Last month, our own Eric Allen had an opportunity to visit China to support the deployment of Ei’s software on various projects. As we discussed in our first blog post on the topic, the regulations have been ever-changing, even up to the compliance deadline. Interestingly, we have identified some requirements that are new to us - requirements which do not exist in the “mature” set of regulations the US EPA has issued and that we’re all familiar with. These include:
- Tagging of streams with >2% (compared to >10%) Volatile Organic Compound (VOC)
- Specifications around the information to be included on physical tags, and requirements for tagging
- Recording Pictures of leaking components
- Limitations on monitoring in strong winds
- Recording Temperature / Pressure Data of Process Stream
The development of these regulations did not occur in a vacuum; instead, development involved international coordination and knowledge-sharing - and likely involved some input from US regulators. Furthermore, with few industry groups lobbying on behalf of industry (such as the American Fuels and Petrochemical Manufacturers (AFPM) and American Petroleum Institute (API) groups we have in the US), there was limited rule-setting feedback from industry. As such, seeing these “new” requirements pop-up in the Chinese regulations may point to an underlying “wish list” that rule-setters in the US and elsewhere may have.
Monitoring of Streams with >2% VOC
In the U.S., streams that contain >10% VOC are regulated by LDAR (in the case of the NSPS requirements of 40 CFR Part 60, or in the case of the MACT regulations under 40 CFR Part 63, >5% Hazardous Air Pollutants). Within the range of 2% - 10% VOC content, one would expect a reduced % VOC threshold to now regulate the following streams:
- Water-containing streams - this could potentially including water-boots, sour water, and slurry-containing lines.
- Additives - this would likely impact a greater number of additive systems.
- Natural gas and purchased gas lines - although many plants inventory their fuel gas lines (do to the lines containing a higher percentage of alkenes and C3+ hydrocarbons), many of the fuel gas or purchased gas lines which are commonly excluded from monitoring fall within the 2-10% range of VOC content.
Lesson Learned: When doing a reinventory project, or re-highlighting your P&IDs for LDAR applicability, pay close attention to the streams which are “on the fringes” of applicability thresholds.
Requirements and Specifications for Physical Tags
The Chinese regulations we have reviewed include requirements for physical tagging of LDAR components, which would eliminate tagless LDAR program options (such as those which use virtual tags depicted on isometrics or other drawings). Furthermore, these regulations have very specific requirements around the format of the LDAR tags used - which includes requirements for using barcoded LDAR tags. What may be the reason for these requirements?
First, requiring tags of a specific format (which includes the unit listing) can increase the “auditability” of the program . Of course, there’s the easy-to-surmise “the more things that are required the more chances there are to mess up.” However, there may be a deeper reason for this requirement: physical tagging can greatly increase an auditors (both internal and external) ability to thoroughly audit a program. When LDAR applicable components are not physically tagged (such as in the case of a poorly-maintained tagging program, or a poorly executed LDAR inventory which uses a great number of virtual “A-tags”) - it becomes increasingly difficult to identify if there are compliance issues within the inventory.
Second, when barcode tags are used with barcode-capable handhelds for monitoring, it’s possible to introduce a higher level of quality control on the monitoring being performed - this ensures the LDAR technician is at the physical tag (hopefully eliminating the opportunities for “in the office” monitoring). This, however, introduces a set of technological challenges, including architecturing monitoring software to ensure the barcode scanning functionality cannot be overridden, and modifying workflows to ensure “one-off” monitoring events are performed with barcode scanners (instead of commonly-used paper logs).
Lesson Learned: Ensure your LDAR program has an effective tag maintenance program in place, and ensure “A-Tags” are not overused during an inventory project.
Recording of Pictures of Leaking Components
For leaking components, current regulations require that, in addition to commonly recorded information for leakers, a picture is taken of the leaking component. Although this may be a best practice to do (it helps repair personnel positively identify the leaking component) - this can introduce compliance challenges. First, many handheld devices utilized for monitoring do not contain integrated cameras (fortunately for our China projects, our EiMOC™ program has this functionality); or, the software is not architectured to smoothly record this information. Second, most plants have strict permitting requirements around getting a camera-permit to take pictures - this can introduce additional challenges in logistics and delays for performing repairs and follow-up monitoring.
Lesson Learned: When technicians identify a leak, ensure they thoroughly document the location of the leaking component, and the location of the leak on the component, to make it easier for repair personnel to effectively repair the leak.
Limitations on Monitoring in Strong Winds
The regulations we reviewed include limitations around monitoring in high-wind conditions, specifically limiting monitoring from occurring when winds exceed 3 meters per second. This is likely a measure to collect more consistent monitoring data - as strong winds can diminish a recorded screening value (in ppm) of a monitored component. However, if LDAR monitoring is performed by a trained professional monitoring technician in accordance with proper monitoring technique (including monitoring probe placement, distance from the leak interface, and traverse speed) - wind impacts have a mostly negligible impact on recorded screening value (in ppm).
Lesson Learned: Ensure your technicians are properly trained on the monitoring requirements (i.e. USEPA Method 21) and best practices, including probe placement and monitoring speed.
Recording Temperature / Pressure Data of Process Streams
There appears to be an increased focus on LDAR stream applicability determinations and characterizing process streams, as shown in a recordkeeping requirement to record stream temperature and pressure data for equipment in the LDAR program. Using industry-standard technologies for documenting stream characteristics (paper-P&IDs and highlights), this represents a significant challenge (see our page on how our LDAR Intelligence software with intelligent P&IDs can do this automatically). As for how this temperature and pressure data will be used in the LDAR program? Potentially for enhanced emission calculations (which take into consideration the temperature and pressure of the line), or for categorization of the effectiveness of Low-E equipment. Who knows.
Lesson Learned: When determining LDAR applicability (such as during a P&ID re-highlight effort), ensure you’re engaging the Process Engineering group to ensure accurate chemical speciation is referenced to determine stream applicability.
To meet the strict emission reduction targets China is attempting to achieve, the LDAR regulations being created are setting new precedents with limited input from industry groups. These regulations offer an opportunity to explore the fringes of the rule-setting process, and offer opportunities for all of us to explore some potential new industry-best practices. Stay tuned as we continue to learn more through our various implementations of LDAR programs in China.