This July, Ei has been proud to introduce our LDAR technologies, as well as to provide services, to challenging projects in China through our partnership with Sage Environmental Consulting. The regulatory environment in China is very challenging with tight timelines, decentralized rulemaking, and ever-changing LDAR rules. On top of this, local technical LDAR knowledge is very hard to come by, and the local technician labor pool is extremely inexperienced. Safe to say, the challenges faced in China can only be overcome through technical expertise and technology.
(Ever Changing) Regulations
Currently, Chinese industries are under a province mandate to implement a traditional LDAR program before the end of the year, however, the exact regulatory requirements are left to the local regions to decide - there's limited centralized rulemaking (such as we have in the United States) that outlines the specific technical requirements for these LDAR programs. Regionally, the rulemaking process coming from the local EPBs (Environmental Protection Board) does not stick to "traditional" rulemaking timelines - with new proposed drafts of the LDAR rules being released mid-way through the current compliance period - leaving industry with a difficult decision - do we implement what has been finalized? Or do we implement more-strict version that's already been released for comment?
To adapt to these changing regulatory requirements, such as what wt% VOC determines "in LDAR service" vs not, old school P&ID highlighting practices fall grossly short of fulfilling project needs. If the "in LDAR service" definition changes - requiring updates to the P&IDs - the only way to do this is to re-print and redo from scratch the P&ID. A huge waste of time that the tight regulatory timeline of these projects cannot support. Furthermore, 11x17" color printers are difficult to find in parts of China.
A better practice is to electronically highlight the P&IDs with electronic markups - if anything changes - it's possible to simply update the changes. Furthermore, if plotted correctly, the P&IDs become text-serchable - greatly increasing the P&ID highlight and field flagging time.
A best practice is to simply do away with highlighting markups, and in place use software to make automatic LDAR highlights through data that is integrated in the P&IDs. As the rules and requirements change, highlights can be instantly regenerated - nearly eliminating the re-highlighting time.
Experience, Training, and Quality Control
The most cost effective way to execute the loads of field work (flagging, tagging, documenting, monitoring, and repairing) associated with these projects is to use local technical labor. The challenge with this, however, is that these technicians (and the companies who supply them) have hardly any knowledge of LDAR - and even those who "know" LDAR often don't know the right thing - a dangerous situation. This requires two things: hands-on detailed training from subject matter experts, and technologies to automate and eliminate error-prone manual processes and data collection.
Ei's FieldTech Toolbox™ software is being successfully implemented to eliminate as much manual data entry as possible (while still meeting regulatory requirements) and to implement quality controls to instantly help these technicians and ultimately prevent them from collecting bad data. During the documentation phase, we pre-load FieldTech Toolbox™ with simplified, pre-determined data picklist options to ensure data consistency across a large, inexperienced team. We also set-up customized quality controls to notify and/or prevent the technicians from collecting bad data - including entering the wrong tag number, documenting components which have already been documented by another technician, or location description conformance.
Best Practices in Managing the Inventory and Monitoring Data
With large teams of inventory personnel (>30 personnel per unit), data management will make or break the project. Stick to inefficient management practices and you'll succeed in both not meeting the project deadline and not giving the field crews enough information to do their job accurately, not a good situation!
Using our FieldTech Toolbox™, we're are able to send documenting and monitoring crews out into the field in teams of two: one technician with an intrinsically safe tablet running the software paired with another technician's monitoring instrument. These dual-purpose teams are able to both document and monitor at the same time - eliminating multiple trips into the field - saving time reducing the chance for monitoring oversights. Better yet, with two sets of eyes on every component - components and leak interfaces have a much reduced chance of being overlooked.
Daily, with our FieldTech Manager™ software, we import and compile the day's data in seconds (even across teams of >30 technicians). This data is instantly QA'd, so any issues can be communicated to the field crews before the next days work. For the next day, the we compile ALL of the unit's data (even from other technicians) and send the technicians out with the entire unit's worth of inventory data - helping them know exactly what's been done previously - eliminating wasted time.
With ever-changing regulatory requirements in an environment limited technical LDAR resources, the key to success is proving to be leveraging industry-leading technologies, best-practices, and technical knowledge. Ei is proud to be supporting Chinese industries during this busy and transformational environmental regulatory time.