Safety Driven Performance 2013 Developing and Maintaining Relief System Design Documentation as an Evergreen Process Marie Baker Relief System Optimization Technical Manager Lloyd’s Register Energy America’s, Inc.

Agenda Overview of 29 CFR 1910.119 – How this standard applies to relief systems Relief system design documentation methodology – Benefits of using a system based approach for relief systems Developing an evergreen process – The importance of an evergreen process for relief systems Optimization of relief system design documentation – Helpful hint for optimizing data

29 CFR 1910.119 – Process Safety Management of Highly Hazardous Chemicals Intended to prevent or minimize consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals Applies to facilities that meet the following requirements: Process involving a chemical at or above the specified threshold quantities listed in appendix A Process involving a flammable gas or liquid with a flashpoint below 100 °F on site in a quantity of 10,000 pounds or more

29 CFR 1910.119 – 14 Elements of Process Safety Management Employee participation Process safety information Process hazard analysis Operating procedures Training Contractors Pre-startup safety reviews Mechanical integrity Hot work permit Management of change Incident investigation Emergency planning and response Compliance audits Trade secrets

29 CFR 1910.119 (d) – Process Safety Information Highly hazardous process chemical information Physical data Toxicity information Process technology information Block flow diagram/Process flow diagram (PFD) Process chemistry Safe upper/lower limits Process equipment information Process & instrumentation diagrams (P&ID) Equipment design codes and standards Relief system design and design basis Talk about subsection ii – The employer shall document that equipment complies with recognized and generally accepted good engineering practices (RAGAGEP)

What is Relief System Design Basis Relief system design basis – documents how the loads and sizes of the relief system were determined Includes but not limited to: Overpressure scenarios Relief load calculations Assumptions

Relief System Documentation Methodology – System based approach System based approach is the preferred methodology System comprised of: Protected equipment Interconnected piping Relief device(s) Relevant equipment included in documentation Pressure sources Inlet control valves Restriction orifices Locked open/closed valves Determine how to evaluate the relief systems – device vs. system approach System – based on equipment rather than relief device

Benefits of System Based Approach All equipment is evaluated Pressure Vessels Heat Exchangers Pumps Tanks Captures equipment without overpressure protection Presents a total picture of the system All equipment is evaluated not just equipment with a relief device. Analysis should be performed on unprotected to determine if protection is needed.

System Based Approach - Example

Relief System Documentation Methodology Overpressure Scenario Evaluation Includes all systems, protected and unprotected All scenarios evaluated for each system Rationale provided for each For all credible overpressure scenarios Calculations performed Required relief load Required orifice area Inlet and outlet pressure drops Any assumptions should be documented Full evaluation of all potential overpressure scenarios performed for each system and rationale provided documenting why credible/not credible. This is good practice as it can eliminate questions later about specific cases (why or why not considered), PHA/HAZOP questions can be answered quickly and easily Credible scenarios should have relief rate calculated or explanation of why no load calculated – nominal or same as another case (MAWP < Pressure > MAAP) Good practice to calculate area and pressure drops for all cases not just controlling. Largest rate may not be the largest area or have the highest pressure drop.

Recommended Relief System Documentation API 521 recommended documentation Protected equipment information Overpressure scenario analysis Relief conditions Relief device manufacturer/model Relief load calculations Effluent location Full listing provided in API 521 Section 4.4

Benefits of Relief System Documentation Process Consistent documentation Following same standards/guidelines on all projects All equipment is evaluated Protected and unprotected Information is detailed Scenario rationales fully explained Calculations included Assumptions stated

Benefits of Relief System Documentation Process Current information available to the facility Process Hazard Analysis (PHA) Hazard and Operability (HAZOP) Turnaround (TAR) planning Internal and external audits

Steps to Evergreen the Relief System Documentation – Step 1 Define/develop baseline for relief system design Revalidation Partial or full Recommended when documentation is scarce at a facility Gap analysis Based on overpressure scenarios Based on documentation Design verification

Steps to Evergreen the Relief System Documentation – Step 2 Develop a process for updating the relief system design basis Who will be responsible for relief system documentation In-house group or third party contractor How information will get to the responsible group How and where information will be stored Electronically or paper copies Central location or multiple copies spread throughout facility When will relief systems group be brought in on projects Who will have access to the information and to what extent Communication to all areas of the plant about the importance of keeping the relief system design and documentation up to date.

Steps to Evergreen the Relief System Documentation – Step 3 Implement the process and continually improve on it Workflow process written in detail Look for ways the process can be more efficient Who is responsible for keeping up to date on new standards As people and job responsibilities change, there needs to be a succession plan or detailed documents on the process and how it has been working. As standards change, there needs to be a process to keep up with those as well. Each time the standards are published there is more information and more detail on the existing information.

Optimizing Relief System Design and Documentation Master system files stored as PDF electronically Limits access for unauthorized changes Provides venue for anyone needing the information Can easily be viewed in meetings Utilizing database software Provides storage of data Various software available depending on facility requirements Software can provide users with different levels of accessibility Information is searchable by plant personnel Specific information can be easily extracted

Any questions?

Marie Baker For more information please contact: Relief System Optimization Technical Manager Lloyd’s Register Energy Americas 1330 Enclave Parkway, Suite 200 Houston, TX 77077 T +1 281 649 2781 E mariee.baker@lr.org W www.lrenergy.org