Leak Detection and Repair (LDAR) programs cannot be implemented or sustained by an individual. It requires a team working together to ensure that compliance is maintained appropriately. Typically, most people would consider the LDAR team is composed of the environmental department and the LDAR technician(s). However, a successful program includes personnel across the site including operations, engineering, and maintenance. Most persons working at a facility with an LDAR program in place have LDAR responsibilities that should be properly communicated.
Many day-to-day tasks are considered part of the LDAR program. Operations personnel may be responsible for conducting weekly pump visual inspections and documenting process changes via a Management of Change (MOC) program, which could result in the addition or subtraction of the number of LDAR components in the field. Additionally, personnel should inform the Environmental department and LDAR technician when components are in or out of LDAR service. Finally, all personnel should know what to do if they identify an open-ended line (OEL) or see visibly leaking components in the field. These are just a few examples of what LDAR responsibilities exist for personnel not in the Environmental department or LDAR group.
A written LDAR management plan (sometimes called Written LDAR Programs or LDAR Monitoring Plans) is a fully developed, closed-loop communication procedure with key elements to ensure LDAR compliance. LDAR plans will vary from facility to facility, depending on the relevant federal regulations. In some instances, facilities are required to develop and maintain LDAR Monitoring Plans as part of the requirements in a Consent Decree (CD). Regardless, EPA recommends that an LDAR Monitoring plan be developed as a “best practice” in order to “increase the effectiveness of an LDAR program.”
LDAR Monitoring Plans vary, but these are key elements seen in almost every plan:
- A list of LDAR applicable units and their associated regulations,
- Documentation of requirements specific to different types of equipment,
- Procedures associated with Management of Change (MOC) for ensuring that new LDAR applicable components are added to the existing database and monitoring routes,
- Description of roles and responsibilities for LDAR Personnel,
- How to conduct and record Audio, Visual and Olfactory (AVO) inspections,
- How to identify and address OELs,
- Procedures associated with leaking equipment typically including (but not limited to):
- Methods for monitoring,
- Leak Repair,
- Equipment Replacement, and
- Recordkeeping Measures.
The LDAR Monitoring Plan should be the ultimate reference guide for anything related to LDAR at a facility. It should be available to any personnel at the facility to ensure that roles and responsibilities are made clear to all members of the LDAR program. In addition to the LDAR Monitoring Plan, it is helpful to provide training to all personnel highlighting the LDAR Monitoring plan and LDAR responsibilities of each individual. Training can be provided on an annual basis along with other required training.
If you have any questions regarding the applicability of any aspect of this topic, please reach out to
Inaas Darrat – Director of Chemical Sector Services for more information and how Trinity can help.
Related Training:
For more information and assistance evaluating your current compliance requirements, please contact Inaas Darrat at
713.552.1371.
