Maintenance Procedures – Propane Facility System Guidelines

 In October 2017, Technical Safety BC issued a detailed technical manual entitled “Maintenance Procedures – Propane Facility Systems Guidelines”.  This document was published to help propane bulk plant operators set up operations and maintenance procedures to address new requirements set forth in the 2015 edition of the B149.2 Propane Storage and Handling Code.  As a companion to the Guidelines, Technical Safety BC also issued a sample Audit Checklist.

To read and download a copy of the Manual, click on the “Read More” button below.

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To read and download a copy of the companion sample Audit Checklist, click on the “Read More” button below.

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Technical Safety BC Issues Directive on Propane Facility Operations and Maintenance Procedures

On October 20, 2017, Technical Safety BC issued a Directive regarding the requirements for Propane Facility Operations and Maintenance Procedures in British Columbia.  New requirements set forth in the 2015 edition of the B149.2 Propane Storage and Handling Code come into effect in British Columbia as of November 1, 2017.  This directive provides details on the new requirements.

To read and download a copy of the Directive, click on the “Read More” button below.

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Incorporating B149 Code Changes Into Daily Operations

This article, related to incorporating B149 code changes into daily operations, first appeared in the 2015 Nov/Dec edition of Propane Canada Magazine.

My last few articles have provided information and discussed the ramifications of the regulatory impact the 2015 editions of the fuels and pressure vessels codes and provincial regulations will have on the propane industry. I like to believe that one of the purposes of these articles is to provide information on the regulatory regime as it develops so that company owners and users of the relevant code and regulations can be proactive rather than being reactive to new requirements.

This got me to thinking that it is great to provide this information but what does a person do with it once they have received it?  If the information ends with the reading of the article and no further steps are taken, then the regulatory impact will result in a non-compliant position subject to the legal means available for enforcement of the codes and regulations by the Authority Having Jurisdiction.


I learned long ago that knowledge, and the ability to translate that knowledge into workable solutions, is key to being proactive and keeping one step ahead of the game. I would, therefore, hope that my articles provide the trigger for readers to take the next steps.

Steps might include identifying areas requiring additional or new development of policies and procedures, as well as to identify training initiatives necessary for employees to continue to complete their tasks in an efficient, cost-effective, and safe manner.

Training Requirements

Training is very vital in any company or organization that aims at progressing. Training simply refers to the process of acquiring the essential skills required for a certain job. It targets specific goals, such as understanding a process or operating a certain machine or system.

It is common knowledge that a properly trained person becomes more informed about procedures for the various tasks he or she must complete and that the person’s confidence is also boosted by training and development. This confidence comes from the fact that the per-son is fully aware of his/her roles and responsibilities. It also helps the person to carry out the duties in a better way and even find new ideas to incorporate into the daily execution of duties.

Legalese Clauses

ComplianceRegulations are written in what I describe as “legalese” which means that the lay-man’s clause wording developed and accepted by the working Technical Committees is reviewed and possibly edited by lawyers to ensure that the clause requirement meets the minimum standard required for enforcement by the Authorities Having Jurisdiction. This sometimes ends up with the clause not being quite as clear or concise as it was when the technical committee first developed the clause and therefore makes it difficult for the worker in the field to feel comfortable interpreting the requirement.

This is where the policies, procedures, and training come into play by ensuring, whether a person is a technician, fuel delivery person or plant operator, that each person in that position gains similar skills and knowledge. This brings each position to a higher uniform level, making the workforce more reliable in completing the task correctly the first time.

More Than Having a New Code

When one understands the requirements for uniform regulatory knowledge, the legalese of the written clauses, and the need for new technical knowledge, the need for effective training becomes evident. The training of technicians, fuel delivery personnel and plant operators is just not as simple as giving those persons a copy of the latest code and provincial regulations.

Recap of 2015 Regulatory Impact

While there have been numerous changes within the 2015 code editions, there are three primary regulatory initiatives which will require propane company owners and users of the codes and regulations to develop and/or edit existing policies and procedures.  These changes will also require training of staff to ensure they can correctly complete the tasks required for the company to meet its regulatory compliance obligations for 2016 forward.

(1) Pressure Relief Valve (PRV) Change Out

As previously stated in my May/June 2015 article on this subject, it is my opinion that this requirement is most likely going to be the most challenging regulatory requirement the propane industry has faced in its history.  This single requirement will put a tremendous strain on the industry’s resources, people, equipment, and finances.

Even before there is any field activity on the replacement of PRVs it is essential the company have in place the necessary policies and procedures and trained staff to perform the actual field work.

The task of replacing PRVs is not as straightforward as it sounds and can be-come quite complicated and complex when you have to consider the logistics of:

  • keeping customers supplied with propane;
  • exchanging the customer’s propane tank (which could require evacuation of the product on-site);
  • dealing with tank components which may not operate as designed or are not available to evacuate the pro-pane from the tank;
  • transporting tanks from the plant to the customer site and then back to the plant;
  • evacuation of the propane from the tank at the plant; and finally
  • replacing the PRV.

This means that companies should already be diligently working on developing their policies and procedures, identifying relevant training programs, and scheduling the training of technicians, helpers, and bulk truck drivers as soon as possible.

(2) Construction Site Cylinder Storage and Use

Cylinder Storage at Construction SitesThere are extensive new requirements that affect how propane cylinders are stored and used on construction sites.  As with the PRV change out, companies will be required to provide new/edited policies and procedures and additional training for cylinder delivery personnel.

Several provinces and territories automatically adopt the latest edition of the code once it is published. For example, the B149.2 Propane Storage and Handling Code was published by CSA in Au-gust 2015.  Provinces and territories that have not already adopted the 2015 code will be doing so in 2016.  This means that some delivery personnel delivering to construction sites for the 2015/2016 winter construction heating season must be trained in the new requirements. In addition, the company must have in place policies and procedures describing how the Company will deliver propane cylinders to the construction site.

(3) New Propane Facility Maintenance Requirements

The purpose of the new clauses in the code is to provide a minimum standard for the operation and maintenance of propane facilities and equipment. The new clauses apply to tank systems, filling plants, container refill centres and other facilities where liquid propane is piped to a vaporizer or process. Because there are many variables, it is not possible for the Code to prescribe a set of operation and maintenance procedures that will be adequate from the standpoint of safety in all cases without being burdensome and, in some cases, impractical. The proposed clauses establish a baseline or minimum standard.

The maintenance procedures are to cover testing, inspection, monitoring, and documenting of the equipment, its repair, and general upkeep.

There is also a requirement for persons who perform maintenance on facility propane systems to be trained in the hazards of the system and in the maintenance and testing procedures applicable to the facility.

Once again, this requirement is already in place in some provinces and territories and will be coming into force 2016 in those provinces and territories that do not automatically adopt the latest edition of the code.

These new requirements will require some companies to develop new policies and procedures with respect to maintenance of the propane facilities described and others to edit the policies and procedures to address the new requirements.  Also, the training component is new within the code and therefore will require the identification of relevant training programs and the scheduling of personnel to take the training.

In Conclusion

It is my hope that this article will be the catalyst for the reader to become proactive and to take the next necessary steps to ensure that his or her company develops the policies and procedures, identifies the training initiatives required, and schedules the training of staff to meet the new regulatory obligations.

The Fuels Learning Centre has developed an extensive training program covering all of the aspects listed above for evacuating propane tanks regardless of location and the change out of the PRV.  The course is currently being studied by several Authorities Having Jurisdiction across Canada for their review and comment, as is the process for all new courses related to regulated activities.  It is anticipated this course will be available for our Instructors to conduct training on or be-fore January 1, 2016.

Also, we have developed a new course to address the requirement for persons who perform maintenance on propane facility systems to be trained in the hazards of the system and in the maintenance and testing procedures applicable to the facility.  We expect this course to be available for our Instructors on or before January 1, 2016, as well.

Our training courses for cylinder delivery and installation of construction heaters already provide the 2015 code requirements your staff and customers will require in order to complete their duties and keep the company in compliance for the 2015/2016 winter construction heating season.

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Nova Scotia Labour & Advanced Education Issues Directive Related to Flare Stacks and Vehicle Parking at Bulk Plants

Nova Scotia logoThis Directive (FSD 2015-003) clarifies the requirement that propane may not be released to the atmosphere and that an approved flare stack must be used to burn off propane from tanks requiring emptying prior to repairs. In addition, the Directive clarifies that only vehicles required for the operation of the bulk plant be parked within the fenced area. Employee and visitor parking is not allowed in the fenced area.

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TSSA Issues Revision to Advisory Related to the Propane Facility License Process

Ontario - TSSA Logo 01This Advisory (FS-188-11 Rev 2), which is the second revision of a previous Advisory describes the process to be followed to license a propane facility, including new requirements for insurance which will take effect on January 1, 2016.

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Fire Prevention and Fire Control at Propane Bulk Plants

Fire prevention and control is key to minimizing risk at the bulk propane storage plant.  This article, which first appeared in the Nov/Dec 2012 edition of Propane Canada magazine discusses the various aspects of fire control and prevention that should be considered.

A client recently asked me, as part of their internal due diligence, to verify that appropriate fire prevention and fire controls were in place and operational at one of their propane bulk plants.  The audit looked at the physical aspects of fire prevention and control as well as related policies and procedures.  The following discusses the items that were addressed in the audit.

Site Security

Site security is the main factor in preventing unauthorized persons from entering the actual propane bulk tank storage yard.  Unauthorized persons may unwittingly provide a source of ignition by either smoking or in the type of clothing they wear.  Nylon outer clothing, shirts, jacket or pants can build up static electricity which can arc with sufficient energy to ignite propane vapours.

The yard must have a controlled entry point.  Gates are used to provide the controlled entry point and fencing around the perimeter of the yard provides the security.  Signage at the entrance to the fenced yard warns unauthorized persons not to enter.  Gates to the propane bulk tank storage yard must be closed and locked when the plant is not in use.

visitors-must-sign-log-sign-s-6763A visitors log is a good way to record who and when a non-employee enters the yards.  Do not let visitors enter the yard unless escorted by an employee at all times. The escorting of non-employees ensures that the visitor does not inadvertently wander into yard traffic areas or propane transfer areas without the benefits of the proper clothing and that the visitor can be led to the evacuation meeting place should an emergency occur.  These rules should apply to the general public as well as municipal, provincial or federal employees attending the facility as part of their work.

It is also important to control the vehicles entering the fenced yard.  Only allow essential vehicles to enter the fenced yard.  Do not permit customer vehicles or employee vehicles to enter or park in the yard area.  Provide parking spaces for customers and employees outside the fenced yard.  Bulk trucks and cargo liners which are stationed out of the facility must, when parked, be within the fenced yard area.

Tank Protection

To prevent the release of propane from a damaged propane container or piping system, propane bulk storage tanks, as well as transient tanks and cylinders, must be protected from physical damage by either their location or barriers such as concrete filled posts, steel guard rails, and post or New Jersey concrete turnpike barriers.


No smoking signs, turn off ignition signs, and UN1075 placards, as well as the company name and logo, stenciled on the propane bulk storage tanks, bulk trucks and cargo liners can act as a constant warning as to the product stored and transferred at the plant.

Dispenser Warning Signs 01 - Original


A key component of fire prevention is training.  Trained and certified personnel must only be allowed to drive bulk trucks/cargo liners, load and unload and to operate the facility.  Ensure that employees have the correct training and level of certification before allowing them to perform any functions within the plant.


It is essential that persons working within the propane bulk storage yard wear the appropriate clothing.  Clothing can be cotton or blends of material as long as it does not build up a static electric charge.

Control of Ignition Sources

When looking at controlling ignition sources one must consider the installation of the bulk storage tanks, ongoing maintenance of the grounds and components, leak control and propane released during the transfer process.  Ignition sources are controlled within a propane bulk plant by incorporating employee training, wearing appropriate clothing, and by:

  1. Ensuring that distances listed in the Code are initially provided and maintained from tanks and points of transfer, property lines and buildings.
  2. Ensuring the area around and under the bulk storage tanks gravel or asphalt are free of vegetation or material storage.
  3. Having all electrical components rated explosion proof Class 1, Group D.
  4. Using hose end valves at unloading and loading bulkheads which are designed for limited liquid propane release on disconnect.
  5. Equipping Liquid and vapour openings in all tanks with Internal Safety Control Valves (ISC) that are closed when the plant is not in operation.
  6. Unloading of cargo liners and loading of bulk trucks is through bulkheads equipped with Emergency Shut-off Valves and back check valves.
  7. Having a grounding system in place at all unloading and loading bulkheads to prevent the buildup of static electricity.
  8. Using CSA certified hose assemblies used to transfer propane in and out of the plant which are inspected and tested annually in accordance with the requirements of Transport Canada Regulations and CAN/CSA B620 Highway Tanks and Portable Tanks for the Transportation of Dangerous Goods Standard.
  9. Permitting only cargo liner tanks and bulk truck tanks which are built, inspected and tested in accordance with the requirements of Transport Canada Regulations and CAN/CSA B620 Highway Tanks and Portable Tanks for the Transportation of Dangerous Goods Standard.

Fire Control

Fire control relies on the physical plant design, components, and internal and external resources. The following is a list of items that one would expect to be in place to control a fire within a propane plant.

  • Nitrogen or air activated valves with emergency shutdown stations located around the plant. As a minimum, shut down stations would be at each loading and unloading bulkhead and a safe area outside of the fenced yard.
  • Air actuated Internal Safety Control Valves (ISC) and Emergency Shut-off Valves (ESV) which close on loss of nitrogen or air pressure. Nitrogen or air pressure is supplied by plastic tubing that melts if exposed to temperatures generated by fire or radiant heat causing a loss of air pressure within the system resulting in the automatic closure of all ISC and ESV valves.
  • Plants equipped with cable operators which have fusible links that melt if exposed to temperatures generated by fire or radiant heat causing the cable to separate which allows the ISC or ESV to close
  • Hand-held fire extinguishers must be placed strategically around the facility to help control possible fire situations. Fire extinguishers must also be inspected and tagged annually by a company that specializes in maintaining fire extinguishers. Part of the monthly plant inspection must provide for fire extinguisher inspection to ensure the fire extinguisher is actually in place and properly charged.
  • Since the local fire department (which may be a volunteer force) responds to calls at the facility, it is important to meet with the fire services and obtain a listing of the equipment that can be used to respond to a fire at your facility. This is also an opportune time to have the fire services visit the site.
  • Sufficient space maintained in the yard to maneuver fire trucks for position to fight fires.
  • Provincial or local fire services may also request additional fire suppression systems to be installed with a dedicated water supply to cool tanks and provide protection for emergency response personnel.
  • It is a prudent exercise to look at the fire prevention and fire control systems and processes at your propane bulk storage plant on an annual basis to ensure that the correct policies and procedures are in place, all components are maintained and operate as required and that employees know what to do in the case of an incident.


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