report on 7 round of external safety audit of gail · esa of gail – vijaipur oisd:p&e...

Process and Engineering Group

ESA of GAIL – Vijaipur

OISD:P&E ESA-No/2017 – 2018 Issue date:17.10.2017

Report on External Safety Audit of GAIL – Vijaipur (12th September to 15th September, 2017)

of 20 Disclaimer: The observations made in this reports are based on checking of random sample and does not guarantee the intactness of complete system. The industries should consider this as guidelines and check for horizontal deployment wherever possible.

REPORT

ON

7th ROUND OF EXTERNAL SAFETY AUDIT OF GAIL – VIJAIPUR

(12TH September to 15th September, 2017)

AUDIT TEAM:

Shri K Anandarao, CGM-HSE, HPCL – Team Leader Shri P K Sarma, Additional Director (Process), OISD – Member Shri Ani Thomas, DGM-Projects, HPCL-MR – Member Shri Dharmvir- Additional Director (Engineering), OISD – Member Coordinator

Oil Industry Safety Directorate Government of India

Ministry of Petroleum & Natural Gas 8th Floor, OIDB Bhavan, Plot No. 2, Sector – 73, Noida – 201301 (U.P.)

Website: www.oisd.gov.in Tele: 0120-2593800, Fax: 0120-2593802

http://www.oisd.gov.in/






INTRODUCTION :

As intimated vide letter No. OISD/PS/ESA/GAIL-VIJAIPUR dated 5th September’ 2017 by Executive Director, OISD, Noida. 7th Round of External Safety Audit (ESA) of GAIL–Vijaipur was carried out during 12th September to 15th September 2017.

PREAMBLE :

A brief of Organisation is given as Annexure-I.

METHODOLOGY :

The audit team adopted the following strategy to cover all the areas, which were under the purview of the audit:

Field visits.

Discussions on safety issues, pending ESA recommendations with the concerned officers.

Inspection and review of records/documents.

Checks on systems and procedures.

Checking compliance of Safety Management System.

Conducting mock drill.

Sample checking of implementation of OISD standards.

Checking of statutory licenses/approvals.

Feed back to Management on concluding day highlighting areas of appreciation and suggesting areas of improvements.

PREVIOUS AUDITS AT A GLANCE :

AUDIT ESA

NO OF RECOMMENDATIONS 196

TOTAL NO OF RECOMMENDATIONS PENDING AS ON DATE 192

PERCENTAGE COMPLIANCE 98






OBSERVATIONS AND RECOMMENDATIONS:

Sr.No. OBSERVATIONS RECOMMENDATIONS

SAFETY MANAGEMENT SYSTEM:

1. Separate HAZOPs were available for LPG and C2/C3 units; but integrated HAZOP was not available.

Next HAZOP is due in 2018. Integrated HAZOP should be carried out for the entire installation.

2. 8 out of 91 HAZOP recommendations are pending.

Time bound schedule should be prepared for liquidating the balance HAZOP recommendations.

3. Safety Awareness Survey: During last Awareness Survey in 2015, Safety Awareness level among GAIL employee was ranked ‘Best’; however training was advised for contract workers.

Fresh Safety Awareness Survey should be undertaken through a reputed third party to assess the current level of Safety Awareness of the contract workers as well as own employees.

4. Latest Safety Manual was available in soft form only. Hard copy was not updated.

Updated Safety Manual should be made available in hard form also at Control Rooms, Fire station etc.

5. Accident investigation discussion of Non-reportable incidents in Management Safety Committee meeting was not being carried out.

Review and discussion of Non-reportable accidents in Management Safety Committee meeting should be put in practice.

6. Approved list of Authorised permit issuers & receivers was available.

System to be developed to ensure the competency of all issuers & receivers of the work permit system, particularly the fresh inclusions in the list.

7. Welfare facilities (e.g. Restrooms, toilets and dining place) provided for the TTL drivers were observed to be very good and well maintained. Such facilities for contract workmen / ladies at other locations were not observed.

Contract workers welfare measures such as restrooms, toilets and dining places at other strategic locations should be maintained as per the guidelines of OISD-GDN-207.







OCCUPATIONAL HEALTH CENTRE (OHC):

8. Medical examination of the employees is done annually but records were not maintained systematically.

Employee health record traceability to be improved. Segregated list of employee working in hazardous area to be prepared. Computerization of the Health records of all employees should be there for quick view.

9. Mapping of the age profile and chronic cases by OHC was not in practice.

Mapping of the age profile and chronic cases should be prepared and updated by OHC for presentation and review by top management.

10. Outcome of hygiene survey done through M/s SGS in 2013 was rated as “satisfactory”, which is not indicative of the actual position and required improvement (if any).

Next hygiene survey should be done with results under objective scale (e.g. %age, marks etc.) for correct assessment of the outcome.

FIRE AND SAFETY:

11. Plot plan of the installation was not displayed at Fire Station Control Room & Main Control Room.

Fire & Safety Control Room up gradation with digitized Plot plan of the Layout, indication of Manual Call Points (MCP) and Hot work locations on the Plot plan should be reviewed and implemented.

12. Fire water header in flare area was covered with grass & other vegetation at certain location posing threat of external corrosion.

Fire water header should be maintained free from grass & other vegetation and 300 mm pipe bottom clearance should be maintained.

13. Alternate escape route was not there for Fire & Safety office building (1st floor).

Alternate escape route should be provided for F&S department building floors.

LPG AND C2 / C3 PLANT:

14. Local Emergency Shut Down (ESD) switch of RG heater at C2/C3 plant

RG heater (ESD) switch should be re located beyond 15 meters from the







is located near the heater (about 8-10 Meters away).

heater in line with OISD-STD-111, Clause 11.4.

15. Close sampling system is provided for LPG, while for other HC sampling in the plant, open sampling is in practice.

Closed loop sample points should be provided for HC streams at plant as well as offsite locations.

16. Pressure of the hot water expansion vessel at LPG plant (train 11) is maintained by Natural Gas (NG); PSV vent is open to atmosphere.

Proposal for use of Nitrogen instead of Natural Gas (NG) as pressurizing fluid to be expedited for implementation.

17. Some of the OWS vent outlets inside plant area of LPG-Unit I (Train 11), LPG- Unit II (Train 12) & C2/C3 Unit are in close proximity of process equipment / structures and are not 3M above the nearest tallest structure within the radius of 15M in line with OISD-STD-109.

OWS vent height / orientation should be suitably modified in line with OISD-STD-109 (6.3.1).

LPG HORTON SPHERE:

18. Walkway at the top of the Horton sphere (A/B/C) is obstructed for free and safe movement due to presence of stacks of scaffolding pipes, grating material etc.

Walkway should be kept free for easy movement.

19. Open / close indication of the upstream plug valves of the Horton sphere PSVs are not clear.

Clear marking on the valve stem should be provided for displaying Open/ Close position.

20. Mercaptan evacuation from drum:- Electric cable from the power switch to the portable evacuation pump is quite long and lying loosely on the ground.

Electric cable should be laid & dressed properly using cable tray.







21. Scaffoldings erected at LPG Horton Sphere area had display board - ‘Fit for Use’ / ‘Not Fit for Use’ without certification (Green or Red tag) from the competent authority.

For easy understanding by general layman / workman, use of tags ‘Green – Fit-for-purpose’ or ‘Red-Unfit for purpose’ needs to be displayed prominently on the Scaffolding structures as certificate of its integrity inline with OISD-GDN-192.

NAPHTHA TANKS:

22. Bottom drain line of the tanks to OWS is provided with single valve.

Double valves should be provided on the tank bottom drain line.

23. Naphtha tanks are of fixed roof design; Nitrogen blanketing provision is provided. Floating roof tank is more desirable for Class ‘A’ product storage.

N2 blanketing system should be checked regularly to ensure no blockage in the supply line hindering free flow of N2. Use of flow indicating rota meter may be explored.

24. Valve manifold of Naphtha tanks are placed inside the dyke wall.

Valve manifold of Naphtha tanks should be kept outside the dyke wall as per MB Lal Committee recommendations.

LOADING BAYS (NAPHTHA , LPG, PROPANE, PENTANE):

25. Naphtha TL loading:- Top loading of Naphtha in TL is done. Overhead anchoring string directed across the TL is provided for fixing of safety belt / fall arrestor; But same is not in use.

Suitable fall arrestor system with longitudinal anchoring string (similar to the facility at the TL safety check post) should be provided at Naphtha loading bays.

26. LPG loading arm fitting to Tank lorry is of flange to flange fitting with nut/bolts. Average 80-90 Tank lorries are loaded daily.

OEM of the loading arm should be consulted and quick fitting break away coupling with isolation valve should be provided in the loading arms.

27. Excess Flow Check Valve (EFCV) is not provided on the LPG loading lines; Digital Control Valve (DCV) is

High flow rate value set for the Digital Control Valve (DCV) should be checked and kept below the design shut off value







provided upstream of the loading arm which gets closed in the event of MFM flow rate exceeding the high set values.

of EFCV applicable for the loading arm size.

28. Electrical continuity jumpers at few flanges in the Naphtha and LPG loading circuits were found missing / dislocated / damaged.

Missing / dislocated / damaged electrical continuity jumpers should be rectified. A system should be put in practice for periodic survey to check and rectify integrity of all continuity jumpers at loading / storage / plant and other applicable locations.

29. Protective girder provided at both sides of the Weigh bridge of Propane loading gantry is observed to be very short in height and provide inadequate protection to the TTL tyres.

Propane loading gantry’s weigh bridge girder height should be increased suitably similar to the weigh bridge of LPG loading gantry.

30. Ordinary paper with lamination is hung as “EXIT” display at number of points along the elevated platform of LPG Tank Wagon gantry.

Durable painting boards should be used for display of alert messages.

CONTROL ROOM SAFETY:

31. Control room operating personnel are not adequately conversant with the operating system of clean agent flooding system.

SOP for the clean agent flooding system is to be prominently displayed and operating personnel should be made fully aware of its operation.

ELECTRICAL SYSTEM:

32. No employee is having Supervisory License for working inside HT substation. As per the state government rules, it is mandatory to have at least one person with Supervisory License.

Action should be taken for compliance inline with CEA Safety Regulations 2010.







33. No manual switch is provided for emergency lighting in the control room.

Manual switch along with auto cut-in provision needs to be provided in control rooms for emergency lighting.

34. SOP for critical electrical emergency services for fault finding / trouble shooting is not available at substation.

SOPs for critical electrical emergency services should be developed and displayed in substation.

35. Checked battery banks and found ok. Fixtures not suitable for Gas group IIC.

All electrical equipment in the battery room shall be replaced with flameproof equipment suitable for Gas group IIC.

36. Illumination in unit areas is good; However, around the periphery roads and approach to Watch towers, illumination level was not adequate.

Illumination survey should be carried out and lux level should be maintained in line values recommended in OISD-RP-149.

37. Elevator test certificate was not renewed on annual basis (certified by PWD inspector).

Elevator test certificate should be renewed on annual basis.

38. Equipment as per area classification:- In general, the plant area instrument /electrical JBs and Fixtures are in excellent condition except some of the JBs in Pentene and Naphtha loading areas - not properly sealed, bolts are missing and cover not tightened properly to meet the conformity.

Integrity of FLP JBs in plant area to be ensured. System should be put in practice for periodic survey of all FLP JBs and fixtures at different locations of the installation.

GENERAL:

39. Identification markings of pipelines / valves, particularly at offsite locations were not available at certain locations.

Stencilling of pipelines / valves at all operating locations should be done for operational convenience.

40. Fittings of all utilities (Air, Water & Non-compatible end coupling for N2 hose







N2) at hose stations were same at flare area.

at utilities station should be used to avoid inadvertent use of N2 instead of other utilities (Air & Water).

41. Incident direction clock is placed beyond the battery limit main gate adjacent to the road going to left and is not a convenient guide in case one has to go straight or to the right.

Incident direction clock should be relocated suitably upstream of the entrance gate for enhanced effectiveness.

42. Fencing adjacent to the railway track (near the Fire service building) is provided on one side of the track only.

Fencing near the railway track should be provided at both sides at critical locations (e.g. adjacent to vehicular roads, road crossing etc.)

43. Accumulation of metal scrap pipes by the side of some of the roads and near fire water pump house area was observed.

Metal scrap accumulated beside roads and near fire water pump house area should be removed /stacked properly.

44. It has been observed that two speed limits are followed at GAIL– Vijaipur as follows:

For HMV - 20 kms/hr &

For LMV - 40 kms/ hr

GAIL-Vijaipur management may review for fixing a common speed limit for vehicle movement within the installation at 25 km per hour as per the OISD guidelines for traffic management.

45. The present Attendance Management System does not provide exact no. of person (Company employees plus contract workers) present at any instant inside the installation.

For better handling of emergency management, a system may be developed to ascertain number of employees inside the complex by integrating manual entry record at gate along with the digital records generated through Attendance Management System.

46. It has been observed during site visit that some of the contract workers were having gate passes without contractor’s name.

It should be ensured that all entries of the gate pass including contractor’s name are checked before issuing the gate pass.







47. Training: Feedback / test to assess understanding of the participants after a training session is not in practice.

A system of feedback or Pre & Post test of the trainees to be reviewed and put in practice to assess effectiveness of the training imparted.

48. Megaphone for communication was not used during mock drill.

Megaphone for communication should be used during emergency handling.

49. Cable entry to the Main Control Room was not sealed.

Sealing of Cable entry to the Main Control Room should be ensured.

50. Forced ventilation, single pass Once-through type air system was not provided in Gas Chromatography Room and Hydrocarbon Testing Room with 10-12 changes of whole air per hour (Cl. 6.0 of OISD-GDN-211).

Forced ventilation, single pass Once-through type air system should be provided in Gas Chromatography Room and Hydrocarbon Testing Room with 10-12 changes of whole air per hour (Cl. 6.0 of OISD-GDN-211).

51. Height of fume hood outlet duct was one meter from the terrace of the building.

Height of fume hood outlet duct should be above three meters from the terrace of the building.

MOCKDRILL

Refer Annexure II






Annexure I

1.0 Brief Description of GAIL, Vijaipur: GAIL (India) Limited is having its most valued installation at Vijaipur, Dist. GUNA of Madhya Pradesh. Vijaipur complex is the O&M Head Quarter of HVJ Natural Gas Transmission Pipeline (includes 6 compressor stations at different Locations, MCR station for monitoring pipeline health & hydraulics of natural gas), 2 gas processing units for Liquid Hydrocarbon production and 1 petrochemical complex for C2-C3 extraction. HVJ COMPRESSOR STATION: The Compressor Station at Vijaipur has been provided to boost the pressure of Natural Gas in order to overcome the frictional and other losses in the pipeline and also to meet the contractual requirement of minimum pressure of the consumers along the HVJ Pipeline, RLNG Pipeline from Dahej, Gujarat (known as DVPL) & VDPL (Vijaipur Dadri-Bawana Pipeline). (A) HVJ Compressors: - The Natural Gas is received from upstream (Khera Compressor

Station) through 36 inch dia HVJ pipeline at a flow rate of 27.5 to 28.5 MMSCMD (Million metric standard cubic meters per day) at a pressure of 40 to 60 kg/cm2. A Part of the gas, as received from Khera, goes to LPG Recovery Plant through 24 inch dia pipeline for extraction of Petroleum Products like Liquefied Petroleum Gas (LPG), Propane, Pentane and Special Boiling Point Solvent. For the balance gas from the Khera, the gas is further compressed by the Mainline Compressors (with 3 Running units & 2 Standby units) to the range of 85 to 90 kg/cm2 and is feed into the 30 inch diameter pipeline towards Auraiya, UP Sector. LEF compressor (in LPG Plant) compressed 2.0-2.5 MMSCMD of C2-C3 rich gas and connected to M/L compressor discharge at a pressure of 88-93kg/cm2g.

• After extraction of LPG, the lean gas is received in the Compressor Station through

two streams namely (i) HP (High Pressure) Stream with a normal flow rate of 300000 to 500000 SM3/hr at a pressure of 50 to 56 kg/cm2g; (ii) MP (Medium Pressure) stream with a normal flow rate of 140000 to 200000 SM3/hr. at a pressure of 41 to 46 kg/cm2g. (iii) Flow from LEF with a normal flow rate of 100000 to 120000 SM3/hr at a pressure of 85 to 92 kg/cm2.






• HP lean gas, as received from LPG Plant through 24 inch diameter pipeline, is directly diverted into the 36 inch dia pipeline to Dadri / DESU through the loop line called GREP pipeline.

• Part of MP lean gas is directly diverted to NFL at a pressure of 41-42.5 kg/cm2g,

and, rest MP lean gas diverted to Rajasthan sector through Branch line compressor for boosting up of pressure from 42 to 69 kg/cm2g.

• Flow from LEF Compressor is sent to the 30inch diameter pipe line towards UP

sector by connecting it to main line discharge header. (B) DVPL Compressors:- Under DVPL Project Phase-1, 3 nos. of booster compressors are

provided at Vijaipur for onward gas transmission through the existing 36 inch Vijaipur Dadri Loop Line, which is known as GREP pipeline. Regasified LNG received from M/s Petronet LNG limited at Dahej Terminal transported through 42inch pipeline upto Vijaipur plant called DVPL Pipeline. DVPL pipeline designed for a maximum possible flow rate of 23.9 MMSCMD to deliver pressure of 53 to 56 kg/cm2 at Vijaipur. At present DVPL pressure at Vijaipur is expected around 75-80 Kg/cm2 due to low flow requirements. After Filtration and metering RLNG is fed to DVPL compressors through Common Suction header of 30 inch size. However as per requirements RLNG and HP gas can be mixed to feed suction of DVPL Compressors. Gas received at suction header is compressed up to 92 kg/cm2 with the help of DVPL Compressors driven by Gas Turbines (with two running & one standby unit). Presently discharge from DVPL compressors are transmitted to downstream customers through a discharge header of 30 inch size to GREP line.

(C) VDBPL Compressor:- Under VDBPL Project, 3 nos. of booster compressors are

provided at Vijaipur for onward gas transmission through the 48 inch Vijaipur Dadri Bawana Line. Regasified LNG received from M/s Petronet LNG limited at Dahej Terminal is transported through 42 inch DVPL-1 and 48 inch DVPL-2 pipeline upto Vijaipur. DVPL-2 pipeline is designed for a maximum possible flow rate of 60 MMSCMD to deliver pressure of 53 to 56 kg/cm2 at Vijaipur. At present DVPL pressure at Vijaipur is expected around 75-80 Kg/cm2 due to low flow requirements. After Filtration and metering RLNG is fed to VDPL compressors through Common Suction header of 30 inch size. The RLNG gas is compressed upto the pressure of 92 kg/cm2 by Gas turbine compressors (with two running & one standby unit) and discharge is fed into 48 inch VDBPL line.






All the compressors are identical and designed to boost from a suction pressure of 62 Kg/Cm2 to discharge pressure of 99.93 Kg/Cm2.

LPG Recovery Plant and C2-C3 Petrochemical Complex: LPG Recovery Plant:

DESIGN 2 x 7.5 = 15 MMSCMD LPG (2 x 203,000) 406,000 MT / YR PROPANE (2 x 65,000) 130,000 MT / YR NAPHTHA 24,000 MT / YR PENTANE 42,000 MT / YR

Process description:

1. Removal of heavier hydrocarbons at V-101 Knock out drum. 2. Gas drying-

a) Moisture is removed in feed gas dryers using Mol sieves. b) Regeneration of Dryers: LEF overhead vapors heated in Vertical fired

heaters to a temperature of 280 C. 3. Filtration - of Gas for checking carryover of solid particles from the dryers. 4. High Pressure cooling - Cold streams of separators are utilized for heat exchange 5. High Pressure Separator - Majority of liquid (C4 and heavier) is separated at this

stage. 6. 2nd stage cooling - In expander compressor by isentropic expansion. 7. Low Pressure separator - Liquid generated as a result is separated here. 8. Vapours are used to condense LEF top vapours and then for further cooling in the

chiller. Liquids from both separators provide cold to the feed stream before further processing.

9. Gas Processing - Separator II vapours are compressed in Comp of Exp-Comp and then sent to Lean Gas Compressor.

10. Lean Gas Comp. first stage discharge at 45 Kg/cm2 is sent as MP Lean Gas. Remaining gas is further compressed to 55 Kg/cm2 & sent out as HP

11. Liquid Processing - Liquid from both the separators combine after chiller & sent to Light End Fractionator.

12. LEF Column: - Light Ends like C1, C2 and some C3 stripped off the top and the rest goes through the bottom.

13. Propane Column: - LEF bottom liquids is sent as feed to this column. 14. C3 recovered from the top and is sent to C3 storage.






15. LPG Column: - C3 column bottom forms the feed to this column. 16. The top product (LPG) & is sent to storage. 17. Naphtha column - LPG column bottom is further fractionated to produce Pentane

as top product and Naphtha as bottom product. C2-C3 Petrochemical complex:

UNIT CAPACITY

GSU (Gas Sweetening Unit) 21.12MMSCMD

GPU ( Gas Processing Unit) 21.72MMSCMD

IA ( Instrument Air ) 5000 NM3/HR X 3

PSA ( Nitrogen Plant) 700 NM3/HR X 3

DM ( De-mineralized water plant) 185 M3/HR X 2

Condensate Polishing Unit ( CPU) 125 M3/HR X 2

UTILITY BOILER 120 TPH @ 106 KG/CM2 510 C

HRSG 85 TPH X 3 @ 106 KG/CM2 510 C

COOLING TOWER 32000 M3/HR 8 CELL INDUCED DRAFT COUNTER CURRENT

GAS SWEETENING UNIT

• The main purpose of the gas sweetening unit is to sweeten the gas by removing the CO2 content in it, with suitable solvent.

• MDEA (Activated Methyl Di Ethanol Amine) as the solvent.






The process is divided into following sub sections:

Feed Gas Filtration Absorption Amine regeneration Amine Filtration system

GAS PROCESSING UNIT The main purpose of the Gas Processing Unit is to condense the available ethane, propane , butane , pentane and higher hydrocarbons in the sweetened natural gas coming from GSU and separate ethane and propane fractions from rest of the hydrocarbons and re inject them into the gas line going to Pata for further processing at Pata to make value added products. The process is divided into following subsections:

Feed Gas Compression Feed Gas drying & Dryer Regeneration Feed Gas chilling/separation Feed Gas expansion Demethanizer & Demethaniser Overhead Expander Prestripper & C2C3 Extraction Lean gas compression Residue gas compression Propane Refrigeration system

STORAGE FACILITIES

STORAGE LPG PROPANE PENTANE C2-C3

NAPHTHA/ NGL

NO. OF VESSELS 8 SPHERES

3 SPHERES

5 BULLETS

3 SPHERES

2 TANKS

CAPACITY 8*2500 M3 3*2500 M3 5*198 M3 3*1500 M3 2*1300 M3

LPG DESPATCH ROAD 5 PUMPS @ 80 M3/HR 8 BAYS

RAIL 4 PUMPS @ 300 M3/HR 80 BAYS






Process Flow diagram of LPG Plant






Process Flow diagram and Block Diagram of GSU and GPU of C2C3 Plant






Annexure II

MOCK DRILL REPORT Scenario: LPG leak at Top Flange & Fire of sphere no. 205 B. Activity Time 1) Fire call given by activating the manual call point (MC) No. 30 18.12 hrs. 2) 1st Fire Truck arrived at site 18.16 hrs. 3) Site in-charge Incident controller arrived at site 18.17 hrs. 4) Fire controller (GM-Fire Safety) arrived at site 18.17 hrs. 5) Fire Siren blown 18.18 hrs. 6) Incident Site Controller (Operations) arrived 18.19 hrs. 7) Stretcher brought 18.20 hrs. 8) F&S arrived with BA set 18.21 hrs. 9) Area power & Tower lights flickering 18.20 hrs. 10) 2 nos. of Fire Truck came at site 18.23 hrs. 11) 2 nos. of CISF reported 18.24 hrs. 12) Road barricading by CISF& DC reported 18.25 hrs. 13) Fire water stopped 18.30 hrs. 14) Dyke wall valve in close condition. ----- 15) All clear Sounded 18.30 hrs. 16) Mechanical fitters reported and climbed and attended leak arrest Observations:

1. Fire controller should wear Jacket for ease of Identification. 2. Use megaphone for communication. 3. Operating Personnel to accompany Mechanical fitters for identification of job to be done.

report on 7 round of external safety audit of gail · esa of gail – vijaipur oisd:p&e...

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