Leak detection and repair (LDAR) regulations and compliance programs were put into place by the U.S. Environmental Protection Agency (EPA) because of the amount of volatile organic compounds (VOCs) and volatile hazardous pollutants (VHAPs) emitted by leaking equipment such as valves, pumps and connectors in industries including petroleum refining and chemical manufacturing. LDAR managers and technicians are required to follow fundamental LDAR procedures, such as Method 21 monitoring techniques and analyzer calibration procedures, to keep LDAR programs in compliance.
An LDAR program is the system of procedures a facility uses to locate and repair leaking components—including valves, pumps, connectors, compressors and agitators—in order to minimize the emission of fugitive VOCs and VHAPs. The EPA conducts audits and pursues enforcement actions in the petroleum refining and chemical manufacturing industries in order to verify minimization of VOC and VHAP emissions.
LDAR Program Best Practices
At a minimum, LDAR programs should include scheduling inspections to ensure compliance, producing and tracking work orders as soon as leaking components are discovered, and environmental reporting. Successful LDAR programs’ best practices implementations are listed on page 90.
These best practices are streamlined with the use of automatic data capture technology featuring the right bar code labels for an LDAR program.
Benefits of LDAR Programs
Obviously, cost savings, environmental protection, and worker and community safety are the goals of an effective LDAR program. The specific benefits of LDAR programs are eye-opening, as petroleum refineries could reduce emissions from equipment leaks by 65 percent and chemical facilities could reduce VOC emissions by 60 percent. Additionally, the EPA estimates that facilities could potentially save $800,000 per year per facility, based on the average value of product loss due to equipment leaks being $1,400 per ton.
Choosing an effective asset management solution is key to successful LDAR management. Using automatic identification and data capture practices along with durable, application-suitable LDAR tags and steam trap tags that are compatible with asset management software applications streamlines the process of gathering and maintaining large quantities of data for regulated parts and equipment. This reduces the manual documentation time ordinarily required for extensive recordkeeping, yet also ensures regulation reporting is precise and easy to generate.
Though fugitive emissions and LDAR programs are complicated by nature, these programs generally have five primary components. While the specific requirements may vary among federal and state regulations, every LDAR program should include the following features.
1. Identifying Components
Every regulated component must have a unique identification number, along with an identified location. An equipment log should be maintained that contains information on replacement parts, newly added equipment and equipment taken out of service. ID numbers should be marked on the equipment and on instrumentation diagrams. LDAR equipment in the field faces tough environmental conditions on a daily basis. But the identifying components must remain readable for the life of the equipment.
2. Leak Definition
Measured in parts per million (ppm), leaks are defined as measured concentration exceeding a standard, accepted threshold based on the relevant regulation. Different federal and state regulations have different accepted thresholds, and what is considered an acceptable level may differ according to the industry. In some cases, multiple regulations may apply within the same facility, which adds confusion. To solve this problem, the EPA recommends defining leaks at a level lower than the minimum accepted threshold among all applicable regulations.
3. Monitoring Components
The primary method used to monitor components for the purpose of leak detection is EPA Reference Method 21. Method 21 uses a portable detecting instrument to periodically evaluate emissions weekly, monthly, quarterly or annually. This frequency is also defined in regulatory guidelines and may vary among specific regulations and by industry.
4. Repairing Components
Regulatory guidelines set a deadline by which detected leaks must be repaired, ranging from a few days to several weeks. Typically, repair must be attempted within five days after a leak is detected, and a second attempt must occur within 15 days if the first attempt is unsuccessful. Other regulations set approved repair practices, such as tightening bonnet bolts or packing gland nuts. If a repair requires that equipment be shut down, it may be placed on a Delay of Repair list if properly warranted and documented.
For example, all other repair alternatives not requiring shutdown must be explored before equipment may be justifiably placed on the Delay of Repair list. Asset management systems that use LDAR tags can help monitor life cycle and predictive maintenance, as well as help perform reliability studies on equipment. Knowing when equipment needs repair or replacing ahead of time reduces downtime and increases efficiency. Instead of manually documenting identification numbers and repair requests, operators can simply scan the corresponding asset tag to automatically place equipment in a maintenance and repair queue.
Likewise, repair attempts can be more easily documented without the risk of human error leading to inaccurate or outdated records.
LDAR regulations have strict documentation standards, requiring a vast amount of information about every regulated part to be carefully documented and maintained with accurate information. Employing an asset management system that focuses on automatic identification and data capture makes data collection faster, less expensive and more accurate than manual data collection.
When these five elements become automated, man-hour demands and overhead costs are reduced, enabling effective LDAR management while reducing complexity and ensuring compliance. If a facility is subject to LDAR regulations and operators are relying on manual identification and documentation methods, a facility can drastically reduce compliance costs by implementing a comprehensive asset management program that focuses on automatic data capture with LDAR tags.
Facilities and maintenance management are critical functions that have benefited greatly from advances in technology, yet some maintenance departments have remained stagnant for decades. Where there is introduction of innovative technology, the impact has been tremendous on outdated facilities and maintenance management practices, inspiring some key trends likely to shift the industry as a whole in the coming years.
Traditional facilities and maintenance management methods are now unheard of in most organizations. With the availability of software applications that integrate with existing business systems, paper and pencil methods pale in comparison in terms of accuracy and availability of data.
Mobile devices are more connected and portable than ever, with sophisticated capabilities and the ability to perform myriad complex tasks with the help of mobile apps.
Any smartphone can now serve multiple functions for example, as a barcode scanner by downloading a simple application. Now, mobile devices make it possible to achieve almost every desired outcome without ever speaking directly to another human being.
LDAR Best Practices
- Integrate an awareness of the benefits of leak detection and repair into the company’s operating and maintenance program.
- Write an LDAR program that includes an overall, facility-wide leak rate goal, procedures for identifying leaking equipment within process units, procedures for repairing and keeping track of leaking equipment, and more.
- Provide training that provides LDAR personnel with technical understanding to implement the written LDAR program and educate LDAR team members on their individual responsibilities.
- Audit the LDAR program using internal and third-party groups to ensure it is correctly conducted and that issues are identified and corrected.
- Put sufficient oversight procedures into place to increase accountability of contractors performing monitoring.
- Use an internal leak definition for valves and pumps in light liquid or gas vapor service, and monitor against that uniform definition.
- Make a first attempt at repair within five days of leak detection and a final repair within 15 days; place any component that cannot be repaired within those time frames on a Delay of Repair list to be repaired during the next shutdown cycle.
- Include a plan for more frequent component monitoring, especially of those that contribute most to equipment leak emissions.
- Ensure that you can justify the equipment on the Delay of Repair list and have a plan in place to fix these components.
- Use electronic monitoring and storage of LDAR data.
- Include procedures to ensure the QA/QC review of all data generated by LDAR monitoring technicians is completed on a daily basis or at the conclusion of each monitoring occurrence.
- Calibrate LDAR monitoring equipment consistently using an appropriate calibration gas that is in accordance with 40 CFR Part 60, EPA Reference Test Method 21.
- Follow all recordkeeping and reporting requirements and have organized records readily available to demonstrate that the LDAR program is a component of the organization’s routine operation and management.