Some Excess Flow Valves (EXFVs) models can be placed into a position that would render them useless in their intended function. I have encountered this scenario more than once during my PHAs, Investigations, Audits, etc. There are not many manufacturers that incorporate this failure mode in their designs, but there a couple that do; and for those that do, I HIGHLY RECOMMEND these valves be placed into the facility’s Car-Seal Program to ensure that these safety critical valves are MAINTAINED in their “safe operational position”.
