EPCL Port Harcourt DRAFT PDF

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

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 Authority
Registered Office: Standard House, 12-13 Essex Street,
London WC2R 3AA Registered in England No. 1994696
A Charles Taylor company
Revision
Date
Comments
October 2012
Resurvey
May 2011
Resurvey
June 2009
Resurvey
December 2006
Revised to include new values and loss

estimates
November 2006
Updated to include client comments
October 2006
Previous survey in March 2005 when the

site was owned by NNPC
Report for
United Insurance Brokers,
Mansell Court,
69 Mansell Street,
London,
E1 8AN
Insurance Risk Survey of

Eleme
Petrochemical
Company
Limited
(EPCL), Port Harcourt,
Nigeria
Main Contributors
Doug Scott
22nd to 24th October 2012
Issued by
Doug Scott
BTech CEng CSci FIChemE MEI
Reviewed by
Roger Barrett
BEng CEng FIChemE
Approved by
Draft
Charles Taylor plc

Disclaimer
Richard Radevsky
BSc, CEng, CSci, CEnv, PEng, FICE, FCIWEM, MEI,
MIFireE, FCIArb
Charles Taylor
88 Leadenhall Street
London
EC3A 3BP
UK
Tel: +44 (0) 20 7623 1819
Fax: +44 (0) 20 7623 1817
This report has been prepared solely for the use

of Eleme Petrochemical Company Limited
(EPCL) and Eleme Petrochemical Company
Limited (EPCL)s insurance brokers and
underwriters. Neither Charles Taylor nor its
individual
representatives
shall
in
any
circumstances be responsible to any other
person for any loss or damage or liability
however caused arising from the use of his
report or the information it contains.
Charles Taylor Adjustings Standard Terms and
Conditions can be found at:
http://www.charlestayloradj.com/pdfs/TermsAnd
Conditions.pdf
Executive Summary
Introduction
Charles Taylor Technical (CTT) has been commissioned by United Insurance Brokers to
produce 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 business
interruption 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 has
been 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 in
2012 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 of
the 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, whilst
construction 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 the
Nigerian National Petroleum Organization Corporation (NNPC) but was sold to
Indorama in May 2006. EPCL operates an olefins plant and downstream units, which
are mostly polymer plants, at Port Harcourt, Nigeria. The facilities date from the mid1990s. The site suffered from underfunding for many years but since Indorama took
over 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 and
families.
The facilities are relatively modern with good spacing between the individual process
units, utilities and the storage area. However, there is an element of congestion within
some of the process facilities. The level of loss prevention features varies between
process units. 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 plot
layout of the site was originally developed.
Administration
Prior to the sale of EPCL to Indorama, NNPC maintained an unusually tight control
over finances. This resulted in serious underfunding, particularly of the maintenance
budget and no major overhaul of the site was undertaken between 1996 and 2006.
The site organization generally follows accepted practice, with a direct reporting route
from the safety manager to the site manager. There are currently no unusual features
and a technical services group has now been established.
Staffing levels have been significantly reduced from the approximately 1,200 present
when NNPC ran the site 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 positions
with 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 further
turnaround 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 to
be 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 personnel
supplemented by police and military personnel.
Fire Protection
The fire detection and protection systems have been overhauled and are largely
operational. However some obsolete systems are in place, including a number of
halon systems. One of the electrical fire pumps is in continuous operation to supply
water 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 in
good 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 still
has 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.
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 Amount
USD
Details
850,000
Limitations
of
feedstock
supply.
This
has
reduced
production at the plant and also
caused an increased cost of working
as a result of increased utility usage
per unit of production.
Damage to Olefin Plant cold box.

The cause has not been positively
identified but is probably due to
thermal cracking of the cold box
during start-ups and shutdowns
since the plant was commissioned.
10 Jan 2009
May 2008
Comments
The
claim
was
subsequently
withdrawn.
Repairs
were made and a
replacement cold box ordered. This
was installed at the last turnaround
in 2010.
Loss Estimates
Scenario
Property
Damage
(USD
Million)
Business
Interruption
(USD
Million)
Combined
(USD Millions)
Property Damage
Vapour cloud explosion in the olefin

plant following a release from the C2
splitter reflux drum
435
600
1,035
Machinery
Breakdown
Damage to the rotating elements of

the
olefin
plant
cracked
gas
compressor
19.0
50.0
69.0
Complete destruction of the olefin

plant 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 indemnity
period) for business interruption losses.
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:
Withdrawn, 2,
Unknown, 0, 0%
8%
Completed, 6,
25%
In Progress, 11,
46%
Unchanged, 5,
21%
The key features of the site have been assessed using CTTs Key Risk Rating Indicator
System (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 of
individual features have been identified and rated according to the KRRIS system. The
higher the number (rated 0 to 4), the better the risk. The risks are also represented
graphically (ranging from red for poor, to bright green for good). The results are shown
below.
2008 Charles Taylor technical
Overall Presentation Sheet

Printer Friendly Versi
Latest
Assessment
Hardware
Natural Perils
Previous
Assessment
Inherent Hazard
5 Parameters
Operating Procedures
Layout
2 Parameters
Water Supplies
2.8
3.0
Fire w ater system appears in good condition,.

There is still a problem w ith use of f ire w ater
f orw ashdow n, etc.
6 Parameters
Perm it to Work System
4 Parameters
Drainage
2.6
Permit system is operating satisf actoaly but some

minor improvements are possible.
2.8
Fire detection systems have been repaired The

system is reported to be operational, although
there are a large number of f ault alarms..
1.0
Previous
Assessment
The f acilite process large quanties of volatile

hydrocarbon materials.
6 Parameters
Fire and Gas Detection
3.5
Operating procedures have been revised but

f urther improvements are possible.
Protections
2.8
Note that f urture construction projects couls

impat the operating procedures.
Latest
Assessment
Minor exposure f rom other f acilities.
Previous
Assessment
All senior management positions occupied by expats.
External Exposures
9 Parameters
Software
Managem ent
3.5
Natural perils at the site are limited.
7 Parameters
Latest
Assessment
2.5
Vegitation has been cleared f rom the drains

since the last survey.
A LOTO system ahs now been implemented.
6 Parameters
Maintenance
2.8
Layout betw een units is generally spacious.

There are some congested areas w ithin the units
4
Process
Area Fire
Fire f ighting systems are operational.
2.3
A considerable amount of mainteance w ork has

taken place since the take over by Indorama. The
condition and reliability of the equipment is much
improved. Availability is now approaching 100%
3 Parameters
2.1
An ORICLE based CMMS is now in use.
2 Parameters
Control System s
2.0
Process Safety System s
Loading/ Unloading
Storage
3 Parameters
Managem ent of
Change
Utilities
Machinery
2 Parameters
2.0
Systems appear to be in good condition
3 Parameters
Inspection Procedures
4
3
5 Parameters
Safety Procedures and

Practices
3 Parameters
Passive
Protection
Level of passive protection varies betw een
dif f erent process units.
3.0
Inspection Procedures are to a generally good

standard w ith a w ell trained and enthusiastic
w orkf orce.
The site is moving is considering a move to Risk
Based Inspection but does not have enough data
to trend corrosion rates.
1.8
4 Parameters
Foam
Supplies
3.0
N/A
There are signif icant stocks of f oam. It is not

clear if the f oam is regularly inspected.
5 Parameters
Em ergency
2.8
Response
The emergency response capability appears
adequate and some, basic, pre-planning has
been done.
2
1
3 Parameters
Portable Equipm ent
3.3
Fixed f ire f ighting equipment is on good condition
2.0
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
2.2
The site is largely self suf f icent in utilities.
3 Parameters
Utility Area Fire

Protection
2.3
Saf ety procedures are generally to a high

stadard. There is increased aw areness and
implementation of process saf ety procedures.
A major pow er f ailure occurred in earlier in 2012,

resulting in a total plant shutdow n.
7 Parameters
1.8
1.5
Systems examined w ere generally in good

condition, w ith the exception of the a f oam
system f or the ethylene storage area.
Some of the storage f acilities have been

ref urbished.
5 Parameters
4 Parameters
N/A
Most porducts are transported by truck in a non

haardous f orm. A new road tanker unloading
f acility has been built w ith basic f acilities.Pipeline
systems w ere not review ed in detail during the
survey
2.3
The management of change is capable of

improvement.
5 Parameters
6 Parameters
Offsites Fire Protection
2.0
The engineering f unction is reported to be

adequately staf f ed and resourced.
Although control rooms are blastproof ed, the

doors are f requently lef t in the open position.
Engineering/
Technical Services
DCS systems have been upgraded
3 Parameters
6 Parameters
6 Parameters
Security
A high level of security is in place at the site.

4
1.4
Testing of gas gestion systems f ollow s normal

practice.
Testing/Inspection
3.0
5 Parameters
3 Parameters
How ever testing of the f ire w ater pumps is not

f ully in line w ith NFPA standards.
6 Parameters
This sheet summaries the various parameters for each of the indicators shown above. For a full understanding of the individual parameters contributing to indicator, the individual hardware, software
and protections worksheets should be consulted
Contents
1.
Introduction
1.1.
1.2.
1.3.
1.3.1.
2.
Background
2.1.
2.1.1.
2.1.2.
2.2.
3.
Insured Values
Property Values
Business Interruption
Loss History
Recommendations for Risk Improvement

3.1.
3.2.
4.
The Survey
The Company
The Location
Meteorological Information
New Recommendations
Previous Recommendations
Exposure to Perils
4.1.
4.1.1.
4.1.2.
4.1.3.
4.1.4.
4.1.5.
4.1.6.
4.1.7.
4.1.8.
4.1.9.
4.1.10.
4.1.11.
4.1.12.
4.1.13.
4.1.14.
4.2.
4.3.
4.4.
Property
Fire and Explosion
Surrounding Exposures
Subsidence and Collapse
Earthquake
Tsunami
Volcano
Lightning
Wind and Storm
Flood
Vehicle Impact
Vessel Impact
Aircraft Impact
Riot Strike and Civil Commotion
Terrorism and Sabotage
Machinery Breakdown
Construction
Business Interruption
11
11
12
13
14
16
16
16
17
17
18
18
22
40
40
40
40
41
41
41
41
42
42
43
43
43
43
44
45
45
45
46
5.
Loss Estimates
5.1.
5.2.
5.3.
5.4.
5.5.
5.6.
6.
Definitions and Loss Scenarios

Property Damage
Property Damage Business Interruption
Machinery Breakdown
Machinery Breakdown Business Interruption
Summary of Loss Estimates
Description of Installation
6.1.
6.1.1.
6.1.2.
6.1.3.
6.1.4.
6.2.
6.2.1.
6.2.2.
6.2.3.
6.2.4.
6.2.5.
6.2.6.
6.2.7.
6.3.
6.3.1.
6.3.2.
6.4.
6.4.1.
6.4.2.
6.4.3.
6.4.4.
6.5.
6.5.1.
6.5.2.
6.5.3.
6.5.4.
6.5.5.
6.5.6.
6.5.7.
6.5.8.
6.5.9.
6.5.10.
6.6.
Production Facilities
Process Units
New Projects
Process Hazards
Layout
Control and Process Safety Systems
Basis
Control Room Design
Emergency Shutdown Systems
Remote Isolation, Depressurisation and Blowdown
Pressure Relief Systems
Combustion Safeguards
Shaft Sealing
Feedstock Supply and Product Transfer
Road
Pipeline
Storage Facilities
Atmospheric Storage
Pressurised Storage
Refrigerated Storage
Warehousing
Utilities
Water
Fuel Gas/Fuel Oil
Steam
Electricity
Hot Oil
Air
Nitrogen
Flare
Effluent Treatment
Incineration
Major Equipment Items
47
47
47
49
50
50
51
52
52
53
55
55
58
61
61
61
62
62
62
63
63
63
63
63
63
64
65
69
72
72
73
74
74
75
77
77
78
78
78
79
79
10
7.
8.
Administration
81
7.1.
7.2.
7.2.1.
7.2.2.
7.3.
7.3.1.
7.4.
7.4.1.
7.4.2.
7.4.3.
7.5.
7.6.
7.7.
7.8.
81
82
82
85
87
87
93
93
95
95
96
102
106
107
Organisation
Operations
Process Operations
Control of Maintenance
Maintenance
Turn Around Maintenance (TAM)
Engineering
Management
Management of Change
Hazard Studies
Inspection
Safety, Health and Environment
Emergency Response
Security
Fire Protection
8.1.
8.2.
8.3.
8.4.
8.5.
8.5.1.
8.5.2.
Fire and Gas Detection

Fire Water System
Active Systems
Passive Systems
Mobile Equipment
Fire Trucks
Foam and Dry Powder Stocks
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
List of Acronyms
Information on Impairment Systems
Management of Change Checklist
Organizational Change Guidance
Sample Fire Fighting Pre-plan
Plotplan
Permit to Work Forms
110
110
111
113
115
117
117
118
11
1. Introduction
1.1. The Survey
Charles Taylor Technical (CTT) has been commissioned by United Insurance Brokers to
produce an underwriting survey report, for insurance purposes, of Eleme Petrochemical
Company Limited (EPCL), Port Harcourt, Nigeria.
The survey concentrated on property damage, machinery breakdown and business
interruption
The following personnel were involved in the survey their assistance is acknowledged with
appreciation.
Leadway Insurance
Ojo Olatunde
Risk Surveyor
Dover Engineering
Kesiena Atirene
Risk Survey Engineer
Eleme Petrochemicals Co Ltd.

B.K. Shavastava
Technical Director
M. Bhosale
Technical Director's office
S.C. Sarkar
E. Ikpuku
S. Ichin
Olefins Plant Manager
D. Mital
Olefins Plant
S. Bhaliachaiyay
Olefins Plant
A.B. Rao
Polymer Plants Manager
Nwakaji Ekaa
Polypropylene Plant
S.K. Dave
Polypropylene Plant
Anil Gupta
Power & Utilities Manager
S.B. Sagdeo
Engineer
Phool Sugh
Engineer
B. Mangalmurit
Engineer
Enyinda Sylvester
CES Workshop
Chintamani P.
Mechanical Engineer
Linaye
Mechanical Engineer
Jaja B.
Mechanical Engineer
Mohan Putta
Mechanical Engineer
Phool Singh
Rotating Machinery Engineer
Nwajiobi Collinns
Electrical Engineer
A.K. Bharucha
Electrical Engineer
Porkay Bhall
Electrical Engineer
12
S. Dineshkumar
Instrument Engineer
S.B. Sagdeo
Instrument Engineer
Ansari Siraje Alam

B. Phamanage
Technical Services Department
Bareen Phamarage
Eniafe Babajide
Ezemwugo Patricia
Ezugu Benneth
Nwawosike A. Joy
Olumoye O.R.
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 for
risk 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 with
interests ranging from petrochemicals, textiles and cement. The timeframe for the takeover
is shown below:
13
The NNPC organization was centrally controlled, with individual subsidiaries having limited
authority for expenditure and other decision making. This resulted in difficulties in planning,
recruitment and maintenance of the major locations. The sale of EPCL to Indorama has
reduced the constraints of central control and has allowed access to funds for long overdue
maintenance at the site, as well as changes to the management structure and operating
procedures.
The senior management members at the site have all arrived since privatisation and are
mostly Indian nationals. In addition, there are Indian expats at all levels within the
organization. Most of the original Nigerian workforce has left EPCL for other parts of NNPC.
Training programmes are being set up for Nigerian nationals with the long term intention of
replacing Indian staff with Nigerian nationals.
Further details of Indorama are available from the companys website:
http://www.indorama.com/
1.3. The Location

Eleme Petrochemicals Company Limited (EPCL) operates a single petrochemicals site at
Port Harcourt in the River Province of Nigeria. It consists of an ethylene cracker,
polyethylene, polypropylene and butene-1 plants, together with associated utilities, storage
and infrastructure. The plant was commissioned in 1996 and had been operating
continuously since then, without a major shutdown for maintenance (Turn Around
Maintenance or TAM), until 2006 when the management of EPCL was taken over by
Indorama.
Due to the lack of maintenance and feedstock limitations, the process units had seldom
performed at anything like full capacity and were frequently shutdown. Since the takeover
by Indorama, there has been significant capital investment and a number of shutdowns for
site wide maintenance and refurbishment.
The plant is located near the town of Eleme, approximately 15 minutes drive from Port
Harcourt, the capital of Rivers State. The site is elevated 15m to 18m above the level of the
Bonny River, which runs 5km from the site, and there is no history of flooding in the area.
14
1.3.1. Meteorological Information

Meteorological conditions in Port Harcourt are shown below:
Brief details of the meteorological conditions, when known are given below
Topology
The area is flat and no terracing is necessary.
Lightning
There are around 140 lightning days per year and lightning strikes have affected the site.
Temperature
Maximum temperatures are approximately 32C to 33C, with minimum temperatures of

approximately 20C to 22C.
Humidity
Humidity is typically in the region of 90%.
Rain
Rainfall is approximately 3,000 mm per year, with the rainy season lasting from March to
November.
Wind and Storm
Prevailing wind from the Northeast in the dry season and Southwest in the wet season.
Further information is given below:

Temperature
Average
Record
Relative
Humidity
Max
Average
Dew Point
(C)
am
pm
15
37
21
93
57
29
13
37
22
93
61
27
28
21
39
68
27
26
28
20
36
23
May
27
26
28
21
37
23
96
73
June
26
26
27
18
37
23
96
78
Average
Temperature
Min
Max
Min
Jan
27
26
28
Feb
28
27
March
27
April
Month
Average No. of
Days with
Precipitation
15
Temperature
Average
Record
Relative
Humidity
Max
Average
Dew Point
(C)
am
pm
Average No. of
Days with
Precipitation
16
41
22
96
79
11
26
20
32
22
97
81
13
24
26
21
37
23
98
25
25
26
21
36
23
97
76
Nov
26
25
27
18
37
22
96
69
Dec
26
25
27
17
37
21
93
61
Average
Temperature
Min
Max
Min
July
25
24
26
Aug
25
24
Sept
25
Oct
Month
Source: http://www.weatherbase.com
16
2. Background
2.1. Insured Values
2.1.1. Property Values
The replacement values for the facilities were estimated by AVC (of the UK) in 2006 to be
USD 868 million. A revaluation by AVC was undertaken in 2011 but the available valuation
data provided is from the 2006 valuation and the breakdown of the current insured values
are given below:
Unit
USD
Ethylene Cracker
284,800,000
Polyethylene
181,700,000
Butene-1
10,500,000
Polypropylene
80,100,000
Polypropylene Bagging
24,200,000
10,500,000
Storage Area (Including Pipeline to

Refinery)
57,600,000
Power Station
109,300,000
Cooling Water
23,100,000
Demineralised Water
33,400,000
Air and Nitrogen
22,900,000
Flare Area
Effluent Treatment (Including Incinerator)
Administration and General
Refinery Tank Farm
Total
9,400,000
16,800,000
Excluded
3,700,000
868,000,000
These values are now six years old and a revaluation would be prudent.
The following non process property has been notified:
USD
Laboratory
16,400,000
Plastic Technology Centre
13,950,000
Administrative Department
8,020,000
Main Workshop
7,970,000
Main Warehouse
6,640,000
17
USD
Technical Building
5,610,000
Canteen
3,990,000
Medical 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 12
months (24 months is commonly assumed) and therefore underwriters exposure is likely to
be considerably less than the full business interruption figure.
2.2. Loss History

Brief details of loss history are given in the table below:
Date
10 Jan 2009
May 2008
Loss Amount
USD
Details
850,000
Limitations
of
feedstock
supply.
This
has
reduced
production at the plant and also
caused an increased cost of working
as a result of increased utility usage
per unit of production.
Damage to Olefin Plant cold box.

The cause has not been positively
identified but is probably due to
thermal cracking of the cold box
during start-ups and shutdowns
since the plant was commissioned.
Comments
The
claim
was
subsequently
withdrawn.
Repairs were made and a
replacement cold box ordered. This
has now arrived on site and was
installed at the last turnaround in
2010.
18
3. Recommendations for Risk Improvement

3.1. New Recommendations
CTT categorises recommendations with the following classification:
1. Priority: Major risk deficiency that requires prompt action. It is advised that capital
expenditure be allocated to these recommendations in preference to other
recommendations listed here. These recommendations should be completed within three
months of the survey report date.
2. CAPEX: Recommendations requiring capital investment. These recommendations

should be completed within the next budget cycle unless a major shutdown is required
for implementation.
3. Procedural: Recommendations requiring little capital investment.

These
recommendations require effort and commitment by staff and can make an important
contribution to risk improvement. They should not be regarded as trivial items. These
recommendations should be completed with 12 months of the survey report date.
12-01
Category
New Projects Risk Engineering Review

Priority
CAPEX
Procedural
Recommendation
Undertake a risk engineering review of the proposed new units. This will
involve a review of the design to:
Ensure that appropriate process safety features are installed.
An adequate level of fire protection is installed.
Time to react to and recover from incidents is minimised.
Process safety and fire fighting systems are appropriate for staffing
levels and maintenance regimes that will exist once the units are
complete.
The study is probably best conducted at the project contractors offices at a
point in time where the findings can be incorporated in the final scope of work.
Reason
A risk engineering review will ensure that appropriate process safety features
are built into the new units. This, in turn, will result in a greater potential for
the incidents to be more easily prevented or controlled.
Examples
Ammonia, Urea and Ethylene plant upgrade projects.
19
12-02
Category
New Projects Consequence Modelling

Priority
CAPEX
Procedural
Recommendation
Perform a study using consequence modelling to determine the effects of an

incident in one part of the site on other locations. The study should cover
areas outside the process facilities, including: storage, utilities, offices,
accommodation areas and residential areas outside the site boundary. The
study should consider:
Explosions (including VCE and BLEVE).
Fire (both pool and jet fire).
Toxic gas release.
Terrorism and sabotage.
Natural perils.
Utility failures.
Contingent failures such as loss of feedstock.

The study should consider hazards at both the construction and operational
stages.
The results of the study would provide input into the detailed design and
layout of the facilities (including the requirement for safe havens in the event
of a major ammonia escape) and emergency planning.
Reason
The new plants being constructed, plus planned expansion to the original
facilities, will change the overall hazard profile at the site.
The
interrelationship of the hazards needs to be considered in detail, especially as
there are now a significant number of people resident at the site something
not envisaged at the design stage.
Examples
Planned construction projects at the site, particularly the ammonia and urea
plants.
12-03
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 recording
of revision numbers and dates of changes).
There should also be a consistent approach to the storage and filing of master
copies of documents and a register of holders for controlled documents.
Reason
Unless there is a consistent approach to document control, there is a potential

for confusion between the status of documents at different parts of the site.
Examples
There are different approaches to controlling documentation at the olefins and

polymer units. Within the Olefins plant, there is a "controlled" copy with a red
stamp on each page. If photocopied the red stamp will appear as black and it
will be clear that the document may not be up to date.
Within the polymer units "original copies" are available which have no
distinguishing stamps.
20
12-04
Category

Priority
CAPEX
Procedural
Recommendation
Revise the permit procedure to ensure that permits are filed for more than a
week. The following points should be considered:
If all copies of the permits are collected together and "signed back", there
can be no confusion regarding the status of work which could occur if a
loose copy of the permit was found.
There should be separate files for completed and uncompleted work.
In addition to the permit forms, supporting information should be included
(Job safety analysis sheets, isolation certificates).
There should be regular auditing of the permit system.
Whilst filing in the control room for an extended period (beyond the
normal auditing frequency) is not necessary it is common to file permits
for a two year period.
Reason
The current practice of filing a single copy of each permit for only a week
gives limited opportunity for auditing.
Examples
Files of permits in all units.
12-05
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 that
recommendations are being progressed towards an end point for
implementation.
Ideally, the database should nominate a responsible individual for each
recommendation, with a timeframe for implementation and automatic flagging
of overdue actions.
Reason
Unless a comprehensive set of recommendations is available together with a

robust programme for implementation, there is a danger that many
recommendations will not be completed.
In addition a backlog of incomplete recommendations is likely to have a
negative effect on the safety culture of the site.
Examples
EPCL operated several databases for recommendations from different

sources.
21
12-06
Category
Ethylene Storage Tank Area - Housekeeping

Priority
CAPEX
Procedural
Recommendation
Clear vegetation from the dike area and make sure that the area, including the
impounding basin is in good condition.
Confirm that the foam system for the impounding basin is in good condition
(both the equipment and the foam).
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 the
impounding basin. This could limit the capacity of the tank for ethylene spills
and the water would provide a source of heat to assist vaporization of
ethylene. In addition. tree roots might cause damage, to the basin and
damage its integrity.
The integrity of the foam system is unknown and may not be functional.
Examples
Ethylene storage tank area.
12-07
Category
Gas Detection Systems for Occupied buildings

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 to
a 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 the
temperature rise when flammable gas is combusted on a catalyst pellet. If
detectors are installed in a moving air stream, there will be a cooling effect
which will counter the heat rise, possibly leading to false readings.
Examples
Olefin plant control room.
12-08
Category
Inspection of Fire Protection Equipment

Priority
CAPEX
Procedural
Recommendation
Ensure that regular inspections of ALL fire fighting equipment are made and
recorded. Ideally there should be random spot checks by management to
ensure that inspections are being correctly undertaken.
This recommendation should be read in conjunction with recommendation 0601.
Reason
Unless regularly inspected, it is difficult to ensure that equipment is in the

correct location and in good condition.
Examples
Whilst almost all extinguishers had inspection tags, the frequency of

inspection varied from one location to another.
In addition, some sprinkler systems in the Polyethylene warehouse had been
isolated.
22
12-09
Testing of fire fighting Foam
Category
Priority
CAPEX
Procedural
Recommendation
Conduct regular checks on the stocks of fire fighting foam at the site. Foam
which is not in good condition should be replaced.
Reason
Defective fire fighting foam will perform effectively either in a fire fighting role
or 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 owned
and operated by NNPC. During these surveys numerous recommendations were made and,
during NNPCs ownership, there was little improvement. The recommendations below were
those which were outstanding at the end of the 2011 survey.
Of the 24 recommendations in 2011:
6 are complete
11 are In progress
2 are withdrawn
5 are Unchanged
11-01
Category
SIMOPS (Simultaneous Operations)
Recommendation
Develop a procedure to control simultaneous construction and operation within the

same area. The procedure should include, but not be limited to:
Ensuring adequate separation between construction and operational areas,

including the installation of fences and emergency exits
A risk matrix to identify which construction/commissioning activities can be safety

undertaken concurrently with operational activities.
Communication between operating and construction personnel in areas such as:

o Hot work
o Emergency response
A good description of SIMOPS activities at an onsite location is available from:
http://www.onepetro.org/mslib/servlet/onepetropreview?id=IPTC-13705-MS&soc=IPTC
Reason
Construction and commissioning activities can lead to hazardous situations, which,

without careful control and communication, can result in hazardous situations
occurring.
Examples
The main value of the SIMOPS procedure will be in the future when construction of the
LDPE, methanol and ammonia/urea plants takes place.
There are some areas within the existing facilities where SIMOPS is currently
applicable, for example in the construction work being undertaken in the PE plant.
Where a portable concrete mixer with an internal combustion engine was in use. This
appeared to be close to or within an electrically classified area with no evidence of a
hot work permit.
EPCL Post Survey

Comment 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 that
this recommendation is completed without delay.
23
Internal combustion driven concrete mixer

close to process area in PE plant
11-02
Category
Wafer Valves
Recommendation
Identify any wafer (long bolted) valves on hydrocarbon lines in the process units and
storage areas.
These should either be replaced with standard flanged valves or provided with
insulation and a fire resistant covering.
Reason
The longer bolts in wafer type valves have limited thermal inertia and will heat up
quickly in a fire. They are also likely to suffer from direct flame impingement if there is
a fire in the area. The direct flame contact causes the bolts to expand rapidly and
lengthen, allowing both gaskets to leak hydrocarbons which will feed the fire and
increase the level of damage.
Examples
A wafer type valve was identified in the piping around the 1-C-5 column in the Olefin
plant.
EPCL Post Survey

Comment 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 October
2012
Insulation has been installed to protect the long bolted flanges, an example was shown
below.
The recommendation is COMPLETE.
24
11-03
Category
Recommendation
3
Conduct a fundamental review of the existing procedures for the control of
maintenance to ensure compliance with existing good practice in the hydrocarbon
processing industries.
The review should include a full assessment of all aspects of the maintenance
activities, including:
The requirement for some form of risk assessment before the start of each activity
(standard procedures could be used for frequent activities).
Ensure that the job site is visited by operations and maintenance staff together
prior to the issue of the permit and at the hand-back stage.
Limit the validity of the permit to a single shift, with a maximum period of 24 hours
with revalidation at each shift.
Examination of equipment to be used for each activity to ensure that it is suitable

for its purpose.
Ensure that all personnel are aware of the activities currently taking place. This is
often achieved with the use of plotplans mounted on a wall in the control room
with markers showing the location and type of activity. In addition, a copy of the
permit should be available at the job site.
Permits should be filed for a period of at least three months to allow auditing of
the system.
There should be separate folders for filing permits for completed work and permits
for work that is continuing (even when the permit has expired).
Isolation and de-isolation of equipment, ideally using a Lock Out/Tag Out (LOTO)
system.
The permit system should be regularly audited.

Guidance is available from a number of sources, including:
http://www.ogp.org.uk/pubs/189.pdf
http://www.hse.gov.uk/pubns/priced/hsg250.pdf
Reason
There have been a number of recommendations relating to the permit to work system
and a fundamental review is considered desirable to ensure that safe working
procedures continue to be to a high standard.
As EPCL have an ambitious expansion programme over the next few years, now is
considered to be the ideal time to review the permit system.
25
Examples
A number of issues were identified during the survey:
There is no indication that each activity has some form of safety assessment or
risk review prior to work commencing (however standard risk assessments are
available for some tasks).
Equipment for use for maintenance appeared unsuitable:

o Electrical cabling with taped connections in the PP plant
o Internal combustion engine driving a concrete mixer, possibly in an
electrically classified area, in the PE plant
o A sandblasting skid with a non "Ex" rated motor in the Olefin plant. Whilst
this may be intended for use during plant shutdowns, it is likely that in some
cases it will be used for sandblasting whilst adjacent equipment is in
operation.
No permits were displayed at jobsites.
Permits examined in the control rooms showed that permits were kept open over
weekends with some permits being open for five days.
The "sign-off" date by operations supervisors was often a day or two after the last
day of validity of the permit, suggesting a gap between work being completed and
checks at the jobsite.
It should be noted that two of the four fires reported in 2011 were related to the control
of maintenance.
EPCL Post Survey

Comment 2011
The existing procedure is effective and well established. However, we are reviewing it
for further improvement based on some of the recommendation. The plot plan with
location marking showing activities already exist in control room. (Auditor may have
overlooked.) Most of the suggestions have already been implemented in our system.
Status October
2012
This is COMPLETE, an example is shown below:
26
11-04
Category
Trip Bypass Procedure
Recommendation
Review the current trip bypass procedure and, if considered necessary, revise it to
ensure:
Trips which are bypassed for an extended period receive a higher level of scrutiny
than trips bypassed for a short period of time. This is often achieved by requiring
a higher level of authority to extend a bypass beyond a short period of time.
Where bypasses are required to extend beyond a short period of, typically 24 48
hours, a Management of Change procedure is followed.
The bypass procedure should require some form of risk assessment to identify
any additional safety precautions required whilst the bypass is active. Ensure that
procedure is followed rigorously.
The trip bypass authorization forms should be filed (with separate files for
completed and active forms).
Regular auditing of the forms and bypass register should take place to ensure that
the procedure is being followed as required.
If a trip bypass register, in addition to the forms, is to be used each trip should be
individually "signed off" and "signed back".
It may be appropriate to modify the existing procedure so that multiple trips, on a
single piece of equipment can be bypassed simultaneously when the equipment is out
of service. However, the disabling and, especially, the establishment of each trip
should be noted individually.
A discussion of trip bypass procedures is given in:
http://www.torusinsurance.com/documents/Best%20Practice%20Centre/Safety_Interlo
ck.pdf
Reason
Whilst EPCL currently has a trip bypass procedure as part of the safety manual, this
requires a separate form to be completed for each bypass. This is considered
impractical in situations where multiple trips may be bypassed at the same time. For
example during the decoking of a cracking furnace.
Where procedures are developed but then not used, short cuts and deviations can
occur. It is preferable to have a clear concise, practical procedure which can be used
throughout the site without the need for modification or misuse in some situations.
Examples
During visits to the control rooms no bypass forms were reviewed but each plant had a
trip bypass register which appeared to be correctly completed.
In the Olefins plant, the trip bypass register dates from March 2011. There was no
evidence of any trips which were previously bypassed being "carried forward" to the
new register. There were a number of cases where bypasses had been in place for
weeks. Elsewhere in the register, it was not clear if individual loops had been
established or not as a single signature appeared to have been used to confirm that
several bypasses had been re-established.
EPCL Post Survey

Comment 2011
The present system is well established and most suitable based on our requirement
and type of work being done. However, we are reviewing it further. Some of the
suggestions have already been taken care.
Status October
2012
Trip bypass registers are being prepared for use in the individual unit control rooms but
the implementation of a more advanced trip bypass system has not been investigated.
The situation is UNCHANGED.
27
11-05
Flange Systems
Category
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 and
bolts are to the same material as the flanges and piping).
The value of good bolting practices could be emphasised through training courses,
toolbox talks, etc.
Reason
Poor bolting and flange practices increase the likelihood of flange leaks and the
release of sufficient hydrocarbon material to generate a fire or explosion. This problem
is shown clearly in the schematic below.
A particular concern exists if carbon steel bolts are installed in stainless pipework. In
the event of low temperatures, for example during blowdown, low temperatures could
be generated in pipework. Whist stainless materials might be suitable, there could be
brittle fracture of carbon steel studs.
Examples
A thin steel plate was installed as a blind on a virgin C5 line at offsites liquid pump
house.
Studs which did not fully penetrate the nuts on either side of the flange were
noted in the offsites LPG pump area.
Very limited amounts of short bolting were noted in process areas.
Stainless piping and flanges with carbon steel bolting were noted in the olefin
plant cold section.
EPCL Post Survey

Comment 2011
We have already surveyed short bolting and less bolting. Correction is under
progress. Since some blinds are only for positive isolations, thickness was less for big
diameter pipes. However, all attempts are to be made to install correct rated blinds in
true isolation cases.
CTt Comment
The response is unclear. Where blinds are installed in pressurised systems, they
should always be rated for the same pressure as the piping system.
Status October
2012
No examples of incorrect flanging were noted during the survey. The recommendation
is considered COMPLETE.
11-06
Maintenance of Drains
Category
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 may
occur during heavy rain. If the drains are partially blocked rainwater might flood some
areas of the plant resulting in damage.
The drains are also required to cope with fire water flow and if restricted could result in
a back-up of water spreading out on the plant with burning hydrocarbons on top. The
area exposed to fire could be increased significantly.
The drains are also required to transfer spillages of hydrocarbons to a safe location
and if blocked or restricted could result in a pool of liquid which could result in a fire.
Examples
EPCL Post Survey

Comment 2011
We will enhance the drain cleaning frequency; this is an on-going process.
Status October
2012
In general, drains were clean and the recommendation is COMPLETE.
A flooded drain was noted on the edge of the process area.

Channels to discharge LPG out of the storage area are partially blocked by earth
and vegetation.
28
11-07
Category
Risk Based Inspection
Recommendation
Develop a risk based inspection programme, including recording and analysis systems
in advance of the next plant turnaround.
Reason
Whilst the plant is approx. 17 years old, there was limited inspection activity prior to the
takeover of the site by Indorama. Since then there has been a huge increase in the
amount of inspection activity undertaken. Until now this has concentrated on ensuring
the integrity of the existing assets. However after the next turnaround, there will be
adequate data available to start a Risk Based Inspection (RBI) programme. This will
require trending of wall thickness data to determine corrosion rates and remaining life
of materials.This process would be facilitated if systems for storage and analysis of
data were in place prior to the next turnaround.
Examples
Currently, there is no programme for trending of inspection data.
EPCL Post Survey

Comment 2011
For RBI, as suggested, a system is under development by trending of piping thickness

data 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 focusing
inspection efforts in the areas of greatest loss potential both in terms of frequency and
magnitude.The following references give a general overview of risk based inspection
procedures:http://www.hse.gov.uk/research/crr_htm/2001/crr01363.htmhttp://www.dnv.
com/binaries/13_paper_aem_%20paper_final_tcm4-367866.pdf
Status October
2012
There has been limited progress, possibly due to the departure of the inspection
manager. The recommendation is IN PROGRESS.
11-08
Corrosion Under Insulation
Category
Recommendation
Increase inspection of high hazard areas where Corrosion Under Insulation (CUI)
might be present. In particular inspection should concentrate on areas where the
insulation is damaged.
Reason
Corrosion, if unchecked, will result in thinning and rupture of the pipe and the possible
release of hydrocarbon materials with the subsequent potential for fire or explosion.
Examples
There are numerous places in the process and storage areas where damaged
insulation is present and in some cases vegetation growing. A specific case is the
pipework at the base of the refrigerated ethylene storage tank.
EPCL Post Survey

Comment 2011
Most CUI inspection is done during TAM. We shall enhance scope during TAM 2012
as per hazard. CUI can be minimised by insulation repairs that should be taken up
thoroughly in the whole complex on priority.
CTt Comment
The problem with CUI is the lack of visibility of corrosion as it hidden beneath the
insulation. Where repairs are made to insulation, it is necessary to check and ensure
that there is no CUI before repairing the insulation. Repairs to insulation will not
prevent pipework rupture if corrosion is already present.As a minimum, a register of
suspect locations should be established and inspections made as quickly as practical.
In many cases, CUI inspections can be undertaken outside of a TAM.There are also
techniques, of varying effectiveness, which can be applied to check for CUI without
removal of insulation.The implementation of an RBI programme will assist in identifying
the piping sections which should receive priority.
Status October
2012
Pulsed Eddy Current technology is being used to check for under insulation corrosion.
Note that whilst this will work for many applications, there are some areas where it is
unsuitable.
The recommendation is considered to be IN PROGRESS.
29
Refrigerated
ethylene
tank
pipework
with
corroded
insulation
Vegetation growing in
process piping
11-09
Fireproofing
Category
Recommendation
Review the condition of fire proofing in the process areas and, where appropriate
make repairs.
Reason
Fire proofing provides protection against damage to steelwork from thermal radiation
and direct flame impingement. If the fire proofing is damaged, even in only one area
the protection will be damaged.
Examples
Fireproofing was damaged in a number of locations in the process areas. Most of the
damage noted was on structural steelwork. Fire resistant panels had been attached on
top of steel beams.
EPCL Post Survey

Comment 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 October
2012
A specific response to the recommendation was not obtained but no problems were
noted on site. Pending confirmation from EPCL that the repairs are complete, the
recommendation is considered to be IN PROGRESS.
Damaged fireproofing
in the process area
Damaged
fireproofing
in
the
process
area
09-01
Category
Recommendation
Sampling Procedures
1
Review the current sampling procedures (and their operation in practice) for liquefied
gases and, if possible, revise the procedure to avoid the release of process fluids during
30
the sampling procedure.

If not yet completed, a Job Safety Analysis (JSA) should be undertaken for sampling
activities.
Reason
The current sampling procedures involve the release of process materials to

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

Comment 2009
We will review current procedure and ensure proper implementation to avoid release of
hydrocarbon mixtures during sampling.
Status May 2011
A JSA is reported to be in place and some sampling points go to flare. However there
does not appear to have been a comprehensive review of sampling and development of
methods of working which avoid the release of liquefied gases to atmosphere.
The recommendation is IN PROGRESS.
EPCL Post Survey

Comment 2011
We will do a comprehensive study for sampling and development methods of working.
Status October
2012
Current practice is to purge to flare before sampling where possible rather than to purge
to atmosphere. Some piping modifications will be necessary before all purging to
atmosphere ceases and these will be completed at the next turnaround.
09-02
Fire and Gas Alarm Systems
Category
Recommendation
Review the adequacy of the existing fire and gas panels and make appropriate repairs
and 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 be
low.
Examples
Fault alarms were active on most of the fire alarm panels inspected in buildings and
process areas.
Some of the equipment at the site may be obsolete, for example the site uses
catalytic pelletizer type flammable gas detectors whilst newer, more reliable, infrared
detectors are available.
EPCL Post Survey

Comment 2009
Last year, we changed the Fire & gas alarm system of PE plant. This year, we would do
similar job in PP plant. For other plants, depending on requirement we may change
phase wise. This would increase overall reliability.
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 to
be as a consequence of changes to the power supply to the panel and alarm loops. In
addition, there were fire alarm lights illuminated in some places and, possibly, some
genuine fault alarms.
The recommendation is considered to be In PROGRESS.
EPCL Post Survey

Comment 2011
Being reviewed from time to time.
Status October
2012
No problems were noted in the fire and gas panels during the surveys.
recommendation is considered COMPLETE.
The
31
09-03
Control Room Doors
Category
Recommendation
Install automatic door closers on the external doors in the control room building.
Reason
Large heavy doors, such as those on the control room, can be cumbersome to open
and close manually and there is a temptation to leave them open, particularly in a warm
climate. However the integrity of the control room is compromised when the doors are
left open. In the, unlikely, event of a major explosion there would be casualties within
the control room and damage to control equipment.
Examples
All process control rooms.
EPCL Post Survey

Comment 2009
Matching with the integrity of blast proof arrangement of control room, the main doors
are made quite robust & heavy. Providing door closure may cause inconvenient.
Anyway, we would review it.
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 Survey

Comment 2011
Door closures are already installed. We will establish administrative control to ensure
doors are always closed.
Status October
2012
The situation is UNCHANGED.
09-05
Document Control
Category
Recommendation
Develop a document control procedure to ensure that:

Key documents are "controlled" with the latest versions being accessible to
registered users and older versions destroyed.
Uncontrolled copies can be clearly identified.
Documents are written in an approved style with information such as date, revision
number, etc. clearly displayed.
Reason
Currently EPCL are largely working with documents inherited when the site was under
NNPC operation. Some key documents, such as Process and Instrumentation
Drawings (P&IDs) have been updated and, it is understood that many other documents
are likely to be developed or revised now that the more urgent work of improving the
plants mechanical integrity is completed.
Unless well-developed systems for the control of documents are developed, there is a
danger of different versions of the same document being used by different people.
Examples
Currently the site P&IDs have been updated but the original "as built" drawings are
the ones available for reference in the plant control rooms.
It is intended that many of the drawings, procedures, etc. will be available on the
company Intranet. Unless, appropriate checks are built into the system, it will be
difficult to control downloading, printing and storage of uncontrolled documents.
EPCL Post Survey

Comment 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 9000
standards. This recommendation is IN PROGRESS.
EPCL Post Survey

Comment 2011
We are gearing up for ISO9000, ISO14000 and OHSAS17000 certification.

recommendation will be automatically complied with.
Status October
2012
Whilst there has been some progress, there are still areas for improvement. A new
recommendation, 12-03, on this topic has been made and this recommendation is
WITHDRAWN.
This
32
09-06
Operator Emergency Training
Category
Recommendation
3
1.
2.
3.
Reason
1.
2.
3.
Review the existing emergency shutdown procedures and revise/update where

necessary. Instructions should be written in a simple, easy to read, format.
"Short form" emergency instructions should be prepared as a standalone
document. These could be in the form of checklists so that operators can confirm
that they have completed all the emergency actions required.
Institute an emergency simulation program for process operators so that they are
familiar with required actions in the event of a process upset. The following points
are offered for consideration:
Process upset conditions should be considered in turn (e.g. loss power, loss
cooling water, etc.).
Simulation training should be at the same time each week so that each shift
has the opportunity to practice each specific scenario.
Field operators should place tags on the valves they would operate to ensure
they know the correct location of the equipment.
Panel operators should list the actions they would take.
Field and panel operators actions can be checked and refresher training
provide if necessary.
Whilst the operating instructions reviewed did contain emergency shutdown
procedures, there were sometimes vague and in a difficult to follow format.
Simple one page, step by step, instructions are easier for operators to understand
than complex manuals.
In emergency situations, operators and supervisors are under increased stress and
the potential for mistakes increases. Training will reduce the potential for error.
Examples
Current Emergency procedures examined are based on the original contractors

operating instructions which are, in some cases, limited or out of date.
EPCL Post Survey

Comment 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 Survey

Comment 2011
This is an on-going process and being done from time to time.
Status October
2012
The recommendation is still not fully implemented, it was discussed in detail with the
Olefin plant management and implementation is anticipated in the future.
33
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 of
abnormal behaviour of the transformer and may indicate appropriate action that may be
taken on the equipment before it suffers great damage. The frequency of the testing
being determined by the nature of results obtained, with the interval being reduced
depending upon the rate of rise of gas concentration. Therefore, it is recommended
that the facility follows current industry best practice of sampling and testing transformer
oil every 12-18 months.
Reason
It was indicated that the transformers' oil was sampled and tested during TAM1. This
included Dissolved Gas Analysis (DGA) and dielectric testing. It was reported that
similar testing would be performed during TAM2 and subsequent turnaround.
Status June 2009
EPCL state that:

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

Comment 2011
We do not have any gas in transformer.

months 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 transformer
oil and are indicative of impending failure.
An introduction to DGA can be found at:
http://www.electricity-today.com/et/issue0203/i02_analysis.htm
Status October
2012
EPCL have purchased equipment for use on site. However the results of analysis do
not appear credible and samples are being sent off site for analysis in a specialist
laboratory.
Oil quality checking procedure every six
34
CTC 2006 Recommendations

06-01
Fire Detection/Protection Impairment System
Category
Recommendation
Develop an Impairment programme so that equipment which is out of service or being

used for non-firefighting purposes is recorded and corrective action is taken as quickly
as possible.
Staff and contractors should be made aware of this requirement.
Reason
Considerable effort and expense has gone in to the renovation of the site, including the
fire detection and protection systems and whilst most equipment is in much better
condition than at the start of 2006, there are many systems where repairs are not fully
complete and there may be confusion over the operational status of equipment.
In addition fire water is still being used for cooling and other non-fire related purposes.
Finally, an up to date report with the status of all fire detection and protection systems
would be useful to insurance underwriters at the completion of TAM1 and the start-up
of plants.
Examples
Whilst the use of fire water for process cooling is much improved from the situation
before TAM1, there are still some cases where fire water is used for cooling. In
addition, there is considerable (uncontrolled) use of fire water for purposes, such as
wash down of process areas. Fire hoses used for these purposes are evident in
several parts of the site and the volume of water is such that the one of the main
electrically driven pumps is operating continuously to supply demand.
In addition a number of defects, which have not yet been repaired were noted, where
these exist additional safety precautions will be necessary to ensure that safety of the
facilities are not compromised. These include:
One diesel fire pump is not operational.
Defects to the control system of a second system appear to exist.
The dry powder system protecting the catalyst area in the polypropylene plant is
not fully functional.
The "trouble" alarm on the gas panel in the olefins plant is illuminating.
Status of fire detectors in the office block is uncertain.
This is probably not a complete list.
Status June 2009
EPCL State that:

With the revamp of the fire detection and protection system in PE the system now exist
in all plants.
CTt Comment
Some defects were noticed in many of the plants, this recommendation is considered
to be IN PROGRESS.
Status May 2011
The diesel fire pump and catalyst systems are now reported to be operational. The
other aspects are also covered in 09-02. This recommendation was considered
complete.
For future reference, details of an impairment system are available from Liberty Mutual
via the internet. A copy is attached in Appendix B.
Status October
2012
Parts of the sprinkler system in the Polyethylene plant warehouse were isolated.
These systems were not clearly marked and did not appear to be known to fire
fighters.
In effect there has been no progress on this recommendation and the status is
UNCHANGED.
35
06-03
Under Insulation Corrosion
Category
Recommendation
Increase the speed of the under insulation inspection programme. The programme
should be prioritised so that the most hazardous piping (based temperature, pressure,
contents and corrosion potential) is inspected first.
Reason
The inspection programme has so far only considered a small proportion of the piping
where under insulation could exist. A leak of hydrocarbon material from a corroded
pipe could result in a serious fire or explosion.
Examples
Currently approximately 10% of the pipework has been checked for under insulation.
From visual inspection, there are many places where the external weather protection
over the insulation has become damaged, with the potential for water to seep into the
insulation, possibly causing corrosion.
Status June 2009
EPCL State that:

Under insulation corrosion inspection is being done as a routine and during shutdown
opportunities.
CTt Comment
There is considerable inspection activity related to under insulation corrosion. This

recommendation is considered to be IN PROGRESS.
Status May 2011
This is an on-going process and is IN PROGRESS.
EPCL Post Survey

Comment 2011
Action is initiated.
Status October
2012
The requirements of this recommendation are also covered in recommendation 11-08

and this recommendation is WITHDRAWN.
06-10
Category
Recommendation
Review the management of change procedure to:

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

result in hazardous changes being approved without adequate assessment.
2. The lack of an assessment procedure for staffing changes could result in the
introduction of hazards in situations where staffing levels change, job descriptions
are altered, etc.
Examples
The aspects discussed above are not included in the current Management of Change
Procedure.
Status June 2009
EPCL State that:

MOC system implemented. SOP available on the internet.
CTt Comment
Some aspects of the MOC procedure

recommendation is IN PROGRESS.
Status May 2011
There appears to be NO CHANGE since the 2009 survey.
EPCL Post Survey

Comment 2011
This is a well-established procedure but there is scope for improvement and is being
done.
Status October
2012
This is reported to be COMPLETE.
still
require
improvement
and
this
36
06-11
Emergency Plan
Category
Recommendation
Review the existing Emergency plan to provide a greater level of detail in areas such
as:
1. The provision of an adequately equipped emergency coordination centre in a safe
and accessible location.
2. Review the format of the plan to see if it can be restructured for improved clarity.
3. Prepare fire pre-plans for likely fire situations.
To ensure that the practicality of the plan a full scale or desktop exercise should be
performed.
Reason
1. The current location of the emergency coordination centre is undecided. One

option appears to be the use of the fire station control room. It is generally
considered preferable to use a room without distractions close to the main entrance.
2. The current emergency plan is comprehensive but the information is not always
easily accessible. Key facts are hidden in complex paragraphs and may be
overlooked during an emergency when staff will be in a highly stressful situation.
Greater use of bullet points, flow charts, and shorter paragraphs would assist and
some information aspects could perhaps be transferred to appendices.
3. Currently there are no detailed plans for fire fighting in some of the areas with
significant fire potential. Preplanning will allow a faster response to a fire, resulting
in a lower level of damage. An example is given in Appendix E.
Examples
Site emergency plan.
Status June 2009
EPCL State that:

SOP for emergency procedures existing.
completed and available on the Intranet.
On Site Emergency Management Plan
CTt Comment
Some aspects, such as pre-planning are still not complete. The recommendation is
considered to be IN PROGRESS.
Status May 2011
There has been an element of pre-planning but further progress is possible, including
the provision of thermal radiation modelling to allow position of fire trucks to be fixed
and the nearest fire hydrants identified.
EPCL Post Survey

Comment 2011
Being reviewed from time to time.
Status October
2012
Some preplans have been developed but these are generic and not specific to each
plant area or storage vessel.
37
Recommendations Prior to 2005
No.
03.03
Title
Liquid
Ethylene
Storage
Tank
Summary
Various
repairs to the
ethylene tank.
Status in 2006
June2009 Status
(EPCL Comments)
IN PROGRESS
COMPLETED
Progress
had
been
made in the area but
some work still needs to
be done. Examples are
the rod hanger on one
of the ethylene pipes to
the tank and insulation
around
the
liquid
ethylene pumps.
Note that site visits

indicated that the rod
hanger has still not
been replaced.
May 2011 Status
October 2012
Status
Some repairs to the

ethylene tank remain.
The recommendation
is IN PROGRESS.
A technical review of
the rod hanger has
been undertaken and
the hanger found to
unnecessary.
EPCL Post Survey be
the
Comment 2011 - We However,
are reviewing the analysis might not
have considered the
engineering
fact that the hanger is
company.
supporting
the
bellows (which shows
signs of distortion)
and not a section of
pipe.
It would be
prudent to repeat the
analysis including the
bellows.
The recommendation
is IN PROGRESS
Piping Support with Rod

Hanger Missing the situation
since at least 2003
38
No.
Title
Summary
Status in 2006
03.04
Use of
Cellular
Telephone
s within
the
Process
Plant
Use of mobile
phones within
process plant.
NO CHANGE
Personnel using phones
were noted in several
areas including adjacent
to the DCS panels,
where there is concern
that the mobile phone
signal could interfere
with the DCS.
98.01
Remote
Operated
Isolation
Valves
Install
Remotely
Operated
valves for
process
isolation in
emergency
situations
IN PROGRESS
98.03
Fire-water
Pumps
Stop
unauthorized
use of fire
water.
NO CHANGE
June2009 Status
(EPCL Comments)
Out of 4 additional
ROVs identified for
installation
2
are
already installed and 2
are procured waiting
shutdown
for
installation
May 2011 Status
October 2012
Status
Examples of mobile
phone
use
in
hydrocarbon
areas
were found during
the survey.
It
appears that mobile
phones
are
a
common form of
communication at the
site.
There
is
NO
CHANGE
to
the
previous situation.
EPCL Post Survey
Comment 2011 Theoretically
in
normal running plants
cellular
telephones
do not pose any
hazard.
CTC Comment
There
is
no
consensus over the
hazards posed by
mobile phones but
many
companies
prohibit their use in
electrically classified
areas.
The
situation
is
unchanged
from
2011,
senior
management
were
noted using cellular
phones
The
practice
is
different from most
hydrocarbon facilities
where the use of
mobile phones is
forbidden
and
phones are often not
allowed
in
the
hydrocarbon
facilities.
The
situation
is
UNCHANGED
All 4 of the originally

proposed ROVs are
now
installed
However, there are
still a number of
locations where there
are vessels with large
inventories and no
ROVs installed.
Common criteria are:
5 m3 for LPG
containing
vessels
10 m3 for liquid
hydrocarbons
The recommendation
is IN PROGRESS.
EPCL Post Survey
Comment 2011 Already installed in
two places, further
under review
There
are
still
locations
where
ROVs should be
installed and, it would
useful to establish a
list of locations so
that valves can be
installed
at
the
forthcoming TAM in
The
situation
is
UNCHANGED.2013.
The level of fire water

use is such that one
of the main electric
pumps is running
continuously.
There is a project to
install larger jockey
pumps.
The recommendation
is IN PROGRESS.
EPCL Post Survey
Comment 2011 - We
are planning to install
a bigger jockey pump
to take care of
uncontrolled leakage.
The
new
larger
jockey pump has
been installed but is
not
yet
fully
commissioned.
Hence
the
main
electric pump is still
operating.
The recommendation
IS IN PROGRESS.
39
No.
Title
96.13
Halon
System
Status
Summary
Replace halon
with FM 200
Status in 2006
NO CHANGE
June2009 Status
(EPCL Comments)
Preliminary work and
technical discussion is
in progress. Would be
implemented in phased
manner from 2010.
May 2011 Status
A programme for Changeout of the

replacement of the halon systems is
Halon systems is underway but not
underway.
complete.
The
The recommendation recommendation is
IN PROGRESS.
is IN PROGRESS.
EPCL Post Survey
Comment 2011 - Job
is in progress
October 2012
Status
40
4. Exposure to Perils
4.1. Property
4.1.1. Fire and Explosion
Fire and explosion risks are inherent in hydrocarbon facilities. The potential size of a loss
will be determined by the inventories of hydrocarbon materials, spacing and fire protection
facilities. The likelihood of a loss is related to operating and other procedures. These are
discussed in detail in the main body of the report.
4.1.2. Surrounding Exposures
The nearest large industrial site is NNPCs Port Harcourt refinery (approximately 6 km
away), there are also some oil production facilities (approximately 5 km away). There are no
significant industrial activities around the EPCL site and exposure is considered low.
The Natural Gas Liquids (NGL) pipeline feeding the site terminates at a custody transfer point
in a Nigerian Agip Operating Company (NAOG) terminal at the North West corner of the site.
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 exposed
to small fires from shanty dwellings, car fires, etc.
41
4.1.3. Subsidence and Collapse

No serious signs of subsidence or collapse were noted during site visits, although there was
very minor damage to some pipe support footings, reportedly as a result of erosion from
condensate 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 0
equivalent
to
Modified-Mercalli V
and below.
4.1.5. Tsunami
The Munich Re "Globe of Natural Hazards" does not consider the area to be exposed to
tsunami. In any event the plant is set well back from the coast.
4.1.6. Volcano
Approximately 400 km to
the East of Port Harcourt
is an area of volcanic
activity that stretches
south west to northeast in
a line from the Gulf of
Guinea to Cameroon.
The Munich Re "Globe of
Natural Hazards" does not
consider the area around
the site to be exposed to
active volcanoes.
42
4.1.7. Lightning
The Munich Re "Globe of
Natural Hazards" shows
the area as subject to 20 40 lightning strikes per
km2 per year.
There
have
been
numerous lightning strikes
at the plant. At least two
have resulted in minor
fires.
Actions taken to minimise
the impact of lightning
includes ground resistivity
surveys.
4.1.8. Wind and Storm
Whilst the region is prone to electrical storms, it is not generally subject to significant
windstorm activity.
The Munich Re
"Globe of Natural
hazards"
considers
the
area to have a
Zone 1 exposure
to hailstones, the
lowest of six
ratings.
43
The Munich Re
"Globe of Natural
Hazards"
considers
the
area to have a
Zone 2 exposure
to tornado, the
second lowest of
four rankings.
4.1.9. Flood
There is no history of flooding either from rainfall or sea water inundation.
4.1.10. Vehicle Impact
Vehicles are free to travel on roads around the site and therefore vehicle impact is possible
4.1.11. Vessel Impact
There is no jetty associated with the site and therefore marine impact is not possible.
4.1.12. Aircraft Impact
Nearby airports are shown below:
44
The Port Harcourt international airport handles both fixed wing and helicopter flights and is
located approximately 25 km from the site. The Nigerian Air Force (NAF) airbase is approx.
5 km from the site. This has a mixture of military flights plus some fixed wing and helicopter
flights. Flight paths are reported to avoid the EPCL site and no aircraft were noted overflying
during the survey.
4.1.13. Riot Strike 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, including
theft, vandalism and sabotage have occurred. These have primarily affected the upstream
oil industry but the downstream sector has also been affected.
There has been previous resentment by the local community in the past which culminated in
the kidnapping of a number of Indorama employees and dependents (including women and
children) some years ago but relationships with the local communities are now reported to
45
be very good. All Indoramas ex-pat staff and their families are now housed within the site
boundary.
4.1.14. Terrorism and Sabotage
The 2012 Aon "Terrorism and Political Violence Map" rates Nigeria as Severe Threat, the
highest 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 have
been 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 resold
and 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 Fired

Heaters
The major fired heaters are the cracking

furnaces in the ethylene plant plus boilers.
The major risk

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

equipment items, the key items being:
HP
compressors,
particularly
associated with the ethylene plant.
Extruders associated with the two
polymer plants.
Gas turbines.
There is a wide range of incidents which

can lead to damage of rotating
equipment leading to varying levels of
damage. Under most circumstances,
damage will be limited to the rotating
elements of the machine but, in extreme
cases, total destruction can occur.
Transformers
There are a number of large transformers

on the site. Many transformers have fire
walls between adjacent units but fixed fire
protection is not installed.
A fire involving a transformer is unlikely

to spread to adjacent equipment,
however, in the unlikely event of a
transformer explosion, fire walls could fail
resulting in additional damage to nearby
units.
Others
Catalysts
In some situations, catalyst life can be

reduced or destroyed as a result of
process upsets or damage caused by fire
or other perils.
4.3. Construction
Major Construction projects are planned over the coming years. A new ammonia - urea
complex is currently scheduled to start construction at the beginning of 2013 and an
expansion to the ethylene cracker towards the end of 2013.
These projects, particularly the latter, are likely to result in significant cross exposures.
46
Anticipated hazards include:

Exposure
Interface with
Existing 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 of
construction 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 by
diesel fuel in the gas turbines.
There are problems with the limitation of feedstock from Agip and this sometimes leads to
the reduction in output from the units. This was the case at the time of the survey, with
production being limited due to flooding problems at the Agip site.
47
5. Loss Estimates
5.1. Definitions and Loss Scenarios
There are numerous definitions for defining levels of damage. Probable, Maximum Loss
(PML), Estimated Maximum Loss (EML), Maximum Amount Subject (MAS) are amongst the
terms 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 was
identified. 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 events
would 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 process
safety systems and fixed fire protection systems. Such events would be natural perils,
such as a major earthquake or extremely rare events such as aircraft impact.
In general, only the EML event is calculated, as this is of the greatest significance to
underwriters.
5.2. Property Damage

The following replacement values have recently been estimated by AVC and are used to
calculate the size of loss below:
Unit
USD
Ethylene Cracker
284,800,000
Polyethylene
181,700,000
Butene-1
10,500,000
Polypropylene
80,100,000
Polyethylene Bagging
24,200,000
10,500,000
Storage Area (including pipeline to

Refinery)
57,600,000
Power Station
109,300,000
Cooling Water
23,100,000
Demineralised Water
33,400,000
Air and Nitrogen
22,900,000
Flare Area
9,400,000
48
Unit
USD
Effluent Treatment (Including

Incinerator)
16,800,000
Administration and General
Excluded
Refinery Tank Farm
3,700,000
Total
868,000,000
The largest potential loss at the site is considered to be a vapour cloud explosion (VCE), the
largest inventories of liquefied gas in the process area are:
Polyethylene
Plant
Olefin Plant
C3
Splitter
C3
Splitter
Reboiler
C3
Splitter
Reflux
Drum
D-32
C-8A/B
E-76
D-35
Ethylene/
Ethane
Ethylene/
Ethane
Propylene/
Propane
Propylene/
Propane
Propylene/
Propane
Cyclohexane/Et
hylene
24.8
27.8
23.8
19.3
18.1
18.1
110-140
-27
-22/2
-1
23
48
41
41
310
Diameter M
6.0
4.6
2.914
4.1
4.65
2.49
3.4
Length T/T m
17.5
61.65
12
16.2
104.4
4.88
13.45
Percent Full
50%
90%
50%
90%
65%
247
144
72
107
180
22
122
151,905
79,200
39,600
60,956
104,400
12,540
75,030
110,000
Flash Fraction
0.12
0.53
0.85
1.00
0.64
0.61
0.57
1.00
Mass of Cloud
18,229
41,976
33,660
60956
66,816
7,649
42,767
55,000
Propylene
Ethane
Ethane
Ethylene
Propane
Propane
Propylene
Cyclohexane
Propylene
Refrigeration
Drum
C2
Splitter
Column
C2
Splitter
Reboiler
C2
Splitter
Reflux
Drum
Tag No.
D-44
C-6
E-59
Contents
Propylene
Ethylene/
Ethane
Pressure
Kg/cm2
1.3
Temperature oC
Volume M
Mass Kg
Modelled as:
Cyclohexane
Circuit
Note 1: 50% of cyclohexane assumed released (some parts of the circuit are at lower than maximum
temperatures and pressures)
Using the Swiss Re ExTool method with an explosion efficiency of 6% for unsaturated
hydrocarbons and 4% for saturated hydrocarbons, the worst case scenario is a release of
ethylene from the C2 Splitter Reflux Drum (The largest release of olefins at the site) resulting
in the following damage levels.
80% Damage
40% Damage
5% Damage
Total
Overpressure radius, M
125
283
448
Static Loss, USD Million
29.46
238.68
4.89
273.03
Drift Loss USD, Million
76.07
231.23
3.30
310.60
49
After making the following allowances, the loss estimates are given below:
Fire following the initial explosion 10%
Damage outside the plot areas 10%
Debris removal 10 %
Fire Fighting 1%
Inflation 9% (based on 3 years at 3% per annum the loss occurring on the last day of
the policy year, plus a two year rebuilding period).
The loss is estimated at approximately: USD 435 million.

Note that underwriters exposure might be reduced as some of the factors included in the
calculation (e.g. debris removal and fire fighting expenses) have been excluded from the
valuation.
Damage contours are shown below:
Key
1
Polyethylene Warehouse
Polyethylene Plant
Butene-1
Olefins
Cracking Furnaces
Compressed Air/Air Separation
Polypropylene Warehouse
Polypropylene Plant
Power Plant
10
Water Treatment and Cooling

Water
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 indemnity
period.
A repair time of around 24 months would normally be expected in this situation and the loss
is estimated to be USD 600 million but underwriters exposure would be limited to the USD
300 million insured value.
50
5.4. Machinery Breakdown

The largest machine at the site is understood to be the Olefin Plant Cracked Gas
Compressor. The replacement value for this unit was not obtained but by comparison with
similar 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 of
approximately 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 the
rotor and rebuild the machine)
15.4
Additional Costs
Inflation for 21 months at 5% per annum (incident on last day of policy year and
9 month replacement)
Total
3.6
19.0
Destruction of Machine
(100% loss of machine value and 20% to remove and replace the machine)
26.4
Additional Costs
Inflation for 30 months (incident on last day of policy year and 18 month
replacement)
Total
6.3
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, the
following would apply:
1.
Destruction of the rotating elements of the machine.

Assuming spare parts are available, repairs and a resumption of production
should be possible within a two-month period. The loss would therefore be:
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 underwriters exposure to USD 300
million.
51
5.6. Summary of Loss Estimates

Scenario
Property
Damage
(USD
Million)
Business
Interruption
(USD
Million)
Combined
(USD Millions)
Property Damage
Vapour cloud explosion in the olefin

plant following a release from the C2
splitter reflux drum
435
600
1,035
Machinery
Breakdown
Damage to the rotating elements of

the
olefin
plant
cracked
gas
compressor
19.0
50.0
69.0
Complete destruction of the olefin

plant 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 indemnity
period) for business interruption losses.
52
6. Description of Installation
6.1. Production Facilities
EPCL operates a petrochemical complex producing ethylene and propylene for the
manufacture of polyethylene, polypropylene and butene1. Raw material is an ethane rich
Natural Gas Liquids (NGL) feed from the Obiafu-Obrikom Natural Gas Liquids separation
facilities operated by Agip (as a NNPC Joint Venture). There are currently feedstock
problems due to flooding at the AGIP facilities which currently limit production in the olefins
unit 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 NNPCs Port Harcourt Refinery, can be imported for use in the polypropylene plant.
However the Port Harcourt Refinery FCC unit is often not operational and propylene is
seldom supplied. Simple unloading facilities have been installed to unload Propylene Rich
Feed (PRF) from NNPCs Warri refinery but, again, this is not done on a regular basis. One
of the cracking furnaces can operate on Virgin C5 feedstock.
Pyrolysis gasoline, a by-product of the olefins plant, can be exported by pipeline to the
refinery.
A simple block diagram is given below:
53
6.1.1. Process Units

Brief details of the production units are given in the table below.
Designation
Olefins Plant
Polypropylene
(PP)
Polyethylene
(PE)
Capacity
Tonnes/Year
300.000
80,000
270,000
Licensor
Contractor
Year
Comments
Kellogg
"Millisecond"
technology
Chiyoda
Corporation
1995
Four of the six cracking furnaces

have been retubed using Kellogg
Brown and Root (KBR) SCORE
The plant has
technology.
reached production capacities of
305 310,000 tonnes per year
for short periods but is now
operating at approx. 55,000
tonnes per year.
Montel (ex
Himont)Spheripol
technology
Technimont
SpA and
Japanese Gas
Corporation
(JGC)
1995
Currently
there
is
no
polypropylene supply from the
Port Harcourt refinery and the
unit runs on propylene provided
The
from the olefin unit.
processing of a VC5 stream and
the import of PRF (Propylene
Rich Feed) from Warri has
increased the availability of
feedstock.
Due to feedstock limitations the
plant previously ran in campaign
mode but is now operating at 70
- 80% of capacity.
This
represents a safer mode of
operation than the frequent startups and shut downs associated
with campaign mode.
The plant has run at up to 50%
above design. Throughputs will
vary with grade of polymer being
produced.
Total production for 2012 is
expected to be 58 60,000
tonnes. Run times have been
up to 98 days.
There are 2 extruders each
capable of 100% of production.
One unit is original and
scheduled for replacement, the
other is a new unit.
Nova (Du-Pont)
Sclairtech
technology
Kobe Steel
1995
This is a medium pressure unit,

operating at approx. 145 bar g.
Twin extruders are
270oC.
installed
The
plant
has
been
debottlenecked,
which
has
increased the capacity to
302,000 tonnes/year. The plant
is operating at 70 - 80% of
capacity but has run at
throughputs up to 15% above
original design capacity.
Throughput will vary with the
grade
of
polymer
being
produced.
There are 2 extruders, each
sized for approximately 75% of
capacity.
One unit is original and
scheduled for replacement, the
other is a new unit.
54
Designation
Butene-1
Capacity
Tonnes/Year
22,000
Licensor
Institut
Francais du
Petrole (IFP)
Alphabutol
technology
Contractor
Year
Kobe Steel
1995
Utilities and
Offsites
Chiyoda
Corporation
1995
Infrastructure
Spie
Batignolles
1995
Comments
The plant is operating at 70 80% of capacity.
Olefin plant cracking furnaces
Polypropylene
system
plant
reactor
55
6.1.2. New Projects

EPCL are planning a series of new projects at the site. The first is likely to be a new
ammonia urea plant with construction expected to start in the first quarter of 2013 and with a
36 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 the
addition 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 existing
facilities, 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 design
stage 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 comprehensive
consequence 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 electrical
equipment.
Simple procedures such as good
housekeeping and control of smoking can reduce the
hazard 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 large
storage tanks. Large fires involving stock tanks give
rise to high levels of thermal radiation and may
spread 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 of
thermal radiation.
Explosion:
Most explosions are relatively small and occur as a

result of ignition of small amounts of flammable gases
or liquids in a confined space. However sometimes
more serious explosions can occur.
56
Vapour Cloud Explosion (VCE):
VCEs are amongst the most destructive events that

can occur in the oil and petrochemical industries.
They occur following the release of a cloud of
flammable gas which ignites.
They are most
destructive in areas of congestion such as process
areas.
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 the
contents. When the vessel ruptures, the contents, if
they are flammable, will ignite generating high but
short lived levels of thermal radiation and limited
overpressure.
Mercury:
Mercury in very low concentrations is sometimes

found in gas fields. The mercury may concentrate in
processing equipment and may cause damage. Of
particular concern are aluminium vessels and heat
exchangers where rapid failure may occur.
Tests for mercury are reported to have been
undertaken and no traces found at the parts per billion
(pbb) level.
Pressure Vessel Rupture:
In some situations a vessel can rupture either due to

excessive internal pressure or a defect in the vessel,
for example due to corrosion. The consequences are
likely 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 from
ammonia 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 if
cooling water failure occurs (which will prevent the
removal 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" are
necessary in such situations. Additionally, physical
precautions, such as blast walls, may also be
required.
Pyrophoric Materials:
Some materials, particularly polymer catalysts, are

flammable on exposure to air and may ignite.
57
"Rollover":
This occurs in refrigerated storage tanks when a layer

of cold, heavier, liquid exists on top of a warmer less
dense liquid. The two layers can suddenly "rollover"
releasing large quantities of vapour which may
exceed the capacity of the tanks pressure protection
system. The only refrigerated tank at the site is for
ethylene storage and the tank is designed to minimise
the potential for rollover.
Hot Oil Systems:
The polyethylene plant has hot oil as a heat transfer

medium to limit the number of direct fired heaters or
as an alternative to boilers. Hot oil is often flammable
and particular problems can occur in the fired heaters
of hot oil systems.
Fired Heaters:
Boilers and fired heaters often provide the ignition

source for a leak of flammable gas.
Rotating Machinery:
Many plants have large items of rotating machinery

operating at high speed. Failures in ancillary systems
such as lube oil or unexpected operating conditions or
manufacturing defects can result in mechanical
failures. These generally result in damage to the
rotating elements but in severe cases can result in
total destruction.
Poly Chlorinated Bi Phenols

(PCBs)
There are no PCBs on site.
Asbestos
With the exception of some sheeting for buildings,

there is no asbestos on site.
Radioactive sources
Radioactive level measurement instruments are in

use in the polymer plants.
Weld inspection using radioactive sources, generally
owned and controlled by the inspection contractor.
There is also a radioactive source in the alloy
analyser at the site.
Road Collision
There are frequent road movements around the site.

Whilst vehicle access to the process units is
controlled, collisions with piperacks or road side
equipment may occur.
58
6.1.4. Layout
Brief details of the layout are given in the table below:
General
Details
Comments
The existing process units are located to

the south of the site.
There is plenty of space for future

expansion and the new accommodation
facilities constructed at the site are
remote from operational and storage
areas.
The Natural Gas Liquids (NGL) pipeline

feeding the site terminates at a custody
transfer point in a Nigerian Agip Operating
Company (NAOG) terminal at the plant
north west corner of the site.
The process and utilities are arranged in 2
rows west to east in the following order:
Row 1 (northerly row)
Polypropylene warehouse.
Polypropylene production.
Power plant.
Cooling Water Systems and Water
Treatment.
Row 2 (southerly row).
Polyethylene warehouse.
Polyethylene production.
Olefin Unit.
Vacant plot.
Air separation and compressed air
utilities.
These facilities are on individual plots
approximately 150m by 250m, with
separation by road, approximately 12 m
wide.
Storage facilities are located to the east of
the site.
Much of the area is open, particularly

around the main administration building.
This will limit the hazard faced by
employees in the building in the event of
a major explosion. Spacing between the
various process, utility and storage
facilities is also good, limiting the
potential for domino effects from one
area affecting adjacent areas. This is, in
part, due to anticipated future expansion
at the site, which has not so far taken
place.
Spacing within the process areas is

congested in some locations.
This could limit access for maintenance

and inhibit firefighting.
The new ammonia and urea plants are

being constructed to the north of Row 1
and the HDPE unit to the south of row 2.
The flare-stacks and burn pits are located
to the East of the currently unoccupied
areas, with adequate sterile areas
defined.
Process
areas
are
on
concrete
foundations
surrounded
by
areas
backfilled with stone.
Piperacks
In some locations damage to the

concrete pads supporting minor items of
structural steelwork was noted.
The level of fireproofing on piperacks is

variable between process units.
Generally pumps are not located under or
partially under piperacks.
This will greatly minimise the potential for

the fin fans to affect the extent of the fire.
59
Electrical Cabling
Details
Comments
Within the polyethylene plant, fin fan

coolers were not fireproofed to the full
load bearing height.
The air flow from the fin fans will

exacerbate flames from a pool fire. The
provision of fireproofing almost to the top
of the fin fan cooler will minimise the
extent of damage caused by a pool fire
under the fin fan.
Within the olefin plant, drainage points are

underneath the main piperacks.
If the ground were sloped towards these

drains, spills of burning liquid would run
under the pipes and cabling, potentially
causing significant damage.
Cable routing in the plants is partially

below ground and partially above ground
at the lowest piperack level.
This provides a lower level of protection

than cabling run underground.
In a number of locations electrical or

instrument cabling runs along the piperack
at the lowest level.
Cabling would be exposed to a fire under

the piperack. A serious fire could result
in lengthy re-cabling times, with resultant
loss of production.
Piperack
with
above
ground electrical cabling
60
Details
Compressor Houses
Comments
Within the olefins plant, there are two

separate compressor houses. Both
refrigeration compressors are located
within one building with a separate
structure for the cracked gas compressor.
The main compressor houses are roofed
and walled around three sides at the
upper level. The remaining side is left
open to allow access for maintenance.
The structures are open on all 4 sides at
ground level.
Within the olefin plant, the cracked gas
and refrigeration compressors are in
separate structures.
This will allow natural ventilation and

prevent the build-up of high levels of gas
in the event of a release.
Lube/seal systems are located to the side

of the compressor, close to the plant.
The close location of the lube/seal

system to the compressor could result in
damage in the event of a lube seal fire.
All of the main compressors have
independent lube/seal oil systems.
Olefin
plant
process
compressor house
Fired Heaters
The main fired heaters are the cracking

furnaces and boilers are located at the
Southern end of the olefin unit.
The location of all the fired heaters in

one location minimises the likelihood that
a gas leak will find a source of ignition.
A plotplan is shown in Appendix F.

61
6.2. Control and Process Safety Systems

6.2.1. Basis
Brief details of the control system are given below:
Details
Comments
Configuration
On the olefins plant the trip systems are

integrated into the DCS. The polymer
plants have independent ESD systems.
Fully independent ESD systems are

considered preferable to integration of
the trip functions within the DCS.
No SIL analysis has been undertaken in
any of the plants by EPCL.
Type
Yokagawa
Centum
3000
DCS
(Distributed Control Systems) are installed
in all units.
The original DCS systems

upgraded in the 2010 TAM.
Neither the existing or new plants have

alarm management functions.
A
number
of
companies
have
experienced problems, with 1 "alarm
flood", during a major incident . This
results in literally hundreds of alarms
being activated within a very short space
of time. When this happens, the sheer
volume of alarms makes it difficult for
operators to follow the exact sequence of
events. Alarm management systems
assist by filtering out the less important
alarms.
were
6.2.2. Control Room Design

Brief details are given below:
Details
Location
Each of the process units has an

independent control room. In addition
there are control rooms for the power
station and the storage area.
Construction
Process control rooms are blast resistant

structures but appear unpressurised.
Whilst automatic door closers were
originally fitted, these have, in some
cases, been removed or are ineffective,
as in the polyethylene plant. Therefore
doors may be left open, defeating the
blast resistance. Some control rooms are
located close to the process facilities.
Smoke Detection
The control rooms have fire detection

systems.
Fire Protection
The control rooms have fixed fire

protection systems covering the control
system and adjacent instrument rack
rooms.
Comments
All the process control rooms had the

doors in the open position during the
survey which would negate the blast
resistance of the structure.
In some cases doors between the control

and rack rooms are left open which will
prevent the gaseous systems working
effectively. This is believed to be due to
problems with the air conditioning system
and once repairs are made doors will be
maintained in the closed position.
http://www.hse.gov.uk/pubns/chis6.pdf
62
6.2.3. Emergency Shutdown Systems

Type
Details
Comments
The olefins plan has the trip systems

integrated into the DCS. The polymer
plants have independent ESD systems.
Fully independent ESD systems are

considered preferable to integration of
the trip functions within the DCS.
No SIL analysis has been undertaken in
any of the plants by EPCL.
The ESD systems are hard-wired systems

and are not dependent upon computer
software for operation. In some cases,
these are two out of three (2-O-O-3)
voting systems.
The
polymerisation
reactions
are
exothermic. Both have shutdown systems
and the PP plant has a catalyst kill
system, which injects CO into the reactors
to kill the reaction immediately stopping
reaction heat generation.
This system worked successfully during

the power failure earlier in 2011.
6.2.4. Remote Isolation, Depressurisation 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 to
atmosphere 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 and
C3 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 not
fireproofed. 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
Configuration:
Details
Comments
With some exceptions single pressure

relief valves have been installed on
process duties. On a few duties, pressure
relief valves are duplicated.
It is difficult to test relief valves when the

plant is operating when there are only
single valves.
Duplicated relief valves are installed on

the spheres, complete with Castell key
interlocks to ensure that a relief line is
always open.
This will allow a valve to be removed for

testing and inspection whilst the plant is
in operation without the necessity of
either taking the unit out of service or
waiting for a shutdown.
The use of car seals appears to be
universally applied to pressure relief
systems at the site.
Some, at least, of the Castell key

systems are not functioning and have
been replaced by a car seal system.
http://www.castell.com/en/
63
6.2.6. Combustion Safeguards

Boilers, furnaces, and direct-fired heaters have fuel gas management systems.
Fuel gas isolation consists of a double block and bleed system.
6.2.7. Shaft Sealing
Many 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 given
below:
Product
From/To
Length
Comments
Natural Gas Liquids

(NGLs)
Obaifu-Obrikom
gas separation
plant.
85 km
The NGL and fuel gas line follow a

common routing.
Fuel Gas
Obaifu-Obrikom
gas separation
plant.
85 km
The NGL and fuel gas line follow a

common routing.
Fuel gas from this line would be required
for start-up but once continuous
operation is underway, fuel gas for the
site can be taken from the cracking
furnace overheads.
Propylene Rich
Feed
Port Harcourt
Refinery.
6 km
Currently out of use until the Port

Harcourt refinery FCC is returned to
service.
Virgin C5+
Port Harcourt
Refinery
6 km
Cracked C5+
Port Harcourt
Refinery
6 km
6.4. Storage Facilities

The site contains atmospheric, pressurised and refrigerated storage.
64
6.4.1. Atmospheric Storage

Brief details of atmospheric storage are given in the table below:
No.
Installed
Stored Material
Capacity (m )
Type of Roof
Virgin C5+,
4,630
Cone
Cracked C5+,
1,671
Floating
Cyclohexane
2,000
Cone
Ocene-1
2,000
Cone
Gas Oil
2,050
Cone
Atmospheric
storage area
Further details are given below:

Details
Diking
The tanks are grouped within one main

bund with approximately a tank diameter
between the tanks. The two floating roof
tanks are separated by a common wall.
Comments
65
Instrumentation
Details
Comments
It is understood that the tanks originally

had independent high level alarms.
This should prevent overfilling, if the level

gauging system failed.
This differs from information obtained
from previous surveys which stated that
there were no independent alarms.
However, it is likely that level alarms
systems were not well maintained whilst
NNPC operated the plant.
All the tanks that have been overhauled

have had the level gauging and alarm
systems renovated. Where possible, this
has involved refurbishing the original
servo type, level gauging system and float
switches.
This should avoid accidental overfilling.
In some cases radar type level gauging

has been installed.
Radar type level gauging is considered

very reliable and generally considered
not to require an independent level
alarms.
Fire Protection
All the tanks are fitted with semi-fixed

foam systems and water deluge.
Drains
Roof drains on the floating roof tanks are

normally left open. The drain lines are
checked every shift.
This will avoid a build-up of rainwater on

the tank roof which could cause the roof
to sink. However any leakage from the
roof drain line could lead to the discharge
of the tank contents into the diked area.
The dike drains are also left open in the

rainy period.
This will avoid situations where almost

empty tanks will float if there is a serious
build-up of rain water in the dike.
However, it does raise the possibility that
any spillage of hydrocarbons will not be
contained, perhaps leading to running
hydrocarbon fires along the drains
system to the effluent treatment plant.
Such fires could lead to ignition of nearby
vegetation, this has happened in other
locations.
The drains from the atmospheric storage

area go either to the storm water drains or
the Effluent Treatment Plant (ETP).
During the rainy season the route to a
dedicated storage basin in the EDP is
normally open.
6.4.2. Pressurised Storage

Brief details of pressurised storage are given in the table below:
No.
Installed
Stored Material
Capacity
3
(m )
Comments
o
NGL
3,809
These tanks operate at -5 C and are

thermally insulated.
VC5
2,760
These were previously propylene rich

tanks similar to those described below.
o
They were converted to operate at -5 C
and have been thermally insulated.
66
No.
Installed
Capacity
3
(m )
Stored Material
Propylene rich feed
2,760
Butene (Intermediate Product).
Purified Propylene.
Comments
The propylene rich feed was originally
intended to be supplied from the NNPC
Port Harcourt refinery. More recently,
there have been some tanker imports
from NNPCs Warri refinery. Supply from
both sources is no longer available.
One of these tanks has
been converted
o
to NGL operation at-5 C and insulated.
905
2,239
Part of sphere storage

area
Further details are given below:

Details
Construction
Comments
The spheres are of conventional

construction. a number are insulated for
storage of NGL.
All pipe flanges are located outside the
shadow of the sphere.
Minimising the number of flanges,

valves, etc. will limit the potential for a
leak under the vessel and the potential
for a BLEVE.
67
Details
Diking
Comments
The tanks are located in sloped concrete

dikes. piping penetrations through the
dikes are sealed.
The spheres have drainage channels
leading away from the sphere area.
Pumps
Pumps are located remotely from the

spheres.
Instrumentation
It is understood that the spheres originally

had independent high level alarms.
This should prevent overfilling, if the

level gauging system failed.
As spheres have been taken out of

service for inspection, the original servo
type level indicators plus float switched
have been repaired or radar type level
indication installed.
This should avoid accidental overfilling.

Radar type level gauging is considered
very reliable and generally considered
not to require an independent level
alarm.
Gas detection is installed in some areas.

Pressure Relief
Duplicated relief valves are installed on

the spheres.
Some poorly installed supports

pressure relief systems were noted.
These originally included Castell key

interlocks to ensure that one relief line is
always open. However some of these
at least are non-functional and have
been replaced with a plastic car seal
system.
for
68
Details
Comments
Support for sphere PSV systems,

this is wedged in position with no
fixings.
Motor Operated
Valves
ROVs, sample points etc. are located on

the outside of the dike wall. Penetrations
through the dike wall are generally well
sealed 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.
69
6.4.3. Refrigerated Storage

Ethylene is stored in a 12,630m3 double skinned tank constructed by Entrepose of France to
API 620.
Construction
Details
Comments
Double wall tank with a perlite filled

annulus, constructed to API 620.
There is a nitrogen purge through the
annulus.
The fill and empty lines for the tank
contain bellows which appear to be
slightly distorted. A support for one of the
pipes appears to be missing.
To minimize the potential for rollover, the
tank contents are continually circulated
and sprayed into the top of the tank.
There is reported to be some leakage of

ethylene through the inner skin of the
tank.
The tank annulus is purged with nitrogen.

Previous surveys have noted a missing
rod hanger on one of the main ethylene
tank lines.
In response to previous
recommendations,
EPCL
have
undertaken an engineering study which
has determined that the rod hanger is not
necessary.
It is not clear if the analysis assumed that

the piping is rigid, as opposed to a
bellows, which is distorted. It would be
prudent to repeat the analysis to check if
the lack of the rod hanger s still adequate
in the present of a bellows rather than
rigid pipe.
Piping Support with Rod

Hanger Missing
70
Details
Comments
The tank is located in a sloped concrete

wall dike, with drains leading to an
impounding basin.
The mastic used to seal the expansion

gaps in the dikes has largely perished
and, in its current condition, the dike may
leak.
Within the dike, there is a channel leading

to a small impounding basin with a foam
system.
The foam system will minimise

evaporation of any ethylene spillage.
The entire diked area is overgrown with

vegetation and requires clearance. This
particularly applies to the impounding
basin, which contains a level of water and
several medium sized trees.
Water could act as a source of heat to

allow rapid vaporization of liquid
ethylene.
Ethylene
tank
pipeline
showing
distorted bellows
Diking
71
Details
Comments
Ethylene
impounding basin
Pumps
Pumps are located remotely from the

storage tank.
Instrumentation
The refrigerated tank has 2 independent

level gauging systems. One is a float type
system; the other is based on a differential
pressure system.

This should prevent overfilling, if the
level gauging system failed. The use of
different measuring techniques will
minimise the potential for common mode
failures.
A single Boil Off Gas (BOG) compressor

returns vaporised ethylene gas to the
olefin unit for re-liquefaction. When the
ethylene plant is shut down the vaporised
gas is vented to the flare.
An unusual feature of the tank is the fact

that the flare vent control valve fails
closed and in the event of a power failure
or other interruption to the instrument air
supply an operator needs to climb the
tank and manually open the bypass.
Fire Protection
The tank itself is fitted with a water deluge

system around its circumference.
Medium expansion foam and water
deluge systems are installed to cover a
small impounding basin within the diked
area.
From a visual inspection, this equipment

appeared to be in poor condition and
should be checked.
72
6.4.4. Warehousing
The main products from the site are solids, stored in separate warehouses:
Polypropylene - 19,000m2 warehouse
Polyethylene - 42,000m2 warehouse.
Both warehouses are protected with sprinkler systems.

section were isolated.
Some sections of the sprinkler
Layout of the warehouses is good with clear access around the bagging areas and the fork
lift 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 is
limited.
Restricted access to
fire fighting equipment
in the polyethylene
warehouse
6.5. Utilities
The site is designed to be self-sufficient in utilities. Further details are given in the sections
below.
73
6.5.1. Water
Brief details of the water systems are given in the table below:
Details
Comments
Sources
There are 6 boreholes of which 3 are

normally
in use producing approximately
3
300m /hour.
There were originally 8 boreholes but 2

are outside the site boundary and no
longer used.
Storage
2 tanks are installed, each of 55,000m

capacity.
These tanks also provide the fire water

supply.
Treatment
Water treatment consists of 3 decarbonators for carbon dioxide degasification and six sand filters to produce
filtered cooling water.
There is also a demineralisation unit to
remove sediment and ferric ions, plus 2
activated carbon filters for potable water.
Cooling Water:
A single cooling water system covering all

the process units is installed.
Raw Water:
A vent is installed in the cooling water

return line. This is located on the return
line itself rather than on the individual
pipes to each cell.
Vents are often installed on the return

lines of cooling water systems to avoid
the entry of flammable gases (from heat
exchanger leaks) from entering the
cooling tower where they might ignite.
The efficiency of the arrangement
installed at the site is not clear. In the
case of significant leaks, it may allow gas
to be swept past the vent into the cooling
towers.
A gas detection system is installed.
This should detect any hydrocarbon

gases in the returned cooling water from
leaks in heat exchangers.
The original cooling tower internals have

now been replaced with polypropylene
packing.
Cooling tower fans are reported to have
explosion proof motors.
This will reduce the

flammable gas igniting.
likelihood
of
The gearboxes and motors have vibration

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

cells.
No. Normally in Use
8 cells should be adequate for full

operation but previously all 10 have been
in use.
No. of Pumps
5 electrically
driven pumps, each of
3
8,400m /hour are installed.
No. Normally in Use
The system is designed for 3 of the 5

pumps to normally be in use.
All cells are now operational and repairs

to gearboxes and fans, reported
defective in previous surveys have now
been repaired.
Packing in the cells is in relatively poor
condition. Some has been displaced into
the cooling water return line and blocked
tubes in many of the exchangers.
Previous problems of leakage, requiring

th
a 4 pump to operate have now been
overcome.
74
Details
Boiler Feed Water
Comments
Treatment consists of:
3 Activated carbon filters installed for

condensate treatment.
3
2 x 175 m /hr
1 x 280 m /hr
The Boiler Feed Water quality has

previously been poor on occasions and
this may have contributed to problems
with the boiler tubes. Improved chemical
dosing and monitoring are now in place.
3 mixed bed polishers all 280 m /hr.

In addition to provision of fresh Boiler
Feed Water, there is a significant recycle
of condensate.
3
The following storage capacity is installed:

3
Demineralised water 1,500 m

3
Polished water 2 x 1,500 m
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 the
olefin plant has been achieved, fuel gas is provided by the cracking furnaces.
The gas turbines can operate on either natural gas or diesel fuel.
6.5.3. Steam
No. of Boilers
Operating
Configuration
Details
Comments
All steam raising takes place on the

olefins plant using the following:
The boilers have been refurbished as

part of TAM 1 and are now equipped with
a Yokogawa DCS systems.
3 Boilers each generating

2
tonnes/hour at 48 kg/cm .
6 Cracking furnaces generating steam

2
2
at 48 kg/cm and 109 kg/cm .
Steam is provided by
furnaces and the boilers.
the
120
cracking
At low cracking rates all three boilers were

required to meet steam demand. As
demand increases, more heat from the
cracking furnaces is recoverable as steam
and 2 boilers will be adequate to meet
demand. However normal practice is to
keep all 3 boilers in operation at reduced
flow rates to allow for the possibility of a
boiler trip.
Distribution
During periods when boilers are taken

out of service for statutory inspection,
there will be no spare steam capacity.
Steam is provided at 4 pressure levels:

2
Ultra high pressure (109 kg/cm ).
2
High Pressure (48 kg/cm ).
2
Medium Pressure (11 kg/cm ).
2
Low Pressure (5 kg/cm ).
75
Boiler house
6.5.4. Electricity
No. of External
Feeders
Details
Comments
There is a single feeder, owned by

National Electrical Power Authority
(NEPA) to connect EPCL to the Port
Harcourt Refinery.
EPCL currently supply approx. 0.5 MW to

the Port Harcourt Refinery.
Previously EPCL exported power to the

following:
Pipeline and Products Marketing
Company
(PPMC),
a
NNPC
subsidiary.
EPCLs housing colony.
The current situation is unknown but the

small size of these loads by comparison
with the installed gas turbine capacity is
unlikely to affect plant operations.
76
On Site Generation
Details
Comments
There are four GE Frame 6 power

generators installed, each with a capacity
of 33 MW.
The units can be fired on gas and diesel

fuel. It is understood, that they have also
been fired on propylene in the past.
There was a total power failure at the site
in April. It is understood that the natural
gas supply was interrupted and when one
of the operating gas turbines changed
over to diesel fuel, excessive flow
occurred and the turbine tripped. The
second operating gas turbine then tripped
due to high temperature spread in the
exhaust system.
These units are reported to be in generally
good condition.
The gas turbines are located within a

large single building. The number of
flanges on the fuel gas lines within the
buildings is limited.
This will minimise the potential for a gas

leak from a flange to generate an
explosion within the building.
Interior of gas turbine

building
Operating
Configuration
Maximum demand is 35 MW, with current

site demand varying between 28 32
MW.
This is met by running 2 generators at
approximately 50% capacity.
Distribution
This will allow one machine to take over

full load in the event that the other
machine trips.
Power is generated at 11 KV in the main

generators, then stepped up to 33 KV.
There are also 3.3 KV and 415 V
distribution systems.
Distribution is via a secondary selective
system.
There is a load shedding system covering
the site.
High voltage switchgear is SF6 type, LV
switchgear is vacuum type.
Some simple, low voltage, extensions to
the system have been made to assist with
maintenance and routine work activities.
A single transformer failure should not

result in a power failure within the site.
77
Details
Equipment
Protection
Emergency
Generation
Comments
Fire walls are installed between

transformers.
Carbon dioxide systems are installed
on the gas turbine generators.
Emergency power is provided by 4 diesel

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

A hot oil system is installed in the PE plant.
6.5.6. Air
Details
Comments
No. of Compressors
There are 5 electrically driven centrifugal,

oil free, air compressors.
A new unit is in operation to replace one

of the original units which has been
cannibalised for spares.
Capacity
4 Elliot
machines, each
rated at 6,800
3
2
Nm /hour at 8 kg/cm g.
1 Ingersoll
Rand machine,
rated at
3
2
7,505 Nm /hour at 8 kg/cm g.
Operating
Configuration
3 Units are required for full operation.

The air compressors supply plant and
instrument air and also provide a feed to
the nitrogen generation unit.
Air Treatment:
Air driers are installed for the instrument

air system.
Back-up Facilities
Air receivers provide buffer capacity of 15

30 minutes for the instrument air supply.
In addition, some plants have small
independent instrument air compressors.
When all process units are in full

production, there will be no standby
machine.
This represents a satisfactory level of

back-up.
78
6.5.7. Nitrogen
Brief details are given below.
Type of Supply
Details
Comments
The original system comprised an Air

Products cryogenic nitrogen unit.
The air dryers for the unit have

previously been ineffectual, allowing
moisture to pass with subsequent
freezing in the cryogenic unit. Since the
takeover of the site by Indorama, the
molecular sieve has been replaced and
the unit is reported to be working
satisfactorily.
A new nitrogen unit was ordered from the

Suzhou Oxygen Plant Company (SOPC),
China. Some equipment items for the
unit have been purchased directly by
EPCL rather than sourced through
SOPC. Both units are now operational.
Whilst this may not be a company widely

known in the West, they are reported to
have built over 600 units worldwide.
Unit
Storage
N2 Liquid
3
Nm /hr
N2 Gas
3
Nm /hr
Air
Products
390
3,400
SOPC
450
1,800
There are 3 liquid nitrogen storage

tanks
3
each with a capacity of 175 m .
Facilities
are installed to provide 6,400
3
m /hr. of vaporisation capacity.
There are also facilities to load/unload

liquid 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 olefin
unit), 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 prevent
the movement of flammable gases through the drain system. The seals are vented to
atmosphere with flame arrestors installed. Whilst the main drainage channels are largely clear
of vegetation, in several locations small drains feed into the open drains and these are fitted
with metal grids, presumably to prevent rodents, etc. entering the system. Many of these are
partially (in some cases almost totally blocked) with debris and could restrict discharge.
The system has segregation between the storm water and oily-water drainage systems with
all oily drainage directed through to a proper drainage system in the water treatment area.
79
Effluent clean up consists of:
Equalization
Neutralisation
Coagulation
Flocculation
Dissolved Air Floatation
Clarification
Effluent treatment plant
A separate caustic treatment unit is installed.

6.5.10. Incineration
Two incinerators are installed:
Polymer incinerator 5,061 kg/day capacity
Back-up incinerator, sludge waste 360 litre/hr; solid waste 50kg/hr.
6.6. Major Equipment Items

A full list of the main equipment items was not provided by EPCL but the major rotating
machines are believed to be:
Manufacturer
Olefin Plant Cracked Gas Compressor
Elliot/Mitsubishi
Olefin Plant Propylene and Ethylene Refrigeration

Compressors
Elliot/Mitsubishi
80
Manufacturer
Power Plant Gas Turbine Generators
GE (Frame 6)
Polypropylene Plant Extruders

Polyethylene Plant - Extruders
Further details of equipment maintenance are given in section 7.3.
81
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 the
takeover by Indorama was around 1,000, currently, there are approx. 600 local staff and 170
expats. The former NNPC staff who have left the site work in other NNPC business units
and there were no significant redundancies that might have triggered resentment against the
company management.
EPCL 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.

reporting to him are:
Olefins
Polymers
Offsites/Utilities
Maintenance
Technical Service
Health, Safety and Environment (HSE)
The key departments
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 and
increase 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.
82
7.2. Operations
7.2.1. Process Operations
Brief details of the operations group are given below:
Details
Performance
Comments
The facilities now have an availability

approaching 100%. But throughput may
be limited by shortage of feedstock.
There was a total shutdown in February
when a power failure at the Agip plant
supplying EPCL suffered a power failure.
Coincidently, there was a power failure at
EPCL at the same time, resulting in a
shutdown of the polymer units.
Operation is becoming more stable with 1
or 2 "First Intervention Reports" (process
upsets).
On stream time in the polyethylene plant
has increased as a consequence of a new
mechanical seal on the reactor agitator.
There have been several forced
shutdowns of the polypropylene plant but
most downtime on both units is planned.
Panel
Operator
s
Field
Operator
s
Offsites
Utilities
Polypropylene/
Butene 1
Shift
Engineer
Power
Polypropylene
The operational activities are split

between three main groups:
Olefins (sub dived into hot and cold
sections).
Polymers
(subdivided
into
Polypropylene and Polyethylene &
Butene)
Power Utility and Offsites.
Each unit has a plant manager and
production manager (working days), plus
shift teams as follows:
Olefin Plant
Organisation and
Staffing Levels
Whilst most of the supervisors and

senior personnel are Indian ex-pats. At
operator level, Indian personnel are
increasingly being replaced with local
staff.
1 Shift engineer and assistant, the

olefins plant is split into hot and cold
sections.
2 Plus one field operator at NNPC
83
Details
Comments
Outside day working hours, there is a shift

manager in charge of the site.
This will ensure a good level of

communication and control in the event
of a major incident. In the absence of a
nominated individual, confusion can
arise over who takes initial charge of an
emergency and who has authority to
shut down the plant.
The site has four shift teams working a

three shift system.
8 hour as opposed to 12 hour shifts will

reduce the level of fatigue faced by shift
personnel,
particularly
during
hot
weather.
Indian operators work 12 hour shifts.
As the local and Indian personnel work

different shift patterns, shift hand overs
will be staggered and not all personnel
will handover at the same time.
Provided hand over procedures are
properly handled this should provide a
better level of continuity than all
personnel changing shift at the same
time.
Local operators work a 7/7/10 hour shift

pattern.
This unusual arrangement is used to

minimise the risk to local personnel
when travelling to the site outside normal
working hours.
Most operators are understood to be in

the age range of 20- 55.
There will not therefore be a sudden

large reduction in the overall level of
operating experience in the near future
but some senior personnel will be
retiring.
Warehouse activities (bagging, fork lift

truck driving, etc.) will be largely
performed by contractors under the
supervision of EPCL staff.
This is a common procedure in polymer

and other plants with large solids
warehouses.
Budget
Budgetary pressures were apparent when

NNPC were the operators of the plant.
There now appears to be significantly
greater resources available.
Training
EPCL now have a training department

which coordinates training across all parts
of the organization.
Trainees will be college graduates with a
science or chemical engineering diploma.
Recruitment from the local area helps to

reinforce good relationships with the
local community.
The recruitment process includes a

written test.
Trainees will undergo a mixture of
classroom and on the job training lasting
approx. 18 months.
Progress is
measured by a mixture of continuous
assessment and interviews but not written
tests.
This will ensure that all recruits have an

adequate command of the English
language.
Operators will initially be trained for a

single operational role on one unit but as
they gain experience will train in a number
of positions.
The recruits from 2006 are now fully
trained field operators and are taking over
panel operating positions.
84
Experience
Details
Comments
A process simulator is available in the

training centre but has not been fully
configured.
This is a basic simulator and considered

to be of very little value for training. An
improved version of the simulator may
be provided in the future.
Most, but not all, operators are graduates.

For more senior positions, including panel
operators and above, EPCL are
appointing
experienced
process
operators, many are Indian ex-pats.
The Ex-pats are being replaced as local

personnel gain competence.
Local operators have either been trained

by EPCL or were recruited from other
process facilities.
Most operations personnel are under 40
and staff turnover is low. There is now a
pool of trained field operators with the
capability to become panel operators.
Few of the personnel from NNPC are

now on site.
Previously, there were a number of

Romanian nationals who had senior
operating positions and had worked at the
site for a number of years. Currently only
1 remains, he is now the olefins plant
manager.
Documentation:
Standard Operating
Procedures
Operating procedures have been totally

revised since Indorama took over the site.
A further upgrade has taken place to
ensure all documentation complies with
ISO 9001 requirements.
Checklists
Checklists have been developed for

activities such as start-up of fired heaters.
Log sheets are completed

operators twice per shift.
Updating
by
field
The use of checklists for start-up can be

useful and is widely practiced.
For
example to ensure that fired heaters and
boilers are purged before firing and for
ensuring that lube oil systems are
functioning before compressors are
started.
All Process and Instrumentation Diagrams

(P&IDs) are reported to be up to date.
As
stated
above,
the
operating
procedures were revised when Indorama
took over the site and have been further
revised to comply with ISO 9001
requirements.
Emergency
Response
Procedures
The emergency procedures have been

revised but are not in a "short format".
The procedures examined for the olefin

plant were comprehensive for the
different scenarios but are up to 12
pages long. All actions by all operators
are recorded in the same document.
Information might be more accessible if
the information was re-organised so that
the actions of each individual operator
were more clearly identified.
Some emergency shutdown training takes

place but this appears to be classroom
based and some scenarios are simulated
by temporary changes to the DCS.
Under emergency conditions operators

may react in unexpected ways and
regular field simulations are often
considered a helpful way of reducing
operator error. Without this operators
may be confused as to the location of
the critical valves and other equipment.
85
Process Upsets
Communications/
Shift Handover
Details
Comments
The
recommendation
from
2006
regarding
Emergency
Response
procedures has not yet been addressed.
Following discussions with the plant

manager more complete implementation
is expected in the future.
A reporting procedure for process-upsets

is being developed. The first stage is the
completion of a "First Information Report".
After investigation a "Facts and Analysis
Report" is produced with lessons learned.
A previous survey recorded that all alarms
are recorded on the DCS system and no
problems with alarm flooding have been
reported.
A
number
of
companies
have
experienced problems, with "alarm
flood", during major incident.
This
results in literally hundreds of alarms
being activated within a very short space
of time. When this happens, the sheer
volume of alarms makes it difficult for
operators to follow the exact sequence
of events. Alarm management systems
assist by filtering out the less important
alarms.
Shift logs are maintained by the shift

engineer and panel operators.
The
condition of the plant is discussed by the
incoming and outgoing supervisors both
incoming and outgoing personnel sign the
log book.
It is often considered advantageous for

both the outgoing and incoming
supervisors to sign the log book to
ensure that there has been a thorough
exchange of knowledge.
As the local and Indian personnel work
different shift patterns, shift hand overs
will be staggered and not all personnel
will handover at the same time.
Provided hand over procedures are
properly handled this should provide a
better level of continuity than all
personnel changing shift at the same
time.
In each plant, there is a log book for each

area. Field operators hand over in their
respective shelters.
A better alternative, in most cases,

would be for the field operators to walk
round their area as part of the handover
process.
7.2.2. Control of Maintenance

Overview
The permit to work system has been

revised since the 2011 survey and
separate vessel entry and vehicle entry
permits are in use.
Copies of the permits are given in

Appendix G.
A plotplan is located in the olefins control

room showing the locations active
permits.
This is considered a positive feature

allowing operations personnel to quickly
identify the location of active work
permits.
The permit system will be implemented

for the new projects from the very start of
construction.
86
Types of Permit
The Permit to Work System consists of

the follows forms: Cold work
Hot work
Permits contain a checklist of safety

procedures, in line with accepted
practice.
The vessel entry permit is basically a

checklist and does not appear to contain
the same requirements for approvals
and hand backs as the hot and cold
permits. It is used in conjunction with a
hot or cold permit.
Vessel entry
Excavation
Vehicle entry
A separate electrical isolation certificate is

used in conjunction with the permit.
Excavation activities are covered under
the management of change procedure.
No. of Copies
There are 2 copies of the permit, one

each for:
Operations department, in the control

room.
The operations copy of the permit is

available in the control room.
Copies of permits were not available at

the jobsites. It is desirable for the
maintenance copy to be kept at the job
site (in a plastic envelop for weather
protection). This would allow operational
and safety staff to check that the safety
conditions required on the permit were
being followed.
Displayed at jobsite.
Job Safety Analysis

(JSA)
A JSA for each task takes place, where

appropriate equipment to be used for
maintenance work is examined to ensure
that it is in good condition. This applies to
both EPCL and contractors equipment.
Standard risk assessments exist for some
routine activities.
Training
Training courses are arranged both for

permit issuers and permit receivers.
Signatures
Signatures are required from operations,

maintenance and safety personnel both
before work starts and after complete.
Unusually, the handback signatures are

on the reverse side of the permit form to
the authorization signatures.
This is considered good practice,

especially with contractors equipment,
which is often in poor condition.
A review of permits in the PP and Olefin

plant control rooms showed that most
were not signed back by the operations
personnel until a day or two after the
work had been completed and signed off
by the maintenance personnel.
This makes it difficult to determine if a
particular activity has been completed at
a glance.
Validity
Permits can be valid for up to 1 day

without revalidation and can then be
revalidated for up to 3 days.
If work starts just before a weekend, the

permit can be valid for a period of up to 5
days and may not be "signed back" by
operations personnel for a further day or
2.
Revalidation of all permits after each
shift would be advantageous as working
conditions for colds permits may also
change.
Filing
Active permits are recorded in a register,

which allows cross referencing between
different permits, isolation certificates, etc.
The cross referencing does not appear

to work well in practice.
A single copy of each permit, without any

supporting information, is filed for a period
of 7 days.
Most permit systems file permits for a

period of 3 months, minimum. This
allows comprehensive auditing of the
permit procedure.
87
A common folder is used for filing all

permits with no differentiation between
continuing and completed work.
This can lead to confusion over the

status of work and, possibly, attempts to
operate equipment not yet fully repaired.
Permits are individually numbered.
Permits which are uniquely numbered

are easier to cross check and cross
reference several permits may be
required for one task.
Auditing of the permits now takes place.
This is a useful process to ensure that

the permit system is operating as
planned.
Isolation
Procedures:
A LOTO system is now in place covering

instrument and mechanical maintenance.
Mechanical
Valves closed for isolation during

maintenance are now reported to be
tagged and padlocked. Where pipework
is opened blinds are installed.
The use of tags and padlocks to ensure

that valves is considered good practice.
Casing blinds (to fit inside pumps where

the casing has been removed) are
available for some situations.
Installation of blinds in the suction and

discharge lines of some pumps can be
difficult.
However casing blinds are
unusual and their effectiveness is
unknown.
Electrical
Electrical isolation is achieved by "racking

out" electrical equipment.
This will provide effective isolation but

the use of a padlock on the isolator
handle would represent an additional
precaution against errors.
The site
management are currently reviewing the
adequacy of the existing system.
Instrument
Since the 2011 survey, the trip by pass

procedure has been revised and new
bypass registers have been developed
and will soon be in use in all the process
units.
Whilst this is an improvement on the

previous system, the new procedure
does
not
comply
fully
with
recommendation 11-04.
There may also be confusion with regard
to bypasses on standby equipment
(where the bypass needs to be active to
avoid the, non-operating, standby
equipment 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 the
facilities in a series of TAMs and conditions are much improved.
Brief details of the maintenance function, known as Central Engineering Services, are shown
below:
Performance
Details
Comments
Plant reliability is now 99 100%. Figures

for 2012 are shown below.
The represents a huge improvement over

the last few years when the plant was
taken over from NNPC.
88
Details
Organisation and
Staffing Levels
Comments
The current organizational structure is

shown below:
Current staffing
departments are:
levels
in
the
main
Unit
Expat
Local
Approved No.
58
152
Actual No.
51
155
Olefins
28
Polyethylene
10
31
Polypropylene
20
Power & Utilities
10
25
Central Engineering
Workshops
15
51
Numbers are broadly similar to the 2011

survey.
Whilst there are vacancies for a few of

senior (ex-pat) personnel, there are no
skills shortages.
89
Details
Comments
Budget
No budgetary constraints were apparent.
Training

There is a training facility at the site with
an apprenticeship programme. Initially,
EPCL recruited experienced personnel
and many of these are still on site.
Additional specialist training is provided
where appropriate, for example for the
new DCS systems.
Experience
EPCL
has
employed
experienced
maintenance personnel.
Additional
training is provided where required.
There are also a number of Indian ex-pat
personnel, generally at supervisor level
and above.
Average age is approximately 40, with the
local workforce generally being at the
younger end of the age range.
Experience levels are reported to be

adequate and staff turnover levels are low
enough to prevent a drain on the
resources available.
Philosophy
When EPCL was owned and operated by

NNPC, there was a severe shortage of
funds resulting in a backlog of
maintenance. Since then, EPCL have
invested significantly in maintenance
activities.
Since the plant was taken over by
Indorama, there
have been 3
maintenance turnarounds:
An example is the decision to purchase a

new cold box for the Olefin plant, even
though repairs to the existing box
appeared to be satisfactory.
TAM 1
Major turnaround in 2006

(USD 58 million)
TAM
2A
26 day turnaround in May

2008
TAM
2B
10
day
turnaround
in
November 2008
Total cost of TAM 2 was USD
72 million
TAM 3
22 day turnaround in March

2010 (USD 3.2 million)
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 Pressure
Swing Adsorption (PSA) system.
TAM 4 will take place in February 2013

and last 22 days. The main activities will
be:
Overhaul of the cracked gas

compressor
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
90
Planning
Details
Comments
Maintenance is largely preventive and

predictive, together with "LLF" (Look
Listen Feel) activities, coupled with daily
checking of key parameters on key
equipment.
LLF activities would often be considered

as an operators function and it is a little
surprising to find a significant proportion of
maintenance activity dedicated to this type
of activity.
The ORACLE Computerised Maintenance

Management System (CMMS) has been
in use at the site for 18 months.
Previously, MAXIMO was used.
EPCL are preparing SMP (Standard
Maintenance Procedures) for many
routine activities. More than 700 SMPs
have been developed and the process is
largely complete.
For standard activities, these include

JSAs.
Documentation
Only maintenance records since ORACLE

was installed are in the system.
Earlier records are either available in

MAXIMO or as hard copies. The lack of
information available in ORACLE could
hinder fault finding and reliability studies.
However, it would be a major activity to
migrate the plant maintenance history
entirely onto ORACLE.
Mechanical
Vibration monitoring systems (Bentley

Nevada 3300 series) are installed on
large rotating equipment items such as:
Main compressors in the ethylene

plant (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 by

3500 series equipment.
Vibration trips are installed on the gearbox
and motors of the cooling tower fans.
New data capture type vibration
monitoring and analyser (SKF CMX
Series) equipment has been purchased
and technicians trained in its use.
Vibration monitoring is performed at
intervals as shown below:
Equipment Covered
The increased use of vibration monitoring

systems has resulted in the identification
of a number of "bad actors"
Vibration
Monitoring
Equipment with:
High capital cost
Impact
on
production
Impact on safety/
environment
Weekly
Equipment:
On standby
More than 22 kW,
and
Operating
above
2,800 rpm
Fortnightly
91
Details
Comments
Equipment:
On standby,
More than 22 kW,
and
Operating between
1,400 and 2,800
rpm
Monthly
Balance of equipment
When
required
One extruder in each of the polymer

plants has been replaced. The original
surviving extruder on each plant will be
replaced in the future.
An in house lube oil testing programme
has being set up with regular checks on
moisture, viscosity and particles.
If
problems are suspected, lube oil samples
will be sent for particle size analysis.
Ferrography
is
performed
during
turnarounds if considered necessary.
There is some equipment balancing
capability at the site but larger items
would probably have to be returned to the
manufacturer for balancing.
Previous problems with the olefin plant
compressors were as a result of solids
deposition on the rotors. There were also
initial
problems
of
high
bearing
temperatures have now been resolved.
All the rotors have been rebalanced and
some replacement bearings installed.
An additional injection system was
installed to suppress polymer formation by
the injection of "Actrene" and this appears
to be successful.
It is intended to replace the tubes in all 6
cracking furnaces before the end of 2012.
Tubes in 4 furnaces had been replaced at

the 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
Previously, the machines have been

operating at part load which is reported to
increase the EOH (equivalent operating
hours) of each machine. However this is,
at least in part, compensated for by a
relatively low number of starts.
Note EOH Equivalent Operating Hours.

Details of recent gas turbine maintenance
is given in the table below:
92
Details
Running
Hours at
Time of
HGP
(Hrs)
Major
Inspection
Done
GT#1 12 Feb 05
50815.4
11 Jun 11
GT#2 1 Mar 04
GT#3
Last (HGP)
Inspection
Date
Comments
Running
Hours at
Time of M.
Inspection
(Hrs)
23 Oct 12
Running
Hrs
Inspection Schedule
98,776
CI planned in 2014
48991.0
77,599
MI planned for Dec 12 or Jan 13
5 Apr 04
29279.2
48,341
MI planned late 2013 or early

2014
GT#4 5 May 05
49278.2
101,876
HFPI planned for 2013
1.
2.
3.
5 Aug 08
78380
GT#4 Major inspection was carried out after 28000 hrs running of HGP.
Based on the observation and experience in MI/HGP & CI GT inspection schedule is prorated.
Due to low load and clean fuel (GAS) operation HOT GAS PARTS were in excellent condition.
There has been some slippage in dates

from the information provided at the time
of the 2011 survey.
Control systems for the gas turbines are
being updated. 1 unit has already been
upgraded from the Mark 4 to Mark 6
system.
All rotors can be balanced on site. The
balancing equipment is to be modified so
that these items can be balanced. Some
machines can be balanced on line.
Electrical
The oil in all transformers underwent a

Dissolved Gas Analysis (DGA) and
dielectric test at TAM1 and no problems
were identified.
DGA may be valuable for determining the

early stages of transformer oil breakdown
on large critical transformers.
Dielectric testing takes place every 6

months. EPCL now have the capability to
perform DGA testing on site. However
recent
results
have
indicated
unrealistically high levels of ethane in all
the transformers with no other indication
of problems. Samples are now being sent
to an external laboratory for analysis.
EPCLs on site equipment cannot

measure hydrogen levels which they
consider to be an important parameter.
A Thermographic camera has recently

been bought for the site and is used to
check for hot spots in electrical
equipment.
Thermography is increasingly used as an

economic
non-invasive
method
of
detecting faults. This may be a useful
technique for use prior to the TAM to
identify equipment which might be in need
of repair.
There are understood to be facilities for

rewinding large electric motors in the
region.
Lack of suitable facilities could lead to

long periods of downtime whilst a motor
was shipped abroad to the manufacturer.
Some equipment is obsolete and

replacement is taking place, including
some DC machines and invertors.Annual
earthing checks are undertaken.
Instrumentation
Full loop tests are undertaken at each

shutdown. The trip systems are often
used to shut down units when
maintenance is required.
93
Details
Comments
The potential for trip testing in operation

appears limited. In some cases, there are
twin sections of the plant operating in
parallel allowing full loop testing without
taking the plant out of action.
The example quoted was the extruder

section of the polymer plants which are
amongst the least hazardous parts of the
process.
Full function tests (excluding the final

element) take place during operation.
However tests will take place if a problem
is suspected.
Some systems are partially duplicated

which would facilitate on line testing.
So far no SIL (Safety Integrity Level)
assessment has been undertaken to
identify the overall reliability of the loops
and the level of testing required.
The trip valves on the steam turbines are

tested prior to start-up and at shutdowns.
In situations where there is poor steam

quality, scale can build up across the
valve seat preventing it from closing in an
emergency. However, steam quality at
EPCL is reported to be good.
Since Indorama took over EPCL, there

has been considerable upgrading of the
instrumentation, including new DCS
systems in the process units and new F &
G panels in some locations. Further F&G
panels will be replaced.
Spares
"Insurance" spares include rotors and

diaphragms for rotors for the olefin plant
compressors and turbines.
Rotors for turbines and compressors have

either been replaced or refurbished.
Rotors are stored vertically and some are

within nitrogen containers. 6 monthly
checks are made to ensure that there is
still nitrogen pressure in the containers.
Vertical storage will prevent distortion of

the shaft in storage, and nitrogen will
protect against corrosion.
EPCL receive "last run" notification from

component suppliers.
"Last run" notification is a warning by

suppliers that this is the last production
run for a component after which the
equipment will be considered obsolete.
This allows customers to either purchase
large quantities of spares for future use or
look for replacement equipment.
EPCL state that they have never suffered

downtime due to lack of spare parts.
7.4. Engineering
Brief details of the engineering function are given below:
7.4.1. Management
Organisation and
Staffing Levels
Details
Comments
The engineering team consists of 11

people split between Projects and
Process Engineering. Staffing levels are
reported to be adequate.
There is understood to be a shortage of
experienced personnel and EPCL are
trying to recruit ex-pats.
The library function, previously part of this

group is now administered by the
Inspection function.
EPCL have scanned much of the

documentation and drawings into pdf
format, some are available on the site
intranet.
Data sheets for the olefins unit have been

completely scanned.
94
Details
Comments
The library currently contains 3 copies of

the site documentation as hard copies
and microfilm.
Further copies are
available in other departments.
In theory it should be possible to recreate

the library in the event of a fire in the
document rooms but there could be
difficulties in ensuring replacement
documents are up to date.
Key documents and drawings, such as

Process and Instrumentation Diagrams
(P&IDs) are "controlled documents".
The availability of documents on the

intranet could lead to numerous copies
being printed by members of the
workforce, making it difficult to ensure that
documentation is up to date. It would
therefore be prudent to ensure that
"uncontrolled" copies (those printed
without authorization) are marked or water
marked in some way.
Controlled
documents need to be clearly marked and
a distribution list kept, ideally with
superseded documents being returned to
document control for recording and
destruction.
All the site P&IDs are now reported to be

updated and available in an AUTOCAD
format.
All documentation is reported to be stored
in files in 2 separate servers located in
different buildings.
Training

A number of graduates were trained as
part of Nigerian government training
programmes. These are now employed
by EPCL in engineering roles. Further
training is provided where appropriate.
Experience
Most personnel currently working on site

in a technical function are well
experienced and there are no immediate
training needs.
Engineering
Standards
The facilities appear to have been built to

industry standards.
Standards used
appear to have been those of the licensor
plus relevant industry standards such as
ASME, TEMA, API codes etc. In some
cases, standards from the country of
origin may have been substituted, for
example DIN in Germany, BS for the UK.
This greatly reduces the possibility of data

loss.
Mixing of codes on pressure systems can

lead to incompatibility.
Whilst accepted industry standards
appear to have been used at EPCL, there
are some obvious differences between
loss prevention philosophies between the
different process units particularly with
regard to fireproofing in the process
facilities.
EPCL
have
developed
technical
agreements with the licensors of the major
process units:
Kellogg (olefins)
Nova (polyethylene)
Basell the successor to Technimont
(polypropylene)
IFP(now Axens) - the butane-1 plant
Previously EPCL appointed SK Energy of
Korea (who operates similar olefins
plants) as technical advisors but this
agreement has now ceased.
In addition, EPCL have appointed
Ingenero (India) to provide real time
monitoring and feedback of process
operations.
Ingenero have been

function since 2008.
performing
this
95
7.4.2. Management of Change

Details
Comments
Management of
Change:
The management of change system is

described below:
The level of safety review for most

modifications has increased since the
2011 review and Hazard and Operability
(HAZOP) Studies are required for most
changes. There is still no requirement for
organization changes to be treated under
the management of change procedure.
Overview
A management of change procedure has

been developed by EPCL as part of the
new safety manual and is being used in
conjunction with the 320 changes that
have been proposed since the takeover
by EPCL.
Whilst some of the drawbacks identified in

the 2009 survey have been addressed,
there still appears to be an issue with
ensuring that drawings and other
documentation are up to date before the
modification is considered complete.
One of the fires that occurred in 2011
appears to have been due, in part, to a
failure to update an SOP (Standard
Operating Procedure), following a physical
change.
The procedure now includes a checklist to

determine if a HAZOP is needed.
A Pre Start-up Safety Review (PSSR) is
required prior to start-up following any
change.
Whilst the checklist is an improvement on

the previous system, it could still be
improved by implementation of a more
comprehensive checklist.
Hardware changes
All physical changes to the site go through

the MOC procedure.
Process changes
Process changes are covered in the MOC

procedure.
Organizational
changes
There is no requirement for a review of

staffing levels or organizational changes.
It is becoming increasingly common to

review changes to staffing levels as part
of
the
management
of
change
procedures.
This should identify
situations where, for example, under
reduced staffing levels a person might be
required to be in 2 locations at the same
time during start-up.
7.4.3. Hazard Studies

Details
Hazard Analysis
Comments
HAZOP studies of all the units were

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

periodically and in some countries this is a
legal requirement. As a pre-requisite an
accurate set of P&IDs is required.
An update of the studies would also be a
useful training exercise for operators and
might explain the basis of aspects of the
design which appear strange, such as the
action on air failure of the vent valve on
the ethylene storage tank (see section
6.5.3).
EPCL are considering a re-HAZOP of the

site but no final decision has been made.
A comprehensive review of the site should

be undertaken in advance of construction
of the new units.
96
7.5. Inspection
Brief details of the inspection function are shown below:
Organisation and
Staffing Levels
Details
Comments
The inspection function now reports

directly to the site management. The
organizational structure of the department
is shown below.
Currently, there is a vacancy for the Head
of inspection. The previous title holder has
returned to India.
Unlike most locations, there is only limited

involvement of outside contractors during
TAMs.
Technical Director
Other Departments
Head Inspection
Engineer in Charge
Insp. Engr-1
Insp. Engr-2
Insp. Engr-3
Insp. Engr-4
Equipment:
Radiography
Radiographic work is contracted out but

EPCL staff interpret the radiographic
plates.
It is common practice for radiographic

activity to be performed by a third party
company.
EPCL staff are reported to
work closely with the 3rd party inspectors.
There have been problems in some
locations in Nigeria with radiographic
plates being "ringed" (the same plate used
for more than one weld). To avoid this
EPCL personnel supervise contractors
and make sure each film has a unique
reference number on the film.
EPCL have their own darkroom and film
developing capability.
97
Details
Comments
Ultrasonic
Panametrics
ultrasonic
thickness
measurement equipment, A, B, C scan
equipment with data capture facilities is
available at the site. An additional probe
has been purchased since the 2009
survey and purchase of a further unit is
planned.
Probes for use at high temperature are

available and EPCL have no difficulty with
repeatability of readings but generally
prefer to take thickness measurements off
line.
Magnaflux
Magnaflux equipment is available on site.
Eddy current
Contractors would be employed if eddy

current inspection were necessary.
Dye penetrant
Dye penetrant equipment is available.
Alloy Analyser
A Niton metals analyser is available on

site.
These are becoming increasingly popular

by comparison with the better known
Texas Nuclear Analysers because the
radioactive source within the instrument
has a longer half-life requiring less
frequent replacements.
Other
A Holiday detector is available.
This detects defects in vessel and pipeline

coatings. One use will be to detect the
quality of painting systems under
insulation to prevent Corrosion Under
Insulation (CUI).
Other equipment includes a carburization

detector, coating thickness meter and
hardness testers.
Experience
Designation
Qualifications and experience levels are

shown in the table below:
Relevant
Experience
Basic Qualification
Sr. Engineer (Local)
54+ years
HND
and
(Mech.)
Engineer-1 (Local)
12+ years
B.Tech. (Chem.)
ASNT Level-II MPT, AutoCAD
Engineer-2 (Local)
11+ years
B.Tech. (Met.)
ASNT Level-II UFD & RT, API 570
Engineer-3 (Local)
11+ years
B.Tech. (Met.)
ASNT Level-II RT & UFD, Corrosion, API

510
Engineer-4 (Local)
9+ years
B.Tech. (Met.)
ASNT Level-II DPI & RT, Corrosion,

CSWIP 3.1
Documentation
B.Tech.
Specialized Training
Good quality records are available for the

inspection
work
undertaken
since
Indorama took over the site. However,
there is generally only one set of
thickness measurements available.
ANST Level-II RT
So far this has prevented the recording of

data in a form which allows trending to
identify corrosion trends.
More information should be available
following the next TAM in 2013 and it
would be prudent for EPCL to have
systems already in place to upload data
so that trending can start shortly after the
TAM is complete.
Trending should apply to safety valves
inspections as well as wall thickness
measurements to ensure that valves
which consistently perform poorly can be
identified.
98
Details
Comments
EPCL have developed software for

recording inspection information and
trending.
This will become increasingly useful as

more inspection data is produced.
Pipelines
None of the pipelines connected to the

site are the property of EPCL but a Long
rang Ultrasonic Thickness programme
was recently completed and no problems
were identified.
Whilst these pipelines are not the

responsibility of EPCL, it is prudent for
EPCL to check their condition to ensure
pipeline damage to import or export
pipelines will not affect onsite activities.
Boilers and Fired

Heaters
All statutory inspections required by the

Nigerian Authorities are undertaken.
An order has been placed for a remaining
life study of one boiler.
Piping
Inspection philosophy is largely based on

Indian practice, which generally requires
an internal inspection every 2 years.
Previous plans anticipated future TAMs

taking place at intervals of up to 4 years,
which is longer than the 2 year figure used
so far. However a 4 yearly inspection
interval is not out of line with practice in
some areas and is a significant
improvement on practice at the site in the
past.
The current inspection procedure is to

take 4 separate readings at each
inspection point and record the worst
case.
Unless comprehensive records are

maintained, the same location may not be
measured on successive inspections and
the trending/remaining life calculations
may be in error.
The site has investigated a Risk Based

Inspection (RBI) approach to inspection
but details have not yet been worked out.
Whilst companies are increasingly moving

to Risk Based Inspections (RBI), when
Indorama originally took over the site, they
did not consider that there was sufficient
data available to implement RBI at the
site.
The fact that RBI is now being considered
demonstrates the increased confidence
that EPCL now has in the mechanical
integrity of piping and pressure vessels by
comparison with 3 years ago. However
significant work remains before the RBI
can be applied (for example likely
corrosion locations such as stagnant
areas and small bore connections need to
be identified).
A programme of inspection of areas

where insulation is damaged is underway.
There are a significant number of

locations where insulation is damaged
and it would be useful to speed up the
inspection process where possible. This
may not be possible, particularly on lines
which are in constant use. This will
identify areas where under insulation
corrosion could exist and allow remedial
action to be undertaken before the
problem becomes serious.
Corrosion Under Insulation (CUI) work is

progressing with priority being given to
piping sections subject to thermal cycling.
It is claimed that there is no CUI in the

offsites area but the extent of checking
appears limited.
Thermography has been used to find
areas of damaged insulation, which may
indicate the presence of CUI.
Pulsed eddy current technology is being
used.
Whilst this has common application for

CUI, there are some areas where it is
ineffective.
99
Pressure Vessels
Spheres
Details
Comments
After inspection, the surface metal is given

a protective coating before insulation is
reinstalled.
Progress is slow as the piping must be

available for inspection.
The actual
inspection is performed by cutting holes in
the insulation and taking thickness
readings. Most forms of non-intrusive
inspection are considered impractical or
uneconomic by EPCL. However recent3
developments in Real Time Radiography
might be helpful at the site.
Pressure vessels are code stamped and

there are no ASME VIII div 2 vessels on
site.
A significant number of process vessels
and tube bundles were inspected during
TAM1. Those considered less likely to
suffer corrosion were inspected during
TAM2.
The cold section of the olefin plant is

considered as an area where corrosion is
unlikely and has not so far been
examined. Whist corrosion may be limited
due to the operating conditions and the
use of stainless steel, this is also the part
of the plant which represents the greatest
VCE hazard.
7 of the 12 spheres at the site have now

been internally inspected using ultrasonic
thickness measurement, magnaflux and
hydrotesting.
In addition Magnetic
Particle Inspection (MPI) has been
conducted on the sphere legs and the
spheres have been checked for
subsidence. The legs of one sphere have
been checked using Pulsed Eddy Current
(PEC) technology.
An additional sphere will be internally
inspected during TAM4.
There have been cases, in other

locations, where the sphere integrity has
been adequate but corrosion of sphere
legs has occurred, resulting in collapse of
the sphere. Inspection of the legs is
therefore prudent.
An external inspection company has

undertaken acoustic emission testing of
the sphere legs. In addition, EPCLs civil
engineering department have done
foundation checks on the sphere legs.
Neither of these inspections identified
problems.
Once each sphere has had an initial
inspection a re-inspection is planned at 5
to 10 year interval in line with API 576.
This aspiration looks unlikely to be

achieved. 5 of the spheres have not been
internally inspected in the 6 years since
Indorama took over the site.
Spheres, converted to VC5 use, are

hydrotested during the conversion work.
Tanks
Wall thickness measurements of tanks

have been undertaken.
One of the floating roof and 2 of the fixed
roof tanks have been opened for internal
inspection since Indorama took over the
site.
EPCL have checked the potential for
some form of inspection of the ethylene
tank
Whilst a South African company
offered a solution this involved drilling
through the tank walls.
It is common practice not to internally

inspect refrigerated tanks unless there are
indications of problems.
http://www.tuvamerica.com/industry/petrochem/pdfs/POS8024_RTRBrochure.pdf
100
Details
Pressure Safety
Valves (PSVs)
Comments
Inspection of PSVs is in line with API 576

Inspection of Pressure Relieving
Devices.
Pre-pop tests are undertaken and results
included on inspection sheets.
This will help to identify PSVs which are

consistent poor performers.
All critical PSVs at the site are now

reported to have been inspected since
Indorama took over the site. The bulk of
these were done during TAM1 with the
balance at TAM2.
Smaller PSVs which may not be indicated
on P&IDs, for example those on lube oil
systems) have now been identified and
included in the survey programme.
The majority of valves will be checked at
TAM 4 but approx. 15 20 are checked
every year.
In future valves will be
inspected at 3 5 year intervals.
PSVs that have been tested are colour
coded before being reinstalled on the
plant.
Pressure tests are conducted on a test
bench with nitrogen used for pressures up
to 140 bars and water used above that
pressure.
A hot set pressure correction is applied
where necessary.
Whilst the use of water for high pressure

testing is understandable, it is desirable to
use the correct medium for testing (water
for valves on liquid duties and nitrogen for
valves on vapour duties). Use of the
wrong fluid could result in incorrect
calibration.
Hoses
Following a recommendation in the 2009

survey a pressure testing programme for
armoured hoses used with hydrocarbon
materials has been established with
pressure tests being conducted at 6
monthly intervals.
Cranes
All cranes slings, etc. are inspected by a

third party inspection body.
Crane
inspection
is
requirement in Nigeria.
Cranes, slings, etc. are fully inspected,

including a load test, every 14 months.
This is a statutory requirement in Nigeria.
There are reported to be 6 monthly

inspections of slings, etc.
A colour coding system is in use.
statutory
101
Details
Lifting
equipment
coding scheme details
Positive Materials
Identification
Comments
colour
Incoming material is tested & certified at

the suppliers premises by third party
inspection companies such as: Lloyds;
Bureau Veritas; etc. before dispatch. The
material test certificates are reviewed by
inspection department before giving
clearance for dispatch.
A Niton alloy analyser is available at the
site but is only used on a random basis.
However, there was 100% checking for
materials involved in the VC5 project.
This procedure may have the potential to

allow rogue sections of material to enter
the site. Whilst it offers a reasonable level
of protection, it would be preferable to test
and colour code each individual alloy
component entering the site.
EPCL also intends to perform some

random checks on alloy material installed
on the plant.
Welders
Welding is performed by a mixture of in

house and contract welders. Generally
welders are required to produce test
pieces on site but previously issued
certificates are accepted if they are less
than 6 months old.
Welds are checked in line with code
requirements and poorly performing
welders are either successfully recertified
or dismissed.
This differs slightly from common practice

which generally requires the completion of
test pieces from all welders who have not
previously worked at the site on a regular
basis.
102
Details
Comments
Corrosion Protection
Cathodic protection is installed on the

NGL feed line from AGIP. Soil conditions
on the propylene line from the Port
Harcourt refinery do not require cathodic
protection, except in one small section
where a sacrificial anode is installed.
The line to the refinery is understood to be

the property of EPCL, whilst the NGL feed
line is the property of AGIP.
Specific Problem
Areas
There were serious corrosion concerns

when EPCL took over the site from
NNPC.
Most of these have been
addressed during TAM 1 and TAM 2 and
mechanical integrity of the site is greatly
improved.
The main issues at the time of the 2011
survey were:
Corrosion Under Insulation (CUI)
250 m of steam condensate line requiring

replacement has been identified in the
polyethylene plant. No significant CUI has
been identified in process piping.
Erosion in cracking furnace tubes
Tubes in 4 of the furnaces have been

replaced. Tubes in the remaining 2 will be
replaced before the end of the year.
7.6. Safety, Health and Environment

Performance
Details
Comments
The site has recently achieved a 5 star

safety rating in the British Safety Council
scheme with a score of 92.27%.
There is a much greater awareness of

safety issues at the site than during the
2011. This is reflected in safety meetings
and notices around the site.
There is also a clear understanding
between occupation safety and process
safety issues.
EPCL has also been award a Sword of

Honour, with a score of 71 out of a
possible 72.
Accident trends over the last few years
are shown below:
103
Details
Comments
There is now a significant emphasis on

process safety at the site with regular
reviews of incidents world-wide and the
potential lessons that could be learnt by
EPCL.
Scaffolding at the site is to a high
standard.
Scaffolding in developing countries is

often very poor and EPCLs high
standards are the exception.
Newly installed process

safety notice in the olefin
plant
104
Organisation and
Staffing Levels
Details
Comments
The HSE function reports to the Technical

Director.
This will allow a clear reporting route, with

no conflicts of interest.
The department is headed by the site

Head of HSE, with the following groups
reporting to him.
The HSE department is split into 4
subgroups as shown below:
Environment (2)
Safety (5)
Occupational Health (21)
Fire (see section 6.7).
In addition to the departmental manager

and safety officer, there is a safety
representative on each shift team. Whilst
the reporting route is to the safety
department, there have been conflicts of
interests in other locations. This has
resulted in the shift safety officer
sometimes being more concerned with
production activities than safety.
In addition, safety ambassadors

appointed in each unit.
are
Experience
The Head of HSE has extensive

experience of process operations and
process safety.
All personnel at the site have a diploma in
safety.
Accident Reporting
A comprehensive
system is in place.
Employee
Involvement
incident
reporting
Accident statistics are shown above.
Incidents are investigated to identify root

cause. This is undertaken with a formal
procedure rather than one of the software
packages currently on the market.
Lessons learned from incidents are widely
circulated.
A review of the fires that have taken place

in 2011 indicated that the system is
working well and root causes are being
identified.
In addition a system, INDSOP, (Indorama

Safety Observation Process) has been
developed for safety observations.
This is similar to the Du Pont STOP

system and aims to encourage reporting
of poor safety features on a no blame
basis.
EPCL are considering the use of Leading

indicators to modify the track safety
performance.
Leading indicators are a relatively new

approach based on tracking factor which
might lead to a major incident rather than
historical data which is more related to
occupational safety.
EPCL have worked energetically at the site

and there is now a collective consensus
that safety is a line management
responsibility with the safety function acting
largely as an auditor and advisor.
This is in
philosophy.
A new draft safety manual is now being

printed.
This covers a number of process safety

management issues in addition to the
standard "slip, trips and falls" procedures.
There is an interlocking series of 8 safety

committees, the most senior being the
APEX committee, which is chaired by the
Technical Director and involves the heads
of departments. There are also individual
plant committees and a contractors
committee.
line
with
modern
safety
105
Details
Comments
There is a "safety ambassador" for each

area.
The ambassadors are Nigerian nationals,

which should avoid the appearance of expat personnel arriving on site and
preaching.
All new recruits are provided

induction training by EPCL staff.
with
A recent initiative is the appointment of a

senior operations person from each unit to
act as a PSM (Process Safety
Management) coordinator. It is intended
to conduct a process safety audit using
standard references such as API 750 and
CCPS guidelines as a basis.
Housekeeping
Control of Ignition
Sources
Housekeeping was generally to a good

standard.
Occasional examples of missing plugs
and missing bolts on Ex rated electrical
panels were noted.
Where this occurs, this is an indication

that the site conditions are not being
inspected properly before permits are
"handed back" at the end of a
maintenance activity.
In the worst example noted the situation
was rectified before the end of the survey.
Smoking is only permitted in 2 authorised

locations in the site.
There are reputed to be few smokers in the

workforce No evidence of smoking in
unauthorized areas was noted during the
site visit, indicating a good level of
discipline.
EPCL do not consider that the use of

mobile phones in hydrocarbon areas
constitutes a hazard.
A number of infringements were noted,

even by personnel at supervisor level.
Whilst there is disagreement over the spark
potential of a mobile phone, it would be
prudent to prevent their use in hazardous
areas. This not only removes a, possible,
source of ignition but also avoids a
situation where the safety rules start to lose
their clarity and are more likely to be
disobeyed.
All vehicles entering the process areas

have flame arresters fitted.
Safety Auditing
A variety of safety audits take place:
Work permit audits
These have
recently.
only
been
introduced
Internal WPCL safety management

audits
Check list audits
ambassadors
by
unit
safety
British Safety Council Audits
These use checklists and are performed

by personnel within the unit concerned.
At present, there is no cross auditing.
See above for results on the 2012 audit.
INDSOP audits conducted by plant

managers
Currently, there is no central database of
recommendations.
Contractors
This may lead to a piecemeal response

and lack of oversight at a senior level.
EPCL
have
a
contractor
safety
management programme including a
review of contractor safety performance at
the tender stage.
Contractors have safety briefings when
they first arrive on site. Some contractors
have safety training before arriving on
site.
There is also a safety committee
dedicated to contractor issues.
Contractor personnel will need a pass

showing that they have received safety
training before being allowed onto site.
106
7.7. Emergency Response

Details
Comments
Organisation and
Staffing 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. Additional

personnel may be employed when the
new units come on stream.
Experience
All the fire fighters have professional fire

training, including fire fighting training prior
to joining EPCL.
Training
The site has a fire training ground with

facilities for both pool fire and jet fire
training.
Fire fighter competence is likely to erode

without live firefighting experience and it
would be desirable to resume regular
training on both pool and jet fires as soon
as possible to rebuild experience levels.
Currently, there is no smoke house in the

training centre.
Training in the use of Breathing

Apparatus (BA) will be essential for
emergencies in the ammonia plant where
large toxic releases are possible.
Employee
Involvement
An auxiliary fire team composed of security

and maintenance personnel has been
established. This consists of 6 people per
shift.
Mutual Aid
A mutual aid scheme is being developed

involving:
Shell Petroleum (may not attend all

fires).
Mobil.
Total/ELF
The inclusion of fire teams from other

hydrocarbon facilities will ensure that
many of the mutual aid personnel will be
experienced in the specific dangers
associated with hydrocarbon fires.
The level of operational equipment

available at Port Harcourt may be limited.
Port Harcourt Refinery.
107
Details
Comments
River State Fire Authority (the local

municipal fire brigade).
Local authority firefighters frequently

have a limited understanding of oil
industry fires and may have limited
equipment.
Some additional organisations (AGIP and

Nigerian Port Authority) will be assisted by
the scheme but will not contribute to it.
A key location is the AGIP metering

station located within the EPCL site. The
metering station is critical to the supply of
feedstock to EPCL.
Hose couplings are standardised between

all members of the mutual aid system.
Emergency Planning
An emergency plan (EPCL-HSEF-2-111)

has
been
developed.
Roles
and
responsibilities have been defined and
deputies nominated.
This was last
updated in April 2011.
Points noted in the previous CTT survey

are
understood
to
have
been
incorporated in the latest version of the
emergency plan.
Emergency coordination centres have

been established in the Plant Shift
Superintendents office and the fire station.
These are reported to be fully equipped.
A level of pre-planning has been
completed for generic incidents such as
tank fires and process area fires.
Emergency Drills and

Simulations
Well-developed pre plans can assist in

the early stages of emergency planning
by providing firefighters with the basic
information required to mount a fire
attack quickly.
The ones currently available lack detail
and do not currently include hazard
contours, it is therefore not possible to
predict if the existing plan will be
rendered ineffective by high levels of the
thermal radiation or other hazards.
Some of the pre-plans envisage the use
of aluminized suits which differs from
common practice and may not be
practical in some situations.
There are frequent minor drills.

Emergency simulations take place on an
annual basis, including mutual aid
partners.
7.8. Security
After CTTs 2006 survey, a kidnap event took place affecting a number of EPCLs ex-pat
staff and family members. Since then there have been significant and on-going increases in
security. Brief details of the security function are given below:
Organisation and
Staffing Levels
Details
Comments
EPCL have a small security department,

totalling 23, reporting to the site
administration manager.
They are
supported by a much larger number of
external security personnel, totalling
approx. 300, including police and army
contingents based at the site.
There are a small number of expat
personnel at senior levels.
EPCL have now recruited one of the 2

Israeli security experts formerly working
under contract onto full time staff.
108
Details
Comments
Approx. 160 of the personnel are unarmed

and provide basic security at locations
such as control of entry to buildings, etc.
They are employed by two local security
contractors:
Pentagon Security - provide security in
the outer perimeter and up to the inner
fence to the process, utility and
offsites.
Bulwark - provide security within the
inner fence containing the process,
utility and offsites.
There are also a number of Nigerian state
authorities involved in security at EPCL:
Nigerian army (84)
Mobile police (64)
Regular police(30)
Security intelligence officers (2).
members of the anti-bomb group (4)
The army and mobile police are both
armed and have bases inside the site
parameter.
Some of the security personnel operate

within the site in plain clothes.
In addition EPCL have undertaken a

number of actions to limit tension between
the company and the surrounding
community, including the provision of
training programmes and the use of local
people, where possible, for unskilled work.
Other miscellaneous activities include the
running of security consciousness classes.
Post Orders
All the EPCL security personnel and

external agencies have defined roles
through a chain of command.
There are three levels of patrolling:
External to the site
Within the site boundary
By plain cloths personnel at the site
Security Patrols
Security patrols take place involving the

contractors and the external agencies.
Dematching/Search
Policies
There is no dematch policy but random

searches of vehicles entering and leaving
the site take place.
These are concerned with theft as much

as security threats.
Drug/Alcohol Abuse
There are currently no drug or alcohol

testing programmes.
There are reported to be no drug or

alcohol problems at the site. Alcohol is
allowed in residential areas but no
problems have been reported.
Employee
Background Checks
Checks take place on local recruits and

long term contractors.
Weapons
The soldiers and mobile police are armed.
Experience and
Training
Many of the contract security personnel

are ex-military or ex-police.
Post orders define the requirements of

the security section.
These should
include the chain of command, required
duties, normal operating duties, and
emergency
responses
to
security
incidents.
109
Details
Control of Access to
the Site
There is one main gate into the site.
Physical Precautions
Since the kidnapping incident security

precautions have been significantly
increased.
There is only one point of access to the
site, through a well-guarded gate.
An access control system featuring
swipe cards is being installed.
The site has been divided into a

number of areas with security
posts between them.
The original wire fences topped

with barbed wire have now been
replaced by a 3m concrete wall
topped with an electrified fence.
Comments
Other gates could be used for emergency
access but are generally kept closed.
A multi camera CCTV monitoring

system has being installed
covering the entire perimeter.
The system has movement
detectors which alarm at the
central
monitoring
station.
There are plans to extend the

system.
All Ex-pat personnel and their families are
now located with the EPCL production site.
Construction areas will be fenced off to
prevent construction personnel entering
operational areas.
This will need to be done with care to

ensure that the newly installed fences do
not block emergency exits and entry
points to the existing plant.
Additional difficulties may be encountered
in the olefins plant where construction
activities will take place within an existing
plant and which may be operational at
times.
110
8. Fire Protection
8.1. Fire and Gas Detection
Brief details of the fire detection systems are given below:
Details
Comments
General
Manual Call Points (MCPs) are installed

throughout the site.
Buildings
Smoke detection is installed in buildings,

including underfloor areas in control
rooms.
Detectors are also installed on the air
inlets for air conditioning systems.
The smoke detection system in the main

office building has not yet been
renovated but the plant based systems
are understood to be operational or under
repair. See below.
Process Areas
Gas detectors are installed through the

process areas.
The gas detectors and panel for the

polypropylene plant have been replaced.
Spare parts and vendor support for the
systems in other units is still available.
Heat detection systems are installed in

some process areas to activate water
sprays.
The level of detectors varies within the
process facilities reflecting different design
philosophies. Numbers of detectors are:
Olefins 36.
Polypropylene 45.
Butene 1 - 18
The fire alarm panels have been

refurbished since EPCL took over the site.
During the survey most of the loops on

the panels had fault status lights
illuminated. This is reported to be due
the fact that the original power supplies
have been replaced. The internal logic in
the system does not recognise the new
power source and hence indicates a fault.
The gas detection system has been

refurbished over the last few years.
Pellistor type detectors are still in use

rather than the more modern infra-red
types. Whilst pellistor type detectors are
more susceptible to poisoning than infrared types, process materials at the site
do not contain sulphur the most
common poison.
Within the LPG and refrigerated storage

areas gas detectors are installed.
Smoke detectors are installed in the
polyethylene and polypropylene storage
facilities. Fusible plugs, activating deluge
systems are also installed.
Gas detectors alarm at 25% and 50% of

LEL but do not initiate any shutdown
action.
Storage Areas
The storage area F & G panel was

indicating a fault at the time of the survey.
Utilities
The gas turbines are fitted with heat and

flame detection systems. These activate
carbon dioxide extinguishing systems.
Signalling
There are local fire panels around the site

with a repeater at the fire station.
These systems are reported to be

operational and set to trigger the
associated carbon dioxide system.
111
Details
Testing
Comments
Regular testing of the fire and gas system

is undertaken.
Smoke generators are used to test the
smoke detectors, and "black light" torches
to check the flame detectors.
Gas detectors are reported to be tested by
aerosol spray at 6 monthly intervals.
The gas detectors are pellistor type

detectors which are relatively old
technology. More modern designs, with
increased reliability feature infra-red
technology.
8.2. Fire Water System

Fire water pumps
Brief details of the fire water system are given below:

Details
Design Basis
Design fire water requirements for the site

are given below:
3
Olefins - 1,550 m /hour.
3
Polypropylene - 1,470 m /hour.
3
Polyethylene/Butene-1 - 1,350 m /hour.
3
NGL storage - 1,717 m /hour (based on a
fire affecting one sphere and cooling of
others).
Comments
112
Details
Fire Pumps
Comments
There are 4 main fire water pumps (2 diesel

and
2 electric) each with a capacity of 900
3
m /hour. A further diesel driven "support
pump" exists.
Pressure in the fire main is designed to be
maintained at 10.5 bar g by 2 jockey pumps
(1 diesel
and 1 electric) with a capacity of
3
105 m /hour.
One of the main fire pumps is currently in
continuous operation as the demand for fire
water for duties such as flushing and wash
down exceeds the capacity of the jockey
pump.
3
A new 50 m /hr capacity jockey pump has

been installed but was not commissioned at
the time of the survey.
Once this pump is commissioned, it

should be possible to shut down the
main electrical pump.
The diesel fuel tanks are located close to the

diesel pumps and could affect them if the
contents spilled and ignited.
Whilst there is diking around the tank,

which would contain spillages, high
thermal radiation levels could damage
the fire pumps. In similar locations, it is
common practice to install a firewall
between the tanks and the pumps.
Fire Water Supply
Fire water
supply is taken from the two
3
55,000 m raw
water tanks. With a minimum
3
of 65,000 m reserved for fire water.
The tanks are replenished from the
boreholes described in section 6.6.1.
This supply would last for over 24 hours

well in excess of normal fire water
capacity.
Fire Main
The fire water ring main is buried and

consists of a looped grid. The main loop is
24 inches in diameter, with laterals and
branches ranging between 18 inch and 8
inch.
The fire main is externally coated for
corrosion protection.
The fire water lines are reported to have

been flow tested and found to be in
good condition with no serious
corrosion.
There are approximately 280 twin connection

hydrants at 90 m intervals or, in congested
plant areas, 50 m intervals.
In addition, there are 51 monitors around the
site.
Many monitors are located within posts

to prevent impact damage.
Fire hose cabinets and fire reels are installed

around the site.
Some cases were noticed where fire water
hoses were being used for wash down or
flushing.
This
is
considered
undesirable.
Operations personnel generally do not
replace fire fighting equipment after
use. This can result in equipment being
damaged or unavailable when required
for firefighting.
If firefighting equipment is required for
other purposes, it should be under
some form of impairment procedure.
In the Polyethylene plant the fire water

system has been tied in to provide
emergency cooling water for the process.
This should ensure a supply of cooling

water in the event of a power cut, the
temptation to use fire water for routine
cooling must be resisted.
113
Testing
Details
Comments
The main fire pumps, electric and diesel fire

pumps are started for 30 - 40 minutes every
15 days.
The reason for the 15 day test interval

is to minimise the number of times that
the electric fire pump is started, as high
levels of current are required when the
pump starts.
The NFPA guidelines recommend 30
minute testing on a weekly basis for
diesel and 10 minutes on a monthly
basis for electric pumps and this period
should be used in the future.
The pumps are started by dropping the

pressure in the main.
This
will
ensure
that
the
instrumentation, as well as the pump is
operational.
The fire pump head curves are checked on a

six monthly basis but flow curves are not
produced.
A flow meter is installed in the fire water
return line to the fire water tank which will
facilitate fire water pump testing.
It would be prepare actual flow curves

for the pumps so that performance
across the entire pump curve can be
reviewed, 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
Buildings
A number of fixed systems are installed in

various buildings:
Laboratory sprinkler system with a
2
7.74 l/min/m density.
Process Areas
Comments
Control and rack rooms (including

underfloor areas) halon or carbon
dioxide systems.
Some of the underfloor systems in

control rooms use carbon dioxide which
is an asphyxiant. These are set for
manual operation to allow personnel to
evacuate the room before the system is
triggered.
The halon systems are reported to be

interlocked with air conditioning equipment.
Halon systems are slowly being replaced by
FM 200.
Halon is now banned under the

Montreal Protocol but some developing
countries have a waiver for continuing
use for a period.
In some locations, such as the
instrument rack room in the olefins
room, the doors are open and portable
fans installed due to defects in the air
conditioning system and this will
prevent the extinguishing system
working effectively. Whilst there will be
considerable movement into and out of
the rack rooms during start-up the
normal practice should be to keep the
doors shut.
This has been an on-going problem for
a number of years.
In addition to hydrants, monitors and

extinguishers, a number of systems are
installed in the process areas:
Fired heaters have manually operated
steam snuffing systems.
Actuation
valves are located at a safe distance.
114
Details
A number of hand held steam lances are

available.
Automatically
actuated
foam/water
deluge systems are installed on vessels
and pump seals in the polymer plants
Automatically actuated water deluge
systems in the polypropylene plant, 4 in
total.
There is a significant variation in the

level of protection between the olefin
and polyethylene plants.
A manually operated deluge system is

installed
around
the
refrigeration
compressors in the olefin plant.
2
Deluge rates are 10.2/l/min/m
for most
2
duties and 20.4 l/min/m for pumps.
A similar system may be installed

around the cracked gas compressor but
this was not visited during the survey.
These are activated by melt tubes.
Storage Areas
Utilities
Comments
Dry powder systems are installed to

protect the TEAL handling systems in
the polypropylene plant.
All the major liquid storage facilities have

fixed fire protection:
Main atmospheric storage tanks2 water
deluge (varying
from 6.5/l/min/m to 12.2
2
/l/min/m ) fixed foam systems.
Spheres have water deluge rings
covering the entire surface.
The refrigerated ethylene tank has a
water deluge2 system with a density of
10.2 l/min/m . In addition there is an
impounding basin for containment of
ethylene spillages which is equipped
with water deluge and fixed foam
systems.
The bladder tanks for the foam systems are
reported to have been recently tested and
found to be in good condition and are
rechecked at 2 yearly intervals.
Discharge rates appear to be in line

with API standards.
Fire protection systems on tanks are
being overhauled.
The
polypropylene
and
polyethylene
warehouses have water deluge systems with2
water densities varying
between 7.8 l/min/m
2
and 18.3 l/min/m depending on the area
being protected.
The catalyst storage facility has a deluge
2
system with a water density of 15.1l/min/m .
2 of the sprinkler systems were isolated

at the time of the inspection.
There are a limited number of extinguishers

and hose reels within warehouses.
Access to some equipment was limited.
A number of fixed systems are installed in

the utility areas:
Motor Control Centres (MCCs) and

switchrooms have fixed carbon dioxide
extinguishing systems
The provision of fixed systems again

suggests a difference in design
philosophies between the different
plants. There are no fixed systems
within the olefin unit, whilst MCCs and
switchrooms in both the polypropylene
and
polyethylene
plants
have
protection.
Fixed carbon dioxide systems are

installed in the 4 gas turbine cubicles.
There were no water deluge systems noted
on the main transformers.
115
Details
Comments
Liquid CO2 system gas

turbine
Testing
Fire fighting systems are maintained on an

annual basis.
8.4. Passive Systems

Details
Comments
Buildings
Control rooms for the process units are blast

resistant without windows. However in all
the process control rooms visited, the main
doors were open.
The level of blast resistance was not

determined.
Despite the blast resistant design, the
integrity of the control rooms is reduced
if doors are left open.
Process Areas
The level of passive fire protection varies

considerably with only limited protection in
the olefins plant but a considerably higher
level of protection in the polyethylene plant.
Again this suggests different fire

protection philosophies between the
different licensors and contractors.
The requirement for fireproofing will be
lower in plants handling hydrocarbons
which will be in the gas phase after
release rather than the liquid phase
where pool fires might result.
116
Details
Comments
Many vessel skirts are fire proofed.
Fire proofing has been applied to a

number of vessels where it was
previously missing but there may be
others where fire proofing is still
required.
The level of fire proofing on piperacks is

variable
with
some
racks
carrying
predominantly hydrocarbon gases being fire
proofed in the polyethylene plant. In other
locations piping with liquid inventories is in
un-fireproofed racks.
There is generally little value in

fireproofing piperacks containing gases.
Fireproofing is designed basically as
protection from liquid pool fires.
Fin fan coolers are partially fireproofed but

not to the full load bearing height.
The air flow from the fin fans will

exacerbate flames from a pool fire. The
provision of fireproofing almost to the
top of the fin fan cooler will minimise the
extent of damage caused by a pool fire
under the fin fan.
In some places, particularly in the process

areas, fire proofing was damaged and
requires repair.
The TEAL (catalyst) storage areas in the
polypropylene and polyethylene plants are
constructed of concrete with dividing walls
between the TEAL containers.
In some locations pipe supports on liquid
lines were not fire proofed.
Storage Areas
Sphere legs are fireproofed.

2 hour rated fire walls are installed in some
warehouses.
Utilities
Fire walls are installed between transformers

with stone covered drainage at the base.
2 hour rated fire doors are installed at all
substations.
In some cases, the height of the fire

wall might not be sufficient to prevent a
degree of thermal radiation exposure by
the adjacent transformer.
117
Transformers separated
by firewalls
8.5. Mobile Equipment

8.5.1. Fire Trucks
Brief details of the fire trucks are given in the table below:
No. of
Trucks
Details
Comments
Combination Truck
3,000 l/min water pump at

100m head.
4,000 l foam, 8,000 l water and
1,000kg dry chemical.
One of these is a new Tata fire truck

purchased since Indorama purchased
the EPCL.
Multi-purpose truck
8,000 l water and 1,0000 l

foam
This is a new truck purchased since the

2009 survey. It was originally intended
to deal with bush fires originating
outside the site. However, bush fires
have ceased to be an issue since the
concrete security wall has been built.
Bronto Skylift
Foam/water pump 3,000 1/min

capacity at 100 m head.
4,000 l foam.
Rescue Truck
250 Kg of dry powder with a

discharge rate of 2.3 kg/sec.
Water Tender
7,000 l water
A monitor has now been added to this

vehicle.
118
No. of
Trucks
Details
Foam Trailer
4,000 l foam.
Dry Chemical
Powder
4,000 l water
Comments
All fire trucks are reported to be operational.

There are approximately 1,500 portable fire extinguishers throughout the site. These are dry
powder, 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 inconsistencies
in the frequency of inspection.
8.5.2. Foam and Dry Powder Stocks
Minimum foam stocks are:
AFFF 6,000 litres
AFFF (ATC) 5,000 litres
FFFP 10,000 litres
Dry chemical powder 4,000 litres
Care should be taken in the use of foam as mixing different foam types may reduce
efficiency.
Some foam is available in fire trucks and a 3,800 l overhead tank has been installed to
provide rapid refilling of fire trucks, together with a limited stock in drums.
The frequency of testing of foam stocks is unknown.
Appendix A
List of Acronyms
A list of common acronyms are given below, many of them may not appear in this particular
report but are include for convenience:
Acronym
Description
Acronym
Description
2-o-o-3
2 out of 3 (instrumentation)
ERP
Emergency Response Plan
AFFF
Aqueous Film Forming Foam
ERT
Emergency Response Team
ALARP
As low as reasonably practical
ESD
Emergency Shut Down
AMS
Alarm Management System
ETBE
Ethyl Tertiary Butyl Ether
AMS
Alpha Methyl Styrene
Ex
Explosion Proof
ATC
Alcohol Tolerant (foam) Concentrate
F&G
Fire and Gas
BD
Bursting Disc
FAT
Factory Acceptance test
BFW
Boiler Feed Water
FBD
Functional Block Diagram
BLEVE
Boiling Liquid Expanding Vapour

Explosion
FCC
Fluidized Bed Catalytic Cracker
BOP
Blow Out Preventor
FEED
Front End Engineering Design
BPD
Barrels Per Day
FFFP
Film Forming Fluoro-protein (foam)
CCR
Continuous Catalyst Regeneration

(Platformer/Reformer)
FLT
Fork Lift Truck
CDU
Crude Distillation Unit
FMD
Flooded Member Detection
CMMS
Computerised Maintenance
Management System
FOC
Fibre Optic cable
CO2
Carbon Dioxide
FP
Fluoro Protein (foam)
COMAH
Control of Major Accident Hazards
GIS
Gas Insulated Switchgear
COTP
Captain of the Port (from US 33 CFR

154)
GRE
Glass fibre Reinforced Epoxy
CP
Cathodic Protection
GRP
Glass Reinforced Plastic
CPT
Compliant Piled Tower
H2S
Hydrogen Sulphide
CRINE
Cost Reduction in the New Era (UK)
HAZID
Hazard Identification
CT
Cooling Tower
HAZOP
Hazard and Operability Study
CUI
HDS
Hydro Desulphurisation
CW
Cooling Water
HIC
Hydrogen Induced Corrosion
DCS
Distributed Control System
HIPPS
High Integrity Pressure Protective

System
DGA
High Integrity Protective Systems
HIPS
High Integrity Protective Systems
DWT
Dead Weight Tonnes
HP
High Pressure
ECC
Emergency Control (or Coordination)

Centre
HPVR
High Pressure Vessel Rupture
EEMUA
Engineering Equipment and Material

Users Association
HRSG
Heat Recovery Steam Turbine
EIV
Emergency Isolation Valve
HV
High Voltage
EML
Estimated Maximum Loss
HVAC
Heating Ventilating and Air Conditioning
Acronym
Description
Acronym
Description
ICSS
Integrated Control and Safety System
NACE
National Association of Corrosion

Engineers
IP
Impressed Current (Cathodic Protection)
NDT
Non Destructive Testing
IS
Intrinsically Safe
NFPA
National Fire Protection Association
ISGOTT
International Safety Guide for Oil

Tankers and Terminals
NGL
Natural Gas Liquids (C2-C4)
ISRS
International Safety Rating System
NOC
No Objection Certificate
JT
Joule Thompson (Valve)
NORM
Naturally Occurring Radioactive Material.
KPI
Key Performance Indicator
O&M
Operation and Maintenance
LAHH
Level Alarm High
OEM
Original Equipment Manufacturer
LEL
Lower Explosive Limit
OPC
OLE for Process Control
LNG
Liquefied Natural gas (C1)
OTN
Open Transport Network
LOPA
Layers of Protection Analysis
P&ID
Process and Instrumentation Diagram
LOPC
Loss of Primary Containment
PAGA
Public address and general alarm
LOS
Line of Site
PCB
Poly-chlorinated Biphenol
LOTO
Lock Out Tag Out
PCS
Process Control System
LP
Low Pressure
PDCS
Power Distribution Control System
LPG
Liquefied Petroleum Gas
PFD
Probability to fail on demand
LSA
Low Specific Activity (Scale)
PI
Polarization Index
LTA
Lost Time Accident
PLC
Programmable Logic Controller
LTI
Loss Time Incident
PLET
Pipe Line End Termination
LTI
Lost Time Injuries
PMI
Positive Materials Investigation
LTSA
Long term Service Agreement
PML
Probable Maximum Loss
LV
Low Voltage
PSA
Pressure Swing Absorption
MAS
Maximum Amount Subject
PSSR
Pre Start-up Safety Review
MCC
Motor Control Centre
PSV
Pressure Safety Valve
MDEA
Methyl Di Ethanol Amine
PTW
Permit to Work
MFL
Magnetic Flux Leakage
QHSE
Quality Health, Safety and Environment
MMS
Machine Monitoring System
QRA
Quantitative Risk Assessment
mmscfd
Million Standard Cubic Feet/Day
RAS
Radioactive Source
MOC
Management Of Change
RBI
MOL
Main Oil Line
RLA
Remaining Life Assessment
MOV
Motor Operated Valve
RO
Reverse Osmosis (Desalination)
ROV
Remote Operated Valve
MPI
MSF
Multi Stage Flash (Desalination)
ROV
Remotely Operated Vehicle
MTBF
Mean Time Between Failures
RTDB
Real time database
MTTR
Mean Time to Repair
RTU
Remote Termination Unit
Acronym
Description
Acronym
Description
SAT
Site Acceptance Test
SRB
Sulphur Reducing Bacteria
SBM
Single Buoy Mooring
SSSV
Sub Surface Safety Valve
SCADA
Supervisory Control and Data

Acquisition System
TLP
Tension Leg Platform
SCC
Stress Corrosion Cracking
TPD
Tonnes per day
SDH
Synchronous Digital Hierarchy
UF
Urea Formaldehyde
SF6
Sulphur Hexafluoride
UFL
Umbilical Flow Line
SHE
Safety Health & Environment
UPS
Uninterruptable Power Supply
SIL
Safety Integrity Level
UT
Ultrasonic Thickness (Measurement)
SIS
Safety Instrumented System
VCE
Vapour Cloud Explosion
SOLAS
Safety of Life At Sea
VDU
Vacuum Distillation Unit
SONET
Synchronous Optical Network
VESDA
Very Early Smoke Detection Apparatus
SPM
Single Point Moorings
WH
Well Head
Appendix B
Information on Impairment Systems
Appendix C
Management of Change Checklist
SAFETY ASSESSMENT
Plant
Title
Ref No
Underline those factors which have been changed by the proposal.

Process conditions
temperature
pressure
flow
level
composition
toxicity
flash point
reaction conditions
Operating methods
start up
routine operation
shutdown
preparation for maintenance
abnormal operation
emergency operation
layout and positioning of
controls and instruments
Within the categories listed below,

does the proposal
Relief and Blowdown
1.
2.
3.
Engineering methods
trip and alarm testing
maintenance procedures
inspection
portable equipment
Safety equipment
fire fighting and
detection systems
means of escape
safety equipment for
personnel
Environmental conditions
liquid effluent
solid effluent
gaseous effluent
noise
Yes
or No
Engineering hardware and design

line diagram
lighting protection
wiring diagram
radioactivity
plant layout
rate of corrosion
design pressure
rate of erosion
design temperature
isolation for maintenance
materials of construction
mechanical-electrical
loads on or strength of:
fire protection of cables
foundations
handrails
structures
ladders
vessels
platforms
pipework/supports/bellows
walkways
temporary or permanent:
tripping hazard
pipework/supports/bellows
access for
valves
operation
slip-plates
maintenance
restriction plates
vehicles
fillers
plant
instrumentation and control
fire fighting
systems
underground/overhead:
trips and alarms
services
static electricity
equipment
What problem has been created which affects plant or Signed
personnel safety and what action is recommended to minimise it & date
Introduce or alter any potential cause of over/under pressuring (or

raising or lowering the temperature in) the system or part of it?
Introduce a risk of creating a vacuum in the system or part of it?
In any way affect equipment already installed for the purpose of
preventing or minimising over or under pressure?
Area Classification
4.
5.
6.
Introduce or alter the location of potential leaks of flammable

material?
Alter the chemical composition or the physical properties of the
process material?
Introduce new or alter existing electrical equipment?
Safety Equipment
7.
8.
Require the provision of additional safety equipment?

Affect existing safety equipment?
Operating and Design

9. Introduce new or alter existing hardware?
10. Require consideration of the relevant Codes of Practice and
Specifications?
11. Affect the process or equipment upstream or downstream of the
change?
12. Affect safe access for personnel and equipment, safe places of
work and safe layout?
13. Require revision of equipment inspection frequencies?
14. Affect any existing trip or alarm system or require additional trip
or alarm protection?
15. Affect the reaction stability or controllability of the process?
16. Affect existing operating or maintenance procedures or require
new procedures?
17. Alter the composition of, or means of disposal of effluent?
18. Alter noise level?
Safety Assessor. ........................................................... date ...................................................................................................................................
Check by ............................................................... Plant Manager .......................... Checked by ............................................................. Engineer
Recommendation
Description
Category
12-01
Rehabilitation Project Risk Engineering Review
Priority
12-02
Procedural
XX-YY
Procedural
XX-YY
Procedural
XX-YY
??????????
Procedural
XX-YY
??????????
Procedural
XX-YY
??????????
Procedural
XX-YY
??????????
Procedural
11-01
SIMOPS (Simultaneous Operations)
Priority
11-02
Wafer Valves
Priority
11-03
Priority
11-04
Trip Bypass Procedure
Priority
11-05
Flange Systems
Priority
11-06
Maintenance of Drains
Priority
11-07
Priority
11-08
Priority
11-09
Fireproofing
Priority
09-01
Sampling Procedures
Priority
09-02
Fire and Gas Alarm Systems
Priority
09-03
Control Room Doors
Priority
09-04
Urea Formaldehyde Foam (Cold Insulation)
Priority
09-05
Document Control
Priority
09-06
Operator Emergency Training
Priority
09-07
Permit to Work (PTW) System
Priority
09-08
Isolation for Maintenance
Priority
09-09
Electrical Integrity
Priority
09-10
Trip By-Pass Procedure
Priority
06-01
Fire Detection/Protection Impairment System
Priority
06-02
Job Safety Analysis (JSA)
Priority
06-03
Under Insulation Corrosion
Priority
06-04
Housekeeping
Priority
06-05
Offsites Area
Priority
06-06
Organization Engineering Function
Priority
06-07
Inspection - Hoses
Priority
06-07
Positive Materials Identification
Priority
06-08
Operator Emergency Procedures
Priority
06-09
Permit To Work
Priority
06-10
Priority
06-11
Emergency Plan
Priority
06-12
Asset Ownership of Fire Fighting Equipment
Priority
Appendix D
Organizational Change Guidance
Appendix E
Sample Fire Fighting Pre-plan
Reproduced with Permission of

Resource Protection International
Phone (44) (0) 1296 399311
Fax (44) (0) 1296 395669
Email ramsden@resprotint.co.uk
Appendix F
Plotplan
Appendix G
Permit to Work Forms

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Insurance Risk Survey of Eleme Petrochemical Company

Limited (EPCL), Port Harcourt, Nigeria

88 Leadenhall Street, London, EC3A 3BA

Revised to include new values and loss

Updated to include client comments

Previous survey in March 2005 when the

Insurance Risk Survey of

22nd to 24th October 2012

Charles Taylor plc

This report has been prepared solely for the use

Business Interruption (12 months)

Damage to Olefin Plant cold box.

Vapour cloud explosion in the olefin

Damage to the rotating elements of

Complete destruction of the olefin

Recommendations for Risk Improvement

New Projects Risk Engineering Review

New Projects Consequence Modelling

Permit to Work System Filing

Ethylene Storage Tank Area - Housekeeping

Gas Detection Systems for Occupied buildings

Inspection of Fire Protection Equipment

Testing of fire fighting Foam

2008 Charles Taylor technical

Overall Presentation Sheet

Fire w ater system appears in good condition,.

Perm it to Work System

Permit system is operating satisf actoaly but some

Fire detection systems have been repaired The

The f acilite process large quanties of volatile

Fire and Gas Detection

Operating procedures have been revised but

Note that f urture construction projects couls

Minor exposure f rom other f acilities.

All senior management positions occupied by expats.

Natural perils at the site are limited.

Vegitation has been cleared f rom the drains

A LOTO system ahs now been implemented.

Layout betw een units is generally spacious.

A considerable amount of mainteance w ork has

An ORICLE based CMMS is now in use.

Process Safety System s

Systems appear to be in good condition

Safety Procedures and

Inspection Procedures are to a generally good

There are signif icant stocks of f oam. It is not

Portable Equipm ent

Fixed f ire f ighting equipment is on good condition

Much of the machinery has been overhauled

The site is largely self suf f icent in utilities.

Utility Area Fire

Saf ety procedures are generally to a high

A major pow er f ailure occurred in earlier in 2012,

Systems examined w ere generally in good

Some of the storage f acilities have been

Most porducts are transported by truck in a non

The management of change is capable of

Offsites Fire Protection

The engineering f unction is reported to be

Although control rooms are blastproof ed, the

DCS systems have been upgraded

A high level of security is in place at the site.