TO: SHELL PETROLEUM DEVELOPMENT COMPANY OF NIGERIA LTD. FROM: DATE: MAY 12, 2013.

SUBJECT: AIR POLLUTION CAUSED BY GAS FLARING. ____________________________________________________________________________ The effect of air pollution due to incomplete combustion of hydrocarbon gas on our environment cannot be underestimated. Therefore in pursuance of the corporate goal of health, safety and environment in SPDC operations, I hereby forward to you this proposal for your consideration on how to reduce the effect of the above mentioned subject in our environment, and also enhance production. Two factors are responsible for incomplete combustion in our flares: The ratio of oil to gas carried over to flare and the ration of air to gas supporting combustion. It should be noted that proper regulation of these factors will improve the quality of our flare, since the ratio of oil carried to flare is a function of the efficiency of our separators. It therefore means that a critical examination of our separation process will be helpful in this regard. Also, some factors that affect separation in flow station operation include unsteady pressure and temperature, underperformance of instrument and production equipments, poor maintenance, design and modifications. In what ways has these factors affected the quality of our separation? (1) Unsteady Pressure and Temperature. Studies revealed that pressure maintenance has not been steady in some flow stations due to header communication and poor well distribution. For example, if we have a low pressure as a result of header communication or poor well distribution, this could lead to liquid carry over to flare. And since temperature is not controlled pressure control now becomes critical. (2) Instrument and Production Equipments Performance. Performance of most of the instruments and pumps in the field is poor. For example controllers, dump valves etc. Most of the instruments have not been able to maintain proper level which is a critical factor in horizontal separators. (3) Separators. Our separators have no instrument to monitor the state of the internals for example, the mist extractor which is an important component in determining the size of droplets carried over to flare.

Having highlighted some of my observations, I hereby present the following recommendations: (1) A study group should be set up with production department to look into process related problems, with a view to identifying and solving them. Set operational standards for

each flow station and make recommendations to the appropriate line authority in view of the dynamic nature of the process. The group should include: The supervisor of the field to be studied and 3 others. (2) Each district should look into the problem of incorrect well distribution and header communication to ensure proper pressure maintenance. (3) Install differential pressure transmitter on all separators to monitor the state of the mist extractor at any point in time. (4) The old and poorly maintained controller and dump valves are not maintaining proper levels in the separators. These should be replaced with new ones or phased out where equipments spares can no more be procured. The same goes for pumps and other production equipments. (5) Production staff should be given more training on Process operating standards, Instrumentation and Troubleshooting techniques to enhance front line maintenance. In conclusion, the implementation of the above provides S.P.D.C the following benefits: (1) Reduction in environmental pollution and the attendants health Hazard, thereby making S.P.D.C foremost in the promotion of W.H.O. Health Policy on Environment. (2) Increase in oil recovery due to efficient separation. (3) Reduction in turbulent flow as a proper level maintenance.

Cc: PRDE/4 PRDE/1 PRDESS