June 3, 2019
Can Your LDAR Database Survive an EPA Section 114 Information Request (114IR)?
David Ranum, TRICORD Consulting, LLC
Three reasons why LDAR databases are the most requested data in 114IR: 1) easy to ask for, 2) easy enforcement, and 3) more bang for the EPA buck. The complexities of managing an LDAR program are only exacerbated by the knowledge of all information or by compliance, or lack thereof, which are stored electronically in one place for all to see. With the rise of EPA consent decrees and the requirement for electronic storage of monitoring data, we have also seen an apparent increase of 114IR focusing solely on database records. This presentation will discuss tried-and-true successful approaches based on twenty years of experience in responding to LDAR 114IR along with best practices for the management, storage and quality control checks of your LDAR compliance data.