DECISION AND ORDER 2020 NSUARB 8 M09557 NOVA …

DECISION AND ORDER 2020 NSUARB 8 M09557

NOVA SCOTIA UTILITY AND REVIEW BOARD

IN THE MATTER OF THE PIPELINE ACT AND THE GAS PLANT FACILITY REGULATIONS AND THE NOVA SCOTIA CODE OF PRACTICE FOR LIQUEFIED NATURAL GAS FACILITIES

-and-

IN THE MATTER OF AN APPLICATION by PIERIDAE ENERGY (CANADA) LTD. forthree variances from the Code of Practice respecting a Liquefied Natural Gas (LNG) Facility at Goldboro, Guysborough County, Nova Scotia

BEFORE: Jfiy Roland A. Deveau, Q.C., Vice Chair- M -Steven M. Murphy, MBA, P.Eng., Member

QxItjXRichard J. Melanson, LL.B., Member

DECISION AND ORDER

WHEREAS by Order of the Nova Scotia Utility and Review Board issued November 5, 2018, it granted to Pieridae Energy (Canada) Ltd. (Pieridae) a Permit to Construct a Liquefied Natural Gas (LNG) Facility at Goldboro, Guysborough County, Nova Scotia;

AND WHEREAS the Certifying Authority for the Board pursuant to s. 22 of the Gas Plant Facility Regulations (Nova Scotia) (Regulations) is Lloyd’s Register North America Inc. (Lloyd’s Register);

AND WHEREAS by application dated December 12, 2018, Pieridae requested three variances from the Nova Scotia Code of Practice for Liquefied Natural Gas Facilities - July 2005 (Code of Practice);

AND WHEREAS in support of the application Pieridae submitted as its primary submission that “the CSA Z276-18 Canadian Code covering Liquid Natural Gas Storage and Handling now dates from January 2018 and reflects many aspects of technology that have become State of the Art in the intervening period”;

Document: 273379

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AND WHEREAS Lloyd’s Register filed its Reports with the Board on September 10, 2019, respecting its review of the requested variances and it concluded that “the proposed deviation[s] meets the intent of the code, subject to compliance with measures outlined in the attached [Comment Response Sheets]”;

AND WHEREAS the Board has the authority to approve the said variances pursuant to the Pipeline Act, R.S.N.S. 1989, c. 345, the Regulations, and section 1.2 of the Code of Practice where the application is supported by an assessment that demonstrates equal or greater safety;

AND WHEREAS the Board conducted a paper hearing into the matter and finds that the three variances should be granted, subject to Pieridae complying with the measures outlined by Lloyd’s Register;

IT IS HEREBY ORDERED that the following three variances are approved and the Permit to Construct (NG-PIER-01) is amended accordingly:

a) that the use of design spills as per paragraph 4.2.2.1 of the Code of Practice be waived and the Canadian Code CSA Z276-18 be used in its place;

b) that the use of impounding for full containment LNG tanks as per section 4.2.2.1 of the Code of Practice be waived and the rules contained in the Canadian Code CSA Z276-18 be applied in its place; and

c) that the design data information required by the Code of Practice Appendix B, Section (i) - Process Flow Diagrams (PFDs) and Section (j) - Piping and Instrumentation Diagrams (P&IDs) be modified.

IT IS FURTHER ORDERED that the conditions relating to the above approvals are more fully set out in Schedules A, B and C, respectively.

IT IS FURTHER ORDERED that in all other respects the terms and conditions in the Permit to Construct remain in full force and effect.

DATED at Halifax, Nova Scotia, this 20th day of January, 2020.

Clerk of the Board

Document: 273379

Schedule A¥ift

1 NOVA SCOTIA

l UTillTY AND REVIEW BOARDLloyd'sRegister

Application for Variance - Goldboro LNG |

Doc N°: PED AfV 0002 Page 1 of 1 || Topic Spills from Transport Lines

Date of Application to NSUARB by PEP: 12th Dec 2018Part 1. Variance Sought by PED:PEL requests that the use of design spills as per paragraph 4.2.2.1 of the Nova Scotia Code for LNG Handling Faculties is waived and the Canadian Code CSA Z276-18 is used in its place.Part 2. Justification Provided by PEDPoint 2 relates to the "largest total quantity of LNG or other flammable liquid that could be released from a single transfer line in ten minutes." Both NFPA 59A and CSA Z276-18 are prescriptive and CSA Z276-18 states in paragraphs 5.2.2.2 and 5.4.3 that a design spill should be based on values in Table 2. Table 2 defines design spills where the maximum flow will be for a loss of inventory from a 60 mm hole with flow for 10 minutes. For completeness the European Code EN1473 uses design spills established by risk analysis. In many cases known to PEL this actually leads to maximum design spills being less than those advocated by the Canadian Code with larger spill being shown as non-credible.Part 3. LR recommendationLR have investigated relevant factors which are reported in CRS N°N001-02-Goldboro-002 Rev 01 attached and have concluded that the proposed deviation

Meets the intent of the code, subject to compliance with measures outlined in the attached CRS

For Lloyds Register (name, signature, date)

Stephen Duffy, 10th September 2019

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Project Manager

Document: 273409

Comment Response SheetLloyd's Register Energy

Client:Project:Client Contract No: Transmittal No: Client reference:

Nova Scotia Utility and Review Board Goldboro Regulatory Variance PRJ11081799 E-mail

CRS number:Revision:Status:CRS Date: Page:

N001 -02-Goldboro-002 01Closed 04 July 2019 1 of 4

Attention: Keith ThomasCopied to: Stephen Duffy

SUBJECT SPILLS FROM TRANSPORT LINES

DOCUMENT APPRAISAL STATUS SUMMARYThe document(s) below have been examined in accordance with the Work Instruction(s) referenced and are assigned the status code(s) indicated, subject to the following comment(s):

Document No. I Rev. I Title I Status

PED AFV 0002 12/12/18 SPILLS FROM TRANSPORT LINES AC

COMMENT STATUS KEY # = Closed Comment Open Comment

APPRAISAL STATUS KEYA = Approved/Accepted AC = Approved/Accepted with conditions H = Hold Q = Queries

R = Rejected, not acceptableRl = Retained as supporting documentation for information onlyS = SupersededI = Requested for Information only

FINAL ACCEPTANCE DEPENDS ON SATISFACTORY SURVEY AND TESTINGLloyd's Register Group Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as 'Lloyd's Register1. Lloyd's Register assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd's Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

Document: 273409

Lloyd's Register Energy

Comment Response Sheet

Client: Nova Scotia Utility and Review Board CRS number: N001-02-Goldboro-002Project: Goldboro Regulatory Variance Revision: 01Client reference: Page: 2 of 4

DOCUMENT APPRAISAL DETAILS

PED AFV 0002 12/12/18 SPILLS FROM TRANSPORT LINES AC

Work Instruction(s): UARB-PIER-GOLD-PWI-1001

1 • Technical Safety Comments

1.1 £ LR have consider the application for a variance from the requirements listed in theNova Scotia Department of Energy Code of Practice, version 1, July 2005, section 4.2.2.1. on the basis of the following information:

1. Section 1, Nova Scotia Dept Energy Code, 20015. As acknowledged in Section 3.1 of CSA Z276-01, new concepts in the production, storage, and use of LNG are still evolving, and advancements in engineering and improvements in equipment may result in LNG facility design, equipment fabrication methods, and operating practices that differ from this Code of Practice. However, such changes or improvements may provide desirable safety and operational aspects that meet the intent of this Code of Practice.

2. The eleventh edition of CSA Z276, Liquefied natural gas (LNG) —Production, storage, and handling, supersedes the previous editions published in 2015, 2011, 2007, 2001, 1994, 1989, 1981, 1978, 1973, and 1972.

3. Section 14.1, Z276-01. The risk-based approach is not a replacement for the application of codes and standards. The strict application of codes and standards is most appropriate for facilities which are well understood and whose design, in many cases, has been developed over many years. The risk-based approach towards design is an opportunity to reduce risk below the “code only” level and is applied when there are few or complex facilities of a low number and where control of risk needs to be enhanced, or where code requirements do not apply or do not exist. Both prescriptive and risk-based approaches are used in the planning, design, and operation of LNG plants.

4. EN 1473.4.3.1 Safety philosophy approach.LNG installations shall be designed to provide generally accepted levels of risk (see Annex K) for life and property outside and inside the plant boundaries. In order to ensure this high level of safety in the LNG facilities and its surroundings, safety shall be considered throughout all the project development phases: engineering, construction, start-up, operation and decommissioning. In particular, hazard assessments, see 4.4, shall be carried out and the required safety measure implemented to ensure acceptable risk levels.

LR have considered the request to apply a risk based approach towards design as an opportunity to reduce the risk to below, "code only" levels. This request meets the intent of the Nova Scotia Code, 2005, subject to conditions described in section 14 of Z276-18 (Risk Assessment for LNG Plants and EN 1473 Safety Philosophy

FINAL ACCEPTANCE DEPENDS ON SATISFACTORY SURVEY AND TESTINGLloyd’s Register, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively referred to in this clause as the ‘Lloyd s Register Group’. The Lloyd's Register Group assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd s Register Group entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

Document: 273409



Client: Nova Scotia Utility and Review BoardProject: Goldboro Regulatory VarianceClient reference:

CRS number: N001-02-Goldboro-002 Revision: 01Page: 3 of 4


Approach).(Comment by Ian Thomas)

PEL Response: No further comment

Process Safety Comments

2.1 £ LR Process Safety have considered the application for a variance from therequirements listed in the Nova Scotia Department of Energy Code of Practice, version 1, July 2005, Appendix B, section 4.2.2.1 related to Impoundment Area Capacity on Vaporization, Process or Transfer Areas on the basis of the following considerations:

1. The applicant has proposed the use the Canadian Code CSA Z276-18 instead of the NSDECoP prescriptive requirement

2. Similar criteria to that stated in CSA Z276-18 is found in other relevant international standards such as NFPA 59A, EN 1473.

3. CSA Z276-18 Section 5.4.3 provide a semi-prescriptive guidance for Spill Design;

4. Also, CSA Z276-18 Section 4.1 indicates that advancements in engineering and improvement in equipment will result in LNG Facilities Design that might not be covered by this standard

5. CSA Z276-18 Section 4.3.2 indicates that each LNG Plant shall:1. have a risk management system that defines a risk base approach to

planning, design, ...2. assesses risks according to Clauses 14.1 and 14.23. is integrated into all phases of the project development and decision

making processes, addressing risk to members of the public, personnel in the plant,...

4. implement risk reduction measures, as necessary, to control risk to ALARP level

6. CSA Z276-18 Section 14 provides criteria for Risk Base approach for LNG Plants

1. It is also known that the applicant is to develop at detail design stage a risk assessment identifying all those credible LNG releases through the use of an appropriate methodology and use of data which is publicly available, defensible and referenceable and, through this assessment, it is possible to identify all those credible releases.

7. In either of these two CSA Z276-18 guidances, the final design of the spill collection system is to be appropriate to collect at least the largest identified spill for each of related process areas.

The variation request meets the intent of the Department of Energy Code of Practice, 2005(Comment by Manuel Dominguez-Santisbon)

PEL Response: No further comment

FINAL ACCEPTANCE DEPENDS ON SATISFACTORY SURVEY AND TESTINGLloyd's Register Group Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as 'Lloyd’s Register*. Lloyd's Register assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd's Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

Document: 273409






In preparing this report, the undersigned surveyor is acting as an independent person in accordance with the applicable policy on conflict of interest.

Surveyor to Lloyd’sRegister: Ian Thomas/Manuel Dominguez-Santisbon

Co-ordinator /.Project Manager: Stephen Duffy

Client Response Prepared by:Dated

Keith Thomas 17.07.2019

FINAL ACCEPTANCE DEPENDS ON SATISFACTORY SURVEY AND TESTINGLloyd's Register Group Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as 'Lloyd's Register*. Lloyd's Register assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd’s Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

Document: 273409

Schedule B

1i ,; NOVA SCOTIA [ UTILITY AND REVIEW BOARD !

LloydsRegister

Application for Variance - Goldboro LNGDoc N°: PED AfV 0001 Page 1 of 1 I

Topic Impounding for Full Containment LNG Tanks

Date of Application to NSUARB by PEP: 12th Dec 2018Part 1. Variance Sought by PED:PED request that in the particular case of Goldboro LNG, NSUARB waives section 4.2.2.1 of the Nova Scotia Code of Practice for LNG Handling Facilities in favor of applying the rules contained in the Canadian Code CSA Z276-18

Part 2. Justification Provided by PEDThe Nova Scotia Code of Practice was developed at a time when the use of " Full Containment Tanks” for LNG facilities was not standard practice. In the intervening period this type of tank has become the design of choice for maximum safety. If the inner tank shell fails, the containment of the LNG is achieved through the outer concrete shell which effectively acts as the impounding basin. All major codes including NFPA 59A, EN 1473, and indeed CSA Z276- 18 no longer require 110% impounding of a tanks volume to be used if the tanks are "Full Containment" design. Canaport LNG facility in New Brunswick uses Full Containment tanks without impoundment in conformance with the Canadian Code. The use of impoundment will result in significant complication and changes to the design and extra cost without adding anything to the safety of the design. In fact, the only way to offset the cost of providing impounding would be to change the tank design to "Single Containment" which PEL considers inherently less safe and consequently is not an acceptable option to us. We would therefore request that in the particular case of Goldboro LNG, NSUARB waives section 4.2.2.1 of the Nova Scotia Code of Practice for LNG Handling Facilities in favor of applying the rules contained in the Canadian Code CSA Z276-18 which we understand NSUARB was a party in developing. This would permit the use of Full Containment tanks without any compromise on the safety of the installation.

Part 3. LR recommendationLR have investigated relevant factors which are reported in CRS N°N001-02-Goldboro-001 Rev 02 attached, and have concluded that the proposed deviation




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Project Manager

Document: 273407





N001 -02-Goldboro-001 02Closed29 August 20191 of 5

Attention: Keith ThomasCopied to: [email protected]; Steve Duffy

SUBJECT IMPOUNDING FOR FULL CONTAINMENT LNG TANKS



PED AFV 0001 12/12/18 IMPOUNDING FOR FULL CONTAINMENT LNG ATANKS

COMMENT STATUS KEY • = Closed Comment

APPRAISAL STATUS KEYA = Approved/Accepted RAC = Approved/Accepted with conditions RlH = Hold SQ = Queries I

Open Comment

= Rejected, not acceptable= Retained as supporting documentation for information only = Superseded= Requested for Information only

FINAL ACCEPTANCE DEPENDS ON SATISFACTORY SURVEY AND TESTINGLloyd's Register Group Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as 'Lloyd's Register*. Lloyd's Register assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd’s Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

Document: 273407

mailto:[email protected]





PED AFV 0001 12/12/18 IMPOUNDING FOR FULL CONTAINMENT LNG TANKS A


1- Environmental Comments

1.1 £ LR have considered the application for a variance from the requirements listed in theNova Scotia Department of Energy Code of Practice, version 1, July 2005, section 4.2.2.1. on the basis of the following information:

1. Section 1, Nova Scotia Dept Energy Code, 2005. As acknowledged in Section 3.1 of CSA Z276-01, new concepts in the production, storage, and use of LNG are still evolving, and advancements in engineering and improvements in equipment may result in LNG facility design, equipment fabrication methods, and operating practices that differ from this Code of Practice. However, such changes or improvements may provide desirable safety and operational aspects that meet the intent of this Code of Practice.”

2. The eleventh edition of CSA Z276, Liquefied natural gas (LNG) —Production, storage, and handling, supersedes the previous editions published in 2015, 2011, 2007, 2001,1994, 1989, 1981,1978, 1973, and 1972.

3. CSA Z 276 - 18, 5.2.1.1, In order to minimize the potential for an accidental discharge of LNG containers that can endanger adjoining property or important process equipment and structures, or reach waterways, there shall be an impounding area provided for each container.

4. CSA Z 276-18, S.2.2.4 b) Where the secondary container of a double or full containment tank system or the outer concrete container of a membrane containment tank system complies with the requirements of Clause 5.2.1.1, it shall be considered to be the impounding area for the purpose of determining the siting area distances in accordance with Clauses 5.3 and 5.4.

5. Review of industry standards, describing evolution of storage tanks through single tanks containment, double tank containment, to full tank containment system used in the majority of LNG storage tanks built in the last 10 years.

The variation request meets the intent of the Department of Energy Code of Practice, 2005 subject to the following condition:

1. The application shall be supported by a risk assessment that considers the potential for accidental spills and leaks that can endanger important structures, equipment, adjoining property, or that can reach waterways. Risk assessment shall consider, tank design (full containment) credible scenarios, likelihood, proximity to and impact on people, waterways and equipment. Management options shall consider design codes, mitigation measures, barrier controls, monitoring, maintenance and assurance.

FINAL ACCEPTANCE DEPENDS ON SATISFACTORY SURVEY AND TESTINGLloyd’s Register, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as the ‘Lloyds Register Group’. The Lloyd's Register Group assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd’s Register Group entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract

Document: 273407






(Comment by Ian Thomas)

Client response to CRS rev 01PEL note that LR Technical Safety state that the application shall be supported by a risk assessment, however a HAZID assessment and QRA were both performed during the FEED stage of the project covering all equipment (Piping, safety valves, etc.) other than the tank fabric itself. Neither of these assessments stated that loss of containment from the tank (other than piping associated with the tank) is a credible scenario. An LNG impounding basin has been provided in the LNG Storage area to mitigate against the effect of credible spills from the piping associated with the LNG Storage Tanks. PEL do not feel that an additional risk assessment specifically for the tank itself is necessary at this stage. For clarity, the QRA will be updated during the detailed design stage covering all equipment/piping mounted on or around the tank.

Li iJComment CRS rev 02The HAZID and QRA have been reviewed by our technical authority. Both studies are fit for purpose, meet required standards. No concerns noted. We agree that an additional risk assessment for the tanks is not required at this stage and note that the QRA will be updated during detailed design.

(Comment by Ian Thomas)

Mechanical Process Equipment Comments

2.1 Q LR Process Safety have considered the application for a variance from therequirements listed in the Nova Scotia Department of Energy Code of Practice, version 1, July 2005, Appendix B, section 4.2.2.1 related to Impoundment Area Capacity on the basis of the following considerations:

1. The applicant has proposed the use Full Containment Tanks which include an outer concrete shell

2. CSA Z276-18 Section 5.2.2.4 (b) indicates that where the secondary container of a double or full containment tank system or the outer concrete container of a membrane containment tank system complies with the requirements of Clause 5.2.1.1, then, it shall be considered to be the impounding area.

3. Similar criteria to that stated in CSA Z276-18 is found in other relevant international standards such as NFPA 59A, EN 1473.

4. Project Tank Design Specification 188479-300-SP-SP-00001 Rev. C provides a suitable set of design codes as well as design criteria in which operational and accidental loads are considered as part of the tank design; on that basis, it is considered that the secondary containment system of the

FINAL ACCEPTANCE DEPENDS ON SATISFACTORY SURVEY AND TESTINGLloyd's Register Group Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as 'Lloyd's Register1. Lloyd's Register assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd’s Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

Document: 273407

Lloyd's Register Comment Response Sheet Energy




proposed tanks complies with the requirements of Clause 5.2.1.1 as indicated in Clause 5.2.2.4 (b) and requirements of Clause 5.2.2.5 of the CSA Z276-18;

The variation request meets the intent of the Department of Energy Code of Practice, 2005(Comment by Manuel Dominguez-Santisbon)

FINAL ACCEPTANCE DEPENDS ON SATISFACTORY SURVEY AND TESTINGLloyd's Register Group Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as 'Lloyd's Register*. Lloyd’s Register assumes no responsibility and shall not be Isable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd's Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

Document: 273407





N001 -02-Goldboro-001 02Closed29 August 2019 5 of 5


Surveyor to Lloyd’sRegister: Ian Thomas/Manuel Dominguez-Santisbon



FINAL ACCEPTANCE DEPENDS ON SATISFACTORY SURVEY AND TESTINGLloyd’s Register Group Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as ’Lloyd’s Register’. Lloyd’s Register assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd’s Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

Document: 273407

Schedule C

Application for Variance - Goldboro LNGNOVA SCOTIAUTIUTY AND REVIEW BOARD Page 1 of 2

PFD and P&ID Content

Date of Application to NSUARB by PEP: 12th Dec 2018Part 1. Variance Sought by PED:PEL requests that the information required to be shown on the PFDs and P&ID as per Appendices b and j of the Nova Scotia Code of Practice for LNG Handling Facilities is reduced in line with the description below

Part 2. Justification Provided by PED

Process Flow Diagrams (PFD's)Appendix B, Section i of the Nova Scotia Department of Energy Code of Practice — Liquified Natural Gas Facilities — July 2005 states the requirements for the contents of a PFD. In our experience it is now not normal practice to include some of these items. The requirements that we suggest should be omitted / modified are:

1. Design and operating informationReasoning: Design conditions are available elsewhere (Equipment Lists, P&l Ds, Datasheets, etc.) and it is best practice within the industry to minimise the number of documents that contain the same information to avoid discrepancies. Therefore, it is considered normal practice not to include this information on PFDs. With regards to operating conditions and heat duty, these are provided in the Heat and Material Balances and, in many locations within the facility, the operating conditions can vary significantly for the differing cases being considered. Stream diamonds are already provided at the key process streams on the PFDs and these link to the Heat and Material Balances where the operating data is contained.

2. Major isolation valves indicating which are normally closed;Reasoning: The key purpose of the document is to show the sequence of key equipment items and key control loops. Typically, major routing valves are also shown in order to indicate normal operation (e.g. around the dehydration vessels), however other major isolation valves (including ESD Valves) are not normally shown on PFDs as they can detract from the key purpose of the document. All valves (including normal opening / closing positions) are shown on other documentation such as the P&IDs.

Piping & Instrumentation Diagrams

Appendix B, Section j of the Nova Scotia Department of Energy Code of Practice — Liquified Natural Gas Facilities — July 2005 states the requirements for the contents of a P&ID. In our experience it is not normal practice to include some of these items. The requirements that we suggest should be omitted / modified are:

1 .Key data for each piece of equipment should be shown on the PID. Usually MAWP, MAWT, capacity, dimensions, heat duties, and material of construction

Reasoning:We agree that key equipment data should be provided for each piece of equipment, typically those parameters specified by process engineering, such as Design Temperature and Pressure for all items, capacity for all items (typically interpreted as duty for heat exchangers, flowrate

Document: 273408

ii.[ NOVA SCOTIA [ UTILITY AND REVIEW BOARD Uoydj

Register

Application for Variance - Goldboro LNGDoc N°: PED AfV 0003 Page 2 of 2 |

Topic PFD and P&ID Content

and head / differential pressure for pumps and compressors and dimensions for vessels).

We would not normally include dimensions for items such as pumps and heat exchangers as these are not specified for the equipment item, rather they are resultant from the capacity specification. It is typical to include a trim "line number” to equipment on P&IDs during detailed design which would be reported on the P&ID and would contain the material code of the trim (valves, instruments, etc. connected to the vessel). The connected lines will also have materials shown, hence it is not usual to include the equipment materials. Furthermore, this equipment information is included in other documents such as the equipment list and equipment datasheets.

Regarding Relief Devices the controlling case for sizing shall be identified and indicated on the P&IDs.

In all cases, the information is and will continue to be readily available, especially considering the modern document management system that will be provided as part of the project. Consequently, the amount of information required to be shown in particular diagrams has reduced significantly to that which is truly useful to operation staff and so the information should be reduced accordingly.

Part 3. LR recommendationLR have investigated relevant factors which are reported in CRS N°N001-02-Goldboro-003 Rev 01 attached and have concluded that the proposed deviation




Project Manager

Document: 273408






Attention: Keith ThomasCopied to: Stephen Duffy

SUBJECT PFD AND P&ID CONTENT


PED AFV 0003 12/12/18 PFD AND P&l D CONTENT A

COMMENT STATUS KEY # = Closed Comment Open Comment

APPRAISAL STATUS KEYA = Approved/Accepted AC = Approved/Accepted with conditions H = Hold Q = Queries

R = Rejected, not acceptableRl = Retained as supporting documentation for information onlyS = SupersededI = Requested for Information only

FINAL ACCEPTANCE DEPENDS ON SATISFACTORY SURVEY AND TESTINGLloyd's Register Group Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as 'Lloyd's Register*. Lloyd’s Register assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd's Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

Document: 273408






PED AFV 0003 12/12/18 PFD AND P&ID CONTENT A


1 - Process Safety Comments

1.1 % LR have considered the application for a variance from the requirements listed in theNova Scotia Department of Energy Code of Practice, version 1, July 2005, Appendix B, Section (i) - Process Flow Diagrams (PFDs) and Section (j) - Piping and Instruments Diagrams (P&IDs) related to design data information to be shown on those document types on the basis of the following considerations:

1. PEL proposed information to be shown on PFDs follows the intended criteria described within ISO 10628 (2001) - Flow Diagrams for Process Plants - General Rules Section 4.2 and PIP PIE001 Process Flow Diagrams Documentation Criteria

2. PEL proposed information to be shown on P&IDs follows the intended criteria described within ISO 10628 (2001) - Flow Diagrams for Process Plants - General Rules Section 4.3 and, PIP PIC001 Piping and Instrumentation Diagram Documentation Criteria

3. Design data information is also shown within specific documents which are available to the project and, which are more relevant to the equipment type i.e. datasheets and piping materials specifications within others.

LR considers that the variation request meets the intent of the Department of Energy Code of Practice, 2005 (Comment by Manuel Dominguez-Santisbon)

PEL Response:

PEL note that while the PFDs and P&IDs generally follow the principles of ISO 10628 and PIP PIE001 / PIC001 (particularly the intent of these documents with regards content), the PFDs and P&IDs are not completely in alignment with the details of these documents. We also note that PIP PIE001 and ISO 10628 are not completely in alignment with each other. PEL believes that this demonstrates that our drawings are in line with industry standards, however PEL do not wish to produce documents in strict adherence to ISO 10628 or PIP PIE001 / PIC001.

FINAL ACCEPTANCE DEPENDS ON SATISFACTORY SURVEY AND TESTINGLloyd's Register, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively referred to in this clause as the ‘Lloyd s Register Group'. The Lloyd’s Register Group assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd’s Register Group entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

Document: 273408


Client: Nova Scotia Utility and Review BoardProject: Goldboro Regulatory VarianceClient Contract No: PRJ11081799 Transmittal No: E-mailClient reference:


N001 -02-Goldboro-003 01Closed02 July 20193 of 3


Surveyor to Lloyd’sRegister: Manuel Dominguez-Santisbon



Keith Thomas 17.07.2019

FINAL ACCEPTANCE DEPENDS ON SATISFACTORY SURVEY AND TESTINGLloyd's Register Group Limited, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this clause as 'Lloyd's Register1. Lloyd's Register assumes no responsibility and shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a contract with the relevant Lloyd's Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

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DECISION AND ORDER 2020 NSUARB 8 M09557 NOVA …