We're being asked to install PSV's on a lean amine system where it has been discovered (following an incident) that the booster pumps are capable of producing a discharge pressure higher than the pipe rating of the large distribution network. The spillback system (which, fortunately, goes back to the large atmospheric surge tank) is being upgraded but local code does not allow us to take full credit for this instrumentation and we're required to use the PSV to protect against the PV fail closed scenario.
We have API 520 Pt. 2 as a required code and considered the word "shall" in the first sentence of section 11.1 as making free draining as a REQUIREMENT. This led us to doing the initial design with a riser pipe from the pump discharge, in order to have the PSV above the top of the surge tank thereby ensuring that the discharge line from the PSV is self draining.
Our customer is, rightly so, looking to minimize cost and is suggesting that we should be able to just operate in a liquid filled system, and have a minimal piping system with the PSV discharge line relieving into the spillback line, thereby saving substantially on installed cost. They used the example of thermal PSVs, often installed 'around' block valves (for instance, on an exchanger that can be isolated) as an example that PSVs can be accepted in cases where it is liquid service on both sides.
I'm struggling with this contradiction and would appreciate your comments/suggestions, especially if there are specific API, ASME, .... codes that can be referenced (we are bound to both sections of 520, ASME Section VIII, B-31.3 and CSA B51 by local regulation).
Thank-you in advance for any guidance you can provide.
Ken