Do You Have To Fix Your LDAR Delay Of Repair Equipment During A Weather Induced Shutdown or Idle?
Winter weather and lingering pandemic effects present continued challenges to operating facilities. Especially when those challenges force a facility to shut down or idle. When atypical operating procedures exist, it can lead to questions related to regulatory compliance. One specific question you should be asking is if your facility’s Delay of Repair equipment needs to be repaired during idling or shutdowns. To that question, your facility should have a documented answer.
EPA allows Delay of Repair for equipment for which leaks have been detected if repair within 15 days is technically infeasible without a process shutdown. Meaning, the repair on leaking components can be held off until there is a process shutdown. Does recent idling or shutdowns due to weather conditions or power outages count as a process unit shutdown under LDAR regulations? It potentially could if not documented properly.
Process unit shutdown means a work practice or operational procedure that stops production from a process unit or part of a process unit during which it is technically feasible to clear process material from a process unit or part of a process unit consistent with safety constraints and during which repairs can be accomplished. The following are not considered process unit shutdowns:
(1) An unscheduled work practice or operational procedure that stops production from a process unit or part of a process unit for less than 24 hours.
(2) An unscheduled work practice or operational procedure that would stop production from a process unit or part of a process unit for a shorter period of time than would be required to clear the process unit or part of the process unit of materials and start up the unit, and would result in greater emissions than delay of repair of leaking components until the next scheduled process unit shutdown.
Does warm idle or process shutdown due to a natural gas curtailment count as a process unit shutdown? Based on the definition above, it potentially could if the shutdown or idling is more than 24 hours and the lines can safely be cleared in order to repair the equipment.
Despite weather events, facilities are still subject to monitoring and DOR requirements. But like any situation, it is not always cut and dry. Icy, snowy conditions may make monitoring or repair efforts unsafe. Leaking components should only be fixed when the process unit is shutdown and before the facility is brought back online, but only when it’s safe to perform the repairs.
If these types of events occur, the shutdown or idling event must be documented properly to avoid non-compliance. Documentation with a detailed explanation of the events, causes of the shut down, the extent of shut down, and reasons for it being unsafe to monitor or repair a DOR is required to be written down to document ongoing compliance.
Did you know that when you deem something as unsafe to monitor or repair, LDAR regulations require you to have a “written” Unsafe-to-Monitor Plan?
Do you know where your written Unsafe-To-Monitor plan is located? Do you have extreme weather conditions listed in the Plan?
Reach out to Ed Diaz (502) 645-3451 or Ron Clark (484) 325-0179 to help ensure you have all the proper documentation in your Unsafe-To-Monitor Plan for the facility.
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