June 13, 2

Robert M

US Enviro

Mail Code

109 T.W.

Research

RE: Respo

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3

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 therefore
4

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