Flare- Single Flare for LPG and LNG Storage

Ramzi Fawaz e mail to Rob Klein Naglevoort

Message in caps is by A Aranda

This is to confirm our discussion of today, we request that you

attend a Process Coordination Meeting at Kellogg's Offices at
Greenford on Tuesday Oct 27 starting at 10:00 am. Since Greg
would not be here on that day suggest that one or more of our
home office process engineers (Gary,Steve, Pieter) also accompany
you.

LPG Storage Flare: Is it safe to combine the LPG/LNG storage

flares.

** THIS IS A SAFETY ISSUE, AND I NEED HOUSTON, CHIEF ENGINEER

POSITION.

TO MY KNOWLEDGE WE HAVE NEVER DESIGNED A TANK LNG FLARE, ( LOW

PRESSURE) THAT COMBINE C1, C3 AND C4.

THE INITIAL SCHEME HAS C3 AND C4 AS A SEPARATE FLARE FROM C1,

NOW THE CLIENT WANTS TO COMBINE THEM IN ONE FLARE.

I AM NOT COMFORTABLE SO WE TOLD THE CLIENT THAT:

* WE ARE PROCEEDING TO DESIGN A SEPARATE C3,C4 FLARE

* IN THE INTERIM REQUEST ADVISE FROM HOUSTON

THE CLIENT HAS ACCEPTED OUR RECOMMENDATION FOR NOW.

A Arande response

This is an e mail form our resident cleint to the hague.

Charlie and Don, this is an important meeting, so I wish to

request that at least one of you attend.

I understand that Don will be out of town by then,

I also need Urey posiiton on the flare issue.

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Please contact Royle/Styels for more info

Please let us know your plans.

A Aranda response
ulian Royle for more info, thanks

3. C1.C3.C4 combined flares.

I have discussed this issue with my client, and he has agreed

that a KBR position would be useful, specially since we are
working on a fast track basis, both SIOP and us do not want to
make the wrong decision on such an important issue

However it appears that I am personally on a minority in KBR,

since I am more concerned about the safety issue that Don and
Urey.

Therefore I will need a clear KBR posiiton from Urey by 23 Oct.

Urey you can call Julian Royle to get more info,but the issue is
realy straight forward

ie: Does KBR recommends to combine LNG and LPG cryo low pressure
tankage into one single flare , or not ? considering the
realities of simultanous ship loading in 2 separate jetties of
LNG and LPG, in Nigeria, with Nigerian operators.

The issue is fairly simple, ie are we confortable mixing lng

vapors (-100 to - 160) that can be released simultanously with C4
vapors at (-10) what happens when the C4 is cooled to LNg temp ?

To my knowledge, (and I have worked on most LNG plants for

Kellogg) we have never done it before, that is to combine LNG
and LPG LOW PRESSUE FLARING, so I do not know what experience
Urey is refering to

Nevertheless I will sumit to KBR Chief engineer decision, but I

need Urey position in writing, asap.

We only have one shot at this, so we better be right, because we

will have to stand behind it and guarantee it when we bid the
job LSTK in dec 15, so we cannot have " if and buts" by then

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At this time, there has not been any discussion on the guarantees
that NLNG will be asking/imposing on the Contractor. I've
advised the team here to stick with the design margins that were
adopted on the existing facility as the basis for their cost
estimate/proposal. I believe there is significant uncertainty in
the feed composition to the facility and I've explained to Arturo
that within the process simulation, there is the greatest
uncertainty in the prediction of the scrub column bottoms stream,
i.e., the feed to the fractionation unit. There appears that
there may be some confusion about the reason for some of the
guarantees in the fractionation area (e.g., the need to design
the overhead and reboiler circuits for operational flexibility to
match the column capabilities).
With regard to the LPG/LNG flare issue, I expect that with
adequate effort we will be able to combine these services into a
single flare. I have mentioned that we need to look into the
problems of condensation and the possibility of freezing.
However, as with some of the streams in Woodside Phase II, we
chose to put some 'wet' streams into the LNG flare to avoid
running the DOMGAS flare header into the LNG train. In our
study, we said there was a possibility that some water could
freeze out, but that the quantities were insufficient to pose a
safety risk. After full consideration I suspect we will reach
the same conclusion with these two tank flare systems, but not a
decision we can take without first doing the work.

I sat in on a meeting between MWKL and NLNG (Greg McLachlan)

where the flare issue was discussed. We pointed out that
combining these two flare services (LNG tank flare with LPG tank
flare) required careful and thorough study, and that there was
not sufficient time to carry out this study in the proposal
phase, but that it would be done as early as possible. He seemed
to accept this, but said that MWKL needed to put that into
writing. NLNG are also concerned that MWKL will waste a lot of
time engineering the two flare design in the PS that will then
have to be changed later (question was asked whether we were just
trying to make more work for the office at NLNG's expense).
However, his biggest concern seemed to be that NLNG had only been
told that we were not going to adopt the revised BOD design basis
of a single flare verbally, and not in writing.

In addition to the liquids and possibly solids issues, we tabled

some operational issues as well. However, these were not
considered by NLNG to be sufficient justification for two flare

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systems. My biggest concern over the flare systems is that we
must not introduce a way that the tanks can be connected up with
a high pressure source that might inadvertently over pressure the
tanks.

I hope this clarifies the issues a little.

19 Oct 98 U Miller e mail

I had not seen the below message until Judy sent it on 16

October. It is not clear, from the messages below, what the
exact safety concerns are. It is not unusual, nor inherently
unsafe, to mix C1, C2, C3, and C4 into a common flare system. We
do this for other processes.

In order for us to address the safety issues related to this

matter, please have the process folk provide additional
information specifically related to their concerns about the
safety of the flare system. We then can evaluate and comment.

LP Storage Flare - I discussed this at length with Don, and we

agreed that the odds of creating safety hazards by combining the
LNG and LPG storage flare systems were small. However, an
assessment of two possibilities must be made, the first is
freezing butane in the header during simulataneous relief, and
the second is carry over of the condensed liquids up the flare
stack which could ignite and fall to the ground as burning rain.
Studying these possibilities under the possible simultaneous
relief scenarios is expected to show difficulties to be highly
unlikely. I would expect Urey to agree with the client's concept
under the condition that we conduct the studies.

D Hill response

On the flare issue, don't forget sequential releases, where a

butane release follows an LNG release that has cooled the system
down.

21 Oct 98 Technip Response

The response to Shell concerning a common flare for LNG and LPG
tanks must be carefully prepared. One flare per product is the
most comfortable solution, but is it necessary? Will the same

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question be raised in relation to a common flare for propane and
butane storage i.e. will we need three flares to be
"comfortable"?

The mixing of gaseous effluents which are very different in

nature is a common problem in the hydrocarbon processing
industries and one which both Technip and Kellogg are used to
solving. In ethylene plants for example the common practice is to
have a single flare for hot and cold streams. In this case there
are separate flare K.O. drums in the unit, and long separate
flare headers to allow warming of the cold stream before mixing.
A calculation of heat exchange with the environment is used as a
basis for changing fom SS to CS (which is not an issue for the
NLNG storage flare which is all SS). A small liquid knock out
device is located downstream of the mixing point. It has been
known to use external fins on the flare header to enhance heat
transfer with the environment and even solutions with steam
jacketing and direct steam injection (MWK could look into their
ethylene experience to confirm this).

It is confirmed that Technip has no specific references with a

common flare in mixed LPG/LNG service. However, such a solution
has been retained on certain recent projects at the design stage
and we think it should be possible to engineer a single flare
solution for the NLNG Expansion project. The main problem is
likey to be the time required to do the studies.

The issues which need to be resolved include

* Correct selection of the mixing point for the different vapours
with respect to the KO drum given the mist type condensation
mechanism.

* Correct design of the KO drum.

* The sweep gas purge rate to avoid air intake into the flare
system due to LPG condensation after cold LNG vapour discharge.

* The potential for tank to tank contamination as a result of

negative tank pressures for example during upsets during loading

* The potential for butane freezing

The use of dynamic simulation can be used to improve the heat

transfer modelling.

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The risks of flooding of the flare header with condensed LPG
should be easily reduced by the correct specification of slopes
for headers.

23 Oct 98 U Miller e mail

I have reviewed the situation of the combined flare for the NLNG
plant, and I do not believe there is sufficient data nor
rationale to tell a client that a combined flare system is
inherently unsafe.

I think the Technip response is well done and is along the lines
of my thoughts. I do not believe there is a strong argument, at
this stage, to tell a client that he cannot use a common flare.
Once the detailed design and the needed studies are conducted, it
may be found that the design may be impracticable.

A properly designed system, considering all the potential

anticipated scenarios should be a safe system. This is not a
safety issue but rather is a design issue. If the design is not
correctly done, then it would become a safety issue, however,
this is true for all we do.

I had a brief discussion with Duffer Crawford and Derek Wilson at

lunch on Wednesday. Duffer does believe the single flare
situation is workable. He stated that, in his opinion, the
butane will not freeze, and the biggest concern is the
condensation of butane in "cold" system after a LNG release. The
system can be analyzed with sufficient accuracy to predict the
results.

This modeling must be a consideration, and the essential question

is "can the system be designed to handle the anticipated credible
scenarios and remain functional?" For example, can a liquid
knock-out system be designed to handle the amount of condensation
expected?

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