leak detection and repair (ldar)pubs.awma.org/flip/em-nov-2014/darrat.pdf · upon completion of the...

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by Inaas Darrat

Inaas Darrat, P.E., is a principal consultant and director of Chemical Sector Services with Trinity Consultants Inc., Houston, TX. E-mail: [email protected].

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EPA Priority:

Leak Detection and Repair (LDAR)A brief overview of the established U.S. Leak Detection and Repair (LDAR) program.

VOCs

06_EM1114-FT1-Darrat.indd 6 10/20/14 12:24 PM

Copyright 2014 Air & Waste Management Association

november 2014 em 7awma.org

A LDAR program is a facility’s system of procedures to minimize fugitive volatile organic compound (VOC) and hazardous air pollutant (HAP) emissions from leaking components (e.g., valves, pumps, con-nectors, compressors, and agitators).2 It is a struc-tured program to detect and repair equipment that is identifi ed as leaking. A portable device is used to identify equipment that is emitting suffi cient amounts of material above a specifi ed threshold (e.g., 10,000 parts per million by volume [ppmv]) to warrant reduction of the emissions through repair techniques. Additionally, sight, sound, and/or smell inspections are performed for certain types of equipment. LDAR is applied to equipment types that can be repaired while in operation, resulting in immediate emissions reduction.

The U.S. Environmental Protection Agency (EPA) has identifi ed the reduction of fugitive VOC and HAP emissions as a key enforcement priority and has been conducting audits and pursuing enforce-ment actions of LDAR programs in the petroleum refi ning and chemical manufacturing since the late 1990s. Both large and small facilities have been reviewed under this coordinated EPA program. EPA is also conducting LDAR inspections at natural gas processing plants.

EPA’s Inspection ProgramInitially, EPA focused on petroleum refi neries for its LDAR-related enforcement activities. Since 2005, however, the agency has also concentrated enforce-ment efforts within the chemical industry (e.g., facili-ties subject to Hazardous Organic NESHAP [HON], Pharmaceutical MACT, Miscellaneous Organic NESHAP [MON], and NSPS VV/VVa). Further-more, EPA has conducted inspections for natural gas processing plants, including those potentially

EXAMPLE FINDINGS in Recent Notices of Violations 1. Having open-ended lines. Inspectors can easily identify

this issue by visual inspection during audit walkthroughs. Inspectors commonly fi nd open-ended lines at sampling connection systems.3

2. Not conducting monitoring of each regulated component every monitoring period, or not having suffi cient documentation that monitoring was conducted.

3. Not repairing leaks within the timeframes required (e.g., completing repair, including Method 21 monitoring within 15 days of discovery).

4. Not conducting follow-up monitoring after leak repair (i.e., monitoring conducted within three months of repair or monitoring for two consecutive months with no leaks discovered, depending on the rule).4

5. Not maintaining leaker tags. 6. Improperly applying “delay of repair”. 7. Classifying insulated valves as exempt from monitoring.5 8. Not maintaining required lists (e.g., diffi cult-to-monitor

[DTM], unsafe-to-monitor [UTM], instrumentation systems, and pressure relief valves equipped with rupture disks).

9. Not reporting delay of repair technical infeasibility information in periodic reports.

10. Not maintaining complete leak repair records.

Fabio Cardano/iStock/Thinkstock

Leak Detection and Repair (LDAR)

initiatives are required as part

of several standards estab-

lished under the U.S. Code of Federal

Regulations (CFR): New Source Per-

formance Standards (NSPS; 40 CFR

60); National Emissions Standards for

Hazardous Air Pollutants (NESHAP; 40

CFR 61); Maximum Achievable Control

Technology (MACT; 40 CFR 63); and

Hazardous Waste Handling (40 CFR

264/265).1 While the LDAR regula-

tions all have similar requirements,

unrecognized nuances and the overall

complexity within each regulation can

result in potential violations.



subject to NSPS rules. As shown in recent notices and/or findings of violations, the compliance issues discovered by EPA at chemical manufacturing facil-ities encompass all facets of the LDAR standards.

In a typical LDAR program, portable analyzers are utilized to periodically monitor each regulated component at a frequency varying from monthly to every eight years, depending on the applicable regulation and component being monitored. If the component is found to be leaking, it is tagged and must be repaired within a specified time.

Please note that these are leak detection programs; therefore, leaks are expected to be discovered. Finding a leak is not always a violation; however, failure to conduct appropriate monitoring, record-keeping, reporting, and repairs would be viola-tions. Therefore, a review of recordkeeping (e.g., repair timing records and leak rate calculations), reporting (delay of repair), and monitoring fre-quencies are key components to any EPA inspec-tion (see sidebar “Example Findings in Recent Notices of Violations” on previous page).

Example Finding: Not Conducting Method 21 ProperlyFor both petroleum refineries and chemical man-ufacturing facilities, EPA has cited inappropriate application of 40 CFR 60, Appendix A, Method 21 (Method 21). Method 21 requires a portable monitoring device for identifying components emitting VOC/HAP above the applicable leak definitions (e.g., 10,000 ppmv or 500 ppmv). One of the primary methods by which EPA assesses adherence to the Method 21 is “comparative monitoring.” Often when conducting comparative monitoring, EPA inspectors will observe the facility LDAR technician while conducting parallel moni-toring per Method 21, which includes observing the following:

• zero and leak definition calibration checks;• calibration precision testing;• instrument response time checks;• time spent monitoring per component; and• leak interface monitoring techniques for each

component.

According to

EPA, being one

centimeter away

from the interface

can cause the

technician to miss

a defined leak.

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Upon completion of the monitoring, EPA will compare its leak rates (e.g., percentage of leak-ing components to number of components mon-itored) with the facility technician’s leak rates. In a study covering 17 petroleum refineries, the leak rate based on EPA monitoring was approximately 5%, while the leak rate based on industry mon-itoring was approximately 1%.6 Discrepancies between the leak rates can be due to any one of the above-listed factors and increases the level of scrutiny for facility leak rates previously reported. For example, according to EPA, being one centi-meter away from the interface can cause the tech-nician to miss a defined leak.6

Consent Decree-Enhanced LDARAs a result of recent LDAR audits and associated enforcement actions, EPA has initiated enhanced LDAR programs as part of the most recent con-sent decrees.7,8 The enhanced LDAR programs for chemical facilities are more stringent than the enhanced LDAR required for the refining industry. Starting in 2000, petroleum refineries were required by consent decree to implement

enhanced LDAR programs. The petroleum refin-ery enhanced LDAR includes four main elements:

1. Leak definitions were lowered from NSPS VV levels (e.g., 10,000 ppmv) to HON levels (e.g., 500 ppmv);

2. Limited delay of repair usage until “drill and tap” is utilized;

3. Initial attempts at repair were required at con-centrations as low as 200 ppmv (not a “leak” but a lowered action level); and

4. Periodic internal/third-party audits were required, including comparative monitoring of valves.9

Recent chemical industry consent decrees have included enhanced LDAR programs incorporating many of the petroleum refinery enhanced LDAR requirements, while adding several new aspects:10

1. Lowering the leak definitions: pumps—lowered from HON (e.g., 1,000 ppmv) and Pharma MACT (e.g., 2,000 ppmv) levels to 500 ppmv; agitators—lowered from HON/Pharma MACT


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levels (e.g., 10,000 ppmv) to 2,000 ppmv or 500 ppmv; and all other components—lowered from 500 ppmv to 250 ppmv or sometimes even lower (i.e., lower than the petroleum refin-ery enhanced LDAR leak definitions).

2. Requiring certified “low-leak” technology and packing materials for repair of leaking or instal-lation of new valves and connectors.

3. Periodic monitoring of closure devices associ-ated with open-ended lines via Method 21 at a defined leak definition (e.g., 200 ppmv).

4. Requiring more stringent delay of repair pro-visions.

5. Comparative monitoring within third-party LDAR audits for valves, closure devices on open-ended lines, pumps, connectors, and agi-tators.

6. More frequent periodic monitoring of certain valves, connectors, pumps, and agitators and removing monitor frequency reduction allow-ances for good performance.

LDAR Penalty PolicyIn addition to enhanced LDAR, consent decrees have a penalty fee and stipulated penalties associ-ated with them. EPA has an LDAR penalty policy that is organized by the following categories:11

• Recordkeeping violations ($250—$37,500).• Reporting violations ($250—$37,500 for miss-

ing information and $250 per day for late reports with a cap as high as $37,500).

• Failure to identify equipment, including mis-identifying equipment ($250—$5,000 per component depending on the component type, with a cap of $2.5MM).

• Inspection and Method 21 monitoring viola-tions ($100—$2,000 per component for missed inspections, $250 per calibration non-compli-ance, and $2,500—$18,500 per monitoring requirement per process unit for failure to mon-itor correctly).

• Failure to tag leaking equipment for repair ($100—$2,000 per component).

• Failure to repair leaks on time or at all ($100—$3,000 per component per day with caps of $1,000—$375,000 per component).

• Equipment standard violations (e.g., OELs, com-pressor seals; $750—$2,000 per component, or higher for long-term violations).

• Pressure testing violations ($100—$2,000 per component).

A multiplier is applied to the fee listed in the policy if emissions are associated with HAPs, HAPs with risk to communities, and/or VOC non-attainment areas.

In addition to the above penalties for past non-com-pliance, stipulated penalties are outlined to address any future specific non-compliance, such as not developing a timely, written LDAR plan; not con-ducting Method 21 accordingly; and not conduct-ing third-party LDAR audits, as required.

SummaryEPA will continue to conduct LDAR audits and seek enhanced LDAR requirements for facilities undergoing enforcement action. Facilities subject to LDAR requirements that have not been affected thus far should consider the lessons learned from the refining and chemical sectors that have already been affected. em

Finding a leak is not

always a violation;

however, failure to

conduct appropriate

monitoring,

recordkeeping,

reporting, and

repairs would be

violations.


Notes and References1. It should be noted that 40 CFR 98 also requires leak detection for greenhouse gases (GHGs). 2. Other pollutants are regulated, such as GHGs under 40 CFR 98, but this article focusses primarily on LDAR for HAP and VOC emissions.3. Per 40 CFR 63.161, as well as other definition sections of LDAR regulations, Open-ended valve or line means any valve, except pressure relief

valves, having one side of the valve seat in contact with process fluid and one side open to atmosphere, either directly or through open piping.4. Connectors, depending on the regulation, may also be subject to follow-up monitoring. Please refer to your applicable LDAR regulations

for other examples.5. While there is an exemption from monitoring for insulated connectors for regulations where periodic monitoring is required, no such ex-

emption exists for insulated valves.6. See Leak Detection And Repair—A Best Practices Guide; EPA-305-D-07-001; Office of Enforcement and Compliance Assurance, U.S. Envi-

ronmental protection Agency, October 2007; http://www.epa.gov/compliance/resources/publications/assistance/ldarguide.pdf.7. Please note not all chemical facilities that received LDAR-related consent decrees have been required to initiate an enhanced LDAR programs.8. While current filed consent decree for natural gas processing plants are not on the same order as refining and chemical industries consent

decrees, it does not mean that future consent decrees for oil and gas industry would not be similar to chemical and refining industries consent decrees.

9. The frequency of third-party audits was dependent on each individual consent decree. It could be annual, biennial, every five years, etc.10. Please note that this is not a rigorous list and not all consent decrees will include all these elements.11. Appendix VI—Leak Detection and Repair Penalty Policy; Office of Enforcement and Compliance Assurance, U.S. Environmental protection

Agency, September 2012.

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