Garlock Sealing Technologies

Enhanced Leak Detection and Repair Programs

for the Chemical Processing Industries

October 19-21, 2010 | Reliant Center, Houston, Texas

Written by Jim Drago, P.E.

Regulations

Abstract
The term, Enhanced Leak Detection
and Repair Program, or, Enhanced
LDAR, is finding its way into USA petroleum and chemical process plants
via consent decrees. Enhanced LDAR
is used by the Environmental Protection Agency (EPA), describing actions
that plants must take to attain and go
beyond regulatory compliance. Enhanced LDAR covers a number of elements such as quality control, training,
monitoring, repairs and most notably,
equipment upgrades.
This paper will summarize the elements
of a typical, Enhanced LDAR Program
with special emphasis on the element
of Equipment Upgrades. This element
requires the use of valves with performance warranted valve stem sealing
technologies, valve replacement and
preventive maintenance programs.
Also included is an overview of regulations, approved monitoring methods
and consent decrees.

Method 21 leak detection procedure

was rushed and the general attitude
was one of regulatory compliance only,
not finding and eliminating leaks2. For
over a decade EPA has focused on refineries and finalized consent decrees
at nearly all sites in the USA. The face
of LDAR had changed by 2007 and as a
result full time staffs of experienced
persons lead programs, contractors
were chosen for their expertise on a
time and materials basis, Method 21
quality over quantity was stressed and
specialized database software were
owned and maintained by the sites
LDAR group2. Now the enforcement
activities of the EPA are focused on
chemical processing sites. The evolution of LDAR programs has elevated
expectations that LDAR organizations
will seek out and eliminate leaks not
just monitor to attain compliance.
Where LDAR programs come under
enforcement scrutiny Enhanced LDAR
Programs are considered appropriate
injunctive relief.

The Air Pollution Control Act of 1955

was instituted to provide research and
technical assistance related to air pollution control3. In 1962 Rachel Carsons
book, Silent Spring launched environmental activism with its expos of the
affects of pesticides on birds and the
environment. The Clean Air Act (CAA)
of 1963 affected all industrial plant
sites, referred to as stationary sources.
In 1970 President Nixon instituted the
EPA and the CAA was expanded to include mobile sources tail pipe emissions. 1972 saw the institution of the
Clean Water Act. In 1990 the CAA was
amended to include LDAR programs
and the permit process. In this present
day EPA has become more aggressive
with regards to declaring greenhouse
gas (GHG) emission a national health
danger, the validity of air permits in the
state of Texas4 and that new or expanded facilities address GHG concerns5.
Table 1 shows the current regulations
that require LDAR programs.

Introduction
Fugitive emissions from valves are the
largest contributor to the fugitive emissions of any plant processing volatile
organic compounds (VOC) and hazardous air pollutants (HAP). In the late
1990s inspections by the EPA of refineries showed that fugitive emissions
were being under reported by a factor
of 2X1 and that LDAR programs were
deficient. A typical LDAR program in
1990 was staffed with junior part-time
managers, work was contracted to
the lowest bidder, performance of the

Federal Regulations Requiring LDAR Programs with Method 21 Leak Monitoring

40CFR: Protection of the Environment
Part

Description

60

Standards of Performance for New Stationary Sources (NSPS)

61

National Emissions Standards for Hazardous Air Pollutants (NESHAP)

63

NESHAP for Source Categories - Maximum Achievable Control Technology (MACT)

65

Consolidated Federal Air Rule

264

Standards For Owners and Operators of Hazardous Waste Treatment, Storage and
Disposal Facilities

265

Interim Status Standards for Owners and Operators of Hazardous Waste Treatment,
Storage and Disposal Facilities

Table 1

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Garlock Sealing Technologies

LDAR Programs for the

Chemical Processing Industry
Consent Decrees
A consent decree is a negotiated agreement between the government (represented by the EPA and Dept. of Justice
(DOJ)) and the plant site. In return for
not being convicted of guilt the plant is
mandated to pay penalties, perform special projects and perform injunctive relief.
When an LDAR program is found wanting Enhanced LDAR is deemed the appropriate injunctive relief. Two points of
view can emerge during the negotiation
process. The plant can feel that the negotiation is legalized extortion and the consent decree process allows regulation to
be created without the normal diligence
of the process. EPA and DOJ feel that
despite ample information guidance on
the proper development and execution
of a LDAR program it is still a common
area of non-compliance. The decrees of
1998 to 2008 required that formal LDAR
programs with dedicated management
be instituted and all reports be signed by
plant managers. Figure 1 shows the decline in fugitive emissions. The decrees
of the current day are requiring Enhanced
LDAR programs which specify low-leak
valve and packing technologies. Table
2 shows recent decrees that specify
Enhanced LDAR.

Recent Consent Decrees Requiring Enhanced LDAR Programs6,7

Company name
and date

Civil
Penalties

Injunctive Relief

March 31, 2010 Shell

Chemical LP/Shell
Chemical Yabucoa,
Inc.6

1) Enhanced LDAR
2) Relinquishing of permits, facility
shutdown and installation equipment to curtail the emission of
NOx, SO2

August 25, 2009

Vertellus Agriculture
and Nutrition
Specialties, LLC7
July 31, 2009 Ineos
ABS USA
Corporation/Lanxess
Corporation6

Required
Supplemental Environmental Projects

$3.5M

$193K to support
educational environmental activities and
local emergency
organizations.

1) Enhanced LDAR
2) Installation of new incinerator.

$425K

$705K for a two-year

project to upgrade
pumps with technology
that will eliminate
fugitive emissions.

1) Enhanced LDAR
2) Monitoring and equipment
installation for flare, spill reporting
and acrylonitrile processes

$3.1M

None

Table 2

Approved Monitoring Methods

Method 219 uses a vapor analyzer and
the Alternative Work Practice10 (AWP)
uses optical methods. Both comply with
regulations for measuring emissions.
Method 21 allows the use of OVA-organic vapor analyzer or TVA-toxic vapor
analyzer, as shown in Figures 2a, b. Each
component is approached and sniffed
to record the leak concentration at the
seal area of the equipment being monitored. This is the traditional and current
method for monitoring. In December of
2009 the AWP was accepted as regulation. It utilizes infrared (IR) cameras to
view leaks from equipment. The camera

Fig. 1 Fugitive emissions have declined over the last 20 years8.

has not yet been used by any plant site to

fulfill regulatory requirements. The procedure of using AWP allows more components to be monitored over a shorter
period of time. However, the IR camera

survey must be more frequent (every 30,

45 or 60 days) and in addition a Method
21 survey must be done yearly. Figures
3a, b and 4 show the camera in use and
screen view.
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Garlock Sealing Technologies

LDAR Programs for the

Chemical Processing Industry
Enhanced LDAR Program

Figure 4. IR camera view. Black plumes indicate

leakage. Photo courtesy of FLIR Systems, Inc.

A leak detection and repair program is defined by regulations. Those regulations

define which plant equipment (components) are monitored, set the criteria for
what defines a leak, the repair of components to stop leaks, data documentation
and reports. The objective is to find and
eliminate leaks. An Enhanced LDAR program is beyond regulatory compliance.
Table 3 show the elements of Enhanced
LDAR.

Elements of Enhanced LDAR

Part

Figures 2 a, b Technicians are using Method 21 to

monitor leakage. Photos courtesy of Team Industrial
Services.

Figure 3a. Technician is using an IR camera to monitor leakage. Photo courtesy of Sage Environmental
Consultants, LLC.

Figures 3b. Technician is using an IR camera to monitor

leakage. Photo courtesy of FLIR Systems, Inc.

Title

Description

Applicability-General

All requirements are in addition and not in lieu of

existing local, state and federal regulations.

Monitoring Frequency

Depends on equipment type valve, flange, pump,

threaded connection, etc. and leak performance.

Monitoring Methods and Equipment

Mandates use of Method 21 with a toxic vapor

analyzer and data logger.

Leak Detection and Repair Action

Levels

Action levels are the leak levels at which repair is

required.

Leak Repairs

Defines the first attempt and final attempt time

limits.

Delay of Repair (DOR)

Criteria allowing a component to be put on the DOR

list. NOTE: These lists are a focal point of EPA
inspections.

Equipment Upgrades, Replacement

and Improvement

Defines the requirements of low-leak valves and

packing. Defines a plan whereby all valve components are upgraded.

Management of Change

All equipment added to or removed from a plant

must be recorded and evaluated with regard to applicable LDAR requirements.

Training

All company personnel and contractors responsible

for monitoring, maintenance, repairs and any LDARrelated activities must be trained within six months
of initiation of Enhanced LDAR.

Quality Assurance and Control

Monitoring data must be certified as accurate and

collected according to the standard. Once a quarter
monitoring data is randomly checked to assure
consistency and compliance.

LDAR Audits and Corrective

Actions

Third-party audits conducted initially and annually.

Documentation of the corrective action plan, course
of action and outcomes must be submitted to EPA.

Certification of Compliance

To all applicable regulations, completion of corrective actions and that all equipment under regulation
is documented in the program.

Recordkeeping

Original records of all LDAR audits and documentation of Enhanced LDAR Program compliance must
be retained.

Reporting

Annual reports that document compliance with the

Enhanced LDAR Program are filed at the specified
time periods.

Table 3

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Garlock Sealing Technologies

LDAR Programs for the

Chemical Processing Industry
Part G Equipment Upgrades,
Replacement and Improvement
Part G is the most progressive and demanding part of Enhanced LDAR. It is
the first time this degree of definition and
prescriptive action has been targeted toward valve leaks. Part G requires valve
replacement and improvement with
low-leak valve and packing technologies.
These low-leak technologies must be
warranted for performance of 100 ppm
and or come with test documentation
that exhibits the same. Enhanced LDAR
raises the bar from 500 ppm acceptability levels to 100 ppm. It exemplifies the
spirit of LDAR that EPA wishes to promote, that is, to actively look for, find and
stop leaks.
Originally three alternatives were developed:
Alternative 1 Preventative
Maintenance and Replacement
Action Plan (PMRAP)

warranty for 5 years able to deliver 100

ppm leak performance and/or a report
from a generally accepted test procedure
that demonstrates such performance

can be achieved (Table 4). Currently the

regulators are considering more definition with regard to test methods.

Test methods that could be, generally accepted procedures and good
engineering practices.
Part

Description

ISO 15848-1 (International Organization

for Standardization)

Industrial valves - Measurement, test and qualification

procedures for fugitive emissions - Part 1: Classification system and qualification procedures for type
testing of valves

API 622 (American Petroleum Institute)

Type Testing of Process Valve Packing for Fugitive

Emissions

Chevron Texaco GR-500 App. V

Instruction for Selecting, Installing and Use of Packing

in Refinery Equipment

Shell MESC SPE 77/300

Procedure and Technical Specification for Type Acceptance Testing (TAT) of Industrial Valves

ISA/ANSI 93.00.01 (International Society

of Automation)

Standard Method for the Evaluation of External Leakage of Manual and Automated On-Off Valves

FCI 91-1-1997 (Fluid Control Institute)

Standard for Qualification of Control Valve Stem Seals

VDI 2440 (Verein Deutscher IngenieureAssociation of German Engineers)

Reducing Emissions from Mineral Oil Refineries

Table 4

Alternatives 2 and 3 Component

Replacement, Improvement and
Elimination Programs
Alternative 1 has never been written into
a consent decree and probably never
will. It defines a Preventive Maintenance
and Replacement Action Plan (PMRAP)
and requires such actions as a leak trend
analysis. This analysis would identify
which components leak and indentify the
causes. Trend analysis would indentify
recurring components and causes. The
analysis would direct fixes to correct repeat problems. Trending would identify
components that were in compliance but
weak performers, these would be targets for repair or replacement. This is a
very holistic proactive approach.
Alternative 2 has been invoked in consent
decrees. It is more prescriptive than Alternative 1. The defining terminology of
these rules are, low-leak, packing and
valve technology. Low-leak is defined as
a valve with stem packing that carries a

Warranties are generally subject to valve conditions and installation practices.

Figures 5 and 6 are examples of a typical warranty and test data.

Figure 5: Typical low-leak packing warranty.

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Garlock Sealing Technologies

LDAR Programs for the

Chemical Processing Industry

Figure 6: Typical data from a low-leak packing test report.

Conclusions
Under Part G if a valve stem packing is
leaking more than 250 ppm it must be repaired or replaced with low-leak technology within 30 days or at the next maintenance shutdown. If it is found to be
leaking between 100 ppm and 250 ppm
it must be repaired or repacked according to the equation shown in Table 5.
This is the, Enhanced, in Enhanced
LDAR. The requirements to use lowleak technology and to replace 10% of
the qualified valve population leaking between 100 ppm and 250 ppm are beyond
any current regulations anywhere in the
USA. This is mandated preventive LDAR
aimed at getting the entire population of
regulated components well below the
screening value of 250 ppm. Alternative
3 of Part G is the same as Alternative 2
except instead of 10% of the qualified
valve population, 20% (replace 0.10 with
0.20 in the equation in Table 5) must be
replaced or repaired.

nect types are also addressed in Part G.

In the case that a connection if found to
be leaking above 250 ppm it must be repaired or replaced with technology that
in the judgment of the plant will attain a
leak performance below 250 ppm. This
is similar guidance to valve stem seals
except plant judgments are accepted
and warranties with test reports are not
required.

Enhanced LDAR pushes the limits to 100

ppm as the new standard for valve stem
seals. LDAR remains a National Air Toxic
Enforcement Priority11. After spending
the last 10 years focusing on refineries,
EPA investigators and enforcers are concentrating on chemical process plants.
Enhanced LDAR will be the norm wherever there are issues with LDAR programs.

Equation for the Number of Valves to be Repacked or Replaced Annually

VTBRR = 0.10 x (VT VDOR VPRR VPR)
VTBRR

Valves To Be Replaced or Repacked annually

VT

Valves Total number of valves in the process unit.

VDOR

Valves on Delay Of Repair

VPR

Valves Pending Repair

VPRR

Valves Previously Replaced or Repacked with low-leak technology

Table 5

Connectors that are flanged, threaded,

compression, cam-lock and quick-con|5

Garlock Sealing Technologies

LDAR Programs for the

Chemical Processing Industry
Referenced Notes:
1) EPA-305-D-07-001, Leak Detection and Repair-A Best Practices Guide,
(2007), Appendix E
2) LDAR-Past, Present and Future A presentation by Graham E. Buzz
Harris of Sage Environmental Consulting, LP at the Air & Waste Management
Association Conference, April 26, 2007
3) Origins of Modern Air Pollution Regulations,
http://www.epa.gov/eogapti1/course422/apc1.html

Jim Drago, P.E.

Manager, Business Development
Garlock Sealing Technologies,
Palmyra, NY
Email: jim.drago@garlock.com
Phone: 1-315-597-3070

EPA

website,

4) EPA rejects air permits of 122 Texas plants - Facilities must reapply; irate Perry
says jobs, energy at risk, July 1, 2010 - Houston Chronicle, R.G. Ratcliffe of
the Austin Bureau
5) Proposed Rules on Clean Air Act Permitting for Greenhouse Gas Emissions,
August 12, 2010, http://www.epa.gov/NSR/actions.html#2010
6) EPA Cases and Settlements - http://cfpub.epa.gov/compliance/cases/
7) EPA and DOJ reach agreement with Vertellus on Clean-Air Violations,
http://yosemite.epa.gov/opa/admpress.nsf/0/4090430D9914B1B18525761D0
058A5C7
8) EPA Toxic Release Inventory (TRI) - http://www.epa.gov/triexplorer/
9) Method 21 - Determination of Volatile Organic Compound Leaks,
http://www.epa.gov/ttn/emc/promgate/m-21.pdf
10) Alternative Work Practice To Detect Leaks From Equipment,
http://www.tceq.state.tx.us/assets/public/implementation/air/rules/
ldar/2006_17402.pdf
11) Background Paper for Candidate National Enforcement Priority: Air Toxics,
January 2010, http://www.epa.gov/compliance/resources/publications/data/
planning/priorities/fy2011candidates/fy2011candidate-air.pdf

General References:
1) Burgard, Drago, Hurley, What is the next Generation of LDAR and How to Get
There?, 9th Annual ISA Fugitive Emissions LDAR Symposium, May 2009,
Austin, TX, USA
2) Proceedings of the 10th Annual ISA Fugitive Emissions LDAR Symposium,
May 2010, San Antonio, TX, USA
3) Siebenaler, Shane (Southwest Research Institute), Testing Standards for Low Leak Technology, 10th LDAR Symposium
4) Ross, Bill (Chevron Corp.), Fugitive Emissions, American Petroleum Institute
SCOPV Spring 2010 Minutes Attachment
5) Drago, Jim, Optical technologies monitor leak detection, fugitive emissions,
Plant Engineering, June/July 2010
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