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380 Fugitive Source Inspection

3-day lecture and laboratory course
2 CEUs

Course Description

As documented under various EPA regulations (NESHAP, NSPS, HON, and MACT), fugitive emissions of hazardous air pollutants (HAPs) from affected facility equipment must be monitored on a routine and continuous basis as part of a facility's leak detection and repair program (LDAR). In particular, these regulations specify Federal Reference Method (FRM) 21 as a procedure for identifying fugitive leaks of volatile hazardous air pollutant (VHAP) from valves, pumps, compressors, relief valves, connectors, flanges and various other pieces of equipment within a process. Equipment leak standards as identified in the regulations are designed to reduce volatile organic compound (VOC) and VHAP emissions from various components within the process.

These new regulations have placed the responsibility of fugitive emission reduction of VOCs and VHAPs on the source through their LDAR program. With these new programs comes the responsibility of agency personnel and inspectors to verify, inspect, and document the effectiveness of the source-specific LDAR program to minimize emissions. Verification of a source LDAR program meeting compliance requirements may be accomplished through a level approach. Level I involves agency records review. Level II involves on site inspection of the LDAR program, observation of source personnel performing leak detection using portable VOC analyzers meeting FRM 21 requirements, and evaluation of the data acquisition system. Finally, Level III involves agency personnel performing leak detection using portable VOC analyzers meeting FRM 21 requirements.

This course is specifically designed for field inspectors who have the responsibility to evaluate compliance with EPA regulations involving source LDAR programs designed to minimize fugitive VOC and VHAP emissions from specific process equipment. The course briefly reviews applicable regulations and sources affected by those regulations, the type of flanges and valves and other process equipment covered by the regulations, and how EPA defines leaks. Specific to this course offering, a thorough review of FRM 21 will be presented, along with review of field portable instrumentation. Presentations and demonstrations will involve the operation, check-out, calibration, and maintenance of field portable VOC analyzers through approved checklists. In particular, field demonstrations associated with proper orientation and use of portable analyzers in evaluating fugitive emissions from plant process equipment as part of an agency fugitive leak inspection program will be documented. The participant will learn how to establish an agency fugitive leak inspection program, defining organization structure and responsibilities, equipment needs, selection, storage, calibration and maintenance, and standardized inspection techniques using audit checklists. In addition to the learning sessions, the course will offer structured panel discussions, field video tape presentations, and laboratory demonstrations of auditing instrumentation. All participants will receive a Course Manual, valuable handouts, and standardized auditing procedures that can be used in the field for reference when planning and administering an agency source inspection.

Major topics

• Regulations Associated with Fugitive Source Emissions
• Chemical and Physical Properties of Fugitive Emissions
• Applicable Source Categories of Fugitive Emissions
• Defining Leaks
• Federal Reference Method (FRM) 21
• Survey of Portable Instrumentation
• Agency Fugitive Leak Inspection Program
• Performing an Agency Inspection for Fugitive Leaks
• Future Tools For Determining Leak Detection
  • Smart LDAR
  • CellNet Data Systems and Adsistor Ring Sensor