Regulatory Impacts of Inadequate Fugitive Monitoring By not fully identifying all leaking components, refineries are likely causing the unnecessary release of excess hydrocarbons. Most LDAR regulations allow for decreased monitoring frequency if certain performance standards are consistently achieved. Monitoring frequency is decreased from quarterly to annual monitoring if less than two percent of the valves within a process unit are found leaking. Conversely, if greater than two percent of the valves are found to be leaking, monitoring must be conducted quarterly. EPA monitoring showing a greater than two percent leak rate has resulted in refineries reverting back to quarterly monitoring.
Several refineries use a leak definition lower than the regulatory limit.
Rather than monitoring annually, some refineries monitor quarterly. Meanwhile, however, the regulated industry is expected to comply fully with existing LDAR requirements. EPA Policies for Reducing, Eliminating Penalties for Self-Policing EPA has adopted two policies designed to encourage the regulated community to comply with environmental laws.