June 13, 2

Robert M

US Envir o

Mail Cod e

109 T.W.

Research

RE: Resp o

Dear Mr.

On behal f

response

FSA repr e

technolo g

promine n

producti o

facilities a

include: m

piping sy s

fluid seali

Respons e

2. Please

the data s

factors f o

calculate

F o

overesti m

referred t

correlati o

We comp

Tribology

results to

in API 68 2

used for t

shown in

conclude

the emis s 2 014

orales

nmental Pro t

e : C404

‐ 02

Alexander D r

Trinage Park

,

o nse to the L e

Morales,

f of the Fluid

to the EPA’s

e sents the lea

g y specificall y

n t role in pre v

o n and refini n

a nd generally

m echanical s e

s tems, and g a

ng devices in

e to White Pa

comment o n

s ources disc u

o r equipmen t

these emissi

o r the case o f

m ate leakage l

t o in this stu d

o ns used.

ared the equ

and Lubricat

be quite diff e

2 current edi t

t he data in ta

table 2

‐ 10 is

that the equ a

ion estimate s t ection Agen c

r ive

, NC 27711

e aks White P a

Sealing Asso c

leaks white p

ding North A

y designed fo r

v enting leaks

g, in power p

all industrial

e als, compres

a skets. FSA m

the America

per on Leak s

n the approa c

u ssed. Please

leaks prese n

ons, both on

f Mechanical

l evels some w

d y (page 8) es

ation for “Pu

ion Engineer s

e rent. As yo u

t ion of 5.6 g m

ble 2

‐ 9 for “L

inconsistent

a tion used fo

s used in API c y Office of A

a per on Met h

c iation (FSA),

p aper.

merican seal i

r containme n

and emissio n

p lants, chemi c

activity in th

sion packing,

m embers acc o

s market.

s

c hes for qua n

comment o n

n ted in this p a

the total na t

Seals, the m e

w hat. For exa

t imates pum p

mp seals/all ”

s (STLE) docu

u can see, the

m /hr which c o

ight liquid p u

with API 682

r the data sh o

682 and the S

1 ir Quality Pla

h ane and VO C

we respectf u

i ng device m a

n t of product s

n s. FSA’s tec h

c al and petro

e world. Th e

expansion j o

o unt for a ma j

n tifying emis s

n the nation a

a per. Please

t ional and re g

e thods used f

mple the EP A

p seal leaks a

” in table 2

‐ 1 0

ment SP

‐ 30 (

STLE equati o

o rresponds to

u mps” is the s

and STLE lea

o wn in table

S TLE docum e nning and St a

C Emissions i n

u lly submit th

a nufacturers

.

s used in ind u

h nologies are

o chemical pla n

e technologie

o ints, ducting

j ority of the m

s ions and on

a l estimates o

comment o n

g ional equip m

f or quantifyi n

A Equipment

a t a level that

0 with the eq u

1994). The a t

o n agrees wit

o 1000 ppmv.

s ame as the o

kage limits a n

2

‐ 9 would b e

e nts. a ndards

n the Oil and N

h ese technica

. Sealing dev

u strial proces s

used in ever y

nts, water an

s represente d

g systems, ex p

m anufacturi n

the emissio n

o f emissions a

n the activity

m ent counts

.

n g emissions a

Leaks 1995 T

is higher tha

uation used i

t tached grap h

h the leakag e

We noticed t

o ne used in S P

n d methods o

e st agree, an d N atural Gas S

l comments i

ices are

s es and play a

y aspect of o i

n d waste wat e

d by the FSA

p ansion joint s

n g capacity fo

n factors use d

a nd emissio n

data used t o

.

a ppear to

able 2.10 tha

n some othe r

n the Societ y

h shows the

e limit refere n

t hat the equ a

P

‐ 30. The dat

o f calculation

d is consisten t S ector

n

a

i l

e r

s

r

d in

n

o

t is

r

y of

n ced

a tion

t a

. We

t withHowever

conserva t

appears t

these em i

level tha n

Modern m

database

accordan c

users get

factor” a p

The “EPA

must mo n

correlati o

which is t

bagging i s

5. Are th e

and stor a

potential

the age of

factors a n the more im p

t ive at the ti m

o be that the

i ssion levels t

n estimates t h

m echanical s e

from which t

c e with API 6 8

proper credi t

p proach whic

Correlation A

n itor these p u

o n approach w

o totally encl

s done very o

e re types of w

a ge stations t

for leaks ar e

of the equip m

n d others th a p ortant poin t

m e, current p r

leaks are at c

t o much low e

h at were tab u

e als

– wheth e

t he emission f

8 2 must all m

t for using A P

h still relies o

A pproach” is,

u mp seals

– t y

w ould be the

ose (“baggin g

ften these d a

w ells sites, g a

hat are mor e

e the number

m en t

, as well a

a t you believ e t is that, in a d

r actices resul t

c ertain histo r

e r levels. The

u lated almos t

e r single or d u

f actors were

m eet the requ

P I 682 seals. T

o n data from t

we believe, t

y pically mon t

most accura t

g ”) the pum p

a ys.

a thering and

e prone to le a

and types o f

a s factors th a

e to be impo r

2 d dition to the

t in significa n

r ical levels, b u

se values are

t 20 years ag o

u al

– leak les s

developed. I

irements of t

T his is especi a

t he early 199

t he most co m

t hly. Althoug

t e except for

and directly

boosting sta t

a ks than oth e

f equipment,

a t relate to t h

r tant. fact that the

n tly lower lea

u t the curren t

e probably m u

o

.

s than the se a

I n fact, seals m

t he Clean Air

a lly true whe n

9 0s.

m monly used

g h the correla

the “Unit Sp e

measure th e

t ions, proces

e rs? S ome fa c

the mainten

h e local geol o estimates m

kage rates. T

t State and F e

u ch closer to t

a ls that were

m anufacture

Act. It is not c

n using the “ a

method. Aft e

tion is a subj e

e cific Correla t

e leakage. W e

sing plants, a

c tors that co u

ance of that

o gy. Please d ay have bee n

T he assumpti o

e deral rules l

t he actual le a

included in t h

d and qualifi e

c lear that en d

a verage emis s

e r all, end us e

e ct of debat e

t ion Approac

e do not kno w

a nd transmis s

u ld affect th e

equipment, a

iscuss these n

o n

imit

a kage

h e

e d in

d

s ion

e rs

e

, the

h”

w

s ion

e

a nd3 One very important factor that can affect the potential for leaks is the quality and design of the

equipment used, not just its maintenance. A good example would be block valves, which, for a given

size and pressure class, can be made to the same API construction standard. However, there are design

factors that can mean the difference between meeting certain leakage criteria (i.e. 500 ppm or 100

ppm) or not. Testing and qualification to API test standards (i.e. API 624) can mitigate the risk for

leakage in the plant.

Other factors that will affect the potential for leaks are:

Plant procedures such as clearly documented repair procedures

Training of personnel implementing the repair

Qualification and approval of sealing devices based on established plant specifications/

standards. As an example, requiring compression packings used in the plant meet specific test

criteria with documented test results demonstrating their LowE (Low Emission) criteria.

11. Please comment on the cost of detecting a leak when compared to the cost to repair a leak.

Multiple studies described in this paper suggest that detecting leaks is far more costly than repairing

leaks and, due to generally low costs of repair and the subsequent product recovery, it is almost

always economical to repair leaks once they are found. Please comment on this overall conclusion.

Section 3.2 Repair states: “After a leak is detected, the owner or operator of the facility must decide

whether or not to fix the leak, unless they are required to fix the leak due to regulatory or permitting

obligations. This decision can be based on several factors, including, the cost of fixing the leak and the

size of the leak.”

Many plants may not have much leeway in deciding what to fix. If they are on an LDAR program, they

either have to fix it immediately, put it on a ‘delay of repair’ list (which has a limited number of spaces;

going over the limit results in fines). We think the sentence in 3.2 down plays the importance of repair.

For valves, a repair is typically defined as a gland adjustment to reduce the leak. If that is not successful,

the next step is to re

‐ pack the valve (if it can be isolated, i.e. a control valve). Another option is to ‘drill

& tap’ the valve. Often the plants will decide simply to replace the valve as the cost to repair exceeds

the valve cost. As there is no detail on how the cost of repair is calculated, it’s hard to validate it.

We have been given an example that the cost to repair a control valve can be $3500. More than 1⁄2 the

cost can be to rig, scaffold, isolate and repack and test the valve.

Gland adjustments can mitigate the leak, but the effectiveness over time is not determined.

For mechanical seals we disagree that the cost of detecting a leak is more than the repair costs. We do

not have any good estimates for the costs to detect a leak but the costs to repair based on the default

values from the FSA Life Cycle Cost estimator range from $2500.00 to $3000.00 per seal per repair (for

single, dual seal or packing for a 1.750” shaft). We feel that the cost of detection would be less than this.

Another consideration is that detection is required to identify the seals that need repair and therefore4 should be included as part of a preventive maintenance program. Perhaps the justification should be

based on the cost to avoid regulatory fines for major leak occurrences including the cost of LDAR and

QIP.

It must, however, be noted that although the cost of an individual leak detection might be less than the

cost of repair, the cost of a detection program, i.e. the cost of regular detection activity, will depend on

frequency and population of equipment being monitored. When this is factored in, the cost of the

repair of an occasional leak could certainly be less than the cost of monitoring. Nevertheless,

monitoring is required to find leaks, and must continue once a repair is conducted as any piece of

equipment could experience a leak, including the repaired equipment.

12. If the conclusion is correct that it is almost always economical to repair leaks once they are found,

then how important is the quantification of emissions from leaks when implementing a program to

detect and repair leaks?

We believe that leakage detection is required to identify seals that should be repaired. Quantification of

the leakage is necessary only to determine the severity of the leak and determine the urgency to make

repairs and prioritize among repair requirements. Therefore qualitative leakage detection, such as

go/no

‐ go thresholds, could be sufficient to identify the emission severity.

13. Please comment on the state of innovation in leak detection technologies. Are there new

technologies under development that are not discussed in this paper? Are there significant

advancements being made in the technologies that are not described in this paper

The mitigation described focuses almost exclusively on the detection options, not the repair options

which are pretty much undefined in this document. Note that section 4.1 in the Compressor document

does a much better job of describing a mitigation option for reciprocating (replacing seals, correcting

alignment issues etc.).

One way to mitigate repair is to improve the sealing solutions that are used, and improve the equipment

they are installed in. Simply repairing equipment to its original condition only guarantees previous

performance. The equipment could have been in use for a decade or more, but newer sealing

technologies can reduce emission levels significantly more than a “repair” to like new condition.

Upgrading to new technology is more important than just “repairing”. This should be included in this

paper.

LowE sealing solutions are available that can meet much lower leakage limits, and they are tested and

certified using established test techniques (a relatively new development in the industry).

Consistent installation technique is very important to reduce the number of leaks in a plant. An

improperly packed valve, or an improperly assembled flange, connector etc. will likely leak. Training and

documentation are an important component of reducing the number of leaks in a plant. There is no

emphasis on training, yet this is as likely to contribute to reduced emissions as any other program.

The Fluid Sealing Association Gasket Technical Committee makes the following recommendation along

this particular point to further reduce these emissions caused by leaking joints:5 ‐ Proper material selection for the correct application is critical for the longevity of joint integrity;

incorrect material selection can seriously reduce the life of a gasket and increase the risk of failure which

can cause leaks.

‐ Newer efficient materials are available to help users with better sealability and achieve lower

leakage rates.

‐ By consensus of the member gasket material manufacturers within the FSA Gasket Division, a

majority of Bolted Flange Connection failures are associated with installation and assembly related

factors involving the gasket. To help in reducing these leaks please refer to ASME's PCC

‐ 1

‐ 2013, and the

ESA+FSA

– Gasket Installation Procedures (that can be found at www.fluidsealing.com).

Conclusion

Most of the leak estimates are based on surveys and studies conducted 20 years ago. Sealing

technology has significantly improved for gaskets, compression packing, and mechanical seals. We

believe more emphasis on personnel training and upgrading equipment to new technologies will result

in optimal use of sealing systems which will prevent leaks and emissions.

The FSA hereby submits these technical comments. Members of the FSA stand ready to answer any

questions you may have and thank you for your consideration. Please contact Henri Azibert, Technical

Director, Fluid Sealing Association with any questions you may have at 603

‐ 475

‐ 4335 or

Henri@Fluidsealing.com

. Thank you.

cc: Chris Swonger, Chair FSA Government Relations Committee chris.swonger@smiths.com