LDAR Programs: Compliance

LDAR Programs:
100%
Compliance
Achievable Goal or Wishful Thinking?
by Roy Massengale, EnRUD Resources
Leak Detection and Repair
(LDAR) programs have been
around since the early 1980’s.
Many things have changed since
their inception. More industries
have been regulated, specific toxic
chemicals have been targeted for
regulation, and areas or regions
with poor air quality have had
additional monitoring and record
keeping burden placed upon
them. As well as the leak definitions (levels at which a repair
should be attempted) have been
lowered and more focus placed on
the LDAR programs by the regulating entities.
As these programs have
matured, elaborate monitoring
systems consisting of a portable
gas chromatograph and data logging system have been developed
to ease the burden of gathering
data on tens or even hundreds of
thousands of data points per year.
Sophisticated software packages
have been developed to handle the
onerous record keeping and
reporting requirements of the
maze of regulations that facilities
are required to comply with.
These software packages perform
additional tasks such as manage
the scheduling of components as
well as calculate estimated mass
emissions (lbs./year leaking into
environment) that these facilities
are required to report to the government.
Yet, with all this change and
sophistication, the basic elements
are the same. We are just applying
technology of the 21st century to
the training needs to be designed
to show personnel how to operate
the technology (i.e. monitoring
system and software application)
as is traditionally performed. But,
the aspect of training that tends to
get lost is the routine training as to
what and why these people are
doing what they are doing.
A comprehensive training program should involve more than
just the elements of how to operate
the technology. The foundation of
all LDAR programs is EPA
Method 21 and though it is not an
expansive method it is routinely
misapplied. The comprehensive
training program should incorporate a module on EPA Method 21.
The EPA Method 21 training module should be set up so that personnel responsible for monitoring
can review material and take
annual examinations to document
training performed. There should
also be a module that would
review each of the federal and
state regulations applicable as
well as any permit provisions with
associated tests to document training performed.
Another aspect of training that
can sometimes get lost (but is getting attention now that many
refineries have signed compliance
decrees) is the routine training of
individuals not directly involved
in the LDAR program. These individuals are typically the operators
and maintenance staff at the facilities. These individuals can directly impact the success of a LDAR
compliance program. They need
to be introduced to the elements of
an LDAR program and helped to
understand how their involvement will allow a facility to
approach 100% compliance.
The effort to achieve 100% compliance with all the LDAR requirements is a monumental task that
can realistically only be achieved
through a team effort. A team
needs to be properly trained to
reach it’s goals.
“KNOWLEDGE IS THE KEY TO
SUCCESS AND TRAINING IS
THE DOORWAY TO COMPLIANCE.”
For more information on LDAR
Compliance Assistance, Please
call Roy Massengale at EnRUD
Resources at (281) 333-5816 or
visit www.enrud.com.
be more efficient in the tasks. The
basic elements are: 1) we identify
regulated pieces of equipment 2)
periodically check these components 3) if they leak, we initiate a
repair program 4) record information and report to appropriate regulatory agencies. It sounds so
simple
We take advantage of all the
technology to make our jobs easier
and more efficient. We take
advantage of software applications to manage the information
we gather. We can lose sight of
one constant element as we thrust
ourselves into the technology age.
The one constant element is the
LDAR programs are run or managed by people. The technology is
only making us more efficient if
these persons are properly
trained. As would be expected,
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