Addressing Incomplete Dossier and ARH Requirements

Comprehensive Guide to Fulfilling Article 93 of Executive Decree No. 21-261

hydrocarbon facility storage installation

Highlights

Understand the Regulatory Context: The decree governs pressurized and electrical equipment in hydrocarbon facilities and requires detailed hydrostatic testing procedures.
Prepare a Detailed Site Test Procedure: Your dossier must include a complete and precise site test procedure, including hydrostatic tests, to gain ARH approval.
Follow Structured Compliance Steps: Successful compliance involves document review, technical consultation with ARH, and proper implementation of safety protocols.

Background and Regulatory Context

In Algeria, hydrocarbon facilities are subject to strict regulatory oversight to ensure the highest levels of safety and operational reliability. Executive Decree No. 21-261, enacted on June 13, 2021, plays a pivotal role in setting the standards for both pressurized equipment (PE) and electrical equipment used in these installations. Article 93 of the decree specifically mandates the submission of a site test procedure—typically a hydrostatic test procedure—by the project owner or master of the work.

The site test procedure is not merely a formality; it constitutes a critical component of the dossier that seeks official approval from the ARH, the authority responsible for regulating hydrocarbons. The ARH uses this procedure to verify that all safety measures meet established standards and that the installation is capable of operating under designated conditions without undue risk.

Key Components of the Site Test Procedure

The completeness and accuracy of the dossier are essential to obtain the necessary technical advice and subsequent approval from the ARH. A comprehensive site test procedure should articulate the following critical components:

1. Preparation and Documentation

Documentation Baseline: Begin by gathering all the preliminary documentation required by the decree. This encompasses detailed schematics of the storage installation, design specifications, operational manuals, and any previous testing records. Accurate and thorough documentation ensures that every aspect of the installation can be reviewed in the context of safety and compliance.

Technical Dossier Compilation: The dossier should include a clearly defined technical dossier that outlines the following:

a. Overview of the Installation

Include comprehensive descriptions of the site layout, equipment utilized, storage capacities, and the intended operational conditions. This overview provides ARH with contextual insight, thereby aiding in a subsequent technical evaluation.

b. Relevant Standards and Protocols

Align your documentation with internationally recognized standards for hydrostatic testing, as well as any pertinent local standards. Reference relevant inspections, certifications, and calibration records of testing equipment that will be used.

2. Detailed Hydrostatic Testing Procedure

The core component of meeting Article 93 is the hydrostatic testing procedure. This test is designed to assess the mechanical integrity and leak-tightness of the storage installation by subjecting it to pressures exceeding normal operating conditions. A well-structured hydrostatic test procedure comprises:

a. Test Objectives and Scope

Clearly define the purpose of the test, i.e., to verify the structural strength and safety of pressurized components. Enumerate the scope of the test by specifying which sections of the installation will be subjected to these conditions.

b. Test Equipment and Instrumentation

List and detail the testing equipment, sensors, gauges, and data recording systems that will be utilized. Ensure that all instruments are calibrated and certified as per applicable standards.

c. Test Execution Plan

Provide a step-by-step plan that details all phases of the hydrostatic test. This should include system pressurization schedules, the duration of pressure holding, safety procedures during testing, and clear criteria for test termination in case of anomalies.

d. Acceptance Criteria and Safety Margins

Explain the quantitative and qualitative criteria that determine whether the installation successfully passes the test. This should include acceptable pressure gradients, leak detection thresholds, and the overall performance under stress conditions.

3. Technical Analysis and Risk Mitigation

Beyond the test itself, it is imperative to include a thorough technical analysis that addresses potential risks and outlines mitigation measures. This analysis should:

a. Identification of Critical Points

Identify components of the installation that present critical risk factors. Use an analytical approach, such as Failure Mode and Effects Analysis (FMEA), to predict potential points of failure during the test.

b. Mitigation Strategies

For each potential issue discovered during the analysis, document a strategy that outlines how the risk will be mitigated. This should encompass safety provisions, such as emergency shutdown procedures, and contingency plans if the test uncovers deficiencies.

4. Submission and Consultation with ARH

Prior to executing the test, ensure that your dossier is reviewed and approved by the ARH. The regulator may require additional technical details or suggest modifications. The steps involved include:

a. Initial Review

Submit the preliminary dossier, including your detailed site test procedure, for an initial review. This step ensures that any major deficiencies are identified early on.

b. Technical Consultation

Engage in technical consultations or meetings with ARH officials. During these sessions, address all their queries and modify the plan as needed. This iterative process is crucial to align the testing procedure with regulatory expectations.

c. Final Submission

Upon receiving technical approval, formalize and complete the dossier with the finalized test procedure. Ensure that all documents are completely accurate and that you have retained copies of all communications and approvals.

Step-by-Step Compliance Process

The following table outlines a structured compliance process that can be adopted to rectify an incomplete dossier and ensure adherence to Article 93 of the relevant executive decree:

Step	Description	Outcome
Initial Documentation	Gather all necessary documents, schematics, and previous test records.	Foundation for technical review established
Drafting Procedure	Prepare a detailed hydrostatic test procedure including test plan, equipment, and parameters.	Comprehensive testing plan developed
Technical Analysis	Perform risks analysis and establish mitigation measures.	Improved safety and enhanced reliability
Submission for Review	Submit the dossier including the test procedure to ARH for initial review.	Feedback and technical advice received
Consultation and Revision	Engage with ARH for consultations and make necessary adjustments.	Alignment with ARH recommendations achieved
Final Submission	Submit the revised, complete dossier for final approval.	Dossier approved and compliance secured

Implementing a Successful Site Test Procedure

Additional Recommendations

In light of the dossier being incomplete and the ARH's insistence on a proper site test procedure, consider these additional recommendations to safeguard against further issues:

Regular Internal Audits

Prior to submission, conduct regular internal audits of your documentation and procedures. This proactive approach ensures that any discrepancies or missing elements are identified and addressed promptly. Internal audits also help in maintaining updated records that are aligned with both national and international standards.

Third-Party Verification

Engaging independent inspectors or certified auditors can provide an extra layer of assurance regarding the integrity of your procedures. Third-party verification often lends greater credibility to your dossier and can expedite ARH approval.

Training and Documentation Updates

Ensure that all personnel involved in the testing and documentation process are thoroughly trained on the latest regulatory requirements. Regular updates to the documentation reflecting the latest best practices and regulatory changes are paramount in maintaining compliance.

Ensuring Long-Term Compliance and Safety

Beyond meeting the immediate requirements of Article 93, it is vital to develop a culture of continuous improvement within your operations. Establish procedures to periodically review and, if necessary, update your site test procedure to incorporate new technological advances and evolving safety standards. A proactive stance on safety not only meets regulatory demands but also minimizes the risk of incidents that could have severe operational and environmental consequences.

Potential Challenges and Solutions

It is not uncommon for project owners and managers to encounter challenges during the preparation and submission of technical dossiers for regulatory review. Here are some potential challenges and practical solutions:

Challenge: Incomplete Data and Documentation

Solution: Conduct a thorough inventory of all related documentation. Create checklists that ensure every necessary component—from schematics and equipment certifications to calibration records—is included. Utilizing digital management systems for documents can significantly reduce oversight.

Challenge: Misinterpretation of Regulatory Requirements

Solution: Engage in direct communication with regulatory bodies and seek clarifications as required. Document all correspondence and consider employing legal or technical advisors with expertise in hydrocarbon facility regulations to ensure that every aspect of the decree is accurately interpreted and applied.

Challenge: Integration of Technical Analysis and Safety Protocols

Solution: Leverage industry best practices by conducting risk analyses and scenario planning. Developing a cross-functional team that includes operations, safety, and engineering personnel can facilitate the integration of robust safety protocols within your test procedures.

Conclusion and Final Thoughts

In conclusion, addressing the incompleteness of the dossier and successfully meeting the ARH requirements of Article 93 of Executive Decree No. 21-261 demands a systematic, detailed, and technically rigorous approach. By preparing comprehensive documentation and a detailed hydrostatic test procedure, as well as by engaging proactively with regulatory authorities, you can ensure not only compliance but also the safety and reliability of your hydrocarbon storage installations.

The recommendations provided herein, ranging from internal audits and third-party verification to structured risk analyses, offer a practical roadmap for aligning your operations with established standards. This not only facilitates immediate approval from the ARH but also positions your facility for long-term operational excellence and safety compliance.

References

Decret-21-261 English Version - Scribd
Decret Executif n°21-261 - Scribd
Decret Executif n°21-261 - ARH
Official Journal Article - Joradp
Energy Ministry Decree List - Energy.gov.dz