Leak Detection and Repair (LDAR) plays an important role in supporting environmental compliance at pulp and paper facilities. Under 40 CFR Part 63, Subpart S (commonly referred to as MACT S), certain facilities classified as major sources of Hazardous Air Pollutants (HAPs) are subject to LDAR requirements. Compared to the more detailed LDAR standards found in sectors like chemical manufacturing and petroleum refining, the MACT S provisions are relatively limited in scope. As a result, LDAR may receive less attention within broader compliance efforts. This can lead to variability in how LDAR programs are implemented, including differences in staffing, documentation practices, and execution consistency. These factors may contribute to challenges in maintaining compliance, particularly in areas such as recordkeeping, monitoring intervals, and repair tracking. Recent enforcement actions by the EPA indicate increased attention to LDAR program performance, with a particular emphasis on documentation accuracy and the management of bypass lines. Facilities may benefit from reviewing their LDAR practices to ensure alignment with regulatory expectations.
Closed Vent System Bypasses
Closed Vent System (CVS) bypass line standards under MACT Subpart S may seem straightforward, but meeting monitoring and record keeping requirements necessitates a robust bypass line monitoring program, complete with operator training and a proper car seal management system. EPA enforcement has increasingly focused on the management of these programs; in response, facilities should consider developing internal protocols for the maintenance of car seals and proper documentation of car seal removals and bypass line openings. Facilities must ensure that every bypass event is documented, with clear records demonstrating compliance with applicable regulatory provisions.
Recordkeeping
Facilities may be diligently monitoring leaks and making repairs, but without proper records, documenting compliance may be difficult. This would make determining compliance difficult during an LDAR inspetionc. As such, recordkeeping is one of the most important parts of a healthy LDAR program. Chemical and refining facilities with large component inventories, often containing well in excess of 50,000 components, deploy complex LDAR Database solutions to manage their recordkeeping burden. In contrast, pulp and paper facilities may opt instead to go with a less expensive, simpler recordkeeping approach, perhaps built using spreadsheets, to manage component inventories containing an order of magnitude fewer components. While this approach may appear to be more straightforward, it introduces human error into the mix, and can make it more difficult to track compliance, particularly due to the manual nature of generating useful reports such as a component’s monitoring history and does not allow all parties to have a full picture of the program. Without a clear review trail and easily accessible documentation, facilities risk noncompliance findings during inspections, even if monitoring and repairs were performed correctly.
LDAR Program Management
In the pulp and paper industry, enforcement efforts related to Leak Detection and Repair (LDAR) programs have generally emphasized the importance of effective program management. Some facilities choose to delegate LDAR responsibilities to third-party contractors or assign limited internal resources. Managing an LDAR program this way can lead to inefficiencies and difficulties when it comes to demonstrating compliance. Indicators of an under-resourced LDAR program may include delays in repairs, frequent use of Delay of Repair provisions, and challenges generating reports on key performance metrics such as chronic leakers. Additionally, component inventories may not always reflect recent physical changes at the facility. To address these issues, facilities are encouraged to implement strong Management of Change (MOC) procedures to ensure updates are accurately incorporated into the LDAR program.
Further improvements can be achieved through measures such as requiring management approval for Delay of Repair decisions, conducting regular Quality Assurance and Quality Control (QAQC) reviews, scheduling periodic third-party audits, and establishing comprehensive LDAR training programs.
Generally, EPA’s enforcement actions in the pulp and paper LDAR sphere are geared toward pushing pulp and paper LDAR standards closer to chemicals and refining LDAR standards, such as more frequent monitoring, technician certification requirements, and specific monitoring instrument calibration requirements, to name a few. EPA appears to have taken experiences from LDAR enforcement against chemical plants and refineries and applied it to the pulp and paper industry. While the fate of the recent pulp and paper LDAR enforcement push is uncertain under the Trump administration, facilities should nonetheless be aware of the issues EPA is focusing enforcement action on, and work towards solving those issues before the agency comes knocking.
If you are concerned about the health of your pulp and paper facility’s LDAR program, or if you’re simply interested in learning more about enforcement actions against the pulp and paper industry, please email Inaas Darrat, Director of Chemical Sector Services (CSS) business line & LDAR SME, Deanna Duram, a Pulp, Paper & Tissue SME.
