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LDAR

How To Set Up Your LDAR Program: A 5-Step Plan

By | LDAR

What is an LDAR Program?

LDAR (Leak Detection & Repair)

Leak Detection and Repair (LDAR) Programs are put in place to monitor process equipment leaks for fugitive emissions in the petrochemical industry.

Leak Detection and Repair (LDAR) Programs are put in place to monitor process equipment leaks for fugitive emissions in the petrochemical industry. Solid LDAR programs are critical in controlling fugitive emissions of VOCs, or volatile organic compounds, that cause pollution and safety risks for facility workers and operators, and the environment.

Maintaining refinery process equipment through an LDAR program mitigates these risks. Utilizing leak detection equipment to identify equipment leaks and then repairing those leaks in a timely manner enables operators to prevent most most fugitive emissions occurrences. In addition, successful leak detection and repair programs prevent product loss that impacts facility efficiencies and economics, the health and safety of workers, and the environment.

Fugitive emissions are emissions of gases or vapors from pressurized equipment due to leaks and other unintended or irregular releases of gases, mostly from industrial activities. As well as the economic cost of lost commodities, fugitive emissions contribute to air pollution and climate change.[1]

Fugitive Emission Regulations: Building a Compliant LDAR Program

Regulators pay more attention to fugitive emissions now more than ever. Fugitive emissions initially received special attention as a result of the 1963 Clean Air Act and its Amendments. These rules, passed by Congress, gave greater authority to the Federal Government and the United States Environmental Protection Agency (USEPA) to enforce ambient air standards, and thereby reduced authority from state and local agencies to regulate ambient air quality.

Today there are many rules and regulations governing fugitive emissions monitoring or leak detection and repair programs. Since the Clean Air Act, federal, state, and municipal agency authority to pass laws regulating fugitive monitoring has grown. These laws can get confusing since more than one law often affects the same component subject to equipment leak regulations. With multiple laws and regulating authorities, it is often difficult to understand which rules apply and what they require. To understand fugitive monitoring laws, one must first be informed of the purpose and origin of the applicable laws. Then, it is important to focus on key rules that lay the groundwork for understanding additional standards. With that said, having a competent LDAR contractor, who is expert at understanding these laws and applying them to your situation, is essential in building a compliant and successful leak detection and repair program.

Build Your LDAR Program: 5 Simple Steps

Industrial Specialty Services, a BrandSafway company, has designed a simple, step-by-step plan to build LDAR programs that accurately represent your project requirements.

Step 1: Develop Your Standard Operating Procedures

The first step in developing a successful leak detection and repair program is a cooperative endeavor between you and your ISS LDAR expert to complete, approve and adopt your standard operating procedures (SOP). Critical elements of your LDAR compliant SOP include:

LDAR Tagging

Tagging is an important component of any LDAR program.

  • LDAR monitoring schedule
  • Component tagging
  • Equipment component regulatory applicability
  • Comprehensive reporting
  • Recordkeeping procedures
  • Personnel contact information
  • Personal protective equipment (PPE) requirements
  • QA/QC processes for compliance assurance

Designation of responsibility is another key element of your SOP. This encompasses the selection of responsible parties and the assignment of tasks to those parties. Early consultation with your maintenance and operations department responsible for these tasks helps to avoid miscommunication, gaps and misunderstandings. In addition, it ensures that the LDAR program will interface smoothly with these departments.

Additional topics reviewed and addressed in your SOP include turnaround preparation, unit entry procedures, work permitting, training requirements, leak identification and leak communication procedures.

Step 2: Laws Governing Your LDAR Program

In the second step, we will research and share comprehensive knowledge of the permits, regulation(s), consolidation agreements, consent decrees, permit(s), and/or binding agreements governing your facility’s LDAR program.

Step 3: Your LDAR Unit Equipment Information Packet

In step three, we set up a database of regulations for each unit in your facility. The ISS LDAR team funnels, filters, and identifies congestion overlap and applicable LDAR regulations of varying stringency into a condensed table called a Unit Equipment Information Packet. Your ISS Unit Equipment Information Packet provides a confident answer to every auditor’s inevitable question: “How does your LDAR program for this facility affect this particular unit?” By listing applicable regulation names, monitoring frequencies, and leak definitions, delineating equipment categories, and drawing attention to regulatory-driven triggers, the Unit Equipment Information Packet is a comprehensive knowledge base for all who need to know more about the LDAR program on a unit-by-unit basis at the subject facility.

Step 4: Facility Process Flow Diagrams

In the fourth step, ISS obtains your facility’s process flow diagrams (PFD’s), piping and instrument diagrams (P&ID’s), the P&ID abbreviations key, material balance sheets, and stream speciation data from the appropriate contact identified in your SOP in Step 1. Utilizing smart software, we then highlight or color-code the P&ID’s according to stream state and service. If material balance sheets and stream composition/stream speciation data are not available or found to be outdated, ISS must instead rely heavily on the expertise of your engineers or ISS provided engineers. Then the field review begins.

Step 5: Component Inventory Database and Monitoring

In the fifth step, detailed data is collected on a daily basis for affected components. We review all affected components for accuracy and compliance, and perform necessary correction. All corrections are updated in the database. Monitoring commences as scheduled according to the applicable regulation set up in your LDAR Unit Equipment Information Packet in Step 2. Finally, we initiate a monthly QA/QC process to ensure ongoing compliance.

Leak Detection and Repair Program Checklist 

Below is a convenient checklist that will help you build in the critical elements of a superior LDAR program.

  • Provide LDAR training for personnel
  • Physically tag each component of regulated equipment
  • P&ID’s (piping and instrumentation diagram) with Tag numbers on components
  • Implement an aggressive MOC (management of change) program
  • Perform a field audit to verify P&ID accuracy
  • Utilize a lower than regulation leak definition throughout the facility
  • Collect data electronically with GPS tracking
  • Utilize a minimum inspection time from highest deflection point
  • Store electronic calibration data
  • Perform monthly QA/QC certifications and calibration, and monitor data monthly to ensure all items are closed out
  • Audit field monitoring personnel quarterly
  • Monitor more frequently than regulations require
  • Attempt repairs when a leak is first discovered
  • Guide Maintenance to complete repairs in the allowed times
  • Complete DOR’s (delay of repairs) with all parties prior to deadlines
  • Evaluate DOR items monthly
  • Review all TOS (temporarily out of service) components prior to their deadline to ensure they are still void of product
  • Re-monitor repaired leaks several times to insure repair is a long term fix
  • Utilize the best available technology and leak-less equipment where feasible.
  • Reconcile all monitoring data and field counts on their frequency and during reporting
  • Keep all records for proof of compliance
  • Audit the full LDAR program annually

Conclusion

Many regulations and a lot of detailed data are involved in designing a best-in-class LDAR program to ensure regulatory compliance when it comes to fugitive emissions. It is critical to review all data reports with your facility’s operations and environmental department for understanding and acknowledgement of completion and ongoing compliance.


Why Industrial Specialty Services for LDAR Solutions?

ISS offers 150 years of management experience, cutting-edge technology and a highly effective data management system to ensure successful LDAR programs and more, while ensuring regulatory compliance with USEPA Method 21 and other mandated requirements for VOC monitoring.

Learn about our comprehensive LDAR Solutions

Please CONTACT US if you have any questions about leak detection and repair, or if you’d like a quote for LDAR services.

[1] Source: Wikipedia