Third Party Audit Guidance by EnRUD Resources, Inc.

1.0 PRE-AUDIT ACTIVITIES

Auditor shall follow the pre-audit activities:

1.1 Review of all Federal, State and Local regulations that apply to the audited facility.

1.2 Utilization of a tool such as a pre-audit questionnaire to request all needed information to prepare for the on-site audit activities.

1.3 Development of an interview schedule to identify and coordinate the refinery resources that will be interviewed as part of the audit.

1.4 Confirm complete understanding of the scope, objectives and timeline for the audit.

1.5 Prior to any work at each refinery, the Auditor must satisfy any contractor requirements for entry such as Contractor orientation training, drug screening or any other mandated requirements. Time to meet these requirements will be built into the audit.

1.6 Prior to the start of the audit, the auditor will conduct an opening conference to outline the work that will be conducted during the audit. As part of this conference a daily update time will be announced so interested parties can listen to a summary of the day's auditing activity. Also a closing conference will be announced to provide a final update on the audit prior to the Auditor leaving the site.

1.7 The Auditor shall provide the monitoring equipment to be used for the comparative monitoring activity. The Facility shall be informed of the type of equipment to be used prior to the audit. Only intrinsically safe rated equipment will be acceptable. The Auditor shall also have a backup plan for providing replacement-monitoring equipment should the original equipment fail.

1.8 An agreement on calibration gases shall be reached prior to the audit. If the Auditor is to provide the gases they must be on site and ready for use prior to the audit. An internal approval process may be required prior to bringing these gases on site.

1.9 Establishment of a monitoring plan for the comparative monitoring will be agreed upon prior to the audit.

2.0 REVIEW OF WRITTEN LDAR PROGRAM

Audit shall include a review of the facility written plan including but not limited to:

2.1 Program was established within 180 days after the Date of Entry.

2.2 System is in place to ensure continuing compliance with written plan changes and updates.

2.3 Establishment of a refinery-wide leak rate goal on a unit-by-unit basis and an evaluation of the performance to meet this goal.

2.4 The identification of all equipment in light liquid and/or in gas/vapor service that has the potential to leak VOCs, HAPs and VHAPs.

2.5 Procedures for identifying leaking equipment.

2.6 Procedures for repairing and keeping track of leaking equipment.

2.7 The process for evaluating new and replacement equipment to promote consideration and installation of equipment that will minimize leaks and/or eliminate chronic leakers.

2.8 A definition of "LDAR Personnel" and the process for accountability, and identify the person or position that will be the "LDAR Coordinator". Verify the person has the responsibility to implement improvements to the LDAR program.

2.9 Procedures (e.g., a Management of Change program) to ensure that components subject to LDAR requirements added to each refinery during maintenance and construction are integrated into the LDAR program.

2.10 Procedures to ensure sensory leaks are reported and acted upon within the appropriate timeframe.

3.0 REVIEW OF TRAINING PROGRAM

Audit shall include a review of the facility's training program. The Auditor's judgment based on pre-existing experience and benchmarking with other programs shall be the recommended standard for the evaluation. Work shall include but not be limited to:

3.1 Is a proper Training Program established?

3.2 For the facility employees newly assigned to LDAR responsibilities: Has the Facility required and provided training prior to employee beginning such work?

3.3 For the Facility employees assigned LDAR responsibilities, such as monitoring technicians, database users, QA/QC personnel and the LDAR Coordinator: Has the Facility provided and required completion of annual LDAR refresher training?

3.4 For all other the Facility employee operations and mechanical personnel, such as operators or mechanics performing valve packing and designated unit supervisor reviewing for delay of repair work: Has the Facility provide and required completion of an initial training program that includes instruction on aspects of LDAR that are relevant to the person's duties? Was refresher training for these personnel performed in a timely matter?

3.5 If contract employees are performing LDAR work, has the contractor provided its training information and records to the Facility?

4.0 REVIEW OF AUDIT PROGRAM

Audit shall include a review of the facility's audit program including but not limited to:

4.1 Is there a LDAR audit program?

4.2 Are processes and procedures in place to correct non-compliance issues and are written records maintained of this activity?

4.3 Has the LDAR audit program been integrated into the existing facility audit and corrective action program?

5.0 REVIEW FIRST ATTEMPT AT REPAIR

Audit shall include a review of the facilities first attempt at repair including but not limited to:

5.1 Has the Facility implemented "first attempt at repair" using the appropriate leak rate definitions? 5.2 (Optional) Does the Facility have a procedure to evaluate the "first attempt at repair" program to determine if repairs improve or hamper leaks?

6.0 REVIEW LDAR MONITORING FREQUENCY

Audit shall include a review of the facility's monitoring frequency including but not limited to:

6.1 Has the Facility implemented the proper leak definitions on equipment types basis on Local, State, and Federal regulations?

6.2 Has the Facility implemented the proper monitoring frequencies based on the current applicable regulations?

7.0 REVIEW ELECTRONIC MONITORING, STORING AND REPORTING OF LDAR DATA

Audit shall include a review of the facility's monitoring frequency including but not limited to:

7.1 Has the Facility continued to maintain an electronic database for storing and reporting LDAR data?

7.2 Does the Facility use dataloggers and/or electronic data collection devices during all LDAR monitoring?

7.3 Has the Facility or its designated contractor used its/their best efforts to transfer, on a daily basis, electronic data from electronic datalogging devices to the electronic database?

7.4 For all monitoring events in which an electronic data collection device is used, has the collected monitoring data included calibration information, operator identification, and instrument identification? 7.5 If the Facility used paper logs where necessary or more feasible (e.g., small rounds, re-monitoring, or when dataloggers are not available or broken), was a record, at a minimum, the identification of the technician undertaking the monitoring, the date, monitor reading, and the identification of the monitoring equipment captured?

7.6 Does the Facility have a reliable backup system for their data management software?

8.0 REVIEW QA/QC OF LDAR DATA

Audit shall include a review of the QA/QC of LDAR data including but not limited to:

8.1 Does the Facility have a procedure to ensure a quality assurance/quality control ("QA/QC") review of all data generated by the LDAR monitoring technicians?

8.2 Does the contractor review the monitoring data before submittal to the Facility?

8.3 Is the contractor review process adequate to uncover data errors?

8.4 Is the daily monitoring report periodically reviewed?

9.0 REVIEW OF CALIBRATION AND CERTIFICATION RECORDS

Audit shall include a review of the calibration and certification records including but not limited to:

9.1 Are the calibration gases of a methane/air mixture?

9.2 Does the Facility have certification papers on each of the calibration gases with the required information as listed in 40 CFR Part 60, EPA Reference Test Method 21?

9.3 Are all calibrations of LDAR monitoring equipment in accordance with EPA Reference Test Method 21?

9.4 Are there daily calibration records for the instruments that were used for monitoring? Are they properly filled out and filed?

9.5 Are there quarterly certification records for the instruments that were used during each quarter of monitoring? Are they properly filled out and filed?

10.0 REVIEW DELAY OF REPAIR

Audit shall include a review of the delay of repair process including but not limited to:

10.1 Does the Facility have a written delay of repair procedure?

10.2 Is there a required sign-off by the unit supervisor, which position was identified in the written program, that the piece of equipment is technically infeasible to repair without a process unit shutdown, before the component was eligible for inclusion on the "delay of repair" list?

10.3 Has it been demonstrated that the Facility made every effort to repair the leak before placing the component on delay of repair?

11.0 REVIEW RECORDKEEPING AND REPORTING REQUIREMENTS

Audit shall include a review of the record keeping and reporting requirements including but not limited to:

11.1 Is the Facility keeping the proper records per any Local, State, or Federal regulations?

11.2 Are records being maintained for the duration period as stated in the Local, State, or Federal regulations?

11.3 Has the Facility submitted to the state agency their semi-annual or periodic reports on a timely basis?

11.4 Is the information provided in the semi-annual or periodic reports meet the criteria as listed in the Local, State, or Federal regulations?

12.0 FIELD ACTIVITIES

12.1 Comparative Monitoring: As part of the LDAR audit, comparative monitoring shall be conducted on the following equipment. This is a suggested method. The Facility will entertain any suggestions by the auditor for more appropriate methods based on auditor's experience and benchmarking with industry standards. The Facility may, at their discretion, have the contract LDAR technician monitor the same components as the auditing team. Valves and Control Valves- Ten (10) percent of the total valves in the LDAR program. Pumps- Ten (10) percent of pumps in the LDAR program

12.2 Verification of Proper Tagging: As part of the LDAR audit, field verification of proper tagging will be conducted by selecting random sections of process units, inspecting those selected areas, reviewing all light and heavy components within those areas, verify proper identification by comparing field information with P&ID and stream data. Approximately three (3) percent of each process unit will be randomly reviewed. If an alternative monitoring plan is agreed upon, a complementary method of reviewing components may be suggested by the Auditor and approved by the Facility.

12.3 Verification of "Leaker" Tagging: As part of the LDAR audit, field verification of proper "leaker" tagging will be conducted by selecting random sections of process units. Approximately three (3) percent of each process unit will be randomly reviewed for proper leak tags. If an alternative monitoring plan is agreed upon, a complementary method of reviewing components may be suggested by the Auditor and approved by the Facility.

12.4 Delay of Repair Verification: The audit will verify that 100% of "delay of repair" components are properly tagged. The database list shall be compared with the fieldwork.

12.5 OEL/Sample Systems/Plug Audit: For the same areas that are being verified for proper tagging, the audit will include a review of proper management of open-ended lines, sample systems, and verify the presence of plugs in lines as appropriate.

12.6 Observation of LDAR Technician: The calibration of instruments and monitoring techniques will be observed and reported on.

13.0 POST AUDIT ACTIVITIES

13.1 A written and electronic audit report will be prepared and submitted to the Facility detailing the findings of the audit. The draft of this report shall be submitted to the Facility for comments. Once auditor has received comments then a final report will be provided to the Facility.

13.2 Any learnings that would improve the quality of the program will be incorporated into the next audit plan.

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