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United States
Environmental Protection Agency
Office of Compliance
Office of Enforcement and Compliance Assurance
1200 Pennsylvania Avenue, NW
(mail code)
Washington, DC 20460

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Disclaimer

The U.S. Environmental Protection Agency (EPA) has reviewed this document and approves it for publication. This
document does not constitute rulemaking by the EPA and may not be relied on to create a substantive or procedural right
or benefit enforceable at law or in equity, by any person. The EPA may take actions at variance with this document and its
internal procedures.

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Contents


1.0    Purpose	1
2.0    Why Regulate Equipment Leaks?	2
3.0    Sources, Causes And Control Of Equipment Leaks	3
       3.1    How are emissions from equipment leaks reduced?	3
       3.2    What regulations incorporate LDAR programs?	6
4.0    What Are the Benefits of an LDAR Program?	7
       4.1    Reducing Product Losses	8
       4.2    Increasing Safety for Facility Workers and Operators	8
       4.3    Decreasing Exposure for the Surrounding Community	8
       4.4    Potentially Reducing Emission Fees	8
       4.5    Avoiding Enforcement Actions	8
5.0    Elements of an LDAR Program	9
6.0    What Compliance  Problems Have Been Found With Current LDAR
       Programs?	15
7.0    Model LDAR Program	19
       7.1    Written LDAR Program	20
       7.2    Training	20
       7.3    LDAR Audits	21
       7.4    Contractor Accountability	22
       7.5    Internal  Leak Definition for Valves and Pumps	22
       7.6    More Frequent Monitoring	23
       7.7    Repairing Leaking Components	23
       7.8    Delay of Repair Compliance Assurance	24
       7.9    Electronic  Monitoring and Storage of  LDAR Data	24
       7.10  QA/QC of LDAR Data	25
       7.11  Calibration/Calibration Drift Assessment	25
       7.12  Records Maintenance	26
8.0    Sources of Additional Information	27

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Tables

Table 3.1     Sources of equipment leaks	4
Table 3.2     Equipment component counts at a typical refinery or chemical plant.. . . 5
Table 3.3     Uncontrolled VOC emissions at a typical facility	5
Table 4.1     Control effectiveness for an LDAR program at a chemical process unit
             and a refinery	7

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Leak Detection and Repair Compliance Assistance Guidance—A Best Practices Guide
Appendices
Appendix A   Federal Regulations That Require a Formal LDAR Program
             With Method 21	29
Appendix B   Federal Regulations That Require the Use of Method 21
             But Do Not Require a Formal LDAR Program	30
Appendix C   Method 21 General Procedure	31
Appendix D   Method 21—Determination of Volatile Organic Compound Leaks	32
Appendix E   Summary of NEIC Comparative Monitoring Results of
             Leaking Valves at 17 Refineries	39
Appendix F   Enforcement Alert	40

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     Leak Detection and Repair—A Best Practices Guide
1.0  Purpose
In general, EPA has found significant widespread
noncompliance with Leak Detection and Repair
(LDAR) regulations and more specifically, noncom-
pliance with Method 21 requirements. In 1999, EPA
estimated that, as a result of this noncompliance,
an additional 40,000 tons of VOCs are emitted an-
nually from valves at petroleum refineries alone.

This document is intended for use by regulated
entities as well as compliance inspectors to identify
some of the problems identified with LDAR pro-
grams focusing in on Method 21 requirements and
describe the practices that can be used to increase
the effectiveness of an LDAR program. Specifically,
this document explains:

   • The importance of regulating equipment
     leaks;
   • The major elements of an LDAR program;
   • Typical mistakes made when monitoring to
     detect leaks;
   • Problems that occur from improper manage-
     ment of an LDAR program; and
   • A set of best practices that can be used to
     implement effective an LDAR program.
Some of the elements of a model LDAR program,
as described in Section 7.0, are required by current
Federal regulations. Other model LDAR program
elements help ensure continuous compliance al-
though they may not be mandated from a regulato-
ry standpoint. Furthermore, State or local require-
ments may be more stringent than some elements
of the model LDAR program, such as with leak
definitions. Prior to developing a written LDAR
program plan, all applicable regulations should be
reviewed to determine and ensure compliance with
the most stringent requirements.

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2.0  Why  Regulate Equipment Leaks?
EPA has determined that leaking equipment, such
as valves, pumps, and connectors, are the largest
source of emissions of volatile organic compounds
(VOCs) and volatile hazardous air pollutants
(VHAPs) from petroleum refineries and chemical
manufacturing facilities. The Agency has estimated
that approximately 70,367 tons per year of VOCs
and 9,357 tons per year of HAPs have been emitted
from equipment leaks. Emissions from equipment
leaks exceed emissions from storage vessels, waste-
water, transfer operations, or process vents.

VOCs contribute to the formation of ground-level
ozone. Ozone is a major component of smog, and
causes or aggravates respiratory disease, particu-
larly in children, asthmatics, and healthy adults
who participate in  moderate exercise. Many
areas of the United States, particularly those areas
where refineries and chemical facilities are located,
do not meet the National Ambient Air Quality
Standard (NAAQS) for ozone. Ozone can be trans-
ported in the atmosphere and contribute to nonat-
tainment in downwind areas.

Some species of VOCs are also classified as VHAPs.
Some known or suspected effects of exposure to
VHAPs include cancer, reproductive effects, and
birth defects. The highest concentrations of VHAPs
tend to be closest to the emission source, where
the highest public exposure levels are also often
detected. Some common VHAPs emitted from re-
fineries and chemical plants include acetaldehyde,
benzene, formaldehyde, methylene chloride, naph-
thalene,  toluene, and xylene.

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3.0  Sources,  Causes And Control  Of Equipment  Leaks
A typical refinery or chemical plant can emit 600-
700 tons per year of VOCs from leaking equipment,
such as valves, connectors, pumps, sampling con-
nections, compressors, pressure-relief devices, and
open-ended lines.

Table 3.1 shows the primary sources of emissions
from components subject to equipment leak regu-
lations. In a typical facility, most of the emissions
are from valves and connectors because these are
the most prevalent components and can number in
the thousands (Table 3.2). The major cause of emis-
sions from valves and connectors is seal or gasket
failure due to normal wear or improper mainte-
nance.

Previous EPA studies have estimated that valves
and connectors account for more than 90% of emis-
sions from leaking equipment with valves being the
most significant source (Table 3.3). Newer informa-
tion suggests that open-ended lines and sampling
connections may account for as much as 5-10% of
total VOC emissions from equipment leaks.

3,1        are


Facilities can control emissions from equipment
leaks by implementing a leak detection and repair
(LDAR) program or by modifying/replacing leak-
ing equipment with "leakless" components. Most
equipment leak regulations allow a combination of
both control methods.

   •  Leaks from open-ended lines, compressors,
     and sampling connections are usually fixed
 by modifying the equipment or component.
 Emissions from pumps and valves can also be
 reduced through the use of "leakless" valves
 and "sealless" pumps. Common leakless
 valves include bellows valves and diaphragm
 valves, and common sealless pumps are dia-
 phragm pumps,  canned motor pumps, and
 magnetic drive pumps. Leaks from pumps
 can also be reduced by using dual seals with
 or without barrier fluid.

 Leakless valves and sealless pumps are ef-
 fective at minimizing or eliminating leaks,
 but their use may be limited by materials
 of construction considerations and process
 operating conditions. Installing leakless and
 sealless equipment components may be a
 wise choice for replacing individual, chronic
 leaking components.
    is a work practice designed to
identify leaking equipment so that
emissions can be reduced through repairs, A com-
ponent that is subject to LDAR requirements must be
monitored at specified, regular intervals to determine
whether or not it is leaking. Any leaking component
must then be repaired or replaced within a specified
time frame.

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                                                      Leak Detection and Repair—A Best Practices Guide
Table 3.1  - Sources of equipment leaks.
  Pumps are used to move fluids from one point to
  another. Two types of pumps extensively used in pe-
  troleum  refineries and chemical plants are centrifugal
  pumps and positive displacement, or reciprocating
  pumps.
Leaks from pumps typically occur at the seal.
  Valves are used to either restrict or allow the move-
  ment of fluids. Valves come in numerous varieties and
  with the exception of connectors, are the most com-
  mon piece of process equipment in industry.
Leaks from valves usually occur at the stem or gland
area of the valve body and are commonly caused by a
failure of the valve packing or 0-ring.
  Connectors are components such as flanges and
  fittings used to join piping and process equipment
  together. Gaskets and blinds are usually installed
  between flanges.
Leaks from connectors are commonly caused from
gasket failure and improperly torqued bolts on
flanges.
  Sampling connections are utilized to obtain samples
  from within a process.
Leaks from sampling connections usually occur at the
outlet of the sampling valve when the sampling line is
purged to obtain the sample.
  Compressors are designed to increase the pressure of
  a fluid and provide motive force. They can have rotary
  or reciprocating designs.
Leaks from compressors most often occur from the
seals.
  Pressure relief devices are safety devices designed
  to protect equipment from exceeding the maximum
  allowable working pressure. Pressure relief valves and
  rupture disks are examples of pressure relief devices.
Leaks from pressure relief valves can occur if the
valve is not seated properly, operating too close to the
set point, or if the seal is worn or damaged. Leaks
from rupture disks can occur around the disk gasket
if not properly installed.
  Open-ended lines are pipes or hoses open to the
  atmosphere or surrounding environment.
Leaks from open-ended lines occur at the point of the
line open to the atmosphere and are usually con-
trolled by using caps, plugs, and flanges. Leaks can
also be caused by the incorrect implementation of the
block and bleed procedure.

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Leak Detection and Repair—A Best Practices Guide
         Table 3.2 - Equipment component counts at a typical
         refinery or chemical plant.
              Component

                Pumps

                Va Ives

              Connectors

           Open-ended lines

          Sampling connections

          Pressure relief valves
   Range

  10 - 360

150-46,000

600 - 60,000

  1-1,600

  20 - 200

  5-360
Average

  100

 7,400

 12,000

  560

  80

  90
         Source: "Cost and Emission Reductions for Meeting Percent Leaker Require-
         ments for HON Sources."  Memorandum to Hazardous Organic NESHAP
         Residual Risk and Review of Technology Standard Rulemaking docket.  Docket
         ID EPA-HQ-OAR-2005-0475-0105.
         Table 3.3 - Uncontrolled VOC emissions at a typical facility.
              Component

                Pumps

                Valves

              Connectors

           Open-ended lines

          Sampling connections

          Pressure relief valves

                 Total
Average Uncontrolled
VOC Emissions (ton/yr)

        19

       408

       201

        9

        11

        5

       653
                  percent Qf
                            3

                           62

                           31

                            1

                            2

                            1
         Source: Emission factors are from Protocol for Equipment Leak Emission Esti-
         mates, EPA-453/R-95-017, Nov 1995, and equipment counts in Table 3.2.
                     More recent data
                     indicates that open-
                     ended lines and
                     sampling connections
                     each account for ap-
                     proximately 5-10% of
                     total VOC emissions.

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                                               Leak Detection and Repair—A Best Practices Guide
3.2


LDAR programs are required by many New Source
Performance Standards (NSPS), National Emission
Standards for Hazardous Air Pollutants (NESHAP),
State Implementation Plans (SIPs), the Resource
Conservation and Recovery Act (RCRA), and other
state or local requirements. There are 25 federal
standards that require facilities to implement
LDAR programs. Appendix A shows the 25 federal
standards that require the implementation of a for-
mal LDAR program using Method 21. Appendix B
lists 28 other federal regulations that require some
Method 21 monitoring, but do not require LDAR
programs to be in place.

   •  NSPS (40 CFR Part 60)  equipment leak
     standards are related to fugitive emissions of
     VOCs and apply to stationary sources that
     commence construction, modification, or
     reconstruction after the date that an NSPS is
     proposed in the Federal Register.
   •  NESHAP (40 CFR Parts 61, 63, and 65) equip-
     ment leak standards apply to both new and
     existing stationary sources of fugitive VHAPs.
   •  RCRA (40 CFR Parts 264 and 265) equipment
     leak standards apply to hazardous waste
     treatment, storage, and disposal facilities.
   •  Many state and local air agencies incorporate
     federal LDAR requirements by reference, but
     some have established more stringent LDAR
     requirements to meet local air quality needs.

A facility may have equipment that is subject to
multiple NSPS and NESHAP equipment leaks stan-
dards. For example, a number of manufacturing
processes listed in the Hazardous Organic NES-
HAP (HON) equipment leak standard (40 CFR 63,
Subpart H) may utilize equipment for which other
NESHAP or NSPS equipment leak standards could
apply (such as 40 CFR 60, Subpart W). In addi-
tion, one process line may be subject to one rule
and another process line subject to another rule.
Facilities must ensure that they are complying with
the proper equipment leak regulations if multiple
regulations apply.

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      Leak Detection and Repair—A Best Practices Guide
4.0  What  Are the  Benefits  of an  LDAR Program?
When the LDAR requirements were developed, EPA
estimated that petroleum refineries could reduce
emissions from equipment leaks by 63% by imple-
menting a facility LDAR program. Additionally,
EPA estimated that chemical facilities could reduce
VOC emissions by 56% by implementing such a
program.

Table 4.1 presents the control effectiveness of an
LDAR program for  different monitoring intervals
and leak definitions at chemical process units and
petroleum refineries.
                 Emissions reductions from implementing an LDAR
                 program potentially reduce product losses, increase
                 safety for workers and operators, decrease exposure
                 of the surrounding community, reduce emissions
                 fees, and help facilities avoid enforcement actions.
                            -                      at a
                   facility.
                   Applying the equipment modifications and LDAR
                   requirements of the HON to the sources of uncontrolled
                   emissions in the typical facility presented in Tables 3.2 and
                   3.3 would reduce the emissions per facility by approximately
                   582 tons per year of emissions, an 89% reduction.
   Table 4.1 - Control effectiveness for an LDAR program at a chemical process unit and a refinery.
        Equipment Type and Service


          Chemical Process Unit
          Valves-Gas Serviceb
       Valves - Light Liquid Service0
       Pumps - Light Liquid Service0
        Connectors - All Services
               Refinery
          Valves-Gas Serviceb
       Valves - Light Liquid Service0
       Pumps - Light Liquid Service0
        Connectors - All Services
Monthly Monitoring
   10,000 ppmv
  Leak Definition
      87
      84
      69
      88
      76
      68
Control Effectiveness (% Reduction)

      Quarterly Monitoring
   10,000 ppmv Leak Definition
            67
            61
            45
            70
            61
            45
   Source: Protocol for Equipment Leak Emission Estimates, EPA-453/R-95-017, Nov 1995.
  500 ppm
Leak Definition3
                                                        75
                                                        93
                                                                                              81
   a Control effectiveness attributable to the HON-negotiated equipment leak regulation (40 CFR 63,  Subpart H) is estimated based on equipment-specific leak
      definitions and performance levels.  However, pumps subject to the HON at existing process units have a 1,000 to 5,000 ppm leak definition, depending on the
      type of process.
   b Gas (vapor) service means the material in contact with the equipment component is in a gaseous state at the process operating conditions.
   c Light liquid service means the material in contact with the equipment component is in a liquid state in which the sum of the concentration of individual constitu-
      ents with a vapor pressure above 0.3 kilopascals (kPa) at 20°C is greater than or equal to 20% by weight.

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                                                  Leak Detection and Repair—A Best Practices Guide
41                   -. " .  ;>6S

In the petrochemical industry, saleable products
are lost whenever emissions escape from process
equipment. Lost product generally translates into
lost revenue.

4.2                    for                 and

Many of the compounds emitted from refineries
and chemical facilities may pose a hazard to ex-
posed workers and operators. Reducing emissions
from leaking equipment has the direct benefit of
reducing occupational exposure to hazardous com-
pounds.

4.3                        for the

In addition to workers and operators at a facil-
ity, the population of a surrounding community
can be affected by severe, long-term exposure to
toxic air pollutants as a result of leaking equip-
ment. Although most of the community exposure
may be episodic, chronic health effects can result
from long-term exposure to emissions from leaking
equipment that is either not identified as leaking or
not repaired.
4.4

To fund permitting programs, some states and local
air pollution districts charge annual fees that are
based on total facility emissions. A facility with an
effective program for reducing leaking equipment
can potentially decrease the amount of these an-
nual fees.
4.5

In setting Compliance and Enforcement National
Priorities for Air Toxics, EPA has identified LDAR
programs as a national focus.  Therefore, facilities
can expect an increased number and frequency of
compliance inspections and a closer review of com-
pliance reports submitted to permitting authorities
in an effort by the Agency to assess LDAR programs
and identify potential LDAR problems. A facil-
ity with an effective LDAR program decreases the
chances of being targeted for enforcement actions
and avoids the costs and penalties associated with
rule violations.
                 of
  ''  Source: Hazardous Air Polli '      -  - -
     Process Units in the Synthe,
     Manufacturing Industry-Baci\giuui iu n nui11idliu
     for Proposed Standards, Vol. IC-Model Emissioi
     Sources, Emission Standards Division, US EPA,
     Office of Air and Radiation, OAQPS, Research
     Triangle Park, NC. Nov 1992,

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     Leak Detection and Repair—A Best Practices Guide
5.0 Elements of an  LDAR Program
The requirements among the regulations vary,       For each element, this section outlines the typical
but all LDAR programs consist of five basic ele-      LDAR program requirements, common compliance
ments, which are discussed in detail in Sections 5.1   problems found through field inspections, and a
through 5.5.                                  set of best practices used by facilities with effective
                                            LDAR programs.




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                                                  Leak Detection and Repair—A Best Practices Guide
                   1
Identifying Components

           i •
    Leak Definition
Monitoring Components
 Repairing Components
          T
    Recordkeeping
Current Requirements
• Assign a unique identification (ID) number to each regulated com-
  ponent.
• Record each regulated component and its unique ID number in a
  log.
• Physically locate each regulated component in the facility, verify its
  location on the piping and instrumentation diagrams (P&IDs) or pro-
  cess flow diagrams, and update the log if necessary. Some states
  require a physical tag on each component subject to the LDAR
  requirements.
• Identify each regulated component on a site plot plan or on a con-
  tinuously updated equipment log.
• Promptly note in the equipment log when new  and replacement
  pieces of equipment are added and equipment is taken out of ser-
  vice.

Common Problems
• Not properly identifying all regulated equipment components.
• Not properly documenting exempt components (e.g., <300 hour
  exemption and <5 (or <10) weight  % HAP).

Best Practices
• Physically tag each regulated equipment component with a unique
  ID number.
• Write the component ID number on piping and instrumentation
  diagrams.
• Institute an electronic data management system for LDAR data and
  records, possibly including the use of bar coding equipment.
• Periodically perform a field audit to ensure lists and diagrams ac-
  curately represent equipment installed in the plant.
                                               10

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      Leak Detection and Repair—A Best Practices Guide
Identifying Components
Monitoring Components
 Repairing Components
          T
    Recordkeeping
Current Requirements
• Method 21 requires VOC emissions from regulated components to
  be measured in parts per million (ppm).  A leak is detected when-
  ever the measured concentration exceeds the threshold standard
  (i.e., leak definition) for the applicable regulation.
  - Leak definitions vary by regulation, component type, service (e.g.,
    light liquid, heavy liquid, gas/vapor), and monitoring interval.
  - Most NSPS have a  leak definition of 10,000 ppm. Many NESHAP
    use a 500-ppm or 1,000-ppm leak definition.
• Many equipment leak regulations also define a leak based on visual
  inspections and observations (such as fluids dripping, spraying,
  misting or clouding from  or around components), sound (such as
  hissing), and smell.
  Note: The LDAR requirements specify weekly visual inspections of
        pumps, agitators, and compressors for indications of liquids
        leaking from the seals.

Common Problems
• Using the wrong leak definition for a particular component due to
  confusion  at facilities where multiple LDAR regulations apply.

Best Practices
• Utilize a leak definition lower than what the regulation requires.
• Simplify the program by using the lowest leak definition when mul-
  tiple leak definitions exist.
• Make the lowest leak definition conservative to provide a margin of
  safety when monitoring components.
• Keep the lowest leak definition consistent among all similar com-
  ponent types. For example, all valves in a facility might have a leak
  definition of 500 ppm.
                                                    11

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                                                          Leak Detection and Repair—A Best Practices Guide
      Identifying Components
          Leak Definition
      Repairing Components
          Recordkeeping
      Monitoring Components
The monitoring inter-
val is the frequency at
which individual com-
ponent monitoring is conducted.
For example, valves are generally
required to be monitored once a
month using a leak detection in-
strument, but the monitoring inter-
val may be extended (e.g. to once
every quarter for each valve that
has not leaked for two successive
months for Part 60 Subpart W,
or on a process unit basis of once
every quarter for process units
that have less than a 2% leak rate
for Part 63 Subpart H).
Current Requirements
• For many NSPS and NESHAP regulations with leak detection provisions,
  the primary method for monitoring to detect leaking components is EPA
  Reference Method 21 (40 CFR Part 60, Appendix A).
• Method 21 is a procedure used to detect VOC leaks from process equip-
  ment using a portable detecting instrument.
• Appendix C of this guide explains the general procedure and Appendix D
  presents the complete Method 21 requirements.
• Monitoring intervals vary according to the applicable regulation, but are typ-
  ically weekly, monthly, quarterly, and yearly. For connectors, the monitoring
  interval can be every 2, 4, or 8 years. The monitoring interval depends on
  the component type and periodic leak rate for the component type.

Common Problems
  Not following Method 21 properly.
  Failing to monitor at the maximum leak location (once the highest read-
  ing is obtained by placing the probe on and around the interface, hold the
  probe at that location approximately two times the response rate of the
  instrument).
  Not monitoring long enough to identify a leak.
  Holding the detection probe too far away from the component interface.
  The reading must be taken at the interface.
  Not monitoring all potential leak interfaces.
  Using an incorrect or an expired calibration gas.
  Not monitoring all regulated components.
  Not completing monitoring if the first monitoring attempt is unsuccessful
  due to equipment being temporarily out of service.

Best Practices
• Although not required by Method 21, use  an automatic (electronic) data
  logger to save time, improve accuracy, and provide an audit record.
• Audit the LDAR program to help ensure that the correct equipment is being
  monitored, Method 21 procedures are being followed properly, and the
  required records are being kept.
• Monitor components more frequently than required by the regulations.
• Perform QA/QC of LDAR data to ensure accuracy, completeness, and to
  check for inconsistencies.
• Eliminate any obstructions (e.g.,  grease on the component interface) that
  would prevent monitoring at the interface.
• If a rule allows the use of alternatives to Method 21 monitoring, Method
  21 should still be used periodically to check the results of the alternative
  monitoring method.
                12

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      Leak Detection and Repair—A Best Practices Guide
Identifying Components
    Leak Definition
Monitoring Components
 Repairing Components
Current Requirements
• Repair leaking components as soon as practicable, but not later than a
  specified number of calendar days (usually 5 days for a first attempt at
  repair and 15 days for final attempt at repair) after the leak is detected.
• First attempts at repair include, but are not limited to, the following
  practices where practicable and appropriate:
  Tightening bonnet bolts
  Replacing bonnet bolts
  Tightening packing gland nuts
  Injecting lubricant into lubricated  packing
  If the repair of any component is technically infeasible without a process
  unit shutdown, the component may be placed on the Delay of Repair
  list, the ID number is recorded, and an explanation of why the compo-
  nent cannot be repaired immediately is provided. An estimated date for
  repairing the component must be included in the facility records.
  Note: The "drill and tap" method for repairing leaking valves is gener-
        ally considered technically  feasible without requiring a process
        unit shutdown and should  be tried if the first attempt at repair
        does not fix the leaking valve.  See section 6.7 for a discussion of
        "drill and tap".
• The component is considered to be repaired only after it has been
  monitored and shown not to be leaking above the applicable leak defini-
  tion.

Common Problems
• Not repairing leaking equipment within the required amount of time
  specified by the applicable regulation.
• Improperly placing components on the Delay of Repair list.
• Not having a justifiable reason for why it is technically infeasible to
  repair the component without a process  unit shutdown.
• Not exploring all available repair alternatives before exercising the Delay
  of Repair exemption (specifically as it pertains to valves and "drill and
  tap" repairs).

Best Practices
• Develop a plan and timetable for repairing components.
• Make a first attempt at repair as soon as possible after a leak is detect-
  ed.
• Monitor components daily and over several days to ensure a leak has
  been successfully repaired.
• Replace problem components with "leakless" or other technologies.
                                                    13

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                                                 Leak Detection and Repair—A Best Practices Guide
Identifying Components
    Leak Definit ion
Monitoring Components
 Repairing Components
Current Requirements

For each regulated process:
• Maintain a list of all ID numbers for all equipment subject to an
  equipment leak regulation.
• For valves designated as "unsafe to monitor," maintain a list of ID
  numbers and an explanation/review of conditions for the designa-
  tion.
• Maintain detailed schematics, equipment design specifications
  (including dates and descriptions of any changes), and piping and
  instrumentation diagrams.
• Maintain the results of performance testing and leak detection
  monitoring, including leak monitoring results per the leak frequency,
  monitoring leakless equipment, and non-periodic event monitoring.

For leaking equipment:
• Attach ID tags to the equipment.
• Maintain records of the equipment ID number, the instrument and
  operator ID numbers, and the date the leak was detected.
• Maintain a list of the dates of each repair attempt and an explanation
  of the attempted repair method.
• Note the dates of successful repairs.
• Include the results of monitoring tests to determine if the repair was
  successful.

Common Problems
• Not keeping detailed and accurate records required by the appli-
  cable regulation.
• Not updating records to designate new components that are subject
  to LDAR due to revised regulations or process modifications.

Best Practices
• Perform internal and third-party audits of LDAR records on a regular
  basis to ensure compliance.
• Electronically monitor and store LDAR data including regular QA/QC
  audits.
• Perform regular records maintenance.
• Continually search for and update regulatory requirements.
• Properly record and report first attempts at repair.
• Keep the proper  records for components on Delay of Repair lists.
                                               14

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     Leak Detection and Repair—A Best Practices Guide
6.0  What Compliance Problems  Have  Been  Found With Current
       LDAR Programs?
Many regulatory agencies determine the compli-
ance status of LDAR programs based on a review of
submitted paperwork. Some conduct walk-through
inspections to review LDAR records maintained
on site and perform a visual check of monitoring
practices. However, a records review will not show
if monitoring procedures are being followed. Simi-
larly, the typical walkthrough inspection will not
likely detect improper monitoring practices since
operators will tend to ensure that they are following
proper procedures when they are being watched.

EPA's National Enforcement Investigations Center
(NEIC) conducted a number of sampling investiga-
tions of LDAR programs at 17 petroleum refineries.
Appendix E summarizes the comparative monitor-
ing results, and Appendix F contains a copy of the
1999 Enforcement Alert that explains the monitor-
ing results. The investigations consisted of records
review and comparative leak monitoring (compar-
ing the leak rate found by NEIC to the facility's
historic leak rate) at a subset of the facility's total
components. These investigations have  shown
a pattern of significantly higher equipment leak
rates (5%) than what the refineries reported (1.3%).
While there have been improvements since 1999,
facility audits are still showing significantly elevat-
ed leak rates, especially in the chemical manufac-
turing industries.

The discrepancy in leak rates indicates that moni-
toring staff may not be complying with Method 21
procedures. Failure to accurately detect leaks may
be due to a lack of internal quality control oversight
or management accountability for the LDAR pro-
grams regardless of whether the monitoring is done
by contractors or in-house personnel.

Each leak that is not detected and repaired is a lost
opportunity to reduce emissions. In the October
1999 Enforcement Alert, EPA estimates that an ad-
ditional 40,000 tons of VOCs are emitted annually
from petroleum refineries because leaking valves
are not found and repaired.

Several important factors contribute to failing to
identify and repair leaking components:

  1. Not identifying all regulated compo-
     nents/units in inventory

     If a facility does not properly identify all of its
     regulated components, some leaks may go
     unidentified. Unidentified components may
     leak or have existing leaks that will worsen
     over time if the components are not properly
     identified, monitored and repaired. Facili-
     ties can fail to identify regulated components
     when new processes are constructed, exist-
     ing process are modified, or new or revised
     equipment leak regulations are published.

  2. Not monitoring components

     In some cases, the number of components re-
     ported to have been monitored may indicate
     problems with monitoring procedures. What
     facility inspectors have found:

     •  A data logger time stamp showed valves
        being monitored at the rate of one per
        second with two valves occasionally be-
                                             15

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                                          Leak Detection and Repair—-A Best Practices Guide
   ing monitored within the same 1-second
   period.
•   At one facility, a person reported monitor-
   ing 8,000 components in one day (assum-
   ing an 8-hour work day, that represents
   one component every 3.6 seconds).
•   Records evaluations showed widely vary-
   ing component monitoring counts, sug-
   gesting equipment might not always be
   monitored when required.
•   Equipment was marked "temporarily out
   of service" because the initial inspection
   attempt could not be performed. Howev-
   er, the equipment was in service for most
   of the period, and no subsequent (or prior)
   inspection attempts were performed to
   meet the monitoring requirement.

However, even when records show a realistic
number of components are being monitored,
if there are no oversight or accountability
checks, then there is no guarantee that com-
ponents are actually being monitored.
3. Insufficient time to identify a leak

   In other cases, facilities are not following
   proper monitoring procedures, resulting in a
   lower number of leaking components being
   reported.

   •  If a worker moves the probe around the
     component interface so rapidly that the
     instrument does not have time to properly
     respond, then a component may never be
     identified as leaking.
   •  If a worker fails to find the maximum leak
     location for the component and then does
     not spend twice the response time at that
     location, then the monitoring instrument
     will not measure the correct concentra-
     tion of hydrocarbons and the leak may
     go undetected. Optical leak imaging
     shows the importance of identify-
     ing the maximum leak location, as
     hydrocarbons are quickly dispersed
     and diluted by air currents around the
     component.

4. Holding the probe away from the compo-
   nent interface

   The probe must be placed at the proper
   interface of the component being analyzed.
   Placing the probe even 1 centimeter from the
   interface can result in a false reading, indicat-
   ing that the component is not leaking, when
   in fact it is leaking. Eliminate any issues (e.g.,
   grease on the component interface) that pre-
   vent monitoring at the interface (e.g., remove
   excess grease from the component before
   monitoring or use a monitor that won't be
   impacted by the grease and is easy to clean.
                                        16

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   For equipment with rotating shafts (pumps
   and compressors), Method 21 requires the
   probe be placed within 1 centimeter of the
   shaft-seal interface. Placing the probe at the
   surface of the rotating shaft is a safety hazard
   and should be avoided.

5. Failing to properly maintain monitoring
   instrument

   Factors that may prevent the instrument
   from identifying leaks are:

   •  Not using an instrument that meets the
     specifications required in Method 21, sec-
     tion 6.
   •  Dirty instrument probes;
   •  Leakage from the instrument probes;
   •  Not zeroing instrument meter;
   •  Incorrect calibration gases used; and
   •  Not calibrating the detection instrument
     on a daily basis.
6. Improperly identifying components as
   "unsafe" or "difficult" to monitor

   Components that are identified as being
   "unsafe to monitor" or "difficult to monitor"
   must be identified as such because there is a
   safety concern or an accessibility issue that
   prevents the component from being success-
   fully monitored.

   All unsafe or difficult-to-monitor compo-
   nents must be included on a log with identi-
   fication numbers and an explanation of why
   the component is "unsafe to monitor" or "dif-
   ficult to monitor." Monitoring can be deferred
   for all such components, but the facility must
   maintain a plan that explains the conditions
   under which the components become safe to
   monitor or no longer difficult to monitor.
                                           17

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                                               Leak Detection and (Repair—A Best Practices Guide
7. Improperly placing components/units
   on the "Delay of Repair" list

   Generally, placing a leaking component on
   the "Delay of Repair" list is permissible only
   when the component is technically infeasible
   to repair without a process unit shutdown
   (e.g., for valves the owner/operator must
   demonstrate that the emissions from imme-
   diate repair will be greater than waiting for
   unit shutdown).

   Repair methods may exist, such as "drill and
   tap" for valves, that allow leaks to be fixed
   while the component is still in service. Fail-
   ing to consider such repair methods before
   exercising the "Delay of Repair" list may con-
   stitute noncompliance with repair require-
   ments (usually 15 days under federal LDAR
   standards).

   Components placed on the "Delay of Repair"
   list must be accompanied by their ID num-
   bers and an explanation of why they have
   been placed on the list. These components
   cannot remain on the list indefinitely - they
   must be repaired by the end of the next pro-
   cess unit shutdown.
    and Tap is a repair method where
a hole is drilled into the valve pack-
ing          tapped, so that a small
valve and fitting can be attached to the gland,
A packing gun is connected to this fitting and
the small valve is opened allowing new packing
material to be pumped into the packing gland.
 Many companies consider this a permanent
repair technique, as newer, pumpable packing
types are frequently superior to the older  pack-
ing, types they rep ace. Packing types can be
changed and optimized for the specific applica-
tion over time.
                                             18

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     Leak Detection and Repair—A Best Practices Guide
7.0  Model LDAR  Program
Experience has shown that facilities with an effec-
tive record of preventing leaks integrate an aware-
ness of the benefits of leak detection and repair into
their operating and maintenance program. This
section outlines some of the major elements of suc-
cessful LDAR programs. These program  elements
were developed from:

   •  Evaluation of best practices identified at
     facilities with successful LDAR programs, and
   •  Analysis of the root  causes of noncompliance
      at facilities that were found to have recurring
      violations of LDAR regulatory requirements.

LDAR programs that incorporate most or all of the
elements described in the following sections have
achieved more consistent results in their LDAR
programs, leading to increased compliance and
lower emissions.
       Written LDAR Program
           (Section 7.1)
             Training
           (Section 7.2)
           LDAR Audits
           (Section 7.3)
     Contractor Accountability
           (Section 7.4)
      Internal Leak Definitions
           (Section 7.5)
      More Frequent Monitoring
           (Section 7.6)
                     First Attempt at Repair
                         (Section 7.7)
                     Delay of Repair Compli-
                        ance Assurance
                          (Section 7.8)
                     Electronic Monitoring
                      and Storage of Data
                          (Section 7.9)
                      QA/QC of LDAR Data
                         (Section 7.10)
                     Calibration/Calibration
                        Drift Assessment
                         (Section 7.11)
                     Records Maintenance
                         (Section 7.12)
                                               19

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               ..            -

A written LDAR program specifies the regulatory
requirements and facility-specific procedures for re-
cordkeeping certifications, monitoring, and repairs.
A written program also delineates the roles of each
person on the LDAR team as well as documents all
the required procedures to be completed and data
to be gathered, thus establishing accountability.
The plan should identify all process units subject
to federal, state, and local LDAR regulations and
be updated as necessary to ensure accuracy and
continuing compliance.
   An overall, facility-wide leak rate goal that will be a
   target on a process-unit-by-process-unit basis;
   A list of all equipment in  light liquid and/or in gas/
   vapor service that has the potential to leak VOCs
   and VHAPs, within process units that are owned
   and maintained by each  facility;
   Procedures for identifying leaking equipment
   within process units;
   Procedures for repairing  and keeping track of leak-
   ing equipment;
   A process for evaluating  new and replacement
   equipment to promote the consideration of install-
   ing equipment that will minimize leaks or eliminate
   chronic leakers;
   A list of "LDAR Personnel" and a description
   of their roles and responsibilities, including the
   person or position for each facility that has the
   authority to implement improvements to the LDAR
   program; and
   Procedures (e.g., a Management of Change pro-
   gram) to ensure that components added to each
   facility during maintenance and construction are
   evaluated to determine if they are subject to  LDAR
   requirements, and that affected components are
   integrated into the LDAR program.
Within thirty (30) days after developing the writ-
ten facility-wide LDAR program, submit a copy of
the Program to EPA and to the appropriate state
agency.

7.2

A training program will provide LDAR personnel
the technical understanding to make the written
LDAR program work.  It also will educate members
of the LDAR team on their individual responsibili-
ties. These training programs can vary according to
the level of involvement and degree of responsibility
of LDAR personnel.
 »  Provide and require initial training and annual
    I	DAR refresher training for all facility employees
    assigned 1	DAR compliance responsibilities, such
    as monitoring technicians, database users, QA/QC
    personnel, and the LDAR Coordinator;
 »  For other operations and maintenance personnel
    with responsibilities related to 1	DAR, provide and
    require an initial training program that includes
    instruction on aspects of LDAR that are relevant to
    their duties (e.g., operators and mechanics per-
    forming valve packing and unit supervisors that
    approve delay of repair work). Provide and require
    "refresher" training in LDAR for these personnel at
    least every three years.
 »  Collect training information and records of contrac-
    tors, if used.
                                                  20

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7.3

Whether LDAR monitoring is done in house or
contracted to third parties outside the company,
the potential exists for LDAR staff not to adhere
correctly to the LDAR program.  Internal and
third-party audits of a facility LDAR program are
a critical component of effective LDAR programs.
The audits check that the correct equipment is
being monitored, Method 21 procedures are being
followed, leaks are being fixed, and the required
records are being kept. In short, the audits ensure
that the LDAR program is being conducted cor-
rectly and problems are identified and corrected.
» Review records on a regular cycle to ensure that all
  required LDAR-related records, ogs, and databases
  are being maintained and are up to date,
» Ensure and document that the correct equipment is
  included in the LDAR program and that equipment
  identified as leaking is physically tagged with the
  equipment ID number.
» Observe the calibration and monitoring techniques
  used by LDAR technicians, in particular to ensure
  the entire interface is checked and the probe is held
  at the interface, not away from the interface,
» Retain a contractor to perform a third-party audit of
  the facility LDAR program at least once every four
  (45 years.
» Perform facility-led audits every four (4) years.
  	 Use personnel familiar with the LDAR program
    and its requirements from one or more of the
    company's other facilities or locations (if available),
  	 Perform the first round of facility-led LDAR audits
    no later than two (2) years after completion of the
    third-party audits outlined above, and every  four
    (4)  years thereafter,
  	 This rotation ensures that the facility is being
    audited once every two (2) years.
» If areas of noncompliance are discovered, initiate a
  plan to resolve and document those issues,
« Implement, as soon as practicable, steps necessary
  to correct causes of noncompliance, and prevent, to
  the extent practicable, a  recurrence of the cause  of
  the noncompliance,
« Retain the audit reports and maintain a written
  record of the corrective actions taken in response to
  any deficiencies identified.
                                                  21

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7,4

Contractors performing monitoring are frequently
compensated for the number of components they
monitor, which might provide an incentive to rush
through monitoring procedures and not adhere to
Method 21 requirements for response time, moni-
toring distance, etc. If this happens, some equip-
ment leaks may not be detected. To overcome this
potential problem, facilities should have in place
sufficient oversight procedures to increase the  ac-
countability of contractors.
7.5                           for       and
  » Write contracts that emphasize the quality of
    work instead of the quantity of work only.
  » Require contractors to submit documentation
    that their 1	DAR personnel have been trained on
    Method 21 and facility-specific LDAR proce-
    dures.
    Perform spot audits in the field to ensure that
    Method 21 procedures are being followed.
    This can include spot-checking monitored
    components with another hydrocarbon analyzer
    or following LDAR personnel as they perform
    monitoring.
The varying leak definitions that can apply to
different process units and components can be
confusing and lead to errors in properly identifying
leaks. To counter this potential problem, operate
your LDAR program using an internal leak defini-
tion for valves and pumps in light liquid or gas
vapor service. The internal leak definition would be
equivalent to or lower than the applicable defini-
tions in your permit and the applicable federal,
state, and local regulations.  Monitoring against a
uniform definition that is lower than the applicable
regulatory definition will reduce errors and provide
a margin of safety for identifying leaking compo-
nents. The internal leak definition would apply to
valves and pumps (and possibly connectors) in light
liquid or gas vapor service.
  »  Adopt a 500-ppm or lower internal leak definition
    for VOCs for all valves in light liquid and/or gas
    vapor service, excluding pressure relief devices.
  »  Adopt a 2,000-ppm or lower internal leak definition
    for pumps in light liquid and/or gas/vapor service.
  «  Record, track, repair, and monitor leaks in excess
    of the internal leak definition.  Repair and monitor
    leaks that are greater than the internal  leak defini-
    tions but less than the applicable regulatory leak
    definitions within thirty (30) days of detection.
                                                     Consent Decrees between EPA and many chemical
                                                     facilities subject to the HON require using a 250-ppm
                                                     leak definition for valves and connectors and a 500-
                                                     pprn leak definition for pumps.
                                                     Note: If a state or local agency has lower leak defini-
                                                           tions, then the internal leak definition should
                                                           be set to the lowest definition or even lower to
                                                           include/allow for margin of error.
                                                 22

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7=6

Many regulations allow for less frequent monitor-
ing (i.e. skip periods) when good performance (as
defined in the applicable regulation) is demon-
strated. Skip period is an alternative work practice
found in some equipment leak regulations and
usually applies only to valves and connectors. After
a specified number of leak detection periods (e.g.,
monthly) during which the percentage of leaking
components is below a certain value (e.g., 2% for
NSPS facilities), a facility can monitor less fre-
quently (e.g., quarterly) as long as the percentage
of leaking components remains low. The facility
must keep a record of the percentage of the compo-
nent type found leaking during each leak detection
period.

Experience has  shown that poor monitoring rather
than good performance has allowed facilities to
take advantage  of the less frequent monitoring
provisions. To ensure that leaks are still being
identified in a timely manner and that previously
unidentified leaks are not worsening over time,
implement a plan for more frequent monitoring for
components that contribute most to equipment
leak emissions.

To stop detected leaks while they are still small,
most rules require a first attempt at repair within 5
days of the leak detection and a final repair within
15 days. However, any component that cannot be
repaired within those time frames must be placed
on a "Delay of Repair" list to be repaired during the
next shutdown cycle.

First attempts at repair include, but are not limited
to, the following best practices where practicable
and appropriate:

   •   Tightening bonnet bolts;
   •   Replacing bonnet bolts;
   •   Tightening packing gland nuts; and
   •   Injecting lubricant into lubricated packing.
  «  Schedule the "first attempt at repair" of those
    components that the monitoring personnel are not
    authorized to repair consistent with the existing
    regulatory requirements,
  •  Monitor the component for which a "first attempt
    at repair" was performed no later than the next
    regular business day to ensure the leak has not
    worsened.
                                               23

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7,8         of

Any component that cannot be repaired during the
specified repair interval must be placed on a "Delay
of Repair" list to be repaired during the next shut-
down cycle.  Delay of repair compliance assurance
procedures ensure that the appropriate equipment
is justifiably  on the "Delay of Repair" list and that
facilities have a plan to fix these components.
  * 1	lave the unit supervisor approve in advance
    and certify ail components that are technically
    infeasible to repair without a process unit shut-
    down ,
  * Continue to monitor equipment that is placed on
    the "Delay of Repair™ list in the facility's regular
    I	DAR monitoring.  For leaks above the internal
    leak definition rate and below the regulatory
    rate, put the equipment on the "Delay of Repair"
    list within 30 days,
  » Implement the following repair policies and
    procedures within  15 days of implementing the
    written LDAR program:
    	  For valves, other than control valves or pres-
       sure relief valves, that are leaking at a rate of
       10,000 ppm or greater and cannot be feasibly
       repaired without a process unit shutdown,
       use "drill and tap" repair methods to fix the
       leaking valve, unless you can determine and
       document that there is a safety, mechanical,
       or major environmental concern  posed by
       repairing the leak in this manner.
    -  Perform up to two "drill and tap" repair at-
       tempts to repair a leaking valve, if necessary,
       within 30 days of identifying the leak.
7.9                          and         "     Ai
       Data

Electronic monitoring and storage of LDAR data
will help evaluate the performance of monitor-
ing personnel (via time/date stamps), improve
accuracy, provide an effective means for QA/QC,
and retrieve records in a timely manner for review
purposes.  Incorporate and maintain an electronic
database for storing and reporting LDAR data. Use
data loggers or other data collection devices during
all LDAR monitoring.
     Use best efforts to transfer, on a daily basis, elec-
     tronic data from electronic data logging devices to
     the database.
     For all monitoring events in which an electronic
     data collection device is used, include a time and
     date stamp, operator identification, and instrument
     identification.
     Paper logs can be used where necessary or more
     feasible (e.g., small rounds, re-monitoring fixed
     leaks, or when data loggers are not available
     or broken), and should record, at a minimum,
     the monitoring technician, date, and  monitoring
     equipment used.
     Transfer any manually recorded  monitoring data to
     the database within 7 days of monitoring.
     Review records to identify  "problem" components
     for preventative maintenance (repair  prior to an-
     ticipated failure) or for replacement with "leakless"
     technology.
                                                  24

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 '

QA/QC audits ensure that Method 21 procedures
are being followed and LDAR personnel are moni-
toring the correct components in the proper man-
ner.  Develop and implement a procedure to ensure
QA/QC review of all data generated by LDAR
monitoring technicians on a daily basis or at the
conclusion of each monitoring episode.
 /

Always calibrate LDAR monitoring equipment us-
ing an appropriate calibration gas, in accordance
with 40 CFR Part 60, EPA Reference Test Method
21.
  Some QA/QC procedures include:
  » Daily review/sign-off by monitoring technicians
    of the data they collected to ensure accuracy
    and validity.
  » Periodic review of the daily monitoring reports
    generated in conjunction with record keeping
    and reporting requirements.
  » Quarterly QA/QC of the facility's and contractor's
    monitoring data including:
    	  Number of components monitored per tech-
       nician;
    	  Time between monitoring events; and
    	  Abnormal data patterns.

    •  Conduct the calibration drift: assessment using, at
      a minimum, approximately 500 ppm of calibra-
      tion gas.
    »  If any calibration drift assessment after the initial
      calibration shows a negative drift of more than
      10% from the previous calibration, re-monitor all
      valves that were monitored since the last cali-
      bration with a reading of greater than 100 ppm.
      Re-monitor all pumps that were monitored since
      the last calibration with a reading of greater than
      500 ppm.
                                                 25

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Organized and readily available records are one
potential indication of an effective LDAR program.
Well-kept records may also indicate that the LDAR
program is integrated into the facility's routine
operation and management. The equipment leak
regulations specify recordkeeping and reporting
requirements; incorporating the elements below
will help ensure your facility LDAR records are
thorough and complete.
       Elements;
       Records to maintain:
       »  A certification that the facility implemented the
          "first attempt at repair" program.
       «  A certification that the facility implemented
          QA/QC procedures for review of data generated
          by LDAR technicians.
       «  An identification of the person/position at each
          facility responsible for 1	DAR program perfor-
          mance as defined in the written program.
       *  A certification that the facility developed and
          implemented a tracking program for new
          valves and pumps added during maintenance
          and  construction defined in the written pro-
          gram.
       *  A certification that the facility properly com-
          pleted calibration drift assessments,
       »  A certification that the facility implemented the
          "delay of repair" procedures,
       «  The  following information on I	DAR  monitoring:
          (1)  The number of valves and  pumps present
              in each process unit during the quarter;
          (2)  The number of valves and  pumps moni-
              tored  in each process unit;
          (3)  An explanation for missed  monitoring if
              the number of valves and pumps present
              exceeds the number of valves and pumps
              monitored during the quarter;
(4)  The number of valves and pumps found
    eaking;
(5)  The number of "difficult to monitor" pieces
    of equipment monitored;
(6)  A list of all equipment currently on the
    "Delay of Repair" list and the date each
    component was placed on the list;
(7)  The number of repair attempts not com-
    pleted promptly or completed within 5
    days;
(8)  The number of repairs not completed
    within 30 days and the number of compo-
    nents not placed on the "Delay of Repair"
    list; and
(9)  The number of chronic leakers that do not
    get repaired.
Records of audits and corrective actions.  Prior
to the first third-party audit at each facility,
include in your records a copy of each audit
report from audits conducted in the previous
calendar year and a summary of the actions
planned or taken to correct all deficiencies
identified in the audits.
For the audits performed in prior years, iden-
tification of the auditors and documentation
that a written plan exists identifying corrective
action for any deficiencies identified and that
this plan is being implemented.
                                                   26

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     Leak Detection and Repair—A Best Practices Guide
S.O  Sources  of  Additional  Information
     Inspection Manual: Federal Equipment Leak Regulations for the Chemical Manufacturing Industry,
     EPA/305/B-98/01 I.December 1998.
     http://cfpub.epa.gov/compliance/resources/publications/assistance/sectors/chemical/index.cfm

         Vol 1: Inspection Manual
         http://www.epa.gov/compliance/resources/publications/assistance/sectors/insmanvoll.pdf

         Vol 2: Chemical Manufacturing Industry Regulations (3 parts on the Internet)
         http://www.epa.gov/compliance/resources/publications/assistance/sectors/insmanvol2ptl.pdf
         http://www.epa.gov/compliance/resources/publications/assistance/sectors/insmanvol2pt2.pdf
         http://www.epa.gov/compliance/resources/publications/assistance/sectors/insmanvol2pt3.pdf

         Vol 3: Petroleum Refining Industry Regulations
         http://www.epa.gov/compliance/resources/publications/assistance/sectors/insmanvol3.pdf

     1995 Protocol for Equipment Leak Emission Estimates. EPA-453/R-95-017. Nov 1995.
     http://www.epa.gov/ttnchiel/efdocs/equiplks.pdf

     Enforcement Alert, EPA Office of Enforcement and Compliance Assurance,
     EPA300-N-99-014, Oct 1999.
     http://www.epa.gov/compliance/resources/newsletters/civil/enfalert/emissions.pdf

     National Petroleum Refinery Initiative, EPA.
     http://www.epa.gov/compliance/resources/cases/civil/caa/refineryinitiative032106.pdf

     Petroleum Refinery Initiative Fact Sheet, EPA.
     http://www.epa.gov/compliance/resources/cases/civil/caa/petroleumrefinery-fcsht.html

     Petroleum Refinery National Priority Case Results.
     http://www.epa.gov/compliance/resources/cases/civil/caa/oil/

     Draft Staff Report, Regulation 8, Rule 18, Equipment Leaks, Bay Area Air Quality Management District,
     Jul 1997.
     http://www.baaqmd.gov/pln/ruledev/8-18/1997/0818_sr_071097.pdf

     Standards of Performance for Equipment Leaks of VOC in the Synthetic Organic Chemicals Manu-
     facturing Industry; Standards of Performance for Equipment Leaks of VOC in Petroleum Refineries;
     Proposed Rule. [EPA-HQ-OAR-2006-0699; FRL- ] RIN 2060-AN71.
     http://www.epa.gov/ttn/oarpg/t3/fr_notices/equip_leak_prop!03106.pdf

     Industrial Organic Chemicals Compliance Incentive Program, EPA Compliance and Enforcement.
     http://www.epa.gov/compliance/incentives/programs/ioccip.html
                                                 27

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                                                    Leak Detection and Repair—A Best Practices Guide
Leak Detection and Repair Program Developments.
http://www.epa.gov/compliance/neic/field/leak.html

Compliance and Enforcement Annual Results: Important Environmental Problems / National Priorities.
http://www.epa.gov/compliance/resources/reports/endofyear/eoy2006/sp-airtoxics-natl-priorities.html

Portable Instruments User's Manual For Monitoring VOC Sources. EPA-340/1-86-015.
Inspection Techniques For Fugitive VOC Emission Sources, EPA 340/l-90-026a,d,e,f (rev May 1993) Course #380.

Environmental compliance assistance resources can be found at:

    http://cfpub.epa.gov/clearinghouse/
    http://www.assistancecenters.net/
    http://www.epa.gov/compliance/assistance/sectors/index.html
                                                  28

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    Leak Detection and Repair—A Best Practices Guide
Appendix A   Federal  Regulations That Require a Formal LDAR
                Program With Method 21
40CFR
Part Subpart
60
60
60
60
61
61
63
63
63
63
63
63
63
63
63
63
63
63
63
63
63
63
65
264
265
VV
ODD
GGG
KKK
J
V
H
1
J
R
CC
DD
SS
TT
UU
YY
GGG
III
MMM
FFFF
GGGGG
HHHHH
F
BB
BB
Regulation Title
SOCMI VOC Equipment Leaks NSPS
Volatile Organic Compound (VOC) Emissions from the Polymer Manufacturing
Industry
Petroleum Refinery VOC Equipment Leaks NSPS
Onshore Natural Gas Processing Plant VOC Equipment Leaks NSPS
National Emission Standard for Equipment Leaks (Fugitive Emission Sources) of
Benzene
Equipment Leaks NESHAP
Organic HAP Equipment Leak NESHAP (HON)
Organic HAP Equipment Leak NESHAP for Certain Processes
Polyvinyl Chloride and Copolymers Production NESHAP
Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout
Stations)
Hazardous Air Pollutants from Petroleum Refineries
Hazardous Air Pollutants from Off-Site Waste and Recovery Operations
Closed Vent Systems, Control Devices, Recovery Devices and Routing to a Fuel
Gas System or a Process
Equipment Leaks - Control Level 1
Equipment Leaks - Control Level 2
Hazardous Air Pollutants for Source Categories: Generic Maximum Achievable
Control Technology Standards
Pharmaceuticals Production
Hazardous Air Pollutants from Flexible Polyurethane Foam Production
Hazardous Air Pollutants for Pesticide Active Ingredient Production
Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing
Hazardous Air Pollutants: Site Remediation
Hazardous Air Pollutants: Miscellaneous Coating Manufacturing
Consolidated Federal Air Rule - Equipment Leaks
Equipment Leaks for Hazardous Waste TSDFs
Equipment Leaks for Interim Status Hazardous Waste TSDFs
     Note: Many of these regulations have identical requirements, but some have different applicability
     and control requirements.
                                     29

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                            Leak Detection and Repair—A Best Practices Guide
Appendix B  Federal Regulations That Require the Use
             of Method 21 But Do Not Require a Formal
             LDAR Program
40CFR
Part Subpart
60
60
60
61
61
61
61
63
63
63
63
63
63
63
63
63
63
63
63
63
63
65
264
264
265
265
270
270
XX
QQQ
WWW
F
L
BB
FF
G
M
S
Y
EE
GG
HH
00
PP
QQ
VV
HHH
JJJ
VVV
G
AA
CC
AA
CC
B
J
Regulation Title
Bulk Gasoline Terminals
VOC Emissions from Petroleum Refinery Wastewater Systems
Municipal Solid Waste Landfills
Vinyl Chloride
Benzene from Coke By-Products
Benzene Transfer
Benzene Waste Operations
Organic Hazardous Air Pollutants from SOCMI for Process Vents, Storage
Vessels, Transfer Operations, and Wastewater
Perchloroethylene Standards for Dry Cleaning
Hazardous Air Pollutants from the Pulp and Paper Industry
Marine Unloading Operations
Magnetic Tape Manufacturing Operations
Aerospace Manufacturing and Rework Facilities
Hazardous Air Pollutants from Oil and Gas Production Facilities
Tanks - Level 1
Containers
Surface Impoundments
Oil/Water, Organic/Water Separators
Hazardous Air Pollutants from Natural Gas Transmission and Storage
Hazardous Air Pollutant Emissions: Group IV Polymers and Resins
Hazardous Air Pollutants: Publicly Owned Treatment Works
CFAR - Closed Vent Systems
Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal
Facilities - Process Vents
Owners and Operators of Hazardous Waste Treatment, Storage and Disposal
Facilities - Tanks, Surface Impoundments, Containers
Interim Standards for Owners and Operators of Hazardous Waste Treatment,
Storage, and Disposal Facilities- Process Vents
Interim Standards for Owners and Operators of Hazardous Waste Treatment,
Storage, and Disposal Facilities - Tanks, Surface Impoundments, Containers
Hazardous Waste Permit Program - Permit Application
Hazardous Waste Permit Program - RCRA Standardized Permits for Storage
Tanks and Treatment Units
                           30

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     Leak Detection and Repair—A Best Practices Guide
Appendix C    Method 21 General Procedure
     Failure of facilities to follow Method 21 can
     lead to them not properly identifying and sub-
     sequently repairing leaking components. It is
     critical for facilities to refer to the complete
     text of Method 21 (see Appendix D) for de-
     tailed explanations of each general procedure
     found below and how to properly perform
     each step.

        1. Evaluate Instrument Performance

          Performance criteria for the monitoring
          instrument:

          •  For each VOC measured, the re-
             sponse factor should be <10 unless
             specified in the applicable regula-
             tion.  Response factor is the ratio of
             the known concentration of a VOC
             compound to the observed meter
             reading when measured using an
             instrument calibrated with the
             reference compound specified in the
             applicable regulation.
          •  The calibration precision should be
             <10 percent of the calibration gas
             value. Calibration precision is the
             degree of agreement between mea-
             surements of the same known value,
             expressed as the relative percentage
             of the average difference between
             the meter readings and the known
             concentration to the known concen-
             tration.
          •  The response time should be <30
             seconds. Response time is the
             time interval from a step change
     in VOC concentration at the input
     of the sampling system to the time
     at which 90% of the corresponding
     final value is reached as displayed on
     the instrument readout meter.

2.  Calibrate Instrument

   Before each monitoring episode:

   •  Let the instrument warm up.
   •  Introduce the calibration gas into
     the instrument probe.
   •  Adjust the instrument meter read-
     out to match the calibration gas con-
     centration value.

3.  Monitor Individual components

   When monitoring components:

   •  Place the probe at the surface of the
     component interface where leakage
     could occur.
   •  Move the probe along the interface
     periphery while observing the in-
     strument readout.
   •  Locate the maximum reading by
     moving the probe around the inter-
     face.
   •  Keep the probe at the location of the
     maximum reading for 2 times the
     response factor.
   •  If the concentration reading on the
     instrument readout is above the
     applicable leak definition, then the
     component is leaking and must be
     repaired.
                                             31

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                                              Leak Detection and Repair—A Best Practices Guide
Appendix D    Method 21—Determination of  Volatile Organic
                    Compound  Leaks
     i.o
     1.1 Analytes.
Analyte
Volatile Organic Compounds (VOC) 	
CAS No.
No CAS number assigned.
     1.2 Scope. This method is applicable for the
     determination of VOC leaks from process
     equipment. These sources include, but are not
     limited to, valves, flanges and other connec-
     tions, pumps and compressors, pressure relief
     devices, process drains, open-ended valves,
     pump and compressor seal system degas-
     sing vents, accumulator vessel vents, agitator
     seals, and access door seals.

     1.3 Data Quality Objectives. Adherence to the
     requirements of this method will enhance the
     quality of the data obtained from air pollutant
     sampling methods.

     2.0          of

     2.1 A portable instrument is used to detect
     VOC leaks from individual sources. The
     instrument detector type is not specified, but
     it must meet the specifications and perfor-
     mance criteria contained in Section 6.0. A
     leak definition concentration based on a
     reference compound is specified in each ap-
     plicable regulation. This method is intended
     to locate and classify leaks only, and is not to
     be used as a direct measure of mass emission
     rate from individual sources.
3.0

3.1 Calibration gas means the VOC com-
pound used to adjust the instrument meter
reading to a known value. The calibration gas
is usually the reference compound at a known
concentration approximately equal to the
leak definition concentration.

3.2 Calibration precision means the degree
of agreement between measurements of the
same known value, expressed as the relative
percentage of the average difference between
the meter readings and the known concentra-
tion to the known concentration.

3.3 Leak definition concentration means the
local VOC concentration at the surface of a
leak source that indicates that a VOC emis-
sion (leak) is present. The leak definition is an
instrument meter reading based on a refer-
ence compound.

3.4 No detectable emission means a lo-
cal VOC concentration at the surface of a
leak source, adjusted for local VOC ambient
concentration, that is less than 2.5 % of the
specified leak definition concentration. That
indicates  that a VOC emission (leak) is not
present.
                                            32

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     Leak Detection and Repair—A Best Practices Guide
3.5 Reference compound means the VOC species
selected as the instrument calibration basis for
specification of the leak definition concentration.
(For example, if a leak definition concentration is
10,000 ppm as methane, then any source emission
that results in a local concentration that yields a
meter reading of 10,000 on an instrument meter
calibrated with methane would be classified as a
leak. In this example, the leak definition concentra-
tion is 10,000 ppm and the reference compound is
methane.)

3.6 Response factor means the ratio of the known
concentration of a VOC compound to the observed
meter reading when measured using an instrument
calibrated with the reference compound specified
in the applicable regulation.

3.7 Response time means the time interval from a
step change in VOC concentration at the input of
the sampling system to the time at which 90 per-
cent of the corresponding final value is reached as
displayed on the instrument readout meter.

4,0

.) „'  "

5.1 Disclaimer. This method may involve hazard-
ous materials, operations, and equipment. This test
method may not address all of the safety problems
associated with its use. It is the responsibility of the
user of this test method to establish appropriate
safety and health practices and determine the ap-
plicability of regulatory limitations prior to per-
forming this test method.

5.2 Hazardous Pollutants. Several of the com-
pounds, leaks of which may be determined by this
method, may be irritating or corrosive to tissues
(e.g., heptane) or may be toxic (e.g., benzene, methyl
alcohol). Nearly all are fire hazards. Compounds in
emissions should be determined through familiar-
ity with the source. Appropriate precautions can
be found in reference documents, such as reference
No. 4 in Section 16.0.

6,0            and

A VOC monitoring instrument meeting the follow-
ing specifications is required:

6.1  The VOC instrument detector shall respond to
the compounds being processed. Detector types
that may meet this requirement include, but are
not limited to, catalytic oxidation, flame ionization,
infrared absorption, and photoionization.

6.2  The instrument shall be capable of measuring
the leak definition concentration specified in the
regulation.

6.3  The scale of the instrument meter shall be
readable to +2.5 % of the  specified leak definition
concentration.

6.4  The instrument shall be equipped with an
electrically driven pump to ensure that a sample
is provided to the detector at a constant flow rate.
The nominal sample flow rate, as measured at the
sample probe tip, shall be 0.10 to 3.01/min (0.004 to
0.1 ft 3 /min) when the probe is fitted with a glass
wool plug or filter that may be used to prevent
plugging of the instrument.

6.5  The instrument shall be equipped with a probe
or probe extension or sampling not to exceed 6.4
mm (1/4 in) in outside diameter, with a single end
opening for admission of sample.
                                              33

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                                                 Leak Detection and Repair—-A Best Practices Guide
6.6 The instrument shall be intrinsically safe for
operation in explosive atmospheres as defined by the
National Electrical Code by the National Fire Preven-
tion Association or other applicable regulatory code
for operation in any explosive atmospheres that may
be encountered in its use. The instrument shall, at a
minimum, be intrinsically safe for Class 1, Division
1 conditions, and/or Class 2, Division 1 conditions,
as appropriate, as defined by the example code. The
instrument shall not be operated with any safety
device, such as an exhaust flame arrestor, removed.

7.0           and

7.1 Two gas mixtures are required for instrument
calibration and performance evaluation:

7.1.1 Zero Gas. Air, less than 10 parts per million by
volume (ppmv) VOC.

7.1.2 Calibration Gas. For each organic species that
is to be measured during individual source surveys,
obtain or prepare a known standard in air at  a con-
centration approximately equal to the applicable
leak definition specified in the regulation.

7.2 Cylinder Gases. If cylinder calibration gas mix-
tures are used, they must be analyzed and certified
by the manufacturer to be within  2 % accuracy, and
a shelf life must be specified. Cylinder standards
must be either reanalyzed or replaced at the end of
the specified shelf life.

7.3 Prepared Gases. Calibration gases maybe
prepared by the user according to any accepted
gaseous preparation procedure that will yield a
mixture accurate to within 2 percent. Prepared
standards must be replaced each day of use unless
it is demonstrated that degradation does not occur
during storage.
7.4 Mixtures with non-Reference Compound Gases.
Calibrations may be performed using a compound
other than the reference compound. In this case,
a conversion factor must be determined for the al-
ternative compound such that the resulting meter
readings during source surveys can be converted to
reference compound results.

     *
      and

8.1 Instrument Performance Evaluation. Assemble
and start up the instrument according to the man-
ufacturer's instructions for recommended warmup
period and preliminary adjustments.

8.1.1 Response Factor. A response factor must be
determined for each compound that is to be mea-
sured, either by testing or from reference sources.
The response factor tests are required before plac-
ing the analyzer into service, but do not have to be
repeated at subsequent intervals.

8.1.1.1 Calibrate the instrument with the reference
compound as specified in the applicable regula-
tion. Introduce the calibration gas mixture to the
analyzer and record the observed meter reading. In-
troduce zero gas until a stable reading is obtained.
Make a total of three measurements by alternating
between the calibration gas and zero gas. Calculate
the response factor for each repetition and the aver-
age response factor.

8.1.1.2 The instrument response factors for each
of the individual VOC to be measured shall be less
than 10 unless otherwise specified in the applicable
regulation. When no instrument is available that
meets this specification when calibrated with the
reference VOC specified in the applicable regula-
                                               34

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     Leak Detection and Repair—A Best Practices Guide
tion, the available instrument may be calibrated
with one of the VOC to be measured, or any other
VOC, so long as the instrument then has a response
factor of less than 10 for each of the individual VOC
to be measured.

8.1.1.3 Alternatively, if response factors have been
published for the compounds of interest for the
instrument or detector type, the response factor
determination is not required, and existing results
maybe referenced. Examples of published response
factors for flame ionization and catalytic oxidation
detectors are included in References 1-3 of Section
17.0.

8.1.2 Calibration Precision. The calibration preci-
sion test must be completed prior to placing the
analyzer into service and at subsequent 3-month
intervals or at the next use, whichever is later.

8.1.2.1 Make a total of three measurements by
alternately using zero gas and the specified calibra-
tion gas. Record the meter readings. Calculate the
average algebraic difference between the meter
readings and the known value. Divide this aver-
age difference by the known calibration value and
multiply by 100 to express the resulting calibration
precision as a percentage.

8.1.2.2 The calibration precision shall be equal to or
less than 10 % of the calibration gas value.

8.1.3 Response Time. The response time test is re-
quired before placing the instrument into service. If a
modification to the sample pumping system or flow
configuration is made that would change the response
time, a new test is required before further use.

8.1.3.1 Introduce zero gas into the instrument
sample probe. When the meter reading has sta-
bilized, switch quickly to the specified calibration
gas. After switching, measure the time required to
attain 90 % of the final stable reading. Perform this
test sequence three times and record the results.
Calculate the average response time.

8.1.3.2 The instrument response time shall be equal
to or less than 30 seconds. The instrument pump,
dilution probe (if any), sample probe, and probe
filter that will be used during testing shall all be in
place during the response time determination.

8.2 Instrument Calibration. Calibrate the VOC
monitoring instrument according to Section 10.0.

8.3 Individual Source Surveys.

8.3.1 Type I—Leak Definition Based on Concen-
tration. Place the probe inlet at the surface of the
component interface where leakage could occur.
Move the probe along the interface periphery while
observing the instrument readout. If an increased
meter reading is observed, slowly sample the inter-
face where leakage is indicated until the maximum
meter reading is obtained. Leave the probe inlet at
this maximum reading location for approximately
two times the instrument response time. If the
maximum observed meter reading is greater than
the leak definition in the applicable regulation,
record and report the results as specified in the
regulation reporting requirements. Examples of
the application of this general technique to specific
equipment types are:

8.3.1.1 Valves. The most common source of leaks
from valves is the seal between the stem and hous-
ing. Place the probe at the interface where the stem
exits the packing gland and sample the stem cir-
cumference. Also, place the probe at the interface
of the packing gland take-up flange seat and sample
                                               35

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                                                 Leak Detection and Repair—A Best Practices Guide
the periphery. In addition, survey valve housings of
multipart assembly at the surface of all interfaces
where a leak could occur.

8.3.1.2 Flanges and Other Connections. For welded
flanges, place the probe at the outer edge of the
flange-gasket interface and sample the circumfer-
ence of the flange. Sample other types of nonper-
manent joints (such as threaded connections) with
a similar traverse.

8.3.1.3 Pumps and Compressors. Conduct a cir-
cumferential traverse at the outer surface of the
pump or compressor shaft and seal interface. If
the source is a rotating shaft, position the probe
inlet within 1 cm of the shaft-seal interface for the
survey. If the housing configuration prevents a
complete traverse of the shaft periphery, sample all
accessible portions. Sample all other joints on the
pump or compressor housing where leakage could
occur.

8.3.1.4 Pressure Relief Devices. The configuration
of most pressure relief devices prevents sampling
at the sealing seat interface. For those devices
equipped with an enclosed extension, or horn,
place the probe inlet at approximately the center of
the exhaust area to the atmosphere.

8.3.1.5 Process Drains. For open drains, place the
probe inlet at approxima tely the center of the area
open to the atmosphere. For covered drains, place
the probe at the surface of the cover interface and
conduct a peripheral  traverse.

8.3.1.6 Open-ended Lines or Valves. Place the probe
inlet at approximately the center of the opening to
the atmosphere.
8.3.1.7  Seal System Degassing Vents and Accumula-
tor Vents. Place the probe inlet at approximately
the center of the opening to the atmosphere.

8.3.1.8  Access door seals. Place the probe inlet at
the surface of the door seal interface and conduct a
peripheral traverse.

8.3.2 Type II—"No Detectable Emission". Deter-
mine the local ambient VOC concentration around
the source by moving the probe randomly upwind
and downwind at a distance of one to two meters
from the source. If an interference exists with this
determination due to a nearby emission or leak, the
local ambient concentration may be determined
at distances closer to the source, but in no case
shall the distance be less than 25 centimeters. Then
move the probe inlet to the surface of the source
and determine the concentration as outlined in
Section 8.3.1. The difference between these concen-
trations determines whether there are no detect-
able  emissions. Record and report the results as
specified by the regulation. For those cases where
the regulation requires a specific device installa-
tion, or that specified vents be ducted or piped to
a control device, the existence of these conditions
shall be visually confirmed. When the regulation
also  requires that no detectable emissions exist,
visual observations and sampling surveys are re-
quired. Examples of this technique are:

8.3.2.1  Pump or Compressor Seals. If applicable, de-
termine the type of shaft seal. Perform a survey of
the local area ambient VOC concentration and de-
termine if detectable emissions exist as described
in Section 8.3.2.

8.3.2.2  Seal System Degassing Vents, Accumulator
Vessel Vents, Pressure Relief Devices. If applicable,
                                              36

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     Leak Detection and Repair—A Best Practices Guide
observe whether or not the applicable ducting or
piping exists. Also, determine if any sources exist in
the ducting or piping where emissions could occur
upstream of the control device. If the required duct-
ing or piping exists and there are no sources where
the emissions could be vented to the atmosphere
upstream of the control device, then it is presumed
that no detectable emissions are present. If there
are sources in the ducting or piping where emis-
sions could be vented or sources where leaks could
occur, the sampling surveys described in Section
8.3.2 shall be used to determine if detectable emis-
sions exist.

8.3.3 Alternative Screening Procedure.

8.3.3.1 A screening procedure based on the forma-
tion of bubbles in a soap solution that is sprayed on
a potential leak source may be used for those sourc-
es that do not have continuously moving parts, that
do not have  surface temperatures greater than the
boiling point or less than the freezing point of the
soap solution, that do not have open areas to the
atmosphere that the soap solution cannot bridge,
or that do not exhibit evidence of liquid leakage.
Sources that have these conditions present must be
surveyed using the instrument technique of Section
8.3. lor 8.3.2.
8.3.3.2  Spray a soap solution over all potential leak
sources. The soap solution may be a commercially
available leak detection solution or may be pre-
pared using concentrated detergent and water. A
pressure sprayer or squeeze bottle may be used to
dispense the solution. Observe the potential leak
sites to determine if any bubbles are formed. If
no bubbles are observed, the source is presumed
to have no detectable emissions or leaks as appli-
cable. If any bubbles are observed, the instrument
techniques of Section 8.3.1 or 8.3.2 shall be used
to determine if a leak exists, or if the source has
detectable emissions, as applicable.
                                               37

-------
        ilitf
              Section
    Quality control measure
            Effect
  8.1.2.
  10.0.
Instrument calibration
precision check.
Instrument calibration.
Ensure precision and accuracy,
respectively, of instrument
response to standard.
 .'   •

10.1 Calibrate the VOC monitoring instrument as
follows. After the appropriate warmup period and
zero internal calibration procedure, introduce the
calibration gas into the instrument sample probe.
Adjust the instrument meter readout to correspond
to the calibration gas value.

Note: If the meter readout cannot be adjusted to
the proper value, a malfunction of the analyzer
is indicated and corrective actions are necessary
before use.

. .". J   -  '"

 , '; -.                and

13.0

    •'

   ".   "  " *
                   Factors of VOC Analyzers at a Meter Read-
                   ing of 10,000 ppmv for Selected Organic
                   Compounds. U.S. Environmental Protection
                   Agency, Research Triangle Park, NC. Publica-
                   tion No. EPA 600/2-81051. September 1981.
                 2. Brown, G.E., et al. Response Factors of VOC
                   Analyzers Calibrated with Methane for
                   Selected Organic Compounds. U.S. Environ-
                   mental Protection Agency, Research Triangle
                   Park, NC. Publication No. EPA 600/2-81-022.
                   May 1981.
                 3. DuBose, DA. et al. Response of Portable
                   VOC Analyzers to Chemical Mixtures. U.S.
                   Environmental Protection Agency, Research
                   Triangle Park, NC. Publication No. EPA
                   600/2-81-110. September 1981.
              4. Handbook of Hazardous Materials: Fire, Safety,
              Health. Alliance of American Insurers. Schaumberg,
              IT, 1983.

              " ••'  ''  '                             arid
                    •' .)ii
    •
   1.  Dubose, DA., and G.E. Harris. Response
                                               38

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     Leak Detection and Repair—A Best Practices Guide
Appendix E   Summary of NEIC Comparative  Monitoring  Re-
                  sults of  Leaking Valves at 17  Refineries

Valves Monitored
Number of Leaks
Leak Rate (%)
Emissions Rate (Ib/hr)
Potential Emissions
from Undetected Leaks (Ib/
hr)a
Refineries Total
170,717
2,266
1.3
1,177.0
NEIC Total
47,526
2,372
5.0 (avg)
2,775.5
1,598.5
     Source: Enforcement Alert - Proper Monitoring Essential to Reducing 'Fugitive Emissions' Under
     Leak Detection and Repair Programs, EPA 300-N-99-014. US EPA Office of Enforcement and
     Compliance Assurance. Vol. 2, No. 9, Oct 1999.

     a Potential Emissions from Undetected Leaks (Ib/hr) = NEIC Total Emissions Rate (Ib/hr)
       - Refineries Total Emissions Rate (Ib/hr)
                                         39

-------
Appendix F     Enforcement  Alert
                                          United States
                                          Environmental Protection
                                          Agency
   Office of Enforcement
   and Compliance
   Assurance (2201A)
                                                                                     EPA 306-N-S9-01J
                               Enforcement  Alert
            Volume 2, Numbers
                                           Office of Regulatory Enforcement
                                                                                         October 1999
                Proper Monitoring Essential to Reducing 'Fugitive
            Emissions'  Under Leak  Detection and Repair  Programs
            ' I "he Clean  Air Act requires
            J. «£meri*5 to develop and iBiple-
            uitiii a L*ik Deteesieii ind Rtpaii
            (LDAR) program EO control fugitive
            emissions. Fugitive emusiora occur
            from valves, pumps, compressors.
            pressure relief valves, flanges, con-
            nector? and ether pjpinp components,
              Comparison monitoring con-
                     About
                Enforcement Alert
                           Alert"   is
             Enfo»e«i»Bnt  to  mfcrro  ami
             community  of  important
             environmental  enforcement
             issues, recent frends and
             sigfuticanlenlof eerr>ent acbons

             This I illor mabu n should help thf
             r*gutil«tf eomittuftity anticif^l^
             and ptwveEit violaifiorts of fe" large. To
 ctoam a proper readiiis of enussion-i
 fiomieakiue 4ompoaents ibenioimoi-
 itt| equipmea: must be talitoared cta-

                   on page 2
                         This publication is found CHI tltc Intenict at http://Hww.efta.gov/oeca/arrfenfAleft
                                                      40

-------
Enforcement Alert
Coutiuued from
page 1

rectlv and held at the
component interface
where leakage couidoc- tmnffy
•™ur *'^ c IT t^1'3 f^V b^
nveen the valve vteni ^
and housing) for a suffi-
cient length of time to
obtain g valid measure- C
mem. p
E


Comparative Monitorinci Results



Emissions Potential
Company NBC Leak Rate: Rale: Emissions:
Monitoring: Monitoring: Company,' Company,' Undetected
Valves-leaks Valvei'ieaka MBCI%J NEICpbOii) Ltak» PJ*rl

7S^^170 3j^3^SS4 &3J1Q.5
7,S7SI2» 3,4871218 2.8/6 J
3,»13«2 2,««af«8 0.6/5,4
2.1SI2S 1 ,78404 1.21.4
5.SSSS6 2.10M12 OJ/SJ
LDAR Programs p ^^ ^ ^
Should Consist of
G
Several
Processes M
i
LDAR pioaraius are
generally compiued of **
four processes. Resula- K

14,3071226 3, 652:236 1.6/6.1

2§,?1M?38 3,3S«1'?9 3,6/SJ
S^3^ 2,?i«4 OJ/3.t
8,374/78 2.MV55 O.W1^
e,»W«1 1.SSW114 1.4^.9
tions vary but usually L f2(6S656 3,2281125 0.2/3,8
require refineries, to: ^
• Identify eorapc<. u
neiit^ to ke iiiciisd^d in
the program:
P
• Conduct routine
monitoring of identified ®
'n'C'H31T""'v*'£21'''~ '
4,160/40 1.W11.5
s,§44ss 2,4a?rtoa o.sw.3

7,181/112 2,^71130 1,6/4,5
4,060/181 2.4/4.S
6,640/36 2,608-74 0.5,'2.8
• Repair any leak. Total 170,71 47,§2«2,372 1.%&fl (
ine components; aiid
• Report monitor-
jng results
Compliance issues ss'ccisted with
each of these processes have resulted
in numerous enforcement actions by
EPA Regional offices. State agencies,
or local air boards, depending on tlie
spectfit leguiation^. Caninion viola-
tioiis incltide:
• Faihire to idecnfr process
tunts and compcnecrc that must be
monitored;
H Fsilius to follow p3cs-cnbiii
nisut'onag procedures.
• Use of incoirect o: expired
calibntion gashes:
nr-rnnFS ift»



• Failure to repair ccmpdnsn't
within specified [kceaasaes. and
• Failure to submit quanerly re-
pom and maintain appropnate cali-
branoD and'or moatonne record?

Refinery Monitoring
Reports; What EPA is
Finding
Dunns The past seveial veais.
NEIC has monitored for kakiug com-
fioMiiK a: lefineiies. Foi 1 ~ facilities
investigated by NEIC. the average
leak ra:e reported by the iacilities wai


38.8/106.6 67,8
44*73.5 29.S
183/90,* 71,8
1S.S/17.1 1,6
SO.?;i2S,8 7&A
1S4.7CT23 227.S

122^/3€9.7 24?,i

332,2469.7 137 A
16.S/76.8 S9.7
504/78,5 27,7
§6.1ffi
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                                         Enforcement Alert
Continued from pa** 2

5" percent of the leaking valves would
be mis sed when monitoring above the
500 ppm level.
   Fugitive emissions account for 22
percent of all emissions from con-re-
fiwne1; but account for more than 55
percent of all refinery emissions iden-
tified in the 1996 Toxic Release IB-
ventorv (TRI). Since TRI taclude-s
only  "reporwble" Isydio carbons, total
fugitive emissions were significantly
larger than the 33 million pounds thec
identified by reporting refineries.
   Tie failiue to identify leaks means
that thei' remain ucrep aired and will
continue to release VOCi and hazard-
ous substances into die  atmosphere.
Eoii vsion estimate? \i>«w a 50 -50 splu
between component; in f as light liq-
uid service (:ee Table, Page 2} sug-
s«t  that ties*  i~ lefiuenei' anmil
fugitive emissions c ould be more that
6.000 toss per year greater than pre-
viously believed Extrapolating dus drf-
fereiK* w all refinene; larger than the
smallest lefinerj' im-e;agated V,- KEJC
also  :ugge5ts that there may be  an
addiiional SO million pounds of VOCs
    •   EPA Policies for  .'
    Reducing, Eliminating '
     • -; Penalties for  /'-:
 ^ •  EPAhasadcpiednvopokcits
  designed to encourage the regu-
  lated comimmity to comply
    For mo»« info taiat ion, s« '
                           *
  axidtpoiitml.md die Small By-Ti- .
'  :nes» '
beuif tnurted each yea because re-
finery leaks are not being identified
properly and repaired promptly, a? re-
quired by LDAR programs. Signifi-
cautly md as recognised by mdustr)',
fiigiave emisdoas can be reduced by
up to 9Cf p«c«ui if leak 4 ir* d*!*ct«l
and repined m a timely maimer.

Regulatory Impacts of
Inadequate Fugitive
Monrtoring
   By not fully identifyaiE all leaiiae
CMQponeais. refiuenes ai* kkeJycaus-
iag tie luuiiecessar.' releat* of excess
hydrocarbons. The impacts of "iese
additions! hydrocarbon «3ea5es nisy
result itr
   •   Additional VOC
that  could  worsen   local   or
traKWiindry smoe problems:
   •   Under icpoitiug of fugitive
emissions on die annual Toxic Report-
ing Inventor}':
   •   Under repoiuaf  of vanous
TRI chemical? on annual Form R mb-
rci>sioti>: »nd
   •   Delayed or denied permiK for
espsnsioti
   Most LDAR regiilatioii? allow for
decreased rnoniionue ffequittcy if cer-
tain perfomiicce standards  aie coa-
siscemly achieved. Monirormg fre-
quency is decreased from qusnerly TO
annual monitoring ifle« than wo per-
cent of the valve?, within a process
wu; are foucd leakine. Cauveisely. if
eieatei thin :wo percent of "Jw valves
aie found to l>e leaking, moiutoruaa
must  be conducted quarterly. EPA
monitoring showing n greater ±an two
percent leal; rate has resulted in re-
fineries reverting back to quarterly
momtanne.
Improving Leak Detection
Monitoring Reliability
   Aliieusli 1101 requited tuider cur-
ren: LDAR prosiains. sevenl prac-
tices appear to improve die reliability
of monitoring dura snd LDAR com-
pliaiK*1
   •   Energetic LDAR coordina-
tors (advocates) with the responsibil-
irv «nd authority to msfce thing; bap-
pec:
   •   Contmuitig educauon.'ie-
fresiiei programs for plan; operators.
Plant operator; can have a major im-
pact on LDAR coniplianre;
   •   Diligent aid well-motivated
inomtceing personnel
   •   L'^e of a lower duo required
leak defimtiob. Sei'eiaireiineiies use
i leak deamtion bwer inan tie resu-
lator>' limit. For example, sex-erai re-
fineries u» a 500 ppm limit rather than
the regulatory litrsit of 10.000 ppm:
   •   More fiequeci uionitoiing
than required.. Fvathsi lian monitor-
ing annually, some refineries monitor
quarterly More frequent monitoring
aho way permit tower emission; to
be reported on the annual Toxic  Re-
polttne Inventory and or Form R.S; and
   •   Established Quality Assur-
ance.'Qnaliti'Con^oSprocedtire?. Srv-
«ial refineriei have initiated a prosrasj
to check the monitoriiaE r*5iii:s 5iib-
initced by the u»ni:aruif team  (in-
house or coatractor).
   EPA't Office of EiiTOrcemeK and
Compliance A^uraccei? encourafied
by efforts currently underway by the
National Advisor. Couiniiitee oa En-
vironmental Policy  ana Technology
(NACEPT) peiroluem  refming
workgroup to find moie cost-effec-
nve ways to identify significant leaks

            Continnfcl on page  4
OCTOBER1S»

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   United States
   Environmental Protection Agency
   Office erf Repylstory Enforcement
   22J8A
   Washington. D.C. 70160

   Official Busan«s
   Penalty for Private Use $300
Continued from page 5


through tww technology that allows
for quick idenf ifkaaon of the most sif •
uiSeaui loss«. Mtauwhilt. however.
the ie§uls;ed industry is expected ta
comply fully with «xi>tme LDAR re-
quirements.
   Contact Kelt Gating,  XationaJ
Enfoi cemfitt Itnfitigationi Cen-
ter,      i3QS>236-66SS;Email:
ga>'ing.kett-'.aepa.gw; Tern  Ripp,
Office of Compliance, Mannfat-
tuiing, Enfrgv antl  Trampontniou
Division,  (2 0] 564- 7003; Etna it:
lipp.ttmiiafpamail.fpa.gov; or Jim
Jackson, Office t>f Regulatmv En-
fertemtnt, Ah EnfortttneM Divi-
sion,  (202)   S64-2&02;Etnail:
jatbf0H.jamtnaipaiiteil.tpe.gev.

ERA'S Y2K Enforcement
Policy
   EPA's "Y2K EMsicemflii Poliev is
toiaied ro emcowige the expedra
testing of computer associated hard-
ware and software that may be poten-
tially vulnerable to Y2K problems.
   Under this policy, which \ras pub-
lidied in the Federal Register co K&rcli
10. 1999. EPA iniaids to waive 100
percent of the mil penalties and rec-
ommend agamK crmunal prownition
for ewirMuueiua) violation'; reiiiltsug
from Y2K testing dengned fa identify
To recei\-e tiw policy's benefits (e.g.,
watver of pemlties Air :o teamg^l, regu-
lated en£im« must aeldrest specific cri-
teria 
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vvEPA
     United States
     Environmental Protection
     Agency
     Office of Compliance
     Office of Enforcement and Compliance Assurance
     (mail code)

     EPA-305-D-07-001
     October 2007
     www.epa.gov/compliance

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