Fluxara — Pre-Commissioning Checklist

Pre-Commissioning Checklist · DPR v15 · Month 0–12

Fluxara Plant
Pre-Commissioning Master Checklist

Comprehensive gate-by-gate checklist from financial close to first commercial production at Month 12. Each phase has a go/no-go gate. ⛔ marks items that are blockers — do not proceed to next phase without these.

Phase 0 · Month 0

Financial Close & Site Possession

Day 1 — Week 4

items

Finance & Legal

⛔ Term loan sanction letter received from bank

₹12.43 Cr debt at 10.5% p.a. · 7 years · 12-month moratorium · DS ₹2.66 Cr/yr confirmed in letter

Promoter + CFO

⛔ Equity infusion ₹6.70 Cr — funds in designated project account

Confirm account balance before any civil work expenditure. Promoter bridges ₹0.75 Cr Y1 interest gap (reduced from ₹1.55 Cr in DPR v15 due to India BOM savings)

Promoter

DPIIT SISFS grant ₹35L — application filed or confirmed

DPIIT recognition DPIIT 246192 is active. File SISFS application — if received, deduct from equity requirement

CFO

⛔ PMC (Project Management Consultant) appointed

PMC handles equipment procurement, vendor management, civil supervision. Engage by Day 1.

Plant Manager

Land & Site

⛔ TSIIC land allotment — 3 acres at Sangareddy · possession letter received

₹3 Cr (3 acres × ₹1 Cr/acre). Confirm boundary demarcation and survey number.

Promoter + Legal

Site survey, soil test, and topographic map completed

Soil bearing capacity test (SBC) required for RCC civil design. If SBC <10 T/m²: pile foundation needed → add ₹20-40L to civil estimate

PMC + Civil

Site plan approved by TSIIC estate office

Required before any civil construction begins

PMC

Temporary site office and security established

Minimum: one container office, one security cabin, perimeter fencing

Site Engineer

Regulatory — Begin Applications (Long Lead Time)

⛔ TSPCB Consent to Establish (CTE) application filed

Orange category, NIC 2029. Processing time: 60–120 days. File immediately on Day 1. Required before civil construction.

Environmental Consultant

✅ IBR registration NOT required — Thermal Oil Heater (TOH) operates at ~0.5 bar(g)

TOH with Therminol 55 at near-atmospheric pressure is outside the scope of the Indian Boilers Regulation. This eliminates 6–10 weeks off the critical path and removes the requirement for a licensed IBR boiler attendant.

PMC — confirm with TOH vendor

Factory Act licence application filed

File with District Industries Centre. Processing: 30–60 days.

HR/Admin

MSME Udyam registration updated/confirmed (was already filed)

For priority sector lending and subsidy eligibility

CFO

⛔ Customer engagement begins — Month 1 (DO NOT DEFER)

HDS target: tyre compound manufacturers (Apollo, MRF, CEAT tech centers). PCC coatings: Asian Paints, Berger. Target 3 meetings in Month 1. Sample commitment required by Month 6.

Plant Manager + Promoter

Phase 0 Go/No-Go Gate

Proceed to civil work only when: CTE application filed · TOH vendor selected and specification confirmed · Equity + loan funds confirmed in account

Phase 1 · Month 1–4

Civil Works & Lab Trials

Month 1 to Month 4 — parallel tracks

items

Civil Construction (Track A)

⛔ TOH/Furnace building — fire-rated RCC construction only (NOT PEB/pre-engineered building)

RCC construction is mandatory for the furnace+TOH building due to fire risk from combustion and thermal oil (flash point Therminol 55: 150°C). Design: RCC column-beam with brick infill, fire-rated door, explosion vent panel, spill bund. IBR registration NOT required — no steam boiler present.

Civil Contractor + PMC

⛔ ETP/ZLD foundations — construct first (longest cure time)

ETP concrete tanks need 28-day curing before filling. Sequence: ETP foundation → 28 days → equipment installation. If done last, delays ZLD startup by 1 month.

Civil Contractor

Process building — RCC frame, acid/alkali resistant floor finish (epoxy)

Floor must slope to drain with spill collection. NaOH and CaO are corrosive — plain concrete floor will degrade within 6 months.

Civil

RHA storage shed — concrete pad, covered, near furnace

20 days RHA inventory needed. At 15 MT/day: 300 MT storage. Size: min 500 m² at 0.8 MT/m² bulk density.

Civil

Husk storage yard — compacted road base, drainage, covered area for 7 days inventory

7 days husk = 140 MT. Covered area to prevent moisture gain (husk moisture affects NCV).

Civil

Spray dryer building — ceiling height min 10 m (dryer cylinder height ~8 m)

Confirm spray dryer dimensions with vendor before finalising building height.

Civil + PMC

Chemical storage — separate rooms for NaOH, CaO, CTAB (segregate incompatibles)

NaOH + CaO storage OK together. CTAB (organic) separate from caustics. Min: secondary containment (bunded floor) for NaOH room = 110% of largest tank volume.

Civil + Safety Officer

Solar PV mounting structure — 250 kWp system (1,000 m² footprint approx.)

Can be on process building roof or dedicated ground mount. Coordinate with solar contractor for structure design.

Civil + Solar vendor

Lab Validation Trials (Track B — CRITICAL PATH)

⛔ Lab validation completed — extraction efficiency ≥85% confirmed on local RHA

See SOP-001 dissolution test and ML Research doc Lab Trial Matrix. Must complete by Month 4 before engineering freeze.

QC Officer + Process Engineer

⛔ Causticisation efficiency ≥78% confirmed at lab scale

Lab scale will underperform plant scale (heat loss). If lab shows 78%: plant should achieve 82%+. If lab shows <72%: plant target of 82% at risk — escalate to process consultant.

QC Officer

⛔ HDS grade silica BET ≥165 m²/g demonstrated at lab scale

Lab silica BET may be slightly lower than plant due to different filtration/drying. If lab BET ≥165: plant should achieve ≥175.

QC Officer + external BET lab

RHA XRF from 5 different local suppliers — SiO₂ content mapped

Identify best SiO₂ content supplier. Lock supply agreement with ≥92% SiO₂ clause.

QC Officer + Procurement

Furnace temperature amorphous test — confirm 700°C threshold for your system

Fire RHA samples at 650/700/720/750°C. Send for XRD. Confirm cristobalite onset temperature.

External certified lab

Engineering parameters document issued — "Process Design Basis" for equipment vendors

Based on lab results. Contains: extraction efficiency, leach conditions, filter press requirements, spray dryer conditions. Vendors need this to finalise equipment specs.

Process Engineer + PMC

Equipment Procurement (Track C)

⛔ Engineering Freeze — finalise equipment BOM by Month 2

Long-lead items: Furnace (12–14 weeks) · TOH unit (6–8 weeks, shorter than IBR boiler's 14–18 wks) · Double-effect evaporator+MVR (12–16 weeks) · Spray dryer (10–14 weeks). Order must go by Month 2 to arrive by Month 7.

PMC + Plant Manager

⛔ MVR unit included in evaporator order — confirm at time of order placement

MVR is mandatory from Day 1 (see DPR v15 Section 6). Must not be treated as optional or Phase 1B item. Confirm with evaporator vendor that MVR compressor is included in the same PO.

PMC

CEMS system specified and ordered — must be operational before CTO

TSPCB requires CEMS before grant of Consent to Operate. Connect to TSPCB server for real-time data feed. Include: CO₂, CO, SO₂, NOₓ, PM, temperature, flow.

PMC + Environmental Consultant

ZLD system (ETP 25 KLD) specified and ordered — 14-week lead time

Must be operational on Day 1 of production. No liquid discharge allowed.

PMC

QC lab equipment ordered: BET, XRF, PSD, moisture analyser

Minimum lab for internal QC: bench-top XRF (₹8–12L), laser diffraction PSD (₹6–10L), moisture analyser (₹1.5L). BET: can outsource initially (₹2,000–3,500/sample).

QC Officer + PMC

CTAB buffer stock ordered — 4 weeks minimum inventory confirmed with supplier

CTAB is imported (highest supply risk). Secure 4-week buffer (at 0.289 MT/day = ~8 MT buffer). Identify backup supplier.

Procurement

Phase 1 Go/No-Go Gate

Civil: CTE received · Boiler house structure at lintel level
Lab: Extraction ≥85% · Causticisation ≥78% · Engineering Freeze document issued
Procurement: All long-lead orders placed

Phase 2 · Month 4–10

Equipment Installation & Mechanical Completion

Month 4 to Month 10

items

Furnace & Thermal Oil Heater (TOH) Installation

⛔ TOH coil installation — leak test at 1.5× operating pressure before oil fill

Perform hydrostatic test of all TOH coils and process HX at 1.5× design pressure (min 1.0 bar). Check all flanges and welds. No IBR inspector required. TOH vendor witnesses and signs off.

TOH vendor + PMC

⛔ Thermal oil (Therminol 55 / Dowtherm A) charged and circulation confirmed

Fill expansion tank to ½ level with fresh thermal oil. Start circulation pump and purge all air pockets. Check oil flow at each HX outlet. No boiler water treatment needed — thermal oil does not require chemical dosing.

TOH vendor + Process Engineer

Husk conveyor installed and tested — start/stop, blockage detection, reversal

Test at 25%, 50%, 75%, 100% capacity. Confirm feed rate control (VFD on conveyor motor).

Mechanical

⛔ CEMS installed and tested — before TSPCB inspector visit

CEMS supplier commissions the unit and demonstrates to TSPCB inspector. Must show real-time data feed to TSPCB server. This takes 2–4 weeks after physical installation.

CEMS vendor + TSPCB

⛔ Temperature interlock: CEMS auto-shutoff at 720°C — test with simulated signal

Safety interlock must be tested before any husk burning. Test: force CEMS temperature reading to 720°C (using signal injector), confirm conveyor stops. Log test result with signature.

Instrumentation + Safety Officer

Process Equipment Installation

Leach reactors — glass lining inspection report from glass-lining contractor

Inspect every section of glass lining before reactor fills. Holiday (pinhole) test with high-voltage spark tester. Any spark = reject that section. Get lining contractor sign-off before oil jacket is pressurised.

PMC + Process Engineer

⛔ MVR compressor commissioned by vendor — performance test at design conditions

Vendor must demonstrate: compressor runs at design inlet pressure, discharge pressure, and flow. Without MVR proven, do not accept handover. MVR failure after handover = plant cannot run.

Evaporator vendor + PMC

Filter press — fill test with water, check all plate seals

At 8 bar water pressure, check: no weeping at plate joints, no cloth tears, correct plate assembly sequence. Record as-found condition for future reference.

Mechanical

⛔ Spray dryer SS316 — confirm material of construction from vendor: heat number + MTC (Material Test Certificate)

Spray dryer must be SS316 (not SS304 or MS) — moisture + silica + NaOH traces are corrosive. Request mill test certificate for all wetted parts. False SS316 certificates exist — inspect plate markings.

PMC + QC

CaO slaker — cooling water interlock test: confirm heating stops if cooling water fails

Slaker temperature can exceed 100°C in 5 minutes without cooling. Interlock must shutdown CaO screw feeder on cooling water low flow.

Instrumentation

CO₂ absorption/compression unit — performance test with furnace flue

Key specification: CO₂ purity ≥95% at outlet, PM <5 mg/m³. Test during furnace trial run and confirm by grab sample.

CO₂ system vendor + Process

Utilities & Electrical

⛔ HT power connection energised — TSSPDCL approval and meter installed

Without HT connection: no plant operation. File application Month 1. Processing: 60–120 days. ₹17L security deposit for HT. Do not leave this till Month 9.

PMC + Electrical Contractor

DG 200 kVA — installed, tested, fuel storage (7 days) in place

Auto-start on grid failure. Test: simulate grid failure, confirm DG starts and takes load within 30 seconds.

Electrical

Solar 250 kWp — commissioned and connected to site main board

Net metering arrangement with TSSPDCL for export credits.

Solar vendor

SCADA/PLC system installed — all sensors wired and communicating

Verify all OPC-UA tags (from Digital Twin Schema) are live. Test: call all SCADA tags from Digital Twin Python script and confirm non-null readings.

Instrumentation + IT

Safety systems: eye wash stations × 6, safety showers × 4, first aid kits × 4

Location: leach area × 2, causticisation area × 1, CaO slaker area × 1, QC lab × 1, gate area × 1. Test eyewash flow weekly.

Safety Officer

Fire extinguishers: CO₂ (electrical), DCP (chemical), foam (husk) — installed per fire plan

Minimum: one per 50 m² in process areas, one per 200 m² in husk storage. Check NBW date on all cylinders.

Safety Officer

ZLD system commissioned — water balance confirmed (80% recovery demonstrated)

Run ZLD with clean water at 80% of design flow for 72 hours. Confirm recovery rate ≥75% in test run. TSPCB inspector may witness this during CTO inspection.

ZLD vendor + Process Engineer

Mechanical Completion (Handover)

⛔ Punch-list closure — all Category A (safety/production critical) items resolved

Mechanical Completion Certificate signed by PMC. Category A punch items are blockers. Category B and C can be closed in first 30 days of operation.

PMC + Plant Manager

As-built drawings issued — P&IDs, electrical single-line, civil layout

Essential for future maintenance, expansions, and regulatory inspections. Do not accept handover without as-built drawings.

PMC

All vendor O&M manuals received and filed in control room

Every equipment item must have: operation manual, maintenance manual, spare parts list, vendor contact. Organise in binders by area.

Plant Manager

All operators trained on SOPs — sign-off on SOP-001 through SOP-012

Minimum: 2 weeks classroom training on chemistry and process. 2 weeks on-site training with vendor. Competency assessment before first solo operation.

Plant Manager + Vendor trainers

Phase 2 Go/No-Go Gate — Mechanical Completion Certificate

All Category A punch items closed · TOH first-fire completed and oil temps confirmed · CEMS live and connected to TSPCB · HT power available · ZLD operational · All operators trained · Mechanical Completion Certificate signed

Phase 3 · Month 9–12

Regulatory Clearances

Month 9 to Month 12

items

TSPCB Consent to Operate

⛔ TSPCB CTO inspection — book inspection appointment after mechanical completion

Inspector will check: CEMS live and transmitting, ZLD operational, fire safety systems, chemical storage, ETP inlet/outlet quality, husk storage. Prepare documentation folder.

Environmental Consultant + Plant Manager

⛔ Consent to Operate (CTO) received — do not start commercial production without CTO

Production without CTO is illegal under Water Act/Air Act. TSPCB can seal the plant. Trial runs (water + chemicals, no husk) may be done without CTO with pre-intimation.

Plant Manager + Environmental Consultant

Fire NOC from local fire department

Required for factory licence renewal. Book fire department inspection alongside TSPCB.

Safety Officer

Thermal Oil Heater (TOH) Pre-Commissioning

⛔ TOH first-fire — confirm oil supply temperature 180–220°C, no leaks, all HX outlets warm

No IBR Certificate of Fitness required — TOH is not a pressure vessel under IBR. Perform first fire on diesel/LPG auxiliary, then introduce husk gradually. Monitor expansion tank level, system pressure, and all HX outlet temperatures.

TOH vendor + Shift Supervisor

FSSAI (Begin Application at Month 12)

⛔ FSSAI Central Licence application filed at Month 12 commissioning — NOT deferred

FSSAI E551 approval timeline: 12–18 months. Filing at Month 12 means approval by Month 24–30. Dental/food grade revenue begins Year 3 — this timeline is what makes Y3 revenue work.

Plant Manager + FSSAI consultant

FSSAI application requirements: GMP audit, site plan, process flow, lab test reports

Engage FSSAI-approved lab for product testing. All heavy metals (Pb, As, Hg) must be below limits. Prepare GMP documentation alongside commissioning.

QC Officer + FSSAI consultant

BIS certification application — IS 6579 for precipitated silica (optional, enhances domestic sales)

Not mandatory for domestic sales initially, but required for some B2B customers. File within first 6 months of commercial production.

QC Officer

Export documentation: IEC (Import Export Code) with DGFT

Required before first export shipment. Apply through DGFT online portal. Processing: 2–3 days online. HS Code for export: 2811.22.00

CFO + Export Manager

Phase 3 Go/No-Go Gate — Commercial Production Clearance

CTO received · TOH commissioning sign-off from vendor (no IBR CF needed) · Factory licence issued · Fire NOC received · FSSAI application filed

Phase 4 · Month 10–11

Trial Runs — System Checkout

Before CTO receipt: water trials · After CTO: material trials

items

Trial 1 — Water Trials (before CTO — no regulatory restriction)

Fill all process vessels with water — check for leaks on all flanges and connections

24-hour hold test on all tanks. Mark any seeping joints for re-torquing. Do not fill with chemicals until all leaks resolved.

Mechanical + Process Engineer

Run all pumps and agitators — check bearing temperature, vibration, current draw

Bearing temp should stabilise within 30 min of start. If bearing temp >80°C at steady state: check alignment, lubrication. Record base current draw for future fault detection comparison.

Mechanical

TOH first-fire trial — confirm oil supply temperature reaches 180°C, all HX outlets warm

No IBR inspector required. Start on diesel/LPG, introduce husk gradually. Log: time to reach 180°C oil supply, expansion tank level stable, all HX outlet temps within design range. PRD not expected to lift — if it does, shut down immediately.

TOH vendor + Shift Supervisor

SCADA system verification — confirm all OPC-UA tags reading live values

Compare SCADA readings to local instruments at 5 points. Acceptable error: ±2%. Log calibration factors for any offsets found.

Instrumentation

Evaporator + MVR water trial — confirm thermal balance

Run MVR on hot water at 50% capacity. Confirm: compressor power within design range, product concentration increases over time.

Evaporator Operator

ZLD water balance confirmed — run with process water, measure inlet/outlet flows

Target: 80% permeate recovery on the RO. If <75%: check RO membrane condition, pre-treatment.

ETP Operator

Filter press water trial — confirm cycle time, pressure, open/close mechanism

Run 3 complete cycles with clear water. Cycle time target: 60–75 min. Confirm hydraulic opening mechanism operates smoothly.

Mechanical

Digital Twin connected to SCADA — confirm readings matching

Run Digital Twin Python script against live SCADA data. Confirm no null readings. Run balance() function — check predicted values are reasonable.

IT + Process Engineer

Trial 2 — Chemical Material Trials (after CTO)

⛔ First NaOH leach trial — 200 kg RHA batch, sample at 30, 60, 90, 120 min

First real chemistry test. Target: SiO₂ dissolution ≥85%. Record all SCADA data for baseline. Compare to lab results — if within 10%: process is scaling correctly.

Process Engineer + QC

⛔ First precipitation trial — produce first silica sample, measure BET

Send sample to BET lab. Result expected in 3–5 days. If BET ≥150 m²/g: process working. If <130 m²/g: review pH endpoint and temperature.

Process Engineer + QC

⛔ First causticisation trial — NaOH recovery measured

Titrate recovered NaOH solution. Compare to lab results. If recovery <70%: temperature problem or CaO quality issue.

Process Engineer + QC

Send first product samples to 3 target customers for evaluation

HDS sample to tyre compounders (Apollo, MRF). PCC sample to coatings buyers. This is the start of the qualification process — typically 3–6 months for customer approval.

Plant Manager + Sales

First CTAB-treated HDS batch — measure CTAB value, confirm ≥160 mg/g at trial scale

First batch may be slightly below spec while process is dialled in. Use as training run — do not sell, use for process optimisation.

QC Officer

Mass balance closure check — input vs. output within ±8% for week 1

Acceptable: ±8% in week 1 (measurement errors, heel in tanks). Target: ±3% by month 3. Log daily mass balance in OPR form.

Process Engineer

Bank draw-down monitoring — monthly statement to confirm spend aligns with plan

Compare actual spend to month-wise CAPEX plan. Alert if >10% ahead (risk of fund shortfall). Promoter bridging WC ₹1.55 Cr ready for Y1 moratorium interest.

CFO

Phase 4 Go/No-Go Gate — Commercial Production Ready

First batch BET ≥150 m²/g · First causticisation recovery ≥70% at plant scale · ZLD operational · CEMS transmitting to TSPCB · First customer samples dispatched · All operators solo-competent on their unit operations

Plant Manager

Name / Sign / Date — Month 12 Commercial Production Sign-Off

PMC Representative

Confirms mechanical completion and handover

Promoter / Director

Authorises commercial production commencement