Proposed Uniform Standards for Equipment Leaks

12 th LDAR Symposium May 15-16, 2012 New Orleans, LA Proposed Uniform Standards for Equipment Leaks Standards Certification Education & Training Publishing Conferences & Exhibits 1

Proposed LDAR Uniform Standards (U. S.) The Uniform Standards proposed in 40 CFR 65 on 3/24/12 represent EPA s new direction in regulatory development, : Menu of potential requirements Generally a cleaner read of NSPS and NESHAP provisions; There are some things included that have not been in any previous LDAR regulation. Existing regulations will need to be amended to point to a certain set of requirements within the Uniform Standard There are Uniform Standards for: General Standards (Subpart H); Storage and Transfer (Subpart I); Equipment Leaks (Subpart J); Heat Exchanger (Subpart L, published November 2011) Closed Vent Systems and Control Devices (Subpart M). 2

LDAR Uniform Standards (LDAR U.S.) Apply to: Process units, closed vent systems, and fuel gas systems that contain or contact regulated material; Within those types of facilities, provisions are for: Valves, pumps, connectors, agitators, pressure relief devices, compressors, sampling connection systems, open-ended valves and lines, instrumentation systems and any other equipment, as defined in the referencing subpart. 3

LDAR U.S. Compliance Approach Identify subject equipment Comply with referenced standards Or alternative standards for batch processes Comply with applicable notification, recordkeeping, and reporting Vacuum service equipment is exempt, but you must: Identify equipment in vacuum service; Continuously demonstrate that the equipment remains in vacuum service; Optical Gas Imaging (OGI) in 65.450 may be used as an alternative to M21 if the referencing subpart allows Identify equipment where OGI will be used Follow protocol in Appendix K (yet to be published) 4

LDAR U.S. Valve GV and LL Monitor monthly at 500 ppm leak definition initially to establish leak percent (or use prior similar monitoring data) Based on average leak percent over last 2 periods, monitoring frequencies are: Over 2% must monitor monthly (unless <=3 total leaks) Less than 2% = quarterly Less than 1% may monitor semiannually Less than 0.5% may monitor annually Less than 0.25% may monitor biennially. Leak % may be by unit or groups of units but you may not monitor any group less than quarterly if the overall valve leak rate is >2% Monitor each repaired valve within 3 months after repair 5

LDAR U.S. Valve GV and LL Valves with less than 1 year monitoring history must be assigned to the most frequently monitored subgroup until 1 year of data is available Valves with no actuator penetration are exempt from valve standards and are subject to sensory monitoring in 65.430; UTM and DTM are exempt from monitoring by percent leaking and are monitored according to their written plan (whenever safe for UTM and at least annually for DTM) Clarifies 3% limit is for new sources only Mostly HON requirements for valves from any referencing subpart 6

LDAR U.S. Pumps LL Pump standards are also based on HON requirements: 2,000 ppm leak definition (except 5,000 ppm for polymerizing monomers) Monthly instrument monitoring Weekly visual inspection Must document visual inspection results Must repair before next weekly inspection or monitor to show no leak Allow DTM and UTM designations for pumps No QIP program 7

LDAR U.S. Connectors GV and LL If referenced, monitor initially within 12 months at 500 ppm leak definition to establish leak percent (or use prior similar monitoring data) Based on leak percent, monitoring frequencies are: 0.5% or greater must monitor annually 0.25% or greater but <0.5%, must monitor every 4 years Less than 0.25%, must monitor every 8 years, but Must monitor 50% of connectors within 4 years If 0.35% or greater leak, complete all within the initial 4 year period If less than 0.35%, have 4 more years to complete connector monitoring Inaccessible connectors are exempt from above and only require response to sensory indications of leakage Monitor each repaired connector within 90 days after repair 8

LDAR U.S. Agitators GV and LL Agitator standards are also based on HON requirements: 10,000 ppm leak definition Monthly instrument monitoring Weekly visual inspection Must document visual inspection results Must repair before next weekly inspection or monitor to show no leak Allow DTM and UTM designations for agitators Exemption from instrument monitoring for agitators obstructed by other equipment, but still must perform visual inspections weekly 9

LDAR U.S. Pressure Relief Devices GV PRDs must operate with less than 500 ppm reading above background. All PRDs after each release to atmosphere: Monitor within 5 days of the release (or if using a rupture disk, replace RD within 5 days and monitor within 5 days of RD return to service) Reading of 500 ppm or greater is non-compliant No provision to repair or DOR Where referencing subpart specifies, no PRD releases to atmosphere are allowed: PRD must vent through a closed vent system to a control device, or PRD must be equipped with device(s) that can record the time and duration of each release and notify operators of the release. If the device can also read concentration, its data can be used to satisfy the 5 day follow-up monitoring requirement 10

LDAR U.S. Compressors GV Either comply with a seal standard or designate the compressor for operation less than 500 ppm above background Seal standard requires a barrier fluid system that meets standards similar to those for pumps Must comply with sensory monitoring requirements for all potential leak interfaces on the compressor besides the seal Does not include option to capture seal leakage and vent by CVS to process, fuel gas, or control device Designation for operation at less than 500 ppm above background Monitor initially, annually, and upon agency request to confirm Any reading of 500 ppm or greater is a deviation 11

LDAR U.S. Sample Systems Requirements are very similar to those in NSPS VV and HON Some additional options for handling materials collected by closed purge Do not appear to be any added requirements Recordkeeping requirement to log the date, time, and volume of each purge! 12

LDAR U.S. Open-Ended Valves & Lines Equip open-ended valves and lines with a cap, blind flange, plug or second valve so that the open-ended valve or line operates with an instrument reading of less than 500 ppm above background. Must seal the open end except when in use Double block valves must close upstream valve first Conduct instrument monitoring to verify less than 500 ppm above background initially upon installation, annually, and as requested by the agency Any reading of 500 ppm or greater is a deviation OELs in emergency relief systems would be exempt, unless the referencing subpart allows no release to atmosphere 13

LDAR U.S. Other Equipment Other equipment must comply with sensory monitoring requirements in 65.430 including: All equipment at a plant site with less than 1,500 total pieces of equipment Any equipment that contains or contacts regulated material, but is not in regulated material service (i.e., under 5 wt.% VOC or HAP) Equipment in regulated material service less than 300 hours per year Valves, pumps, connectors and agitators in heavy liquid service Connectors in GV and LL where 65.422 is not required Instrumentation systems (benefit to all non-hon units) PRDs in LL service Any equipment with sensory monitoring requirements Any other equipment specified by the referencing subpart 14

LDAR U.S. Closed Vent & Fuel Gas Systems 65.429 points on the Uniform Standards Subpart M CVS and fuel gas systems that are used to collect and control air emissions must: Perform instrument monitoring initially, annually, and at the request of the agency Demonstrate that instrument readings are less than 500 ppm above background, and any reading >=500 ppm is a deviation Subpart M contains requirements for control devices control efficiency, bypass prevention/detection, performance testing, and recordkeeping on periods of non-compliance Treatment of Fuel Gas Systems like CVS is new and potentially significant 15

LDAR U.S. Sensory Monitoring Requirements If indications of potential leakage are observed, you have 5 days to: Repair to eliminate the sensory indications of leakage; Repair to no bubble condition by soap bubble testing; Monitor with instrument and repair if above the leak definition in Table 1 Also includes requirements to keep records of your determination of: Heavy liquid service Appears to be an exemption if you perform sensory monitoring on all equipment in the process unit In regulated service less than 300 hours per year 16

LDAR U.S. Instrument Monitoring Specifies and paraphrases some parts of Method 21 Specifies that the instrument criteria for response factor <10 must be demonstrated for streams (not pure compounds) on an inert free basis Or correct readings with RF values if no commercially available instrument can meet the RF criterion above Requires calibration drift assessment Similar to NSPS VVa, but without the algebraic average language Specifies calibration gas similar to VVa Zero; cover several leak definitions within 2,000 ppm; and around 10,000 ppm Allows reference compound other than methane if analyzer will not respond to methane 17

LDAR U.S. Instrument Monitoring Monitoring performance: Monitor when equipment is in regulated material service or in any other material that would be detectable by the instrument Specifies minor variations that would be allowed to use historical monitoring to set initial monitoring frequency for valves and connectors Explicitly allows monitoring results to be corrected for background or not 18

LDAR U.S. Leak Identification and Repair Weatherproof, readily identifiable identification of leaks First attempt in 5 days, and, unless you can determine that the attempt was unsuccessful by other means, monitor no later than 5 days after the leak is detected Successful repair and monitor to verify success within 15 days of leak detection Allows designation as unsafe to repair, which must then follow delay of repair requirements Leak identification removal: Valves: after the follow-up monitoring within 3 months after repair Connectors: after the follow-up monitoring within 90 days after repair Other equipment: after successful repair 19

LDAR U.S. Delay of Repair Delay of repair (DOR) is allowed if: Repair is technically infeasible without a process unit shutdown You must repair this equipment as soon as practical, but no later than the end of the next process unit shutdown or 5 years after detection, whichever is sooner. For the purposes of this section, a process unit shutdown is any shutdown that lasts more than 24 hours, regardless of whether it was planned or unplanned. Definitions in Subpart H indicate that an unscheduled work practice or operations procedure that would stop production from a process unit, or part of a process unit, for a shorter period of time than would be required to clear the process unit, or part of the process unit of materials and start up the unit, and would result in greater emissions than delay of repair of leaking components, until the next scheduled process unit shutdown is not a process unit shutdown 20

LDAR U.S. Delay of Repair (Cont d.) Delay of repair (DOR) is allowed if: Equipment is determined to be unsafe to repair; Must repair by sooner of next process unit shutdown or 5 years. Equipment is isolated from the process such that it does not contact or contain regulated material; Valve, connector, and agitator repairs may be delayed if: Document planned date of repair and demonstrate that purged emissions to allow immediate repair would be greater than allowing the component to leak until the planned repair date. Pump repairs may also be delayed if: Replacing the seal with a system determined to offer better performance DOR is allowed for up to 6 months. 21

LDAR U.S. Delay of Repair (Cont d.) Requirements for equipment on DOR: Continue to monitor at the specified frequency for the type of equipment Not required where equipment is isolated from the process Agitators and pumps need not conduct weekly visual inspections When valve or connectors are repaired, it must be done using low leak technology unless technically infeasible Develop a written plan that addresses demonstration of whether a device or repair technique qualifies as low leak technology, criteria for selecting the low leak technology to be used for a repair and installation procedures for the selected technology. 22

LDAR U.S. Delay of Repair (Cont d.) DOR low leak technology for valves includes but is not limited to: Repacking the valve with a low emission packing; Replacing the valve with a valve designed to accommodate low emission packing; Replacing the valve with a bellows seal valve; or Other repair or replacement that has been tested rigorously and did not leak above 500 ppm during the entirety of the test. DOR low leak technology for connectors includes but is not limited to: Replacing the flange gasket. Replacing the entire connector. Other repair or replacement that has been tested rigorously and did not leak above 500 ppm during the entirety of the test. 23

LDAR U.S. Delay of Repair (Cont d.) If you cannot use low leak technology in your DOR repairs for valves and connectors: You would be required to explain why that replacement is technically infeasible in your annual periodic report. Future leaks that are placed on DOR would require a new analysis of technical feasibility of using low leak technology. 24

LDAR U.S. Batch Alternatives Batch processes are allowed to monitor within 30 days after reconfiguring the process and repair leaks without counting them in frequency determination for valves and connectors. You may use Table 2 to determine the appropriate monitoring frequency for pumps, valves, and agitators that run significantly less than full time. To allow operating flexibility, you may monitor anytime during the specified period so long as consecutive monitoring events are at reasonable intervals, such as: Monthly tasks must be separated by at least 14 days Quarterly tasks must be separated by at least 30 days, etc. 25

LDAR U.S. Optical Gas Imaging (OGI) You may use OGI to monitor for leaks instead of instrument monitoring if you meet all three criteria below: Referencing subpart must directly reference 65.450; OGI instrument must meet the performance criteria in, and the OGI survey must be conducted in accordance with, 40 CFR 60 Appendix K You may only use OGI as an alternative to monitoring, it may not be used in lieu of sensory surveys or design requirements Compliance requirements: Identify all equipment where OGI is to be used Use 60 grams/hour release for daily instrument check and bimonthly frequency unless directed otherwise by the referencing subpart May not use leak percent based extended frequencies A leak is any emission that can be imaged and leak repair can be determined by eliminating a visible leak Maintain required records 26

LDAR U.S. Notifications and Reports Notification of Compliance Status Submit the earlier of: 240 days after the applicability date in referencing subpart or 60 days after first performance test Semiannual Reports Report deviations Annual Reports Same as Semiannual plus Numbers monitored, leaked, and not repaired within 15 days Reasons for delay of repair Reasons low leak technology not used on DOR leak repairs 27

LDAR U.S. Recordkeeping Significant new records, general: Identification of equipment with special determinations (DTM, UTM, UTR, etc.) along with facts to justify and written monitoring plans; Identification of equipment that is not to be operated with readings over 500 ppm and records of time and duration that is exceeded; Identification of equipment with exemptions to monitoring, such as vacuum service or regulated service <300 hours per year, along with any deviations; Records of calibration, calibration standard gases, calibration drift assessments, and re-monitoring for failed drift assessments; DOR justification, signature, estimated repair date, shutdown dates, and where/why low leak technology was found infeasible. For valves: Valves grouping, any reassigned, and start/end dates of monitoring; Monitoring results and percent leak calculations for each group; 28

LDAR U.S. Recordkeeping (Cont d.) For pumps and agitators: Date and results of visual inspections, including characteristics of liquids dripping if applicable For connectors (if applicable): Start/end dates of each monitoring event; Monitoring results and percent leak calculations. For pressure relief devices Dates of releases and dates of post-release monitoring or RD replacement Quantity of regulated material released to atmosphere in each event For compressors: For alternative compressor standard, dates and readings of each compliance test 29

LDAR U.S. Recordkeeping (Cont d.) For sample systems: Records of the date of each purge and estimates of the purged amount For open-ended valves/lines, closed vent systems, fuel gas systems : Dates and results for each compliance test Records for optical gas imaging: Equipment and process units to use OGI Video records with date/time stamps Equipment screened and date/time of screening Documentation of repairs and repair verification imaging Flare records visual emissions and times w/o pilot or pilot monitoring 30

LDAR Uniform Standards Conclusions The Uniform Standards have cleared up some confusing language, but create other issues: Move most requirements to the most stringent provision in any of the existing equipment leaks regulations; Add some requirements that go beyond any of the existing equipment leaks regulations; Create several new requirements where any reading of 500 ppm or greater above background is a deviation; Create confusion reviewing requirements when you do not know whether a section will be referenced by your applicable subparts; Create consistent applicability language that was different for a reason in the applicable subparts. The docket is still open for comments until June 25, 2012 31