Exploring the Components of a Refinery’s LDAR Program: An Interview with Ray Smalts, Environmental Specialist II
Ray Smalts, Environmental Specialist II for HollyFrontier Corporation, Navajo Refining Company in New Mexico, has been involved in the environmental sector for over 15 years. Working primarily in leak detection and repair, he has spent the past seven years overseeing LDAR programs, MACT-CC, emission compliance, Title V requirements, Consent Decrees and tank regulations.
Maintaining compliance with the various EPA regulated limits and thresholds is the aspect of his job that Smalts finds most rewarding and challenging. Pump Engineer was pleased to discuss the components of a refinery LDAR program with Smalts and talk about his experience handling leakage in pumps and valves.
By Stephanie Matas
Ray Smalts began his career in the emissions industry as a LDAR monitoring technician. He has since been promoted to Regional Project Manager of the southwest region. In 2013, Ray was offered a position at HollyFrontier’s Navajo Refinery where he acts as an Environmental Specialist in Artesia, New Mexico. Some of his daily responsibilities include: Program Management for the Leak Detection and Repair Program, MACT CC Compliance and Reporting, NSPS GGGa Compliance and Reporting, NSPS QQQ Compliance and Reporting, BWON Compliance and CEMS Tracking.
It is mandatory for companies such as HollyFrontier to have an LDAR program at all their refineries. Having gained a significant experience in the industry, Smalts reflected on how the program has changed over time. “There are arguments that the current LDAR program needs to be updated as facilities in the last 30 years have adopted so many new control methods, it is not as cost-effective as it once was. The LDAR program finds leaks, so if you have a facility that has a consent decree and you are having a hard time finding leaks at 500 ppm, the facility is doing an adequate job controlling their leaks.” As there will always be some leaks in process units, following the LDAR program ensure that the contractors are checking literally every component at its leak interface and at every potential leak point. This allows technicians to pinpoint the exact cause of an issue.
“Method 21 prescribes the mandatory elements of an LDAR inspection program, including requirements for calibration, drift testing for the calibration, what part of the component is monitored, how the component is monitored and the speed in which the component is monitored. It describes leak thresholds, what must be done if those thresholds are exceeded and the time frame for getting those leaks repaired,” said Smalts. The Navajo Refinery’s LDAR program adheres to Method 21 standards, utilizing into the software on the PDA that it is connected to it.
A few years ago, the warehouse department opted for Low-E packing to be installed on all new components at the Navajo refinery. “The warehouse discovered that the cost was tangible, within a dollar or two, to that of a valve with standard packing. Although this was not a requirement in our facility, the transition helped us achieve a lower leak rate. We have gone above and beyond what is required and rather than constantly replacing the packing, we spend a little more and got a better packing,” he said.
The federal limit for fugitive emissions, for both HAPS and VOCs, is 10,000 ppm. “Components in HAP or VOC service are treated the same way,” noted Smalts. One cannot often physically see the difference between HAPS and VOCs when monitoring, unless they are exposed to extreme conditions such as in a cryogenic unit. Leaks in these units might result in an ice ball forming around a bend in a pipe, where there is a 90 degree connection.
Sometimes, yellow discoloration in the ice or a distinct odor will indicate where fugitive emissions are being released. Other times, distortion will indicate fugitive emissions. Distortion can be detected with the naked eye. “It looks like steaming asphalt when you are driving on a hot summer day,” explained Smalts. “The heat being released from the pavement will cause a visual distortion, in the same way emissions may be seen across equipment. If a process unit is running at 600 degrees, you cannot touch it because you feel the heat as you move towards it and if you look at it, you see the distortion; this does not necessarily indicate that it is leaking. If you see distortion on a piece of equipment that is not hot, chances are there is something leaking from the fitting, connector, or valve,” he said. “When using IR (infrared) cameras to look around at a facility, you see the body heat, vapors and plumes; you see grey equipment releasing what looks like smoke. If you take the camera off, you will see nothing.”
Smalts believes improvements to LDAR technology will ultimately result in a decrease in the frequency of inspections. He foresees that the increase in use of IR camera technology will change how inspections are conducted, based on how stringent refineries and gas plants are running inspection programs. He also believes that a change in environmental monitoring will take place prior to the full adoption of drone technology in refineries. “For now, drones are better suited for pipelines and field work where you are monitoring a vast amount of land. A facility or a large refinery, with things flying around, even with proper control, increase the risk of accidents. For drones to be suited for smaller industrial environments they would all need to be equipped with specialized camera technology in order to distinguish between hot process piping steam and a leak. Just because you see a plume does not mean it is a leak.”
There is talk of revamping the current LDAR program in coming years, and while cost is always an important consideration, it is not the only element to keep in mind. “We will pay extra to make sure things work properly because at the end of the day, compliance is the most important factor in any LDAR Program. Cost is a parameter of review but is not a deciding factor when I prepare proposals on any project,” said Smalts.
In the future Smalts predicts that sensors will be set up at unit boundaries which will eliminate the need for a technician to go out into the field and conduct manual inspections. Technicians would only become involved in order to pinpoint the issue when the sensors predicted some sort of anomaly.
Managing Regulatory Updates
To manage and keep track of the multitude of regulatory changes in the realm of fugitive emission control, HollyFrontier has implemented a data software system for emissions. This system includes emission limit tracking and reporting so engineers can receive and review project data in real time. “In the past we were more reactive with our tracking and recorded data manually via spreadsheets. We still use spreadsheets today but are migrating toward digitized software specifically designed for environmental compliance.” Smalts noted that if you are not using data in real time, then it is easy to overlook or miss something. “If we exceed a permit limit or a threshold right now, we will receive an alert and then we can act immediately; we will be able to make adjustments or replace malfunctioning equipment in a timely manner, in order to mitigate any potential compliance issues.”
Handling Valve & Pump Repairs
In a refinery most leaks stem from pumps and valves. If a leak is detected in either of these applications there are two delay of repair options. The first option is to isolate the component from service until repaired; the second requires a full unit shutdown to repair.
“As leakages from a pump seal is not uncommon, many facilities have processes with spare pumps. In the event of a pump leak, operators would swap to the spare pump and the leaking pump would be isolated from service until repaired. If during the time the pump is isolated for repairs, the spare pump begins leaking, the spare pump would be allowed to operate on delay of repair as it cannot be isolated from service.” If a system must continue to run after a leak is detected a shutdown may be necessary. The general criteria for a shutdown is: if the application will run for less than 24 hours you do not have an obligation to repair components on delay of repair. If it is over 24 hours some effort must be made.
While it is generally the technicians that find the leaks in pumps and valves, the decision on necessary repairs are made by operations personnel and maintenance. “Sometimes the equipment configuration will allow for isolation, but some pieces of equipment cannot be isolated as it is not possible to get the pressure down enough to safely open the process line. For example, if a block valve is not holding because of age, and the valves are closed but product is continuing to get through, the operations personnel would delay the repair until the next turnaround or shutdown,” said Smalts. For LDAR components, there is only a 15-day repair window from the discovery of the leak. “If a we have sufficient stock on hand, then repairs can be made quickly and within the within the repair deadline. The repairs that require extended lead time in order to obtain the necessary equipment are more difficult to meet, but 95% of the time repairs are made within the time frame,” he continued.
Bridging The Knowledge Gap
For new environmental specialists entering the industry Smalts suggests that hands on experience is the best way to learn. “When you leave school, you know how to do the calculations and understand the basics, but there is only so much you can learn in a classroom. At each facility, the application will change and you will find that though the processes are similar, there will always be particular practices for specific units or piece of equipment that you may not be familiar with,” relayed Smalts. “Just because you have done a task somewhere else does not mean that is the only way to do the same task.”
Compliance regulations and limits are something everyone must adhere to, but there are multiple ways to come to the same conclusion. “You have to use logic, but you have to be flexible depending on the climate and location where you work. You might need to alter how you do things in order to work efficiently. The hardest part to teach new engineers, is how to think out of the box,” Smalts said. Some of the engineers on staff that have 30 plus years of experience, there is not documentation available for what they know. It is not so much about what you know individually, but the knowledge you gain from others.