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).