Propose Dep z Requirements Eub March 162004

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    Proposed Requirements forCalculating Emergency Planning

    Zones for Sour Wells, Sour

    Pipelines and Sour Production

    Facilities

    Presented by:Gary Neilson BSc(Hons) P.Phys

    Public Safety Implementation Team

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    Presentation Outline

    Background

    Proposed new requirements

    EPZ calculation process

    Implications

    Future work

    EUBMODELS Structure

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    Background

    Project initiated to address issues heard

    by Provincial Advisory Committee on

    Public Safety and Sour Gas*

    Proposed EPZ calculation requirements

    based on assessing the hazard footprint of

    a sour gas release using dispersion

    modelling*ProvincialAdvisory Committee on Public Safety and Sour Gas Findings and

    Recommendations Final Report December 2000

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    Background

    In the past, disagreement between

    experts and public about model

    choices and inputs that will lead to

    accurate, useful and credible results

    Difficult for EUB to make informed

    decisions in the public interest without

    full understanding of differences

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    Background

    Draft requirements published mid-December 2003 Early draft February 2002

    Technical workshop & focus groups

    Peer review/EUB testing of EUBMODELS

    Requesting feedback on clarity of the requirements/additional requirements

    the supporting EUBMODELS documentation and software

    March 31, 2004 (extended)

    Requirements will be included in future revision of

    Guide 71 - Emergency Preparedness and ResponseRequirements for the Upstream Petroleum Industry

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    Proposed Requirements

    Address suite of PSSG Recommendations (17,18,19, 58 and 62)

    Define the minimum standards to calculate an EPZto protect public SAFETY (protect against fatalities

    or serious irreversible health effects)

    Replaces the simple release rate based equations (ornomographs)

    EPZ derived from new requirements remains first

    step. Actual size and shape of the final EPZ mustreflect site-specific features of the area

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    Proposed Requirements

    EPZ more realistically calculated characterization of the release (representative gas analysis,

    source conditions at exit calculated, real gas effects)

    dispersion modelling,

    consequence modelling to a toxic load based endpoint

    (concentration AND exposure time important) Credit for PRACTICAL mitigation actions (e.g.limiting release duration through ignition)

    No reduced EPZ as presently defined as single EPZincludes mitigation actionsNO EUB PRE-

    APPROVAL Applicable to new applications, ERP updates ANDinterventions

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    Proposed Requirements

    EUBMODELS (Screening

    Level EPZ Calculation)

    Technical Descriptionsand Formulations

    User Guide & Tutorial

    Software Package

    REQUIREMENTS

    (Minimum Standards)

    Sour Gas Release RatesGas composition

    Depressurization (REAL GAS EFFECTS)

    Release Duration

    Dispersion Modelling

    Meteorological ConditionsConcentration Fluctuations

    EPZ Endpoints

    Base CaseMANDATORY

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    Release Rates

    For wells maximum release rates required asdescribed in Guide 56

    For pipelines mass release rate profile from a

    guillotine break must be calculated using themaximum licenced pressure

    account for the emergency shutdown valve (ESD)

    trip set points

    the distance between ESD valves mass of gas in adjacent pipeline segments that

    escapes before the valves close

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    Depressurization - why are real gas

    effects important?

    Ideal gas laws under predict EPZ

    Real gases can form liquid aerosol as theyexpand and cool

    Well releases are sensitive to wellhead exit

    conditions (pressure, temperature, holediameter)

    More detailed calculation may result in buoyantrelease

    Pipelines usually dense due to pressures EUBMODELS Base Case always dense release -

    CONSERVATIVE

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    Release Duration

    Duration defines exposure time Duration for wells must be realistic for the scenario

    (drilling, servicing or producing) and other site-specific factors

    Duration for pipelines determined by transient mass

    release through a guillotine break Countermeasures such as ignition that limit theduration of the sour gas release are permissible(documented and PRACTICAL)

    For pipelines ignition not allowed as acountermeasure

    releases not typically long enough for manualignition

    self-ignition not guaranteed

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    Dispersion Modelling

    Worst case Met conditions assumed Dispersion model used must account for

    real gas effects

    dense or buoyant releases

    For dense plumes parallel airflow model is acceptablebecause a sour gas release from a well or pipelineoccurs at or near ground level

    Plumes that rise complex terrain model may be required

    EUBMODELS Base Case must still be included in the

    documentation supporting an EPZ calculation as well asthe calculation using a complex terrain model forcomparison purposes

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    criterion

    complex

    parallel

    Requirements now address issues of terrain Buoyant releases may require complex terrain

    modelling

    Compare terrain elevations in EPZ to terrain criteriadefined in EUBMODELS

    Criteria based on EUB Guide 60 (Flaring) kinetic energy lift sufficient to overcome temperature

    gradient

    Complex Terrain Criterion - H2S

    Releases

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    Toxic Load End Points

    Endpoint described by toxic load criterion L=KCnt

    same adverse effect for low concentration overlonger time as high concentration for short time

    concentration weighted (n) K accounts for concentration fluctuations

    (dispersion models only predict averages)

    Objective of endpoint is to provideconservatism to protect public safety (i.e. iflevel achieved would not expect fatality orother serious irreversible adverse effect)

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    EPZ Calculation Process

    EPZ to be

    used for Public

    Involvement

    EPZ tuned to reflect

    site specific features

    EUBMODELS Base

    Case (Mandatory)EPZ pre-approval from

    EUB not required

    EUBMODELS BC

    Parameters varied

    Acceptable

    Acceptable ERP

    EUB

    assessment

    Alternate Methods

    EUBMODELS BC must also be

    modelled using alternate methods

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    Implications

    Anticipate zones will change More effort required than previous simplistic

    approach

    detailed documentation (explaining mitigation

    actions, variation of base case parameters,alternate methods)

    Responsibility on industry to ensure practicalmitigation measures used

    Operational implications (e.g. ESD valve trippoints)

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    Future Work

    Toxic load endpoints need further discussion workshop on H2S toxicity

    objective to assist EUB in selecting safety endpoint

    Ignition timing lower limit needs to be defined workshop planned

    Address stakeholder comments

    Develop implementation strategy withstakeholders depending on impact compared to

    previous methods

    Revise Guide 71targeting fall 2004

    EUBRISK and EUBHVPEUBMODELS canbe adapted possibly undertake in new fiscal year

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    EUBMODELS Structure

    ExcelUSER INPUT USER OUTPUT

    EUBFlash EUBSlab

    EUBMODELS

    Sp read s h eet Sp read s h eet

    Runs 54 times

    for met matrix

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    Summary of PROPOSEDRequirements

    Requirements in draftRequirements in Guide 71still apply

    No reduced EPZ application (size of EPZdetermined by varying parameters) - single EPZ canbe taken forward to communities for discussion and

    fine tuning EUB review post public involvement as part of ERP

    assessmentREALISTIC MITIGATION

    Requirements applicable to new applications, ERPupdates or interventions

    Provide clarity to assist in EUB decisions

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    Project Website

    www.eub.gov.ab.ca/BBS/new/Projects/sgr.htm

    [email protected]