Your Guide to the Ultimate LDAR Program & Its Benefits (2024)

What Is LDAR?

The U.S. Environmental Protection Agency’s (EPA) Leak Detection and Repair (LDAR) programs are a set of federal regulations aimed at reducing emissions of volatile organic compounds (VOCs) and volatile hazardous air pollutants (VHAPs). These regulations set requirements for monitoring, repairing and maintaining specific industrial components at risk of leaking these pollutants into the environment.

While LDAR compliance is required by any business operating equipment subject to these requirements, the programs are particularly relevant to oil, gas and chemical industries. Businesses that violate LDAR can be subject to a wide range of punitive actions. In the late 1990s and early 2000s, for example, ExxonMobil suffered significant financial and operational penalties as a result of LDAR noncompliance.

Purpose of LDAR Programs and the Key Elements Involved

Reducing dangerous emissions, particularly emissions of VOCs and VHAPs, is the primary goal of LDAR programs. The EPA uses LDAR enforcement to reduce contamination of the air, soil and water, protecting natural environments and the surrounding communities where hazardous emissions can harm wildlife and local residents.

But the agency also argues that hazardous emissions represent aproduct loss for the businesses creating them, resulting in lost revenue for those companies. Reduced hazardous emissions also increases workplace safety for employees at any facility where this equipment is operated.

While the specific requirements of LDAR programs may vary from one industry to the next, each program features five key elements:

• Identifying regulated components: Each asset subject to LDAR requirements must be given a unique ID for tracking and record-keeping. In many cases, a barcode or other physical tracking ID is used.
• Asset leak definition: The threshold for defining a leak varies based on the type of component, the type of service and the monitoring interval. Each LDAR program sets measurement thresholds so that onsite staff can easily identify a leak.
• LDAR monitoring: Each LDAR program sets guidelines for monitoring leak components and maintaining the program’s environmental compliance.
• Asset repair: Regulations define the required time frame for repairing identified leaks as well as protocols and best practices for addressing those leaks.
• Record maintenance tasks: Detailed record-keeping includes logging all repair and maintenance work orders, performance testing, asset monitoring and other actions required by the LDAR program.

How Is a Leak Defined?

According to LDAR programs, a leak is defined as an amount of a hazardous substance, measured in parts-per-million (PPM), that escapes the component where it is meant to be enclosed. That measured amount must exceed the leak threshold set by the program.

When evaluating for leaks of VOCs and VHAPs, airborne detection instruments are often required. Along with these tools, though, leaks may also be detected and defined using visual evidence — such as dripping, spraying or pooling of liquid — as well as the sound of hissing gas, the smell of harmful contaminants or other evidence.

A wide range of federal, state and local LDAR programs have been created to set standards for leak detection across specific industries and work environments. Examples of these tailored leak standards include:

• National NESHAP equipment leaks standards, which set standards for addressing VHAP emissions from new and existing stationary sources
• RCRA standards for hazardous and solid waste, which set equipment leak standards for hazardous waste treatment, storage and disposal facilities
• The California Air Resources Board’s Oil and Gas Methane Regulation, which sets and enforces leak rate standards for owners and operators of oil and natural gas facilities

Most Common Sources of Leaks

When a VOC or VHAP leak is detected, LDAR technicians start by inspecting the most likely sources of these leaks. While the assets suffering these leaks can vary widely in their design, most leaks develop through one of the following components:

Valves

Valves are put in place to control the flow of hazardous emissions and other substances within a piece of equipment or a larger industrial process. A wide range of valve devices may be used in different industries and on different equipment. Leaks from valves typically develop when the seal of a valve packing or O-ring fails.

Pumps

Pumps are widely used in petroleum refineries and chemical plants to move liquids from one location to another. No matter what kind of pump used in the equipment, pump leaks most commonly develop at the seal where the pump connects to a pipe or other piece of equipment.

Connectors

Connectors are used to provide a complete seal when joining piping and process equipment. Connectors are the most common type of component used in industrial equipment that contains harmful pollutants such as VOCs and VHAPs. According to the EPA, most connector leaks result from either gasket failure or improperly torqued bolts.

Compressors

Compressors increase pressure on fluids and gas to facilitate their movement into different pipes and processing equipment. Compressor leaks typically develop around the seals of the device.

Pressure Relief Devices

These devices are often deployed with compressors to ensure internal equipment pressures aren’t pushed beyond their maximum working limit. Leaks in pressure relief devices are often caused by an improper valve fit, a failed seal or device placement too close to the set point.

Open-ended Lines

Open-ended pipes and hoses can sometimes be the source of a fugitive emissions leak. Leaks from these lines occur when caps, plugs or flanges fail to fully seal the opening.

Best Ways to Monitor Leaks

Consistent monitoring is a critical element of any internal LDAR program. Along with ensuring compliance with applicable LDAR laws, a strong monitoring program is any organization’s first step toward identifying leaks, making timely repairs, reducing harmful emissions and avoiding regulatory scrutiny. Every leak monitoring strategy should include the following:

Basic Sensory Inspection

Onsite technicians and inspectors should always be vigilant for signs of a potential hazardous leak. Depending on the types of hazardous materials used at that site, sensory information such as visible fluid leaks, concerning smells and the sound of hissing gas are all common signs that a leak has developed. Onsite personnel should also pay attention to dramatic changes in other conditions, such as sudden losses of pressure for compressors and storage tanks or equipment failures that may be triggered by a leak.

Detection Instruments

Calibrated detection instruments are used to gather specific measurements in determining whether the presence of a harmful substance constitutes a leak. These instruments are also critical to identifying leaks not detectable through sensory inspection, such as the release of odorless but toxic gasses into the environment. Onsite personnel using these instruments should always make sure the devices have undergone proper calibration to ensure an accurate reading. Optical gas imaging (OGI) is an excellent example in that this thermal imaging technology can use infrared cameras to detect gas leaks. The OGI cameras target specific gasses by blocking energy from reaching the camera’s infrared detector; which creates a cloud that highlights where the leak is present.

Protocols for Monitoring Frequency

Applicable LDAR regulations will define the expectations for monitoring components for leaks. Depending on the components and the regulation itself, the required analyzer frequency may be weekly, monthly, quarterly and yearly. Keep in mind that these frequencies represent the minimum requirement. Many organizations setting up their own LDAR program may choose to implement more frequent monitoring intervals than what is required by law. All monitoring data should be documented in your LDAR records to prove compliance in the event of an audit.

The Risk of LDAR Noncompliance

Failure to comply with LDAR regulations can represent a costly and disruptive legal problem for businesses — and could have lasting consequences for your brand’s reputation in your industry. As previously mentioned, ExxonMobil offers one of the best examples of the risk that comes with LDAR noncompliance. In the late 1990s and into the early 2000s, regulators discovered that ExxonMobil had failed to meet a number of legal requirements for leak monitoring and timely leak repair. This resulted in the release of benzene-contaminated waste into waterways around Staten Island, N.Y.

The company ended up settling their case with the EPA for $11.2 million, although the company was also embroiled in additional regulatory infractions before and after this incident. In addition to the regulatory fine and the negative environmental impact, the company also suffered the following:

• Increased operational disruptions due to regulatory investigations and evaluations
• Material loss resulting from unidentified leaks
• Reputational damage due to media coverage of this event

How to Implement an LDAR Program at Your Organization

To ensure compliance with applicable LDAR regulations, companies should consider setting up their own LDAR program that accounts for various emissions reduction requirements set at the local, state and national level.

This LDAR program can provide a framework for ensuring proper monitoring, leak detection, repair and maintenance for all assets housing VOCs and VHAPs, keeping your organization in compliance while making it easier to organize priorities and allocate resources for inspection, maintenance and repair.

For companies building an LDAR program from scratch, one recommended approach is to begin by following the best practices of a common regulation or standard, such as 40 CFR 60 or Method 21, that aligns with your program’s needs. You can then modify the details of this program based on regulatory requirements and/or your organization’s emissions management preferences.

Along with developing and documenting these requirements, program managers should also prioritize the following actions:

• Implementing a preventive maintenance software solution to schedule inspections for potential or actual leaks
• Creating an onboarding process to train employees on the new LDAR program, including your preventive maintenance software
• Assigning accountability for LDAR program requirements to specific personnel and roles
• Setting up barcode tracking for assets and ensuring that the five pillars of LDAR program development are all in place

How a CMMS Can Assist With an LDAR Program

Whether your organization is enhancing an existing LDAR program or starting one from scratch, a computerized maintenance management system (CMMS) can help you manage this implementation for a smoother transition and better program results.

A CMMS software can support your LDAR program through the following:

• Preventive maintenance scheduling for leak inspections and maintenance
• Automated notifications and reminders for upcoming LDAR services
• Integrated asset tracking and data management
• Easy uploading of photos and information relevant to leak monitoring and detection

No matter how many assets you manage or how complicated your specific LDAR requirements may be, a CMMS can simplify this workload to help you ensure compliance at scale.

Find out how Coast’s CMMS can power a better LDAR program for your business — sign up for a free account today.