DEHN India
DEHN India
DEHN India
Date: 28.04.2020
DEHN INDIA PVT. LTD.
Plot No. 213, Sector - 7,
IMT Manesar, Gurugram 122050
(Haryana) India
To, TEL. +91 124 4007680
The Secretary FAX. +91 124 4007684
Petroleum and Natural Gas Regulatory Board e-mail: info@dehn.in
1st Floor, World Trade Centre, web: www.dehn.in
Babar Road, New Delhi - 110001
Subject: Comment on the draft regulation “Technical Standards and Specifications including Safety
Standards for Refineries and Gas Processing Plants Regulations, 2020”
Dear Sir,
This is with reference to the Public Notice dated 17.02.2020 & 02.03.2020 regarding the submission
of views/comments to the above-mentioned draft regulation.
We are pleased to submit our comments for your kind review and incorporate in the regulation.
We suggest for detailing of the lightning protection requirement considering human safety and
equipment protection during operation of plant. Following are our comments to be included in sub-
chapter.
i. A lightning strike is an electrical discharge between the cloud and the earth. It is a natural,
unpredictable phenomenon having independent current source. The lightning has number of
components such as lightning current, very high peak current, charges, specific energy with a
wave shape of 10/350 µs.
ii. The lightning current parameters playing a role in the integrity of an LPS are peak current I,
the charge Q, the specific energy W/R, the duration T, and the average steepness of the
current di/dt. With this form of discharge, very high current densities occur at the point of
impact. The high currents lead to heating and potential shifts along the discharge line. The
lightning current has electromagnetic effects. These can be galvanic, inductive or capacitive
coupling, conducted shock waves and electromagnetic pulse fields.
iii. A lightning strike can ignite an explosive atmosphere both through a direct impact and from
the effects of a further impact.
iv. In case of a direct lightning strike, the high currents along the lightning current path can heat
up these system parts, spray discharges can occur. Spark discharges or arcing are possible due
to potential differences to adjacent parts of the system. This will ignite explosive atmospheres.
And therefore, proper lightning protection system shall be provided.
5.8.13.2. Measures to reduce the negative effects of lightning
i. The lightning strike in potentially explosive areas must be prevented, otherwise the explosive
atmosphere will ignite. All parts of a system with potentially explosive atmosphere must be
protected with a lightning protection system to ensure human safety and minimum loss to
property and environment.
ii. In general, a lightning protection system shall be designed and installed minimum in LPL II as
per IEC 62305-2 for areas with risk of explosion. However, a detailed risk assessment according
to IEC 62305-2 shall recommend for higher/stricter values i.e. LPL I and accordingly LPL I to be
followed for designing LPS.
iii. The Lightning protection system must be planned and installed strictly according to method
and specification given in IEC 62305. A risk assessment according to IEC 62305 part 2 is
recommended for all cases.
iv. Lightning discharge paths must be designed in such a way that their heating or ignitable sparks
cannot become the ignition source of the dangerous explosive atmosphere.
v. When discharging lightning currents, flashovers should be avoided, especially in potentially
explosive areas of Zone 1/21 and 0/20. In order to achieve this, the discharge paths must be
in a sufficient safety distance from all parts of the system considering electrical separation
distance based on formula given in IEC 62305-3.
vi. All operational buildings like unit substation, unit control rooms, fire control rooms, ETP
buildings, administrative buildings etc. shall be protected against direct lightning and installed
with external LPS, designed in minimum LPL II or higher depending upon actual risk
assessment calculation.
vii. All critical and emergency equipment shall be provided with surge protection device as per
type classified in IEC 62305 part 4.
viii. All equipment signals related to electrical fault, tripped, alarms, indication, and malfunction
bring up in central control room or in DCS shall have surge protection device able to handle
10/350 lightning impulse current.
ix. All Intrinsically safe circuits/signals for process units, storage tanks etc. shall have PESO
approved surge protection device in the field in hazardous area and in the central control
room in safe area, strictly in accordance with IEC 60079 and IEC 62305.
x. Fire and Gas detection system and emergency shutdown system shall have surge protection
device to minimise the loss to life and property by ensuring maximum availability of fire
protection facilities.
xi. All emergency response system like Public Address system, CCTV surveillance, Access control
system etc. shall be protected with proper surge protection device able to handle 10/350
lightning impulse current.
xii. Storage tanks shall be protected against lightning using rolling sphere method and the
discharge paths must be in a sufficient safety distance from all parts of the system. The safety
distance shall be maintained in such a way that the system doesn’t hinder the movement or
limit the space available inside dyke area and doesn’t add up to any safety hazard due to non-
maintenance. This safety hazard can be avoided by using special cables tested as per IEC /TS
62561-Part 8 from a recognised international lab for compensating equivalent separation
distance while discharging 10/350 lightning impulse current of 150KA (level 2) or higher.
xiii. The installation of the Lightning protection system shall be done under close supervision of
the manufacturer of LPS components.
xiv. The plant/entity shall prepare report for approval for conformities to the requirements
mentioned in this regulation as per provided checklist as per annexure (attached) for ease of
planning and execution of the non-conformities/ protection measures.
Certificate Ref. No.:
2 BUILDING/STRUCTURE DETAILS
2.1. Name:
2.2. Location:
2.3. Dimension:
2.4. Type of Construction:
2.5. Roof type: Concrete/Metal
2.6 Roof shape: Flat/Pitched
3 PRE-REQUISITE OF TESTING/INSPECTION
3.1. Design & drawing of LPS as per IS/IEC 62305
3.2. Lightning protection standards: IS/IEC 62305
3.3. Class of LPS adopted:
4 INSPECTION/TESTING CRITERIA
External LPS Internal LPS
Page 1
4.2. Down Conductor system
4.2.1. Numbers: Min. distance btw DC is maintained
4.2.2. Material: Al/Cu/GI Type: Flat/round
Page 2
5.2. Testing of technical documentation:
5.2.1 Complete Incomplete
(Design criteria, design calculation, drawings, installation test report etc.)
6 TESTING AT SITE
6.1. External LPS:
6.1.1. Installation of all conductors and system components:
6.1.2. Installation and condition of the air-termination system:
6.1.3. Installation and condition of the down-conductors:
6.1.4. All earth connections:
6.1.5. Components affected by corrosion:
COMMENTS:
(Condition of down conductors, jointing
of down conductors, crossing of
electrical/metal lines, rust or corrosion,
hanging of down conductors, improper
termination, corroded earth electrode, no
earth pit chamber, no nameplate etc.)
7 MEASUREMENT:
7.1. Electrical conductivity of connections for lightning protection components
Sample #1 Yes No Value: ≤0.2 Ohm
Sample #2 Yes No Value: ≤0.2 Ohm
Sample #3 Yes No Value: ≤0.2 Ohm
Sample #4 Yes No Value: ≤0.2 Ohm
Sample #5 Yes No Value: ≤0.2 Ohm
Page 3
8 TEST/INSPECTION REPORT
8.1. The LPS has no defects Yes No
The test revealed the following defects
1 11
2 12
3 13
4 14
5 15
6 16
7 17
8 18
9 19
10 20
8.2. Details on administrative regulations
Page 4