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Low-Leak Valve Technology: An Update

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

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Low-Leak Valve Technology: An Update

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  1. Low-Leak Valve Technology: An Update

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

  3. 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

  4. 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

  5. Refresher: Typical ELP LLT Requirements Valve internal leak definition is 250 ppm • Every new valve shall be a certified Low-E Valve/Packing • Replace/repack valves leaking > 250 ppm with Low-E technology identified during any regular monitoring event • Replace/repack valves with Low-E technology leaking between 100 and 250 ppm • Low-E valve/packing leaking > 250 ppm • Low-E status not invalidated, 5/15 day repair attempts • Replace/repack if leak > 500 ppm • Commercial unavailability exclusion for Low-E technology • Connector improvement and replacement program

  6. 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

  7. 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

  8. Comparison of Low-E Valve ELP Requirements A-Ineos Lanxness; B-Vertellus; C-Formosa; D-Dow; E-Sabic; F-Ineos Lima; G-DuPont; H-FHR

  9. 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?

  10. 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

  11. 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

  12. 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?

  13. Contact Information John Butow, P.E. 75 Valley Stream Parkway, Suite 200 Malvern, PA 19355 john.butow@erm.com 484.913.0342 The world’s leading sustainability consultancy

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