Third Party Audit Guidance by EnRUD Resources, Inc.

1.0 PRE-AUDIT ACTIVITIES

Auditor shall follow the pre-audit activities:

1.1 Review of all Federal, State and Local regulations that apply to the audited facility.

1.2 Utilization of a tool such as a pre-audit questionnaire to request all needed information to prepare for the on-site audit activities.

1.3 Development of an interview schedule to identify and coordinate the refinery resources that will be interviewed as part of the audit.

1.4 Confirm complete understanding of the scope, objectives and timeline for the audit.

1.5 Prior to any work at each refinery, the Auditor must satisfy any contractor requirements for entry such as Contractor orientation training, drug screening or any other mandated requirements. Time to meet these requirements will be built into the audit.

1.6 Prior to the start of the audit, the auditor will conduct an opening conference to outline the work that will be conducted during the audit. As part of this conference a daily update time will be announced so interested parties can listen to a summary of the day's auditing activity. Also a closing conference will be announced to provide a final update on the audit prior to the Auditor leaving the site.

1.7 The Auditor shall provide the monitoring equipment to be used for the comparative monitoring activity. The Facility shall be informed of the type of equipment to be used prior to the audit. Only intrinsically safe rated equipment will be acceptable. The Auditor shall also have a backup plan for providing replacement-monitoring equipment should the original equipment fail.

1.8 An agreement on calibration gases shall be reached prior to the audit. If the Auditor is to provide the gases they must be on site and ready for use prior to the audit. An internal approval process may be required prior to bringing these gases on site.

1.9 Establishment of a monitoring plan for the comparative monitoring will be agreed upon prior to the audit.

2.0 REVIEW OF WRITTEN LDAR PROGRAM

Audit shall include a review of the facility written plan including but not limited to:

2.1 Program was established within 180 days after the Date of Entry.

2.2 System is in place to ensure continuing compliance with written plan changes and updates.

2.3 Establishment of a refinery-wide leak rate goal on a unit-by-unit basis and an evaluation of the performance to meet this goal.

2.4 The identification of all equipment in light liquid and/or in gas/vapor service that has the potential to leak VOCs, HAPs and VHAPs.

2.5 Procedures for identifying leaking equipment.

2.6 Procedures for repairing and keeping track of leaking equipment.

2.7 The process for evaluating new and replacement equipment to promote consideration and installation of equipment that will minimize leaks and/or eliminate chronic leakers.

2.8 A definition of "LDAR Personnel" and the process for accountability, and identify the person or position that will be the "LDAR Coordinator". Verify the person has the responsibility to implement improvements to the LDAR program.

2.9 Procedures (e.g., a Management of Change program) to ensure that components subject to LDAR requirements added to each refinery during maintenance and construction are integrated into the LDAR program.

2.10 Procedures to ensure sensory leaks are reported and acted upon within the appropriate timeframe.

3.0 REVIEW OF TRAINING PROGRAM

Audit shall include a review of the facility's training program. The Auditor's judgment based on pre-existing experience and benchmarking with other programs shall be the recommended standard for the evaluation. Work shall include but not be limited to:

3.1 Is a proper Training Program established?

3.2 For the facility employees newly assigned to LDAR responsibilities: Has the Facility required and provided training prior to employee beginning such work?

3.3 For the Facility employees assigned LDAR responsibilities, such as monitoring technicians, database users, QA/QC personnel and the LDAR Coordinator: Has the Facility provided and required completion of annual LDAR refresher training?

3.4 For all other the Facility employee operations and mechanical personnel, such as operators or mechanics performing valve packing and designated unit supervisor reviewing for delay of repair work: Has the Facility provide and required completion of an initial training program that includes instruction on aspects of LDAR that are relevant to the person's duties? Was refresher training for these personnel performed in a timely matter?

3.5 If contract employees are performing LDAR work, has the contractor provided its training information and records to the Facility?

4.0 REVIEW OF AUDIT PROGRAM

Audit shall include a review of the facility's audit program including but not limited to:

4.1 Is there a LDAR audit program?

4.2 Are processes and procedures in place to correct non-compliance issues and are written records maintained of this activity?

4.3 Has the LDAR audit program been integrated into the existing facility audit and corrective action program?

5.0 REVIEW FIRST ATTEMPT AT REPAIR

Audit shall include a review of the facilities first attempt at repair including but not limited to:

5.1 Has the Facility implemented "first attempt at repair" using the appropriate leak rate definitions? 5.2 (Optional) Does the Facility have a procedure to evaluate the "first attempt at repair" program to determine if repairs improve or hamper leaks?

6.0 REVIEW LDAR MONITORING FREQUENCY

Audit shall include a review of the facility's monitoring frequency including but not limited to:

6.1 Has the Facility implemented the proper leak definitions on equipment types basis on Local, State, and Federal regulations?

6.2 Has the Facility implemented the proper monitoring frequencies based on the current applicable regulations?

7.0 REVIEW ELECTRONIC MONITORING, STORING AND REPORTING OF LDAR DATA

Audit shall include a review of the facility's monitoring frequency including but not limited to:

7.1 Has the Facility continued to maintain an electronic database for storing and reporting LDAR data?

7.2 Does the Facility use dataloggers and/or electronic data collection devices during all LDAR monitoring?

7.3 Has the Facility or its designated contractor used its/their best efforts to transfer, on a daily basis, electronic data from electronic datalogging devices to the electronic database?

7.4 For all monitoring events in which an electronic data collection device is used, has the collected monitoring data included calibration information, operator identification, and instrument identification? 7.5 If the Facility used paper logs where necessary or more feasible (e.g., small rounds, re-monitoring, or when dataloggers are not available or broken), was a record, at a minimum, the identification of the technician undertaking the monitoring, the date, monitor reading, and the identification of the monitoring equipment captured?

7.6 Does the Facility have a reliable backup system for their data management software?

8.0 REVIEW QA/QC OF LDAR DATA

Audit shall include a review of the QA/QC of LDAR data including but not limited to:

8.1 Does the Facility have a procedure to ensure a quality assurance/quality control ("QA/QC") review of all data generated by the LDAR monitoring technicians?

8.2 Does the contractor review the monitoring data before submittal to the Facility?

8.3 Is the contractor review process adequate to uncover data errors?

8.4 Is the daily monitoring report periodically reviewed?

9.0 REVIEW OF CALIBRATION AND CERTIFICATION RECORDS

Audit shall include a review of the calibration and certification records including but not limited to:

9.1 Are the calibration gases of a methane/air mixture?

9.2 Does the Facility have certification papers on each of the calibration gases with the required information as listed in 40 CFR Part 60, EPA Reference Test Method 21?

9.3 Are all calibrations of LDAR monitoring equipment in accordance with EPA Reference Test Method 21?

9.4 Are there daily calibration records for the instruments that were used for monitoring? Are they properly filled out and filed?

9.5 Are there quarterly certification records for the instruments that were used during each quarter of monitoring? Are they properly filled out and filed?

10.0 REVIEW DELAY OF REPAIR

Audit shall include a review of the delay of repair process including but not limited to:

10.1 Does the Facility have a written delay of repair procedure?

10.2 Is there a required sign-off by the unit supervisor, which position was identified in the written program, that the piece of equipment is technically infeasible to repair without a process unit shutdown, before the component was eligible for inclusion on the "delay of repair" list?

10.3 Has it been demonstrated that the Facility made every effort to repair the leak before placing the component on delay of repair?

11.0 REVIEW RECORDKEEPING AND REPORTING REQUIREMENTS

Audit shall include a review of the record keeping and reporting requirements including but not limited to:

11.1 Is the Facility keeping the proper records per any Local, State, or Federal regulations?

11.2 Are records being maintained for the duration period as stated in the Local, State, or Federal regulations?

11.3 Has the Facility submitted to the state agency their semi-annual or periodic reports on a timely basis?

11.4 Is the information provided in the semi-annual or periodic reports meet the criteria as listed in the Local, State, or Federal regulations?

12.0 FIELD ACTIVITIES

12.1 Comparative Monitoring: As part of the LDAR audit, comparative monitoring shall be conducted on the following equipment. This is a suggested method. The Facility will entertain any suggestions by the auditor for more appropriate methods based on auditor's experience and benchmarking with industry standards. The Facility may, at their discretion, have the contract LDAR technician monitor the same components as the auditing team. Valves and Control Valves- Ten (10) percent of the total valves in the LDAR program. Pumps- Ten (10) percent of pumps in the LDAR program

12.2 Verification of Proper Tagging: As part of the LDAR audit, field verification of proper tagging will be conducted by selecting random sections of process units, inspecting those selected areas, reviewing all light and heavy components within those areas, verify proper identification by comparing field information with P&ID and stream data. Approximately three (3) percent of each process unit will be randomly reviewed. If an alternative monitoring plan is agreed upon, a complementary method of reviewing components may be suggested by the Auditor and approved by the Facility.

12.3 Verification of "Leaker" Tagging: As part of the LDAR audit, field verification of proper "leaker" tagging will be conducted by selecting random sections of process units. Approximately three (3) percent of each process unit will be randomly reviewed for proper leak tags. If an alternative monitoring plan is agreed upon, a complementary method of reviewing components may be suggested by the Auditor and approved by the Facility.

12.4 Delay of Repair Verification: The audit will verify that 100% of "delay of repair" components are properly tagged. The database list shall be compared with the fieldwork.

12.5 OEL/Sample Systems/Plug Audit: For the same areas that are being verified for proper tagging, the audit will include a review of proper management of open-ended lines, sample systems, and verify the presence of plugs in lines as appropriate.

12.6 Observation of LDAR Technician: The calibration of instruments and monitoring techniques will be observed and reported on.

13.0 POST AUDIT ACTIVITIES

13.1 A written and electronic audit report will be prepared and submitted to the Facility detailing the findings of the audit. The draft of this report shall be submitted to the Facility for comments. Once auditor has received comments then a final report will be provided to the Facility.

13.2 Any learnings that would improve the quality of the program will be incorporated into the next audit plan.

Cooling Tower Water Testing - Not the same old El Paso Method

In the early 70's, the El Paso Products Company devised a cost effective method to sample for VOC's in the cooling water. This method utilized a dynamic or flow-through system for air stripping a sample of the water and analyzing the resultant off-gases for VOC's using a common flame ionization detector (FID) analyzer, and has been required in permits in Texas for many years.

The El Paso Products method, however, has been overshadowed nationally by the use of purge and trap analysis of water samples utilizing gas chromatography and/or mass spectrometry techniques. While direct water analysis has been shown to be effective for cooling tower measurements of heavier molecular weight organic compounds with relatively high boiling points, Texas Commission on Environmental Quality (TCEQ) has determined that this approach may be ineffective for capture and measurement of volatile organic compounds with lower boiling points, such as ethylene, propylene, 1,3-butadiene, and butenes. VOC's with a low molecular weight and boiling point are generally lost in the sample collection step of purge/trap type analysis. Consequently, TCEQ requires that the air stripping method presented in Appendix P of the TCEQ Sampling Procedures manual be used for cooling tower and other applicable water matrix emission measurements of VOC's with boiling points below 140o F.

This test method had been review and accepted by the Texas Environmental Department currently known as Texas Commission on Environmental Quality (TCEQ). This method was accepted for analyzing samples for any VOC's that may come in contact with the cooling water. As of January of 2003, the TCEQ has adopted a new modified El Paso method. This method has taken an EPA methodical approach to testing. In this modified method certain criteria have to be met before this method can be utilized 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 calibration of specific components of the cooling water tower apparatus. These components are: air rotameter, water rotameter, and the temperature gauge. To calibrate these components, specialized equipment should be purchased to accomplish these tasks.

EnRUD Resources, Inc. has the experience and the equipment to perform the 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. EnRUD now offers this testing service through the Compliance Assistant Division (CAD). The Compliance Assistance Division will provide a turnkey solution from testing to reporting of calculated mass emissions from cooling tower. If data dictates that samples be speciated periodically, EnRUD Resources, Inc. will provide a 3rd party laboratory or provide samples to the facilities in-house laboratory. Stay tuned for more exciting news as EnRUD Resources, Inc. begins to automate the data acquisition process of cooling tower testing. In the near future we will have a pen-based data acquisition solution that will automate the testing process preventing the need for paper in the field. Customers or contractors will be able collect the information in the field electronically and up-load the information to a PC based data management system. This allows the customer to perform calculations and reports at the touch of a button. For more information on Cooling Tower Water Testing.

HRVOC LDAR AUDITS - A Trend that will continue.....

The federal and state environmental regulating authorities have always performed periodic checks to insure companies were complying with dictated mandates. In the mid 1990's the EPA began performing multimedia audits of the petroleum refining industry. As a result of these efforts the EPA, state and local authorities signed binding legal arrangements (called Global Consent Decrees) with several companies containing enforcement stipulations, civil fines, and enhanced LDAR programs.

Contained within these enhanced LDAR programs was the requirement for periodic 3rd party LDAR audits. The state of Texas has proposed additional regulations and changes to current regulations that will affect the non-attainment areas. These sweeping additional changes require, among other things, periodic 3rd party LDAR audits. California's South Coast Air Quality Management District is considering legislating periodic 3rd party LDAR audits. A dynamic that began with the Global Consent Decrees and is finding its way into many state and local LDAR regulations is periodic 3rd party audits. The regulating entities struggle with strategies to comply with the 1990 Clean Air Act pollutant reduction goals. One thing is clear; they want to ensure the data gathered is valid. After all, this information is plugged into air pollutant models which are used to develop emission reduction strategies far into the future.

The reductions of HRVOC, from the LDAR component of emissions, are critical to meeting the goals set forth in the 1990 Clean Air Act. The regulating entities need data they can count on. Thus, it is highly probable that mandated LDAR audits, not just HRVOC LDAR Audits, are "A Trend That Will Continue". Every facility regulated by the new HRVOC rule in the Houston/Galveston non-attainment area will be required to have once every two calendar years an independent third party audit (not your contractor) performed. These audits are comprised mainly of three areas: 1) A field audit 2) Comparative monitoring 3) Review of previous monitoring data or a LDAR database audit. The field audit will require an experienced "LDAR" individual to evaluate the LDAR program for components that should have been tagged/monitored or inspected and were not. This process will require LDAR program and process knowledge.

The second aspect, comparative monitoring, has a requirement as to when it should be performed, how many and which components shall be in the sample population. The third aspect will require an individual with database and LDAR regulatory experience to evaluate the monitoring process of your in-house or contractor monitoring. The owner shall give verbal notification of date to appropriate agency at least 30 days prior to an audit date and copies of audit report have to be submitted to appropriate agencies within 30 days of audit completion Facilities should schedule well in advance to insure that they have secured services of organizations with the proper skills to properly perform these tasks.

RT-201 Air Stripper System

General

The "VOC in Water" Air Stripper System based on the El Paso Method can aid in the measurement of fugitive volatile materials, which can escape from cooling tower water for example, and can be an indicator for process leaks and will allow plants to conform to laws limiting such emissions.

Description

The RT-201 Air Stripper is based on a standardized method and is the preferred system for reliably testing VOC (Volatile Organic Compounds) in low PPM-concentrations with a FID-analyzer from cooling tower water. It can also be used in a wide variety of other applications where VOC concentrations in water need to be measured. When connected to a Total Hydrocarbon FID-analyzer the RT-201 is a continuous on-line or transportable monitor, which provides the measurement of low ppm concentrations of dissolved solvents in water. This could be from cooling water, industrial waste- water, groundwater, process or rain water run-off. Continuous monitoring is a reliable and effective method to improve the process management for treating, discharging and detecting of dissolved VOCs in water. Compared to the laboratory grab sample analysis method, the technique of continuous on-line monitoring provides cost effective, remote and operator unattended measurement of volatile hydrocarbons in water.

After the RT-201 stripping unit is connected via a short sample line to FIA (Flame Ionization Analyzer), it reliably measures strippable dissolved and dispersed volatile organic compounds in water.

Typical Applications

  • Cooling Towers
  • Condensate Water
  • Holding Ponds
  • Heat Exchangers
  • Waste Water
  • Process Stream Analysis
  • Spray Paint Booth

VOC in Cooling Tower

Water Leaks of volatile hydrocarbons from heat exchangers may emit large amounts of VOC which can cause emissions into the atmosphere or may create a hazard. Continuous on-line monitoring gives an early warning of possible corrosion leaks. Savings in lost product can be substantial.

VOC in Heat Exchanger Water

The continuous monitoring of volatile hydrocarbons in condensate or cooling water gives the possibly earliest warnings for the development of leaks in a heat exchanger.

VOC in Waste Water, Holding Ponds

Drainage run-offs, equipment leaks or spills can be the cause for a build up of volatile hydrocarbons. A VOC analyzer with the Model RT-201 continuously indicates the presence of VOC in such waters. Features:

  • Continuous monitoring means uninterrupted real time measurement of VOCs in contaminated water.
  • Direct measurement does not require any sample pretreatment prior to measurement.
  • Monitoring process with a FID is more selective for the detection of VOC in the presence of physical and chemical interference in contaminated water.
  • Major Applications are Continuous monitoring (or field monitoring) of VOCs in water from cooling towers, cooling water outlets, condensers, heat exchangers, water wells, spray paint systems, extraction water run off, rain water run off.

Approaching ISO-LDAR - LeakTracker System Mars 4.0

Today's industries are continually striving to compete globally. As part of this process companies have spent millions and will spend millions more meeting the rigorous product and organizational standards known as ISO 9000 and ISO 14000. The ISO 14000 organizational standards provide a comprehensive guidance for establishing, maintaining and evaluating an environmental management system. The world of Leak Detection and Repair (LDAR) is evolving. Since the early 90's EPA enforcement teams have been performing multimedia audits concentrating on the refining industry. As a result of these efforts, 10 companies have signed global consent decrees. These global decrees have numerous additional LDAR requirements. California's South Coast Air Quality Management District (SCAQMD) has recently modified its local LDAR rule (1173). The Houston/Galveston non-attainment area is in the process of modifying its LDAR rule (Chapter 115). These three efforts by state and federal authorities affect numerous facilities. They all have some common components.

  • Requirement for the use of electronic data acquisition and man- agement systems
  • Requirement for periodic third party audits
  • Requirement that the data be analyzed for anomalies based on monitoring time. It becomes readily recognizable that the regulating community is asking for environmental management systems that insure the quality of the data gathered and reported.

As part of that, they are asking that the facility certify job being performed by evaluating the work process using the monitoring date and time. In the past, facilities have had to perform this task with inadequate data, only one time stamp. Enrud Resources, Inc. has added additional time stamps and functionality to the patented LeakTracker™ System. Facilities now have the data acquisition mechanisms available for them to accurately depict the monitoring process, allowing them to "Approach ISO-LDAR". No longer will the LDAR responsible party have to certify the monitoring process with inadequate data. Now you can tell how long they surveyed a component and how long they spent during the Method 21 compliance interval. In the past, we have had to make hand sweeping assumptions based on the time between monitoring events. Now a facility can perform meaningful QA/QC routines that they can confidently stand behind. In addition to the additional time stamps, MARS version 4.0 will allow you to edit pick-lists, increase field lengths, perform documented visual surveys, perform tagging, and document calibration. The Leaktracker™ System is compatible with virtually every LDAR data management system, including LeakDas™ Version 3.0 and FEMSEXPRESS 5.0.

Subcategories

Get a Quote


Please let us know your name
 
Invalid email address.
 
Invalid Input
 
Please let us know your phone number
 
Invalid Input
 
 

Newsletter signup

LDAR SOLUTIONS &
INFORMATION CENTER

Recent
Articles

Federal &State
Regulations

LDAR
Resources