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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