Regulator s Perspective

Transcription

1 NEB Workshop Regulator s Perspective ABSA Calgary, June 28 & 29, 2017 Rev

2 Objectives To inform about IB Concerns about Carbon Steels with Low Toughness Properties ABSA s Role 2

3 A/SA-105 Material - Concerns (1/2) It has been reported that some flanges made of SA-105 material may have low toughness properties. Other common carbon steel materials were also found to have unexpected low toughness values (e.g. SA-106, SA-234) Low toughness can result in brittle fracture of the material during hydrostatic tests, cold startups, or upset conditions that result in low temperature operations. 3

4 A/SA-105 Material - Concerns (2/2) Based on the industry reports, the following factors seem to contribute to low toughness values of carbon steels: Chemistry Heat treatment Grain size Inadequate manufacturing processes Material specifications do not specify minimum toughness requirements

5 ASME Code - Proposed Changes (1/2) The ASME code committee approved the item that will: assign "as forged" A/SA-105 forged flanges to Curve A for toughness considerations, and impose a limit of 0 F (-18 C) Minimum Design Metal Temperature (MDMT) for the exemption of "as forged" A/SA-105 forged flanges from impact testing under the rules of UCS-66(g),

6 ASME Code - Proposed Changes (2/2) If A/SA-105 forged fittings and flanges are normalized after forging, these flanges and fittings may be assigned to Curve B. The 2019 edition of ASME BPV Code will include this change.

7 What is ABSA? ABSA has been delegated by the Alberta Government as the organization responsible for the administration and delivery of safety programs related to pressure equipment in Alberta. It is a not-for-profit organization reporting to a volunteer Board of Directors. 7

8 ABSA s role in the Alberta Pressure Equipment Industry is ABSA is the regulatory authority whose ultimate quality objective is to prevent injury to people arising from the operation of pressure equipment. 8

9 AER - ABSA Steam distribution pipelines and high temperature pipelines Specific characteristics of these pipelines Reason for the use of CSA Z662 Clause 14 or Annex I for steam distribution pipelines and high temperature pipelines Pipeline Rule, Directive 077 IB content/uploads/2015/04/ib10-006_r3.pdf

10 Open Forum Discussion - Questions - 10

11 Additional Topics for Discussion If time allows, we should talk about: Regulations vs. Codes Why is design registration required ABSA s design registration process Limitations of CSA Z662 Clause 4 and need to use Clause 14 or Annex I for steam distribution pipelines and high temperature pipelines Relationship between Pipeline Rules and Pressure Equipment Safety Regulation 11

12 The Regulation vs Codes / Standards The weight of the Pressure Equipment Safety Regulation is more than all codes and standards combined. AR 49/2006

13 Timeline Colonization of North America progresses. The Steam Boilers Ordinance of the Northwest Territories Boilers Branch formed. Province of Alberta created. Boilers Branch changed, with the support of industry, into ABSA In North America, 10,000 pressure equipment explosions 10,000 fatalities 15,000 injuries 13

14 Design Survey Process Target is 15 working days for the initial design survey 50% Quality of design submission Design arrives in ABSA Submission log-in Survey design Is submission acceptable for registration? Yes Mailing and Invoicing Record retention End No 50% Submitter provides resubmission / answers 14

15 Percentage of Designs that Passed the Initial Design Review Without Deficiencies

16 CSA Z662 Limitations of CSA Z662 Clause 4 and need to use Clause 14 or Annex I for steam distribution pipelines and high temperature pipelines

17 For more info: Refer to Directive 56 FAQ 17

18 Pipeline Rules (AR 91/2005) Section 3(2) states: for a steam distribution pipeline having an internal aggregate capacity greater than 0.5 cubic metres, the licensee shall (a) confirm in its application to the Regulator that it has registered the design of the pipeline and any mechanical coupling with the Alberta Boilers Safety Association in accordance with the Design, Construction and Installation of Boilers and Pressure Vessels Regulations (AR 227/75), and (b) obtain all required approvals from the Alberta Boilers Safety Association prior to putting the pipeline into operation. 18

19 Pipeline Rules (AR 91/2005) It will be more accurate if section 3(2) states: for a steam distribution or high temperature pipeline having an internal aggregate capacity greater than 0.5 cubic metres, the licensee shall (a) confirm in its application to the Regulator that it has registered the design of the pipeline and any mechanical coupling with the Alberta Boilers Safety Association in accordance with the Design, Construction and Installation of Boilers and Pressure Vessels Regulations (AR 227/75) Pressure Equipment Safety Regulation (AR 49/2006), and (b) obtain all required approvals from the Alberta Boilers Safety Association prior to putting the pipeline into operation. For more info: Refer to Directive 77 19

20 Alberta s Pipeline Act vs. Safety Codes Act Alberta s Pipeline Safety Codes Act Act, Pressure Equipment Pipeline Rules Exemption Order Other Regulations Pressure Equipment Safety Regulation Note: Pressure Welder Pipeline Rules Regulation refer directly to the Power Engineer PESR, and Regulation by-pass the PEEO For more info: Refer to Directive 77 20

21 AER Directive 77 vs. PEEO, Section 2(1)(e) for Steam Pipelines Section 2(1)(e) exempts pipelines from the SCA Alberta Energy Regulator has issued Directive 077 which establishes requirements for steam pipelines and high temperature pipelines used in recovery of hydrocarbons (Part B, Section 3). In general, ABSA is responsible for design registration, construction, operation and maintenance of these steam distribution and high temperature pipelines. See Information Bulletin IB Rev.3. 21

22 Information Bulletin IB Rev. 3 I Introduction This Information Bulletin is intended to supplement, and should be reviewed with, AER Directive 077 In general, design registration, construction, operation, and maintenance of steam pipelines is under ABSA s programs. IB specifies the application of ABSA s programs to steam pipelines and high temperature pipelines that are regulated under the Pipeline Act in accordance with AER Directive