Leak Detection and Repair (LDAR) programs cannot be implemented and sustained by a single individual. It takes a team to ensure that compliance is maintained appropriately. Typically, the traditional LDAR team is considered to be the Environmental Department and the LDAR technician(s). However, every person working at a site that has a LDAR program in place has LDAR responsibilities that should be communicated to them properly. Closing the loop on communication between all parties involved in the LDAR program is key to ensuring compliance.
Key items in LDAR programs that are routinely overlooked due to poor communication include not reporting or repairing items visually found to be leaking, components added or removed in the field which may or may not be documented in the Management of Change (MOC) program, identification of Open-Ended Lines (OELs), and items on Delay of Repair (DOR) not being fixed during Process Unit Shutdowns. Not only are these items that are frequently overlooked due to lack of communication, but these are considered "low-hanging fruit" deviations for USEPA inspections and third-party LDAR audits as they are easily identifiable.
All personnel should be made aware of their LDAR responsibilities and clear channels for conveying information to dedicated LDAR staff should be suitably advertised. Some best management practices for "closing the loop" in LDAR include the following:
- Have clearly defined roles/responsibilities for all site personnel.
- Develop a Written LDAR Manual with appropriate site procedures documented that is accessible to all employees.
- Provide annual training or at a minimum once every three years on LDAR responsibilities and procedures for the site.
- Create a routine opportunity to remind personnel of LDAR activities/responsibilities and allow for reporting potential compliance issues noted in the field (may be able to incorporate this practice to an existing daily or weekly meeting to touch base with personnel).
- Develop "cut sheets" with LDAR information specific to different personnel that can be posted in common areas (e.g., break room, control room, etc.).
- Conduct random internal observations of LDAR activities with the initial observation being conducted by an LDAR subject matter expert.
- Developing and documenting internal Quality Assurance/Quality Control (QA/QC) procedures.
- Creating communication flow charts which clearly relay roles and responsibilities.
These practices, among others, will assist with closing the loop in communication and developing a site-wide comprehensive LDAR compliance program. Trinity has experience with assisting facilities with developing their LDAR programs with the development of site specific flow charts and procedures, LDAR training, as well as third party auditing and preparation of LDAR manuals. If you have an immediate concern or would like assistance with your LDAR program, please contact Inaas Darrat at (713) 552-1371 Ext. 209.