Outdoor process pipe rack with insulated lines and steel structure seen from below
PESO · SMPV(U) Rules 2016 · Resources

Altering a PESO-licensed gas installation? The P&ID goes in with the plan.

PESO reads the P&ID twice: when the licence is granted and every time the licensed premises change. The second one is the one plants miss.

Under the SMPV(U) Rules 2016, PESO asks for a piping and instrumentation diagram twice: with the plans for a new storage licence (Rule 46(1)(i)(e)) and with every alteration to licensed premises (Rule 53(2)(ii)). An approved alteration cannot be taken into use until the licence is amended under Rule 53(5).
Written answer from a P&ID engineer

Does your change need PESO approval first?

Two answers you already know. The rule that applies appears here. No email needed.

Free · instant · based on SMPV(U) Rules 2016, Rules 46, 53 and 54

46(1)(i)(e)P&ID with a new SMPV storage licence
53(2)(ii)P&ID with every alteration
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The duty, to clause level

Which rules ask for a P&ID, and when?

Four provisions of the Static and Mobile Pressure Vessels (Unfired) Rules 2016 decide when PESO sees your P&ID. The Chief Controller of Explosives or a Controller he authorises applies them.

InstrumentRuleWhat it requiresWhen
SMPV(U) Rules 201646(1)(i)(e)A piping and instrumentation diagram for the vessels, equipment and system proposed, filed with the specifications and plans for a storage licence.Before the licence
SMPV(U) Rules 201646(1)(i)(c)For major installations of flammable or toxic gases including LNG (above 50 t of product, or 100 m³ water capacity per vessel, whichever is less): the area within 500 m, a HAZOP study and a risk analysis report by a reputed agency.Before the licence
SMPV(U) Rules 201653(1) and 53(2)No alteration until PESO approves the plan in writing. The filing carries three copies of the plan with the alteration in distinct colour and the reasons, and the P&ID of the vessels, equipment and system proposed.Before the alteration
SMPV(U) Rules 201653(4), 53(5) and 54(1)Apply to amend the licence as soon as the sanctioned alteration is built, in Form AS-1 or AS-2 with four copies of the sanctioned plan. The altered part is not used until the licence is amended.After the alteration, before use

Rule numbers are from the SMPV(U) Rules 2016 as published. PESO amends the rules and issues standard operating procedures and circulars, so name the version your circle office applies in the filing rather than assuming the latest.

Not sure whether your installation counts as a major installation?

What counts as an alteration

Which changes bring the P&ID back to PESO?

Rule 53 applies to any alteration in the licensed premises. These are the changes that alter what the licensed P&ID shows.

New or replaced vesselA bullet, mounded vessel or tank added, replaced or re-rated.
New line or tie-inA filling, discharge or vapour line added or rerouted on the vessel system.
Pump or compressor changedTransfer equipment added, replaced or relocated.
Relief, vent or flare changedA relief valve, vent or flare connection added, resized or moved.
Capacity increasedMore vessels or larger vessels, which can also cross the major-installation threshold of Rule 46(1)(i)(c).
Different gas storedA change of product changes the hazard the approved plan was based on.

Planning one of these changes?

Who does what

Who files, who draws and who approves?

Three parties share a PESO alteration. Each holds a separate part of it.

  1. The licenseeApplies for approval of the alteration and for the licence amendment, and holds the licence.
  2. The engineer the licensee appointsPrepares the plan, the P&ID and, where Rule 46(1)(i)(c) applies, the HAZOP and risk analysis.
  3. The Chief Controller or ControllerScrutinises the plan and P&ID, sanctions the alteration and amends the licence.

What an out-of-date licence P&ID costs you

A P&ID filed years ago and never updated turns every later filing into a reconstruction job.

  • The next alteration is drawn against a sheet that no longer matches the site.
  • A HAZOP for a major installation is run on that sheet, so lines missing from it are never studied.
  • An insurer or client auditor walking the site sees equipment the licence drawings do not show.
How a submission is prepared

How is a PESO alteration filing put together?

A clean filing starts on site, not at the drawing board, because the alteration is drawn against the installation as it stands.

STEP 01

Compare licence and site

The licensed P&ID and plan are walked against the installation and differences logged.
STEP 02

Draw the alteration

P&ID updated, plan drawn with the alteration in distinct colour and the reasons stated.
STEP 03

HAZOP and risk analysis

Where Rule 46(1)(i)(c) applies, the HAZOP is run on the updated P&ID and the risk analysis prepared.
STEP 04

Filing set

Drawings, specifications and reports assembled for the licensee's PESO e-filing.
STEP 05

Scrutiny queries

Drawing queries from the Controller answered and sheets revised.
STEP 06

Amendment set

Sanctioned plans issued as built for the Form AS-1 or AS-2 amendment.

What the filing has to show

Two things carry a PESO alteration: a drawing that matches the plant, and a plant that matches the drawing.

Illustrative P&ID with red clouds marking a bypass and a replaced pump found on siteThe drawing
Illustrative example, not a client drawing. Differences found on site are clouded before the alteration is drawn.
Insulated process pipework and valve stations inside an operating plantThe site
Walked, not assumed. Every line on the sheet is traced in the plant.

Who prepares and checks the drawings?

Every proposal names the people on the drawings, with CVs. The licensee signs the application; the engineers sign the drawings.

Prepares

P&ID lead

Walks the site and draws the P&ID and the alteration plan. Named in the proposal.
Checks

Checking engineer

Checks every sheet against the site record before issue. Named in the proposal.
Record

Drawing register

Each sheet carries its revision and the date it was checked, so the filing can be traced.

Planning several alterations this year? Send this to your projects head.VB Engineering capability brochure, sent to you by email.

Before you file

Questions plants ask about P&IDs for PESO

Does PESO need a P&ID for a new SMPV licence?

Yes. Rule 46(1)(i)(e) of the SMPV(U) Rules 2016 lists a piping and instrumentation diagram for the vessels, equipment and system among the plans filed for a storage licence.

Does PESO need a revised P&ID when a licensed installation is altered?

Yes. Rule 53(2)(ii) requires the P&ID of the vessels, equipment and system proposed with every alteration filing, alongside three copies of the plan showing the alteration in distinct colour.

Which drawings does PESO ask for with an alteration?

Three copies of a properly drawn plan of the licensed premises with the alteration in distinct colour and the reasons, the P&ID, and any other document the Chief Controller or Controller specifies (Rule 53(2)).

Can we carry out the alteration before PESO approves it?

No. Rule 53(1) says no alteration shall be carried out until the plan showing it has been approved in writing by the Chief Controller or a Controller he authorises.

When do we apply to amend the licence?

As soon as the sanctioned alteration has been carried out (Rule 53(4)). The amendment is applied for in Form AS-1 or AS-2 with four copies of the sanctioned plan, and the altered part is not used until the licence is amended (Rule 53(5), Rule 54(1)).

Which installations need a HAZOP for PESO?

Major installations of flammable or toxic gases including LNG, where total product exceeds 50 t or any vessel exceeds 100 m³ water capacity, whichever is less. Rule 46(1)(i)(c) asks for a HAZOP study and a risk analysis report by a reputed agency.

What is an SMPV licence?

An SMPV licence is PESO's licence to store compressed gas in pressure vessels under the Static and Mobile Pressure Vessels (Unfired) Rules 2016, which apply to vessels above 1,000 litres water capacity.

Who prepares the P&ID for a PESO filing?

The licensee files, and the drawings are prepared by the engineer the licensee appoints. VB Engineering prepares the P&ID, the alteration plan and, where needed, the HAZOP for the licensee's filing.

What if the P&ID on our licence no longer matches the site?

Rebuild it from the installation before the next alteration is filed. An alteration drawn on an out-of-date sheet carries the old differences into the new approval.

How do we get PESO approval for an alteration?

File the alteration plan, P&ID and documents on PESO's online system for scrutiny, wait for the signed plan, build the alteration, then apply to amend the licence before use.

Question not answered here? Ask a P&ID engineer.

Tell us the alteration you are planning

Tell us the installation and the change. We reply in writing with the drawing set PESO will expect and whether a HAZOP and risk analysis apply.

  • The drawings your alteration filing needs, listed
  • Whether Rule 46(1)(i)(c) makes your installation a major installation
  • A written answer whether or not you engage us

Ask a P&ID engineer

Takes under a minute. No obligation.
  • A reply from a P&ID engineer, not a sales desk
  • The drawing list for your alteration in writing
  • Whether a HAZOP applies to your installation

Prefer to write? connect@groupvb.com · or WhatsApp us from the chat button

Altering a licensed gas installation? PESO needs the P&ID before you build.