service. However, the disabling and, especially, the establishment of each trip should be noted individually. A discussion of trip bypass procedures is given in: http://www.torusinsurance.com/documents/Best%20Practice%20Centre/Safety_Interlo ck.pdf Whilst EPCL currently has a trip bypass procedure as part of the safety manual, this requires a separate form to be completed for each bypass. This is considered impractical in situations where multiple trips may be bypassed at the same time. For example during the decoking of a cracking furnace. Where procedures are developed but then not used, short cuts and deviations can occur. It is preferable to have a clear concise, practical procedure which can be used throughout the site without the need for modification or misuse in some situations. During visits to the control rooms no bypass forms were reviewed but each plant had a trip bypass register which appeared to be correctly completed. In the Olefins plant, the trip bypass register dates from March 2011. There was no evidence of any trips which were previously bypassed being "carried forward" to the new register. There were a number of cases where bypasses had been in place for weeks. Elsewhere in the register, it was not clear if individual loops had been established or not as a single signature appeared to have been used to confirm that several bypasses had been re-established. The present system is well established and most suitable based on our requirement and type of work being done. However, we are reviewing it further. Some of the suggestions have already been taken care. Trip bypass registers are being prepared for use in the individual unit control rooms but the implementation of a more advanced trip bypass system has not been investigated. The situation is UNCHANGED.
Reason
Examples
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11-05
Flange Systems
3 Review the current practices with regard to : Provision of blinds (to ensure that only correctly rated blinds are installed). Studs fully penetrated the nuts at both ends of a flange. Specification of bolts and studs on stainless steel piping (to ensure that studs and bolts are to the same material as the flanges and piping). The value of good bolting practices could be emphasised through training courses, toolbox talks, etc. Poor bolting and flange practices increase the likelihood of flange leaks and the release of sufficient hydrocarbon material to generate a fire or explosion. This problem is shown clearly in the schematic below. A particular concern exists if carbon steel bolts are installed in stainless pipework. In the event of low temperatures, for example during blowdown, low temperatures could be generated in pipework. Whist stainless materials might be suitable, there could be brittle fracture of carbon steel studs. A thin steel plate was installed as a blind on a virgin C5 line at offsites liquid pump house. Studs which did not fully penetrate the nuts on either side of the flange were noted in the offsites LPG pump area. Very limited amounts of short bolting were noted in process areas. Stainless piping and flanges with carbon steel bolting were noted in the olefin plant cold section.
Reason
Examples
EPCL Post Survey Comment 2011
We have already surveyed short bolting and less bolting. Correction is under progress. Since some blinds are only for positive isolations, thickness was less for big diameter pipes. However, all attempts are to be made to install correct rated blinds in true isolation cases. The response is unclear. Where blinds are installed in pressurised systems, they should always be rated for the same pressure as the piping system. No examples of incorrect flanging were noted during the survey. The recommendation is considered COMPLETE.
CTt Comment Status October 2012
11-06
Maintenance of Drains
Category Recommendation Reason
3 Ensure that a regular programme of drain cleaning takes place throughout the site. This should be controlled through the maintenance work order system. Whist the flow through the drains systems is generally low, much higher rate flows may occur during heavy rain. If the drains are partially blocked rainwater might flood some areas of the plant resulting in damage. The drains are also required to cope with fire water flow and if restricted could result in a back-up of water spreading out on the plant with burning hydrocarbons on top. The area exposed to fire could be increased significantly. The drains are also required to transfer spillages of hydrocarbons to a safe location and if blocked or restricted could result in a pool of liquid which could result in a fire. A flooded drain was noted on the edge of the process area. Channels to discharge LPG out of the storage area are partially blocked by earth and vegetation.
Examples
We will enhance the drain cleaning frequency; this is an on-going process. In general, drains were clean and the recommendation is COMPLETE.
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11-07
Risk Based Inspection
3 Develop a risk based inspection programme, including recording and analysis systems in advance of the next plant turnaround. Whilst the plant is approx. 17 years old, there was limited inspection activity prior to the takeover of the site by Indorama. Since then there has been a huge increase in the amount of inspection activity undertaken. Until now this has concentrated on ensuring the integrity of the existing assets. However after the next turnaround, there will be adequate data available to start a Risk Based Inspection (RBI) programme. This will require trending of wall thickness data to determine corrosion rates and remaining life of materials.This process would be facilitated if systems for storage and analysis of data were in place prior to the next turnaround. Currently, there is no programme for trending of inspection data. For RBI, as suggested, a system is under development by trending of piping thickness data by December 2011. Trending of wall thickness reduction is only one aspect of RBI but a necessary one. An analysis of the consequences of failure is also necessary to help in focusing inspection efforts in the areas of greatest loss potential both in terms of frequency and magnitude.The following references give a general overview of risk based inspection procedures:http://www.hse.gov.uk/research/crr_htm/2001/crr01363.htmhttp://www.dnv. com/binaries/13_paper_aem_%20paper_final_tcm4-367866.pdf There has been limited progress, possibly due to the departure of the inspection manager. The recommendation is IN PROGRESS.
Examples EPCL Post Survey Comment 2011 CTt Comment
Status October 2012
11-08
Corrosion Under Insulation
3 Increase inspection of high hazard areas where Corrosion Under Insulation (CUI) might be present. In particular inspection should concentrate on areas where the insulation is damaged. Corrosion, if unchecked, will result in thinning and rupture of the pipe and the possible release of hydrocarbon materials with the subsequent potential for fire or explosion. There are numerous places in the process and storage areas where damaged insulation is present and in some cases vegetation growing. A specific case is the pipework at the base of the refrigerated ethylene storage tank. Most CUI inspection is done during TAM. We shall enhance scope during TAM 2012 as per hazard. CUI can be minimised by insulation repairs that should be taken up thoroughly in the whole complex on priority. The problem with CUI is the lack of visibility of corrosion as it hidden beneath the insulation. Where repairs are made to insulation, it is necessary to check and ensure that there is no CUI before repairing the insulation. Repairs to insulation will not prevent pipework rupture if corrosion is already present.As a minimum, a register of suspect locations should be established and inspections made as quickly as practical. In many cases, CUI inspections can be undertaken outside of a TAM.There are also techniques, of varying effectiveness, which can be applied to check for CUI without removal of insulation.The implementation of an RBI programme will assist in identifying the piping sections which should receive priority. Pulsed Eddy Current technology is being used to check for under insulation corrosion. Note that whilst this will work for many applications, there are some areas where it is unsuitable. The recommendation is considered to be IN PROGRESS.
Reason Examples
EPCL Post Survey Comment 2011 CTt Comment
Status October 2012
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Refrigerated ethylene tank pipework with corroded insulation
Vegetation growing in process piping
11-09
Fireproofing
2 Review the condition of fire proofing in the process areas and, where appropriate make repairs. Fire proofing provides protection against damage to steelwork from thermal radiation and direct flame impingement. If the fire proofing is damaged, even in only one area the protection will be damaged. Fireproofing was damaged in a number of locations in the process areas. Most of the damage noted was on structural steelwork. Fire resistant panels had been attached on top of steel beams. We are reviewing it considering relevant API standard. The comment above is applicable for areas where additional fireproofing is required. However, it does not cover repairs required to existing fireproofing. A specific response to the recommendation was not obtained but no problems were noted on site. Pending confirmation from EPCL that the repairs are complete, the recommendation is considered to be IN PROGRESS.
Examples
EPCL Post Survey Comment 2011 CTt Comment Status October 2012
Damaged fireproofing in the process area
Damaged fireproofing in the process area
09-01
Sampling Procedures
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
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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. 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. A JSA is reported to be in place and some sampling points go to flare. However there does not appear to have been a comprehensive review of sampling and development of methods of working which avoid the release of liquefied gases to atmosphere. The recommendation is IN PROGRESS. We will do a comprehensive study for sampling and development methods of working. Current practice is to purge to flare before sampling where possible rather than to purge to atmosphere. Some piping modifications will be necessary before all purging to atmosphere ceases and these will be completed at the next turnaround. The recommendation is IN PROGRESS.
Examples EPCL Post Survey Comment 2009 Status May 2011
09-02
Fire and Gas Alarm Systems
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.
Examples
EPCL Post Survey Comment 2009 EPCL Status May 2011
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. It has been reviewed and JSA is in place now. All the Fire panels examined showed numerous faults. However this is understood to be as a consequence of changes to the power supply to the panel and alarm loops. In addition, there were fire alarm lights illuminated in some places and, possibly, some genuine fault alarms. The recommendation is considered to be In PROGRESS. Being reviewed from time to time. No problems were noted in the fire and gas panels during the surveys. recommendation is considered COMPLETE. The
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09-03
Control Room Doors
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. Control room doors in the PE and Olefin plant were in the open position during the survey. There is NO CHANGE to the situation at the time of the previous survey. Door closures are already installed. We will establish administrative control to ensure doors are always closed. The situation is UNCHANGED.
09-05
Document Control
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. 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. 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.
Reason
Examples
EPCL Post Survey Comment 2009 Status May 2011 EPCL Post Survey Comment 2011 Status October 2012
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. EPCL is modifying their document control procedures to comply with ISO 9000 standards. This recommendation is IN PROGRESS. We are gearing up for ISO9000, ISO14000 and OHSAS17000 certification. recommendation will be automatically complied with. This
Whilst there has been some progress, there are still areas for improvement. A new recommendation, 12-03, on this topic has been made and this recommendation is WITHDRAWN.
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09-06
Operator Emergency Training
Category Recommendation 1. 2. 3.
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. 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. In emergency situations, operators and supervisors are under increased stress and the potential for mistakes increases. Training will reduce the potential for error.
Reason
1. 2. 3.
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. Whilst emergency procedures have been revised and emergency shutdown training (classroom based) takes place, it does not follow the practices outlined above. The recommendation is considered to IN PROGRESS. This is an on-going process and being done from time to time. The recommendation is still not fully implemented, it was discussed in detail with the Olefin plant management and implementation is anticipated in the future. The recommendation is IN PROGRESS.
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ARM Survey 2008

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. Suitable testing kit has been purchased. Testing frequency is once every six months. No further DGA analysis has been undertaken and the recommendation is considered to be UNCHANGED. Some limited new analysis has been performed but DGA is still not undertaken on a regular basis. The situation is UNCHANGED, We do not have any gas in transformer. months is established now. Oil quality checking procedure every six
Reason
Status June 2009
CTt Comment Status May 2011
EPCL Post Survey Comment 2011 CTt Comment
It is not clear that the recommendation has been understood. DGA (Dissolved Gas Analysis) is a well-established technique to check for dissolved gas in transformers. Dissolved gases would be present as a consequence of a breakdown of the transformer oil and are indicative of impending failure. An introduction to DGA can be found at: http://www.electricity-today.com/et/issue0203/i02_analysis.htm EPCL have purchased equipment for use on site. However the results of analysis do not appear credible and samples are being sent off site for analysis in a specialist laboratory. The recommendation is IN PROGRESS.
Status October 2012
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CTC 2006 Recommendations

06-01 Fire Detection/Protection Impairment System
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. 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. 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. EPCL State that: With the revamp of the fire detection and protection system in PE the system now exist in all plants. Some defects were noticed in many of the plants, this recommendation is considered to be IN PROGRESS. The diesel fire pump and catalyst systems are now reported to be operational. The other aspects are also covered in 09-02. This recommendation was considered complete. For future reference, details of an impairment system are available from Liberty Mutual via the internet. A copy is attached in Appendix B. Parts of the sprinkler system in the Polyethylene plant warehouse were isolated. These systems were not clearly marked and did not appear to be known to fire fighters. In effect there has been no progress on this recommendation and the status is UNCHANGED.
Reason
Examples
Status June 2009
Status October 2012
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06-03
Under Insulation Corrosion
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. There is considerable inspection activity related to under insulation corrosion. This recommendation is considered to be IN PROGRESS. This is an on-going process and is IN PROGRESS. Action is initiated. The requirements of this recommendation are also covered in recommendation 11-08 and this recommendation is WITHDRAWN.
Reason
Examples
Status June 2009
CTt Comment Status May 2011 EPCL Post Survey Comment 2011 Status October 2012
06-10
Management of Change
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. 2. Update the procedure to include changes to staffing levels and job functions. Further information is given in Appendix D and a sample method of is given in: http://213.212.77.20/research/crr_pdf/2001/crr01348.pdf 1. The lack of clear criteria to determine if detailed assessment is necessary could result in hazardous changes being approved without adequate assessment. 2. 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. 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. Some aspects of the MOC procedure recommendation is IN PROGRESS. still require improvement and this
Reason
Examples Status June 2009 CTt Comment Status May 2011 EPCL Post Survey Comment 2011 Status October 2012
There appears to be NO CHANGE since the 2009 survey. This is a well-established procedure but there is scope for improvement and is being done. This is reported to be COMPLETE.
36
06-11
Emergency Plan
Category
Recommendation
3 Review the existing Emergency plan to provide a greater level of detail in areas such as: 1. The provision of an adequately equipped emergency coordination centre in a safe and accessible location. 2. Review the format of the plan to see if it can be restructured for improved clarity. 3. 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. 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. 2. 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. 3. 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. Site emergency plan. EPCL State that: SOP for emergency procedures existing. completed and available on the Intranet. On Site Emergency Management Plan
Reason
Examples Status June 2009
Some aspects, such as pre-planning are still not complete. The recommendation is considered to be IN PROGRESS. There has been an element of pre-planning but further progress is possible, including the provision of thermal radiation modelling to allow position of fire trucks to be fixed and the nearest fire hydrants identified. The recommendation is IN PROGRESS. Being reviewed from time to time.
Some preplans have been developed but these are generic and not specific to each plant area or storage vessel. The recommendation is IN PROGRESS.
37
Recommendations Prior to 2005

June2009 Status (EPCL Comments)
COMPLETED Note that site visits indicated that the rod hanger has still not been replaced.
No.
03.03
Title
Liquid Ethylene Storage Tank
Summary
Various repairs to the ethylene tank.
Status in 2006
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.
May 2011 Status

Some repairs to the ethylene tank remain. The recommendation is IN PROGRESS.
October 2012 Status
A technical review of the rod hanger has been undertaken and the hanger found to unnecessary. EPCL Post Survey be the Comment 2011 - We However, are reviewing the analysis might not have considered the engineering fact that the hanger is company. supporting the bellows (which shows signs of distortion) and not a section of pipe. It would be prudent to repeat the analysis including the bellows. The recommendation is IN PROGRESS
Piping Support with Rod Hanger Missing the situation since at least 2003
38
No.
03.04
Title
Use of Cellular Telephone s within the Process Plant
Summary
Use of mobile phones within process plant.
Status in 2006
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.
May 2011 Status

Examples of mobile phone use in hydrocarbon areas were found during the survey. It appears that mobile phones are a common form of communication at the site. There is NO CHANGE to the previous situation. EPCL Post Survey Comment 2011 Theoretically in normal running plants cellular telephones do not pose any hazard. CTC Comment There is no consensus over the hazards posed by mobile phones but many companies prohibit their use in electrically classified areas.
October 2012 Status

The situation is unchanged from 2011, senior management were noted using cellular phones The practice is different from most hydrocarbon facilities where the use of mobile phones is forbidden and phones are often not allowed in the hydrocarbon facilities. The situation is UNCHANGED
98.01
Remote Operated Isolation Valves
Install Remotely Operated valves for process isolation in emergency situations
IN PROGRESS
Out of 4 additional ROVs identified for installation 2 are already installed and 2 are procured waiting shutdown for installation
All 4 of the originally proposed ROVs are now installed However, there are still a number of locations where there are vessels with large inventories and no ROVs installed. Common criteria are: 5 m3 for LPG containing vessels 10 m3 for liquid hydrocarbons The recommendation is IN PROGRESS. EPCL Post Survey Comment 2011 Already installed in two places, further under review The level of fire water use is such that one of the main electric pumps is running continuously. There is a project to install larger jockey pumps. The recommendation is IN PROGRESS. EPCL Post Survey Comment 2011 - We are planning to install a bigger jockey pump to take care of uncontrolled leakage.
There are still locations where ROVs should be installed and, it would useful to establish a list of locations so that valves can be installed at the forthcoming TAM in The situation is UNCHANGED.2013.
98.03
Fire-water Pumps
Stop unauthorized use of fire water.
NO CHANGE
The new larger jockey pump has been installed but is not yet fully commissioned. Hence the main electric pump is still operating. The recommendation IS IN PROGRESS.
39
No.
96.13
Title
Halon System Status
Summary
Replace halon with FM 200
Status in 2006
NO CHANGE

Preliminary work and technical discussion is in progress. Would be implemented in phased manner from 2010.
May 2011 Status
October 2012 Status
A programme for Changeout of the replacement of the halon systems is Halon systems is underway but not underway. complete. The The recommendation recommendation is IN PROGRESS. is IN PROGRESS. EPCL Post Survey Comment 2011 - Job is in progress

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18

3. Recommendations for Risk Improvement

12-01 Category Recommendation Priority

New Projects Risk Engineering Review CAPEX Procedural

12-02 Category Recommendation Priority

New Projects Consequence Modelling CAPEX Procedural

12-03 Category Recommendation Priority

Controlled Documents CAPEX Procedural

12-04 Category Recommendation Priority

Permit to Work System Filing CAPEX Procedural

12-05 Category Recommendation Priority

Database of Recommendations CAPEX Procedural

12-06 Category Recommendation

Ethylene Storage Tank Area - Housekeeping Priority CAPEX Procedural

12-07 Category Recommendation

Gas Detection Systems for Occupied buildings Priority CAPEX Procedural

12-08 Category Recommendation Priority

Inspection of Fire Protection Equipment CAPEX Procedural

12-09 Category Recommendation Reason Examples Priority

Testing of fire fighting Foam CAPEX Procedural

3.2. Previous Recommendations

EPCL Post Survey Comment 2011 Status October 2012

Internal combustion driven concrete mixer close to process area in PE plant

Examples EPCL Post Survey Comment 2011 Status October 2012

EPCL Post Survey Comment 2011

Status October 2012

Trip Bypass Procedure

EPCL Post Survey Comment 2011 Status October 2012

EPCL Post Survey Comment 2011

CTt Comment Status October 2012

Category Recommendation Reason

EPCL Post Survey Comment 2011 Status October 2012

Risk Based Inspection

Category Recommendation Reason

Examples EPCL Post Survey Comment 2011 CTt Comment

Status October 2012

Corrosion Under Insulation

EPCL Post Survey Comment 2011 CTt Comment

Status October 2012

Refrigerated ethylene tank pipework with corroded insulation

Vegetation growing in process piping

Category Recommendation Reason

Damaged fireproofing in the process area

Damaged fireproofing in the process area

Examples EPCL Post Survey Comment 2009 Status May 2011

EPCL Post Survey Comment 2011 Status October 2012

Fire and Gas Alarm Systems

Category Recommendation Reason

EPCL Post Survey Comment 2009 EPCL Status May 2011

EPCL Post Survey Comment 2011 Status October 2012

Control Room Doors

Category Recommendation Reason

Examples EPCL Post Survey Comment 2009 Status May 2011

EPCL Post Survey Comment 2011 Status October 2012

Operator Emergency Training

Examples EPCL Post Survey Comment 2009 Status May 2011

EPCL Post Survey Comment 2011 Status October 2012

ARM Survey 2008

Status June 2009

CTt Comment Status May 2011

EPCL Post Survey Comment 2011 CTt Comment

Status October 2012

CTC 2006 Recommendations

2012 Rec's

2012 Rec's