Frequently Asked Questions - Pressure Piping Within Oil and Gas Facilities
The changes to the Safety Standards Act introduced through Bill 13 were to clarify jurisdictional responsibilities in the areas of pressure piping and refrigeration systems. The changes are expected to result in more efficient oversight of oil and gas operations in B.C. and allow both the Commission and Technical Safety BC to focus their efforts in those areas of responsibility. For more information, please see Industry Bulletin 2016-34 Safety Standards Amendment Act Resulting Regulatory Authority and Process Changes.
No, the changes only affect facilities regulated under the Oil and Gas Activities Act. If the facility is NEB regulated, the BC Oil and Gas Commission has no regulatory involvement in the equipment, piping or components. For further information, please contact the NEB or Technical Safety BC directly.
Application design review is the first stage in our regulatory lifecycle approach to managing risks to public safety and the environment. The Commission reviews facility applications as an integrated system of singular components required to perform safely as a whole network. By focusing on where and how components interface within the system, the Commission can evaluate and assess the interaction of the elements with an eye for risk, reliability and safety.
The Commission utilizes a professional reliance model in some specific areas of its regulation of oil and gas activities. Engineering designs must be signed and sealed for use in B.C. by a member of Engineers & Geoscientists BC (formerly APEGBC). The requirements apply to the design, construction, operations/maintenance and decommissioning stages of projects. This professional reliance model is supplemented at the application stage by a design review process performed by Commission professional staff or third party subject matter experts. Additionally, targeted field inspections are undertaken during the construction, commissioning, operations, and decommissioning phases.
If an applicant intends to design all or a portion of a facility outside of B.C., they should refer to the Engineers & Geoscientists Quality Management Guidelines - Use of Seal, section 184.108.40.206. Appendix D of the LNG Facility Application and Operations Manual provides further guidance on how to meet professional reliance requirements to the Commission’s satisfaction and is consistent with the Engineering & Geoscientists Quality Management Guidelines.
Yes this is correct, the legislation refers directly to ASME B31.3 as an acceptable design code (not CSA B51), therefore design registration is not required for process pressure piping and fittings. In cases where CSA B51 is the design standard, design registration is required. A proponent may still choose to register for CRNs in any circumstance and can do this through Technical Safety BC.
There is no requirement to submit these packages to Technical Safety BC, except in instances where there is a design requirement to follow CSA B51. Proponents may still choose to register for Canadian Registration Numbers (CRN) for any reason and can do this through Technical Safety BC.
Prior to start-up following installation of the piping, the permit holder must have all this information available. The signed and sealed P&IDs must be submitted to the Commission following installation of the piping. The Commission may choose to audit the rest of the documentation.
If a design is currently registered, it is up to the permit holder whether to maintain the registration or cancel it. If they choose to keep it registered, design registrations for Commission-regulated elements will be reviewed and administered by Technical Safety BC. In these cases, compliance with the design registration requirements will fall to the Commission. This would be in addition to the Commission requirements.
The welder qualification shall be in accordance with the requirements in the code of construction (e.g. ASME B31.3, Section 328.2 and CSA Z662 Clause 7.8).
The Commission has no extra requirements for welders above what is required by the code of construction.
The Commission does not authorize test facilities.
Forms 1329 and 1330 were created by Technical Safety BC to satisfy the requirement to submit manufacturer’s data reports under CSA B51. The Commission would not require submission of these forms if design registration was pursued by a proponent. ASME B31.3 requires inspection by the owner’s inspector (or the inspector’s delegates) and therefore, if the Commission chooses to verify the satisfactory completion of the required examinations and testing, the Commission would request a copy of the inspector’s verification report indicating compliance to the code and the engineering design.
The Commission requires permit holders ensure all workers including inspectors and supervisors are competent (i.e. qualified, trained and experienced to perform the required duties). Note that for pressure piping designed to ASME B31.3, the standard includes minimum qualifications for inspectors.
Section 78(3) of the Drilling and Production Regulation states piping at facilities must be designed, constructed and operated in accordance with CSA Z662 or ASME B31.3. The only exception is for piping at gas processing plants and LNG facilities. All code breaks must be shown on the as-built drawings.
The Commission does not require completion and submission of this form in order to complete the upgrades. However, the required information listed in the form must be available and provided to the Commission if requested.
For fuel gas trains where the CSA B149.3 code is followed in the design of gas fired appliances (such as line heaters, tank heaters, glycol and amine reboilers, etc.), the as-built or record drawings for these facilities must clearly state they were designed and constructed in compliance with the requirements in CSA B149.3. It is a regulatory requirement that these drawings are stamped and signed by a professional engineer registered in B.C. The Commission does not require certification by a third party.
No, the Commission does not require permit renewal to operate pressure piping and refrigeration systems at a facility that was permitted under Oil and Gas Activities Act (OGAA).