TYSER RISK MANAGEMENT (Bangladesh) LIMITED RISK ENGINEERING REPORT NORTH WEST POWER GENERATION COMPANY LIMITED 225 MW Combined Cycle Power Plant Unit – II Sirajganj Bangladesh June 2020 Prepared For Tysers, UK 1 TYSER RISK MANAGEMENT (Bangladesh) LIMITED By appointment and instruction of Tysers, UK, a Risk Engineering Survey of 225 MW Combined Cycle Power Plant Unit – II, North West Power Generation Company Limited located at Sirajganj, Bangladesh was carried out on 16th June 2020 by Tyser Risk Management (Bangladesh) Limited. Enclosed please find the report. This is a Confidential Report, and as such, all parties in receipt of this report are requested to maintain confidentiality of its contents. It has been prepared for the Reinsurers for the specific purpose (outlined in the instruction referred to above) and should not be shown to, nor relied on by, any other party or for any other purpose. Tyser Risk Management (Bangladesh) Limited accepts no liability nor does it assume control over the original or subsequent copies. Reliance on Information Provided / Acceptance in Good Faith__________________________ This report has been prepared primarily from the information provided to the inspection team by the concerning authorities at site, and from whatever was apparent to the inspection team during physical inspection of the sites. Limit of Service__________________________________________________________________ All and any recommendation, advice, comment, or suggestion, whether verbally or formally presented in this report is based on information provided by the concerning authorities at site, from physical inspection of the site, and our experience and exposure to the hazard and credible risks associated with the process for which logical and economical resolutions can be incorporated within the system (process, design, instrument, and environment). It is explicitly understood by Tysers, North West Power Generation Power Company Ltd., its Reinsurers, associates, and all others that it is unrealistic and impossible to ascertain each and every hazard or risk present at any particular site or process. As such, Tyser Risk Management (Bangladesh) Limited does not certify that all credible or incredible risks have been assumed, considered, or incorporated in the report. Natural disasters (except Flood, Cyclone, and Earthquake) or “Acts of God”, or unforeseen “Acts of War”, and other extreme circumstances beyond human or economic control may not have been considered or expressed in the report. Any recommendation, advice, comment, or suggestion regarding any process, design, instrument, or environment shall be construed as a singular recommendation, advice, comment or suggestion for all processes, designs, instruments, and environments similar in nature and design present within the same compound or site. The physical inspection of the property and the recommendations herewith are purely advisory and are for the purpose of assisting the client to manage the risks that could or may affect its interests. Neither Tyser Risk Management (Bangladesh) Limited nor its employees, or associates, make any warranty, whether express or implied, concerning the content of the report submitted. Enclosed please find the Risk Engineering Report. For and on behalf of Tyser Risk Management (Bangladesh) Limited Riasat Farabi Manager, Technical riasatfarabi@trmbl.com HOUSE 80 (A-2) ROAD 07 BLOCK H BANANI DHAKA 1213 BANGLADESH PHONE: + (8802) 985 4291 FAX: +(8802) 985 1186, A CONCERN OF TYSERS, UK EMAIL: INFO@TRMBL.COM WEB: WWW.TRMBL.COM 2 ESTABLISHED IN 1820 TYSER RISK MANAGEMENT (Bangladesh) LIMITED Preface Tyser Risk Management (Bangladesh) Limited has been appointed by Tyser, UK for conducting a Risk Engineering Survey of 225 MW MW Combined Cycle Power Plant Unit – II, North West Power Generation Company Limited (NWPGCL Unit – II) at Sirajganj, Bangladesh. The initial risk engineering survey was th carried out previously by Tyser Risk Management (Bangladesh) Limited at 11 June 2018. This year, on 16th June 2020, Tyser Risk Management has done a follow-up Risk Engineering Survey of the facilities. It should be noted that the findings and recommendations of the study are based on physical survey of the site and the data provided by the plant authorities. Some of the information have also been used from the previous Risk Engineering Report. Tyser Risk Management has exercised all reasonable skill, care and diligence in carrying out the study. This report is not deemed to be any undertaking, warranty or certificate. 3 TYSER RISK MANAGEMENT (Bangladesh) LIMITED Recommendations for Risk Improvement Risk Improvement Recommendations The recommendations / suggestions for risk improvement presented here makes no claim for completeness or exhaustiveness. The recommendations presented here for minimizing potential losses that are based on brief general observations and discussions at the site. These are not the result of detailed engineering studies. The Insured remains fully responsible for compliance with all applicable laws and regulations. The recommendations are categorized in below given criteria: : Highest, for urgent consideration : Orange: Serious : Yellow: Relatively Important : Green: For prudent risk engineering practice : Blue: Complied per records Review of New Recommendations No Recommendation from 2018 2020-01 Acid Container need to be removed from battery bank room 2020-02 A Permanent Scrap Shed Need to be Built 2020-03 Automatic Fire Detection & Protection System, CCTV, Containment Bund need to be implemented in Chemical Storage of NWPGCL Unit II 2020-04 Automatic Fire Detection & Protection System, Aisle Marking need to be implemented in Storages of NWPGCL Unit II 4 Code TYSER RISK MANAGEMENT (Bangladesh) LIMITED Serial No. 2020-01 Recommendation Acid Container need to be removed from battery bank room: At the time of inspection, it was found that some of the acid containers are kept aside in the battery room. As all these batteries produces hydrogen all the time and hydrogen is a highly explosive gas so it is mandatory not to keep any chemical related substance in the room. So, it is recommend that those should be removed from battery bank room & place it in the chemical store. 2020-02 A Permanent Scrap Shed Need to be Built: During site survey, it was noticed there was a temporary place for keeping corrosion inhibitor bottles which has kept at open space. As the plant will continue its operation, more scraps will be formed and for that the plant should build a proper designated scrapyard to dispose those in proper and safe manner. So, it is recommended that they should build a permanent scrap shed soon. 5 Code TYSER RISK MANAGEMENT (Bangladesh) LIMITED 2020-03 Automatic Fire Detection & Protection System, CCTV, Containment Bund need to be implemented in Chemical Storage of NWPGCL Unit II During inspection, it has been observed that a new chemical storage has been built for NWPGCL Unit II. At this chemical store, huge quantity of important chemicals have been stored without keeping proper safety measures. It is strongly recommended to install automatic fire detection and protection system as per NFPA guideline at chemical storages along with CCTV and most important to keep these chemicals within separated Containment Bund. 2020-04 Automatic Fire Detection & Protection System, Aisle Marking need to be implemented in Storages of NWPGCL Unit II At the time of inspection, it has been observed that in storage, there are huge quantity of electrical and mechanical materials has been stored without keeping proper safety measures. It is strongly recommended to install automatic fire detection and protection system as per NFPA guideline at storages along with CCTV and aisle marking. 6 TYSER RISK MANAGEMENT (Bangladesh) LIMITED Review of Previous Recommendations SL. NO. Recommendation from 2018 Status 2018-01 Electrical Earthing Continuity Test timing should be changed Complied 2018-02 Pipe line color codes should be maintained throughout plant In Progress 2018-03 Fire pump maintenance need to done as per NFPA 25 guidelines In Progress 2018-04 Safety Audit by third party should be carried out 2018-05 In Progress 2018-06 Overall housekeeping needs improvement. All the exit signs should be operational. 2018-07 Plant condition monitoring needs expansion In Progress 2018-08 Battery room exhaust fan need to be operational 24/7. Complied 2018-09 Plant Procedure Complied 2018-10 Detector maintenance procedure need to improve Complied 7 Complied Complied Code TYSER RISK MANAGEMENT (Bangladesh) LIMITED Serial No. Recommendation Status on June 2020 201801 Electrical Earthing Continuity Test timing should be changed: It was noted that the electrical earthing continuity tests are scheduled once for the winter season in Bangladesh, i.e. December/January. It is recommended that, either two tests are carried out each year, or if one test is to be carried out then it must be within the hottest and wettest months of the year (typically June/July in Bangladesh). Complied: NWPGCL Unit II had already changed schedule for their electrical Earthing Continuity Test on hottest season. Latest report has been attached with the report. 201802 Pipe line color codes should be maintained throughout plant: During inspection it was observed that appropriate color codes had not been maintained for the pipelines. It is recommended the plant confirms to an international standard, such as the ANSI A13.1 for pipeline color coding. 201803 Fire pump maintenance need to be done as per NFPA 25 guidelines: At the time of inspection it was informed by the plant personnel that all the fire pumps are being inspected and maintained regularly, however not as per any particular maintenance standard. It is recommended that the inspection and testing is carried out as per NFPA – 25 (Edition 2011, Chapter – 8, or latest) guidelines. Annual flow test and churn test for various FW pumps should be conducted. Corrective steps should be taken for those pumps showing more than 10% drop in design performance. Fire pumps are safety critical equipment. It is accepted practice throughout the industry to periodically recheck fire pump operating curves by carrying out a detailed pump head vs' design capacity check (3 points: zero flow, design rated flow, 150% of the design rated flow. once per year). In this respect, NFPA 25 (section 5-3.3.1) provides an accepted fire protection guideline. The resulting flow pressure (capacity-head) curve should be compared to the vendor supplied pump performance curve in order to facilitate detection of deterioration in impeller or driver performance that could reduce firewater supply effectiveness under emergency conditions. In Progress: NWPGCL Unit II has already prepared a color coding board, which they will be implemented throughout the pant. Already 80% work has been done. Some of the tanks remained. Hopefully they completed it by end of this year. In Progress: 8 NWPGCL Unit II already started working on it. At present procurement of the flow meter is hindered because of recent outbreak of Covid19. Code TYSER RISK MANAGEMENT (Bangladesh) LIMITED 201804 Safety Audit by third party should be carried out: 201805 Overall housekeeping needs improvement: Audit is an essential part of any safety management system. Although, internal audit is carried out in scheduled interval, a third party external audit is required to ensure the quality of internal audits. In addition, detail audit to ensure the safety management system is working properly is required by external third party auditors. Therefore, it is recommended that NWPGCL arranges safety audit by third party at least once every three year interval. While the overall housekeeping condition of NWPGCL – Sirajganj Unit - II is satisfactory (Still lots of construction is going on for unit 3 & 4), there is however room for improvement. Several waste items from plant installation and commissioning still remains within the plant area. These should be removed as soon as possible, and definitely prior to onset of the next cyclone season (March-April). The housekeeping philosophy the plant should observe is – Complied: It was informed by the plant personnel that lenders of the project have a strong monitoring on EHS aspect. AECOM India, MIGA performed EHS audit at regular interval. Besides local consultant /auditors (EQMS) also performed routine audit and related reported has been attached with this report. In progress: During the site visit lots of improvement seen regarding housekeeping in NWPGCL Unit II. But still there are lot of scope for improvement. As some of the scrap found outside in appropriate places. “A designated place for everything, and everything in its designated place” 201806 All the exit signs should be operational: Complied: During inspection all the The number of Exit Signs in the plant was adequate. At the exit signs seemed to be time of inspection most of the exit signs were not in operational. operation. The plant management informed that as these Exit signs are under maintenance, that’s why these signs are not working. It is highly recommended to make sure that all these Exit Signs are working and they are operational 24/7. 201807 Plant Conditioning Monitoring Needs expansion : The Plant Condition Monitoring system is partially in place e.g. periodic lube oil testing of HFO engines, but other testing e.g. thermography for plant equipment and electric switchgear, MCC etc.), transformers commissioning test record was not readily available which should form a baseline data for the periodic inspection and testing of the transformer and its oil. 9 In Progress: HSD oil sample test, DGA, Furan test has already done by NWPGCL Unit II. Other test procedures are to be done within August 2020. TYSER RISK MANAGEMENT (Bangladesh) LIMITED A complete Condition Monitoring Plan should be developed at the earliest and a base line data recorded. A trend analysis of all tests results and data recorded be undertaken as this would greatly help in predicting the condition and will enable the insured to take preventive measures before occurrence of a breakdown. Following equipment and data monitoring should be covered: Vibration Measurement and Analysis (Rotary & Reciprocating Equipment) Oil Condition and Wear Debris Analysis (Rotary & Reciprocating Equipment) Transformer and Transformer oil tests (DGA and Furan test). Thermography (covering steam & exhaust gas piping and switchgear system) Corrosion Monitoring (CP, NDT, thickness testing) Performance trending of major equipment (Design vs. Actual output) 201808 Battery room exhaust fan need to be operational 24/7: Complied During inspection battery bank exhaust fan found in At the time of inspection it was found that the exhaust fan in operational. the battery room is not working. As all these batteries produces hydrogen all the time and hydrogen is a highly explosive gas so it is mandatory to run the exhaust fan 24/7. It will make sure that all the hydrogen will be removed from that room and hydrogen will go to atmosphere. 201809 Plant Procedure: The plant operating & HSE procedures should be developed in a manner that these become specific to a NWPGCL plant. A list of procedures be first developed and then a monthly schedule of progress be prepared targeting for completion of procedures by end 2019. The following procedures should also be developed and implemented: 1.Emergency Response Procedure A comprehensive procedure should be developed after conducting a detailed Impact Assessment (IA), under various possible scenarios, targeting for availability and implementation by early 2020. 2.Fire System Impairment Procedure During the operating period there will be occasions when isolation of the Fire detection or suppression system for an 10 Complied: NWPGCL Unit II has already prepared Emergency Response Procedure, Fire System Impairment Procedure, Oil Spill handling procedure, .MOC Procedure. TYSER RISK MANAGEMENT (Bangladesh) LIMITED area is required, for routine maintenance or rectification work. Only authorized personnel should be assigned the task of controlling the fire system impairment and the work should be managed in such a way so as to be completed in shortest possible time. The procedure should cover different areas and equipment type, clearly listing alternate arrangements to be made for fire surveillance / extinguishing. A format should be part of the procedure giving details of the fire system impairment, actions required and approvals, it should be signed-off subsequent to normalisation of the system. 3.Oil Spill handling procedure In view of large quantity of fuel oil being handled and stored at NWPGCL, a specific procedure titled “Oil Spill handling Procedure” should be developed. Depending upon the scenario, the procedure may be classified into three Tiers as shown below: Tier-1---A small spill. Tier-2---A medium spill, such as from storage tank leakage incidents or bursting of a pipeline in / around tank farm or during fuel unloading from sea tanker. Tier-3--A large spill, bursting of bulk tank or day tank or any other accident, where substantial outside resources will be required The procedure should include equipment and material required for handling Tier-1 and 2 level incidents and training of staff. In order to avoid accidental spillage, it is prudent that unloading instructions be displayed in Bangla language at the un-loading bay for clear understanding of all involved. 4.ESD Trip Bypass Procedure It is to be realized that situations may arise where the ESD /Trip system has to be overridden or bypassed mainly due to faulty instruments; however it is imperative that the overridden ESD or Trip system is normalized in shortest possible time. In the interim period specific instructions should be available for monitoring of the relevant areas and actions to be taken to address a resultant emergency situation to avoid a mishap. 5.MOC Procedure NWPGCL should develop a comprehensive MOC procedure for the Plant carrying full details of the Changes in plant design, control system settings, documents and operating procedures. Requirement of PHA techniques i.e. Hazard Identification (HAZID), Hazard Analysis (HAZAN), Hazard and Operability Studies (HAZOP). The procedure should depict BRPL plant manager and higher management’s formal approval based on the nature of the change for any changes 11 Oil Spill pipe line For ESD Trip Bypass procedure the plant personnel informed through e-mail: “We do not bypass ESD system. So it was a question from your side if any fault in any instrument happens, how to mitigate the issue. I cannot share full details. But in brief, let’s assume one core turbine bearing temp thermocouple, which uses 3 different channels. If one channel gets faulty/deviates from the values from others, it gives an alarm. If more than one channel gets faulty, it goes to Trip automatically. Second, We have different access modes to the logic architecture of application server. Any change in logic diagrams for overriding need to be performed by OEM people (Either from Remote monitoring or from site). We do not have access for overriding ESD. (like TYSER RISK MANAGEMENT (Bangladesh) LIMITED to important operating parameters and any change plant converting 2-out-of-3 to design aspects. A complete record in an easily accessible 1-out-of-3).” format should be available at the plant. 2018- Detector Maintenance procedure need to improve: 10 At the time of inspection it has been observed that smoke and heat detector check-up and maintenance schedule is in place. These detectors has been checked yearly and found satisfactory. The plant personnel use jute smoke to find out whether these smoke detectors are working or not. To find out whether the heat detectors are in working condition the personnel use heat gun to generate heat. • Smoke detectors need to be checked by sample gas (Aerosol type) found in fire-fighting accessories shop, also the response time need to be noted. • Smoke detector batteries (if there is any) need to replace after every 6 months. • Any smoke/ heat detector need to be replaced after every 10 years of use. • Heat detector’s response time need to be noted as well as the set point should be noted. 12 Complied Smoke detection system has been checked through Aerosol type gas and heat detection has been inspected through heat gun.