An effective Leak Detection and Repair (LDAR) program is a must-have component for a wide variety of facilities that exist “inside the fence.” While examining the components of such programs, EMS also suggests that there is an interest among facility and pipeline operators that could be powered by understanding the needs of both groups.

The US Department of Transportation (DOT) and its Office of Pipeline Safety regulate pipelines. They comment regularly, for example, about Lost and Unaccounted-For Gas (LUAF), “the difference between the amount of gas purchased and the quantity of gas sold, whether it is more or less.” Their attention is almost always on pipelines because the national transportation and distribution system is under constant scrutiny and continuous regulation.

Now it is time to look inside. Not just inside the city gate, that pre-defined physical location where gas is delivered by a pipeline to a local distribution company. We wish to look inside the fence, in the facility where gases are regularly used for the generation of energy or conversion to other products.

Inside the fence we are dealing with process facilities, refineries and power plants. These have their own sets of environmental, health and safety management, maintenance, and operational objectives. They are not necessarily the same as those for pipeline operators; they operate under different regulations, set by different regulatory bodies.

For example, minimizing air pollution and lowering emissions are not merely necessary for the environment, they are actions required by the government. Facilities operators are now required to accurately measure, quantify and report real numbers relative to emissions – not merely estimate them.

Today, US Environmental Protection Agency (EPA), US Occupational Safety and Health Administration (OSHA), and state regulations are rigorous and much more stringent that ever.

As a previous EMS article pointed out, without testing and measurement, pipeline owners could be suffering major lost and unaccounted for gas deficits. Although this component is just as important for facilities as it is for pipelines, inside the fence there are other issues besides LUAF.

Eighty Million Pounds of VOCs – or More?
Volatile organic compounds (VOCs) contribute to ground-level ozone, a principal component of smog, which can cause significant health and environmental problems. They also constitute immense health and safety hazards.

According to the EPA Office of Regulatory Enforcement, Federal regulations require refiners and process facilities to routinely monitor for leaks, then fix any equipment found to be leaking. In one instance, the EPA believes that failing to identify and repair leaks at petroleum refineries could be leading to as much as 80 million pounds annually in additional VOC emissions. Refineries and other hydrocarbon processing facilities are not the only source of VOCs – any facilities that use solvents could also be sources.

This leads us to the term “fugitive emissions.” Fugitive emissions occur from valves, compressors, pumps, flanges, connectors and other piping components. The government says that there is a disparity between what refineries and hydrocarbon processing facilities report and what the EPA has found may be attributable to refineries which are not monitoring in accordance with 40 CFR Part 60, Appendix A, Method 21. So there are government requirements that operators develop and implement a Leak Detection and Repair (LDAR) program to control these fugitive emissions.

Building an Effective Program
LDAR programs are generally comprised of four processes. While regulations vary, they usually require that facilities:

• Precisely identify components to be included in the program
• Regularly conduct monitoring of identified components
• Promptly repair leaking components
• Comprehensively report monitoring results.

The most valuable and cost-effective programs integrate these four processes.

After determining a target list of leaking compounds, there is a need for regular, frequent inspections that interlock with the other processes. Integration is important since there are major risks from high-pressure lines, compressors, valves and other operating equipment.

Inside the fence, leaks found are frequently as much as 500 parts-per-million. This figure represents literally tons of emissions and tons of product lost into the environment (as well as a major safety hazard). Pipelines, where EMS has previously focused its efforts, are invisible from inside the fence. Now, we work inside the fence for point-source leak detection, maintenance and reporting.

Maximizing Point-Source Leak Detection
In facilities, the methodology proven most effective is point-source leak detection: close-range detection and measurement techniques. Even after years of successful implementation, point-source leak detection is labor-intensive and costly. Technology becomes a significant advantage. New infrared (IR) imaging cameras, for example, enable companies to spot methane and other VOC gas leaks quickly and easily. These cameras can rapidly scan large areas to deliver real-time thermal images of gas leaks. They become a cost-minimizing component of enhanced fugitive emissions monitoring programs that meet federal and state regulatory requirements.

Organizing Effective Repairs
Prompt repair of leaks – as part of a regularly organized maintenance program – is the next element of the equation. Yes, more effective repair materials are crucial. There is a unique standalone composite repair kit called I-Wrap which includes all the materials needed to complete pipe rehabilitation for a specific line size and piping system requirement. It significantly reduces repair time, which reduces facilities’ downtime.

At the same time, scheduled, tracked maintenance processes ensures that such repairs do not impair effective day-today operations in the first place.

Connecting with Database Management
Inside the fence, the collection, management and reporting of detection and remediation information are just as important as in the pipeline sector. Integrate every part of the LDAR program via effective database management virtually guarantees the success of fugitive emissions control.

Facilities that undertake leak prevention should take advantage of a complete regulatory compliance analysis and reporting tool, one that can target multiple quality flaws in its
fugitive database. To be most useful and flexible, the system should work with any database, and demonstrate the ability to generate reports customized to meet evolving government standards at any time.

It should work quickly, returning results in seconds instead of minutes (or days) – and it ought to be able to link with the company’s overall enterprise data system.

The users and administrators of the database management system are only some of its beneficiaries. The operators and owners of refineries, processing facilities and utilities receive improved control over potentially hazardous situations that are increasingly in the news, increasingly the focus of community attention.

To many facility owners and corporate entities, there is additional value in being good environmental stewards. There also ought to be measurable benefits in terms of cost- and risk avoidance from the inception of the LDAR program.

Key Point: Two Communities Should Share
We believe there is an opportunity to join two communities, the transportation and distribution industry outside the fence with refiners, petrochemical processors and utility operators inside the fence.

It is frequently observed that each market sector operates as though it is independent of the other, following different regulatory agencies’ requirements, talking about similar issues in different languages.

If the two communities increase their interactions, then plant environmental teams can have meaningful discussions with pipeline environmental teams, making certain which group is responsible for which jobs.

Recognizing that effective LDAR programs are similar to effective pipeline MRO programs can lead to improvements in communications. There will also be an improvement in the overall level of environmental knowledge, so that one community’s environmental knowledge achieves the same level as the other.

We understand that there are two communities. But we suggest that the fence line could be considered a mental construct that can be changed to promote greater interaction between two equally critical groups of professionals.