Originally posted at Valve-World-Americas.com
Technology has been a catalyst for the rapid growth of civilization over the past century. Industries such as petroleum, chemical, and oil & gas have relied on established methodologies. Now, individuals stand on the cusp of significant technological advancements that promise a change in production capabilities, profit preservation, and emissions reduction.
The valve design is overdue for a change. One can best understand where the industry is heading in the future by reviewing where it came from. Specifically, it is beneficial to look at the history of valve design and the problems that advancements sought to solve.
By Bronson Pate, Vice President MagDrive Technologies, and Gobind Khiani, President GAPV Incorporated
A Brief Look Back
Many say the first valve was developed during the Roman Empire and made of bronze. However, it was not until 1705, when the first steam engine was created, that new and improved valves were needed to regulate steam and high pressure. Lessons learned from steam engines also improved valves used in irrigation and plumbing. The door had been opened, and the 1800s and 1900s gave birth to valve manufacturing at scale.
As the world’s energy needs increased and society moved from steam to fossil fuels, new problems arose, including fugitive emissions and leaking valves. The American Petroleum Institute (API) was established in 1919 and developed standards for valves to help reduce fugitive emissions in the United States of America, specifically to the petroleum industry. A few years after API was established, the International Organization for Standardization (ISO) was founded in 1947 by 25 countries. These two committees have developed the principal ‘Good Engineering Practices,’ which are used most today. ISO 15848-1, API 622, 624, and 641 all have a significant impact on helping reduce the overall impact of emissions on the environment.
During the proposal of the regulations in the 1980s, the United States Environmental Protection Agency (USEPA) recognized ‘Leakless Equipment.’ Although the proposed rules would not require leakless equipment in facilities, this equipment was not widely accepted, and the emission reduction per the control cost was unreasonable. Therefore, the USPEA suggested that if someone wanted to use leakless equipment, they would be allowed to as an alternative to compliance. Some components, as per the USEPA, can meet the definition of No Detectable Emissions (NDE). NDE is ‘indicated by an instrument reading of less than 500 ppm above background.’
The mid-2000s brought the first Consent Decrees requiring Certified Low Leaking Technology (CLLT) for all valves and packing newly installed into plant environments, limiting leaks to a <100 part per million by volume leak rate.
The Need for Leak Control
The Environmental Protection Agency, under the direction of President Biden, is proposing changes to the Clean Air Act, 40 CFR 60. A proposal released in the Federal Register on November 15th, 2021, first mentioned this. After a year of comments, the EPA released an update to this proposal that was printed in the Federal Register on December 6, 2022. The EPA proposes revising new source performance standards for greenhouse gas and volatile organic compound emissions from the (O&G) industry. The EPA is requiring the United States to establish emission guidelines that follow the new performance standards to reduce greenhouse gas emissions. One area where the EPA is looking at reducing methane and volatile organic compounds is by disallowing the use of natural gas-driven controllers at new, reconstructed, and modified sources of emissions.
According to the 2021 Inventory of U.S. Greenhouse Gas Emissions and Sinks (GHGI), pneumatic controllers in petroleum systems are responsible for 700 metric tons of methane emissions, and pneumatic controllers in the natural gas industry are responsible for 1.4 million metric tons of methane emissions. These amounts represent 45% and 22% of all methane emissions in the petroleum and natural gas industries, respectively. Carbon Limits produced a report for the Clean Air Task Force that identified pneumatic controllers as the second-largest source of methane emissions in the O&G industry, only behind component leaks.
Valve standards like those listed are critical, as 90% of all fugitive emissions come from valves and connectors, according to the United States Environmental Protection Agency (USEPA) in the “Leak Detection and Repair: A Best Practice Guide” of 20101.
New Regulations
Gas-powered actuators and pneumatics have traditionally been used on O&G facilities and pipelines as a reliable and low-cost option to control the process through actuated valves and controllers, including powering pneumatic pumps. The higher energy is then vented to the atmosphere; greenhouse gas and methane gas are vented with a potential for global warming between 35x to 120x greater than that of carbon dioxide. It is important to eliminate/reduce methane and GHG venting from these sites to minimize the environmental impact of emissions and to maintain the sustainability of the industry.
The EPA documents call out three different types of natural gas-driven pneumatic controllers, high-bleed, low-bleed, and intermittent controllers. High-bleed controllers emit more than 6 SCFH of methane and VOCs, low bleed emits less than 6 SCFH of methane and VOCs, and intermittent vent methane and VOC’s only during operation. The high-bleed and low-bleed controllers are commonly used on control valves while the intermittent bleed controllers are mostly used on isolation valves. One might think most methane emissions come from high and low bleed controllers, but the GHGI report indicated 88% of all methane emissions mentioned above come from intermittent controllers. Many field studies indicate that the average emission rates exceed the manufacturer’s published data.
Once the new regulations, called OOOOb New Source Performance Standards and OOOOC Emission Guidelines, go into effect, the installation of natural gas-driven controllers that emit gas will be restricted to very few applications. Certain states and Canadian provinces have already implemented restrictions on using gas-emitting pneumatic controllers. The Colorado Air Quality Control Commission implemented regulation Number 7 which requires the use of non-emitting gas controllers at new and modified sites beginning May 1, 2021. Operators in Colorado had to begin replacing gas-emitting controllers by May 2022. The province of British Columbia updated its regulation 52.05 which required a reduction in the use of natural gas driven pneumatic controllers beginning January 1, 2021. The province of Alberta implemented Directive 60 which requires any pneumatic instruments installed on or after January 2022 must be zero-emission controllers. The states of New York and New Mexico are also considering only allowing zero-emission controllers.
These proposed regulations, along with public pressure and the financial pressure brought about by the ESG requirements, are going to affect all segments of the O&G industry. As with most actuator applications, there are multiple options depending on, among other things: location, number of controllers at a location, type of controllers already installed, operating media, customer philosophy, history with various products, and economics. The economic consideration can be broken down into several categories, such as initial material cost, total installed cost, total cost of ownership, etc.
Due to this pressure, the oil and gas industry is looking into the following options:
The best approach depends on the specific needs and resources of each site. Implementing zero venting strategy can help minimize the environmental impact of these GHG and methane emissions towards the sustainability of the industry.
The proposed regulations focus on what the EPA refers to as the ‘best available control technology’. With relatively few exceptions, the stated best system of emission reduction is to require the use of zero-bleed controllers.
One item to note is the owner of this equipment is going to be required by the new regulations to perform quarterly inspections using optical imaging equipment and maintain records of these inspections and any repairs deemed necessary. There are organizations out there that manufacture a recompression retrofit kit for existing gas over oil and direct gas operators. The initial cost of the retrofit might be lower than replacing the entire assembly, but there are drawbacks. The quarterly inspections, record keeping, and maintenance required make the total cost of ownership of these options higher than other solutions.
New Technology
So, why are more of these components not placed in facilities? Why is this such a thing when the USPEA allows it and, based on the testing standards, proves the valves operate less than 100 ppm on average?
First, it could be that during the public comments of New Source Performance Standards VVa (NSPS VVa), USEPA stated, “no detectable emissions can be leaking at any point; they are not under the same LDAR provisions as equipment not designated as such. If a piece of equipment designated as having no detectable emissions does leak, then it is not meeting the requirement in the rule.” This statement shows that the USEPA does not intend for NDE to be used unless the industry considers the component NDE, as it would be an automatic violation if found leaking.
As it stands, over many years, many components are still found to be leaking greater than 500 ppm. This shows that no matter how many testing standards are in place, valves still leak even when the best engineers in the world have designed a component to meet the most demanding standards. What if, within the industry, one could genuinely find an NDE component or, better yet, only a component that never could have an indicated instrument reading more significant than the ambient air, or more commonly referred to as background?
Producing zero ppm components is a reality that has been around for many years on pumps. However, within valves, it has shown significant improvement within the standards but has yet to reach a zero truly. What if technology has finally caught up on valves? Magnetic valves have been designed not only to meet NDE but also to meet a zero fugitive emission environment. Through magnetics, valves have finally been able to catch up to the world of zero fugitive emissions. To hit the global goal of ‘net zero’ by 2050, these techno- logical strides will be a strategic piece in achieving a viable ‘net zero.’
For the industry to keep pace, it must be agile and willing to seek change or advancement. The problem with many valves today is that they do not work with current supporting technology and understanding of environmental impacts. Many items come to light when talking about this type of change.
For example, many question, ‘are magnets powerful enough to operate a valve’? Magnetics have many great potential applications, but when used in valves, the strength that can be created is exceptionally outlandish. A half-inch diameter shaft can be sheared when magnetic actuation creates 900 to 1,000 in-lbs in torque. With this knowledge, an operator can calculate the infinite shear, allowing the magnets to skip when maximum torque has been achieved in either opening or closing. Do they work in high and low temperatures? They do. Some magnets gain upwards of 40% additional strength at cryogenic temperatures. Even in high temperatures, where leaks are often a significant problem, some magnets can operate over 1,000°F.
What is the working life of a magnetic valve? Since the valve does not rely on dynamic packing with magnets, testing has shown a valve actuating over 40,000 additional actuations even after completing an API 6FA fi re test. Does the footprint increase if magnetics are used? With some new technology, changes must be made to the existing structures. The changes can be costly; sometimes, redesigning the existing infrastructure reduces technological advancement opportunities. With magnetics, the infra- structure does not have to be redesigned.
Becoming Emission Free
With some of the most challenging questions answered, the only possible question is how can one truly have zero fugitive emissions? When exploring a traditional valve, at least 90% of all leaks can be found from the packing to the stem area, as both areas are dynamic.
While one may still find a leak at the bonnet gasket in some cases, as it is a static seal, the chance of a leak occurring is meager. Magnetic actuators can be integrated into most standard valves as a retrofit. With this retrofit, the only potential leaking interface would be the gasket used when attaching to the bonnet. All dynamic leaking interfaces have been removed, and the magnetic actuator is fully encapsulated with a solid wall. It does not have any external actuation, thus making a magnetically actuated valve more like a check valve.
The USEPA agrees, as published in the “Inspection Manual: Federal Equipment Leak Regulations for the Chemical Manufacturing Industry,” dated December 1998, that “Since a check valve has no stem or subsequent packing gland, it is not considered a potential source of fugitive emission and is not subject to the standards.” Without having any external actuation, a Magnetic Zero-E control, gate, globe, plug, or ball valve can be classified categorically as check valves.
Final Thoughts
If one is looking for ways to reduce emissions, Zero-E solutions will be a way of the future. Fugitive emissions have been listed as an ‘Enforcement Alert’ related to refineries since 1999. Since 2000, refineries have been under agreed settlements called Consent Decrees (CDs). These CDs have helped decrease emissions from refineries, but each facility hits a plateau in emission reduction. Zero-E solutions can interrupt these trends and begin to deliver emission reduction again. For example, if only 5% of leaking valves at a facility are exchanged for a Zero-E solution, a decrease of 63% in fugitive emissions can be reduced. The same reduction can be found if one wants a decline of CO2e for their Net-Zero 2050 goals.
Zero-E solutions also eliminate the need to put a human into an operating facility for monitoring, as Zero-E solutions like magnetic actuation eliminate the leak path, and monitoring requirements are either significantly reduced or nonexistent.
Considering the evolution and advancements in the industry, processes have become more complex; the industry has dug deeper, operates at more extreme temperatures and pressures, and is processing more harmful and lethal materials at a higher rate than ever before. With that, one must consider the advancements in supporting technology. Collectively, the harsh impact of failure in these systems is thanks to the advances in monitoring and general environmental impact studies is understood. What was potentially ‘working fine’ 50 years ago may not be the best solution for today.