Typically these changes are being driven by Consent Decrees, definitions defining ‘Certified Low Leak Valve Technology’ and ‘Certified Low Leak Packing Technology’ (traditional and injectable), and the enforcement of low leak levels. As the driving forces behind these changes are evident, the focus of the industry must become ways to first address and then implement these changes.
By Ivy Davis
Fugitive emissions are unintentional leaks emitted from sealed surfaces, such as packings and gaskets, or leaks from piping systems and equipment resulting from corrosion or faulty connections. They are typically emitted into the air by the following sources:
• Open-ended lines
• Sampling connections
• Pressure relief valves
These sources must be monitored for fugitive emissions through a Leak Detection and Repair (LDAR) Program. An LDAR program is the system of procedures that a facility utilizes to locate and repair leaking components, including valves, pumps, connectors, compressors, and agitators, to minimize the emission of fugitive volatile organic compounds (VOCs) and hazardous air pollutants (HAPs).1
Why have the solutions to reduce fugitive emissions changed rapidly?
Prior to the inception of the EPA, in 1958 ‘The Health, Education, and Welfare Department’, sent Dr. Bernie Steigerwald to perform a site survey of Los Angeles area refineries, concluding, there are components that leak, and many components have the potential to leak. If calculated cumulatively, equipment leaks may cause a pollution problem.
Later, EPA invested in research to identify environmental issues, and more so problems specific to fugitive emissions. One large project went to Radian Corporation to measure atmospheric emissions from petroleum refineries where they conducted the following tests:
• Instrument monitoring for presence of leaks,
• Correlation equations and emission factors,
• Bagging procedure later formalized by EPA.
Another large project went to Rockwell Corporation teaming with Texas A&M University to measure emissions from oil & gas production and they conducted the following test:
• Leak detection by Soap scoring (Bubble Test).2
On December 17, 1963, the Clean Air Act was put into effect by the Environmental Protection Agency (EPA). “The Clean Air Act is the law that defines EPA’s responsibilities for protecting and improving the nation’s air quality and the stratospheric ozone layer.”3 Since then, the only major changes to the Clean air act were the Amendments of 1990. Considering the lack of major changes to the initial governing rules for air quality, the industry has continued toward stricter self-imposed regulation through the LDAR programs.
The cost savings, along with environmental protection, and worker and community safety are the factors that have increased the momentum in the regulation of fugitive emissions. When the Clean Air Act was first established, the industry had a reactive approach. However, considering the impact of benefits along with new technologies and products, the industry has shifted to a proactive approach.
Proactive Versus Reactive
“Managing leak documentation is great, but we really need to focus on stopping the leaks before they need to be managed,” said industry expert Rodney Roth of RFS Compliance Solutions. He highlighted that the focus should be placed on prevention and being proactive rather than reactive. There are several questions to consider when shifting to a proactive approach for fugitive emissions monitoring.
1. Did the user follow the torque management requirements for the Low E valve and low E packing warranty during installation?
2. How can leaks be prevented?
3. Is the equipment maintained properly?
4. Do the users understand how to prevent leaks through proper valve maintenance?
5. Are the valve and packing suppliers available to properly train personnel? There are considerations that must be made to achieve a proactive approach. Effective processes for Leak Prevention, Repair, and Maintenance must be implemented. The first step is the development work practices that proactively reduce the likelihood that leaks will occur. This can be achieved through training, proper installation and maintenance of valves and packing, as well as the installation of certified low emission technology.
Without proper training the installation process can easily become a major issue leading to fugitive emissions that otherwise may not have occurred. Packing manufacturers, gasket manufacturers, and valve OEM’s are all responsible for providing the necessary training for the proper use of their products. Additionally, companies such as RFS Compliance Solutions offer training courses on all types of subjects, such as valve packing installation, gasket installation and proper bolting, LDAR 101, etc.
Installation of packing, gaskets, and valves is performed by either onsite maintenance staff or approved contractors brought onsite to complete the process. Processes are usually put in place by the manufacturers to ensure the installation has been performed properly. These processes are documented and signed off on by leadership personnel from the facility. Not following the processes in place lead to failures (fugitive emissions) that must be reported, and repaired. Proper valve maintenance and proper packing installation performed by trained personnel will dramatically affect overall LDAR performance.
Use only ‘Certified Low Leaking Valve Technology’ and ‘Certified Low Leaking Packing Technology’. Many end uses have addressed this within the Approved Manufacturers list (AML), ensuring the products purchased and installed are capable of meeting the compliance requirements in place.
“With the development of better valve designs and manufacturing methods, as well as better performing valve packing, compliance with today’s reduced emissions standards is achievable,” said Roth. “Being proactive can be summed up using these three words: prevention, reduction, and elimination.”
Despite a facilities adherence to emission standards and preventative action, some leakage may be unpreventable. In the instance that a company finds itself with a fine from the EPA, swift action will be required to achieve improvements within the mandated timeline.
The final and most critical piece is the “R” in LDAR – repair. If a user is at the repair stage of his/her program to prevent a leaking valve, time is of the essence. Procuring a new valve is a viable solution, but it may prove to be costly and time consuming. Another solutions is therefore to replace the valve’s packing with either injectable packing or traditional packing styles.
To comply with outlined standards, there are some simple steps that must be followed, as outlined below:
1. Torque – Verify packing torque prior to equipment start up.
2. Valves – Maintain valves as outlined by the manufacturer.
3. Packing – Maintain packing as outlined by the manufacturer.
Valve compliance can be easily addressed utilizing API 624 and API 641 test protocols for Low E certification. Additionally, packing compliance can be addressed based on their performance in the API 622 test protocol.
All three of these standards have the same leakage requirement in place. Valves to be tested in accordance with API 624 and API 641 must have API 622 compliant packing installed before being tested pursuant to the requirements of API 624 and API 641.4
Benefits of an LDAR Program
“When the LDAR requirements were developed, EPA estimated that petroleum refineries could reduce emissions from equipment leaks by 63% by implementing a facility LDAR program. Additionally, EPA estimated that chemical facilities could reduce VOC emissions by 56% by implementing such a program,” stated the EPA in their Leak Detection and Repair Compliance Assistance Guide.5
Reduction in emissions is the reason that LDAR was established along with the state agencies to reduce the air pollution from refineries and chemical plants. With that goal in mind, this is a two-way street for all involved. The EPA can seem like just a rule enforcer putting unimaginable fines and penalties on oil and gas – an industry already under pressure – but they are also willing to negotiate and provide guidance. By following an LDAR program a user can reduce product losses, increase safety for workers and operators, and decrease exposure to pollutants. It is essential that everyone work together to provide a better future for generations to come.
With high quality low E valves, low E packing and the introduction of low E injectable packing, there will be a reduced amount of EPA enforcements in the downstream sector of our industries,” shared Roth. He foresees the EPA placing a larger focus on the midstream and upstream sectors in the future years.
As users know what is driving changes toward an emission free environment, the next step is to understand what needs to be done to address them. Below is a summary of steps that need to be addressed, as outlined in the article:
• Five Year Compliance as outlined in Consent Decree language
• Effective product selection (valves & packing)
• Warranty/Performance statement (Testing to Support)
• Effective Maintenance
• Warranty Compliance (valves & packing)
• Effective corrosion inhibitors
• Use of torque wrenches
• Use of effective anti-seize (Jet-Lube 550 Extreme)
• Proper installation procedures
• Properly Trained/Certified installers
Following these steps will ultimately allow users to mitigate the risk of emission leaks and act proactively rather than reactively.
*Special thanks to Rodney Roth, Consultant with RFS Compliance Solutions for sharing his training videos, presentations and technical expertise to complete this article.
ABOUT THE AUTHOR
Ivy Davis began her career in 2007 with a Bachelors of Business Administration in Marketing from Texas Lutheran University. She was awarded the ‘Outstanding Marketing Award’ for the highest GPA in her graduating class and has since excelled as a marketing professional. Ivy continues to pursue her passion for marketing and regularly consults with organizations to facilitate marketing plans for exponential growth in their industry. She has worked in Houston, Texas for the last decade and focuses predominantly on the oil & gas and technology sectors.