In general, EPA has found signifi cant widespread noncompliance with Leak Detection and Repair (LDAR) regulations and more specifi cally, noncompliance with Method 21 requirements. In 1999, EPA estimated that, as a result of this noncompliance, an additional 40,000 tons of VOCs are emitted annually from valves at petroleum refi neries alone
In general, EPA has found signifi cant widespread noncompliance with Leak Detection and Repair (LDAR) regulations and more specifi cally, noncompliance with Method 21 requirements. In 1999, EPA estimated that, as a result of this noncompliance, an additional 40,000 tons of VOCs are emitted annually from valves at petroleum refi neries alone.
This document is intended for use by regulated entities as well as compliance inspectors to identify some of the problems identified with LDAR programs focusing in on Method 21 requirements and describe the practices that can be used to increase the effectiveness of an LDAR program. Specifi cally, this document explains:
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The importance of regulating equipment leaks;
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The major elements of an LDAR program;
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Typical mistakes made when monitoring to detect leaks;
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Problems that occur from improper management of an LDAR program; and
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A set of best practices that can be used to implement effective an LDAR program.
Some of the elements of a model LDAR program, as described in Section 7.0, are required by current Federal regulations. Other model LDAR program elements help ensure continuous compliance although they may not be mandated from a regulatory standpoint. Furthermore, State or local requirements may be more stringent than some elements of the model LDAR program, such as with leak definitions. Prior to developing a written LDAR program plan, all applicable regulations should be reviewed to determine and ensure compliance with the most stringent requirements.
