Annex 1

Statistics on incidents recorded by the LPGA

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 Annex 2

Extracts from LPGA’s Codes of Practice

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 Annex 3

Mott Macdonald’s Opinion on Regulation in the LPG Industry

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Temporarily excised.

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 Annex 4

Technical compatibility

Product Compatibility

1. In the UK, all domestic bulk LPG is commercial propane. The LPGA Code of

Practice No 1 Part 1 requires that it complies with BS4250, the key

characteristics of which are as follows:

TABLE 1

Property Commercial propane

Gauge vapour pressure, at 40°C (measured or calculated) (kPa), max. 1,550

Total sulphur content (mg/kg), max. 200
Mercaptan sulphur content (mg/kg), max. 50
3
Hydrogen sulphide content (mg/m ), max. 0.75
3
Ammonia content (mg/m in the vapour phase), max. 2.3
Copper corrosion, 1h at 40°C Class 1
Tendency to freeze in valves Pass
Dienes content, mole percent max. 0.5
Ethylene content, mole percent, max. 1.0
Alkynes content, mole percent, max. 0.5
C4 and higher hydrocarbons content, mole percent, max. 10.0
C5 and higher hydrocarbons content, mole percent, max. 2.0
R number 10 max
O number 33 max

Source: BSI

2. We have been told by all main parties that all bulk LPG compliant with

BS4250 is functionally identical and that propane from various suppliers can

safely be mixed.

3. However, we were informed by one LPG supplier that although there is likely

to be a high level of compliance with BS4250, due to the fact that the major oil

companies are the suppliers, there have been occasions when they have

been supplied LPG for sale which did not comply with BS4250.

4. Potential impurities which could be found in LPG which doesn’t conform to BS

4250: corrosive impurities such as hydrogen sulphide, ammonia and caustic;

carcinogenic impurities such as 1,-butadiene; free water which can lead to

loss of supply.

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5. Mott Macdonald’s Opinion on product compatibility:

We understand that LPG producers carry out their own product quality checks

but clearly there will be instances when off-spec product leaves the site. From

our discussions with a range of LPG suppliers, covering all the majors and

several independents, no other incidents of off-spec LPG were reported and

the quality of LPG they buy was not raised as an issue. We were advised that

any quality issues would be resolved with the producers directly and would

thus not affect the customer. We understand one LPG supplier claims to be

the only one to test LPG in the field which enables them to detect any off-

spec product before it is delivered to customers. They confirm having

detected occasional non-conformance.

Heavy ends in the LPG stay at the bottom of old tanks as the lighter propane

and butane vaporise first. Over time, the gas odorising agent concentrates

and may give rise to false alarms of reported leaks. Not a gas quality issue.

BS4250 limits the impurity levels for on-spec LPG, with ammonia and water

being especially important since they can have a corrosive effect on the tank.

We were advised by several LPG suppliers, corroborated independently by a

tank contractor, that no significant internal corrosion has been discovered in

any above-ground or buried tank at the 10-year service. We believe,

therefore, that the integrity of customer tanks operated by the suppliers we

saw is similar.

We were advised by one supplier that they had acquired some tanks which

had higher quantities of residue than their own stock. It is not known if the

acquired tanks had significantly higher levels of corrosion than the supplier’s

previous stock. Our understanding is that the level of residue deposited is not

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 simply a function of gas composition but also on the way the tank is used eg

frequency and rate of tank contents turnover.

We do not believe there is significant variability in the quality or compatibility

of LPG supplied to the domestic market.

Different tank valve arrangements—Mott’s research and opinion

6. LPGA codes set out the valve arrangement on LPG tanks. There are 7

possible valves on an LPG tank and their functions are described as follows:

• Pressure Relief Valve (PRV) must be positioned in the vapour space of

the tank (the top of the tank) and is required to protect the tank from being

over pressurised by discharging gas to atmosphere at a predetermined

tank pressure. Larger tanks have a number of these but the vast majority

of domestic bulk tanks require only one. It is normal industry practice to fit

the PRV with a relief valve adaptor to enable the PRV to be changed on a

tank without having to decommission the tank.

• Filler Valve to fill the tank with LPG.

• Ullage gauge, also known as maximum filling level gauge or ullage valve.

This is a small bleed valve that has a dip tube attached to it within the

tank. This tube extends to the 86.6 per cent full level of the tank. Most

LPG suppliers fill to the range 85 to 87 per cent. When the tank liquid level

reaches this tube liquid LPG is discharged from the bleed valve indicating

tank full. Usually combined with vapour offtake valve.

• Vapour off-take valve. This is the supply of LPG in a gaseous phase to

the service pipework supplying the customer.

• Contents gauge. This is a small dial on the tank indicating the contents of

the tank in percentage of total volume.

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 • Liquid offtake. This is fitted for the removal of liquid from the tank (eg for

evacuating tank prior to uplifting and/ or for a commercial uses such as.

forklift trucks which utilise LPG as a liquid). It is not required for use by

domestic bulk LPG customers and is normally blanked off. It is usually

located on top of the tank with an internal dip tube to the bottom.

• Liquid drain. Where fitted, this provides alternative means to drain the

contents of the tank in the event of an emergency or problems with the

liquid off-take.

7. Thus, the functions required for a domestic bulk tank can be reduced to 5

valves, hence the modern 5-in-line arrangement shown in the figure below.

Vapour PRV
Offtake Valve
+
Ullage Valve
Liquid Fill
Valve

Contents Gauge

5 - in - Line Valve
Arrangement

Note: Graphic for illustrative purposes only, does not show all fittings.

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The combo valve

8. The ’Combo’ valve incorporates 4 out of the 7 functions mentioned above,

namely filler valve, vapour offtake, ullage, and liquid off-take/removal. This

leaves the contents gauge and PRV plus the Combo valve on the tank, hence

3-in-line arrangement if a Combo valve is used.

9. MML encountered three Combo valves, all with same functionality: 66/50,

84/10 and 84/12.

Reasons for differing Valve Arrangements

10. Over the years many different valve arrangements have been used on tanks,

although they all include the above-mentioned functional valves. The number

of different arrangements and combinations has arisen for the following

reasons:

• Economy—less openings in the tank shell and combining functions in one

valve ie the Combo valve, will reduce the costs.

• Safety—separating the vapour off-take and the liquid filler will avoid

splashes of liquid LPG entering the vapour pipework supplying the

customer.

• Safety—some operators perceive the reduced number of tank openings to

reduce the risk of leaks on tank fitting joints.

• Operational—combining the ullage and filler could assist the driver to

better supervise the operation.

11. Three-in-line, and five-in-line valve systems are other variations referring to

the number of valves on top of the tank.

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12. We believe the specific arrangement is immaterial once the basic functional

valves are correctly included and the whole system conforms to PSSR, PER

and the LPGA Codes of Practice. In practice, a competent LPG supplier and

a competent suitably trained driver will be able to fill any of the domestic bulk

LPG tanks irrespective of the valve arrangements.

13. Pressure System Safety Regulation (PSSR) and its written scheme of

examination require the LPG supplier who owns or intends filling the tank to

know the history of the tank. The LPG supplier must ensure that the test

certificates, valving system, its location and driver instruction allow it to be

safely filled with LPG.

Filler Valves and the use of an adaptor

14. All tankers observed by MML were fitted with the standard 1¾” ACME

connector, and we understand from a variety of sources that this is ubiquitous

across the industry for domestic bulk filling.

15. Adaptors would be needed when connecting fittings whose connections were

not compatible. For example, step-up adaptors are used for filling large LPG

tanks by connecting 1¾” ACME to 2¼” ACME connections.

16. When a tank is being filled, the product flow must be in one direction only,

and safety is assured by the use of back pressure check (non-return) valves.

These allow flow of LPG liquid into the tank, but prevent outward flow from

the customer tank in the event of rupture or damage to the hose or filler valve

fitting.

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17. The LPGA codes and PER require the additional safety feature of a positive

shut off valve on the filler valve to be fitted at the first available opportunity, as

reference below:

• LPGA Code of Practice No. 1 Part 1 Section 3.1.16.2 requires existing

tanks that do not have this isolation valve to be modified at the first

available opportunity.

• LPGA Technical Memorandum 21, 1987 requires existing tanks that do

not have this isolation valve to be modified at the first available

opportunity.

• PER 1999, when read in conjunction with the LPGA Codes of Practice,

may be interpreted to identify a similar requirement to ensure safe filling

operations.

18. However, since the LPGA Codes are voluntary, there is a range of

interpretation regarding when suppliers refurbish tanks and replace filler

valves. For example, we were advised that whilst all LPG suppliers may not

consider the 10-year examination frequency as the same as that for tank

refurbishment, some companies carry out a complete valve replacement at

the 10-year inspection. In practice, we expect the tank population to be

progressively refurbished over the next few years.

19. All LPG Suppliers we contacted reported following the LPGA Codes of

Practice.

20. A filler hose adaptor is frequently used when filling the older valves without a

positive shut-off valve. This adaptor is positioned at the end of the filling hose

closest to the tank being filled. It serves as an added safety factor. The

operating parts include a back check valve and a bleed valve. When the

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 filling operation is completed, and the hose end valve closed, the bleed valve

on the adaptor is opened. If a small amount of liquid LPG is quickly released,

it indicates that the check valves in the filler valve have closed and the hose

can be safely disconnected. If, however, liquid LPG continues to escape from

the adaptor bleed valve, it is evident that the check valves are not functioning

properly. If this should happen, the driver leaves the adaptor in place on the

tank, disconnects the hose at the tanker end of the adaptor, and places the

cap on the adaptor. The driver may retrieve the adaptor at a later date when

the filler valve has been repaired or replaced.

21. During our survey, many LPG suppliers stated they had such adaptors. One

LPG supplier reported using it as an additional fitting on their tanker hose end

fitting. They further stated they have discovered through their experience that

this hose end filler arrangement reduces the bending moment on the filler

valve and is consequently safer. MML accepts that the filling assembly is

shorter and that the bending moment is reduced. MML feel it also overcomes

the difficulty of a driver encountering a tank filler valve that does not have a

positive shut off valve. It does however, introduce a further threaded

connection (designed for connection by hand threading) in the tanker hose-

end valve assembly. MML consider additional threaded connections as

potentially hazardous due to the possibility of leaks. []. Note also that

LPGA CoP 1, Part 1, 3.1.16.5 states ’Where a storage vessel is to be filled on

a regular basis by one supplier the use of adapters should be avoided’.

22. The current situation is that the vast majority of filler valves have already been

changed, and now include the integral manual isolation in the filler valve.

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23. Regarding tanker hose-end valves, there will always be the requirement to

use adaptors for step-up and step-down use in situations where larger filler

valves are used. These are encountered typically in industrial installations. In

addition, it is sensible for LPG Cos to continue to carry the Rego 7577V as a

spare on tankers should an unforeseen tank filler valve, without manual shut-

off, be encountered. MML would recommend that LPG Cos consider

improving driver training, tanker procedures and record-keeping to ensure

any risks related to using adaptors, eg inadvertent uncoupling of adaptor

while disconnecting, are reduced.

Differences in Operational Procedures

24. CC has stated that the four major LPG suppliers cover some 90 per cent of

the installed bulk tanks. Our estimate is that the practices of the ten LPG

suppliers we spoke to, including all four majors, cover at least this 90 per cent

of installed bulk tanks. All these suppliers advised that these practices were

representative across their operations.

25. From our review of the filling operations, we found remarkably consistent

operations, essentially to the minimum acceptable level, namely the LPGA

CoP. We found that maintenance is carried out by a mix of in-house and third

party resources and the industry is familiar with contracting-out maintenance.

In our view, the reputable maintenance contractors mentioned by the

suppliers carry out work to the same minimum standards (CoP) across the

industry.

26. Before any installation is to be filled the LPG supplier trains the driver on the

specifics of the installation in terms of location, access, valving arrangements,

contacting customer etc. It is normal for drivers to check the LPG tanker they

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 will be using that day for all fittings, operability of controls and required

paperwork before leaving the supplier’s depot. Suppliers differ in the

checklists they use and information recorded.

27. To identify differences in filling procedures we divided the process into three

steps:

(a) Pre-filling checks

We found all drivers we observed to position the tanker and carry out checks

on the tank and valves in a similar way. The only difference was in the safety

marking of the installation by warning signs and cones. Some suppliers

placed a warning sign in the road several metres upstream of the tanker,

some placed cones around the tank while filling, and others did neither.

(b) Filling operation

In most respects the filling operations performed by the drivers were similar.

We observed four main differences:

(i) Most tanks had a lid which was locked between fillings but some

suppliers advised that they did not lock the lid as keys could get lost and

thus affect top-up.

(ii) Whilst all tankers had earthing reels, some suppliers earthed the tank

for all operations and others for none.

(iii) There was wide variation in the provision of a remote ’deadman’ control

for the tanker. We found major and independent suppliers in both

categories of those who used a remote deadman and those who did not.

The LPGA Code of Practice No.2 requires ’hoses exceeding 10 metres

in length (including end fittings) should be provided with a means for the

person controlling the delivery to shut the internal valve in the road

tanker by remote control from a position adjacent to the hose end’.

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 (iv) The normal check to confirm the tank is full is when liquid discharges

from the ullage valve, corresponding to a tank volume of between 85 per

cent and 87 per cent full. The valve is opened and closed at the start of

filling to confirm operability. Some suppliers’ drivers then check the

contents gauge and at regular intervals (eg every 20 per cent) open the

ullage valve to visually check for liquid, increasing the frequency as the

tank nears 85 per cent. Other suppliers’ drivers only check near the top

and others still leave the valve open throughout the fill.

(c) Defective Reporting and Rectification procedure

There are two major differences in the Defective Reporting and Rectification

procedure:

• The level of site defect reporting and action. Some suppliers complete site

defect reports at each filling, others only do so when there is a defect to

report. The level of detail in the forms varies from very basic to detailed

reports covering over 20 aspects of the installation. Whilst we found some

LPG suppliers to have impressive procedures for follow-up action to

defect reports we were not able to determine the extent of follow-up for all

the suppliers we visited

• Some suppliers empower their drivers to carry out minor repairs on site

and these drivers carry basic tools and spares for this purpose. The

drivers record any such modifications to update the tank records.

The Provision of Emergency Services

28. Emergency response across the industry is provided by a mix of in-house,

contractor and 3rd party resources. All major suppliers and many

independents attend to the first emergency call in-house, then forward the

enquiry to their own team if available or local contractors. It is common for the

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 out-of-hours response number for some independents to be the personal

contact number of the company owner.

29. The Gas Safety (Installation & Use) Regulations require a 12 hour response

to gas leaks, although most suppliers stated they respond much quicker.

30. Some LPG Cos have arrangements in place with specialist facilities

management organisations, while others have agreements with 3rd parties

such as the local police constabulary to coordinate action. In the more rural

areas, major LPG suppliers utilise the knowledge & services of pre-qualified

local contractors who will telephone the customer in the first instance and see

if through their instructions the installation can be made safe before they

arrive. They will then visit the site.

31. Emergency service is an area where LPG suppliers are prepared to overlook

competitor considerations and attend to emergencies for any customer. For

example, all LPG suppliers we contacted advised that if they were contacted

by a competitor’s customer with an emergency they would respond to it as if

the customer were their own. In practice, the response could come from a

contractor the original supplier would have used.

Consistency in Installations

32. All tanks in service must conform to PSSR. Related pipework must conform to

GSIUR. In addition, the LPGA CoP, which provide adequate guidance for the

installation of tanks and related pipework. PSSR also requires an inspection

and briefing for the driver before filling a different tank configuration therefore

there are no safety issues directly related to filling with different valve

arrangements once a driver has been trained.

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33. We found a high awareness among suppliers and contractors of safety

separations, location guidelines and materials selection. Tanks and related

pipework were found to be installed consistently to similar standards,

although minor improvements could be made, for example many installations

seen had similar location issues relating to proximity to grown vegetation.

34. All service pipework we saw followed the standard format set out in GS(IU)R,

being; first stage regulator on tank, usually accompanied by second stage

and UPSO/OPSO, followed by a portion of underground LPG pipework in

polyethylene (PE) terminating in an Emergency Control Valve (ECV). We

recognise that many older installations which predate GS(IU)R (1994) do not

conform to this format. All tanks and PRVs seen by MML were within date.

35. In the domestic bulk market, there are effectively three valve arrangements in

service; 5-in-line, 3-in-line with a Combo valve, and the underground tank that

is really a 5-in-line but all fittings raised up on the lid. The driver will be trained

to fill each of these but will also be expected to fill many non-domestic tanks,

also with different valve arrangements. In our view, domestic bulk installations

will be by far the simplest the driver encounters.

36. The manual valve on the filler is a requirement being implemented as older

tanks come up for refurbishment as an additional safety measure should the

check valve on the tank fail. It is not an issue once the Rego 7577V adaptor is

used, which provides another mechanism to isolate the tanker hose from the

tank. These are normal operational and training issues.

37. The service pipework is defined in GSIUR. This is taken to include all the

associated controls and valves up to the outlet of the ECV. Its ownership has

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 many combinations. The following are some encountered during MML

survey:

(a) LPG supplier-owned, reflecting many newer installations.

(b) Customer-owned, usually associated with the customer owning the tank.

(c) Part customer, part LPG supplier. This arises if there is a particularly

long distance from tank to ECV. The LPG Co will in effect get the

customer to pay for some of it.

38. Only CORGI/LPG qualified engineers can install, test or maintain the service

pipework regardless of who owns it. MML’s view is that this occurs at most

installations. Moreover, the drivers of three of the suppliers we saw had

CORGI/ LPG qualifications. The normal testing requirement is that the correct

material is used and that it is installed and tested per CoPs.

39. MML propose that not all installations can meet current CoP due to their age

and history (eg the tank portfolios of some acquired firms) but over a period of

time they will all be harmonised. We found several cases where new

suppliers had relocated tanks when they had taken over from another

supplier, so that the new installation complied with LPG CoP. We were

advised that some of the modernisation programmes are behind schedule

and there is a backlog of older equipment to be refurbished. Tank fitting and

installation is undertaken by a mix of in-house and contracted resources.

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