Global Congress on Process Safety - 2012

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The PSV that did not fail Misconceptions about PSVs

Emmanuelle Hagey
NOVA Chemicals Corporation
Calgary, Alberta, Canada
hageye@novachem.com

[This paper shall not be reproduced without the authors permission]

Prepared for Presentation at

8th Global Congress on Process Safety
Houston, TX
April 1-4, 2012
UNPUBLISHED

AIChE shall not be responsible for statements or opinions contained

in papers or printed in its publications

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The PSV that did not fail Misconceptions about PSVs

Emmanuelle Hagey
NOVA Chemicals Corporation
Calgary, Alberta, Canada
hageye@novachem.com

Keywords: Pressure relief device, PSV.

Abstract
Pressure relief devices represent the last line of defense for a pressure vessel in a chemical plant
during abnormal situations. This paper presents some key points that every plant engineer
should know about PSV lifecycle, from design to installation and maintenance.

1. Introduction
Pressure relief devices perform a major role in a chemical plant. They protect the equipment
from unpredictable events that bring the operating pressure beyond the Maximum Allowable
Working Pressure (MAWP) of the equipment. Without these devices and if the over-pressure is
allowed to continue, the equipment can mechanically fail, and release material that creates a
hazard. The hazard can be local such as steam or condensate release which can burn workers in
the nearby area, or it can have severe consequences such as a large release of a toxic substance, a
flammable gas or combustible liquid followed by a fire and/or an explosion, with potentially
multiple fatalities.
In the mid-90s, OSHA PSM Standard 29 CFR 1910.119 Process Safety Management of Highly
Hazardous Chemicals mandated US companies to document all Process Safety Information,
including relief systems, before performing a Process Hazard Evaluation. Based on those
recommendations, audits were performed in the oil, gas and chemical industry on more than 250
plants in the USA. In 2000, a study based on the findings from the survey [1] showed that nearly
40% of the equipment had a deficient pressure relieving system. The analysis showed that about
25% of the Pressure Relief Devices (PRD) installed were either undersized, improperly installed
or a combination of both. The other 15% represents the equipment having no relief device at all.
The present paper brings forward common misconceptions about Pressure Safety Valves (PSVs)
and provides guidelines for answering these misconceptions. PRD related issues can be classified
in one of three areas: design flaws, operational issues, and testing/reliability/preventative

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maintenance. Examples of common pitfalls will be presented, providing a starting point for
what every plant engineer should know about process safety.

2. Challenges encountered in the design of new PSVs.

2.1 Understanding Relieving Scenarios.
API STD 521 [3] lists control valve failure as one of many causes of overpressure. Both
scenarios, valve failing open and valve failing close, must be assessed to determine if an
overpressure would result from the failure. This must be done regardless of the valve setting for
loss of instrument air. For example, a letdown valve between two headers with significant
pressure difference can fail open even if it set to fail closed. A vessel outlet valve can fail closed,
even if it is set to fail open.
2.2 Probability of occurrence of the design case: an unresolved dilemma.
There is a misconception in the industry that an oversized PSV is not a problem because it still
provides protection. People who convey this idea do not know much about relieving systems.
However, they put the finger on an issue that is not easy to resolve.
A PSV must be designed to handle the worst case scenario, which usually is the scenario that
would rarely occur (such as a fire case, or tube rupture in a heat exchanger). The scenario with
the (much) smaller relieving rate is usually the most probable scenario. If a PSV is designed for a
wide range of relieving rates and if it is activated for the small relieving load, it will most likely
chatter, which can lead to significant damage to the PSV. Chattering is characterized by rapid
opening and closing of the PSV, at a frequency higher than 1 Hz [2].
Below are a few pointers on how to avoid installing unnecessarily oversized PSVs:
2.2.1. Evaluating a scenario.
Be realistic in the evaluation of a scenario, i.e., understand the system before computing the
required relieving rate. In the case of loss of condensing in a distillation tower, it should be
evaluated if the reboiler can actually generate any vapor at the relieving pressure. Using the
reboiler design duty under relieving conditions can lead to huge relieving rates when in fact the
heating media may not be hot enough to reach the material boiling point under the relieving
pressure. This is especially true when the distillation column operating pressure is much lower
than the MAWP (for example, vacuum operating pressure vs. 50 psig MAWP). In this case, a
detailed simulation of the heat exchange in the reboiler is required. If a tower operates at high
pressure (e.g., operating pressure at 350 psig and MAWP at 400 psig), the error due to keeping
the reboiler duty constant is much lower, possibly negligible. In both cases, the tower bottom
composition must be reviewed because the feed will end up entirely in the bottom of the tower,
and the change in composition may impact the relieving rate. Table 1 shows examples of the
difference in relieving rates for loss of condensing depending on the assumption used for
calculation.

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Table 1. Examples of calculated relieving rates in a distillation tower due to loss of

condensing when using different approaches.
Operating
Pressure
22 psig
vacuum
5 psig
60 psig

MAWP and
PSV set
pressure
65 psig
30 psig
50 psig
73 psig

Relieving rate using a

constant reboiler duty
based on design (lb/hr)
200,000
100,000
212,000
100,000

Relieving rate using a

detailed simulation of the
reboiler (lb/hr)
123,000
4,000
75,000
73,000

2.2.2. Multiple PSVs.

One of the solutions offered when sizing a PSV device where multiple scenarios have very
different relieving rates is to install two or more PSVs with staggered set pressures. The smaller
PSV is set at the lower set pressure and opens to relieve scenarios with small relieving rates. The
larger PSV will open only when required by the scenario having a much larger relieving rate
(there is typically several scenarios with small relieving rates and one scenario with a large
relieving rate). This is a good idea if it is applied appropriately, i.e. if the set pressure staggering
is wide enough. PSVs set pressure adjustment is done manually. The allowable tolerance on PSV
set pressure, as per the ASME code [4], is +/-2 psi (15 kPa) for set pressure <= 70 psi (500 kPa),
and +/- 3% for set pressure above 70 psi. Assuming a MAWP of 500 psig, the tolerance is +/-15
psig. Having two PSVs with set pressure of 500 and 505 psig respectively will not prevent both
PSVs from opening more or less at the same time and causing chattering of one or both PSVs. In
this case, the set pressures should be at least 30 psig apart to avoid any overlap due to set
pressure tolerance. As per the ASME code [4], the set pressure of the second PSV can be as high
as 105% of the MAWP. In the example, the set pressure for the larger PSV can be as high as 525
psig. To maintain the set pressure margin, the first PSV should be set below the MAWP and not
higher than 495 psig. This can only be done if the operating pressure is low enough.
2.2.3. Is a PSV really required?
In the past, a PSV was required for all credible scenarios, including fire as per the ASME code
(See Table 2 for 2004 version of the ASME Code). In 2008, API [3] introduced the concept of jet
fire vs. pool fire, concept that was not discussed before. In case of jet fire, the vessel may fail
because of high local metal temperature not high pressure. A PSV is not the best suited safety
element and API has accepted this situation [3]. In 2008, the ASME Code [4] changed the term
pressure relief device with overpressure protection, giving credit to protection by system
design. This change gives engineers more and better tools to protect a vessel from all credible
scenarios, including jet fire. This is extremely important in a plant such as an ethylene
production facility because most of the fire cases are jet fires rather than pool fires.

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Table 2. Extract from the ASME Code Section VIII (2004 and 2008 editions)
UG-125
GENERAL
(2004)

UG-125
GENERAL
(2008)

(a) All pressure vessels within the Scope of this Division, irrespective of size or pressure, shall
be provided with pressure relief devices in accordance with the requirements of UG-125
through UG-137.
(1) It is the responsibility of the user to ensure that the required pressure relief devices are
properly installed prior to initial operation.
(2) It is the responsibility of the user or his/her designated agent to size and select the
pressure relief device(s) based on its intended service.
(a) Other than unfired steam boilers [see UG-125(b)], all pressure vessels within the scope of
this Division, irrespective of size or pressure, shall be provided with overpressure protection in
accordance with the requirements of UG-125 through UG-137 and/or overpressure protection
by system design per UG-140.In addition, the following shall apply:
(1) It is the users or his/her designated agents responsibility to identify all potential
overpressure scenarios and the method of overpressure protection used to mitigate each
scenario.
(2) It is the responsibility of the user to ensure that the required overpressure protection
system is properly installed prior to initial operation.
(3) If a pressure relief device(s) is to be installed, it is the responsibility of the user or his/her
designated agent to size and select the pressure relief device(s) based on its intended service.

2.3 PSV installation.

Incorrect PSV installation can be another cause of chattering. High inlet pressure drop in PSV
inlet lines will create chattering. Non mandatory ASME Appendix M [5] and API RP 520 [6]
make a strong recommendation that the inlet pressure losses to a PSV should be less than 3% of
the PSV set pressure. The value of 3% is in part based on the typical 7% blowdown. However,
engineering analysis could allow a higher pressure drop.
Blowdown is the difference between the closing and the set pressure, expressed in percentage of
the set pressure. A blowdown of 7% is typical for spring-operated valves. For example, a PSV
with a 7% blowdown and set pressure of 100 psig will reclose at 93 psig. If the inlet pressure
drop is 3% of set pressure, when the pressure reaches 100 psig in the vessel and the PSV opens,
the pressure at the PSV will drop due to friction pressure losses, in this case, to 97 psig. If the
pressure losses are allowed to be higher, there can be a case where the pressure at the PSV
approaches 93 psig and the PSV re-closes (the pressure in the vessel is still 100 psig). With no
flow, the pressure losses become zero, the pressure at the PSV reaches 100 psig again and the
PSV re-opens. This sequence continues multiple times and can lead to PSV destruction or severe
damage. If the PSV cannot be isolated or an alternative is not present to provide relief to the
system, the plant has to be shut down to repair the PSV.
Based on the above explanation of blowdown, an engineering analysis could determine that a
PSV with a 10% blowdown could tolerate with 4 to 5% inlet pressure losses. In 2009, OSHA
started to fine companies for not following the 3% rule [2]. OSHA has stated that inlet losses
larger than 3% may be considered only if an engineering analysis can assure of the valve stability
(will not chatter). This is a significant change and it is recommended to contact the local
authorities to determine the regulatory requirements in each location where plants operate.

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2.4 Communicating with PSV vendors.

Some of the equipment is subject to scenarios that could lead to a combination of liquid, vapor
and two-phase relief. When communicating a specification sheet to a vendor for sizing and cost
estimate, only one very small piece of information is available: information on the sizing case.
The vendor will make his recommendation based on this specification sheet. It is very valuable
to establish a good communication with PSV vendors and to communicate as much information
as possible on the system and the different scenarios. For example, the PSV choice might be
different if you explain that the design case is the only liquid relief scenario and all other
relieving cases are vapour (liquid overfill in an otherwise not liquid full drum). Relieving
temperatures are also an important parameter to discuss, especially if one scenario has a relieving
temperature much different from the other scenarios. The vendor is then in a better position to
provide you with adequate proposal of PSV design. Note that although vendors will have generic
guidelines on material usage based on composition and temperature, the choice of materials is
left to the customer. It is extremely important in this situation to review materials options with
the metallurgist and mechanical engineer

3. Plant Debottleneck and revamp.

3.1 Reviewing or not reviewing existing design.
During debottlenecks, it is common to add a parallel system to one already in place. While it is a
legitimate process to not re-invent the wheel, duplication should be done with caution. It is
recommended to:
Review the appropriate codes so that the new system is built according to the latest
version, not the one in place twenty or thirty years ago.
Perform a review of the process (feed rates, operating conditions, and control strategy),
design (acceptable mechanical stress loadings) and relieving conditions of the existing
system to ensure that the new conditions are within the original design parameters.
Potentially take advantage of new technology and/or requirements to build a more robust
new system.
Relieving systems and PSV sizing documentation should be reviewed during debottleneck
projects even if it appears that no significant change is being made. A simple example is a vessel
for which the worst case scenario is fire. If the vessel inventory remains identical in an existing
vessel, the following statement can be found in justifying the PSV sizing: since the vessel
dimensions and liquid level have not changed, the relieving requirements do not change either.
This may or may not be true.
The original design may have been erroneous.
This may be the nth debottleneck that will overload the system.
A previous project may have not implemented the relieving device required changes at
the time.
Even if flowrates or liquid levels do not change, stream composition changes can
significantly affect relieving rates.
What if the sizing scenario changes? For example, fire case used to be the sizing case and
truly does not change (same composition and liquid level in the drum). However, a

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scenario such as a control valve failure could become the governing case because the
control valve size has increased to accommodate a larger flow.
3.2 Adding a control valve can jeopardize a system.
A simple addition of a control valve can put a system in danger of over-pressure. When adding a
control valve in a unit, a review should be performed to ensure that every vessel is still
adequately protected against overpressure. Control valves are not allowed between a vessel and
the PSV that protects that vessel as per the ASME Code [4]. Figure 1 represents an example
where adding a pressure control valve on an exchanger outlet line effectively isolated the
exchanger from the PSV that was protecting it previously. As per Figure 1, the exchanger is not
protected against overpressure.

Figure 1: Addition of a pressure control valve on a reboiler outlet line, creating a barrier in
the relief path.
3.3 Shaved disks?
In the example shown in Figure 1, it was suggested to shave the disk of the control valve to
provide a path to the existing PSV, now located downstream of the control valve.
This contravenes at least ASME Code UG-135 (b) and (d) [4]:
UG-135 (b)(1) The opening through all pipe, fittings, and nonreclosing pressure relief devices (if installed)
between a pressure vessel and its pressure relief valve shall have at least the area of the pressure relief valve
inlet. The characteristics of this upstream system shall be such that the pressure drop will not reduce the
relieving capacity below that required or adversely affect the proper operation of the pressure relief valve.
UG-135 (d) There shall be no intervening stop valves between the vessel and its pressure relief device or
devices, except:
(1) when these stop valves are so constructed or positively controlled that the closing of the maximum
number of block valves possible at one time will not reduce the pressure relieving capacity provided by the
unaffected pressure relief devices below the required relieving capacity; or
(2) under conditions set forth in Appendix M.

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Note: Appendix M does not allow remotely operated valves (including control valves) under any
circumstances.
M-5.8 Stop Valve(s) Provided in the Pressure Relief Path Where There is Normally Process Flow.
Stop valve(s), excluding remotely operated valves, may be provided in the relief path where there is
normally a process flow, provided ()

The only acceptable use of hole in valves has been found in API STD 521 [3]. For the hydraulic
expansion scenario, the use of a small hole (1/4 in) in block valves is allowed for systems
consisting of piping only. The hole is not a path to a relief valve; it is a way of preventing the
pipeline to be completely blocked in and then be subjected to overpressure due to thermal
expansion.

4. Challenges in plant operation.

4.1 Operating too close to the PSV set pressure.
A PSV will start leaking when the operating pressure reaches 90% of the PSV set pressure (for
spring operated valves). It is recommended to operate below the 90% of set pressure, and 80%
for steam systems. Consistent operation at a pressure close to the PSV set pressure can cause
PSV malfunction such as premature lifting, and seizing.
4.2 Knowing the shortcomings of the PSVs.
Bellows PSVs are recommended when there is a potential for high back pressure. Therefore,
people tend to think that they can work in any case of high back pressure. This is not true. If the
backpressure reaches 60% of the set pressure, the closing force on the PSV is so strong that the
flow will be greatly reduced. This is particularly important with low set pressures (50 psig or
less) relieving into a header that could be subject to high back pressures (25 to 30 psig) due to
multiple devices relieving simultaneously into the header.
The bonnet of bellows PSVs must be unplugged. When most of the PSVs in a plant are of the
conventional type with plugged bonnet, it is possible to be confused and purposely plug a bonnet
thinking it is the right thing to do. Figure 2 shows what happens to bellows when the PSV
operates with the bonnet plugged. Some of the solutions are to identify bellows PSVs in the plant
with a sign reinforcing that the bonnet must not be plugged. A simple information sheet like
Table 3 could be posted in operators shelters and in control rooms as well.
Table 3: Major spring-operated safety valve vendors and how the model number reflects
the type of PSV.
Farris
Consolidated
Crosby

Conventional
A or C following the orifice designation letter
e.g., 26JA11-121
Any series, including 1900 followed by 00
e.g., 1905-00LC-1-S4
JOS series
e.g., 1D2-JOS-E-12

Bellows
B or D following the orifice designation letter
e.g., 26JB11-121
1900 series only, and 30 or 35 present in model
number
e.g., 1905-30LC-1-S4
JBS series
e.g., 1D2-JLT-JBS-E-22

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Figure 2: A damaged bellows after the PSV lifted with a plugged bonnet.

4.3 Not recognizing when a PSV opens.

If the PSV is piped to a flare line and the relief is small and does not affect operating conditions
much, it may be hard to detect when a PSV opens. Engineers and operators cannot check every
pressure data for every minute of the day to provide this information. However, in certain
instances, it can be important. Start-up can be a time when engineers need to monitor plant data
to check if PSVs are lifting.
For example, if a pilot-operated relief valve is installed on a stream known for not being clean, a
filter can be added on the pilot line to ensure that debris do not plug the pilot. In this case,
pressure spikes should be reported so that the filter can be cleaned each time the PSV opens. If
the filter plugs, the PSV will fail safe and it will open, even if there is no overpressure. This is
more an operating issue than a safety concern.
4.4 Alternate relief.
When a PSV must be serviced and isolation is possible, it can be removed while the unit is online provided the equipment remains protected against overpressure. The most straightforward
means of alternate relief is a twin or spare PSV that is put on-line when the main PSV is taken
off-line. Other means can be used, but any alternate relief must comply with the ASME code as
much as any PSV. Other than making sure that the alternate relief is at least of the same size
and has the proper set pressure, the following points should be reviewed in order to comply with
the ASME Code [4]:

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The opening through all pipes and fittings shall be at least the same as the alternate PSV
inlet nominal size.
There shall be no control valve in the path
The pressure losses between the equipment being protected and the PSV should be less
than 3% of the PSV set pressure.
Block valves can be present as defined in Appendix M of the ASME Code [5].
This list is not exhaustive but reflects some of the minimum requirements.

5. Inspection and reliability.

Inspection and reliability groups are usually called upon when a PSV has been found deficient.
However, those groups possess a lot of information that is useful for design and operation.
Information usually detained by inspection groups includes:
Statistical data on existing PSVs, tests reports, when a set point has been changed,
damage found during maintenance.
Reports on potential causes of failure when PSVs have been found damaged or have
malfunctioned (premature lift, failure to re-close)
Maintenance reports that can lead to metallurgy recommendation.
Risk-based evaluation of PSVs should be done before determining if the testing/maintenance
frequency of a PSV can be diminished, but is not necessarily enough. Increasing the time
between preventative maintenance/inspection can lead to significant step up in the risk of loss of
process containment due to overpressure at the plant level [7]. Design and operation engineers,
as well as reliability and process safety experts should contribute to the assessment.
Inspection and reliability may be a small, but it is a strong link in the PSV lifecycle chain and it
should be used as much as possible by design and plant engineers.

6. Conclusion
A PSV is a relatively small, static piece of equipment that does not always get the attention it
deserves. In day to day steady state life of a plant, PSVs are not needed, and therefore are
ignored. However, PSVs operate only during abnormal situations, and have to respond to large
sudden changes in pressure. Therefore they are subject to more aggressive conditions than other
type of instrumentation. Their failure may lead to catastrophic consequences and therefore PSVs
should be made a priority in design, operation and reliability efforts.

7. References
[1] C. Berwanger, R.A. Kreder, W-S. Lee, Analysis identifies deficiencies in existing pressure
relief systems Process Safety Progress, Vol 19, No. 3, pp.166-172, 2000.
[2] D. Smith, J. Burgess, C. Powers, Relief device inlet piping: beyond the 3 percent rule
Hydrocarbon Processing, Nov 2011, pp 59-66.
[3] API STD 521/ ISO 23251 Pressure-relieving and Depressuring Systems. Fifth Edition.

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[4] ASME/BPVC Section VIII Division 1, Rules for construction of Pressure Vessels, UG-125
to UG-140 Overpressure Protection, 2010.
[5] ASME/BPVC Section VIII Division 1, non-mandatory Appendix M, Installation and
operation, 2010.
[6] API RP 520 Part II Sizing, Selection, and Installation of Pressure-Relieving Devices in
Refineries. Part II - Installation, 2011.
[7] ] S. Urbanik, Evaluating Relief Valve Reliability When Extending the Test and Maintenance
Interval Process Safety Progress, Vol 23, No. 3, pp.191-196, 2004.