Implementation of a Successful Enhanced Leak Detection & Repair Program
With over 30 years of experience in the industry, Dan Devine began his career in 1987 working for the Union Carbide Corporation after graduating from the University of Iowa with a Bachelor of Science degree in Chemical Engineering. He joined a major chemical company in 2001 through the acquisition of Union Carbide. Dan recently retired and is now working in a valve and piping consulting engineer role as an independent contractor through Midland Engineering, Ltd.
Having worked in multiple chemical manufacturing industry roles including production, chemical distribution, Dan spent the majority of his time in engineering design and project functions dealing with valve, piping, and pressure vessel technology. In his time at the chemical company, Dan was the Valve and Sealing (Packing) Technical Resource Leader, where he successfully implemented a low emission valve and packing program for an ELP at the Midland Michigan Operations Site.
Dan explained that there are two ways in which enhanced leak detection and repair programs come about; the Environmental Protection Agency (EPA) would come in and perform Method 21 to “sniff” valves, open lines and connectors to verify whether the leakage rates being reported by the operator were accurate. If they discovered that the leakage rate was greater than reported, a consent decree would be put in place to take the necessary steps to work toward the accepted leakage rates.
A legally binding document, companies found in violation of their reported leak rates would negotiate with the EPA and could ultimately be fined. Another way a program might come to fruition is through a Section 114 request, under which the EPA could take a company's LDAR database and analyze it for errors or any violations that would mandate bringing in a consent decree.
“The negotiation for the chemical company began in 2008 or 2009. As a valve and piping engineer, I was invited to hear about how we could comply with low E valves, but there were a lot of things in the consent decree that we objected to or did not think we would ever be able to comply with. We started to work with them and then a few years later, we had gotten to the point where everything was as good as it was going to get. They were trying to streamline their template and they wanted to use this as a successful template for the chemical industry, which was a really interesting thing to be a part of,” said Dan. “It went into force in November 2011 and then I worked on writing pipe specifications and writing all the valve codes. I also identified packing and valve manufacturers that were acceptable for that chemical service, for all the functions we needed that valve to do and then whether they were low E or not. It was a very labor-intensive effort, but it was worth it and very rewarding. At first it was difficult to find the products commercially available, but that has definitely changed over time and now we have so many options available. We were able to comply with all the technology, meet all the intent of the consent decree and stay in compliance within 5 years, making us the fastest to terminate a consent decree.”
Spreading the Word
Having presented on the topic at a number of recent conferences, Dan has been trying to convey a message to the industry, to help simplify what until recent years was an almost abstract concept. When the idea of lowering emissions was first introduced, the definitions for leak levels and the parameters for a Low E valve shocked the industry and seemed like an impossibility.
“I have been heavily involved in getting the word out about the importance of lowering fugitive emissions and working with the manufacturers has been really rewarding. The response was really good, especially from packing manufacturers at first. We had three low emission packing manufacturers right when we started and then by the time we were done with our consent decree, we had quite a few low emission valve manufacturers. It was really good to see the changes and reduction in emissions from our chemical plants.”
Dan also believes that involvement in networking events within the industry are an important part of the product development that the end users so desperately need. From broad more commodity type solutions to specialty products for tough situations, the variety of options being offered has greatly improved in recent years. “It is important to see what others are going through and find common ground to work on together. When we come together it makes our voices heard, helps valve and packing manufacturers understand the importance of investing in these products, because these changes do not come to them for free. We understand that they need to invest heavily in these innovations, but when they hear from the people buying the valves, it helps progress. Leak levels are 250 or 500PPM on a valve, it used to be 10,000PPM, before that is was 20,000PPM and those levels have dropped through combined efforts.”
In the past five years, the standards have caught up to the low leak definitions and become the accepted norm, and packing and valve manufacturers have taken great strides to improve and modify their products. Now the industry is aware of the jargon that comes along with lowering emissions, but many are still confused about what is involved and how to approach a leak detection program.
“I think the message to get across is that it is not an exact science. You have to try to comply the best you can, work toward eliminating emissions. You are not going to get to zero right away, but we are getting closer and I believe that sometime in the future, we will reach the goal,” Dan said.
One of the recurring topics that Dan believes is important to share with the industry is the consent decree's drill and tap provision. Dan explained that it contains the function of how the valve operates and changes the friction around the stem. If it changes response time then it can become a process safety hazard which everyone wants to avoid. He stresses that it is really important for people to know that they cannot modify the valve without taking into consideration how it might impact the chemical process.
Dan also reveals that he is excited about the new innovations that are coming out to help combat, lower and monitor emissions. “I have met a lot of people while being involved in conferences and have spoken to many about new Low E products that are hitting the market. There are a lot of products focusing on low emission and Low E packing. There are definitely some really neat innovations now and things I had not seen before, so it is nice to see that the industry is stepping up to make improvements and come up with new product designs,” he said. “For example, there was a question brought up about packing adjustments. Who adjusts that? How do they know to do it and how? Well, rather than being torque-based, some of these companies have invented visual-based packing adjustment tools. If we are constantly encountering issues with people on the field not knowing how much torque to apply when adjusting the packing, this takes the guesswork out of it. You do not have to know what torque is on there, it is just where two lines come together, where the packing is sitting up at a certain mark. Another example is a magnetic valve technology that is claiming to be inherently leak-free which I think is a great development. People are often weary about new technology, but some of the companies that I have worked with have developed technology through work with NASA and nuclear projects, so sometimes we can learn from developments that have been successful in other industries.”
More Than Just Valves
Though valves are one of the most common culprits when it comes to leakage, Dan expresses how vast the topic of fugitive emissions is becoming. Though the industry is becoming more aware of the issue and making great efforts to mitigate the problem, only the surface is scratched on the topic of fugitive emissions. Dan believes that it is important for the industry to share knowledge and look into other aspects of the technology being used.
“Fugitive Emissions is so broad and there are so many things you have to deal with, it is interesting to explore some specific topics into more detail when you have the opportunity. I am looking at only one little part of it and there is still so much more to learn,” explained Dan. “ I sat in on a presentation about fence line monitoring and that was really interesting to see all these tools and technology that is being developed and improving right now. It is really rewarding to see.”
Looking to the Future
Now, in his role as a valve and piping consulting engineer for Midland Engineering, Dan is continuing to find ways to share his expertise and knowledge in the industry. Recognizing the immense gap in the industry, he is continuing to find ways to mentor and educate young engineers and help mitigate the “brain drain” that often accompanies such a large talent gap.
“It is critical that the industry find ways to preserve knowledge and bring in new talent. When I did some Six Sigma, I got what they call Greenbelt Project Leadership certification and one of the questions was, “What does it take to mentor a new piping engineer?” Then from that team, we developed all these things you have to get trained on. We developed a lot of the training around it and then to show support, we kept meeting once a week after the new engineers were trained. It started off just locally in Michigan and West Virginia and the next thing I know, it spreads to Texas, then the rest of North America and then the company decided to spread it globally, where the subject matter experts who can answer lots of questions would hold a weekly meeting with the young engineers to give them support and help build a better team.”
Dan is proud to say that he is passionate about what he does and his passion also applies to mentorship. He attributes his own mentors early in his career for helping to foster, nurture and explore this passion.
“People gave me their passion when I started in engineering in 1992. I had some really good mentors, people who love the technology, wanted to share their knowledge and I make an effort to pay it forward, as they say,” said Dan. “I was always grateful for what they gave to me, so a big part of my career was mentoring young engineers.”
Dan continues to present at events and be involved with the industry so that he can continue to mentor and share his knowledge, and also pick up a few things along the way. “I still find myself learning from people. You hear people say, “Oh, millennials.” But I do not see them being any different. The ones I work with are not any different than I was when I started and probably my parents’ generation. If you really want to do the technology right, you really want it to be safe and effective, if you want to be proactive and learn, you will find a way. And if you have someone making an impact, introducing you to a community that can sometimes almost feel like a family, it is hard not to develop a passion and care about your field.”