PROPOSED AMENDMENTS TO PART 23: OIL AND GAS TO THE OCCUPATIONAL HEALTH AND SAFETY REGULATION

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1 Online APPENDIX Feedback 1 PART 23: OIL AND GAS Definitions 23.1 In this Part: flow piping system means a temporary or portable system of piping and other component parts, including valves and fittings, that is (a) located above ground, and (b) for use to convey to or from a well head a liquid under pressure, or a gas under pressure, during drill stem testing, swabbing, cementing, well servicing or well stimulation; Pumps (1) A positive displacement pump and attachments must have valves, pipes and fittings capable of withstanding the pump's maximum working pressure. (2) A quick closing type valve must not be used on the discharge line of a positive displacement pump. (3) A positive displacement pump must be protected against freezing. (4) Except for a pumping wellhead well head, a pressure relief device must be installed on the discharge side of a positive displacement pump, but a valve must not be installed between them. (5) For a wellhead well head utilizing a down-hole positive displacement pump, the employer must implement measures to prevent the pump from causing pressures that exceed the pressure rating of the system. Liquefied gas used for purging or gauging operations or well stimulation The employer must ensure that workers are protected from hazards that may be caused by the release of liquefied gas being used for purging or gauging operations or well stimulation. Flow piping (1) Flow piping systems must be anchored during well testing or stimulation unless there is an effective quality assurance program to ensure integrity of the piping system. (2) The quality assurance program must include routine inspections, nondestructive testing, pressure testing, identification of piping components, and piping specifications that meet the service application. (3) If swivel joints or hoses are used in well stimulation and similar operations, the piping system must be secured at the well head and supply vehicle or pumping unit end with wire rope safety lines not less than 11 mm ( 7 /16 in) in diameter, or chains of equal strength. (4) Flowback lines must be anchored and restrained. Page 1

2 (5) If a system of piping and swivel joints with a pressure greater than kpa (300 psi) is used in well stimulation and similar operations (a) the operation must be conducted by remote control, (b) unauthorized workers must not enter the area between the point of discharge and the well head, and (c) before starting operations, warning signs must be posted in the area stating "DANGER, NO UNAUTHORIZED WORKERS ALLOWED IN THIS AREA" or other similar language. (6) Subsections (3) and (5) do not apply to well testing. (7) In a flow piping system exceeding kpa (500 psi), (a) connections must be welded, flanged or hammer unions, and (b) if there is only a threaded connection available at the well head, special precautions must be taken. (8) A piping system must be completely depressurized before leaking connections or fittings are corrected. (9) Hammering on a pressurized system is not permitted. (10) Repealed. [B.C. Reg. 312/2003.] (11) If liquid carbon dioxide or other liquified gas is used for well stimulation, the valve controls of the supply unit must be on the side opposite to the pipe supplying the liquified gas. Flow piping systems integrity assurance program (1) The employer must develop and implement a program for the purpose of ensuring the integrity of the flow piping systems at the worksite. (2) In fulfilling the requirements of subsection (1), the employer must take into consideration the conditions under which the flow piping systems may operate, including, without limitation, corrosion factors and fluctuating temperatures and pressures, and must include provision for the following elements: (a) routine inspections, non-destructive testing and pressure testing of piping and other component parts of the flow piping systems, including setting out in writing, for each type of part to be inspected or tested, (i) the inspection or testing procedure, (ii) the frequency of inspection or testing and how the frequency is to be determined, Page 2

3 (iii) the criteria for rejection of a part and its removal from service, and (iv) the method of determining how frequently a part is to be replaced, including the basis for replacement; (b) preparing, updating and making readily available at the worksite an up-to-date document, relating to the inspections and testing referred to in paragraph (a), that identifies each part that has been inspected or tested, and sets out, for that part, (i) the inspection or testing procedure followed, (ii) the results of the inspection or testing, and (iii) if a part has been rejected, the rejection criteria applied; (c) periodic reviews and updates of the program; (d) a system of preparing and retaining records in relation to each element of the program. (3) The employer must assign to a qualified person responsibility for administration of the program referred to in subsection (1). Flow piping systems selection, installation, operation and inspection The employer must ensure that (a) the flow piping systems at the worksite are (i) selected based on the manufacturer s specifications, having regard to the systems anticipated operation, and (ii) installed, operated and inspected in accordance with the manufacturer s instructions and specifications, and (b) copies of all of the manufacturer s instructions and specifications in relation to the flow piping systems are readily available at the worksite. Flow piping systems restraint systems (1) The employer must ensure that each flow piping system at the worksite is restrained by an engineered restraint system that is designed and manufactured (a) to be used for the purpose of safely restraining the flow piping system, and (b) to withstand the forces that may be encountered if the flow piping system fails. Page 3

4 (2) If a restraint system has been manufactured by a commercial manufacturer, the employer must ensure that the restraint system is installed and anchored in accordance with the instructions and specifications of that manufacturer. (3) If a restraint system has been manufactured by the employer or another persons who is not a commercial manufacturer, the employer must ensure that (a) engineering documentation has been prepared demonstrating that the restraint system has been designed and manufactured as described in subsection (1), (b) the restraint system is installed and anchored in accordance with the engineering documentation, and (c) a copy of the engineering documentation is readily available at the worksite. (4) In addition to meeting the requirements of subsection (2) or (3) (b), the employer must ensure that each restraint system is anchored at both the well head and the supply vehicle or pumping unit, but a restraint system need not be anchored to the well head or to the supply vehicle or pumping unit. (5) The employer must ensure that temporary ground anchors that are part of a restraint system are pull tested before initial use and, if they continue to be used, that they are tested annually and whenever they may have been affected by seasonal changes. Flow piping systems other requirements (1) If the pressure of a flow piping system may exceed kpa (435 psi), the employer must ensure that all of the flow piping system connections are welded or flanged or are hammer unions. (2) The employer must ensure that a flow piping system is completely depressurized before a leak in a connection or fitting in the flow piping system is corrected. (3) The employer must ensure that a person does not hammer on a pressurized flow piping system. (4) If workers are using liquefied gas for well stimulation, the employer must ensure that the unit that supplies the liquefied gas and the unit that pumps the liquefied gas are positioned so that the valve controls of each unit are on the opposite side of that unit from the piping that supplies the liquefied gas to the well. Pressure testing requirements (1) Before commencing a service operation, piping, pumps, valves and fittings to be used in the operation must be hydraulically tested to a pressure not less than 10% above the maximum anticipated operating pressure as determined by the well owner. Page 4

5 (2) Before commencing well testing or flowback operation, flow line piping, valves and fittings from the well head to the first pressure control choke must be hydraulically pressure tested to a pressure not less than 10% above the maximum anticipated shut-in pressure as determined by the well owner. (3) When nitrogen is being used in well stimulation, the piping system may be pressure tested with nitrogen provided that the nitrogen treating line is connected to the main line as close to the well as practicable. (4) Documentation of the testing must be available on the worksite for inspection by an officer. (5) Air must be purged from the piping system before pressurizing low flash point hydrocarbons. Pressure testing requirements (1) The employer must ensure that, before a well service operation commences, piping, pumps, valves and fittings that are to be used in the operation have been (a) hydraulically pressure tested, or (b) if hydraulic pressure testing is not practicable, pressure tested with an inert gas, to the pressure determined under subsection (2). (2) The pressure to which piping, a pump, a valve or a fitting is to be tested under subsection (1) is (a) the test pressure recommended by the manufacturer of the piping, pump, valve or fitting, or (b) if the manufacturer has not recommended a test pressure, to a pressure that is at least 10% above the maximum operating pressure anticipated by the well owner, except that the test pressure must not exceed the maximum pressure rating of that piping, pump, valve or fitting. (3) The employer must ensure that, before a well testing or flowback operation commences, the flow piping system from the well head to the first pressure control choke has been (a) hydraulically pressure tested, or (b) if hydraulic pressure testing is not practicable, pressure tested with an inert gas, to the test pressure recommended by the manufacturer of the flow piping system or, if the manufacturer has not recommended a test pressure, to a pressure that is at least 10% above the maximum shut-in pressure anticipated by the well owner. (4) The employer must ensure that documentation of the results of the testing required under subsections (1) and (3) is readily available at the worksite. Page 5

6 (5) The employer must ensure that if (a) nitrogen is being used in well stimulation, and (b) the flow piping system that supplies the nitrogen to the well is pressure tested with nitrogen, the nitrogen treating line is connected to the main line as close as practicable to the well. (6) The employer must ensure that, before a flow piping system is pressurized with low flash point hydrocarbons, the air has been purged from the flow piping system. EXPLANATORY NOTES TO THE PROPOSED AMENDMENTS: In recent years, due to advancing technologies, the operating pressures of flow piping systems are far greater than the pressures when the current requirements were developed under the Occupational Health and Safety Regulation ( OHSR ). Serious injuries can occur to workers when flow piping systems fail and the component parts are not restrained properly. Current section 23.69(3) of the OHSR requires the use of 11 mm (7/16 inch) wire rope restraint lines for swivel joints or hoses used in well stimulation or similar operations. The restraints must be secured at the well head and at the supply unit or pumping unit head. These requirements do not allow for other types of restraints to be used that may provide equal or greater protection. WorkSafeBC has received variance requests over the last few years to allow other restraint systems, such as synthetic restraint lines to be used in place of the wire rope restraints. This illustrates that the wire rope restraints may not be as protective as some other types of restraints. The purpose of the proposed amendments to section is to ensure that flow piping systems are safe under the conditions being operated and for them to be properly restrained. Page 6

7 Proposed new definition of flow piping system: A definition of flow piping system is proposed to provide clarity to stakeholders about the type of piping being discussed in this section. The proposed flow piping system requirements apply to temporary or portable above ground piping systems used to convey liquid or gas under pressure to or from a well head. Applicable activities include drill stem testing, swabbing, cementing, well servicing and stimulation of the well, as well as service rig well servicing activities that uses flow piping systems. Proposed subsections 23.69(1) and (2): Integrity assurance program The current wording of subsection 23.69(1) requires flow piping systems to be anchored during well testing and stimulation, unless there is an effective quality assurance program to ensure the integrity of the piping system. Subsection (2) elaborates on what is required as part of the quality assurance program. WorkSafeBC is proposing that employers develop and implement an effective program for ensuring the integrity of the flow piping systems regardless of whether it is anchored or the type of well operation. In the oil and gas industry, this program is commonly referred as an Operations and Maintenance (O&M) Program. Flow piping systems experience a variety of harsh operational conditions, such as high pressures, corrosion, and extreme temperatures. Under the dynamic nature of well operations, the implementation of the program is one of the ways to ensure that flow piping systems do not fail in a catastrophic manner. The pertinent points contained in the current prevention Guideline G23.69, Flow Piping, were incorporated in the proposed requirements of the program in subsection (2). Proposed subsection 23.69(3): Qualified person to administer the program The proposed subsection 23.69(3) requires that the employer assign a qualified person responsibilities for administering the program. This is a person who has knowledge of the flow piping system and ensures that the required elements of the program are fully implemented. Proposed subsection : Selection, installation, operation and inspection During the last public consultation, stakeholders raised that the proposed amendments with a requirement for a professional engineer to certify flow piping systems prior to use was redundant and unnecessary since the components of flow piping systems already have operating specifications from the manufacturer. Based on the stakeholder feedback, the proposed amendments have removed the requirement for flow piping systems to be certified by a professional engineer. Instead, the proposed section requires that the employer ensure that flow piping systems are selected based on the anticipated operating conditions and installed, operated and inspected in accordance with the manufacturer s instructions and specifications. Copies of the flow piping manufacturer s instructions and specifications must be readily available at the worksite. Proposed subsection : Restraint systems Currently, subsection 23.69(3) requires that, if swivel joints or hoses are used in well stimulation and similar operations, the piping system be secured at the well head and the supply vehicle or pumping unit end with wire rope safety lines not less than 11 mm (7/16 in.) in diameter, or Page 7

8 chains of equal strength. This requirement is restrictive to employers who may wish to use other restraint systems that may offer equal or better protection to workers. Also, stakeholders have informed WorkSafeBC that some well heads may not be designed for the purpose of withstanding external loads and there are similar issues with anchoring to pumping units or vehicles. Current subsection 23.69(4) states that flowback lines must be anchored and restrained. The proposed subsection requires that each flow piping system be restrained by an engineered restraint system and anchored at specified locations. The engineered restraint system must be designed and manufactured for the purpose of safely restraining the flow piping system and it must be able to withstand the forces likely encountered during failure of the flow piping system. The proposed amendments allow restraint systems that were not commercially manufactured to be used if they were designed and made for the purpose of restraining piping systems and there is detailed engineering documentation for the restraint system. As stated in the current Prevention Guideline G23.69 (3), the detailed engineering documentation would include information such as: installation instructions, engineering specifications and drawings, precautionary information and limitations, testing certification, other instructions for component use, maintenance, inspection and removal from service, and certification by a professional engineer that the restraint system has been engineered and is adequate for the intended purpose. The proposed amendments require that a restraint system is anchored in accordance with the instructions and specifications of the manufacturer of the restraint system at the well head, the supply vehicle or pumping unit, but not necessarily to the well head or the supply vehicle or pumping unit. Other effective anchor points must be used in close proximity to the well head, the supply vehicle or pumping unit. The manufacturer or the engineering documentation may also stipulate other locations as well. When ground anchors are used, they must be pull tested prior to initial use. Where ground anchors may not be feasible, other types of anchors, such as cement weights may be used. Proposed subsection : Other requirements The intent of the proposed subsection (1) is similar to the current requirement of subsection 23.69(7), except that the proposed pressure is lowered from 3500 kpa to 3000 kpa to be consistent with Alberta s requirement and it is more protective. It is likely that most operations are well beyond this threshold so the impact of the change to industry stakeholders should be minimal. The intent of the proposed subsections (2), (3), and (4) is similar to the current requirements of subsections 23.69(8), (9) and (11) with some changes to the wording for clarity. Proposed subsection : Liquefied gas used for purging or gauging operations or well stimulation A consequential amendment is proposed to add a new subsection , relating to liquefied gas used for purging or gauging operations or well stimulation. The proposed new subsection is to address the potential hazards of using liquefied gas for purging or gauging operations or well stimulation. Currently, the hazards of liquefied gas are addressed in section Page 8

9 23.69(11), but it is specific to the locations of valves during a well stimulation activity. There are other hazards associated with handling liquefied gas that workers must be protected from, such as extreme temperatures and pressures. Proposed subsections 23.72(1) to (6): pressure testing requirements The proposed amendments to section clarify the current requirements by reflecting the current practices of the industry. The current requirement does not provide guidance to stakeholders about the maximum test pressures. Under some circumstances, it is not practicable to hydraulically pressure test piping, pumps, valves and fittings, so a provision was made to pressure test with an inert gas. Also, these components must be tested to the test pressures recommended by the manufacturer of these parts. If the manufacturer has not recommended a test pressure, the test pressure must be at least 10% above the maximum operating pressure anticipated by the well owner, but not exceed the maximum pressure rating of that piping, pump, valve or fitting. Page 9