Low leak Seals/Packing/Gasket materials

[techv]

We have new plant coming up. Per new regulations, LDAR is to be based on 10000 ppm of VOC. Point source emission standard is also specified with 10000 ppm for all pumps/compressor seals, valve packing and flange gaskets which are in the fluid service containing >10% VOCs. Since the standard for both point source and monitoting (LDAR) is same, this has resulted in confusion "Is this point source std referring to LDAR or does it really call for design/procurement low leak seals/packing/gaskets to meet the point source standard for the Pumps/Compressors/Valves/Flanges??

Please provide some guidance in interpretaion and compliance based on your industry.

 

[dcasto]

You can install whatever you want. It's a performance regulation. If the point leaks you must repair it and keep monitoring it. If the point doesn't leak, then your monitoring requirements decrease. If you have automated detection on a pump seal, then you only have to repair the seal if it leaks. So, it is your choice, better seals up front and little work monitoring them, or less reliable and more monitoring.

On rotating equipment, put in a twin seal with a monitor. Reciprocating equipment and their seals are more difficult to monitor and to get to seal, so we just monitor and repair.

Relief valves, get the seats right and design in a system where the relief valves just never operate, use a control valve to a flare header that opens way before the relief is needed.

Design in a VRU system from the beginning.

Other valves and seals, just be picky and make vendors give warranties.