Standards Certification Education & Training Publishing Conferences & Exhibits 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 –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 Requirement Chemical Plant A 2009 B 2009 C 2011 D 2012 E 2012 F 2012 G 2013 H 2013 Valve Tightening Work Practices NNNNNNNY Optional Pro-Active Monitoring NNNNNNNY Install New Valves/ Packing with Low-E YYYYYYYY Replace/Repack Existing Valves Leaking > 250 ppm with Low-E YYYYYYYY Replace/Repack Existing Valves Leaking Between ppm with Low-E YYNNNNNN Replace/Repack Existing Valves during Turnaround NNNNNNNY Commercial UnavailabilityYYYYYYYY 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 Valve SizeSize % of Valve Population Assumed “Regular” Valve Cost Assumed Low-E Valve Cost Small≤ 1”47%$250$ Medium1” < 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; 1 st 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 Valve Type Direct Costs Indirect Costs Over 5 Yrs Monitoring Costs Over 5 Yrs Leak Repair Costs Over 5 YrsSum 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

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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