Visual Indication: Simple Solutions for Ambitious Commitments

To successfully achieve the targets defined by the ambitious GHG commitments, both the expansion of emissions control regulations to equipment and sites yet to be regulated, and the adoption of new technologies and practices are inevitable. One needs to look no further than recently proposed rules to find an example of the mandated implementation of new technology.

By Foster Voelker II, Director of Engineering – Williams Valve

Net Zero Goals

Net zero greenhouse gas commit­ments (GHG) are at the forefront of discussions regarding the future of business and geopolitics. According to the United Nations website, “more than 70 countries, including the big­gest polluters – China, the United States, and the European Union – have set a net-zero target, that covers ap­proximately 76% of global emissions. Over 1,200 companies have put in place science-based targets in line with net zero, and more than 1,000 cit­ies, educational institutions, and over 400 financial institutions have joined the Race to Zero, pledging to take rigorous, immediate action to halve global emissions by 2030.”¹

These commitments have already had an impact on policy, as can be seen with the EPA’s response to President Biden’s executive order issued on January 20th, 2021 titled: ‘Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis’. According to the U.S. Small Business Administration’s Of­fice of Advocacy, “On November 15, 2021, the Environmental Protection Agency (EPA) published a proposed rule titled “Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review.” The EPA pro­posed rule includes a new Appendix K, which establishes requirements for Optical Gas Imaging (OGI) to de­tect methane leaks.² This proposed rule would directly regulate methane emissions from new and modified sources (NSPS) and establish stan­dards for state regulation of methane emissions from existing sources (EG). Existing sources include sources sub­ject to EPA regulation under the 2012 NSPS and the 2016 NSPS for this in­dustry, as well as some sources never before subject to EPA regulations.²

Leak Detection is Key to Success

Implementation of new technologies because of EPA regulations is noth­ing new. In the refining sector, con­trolling fugitive emissions has long been a core focus of the EPA. It has ensured that enhanced leak detection and repair (LDAR) programs and cer­tified low leak technology (CLLT) re­quirements are targeted at valves and mechanical packing. As a result, over the past several years, the adoption and utilization of these CLLT technolo­gies has become standard practice at refineries.

With the expansion of regulatory re­quirements to new facilities, the tech­nologies and protocols common in the refining sector will need to be imple­mented at these facilities. Leak detec­tion is key to developing an effective emission reduction program. The dis­cussion around new technologies is therefore often focused on technolog­ical advancements in leak detection, such as OGI or acoustics, and direct emission offsets, such as carbon cap­ture and biofuels. While important, leak detection and subsequent re­pair are reactive approaches to emis­sions reduction as the leak must first develop and be identified; they ig­nore an integral part of an effective program, proactive maintenance. De­velopments in maintenance and CLLT technologies may offer proactive solu­tions that could benefit these newly affected sites.

Proactive Technologies

Historically, in the refining sector, once a leak is detected, maintenance personnel would make two attempts at repair. If those attempts were unsuc­cessful, an extraordinary attempt at re­pair was made, typically via drill and tap. Drill and tap is a repair method where a hole is drilled into the valve stuffing box and tapped, so that an ad­ditional small valve and fitting can be attached. A packing gun is connected to this fitting and the small valve is opened to allow new packing material to be pumped into the stuffing box.

The valves found in the refining sec­tor, especially multiturn designs such as API 600, typically do not have stem seal injection ports as a standard. Hence the necessity for the drill and tap repair previously mentioned. How­ever, many valves found at other facili­ties, like API 6D, come equipped with injection ports as a standard, through the conduit gate valves, see Image 1, and trunnion ball valves, see Image 2.

While standard injection ports allevi­ate the need to drill and tap, the port offers no benefit in detecting leaks. The traditional apparatuses utilized to identify leaks such as cameras, flame ionization detectors, acoustic detectors, etc., require a costly equip­ment purchase and personnel training. These methods also unfortunately re­quire the leak to be present.

A desire to proactively maintain equip­ment and prevent leaks has led one company, J-S Machine and Valve Inc., to develop a patent-pending injection fitting that has a visual indicator allow­ing maintenance personnel to identify load loss by sight without any addi­tional equipment.

Mike Dunn, owner of J-S Machine and Valve Inc., refers to this fitting upgrade as “a visual indication retrofit for valves equipped with injectable packing.” How­ever, the fitting is not limited to valves already equipped with injection fittings and can also work with a drill and tap repair. Mike notes that while there have been similar concepts, the simplicity of this design is the main differentiating feature. No modification is needed, and maintenance personnel can pack the valve with the same procedures used with previous fittings. As the injectable packing degrades over time, the visual indicator on the injector moves to a point that visually shows maintenance personnel that the valve has lost pack­ing compression.

Not only does the retrofit provide a vi­sual indication of required maintenance, it contains springs that are engineered to provide a dynamic load on the pack­ing similar to traditional live load or Bel­leville washers. The spring load can be varied based on a specific stress require­ment. This maintained load can help to prevent leaks from forming and when combined with the visual indicator, of­fers a robust proactive maintenance so­lution to prevent leaks that is easy to in­stall and works with existing equipment.

Conclusion

Moving forward, a truly effective emis­sion reduction program will utilize tech­nologies both proactively and reactive­ly. Purchasing specifications requiring CLLT valves and packings, maintenance programs that mitigate leak poten­tial with visual indicators and routine packing adjustments, leak detection and repair programs utilizing CLLT in­jectables as well as other unforeseen improvements driven by regulations. New facilities falling under regulatory requirements for the first time would be wise to take advantage of all the tech­nologies currently available for emis­sion reduction, including underutilized solutions like visual indicators.

REFERENCES

1. https://www.un.org/en/climatechange/net-zero-coalition
2. https://cdn.advocacy.sba.gov/wp-content/uploads/2022/02/01095333/Fact-Sheet-Oil-and-Gas-NSPS-EG-NPRM.pdf