HRVOC LDAR AUDITS - A Trend that will continue.....

The federal and state environmental regulating authorities have always performed periodic checks to insure companies were complying with dictated mandates. In the mid 1990's the EPA began performing multimedia audits of the petroleum refining industry. As a result of these efforts the EPA, state and local authorities signed binding legal arrangements (called Global Consent Decrees) with several companies containing enforcement stipulations, civil fines, and enhanced LDAR programs.

Contained within these enhanced LDAR programs was the requirement for periodic 3rd party LDAR audits. The state of Texas has proposed additional regulations and changes to current regulations that will affect the non-attainment areas. These sweeping additional changes require, among other things, periodic 3rd party LDAR audits. California's South Coast Air Quality Management District is considering legislating periodic 3rd party LDAR audits. A dynamic that began with the Global Consent Decrees and is finding its way into many state and local LDAR regulations is periodic 3rd party audits. The regulating entities struggle with strategies to comply with the 1990 Clean Air Act pollutant reduction goals. One thing is clear; they want to ensure the data gathered is valid. After all, this information is plugged into air pollutant models which are used to develop emission reduction strategies far into the future.

The reductions of HRVOC, from the LDAR component of emissions, are critical to meeting the goals set forth in the 1990 Clean Air Act. The regulating entities need data they can count on. Thus, it is highly probable that mandated LDAR audits, not just HRVOC LDAR Audits, are "A Trend That Will Continue". Every facility regulated by the new HRVOC rule in the Houston/Galveston non-attainment area will be required to have once every two calendar years an independent third party audit (not your contractor) performed. These audits are comprised mainly of three areas: 1) A field audit 2) Comparative monitoring 3) Review of previous monitoring data or a LDAR database audit. The field audit will require an experienced "LDAR" individual to evaluate the LDAR program for components that should have been tagged/monitored or inspected and were not. This process will require LDAR program and process knowledge.

The second aspect, comparative monitoring, has a requirement as to when it should be performed, how many and which components shall be in the sample population. The third aspect will require an individual with database and LDAR regulatory experience to evaluate the monitoring process of your in-house or contractor monitoring. The owner shall give verbal notification of date to appropriate agency at least 30 days prior to an audit date and copies of audit report have to be submitted to appropriate agencies within 30 days of audit completion Facilities should schedule well in advance to insure that they have secured services of organizations with the proper skills to properly perform these tasks.

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