FUGITIVE EMISSIONS

Development of emission factors from

API 622/624 test data
In the United States, Leak Detection and Repair (LDAR) regulations have been around for more than 30 years. These
regulations are aimed at reducing fugitive emissions and were initially designed on the paradigm of “Find the leak and
fix the leak”. As technology and engineering design become the forefront of the USA Environmental Protection Agency’s
(USEPA) approach to control fugitive emissions, the paradigm has shifted to prevention of the leak before it starts.
Manufacturers and many committees have been working closely together in developing new standards that every valve,
packing or connection must meet before being put into service called Low Emission Technology (Low E). US companies
and many other countries are using the American Petroleum Institute (API) standards, API 622 (packing) and
API 624 (valves), as designed requirements to ensure Low E is achieved.

By Graham “Buzz” Harris and Bronson Pate, Sage Environmental Consulting, L.P.

Low E technology cycles. Shell is another company that has more industry-wide applicability and focus
Historically, there has been a wide their own testing procedure for packing. on methane testing versus using helium
spectrum of packing and valve product While there are numerous industry testing (which is easier to translate in field LDAR
quality, along with many unsupported practices, the API test procedures provide monitoring results).
claims of low emissions. Only recently,
however, have manufactures started to
Comparison of Service Parameters: API 622 and API 624
supply guarantees, warranties, and most
importantly, test data to prove their claims Standard identification API STD 622 API STD 624
of these low emissions from their packing
and/or valves. Based on hard data, Type Testing of Rising Stem
Type Testing of Process
USEPA has begun to require Low E Valves Equipped with
Title and edition Valve Packing for Fugitive
Graphite Packing for Fugitive
in Consent Decrees that have been Emissions, Second Edition
written over the last four to five years. Emissions, First Edition
Several companies have also started
Standard by the American Standard by the American
implementation of Low E standards
Date Petroleum Institute, Petroleum Institute,
voluntarily before being required by
10/01/2011 02/01/2014
USEPA. The use of Low E is gradually
increasing, whether USPEA-required or 500 ppmv maximum after
Pass Criteria one adjustment
100 ppmv maximum
voluntary, and is starting to be recognized
as a cost-effective solution to controlling Specified fixture
Equipment simulating a valve
Valve being qualified
fugitive emissions, as well as being
beneficial on a public relations front. Packing adjustment One allowed None allowed
Methane 97% minimum Methane 97% minimum
Fugitive emission testing Media purity purity
A rigorous amount of valve and packing
testing has been conducted worldwide, Temperature 500°F (260°C) 500°F (260°C)
with some companies even developing Pressure 600 psig (41.4bar-g) 600 psig (41.4bar-g)
their own internal testing procedures. The
Number of valve stem
European Union (EU) and British standard 1510 310
actuations
ISO 15848-1 allows testing by either
helium or methane, with most test data Number of thermal
5 3
to date being conducted with helium. API cycles
has developed multiple fugitive emission Leak measurement
testing procedures, but most relevant to Method 21 Method 21
method
Low E specifications would be API 622,
which is a packing test using methane, Leak measurement Done with stem in static Done with stem in static
and API 624, which is a valve test using details state and dynamic states
methane and packing that has passed API Leak measurement Every 50 actuations of the Every 50 actuations of the
622. The ChevronTexaco test procedure is frequency stem stem
very similar to API 622, but it tests packing
within a valve and includes more wear *Prepared and used by permission from Garlock

1
June 2015
FUGITIVE EMISSIONS

*Prepared and used by permission from Garlock.

API 622 test data Accelerated Wear Time: Both API 622 period, but represent a much longer
PPM Readings in API 622 and 624: During and 624 have a requirement for period because of the accelerated
testing of either API 622 or API 624, the accelerated wear. API 622 includes 1510 mechanical and thermal cycles. The
parts per million (ppm) readings are the mechanical wear cycles and 5 thermal equivalent process life may vary based
most significant monitoring parameter. To stress cycles for the packing that is being on: continuous versus batch processes,
accomplish this, the probe is split in two, tested. API 624 includes 310 mechanical process application of the valve or
to simultaneously check both the stem and wear cycles and 3 thermal stress cycles, packing (manual isolation, drain,
packing. Aluminum foil is used as a partial but the caveat is that the packing must sample, motor operated, control, etc.
shroud to collect leakage from any point have passed API 622 before API 624 type valve), and other factors associated
around the stem and packing. The test requires testing can even take place. Both of with process-specific applications for
that ppmv data is recorded over one minute these tests occur over a 3 to 6 day consideration during this analysis.
and the average and maximum reading
observed during that minute be recorded with Continuous Process- Cycle to Time
no background correction. The data presented Accelerated Wear Cycles to Operating Time
in this paper uses the maximum readings
recorded in either static or dynamic modes. Frequency % of Weighted
Continuous Processes
This approach should be conservatively higher per year Total Frequency
than traditional Method 21 (M21) readings.
Mass Emissions from PPM: In 1995 USEPA
Low High Low High
Valve Application Valves
put out mass emission factors (EFs) based End End End End
on industry collection data. Please note Manually operated block
that for Low E testing, no pegged emission 1 10 78% 0.78 7.8
isolation valves
factor (i.e., for readings off the high end of
the scale) will be needed. Block valves isolating
5 24 2% 0.1 0.48
For the petroleum industry: pumps
– Default Zero EF (reading zero) = Drain valves 12 120 5% 0.6 6
0.0000078 kg/hr/source
– Correlation equation = 2.29*10^- Sample valves 52 795 2% 1.04 15.9
6*SV^0.746 kg/hr/source
Motor operated valves 150 1000 2% 3 20
For SOCMI:
Process control valves 500 5000 11% 55 550
– Default Zero EF (reading zero) =
0.00000066 kg/hr/source Totals 720 6949 100% 60.52 600.18
– Correlation equation = 1.87*10^-
6*SV^0.873 kg/hr/source Average Annual
330.35
It is important to note that these emission Operation Cycles
factors are for the instant the measurement
Years of Operation for
occurs, not some average or cumulative 4.57
1510 Operating Cycles
emissions over time.

2
June 2015
 FUGITIVE EMISSIONS

Note that the tables present estimates

Batch Process- Cycles to Time
of frequency of operation and thermal
stress. These estimates were developed
Accelerated Wear Cycles to Operating Time
by several knowledgeable personnel from
Frequency % of Weighted the environmental, industrial, and valve/
Batch Processes packing manufacturers. These are not
per year Total Frequency
hard data from any of these sources,
Low High Low High but are estimates of ranges that seemed
Valve Application Valves
End End End End reasonable to a wide range of people in
relevant industries.
Manually operated
12 365 75% 9 273.75 In summary of accelerated wear time, 1510
block isolation valves mechanical wear cycles represents 3.1 to 4.6
Block valves isolating years of operating time for batch/ continuous
24 365 2% 0.48 7.3
pumps process units. Five (5) thermal cycles represent
0.1 to 6.6 years of operating time for batch/
Drain valves 12 365 5% 0.6 18.25 continuous process units. USEPA defines
Sample valves 52 795 2% 1.04 15.9 Low E as <100 ppmv operation for five (5)
years, and accepts API 622 data to satisfy
Motor operated valves 150 1000 5% 7.5 50 that criteria. While the thermal cycles in API
Process control valves 500 5000 11% 55 550 622 fall short of the potential thermal cycles
in 5 years for batch processes, the API 622
Totals 750 7890 100% 73.62 915.2 accelerated wear cycles average to around
5 years equivalent operation for continuous
Average Annual
494.41 operating units and mechanical wear for
Operation Cycles
batch units. This paper assumes that the API
Years of Operation for 622/624 readings are a reasonable surrogate
3.05
1510 Operating Cycles for a 5 year period of operation for most
petroleum and chemical industry valves.
Continuous Process- Thermal Cycles to Time
Thermal Cycles to Operating Time API 622 emissions over time
Continuous Processes: Scheduled Unscheduled Total example
• 1510 cycles with a reading every 50
Run Lengths Between Shutdowns/ Shutdowns/ Shutdowns/
cycles (including beginning and end
T/A, yrs yr yr yr
readings) resulting in 42 readings;
5 0.20 0.5 0.70 • 42 readings spread evenly over 5 years
4 0.25 0.4 0.65 would be one reading every 45.6 days
3 0.33 0.3 0.63 (roughly every 6 weeks);
• Default zero and correlation equations
2 0.50 0.2 0.70
for petroleum and SOCMI are used
1 1.00 0.1 1.10 to calculate instantaneous emission
Average Shutdowns/yr 0.76 estimates;
Years of Operation for • Emissions from the previous to current
6.61 readings are averaged over the 45.6
5 Thermal Cycles
days between readings;
Batch Process- Thermal Cycles to Time • Emissions are summed over the 42
total readings and divided by the time
Thermal Cycles to Operating Time
in years to create an average emission
Continuous Processes: Scheduled Unscheduled Total factor in kg/yr/source; and
Run Lengths Between Shutdowns/ Shutdowns/ Shutdowns/ • Emission factors for static and dynamic
T/A, yrs yr yr yr readings are averaged to develop an
overall average Low E emission factor.
5 0.20 0.5 0.70
4 0.25 0.4 0.65
API 624 emissions over time
3 0.33 0.3 0.63
example
2 0.50 0.2 0.70
• 310 cycles with a reading every 50
1 1.00 0.1 1.10 cycles (including beginning and end
Average Shutdowns/yr 0.76 readings) results in 14 readings;
• 14 readings spread evenly over 5 years
Years of Operation for
6.61 would be one reading every 140.4 days
5 Thermal Cycles (roughly semi-annual);

3
June 2015
FUGITIVE EMISSIONS
• 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; and
• Emission factors for static and dynamic
readings are averaged to develop an
overall average Low E emission factor.
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 purposes. Another approach
would be to allow an average emission
*Low E Emission Factors are the average of all the API 622/624 tests using either petroleum or chemical
correlations/ default zero emission factors.
*API 622 and 624 test reports were provided by and thanks to: Ron Walters of Teadit North America, Todd Haberkost of Ladish Valves, Jim Drago of
Garlock, Scott Boyson and Rodney Roth of A.W. Chesterton Company, and Josh Erd of Nippon Pillar Corporation of America.
4
factor (or control efficiency) for Low E valves
and packing to be used to predict emissions
for permitting. Yet another alternative
would be to require applicants to include
calculations of an emission factor for the
specific Low E equipment the site has
chosen to use (following these procedures
or others specified by USEPA).
Control efficiency approach
In lieu of developing emission factors for
Low E, it would be possible to develop
a control efficiency estimate for Low E
application that could be applied to the
normal average emission factor.
The following table shows control
efficiency (CE) estimates calculated as:
• CE%=(1-(Average EF/ Low E EF)) x 100
• Average EF is for valves in a specific
service category within a specific
industry
• Low E EF is for valves in a specific
industry, but all testing is done for
valves in Gas/Vapor service (methane,
600 psi)
Conclusions
The measurements done in API 622/624
testing procedure produce 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, all of which fall
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%. These Low EFs and control
efficiencies could be used for permitting,
when actual components that will
require monitoring do not yet exist.
USEPA should also consider allowing
use of Low E EFs for non-monitored
valves (such as HL service, Unsafe To
Monitor, Closed Vent Systems, etc.)
because this would encourage the use
of Low E valves/packings in these
applications. Neither USEPA nor the
State Agencies currently accept these
Low E EFs and control efficiencies for
permitting. In conclusion, it is strongly
suggested that the USEPA review these
calculations and/or replicate their
own approach to similar calculations.
USEPA-sanctioned Low E EFs and/or
control efficiencies would add yet
another incentive for every new facility
or modification to be constructed
with Low E technology. Once they
are accepted by USEPA, most states
should begin to accept the Low E
factors as well.
June 2015
 FUGITIVE EMISSIONS

About the authors

Buzz Harris is a Chemical Engineer with 43 years experience in industry and consulting. He began his career as a
process engineer at the Texaco Port Arthur refinery, where he spent six years rotating through responsibility for all
the major refining process categories. He joined Radian Corporation in 1976, where he worked 29 years before
joining Sage in 2005. He has spent the last 37 years in consulting to the refining, petrochemicals, and gas processing
industries. Buzz played a lead role in the fugitive emission studies that established the monitoring protocol, correlation
equations, and emission factors for refineries and SOCMI facilities. He has been continuously involved in LDAR
equipment leaks issues for 37 years, in projects ranging from bagging, training, regulatory development, auditing,
and expert witness services. In recent years, LDAR audits have become nearly his full-time job, having completed more
than 235 LDAR audits over the last twelve years. Buzz has also been active in supporting the development of new LDAR technologies, such
as Smart LDAR. He has played a part in most public demonstrations of infrared imaging of equipment leaks, and has participated in several
private demonstrations. He is a certified GasFindIR thermographer with field experience in implementing Smart LDAR. Buzz is active in
development and presentation of training materials related to LDAR, and has lectured at LDAR University and Sage’s LDAR Essentials training
and LDAR for Experts training. He has presented several dozen papers on LDAR at workshops and meetings and has chaired several LDAR-
specific workshops. He is regular participant on expert panels to field audience questions on LDAR and Smart LDAR.
Bronson Pate has more than 7 years of full time professional experience with Sage. Bronson has worked with
multiple facilities to develop LDAR programs including those subject to LDAR consent decree requirements. He
has experience in fugitive emission source Leak Detection and Repair (LDAR) monitoring, tagging, and database
management, including Process and Instrumentation Diagram (P&ID) review. He has participated in and/or led
over 100 CD LDAR audits. He has been trained and groomed for the audit lead position by Buzz Harris and David
Ranum. Bronson also has experience in the environmental field focused on air quality compliance in the refining,
petrochemical, and natural gas processing industries. Bronson is also familiar with the Benzene Waste Operations
NESHAP (BWON) standard including required sampling, training, reporting, and lab auditing. Bronson has also
helped with Environmental Impact Statements (EIS) for oil and gas production companies, with the refining industry in producing Spill
Prevention, Control and Countermeasure Plan (SPCC), and with air permitting including MACT, BACT, Netting and Title V. Bronson is one
of HSE-U trainers for LDAR Essentials, Advanced LDAR and LDAR for Experts. Before joining Sage, he served as lead LDAR technician for
various refineries and gasification facilities in Wyoming, Colorado, Utah and New Mexico. He was responsible for component tagging,
P&ID review, Method 21 fugitive monitoring and database management. He also has experience performing on-line leak sealing,
specifically drill and taps, wire wraps, pin and pumps and clamp measurements with placement and sealing.

5
June 2015