What is Leak Detection and Repair (LDAR)?
Leak Detection and Repair (LDAR) is the process of identifying leaking equipment and repairing it to minimize emissions.
Regulators, like the Environmental Protection Agency (EPA), require manufacturers to follow LDAR guidelines. However, an LDAR program isn’t just to ensure regulatory compliance. It can also save manufacturers lots of money.
In this post, we walk you through important details about Leak Detection and Repair and explain how you can set up an LDAR program in your facility.
EPA Regulations for Leak Detection and Repair (LDAR)
The EPA issues the LDAR regulations in the United States. The regulations address various Leak Detection and Repair rules for manufacturers. For example, 40 CFR Subpart OOOOa issues LDAR regulations for oil and gas companies. The law regulates:
- Survey frequency
- Types of facilities required to follow LDAR regulations
- Required LDAR training
- LDAR maintenance protocols
- Required data storage and reporting
LDAR aims to minimize volatile organic compounds (VOCs) and hazardous air pollutants (HAPs). You can detect VOC leaks using instruments such as vapor analyzers or sound, smell, and visual inspections.
However, even when a device, like a vapor analyzer, detects a leak, the equipment may not necessarily violate EPA regulations. The leaks must be detected above a specified EPA-regulatory threshold to be in violation.
Local agencies and states may define what constitutes a leak differently. As a result, the leak threshold can differ across regulations. Therefore, it’s best to create a Leak Detection and Repair program that complies with the most stringent regulatory requirements.
LDAR and Volatile Organic Compounds
According to the EPA, “Volatile organic compounds are compounds that have a high vapor pressure and low water solubility.” Examples include trichloroethylene, methyl tert-butyl ether (MTBE), and chloroform.
VOCs can react with other gasses in the air and form air pollutants. While not harmful, some can have short- and long-term adverse health effects. The EPA works to minimize their emission.
4 Steps to Setting Up an LDAR Program
Setting up and implementing a Leak Detection and Repair program increases compliance. While it costs money to set up an LDAR program, what makes LDAR programs worth investing in are the cost savings that follow.
A small leak in a minor component may not seem like much. However, that leak can cost a lot of money over time. An LDAR program ensures efficient use of resources. This translates into a positive ROI on the money invested in implementing the program.
In addition, you can add LDAR-related tasks to your existing physical asset maintenance program. Technicians can check equipment for LDAR as they do proactive maintenance. This saves time.
Let’s get started: Implementing an LDAR program is a four-step process.
Step 1: Label Your Components
You need to identify components from which to collect data and where to maintain the collected data for potential future regulatory audits.
Start by physically labeling components with a barcode and/or an identification number. Also, mark the identification numbers on the piping and instrumentation diagrams (P&IDs).
Ideally, manage all the Leak Detection and Repair data on a computerized maintenance management system (CMMS). If you already use a CMMS, create asset/parts records on the system and enter their identification numbers.
To do this, we suggest creating LDAR preventive maintenance work orders to monitor and maintain the equipment.
In a CMMS like MaintainX, work orders are available in real-time to alert technicians and management of failures and provide an audit trail of all LDAR work for regulators.
Step 2: Identify Leak Thresholds
As discussed earlier, not all leaks constitute a violation. Equipment is in violation only when the leak exceeds the established regulation levels.
Remember, local agencies and states may have different requirements. As a result, adhere to the strictest rule. Also, you may want to maintain an additional margin of safety to ensure the leak levels don’t abruptly breach the threshold. Such a breach can cause unplanned downtime.
For each monitored component, compile the information on leak levels in your CMMS. Be sure to cite the regulation you are following. This will aid technicians in quickly determining if a component needs a repair.
Step 3: Monitor Components
At this point, you are ready to implement your LDAR proactive maintenance program. Focus on surveying components on the frequency required by the regulation—although you may choose to survey components more frequently.
Use EPA Method 21 as a reference to prepare the LDAR monitoring schedule and process.
Once you’ve created a schedule and assigned work orders, technicians can test components based on the data you entered in the CMMS.
Components that pass the test should be marked as such. You should initiate a work order to repair equipment if a component fails. The CMMS will store these records so you can review them as needed. In MaintainX, a new work order is created automatically to repair a piece of equipment that fails.
Step 4: Record Data
Data is critical for audits. The more efficiently you store data, the easier the audit will be. The EPA recommends storing LDAR data electronically, making a CMMS an excellent choice.
In addition to making audits easier, storing data on a CMMS can significantly reduce the time required to manage documents. Less time spent managing data means more time to be productive elsewhere.
CMMS also ensures you have access to all the data you need when you need it. Instead of going through piles of paper, you can just look up the component IDs, test results, and repairs from the CMMS within seconds. In addition, MaintainX features a robust reporting module for real-time reports and KPIs.
Make LDAR Audits Easier with MaintainX
Database reviews are the backbone of an LDAR audit. The database should have data on monitoring schedules, test results, repair timelines, and delay of repair (DOR) reports, among other required data schedules. A CMMS like MaintainX ensures all your LDAR data is available in real-time at your fingertips. Of course, other benefits to using a CMMS for managing LDAR data include reduced administrative load, centralized access to data, and preventive work orders.