The mitigation conundrum: when reducing one hazard may increase another

Filippo Gavelli, Ph.D., P.E. Principal Engineer, Head of Dispersion Consulting, GexCon US Scott Davis, Ph.D., P.E. Principal Engineer, President, GexCon US AIChE Spring Meeting 13th Topical Conference on Natural Gas Utilization San Antonio, April 28-May 2, 2013

Abstract Siting regulations for onshore LNG facilities in the United States require the consequences of credible accidental scenarios to be confined within the facilitys boundaries that is, no harm should occur to the public or public property from the worst credible events. Compliance with regulations based on worst credible events is often challenging and may require mitigation methods. One example is that of vapor barriers being used to control the dispersion of a flammable cloud from a release within the facility, in order to keep the cloud from extending beyond the property boundaries before dissipating below -LFL. However, using barriers to keep the flammable cloud from dispersing too far downwind is likely to result in a larger volume of gas remaining near the release location and possibly within congested areas inside the facility. This may therefore increase the hazard footprint from the worst credible overpressure scenarios. Similarly, the flow obstruction posed by the barriers may decrease the air flow through the area increasing the overpressure hazard from smaller releases. Since small releases tend to occur more frequently, increasing their potential severity is likely to increase the overall risk to which facility personnel are exposed. Fortunately, not all barrier installations will have an adverse impact on overpressure hazard and/or personnel risk. This paper will examine the impact of vapor barriers on overpressure hazards for different barrier configurations. The case study will apply CFD modeling to realistic scenarios, inside a detailed 3D model of a typical LNG liquefaction facility. Introduction The siting of LNG facilities in the United States is regulated by prescriptive requirements for the hazard analysis. The tacit rationale behind prescriptive (or deterministic) regulations is that there may be no hazard to the public or public property in the event of an accident. Since it would be effectively impossible to protect the public against

cataclysmic events to nearly any kind of facility (the example of ground-splitting earthquakes has been used in the past to argue against the safety of LNG terminals), one of the critical parts of prescriptive regulations is the definition of the maximum credible event (MCE - even though that term is not explicitly used in the regulatory language). Facility developers need to demonstrate that the hazard footprint, to specified threshold levels, for any accidental scenario of magnitude up to the MCE. Over the last several years, and particularly since the recent market changes led to numerous LNG export facilities being proposed in the United States, the criteria for the selection of the MCE have evolved significantly: in addition to the "design spill" defined in NFPA 59A, which was the only scenario required for LNG import facilities until a few years ago, "flashing and jetting" release scenarios for both LNG and flammable refrigerants (if used) are now also required to be evaluated. Accidental leaks selection criteria have not yet been codified in the regulations, therefore, analysts currently need to rely upon practical guidance from regulatory staff. Practical Scenarios Even though every facility is different, flashing and jetting MCEs in excess of 100 kg/s are rather common. For these scenarios, the hazard distances for unimpeded vapor cloud dispersion is likely to extend beyond the property boundaries. In these cases, prescriptive regulations allow the use of passive mitigation measures in order to control the vapor cloud dispersion and thus ensure that the hazard footprint from the MCEs will not extend beyond areas under the facility owner's control. The most common vapor dispersion mitigation measure adopted is that of vapor barriers. Therefore, most LNG facilities being proposed in the United States currently require one or more sets of vapor barriers to ensure public safety according to the regulations. In certain cases, facilities have been able to demonstrate that installing a single row of vapor barriers along, or just inside, the property boundaries is sufficient to meet the regulatory requirements for vapor dispersion hazards. This is generally the case when there is sufficient distance between the accidental leakage source (e.g., high-pressure piping within the liquefaction area) and the boundary, so that the flashing jet release loses much of its momentum before reaching the barrier; the low-momentum, dense vapor cloud is unable to climb the barrier and instead spreads laterally along the length of the fence, remaining within the facilitys boundaries. Figure 1 shows such an example: the vertical cut plane through the vapor cloud shows a small increase in thickness as the cloud reaches the barrier, pushed primarily by the wind (as for a cloud produced by vaporization of a liquid spill).

Figure 1. Low-momentum vapor cloud, contained by fenceline barrier

There are, however, situations in which the flashing jet release from an accidental leakage source reaches the vapor barrier with significant residual momentum. In these cases, the vapor cloud will manage to jump the barrier and spill over the opposite side, as shown in Figure 2.

Figure 2. High-momentum vapor cloud, not contained by fenceline barrier

If the barrier is located along, or just inside, the property line, the barrier will be inadequate to control the vapor cloud dispersion in compliance with regulatory requirements. Potential solutions include: a) raising the vapor barrier height, or b) adding a second row of barriers between the leakage source and the property line. The barrier height necessary to control a momentum-driven dense vapor cloud can exceed 30 ft and become very expensive, due the need to sustain high wind loading, earthquake vibrations, etc. Therefore, adding a second row of barriers is often considered the most practical solution: the inner row intercepts the vapor cloud from a flashing jet release and reduces its momentum by forcing it to jump over the barrier; the inner row also reduces the mass flux of vapor that reaches the fenceline barrier. When the cloud reaches the fenceline barrier, it is smaller and with less momentum, making it possible for the barrier to contain it; in some cases, proper placement of the first barrier may render the fenceline barrier unnecessary, as shown in Figure 3.

Figure 3. High-momentum vapor cloud, contained by two rows of barriers (the fenceline barrier is not strictly necessary in this case)

The conundrum As shown in the examples above, by design vapor barriers tend to contain the vapor within a smaller area. This however may have an unintended adverse effect, particularly for the more reactive flammable refrigerants, as it may result in larger flammable volumes near the release location, which is often within or close to a congested area (e.g., the gas processing or liquefaction areas). Therefore, the use of vapor barriers to mitigate vapor dispersion hazards can at least in principle increase a facilitys overpressure hazards. In practice, as will be discussed shortly, vapor barriers are not likely to result in increased overpressure hazards for the larger, less probable scenarios that must be evaluated for facility siting purposes; they are, however, likely to increase the hazard footprint of the smaller, more probable accidents. Figure 4 shows an LNG liquefaction train from a small-scale LNG liquefaction facility. For the purpose of this example, the rest of the facility has been removed. Three different cases are considered, to evaluate the effect of vapor barrier location on potential overpressure hazards: 1. The reference case, without any vapor barriers (shown in Figure 4); 2. Vapor barriers on three sides, approximately 25 m away from the edges of the liquefaction train (shown in Figure 5); 3. Vapor barriers on three sides, approximately 10 m away from the edges of the liquefaction train (shown in Figure 6).

Figure 4. Reference case no barriers

Figure 5. Wide barrier spacing (25 m outside process area)

Figure 6. Tight barrier spacing (10 m outside process area)

A frequently used measure of the propensity for gas cloud accumulation within a space is the ventilation rate for a given wind speed and direction; this is often expressed in air changes per hour (ACH). Figure 7 shows the wind velocity vectors for the three barrier configurations, for an external wind at 2 m/s from the west. The vector plots show that the presence of the barriers affects the air flow through the liquefaction area, causing near-stagnant regions; these low-flow areas are more pronounced, as expected, for the tighter fence layout. The ACH rates for these scenarios are listed in Table 1; the values are normalized to the reference case (no barriers).

Figure 7. Wind velocity vectors for the three barrier configurations.

Table 1. Ventilation rates for different barrier spacings

Barrier gap No barriers 25 m 10 m ACH (normalized) 100% 91% 85%

The lower ACH due to the presence of vapor barriers will result, for any given release, in slower dilution of the vapor cloud. This, however, does not necessarily mean that overpressure hazards form the ignition of a vapor cloud will always be worse as ventilation is reduced. For example, Table 2 shows the max flammable volume obtained for a large release (over 100 kg/s) of a refrigerant within the liquefaction train. The results show that adding barriers increases the size of the flammable cloud in the congested area near the release, as the barriers limit the downwind dispersion of the cloud. However, the tighter barrier scenario (10 m out) results in a smaller flammable volume than the wider barrier gap (25 m); this occurs because, for a large release, the lower ventilation rate results in a richer cloud and therefore a smaller portion in the flammable range. In a prescriptive regulatory environment, the largest flammable volume determines the worst-case conditions for overpressure hazards and therefore the 10 m barrier distance would result in lesser consequences than the 25 m case.

Table 2. Max. flammable volumes for a large release

Barrier gap No barriers 25 m 10 m Max. cloud volume (normalized) 100% 119% 108%

Failure data for these facilities indicate that very large releases are very unlikely to occur; the more likely failure scenarios instead are small releases e.g., from valve stem packing failure on the order of 1 kg/s or less. While these releases do not pose a threat to the public, they may pose a threat to personnel safety. Table 3 shows the max flammable volume obtained for a 1 kg/s release of a refrigerant within the liquefaction train. The results show that as ventilation in reduced (tighter barrier spacing) the maximum flammable volume increases and therefore so does the overpressure hazard. This occurs because, for a small release, only a small portion of the cloud remains above the flammable range.

Table 3. Max. flammable volumes for a small release

Barrier gap No barriers 25 m 10 m Max. cloud volume (normalized) 100% 112% 127%

Conclusions This paper examined the potential unintended effects of placing vapor barriers around congested areas of an LNG facility, to control large vapor cloud releases in order to comply with U.S. federal regulations. The analysis showed that, as expected, adding vapor barriers reduces the ventilation rates within the fenced-in area. The ventilation reduction generally results in larger flammable cloud sizes for small releases; the effect on large releases, however, is more difficult to predict and may actually result in smaller flammable volumes as much of the vapor cloud may remain above the flammable range. Since U.S federal regulation require facility siting based on large releases and, for a given fuel and congested area, overpressures tend to increase with the size of the flammable cloud, the addition of vapor barriers to a facility does not necessarily result in a larger overpressure footprint for the LNG facility. However, the overpressure hazards for smaller releases are more likely to be increases, therefore, personnel hazards may be increased. Similarly, if a facility siting were subject to risk-based regulations, the increased consequences from the more frequent, smaller releases may indeed result in a larger risk footprint. Given the large number of parameters that affect ventilation, gas dispersion and overpressures, the reader is cautioned to remember that the results presented in this paper are case-specific. As such, the numerical values and trend reported above should not be applied to any facility in lieu of a site-specific analysis. Author Biographies Dr. Filippo Gavelli is the Head of the Dispersion Consulting group at GexCon and is responsible for GexCons LNG safety consulting business worldwide. He specializes in the analysis of heat transfer and fluid flow phenomena, including multiphase flows and cryogenic fluids. He has over 10 years of engineering consulting experience and 20 years of experience in computational fluid dynamics (CFD) modeling, using several research and commercial codes. He applies his expertise to modeling the atmospheric dispersion of hazardous gaseous releases, and has extensive experience modeling hazard scenarios for Liquefied Natural Gas (LNG) facilities, including vapor cloud dispersion, pool fires and vapor cloud deflagrations; his experience includes more than

20 LNG installations worldwide, including onshore, offshore and floating (FLNG) facilities for LNG import, export (liquefaction) and peak shaving. Dr. Gavelli is a member of the technical committees for NFPA 59A (LNG facilities standard) and NFPA 2 (hydrogen technologies code) and was the lead in the model validation effort that led to FLACS approval by the U.S. DOT under 49 CFR 193. Dr. Gavelli is the lead author of several gas dispersion and explosion safety-related papers and has been a regular contributor to LNG-related technical committees and expert panels for several years. He is a member of the GexCon docents group, which develops and delivers safety seminars to facility owners and operators, safety engineers, and regulatory agencies, on the hazards associated with gas explosions, dust explosions and LNG. Dr. Gavelli is also responsible for software technical support and training for FLACS customers in North America and has provided training to over 100 users, including staff from regulatory and government agencies.

Dr. Scott Davis is the President at GexCon US and specializes in the engineering analysis and testing of combustion, thermal, and fluid processes. Dr. Davis is responsible for fire and explosion related activities, which include post-incident investigative work, worldwide training and experimentation, as well as performing risk assessments and safety studies for offshore and floating oil & gas installations, petrochemical facilities, and various other industries. These studies include explosion risk assessment, blast and venting analyses, assessment of combustible dust explosions, toxic/flammable gas releases and dispersion, hydrogen safety, ventilation, detector placement, and carbon monoxide dispersion with the assistance of the worldleading FLACS software developed by GexCon. Dr. Davis serves on the committee responsible for NFPA 720 Standard for the Installation of Carbon Monoxide (CO) Detection and Warning Equipment and has served on that for NFPA 921 Guide for Fire and Explosion Investigations. He is also a member of GexCons docents group, which develops and delivers worldwide industrial seminars to owners, operators, safety engineers, and regulatory agencies, on the hazards associated with gas explosions, dust explosions and LNG.