1. 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.

2. Agenda
Overview of 29 CFR – 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

3. 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

4. 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

5. 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)

6. 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

7. 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

8. 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.

9. System Based Approach - Example

10. 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.

11. 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

12. 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

13. 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

14. 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

15. 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.

16. 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.

17. 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

18. Any questions?

19. Marie Baker For more information please contact:
Relief System Optimization Technical Manager
Lloyd’s Register Energy Americas
1330 Enclave Parkway, Suite 200
Houston, TX T E W