Improving Valve Fugitive Emissions Performance

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Cleopatra McCormick
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1 Improving Valve Fugitive Emissions Performance Steve McJones and Rich Sobilo March 6, 2014

2 Steve McJones Advisor Pressure Vessels, Piping and Valves BP Refining & Logistics Technology Support BP Refineries Worldwide Chairman - API Sub Committee on Piping & Valves 2014 BP Products North America Inc. All rights reserved

3 Rich Sobilo, P.E. Technical Authority Fixed Equipment BP Whiting (Indiana) Refinery Valves, Tanks, Fire Protection, and Relief Valves Director of Engineering Union Tank Car Company, Manufacturer and Lessor of Rail Tank Cars Also manufactured angle, ball, vacuum and pressure relief valves

4 Improving Fugitive Emissions Performance BP Refining and Marketing Whiting, Indiana Refinery 80,000 Monitored Valves in our LDAR Program Executed an EPA consent decree in 2012 Working on Improvements since Valves on a Turnaround Worklist Approximately 20 Units in the Refinery on an Average 5-Year Turnaround Cycle

5 Improving Fugitive Emissions Performance Valve Failures Stem Packing Leak Bonnet Leak 77% Flange Leak Leaks Through Seat Valve Inoperable Other

6 Improving Fugitive Emissions Performance BP emissions testing During the 1990s BP conducted a number of tests in order to obtain an understanding of the problem and explore possible solutions. The general conclusions are summarized below: Tests on rising stem gate/globe valve packings showed that: All graphite packings perform better than asbestos; Some relatively simple low to medium density graphite packings with braided end rings can give very good performance; The best performance was obtained from an "engineered" design of packing with some pressure energizing capability;

7 Improving Fugitive Emissions Performance BP emissions testing (continued) Graphite packings generally are relatively insensitive to stem damage; Stem straightness and run-out must be carefully controlled; The gland follower must be guided on the packing chamber, not the stem; Whilst good surface finish and close tolerances may give improved sealing performance, these parameters need not be better than is currently being achieved by the leading valve manufacturers (and very smooth finishes obtained by burnishing are positively disadvantageous). Very smooth stem finishes produced by burnishing, etc. are detrimental to good sealing of graphite packings.

8 Improving Fugitive Emissions Performance Typical Rising Stem Valve Packing Specification Die-formed flexible graphite with top and bottom ring of braided carbon yarn. Typical Quarter Turn Valve Packing Specification Kalrez or modified nitrile o-rings and die-formed flexible graphite rings with top and bottom rings of braided carbon yarn.

9 Improving Fugitive Emissions Performance Prior to consent decree Chronic Leakers Complaints for Unit Personnel Turnaround Worklist Various Strategies Maintain - Tighten gland nuts -Repack - Recondition -PumpUp Replace - Select Manufacturers - New Technologies

10 Improving Fugitive Emissions Performance Prior to consent decree Maintain More rigor around re-tightening Expanded use of reconditioned valves Repacking with Live-Loading Replace Best performing manufacturers (LDAR Database) Expanded use of valve replacement due to economics

Improving Fugitive Emissions Performance Valve

Up Processing New valve costs Procurement, etc.

11 Improving Fugitive Emissions Performance Valve Failures 77% Buying a new car instead of fixing the flat! Repairs (re-tightenings) Re-monitoring Pumping Up Processing New valve costs Procurement, etc. Installation Quality Control, etc. We consider the Life Cycle Cost of the installed valve

12 Improving Fugitive Emissions Performance Prior to consent decree Replace Expanded use of valve replacement due to economics New Valves Better Results About 20% of valves replaced in 2007 were on the work list again in 2012 Many had leaks within the first year

13 Improving Fugitive Emissions Performance This is still prior to consent decree (2011) Whiting tried to improve performance of new valves by requesting testing The level of testing and cooperation was mixed to put it mildly, ranging from nothing to very thorough (various valve types and sizes) Even when testing was performed, there were numerous variables to decipher: Packing or valve test In house, supervised/certified or outside lab testing Valve randomly selected Test type (API 622, ISO 15848, Company Tests, etc.) Emissions limit (100 ppm or 500 ppm) Test attributes (Cycles, temperature, pressure, media, etc.)

14 Improving Fugitive Emissions Performance Due to consent decree Must Purchase a Certified Low- Leaking Valve, Or Repack with Certified Low- Leaking Packing Limited, Pre-Defined Strategies Maintain - Tighten gland nuts - Repack (Certified Low-Leaking) - Recondition (Repack) -PumpUp Replace - Certified Low Leak Valve - New Technologies (Certified)

15 Improving Fugitive Emissions Performance Consent decree, BP Whiting and the EPA July 2012 Part G Valve Replacement/Improvement Program Certified Low-Leaking Valves/Packing a. Certified Low-Leaking Valves shall mean valves for which a manufacturer has issued either: (i) a written guarantee that the valve will not leak above 100 parts per million (ppm) for five years; or (ii) a written guarantee, certification or equivalent documentation that the valve has been tested pursuant to generally-accepted good engineering practices and has been found to be leaking at no greater than 100 ppm. 1. Guarantee by a Letter (5 <100 ppm) 2. Generally accepted good engineering practice At Whiting, we have been analyzing test results

16 Improving Fugitive Emissions Performance Whiting created a Specification WBU-GIS Rising Stem Valves require successful Testing Quarter-Turn Valves require only a Guarantee

17 Improving Fugitive Emissions Performance Other important items in WBU-GIS Procurement Responsibility 5.0 Testing Requirements 6.0 Valve Selection 7.0 Type Testing (API RP 591 ISO ) 8.0 Independent Testing 9.0 Test Documentation 10.0 Listing of Approved Valves Internal Web Site 11.0 Packing Corrosion Resistance 12.0 Results Ranking Annex A Fugitive Emission Test Summary Annex B Fugitive Emission Guarantee Example

18 Improving Fugitive Emissions Performance AML Approval Procurement FE Data Solicitation and Collection Quality Assurance Data Analysis and Approval Recommendation Reliability Engineering FE Approval WBU AML Vendors Supplied FE Packages - 98 Suppliers Qualified - 24 Valve Categories -6 Disqualified - 26 Provided Insufficient Data

19 BP WBU AML Qualification Progress BP WBU FE Qualification Progress Data Suppliers FE Packages Suppliers Qualified Suppliers Disqualified Suppliers Insificient FE Data 1/22/2014 1:03:45 PM; BP QA: D. Filipovic

20 Improving Fugitive Emissions Performance We solicited over 250 (valve) manufacturers from our Procurement records Obviously many of them were no longer in business, many had been consolidated into larger, parent companies We had to have a way to judge performance and decipher the various testing performed thus far WE NEEDED TO BUY VALVES!!!! BP approved distributor contributed to FE data collection We developed a methodology of analyzing and judging performance of various test data, we then added that to our specification when it was finalized

21 WBU-GIS WBU-GIS The specification lays out parameters for providing relativejudgment of the tests We judged the testing against industry standards and each other: Relative Test Comparison Comparison to Industry Standards Performing Entity (Independent Lab?) Media Mechanical Cycles Thermal Cycles Maximum Temperature Pressure Maximum Leakage Rate (ppm) Mean Leakage Rate (ppm) Gland Nut Adjustments Performed/Allowed Media Mechanical Cycles Thermal Cycles Maximum Temperature Pressure Maximum Leakage Rate (ppm) Mean Leakage Rate (ppm) Gland Nut Adjustments Performed/Allowed

22 Sample Test Reports

23 Test Attribute Scoring

24 Scores By Test Attribute

25 Quarter-Turn Certification Review

26 Standard Industry Test Comparison

28 Sample FE Test Graph

29 Ranking of Rising Stem Test Results

30 Ranking of Quarter-Turn Valve Documentation

31 BP QA PDCA for Valve FE

32 Reliability Engineering The Ultimate Goal is to minimize fugitive emissions How Are We Doing This? Robust Approval of Manufacturers New Packing Technology New Valve Technology Reconditioning Valves Repacking Valves (fixing the flat)

33 Reliability Engineering Valve established as leaker Reconditioned Valve Valve Replacement Replace New Valve Consider life cycle cost, severity of the leak, age of the valve, other issues, current valve design or manufacturer, application for decision on replacement Maintain Valve Maintenance Enhanced Design In-Kind Drill and Tap Repacking Retightening Valve Design Packing Design

34 Improving Fugitive Emissions Performance Other strategies Limited, Pre-Defined Strategies Replace - Certified Low Leak Valve - New Technologies New Technologies o Installation of Bellows Seal Valves High mechanical cycling Thermal cycling Historic poor performance

Improving Fugitive Emissions Performance Other strategies Limited, Pre-Defined Strategies Maintain - Tighten gland nuts - Repack (Certified Low-Leaking) - Recondition (Repack) -PumpUp Repack and

35 Improving Fugitive Emissions Performance Other strategies Limited, Pre-Defined Strategies Maintain - Tighten gland nuts - Repack (Certified Low-Leaking) - Recondition (Repack) -PumpUp Repack and Recondition o Use of Approved Packing Materials (approved by WBU-GIS ) o Use of Live-Loading based upon service, operating conditions o Detailed examination of stuffing box components and installation: Clearances Surface finishes Packing dimensions Sequencing and torque WBU Valve Reconditioning Specification WBU-GIS Appendix D

36 Improving Fugitive Emissions Performance Reconditioning Repacks

37 Improving Fugitive Emissions Performance How are we doing? It s very early! Struggles in using LeakDas Database for reliability work Refinery Wide Data Some data focused on one Unit Close to 300 Valves Last Turnaround in 2012, previous Turnaround in 2012

38 WBU FE Testing 2008 Results vs BP WBU FE Test's vs % to 0.9% Test Count WBU FE TEST Total Pass Fail Total Pass Fail 1/23/2014 2:32:09 PM; BP QA: D. Filipovic

39 ISOM Valve Leaks 2008 vs ISOM Valve Leaks vs Data % Decrease 1000 No Bellows Leaks Isom Valves Total Pass Fail Total Pass Fail 86 Total 86 Pass Bellows 0 Fail 1/22/ :43:45 AM; BP QA: D. Filipovic

40 ISOM Leaks by Year ISOM Valve Leaks Over 499 ppm by Year Leaks Over 499 ppm Year 1/22/ :20:24 AM; BP QA: D. Filipovic

41 ISOM Leaks by PPM Range 2008 vs ISOM Valves - Leak Range in PPM Reductions in every range -180Less Leaks for one year in one Unit Data PPM PPM PPM PPM PPM PPM PPM > PPM >10000 Valves PPM 1/27/2014 8:57:25 AM; BP QA: D. Filipovic

42 Improving Fugitive Emissions Performance Summary of Data LeakDas database issues Multiple Leaks Leak Definition 100 vs. 500 ppm Change-out of Tags Refinery Wide Leak Rate ( 07 vs. 13) 30% reduction One Unit (ISOM) Data ( 07 vs. 13) 180 less leaks per year Sample Replacement ( 07 vs. 13) Bellows Seal No bellows leaks after 18 months Overall our performance has been trending positively even though we have only been at it for a couple of years

43 Improving FE Performance Path Forward Continue to Track Performance using LDAR Database Tweak Database to make it more friendly for reliability work Judge performance of more reliable solutions (Life Cycle Analysis) Tighten, re-monitor, pump-up, procure, remove, install pre-maturely on some percentage of valves Focus on Chronic Leakers within Units Enhance Reconditioning Program Continue our Quality Assurance Program for Valves vs. Replacing with a longer life (Higher MTBF) alternative

44 Path Forward Use Results from Repacking Data Acceptable clearances for future repair work Run Fugitive Emission testing with worn conditions Modify Valve Reconditioning Specification based upon Results and Field Performance Review API 624 Test Results Secure Design Data from Manufacturers Ensure Packing Make and Model Clearances (Stuffing box to Gland; Gland to stem, etc.) Finishes (Stem OD, Stuffing box ID)

45 Thank You! Thank you for your attention and participation Questions?

Fugitive Emissions Standards & Laboratory Test Methods for Valves

Fugitive Emissions Standards & Laboratory Test Methods for Valves By: Greg Johnson President, United Valve 50 Years in 50 Seconds 1964 Houston air pollution Measuring air pollution in 1974 1 50 Years in