15th LDAR Symposium

May 19-21, 2015

New Orleans, LA

Development of
Emission Factors from
API 622/624 Test Data
Buzz Harris and Bronson Pate
Sage Environmental Consulting
Standards
Certification
Education & Training
Publishing
Conferences & Exhibits

Presenter Information

Buzz Harris holds a BS in Chemical Engineering with 45

years experience and still learning
Bronson Pate holds a degree in Engineering with 8 years
of full time experience plus 3 years of internships in
LDAR during university studies

Overview
Low Emission (Low E) Technology Introduction
Primary US tests for Low E packing and valves use
methane and include Method 21 type readings
Tests are based on accelerated wear that should be
representative of 5 years or more of field operations
EPA is requiring Low E in new Consent Decrees and
encouraging voluntary application
Emission Factors (EF) and control efficiencies can be
developed from the test readings, which, if approved,
would provide more incentive to use Low E in any new
construction
Conclusions
3

Low E Technology
There have always been packings and valves that were
more or less likely to leak
Only recently, however, have we had guarantees,
warranties, and, most importantly, test data to prove
manufacturers claims of low emissions
Based on hard data, EPA has begun to require Low E in
Consent Decrees written over the last 4 to 5 years
Several companies had begun their own Low E testing
and implementation voluntarily before that
The use of Low E is gradually being recognized as cost
effective and just good business

Fugitive Emissions Testing

A number of valve and packing tests have been developed:
ISO 15848-1 is an EU and British standard that allows
testing by either helium or methane, with most test data
to date done with helium
API 622 is a packing test using methane
API 624 is a valve test using methane
ChevronTexaco test procedure is similar to API 622, but
it tests packing in a valve and includes more wear cycles
Shell also has its own packing test
The API test procedures have more industry wide
applicability and focus on methane testing

API 622 and 624 Details

Comparison of Service Parameters: API 622 and API 624
Standard identification
Title and edition

API STD 622

API STD 624

Type Testing of Rising Stem Valves Equipped

Type Testing of Process Valve Packing for
with Graphite Packing for Fugitive Emissions,
Fugitive Emissions, Second Edition
First Edition

Date

Standard by the American Petroleum

Institute, 10/01/2011

Standard by the American Petroleum Institute,

02/01/2014

Pass Criteria
Equipment
Packing adjustment
Media
Temperature
Pressure

500 ppmv maximum after one adjustment

Specified fixture simulating a valve
One allowed1
Methane 97% minimum purity
500F (260C)
600 psig (41.4bar-g)

100 ppmv maximum

Valve being qualified
None allowed
Methane 97% minimum purity
500F (260C)
600 psig (41.4bar-g)

Number of valve stem actuations

1510

310

Number of thermal cycles

Leak measurement method

Method 21

Method 21

Leak measurement details

Done with stem in static state

Done with stem in static and dynamic states

Leak measurement frequency

Every 50 actuations of the stem

Every 50 actuations of the stem

PreparedbyandusedwithpermissionofGarlock

API 622 Test Data

PPM Readings in API 622 and 624

Probe split in two to simultaneously check
both stem and packing
Tin foil used as a partial shroud to try to
collect leakage from any point around the
stem and packing
Record ppmv data over a minute and report
the average and maximum with no
background correction
Some report both static and dynamic (stem
moving) readings
This paper uses the maximum readings
recorded in either static or dynamic modes
This should be conservatively higher than
traditional M21 readings

Mass Emissions from ppm

For petroleum industry:
Default Zero EF (reading zero) = 0.0000078 kg/hr/source
Correlation equation = 2.29*10^-6*SV^0.746 kg/hr/source

For chemical industry:

Default Zero EF (reading zero) = 0.00000066 kg/hr/source
Correlation equation = 1.87*10^-6*SV^0.873 kg/hr/source

No need for Pegged EF in Low E testing!

These emission estimates are for the instant the
measurement occurs
Still need to estimate emissions over time
9

Accelerated Wear Time

API 622 includes 1510 mechanical wear cycles and 5
thermal stress cycles
API 624 includes 310 mechanical wear cycles and 3
thermal stress cycles, but also requires packing to have
passed API 622 before 624 testing
The tests take place over 3 to 6 days, but represent a
much longer period because of the accelerated use
The equivalent process life may vary with:
Continuous vs. batch processes
Process application of the valve (manual isolation, drain,
sample, motor operated, control, etc. valve)
Other factors too process specific for consideration here

10

Continuous Process Cycles to Time

Accelerated Wear Cycles to Operating Time
Continuous Processes

Frequency per year

% of Total

Weighted Frequency

Valve Application

Low End

High End

Valves

Low End

High End

Manually operated block isolation valves

10

78%

0.78

7.8

Block valves isolating pumps

24

2%

0.1

0.48

Drain valves

12

120

5%

0.6

Sample valves

52

795

2%

1.04

15.9

Motor operated valves

150

1000

2%

20

Process control valves

500

5000

11%

55

550

Totals

720

6949

100%

60.52

600.18

Average Annual Operation Cycles

330.35

Years of Operation for 1510 Operating Cycles

4.57

11

Batch Process Cycles to Time

Accelerated Wear Cycles to Operating Time
Batch Processes

Frequency per year

% of Total

Weighted Frequency

Valve Application

Low End

High End

Valves

Low End

High End

Manually operated block isolation valves

12

365

75%

273.75

Block valves isolating pumps

24

365

2%

0.48

7.3

Drain valves

12

365

5%

0.6

18.25

Sample valves

52

795

2%

1.04

15.9

Motor operated valves

150

1000

5%

7.5

50

Process control valves

500

5000

11%

55

550

Totals

750

7890

100%

73.62

915.2

Average Annual Operation Cycles

494.41

Years of Operation for 1510 Operating Cycles

3.05

12

Continuous Process Thermal Cycles to Time

Thermal Cycles to Operating Time
Continuous Processes:

Scheduled

Unsheduled

Total

Run Lengths Between T/A, yrs

Shutdowns/yr

Shutdowns/yr

Shutdowns/yr

0.20

0.5

0.70

0.25

0.4

0.65

0.33

0.3

0.63

0.50

0.2

0.70

1.00

0.1

1.10

Average

0.76

Years Operation for 5 thermal cycles

6.61

13

Batch Process Thermal Cycles to Time

Thermal Cycles to Operating Time
Batch Processes:

Scheduled

Unsheduled

Total

Campaign Run Lengths, days

Shutdowns/yr

Shutdowns/yr

Shutdowns/yr

30

12.17

0.05

12.22

20

18.25

0.04

18.29

10

36.50

0.03

36.53

73.00

0.02

73.02

365.00

0.01

365.01

Average
Years Operation for 5 thermal cycles

101.01
0.05

14

Summary Accelerated Wear Time

1510 mechanical wear cycles represent 3.1 to 4.6 years
of operating time for batch/continuous process units
5 thermal cycles represent 0.1 to 6.6 years of operating
time for batch/continuous process units
EPA defines Low E as <100 ppm operations for 5 years,
and accepts API 622 data as satisfying that definition
The thermal cycles in API 622 falls far short of the potential
thermal cycles in 5 years for a batch process, but
API 622 accelerated wear cycles average to around 5 years
equivalent operation for continuous operating units and
mechanical wear for batch units

This paper, therefore, assumes that the API 622/624

readings are spread evenly over a 5 year period
15

API 622 Emissions Over Time Example

1510 cycles with a reading every 50 cycles (including
beginning and end readings) results in 42 readings
42 readings spread evenly over 5 years would be one
reading every 45.6 days (roughly every 6 weeks)
Default zero and correlation equations for petroleum and
SOCMI are used to calculate instantaneous emission
estimates
Emissions from the previous to current readings are
averaged over the 45.6 days between readings
Emissions are summed over the 42 total readings and
divided by the time in years to create an average
emission factor in kg/yr/source
Emission Factor for static and dynamic readings are
averaged

16

API 624 Emissions Over Time Example

310 cycles with a reading every 50 cycles (including
beginning and end readings) results in 14 readings
14 readings spread evenly over 5 years would be one
reading every 140.4 days (roughly semi-annual)
Default zero and correlation equations for petroleum and
SOCMI are used to calculate instantaneous emission
estimates
Emissions from the previous to current readings are
averaged over the 140.4 days between readings
Emissions are summed over the 14 total readings and
divided by the time in years to create an average emission
factor in kg/yr/source
Emission Factor for static and dynamic readings are
averaged

17

Emission Factors Summary

API622and624testsreportswereprovidedbyandthanksgoto:
RonWaltersofTeaditNorthAmerica
ToddHaberkostofLadishValves
JimDragoofGarlock
ScottBoysonandRodneyRothofA.W.ChestertonCompany
JoshErdofNipponPillarCorporationofAmerica
18

Low E Emission Factor Considerations

All of these emission factors calculated from low
emission packing and valves are near the default zero
emission factor for valves
One approach to encourage voluntary use of Low E would be to
allow use of the default zero factor to predict emissions for
permitting
Another approach would be to allow an average emission factor
(or control efficiency) for Low E valves and packing to date to be
used to predict emissions for permitting
Another approach would be to require applicants to include
calculations of an emission factor for the specific Low E
equipment they will use

19

Control Efficiency Approach

In lieu of developing emission factors for Low E, it would

also be possible to develop a control efficiency for
application of Low E that could be applied to the normal
average emission factor
The following table shows control efficiency estimates
calculated as:
CE%=(1-(Average EF/Low E EF))X100
Each Average EF above is for valves in a specific service category
in a specific industry
Each Low E EF above is for valves in a specific industry, but all
testing is done on Gas/Vapor service (methane, 600 psi)
20

Low E Control Efficiency

LowEEmissionFactorsaretheaverageofalltheAPI622/624testsusingeitherpetroleum
orchemicalcorrelations/defaultzeroemissionfactors.
21

Conclusions
The measurements done in API 622/624 testing give
methane ppmv data that can be used to estimate
emissions
API 622/624 are accelerated wear tests that appear to
represent a five year period for the average valve (with
the exception of thermal cycles on a batch process)
Emission factors (EFs) developed for API 622/624 data
range in value from 4.6E-6 up to 1.8E-5, falling about
one order of magnitude higher than the default zero EFs
(6.6E-7 up to 7.8E-6)
Control efficiency numbers for the Low E EFs compared
to EPA Protocol Average EFs range from 97.3 to 99.9%
22

Conclusions
These Low E EFs and control efficiencies could be used
for permitting, where actual components that can be
monitored do not exist yet
EPA should also consider allowing use of Low E EFs for
non-monitored valves (such as HL service, UTM, etc.)
Neither EPA nor the states currently accept these Low E
EFs and control efficiencies for permitting
We ask that EPA review these calculations and/or
replicate their own approach to similar calculations
EPA-sanctioned Low E EFs and/or control efficiencies
would add another incentive for every new facility or
modification to be done with Low E technology
23