Environmental Permitting

Leaks: How to Keep Emissions from Adding Up

Identifying Leaks

Emissions from leaks are considered fugitive emissions because they cannot reasonably pass through a stack.  To help identify leaks, EPA developed a test method, known as Method 21, for the determination of VOC leaks from process equipment, including valves, pumps, compressors, pressure relief valves, flanges, connectors, and other piping components.

LDAR Programs

Numerous federal regulations require the implementation of LDAR programs, which are generally composed of four steps:

  • Identify components to be included in the program;
  • Conduct routine monitoring of identified components;
  • Repair any leaking component; and
  • Record and report monitoring results.

While all LDAR programs are similarly composed, the specifics of each program are unique depending on the source and the applicable standard; even the definition of what constitutes a "leak" varies among standards. Therefore, it is important to carefully review the requirements of the applicable standard before implementing an LDAR program.

When implementing an LDAR program, beware of the following common problems that may occur and possibly result in EPA enforcement action:

  • Improper identification or failure to identify and/or monitor all the regulated components;
  • Improper monitoring techniques;
  • Improper maintenance of the monitoring device;
  • Failure to repair components within specified time frames; and
  • Failure to maintain necessary records and submit required reports.

In addition to those regulations necessitating an LDAR Program, there are many more regulations requiring the use of Method 21 monitoring without the implementation of a formal LDAR Program.

Benefits of LDAR

Effective LDAR can positively impact a facility in many ways, such as:

  • Reducing product losses.  In many cases, emissions are lost product, and lost product is lost revenue.
  • Improving health and safety.  Reducing fugitive emissions makes for a safer working environment and reduces employee exposure VOCs and HAPs at the facility, as well as reducing the exposure of the surrounding community. 
  • Reducing emissions fees.   Many states levy fees for the quantity of pollutants emitted.  Reducing leaks reduces emissions and reduces emissions fees.
  • Avoiding fines, enforcement actions, and bad publicity.  EPA has identified leaking equipment as the largest source of HAP emissions from refineries and chemical manufacturing facilities.  As a result, the agency has included LDAR as a national enforcement priority.

Additional Resources:

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Timothy P. Fagan is a Legal Editor for BLR’s environmental publications, focusing primarily on air quality related topics. Mr. Fagan has covered environmental developments with BLR since 2000. Before joining BLR, he spent 5 years in environmental consulting and was responsible for air quality permitting and compliance for a broad range of industries in both the private and public sector. He received a Bachelor of Science degree in chemical engineering from Villanova University and a Master’s degree in environmental engineering from the Pennsylvania State University.