Tuesday, June 9, 2009

Do the decisions that were made a decade ago effect your compliance today? This presentation will provide a summary of some of the best practices for Leak Detection and Repair seen throughout North America, by Colin K. Sheffield, Corporate Subject Matter Expert for Valero Energy Corporation.

An LDAR program presents thousands of opportunities for compliance annually. LDAR continues to be a top enforcement priority for the EPA, both civil and criminal. EPA released their LDAR Best Practices Guide in October 2007, which gives insight into enforcement target areas. This presentation discusses major compliance challenges surrounding the LDAR program, and where to focus your LDAR resources to guarantee compliance. Data analysis and field assessment strategies will be presented to design a program to assure your program can pass regulatory, internal, and third party audits.

The EPA finalized the Alternate Work Practice (AWP) for Smart LDAR on December 15, 2008, culminating almost a decade of development and demonstrations. The AWP allows facilities complying with Federal LDAR regulations in 40 CFR Parts 60, 61, 63, and 65 to use optical imaging, along with a single Method 21 inspection per year, as an option to use of Method 21 at normal frequencies. While it is great to have a final AWP, there are still barriers to application of the AWP for facilities with a state LDAR regulation or a Consent Decree. There are also a number of complexities in designing an AWP program, from load leveling and compliance demonstration to stream applicability and daily demonstration release rates. This presentation will review the AWP requirements, identify near-term niche applicability candidates, and offer some project experience for design of a Smart LDAR program under the final AWP.

How to Manage a Successful LDAR Program will give each attendee a more accurate knowledge of how to manage a successful LDAR program and how to focus on compliance. The information presented will assist facilities in being able to determine how to document and demonstrate the compliance of their LDAR program. We will review the most common areas of compliance exposure involved in managing an LDAR program. We will also cover how to prepare for an LDAR audit on a daily basis so that the facility is always audit ready. The focus of the information presented is to illustrate how to manage a compliant LDAR program and minimize compliance exposure.

With the new Alternate Work Practice (AWP) signed and soon to be put in place, new opportunities are available to the petroleum industry. Smart LDAR is a more efficient way of conducting leak surveys, both economically and environmentally. This presentation will provide information on the benefits of this new technology.