Ei "Ask a Regulator" Webinar - Consent Decree Enhanced LDAR Programs with Kosta Loukeris (EPA)

Links to the presentation and recording of the webinar are included at the end of this post.

This past Tuesday, Ei hosted Kosta Loukeris from EPA Region 5 who serve's as the EPA's national contact for LDAR on a webinar titled CD ELPs: How ELPs are Preventable. During the webinar Ei covered recent CD ELP enforcement news, focusing on three of the EPA's top LDAR enforcement priorities: Low-E / Preventative MaintenanceLDAR Inventory Clean-up, and Management of Change (MOC)

Before (and during) the webinar, Ei surveyed industry - providing industry a forum to ask anonymous LDAR-related questions to Kosta, which were answered during a Q&A session with Kosta at the end of the webinar, including:

  • What are the EPAs top LDAR enforcement priorities?
  • Of the recent ELPs that have been lodged, can you provide an overview of key provisions and what industry sectors are in negotiation?
  • What measures is the EPA seeking in O&G CD ELPs that exceed the requirements of NSPS KKK or OOOO.
  • Does the EPA have a set of benchmarks for performance with LDAR programs (such as leak rates for pumps, valves)?
  • For Low-E: if a warranty is issued by a valve manufacturer, is the site required to show proof that they've meet the provisions of the warranty for the Low-E valve to be deemed truly 'Low-E'?
  • Any update on the Alternative Work Practice (IR Camera) in lieu of Method 21? Have facilities been successful in working with the States to implement the AWP?
  • What has happened to the Uniform Standards?

Although we were not able to get to all of the questions asked during the webinar click here to see the full list we are working to provide the follow-up to all of the unanswered ones. If you had a question that was not answered on the webinar and would like it answered now, please email us at webinar@ldarprojects.com.