RIM SEAL FIRE PROTECTION SYSTEM HOLLOW METALLIC TUBE TYPE DETECTION OISD 116 117 FRAUD SCAM

1. 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.

2. 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
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4. 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.R21012/1/2008.OR-1 dated 26.10.2009. The motto behind setting up of the
Chairmen committee was as follows.

5. 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……
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7. 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.
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12. 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.
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19. Following recommendations were given by EIL referred in serial 3.3 above
Conclusion
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 system
a. Linear Heat Hollow Metallic Tube Type Detectors
b. Fiber Optic Type (plastic shielded encased in SS tube) Linear Heat Detector
2. Gaseous (Clean agent) Flooding system
a. 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.
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23. 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.
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26. 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.

27. 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.
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30. 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.
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33. 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.
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35. 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 standards
This 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.

36. Recommendation of Chairmen
Committee
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 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.
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.
Go to next slide to view the relevant document.

38. 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.
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40. UL website mentions products certified for hazardous location fall
under the UIPV category and not UTHV.
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42. 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.
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44. 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.

45. 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.
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47. 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

48. SR NO
1
2
RESPONSIBLE
Chairmen
Committee
OISD
IRREGULARITY
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.
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.

49. SR NO
RESPONSIBLE
3
Technical Expert
Committee
IRREGULARITY
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.

50. Petroleum Ministry needs to ask OISD : and CMD BPCL retired on
Chairmen of IOCL retired on 1.2.2011
1. On what basis did the Chairmen committee delete clean agent based system ?
18.8.2010.
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 ?

51. 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.