10th December 2017
Manage your LDAR Program
Original article from Environmental Quarterly (Fall 2017) Trinity Consultants
What is LDAR
In a basic sense, Leak Detection and Repair (LDAR) is exactly what the name suggests: finding facility components that are leaking and fixing them. However, not every source that emits pollutants is necessarily a leak, and not every leak is easy to identify. Thus, key questions include: what needs to be monitored? How often do you need to monitor? What do you monitor with? How is a leak defined? When is the repair required to be made?
Finding a leak
Facilities can employ the conventional Method 21 that involves hand-held instrument such as a flame ionization detector (FID) or a photoionization detector (PID) “sniffing” individual components. Alternatively, a more robust method using optical gas imaging (OGI) cameras can be used to visualize gas streams, enabling an experience OGI surveyor to assess up to several thousands components within a day- approximately 10x more than Method 21. However, OGI cameras does not quantify the gas emitted and comes with hefty price tag of approximately 85k USD.
Reporting requirements
Using monitoring data or published emissions factors requires careful consideration of the calculation methods and emission factors that will be used in order to align the emissions data that are reported publicly (Sustainability report etc.).
Monitoring plan
At the heart of every successful LDAR program is a monitoring plan. Although the level of detail and complexity of these plans will vary depending on their scope (one facility or many) and purpose (e.g., internal requirement or expected upcoming regulatory requirement), each should clearly spell out how you comply with the underlying LDAR aims and rules.
Surveyors and their qualifications
A highly trained surveyor can ensure a complete, accurate, and compliant survey. These are a few basic, but critical, questions that should be answered:
Agency and non-governmental organisation interest
The oil and gas industry in general, and fugitive leaks in particular, are a growing focus for both regulatory agencies as well as environmental non-governmental organizations (ENGOs) in the country. OGI cameras will be more widely available to ever more qualified regulators, and can be used as a tool for conducting spot checks on facilities. Besides, ENGOs such as Earthworks and others have purchased OGI cameras to “expose” the pollution being generated by oil and gas facilities. A prime example of this is the Oil and Gas Threat Map, which is an interactive map showing the locations of oil and gas facilities across the United States.
Implementation strategy
With the many complex facets of LDAR program management, the single most important step facilities can take is careful and comprehensive planning. This is most effective when it involves a cross-functional team of environmental and safety staff, operations and maintenance personnel, and LDAR surveyors. Coordination of monitoring logistics (equipment rental or purchase and periodic calibration), training of personnel, and management of data are other aspects of LDAR program development that require careful consideration
Trinity Consultant’s LDAR support in Malaysia
In collaboration with Riverstone Environmental, Trinity facilitates the development and implementation of LDAR programs including the following tasks:
What is LDAR
In a basic sense, Leak Detection and Repair (LDAR) is exactly what the name suggests: finding facility components that are leaking and fixing them. However, not every source that emits pollutants is necessarily a leak, and not every leak is easy to identify. Thus, key questions include: what needs to be monitored? How often do you need to monitor? What do you monitor with? How is a leak defined? When is the repair required to be made?
Finding a leak
Facilities can employ the conventional Method 21 that involves hand-held instrument such as a flame ionization detector (FID) or a photoionization detector (PID) “sniffing” individual components. Alternatively, a more robust method using optical gas imaging (OGI) cameras can be used to visualize gas streams, enabling an experience OGI surveyor to assess up to several thousands components within a day- approximately 10x more than Method 21. However, OGI cameras does not quantify the gas emitted and comes with hefty price tag of approximately 85k USD.
Reporting requirements
Using monitoring data or published emissions factors requires careful consideration of the calculation methods and emission factors that will be used in order to align the emissions data that are reported publicly (Sustainability report etc.).
Monitoring plan
At the heart of every successful LDAR program is a monitoring plan. Although the level of detail and complexity of these plans will vary depending on their scope (one facility or many) and purpose (e.g., internal requirement or expected upcoming regulatory requirement), each should clearly spell out how you comply with the underlying LDAR aims and rules.
- The plan should be a practical guidebook that any surveyor can implement – with clearly outlined procedures for surveying components, tracking and repairing leaks, and documenting the actions taken.
Surveyors and their qualifications
A highly trained surveyor can ensure a complete, accurate, and compliant survey. These are a few basic, but critical, questions that should be answered:
- Do your camera operators know the difference between a gas leak and surface convection?
- Are they familiar enough with your facility operations to know when a pneumatic actuator is a vent rather than a leak?
- Do they have the tools necessary to complete a full day of surveying (e.g., a power inverter for in-vehicle charging)?
- Most importantly, can they complete a general survey safety and in accordance with your requirements?
Agency and non-governmental organisation interest
The oil and gas industry in general, and fugitive leaks in particular, are a growing focus for both regulatory agencies as well as environmental non-governmental organizations (ENGOs) in the country. OGI cameras will be more widely available to ever more qualified regulators, and can be used as a tool for conducting spot checks on facilities. Besides, ENGOs such as Earthworks and others have purchased OGI cameras to “expose” the pollution being generated by oil and gas facilities. A prime example of this is the Oil and Gas Threat Map, which is an interactive map showing the locations of oil and gas facilities across the United States.
Implementation strategy
With the many complex facets of LDAR program management, the single most important step facilities can take is careful and comprehensive planning. This is most effective when it involves a cross-functional team of environmental and safety staff, operations and maintenance personnel, and LDAR surveyors. Coordination of monitoring logistics (equipment rental or purchase and periodic calibration), training of personnel, and management of data are other aspects of LDAR program development that require careful consideration
Trinity Consultant’s LDAR support in Malaysia
In collaboration with Riverstone Environmental, Trinity facilitates the development and implementation of LDAR programs including the following tasks:
- Defining LDAR program and training requirements
- Acquiring equipment and providing the associated training
- Implementing monitoring equipment capable of logging data for upload to tracking software
- Assisting in software selection for long-term program compliance documentation
- Integration with multiple LDAR databases such as LeakDAS, FEMS, and GuideWare or Trinity’s custom build LDAR database
- 3rd party audit
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Riverstone Environmental Sdn Bhd (967872-H)
www.riverstone-enviro.com Tel: +603 5115 0232 A-09-01, Sky Park One City Jalan USJ 25/1 47650 Subang Jaya Selangor, MALAYSIA |
