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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.
1. Avoiding risk
2. Engineering controls
3. Administrative control
Regarding the administrative control, the spirit of API 521 Section 4.2.2 is:
Implication
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 4.4.2.1 clearly said:
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 4.4.9.2), c)
check valve leakage or failure (see 4.4.9.3), d) heat transfer equipment failure (see
4.4.14).