Biomethane gas installations

Safety legislative obligation

What is biomethane?
Biomethanealso known as biogasis a
hydrocarbon gas produced from the
breakdown of organic matter in the absence of
oxygen.
Depending on the source, biogas typically
comprises the following compounds with
varied percentages:
Compound

Methane

5085

Carbon dioxide

550

Hydrogen

01

Hydrogen sulphide

03

Nitrogen

05

Oxygen

02

Biomethane is generally produced by one of

two methods:
Anaerobic digestion biogas is
produced in purpose-designed, aboveground tanks or in ponds to optimise the
gas-producing decay process from animal
and other organic waste.
Landfill biogas is produced by allowing
natural decay to occur within a landfill site
where gas is produced and then captured.

What is the relevant safety legislation?

The Petroleum and Gas (Production and
Safety) Act 2004 (the P&G Act) and the
Petroleum and Gas (Production and Safety)
Regulation 2004 (the Regulation) govern the

safe operation and management of

biomethane gas installations.
Biomethane, including gas produced from
waste disposal tips and treatment of sewage, is
defined as petroleum and fuel gas under the
P&G Act and Regulation.
Under this legislation there are a number of
key requirements relevant to biomethane gas
installations:
1. The need to make and implement a safety
management plan (SMP) for the plant
2. Three statutory positions in the legislation
with specific obligations: executive safety
manager, operator, and site safety
manager.
3. Risk assessment requirements when
using unodourised gas
4. Approval processes for the design of
relevant gas burning devices
5. Requirements for installers to be licensed
or competent under the SMP
These are outlined in more detail in the
following sections.

Is the production or use of biogas

operating plant?
Yes by virtue of section 670(5) (e) of the P&G
Act and section 10(3) (c) of the Regulation, an
activity involving the collection, transportation
or use of fuel gas (biogas) at a place is
prescribed as operating plant.

What are the key requirements for

operating plant under the P&G Act?
You must have a safety management plan
(SMP) that is compliant with the P&G Act
before plant is commissioned or operated.

What should go into an SMP?

Section 675 of the P&G Act lists the content
requirements of an SMP. To help you
understand these requirements we have also
prepared a guideline called SafeOp.

My organisation already has a safety

management plan or system. Do I need
to create a new one?
No, your existing system can be used as long
as it incorporates all the relevant elements
prescribed under section 675 of the P&G Act.
The Petroleum and Gas Inspectorate (P&G
Inspectorate) suggests that the operator
create a document mapping the existing
system against the elements listed in section
675 of the P&G Act. Any deficiencies that are
identified should then be addressed in the
existing system.

Who is the executive safety

managerof an operating biogas plant?
The executive safety manager, or ESM, is the
senior managing officer of the corporation or
organisation responsible for the management
and safe operation of the operating plant.
(See section 687[1][b] of the P&G Act).
The senior managing officer is the person who
is the most senior officer (e.g. CEO) of the
corporation in Australia and is responsible for
managing the corporation.

What are the ESMs general

obligations?
The ESM must:
appoint an appropriately qualified person
as the operator of the biogas plant
ensure that the operator of the biogas
plant has, for each stage of the plant (such
as commissioning and operation), an SMP
made under section 674(1)(a) after
consultation with the employees at the
plant
approve the SMP before it is put into effect
ensure that the SMP is implemented in a
way that effectively manages the risks
associated with the plant.

On or before 1 September each year, the

ESM must also lodge an annual safety report
for the plant with the Chief Inspector,
Petroleum and Gas, in relation to the preceding
financial year (refer to section 690 of the P&G
Act).

Who is the operator of an operating

biogas plant?
Under the P&G Act the operator is the
individual responsible for the management and
safe operation of the biogas plant. Typically,
the operator would be the operations manager
or general manager for the plant. It is not the
person actually operating the plant or parts of
the plant.

What are the operators obligations?

Section 674 of the P&G Act says that the
operator must make, implement and maintain
an SMP that complies with section 675 of the
P&G Act for each stage of the plant. The
operator must not begin a stage of the plant
unless the operator has made the SMP for that
stage.
The SMP is not submitted to, or approved by,
the P&G Inspectorate. It is, however, subject to
audit by the P&G Inspectorate.
Where there are separate entities operating
parts of biogas plants they are each plant and
each operator must have an SMP that
complies with section 675.
Example: Where biogas is produced by one
company and the use of gas (e.g. power
generation) is managed by another, then
they are separate plant and each operator
requires an SMP that complies with section
675 of the P&G Act.
The operator of a biogas plant operated for the
first time in Queensland must ensure that the
Chief Inspector is given written notice within
20 business days before commissioning or
operating the plant.

Stephen Matheson | Chief Inspector | Petroleum and Gas

Ensure all relevant people in your organisation receive a copy of this information sheet.
Follow our updates on Gas safety Queensland Facebook and Twitter
State of Queensland, Department of Natural Resources and Mines, 2013.

Version 2, January 2013, Page 2

Who is the site safety manager?

The site safety manager (SSM) is an
appropriately qualified person who is required
for the site under the SMP and is appointed by
the operator.
It is expected that all sites where multiple
persons are working on a regular basis would
have a site safety manager. If the SMP does
not stipulate one, then the Chief Inspector can
require one to be appointed.

What are the site safety managers

obligations?
The site safety manager must ensure
each person who enters the site is given
an appropriate induction
each person at the site complies with
standard operating procedures, the
emergency response procedure and other
measures necessary for the safety of the
site and the person
each person at the site performs their
functions safely and follows standard
operating procedures for the plant
necessary first aid, safety and other
equipment is available and maintained.
relevant staff are trained in first aid and
general safety procedures.

Is a risk analysis required for the use of

un-odourised biogas?
Yes, section 628 of the P&G Act requires fuel
gas to be odourisedunless the supply is to
an industrial installation where a risk analysis
has been carried out by an appropriately
qualified person. The risk analysis must
demonstrate that the supply is safe.
Gas-detection equipment and safety shutdown systems will most likely be needed.

Who is an appropriately qualified

person?
Section 628 of the P&G Act defines an
'appropriately qualified person as one who is
independent of the person supplying the fuel
gas. The Chief Inspector has prepared a list of
people that have already been considered

appropriately qualified to undertake the risk

assessment.
Other persons can also seek to be considered
for this role by applying to the Chief Inspector.

Hydrogen sulphide H2S has a smell. Can

this be used as an odorant?
Noalthough biogas may contain traces of
H2S, under no circumstances shall it be used
to satisfy the odourisation of biogas.
H2S has a rotten egg smell at only a few parts
per million (ppm), but it can also become
undetectable by smell. Exposure to H2S at
relatively low levels can affect the olfactory
nerves used for smelling, and prolonged
exposure can be fatal.

Do biogas tanks and ponds need to be

approved and certified?
No, there are no specific provisions in the
P&G Act for tanks or ponds to be approved
and certified; therefore, it is imperative that the
SMP identifies and manages any risks
associated with biogas tanks and ponds. This
includes the location, design, materials,
construction, installation, operation and
maintenance of the ponds and tanks and their
associated collection and filtration systems.
It is highly unlikely that potential operators of
biogas plants will have the skills and/or
competencies to identify all of the inherent
risks associated with biogas plants. Therefore,
risk assessments should be undertaken in
conjunction with people who possess the
necessary skills and competencies. Only
experienced, skilled and competent
organisations should be engaged to design
and build biogas plants.

Do biogas gas appliances need to be

approved?
Yes, all Type B (industrial) gas devices
(appliances) that use biogas must be approved
and certified by an approved Type B approving
authority before installation or use.

Stephen Matheson | Chief Inspector | Petroleum and Gas

Ensure all relevant people in your organisation receive a copy of this information sheet.
Follow our updates on Gas safety Queensland Facebook and Twitter
State of Queensland, Department of Natural Resources and Mines, 2013.

Version 2, January 2013, Page 3

Examples of typical Type B devices used at

biogas plants include stationary engines,
turbines and hot water heaters.
Flares are currently not prescribed in
Regulation and are therefore not Type B
devices. Some flares require a separate
burner system, generally operating on LPG, to
ignite the flare. These systems may be a Type
B device in their own right and must be
approved.

What is the process for approving and

certifying gas systems and gas
appliances?
All the relevant technical, design and
operating information for the gas device must
be submitted to a Type B gas appliance
approving authority. The authority then
assesses the information against the relevant
gas appliance safety requirement.
Generally, gas appliance manufacturers or
suppliers would make the technical
submission to an approving authority to have
a gas device approved for use. The proposed
operator/owner, of the device and/or their gas
device installer (if they have the technical
expertise), may also apply for approval to the
approving authority.
Once the design of the Type B gas device has
been approved, all gas work associated with
the Type B appliance (installation,
commissioning and maintenance) must be
undertaken by licensed/authorised persons
under the P&G Act.
The installation, testing and commissioning of
the gas system (pipes, valves, fittings and
equipment) from the outlet of the biogas tank
or pond, up to the gas isolation valve of the
Type B appliance, must be undertaken by the
holder of a relevant Queensland gas work
licence or gas work authorisation (industrial
appliances). Work from gas isolation valve
and the Type B appliance itself can only be
undertaken by the holder of a relevant gas
work authorisation (industrial appliances).

Once the gas system and the Type B gas

appliance have been installed, the installation
must be certified under section 697 of the P&G
Act.

What needs to be considered when

designing, installing and operating
biogas systems?
As part of the SMP process, biogas systems
must undergo a hazard and operability study
(HAZOP) risk assessment and meet relevant
standards. Standards include, but are not
limited to:
AS2430 Classification of hazardous areas
AS3000 Electrical installations
AS/NS5601 Gas installations
AS3814 Commercial and industrial gasfired\ appliance and
AS1375 SAA Industrial fuel-fired appliances
code
The design and installation of biogas systems
must take into account water removal from the
gas. It must also take into account the potential
presence of H2S, which is both corrosive and
lethal in high concentrations.
Ideally, all water and H2S should be removed
from biogas before its transportation and use.
H2S removal is required in order to avoid
corrosion in piping, compressors, tanks and
engines. H2S is extremely reactive with most
metals, and this reactivity is increased by the
presence of water and elevated temperatures.
Any risk of transporting biogas that is in a
flammable range in the gas system or for an
ignition source to enter the gas system must be
eliminated or controlled.

What other legislation may apply?

This information sheet focuses only on safety
matters in regard to the gas-related activities
and is not intended to be a guide to all
applicable legislation.
There will be other relevant legislation that
project proponents and operators will be
subject to and it is up to the
proponent/operators to determine this.

Stephen Matheson | Chief Inspector | Petroleum and Gas

Ensure all relevant people in your organisation receive a copy of this information sheet.
Follow our updates on Gas safety Queensland Facebook and Twitter
State of Queensland, Department of Natural Resources and Mines, 2013.

Version 2, January 2013, Page 4

These may include:

Under the section 135(2)(q) of the
Regulation the operator of a facility that
produces, processes or uses biogas is
liable to pay a Petroleum and Gas Safety
and Health fee. For further details, email
safetyandhealthlevy@dnrm.qld.gov.au or
phone the Levy Manager on 3199 8018.
As the site will be a workplace, the
Queensland Workplace Health and Safety
Act 2011 will also apply in regard to
general workplace safety matters across
the whole plant.
Environmental matters will need to be
considered under the Environmental
Protection Act 1994.
Local council planning and development
legislation may apply to the construction
and development of the plant.

For further information

It is strongly recommended that any potential
owner or operator of a biogas operating plant
contact the P&G Inspectorate before installing
the plant.
Ideally, a meeting with the proposed owner or
operator of the plant and the designer of the
plant should occur early in the conceptual
stage of development. This will ensure that
the owner or operator has an opportunity to
ask questions and seek further information
and clarification.
Contact the Petroleum and Gas
Inspectorate:
Email: gassafe@dnrm.qld.gov.au or phone:
Regional offices
Northern (Townsville)
(07) 4447 9274
Central (Rockhampton)
(07) 4936 0188
Southern (Woolloongabba) (07) 3330 4241

Stephen Matheson | Chief Inspector | Petroleum and Gas

Ensure all relevant people in your organisation receive a copy of this information sheet.
Follow our updates on Gas safety Queensland Facebook and Twitter
State of Queensland, Department of Natural Resources and Mines, 2013.

Version 2, January 2013, Page 5