United States Office of Solid Waste EPA 550-F-0-7001

Environmental Protection and Emergency Response Revised June 2007

Agency (5104A) www.epa.gov/OEM

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 unintended release path to the atmosphere.

EFVs are intended to bring the release under
While excess flow valves (EFV) are in control until the leaking element (e.g. hose
extensive service and have prevented or pipe) can be blocked in and positively
numerous pipe or hose breaks from isolated for corrective action.
becoming much more serious incidents,
experience has shown that in some cases the Industry incident experience, however, has
EFV did not perform as intended, usually shown that under certain circumstances,
because of misapplication. Also, undue EFVs can fail to provide the protection
reliance must not be placed on EFVs as the anticipated of them. In fact, a number of
sole or primary protection to control significant releases of hazardous materials
accidental chemical releases from tanks or have occurred from systems ‘protected’ by
piping. EFVs. One event investigated by the
National Transportation Safety Board
Excess flow valves are protective devices (NTSB) resulted in the deaths of three plant
intended to prevent the uncontrolled release employees and the evacuation of 2,000
of hazardous materials from road, rail and nearby residents. Concerned that undue
marine transport vessels, stationary storage reliance might be placed upon EFVs, the
vessels and distribution networks. EFVs are NTSB recommended in its investigation
designed to close when the flow rate through report that EPA:
them exceeds the expected range of normal
operation, for example due to a downstream “Notify all facilities that are
leak or valving error that provides an required to submit risk management
plans to the Environmental

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Protection Agency that tank car significant incidents where flow restriction
excess flow valves cannot be relied prevented EFV closure.
upon to stop leaks that occur during
tank car loading and unloading 8/2002 in Missouri – A chlorine railcar
operations and that those companies transfer hose ruptured, releasing 48,000
that have included reliance on such pounds of chlorine. Hundreds of residents
valves in their risk management were evacuated or sheltered-in-place, and
plans should instead identify and sixty-three local residents sought medical
implement other measures that will evaluation; three were admitted to the
stop the uncontrolled release of hospital. The chlorine also damaged tree
product in the event of a transfer leaves and vegetation around the facility.
line failure during tank car loading The CSB determined that an excess flow
or unloading.” valve internal to the chlorine railcar did not
close, contributing to the severity of the
EPA shares the NTSB’s concerns and event. As a result of such chlorine releases,
additionally recognizes that the use of EFVs the CSB has issued a recommendation to the
extends beyond tank cars and includes Department of Transportation (DOT) to
loading and unloading operations associated expand the scope of DOT regulatory
with tank trucks, marine barges, stationary coverage to include chlorine railcar
tankage and piping distribution networks. unloading operations and ensure the
This Hazard Alert is intended to provide an regulations specifically require remotely
understanding of (1) how EFVs function, (2) operated emergency isolation devices that
circumstances that can lead to their failure to will quickly isolate a leak in any of the
function as intended, (3) important design flexible hoses (or piping components) used
and operational factors for enhancing the to unload a chlorine railcar.
reliability of EFVs, and (4) alternate means
available for stopping uncontrolled releases. 7/2001 in Michigan – A methyl mercaptan
release occurred when a pipe attached to a
Facilities should be aware of, and give fitting on the unloading line of a railroad
proper regard to, industry best practice tank car fractured and separated. Fire
guidance and regulatory requirements for damage to cargo transfer hoses on an
the use of EFVs. adjacent tank car also resulted in the release
of chlorine gas. Neither of the two EFVs
When they are properly designed, installed, closed to control the release. Three plant
and maintained, EFVs play an important employees were killed in the resulting
role in comprehensive accidental release explosion and several employees were
prevention systems. It is not EPA’s intent to injured. Approximately 2,000 local
dissuade the regulated community from the residents were evacuated from their homes
use of EFVs but, rather, to provide for 10 hours. Failure of the EFVs to close
precautionary guidance regarding their use contributed to the severity of the incident.
as a sole means of protection. The NTSB determined that the facility
placed undue reliance on the tank car EFV
Accidents to close in the event of a leak from the
transfer line.
Provision should be included for blocking in
(isolating) hazardous material transfer lines 4/1998 in Iowa – A propane release
in addition to the protection provided by occurred when a vehicle struck and severed
EFVs. As in the following incidents, failure unprotected, aboveground liquid and vapor
to understand the limitations of EFVs has lines serving an 18,000-gallon propane
been a contributing factor in a number of storage tank. The lines fed vaporizers,
which fueled heaters located in barns and

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other farm structures. The liquid line, which children. The investigation report concluded
was sharply reduced in pipe diameter, was that the release was attributed to the plastic
completely severed where it connected to a feed line being damaged by heat from a
manual shut-off valve directly beneath the faulty splicing in a buried electrical service
tank. The release ignited and the tank cable located close to the natural gas line.
subsequently exploded, killing two fire The natural gas feeder line was not equipped
fighters and injuring seven other emergency with an excess flow valve. Among the
personnel. A subsequent CSB investigation findings it was concluded that “Had an
determined that the flow capacity of the excess flow valve been installed in the gas
liquid outlet piping system downstream of line to the residence, the valve would have
the EFV was insufficient to allow the EFV closed after the hole in the pipeline
to close. developed, and the explosion likely would
not have occurred.”
9/1999 in North Carolina – More than
35,000 gallons of propane were released Understanding the
when the discharge hose on an LPG
transport truck separated from its hose Hazard
coupling at the delivery end of the hose, and
none of the safety systems on either the Proper use of EFVs requires an
truck or the receipt tank worked as intended understanding of their capabilities and their
to stop the release. The DOT determined limitations.
that emergency systems such as EFVs do
not always function properly when a pump The National Fire Protection Association
is used to unload the protected vessel. If a (NFPA) defines an EFV as a “valve
release occurs downstream of the pump and designed to close when the liquid or vapor
the EFV activation point is greater than the passing through it exceeds a prescribed flow
pump capacity, the pump will function as a rate” (NFPA 58). EFVs are most commonly
regulator limiting the flow to below that used on the liquid and vapor connections of
required to close the EFV. transport containers (e.g., rail cars and tank
trucks) and on some stationary tankage.
Two common themes in these accidents are EFVs are often installed inside of the vessel
that flow restrictions prevented the flow so that protection is provided even if the
through an EFV from exceeding the shut-off piping external to the vessel is damaged.
flow rate, and emergency isolation block EFVs are also very commonly used in
valves were not activated. A literature natural gas distribution lines serving end-
review revealed a number of additional users such as residential and commercial
incidents where the rates of discharge from consumers. Figure 1 shows an EFV installed
releases were insufficient to close the EFVs. in the liquid unloading line on a chlorine
railcar. In-line EFVs can also be installed in
The literature also shows, cases such as the external piping systems (e.g., to protect
one below, where an EFV was not installed individual distribution lines).
but would have been beneficial:

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

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Applications and Limitations of Excess Flow Valves Revised June 2007

against the seat, stopping the flow. This

design permits the valve to be installed in
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.

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 Figure 2. EFV for Chlorine Service
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 (OSHA) 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 3. EFV for Ammonia or LPG Services
figure. The valve shown in Figure 3 is used
in LPG and anhydrous ammonia service. A The potential for flow restrictions
spring normally holds the plug in the open preventing the closure of the EFV is well
position shown. When the flow through the recognized by organizations issuing good
valve is high enough, the plug is forced practice guidance for the use of EFVs. For

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Applications and Limitations of Excess Flow Valves Revised June 2007

example, the CI cautions that the EFV is • The system pressure upstream of the
principally a protection against an event that EFV is not high enough to produce a
damages the manual valve on the transport closing flow rate.
container during transit and not a protection
against damage to connected loading or • Foreign matter such as welding slag or a
unloading system piping. The CI notes that build up of process contaminants lodged
the EFV “may close if a catastrophic leak in the EFV can prevent its closing.
involving a broken connection occurs but it
is not designed to act as an emergency shut • The piping break or damage occurs
off device during transfer.” CI guidance upstream of an in-line EFV.
does not specify the use of EFVs on
stationary tankage, but recognizes that some • The flow through the EFV is in the
users choose to use EFVs in such a manner. wrong direction.
CI pamphlets addressing EFVs are identified
in the Information Resources section, below. • The EFV has been damaged, or is
otherwise not operable.
The installation of EFVs in stationary
tankage is commonly used with LPG and Recognizing the limitations inherent in the
anhydrous ammonia. NFPA, in its Liquefied design and application of EFVs, NPGA, CI,
Petroleum Gas Code, specifies that, where NFPA, and CGA all recommend or require
EFVs are required, the “connections, or line, the use of some secondary means of
leading to or from any individual opening preventing uncontrolled releases in certain
shall have greater flow capacity than the high risk situations.
rated flow of the excess-flow valve
protecting the opening.” CGA, in its Safety
Requirements for the Storage and Handling Controlling the Hazard
of Anhydrous Ammonia, specifies that
“piping, including valves and fittings in the Careful analysis is required in order to
same flow path as the excess flow valve, determine how much reliance can be placed
shall have a greater capacity than the rated upon EFV’s ability to bring the rate of
flow of the excess flow valve.” release under control, and to identify any
necessary and appropriate supplemental
The National Propane Gas Association controls for accidental releases.
(NPGA) notes a number of conditions which
could result in the failure of an EFV to System Design and Installation
close:
System design and installation issues must
• Piping system restrictions such as pipe be considered in evaluating the degree of
length, branches, reduction in pipe size, reliance to be placed on an EFV.
and partially closed shut-off valve, Considerations should include:
could limit the flow rate through the
EFV. • For the EFV to close, the failure in the
downstream piping must result in
• The size of break or damage enough flow to exceed the EFV
downstream of the EFV is not large activation point. Analyze credible,
enough to allow a flow sufficient to catastrophic failures at likely release
close the valve. 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.

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necessary to activate the EFV), and

• The characteristics of the hazardous preventive maintenance program for the
material have to be considered. Release EFV based upon past experience, the
rate calculations must address the effect characteristics of the process stream,
on flow rate of two-phase flow that will and standard EFV maintenance
result upstream of the release point guidelines (e.g., CI Pamphlet 042, which
when liquefied compressed gases flash may provide guidance to facilities
to vapor as system pressure is released. handling other chemicals).

• The pressure in the vessel must be • Operating procedures and training to

adequate to produce the flow necessary address the operation of the EFV and all
to seat the EFV. Consider the effects of supplemental controls.
low vapor pressure liquids and
minimum credible winter temperatures. • Controls to manage system changes that
might otherwise compromise the
• The type of EFV specified must be function of the EFV. (Management of
appropriate to the intended service, and Change)
any necessary constraints on the
physical orientation of the valve must be Determining the Need for Additional
identified. Protection

• The system must be installed in strict Facilities, absent any applicable industry
accordance to design specifications. guidance or regulatory requirements, should
take a risk-based approach in evaluating the
• The flow capacity of the EFV must be need to supplement EFVs in controlling
great enough to avoid nuisance flow accidental releases. Considerations,
stoppages caused by normal variations addressing both the consequences and the
in process flow rates, but not so high as likelihood of a catastrophic release, would
to negate its protective function. include:

• A piping system network with smaller • The hazardous nature of the chemical
branch lines coming off the main line involved, such as toxicity, flammability,
will need separate EFVs to control and hazard to the environment.
releases in these branch lines.
• The size of potential releases, depending
• A release that is not large enough to on the potential for significant back-
activate the EFV can still be large flow to the point of release, size of
enough to lead to serious consequences inventory, and flow rates involved.
and thus require alternative control
capability. • The likelihood of a release, depending
on frequency of loading and unloading
Operation and Maintenance Practices operations and type of equipment used.
A system containing flexible hoses or
Like any safety device, an EFV must be articulated (swivel-joint) piping may be
properly maintained and operated in order more prone to a release than a system
for it to provide its intended protective containing more robust rigid piping.
function. There should be:
• Local conditions such as the possibility
• An appropriate inspection, testing of flooding, mud or rock slides, wash
(including verification of flow rate outs, sink holes and subsidence or other

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earth movement situations warrant failure, but not against leaks that occur
particular attention for stationary upstream or down-stream of the hose.
systems.
The technologies, systems, and practices
• The severity of a credible release on cited above are meant only to be illustrative;
surrounding populations, workers, they do not constitute a definitive list of
facilities, and the environment. options, and are not meant to establish
‘requirements’ for any particular
Alternative/Additional Means for application. Additional details are provided
Controlling Releases in the references at the end of this Alert.
References to regulatory requirements and
Industry guidance and regulatory industry best practices are not intended as
requirements increasingly recognize the interpretations and users should consult the
prudence of providing alternative means of referenced documents to determine
stopping accidental releases in certain applicability to their own particular
situations, either in place of or in addition to circumstances.
EFVs. Examples of approaches used in
industry include: If it is determined that manual (“hand-on”)
intervention is the most appropriate
• Remotely isolating leaking transfer approach to responding to releases, a critical
systems, with particular emphasis on analysis should be made of issues such as:
flexible hoses, by bolting fail-safe (air the number and location of isolation valves
to-open) actuated valves on the relative to likely points of release; the
discharge side of railcar manual valves. properties of the released chemical and the
correspondingly required personal protective
• Shut-off protection by quick closing equipment (PPE); personnel staffing,
valves that can be controlled from location and response times; and the
locations that would be accessible even adequacy of training provided to personnel
in the event of a release. responding to a release.

• Emergency shutoff valves equipped for What Needs To Be Done

remote manual closure and automatic
shutoff using thermal (fire) actuation or EPA urges users of EFVs to evaluate their
chemical detection. The valve may be applications to verify the operability of in-
internal to the tank, in lieu of an EFV, or place controls and to determine whether
it may be installed external to the tank additional controls are warranted to
as close as practical to the tank outlet, minimize the risk of release of hazardous
provided there is an internal EFV. materials. Industry experience indicates that
Emergency shut-off systems should be sole reliance on EFVs to control accidental
thoroughly tested on a regular schedule releases may not always be sufficient and
to ensure that they will operate as needs to be substantiated by a thorough
intended when needed. engineering and risk evaluation. In most
cases where supplemental controls were
• Commercially available hoses with a available and clearly identified, they were
self closing device at each end that will successfully applied. Where this has not
shut off flow entering the hose from been the case, appropriate revisions should
either direction if the hose is pulled be made to Risk Management Program
apart or sheared may be considered as elements such as operating procedures,
an additional measure of protection. training, and emergency response plans.
Such devices will protect against hose

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Applications and Limitations of Excess Flow Valves Revised June 2007

Conclusion Codes and Standards

• The Chlorine Institute, Inc.: Pamphlet

Millions of EFVs are in service and each
001, Chlorine Manual; Pamphlet 042,
year many properly-sized and correctly
Maintenance Instructions for Chlorine
installed EFVs operate as intended to greatly
Institute Standard Excess Flow Valves;
mitigate the consequences of hazardous
Pamphlet 049, Recommended Practice
material releases. Incident investigations
for Handling Bulk Highway Transports;
show that when the EFV was in place but
Pamphlet 057, Emergency Shut-Off
did not function as intended, it was usually
Systems for Bulk Transfer of Chlorine;
because either the valve was not correctly
Pamphlet 066, Recommended Practice
sized and flow-rated or line restrictions or
for Handling Chlorine Tank Cars
low inlet pressure prevented sufficient flow
needed for valve closure. Mechanical
• The Compressed Gas Association, Inc.:
malfunction of the EFV is very rarely shown
ANSI K61.1 (CGA G-2.1), American
to be a contributing factor. Release rates
that are less than the EFV activation rate National Standard Safety Requirements
represent a very serious situation. Natural for the Storage and Handling of
gas or city gas leaks downstream of the Anhydrous Ammonia
regulator or meter fall into this category.
Alternate or additional means of release • The National Fire Protection
prevention/mitigation should be installed for Association, Inc.: NFPA 58, Liquefied
high-risk situations and situations where Petroleum Gas Code
EFV’s may not be effective.
• Freeman, R. A., and D.A. Shaw, “Sizing
Excess Flow Valves,” Plant/Operations
Information Resources Progress, Vol. 7, No. 3, July 1988

References with information about the use • UK Health and Safety Executive:
of EFVs and other methods for controlling “Emergency Isolation,“
hazardous releases are listed below. http://www.hse.gov.uk/hid/land/comah/l
Regulations potentially applicable to EFVs evel3/5c7177c.htm
and codes and standards that may be
relevant are also included. Accident Histories

Statutes and Regulations • National Transportation Safety Board,

Hazardous Materials Accident Report
• Clean Air Act Section 112(r)(1) – NTSB/HZM-02/01, “Hazardous
General Duty Materials Release From Railroad Tank
• EPA’s Risk Management Program Rule Car With Subsequent Fire at Riverview,
[40 CFR 68] Michigan, July 14, 2001”
• OSHA Process Safety Management
Standard [29 CFR 1910.119] • National Transportation Safety Board,
• OSHA Standards: 29 CFR 1910.110, Pipeline Accident Report, NTSB/PAR
Storage And Handling Of Liquefied 01/01, “Natural Gas Explosion and Fire
Petroleum Gases; 29 CFR 1910.111, in South Riding, Virginia July 7, 1998”
Storage and Handling of Anhydrous
Ammonia; and 29 CFR 1926.153, • U.S. Chemical Safety and Hazard
Liquefied Petroleum Gas (LP-Gas) Investigation Board, Investigation
• DOT regulations [49 CFR 171-180] Report No. 98-0071-1-1A, “Propane
Tank Explosion (2 Deaths, 7 Injuries),

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Emergency Isolation for Hazardous Material Fluid Transfer Systems –

Applications and Limitations of Excess Flow Valves Revised June 2007

Herrig Brothers Feather Creek Farm, No. 2002-01-SA, “Chlorine Transfer

Albert City, Iowa, April 9, 1998.” Hose Failure”

• U.S. Chemical Safety and Hazard • U.S. Chemical Safety and Hazard
Investigation Board: Investigation Investigation Board: Safety Bulletin
Report No. 2002-04-I-MO, “Chlorine No. 2005-06-I-LA, “Emergency
Release (66 Sought Medical Shutdown Systems for Chlorine
Evaluation), DPC Enterprises, L.P., Transfer”
Festus, Missouri, August 14, 2002.”

• U.S. Chemical Safety and Hazard

Investigation Board: Safety Advisory

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

Notice: The statements in this document are intended solely as guidance.

This document does not substitute for or change any applicable statutory
provisions or regulations, nor is it a regulation itself. The guidance it provides
may not be appropriate for every situation.

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