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What’s TRICORD’s 2-Day LDAR Training All About?

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If you haven’t heard, TRICORD’s own Buzz Harris and David Ranum are hosting a 2-day LDAR Training Event December 13th and 14th in Austin, Texas and you’re invited! In this blog post, you’ll find out what you can expect to learn and how to register for the event. And if there’s something you’re interested in that you don’t see on the agenda, please let us know!

DAY 1

LDAR Regulations

If you’re looking to learn the ins and outs of LDAR regulations, look no further. Buzz and David will cover how federal LDAR regulations are organized, how to search for specific regulations, and how to retrieve important background information. You’ll also learn how to access the Electronic Code of Federal Regulations and how to employ pdf editing tools to bookmark, highlight, underline, and comment on the important elements within a regulation. Finally, you’ll find out how to use the Applicability Determination Index to query EPA regulatory interpretations.

Method 21, Optical Gas Imaging, and Component Identification

Master the process from the masters themselves. You’ll become familiar with basic and enhanced Method 21 procedures, find out about the Alternative Work Plan (and why refineries aren’t using it) and why natural gas production facilities are turning more and more to infrared leak detection. Thinking of a re-tagging project? You’ll find out how to do it efficiently and the best tags to use.

Monitoring Equipment

In this section, you’ll discover the best ways to care for your monitoring equipment and how to keep it working properly. You’ll leave confident in your inspection skills and capable of verifying that each of your analyzers is properly certified, calibrated, operated, and maintained.

Database Audits and Common Pitfalls

End the work day learning how to prepare for EPA Section 114 requests, how to minimize your risk of database compliance issues, and the ten common database pitfalls to avoid.

DAY 2

Program Management and Quality Assurance (Plant Level to Corporate)

We’ll start the second day bright and early going over the elements of management and quality assurance that are essential to the successful administration of an LDAR program.

Regulatory Grey Areas and Interpretations

It’s not all black and white. In this section, you’ll learn about some of the most important regulatory grey areas that can affect your facility and ways to resolve issues you may face.

Emissions Calculations

Be sure that your database is calculating LDAR emissions correctly and protect yourself from liability. We’ll take you behind the scenes to understand how Method 21 ppm screening concentrations translate into kilogram/hour mass emissions.

Applicability Determination and P&IDs

Lastly, you’ll find out all about the various resources available for you in making LDAR applicability decisions. Learn how to document those decisions on P&IDS and get some tips on “reading” P&IDs.

In addition to all the great learning you’ll do, the training is a great way to network and socialize with other LDAR professionals. A happy hour at the end of Day 1 will round out the day and make you fast friends with the affable Dave and Buzz. A lite breakfast and lunch buffets will also be provided each day.

To reserve your spot, simply fill out a registration form below and email it to david.ranum@tricordconsulting.com. And please let us know if there’s anything else you’d like to see on the agenda!http://tricordconsulting.com/site/wp-content/uploads/2017/11/TRICORD-2017-LDAR-TRAINING-ELECTRONIC-REGISTRATION-FORM.docx

TRICORD 2017 LDAR TRAINING ELECTRONIC REGISTRATION FORM

Extremely detailed and realistic high resolution 3D illustration of a Hurricane approaching Texas. Shot from Space. Elements of this image are furnished by Nasa.

First a Hurricane, Next a Regulatory Crisis

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For the unprepared, a hurricane brings two storms. Once the winds and rain are over, a wave of new policies, regulations, and/or modifications kick in, invoking special reporting requirements created in the aftermath of Hurricane Katrina.

One such policy change occurred in 2007, when the Louisiana State Police (LSP) approved regulations under Louisiana Administrative Code Title 33(LAC)[1] §11103 Applicability A, mandating special reporting requirements for facilities that

[…] engaged in the transportation of hazardous materials by railcars, vessels, or barges, or the temporary storage of hazardous materials in any storage vessel not permanently attached to the ground [if that activity is within] a parish affected, or projected to be affected, by a Category 3 or higher hurricane for which a mandatory evacuation order has been issued.

But before we delve into these special reporting requirements, let’s confirm they apply to your facility. A “hazardous material,” as defined under LAC1 §11105, Requirements for Reporting B, refers to a list of chemicals in 40 C.F.R. Part 355, Appendix A (List of Extremely Hazardous Substances). The list can be searched by CAS number or chemical name.

“Temporary Storage” is described under LAC1 §11105, Requirements for Reporting B, Definitions, as storage “in a portable container” and excludes storage in pipelines or any other storage vessel permanently attached to the ground.

So if your facility stores a listed chemical onsite (excluding pipelines and grounded tanks), then your facility is subject to the regulation.

Next, consider the category of the hurricane (the requirement only applies to Category 3 and higher) and whether a mandatory evacuation was called for the parish where the facility is located. The following link provides contact information to parish emergency response offices where you can get news on the latest orders: http://gohsep.la.gov/about/parishpa.

If all the criteria are met to invoke the rule at your facility, the regulation dictates

Notification shall be given to the DPS, via electronic submittal, to the 24-hour Louisiana Emergency Hazardous Materials Hotline email address at emergency@la.gov within 12 hours of a mandatory evacuation order issued by the proper parish authorities.

Special Reporting Requirements

For any hazardous materials stored onsite that were reported in the facility’s annual Superfund Amendments and Reauthorization Act (SARA) inventory report and whose current storage is not in excess of what is typically stored at the facility, no reporting is required.

However, it is required to report those hazardous materials that were not reported in the annual SARA inventory report or which are in “excess” of what is typically stored at the facility.

Per LAC1 §11105, Requirements for Reporting C, Mechanisms and Responsibilities 1,  persons subject to provisions shall report the following within 12 hours of an order of evacuation issued by local parish authorities:

the exact nature of, and the type, location, and relative fullness of the container (i.e., full, half-full, or empty) of all hazardous materials that are located within a parish subject to the evacuation order;

the primary and secondary contact person’s phone, e-mail, and fax number; and

whether the facility will be sufficiently manned such that post-event assessments will be performed by company personnel (as soon as safely practicable) and that any releases and/or hazardous situations will be reported in accordance with existing Louisiana Department of Environmental Quality (LDEQ) and state police reporting requirements.

The regulation also requires that in addition to the notification to the LSP, “within a reasonable period of time” persons subject to the rule “shall perform a post-event assessment of those hazardous materials that were actually present in the affected area and to what degree, if any, those materials were compromised by said event and their current condition.”  Such information must be available for review by the LSP, and the LDEQ shall have access to this information.

To recap, within 12 hours of a mandatory evacuation order and with a Category 3 hurricane heading towards your facility, you must email a report listing any hazardous substances that were not reported on the facility’s SARA or which are present in quantities above those normally stored onsite.

Seems simple enough, right?

But hurricanes are not always predictable. They strengthen and weaken without warning, and evacuation orders may be announced when facility personnel are not equipped to respond within 12 hours, like on the weekend when only off-shift personnel are onsite.

Or perhaps your facility is located within a parish with low lying, exposed areas.  Authorities may decide to proceed with an abundance of caution and issue a mandatory evacuation order for a Category 2 hurricane. But then overnight the hurricane may strengthen into a Category 3. Now you’re really in a pickle.

And what defines, “excess” of what is typically stored? The regulation does not provide a definition. If you normally store one tote of hazardous material, is three considered excess storage above normal storage volumes? Using temporary rental storage tanks can also complicate the issue.

If a facility has a robust chemical approval process, which most do, this reporting may be more of a nuisance than a potential compliance issue. However, ambiguity in the regulation could allow for regulatory interpretations that cast your facility in a negative light.

Most recently, Hurricane Harvey has brought the issue to the fore, initiating these conversations between regulated facilities and state police to clarify or develop policy memos on the intent on of the regulation.

For the latest on reporting requirements that kick in after a hurricane, and other things you need to know, stay tuned to this blog.

-Kelly Bradberry

[1] Louisiana Administrative Code Title 33, Environmental Quality, Part V. Hazardous Waste and Hazardous Materials, Subpart 2. Department of Public Safety and Corrections–Hazardous Materials, Chapter 111. Reporting Requirements for Category 3 or Higher Hurricane – http://www.doa.la.gov/osr/lac/33v05/33v05.doc

Volunteer Spotlight: Laura Blohm and the Ronald McDonald House

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IMG_4924To foster a volunteer culture, TRICORD supports the individual expressions that ‘giving back’ takes for each of its employees, whether it’s donating weekends to teach local kids or raising money for cancer research through Race for the Cure. In our volunteer spotlight blog series, we highlight the causes TRICORD employees are most passionate about. We hope you find some causes you care about and learn more about some great organizations.

This quarter, we’re shining a light on the Ronald McDonald Foundation through the eyes of environmental expert Laura Blohm.

How did Laura first hear about the Ronald McDonald House (RMDH)?

Laura first became interested in RMDH in 2004, when her newborn niece required pediatric intensive care for the first days of her life. Laura credits RMDH for offering her sister and brother-in-law a place to restore themselves between visits while their daughter was receiving critical care. Generous volunteers and contributors made Laura’s sister and husband feel at home and provided support at no cost to the family.

What does RMDH provide?

RMDH provides a communal kitchen with snacks, a communal living area, showers, sinks, bathrooms, and private sleeping rooms for families whose loved ones are receiving treatment at nearby hospitals. Laura says that many of the families come from far away, and that many low income families receive overnight rooms without which they may not have a place to stay. Laura’s seen people from all across Texas, the U.S., and out of the country benefit from the support RMDH provides.

How did Laura become involved in RMDH?

Laura’s niece got better soon (she’s now a healthy teenager), but Laura never forgot the kindness shown to her family. She organized volunteer events at her high school and later through her college co-ed service fraternity, Alpha Phi Omega, to support RMDH’s mission.

When Laura became a TRICORD employee in 2015, she learned about TRICORD’s enthusiasm for volunteering and commitment to donate 10% of profits to charitable organizations. RMDH was naturally on her mind, and she now volunteers regularly with RMDH affiliated with Texas Children’s Hospital in Houston. TRICORD has also become a contributor to RMDH.

What does Laura do for RMDH?

Laura works two to three shifts a month at RMDH, making sure rooms are stocked with linens and other essential items and that the rooms are temperature controlled for a comfortable stay. When guests arrive, Laura helps them fill out the necessary paperwork and gives them a tour of the house. Laura says most guests usually only sleep a couple of hours a night, but RMDH helps make that as restful as possible. Aside from that, Laura helps with housekeeping and daily chores like making sure the pantry is stocked. Laura says, “I’ve noticed that the little things, when you’re in a situation like these parents are […] tends to go a long way.”

How does TRICORD support Laura in her volunteering efforts?

Each year TRICORD employees receive $1000 to donate to a charity or someone in need. Last year, Laura divided the amount between Star of Hope, RMDH, and a cancer outpatient group in Chicago. Within 20 minutes of submitting the online donation to RMDH, Laura received a call from a RMDH representative expressing their sincere thanks for the contribution. RMDH used the money to buy snacks for the families.

Where can I learn more about RMDH?

To learn more about RMDH and ways to get involved, check out the official website at https://www.rmhc.org/.

LDAR group

Meet TRICORD’s Fugitive Emissions Team

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TRICORD is pleased to announce the addition of Graham “Buzz” Harris and David Ranum to our fugitive emissions team, offering unmatched expertise and nationally recognized experience in all things LDAR. If you have an LDAR question or issue – or just want to say “hello” – we invite you to connect with Buzz, David, or our fugitive emissions team leader, Chris Lehmann. Here’s a brief introduction to each expert.

Buzz Harris 4Meet TRICORD Expert Graham “Buzz” Harris

Known as the “Godfather of LDAR,” Buzz brings a wealth of LDAR experience and expertise to the team. The credentials that earned him this recognition are based on his role in developing LDAR regulations and protocols, including EPA’s Method 21 monitoring protocols, and emissions correlation equations and factors. Buzz also co-authored the section on fugitive emissions in the Encyclopedia of Chemical Engineering; wrote Chapter 7 of the API Manual “Disposal of Refinery Waste,” covering VOC emissions; and contributed to the API GHG emissions protocol focusing on point source emissions and leaks. His extensive experience has led to his serving as a subject matter expert in LDAR related court cases, an advisor in Consent Decree negotiations, and a sought speaker on LDAR conference panels. Buzz has parlayed his knowledge and involvement as lead auditor in over 250 LDAR audits into LDAR Essentials and Experts training courses, which he teaches to new and mid-career professionals.

David Ranum 4Meet TRICORD Expert David Ranum

David is a long-time experienced LDAR and direct emissions monitoring expert who has conducted hundreds of LDAR audits across the U.S. for the Oil & Gas, Refining, and Petrochemical industries and has led numerous emissions studies in the U.S. and internationally involving regulators and industry alike. He has served as field lead and project manager on multiple “high stake” emissions measurement projects involving Method 21, optical gas imaging, emissions bagging, and high flow sampling. With this experience, David has developed and provided beginners and advanced training courses on infrared camera use to hundreds of technicians. He has also provided training in emissions quantification, LDAR Fundamentals, and NSPS KKK, OOOO, and OOOOa LDAR requirements. Beyond LDAR, David’s experience and expertise includes ambient air and source level monitoring applications.

Chris Lehmann 4Meet TRICORD Expert Chris Lehmann

Chris’s client base includes 38 refineries, 15 chemical plants, and numerous upstream and mid-stream oil and gas companies. His LDAR skills include auditing, training, and managing complex field projects. Chris’s engineering mindset, coupled with Six Sigma Black Belt training, expertise in SQL, and versatility with Excel, allows him “backstage” access to LDAR databases and the ability to identify issues that have gone undetected for years. Chris has led and conducted over 60 third-party consent decree and highly reactive volatile organic compound LDAR audits, managed multiple LDAR program revamps and facility-wide inventory management projects, and conducted numerous stream speciation evaluations. As a nationally recognized subject matter expert, Chris has provided specialized LDAR training to hundreds of industry professionals. Chris has made a name for himself with federal and state regulatory agencies employing EPA Method 21, optical gas imaging, bagging, and high flow sampling to characterize emissions from leaking components.

LDAR regulations can be complex, challenging, and lead to years of enforcement without the right consultant by your side. Let our experts do the heavy lifting for you.  Our Fugitive Emissions team is stronger than ever and ready to take on your LDAR needs. Give us a call at 888.900.0746 – we want to help.

What You Need to Know About the EPA’s Refinery Sector Rule and Where to Go for More Info

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ICYMI, the EPA recently answered questions regarding amendments to the Refinery Sector Rule (responses dated April 7, 2017 to questions submitted July 12, 2016 by AFPM). We’ve included take-aways from EPA responses below, and we’re hosting a Louisiana Refinery RSR Meeting on July 21 to facilitate discussion among industry peers and Subject Matter Experts about solutions to on-going challenges faced while implementing the rule.

Let us know if you’re interested; we’ll be discussing topics by section including Miscellaneous Process Vents (MPV)/Maintenance Vents, Pressure Relief Devices (PRD), Flares, Benzene Fenceline Monitoring, and more.

Click here to let us know ASAP if you’re interested in attending the meeting.

Here’s a summary of what you need to know:

For Maintenance Vents, the only time bypass requirements do not apply is when vents are used solely for maintenance, startup, and shutdown and not normal operations. Not all equipment vents require LEL monitoring; a representative vent can be designated for the vessel or equipment. Real-time calculations are not required to confirm 72lb exceptions (estimations can be used in VOC verifications, but must document vent openings). Vent releases less than 72lbs must be documented and reported. For pyrophoric catalysts, namely pure hydrogen, a system must be in place that supplies hydrogen with low enough organics levels to achieve a 10% LEL for maintenance vents.

For Bypass Monitoring, maintenance vents and activities in compliance with 63.643(c) are not considered bypass events, even if they are routed through an emission point subject to bypass monitoring or reporting. Analyzer vent exhaust is considered a miscellaneous process vent (after 1/30/2019) and not a bypass from a control device. Open Ended Lines (OEL) and PRDs in HAP service subject to 63.648 are not subject to bypass monitoring provisions of the RSR. OELs and PRDs that are not in HAP service would be subject to bypass monitoring requirements. However, non-HAP OELs that are required to be capped or plugged under another regulation would not be required to follow bypass monitoring requirements.

For Miscellaneous Process Vents, a high point bleed is not considered an MPV under active use, but MPVs are regulated under 63.648 fugitive OEL requirements when not in use.

For questions about what constitutes “Uncontrolled,” a floating roof tank is considered controlled. If the tank does not meet seal and fitting requirements of Subpart WW, Subpart WW provides compliance deadlines to meet the additional requirements, including extended compliance deadlines and alternative controls of 63.1063(a)(2)(ix). Fixed roof tank external controls that don’t meet the requirements are considered uncontrolled, and controls should be updated by the compliance date and reported in a Notice of Compliance.

For Flare Gas Instrumentation, Table 13 does not require instrumentation to be placed in unsafe locations (the phrase “where feasible” was inadvertently omitted). Account for flare purge gas not captured in flowmeters using orifice flow calculations and/or manual measurements in combination with engineering calculations. The flow rate of purge gas must be included in any calculations for flare tip velocity or combustion zone net heating value.

For PRD releases, non-HAP PRD releases have to be reported unless the root cause analysis indicates that the equipment causing the release was not in HAP service AND the release event was only from equipment not in HAP service.

For Wet Gas Scrubber (WGS) Monitoring, a pressure differential (ΔP) can be used as a monitoring alternative if a daily inspection identifies a problem in the WGS that uses the water nozzle and line inspection monitoring alternative that cannot be repaired within 12 hours and the facility had a source test to determine a ΔP operating limit.

For FCCU Oxygen Content Calculation, a wet oxygen reading can be used to demonstrate compliance, with no correction for moisture content.

For CRU Scrubbers, a chlorsorb is considered a vent exemption from Table 15 and 16 of Subpart UUU.

For more details on the EPA’s response or to find out more about the July 21st Louisiana RSR Workgroup Meeting, call or email Kelly Bradberry at kelly.bradberry@tricordconsulting.com or (225) 715-1452.