United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(5104 A)
EPA550-F-0-7001
Revised June 2007
www.epa.gov/OEM
CHEMICAL SAFETY
Emergency Isolation for Hazardous Material Fluid Transfer
Systems - Applications and Limitations of Excess Flow Valves
The Environmental Protection Agency (EPA) is issuing this Alert as part of its ongoing
effort to protect human health and the environment by preventing chemical accidents.
We are striving to learn the causes and contributing factors associated with chemical
accidents and to prevent their recurrence. Major chemical accidents cannot be prevented
solely through regulatory requirements. Rather, understanding the fundamental root
causes, widely disseminating the lessons learned, and integrating these lessons learned
into safe operations are also required. EPA publishes Alerts to increase awareness of
possible hazards. It is important that facilities, State Emergency Response Commissions
(SERCs), Local Emergency Planning Committees (LEPCs), emergency responders, and
others review this information and consider whether additional action is needed to
address the hazards.
Problem
While excess flow valves (EFV) are in
extensive service and have prevented
numerous pipe or hose breaks from
becoming much more serious incidents,
experience has shown that in some cases the
EFV did not perform as intended, usually
because of misapplication. Also, undue
reliance must not be placed on EFVs as the
sole or primary protection to control
accidental chemical releases from tanks or
piping.
Excess flow valves are protective devices
intended to prevent the uncontrolled release
of hazardous materials from road, rail and
marine transport vessels, stationary storage
vessels and distribution networks. EFVs are
designed to close when the flow rate through
them exceeds the expected range of normal
operation, for example due to a downstream
leak or valving error that provides an
unintended release path to the atmosphere.
EFVs are intended to bring the release under
control until the leaking element (e.g. hose
or pipe) can be blocked in and positively
isolated for corrective action.
Industry incident experience, however, has
shown that under certain circumstances,
EFVs can fail to provide the protection
anticipated of them. In fact, a number of
significant releases of hazardous materials
have occurred from systems 'protected' by
EFVs. One event investigated by the
National Transportation Safety Board
(NTSB) resulted in the deaths of three plant
employees and the evacuation of 2,000
nearby residents. Concerned that undue
reliance might be placed upon EFVs, the
NTSB recommended in its investigation
report that EPA:
"Notify all facilities that are
required to submit risk management
plans to the Environmental
Office of Emergency Management
Page 1
-------
Emergency Isolation for Hazardous Material Fluid Transfer Systems -
Applications and Limitations of Excess Flow Valves
Revised June 2007
Protection Agency that tank car
excess flow valves cannot be relied
upon to stop leaks that occur during
tank car loading and unloading
operations and that those companies
that have included reliance on such
valves in their risk management
plans should instead identify and
implement other measures that will
stop the uncontrolled release of
product in the event of a transfer
line failure during tank car loading
or unloading."
EPA shares the NTSB's concerns and
additionally recognizes that the use of EFVs
extends beyond tank cars and includes
loading and unloading operations associated
with tank trucks, marine barges, stationary
tankage and piping distribution networks.
This Hazard Alert is intended to provide an
understanding of (1) how EFVs function, (2)
circumstances that can lead to their failure to
function as intended, (3) important design
and operational factors for enhancing the
reliability of EFVs, and (4) alternate means
available for stopping uncontrolled releases.
Facilities should be aware of, and give
proper regard to, industry best practice
guidance and regulatory requirements for
the use of EFVs.
When they are properly designed, installed,
and maintained, EFVs play an important
role in comprehensive accidental release
prevention systems. It is not EPA's intent to
dissuade the regulated community from the
use of EFVs but, rather, to provide
precautionary guidance regarding their use
as a sole means of protection.
Accidents
Provision should be included for blocking in
(isolating) hazardous material transfer lines
in addition to the protection provided by
EFVs. As in the following incidents, failure
to understand the limitations of EFVs has
been a contributing factor in a number of
significant incidents where flow restriction
prevented EFV closure.
8/2002 in Missouri - A chlorine railcar
transfer hose ruptured, releasing 48,000
pounds of chlorine. Hundreds of residents
were evacuated or sheltered-in-place, and
sixty-three local residents sought medical
evaluation; three were admitted to the
hospital. The chlorine also damaged tree
leaves and vegetation around the facility.
The CSB determined that an excess flow
valve internal to the chlorine railcar did not
close, contributing to the severity of the
event. As a result of such chlorine releases,
the CSB has issued a recommendation to the
Department of Transportation (DOT) to
expand the scope of DOT regulatory
coverage to include chlorine railcar
unloading operations and ensure the
regulations specifically require remotely
operated emergency isolation devices that
will quickly isolate a leak in any of the
flexible hoses (or piping components) used
to unload a chlorine railcar.
7/2001 in Michigan - A methyl mercaptan
release occurred when a pipe attached to a
fitting on the unloading line of a railroad
tank car fractured and separated. Fire
damage to cargo transfer hoses on an
adjacent tank car also resulted in the release
of chlorine gas. Neither of the two EFVs
closed to control the release. Three plant
employees were killed in the resulting
explosion and several employees were
injured. Approximately 2,000 local
residents were evacuated from their homes
for 10 hours. Failure of the EFVs to close
contributed to the severity of the incident.
The NTSB determined that the facility
placed undue reliance on the tank car EFV
to close in the event of a leak from the
transfer line.
4/1998 in Iowa - A propane release
occurred when a vehicle struck and severed
unprotected, aboveground liquid and vapor
lines serving an 18,000-gallon propane
storage tank. The lines fed vaporizers,
which fueled heaters located in barns and
Office of Emergency Management
Page 2
-------
Emergency Isolation for Hazardous Material Fluid Transfer Systems
Applications and Limitations of Excess Flow Valves
Revised June 2007
other farm structures. The liquid line, which
was sharply reduced in pipe diameter, was
completely severed where it connected to a
manual shut-off valve directly beneath the
tank. The release ignited and the tank
subsequently exploded, killing two fire
fighters and injuring seven other emergency
personnel. A subsequent CSB investigation
determined that the flow capacity of the
liquid outlet piping system downstream of
the EFV was insufficient to allow the EFV
to close.
9/1999 in North Carolina - More than
35,000 gallons of propane were released
when the discharge hose on an LPG
transport truck separated from its hose
coupling at the delivery end of the hose, and
none of the safety systems on either the
truck or the receipt tank worked as intended
to stop the release. The DOT determined
that emergency systems such as EFVs do
not always function properly when a pump
is used to unload the protected vessel. If a
release occurs downstream of the pump and
the EFV activation point is greater than the
pump capacity, the pump will function as a
regulator limiting the flow to below that
required to close the EFV.
Two common themes in these accidents are
that flow restrictions prevented the flow
through an EFV from exceeding the shut-off
flow rate, and emergency isolation block
valves were not activated. A literature
review revealed a number of additional
incidents where the rates of discharge from
releases were insufficient to close the EFVs.
The literature also shows, cases such as the
one below, where an EFV was not installed
but would have been beneficial:
children. The investigation report concluded
that the release was attributed to the plastic
feed line being damaged by heat from a
faulty splicing in a buried electrical service
cable located close to the natural gas line.
The natural gas feeder line was not equipped
with an excess flow valve. Among the
findings it was concluded that "Had an
excess flow valve been installed in the gas
line to the residence, the valve would have
closed after the hole in the pipeline
developed, and the explosion likely would
not have occurred."
Understanding the
Hazard
Proper use of EFVs requires an
understanding of their capabilities and their
limitations.
The National Fire Protection Association
(NFPA) defines an EFV as a "valve
designed to close when the liquid or vapor
passing through it exceeds a prescribed flow
rate" (NFPA 58). EFVs are most commonly
used on the liquid and vapor connections of
transport containers (e.g., rail cars and tank
trucks) and on some stationary tankage.
EFVs are often installed inside of the vessel
so that protection is provided even if the
piping external to the vessel is damaged.
EFVs are also very commonly used in
natural gas distribution lines serving end-
users such as residential and commercial
consumers. Figure 1 shows an EFV installed
in the liquid unloading line on a chlorine
railcar. In-line EFVs can also be installed in
external piping systems (e.g., to protect
individual distribution lines).
7/1998 in Virginia - A natural gas release
occurred in the underground feed line
serving a newly constructed residence in
which the occupants had moved-in just
hours before. The leaking gas entered the
basement where it found an ignition source
and exploded killing one of the new owners
and injuring the other parent and their two
Office of Emergency Management
Page 3
-------
Emergency Isolation for Hazardous Material Fluid Transfer Systems -
Applications and Limitations of Excess Flow Valves
Revised June 2007
from Car
against the seat, stopping the flow. This
Liquid Chlorine design permits the valve to be installed in
Figure 1. EFV in Chlorine Railcar Liquid
Outlet Line
EFVs are used with a variety of hazardous
chemicals, of which chlorine, liquefied
petroleum gases (LPG), natural gas and
anhydrous ammonia are among the most
common. Consequently, these four
chemicals are used as examples in this
Hazard Alert. Guidance for the application
of EFVs with regard to these four chemicals
is issued, respectively, by the Chlorine
Institute (CI), NFPA, and the Compressed
Gas Association (CGA). Regulatory
requirements for the usage of EFVs are
imposed by various state and federal
agencies, including the Occupational Safety
and Health Administration (OSF£A) and the
DOT.
Figures 2 and 3 illustrate two common
designs for EFVs. The valve in Figure 2,
designed for use on a chlorine rail car or
tank truck, contains a ball that is driven
upwards against a seat to stop the flow when
it exceeds the shut-off rate. The design of
this type of EFV requires that it be mounted
in the vertical orientation shown in the
figure. The valve shown in Figure 3 is used
in LPG and anhydrous ammonia service. A
spring normally holds the plug in the open
position shown. When the flow through the
valve is high enough, the plug is forced
any orientation. It should be noted that
EFVs permit flow in both directions, but
only stop flow in one direction.
Consequently, flow direction must be
correctly considered in the installation of the
EFV. In both figures, the protected flow
direction would be upwards through the
valves.
Normal Flow Position
Flow Ctiecked Position
Flow Dirictorv
Figure 2. EFV for Chlorine Service
Plug
Spring
Figure 3. EFV for Ammonia or LPG Services
The potential for flow restrictions
preventing the closure of the EFV is well
recognized by organizations issuing good
practice guidance for the use of EFVs. For
Office of Emergency Management
Page 4
-------
Emergency Isolation for Hazardous Material Fluid Transfer Systems
Applications and Limitations of Excess Flow Valves
Revised June 2007
example, the CI cautions that the EFV is
principally a protection against an event that
damages the manual valve on the transport
container during transit and not a protection
against damage to connected loading or
unloading system piping. The CI notes that
the EFV "may close if a catastrophic leak
involving a broken connection occurs but it
is not designed to act as an emergency shut-
off device during transfer." CI guidance
does not specify the use of EFVs on
stationary tankage, but recognizes that some
users choose to use EFVs in such a manner.
CI pamphlets addressing EFVs are identified
in the Information Resources section, below.
The installation of EFVs in stationary
tankage is commonly used with LPG and
anhydrous ammonia. NFPA, in its Liquefied
Petroleum Gas Code, specifies that, where
EFVs are required, the "connections, or line,
leading to or from any individual opening
shall have greater flow capacity than the
rated flow of the excess-flow valve
protecting the opening." CGA, in its Safety
Requirements for the Storage and Handling
of Anhydrous Ammonia, specifies that
"piping, including valves and fittings in the
same flow path as the excess flow valve,
shall have a greater capacity than the rated
flow of the excess flow valve."
The National Propane Gas Association
(NPGA) notes a number of conditions which
could result in the failure of an EFV to
close:
• Piping system restrictions such as pipe
length, branches, reduction in pipe size,
and partially closed shut-off valve,
could limit the flow rate through the
EFV.
• The size of break or damage
downstream of the EFV is not large
enough to allow a flow sufficient to
close the valve.
• The system pressure upstream of the
EFV is not high enough to produce a
closing flow rate.
• Foreign matter such as welding slag or a
build up of process contaminants lodged
in the EFV can prevent its closing.
• The piping break or damage occurs
upstream of an in-line EFV.
• The flow through the EFV is in the
wrong direction.
• The EFV has been damaged, or is
otherwise not operable.
Recognizing the limitations inherent in the
design and application of EFVs, NPGA, CI,
NFPA, and CGA all recommend or require
the use of some secondary means of
preventing uncontrolled releases in certain
high risk situations.
Controlling the Hazard
Careful analysis is required in order to
determine how much reliance can be placed
upon EFVs ability to bring the rate of
release under control, and to identify any
necessary and appropriate supplemental
controls for accidental releases.
System Design and Installation
System design and installation issues must
be considered in evaluating the degree of
reliance to be placed on an EFV.
Considerations should include:
• For the EFV to close, the failure in the
downstream piping must result in
enough flow to exceed the EFV
activation point. Analyze credible,
catastrophic failures at likely release
points, such as flexible hoses in
unloading systems, to determine if the
flow resistance in the piping both
upstream and downstream of the EFV
might prevent the EFV from closing.
Office of Emergency Management
Page 5
-------
Emergency Isolation for Hazardous Material Fluid Transfer Systems
Applications and Limitations of Excess Flow Valves
Revised June 2007
• The characteristics of the hazardous
material have to be considered. Release
rate calculations must address the effect
on flow rate of two-phase flow that will
result upstream of the release point
when liquefied compressed gases flash
to vapor as system pressure is released.
• The pressure in the vessel must be
adequate to produce the flow necessary
to seat the EFV. Consider the effects of
low vapor pressure liquids and
minimum credible winter temperatures.
• The type of EFV specified must be
appropriate to the intended service, and
any necessary constraints on the
physical orientation of the valve must be
identified.
• The system must be installed in strict
accordance to design specifications.
• The flow capacity of the EFV must be
great enough to avoid nuisance flow
stoppages caused by normal variations
in process flow rates, but not so high as
to negate its protective function.
• A piping system network with smaller
branch lines coming off the main line
will need separate EFVs to control
releases in these branch lines.
• A release that is not large enough to
activate the EFV can still be large
enough to lead to serious consequences
and thus require alternative control
capability.
Operation and Maintenance Practices
Like any safety device, an EFV must be
properly maintained and operated in order
for it to provide its intended protective
function. There should be:
• An appropriate inspection, testing
(including verification of flow rate
necessary to activate the EFV), and
preventive maintenance program for the
EFV based upon past experience, the
characteristics of the process stream,
and standard EFV maintenance
guidelines (e.g., CI Pamphlet 042, which
may provide guidance to facilities
handling other chemicals).
• Operating procedures and training to
address the operation of the EFV and all
supplemental controls.
• Controls to manage system changes that
might otherwise compromise the
function of the EFV. (Management of
Change)
Determining the Need for Additional
Protection
Facilities, absent any applicable industry
guidance or regulatory requirements, should
take a risk-based approach in evaluating the
need to supplement EFVs in controlling
accidental releases. Considerations,
addressing both the consequences and the
likelihood of a catastrophic release, would
include:
• The hazardous nature of the chemical
involved, such as toxicity, flammability,
and hazard to the environment.
• The size of potential releases, depending
on the potential for significant back-
flow to the point of release, size of
inventory, and flow rates involved.
• The likelihood of a release, depending
on frequency of loading and unloading
operations and type of equipment used.
A system containing flexible hoses or
articulated (swivel-joint) piping may be
more prone to a release than a system
containing more robust rigid piping.
• Local conditions such as the possibility
of flooding, mud or rock slides, wash-
outs, sink holes and subsidence or other
Office of Emergency Management
Page 6
-------
Emergency Isolation for Hazardous Material Fluid Transfer Systems
Applications and Limitations of Excess Flow Valves
Revised June 2007
earth movement situations warrant
particular attention for stationary
systems.
• The severity of a credible release on
surrounding populations, workers,
facilities, and the environment.
Alternative/Additional Means for
Controlling Releases
Industry guidance and regulatory
requirements increasingly recognize the
prudence of providing alternative means of
stopping accidental releases in certain
situations, either in place of or in addition to
EFVs. Examples of approaches used in
industry include:
• Remotely isolating leaking transfer
systems, with particular emphasis on
flexible hoses, by bolting fail-safe (air-
to-open) actuated valves on the
discharge side of railcar manual valves.
• Shut-off protection by quick closing
valves that can be controlled from
locations that would be accessible even
in the event of a release.
• Emergency shutoff valves equipped for
remote manual closure and automatic
shutoff using thermal (fire) actuation or
chemical detection. The valve may be
internal to the tank, in lieu of an EFV, or
it may be installed external to the tank
as close as practical to the tank outlet,
provided there is an internal EFV.
Emergency shut-off systems should be
thoroughly tested on a regular schedule
to ensure that they will operate as
intended when needed.
• Commercially available hoses with a
self closing device at each end that will
shut off flow entering the hose from
either direction if the hose is pulled
apart or sheared may be considered as
an additional measure of protection.
Such devices will protect against hose
failure, but not against leaks that occur
upstream or down-stream of the hose.
The technologies, systems, and practices
cited above are meant only to be illustrative;
they do not constitute a definitive list of
options, and are not meant to establish
'requirements' for any particular
application. Additional details are provided
in the references at the end of this Alert.
References to regulatory requirements and
industry best practices are not intended as
interpretations and users should consult the
referenced documents to determine
applicability to their own particular
circumstances.
If it is determined that manual ("hand-on")
intervention is the most appropriate
approach to responding to releases, a critical
analysis should be made of issues such as:
the number and location of isolation valves
relative to likely points of release; the
properties of the released chemical and the
correspondingly required personal protective
equipment (PPE); personnel staffing,
location and response times; and the
adequacy of training provided to personnel
responding to a release.
What Needs To Be Done
EPA urges users of EFVs to evaluate their
applications to verify the operability of in-
place controls and to determine whether
additional controls are warranted to
minimize the risk of release of hazardous
materials. Industry experience indicates that
sole reliance on EFVs to control accidental
releases may not always be sufficient and
needs to be substantiated by a thorough
engineering and risk evaluation. In most
cases where supplemental controls were
available and clearly identified, they were
successfully applied. Where this has not
been the case, appropriate revisions should
be made to Risk Management Program
elements such as operating procedures,
training, and emergency response plans.
Office of Emergency Management
Page 7
-------
Emergency Isolation for Hazardous Material Fluid Transfer Systems
Applications and Limitations of Excess Flow Valves
Revised June 2007
Conclusion
Millions of EFVs are in service and each
year many properly-sized and correctly
installed EFVs operate as intended to greatly
mitigate the consequences of hazardous
material releases. Incident investigations
show that when the EFV was in place but
did not function as intended, it was usually
because either the valve was not correctly
sized and flow-rated or line restrictions or
low inlet pressure prevented sufficient flow
needed for valve closure. Mechanical
malfunction of the EFV is very rarely shown
to be a contributing factor. Release rates
that are less than the EFV activation rate
represent a very serious situation. Natural
gas or city gas leaks downstream of the
regulator or meter fall into this category.
Alternate or additional means of release
prevention/mitigation should be installed for
high-risk situations and situations where
EFVs may not be effective.
Information Resources
References with information about the use
of EFVs and other methods for controlling
hazardous releases are listed below.
Regulations potentially applicable to EFVs
and codes and standards that may be
relevant are also included.
Statutes and Regulations
• Clean Air Act Section 112(r)(l) -
General Duty
• EPA's Risk Management Program Rule
[40 CFR 68]
• OSF£A Process Safety Management
Standard [29 CFR 1910.119]
• OSHA Standards: 29 CFR 1910.110,
Storage And Handling Of Liquefied
Petroleum Gases; 29 CFR 1910.111,
Storage and Handling of Anhydrous
Ammonia; and 29 CFR 1926.153,
Liquefied Petroleum Gas (LP-Gas)
• DOT regulations [49 CFR 171-180]
Codes and Standards
• The Chlorine Institute, Inc.: Pamphlet
001, Chlorine Manual; Pamphlet 042,
Maintenance Instructions for Chlorine
Institute Standard Excess Flow Valves;
Pamphlet 049, Recommended Practice
for Handling Bulk Highway Transports;
Pamphlet 057, Emergency Shut-Off
Systems for Bulk Transfer of Chlorine;
Pamphlet 066, Recommended Practice
for Handling Chlorine Tank Cars
• The Compressed Gas Association, Inc.:
ANSI K61.1 (CGA G-2.1), American
National Standard Safety Requirements
for the Storage and Handling of
Anhydrous Ammonia
• The National Fire Protection
Association, Inc.: NFPA 58, Liquefied
Petroleum Gas Code
• Freeman, R. A., and D.A. Shaw, "Sizing
Excess Flow Valves," Plant/Operations
Progress, Vol. 7, No. 3, July 1988
• UK Health and Safety Executive:
"Emergency Isolation,"
http: //www .hse.gov .uk/hid/land/comah/1
eve!3/5c7177c.htm
Accident Histories
• National Transportation Safety Board,
Hazardous Materials Accident Report
NTSB/HZM-02/01, "Hazardous
Materials Release From Railroad Tank
Car With Subsequent Fire at Riverview,
Michigan, July 14,2001"
• National Transportation Safety Board,
Pipeline Accident Report, NTSB/PAR-
01/01, "Natural Gas Explosion and Fire
in South Riding, Virginia July 7, 1998"
• U.S. Chemical Safety and Hazard
Investigation Board, Investigation
Report No. 98-0071-1-1A, "Propane
Tank Explosion (2 Deaths, 7 Injuries),
Office of Emergency Management
Page 8
-------
Emergency Isolation for Hazardous Material Fluid Transfer Systems
Applications and Limitations of Excess Flow Valves
Revised June 2007
Herrig Brothers Feather Creek Farm,
Albert City, Iowa, April 9, 1998."
U.S. Chemical Safety and Hazard
Investigation Board: Investigation
Report No. 2002-04-I-MO, "Chlorine
Release (66 Sought Medical
Evaluation), DPC Enterprises, L.P.,
Festus, Missouri, August 14, 2002."
U.S. Chemical Safety and Hazard
Investigation Board: Safety Advisory
No. 2002-01-SA, "Chlorine Transfer
Hose Failure"
U.S. Chemical Safety and Hazard
Investigation Board: Safety Bulletin
No. 2005-06-I-LA, "Emergency
Shutdown Systems for Chlorine
Transfer"
For More Information:
Call the Superfund, TRI, EPCRA, Risk Management Program,
and Oil Information Center
(800) 424-9346 or (703) 412-9810
TDD (800) 553-7672 or (703) 412-3323
Office of Emergency Management
Page 9
------- |