Proposed Requirements for Calculating Emergency Planning Zones for Sour Wells, Sour Pipelines and Sour Production

Facilities
Presented by: Gary Neilson BSc(Hons) P.Phys Public Safety Implementation Team

Presentation Outline
Background Proposed new requirements EPZ calculation process Implications Future work

EUBMODELS Structure

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
*Provincial Advisory Committee on Public Safety and Sour Gas Findings and Recommendations Final Report December 2000

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

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 Response Requirements for the Upstream Petroleum Industry

Proposed Requirements
Address suite of PSSG Recommendations (17,18, 19, 58 and 62) Define the minimum standards to calculate an EPZ to protect public SAFETY (protect against fatalities or serious irreversible health effects) Replaces the simple release rate based equations (or nomographs) EPZ derived from new requirements remains first step. Actual size and shape of the final EPZ must reflect site-specific features of the area

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 EPZ includes mitigation actions NO EUB PREAPPROVAL Applicable to new applications, ERP updates AND interventions

Proposed Requirements
Base Case MANDATORY
REQUIREMENTS (Minimum Standards)
Sour Gas Release Rates Gas composition Depressurization (REAL GAS EFFECTS) Release Duration Dispersion Modelling Meteorological Conditions Concentration Fluctuations EPZ Endpoints EUBMODELS (Screening Level EPZ Calculation)

Technical Descriptions and Formulations

User Guide & Tutorial Software Package

Release Rates
For wells maximum release rates required as described in Guide 56 For pipelines mass release rate profile from a guillotine break must be calculated using the maximum 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
9

Depressurization - why are real gas effects important?

Ideal gas laws under predict EPZ Real gases can form liquid aerosol as they expand and cool Well releases are sensitive to wellhead exit conditions (pressure, temperature, hole diameter) More detailed calculation may result in buoyant release Pipelines usually dense due to pressures EUBMODELS Base Case always dense release CONSERVATIVE
10

Release Duration
Duration defines exposure time Duration for wells must be realistic for the scenario (drilling, servicing or producing) and other sitespecific factors Duration for pipelines determined by transient mass release through a guillotine break Countermeasures such as ignition that limit the duration of the sour gas release are permissible (documented and PRACTICAL) For pipelines ignition not allowed as a countermeasure releases not typically long enough for manual ignition self-ignition not guaranteed
11

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 acceptable because a sour gas release from a well or pipeline occurs 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 as the calculation using a complex terrain model for comparison purposes

12

Complex Terrain Criterion - H2S Releases

Requirements now address issues of terrain Buoyant releases may require complex terrain modelling Compare terrain elevations in EPZ to terrain criteria defined in EUBMODELS Criteria based on EUB Guide 60 (Flaring)
kinetic energy lift sufficient to overcome temperature gradient
complex

criterion parallel

13

Toxic Load End Points

Endpoint described by toxic load criterion
L=KCnt same adverse effect for low concentration over longer 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 provide conservatism to protect public safety (i.e. if level achieved would not expect fatality or other serious irreversible adverse effect)

14

EPZ Calculation Process

EUBMODELS Base Case (Mandatory) EPZ pre-approval from EUB not required EPZ to be used for Public Involvement EPZ tuned to reflect site specific features

Acceptable

EUBMODELS BC Parameters varied

EUB assessment

Acceptable

ERP

Alternate Methods EUBMODELS BC must also be modelled using alternate methods

15

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 practical mitigation measures used Operational implications (e.g. ESD valve trip points)

16

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 with stakeholders depending on impact compared to previous methods Revise Guide 71 targeting fall 2004 EUBRISK and EUBHVP EUBMODELS can be adapted possibly undertake in new fiscal year

17

EUBMODELS Structure
EUBMODELS

USERSpreadsheet INPUT

Excel

USER OUTPUT Spreadsheet

Runs 54 times for met matrix

EUBFlash EUBSlab

18

Summary of PROPOSED Requirements

Requirements in draft Requirements in Guide 71 still apply No reduced EPZ application (size of EPZ determined by varying parameters) - single EPZ can be taken forward to communities for discussion and fine tuning EUB review post public involvement as part of ERP assessment REALISTIC MITIGATION Requirements applicable to new applications, ERP updates or interventions Provide clarity to assist in EUB decisions

19

Project Website

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

draft.protocol@gov.ab.ca

20