Low-Leak Valve Technology An Update Standards Certification Education

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 Y Optional Pro-Active Monitoring N N N N Y Install New Valves/ Packing with Low-E Y Y Y Y Replace/Repack Existing Valves Leaking > 250 ppm with Low-E Y Y Y Y Replace/Repack Existing Valves Leaking Between 100 -250 ppm with Low-E Y Y N N N Replace/Repack Existing Valves during Turnaround N N N N Y Commercial Unavailability Y Y Y Y A-Ineos Lanxness; B-Vertellus; C-Formosa; D-Dow; E-Sabic; F-Ineos Lima; G-Du. Pont; 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 M 21 Low-E valve population leak rate < 0. 1%, annual M 21 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 % 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 M 21 – Low-E; 1 st year (2 quarters, then semiannual M 21), 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 Over 5 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 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?

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