In the first part of our series on provincial regulations, we look at the approval process for a leak repair in Ontario.
While you can plan to clean up and perform repairs when leaks occur, you never plan for a leak to happen. And, when it does, you need a fix fast. That’s why it’s helpful to know how to plan for and seek regulatory approval for leak repairs in advance.
Same plan …
“From an execution standpoint, once the repair or component is registered, the plan to complete the repair is the same activity. There are slight differences, however, within each regulatory authority,” Innovator Technical Director Chris Coombs said.
That means, whether you’re in Alberta or Ontario, the leak repair process is the same. In fact, they’re standard and procedurally driven regardless of your location.
… Different regulations
How facility leaders seek approval for those repairs, however, is where the differences lie.
“Each province has a regulatory authority responsible for interpreting governing codes and standards and administration of the safety programs in relation to pressure boundary systems,” Coombs said. “In Ontario, that organization is called TSSA, the Technical Safety and Standards Association.”
The government-appointed authority in Alberta is the Alberta Boiler and Pressure Vessel Safety Association (ABSA).
“In each organization, there are review engineers or safety code officers, respectively,” Coombs explained. “Those individuals are responsible for reviewing designs or repair plans in conjunction with the governing code. They’re responsible for reviewing the application and ensuring whatever activity — a leak repair or hot tap — meets the intent of those codes and the provincial legislation. That’s the responsibility of each organization.”
The enclosure curveball
But a leak repair isn’t always just a leak repair. While suppressing a leak on a non-pressure boundary component doesn’t require regulatory approval, those requiring pressurized enclosures do. In fact, one of the most common leak repair methods involves using an enclosure to suppress the leak. In these applications, designers and fabricators either craft an enclosure for a specific leaking component or select an enclosure from a stock program.
“Engineered enclosures are classified as Category ‘H’ fittings (CSA B51) and do not have dedicated design codes to follow,” Coombs explained. “Typically, ASME Section VII Div.1 rules are applied where applicable while also utilizing recognized engineering publications and ensuring compliance with the ‘code of construction’ for the leaking component.”
These enclosures then become part of the pressure boundary for that system and, therefore, require approval from the jurisdictional authority (JA). As with planning for a leak repair, enclosure engineering is very similar regardless of the province, but regulations differ on how each approves an application based on the JA.
“Whether we’re installing that enclosure in Alberta or Ontario, as a company, the engineering principles we follow are the same. When it comes to how you apply for approval on provincial regulations — following the rules for TSSA or ABSA — that’s when it separates a little,” Coombs said.
“The biggest difference between Alberta and Ontario is not actually in the enclosure approval. It’s how they approve the overall application.”
In Ontario, contractors can apply for an Online Leak Sealing Certificate of Approval (CofA), which allows them to perform these activities at locations controlled by Quality Management Systems.
When contractors successfully demonstrate this capability through competency, procedures, and a quality control manual, they are granted this certificate. Once the Quality Management System is in place, leak repair approval activity involving an engineering enclosure is heavily dependent on the registration of that design.
The Ontario leak repair advantage
Through collaboration with Innovator and other industry stakeholders, TSSA has implemented an expedited review process with a three-day turnaround. This speedy turnaround time allows contractors and end users to perform leak repairs with engineered enclosures much quicker when compared to other jurisdictions.
“Innovator is always on the leading edge of either the design requirements or we’re actually the ones initiating the changes in those design requirements. A very common thing I hear, whether it’s from our customers or somebody in our company is, ‘We didn’t do that five years ago’ or ‘Why didn’t we have to do that 10 years ago?’” Coombs said. “It’s because we’re always evolving our process, learning from what we’ve done, and improving on it. That’s something we carry throughout all our business. It’s not just in leak repair or hot tapping, that’s standard throughout our company.”
Since such evolution comes standard, customers can rest assured knowing they can expect and will receive the best service possible no matter where they are. We’ll explore a closer look at leak repair in Alberta in the next part of our series on government regulations.