466129 epcl port harcourt draft.pdf

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Insurance Risk Survey of Eleme Petrochemical CompanyLimited (EPCL), Port Harcourt, Nigeria

22nd to 24th October 2012

88 Leadenhall Street, London, EC3A 3BATel +44 (0)20 7623 1819Fax +44 (0)20 7623 1817

www.cttechnical.com

Charles Taylor Adjusting Limited is an appointedrepresentative of Charles Taylor plc which isauthorised and regulated by the Financial Services Authority

Registered Office: Standard House, 12-13 Essex Street,London WC2R 3AA Registered in England No. 1994696

A Charles Taylor company

Revision Date Comments

6 October 2012 Resurvey

5 May 2011 Resurvey

4 June 2009 Resurvey

3 December 2006 Revised to include new values and lossestimates

2 November 2006 Updated to include client comments

1 October 2006 Previous survey in March 2005 when thesite was owned by NNPC

http://www.cttechnical.com/





Disclaimer

This report has been prepared solely for the useof Eleme Petrochemical Company Limited

(EPCL) and Eleme Petrochemical Company

Limited (EPCL)’s insurance brokers and

underwriters. Neither Charles Taylor nor itsindividual representatives shall in any

circumstances be responsible to any otherperson for any loss or damage or liability

however caused arising from the use of hisreport or the information it contains.

Charles Taylor Adjusting’s Standard Terms and

Conditions can be found at:

http://www.charlestayloradj.com/pdfs/TermsAnd

Conditions.pdf

Report for

United Insurance Brokers,Mansell Court,

69 Mansell Street,London,

E1 8AN

Main Contributors

Doug Scott

Issued by

Doug Scott BTech CEng CSci FIChemE MEI

Reviewed by

Roger Barrett BEng CEng FIChemE

Approved by

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

Charles Taylor

88 Leadenhall StreetLondonEC3A 3BP

UKTel: +44 (0) 20 7623 1819Fax: +44 (0) 20 7623 1817

Insurance Risk Survey ofEleme Petrochemical

Company Limited(EPCL), Port Harcourt,

Nigeria

22nd to 24th October 2012

Draft

Charles Taylor plc

http://www.charlestayloradj.com/pdfs/TermsAndConditions.pdf







3

466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR

Executive Summary

Introduction

Charles Taylor Technical (CTT) has been commissioned by United Insurance Brokers toproduce an underwriting survey report for insurance purposes of Eleme Petrochemical

Company Limited (EPCL), Port Harcourt, Nigeria. Information was obtained during meetings

with key staff, a site visit and from a previous survey report.

The survey concentrated on property damage, machinery breakdown and businessinterruption at the plant.

Overview of Risk

Significant Changes since the Last Survey

There have been no major changes since the 2011 survey but steady progress hasbeen made in a number of areas, including updating of the operating procedures and

developing process safety awareness. The site is fully operational but there are

limitations on feedstock supply.

The site now has certification for ISO 9001, ISO 14001 and OSHAS 18001. Early in2012 EPCL achieved 5 stars under the British Safety Council safety rating scheme and

have also been awarded a "Sword of Honour".

There are major construction projects (new ammonia urea plant, plus an expansion ofthe olefin unit and new HDPE unit) planned for the site with construction expected to

start in 2013. This will change the nature of risk at the site in the short term, whilstconstruction takes place, and in the longer term when toxic hazards will be present as

well as the existing fire and explosion hazards.

The Site

Eleme Petrochemical Company Limited (EPCL) was originally a subsidiary of theNigerian National Petroleum Organization Corporation (NNPC) but was sold to

Indorama in May 2006. EPCL operates an olefins plant and downstream units, whichare mostly polymer plants, at Port Harcourt, Nigeria. The facilities date from the mid-

1990s. The site suffered from underfunding for many years but since Indorama tookover the site, there has been major investment in the existing facilities and a high level

of equipment reliability is being achieved.

Natural hazards in the area are modest.

The site is built on a large plot with considerable room for expansion and in addition to

the process, storage and utility systems, also houses the ex-pat workforce andfamilies.

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 withinsome of the process facilities. The level of loss prevention features varies between

process units. The number of remote isolation valves on large process inventories in

the ethylene plant has been increased but additional valves may be required.

Storage facilities are generally to modern standards. Some, but not all, of the tanks

have been refurbished since Indorama took over the site.



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There is adequate space on site for the new units, which were envisaged when the plotlayout of the site was originally developed.

Administ rat ion

Prior to the sale of EPCL to Indorama, NNPC maintained an unusually tight controlover finances. This resulted in serious underfunding, particularly of the maintenance

budget and no major overhaul of the site was undertaken between 1996 and 2006.

The site organization generally follows accepted practice, with a direct reporting routefrom 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 presentwhen NNPC ran the site but appear adequate. 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. There is a trend to replacing ex-pats in more junior positionswith Nigerian nationals, where possible.

There has been considerable revision of operating and maintenance procedures since

the 2011 survey but still some areas where improvements can be made.

Activities in most areas follow accepted industry practice but are, sometimes, at an

early stage. In many cases, these have only been developed in the last five years. A

CMMS (Computerised Maintenance Management System) is now in place. A furtherturnaround is anticipated during early 2013.

The inspection department has been very active and has now collected data for most

equipment, although there is still significant inspection for under insulation corrosion tobe undertaken. Although most piping and equipment has been inspected, there is not,

currently, enough information to allow trending but this situation should change in the

near future as additional readings are undertaken.

There are well resourced safety and firefighting teams at the site and a very high level

of security. Increased attention to process safety activities is now apparent at the site.

A high level of security remains in place with a larger workforce of contract personnelsupplemented by police and military personnel.

Fire ProtectionThe fire detection and protection systems have been overhauled and are largelyoperational. However some obsolete systems are in place, including a number of

halon systems. One of the electrical fire pumps is in continuous operation to supplywater for wash down – a situation unchanged from the 2011 survey - but a new, larger,

jockey pump is currently being installed. Fixed protection systems generally appear ingood condition and the fire trucks are reported to be in good condition.

In summary, the site has improved considerably since it was acquired from NNPC but stillhas a few legacy issues. Procedures are continually improving, a high level of availability is

now achieved and there is an increasing level of process safety awareness.



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Insured Values

The current insured values are:

USD million

Process facilities 848.0

Non-process facilities 69.8

Stocks 65.0

Business Interruption (12 months) 300.0

Loss History

Since Indorama took over the site, there have been two claims:

Date Loss AmountUSD

Details Comments

10 Jan 2009 850,000 Limitations of feedstocksupply. This has reducedproduction at the plant and alsocaused an increased cost of workingas a result of increased utility usageper unit of production.

May 2008 - Damage to Olefin Plant cold box.The cause has not been positivelyidentified but is probably due tothermal cracking of the cold boxduring start-ups and shutdownssince the plant was commissioned.

The claim was subsequentlywithdrawn.

Repairs were made and areplacement cold box ordered. This

was installed at the last turnaroundin 2010.

Loss Estimates

Scenario

PropertyDamage

(USDMillion)

BusinessInterruption

(USDMillion)

Combined(USD Millions)

Property Damage Vapour cloud explosion in the olefinplant following a release from the C2splitter reflux drum

435 600 1,035

MachineryBreakdown

Damage to the rotating elements ofthe olefin plant cracked gascompressor

19.0 50.0 69.0

Complete destruction of the olefinplant cracked gas compressor

32.7 450 458.4

Note that underwriters exposure will be limited to USD 300 million (the policy limit with a 12 month indemnityperiod) for business interruption losses.



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Recommendations for Risk Improvement

A total of nine new recommendations were made as a result of the current survey:

Recommendation Description Category

12-01 New Projects – Risk Engineering Review Priority

12-02 New Projects – Consequence Modelling Priority

12-03 Controlled Documents Procedural

12-04 Permit to Work System – Filing Procedural

12-05 Database of Recommendations Procedural

12-06 Ethylene Storage Tank Area - Housekeeping Procedural

12-07 Gas Detection Systems for Occupied buildings Procedural

12-08 Inspection of Fire Protection Equipment Procedural

12-09 Testing of fire fighting Foam Procedural

The status of the 24 outstanding recommendations from previous surveys is shown below:

The key features of the site have been assessed using CTT’s Key Risk Rating IndicatorSystem (KRRIS) for the Oil, Gas and Petrochemical Industry to determine the key risk

features. For each of the key indicators (Hardware, Software and Protections), a number ofindividual 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 representedgraphically (ranging from red for poor, to bright green for good). The results are shown

below.

Completed, 6,25%

Unchanged, 5,21%

In Progress, 11,46%

Withdrawn, 2,8% Unknown, 0, 0%



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Overall Presentation Sheet

Natur al Perils 3.5 Management 3.5 Fire and Gas Detecti on 2.8

7 Parameters 0 0 1 1 5 5 Parameters 0 0 0 2 2 2 Parameters 0 0 0 2 0

Exter nal Exposu res 2.8 2.8 Water Supplies 3.0


Inherent Hazard 1.0 Permit to Work System 2.6 Drainage 2.5


Layout 2.8 2.3 Process Are a Fire

2.1


Control Systems 2.0 2.0 Offsites Fire Protection 1.5


Process Safety Systems 2.3 2.3 2.0


Loading/ Unloading N/A Inspection Procedures 3.0Passive

Protection 1.8


Storage 1.8 3.0Foam

Supplies N/A


Utilities 2.2Emer gency

Response 2.8 Portable Equipm ent 3.3


Machinery 2.0 Security 3.0 1.4


Safety Procedures and

Practices

Management of

Change

Utility Area Fire

Protection

Engineer ing/

Technical Services

Operating procedures have been revised but

furt her improvements are possible.

Fire water syst em appears in good condition,.

There is still a problem with use of fire w ater

forwashdown, etc.

Systems examined wer e generally in good

condition, w ith the exception of the a foam

system for the ethylene storage area.

The facilite process large quanties of v olatile

hydrocarbon materials.

Permit sys tem is operating satisf actoaly but some

minor improvements are possible.

A LOTO system ahs now been implemented.

Vegitation has been cleared from the drains

since the last survey.

Maintenance

Natural perils at the site are limited. All senior management positions occupied by ex-

pats.

Fire detection systems have been repaired The

system is reported to be operational, although

there are a large number of fault alarms..

Protections

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 c onsulted

Operating Procedures

Hardware Software

Minor exposure from other facilities.

Note that furture construction projects c ouls

impat the operating procedures.

Layout between units is generally spacious.

There are some congested areas w ithin the units

A considerable amount of mainteance work has

taken place since the take over by Indorama. The

condition and reliability of the equipment is much

improved. A vailability is now approac hing 100%

An ORICLE based CMMS is now in use.

Fire fighting systems are operational.

DCS systems have been upgraded

Although control rooms are blastproofed, the

doors are fr equently left in the open position.

The engineering function is reported to be

adequately staff ed and resourced.

The management of c hange is capable of

improvement.

Systems appear to be in good condition

Most porducts are transported by truck in a non

haardous form. A new road tanker unloading

fac ility has been built with basic fac ilities.Pipeline

systems w ere not reviewed in detail during the

survey

Inspection Procedures are to a generally good

standard with a w ell trained and enthusiastic

w orkforce.

The site is moving is considering a move to Risk

Based Inspection but does not have enough data

to trend corrosion rates.

Level of passive protection varies betw een

different process units.

Much of the machinery has been overhauled

since Indorama took over the site. 1 gas turbine

has been overhauled and plans are in place to

overhaul the others.B22

A high level of security is in place at the site. Testing of gas gestion systems follows normal

practice.

However testing of the fire w ater pumps is not

fully in line with NFPA standards.

Some of the storage facilities have been

refurbished.

Safety pr ocedures are generally to a high

stadard. There is increased awareness and

implementation of process safety procedures.

There are significant stocks of foam. It is not

clear if the foam is regularly inspected.

The site is largely self suf ficent in utilities.

A major power f ailure occurred in earlier in 2012,

resulting in a total plant shutdow n.

The emergency response capability appears

adequate and some, basic, pre-planning has

been done.

Fixed fire f ighting equipment is on good condition

Testing/Inspection

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Printer Friendly Versi

© 2008 Charles Taylor technical



8


Contents

1. Introduction 11

1.1. The Survey 11

1.2. The Company 12

1.3. The Location 13

1.3.1. Meteorological Information 14

2. Background 16

2.1. Insured Values 16

2.1.1.

Property Values 16

2.1.2.

Business Interruption 17

2.2.

Loss History 17

3. Recommendations for Risk Improvement 18

3.1. New Recommendations 18

3.2. Previous Recommendations 22

4.

Exposure to Perils 40

4.1. Property 40

4.1.1.

Fire and Explosion 40

4.1.2. Surrounding Exposures 40

4.1.3. Subsidence and Collapse 41

4.1.4.

Earthquake 41

4.1.5.

Tsunami 41

4.1.6.

Volcano 41

4.1.7. Lightning 42

4.1.8. Wind and Storm 42

4.1.9. Flood 43

4.1.10. Vehicle Impact 43

4.1.11.

Vessel Impact 43 4.1.12. Aircraft Impact 43

4.1.13.

Riot Strike and Civil Commotion 44

4.1.14.

Terrorism and Sabotage 45

4.2.

Machinery Breakdown 45

4.3. Construction 45

4.4. Business Interruption 46



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5. Loss Estimates 47

5.1.

Defini tions and Loss Scenarios 47

5.2.

Property Damage 47

5.3. Property Damage Business Interruption 49

5.4. Machinery Breakdown 50

5.5. Machinery Breakdown Business Interruption 50

5.6. Summary of Loss Estimates 51

6. Description of Installation 52

6.1. Production Facilit ies 52

6.1.1. Process Units 53

6.1.2.

New Projects 55 6.1.3. Process Hazards 55

6.1.4. Layout 58

6.2. Control and Process Safety Systems 61

6.2.1. Basis 61

6.2.2. Control Room Design 61

6.2.3. Emergency Shutdown Systems 62

6.2.4.

Remote Isolation, Depressurisation and Blowdown 62

6.2.5.

Pressure Relief Systems 62

6.2.6.

Combustion Safeguards 63

6.2.7. Shaft Sealing 63

6.3. Feedstock Supply and Product Transfer 63

6.3.1.

Road 63

6.3.2. Pipeline 63

6.4. Storage Facilit ies 63

6.4.1.

Atmospheric Storage 64

6.4.2. Pressurised Storage 65

6.4.3. Refrigerated Storage 69

6.4.4. Warehousing 72

6.5. Utilities 72

6.5.1. Water 73

6.5.2.

Fuel Gas/Fuel Oil 74

6.5.3. Steam 74

6.5.4. Electricity 75

6.5.5.

Hot Oil 77

6.5.6.

Air 77

6.5.7.

Nitrogen 78

6.5.8.

Flare 78

6.5.9. Effluent Treatment 78

6.5.10. Incineration 79

6.6. Major Equipment Items 79



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7. Administration 81

7.1.

Organisation 81

7.2.

Operations 82

7.2.1.

Process Operations 82

7.2.2.

Control of Maintenance 85

7.3.

Maintenance 87

7.3.1.

Turn Around Maintenance (TAM) 87

7.4.

Engineering 93

7.4.1.

Management 93

7.4.2.

Management of Change 95

7.4.3.

Hazard Studies 95

7.5.

Inspection 96

7.6.

Safety, Health and Environment 102

7.7. Emergency Response 106

7.8. Security 107

8.

Fire Protection 110

8.1. Fire and Gas Detection 110

8.2. Fire Water System 111

8.3. Acti ve Systems 113

8.4. Passive Systems 115

8.5.

Mobile Equipment 117

8.5.1.

Fire Trucks 117

8.5.2.

Foam and Dry Powder Stocks 118

Appendix A List of Acronyms Appendix B Information on Impairment Systems Appendix C Management of Change Checklist Appendix D Organizational Change Guidance Appendix E Sample Fire Fighting Pre-plan Appendix F Plotplan Appendix G Permit to Work Forms



11


1. Introduction

1.1. The Survey

Charles Taylor Technical (CTT) has been commissioned by United Insurance Brokers to

produce an underwriting survey report, for insurance purposes, of Eleme PetrochemicalCompany Limited (EPCL), Port Harcourt, Nigeria.

The survey concentrated on property damage, machinery breakdown and business

interruption

The following personnel were involved in the survey their assistance is acknowledged with

appreciation.

Leadway Insurance

Ojo Olatunde Risk Surveyor

Dover Engineering

Kesiena Atirene Risk Survey Engineer

Eleme Petrochemicals Co Ltd.

B.K. Shavastava Technical Director

M. Bhosale Technical Director's office

S.C. Sarkar

E. Ikpuku

S. Ichin Olefins Plant Manager

D. Mital Olefins Plant

S. Bhaliachaiyay Olefins Plant

A.B. Rao Polymer Plants Manager

Nwakaji Ekaa Polypropylene Plant

S.K. Dave Polypropylene Plant

Anil Gupta Power & Utilities Manager

S.B. Sagdeo Engineer

Phool Sugh Engineer

B. Mangalmurit Engineer

Enyinda Sylvester CES Workshop

Chintamani P. Mechanical Engineer

Linaye Mechanical Engineer

Jaja B. Mechanical Engineer

Mohan Putta Mechanical Engineer

Phool Singh Rotating Machinery Engineer

Nwajiobi Collinns Electrical Engineer

A.K. Bharucha Electrical EngineerPorkay Bhall Electrical Engineer



12


S. Dineshkumar Instrument Engineer

S.B. Sagdeo Instrument Engineer

Ansari Siraje Alam

B. Phamanage Technical Services Department

Bareen Phamarage Technical Services Department

Eniafe Babajide Technical Services Department

Ezemwugo Patricia Technical Services Department

Ezugu Benneth Technical Services Department

Nwawosike A. Joy Technical Services Department

Olumoye O.R. Technical Services Department

Angus O. Inspection Engineer

Anyanwu C.O. Inspection Engineer

Jerome F. Inspection Engineer

Onyejiaku Angus Inspection Engineer

K.P. Pandey HSE Manager

Felix Okosun Safety Department

Saloka James Environment Department

B.T. West Fire Chief

Aluh Pareto Security Manager

And others

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 forrisk improvement contained in the report are advisory and the decision and responsibility for

implementation rests with the site's management.

1.2. The Company

Eleme Petrochemical Company Limited (EPCL) was originally part of Nigerian National

Petroleum Corporation (NNPC) which is wholly owned by the Nigerian Government.

In May 2006, EPCL was sold to Indorama, a multinational company based in Indonesia withinterests ranging from petrochemicals, textiles and cement. The timeframe for the takeover

is shown below:



13


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 hasreduced 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 operatingprocedures.

The senior management members at the site have all arrived since privatisation and aremostly 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 ofreplacing Indian staff with Nigerian nationals.

Further details of Indorama are available from the company’s website:

http://www.indorama.com/

1.3. The Location

Eleme Petrochemicals Company Limited (EPCL) operates a single petrochemicals site atPort Harcourt in the River Province of Nigeria. It consists of an ethylene cracker,

polyethylene, polypropylene and butene-1 plants, together with associated utilities, storageand infrastructure. The plant was commissioned in 1996 and had been operating

continuously since then, without a major shutdown for maintenance (Turn AroundMaintenance or TAM), until 2006 when the management of EPCL was taken over by

Indorama.

Due to the lack of maintenance and feedstock limitations, the process units had seldomperformed at anything like full capacity and were frequently shutdown. Since the takeover

by Indorama, there has been significant capital investment and a number of shutdowns forsite wide maintenance and refurbishment.

The plant is located near the town of Eleme, approximately 15 minutes’ drive from Port

Harcourt, the capital of Rivers State. The site is elevated 15m to 18m above the level of theBonny River, which runs 5km from the site, and there is no history of flooding in the area.





14


1.3.1. Meteorological Information

Meteorological conditions in Port Harcourt are shown below:

Brief details of the meteorological conditions, when known are given below

Topology The area is flat and no terracing is necessary.

Lightning There are around 140 lightning days per year and lightning strikes have affected the site.

Temperature Maximum temperatures are approximately 32°C to 33°C, with minimum temperatures ofapproximately 20°C to 22°C.

Humidity Humidity is typically in the region of 90%.

Rain Rainfall is approximately 3,000 mm per year, with the rainy season lasting from March toNovember.

Wind and Storm Prevailing wind from the Northeast in the dry season and Southwest in the wet season.

Further information is given below:

Month Average

Temperature

Temperature

AverageDew Point

(C)

RelativeHumidity

Average No. ofDays w ith

Precipitation

Average Record

Min Max Min Max am pm

Jan 27 26 28 15 37 21 93 57 1

Feb 28 27 29 13 37 22 93 61 2

March 27 27 28 21 39 - - 68 2

April 27 26 28 20 36 23 - - 4

May 27 26 28 21 37 23 96 73 5 June 26 26 27 18 37 23 96 78 8



15


Month

Average

Temperature

Temperature

AverageDew Point

(C)

RelativeHumidity

Average No. ofDays w ith

Precipitation

Average Record

Min Max Min Max am pm

July 25 24 26 16 41 22 96 79 11

Aug 25 24 26 20 32 22 97 81 13

Sept 25 24 26 21 37 23 98 - 9

Oct 25 25 26 21 36 23 97 76 8

Nov 26 25 27 18 37 22 96 69 3

Dec 26 25 27 17 37 21 93 61 1

Source: http://www.weatherbase.com

http://www.weatherbase.com/






16


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

USD 868 million. A revaluation by AVC was undertaken in 2011 but the available valuationdata provided is from the 2006 valuation and the breakdown of the current insured values

are given below:

Unit USD

Ethylene Cracker 284,800,000

Polyethylene 181,700,000

Butene-1 10,500,000

Polypropylene 80,100,000

Polypropylene Bagging 24,200,000


Storage Area (Including Pipeline toRefinery)

57,600,000

Power Station 109,300,000

Cooling Water 23,100,000

Demineralised Water 33,400,000

Air and Nitrogen 22,900,000

Flare Area 9,400,000

Effluent Treatment (Including Incinerator) 16,800,000

Administration and General Excluded

Refinery Tank Farm 3,700,000

Total 868,000,000

These values are now six years old and a revaluation would be prudent.

The following non process property has been notified:

USD

Laboratory 16,400,000

Plastic Technology Centre 13,950,000

Administrative Department 8,020,000

Main Workshop 7,970,000

Main Warehouse 6,640,000



17


USD

Technical Building 5,610,000

Canteen 3,990,000Medical Centre 1,800,000

Training Centre 1,640,000

Fire Station 1,260,000

Auditorium 730,000

Laundry 620,000

Lorry Divers Facility 580,000

Sub Station 590,000

Total 69,800,000

The insured value of stocks is: USD 65 million.

2.1.2. Business Interruption

The business interruption sum for the 2011/12 policy period is USD 300 million with a 12

month indemnity period.

A major Vapour Cloud Explosion (VCE) may result in rebuilding times well in excess of 12months (24 months is commonly assumed) and therefore underwriters’ exposure is likely to

be considerably less than the full business interruption figure.

2.2. Loss HistoryBrief details of loss history are given in the table below:

Date Loss AmountUSD

Details Comments

10 Jan 2009 850,000 Limitations of feedstocksupply. This has reducedproduction at the plant and alsocaused an increased cost of workingas a result of increased utility usageper unit of production.

May 2008 - Damage to Olefin Plant cold box.The cause has not been positivelyidentified but is probably due tothermal cracking of the cold boxduring start-ups and shutdownssince the plant was commissioned.

The claim was subsequentlywithdrawn.

Repairs were made and areplacement cold box ordered. Thishas now arrived on site and wasinstalled at the last turnaround in2010.



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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 requiredfor 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 New Projects – Risk Engineering Review

Category Priority CAPEX Procedural

Recommendation Undertake a risk engineering review of the proposed new units. This willinvolve 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 staffinglevels and maintenance regimes that will exist once the units arecomplete.

The study is probably best conducted at the project contractor’s offices at apoint in time where the findings can be incorporated in the final scope of work.

Reason A risk engineering review will ensure that appropriate process safety featuresare built into the new units. This, in turn, will result in a greater potential forthe incidents to be more easily prevented or controlled.

Examples Ammonia, Urea and Ethylene plant upgrade projects.



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12-02 New Projects – Consequence Modell ing


Recommendation Perform a study using consequence modelling to determine the effects of anincident in one part of the site on other locations. The study should coverareas outside the process facilities, including: storage, utilities, offices,accommodation areas and residential areas outside the site boundary. Thestudy 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 operationalstages.

The results of the study would provide input into the detailed design andlayout of the facilities (including the requirement for safe havens in the eventof a major ammonia escape) and emergency planning.

Reason The new plants being constructed, plus planned expansion to the originalfacilities, will change the overall hazard profile at the site. Theinterrelationship of the hazards needs to be considered in detail, especially asthere are now a significant number of people resident at the site – somethingnot envisaged at the design stage.

Examples Planned construction projects at the site, particularly the ammonia and ureaplants.

12-03 Controlled Documents


Recommendation Develop a consistent procedure covering all parts of the site.

The procedure should cover the format of documents (including the recordingof revision numbers and dates of changes).

There should also be a consistent approach to the storage and filing of mastercopies of documents and a register of holders for controlled documents.

Reason Unless there is a consistent approach to document control, there is a potentialfor confusion between the status of documents at different parts of the site.

Examples There are different approaches to controlling documentation at the olefins andpolymer units. Within the Olefins plant, there is a "controlled" copy with a redstamp on each page. If photocopied the red stamp will appear as black and itwill be clear that the document may not be up to date.

Within the polymer units "original copies" are available which have nodistinguishing stamps.



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12-04 Permit to Work System – Filing


Recommendation Revise the permit procedure to ensure that permits are filed for more than aweek. The following points should be considered:

• If all copies of the permits are collected together and "signed back", therecan be no confusion regarding the status of work – which could occur if aloose 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 thenormal auditing frequency) is not necessary it is common to file permitsfor a two year period.

Reason The current practice of filing a single copy of each permit for only a weekgives limited opportunity for auditing.

Examples Files of permits in all units.

12-05 Database of Recommendations


Recommendation Develop a central database of recommendations from accident investigations,safety audits and other sources.

The database should be checked and reviewed regularly to ensure thatrecommendations are being progressed towards an end point forimplementation.

Ideally, the database should nominate a responsible individual for eachrecommendation, with a timeframe for implementation and automatic flaggingof overdue actions.

Reason Unless a comprehensive set of recommendations is available together with arobust programme for implementation, there is a danger that manyrecommendations will not be completed.

In addition a backlog of incomplete recommendations is likely to have anegative effect on the safety culture of the site.

Examples EPCL operated several databases for recommendations from differentsources.



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12-06 Ethylene Storage Tank Area - Housekeeping


Recommendation Clear vegetation from the dike area and make sure that the area, including theimpounding basin is in good condition.

Confirm that the foam system for the impounding basin is in good condition(both the equipment and the foam).

Reason 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 theimpounding basin. This could limit the capacity of the tank for ethylene spillsand the water would provide a source of heat to assist vaporization ofethylene. In addition. tree roots might cause damage, to the basin anddamage it’s integrity.

The integrity of the foam system is unknown and may not be functional.

Examples Ethylene storage tank area.

12-07 Gas Detection Systems for Occupied build ings


Recommendation Review the gas detection systems associated with HVAC systems.

If the detectors are located within the air ducting, consider relocating them toa location near to the inlet of the HVAC system.

Reason EPCL has pellistor type gas detectors rather than alternative infra-red type.

The principle of operation of pellistor type detectors is to measure thetemperature rise when flammable gas is combusted on a catalyst pellet. Ifdetectors are installed in a moving air stream, there will be a cooling effectwhich will counter the heat rise, possibly leading to false readings.

Examples Olefin plant control room.

12-08 Inspection of Fire Protection Equipment


Recommendation Ensure that regular inspections of ALL fire fighting equipment are made andrecorded. Ideally there should be random spot checks by management toensure that inspections are being correctly undertaken.

This recommendation should be read in conjunction with recommendation 06-01.

Reason Unless regularly inspected, it is difficult to ensure that equipment is in thecorrect location and in good condition.

Examples Whilst almost all extinguishers had inspection tags, the frequency ofinspection varied from one location to another.

In addition, some sprinkler systems in the Polyethylene warehouse had beenisolated.



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12-09 Testing of fire fight ing Foam


Recommendation Conduct regular checks on the stocks of fire fighting foam at the site. Foamwhich is not in good condition should be replaced.

Reason Defective fire fighting foam will perform effectively either in a fire fighting roleor as a sealant for liquefied gas spillages.

Examples 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 ownedand operated by NNPC. During these surveys numerous recommendations were made and,

during NNPC’s ownership, there was little improvement. The recommendations below werethose 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 (Simul taneous Operations)

Category 3

Recommendation Develop a procedure to control simultaneous construction and operation within thesame 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 safetyundertaken 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 Reason Construction and commissioning activities can lead to hazardous situations, which,

without careful control and communication, can result in hazardous situationsoccurring.

Examples The main value of the SIMOPS procedure will be in the future when construction of theLDPE, methanol and ammonia/urea plants takes place.

There are some areas within the existing facilities where SIMOPS is currentlyapplicable, 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. Thisappeared to be close to or within an electrically classified area with no evidence of ahot work permit.

EPCL Post SurveyComment 2011

Procedure is under development, implementation by September 2011.

Status October

2012

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 thatthis recommendation is completed without delay.

http://www.onepetro.org/mslib/servlet/onepetropreview?id=IPTC-13705-MS&soc=IPTC





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11-02 Wafer Valves

Category 2

Recommendation Identify any wafer (long bolted) valves on hydrocarbon lines in the process units andstorage areas.

These should either be replaced with standard flanged valves or provided withinsulation and a fire resistant covering.

Reason The longer bolts in wafer type valves have limited thermal inertia and will heat upquickly in a fire. They are also likely to suffer from direct flame impingement if there isa fire in the area. The direct flame contact causes the bolts to expand rapidly andlengthen, allowing both gaskets to leak hydrocarbons which will feed the fire andincrease the level of damage.

Examples 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.

Status October2012

Insulation has been installed to protect the long bolted flanges, an example was shownbelow.

The recommendation is COMPLETE.

Internal combustion driven concrete mixerclose to process area in PE plant



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11-03 Control of Maintenance

Category 3

Recommendation Conduct a fundamental review of the existing procedures for the control ofmaintenance to ensure compliance with existing good practice in the hydrocarbonprocessing 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 togetherprior 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 hourswith revalidation at each shift.

• Examination of equipment to be used for each activity to ensure that it is suitablefor its purpose.

• Ensure that all personnel are aware of the activities currently taking place. This isoften achieved with the use of plotplans mounted on a wall in the control roomwith markers showing the location and type of activity. In addition, a copy of thepermit should be available at the job site.

• Permits should be filed for a period of at least three months to allow auditing ofthe system.

•

There should be separate folders for filing permits for completed work and permitsfor 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 systemand a fundamental review is considered desirable to ensure that safe workingprocedures continue to be to a high standard.

As EPCL have an ambitious expansion programme over the next few years, now isconsidered 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 orrisk review prior to work commencing (however standard risk assessments areavailable 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 anelectrically classified area, in the PE plant

o A sandblasting skid with a non "Ex" rated motor in the Olefin plant. Whilstthis may be intended for use during plant shutdowns, it is likely that in somecases it will be used for sandblasting whilst adjacent equipment is inoperation.

• No permits were displayed at jobsites.

• Permits examined in the control rooms showed that permits were kept open overweekends with some permits being open for five days.

• The "sign-off" date by operations supervisors was often a day or two after the lastday of validity of the permit, suggesting a gap between work being completed andchecks at the jobsite.

It should be noted that two of the four fires reported in 2011 were related to the controlof maintenance.

EPCL Post SurveyComment 2011 The existing procedure is effective and well established. However, we are reviewing itfor further improvement based on some of the recommendation. The plot plan withlocation marking showing activities already exist in control room. (Auditor may haveoverlooked.) Most of the suggestions have already been implemented in our system.

Status October2012

This is COMPLETE, an example is shown below:



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11-04 Trip Bypass Procedure

Category 3

Recommendation Review the current trip bypass procedure and, if considered necessary, revise it toensure:

• Trips which are bypassed for an extended period receive a higher level of scrutinythan trips bypassed for a short period of time. This is often achieved by requiringa 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 – 48hours, a Management of Change procedure is followed.

• The bypass procedure should require some form of risk assessment to identifyany additional safety precautions required whilst the bypass is active. Ensure thatprocedure is followed rigorously.

• The trip bypass authorization forms should be filed (with separate files forcompleted 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 asingle piece of equipment can be bypassed simultaneously when the equipment is outof service. However, the disabling and, especially, the establishment of each tripshould be noted individually.

A discussion of trip bypass procedures is given in:

http://www.torusinsurance.com/documents/Best%20Practice%20Centre/Safety_Interlock.pdf

Reason Whilst EPCL currently has a trip bypass procedure as part of the safety manual, thisrequires a separate form to be completed for each bypass. This is consideredimpractical in situations where multiple trips may be bypassed at the same time. Forexample during the decoking of a cracking furnace.

Where procedures are developed but then not used, short cuts and deviations canoccur. It is preferable to have a clear concise, practical procedure which can be usedthroughout the site without the need for modification or misuse in some situations.

Examples During visits to the control rooms no bypass forms were reviewed but each plant had atrip bypass register which appeared to be correctly completed.

In the Olefins plant, the trip bypass register dates from March 2011. There was noevidence of any trips which were previously bypassed being "carried forward" to thenew register. There were a number of cases where bypasses had been in place forweeks. Elsewhere in the register, it was not clear if individual loops had beenestablished or not as a single signature appeared to have been used to confirm thatseveral bypasses had been re-established.


The present system is well established and most suitable based on our requirementand type of work being done. However, we are reviewing it further. Some of thesuggestions have already been taken care.

Status October2012

Trip bypass registers are being prepared for use in the individual unit control rooms butthe implementation of a more advanced trip bypass system has not been investigated.

The situation is UNCHANGED.








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11-05 Flange Systems

Category 3

Recommendation 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 andbolts 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.

Reason Poor bolting and flange practices increase the likelihood of flange leaks and therelease of sufficient hydrocarbon material to generate a fire or explosion. This problemis shown clearly in the schematic below.

A particular concern exists if carbon steel bolts are installed in stainless pipework. Inthe event of low temperatures, for example during blowdown, low temperatures couldbe generated in pipework. Whist stainless materials might be suitable, there could bebrittle fracture of carbon steel studs.

Examples • A thin steel plate was installed as a blind on a virgin C5 line at offsites liquid pumphouse.

• Studs which did not fully penetrate the nuts on either side of the flange werenoted 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 olefinplant cold section.


We have already surveyed short bolting and less bolting. Correction is underprogress. Since some blinds are only for positive isolations, thickness was less for bigdiameter pipes. However, all attempts are to be made to install correct rated blinds intrue isolation cases.

CTt Comment The response is unclear. Where blinds are installed in pressurised systems, theyshould always be rated for the same pressure as the piping system.

Status October2012

No examples of incorrect flanging were noted during the survey. The recommendationis considered COMPLETE.

11-06 Maintenance of Drains

Category 3

Recommendation Ensure that a regular programme of drain cleaning takes place throughout the site.This should be controlled through the maintenance work order system.

Reason Whist the flow through the drains systems is generally low, much higher rate flows mayoccur during heavy rain. If the drains are partially blocked rainwater might flood someareas of the plant resulting in damage.

The drains are also required to cope with fire water flow and if restricted could result ina back-up of water spreading out on the plant with burning hydrocarbons on top. Thearea exposed to fire could be increased significantly.

The drains are also required to transfer spillages of hydrocarbons to a safe locationand if blocked or restricted could result in a pool of liquid which could result in a fire.

Examples • 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 earthand vegetation.


We will enhance the drain cleaning frequency; this is an on-going process.

Status October2012

In general, drains were clean and the recommendation is COMPLETE.



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11-07 Risk Based Inspection

Category 3

Recommendation Develop a risk based inspection programme, including recording and analysis systemsin advance of the next plant turnaround.

Reason Whilst the plant is approx. 17 years old, there was limited inspection activity prior to thetakeover of the site by Indorama. Since then there has been a huge increase in theamount of inspection activity undertaken. Until now this has concentrated on ensuringthe integrity of the existing assets. However after the next turnaround, there will beadequate data available to start a Risk Based Inspection (RBI) programme. This willrequire trending of wall thickness data to determine corrosion rates and remaining lifeof materials.This process would be facilitated if systems for storage and analysis ofdata were in place prior to the next turnaround.

Examples Currently, there is no programme for trending of inspection data.


For RBI, as suggested, a system is under development by trending of piping thicknessdata by December 2011.

CTt Comment 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 focusinginspection efforts in the areas of greatest loss potential both in terms of frequency andmagnitude.The following references give a general overview of risk based inspectionprocedures:http://www.hse.gov.uk/research/crr_htm/2001/crr01363.htmhttp://www.dnv.com/binaries/13_paper_aem_%20paper_final_tcm4-367866.pdf

Status October2012

There has been limited progress, possibly due to the departure of the inspectionmanager. The recommendation is IN PROGRESS.

11-08 Corrosion Under Insulation

Category 3

Recommendation Increase inspection of high hazard areas where Corrosion Under Insulation (CUI)might be present. In particular inspection should concentrate on areas where theinsulation is damaged.

Reason Corrosion, if unchecked, will result in thinning and rupture of the pipe and the possiblerelease of hydrocarbon materials with the subsequent potential for fire or explosion.

Examples There are numerous places in the process and storage areas where damagedinsulation is present and in some cases vegetation growing. A specific case is thepipework at the base of the refrigerated ethylene storage tank.

EPCL Post SurveyComment 2011 Most CUI inspection is done during TAM. We shall enhance scope during TAM 2012as per hazard. CUI can be minimised by insulation repairs that should be taken upthoroughly in the whole complex on priority.

CTt Comment The problem with CUI is the lack of visibility of corrosion as it hidden beneath theinsulation. Where repairs are made to insulation, it is necessary to check and ensurethat there is no CUI before repairing the insulation. Repairs to insulation will notprevent pipework rupture if corrosion is already present.As a minimum, a register ofsuspect 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 alsotechniques, of varying effectiveness, which can be applied to check for CUI withoutremoval of insulation.The implementation of an RBI programme will assist in identifyingthe piping sections which should receive priority.

Status October2012

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 isunsuitable.

The recommendation is considered to be IN PROGRESS.

http://www.hse.gov.uk/research/crr_htm/2001/crr01363.htm


http://www.dnv.com/binaries/13_paper_aem_%20paper_final_tcm4-367866.pdf








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11-09 Fireproofing

Category 2

Recommendation Review the condition of fire proofing in the process areas and, where appropriatemake repairs.

Reason Fire proofing provides protection against damage to steelwork from thermal radiationand direct flame impingement. If the fire proofing is damaged, even in only one areathe protection will be damaged.

Examples Fireproofing was damaged in a number of locations in the process areas. Most of thedamage noted was on structural steelwork. Fire resistant panels had been attached ontop of steel beams.


We are reviewing it considering relevant API standard.

CTt Comment The comment above is applicable for areas where additional fireproofing is required.

However, it does not cover repairs required to existing fireproofing.Status October2012

A specific response to the recommendation was not obtained but no problems werenoted on site. Pending confirmation from EPCL that the repairs are complete, therecommendation is considered to be IN PROGRESS.

09-01 Sampling Procedures

Category 1

Recommendation Review the current sampling procedures (and their operation in practice) for liquefiedgases and, if possible, revise the procedure to avoid the release of process fluids during

Vegetation growing inprocess piping

Refrigerated ethylene tankpipework with corrodedinsulation

Damagedfireproofingin theprocessarea

Damaged fireproofingin the process area



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the sampling procedure.

If not yet completed, a Job Safety Analysis (JSA) should be undertaken for samplingactivities.

Reason The current sampling procedures involve the release of process materials toatmosphere. If incorrectly operated, valves can freeze leading to an uncontrolled

release of hydrocarbons. If ignited, a serious fire or explosion could occur. An exampleof 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 Liquefied gas sampling procedures in the olefins plant.


We will review current procedure and ensure proper implementation to avoid release ofhydrocarbon mixtures during sampling.

Status May 2011 A JSA is reported to be in place and some sampling points go to flare. However theredoes not appear to have been a comprehensive review of sampling and development ofmethods of working which avoid the release of liquefied gases to atmosphere.

The recommendation is IN PROGRESS.

EPCL Post Survey

Comment 2011

We will do a comprehensive study for sampling and development methods of working.

Status October2012

Current practice is to purge to flare before sampling where possible rather than to purgeto atmosphere. Some piping modifications will be necessary before all purging toatmosphere ceases and these will be completed at the next turnaround.


09-02 Fire and Gas Alarm Systems

Category 1

Recommendation Review the adequacy of the existing fire and gas panels and make appropriate repairsand upgrades as necessary.

Reason 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 below.

Examples • Fault alarms were active on most of the fire alarm panels inspected in buildings andprocess areas.

• Some of the equipment at the site may be obsolete, for example the site usescatalytic pelletizer type flammable gas detectors whilst newer, more reliable, infrareddetectors are available.


Last year, we changed the Fire & gas alarm system of PE plant. This year, we would dosimilar job in PP plant. For other plants, depending on requirement we may change

phase wise. This would increase overall reliability.

EPCL It has been reviewed and JSA is in place now.

Status May 2011 All the Fire panels examined showed numerous faults. However this is understood tobe as a consequence of changes to the power supply to the panel and alarm loops. Inaddition, there were fire alarm lights illuminated in some places and, possibly, somegenuine fault alarms.

The recommendation is considered to be In PROGRESS.


Being reviewed from time to time.

Status October2012

No problems were noted in the fire and gas panels during the surveys. Therecommendation is considered COMPLETE.



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09-03 Control Room Doors

Category 2

Recommendation Install automatic door closers on the external doors in the control room building.

Reason Large heavy doors, such as those on the control room, can be cumbersome to openand close manually and there is a temptation to leave them open, particularly in a warmclimate. However the integrity of the control room is compromised when the doors areleft open. In the, unlikely, event of a major explosion there would be casualties withinthe control room and damage to control equipment.

Examples All process control rooms.


Matching with the integrity of blast proof arrangement of control room, the main doorsare made quite robust & heavy. Providing door closure may cause inconvenient. Anyway, we would review it.

Status May 2011 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 ensuredoors are always closed.

Status October2012

The situation is UNCHANGED.

09-05 Document Control

Category 3

Recommendation Develop a document control procedure to ensure that:

• Key documents are "controlled" with the latest versions being accessible toregistered users and older versions destroyed.

• Uncontrolled copies can be clearly identified.

• Documents are written in an approved style with information such as date, revisionnumber, etc. clearly displayed.

Reason Currently EPCL are largely working with documents inherited when the site was underNNPC operation. Some key documents, such as Process and InstrumentationDrawings (P&IDs) have been updated and, it is understood that many other documentsare likely to be developed or revised now that the more urgent work of improving theplant’s mechanical integrity is completed.

Unless well-developed systems for the control of documents are developed, there is adanger 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 arethe ones available for reference in the plant control rooms.

• It is intended that many of the drawings, procedures, etc. will be available on thecompany Intranet. Unless, appropriate checks are built into the system, it will bedifficult to control downloading, printing and storage of uncontrolled documents.


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.

Status May 2011 EPCL is modifying their document control procedures to comply with ISO 9000standards. This recommendation is IN PROGRESS.


We are gearing up for ISO9000, ISO14000 and OHSAS17000 certification. Thisrecommendation will be automatically complied with.

Status October2012

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 isWITHDRAWN.



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09-06 Operator Emergency Training

Category 3

Recommendation 1. Review the existing emergency shutdown procedures and revise/update wherenecessary. Instructions should be written in a simple, easy to read, format.

2. "Short form" emergency instructions should be prepared as a standalonedocument. These could be in the form of checklists so that operators can confirmthat they have completed all the emergency actions required.

3. Institute an emergency simulation program for process operators so that they arefamiliar with required actions in the event of a process upset. The following pointsare offered for consideration:

• Process upset conditions should be considered in turn (e.g. loss power, losscooling water, etc.).

• Simulation training should be at the same time each week so that each shifthas the opportunity to practice each specific scenario.

•

Field operators should place tags on the valves they would operate to ensurethey 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 trainingprovide if necessary.

Reason 1. Whilst the operating instructions reviewed did contain emergency shutdownprocedures, there were sometimes vague and in a difficult to follow format.

2. Simple one page, step by step, instructions are easier for operators to understandthan complex manuals.

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

Examples Current Emergency procedures examined are based on the original contractorsoperating instructions which are, in some cases, limited or out of date.


This will be reviewed in plant level.

Status May 2011 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.

Status October2012

The recommendation is still not fully implemented, it was discussed in detail with theOlefin plant management and implementation is anticipated in the future.




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ARM Survey 2008

08-02 Analysis of Transformer Oil

Recommendation The study of gases from transformer oils can be used to give and early indication ofabnormal behaviour of the transformer and may indicate appropriate action that may betaken on the equipment before it suffers great damage. The frequency of the testingbeing determined by the nature of results obtained, with the interval being reduceddepending upon the rate of rise of gas concentration. Therefore, it is recommendedthat the facility follows current industry best practice of sampling and testing transformeroil every 12-18 months.

Reason It was indicated that the transformers' oil was sampled and tested during TAM1. Thisincluded Dissolved Gas Analysis (DGA) and dielectric testing. It was reported thatsimilar testing would be performed during TAM2 and subsequent turnaround.

Status June 2009 EPCL state that:

Transformer oil analysis being done with in-house resource. Suitable testing kit hasbeen purchased. Testing frequency is once every six months.

CTt Comment No further DGA analysis has been undertaken and the recommendation is considered

to be UNCHANGED.Status May 2011 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. Oil quality checking procedure every sixmonths is established now.

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 transformeroil and are indicative of impending failure.

An introduction to DGA can be found at:

http://www.electricity-today.com/et/issue0203/i02_analysis.htm

Status October2012

EPCL have purchased equipment for use on site. However the results of analysis donot appear credible and samples are being sent off site for analysis in a specialistlaboratory.







34


CTC 2006 Recommendations

06-01 Fire Detection/Protection Impairment System

Category 1

Recommendation Develop an Impairment programme so that equipment which is out of service or beingused for non-firefighting purposes is recorded and corrective action is taken as quicklyas 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 thefire detection and protection systems and whilst most equipment is in much bettercondition than at the start of 2006, there are many systems where repairs are not fullycomplete 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 systemswould be useful to insurance underwriters at the completion of TAM1 and the start-upof plants.

Examples Whilst the use of fire water for process cooling is much improved from the situationbefore TAM1, there are still some cases where fire water is used for cooling. Inaddition, there is considerable (uncontrolled) use of fire water for purposes, such aswash down of process areas. Fire hoses used for these purposes are evident inseveral parts of the site and the volume of water is such that the one of the mainelectrically driven pumps is operating continuously to supply demand.

In addition a number of defects, which have not yet been repaired were noted, wherethese exist additional safety precautions will be necessary to ensure that safety of thefacilities 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 June 2009 EPCL State that:

With the revamp of the fire detection and protection system in PE the system now existin all plants.

CTt Comment Some defects were noticed in many of the plants, this recommendation is consideredto be IN PROGRESS.

Status May 2011 The diesel fire pump and catalyst systems are now reported to be operational. Theother aspects are also covered in 09-02. This recommendation was consideredcomplete.

For future reference, details of an impairment system are available from Liberty Mutualvia the internet. A copy is attached in Appendix B.

Status October2012

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 firefighters.

In effect there has been no progress on this recommendation and the status isUNCHANGED.



35


06-03 Under Insulation Corrosion

Category 1

Recommendation Increase the speed of the under insulation inspection programme. The programmeshould be prioritised so that the most hazardous piping (based temperature, pressure,contents and corrosion potential) is inspected first.

Reason The inspection programme has so far only considered a small proportion of the pipingwhere under insulation could exist. A leak of hydrocarbon material from a corrodedpipe could result in a serious fire or explosion.

Examples Currently approximately 10% of the pipework has been checked for under insulation.From visual inspection, there are many places where the external weather protectionover the insulation has become damaged, with the potential for water to seep into theinsulation, possibly causing corrosion.


Under insulation corrosion inspection is being done as a routine and during shutdownopportunities.

CTt Comment There is considerable inspection activity related to under insulation corrosion. Thisrecommendation is considered to be IN PROGRESS.

Status May 2011 This is an on-going process and is IN PROGRESS.


Action is initiated.

Status October2012

The requirements of this recommendation are also covered in recommendation 11-08and this recommendation is WITHDRAWN.

06-10 Management of Change

Category 3

Recommendation Review the management of change procedure to:

1. Provide clear guidance on the criteria by which changes are considered trivial andthose 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

Reason 1. The lack of clear criteria to determine if detailed assessment is necessary couldresult 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 descriptionsare altered, etc.

Examples The aspects discussed above are not included in the current Management of ChangeProcedure.


MOC system implemented. SOP available on the internet.

CTt Comment Some aspects of the MOC procedure still require improvement and thisrecommendation is IN PROGRESS.

Status May 2011 There appears to be NO CHANGE since the 2009 survey.


This is a well-established procedure but there is scope for improvement and is beingdone.

Status October2012 This is reported to be COMPLETE.






36


06-11 Emergency Plan

Category 3

Recommendation Review the existing Emergency plan to provide a greater level of detail in areas suchas:

1. The provision of an adequately equipped emergency coordination centre in a safeand 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 beperformed.

Reason 1. The current location of the emergency coordination centre is undecided. Oneoption appears to be the use of the fire station control room. It is generallyconsidered preferable to use a room without distractions close to the main entrance.

2. The current emergency plan is comprehensive but the information is not alwayseasily 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 andsome information aspects could perhaps be transferred to appendices.

3. Currently there are no detailed plans for fire fighting in some of the areas withsignificant fire potential. Preplanning will allow a faster response to a fire, resultingin a lower level of damage. An example is given in Appendix E.

Examples Site emergency plan.


SOP for emergency procedures existing. On Site Emergency Management Plancompleted and available on the Intranet.

CTt Comment Some aspects, such as pre-planning are still not complete. The recommendation isconsidered to be IN PROGRESS.

Status May 2011 There has been an element of pre-planning but further progress is possible, includingthe provision of thermal radiation modelling to allow position of fire trucks to be fixedand the nearest fire hydrants identified.



Being reviewed from time to time.

Status October2012

Some preplans have been developed but these are generic and not specific to eachplant area or storage vessel.




37


Recommendations Prior to 2005

No. Title Summary Status in 2006June2009 Status

(EPCL Comments) May 2011 StatusOctober 2012

Status

03.03 LiquidEthyleneStorageTank

Variousrepairs to theethylene tank.

IN PROGRESS

Progress had beenmade in the area butsome work still needs tobe done. Examples arethe rod hanger on oneof the ethylene pipes tothe tank and insulationaround the liquidethylene pumps.

COMPLETED

Note that site visitsindicated that the rodhanger has still notbeen replaced.

Some repairs to theethylene tank remain.The recommendationis IN PROGRESS.

EPCL Post SurveyComment 2011 - Weare reviewing theengineeringcompany.

A technical review ofthe rod hanger hasbeen undertaken andthe hanger found tobe unnecessary.However, theanalysis might nothave considered thefact that the hanger issupporting thebellows (which showssigns of distortion)and not a section ofpipe. It would beprudent to repeat theanalysis including the

bellows.The recommendationis IN PROGRESS

Piping Support with RodHanger Missing – the situationsince at least 2003



38




Status

03.04 Use ofCellular

Telephones withintheProcessPlant

Use of mobilephones within

process plant.

NO CHANGE

Personnel using phones

were noted in severalareas including adjacentto the DCS panels,where there is concernthat the mobile phonesignal could interferewith the DCS.

Examples of mobilephone use in

hydrocarbon areaswere found duringthe survey. Itappears that mobilephones are acommon form ofcommunication at thesite.

There is NOCHANGE to theprevious situation.

EPCL Post SurveyComment 2011 - Theoretically innormal running plantscellular telephonesdo not pose any

hazard.CTC Comment –There is noconsensus over thehazards posed bymobile phones butmany companiesprohibit their use inelectrically classifiedareas.

The situation isunchanged from

2011, seniormanagement werenoted using cellularphones

The practice isdifferent from mosthydrocarbon facilitieswhere the use ofmobile phones isforbidden andphones are often notallowed in thehydrocarbonfacilities.

The situation isUNCHANGED

98.01 RemoteOperatedIsolationValves

InstallRemotelyOperatedvalves forprocessisolation in

emergencysituations

IN PROGRESS Out of 4 additionalROVs identified forinstallation 2 arealready installed and 2are procured waitingshutdown for

installation

All 4 of the originallyproposed ROVs arenow installedHowever, there arestill a number oflocations where there

are vessels with largeinventories and noROVs installed.

Common criteria are:

• 5 m3 for LPG

containingvessels

• 10 m3 for liquid

hydrocarbons

The recommendationis IN PROGRESS.

EPCL Post SurveyComment 2011 - Already installed intwo places, furtherunder review

There are stilllocations whereROVs should beinstalled and, it woulduseful to establish alist of locations so

that valves can beinstalled at theforthcoming TAM inThe situation isUNCHANGED.2013.

98.03 Fire-waterPumps

Stopunauthorizeduse of firewater.

NO CHANGE The level of fire wateruse is such that oneof the main electricpumps is runningcontinuously.

There is a project toinstall larger jockeypumps.


EPCL Post SurveyComment 2011 - Weare planning to installa bigger jockey pumpto take care ofuncontrolled leakage.

The new larger jockey pump hasbeen installed but isnot yet fullycommissioned.Hence the mainelectric pump is stilloperating.

The recommendationIS IN PROGRESS.



39




Status

96.13 HalonSystem

Status

Replace halonwith FM 200

NO CHANGE Preliminary work andtechnical discussion is

in progress. Would beimplemented in phasedmanner from 2010.

A programme forreplacement of the

Halon systems isunderway.


EPCL Post SurveyComment 2011 - Jobis in progress

Changeout of thehalon systems is

underway but notcomplete. Therecommendation isIN PROGRESS.



40


4. Exposure to Perils

4.1. Property

4.1.1. Fire and Explosion

Fire and explosion risks are inherent in hydrocarbon facilities. The potential size of a losswill 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 arediscussed in detail in the main body of the report.

4.1.2. Surrounding Exposures

The nearest large industrial site is NNPC’s 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.

Local communities extend to the outer perimeter fence in some places. The process and

storage facilities are located well away from the boundary fences and would not be exposedto small fires from shanty dwellings, car fires, etc.



41


4.1.3. Subsidence and Collapse

No serious 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 fromcondensate drains noted in a previous survey. Some damage to concrete covers over cable

trenches was also noted.4.1.4. Earthquake

The Munich Re"Globe of Natural

Hazards" rates the

area as Zone 0equivalent to

Modified-Mercalli Vand below.

4.1.5. Tsunami

The Munich Re "Globe of Natural Hazards" does not consider the area to be exposed to

tsunami. In any event the plant is set well back from the coast.

4.1.6. Volcano

Approximately 400 km to

the East of Port Harcourtis an area of volcanic

activity that stretchessouth west to northeast in

a line from the Gulf ofGuinea to Cameroon.

The Munich Re "Globe of

Natural Hazards" does notconsider the area around

the site to be exposed to

active volcanoes.



42


4.1.7. Lightning

The Munich Re "Globe of

Natural Hazards" shows

the area as subject to 20 -

40 lightning strikes perkm2 per year.

There have been

numerous lightning strikesat the plant. At least two

have resulted in minorfires.

Actions taken to minimise

the impact of lightningincludes ground resistivity

surveys.

4.1.8. Wind and Storm

Whilst the region is prone to electrical storms, it is not generally subject to significantwindstorm activity.


hazards"considers the

area to have aZone 1 exposure

to hailstones, the

lowest of six

ratings.



43



Hazards"considers the

area to have aZone 2 exposure

to tornado, the

second lowest of

four rankings.

4.1.9. Flood

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

4.1.10. Vehicle Impact

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

4.1.11. Vessel Impact

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

4.1.12. Aircraft Impact

Nearby airports are shown below:



44


The Port Harcourt international airport handles both fixed wing and helicopter flights and is

located approximately 25 km from the site. The Nigerian Air Force (NAF) airbase is approx.5 km from the site. This has a mixture of military flights plus some fixed wing and helicopter

flights. Flight paths are reported to avoid the EPCL site and no aircraft were noted overflyingduring the survey.

4.1.13. Riot Str ike and Civil Commotion

The 2012 Aon "Political Risk Map" rates Nigeria as High, the second highest of six ratings on

the scale.

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, includingtheft, 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 which culminated in

the kidnapping of a number of Indorama employees and dependents (including women andchildren) some years ago but relationships with the local communities are now reported to



45


be very good. All Indorama’s ex-pat staff and their families are now housed within the siteboundary.

4.1.14. Terror ism and Sabotage

The 2012 Aon "Terrorism and Political Violence Map" rates Nigeria as Severe Threat, thehighest of five ratings on the scale.

There has previous been considerable unrest in the Niger Delta region of Nigeria and the

Nigerian Military has conducted operations against armed gangs in the region. There havebeen a number of incidents, including kidnapping, shootings attempted invasion of oil

industry facilities, piracy and sabotage.

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 resoldand there are understood to have been no significant attacks or theft from EPCL facilities.

4.2. Machinery Breakdown

Brief details of the machinery breakdown are given in the table below:

Exposure Comments

Boilers and FiredHeaters

The major fired heaters are the crackingfurnaces in the ethylene plant plus boilers.

The major risk associated withequipment of this type is tube rupturewhich will generally cause limiteddamage.

However in extreme situationsexplosions can occur causing totaldestruction.

A number of tubes have leaked and havebeen sealed off; there do not appear to

have been any serious incidentsassociated with tube rupture.

Rotating Equipment There are a large number of rotatingequipment items, the key items being:

• HP compressors, particularlyassociated with the ethylene plant.

• Extruders associated with the twopolymer plants.

• Gas turbines.

There is a wide range of incidents whichcan lead to damage of rotatingequipment leading to varying levels ofdamage. Under most circumstances,damage will be limited to the rotatingelements of the machine but, in extremecases, total destruction can occur.

Transformers There are a number of large transformerson the site. Many transformers have firewalls between adjacent units but fixed fireprotection is not installed.

A fire involving a transformer is unlikelyto spread to adjacent equipment,however, in the unlikely event of atransformer explosion, fire walls could failresulting in additional damage to nearby

units.

Others Catalysts In some situations, catalyst life can bereduced or destroyed as a result ofprocess upsets or damage caused by fireor other perils.

4.3. Construction

Major Construction projects are planned over the coming years. A new ammonia - ureacomplex is currently scheduled to start construction at the beginning of 2013 and an

expansion to the ethylene cracker towards the end of 2013.

These projects, particularly the latter, are likely to result in significant cross exposures.



46


Anticipated hazards include:

Exposure

Interface withExisting Equipment

• Separation• SIMOPS

• barriers

Storage • Separation

• Value of material stocks

• Preservation

Hazardous Materials • Radioactive material

• Pickling chemicals

• Other hazardous chemicals

Fire and Explosion • Smoking

• Explosives for civil work

• Welding

• Fabrication areas

• Hot tapping

Pressure Testing • High pressure leak or pressure testing

Commissioning • Isolations

• Instrument bypassing

• Communication with existing plant

• Impairment of fire protection systems.

Excavations • Buried services

• Trench collapse

• Flooding of trenches

Cranes • Collapse

• Dropped object

At the time of the survey, there was too little information available for the extent ofconstruction hazards to be analysed.

4.4. Business Interruption

The site is self-sufficient in utilities but requires the supply of NGL from Agip as feedstock for

the process units. Natural gas is also imported for use as a fuel but could be substituted bydiesel fuel in the gas turbines.

There are problems with the limitation of feedstock from Agip and this sometimes leads tothe reduction in output from the units. This was the case at the time of the survey, with

production being limited due to flooding problems at the Agip site.



47


5. Loss Estimates

5.1. 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 theterms in common usage. However, they are defined in different ways by different

organizations. Definitions used in calculation of EML by CTT are given below:

• Probable Maximum Loss (PML) – The loss that could occur if the installed safety

systems and fire protection systems operated as intended once the incident wasidentified. Such events would be fires and explosions.

• Estimated Maximum Loss (EML) – The loss that could occur if safety systems and fixed

fire protection systems were unable to function as a result of the incident. Such eventswould be the rare but highly destructive and include 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 processsafety 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 is calculated, as this is of the greatest significance tounderwriters.

5.2. Property DamageThe following replacement values have recently been estimated by AVC and are used to

calculate the size of loss below:

Unit USD

Ethylene Cracker 284,800,000

Polyethylene 181,700,000

Butene-1 10,500,000

Polypropylene 80,100,000Polyethylene Bagging 24,200,000


Storage Area (including pipeline toRefinery)

57,600,000

Power Station 109,300,000

Cooling Water 23,100,000

Demineralised Water 33,400,000

Air and Nitrogen 22,900,000

Flare Area 9,400,000



48


Unit USD

Effluent Treatment (IncludingIncinerator)

16,800,000

Administration and General Excluded

Refinery Tank Farm 3,700,000

Total 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:

Olefin PlantPolyethylene

Plant

PropyleneRefrigeration

Drum

C2SplitterColumn

C2Splitter

Reboiler

C2

SplitterRefluxDrum

C3Splitter

C3SplitterReboiler

C3

SplitterRefluxDrum

CyclohexaneCircuit

Tag No. D-44 C-6 E-59 D-32 C-8A/B E-76 D-35

Contents Propylene Ethylene/

Ethane

Ethylene/

Ethane

Ethylene/

Ethane

Propylene/

Propane

Propylene/

Propane

Propylene/

Propane

Cyclohexane/Et

hylene

Pressure

Kg/cm2

1.3 24.8 27.8 23.8 19.3 18.1 18.1 110-140

TemperatureoC -27 -22/2 -1 23 48 41 41 310

Diameter M 6.0 4.6 2.914 4.1 4.65 2.49 3.4

Length T/T m 17.5 61.65 12 16.2 104.4 4.88 13.45

Percent Full 50% - 90% 50% - 90% 65%

Volume M3 247 144 72 107 180 22 122

Mass Kg 151,905 79,200 39,600 60,956 104,400 12,540 75,030 110,000

Flash Fraction 0.12 0.53 0.85 1.00 0.64 0.61 0.57 1.00

Mass of Cloud 18,229 41,976 33,660 60956 66,816 7,649 42,767 55,000

Modelled as: Propylene Ethane Ethane Ethylene Propane Propane Propylene Cyclohexane

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

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

in the following damage levels.

80% Damage 40% Damage 5% Damage Total

Overpressure radius, M 125 283 448

Static Loss, USD Million 29.46 238.68 4.89 273.03

Drift Loss USD, Million 76.07 231.23 3.30 310.60



49


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: USD 435 million.

Note that underwriters’ exposure might be reduced as some of the factors included in thecalculation (e.g. debris removal and fire fighting expenses) have been excluded from the

valuation.Damage contours are shown below:

5.3. Property Damage 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.The sum insured for Business Interruption is USD 300 million for a 12 month indemnityperiod.

A repair time of around 24 months would normally be expected in this situation and the loss

is estimated to be USD 600 million but underwriters’ exposure would be limited to the USD

300 million insured value.

Key

1 Polyethylene Warehouse

2 Polyethylene Plant

3 Butene-1

4 Olefins

5 Cracking Furnaces

6 Compressed Air/Air Separation

7 Polypropylene Warehouse

8 Polypropylene Plant

9 Power Plant

10 Water Treatment and CoolingWater



50


5.4. 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 withsimilar sized plants, a replacement value of USD 17 million in 2006 has been assumed. An

increase in replacement cost of 25% has been assumed, giving a replacement cost ofapproximately USD 22 million.

Whilst total destruction of a machine is rare, it may occur and two scenarios are postulated:

USD Million

Cost of Machine 22

Damage to Rotating Elements

(50% loss of machine value and 20% cost to strip the machine, replace therotor and rebuild the machine)

15.4

Addi tional Costs

Inflation for 21 months at 5% per annum (incident on last day of policy year and9 month replacement)

3.6

Total 19.0

Destruction of Machine

(100% loss of machine value and 20% to remove and replace the machine) 26.4

Addi tional Costs

Inflation for 30 months (incident on last day of policy year and 18 monthreplacement)

6.3

Total 32.7

5.5. 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, thefollowing 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:

USD300/6 = USD50 million

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:

USD450 million

Note that the indemnity period would limit the underwriter’s exposure to USD 300

million.



51


5.6. Summary of Loss Estimates

Scenario

PropertyDamage

(USD

Million)

BusinessInterruption

(USD

Million)

Combined

(USD Millions)

Property Damage Vapour cloud explosion in the olefinplant following a release from the C2splitter reflux drum

435 600 1,035

MachineryBreakdown

Damage to the rotating elements ofthe olefin plant cracked gascompressor

19.0 50.0 69.0

Complete destruction of the olefinplant cracked gas compressor

32.7 450 458.4

Note that underwriters exposure will be limited to USD 300 million (the policy limit with a 12 month indemnityperiod) for business interruption losses.



52


6. Description of Installation

6.1. Production Facilit ies

EPCL operates a petrochemical complex producing ethylene and propylene for themanufacture of polyethylene, polypropylene and butene–1. Raw material is an ethane richNatural Gas Liquids (NGL) feed from the Obiafu-Obrikom Natural Gas Liquids separation

facilities operated by Agip (as a NNPC Joint Venture). There are currently feedstockproblems due to flooding at the AGIP facilities which currently limit production in the olefinsunit to 85 – 90% of capacity. Prior to the flooding, the olefins plant was operating at full

capacity. The downstream units are operating at 70 – 80% of capacity.

Further feedstock in the form of propylene from the Fluidised Bed Catalytic Cracker (FCC),

at NNPC’s 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 isseldom supplied. Simple unloading facilities have been installed to unload Propylene RichFeed (PRF) from NNPC’s Warri refinery but, again, this is not done on a regular basis. One

of the cracking furnaces can operate on Virgin C5 feedstock.

Pyrolysis gasoline, a by-product of the olefins plant, can be exported by pipeline to the

refinery.

A simple block diagram is given below:



53


6.1.1. Process Units

Brief details of the production units are given in the table below.

Designation CapacityTonnes/Year

Licensor Contracto r Year Comments

Olefins Plant 300.000 Kellogg"Millisecond"technology

ChiyodaCorporation

1995 Four of the six cracking furnaceshave been retubed using KelloggBrown and Root (KBR) SCOREtechnology. The plant hasreached production capacities of305 – 310,000 tonnes per yearfor short periods but is nowoperating at approx. 55,000tonnes per year.

Polypropylene(PP)

80,000 Montel (exHimont)-Spheripoltechnology

TechnimontSpA andJapanese GasCorporation(JGC)

1995 Currently there is nopolypropylene supply from thePort Harcourt refinery and theunit runs on propylene providedfrom the olefin unit. Theprocessing of a VC5 stream andthe import of PRF (PropyleneRich Feed) from Warri hasincreased the availability offeedstock.

Due to feedstock limitations theplant previously ran in campaignmode but is now operating at 70- 80% of capacity. Thisrepresents a safer mode ofoperation than the frequent start-ups and shut downs associatedwith campaign mode.

The plant has run at up to 50%above design. Throughputs will

vary with grade of polymer beingproduced.

Total production for 2012 isexpected to be 58 – 60,000tonnes. Run times have beenup to 98 days.

There are 2 extruders eachcapable of 100% of production.One unit is original andscheduled for replacement, theother is a new unit.

Polyethylene(PE)

270,000 Nova (Du-Pont)Sclairtechtechnology

Kobe Steel 1995 This is a medium pressure unit,operating at approx. 145 bar g.270oC. Twin extruders areinstalled

The plant has beendebottlenecked, which hasincreased the capacity to302,000 tonnes/year. The plantis operating at 70 - 80% ofcapacity but has run atthroughputs up to 15% aboveoriginal design capacity.

Throughput will vary with thegrade of polymer beingproduced.

There are 2 extruders, eachsized for approximately 75% ofcapacity.

One unit is original andscheduled for replacement, theother is a new unit.



54


Designation CapacityTonnes/Year

Licensor Contracto r Year Comments

Butene-1 22,000 InstitutFrancais du

Petrole (IFP) Alphabutoltechnology

Kobe Steel 1995 The plant is operating at 70 -80% of capacity.

Utilities andOffsites

- ChiyodaCorporation

1995

Infrastructure - SpieBatignolles

1995

Olefin plant cracking furnaces

Polypropylene plant reactorsystem



55


6.1.2. New Projects

EPCL are planning a series of new projects at the site. The first is likely to be a new

ammonia urea plant with construction expected to start in the first quarter of 2013 and with a36 month construction period.

A new gas line from Agip will be constructed as part of the project, along with urea export

facilities to a marine jetty.

There are also plans to increase the capacity of the olefin plant by 50%, including theaddition of three new cracking furnaces, plus an HDPE plant. This work is expected to start

towards the end of 2013. There will also be a number of modifications to the existingfacilities, including re-wheeling of the main compressors and changes to column internals.

This is likely to involve significant construction work within the existing olefin plant facilities,some work is likely whilst the plant is operational and a good SIMOPS system is essential.

A new methanol plant is also envisaged in the future.

Whilst the construction of additional process units at the site was envisaged at the designstage and space is available, conditions within the site boundary have changed significantly

with a significant number of people, including families, now being housed within the site. Additional accommodation is currently under construction.

The construction of the ammonia plant, in particular, changes the hazard profile of the site,

presenting a major toxic hazard. It would be prudent to undertake a comprehensiveconsequence modelling study before the plant design has been "frozen" to ensure that fire;

explosion and toxic risks are assessed and minimised.

6.1.3. Process Hazards

• Fire: Fires can occur in almost any location which contains

combustible or flammable material or electricalequipment. Simple procedures such as good

housekeeping and control of smoking can reduce thehazard to acceptable levels.

• Pool Fire: Pool fires occur, following a leakage of flammable

liquid which collects in a low point and ignites. Fires

can vary in size from small fires originating from a

pump seal or flange leak, to whole roof fires on largestorage tanks. Large fires involving stock tanks give

rise to high levels of thermal radiation and mayspread from one tank to its neighbours if tanks are

located too close together.

• Jet Fire: Jet fires occur following release of high pressure gas

or liquid from an orifice, typically a pipe flange. Fires

of this type generate long flames with high levels ofthermal radiation.

• Explosion: Most explosions are relatively small and occur as a

result of ignition of small amounts of flammable gasesor liquids in a confined space. However sometimes

more serious explosions can occur.



56


• Vapour Cloud Explosion (VCE): VCEs are amongst the most destructive events thatcan occur in the oil and petrochemical industries.

They occur following the release of a cloud of

flammable gas which ignites. They are mostdestructive in areas of congestion such as processareas.

• Boiling Liquid Expanding

Vapour (BLEVE):

A BLEVE occurs when the wall of a pressure vessel is

overheated by external heat to the point when it

cannot withstand the internal pressure of thecontents. When the vessel ruptures, the contents, ifthey are flammable, will ignite generating high but

short lived levels of thermal radiation and limitedoverpressure.

• Mercury: Mercury in very low concentrations is sometimesfound in gas fields. The mercury may concentrate in

processing equipment and may cause damage. Ofparticular concern are aluminium vessels and heat

exchangers where rapid failure may occur.

Tests for mercury are reported to have beenundertaken and no traces found at the parts per billion

(pbb) level.

• Pressure Vessel Rupture: In some situations a vessel can rupture either due toexcessive internal pressure or a defect in the vessel,

for example due to corrosion. The consequences arelikely to be a mixture of blast effects and some

projectile damage.

• Toxic Materials: Whilst exposure to high levels of any gas is

undesirable, there will be significant hazards fromammonia in the future when the new ammonia and

urea plants start up.

• Runaway Reactions: Some chemical reactions have the ability to"runaway" or accelerate to a point when they are out

of control. This can occur, for example, when power

failure occurs (which prevents effective missing) or ifcooling water failure occurs (which will prevent theremoval of the heat of reaction). The polypropylene

unit, currently shutdown is considered to have the

major exposure.

Special precautions, such as emergency cooling

water supplies or reaction "kill systems" arenecessary in such situations. Additionally, physical

precautions, such as blast walls, may also berequired.

•

Pyrophoric Materials:Some materials, particularly polymer catalysts, are

flammable on exposure to air and may ignite.



57


• "Rollover": This occurs in refrigerated storage tanks when a layer

of cold, heavier, liquid exists on top of a warmer lessdense liquid. The two layers can suddenly "rollover"

releasing large quantities of vapour which mayexceed the capacity of the tank’s pressure protection

system. The only refrigerated tank at the site is forethylene storage and the tank is designed to minimise

the potential for rollover.

• Hot Oil Systems: The polyethylene plant has hot oil as a heat transfermedium to limit the number of direct fired heaters or

as an alternative to boilers. Hot oil is often flammableand particular problems can occur in the fired heaters

of hot oil systems.

• Fired Heaters: Boilers and fired heaters often provide the ignitionsource for a leak of flammable gas.

• Rotating Machinery: Many plants have large items of rotating machineryoperating at high speed. Failures in ancillary systems

such as lube oil or unexpected operating conditions ormanufacturing defects can result in mechanicalfailures. These generally result in damage to the

rotating elements but in severe cases can result in

total destruction.

• Poly Chlorinated Bi Phenols

(PCBs)

There are no PCBs on site.

• Asbestos With the exception of some sheeting for buildings,

there is no asbestos on site.

• Radioactive sources Radioactive level measurement instruments are inuse in the polymer plants.

Weld inspection using radioactive sources, generally

owned and controlled by the inspection contractor.

There is also a radioactive source in the alloy

analyser at the site.

• Road Collision There are frequent road movements around the site.Whilst vehicle access to the process units is

controlled, collisions with piperacks or road sideequipment may occur.



58


6.1.4. Layout

Brief details of the layout are given in the table below:

Details Comments

General The existing process units are located tothe south of the site.

There is plenty of space for futureexpansion and the new accommodationfacilities constructed at the site areremote from operational and storageareas.

The Natural Gas Liquids (NGL) pipelinefeeding the site terminates at a custodytransfer point in a Nigerian Agip OperatingCompany (NAOG) terminal at the plantnorth west corner of the site.

The process and utilities are arranged in 2rows west to east in the following order:

Row 1 (northerly row)

• Polypropylene warehouse.

• Polypropylene production.

• Power plant.

• Cooling Water Systems and WaterTreatment.

Row 2 (southerly row).

• Polyethylene warehouse.

• Polyethylene production.

• Olefin Unit.

• Vacant plot.

• Air separation and compressed airutilities.

These facilities are on individual plotsapproximately 150m by 250m, withseparation by road, approximately 12 mwide.

Storage facilities are located to the east ofthe site.

Much of the area is open, particularlyaround the main administration building.This will limit the hazard faced by

employees in the building in the event ofa major explosion. Spacing between thevarious process, utility and storagefacilities is also good, limiting thepotential for domino effects from onearea affecting adjacent areas. This is, inpart, due to anticipated future expansionat the site, which has not so far takenplace.

Spacing within the process areas iscongested in some locations.

This could limit access for maintenanceand inhibit firefighting.

The new ammonia and urea plants arebeing constructed to the north of Row 1and the HDPE unit to the south of row 2.

The flare-stacks and burn pits are locatedto the East of the currently unoccupiedareas, with adequate sterile areasdefined.

Process areas are on concretefoundations surrounded by areasbackfilled with stone.

In some locations damage to theconcrete pads supporting minor items ofstructural steelwork was noted.

Piperacks The level of fireproofing on piperacks isvariable between process units.

Generally pumps are not located under orpartially under piperacks.

This will greatly minimise the potential forthe fin fans to affect the extent of the fire.



59


Details Comments

Within the polyethylene plant, fin fancoolers were not fireproofed to the full

load bearing height.

The air flow from the fin fans willexacerbate flames from a pool fire. The

provision of fireproofing almost to the topof the fin fan cooler will minimise theextent of damage caused by a pool fireunder the fin fan.

Within the olefin plant, drainage points areunderneath the main piperacks.

If the ground were sloped towards thesedrains, spills of burning liquid would rununder the pipes and cabling, potentiallycausing significant damage.

Electrical Cabling Cable routing in the plants is partiallybelow ground and partially above groundat the lowest piperack level.

This provides a lower level of protectionthan cabling run underground.

In a number of locations electrical orinstrument cabling runs along the piperackat the lowest level.

Cabling would be exposed to a fire underthe piperack. A serious fire could resultin lengthy re-cabling times, with resultant

loss of production.

Piperack with aboveground electrical cabling



60


Details Comments

Compressor Houses Within the olefins plant, there are twoseparate compressor houses. Both

refrigeration compressors are locatedwithin one building with a separatestructure for the cracked gas compressor.

The main compressor houses are roofedand walled around three sides at theupper level. The remaining side is leftopen to allow access for maintenance.

The structures are open on all 4 sides atground level.

Within the olefin plant, the cracked gasand refrigeration compressors are inseparate structures.

This will allow natural ventilation andprevent the build-up of high levels of gasin the event of a release.

Lube/seal systems are located to the sideof the compressor, close to the plant.

The close location of the lube/sealsystem to the compressor could result in

damage in the event of a lube seal fire. All of the main compressors haveindependent lube/seal oil systems.

Fired Heaters The main fired heaters are the crackingfurnaces and boilers are located at theSouthern end of the olefin unit.

The location of all the fired heaters inone location minimises the likelihood thata gas leak will find a source of ignition.

A plotplan is shown in Appendix F.

Olefin plant processcompressor house



61


6.2. Control and Process Safety Systems

6.2.1. Basis

Brief details of the control system are given below:

Details Comments

Configuration On the olefins plant the trip systems areintegrated into the DCS. The polymerplants have independent ESD systems.

Fully independent ESD systems areconsidered preferable to integration ofthe trip functions within the DCS.

No SIL analysis has been undertaken inany of the plants by EPCL.

Type Yokagawa Centum 3000 DCS’(Distributed Control Systems) are installedin all units.

The original DCS systems wereupgraded in the 2010 TAM.

Neither the existing or new plants have

alarm management functions.

A number of companies have

experienced problems, with "alarmflood", during a major incident1. This

results in literally hundreds of alarmsbeing activated within a very short spaceof time. When this happens, the sheervolume of alarms makes it difficult foroperators to follow the exact sequence ofevents. Alarm management systemsassist by filtering out the less importantalarms.

6.2.2. Control Room Design

Brief details are given below:

Details Comments

Location Each of the process units has anindependent control room. In additionthere are control rooms for the powerstation and the storage area.

Construction Process control rooms are blast resistantstructures but appear unpressurised.Whilst automatic door closers wereoriginally fitted, these have, in somecases, been removed or are ineffective,as in the polyethylene plant. Thereforedoors may be left open, defeating theblast resistance. Some control rooms are

located close to the process facilities.

All the process control rooms had thedoors in the open position during thesurvey which would negate the blastresistance of the structure.

Smoke Detection The control rooms have fire detectionsystems.

Fire Protection The control rooms have fixed fireprotection systems covering the controlsystem and adjacent instrument rackrooms.

In some cases doors between the controland rack rooms are left open which willprevent the gaseous systems workingeffectively. This is believed to be due toproblems with the air conditioning systemand once repairs are made doors will bemaintained in the closed position.

1 http://www.hse.gov.uk/pubns/chis6.pdf

http://www.hse.gov.uk/pubns/chis6.pdf






62


6.2.3. Emergency Shutdown Systems


Details Comments

Type The olefins plan has the trip systemsintegrated into the DCS. The polymerplants have independent ESD systems.

Fully independent ESD systems areconsidered preferable to integration ofthe trip functions within the DCS.

No SIL analysis has been undertaken inany of the plants by EPCL.

The ESD systems are hard-wired systemsand are not dependent upon computersoftware for operation. In some cases,these are two out of three (2-O-O-3)voting systems.

The polymerisation reactions areexothermic. Both have shutdown systems

and the PP plant has a catalyst killsystem, which injects CO into the reactorsto kill the reaction immediately stoppingreaction heat generation.

This system worked successfully duringthe power failure earlier in 2011.

6.2.4. Remote Isolation, Depressur isation and Blowdown

When originally constructed, there were 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 toatmosphere in the event of a pump seal failure. This issue has been highlighted in previous

survey reports and EPCL have installed ROVs in four locations, most recently, on the C2 andC3 splitter reflux drums. There do appear to be some locations, for example the pumps

feeding the bottom section of the C3 splitter, where it may be prudent to install valves.

An ROV is installed on the feed drum in the polypropylene plant but the cabling is notfireproofed. If a leak of propylene ignites, the valve may quickly become inoperable.

ROVs are installed on the spheres and ethylene tank.

6.2.5. Pressure Relief Systems


Details Comments

Configuration: With some exceptions single pressurerelief valves have been installed onprocess duties. On a few duties, pressurerelief valves are duplicated.

It is difficult to test relief valves when theplant is operating when there are onlysingle valves.

Duplicated relief valves are installed onthe spheres, complete with Castell keyinterlocks to ensure that a relief line isalways open.

Some, at least, of the Castell2 key

systems are not functioning and havebeen replaced by a car seal system.

This will allow a valve to be removed fortesting and inspection whilst the plant isin operation without the necessity ofeither taking the unit out of service orwaiting for a shutdown.

The use of car seals appears to beuniversally applied to pressure reliefsystems at the site.

2 http://www.castell.com/en/

http://www.castell.com/en/






63


6.2.6. Combustion Safeguards

Boilers, furnaces, and direct-fired heaters have fuel gas management systems.

Fuel gas isolation consists of a double block and bleed system.

6.2.7. Shaft SealingMany of the pumps at the site handle liquefied gases and are fitted with double mechanical

seals and seal failure protection.

Compressors have wet type seal systems rather than the more modern dry type.

A triple mechanical seal has been fitted on the agitator on the polyethylene plant reactor.

6.3. Feedstock Supply and Product Transfer

6.3.1. 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.

6.3.2. Pipeline

There are a number of principle pipelines entering and leaving the site, brief details are givenbelow:

Product From/To Length Comments

Natural Gas Liquids(NGLs)

Obaifu-Obrikomgas separationplant.

85 km The NGL and fuel gas line follow acommon routing.

Fuel Gas Obaifu-Obrikomgas separationplant.

85 km The NGL and fuel gas line follow acommon routing.

Fuel gas from this line would be requiredfor start-up but once continuousoperation is underway, fuel gas for thesite can be taken from the crackingfurnace overheads.

Propylene RichFeed

Port HarcourtRefinery.

6 km Currently out of use until the PortHarcourt refinery FCC is returned toservice.

Virgin C5+ Port HarcourtRefinery

6 km

Cracked C5+ Port HarcourtRefinery

6 km

6.4. Storage Facili ties

The site contains atmospheric, pressurised and refrigerated storage.



64


6.4.1. Atmospheric Storage

Brief details of atmospheric storage are given in the table below:

No.Installed Stored Material Capacity (m

3) Type of Roof

2 Virgin C5+, 4,630 Cone

2 Cracked C5+, 1,671 Floating

1 Cyclohexane 2,000 Cone

1 Ocene-1 2,000 Cone

2 Gas Oil 2,050 Cone

Further details are given below:

Details Comments

Diking The tanks are grouped within one mainbund with approximately a tank diameterbetween the tanks. The two floating rooftanks are separated by a common wall.

Atmosphericstorage area



65


Details Comments

Instrumentation It is understood that the tanks originallyhad independent high level alarms.

This should prevent overfilling, if the levelgauging system failed.

This differs from information obtainedfrom previous surveys which stated thatthere were no independent alarms.However, it is likely that level alarmssystems were not well maintained whilstNNPC operated the plant.

All the tanks that have been overhauledhave had the level gauging and alarmsystems renovated. Where possible, thishas involved refurbishing the originalservo type, level gauging system and floatswitches.

This should avoid accidental overfilling.

In some cases radar type level gauginghas been installed.

Radar type level gauging is consideredvery reliable and generally considerednot to require an independent levelalarms.

Fire Protection All the tanks are fitted with semi-fixedfoam systems and water deluge.

Drains Roof drains on the floating roof tanks arenormally left open. The drain lines arechecked every shift.

This will avoid a build-up of rainwater onthe tank roof which could cause the roofto sink. However any leakage from theroof drain line could lead to the dischargeof the tank contents into the diked area.

The dike drains are also left open in therainy period.

This will avoid situations where almostempty tanks will float if there is a seriousbuild-up of rain water in the dike.However, it does raise the possibility thatany spillage of hydrocarbons will not be

contained, perhaps leading to runninghydrocarbon fires along the drainssystem to the effluent treatment plant.Such fires could lead to ignition of nearbyvegetation, this has happened in otherlocations.

The drains from the atmospheric storagearea go either to the storm water drains orthe Effluent Treatment Plant (ETP).During the rainy season the route to adedicated storage basin in the EDP isnormally open.

6.4.2. Pressurised Storage

Brief details of pressurised storage are given in the table below:

No.Installed Stored Material

Capacity(m

3) Comments

3 NGL 3,809 These tanks operate at -5oC and are

thermally insulated.

3 VC5 2,760 These were previously propylene richtanks similar to those described below.They were converted to operate at -5

oC

and have been thermally insulated.



66


No.Installed Stored Material

Capacity(m

3) Comments

1 Propylene rich feed 2,760 The propylene rich feed was originallyintended to be supplied from the NNPC

Port Harcourt refinery. More recently,there have been some tanker importsfrom NNPC’s Warri refinery. Supply fromboth sources is no longer available.

One of these tanks has been convertedto NGL operation at-5

oC and insulated.

2 Butene (Intermediate Product). 905

3 Purified Propylene. 2,239

Further details are given below:

Details Comments

Construction The spheres are of conventionalconstruction. a number are insulated forstorage of NGL.

All pipe flanges are located outside the

shadow of the sphere.

Minimising the number of flanges,

valves, etc. will limit the potential for aleak under the vessel and the potentialfor a BLEVE.

Part of sphere storage

area



67


Details Comments

Diking The tanks are located in sloped concretedikes. piping penetrations through the

dikes are sealed.The spheres have drainage channelsleading away from the sphere area.

Pumps Pumps are located remotely from thespheres.

Instrumentation It is understood that the spheres originallyhad independent high level alarms.

This should prevent overfilling, if thelevel gauging system failed.


As spheres have been taken out ofservice for inspection, the original servotype level indicators plus float switchedhave been repaired or radar type levelindication installed.

This should avoid accidental overfilling.

Radar type level gauging is consideredvery reliable and generally considerednot to require an independent levelalarm.

Gas detection is installed in some areas.

Pressure Relief Duplicated relief valves are installed onthe spheres.

Some poorly installed supports for

pressure relief systems were noted.

These originally included Castell keyinterlocks to ensure that one relief line isalways open. However some of theseat least are non-functional and havebeen replaced with a plastic car sealsystem.



68


Details Comments

Motor OperatedValves

ROVs, sample points etc. are located onthe outside of the dike wall. Penetrationsthrough the dike wall are generally wellsealed but there are exceptions.

Poorly sealed penetrations may leak.

Fire Protection All the spheres are equipped with deluge

water sprays, operable from two locations.

This should allow access to a valve

under all wind conditions.

Sphere legs are fireproofed.

Support for sphere PSV systems,this is wedged in position with nofixings.



69


6.4.3. Refr igerated Storage

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


Details Comments

Construction Double wall tank with a perlite filledannulus, constructed to API 620.

There is a nitrogen purge through theannulus.

The fill and empty lines for the tankcontain bellows which appear to beslightly distorted. A support for one of thepipes appears to be missing.

To minimize the potential for rollover, thetank contents are continually circulatedand sprayed into the top of the tank.

There is reported to be some leakage ofethylene through the inner skin of thetank.

The tank annulus is purged with nitrogen.

Previous surveys have noted a missingrod hanger on one of the main ethylenetank lines. In response to previousrecommendations, EPCL haveundertaken an engineering study whichhas determined that the rod hanger is notnecessary.

It is not clear if the analysis assumed thatthe piping is rigid, as opposed to abellows, which is distorted. It would beprudent to repeat the analysis to check ifthe lack of the rod hanger s still adequatein the present of a bellows rather thanrigid pipe.

Piping Support with RodHanger Missing



70


Details Comments

Diking The tank is located in a sloped concretewall dike, with drains leading to animpounding basin.

The mastic used to seal the expansiongaps in the dikes has largely perishedand, in its current condition, the dike mayleak.

Within the dike, there is a channel leadingto a small impounding basin with a foamsystem.

The foam system will minimiseevaporation of any ethylene spillage.

The entire diked area is overgrown withvegetation and requires clearance. Thisparticularly applies to the impoundingbasin, which contains a level of water andseveral medium sized trees.

Water could act as a source of heat toallow rapid vaporization of liquidethylene.

Ethylene tankpipeline showingdistorted bellows



71


Details Comments

Pumps Pumps are located remotely from thestorage tank.

Instrumentation The refrigerated tank has 2 independentlevel gauging systems. One is a float typesystem; the other is based on a differentialpressure system.


This should prevent overfilling, if thelevel gauging system failed. The use ofdifferent measuring techniques will

minimise the potential for common modefailures.

A single Boil Off Gas (BOG) compressorreturns vaporised ethylene gas to theolefin unit for re-liquefaction. When theethylene plant is shut down the vaporisedgas is vented to the flare.

An unusual feature of the tank is the factthat the flare vent control valve failsclosed and in the event of a power failureor other interruption to the instrument airsupply an operator needs to climb thetank and manually open the bypass.

Fire Protection The tank itself is fitted with a water delugesystem around its circumference.

Medium expansion foam and waterdeluge systems are installed to cover asmall impounding basin within the dikedarea.

From a visual inspection, this equipmentappeared to be in poor condition andshould be checked.

Ethyleneimpounding basin



72


6.4.4. Warehousing

The main products from the site are solids, stored in separate warehouses:

• Polypropylene - 19,000m2 warehouse

• Polyethylene - 42,000m2 warehouse.

Both warehouses are protected with sprinkler systems. Some sections of the sprinkler

section were isolated.

Layout of the warehouses is good with clear access around the bagging areas and the forklift truck charging points well separated from the polymer storage. Pallets of polymer are

generally within marked bays but in some locations access to fire fighting equipment islimited.

6.5. Utilities

The site is designed to be self-sufficient in utilities. Further details are given in the sections

below.

Restricted access tofire fighting equipmentin the polyethylenewarehouse



73


6.5.1. Water

Brief details of the water systems are given in the table below:

Details Comments

Raw Water:

Sources There are 6 boreholes of which 3 arenormally in use producing approximately300m

3/hour.

There were originally 8 boreholes but 2are outside the site boundary and nolonger used.

Storage 2 tanks are installed, each of 55,000m3

capacity.These tanks also provide the fire watersupply.

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

There is also a demineralisation unit toremove sediment and ferric ions, plus 2activated carbon filters for potable water.

Cooling Water: A single cooling water system covering allthe process units is installed.

A vent is installed in the cooling waterreturn line. This is located on the returnline itself rather than on the individualpipes to each cell.

Vents are often installed on the returnlines of cooling water systems to avoidthe entry of flammable gases (from heatexchanger leaks) from entering thecooling tower where they might ignite.The efficiency of the arrangementinstalled at the site is not clear. In thecase of significant leaks, it may allow gasto be swept past the vent into the coolingtowers.

A gas detection system is installed. This should detect any hydrocarbongases in the returned cooling water fromleaks in heat exchangers.

The original cooling tower internals havenow been replaced with polypropylenepacking.

Cooling tower fans are reported to haveexplosion proof motors.

This will reduce the likelihood offlammable gas igniting.

The gearboxes and motors have vibrationalarms.

No. of Cells There are 2 cooling towers, each with 5cells.

All cells are now operational and repairsto gearboxes and fans, reporteddefective in previous surveys have now

been repaired.Packing in the cells is in relatively poorcondition. Some has been displaced intothe cooling water return line and blockedtubes in many of the exchangers.

No. Normally in Use 8 cells should be adequate for fulloperation but previously all 10 have beenin use.

No. of Pumps 5 electrically driven pumps, each of8,400m

3/hour are installed.

No. Normally in Use The system is designed for 3 of the 5pumps to normally be in use.

Previous problems of leakage, requiringa 4

th pump to operate have now been

overcome.



74


Details Comments

Boiler Feed Water Treatment consists of:

• 3 Activated carbon filters installed for

condensate treatment.

o 2 x 175 m3/hr

o 1 x 280 m3/hr

• 3 mixed bed polishers all 280 m3/hr.

In addition to provision of fresh BoilerFeed Water, there is a significant recycleof condensate.

The Boiler Feed Water quality haspreviously been poor on occasions and

this may have contributed to problemswith the boiler tubes. Improved chemicaldosing and monitoring are now in place.

The following storage capacity is installed:

• Demineralised water 1,500 m3

• Polished water 2 x 1,500 m3

6.5.2. 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 theolefin plant has been achieved, fuel gas is provided by the cracking furnaces.

The gas turbines can operate on either natural gas or diesel fuel.

6.5.3. Steam


Details Comments

No. of Boilers All steam raising takes place on theolefins plant using the following:

• 3 Boilers each generating 120tonnes/hour at 48 kg/cm

2.

• 6 Cracking furnaces generating steamat 48 kg/cm

2 and 109 kg/cm

2.

The boilers have been refurbished aspart of TAM 1 and are now equipped witha Yokogawa DCS systems.

OperatingConfiguration

Steam is provided by the crackingfurnaces and the boilers.

At low cracking rates all three boilers wererequired to meet steam demand. Asdemand increases, more heat from thecracking furnaces is recoverable as steamand 2 boilers will be adequate to meetdemand. However normal practice is tokeep all 3 boilers in operation at reducedflow rates to allow for the possibility of aboiler trip.

During periods when boilers are takenout 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/cm2).

• High Pressure (48 kg/cm2).

• Medium Pressure (11 kg/cm2).

• Low Pressure (5 kg/cm2).



76


Details Comments

On Site Generation There are four GE Frame 6 powergenerators installed, each with a capacity

of 33 MW.

The units can be fired on gas and dieselfuel. It is understood, that they have also

been fired on propylene in the past.There was a total power failure at the sitein April. It is understood that the naturalgas supply was interrupted and when oneof the operating gas turbines changedover to diesel fuel, excessive flowoccurred and the turbine tripped. Thesecond operating gas turbine then trippeddue to high temperature spread in theexhaust system.

These units are reported to be in generallygood condition.

The gas turbines are located within alarge single building. The number offlanges on the fuel gas lines within the

buildings is limited.

This will minimise the potential for a gasleak from a flange to generate anexplosion within the building.


Maximum demand is 35 MW, with currentsite demand varying between 28 – 32MW.

This is met by running 2 generators atapproximately 50% capacity.

This will allow one machine to take overfull load in the event that the othermachine trips.

Distribution Power is generated at 11 KV in the maingenerators, then stepped up to 33 KV.

There are also 3.3 KV and 415 Vdistribution systems.

Distribution is via a secondary selectivesystem.

There is a load shedding system coveringthe site.

High voltage switchgear is SF6 type, LVswitchgear is vacuum type.

Some simple, low voltage, extensions tothe system have been made to assist withmaintenance and routine work activities.

A single transformer failure should notresult in a power failure within the site.

Interior of gas turbinebuilding



77


Details Comments

EquipmentProtection

• Fire walls are installed betweentransformers.

•

Carbon dioxide systems are installedon the gas turbine generators.

EmergencyGeneration

Emergency power is provided by 4 dieselgenerators, each with a capacity of 2 MW.

These have black start capability and feedthe 3.3 KV system.

The emergency generator provides powerfor:

• Control panel, lube system pumps andfin fan coolers for a gas turbine.

• An instrument air compressor.

• Hot flush system for the polyethyleneplant Plus other critical duties.

6.5.5. Hot Oil

A hot oil system is installed in the PE plant.

6.5.6. Air


Details Comments

No. of Compressors There are 5 electrically driven centrifugal,oil free, air compressors.

A new unit is in operation to replace oneof the original units which has beencannibalised for spares.

Capacity • 4 Elliot machines, each rated at 6,800Nm

3/hour at 8 kg/cm

2 g.

• 1 Ingersoll Rand machine, rated at7,505 Nm

3/hour at 8 kg/cm

2 g.


3 Units are required for full operation.

The air compressors supply plant andinstrument air and also provide a feed tothe nitrogen generation unit.

When all process units are in fullproduction, there will be no standbymachine.

Air Treatment: Air driers are installed for the instrumentair system.

Back-up Facilities Air receivers provide buffer capacity of 15 – 30 minutes for the instrument air supply.

In addition, some plants have smallindependent instrument air compressors.

This represents a satisfactory level ofback-up.



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6.5.7. Nitrogen

Brief details are given below.

Details Comments

Type of Supply The original system comprised an AirProducts cryogenic nitrogen unit.

The air dryers for the unit havepreviously been ineffectual, allowingmoisture to pass with subsequentfreezing in the cryogenic unit. Since thetakeover of the site by Indorama, themolecular sieve has been replaced andthe unit is reported to be workingsatisfactorily.

A new nitrogen unit was ordered from theSuzhou Oxygen Plant Company (SOPC),China. Some equipment items for theunit have been purchased directly byEPCL rather than sourced throughSOPC. Both units are now operational.

Whilst this may not be a company widelyknown in the West, they are reported tohave built over 600 units worldwide.

Unit N2 LiquidNm

3/hr

N2 GasNm

3/hr

AirProducts

390 3,400

SOPC 450 1,800

Storage There are 3 liquid nitrogen storage tankseach with a capacity of 175 m

3.

Facilities are installed to provide 6,400m

3/hr. of vaporisation capacity.

There are also facilities to load/unloadliquid nitrogen and fill nitrogen cylinders.

6.5.8. Flare

The plant has three main flare stacks and a burn pit (to burn heavy waste from the olefinunit), details of the flare stacks are given below:

• FS1 (76.2m high) – covering the olefins plant and utilities. In line with normal practice,

there are two separate flare headers. One for cold gases, the

second for wet gases. By separating the two gas streams, ice plugs(which would occur when wet and cold streams meet) are avoided.

• FS2 (76.2m high) – covering the polypropylene and polyethylene plants.

• FS3 (25 m high) – 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.

6.5.9. Effluent Treatment

The storm water system is largely open and underground sections have gas seals to preventthe movement of flammable gases through the drain system. The seals are vented toatmosphere 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 fittedwith 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.

The system has segregation between the storm water and oily-water drainage systems withall oily drainage directed through to a proper drainage system in the water treatment area.



79


Effluent clean up consists of:

• Equalization

• Neutralisation

• Coagulation

• Flocculation

• Dissolved Air Floatation

• Clarification

A separate caustic treatment unit is installed.

6.5.10. Incineration

Two incinerators are installed:

• Polymer incinerator 5,061 kg/day capacity

• Back-up incinerator, sludge waste 360 litre/hr; solid waste 50kg/hr.

6.6. 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:

Manufacturer

Olefin Plant – Cracked Gas Compressor Elliot/Mitsubishi

Olefin Plant – Propylene and Ethylene RefrigerationCompressors

Elliot/Mitsubishi

Effluent treatment plant



80


Manufacturer

Power Plant – Gas Turbine Generators GE (Frame 6)

Polypropylene Plant – ExtrudersPolyethylene Plant - Extruders

Further details of equipment maintenance are given in section 7.3.



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7. Administration

7.1. Organisation

Since the takeover of EPCL by Indorama, many of the original NNPC staff have left. The

senior management now consists largely of Indian ex-pats. The staff at the time of thetakeover 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 unitsand there were no significant redundancies that might have triggered resentment against the

company management.

EPCL intends to recruit local staff, as far as possible and training programmes have been

established.

The Managing Director of EPCL has three main functions reporting to him:

• Finance and Administration

• Commercial

• Site

Site operations are under the control of the Technical Director. The key departmentsreporting to him are:

• Olefins

• Polymers

• Offsites/Utilities

• Maintenance

• Technical Service

• Health, Safety and Environment (HSE)

The HSE function, in line with good practice, reports directly 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 andincrease in expenditure on new utilities, replacement olefin plant cold box, etc.

Indian personnel work a three month period at the site followed by one month leave.

The site has achieved certification under ISO 9001; ISO 14001 and OSHAS 18001.



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7.2. Operations7.2.1. Process Operations

Brief details of the operations group are given below:

Details Comments

Performance The facilities now have an availabilityapproaching 100%. But throughput maybe limited by shortage of feedstock.

There was a total shutdown in Februarywhen a power failure at the Agip plantsupplying EPCL suffered a power failure.

Coincidently, there was a power failure atEPCL at the same time, resulting in ashutdown of the polymer units.

Operation is becoming more stable with 1or 2 "First Intervention Reports" (processupsets).

On stream time in the polyethylene planthas increased as a consequence of a newmechanical seal on the reactor agitator.

There have been several forcedshutdowns of the polypropylene plant butmost downtime on both units is planned.

Organisation andStaffing Levels

The operational activities are splitbetween three main groups:

• Olefins (sub dived into hot and coldsections).

• Polymers (subdivided intoPolypropylene and Polyethylene &

Butene)• Power Utility and Offsites.

Each unit has a plant manager andproduction manager (working days), plusshift teams as follows:

Whilst most of the supervisors andsenior personnel are Indian ex-pats. Atoperator level, Indian personnel areincreasingly being replaced with localstaff.

O l e f i n P l a n t

P o l y p r o p y l e n e

P o l y p r o p y l e n e /

B u t e n e 1

P o w e r

U t i l i t i e s

O f f s i t e s

Shift

Engineer

21 1 2 1 1

PanelOperator s

4 2 3 1 1 1

FieldOperator s

8 5 8 1 4 22

1 Shift engineer and assistant, theolefins plant is split into hot and coldsections.

2 Plus one field operator at NNPC



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Details Comments

Outside day working hours, there is a shiftmanager in charge of the site.

This will ensure a good level ofcommunication and control in the event

of a major incident. In the absence of anominated individual, confusion canarise over who takes initial charge of anemergency and who has authority toshut down the plant.

The site has four shift teams working athree shift system.

8 hour as opposed to 12 hour shifts willreduce the level of fatigue faced by shiftpersonnel, particularly during hotweather.

Indian operators work 12 hour shifts. As the local and Indian personnel workdifferent shift patterns, shift hand overswill be staggered and not all personnelwill handover at the same time.Provided hand over procedures areproperly handled this should provide a

better level of continuity than allpersonnel changing shift at the sametime.

Local operators work a 7/7/10 hour shiftpattern.

This unusual arrangement is used tominimise the risk to local personnelwhen travelling to the site outside normalworking hours.

Most operators are understood to be inthe age range of 20- 55.

There will not therefore be a suddenlarge reduction in the overall level ofoperating experience in the near futurebut some senior personnel will beretiring.

Warehouse activities (bagging, fork lifttruck driving, etc.) will be largely

performed by contractors under thesupervision of EPCL staff.

This is a common procedure in polymerand other plants with large solids

warehouses.

Budget Budgetary pressures were apparent whenNNPC were the operators of the plant.There now appears to be significantlygreater resources available.

Training EPCL now have a training departmentwhich coordinates training across all partsof the organization.

Trainees will be college graduates with ascience or chemical engineering diploma.

Recruitment from the local area helps toreinforce good relationships with thelocal community.

The recruitment process includes a

written test.Trainees will undergo a mixture ofclassroom and on the job training lastingapprox. 18 months. Progress ismeasured by a mixture of continuousassessment and interviews but not writtentests.

This will ensure that all recruits have an

adequate command of the Englishlanguage.

Operators will initially be trained for asingle operational role on one unit but asthey gain experience will train in a numberof positions.

The recruits from 2006 are now fullytrained field operators and are taking overpanel operating positions.



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Details Comments

A process simulator is available in thetraining centre but has not been fully

configured.

This is a basic simulator and consideredto be of very little value for training. An

improved version of the simulator maybe provided in the future.

Experience Most, but not all, operators are graduates.

For more senior positions, including paneloperators and above, EPCL areappointing experienced processoperators, many are Indian ex-pats.

The Ex-pats are being replaced as localpersonnel gain competence.

Local operators have either been trainedby EPCL or were recruited from otherprocess facilities.

Most operations personnel are under 40and staff turnover is low. There is now apool of trained field operators with thecapability to become panel operators.

Few of the personnel from NNPC arenow on site.

Previously, there were a number ofRomanian nationals who had senioroperating positions and had worked at thesite for a number of years. Currently only1 remains, he is now the olefins plantmanager.

Documentation:

Standard OperatingProcedures

Operating procedures have been totallyrevised since Indorama took over the site. A further upgrade has taken place toensure all documentation complies withISO 9001 requirements.

Checklists Checklists have been developed for

activities such as start-up of fired heaters.

Log sheets are completed by fieldoperators twice per shift.

The use of checklists for start-up can be

useful and is widely practiced. Forexample to ensure that fired heaters andboilers are purged before firing and forensuring that lube oil systems arefunctioning before compressors arestarted.

Updating All Process and Instrumentation Diagrams(P&IDs) are reported to be up to date.

As stated above, the operatingprocedures were revised when Indoramatook over the site and have been furtherrevised to comply with ISO 9001requirements.

EmergencyResponseProcedures

The emergency procedures have beenrevised but are not in a "short format".

The procedures examined for the olefinplant were comprehensive for thedifferent scenarios but are up to 12pages long. All actions by all operatorsare recorded in the same document.Information might be more accessible ifthe information was re-organised so thatthe actions of each individual operatorwere more clearly identified.

Some emergency shutdown training takesplace but this appears to be classroombased and some scenarios are simulatedby temporary changes to the DCS.

Under emergency conditions operatorsmay react in unexpected ways andregular field simulations are oftenconsidered a helpful way of reducingoperator error. Without this operatorsmay be confused as to the location of

the critical valves and other equipment.



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Details Comments

The recommendation from 2006regarding Emergency Response

procedures has not yet been addressed.

Following discussions with the plantmanager more complete implementation

is expected in the future.Process Upsets A reporting procedure for process-upsets

is being developed. The first stage is thecompletion of a "First Information Report".

After investigation a "Facts and AnalysisReport" is produced with lessons learned.

A previous survey recorded that all alarmsare recorded on the DCS system and noproblems with alarm flooding have beenreported.

A number of companies haveexperienced problems, with "alarmflood", during major incident. Thisresults in literally hundreds of alarmsbeing activated within a very short spaceof time. When this happens, the sheervolume of alarms makes it difficult foroperators to follow the exact sequenceof events. Alarm management systems

assist by filtering out the less importantalarms.

Communications/Shift Handover

Shift logs are maintained by the shiftengineer and panel operators. Thecondition of the plant is discussed by theincoming and outgoing supervisors bothincoming and outgoing personnel sign thelog book.

It is often considered advantageous forboth the outgoing and incomingsupervisors to sign the log book toensure that there has been a thoroughexchange of knowledge.

As the local and Indian personnel workdifferent shift patterns, shift hand overswill be staggered and not all personnelwill handover at the same time.Provided hand over procedures areproperly handled this should provide abetter level of continuity than all

personnel changing shift at the sametime.

In each plant, there is a log book for eacharea. Field operators hand over in theirrespective shelters.

A better alternative, in most cases,would be for the field operators to walkround their area as part of the handoverprocess.

7.2.2. Control of Maintenance


Overview The permit to work system has beenrevised since the 2011 survey andseparate vessel entry and vehicle entrypermits are in use.

Copies of the permits are given in Appendix G.

A plotplan is located in the olefins controlroom showing the locations activepermits.

The permit system will be implementedfor the new projects from the very start ofconstruction.

This is considered a positive featureallowing operations personnel to quicklyidentify the location of active workpermits.



87


A common folder is used for filing allpermits with no differentiation betweencontinuing and completed work.

This can lead to confusion over thestatus of work and, possibly, attempts tooperate equipment not yet fully repaired.

Permits are individually numbered. Permits which are uniquely numberedare easier to cross check and cross

reference several permits may berequired for one task.

Auditing of the permits now takes place. This is a useful process to ensure thatthe permit system is operating asplanned.

IsolationProcedures:

A LOTO system is now in place coveringinstrument and mechanical maintenance.

Mechanical Valves closed for isolation duringmaintenance are now reported to betagged and padlocked. Where pipeworkis opened blinds are installed.

The use of tags and padlocks to ensurethat valves is considered good practice.

Casing blinds (to fit inside pumps wherethe casing has been removed) are

available for some situations.

Installation of blinds in the suction anddischarge lines of some pumps can be

difficult. However casing blinds areunusual and their effectiveness isunknown.

Electrical Electrical isolation is achieved by "rackingout" electrical equipment.

This will provide effective isolation butthe use of a padlock on the isolatorhandle would represent an additionalprecaution against errors. The sitemanagement are currently reviewing theadequacy of the existing system.

Instrument Since the 2011 survey, the trip by passprocedure has been revised and newbypass registers have been developedand will soon be in use in all the processunits.

Whilst this is an improvement on theprevious system, the new proceduredoes not comply fully withrecommendation 11-04.

There may also be confusion with regardto bypasses on standby equipment(where the bypass needs to be active toavoid the, non-operating, standbyequipment from causing a shutdown).

7.3. Maintenance

7.3.1. 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 thefacilities in a series of TAMs and conditions are much improved.

Brief details of the maintenance function, known as Central Engineering Services, are shown

below:

Details Comments

Performance Plant reliability is now 99 – 100%. Figuresfor 2012 are shown below.

The represents a huge improvement overthe last few years when the plant wastaken over from NNPC.



89


Details Comments

Budget

No budgetary constraints were apparent.Training EPCL now have a training department

which coordinates training across all partsof the organization.

There is a training facility at the site withan apprenticeship programme. Initially,EPCL recruited experienced personneland many of these are still on site.

Additional specialist training is providedwhere appropriate, for example for thenew DCS systems.

Experience EPCL has employed experiencedmaintenance personnel. Additionaltraining is provided where required.

There are also a number of Indian ex-patpersonnel, generally at supervisor leveland above.

Average age is approximately 40, with thelocal workforce generally being at theyounger end of the age range.

Experience levels are reported to beadequate and staff turnover levels are lowenough to prevent a drain on theresources available.

Philosophy When EPCL was owned and operated byNNPC, there was a severe shortage offunds resulting in a backlog ofmaintenance. Since then, EPCL haveinvested significantly in maintenanceactivities.

Since the plant was taken over byIndorama, there have been 3maintenance turnarounds:

TAM 1Major turnaround in 2006(USD 58 million)

TAM2A

26 day turnaround in May2008

TAM2B

10 day turnaround inNovember 2008

Total cost of TAM 2 was USD72 million

TAM 3 22 day turnaround in March2010 (USD 3.2 million)

An example is the decision to purchase anew cold box for the Olefin plant, eventhough repairs to the existing boxappeared to be satisfactory.

The main activities in TAM 3 were:

• Migration of all DCS systems to the

latest version• Remove damaged cold box and

install replacement

• Change internals in column C2

• Replace absorbent in the H2 PressureSwing Adsorption (PSA) system.

TAM 4 will take place in February 2013and last 22 days. The main activities willbe:

• Overhaul of the cracked gascompressor

• Overhaul of Boil Off Gas compressor

• Cleaning of 45 tube bundles

• Replacement of 4 tube bundles

• Opening of 7 columns• Statutory inspection of 3 boilers

.



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Details Comments

Maintenance is largely preventive andpredictive, together with "LLF" (Look

Listen Feel) activities, coupled with dailychecking of key parameters on keyequipment.

LLF activities would often be consideredas an operators function and it is a little

surprising to find a significant proportion ofmaintenance activity dedicated to this typeof activity.

Planning The ORACLE Computerised Maintenance

Management System (CMMS) has beenin use at the site for 18 months.Previously, MAXIMO was used.

EPCL are preparing SMP (StandardMaintenance Procedures) for manyroutine activities. More than 700 SMPshave been developed and the process islargely complete.

For standard activities, these includeJSAs.

Documentation Only maintenance records since ORACLEwas installed are in the system.

Earlier records are either available inMAXIMO or as hard copies. The lack ofinformation available in ORACLE could

hinder fault finding and reliability studies.However, it would be a major activity tomigrate the plant maintenance historyentirely onto ORACLE.

Mechanical Vibration monitoring systems (BentleyNevada 3300 series) are installed onlarge rotating equipment items such as:

• Main compressors in the ethyleneplant (Bentley Nevada 3500 series)

• Boil Off Gas Compressor

• Gas turbine generators.

• Instrument air compressors (4 units)

• Reactor feed pumps (3 units)

These systems are being replaced by3500 series equipment.

Vibration trips are installed on the gearboxand motors of the cooling tower fans.

New data capture type vibrationmonitoring and analyser (SKF CMXSeries) equipment has been purchasedand technicians trained in its use.Vibration monitoring is performed atintervals as shown below:

The increased use of vibration monitoringsystems has resulted in the identificationof a number of "bad actors"

Equipment CoveredVibration

Monitoring

A Equipment with:

• High capital cost• Impact on

production

• Impact on safety/environment

Weekly

B Equipment:

• On standby

• More than 22 kW,and

• Operating above2,800 rpm

Fortnightly



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Details Comments

C Equipment:

• On standby,

• More than 22 kW,and

• Operating between1,400 and 2,800rpm

Monthly

D Balance of equipment Whenrequired

One extruder in each of the polymerplants has been replaced. The originalsurviving extruder on each plant will bereplaced in the future.

An in house lube oil testing programme

has being set up with regular checks onmoisture, viscosity and particles. Ifproblems are suspected, lube oil sampleswill be sent for particle size analysis.Ferrography is performed during

turnarounds if considered necessary.

There is some equipment balancingcapability at the site but larger itemswould probably have to be returned to the

manufacturer for balancing.

Previous problems with the olefin plantcompressors were as a result of solidsdeposition on the rotors. There were also

initial problems of high bearingtemperatures have now been resolved.

All the rotors have been rebalanced and

some replacement bearings installed.

An additional injection system wasinstalled to suppress polymer formation bythe injection of "Actrene" and this appears

to be successful.

It is intended to replace the tubes in all 6cracking furnaces before the end of 2012.

Tubes in 4 furnaces had been replaced atthe time of the survey.

Inspection of the gas turbines is in line

with the vendors recommendations:• Combustion 8.000 EOH

• Hot Gas Path 24,000 EOH

• Major Inspection 48,000 EOH

Note EOH – Equivalent Operating Hours.

Details of recent gas turbine maintenance

is given in the table below:

Previously, the machines have beenoperating at part load which is reported toincrease the EOH (equivalent operatinghours) of each machine. However this is,at least in part, compensated for by arelatively low number of starts.



92


Details Comments

Last (HGP)Inspection

Date

RunningHours at

Time ofHGP(Hrs)

MajorInspection

Done

RunningHours at

Time of M.Inspection

(Hrs)

23 Oct 12Running

Hrs Inspection Schedule

GT#1 12 Feb 05 50815.4 11 Jun 11 98,776 CI planned in 2014

GT#2 1 Mar 04 48991.0 77,599 MI planned for Dec 12 or Jan 13

GT#3 5 Apr 04 29279.2 48,341 MI planned late 2013 or early2014

GT#4 5 May 05 49278.2 5 Aug 08 78380 101,876 HFPI planned for 2013

1. GT#4 Major inspection was carried out after 28000 hrs running of HGP.2. Based on the observation and experience in MI/HGP & CI GT inspection schedule is prorated.3. Due to low load and clean fuel (GAS) operation HOT GAS PARTS were in excellent condition.

There has been some slippage in datesfrom the information provided at the time

of the 2011 survey.

Control systems for the gas turbines arebeing updated. 1 unit has already beenupgraded from the Mark 4 to Mark 6

system.

All rotors can be balanced on site. Thebalancing equipment is to be modified sothat these items can be balanced. Some

machines can be balanced on line.

Electrical The oil in all transformers underwent aDissolved Gas Analysis (DGA) anddielectric test at TAM1 and no problemswere identified.

DGA may be valuable for determining theearly stages of transformer oil breakdownon large critical transformers.

Dielectric testing takes place every 6months. EPCL now have the capability toperform DGA testing on site. Howeverrecent results have indicatedunrealistically high levels of ethane in allthe transformers with no other indicationof problems. Samples are now being sentto an external laboratory for analysis.

EPCL’s on site equipment cannotmeasure hydrogen levels which theyconsider to be an important parameter.

A Thermographic camera has recentlybeen bought for the site and is used tocheck for hot spots in electricalequipment.

Thermography is increasingly used as aneconomic non-invasive method ofdetecting faults. This may be a usefultechnique for use prior to the TAM toidentify equipment which might be in needof repair.

There are understood to be facilities forrewinding large electric motors in theregion.

Lack of suitable facilities could lead tolong periods of downtime whilst a motorwas shipped abroad to the manufacturer.

Some equipment is obsolete andreplacement is taking place, includingsome DC machines and invertors.Annualearthing checks are undertaken.

Instrumentation Full loop tests are undertaken at eachshutdown. The trip systems are oftenused to shut down units when

maintenance is required.



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Details Comments

The potential for trip testing in operationappears limited. In some cases, there aretwin sections of the plant operating inparallel allowing full loop testing withouttaking the plant out of action.

The example quoted was the extrudersection of the polymer plants which areamongst the least hazardous parts of theprocess.

Full function tests (excluding the finalelement) take place during operation.However tests will take place if a problemis suspected.

Some systems are partially duplicatedwhich would facilitate on line testing.

So far no SIL (Safety Integrity Level)assessment has been undertaken toidentify the overall reliability of the loopsand the level of testing required.

The trip valves on the steam turbines aretested prior to start-up and at shutdowns.

In situations where there is poor steamquality, scale can build up across thevalve seat preventing it from closing in anemergency. However, steam quality atEPCL is reported to be good.

Since Indorama took over EPCL, therehas been considerable upgrading of theinstrumentation, including new DCSsystems in the process units and new F &G panels in some locations. Further F&Gpanels will be replaced.

Spares "Insurance" spares include rotors anddiaphragms for rotors for the olefin plantcompressors and turbines.

Rotors for turbines and compressors haveeither been replaced or refurbished.

Rotors are stored vertically and some arewithin nitrogen containers. 6 monthlychecks are made to ensure that there isstill nitrogen pressure in the containers.

Vertical storage will prevent distortion ofthe shaft in storage, and nitrogen willprotect against corrosion.

EPCL receive "last run" notification fromcomponent suppliers.

"Last run" notification is a warning bysuppliers that this is the last production

run for a component after which theequipment will be considered obsolete.This allows customers to either purchaselarge quantities of spares for future use orlook for replacement equipment.

EPCL state that they have never suffereddowntime due to lack of spare parts.

7.4. Engineering

Brief details of the engineering function are given below:

7.4.1. Management


Details Comments


The engineering team consists of 11people split between Projects andProcess Engineering. Staffing levels arereported to be adequate.

There is understood to be a shortage ofexperienced personnel and EPCL aretrying to recruit ex-pats.

The library function, previously part of thisgroup is now administered by theInspection function.

EPCL have scanned much of thedocumentation and drawings into pdf

format, some are available on the siteintranet.

Data sheets for the olefins unit have beencompletely scanned.



94


Details Comments

The library currently contains 3 copies ofthe site documentation as hard copiesand microfilm. Further copies areavailable in other departments.

In theory it should be possible to recreatethe library in the event of a fire in thedocument rooms but there could bedifficulties in ensuring replacementdocuments are up to date.

Key documents and drawings, such asProcess and Instrumentation Diagrams(P&IDs) are "controlled documents".

The availability of documents on theintranet could lead to numerous copiesbeing printed by members of theworkforce, making it difficult to ensure thatdocumentation is up to date. It wouldtherefore be prudent to ensure that"uncontrolled" copies (those printedwithout authorization) are marked or watermarked in some way. Controlleddocuments need to be clearly marked anda distribution list kept, ideally withsuperseded documents being returned todocument control for recording and

destruction. All the site P&ID’s are now reported to beupdated and available in an AUTOCADformat.

All documentation is reported to be storedin files in 2 separate servers located indifferent buildings.

This greatly reduces the possibility of dataloss.

Training EPCL now have a training departmentwhich coordinates training across all partsof the organization.

A number of graduates were trained aspart of Nigerian government trainingprogrammes. These are now employedby EPCL in engineering roles. Furthertraining is provided where appropriate.

Experience Most personnel currently working on sitein a technical function are wellexperienced and there are no immediatetraining needs.

EngineeringStandards

The facilities appear to have been built toindustry standards. Standards usedappear to have been those of the licensorplus relevant industry standards such as ASME, TEMA, API codes etc. In somecases, standards from the country oforigin may have been substituted, forexample DIN in Germany, BS for the UK.

Mixing of codes on pressure systems canlead to incompatibility.

Whilst accepted industry standardsappear to have been used at EPCL, thereare some obvious differences betweenloss prevention philosophies between thedifferent process units particularly withregard to fireproofing in the processfacilities.

EPCL have developed technicalagreements with the licensors of the majorprocess units:

• Kellogg (olefins)

• Nova (polyethylene)

• Basell – the successor to Technimont(polypropylene)

• IFP(now Axens) - the butane-1 plant

Previously EPCL appointed SK Energy ofKorea (who operates similar olefinsplants) as technical advisors but thisagreement has now ceased.

In addition, EPCL have appointedIngenero (India) to provide real time

monitoring and feedback of processoperations.

Ingenero have been performing thisfunction since 2008.



95


7.4.2. Management of Change


Details Comments

Management ofChange:

The management of change system isdescribed below:

The level of safety review for mostmodifications has increased since the2011 review and Hazard and Operability(HAZOP) Studies are required for mostchanges. There is still no requirement fororganization changes to be treated underthe management of change procedure.

Overview A management of change procedure hasbeen developed by EPCL as part of thenew safety manual and is being used inconjunction with the 320 changes thathave been proposed since the takeoverby EPCL.

Whilst some of the drawbacks identified inthe 2009 survey have been addressed,there still appears to be an issue withensuring that drawings and otherdocumentation are up to date before themodification is considered complete.

One of the fires that occurred in 2011appears to have been due, in part, to afailure to update an SOP (StandardOperating Procedure), following a physicalchange.

The procedure now includes a checklist todetermine if a HAZOP is needed.

A Pre Start-up Safety Review (PSSR) isrequired prior to start-up following anychange.

Whilst the checklist is an improvement onthe previous system, it could still beimproved by implementation of a morecomprehensive checklist.

Hardware changes All physical changes to the site go throughthe MOC procedure.

Process changes Process changes are covered in the MOCprocedure.

Organizationalchanges

There is no requirement for a review ofstaffing levels or organizational changes.

It is becoming increasingly common toreview changes to staffing levels as partof the management of changeprocedures. This should identifysituations where, for example, underreduced staffing levels a person might berequired to be in 2 locations at the sametime during start-up.

7.4.3. Hazard Studies


Details Comments

Hazard Analysis HAZOP studies of all the units wereperformed at the design stage but havenot been reviewed since. Whilst the morecomplex modifications undergo a HAZOPreview, there has not been acomprehensive programme to re-HAZOPall the facilities.

It is prudent to repeat the HAZOP studiesperiodically and in some countries this is alegal requirement. As a pre-requisite anaccurate set of P&IDs is required.

An update of the studies would also be auseful training exercise for operators andmight explain the basis of aspects of thedesign which appear strange, such as theaction on air failure of the vent valve onthe ethylene storage tank (see section6.5.3).

EPCL are considering a re-HAZOP of thesite but no final decision has been made.

A comprehensive review of the site shouldbe undertaken in advance of construction

of the new units.



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7.5. Inspection

Brief details of the inspection function are shown below:

Details Comments


The inspection function now reportsdirectly to the site management. Theorganizational structure of the departmentis shown below.

Currently, there is a vacancy for the Headof inspection. The previous title holder hasreturned to India.

Unlike most locations, there is only limitedinvolvement of outside contractors duringTAMs.

Equipment:

Radiography Radiographic work is contracted out butEPCL staff interpret the radiographic

plates.

It is common practice for radiographicactivity to be performed by a third party

company. EPCL staff are reported towork closely with the 3rd party inspectors.

There have been problems in somelocations in Nigeria with radiographicplates being "ringed" (the same plate usedfor more than one weld). To avoid thisEPCL personnel supervise contractorsand make sure each film has a uniquereference number on the film.

EPCL have their own darkroom and filmdeveloping capability.

Technical Director

Other Departments

Head Inspection

Engineer in Charge

Insp. Engr-1 Insp. Engr-2 Insp. Engr-3 Insp. Engr-4



98


Details Comments

EPCL have developed software forrecording inspection information and

trending.

This will become increasingly useful asmore inspection data is produced.

Pipelines None of the pipelines connected to thesite are the property of EPCL but a Longrang Ultrasonic Thickness programmewas recently completed and no problemswere identified.

Whilst these pipelines are not theresponsibility of EPCL, it is prudent forEPCL to check their condition to ensurepipeline damage to import or exportpipelines will not affect onsite activities.

Boilers and FiredHeaters

All statutory inspections required by theNigerian Authorities are undertaken.

An order has been placed for a remaininglife study of one boiler.

Piping Inspection philosophy is largely based onIndian practice, which generally requiresan internal inspection every 2 years.

Previous plans anticipated future TAMstaking place at intervals of up to 4 years,which is longer than the 2 year figure usedso far. However a 4 yearly inspectioninterval is not out of line with practice insome areas and is a significantimprovement on practice at the site in thepast.

The current inspection procedure is totake 4 separate readings at eachinspection point and record the worstcase.

Unless comprehensive records aremaintained, the same location may not bemeasured on successive inspections andthe trending/remaining life calculationsmay be in error.

The site has investigated a Risk BasedInspection (RBI) approach to inspectionbut details have not yet been worked out.

Whilst companies are increasingly movingto Risk Based Inspections (RBI), whenIndorama originally took over the site, theydid not consider that there was sufficientdata available to implement RBI at thesite.

The fact that RBI is now being considereddemonstrates the increased confidencethat EPCL now has in the mechanicalintegrity of piping and pressure vessels bycomparison with 3 years ago. Howeversignificant work remains before the RBIcan be applied (for example likelycorrosion locations such as stagnantareas and small bore connections need tobe identified).

A programme of inspection of areaswhere insulation is damaged is underway.

Corrosion Under Insulation (CUI) work is

progressing with priority being given topiping sections subject to thermal cycling.

It is claimed that there is no CUI in theoffsites area but the extent of checkingappears limited.

There are a significant number oflocations where insulation is damagedand it would be useful to speed up theinspection process where possible. Thismay not be possible, particularly on lines

which are in constant use. This willidentify areas where under insulationcorrosion could exist and allow remedialaction to be undertaken before theproblem becomes serious.

Thermography has been used to findareas of damaged insulation, which mayindicate the presence of CUI.

Pulsed eddy current technology is beingused.

Whilst this has common application forCUI, there are some areas where it is

ineffective.



99


Details Comments

After inspection, the surface metal is givena protective coating before insulation is

reinstalled.

Progress is slow as the piping must beavailable for inspection. The actual

inspection is performed by cutting holes inthe insulation and taking thicknessreadings. Most forms of non-intrusiveinspection are considered impractical oruneconomic by EPCL. However recent developments in Real Time Radiography

3

might be helpful at the site.

Pressure Vessels Pressure vessels are code stamped andthere are no ASME VIII div 2 vessels onsite.

A significant number of process vesselsand tube bundles were inspected duringTAM1. Those considered less likely tosuffer corrosion were inspected duringTAM2.

The cold section of the olefin plant isconsidered as an area where corrosion isunlikely and has not so far beenexamined. Whist corrosion may be limiteddue to the operating conditions and the

use of stainless steel, this is also the partof the plant which represents the greatestVCE hazard.

Spheres 7 of the 12 spheres at the site have nowbeen internally inspected using ultrasonicthickness measurement, magnaflux andhydrotesting. In addition MagneticParticle Inspection (MPI) has beenconducted on the sphere legs and thespheres have been checked forsubsidence. The legs of one sphere havebeen checked using Pulsed Eddy Current(PEC) technology.

An additional sphere will be internallyinspected during TAM4.

There have been cases, in otherlocations, where the sphere integrity hasbeen adequate but corrosion of spherelegs has occurred, resulting in collapse ofthe sphere. Inspection of the legs istherefore prudent.

An external inspection company hasundertaken acoustic emission testing ofthe sphere legs. In addition, EPCL’s civilengineering department have donefoundation checks on the sphere legs.Neither of these inspections identifiedproblems.

Once each sphere has had an initialinspection a re-inspection is planned at 5to 10 year interval in line with API 576.

This aspiration looks unlikely to beachieved. 5 of the spheres have not beeninternally inspected in the 6 years sinceIndorama took over the site.

Spheres, converted to VC5 use, arehydrotested during the conversion work.

Tanks Wall thickness measurements of tankshave been undertaken.

One of the floating roof and 2 of the fixedroof tanks have been opened for internalinspection since Indorama took over thesite.

EPCL have checked the potential forsome form of inspection of the ethylenetank Whilst a South African companyoffered a solution this involved drillingthrough the tank walls.

It is common practice not to internallyinspect refrigerated tanks unless there areindications of problems.

3 http://www.tuvamerica.com/industry/petrochem/pdfs/POS8024_RTRBrochure.pdf

http://www.tuvamerica.com/industry/petrochem/pdfs/POS8024_RTRBrochure.pdf






101


Details Comments

Positive MaterialsIdentification

Incoming material is tested & certified atthe supplier’s premises by third partyinspection companies such as: Lloyds;Bureau Veritas; etc. before dispatch. Thematerial test certificates are reviewed byinspection department before givingclearance for dispatch.

A Niton alloy analyser is available at thesite but is only used on a random basis.However, there was 100% checking formaterials involved in the VC5 project.

This procedure may have the potential toallow rogue sections of material to enterthe site. Whilst it offers a reasonable levelof protection, it would be preferable to testand colour code each individual alloy

component entering the site. EPCL also intends to perform somerandom checks on alloy material installedon the plant.

Welders Welding is performed by a mixture of inhouse and contract welders. Generallywelders are required to produce testpieces on site but previously issuedcertificates are accepted if they are lessthan 6 months old.

Welds are checked in line with coderequirements and poorly performingwelders are either successfully recertifiedor dismissed.

This differs slightly from common practicewhich generally requires the completion oftest pieces from all welders who have notpreviously worked at the site on a regularbasis.

Lifting equipment colourcoding scheme details



102


Details Comments

Corrosion Protection Cathodic protection is installed on theNGL feed line from AGIP. Soil conditions

on the propylene line from the PortHarcourt refinery do not require cathodicprotection, except in one small sectionwhere a sacrificial anode is installed.

The line to the refinery is understood to bethe property of EPCL, whilst the NGL feed

line is the property of AGIP.

Specific Problem Areas

There were serious corrosion concernswhen EPCL took over the site fromNNPC. Most of these have beenaddressed during TAM 1 and TAM 2 andmechanical integrity of the site is greatlyimproved.

The main issues at the time of the 2011survey were:

• Corrosion Under Insulation (CUI) 250 m of steam condensate line requiringreplacement has been identified in thepolyethylene plant. No significant CUI hasbeen identified in process piping.

• Erosion in cracking furnace tubes Tubes in 4 of the furnaces have beenreplaced. Tubes in the remaining 2 will bereplaced before the end of the year.

7.6. Safety, Health and Environment


Details Comments

Performance The site has recently achieved a 5 starsafety rating in the British Safety Councilscheme with a score of 92.27%.

EPCL has also been award a Sword ofHonour, with a score of 71 out of apossible 72.

Accident trends over the last few yearsare shown below:

There is a much greater awareness ofsafety issues at the site than during the2011. This is reflected in safety meetingsand notices around the site.

There is also a clear understandingbetween occupation safety and processsafety issues.



103


Details Comments

There is now a significant emphasis onprocess safety at the site with regularreviews of incidents world-wide and thepotential lessons that could be learnt byEPCL.

Scaffolding at the site is to a highstandard.

Scaffolding in developing countries is

often very poor and EPCLs highstandards are the exception.

Newly installed processsafety notice in the olefinplant



104


Details Comments

Organisation andStaffing Levels The HSE function reports to the TechnicalDirector.

The department is headed by the siteHead of HSE, with the following groupsreporting to him.

This will allow a clear reporting route, withno conflicts of interest.

The HSE department is split into 4subgroups as shown below:

• Environment (2)

• Safety (5)

• Occupational Health (21)

• Fire (see section 6.7).

In addition to the departmental managerand safety officer, there is a safetyrepresentative on each shift team. Whilstthe reporting route is to the safetydepartment, there have been conflicts of

interests in other locations. This hasresulted in the shift safety officersometimes being more concerned withproduction activities than safety.

In addition, safety ambassadors areappointed in each unit.

Experience The Head of HSE has extensiveexperience of process operations andprocess safety.

All personnel at the site have a diploma insafety.

Acc ident Report ing A comprehensive incident reportingsystem is in place.

Accident statistics are shown above.

Incidents are investigated to identify rootcause. This is undertaken with a formalprocedure rather than one of the softwarepackages currently on the market.

Lessons learned from incidents are widelycirculated.

A review of the fires that have taken placein 2011 indicated that the system isworking well and root causes are beingidentified.

In addition a system, INDSOP, (IndoramaSafety Observation Process) has beendeveloped for safety observations.

This is similar to the Du Pont STOPsystem and aims to encourage reportingof poor safety features on a no blamebasis.

EPCL are considering the use of Leadingindicators to modify the track safetyperformance.

Leading indicators are a relatively newapproach based on tracking factor whichmight lead to a major incident rather thanhistorical data which is more related tooccupational safety.

EmployeeInvolvement

EPCL have worked energetically at the siteand there is now a collective consensusthat safety is a line managementresponsibility with the safety function actinglargely as an auditor and advisor.

This is in line with modern safetyphilosophy.

A new draft safety manual is now beingprinted.

This covers a number of process safetymanagement issues in addition to thestandard "slip, trips and falls" procedures.

There is an interlocking series of 8 safetycommittees, the most senior being the APEX committee, which is chaired by theTechnical Director and involves the headsof departments. There are also individual

plant committees and a contractorscommittee.



105


Details Comments

There is a "safety ambassador" for eacharea.

All new recruits are provided withinduction training by EPCL staff.

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

A recent initiative is the appointment of asenior operations person from each unit toact as a PSM (Process SafetyManagement) coordinator. It is intendedto conduct a process safety audit usingstandard references such as API 750 andCCPS guidelines as a basis.

Housekeeping Housekeeping was generally to a goodstandard.

Occasional examples of missing plugsand missing bolts on Ex rated electricalpanels were noted.

Where this occurs, this is an indicationthat the site conditions are not beinginspected properly before permits are"handed back" at the end of amaintenance activity.

In the worst example noted the situationwas rectified before the end of the survey.

Control of IgnitionSources

Smoking is only permitted in 2 authorisedlocations in the site.

There are reputed to be few smokers in theworkforce No evidence of smoking inunauthorized areas was noted during thesite visit, indicating a good level ofdiscipline.

EPCL do not consider that the use ofmobile phones in hydrocarbon areasconstitutes a hazard.

A number of infringements were noted,even by personnel at supervisor level.Whilst there is disagreement over the sparkpotential of a mobile phone, it would beprudent to prevent their use in hazardousareas. This not only removes a, possible,source of ignition but also avoids asituation where the safety rules start to losetheir clarity and are more likely to bedisobeyed.

All vehicles entering the process areashave flame arresters fitted.

Safety Auditing A variety of safety audits take place:

• Work permit audits These have only been introducedrecently.

• Internal WPCL safety managementaudits

• Check list audits by unit safetyambassadors

These use checklists and are performedby personnel within the unit concerned.

At present, there is no cross auditing.• British Safety Council Audits See above for results on the 2012 audit.

• INDSOP audits conducted by plantmanagers

Currently, there is no central database ofrecommendations.

This may lead to a piecemeal responseand lack of oversight at a senior level.

Contractors EPCL have a contractor safetymanagement programme including areview of contractor safety performance atthe tender stage.

Contractors have safety briefings whenthey first arrive on site. Some contractorshave safety training before arriving onsite.

There is also a safety committeededicated to contractor issues.

Contractor personnel will need a passshowing that they have received safetytraining before being allowed onto site.



106


7.7. Emergency Response


Details Comments


The site fire team consists of:

• A fire chief

• 5 shift fire leaders

• 6 fire fighters per shift

An organization chart is shown below:

The fire team is fully staffed. Additionalpersonnel may be employed when thenew units come on stream.

Experience All the fire fighters have professional firetraining, including fire fighting training priorto joining EPCL.

Training The site has a fire training ground withfacilities for both pool fire and jet firetraining.

Fire fighter competence is likely to erodewithout live firefighting experience and itwould be desirable to resume regulartraining on both pool and jet fires as soonas possible to rebuild experience levels.

Currently, there is no smoke house in thetraining centre.

Training in the use of Breathing Apparatus (BA) will be essential foremergencies in the ammonia plant where

large toxic releases are possible.

EmployeeInvolvement

An auxiliary fire team composed of securityand maintenance personnel has beenestablished. This consists of 6 people pershift.

Mutual Aid A mutual aid scheme is being developedinvolving:

• Shell Petroleum (may not attend allfires).

• Mobil.

• Total/ELF

The inclusion of fire teams from otherhydrocarbon facilities will ensure thatmany of the mutual aid personnel will beexperienced in the specific dangersassociated with hydrocarbon fires.

• Port Harcourt Refinery. The level of operational equipmentavailable at Port Harcourt may be limited.



109


Details Comments

Control of Access tothe Site

There is one main gate into the site. Other gates could be used for emergencyaccess but are generally kept closed.

Physical Precautions

Since the kidnapping incident securityprecautions have been significantlyincreased.

• There is only one point of access to thesite, through a well-guarded gate.

• An access control system featuringswipe cards is being installed.

• The site has been divided into anumber of areas with securityposts between them.

• The original wire fences toppedwith barbed wire have now beenreplaced by a 3m concrete walltopped with an electrified fence.

• A multi camera CCTV monitoringsystem has being installedcovering the entire perimeter.The system has movementdetectors which alarm at thecentral monitoring station.

There are plans to extend thesystem.

All Ex-pat personnel and their families arenow located with the EPCL production site.

Construction areas will be fenced off toprevent construction personnel enteringoperational areas.

This will need to be done with care toensure that the newly installed fences donot block emergency exits and entrypoints to the existing plant.

Additional difficulties may be encounteredin the olefins plant where constructionactivities will take place within an existingplant and which may be operational attimes.



110


8. Fire Protection

8.1. Fire and Gas Detection

Brief details of the fire detection systems are given below:

Details Comments

General Manual Call Points (MCPs) are installedthroughout the site.

Buildings Smoke detection is installed in buildings,including underfloor areas in controlrooms.

Detectors are also installed on the air

inlets for air conditioning systems.

The smoke detection system in the mainoffice building has not yet beenrenovated but the plant based systemsare understood to be operational or under

repair. See below.

Process Areas Gas detectors are installed through theprocess areas.

The gas detectors and panel for thepolypropylene plant have been replaced.Spare parts and vendor support for thesystems in other units is still available.

Heat detection systems are installed insome process areas to activate watersprays.

The level of detectors varies within theprocess facilities reflecting different designphilosophies. Numbers of detectors are:

• Olefins – 36.

• Polypropylene – 45.

• Butene –1 - 18

.

The fire alarm panels have beenrefurbished since EPCL took over the site.

During the survey most of the loops onthe panels had fault status lightsilluminated. This is reported to be duethe fact that the original power supplieshave been replaced. The internal logic inthe system does not recognise the newpower source and hence indicates a fault.

The gas detection system has beenrefurbished over the last few years.

Pellistor type detectors are still in userather than the more modern infra-redtypes. Whilst pellistor type detectors aremore susceptible to poisoning than infra-red types, process materials at the sitedo not contain sulphur – the mostcommon poison.

Storage Areas Within the LPG and refrigerated storageareas gas detectors are installed.

Smoke detectors are installed in thepolyethylene and polypropylene storagefacilities. Fusible plugs, activating delugesystems are also installed.

Gas detectors alarm at 25% and 50% ofLEL but do not initiate any shutdownaction.

The storage area F & G panel wasindicating a fault at the time of the survey.

Utilities The gas turbines are fitted with heat andflame detection systems. These activatecarbon dioxide extinguishing systems.

These systems are reported to beoperational and set to trigger theassociated carbon dioxide system.

Signalling There are local fire panels around the sitewith a repeater at the fire station.



111


Details Comments

Testing Regular testing of the fire and gas systemis undertaken.

Smoke generators are used to test thesmoke detectors, and "black light" torchesto check the flame detectors.

Gas detectors are reported to be tested byaerosol spray at 6 monthly intervals.

The gas detectors are pellistor typedetectors which are relatively oldtechnology. More modern designs, withincreased reliability feature infra-redtechnology.

8.2. Fire Water System

Brief details of the fire water system are given below:

Details Comments

Design Basis

Design fire water requirements for the siteare given below:

Olefins - 1,550 m3/hour.

Polypropylene - 1,470 m3/hour.

Polyethylene/Butene-1 - 1,350 m3/hour.

NGL storage - 1,717 m

3

/hour (based on afire affecting one sphere and cooling ofothers).

Fire water pumps



112


Details Comments

Fire Pumps There are 4 main fire water pumps (2 dieseland 2 electric) each with a capacity of 900

m

3

/hour. A further diesel driven "supportpump" exists.

Pressure in the fire main is designed to bemaintained at 10.5 bar g by 2 jockey pumps(1 diesel and 1 electric) with a capacity of105 m

3/hour.

One of the main fire pumps is currently incontinuous operation as the demand for firewater for duties such as flushing and washdown exceeds the capacity of the jockeypump.

A new 50 m3/hr capacity jockey pump has

been installed but was not commissioned atthe time of the survey.

Once this pump is commissioned, itshould be possible to shut down themain electrical pump.

The diesel fuel tanks are located close to thediesel pumps and could affect them if thecontents spilled and ignited.

Whilst there is diking around the tank,which would contain spillages, highthermal radiation levels could damagethe fire pumps. In similar locations, it iscommon practice to install a firewallbetween the tanks and the pumps.

Fire Water Suppl y Fire water supply is taken from the two55,000 m

3 raw water tanks. With a minimum

of 65,000 m3 reserved for fire water.

The tanks are replenished from theboreholes described in section 6.6.1.

This supply would last for over 24 hours – well in excess of normal fire watercapacity.

Fire Main The fire water ring main is buried andconsists of a looped grid. The main loop is24 inches in diameter, with laterals and

branches ranging between 18 inch and 8inch.

The fire main is externally coated forcorrosion protection.

The fire water lines are reported to havebeen flow tested and found to be ingood condition with no serious

corrosion.

There are approximately 280 twin connectionhydrants at 90 m intervals or, in congestedplant areas, 50 m intervals.

In addition, there are 51 monitors around thesite.

Many monitors are located within poststo prevent impact damage.

Fire hose cabinets and fire reels are installedaround the site.

Some cases were noticed where fire waterhoses were being used for wash down orflushing.

This is considered undesirable.Operations personnel generally do notreplace fire fighting equipment after

use. This can result in equipment beingdamaged or unavailable when requiredfor firefighting.

If firefighting equipment is required forother purposes, it should be undersome form of impairment procedure.

In the Polyethylene plant the fire watersystem has been tied in to provideemergency cooling water for the process.

This should ensure a supply of coolingwater in the event of a power cut, thetemptation to use fire water for routinecooling must be resisted.



113


Details Comments

Testing

The main fire pumps, electric and diesel firepumps are started for 30 - 40 minutes every

15 days.

The reason for the 15 day test intervalis to minimise the number of times that

the electric fire pump is started, as highlevels of current are required when thepump starts.

The NFPA guidelines recommend 30minute testing on a weekly basis fordiesel and 10 minutes on a monthlybasis for electric pumps and this periodshould be used in the future.

The pumps are started by dropping thepressure in the main.

This will ensure that theinstrumentation, as well as the pump isoperational.

The fire pump head curves are checked on asix monthly basis but flow curves are notproduced.

A flow meter is installed in the fire waterreturn line to the fire water tank which willfacilitate fire water pump testing.

It would be prepare actual flow curvesfor the pumps so that performanceacross the entire pump curve can bereviewed, rather than performance at

individual points on the curve.

8.3. Active Systems

The active systems were observed to be in poor condition when the plant was operated by

NNPC but considerable renovation work has taken place since Indorama took over the site.

Details Comments

Buildings A number of fixed systems are installed invarious buildings:

• Laboratory – sprinkler system with a7.74 l/min/m

2 density.

• Control and rack rooms (includingunderfloor areas) – halon or carbondioxide systems.

Some of the underfloor systems incontrol rooms use carbon dioxide whichis an asphyxiant. These are set formanual operation to allow personnel toevacuate the room before the system istriggered.

The halon systems are reported to beinterlocked with air conditioning equipment.Halon systems are slowly being replaced byFM 200.

Halon is now banned under theMontreal Protocol but some developingcountries have a waiver for continuinguse for a period.

In some locations, such as theinstrument rack room in the olefins

room, the doors are open and portablefans installed due to defects in the airconditioning system and this willprevent the extinguishing systemworking effectively. Whilst there will beconsiderable movement into and out ofthe rack rooms during start-up thenormal practice should be to keep thedoors shut.

This has been an on-going problem fora number of years.

Process Areas In addition to hydrants, monitors andextinguishers, a number of systems areinstalled in the process areas:

• Fired heaters have manually operatedsteam snuffing systems. Actuationvalves are located at a safe distance.



114


Details Comments

• A number of hand held steam lances areavailable.

• Automatically actuated foam/waterdeluge systems are installed on vesselsand pump seals in the polymer plants

• Automatically actuated water delugesystems in the polypropylene plant, 4 intotal.

There is a significant variation in thelevel of protection between the olefinand polyethylene plants.

• A manually operated deluge system isinstalled around the refrigerationcompressors in the olefin plant.

Deluge rates are 10.2/l/min/m2 for most

duties and 20.4 l/min/m2 for pumps.

A similar system may be installedaround the cracked gas compressor butthis was not visited during the survey.

• Dry powder systems are installed toprotect the TEAL handling systems inthe polypropylene plant.

These are activated by melt tubes.

Storage Areas All the major liquid storage facilities havefixed fire protection:

• Main atmospheric storage tanks – waterdeluge (varying from 6.5/l/min/m

2 to 12.2

/l/min/m2) fixed foam systems.

• Spheres have water deluge ringscovering the entire surface.

• The refrigerated ethylene tank has awater deluge system with a density of10.2 l/min/m

2. In addition there is an

impounding basin for containment ofethylene spillages which is equippedwith water deluge and fixed foamsystems.

The bladder tanks for the foam systems arereported to have been recently tested andfound to be in good condition and arerechecked at 2 yearly intervals.

Discharge rates appear to be in linewith API standards.

Fire protection systems on tanks arebeing overhauled.

The polypropylene and polyethylenewarehouses have water deluge systems withwater densities varying between 7.8 l/min/m

2

and 18.3 l/min/m2 depending on the area

being protected.

The catalyst storage facility has a delugesystem with a water density of 15.1l/min/m

2.

2 of the sprinkler systems were isolatedat the time of the inspection.

There are a limited number of extinguishersand hose reels within warehouses.

Access to some equipment was limited.

Utilities A number of fixed systems are installed inthe utility areas:

• Motor Control Centres (MCCs) andswitchrooms have fixed carbon dioxideextinguishing systems

The provision of fixed systems againsuggests a difference in designphilosophies between the differentplants. There are no fixed systemswithin the olefin unit, whilst MCCs andswitchrooms in both the polypropyleneand polyethylene plants haveprotection.

• Fixed carbon dioxide systems areinstalled in the 4 gas turbine cubicles.

There were no water deluge systems notedon the main transformers.



115


Details Comments

Testing Fire fighting systems are maintained on anannual basis.

8.4. Passive Systems


Details Comments

Buildings Control rooms for the process units are blastresistant without windows. However in allthe process control rooms visited, the maindoors were open.

The level of blast resistance was notdetermined.

Despite the blast resistant design, theintegrity of the control rooms is reducedif doors are left open.

Process Areas

The level of passive fire protection variesconsiderably with only limited protection inthe olefins plant but a considerably higherlevel of protection in the polyethylene plant.

Again this suggests different fireprotection philosophies between thedifferent licensors and contractors.

The requirement for fireproofing will belower in plants handling hydrocarbonswhich will be in the gas phase afterrelease rather than the liquid phasewhere pool fires might result.

Liquid CO2 system gasturbine



116


Details Comments

Many vessel skirts are fire proofed. Fire proofing has been applied to anumber of vessels where it was

previously missing but there may beothers where fire proofing is stillrequired.

The level of fire proofing on piperacks isvariable with some racks carryingpredominantly hydrocarbon gases being fireproofed in the polyethylene plant. In otherlocations piping with liquid inventories is inun-fireproofed racks.

There is generally little value infireproofing piperacks containing gases.Fireproofing is designed basically asprotection from liquid pool fires.

Fin fan coolers are partially fireproofed butnot to the full load bearing height.

The air flow from the fin fans willexacerbate flames from a pool fire. Theprovision of fireproofing almost to thetop of the fin fan cooler will minimise theextent of damage caused by a pool fireunder the fin fan.

In some places, particularly in the processareas, fire proofing was damaged andrequires repair.

The TEAL (catalyst) storage areas in thepolypropylene and polyethylene plants areconstructed of concrete with dividing wallsbetween the TEAL containers.

In some locations pipe supports on liquidlines were not fire proofed.

Storage Areas Sphere legs are fireproofed.

2 hour rated fire walls are installed in somewarehouses.

Utilities Fire walls are installed between transformerswith stone covered drainage at the base.

2 hour rated fire doors are installed at allsubstations.

In some cases, the height of the firewall might not be sufficient to prevent adegree of thermal radiation exposure bythe adjacent transformer.



117


8.5. Mobile Equipment

8.5.1. Fire Trucks

Brief details of the fire trucks are given in the table below:

No. ofTrucks Details Comments

Combination Truck 3 3,000 l/min water pump at100m head.

4,000 l foam, 8,000 l water and1,000kg dry chemical.

One of these is a new Tata fire truckpurchased since Indorama purchasedthe EPCL.

Multi-purpose truck 1 8,000 l water and 1,0000 lfoam

This is a new truck purchased since the2009 survey. It was originally intendedto deal with bush fires originatingoutside the site. However, bush fireshave ceased to be an issue since theconcrete security wall has been built.

Bronto Skylift 1 Foam/water pump 3,000 1/mincapacity at 100 m head.

4,000 l foam.

Rescue Truck 1 250 Kg of dry powder with adischarge rate of 2.3 kg/sec.

Water Tender 1 7,000 l water A monitor has now been added to this

vehicle.

Transformers separatedby firewalls



118


No. ofTrucks Details Comments

Foam Trailer 1 4,000 l foam.

Dry ChemicalPowder

1 4,000 l water

All fire trucks are reported to be operational.

There are approximately 1,500 portable fire extinguishers throughout the site. These are drypowder, carbon dioxide and pressurised water types. The halon extinguishers at the site

have been taken out of service, as required by the Montreal Protocol, and replaced by

additional CO2 and dry powder extinguishers. Extinguishers are serviced at six monthly

intervals.

The fire station and fire-water pumps are remote from the process area.

Based on the inspection tags on the fire extinguishers, there appears to be inconsistenciesin the frequency of inspection.

8.5.2. 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 has been installed to

provide rapid refilling of fire trucks, together with a limited stock in drums.

The frequency of testing of foam stocks is unknown.




Appendix AList of Acronyms




A list of common acronyms are given below, many of them may not appear in this particularreport but are include for convenience:

Acronym Descript ion Acronym Descript ion

2-o-o-3 2 out of 3 (instrumentation) ERP Emergency Response Plan

AFFF Aqueous Film Forming Foam ERT Emergency Response Team

ALARP As low as reasonably practical ESD Emergency Shut Down

AMS Alarm Management System ETBE Ethyl Tertiary Butyl Ether

AMS Alpha Methyl Styrene Ex Explosion Proof

ATC Alcohol Tolerant (foam) Concentrate F & G Fire and Gas

BD Bursting Disc FAT Factory Acceptance test

BFW Boiler Feed Water FBD Functional Block Diagram

BLEVE Boiling Liquid Expanding VapourExplosion

FCC Fluidized Bed Catalytic Cracker

BOP Blow Out Preventor FEED Front End Engineering Design

BPD Barrels Per Day FFFP Film Forming Fluoro-protein (foam)

CCR Continuous Catalyst Regeneration(Platformer/Reformer)

FLT Fork Lift Truck

CDU Crude Distillation Unit FMD Flooded Member Detection

CMMS Computerised MaintenanceManagement System

FOC Fibre Optic cable

CO2 Carbon Dioxide FP Fluoro Protein (foam)

COMAH Control of Major Accident Hazards GIS Gas Insulated Switchgear

COTP Captain of the Port (from US 33 CFR154)

GRE Glass fibre Reinforced Epoxy

CP Cathodic Protection GRP Glass Reinforced Plastic

CPT Compliant Piled Tower H2S Hydrogen Sulphide

CRINE Cost Reduction in the New Era (UK) HAZID Hazard Identification

CT Cooling Tower HAZOP Hazard and Operability Study

CUI Corrosion Under Insulation HDS Hydro Desulphurisation

CW Cooling Water HIC Hydrogen Induced Corrosion

DCS Distributed Control System HIPPS High Integrity Pressure ProtectiveSystem

DGA High Integrity Protective Systems HIPS High Integrity Protective Systems

DWT Dead Weight Tonnes HP High Pressure

ECC Emergency Control (or Coordination)Centre

HPVR High Pressure Vessel Rupture

EEMUA Engineering Equipment and MaterialUsers Association

HRSG Heat Recovery Steam Turbine

EIV Emergency Isolation Valve HV High Voltage

EML Estimated Maximum Loss HVAC Heating Ventilating and Air Conditioning





ICSS Integrated Control and Safety System NACE National Association of CorrosionEngineers

IP Impressed Current (Cathodic Protection) NDT Non Destructive Testing

IS Intrinsically Safe NFPA National Fire Protection Association

ISGOTT International Safety Guide for OilTankers and Terminals

NGL Natural Gas Liquids (C2-C4)

ISRS International Safety Rating System NOC No Objection Certificate

JT Joule Thompson (Valve) NORM Naturally Occurring Radioactive Material.

KPI Key Performance Indicator O & M Operation and Maintenance

LAHH Level Alarm High OEM Original Equipment Manufacturer

LEL Lower Explosive Limit OPC OLE for Process Control

LNG Liquefied Natural gas (C1) OTN Open Transport Network

LOPA Layers of Protection Analysis P&ID Process and Instrumentation Diagram

LOPC Loss of Primary Containment PAGA Public address and general alarm

LOS Line of Site PCB Poly-chlorinated Biphenol

LOTO Lock Out Tag Out PCS Process Control System

LP Low Pressure PDCS Power Distribution Control System

LPG Liquefied Petroleum Gas PFD Probability to fail on demand

LSA Low Specific Activity (Scale) PI Polarization Index

LTA Lost Time Accident PLC Programmable Logic Controller

LTI Loss Time Incident PLET Pipe Line End Termination

LTI Lost Time Injuries PMI Positive Materials Investigation

LTSA Long term Service Agreement PML Probable Maximum Loss

LV Low Voltage PSA Pressure Swing Absorption

MAS Maximum Amount Subject PSSR Pre Start-up Safety Review

MCC Motor Control Centre PSV Pressure Safety Valve

MDEA Methyl Di Ethanol Amine PTW Permit to Work

MFL Magnetic Flux Leakage QHSE Quality Health, Safety and Environment

MMS Machine Monitoring System QRA Quantitative Risk Assessment

mmscfd Million Standard Cubic Feet/Day RAS Radioactive Source

MOC Management Of Change RBI Risk Based Inspection

MOL Main Oil Line RLA Remaining Life Assessment

MOV Motor Operated Valve RO Reverse Osmosis (Desalination)

MPI ROV Remote Operated Valve

MSF Multi Stage Flash (Desalination) ROV Remotely Operated Vehicle

MTBF Mean Time Between Failures RTDB Real time database

MTTR Mean Time to Repair RTU Remote Termination Unit





SAT Site Acceptance Test SRB Sulphur Reducing Bacteria

SBM Single Buoy Mooring SSSV Sub Surface Safety Valve

SCADA Supervisory Control and Data Acquisition System

TLP Tension Leg Platform

SCC Stress Corrosion Cracking TPD Tonnes per day

SDH Synchronous Digital Hierarchy UF Urea Formaldehyde

SF6 Sulphur Hexafluoride UFL Umbilical Flow Line

SHE Safety Health & Environment UPS Uninterruptable Power Supply

SIL Safety Integrity Level UT Ultrasonic Thickness (Measurement)

SIS Safety Instrumented System VCE Vapour Cloud Explosion

SOLAS Safety of Life At Sea VDU Vacuum Distillation Unit

SONET Synchronous Optical Network VESDA Very Early Smoke Detection Apparatus

SPM Single Point Moorings WH Well Head




Appendix CManagement of Change Checklist




Recommendation Descripti on Category

12-01 Rehabilitation Project – Risk Engineering Review Priority

12-02 Controlled Documents Procedural

XX-YY Permit to Work System – Filing Procedural

XX-YY Database of Recommendations Procedural

XX-YY ?????????? Procedural




11-01 SIMOPS (Simultaneous Operations) Priority

11-02 Wafer Valves Priority

11-03 Control of Maintenance Priority

11-04 Trip Bypass Procedure Priority

11-05 Flange Systems Priority

11-06 Maintenance of Drains Priority

11-07 Risk Based Inspection Priority

11-08 Corrosion Under Insulation Priority

11-09 Fireproofing Priority

09-01 Sampling Procedures Priority

09-02 Fire and Gas Alarm Systems Priority

09-03 Control Room Doors Priority

09-04 Urea Formaldehyde Foam (Cold Insulation) Priority

09-05 Document Control Priority

09-06 Operator Emergency Training Priority

09-07 Permit to Work (PTW) System Priority

09-08 Isolation for Maintenance Priority

09-09 Electrical Integrity Priority

09-10 Trip By-Pass Procedure Priority

06-01 Fire Detection/Protection Impairment System Priority

06-02 Job Safety Analysis (JSA) Priority

06-03 Under Insulation Corrosion Priority

06-04 Housekeeping Priority

06-05 Offsites Area Priority

06-06 Organization – Engineering Function Priority

06-07 Inspection - Hoses Priority

06-07 Positive Materials Identification Priority

06-08 Operator Emergency Procedures Priority

06-09 Permit To Work Priority




06-10 Management of Change Priority

06-11 Emergency Plan Priority

06-12 Asset Ownership of Fire Fighting Equipment Priority




Appendix DOrganizational Change Guidance




Appendix ESample Fire Fighting Pre-plan




Reproduced with Permission of

Resource Protection International

Phone (44) (0) 1296 399311

Fax (44) (0) 1296 395669

Email [email protected]

mailto:[email protected]

mailto:[email protected]




Appendix FPlotplan




Appendix GPermit to Work Forms