Developing and Complying with LDAR Programs Robert vandenMeiracker

2 C R E A T I N G B A L A N C E SM What is LDAR (elledar)?  A) Elf-like humanoids  B) Lightning Detection and Ranging  C) Enemy of Superman  D) Lineal Daughters of the American Revolution  E) Leak Detection and Repair

3 C R E A T I N G B A L A N C E SM What is LDAR?  Regulatory Basis: –New Source Performance Standards (NSPS) VOC’s –National Emission Standards for Hazardous Air Pollutants (NESHAP) Organic HAP’s –Resource Conservation and Recovery Act (RCRA) Hazardous Waste –State Rules

4 C R E A T I N G B A L A N C E SM LDAR Applicability  Industry Subject to LDAR –Chemicals, Polymers, & Resins –Pharmaceutical –Pesticide –Pulp and Paper –Hazardous Waste Storage  Equipment in VOC / HAP / Haz. Waste Service pumpcompressor valveconnector agitatorpressure relief device instrumentation systemsampling connection system

5 C R E A T I N G B A L A N C E SM USEPA Enforcement Priorities (Beverly Bannister, Air, Pesticides and Toxics Management Division EPA, Region 4 presentation at the Carolinas Air Pollution Control Association 2008 Spring Conference)  USEPA FY08 Air Toxics National Sectors –Leak Detection and Repair –Flaring –Surface Coating  Air Toxics Region 4 Sectors –Ongoing –Secondary Aluminum MACT –Pesticides Active Ingredient MACT –Pharmaceutical Production MACT –Phosphoric Acid Mfg/Phosphate Fertilizer MACT –Leak Detection and Repair MACT Sectors

6 C R E A T I N G B A L A N C E SM

7 C R E A T I N G B A L A N C E SM 5 “Easy” Steps to a Successful Program  Identify Equipment  Monitor Equipment  Fix Equipment (if it is leaking)  Keep Records Documenting Everything  Repeat

8 C R E A T I N G B A L A N C E SM Identify Equipment  Read the Applicable Rule(s) –2 to 4 Applicable Rules Not Uncommon –Requirements for Each Rule are Different –Not All Equipment is Subject Part of the Production Unit Threshold Amount of Material  Study Process and Instrumentation Diagrams  Field Verification

9 C R E A T I N G B A L A N C E SM How Many Monitoring Points?  Pulp and Paper Mill: 600  Chemical Plant: 50,000  Polymer Production: 500  17 Refineries (Valves only) –Minimum # 2,229 –Maximum #42,505 –Average10,042  Source: US EPA Enforcement Alert, October 1999

10 C R E A T I N G B A L A N C E SM Example Diagram

11 C R E A T I N G B A L A N C E SM

12 C R E A T I N G B A L A N C E SM Example Picture

13 C R E A T I N G B A L A N C E SM Identify Equipment  Tags –Metal, Plastic, Label, RF Devices, etc.  Diagrams  Pictures  Tables  Post-It ® Notes not Recommended

14 C R E A T I N G B A L A N C E SM Monitoring Frequency  Weekly –RCRA & Generic MACT Pumps  Monthly –Most Sources  Quarterly –Allowances for Documented Non-Leaking Equipment  Annually –Pulp and Paper Equipment  Non-Routine –After Process Safety Device Release  Minimum Number of days between Inspections

15 C R E A T I N G B A L A N C E SM Monitoring Types  Sensory –Visual, Olfactory and Auditory –“Non-Volatile” Materials / Oils / Low Vapor Pressure  Equipment (40 CFR 60, Method 21) –Photo-Ionization Detector (PID) –Flame Ionization Detector (FID) –Does not detect specific compounds –Does not give actual Concentration

16 C R E A T I N G B A L A N C E SM Monitoring Equipment  Specifications –Response Factor < 10 (sample conc. / reading) –Response Time < 30 seconds –Flow Rate (0.1 to 3.0 l/min) –Accuracy / Precision  Safety –Electrically Classified Area? –Intrinsically Safe Equipment  Other Considerations –Weight, Size, Portability, & Durability

17 C R E A T I N G B A L A N C E SM Monitoring Equipment Picture

18 C R E A T I N G B A L A N C E SM Calibration Requirements  Initial Response Factor Test –Verify Instrument Responds to the Material(s) to be Detected –Can Use Manufacturer Data for Common Compounds  Quarterly Precision –Zero Air and Standard Gas –Standard is Usually Methane –Can be Frustrating, Error < 10% of Calibration Gas  Daily Calibration (when in use)

19 C R E A T I N G B A L A N C E SM What is a Leak?  Sensory Observation  Instrument Reading –Varies by Rule and Equipment –MON Agitators > 10,000 ppmv –Amino/Phenolic Resin Connectors > 500 ppmv –Pharmaceutical Pumps > 2,000 pppmv –Pulp and Paper Closed Vent Components > 500 ppmv

20 C R E A T I N G B A L A N C E SM What if a Leak is Detected?  Tag it in an Obvious Manner  Initial Attempt at Repair Within 5 days –Usually Done with Simple Tools  Final Repair Within 15 days –May Require Replacing Seals –Replace Equipment  Exemptions Allowed in Certain Instances  Keep Records –1 st Attempt / Successful Repair / Document Repaired –Equipment not Repaired within 5/15 day timeframe –Develop a Quality Improvement Program (QIP)

21 C R E A T I N G B A L A N C E SM Recordkeeping  Records: –Equipment List (including exemptions)  Depends on Facility –Potentially 1,000’s of points to monitor and keep records –Small: Tables, Forms, etc. –Medium to Large: Integrate LDAR Monitor with off-the-shelf Computer Software

22 C R E A T I N G B A L A N C E SM Exemptions  Difficult / Unsafe to Monitor –Develop Schedule  Vacuum Service –Usually Based on level of vacuum (i.e., <-5 kPa)  Equipment in Service < 300 hr/hr generally exempt  Equipment Designed not to Leak –Welded Connections

23 C R E A T I N G B A L A N C E SM Difficult / Unsafe to Monitor

24 C R E A T I N G B A L A N C E SM Who?  Identification –Collaboration –Environmental / Production/ Engineering / Maintenance  Monitoring –Environmental / Production / Maintenance –Contract Service  Recordkeeping & Reporting –Environmental

25 C R E A T I N G B A L A N C E SM Monitoring Equipment  Usually must be Purchased ($8,000+)  Calibration / Precision Testing Gases –Watch Expiration Dates  Batteries  FID’s Use Hydrogen  Periodic Maintenance  Can be Rented  Other Uses

26 C R E A T I N G B A L A N C E SM Title V Deviations  If equipment is repaired within the appropriate timeframe: Usually not a Deviation  Deviations –Equipment is not Inspected as Required –Equipment is not Repaired within Required Timeframes –Records are not Maintained

27 C R E A T I N G B A L A N C E SM Benefits of LDAR  Credit for Emissions Reductions –Lower Fees –Minor Source –Exemption from Modeling –PSD Netting –Reduction in SARA Emission Estimates  Safety  Monitoring Equipment may have other Uses –Confined Space Entry Monitoring –Non-Regulatory Monitoring

28 C R E A T I N G B A L A N C E SM Challenges to Effective LDAR Compliance  Rules are Complex  Magnitude of Source to Manage is Typically Huge  The numbers involved make it difficult to be perfect always, everytime.

29 C R E A T I N G B A L A N C E SM Complexity  Varying Monitoring Schedules –Different schedules for different types of equipment Pumps, Weekly Visual, Monthly M-21 PRD – GV, M21 within 5 days of Activation Connectors, HL, M-21 after leak repairs –Different schedules for different regulations Valves, GV, LL –Monthly or via Skip Frequency (VV, RCRA, & V) –Quarterly or via Skip Frequency (HON)

30 C R E A T I N G B A L A N C E SM Complexity  Determining individual leak points –Water Lines Steam Lines –Compressed Air Lines –Nitrogen / Inert Gas Lines –Heat Transfer Fluid Lines –Process Lines without Affected Chemicals –Process Lines with Affected Chemicals at Less than Threshold Values –Process lines with affected chemicals –Gas / Vapor –Light Liquid –Heavy Liquid

31 C R E A T I N G B A L A N C E SM Administrative Burden  Compliance Must be Proven –Current LDAR requires Detailed Documentation. –Records are Required for Each Point –Tags for Each Point –Tags for Leakers –Maintenance Records for Each Repair & Repair Attempt –Records for Delays

32 C R E A T I N G B A L A N C E SM Magnitude  Challenges –Easy to miss one or two out of hundreds during set-up or during monitoring –Many tags to maintain –Many records to maintain –Potential for confusion –With hundreds of non-leaking sources, easy for technicians to become complacent –Costly

33 C R E A T I N G B A L A N C E SM Requirements for a Good Program  Set-Up –Accurate Drawings –Detailed Knowledge of Process Conditions Composition, Vapor Pressure, Pressure or Vacuum Service? –Assignment of Organized, Detailed Oriented Personnel

34 C R E A T I N G B A L A N C E SM Requirements for a Good Program  Set-Up –Commitment of Resources May all be Internally Supplied May be Lead and Implemented by Contractor HOWEVER, Must Include Process Knowledge which is Available for Effective Use During Development & Implementation

35 C R E A T I N G B A L A N C E SM Requirements for a Good Program  Good Software Aids in Unraveling Complexity Issues –Can Address Leak Rate Definitions –Can Document Which Programs Apply –Can Aid in Scheduling and Ensuring Monitoring is Done on Schedule –Can Aid in Ensuring Repairs Made Within Deadlines But Software is a Tool and Cannot Eliminate the Basic Challenge that the Rules are Complex.

36 C R E A T I N G B A L A N C E SM Requirements for a Good Program  Running the Program –Management Commitment to Compliance with Monitoring & Repair Deadlines is Vital –Communication between Monitoring Team, Operations, and Maintenance

37 C R E A T I N G B A L A N C E SM Alternatives  "Smart" LDAR  Audible – Visual - Olfactory –Mandated –As an Alternative

38 C R E A T I N G B A L A N C E SM Summary  LDAR programs are difficult to fully implement because… –The rules are complex, and –The piping systems they are intended to regulated consist of literally thousands of components.