5 Additional Best Practices for LDAR Programs
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These best management practices for LDAR programs follow up on the 7 we discussed yesterday.
- Maintain a “Delay of Repair” list. Any component that cannot be repaired during the specified repair interval must be placed on a “Delay of Repair” list to be repaired during the next shutdown cycle. Delay of repair compliance assurance procedures ensure that the appropriate equipment is justifiably on the “Delay of Repair” list and that facilities have a plan to fix these components. Continue to monitor equipment that is placed on the “Delay of Repair” list in the facility’s regular LDAR monitoring. For leaks above the internal leak definition rate and below the regulatory rate, put the equipment on the “Delay of Repair” list within 30 days.
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- Maintain an electronic database. Incorporate and maintain an electronic database for storing and reporting LDAR data. Use data loggers or other data collection devices during all LDAR monitoring. Use best efforts to transfer, on a daily basis, electronic data from electronic data logging devices to the database. For all monitoring events in which an electronic data collection device is used, include a time and date stamp, operator identification, and instrument identification. Transfer any manually recorded monitoring data to the database within 7 days of monitoring.
- Develop and implement a quality assurance/quality control (QA/QC) review. In your QA/QC review procedures, include a daily review/sign-off by monitoring technicians. Periodically review the daily monitoring reports in conjunction with recordkeeping and reporting requirements. Institute a quarterly QA/QC review of your facility’s and contractor’s monitoring data. Include in this review, the number of components monitored per technician; the time between monitoring events; and any abnormal data patterns.
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- Conduct calibration drift assessments of LDAR monitoring equipment. Drift assessments should be conducted, at a minimum, at the end of each monitoring shift. Use a minimum of 500 parts per million (ppm) of the appropriate calibration gas, in accordance with Method 21 (a test method developed by the EPA for the determination of VOC leaks from process equipment). If any calibration drift assessment after the initial calibration shows a negative drift of more than 10% from the previous calibration, remonitor all valves that were monitored since the last calibration with a reading of greater than 100 ppm. Remonitor all pumps that were monitored since the last calibration with a reading of greater than 500 ppm.
- Maintain all required records. Records are one of the first components agency officials review when conducting an inspection of your facility. Organized and readily available records are one potential indication of an effective LDAR program. Well-kept records may also indicate that the LDAR program is integrated into your facility’s routine operation and management.