LDAR Future What Will the Landscape Look Like

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LDAR FutureWhat Will the Landscape Look Like???

• LDAR Presentation
• AWMA Webcast April 2007
• Joe Wilwerding
• EPA National Enforcement Investigations Center
• DFC Bldg 25 Door E2 / Box 25227
• Denver, Colorado 80225
• 303-462-9274

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Joe Wilwerding

• Chemical Engineer
• EPAs National Enforcement Investigations Center
• Areas of Expertise Include
• Performing inspection-related work at large petro
  chemical facilities throughout the U.S
• Leak detection and repair

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Overview

• Whats driving EPA?
• Increasing LDAR emissions profiles
• Continued compliance concerns
• Cost considerations
• Whats the response going to be?
• New or tighter existing LDAR regulations/requireme
  nts
• Continued LDAR enforcement priority
• Development of allowable, alternative monitoring
  methods
• Increased permit requirements for emissions
  monitoring

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Whats driving EPA?Increasing LDAR emissions
profiles

• LDAR percentage of overall emissions increasing
• Measurement, control technologies on point source
  emissions
• Potential continued fugitive emissions
  underestimation
• DIAL study
• Monitoring (Method 21) quality

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Whats driving EPA?Continued Compliance Concerns

• Chemical manufacturing industries
• Late 90s-, refinery-like compliance trends
• CD implementation at refineries
• M21 implementation
• Missed components after initial audits
• Repairs, training, other

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Whats driving EPA?Cost Considerations

• Use of alternative monitoring technologies
• Monitoring
• Repairs

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Whats the response going to be?New/Tighter LDAR
Regulations/Requirements

• NSPS VV revisions
• Mostly just for new/modified sources going
  forward
• 500 ppm valves/2000 ppm pumps
• Plug monitoring
• Connector monitoring?
• Required recordkeeping
• Important guidance on repairs/DOR exemption
  technically feasible, on-line (drill-and-tap)
  repairs required

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Whats the response going to be?New/Tighter LDAR
Regulations/Requirements

• MON compliance
• Enhanced LDAR Programs with enhanced stipulated
  penalties
• SIPs/local regulations?
• HON revisions?
• LDAR guidance document

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Whats the response going to be?Continued LDAR
Enforcement Priority

• Civil
• Possibly through 2010
• Development of Regional EPA LDAR expertise
• Criminal
• New focus
• LDAR contractors, too
• Numerous ongoing cases

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Whats the response going to be?Development of
Allowable, Alternative Monitoring Methods

• SMART LDAR
• Videos
• Can be used wherever current regs require M21
• Have to be able to see a leak based on
  chemicals used at facility (requires speciation
  survey of all regulated comps.)
• Requires daily calibration (verification) to meet
  minimum detection threshold
• Must monitor within verification distance, at
  frequencies greater or equal to M21 (depending on
  comp. type)
• Must keep all monitoring records
• Leak defined as any visible emission
• Repair verification only by optical imaging

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Whats the response going to be?Development of
Allowable, Alternative Monitoring Methods

• SMART LDAR
• Issues
• Periodic M21 requirement
• Enforceability
• Other?

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Whats the response going to be?Increased Permit
Requirements for Emissions Monitoring?

• Fenceline monitors
• IR
• UV
• DIAL
• Ambient monitors
• Onsite
• Offsite

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Q A