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 Eleme Petrochemic al Company Lim it ed 8 th  to 10 th  June 2009 88 Leadenhall Street London EC3A 3BA England Tel: +44 (0) 20 7623 1819 Fax: +44 (0) 20 7623 1817 Registered Office: Essex House, 12-13 Essex Street, London WC2R 3AA Registered in England No. 1994696 Charles Taylor technical Limited is an appointed representative of Charles Taylor Consulting plc which is authorised and regulated by the Financial Services Authority  A division of Charles Taylor Consulting plc
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Eleme Petrochemical Company Limited

8th to 10th June 2009

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Insurance Survey of,

Eleme PetrochemicalsCompany Limited, PortHarcourt, Nigeria 

8th to 10th June 2009 

Draft

Charles Taylor technical

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Report for

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

Main Contributors

Doug Scott

Issued by

…………………………………………………………Eur Ing Doug ScottB Tech C Eng CSci F I Chem E MEI

Reviewed by

………………… Jeff Ashman BEng (Hon) C Eng MIEE

 Approved by

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

Ch l T l t h i l

Insurance Survey of,

ElemePetrochemicalsCompany Limited,Port Harcourt, Nigeria 

8th to 10th June 2009 

Draft

Charles Taylor technical

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i

Executive Summary

Introduction  

Charles Taylor technical has been commissioned by United Insurance Brokers (UIB) toproduce an underwriting risk survey report, for insurance purposes of the Eleme

Petrochemical Company Limited facilities at Port Harcourt Nigeria.

Significant Changes Since the Last Survey

The site has undergone significant renovation since the last survey in 2006. Therehave been two further shut downs for refurbishment andf improvements after the lowlevel of maintenance during the years of NNPC ownership. A small project has beenundertaken to provide Virgin C5 feedstock to one of the furnaces. There has been anincident involving the Olefin plant cold box but this has been resolved without the

need for an insurance claim.

The plant is operating normally with the main limitation on production being theavailability of feedstock.

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,mostly polymers at Port Harcourt Nigeria. The facilities date from the mid 1990s.

Natural hazards in the area are modest.

The facilities are relatively modern with good spacing between the individual processunits, utilities and the storage area. However, there is an element of congestionwithin some of the process facilities. The level of loss prevention features variesbetween process units, with only a limited number of remote isolation valves on large

process inventories in the ethylene plant.

Storage facilities are generally to modern standards but unusually, for a relativelynew facility, do not have independent high level alarms.

 Administ rat ion

P i t th l f EPCL t I d NNPC i t i d ll ti ht t l

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ii

 Activities in most areas follow accepted industry practice but are, sometimes at anearly stage. For example, the site will use the MAXIMO Computerised MaintenanceManagement System (CMMS) but this is still at an early stage of implementation,

Whilst some updating of procedures and documentation has been undertaken, thereis still room for improvement, even in some of the procedures which have alreadybeen updated.

Fire Protection

The fire detection and protection systems have been overhauled and are largelyoperational. However, a number of defective alarm systems were noted around thesite.

One of the electrical fire pumps was in continuous operation to supply water for washdown and a significant number of fire fighting hoses were being used for operationalreasons.

New investment includes a replacement fire alarm system in the polyethylene plant

and a new fire truck.

In summary, EPCL has vastly improved in terms of mechanical integrety as a consequenceof the capital expenditure mantainence turnarounds since Indorma took over the facilities.The focus now needs to be in improving procedural aspects and ensuring all documentationat the site is updated.

Insured Values

The replacement values for the facilities were estimated by AVC (of the UK) in 2006 to beUS$ 868 million. The property values have not been increased since.

The business interruption sum insured is US$ 83 million with a 12 month indemnity period.

Loss History

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

•  May 2008 – damage to cold box, this was subsequently withdrawn

  June 2009 – loss of production as a consequence of lack of feedstock, currentlyestimated at US$ 4 million.

Loss Estimates

Scenario

PropertyDamage

(US$

BusinessInterruption

(US$Combined

(US$ illi )

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Recommendations for Risk ImprovementTen recommendations were made as a result of the survey:

Recommendation Descripti on Category

09-01 Sampling Procedures Priority

09-02 Fire and Gas Alarm Systems Priority

09-03 Control Room Doors CAPEX

09-04 Urea Formaldehyde Foam (Cold Insulation) CAPEX

09-05 Document Control Human Factor

09-06 Operator Emergency Training Human Factor

09-07 Permit to Work (PTW) System Human Factor

09-08 Isolation for Maintenance Human Factor

09-09 Electrical Integrity Human Factor

09-10 Trip By-Pass Procedure Human Factor

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

Recommendation Summary June 2009

Complet e, 17

No Change, 7In progres s,

23

Withdr awn, 6

Unkn ow n, 5

 

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Overall Presentation Sheet

Natural Perils   3.5 Management   3.5 Fire and Gas Detection   2.8

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

External Exposures   2.6 2.3 Water Supplies   3.0

9 Parameters 2 0 1 0 6 6 Parameters 0 1 2 2 1 4 Parameters 0 0 1 2 1

Inherent Hazard   1.0 Permit to Work System   2.9 Drainage   3.0

6 Parameters 2 1 2 0 0 6 Parameters 0 1 1 0 3 3 Parameters 0 0 0 2 0

Layout   2.8 2.3Process Area

Fire Protection  1.9

2 Parameters 0 0 0 2 0 6 Parameters 0 2 1 2 1 6 Parameters 0 1 3 1 0

Control Systems   2.0 2.3 Offsites Fire Protection   1.7

3 Parameters 0 1 1 1 0 3 Parameters 0 0 2 1 0 7 Parameters 1 1 1 2 0

Process Safety Systems   1.9 1.7 2.0

5 Parameters 0 2 2 1 0 3 Parameters 0 1 2 0 0 3 Parameters 0 1 0 1 1

Loading/ Unloading   N/A Inspection Procedures   2.9Passive

Protection  1.8

4 Parameters 0 0 0 0 0 5 Parameters 0 1 1 1 3 4 Parameters 0 1 1 0 0

Storage   1.5 2.6 Foam Supplies   N/A

5P t 1 2 1 1 0 5P t 0 1 2 2 1 3P t 0 0 0 0 0

Storage areas need some refurbishment Safety procedures are generally to a high stadard.

Limited process safety systems installed but

upgrades being undertaken.

 A new management of change procedure has been

developed but still has a number of drawbacks.

Systems appear to be in good condition

Most porducts are transported by truck in a non

haardous form. A new road tanker unloading facility

has been built with basic facilities.Pipeline systems

were not reviewed in detail during the survey

Inspection Procedures are to a generally good

standard with a well trained and enthusiastic

workforce. Some aspects such as Positive Materials

Indentification could be improved.

The site is moving is considering a move to Risk

Based Inspection

Level of passive protection varies between different

process units

Layout between units is generally spacious. There

are some congested areas within 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

improvied. Routine maintenance issues, such a sthe full implenetation of the MAXIMO planning

system needs

Systems have been repaired and are fully

operational

DCS systems being replaced.

 Although control rooms are blastproofed, the doors

are frequently left in the open position.

 A new technical serivces function has now been

developed.

Systems examined were generally good. However

some unsealed penetrations through dikes in the

LPG area were noted.

 All senior management positions occupied by ex-

pats.

Fire detection systems have been repaired and the

system in the Polyethylene plant replaced.

However, a number of falied loops were noted in

different systems around the site.

Protections

Operating Procedures

Hardware Software

Minor exposure from other facilities. There has

been previous unrest with the local community

Operating procedurs are a mixture of orginal and new

procedures. Some operating manuals appear

limitied and full information was not available.

Some undesirable operating procedures were noted,for example the operation of flare drums on manual

control

Fire water system appears in good condition,. There

is still a problem with use of fire water forwashdown,

etc.

 A new permit system has been introduced. And

generally works well but some detailed

improvements are possible..

No problems were noted with drainage during the

survey.

Maintenance

Safety Procedures and

Practices

Management of

Change

Utility Area Fire

Protection

Engineering/

Technical Services

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Latest

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Previous

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Previous

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Previous

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Printer Friendly Versi

© 2008 Charles Taylor technical Overall Presentation Sheet

Natural Perils   3.5 Management   3.5 Fire and Gas Detection   2.8

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

External Exposures   2.6 2.3 Water Supplies   3.0

9 Parameters 2 0 1 0 6 6 Parameters 0 1 2 2 1 4 Parameters 0 0 1 2 1

Inherent Hazard   1.0 Permit to Work System   2.9 Drainage   3.0

6 Parameters 2 1 2 0 0 6 Parameters 0 1 1 0 3 3 Parameters 0 0 0 2 0

Layout   2.8 2.3Process Area

Fire Protection  1.9

2 Parameters 0 0 0 2 0 6 Parameters 0 2 1 2 1 6 Parameters 0 1 3 1 0

Control Systems   2.0 2.3 Offsites Fire Protection   1.7

3 Parameters 0 1 1 1 0 3 Parameters 0 0 2 1 0 7 Parameters 1 1 1 2 0

Process Safety Systems   1.9 1.7 2.0

5 Parameters 0 2 2 1 0 3 Parameters 0 1 2 0 0 3 Parameters 0 1 0 1 1

Loading/ Unloading   N/A Inspection Procedures   2.9Passive

Protection  1.8

4 Parameters 0 0 0 0 0 5 Parameters 0 1 1 1 3 4 Parameters 0 1 1 0 0

Storage   1.5 2.6 Foam Supplies   N/A

5P t 1 2 1 1 0 5P t 0 1 2 2 1 3P t 0 0 0 0 0

Storage areas need some refurbishment Safety procedures are generally to a high stadard.

Limited process safety systems installed but

upgrades being undertaken.

 A new management of change procedure has been

developed but still has a number of drawbacks.

Systems appear to be in good condition

Most porducts are transported by truck in a non

haardous form. A new road tanker unloading facility

has been built with basic facilities.Pipeline systems

were not reviewed in detail during the survey

Inspection Procedures are to a generally good

standard with a well trained and enthusiastic

workforce. Some aspects such as Positive Materials

Indentification could be improved.

The site is moving is considering a move to Risk

Based Inspection

Level of passive protection varies between different

process units

Layout between units is generally spacious. There

are some congested areas within 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

improvied. Routine maintenance issues, such a sthe full implenetation of the MAXIMO planning

system needs

Systems have been repaired and are fully

operational

DCS systems being replaced.

 Although control rooms are blastproofed, the doors

are frequently left in the open position.

 A new technical serivces function has now been

developed.

Systems examined were generally good. However

some unsealed penetrations through dikes in the

LPG area were noted.

 All senior management positions occupied by ex-

pats.

Fire detection systems have been repaired and the

system in the Polyethylene plant replaced.

However, a number of falied loops were noted in

different systems around the site.

Protections

Operating Procedures

Hardware Software

Minor exposure from other facilities. There has

been previous unrest with the local community

Operating procedurs are a mixture of orginal and new

procedures. Some operating manuals appear

limitied and full information was not available.

Some undesirable operating procedures were noted,for example the operation of flare drums on manual

control

Fire water system appears in good condition,. There

is still a problem with use of fire water forwashdown,

etc.

 A new permit system has been introduced. And

generally works well but some detailed

improvements are possible..

No problems were noted with drainage during the

survey.

Maintenance

Safety Procedures and

Practices

Management of

Change

Utility Area Fire

Protection

Engineering/

Technical Services

0

1

2

3

4

0

1

2

3

4

0

1

2

3

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1

2

3

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Latest

 Assess ment

Latest

 Asses sment

Latest

 Assess ment

Previous

 Assessment

Previous

 Assessment

Previous

 Assessment

Printer Friendly Versi

© 2008 Charles Taylor technical

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Contents

1.  Introduction 1 

1.1.  The Company 2 1.2.  The Location 2 

2.  Background 4 

2.1.  Insured Values 4 

2.2.  Loss History 4 

3.  Exposure to Perils 6 

3.1.  Fire and Explosion 6 

3.2.  Surrounding Exposures 6 

3.3.  Subsidence and Collapse 7 

3.4.  Earthquake 7 3.5.  Volcano 7 

3.6.  Tsunami 8 

3.7.  Lightning 8 

3.8.  Flood 9 

3.9.  Wind and Storm 9 

3.10.  Vehicle Impact 10 

3.11.  Vessel Impact 10 

3.12.   Aircraf t Impact 10 

3.13.  Riot Strike and Civil Commotion 10 

3.14.  Terror ism and Sabotage 10 

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4.4.  Machinery Breakdown 15 

4.5.  Machinery Breakdown Business Interruption 15 

4.6.  Summary of Loss Estimates 16 

5.  Description of Installation 17 

5.1.  Location 17 

5.1.1.  Meteorological Information 17 

5.1.2.  New Projects 17 

5.1.3.  Turn Around Maintenance (TAM) 17 

5.2.  Product ion Facilit ies 18 

5.2.1.  Process Units 19 5.2.2.  Process Hazards 21 

5.2.3.  Layout 22 

5.3.  Control and Process Safety Systems 27 

5.3.1.  Basis 27 

5.3.2.  Control Room Design 27 

5.3.3.  Emergency Shutdown Systems 28 

5.3.4.  Remote Isolation, Depressurisation and Blowdown 28 5.3.5.  Pressure Relief Systems 28 

5.3.6.  Combustion Safeguards 29 

5.3.7.  Shaft Sealing 29 

5.4.  Feedstock Supply and Product Transfer 29 

5.4.1.  Road 29 

5.4.2.  Pipeline 29 

5.5.  Storage Facilit ies 30 5.5.1.   Atmospheric Storage 30 

5.5.2.  Pressurised Storage 31 

5.5.3.  Refrigerated Storage 33 

5.5.4.  Warehousing 37 

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5.6.7.  Flare 42 

5.6.8.  Effluent Treatment 42 

5.7.  Major Equipment Items 42 

6.   Administration 44 

6.1.  Organisation 44 

6.2.  Operations 44 

6.3.  Maintenance 49 

6.4.  Engineering 54 

6.5.  Inspection 56 

6.6.  Safety, Health and Environment 59 

6.7.  Emergency Response 63 

6.8.  Security 64 

7.  Fire Protection 67 

7.1.  Fire and Gas Detection 67 

7.2.  Fire Water System 68 7.3.   Active Systems 70 

7.4.  Passive Systems 71 

7.5.  Mobile Equipment 73 

7.5.1.  Fire Trucks 73 

7.5.2.  Foam and Dry Powder Stocks 74 

8.  Recommendations for Risk Improvement 75 

8.1.  New Recommendations 75 

8.2.  Previous Recommendations 80 

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1. Introduction

Charles Taylor technical has been commissioned by United Insurance Brokers to producean underwriting survey report for insurance purposes of the Eleme Petrochemical Companyplant at Port Harcourt, Nigeria. Due to time limitations, not all parts of the site were visitedand some information has been taken from other sources, including previous survey reports.

The survey concentrated on Property Damage, Machinery Breakdown and BusinessInterruption risk to the facility.

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

United Insurance Brokers

Marc Perrin Senior Broker

Eleme Petrochemicals Co Ltd.

Deepak Bang Head Commercial

Subhash Chandra Sarkar Head of Olefins Department

S Dave Offsites Manager

 A K Gupta Power Plant Manager

Neerja Gupta Utilities Manager

V K Gurung Security Manager

B N Jha Projects Manager

 A Michinel Technical Services Manager

 A Mohapatra Polypropylene Plant Manager

S Sadmanabham Polyethylene Plant Manager

S B Sagdeo Instrument Maintenance Manager

S H Sircar HSE Manager

 A Verma Inspection Manager

V K Gurung Security Manager

And others

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1.1. The CompanyEleme Petrochemical Company Limited (EPCL) was originally part of Nigerian NationalPetroleum Corporation (NNPC) which is wholly owned by the Nigerian Government.

However, in May 2006, EPCL was sold to Indorama, a multinational company based inIndonesia with interests ranging from petrochemicals, textiles and cement. Timeframe forthe takeover is shown below:

The NNPC organization was centrally controlled, with individual subsidiaries having limitedauthority 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 hasloosened 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 theorganization. Most of the original Nigerian workforce has left EPCL for other parts of NNPC.T i i b i t f Ni i ti l ith th l t i t ti f

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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 take overby 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, approx 15 minutes drive from Port Harcourt, thecapital of Rivers State.

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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 beUS$ 868 million. A number of items commonly included in valuations such as officebuildings, contingencies, debris removal and firefighting expenses have been excluded. Additionally, there is no value for stocks.

 A breakdown of the replacement value is given below:

Unit US$

Ethylene Cracker 284,800,000

Polyethylene 181,700,000

Butene-1 10,500,000

Polypropylene 80,100,000

Polypropylene Bagging 24,200,000

Polypropylene Bagging 10,500,000

Storage Area (Including Pipeline to Refinery) 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

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2.2. Loss HistoryTwo claims have been reported since the 2006 survey:

Date Loss AmountUS$

Details Comments

May 2008 - Damage to Olefin Plant cold box. Thecause has not been positively identified

but is probably due to thermal cracking ofthe cold box during start-ups andshutdowns since the plant wascommissioned.

The claim was subsequently withdrawn.

Repairs were made and a replacementcold box ordered. This has now arrivedon site and will be installed at the nextmaintenance turnaround. The new coldbox is of a more modern design to theoriginal and is understood to be morerobust.

10 Jan 2009 4,000,000 Limitations of feedstock supply. This hasreduced production at the plant and alsocaused an increased cost of working as aresult of increased utility usage per unit

of production.

It is not clear if this loss is covered by thepolicy or not.

 A detailed loss history of the site prior to the take over by Indorama was not provided but thefollowing information is available from previous survey reports and meetings during thesurvey. It is understood that there have been no significant insurance claims at the sitesince commissioning.

Date Event

10 Jan 98

03 Mar 98

23 Apr 98

Bush Fires following Flare Shoot-Outs

13 Jan 98 Minor fire resulting from sparks from welding work, igniting gasoline from a flange being dismantlednearby

22 May 98 Minor fire caused by leakages on Solution Absorber Unit at Polyethylene Plant

17 Jun 98 Minor Fire from Major Leakage of Ethylene from Blanked Flange of Faulty Safety Valve

11 Sept 98 Minor fire following leakage of hot oil from Polyethylene unit DTA Vaporiser Area

20 Sep 98 Major Fire following Ignition and subsequent Explosion of Jerry-Can of gasoline in Natural GasLiquids reception area control room

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3. Exposure to Perils

3.1. Fire and Explosion

Fire and explosion hazards 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.

3.2. Surrounding Exposures

The nearest large industrial site is NNPC’s Port Harcourt refinery (approximately 6 kmaway), there are also some oil production facilities (approximately 5 km away). There are nosignificant industrial activities around the EPCL site and exposure is considered low.

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Local communities extend to the outer perimeter fence in some places. In any event theprocess and storage facilities are located well away from the boundary fences and would notbe exposed to small fires from shanty dwellings, car fires, etc.

3.3. Subsidence and Collapse

No signs of subsidence or collapse were noted during site visits, although there was veryminor damage to some pipe support footings reportedly as a result of erosion from

condensate drains noted in a previous survey.

3.4. Earthquake

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

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

3.5. Volcano

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3.6. Tsunami

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

3.7. Lightning

The Munich Re “World Map of Natural Hazards” ranks the area as Zone 1, with 2 – 6lightning strikes per km2 per year.

There are around 140 days per year and there have been numerous lightning strikes at theplant. At least two have resulted in minor fires.

 Actions taken to minimise the impact of lightning includes ground resistivity surveys.

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

3.9. Wind and Storm

The Munich Re “World Map of Natural Hazards” considers the area to have a mediumexposure to hailstones and low exposure to tornado

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

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3.10. Vehicle Impact

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

3.11. Vessel Impact

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

3.12. Aircraft ImpactThe Port Harcourt international airport handles both fixed wing and helicopter flights and islocated approximately 25 km from the site. There is also a Chevron Texaco support baselocated around 5 km from the site. Flight paths are reported to avoid the EPCL site and noaircraft were noted overflying during the survey.

3.13. Riot Strike and Civi l Commotion

There have been inter-tribal conflicts in the River State in recent years, together with adepressed economy. In consequence some serious anti-oil industry incidents, includingtheft, vandalism and sabotage have occurred. These have primarily affected the upstreamoil industry but the downstream sector has also been affected.

There has been previous resentment by the local community in the past but this has noweased following the increased deployment of armed police and troops within the siteperimeter. This eventually culminated in the kidnapping of a number of Indorama employees

and dependents (including women and children). The captives were released without loss oflife and security has progressively increased ever since. In the near future, it is intended tohouse all Indorama’s ex-pat staff and their families within the production site boundary.

3.14. Terrorism and Sabotage

There is considerable unrest in the Niger Delta region of Nigeria and the Nigerian Military arecurrently conducting operations against armed gangs in the region. There have been a

number of incidents, including kidnapping, shootings attempted invasion of oil industryfacilities, piracy and sabotage.

 A number of EPCL ex-pats and family members were kidnapped in a raid on theaccommodation facilities but subsequently released unharmed. Security at the site, and intransit to/from the site has tightened considerably since that event.

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Exposure Comments

Boilers and FiredHeaters

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

The major risk associated with equipment ofthis type is tube rupture which will generallycause limited damage.

However in extreme situations explosions canoccur causing total destruction.

 A number of tubes have leaked and havebeen sealed off; there do not appear to havebeen any serious incidents associated withtube rupture.

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

•  HP compressors, particularly associatedwith the ethylene plant.

•  Extruders associated with the two polymerplants.

•  Gas turbines.

There is a wide range of incidents which canlead to damage of rotating equipment leadingto varying levels of damage. Under mostcircumstances, damage will be limited to therotating elements of the machine but, inextreme cases, total destruction can occur.

Transformers There are a number of large transformers onthe site Many transformers have fire wallsbetween adjacent units but fixed fire protectionis not installed.

 A fire involving a transformer is unlikely tospread to adjacent equipment, however, in theunlikely event of a transformer explosion, firewalls could fail resulting in additional damageto nearby units.

Others Catalysts In some situations, catalyst life can bereduced or destroyed as a result of processupsets or damage caused by fire or other

perils.

3.16. Construction

Whilst there is currently limited construction work at the site, there has been considerableactivity as part of the TAMs which have now been completed. There have also beenrelatively modest capital projects such as the VC5 project to provide flexibility in thefeedstock.

Future TAMs and projects could result in construction type hazards such as crane collapse,excavation collapse, etc.

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4. Loss Estimates

4.1. Definitions and Loss Scenarios

There are numerous definitions for defining levels of damage. Probable, Maximum Loss(PML), Estimated Maximum Loss (EML), Maximum Amount Subject (MAS) are amongst the

terms in common usage. However, they are defined in different ways by differentorganizations. Definitions used in calculation of EML by Charles Taylor technical are givenbelow:

•  Probable Maximum Loss (PML) – The loss that could occur if the installed process safetysystems and fire protection systems operated as intended once the incident wasidentified. Such events would be typical process plant fires and explosions.

•  Estimated Maximum Loss (EML) – The loss that could occur if process safety systemsand fixed fire protection systems were unable to function as a result of the incident.Such events would be the rare but highly destructive events that can occur in processfacilities, such as detonations, Vapour Cloud Explosions (VCE) and High PressureVessel Ruptures. HPVR.

•  Maximum Amount Subject (MAS) – A catastrophic loss which could result in majordamage, 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 has been calculated, as this is of the greatest significance tounderwriters.

4.2. Property Damage

The following replacement values have recently been estimated by AVC and are used tocalculate the size of loss below.

Unit US$

Ethylene Cracker 284,800,000

Polyethylene 181,700,000

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Unit US$

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

The largest potential loss at the site is considered to be a vapour cloud explosion (VCE), thelargest inventories of liquefied gas in the process area are:

Olefin PlantPolyethylene

Plant

PropyleneRefrigeration

Drum

C2SplitterColumn

C2Splitter

Reboiler

C2

SplitterRefluxDrum

C3Splitter

C3Splitter

Reboiler

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

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80% Damage 40% Damage 5% Damage Total

Overpressure radius, M 125 283 448

Static Loss, US$ Million 29.46 238.68 4.89 273.03

Drift Loss US$, Million 76.07 231.23 3.30 310.60

 After making the following allowances, the loss estimates are given below:

•  Fire following the initial explosion – 10%

•  Damage outside the plot areas – 10%

•  Debris removal – 10 %

•  Fire Fighting – 1%

•  Inflation – 9% (based on 3 years at 3% per annum the loss occurring on the last day of

the policy year, plus a two year rebuilding period).

The loss is estimated at approximately: US$ 435 million.

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

Damage contours are shown below:

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

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4.4. Machinery Breakdown

The largest machine at the site is understood to be the Olefin Plant cracked gas compressor.The replacement value for this unit was not obtained but by comparison with similar sizedplants, a replacement value US$ 17 million in 2006. The well known Nelson-Farr cost indexshows an increase of approximately 20% between 2006 and February 2009. A currentreplacement value of US$ 22 million has been assumed

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

US$ Million

Cost of Machine 22

Damage to Rotating Elements

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

rotor and rebuild the machine)  15.4

Synthesis Gas Compressor 12.6

 Addi tional Costs

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

and 9 month replacement) 3.6

Total 16.2

Destruction of Machine

(100% loss of machine value and 20% cost to strip the machine, replace the

rotor and rebuild the machine)  26.4

 Addi tional Costs

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

replacement) 6.3

Total 32.7

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2. Total destruction of the machine.

The worst case scenario would be total destruction of the compressor with areplacement time in the range 12 to 18 months. The loss would therefore be:

US$ 124.5 million

4.6. Summary of Loss Estimates

Scenario

PropertyDamage

(US$million)

BusinessInterruption

(US$million)

Combined(US$ million)

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

435 166 601

Machinery Breakdown Damage to the rotating elements ofthe olefin plant cracked gascompressor

16.2 13.8 30.0

Complete destruction of the olefinplant cracked gas compressor

32.7 124.5 157.2

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

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5. Description of Installation

5.1. Location

The Eleme Petrochemicals Company Limited (EPCL) production facility is locatedapproximately 15 km to the East of the centre of Port Harcourt.

The site is elevated 15m to 18m above the level of the Bonny River, which runs 5km fromthe site, and there is no history of flooding in the area.

5.1.1. Meteorological Information

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

Topology 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 22°C to 20°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 to November.

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

5.1.2. New Projects

There are no new projects anticipated in the immediate future. However, in the longer term,it is anticipated that additional production facilities will be added in line with the originaldevelopment schedule when the facilities were first constructed. These include an increasein the capacity of the ethylene plant and additional downstream units, possibly:

•  Ammonia

•  Chlor Alkali

•  Ethylene Glycol

•  VCM

The largest recent project was a modification to the plant to allow the cracking of Virgin C5

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•  TAM1 2006 – September 2006

•  TAM2A - May 2008 (26 days), the timing was adjusted to fit a window of opportunitycaused by the failure of the Olefin Plant cold box.

•  TAM2B - November 2008 (10 days), the timing was adjusted to coincide with ashutdown caused by interruptions of the NGL feedstock to the plant. Whilst a fewactivities are outstanding these are process rather than safety related.

Whilst the plants now appear in overall good condition, there are still some poor operational

features, including the operation of flare systems in manual mode and the running oftemporary connections in the polymer plants.

5.2. Production Facil ities

EPCL operate a modern petrochemical complex producing ethylene for the manufacture of

Polyethylene plant – notetemporary c onnections

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 A simple block diagram is given below:

5.2.1. Process Units

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

Designation CapacityTonnes/Year

Licensor Contractor Year Comments

Olefins Plant 300.000 Kellogg"Millisecond"technology

ChiyodaCorporation

1995 Two of the cracking furnaces(including the one converted forVirgin C5 operation) have beenupgraded with “MERT” tubes whichincrease cracking efficiency andincrease the timing betweenshutdowns for decoking.

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Designation CapacityTonnes/Year Licensor Contractor Year Comments

There are 2 extruders each capableof 100% of production. 1 unit isoperational, the other requiresoverhaul following a failure at somepoint in the past. An overhaul isplanned for some point in the future.

Polyethylene 270,000 Nova (Du-Pont)

Sclairtechtechnology

Kobe Steel 1995 This is a medium pressure unit,

operating at approx 145 bar g.270oC. Twin extruders are installed

Currently operating at approx. 60%capacity

There are 2 extruders, each sizedfor approximately 75% of capacity,both are operational.

Butene-1 22,000 Institut Franyaisdu Petrole (IFP)

 Alphabutoltechnology

Kobe Steel 1995

Utilities andOffsites

- ChiyodaCorporation

1995

Infrastructure - Spie Batignolles 1995

Current production figures for the polyethylene and polypropylene plants which consume allolefins from the olefin plant are shown below:

Polyethylene Production

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Polypropylene Production

5.2.2. Process Hazards

•  The main process hazards are associated with a flammable gas release or loss ofcontainment of significant volumes of liquid hydrocarbons. Many of the processing stepsinvolve handling of highly flammable and explosive gases at elevated temperatures andpressures. Transfer of gases and liquids requires the use of rotating machinery, often ofhigh power, which is subject to mechanical breakdown and failure.

•  Most materials in the process are light, flammable hydrocarbons (both gaseous andliquid). A potential exists for flash fires, jet fires and, in some areas of the plant, liquidpool fires.

•  There are a number of spheres and other vessels with the potential for a Boiling LiquidExpanding Vapour Explosion (BLEVE).

•  Sufficient quantities of volatile liquid hydrocarbons (predominantly ethane, ethylene andpropylene) are present to form a vapour cloud explosion (VCE) in the unlikely event of alarge-scale loss of containment. In addition, there are significant quantities ofcyclohexane used as a diluent at high temperature and pressure in the polyethyleneplant.

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•  Refrigerated storage tanks can suffer “rollover” as a result of thermal layering with a

warmer (less dense) layer below one that is colder (more dense). These layers cansuddenly rotate or rollover with rapid vaporization of the warmer layer.

•  High temperature hot oil systems are employed for process heating in the Polyethyleneplant.

5.2.3. Layout

The site is located on level ground totalling 440 ha and is bordered on the south and west by

the Eleme-Okrika road.

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

Details Comments

General The existing process units are located to thesouth of the site.

There is plenty of space for future expansionand the new accommodation facilitiesconstructed at the site are remote from

operational and storage areas.

The Natural Gas Liquids (NGL) pipeline feedingthe site terminates at a custody transfer point ina Nigerian Agip Operating Company (NAOG)terminal at the plant north west corner of the site.

The process and utilities are arranged in 2 rowswest 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 air utilities.

These facilities are on individual plotsapproximately 150m by 250m, with separationby road, approximately 12 m wide.

Much of the area is open, particularly aroundthe main administration building. This will limitthe hazard faced by employees in the buildingin the event of a major explosion. Spacingbetween the various process, utility andstorage facilities is also good, limiting thepotential for domino effects from one areaaffecting adjacent areas. This is, in part, dueto anticipated future expansion at the site,which has not so far taken place.

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Olefin Plant Cold Section

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Details Comments

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 for the

fin fans to affect the extent of the fire.

Within the olefin plant, concrete around someof the minor steelwork supports was damaged,exposing the holding down bolts.

Whilst this does not appear serious, repairsshould be instituted.

Within the polyethylene plant fin fan coolerswere not fireproofed to the full load bearingheight.

The air flow from the fin fans will exacerbateflames from a pool fire. The provision offireproofing almost to the top of the fin fancooler will minimise the extent of damagecaused by a pool fire under the fin fan.

Within the olefin plant drainage points are If the ground were sloped towards these

TEAL Preparation Area in thePolyethylene Plant

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Details Comments

Compressor Houses Within the olefins plant, there are two separatecompressor houses. Both refrigerationcompressors are located within one buildingwith a separate structure for the cracked gascompressor.

The main compressor houses are roofed and

walled around three sides at the upper level.The remaining side is left open to allow accessfor maintenance.

The structures are open on all 4 sides atground level.

Within the olefin plant, the cracked gas andrefrigeration compressors are in separatestructures.

This will allow natural ventilation and prevent

the build up of high levels of gas in the eventof a release.

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

The close location of the lube/seal system tothe compressor could result in damage in theevent of a lube seal fire.

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 in onelocation minimises the likelihood that a gasleak will find a source of ignition.

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5.3. Control and Process Safety Systems

5.3.1. Basis

Brief details are given below:

Details Comments

Configuration: Each plant has a control systemwith separate hard wired ESD

(Emergency Shut Down) system.

Type: DCS (Distributed Control Systems)are installed in all units.

The original DCS systems installedwhen the plant was firstcommissioned are now becomingdated and a programme of updatingis underway. So far thePolypropylene plant and the offsitessystems DCS systems have beenreplaced.

Neither the existing or new plants

have alarm management functions

 A number of companies have

experienced problems, with “alarmflood”, during major incident. Thisresults in literally hundreds ofalarms being activated within a veryshort space of time. When thishappens, the shear volume ofalarms makes it difficult foroperators to follow the exactsequence of events. Alarmmanagement systems assist byfiltering out the less importantalarms

5.3.2. Control Room Design

Brief details are given below: 

Details Comments

Location: Each of the process units has anindependent control room; inaddition there are control rooms for

the power station and the storagearea. 

Construction: Process control rooms are blastresistant structures but appearunpressurised. Whilst automaticdoor closers were originally fitted,these have in some cases been

 All the process control rooms hadthe doors in the open position whichwould negate the blast resistance ofthe structure.

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5.3.3. Emergency Shutdown Systems

Brief details are given below: 

Details Comments

Type:  All units have proper emergencycontrol systems with critical safetyrelated systems fully segregatedfrom the control systems. Theseare hard-wired systems and these

are not dependent upon computersoftware. In some cases, these aretwo out of three (2-O-O-3) votingsystems.

The polymerisation reactions inparticular are exothermic, and havereaction inhibition systems, whichinject chemicals into the reactors tokill the reaction immediatelystopping reaction heat generation.

5.3.4. Remote Isolation, Depressur isation and Blowdown

There are relatively few Remotely Operated Valves (ROVs) installed in the Olefins unit.ROVs are frequently installed in locations, such as pump suctions to prevent the contents ofupstream vessels (such as drums and columns) being released to atmosphere in the eventof a pump seal failure. This issue has been highlighted in previous survey reports and EPCLhave identified 4 locations where ROVs are required. In 2 cases, they have now been

installed.

 An ROV is installed on the feed drum in the polypropylene plant but the cabling is notfireproofed.

ROVs are installed on the spheres and ethylene tank.

5.3.5. Pressure Relief Systems

Brief details are given below:

Details Comments

Configuration: With some exceptions singlepressure relief valves have been

It is difficult to test relief valveswhen the plant is operating when

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5.3.6. Combust ion Safeguards

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

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

5.3.7. Shaft Sealing

Many of the pumps at the site handle liquefied gases and are fitted with double mechanicalseals and seal failure protection.

5.4. Feedstock Supply and Product Transfer

5.4.1. Road

The main products (polyethylene and polypropylene) are solids and packed in bags ontopallets 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 isa basic system with discharge via armoured hoses. A simple earthing system is installed.So far, this has only operated intermittently but in future, it is intended to import 2-3,000tonnes per month and is shown below:

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Product From/To Length Comments

Natural Gas Liquids(NGLs)

Obaifu-Obrikom gasseparation plant.

85 km The NGL and fuel gas line follow a commonrouting.

Fuel Gas Obaifu-Obrikom gasseparation plant.

85 km The NGL and fuel gas line follow a commonrouting.

Fuel gas from this line would be required forstart-up but once continuous operation isunderway, fuel gas for the site can be taken

from the cracking furnace overheads.

Propylene Rich Feed Port HarcourtRefinery.

6 km Currently out of use until the Port Harcourtrefinery FCC is returned to service.

Virgin C5+  Port HarcourtRefinery

6 km

Cracked C5+  Port HarcourtRefinery

6 km

5.5. Storage Facili tiesThe site contains atmospheric, pressurised and refrigerated storage.

5.5.1. Atmospheric Storage

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

No.Installed Stored Material Capacity (M3) 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

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Details Comments

Fire Protection  All the tanks are fitted with semi-fixed foam systems and waterdeluge.

Drains Roof drains on the floating rooftanks are normally left open.

This will avoid a build-up ofrainwater on the tank roof whichcould cause the roof to sink.However any leakage from the roofdrain line could lead to the

discharge of the tank contents intothe diked area.

The dike drains are also left open inthe rainy period.

This will avoid situations wherealmost empty tanks will float if thereis a serious build up of rain water inthe dike. However, it does raise thepossibility that any spillage ofhydrocarbons will not be contained,perhaps leading to runninghydrocarbon fires along the drainssystem to the effluent treatment

plant. Such fires could lead toignition of nearby vegetation, thishas happened in other locations.

5.5.2. Pressurised Storage

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

No.Installed Stored Material

Capacity(M

3) Comments

3 NGLs 3,809 These tanks operate -5oC and are thermallyinsulated. The insulation appeared in goodcondition.

2 VC5 2,760 These were previously polypropylene tankssimilar to those described below. They wereconverted to operate at -5

oC and have been

thermally insulated

2 Propylene feed (from Port HarcourtRefinery).

2,760

2 Butene (Intermediate Product).

3 Purified Propylene. 2,239

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Further details are given below:

Details Comments

Diking The tanks are located in slopedconcrete dikes with. The masticused to seal the expansion gaps insome dikes has largely perishedand, in its current condition, the dikemay leak.

The dike however would allow liquidspillages to be contained under thesphere and a large spill, withsubsequent ignition could result in aBLEVE.

Pumps Pumps are located remotely fromthe spheres.

Instrumentation The tanks were not originallyequipped with independent highlevel alarms.

This could allow overfilling, if thelevel gauging system failed.

Liquefied Gas Storage

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Details Comments

Motor Operated Valves ROVs, sample points etc. locatedon the outside of the dike wall,penetrations through the dike wallare generally well sealed but thereare exceptions.

Fire Protection  All the spheres are equipped withdeluge water sprays, operable from

two locations.

This should allow access to a valve

under all wind conditions.

Sphere legs are fireproofed.

5.5.3. Refrigerated Storage

Dikes around LiquefiedStorage Spheres

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Brief details are given below:

Details Comments

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

There is a nitrogen purge throughthe annulus.

There is reported to be someleakage of ethylene through theinner skin of the tank.

Diking The tank is located in a sloped

concrete wall dike, with drainsleading to an impounding basin.

The mastic used to seal the

expansion gaps in the dikes haslargely perished and, in its currentcondition, the dike may leak.

Pumps Pumps are located remotely fromthe storage tank.

Instrumentation The tanks were not originallyequipped with independent highlevel alarms.

This could allow overfilling, if thelevel gauging system failed.

Temperature is controlled via single

Boil Off Gas (BOG) compressor,which returns ethylene gas to theolefin unit for re-liquefaction. Whenthe ethylene plant is shut downtemperature is maintained byventing gas to the flare.

 An unusual feature of the tank is the

fact that the flare vent control valvefails closed and in the event of apower failure or other interruption tothe instrument air supply anoperator needs to climb the tankand manually open the bypass.

Fire Protection The tank itself is fitted with a waterdeluge system around itscircumference.

Medium expansion foam and waterdeluge systems are installed tocover the dike area.

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

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Piping Support with RodHanger Missing

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5.5.4. Warehousing 

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

•  Polypropylene - 19,000m2 warehouse

•  Polyethylene - 42,000m2 warehouse.

Both warehouses are sprinklered.

5.6. UtilitiesThe site is designed to be self sufficient in utilities, further details are given in the sectionsbelow. 

5 6 1 Water

Bulk Polymer Storage Silos

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Details Comments

There is also a demineralisation unit to removesediment and ferric ions, plus 2 activatedcarbon filters for potable water.

Cooling Water:  A vent is installed in the cooling water returnline. This is located on the return line itselfrather than on the individual pipes to each cell.

Vents are often installed on the return lines ofcooling water systems to avoid the entry offlammable gases (from heat exchanger leaks)from entering the cooling tower where theymight ignite. The efficiency of the

arrangement installed at the site is not clear,in the case of significant leaks; it may allowgas to be swept past the vent into the coolingtowers.

The original cooling tower internals have nowbeen replaced with polypropylene packing.

Cooling tower fans are reported to haveexplosion proof motors.

This will reduce the likelihood of flammablegas igniting.

The gearboxes and motors have vibration

alarms.

No. of Cells  There are 2 cooling towers, each with 5 cells. All cells are now operational and repairs togearboxes and fans, reported defective inprevious surveys have now been repaired.

Packing in the cells is in relatively poorcondition. Some has been displaced into thecooling water return line and blocked tubes inmany of the exchangers.

No. Normally in use 8 cells should be adequate for full operation but

previously all 10 have been in use.

No. of Pumps 5 electrically driven pumps, each of9,000m

3/hour are installed.

.All are now operational.

No. Normally in use The system is designed for 3 of the 5 pumps tonormally be in use. However currently 4 of the5 pumps are running to a degree of leakage inthe cooling water system.

Boiler Feed Water Treatment consists of:

•  3 Activated carbon filters installed forcondensate treatment.

•  2 Demineralisation beds.

•  3 mixed bed polishers.

In addition to provision of fresh Boiler Feed

The Boiler Feed Water quality has previouslybeen poor on occasions and this may have

contributed to problems with the boiler tubes.Improved chemical dosing and monitoring arenow in place.

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5.6.3. Steam

Brief details are given below.

Details Comments

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

•  3 Boilers each generating 120 tonnes/hour

at 48 kg/cm2.•  6 Cracking furnaces generating steam at

48 kg/cm2 and 109 kg/cm2.

The boilers have been refurbished as part ofTAM 1.

OperatingConfiguration

Steam is provided by the cracking furnaces andthe boilers.

 At low cracking rates all three boilers wererequired to meet steam demand. As demandincreases, more heat from the crackingfurnaces is recoverable as steam and 2 boilers

will be adequate to meet demand. Howevernormal practice is to keep all 3 boilers inoperation at reduced flow rates to allow for thepossibility of a boiler trip.

During periods when boilers are taken out ofservice for statutory inspection, there will beno 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).

5.6.4. Electricity

Brief details are given below.

Details Comments

No. of ExternalFeeders

There is a single feeder, owned by NationalElectrical Power Authority (NEPA) to connectEPCL to the Port Harcourt Refinery. Howeverthere have been problems of reliability and it isnot now used.

Current status of this connect was notdetermined but the main power supply is fromEPCL’s gas turbines.

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Details Comments

The gas turbines are located within a largesingle building. The number of flanges on thefuel gas lines is limited.

This will minimise the potential for a gas leakfrom a flange to generate an explosion withinthe building.

OperatingConfiguration

Maximum demand is 35 MW, with current sitedemand at 19 MW.

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

This will allow one machine to take over fullload in the event that the other machine 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 V distributionsystems.

Distribution is via a secondary selectivesystem.

There is a load shedding system covering thesite.

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

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

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Details Comments

Equipment Protection •  Fire walls are installed betweentransformers.

•  Carbon dioxide systems are installed onthe gas turbine generators.

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

These have black start capability and feed the3.3 KV system.

The emergency generator provides power for:

•  Control panel, lube system pumps and finfan coolers for a gas turbine

•  An instrument air compressor

•  Hot flush system for the polyethylene plant

Plus other critical duties.

5.6.5. Air

Brief details are given below.

Details Comments

No. of Compressors There are 4 electrically driven centrifugal, oilfree, air compressors.

 A new unit is in operation to replace one of theoriginal units which has been cannibalised forspares.

Capacity The machines are each rated at 6,800Nm3/hour at 8 kg/cm2 g.

Operating Configuration 3 Units are required for full operation

The air compressors supply plant andinstrument air and also provide a feed to thenitrogen generation unit.

When all process units are in full production,there will be no standby machine.

 Ai r Treatment:  Air driers are installed for the instrument airsystem.

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

This represents a satisfactory level of back-up.

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Details Comments

 A new nitrogen unit has been ordered fromthe Suzhou Oxygen Plant Company (SOPC),China. Some equipment items for the unithave been purchased directly by EPCL ratherthan sourced through SOPC.

Whilst this may not be a company widelyknown in the West, they are reported to havebuilt over 600 units worldwide. Further detailscan be found at:

http://en.suyang.com.cn/newEbiz1/EbizPortalFG/portal/html/gysy.html?GeneralContentShow_DocID=c373e9087b27eebd8f6bc4f684d8e91b 

Capacity Capacity is 3,400 Nm3/hour of gaseousnitrogen and 390 Nm

3/hour of liquid nitrogen 

Storage There are 3 liquid nitrogen storage tanks eachwith a capacity of 184 m

3.

5.6.7. Flare

The plant has three main flare stacks and a burn pit, details of the flare stacks are given

below:•  FS1 (76.2m high) – covering the olefins plant and utilities (note that there do not

appear to be separate cold and wet sections to the flare which could result in water richstreams in contact with cold streams freezing and causing blockage in the flare lines)

•  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 togetherwith steam coils for evaporation of the drum contents.

The flares and burn pit are located to the northeast of the site with limited potential fordamage to the process or utility systems.

5.6.8. Effluent Treatment

The system has segregation between the storm water and oily-water drainage systems with

all oily drainage directed through to a proper drainage system in the water treatment area.

The storm water system is largely open and underground sections have gas seals to preventthe movement of flammable gases through the drain system. The seals are vented toatmosphere with flame arrestors installed. Whilst the main drainage channels are largelyclear of vegetation in several locations small drains feed into the open drains and these are

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Manufacturer Comments

Olefin Plant – CrackedGas Compressor

Elliot/Mitsubishi The unit is currently operating with the sparerotor installed. An overhaul took place as partof TAM2.

Olefin Plant – Propyleneand EthyleneRefrigerationCompressors

Elliot/Mitsubishi The units are currently operating with thespare rotor installed. . An overhaul tookplace as part of TAM2..

Power Plant – GasTurbine Generators

GE (Frame 6) The units are understood to be in goodcondition with 2 units having hot gas pathinspections in 2004. One unit wasoverhauled in TAM2 and then, I unit will beoverhauled each year for the next three years.

Polypropylene Plant –Extruders

There are 2 extruders each capable of 100%of production. 1 unit is operational, the otherrequires overhaul following a failure at somepoint in the past.

Polyethylene Plant -

Extruders

There are 2 extruders, each sized for

approximately 75% of capacity. 1 is currentlyoperational and the other is being overhauled.

Further details of equipment maintenance is given in section 6.3.

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6. Administration

6.1. Organisation

Since the takeover of EPCL by Indorama, many of the original NNPC staff have left. Thesenior management now consists of Indian ex-pats. The staff at the time of the takeover byIndorama was around 1,000, currently, there are approx 600 local staff and 170 expats.The former NNPC staff who have left the site work in other NNPC business units and therewere no significant redundancies that might have triggered resentment against the companymanagement.

EPCL intend to recruit local staff, as far as possible and training programmes are beingestablished, the last ex-pat recruit arrived at the site around a year ago.

The managing director of EPCL has three main reportees:

•  Finance and Administration•  Commercial

•  Site

The site head has reporting to him the key components of the site operations:

•  Olefins

•  Polymers

•  Offsites/Utilities

•  Maintenance

•  Technical Service

•  Health Safety and Environment (HSE)

The HSE function, in line with good practice, has direct reporting to the site manager.

The previous EPCL management, under NNPC had limited financial authority and evenrelatively minor requests for expenditure had to be approved at a corporate or evenGovernment 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 demonstratedby the extent of work performed in the various TAMs since Indorama bought the site and

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Details Comments

•  Polymers (subdivided into Polypropyleneand Polyethylene & Butene)

•  Power Utility and Offsites.

Each unit has a plant manager and productionmanager (working days), plus shift teams asfollows:

   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

ShiftEngineer

21  1 1 1 1

PanelOperators

4 2 3 1 1 1

FieldOperators

8 5 8 1 4 22 

1 Shift engineer and assistant, the olefinsplant is split into hot and cold sections.

2 Plus one field operator at NNPC

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 amajor event. In the absence of a nominatedindividual, confusion can arise over who takesinitial charge of an emergency and who hasauthority to shut down the plant.

The site has four shift teams working a threeshift system.

8 hour as apposed to 12 hour shifts .willreduce the level of fatigue faced by shiftpersonnel, particularly during hot weather.

Most operators are understood to be in the age

range of 20- 50.

There will not therefore be a sudden large

reduction in the overall level of operatingexperience in the near future.

Warehouse activities (bagging, fork lift truckdriving, etc.) will be largely performed bycontractors under the supervision of EPCL staff.

This is a common procedure in polymer andother plants with large solids warehouses.

Budget Budgetary pressures were apparent when

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Details Comments

The recruitment process includes a written test.

 A number of experienced Nigerian operators,mostly with ammonia plant experience, havealso been recruited.

Trainees will undergo a mixture of classroomand on the job training lasting approx. 18months. Progress is measured by a mixture ofcontinuous assessment and interviews rather

than by written examination

This will ensure that all recruits have anadequate command of the English language.

Operators will initially be trained for a singleoperational role on one unit but as they gainexperience will train in a number of positions.

The recruits from 2006 are now fully trainedfield operators and are now learning paneloperation.

 A process simulator is available but has notbeen fully configured.

Experience Most, but not all, operators are graduates.

For more senior positions, including paneloperators and above, EPCL are appointingexperienced process operators.

These are ex-pats, NNPC secondees orNigerian staff with experience in the processindustries. Some of these will be recruits fromNNPC but there have also been a number ofrecruits from NAFCON (fertilizer manufacturer).

There are a number of Romanian nationals whohave senior operating positions and haveworked at the site for a number of years.

Many of the NNPC secondees are understoodto have been at the site since start up.

Documentation:

Standard OperatingProcedures

Operating procedures have been partiallyrevised and updated since Indorama took overthe site.

However, there are still a number of areas forimprovement.

Completeness Quality of procedures varies; those in the Olefinplant were limited with little informationavailable in the folder examined with pages inthe wrong order and some pages missing.

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Details Comments

Emergency ResponseProcedures

Quality of emergency procedures is variablebetween units but, in most cases, there are noshort form emergency procedures. Those inthe Polyethylene plant were vague and not wellformatted. Instructions were not in a step bystep format.

Due to the defects defined below thepreparation of “short form” emergencyshutdown procedures is desirable and the sitemanagement are currently preparing them.

The site management are currently reviewingthe existing emergency shutdown proceduresin the light of the comments made.

The particular set of emergency procedures

examined had a number of defects, whichreduce their value:

•  The indexing is poor. This would increase the time needed to find theappropriate instructions.

•  The instructions are relatively denselywritten.

Well laid out instructions ease understanding,particularly during an incident.

•  Actions for all personnel appear to bewritten in the same part of the documentwith no split of the activities between the

individual field operators.

It would be preferable for the tasks to beundertaken by each individual operator to belaid out separately to facilitate clarity of

understanding.

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

Under emergency conditions operators mayreact in unexpected ways and regular fieldsimulations are often considered a helpful wayof reducing operator error. Without thisoperators may be confused as to the location ofthe critical valves and other equipment.

Process Upsets  A reporting procedure for process-upsets isbeing 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 alarms arerecorded on the DCS system and no problemswith alarm flooding have been reported.

 A number of companies have experiencedproblems, with “alarm flood”, during majorincident. This results in literally hundreds ofalarms being activated within a very shortspace of time. When this happens, the shearvolume of alarms makes it difficult for operatorsto follow the exact sequence of events. Alarm

management systems assist by filtering out theless important alarms.

This problem has been identified and will beaddressed as part of the DCS upgrade.

Communications/ShiftHandover

Shift logs are maintained by the shift engineerand panel operators The condition of the plant

It is often considered advantageous for both theoutgoing and incoming supervisors to sign the

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Details Comments

Isolation Procedures: Mechanical Reliance is placed on closing of valves and

where pipework is opened blinds are installed.The use of padlocks to ensure that valves arenot opened by mistake would be useful.

 An isolation procedure defining appropriatelevels of isolation should be established.

Electrical Electrical isolation is achieved by “racking out”electrical equipment.

This will provide effective isolation but the useof a padlock on the isolator handle would

represent an additional precaution againsterrors. The site management are currentlyreviewing the adequacy of the existing system.

Instrument A trip bypass register exists and was originallyset up by NNPC.

For short term bypasses, approval is given bythe head of the department.

Longer term bypasses require a more seniorlevel of approval.

There is a trip bypass register for each unit.

Bypasses are checked regularly as part of theregular technical services reports.

The registers in some units, particularly theolefins plant, were confusing and not easy tofollow.

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

6.3. Maintenance

Brief details of the maintenance function are shown below.

Details Comments

Organisation andStaffing Levels  The “Engineering” department is responsible

for maintenance activity and has 2 mainbranches:

Central Services:

• Workshop

Plant Maintenance:

• Olefins

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Details Comments

There are currently no firm plans for a furtherTAM but one is anticipated around March 2010to install a replacement cold box in the olefinplant.

The current level of maintenance shutdownssince Indorama took over the site is muchhigher than would normally be expected andreflects a backlog of maintenance from thedays of NNPC ownership. Once a satisfactorylevel of maintenance has been achieved, thereis no need for TAMs to occur on an annual ortwice annual basis.

Planning   Currently spreadsheets are being used for

maintenance planning.

The MAXIMO Computerised MaintenanceManagement System (CMMS) will beimplemented and will initially be used on thepolypropylene plant. Currently data is beingcollected for future implementation.

Training in “soft skills” is being undertaken toassist personnel to use MAXIMO correctly.

It is reported that future TAMs will beundertaken at a maximum of 4 yearly intervals.However a further shutdown is being plannedto install a replacement cold box in the Olefinplant. 

 At this stage, it is probably too early todetermine TAM frequency. This will onlybecome apparent after the unit has beenoperating in a steady state condition for sometime. Non-intrusive techniques should give ageneral indication of the condition of the plant.

Performance  EPCL have developed a system of KPIs (KeyPerformance Indicators) for the site. Theseshow a current availability of 99%

There currently appears limited overdue

maintenance and these tasks which areoverdue are understood to require maintenanceshut down for completion.

Maintenance under NNPC suffered from lack offinancial resources and the current situation ismuch improved.

Documentation   Most maintenance records are in hard copyand soft copy form. The soft copy is kept onEPCL’s server.

This situation will ensure that a fire or otherincident in the records office will not destroy theentire maintenance history of the plant.

Mechanical Vibration monitoring systems are installed onlarge rotating equipment items such as:

•  Main compressors in the ethylene plant

(Bentley Nevada 3500 series).

•  Gas turbine generators.

•  Instrument air compressors (4 units)

•  Reactor feed pumps (3 units) 

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Details Comments

•  Impact onproduction

•  Impact on safety/environment

B Equipment:

•  On standby

More than 22 kW,and

•  Operating above2,800 rpm

Fortnightly

C Equipment:

•  On standby,

•  More than 22 kW,and

•  Operatingbetween 1,400and 2,800 rpm

Monthly

D Balance ofequipment

Whenrequired

Vibration trips are installed on the gearbox andmotors of the cooling tower fans.

 An in house lube oil testing programme has

being set up with regular checks on moisture,viscosity and particles. If problems aresuspected, lube oil samples will be sent forferrographic analysis.

Dye penetrant testing was performed on therotating elements of key equipment duringTAM1. No problems were identified.

There is some equipment balancing capabilityat the site but larger items would probably have

to be returned to the manufacturer forbalancing.

During TAM1, lube oil quality was found to be

poor with significant contamination by waterand solids. This has now been rectified.

There were initial problems with the olefin plantcompressors as a result of solids deposition onthe rotors. There were also initial problems ofhigh bearing temperatures.

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Details Comments

Electrical The oil in all transformers underwent aDissolved Gas Analysis (DGA) and dielectrictest at TAM1 and no problems were identified.

Further DGA is anticipated in the future and thetransformer oil has been filtered.

DGA may be valuable for determining the earlystages of transformer oil breakdown on largecritical transformers.

Dielectric testing task place every 6 months.

 Annual earthing checks are undertaken.

To date a thermographic camera has not beenused at the site.

Thermography is increasingly used as aneconomic non invasive method of detectingfaults. This may be a useful technique for useprior to the TAM to identify equipment whichmight be in need of repair.

There are understood to be facilities forbalancing large electric motors in the region.

Lack of suitable facilities could lead to longperiods of downtime whilst a motor wasshipped abroad to the manufacturer.

Some equipment is obsolete and replacement

is taking place, including some DC machinesand invertors.

Instrumentation Full function tests on all trip systems wereundertaken during TAM1.

Some components, particularly solenoid valveshave required replacement.

The previous CTt survey in 2006 reported anumber of bypasses of trips in the olefin plant.Whilst the trip bypass register was reviewedduring this survey, it was in a confused and thestate of trips was not always clear.

There is no on line trip testing of the processtrip systems. However tests will take place if aproblem is suspected.

Some systems are partially duplicated whichwould allow partial testing online. However,many companies are often reluctant to performon line testing to prevent an accidentalshutdown of the plant. 

The trip systems on the polymer plants areconsidered less critical as they generally havefrequent short shutdowns for cleaning andgrade changes which would allow trip testing tobe undertaken.

It is now current practice to regularly exercisethe trip valves on the steam turbines.

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

Some equipment is obsolete and replacementis taking place. For example, the fire detectionsystem in the polypropylene plant has been

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Details Comments

EPCL have developed technical agreementswith the licensors of the major process units:

•  Kellogg (olefins)

•  Nova (polyethylene)

•  Basell – the successor to Technimont(polypropylene)

•  IFP(now Axens) - the butane-1 plant

EPCL have appointed SK Energy of Korea(who operate similar olefins plants) as technicaladvisors.

In addition, EPCL have appointed Ingenero (India) to provide real time monitoring andfeedback of process operations

Management ofChange:  

Overview A management of change procedure has beendeveloped by EPCL as part of the new safetymanual and is being used in conjunction withthe 144 changes that have been proposedsince the takeover by EPCL.

 A review of the procedure and some of theproject files showed some weakness in theprocedure:

•  The safety implications of a change weregenerally made at an early stage in thespecification of a change and may notadequately reflect the hazards whichbecome apparent as the technicalimplications of the changes become clear.

•  The requirements for a HAZOP are not

clearly defined and could lead to aninconsistent approach.

•  There is no requirement in the procedure toensure that documentation is updated whenthe change is complete.

The procedure requires a Hazard andOperability (HAZOP) Study to be conducted insome circumstances.

Hardware changes All physical changes to the site go through the

MOC procedure.

Process changes Process changes are covered in the MOCprocedure.

Organizational changes There is no requirement for a review of staffingl l i i l h

It is becoming increasingly common to reviewff f

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6.5. Inspection

Brief details of the inspection function are shown below.

Details Comments

Organisation andStaffing Levels

The inspection function now reports direct tothe site management with the following staffing:

•  Departmental manager

  Corrosion specialist•  4 field inspectors

Equipment:

Radiography Radiographic work is contracted out but EPCLstaff interpret the radiographic plates.

It is common practice for radiographic activity tobe performed by a third party company. EPCLstaff are reported to check the radiographicplates produced by the third party inspectors.

Ultrasonic Panametrics ultrasonic thickness measurementequipment, A, B, C scan equipment with data

capture facilities is available at the site.

Probes for use at high temperature areavailable but EPCL consider them to have

limited reliability at elevated temperatures andthey are not generally used unless a problem isdetected on operating equipment.

Magnaflux Magnaflux equipment is now available on site This equipment has been purchased sinceCTt’s 2006 survey.

Eddy current Contractors would be employed if eddy currentinspection were necessary.

Dye penetrant Dye penetrant equipment is available.

 Alloy Analyser A Niton metals analyser has been purchased. These are becoming increasingly popular bycomparison with the better known TexasNuclear Analysers because the radioactivesource within the instrument has a longer halflife requiring less frequent replacements.

Other A Holiday detector has been purchased. This detects defects in vessel and pipelinecoatings. One use will be to detect the qualityof painting systems under insulation to preventCorrosion Under Insulation (CUI)

Experience The corrosion engineers will be graduate levelappointments. The field inspectors will requirea minimum of level 2 certification in 2 or moreNDT subjects.

This represents a high level of competencearound the site and represents a significantimprovement over the situation when NNPCmanaged the site

Contractors are also used for work duringTAMs and other busy periods

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Details Comments

 All statutory inspections required by theNigerian Authorities are undertaken.

Pressure vessels are code stamped and thereare no ASME VIII div 2 vessels on site.

The site is currently investigating a Risk Based Approach to inspection but details have not yetbeen worked out.

Whilst companies are increasingly moving toRisk Based Inspections (RBI), when Indoramaoriginally took over the site, they did notconsider that there was sufficient data available

to implement RBI at the site. The fact that RBIis now being considered demonstrates theincreased confidence that EPCL now have inthe mechanical integrity of piping and pressurevessels by comparison with 3 years ago.

 A significant number of process vessels andtube bundles have been inspected duringTAM1. Those considered less likely to suffercorrosion were inspected during TAM2.

The cold section of the olefin plant isconsidered as an area where corrosion isunlikely and has not so far been examined.Whist corrosion may be limited due to theoperating conditions and the use of stainlesssteel, this is also the part of the plant which

represents the greatest VCE hazard

Whilst there are a few vessels which have notbeen inspected since Indorama took over thesite, all those considered most hazardous havebeen inspected and, generally, hydrostaticallytested. These include:

•  All vessels containing hydrogen, and

•  All vessel with liquefied gas inventories

 A programme of inspection of areas whereinsulation is damaged is underway.

Corrosion Under Insulation (CUI) work isprogressing with priority being given to pipingsections subject to thermal cycling.

This will identify areas where under insulationcorrosion could exist and allow remedial actionto be undertaken before the problem becomesserious.

Spheres 7 of the 12 spheres at the site have now beeninternally inspected. In addition MagneticParticle Inspection (MPI) has been conducted

on the sphere legs.

Each sphere inspection costs approx. Naira 2.5million.

There have been cases where the sphereintegrity has been adequate but corrosion ofsphere legs has occurred, resulting in collapse

of the sphere. Inspection of the legs istherefore prudent.

Once each sphere has had an initial inspectiona re-inspection is planned at 5 to 10 year

.

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Details Comments

Pressure tests are conducted on a test benchwith nitrogen used for pressures up to 140 barand water used above that pressure.

 A hot set pressure correction is applied wherenecessary.

Whilst the use of water for high pressure testingis understandable, it is desirable to use thecorrect medium for testing (water for valves onliquid duties and nitrogen for valves on vapourduties). Use of the wrong fluid could result inincorrect calibration

Hoses There is currently no comprehensive

programme for inspection of hoses. Wheninspections are required, they are requested bythe unit where the hoses are located.

It is common practice to pressure test hoses

and check for electrical integrity every 6months.

There are now more hoses at the site than atthe time of the previous survey. These includehoses associated with the new propylene richfeedstock import.

 As plant managers’ main focus is likely to be onproduction rather than inspection activities, itwould be prudent for coordination of hoseinspection to be transferred to the inspection

group.

Cranes  All cranes slings, etc. are inspected by a thirdparty inspection body.

Crane inspection is a statutory requirement inNigeria.

Positive MaterialsIdentification 

 All piping materials, welding rods, etc. suppliedto the site are subject to third party inspection.

 A Niton alloy analyser is available at the sitebut is only used on a random basis. However,there was 100% checking for materials involvedin the VC5 project.

This procedure may have the potential to allowrogue sections of material to enter the site.Whilst it offers a reasonable level of protection,it would be preferable to test and colour code

each individual alloy component entering thesite 

EPCL also intend to perform some randomchecks on alloy material installed on the plant.

 Alloy materials entering the site are reported tobe colour coded before entering the stores.

.

Welders Welding is performed by a mixture of in houseand contract welders. Generally welders arerequired to produce test pieces on site butpreviously issued certificates are accepted ifthey are less than 6 months old.

This differs slightly from common practicewhich generally requires the completion of testpieces from all welders who have notpreviously worked at the site on a regular basis.

Corrosion Protection Cathodic protection is installed on the NGLfeed line from AGIP feed. Soil conditions onthe propylene line from the Port Harcourt

fi d t i th di t ti

The line to the refinery is understood to be theproperty of EPCL, whilst the NGL feed line isthe property of AGIP.

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Details Comments

determined that in all cases, the reducedwall thickness still allows safe operationand there has been no requirement forwelding repairs on any of the vessels.Plans are in hand for the replacement ofsome vessels.

•  Many furnace and boiler tubes havebecome defective and have been replaced.

•  As stated above, checks are underway tocheck the extent, if any, of under corrosioninsulation

6.6. Safety, Health and Environment

Brief details of the safety function are shown below.

Details Comments

Organisation andStaffing Levels

The safety function reports to the site manager.

The department is headed by the site Head ofHSE, with the following groups reporting to him.

This will allow a clear reporting route, with noconflicts of interest. 

The safety department is split into 3 subgroupsas shown below:

•  Environment (2 personnel).

. •  Safety Engineering (5 personnel, plus 1vacancy)

•  Occupational Health (15 personnel)

•  Fire (see section 6.7).

This will include a safety representative oneach shift team. Whilst the reporting route is tothe safety department, there have beenconflicts of interests in other locations. Thishas resulted in the shift safety officersometimes being more concerned withproduction activities than safety.

Training The site will generally be recruiting experiencedpersonnel with little requirement for immediate

training.

Once site operations are fully established, itmight be appropriate to arrange a short period

in the HSE function for young engineers as partof their career progression.

Experience The Head of HSE has extensive experience ofprocess operations and process safety.

 All personnel at the site have a diploma in

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Details Comments

Employee Involvement Since taking over the site EPCL have worked

energetically at the site and there is nowcollective consensus that safety is a linemanagement responsibility with the safetyfunction acting largely as an auditor andadvisor.

This is in line with modern safety philosophy.

 A new draft safety manual has been produced.

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Details Comments

Safety Auditi ng Internal safety audits take place twice per year.These use prepared checklists with reportingand follow up of any defects identified.

Contractors Contractors have safety briefings when theyfirst arrive on site. Some contractors havesafety training before arriving on site.

There is also a safety committee dedicated tocontractor issues.

6.7. Emergency Response

. Brief details are given below:

Details Comments

Organisation andStaffing Levels

The site fire team will consist of:

•  A fire chief

•  5 shift fire leaders

•  6 fire fighters per shift

 An organization chart is shown below:

 As in other areas recruitment is not completeand NNPC secondees are currently beingused to cover the positions where permanentemployees have not been appointed.

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Details Comments

The fire training ground is due to be relocatedas a consequence of the changes in the sitelayout required by the decision to provide livingaccommodation within the EPCL boundary forex-pat staff.

Employee Involvement  An auxiliary fire team composed of security andmaintenance personnel has been established.

Mutual Aid  A mutual aid scheme is being developedinvolving:

•  Shell Petroleum.

•  Agip.

•  Mobil.

•  Total/ELF

•  Nigeria Ports Authority (NPA)

The inclusion of fire teams from otherhydrocarbon facilities will ensure that many ofthe mutual aid personnel will be experienced inthe specific dangers associated withhydrocarbon fires.

•  Port Harcourt Refinery. The level of equipment availability at PortHarcourt may be limited

•  River State Fire Authority (the localmunicipal fire brigade).

Local authority firefighters frequently have alimited understanding of oil industry fires

Emergency Planning  An emergency plan has been developedoutlining roles and responsibilities have beendefined and deputies nominated.

Points noted in the previous CTt survey areunderstood to understand been incorporated inthe lasted version of the emergency plan.

Emergency coordination centres have beenestablished in the Plant shift Superintendentsoffice and the fire station. These are reported tobe fully equipped.

.

So far no emergency pre plans have beenprepared.

Well developed pre plans can assist in theearly stages of emergency planning byproviding firefighters with the basic informationrequired to mount a fire attack quickly.

Emergency Drills and

Simulations

Emergency simulations take place on an annual

basis. The 2008 simulation was in thepolypropylene plant and the 2009 one isplanned for the tank farm.

6.8. Security

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Details Comments

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Details Comments

 Approx 160 of the personnel are unarmed andprovide basic security at locations such ascontrol of entry to buildings, etc. They areemployed by two local security contractors:

•  Pentagon Security - provide security in theouter perimeter and up to the inner fence tothe process, utility and offsites.

•  Bulwark - provide security within the inner

fence containing the process, utility andoffsites.

There are also a number of Nigerian stateauthorities involved in security at EPCL:

•  Nigerian army

•  Mobile police

•  Regular police

  2 State security intelligence officers.The army and mobile police, both armed havebases inside the site parameter.

There are also 2 Israeli security specialists onsite.

Some of the security personnel operatedwithin the site in plain clothes.

In addition EPCL have undertaken a number ofactions to limit tension between the companyand the surrounding community, including theprovision of training programmes and the use of

local people, where possible, for unskilled work.

This philosophy has proved successful as localpeople were instrumental in resolving thekidnap of EPCL employees and their families.

Other miscellaneous activities include therunning of security consciousness classes .

Post Orders  All the EPCL security personnel and externalagencies have defined roles through a chain ofcommand.

There are three levels of patrolling:

•  External to the site

•  Within the site boundary

•  By plain cloths personnel at the site

Post orders define the requirements of thesecurity section. These should include thechain of command, required duties, normaloperating duties, and emergency responses tosecurity incidents.

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Details Comments

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Details Comments

Weapons   The soldiers and mobile police are armed.

Experience andTraining

Many of the contract security personal are ex-military or ex-police.

Some training has been provided by securityspecialists from Israel.

Control of access to theSite

Since the kidnapping incident securityprecautions have been significantly increased.

•  There is only one point of access to the site,through a well guarded gate

•  An access control system featuring swipecards in being installed 

There is an inner gate into the process area.Vehicles into this inner area are checked toensure that flame arrestors are fitted.

Physical Precautions  The original wire fences topped with barbed wire

have now been replaced by a 3m concrete walltopped with an electrified fence.

 A multi camera CCTV monitoring system isbeing installed

In addition, All Ex-pat personnel and theirfamilies will soon be located from externalaccommodation to housing with the EPCLproduction site.

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7. Fire Protection

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7. Fire Protection

7.1. Fire and Gas Detection

In addition to the detection systems listed below, there are Manual Call Points (MCPs)throughout the site.

Details Comments

Buildings Smoke detection is installed in buildings,including underfloor areas in control rooms.

Detectors are also installed on the air inlets forair conditioning systems.

The smoke detection system in the main officebuilding has not yet been renovated but theplant based systems are understood to beoperational or under repair. See below.

Process Areas Gas detectors are installed through the processareas.

Heat detection systems are installed in someprocess areas to activate water sprays.

The level of detectors varies within the processfacilities reflecting different design philosophies.Numbers of detectors are:

•  Olefins – 36..

•  Polypropylene – 45.

  Butene –1 - 18 A replacement fire alarm panel has beeninstalled in the Polyethylene plant.

Set points for alarm and actuation also differbetween the polypropylene plant and the other

locations.

 A renovation project for the detection systemsin the plant is well advanced. Details are givenbelow.

Gas detectors alarm at 25% and 50% of LELbut do not initiate any shutdown action.

Some equipment is obsolete and replacement istaking place. For example, the fire detectionsystem in the polypropylene plant has beenreplaced and new system for the polyethyleneplant is on order. 

Storage Areas Within the LPG and refrigerated storage areas

gas detectors are installed.

Smoke detectors are installed in thepolyethylene and polypropylene storagefacilities. Fusible plugs, activating sprinklersystems are also installed.

Gas detectors alarm at 25% and 50% of LEL

but do not initiate any shutdown action.

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Details Comments

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In the Polyethylene plant the fire water system hasbeen tied in to provide emergency cooling waterfor the process.

This should ensure a supply of cooling waterin the event of a power cut, the temptation touse fire water for routine cooling must beresisted.

Testing  The diesel fire pumps were reported to be startedfor 30 - 40 minutes every 2 weeks.

The NFPA guidelines recommend 30 minutetesting on a weekly basis and this periodshould be used in the future. 

Head curves were reported to have been checkedduring TAM1 but appear not to have beenchecked since.

It would also prudent to perform pump headcurve tests on an annual basis as requiredby NFPA in the future.

7.3. Act ive Systems

Brief details of the active systems are given in the table below. Many of the systems were inpoor condition when the plant was operated by NNPC but considerable renovation work hastaken place since Indorama took over the site.

Details Comments

Buildings  A number of fixed systems are installed in variousbuildings:

•  Laboratory – sprinkler system with a 7.74l/min/m

2 density.

•  Control and rack rooms (including underfloorareas) – halon or carbon dioxide systems. The halon systems are reported to beinterlocked with air conditioning equipment.

Some of the underfloor systems in controlrooms use carbon dioxide which is an

asphyxiant. These are set for manualoperation to allow personnel to evacuate theroom before the system is triggered.

Halon is now banned under the MontrealProtocol but some developing countries havea waiver for continuing use for a period. Atsome point the halon systems will need to bedismantled and EPCL propose to replace itwith FM 200 or aragonite.

In some locations, such as the instrument

rack room in the olefins room, the doors areopen and portable fans installed due todefects in the air conditioning system andthis will prevent the extinguishing systemworking effectively. Whilst there will beconsiderable movement into and out of therack rooms during start-up the normal

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Details Comments

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•  A manually operated deluge system isinstalled around the refrigeration compressorsin the olefin plant.

Deluge rates are 10.2/l/min/m2 for most duties and20.4 l/min/m

2 for pumps

 A similar system may be installed around thecracked gas compressor but this was notvisited during the survey.

•  Dry powder system is installed to protect theTEAL handling systems in the polypropyleneplant.

Storage Areas  All the major liquid storage facilities have fixed fireprotection:

•  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 rings covering theentire surface.

•  The refrigerated ethylene tank has a water

deluge system with a density of 10.21/min/m2. In addition there is an impoundingbasin for containment of ethylene spillageswhich is equipped with water deluge and fixedfoam systems.

The bladder tanks for the foam systems arereported to have been recently tested and found tobe in good condition.

Discharge rates appear to be in line with APIstandards.

The polypropylene and polyethylene warehouseshave water deluge systems with water densities

varying between 7.8 1/min/m

2

  and 18.3 1/min/m

2

 depending on the area being protected.

The catalyst storage facility has a deluge systemwith a water density of 15.11/min/m

2.

Deluge isolation valves on the polyethylenewarehouse were examined during the survey

and found to be partially or fully open. Itwould be prudent to car seal these valves inthe open position to prevent accidentalisolation of the sprinkler systems.

Utilities  A number of fixed systems are installed in theutility areas:

•  Motor Control Centres (MCCs) andswitchrooms have fixed carbon dioxideextinguishing systems

The provision of fixed systems againsuggests a difference in design philosophiesbetween the different plants. There are no

fixed systems within the olefin unit, whilstMCCs and switchrooms in both thepolypropylene and polyethylene plants haveprotection.

•  Fixed carbon dioxide systems are installed inthe 4 gas turbine cubicles

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Buildings Control rooms for the process units are blastresistant without windows. However in all theprocess control rooms visited, the main doorswere open.

The level of blast resistance was notdetermined.

Despite the blast resistant design, theintegrity of the control rooms is reduced ifdoors are left open.

Process Areas  The level of passive fire protection variesconsiderably with only limited protection in theolefins plant but a considerably higher level of

protection in the polyethylene plant.

 Again this suggests different fire protectionphilosophies between the different licensorsand contractors.

The requirement for fireproofing will be lowerin plants handling hydrocarbons which will bein the gas phase after release rather than theliquid phase where pool fires might result.

Vessel skirts are fire proofed. Fire proofing has been applied to a numberof vessels where it was previously missing.

The level of fire proofing on piperacks is variablewith some racks carrying predominantlyhydrocarbon gases being fire proofed in the

polyethylene plant. In other locations piping withliquid inventories is in un-fireproofed racks.

There is generally little value in fireproofingpiperacks containing gases. Fireproofing isdesigned basically as protection from liquid

pool fires.

Fin fan cooler are partially fireproofed but not tothe full load bearing height.

The air flow from the fin fans will exacerbateflames from a pool fire. The provision offireproofing almost to the top of the fin fancooler will minimise the extent of damagecaused by a pool fire under the fin fan.

The TEAL (catalyst) storage areas in thepolypropylene and polyethylene plants areconstructed of concrete with dividing walls

between the TEAL containers.

Storage Areas Sphere legs are fireproofed.

2 hour rated fire walls are installed in somewarehouses.

Utilities Fire walls are installed between transformers withstone covered drainage at the base.

2 hour rated fire doors are installed at allsubstations.

In some cases, the height of the fire wallmight not be sufficient to prevent a degree ofthermal radiation exposure by the adjacenttransformer.

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7.5. Mobile Equipment

7.5.1. Fire Trucks

Brief details of the fire trucks are given in the table below.

No. ofTrucks Details Comments

Combination Truck 3 3,0001/min water pump at 100mhead.

4,000 l foam, 8,000 l water and1,000kg dry chemical. 

One of these is a new Tata fire truckpurchased since Indorama purchased theEPCL.

Bronto Skylift 1 foam/water pump 3,000 1/min

Transformer Passive Protection

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The fire station and fire-water pumps are remote from the process area.

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7.5.2. Foam and Dry Powder Stocks

Minimum foam stocks are:

•  AFFF – 6,000 litres

•  AFFF (ATC) – 5,000 litres

•  FFFP – 10,000 litres

•  Dry chemical powder 4,000 litres

Care should be taken in the use of foam as mixing different foam types may reduceefficiency.

Some foam is available in fire trucks and a 3,800 l overhead tank (see below) has beeninstalled to provide rapid refilling of fire trucks, together with a limited stock in drums.

Bulk Foam Tank

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8. Recommendations for Risk Improvement

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8.1. New Recommendations

 At the conclusion of the survey a meeting was held with the site management and a numberof recommendations made, these are given below.

CTt prioritise recommendations with the following classification:

1. Priority: Major risk deficiency that requires prompt action. It is advised that capitalexpenditure be allocated to these recommendations in preference to otherrecommendations listed here.

2. CAPEX: Recommendations requiring capital investment.

3. Human Element: Recommendations requiring little capital investment. Theserecommendations require effort and commitment by staff and can make an important

contribution to risk improvement. They should not be regarded as trivial items, andshould be implemented within a reasonable timeframe.

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

09-01 Sampling Procedures

Category 1

Recommendation Review the current sampling procedures (and their operation in practice) for liquefied gases and, ifpossible, revise the procedure to avoid the release of process fluids during the samplingprocedure.

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

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

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09-02 Fire and Gas Alarm Systems

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Category 1

Recommendation Review the adequacy of the existing fire and gas panels and make appropriate repairs andupgrades as necessary.

Reason Whilst considerable work has been done to repair and upgrade the fire and gas system, the systemstill appears to have a number of defects and its overall integrity may be low.

Examples •  Fault alarms were active on most of the fire alarm panels inspected in buildings and processareas

•  Some of the equipment at the site may be obsolete, for example the site uses catalyticpelletizer type flammable gas detectors whilst newer, more reliable, infrared detectors areavailable.

EPCL Post Sur veyComment

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

09-03 Contro l 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 open and close

manually and there is a temptation to leave them open, particularly in a warm climate. Howeverthe integrity of the control room is compromised when the doors are left open. In the, unlikely,event of a major explosion there would be casualties within the control room and damage to controlequipment.

Examples  All process control rooms

EPCL Post Sur veyComment

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

09-04 Urea Formaldehyde Foam (Cold Insulation)

Category 2

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09-05 Document Contro l

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Category 3

Recommendation Develop a document control procedure to ensure that:

•  Key documents are “controlled” with the latest versions being accessible to registered usersand older versions destroyed.

•  Uncontrolled copies can be clearly identified

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

Reason Currently EPCL are largely working with documents inherited when the site was under NNPCoperation. Some key documents, such as Process and Instrumentation Drawings (P&IDs) havebeen updated and, it is understood that many other documents are likely to be developed orrevised now that the more urgent work of improving the plant’s mechanical integrity is completed.

Unless well developed systems for the control of documents are developed, there is a danger ofdifferent versions of the same document being used by different people.

Examples •  Currently the site P&IDs have been updated but the original “as built” drawings are the ones

available for reference in the plant control rooms.

•  It is intended that many of the drawings, procedures, etc. will be available on the companyIntranet. Unless, appropriate checks are built into the system, it will be difficult to controldownloading, printing and storage of uncontrolled documents.

EPCL Post Sur veyComment

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

09-06 Operator Emergency Training

Category 3

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

2. “short form” emergency instructions should be prepared as a standalone document. These

could be in the form of checklists so that operators can confirm that they have completed allthe emergency actions required.

3. Institute an emergency simulation program for process operators so that they are familiar withrequired actions in the event of a process upset. The following points are offered forconsideration:

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09-06 Operator Emergency Training

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

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

EPCL Post Sur veyComment

This will be reviewed in plant level. 

09-07 Permit to Work (PTW) System

Category 3

Recommendation Review the design of the Permit to Work system to cover the following areas:

1. Revise the design of the permit form so that the authorizing signatures (required before work

starts) and the hand back signatures (required on the completion of work) or on the same sideof the permit form.

2. Keep a copy of the permit to work at the jobsite (usually encased in a plastic envelop to avoiddamage)

3. Keep files for incomplete work separate from those for completed work.

4. Introduce a JSA (Job Safety Analysis) system for none routine work

5. Ensure that site visits take place to ensure that the site is left in a safe condition on thecompletion of maintenance work.

Reason 1. The current design of the form is unusual in having the authorizing signatures (required beforework starts) and the hand back signatures (required on the completion of work) on oppositesides of the permit form. This could lead to confusion when filling in the form and makesauditing of the forms more difficult

2. Provision of a copy of the permit at the job site assists monitoring of the work by operationsand safety personnel

3. It is common for maintenance activities to be incomplete when the PTW expires and is signedoff. To avoid confusion over the status of maintenance activities, it is common practice, toseparate PTWs for completed tasks from those for ongoing maintenance activities. Confusion

over the status of maintenance work was a key factor in the Piper Alpha disaster in the UKNorth Sea in 1987.

4. EPCL currently have a JSA programme covering frequently performed activities, this should beexpanded to cover non routine work, which may introduce unexpected hazards.

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09 08 Isolation for Maintenance

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09-08 Isolation for Maintenance

Category 3

Recommendation Review the existing Isolation standards for maintenance isolation as follows:

•  Apply padlocks and tags to isolations on hazardous piping systems. Note that manycompanies have developed isolation procedures defining isolation requirements based on: fluidproperties, flammability, toxicity, pressure and temperature. These are sometimes in the formof a Risk Matrix.

•  Apply padlocks and tags to electrical isolations

Reason The existing practice requires only blinds on pipework and padlocks do not always appear to befitted for electrical isolations.

Examples Various locations around the site.

EPCL Post Sur veyComment

The existing practice is well established but we would review the merit of the recommendation.  

09-09 Electrical Integrity

Category 3

Recommendation Review Electrical integrity around the site and ensure that electrical work is completed to anacceptable standard.

Where additional cabling is being installed on existing junction boxes, checks should be made toensure that the capacity of the junction boxes is not being exceeded.

Reason Poorly installed or maintained electrical equipment is an ignition source.

Examples •  Many of the explosion proof junction boxes in the olefin plant have almost all of the boltsmissing from the flanges. The same thing, to a lesser extent, is true in other plants.

•  In many buildings the covers on low voltage junction boxes were open

•  There are numerous examples where new low voltage cabling has been run from existing junction boxes without using existing cable trays.

EPCL Post Sur vey Completion of electrical job with full tightening of all bolts will be ensured. Work permit should not

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09-10 Trip By-Pass Procedure

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Category 3

Recommendation Develop a trip bypass procedure covering the following:

•  The level of authorization and checks required before isolation can take place

•  The duration of the isolation

•  Where isolations are likely to be for an extended period (more than a day or two whilst repairs

are made). Some form of safety review should be undertaken to determine if additional,alternative, safety methods need to be undertaken.

Reason The current system consists of a trip bypass register maintained in each of the plant control rooms.These are not always clearly filled in and, in some cases, it was difficult to determine if the dateson which bypasses had been established and when they were restored.

Examples Trip bypass register in the olefins control room.

EPCL Post Sur veyComment

Procedures being revisited to include check list on completion and implementation of change.Check list shall ensure that changes are reflected in the related documents. Document controlsystem will then ensure updating of all controlled copies.  

8.2. Previous Recommendations

There have been numerous recommendations from a number of surveys dating back to1996. At the time of the 2009 survey, there were a total of 58 outstanding

recommendations.Of that total:

•  17 are complete

•  7 have no change

•  23 are in progress

•  6 are withdrawn

•  5 have an unknown status

Recommendations Prior to 2005

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No. Title Summary Status in 2006 Current Status (fromEPCL)

96 08 Fi P t ti C t l P i l t d

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96.08 Fire Protection ControlValve Security

Previously reportedCOMPLETE

-

96.10 Palette Storage Pallets in polymerwarehouses.

UNKNOWN

96.12 Warehouse Practices Wooden palletsstored close toTEAL containers.

UNKNOWN

96.13 Halon System Status Replace halon with

FM 200

NO CHANGE Preliminary work and technical

discussion is in progress.Would be implemented inphased manner from 2010.

98.01 Remote OperatedIsolation Valves

Install RemotelyOperated valves forprocess isolation inemergencysituations

IN PROGRESS Out of 4 additional ROVsidentified for installation 2 arealready installed and 2 areprocured waiting shutdown forinstallation

98.03 Fire-water Pumps Stop unauthorized

use of fire water.

NO CHANGE

98.04 Updating of Piping &InstrumentationDiagrams

Update P&IDs toreflect current statusof plant.

WITHDRAWN

This is repeated in a laterrecommendation

98.06 Wooden Pallets Storage of woodenpallets in polymerwarehouses.

UNKNOWN

99.01 Permit-to-Work System Various

improvements to thePermit-to-workSystem.

IN PROGRESS

 A revised permit system hasrecently been introduced butfurther improvements arepossible.

COMPLETE and being

practiced. SOP is available onthe intranet.

Note that some issues wereidentified during the course ofthe current survey and a newrecommendation relating toPermit-to-Work has beendeveloped.

99.02 Fire Pumps:Housekeeping

Vegetation in the firepump area

COMPLETE -

00.01 Control of Valves onFire-fighting Duty

Position of fire watervalves

Reported COMPLETE -

00 02 S C f R CO

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No. Title Summary Status in 2006 Current Status (fromEPCL)

02 04 Gas Detection System Repairs to the fire IN PROGRESS Fire and gas detection

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02.04 Gas Detection System Repairs to the fireand gas detectionsystem

IN PROGRESS

Repairs to systems within theprocess, utility ands storageareas are nearing completion.

Fire and gas detectionsystems were workingsatisfactorily in all plants butPE. PE system was totallyrevamped and working fine.

02.05 TAM Schedule Undertake Turn AroundMaintenance of thesite

WITHDRAWN

This recommendation isrepeated below.

 A TAM to complete urgentrepairs has been completedwith a further TAM in the firstquarter of 2007

-

02.06 Extensions of PTW Limit valid of a workpermit to one day.

IN PROGRESS

 A revised permit system hasrecently been introduced butfurther improvements arepossible.

COMPLETE and beingpracticed. SOP is available onthe intranet.

Note that some issues wereidentified during the course ofthe current survey and a new

recommendation relating toPermit-to-Work has beendeveloped.

02.07 Bolting l-K-3 (EthyleneCompressor)

Bolting on dischargeflange

Reported COMPLETE -

02.08 Oil Pan l-K-2(PropyleneCompressor)

Oil pan full ofleaking oil undercompressor

Reported COMPLETE -

02.09 Static Bonding onPneumatic Conveyor Check continuity ofearthling onPolypropylene plantpneumaticconveyor.

Reported COMPLETE -

02.0 Power Plant UtilitiesSubstation 3

Check fire breaks incable routes.

IN PROGRESS

Specifications checked and ascope of work is beingprepared.

COMPLETED

02.12 Interlocking of ReliefValves

Lock relief valveisolations in thecorrect position ifmechanicali t l k t

IN PROGRESS

CTC Note: Isolation valveswithout locks were notedduring the survey

The intent of mechanicalinterlock of safety system andthrough provision of chainlock. DON’T UNDERSTAND

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No. Title Summary Status in 2006 Current Status (fromEPCL)

there is still considerable

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work to be done.

03.01 Routine Analysis ofOlefins Cold Box Purge

Routine analysis ofthe cold boxnitrogen purge

IN PROGRESS

03.02 Olefins Plant -Pipework & BoltingCorrosion

Corrosion onpipework

COMPLETE

TAM1 involved a review ofthe piping and vessels

suffering from corrosion in theolefins plant

-

03.03 Liquid EthyleneStorage Tank

Various repairs tothe ethylene tank.

IN PROGRESS

Progress had been made inthe area but some work stillneeds to be done. Examplesare the rod hanger on one ofthe ethylene pipes to the tankand insulation around theliquid ethylene pumps.

Completed.

Note that site visits indicatedthat the rod hanger has still notbeen replaced.

03.04 Use of CellularTelephones within theProcess Plant

Use of mobilephones withinprocess plant.

NO CHANGE

Personnel using phones werenoted in several areasincluding adjacent to the DCSpanels, where there isconcern that the mobilephone signal could interferewith the DCS.

04.01 Turn-Around

Maintenance Delay

Instigate the

delayed TAM.

WITHDRAWN

This recommendation isrepeated below.

 A TAM to complete urgentrepairs has been completedwith a further TAM in the firstquarter of 2007.

04.02 Trip Bypass Develop a tripbypass procedurerequiring approvalby senior staff.

COMPLETE

 A review of the registershowed that it has just beenupdated and a considerable

-

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06-01 Fire Detection/Protection Impairment System

Examples Whilst the use of fire water for process cooling is much improved from the situation before TAM1,

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Examples Whilst the use of fire water for process cooling is much improved from the situation before TAM1,there are still some cases where fire water is used for cooling. In addition, there is considerable(uncontrolled) use of fire water for purposes, such as wash down of process areas. Fire hosesused for these purposes are evident in several parts of the site and the volume of water is suchthat the one of the main electrically driven pumps is operating continuously to supply demand.

In addition a number of defects, which have not yet been repaired were noted, where these existadditional safety precautions will be necessary to ensure that safety of the facilities are notcompromised. 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 fullyfunctional.

•  The “trouble” alarm on the gas panel in the olefins plant is illuminating

•  Status of fire detectors in the office block is uncertain.

This is probably not a complete list.

Status EPCL State that:

With the revamp of the fire detection and protection system in PE the system now exist in allplants.

CTt Comment Some defects were noticed in many of the plants, this recommendation is considered to be INPROGRESS.

06-02 Job Safety Analysi s (JSA)

Category 1

Recommendation Review and implement the Job Safety Analysis procedure as a matter of priority. It should beused to review the safety of all work, including temporary activities associated with start-up.

Reason The JSA procedure represents a structured procedure for reviewing the hazards associated with

particularly activities. The lack of a structured approach may result in the introduction ofunnecessary hazards.

Examples Some activities associated with start-up which were unnecessarily hazardous:

•  The use of temporary flexible hoses and drums with screwed fittings and unions for transfer of

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06-03 Under Insulation Corros ion

C 1

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Category 1

Recommendation Increase the speed of the under insulation inspection programme. The programme should beprioritised so that the most hazardous piping (based temperature, pressure, contents andcorrosion potential) is inspected first.

Reason The inspection programme has so far only considered a small proportion of the piping whereunder insulation could exist. A leak of hydrocarbon material from a corroded pipe could result in aserious fire or explosion.

Examples Currently approximately 10% of the pipework has been checked for under insulation. From visualinspection, there are many places where the external weather protection over the insulation hasbecome damaged, with the potential for water to seep into the insulation, possibly causingcorrosion.

Status EPCL State that:

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. This

recommendation is considered to be IN PROGRESS

06-04 Housekeeping

Category 1

Recommendation  As the plant start-ups progress, ensure that surplus construction material are cleared from the sitetogether with any construction tools.

In addition, all blinds and plugs should be reinstalled in piping and equipment. All bolts in electricalflanges should be reinstalled.

Checks in offsite areas should also take place to ensure a good level of housekeeping around thesite.

Reason Poor house keeping inhibits the development of a safety culture, which the new EPCL wishes topromote.

In addition, missing blinds and plugs on pipework and equipment, increases the potential forleakage of hazardous materials and lack of bolting on electrical equipment the “explosion proof”rating for use in hazardous areas.

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06-05 Offsit es Area

C t 2

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Category 2

Recommendation Review Conditions in the offsites area and make appropriate repairs.

Reason Whilst the offsites areas are often considered to be low hazard by comparison with the processareas, they still contain large inventories of hydrocarbons with significant fire and BLEVE potential.

Examples •  Much of the lighting system is defective with explosion proof covers missing and electricalcontacts exposed. From a visual inspection the system appears unusable, however as a

temporary measure it would advisable to isolate the supply to the area at the appropriatesubstation.

•  Pressure relieves require testing

•  Plugs are missing from some liquefied gas lines

•  The mastic installed in the expansion joints on the concrete dikes of both the refrigerated andpressurized storage has perished and is unlikely to provide an effective barrier to leakage.

Status EPCL State that:

Completed, Repairs done.

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

06-06 Organization – Engineering Function

Category 3

Recommendation Review the site organization chart and consider the inclusion of a site engineering function, withthe inspection group reporting to it.

Reason •  The source of technical support may not always be clear with some departments or individualsmaking decisions which are best taken by experienced project engineers.

•  A technical services/ engineering group would provide a better “home” for the metals inspection

function than the maintenance function. In the latter case, there may be a conflict of interestbetween the desire for maintaining equipment and keeping it in operation and removing it forinspection.

Examples Currently there is a Technology Group, with individuals from separate departments rather than aclearly identifiable engineering/technical services function.

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06-07 Inspection - Hoses

Category 1

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Category 1

Recommendation Review the inspection requirements for hoses and ensure they are inspected in line with acceptedpractice. This generally requires checks on electrical connectivity/isolation and a pressure test atsix monthly intervals.

Hoses should also be checked to ensure that they are fit for purpose.

Reason Use of poorly maintained hoses or the incorrectly specified hoses can lead to failure and

subsequent leakage/fire.

Examples Temporary hoses used in the olefin and polyethylene plant had end connects which appearincompatible with use on liquefied gases.

CTt Comment No response was received from EPCL but from discussions on site, it appears that inspectionpractices for hoses are UNCHANGED.

06-07 Positi ve Materials Identifi cation

Category 3

Recommendation Increase positive identification of alloy materials to every section of piping material, etc. Materialsshould be then colour coded before entry into the stores.

 As EPCL has purchased a Niton metals analyser this should not be problematic.

Reason The current system relies on the manufacturer’s mill certificate being correct. Whilst this is usually

the case, there are numerous examples where incorrect material has been supplied. This mayresult in rapid corrosion or failure due to the material being unable to withstand the pressure ortemperature limits imposed in operation. If this occurs the pipe may rupture leading to a release ofprocess materials.

Examples Currently reliance is placed on the manufacturer’s mill certificate with no additional inspectionunless a problem is detected.

CTt Comment No response was received from EPCL but from discussions on site, it appears that inspectionpractices for hoses are largely UNCHANGED.

06-08 Operator Emergency Procedures

Category 3

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06-08 Operator Emergency Procedures

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

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

Examples Currently, there is limited emergency training for process operators.

Status EPCL State that:

SOP for emergency procedures existing. On site Emergency Management Plan (OSEMP)completed and available on the intranet.

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

06-09 Permit To Work

Category 3

Recommendation Review the permit to work system with regard to the follow points

1. Have all approval and hand-back signatures on the same side of the form

2. Review the need for additional types of permits (for example excavation)

3. Improve filing to ensure that permits for completed activities are filed separately to those forongoing work. Ideally all copies of the permit should be reunited in the control room and

signed off together. Any changes made will need to be fully explained to both operational and maintenance personnelvia appropriate training.

Reason 1. This will increase the ease of auditing the procedure and ensuring that it works as designed

2. Some activities, such as excavation, require particular checks which are not appropriate tomost cold work activities and could be missed unless specifically noted on the permit form.

3. A common file of permits can lead to confusion over the status of work, with the possibility thatoperators might try to start equipment which is still awaiting completion or maintenance. Forexample, where there are delays due to the absence of spare parts.

Examples 1. The new style permits have authorization signatures on the front of the form and the hand –back signatures on the back.

2. The cold work permit is used for excavation and the hot work permit is used for radiography

3. A single file for all permits is used in the olefins control room

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06-10 Management of Change

Category 3

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Category 3

Recommendation Review the management of change procedure to:

1. Provide clear guidance on the criteria by which changes are considered trivial and those whichrequire a more detailed safety assessment, including a HAZOP study. A sample checklistwhich 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:

213.212.77.20/research/crr_pdf/2001/crr01348.pdf

Reason 1. The lack of clear criteria to determine if detailed assessment is necessary could result inhazardous changes being approved without adequate assessment.

2. The lack of an assessment procedure for staffing changes could result in the introduction ofhazards in situations where staffing levels change, job descriptions are altered, etc

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

Status EPCL State that:

MOC system implemented. SOP available on the internet.

CTt Comment Some aspects of the MOC procedure still require improvement and this recommendation is INPROGRESS.

06-11 Emergency Plan

Category 3

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

1. The provision of an adequately equipped emergency coordination centre in a safe andaccessible location

2. Review the format of the plan to see if it can be restructured for improved clarity

3. Prepare fire pre-plans for likely fire situations.

To ensure that the practicality of the plan a full scale or desktop exercise should be performed.

Reason 1. The current location of the emergency coordination centre is undecided. One option appearsto be the use of the fire station control room. It is generally considered preferable to use aroom without distractions close to the main entrance.

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06-12 Asset Ownership of Fire Fighting Equipment

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Category 3

Recommendation Review “asset ownership” of the fire protection and detection equipment.

One department, ideally the fire department, should have overall responsibility for ensuring that theequipment is in good condition, regularly tested. This does not imply that the department shouldphysically check the equipment but should be responsible for ensuring that it is tested. The samedepartment should also be responsible for noting impairments and controlling the use of fire waterby other uses.

Firefighters could include in their duties regular checks on the state of equipment

Reason  At present “ownership” of the assets appears confused with assets generally being “owned” by thedepartment where they are located. This can lead to confusion over who is responsible forchecking equipment and ensuring that it remains in working order.

If the firefighters take over “ownership”, it should also help ensure fire water is used correctly andthat fire hoses, etc. are maintained in good condition and available for use.

Examples Several examples were noted where the apparent status of equipment differed from that found in

practice:•  Diesel fire pumps were in one case reported to be operational, when one requires a new

battery.

•  The weekly running tine for the diesel fire pumps was variously reported as 10 and 30 minutes(the latter is preferred practice).

•  Fire water is being used for a number of purposes other than the three coolers which stillrequire additional cooling.

CTt Comment No information was provided, the status is UNKNOWN.

 ARM Survey 2008

08-01 Vibration Monitoring

Recommendation Regular monitoring and analysis of vibration of rotating equipment enables any problems to be

identified quickly and rectified in a timely manner. Therefore, it is recommended that vibrationmonitoring be extended to include all items of rotating equipment. The frequency of the monitoringshould be decided by the criticality of this equipment.

Reason The facility has good on-line monitoring of major items of rotating equipment and the ability toperform vibration monitoring and analysis of other items of rotating equipment. However, the

it i i t t i ld t f d t h i l l t

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 Appendix A

Plot Plan

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 Appendix BPermit to Work Forms

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 Appendix CManagement of Change Checkl ist

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SAFETY AS ESSMENTS 

Plant Title Ref No

Underline those factors which have been changed by the proposal.

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Process conditions Engineering methods Engineering hardware and designtemperature trip and alarm testing line diagram lighting protectionpressure maintenance procedures wiring diagram radioactivityflow inspection plant layout rate of corrosionlevel portable equipment design pressure rate of erosioncomposition design temperature isolation for maintenance

toxicity Safety equipment materials of construction mechanical-electricalflash point fire fighting and loads on or strength of: fire protection of cablesreaction conditions detection systems foundations handrails

means of escape structures laddersOperating methods  safety equipment for vessels platformsstart up personnel pipework/supports/bellows walkwaysroutine operation temporary or permanent: tripping hazardshutdown Environmental condi tions  pipework/supports/bellows access forpreparation for maintenance liquid effluent valves operationabnormal operation solid effluent slip-plates maintenanceemergency operation gaseous effluent restriction plates vehicles

layout and positioning of noise fillers plantcontrols and instruments instrumentation and control fire fightingsystems underground/overhead:

trips and alarms servicesstatic electricity equipment

Within the categories listed below,does the proposal

Yesor No

What problem has been created which affects plant orpersonnel safety and what action is recommended to minimise it

Signed& date

Relief and Blowdown

1. Introduce or alter any potential cause of over/under pressuring (orraising or lowering the temperature in) the system or part of it?

2. Introduce a risk of creating a vacuum in the system or part of it?

3. In any way affect equipment already installed for the purpose ofpreventing or minimising over or under pressure?

 Area Classi ficat ion 

4. Introduce or alter the location of potential leaks of flammablematerial?

5. Alter the chemical composition or the physical properties of theprocess material?

6. Introduce new or alter existing electrical equipment?

Safety Equipment 

7. Require the provision of additional safety equipment?8. Affect existing safety equipment?

Operating and Design 

9. Introduce new or alter existing hardware?10. Require consideration of the relevant Codes of Practice and

Specifications?11 Aff t th i t t d t f th

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 Appendix DOrganizational Change Guidance

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 Appendix ESample Fire Fighting Pre Plan

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Resource Protection International

Email [email protected]

Reproduced with Permission of

Phone (44) (0) 1296 399311

Fax (44) (0) 1296 395669

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