Developing and Complying with LDAR Programs Robert vandenMeiracker

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Developing and Complyingwith LDAR
ProgramsRobert vandenMeiracker
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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

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What is LDAR?

• Regulatory Basis
• New Source Performance Standards (NSPS)
• VOCs
• National Emission Standards for Hazardous Air
  Pollutants (NESHAP)
• Organic HAPs
• Resource Conservation and Recovery Act (RCRA)
• Hazardous Waste
• State Rules

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LDAR Applicability

• Industry Subject to LDAR
• Chemicals, Polymers, Resins
• Pharmaceutical
• Pesticide
• Pulp and Paper
• Hazardous Waste Storage
• Equipment in VOC / HAP / Haz. Waste Service
• pump compressor
• valve connector
• agitator pressure relief device
• instrumentation system sampling connection system

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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

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5 Easy Steps to a Successful Program

• Identify Equipment
• Monitor Equipment
• Fix Equipment (if it is leaking)
• Keep Records Documenting Everything
• Repeat

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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

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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
• Average 10,042
• Source US EPA Enforcement Alert, October 1999

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Example Diagram
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Example Picture
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Identify Equipment

• Tags
• Metal, Plastic, Label, RF Devices, etc.
• Diagrams
• Pictures
• Tables
• Post-It Notes not Recommended

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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

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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

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Monitoring Equipment

• Specifications
• Response Factor lt 10 (sample conc. / reading)
• Response Time lt 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

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Monitoring Equipment Picture
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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 lt 10 of Calibration
  Gas
• Daily Calibration (when in use)

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What is a Leak?

• Sensory Observation
• Instrument Reading
• Varies by Rule and Equipment
• MON Agitators gt 10,000 ppmv
• Amino/Phenolic Resin Connectors gt 500 ppmv
• Pharmaceutical Pumps gt 2,000 pppmv
• Pulp and Paper Closed Vent Components gt 500 ppmv

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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
• 1st Attempt / Successful Repair / Document
  Repaired
• Equipment not Repaired within 5/15 day timeframe
• Develop a Quality Improvement Program (QIP)

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Recordkeeping

• Records
• Equipment List (including exemptions)
• Depends on Facility
• Potentially 1,000s of points to monitor and keep
  records
• Small
• Tables, Forms, etc.
• Medium to Large
• Integrate LDAR Monitor with off-the-shelf
  Computer Software

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Exemptions

• Difficult / Unsafe to Monitor
• Develop Schedule
• Vacuum Service
• Usually Based on level of vacuum (i.e., lt-5 kPa)
• Equipment in Service lt 300 hr/hr generally exempt
• Equipment Designed not to Leak
• Welded Connections

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Difficult / Unsafe to Monitor
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Who?

• Identification
• Collaboration
• Environmental / Production/ Engineering /
  Maintenance
• Monitoring
• Environmental / Production / Maintenance
• Contract Service
• Recordkeeping Reporting
• Environmental

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Monitoring Equipment

• Usually must be Purchased (8,000)
• Calibration / Precision Testing Gases
• Watch Expiration Dates
• Batteries
• FIDs Use Hydrogen
• Periodic Maintenance
• Can be Rented
• Other Uses

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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

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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

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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.

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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)

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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

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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

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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

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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

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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

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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.
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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

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Alternatives

• "Smart" LDAR
• Audible Visual - Olfactory
• Mandated
• As an Alternative

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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.