Maintenance Procedures - Propane Facility System Guidelines
New requirements for the establishment of procedures for operations and maintenance of propane equipment were introduced in CSA B149.2-15 Propane Storage and Handling Code. Owners of propane facilities must develop and document operating procedures for day to day operation, emergency procedures, and maintenance procedures including testing, inspection, monitoring and repair of facility propane equipment.
The purpose of this manual is to provide facility owners and operators guidance and basic information to conform to Technical Safety BC’s requirements for the development, implementation and documentation of an operations and maintenance program which meets the intent and requirements for CSA B149.2-15 Clause 7.22 Operations and Maintenance Procedures.
The requirements for operations and maintenance procedures apply to the following propane facilities within the jurisdiction of the Gas Safety Regulation:
- tank systems
- filling plants,
- container refill centers
- dispensing systems
- vaporizers and tank heaters
- other equipment where liquid propane is piped to a process
Competency - the demonstrated ability to apply training, experience and knowledge in the execution of duties
Container refill centers – a facility, including a building, consisting of propane storage containers, piping and dispensing systems where liquid propane is transferred to containers
Dispensing systems - a system, consisting of tank, pump and motor, propane dispenser, and associated piping, for the storage, metering, and dispensing of liquid propane into containers or vehicle fuel containers
Filling plant – a facility for the distribution of liquid propane consisting of propane storage tanks and equipment for the transfer of liquid propane to or from rail cars, tank trucks or dispensing to containers or vehicle fuel containers
Tank heater - a form of vaporizer used to apply heat either directly to a portion of the container surface in contact with propane liquid or indirectly by circulating propane liquid from the container to the device and then back to the container
Tank system - a container or assembly of containers designed and fabricated in accordance with CSA B51 for the storage of propane including underground tanks
Vaporizer - a device for converting liquid propane to vapour by means other than atmospheric heat transfer through the surface of the container.
5. Owners and Operators Responsibility
Owners and operators of propane facilities shall develop and implement a management program that includes policies, processes and procedures for the operation and maintenance of the facility which:
- Comply with the Safety Standards Act, Safety Standards General Regulation, Gas Safety Regulation and CSA B149.2
- Set relevant company policies and performance objectives,
- Proactively identify hazards, evaluate risks, identify and implement risk mitigations measures, and conduct inspection, maintenance, and monitoring activities,
- Establish clear responsibilities and accountabilities,
- Provide sufficient trained and competent persons and other resources to manage the program and,
- Administer documentation, records reporting, evaluation and continual improvement.
6. Management Program Requirements
The operation and maintenance management program shall incorporate the following facets and document the program’s policies, processes and procedures in a program management manual. As a minimum, each organization shall address the required facets relative to the size and complicity of the facility. Organizations shall explain their intent, capability and applicability for each facet outlined in this section. Work may be subcontracted provided controls are clearly defined for maintaining full responsibility for compliance with the Safety Standards Act, Safety Standards General Regulation, Gas Safety Regulation and CSA B149.2 by the facility owner/operator.
The management program manual should incorporate the following general requirements:
- bound in a manner that allows for easy revisions and updating
- company logo or letterhead on each page
- typed name and date after a signature
- typed (handwriting not permitted)
- each page must be identified with a page number, total number of pages in the manual and manual revision number and date
The manual should provide clear and simple instructions on the facility owner’s/operator’s policies and procedures for the management program. The manual may be brief or detailed depending on the program requirements based on the size and complicity of the propane facility. Propane facilities in British Columbia, cover a broad range of installations from large filling plants with multiple propane storage tanks holding thousands of liters of propane and equipment for the transfer of liquid propane to or from rail cars, tank trucks to small commercial facilities consisting of a single tank, pump and propane dispenser for the storage, and dispensing of liquid propane into portable cylinders or motor vehicles.
The extent of a program needed to achieve an effective and practical operation and maintenance program will therefore vary considerably and will also depend on the equipment that is at the facility.
The level of documentation detailed in should be appropriate for the size, scope, complexity, and level of risk for an operation and may range from a few paragraphs for small operations consisting of a small amount of equipment with a low level of risk through to several pages for large, complex facilities or operations with numerous types and large numbers of equipment with a much higher level of risk.
The following features are to be included in every manual:
- Title Page - The name and complete address of the facility owner/operator, the facility location, the number assigned to each “controlled” copy, the name of the person or group a controlled copy is issued and the date of issue shall be included on the title page of the manual.
- Contents Page - The manual should contain a page listing the contents of the manual by subject, reference number (if applicable), page number, and revision number of each document.
- Scope - The manual shall clearly identify the facilities, equipment and processes managed under the management program. The manual shall specify if it applies to third-party operated facility assets and have controls to ensure that third parties are fulfilling any contractual agreements with respect to facility operation or maintenance. Any facilities or equipment covered by other operation or maintenance programs shall be identified. Existing operating or maintenance programs can be referenced by the manual and do not have to be included in the manual provided they are documented. The scope should state the types of operations, inspection, maintenance, repairs or alterations the manual includes.
- Statement of Authority and Responsibility - A dated Statement of Authority, signed by the owner/operator or an authorized representative, shall be included in the manual.
Further, the Statement of Authority shall include:
- The owner’s commitment to provide resources for implementing and continually improving the management program
- A statement that all regulated work carried out the facility shall meet the requirements of the Safety Standards Act, General Regulation, Gas Safety Regulation CSA B149.2 and applicable codes or standards;
- A statement that if there is a disagreement in the implementation of the program, the matter is to be referred for resolution to a designated position in the organization with the authority to resolve the matter;
- The title of the individual who is responsible for the management of the program and that the position has the authority to carry out the responsibility. The individual assigned responsibility and accountability for the operation and maintenance program shall ensure that:
- Processes and procedures are developed, documented and implemented to support the execution of all the key components of the operation and maintenance program,
- A process is defined to identify and ensure conformance with changes to regulatory requirements and new editions of standards and codes
- Resources (personnel and technical requirements) are planned and provided to develop, implement, and continually improve the operation and maintenance program
- Manual Control - The manual shall include the necessary provisions for revising and issuing documents to keep the manual current. The title of the individual authorized to approve revisions shall be included in the manual. There shall be provisions for signatures of the authorized individuals responsible for making changes and approving changes or revisions. Any manual changes shall be approved prior to issuance of any revisions to the manual and implementation of the program changes.
- Organization - An organizational chart shall be included in the manual. It shall include the title of the positions in all departments or divisions that perform functions that can affect the execution of the operation and maintenance program such as a facility’s maintenance, operations, or engineering departments. It shall also show the relationship between each department and division.
The manual shall identify the title of those individuals responsible for preparation, implementation, or verification of the operation and maintenance program. The responsibilities shall be clearly defined and the individuals shall have the organizational freedom and authority to fulfill those responsibilities.
- Training and Competency - The operation and maintenance management program shall establish, implement and maintain a process for developing competency requirements and enabling training of employees or contractors responsible for administrating and executing program activities, including operation, inspection, maintenance and repair. Training schedules and frequency must be maintained for all identified critical tasks. The procedures for the administration and maintenance of training records shall be documented in the manual.
The management program shall have a process for verifying that employees and other persons working with or on behalf of the owner are trained and competent to perform their duties in a safe manner. Where contractors are utilized for the maintenance of a facility, there must be a process to evaluate and select contractors on the basis of ability and qualifications to perform contracted duties. The evaluation process should include review of safety and environmental policies, procedures, past performance, ability and qualification check through audits, work-site inspections, and observations of performance as appropriate. There must also be a process in place to ensure that performance requirements and expectations are defined and communicated to the contractor. A process to monitor and assess a contractors’ performance and ensure that identified deficiencies are resolved shall be developed.
Anyone performing regulated work on a gas system or gas equipment must hold a certificate of qualification which entitles them to carry out the work.
- Document and Records Administration - The management program shall establish, implement and maintain a process for administering documents and records needed for the effective implementation of operation and maintenance activities including but not limited to design, construction, operation, maintenance, and decommissioning. The document and record administration process shall encompass creation, security, updating, retention, retrieval and deletion of all information and records. Records may be in electronic or paper-based format.
Responsibilities for document approval shall be specified and shall identify appropriate controls to ensure that revisions and updates to procedural, process or other record documents are reviewed and approved.
The management processes for records shall address:
- Responsibilities and procedures for creating, gathering, updating, retaining, and deleting documents
- Records of past activities, events, changes, analyses and decisions
- An index describing the types, forms and locations of records
- Retention policy as required by regulations or codes and the owner’s/operator’s requirements.
As a minimum information related to location, construction, operating conditions, inspection, testing and maintenance and facility incidents shall be documented and maintained. Where records are incomplete due to change of ownership, asset transfers or other reasons, the management program shall have a process for ensuring safe operation and maintenance in the absence of these records and how the missing information is to be recovered.
- Normal Operation Procedures - The management program shall include procedures for the safe operation of each facility. The commissioning of new or modified facilities, normal operations including shutdown, start-up, operating limits and alarm management shall be addressed. These procedures shall be appropriate to the size and complexity of the facility and eliminate, mitigate or control the identified hazards.
As minimum operation procedures shall address:
- product transfer and handling procedures including the evacuation of propane from containers and the purging of containers;
- monitoring of essential functions and equipment;
- housekeeping and site maintenance;
- any manufacturer’s operating instructions for equipment;
- isolation, deactivation and identification of equipment not in use;
- maintaining clear spaces for access and housekeeping;
- maintaining clearances for cylinder storage, tanks and setbacks around the facility;
- personnel safety;
- site signage and markings as required by codes
- personal protective equipment;
- control of ignition sources;
- grounding and bonding;
- control of access, security, and lock-up;
- xvehicle movement and parking; and
- operator training and experience.
- Emergency Procedures - The management program shall develop and maintain an emergency response and preparedness plan which outlines the responses and procedures for when an incident that could cause an unintentional or uncontrolled release of propane or a potential safety or health hazard, such as a fire, explosion or chemical exposure occurs as identified by a hazard analysis.
This plan shall be designed to stop or mitigate the incidents such that the consequences are minimized. It should address both emergency actions of the facility operator and those of emergency responders from the municipality, township, or region as well as communications with the general public. The emergency plans for external responders are developed by the local emergency response providers, in consultation with the owner/operator.
The procedures in the emergency response plan shall be appropriate to the size and complexity of the facility and as a minimum address:
- evacuation from the danger area to a designated safe location when an emergency occurs
- emergency escape routes, assembly points and shelter areas
- responsibilities such as emergency response command, first aid, firefighting, evacuation wardens
- emergency procedures to manage incidents including the use of emergency shut off devices, electrical isolation and fire suppression
- emergency response training for facility employees
- contact information for facility emergency responders and other individuals who must be notified of an emergency situation
- contact information for external emergency responders
- facility data and contact information for external emergency responders and support agencies such as ambulance and police
- information about chemical hazards and material data sheets
- site map (or site plan) that identifies the location of:
- Fire protection systems
- Emergency equipment
- Indication of direction “north”
- Off-site references to assist with facility orientation (e.g., adjacent roads)
- Property lines
- Fence lines
- Gates for vehicles and personnel
- Buildings and structures, identified by name and general function
- Propane storage containers and their capacity
- Propane transfer, loading and unloading facilities (including rail car or truck if applicable)
- Site electrical system controls (i.e., switch gear, main panel, breaker box)
- Emergency Shutoff Valves (location of valve and remote control device)
- Fire monitoring, detection and suppression equipment, such as monitors, hydrants, sprinkler systems, fire extinguishers and other sources of water for emergency response
- Inspection and Monitoring - The management program shall document and maintain inspection and monitoring procedures that are appropriate for the gas systems, equipment and storage containers in the facility. The procedures should be designed to ensure safe operation and to mitigate risks identified by the hazard analysis. Inspection and monitoring activities should follow relevant regulations, standards, codes and equipment manufacturer’s instructions. These activities will from facility to facility depending on the type and complexity of the facility.
Planning, scheduling, and frequency of inspection and monitoring should consider parameters such as effectiveness of inspection method and technology, previous inspection results, incident history, insufficient documentation, evaluation of anomalies, time dependent consideration, current state of facility/equipment, and industry data such as standard damage mechanisms. The program shall document schedules and have controls to ensure that the planned activities are carried out.
If any irregularities, anomalies, damage or other unsafe conditions are identified, further inspections and investigations such as an engineering assessment, fitness for service evaluation, code guidelines for evaluation imperfections or anomalies or other means shall be used to evaluate if the equipment or facility can continue to be operated safely. The outcome of the evaluation could be to monitor the irregularity by increasing the inspection frequency, altering operational procedures, rerating or repairing equipment.
As a minimum the inspection and monitoring program shall include:
- Inspection of storage tanks and cylinders and their fittings such as safety relief valves, shut off valves
- Corrosion control for above ground containers including paint and localized corrosion at saddles and foundations
- Corrosion control for underground or mounded tanks including cathodic protection systems
- Pipe condition and piping supports
- Requalification for cylinders
- Testing of emergency shut off valves and back check valves
- Hose inspection for damage and leakage
- Regulator operation and inspection
- Maintenance - Maintenance procedures shall be developed for gas systems and equipment based on codes, standards and manufacturer’s instructions. Maintenance procedures shall be documented and reviewed whenever a change, including operational changes, in gas systems or equipment occurs. Written maintenance procedures provided by equipment manufacturers may be used as maintenance manuals. Maintenance work on regulated equipment shall be carried out by individuals holding the appropriate certificate of qualification who have been trained in the maintenance and testing procedures applicable to the systems or equipment on which they are working. Maintenance procedures shall be developed for all gas systems and equipment including:
- Propane storage containers, foundations, gauges, valves, pressure relief valves, emergency shut offs
- Piping, pipe fittings, supports, hydrostatic relief valves, shut off valves, gauges and protective coverings
- Pumps, pump supports, shut off valves, by pass valves, flexible connectors, drive components and lubrication
- Dispensing equipment, supports, shut off valves, by pass valves and break away nozzles
- Compressor supports, shut off valves, by pass valves, back check valves, flexible connectors, strainers/filters, drive components and lubrication
- Vaporizers, ignition systems, strainers, burners, controls and cleaning of heavy ends
- Fire protection equipment, portable extinguishers, hydrants, valves and hoses
- Calibration of gauges, instruments and other monitoring equipment
- Installation, Repair and Alteration Methods - The manual shall include processes for installations, repairs and alterations, including mechanical assembly procedures, materials and nondestructive examination methods, as applicable. Where modifications or repairs are required, there shall be a process to identify and document relevant corrective actions that are acceptable and appropriate for the facility. Repair methodology must be documented to execute the repair. The processes shall include procedures for giving notice to Technical Safety BC before commencing any installation, repair or alteration and after completing any installation, repair or alteration.
Reference shall be made in the manual for inspections, examinations and tests required by the equipment manufacturer, codes or standards upon completion of the installation, repair or alteration including the pressure testing of pressure components upon completion of the work. A detailed description of the method for conducting the pressure test and acceptable test results will be included in this reference.
- Materials - The manual shall describe the method used to ensure that only certified components and acceptable materials are used for installations, repairs and alterations. The manual shall include a description of how new material, equipment or components are ordered, verified, and marked. The manual shall identify the title of the individual(s) responsible for each function and a brief description of how the function is to be performed.
- Incident and Near-miss Investigation - The management program shall document and implement a process to report and investigate any hazards, potential hazards, incidents or near misses affecting or having the potential to affect the safe operation of the facility. A process for reviewing incidents and near-misses within the facility and reports from across industry shall be developed. Lessons learned shall be incorporated into facility procedures and processes to improve the effectiveness of the operation and maintenance program. Procedures shall be reviewed and modified when necessary to prevent or mitigate future incidents.
Records of investigations shall be maintained for the life of the facility until it is decommissioned.
- Exhibits - Any forms referenced in the manual shall be included. The form may be a part of the referencing document or included as an appendix. For clarity, the forms may be completed and identified as examples. The name and accepted abbreviations of the owner/operator shall be included in the manual.
- Change Management - The management program shall have a systematic process for identifying, evaluating, controlling and documenting any change to facility design, specification, operations, standard, organization or activities and legal requirements to ensure that no unforeseen new hazards are introduced and that the risk of existing hazards to employees, public, or the environment are not unknowingly increased. This process should cover changes such as:
- Ownership of a facility,
- The organization and personnel who operate and maintain the facility,
- Equipment, process, process technology and control systems,
- Operating status, such as idling, facility shutdown, or decommissioning which can introduce “temporary” hazards not expected during normal operations;
- Operating conditions,
- Methods, practices, and procedures related to operation or maintenance of the facility
- Standards and regulations related to facilities operation or maintenance,
- Other installations (e.g., power lines) that cross piping and other equipment or facilities,
- Changes to the facility made to account for environmental factors, such as flood, fire, ground movement, and
- Adjacent land use and development.
- The management of change process should address:
- Identification of anticipated and actual changes,
- What constitutes a change (temporary or permanent) and what falls under replacement in kind, which is not subject to the management of change process,
- Responsibilities and authorities for approving and implementing changes,
- Analysis of implications of the changes,
- Impact and risk of the changes,
- Training required as a result of changes
- Communication of the changes, their impact and required documentation,
- Timing of changes (approval and implementation)
- Internal Audits and Control of Program Non-conformances - The management program shall develop and implement a process for conducting internal audits to verify the implementation of the program. This process must define the responsibilities, scope, objectives, frequency, and schedule for internal audits. The process for completing corrective actions for non-conformances identified through internal audits shall be outlined. The process must also ensure auditor competency and independence.
The management program processes shall be regularly monitored to measure conformance to the requirements of the management program. A process to investigate identified non-conformances, initiating and completing corrective actions shall be implemented
- Management Review - The facility owner or management shall review the adequacy, implementation and effectiveness of the facility’s operation and maintenance program on a regular basis. The review shall evaluate if the program’s goals have been met, compliance to facility and regulatory requirements and identification of actions for continual improvement of the operation and maintenance management program.
Prepared by: Brad Wyatt, Provincial Safety Manager, Gas
Date: October, 2017
Controlled Document: MAN-4058-00