Operations Implemented under the Gas Act 2000 Annual Report 2014/15 Consumer Building and Occupational Services Department of Justice REPORT OF THE DIRECTOR OF GAS SAFETY This is the annual report of the Director of Gas Safety pursuant to the Gas Act 2000. It describes the operations of the Director’s office for the financial year 2014/15 as required by Section 16 of the Act. The Director of Gas Safety is a statutory appointment established by Section 9 of the Gas Act 2000. Mr Dale Webster held this position for the period covered in this report. The Gas Act 2000 requires the Director of Gas Safety to deliver to the Minister a report on the Director's operations during the previous financial year. The Minister must cause a copy of each report to be laid before both Houses of Parliament. Director of Gas Safety: Dale Webster Office: Consumer Building and Occupational Services Office Address: 30 Gordon Hills Road, Rosny Park 7018 Postal Address: Director of Gas Safety PO Box 56 Rosny Park 7018 Telephone: 1300 366 322 Office hours: 9:00am to 5:00pm, Monday to Friday (except public holidays) Website: www.justice.tas.gov.au Email: wstinfo@justice.tas.gov.au 2 PREFACE This report covers the Director of Gas Safety’s operations under the Gas Act 2000 (the Act) as it was in force for the 2014/15 financial year. Section 4 of the Act states that the objectives of the Act are: (a) to facilitate the development of a gas supply industry in Tasmania; and (b) to promote efficiency and competition in the gas supply industry; and (c) to promote the establishment and maintenance of a safe and efficient system of gas distribution and supply; and (d) to establish and enforce proper standards of safety, reliability and quality in the gas supply industry; and (e) to establish and enforce proper safety and technical standards for gas installations and appliances; and (f) to protect the interests of consumers of gas. The Director of Gas Safety is appointed in accordance with Section 9 of the Act. Section 10 of the Act states that the Director of Gas Safety has the following functions: (a) the monitoring and regulation of safety and technical standards in the gas supply industry; (b) the monitoring and regulation of safety and technical standards with respect to gas installations and gas appliances. The Director of Gas Safety, in administrating the Act, provides input and is involved in a range of activities in liaison with the gas industry and other Government agencies. This includes gas entity licensing functions and gas emergency management vested with the Regulator and Minister for Energy, Department of Infrastructure, Energy and Resource (now Department of State Growth) respectively. The Director’s actions in relation to these functions are dealt within this report. 3 Contents REPORT OF THE DIRECTOR OF GAS SAFETY .......................................................................... 2 PREFACE .................................................................................................................................... 3 OFFICE OF THE DIRECTOR OF GAS SAFETY ......................................................................... 6 VISION ........................................................................................................................................ 8 SECTION 1: GAS DISTRIBUTION .............................................................................................. 9 Table 1: Tasmanian Network Location of Natural Gas Distribution Networks and Isolated LP Gas Networks .......................................................................................................................... 9 1.1. Natural Gas Rollout .................................................................................................... 10 1.2. Network Incident and Accident Reporting ................................................................... 10 1.3. Gas Distribution Entity Safety and Operating Plan ...................................................... 11 1.4. Gas Distribution Standards ......................................................................................... 11 1.5. Distribution Network Equipment and Integrity Management ........................................ 12 1.6. Dial Before You Dig .................................................................................................... 12 1.7. Isolated Gas Networks ................................................................................................ 13 1.8 Gas Distribution Network Life Cycle Auditing .............................................................. 13 Table 2: Director’s Gas Network - Life Cycle Administration and Safety Program.................. 13 1.9 Annual Distribution Gas Entity (TGN) Performance Report ......................................... 14 Table 3: Gas Distributors Operational Performance 2014/15 (extracted from the Tas Gas Networks annual reporting data to the Director of Gas Safety 2014/15) ................................ 14 SECTION 2: GAS RETAILING ................................................................................................... 15 2.1. Gas Retailer Emergency Gas Curtailment Planning .................................................... 15 SECTION 3: GAS SUPPLIERS, STORAGE SYSTEMS AND CONDITIONING ......................... 15 3.1 Liquefied Natural Gas (LNG)....................................................................................... 15 3.2 LP Gas (LPG) ............................................................................................................. 16 3.3 Compressed Natural Gas (CNG) ................................................................................ 16 3.4 Biogas ........................................................................................................................ 16 Table 4: Gas Storage and Conditioning Plants ...................................................................... 17 SECTION 4: GAS INSTALLATIONS AND APPLIANCES .......................................................... 17 4.1 Notification and Certification ....................................................................................... 17 4.2 Complex Gas Installation Design Acceptance ............................................................. 18 4.3 Prescribed Standard Gas Installation Acceptance ...................................................... 19 4.4 Type B Gas Appliance Acceptance ............................................................................. 19 4.5 Type A Gas Appliance Class Certifying External Authorities ....................................... 21 Table 5: Tasmanian approved gas appliance external authorities ......................................... 21 4.6 Type A Gas Appliance Acceptance - Individual Appliance Certification Schemes ....... 22 4.7 Prohibition of Sale, Product Withdrawal and Recall of Gas Appliances and Components .......................................................................................................................... 22 4 Table 6: Tasmanian gas appliance prohibition of sale, product withdrawal and recall of gas appliances and components .................................................................................................. 23 4.8 Major Events ............................................................................................................... 23 4.9 Internet Sale of Gas Appliances .................................................................................. 23 4.10 Carbon Monoxide ....................................................................................................... 24 4.11 Gas Installation and Appliance Incidents ....................................................................... 24 SECTION 5: OFFICE OF THE DIRECTOR OF GAS SAFETY PROGRAMS/ACHIEVEMENTS25 5.1 Regional Delivery of Programs ................................................................................... 25 Table 7: Operation and maintenance of administrative systems primary outputs ................... 25 Table 8: Summary of Achievements ...................................................................................... 27 5.2 Inspection Program ..................................................................................................... 31 5.3 Technical Standards Development ............................................................................. 32 Table 9: Technical Standards Development and Implementation 2014/15............................. 32 Table 10: Participation in committees and organisations ....................................................... 34 Table 11: Communication products ....................................................................................... 35 Gas safety and technical publications ........................................................................................ 36 Expos and other public events ................................................................................................... 36 Table 12: Staff development .................................................................................................. 37 SECTION 6: INTERGOVERNMENT INDUSTRY ADMINISTRATION ........................................ 39 SECTION 7: CONCLUSION ...................................................................................................... 39 APPENDIX 1: GLOSSARY AND ABBREVIATIONS .................................................................. 41 5 OFFICE OF THE DIRECTOR OF GAS SAFETY The Director of Gas Safety, Mr Dale Webster, is supported by the Office of the Director of Gas Safety, Gas Standards and Safety (GSS). The GSS unit is managed by the Manager Gas Safety, Mr Andrew Ayton, who is delegated the role of the Director. The GSS unit became part of the newly formed Building Standards and Occupational Licensing (BSOL), the outcome of a merger of Building Standards, Electrical Standards, Working With Vulnerable People, and Occupational Licensing and Accreditation. This structure has enabled resource and knowledge sharing, and, hence greater efficiencies between technical and nontechnical units within the branch for energy safety administration. The Office of the Director of Gas Safety comprises three Authorised Officers and one Administrative Officer, with additional administrative support from BSOL administration and records staff. The benefit of this structure is still being realised, with continual improvement that aligns complementary outputs and gains the efficiencies that are expected of the Department in the current economic climate. Administrative and industry performance functions are centralised in Launceston, with the capability for Gas Act 2000 safety technical compliance programs in each region. Specialist policy functions are resourced from the regional Gas Safety Specialists in conjunction with the BSOL Directorate. It is pleasing to report that during this reporting year, following targeted recruitment, that regionally based technical and inspection service delivery now has the capability for all downstream installations and infrastructure inspection services, including individual industrial and commercial appliance (type B appliance) technical programs. Staff turnover nevertheless necessitated general assistance for Southern regional functions to be resourced from Launceston, however recruitment to fill the staff vacancy has commenced, which will bolster Southern region productivity. Ensuing employee training and mentoring will mean that this output will be resourced from the increased Hobart staffing in the near future. Gas Entity Infrastructure Design Acceptance and Safety Systems Administration has relocated to Hobart subsequent to the promotion of an existing staff member to Gas Safety Specialist –Supply Reliability and Programs. The GSS unit operational structure and activities are shown in Figure 1. 6 7 VISION Consistent with the vision of the Department of Justice to provide ‘A fair just and safe Tasmania’, and in accordance with the administrative role of the Director of Gas Safety, GSS strives to provide leadership and effective governance in respect to gas infrastructure, downstream installation safety and technical standards. GSS achieves this by ensuring the evolving natural gas, compressed liquefied natural gas, biogas and LP Gas industries achieve levels of excellence in construction, operations, reliable supply, acceptable public safety and energy efficiency. The Director of Gas Safety will: ensure that gas infrastructure operations achieve high standards of safety, reliability and control inherent risks; provide advice to the gas industry to achieve best practice in gas safety; develop communication products and promote consumer understanding of gas safety through education and communication; work with industry stakeholders to ensure the efficient and safe evolution of gas technology and work standards for Tasmanian consumers; in conjunction with national jurisdictions, work to achieve desired levels of national harmonisation in the regulation of gas safety technical standards; and work to achieve contemporary program delivery models to enhance efficient operations. We achieve our vision through the following values, expected from our team at all times. Excellence: We strive for quality and excellence in our functions. Respect: We treat all stakeholders and staff with respect. Accountability: We take responsibility for our actions and decisions. Integrity: We make decisions on merit, based on facts, logic and due process. Commitment: We work cooperatively, mentor and support other team members to enhance development of the gas industry in Tasmania. Cooperation: We work cooperatively, inclusively and are open in our dealings. Creativity: We seek to solve problems creatively within the boundaries of prescriptive standards and codes. 8 SECTION 1: GAS DISTRIBUTION It is once again gratifying to report that natural gas networks continue to provide a reliable supply of natural gas to an increasing number of consumers through Natural Gas Distribution Facilities operated under license by Tas Gas Networks Pty Ltd (TGN). Apart from a single incident affecting the gas supply to 59 domestic, commercial and industrial consumers, it appears that the effective planning for natural gas supply/quality and the successful response to incidents by gas entities, the Director’s office and major consumers to prevent any major interruption to Tasmanian natural gas supply. There has been no serious property damage or personal injury in the operation of distribution networks. Concerted efforts by the Director and gas entities with enforcement activity and educating third parties to identify gas infrastructure locations using the Dial Before You Dig process has encouragingly resulted in a reduction in the number of uncontrolled gas releases caused by third party interference. In April 2015, a gas quality incident involving a quantity of high hydrocarbon dew point gas entering the Tasmanian Gas Pipeline in Victoria threatened natural gas supplies to Tasmanian centres. Gas entities declined to accept the out of specification gas due to concerns for safety and possible equipment damage. As a result, the Director of Gas Safety was not asked to accept the off-specification gas in accordance with the Act. Mass consumer curtailment was averted in this instance by Tas Gas Pipelines Pty Ltd venting to atmosphere the off spec gas at Rosevale station. No consumer gas supplies were affected by this incident, however an unknown quantity of off spec gas was delivered through the Bell Bay lateral. No adverse effects were reported in respect to consumer installations connected to this lateral. Following the out of specification gas incident, the Director of Gas Safety coordinated an incident debrief with all stakeholders. This initiative was well received by industry, with various actions resulting. These actions will be developed or applied by Gas Standards and Safety during 2015/16. The amount of Director of Gas Safety gas distribution network investigations increased during the reporting period. The primary cause being a considerable increase in the quantity of deliberate gas meter interference for the purposes of diverting gas. These investigations have used considerable Gas Standards and Safety resources so the Director is continuing to liaise with industry to provide proactive prevention to discourage this very dangerous trend. The Director continues to maintain regular meetings with TGN to facilitate the open exchange on topical network operational and regulatory matters. These meetings have been held quarterly and have been of considerable benefit to both TGN and GSS. Table 1: Tasmanian Network Location of Natural Gas Distribution Networks and Isolated LP Gas Networks Existing Natural Gas Distribution Facility BURNIE BELL BAY DEVONPORT HOBART Suburb / Town Receiving Gas Supply Dynnyrne Glenorchy LAUNCESTON St Leonards Gas Facility, New Extensions Commissioned 2014/15 New Facility Planning Reviews Nil Nil Nil Mc Devitt Avenue Extension to Bunning’s Hardware Nil 1000 kPa extension designs yet to be submitted 9 Extension of network to Penny Royal Gunnery development LONGFORD ULVERSTONE South Ulverstone Nil Distribution network construction yet to commence. WESTBURY Nil WYNYARD Nil Industrial estate and town SMITHTON centre Existing LP Gas Isolated Gas Facility LAUNCESTON Glenara Lakes Distribution network construction commenced Initial Consideration na ST HELENS Sunhaven Villas 1.1. Preliminary designs commenced Nil Decommissioned and working through safety documentation prior to amending licence Natural Gas Rollout Natural gas network expansion and construction has been limited to an additional 5.04 kilometres. Natural gas network/s augmentation has been predominantly associated with major retail and housing subdivision developments, with smaller additions to facilitate the connection of natural gas consumers when deemed commercially viable by TGN. Proposed future natural gas networks at Ulverstone and Smithton, including a cross country network from Port Latta, have undergone preliminary non-technical assessment. However, detailed design and construction is yet to commence. 1.2. Network Incident and Accident Reporting Incident and accident reporting by the distributor has been ongoing, with the collation of data showing a statistically misleading increase in the number of incidents for this reporting period. Whilst there were 16 incidents reported for the reporting period, eight of these were the result of a gas curtailment incident resulting from a single event involving a Pipeline Integrity Gauge (PIG) operating to verify the integrity of the Devonport high pressure steel transmission network, became trapped in the pipeline. This incident resulted in the loss of gas supply to 59 domestic, commercial and industrial consumers in the Quoiba area for three hour duration. Incident data is assessed for trends to determine both the cause and required risk controls, and in actual fact, this demonstrates a pleasing reduction in third party impact causing uncontrolled gas release incidents. (Refer Figure 2) The reduction in frequency of third party activity impacting on the security of networks may be partially explained by the education program rolled out by Gas Standards and Safety, TGN and DBYD. This positive result is in spite of the added risk of the rollout of the national broadband network – an activity which has increased the risk of impact on gas network infrastructure due to the significant amount of work in the vicinity of gas mains. As a result, the Director will continue working in conjunction with the distribution gas entity on community awareness programs to continually improve public appreciation of gas infrastructure, in particular the possible consequences of damaging gas networks. Education of civil and trade contractors through the BSOL allied trades e-newsletter (eConnections) will also continue. 10 Consistent with international indicators, third party activity remains the primary risk to buried gas infrastructure. Applying lead indicators in the prediction of major incidents, the Director’s actions have included undertaking a targeted liaison program aimed at less critical near-miss incidents. This is highlighted by the increase in gas distribution incident investigations undertaken by the Director’s office. No injuries to employees or the public have resulted from any incidents, and gas network metering and isolation design has been compliant and acceptable. Figure 2 – Director’s Gas Distribution Operations 1.3. Gas Distribution Entity Safety and Operating Plan The entity’s safety and operating plans has remained unamended during the reporting period. The Director continues to measure safety, reliability and structural integrity performance against the current independently certified and accepted safety and operating plan for the gas entity’s natural gas networks. GSS is expecting a revised safety and operating plan in the latter half of 2015 which will reflect proposed fundamental personnel changes for the maintenance and integrity management of their distribution infrastructure. This will involve a comprehensive review of the revised plan by GSS prior to acceptance by the Director. 1.4. Gas Distribution Standards A review of the Gas Entity Tier 2 and 3 design and operation policy and procedures has been ongoing. This has involved independent certification from a person approved by the Director to ensure gas entity standards are consistent with current activities and contemporary compliance requirements. While not ideal, the gas curtailment incident involving the entrapped PIG did provide a good insight into the way the gas entity manages such an emergency, including valuable in-field testing of standards covering gas curtailment and re-instatement of gas to affected consumers. The Director had a representative on site for the duration of the emergency and was satisfied with the calm and systematic approach employed during the mitigation and recovery phases. Any safety concerns observed and raised during the incident response were addressed following a debrief and were also incorporated into revised gas entity standards. 11 1.5. Distribution Network Equipment and Integrity Management Due to encroachment adjacent to high pressure steel transmission networks, and in line with contemporary Australian Standards requirements, the theoretical Maximum Allowable Operating Pressure (MAOP) has been reduced in Devonport and Hobart to mitigate the consequences in the event of an uncontrolled gas escape. To date the reduced MAOP in these networks has not affected their reliability, and there remains sufficient supply capacity redundancy to maintain sufficient quantities of gas to consumers. The continuation of the leakage surveys monitoring program is intended and will be reported to the Director. This program ensures public risk is as low as reasonably practicable and detection measures are implemented to identify leakage. A total of 281 kilometres of network mains were surveyed for gas leakage. Encouragingly no gas leaks were identified during these leakage surveys. (Refer Table 3) To ensure the ongoing safety and integrity of high pressure transmission distribution infrastructure, the gas entity developed and implemented a Pipeline Integrity Management Plan. The Director is expecting to complete a comprehensive review of this Plan in the first quarter of 2016. Natural gas distribution networks have been operating for just over ten years and, as a result, the administration and regulation focus have progressed from design and construction quality assurance to infrastructure integrity and operational management assessment and validation. This program uses maintenance records, physical characteristics and operating history of the networks to predict the integrity of a given network. In line with this approach, systemic reviews and direct pipeline integrity assessments of high pressure steel distribution networks in Devonport, Launceston and Hobart have commenced. Reviews and assessments include remaining life review, location class review and safety management study reviews, pipeline coating assessments involving cathodic protection reviews, direct current gradient surveys, pipeline dig up surveys, and pipe wall integrity assessments using intelligent pipeline integrity gauge/s. The information collected by these studies will result in the development of remaining life reports and updates of pipeline integrity management plans for these networks. 1.6. Dial Before You Dig The Director continues to encourage the use of the Dial Before You Dig phone and internet service by all infrastructure owners and contractors undertaking civil excavation in the vicinity of gas infrastructure. The Director’s office meets with Dial Before You Dig’s Victorian Operations Manager to identify improvements in service delivery. The Director extensively consulted with Dial Before You Dig in the development and publication, in August 2014, of a dedicated ‘Dial before You Dig Service Guidelines for Tasmania’. These service guidelines were developed to set Tasmanian-specific standards which everyone is expected to meet, when dealing with the safety of those who work near underground assets and the protection of those assets. Dial Before You Dig and the Director’s office hope to commence discussions in the latter half of 2015 on the development of a memorandum of understanding (MOU) that will seek to describe how parties will interact with each other, provide a platform for further cooperation and provide for sharing of information. The Director has continued to assess and review the currency, accuracy and reliability of asset records to ensure the suitability of information made available by gas entities to the public through the Dial Before You Dig service. 12 Regular presentations and provision of guidance information to reach a large audience of Tasmanian trades and affiliated professionals is exceeding expectations regarding the use of the Dial Before You Dig system. This reporting period saw a threefold increase in enquiries with 21,582 received by the Dial Before You Dig provider for Tasmania relating to distribution gas infrastructure. 1.7. Isolated Gas Networks No new isolated gas networks were constructed in 2014/15. The Director was notified late in the reporting period that it is the intention of gas entity, Origin Energy, to decommission an isolated LP Gas network on Tasmania’s East coast. The Director is currently consulting with the gas entity and the Office of the Tasmanian Economic Regulator (OTER) regarding resultant licence amendments. This will require both a review of the decommissioning activity to ensure it does not lead to an unacceptable level of risk, and approval of the revised safety and operating plan. 1.8 Gas Distribution Network Life Cycle Auditing Refining of audit models for the life cycle audit of gas networks is continuing. The Director’s natural gas network and high pressure distribution pipelines review, along with an audit of gas atmosphere hazardous area electrical installation compliance, reliability, public safety and condition survey received priority during the reporting period. Proactive compliance audits have continued to lapse in 2014/15. This is largely due to the redirection of limited resources to core and reactive duties including complex applications for acceptance and gas appliance safety. Table 2: Director’s Gas Network - Life Cycle Administration and Safety Program Formal Safety Instrument Gas Entity – Pipeline Integrity management plan Gas Entity Pipeline maximum operating pressure review Administrative Program Initial document and implementation review 5 year review Direct current and ground variance for direct assessment Inline inspection of pipelines Steel pipeline integrity plan review Pipeline quality gas review Finalisation of electrical installations in hazardous areas audit Gas Entity - Full Safety Review of infrastructure hazards Purpose Pipeline system design, construction, operation and maintenance activities, in conjunction with the application of sound engineering principles with due regard to safety Technical compliance and public safety Detect and monitor deterioration of pipeline protective coating condition Detect and monitor internal condition of pipe and its capability to operate at MAOP Detect out of specification product, frequency and effects analysis Maintain safe electrical installations at meter stations to ensure acceptable network reliability and public safety Maintenance of public safety 13 Formal Safety Instrument Assessments of gas networks Gas Entity - Safety management systems Gas Entity - Network design certifiers acceptance 1.9 Administrative Program and currency of protective systems Review currency with operations and construction Purpose and pipeline management from encroachment Approval of Independent Design Certification Technical compliance of new networks designs Maintain acceptable network reliability and public safety Annual Distribution Gas Entity (TGN) Performance Report In line with the layers of protection model utilised by the Director, nationally consistent reporting criteria provide lead safety and reliability indicators. Lag (near miss) and lead indictors are collated and reviewed across reporting periods to ascertain the ongoing adequacy and effectiveness of distribution networks, risk mitigation actions including safety critical operations and maintenance activities, hazard identification, training, network integrity, network controls and emergency preparedness. Table 3: Gas Distributors Operational Performance 2014/15 (extracted from the Tas Gas Networks annual reporting data to the Director of Gas Safety 2014/15) Statistics Length of distribution network (kilometres) Public third party reported gas leaks Gas escapes on mains not caused by third parties Kilometres of network subjected to leak survey Leaks detected during surveys Leak repairs as result of surveys Emergency / Incident response Level 4 incidents Level 3/2/1 incidents Emergency response exercises planned Emergency response exercises completed Average time to respond to emergency notification Longest time to respond to emergency notification Dial before you dig enquiries Third party interference where Dial Before You Dig enquiries were performed Operational performance Scheduled audits Non-conformance identified Non-conformance not corrected in scheduled time Gas quality tests Gas quality excursions (including odorant) Pressure/ temperature excursions Cathodic protection system surveys conducted Unsatisfactory CP system test results Polyethylene Mains 500 kPa 1000kpa 716.418 56.445 113 0 Steel Mains 5.0 MPa 46.099 0 0 0 0 220.8 0 0 14.8 0 0 45.8 0 0 16 (8 accounted for in single pigging incident) 0 2 2 32 minutes 118 minutes 21,582 8 307 16 1 2 1 0 2 0 14 SECTION 2: GAS RETAILING Commercial retailing of natural gas to industrial, commercial and domestic retail consumers is undertaken by licensed gas entities Aurora Energy Pty Ltd and Tas Gas Retail Pty Ltd. Consumer connections to the natural gas network increased by 8% this financial year. The increased consultation with retailers planned for 2014/15 was not achieved due to the ongoing significant change in technical resourcing. 2.1. Gas Retailer Emergency Gas Curtailment Planning The requirements for natural emergency supply protocols by licensed gas retailers are embedded in the Tasmanian Natural Gas Supply Emergency Coordination Plan. Implementation of industry gas quality communications protocol for the Tasmanian Gas Supply Emergency Coordination Plan, to manage local supply curtailment issues and emergency incidents, is ongoing. In particular the Director and retailers are working through actions that resulted from a debrief convened by the Director following an out of specification gas incident. The Director accepted Aurora Energy’s revised and resubmitted Safety and Operating Plan – provided as a result of a prescribed five year review and alignment with industry agreed gas quality and emergency gas supply coordination provisions. There is a possibility that threatened industrial action at the BHP ESSO plant in Victoria may adversely affect Tasmanian natural gas supplies. Given the uncertainty of the timing and extent of any industrial action, or even the eventuality of such action, the Director of Gas Safety initiated meetings with gas retailers to proactively prepare in the event that prolonged industrial action would reduce Tasmanian gas supplies to a point that curtailment is necessary. SECTION 3: GAS SUPPLIERS, STORAGE SYSTEMS AND CONDITIONING Ongoing independent certification of design, installation, testing and mechanical completion procedures for gas storage facilities CNG, LNG and LP Gas continues to be refined. Co-operation with all gas suppliers has resulted in improved gas safety standards and compliance. 3.1 Liquefied Natural Gas (LNG) It is pleasing to report that existing and new gas storage safety management systems are being implemented affectively in this sector of the fuel gas industry. This program has been ongoing in 2014/15 with the Director reviewing LNG supplier implementation of gas safety management plans for major conditioning and storage facilities, and major installations. These LNG management arrangements have multiple site systems management for design, testing, commissioning, operations and emergency management. Supply of LNG to industrial consumers has become an alternate energy option for large consumers isolated from the NG transmission system. This is providing economic energy advantages for these consumers. The Director continues to review and audit the operational safety case for the BOC Westbury natural gas purification to LNG facility in consultation with the Major Hazard Facility (MHF) branch of WorkSafe Tasmania. Gas Standards and Safety conducted an extensive audit of the Westbury pipeline facility’s asset management and safety critical equipment, and planning has commenced 15 for a permit to work management and implementation audit in the first quarter of the 2015/16 financial year. 3.2 LP Gas (LPG) LP Gas connections remain high in areas not serviced by NG networks. The Gas (Safety) Regulations 2014 provide continuity of previous Dangerous Substances regulations which were rescinded as part of the Dangerous Goods Act 1995. Following the rescinding of the Dangerous Substances regulations, continuity of design and approvals process, and public safety for the LP Gas storage, supply, installation, marine vessel and vehicle gas conversion industries, has been maintained as part of the Director’s administrative role. Ongoing independent certification of design and installation, testing and mechanical completion procedures for gas storage facilities exceeding 8,000 litres of LP Gas has been refined. LP Gas storage, monitoring and approval programs have increased the compliance rate in this industry. The Director, in collaboration with WorkSafe Tasmania, has consulted with LP Gas suppliers on the development and implementation of systems for the extension of LP Gas cylinder test intervals to 15 years in line with amendments to prescribed standards. A number of gas suppliers are looking at, or are implementing, such systems to reduce ongoing operating costs. 3.3 Compressed Natural Gas (CNG) The CNG gas conditioning and storage process is managed under the Director’s gas safety management plan and gas storage approvals system. The Self Point CNG facility owned and operated by natural gas distributor Tas Gas Networks (TGN) remains the solitary CNG dispenser in Tasmania. The demand for CNG as an alternative to conventional fuels was expected to increase, with design considerations at two new sites in northern Tasmania. Further expansion of this fuel’s availability to industrial and commercial fleets in particular has not yet eventuated. Dependent on the success and viability of current Victorian gas infrastructure developments using CNG storage as a means of gas supply to isolated natural gas distribution networks, the Director of Gas Safety anticipates in coming years the development of similar systems to supply industrial and commercial precincts that are currently isolated from Tasmanian gas distribution networks. 3.4 Biogas Biogas (dairies, rural husbandry), municipal and industrial waste gases capture and combustion is driving new co-generation, tri-generation projects by commercial and industrial consumers to offset escalating energy costs. The Director is monitoring a number of field trials proving up biogas chemistry and volume. The expectation that the use of waste gas for energy generation will increase in the agriculture and water treatment industry is proving accurate due to the frequency of enquires received by the Director’s Office. Targeted new groups have been identified for an expanding communications audience. The Director of Gas Safety has been involved in initial meetings with Lion dairy products in Burnie in 16 respect to proposed digester and biogas utilisation designs, and has been involved in networking and learning opportunities provided by Bioenergy Australia. Biogas has been adopted into prescribed technical standards administered by the Director. Work on this phase of the waste gas industry will continue in 2015/16 as projects develop. Table 4: Gas Storage and Conditioning Plants Gas Facility, New Infrastructure Commissioned 2014/15 Gas Type Location CNG Portable LNG Norske Skog 80,000 Litre storage vessel and associated equipment commissioned Bio Gas Cascade Brewery Commissioned Bio Gas Municipal Waste Stations Numerous designs enquires for new and upgrades of Bio Gas installations at municipal waste stations and sewage plants Biogas Dulverton Refuse Centre Biogas Lion - Burnie Waste Gas New Facility or Installation Approvals 2014/15 CNG storage container to supply art installation Part of major project involving LNG storage system and new paper coater Digester, flare and duel fuel operation of existing boiler Extraction system, and flare determining gas quality and quantity energy generation business case Initial design for Digester, flare and duel fuel operation of existing boiler SECTION 4: GAS INSTALLATIONS AND APPLIANCES The installation of new gas service connections to industrial and commercial consumers has increased this year and subsequently maintained a high demand for the Director’s natural gas installations and gas appliance, safety and technical compliance programs. Applications for new and alterations/additions to existing Type B gas appliance and complex gas installation acceptances have again increased from the previous year. Maintaining this program continues to be problematic with reduced staffing, and this has caused some delays to industry and increased intrastate travel costs within the GSS unit. As a result GSS resources will increase by one full time equivalent position in 2015/16 financial year to enhance this programs productivity in line with industry expectations. 4.1 Notification and Certification The Gas Act 2000 installation, notification and certification procedures used by gasfitters to certify work compliance continues to operate effectively. 17 Further improvement in the installation, notification and connections process is expected following the employment – by the Director of Gas Safety – of new gas fitting work compliance plates attached to gas fitting work by the installing gasfitter. The revised gas fitting work compliance plates enables gas suppliers (LP Gas, NG, CNG, LNG) to determine the status of the complex and prescribed standard installations administrative compliance program for supply safety and technical standards. Minor numbers of gasfitter non-notification have occurred, been identified and rectified principally through cooperation with gas entities. Additional protocols have been developed in conjunction with the Compliance and Dispute Resolution unit within BSOL for non-notification regulatory enforcement action pursuant to the Occupational Licensing Act 2005. Measurement of the effectiveness of this cooperative enforcement approach will be ongoing during the 2015/16 financial year. A notification form for the vehicle gas fitting industry has not been completed due to resourcing. 4.2 Complex Gas Installation Design Acceptance Inspectors completed the design assessment of 242 complex gas installations primarily at commercial sites. This was a 22% increase on last year and maintains the increase experienced over the previous reporting periods, although with sustained reduced resources. New gas installation work appears to still be significantly influenced by consumer energy efficiency costs and commercial retrofitting of steam, hot water and commercial catering gas appliances. The marked increase in alterations and additions to existing gas installations illustrates that those that have previously shifted to gas as a source of energy have experienced benefits and are looking to further increase costs and business efficiencies. A significant resource was allocated to the substantial LPG, CNG, NG and Bio Gas installation projects at Henty Gold, Dulverton waste transfer station, Dark Mofo flame organ and Pete Matilla Gateway Sculpture including design, construction, commissioning and safety management administration and acceptances. High pressure gas supply to high pressure gas installations is continuing to require long term staff knowledge management and a transfer of gas transmission integrity management standards to these gas installations. Figure 3 – Complex Gas Installation Design Acceptances 18 Figure 4 – Major Installations >1050kPa MAOP-CNG, LNG, Biogas Plants 4.3 Prescribed Standard Gas Installation Acceptance The Director accepted 64 submissions for prescribed standard gas installation connections which is less than the previous reporting period. Considering the financial years between 2011- and 2013 recorded an increase in prescribed standard gas installation connections of over 700%, this program still requires significant resourcing. Combined with an increase in type B appliance and complex gas installation applications for acceptance, this has directly affected the GSS unit’s capacity to undertake other programs. The Director of Gas Safety remains focused on safety and technical design considerations for acceptance of multi-residential prescribed standard gas installations. This includes gas distributor’s gas metering system location and installation standards. This has been extended to the maintenance and operation of consumer installation and appliance reviews with the principal owner of the prescribed installations, Housing Tasmania. Figure 5 – Prescribed Standard Gas Installation Design Acceptances 4.4 Type B Gas Appliance Acceptance This office completed acceptances for 72 Type B gas industrial appliance designs, a further 5% increase on the previous year. The expansion of appliance control functions and their use in the gas industry, to provide energy efficiencies, continues to increase the complexity of Type B appliances and has demanded extended application review and acceptance time frames. The Director, through investigations into appliance incidents, has identified maintenance, modification to Programmable Logic Controller (PLC) programs and operator training failures. However, the Director has been unable to resource the implementation of proactive safety integrity programs on installed equipment. 19 The Director has continued to implement a quality acceptance scheme requiring ISO 9000 certification of the manufacturer, to assess certain high consumption Type B appliances manufactured internationally before being considered for use in Tasmania. Significant projects continue to impact on the demand for the services of the Director’s office and staff expertise as forecast. Long term resourcing and knowledge management was required to facilitate the acceptance and integrity management of the Tamar Valley Power Station Pratt and Whitney FT8 turbine synchronous condenser modification. The state-of-the-art Henty Gold sodium cyanide generator project also received operational acceptance from the Director of Gas Safety during the reporting period. Highly visual public displays, the Dark Mofo organ and Matilla Gateway Sculpture, exploiting flame manipulation for artistic affect have undergone significant review and acceptance including legislative requirements, operational management and public safety for these unique type B appliances located, by nature, in close proximity to the general public. Unique and complex type B appliances such as these require design certifier acceptance programs, and adoption of layer protection philosophy, staged design, commissioning and operations consent phases, together with succinct analysis and evaluation with the proponents and their equipment suppliers to ensure safety. Figure 6 – Type B Appliance Acceptances Figure 7 – Major Appliance Commissioning / Acceptance 20 Figure 8 – Gas Safety Management Plans 4.5 Type A Gas Appliance Class Certifying External Authorities The Australian National Testing laboratories were audited by Energy Safety Victoria for the purpose of type testing to certain appliance test standards. This program will be ongoing with performance reporting to each state by Energy Safety Victoria. The Director accepts the interstate regulator’s audit results. In conjunction with the Gas Technical Regulators Committee (GTRC), the Director continued to assist in the development of nationally consistent rules for gas appliance and component certification and assessment criteria for the recognition of conformity assessment bodies. The Director expected to implement these rules with the four approved external authorities during 2014/15; however, due to legislative concerns, GTRC members made the decision to defer the implementation of the GTRC Rules until a cost benefit analysis on the introduction of periodic safety critical testing to replace/complement existing visual inspections is completed. This cost benefit analysis will weigh up any safety benefits against any additional impost on business and consumers. A model for notification by external authorities and interstate regulators, of gas appliance products suspended from the market and appliances withdrawn from market, is operational. This is functional and effective through the GTRC membership and the certifying bodies. To assist gasfitters to verify the certification status of gas appliances, the GTRC has developed and implemented a single national certification database as opposed to the four individual databases currently available. This has required funding from participating states and territories. In the latter part of the reporting period, the Director received an application from Vipac Engineers and Scientists for recognition as an external authority in Tasmania to certify that type A gas appliances and components are compliant with prescribed standards before being made available for sale. Gas Standards and Safety are reviewing Vipac’s scheme rules and associated accreditations. If approved, this is expected to occur in late 2015. Table 5: Tasmanian approved gas appliance external authorities Organisation Australian Gas Association SAI Global IAMPO R&T Oceana ‘Gas Mark’ Global Mark Pty Ltd Address 66 Malcolm Road, Braeside, VIC 3195 286 Sussex Street, Sydney, NSW 2000 1040 Dandenong Road, Carnegie, VIC 3163 Suite 4.07, 32 Delhi Road, North Ryde, NSW 2113 21 4.6 Type A Gas Appliance Acceptance - Individual Appliance Certification Schemes The Director has maintained the policy that a single appliance imported into Tasmania. Appliances may undergo individual site safety certification and acceptance. This scheme allows new or manufactured – non-certified individual appliances imported into Tasmanian to undergo inspection for safety certification against relevant technical standards determined by the Director. Importation in excess of five appliances will require class certification by an approved external authority in accordance with an appropriate technical standard and the requirements for class certification in the Act. There remains a strong demand for this Tasmanian specific certification scheme with fifteen separate appliances approved in 2014/15. The availability of overseas gas appliances using the internet is expected to drive a further increase in the call for individual certification. Pursuant to Section 70 of the Gas Act 2000, two Tasmanian Type B licensed gasfitters have been approved to conduct individual gas appliance certification. The Australian Gas Association, already being an approved external authority has developed an individual appliance scheme for commercial cooking appliances. The Australian Gas Association’s scheme is proving to be cost prohibitive to consumers due to the need to transport appliances to Victoria for testing. Individual appliance mutual recognition arrangements with interstate gas regulators are in place. Legislation enables importation into Tasmania of unique appliances previously approved by other interstate regulators. Figure 9 – Type A Appliance Approval by Director 4.7 Prohibition of Sale, Product Withdrawal and Recall of Gas Appliances and Components The Director has responsibilities pursuant to Section 79 A-C for prohibition of supply of unsafe gas appliances. A single prohibition on the sale of unsafe and non-compliant butane canister cookers was initiated during the reporting period. Following safety concerns, the Director’s office assisted and supervised several market initiated recalls within Tasmania during the reporting period. 22 Table 6: Tasmanian gas appliance prohibition of sale, product withdrawal and recall of gas appliances and components Appliance Action Reason for Action Butane canister cookers (multiple brands and models) Director of Gas Safety prohibition on the supply Voluntary national recall, Connections magazine article Voluntary national recall Non-compliance with prescribed standard and unsafe due to inoperability of over pressure protection device designed to disengage canister before canister rupture Global Valve Alliance (model BV20F ) Trauma hot water heaters Swift RV cooking appliances Cannon Heaters Coolabah BBQ Home Gas Smoker Voluntary national recall, Director direct mail out to identified appliance owners Negotiating with ACC for national recall Installation of flame failure device as part of appliance Unsatisfactory leakage Non-compliance with prescribed standard Incorrectly installed cookers; by not providing adequate support with the appliance enclosure, which in and a number of instances nationally led to excess movement and vibration causing internal appliance pipework to leak gas. Excessive levels of carbon monoxide entering homes under certain climatic and installation conditions Explosion following user re-light following appliance flame failure Thetford Triplex Plus Oven/Grill Cooking Appliance Voluntary national recall, Connections magazine article In some instances an incorrectly installed fascia causing the gas control valve to be misaligned and in extreme cases may stick in the open position. If this defect is present there is a risk of gas building up into the appliance when not lit and this may lead to a possible explosion within the oven. Comcater Pty Ltd Frymaster 45 Series Field retro-fit program Excessive carbon monoxide production during operation 4.8 Major Events Significant resources continue to be deployed to ensure public safety at significant Tasmanian events such as The Taste of Tasmania, Dark Mofo, Agfest and Festivale. This has required event organisers, with the assistance of the Director’s office, to develop and implement gas safety management plans for the safe use of gas appliances and emergency response in the event of a gas related incident. The Director’s comprehensive guidance material for both the storage and use of LP gas at public events, and the assessment and use of temporary flame effects operated before an audience, has been well received and implemented by event organisers and display managers, due largely to public exposure risks. The Director has implemented minimum requirements for the design, manufacture and operation of flame effects using an international standard that provides requirements for the protection of the audience, support personnel, performers, the operator, assistants, and property where flame effects are used. 4.9 Internet Sale of Gas Appliances It is disturbing to report the sale of new non-certified products, imported into Australia and purchased via the internet by Tasmanian consumers. This issue continues to be difficult for gas regulators to regulate. The significant reduction in Australian manufactured appliances, and a transfer to Asian offshore manufacturers, has seen this trend of importation of non-certified products grow considerably. Wholesaling of gas appliances via internet based sales sites without appliance certification is creating an unacceptable void in the appliance safety certification scheme and increasing risk to the public. 23 Importers often move to alternate interstate locations to avoid regulators’ attempts to implement legislative actions. Importers are prepared to undertake significant actions to avoid detection and the administrative powers of regulators. 4.10 Carbon Monoxide A carbon monoxide awareness program continues to be a priority of the Director, following the national strategy for exposure to carbon monoxide and the release of the coroner’s findings into the deaths of three men by carbon monoxide poisoning near Miena in the Central Highlands on 17 March 2012. Targeted carbon monoxide education programs have seen the Director’s office work with training providers and communicate with gasfitters, caravan suppliers and caravan rental businesses about the dangers of improper installation and operation of gas appliances, including the need for continual maintenance and testing for safe operation. Communication has been in the form of direct correspondence, published articles, participation at selected recreational vehicle expos and the presentation of sessions to gas fitters as part of the 2014 WorkSafe Month activities. Carbon monoxide educational topics included additional installation and testing requirements within gas fitting standard AS/NZS 5601 and raising awareness in respect to the enclosure of recreational vehicle appliance flues by annexes or similar. 4.11 Gas Installation and Appliance Incidents GSS has responded to 21 gas storage, installation and appliance incidents in this reporting period. Portable LP Gas storage and appliance incidents remain the predominant cause. Following a considerable number of incidents nationally and internationally, the use of patio style area heaters is predicted to represent a risk to Tasmanian consumers. Whilst these gas appliances are safety tested and conform to prescribed standards, the portability of these appliances lends to their misuse, such as operating them indoors or in poorly ventilated areas. Subsequently the Director’s Office has been working closely with the Gas Technical Regulators Committee on the development of additional local and national minimum safety standards including oxygen depletion monitoring devices and tilt sensing interlocks. Similar to trends identified in Tasmania, the collection of incident data at a national level has also identified that portable appliances connected to minor LP Gas storage cylinders and disposable canisters make up a disproportionate number of serious incidents compared to other forms of gas installations. As a result the Director has been involved in a number of projects aimed at reducing these incidents at a local and national level. Projects include the distribution of educational material and review of appliance design and certification standards. An unexplained spike in the number of incidents involving school science laboratory gas bunsen burner turrets was experienced this financial year. As a result, the Director’s office liaised extensively with the Department of Education, certification bodies, manufacturers, suppliers and maintenance contractors to develop a holistic and shared curative strategy. Continued monitoring and statistical analysis of incident causation will inform the Director of Gas Safety if this strategy is effective. 24 Figure 10 – Gas Incident Investigations SECTION 5: OFFICE OF THE DIRECTOR OF GAS SAFETY PROGRAMS/ACHIEVEMENTS Considering increased planned outputs the Director has completed all reactive programs and has made acceptable progress towards the rationalisation of the Gas Safety Legislation, development of unconventional gas utilisation and new evolving industries. These programs form the critical administration and control of gas infrastructure expansion and construction in Tasmania. The following programs are mandated under the Gas Act 2000 and the Gas Pipeline Act 2000 prescribed standards. 5.1 Regional Delivery of Programs Table 7: Operation and maintenance of administrative systems primary outputs Industry Segment Business Management System Output Reason Management Annual report output and statistical collation Annual report on activities of the Director Time allocation data collation for gas entity activity Time records Legislative requirement Gas Act 2000 Recovery of reasonable cost pursuant to Gas Act 2000 Communicate with national gas regulators Maintenance of technical and evolving standards Business document control Administer the document and publications register Web development and management Review and update the gas website Business administration and appliance programs Safe gas installations and appliances Maintenance of document and publications standards Quality control of public documents 25 Industry Segment Business Management System Output Reason Communications management system Internal delivery of relevant and timely publications Identify safety, training and educational needs and stakeholder expectations Gas appliance (Type A) safety management Gas appliance approval (Type A) program Gas External Authority approval Accident and incident investigation program Undertake commercial sensitivity assessment of gas infrastructure information records Gasfitter administration Deliver timely Freedom of Information requests Consumer safety Consumer safety Consumer safety Community safety Gas emergency response Preserve information confidentiality Ensure adequate Gas safety management GSMP for large or plan (GSMP) acceptances high risk installations Safety and reliability of installations Gasfitter installations notification database Verify gasfitter certifications of gas installations Gas installations Acceptance program Gas appliance design and installation acceptance (Type B) Gas Distribution Identify and implement unsafe gas appliance notifications Conduct safety approval procedures for appliances and establish national alliances Ensure competent organisations are approved to examine gas appliance safety Respond to accidents and incidents on gas transmission, distribution and installations that pose a risk to supply and public safety. Gas Entity network approval program Gas Entity network integrity monitoring Gasfitter certification data Deliver 3 regional installation technical compliance programs Deliver 3 regional Type B appliance technical compliance programs Review proposed network submissions Review of safety and operating plans Consumer safety Consumer safety Ensure construction standards compliance Ensure acceptable levels of public risk and supply integrity 26 Industry Segment Gas Storage and Conditioning Business Management System Installation disconnections and reconnection procedures. Gas Storage Systems Gas Storage Systems safety management and emergency response planning Output Reason Deliver timely disconnection orders Design acceptance and supplier / stakeholder management project Control unsafe or non-compliant gas installations Target supplier compliance in existing and new gas storage products Approval of GSMP Consumer and public safety enhancement While staffing resources available to the Director’s office remained low this year, the office was able to successfully deliver prescribed reactive outputs in line with industry expectations, including: Administration; gas installations [complex] acceptance; gas installations [prescribed] acceptance; gas appliance and installation research and standards development; gas distribution approvals programs; gas appliance and components certification and approvals; gas storage systems, reliability and supply; incident and accident investigations; and facilitation of compliance of new industry participants. Targeted recruitment to sustain Gas Standards and Safety outputs resulted in the promotion of an existing inspector to the vacant Gas Infrastructure Safety specialist role. Backfilling of the resultant gas inspector’s position has commenced and should result in an additional inspector commencing with the branch in the first quarter of the financial year. Filling this position will essentially provide staffing numbers one fulltime equivalent less than the operating level prior to the commencement of recruitment restrictions, and will provide much needed support to meet the diverse expectations and safety outcomes of industry and the general public. Table 8: Summary of Achievements Activity Function Safety Outcome Gas Distribution and Storage Investigated uncontrolled gas release incidents on gas infrastructure Driven development of network load shedding and gas quality emergency guidelines Maintained Gas Suppliers Gas Safety Management Planning for LNG and CNG Gas storage Identify causation of incidents and review operational standards Prevent recurrence of uncontrolled gas incidents, and ensure acceptable levels of public risk Stakeholder engagement and development of stakeholder appliance conversion, gas storage and natural gas supply in emergencies Enhance Tasmanian natural gas supply emergency plan Ensure timely response to any loss of containment incident, supply emergency and maintenance management Manage inherent public risks from uncontrolled gas emergencies. Assist emergency response organisations 27 Activity Function Safety Outcome Reviewed network reliability, integrity, operational management, public safety and condition survey Ensure compliance, adequacy, currency, accuracy and reliability of operational records Maintain supply safety and control public risk Reviewed development of gas entity operations safety and operating plans Implemented a compliance audit program for LNG gas pipeline facilities Participated in multi-agency emergency response and gas curtailment exercise Ensure compliance and adequate management of gas infrastructure through documented policies and procedures Ensure compliance of emergency response and planning Test current state wide emergency response and gas curtailment mechanisms Maintain supply safety and control public risk Maintain infrastructure safety and control public risk Protect vulnerable gas consumers Gasfitter Licensing and Gas Worker Accreditation Ongoing collaboration with stakeholders to identify required training and skills development for refrigeration workers for flammable hydrocarbon refrigerants Developed and delivered targeted training to wider gas fitting industry Investigated non-compliant gas installation work standards and resultant safety issues Provided advice and conducted investigations Ensure that comprehensive standards for training Maintain gas fitter competency around topical technical issues Issue gasfitter defects, infringement, consumer disconnect and rectification notices Ensure compliant gas fitting and licensing standards Ensure that competent persons undertake all forms of gas fitting work Ensure gas installation compliance and standards providing adequate level of consumer safety Ensure gas installation safety standards for consumers Ensure safe gas fitting and licensing standards Gas Appliances and Installations Investigated uncontrolled gas incidents on in situ and portable gas appliances Collaborated with national gas technical regulators on gas appliance safety concerns and initiate actions in respect to appliance certification bodies, suppliers and consumers Implemented policy for gas installations at public events Implemented carbon monoxide education program Identify causation of incidents and review technical standards Minimise the likelihood of death or injury from exposure to unsafe gas appliances Minimise the likelihood of inadequate installation and design Minimise the likelihood of death or injury from exposure to carbon monoxide Prevent reoccurrence, produce education materials, web information and implement product withdrawal standards Protection of consumers Ensure a transparent safety model is implemented for consumers and the public Prevent reoccurrence and provide education 28 Activity Function Safety Outcome Continued to research, review and adopt relevant technical standards and codes for gas appliances Develop, in conjunction with GTRC, appliance certification scheme rules Ensure a consistent and robust national appliance certification scheme that effectively delivers safety outcomes for ever increasing imported products Continued to develop and Ensure gas storage systems implement gas safety installations achieve management planning for acceptable levels of risk LNG, CNG, Bio Gas control and emergency Storage preparedness Continued to develop and Ensure installations achieve implement gas safety acceptable levels of risk management planning for control and emergency flare and waste gas preparedness removal systems Gas Technical Standards and Working Groups Contributed to national and Australian Building Code Development of best practice board agenda for inclusion and ensure net gain for the of on-site gas fitting work in gas fitting industry. National Construction Code Engaged gas supply Develop industry procedures industry stakeholders and communication protocols following out of in the event of reoccurrence specification gas incident Continued to research, review and adopt relevant Ensure consistent national and technical standards and international standards apply codes for emerging to Tasmanian gas industry technology Ensure evolving type A and B Participated in development appliance design achieve of industrial appliance acceptable levels of risk safety standards control Manage consequences and inherent risks Manage specialised surveying services to contain inherent risks Alignment of prescribed gas fitting technical requirements with the greater construction industry standards Ensure safe and reliable supply of natural gas to vulnerable consumers Ensure currency of intrinsic safety in the gas industry emerging technologies Set contemporary appliance design specifications Stakeholder Relations Facilitated stakeholder meetings for the management of buried infrastructure Continued to facilitate gas entity meetings for the management of safe gas infrastructure Contributed to national Gas Technical Regulator Committee programs Committed to GTRC audit program for external authorities. Participated with State Growth Natural Gas Supply Emergency Coordinating Committee Development of safe work procedures for work adjacent to buried infrastructure Ensure worker safety, recording and quality of location information Maintain adequacy of management communications Ensure safety and reliability of Tasmanian NG supplies Harmonise gas product and legislative outcomes to national and COAG standards. Maximise safety and economic outcomes to gas consumers Provide verification of external authority outcomes Ensure consumer safety and quality of approved gas appliance on the Tasmania market Preparation and prevention strategies for pipeline operations Facilitate and enhance natural gas supply protocols to ensure public and emergency worker safety 29 Activity Function Communications and Education Management Provide targeted guidance in respect to ground works Provided industry specific adjacent to buried gas training presentations infrastructure, and appliance safety performance in respect to Carbon Facilitate stakeholder and Administered a gas specific consumer access to gas internet site and gas safety technical standards and safety publications information Contributed articles to Improve stakeholder and end Connections magazine user education on gas safety Issued Guidance Notes Provide stakeholder advice following investigations Educate type B gas fitters on Commenced planning for changes to prescribed Type B appliance industry standards and provide forum opportunity for open forum Business Administration Administered, reviewed and identified opportunity for business management improvement Commenced review of document standards for web viewing Continue development of contemporary business unit models Safety Outcome Manage public risk by ensuring relevant industry stakeholders are aware of their obligations and safety expectations Provide timely delivery of industry communications products Enhance gas education policy and expand audience Enhance safety of civil and gas workers Safe and compliant type B appliances and planning to meet industry needs Efficiently administer all business processes Improve industry efficiencies Enhance timely delivery of services Ensure adequacy of regional safety and technical coverage thus improving output in line with industry and community expectations Ensure acceptable staff workloads and enhance timely delivery of services Commenced review of Act and Regulations Ensure adequate and improved regulatory requirements to facilitate safe outcomes in an evolving industry Provide consistent and contemporary gas safety framework Refined gas storage approvals systems and administration program Ensure adequacy of all gas storage facilities Enhance levels of public risk and reliability Commenced targeted recruitment Policy Development 30 5.2 Inspection Program Inspections of complex and prescribed standard gas installations and type B appliances increased again this reporting year in line with the increased industry demand for these acceptance programs. To ensure appropriate management of resources, the Director’s office examines the inherent risk of individual installations and appliances to drive and enhance its field-based inspection programs. Refer figures 11 and 12 As a result of statistical analysis of historical incident data derived from both Tasmania and nationally, the Director of Gas Safety continues to believe that standard gas installations and portable appliances are the greatest organisational risk confronting GSS. Subsequently GSS intensified, its proactive regional ‘standard’ gas installation inspection schedule. The Director of Gas Safety is conscious not to undermine technical and safety effectiveness already realised in respect to high risk complex and prescribed standard gas installations, and type B appliances. Therefore when considering the increased standard gas installation inspections realised as a result of this additional focus, compared as a proportion of actual installations installed, it demonstrates that standard gas install inspections continue to be primarily performed on a reactionary basis, following complaint or incident. Figure 11 – Field Inspection Activities Figure 12 – Type B Appliance Field Activities 31 5.3 Technical Standards Development Development of safety and technical standards for the Tasmanian gas industry is ongoing to meet emerging trends and technology expansion. Consultation between WorkSafe, industry stakeholders, end users, interstate regulators and gas industry organisations is ongoing to ensure currency, relevance and completeness of Tasmanian gas standards. Adoption of international standards is growing as unique appliances and appliance applications enter the local market. The Director’s office routinely provides technical comment and feedback to Australian Standards committees in respect to proposed amendments and drafts (refer Table 8). The Director is represented by GSS on Australian Standards committees AS 3814 Industrial gas appliances (AG-001-00-05) and AS 1596 The storage and handling of LP Gas (ME-15). Considerable resources have been allocated to these committee roles and to providing input into other evolving standards as they are amended to manage ongoing appliance, gas storage and gas infrastructure technological advances – including in particular gas turbine operational control and safety. Considerable resources have also been allocated to the consultative process with the Australian Building Code Board in respect to the inclusion of on-site gas fitting in the National Construction Code. This process is in the initial stages of development – primarily investigating the merits of the inclusion of gas fitting, in line with COAG directives, and the scope of on-site gas fitting work for inclusion in a standalone gas-fitting code of Australia. A consultation paper to stakeholders is expected to be released for comment in the latter half of 2015. Table 9: Technical Standards Development and Implementation 2014/15 Standard AS 1596 Title The storage and handling of LP Gas AS 2809 Road tank vehicles for dangerous goods Tankers for cryogenic liquids AS 2885.0 Pipelines—Gas and liquid petroleum Part 0: General requirements AS 3814 Industrial and Commercial Gas Appliances AS 3961 Liquefied Natural Gas— Storage and Handling AS 4670 Commercial propane and commercial butane for heating purposes Revisions Ongoing input to Standards committee ME15 agenda items Following extensive experience in general cryogenic operations, provide clarification of where a ‘Trycock’ valve fits into the requirements of this standard and the requirements for the use of Internal Safety Control (ISC) and Excess Flow Valves Draft amendments including comprehensive change of focus in respect to general and technical aspects of integrity management accountability and approvals. Major review featuring expanded hazard and risk requirements in line with international practice, functional safety of electrical/electronic/programmable electronic safety-related systems and contemporary gas engine requirements Provide requirements for the design, construction and operation of installations for the storage and handling of liquefied natural gas (LNG), covering installations of atmospheric-type tanks for supplying marine terminals, pipeline peak saving, and pressure tanks Draft Guideline developed by Gas Energy Australia as a supplement for the standard covering management of odorant in the LPG supply chain 32 Standard Title AS 5263 Gas appliances (parts 0, 1,2,3 & 7) AS/NZS 60079.10.1 Explosive atmospheres Classification of areas Explosive gas atmospheres Revisions New suite of appliance standards aimed at providing manufacturers, designers, regulatory authorities, testing laboratories and similar organisations with uniform minimum requirements for the safety, performance and use of gas appliances Standards committee MS‐011 proposal to significantly amend current standard including removal of industry-based examples contained in annex HBxxx Provide guidance for authorities, drivers, LPG industry business managers and supervisors through a tanker operation handbook National Construction Code Gas-fitting code of Australia Consideration of whether the technical requirements for on-site gas-fitting are better determined and expressed under current arrangements through the Gas Acts and regulations of each State and Territory or through the National Construction Code (NCC) as a separate Gas-fitting Code of Australia, which would in-turn be referenced by legislation of the States and Territories NFPA 160 Standard for the Use of Flame Effects Before an Audience Provide guidance to public safety officials, designers, and operators of flame effects for the reasonable protection for viewing audiences and performers of flame effects. Draft Australian Standards Handbook 5.4 Vehicle Gas Fitting and Stationary Engines While the newly implemented vehicle gasfitter worker competency training package for LNG, CNG and LP gas vehicle gasfitters by Skills Tasmania and the worker licensing scheme by BSOL are operating effectively, the slowdown of commercial uptake of gas as an automotive fuel has restricted the implementation of vehicle gas fitting packages this year. Industry stakeholder consultation is ongoing for the review of automotive gas fitting competency requirements, standards of work, and records. The Director of Gas Safety held a meeting with the Tasmanian Automobile Chamber of Commerce and Department of State Growth -Transport to further develop regulatory and administration cooperation. Work determinations and licensing development pursuant to the Occupational Licensing Act for stationary gas engines has been completed and executed. Industry stakeholder consultation is ongoing for review of competency requirements. No new work was undertaken by the Director’s office on this matter. 5.5 Gas Committees and Associations Membership of the national GTRC regularly provides Tasmania with current gas appliance and gas technical and safety information exchange, including products withdrawn from market, illegal sales of equipment, and audit results by interstate regulators on appliance certifying bodies. Member communications frequently result in product warnings to the Tasmanian public, gasfitter communications or appliance safety investigations. 33 The bi-annual meetings revolve through participating states and territories. The financial capacity of GSS budget has allowed, for the first time in a considerable number of years, the opportunity for GSS to attended both GTRC meetings convened during the reporting period – with Tasmania hosting the November 2014 GTRC meeting in Launceston. This has permitted GSS participation in the GTRC programs that directly affects the Tasmanian Gas Industry and COAG national program implementation. Staff attended the Tasmanian Electrolysis Committee regional meetings. The Committee’s role identifies the adequacy of cathodic protection systems and design requirements for high pressure gas pipelines and infrastructure in the vicinity of high voltage electrical infrastructure. To test, practice and explore industry mechanisms and communications between each of the major stakeholders during a natural gas supply shortage, the Natural Gas Supply Emergency Coordination Committee conducted the desk top exercise ‘slow burn’. The exercise involved all major stakeholders in the Natural Gas industry in Tasmania to confirm whether the Tasmanian (Natural) Gas Supply Emergency Management Plan adequately describes the roles and responsibilities during a natural gas supply shortage. All participants derived benefit from the exercise, including an understanding of the consequences of curtailment decisions on contractual obligations, and vice versa. More recently the Director’s office has convened several meetings of members of the Natural Gas Supply Emergency Coordination Committee. First, a post-incident debrief following a gas quality excursion, and second, a planning meeting to discuss the consequences of gas rationing as a result of imminent industrial action at the BHP ESSO gas plant. Table 10: Participation in committees and organisations Committee Member organisations Gas Technical Regulators Committee (GTRC) All Australian States and New Zealand gas technical regulators Committee to Coordinate the Response to Energy Supply Emergencies Gas infrastructure owners, GSS, Department of State Growth Tasmanian Electrolysis Committee WorkSafe, Aurora Energy, Tas Networks, Hobart City Council, Telstra, Tas Water, Tas Gas Networks, private consultants 5.6 Committee purpose Harmonisation of national gas safety standards and advice to COAG. Industry communications. Requests for appliance condition and investigations. Acceptance of external authority performance audit. A functional committee to coordinate across jurisdiction emergency gas supplies Functional committee to coordinate electrolysis standards for Tasmanian infrastructure Policy Development and Legislation Significant resources have been required in undertaking a major review of both the Gas Pipelines Act 2000 and the Gas Act 2000. The purpose of the review being to separate the economic/licensing functions administered by the Department of State Growth and the technical/safety functions administered by the Director of Gas Safety and Department of Justice. These functions are currently combined in both sets of legislation and in many cases are not clear. 34 This approach is also in line with Government expectations, and consistent with the Government’s Tasmanian Energy Strategy requiring the elimination of unnecessary bureaucracy that does not promote safe, reliable gas infrastructure, or provide proper safety and technical standards for gas installations and appliances in line with community and public safety expectations. At the end of the reporting period both the Director of Gas safety and Department of State Growth have prepared and presented drafting instructions and draft bills to the Office of Parliamentary Counsel. 5.7 Communications and Gas Safety Education Development of policy and educational information to inform stakeholders of legislative and technical matters has remained a focus during 2014/15. See Table 11 for outputs of this program. The Director’s education program delivery has expanded from a model predominately restricted to the use of electronic media, web publications, Connections magazine, and targeted programs to stakeholders, to include expos and other public events. This new delivery method is seen as the primary model for maximum penetration to stakeholders. The bi-annual Connections magazine has been substituted by a BSOL e-newsletter distributed to allied trades on a two-monthly cycle. The e-newsletter has been highly beneficial in communicating specific messages to all building trades, professions and gas fitting industries in a timelier manner. Also well received were three regional gas fitting compliance presentations delivered in conjunction with WorkSafe’s ‘WorkSafe Month’ activities. This year’s sessions targeted the new content of the recently amended gas fitting standard AS/NZS 5601. Not so successful was the attendance at a Natural Gas Awareness Seminar for Civil Contractors working within Tasmanian Road Reserves – where the attendance was very disappointing. This was despite the sessions being sanctioned and jointly presented by TGN, DBYD and the Tasmanian branch of the Civil Contractors Federation. Additional presentations are expected this coming year, including the substantially revised gas fitting standard AS3814 and continuation of the targeted education program into the dangers of misused gas appliances and resultant carbon monoxide. GSS also delivered its gas safety and compliance message to industry and a targeted public audience at selected expos and public events. Further analysis of cost affective public and consumer education methods is ongoing and will be priority in 2015/16. Table 11: Communication products Program GSS website Gas quality curtailment standards Complex gas installation application Type B appliances New or Managed Output 2013/14 Target Audience Maintained a gas safety and technical standards website Gas consumers Gasfitters Gas workers Gas distributors Community Rural landowners Infrastructure owners Final draft approved for Emergency Gas Supply conditional approval procedure Quality specification for distributors Gas entity notification protocol Director’s gas safety management confirmation policy WorkSafe Director Distribution entity Retailers Type B gasfitters Industrial consumers 35 Program New or Managed Output 2013/14 Biogas collection and utilisation Director’s biogas safety policies Director’s gas safety management policy Presentations Education Biogas publications including Fact Sheet Gas Safety domestic biogas systems, Guidance Note Gas Safety - Gas Installations Supplied from biogas facilities and Guidance Note Gas Safety - Biogas gas composition certification Gas safety and technical publications Fact Sheet - Gas Safety Badly Ventilated Gas Flues create safety concerns for RV users Information Sheet - Gas Safety - Gas installation with buried gas pipes within public land - Reissued Fact Sheet - Prohibition on the sale of gas appliances March 2015 Fact Sheet Gas Safety - A guide for gas appliances air requirements Expos and other public events 5.8 AGFEST, HIA Home and Building Expo, Sustainable Living Expo and various camping and recreation expos Target Audience Gasfitters Developers Waste and water authorities Gasfitters Gasfitters Gas Consumers Civil Contractors Gasfitters Consumers Community Gasfitters Annex manufacturers RV industry Consumers Community Gasfitters Consumers Community Consumers Gasfitters Community Gas consumers Gasfitters Gas workers Community Rural landowners Civil Contractors RV industry Staff Development Continuous development is encouraged for all authorised officers and administration staff. Staff development and mentoring is ongoing with additional staff training requirements identified in Table 12. Staff training is provided in accordance with agreed development plans that provide and develop individuals’ and Gas Standards and Safety’s growing areas of speciality. Core training including Type B gas appliance, design assessment, combustion engineering and product monitoring is continuing. Staffing, training and operational efficiencies are priorities but are severely stretched to meet all areas of gas industry expansion and development. Technical library resources also continue to be sourced to ensure Gas Standards and Safety staff capability for meeting the expected gas industry emerging technology, energy efficiency, fire hazard analysis and risk modelling and analysis. 36 Table 12: Staff development Issue or Risk Rotating appliances Non-consuming gas equipment Permitting fuel cells (hydrogen) Development Turbine standards adopted Combustion engineering standards Adiabatic energy transfer systems - safety standards Certification and building standards Reciprocating engines including automotive gas installations Internal combustion, work engine safety Technology and specialist control equipment Equipment fit for purpose analysis and incident investigation. Original equipment manufacturer programing access certificates. High pressure gas infrastructure fabrication and quality assurance standards Model to compliment layers of protection philosophy LNG technical and safety standards Quantitative risk assessment and layers of protection philosophy for safety of LNG consuming installations Societal thermal risk quantitative modelling Thermodynamics Models implemented for qualitative and quantitative risk assessment Adiabatic compression or expansion, work engines Gas storage Liquid storage, dehydration, and gas vaporisation Gas measurement Waste and biogases Pipeline continuity of supply and public risks Purging and inverting Fire science, fire dynamics and fire causation Highly technical incident investigations including complex causational relationships with operational management 5.9 Liquid and gas chromatography, mass measurement and meter proving Waste gas quality and safe combustion Pipeline direct assessment and validation procedures Steel pipeline corrosion control cathodic protection Safe purging of large volume vessels Fire investigation, key technical skills interpreting the patterns and phases of fire Precise analysis of incident root cause/s Gas Supply Management The Director of Gas Safety is a member of the Natural Gas Supply Emergency Co-ordination Committee – a sub-committee of the Committee to Coordinate the Response to Energy Supply Emergencies for the purpose of advising the Minister on how to respond to natural gas supply emergencies. The Manager of Gas Safety represents the Director on this committee. The Director of Gas Safety has committed to the Tasmanian Gas Emergency Response and Coordination Plan requirements. A staff availability roster is operational for after-hour response to onshore gas infrastructure and installation incidents, as well as intrastate, interstate and offshore supply or gas quality issues. Response to 34 installation and supply incidents during the reporting period and total of 201 over seven years of implementation has been beneficial to Tasmania Fire Service and Tasmania Police in responding to incidents and ensuring safe procedures for isolation and recovery. The Director of Gas Safety’s incident response management system has enhanced enforcement of real time isolation of uncontrolled gas escapes and gas vapour cloud control of deflagration events. 37 An out of gas specification incident did not result in gas curtailment to any consumers as a direct result of preparation due to industry participation in exercises for pipeline emergency management and recovery planning. The incident did provide valuable learning opportunity with the Director of Gas Safety facilitating an incident debrief with a licensed gas entities, Department of State Growth, major consumers and suppliers. Agreed outcomes derived as a result of lessons learnt from this real life testing of industry interaction and communication. in particular the contractual arrangements that drove communications and decisions, will be developed and implement by Gas Standards and Safety during 2015/16 Aside from testing aspects of the Inter Government Tasmanian (Natural) Gas Supply Emergency Coordination Plan, this exercise proved constructive for assessing sufficient GSS resources to manage the information and decision making needs during a natural gas supply emergency. The review of GSS’s Incident Response Management Plan will receive priority following recruitment in key positions. The Director’s office maintains internal emergency communication protocols and contact data for Tasmanian-based LP Gas, CNG and LNG suppliers. Emergency data exchange with the Tasmania Fire Service as part of the co-operative program is facilitated by the Director of Gas Safety. This data exchange enhances preparedness for industry communication and response protocols and the Director’s office emergency callout to incidents during after-hours response. 5.10 Emergency Incident Coordination The Director maintains management plans and internal procedures for GSS ‘on shore’ emergency gas incident response protocols. Emergency Incident Response Management plans and the staff availability roster have operated successfully to cater for an expanding use of different fuel gases and complexity in gas supply chain management. Documentation for gas appliance, gas conversion approvals and standby liquefied gas storage approvals during gas curtailment are available for emergency implementation. 5.11 Gasfitter Training and Accreditation As reported previously, GSS became part of the newly formed Building Standards and Occupational Licensing in the latter half of 2014; the outcome of a merger of Building Standards, Electrical Standards, Working With Vulnerable People, and Occupational Licensing and Accreditation. This amalgamation has realised expected synergies including technical assistance and policy advice for Occupational Licensing Act administration and licensing scheme for gas fitting. A database for recording all consumer gas fitting work certifications is maintained by the Director of Gas Safety. Records provide interpretative and administrative systems for monitoring the performance of gasfitters. WorkSafe Tasmania maintains a database of all self-certifying licensed vehicle gasfitters. Relocation of these records and auditing of work and compliance monitoring has been identified through the maintenance of a completed work notification scheme; however, the Director has not had the resources needed for this particular project. 38 SECTION 6: INTERGOVERNMENT INDUSTRY ADMINISTRATION Collaboration with the Office of the Economic Regulator ensured a smooth path for pipeline approvals, licensing and recovery of the Director’s reasonable costs from licensed gas entities. Cooperation with the Tasmania Fire Service in relation to fuel gas industry expansion and the changed requirements has been limited due to restricted resource capability. Despite this, notification reliability has significantly increased for incidents and emergencies in which gas is, or is suspected to be, a contributing factor. Emergency management, emergency incident response and incident investigation is ongoing, with sound intergovernmental communications and response capability established between first notification and response systems. SECTION 7: CONCLUSION New installation connections are continuing in all gas networks. Increasing social and political drivers are encouraging commercial and industrial buildings to undergo retrofitting as energy efficiency expands the use of clean hydrocarbon fuel gases. Retrofitting of more efficient appliances and the ongoing emergence of new technology used in production and storage of compressed natural gas (CNG), liquefied natural gas (LNG) and biogas has required the office to broaden the development of product and appliance technology projects. Increased use of advanced equipment control technology for specialised appliance combustion control and reduced atmospheric contaminants has required additional administrative review and acceptance models. Targeted training will be ongoing for specialist type B appliance inspectors during 2015/16. The vehicle gas fitting industry has not previously had work standards administered through the requirements of the Gas Act 2000. This has been identified as requiring specialised resources within GSS. Notwithstanding Occupational Licensing (Reciprocating Internal Combustion Engine Gas-fitting Work) Determinations, no automotive installation standards program was commenced in this year. COAG, through the COAG Energy Council (formally Standing Council on Energy and Resources is driving national reforms for harmonised legislation in: gas appliances safety certification standards; energy (pipelines and networks) technical and safety standard harmonisation and enhancement planning; new gas appliance certifying models; and strategy for carbon monoxide by gas appliance. The harmonisation of downstream consumer installation standards continues to be driven by the Australian Building Code Board. The Board has determined to proceed with the scoping of a Gas Code for onsite building work, as part of a process to help determine the costs and benefits of developing such a Code for inclusion in the National Construction Code. The Director’s office has and will continue to participate as a member of a Working Group to scope what a Gas Code for onsite work would contain, which will then be provided to industry Stakeholders under the COAG Best Practice Guidelines for Regulation. Rationalisation of the Gas Pipelines Act 2000 and the Gas Act 2000, separating economic/licensing and technical/safety functions has substantially commenced. Development of the Gas Safety Bill and subsequent regulations will be ongoing in 2015/16. 39 Resource planning will need to be provided to meet these challenges. At this stage, all issues to reach a harmonised approach for all states and achieve across border synergies are being handled by national working parties. Gas transmission programs pursuant to the Gas Pipelines Act 2000 have seen a reduced approvals schedule. However increased involvement in downstream programs has been at the detriment of proactive programs involving policy and legislative development, education and communications, and the gas entity safety management systems auditing and review program. Restrictions and staff movements are inhibiting the delivery of some programs. Reinstatement of the GSS unit staffing levels has commenced in line with the identified growth areas; this is required to enable the Director’s capability to meet all current programs and maintain public safety standards, and ensure supply and reliability standards are achieved as the Tasmanian gas industry growth continues. A greater enforcement focus has been introduced and continues to require considerable resources, in particular those matters involving interference with gas infrastructure, diversion and abstraction of gas, extended gasfitter work standards, focus to standard gas installations, pipeline integrity, gas conditioning, gas storage and new compliance standards. Dale Webster DIRECTOR of GAS SAFETY 40 APPENDIX 1: GLOSSARY AND ABBREVIATIONS ABCB AEMO BSOL CNG COAG Director GSMP GSS GTRC ISO kPa LNG LP Gas MAOP NCC NFPA NG PIG TGN Australian Building Code Board Australian Energy Market Operator Building Standards and Occupational Licensing Compressed Natural Gas Council of Australian Government Director of Gas Safety Gas Safety Management Plan Gas Standards and Safety (Unit of Workplace Standards) Gas Technical Regulators Committee International Standards Organisation Kilo Pascals Liquefied Natural Gas Liquefied Petroleum Gas Maximum Allowable Operating Pressure National Construction Code National Fire Protection Association Natural Gas Pipeline Integrity Gauge Tas Gas Networks 41