Low Leak Valve and Valve Packing

Technology (Low-E Valve)

Kosta Loukeris

u.s. EPA Region 5

Loukeris.Constantinos@epa.gQy

(312) 353-6198

8/16/2011

U.S. Environmental Protection Agency

1
Overview

• Basic Knowledge

• Current Enforcement Language

• Current Enforcement Triggers

• Best Practices for Installing Low-E Valve

• Vendor Availability

• Commercial Unavailability

• Valve Testing Procedures

• Emissions Analysis

• Proposal

8/16/2011 u.s. Environmental Protection Agency 2
Basic Knowledge

Sources of Fugitive Emissions by Equipment Type

8/16/2011

P urn ps I

Compressors

10%

Tanks

10%

Flanges

5%

u.s. Environmental Protection Agency 3
Basic Knowledge

• Low-E Valves Used for Over 15 years

• Reduce Leak Rates (1.4 valves leaking per 1000,

500 ppm leak definition)

• Reduce Maintenance Costs

• Reduce Product Losses

• Reduce Fugitive Emissions

• Reduce Monitoring Frequency

• Slight Increase in Cost, 10-35% from using non

Low-E Valve Technology

8/16/2011 U.S. Environmental Protection Agency 4
Basic Knowledge - Packing Technology

Style 212 ULE is made up of two unique types of graphite

rope packing using an "A-8-A"

configuration. There are four "A" type packing rings with a

single "8" type ring in the middle.

The "A" type rings are manufactured from a proprietary yarn

consisting of several strands of

high purity GRAPH-LOCK® contained by an Inconef

filament jacket. This Inconel** wire filament

is only 0.004" diameter, making the finished braid non-scoring

and thermally conductive. The

center "8" type ring is braided from graphite fiber reinforced

flexible graphite yarns and high

purity graphite filament yarns

TEMPERATURE -328oF to +1200oF

-2000C to +6500C in steam

+8500F(+4550C) atmosphere

PRESSURE 4500 psi (310 Bar)

PH 0 - 14 (except strong oxidizers)

8/16/2011 U.S. Environmental Protection Agency 5
Current Enforcement Triggers

• All new valves must be installed with a Low-E Valve

or Low-E Valve Packing Techology

• For existing valves, replace or repack each valve,

within 30 days or by next maintenance shutdown,

that was found leaking over 250 ppm with a Low-E

Valve or Low-E Packing Technology

- Options:

• Repack existing valve

• Replace with new valve

• Repack new non Low-E valve with Low-E Packing

8/16/2011 u.s. Environmental Protection Agency 6
Current Enforcement Language

• Low-E Valve is defined as:

A valve (including its specific packing assembly) or

valve packing for which the manufacturer has issued a

written warranty that it will not emit fugitives at greater

than 100 ppm, and that, if it does so emit at any time in

the first five years, the manufacturer will replace the

valve; provided however, that no valve shall qualify as

"Low-E" by reason of written warranty unless the valve

(including its specific packing assembly) either:

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Definition - Criteria

(a) first was tested by the manufacturer or a qualified testing firm

pursuant to generally-accepted good engineering practices for

testing fugitive emissions and the results of the testing

reasonably support the warranty; or (b) is as an Extension of

another valve that qualified as "Low-E";

(ii) A valve (including its specific packing assembly) that:

(a) Has been tested by the manufacturer or a qualified

testing firm pursuant to generally-accepted good engineering

practices for testing fugitive emissions and that, during the test,

at no time leaked at greater than 500 ppm, and on Average,

leaked at less than 100 ppm; or (b) Is an Extension of another

valve that qualified as "Low-E".

8/16/2011 U.s. Environmental Protection Agency 8
Best Practices Upon Installing Low Leak Valve

Technology

• Upon installation or repacking, a facility shall tighten the valve's packing

gland nuts or their equivalent to: (i) the manufacturer's recommended

gland nut or packing torque; or (ii) any appropriate tightness that will

minimize the potential for fugitive emission leaks of any magnitude.

This practice shall be implemented prior to the valve's exposure to

process fluids.

• Not less than three days nor more than two weeks after a new valve

that has been installed or an existing valve repacked first is exposed to

process fluids at operating conditions, a facility shall recheck the load

on the valve packing and, if necessary, shall tighten the packing gland

nuts or their equivalent to: (i) the manufacturer's recommended gland

nut or packing torque; or (ii) any appropriate tightness that will minimize

the potential for fugitive emission leaks of any magnitude.

8/16/2011 U.S. Environmental Protection Agency 9
Valve Testing Procedures

• Currently Available Test Procedures

- API 622 (1 st and 2nd Edition)

- ISO 15848-1 *

- VOl 2440*

- Chevron Texaco Standard

- ANSI/lSA-93.00.01-1999

- FCI 91-1-1997(R2003)

- Shell SPE 77/312*

* Procedures use leak rates to determine leakage (mg/m3)

8/16/2011 u.s. Environmental Protection Agency 10
Valve Testing Requirements

• Mechanical Cycling

- Cycle while turning the valve on/off

• Thermal Cycling

- Increasing and decreasing temperature during

mechanical cycling

• Method 21 or Testing at certain intervals

8/16/2011 u.s. Environmental Protection Agency 11
Commercial Unavailability (CU)

• Not all valves are able to be repacked or

replaced with a Low E-Valve.

- Examples: Valves used for instrumentation on

piping 5/8" or less

• Factors to be Evaluated in Determining CU - Valve Type

- Retrofit Requirements

- Packing Friction

- Valve Operating Conditions (Temperature, Pressure)

- Compatibility of Materials of Constructions with Process Chemistry

8/16/2011 U.S. Environmental Protection Agency 12
Valve Types and Packing Materials

• Gate - Ball - Butterfly - Quarter Turn -

Check - Control - Needle - Globe,

Strahman, etc.

• Packing Materials

- Graphite

• Refineries, petrochemical, oil and gas, and some

chemical plants

- Teflon (PTFE)

• Primarily chemical plants

- Bellows Seals

8/16/2011 U.S. Environmental Protection Agency 13
Consent Decrees with Low Leak Valve Technology

• Chemical Plants

- Vertellus (Pharma/HON);

- INEOS/Lanxess (P&R IV);

- Dow Chemical (HON and P&R IV)

• Refineries

- Hovensa*

- BP Whiting

- Murphy Oil

- Shell Chem

* Hovensa and Chevron (Richmond, CA) have been using LLVT for 10+ years

8/16/2011 u.s. Environmental Protection Agency 14
Fugitive Emissions

4.000%

Yearly Valve Leak Rates 2003 to 2010 for 19 Refineries and 2 Chemical

Plants in California

3.500% --

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