Low-Leak Valve
Technology:
An Update
Standards
Certification
Education & Training
Publishing
Conferences & Exhibits
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 Requirements
Optional
• 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
Chemical Plant
Requirement
A
2009
B
2009
C
2011
D
2012
E
2012
F
2012
G
2013
H
2013
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
Assumed
“Regular”
Valve Cost
Assumed
Low-E Valve
Cost
Valve
Size
Size
% of Valve
Population
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
Indirect
Monitoring Leak Repair
Costs
Costs Over Costs Over 5
Over 5 Yrs
5 Yrs
Yrs
Valve
Type
Direct
Costs
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
Sum
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 nonCD 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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