LDAR Compliance

LDAR Audits | Regulatory Interpretations | LDAR Personnel Training | LDAR Software | LDAR CBT | Cooling Tower Testing | SOPs | Response Factor | Bagging

LDAR Audits

EnRUD Resources, Inc. has the experience and LDAR regulatory knowledge to perform any of the following audits listed below:

• Texas HRVOC Audit

The state of Texas has recognized the necessity to control highly reactive volatile compounds (HRVOC) within the non-attainment areas where ozone creation is a great concern. One of the state's answers to the problem is focusing on the control of these compounds, hence the state of Texas has adopted new control requirements (Chapter 115, Subchapter H). Within Subchapter H, a new section for controlling highly reactive VOCs from equipment leaks was added, Subchapter H: Highly-Reactive Volatile Organic Compounds, Division 3. This division addresses the HRVOC fugitive emission aspect of the regulation. When creating this division, the state of Texas also recognizes the importance of ensuring that the intent of the regulation is not being compromised by including an audit section. Every facility regulated by the new HRVOC rule in the Houston/Galveston non-attainment areas will be required to perform yearly an independent third party audit. The audit is comprised of three segments: 1) A field audit 2) Comparative monitoring & Method 21 procedure adherence 3) Review of previous monitoring data. The field audit will be the review of the proper procedure for the tagging of leaking valves that are placed on shutdown. The second aspect, comparative monitoring, dictates when and how many valves will be selected randomly based on leak rates. The third aspect will require an individual with database and LDAR regulatory knowledge to evaluate the monitoring process.

• Comparative Monitoring

Comparative Monitoring is selecting components in a monitoring program based on a class/classes and a pre-determined percentage. The pre-determined percentage can be decided by a facility or if the comparative monitoring is a regulated comparative monitoring, then the regulation will provide the percentage. Components are selected randomly and then monitored by experience monitoring personnel. A report providing the findings and leak percent calculations will be provided to the customer. Comparative monitoring is a quality assurance tool that allows customers to compare the leak percentages found against their contractor's or in-house's monitoring leak percents.

• LDAR Customized

  Customers can contract EnRUD to perform customized LDAR audits. Customize audits allow customers to focus on problem area by allowing them to select the kind of audit that best fits the facility. There are many aspects to a LDAR program and each customer has different strengths and weakness. With this customized audit, a customer can change a program's weakness into a strength. To get ideas on selection of items to customize your audit, click here for Third Party Audit Guidance by EnRUD Resources, Inc.

• LDAR Tagging

LDAR tagging audit is reviewing the tagging of the equipment in the field using P&IDs and a master component list provided by the LDAR data management program. The audit requires experience personnel who can read marked up color coded P&IDs and LDAR regulatory knowledge. This knowledge is necessary to ensure and verify that the proper equipment is identified and coded correctly in the master component database. EnRUD has experience and knowledgeable LDAR personnel who have performed LDAR tagging projects.

• Consent Decree

  Many refineries have signed a Consent Decree with the EPA. Within these Consent Decrees, the EPA added a section for LDAR audits. The refineries have to contract a third party auditor to perform an audit on their facility based on specified requirements listed in their Consent Decree. EnRUD has the LDAR experience and the regulatory knowledge to perform these audits.

• LDAR Contractor

• Simulated NEIC

  The NEIC (compliance enforcement, branch of the EPA) every year perform audits on selected facilities to ensure compliance. These audits are rigorous and cover of many areas. One of the areas that the NEIC covers is LDAR. A way to prepare an EPA LDAR audit is to go through a simulated NEIC audit. This audit is much like the one that the facility would receive from the NEIC. If you haven't had the fortunate opportunity to go through a NEIC audit then this is the opportunity to prepare for it. EnRUD has the LDAR experience and the regulatory knowledge to perform these audits.

Browser Based Regulatory Interpretations

• 40 CFR 60 - VV
• 40 CFR 63 - GGG, MMM
• 40 CFR 61 - V
• 40 CFR 264 - AA, BB, CC
• 40 CFR 63 - H, UU
• States - Louisiana & Texas

LDAR Personnel Training

• EPA Method 21

EnRID provides in depth training on the EPA Method 21 that virtually every LDAR regulation references. EPA Method 21 is the method for proper selection of analyzers, proper calibration and certification of analyzers, and proper monitoring procedure on how to monitor equipment. In this training class, a person will taught how to select an instrument, how to calibrate an instrument, how to certify the instrument, and how to monitor equipment with an instrument. The training also discuss how and where to monitor on several class and types of equipment. For information on computer base training for EPA Method 21, click here.

• LDAR Introduction

  For first time beginners into the LDAR (leak detection and repair) industry, this training will introduce new comers basic information about the Leak Detection and Repair industry. The training covers EPA Method 21, regulations, database management programs, instrumentation, and dataloggers.

• Federal & State Regulations
• LDAR Technician I & II
• TVA-1000B Analyzer
• LDAR Coordinator
• LeakTracker™ System 200
• LDAR Audit Preparation

LDAR Software Services

LDAR CBT

• EPA Method 21

EnRUD offers CD-ROM Based Training Covering EPA Method 21. Provides in depth training on the EPA Method that virtually every LDAR regulation references. The training packages contain numerous equipment diagrams and bitmaps and animated gif's that show your personnel how and where to monitor. Detailed procedures guide you through how and why you perform daily calibrations and the quarterly performance evaluations on the portable gas detectors. The training package not only clearly explains EPA Method 21, it also gives real world experience to the application of the Method.

• LeakTracker™ System 200 / M.A.R.S.

  EnRUD offers LeakTracker™ 200 System CD-ROM based training covering the M.A.R.S.® Software. This training package familiarizes your personnel on how to use the M.A.R.S. software. Detailed procedures will guide you through the M.A.R.S. introduction and setup, to configuration, uploading & downloading, and how to use the Alpha & other functions keys. This training package will also expose personnel to the database structures used within M.A.R.S. Overall, this is the FastTrack to learning all there is needed for the M.A.R.S. Software

Cooling Water Tower Testing

Cooling Water Tower Testing As of January of 2003, the TCEQ has adopted a new modified El Paso method (Appendix P). In this modified method certain criteria have to be met before this method can be utilization and a QA/QC procedure has been added which was not provided in the previous El Paso method.

Previously, the FID analyzer that was utilized could be of analog type readouts that were design to read much higher concentration and not design to measure the lower concentration levels typically found in cooling water. FID analyzers used in conjunction with the new method must be a digital readout (readable to 0.1 ppmv), must be able to calibrate to low methane concentrations (e.g. 5, 10 ppmv) and have a sampling rate less than 2000 ml/min.

The QA/QC section of the method now requires semi-annually certification of specific components of the cooling water tower apparatus. These components are: air rotameter, water rotameter, and the temperature gauge.

EnRUD Resources, Inc. (EnRUD) has the experience and the equipment to perform necessary QA/QC on the cooling tower water apparatus and the knowledge to perform cooling tower water testing with the procedure incorporated in the TCEQ sampling procedures manual. For facilities that utilize continuous emission monitoring systems (CEMS), EnRUD can be contracted to be your facilities backup in the event that your CEMS fails.

• Cooling Water Tower Testing Apparatus

The cooling water tower testing apparatus is utilized in performing the new El Paso method (Appendix P) on cooling water towers in the state of Texas. This testing apparatus is a professionally built and meet the specification requirements of the TCEQ Appendix P for testing cooling water towers.

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• Cooling Water Tower Testing Apparatus

Certification TCEQ's Appendix P requires the air/water rotameters and temperature gauge to be certified on a semi-annual basis. The air/water rotameter and temperature gauge are shipped or delivered to EnRUD to be certified by experienced personnel in accordance with Appendix P. Certification papers are provided to demonstrate compliance.

SOPs

Response Factor

Bagging

LDAR Audits | Regulatory Interpretations | LDAR Personnel Training | LDAR Software Services | LDAR CBT
SOPs | Response Factor | Bagging