Implementation and Management of Leak Detection and Repair Programs

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

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

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(No Transcript)
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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

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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

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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

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Elements of LDAR
Identification of Components
Leak Definition
Monitoring
Repair
Recordkeeping Reporting
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Model LDAR Program

• Written LDAR program
• Training
• Accountability
• Audits
• Electronic monitoring and storage of data
• QA/QC of LDAR data
• Records maintenance

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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

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Elements of an LDAR Program

• A detailed description of the facilitys LDAR
  organization
• Procedures for inventory modifications
• Procedures associated with specific aspects of
  the sites LDAR program
• Training expectations and requirements
• Overall leak rate goals to be obtained on a unit
  by unit basis

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Roles Responsibilities

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

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Monitoring

• Audible, Visual, Olfactory (AVO)
• Method 21
• Smart LDAR

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Method 21

• EPA method of detecting VOC leaks from equipment
  sources
• Instrument requirements
• Calibration requirements
• Monitoring techniques for individual equipment
  types
• Safety requirements

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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)

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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 gt24 hours
• Revisions made to the inventory

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Data Accuracy

• Daily QA/QC
• Periodic
• Monthly
• Quarterly

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Other Program Considerations

• DTMs
• UTMs
• OELs
• Reporting
• Training

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Inventory Inventory Control
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Repair

• First Attempt
• Repair Timing
• Delay of Repair
• Chronic Leakers

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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

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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

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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 (60.482-11a)

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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

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Other Key Definitions

• First Attempt at Repair
• 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 60.485 (b) to verify
  that emissions from the equipment are below the
  applicable leak definition.

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New Equipment Requirements

• Pumps 60-482-2 (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 60.482-7 (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.

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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

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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 60.482-2(d)(5)(i)
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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.

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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 60-482-11a

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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

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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

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VVa Applicability

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

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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 gt0.5 within 12 months.
• If leaking is gt0.25 but lt0.5 within 4 years.
• If leaking is lt0.25 there is a specified time
  table.

Stayed until August 1, 2008
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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.

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Questions?