Valves found to be leaking between 100 ppm and 250 ppm must be noted, listed and prioritized in order of magnitude of leakage and the number of times they were found to be leaking.
The list is used to determine how many valves must be replaced or repacked. This is done by taking 10% of the valves leaking between 100 ppm and 250 ppm, less the number of DOR valves, those previously fitted with low-leak packing and those scheduled for replacement or repair in the next scheduled shutdown:
VTBRR = 0.10 (VT - VDOR - VPRR - VPR)
where VTBRR is the number of valves leaking at a rate of 100–250 ppm to be replaced or repacked in the maintenance shutdown, VT is the total number of valves in the covered process unit at the time of the shutdown, VDOR is the number of DOR valves to be replaced or repacked in the shutdown, VPRR is the number of valves previously replaced or repacked with certified low-leak technology and VPR is the number of valves awaiting replacement or repacking prior to shutdown.
The more stringent alternative of Part G requires that 20% of valves leaking between 100 ppm and 250 ppm be replaced or repacked. Optionally, valves emitting HAPs can be eliminated from service — but their removal mustn't introduce other potential points of leakage. The number of such valves may be credited toward the calculated number of valves requiring replacement or repacking.
If a certified low-leak valve or packing isn't commercially available, the site must submit a report, identifying each affected valve, vendors contacted and written documentation from each such vendor that a certified remedy is unavailable.
Flanged, threaded, compression, cam-lock and quick-connect-type connectors also are subject to repair, replacement and improvement. Any connector found to be leaking at or above 250 ppm must be repaired with technology that in the plant's judgment will attain a level of leakage below 250 ppm. As with valves, a successful repair must be made within 30 days of detection. Connectors are subject to the same post-replacement/repair monitoring requirements as valves. Connectors eliminated or replaced by welded joints or pipe are considered to be repaired or improved.
The site must report all equipment replacements, improvements and eliminations, identifying the relevant equipment, describing the action taken for compliance with Part G equipment upgrades and scheduling of future replacements and upgrades.
Part H deals with change management. All equipment added to or removed from a plant must be recorded and evaluated with regard to applicable LDAR requirements; documents must be retained. In addition, all personnel and contractors responsible for monitoring, equipment maintenance and repairs, and other LDAR-related activities must be trained — per Part I, which stipulates the training must commence within six months of initiation of an ELP, and refreshers must be conducted annually.
Part J sets forth requirements for quality assurance and control. It calls for LDAR technicians to certify on a daily basis that monitoring data are accurate and have been properly collected. Records of the LDAR department must be internally audited on a quarterly basis by a non-technician but LDAR-trained employee. The audits must include a review of equipment that isn't now but should be covered by the ELP, records documenting monitoring frequency, all sign-offs, repair documents, monitoring data versus equipment count, calibration and monitoring equipment maintenance records, and field observation of equipment monitoring. In addition, yearly third-party audits are required.
Part M requires retention of all original records, including copies of every LDAR audit and documentation of prescribed ELP compliance. The plant must retain monitoring data, leak repair, training and audit records for five years and calibration equipment records for one year. Electronic records of monitoring data must be retained for the duration of the consent decree.
Part N stipulates that compliance status reports must be filed at intervals specified by the consent decree. The reports must detail the personnel assigned to LDAR activities, percentage of their time devoted to these functions, all instances of non-compliances, problems encountered in the process of compliance, training requirements, quality-assurance/quality-control deviations and corrective actions, and provide a summary of LDAR audit results. The plant manager and an environmental or engineering management official must sign and certify the reports to be true.
Enhanced LDAR takes standard LDAR to a higher level of compliance, mandating the use of certified low-leak valves and packings, and aligning the regulations with the best available technologies and practices.
Jim Drago, P.E., is manager, business development and market research, for Garlock Sealing Technologies, Palmyra, N.Y. E-mail him at email@example.com.
1. "FY08–FY10 Compliance and Enforcement National Priority: Clean Air Act, Air Toxics," U.S. EPA, Washington, D.C. (Oct. 2007).
2. "Leak Detection and Repair — A Best Practices Guide," Appendix E, "Enforcement Alert —Proper Monitoring Essential to Reducing 'Fugitive Emissions' Under Leak Detection and Repair Programs," U.S. EPA, Washington, D.C. (2007).