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Caution On Uses Of Car Seal Open (cso) To Resolve

Blocked Outlet Scenarios

The short version:
Uses of administrative controls such as car-seal-open (CSO) a valve only eliminate the
scenarios if failure of the administrative control does not result in an overpressure that
exceeds the hydrotested pressure of the equipment. When the equipment does not
have a hydrotested pressure, then stress analysis should be done. MAWP can be used
as the limit instead of the hydrotested pressure.

The long version:

In the past when I consider a blocked outlet scenario, if we can CSO the outlet path,
then I would dismiss the blocked outlet scenario under the basis that if the valve is
CSO, there is no need to consider valve closing during operating.

Similarly, I would do the same thing for a control valves bypass line that is CSC. If the
bypass is CSC, then I do not assume that the bypass will open can cause overpressure.

Someone pointed out that I overlooked the possibility of failure of the administrative
control itself.

The Relevant Standards

After reviewing API 521 6th Section 4.2.2 in the hierarchy of protective measures,
administrative control is at the bottom of the list.

1. Avoiding risk
2. Engineering controls
3. Administrative control

Regarding the administrative control, the spirit of API 521 Section 4.2.2 is:

An administrative control should be used as a protection measure if the

potential overpressure does not exceed the corrected hydrotest pressure

I have been doing this wrong for so long (well, for moths at least). We have the
tendency to recommend CSO to eliminate blocked outlet scenarios and thats not
correct. For example, I recently reviewed a recommendation to CSO a gate valve on the
outlet of a PD pump to avoid blocked outlet scenario. This approach turns out to be
inappropriate. In the event that administrative control failure, the valve does get shut,
the PD can overpressure itself. Like in API 521 6th Section clearly said:

[..]administrative controls can be used to prevent the closed outlet scenario

unless the resulting pressure exceeds the maximum allowed by the pressure
design code [usually the corrected hydrotest pressure is exceeded (see 3.1.22
and 4.2.2)].[..] So now, whether CSO outlet gate valve or not, we still need a
relief device (engineering controls).
Though my next question would be, if we have a HIPS on a control valve that
is used to eliminate the control valve failure, is this considered administrative
control? If so, then should we consider failure of this system and whether
overpressure can exceed the hydrotested pressure of the protected system?
Hopefully this philosophy is not overriding the HIPS credit. Note: The ASME
VIII Appendix M is non-mandatory. Therefore, the consideration of
administrative control failure is only recently made clear to me through API
6th edition.

API 521 6th 4.2.2 Use of Administrative Controls if Corrected Hydrotest Pressure Not
Exceeded Certain pressure design codes allow the use of administrative controls if the
potential overpressure does not exceed the corrected hydrotest pressure, whereas
other pressure design codes do not address this subject. Therefore, applying this for
equipment built to pressure design codes that do not address the issue could cause the
equipment to be overstressed. In these cases, the user should perform mechanical
analyses and/or risk analyses. This philosophy is applied to the following scenarios: a)
closed outlets on vessels (see 4.4.2), b) inadvertent valve opening (see, c)
check valve leakage or failure (see, d) heat transfer equipment failure (see