To meet the increasingly stringent environmental and safety standards instituted by governments and standards boards, manufacturers and users alike must be constantly aware of changes and challenges for which they are ultimately responsible. Thus, the topic for this year’s VMA Technical Seminar, held March 10-11 in New Orleans, was greatly appreciated by the attendees as they were able to gather much-needed information from experts in the manufacturing, engineering and end-user sectors who shared their knowledge on this most important topic.
The conference began with a keynote address by Douglass Morris, chief of Offshore Regulatory Programs at the Bureau of Safety and Environmental Enforcement. BSEE was established in October, 2011 as a part of the reorganization of the Department of the Interior’s offshore regulatory structure that was in direct response to the Deepwater Horizon incident. BSEE’s mandate is: “To promote safety, protect the environment and conserve resources offshore through vigorous regulatory oversight and enforcement.”
In addition to enforcing current regulations and ensuring that operators adhere to the stipulations of their approved leases, plans and permits, Morris said that BSEE is instituting the Well Control and Blowout Preventer Rule, which will codify decades of BSEE policies. The objectives of the rule are to define safe drilling practices, performance criteria for downhole equipment and performance criteria for Blowout Preventers (BOPs). The rule will also increase and verify reliability of BOPs and establish criteria for maintenance and repair of BOP equipment, incorporating industry standards as the baseline.
This process has been going on since 2012, May 2012 and the final rule is being published in the spring of 2016. Implementation will be staged over several years.
Doing Business in the European Union
During his presentation, Mike Norman of DNV-GL Business Assurance shared applicable requirements from the European Union’s New Legislation Framework (NLF) and what that means for manufacturers and producers in North America. Norman drew attention to the new requirements of the Pressure Equipment Directive (PED), which affect manufacturers and authorized representatives of manufacturers including importers and distributors.
Most of the changes are strictly about risk, so there are new traceability requirements, including the need for keeping documentation for at least 10 years and making information available to whoever is ultimately responsible for the product in the EU. Once implemented it will mean that manufacturers and authorities will have to act in a more harmonized way and more market surveillance and authority control will be in place.
Li Li, senior health, safety and environmental technical specialist at Fluor Enterprises stressed the importance of doing a comprehensive Hazard and Operability (HAZOP) analysis and safety and environmental risk assessment during the development stage of any project. Li stressed that every EPC should have a dedicated team that must focus on identifying what could go wrong in every system, potential causes, initiating events, previous incidents and resulting consequences. Safety, environmental, health and financial risks are all assessed.
“All types of valves play important roles in the facility’s safety and environmental compliance,” said Li, “Early hazards identification at the detail engineering phases can offer great opportunities for various engineering disciplines to apply inherent safer design (ISD) principles or risk tolerable solutions to prevent or mitigate the potential safety and environmental hazards.”
As an end-user of valves, Stephen Treichler, mechanical services manager at BASF, pointed out that today, process safety performance and environmental compliance expectations are an ever-rising bar that applies to every facet of the petro-chemical industry. “When considering risk, you have to start first with, when does a valve become more than just a commodity valve? What are the implications when a simple block valve gets enhanced to become part of a complex SIS? What about the other risks out of the control of the original designer or even the valve manufacturer?”
He also said the issue was compounded when considering the users’ expectations concerning supplier technical support in a lean engineering culture and their need for timely response to design/QC issues that could affect our environment and community impact, long-term cost of ownership, or even the degree of risk being placed on those working in or near the facility.
Afton Coleman, Fieldvue SIS product manager at Emerson Process Management, addressed the challenges of high integrity pressure protection systems (HIPPS) from the manufacturer’s point of view. “It’s essential that product level challenges such as final control, pressure sensors and logic server must be considered individually but then also as all of these components integrate into the system,” she said.
Coleman pointed out there can be two types of faults when a failure occurs. “A random failure is basically a product issue, something that could occur due to an inappropriate application,” she said. “The second is systemic failures—50% of dangerous failures are attributed to the valves. But you can’t ignore the human element of things. They can start with the manufacturing process, in design or implementation phase, in operation, or decommission phase. You have to consider everything.”
David Bayreuther of Metso kicked off a series of three presentations on Thursday afternoon, all of which dealt in some way or another with preventing emissions.
In his presentation, Bayreuther pointed out there is no singular, comprehensive way to test and validate compliance with the expectations of the EPA. One successful test in a laboratory is no guarantee of future results, and success in a laboratory does not equal success in the plants because laboratory tests do not address thermal stress, pipe stress, flow erosion, vibration, effects of corrosion (both within the system and from outside conditions) and mechanical wear.
“Emissions testing standards are a confusing mess so it is practically impossible to have all the combinations covered,” he said. “Despite this, there are massive improvements to packing and seal materials, and installation techniques, leading to lower fugitive emissions.”
Henri Azibert of the Fluid Sealing Association agreed performance demands for curbing emissions are higher than ever, but the products also have higher performances than ever. In his discussion of compression packing formulation and design, he pointed out that testing of packing in a fixture such as that specified by API 622 is not a guarantee that the same emission level will be achieved in a given valve. “Just because the packing passes doesn’t mean it’s going to work in YOUR valve,” he noted. “Factors such as surface finishes, concentricity of the shaft to the stuffing box, tolerances on diameters, bolt stress and deformation under load all affect emission results.”
Shorts pointed out that the Fluid Sealing Association (FSA) Gasket Division Technical Subcommittee is currently developing a performance standard for semi-metallic gaskets (spiral wound, kammprofile, corrugated metal insert) commonly used in the valve OEM industry. Leakage qualification standards on this product group is lacking so the standard is being developed to eventually use methane gas at high temperatures. The committee is specifically looking for additional gasket manufacturers and affiliates (OEM’s, engineers, etc.) to become involved in this development in order to capture all facets of ultra-low emissions requirements.
Seismic Testing for Safety
Kalsi Engineering discussed the critical aspects of seismic design and qualification testing for valves and valve assemblies.It’s often thought that seismic requirements are important only for nuclear projects, but pipelines are often laid in highly seismically active areas such as Alaska, so it is essential that qualification testing can verify that equipment will properly function under worst-case scenario conditions. In their presentation, Dr. M.S. Kalsi and Nimish Jagtap of
“Qualification can be by analysis alone and is suitable when valve assembly geometry and key features can be adequately modeled,” said Jagtap. “Analysis can also be used to extend test results to higher acceleration or frequency conditions, which may not be possible in a lab. Analysis is also done by testing only, but when testing occurs, the valve must be under pressure, and the actuator must operate to demonstrate that the assembly and the components are able to withstand the stresses of seismic activity.”
Kalsi pointed out that “Testing generally provides more detailed results. But precautions should be taken to ensure test configuration provides results that are representative of the ‘as installed’ configuration.”
Standards issues dominated the last day of the seminar, and the session opened with a lively presentation by Jay Cameron of HSB Global Standards. Comparing the value of ASME code cases to precedents in the legal field, Cameron said that code cases are basically exceptions to the mandatory code rules. Calling it a “try before you buy” product to introduce new materials, design rules, welding techniques and new technologies, code cases are a way to get an idea into production much faster than waiting for the ASME code book to be revised. There is even a project team to evaluate additive manufacturing of production parts for pressure-retaining equipment and they are looking for people to get involved.
Carlos Davila of Crane ChemPharma/Energy and Rick Faircloth of Cameron Valves and Measurement closed out the meeting with comprehensive updates on industry standards. Davila gave the group an update on valve standards being revised by three different organizations, including ASME, API and MSS. There are changes upcoming in 2016 for ASME standards for valves, flanges, forged fittings and cast copper alloy. Changes are upcoming in 2017 for B16.25 concerning butt-welding ends.
Updates on check, globe and gate valves, valve qualification procedures and fire testing are scheduled by API, and MSS is introducing new accreditation, marking and terminology standards for the next edition. Requirements for steel flanges, packing, gaskets, butterfly valves and knife gate valves are also in the works for the next edition.
Faircloth provided the latest update on the development of the API Upstream Standards for supply chain management. API 20 covers not just suppliers of bolts or forgings; it covers welding materials and practices and it even governs suppliers providing NDE services for equipment used in the oil and natural gas industries.
He said the purpose of this supply chain standard is to:
- Institutionalize best practices for supplier review and qualification
- Harmonize component and process qualification requirements
- Establish scalable requirements to address various levels of criticality and risk
- And allow suppliers, product manufacturers and end users access to the industry’s licensing and accreditation program.
Attendees had many questions for the last three speakers, with concerns about additive manufacturing, weight issues and code cases being addressed.