Maintaining a Leak Detection and Repair (LDAR) program is a daunting challenge, requiring individual identification of thousands (or even hundreds of thousands) of components, assigning requirements, and maintaining on-going compliance with monitoring and work practice standards. Plus, the very nature of chemical, refining, and gas facilities makes this a perilous journey, with the ongoing process improvement objectives begetting constant changes in LDAR components and their requirements. Therefore, LDAR champions, both those just starting their journey and those who have already traveled far, must constantly strive to maintain and improve their programs. To help aid those on this ongoing quest, this article highlights five (5) key LDAR program elements to keep in mind and cross check to ensure that you stay on the right path for LDAR program compliance.
 
This includes:

1. Identification of Equipment
2. Monitoring Frequency
3. Requirements for Repair
4. Recordkeeping
5. Reporting

 
1. Identification of equipment: Keeping the Equipment Inventory up to date is imperative to the upkeep of the LDAR program. Equipment in a process unit must be identified to be readily distinguished from equipment not subject to equipment leak regulation. Therefore, the failure to identify regulated equipment, or not identifying in a manner specified by the applicable rule, could be a violation. Identification needs can range from specifying individual components to groups of equipment, will vary based on the service, component type, and applicable rule, and may also include identifying specific program exemptions, such as equipment in vacuum service. And once all identification requirements are met, they must be updated to reflect component changes as they occur from process updates and improvements
 
Some items to consider are the following:

• When was the last tagging effort?
• When was the last stream composition/service review?
• When was the last turnaround and are records of added/replaced components available?
• Do you have a tag maintenance program?
• How do you identify component changes (additions/removals)?
• What is the MOC process at your site and how are component changes evaluated?
• Do you know the tagging requirements for each subject rule??

 
2. Monitoring Frequency: The frequency of monitoring depends on the type of equipment, its regulated service, and the applicable LDAR standard. The equipment that is subject to such periodic monitoring includes, but may not limited to:

• Pumps
• Compressors
• Valves
• Flanges and/or connectors
• Pressure relief valves (PRVs)
• Closed-vent systems (CVS) – hard pipe
• CVS -duct work
• Agitators

 
One easily missed monitoring event is monitoring equipment as required after repair, with most rules requiring additional monitoring to confirm a leak has been repaired. Monitoring may also be missed due to temporary downtime in the schedule monitoring window.
 
Some questions to consider to ensure you are meeting all required monitoring frequencies:

• Is my monitoring schedule robust enough to avoid missed monitoring from temporary downtime?
• Was the required follow-up monitoring identified and completed for each leak?
• Is each component removed from service tracked to ensure it is monitored when it comes back in service
• Is annual DTM monitoring scheduled and completed
• Do monitoring records accurately document each monitoring event including
• The instrument and equipment identification number
• The operator name/initials/identification number
• The date and time of each monitoring event

 
3. Requirements for Repair: Most LDAR regulations require owners or operators to make a first attempt at repair within five days of identifying a leak. If the first attempt is ineffective, then a leak must be repaired as soon as practicable, but no later than 15 days after the leak was detected, unless one of the few exemptions apply (e.g. technical infeasibility without a process shutdown). Failing to make repairs on time and for failing to make repairs altogether will result in penalties.
 
An instance where delay of repair (DOR) is allowed is if repair within 15 days is technically infeasible without a process unit shutdown. If a DOR is required, then document the reason for the delay and the dates of process unit shutdowns.
 
Review leak records, including:

• Confirmation that leak tags are added to the equipment.
• Records of the equipment ID number, the instrument and operator ID numbers, and the date the leak was detected.
• A list of the dates of each repair attempt and an explanation of the attempted repair method.
• The dates of successful repairs.
• The results of monitoring to determine if the repair was successful.

 
4. Recordkeeping: Keeping detailed and accurate records required by the applicable regulations is crucial to the upkeep of a good LDAR program. A common problem with recordkeeping is not updating records to designate new components that are subject to LDAR due to revised regulations or process modifications. Performing regular records maintenance is recommended to ensure that this and other pitfalls are avoided.
 
Review items for LDAR recordkeeping include:

• Rule applicability designations for each process unit or process area
• Maintain a list of all ID numbers for all equipment subject to an equipment leak regulation.
• Maintain a list of ID numbers and an explanation/review of conditions for each component designated as unsafe-to-monitor or difficult-to-monitor.
• Maintain detailed schematics, equipment design specifications (including dates and descriptions of any changes), and piping and instrumentation diagrams showing applicable LDAR components and all process unit boundaries.
• Maintain the results of each leak detection monitoring, including results of all standard M21 monitoring and AVO inspections, monitoring for leakless equipment, and non-periodic event monitoring, as applicable

 
5. Reporting: Reporting requirements are instrumental for assessing compliance. While the regulations require that certain reports be completed only once (e.g. Initial Notification, Notification of Compliance Status), other reports must be submitted at regular intervals (e.g. semi -annual reports). Penalties can occur for failure to submit reports, submitting incomplete reports, and late submissions of reports.
 
Common reporting issues to check for include:

• Ensure all required component monitoring data is included (and that nothing extra is being added)
• Check that all monitoring and leak data is provided by reporting period (not just monthly for each component type)
• Confirm that the required delay of repair data is provided
• Confirm that all leak data was reviewed to determine any changes to required inspection frequencies

 
Reviewing these items provides a strong start to keeping you on the path of compliance. If you want to learn more about other LDAR program areas and get a comprehensive view of LDAR compliance sign up for the following upcoming courses by Trinity experts:

• May 23, 2024 – Compliance Management for Fugitive Emissions and LDAR Programs
• September 19, 2024 – Compliance Management for Fugitive Emissions & LDAR for Natural Gas Processing Plants

For more information or assistance, please contact Inaas Darrat ([email protected]).