1. Implementation and Management of Leak Detection and Repair Programs – New Rules and Other Considerations
Nebraska Ethanol Safety & Environmental Coalition (NESEC)
March 4, 2010

2. Agenda About Us Why LDAR?
Considerations for Implementation and Management of an LDAR Program
New Rules and Challenges
Questions

4. Why LDAR?
Control leaks of Volatile Organic Compounds (VOC) – precursors to Ozone - and Hazardous Air Pollutants (HAPs)
Is part of the New Source Performance Standards (NSPS)
VOCs are a primary source of fugitive emissions from refineries and chemical plants.
Economics
Safety

5. Chemical Plants
Concern is leaks from valves, flanges, connectors, open-ended lines and other equipment
Primary regulation is NSPS Subpart VV and VVa
Number of ways to identify leaks
Inventory control
Audio, Visual, Olfactory
Instrument Detection
Smart LDAR (Infrared Camera)
Controlling leaks
Process design
Equipment selection (“leakless” components and “seal-less” pumps)
Monitoring

6. What do we mean when we say LDAR?
For Chemical Plants
LDAR is a work practice
Involves the identification of regulated components and equipment
Monitoring at specified intervals by prescribed methods
Repair within specified time frames
Recordkeeping and reporting

7. Elements of LDAR Identification of Components Leak Definition
Monitoring
Repair
Recordkeeping &
Reporting

8. Model LDAR Program Written LDAR program Training Accountability Audits
Electronic monitoring and storage of data
QA/QC of LDAR data
Records maintenance

9. Elements of a Written LDAR Program
Method for identifying equipment subject to LDAR
Procedures for identifying leaking equipment
Procedures for repairing and keeping track of leaking equipment
Process for evaluating new and replacement equipment

10. Elements of an LDAR Program
A detailed description of the facility’s LDAR organization
Procedures for inventory modifications
Procedures associated with specific aspects of the site’s LDAR program
Training expectations and requirements
Overall leak rate goals to be obtained on a unit by unit basis

11. Roles & Responsibilities
LDAR Coordinator
Data Base Manager
Monitoring Personnel
Responsibilities that need to be assigned.
Monitoring
Data Collection and Validation
Scheduling
Repair and Re-monitoring

12. Monitoring
Audible, Visual, Olfactory (AVO)
Method 21
Smart LDAR

13. Method 21 EPA method of detecting VOC leaks from equipment sources
Instrument requirements
Calibration requirements
Monitoring techniques for individual equipment types
Safety requirements

14. Recordkeeping
Information must be kept in a “readily accessible location” for 2 years
List of equipment ID numbers subject to the rule (component inventory)
Monitoring information
Calibration records
Leaking equipment information
Delayed repair information
Unsafe to Monitor (UTM)
Difficult to Monitor (DTM)

15. Reporting Initial report due within 180 days of startup
Semiannual report due every 6 months thereafter
Must Report:
Process unit identification
Number of valves, pumps, PRVs, and compressors for which leaks were detected, and those not repaired within 15 days
Facts explaining each delay of repair
Dates of process unit shutdowns >24 hours
Revisions made to the inventory

16. Data Accuracy
Daily QA/QC
Periodic
Monthly
Quarterly

17. Other Program Considerations
DTMs
UTMs
OELs
Reporting
Training

18. Inventory & Inventory Control

19. Repair
First Attempt
Repair Timing
Delay of Repair
Chronic Leakers

20. Delay of Repair
Delay of repair of leaking equipment is allowed if repair within 15 days is technically infeasible without a process unit shutdown
Repairs must occur during the next scheduled shutdown
Delay of repair can not be used as a convenience tool, and records must be authorized and signed by the facility owner/operator

21. Common Compliance Issues
Not identifying all regulated components
Improper classification of components (unsafe or difficult to monitor)
Missed monitoring events
Improper monitoring of components
Failing to maintain monitoring equipment
Improper use of delay of repair
Recordkeeping and Reporting Issues
Open Ended Lines

22. Subpart VV and VVa
The primary regulation and the basis for many LDAR regulations – federal and state
VV was amended on Nov. 16, 2007
A stay was imposed (until August 1, 2008) but only affects
The definition of process unit and the storage vessels associated with the process unit
Connectors ( a)

23. Amendments to VV New Definitions Clarification of Process Unit
Requirements for New Equipment
Requirements for Containers in Closed-Purge Sampling Systems
Monitoring Requirements for Pumps on Delay of Repair
Examples of First Attempts

24. Other Key Definitions First Attempt at Repair Repaired
means each valve, pump, pressure relief device, sampling connection system, open-ended valve or line, and flange or other connector in VOC service.
Repaired
means that equipment is adjusted, or otherwise altered, in order to eliminate a leak as defined in the applicable sections of the subpart and is re- monitored as specified in (b) to verify that emissions from the equipment are below the applicable leak definition.

25. New Equipment Requirements
Pumps (a)(1)
A pump that begins operation in light liquid service after the initial startup date for the process unit must be monitored for the first time within 30 days after the end of its startup period.
Valves (a)(2)
A valve that begins operation in gas/vapor service or light liquid service must be monitored for the first time within 30 days after the end of its startup period.

26. Weekly Visual Inspections
Weekly visual pump inspections are required by Subpart VV and VVa
Repair requirements for visually leaking pumps
No reporting requirement for visual inspections, but must be able to demonstrate compliance

27. Changes to Visual Inspection Requirements
For Pumps
If there are indications of liquids dripping from the pump seal at the time of the weekly inspection
Monitor the pump within 5 days as to determine if there is a leak of VOC or barrier fluid.
Designate the visual indications of liquids dripping as a leak
Note there was a change in the sensor leak information as well (d)(5)(i)

28. Other General Changes
Added a provision that containers part of a closed-purge system must be covered or closed when not being filled or emptied.
Added – as an alternative to monitoring all of the valves in the first month of a quarter, an owner may elect to subdivided the process unit into 2 or 3 groups of valves and monitor each subgroup in a different month during the quarter, provided each subgroup is monitored every 3 months. The owner must keep records of the valves assigned to each subgroup.
Explanation for calculating the percent of valves leaking.
Added some provisions for equipment in Batch or in Service less than 300 hours per year.

29. VVa
For affected facilities that commenced construction, reconstruction, or modification after Nov. 7, 2006.
Demonstrate compliance within 180 days of initial startup.
New leak definitions of 2000 ppm for most pumps, and 500 ppm for valves, connectors, and pressure relief devices
New requirements for Connectors in VVa a

30. VVa Applicability
Modification means any physical or operational change to an existing facility which results in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies
Routine maintenance, repair, or replacement of equipment does not meet the requirements of a “modification”

31. VVa Applicability
Reconstruction means the replacement of components of an existing facility where the fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility

32. VVa Applicability
A facility must comply with Subpart VVa if it meets the definitions of construction, reconstruction, or modification after November 7, 2006

33. 60.482-11a Connectors in gas/vapor and light liquid service
Initially monitor all connectors in the process unit by the later of either 12 months after the compliance date or 12 months after the initial startup. (If all connectors in the process unit have been monitored for leaks prior to the compliance date, no initial monitoring is required provided not process changes have been made.)
Leak Rate is 500 ppm
Perform monitoring subsequent to the initial monitoring:
If %leaking is >0.5 % within 12 months.
If %leaking is >0.25% but <0.5% within 4 years.
If %leaking is <0.25% there is a specified time table.
Stayed until August 1, 2008

34. Actions
Need to evaluate your facilities practices to incorporate changes.
Need to self audit to ensure compliance.
Need to look carefully at new equipment in existing units and look at the rule for equipment subject to VVa
Watch the new record keeping requirements.

35. Questions?