P 105 Liquid Cryogenic C2 Transportation

P 105


Liquid Cryogenic  C2 Transportation

In 1991-92, I had the honor to execute the first double walled cryogenic Ethylene tank terminal facilities at Hazira. But in late 2013,PX IV at JMD was looking for cryogenic Ethylene availability for their compressor duty as refrigerant media and the PMT (Project management Team) and the concerned DECs  were going around without coming to any concrete methodology! Especially M/S Fluor HSE personnel were exploring the possibility of accommodating two horton spheres in the available cramped space. Specially C2 being one of the challenging cryogenic medium, the wall thickness for sphere was crazy and LEL distance was hitting the nearby sub-station in PX B/L. So the possibility of creating any storage at South corridor got ruled out.

Then only they posed the issue to my attention and also asked whether we can utilize ISO container to transport the C2 through National Hi-way and can we get PESO permission and licence for transportation ! As that was the time I used to give consultancy to the PESO department, I knew that methodology was not at all acceptable statutorily especially in Indian roads. When I ruled it out, people around criticized me and commented. Moreover, one set of team strongly vouched that we should bring the Cryogenic C2 from our Nagothane plant area only since it had the loading infrastructure already. No one was ready to look into the involved challenges:- involved transportation distance of 1000+ KMs. one way, involvement of two different state authorities enroute, number of toll posts, local political issues at Raigad District and availability of suitable transport media etc.
The specialist team of RTG discouraged me to consider Hazira facilities for sourcing cryogenic C2
because of cramped movement space at Hazira.  That made me to consider  DMD-Dahej as the probable sourcing point .As such VMD do not have cryogenic storage for ethylene at all.

As luck would have it, self & Sh.Samir Karnik  bumped on a LNG carrier parked at Dahej  main road opposite to DMD main gate. Seeing that , we jumped out of our car and got in touch with that truck driver to gather data about that vehicle &its specification etc.. He said that in India there are about 50-60 semi-trailers licensed by PESO for LNG movement across the country. He added that most of them are designed &fabricated indigenousky at IOC Workshop, Nashik. So our attention got shifted to Nashik. Meanwhile we thought it is better to seek the confidence of PESO department officials  for
going ahead with semi-trailer arrangement for cryogenic C2 transport in Indian roads, since there was no prior reference for that challenging service. In Jan.'15 I organised a presentation to the entire PESO department at Nagpur with our team .  I made sure that Reliance presentation address all aspects of safety assurance and the presentation went through very smooth ,more than anybody's expectation. Rather my team questioned me post meeting- sir, who is CCE in that gathering! The meeting went on for sharp 40 minutes and only 2 questions were tabled by authorities-1) considering the involved distance, with only day light driving, will consideration of one night halt enroute only be sufficient ? 2) in case of vacuum break in cryogenic tank , what will be the time estimate for the pressure build up to pop the safety relief valve?  Post meeting when I had a sitting with CCE- Mr.Thomas, he suggested to consider INOX favorably, since they had the experience to build Hydrogen containers for space crafts. That made my task even simpler.
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Key Aspects:-  Communication,  Conviction, Critical challenge, Faith, Incident analysis,
Leadership, Reputation, Technical issue

P 104 PESO consultancy

P  104


PESO Consultancy

Since 2008, Peso department found my knowledge and expertise in mastery in various  international safety codes and analysis of various  critical scenario, they started consulting me for various critical
situations. Especially Mr Yedla supported my views when it came to re-introduction of RIM seal fire protection for all class 'A' petroleum floating roof tanks that too especially with a single party specific model. Somehow officials in OISD were carried away with discounting to go with poly-urethane tubing  type sensing arrangement  and vouched only metallic insert wire approach. The beauty was that even the OEM was not claiming that this product is suitable for rim seal fire sensing! But OISD thrust  that on all end users by incorporating that requirement in OISD 118 in the year 2010.
That was the time the Peso department looked for my services to ensure verification of its absolute incorporation. During that phase two CCEs came in and they were looking for industry support  to
counter OISD's insistence on incorporating all their standards as part of Petroleum Rules/SMPV Act.
In 2013, OISD gave 84 recommendations to be introduced in Petroleum rules; that time CCOE Mr PC Srivastava called me to Nagpur to study and analyse the veracity of those recommendations. On detailed scrutiny, I found only 6 or 7 of them were worth consideration and the rest  will completely counter the existing statutory rules. With my practical experience and knowledge I could highlight the issue against each recommendation and the Department could effectively defend the existing rules and countered them. Fortunately ,since that was the Govt. transition stage, all those recommendations by OISD died a natural death. Thus the issue got resolved.

In the midst, as an echo of Jaipur fire accident, there was a proposal from central ministry to enhance the Green Belt from the present 50 M or the fencing around the licensed tankage premises to 250 M !
CCE convened a conference meeting of all petroleum installations stake holders at Nagpur to discuss and arrive at a workable resolution. That point arose, since presently all around any installation/manufacturing complex, mushrooming of several dwelling  take place and they fall within LEL limits of the said unit area.  When this point was tabled in that conference, every one present countered that how can they become responsible  for public dwelling increase and that should be the responsibility of Municipal Corporation/Town Panchayat and industry house cannot cater to free land control. Then this subject was posed to BARC and their legal department to study&advise. Anybody can guess its outcome. That only stopped that recommendation of increase in free space around installations.

The Department gained so much confidence on Reliance  Safety Practices and requested our COE-HSEE to give lectures to the Department officials. With the services of M/S TV Venkateswaran,Vivek Bichave and Prashanti Bhupathy, I led a team to Nagpur to conduct those classes. They conducted brief classes on Hazop study, LOPA and Risk Matrix and touched about various probable mitigation measures that can be implemented.to bring to ALARP level. That was a revelation to most of the Department officers who attended. They profusely thanked us for organizing such lectures to elaborate practical aspects of safety studies.

The department officers used to get in touch with me directly to seek reference of any installation  for any specific hydrocarbon product, availability of MSDS for some unique chemicals, capacity ratings that prevail in Indian sub continent, advice on some specialty chemicals transportation methodology etc. That led to the drafting  the specification for one of Reliance's challenging requirement at JMD!
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Key Aspects :- Faith, Human relations, Incident analysis,  Recognition,Technical issue, Team building, Reputation, 

P 103 Process Safety & Risk Assessment

P  103


Process Safety & Risk Assessment

In 2012/13, my focus got shifted from only fire fighting system for hydrocarbon industry to overall
Process Safety  & Risk Assessment. To start with  Sh.  Ravi Ramaswamy &Ms Prerna Jain , later with Mr  TV Venkateswaran and Ms  Prashanti Bhupathy, I started learning the fundamentals of hazop study, risk assessment , asset integrity check &quantitative risk analysis etc.

In India,in the absence of structured risk regulations, the process safety risk assessment is left to
individual company's own approach. Almost all manufacturing set-up and corresponding  detailed engineering consultants follow only Hazid and Hazop Study approach  and feel satisfied that they have rightly assessed the involved probable risks. They are not taking that forward to develop Risk Matrix or LOPA analysis! That reflects that they are not fully covering the SIS/SIL study and see the value of various mitigation measures implementation to attain ALARP level. As we all know safety has no limit, but how much we should address to have a safe & sustained operation of our installation?

As Reliance has grown to international status, the management has engaged  M/S Du Pont  and asked their experts to carry out various Systems&Process standards  for safe implementation, commissioning & sustained operation of the existing plants and new upcoming installations across the country.

As qualitative assessment alone are not the best mechanism for evaluating high consequence, low frequency incident events, QRA (Quantitative Risk Assessment) feature cropped-in to prevent occupational risks.   Reliance management viewed these requirement as an absolute necessity and formed two groups under the leadership of Mr  V V Surya Rao, who himself is a veteran in Safety. He had his industrial career beginning with M/S Shell and later operated as CEO of NOCIL, the first
petrochemical plant of India producing Ethylene & Propylene in 1960 s. He formulated  OMS-Operational Management System and S&OR- Safety&Operational Risks. That is the set-up,who are the custodians for Safety across Reliance manufacturing locations, exploration, cross-country pipelines & oil terminals/retail outlets.

The resultant benefits are:
As we have the world's largest hydrocarbon processing installation at Jamnagar and big petrochemical complex at Hazira, Dahej,Vadodhra & Nagothane, oil &gas exploration at Kakinada, effective risk management ensures:
Health,safety&well being of employees and surrounding population
Financial performance of the business protected
Reputation of the company & Social status enhancement reflecting in the eyes of regulators & share
holder confidence .
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Key  Aspects :-Reputation, Responsible

P 102 J3 Execution RPMG

 P 102

J3 Execution

Since I did not have any direct responsibility in project execution in J3, my role became more of auditor. As I did have ample free time, my job became multi-various instead of concentrating in one front.At the same time, since we had too many DECs to engineer the various plants under J3, a close coordination and constant check was needed on all of them.

In between there cropped up the need for PTA trucks to transfer PTA from Hazira to Silvaasa Polyester plant. As we had the services of PRS then in 2012,NirajAmbani requested him to continue.
Since PTA is powdery material, it called for top loading from chute hopper. There were no such vehicle in the market and Hazira did not have any chute hopper arrangement. There was another issue of timing! From the overall planning schedule,Silvaasa was supposed to receive PTA from DMD PTA plant 5&6 only , but they were getting delayed,whereas Silvaasa was getting ready for start-up.
Moreover, in the original design of Silvaasa , the concerned DEC  did not address the issue of PTA receipt from tilting semi trailer! People thought that they can get away with containers carrying filled one tonne bags. No one has forecast the need of quantity of one tonne bags and its transportation from Hazira to Silvaasa and unloading in silos.All these ended in a mess and myself and PRS had tough time in convincing the involved stake-holders that these call for specially designed vehicle with top loading and bottom discharge with tilt of container storage. Unfortunately this task did not come up at all and PRS died in Dec 2012! The project got wound up!

In parallel, there was major change in Reliance style of project execution. That was the time the Business Transformation Process was on  and in J3, company removed the sentimentality for a core
Project Management Consultant need and formed an internal PMT team to manage. Moreover, to utilize the advancement of software technology, every DEC was given a virtual B/L Co-ordinate to engineer and manage. That made a complete chaos, as nobody was responsible for ensuring proper
tie-ins at B/L co-ordinates! It took a long time to realize this error and lastly, they engaged M/S Bechtel to ensure these tie-in checks between all the plants in old refinery areas and in C2 complex; since M/S Fluor was overall responsible for entire Gasification complex- both in DTA and SEZ, they were asked to validate the same between themselves, M/S Linde ,Aker and other package vendors.

Reliance had big dream to practice M/S Fluor based Safety Practices in future plants at JMD and wanted to source entire set of their Standards and Specifications. When it came for HSE particularly
Safety and Safe Practices, we were asked to compare the existing Du Pont developed standards with that of Fluor. Myself and core CHSEE team got involved and studied each and every document given to us for scrutiny. Also M/S Fluor sponsored Mr Jani to review all our in-house prepared Loss Prevention Documentation (developed based on J1/J2 Bechtel issued documentation & referring updated codes).  I can proudly state that Mr Jani picked up some useful input data  to incorporate in their existing documentation. Regarding the overall study on Fluor Vs Du Pont based standards developed, less debated , it is better. Finally Reliance did not opt for any of Fluor's HSE Practices documentation at all.
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Key Aspects :- Conviction, Incident analysis, Planning, Reputation, Technical issue, Transfer