# Low LeakValve 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 ProtectionAgency 1

## Overview • Basic Knowledge • Current Enforcement Language • Current EnforcementTriggers • Best Practices for Installing Low-E Valve • VendorAvailability • Commercial Unavailability • Valve Testing Procedures • Emissions Analysis • Proposal 8/16/2011 u.s. Environmental Protection Agency 2

## Basic Knowledge Sources of Fugitive Emissions 

### byEquipmentType

8/16/2011 Purnps 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 oftwo unique types ofgraphite 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 proprietaryyarn consisting ofseveral strands of high purity GRAPH-LOCK®contained by an Inconef filamentjacket. 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 graphitefilament yarns TEMPERATURE -328oF to +1200oF -2000C to +6500C in steam +8500F(+4550C) atmosphere PRESSURE 4500 psi (310 Bar) PH 0 - 14 (exceptstrong oxidizers) 8/16/2011 U.S. Environmental Protection Agency 5

## Current Enforcement Triggers • All newvalves must be installed with a Low-E Valve or Low-E Valve Packing Techology • Forexisting valves, replace or repack each valve, within 30 days or by next maintenance shutdown, thatwas found leaking over250 ppm with a Low-E Valve or Low-E Packing Technology

- Options: • Repack existing valve • Replace with newvalve • 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 forwhich the manufacturer has issued a written warrantythat itwill not emitfugitives at greater than 100 ppm, and that, if it does so emit at anytime in the first five years, the manufacturerwill replace the valve; provided however, that no valve shall qualify as "Low-E" by reason ofwritten warranty unless the valve (including its specific packing assembly) either: 8/16/2011 u.s. Environmental Protection Agency 7

# Definition - Criteria (a) firstwas tested by the manufacturerora qualified testing firm pursuantto generally-accepted good engineering practices for testing fugitive emissions and the results ofthe testing reasonably supportthe warranty; or (b) is as an Extension of anothervalve that qualified as "Low-E"; (ii) A valve (including its specific packing assembly) that: (a) Has been tested bythe manufacturerora qualified testing firm pursuantto generally-accepted good engineering practicesfortesting fugitive emissions and that, during the test, at no time leaked at greaterthan 500 ppm, and on Average, leaked at less than 100 ppm; or (b) Is an Extension ofanother valve that qualified as "Low-E". 8/16/2011 U.s. Environmental Protection Agency 8

### Best Practices Upon Installing Low LeakValve Technology • Upon installation or repacking, a facility shall tighten the valve's packing gland nuts ortheir equivalent to: (i) the manufacturer's recommended gland nut or packing torque; or (ii) any appropriate tightness that will minimize the potential forfugitive emission leaks ofany magnitude. This practice shall be implemented priorto the valve's exposure to process fluids. • Not less than three days nor more than two weeks aftera 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 ortheir equivalent to: (i) the manufacturer's recommended gland nut or packing torque; or (ii) any appropriate tightness that will minimize the potential forfugitive emission leaks ofany magnitude. 8/16/2011 U.S. Environmental Protection Agency 9

## Valve Testing Procedures • CurrentlyAvailable 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 orTesting at certain intervals

8/16/2011 u.s. Environmental ProtectionAgency 11

## Commercial Unavailability (CU) • Notall 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- QuarterTurn - Check- Control - Needle - Globe, Strahman, etc. • Packing Materials

- Graphite • Refineries, petrochemical, oil and gas, and some chemical plants



### - Teflon (PTFE) • Primarilychemical plants



### - Bellows Seals 8/16/2011 U.S. Environmental ProtectionAgency 13

## Consent Decrees with Low LeakValve 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 LLVTfor 10+ years 8/16/2011 u.s. Environmental Protection Agency 14

# Fugitive Emissions

4.000% YearlyValve Leak Rates 2003 to 2010 for 19 Refineries and 2 Chemical Plants in California 3.500% --**3.000~<>**
(.J**2.S00~{,** if o 2.000','0 -- ;; a: -;; .3 1.500%

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