The South Coast AQMD is considering a change to VOC monitoring at facilities that are required to use a Leak Detection and Repair (LDAR) system in order to help meet the Clean Air Act’s requirements for VOC levels. VOCs, or Volatile Organic Compounds, react in the atmosphere with NOx to form Ozone which is the main component of smog. VOCs also react with atmospheric aerosols to form organic particulates. It’s estimated that 30% to 50% of atmospheric particulates are organic. For these reasons, the South Coast AQMD finds VOC leaks a worthy target for control under the 2016 AQMP (Air Quality Management Plan).
Many types of companies are required to maintain an LDAR system to monitor fugitive VOC emissions. These include petroleum refining and chemical products processing, oil and gas production facilities, storage and transfer facilities, marine terminals, and other sources, where VOC emissions occur from fugitive leaks in piping components, wastewater system components, and process and storage equipment leaks. Typically, facilities use a hand held monitor to sample for leaks at each valve, flange, fitting, well-component, etc. on a quarterly basis. Repairs are then made to fix the leak and a report is submitted to the district.
The AQMP is considering a change that will require facilities that currently conduct LDAR to instead use more advanced remote sensing units with advanced infrared or optical technologies (or “Smart LDAR”) for monitoring fugitive VOCs. These systems can detect leaks over a large area much more quickly and could be – and may be required to be – used much more frequently than the current systems. The hand-held monitors make leak detection very time-consuming as the person conducting the monitoring must go throughout the facility and test each point individually. The remote sensing devices can quickly scan and detect leaks allowing monitoring to be done frequently, or perhaps continuously, and repairs made much sooner than otherwise.
This new requirement, if adopted, would have several implications for facilities. When calculating emissions from VOC leaks for their Annual Emissions Inventories, companies must assume the leak has occurred since the previous LDAR was conducted. This could be as much as three months if a company monitors quarterly. Therefore, monitoring often and repairing immediately could significantly reduce the amount of VOC needed to be reported. On the other hand, recent testing by the AQMD of the advanced remote-sensing equipment has shown that it is detecting higher VOC emissions than are being reported through the hand-held monitoring. Some facilities may find their emissions are higher under the new program if their LDAR system using hand-held monitoring has been less than thorough. Another area of concern for facility management is the cost of the new equipment which would be significantly higher than the hand-held monitors. For those companies that utilize the services of monitoring companies, they could be faced with buying the new equipment instead and training personnel to do the monitoring. Some savings could be gained, however, by the reduction of loss of product from the leaks as they are repaired much more quickly.
For more specifics on projects the SCAQMD has initiated using this new technology read our article on Optical Remote Sensing. As the AQMP continues in development, Alta will keep you informed on pending changes. We can help you develop strategies to best address new regulatory requirements before they impact your business and your bottom line.
Contact us for more information at 562-495-5777.
This is the third in a series on informative articles on the regulatory changes coming as a part of the SQAQMD’s 2016 Planning. Blog post authored by Kimba Spencer.