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 .

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“ 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 .