Insurance Risk Survey of Eleme Petrochemical Company Li mi ted (EPC L), Por t Harcour t, Nig eria 22nd to 24th October 2012 88 Leadenhall Street, London, EC3A 3BA Tel +44 (0)20 7623 1819 Fax +44 (0)20 7623 1817 www.cttechnical.com Charles Taylor Adjusting Limited is an appointed representative of Charles Taylor plc which is authorised and regulated by the Financial Services AuthorityRegistered Office: Standard House, 12-13 Essex Street, London WC2R 3AA Registered in England No. 1994696 A Charles Taylor company Revision Date Comments 6 October 2012 Resurvey 5 May 2011 Resurvey 4 June 2009 Resurvey 3 December 2006 Revised to include new values and loss estimates 2 November 2006 Updated to include client comments 1 October 2006 Previous survey in March 2005 when the site was owned by NNPC
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Charles Taylor Adjusting Limited is an appointedrepresentative of Charles Taylor plc which isauthorised and regulated by the Financial Services Authority
Registered Office: Standard House, 12-13 Essex Street,London WC2R 3AA Registered in England No. 1994696
A Charles Taylor company
Revision Date Comments
6 October 2012 Resurvey
5 May 2011 Resurvey
4 June 2009 Resurvey
3 December 2006 Revised to include new values and lossestimates
2 November 2006 Updated to include client comments
1 October 2006 Previous survey in March 2005 when thesite was owned by NNPC
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Executive Summary
Introduction
Charles Taylor Technical (CTT) has been commissioned by United Insurance Brokers toproduce an underwriting survey report for insurance purposes of Eleme Petrochemical
Company Limited (EPCL), Port Harcourt, Nigeria. Information was obtained during meetings
with key staff, a site visit and from a previous survey report.
The survey concentrated on property damage, machinery breakdown and businessinterruption at the plant.
Overview of Risk
Significant Changes since the Last Survey
There have been no major changes since the 2011 survey but steady progress hasbeen made in a number of areas, including updating of the operating procedures and
developing process safety awareness. The site is fully operational but there are
limitations on feedstock supply.
The site now has certification for ISO 9001, ISO 14001 and OSHAS 18001. Early in2012 EPCL achieved 5 stars under the British Safety Council safety rating scheme and
have also been awarded a "Sword of Honour".
There are major construction projects (new ammonia urea plant, plus an expansion ofthe olefin unit and new HDPE unit) planned for the site with construction expected to
start in 2013. This will change the nature of risk at the site in the short term, whilstconstruction takes place, and in the longer term when toxic hazards will be present as
well as the existing fire and explosion hazards.
The Site
Eleme Petrochemical Company Limited (EPCL) was originally a subsidiary of theNigerian National Petroleum Organization Corporation (NNPC) but was sold to
Indorama in May 2006. EPCL operates an olefins plant and downstream units, whichare mostly polymer plants, at Port Harcourt, Nigeria. The facilities date from the mid-
1990s. The site suffered from underfunding for many years but since Indorama tookover the site, there has been major investment in the existing facilities and a high level
of equipment reliability is being achieved.
Natural hazards in the area are modest.
The site is built on a large plot with considerable room for expansion and in addition to
the process, storage and utility systems, also houses the ex-pat workforce andfamilies.
The facilities are relatively modern with good spacing between the individual process
units, utilities and the storage area. However, there is an element of congestion withinsome of the process facilities. The level of loss prevention features varies between
process units. The number of remote isolation valves on large process inventories in
the ethylene plant has been increased but additional valves may be required.
Storage facilities are generally to modern standards. Some, but not all, of the tanks
have been refurbished since Indorama took over the site.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
There is adequate space on site for the new units, which were envisaged when the plotlayout of the site was originally developed.
Administ rat ion
Prior to the sale of EPCL to Indorama, NNPC maintained an unusually tight controlover finances. This resulted in serious underfunding, particularly of the maintenance
budget and no major overhaul of the site was undertaken between 1996 and 2006.
The site organization generally follows accepted practice, with a direct reporting routefrom the safety manager to the site manager. There are currently no unusual features
and a technical services group has now been established.
Staffing levels have been significantly reduced from the approximately 1,200 presentwhen NNPC ran the site but appear adequate. The previous NNPC management team
have been replaced by ex-pat personnel and there are currently ex-pat personnel at all
levels of the organization. There is a trend to replacing ex-pats in more junior positionswith Nigerian nationals, where possible.
There has been considerable revision of operating and maintenance procedures since
the 2011 survey but still some areas where improvements can be made.
Activities in most areas follow accepted industry practice but are, sometimes, at an
early stage. In many cases, these have only been developed in the last five years. A
CMMS (Computerised Maintenance Management System) is now in place. A furtherturnaround is anticipated during early 2013.
The inspection department has been very active and has now collected data for most
equipment, although there is still significant inspection for under insulation corrosion tobe undertaken. Although most piping and equipment has been inspected, there is not,
currently, enough information to allow trending but this situation should change in the
near future as additional readings are undertaken.
There are well resourced safety and firefighting teams at the site and a very high level
of security. Increased attention to process safety activities is now apparent at the site.
A high level of security remains in place with a larger workforce of contract personnelsupplemented by police and military personnel.
Fire ProtectionThe fire detection and protection systems have been overhauled and are largelyoperational. However some obsolete systems are in place, including a number of
halon systems. One of the electrical fire pumps is in continuous operation to supplywater for wash down – a situation unchanged from the 2011 survey - but a new, larger,
jockey pump is currently being installed. Fixed protection systems generally appear ingood condition and the fire trucks are reported to be in good condition.
In summary, the site has improved considerably since it was acquired from NNPC but stillhas a few legacy issues. Procedures are continually improving, a high level of availability is
now achieved and there is an increasing level of process safety awareness.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Insured Values
The current insured values are:
USD million
Process facilities 848.0
Non-process facilities 69.8
Stocks 65.0
Business Interruption (12 months) 300.0
Loss History
Since Indorama took over the site, there have been two claims:
Date Loss AmountUSD
Details Comments
10 Jan 2009 850,000 Limitations of feedstocksupply. This has reducedproduction at the plant and alsocaused an increased cost of workingas a result of increased utility usageper unit of production.
May 2008 - Damage to Olefin Plant cold box.The cause has not been positivelyidentified but is probably due tothermal cracking of the cold boxduring start-ups and shutdownssince the plant was commissioned.
The claim was subsequentlywithdrawn.
Repairs were made and areplacement cold box ordered. This
was installed at the last turnaroundin 2010.
Loss Estimates
Scenario
PropertyDamage
(USDMillion)
BusinessInterruption
(USDMillion)
Combined(USD Millions)
Property Damage Vapour cloud explosion in the olefinplant following a release from the C2splitter reflux drum
435 600 1,035
MachineryBreakdown
Damage to the rotating elements ofthe olefin plant cracked gascompressor
19.0 50.0 69.0
Complete destruction of the olefinplant cracked gas compressor
32.7 450 458.4
Note that underwriters exposure will be limited to USD 300 million (the policy limit with a 12 month indemnityperiod) for business interruption losses.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Recommendations for Risk Improvement
A total of nine new recommendations were made as a result of the current survey:
Recommendation Description Category
12-01 New Projects – Risk Engineering Review Priority
12-02 New Projects – Consequence Modelling Priority
12-03 Controlled Documents Procedural
12-04 Permit to Work System – Filing Procedural
12-05 Database of Recommendations Procedural
12-06 Ethylene Storage Tank Area - Housekeeping Procedural
12-07 Gas Detection Systems for Occupied buildings Procedural
12-08 Inspection of Fire Protection Equipment Procedural
12-09 Testing of fire fighting Foam Procedural
The status of the 24 outstanding recommendations from previous surveys is shown below:
The key features of the site have been assessed using CTT’s Key Risk Rating IndicatorSystem (KRRIS) for the Oil, Gas and Petrochemical Industry to determine the key risk
features. For each of the key indicators (Hardware, Software and Protections), a number ofindividual features have been identified and rated according to the KRRIS system. The
higher the number (rated 0 to 4), the better the risk. The risks are also representedgraphically (ranging from red for poor, to bright green for good). The results are shown
Permit sys tem is operating satisf actoaly but some
minor improvements are possible.
A LOTO system ahs now been implemented.
Vegitation has been cleared from the drains
since the last survey.
Maintenance
Natural perils at the site are limited. All senior management positions occupied by ex-
pats.
Fire detection systems have been repaired The
system is reported to be operational, although
there are a large number of fault alarms..
Protections
This sheet summaries the various parameters for each of the indicators shown above. For a full understanding of the individual parameters contributing to indicator, the individual hardware, software
and protections worksheets should be c onsulted
Operating Procedures
Hardware Software
Minor exposure from other facilities.
Note that furture construction projects c ouls
impat the operating procedures.
Layout between units is generally spacious.
There are some congested areas w ithin the units
A considerable amount of mainteance work has
taken place since the take over by Indorama. The
condition and reliability of the equipment is much
improved. A vailability is now approac hing 100%
An ORICLE based CMMS is now in use.
Fire fighting systems are operational.
DCS systems have been upgraded
Although control rooms are blastproofed, the
doors are fr equently left in the open position.
The engineering function is reported to be
adequately staff ed and resourced.
The management of c hange is capable of
improvement.
Systems appear to be in good condition
Most porducts are transported by truck in a non
haardous form. A new road tanker unloading
fac ility has been built with basic fac ilities.Pipeline
systems w ere not reviewed in detail during the
survey
Inspection Procedures are to a generally good
standard with a w ell trained and enthusiastic
w orkforce.
The site is moving is considering a move to Risk
Based Inspection but does not have enough data
to trend corrosion rates.
Level of passive protection varies betw een
different process units.
Much of the machinery has been overhauled
since Indorama took over the site. 1 gas turbine
has been overhauled and plans are in place to
overhaul the others.B22
A high level of security is in place at the site. Testing of gas gestion systems follows normal
practice.
However testing of the fire w ater pumps is not
fully in line with NFPA standards.
Some of the storage facilities have been
refurbished.
Safety pr ocedures are generally to a high
stadard. There is increased awareness and
implementation of process safety procedures.
There are significant stocks of foam. It is not
clear if the foam is regularly inspected.
The site is largely self suf ficent in utilities.
A major power f ailure occurred in earlier in 2012,
resulting in a total plant shutdow n.
The emergency response capability appears
adequate and some, basic, pre-planning has
been done.
Fixed fire f ighting equipment is on good condition
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
7. Administration 81
7.1.
Organisation 81
7.2.
Operations 82
7.2.1.
Process Operations 82
7.2.2.
Control of Maintenance 85
7.3.
Maintenance 87
7.3.1.
Turn Around Maintenance (TAM) 87
7.4.
Engineering 93
7.4.1.
Management 93
7.4.2.
Management of Change 95
7.4.3.
Hazard Studies 95
7.5.
Inspection 96
7.6.
Safety, Health and Environment 102
7.7. Emergency Response 106
7.8. Security 107
8.
Fire Protection 110
8.1. Fire and Gas Detection 110
8.2. Fire Water System 111
8.3. Acti ve Systems 113
8.4. Passive Systems 115
8.5.
Mobile Equipment 117
8.5.1.
Fire Trucks 117
8.5.2.
Foam and Dry Powder Stocks 118
Appendix A List of Acronyms Appendix B Information on Impairment Systems Appendix C Management of Change Checklist Appendix D Organizational Change Guidance Appendix E Sample Fire Fighting Pre-plan Appendix F Plotplan Appendix G Permit to Work Forms
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
S. Dineshkumar Instrument Engineer
S.B. Sagdeo Instrument Engineer
Ansari Siraje Alam
B. Phamanage Technical Services Department
Bareen Phamarage Technical Services Department
Eniafe Babajide Technical Services Department
Ezemwugo Patricia Technical Services Department
Ezugu Benneth Technical Services Department
Nwawosike A. Joy Technical Services Department
Olumoye O.R. Technical Services Department
Angus O. Inspection Engineer
Anyanwu C.O. Inspection Engineer
Jerome F. Inspection Engineer
Onyejiaku Angus Inspection Engineer
K.P. Pandey HSE Manager
Felix Okosun Safety Department
Saloka James Environment Department
B.T. West Fire Chief
Aluh Pareto Security Manager
And others
This Underwriting Report is not intended to identify all hazards which may exist nor is it
intended to be an exhaustive review of all possible eventualities. The recommendations forrisk improvement contained in the report are advisory and the decision and responsibility for
implementation rests with the site's management.
1.2. The Company
Eleme Petrochemical Company Limited (EPCL) was originally part of Nigerian National
Petroleum Corporation (NNPC) which is wholly owned by the Nigerian Government.
In May 2006, EPCL was sold to Indorama, a multinational company based in Indonesia withinterests ranging from petrochemicals, textiles and cement. The timeframe for the takeover
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
The NNPC organization was centrally controlled, with individual subsidiaries having limited
authority for expenditure and other decision making. This resulted in difficulties in planning,
recruitment and maintenance of the major locations. The sale of EPCL to Indorama hasreduced the constraints of central control and has allowed access to funds for long overdue
maintenance at the site, as well as changes to the management structure and operatingprocedures.
The senior management members at the site have all arrived since privatisation and aremostly Indian nationals. In addition, there are Indian expats at all levels within the
organization. Most of the original Nigerian workforce has left EPCL for other parts of NNPC.
Training programmes are being set up for Nigerian nationals with the long term intention ofreplacing Indian staff with Nigerian nationals.
Further details of Indorama are available from the company’s website:
http://www.indorama.com/
1.3. The Location
Eleme Petrochemicals Company Limited (EPCL) operates a single petrochemicals site atPort Harcourt in the River Province of Nigeria. It consists of an ethylene cracker,
polyethylene, polypropylene and butene-1 plants, together with associated utilities, storageand infrastructure. The plant was commissioned in 1996 and had been operating
continuously since then, without a major shutdown for maintenance (Turn AroundMaintenance or TAM), until 2006 when the management of EPCL was taken over by
Indorama.
Due to the lack of maintenance and feedstock limitations, the process units had seldomperformed at anything like full capacity and were frequently shutdown. Since the takeover
by Indorama, there has been significant capital investment and a number of shutdowns forsite wide maintenance and refurbishment.
The plant is located near the town of Eleme, approximately 15 minutes’ drive from Port
Harcourt, the capital of Rivers State. The site is elevated 15m to 18m above the level of theBonny River, which runs 5km from the site, and there is no history of flooding in the area.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
2. Background
2.1. Insured Values
2.1.1. Property Values
The replacement values for the facilities were estimated by AVC (of the UK) in 2006 to be
USD 868 million. A revaluation by AVC was undertaken in 2011 but the available valuationdata provided is from the 2006 valuation and the breakdown of the current insured values
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
USD
Technical Building 5,610,000
Canteen 3,990,000Medical Centre 1,800,000
Training Centre 1,640,000
Fire Station 1,260,000
Auditorium 730,000
Laundry 620,000
Lorry Divers Facility 580,000
Sub Station 590,000
Total 69,800,000
The insured value of stocks is: USD 65 million.
2.1.2. Business Interruption
The business interruption sum for the 2011/12 policy period is USD 300 million with a 12
month indemnity period.
A major Vapour Cloud Explosion (VCE) may result in rebuilding times well in excess of 12months (24 months is commonly assumed) and therefore underwriters’ exposure is likely to
be considerably less than the full business interruption figure.
2.2. Loss HistoryBrief details of loss history are given in the table below:
Date Loss AmountUSD
Details Comments
10 Jan 2009 850,000 Limitations of feedstocksupply. This has reducedproduction at the plant and alsocaused an increased cost of workingas a result of increased utility usageper unit of production.
May 2008 - Damage to Olefin Plant cold box.The cause has not been positivelyidentified but is probably due tothermal cracking of the cold boxduring start-ups and shutdownssince the plant was commissioned.
The claim was subsequentlywithdrawn.
Repairs were made and areplacement cold box ordered. Thishas now arrived on site and wasinstalled at the last turnaround in2010.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
3. Recommendations for Risk Improvement
3.1. New Recommendations
CTT categorises recommendations with the following classification:
1. Priority: Major risk deficiency that requires prompt action. It is advised that capital
expenditure be allocated to these recommendations in preference to other
recommendations listed here. These recommendations should be completed within three
months of the survey report date.
2. CAPEX: Recommendations requiring capital investment. These recommendations
should be completed within the next budget cycle unless a major shutdown is requiredfor implementation.
3. Procedural: Recommendations requiring little capital investment. These
recommendations require effort and commitment by staff and can make an important
contribution to risk improvement. They should not be regarded as trivial items. These
recommendations should be completed with 12 months of the survey report date.
12-01 New Projects – Risk Engineering Review
Category Priority CAPEX Procedural
Recommendation Undertake a risk engineering review of the proposed new units. This willinvolve a review of the design to:
• Ensure that appropriate process safety features are installed.
• An adequate level of fire protection is installed.
• Time to react to and recover from incidents is minimised.
• Process safety and fire fighting systems are appropriate for staffinglevels and maintenance regimes that will exist once the units arecomplete.
The study is probably best conducted at the project contractor’s offices at apoint in time where the findings can be incorporated in the final scope of work.
Reason A risk engineering review will ensure that appropriate process safety featuresare built into the new units. This, in turn, will result in a greater potential forthe incidents to be more easily prevented or controlled.
Examples Ammonia, Urea and Ethylene plant upgrade projects.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
12-02 New Projects – Consequence Modell ing
Category Priority CAPEX Procedural
Recommendation Perform a study using consequence modelling to determine the effects of anincident in one part of the site on other locations. The study should coverareas outside the process facilities, including: storage, utilities, offices,accommodation areas and residential areas outside the site boundary. Thestudy should consider:
• Explosions (including VCE and BLEVE).
• Fire (both pool and jet fire).
• Toxic gas release.
• Terrorism and sabotage.
• Natural perils.
• Utility failures.
• Contingent failures such as loss of feedstock.
The study should consider hazards at both the construction and operationalstages.
The results of the study would provide input into the detailed design andlayout of the facilities (including the requirement for safe havens in the eventof a major ammonia escape) and emergency planning.
Reason The new plants being constructed, plus planned expansion to the originalfacilities, will change the overall hazard profile at the site. Theinterrelationship of the hazards needs to be considered in detail, especially asthere are now a significant number of people resident at the site – somethingnot envisaged at the design stage.
Examples Planned construction projects at the site, particularly the ammonia and ureaplants.
12-03 Controlled Documents
Category Priority CAPEX Procedural
Recommendation Develop a consistent procedure covering all parts of the site.
The procedure should cover the format of documents (including the recordingof revision numbers and dates of changes).
There should also be a consistent approach to the storage and filing of mastercopies of documents and a register of holders for controlled documents.
Reason Unless there is a consistent approach to document control, there is a potentialfor confusion between the status of documents at different parts of the site.
Examples There are different approaches to controlling documentation at the olefins andpolymer units. Within the Olefins plant, there is a "controlled" copy with a redstamp on each page. If photocopied the red stamp will appear as black and itwill be clear that the document may not be up to date.
Within the polymer units "original copies" are available which have nodistinguishing stamps.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
12-04 Permit to Work System – Filing
Category Priority CAPEX Procedural
Recommendation Revise the permit procedure to ensure that permits are filed for more than aweek. The following points should be considered:
• If all copies of the permits are collected together and "signed back", therecan be no confusion regarding the status of work – which could occur if aloose copy of the permit was found.
• There should be separate files for completed and uncompleted work.
• In addition to the permit forms, supporting information should be included(Job safety analysis sheets, isolation certificates).
• There should be regular auditing of the permit system.
• Whilst filing in the control room for an extended period (beyond thenormal auditing frequency) is not necessary it is common to file permitsfor a two year period.
Reason The current practice of filing a single copy of each permit for only a weekgives limited opportunity for auditing.
Examples Files of permits in all units.
12-05 Database of Recommendations
Category Priority CAPEX Procedural
Recommendation Develop a central database of recommendations from accident investigations,safety audits and other sources.
The database should be checked and reviewed regularly to ensure thatrecommendations are being progressed towards an end point forimplementation.
Ideally, the database should nominate a responsible individual for eachrecommendation, with a timeframe for implementation and automatic flaggingof overdue actions.
Reason Unless a comprehensive set of recommendations is available together with arobust programme for implementation, there is a danger that manyrecommendations will not be completed.
In addition a backlog of incomplete recommendations is likely to have anegative effect on the safety culture of the site.
Examples EPCL operated several databases for recommendations from differentsources.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
12-06 Ethylene Storage Tank Area - Housekeeping
Category Priority CAPEX Procedural
Recommendation Clear vegetation from the dike area and make sure that the area, including theimpounding basin is in good condition.
Confirm that the foam system for the impounding basin is in good condition(both the equipment and the foam).
Reason There is currently significant vegetation growth within the ethylene tank dike.This could become a fire hazard during the dry season.
In addition, there is stagnant water and small trees growing within theimpounding basin. This could limit the capacity of the tank for ethylene spillsand the water would provide a source of heat to assist vaporization ofethylene. In addition. tree roots might cause damage, to the basin anddamage it’s integrity.
The integrity of the foam system is unknown and may not be functional.
Examples Ethylene storage tank area.
12-07 Gas Detection Systems for Occupied build ings
Category Priority CAPEX Procedural
Recommendation Review the gas detection systems associated with HVAC systems.
If the detectors are located within the air ducting, consider relocating them toa location near to the inlet of the HVAC system.
Reason EPCL has pellistor type gas detectors rather than alternative infra-red type.
The principle of operation of pellistor type detectors is to measure thetemperature rise when flammable gas is combusted on a catalyst pellet. Ifdetectors are installed in a moving air stream, there will be a cooling effectwhich will counter the heat rise, possibly leading to false readings.
Examples Olefin plant control room.
12-08 Inspection of Fire Protection Equipment
Category Priority CAPEX Procedural
Recommendation Ensure that regular inspections of ALL fire fighting equipment are made andrecorded. Ideally there should be random spot checks by management toensure that inspections are being correctly undertaken.
This recommendation should be read in conjunction with recommendation 06-01.
Reason Unless regularly inspected, it is difficult to ensure that equipment is in thecorrect location and in good condition.
Examples Whilst almost all extinguishers had inspection tags, the frequency ofinspection varied from one location to another.
In addition, some sprinkler systems in the Polyethylene warehouse had beenisolated.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
12-09 Testing of fire fight ing Foam
Category Priority CAPEX Procedural
Recommendation Conduct regular checks on the stocks of fire fighting foam at the site. Foamwhich is not in good condition should be replaced.
Reason Defective fire fighting foam will perform effectively either in a fire fighting roleor as a sealant for liquefied gas spillages.
Examples Fire fighting foam stocks.
3.2. Previous Recommendations
There have been a series of surveys of EPCL, dating back to the days when it was ownedand operated by NNPC. During these surveys numerous recommendations were made and,
during NNPC’s ownership, there was little improvement. The recommendations below werethose which were outstanding at the end of the 2011 survey.
Of the 24 recommendations in 2011:
• 6 are complete
• 11 are In progress
• 2 are withdrawn
• 5 are Unchanged
11-01 SIMOPS (Simul taneous Operations)
Category 3
Recommendation Develop a procedure to control simultaneous construction and operation within thesame area. The procedure should include, but not be limited to:
• Ensuring adequate separation between construction and operational areas,including the installation of fences and emergency exits
• A risk matrix to identify which construction/commissioning activities can be safetyundertaken concurrently with operational activities.
• Communication between operating and construction personnel in areas such as:
o Hot work
o Emergency response
A good description of SIMOPS activities at an onsite location is available from:
http://www.onepetro.org/mslib/servlet/onepetropreview?id=IPTC-13705-MS&soc=IPTC Reason Construction and commissioning activities can lead to hazardous situations, which,
without careful control and communication, can result in hazardous situationsoccurring.
Examples The main value of the SIMOPS procedure will be in the future when construction of theLDPE, methanol and ammonia/urea plants takes place.
There are some areas within the existing facilities where SIMOPS is currentlyapplicable, for example in the construction work being undertaken in the PE plant.Where a portable concrete mixer with an internal combustion engine was in use. Thisappeared to be close to or within an electrically classified area with no evidence of ahot work permit.
EPCL Post SurveyComment 2011
Procedure is under development, implementation by September 2011.
Status October
2012
It was not confirmed that this recommendation has been completed and it is
considered IN PROGRESS.With construction work due to start at the site in a few months’ time, it is important thatthis recommendation is completed without delay.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
11-02 Wafer Valves
Category 2
Recommendation Identify any wafer (long bolted) valves on hydrocarbon lines in the process units andstorage areas.
These should either be replaced with standard flanged valves or provided withinsulation and a fire resistant covering.
Reason The longer bolts in wafer type valves have limited thermal inertia and will heat upquickly in a fire. They are also likely to suffer from direct flame impingement if there isa fire in the area. The direct flame contact causes the bolts to expand rapidly andlengthen, allowing both gaskets to leak hydrocarbons which will feed the fire andincrease the level of damage.
Examples A wafer type valve was identified in the piping around the 1-C-5 column in the Olefin
plant.
EPCL Post SurveyComment 2011
We are reviewing the status of long bolted valves along with designer specs. Appropriate action will be taken for fire protection based on it. October 2011.
Status October2012
Insulation has been installed to protect the long bolted flanges, an example was shownbelow.
The recommendation is COMPLETE.
Internal combustion driven concrete mixerclose to process area in PE plant
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
11-03 Control of Maintenance
Category 3
Recommendation Conduct a fundamental review of the existing procedures for the control ofmaintenance to ensure compliance with existing good practice in the hydrocarbonprocessing industries.
The review should include a full assessment of all aspects of the maintenance
activities, including:• The requirement for some form of risk assessment before the start of each activity
(standard procedures could be used for frequent activities).
• Ensure that the job site is visited by operations and maintenance staff togetherprior to the issue of the permit and at the hand-back stage.
• Limit the validity of the permit to a single shift, with a maximum period of 24 hourswith revalidation at each shift.
• Examination of equipment to be used for each activity to ensure that it is suitablefor its purpose.
• Ensure that all personnel are aware of the activities currently taking place. This isoften achieved with the use of plotplans mounted on a wall in the control roomwith markers showing the location and type of activity. In addition, a copy of thepermit should be available at the job site.
• Permits should be filed for a period of at least three months to allow auditing ofthe system.
•
There should be separate folders for filing permits for completed work and permitsfor work that is continuing (even when the permit has expired).
• Isolation and de-isolation of equipment, ideally using a Lock Out/Tag Out (LOTO)system.
• The permit system should be regularly audited.
Guidance is available from a number of sources, including:
http://www.ogp.org.uk/pubs/189.pdf
http://www.hse.gov.uk/pubns/priced/hsg250.pdf
Reason There have been a number of recommendations relating to the permit to work systemand a fundamental review is considered desirable to ensure that safe workingprocedures continue to be to a high standard.
As EPCL have an ambitious expansion programme over the next few years, now isconsidered to be the ideal time to review the permit system.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Examples A number of issues were identified during the survey:
• There is no indication that each activity has some form of safety assessment orrisk review prior to work commencing (however standard risk assessments areavailable for some tasks).
• Equipment for use for maintenance appeared unsuitable:
o Electrical cabling with taped connections in the PP plant
o Internal combustion engine driving a concrete mixer, possibly in anelectrically classified area, in the PE plant
o A sandblasting skid with a non "Ex" rated motor in the Olefin plant. Whilstthis may be intended for use during plant shutdowns, it is likely that in somecases it will be used for sandblasting whilst adjacent equipment is inoperation.
• No permits were displayed at jobsites.
• Permits examined in the control rooms showed that permits were kept open overweekends with some permits being open for five days.
• The "sign-off" date by operations supervisors was often a day or two after the lastday of validity of the permit, suggesting a gap between work being completed andchecks at the jobsite.
It should be noted that two of the four fires reported in 2011 were related to the controlof maintenance.
EPCL Post SurveyComment 2011 The existing procedure is effective and well established. However, we are reviewing itfor further improvement based on some of the recommendation. The plot plan withlocation marking showing activities already exist in control room. (Auditor may haveoverlooked.) Most of the suggestions have already been implemented in our system.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
11-04 Trip Bypass Procedure
Category 3
Recommendation Review the current trip bypass procedure and, if considered necessary, revise it toensure:
• Trips which are bypassed for an extended period receive a higher level of scrutinythan trips bypassed for a short period of time. This is often achieved by requiringa higher level of authority to extend a bypass beyond a short period of time.Where bypasses are required to extend beyond a short period of, typically 24 – 48hours, a Management of Change procedure is followed.
• The bypass procedure should require some form of risk assessment to identifyany additional safety precautions required whilst the bypass is active. Ensure thatprocedure is followed rigorously.
• The trip bypass authorization forms should be filed (with separate files forcompleted and active forms).
• Regular auditing of the forms and bypass register should take place to ensure that
the procedure is being followed as required.• If a trip bypass register, in addition to the forms, is to be used each trip should be
individually "signed off" and "signed back".
It may be appropriate to modify the existing procedure so that multiple trips, on asingle piece of equipment can be bypassed simultaneously when the equipment is outof service. However, the disabling and, especially, the establishment of each tripshould be noted individually.
A discussion of trip bypass procedures is given in:
Reason Whilst EPCL currently has a trip bypass procedure as part of the safety manual, thisrequires a separate form to be completed for each bypass. This is consideredimpractical in situations where multiple trips may be bypassed at the same time. Forexample during the decoking of a cracking furnace.
Where procedures are developed but then not used, short cuts and deviations canoccur. It is preferable to have a clear concise, practical procedure which can be usedthroughout the site without the need for modification or misuse in some situations.
Examples During visits to the control rooms no bypass forms were reviewed but each plant had atrip bypass register which appeared to be correctly completed.
In the Olefins plant, the trip bypass register dates from March 2011. There was noevidence of any trips which were previously bypassed being "carried forward" to thenew register. There were a number of cases where bypasses had been in place forweeks. Elsewhere in the register, it was not clear if individual loops had beenestablished or not as a single signature appeared to have been used to confirm thatseveral bypasses had been re-established.
EPCL Post SurveyComment 2011
The present system is well established and most suitable based on our requirementand type of work being done. However, we are reviewing it further. Some of thesuggestions have already been taken care.
Status October2012
Trip bypass registers are being prepared for use in the individual unit control rooms butthe implementation of a more advanced trip bypass system has not been investigated.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
11-05 Flange Systems
Category 3
Recommendation Review the current practices with regard to :
• Provision of blinds (to ensure that only correctly rated blinds are installed).
• Studs fully penetrated the nuts at both ends of a flange.
• Specification of bolts and studs on stainless steel piping (to ensure that studs andbolts are to the same material as the flanges and piping).
The value of good bolting practices could be emphasised through training courses,toolbox talks, etc.
Reason Poor bolting and flange practices increase the likelihood of flange leaks and therelease of sufficient hydrocarbon material to generate a fire or explosion. This problemis shown clearly in the schematic below.
A particular concern exists if carbon steel bolts are installed in stainless pipework. Inthe event of low temperatures, for example during blowdown, low temperatures couldbe generated in pipework. Whist stainless materials might be suitable, there could bebrittle fracture of carbon steel studs.
Examples • A thin steel plate was installed as a blind on a virgin C5 line at offsites liquid pumphouse.
• Studs which did not fully penetrate the nuts on either side of the flange werenoted in the offsites LPG pump area.
• Very limited amounts of short bolting were noted in process areas.
• Stainless piping and flanges with carbon steel bolting were noted in the olefinplant cold section.
EPCL Post SurveyComment 2011
We have already surveyed short bolting and less bolting. Correction is underprogress. Since some blinds are only for positive isolations, thickness was less for bigdiameter pipes. However, all attempts are to be made to install correct rated blinds intrue isolation cases.
CTt Comment The response is unclear. Where blinds are installed in pressurised systems, theyshould always be rated for the same pressure as the piping system.
Status October2012
No examples of incorrect flanging were noted during the survey. The recommendationis considered COMPLETE.
11-06 Maintenance of Drains
Category 3
Recommendation Ensure that a regular programme of drain cleaning takes place throughout the site.This should be controlled through the maintenance work order system.
Reason Whist the flow through the drains systems is generally low, much higher rate flows mayoccur during heavy rain. If the drains are partially blocked rainwater might flood someareas of the plant resulting in damage.
The drains are also required to cope with fire water flow and if restricted could result ina back-up of water spreading out on the plant with burning hydrocarbons on top. Thearea exposed to fire could be increased significantly.
The drains are also required to transfer spillages of hydrocarbons to a safe locationand if blocked or restricted could result in a pool of liquid which could result in a fire.
Examples • A flooded drain was noted on the edge of the process area.
• Channels to discharge LPG out of the storage area are partially blocked by earthand vegetation.
EPCL Post SurveyComment 2011
We will enhance the drain cleaning frequency; this is an on-going process.
Status October2012
In general, drains were clean and the recommendation is COMPLETE.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
11-07 Risk Based Inspection
Category 3
Recommendation Develop a risk based inspection programme, including recording and analysis systemsin advance of the next plant turnaround.
Reason Whilst the plant is approx. 17 years old, there was limited inspection activity prior to thetakeover of the site by Indorama. Since then there has been a huge increase in theamount of inspection activity undertaken. Until now this has concentrated on ensuringthe integrity of the existing assets. However after the next turnaround, there will beadequate data available to start a Risk Based Inspection (RBI) programme. This willrequire trending of wall thickness data to determine corrosion rates and remaining lifeof materials.This process would be facilitated if systems for storage and analysis ofdata were in place prior to the next turnaround.
Examples Currently, there is no programme for trending of inspection data.
EPCL Post SurveyComment 2011
For RBI, as suggested, a system is under development by trending of piping thicknessdata by December 2011.
CTt Comment Trending of wall thickness reduction is only one aspect of RBI but a necessary one. An analysis of the consequences of failure is also necessary to help in focusinginspection efforts in the areas of greatest loss potential both in terms of frequency andmagnitude.The following references give a general overview of risk based inspectionprocedures:http://www.hse.gov.uk/research/crr_htm/2001/crr01363.htmhttp://www.dnv.com/binaries/13_paper_aem_%20paper_final_tcm4-367866.pdf
Status October2012
There has been limited progress, possibly due to the departure of the inspectionmanager. The recommendation is IN PROGRESS.
11-08 Corrosion Under Insulation
Category 3
Recommendation Increase inspection of high hazard areas where Corrosion Under Insulation (CUI)might be present. In particular inspection should concentrate on areas where theinsulation is damaged.
Reason Corrosion, if unchecked, will result in thinning and rupture of the pipe and the possiblerelease of hydrocarbon materials with the subsequent potential for fire or explosion.
Examples There are numerous places in the process and storage areas where damagedinsulation is present and in some cases vegetation growing. A specific case is thepipework at the base of the refrigerated ethylene storage tank.
EPCL Post SurveyComment 2011 Most CUI inspection is done during TAM. We shall enhance scope during TAM 2012as per hazard. CUI can be minimised by insulation repairs that should be taken upthoroughly in the whole complex on priority.
CTt Comment The problem with CUI is the lack of visibility of corrosion as it hidden beneath theinsulation. Where repairs are made to insulation, it is necessary to check and ensurethat there is no CUI before repairing the insulation. Repairs to insulation will notprevent pipework rupture if corrosion is already present.As a minimum, a register ofsuspect locations should be established and inspections made as quickly as practical.In many cases, CUI inspections can be undertaken outside of a TAM.There are alsotechniques, of varying effectiveness, which can be applied to check for CUI withoutremoval of insulation.The implementation of an RBI programme will assist in identifyingthe piping sections which should receive priority.
Status October2012
Pulsed Eddy Current technology is being used to check for under insulation corrosion.Note that whilst this will work for many applications, there are some areas where it isunsuitable.
The recommendation is considered to be IN PROGRESS.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
11-09 Fireproofing
Category 2
Recommendation Review the condition of fire proofing in the process areas and, where appropriatemake repairs.
Reason Fire proofing provides protection against damage to steelwork from thermal radiationand direct flame impingement. If the fire proofing is damaged, even in only one areathe protection will be damaged.
Examples Fireproofing was damaged in a number of locations in the process areas. Most of thedamage noted was on structural steelwork. Fire resistant panels had been attached ontop of steel beams.
EPCL Post SurveyComment 2011
We are reviewing it considering relevant API standard.
CTt Comment The comment above is applicable for areas where additional fireproofing is required.
However, it does not cover repairs required to existing fireproofing.Status October2012
A specific response to the recommendation was not obtained but no problems werenoted on site. Pending confirmation from EPCL that the repairs are complete, therecommendation is considered to be IN PROGRESS.
09-01 Sampling Procedures
Category 1
Recommendation Review the current sampling procedures (and their operation in practice) for liquefiedgases and, if possible, revise the procedure to avoid the release of process fluids during
Vegetation growing inprocess piping
Refrigerated ethylene tankpipework with corrodedinsulation
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
the sampling procedure.
If not yet completed, a Job Safety Analysis (JSA) should be undertaken for samplingactivities.
Reason The current sampling procedures involve the release of process materials toatmosphere. If incorrectly operated, valves can freeze leading to an uncontrolled
release of hydrocarbons. If ignited, a serious fire or explosion could occur. An exampleof this occurred at Feyzin in France in the 1960s(http://shippai.jst.go.jp/en/Detail?fn=2&id=CC1300001).
Where necessary, provide appropriate training.
Examples Liquefied gas sampling procedures in the olefins plant.
EPCL Post SurveyComment 2009
We will review current procedure and ensure proper implementation to avoid release ofhydrocarbon mixtures during sampling.
Status May 2011 A JSA is reported to be in place and some sampling points go to flare. However theredoes not appear to have been a comprehensive review of sampling and development ofmethods of working which avoid the release of liquefied gases to atmosphere.
The recommendation is IN PROGRESS.
EPCL Post Survey
Comment 2011
We will do a comprehensive study for sampling and development methods of working.
Status October2012
Current practice is to purge to flare before sampling where possible rather than to purgeto atmosphere. Some piping modifications will be necessary before all purging toatmosphere ceases and these will be completed at the next turnaround.
The recommendation is IN PROGRESS.
09-02 Fire and Gas Alarm Systems
Category 1
Recommendation Review the adequacy of the existing fire and gas panels and make appropriate repairsand upgrades as necessary.
Reason Whilst considerable work has been done to repair and upgrade the fire and gas system,the system still appears to have a number of defects and its overall integrity may below.
Examples • Fault alarms were active on most of the fire alarm panels inspected in buildings andprocess areas.
• Some of the equipment at the site may be obsolete, for example the site usescatalytic pelletizer type flammable gas detectors whilst newer, more reliable, infrareddetectors are available.
EPCL Post SurveyComment 2009
Last year, we changed the Fire & gas alarm system of PE plant. This year, we would dosimilar job in PP plant. For other plants, depending on requirement we may change
phase wise. This would increase overall reliability.
EPCL It has been reviewed and JSA is in place now.
Status May 2011 All the Fire panels examined showed numerous faults. However this is understood tobe as a consequence of changes to the power supply to the panel and alarm loops. Inaddition, there were fire alarm lights illuminated in some places and, possibly, somegenuine fault alarms.
The recommendation is considered to be In PROGRESS.
EPCL Post SurveyComment 2011
Being reviewed from time to time.
Status October2012
No problems were noted in the fire and gas panels during the surveys. Therecommendation is considered COMPLETE.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
09-03 Control Room Doors
Category 2
Recommendation Install automatic door closers on the external doors in the control room building.
Reason Large heavy doors, such as those on the control room, can be cumbersome to openand close manually and there is a temptation to leave them open, particularly in a warmclimate. However the integrity of the control room is compromised when the doors areleft open. In the, unlikely, event of a major explosion there would be casualties withinthe control room and damage to control equipment.
Examples All process control rooms.
EPCL Post SurveyComment 2009
Matching with the integrity of blast proof arrangement of control room, the main doorsare made quite robust & heavy. Providing door closure may cause inconvenient. Anyway, we would review it.
Status May 2011 Control room doors in the PE and Olefin plant were in the open position during the
survey.There is NO CHANGE to the situation at the time of the previous survey.
EPCL Post SurveyComment 2011
Door closures are already installed. We will establish administrative control to ensuredoors are always closed.
Status October2012
The situation is UNCHANGED.
09-05 Document Control
Category 3
Recommendation Develop a document control procedure to ensure that:
• Key documents are "controlled" with the latest versions being accessible toregistered users and older versions destroyed.
• Uncontrolled copies can be clearly identified.
• Documents are written in an approved style with information such as date, revisionnumber, etc. clearly displayed.
Reason Currently EPCL are largely working with documents inherited when the site was underNNPC operation. Some key documents, such as Process and InstrumentationDrawings (P&IDs) have been updated and, it is understood that many other documentsare likely to be developed or revised now that the more urgent work of improving theplant’s mechanical integrity is completed.
Unless well-developed systems for the control of documents are developed, there is adanger of different versions of the same document being used by different people.
Examples • Currently the site P&IDs have been updated but the original "as built" drawings arethe ones available for reference in the plant control rooms.
• It is intended that many of the drawings, procedures, etc. will be available on thecompany Intranet. Unless, appropriate checks are built into the system, it will bedifficult to control downloading, printing and storage of uncontrolled documents.
EPCL Post SurveyComment 2009
EPCL will work to develop a document control system where copies are controlled.Conversion of hard copies of P&IDs to CAD format and field verification is to start soon.These documents shall be also part of the controlled documents.
Status May 2011 EPCL is modifying their document control procedures to comply with ISO 9000standards. This recommendation is IN PROGRESS.
EPCL Post SurveyComment 2011
We are gearing up for ISO9000, ISO14000 and OHSAS17000 certification. Thisrecommendation will be automatically complied with.
Status October2012
Whilst there has been some progress, there are still areas for improvement. A new
recommendation, 12-03, on this topic has been made and this recommendation isWITHDRAWN.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
09-06 Operator Emergency Training
Category 3
Recommendation 1. Review the existing emergency shutdown procedures and revise/update wherenecessary. Instructions should be written in a simple, easy to read, format.
2. "Short form" emergency instructions should be prepared as a standalonedocument. These could be in the form of checklists so that operators can confirmthat they have completed all the emergency actions required.
3. Institute an emergency simulation program for process operators so that they arefamiliar with required actions in the event of a process upset. The following pointsare offered for consideration:
• Process upset conditions should be considered in turn (e.g. loss power, losscooling water, etc.).
• Simulation training should be at the same time each week so that each shifthas the opportunity to practice each specific scenario.
•
Field operators should place tags on the valves they would operate to ensurethey know the correct location of the equipment.
• Panel operators should list the actions they would take.
• Field and panel operators actions can be checked and refresher trainingprovide if necessary.
Reason 1. Whilst the operating instructions reviewed did contain emergency shutdownprocedures, there were sometimes vague and in a difficult to follow format.
2. Simple one page, step by step, instructions are easier for operators to understandthan complex manuals.
3. In emergency situations, operators and supervisors are under increased stress andthe potential for mistakes increases. Training will reduce the potential for error.
Examples Current Emergency procedures examined are based on the original contractorsoperating instructions which are, in some cases, limited or out of date.
EPCL Post SurveyComment 2009
This will be reviewed in plant level.
Status May 2011 Whilst emergency procedures have been revised and emergency shutdown training(classroom based) takes place, it does not follow the practices outlined above.
The recommendation is considered to IN PROGRESS.
EPCL Post SurveyComment 2011
This is an on-going process and being done from time to time.
Status October2012
The recommendation is still not fully implemented, it was discussed in detail with theOlefin plant management and implementation is anticipated in the future.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
ARM Survey 2008
08-02 Analysis of Transformer Oil
Recommendation The study of gases from transformer oils can be used to give and early indication ofabnormal behaviour of the transformer and may indicate appropriate action that may betaken on the equipment before it suffers great damage. The frequency of the testingbeing determined by the nature of results obtained, with the interval being reduceddepending upon the rate of rise of gas concentration. Therefore, it is recommendedthat the facility follows current industry best practice of sampling and testing transformeroil every 12-18 months.
Reason It was indicated that the transformers' oil was sampled and tested during TAM1. Thisincluded Dissolved Gas Analysis (DGA) and dielectric testing. It was reported thatsimilar testing would be performed during TAM2 and subsequent turnaround.
Status June 2009 EPCL state that:
Transformer oil analysis being done with in-house resource. Suitable testing kit hasbeen purchased. Testing frequency is once every six months.
CTt Comment No further DGA analysis has been undertaken and the recommendation is considered
to be UNCHANGED.Status May 2011 Some limited new analysis has been performed but DGA is still not undertaken on a
regular basis.
The situation is UNCHANGED,
EPCL Post SurveyComment 2011
We do not have any gas in transformer. Oil quality checking procedure every sixmonths is established now.
CTt Comment It is not clear that the recommendation has been understood. DGA (Dissolved Gas Analysis) is a well-established technique to check for dissolved gas in transformers.Dissolved gases would be present as a consequence of a breakdown of the transformeroil and are indicative of impending failure.
EPCL have purchased equipment for use on site. However the results of analysis donot appear credible and samples are being sent off site for analysis in a specialistlaboratory.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
CTC 2006 Recommendations
06-01 Fire Detection/Protection Impairment System
Category 1
Recommendation Develop an Impairment programme so that equipment which is out of service or beingused for non-firefighting purposes is recorded and corrective action is taken as quicklyas possible.
Staff and contractors should be made aware of this requirement.
Reason Considerable effort and expense has gone in to the renovation of the site, including thefire detection and protection systems and whilst most equipment is in much bettercondition than at the start of 2006, there are many systems where repairs are not fullycomplete and there may be confusion over the operational status of equipment.
In addition fire water is still being used for cooling and other non-fire related purposes.
Finally, an up to date report with the status of all fire detection and protection systemswould be useful to insurance underwriters at the completion of TAM1 and the start-upof plants.
Examples Whilst the use of fire water for process cooling is much improved from the situationbefore TAM1, there are still some cases where fire water is used for cooling. Inaddition, there is considerable (uncontrolled) use of fire water for purposes, such aswash down of process areas. Fire hoses used for these purposes are evident inseveral parts of the site and the volume of water is such that the one of the mainelectrically driven pumps is operating continuously to supply demand.
In addition a number of defects, which have not yet been repaired were noted, wherethese exist additional safety precautions will be necessary to ensure that safety of thefacilities are not compromised. These include:
• One diesel fire pump is not operational.
• Defects to the control system of a second system appear to exist.
• The dry powder system protecting the catalyst area in the polypropylene plant is
not fully functional.• The "trouble" alarm on the gas panel in the olefins plant is illuminating.
• Status of fire detectors in the office block is uncertain.
This is probably not a complete list.
Status June 2009 EPCL State that:
With the revamp of the fire detection and protection system in PE the system now existin all plants.
CTt Comment Some defects were noticed in many of the plants, this recommendation is consideredto be IN PROGRESS.
Status May 2011 The diesel fire pump and catalyst systems are now reported to be operational. Theother aspects are also covered in 09-02. This recommendation was consideredcomplete.
For future reference, details of an impairment system are available from Liberty Mutualvia the internet. A copy is attached in Appendix B.
Status October2012
Parts of the sprinkler system in the Polyethylene plant warehouse were isolated.These systems were not clearly marked and did not appear to be known to firefighters.
In effect there has been no progress on this recommendation and the status isUNCHANGED.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
06-03 Under Insulation Corrosion
Category 1
Recommendation Increase the speed of the under insulation inspection programme. The programmeshould be prioritised so that the most hazardous piping (based temperature, pressure,contents and corrosion potential) is inspected first.
Reason The inspection programme has so far only considered a small proportion of the pipingwhere under insulation could exist. A leak of hydrocarbon material from a corrodedpipe could result in a serious fire or explosion.
Examples Currently approximately 10% of the pipework has been checked for under insulation.From visual inspection, there are many places where the external weather protectionover the insulation has become damaged, with the potential for water to seep into theinsulation, possibly causing corrosion.
Status June 2009 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. Thisrecommendation is considered to be IN PROGRESS.
Status May 2011 This is an on-going process and is IN PROGRESS.
EPCL Post SurveyComment 2011
Action is initiated.
Status October2012
The requirements of this recommendation are also covered in recommendation 11-08and this recommendation is WITHDRAWN.
06-10 Management of Change
Category 3
Recommendation Review the management of change procedure to:
1. Provide clear guidance on the criteria by which changes are considered trivial andthose which require a more detailed safety assessment, including a HAZOP study. A sample checklist which may prove useful is given in Appendix C.
2. Update the procedure to include changes to staffing levels and job functions.Further information is given in Appendix D and a sample method of is given in:
Reason 1. The lack of clear criteria to determine if detailed assessment is necessary couldresult in hazardous changes being approved without adequate assessment.
2. The lack of an assessment procedure for staffing changes could result in the
introduction of hazards in situations where staffing levels change, job descriptionsare altered, etc.
Examples The aspects discussed above are not included in the current Management of ChangeProcedure.
Status June 2009 EPCL State that:
MOC system implemented. SOP available on the internet.
CTt Comment Some aspects of the MOC procedure still require improvement and thisrecommendation is IN PROGRESS.
Status May 2011 There appears to be NO CHANGE since the 2009 survey.
EPCL Post SurveyComment 2011
This is a well-established procedure but there is scope for improvement and is beingdone.
Status October2012 This is reported to be COMPLETE.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
06-11 Emergency Plan
Category 3
Recommendation Review the existing Emergency plan to provide a greater level of detail in areas suchas:
1. The provision of an adequately equipped emergency coordination centre in a safeand accessible location.
2. Review the format of the plan to see if it can be restructured for improved clarity.
3. Prepare fire pre-plans for likely fire situations.
To ensure that the practicality of the plan a full scale or desktop exercise should beperformed.
Reason 1. The current location of the emergency coordination centre is undecided. Oneoption appears to be the use of the fire station control room. It is generallyconsidered preferable to use a room without distractions close to the main entrance.
2. The current emergency plan is comprehensive but the information is not alwayseasily accessible. Key facts are hidden in complex paragraphs and may be
overlooked during an emergency when staff will be in a highly stressful situation.Greater use of bullet points, flow charts, and shorter paragraphs would assist andsome information aspects could perhaps be transferred to appendices.
3. Currently there are no detailed plans for fire fighting in some of the areas withsignificant fire potential. Preplanning will allow a faster response to a fire, resultingin a lower level of damage. An example is given in Appendix E.
Examples Site emergency plan.
Status June 2009 EPCL State that:
SOP for emergency procedures existing. On Site Emergency Management Plancompleted and available on the Intranet.
CTt Comment Some aspects, such as pre-planning are still not complete. The recommendation isconsidered to be IN PROGRESS.
Status May 2011 There has been an element of pre-planning but further progress is possible, includingthe provision of thermal radiation modelling to allow position of fire trucks to be fixedand the nearest fire hydrants identified.
The recommendation is IN PROGRESS.
EPCL Post SurveyComment 2011
Being reviewed from time to time.
Status October2012
Some preplans have been developed but these are generic and not specific to eachplant area or storage vessel.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Recommendations Prior to 2005
No. Title Summary Status in 2006June2009 Status
(EPCL Comments) May 2011 StatusOctober 2012
Status
03.03 LiquidEthyleneStorageTank
Variousrepairs to theethylene tank.
IN PROGRESS
Progress had beenmade in the area butsome work still needs tobe done. Examples arethe rod hanger on oneof the ethylene pipes tothe tank and insulationaround the liquidethylene pumps.
COMPLETED
Note that site visitsindicated that the rodhanger has still notbeen replaced.
Some repairs to theethylene tank remain.The recommendationis IN PROGRESS.
EPCL Post SurveyComment 2011 - Weare reviewing theengineeringcompany.
A technical review ofthe rod hanger hasbeen undertaken andthe hanger found tobe unnecessary.However, theanalysis might nothave considered thefact that the hanger issupporting thebellows (which showssigns of distortion)and not a section ofpipe. It would beprudent to repeat theanalysis including the
bellows.The recommendationis IN PROGRESS
Piping Support with RodHanger Missing – the situationsince at least 2003
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
No. Title Summary Status in 2006June2009 Status
(EPCL Comments) May 2011 StatusOctober 2012
Status
03.04 Use ofCellular
Telephones withintheProcessPlant
Use of mobilephones within
process plant.
NO CHANGE
Personnel using phones
were noted in severalareas including adjacentto the DCS panels,where there is concernthat the mobile phonesignal could interferewith the DCS.
Examples of mobilephone use in
hydrocarbon areaswere found duringthe survey. Itappears that mobilephones are acommon form ofcommunication at thesite.
There is NOCHANGE to theprevious situation.
EPCL Post SurveyComment 2011 - Theoretically innormal running plantscellular telephonesdo not pose any
hazard.CTC Comment –There is noconsensus over thehazards posed bymobile phones butmany companiesprohibit their use inelectrically classifiedareas.
The situation isunchanged from
2011, seniormanagement werenoted using cellularphones
The practice isdifferent from mosthydrocarbon facilitieswhere the use ofmobile phones isforbidden andphones are often notallowed in thehydrocarbonfacilities.
The situation isUNCHANGED
98.01 RemoteOperatedIsolationValves
InstallRemotelyOperatedvalves forprocessisolation in
emergencysituations
IN PROGRESS Out of 4 additionalROVs identified forinstallation 2 arealready installed and 2are procured waitingshutdown for
installation
All 4 of the originallyproposed ROVs arenow installedHowever, there arestill a number oflocations where there
are vessels with largeinventories and noROVs installed.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
4. Exposure to Perils
4.1. Property
4.1.1. Fire and Explosion
Fire and explosion risks are inherent in hydrocarbon facilities. The potential size of a losswill be determined by the inventories of hydrocarbon materials, spacing and fire protection
facilities. The likelihood of a loss is related to operating and other procedures. These arediscussed in detail in the main body of the report.
4.1.2. Surrounding Exposures
The nearest large industrial site is NNPC’s Port Harcourt refinery (approximately 6 km
away), there are also some oil production facilities (approximately 5 km away). There are no
significant industrial activities around the EPCL site and exposure is considered low.
The Natural Gas Liquids (NGL) pipeline feeding the site terminates at a custody transfer point
in a Nigerian Agip Operating Company (NAOG) terminal at the North West corner of the site.
Local communities extend to the outer perimeter fence in some places. The process and
storage facilities are located well away from the boundary fences and would not be exposedto small fires from shanty dwellings, car fires, etc.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
4.1.3. Subsidence and Collapse
No serious signs of subsidence or collapse were noted during site visits, although there was
very minor damage to some pipe support footings, reportedly as a result of erosion fromcondensate drains noted in a previous survey. Some damage to concrete covers over cable
trenches was also noted.4.1.4. Earthquake
The Munich Re"Globe of Natural
Hazards" rates the
area as Zone 0equivalent to
Modified-Mercalli Vand below.
4.1.5. Tsunami
The Munich Re "Globe of Natural Hazards" does not consider the area to be exposed to
tsunami. In any event the plant is set well back from the coast.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
The Port Harcourt international airport handles both fixed wing and helicopter flights and is
located approximately 25 km from the site. The Nigerian Air Force (NAF) airbase is approx.5 km from the site. This has a mixture of military flights plus some fixed wing and helicopter
flights. Flight paths are reported to avoid the EPCL site and no aircraft were noted overflyingduring the survey.
4.1.13. Riot Str ike and Civil Commotion
The 2012 Aon "Political Risk Map" rates Nigeria as High, the second highest of six ratings on
the scale.
There have been inter-tribal conflicts in the River State in recent years, together with a
depressed economy. In consequence some serious anti-oil industry incidents, includingtheft, vandalism and sabotage have occurred. These have primarily affected the upstream
oil industry but the downstream sector has also been affected.
There has been previous resentment by the local community in the past which culminated in
the kidnapping of a number of Indorama employees and dependents (including women andchildren) some years ago but relationships with the local communities are now reported to
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
be very good. All Indorama’s ex-pat staff and their families are now housed within the siteboundary.
4.1.14. Terror ism and Sabotage
The 2012 Aon "Terrorism and Political Violence Map" rates Nigeria as Severe Threat, thehighest of five ratings on the scale.
There has previous been considerable unrest in the Niger Delta region of Nigeria and the
Nigerian Military has conducted operations against armed gangs in the region. There havebeen a number of incidents, including kidnapping, shootings attempted invasion of oil
industry facilities, piracy and sabotage.
Much of the violence is financially motivated with kidnapping for ransom and theft of refined
oil products (sometimes resulting in fires). The Products at EPCL cannot easily be resoldand there are understood to have been no significant attacks or theft from EPCL facilities.
4.2. Machinery Breakdown
Brief details of the machinery breakdown are given in the table below:
Exposure Comments
Boilers and FiredHeaters
The major fired heaters are the crackingfurnaces in the ethylene plant plus boilers.
The major risk associated withequipment of this type is tube rupturewhich will generally cause limiteddamage.
However in extreme situationsexplosions can occur causing totaldestruction.
A number of tubes have leaked and havebeen sealed off; there do not appear to
have been any serious incidentsassociated with tube rupture.
Rotating Equipment There are a large number of rotatingequipment items, the key items being:
• HP compressors, particularlyassociated with the ethylene plant.
• Extruders associated with the twopolymer plants.
• Gas turbines.
There is a wide range of incidents whichcan lead to damage of rotatingequipment leading to varying levels ofdamage. Under most circumstances,damage will be limited to the rotatingelements of the machine but, in extremecases, total destruction can occur.
Transformers There are a number of large transformerson the site. Many transformers have firewalls between adjacent units but fixed fireprotection is not installed.
A fire involving a transformer is unlikelyto spread to adjacent equipment,however, in the unlikely event of atransformer explosion, fire walls could failresulting in additional damage to nearby
units.
Others Catalysts In some situations, catalyst life can bereduced or destroyed as a result ofprocess upsets or damage caused by fireor other perils.
4.3. Construction
Major Construction projects are planned over the coming years. A new ammonia - ureacomplex is currently scheduled to start construction at the beginning of 2013 and an
expansion to the ethylene cracker towards the end of 2013.
These projects, particularly the latter, are likely to result in significant cross exposures.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Anticipated hazards include:
Exposure
Interface withExisting Equipment
• Separation• SIMOPS
• barriers
Storage • Separation
• Value of material stocks
• Preservation
Hazardous Materials • Radioactive material
• Pickling chemicals
• Other hazardous chemicals
Fire and Explosion • Smoking
• Explosives for civil work
• Welding
• Fabrication areas
• Hot tapping
Pressure Testing • High pressure leak or pressure testing
Commissioning • Isolations
• Instrument bypassing
• Communication with existing plant
• Impairment of fire protection systems.
Excavations • Buried services
• Trench collapse
• Flooding of trenches
Cranes • Collapse
• Dropped object
At the time of the survey, there was too little information available for the extent ofconstruction hazards to be analysed.
4.4. Business Interruption
The site is self-sufficient in utilities but requires the supply of NGL from Agip as feedstock for
the process units. Natural gas is also imported for use as a fuel but could be substituted bydiesel fuel in the gas turbines.
There are problems with the limitation of feedstock from Agip and this sometimes leads tothe reduction in output from the units. This was the case at the time of the survey, with
production being limited due to flooding problems at the Agip site.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
5. Loss Estimates
5.1. Definitions and Loss Scenarios
There are numerous definitions for defining levels of damage. Probable, Maximum Loss
(PML), Estimated Maximum Loss (EML), Maximum Amount Subject (MAS) are amongst theterms in common usage. However, they are defined in different ways by different
organizations. Definitions used in calculation of EML by CTT are given below:
• Probable Maximum Loss (PML) – The loss that could occur if the installed safety
systems and fire protection systems operated as intended once the incident wasidentified. Such events would be fires and explosions.
• Estimated Maximum Loss (EML) – The loss that could occur if safety systems and fixed
fire protection systems were unable to function as a result of the incident. Such eventswould be the rare but highly destructive and include detonations, Vapour Cloud
Explosions (VCE) and High Pressure Vessel Ruptures. (HPVR).
• Maximum Amount Subject (MAS) – A catastrophic loss which could result in major
damage, or total destruction of a site. Such an event would overwhelm the processsafety systems and fixed fire protection systems. Such events would be natural perils,
such as a major earthquake or extremely rare events such as aircraft impact.
In general, only the EML event is calculated, as this is of the greatest significance tounderwriters.
5.2. Property DamageThe following replacement values have recently been estimated by AVC and are used to
Note 1: 50% of cyclohexane assumed released (some parts of the circuit are at lower than maximumtemperatures and pressures)
Using the Swiss Re ExTool method with an explosion efficiency of 6% for unsaturatedhydrocarbons and 4% for saturated hydrocarbons, the worst case scenario is a release ofethylene from the C2 Splitter Reflux Drum (The largest release of olefins at the site) resulting
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
After making the following allowances, the loss estimates are given below:
• Fire following the initial explosion – 10%
•
Damage outside the plot areas – 10%
• Debris removal – 10 %
• Fire Fighting – 1%
• Inflation – 9% (based on 3 years at 3% per annum the loss occurring on the last day of
the policy year, plus a two year rebuilding period).
The loss is estimated at approximately: USD 435 million.
Note that underwriters’ exposure might be reduced as some of the factors included in thecalculation (e.g. debris removal and fire fighting expenses) have been excluded from the
valuation.Damage contours are shown below:
5.3. Property Damage Business Interruption
A major vapour cloud explosion would result in large scale destruction of the plant involving
a long period of downtime and replacement of major vessels and equipment.The sum insured for Business Interruption is USD 300 million for a 12 month indemnityperiod.
A repair time of around 24 months would normally be expected in this situation and the loss
is estimated to be USD 600 million but underwriters’ exposure would be limited to the USD
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
5.4. Machinery Breakdown
The largest machine at the site is understood to be the Olefin Plant Cracked Gas
Compressor. The replacement value for this unit was not obtained but by comparison withsimilar sized plants, a replacement value of USD 17 million in 2006 has been assumed. An
increase in replacement cost of 25% has been assumed, giving a replacement cost ofapproximately USD 22 million.
Whilst total destruction of a machine is rare, it may occur and two scenarios are postulated:
USD Million
Cost of Machine 22
Damage to Rotating Elements
(50% loss of machine value and 20% cost to strip the machine, replace therotor and rebuild the machine)
15.4
Addi tional Costs
Inflation for 21 months at 5% per annum (incident on last day of policy year and9 month replacement)
3.6
Total 19.0
Destruction of Machine
(100% loss of machine value and 20% to remove and replace the machine) 26.4
Addi tional Costs
Inflation for 30 months (incident on last day of policy year and 18 monthreplacement)
6.3
Total 32.7
5.5. Machinery Breakdown Business Interruption
The major machinery breakdown business interruption potential will result from a failure of
one of the compressors in the ethylene plant. Using the same two scenarios as above, thefollowing would apply:
1. Destruction of the rotating elements of the machine.
Assuming spare parts are available, repairs – and a resumption of production –should be possible within a two-month period. The loss would therefore be:
USD300/6 = USD50 million
2. Total destruction of the machine.
The worst case scenario would be total destruction of the compressor with a
replacement time in the range 12 to 18 months. The loss would therefore be:
USD450 million
Note that the indemnity period would limit the underwriter’s exposure to USD 300
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
5.6. Summary of Loss Estimates
Scenario
PropertyDamage
(USD
Million)
BusinessInterruption
(USD
Million)
Combined
(USD Millions)
Property Damage Vapour cloud explosion in the olefinplant following a release from the C2splitter reflux drum
435 600 1,035
MachineryBreakdown
Damage to the rotating elements ofthe olefin plant cracked gascompressor
19.0 50.0 69.0
Complete destruction of the olefinplant cracked gas compressor
32.7 450 458.4
Note that underwriters exposure will be limited to USD 300 million (the policy limit with a 12 month indemnityperiod) for business interruption losses.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
6. Description of Installation
6.1. Production Facilit ies
EPCL operates a petrochemical complex producing ethylene and propylene for themanufacture of polyethylene, polypropylene and butene–1. Raw material is an ethane richNatural Gas Liquids (NGL) feed from the Obiafu-Obrikom Natural Gas Liquids separation
facilities operated by Agip (as a NNPC Joint Venture). There are currently feedstockproblems due to flooding at the AGIP facilities which currently limit production in the olefinsunit to 85 – 90% of capacity. Prior to the flooding, the olefins plant was operating at full
capacity. The downstream units are operating at 70 – 80% of capacity.
Further feedstock in the form of propylene from the Fluidised Bed Catalytic Cracker (FCC),
at NNPC’s Port Harcourt Refinery, can be imported for use in the polypropylene plant.
However the Port Harcourt Refinery FCC unit is often not operational and propylene isseldom supplied. Simple unloading facilities have been installed to unload Propylene RichFeed (PRF) from NNPC’s Warri refinery but, again, this is not done on a regular basis. One
of the cracking furnaces can operate on Virgin C5 feedstock.
Pyrolysis gasoline, a by-product of the olefins plant, can be exported by pipeline to the
1995 Four of the six cracking furnaceshave been retubed using KelloggBrown and Root (KBR) SCOREtechnology. The plant hasreached production capacities of305 – 310,000 tonnes per yearfor short periods but is nowoperating at approx. 55,000tonnes per year.
Polypropylene(PP)
80,000 Montel (exHimont)-Spheripoltechnology
TechnimontSpA andJapanese GasCorporation(JGC)
1995 Currently there is nopolypropylene supply from thePort Harcourt refinery and theunit runs on propylene providedfrom the olefin unit. Theprocessing of a VC5 stream andthe import of PRF (PropyleneRich Feed) from Warri hasincreased the availability offeedstock.
Due to feedstock limitations theplant previously ran in campaignmode but is now operating at 70- 80% of capacity. Thisrepresents a safer mode ofoperation than the frequent start-ups and shut downs associatedwith campaign mode.
The plant has run at up to 50%above design. Throughputs will
vary with grade of polymer beingproduced.
Total production for 2012 isexpected to be 58 – 60,000tonnes. Run times have beenup to 98 days.
There are 2 extruders eachcapable of 100% of production.One unit is original andscheduled for replacement, theother is a new unit.
Polyethylene(PE)
270,000 Nova (Du-Pont)Sclairtechtechnology
Kobe Steel 1995 This is a medium pressure unit,operating at approx. 145 bar g.270oC. Twin extruders areinstalled
The plant has beendebottlenecked, which hasincreased the capacity to302,000 tonnes/year. The plantis operating at 70 - 80% ofcapacity but has run atthroughputs up to 15% aboveoriginal design capacity.
Throughput will vary with thegrade of polymer beingproduced.
There are 2 extruders, eachsized for approximately 75% ofcapacity.
One unit is original andscheduled for replacement, theother is a new unit.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
6.1.2. New Projects
EPCL are planning a series of new projects at the site. The first is likely to be a new
ammonia urea plant with construction expected to start in the first quarter of 2013 and with a36 month construction period.
A new gas line from Agip will be constructed as part of the project, along with urea export
facilities to a marine jetty.
There are also plans to increase the capacity of the olefin plant by 50%, including theaddition of three new cracking furnaces, plus an HDPE plant. This work is expected to start
towards the end of 2013. There will also be a number of modifications to the existingfacilities, including re-wheeling of the main compressors and changes to column internals.
This is likely to involve significant construction work within the existing olefin plant facilities,some work is likely whilst the plant is operational and a good SIMOPS system is essential.
A new methanol plant is also envisaged in the future.
Whilst the construction of additional process units at the site was envisaged at the designstage and space is available, conditions within the site boundary have changed significantly
with a significant number of people, including families, now being housed within the site. Additional accommodation is currently under construction.
The construction of the ammonia plant, in particular, changes the hazard profile of the site,
presenting a major toxic hazard. It would be prudent to undertake a comprehensiveconsequence modelling study before the plant design has been "frozen" to ensure that fire;
explosion and toxic risks are assessed and minimised.
6.1.3. Process Hazards
• Fire: Fires can occur in almost any location which contains
combustible or flammable material or electricalequipment. Simple procedures such as good
housekeeping and control of smoking can reduce thehazard to acceptable levels.
• Pool Fire: Pool fires occur, following a leakage of flammable
liquid which collects in a low point and ignites. Fires
can vary in size from small fires originating from a
pump seal or flange leak, to whole roof fires on largestorage tanks. Large fires involving stock tanks give
rise to high levels of thermal radiation and mayspread from one tank to its neighbours if tanks are
located too close together.
• Jet Fire: Jet fires occur following release of high pressure gas
or liquid from an orifice, typically a pipe flange. Fires
of this type generate long flames with high levels ofthermal radiation.
• Explosion: Most explosions are relatively small and occur as a
result of ignition of small amounts of flammable gasesor liquids in a confined space. However sometimes
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
• Vapour Cloud Explosion (VCE): VCEs are amongst the most destructive events thatcan occur in the oil and petrochemical industries.
They occur following the release of a cloud of
flammable gas which ignites. They are mostdestructive in areas of congestion such as processareas.
• Boiling Liquid Expanding
Vapour (BLEVE):
A BLEVE occurs when the wall of a pressure vessel is
overheated by external heat to the point when it
cannot withstand the internal pressure of thecontents. When the vessel ruptures, the contents, ifthey are flammable, will ignite generating high but
short lived levels of thermal radiation and limitedoverpressure.
• Mercury: Mercury in very low concentrations is sometimesfound in gas fields. The mercury may concentrate in
processing equipment and may cause damage. Ofparticular concern are aluminium vessels and heat
exchangers where rapid failure may occur.
Tests for mercury are reported to have beenundertaken and no traces found at the parts per billion
(pbb) level.
• Pressure Vessel Rupture: In some situations a vessel can rupture either due toexcessive internal pressure or a defect in the vessel,
for example due to corrosion. The consequences arelikely to be a mixture of blast effects and some
projectile damage.
• Toxic Materials: Whilst exposure to high levels of any gas is
undesirable, there will be significant hazards fromammonia in the future when the new ammonia and
urea plants start up.
• Runaway Reactions: Some chemical reactions have the ability to"runaway" or accelerate to a point when they are out
of control. This can occur, for example, when power
failure occurs (which prevents effective missing) or ifcooling water failure occurs (which will prevent theremoval of the heat of reaction). The polypropylene
unit, currently shutdown is considered to have the
major exposure.
Special precautions, such as emergency cooling
water supplies or reaction "kill systems" arenecessary in such situations. Additionally, physical
precautions, such as blast walls, may also berequired.
•
Pyrophoric Materials:Some materials, particularly polymer catalysts, are
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
6.1.4. Layout
Brief details of the layout are given in the table below:
Details Comments
General The existing process units are located tothe south of the site.
There is plenty of space for futureexpansion and the new accommodationfacilities constructed at the site areremote from operational and storageareas.
The Natural Gas Liquids (NGL) pipelinefeeding the site terminates at a custodytransfer point in a Nigerian Agip OperatingCompany (NAOG) terminal at the plantnorth west corner of the site.
The process and utilities are arranged in 2rows west to east in the following order:
Row 1 (northerly row)
• Polypropylene warehouse.
• Polypropylene production.
• Power plant.
• Cooling Water Systems and WaterTreatment.
Row 2 (southerly row).
• Polyethylene warehouse.
• Polyethylene production.
• Olefin Unit.
• Vacant plot.
• Air separation and compressed airutilities.
These facilities are on individual plotsapproximately 150m by 250m, withseparation by road, approximately 12 mwide.
Storage facilities are located to the east ofthe site.
Much of the area is open, particularlyaround the main administration building.This will limit the hazard faced by
employees in the building in the event ofa major explosion. Spacing between thevarious process, utility and storagefacilities is also good, limiting thepotential for domino effects from onearea affecting adjacent areas. This is, inpart, due to anticipated future expansionat the site, which has not so far takenplace.
Spacing within the process areas iscongested in some locations.
This could limit access for maintenanceand inhibit firefighting.
The new ammonia and urea plants arebeing constructed to the north of Row 1and the HDPE unit to the south of row 2.
The flare-stacks and burn pits are locatedto the East of the currently unoccupiedareas, with adequate sterile areasdefined.
Process areas are on concretefoundations surrounded by areasbackfilled with stone.
In some locations damage to theconcrete pads supporting minor items ofstructural steelwork was noted.
Piperacks The level of fireproofing on piperacks isvariable between process units.
Generally pumps are not located under orpartially under piperacks.
This will greatly minimise the potential forthe fin fans to affect the extent of the fire.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
6.2. Control and Process Safety Systems
6.2.1. Basis
Brief details of the control system are given below:
Details Comments
Configuration On the olefins plant the trip systems areintegrated into the DCS. The polymerplants have independent ESD systems.
Fully independent ESD systems areconsidered preferable to integration ofthe trip functions within the DCS.
No SIL analysis has been undertaken inany of the plants by EPCL.
Type Yokagawa Centum 3000 DCS’(Distributed Control Systems) are installedin all units.
The original DCS systems wereupgraded in the 2010 TAM.
Neither the existing or new plants have
alarm management functions.
A number of companies have
experienced problems, with "alarmflood", during a major incident1. This
results in literally hundreds of alarmsbeing activated within a very short spaceof time. When this happens, the sheervolume of alarms makes it difficult foroperators to follow the exact sequence ofevents. Alarm management systemsassist by filtering out the less importantalarms.
6.2.2. Control Room Design
Brief details are given below:
Details Comments
Location Each of the process units has anindependent control room. In additionthere are control rooms for the powerstation and the storage area.
Construction Process control rooms are blast resistantstructures but appear unpressurised.Whilst automatic door closers wereoriginally fitted, these have, in somecases, been removed or are ineffective,as in the polyethylene plant. Thereforedoors may be left open, defeating theblast resistance. Some control rooms are
located close to the process facilities.
All the process control rooms had thedoors in the open position during thesurvey which would negate the blastresistance of the structure.
Smoke Detection The control rooms have fire detectionsystems.
Fire Protection The control rooms have fixed fireprotection systems covering the controlsystem and adjacent instrument rackrooms.
In some cases doors between the controland rack rooms are left open which willprevent the gaseous systems workingeffectively. This is believed to be due toproblems with the air conditioning systemand once repairs are made doors will bemaintained in the closed position.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
6.2.3. Emergency Shutdown Systems
Brief details are given below:
Details Comments
Type The olefins plan has the trip systemsintegrated into the DCS. The polymerplants have independent ESD systems.
Fully independent ESD systems areconsidered preferable to integration ofthe trip functions within the DCS.
No SIL analysis has been undertaken inany of the plants by EPCL.
The ESD systems are hard-wired systemsand are not dependent upon computersoftware for operation. In some cases,these are two out of three (2-O-O-3)voting systems.
The polymerisation reactions areexothermic. Both have shutdown systems
and the PP plant has a catalyst killsystem, which injects CO into the reactorsto kill the reaction immediately stoppingreaction heat generation.
This system worked successfully duringthe power failure earlier in 2011.
6.2.4. Remote Isolation, Depressur isation and Blowdown
When originally constructed, there were relatively few Remotely Operated Valves (ROVs)installed in the Olefins unit. ROVs are frequently installed in locations, such as pump suctions
to prevent the contents of upstream vessels (such as drums and columns) being released toatmosphere in the event of a pump seal failure. This issue has been highlighted in previous
survey reports and EPCL have installed ROVs in four locations, most recently, on the C2 andC3 splitter reflux drums. There do appear to be some locations, for example the pumps
feeding the bottom section of the C3 splitter, where it may be prudent to install valves.
An ROV is installed on the feed drum in the polypropylene plant but the cabling is notfireproofed. If a leak of propylene ignites, the valve may quickly become inoperable.
ROVs are installed on the spheres and ethylene tank.
6.2.5. Pressure Relief Systems
Brief details are given below:
Details Comments
Configuration: With some exceptions single pressurerelief valves have been installed onprocess duties. On a few duties, pressurerelief valves are duplicated.
It is difficult to test relief valves when theplant is operating when there are onlysingle valves.
Duplicated relief valves are installed onthe spheres, complete with Castell keyinterlocks to ensure that a relief line isalways open.
Some, at least, of the Castell2 key
systems are not functioning and havebeen replaced by a car seal system.
This will allow a valve to be removed fortesting and inspection whilst the plant isin operation without the necessity ofeither taking the unit out of service orwaiting for a shutdown.
The use of car seals appears to beuniversally applied to pressure reliefsystems at the site.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
6.2.6. Combustion Safeguards
Boilers, furnaces, and direct-fired heaters have fuel gas management systems.
Fuel gas isolation consists of a double block and bleed system.
6.2.7. Shaft SealingMany of the pumps at the site handle liquefied gases and are fitted with double mechanical
seals and seal failure protection.
Compressors have wet type seal systems rather than the more modern dry type.
A triple mechanical seal has been fitted on the agitator on the polyethylene plant reactor.
6.3. Feedstock Supply and Product Transfer
6.3.1. Road
The main products (polyethylene and polypropylene) are solids and packed in bags onto
pallets and are exported by road.
There are occasional road exports of liquefied gases from the site by a road tanker. Loading
takes place in the offsite area by armoured hoses.
A new installation for the import of Propylene Rich Feed from Warri has been installed. This
is a basic system with discharge via armoured hoses. A simple earthing system is installed.So far, this has only operated intermittently.
6.3.2. Pipeline
There are a number of principle pipelines entering and leaving the site, brief details are givenbelow:
Product From/To Length Comments
Natural Gas Liquids(NGLs)
Obaifu-Obrikomgas separationplant.
85 km The NGL and fuel gas line follow acommon routing.
Fuel Gas Obaifu-Obrikomgas separationplant.
85 km The NGL and fuel gas line follow acommon routing.
Fuel gas from this line would be requiredfor start-up but once continuousoperation is underway, fuel gas for thesite can be taken from the crackingfurnace overheads.
Propylene RichFeed
Port HarcourtRefinery.
6 km Currently out of use until the PortHarcourt refinery FCC is returned toservice.
Virgin C5+ Port HarcourtRefinery
6 km
Cracked C5+ Port HarcourtRefinery
6 km
6.4. Storage Facili ties
The site contains atmospheric, pressurised and refrigerated storage.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
6.4.1. Atmospheric Storage
Brief details of atmospheric storage are given in the table below:
No.Installed Stored Material Capacity (m
3) Type of Roof
2 Virgin C5+, 4,630 Cone
2 Cracked C5+, 1,671 Floating
1 Cyclohexane 2,000 Cone
1 Ocene-1 2,000 Cone
2 Gas Oil 2,050 Cone
Further details are given below:
Details Comments
Diking The tanks are grouped within one mainbund with approximately a tank diameterbetween the tanks. The two floating rooftanks are separated by a common wall.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Instrumentation It is understood that the tanks originallyhad independent high level alarms.
This should prevent overfilling, if the levelgauging system failed.
This differs from information obtainedfrom previous surveys which stated thatthere were no independent alarms.However, it is likely that level alarmssystems were not well maintained whilstNNPC operated the plant.
All the tanks that have been overhauledhave had the level gauging and alarmsystems renovated. Where possible, thishas involved refurbishing the originalservo type, level gauging system and floatswitches.
This should avoid accidental overfilling.
In some cases radar type level gauginghas been installed.
Radar type level gauging is consideredvery reliable and generally considerednot to require an independent levelalarms.
Fire Protection All the tanks are fitted with semi-fixedfoam systems and water deluge.
Drains Roof drains on the floating roof tanks arenormally left open. The drain lines arechecked every shift.
This will avoid a build-up of rainwater onthe tank roof which could cause the roofto sink. However any leakage from theroof drain line could lead to the dischargeof the tank contents into the diked area.
The dike drains are also left open in therainy period.
This will avoid situations where almostempty tanks will float if there is a seriousbuild-up of rain water in the dike.However, it does raise the possibility thatany spillage of hydrocarbons will not be
contained, perhaps leading to runninghydrocarbon fires along the drainssystem to the effluent treatment plant.Such fires could lead to ignition of nearbyvegetation, this has happened in otherlocations.
The drains from the atmospheric storagearea go either to the storm water drains orthe Effluent Treatment Plant (ETP).During the rainy season the route to adedicated storage basin in the EDP isnormally open.
6.4.2. Pressurised Storage
Brief details of pressurised storage are given in the table below:
No.Installed Stored Material
Capacity(m
3) Comments
3 NGL 3,809 These tanks operate at -5oC and are
thermally insulated.
3 VC5 2,760 These were previously propylene richtanks similar to those described below.They were converted to operate at -5
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Diking The tanks are located in sloped concretedikes. piping penetrations through the
dikes are sealed.The spheres have drainage channelsleading away from the sphere area.
Pumps Pumps are located remotely from thespheres.
Instrumentation It is understood that the spheres originallyhad independent high level alarms.
This should prevent overfilling, if thelevel gauging system failed.
This differs from information obtainedfrom previous surveys which stated thatthere were no independent alarms.However, it is likely that level alarmssystems were not well maintained whilstNNPC operated the plant.
As spheres have been taken out ofservice for inspection, the original servotype level indicators plus float switchedhave been repaired or radar type levelindication installed.
This should avoid accidental overfilling.
Radar type level gauging is consideredvery reliable and generally considerednot to require an independent levelalarm.
Gas detection is installed in some areas.
Pressure Relief Duplicated relief valves are installed onthe spheres.
Some poorly installed supports for
pressure relief systems were noted.
These originally included Castell keyinterlocks to ensure that one relief line isalways open. However some of theseat least are non-functional and havebeen replaced with a plastic car sealsystem.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Motor OperatedValves
ROVs, sample points etc. are located onthe outside of the dike wall. Penetrationsthrough the dike wall are generally wellsealed but there are exceptions.
Poorly sealed penetrations may leak.
Fire Protection All the spheres are equipped with deluge
water sprays, operable from two locations.
This should allow access to a valve
under all wind conditions.
Sphere legs are fireproofed.
Support for sphere PSV systems,this is wedged in position with nofixings.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
6.4.3. Refr igerated Storage
Ethylene is stored in a 12,630m3 double skinned tank constructed by Entrepose of France to API 620.
Brief details are given below:
Details Comments
Construction Double wall tank with a perlite filledannulus, constructed to API 620.
There is a nitrogen purge through theannulus.
The fill and empty lines for the tankcontain bellows which appear to beslightly distorted. A support for one of thepipes appears to be missing.
To minimize the potential for rollover, thetank contents are continually circulatedand sprayed into the top of the tank.
There is reported to be some leakage ofethylene through the inner skin of thetank.
The tank annulus is purged with nitrogen.
Previous surveys have noted a missingrod hanger on one of the main ethylenetank lines. In response to previousrecommendations, EPCL haveundertaken an engineering study whichhas determined that the rod hanger is notnecessary.
It is not clear if the analysis assumed thatthe piping is rigid, as opposed to abellows, which is distorted. It would beprudent to repeat the analysis to check ifthe lack of the rod hanger s still adequatein the present of a bellows rather thanrigid pipe.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Diking The tank is located in a sloped concretewall dike, with drains leading to animpounding basin.
The mastic used to seal the expansiongaps in the dikes has largely perishedand, in its current condition, the dike mayleak.
Within the dike, there is a channel leadingto a small impounding basin with a foamsystem.
The foam system will minimiseevaporation of any ethylene spillage.
The entire diked area is overgrown withvegetation and requires clearance. Thisparticularly applies to the impoundingbasin, which contains a level of water andseveral medium sized trees.
Water could act as a source of heat toallow rapid vaporization of liquidethylene.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Pumps Pumps are located remotely from thestorage tank.
Instrumentation The refrigerated tank has 2 independentlevel gauging systems. One is a float typesystem; the other is based on a differentialpressure system.
This differs from information obtainedfrom previous surveys which stated thatthere were no independent alarms.However, it is likely that level alarmssystems were not well maintained whilstNNPC operated the plant.
This should prevent overfilling, if thelevel gauging system failed. The use ofdifferent measuring techniques will
minimise the potential for common modefailures.
A single Boil Off Gas (BOG) compressorreturns vaporised ethylene gas to theolefin unit for re-liquefaction. When theethylene plant is shut down the vaporisedgas is vented to the flare.
An unusual feature of the tank is the factthat the flare vent control valve failsclosed and in the event of a power failureor other interruption to the instrument airsupply an operator needs to climb thetank and manually open the bypass.
Fire Protection The tank itself is fitted with a water delugesystem around its circumference.
Medium expansion foam and waterdeluge systems are installed to cover asmall impounding basin within the dikedarea.
From a visual inspection, this equipmentappeared to be in poor condition andshould be checked.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
6.4.4. Warehousing
The main products from the site are solids, stored in separate warehouses:
• Polypropylene - 19,000m2 warehouse
• Polyethylene - 42,000m2 warehouse.
Both warehouses are protected with sprinkler systems. Some sections of the sprinkler
section were isolated.
Layout of the warehouses is good with clear access around the bagging areas and the forklift truck charging points well separated from the polymer storage. Pallets of polymer are
generally within marked bays but in some locations access to fire fighting equipment islimited.
6.5. Utilities
The site is designed to be self-sufficient in utilities. Further details are given in the sections
below.
Restricted access tofire fighting equipmentin the polyethylenewarehouse
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
6.5.1. Water
Brief details of the water systems are given in the table below:
Details Comments
Raw Water:
Sources There are 6 boreholes of which 3 arenormally in use producing approximately300m
3/hour.
There were originally 8 boreholes but 2are outside the site boundary and nolonger used.
Storage 2 tanks are installed, each of 55,000m3
capacity.These tanks also provide the fire watersupply.
Treatment Water treatment consists of 3 de-carbonators for carbon dioxide de-gasification and six sand filters to producefiltered cooling water.
There is also a demineralisation unit toremove sediment and ferric ions, plus 2activated carbon filters for potable water.
Cooling Water: A single cooling water system covering allthe process units is installed.
A vent is installed in the cooling waterreturn line. This is located on the returnline itself rather than on the individualpipes to each cell.
Vents are often installed on the returnlines of cooling water systems to avoidthe entry of flammable gases (from heatexchanger leaks) from entering thecooling tower where they might ignite.The efficiency of the arrangementinstalled at the site is not clear. In thecase of significant leaks, it may allow gasto be swept past the vent into the coolingtowers.
A gas detection system is installed. This should detect any hydrocarbongases in the returned cooling water fromleaks in heat exchangers.
The original cooling tower internals havenow been replaced with polypropylenepacking.
Cooling tower fans are reported to haveexplosion proof motors.
This will reduce the likelihood offlammable gas igniting.
The gearboxes and motors have vibrationalarms.
No. of Cells There are 2 cooling towers, each with 5cells.
All cells are now operational and repairsto gearboxes and fans, reporteddefective in previous surveys have now
been repaired.Packing in the cells is in relatively poorcondition. Some has been displaced intothe cooling water return line and blockedtubes in many of the exchangers.
No. Normally in Use 8 cells should be adequate for fulloperation but previously all 10 have beenin use.
No. of Pumps 5 electrically driven pumps, each of8,400m
3/hour are installed.
No. Normally in Use The system is designed for 3 of the 5pumps to normally be in use.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Boiler Feed Water Treatment consists of:
• 3 Activated carbon filters installed for
condensate treatment.
o 2 x 175 m3/hr
o 1 x 280 m3/hr
• 3 mixed bed polishers all 280 m3/hr.
In addition to provision of fresh BoilerFeed Water, there is a significant recycleof condensate.
The Boiler Feed Water quality haspreviously been poor on occasions and
this may have contributed to problemswith the boiler tubes. Improved chemicaldosing and monitoring are now in place.
The following storage capacity is installed:
• Demineralised water 1,500 m3
• Polished water 2 x 1,500 m3
6.5.2. Fuel Gas/Fuel Oil
Fuel gas is supplied by pipeline from the Obaifu Obrikom gas separation facility. This supply
is used for start-up or when the olefin plant is out of operation. Once stable operation of theolefin plant has been achieved, fuel gas is provided by the cracking furnaces.
The gas turbines can operate on either natural gas or diesel fuel.
6.5.3. Steam
Brief details are given below:
Details Comments
No. of Boilers All steam raising takes place on theolefins plant using the following:
• 3 Boilers each generating 120tonnes/hour at 48 kg/cm
2.
• 6 Cracking furnaces generating steamat 48 kg/cm
2 and 109 kg/cm
2.
The boilers have been refurbished aspart of TAM 1 and are now equipped witha Yokogawa DCS systems.
OperatingConfiguration
Steam is provided by the crackingfurnaces and the boilers.
At low cracking rates all three boilers wererequired to meet steam demand. Asdemand increases, more heat from thecracking furnaces is recoverable as steamand 2 boilers will be adequate to meetdemand. However normal practice is tokeep all 3 boilers in operation at reducedflow rates to allow for the possibility of aboiler trip.
During periods when boilers are takenout of service for statutory inspection,there will be no spare steam capacity.
Distribution Steam is provided at 4 pressure levels:
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
On Site Generation There are four GE Frame 6 powergenerators installed, each with a capacity
of 33 MW.
The units can be fired on gas and dieselfuel. It is understood, that they have also
been fired on propylene in the past.There was a total power failure at the sitein April. It is understood that the naturalgas supply was interrupted and when oneof the operating gas turbines changedover to diesel fuel, excessive flowoccurred and the turbine tripped. Thesecond operating gas turbine then trippeddue to high temperature spread in theexhaust system.
These units are reported to be in generallygood condition.
The gas turbines are located within alarge single building. The number offlanges on the fuel gas lines within the
buildings is limited.
This will minimise the potential for a gasleak from a flange to generate anexplosion within the building.
OperatingConfiguration
Maximum demand is 35 MW, with currentsite demand varying between 28 – 32MW.
This is met by running 2 generators atapproximately 50% capacity.
This will allow one machine to take overfull load in the event that the othermachine trips.
Distribution Power is generated at 11 KV in the maingenerators, then stepped up to 33 KV.
There are also 3.3 KV and 415 Vdistribution systems.
Distribution is via a secondary selectivesystem.
There is a load shedding system coveringthe site.
High voltage switchgear is SF6 type, LVswitchgear is vacuum type.
Some simple, low voltage, extensions tothe system have been made to assist withmaintenance and routine work activities.
A single transformer failure should notresult in a power failure within the site.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
6.5.7. Nitrogen
Brief details are given below.
Details Comments
Type of Supply The original system comprised an AirProducts cryogenic nitrogen unit.
The air dryers for the unit havepreviously been ineffectual, allowingmoisture to pass with subsequentfreezing in the cryogenic unit. Since thetakeover of the site by Indorama, themolecular sieve has been replaced andthe unit is reported to be workingsatisfactorily.
A new nitrogen unit was ordered from theSuzhou Oxygen Plant Company (SOPC),China. Some equipment items for theunit have been purchased directly byEPCL rather than sourced throughSOPC. Both units are now operational.
Whilst this may not be a company widelyknown in the West, they are reported tohave built over 600 units worldwide.
Unit N2 LiquidNm
3/hr
N2 GasNm
3/hr
AirProducts
390 3,400
SOPC 450 1,800
Storage There are 3 liquid nitrogen storage tankseach with a capacity of 175 m
3.
Facilities are installed to provide 6,400m
3/hr. of vaporisation capacity.
There are also facilities to load/unloadliquid nitrogen and fill nitrogen cylinders.
6.5.8. Flare
The plant has three main flare stacks and a burn pit (to burn heavy waste from the olefinunit), details of the flare stacks are given below:
• FS1 (76.2m high) – covering the olefins plant and utilities. In line with normal practice,
there are two separate flare headers. One for cold gases, the
second for wet gases. By separating the two gas streams, ice plugs(which would occur when wet and cold streams meet) are avoided.
• FS2 (76.2m high) – covering the polypropylene and polyethylene plants.
• FS3 (25 m high) – covering the ethylene storage tank.
Flare drums are reported to be instrumented with automatic pump out on high level together
with steam coils for evaporation of the drum contents.
The flares and burn pit are located to the northeast of the site with limited potential for
damage to the process or utility systems.
6.5.9. Effluent Treatment
The storm water system is largely open and underground sections have gas seals to preventthe movement of flammable gases through the drain system. The seals are vented toatmosphere with flame arrestors installed. Whilst the main drainage channels are largely clear
of vegetation, in several locations small drains feed into the open drains and these are fittedwith metal grids, presumably to prevent rodents, etc. entering the system. Many of these are
partially (in some cases almost totally blocked) with debris and could restrict discharge.
The system has segregation between the storm water and oily-water drainage systems withall oily drainage directed through to a proper drainage system in the water treatment area.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
7. Administration
7.1. Organisation
Since the takeover of EPCL by Indorama, many of the original NNPC staff have left. The
senior management now consists largely of Indian ex-pats. The staff at the time of thetakeover by Indorama was around 1,000, currently, there are approx. 600 local staff and 170
expats. The former NNPC staff who have left the site work in other NNPC business unitsand there were no significant redundancies that might have triggered resentment against the
company management.
EPCL intends to recruit local staff, as far as possible and training programmes have been
established.
The Managing Director of EPCL has three main functions reporting to him:
• Finance and Administration
• Commercial
• Site
Site operations are under the control of the Technical Director. The key departmentsreporting to him are:
• Olefins
• Polymers
• Offsites/Utilities
• Maintenance
• Technical Service
• Health, Safety and Environment (HSE)
The HSE function, in line with good practice, reports directly to the site manager.
The previous EPCL management, under NNPC, had limited financial authority and even
relatively minor requests for expenditure had to be approved at a corporate or even
Government level. The change of ownership has removed the previous financial restrictions,
allowing much better access for funds for spare parts and other uses. This is demonstrated
by the extent of work performed in the various TAMs since Indorama bought the site andincrease in expenditure on new utilities, replacement olefin plant cold box, etc.
Indian personnel work a three month period at the site followed by one month leave.
The site has achieved certification under ISO 9001; ISO 14001 and OSHAS 18001.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
7.2. Operations7.2.1. Process Operations
Brief details of the operations group are given below:
Details Comments
Performance The facilities now have an availabilityapproaching 100%. But throughput maybe limited by shortage of feedstock.
There was a total shutdown in Februarywhen a power failure at the Agip plantsupplying EPCL suffered a power failure.
Coincidently, there was a power failure atEPCL at the same time, resulting in ashutdown of the polymer units.
Operation is becoming more stable with 1or 2 "First Intervention Reports" (processupsets).
On stream time in the polyethylene planthas increased as a consequence of a newmechanical seal on the reactor agitator.
There have been several forcedshutdowns of the polypropylene plant butmost downtime on both units is planned.
Organisation andStaffing Levels
The operational activities are splitbetween three main groups:
• Olefins (sub dived into hot and coldsections).
• Polymers (subdivided intoPolypropylene and Polyethylene &
Butene)• Power Utility and Offsites.
Each unit has a plant manager andproduction manager (working days), plusshift teams as follows:
Whilst most of the supervisors andsenior personnel are Indian ex-pats. Atoperator level, Indian personnel areincreasingly being replaced with localstaff.
O l e f i n P l a n t
P o l y p r o p y l e n e
P o l y p r o p y l e n e /
B u t e n e 1
P o w e r
U t i l i t i e s
O f f s i t e s
Shift
Engineer
21 1 2 1 1
PanelOperator s
4 2 3 1 1 1
FieldOperator s
8 5 8 1 4 22
1 Shift engineer and assistant, theolefins plant is split into hot and coldsections.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Outside day working hours, there is a shiftmanager in charge of the site.
This will ensure a good level ofcommunication and control in the event
of a major incident. In the absence of anominated individual, confusion canarise over who takes initial charge of anemergency and who has authority toshut down the plant.
The site has four shift teams working athree shift system.
8 hour as opposed to 12 hour shifts willreduce the level of fatigue faced by shiftpersonnel, particularly during hotweather.
Indian operators work 12 hour shifts. As the local and Indian personnel workdifferent shift patterns, shift hand overswill be staggered and not all personnelwill handover at the same time.Provided hand over procedures areproperly handled this should provide a
better level of continuity than allpersonnel changing shift at the sametime.
Local operators work a 7/7/10 hour shiftpattern.
This unusual arrangement is used tominimise the risk to local personnelwhen travelling to the site outside normalworking hours.
Most operators are understood to be inthe age range of 20- 55.
There will not therefore be a suddenlarge reduction in the overall level ofoperating experience in the near futurebut some senior personnel will beretiring.
Warehouse activities (bagging, fork lifttruck driving, etc.) will be largely
performed by contractors under thesupervision of EPCL staff.
This is a common procedure in polymerand other plants with large solids
warehouses.
Budget Budgetary pressures were apparent whenNNPC were the operators of the plant.There now appears to be significantlygreater resources available.
Training EPCL now have a training departmentwhich coordinates training across all partsof the organization.
Trainees will be college graduates with ascience or chemical engineering diploma.
Recruitment from the local area helps toreinforce good relationships with thelocal community.
The recruitment process includes a
written test.Trainees will undergo a mixture ofclassroom and on the job training lastingapprox. 18 months. Progress ismeasured by a mixture of continuousassessment and interviews but not writtentests.
This will ensure that all recruits have an
adequate command of the Englishlanguage.
Operators will initially be trained for asingle operational role on one unit but asthey gain experience will train in a numberof positions.
The recruits from 2006 are now fullytrained field operators and are taking overpanel operating positions.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
A process simulator is available in thetraining centre but has not been fully
configured.
This is a basic simulator and consideredto be of very little value for training. An
improved version of the simulator maybe provided in the future.
Experience Most, but not all, operators are graduates.
For more senior positions, including paneloperators and above, EPCL areappointing experienced processoperators, many are Indian ex-pats.
The Ex-pats are being replaced as localpersonnel gain competence.
Local operators have either been trainedby EPCL or were recruited from otherprocess facilities.
Most operations personnel are under 40and staff turnover is low. There is now apool of trained field operators with thecapability to become panel operators.
Few of the personnel from NNPC arenow on site.
Previously, there were a number ofRomanian nationals who had senioroperating positions and had worked at thesite for a number of years. Currently only1 remains, he is now the olefins plantmanager.
Documentation:
Standard OperatingProcedures
Operating procedures have been totallyrevised since Indorama took over the site. A further upgrade has taken place toensure all documentation complies withISO 9001 requirements.
Checklists Checklists have been developed for
activities such as start-up of fired heaters.
Log sheets are completed by fieldoperators twice per shift.
The use of checklists for start-up can be
useful and is widely practiced. Forexample to ensure that fired heaters andboilers are purged before firing and forensuring that lube oil systems arefunctioning before compressors arestarted.
Updating All Process and Instrumentation Diagrams(P&IDs) are reported to be up to date.
As stated above, the operatingprocedures were revised when Indoramatook over the site and have been furtherrevised to comply with ISO 9001requirements.
EmergencyResponseProcedures
The emergency procedures have beenrevised but are not in a "short format".
The procedures examined for the olefinplant were comprehensive for thedifferent scenarios but are up to 12pages long. All actions by all operatorsare recorded in the same document.Information might be more accessible ifthe information was re-organised so thatthe actions of each individual operatorwere more clearly identified.
Some emergency shutdown training takesplace but this appears to be classroombased and some scenarios are simulatedby temporary changes to the DCS.
Under emergency conditions operatorsmay react in unexpected ways andregular field simulations are oftenconsidered a helpful way of reducingoperator error. Without this operatorsmay be confused as to the location of
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
The recommendation from 2006regarding Emergency Response
procedures has not yet been addressed.
Following discussions with the plantmanager more complete implementation
is expected in the future.Process Upsets A reporting procedure for process-upsets
is being developed. The first stage is thecompletion of a "First Information Report".
After investigation a "Facts and AnalysisReport" is produced with lessons learned.
A previous survey recorded that all alarmsare recorded on the DCS system and noproblems with alarm flooding have beenreported.
A number of companies haveexperienced problems, with "alarmflood", during major incident. Thisresults in literally hundreds of alarmsbeing activated within a very short spaceof time. When this happens, the sheervolume of alarms makes it difficult foroperators to follow the exact sequenceof events. Alarm management systems
assist by filtering out the less importantalarms.
Communications/Shift Handover
Shift logs are maintained by the shiftengineer and panel operators. Thecondition of the plant is discussed by theincoming and outgoing supervisors bothincoming and outgoing personnel sign thelog book.
It is often considered advantageous forboth the outgoing and incomingsupervisors to sign the log book toensure that there has been a thoroughexchange of knowledge.
As the local and Indian personnel workdifferent shift patterns, shift hand overswill be staggered and not all personnelwill handover at the same time.Provided hand over procedures areproperly handled this should provide abetter level of continuity than all
personnel changing shift at the sametime.
In each plant, there is a log book for eacharea. Field operators hand over in theirrespective shelters.
A better alternative, in most cases,would be for the field operators to walkround their area as part of the handoverprocess.
7.2.2. Control of Maintenance
Brief details are given below:
Overview The permit to work system has beenrevised since the 2011 survey andseparate vessel entry and vehicle entrypermits are in use.
Copies of the permits are given in Appendix G.
A plotplan is located in the olefins controlroom showing the locations activepermits.
The permit system will be implementedfor the new projects from the very start ofconstruction.
This is considered a positive featureallowing operations personnel to quicklyidentify the location of active workpermits.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
A common folder is used for filing allpermits with no differentiation betweencontinuing and completed work.
This can lead to confusion over thestatus of work and, possibly, attempts tooperate equipment not yet fully repaired.
Permits are individually numbered. Permits which are uniquely numberedare easier to cross check and cross
reference several permits may berequired for one task.
Auditing of the permits now takes place. This is a useful process to ensure thatthe permit system is operating asplanned.
IsolationProcedures:
A LOTO system is now in place coveringinstrument and mechanical maintenance.
Mechanical Valves closed for isolation duringmaintenance are now reported to betagged and padlocked. Where pipeworkis opened blinds are installed.
The use of tags and padlocks to ensurethat valves is considered good practice.
Casing blinds (to fit inside pumps wherethe casing has been removed) are
available for some situations.
Installation of blinds in the suction anddischarge lines of some pumps can be
difficult. However casing blinds areunusual and their effectiveness isunknown.
Electrical Electrical isolation is achieved by "rackingout" electrical equipment.
This will provide effective isolation butthe use of a padlock on the isolatorhandle would represent an additionalprecaution against errors. The sitemanagement are currently reviewing theadequacy of the existing system.
Instrument Since the 2011 survey, the trip by passprocedure has been revised and newbypass registers have been developedand will soon be in use in all the processunits.
Whilst this is an improvement on theprevious system, the new proceduredoes not comply fully withrecommendation 11-04.
There may also be confusion with regardto bypasses on standby equipment(where the bypass needs to be active toavoid the, non-operating, standbyequipment from causing a shutdown).
7.3. Maintenance
7.3.1. Turn Around Maintenance (TAM)
A major concern at this location during the years of NNPC ownership was the lack of
turnaround maintenance. Since then significant funds have been spent renovating thefacilities in a series of TAMs and conditions are much improved.
Brief details of the maintenance function, known as Central Engineering Services, are shown
below:
Details Comments
Performance Plant reliability is now 99 – 100%. Figuresfor 2012 are shown below.
The represents a huge improvement overthe last few years when the plant wastaken over from NNPC.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Budget
No budgetary constraints were apparent.Training EPCL now have a training department
which coordinates training across all partsof the organization.
There is a training facility at the site withan apprenticeship programme. Initially,EPCL recruited experienced personneland many of these are still on site.
Additional specialist training is providedwhere appropriate, for example for thenew DCS systems.
Experience EPCL has employed experiencedmaintenance personnel. Additionaltraining is provided where required.
There are also a number of Indian ex-patpersonnel, generally at supervisor leveland above.
Average age is approximately 40, with thelocal workforce generally being at theyounger end of the age range.
Experience levels are reported to beadequate and staff turnover levels are lowenough to prevent a drain on theresources available.
Philosophy When EPCL was owned and operated byNNPC, there was a severe shortage offunds resulting in a backlog ofmaintenance. Since then, EPCL haveinvested significantly in maintenanceactivities.
Since the plant was taken over byIndorama, there have been 3maintenance turnarounds:
TAM 1Major turnaround in 2006(USD 58 million)
TAM2A
26 day turnaround in May2008
TAM2B
10 day turnaround inNovember 2008
Total cost of TAM 2 was USD72 million
TAM 3 22 day turnaround in March2010 (USD 3.2 million)
An example is the decision to purchase anew cold box for the Olefin plant, eventhough repairs to the existing boxappeared to be satisfactory.
The main activities in TAM 3 were:
• Migration of all DCS systems to the
latest version• Remove damaged cold box and
install replacement
• Change internals in column C2
• Replace absorbent in the H2 PressureSwing Adsorption (PSA) system.
TAM 4 will take place in February 2013and last 22 days. The main activities willbe:
• Overhaul of the cracked gascompressor
• Overhaul of Boil Off Gas compressor
• Cleaning of 45 tube bundles
• Replacement of 4 tube bundles
• Opening of 7 columns• Statutory inspection of 3 boilers
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Maintenance is largely preventive andpredictive, together with "LLF" (Look
Listen Feel) activities, coupled with dailychecking of key parameters on keyequipment.
LLF activities would often be consideredas an operators function and it is a little
surprising to find a significant proportion ofmaintenance activity dedicated to this typeof activity.
Planning The ORACLE Computerised Maintenance
Management System (CMMS) has beenin use at the site for 18 months.Previously, MAXIMO was used.
EPCL are preparing SMP (StandardMaintenance Procedures) for manyroutine activities. More than 700 SMPshave been developed and the process islargely complete.
For standard activities, these includeJSAs.
Documentation Only maintenance records since ORACLEwas installed are in the system.
Earlier records are either available inMAXIMO or as hard copies. The lack ofinformation available in ORACLE could
hinder fault finding and reliability studies.However, it would be a major activity tomigrate the plant maintenance historyentirely onto ORACLE.
Mechanical Vibration monitoring systems (BentleyNevada 3300 series) are installed onlarge rotating equipment items such as:
• Main compressors in the ethyleneplant (Bentley Nevada 3500 series)
• Boil Off Gas Compressor
• Gas turbine generators.
• Instrument air compressors (4 units)
• Reactor feed pumps (3 units)
These systems are being replaced by3500 series equipment.
Vibration trips are installed on the gearboxand motors of the cooling tower fans.
New data capture type vibrationmonitoring and analyser (SKF CMXSeries) equipment has been purchasedand technicians trained in its use.Vibration monitoring is performed atintervals as shown below:
The increased use of vibration monitoringsystems has resulted in the identificationof a number of "bad actors"
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
C Equipment:
• On standby,
• More than 22 kW,and
• Operating between1,400 and 2,800rpm
Monthly
D Balance of equipment Whenrequired
One extruder in each of the polymerplants has been replaced. The originalsurviving extruder on each plant will bereplaced in the future.
An in house lube oil testing programme
has being set up with regular checks onmoisture, viscosity and particles. Ifproblems are suspected, lube oil sampleswill be sent for particle size analysis.Ferrography is performed during
turnarounds if considered necessary.
There is some equipment balancingcapability at the site but larger itemswould probably have to be returned to the
manufacturer for balancing.
Previous problems with the olefin plantcompressors were as a result of solidsdeposition on the rotors. There were also
initial problems of high bearingtemperatures have now been resolved.
All the rotors have been rebalanced and
some replacement bearings installed.
An additional injection system wasinstalled to suppress polymer formation bythe injection of "Actrene" and this appears
to be successful.
It is intended to replace the tubes in all 6cracking furnaces before the end of 2012.
Tubes in 4 furnaces had been replaced atthe time of the survey.
Inspection of the gas turbines is in line
with the vendors recommendations:• Combustion 8.000 EOH
• Hot Gas Path 24,000 EOH
• Major Inspection 48,000 EOH
Note EOH – Equivalent Operating Hours.
Details of recent gas turbine maintenance
is given in the table below:
Previously, the machines have beenoperating at part load which is reported toincrease the EOH (equivalent operatinghours) of each machine. However this is,at least in part, compensated for by arelatively low number of starts.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Last (HGP)Inspection
Date
RunningHours at
Time ofHGP(Hrs)
MajorInspection
Done
RunningHours at
Time of M.Inspection
(Hrs)
23 Oct 12Running
Hrs Inspection Schedule
GT#1 12 Feb 05 50815.4 11 Jun 11 98,776 CI planned in 2014
GT#2 1 Mar 04 48991.0 77,599 MI planned for Dec 12 or Jan 13
GT#3 5 Apr 04 29279.2 48,341 MI planned late 2013 or early2014
GT#4 5 May 05 49278.2 5 Aug 08 78380 101,876 HFPI planned for 2013
1. GT#4 Major inspection was carried out after 28000 hrs running of HGP.2. Based on the observation and experience in MI/HGP & CI GT inspection schedule is prorated.3. Due to low load and clean fuel (GAS) operation HOT GAS PARTS were in excellent condition.
There has been some slippage in datesfrom the information provided at the time
of the 2011 survey.
Control systems for the gas turbines arebeing updated. 1 unit has already beenupgraded from the Mark 4 to Mark 6
system.
All rotors can be balanced on site. Thebalancing equipment is to be modified sothat these items can be balanced. Some
machines can be balanced on line.
Electrical The oil in all transformers underwent aDissolved Gas Analysis (DGA) anddielectric test at TAM1 and no problemswere identified.
DGA may be valuable for determining theearly stages of transformer oil breakdownon large critical transformers.
Dielectric testing takes place every 6months. EPCL now have the capability toperform DGA testing on site. Howeverrecent results have indicatedunrealistically high levels of ethane in allthe transformers with no other indicationof problems. Samples are now being sentto an external laboratory for analysis.
EPCL’s on site equipment cannotmeasure hydrogen levels which theyconsider to be an important parameter.
A Thermographic camera has recentlybeen bought for the site and is used tocheck for hot spots in electricalequipment.
Thermography is increasingly used as aneconomic non-invasive method ofdetecting faults. This may be a usefultechnique for use prior to the TAM toidentify equipment which might be in needof repair.
There are understood to be facilities forrewinding large electric motors in theregion.
Lack of suitable facilities could lead tolong periods of downtime whilst a motorwas shipped abroad to the manufacturer.
Some equipment is obsolete andreplacement is taking place, includingsome DC machines and invertors.Annualearthing checks are undertaken.
Instrumentation Full loop tests are undertaken at eachshutdown. The trip systems are oftenused to shut down units when
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
The potential for trip testing in operationappears limited. In some cases, there aretwin sections of the plant operating inparallel allowing full loop testing withouttaking the plant out of action.
The example quoted was the extrudersection of the polymer plants which areamongst the least hazardous parts of theprocess.
Full function tests (excluding the finalelement) take place during operation.However tests will take place if a problemis suspected.
Some systems are partially duplicatedwhich would facilitate on line testing.
So far no SIL (Safety Integrity Level)assessment has been undertaken toidentify the overall reliability of the loopsand the level of testing required.
The trip valves on the steam turbines aretested prior to start-up and at shutdowns.
In situations where there is poor steamquality, scale can build up across thevalve seat preventing it from closing in anemergency. However, steam quality atEPCL is reported to be good.
Since Indorama took over EPCL, therehas been considerable upgrading of theinstrumentation, including new DCSsystems in the process units and new F &G panels in some locations. Further F&Gpanels will be replaced.
Spares "Insurance" spares include rotors anddiaphragms for rotors for the olefin plantcompressors and turbines.
Rotors for turbines and compressors haveeither been replaced or refurbished.
Rotors are stored vertically and some arewithin nitrogen containers. 6 monthlychecks are made to ensure that there isstill nitrogen pressure in the containers.
Vertical storage will prevent distortion ofthe shaft in storage, and nitrogen willprotect against corrosion.
"Last run" notification is a warning bysuppliers that this is the last production
run for a component after which theequipment will be considered obsolete.This allows customers to either purchaselarge quantities of spares for future use orlook for replacement equipment.
EPCL state that they have never suffereddowntime due to lack of spare parts.
7.4. Engineering
Brief details of the engineering function are given below:
7.4.1. Management
Brief details are given below:
Details Comments
Organisation andStaffing Levels
The engineering team consists of 11people split between Projects andProcess Engineering. Staffing levels arereported to be adequate.
There is understood to be a shortage ofexperienced personnel and EPCL aretrying to recruit ex-pats.
The library function, previously part of thisgroup is now administered by theInspection function.
EPCL have scanned much of thedocumentation and drawings into pdf
format, some are available on the siteintranet.
Data sheets for the olefins unit have beencompletely scanned.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
The library currently contains 3 copies ofthe site documentation as hard copiesand microfilm. Further copies areavailable in other departments.
In theory it should be possible to recreatethe library in the event of a fire in thedocument rooms but there could bedifficulties in ensuring replacementdocuments are up to date.
Key documents and drawings, such asProcess and Instrumentation Diagrams(P&IDs) are "controlled documents".
The availability of documents on theintranet could lead to numerous copiesbeing printed by members of theworkforce, making it difficult to ensure thatdocumentation is up to date. It wouldtherefore be prudent to ensure that"uncontrolled" copies (those printedwithout authorization) are marked or watermarked in some way. Controlleddocuments need to be clearly marked anda distribution list kept, ideally withsuperseded documents being returned todocument control for recording and
destruction. All the site P&ID’s are now reported to beupdated and available in an AUTOCADformat.
All documentation is reported to be storedin files in 2 separate servers located indifferent buildings.
This greatly reduces the possibility of dataloss.
Training EPCL now have a training departmentwhich coordinates training across all partsof the organization.
A number of graduates were trained aspart of Nigerian government trainingprogrammes. These are now employedby EPCL in engineering roles. Furthertraining is provided where appropriate.
Experience Most personnel currently working on sitein a technical function are wellexperienced and there are no immediatetraining needs.
EngineeringStandards
The facilities appear to have been built toindustry standards. Standards usedappear to have been those of the licensorplus relevant industry standards such as ASME, TEMA, API codes etc. In somecases, standards from the country oforigin may have been substituted, forexample DIN in Germany, BS for the UK.
Mixing of codes on pressure systems canlead to incompatibility.
Whilst accepted industry standardsappear to have been used at EPCL, thereare some obvious differences betweenloss prevention philosophies between thedifferent process units particularly withregard to fireproofing in the processfacilities.
EPCL have developed technicalagreements with the licensors of the majorprocess units:
• Kellogg (olefins)
• Nova (polyethylene)
• Basell – the successor to Technimont(polypropylene)
• IFP(now Axens) - the butane-1 plant
Previously EPCL appointed SK Energy ofKorea (who operates similar olefinsplants) as technical advisors but thisagreement has now ceased.
In addition, EPCL have appointedIngenero (India) to provide real time
monitoring and feedback of processoperations.
Ingenero have been performing thisfunction since 2008.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
7.4.2. Management of Change
Brief details are given below:
Details Comments
Management ofChange:
The management of change system isdescribed below:
The level of safety review for mostmodifications has increased since the2011 review and Hazard and Operability(HAZOP) Studies are required for mostchanges. There is still no requirement fororganization changes to be treated underthe management of change procedure.
Overview A management of change procedure hasbeen developed by EPCL as part of thenew safety manual and is being used inconjunction with the 320 changes thathave been proposed since the takeoverby EPCL.
Whilst some of the drawbacks identified inthe 2009 survey have been addressed,there still appears to be an issue withensuring that drawings and otherdocumentation are up to date before themodification is considered complete.
One of the fires that occurred in 2011appears to have been due, in part, to afailure to update an SOP (StandardOperating Procedure), following a physicalchange.
The procedure now includes a checklist todetermine if a HAZOP is needed.
A Pre Start-up Safety Review (PSSR) isrequired prior to start-up following anychange.
Whilst the checklist is an improvement onthe previous system, it could still beimproved by implementation of a morecomprehensive checklist.
Hardware changes All physical changes to the site go throughthe MOC procedure.
Process changes Process changes are covered in the MOCprocedure.
Organizationalchanges
There is no requirement for a review ofstaffing levels or organizational changes.
It is becoming increasingly common toreview changes to staffing levels as partof the management of changeprocedures. This should identifysituations where, for example, underreduced staffing levels a person might berequired to be in 2 locations at the sametime during start-up.
7.4.3. Hazard Studies
Brief details are given below:
Details Comments
Hazard Analysis HAZOP studies of all the units wereperformed at the design stage but havenot been reviewed since. Whilst the morecomplex modifications undergo a HAZOPreview, there has not been acomprehensive programme to re-HAZOPall the facilities.
It is prudent to repeat the HAZOP studiesperiodically and in some countries this is alegal requirement. As a pre-requisite anaccurate set of P&IDs is required.
An update of the studies would also be auseful training exercise for operators andmight explain the basis of aspects of thedesign which appear strange, such as theaction on air failure of the vent valve onthe ethylene storage tank (see section6.5.3).
EPCL are considering a re-HAZOP of thesite but no final decision has been made.
A comprehensive review of the site shouldbe undertaken in advance of construction
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
7.5. Inspection
Brief details of the inspection function are shown below:
Details Comments
Organisation andStaffing Levels
The inspection function now reportsdirectly to the site management. Theorganizational structure of the departmentis shown below.
Currently, there is a vacancy for the Headof inspection. The previous title holder hasreturned to India.
Unlike most locations, there is only limitedinvolvement of outside contractors duringTAMs.
Equipment:
Radiography Radiographic work is contracted out butEPCL staff interpret the radiographic
plates.
It is common practice for radiographicactivity to be performed by a third party
company. EPCL staff are reported towork closely with the 3rd party inspectors.
There have been problems in somelocations in Nigeria with radiographicplates being "ringed" (the same plate usedfor more than one weld). To avoid thisEPCL personnel supervise contractorsand make sure each film has a uniquereference number on the film.
EPCL have their own darkroom and filmdeveloping capability.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
EPCL have developed software forrecording inspection information and
trending.
This will become increasingly useful asmore inspection data is produced.
Pipelines None of the pipelines connected to thesite are the property of EPCL but a Longrang Ultrasonic Thickness programmewas recently completed and no problemswere identified.
Whilst these pipelines are not theresponsibility of EPCL, it is prudent forEPCL to check their condition to ensurepipeline damage to import or exportpipelines will not affect onsite activities.
Boilers and FiredHeaters
All statutory inspections required by theNigerian Authorities are undertaken.
An order has been placed for a remaininglife study of one boiler.
Piping Inspection philosophy is largely based onIndian practice, which generally requiresan internal inspection every 2 years.
Previous plans anticipated future TAMstaking place at intervals of up to 4 years,which is longer than the 2 year figure usedso far. However a 4 yearly inspectioninterval is not out of line with practice insome areas and is a significantimprovement on practice at the site in thepast.
The current inspection procedure is totake 4 separate readings at eachinspection point and record the worstcase.
Unless comprehensive records aremaintained, the same location may not bemeasured on successive inspections andthe trending/remaining life calculationsmay be in error.
The site has investigated a Risk BasedInspection (RBI) approach to inspectionbut details have not yet been worked out.
Whilst companies are increasingly movingto Risk Based Inspections (RBI), whenIndorama originally took over the site, theydid not consider that there was sufficientdata available to implement RBI at thesite.
The fact that RBI is now being considereddemonstrates the increased confidencethat EPCL now has in the mechanicalintegrity of piping and pressure vessels bycomparison with 3 years ago. Howeversignificant work remains before the RBIcan be applied (for example likelycorrosion locations such as stagnantareas and small bore connections need tobe identified).
A programme of inspection of areaswhere insulation is damaged is underway.
Corrosion Under Insulation (CUI) work is
progressing with priority being given topiping sections subject to thermal cycling.
It is claimed that there is no CUI in theoffsites area but the extent of checkingappears limited.
There are a significant number oflocations where insulation is damagedand it would be useful to speed up theinspection process where possible. Thismay not be possible, particularly on lines
which are in constant use. This willidentify areas where under insulationcorrosion could exist and allow remedialaction to be undertaken before theproblem becomes serious.
Thermography has been used to findareas of damaged insulation, which mayindicate the presence of CUI.
Pulsed eddy current technology is beingused.
Whilst this has common application forCUI, there are some areas where it is
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
After inspection, the surface metal is givena protective coating before insulation is
reinstalled.
Progress is slow as the piping must beavailable for inspection. The actual
inspection is performed by cutting holes inthe insulation and taking thicknessreadings. Most forms of non-intrusiveinspection are considered impractical oruneconomic by EPCL. However recent developments in Real Time Radiography
3
might be helpful at the site.
Pressure Vessels Pressure vessels are code stamped andthere are no ASME VIII div 2 vessels onsite.
A significant number of process vesselsand tube bundles were inspected duringTAM1. Those considered less likely tosuffer corrosion were inspected duringTAM2.
The cold section of the olefin plant isconsidered as an area where corrosion isunlikely and has not so far beenexamined. Whist corrosion may be limiteddue to the operating conditions and the
use of stainless steel, this is also the partof the plant which represents the greatestVCE hazard.
Spheres 7 of the 12 spheres at the site have nowbeen internally inspected using ultrasonicthickness measurement, magnaflux andhydrotesting. In addition MagneticParticle Inspection (MPI) has beenconducted on the sphere legs and thespheres have been checked forsubsidence. The legs of one sphere havebeen checked using Pulsed Eddy Current(PEC) technology.
An additional sphere will be internallyinspected during TAM4.
There have been cases, in otherlocations, where the sphere integrity hasbeen adequate but corrosion of spherelegs has occurred, resulting in collapse ofthe sphere. Inspection of the legs istherefore prudent.
An external inspection company hasundertaken acoustic emission testing ofthe sphere legs. In addition, EPCL’s civilengineering department have donefoundation checks on the sphere legs.Neither of these inspections identifiedproblems.
Once each sphere has had an initialinspection a re-inspection is planned at 5to 10 year interval in line with API 576.
This aspiration looks unlikely to beachieved. 5 of the spheres have not beeninternally inspected in the 6 years sinceIndorama took over the site.
Spheres, converted to VC5 use, arehydrotested during the conversion work.
Tanks Wall thickness measurements of tankshave been undertaken.
One of the floating roof and 2 of the fixedroof tanks have been opened for internalinspection since Indorama took over thesite.
EPCL have checked the potential forsome form of inspection of the ethylenetank Whilst a South African companyoffered a solution this involved drillingthrough the tank walls.
It is common practice not to internallyinspect refrigerated tanks unless there areindications of problems.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Positive MaterialsIdentification
Incoming material is tested & certified atthe supplier’s premises by third partyinspection companies such as: Lloyds;Bureau Veritas; etc. before dispatch. Thematerial test certificates are reviewed byinspection department before givingclearance for dispatch.
A Niton alloy analyser is available at thesite but is only used on a random basis.However, there was 100% checking formaterials involved in the VC5 project.
This procedure may have the potential toallow rogue sections of material to enterthe site. Whilst it offers a reasonable levelof protection, it would be preferable to testand colour code each individual alloy
component entering the site. EPCL also intends to perform somerandom checks on alloy material installedon the plant.
Welders Welding is performed by a mixture of inhouse and contract welders. Generallywelders are required to produce testpieces on site but previously issuedcertificates are accepted if they are lessthan 6 months old.
Welds are checked in line with coderequirements and poorly performingwelders are either successfully recertifiedor dismissed.
This differs slightly from common practicewhich generally requires the completion oftest pieces from all welders who have notpreviously worked at the site on a regularbasis.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Corrosion Protection Cathodic protection is installed on theNGL feed line from AGIP. Soil conditions
on the propylene line from the PortHarcourt refinery do not require cathodicprotection, except in one small sectionwhere a sacrificial anode is installed.
The line to the refinery is understood to bethe property of EPCL, whilst the NGL feed
line is the property of AGIP.
Specific Problem Areas
There were serious corrosion concernswhen EPCL took over the site fromNNPC. Most of these have beenaddressed during TAM 1 and TAM 2 andmechanical integrity of the site is greatlyimproved.
The main issues at the time of the 2011survey were:
• Corrosion Under Insulation (CUI) 250 m of steam condensate line requiringreplacement has been identified in thepolyethylene plant. No significant CUI hasbeen identified in process piping.
• Erosion in cracking furnace tubes Tubes in 4 of the furnaces have beenreplaced. Tubes in the remaining 2 will bereplaced before the end of the year.
7.6. Safety, Health and Environment
Brief details are given below:
Details Comments
Performance The site has recently achieved a 5 starsafety rating in the British Safety Councilscheme with a score of 92.27%.
EPCL has also been award a Sword ofHonour, with a score of 71 out of apossible 72.
Accident trends over the last few yearsare shown below:
There is a much greater awareness ofsafety issues at the site than during the2011. This is reflected in safety meetingsand notices around the site.
There is also a clear understandingbetween occupation safety and processsafety issues.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
There is now a significant emphasis onprocess safety at the site with regularreviews of incidents world-wide and thepotential lessons that could be learnt byEPCL.
Scaffolding at the site is to a highstandard.
Scaffolding in developing countries is
often very poor and EPCLs highstandards are the exception.
Newly installed processsafety notice in the olefinplant
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Organisation andStaffing Levels The HSE function reports to the TechnicalDirector.
The department is headed by the siteHead of HSE, with the following groupsreporting to him.
This will allow a clear reporting route, withno conflicts of interest.
The HSE department is split into 4subgroups as shown below:
• Environment (2)
• Safety (5)
• Occupational Health (21)
• Fire (see section 6.7).
In addition to the departmental managerand safety officer, there is a safetyrepresentative on each shift team. Whilstthe reporting route is to the safetydepartment, there have been conflicts of
interests in other locations. This hasresulted in the shift safety officersometimes being more concerned withproduction activities than safety.
In addition, safety ambassadors areappointed in each unit.
Experience The Head of HSE has extensiveexperience of process operations andprocess safety.
All personnel at the site have a diploma insafety.
Acc ident Report ing A comprehensive incident reportingsystem is in place.
Accident statistics are shown above.
Incidents are investigated to identify rootcause. This is undertaken with a formalprocedure rather than one of the softwarepackages currently on the market.
Lessons learned from incidents are widelycirculated.
A review of the fires that have taken placein 2011 indicated that the system isworking well and root causes are beingidentified.
In addition a system, INDSOP, (IndoramaSafety Observation Process) has beendeveloped for safety observations.
This is similar to the Du Pont STOPsystem and aims to encourage reportingof poor safety features on a no blamebasis.
EPCL are considering the use of Leadingindicators to modify the track safetyperformance.
Leading indicators are a relatively newapproach based on tracking factor whichmight lead to a major incident rather thanhistorical data which is more related tooccupational safety.
EmployeeInvolvement
EPCL have worked energetically at the siteand there is now a collective consensusthat safety is a line managementresponsibility with the safety function actinglargely as an auditor and advisor.
This is in line with modern safetyphilosophy.
A new draft safety manual is now beingprinted.
This covers a number of process safetymanagement issues in addition to thestandard "slip, trips and falls" procedures.
There is an interlocking series of 8 safetycommittees, the most senior being the APEX committee, which is chaired by theTechnical Director and involves the headsof departments. There are also individual
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
There is a "safety ambassador" for eacharea.
All new recruits are provided withinduction training by EPCL staff.
The ambassadors are Nigerian nationals,which should avoid the appearance of ex-pat personnel arriving on site andpreaching.
A recent initiative is the appointment of asenior operations person from each unit toact as a PSM (Process SafetyManagement) coordinator. It is intendedto conduct a process safety audit usingstandard references such as API 750 andCCPS guidelines as a basis.
Housekeeping Housekeeping was generally to a goodstandard.
Occasional examples of missing plugsand missing bolts on Ex rated electricalpanels were noted.
Where this occurs, this is an indicationthat the site conditions are not beinginspected properly before permits are"handed back" at the end of amaintenance activity.
In the worst example noted the situationwas rectified before the end of the survey.
Control of IgnitionSources
Smoking is only permitted in 2 authorisedlocations in the site.
There are reputed to be few smokers in theworkforce No evidence of smoking inunauthorized areas was noted during thesite visit, indicating a good level ofdiscipline.
EPCL do not consider that the use ofmobile phones in hydrocarbon areasconstitutes a hazard.
A number of infringements were noted,even by personnel at supervisor level.Whilst there is disagreement over the sparkpotential of a mobile phone, it would beprudent to prevent their use in hazardousareas. This not only removes a, possible,source of ignition but also avoids asituation where the safety rules start to losetheir clarity and are more likely to bedisobeyed.
All vehicles entering the process areashave flame arresters fitted.
Safety Auditing A variety of safety audits take place:
• Work permit audits These have only been introducedrecently.
• Internal WPCL safety managementaudits
• Check list audits by unit safetyambassadors
These use checklists and are performedby personnel within the unit concerned.
At present, there is no cross auditing.• British Safety Council Audits See above for results on the 2012 audit.
• INDSOP audits conducted by plantmanagers
Currently, there is no central database ofrecommendations.
This may lead to a piecemeal responseand lack of oversight at a senior level.
Contractors EPCL have a contractor safetymanagement programme including areview of contractor safety performance atthe tender stage.
Contractors have safety briefings whenthey first arrive on site. Some contractorshave safety training before arriving onsite.
There is also a safety committeededicated to contractor issues.
Contractor personnel will need a passshowing that they have received safetytraining before being allowed onto site.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
7.7. Emergency Response
Brief details are given below:
Details Comments
Organisation andStaffing Levels
The site fire team consists of:
• A fire chief
• 5 shift fire leaders
• 6 fire fighters per shift
An organization chart is shown below:
The fire team is fully staffed. Additionalpersonnel may be employed when thenew units come on stream.
Experience All the fire fighters have professional firetraining, including fire fighting training priorto joining EPCL.
Training The site has a fire training ground withfacilities for both pool fire and jet firetraining.
Fire fighter competence is likely to erodewithout live firefighting experience and itwould be desirable to resume regulartraining on both pool and jet fires as soonas possible to rebuild experience levels.
Currently, there is no smoke house in thetraining centre.
Training in the use of Breathing Apparatus (BA) will be essential foremergencies in the ammonia plant where
large toxic releases are possible.
EmployeeInvolvement
An auxiliary fire team composed of securityand maintenance personnel has beenestablished. This consists of 6 people pershift.
Mutual Aid A mutual aid scheme is being developedinvolving:
• Shell Petroleum (may not attend allfires).
• Mobil.
• Total/ELF
The inclusion of fire teams from otherhydrocarbon facilities will ensure thatmany of the mutual aid personnel will beexperienced in the specific dangersassociated with hydrocarbon fires.
• Port Harcourt Refinery. The level of operational equipmentavailable at Port Harcourt may be limited.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Control of Access tothe Site
There is one main gate into the site. Other gates could be used for emergencyaccess but are generally kept closed.
Physical Precautions
Since the kidnapping incident securityprecautions have been significantlyincreased.
• There is only one point of access to thesite, through a well-guarded gate.
• An access control system featuringswipe cards is being installed.
• The site has been divided into anumber of areas with securityposts between them.
• The original wire fences toppedwith barbed wire have now beenreplaced by a 3m concrete walltopped with an electrified fence.
• A multi camera CCTV monitoringsystem has being installedcovering the entire perimeter.The system has movementdetectors which alarm at thecentral monitoring station.
There are plans to extend thesystem.
All Ex-pat personnel and their families arenow located with the EPCL production site.
Construction areas will be fenced off toprevent construction personnel enteringoperational areas.
This will need to be done with care toensure that the newly installed fences donot block emergency exits and entrypoints to the existing plant.
Additional difficulties may be encounteredin the olefins plant where constructionactivities will take place within an existingplant and which may be operational attimes.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
8. Fire Protection
8.1. Fire and Gas Detection
Brief details of the fire detection systems are given below:
Details Comments
General Manual Call Points (MCPs) are installedthroughout the site.
Buildings Smoke detection is installed in buildings,including underfloor areas in controlrooms.
Detectors are also installed on the air
inlets for air conditioning systems.
The smoke detection system in the mainoffice building has not yet beenrenovated but the plant based systemsare understood to be operational or under
repair. See below.
Process Areas Gas detectors are installed through theprocess areas.
The gas detectors and panel for thepolypropylene plant have been replaced.Spare parts and vendor support for thesystems in other units is still available.
Heat detection systems are installed insome process areas to activate watersprays.
The level of detectors varies within theprocess facilities reflecting different designphilosophies. Numbers of detectors are:
• Olefins – 36.
• Polypropylene – 45.
• Butene –1 - 18
.
The fire alarm panels have beenrefurbished since EPCL took over the site.
During the survey most of the loops onthe panels had fault status lightsilluminated. This is reported to be duethe fact that the original power supplieshave been replaced. The internal logic inthe system does not recognise the newpower source and hence indicates a fault.
The gas detection system has beenrefurbished over the last few years.
Pellistor type detectors are still in userather than the more modern infra-redtypes. Whilst pellistor type detectors aremore susceptible to poisoning than infra-red types, process materials at the sitedo not contain sulphur – the mostcommon poison.
Storage Areas Within the LPG and refrigerated storageareas gas detectors are installed.
Smoke detectors are installed in thepolyethylene and polypropylene storagefacilities. Fusible plugs, activating delugesystems are also installed.
Gas detectors alarm at 25% and 50% ofLEL but do not initiate any shutdownaction.
The storage area F & G panel wasindicating a fault at the time of the survey.
Utilities The gas turbines are fitted with heat andflame detection systems. These activatecarbon dioxide extinguishing systems.
These systems are reported to beoperational and set to trigger theassociated carbon dioxide system.
Signalling There are local fire panels around the sitewith a repeater at the fire station.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Testing Regular testing of the fire and gas systemis undertaken.
Smoke generators are used to test thesmoke detectors, and "black light" torchesto check the flame detectors.
Gas detectors are reported to be tested byaerosol spray at 6 monthly intervals.
The gas detectors are pellistor typedetectors which are relatively oldtechnology. More modern designs, withincreased reliability feature infra-redtechnology.
8.2. Fire Water System
Brief details of the fire water system are given below:
Details Comments
Design Basis
Design fire water requirements for the siteare given below:
Olefins - 1,550 m3/hour.
Polypropylene - 1,470 m3/hour.
Polyethylene/Butene-1 - 1,350 m3/hour.
NGL storage - 1,717 m
3
/hour (based on afire affecting one sphere and cooling ofothers).
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Fire Pumps There are 4 main fire water pumps (2 dieseland 2 electric) each with a capacity of 900
m
3
/hour. A further diesel driven "supportpump" exists.
Pressure in the fire main is designed to bemaintained at 10.5 bar g by 2 jockey pumps(1 diesel and 1 electric) with a capacity of105 m
3/hour.
One of the main fire pumps is currently incontinuous operation as the demand for firewater for duties such as flushing and washdown exceeds the capacity of the jockeypump.
A new 50 m3/hr capacity jockey pump has
been installed but was not commissioned atthe time of the survey.
Once this pump is commissioned, itshould be possible to shut down themain electrical pump.
The diesel fuel tanks are located close to thediesel pumps and could affect them if thecontents spilled and ignited.
Whilst there is diking around the tank,which would contain spillages, highthermal radiation levels could damagethe fire pumps. In similar locations, it iscommon practice to install a firewallbetween the tanks and the pumps.
Fire Water Suppl y Fire water supply is taken from the two55,000 m
3 raw water tanks. With a minimum
of 65,000 m3 reserved for fire water.
The tanks are replenished from theboreholes described in section 6.6.1.
This supply would last for over 24 hours – well in excess of normal fire watercapacity.
Fire Main The fire water ring main is buried andconsists of a looped grid. The main loop is24 inches in diameter, with laterals and
branches ranging between 18 inch and 8inch.
The fire main is externally coated forcorrosion protection.
The fire water lines are reported to havebeen flow tested and found to be ingood condition with no serious
corrosion.
There are approximately 280 twin connectionhydrants at 90 m intervals or, in congestedplant areas, 50 m intervals.
In addition, there are 51 monitors around thesite.
Many monitors are located within poststo prevent impact damage.
Fire hose cabinets and fire reels are installedaround the site.
Some cases were noticed where fire waterhoses were being used for wash down orflushing.
This is considered undesirable.Operations personnel generally do notreplace fire fighting equipment after
use. This can result in equipment beingdamaged or unavailable when requiredfor firefighting.
If firefighting equipment is required forother purposes, it should be undersome form of impairment procedure.
In the Polyethylene plant the fire watersystem has been tied in to provideemergency cooling water for the process.
This should ensure a supply of coolingwater in the event of a power cut, thetemptation to use fire water for routinecooling must be resisted.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Testing
The main fire pumps, electric and diesel firepumps are started for 30 - 40 minutes every
15 days.
The reason for the 15 day test intervalis to minimise the number of times that
the electric fire pump is started, as highlevels of current are required when thepump starts.
The NFPA guidelines recommend 30minute testing on a weekly basis fordiesel and 10 minutes on a monthlybasis for electric pumps and this periodshould be used in the future.
The pumps are started by dropping thepressure in the main.
This will ensure that theinstrumentation, as well as the pump isoperational.
The fire pump head curves are checked on asix monthly basis but flow curves are notproduced.
A flow meter is installed in the fire waterreturn line to the fire water tank which willfacilitate fire water pump testing.
It would be prepare actual flow curvesfor the pumps so that performanceacross the entire pump curve can bereviewed, rather than performance at
individual points on the curve.
8.3. Active Systems
The active systems were observed to be in poor condition when the plant was operated by
NNPC but considerable renovation work has taken place since Indorama took over the site.
Details Comments
Buildings A number of fixed systems are installed invarious buildings:
• Laboratory – sprinkler system with a7.74 l/min/m
2 density.
• Control and rack rooms (includingunderfloor areas) – halon or carbondioxide systems.
Some of the underfloor systems incontrol rooms use carbon dioxide whichis an asphyxiant. These are set formanual operation to allow personnel toevacuate the room before the system istriggered.
The halon systems are reported to beinterlocked with air conditioning equipment.Halon systems are slowly being replaced byFM 200.
Halon is now banned under theMontreal Protocol but some developingcountries have a waiver for continuinguse for a period.
In some locations, such as theinstrument rack room in the olefins
room, the doors are open and portablefans installed due to defects in the airconditioning system and this willprevent the extinguishing systemworking effectively. Whilst there will beconsiderable movement into and out ofthe rack rooms during start-up thenormal practice should be to keep thedoors shut.
This has been an on-going problem fora number of years.
Process Areas In addition to hydrants, monitors andextinguishers, a number of systems areinstalled in the process areas:
• Fired heaters have manually operatedsteam snuffing systems. Actuationvalves are located at a safe distance.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
• A number of hand held steam lances areavailable.
• Automatically actuated foam/waterdeluge systems are installed on vesselsand pump seals in the polymer plants
• Automatically actuated water delugesystems in the polypropylene plant, 4 intotal.
There is a significant variation in thelevel of protection between the olefinand polyethylene plants.
• A manually operated deluge system isinstalled around the refrigerationcompressors in the olefin plant.
Deluge rates are 10.2/l/min/m2 for most
duties and 20.4 l/min/m2 for pumps.
A similar system may be installedaround the cracked gas compressor butthis was not visited during the survey.
• Dry powder systems are installed toprotect the TEAL handling systems inthe polypropylene plant.
These are activated by melt tubes.
Storage Areas All the major liquid storage facilities havefixed fire protection:
• Main atmospheric storage tanks – waterdeluge (varying from 6.5/l/min/m
2 to 12.2
/l/min/m2) fixed foam systems.
• Spheres have water deluge ringscovering the entire surface.
• The refrigerated ethylene tank has awater deluge system with a density of10.2 l/min/m
2. In addition there is an
impounding basin for containment ofethylene spillages which is equippedwith water deluge and fixed foamsystems.
The bladder tanks for the foam systems arereported to have been recently tested andfound to be in good condition and arerechecked at 2 yearly intervals.
Discharge rates appear to be in linewith API standards.
Fire protection systems on tanks arebeing overhauled.
The polypropylene and polyethylenewarehouses have water deluge systems withwater densities varying between 7.8 l/min/m
2
and 18.3 l/min/m2 depending on the area
being protected.
The catalyst storage facility has a delugesystem with a water density of 15.1l/min/m
2.
2 of the sprinkler systems were isolatedat the time of the inspection.
There are a limited number of extinguishersand hose reels within warehouses.
Access to some equipment was limited.
Utilities A number of fixed systems are installed inthe utility areas:
• Motor Control Centres (MCCs) andswitchrooms have fixed carbon dioxideextinguishing systems
The provision of fixed systems againsuggests a difference in designphilosophies between the differentplants. There are no fixed systemswithin the olefin unit, whilst MCCs andswitchrooms in both the polypropyleneand polyethylene plants haveprotection.
• Fixed carbon dioxide systems areinstalled in the 4 gas turbine cubicles.
There were no water deluge systems notedon the main transformers.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Testing Fire fighting systems are maintained on anannual basis.
8.4. Passive Systems
Brief details are given below:
Details Comments
Buildings Control rooms for the process units are blastresistant without windows. However in allthe process control rooms visited, the maindoors were open.
The level of blast resistance was notdetermined.
Despite the blast resistant design, theintegrity of the control rooms is reducedif doors are left open.
Process Areas
The level of passive fire protection variesconsiderably with only limited protection inthe olefins plant but a considerably higherlevel of protection in the polyethylene plant.
Again this suggests different fireprotection philosophies between thedifferent licensors and contractors.
The requirement for fireproofing will belower in plants handling hydrocarbonswhich will be in the gas phase afterrelease rather than the liquid phasewhere pool fires might result.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
Details Comments
Many vessel skirts are fire proofed. Fire proofing has been applied to anumber of vessels where it was
previously missing but there may beothers where fire proofing is stillrequired.
The level of fire proofing on piperacks isvariable with some racks carryingpredominantly hydrocarbon gases being fireproofed in the polyethylene plant. In otherlocations piping with liquid inventories is inun-fireproofed racks.
There is generally little value infireproofing piperacks containing gases.Fireproofing is designed basically asprotection from liquid pool fires.
Fin fan coolers are partially fireproofed butnot to the full load bearing height.
The air flow from the fin fans willexacerbate flames from a pool fire. Theprovision of fireproofing almost to thetop of the fin fan cooler will minimise theextent of damage caused by a pool fireunder the fin fan.
In some places, particularly in the processareas, fire proofing was damaged andrequires repair.
The TEAL (catalyst) storage areas in thepolypropylene and polyethylene plants areconstructed of concrete with dividing wallsbetween the TEAL containers.
In some locations pipe supports on liquidlines were not fire proofed.
Storage Areas Sphere legs are fireproofed.
2 hour rated fire walls are installed in somewarehouses.
Utilities Fire walls are installed between transformerswith stone covered drainage at the base.
2 hour rated fire doors are installed at allsubstations.
In some cases, the height of the firewall might not be sufficient to prevent adegree of thermal radiation exposure bythe adjacent transformer.
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
8.5. Mobile Equipment
8.5.1. Fire Trucks
Brief details of the fire trucks are given in the table below:
No. ofTrucks Details Comments
Combination Truck 3 3,000 l/min water pump at100m head.
4,000 l foam, 8,000 l water and1,000kg dry chemical.
One of these is a new Tata fire truckpurchased since Indorama purchasedthe EPCL.
Multi-purpose truck 1 8,000 l water and 1,0000 lfoam
This is a new truck purchased since the2009 survey. It was originally intendedto deal with bush fires originatingoutside the site. However, bush fireshave ceased to be an issue since theconcrete security wall has been built.
Bronto Skylift 1 Foam/water pump 3,000 1/mincapacity at 100 m head.
4,000 l foam.
Rescue Truck 1 250 Kg of dry powder with adischarge rate of 2.3 kg/sec.
Water Tender 1 7,000 l water A monitor has now been added to this
466129 Eleme Petrochemical Company Limited (EPCL), Port Harcourt, Nigeria DS/RWB/RAR
No. ofTrucks Details Comments
Foam Trailer 1 4,000 l foam.
Dry ChemicalPowder
1 4,000 l water
All fire trucks are reported to be operational.
There are approximately 1,500 portable fire extinguishers throughout the site. These are drypowder, carbon dioxide and pressurised water types. The halon extinguishers at the site
have been taken out of service, as required by the Montreal Protocol, and replaced by
additional CO2 and dry powder extinguishers. Extinguishers are serviced at six monthly
intervals.
The fire station and fire-water pumps are remote from the process area.
Based on the inspection tags on the fire extinguishers, there appears to be inconsistenciesin the frequency of inspection.
8.5.2. Foam and Dry Powder Stocks
Minimum foam stocks are:
• AFFF – 6,000 litres
• AFFF (ATC) – 5,000 litres
• FFFP – 10,000 litres
• Dry chemical powder 4,000 litres
Care should be taken in the use of foam as mixing different foam types may reduce
efficiency.
Some foam is available in fire trucks and a 3,800 l overhead tank has been installed to
provide rapid refilling of fire trucks, together with a limited stock in drums.
The frequency of testing of foam stocks is unknown.