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Low-Leak Valve Technology: An Update

Outline

• Refresher from Last Year• New CDs• New ELP Requirements• Total Valve Ownership Cost• Conclusions

Why an update?

• EPA renewed the Air Toxics National Enforcement Initiative for another 3 years from 2014-2016– Ongoing since 2005, continues to target LDAR

• 2 new CDs lodged since last year’s conference – 8 CDs that now include Enhanced LDAR Program (ELP) requirements

• New ELP requirements– Valve tightening, existing valve replacement/repack, optional monitoring

• Desire to understand “Total Valve Ownership” cost– Valve lifetime cost for low-leak technology (LLT) valves vs. non-LLT

Refresher: Low-Leak Valve Technology

• Defined in CDs under:– Certified Low-Leaking Valves, Low-Emissions Valve, Low-E Valve– Certified Low-Leaking Valve Packing Technology,

Low-Emissions Packing, Low-E Packing

• Manufacturer guarantee that valve/packing will not leak above 100 ppm for 5 years

• Guarantee or certification that valve/packing has been tested and found to not be leaking > 100 ppm

Refresher: Typical ELP LLT Requirements

Valve internal leak definition is 250 ppm

1.Every new valve shall be a certified Low-E Valve/Packing

2.Replace/repack valves leaking > 250 ppm with Low-E technology identified during any regular monitoring event

3.Replace/repack valves with Low-E technology leaking between 100 and 250 ppm

4.Low-E valve/packing leaking > 250 ppm– Low-E status not invalidated, 5/15 day repair attempts– Replace/repack if leak > 500 ppm

5.Commercial unavailability exclusion for Low-E technology

6.Connector improvement and replacement program

New ELP Requirements

• Valve Tightening Work Practices– After installation, ensure the valve packing gland nuts or

equivalent are tightened to:– The manufacturer’s recommended gland nut/packing torque OR

– Any appropriate tightness that will minimize the potential for fugitive emission leaks of any magnitude

• Replacement or Repack of All Existing Valves during next process unit turnaround– Includes those valves not leaking > 250 ppm– Replacement schedule is phased according to unit

• Voluntary pre-CD installation of 1,200 Low-E valves

New ELP RequirementsOptional

• Proactive Monitoring and Repair Practices relating to All Valves– May undertake either Method 21 or an IR Camera survey

following a shutdown that involves thermal cycling – In addition to regular Method 21 monitoring

– Must also monitor via Method 21 following detection of leak using IR Camera

– Any leak rate detected > 250 ppm does not require replacement/repack with Low-E

Comparison of Low-E Valve ELP Requirements

Requirement

Chemical Plant

A2009

B2009

C2011

D2012

E2012

F2012

G2013

H2013

Valve Tightening Work Practices

N N N N N N N Y

Optional Pro-Active Monitoring

N N N N N N N Y

Install New Valves/Packing with Low-E

Y Y Y Y Y Y Y Y

Replace/Repack Existing Valves Leaking > 250 ppm with Low-E

Y Y Y Y Y Y Y Y

Replace/Repack Existing Valves Leaking Between 100-250 ppm with Low-E

Y Y N N N N N N

Replace/Repack Existing Valves during Turnaround

N N N N N N N Y

Commercial Unavailability Y Y Y Y Y Y Y Y

A-Ineos Lanxness; B-Vertellus; C-Formosa; D-Dow; E-Sabic; F-Ineos Lima; G-DuPont; H-FHR

Refresher: Cost of Low-E Valve Technology

• Last Year– Performed an analysis to determine cost of Low-E valves vs.

“regular” valves– The analysis suggested that Low-E was cost-effective with little

to no difference in Low-E vs. “regular” valve cost – Slight premium for larger valves (hundreds, not thousands) due to

Low-E packing

– Conclusion: Non-material increase of costs for equipment associated with implementing a low-leak technology program on one-to-one valve replacement basis

• Would it make sense for non-CD facilities to use Low-E for expansion projects?

Use Low-E for expansion projects for a non-CD facility?

• Population of 1,000 valves• Regular valve population leak rate of <2%, quarterly M21• Low-E valve population leak rate < 0.1%, annual M21• Assume 2-hour installation, 5-year life at 10% interest• Assume technician monitors 250/day in 40 hrs at $35/hr• Repair per valve takes 4 hrs at $40/hr

Valve Size Size

% of Valve Population

Assumed“Regular” Valve Cost

Assumed Low-E Valve

Cost

Small ≤ 1” 47% $250 $262.50

Medium 1” < x ≤ 4” 50% $500 $550

Large > 4” 3% $1,500 $1,875

Results

• Direct – valve, packing, and installation cost• Indirect – capital recovery (5-year equipment life at 10% interest)• Monitoring

– Regular; 5 years of quarterly M21

– Low-E; 1st year (2 quarters, then semiannual M21), annual thereafter

• Leak Repair – Regular; 2% leak rate per monitoring event

– Low-E; 0.1% leak rate per monitoring event

Valve Type

Direct Costs

Indirect Costs

Over 5 Yrs

Monitoring Costs Over

5 Yrs

Leak Repair Costs Over 5

Yrs Sum

Regular $514,175 $678,190 $28,000 $64,000 $1,284,365

Low-E $539,171 $711,160 $9,800 $1,120 $1,261,251

Delta $24,996 $32,969 $18,200 $62,880 $23,114

Conclusions

• New ELP requirements indicate that EPA is continually looking at ways to increase LDAR enforcement

• For a non-CD facility considering an expansion, the total ownership costs associated with Low-E valves for a non-CD facility expansion, when compared to “regular” valves, appear to be comparable over a 5-year period when factoring in repair and monitoring costs

Final Thought• Will proactively installing Low-E valves improve my

facility’s standing with the EPA and mitigate any potential enforcement action?

Contact Information

John Butow, P.E.

75 Valley Stream Parkway, Suite 200

Malvern, PA 19355

john.butow@erm.com

484.913.0342

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