The Modernization of LDAR and the Long Term Advantages Gained

Rodney Roth – North American Strategic Accounts Manager – Stationary Equipment: A.W. Chesterton Company

Mark Kelsey – LDAR Business Unit Leader

Sage ATC Environmental Consulting

Speakers

•Valves

•New, Modified & Repaired

•Valve Standards

• Impact on Valves and Valve Sealing

•Valve Repair (or should we say valve maintenance?)

• Leak Prevention Opportunities

•Training

Overview

Valves

• New, Modified & Repaired

• Valve Standards

• Impact on Valves and Valve Sealing

Valve Repair (or should we say valve

maintenance?)

• Leak Prevention Opportunities

• Training

Overview

“Managing leak documentation is great but we

really need to focus on stopping the leaks before

they need to be managed”

“The FOCUS should be placed on PREVENTION”

What is LDAR and WHY is the R so Important?

•When looking at “Managing the R in LDAR”, there are some questions we should ask ourselves.

• Should the 1st attempt be considered repair, when packing torque management is a part of every Low E Valve and Low E Packing warranty?

• Are we actually repairing valves as part of our LDAR programs with respect to the “First Attempt”?

• Would we need to consider the need for Repairs initially if we seek to Prevent Leaks?

• What if we did a Better job of Maintaining the Valves as part of our programs?

• Do we understand the Best way to Prevent leaks through proper valve maintenance?

• Are we asking our valve and packing suppliers to properly train our staffs?

What is LDAR and WHY is the R so Important?

•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; HOWEVER, proper valve maintenance and proper packing installation by trained personnel will dramatically effect overall LDAR performance

•“Time and effort during valve packing Installation is the best chance to reduce LDAR issues”

Valve Packing Performance Effects on LDAR

Areas of Concern

•Establish work practices that can carry forward with or without a Consent Decree being in effect

•By working towards the prevention of leaks, eventually there will be little to no need to repair leaks

•Properly train personnel to manage the torque maintenance requirements for the valve and installed packing to reduce or completely eliminate the “R” in LDAR

Implementation of Effective Processes for Leak Prevention and Repair after Detection

•Use only “Certified Low Leaking Valve Technology” and “Certified Low Leaking Packing Technology”

•Develop work practices that proactively reduce likelihood of having leaks occur

•Properly Maintain Valves as Required by Valve OEM Warranty, Packing Warranty, LDAR Programs or Consent Decrees

Implementation of Effective Processes for Leak Prevention and Repair after Detection

Leak Monitoring and Prevention (LMAP)

• Modernize LDAR by changing to LMAP

• Repairs are a potential subset of the requirement

• More emphasis on prevention

Prevention

Repair

•Proactive

•Negative

•Reactive

Problems with “Repair”

End user definition:

• Work done in a shop

• Replacing or repairing valve components

LDAR definition:

• Re-torqueing / re-tightening gland flange studs (actually typical valve maintenance)

Various Methods

Maintain valves as outlined by manufacturer

Valves

Maintain packing as outlined by manufacturer

Packing

Verify packing torque prior to unit startup.

Torque

Consent Decree Low E Packing• A valve (including its specific packing assembly) for which

the manufacturer has issued a written warranty that it will not:

• Emit fugitives at greater than 100 ppm

• If it emits >100 ppm in the first five years, the manufacturer will replace

• No valve shall qualify as “Low-E” unless the valve (and packing assembly) was:

• First tested by the manufacturer or a qualified testing firm pursuant; OR

• Is an Extension of another valve that qualified as “Low-E”

End Users

• End users who have Consent Decrees in place must comply with the types of definition listed previously

Prevention Reduction Elimination

End Users

Not currently operating under a Consent Decree

But, take steps towards

compliance

Potential Rewards

API 624

• 2015 – re-publication of API 600 and API 602

• Requires compliance to API 624

• Users will inherently meet EPA definition of Low E valve when installing

• API 600

• API 602

API 624

• “Type Testing of Rising Stem Valves Equipped with Graphite Packing for Fugitive Emissions”

• Recorded leakage of 100 ppm or less* in

• 310 mechanical cycles

• 3 thermal cycles from ambient to 500°F

Affected API standards

Steel Gate Valves—Flanged and Butt-welding Ends, Bolted Bonnets”

5.9.7

Valves shall be qualified by type testing to meet the fugitive emissions requirements of API Std. 624.*

API 600 Gate, Globe, and Check

Valves for Sizes DN 100 (NPS 4) and Smaller for the Petroleum and Natural Gas Industries”

5.9.4

Valves shall be qualified by type testing to meet the fugitive emissions requirements of API 624.*

API 602

API 641

• Currently in development

• Will offer end users same ability to validate Quarter-Turn valves as they currently have for the evaluation of their rising stem valve population.

• Is in Task Group review and some initial drafts have been sent out for official ballot and comment

• Standard is not currently in publication by the EPA

• End users must look for other ways of performing evaluations on Quarter-Turn valves for suitability in Low E applications

API Standards Potentially Affected by API 641

API 608

• Metal Ball Valves-Flanged, Threaded and Welding Ends

API 609

• Butterfly Valves: Double-flanged, Lug- and Wafer-type

API 599

• Metal Plug Valves-Flanged, Threaded and Welding Ends

Consent Decree Low E Packing

• A valve packing product, independent of any specific valve, for which the manufacturer has issued a written warranty that

• the packing will not emit fugitives at greater than 100 ppm

• if it does so emit at any time in the first five years, the manufacturer will replace the product

• provided however, that no packing product shall qualify as “Low-E” by reason of written warranty unless the packing first was tested

• by the manufacturer or

• a qualified testing firm pursuant to generally-accepted good engineering practices for testing fugitive emissions

Compliance

• Can be addressed easily through evaluation of Low E packing products based on their performance in the API 622 test protocol.

• Current API 622 test protocol is purely a “Performance” test

• Task Group is preparing next version of API 622

• Meet same leakage criteria as API 624

• Less than 100 ppm without re-torque

Users under Consent Decrees

• Required to Comply with type of definitions listed previously

Prevention Reduction Elimination

APR RP621

• Recommended Practice 621 Reconditioning of Metallic Gate, Globe, and Check Valves

• To be published in 2016

• API RP621 will be published with procedures outlined to ensure valves being repaired meet Low E requirements

• Will have printed document to use to support repair of existing/ used valves

• Will have documents to support the manufacture and testing of new valves they will approve and procure

Torque

Verify Required Torque

New valve is installed

Repaired valve is

installedValve has

been repacked in

the field

Consent Decree

• EPA has modified Consent Decree to force verification of required torque.

• This is missed on many occasions due to:

• Lack of experience

• Lack of training

• Manufacturers have began adding tags

• Packing bolting can loosen during transport

Prevention is PRO-ACTIVE andPOSTIVE!

Repair is REACTIVE, COSTLY and NEGATIVE!

Additional steps

• 1. Data collection software capable of sending notice of upcoming torque verification

• 2. 5&15 day rule leads to emergency repairs

• Repairs done as part of rule can lead to premature failure

• Lack of proper understanding of effective packing re-torque

• Over-tightening due to lack of training*

• Results in expensive drill & taps or delay of repair

Additional steps

• 3. Valve and packing maintenance training

• 4. Pre Consent Decree Compliance

• 5. Consent Decree Negotiation Compliance

• 6. Post Decree Compliance

Additional Steps

7. Low E asset management

• Potential use of a standalone software, OR

• Possibly include in LDAR software currently being used

• Others

• 8. Understanding proper packing bolt loads

• Will minimize variability in performance

• Ensure longer packing life

• Keep valves operable

“Eliminate the USE of LDAR as the name and Change to LMAP (Leak Monitoring and Prevention)

•The Words Detection (leaks will always exist) and Repair (reaction required) immediately lead us to a Negative

•Monitoring and Prevention can both be seen as completely PROACTIVE in nature

The Future is Bright!

Rodney Roth: Strategic Accounts Manager – Stationary Equipment

rothr@chesterton.com

Mark Kelsey: LDAR Business Unit Leader

Mark.kelsey@sageenvironmental.com