the pressure equipment safety authority

Overpressure Protection Requirements

AB–525

Edition 2, Revision 0 – Issued 2021-12-13

 Overpressure Protection Requirements

Table of Contents
FOREWORD .................................................................................................................. iii
1.0 INTRODUCTION .................................................................................................. 1
2.0 SCOPE ................................................................................................................. 2
3.0 DEFINITIONS ....................................................................................................... 3
4.0 REFERENCE PUBLICATIONS............................................................................ 6
5.0 OVERPRESSURE RISK ASSESSMENTS .......................................................... 8
5.1 Overpressure Scenarios ............................................................................ 8
5.1.1 Scenarios to Be Considered ........................................................... 8
5.1.1.1 Special Scenario Requirement for Heat Exchangers ..................... 8
5.1.1.2 Mitigation by Active Operator Intervention ..................................... 9
5.1.1.3 Maximum Upset Pressure of a Connected CSA Z662 Line ..........10
5.1.2 Consideration for Co-Occurrence of Scenarios ............................ 10
5.1.3 Outcome of Scenario Evaluation .................................................. 10
5.2 Documentation of the Overpressure Risk Assessment ............................ 11
5.2.1 Supplementary Documentation Requirement for Vessels ............ 11
5.2.2 Overpressure Risk Assessment Summary ................................... 11
5.3 Revalidation of an Overpressure Risk Assessment ................................. 12
6.0 METHODS OF OVERPRESSURE PROTECTION ............................................ 13
6.0.1 Limitation to Protection by Pressure Relief Valves ....................... 13
6.0.2 Limitation for Protection from Certain Chemical Reactions........... 13
6.0.3 Special Consideration for Adequately Vented Discharge Piping
Systems ................................................................................................... 13
6.1 Protection by Pressure Relief Valves, Rupture Disc, and Pin Devices .... 14
6.1.1 Integrity Management System Requirements ............................... 14
6.1.2 Overpressure Protection System Design Requirements .............. 15
6.1.2.1 Required Relief Device Set Pressure and Capacity Rating...........15
6.1.2.2 Requirements for Intervening Valves ............................................15
6.1.2.3 Pressure Relief Valve Location for Fired Equipment.....................16
6.1.2.4 Technical Justification Required for Rupture Disc and Pin Devices
16
6.1.3 Design Submission Requirements ................................................ 16
6.1.3.1 List of Pressure Relief Devices .....................................................17
6.1.3.2 Additional Documentation for Rupture Disc and Pin Devices ........17
6.2 Overpressure Protection by System Design (OPPSD): Listed Cases ...... 17
6.2.1 Integrity Management System Requirements ............................... 18
6.2.1.1 System Documentation and Operation / Maintenance Procedures
18
6.2.1.2 Establishment of a Monitoring Program ........................................19
6.2.1.3 Establishment of a Management of Change (MOC) Program .......19
6.2.1.4 Supplementary Requirements for Vessels ....................................20
6.2.2 System Design Requirements ...................................................... 20

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6.2.2.1 Permitted Cases...........................................................................20

6.2.2.2 Required Maximum Allowable Working Pressure .........................21
6.2.2.3 Supplementary Requirements for Section VIII-1 Vessels..............22
6.2.2.4 Engineering Assessment for Adequately Vented Equipment ........22
6.2.3 Design Submission Requirements ................................................ 22
6.2.3.1 Required Submission Contents ....................................................23
6.2.3.2 Supplementary Requirements for Vessels ....................................24
6.3 Overpressure Protection by System Design (OPPSD): Unlisted Cases .. 24
6.3.0.1 Consideration on a Case-by-Case Basis ......................................25
6.3.1 Integrity Management System Requirements ............................... 25
6.3.2 System Design Requirements ...................................................... 25
6.3.2.1 Technical Justification Required ...................................................25
6.3.2.2 Required Maximum Allowable Working ........................................25
6.3.2.3 Equivalent Safety to a Pressure Relief Valve................................25
6.3.2.4 Supplementary Requirements for Vessels ....................................26
6.3.3 Design Submission Requirements ................................................ 26
6.3.3.1 Required Submission Contents ....................................................26
ANNEX A: ALTERNATIVE APPROACHES TO THIS DOCUMENT ............................ 28
A-1 Statement of Variations from AB-525 Required ....................................... 28
A-2 Alternative Approaches ............................................................................ 29
A-3 Variance Required for Variations from Regulated Requirements ............ 29
ANNEX B: ALTERATIONS AND MODIFICATIONS .................................................... 30
B-1 Increase in Maximum Upset Pressure ..................................................... 30
B-2 Change of Overpressure Protection Approach ........................................ 30
B-3 Additions and Modifications to Pressure Equipment ................................ 30
B-4 Exemption from Registration for Small-Volume Additions........................ 31
ANNEX C: OVERPRESSURE REPORTING REQUIREMENTS .................................. 32
C-1 Unsafe Overpressure Conditions ............................................................. 32
C-2 Investigation and Follow-Up by Owner .................................................... 32
ANNEX D: DOCUMENTATION OF EXISTING SYSTEMS .......................................... 33
D-1 Identification of Overpressure Protection ................................................. 33
D-2 Use of Overpressure Allowances by Legacy Equipment ......................... 33
D-3 Update of Integrity Management System ................................................. 33
D-4 Acceptance of Overpressure Protection .................................................. 34
D-5 Timeline for Implementation..................................................................... 34
ANNEX E: CHANGE OF EQUIPMENT OWNERSHIP ................................................. 35
REVISION LOG ............................................................................................................ 36

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FOREWORD

The Administrator in the pressure equipment safety discipline has established

that this ABSA document, AB-525: Overpressure Protection Requirements for
Pressure Vessels and Pressure Piping, Edition 2, Revision 0, defines
requirements that must be met in Alberta for systems that consist of pressure
piping and/or pressure vessels where overpressure protection is provided by:

 pressure relief valve(s) in accordance with subsections 38(1)(a), 38(2), and

38(3) of the Pressure Equipment Safety Regulation; and/or,
 other means of overpressure protection, as provided for by subsections
38(1)(b) and 38(3) of the regulation.

In addition to providing guidance as to how overpressure protection

requirements can be met, this document also establishes how certain cases of
overpressure protection by system design for pressure vessels and pressure
piping may be registered without applying for case-by-case consideration.

The next reaffirmation of AB-525 is scheduled for 2025.

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1.0 INTRODUCTION
The Pressure Equipment Safety Regulation requires that all pressure equipment be
protected from overpressure by means of a pressure relief valve, or by other means of
overpressure protection acceptable to the Administrator.

Pressure relief valves are the most practical choice for many applications. Pressure
relief valves are dedicated devices attached to the equipment that, by means of simple
mechanical actuation, open to release some of the equipment’s contents into a flare
system or directly to the atmosphere in order to relieve excess pressure, providing a last
line of defense against catastrophic failure of the equipment.

Pressure relief valves may not be suitable for all applications. In the past, the question
was raised as to what other methods of overpressure protection can be expected to be
acceptable to the Administrator, and how such systems need to be documented at the
time of design registration. An industry task group was formed in January 2011 to
address this question, with the goal of setting out guidelines to help ensure that
designers can specify overpressure protection systems with confidence that they will be
accepted.

Later that year, the group finalized and adopted a report proposing recommendations to
ABSA for the use of overpressure protection by means other than by pressure relief
valves; the report was reviewed and endorsed by the Boilers and Pressure Vessels
Technical Council of the Safety Codes Council at their meeting in September 2011. The
original edition of this document was based on the recommendations made in that
report.

A task group was reassembled in 2018 to obtain feedback and discuss requests for
changes to the 1st edition of this document. This resulting 2nd edition is a complete
rewrite and restructure of the original, intended to more fully develop or otherwise clarify
some concepts, and to facilitate comprehension and compliance.

ABSA policy documents are periodically reviewed to ensure that they are aligned with
current industry practices. We would welcome any suggestions you have to improve this
document. Please provide your comments to:

Djordje Srnic
Manager of Codes and Standards
[email protected]

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2.0 SCOPE
This document applies to pressure piping systems and pressure vessels1 that are
subject to the Safety Codes Act and are not exempt from the Pressure Equipment
Safety Regulation. It also applies to pipelines and other additional equipment which is
required to be registered by ABSA in accordance with AER Directive 077 and IB10-006.

This document supplements and clarifies the requirements of the Safety Codes Act and
the Pressure Equipment Safety Regulation.

Thermal relief for piping in liquid service shall be addressed by the designer and is not
within the scope of this document.

The main body of this document establishes requirements for overpressure risk
assessments and for overpressure protection of equipment by several specific means.
The following supplementary appendices are mandatory and within the scope of this
document:

 Annex A, ‘Alternative Approaches to this Document’ establishes requirements

for submissions which make minor variations from this document, and
contains brief discussion about other approaches not within the scope of this
document.
 Annex B, ‘Alterations and Modifications’ establishes requirements for changes
to existing equipment, when the equipment will rely on overpressure
protection by means other than a pressure relief valve after the change is
complete.
 Annex C, ‘Overpressure Reporting Requirements’ discusses the Safety
Codes Act requirement to report accidents and unsafe conditions, and refers
to IB18-004 for the definition of ‘unsafe condition’ as it applies to overpressure
protection for the purposes of determining reporting requirements for
overpressure events.
 Annex D, ‘Documentation of Existing Systems’ discusses the application of
these requirements for systems predating the original 2013 publication of this
document.
 Annex E, ‘Change of Equipment Ownership’ establishes and clarifies
requirements pertaining to changes of equipment ownership.

1
Requirements in this document for pressure vessels also apply to vessels registered as category ‘H’
fittings.

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3.0 DEFINITIONS
ABSA Safety Codes Officer (SCO) – means a safety codes officer, designated under
the Act, in the pressure equipment discipline. [PESR 1(1)(ee)]

Act and Regulations – means the Alberta Safety Codes Act and the following
regulations:

Pressure Equipment Exemption Order (Alberta Regulation 56/2006),

Pressure Equipment Safety Regulation (Alberta Regulation 49/2006),
Power Engineers Regulation (Alberta Regulation 85/2003),
Pressure Welders Regulation (Alberta Regulation 169/2002)

Administrative controls – procedures that, in combination with mechanical locking

elements, are intended to ensure that personnel actions do not compromise the
overpressure protection of the equipment.

Administrator – means the Administrator in the pressure equipment discipline

appointed under the Act. [PESR, 1(1)(b)]

Canadian Registration Number (CRN) – is the acronym for Canadian Registration

Number and means a design registration number issued by a pressure
equipment jurisdiction in Canada per the requirements of CSA B51 Code. CRNs
are issued for boiler, pressure vessel or fitting designs. A boiler, pressure vessel
or fitting that is planned to be used in Alberta must have a CRN issued by ABSA.
Note: In addition to CRNs, there are other types of provincial design registrations
in Alberta. Alberta provincial design registration numbers (not CRNs) are issued
for pressure piping design registrations (PP numbers), special design
registrations (ALDs), or welding procedures (WPs).

Credible overpressure scenario – means an overpressure scenario that is

foreseeable and which has not been demonstrated to be non-credible in
accordance with one of the methods listed in section 3.1.2 of WRC 498.

Fired heater pressure coil – means the total fluid-retaining system with an internally
insulated enclosure and header boxes of a petroleum or chemical plant direct-
fired heater, including tubes, return bends, crossover piping, inlet and outlet
headers, and manifolds. [PESR, 1(1)(m)]

Integrity management system (IMS) – means a system for ensuring that pressure
equipment is designed, constructed, installed, operated, maintained, and
decommissioned in accordance with the Pressure Equipment Safety Regulation.
[PESR 1(1)(s)]

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Intervening valve2 – a valve which has the potential to block flow along the relief path
of pressure equipment, due to being placed either between the protected
equipment and its relief device, or between the relief device outlet and the point
at which vented fluids are released to the atmosphere.

Maximum allowable working pressure (MAWP)3 – means the pressure authorized on

the design registration or a lesser pressure as indicated on the manufacturer’s
data report. [PESR 1(1)(v)]

Maximum upset pressure – for a specific pressure equipment component that is

protected other than by a pressure relief device, means the maximum pressure
condition that the component could foreseeably be exposed to in any credible
overpressure scenario identified by an overpressure risk assessment.

Mechanical locking elements – means elements that when installed on a stop valve,
provide a physical barrier to the operation of the stop valve, such that the stop
valve is not capable of being operated unless a deliberate action is taken to
remove or disable the element. Such elements, when used in combination with
administrative controls, ensure that the equipment overpressure protection is not
compromised by personnel actions. Examples of mechanical locking elements
include locks (with or without chains) on the stop valve hand wheels, levers, or
actuators, and plastic or metal straps (car seals) that are secured to the valve in
such a way that the strap must be broken to operate the stop valve. [Sec XIII,
App. B, Par. B-3]

Overpressure protection by system design (OPPSD) 4 – protection of pressure

equipment from overpressure by means other than by use of a pressure relief
valve, rupture disc, or pin device.

Overpressure risk assessment – means a risk assessment in which qualified

personnel consider all credible overpressure scenarios with respect to each
pressure equipment component within its scope, and determine either a required
set pressure and capacity rating for a relief device, or a maximum upset pressure
for which the component needs to be designed.

Owner – includes a lessee, a person in charge, a person who has care and control and
a person who holds out that they have the powers and authority of ownership or
who for the time being exercise the powers and authority of ownership [SCA
1(1)(v)]

2
Intervening valves were referred to as controlled valves in the previous edition of this document. Use of
the term controlled valve has been discontinued in order to avoid potential confusion between controlled
valves, which are valves that are subject to administrative controls in order to prevent their inadvertent
operation, and control valves, which are valves used to control the flow of fluid in process applications.
3
As defined herein and in the Pressure Equipment Safety Regulation, this term is equivalent to the term
‘design pressure’ with respect to pressure piping, as used in the pressure piping codes.
4
In the original edition of this document, ‘OPPSD’ was used to refer only to overpressure protection by
specific predefined methods; in this revised edition, it includes what was previously referred to as ‘Other
Methods of Overpressure Protection’ (OMOPP).

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Pin device – is a non-reclosing pressure relief device meeting the requirements of

ASME Section VIII-1 which is actuated by inlet static or differential pressure and
designed to function by the activation of a load-bearing section of a pin that
supports a pressure-containing member.

Pressure equipment integrity management (PEIM) system – a PEIM system is a

quality management system that meets the requirements of AB-512 and for
which the owner holds a Certificate of Authorization Permit in accordance with
Section 11(3) of the Pressure Equipment Safety Regulation.

Pressure relief device – means a pressure relief valve, rupture disc device, or pin
device that meets the requirements of the ASME code.

Pressure relief valve – means a safety valve, relief valve, or safety relief valve that
meets the requirements of the ASME Code.

Professional engineer – as defined in the Pressure Equipment Safety Regulation, a

person who is properly registered as a professional engineer and authorized to
practice engineering in any province or territory of Canada or in any state of the
United States.

Public occupancy – means any facility where members of the general public are likely
to be present. This would include schools, offices, shopping malls, stores,
arenas, pools, restaurants, hotels, etc.

Rupture disc device – is a non-reclosing pressure relief device meeting the

requirements of ASME Section VIII-1 which is actuated by inlet static pressure
and designed to function by the bursting of a pressure-containing disc.

Safety-critical element – is an equipment or process parameter that can have an

impact on the maximum upset pressure determined by an overpressure risk
assessment, or another impact on overpressure protection of pressure
equipment; may include equipment or instrument maintenance requirements,
instrument redundancy, assumed fluid properties such as specific gravity or
viscosity, power sources, mechanical components such as pump impellers, etc.

Technical justification – justification for an action or proposal that is based on the

technical requirements of the intended application or on safety or environmental
concerns.

Thermal liquid heating system – means one or more thermal liquid heaters, and any
connected piping system or vessel, in which a thermal liquid that is not
pressurized by the application of a heat source is used as the heat transfer
medium. [PESR 1(1)(ff.1)]

Thermal relief – means protection against the phenomenon whereby an

incompressible fluid contained in a fixed-volume container is exposed to an
increase in temperature, and the resulting thermal expansion of the fluid causes
a disproportionately large increase in system pressure.

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4.0 REFERENCE PUBLICATIONS

The following documents are referred to in this document, and are listed here for
reference only. These documents may be amended from time to time; please refer to
the latest applicable edition of the referred documents, except in cases where a specific
edition is explicitly referred to in later sections of this document.

AB-512: Owner-User Pressure Equipment Integrity Management Requirements, Alberta

Boilers Safety Association

AB-513: Pressure Equipment Repair and Alteration Requirements, Alberta Boilers

Safety Association

API Standard 521: Pressure-relieving and Depressuring Systems, American Petroleum

Institute

API RP 585: Pressure Equipment Integrity Incident Investigation, American Petroleum

Institute

ASME B31.1: Power Piping, The American Society of Mechanical Engineers

ASME B31.3: Process Piping, The American Society of Mechanical Engineers

ASME Boiler and Pressure Vessel Code / Section I: Rules of Construction for Power
Boilers, The American Society of Mechanical Engineers

ASME Boiler and Pressure Vessel Code / Section IV: Rules of Construction of Heating
Boilers, The American Society of Mechanical Engineers

ASME Boiler and Pressure Vessel Code / Section VIII, Division 1: Rules for
Construction for Pressure Vessels, The American Society of Mechanical Engineers

ASME Boiler and Pressure Vessel Code / Section XIII: Rules for Overpressure
Protection, The American Society of Mechanical Engineers

CSA B51:19: Boiler, pressure vessel, and pressure piping code, Canadian Standards
Association, operating as CSA Group

CSA Z662:19: Oil and gas pipeline systems, Canadian Standards Association,
operating as CSA Group

Directive 077: Pipelines – Requirements and Reference Tools, Alberta Energy

Regulator

Information Bulletin IB10-006 Rev. 3: Interpretation: Steam Pipelines, Alberta Boilers

Safety Association

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Information Bulletin IB18-004: Interpretation: Pressure Equipment Safety Regulation

Section 35: Reporting Unsafe Conditions, Accidents and Fires, Alberta Boilers Safety
Association

Safety Codes Act: Revised Statutes of Alberta 2000, Chapter S-1, Province of Alberta

Safety Codes Act / Pressure Equipment Exemption Order (AR 56/2006), Province of
Alberta

Safety Codes Act / Pressure Equipment Safety Regulation (AR 49/2006), Province of
Alberta

WRC Bulletin 498: Guidance on the Application of Code Case 2211— Overpressure
Protection by Systems Design, Welding Research Council

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5.0 OVERPRESSURE RISK ASSESSMENTS

Prior to placing pressure equipment into service which is not protected from all
overpressure scenarios only by means of pressure relief valves, an Owner shall
undertake an overpressure risk assessment, in which one or more persons who are
familiar with the equipment and with the associated process and experienced in process
hazard analysis techniques, shall identify all credible overpressure scenarios, and shall
determine that the equipment will be adequately protected from each.

5.1 Overpressure Scenarios

5.1.1 Scenarios to Be Considered

An overpressure scenario shall be considered to be credible and shall be

evaluated if that scenario could foreseeably lead to an overpressure
condition of the equipment, and it has not been demonstrated to be ‘non-
credible’ in accordance with one of the methods listed in section 3.1.2 of
WRC 498.

Although selection and analysis of overpressure scenarios is dependent

on the expertise of the persons conducting the overpressure risk
assessment, API 521 provides guidance on potential causes of
overpressure. Some potential sources of overpressure that may need to
be considered include startup, shutdown, operating, and upset conditions;
scenarios involving fire or operator error; and equipment or
instrumentation failure such as valve failure, fail-open of a parallel pump,
plugged filters, saturated adsorber trays, etc.

5.1.1.1 Special Scenario Requirement for Heat Exchangers

A shell and tube heat exchanger which relies on overpressure

protection by system design shall give consideration to a scenario
involving tube rupture and the resulting leakage of pressurized fluid
from a higher pressure chamber to a lower pressure chamber. In
considering this scenario, the full maximum allowable working
pressure (MAWP) of the higher-pressure side shall be used as the
maximum upset pressure for the lower-pressure side. The use of
‘corrected hydrotest pressure’ discussed by paragraph 4.4.14.2.1 of
API 521 (previously known as the '10/13 Rule' or the '2/3 Rule') is
not acceptable for use when determining the maximum upset
pressure or required relief device set pressure for a heat
exchanger.

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5.1.1.2 Mitigation by Active Operator Intervention

Active operator intervention is generally not permitted to be used to

mitigate any overpressure scenario, but may be considered on a
case-by-case basis.

When active operator intervention is contemplated to mitigate any

overpressure scenario, a design survey submission may be made
for case-by-case consideration. The overpressure risk assessment
shall include a summary statement made by the Owner that
certifies that all of the requirements of API 521 clause 4.2.5 have
been met, and which meets the following additional requirements.

The summary statement shall provide brief descriptions of the

following:

 The scenario which is to be mitigated by operator intervention,

and its expected frequency of occurrence
 The alarm or abnormal event that will alert the operator to
intervene
 The intervention actions required to be taken by the operator,
and an indication of the amount of time the operator will have to
take the actions
 The consequences of failure to mitigate the scenario by
operator intervention

The summary statement shall indicate the Owner’s commitment to

establish requirements in their integrity management system to
train operators to recognize and act upon the scenario to be
mitigated, and shall include a brief description of the training
required for an operator to recognize and act upon the alarm or
abnormal event, and an indication of the frequency with which that
training will be repeated.

Any such summary statements are required to be submitted as a

part of the overpressure risk assessment summary described in
section 5.2.2 below.

In addition to the summary statement, an assessment of the

probability of operator intervention failure shall include estimates of
the quantitative probabilities of:

 The alarm successfully actuating, or of the abnormal event

presenting in the expected (recognizable) fashion

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 The alarm or abnormal event being recognized by the operator5

 The operator successfully undertaking the required mitigating
actions within the required amount of time
 The mitigating actions undertaken by the operator successfully
mitigating the overpressure scenario

The resulting probability of failure of operator intervention shall be

calculated based on at least the above-listed factors, and the co-
occurrence of the initiating scenario and of operator intervention
failure shall be evaluated as described below for co-occurrence of
scenarios.

The above requirements for operator intervention do not apply for

the temporary operation of an intervening valve as provided for by
ASME Section XIII, Mandatory Appendix B, paragraph B-7, if the
requirements of this document are met.

5.1.1.3 Maximum Upset Pressure of a Connected CSA Z662

Line

If pressure equipment relies on the overpressure protection of a

CSA Z662 pipeline which is protected from overpressure in
accordance with CSA Z662 clause 4.18, then the maximum upset
pressure used for the pressure equipment shall include the 10%
overpressure that is permitted by CSA Z662 clause 4.18.1.2.

5.1.2 Consideration for Co-Occurrence of Scenarios

Co-occurrence of any set of overpressure scenarios shall be considered

as a separate scenario:

 if their random co-occurrence meets the definition of a credible

scenario, given the anticipated frequencies and durations of the
independent random events; or,
 if their co-occurrence has a potential common cause (e.g., power
failure) which itself meets the definition of a credible scenario.

5.1.3 Outcome of Scenario Evaluation

For each pressure equipment component, the overpressure risk

assessment shall consider the effects of each credible overpressure
scenario, and shall conclude either:

5
An estimate of the probability of an operator recognizing a scenario shall consider the frequency at
which the operator’s attention is drawn to the potential for a scenario to occur through training or other
means, and the operator’s expected perception of the likelihood of the scenario occurring. It is cautioned
that although unlikely scenarios seem to present a lesser danger due to their decreased frequency, they
are less likely to be recognized when they do occur.

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 that the equipment will be protected by a pressure relief valve, rupture

disc device, or pin device, and establish a required set pressure and
minimum capacity rating for that device; or,
 that there are other specific means by which the equipment will be
protected, and specify the maximum upset pressure that could
foreseeably be developed in the equipment under that scenario.

5.2 Documentation of the Overpressure Risk Assessment

If the overpressure risk assessment indicates that any equipment will be

protected by any means other than by a pressure relief valve, then the
overpressure risk assessment shall be documented to the extent required to
demonstrate that all requirements of this document were met and to demonstrate
that its contributors were adequately qualified and duly diligent in undertaking the
assessment.

The risk assessment documentation shall be kept by the Owner in a manner that
will allow it to be accessible for the life of the equipment that it pertains to, and
shall be made available to a safety codes officer upon request.

5.2.1 Supplementary Documentation Requirement for Vessels

When a pressure vessel is to be protected from overpressure by any

means other than by a pressure relief valve, rupture disc, or pin device,
then the overpressure risk assessment documentation shall include the
documentation described by ASME Section XIII subparagraph 13.2(b) or
13.3(f), as applicable.

It is acknowledged that manufacturers of ASME Section VIII-1 pressure

vessels sometimes do not mark the Manufacturer's Data Report (MDR) as
described by paragraph 13.2 of ASME Section XIII due to lack of
information about overpressure protection; it is thus acceptable for a
pressure vessel's data report not to be marked as described by this
subparagraph.

5.2.2 Overpressure Risk Assessment Summary

When an overpressure risk assessment summary is submitted as a part of

a pressure piping design submission, it shall be prepared at the time the
risk assessment is completed, and shall include:

 A list of individual(s) who participated in the assessment, including for

each individual, their job title, any credentials they have (P.Eng., etc.),
and the name of their employer.6
6
Additional information about the individuals who participated in the assessment may be required to be
kept on file by the Owner in order to meet the general documentation requirements of section 5.2.

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 A brief description of the methodology used for the analysis

 For each pressure equipment component, identification of the
overpressure scenario that was determined to govern, and either the
required relieving pressure and capacity rating if the component is to
be relieved from overpressure by means of a pressure relief valve,
rupture disc, or pin device; or the component's maximum upset
pressure if it is to be protected by other means
 A list of all overpressure scenarios considered and an indication of any
scenarios that were dismissed as non-credible
 Justification for the exclusion of any scenarios that were considered or
which may typically be considered for similar applications, but were
determined to not be credible
 In cases where separate methods of overpressure protection are used
for various overpressure scenarios, an indication of which method is
relied upon for each scenario
 A list of any overpressure scenarios which rely on operator intervention
as described by 5.1.1.2 above, and any associated summary
statements required by that section
 An indication of any safety-critical elements or other factors that were
considered to mitigate any given overpressure scenario, either by
reducing its maximum upset pressure or by making it not reasonably
foreseeable or otherwise not credible
 A summary of any other important results and conclusions obtained
from the assessment

The summary shall be prepared as a controlled document with an

assigned document number and revision level, and shall be authenticated
by a professional engineer and signed by an authorized representative of
the Owner who participated in the assessment.

5.3 Revalidation of an Overpressure Risk Assessment

When an overpressure risk assessment is required to be revalidated, personnel

who are qualified to undertake such an assessment shall review and accept
responsibility for it with consideration of any changes made. Their review and
acceptance shall be documented in a manner acceptable to the Owner.

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6.0 METHODS OF OVERPRESSURE PROTECTION

Pressure equipment shall be protected from all credible overpressure scenarios
identified by the overpressure risk assessment prior to being placed into service. For
each scenario, overpressure protection shall be provided by at least one of the methods
described in sections 6.1, 6.2, and 6.3 of this document.

6.0.1 Limitation to Protection by Pressure Relief Valves

Equipment meeting the following criteria shall be protected from all

credible overpressure scenarios by means of pressure relief valves in
accordance with section 6.1, and intervening valves are not permitted:

 Equipment constructed to ASME Section I or Section IV

 ASME B31.1 boiler external piping (BEP)
 ASME Section VIII-1 equipment subject to subparagraphs UW-2(c)7 or
UW-2(d)8
 Fired heater pressure coils
 Thermal liquid heating systems
 Pressure equipment in public occupancy locations

6.0.2 Limitation for Protection from Certain Chemical Reactions

Systems which are not self-limiting with respect to pressure resulting from
chemical reactions shall be protected from all credible overpressure
scenarios by means of pressure relief valves or rupture disc or pin devices
in accordance with section 6.1.

6.0.3 Special Consideration for Adequately Vented Discharge Piping

Systems9

A discharge piping system, including any intermediate pressure vessels10,

which meets the description for ‘adequately vented equipment’ listed as
Case 3 in section 6.2.2 of this document and which meets the
requirements of CSA B51 clause 12.2.2.7 by virtue of meeting its
requirements for maintaining cross-sectional areas, is protected from
overpressure in a manner acceptable to the Administrator in accordance

7
UW-2(c) applies to “unfired steam boilers with design pressures exceeding 50 psi (343 kPa)”
8
UW-2(d) applies to “pressure vessels or parts subject to direct firing”
9
See subsection 2(2)(d) of the Pressure Equipment Exemption Order for an exemption for vented
pressure equipment having a maximum allowable working pressure not exceeding 103 kPa, and meeting
the requirements therein.
10
Intermediate pressure vessels (e.g. flare knock-out drums) can be included in an adequately vented
discharge piping system if the combined system meets the description of ‘adequately vented equipment’
with inclusion of the vessel. The cross-sectional areas to be considered for the vessel are the areas of its
inlets and outlets, rather than the cross-sectional area of the vessel itself.

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with subsection 38(1)(b) of the Pressure Equipment Safety Regulation

when the following requirements are met:11

 An overpressure risk assessment meeting the requirements of 5.0

Overpressure Risk Assessments shall be conducted with respect to
the equipment.
 The Owner shall establish a management of change (MOC) program
which will require revision or revalidation of the overpressure risk
assessment if changes are made which may affect the equipment in
question.
 The equipment shall be represented in a pressure piping design
submission which indicates that it meets the requirements of CSA B51
clause 12.2.2.7, that the cross-sectional area of the discharge piping is
maintained to the point of atmospheric discharge, and that the
requirements for this special consideration have been met.

6.1 Protection by Pressure Relief Valves, Rupture Disc, and Pin Devices

When pressure relief valves meeting the requirements of the ASME code are
relied upon for protection of pressure equipment from one or more of the credible
scenarios identified by the overpressure risk assessment, they are acceptable for
use in accordance with subsection 38(1)(a) of the Pressure Equipment Safety
Regulation, and the requirements of section 6.1 of this document shall be met.

When rupture disc or pin devices meeting the requirements of the ASME code
are relied upon for protection from one or more of the credible scenarios
identified by the overpressure risk assessment, they are acceptable for use in
accordance with subsection 38(1)(b) of the Pressure Equipment Safety
Regulation when the requirements of section 6.1 of this document are met.

Overpressure protection shall be provided for each remaining scenario, in

accordance with section 6.2 or 6.3 of this document.

6.1.1 Integrity Management System Requirements

Owners of pressure equipment which is protected from overpressure by

means of pressure relief valves, rupture disc, or pin devices shall establish
an integrity management system as required by subsection 37(b) of the
Pressure Equipment Safety Regulation.

If intervening valves are used, then the integrity management system shall
describe the administrative controls which govern their operation.

11
Adequately vented equipment which does not meet the cross-sectional area condition given in CSA
B51 clause 12.2.2.7 can be considered for acceptance in accordance with 6.2 Overpressure Protection
by System Design (OPPSD): Listed Cases, Case 3, in which case it is required to meet the requirements
of that clause for an engineering analysis.

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6.1.2 Overpressure Protection System Design Requirements

6.1.2.1 Required Relief Device Set Pressure and Capacity

Rating

Pressure relief valves and rupture disc and pin devices shall be
selected with a set pressure and capacity rating as prescribed by
any required overpressure risk assessment and with consideration
of the following regulatory requirements:

As required by subsection 38(2) of the Pressure Equipment Safety

Regulation, a pressure relief device must be set to open before the
pressure in the equipment exceeds its maximum allowable working
pressure. Consideration shall not be given to the overpressure
allowances permitted by some codes of construction in determining
the set pressure of the relief device, such as those given in ASME
Section VIII-1 subparagraph UG-154(e)(2), CSA Z662 clause
4.18.1.2, or ASME B31.3, paragraph 302.2.4.12

As required by subsection 38(3) of the Pressure Equipment Safety

Regulation, a pressure relief device must be sized with an
adequate capacity and vented such that the maximum pressure in
the protected equipment will not exceed any prescribed limit of
overpressure given in the applicable code of construction while the
device is operating to relieve pressure, such as the limits given in
subparagraph UG-153(a) of ASME Section VIII-1 and
subparagraph 322.6.3(c) of ASME B31.3.

If multiple pressure relief devices are used in series, such as in the

case where a rupture disc device is used in series with a pressure
relief valve to protect the relief valve from exposure to the service
fluid, then the above requirements shall be applied with
consideration of the combination of these relief devices as a single
relief device.

Consideration shall be given to the effects of back pressure on the

effective set pressure and capacity rating of a pressure relief valve,
rupture disc, or pin device.

6.1.2.2 Requirements for Intervening Valves

The following requirements shall be met with respect to the use of

intervening valves:

12
Since the Pressure Equipment Safety Regulation requires that a relief device be set to open before
pressure equipment reaches its maximum allowable working pressure, the provision of ASME B31.3 for
pressure and temperature variations does not apply, except during operation of the device.

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 Intervening valves shall have mechanical locking elements

meeting the definition of this term given in section 3.0,
‘Definitions’.
 Intervening valves shall be subject to administrative controls
meeting the definition of this term given in section 3.0,
‘Definitions’, and which are described in the Owner’s integrity
management system. Administrative controls shall include, as a
minimum, documentation of operation and maintenance
procedures, and training requirements for operation and
maintenance personnel.
 If registration of the equipment as a pressure piping system is
required, any intervening valves shall be represented on the
submitted P&IDs with a clear indication that they are ‘car-sealed
open’ (‘CSO’) or otherwise controlled to prevent their
inadvertent operation.

Nonmandatory Appendix B of ASME Section XIII provides

extensive additional information and non-mandatory guidance for
the use of intervening valves.

6.1.2.3 Pressure Relief Valve Location for Fired Equipment

Any equipment subject to direct or indirect firing which is required

by section 6.0 to be protected only by means of a pressure relief
valve shall have that relief valve placed directly at or as close as is
practicable to the equipment outlet.

6.1.2.4 Technical Justification Required for Rupture Disc and

Pin Devices

Justification for the use of a rupture disc or pin device shall relate
its use to safety, process, or environmental concerns.

6.1.3 Design Submission Requirements

Any equipment protected from overpressure by means of a pressure relief

valve or by means of a rupture disc or pin device shall be represented in a
pressure piping design submission, unless such a submission is exempt
from registration in accordance with subsection 14(6) of the Pressure
Equipment Safety Regulation.13

13
Subsection 14(6) of the Pressure Equipment Safety Regulation provides an exemption from registration
for a pressure piping system having an aggregate internal volume not exceeding 500 litres.

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6.1.3.1 List of Pressure Relief Devices

As required by subsection 16(1)(c) of the Pressure Equipment

Safety Regulation, any required submission for design registration
of a piping system shall include a list of pressure relief devices.

As provided for by subsections 16(1)(c) and 16(1)(i) of the

regulation, the list shall include the following minimum information
pertaining to each device:

 Tag number or other device identification

 Type of device (pressure relief valve, rupture disc device, or pin
device)
 Device set pressure
 Document number for the included P&ID or other layout drawing
where the device is shown
 A list of pressure piping lines and other pressure equipment
protected by the device14

The list shall be provided on a controlled document with assigned

document number and revision level and shall be stamped by a
professional engineer as required by subsection 16(2) of the
regulation.

6.1.3.2 Additional Documentation for Rupture Disc and Pin

Devices

As provided for by subsection 16(1)(i), any required submission for

design registration of a piping system which makes use of rupture
disc or pin devices for overpressure protection shall include the
following additional documentation pertaining to such devices:

 Identification of the technical justification for use of the devices

in lieu of relief valves
 A letter from the Owner specifically accepting the use of the
devices
 A copy of the overpressure risk assessment summary described
in section 5.2.2

6.2 Overpressure Protection by System Design (OPPSD): Listed Cases

When overpressure protection by system design (OPPSD) falling within the

scope of one of the specifically permitted cases listed in section 6.2.2 below is

14
It is acceptable to identify a pressure relief valve which protects each pressure piping line on the
submitted line designation table in lieu of listing the lines protected by each device on the submitted list of
pressure relief devices.

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 Overpressure Protection Requirements

relied upon for protection of pressure equipment from one or more of the credible
scenarios identified by the overpressure risk assessment, the requirements of
section 6.2 of this document shall be met.

Overpressure protection shall be provided for each remaining scenario, in

accordance with section 6.1 or 6.3 of this document.

6.2.1 Integrity Management System Requirements

Owners of pressure equipment which relies on overpressure protection by

system design (OPPSD) for protection from any credible overpressure
scenario shall establish an integrity management system as required by
subsection 37(b) of the Pressure Equipment Safety Regulation.15

The integrity management system shall contain all of the elements

described in this section.

6.2.1.1 System Documentation and Operation / Maintenance

Procedures

The integrity management system shall:

 Establish a system for documenting the extent of equipment

protected by OPPSD
 Establish a system for documenting, monitoring, and
maintaining any additional equipment, instrumentation, and
other safety-critical elements that are relied upon for protection
of the equipment by OPPSD
 Establish any inspection and maintenance activities that are
required to ensure the continued integrity of the overpressure
protection, including required intervals
 Specify responsibilities for operations, maintenance, inspection,
and engineering staff related to OPPSD
 Ensure that the Owner’s operating and maintenance procedures
and associated documentation are adequate to ensure that:
 Operators and maintenance personnel are aware of systems
that rely on OPPSD16
 Maintenance procedures are adequately detailed to ensure
that all portions of the OPPSD systems will continue to
function as required
 Changes to safe operating limits and changes during
maintenance will not be permitted to OPPSD systems

15
Establishment of a PEIMS in accordance with AB-512 is mandatory in the case that the equipment
protected by OPPSD includes any pressure vessel; see section 6.2.1.4 below.
16
It is particularly important to stress to operations and maintenance personnel that the equipment is not
protected from overpressure by a relief valve or similar pressure relief device.

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 Overpressure Protection Requirements

without following the requirements of the established

management of change program
 Records of maintenance activities are created and
maintained
 A process for safe shutdown of plant equipment and/or
reduction of pressure is established, in the event that
equipment operating pressure exceeds the safe operating
limits established in accordance with subsection 37(e) of the
Pressure Equipment Safety Regulation

6.2.1.2 Establishment of a Monitoring Program

A monitoring program shall be established which is capable of

providing assurance that the maximum pressure the equipment has
been exposed to in operation has remained below its maximum
allowable working pressure.

At a minimum, the monitoring program must:

 Provide for continuous recording of the pressure conditions

adequate to determine whether the operating pressure of the
monitored equipment goes above the maximum upset pressure
 Provide for maintenance and retrievability of recorded
conditions
 Establish requirements for periodic calibration, maintenance,
and testing of monitoring devices and instrumentation, and for
keeping records of these activities
 Be designed to duly notify appropriate personnel in the event
that the operating pressure in any of the monitored equipment
exceeds its maximum permitted pressure
 Be acceptable to ABSA for the purpose for which it is intended
 Establish a system for investigating and reporting unsafe
overpressure conditions in accordance with Annex C,
‘Overpressure Reporting Requirements’

6.2.1.3 Establishment of a Management of Change (MOC)

Program

A management of change program shall be established which is

capable of ensuring that any change that is proposed to be made to
the equipment or to any safety-critical element affecting the
equipment, will be reviewed by qualified individuals prior to its
implementation.

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 Overpressure Protection Requirements

At a minimum, the management of change program must:

 Require one or more individuals deemed competent by the

Owner to undertake and document a thorough analysis of the
proposed change, evaluating for safety and for its effect on the
overpressure protection of any pressure equipment that may be
affected by it
 Require revision or revalidation of the overpressure risk
assessment in accordance with section 5.0, ‘Overpressure Risk
Assessments’
 Ensure that the requirements of Annex B, ‘Alterations and
Modifications’ and any other applicable requirements of this
document are met with respect to the change
 Require that records of the management of change analysis be
signed by the qualified individuals who took part in it, and kept
by the Owner
 Provide for follow-up to ensure that all required actions that are
identified by the management of change analysis are
undertaken
 Establish a process for change of ownership that meets the
requirements of Annex E, ‘Change of Equipment Ownership’

6.2.1.4 Supplementary Requirements for Vessels

If the equipment that relies on overpressure protection by system

design includes any pressure vessel, then the integrity
management system must be established as an Owner-User
pressure equipment integrity management system (PEIMS) which
meets the requirements of AB-512.

In addition to revalidation of the overpressure risk assessment

when changes are made in accordance with the management of
change program, the integrity management system shall establish a
regular interval at which the overpressure risk assessment shall be
reviewed and revalidated, even when no changes have been
proposed.

6.2.2 System Design Requirements

6.2.2.1 Permitted Cases

Use of section 6.2 is limited to overpressure protection by system

design (OPPSD) in which system operating pressure is limited in
one of the following ways:

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1. Centrifugal Pumps or Compressors:17 the limiting source of

pressure in the equipment is a non-positive-displacement pump
or compressor, which for the installed configuration, is not
physically capable of producing a pressure higher than the
maximum upset pressure identified in the overpressure risk
assessment
2. SAGD Pressure Source: the limiting source of pressure in the
equipment is pressure from steam-assisted gravity drainage
(SAGD) piping from a well head, which in turn has its pressure
limited by the use of a non-positive-displacement pump which
for the installed configuration, is not physically capable of
producing a pressure higher than the maximum upset pressure
identified in the overpressure risk assessment
3. Adequately Vented Equipment: pressure equipment, such as an
open flare line or discharge piping, which is vented to
atmosphere with no potential sources of blockage, such that no
combination of flow rate, fluid composition, and other factors
could foreseeably produce a pressure higher than its maximum
allowable working pressure
4. Connected CSA Z662 Line: pressure equipment is protected
with a connected CSA Z662 line that itself is protected in
accordance with clause 4.18 of CSA Z662, except that the
maximum upset pressure used for design of the equipment
must be 10% higher than the maximum operating pressure of
that line18

6.2.2.2 Required Maximum Allowable Working Pressure

Each pressure equipment component shall have a maximum

allowable working pressure (MAWP) at least equal to the maximum
upset pressure specified by the overpressure risk assessment for
that component.

The MAWP of a component may not be reduced below the

determined maximum upset pressure to take advantage of the
overpressure allowances permitted by ASME Section VIII-1
subparagraphs UG-153(a) or UG-154(e)(2), nor by CSA Z662
clause 4.18.1.2, nor for the occasional pressure / temperature
variations permitted by ASME B31.3, paragraph 302.2.4.

17
This permitted case applies exclusively to scenarios where system pressure is limited by the capability
of a non-positive-displacement pump or compressor; it is not acceptable to rely on an automated control
valve to similarly limit downstream system pressure.
18
This 10% buffer is required because CSA Z662 clause 4.18.1.2 permits such a line’s maximum
operating pressure to be exceeded by 10%, which does not meet the requirements of subsection 38(2) of
the Pressure Equipment Safety Regulation.

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 Overpressure Protection Requirements

6.2.2.3 Supplementary Requirements for Section VIII-1

Vessels

Pressure vessels built to ASME Section VIII-1 which rely on

overpressure protection by system design need to meet the
applicable requirements of ASME Section XIII, Part 13.

6.2.2.4 Engineering Assessment for Adequately Vented

Equipment

For pressure equipment which meets the description of ‘adequately

vented equipment’ other than discharge piping meeting the
requirements of section 6.0.3, an engineering assessment shall be
provided as a part of the overpressure risk assessment, and shall
demonstrate that no combination of flow rate, fluid composition, and
other factors could foreseeably produce a pressure higher than the
equipment’s maximum allowable working pressure for any credible
overpressure scenario.

6.2.3 Design Submission Requirements

Pressure equipment that is protected from one or more overpressure

scenarios in accordance with section 6.2 shall be represented in a
pressure piping design submission meeting the requirements of this
section. If the equipment which relies on section 6.2 for overpressure
protection includes any pressure vessel, then this pressure piping
submission is required even if the piping system has an aggregate internal
volume not greater than 500 liters, so that the method of overpressure
protection can be considered for specific acceptance by the Administrator
as required by subsection 38(1)(b) of the Pressure Equipment Safety
Regulation.19

The proposed method of overpressure protection is acceptable for use in

Alberta in accordance with subsection 38(1)(b) of the Pressure Equipment
Safety Regulation (PESR) when it is acknowledged on the acceptance
letter associated with that piping submission, or when such a piping
submission is not required by the above paragraph and all of the
requirements of section 6.2 of this document are met.

19
When the aggregate internal volume of piping is not greater than 500 liters, and only piping but no
pressure vessel relies on section 6.2 for overpressure protection, then the exemption from registration
provided in subsection 14(6) of the Pressure Equipment Safety Regulation applies and a submission
need not be made to Design Survey, but all other requirements of this document still apply.

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6.2.3.1 Required Submission Contents

In addition to the documentation normally required to be submitted

for registration of a piping system, the submission shall include the
following, as provided for by subsection 16(1)(i) of the PESR:

1. A statement from the Owner – a representative authority from

the Owner shall issue a signed statement which has the
following elements and features:
 A statement accepting the principles relied upon for OPPSD
 A statement acknowledging the Owner’s responsibility for
OPPSD, and accepting the risks associated with it
 A commitment to implement and maintain the required
monitoring program
 A commitment to implement the required integrity
management system
2. A copy of the overpressure risk assessment summary – a
copy of the overpressure risk assessment summary as
described in 5.2.2 Overpressure Risk Assessment Summary,
authenticated by a professional engineer and signed by the
Owner’s authorized representative
3. A description of the monitoring program – a description with
details adequate for the design surveyor to determine that the
monitoring program will meet the requirements of this document
and is suited to its intended purpose
4. A list of pressure piping system lines protected by OPPSD
– a detailed list of all pressure piping system lines which rely on
OPPSD for protection from any overpressure scenario; for each
line, this list shall include:
 Line identification number or other identifying characteristic
 Method of overpressure protection used, including an
indication of the permitted ‘case’ type used in the case of
overpressure protection by system design
 Maximum upset pressure for the line specified by the
overpressure risk assessment
 Design pressure for the line
 Indication that the line is in lethal service, if applicable
5. A list of pressure vessels protected by OPPSD – a detailed
list of all pressure vessels which rely on OPPSD for protection
from any overpressure scenario; for each vessel, this list shall
include:
 Vessel Canadian Registration Number (CRN)
 Vessel serial number or other identifying characteristic
 Maximum allowable working pressure (MAWP) for the vessel
or for each pressure chamber

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 Overpressure Protection Requirements

 Method of overpressure protection used, including an

indication of the permitted ‘case’ type used in the case of
overpressure protection by system design
 Maximum upset pressure for the vessel or for each pressure
chamber, as specified by the overpressure risk assessment
 Indication that the vessel is in lethal service, if applicable

6.2.3.2 Supplementary Requirements for Vessels

Design submissions for systems containing pressure vessels which

rely on OPPSD for protection from one or more overpressure
scenarios shall meet the following additional requirements:

 The statement from the Owner described in item 1 above shall

have an additional statement accepting the responsibilities
described in paragraph UG-151 and subparagraph UG-152(a)
of ASME Section VIII-1, and paragraph 13.2 of ASME Section
XIII.
 Process and instrumentation diagrams (P&IDs) shall be
submitted which show the vessels and all connected process
and safety systems.

6.3 Overpressure Protection by System Design (OPPSD): Unlisted Cases

When overpressure protection by system design falling outside the scope of one
of the specifically permitted cases listed in section 6.2.2 is relied upon for
protection of pressure equipment from one or more of the credible overpressure
scenarios identified by the overpressure risk assessment by either mitigating the
scenario, or by actively relieving excess pressure, the requirements of section
6.3 of this document shall be met.

Overpressure protection shall be provided for each remaining scenario, in

accordance with section 6.1 or 6.2 of this document.

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6.3.0.1 Consideration on a Case-by-Case Basis

Approaches to overpressure protection provided for by section 6.3

are considered on a case-by-case basis depending on their
technical merits and the level of safety achieved. If there is any
doubt as to whether a given approach may be acceptable, then it is
recommended that the designer or Owner contact ABSA Design
Survey in advance to determine whether it is acceptable for use in
Alberta, prior to relying on its acceptance.

It should be noted that the requirements presented herein are base

requirements, and additional requirements may apply depending on
the approach being proposed.

6.3.1 Integrity Management System Requirements

The Owner's integrity management system shall meet the requirements of

6.2.1 Integrity Management System Requirements, and shall incorporate
any additional elements that are needed in order to ensure that the
proposed method of overpressure protection will remain effective and
safe.

6.3.2 System Design Requirements

6.3.2.1 Technical Justification Required

Justification for the use of the alternative method of overpressure

protection shall be acceptable to the Owner, and shall relate its use
to safety, process, or environmental concerns.

6.3.2.2 Required Maximum Allowable Working

The requirements given in section 6.2.2.2 of this document shall

apply.

The means of overpressure protection shall mitigate the

overpressure scenario which relies upon it, either by preventing
excess pressure from building up, or by actively relieving excess
pressure before the equipment reaches its maximum allowable
working pressure.

6.3.2.3 Equivalent Safety to a Pressure Relief Valve

The means of overpressure protection shall be at least as safe as a
pressure relief valve that is properly selected and suitable for the
service.

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In comparison to such a relief valve, an overpressure protection

system which is required to actively function to provide pressure
relief shall:
 Be at least as reliable, in terms of its probability of functioning
on demand, and
 Be at least as effective at preventing overpressure when it
functions

6.3.2.4 Supplementary Requirements for Vessels

The requirements given in section 6.2.3.2 of this document shall
apply.

6.3.3 Design Submission Requirements

Pressure equipment that is protected from one or more overpressure
scenarios in accordance with section 6.3 shall be represented in a
pressure piping design submission meeting the requirements of this
section. This is required in order for the method of overpressure protection
to be considered for specific acceptance by the Administrator in
accordance with subsection 38(1)(b) of the Pressure Equipment Safety
Regulation, even if that piping system has an aggregate internal volume
not greater than 500 liters and would otherwise have been considered
exempt from registration requirements.

The proposed method of overpressure protection is acceptable for use in

Alberta in accordance with subsection 38(1)(b) of the Pressure Equipment
Safety Regulation when it is specifically acknowledged on the acceptance
letter associated with that piping submission.

6.3.3.1 Required Submission Contents

In addition to the documentation normally required to be submitted
for registration of a piping system and the additional items required
by section 6.2.3 (including ‘Supplementary Requirements for
Vessels’, if applicable), the design submission shall include the
following, as provided for by subsection 16(1)(i) of the PESR:

 A written commitment by the Owner to implement any elements

of the required integrity management system that are
specifically incorporated for the proposed method of
overpressure protection as required by section 6.3.1, and brief
descriptions of those elements
 A brief description of the required technical justification,
including a statement of acceptance by the Owner
 A detailed description of the proposed overpressure protection
approach, adequate to demonstrate the required equivalent
safety to a suitably selected pressure relief valve

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It should be noted that depending on the complexity of the

proposed approach of overpressure protection, the design surveyor
may need to request additional information to determine whether it
is suitable for registration, as provided for by subsection 16(1)(i) of
the Pressure Equipment Safety Regulation.

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ANNEX A: ALTERNATIVE APPROACHES TO THIS DOCUMENT

Although this document gives an indication of how overpressure protection can be
achieved in a way that is acceptable to the Administrator in accordance with
subsections 38(1)(a) and 38(1)(b) of the Pressure Equipment Safety Regulation, it is
intended to suit a majority of general applications, but cannot be expected to suit all
applications.

Submissions proposing overpressure protection by means which do not comply with this
document in its entirety are considered on a case-by-case basis.

A-1 Statement of Variations from AB-525 Required

In the case that the general principles of this document are followed but
individual variations are made with respect to one or more specific sections, a
pressure piping submission is to be made with the information required by the
applicable sections of this document, and is to be accompanied by a
comprehensive ‘statement of variations’ which meets the requirements of this
annex.

The statement of variations shall be clearly labeled "Statement of Variations from

AB-525" and shall list all individual variations from this document. For each
individual variation, it shall provide: 20

 The specific section of this document from which the variation is made
 A short, plain-English description of the rule from which the variation is
made
 A description of technical justification for the variation
 A proposal of how equivalent safety will be achieved

The statement of variations shall conclude with a clear statement that all other
requirements of the applicable sections of this document have been met.

The statement of variations shall be prepared as a controlled document with an

assigned document number and revision level, and shall be authenticated by a
professional engineer and signed by the Owner’s authorized representative.

The proposed methods of overpressure protection are deemed acceptable to the

Administrator in accordance with subsection 38(1)(b) of the Pressure Equipment
Safety Regulation despite the described variations only when the statement of
variations is accepted and specifically acknowledged on the acceptance letter
associated with that piping submission.

20
The required information may be provided as one or more tables, in point format, in paragraphs, or in
any other suitable format, as long as the required information is clearly associated with each individual
variation.

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A-2 Alternative Approaches

This document is intended to primarily provide guidance for common

overpressure protection cases that are acceptable to the Administrator, and to
provide a starting point for reasonable variations from those cases. It should be
noted that if the rules and guidance provided herein do not suit the Owner's
overpressure protection situation or if there are other special circumstances, it is
possible for alternative means of overpressure protection to be specifically
accepted in accordance with subsection 38(1)(b) of the Pressure Equipment
Safety Regulation on a case-by-case basis.

A-3 Variance Required for Variations from Regulated Requirements

It is not possible to vary from regulated requirements by registration of a piping

system design which describes the proposed variation. In such cases, an
application for a variance which makes an effective argument for equivalent
safety must be made to the Administrator in accordance with subsection 38(1) of
the Safety Codes Act.

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ANNEX B: ALTERATIONS AND MODIFICATIONS

This annex presents requirements for changes to existing equipment, and for additions
and modifications to existing equipment, in cases where any pressure vessel or
pressure piping system will rely on overpressure protection by means other than by a
pressure relief valve after that change is complete.

B-1 Increase in Maximum Upset Pressure

If upon any reassessment of the overpressure risk assessment, a maximum

upset pressure is determined for a pressure equipment component which is
above that component’s maximum allowable working pressure, then that
pressure equipment component shall be subjected to an alteration in accordance
with AB-513 as required to suit the new maximum upset pressure, or alternatively
the component may be replaced.21 In the case of piping, the line designation
table associated with the piping system registration shall be revised to reflect the
required increase of design pressure.

A new design registration application shall be made for modification of the

existing piping system in order to reflect the changes to the overpressure risk
assessment summary and the maximum allowable working pressures of the
applicable components.

B-2 Change of Overpressure Protection Approach

If any change is made to the approach relied upon for protection of any pressure
equipment component then all of the requirements of this document shall be met
with respect to the new approach.

If the change in overpressure protection approach is to an approach other than

protection by a pressure relief valve, then a new design registration application
shall be made for modification of the existing piping system in order to meet the
requirements of this document relating to design submissions for the new
overpressure protection approach.

B-3 Additions and Modifications to Pressure Equipment

When an addition or modification is made to any piping system or other pressure

equipment, all of the requirements of this document shall be met for both the
existing equipment and for the addition or modification.

If any existing pressure equipment is relied upon for overpressure protection of

the addition or modification, or may otherwise be affected by the addition or
modification, then its overpressure risk assessment shall be revised or reaffirmed
to reflect the system in the modified condition. A pressure piping design
21
In the case of a vessel for which initial construction is not complete, the registered design for the vessel
may in some cases be revised and the vessel then initially built to the revised design.

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submission shall be made to represent the addition or modification, and any

portion of the existing system that is relied upon for overpressure protection shall
be represented in the submission. In particular:

 P&IDs shall be provided to show any portions of the existing system

that are relied upon for overpressure protection of the addition or
modification
 Any pressure relief devices in the existing system that are relied upon
by the addition or modification shall be represented in the required list
of pressure relief devices

If the existing equipment relies upon overpressure protection by system design

and makes use of overpressure allowances given in the applicable codes of
construction, as permitted only by paragraph D-2, ‘Use of Overpressure
Allowances by Legacy Equipment’ in Annex D, then the required design
submission shall clearly indicate that the overpressure allowance was used with
respect to design of that legacy equipment, and the newly added or modified
portion of the equipment shall have a maximum allowable working pressure
which suits the full maximum upset pressure, without making use of the
overpressure allowance permitted for the legacy equipment.

B-4 Exemption from Registration for Small-Volume Additions

When a pressure piping system is being added to or modified, and the addition or
modification thereto has an aggregate internal volume not exceeding 500 liters,
then design registration of the addition or modification is exempt22 in accordance
with subsection 14(6) of the Pressure Equipment Safety Regulation (PESR), only
if any pressure vessel contained in the added or modified portion is adequately
protected from all credible overpressure scenarios by means of a pressure relief
valve, rupture disc, or pin device, or if the pressure vessel was already present
and the addition or modification does not change the means by which it is
protected.

If the added or modified portion contains any pressure vessel which relies on
overpressure protection by any other means, then the addition or modification
shall be represented in a pressure piping design submission as an addition to the
existing system in order for that means of overpressure protection to be
considered for specific acceptance by the Administrator as required by
subsection 38(1)(b) of the PESR, even if that addition or modification has an
aggregate internal volume not greater than 500 liters and would otherwise have
been considered exempt from registration requirements. The proposed method
of overpressure protection is acceptable to the Administrator if it is specifically
acknowledged on the acceptance letter associated with that piping submission.

22
This exemption is from design registration only; all other requirements of the Pressure Equipment
Safety Regulation and of this document shall be met.

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ANNEX C: OVERPRESSURE REPORTING REQUIREMENTS

C-1 Unsafe Overpressure Conditions

The following scenarios constitute “process operating conditions outside of

acceptable limits and which require immediate action to shut down the
equipment” as described by API RP 585, and therefore fall within the definition of
‘unsafe condition’ given in ABSA Information Bulletin IB18-004. Any such near-
miss incidents are to be reported to the Administrator as required by that
Information Bulletin and by subsection 35(1) of the Pressure Equipment Safety
Regulation:

 A pressure equipment component which relies on a pressure relief

valve, rupture disc, or pin device for overpressure protection is
subjected to a pressure above its maximum allowable working
pressure, and the relief device does not operate
 A pressure equipment component which relies on a pressure relief
valve, rupture disc, or pin device for overpressure protection is
subjected to a pressure during operation of the relief device which is
above the limit specified by the component's code of construction for
overpressure while the device is operating
 A pressure equipment component which relies on a method of
overpressure protection other than a pressure relief valve, rupture disc,
or pin device is subjected to a pressure greater than its maximum
allowable working pressure23

C-2 Investigation and Follow-Up by Owner

The Owner shall conduct an investigation into the root cause of any unsafe
condition described above, and shall revise the overpressure risk assessment
and shall take any corrective actions necessary to prevent recurrence of the
unsafe condition.

23
Any limit permitted by a component's code of construction for overpressure while a relief device is
operating may not be considered for equipment that is not protected by a pressure relief valve, rupture
disc, or pin device, except as described under 'Use of Overpressure Allowances by Legacy Equipment' in
Annex D, ‘Documentation of Existing Systems’.

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ANNEX D: DOCUMENTATION OF EXISTING SYSTEMS

It is recognized that there is pressure equipment in Alberta that relies on overpressure
protection by means other than by a relief valve which predates the 2013 publication of
the original edition of this document. The requirement of the Pressure Equipment Safety
Regulation that equipment be protected by a pressure relief valve meeting the ASME
code or by other means acceptable to the Administrator predated that original
publication.

Any pressure equipment which predates the 2013 publication of this document and
which is protected by means other than by a pressure relief valve shall meet the
requirements of this annex, if that means of overpressure protection has not previously
been specifically accepted by the Administrator.24

It should be noted that the Owner is fully responsible for the operation of their own
equipment and for compliance with the Safety Codes Act and associated regulations,
and it is the Owner's responsibility to ensure that these requirements are met with
respect to their existing equipment.

D-1 Identification of Overpressure Protection

The Owner shall undertake an overpressure risk assessment meeting the

requirements of section 5.0 of this document, documenting the means by which
each pressure equipment component is protected from each credible
overpressure scenario.

D-2 Use of Overpressure Allowances by Legacy Equipment

If a system which predates the 2013 publication of the original edition of this
document makes use of overpressure protection by system design and the
maximum upset pressure for a pressure equipment component relies on the
overpressure allowance of ASME B31.3 paragraph 302.2.4 or ASME Sec VIII-1
subparagraph UG-153(a), then this alternative selection of maximum upset
pressure is permitted only for this legacy equipment, and the use of this
overpressure allowance shall be clearly documented in the overpressure risk
assessment.25

D-3 Update of Integrity Management System

The Owner's integrity management system shall be updated to meet all

applicable requirements of this document with respect to the means by which
overpressure protection is achieved.

24
Such systems which comply with section 6.0, ‘Documentation of Existing OPPSD Systems’ of the
original edition of this document are understood to have been accepted by the Administrator, and are not
intended to be subject to this annex.
25
The equipment may alternatively be rerated as described in ‘Increase in Maximum Upset Pressure’ in
Annex B, ‘Alterations and Modifications’.

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 Overpressure Protection Requirements

Upon regular scheduled audit of the Owner's integrity management system, at

the auditor's discretion, the ABSA auditor / safety codes officer may accept the
required updates pertaining to the existing means of overpressure protection
without requiring a formal review and acceptance, or may require the Owner to
make an application to ABSA for design registration of a piping system which
contains the documentation required by this document for the applicable means
of overpressure protection.

D-4 Acceptance of Overpressure Protection

Overpressure protection of that equipment is acceptable to the Administrator in

accordance with subsection 38(1)(b) of the Pressure Equipment Safety
Regulation when the ABSA auditor / safety codes officer specifically accepts the
Owner's updated integrity management system, or when the Owner makes the
required submission to ABSA for design registration of a piping system and that
piping submission is accepted for registration and the alternate means of
overpressure protection is specifically acknowledged on the associated
acceptance letter.

D-5 Timeline for Implementation

It is expected that the requirements of this annex would have been implemented
in the years following the initial publication of this document. In the event that
they have not yet been met, the required overpressure risk assessment and
updates to the Owner's integrity management system shall be completed on a
schedule established by the Owner and acceptable to ABSA.

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ANNEX E: CHANGE OF EQUIPMENT OWNERSHIP

When pressure equipment that is protected from overpressure by means other than by
a pressure relief valve is subjected to a change of ownership, the following
requirements shall be met in order for that overpressure protection to continue to be
acceptable to the Administrator in accordance with subsection 38(1)(b):

 All of the requirements of subsections 36(1), 36(2), 36(3), and 36(4) of the
Pressure Equipment Safety Regulation shall apply with respect to that
equipment, regardless of whether the equipment is limited to the types of
equipment listed therein as subject to those requirements.
 The new Owner shall implement an integrity management system that meets
the requirements of this document for the types of overpressure protection
that are relied upon.

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REVISION LOG
Edition Revision Date Description
1 0 2013-03-18 Initial Publication
2 0 2021-12-13 Major restructure / rewrite

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