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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.

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

Insured Values
The current insured values are:
USD million
Process facilities

848.0

Non-process facilities

69.8

Stocks

65.0

Business Interruption (12 months)

300.0

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

Loss 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.

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

Recommendations for Risk Improvement


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

Description

Category

12-01

New Projects Risk Engineering Review

Priority

12-02

New Projects Consequence Modelling

Priority

12-03

Controlled Documents

Procedural

12-04

Permit to Work System Filing

Procedural

12-05

Database of Recommendations

Procedural

12-06

Ethylene Storage Tank Area - Housekeeping

Procedural

12-07

Gas Detection Systems for Occupied buildings

Procedural

12-08

Inspection of Fire Protection Equipment

Procedural

12-09

Testing of fire fighting Foam

Procedural

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

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

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

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

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

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

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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

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

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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

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

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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

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

12

S. Dineshkumar

Instrument Engineer

S.B. Sagdeo

Instrument Engineer

Ansari Siraje Alam


B. Phamanage

Technical Services Department

Bareen Phamarage

Technical Services Department

Eniafe Babajide

Technical Services Department

Ezemwugo Patricia

Technical Services Department

Ezugu Benneth

Technical Services Department

Nwawosike A. Joy

Technical Services Department

Olumoye O.R.

Technical Services Department

Angus O.

Inspection Engineer

Anyanwu C.O.

Inspection Engineer

Jerome F.

Inspection Engineer

Onyejiaku Angus

Inspection Engineer

K.P. Pandey

HSE Manager

Felix Okosun

Safety Department

Saloka James

Environment Department

B.T. West

Fire Chief

Aluh Pareto

Security Manager

And others

This Underwriting Report is not intended to identify all hazards which may exist nor is it
intended to be an exhaustive review of all possible eventualities. The recommendations 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:

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

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.

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

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

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

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

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

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

Polypropylene Bagging

10,500,000

Storage Area (Including Pipeline to


Refinery)

57,600,000

Power Station

109,300,000

Cooling Water

23,100,000

Demineralised Water

33,400,000

Air and Nitrogen

22,900,000

Flare Area
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

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

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.

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

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.

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

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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

Controlled Documents
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.

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

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12-04
Category

Permit to Work System Filing


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

Database of Recommendations
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.

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

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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.

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

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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.

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

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.

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

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11-03

Control of Maintenance

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.

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

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:

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

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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.

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

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.

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

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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.

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

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

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

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.
The recommendation is IN PROGRESS.

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.

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

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.

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

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.
The recommendation is IN PROGRESS.

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

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.
The recommendation is IN PROGRESS.

Oil quality checking procedure every six

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

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.

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

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

Management of Change

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

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

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.
The recommendation is IN PROGRESS.

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.
The recommendation is IN PROGRESS.

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

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

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

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

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

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

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

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.

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

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.

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

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.

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

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:

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

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

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

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.

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

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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

Polypropylene Bagging

10,500,000

Storage Area (including pipeline to


Refinery)

57,600,000

Power Station

109,300,000

Cooling Water

23,100,000

Demineralised Water

33,400,000

Air and Nitrogen

22,900,000

Flare Area

9,400,000

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

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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

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

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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.

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

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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.

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

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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.

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

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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:

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

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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.

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

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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

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

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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.

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

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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.

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

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"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.

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

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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.

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

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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

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

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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.


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

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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

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

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6.2.3. Emergency Shutdown Systems


Brief details are given below:

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
Brief details are given below:

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/

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

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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.

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

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.

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

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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.

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

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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.

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

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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.
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.

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

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

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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.

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

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6.4.3. Refrigerated Storage


Ethylene is stored in a 12,630m3 double skinned tank constructed by Entrepose of France to
API 620.
Brief details are given below:

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

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

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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

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

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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 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.
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.

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

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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.

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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.

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

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
Brief details are given below:

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 ).

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

75

Boiler house

6.5.4. Electricity
Brief details are given below:

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.

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

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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.

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

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
Brief details are given below:
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.

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

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

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

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

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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.

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

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.

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

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

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

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.

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

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.

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

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


Brief details are given below:
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.

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

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.

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

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.

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

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.

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

89

Details

Comments

Budget

No budgetary constraints were apparent.

Training

EPCL now have a training department


which coordinates training across all parts
of the organization.
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

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

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

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

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:

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

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.

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

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
Brief details are given below:

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.

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

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

EPCL now have a training department


which coordinates training across all parts
of the organization.
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.

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

performing

this

95

7.4.2. Management of Change


Brief details are given below:
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


Brief details are given below:
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.

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

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.

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

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.

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

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.

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

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

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

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.

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

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.

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

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


Brief details are given below:

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:

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

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

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

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.

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

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.

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

106

7.7. Emergency Response


Brief details are given below:
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.

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

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.

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

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.

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

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.

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

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.

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

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).

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

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.

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

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.

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

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.

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

115

Details

Comments

Liquid CO2 system gas


turbine

Testing

Fire fighting systems are maintained on an


annual basis.

8.4. Passive Systems


Brief details are given below:
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.

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

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.

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

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.

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

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.

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

Appendix A
List of Acronyms

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

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

Corrosion Under Insulation

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

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

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

Risk Based Inspection

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

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

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

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

Appendix B
Information on Impairment Systems

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

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

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

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

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

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

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

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

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

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

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

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

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

Appendix C
Management of Change Checklist

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

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

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

Recommendation

Description

Category

12-01

Rehabilitation Project Risk Engineering Review

Priority

12-02

Controlled Documents

Procedural

XX-YY

Permit to Work System Filing

Procedural

XX-YY

Database of Recommendations

Procedural

XX-YY

??????????

Procedural

XX-YY

??????????

Procedural

XX-YY

??????????

Procedural

XX-YY

??????????

Procedural

11-01

SIMOPS (Simultaneous Operations)

Priority

11-02

Wafer Valves

Priority

11-03

Control of Maintenance

Priority

11-04

Trip Bypass Procedure

Priority

11-05

Flange Systems

Priority

11-06

Maintenance of Drains

Priority

11-07

Risk Based Inspection

Priority

11-08

Corrosion Under Insulation

Priority

11-09

Fireproofing

Priority

09-01

Sampling Procedures

Priority

09-02

Fire and Gas Alarm Systems

Priority

09-03

Control Room Doors

Priority

09-04

Urea Formaldehyde Foam (Cold Insulation)

Priority

09-05

Document Control

Priority

09-06

Operator Emergency Training

Priority

09-07

Permit to Work (PTW) System

Priority

09-08

Isolation for Maintenance

Priority

09-09

Electrical Integrity

Priority

09-10

Trip By-Pass Procedure

Priority

06-01

Fire Detection/Protection Impairment System

Priority

06-02

Job Safety Analysis (JSA)

Priority

06-03

Under Insulation Corrosion

Priority

06-04

Housekeeping

Priority

06-05

Offsites Area

Priority

06-06

Organization Engineering Function

Priority

06-07

Inspection - Hoses

Priority

06-07

Positive Materials Identification

Priority

06-08

Operator Emergency Procedures

Priority

06-09

Permit To Work

Priority

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

06-10

Management of Change

Priority

06-11

Emergency Plan

Priority

06-12

Asset Ownership of Fire Fighting Equipment

Priority

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

Appendix D
Organizational Change Guidance

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Appendix E
Sample Fire Fighting Pre-plan

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

Reproduced with Permission of


Resource Protection International
Phone (44) (0) 1296 399311
Fax (44) (0) 1296 395669
Email ramsden@resprotint.co.uk

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

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

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

Appendix F
Plotplan

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

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

Appendix G
Permit to Work Forms

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

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

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

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

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