Leak detection and repair, otherwise known as LDAR, is an integral part of any oil, gas, or chemicals business. The guidelines, which were originally instituted by the EPA via the Clean Air Act, were meant to rein in potentially deadly and destructive volatile organic compounds (VOCs) and volatile hazardous air pollutants (VHAPs) that might be emitted into the air by faulty equipment, like valves, pumps, connectors, compressors, and agitators.
If your company is not on top of its LDAR, the consequences can be steep; fugitive emissions can cost millions of dollars in fines, and can even shut down operations either temporarily or permanently if the EPA auditor concludes that the LDAR program has not been followed.
Because effectiveness is the name of the game when it comes to LDAR programs, we’ve compiled a handy guide to help you ensure that your oil, gas, or chemicals business is adhering to EPA guidelines in ways that you can seamlessly integrate into your long-standing procedures. Here are 4 improvements you should make now:
- Ensure that Your LDAR Program is Comprehensive
- Make Your Leak Rates Goals Known
- Implement Cutting-Edge Training Programs
- Conduct Regular Internal Audits
Ensure that Your LDAR Program is Comprehensive
Just because you regularly pass EPA audits doesn’t mean that your LDAR program is as comprehensive as it should be to sustain itself into the future. Here are some components that should be part of every LDAR program:
- Identify all components – Double-check that each component in your process has both a unique location as well as a unique number attached to it for tracking purposes. Outfit the components, especially the ones that have been installed in the elements, with specialized LDAR tags that contain ID numbers, instrumentation diagrams, and more.
- Clarify your leak definition – Because there can be dozens of different leak guidelines depending on the intricacies of the facility, the EPA recommends keeping a detailed register that defines leaks at lower-than-minimum levels. This small change guarantees that your leak levels won’t crawl up into dangerous territories quickly.
- Monitor all necessary components – Use the tools that the EPA recommends to identify and monitor the necessary components. In this case, it would be EPA Reference Method 21, which calls for the use of a portable detecting instrument to evaluate emissions on a weekly, monthly, quarterly, or annual basis, depending on your business.
- Get to know the repair guidelines – If you detect a leak, don’t delay – the EPA has established regulatory guidelines that clearly state the timeline for leak repairs as they occur. Make sure that all parties are acquainted with the guidelines before a leak happens.
Make Your Leak Rate Goals Known
Now that you’ve taken the first steps to diversify your LDAR program, dedicate the time to formulate all of your leak rate goals as they vary throughout your facility. Once you have confirmed that the numbers fit all EPA guidelines, compile a transparent draft of your leak rate goals that can be easily accessed by all necessary members of every department. You can also choose to post these leak rate goals throughout the facility if appropriate.
The main objective here is for you to create a written program with the leak rate goals placed at the forefront. The concept of LDAR should not be one that is only taught to those who work on the leaks or deal with EPA audits, specifically; the program should be on a range of workers’ radars so that, as they move through the company, they are prepared to face the often harsh regulatory measures that encompass the Clean Air Act.
Implement Cutting-Edge Training Programs
Once a comprehensive and fully-transparent LDAR program has been written, it’s time for you to educate your employees through in-house training programs that are customized to fit the specific EPA guidelines that your business is currently facing.
This training must include all components that are listed in LDAR, as well as what to do in the event of a leak or during audit time. Update your training manual, procedures, and written LDAR program as changes in regulations and leak rate goals arise.
Conduct Regular Internal Audits
All companies that are made to implement LDAR programs will receive audits from state, federal, or third-party auditors. Because of this, it’s in your best interest to conduct regular internal audits that cover the exact same information that the EPA-approved ones will. Here is how you can best prepare:
- Identify and display all equipment that falls under the guidelines
- Show an understanding and procedure of how your business regards fugitive monitoring
- Provide all relevant data, including leak rates goals and figures from your preventative maintenance tracking system; all logs must be up-to-date
- Ensure that all necessary equipment is properly tagged with the equipment ID number
- Observe all LDAR technicians to guarantee that all are following proper protocol
- If any areas of noncompliance are identified, develop a plan and timeline for repairing the leak
The EPA recommends that you perform a facility-lead audit every 4 years, with the first one being no later than 2 years after your facility’s first third-party audit. Having said that, do your due diligence and adjust this timetable as needed and as regulations shift.
Following these best practices, from following guidelines to clarifying leak definitions, monitoring your assets, and conducting regular audits, will ensure that your LDAR program is both comprehensive and effective for a positive impact on the bottom line.