Implementation and Management of Leak Detection and Repair Programs – New Rules and Other Considerations

Nebraska Ethanol Safety & Environmental Coalition (NESEC) March 4, 2010

Agenda

 About Us  Why LDAR?

 Considerations for Implementation and Management of an LDAR Program  New Rules and Challenges  Questions

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

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

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

Elements of LDAR

Identification of Components Leak Definition Monitoring Repair Recordkeeping & Reporting

Model LDAR Program

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

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

Elements of an LDAR Program

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

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

Monitoring

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

Method 21

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

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)

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 >24 hours Revisions made to the inventory

Data Accuracy

 Daily QA/QC  Periodic  Monthly  Quarterly

Other Program Considerations

 DTMs  UTMs  OELs  Reporting  Training

Inventory & Inventory Control

Field Documentation

Date: Technician: Component ID Description To Be Added To Be Removed Change Notes Backgroud Reading Reading

Repair

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

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

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

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)

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

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.

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.

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

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)

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.

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

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”

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

VVa Applicability

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

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 >0.5 % within 12 months.

If %leaking is >0.25% but <0.5% within 4 years.

If %leaking is <0.25% there is a specified time table.

Stayed until August 1, 2008

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.

Questions?