Leak detection and repair (LDAR) programs live and die by their details. As years pass after the implementation of an LDAR program, and the staff involved either retire or move on to other assignments, it is easy for those details to start to lose some vigor. With multiple process changes and years down the road, maybe your LDAR program requires a "check-up."
Traditional Gap Assessment Process
One service many of our chemical, petrochemical, pharmaceutical, and oil and gas clients find valuable is an LDAR Gap Assessment, which reviews your LDAR program with regards to its level of compliance. Traditionally, these gap assessments include site visits that last from one to five days, in which we examine your current LDAR program's robustness. We provide documentation and comments on various items as being good/great practices or areas that require attention. Our years of experience enable us to focus on items frequently cited in past enforcement actions for the oil and gas, refining, and chemical industries. The U.S. Environmental Protection Agency (EPA) expects facilities in those industries to have already addressed these LDAR program concerns. At the close of the gap assessment, we discuss the results of the Gap Assessment with the facility EHS manager. After the assessment, we provide a report that highlights the work-practices that may require immediate or long-term improvement. Similar assessments can be done for other regulatory requirements, including but not limited to NSPS NNN, NSPS RRR, HON, MON, Pharma MACT, BWON, etc.
Gap Assessments during COVID-19
In light of COVID-19, in-person site visits are being minimized, but EPA and state/local agency enforcement continues. EPA has implemented a temporary policy with the understanding that the COVID-19 pandemic may impact facilities (please see Trinity summary of EPA temporary policy for additional information). EPA has provided notice that the temporary policy terminates in its entirety at 11:59 pm ET, August 31, 2020. A way to continue to review compliance and minimize exposure of COVID-19 is to conduct desktop gap assessments. Additionally, some field work may be done virtually, especially if facilities allow the utilization intrinsically-safe tablets and computers with cameras or allow other devices with cameras. There are a few things that can't be replicated virtually such as comparative monitoring, which is normally an optional item in gap assessment, but a requirement in consent decree-required third party LDAR audits. Most all other aspects (e.g., records review, database reviews, and interviews) of the LDAR gap assessment can be completed virtually, some facets (e.g., component identification verification and LDAR technician observations) will suffer efficiency loss, but can still be done.
Additional Support through the Process
Trinity and its Chemical Sector Services (CSS) group have extensive experience in helping our refining, chemical, petrochemical, pharmaceutical, and oil and gas clients to identify and address their LDAR compliance issues. We have supported numerous facilities that have asked to better understand their current state of compliance, and provided them with levels of assurance to make tough compliance decisions. Sometimes, as a result of these analyses, Trinity has helped facilities self-report any discoveries and continue our assistance through negotiating allegations presented in Findings of Violations (FOVs), and with the issuance of a consent decrees.
For those facilities already within the EPA enforcement timeline, we have also provided a pre-inspection gap analysis, assistance during the EPA inspection, and/or helping with the facility's response to EPA's initial FOV.
Whether your company is looking for an initial gap assessment, a full compliance audit, or an FOV response, Trinity's CSS team have the regulatory understanding and experience in enforcement assistance to meet your current and future needs. Please contact Dan Smith, Courtny Edge, or Inaas Darrat if you have any LDAR questions or wish to discuss conducting an LDAR gap assessment.