2012 rec's

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

3. Recommendations for Risk Improvement

3.1. New Recommendations

CTT categorises recommendations with the following classification:

1. Priority: Major risk deficiency that requires prompt action. It is advised that capital

expenditure be allocated to these recommendations in preference to otherrecommendations listed here. These recommendations should be completed within three

months of the survey report date.

2. CAPEX: Recommendations requiring capital investment. These recommendations

should be completed within the next budget cycle unless a major shutdown is requiredfor implementation.

3. Procedural: Recommendations requiring little capital investment. These

recommendations require effort and commitment by staff and can make an importantcontribution to risk improvement. They should not be regarded as trivial items. These

recommendations should be completed with 12 months of the survey report date.

12-01 New Projects – Risk Engineering Review

Category Priority CAPEX Procedural

Recommendation Undertake a risk engineering review of the proposed new units. This willinvolve a review of the design to:

Ensure that appropriate process safety features are installed.

An adequate level of fire protection is installed.

Time to react to and recover from incidents is minimised.

Process safety and fire fighting systems are appropriate for staffinglevels and maintenance regimes that will exist once the units arecomplete.

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

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

Examples Ammonia, Urea and Ethylene plant upgrade projects.

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12-02 New Projects – Consequence Modelling


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

Explosions (including VCE and BLEVE).

Fire (both pool and jet fire).

Toxic gas release.

Terrorism and sabotage.

Natural perils.

Utility failures.

Contingent failures such as loss of feedstock.

The study should consider hazards at both the construction and operationalstages.

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

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

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

12-03 Controlled Documents


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

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

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

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

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

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

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12-04 Permit to Work System – Filing


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

If all copies of the permits are collected together and "signed back", therecan be no confusion regarding the status of work – which could occur if aloose copy of the permit was found.

There should be separate files for completed and uncompleted work.

In addition to the permit forms, supporting information should be included(Job safety analysis sheets, isolation certificates).

There should be regular auditing of the permit system.

Whilst filing in the control room for an extended period (beyond thenormal auditing frequency) is not necessary it is common to file permitsfor a two year period.

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

Examples Files of permits in all units.

12-05 Database of Recommendations


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

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

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

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

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

Examples EPCL operated several databases for recommendations from differentsources.

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12-06 Ethylene Storage Tank Area - Housekeeping


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

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

Reason There is currently significant vegetation growth within the ethylene tank dike.This could become a fire hazard during the dry season.

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

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

Examples Ethylene storage tank area.

12-07 Gas Detection Systems for Occupied buildings


Recommendation Review the gas detection systems associated with HVAC systems.

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

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

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

Examples Olefin plant control room.

12-08 Inspection of Fire Protection Equipment


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

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

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

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

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

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12-09 Testing of fire fighting Foam


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

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

Examples Fire fighting foam stocks.

3.2. Previous Recommendations

There have been a series of surveys of EPCL, dating back to the days when it was ownedand operated by NNPC. During these surveys numerous recommendations were made and,

during NNPC’s ownership, there was little improvement. The recommendations below werethose which were outstanding at the end of the 2011 survey.

Of the 24 recommendations in 2011:

6 are complete

11 are In progress

2 are withdrawn

5 are Unchanged

11-01 SIMOPS (Simultaneous Operations)

Category 3

Recommendation Develop a procedure to control simultaneous construction and operation within thesame area. The procedure should include, but not be limited to:

Ensuring adequate separation between construction and operational areas,including the installation of fences and emergency exits

A risk matrix to identify which construction/commissioning activities can be safetyundertaken concurrently with operational activities.

Communication between operating and construction personnel in areas such as:

o Hot work

o Emergency response

A good description of SIMOPS activities at an onsite location is available from:

http://www.onepetro.org/mslib/servlet/onepetropreview?id=IPTC-13705-MS&soc=IPTCReason Construction and commissioning activities can lead to hazardous situations, which,

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

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

There are some areas within the existing facilities where SIMOPS is currentlyapplicable, for example in the construction work being undertaken in the PE plant.Where a portable concrete mixer with an internal combustion engine was in use. Thisappeared to be close to or within an electrically classified area with no evidence of ahot work permit.

EPCL Post SurveyComment 2011

Procedure is under development, implementation by September 2011.

Status October

2012

It was not confirmed that this recommendation has been completed and it is

considered IN PROGRESS.With construction work due to start at the site in a few months’ time, it is important thatthis recommendation is completed without delay.

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11-02 Wafer Valves

Category 2

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

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

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

Examples A wafer type valve was identified in the piping around the 1-C-5 column in the Olefin

plant.


We are reviewing the status of long bolted valves along with designer specs. Appropriate action will be taken for fire protection based on it. October 2011.

Status October2012

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

The recommendation is COMPLETE.

Internal combustion driven concrete mixerclose to process area in PE plant

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11-03 Control of Maintenance

Category 3

Recommendation Conduct a fundamental review of the existing procedures for the control ofmaintenance to ensure compliance with existing good practice in the hydrocarbonprocessing industries.

The review should include a full assessment of all aspects of the maintenance

activities, including: The requirement for some form of risk assessment before the start of each activity

(standard procedures could be used for frequent activities).

Ensure that the job site is visited by operations and maintenance staff togetherprior to the issue of the permit and at the hand-back stage.

Limit the validity of the permit to a single shift, with a maximum period of 24 hourswith revalidation at each shift.

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

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

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

There should be separate folders for filing permits for completed work and permitsfor work that is continuing (even when the permit has expired).

Isolation and de-isolation of equipment, ideally using a Lock Out/Tag Out (LOTO)system.

The permit system should be regularly audited.

Guidance is available from a number of sources, including:

http://www.ogp.org.uk/pubs/189.pdf

http://www.hse.gov.uk/pubns/priced/hsg250.pdf

Reason There have been a number of recommendations relating to the permit to work systemand a fundamental review is considered desirable to ensure that safe workingprocedures continue to be to a high standard.

As EPCL have an ambitious expansion programme over the next few years, now isconsidered to be the ideal time to review the permit system.

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Examples A number of issues were identified during the survey:

There is no indication that each activity has some form of safety assessment orrisk review prior to work commencing (however standard risk assessments areavailable for some tasks).

Equipment for use for maintenance appeared unsuitable:

o Electrical cabling with taped connections in the PP plant

o Internal combustion engine driving a concrete mixer, possibly in anelectrically classified area, in the PE plant

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

No permits were displayed at jobsites.

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

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

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

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

Status October2012

This is COMPLETE, an example is shown below:

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11-04 Trip Bypass Procedure

Category 3

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

Trips which are bypassed for an extended period receive a higher level of scrutinythan trips bypassed for a short period of time. This is often achieved by requiringa higher level of authority to extend a bypass beyond a short period of time.Where bypasses are required to extend beyond a short period of, typically 24 – 48hours, a Management of Change procedure is followed.

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

The trip bypass authorization forms should be filed (with separate files forcompleted and active forms).

Regular auditing of the forms and bypass register should take place to ensure that

the procedure is being followed as required. If a trip bypass register, in addition to the forms, is to be used each trip should be

individually "signed off" and "signed back".

It may be appropriate to modify the existing procedure so that multiple trips, on asingle piece of equipment can be bypassed simultaneously when the equipment is outof service. However, the disabling and, especially, the establishment of each tripshould be noted individually.

A discussion of trip bypass procedures is given in:

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

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

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

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

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


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

Status October2012

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

The situation is UNCHANGED.

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11-05 Flange Systems

Category 3

Recommendation Review the current practices with regard to :

Provision of blinds (to ensure that only correctly rated blinds are installed).

Studs fully penetrated the nuts at both ends of a flange.

Specification of bolts and studs on stainless steel piping (to ensure that studs andbolts are to the same material as the flanges and piping).

The value of good bolting practices could be emphasised through training courses,toolbox talks, etc.

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

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

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

Studs which did not fully penetrate the nuts on either side of the flange werenoted in the offsites LPG pump area.

Very limited amounts of short bolting were noted in process areas.

Stainless piping and flanges with carbon steel bolting were noted in the olefinplant cold section.


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

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

Status October2012

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

11-06 Maintenance of Drains

Category 3

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

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

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

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

Examples A flooded drain was noted on the edge of the process area.

Channels to discharge LPG out of the storage area are partially blocked by earthand vegetation.


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

Status October2012

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

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11-07 Risk Based Inspection

Category 3

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

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

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


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

CTt Comment Trending of wall thickness reduction is only one aspect of RBI but a necessary one. An analysis of the consequences of failure is also necessary to help in focusinginspection efforts in the areas of greatest loss potential both in terms of frequency andmagnitude.The following references give a general overview of risk based inspectionprocedures:http://www.hse.gov.uk/research/crr_htm/2001/crr01363.htmhttp://www.dnv.com/binaries/13_paper_aem_%20paper_final_tcm4-367866.pdf

Status October2012

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

11-08 Corrosion Under Insulation

Category 3

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

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

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

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

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

Status October2012

Pulsed Eddy Current technology is being used to check for under insulation corrosion.Note that whilst this will work for many applications, there are some areas where it isunsuitable.

The recommendation is considered to be IN PROGRESS.

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11-09 Fireproofing

Category 2

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

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

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


We are reviewing it considering relevant API standard.

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

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

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

09-01 Sampling Procedures

Category 1

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

Vegetation growing inprocess piping

Refrigerated ethylene tankpipework with corrodedinsulation

Damagedfireproofingin theprocessarea

Damaged fireproofingin the process area

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the sampling procedure.

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

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

release of hydrocarbons. If ignited, a serious fire or explosion could occur. An exampleof this occurred at Feyzin in France in the 1960s(http://shippai.jst.go.jp/en/Detail?fn=2&id=CC1300001).

Where necessary, provide appropriate training.

Examples Liquefied gas sampling procedures in the olefins plant.


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

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

The recommendation is IN PROGRESS.

EPCL Post Survey

Comment 2011

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

Status October2012

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


09-02 Fire and Gas Alarm Systems

Category 1

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

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

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

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


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

phase wise. This would increase overall reliability.

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

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

The recommendation is considered to be In PROGRESS.


Being reviewed from time to time.

Status October2012

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

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09-03 Control Room Doors

Category 2

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

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

Examples All process control rooms.


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

Status May 2011 Control room doors in the PE and Olefin plant were in the open position during the

survey.There is NO CHANGE to the situation at the time of the previous survey.


Door closures are already installed. We will establish administrative control to ensuredoors are always closed.

Status October2012

The situation is UNCHANGED.

09-05 Document Control

Category 3

Recommendation Develop a document control procedure to ensure that:

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

Uncontrolled copies can be clearly identified.

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

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

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

Examples Currently the site P&IDs have been updated but the original "as built" drawings arethe ones available for reference in the plant control rooms.

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


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

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


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

Status October2012

Whilst there has been some progress, there are still areas for improvement. A new

recommendation, 12-03, on this topic has been made and this recommendation isWITHDRAWN.

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09-06 Operator Emergency Training

Category 3

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

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

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

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

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

Field operators should place tags on the valves they would operate to ensurethey know the correct location of the equipment.

Panel operators should list the actions they would take.

Field and panel operators actions can be checked and refresher trainingprovide if necessary.

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

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

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

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


This will be reviewed in plant level.

Status May 2011 Whilst emergency procedures have been revised and emergency shutdown training(classroom based) takes place, it does not follow the practices outlined above.

The recommendation is considered to IN PROGRESS.


This is an on-going process and being done from time to time.

Status October2012

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


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ARM Survey 2008

08-02 Analysis of Transformer Oil

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

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

Status June 2009 EPCL state that:

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

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

to be UNCHANGED.Status May 2011 Some limited new analysis has been performed but DGA is still not undertaken on a

regular basis.

The situation is UNCHANGED,


We do not have any gas in transformer. Oil quality checking procedure every sixmonths is established now.

CTt Comment It is not clear that the recommendation has been understood. DGA (Dissolved Gas Analysis) is a well-established technique to check for dissolved gas in transformers.Dissolved gases would be present as a consequence of a breakdown of the transformeroil and are indicative of impending failure.

An introduction to DGA can be found at:

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

Status October2012

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


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CTC 2006 Recommendations

06-01 Fire Detection/Protection Impairment System

Category 1

Recommendation Develop an Impairment programme so that equipment which is out of service or beingused for non-firefighting purposes is recorded and corrective action is taken as quicklyas possible.

Staff and contractors should be made aware of this requirement.

Reason Considerable effort and expense has gone in to the renovation of the site, including thefire detection and protection systems and whilst most equipment is in much bettercondition than at the start of 2006, there are many systems where repairs are not fullycomplete and there may be confusion over the operational status of equipment.

In addition fire water is still being used for cooling and other non-fire related purposes.

Finally, an up to date report with the status of all fire detection and protection systemswould be useful to insurance underwriters at the completion of TAM1 and the start-upof plants.

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

In addition a number of defects, which have not yet been repaired were noted, wherethese exist additional safety precautions will be necessary to ensure that safety of thefacilities are not compromised. These include:

One diesel fire pump is not operational.

Defects to the control system of a second system appear to exist.

The dry powder system protecting the catalyst area in the polypropylene plant is

not fully functional. The "trouble" alarm on the gas panel in the olefins plant is illuminating.

Status of fire detectors in the office block is uncertain.

This is probably not a complete list.

Status June 2009 EPCL State that:

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

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

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

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

Status October2012

Parts of the sprinkler system in the Polyethylene plant warehouse were isolated.These systems were not clearly marked and did not appear to be known to firefighters.

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

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06-03 Under Insulation Corrosion

Category 1

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

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

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


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

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

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


Action is initiated .

Status October2012

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

06-10 Management of Change

Category 3

Recommendation Review the management of change procedure to:

1. Provide clear guidance on the criteria by which changes are considered trivial andthose which require a more detailed safety assessment, including a HAZOP study. A sample checklist which may prove useful is given in Appendix C.

2. Update the procedure to include changes to staffing levels and job functions.Further information is given in Appendix D and a sample method of is given in:

http://213.212.77.20/research/crr_pdf/2001/crr01348.pdf

Reason 1. The lack of clear criteria to determine if detailed assessment is necessary couldresult in hazardous changes being approved without adequate assessment.

2. The lack of an assessment procedure for staffing changes could result in the

introduction of hazards in situations where staffing levels change, job descriptionsare altered, etc.

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


MOC system implemented. SOP available on the internet.

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

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


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

Status October2012 This is reported to be COMPLETE.

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06-11 Emergency Plan

Category 3

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

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

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

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

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

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

2. The current emergency plan is comprehensive but the information is not alwayseasily accessible. Key facts are hidden in complex paragraphs and may be

overlooked during an emergency when staff will be in a highly stressful situation.Greater use of bullet points, flow charts, and shorter paragraphs would assist andsome information aspects could perhaps be transferred to appendices.

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

Examples Site emergency plan.


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

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

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



Being reviewed from time to time.

Status October2012

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


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Recommendations Prior to 2005

No. Title Summary Status in 2006June2009 Status

(EPCL Comments) May 2011 StatusOctober 2012

Status

03.03 LiquidEthyleneStorageTank

Variousrepairs to theethylene tank.

IN PROGRESS

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

COMPLETED

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

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

EPCL Post SurveyComment 2011 - Weare reviewing theengineeringcompany.

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

bellows.The recommendationis IN PROGRESS

Piping Support with RodHanger Missing – the situationsince at least 2003

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Status

03.04 Use ofCellular

Telephones withintheProcessPlant

Use of mobilephones within

process plant.

NO CHANGE

Personnel using phones

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

Examples of mobilephone use in

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

There is NOCHANGE to theprevious situation.

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

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

The situation isunchanged from

2011, seniormanagement werenoted using cellular phones

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

The situation isUNCHANGED

98.01 RemoteOperatedIsolationValves

InstallRemotelyOperatedvalves forprocessisolation in

emergencysituations

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

installation

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

are vessels with largeinventories and noROVs installed.

Common criteria are:

5 m3

for LPGcontainingvessels

10 m3

for liquidhydrocarbons

The recommendationis IN PROGRESS.

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

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

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

98.03 Fire-waterPumps

Stopunauthorizeduse of firewater.

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

There is a project toinstall larger jockeypumps.


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

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

The recommendationIS IN PROGRESS.

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Status

96.13 HalonSystem

Status

Replace halonwith FM 200

NO CHANGE Preliminary work andtechnical discussion is

in progress. Would beimplemented in phasedmanner from 2010.

A programme forreplacement of the

Halon systems isunderway.


EPCL Post SurveyComment 2011 - Jobis in progress

Changeout of thehalon systems is

underway but notcomplete. Therecommendation isIN PROGRESS.