Understanding LDAR Requirements for Oil and Gas Operators
What is LDAR?
Also known as leak detection and repair, LDAR programs are aimed at identifying and fixing emissions leaks at chemical, oil, and natural gas facilities.
LDAR can be separated into three stages. First, specialized equipment is used to search for leaks, which are invisible to the human eye. The second stage involves characterizing the severity of leaks based on emission rate and safety concerns. Leaks are then monitored and eventually repaired and reported.
Although governments often establish their own LDAR standards, actual regulations and acceptance criteria differ from jurisdiction to jurisdiction. As responsibly sourced gas grows in popularity, some upstream oil and gas companies have even taken on voluntary LDAR measures to provide workers greater safety and produce more sustainable commodities.
Why LDAR?
There are three big reasons leak detection and repair programs have grown in adoption and enforcement.
Environmental protection. Across the globe, governments are responding to climate change with a host of initiatives. Many center around reducing greenhouse gas emissions like methane, as well as volatile organic compounds (VOCs). For example, the energy sector is responsible for about a quarter of methane emissions globally.¹
Worker and community safety. Upstream oil and gas facilities can be dangerous workplaces for field operators. Limiting workplace injuries caused by hazardous emissions allows companies to promote worker happiness and longevity. Furthermore, companies may also wish to prevent surrounding community illness brought on by longer-term exposure to toxic emissions.
Financial incentives. Limiting downside financial risks caused by lawsuits or leaky equipment is another major reason for LDAR. In the United States, the EPA estimates that the average value of lost product caused by equipment leaks is $730,000 per year per facility.²
Regulatory examples of LDAR
In the past decade, a growing number of regulators around the world have moved to mandate LDAR programs for the upstream oil and gas industry. In Canada, for example, the Alberta Energy Regulator (AER) documents its LDAR requirements in Directive 060.³ This directive stipulates the type, frequency, and status of emissions screenings and repairs, requiring companies to establish fugitive emissions management plans, or FEMPs. Directive 060 also requires FEMPs to showcase improvement in key areas over time, such as reducing total emissions from leaks as well as shortening the time between emissions detection and repair.
In America, the EPA lays out LDAR regulations in 40 CFR Subpart OOOOa, which sets expectations of survey frequencies, facilities that must be inspected, training, maintenance, and storing and reporting of data.⁴ Similar to Canada, O&G operators in the U.S. may choose between two prescribed LDAR options: (1) Method 21, which requires the use of handheld organic vapor analyzers like photoionization devices, and (2) Alternative Work Practice, which relies on optical gas imaging (OGI) cameras. Operators in the U.S. may also choose to apply to the EPA to use alternative technologies or methods, such as aircraft, satellites, drones, or continuous sensors. To date, the EPA has yet to approve any of these new technologies, but interest is growing.
Establishing an LDAR program
Broadly, LDAR can be broken down into three stages: leak identification, leak monitoring, and leak repair. In Canada, regulators often refer to LDAR programs and FEMPs interchangeably.
Leak identification
At chemical, oil, or gas facilities, field operators measure emissions potentially leaking from different kinds of components. Thus, any LDAR program must first identify where to look for methane leaks. Depending on the emission type, operators may use specialized equipment. Equipment used for methane detection may differ meaningfully from that used to detect other VOCs. For methane detection in particular, optical gas imaging (OGI) is a common approach, although some nascent technologies rely on different means of detection (e.g., continuous monitoring by way of gas sensors).
LDAR surveys typically identify, label, and track all components which have leaked before. This process is known as tagging. Operators and regulators should define and agree upon thresholds for escalatable leaks when establishing an LDAR program. These thresholds can be defined on the basis of emission rates or mixing ratios. Establishing an action plan for monitoring different components is also important.
One recent survey of methane emissions looking at some of the most leaky components at oil and gas facilities found that tanks are especially complicit, underlining a clear need for LDAR programs focused on tank inspection and remediation. 5 Other common components that represent leak risks include valves, seals and housings, pumps, connectors, compressors, and open-ended lines.
Leak Monitoring
The protocol and duration for emissions monitoring usually depends on the method used. For instance, plane-, drone-, or satellite-operated leak detection may provide sensitive assessment of larger, outdoor areas, but generally cannot provide sustained readings over time due to higher operating costs.
In Alberta, the AER determines the annual specifications of LDAR monitoring. Directive 060 mandates one to three visits per site per year, while also establishing acceptable screening methodologies and alternative technologies, provided those alternative technologies either match or outperform pre-approved methods like OGI cameras.
Some operators still rely exclusively on human senses to detect leaks. Audio, visual, and olfactory (AVO) means of leak detection remain common, although detection of certain gases can be difficult or impossible, even for trained individuals. Companies often choose to supplement AVO emissions detection with additional detection technology in order to achieve more consistent, reportable results.
Leak Repair and Reporting
If leaks are detected on site, regulators outline the steps necessary to fix them. Some leaks require equipment shutdown, which adds operational cost on top of the cost of repairs, even if the leaks themselves are small. The aim of most LDAR programs is to safely identify the leak with a defined protocol so that operations can resume and leaks from the same source can be pre-empted in the future.
Any LDAR monitoring task should be recorded. If a third party does the monitoring, the manner in which data flows from third-party to first-party should be tracked and explained. Companies increasingly rely on autonomous monitoring so that leak detections and repairs are automatically tracked and reported, and the burden on human intervention is lightened.
Detailed record keeping should allow operators to identify the source, frequency, level, and type of leak over time. This includes an assessment of the components that typically pose leak risks, and those that do not, and as a result, which deserve more monitoring. One stated aim of LDAR is to give operators a better understanding of the typical risk associated with specific components.
LDAR best practices
In order to make the best use of time and resources, consider the following best practices for LDAR:
Tag components with a barcode system to make identification quick and seamless.
If multiple leak definitions exist, use the lowest leak definition in order to head off confusion.
Use continuous monitoring systems in order to get a consistent read on emissions levels and understand your baselines.
After a leak has been repaired, consider monitoring the component daily for a period of time to ensure that the leak hasn’t resurfaced.
If possible, electronically monitor and store records of data to make compliance easy.
Hazardous Air Pollutant Emissions From Process Units in the Synthetic Organic Chemical Manufacturing Industry-Background Information for Proposed Standards, Vol. 1C-Model Emission Sources. Emission Standards Division, US EPA, Office of Air and Radiation, OAQPS, Research Triangle Park, NC. Nov 1992.
https://www.epa.gov/sites/production/files/2014-02/documents/ldarguide.pdf