# Smart L D AR — M ore Cost- E ffective?

M ike meister

managing C onsultant— C orpus C hristi

On December 19, 2008, EPA issued a final rule establishing a voluntary Alternative Work Practice (AWP) to detect leaks of volatile organic compounds (VOC) and hazardous air pollutants (HAP) from process equipment (FR Vol. 73, Number 246), thereby providing the regulated community additional flexibility in complying with leak detection and repair (LDAR) requirements. The AWP allows owners or operators of an affected facility to identify leaking equipment using an optical gas imaging
instrument in lieu of a leak monitor as prescribed in Title 40, Code of Federal Regulations (40 CFR) Part 60, Appendix A (Method 21). The development of the AWP and its associated monitoring technologies are collectively referred to as “Smart LDAR.”



## What is Smart L D AR ?

Beginning in the 1980s, EPA called for the implementation of LDAR programs for control of fugitive VOC emissions (i.e., emissions from piping components such as flanges, connectors, valves, pumps, etc.). Therefore, LDAR requirements were initially promulgated in the New Source Performance Standards (NSPS) under 40 CFR 60, Subpart VV. EPA went on to incorporate LDAR requirements in other
NSPS and 40 CFR 61. These efforts were extended with the passage of the Clean Air Act Amendments of 1990, which resulted in the adoption of LDAR provisions into the Maximum Achievable Control Technology (MACT) rules under the National Emissions
Standards for Hazardous Air Pollutants (NESHAP). More recently, the proposed mandatory Greenhouse Gas Reporting rule (40 CFR 98) contains fugitive monitoring provisions. The current LDAR work practice requires the use of Method 21 to identify component leaks. Method 21 involves moving a gas sampling instrument probe around all leak interfaces (seals) and determining the highest VOC/HAP concentration. After determining the location of the highest concentration, the probe must remain at that location for two times the response time. The
instrument readings are compared with
levels established by EPA and/or the state air pollution regulatory agency
to determine if the component leaks.
If the measured
VOC concentration
at a component
exceeds the leak definition (which typically varies from 500 parts per million by volume (ppmv) to 10,000 ppmv, depending on the type of component and specific subpart), the component must be repaired or replaced within a specified period of time. The repeated Method 21 measurement of emissions following such maintenance must
be below the leak concentration level for the component to be considered repaired.

In 1997, the American Petroleum Institute (API) conducted a study of 11.5 million monitored refinery components to
determine if there was a correlation between component type or application and its potential to leak. The study showed that over 90 percent of the controllable fugitive emissions were attributed to 0.13 percent of the components monitored, demonstrating that significant time and effort is spent monitoring components that, statistically, do not leak. Furthermore, after an LDAR program has been implemented at a site, the number of leaks detected during each subsequent monitoring period decreases because pre-existing leaks have been repaired and may not leak for 

# regulatory update

4 E nvironmental Quarterly | Summer 2009 extended periods of time. Although repair
costs decrease as the number of leaks is reduced, the costs of conducting Method 21 monitoring is not always reduced in the same proportion. In some cases, the cost of conducting Method 21 monitoring may remain constant, resulting in a decrease in
cost-effectiveness.

Conceptually, the costs associated with the current work practice of monitoring each component at a site individually could be significantly reduced by implementing a method that more efficiently locates the high leaking components without monitoring each piping component in the plant using Method 21. This concept, dubbed “Smart LDAR,” could use newer technology to locate and repair the most significant leaking components more quickly and at less cost than the current work practice.



## T echnologies E valuated

Remote sensing (i.e., the acquisition of data through the use of either recording or a real-time sensing device, such as imaging, that is not in direct physical contact with the object being monitored) and instantaneous detection capabilities of Smart LDAR technology can allow an operator to scan process areas containing tens to hundreds of components in real time. Significant leaks can be identified immediately, allowingSummer 2009 | E nvironmental Quarterly 5 quicker repair and ensuring efficient use of resources. In the development of the AWP, EPA researched multiple remote sensing technologies to measure pollutant concentrations, including the following:

n Ultra-Violet Differential Optical Absorption Spectra (UV- DOAS)

n Open-Path Fourier Transform Infrared Spectroscopy (OP-FTIR)

n Rama-Spectroscopy

n Tunable Diode Laser (TDL)

n Differential Absorption Light Detection and Ranging (DIAL/LIDAR)

n Optical Gas Imaging

To date, the only technology that has been approved and implemented as an AWP is optical gas imaging. Due to issues such as excess expense, technical limitations of the number and type of chemicalspecies detected, interference from nontarget emissions, and required expertise for calibration and operation, the other technologies have not been approved as an AWP. However, LIDAR, which utilizes laser absorption and reflection to generate a differential signal that can be used to calculate the concentration of the target compound, is currently in use in both ground-level and airborne applications by EPA and a number of state agencies to create concentration contouring of various
chemicals and to validate emission factors.

Two types of optical gas imaging cameras are available for use as an AWP, the basic operation of which are explained below:

n Active Optical Gas Imaging

- utilizes a laser beam reflected (backscattered) by the background to detect the chemical present. The optical image is produced by the reflected light with a light wavelength strongly absorbed by thegas cloud. The image is displayed realtime on the screen of the gas imaging

camera.

n Passive Optical Gas Imaging - a passive technology that records the difference in absorption of specific infrared (IR) wavelengths in the field of vision and produces the appearance of a cloud where the chemical is present. The technology uses different combinations of lenses, detectors and filters for detecting different pollutants. The optical lens of a passive gas imaging
camera can be tuned to illuminate target compounds (a principle similar to that used in “night-vision” equipment) to
detect leaks.

Optical gas imaging technology offers several advantages from the perspective of Smart LDAR implementation. It meets the Smart LDAR requirements of providing efficient real-time leak analysis while also being lightweight, compact, and robust, thereby allowing a single operator to easily transport the equipment for use under field conditions. In addition, since the cameras can be used to detect leaks from a distance, they provide a greater element of operator safety over the current work practice using
Method 21.

The chief limitation of optical gas imaging is
related to calibration of the camera. Each camera is calibrated based on the required detection limits of compounds that possess a specific range of absorption and reflection wavelengths. If a site is required to monitor pollutants whose ranges do not overlap, the
camera must be recalibrated for the second group of pollutants or another camera used. Other issues that may be considered roadblocks to implementation include the requirement for daily instrument checks, the potential requirement by state agencies that operators must undergo accredited formal training, and the high initial equipment costs (currently available cameras carry a price tag of approximately $85,000.) However, these disadvantages may not necessarily preclude the implementation of optical gas imaging technology as an AWP, particularly for larger sites.



## Smart L D AR I mplementation

Passive optical gas imaging cameras are being widely used throughout industry for leak detection. State agencies are now using this technology in statewide fugitive emissions reduction initiatives (e.g., the
Texas Commission on Environmental Quality’s “Find-It-and Fix-It” program and aircraft overflights over industrial areas such as the Houston Ship Channel). Optical gas imaging cameras have been used to detect the presence of unburned hydrocarbons in flare plumes outside of the flame and to determine combustion efficiency in various
combustion sources. Besides industrial applications, optical gas imaging was used by EPA and the Louisiana Department of Environmental Quality in detecting leaks and other sources of air pollutants, post Hurricane Katrina. The table on page 6 is a partial list of local, state, and federal agencies that currently operate optical gas imaging cameras for the purpose of performing various surveillance and compliance investigations.

In addition to being implemented into LDAR programs as an AWP, optical gas imaging cameras may be utilized in the future by industry and regulatory agencies for various other tasks, such as safety and risk mitigation applications, sulfur hexafluoride (SF
6 ) detection as part of the collaborative effort between EPA and the electric power industry to reduce greenhouse gas emissions (the SF
6 Emission Reduction Partnership), and the quantification of emissions, once the technology is further developed.



## Considerations

There are several key points to consider before implementing an optical gas imaging camera for fugitive gas leak detection.

n The definition of a leak is any visual
indication whether seen via camera or naked eye, which is a departure/ additional to existing work practice standard. For instance, visual indications of a leak from a gas/vapor or light liquid service valve are not addressed in current work practice
standard. Visual indications of a leak from a valve in heavy liquid service would be considered a potential leak. The facility can then decide to eliminate6 E nvironmental Quarterly | Summer 2009 Additionally, weekly visual inspections of affected pump/agitator components may still be required, as prescribed under the current LDAR program, if a site plans to adopt the AWP.

n Smart LDAR does not allow for decrease in monitoring frequency due to “good behavior,” as does the current work practice. Thus, the cost savings realized due to decreased monitoring frequencies when using Method 21 do not apply to the AWP.

n After detecting leaks analogous to the existing work practice standard, owners or operators must re-check the repaired equipment for further leaks with the same gas imaging camera or they may
use Method 21 to confirm that the leak has been repaired. n Owners or operators must perform the specified daily calibration checks to ensure proper operation.

n Owners or operators should be aware of the high initial cost of the equipment and are advised to perform a cost-benefit analysis before purchasing and implementing optical gas imaging equipment. In general, the company would realize a greater benefit in the long run, due to a reduction in labor cost. Additionally, some companies have taken the approach of purchasing one camera for multiple sites to minimize the cost per site. Another option for managing cost is to contract the testing from a firm that specializes in air quality compliance, fugitive leak monitoring, and stack testing.

It is important to note that current optical gas imaging technology cannot quantify or speciate individual chemical compounds although there are efforts currently underway to adapt the technology to such applications. These enhancements include development of software that may interpret gross emission rate based on video imagery. Once the technology is fully realized, industry and agencies alike may be able to quickly and accurately determinecompliance for other air emissionsrelated parameters, such control device performance and emissions limits, in
real-time with the click of a button. t the potential leak or conduct Method 21 monitoring to determine if it meets the
leak definition. Visual indications from a pump (except for pumps addressed under the Hazardous Organic NESHAP [HON] rule) are considered potential leaks; however, under AWP they would
be considered leaks.

n When the AWP is used, owners/operators must also perform annual monitoring using the Method 21 instrument and provide all the Method 21 monitoring results to EPA via email. Therefore, owners or operators who are only required to conduct annual monitoring as part of their LDAR program would not benefit from implementing the AWP. 

# regulatory update

Local, State, and Federal Agencies Using Official Gas Imaging Cameras for Fugitive Leak Detection

L evel A gency

Federal U.S. Environmental Protection Agency (EPA)
U.S. Department of Interior - Mineral Management Service (MMS)

State California - Bay Area Air Quality Management District (BAAQMD)
California - South Coast Air Quality Management District (SCAQMD)
Delaware - Department of Natural Resources and Environmental
Control (DNREC)
Illinois - Environmental Protection Agency (IEPA)
Louisiana - Department of Environmental Quality (LDEQ)
Montana - Department of Environmental Quality (MODEQ)
New Jersey - Department of Environmental Protection (NJDEP)
Texas - Commission on Environmental Quality (TCEQ)
Municipalities City of Houston - Bureau of Air Quality Control (BAQC)
City of Philadelphia - Air Management Services (AMS)

Kansas E nvironmental Conference August 18-20 Wichita, KS

MCIC - E HS Safety School August 24-25 Raleigh, NC

NC A SI Western Regional Meeting September 1 Portland, OR Drop by the Trinity booth at any of these upcoming conferences. We look forward to seeing you! 

# See Y ou on the R oad

T C E Q A dvanced A ir Permitting Seminar September 29-30 Austin, TX

E nvironmental Federation of O klahoma’s 17th A nnual Meeting October 1 Tulsa, OK

Iowa-Illinois Safety Council’s 23rd A nnual
E nvironmental Conference & E xpo October 1 Davenport, IASummer 2009 | E nvironmental Quarterly 7 **Q. George, how would you describe your role at Trinity?** 

A

. That’s an interesting question. Trinity is certainly well known for its air modeling prowess and I have worked for a number of years performing similarly challenging modeling work. My internal role here at Trinity is one of providing senior experience and mentoring due to the sheer number and variety of modeling scenarios in which I been involved over the years from my EPA experience to consulting. I like to share that experience however possible through instruction, project participation, project management, leadership roles in outside organizations, and through company pow-wows that focus on everything from the most sophisticated, new modeling techniques to the everyday task of interpreting the results. Externally, I continue to be focused on applying strategic modeling and regulatory analyses to assist clients in meeting their air quality challenges.

**Q. What are the most pressing environmental challenges**  **your clients seem to be facing in 2009?**

A

. In 2009, clients are facing a number of environmental challenges. First and foremost will be maintaining continued compliance while trimming environmental budgets and staff. Most companies want to maintain operations to the extent possible in spite of the economic downturn. Once the economy begins to recover, companies want to have their staff and resources intact, and their operations poised to respond. Another important challenge for companies in this new era is to have a plan for sustainability and low impact while leaning to green in terms of resource use, emissions, and overall impact on the environment. Energy and resource conservation were not high priorities until the last decade when we realized this approach saves money, saves resources, and makes sense. It’s exciting to be working with clients on meeting these challenges. 

# staff spotlight



# A

tmospheric Scientist T ackles Complex A ir Q uality I ssues

G eorge S che w e

, a Certified Consulting Meteorologist and Qualified Environmental
Professional, joined Trinity’s Covington, Kentucky office in 2008. A veteran of EPA with
nearly three decades of consulting experience, George is well-versed in air quality
regulatory requirements and a master in complex air dispersion modeling analyses.
Here is George’s take on his role and current environmental issues.

**Q. How are you supporting clients in addressing** 
**these issues?**

A

. One way we are trying to address client needs in this challenging economic environment is to provide alternatives for consideration in terms of facility actions, plans, and subsequent subjectivity to applicable regulations. Initial screening modeling that identifies relative impacts of various control strategies, facility layouts, operational changes, time-of-day operations, etc. can go a long way to reducing emissions, reducing impacts, minimizing modeling costs, and revealing culpable sources where emphasis can then be placed. I believe we can offer a quality product for a reduced cost to the client by using a strategic approach that includes initial discussions and meetings with the client and with regulatory agencies when possible to clarify how the modeling should proceed. This is consistent with our client service model always but is particularly important in today’s environment.

**Q. How do you anticipate the environmental field**  **(issues) changing over the next decade?**

A

. I expect more regulations on everything but still a big emphasis on the big sources such as power plants. W ho would have thought 20 years ago that lawn mowers, chain saws, and barbecue grills would be regulated, not to mention wood burning stoves? As we enter a new era in energy production—more wind turbines, solar, nuclear, and the swing toward sustainability and environmentally safe technologies, I anticipate more integration of industry and green technologies. Ultimately, I hope successful integration will lead to a cleaner environment supported by more sustainable technologies that are cost-effective for industry. t

Contact George at (859) 341-8100 or at gschewe@trinityconsultants.com.