Enhanced Leak Detection and Repair Programs for the Chemical Processing Industries

Enhanced Leak Detection and Repair Programs for the Chemical Processing Industries October 19-21, 2010 Reliant Center, Houston, Texas Written by Jim Drago, P.E. Abstract The term, Enhanced Leak Detection and Repair Program, or, Enhanced LDAR, is finding its way into USA petroleum and chemical process plants via consent decrees. Enhanced LDAR is used by the Environmental Protection Agency (EPA), describing actions that plants must take to attain and go beyond regulatory compliance. Enhanced LDAR covers a number of elements such as quality control, training, monitoring, repairs and most notably, equipment upgrades. This paper will summarize the elements of a typical, Enhanced LDAR Program with special emphasis on the element of Equipment Upgrades. This element requires the use of valves with performance warranted valve stem sealing technologies, valve replacement and preventive maintenance programs. Also included is an overview of regulations, approved monitoring methods and consent decrees. Introduction Fugitive emissions from valves are the largest contributor to the fugitive emissions of any plant processing volatile organic compounds (VOC) and hazardous air pollutants (HAP). In the late 1990 s inspections by the EPA of refineries showed that fugitive emissions were being under reported by a factor of 2X 1 and that LDAR programs were deficient. A typical LDAR program in 1990 was staffed with junior part-time managers, work was contracted to the lowest bidder, performance of the Method 21 leak detection procedure was rushed and the general attitude was one of regulatory compliance only, not finding and eliminating leaks 2. For over a decade EPA has focused on refineries and finalized consent decrees at nearly all sites in the USA. The face of LDAR had changed by 2007 and as a result full time staffs of experienced persons lead programs, contractors were chosen for their expertise on a time and materials basis, Method 21 quality over quantity was stressed and specialized database software were owned and maintained by the site s LDAR group 2. Now the enforcement activities of the EPA are focused on chemical processing sites. The evolution of LDAR programs has elevated expectations that LDAR organizations will seek out and eliminate leaks not just monitor to attain compliance. Where LDAR programs come under enforcement scrutiny Enhanced LDAR Programs are considered appropriate injunctive relief. Regulations The Air Pollution Control Act of 1955 was instituted to provide research and technical assistance related to air pollution control 3. In 1962 Rachel Carson s book, Silent Spring launched environmental activism with its exposé of the affects of pesticides on birds and the environment. The Clean Air Act (CAA) of 1963 affected all industrial plant sites, referred to as stationary sources. In 1970 President Nixon instituted the EPA and the CAA was expanded to include mobile sources tail pipe emissions. 1972 saw the institution of the Clean Water Act. In 1990 the CAA was amended to include LDAR programs and the permit process. In this present day EPA has become more aggressive with regards to declaring greenhouse gas (GHG) emission a national health danger, the validity of air permits in the state of Texas 4 and that new or expanded facilities address GHG concerns 5. Table 1 shows the current regulations that require LDAR programs. Federal Regulations Requiring LDAR Programs with Method 21 Leak Monitoring 40CFR: Protection of the Environment Part Description 60 Standards of Performance for New Stationary Sources (NSPS) 61 National Emissions Standards for Hazardous Air Pollutants (NESHAP) 63 NESHAP for Source Categories - Maximum Achievable Control Technology (MACT) 65 Consolidated Federal Air Rule 264 265 Table 1 Standards For Owners and Operators of Hazardous Waste Treatment, Storage and Disposal Facilities Interim Status Standards for Owners and Operators of Hazardous Waste Treatment, Storage and Disposal Facilities 1

Consent Decrees A consent decree is a negotiated agreement between the government (represented by the EPA and Dept. of Justice (DOJ)) and the plant site. In return for not being convicted of guilt the plant is mandated to pay penalties, perform special projects and perform injunctive relief. When an LDAR program is found wanting Enhanced LDAR is deemed the appropriate injunctive relief. Two points of view can emerge during the negotiation process. The plant can feel that the negotiation is legalized extortion and the consent decree process allows regulation to be created without the normal diligence of the process. EPA and DOJ feel that despite ample information guidance on the proper development and execution of a LDAR program it is still a common area of non-compliance. The decrees of 1998 to 2008 required that formal LDAR programs with dedicated management be instituted and all reports be signed by plant managers. Figure 1 shows the decline in fugitive emissions. The decrees of the current day are requiring Enhanced LDAR programs which specify low-leak valve and packing technologies. Table 2 shows recent decrees that specify Enhanced LDAR. Approved Monitoring Methods Method 21 9 uses a vapor analyzer and the Alternative Work Practice 10 (AWP) uses optical methods. Both comply with regulations for measuring emissions. Method 21 allows the use of OVA-organic vapor analyzer or TVA-toxic vapor analyzer, as shown in Figures 2a, b. Each component is approached and sniffed to record the leak concentration at the seal area of the equipment being monitored. This is the traditional and current method for monitoring. In December of 2009 the AWP was accepted as regulation. It utilizes infrared (IR) cameras to view leaks from equipment. The camera Company name and date March 31, 2010 Shell Chemical LP/Shell Chemical Yabucoa, Inc. 6 August 25, 2009 Vertellus Agriculture and Nutrition Specialties, LLC 7 July 31, 2009 Ineos ABS USA Corporation/Lanxess Corporation 6 Table 2 Recent Consent Decrees Requiring Enhanced LDAR Programs 6,7 Injunctive Relief 1) Enhanced LDAR 2) Relinquishing of permits, facility shutdown and installation equipment to curtail the emission of NOx, SO 2 1) Enhanced LDAR 2) Installation of new incinerator. 1) Enhanced LDAR 2) Monitoring and equipment installation for flare, spill reporting and acrylonitrile processes Fig. 1 Fugitive emissions have declined over the last 20 years 8. has not yet been used by any plant site to fulfill regulatory requirements. The procedure of using AWP allows more components to be monitored over a shorter period of time. However, the IR camera Civil Penalties $3.5M $425K $3.1M Required Supplemental Environmental Projects $193K to support educational environmental activities and local emergency organizations. $705K for a two-year project to upgrade pumps with technology that will eliminate fugitive emissions. None survey must be more frequent (every 30, 45 or 60 days) and in addition a Method 21 survey must be done yearly. Figures 3a, b and 4 show the camera in use and screen view. 2

Figure 4. IR camera view. Black plumes indicate leakage. Photo courtesy of FLIR Systems, Inc. Enhanced LDAR Program A leak detection and repair program is defined by regulations. Those regulations define which plant equipment (components) are monitored, set the criteria for what defines a leak, the repair of components to stop leaks, data documentation and reports. The objective is to find and eliminate leaks. An Enhanced LDAR program is beyond regulatory compliance. Table 3 show the elements of Enhanced LDAR. Figures 2 a, b Technicians are using Method 21 to monitor leakage. Photos courtesy of Team Industrial Services. Figure 3a. Technician is using an IR camera to monitor leakage. Photo courtesy of Sage Environmental Consultants, LLC. Figures 3b. Technician is using an IR camera to monitor leakage. Photo courtesy of FLIR Systems, Inc. Elements of Enhanced LDAR Part Title Description A B C D E F G H I J K L M N Table 3 Applicability-General Monitoring Frequency Monitoring Methods and Equipment Leak Detection and Repair Action Levels Leak Repairs Delay of Repair (DOR) Equipment Upgrades, Replacement and Improvement Management of Change Training Quality Assurance and Control LDAR Audits and Corrective Actions Certification of Compliance Recordkeeping Reporting All requirements are in addition and not in lieu of existing local, state and federal regulations. Depends on equipment type valve, flange, pump, threaded connection, etc. and leak performance. Mandates use of Method 21 with a toxic vapor analyzer and data logger. Action levels are the leak levels at which repair is required. Defines the first attempt and final attempt time limits. Criteria allowing a component to be put on the DOR list. NOTE: These lists are a focal point of EPA inspections. Defines the requirements of low-leak valves and packing. Defines a plan whereby all valve components are upgraded. All equipment added to or removed from a plant must be recorded and evaluated with regard to applicable LDAR requirements. All company personnel and contractors responsible for monitoring, maintenance, repairs and any LDARrelated activities must be trained within six months of initiation of Enhanced LDAR. Monitoring data must be certified as accurate and collected according to the standard. Once a quarter monitoring data is randomly checked to assure consistency and compliance. Third-party audits conducted initially and annually. Documentation of the corrective action plan, course of action and outcomes must be submitted to EPA. To all applicable regulations, completion of corrective actions and that all equipment under regulation is documented in the program. Original records of all LDAR audits and documentation of Enhanced LDAR Program compliance must be retained. Annual reports that document compliance with the Enhanced LDAR Program are filed at the specified time periods. 3

Part G Equipment Upgrades, Replacement and Improvement Part G is the most progressive and demanding part of Enhanced LDAR. It is the first time this degree of definition and prescriptive action has been targeted toward valve leaks. Part G requires valve replacement and improvement with low-leak valve and packing technologies. These low-leak technologies must be warranted for performance of 100 ppm and or come with test documentation that exhibits the same. Enhanced LDAR raises the bar from 500 ppm acceptability levels to 100 ppm. It exemplifies the spirit of LDAR that EPA wishes to promote, that is, to actively look for, find and stop leaks. Originally three alternatives were developed: Alternative 1 Preventative Maintenance and Replacement Action Plan (PMRAP) Alternatives 2 and 3 Component Replacement, Improvement and Elimination Programs Alternative 1 has never been written into a consent decree and probably never will. It defines a Preventive Maintenance and Replacement Action Plan (PMRAP) and requires such actions as a leak trend analysis. This analysis would identify which components leak and indentify the causes. Trend analysis would indentify recurring components and causes. The analysis would direct fixes to correct repeat problems. Trending would identify components that were in compliance but weak performers, these would be targets for repair or replacement. This is a very holistic proactive approach. Alternative 2 has been invoked in consent decrees. It is more prescriptive than Alternative 1. The defining terminology of these rules are, low-leak, packing and valve technology. Low-leak is defined as a valve with stem packing that carries a warranty for 5 years able to deliver 100 ppm leak performance and/or a report from a generally accepted test procedure that demonstrates such performance Test methods that could be, generally accepted procedures and good engineering practices. Part Description ISO 15848-1 (International Organization for Standardization) API 622 (American Petroleum Institute) Chevron Texaco GR-500 App. V Shell MESC SPE 77/300 ISA/ANSI 93.00.01 (International Society of Automation) FCI 91-1-1997 (Fluid Control Institute) VDI 2440 (Verein Deutscher Ingenieure- Association of German Engineers) Table 4 can be achieved (Table 4). Currently the regulators are considering more definition with regard to test methods. Industrial valves - Measurement, test and qualification procedures for fugitive emissions - Part 1: Classification system and qualification procedures for type testing of valves Type Testing of Process Valve Packing for Fugitive Emissions Instruction for Selecting, Installing and Use of Packing in Refinery Equipment Procedure and Technical Specification for Type Acceptance Testing (TAT) of Industrial Valves Standard Method for the Evaluation of External Leakage of Manual and Automated On-Off Valves Standard for Qualification of Control Valve Stem Seals Reducing Emissions from Mineral Oil Refineries Warranties are generally subject to valve conditions and installation practices. Figures 5 and 6 are examples of a typical warranty and test data. Figure 5: Typical low-leak packing warranty. 4

Figure 6: Typical data from a low-leak packing test report. Under Part G if a valve stem packing is leaking more than 250 ppm it must be repaired or replaced with low-leak technology within 30 days or at the next maintenance shutdown. If it is found to be leaking between 100 ppm and 250 ppm it must be repaired or repacked according to the equation shown in Table 5. This is the, Enhanced, in Enhanced LDAR. The requirements to use lowleak technology and to replace 10% of the qualified valve population leaking between 100 ppm and 250 ppm are beyond any current regulations anywhere in the USA. This is mandated preventive LDAR aimed at getting the entire population of regulated components well below the screening value of 250 ppm. Alternative 3 of Part G is the same as Alternative 2 except instead of 10% of the qualified valve population, 20% (replace 0.10 with 0.20 in the equation in Table 5) must be replaced or repaired. Connectors that are flanged, threaded, compression, cam-lock and quick-connect types are also addressed in Part G. In the case that a connection if found to be leaking above 250 ppm it must be repaired or replaced with technology that in the judgment of the plant will attain a leak performance below 250 ppm. This is similar guidance to valve stem seals except plant judgments are accepted and warranties with test reports are not required. Conclusions Enhanced LDAR pushes the limits to 100 ppm as the new standard for valve stem seals. LDAR remains a National Air Toxic Enforcement Priority 11. After spending the last 10 years focusing on refineries, EPA investigators and enforcers are concentrating on chemical process plants. Enhanced LDAR will be the norm wherever there are issues with LDAR programs. Equation for the Number of Valves to be Repacked or Replaced Annually VTBRR = 0.10 x (VT VDOR VPRR VPR) VTBRR Valves To Be Replaced or Repacked annually VT VDOR VPR VPRR Table 5 Valves Total number of valves in the process unit. Valves on Delay Of Repair Valves Pending Repair Valves Previously Replaced or Repacked with low-leak technology 5

Referenced Notes: 1) EPA-305-D-07-001, Leak Detection and Repair-A Best Practices Guide, (2007), Appendix E 2) LDAR-Past, Present and Future A presentation by Graham E. Buzz Harris of Sage Environmental Consulting, LP at the Air & Waste Management Association Conference, April 26, 2007 3) Origins of Modern Air Pollution Regulations, EPA website, http://www.epa.gov/eogapti1/course422/apc1.html Jim Drago, P.E. Manager, Business Development Garlock Sealing Technologies, Palmyra, NY Email: jim.drago@garlock.com Phone: 1-315-597-3070 4) EPA rejects air permits of 122 Texas plants - Facilities must reapply; irate Perry says jobs, energy at risk, July 1, 2010 - Houston Chronicle, R.G. Ratcliffe of the Austin Bureau 5) Proposed Rules on Clean Air Act Permitting for Greenhouse Gas Emissions, August 12, 2010, http://www.epa.gov/nsr/actions.html#2010 6) EPA Cases and Settlements - http://cfpub.epa.gov/compliance/cases/ 7) EPA and DOJ reach agreement with Vertellus on Clean-Air Violations, http://yosemite.epa.gov/opa/admpress.nsf/0/4090430d9914b1b18525761d0 058A5C7 8) EPA Toxic Release Inventory (TRI) - http://www.epa.gov/triexplorer/ 9) Method 21 - Determination of Volatile Organic Compound Leaks, http://www.epa.gov/ttn/emc/promgate/m-21.pdf 10) Alternative Work Practice To Detect Leaks From Equipment, http://www.tceq.state.tx.us/assets/public/implementation/air/rules/ ldar/2006_17402.pdf 11) Background Paper for Candidate National Enforcement Priority: Air Toxics, January 2010, http://www.epa.gov/compliance/resources/publications/data/ planning/priorities/fy2011candidates/fy2011candidate-air.pdf General References: 1) Burgard, Drago, Hurley, What is the next Generation of LDAR and How to Get There?, 9th Annual ISA Fugitive Emissions LDAR Symposium, May 2009, Austin, TX, USA 2) Proceedings of the 10th Annual ISA Fugitive Emissions LDAR Symposium, May 2010, San Antonio, TX, USA 3) Siebenaler, Shane (Southwest Research Institute), Testing Standards for Low- Leak Technology, 10th LDAR Symposium 4) Ross, Bill (Chevron Corp.), Fugitive Emissions, American Petroleum Institute SCOPV Spring 2010 Minutes Attachment 5) Drago, Jim, Optical technologies monitor leak detection, fugitive emissions, Plant Engineering, June/July 2010 6