Indorama Eleme Petrochemicals Limited (RC 121777) Eleme Petrochemicals Complex, Eleme, P.M.B.

5151 Port Harcourt, Rivers State, Nigeria 19.02.2013

Chief Inspector of Factories Directorate of Factories Rivers state, Port Harcourt Nigeria Dear Sir, Seasons greetings! Kindly recall your last extension granted to us for the exemption from examination/ testing of some of our equipment on 08th June 2011. You would appreciate; IEPL is contributing significantly in raising economy of Nigeria. High Production targets are being achieved by uninterrupted plant operation & as a result, shutting down the plant without an evident trouble, adversely affects the production targets. As a result, statutory testing of boilers & air receivers (listed below) as stipulated in Nigeria Factorys act, 1990 may not be possible to complete on due time this year. However, we are pleased to confirm that all other lifting equipment, lifting tools & tackles inspection has been certified on time by competent persons as authorized by directorate of Factories, Nigeria. It is worthwhile to mention, that EPCL had initiated & have regularly been organizing testing/certification of lifting tool / tackles, lifting equipment/cranes, fork lifts, air receivers & steam boilers. You would appreciate, that these jobs were not taken up earlier by NNPC so regularly; however, Indorama could streamline these inspections/certifications by doing many adjustments in our production targets. At Indorama, where we give safety an apex priority, we had taken up all the above difficult tasks & completed successfully in the stipulated time frame. Never the less, we would always appreciate your able guidance from time to time to carry forward the above tasks. However, for the test cycle of Boilers/ Air receivers currently due, we are finding it difficult to carry out as the plant is operating on full capacity. Inspection/certification may not be possible without boiler shut down.

A contract is already finalized with a competent & certified agency for inspection/ certification of boilers/air receivers, we will take a call to get testing/ certification done for these boilers, as soon as the plant is shut down and boilers/ air receivers are available for inspection. Until then, we need to keep the plant in operation on a continuous basis to sustain the production targets. We, therefore, request your kind favour for exemption of following equipment from testing for as per details given under:-

S/No

Equipment Name

Tag No 1-SG-1A 1-SG-1B 1-SG-1C

Due Date May, 2011 May, 2011 March, 2013 May, 2012 May, 2012 May, 2012 May, 2012

Exemption Requested. Dec 2013 Dec 2013 Dec 2013 Dec 2013

Duration as per Regulation (Months) 14

Boilers A-C

2 3 4 5

Furnace Steam Drums (Furnaces A - F) PQEs SQEs TQEs

1-D-4A-F 1-E-15A-F 1-E-16A-F 1-E-17A-B 24-D-4B 25-D-2A-B 6-D-606 3-D-1141 3-D-1151

Dec 2013 Dec 2013 Dec 2013 Dec Dec Dec Dec Dec 2013 2013 2013 2013 2013

26

Air Receivers

May, 2012

26

We shall highly appreciate your kind consideration and favour in this regard. Yours Sincerely

Kailash Pandey Head- Safety IEPL -PHC