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

P 101 35KL tanker contd.

P  101

35 KL tanker contd.

As mentioned in last post, since the fabrication of bottom loading facility was new in India, we had several issues with OPW supplied items/arrangement. Let us look at them as case history.
1. Vapor emission from tanker during loading: source was PVRV  and vapor dump valve not fully closing
2.  PVRV  O-ring and API adopter O-ring MOC ?
3. Improper switch setting of Air interlock valve
4. Overfill sensor failure
5.  Mating of vapor arm coupler with  vapor arm adopter of tank was a major issue !

There were other issues at Loading bay also  !
1. Liquid arm closure was not leak tight.
2.Thread worn out problem in coupling joints
3. Vapor coming out from vapor coupler joints.

All these issues were nightmare to PRS and me as we were from hydrocarbon processing industry by experience whereas all others could not realize the sensitivity of the situation. We both took up the issue  with Mr Somasundaram , VP of OPW HQ and ensured replacement/rectification of all these issues.  Here one particular point needs special mention. As far as MOC of O-rings were concerned, initially OPW did not realize that Viton will not withstand MTBE vapors ! Though the order spec. was particular to opt Buna seal, they failed to realize this fact; but once it came as an issue, they
specifically manufactured and replaced all the seals.

When everything was resolved, the resultant Benefits of these new 35KL  New generation Articulate trucks were:
a) Bottom loading facility ensure safe filling, less vapor loss, no static charge, clean environment from pollution angle
b)Vapor recovery system provision enhances safety
c) Overfill protection
d) Since all operating valves are pneumatically controlled, operation is efficient &safe
e) Emergency shutdown push button assures  safety while loading as well as unloading in truck.
f) Pneumatic operation of all valves assure better Reliability.

End Result    Reliance got  robust 35 Kl Bottom loading vehicles for transporting MTBE.
But unfortunately 3 of the stalwarts of the core team are not with us today to see the trucks operational.
M/S PRS,Viswanath rao, and Ilangovan died  natural death but at very young age. Our condolences in their Memoirs.

KeyAspects:- Communication, Critical challenge, Incident analysis, Responsible, Technical issue

P 100 35KL MTBE Vehicle Execution

P 100

35KL MTBE  Vehicle Execution

With open mind discussions by the identified task force, it was decided that we will go for semi-trailer using Tata  LPS 4923 TC BS III. M/S Tata as main contractor have given turn key responsibility to NSRR for design/sourcing of components including bottom loading special devices from M/SOPW- Dover Corp./fabrication /seeking final approval from PESO and roll out all the 35 vehicles in flat 4 months. PRS took the responsibility of fundamental as well as detailed design checks for the components as well as assembly. I took the responsibility for all concerned statutory clearances at each stage both from RTO and PESO Nagpur/Baroda office.
Sh Mahesh , MD of NSSR got carried out the load arrangement design/Center of gravity calculations etc. and got  reviewed by VJTI (Mumbai) , a statutory requirement for type test.

Mr Ilangovan used his power and ensured that Tata factory Jamshedpur deliver first 22 chasis in record time  of 22 days from the date of order. Mahesh used his resources and ensured the requisite plate material and structural members are made available immediately.

Then came the catch! As no fabrication shop in India has handled such a large simultaneous requirement, the shop front and man power got overawed with the situation. Typical of AR,
I took the management control in the shop and drove the work like a project driven.  Luckily, Mahesh has deployed his son Sh Ajay, a fresh engineering graduate then to carry out the detailed planning and deploy the  respective work men with back ground experience. Also, with his vision, he ensured to clear the bays for work progress in sequence.  These took about 6 weeks and the overall schedule was slipping. Added to injury, there were mess in two fronts from the sub suppliers- one was from York, a Tata group company itself for ABS system with brake assembly and the other was  the component quality of OPW-Dover supplied items. The specification called for Approved ABS with brake assembly and all bottom loading components including valves etc. to meet BVLR  Tank Truck as per API RP 1004.

When it came to York, their stores at Pune  had only 4 sets against the requirement of 35. When inquired they responded saying the main component has to be imported from Singapore and it may take more than 3 months time. As we were getting panicky over the situation, PRS found a resolution. He identified that TVS group in Chennai have equivalent model of ABS with brake assembly manufactured under brand name WAPCOS and it can serve the purpose. The technical experts from Tatas, PRS and Mahesh evaluated and interacted with that party to freeze that order.
When it came to OPW- Dover,issue was different! Though they supplied the components in time, the finish and quality / certification were in mess. Mr Ashish was helpless and tried his best  to shield his company's reputation only. The component  especially valve internal machining were coarse and they were not aligning in its position when assembled. As first step, we visited their factory at Poonamalle, in outskirts of Chennai to explore some solution but could not! That made me& PRS to escalate the matter to their HQ at Chicago.  Their VP,Mr Somasundaram understood the entire issue and started taking control.He has deployed personnel from Singapore and USA to look into the issues and sort out.                                                                                                                    Contd.......

Key Aspects :-  Codes& Standard,  Critical challenge,  Incident analysis, Initiative, Responsible,
Technical issue, 

P 99 RPMG Operations

P  99


RPMG Operations

 The entire project execution came under RPMG and the original core discipline heads were asked to only oversee the project progress.  That made me more relaxed and available for any special assignments. That was the time MTBE project was going on at Hazira and they were looking for specially designed transport vehicle for transferring the product to Kandla port for export. As MTBE being a class A product having pungent vapor, they wanted to opt for bottom loading type of vehicle.
Sh Niraj Ambani, who was in-charge for logistics requested me to explore special permission from PESO, the statutory authorities. It was mere coincidence that the government was also exploring to opt for larger capacity of vehicle for road transport movement for liquid hydrocarbon products.

Since I had excellent rapport with the PESO department, I took up the matter directly with CCE and explained the case to him. As he himself was a chemical engineer, he could visualize the specific requirement  but there was no precedence available for bottom loading type vehicles in India. So he put a precondition stating that this special vehicle has to be fabricated directly by the bottom loading component supplier only and not by anybody else.That was a fix since none of the supplier had any experience in complete design and fabrication aspect of hydrocarbon transport vehicle. As usual I discussed the issues with CCE and convinced him that we will go with only reputed fabricator but take the bottom loading component supplier in the loop during design stage . We sent words to many reputed fabricators as well as to chassis suppliers. Parties like Tata Motors, Ashok Leyland,Eicher  participated in technical discussions. In parallel, myself and Niraj worked with the government through our Delhi office to expedite the gazette release for 35 KT capacity transport vehicle.
During the bid stage, for one of the parties M/S NS Rama Rao Body builders , since their MD was not present in India, they have deputed their specialist consultant from Navi Mumbai to represent them and attend.  It so happened that it was Mr PR Srinivasan   ex- HPCL/BPCL, who had the experience of building one bottom loading arrangement vehicle abroad. That came as blessing in disguise for all.  Immediately it was decided that PRS shall be engaged by Reliance as  technical consultant and the entire project execution shall be executed under his supervision.
Then came another surprise! Mr Ilangovan of Tata Motors, who were called for only chassis supply, proposed  'why not we consider these as 'package deal' i.e the chassis supplier takes the total responsibility of sourcing all the requisite components from all approved sub-supplier, of course keeping Reliance technical team completely in the loop and fabricate all the vehicles by a reputed/ PESO  approved fabricator. Initially we thought Tata may look for high overheads as handling charge and overall responsibility! But surprisingly, they were looking for only Rs 40,000/- for a complete vehicle costing Rs 1.4 Crores each.Their idea was to productize  the same.
So it was win-win situation for all. A team consisting of PRS/Ilangovan/ Mahesh of NSRR/ Viswanatha Rao of logistics-Reliance/AR  was formed and order was placed on M/S Tata Motors for 35 vehicles. For bottom loading components , under recommendation of Reliance/PRS, Tata have placed order on M/S Dover India (subsidiary of Dover Corp. Chicago) and Sh Ashish Moghe was the responsible manager from that firm.  Regarding project execution, we shall address in next ......
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Key Aspects:- Incident analysis,  Technical issue,  Team building, Transfer