Cold vent - emergency operation (un-ignited release)

Specific conditions - • Emergency flow rate • Release direction according

to the tip direction
Criteria - • Toxic gas TLV STEL • LFL Toxic gas LC1% 4.7 kW/m
 Toxic gas IDLH 2.0 kW/m
Degassing vent - normal operation (un-ignited)
Specific conditions -
• Maximum continuous flow rate • Release direction according to the tip
direction
Criteria -
• LFL • Toxic gas TLV TWA
As per API 521 you may decide to discharge HC's or other flammable or
hazardous vapours to the atmosphere rather than flare provided that
following issues not to be occurred:

- Formation of flammable mixtures at grade level or on elevated

structures
- Exposure of personnel to toxic vapours or corrosive chemicals
- Ignition of relief systems at the point of emission
- Excessive noise levels
- Air pollution

Flarenet and flaresim (process calculations)

Cold vent is when relief flows are directed to an unignited flare (we are
not going to burn it but discharge directly to atmosphere). Of course
requirements of safety applied here: the flaretip must be at certain
distance from the platform, the discharge flow will have to reach some
minimum velocity to make sure that the hydrocarbon being discharged
and the air being well mixed and have a ratio lower than the flammable
limit. Those values must be verified by rigorous calculations.

Need to design a new waste gas disposal for our releases that are in fact
only generated in emergencies.
Assumption that a Flare Stack might be the only option is in a way
stringent, recently more close attention to item 4 of API-521 shows that
cold vent stacks could also be an option and, in most cases, even more
appropriated.
Decision to opt for (cold stack or flare stack) and why.
The streams with high BlowDown concentrations to be vented to Flare.

The much larger chemical spheres to be vented to atmosphere.

All safety valves had inlet rupture disks to prevent leakage formation in
the Flare header.

It is my understanding that a pressure relief device can legally discharge

to atmosphere i.e Flare header not required. The main legal issue is
chemicals concentrations at the fence line.
I have seen Flares that were burning chemical at 98% destruction and
the dispersion would violate acceptable fence line chemical
concentrations.

Given the human health issues with (Chemicals), I would never consider
a cold atmospheric vent.
I fully agree with your understanding that streams with butadiene must
be sent to the flare stack to be destroyed to avoid Butadiene emissions to
atmosphere, concerning enviroment and health issues. Our plant, though,
is located in a country where this emissions are still not estabilished by
law.
Instead, our flare will bring us some problems related to NOx emissions
related to purge and pilot natural gas continous burning that are
restricted here by law.
That is why we are evaluating the cold stack, but I tend to use as design
basis the explosive limits in our fence to calculate the height of the cold
stack.
As you mentioned health issues, could you please tell me what criteria
should I adopt in my fence limits?

I think that cold vents should be considered for all applications, where
sufficient distance to the vent is not a problem.
It should always be in combination with a flare - e.g. a ground flare for
use when a planned blow down is required e.g. for maintenance.
Now I can do my calculation (stack height) using the following three
criteria:

1) 300 ppb at site fence;

2) 2 ppm at grade floor of the stack (inside the plant);

3) 2% v/v (explosive limit at ground)

With an OSHA limit of 1 ppm (so monitoring and medical surveillance at

>0.5 ppm?), destruction by flare would seem the only option.

Atmospheric venting of heavier than air hydrocarbons is also prohibited

by a number of major petrochemical companies.

EGASPIN 2018 law

5.3.9.2 Cold Venting Cold venting of natural gas or any gas derivatives to
the environment during system depressurization and/or system operation
under emergency or maintenance is hereby prohibited. All gas being
released during the above operations shall be routed to flare and the
conditions under Section 5.3.9.1 shall apply.

5.3.9 Gas Flaring 5.3.9.1 Gas flaring is prohibited. However, should the
licensee/operator be constrained to flare gas due to operational
exigencies such as:- a) Planned operational flaring due to scheduled
maintenance, equipment shutdown, well completions, work-overs,
combustion of gas to maintain flare pilot, etc.; b) Unplanned operational
flaring due to mechanical equipment failures, instrument failures and
difficulty restarting well production. c) Safety flaring to purge flare lines
with hydrocarbon gas for safety purposes. d) Etc,

the following conditions shall be met:

(i) An appropriate waiver and a permit to flare the gas shall be
issued by the Director of Petroleum Resources.
(ii) (ii) The flared gas shall attract appropriate fine for every
standard cubic meter flared, in accordance with existing laws.
(iii) (iii) Pre-treated ‘clean’ gas shall be burnt and the flare shall be
luminous and bright (i.e. show complete smokeless combustion
at operating gas flow rate). The relative density of emitted
smoke shall not exceed two Ringelmann Number which is
related to 40% of smoke density and 60% of light transmission
through smoke – observed over a period of one (1) hour.
(iv) (iv) The allowable heat radiation at ground level is 4.73 kw/m2
(1500 BTU/ft2h) during maximum flaring at a distance of 60m
from the base of the flare.
(v) (v) A maximum sterilised approach distance of 60 meters radius,
measured form the base of the stack shall be maintained. No
 other equipment except that related to the flare itself shall be
located within this area.
(vi) (vi) The noise levels for unprotected ears at 60m radius from the
flare stack shall be well within the threshold of pain (80-
100dBA).
(vii) (vii) Systems that can reduce carry over due to over pressure
shall be considered (e.g. High Integrity Pressure Protection
System – HIPPS, Over Pressure Protection System – OPPS, and
quick closing valves.
(viii) (viii) Purging of the flare headers shall be designed to minimise
emissions to air, by considering e.g. ▪ A closed loop
hydrocarbon purge gas system ▪ Use of nitrogen gas as purge
gas.
(ix) (ix) Relief valves blow down valves and control valves to flare
shall be closed during service and leakages minimized.
(x) (x) The maximum period allowable should not exceed 24 hrs or
as may be determined by the Director of Petroleum Resources.