CEW Features
Application of UG-140 for Overpressure Protection
It’s a common understanding that for a pressure vessel, pressure relief device is required to protect against
overpressure scenario. In the event of credible overpressure scenario, the device is sized for the scenario.
However, if there are no credible overpressure scenarios, a practice of providing a “token valve” sized arbitrarily
is generally followed. This article addresses the question on whether the relief device is required when there are
no credible scenario and how to meet the code requirements even without providing the pressure relief device.
P
ressure vessel is defined as the vessel
designed above 15 psig pressure.
When the vessel is designed per code
ASME Section-VIII Division-1 (henceforth
referred as code), the requirements of the
code are followed for design, fabrication,
and inspection & testing. ASME coded
vessels are marked with ASME “U” stamp on
nameplate. One of the basic requirements
of the code is to provide overpressure
protection for the vessel covered by ASME
Section-VIII Division-1, UG-125 through
UG-140.
Overpressure protection for pressure
vessel can be achieved by either or
combination of following three options:
1. Relief Device: Requirements of
relief device for pressure vessel are
covered by UG-125 through UG-
138. When the findings of detailed
evaluation of various overpressure
scenarios per API Standard-521
state that there are credible cases
for overpressure, pressure relief
devices are provided and sized per
applicable equations given in API
Standard-521.
2. System Design (Inherently Safe
Design): This option overcomes
the requirement of a relief device
to protect pressure vessel. The
documentation and other specific
requirements of this option are covered
by UG-140(a).
3. Safety Instrumented or High Integrity
Protection System (HIPS): This
option can overcome the requirement
of a relief device in specific cases.
The documentation and other specific
requirements of this option are covered
by UG-140(b).
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The ASME UG-140 requirements and
procedures are commonly known as “Code
Case 2211”. In 2008, ASME incorporated
“Code Case 2211” into the body of
Section-VIII Division-1 as Section UG-
140. All overpressure protection systems
addressed by second or third option or a
combination of second and third require
compliance of ASME UG-140 including
all approvals, responsibilities, analysis
and reviews including documentation and
sign-offs.
Detail Requirements of UG-140 (a)
and (b)
Per UG-140, pressure relief device is not
required to protect a pressure vessel if the
pressure is self-limiting and this pressure
is less than equal to MAWP of the vessel
at coincident temperature.
The major requirements of UG-140 are
Detail analysis of various overpressure
scenarios; Multidisciplinary team review;
Risk assessment in the event of credible
scenarios; Manufacturer data report to
state the system protected by design; and
Documentations & signoffs.
1. Detail analysis of various credible
scenarios: API Standard 521,
Pressure-Relieving and Depressuring
Systems, describes “Causes of
Overpressure”. Other standards or
recommended practices that are more
appropriate to the specific application
may also be considered. The typical
overpressure scenarios that need to
be analyzed are Loss of cooling water or
cooling medium, Loss of power, Loss of
steam, Loss of instrument air or electric
supply failure, Individual control valve
failure, Inadvertent valve operation,
Blocked outlet, Individual equipment
failure, Loss of air cooling, Thermal
expansion, Heat exchanger tube rupture,
Fire case, Liquid overfill, Gas Blow by
Reactive hazard
All the scenarios shall be evaluated with
detail explanation to identify whether
the scenario is applicable and if it is
applicable how the pressure reached in the
scenario is less than MAWP of pressure
vessel at co-incident temperature. All
the relevant documents such as Piping
and Instrumentation Diagrams (P&IDs),
Process Flow Diagrams (PFDs), Equipment
General Arrangement (GA) Drawings,
Equipment Data Sheets, Plot Plan,
Equipment Elevation Drawings, Paving
and Drainage Plans, Process Control
System Documentations, Instrument Data
Sheets and Material Safety Data Sheets
(MSDS) of chemicals involved etc. shall be
used to evaluate credibility of overpressure
scenarios. All the relevant documents shall
be attached as a part of documentation.
2. Multidisciplinary team review: The
documentations shall be reviewed and
evaluated by multi-disciplinary team
of people including Process Safety
engineer, Process Technology Leader,
Manufacturing Representatives,
Process Engineers and Relief Design
Subject Matter Experts (SME).
3. Risk assessment in case of credible
overpressure scenario: For a pressure
vessel, if a scenario is found to be
credible for overpressure, then risk
associated with the event shall be
judged to decide whether or not the relief
device shall be provided. The design
shall comply with local regulations and
owner’s risk tolerance criteria. This
approach is scenario specific and if
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CEW Features
it can be justified that having a relief
device does not benefit then one can go
without having a relief device even when
the case is credible for overpressure. To
illustrate, examples can be as follows:
• If fire scenario is applicable to a
pressure vessel operating in gas
service, pressure relief device is of
no help in protecting the vessel as the
vessel ruptures due to overheating
before the pressure reaches the set
pressure of relief device.
• The pressure vessel is empty and fire
case is applicable, relief device is of Figure1: Example of System Architecture for HIPS
little help for the same reasons.
• Pump Seal pots: Consider 5 gallon U High Integrity Pressure Protection Integrity Protection System) used to
stamped seal pot is provided for API System (HIPS) limit the system pressure, including the
pump and fire case is applicable. During a Industrial use of HIPS is to reduce the identification of all truly independent
fire, the seal pot will likely fail, regardless pressure relief device’s size for specific redundancies and a reliability evaluation
of whether it has a PSV, and regardless scenarios. It is not intended to drive the (qualitative and quantitative) of the
of that PSV’s size. For vessel size being complete removal of pressure relief devices. overall safety system shall be provided
that small, a fire-sized PSV will quickly However, in specific cases, use of HIPS as part of UG-140 documentation.
result in the seal pot being emptied can lead to elimination of relief device. HIPS finds its use in complex process
of liquid. Once the liquid is gone the The documentation and other specific applications. For example, the application
vessel will fail due to excessive heating
requirements of this option are covered by of HIPS is for a reactor o perating at high
(excessive wall temperature). Thus, a
UG-140(b). temperature and pressure conditions
PSV can’t adequately prevent this vessel
where coolant is circulated to remove
from failing during a sustained pool fire.
HIPS typically involve an arrangement exothermicity of reaction and loss of
of instruments, final control elements coolant would lead to high temperature
One can go with UG-140 documentation
(e.g. valves, switches, etc.), and logic rise leading to runaway reaction or boil
for such cases.
solvers configured in a manner designed up of coolant. In such application, HIPS
4. Documentation and Sign off: All to avoid overpressure incidents by is used to cut off the feed once coolant
the involved parties shall sign off the removing the source of overpressure flow is stopped.
document to conclude and certify that or by reducing the probability of an
the vessel is protected by system design overpressure contingency to such a low The table (on the next page) can be used as
and in no credible event the pressure will level that it is no longer considered to reference when making a choice between
exceed MAWP at coincident temperature. be a credible case. With appropriate the options to be followed for overpressure
5. Manufacturer’s data report to state levels of redundancy, a HIPS can be protection of pressure vessel while meeting
the system protected by design: designed to achieve a level of availability code requirements.
Annexure-W of ASME Section- equal to or greater than a mechanical
VIII Division-1 provides details of relief device. Example of Pressure Protection of a
Manufacturing Data reports. UG-140 Pressure Vessel Operating in Chlorine
requires that manufacturing data report A detailed description of any safety Service by System Design (UG-140 (a)) (See
shall mention that the vessel is protected critical instrumentation (HIPS-High Figure 2 below)
by system design. Typically, vessel
manufacture provides data report and
this requirement is mentioned in the
notes section of the report. To the data
report, a U-1 or U-1A form is enclosed.
Typically, U-1 or U-1A form should say
“Overpressure protection is provided
by others per UG-140 (a) or (b). OSHA
inspector is likely to see this form to
check for overpressure protection of the
vessel when the ASME code stamped
vessel is not provided with a pressure
relief device. Figure 2: D-101 Schematic

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CEW Features
Equipment / System Protected
D-101 (Chlorine gas knock out drum)
MAWP @ Coincident Temperature
21.5 barg / FV @ 190 °C
System Information
1.1 Protected Equipment : D-101
1.2 Fluid HandleD : Chlorine
1.3 Operating Pressure / Temperature
: 6.5 Barg / 50°C
Description of Overpressure Scenario
1. Loss of Cooling Water or Other
Cooling Fluid: No cooling is supplied
to D-101. Hence, the case is
not applicable.
2. Loss of Power: There are no power
operated equipment associated
with D-101. Hence, the case is not
applicable.
3. Steam Failure: No steam is associated
with D-101. Hence, the case is
not applicable.
4. Instrument Air / Electrical Supply Failure: In
the event of instrument air failure, following
valves shall close as failure position being
Fail Closed. [Inlet of D-101 - 1. EBV-01:
Closure of the valve shall lead to loss of
chlorine gas flow to D-101. Hence, there
shall be no overpressure. Outlet of D-101 -
1. FCV-01 / EBV-02: Closure of the valves
shall not lead to overpressure as chlorine
gas flow to D-101 shall be lost due to
closure of EBV-01.]
5. Individual Control Valve Failure: Failure
Opening of FCV-01: The valve is located
on vent outlet of D-101. The case of
failure opening of control valve shall
result in no overpressure to D-101 as
the valve shall provide open path to
downstream system.
6. Inadvertent Valve Operation: Failure
closure of FCV-01: Failure closure of
the valve shall not result in overpressure
as MAWP of D-101 is higher than the
maximum pressure of chlorine gas at
battery limit which is 9 barg.
7. Individual Equipment Failure: There are
no mechanical equipment associated with
D-101. Hence, the case is not applicable.
8. Loss of Air Cooling :No air cooling
is provided for inlet and outlet
streams of D-101. Hence, the case is
not applicable.
9. Blocked Outlet: Refer to Case 6.
No overpressure.
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Pros and Cons of Relief Device, Safe Design and HIPS UG-140 (b)
Relief Device
Pros
1. Commonly used
2. Highly reliable
3. Designer feels confident
with functionality
4.Standalone Mechanical device
5.Can handle runaway reactions
Cons
1. Requires maintenance
2. Can plug in heavy service
3. Requires disposal system
downstream for safe handling
4. When not used in
combination of HIPS, may
require bigger disposal
system such as large flare
headers and scrubbers
5. Not desirable in toxic services
6. Cannot provide protection
against excessive temperature
Table1: Comparison of Options for Overpressure Protection , (*) Fire case is not considered as a process upset scenario.
10. Gas Blow Through:The case is
not applicable.
11. External Fire: Per Equipment GA
drawing, the equipment is located above
fire height of 7.6m. Hence, overpressure
is not credible.
12. Exchanger Tube Rupture: D-101 is
not connected to any heat exchanger.
Hence, the case is not applicable.
13. Liquid Overfill: D-101 is operating in
gas service. Hence, the case is not
applicable.
14. Thermal Expansion: D-101 is operating
in gas service. Hence, the case is
not applicable.
15. Vacuum: D-101 is designed for full
vacuum. Hence, the case is not deemed to
be credible.
16. Runaway Reactions (Reactive Hazards): No
reactive hazard is associated with D-101.
Hence, the case is not applicable.
17. Any Other: Low pressure nitrogen can be
hooked up to D-101 during maintenance
Inherently safe design HIPS
UG-140 (a) UG-140(b)
Pros Pros
1. Safest way of design 1. Availability / Reliability
2. Eliminate relief device 2. Eliminate relief device and
and associated associated disposal system
disposal system 3. Suitable for toxic services
3. Preferred option for 4. Can eliminate overpressure
toxic services scenarios such as runaway
reactions
5. Can provide protection
against excessive
temperature due to process
upsets (*)
6. Useful when environment
restrictions and safety
constraints limit the venting
Cons Cons
1. Higher design pressures 1. Maintenance, testing and
2. HIPS needs to be used inspection
in combination to handle 2. Complex systems
runaway reactions 3. Expensive systems
and protection against
excessive temperature
3. Designer needs to
meet requirement of
UG-140 by way of
documentations, reviews
and sign-offs
activities. However, maximum operating
pressure of LP Nitrogen is 7 barg which
is less than MAWP of D-101. Hence,
overpressure is not credible.
Safety Critical Instrumentation And
Reliability Evaluation
For D-101, no safety critical instrumentation is
used for purpose of overpressure protection.
Hence, this section is not applicable. As
detailed evaluation of possible overpressure
scenarios suggests that in no case the
pressure can exceed MAWP of D-101, it
can be concluded that pressure is self-
limiting and D-101 is protected by system
design. Hence, no relief device is required
for overpressure protection.
Conclusion
In certain services, having Pressure relief
devices adds to issues related to leaking
and maintenance due to plugging. If it
can be justified that the pressure vessel
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CEW Features
is designed to withstand all credible scenarios, UG-140 comes
handy to meet the requirements of the code. In toxic services Contribute in CEW
such as phosgene, it is desirable to protect the vessel by system
design and/or by employing HIPS system. Pressure relief devices
operating in phosgene service require proper disposal system
and may create operational hazards. These devices also require
critical procedures in place for inspection and maintenance.

HIPS typically finds its application in critical process operations

handling hazardous services. On the other hand, having a relief
device on the vessel provides a kind of insurance for the vessel.
Decision to have a relief device to protect the vessel depends
upon number of factors as service it is operated with, type of
overpressure scenario and experience of engineers working with
the technology. As there are number of factors which influence Dear Readers,
the decision making to protect the vessel and the decision being
scenario specific, its users responsibility to decide the option to Chemical Engineering World (CEW), the
be followed for overpressure protection keeping in mind that the Official Organ of CHEMTECH Founda�on, is
code permits not to have a relief device by way of UG-140 provided
India's premier technology magazine for the
the detail evaluation is performed and analysis is documented to
ensure no hazardous situation would arise due to overpressure that
chemical process industry professionals. This
may lead to loss of containment or risk to operating personnel. highly reputed monthly publica�on provides
novel insights on the dynamics of Indian and
References global process industries. CEW, a niche
1. Pressure-relieving and Depressuring Systems, ANSI/API Standard publica�on with proven track record, has
521, Fifth Edition, January 2007, Addendum May 2008. been dissemina�ng authen�c informa�on on
2. ASME Boiler and Pressure Vessel Code VIII, Division 1, Rules for
process industry innova�ons for more than
Construction of Pressure Vessels, Edition 2010
four decades.
Definition of Terms
1. Design pressure: Pressure, together with the design temperature, You can contribute in the magazine with
used to determine the minimum permissible thickness or physical technical ar�cles, case studies, and product
characteristic of each component, as determined by the design rules write-ups. The length of the ar�cle should
of the pressure-design code
not exceed 1500 words with maximum three
2. MAWP: Maximum gauge pressure permissible at the top of a
completed vessel in its normal operating position at the designated
illustra�ons, images, graphs, charts, etc. All
coincident temperature specified for that pressure the images should be high-resolu�on (300
3. Overpressure: Pressure increase at the relief valve inlet above the DPI) and a�ached separately in JPEG or JPG
set pressure, when the relief valve is relieving (Overpressure is format. Have a look at our editorial calendar
expressed in pressure units or as a percentage of the set pressure.) on the website – www.cewindia.com.
4. Relief device: Device used to relieve excess pressure and/or vacuum
that has developed in a tank
To know more about Chemtech Founda�on,
5. Set pressure: The inlet gauge pressure at which pressure relief valve
is set to open under service conditions
Jasubhai Media and other publica�on and
events, please visit our website –
www.chemtech-online.com

Thank you,
Regards,
Mi�ravinda Ranjan
Editor
Author’s Details
Sushant G Labhasetwar (P.E)
Jasubhai Media Pvt Ltd
Assistant Manager - Process Engineering Team Tel: +91 22 4037 3636 (Dir: 4037 3615)
Daelim Industrial Corporation, Seoul Korea E-mail: mi�ra_ranjan@jasubhai.com
Email: sushant@daelim.co.kr

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