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June 21, 2013
Stop emissions leaks before they start
By Timothy P Fagan, Senior Legal Editor - EHS

Emissions from a leaky valve may not seem like a big deal, but what if a facility had hundreds or even thousands of valves, plus other piping components and equipment that could potentially leak?

In larger facilities, volatile organic compound (VOC) and hazardous air pollutants (HAP) emissions from leaking piping components and equipment can quickly add up, which is why EPA includes leak detection and repair (LDAR) requirements in numerous regulations.   

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:

  1. Identify components to be included in the program;
  2. Conduct routine monitoring of identified components;
  3. Repair any leaking component; and
  4. 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.

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