Initial steps can include
the following:
q Determine what components must be included in the LDAR program per the applicable regulations.
q Decide how to physically identify each affected component so that the person doing the monitoring can easily locate it and monitor it.
Issues to consider when
determining how to physically identify each component:
Physical
Tags:
a)
Attach a physical ID tag to
each component.
q Metal or plastic?
q Stamped or engraved ID number?
q Bar code ID?
q RF (Radio Frequency) ID?
q
Attach with wire?
Attach at two points so it does not flap around and eventually break
free?
q How many other ID tags are already on the component?
b)
ID numbering
system.
q Random numbers?
q Sequential numbering system?
q If a sequential number is used, what if new components are added between two sequential tags?
q Numbers that have some meaning?
q Is it possible for there to be duplicate tag numbers? If so, what number should be used as the “tie breaker?” Combo of Tag ID and Drawing Number?
q
What if the single piece of equipment being monitored
consists of more than one component and each needs to be monitored and recorded
separately (i.e., valve stem and two flanges)? Should each component have its own
physical tag or should the equipment get one tag to represent all sub
components? If one tag is used, how
will the records show that the sub-components have been monitored
individually?
c)
Hanging new
tags.
q Coordinated effort to tag the entire facility all at once?
q Tag the facility one area at a time?
q Hire contractor to hang tags?
q Remove old tags?
q
Always keep a cross reference record of old tag number
with new tag number when replacing tags!
d)
Tag
maintenance.
q Do the components get painted periodically? What if the tag gets painted?
q What is the S.O.P. if someone finds a tag laying on the ground? Will people from other departments know what to do with it or that they should report it and to who?
q What is the S.O.P. for when an LDAR technician discovers a tag is missing?
q Should a missing tag be replaced by one with the same number? What will that cost in time & material?
q If a missing tag is replaced with a new number, how is that cross referenced to the old number?
q
What if the component is replaced? Should the tag number from the old
component be used, or should a new tag be hung?
Use Drawings instead of
Tags:
a)
Establish an initial set of
drawings the LDAR technician will use.
q General purpose P&ID or LDAR specific Isometric?
q Who will create or enhance the drawings that the LDAR technicians will use?
q How will the components be identified on the drawings? ID numbers? Bar codes?
q Who decides the initial drawings are a correct base line of information to start with?
b)
Keeping the drawings up to
date.
q How will changes noted in the field be conveyed to the technician’s drawing?
q Who/How/When will changes to the drawings be permanently updated?
q How will the technician know he or she is taking the most up to date drawing set with them when they go out to perform new inspections?
q
Will the “official” records be kept on hard copy
drawings or electronic copies?
Populate the software used
for LDAR program management with component ID information:
a)
Data entry of new
component information.
q Key in data at the PC?
q
Collect data in the field with a data logger during
tagging, upload to PC software?
b)
Reuse existing component
data.
q Electronically convert data in an existing database or spreadsheet to the new LDAR software?
q Key in existing data that is currently only in hard copy form?
Initial steps can include
the following:
a)
Establish standard location
descriptions.
q Carve up the facility into enough areas and sub-areas that the people doing the monitoring can physically locate the components which need to be inspected.
q Use the location fields available in the LDAR software as a guideline.
q
Set up the LDAR software with the location description
pick lists.
b)
Establish what constitutes a
“reportable Unit” per the regulations.
q Is it all the components in a specific Building or Area?
q Is it all the components associated with a specific “process?”
q
If it is components associated with a process, what if
some components are used on more than one process? (If they were reported in more than one
Unit, then one leak could be counted more than once.)
This aspect has a wide range of issues, but they can be divided into two camps; Subcontract the monitoring task to a qualified contractor who specializes in LDAR, or handle all aspects of monitoring and repair in-house.
ANSWER THESE QUESTIONS
NOW:
q What skill set and/or experience should the LDAR Program Administrator have?
q Will it be a permanent position for that person, or will it be a temporary assignment?
q Who (at this moment in time) is the LDAR Program Administrator for my facility?
With those answers in mind, consider what’s involved with doing the monitoring in-house or subcontracting it to others:
a)
Purchase analyzers.
q How many are required?
q FID or fuel cell type?
q
Data logger built in or separate?
b)
Maintain
analyzers.
q Who will calibrate the analyzers? What is the S.O.P.?
q Who will specify calibration gas standards, purchase the gas & track its inventory?
q What are regulatory requirements for maintenance or calibration?
q Who will perform routine maintenance?
q Who will coordinate with the analyzer supplier if work has to be done?
q Who will perform quarterly certification of each analyzer?
q Certify the analyzers in-house or use a 3rd party?
c)
Train
technicians.
q What qualifications do they require?
q Who will train the technicians?
q How will they be trained?
q How much regulatory information do they need to know?
q What is the S.O.P. for conducting an inspection?
q What is the S.O.P. for reporting irregularities?
q How many components should an technician be expected to monitor in a single day?
d)
Supervision of
technicians.
q What qualifications does the supervisor require?
q Who will supervise the technicians?
q Where will that person get trained?
q Who should the supervisor report to? Maintenance, Environmental, or Operations?
e)
Monitoring only, or Monitor
and 1st Repair Attempt
q
Should the technician be required to make the first
attempt at repair immediately upon discovering a leak?
a)
Qualifications.
q Is LDAR monitoring one of the contractor’s core businesses?
q
Does the contractor have experience at similar
facilities?
b)
Monitoring equipment.
q Should analyzers and data loggers be supplied by the company or should the contractor use their own equipment?
c)
Availability.
q Can the contractor have a technician on site to do monitoring when it needs to be done?
Other contracting considerations:
q Sub-contract the whole LDAR program?
q Combination of in-house and contracted program?
a) Contractor does the monitoring and you do the data management.
b) Contractor does everything but report preparation.
Fundamental to the LDAR
program is effective collection of good data. Managing the program using data
that has poor integrity (i.e., does not correlate to what is really in the
field) exposes the company to risk of non-compliance and makes managing the
program time consuming and frustrating.
In general, data collection
can be carried out two ways; using
pen & paper or electronic data loggers.
a)
How it is done:
· Technician goes out into the field with a form that has the list of components to be inspected, along with pertinent component information.
· There is a place on the form for the technician to write in the analyzer reading.
· When all components are inspected, the technician (or other person) keys the readings into the LDAR software. Any other information such as delayed for shutdown, first attempts at repair, etc. is also keyed in.
b)
Pros:
q Lowest cost.
q It is simple. Nominal training required.
q No chance of “pushing the wrong button.”
q Little chance of losing a day’s worth of inspection data.
q Which order components are inspected in does not matter.
q Technician can scan the page and intuitively choose the order of inspection.
q
Missed inspections are obvious, no reading filled in.
c)
Cons:
q Requires the technician to use both hands to write down the reading, could slow him down.
q Requires data to be keyed in back at the office.
q Hand writing may be hard to read resulting in wrong information.
q Damp or wet conditions could damage the paper or make written information illegible.
q Inspection results could be forged.
a)
How it is done:
· A list of components to be inspected, along with pertinent component information (called a “Route”) is downloaded from the PC software to the data logger. Technician takes the data logger into the field to record inspection results.
· Some data loggers have a way for the technician to record other information such as delayed for shutdown, first attempts at repair, new component, etc.
· When all components are inspected, the technician connects the data logger to the PC and uploads all of the information collected directly into the LDAR software.
b)
Pros:
q All inspections are time and date stamped automatically for QA/QC purposes.
q Data is entered one time. No additional data entry at the PC is required. Less opportunity for error.
q Typically operated with one hand.
q With some data loggers, each component comes up on the screen in the order that they are to be inspected.
q
Can be used in bad weather.
c)
Cons:
q Equipment cost can be significant.
q Potential for lost data due to hardware failure.
q Can’t use it if the battery is not charged.
q Some training is required.
d)
Data Loggers that are stand
alone vs. hardwired to the analyzer:
· Data loggers for LDAR fall into 2 families;
1. Integrated into the analyzer or hard wired so that analyzer readings are automatically recorded in the data logger.
2. Separate from the analyzer, user has to key in the analyzer reading.
q Is it more desirable to have the highest reading detected automatically recorded by the data logger, or should the user be able to decide what the highest reading was and key it in? (Note: The regulations do not require the reading to be automatically recorded. Keying in the reading is effectively the same as writing it down using a pen & paper method.)
q Does cost of the equipment matter when making this decision?
The regulations require an
“effective” repair be made within 15 days of discovering
a leak.
a)
Who will perform the
repairs.
q In house maintenance department who is also responsible for all other repairs at the facility?
q Maintenance crew dedicated to LDAR?
q Subcontractor?
b)
Notification that a repair
is required.
q How will the LDAR supervisor know a repair is required and what the deadlines are?
q How will the maintenance supervisor be notified? What is the S.O.P.?
q Does the need for a repair need to be entered into a computerized maintenance management system?
c)
Re-testing a repaired
component.
q How will the LDAR supervisor be notified that a repair is complete and a re-test can be scheduled?
q
Should technicians be sent out to perform only re-tests,
or should they be rolled into other scheduled inspections that need to be
performed?
a)
Should you create your own
database or purchase an off-the-shelf LDAR software
product?
If you have under 1,000 components to manage and you want to handle it in-house, you could do your scheduling and keep records manually with a spreadsheet. A commercially available LDAR software product becomes essential when the component count gets into the thousands and the complexity of the regulations make it impossible to maintain reliable/defendable records. The R.O.I. comes from two places; minimizing the labor of everyone involved with the LDAR program and automatic maintenance of LDAR specific records that can be used to document compliance.
LDAR software is not your “LDAR Program.” It’s a tool you use to help manage your LDAR Program. If the LDAR Program Administrator function in your company is considered a temporary assignment, then it makes sense to choose LDAR software with features that automate the process of managing fugitive emissions compliance.
b)
Access to the LDAR
software.
q Who will be using the software?
q Technicians?
q LDAR Administrator/Supervisor?
q Environmental Coordinator/Engineer?
q Maintenance Supervisor?
q Subcontractor?
q Restrict use to one PC, or make the LDAR software available on the network?
q Who will use the LDAR software more than anybody else?
q How often will others need access and what information will they be looking for?
c)
Information that the LDAR
software needs to make available to users other than the LDAR
administrator/supervisor who handles day to day monitoring requirements (i.e.,
what do you want to get out of it?).
4 Reports for regulatory submittal:
q Monthly?
q Quarterly?
q Semi-annually?
q Annually?
q Work notification that repairs are needed?
q Anything else?
d)
Scheduling
inspections.
Criteria for when each component should be inspected is specified by each regulation. Part of that criteria takes into consideration the leak history of the component. With some regulations, if components have not leaked for a certain number of monitoring periods, the inspection frequency can be relaxed (i.e., components requiring quarterly inspections could be inspected semi-annually instead).
q Should actual inspection schedules be determined by the LDAR administrator / supervisor?
q Or should the software have logic built in to automatically determine, based on regulatory criteria, the minimum number of times each component needs to be inspected each year?
q Should the software remind the user when deadlines are approaching?
e)
Access to historical
data.
q Is there value in having ready access to information for each component?
q Previous inspection results, when and by who?
q Leak history?
q Repairs that have been done, when and by who?
q Conditions noted in the field, when and by who?
q Next scheduled inspection?
q Which components are out of service and when will they return to service?
q Old tag numbers correlated to new tag numbers?
q Should the software base its logic on the most stringent regulation affecting each component or should it apply the criteria of each regulation separately and record historical information accordingly?
f)
Mass Emissions
Calculations.
q Is mass emissions reporting required?
q What method(s) should be used?
q EPA Correlation Equations?
q SOCMI factors?
q Unit Specific Factor?
q Leak/No Leak?
q Stratification?
g)
Reporting.
q Should required reports be produced automatically by the software, or only on demand?
q What pre-defined LDAR specific report formats come with the software?
q Should there be a way to customize existing reports or create new ad hoc reports?
h)
Security.
q Will there be people accessing the LDAR software who have varying levels of involvement and accountability?
q Should there be multi-level security configurable by the LDAR Administrator/Supervisor?