The Care and Maintenance of an LDAR Program Subject to KKK

1. The Care and Maintenance of an LDAR Program Subject to KKK Dr. Frankie Wood-Black Trihydro Corporation

2. Outline • Elements of an LDAR program • Specific requirements for gas plants • Key areas of focus for gas plants • Tips and best practices

3. Elements of an LDAR Program Identifying Components Leak Definition Monitoring Repair Recordkeeping

4. Elements of an LDAR Program Understanding the Applicable Regulations Management of Change Identifying Components Leak Definition Monitoring Repair Recordkeeping

5. Elements of an LDAR Program Understanding the Applicable Regulations Management of Change Identifying Components Leak Definition Monitoring Repair Recordkeeping

6. Elements of an LDAR Program Understanding the Applicable Regulations Management of Change Identifying Components Leak Definition Method 21 Visual, Olfactory, Sound Alternative Work Practice Sensors Monitoring Repair Recordkeeping

7. Elements of an LDAR Program Understanding the Applicable Regulations Management of Change Identifying Components Leak Definition Method 21 Visual, Olfactory, Sound Alternative Work Practice Sensors Monitoring Repair Timing and DOR Recordkeeping

8. Elements of an LDAR Program Understanding the Applicable Regulations Management of Change Identifying Components Leak Definition Method 21 Visual, Olfactory, Sound Alternative Work Practice Sensors Monitoring Repair Timing and DOR Recordkeeping Reporting

9. LDAR Regulations that Apply to Gas Plants • NSPS Subpart KKK – refers back to NSPS Subpart VV • NSPS Subpart OOOO – refers back to NSPS Subpart VVa • Part 63 Subpart HH – equipment leak standards are included in 63.769 and refers back to Part 63 Subpart H, NSPS Subpart KKK and Part 61 Sections 61.241 through 61.247 • Part 63 Subpart HHH – Applies to Natural Gas Transmission and Storage Facilities

10. Interesting considerations • Leak definition tracks with VV and VVa • Assumed to be in VOC or Wet Gas service unless proven otherwise • NSPS KKK and NSPS OOOO – refer to compliance with 60.482-1 and 60.482-1a (a), (b), and (d) – NOT (e) – These are the general standards and (e) is the 300 hr/yr exemption • Provision for pressure relief devices (PRDs) – Monitored within 5 days after release unless it is located at a non-fractionating plant that is monitored by non-plant personnel – but shall not operate for more than 30 days after a release without monitoring • Part 63 Subpart HH – has a modified definition of major source • Part 63 Subpart HH – also applies to area sources – particularly each triethylene glycol (TEG) dehydration unit

11. Areas of focus • Definition of process unit • Equipment identification • Consistency of identification • Management of change • Reconstruction and/or modification (NSPS, NSPS KKK or NSPS OOOO) • Delay of repair • Quality assurance and quality control of data

12. Model Plant Source: http://en.wikipedia.org/wiki/File:NatGasProcessing.png

13. Tips and Best Practices • Know the regulations that apply • Understand your “process units” • Robust management of change (to include reviews for modification and/or reconstruction) • Document, Document, Document Understand that any point in the program where there is a transfer of responsibility is a potential pitfall.