Leak Detection and Repair
O A Best Practices Pamphlet
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INTRODUCTION
In general, EPA has found significant wide-
spread noncompliance with Leak Detection
and Repair (LDAR) regulations and more
specifically, noncompliance with Method 21
requirements. In 1999, EPA estimated that, as
a result of this noncompliance, an additional
40,000 tons of VOCs are emitted annually from
valves at petroleum refineries alone.
The EPA document "Leak Detection and RepairA Best Practices
Guide" (http://www.epa.gov/Compliance/resources/publications/assis-
tance/ldarguide.pdf) provides a detailed discussion of the sources and
causes of equipment leaks, elements and benefits of an LDAR program,
compliance problems with current LDAR programs, and the major ele-
ments of successful LDAR programs.
This brochure is focused on the major elements of successful LDAR
programs. Experience has shown that facilities with an effective record
of preventing leaks integrate an awareness of the benefits of leak detec-
tion and repair into their operating and maintenance program. 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.
Some of the elements of a model LDAR program, as described in this
brochure, are required by current Federal regulations. Other model LDAR
program elements help ensure continuous compliance although they may
not be mandated from a regulatory standpoint. Furthermore, State or local
requirements 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 deter-
mine and ensure compliance with the most stringent requirements.
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The model LDAR program includes the following elements:
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)
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I. Written LDAR Program
A written LDAR program specifies: the regulatory require-
ments and facility-specific procedures for recordkeeping
certifications, monitoring, and
repairs; the roles of each person on
the LDAR team; documents all the
required procedures to be completed
and data to be gathered; and all pro-
cess units subject to federal, state,
and local LDAR regulations.
Key elements of the written LDAR program include:
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 leaking equipment:
A process for evaluating new and replacement equipment to pro-
mote the consideration of installing 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.
Procedures (e.g., a Management of Change program) 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.
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Within thirty (30) days after developing the written facility-wide LDAR
program, submit a copy of the Program to EPA and to the appropriate
state agency. The plan should be updated as necessary to ensure ac-
curacy and continuing compliance.
2. Training
A training program provides LDAR personnel with: technical
understanding necessary to make the written LDAR pro-
gram work and education of the LDAR team members on
their individual responsibilities. These training pro-
grams can vary according to the level of involvement
and degree of responsibility of LDAR personnel.
The training program should:
Provide and require initial training and annual LDAR
refresher training for all facility employees (e.g.,
monitoring technicians, database users, QA/QC
personnel, the LDAR Coordinator) who are assigned
LDAR compliance responsibilities.
For other operations and maintenance personnel with responsibili-
ties related to LDAR, 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 performing valve pack-
ing 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 contractors, if used.
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3. LDAR Audits
Internal and third-party audits of a facility LDAR program are a
critical component of effective LDAR programs to ensure that the
LDAR program is being conducted correctly and problems are
identified and corrected. The audits verify that the correct equipment
is being monitored. Method 21 procedures are being followed, leaks
are being fixed, and the required records are being kept.
An audit program should include requirements to:
Review records on a regular cycle to ensure that all required LDAR-
related records, logs, 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 tech-
niques 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 (4) 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.
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» 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 practi-
cable, a recurrence of the cause of the noncompliance.
» Retain the audit reports and maintain a written record of the cor-
rective actions taken in response to any deficiencies identified.
4. Contractor Accountability
F
acilities should have in place sufficient oversight procedures
to increase the accountability of contractors performing
monitoring.
LDAR program managers should:
Write contracts that emphasize the quality of work instead of the
quantity of work only.
Require contractors to submit documentation that their LDAR per-
sonnel have been trained on Method 21 and facility-specific LDAR
procedures.
Ensure that the contractor has a procedure in place to review and
certify the monitoring data before submitting the data to the facility.
Review daily results of contractor work to ensure that a realistic
number of components are being monitored.
Perform spot audits in the field to ensure that Method 21 proce-
dures are being followed. This can include spot-checking monitored
components with another hydrocarbon analyzer or following LDAR
personnel as they perform monitoring.
Have periodic reviews of contractor performance (e.g., quarterly or
semi-annually) to resolve issues and correct problems.
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5. Internal Leak Definition for Valves
and Pumps
Ti
I he varying leak definitions that can ap-
ply to different process units and com-
ponents can be confusing and lead to
errors in properly identifying leaks. To counter
this potential problem, operate your LDAR
program using an internal leak definition for
valves and pumps in light liquid or gas vapor
service. The internal leak definition would
be equivalent to or lower than the applicable
definitions 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 components.
Elements:
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 definitions 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 connec-
tors and a 500-ppm leak definition for pumps.
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Note: If a state or local agency has lower leak definitions, then the inter-
nal leak definition should be set to the lowest definition or even lower to
include/allow for margin of error.
6. More Frequent Monitoring
Some equipment leak regulations allow an alternative work
practice (i.e., skip periods) where less frequent monitoring
is required when good performance (as defined in the appli-
cable regulation) is demonstrated. Skip periods usually apply only
to valves and connectors. For example, 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 frequently (e.g., quarterly) as
long as the percentage of leaking components remains low. The
facility must keep a record of the percentage of the component
type found leaking during each leak detection period.
To ensure that leaks are still being identified in a timely manner and that
previously unidentified leaks are not worsening over time, the LDAR pro-
gram should include a plan for more frequent monitoring for components
that contribute most to equipment leak emissions.
This plan should require monitoring of:
Pumps in light liquid and/or gas vapor service on a monthly basis.
Valves in light liquid and/or gas vapor serviceother than difficult-
to-monitor or unsafe-to-monitor valveswith no skip periods.
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7. Repairing Leaking Components
To stop detected leaks while they are still small, most rules
require a first attempt at repair within 5 days of the leak de-
tection and a final repair within 15 days. However, any com-
ponent 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.
Injecting lubricant into lubricated packing.
For those components that monitoring
personnel are not authorized to repair,
the schedule for the "first attempt at
repair" should be consistent with the
existing regulatory requirements.
The component for which a "first at-
tempt at repair" was performed should
be monitored no later than the next
regular business day to ensure the leak
has not worsened.
If the first attempt at repair has not succeeded then other methods,
such as "drill and tap" should be employed where feasible. Drill and tap
procedures are no longer considered extraordinary practices.
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8. Delay of Repair Compliance
Assurance
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 shutdown cycle. Delay of repair
compliance assurance procedures ensure that the appropriate
equipment is justifiably on the "Delay of Repair" list and that facili-
ties have a plan to fix these components.
The procedures should specify that:
The unit supervisor approve in advance and certify all components
that are technically infeasible to repair without a process unit shut-
down.
Equipment placed on the "Delay of Repair" list should continue
to be monitored as part of the facility's regular LDAR monitoring
program. 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.
Within 15 days of implementing the written LDAR program, the fol-
lowing repair policies and procedures should also be implemented:
» For valves, other than control valves or pressure 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 attempts to repair a
leaking valve, if necessary, within 30 days of identifying the
leak.
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9. Electronic Monitoring and Storage
of I DAR Data
lectronic monitoring and storage of LDAR data will:
o o
Help evaluate the performance of monitoring personnel (via time/
date stamps),
Improve accuracy,
Provide an effective means for QA/QC, and
Retrieve records in a timely manner for review purposes.
The data handling procedures of the LDAR program should include these
Elements:
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, electronic data from
electronic data logging devices to the database.
For all monitoring events in which an electronic data collection de-
vice 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 anticipated failure) or for replacement
with "leakless" technology.
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10. QA/QC of LDAR Data
QA/QC audits ensure that Method 21 procedures are being
followed and LDAR personnel are monitoring the correct
components in the proper manner. The LDAR program
should include procedures 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.
Examples of QA/QC procedures include:
Daily review/sign-off by monitoring technicians of the data they col-
lected to ensure accuracy and validity.
Periodic review of the daily monitoring reports generated in con-
junction with recordkeeping and reporting requirements.
Quarterly QA/QC of the facility's and contractor's monitoring data
including:
» Number of components monitored per technician;
» Time between monitoring events; and
» Abnormal data patterns.
I I. Calibration/Calibration Drift
Assessment
A
Iways calibrate LDAR monitoring equipment using an ap-
propriate calibration gas, in accordance with 40 CFR Part
60, EPA Reference Test Method 21.
At a minimum, the calibration drift assessments of LDAR monitor-
ing equipment should be conducted at the end of each monitoring
shift using approximately 500 ppm of calibration gas.
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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 calibration 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.
12. Records Maintenance
The equipment leak regulations specify recordkeeping and
reporting requirements. Organized and readily available
records are an indication of an effective LDAR program and
also indicate that the LDAR program is integrated into the facility's
routine operation and management.
Incorporating the elements below will help ensure your facility LDAR
records are thorough and complete.
Maintain certification records that the facility:
Implemented the "first attempt at repair" program.
Implemented QA/QC procedures for review of data generated by
LDAR technicians.
Maintains an identification of the person/position at each facility
responsible for LDAR program performance as defined in the writ-
ten program.
Developed and implemented a tracking program for new valves and
pumps added during maintenance and construction defined in the
written program.
Properly completed calibration drift assessments.
Implemented the "delay of repair" procedures.
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Record the following information on LDAR monitoring:
(1) The number of valves and pumps present in each process unit
during the quarter.
(2) The number of valves and pumps monitored 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 leaking.
(5) The number of "difficult to monitor" pieces of equipment moni-
tored.
(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 completed promptly or com-
pleted within 5 days.
(8) The number of repairs not completed within
30 days and the number of components not
placed on the "Delay of Repair" list.
(9) The number of chronic leakers that do not
get repaired.
The facility should also maintain 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 ac-
tions planned or taken to correct all deficiencies
identified in the audits.
For the audits performed in prior years, retain 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.
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