rim seal fire protection fraud

Rim Seal Fire Protection System This slide presentation carries information about an irregularity committed while amending Oil Industry Safety Directorate (OISD) standards OISD 116 and 117. Information is intended for benefit of all stake holders involved in decisions pertaining to procurement of Automatic Rim Seal Fire Protection System for protection of Floating roof Tanks. Automatic Rim Seal Fire Protection System specified by OISD namely Hollow Metallic Tube Type Linear Heat Detection using foam based extinguishing media is not certified by UL/VdS/FM/LPCB for Rim Seal Fire Protection of Floating Roof Tanks. This irregularity will have far reaching implications that can result in procurement of unapproved Automatic rim Seal Fire Protection system and jeopardize safety of the oil installations.

In October 2009 a devastating fire destroyed IOCL depot in Jaipur. Government constituted a committee headed by M.B.Lal to enquire into the incident and suggest remedial measures to prevent re-occurrence. M.B.Lal committee recommended that all Floating Roof tanks shall be protected by an Automatic Rim Seal Fire Protection System.

The Rim Seal Fire Detection and Protection System shall be installed in all class A products in the terminal

Go to next slide to view the relevant document.

It is pertinent to note that the recommendation was generic in nature without reference to any particular type/make/model of the system that would encourage competition and provide flexibility in procurement for the benefit of the oil industry. At this point in time, applicable OISD standards for Automatic Rim Seal Fire Protection System were OISD 116 and OISD 117 2008 edition that recommended two types of system namely foam based with suitable detection and clean agent based with quartz bulb type detection.

Subsequently Petroleum Ministry set up a committee of Chairmen of IOCL BPCL and HPCL to revise OISD 116 and 117 2008 edition vide MoPNG circular No.R-21012/1/2008.OR-1 dated 26.10.2009. The motto behind setting up of the Chairmen committee was as follows.

In the 27th Meeting of the Safety council while deliberating on the subject of adoption of New Safety Standards, ratification of standards, amendments in OISD standards etc it was observed that the Safety Standards having far reaching implications should be thoroughly reviewed before it is put up to the larger Safety council for consideration. Accordingly, it has been decided to set up c committee of Chairmen of three oil marketing companies namely Indian oil corporation ltd, Bharat Petroleum Corporation Ltd and Hindustan Corporation Ltd and other concerned Chairmen for review and vetting of standards developed reviewed and amended by OISD……


The committee in their first meeting chaired by Chairman of IOCL was held on 26.11.2009 and concluded that

2.b ……Considering technical merits of such recommendation, three systems were proposed in these OISD standards viz Linear Heat Hollow Metallic Tube Type Detectors, fiber Optic Type (plastic shielding encased in SS tube) Linear Heat Detectors and Gaseous (Clean Agent) Flooding System. Polymer Tubing for detection in rim seal area shall not be used due to limitation like low life cycle, low durability, frequent maintenance and breakdown.

4.0 ….Director(R) BPCL informed that the Hollow Metallic Tube Type Detectors

provided at ONGC Uran is not functioning satisfactorily. It was suggested by CMD, BPCL for participation of CMD ONGC in the next meeting.


A second meeting was held on 4.5.2010 where it was concluded

3.2 CMD ONGC informed that the linear heat hollow metallic tube type detectors provided at ONGC Uran tanks for rim seal fire protection are functioning satisfactorily after carrying out initial maintenance

3.3 …As there was difference of opinion only from BPCL and IOCL (PL) w.r.t

detection tubing(metal vs polymer), technical evaluation was carried out by EIL for various types of detection system…

4.2.1 The robust and reliable linear heat hollow metallic tube type detector

system should be adopted for detection. The other two options such as fiber optics such as fiber optics (plastic shielding encased in SS tube)type Linear Heat Detectors for foam based system and fusible bulb detector on metallic piping and nozzle for gas based (clean agent) are also recommended for adoption.


Following recommendations were given by EIL referred in serial 3.3 aboveConclusion Based on the above the following system is to be considered in the amendments of OUISD 116 and 117 for use in rim seal fire protection and detection system 1. Foam flooding systema. Linear Heat Hollow Metallic Tube Type Detectorsb. Fiber Optic Type (plastic shielded encased in SS tube) Linear Heat Detector 2. Gaseous (Clean agent) Flooding systema. Fusible Bulb Detector cum nozzle All the above system shall have UL/FM/VdS/LPC approval/listing for the composite system.Polymer tubing for detection in the rim seal area is not recommended due to deficiencies observed.


It is important to note that EIL had very clearly recommended that all the systems shall have UL/FM/VdS/LPC approval / listing for the composite system. Hollow metallic tube type detection with foam media was not meeting this criteria, only the clean agent was meeting the criteria.

Information obtained from ONGC Uran through RTI reveals that hollow metallic tube type detectors had generated 44 false alarm and 10 fault alarms from 2005 to 2009. Leakages n the detection tubing and malfunctioning of the evaluation unit ADW were identified as the major causes.


It is clear that CMD ONGC misreported that linear heat detection system was functioning satisfactorily. Based on the incorrect feedback given by CMD ONGC the linear heat hollow metallic tube detector was considered for inclusion in the OISD 116 and 117 standards apart from clean agent system

After release of MOM of the second Chairmen committee meeting by Executive Director OISD vide letter EDS:CC-2 dated 4.5.2010 supplier of Hollow Metallic Tube Type Detection system with foam based extinguishing media approached the Chairman of IOCL and CMD of BPCL, who chaired the second meeting of Chairmen committee held on 27.4.2010, requesting him to recommend only Hollow Metallic Tube Type Detection system with foam based extinguishing media in order to have monopoly and thwart competition posed by clean agent based system. Hence Chairman of IOCL wrote an email advising Chairman of BPCL and HPCL not to consider clean agent based system even though clean agent system was recommended in the second Chairmen committee meeting held on 27.4.2010.

4.2.1 The robust and reliable linear heat hollow metallic tube type detector system should be adopted for detection. The other two options such as fiber optics such as fiber optics (plastic shielding encased in SS tube)type Linear Heat Detectors for foam based system and fusible bulb detector on metallic piping and nozzle for gas based (clean agent) are also recommended for adoption.

After taking care of personal interest given by one of the manufacturer, the recommendations were changed to suit him.

As per the decision of committee of Chairmen conveyed to OISD by BPCL Chairman, it is very clearly stated that only Hollow Metallic Tube Type Detectors are to be used. The system now being suggested is not based upon Hollow Metallic Tube Type detector. The detector in this case is quartz bulb. Therefore this system is not in accordance with the decision conveyed by the committee of Chairmen to go for metallic tube type detector only.


The above decision was not a part of the Chairmen committee meeting (MOM) but was an email exchanged as per the request of the supplier of hollow metallic tube type detector for favoritism.

No de-merits or other reasons were specified for exclusion of clean agent based system despite the fact that the clean agent system had complete system approval and used worldover. In fact quartz bulb efficacy was proven since it

1. Was recommended by OISD vide OISD 116 and 117 for Rim Seal Fire Protection since it is non-electrically operated and hence reliable in lightning prone areas

2. Was Recommended by OISD for protecting comparatively more hazardous storage facility such as liquefied Petroleum Gas mounted storage facilities vide OISD 150

3. Had extinguished rim seal fire on one of the tanks at IOCL Vadinar and second rim seal fire on one of the tanks at Shell Petroleum.


Thus it is clear that Rim Seal Fire Protection system with Quartz bulb detection despite having proven performance was deleted.

The above recommendations thus concluded that only those rim seal fire protection system that use Hollow Metallic Tube Type Detection System with foam based extinguishing media should be used on Floating Roof Tanks.

…include only those Rim Seal Fire Protection systems, which use the Metallic Tube Type Detectors either new or for replacement of existing systems when due. These system should be certified by international certifying agencies like UL, VdS, FM and LPC to ensure that only those systems are used which meet with the highest international standards of safety certification. No further meeting are required of the committee of chairmen on OISD standards.


Further the Chairmen committee in their recommendations specified that these system should be certified by international certifying bodies UL/VdS/FM/LPCB. The system comprises of detection system and extinguishing system.

These system should be certified by international certifying agencies like UL, VdS,FM and LPC to ensure that only those systems are used which meet with the highest international standards of safety certification.

These recommendations were forwarded to Oil Industry Safety Directorate for putting up before the 28th Safety council meeting for adoption in OISD 116 and 117 standardsThis aspect came to the knowledge of the supplier who tried to change the recommendation to his advantage but was too late since these recommendations had reached OISD, hence supplier approached some key personnel in OISD involved in amending the standards to modify Chairmen committee recommendation from complete system approval to approval of detection system. A comparative statement prepared by OISD clearly reveals how OISD modified the Chairmen recommendation to favour the supplier.

Recommendation of Chairmen Committee Only those Rim Seal Fire Protection system which use the linear heat hollow metallic tube type detectors with foam based extinguishing media, either for new or for replacement of existing system when due shall be used. These system shall be certified by international certifying agencies like UL, FM, VdS, LPCB to ensure that those systems are used which meet with highest international standards of international safety certification.

Final Amendment proposed by OISD Only those Rim Seal Fire Protection system which use the linear heat hollow metallic tube type detectors with foam based extinguishing media, either for new or for replacement of existing detection system when due shall be used. These detection system shall be certified by international certifying agencies like UL, FM, VdS, LPCB to ensure that those systems are used which meet with highest international standards of international safety certification.


OISD thus diluted the Chairmen recommendations while amending the OISD standards by specifying that only the detector viz Hollow Metallic Tube Type Linear Heat Detection shall be certified by UL/VdS/FM/LPCB and not complete system ( detection system and extinguishing system).

Finally OISD published the standards 116 and 117 in October 2010 specifying Rim Seal Fire Protection System using Hollow Metallic Tube Type Detection certified by UL/VdS/FM/LPCB.

Rim Seal area is classified as a hazardous area of zone 1 category according to the Petroleum Rules 2002. It is pertinent to note that these international certifying bodies have not certified Hollow Metallic Tube Type Detection for zone 1 application. However it is certified for non-hazardous application which means the certification is not valid for Rim Seal Fire Protection application. Concerned personnel in OISD did not verify this aspect.

Oil companies under the pressure from Petroleum ministry for implementing the M.B.Lal committee recommendation and complying with defective OISD standards began floating tenders. They soon discovered that Hollow Metallic Tube Type Detection System was not certified for zone 1 by UL/VdS/FM/LPCB. UL Certificate submitted by the manufacturer of Hollow Metallic Tube Type Detection system with foam based extinguishing media having certificate number UTHV.S7197. Go to next slide to view the relevant document.

mailto:UTHV.@7197

UL website mentions products certified for hazardous location fall under the UIPV category and not UTHV.


As a result the tenders were either cancelled or kept in abeyance.

OISD realized the above mistake hence decided to amend the standards to introduce an equivalency clause. Tender was invited calling vendors for demonstrating their technology.


A Technical Expert Committee (TEC) was formed by OISD to evaluate and recommend equivalent/superior system. The TEC comprised of Director CBRI Roorkee, Professor of IIT Delhi, representative from Indian Institute of Petroleum Dehradun with coordinator from OISD. OISD had an agenda to demonstrate to the oil companies that there was no equivalent / superior system other than Hollow Metallic Tube Type Linear Heat Detection and thereby send a message to go ahead with the procurements. In response to OISD tender Indian and International vendors submitted their proposals for approval of equivalent/superior assuming that the exercise was genuine. However when all of them were rejected did they realize that OISD intentions were malafide, OISD ensured other vendors were not approved.

TEC concluded that

o The proposals submitted by the vendors were examined and evaluated by the Technical Expert Committee (TEC) and after due diligence it was concluded that none of the offered system is Equivalent to Linear Hollow Metallic Tube type Rim Seal Fire Detection System with foam based extinguishing media.

o However, TEC noted that Impolene Tube Type Rim Seal Fire Detection System can be considered equivalent provided the detection system is UL Listed and/or FM/VdS/LPC approved for the intended purpose of its use.


None in the ministry questioned the first recommendation of TEC as to how the Hollow Metallic Tube Type Detection not approved for intended use can be superior to Impolene detection (that needs to be approved for its intended use) and the second recommendation as to how Impolene tube Detection system rejected by the Chairmen committee was re-introduced by this committee.

Summary of irregularity appears in the next slide

SR NO RESPONSIBLE IRREGULARITY

1 Chairmen Committee

Deleted Clean agent based system having complete system approval though it was recommended in the second Chairmen meeting held on 24.7.2010. Recommended Hollow Metallic Tube Type Detection system with foam based extinguishing media certified by UL/VdS/FM/LPCB without verifying/checking the certification.

2 OISD Diluted the Chairmen committee recommendation that required the complete system approval to detection system approval. Did not cross check whether certificate of Hollow Metallic Tube Type Detection system issued by UL/VdS/FM/LPCB is valid for Rim Seal Fire Protection application before inclusion in OISD 116 and 117. Floated tender inviting proposals for Equivalent/Superior Rim Seal Fire Protection system based on foam system without clean agent system. Reason may be that the clean agent had total system approval for Rim Seal Fire protection System.

SR NO RESPONSIBLE IRREGULARITY3 Technical Expert

Committee Did not check whether the present system appearing in the OISD namely Hollow Metallic Tube Type Detection system has a valid certificate against which TEC was supposed to evaluate equivalent/superior system. Recommended Impolene detection system rejected by Chairmen committee due to leakages caused by kinks formed by UV radiations and therefore resulting in false alarm and maloperation.

4 Petroleum Ministry

Turning a blind eye to the whole matter. Have not checked whether their decision to form a committee of Chairmen to revise OISD standards gave the desired results namely safety standards that have far reaching implications to be vetted before being amended by OISD.

Chairmen of IOCL retired on 1.2.2011 and CMD BPCL retired on 18.8.2010.

Petroleum Ministry needs to ask OISD :1. On what basis did the Chairmen committee delete clean agent based system ?2. Before arriving at a final conclusion, did the Chairmen committee verify

whether the Hollow Metallic Tube Type Detection System is approved by UL/VdS/FM/LPCB for hazardous area zone 1 ?

3. Whether OISD cross checked the Chairmen committee recommendation in serial 2 above ?

4. If Hollow Metallic Tube Type Detection System was the best system, why OISD had to bring in an equivalency clause ?

5. Why clean agent system was not specified in the tender specification of Equivalent/Superior system ?

6. Why OISD did not inform the Technical Expert Committee that impolene tube type detection system was deleted by the chairmen committee due to maloperation ?

7. How is it possible that all the vendors were rejected ? Is there no vendor of Rim Seal Fire Protection System in the world who can meet the specification of OISD tender for equivalent / superior system?

8. After inviting tender for equivalent system why OISD is not able to provide alternate vendors or systems for Rim Seal Fire Protection ?

Unless the Petroleum Ministry intervenes to rectify the fraud, oil companies will be forced to procure the unapproved system. Hence oil companies also need to voice their concerns.

rim seal fire protection fraud

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