Pressure Relief System Documentation Equipment

Based Relational Database is Key to

OSHA 1910.119 Compliance
P. C. Bat) Berwanger and R. A. (Rob) Kreder
Berwanger Incorporated, Houston, Texas 77027

Under OSHA 1910.119, all Process Safety Management
(PSM facilities are required to keep theirpressure relief
system design fnformation current. This article demon-
strates why a pressure relid’ system design verification
effort must be based on an equipment list, rather than a
relief device list, in order to ensure that every piece of
equipment i s adequately protected. 7he formerly com-
mon practice of simply checking the design bases of all
existing relief devices is deficient since this technique
does not systematical& ensure that evely piece of equip
ment is protected.
7he “BemiangerMethod” is a step by step processfor
designing or analyzing a pressure relief system to meet
OSHA 1910.119 Process Safety Infomation (PSI) and
Process Hazard Analysis (PHR) mandates. The method
uses a relational database which tracks the relation-
ships between protected equipment, potential overpres-
sure scenarios, and protective devices.
The challengefacing an operating company does not
end once the design basis has been “verified’-the de-
sign basis information must also be maintained and be
readily accessible to avoid costly reinvention of the wheel
down the road. 7he “Bemuanger Method” also ad-
dresses these maintenance issues.
Why the Old Pressure Relief System Data Structure Does
Not Work
To understand why the old pressure relief system data
structure, which is based on a relief device list and a filing
cabinet full of relief device data sheets (see Figure 1) does
not work, take a look at the typical distillation column ex-
ample shown in Figure 2.
Five potential overpressure scenarios have been identi-
fied:
inlet control valve failure
blocked outlet
loss of overhead coolant
reboiler tube rupture
external fire
For these five potential overpressure scenarios, we have a
single PSV.
Thus, this example helps illustrate the natural relation-
ships (i.e. data structures) that exist between pieces of
equipment, overpressure scenarios, and relief devices. Fig-
ure 3 shows that, in general, for each piece of equipment,
there can be one or more overpressure scenarios and relief
devices.

PressureRelief S y s t e m s and OSHA 1910.119: Three Goals

As process safety managers, we generally have three
goals for a pressure relief system as it relates to OSHA PSV Data Sheet
1910.119:
Goal #1: Ensure the plant is adequately protected against
all potential overpressure scenarios.
To ensure protection, we must address all thepG
tential overpressure scenarios associated with
every piece of equipment.
Goal #2: Maintain the safe design as changes are made to
the plant.
To maintain the safe design, we must have a r e
alistic and reliable information management
system.
Goal #3: Implement the verification and maintenance ef-
fort at low cost.
To minimize costs, we must carefully define tasks
and then execute each task with the most e#i-
cient people and tools. FIGURE 1 Traditional relief system documentation.

Process Safety Progress (Vol. 17, No. 1)

Spring 1998 39
 ~
FIGURE 2 Example distillation system.
0
G? Relief Devices
Equipment
Scenarios
FIGURE 3 Relationships between equipment, overpres-
sure scenarios, and relief devices.
Now, let us remove the relief device from the distillation
column example-as illustrated in Figure 4. And then, ask
ourselves a few questions:
If we are verifying overpressure protection in our
plant by working our way down a PSV list, at what
point in this “process” would we discover that a
piece of equipment without a relief device (such as
the distillation column) was unprotected?
Answer: There is not any point in this ‘process”for
determining that a piece of equipment is without
protection.
Where would we store information about potential
overpressure scenarios (that could affect the distilla-
tion column) if there was no relief device?
Answer: We certainly could not store the informa-
tion with the relief device data sheet. However, we
could store the information with the equipmentfile.
If we changed a relief device, does this change the
potential overpressure scenarios?
Answer: No, the potential oueqressure scenarios
would still be there.
In light of the above; does it make sense to use a
relief valve list, rather than an equipment list, as the
basic checklist for relief system verification? Does it
make sense to store potential overpressure scenar-
ios with the relief device data sheets rather than the
equipment?
Answer: No, it doesn %-- but, this is what a lot offolks
have been doing.
A n Equipment Based Data Structure Solves the Problem
The key to resolving our dilemma is the equipment in-
formation form in Figure 5 , which lists protective devices
as well as overpressure scenarios. In we prepare such a
40 Spring 1998
FIGURE 4 Relationships between equipment, overpres-
sure scenarios, and relief devices.
form for each piece of equipment in the plant, we have a
means of tracking all the overpressure scenarios as well as
the protective devices.
With this in mind, a physical metaphor for our relief sys-
tem information would consist of the two filing cabinets
shown in Figure 6. One for equipment information forms
and the other for relief devices.
Of course, it would be even more efficient to store the
relief system design information electronically in a rela-
tional database with the basic structure shown in Figure 7.
In electronic format, we do away with the paper, and the
information can be accessed from a PC and/or over a com-
puter network.
A Step by Step Procedure for Analyzing a Relief System
OK, now we know how we can store and access the re-
lief system design information. The next question, how do
we create the information in the first place? The four step
process described below has proven most efficient for both
new designs and verification of existing facilities.
Berwanger has filed for patent protection of certain aspects
of this process.
Step 1: For each piece of equipment, an “expert” identifies
all potential overpressure scenarios.
This is unquestionably the most critical step in the
process. Only after an overpressure scenario has
been identified by the “expert” can it be ad-
dressed. Table 1 of API 520, “Bases of Relief Ca-
pacities Under Selected Conditions” provides a
widely recognized checklist for this purpose.
For the most part, the remaining three steps can be
reduced to computerized algorithms. Except for
quality control, the “expert’s”work is largely done.
Step 2: For each overpressure scenario identified in Step 1,
quantify the required relief rate.
The required relief rates for the majority of over-
pressure scenarios, such as tube rupture, external
fire, control valve failure, etc.... can be “canned.”
The use of computerized algorithms, so long as
their applicability are subject to the “expert’s” ap-
proval, not only greatly improves efficiency, but
also improves quality and consistency.
Step 3: For each required relief rate in Step 2, verify that
there is a relief device of adequate capacity.
Again, relief valve sizing can largely be accom-
plished with a computer. For years, API 520 has
Process Safety Progress (Vol. 17, No. 1)
 f /- Reviaion Record - - \

Berwanger, Inc. Tag No: V-l

Equipment Information Form NO: 01 Date: 04/19/95 Initials: A A A
Propylene Purification Vessel

Reference Information
Manufacturer: Vessels, Inc. PFD NO: 100-IA
Nat‘l Board No: 4235 m N 0 : 200-IA
I S 0 NO: 300-IA

Equipment Description
Type: Vettical Vessel (Cylinder) HeighULength: 200 A
Material: Carbon Steel
Mode: Contlnuous Equip volume: 400 0 A3
contents: Om-Purne Fluid Volume: 4000 A3

Conditions
Normal Operating Pres: 350 PS% Normal Operating Temp: 150 d egF
-
Max. ODeratine Pres: 360 .D S I Y- Max Operating Temp: 150 degF
Max. Working Pres: 400 PS% Max Working Temp: 150 degF

Is equipment insulated7 Yes Inwl. Mat‘l: I ” Ca Silicate

Is equipment cooled? No Capacity:
Is nuid agitated? No

tquipment Notes

The vessel could be overpressured in the event of thermal expansion due to ambient temperature rise
while the fluid is blocked in. The reliefrequirement is nominal compared to the external fue reliefcase

In the event of an external fup. the initial relief will be flashing liquid. Upon formationof a vapor space,
the reliefwill be vapor. The reliefdevice should be sized forthe case requiring the largest orifice area.

Protective Devices Causes of Overpressure

PSV-I External Fue: V. Vessel w/ Liquid 5t469 lblhr

PSV-2 Failure ofAutomatic Controls: Inlet 25093 lblhr
Thermal Expansion 416.9 lblhr

FIGURE 5 Equipment information form.

provided the basis of most relief valve sizing equa-

tions. More recently, the Design Institute of Emer-
gency Relief Systems (DIERS) has provided more
accurate, and complicated, correlations for two
phase flow situations. All these correlations are
subject to computerization.
Step 4: With due consideration of all the scenarios identi-
fied in Step 2 , and the actual relief device capaci-
ties determined in Step 3, analyze the relief head-
ers.
Having information on all the individual scenarios
quantified in Step 2 available in a relational
database greatly simplifies the process of combin-
ing individual scenarios to arrive at “global” sce-
narios which may be of most concern to the relief
header network.
For example, if one wants to identify all the exter-
nal fire scenarios for equipment in a specific area
FIGURE 6 New relief system files. of the plant-which have the potential to occur si-

Process Safety Progress (Vol. 17, No. 1)

 multaneously-one could query the database for a
detailed listing of scenarios for those pieces of
equipment as well as the effected relief devices.
Likewise for other “global” scenarios such as cool-
ing water failure, or instrument failure.
Rounding Out a Complete Relief System PHA
Insofar as Process Hazard Analyses (PHA’s) are con-
cerned, OSHA 1910.119 does not limit itself to the “en-
gineering” analysis which has been described above. Other
elements which must be addressed are:
hazards of the process (paragraph e.3.i)
0 previous incidents (e.3.ii)
0 engineering and administrative controls (e.3.iii)
consequences of failures (e.3.i~)
facility siting (e.3.v)
human factors (e.3.vi)
qualitative evaluation of safety and health effects
(e.3.vii)
team/employee input (e.4)
The author has addressed these other elements by:
developing a written Process Hazards Analysis pro-
cedure, approved by company management, which
clearly sets forth the scope, requirements, relevant
documents, materials and equipment, and proce-
dure for performing the PHA.
performing operating employee interviews, and
otherwise inviting employees to express their opin-
ions, to ensure that their concerns are addressed
review of previous incident reports
review of previous PHA reports
conducting a plant management review session,
during which, for each concern raised, a qualitative
42 Spring 1998
risk is assessed, a timely plan for resolution devel-
oped, and responsibility for resolution assigned.
issuing a detailed report which is then used to effec-
tively communicate the substance and findings of
the PHA.
SUMMARY
Potential overpressure scenarios exist whether or not re-
lief devices are there to protect the affected equipment. To
ensure that every piece of equipment is protected it is es-
sential that the pressure relief system design verification be
based primarily on the equipment list. The formerly com-
mon method of simply checking existing relief devices is
inadequate since this technique does not systematically en-
sure that every piece of equipment is protected.
It is most efficient to store relief system design informa-
tion in a relational database where overpressure scenarios
and relief devices are associated with the effected equip-
ment. This system can be implemented electronically and
made available across a computer network. Most of the
necessary calculations can be “canned’ which improves
efficiency and quality control.
Relief systems can be designed and documented using
the four step procedure which forms the heart of the
“Berwanger Method.”
Other OSHA mandated Process Hazard elements such as
facility siting, consequence evaluation, and human factors
have been integrated into the “Berwanger Method,” so that
in its entirety, the method can be used to meet OSHA
1910.119 PHA requirements.
mispaper (41d waspresented at the AIChE Spring National Meeting
in Houston, Z, on March 11, 1997.
Process Safety Progress (Vol. 17, No. 1)