salient observations - pngrb.gov.in
TRANSCRIPT
1. City or Local Natural Gas Distribution Network
Salient Observations: -
Integrity assessment should be done for pipeline sections by proven technique.
In the SCADA system for CNG stations, Supervisory controls was not
established as only data acquisition was available.
Odorant was being batch dosed. Dosing quantity was not recorded and dosing
in ppm was not evaluated w.r.t regulation.
In CNG stations, door interlock for simulation of CO2 fire suppression system
inside compressor was kept in bypass mode.
All isolation valves were not covered in preventive maintenance plan
including its operational & functional checks and observation must be
recorded.
Non sparking tool were not used during maintenance and emergency.
Surge Diverter was not provided across Isolation Joint.
Periodic inspection of fire extinguisher was not done, safety seal and hose
found damaged at locations visited.
Compressor panel spare cable entry points were not plugged.
Salient Observations
Condition of rubber hose to the burners was found very bad and in brittle
condition. Also, observed validity of the rubber hose has expired.
Laid steel network at CGS including DRS - Material & NDT records were not
traceable to ascertain integrity of pipeline sections in conformity to design
standards.
Timely commissioning of permanent cathodic protection (PCP) in place of
temporary cathodic protection (TCP) Unit for protection of U/G Steel PL.
The grid resistance was different on different Plates.
N2 cylinder found in horizontal position in place of Vertical position in
Odourisation Unit.
Approach road from road to CGS station was not properly maintained.
No double earthing connection provided to various electrical equipment.
ERDMP Organogram with roles & responsibilities was not displayed at CNG
Station.
Hydro test plate on all the CNG Vehicles was not checked for validity of
Cylinders before filling gas
First Aid box not properly maintained.
Emergency numbers were not getting displayed on DRS.
Safety manuals and operating manuals were not reviewed periodically.
In the Electrical Room, Insulation Mats are in damaged condition.
List of Authorised personnel for operating Electrical Panel was not displayed.
Identification mark for U/G Valve chamber not available.
House-keeping of MRS of some of Industrial Customers was found poor.
Outlet pipe had been corroded.
Operation & Maintenance of CGD Network-Installation of Gas Detectors and
earthing of various equipment’s like compressors, DRS etc. not evident.
HSE Management System-Training programs did not cover contractors and
utility companies on hazards associated with leaks/damages.
Markers / Warning Signs were not installed in urban areas and industrial
parks.
Double earthing for lightening arrestor is not provided at CNG stations:
Storage cascade is not earthed.
Internal corrosion on steel pipeline was not done.
Industrial Consumers:
a) Fencing was not provided for IPRS installation.
b) Warning sign board was not provided.
c) Approval of IPRS installation by certified TPIA was not available.
Gas detectors were not provided inside DRS/IDRS / CGSinstallations
Off potential measurement was not taken once in a year for steel pipeline
Valves were not be placed at an interval of 1 Km for PE pipe
Gas Detectors, Flame Detectors and Carbon-di-oxide flooding system
installed in the CNG Compressors at Mother Station were not in working
condition.
Internal Audit observations of internal audit were not closed.
Air Compressor rooms within Fenced area of CGS’s, and other electrical
fittings were with Non FLP equipment and accessories.
Original Pipe Book pertaining to the commissioning of GA’s was not
available.
For domestic connections, in buildings, Secondary pressure of approx. 4 bar
is taken upto the building, UG, and crimped to risers upto the regulator
reducing pressure from 4 bar to 21 mbar with no regulator inside the customer
premises.
Boundary walls at all location not as per MHA guidelines
Emergency Control Rooms are not identified in the installations.
At domestic connections wrinkles observed in the bend area of copper tubing.
Copper tube to be checked after commissioning at bend area.
For all underground DRS/DPRS, Gauges and other safety instruments
calibration plan not available, also not calibrated as per frequency since long
time
Neutralization Kit is incomplete
SOP for Odorization Unit, Do’s and Don’ts at Odorization Unit was not
displayed.
PPEs were not available at all odorant unit as per PNGRB T4S Requirements.
High Consequential Areas of various GAs were not identified location wises.
Most of the MDPE Valve Chamber observed without any Tagging on it. Valve
Chamber tagging to be done as GIS Mapping and Final As-Built Drawing.
Formats used by vendors for records, did not carry any evidence of approval
/ consent of client.
Contrcators were carrying out erection work, without approved ITP/QAP,
erection, welding, testing, commissioning procedures.
Welders deployed by vendors in CGD Pipelines, are having cards in which
details like position, diameter, procedure, welding parameters used during
their qualification, were missing.
Pneumatic Testing of RF pads was generally not specified in drawings and
also not in procedures, which should be tested to ensure leak-proof sound
material below RF Pad Plates at branch locations.
No emergency exit was observed in administrative building.
On hydro test reports conclusion like (Accepted / Not Accepted / Ok / Not Ok
/ Satisfactory) were not mentioned.
Awareness among management, employees and customers regarding PNGRB
IMS regulation was not adequate.
Statutory permissions documents for laying and operations were not provided
for review.
As built alignment drawings were not available & piping layout drawings are
not revised as per onsite modifications.
Internal audit mechanism to ensure continual improvement was not properly
addressed.
Consequence, Impact Analysis and Identification of High Consequence Area
(HCA) were not been addressed. Quantification of risk was not done with
respect to above.
Proper maintenance of API 6D/ API 600 Gate/ Ball/ Plug valves was not
carried out.
2. Natural Gas Pipelines
Salient Observations: -
Pigging in some of the pipelines was not done due to operating at low
pressure.
Construction related documents were not available.
Passing of the first and last station valve i.e. valve was observed on scrapper
barrel.
Road around the facilities was not available especially at old locations Non-
availability of.
Continuity of flanges was not maintained.
The minimum distance of 5 meter was not maintained from boundary wall to
QOEC and scrapper barrel.
Painting of above ground piping was not done.
Point support for piping should be rectified.
LEL detectors were not provided at IP stations and terminals.
Thickness measuring locations on the piping and pressure vessels are not
marked and numbered
Preventive maintenance schedule followed by the bases was different from
the IMS Manual.
Gas leakage survey of underground pipelines was not carried out as per IMS
Manual.
Gas test results from all supplies were not available at the Master Control
Rom/ Bases. Major Criteria of H2S and moisture control should be monitored.
Frequency of cleaning of filters was not documented and varies at bases.
Pipeline thickness for aboveground pipelines was carried out but co-relation
study with previous data was not done.
Earth cover monitoring records were not available across the river crossing.
Calibration due date found expired for Hand held gas detectors.
PPEs were not available.
CP monitoring records for cathodic protection was not made available.
Report on effect of interference of Pipelines on Pipelines and was not made
available.
3. Petroleum and Petroleum Products Pipelines
Salient Observations: -
Construction related documents were not available.
HCDs were not covering the entire area.
Pipe supports were not meeting the requirement of Cl.1.8.7 of the Regulation
The detail of dwelling unit or permanent structures was available for ROW
but not for 15M either side of the pipeline.
road around the facilities especially at old locations was not available.
Few valves at inlet manifold of booster pump house and pig launching valves
(HOV) are with welded ends in Pump Station
Miter bends were used at suction line of booster pump area in PL.
Test record for radiography, ultrasonic test or other applicable NDT methods
(as carried out before commissioning) was not available.
Hydro-test (as carried out before commissioning) report was not available.
Inter distance between Booster Pump Shed and Scrapper Launcher or
Receiver was not maintained as per PNGRB regulation.
No tag for identification on the JBs was provided. Middle JB, one no cable
entry was open/unplugged. One of the JB Cover was half closed.
All other Electrical Motors, MOVs in the same area power cables were
connected without any kind of straight through joint. The MOVs located were
hardly 350-400 Meter distance from Electrical Substation.
4. General Observations in NGPL/ PPPL
(i) T4S Audit/ IMS Audit: -
TCP should remain only for a period of 6 months or from the date of
commissioning, not later than that. in some cases. It has been found that the
TCP is continued even after more than 2 years
Corrosion coupons & corrosion probes to be installed for both piggable &
non-piggable pipelines.
Off PSP Readings to be taken on yearly basis as per NACE RP 0169.
Proper maintenance formats to be developed for monthly/ half-yearly/ yearly
maintenance of API 6D/ API 600 Gate/ Ball/ Plug Valves. Valve maintenance
is neglected.
Foot patrolling of mainline to be regularly carried in line with the regulations
Proper maintenance procedure to be developed for casing pipes to address the
issue of shorting of casing & carrier pipe
List of all types of crossings (railway/ road/ river) to be readily available,
indicating crossings by open cut method, if any
Perennial rivers should have motor operated valves in upstream &
downstream for quick isolation
Integrity of all insulating joints to be regularly checked. All IJs to have surge
diverters
There should a robust pipeline integrity plan for all liquid/ natural gas
pipelines for monitoring of health & integrity of pipelines
Design must be audited. It may give some takeaways for the future &
upcoming projects
For Piggable pipelines, Pig residue analysis to be carried out regularly and all
elements such as Fe, Fe2o3, Si, S, H2O, PH Value, SRB, Sulphates, Carbonates
etc., to be examined. the results to be analysed at station level to establish the
trend of internal corrosion
Line Data may be developed. It is a good tool to assess the Integrity of the
pipeline
In CGD Network it has been observed that CAT/ DVCG/ CIPS survey is not
done for assessing the health of the Coating & CP System – it is very essential.
SCADA system must be there for real time monitoring of operational
parameters. IN some CGD Network, SCADA is not available
Management of change procedure is not available in some locations; this is a
must to address any change either for by-passing the safety system or for
change in process line or process parameters
Dosing of Mercaptan should be automatic. In some CGD locations it was
found to be in manual mode
Third party mechanical damage & construction threat to be suitably addressed
Training for all CNG stations personnel to be ensured as per requirement for
safety and mock drill awareness.
All pressure vessels to be hydro tested as per schedule
Thickness measurement of above ground station pipes to be carried out
regularly
Calibration Kits to be procured for testing of UV flame detectors &
Hydrocarbon detectors
Surge analysis to be carried out at the design stage
Lock Out & Tag Out (LOTO) system not followed in electrical maintenance.
Illumination level to be checked regularly for adequacy
Pipeline integrity management system is not carried out properly by
considering all the factors such as CP/ PSP READINGS, CAT/DCVG/ CIPS
SURVEY reports, IPS Survey reports, PIG residue analysis, Soil resistivity,
coating resistivity, internal corrosion rate as per corrosion coupon & corrosion
probes/ low elevation area.
Odorization should be in Auto mode
Proper & regular maintenance/ upkeep of all the fire extinguishers to be
carried out. all fire extinguishers to be either wall mounted or placed on a
raised pedestal
Proper calibration of all pressure gauges to be carried out and calibration tags
to be provided on all the pressure gauges
All SOPs to be prepared and displayed at respective locations
Adequacy of Fire water calculations to be checked in line with the regulations
Earth pit resistance values (individual & grid) to be taken regularly and
displayed on the earth pit.
Pressure set point of the PSV at the SRB to be kept w.r.t. MOP
(ii) ERDMP Audit: -
Off-site mock drills were not carried out.
Mutual aid agreement was not available.
Mutual aid plan was not prepared.
Organogram did not include the name of the different co-ordinators.
Near miss incidents were not reported.
Key elements of QRA viz., Hazard distance, F-N curve, Societal risk etc., are
not covered.
Safety committee were not formed, particularly in CGD installations, safety
committee meeting were not carried out regularly.
ERV was not maintained properly.
Hazardous goods training of LCV driver was not carried out. Same may be
done by RTO recommended parties. Hazardous goods training of LCV driver
has not been carried out. Same may be done by RTO recommended parties.
Number of route markers were not in line with the PNGRB regulations.
Safety awareness programs was not conducted
Hazard distance, individual risk & societal risk to be essentially covered in
the ERDMP & all scenarios to be covered
Emergency control centre to be maintained & one officer should man the
control room. Organogram, safety policy and list of important contact
numbers to be displayed.
Assembly point to be clearly displayed along with name of different teams
Hazop study & Risk Quantification were not certified by Third party.
Various leakage scenarios were not considered for emergency handling.
In case of actual leaks in pipeline, stopping the pipeline was delayed due to
absence of clarity in Control Rooms/ communication for Approval
(iii) Pipe book: -
Golden Joints data and its co-relation with hydro-test reports was not
checked.
Details of sections considered for hydro-test and pressure rating due to
elevation profile was not provided.
Arrangement for recording pressure/ temperature/time and P&ID/ Procedure
was not documented.
Hydro-test Results Manual & Recorded data was not matching.
(iv) Commissioning: -
Data of Gauge plate – Before & After Pigging was not maintained.
Cleaning data of p/l. No. of pigs/ pig cups/ Brush was not available.
Sludge Analysis of operating pipelines for Ferrous Oxide & Sulphides was
not done.
There were delays in commissioning & inertization of Pipeline.
(v) Operations & Maintenance: -
SOP for start/ stop/ normal/ emergency conditions were not properly recorded.
Alarms & Trip were not properly documented/ displayed.
Maintenance data in SAP was not matching with work permits.
Calibration certificates- No master calibrator data/ signatures/ dates/ actions
taken during calibration were not recorded.
Originals of work permits were not filed serially and few completion
certificates were not available
(vi) Intelligent Pigging: -
Normal pigging frequency was not followed.
Criterion for Dig verification was not included.
Analysis of IP Report/ fitness for use certification was not done through
External Agency.
Action Taken Report on repairs/ refurbishment was not recorded.
(vii) ROU: -
Data for acquisition/ laying permission for the entire length of pipeline was
not properly documented.
Encroachment data was not consolidated.
Certification by officer on line walking reports/ actions taken was not
recorded.
(viii) SCADA: -
Archiving philosophy & retrieval of data was not possible.
Leak Detection Philosophy was not displayed.
Annual Leak Detection Test was not done.
(ix) Cathodic Protection: -
Inadequate data in CAT Survey Report.
Actions Taken on DCVG Survey findings were not available.
Interference Survey was not carried out.
(x) Earthing System: -
Earthing Grid Drawing was not available.
Earthing Strips were not as per standard.
SLD as built was not available.
5. LNG facilities
Salient Observations: -
Ship-Shore compatibility checking was not done before ship arrival.
Unloading arm hook/emergency release Coupler fixing as per Standard SOP
Avoid Roll over during filling into LNG Tanks by density measurement
Emergency Shutdown System Checking before unloading for Jetty
Operations
Valve passing in the pig launcher/ receiver barrel
Piping external corrosion at locations of pipe support
Compliance of Statutory requirements
Incident reporting / Investigation/ Analysis/ Safety Interlocks
Hydro Carbon detections / calibrations
Signal of field gas detector not available in control room
Alternate communication for remote valve isolation in case of OFC Cable
snapping.
Process Hazard Analysis
Fire equipment facilities
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