Can Your LDAR Database Survive an EPA...

3/8/16 Can Your LDAR Database Survive An EPA Audit?

Can Your LDAR Database Survive an EPA Audit??

Chen Zhu

David Ranum


Three Reasons Why EPA is Interested in Your LDAR Database


#1 Easy to Ask for:• Database can provide information on the compliance status of

most regulations.

• Records are all conveniently in one place.

• Electronic format therefore easily reproduced.

• Meets the definition of “reasonable request” under the Clean Air Act


#2 Easier Enforcement• Little argument over compliance issues – you’ve documented

them!

• Clearer penalty calculations


#3 Bigger Return for the Inspection Dollar

• Equipment

• Personnel

• Travel


The Section 114 Request

• Purpose – Determine if facility is in compliance with CAA.

• Requested information to be provided within 30 days.


The Section 114 Request - Organization• Enclosure 1 Information Request

• I. Instructions

• II. Definitions

• III. Questions

• Enclosure 2 List of Output Fields for LDAR Compliance Queries


Enclosure 1: The Information Request• Trade secrets or confidential business information are not

exempted.

• Signed authorization that all information is true and complete\under penalty of law.

• Provided information can be used in an administrative, civil or criminal action.


I. Instructions• Separate response for each question.

• Identify each person responding to any question.

• For each question, identify document consulted, examined or referenced.


II. Definitions• Document

• Person, You, Yours

• Masculine words shall also apply to the femine version, singular words shall be construed in the plural and vice-versa.


III. Questions• Back up file in electronic format of the fugitive emissions monitoring

records database for the past 5 years.

• Name of the LDAR Contractor

• Component information for all components in the LDAR program


III. QuestionsFor the same records, provide the results of queries designed to show compliance with the following regulatory requirements:

Final Repair Attempts

2-Month Re-Monitoring

1st Repair Attempt

DTM Monitoring


Enclosure 2 List of Query Output Fields

Final Repair within 15 Days:

DTM Monitoring:


What Do You Need to Prepare for A Database Audit?

• How does EPA conduct a database audit? What are they looking for?

• What do you need to prepare for a database audit?


How Does EPA Conduct A Database Audit?• Request a backup of your database (i.e. bak. file) (5 years)

• Request a master table of component information

• EPA will import the bak. file into their audit software (i.e. Access, SQL)

• EPA will request your facility to run specific queries (Access preferred)


1. A database *.bak file is created using SQL.

2. Unless you know SQL you will have to have your IT dept. do this for you.

3. Because this will be a large file (maybe 1 G-byte or more) you will probably have to send this on a flash drive or via a FTP (File Transfer Protocol) site.

4. Note: EPA expects to receive your *.bak file 10-30 days after request.

Create A *.bak File


What Is A Component Master Table? • Unit Name (e.g. Alky)

• Type of Component (e.g. pumps, valves, etc.)

• Class of Service (i.e., GV, LL, HL)

• Number of each type of component (e.g. 23,500 valves)

• Regulatory applicability (e.g. VV, VVa, HON, etc.)

• Current monitoring method (e.g. M21, AVO, etc.)

• Current leak definition for each component type (e.g. 500 ppm, 2000 ppm etc.)

• Current monitoring frequency for each component type (e.g. Quarterly, Monthly etc.)


Preparing For A Database Audit


How Do You Prepare For A Database Audit?

Export Database

into Access

Select Tables (e.g.

Component, Inspection

History)

Join Selected Tables in Access

Select the Fields

Apply the Criteria Using

Database Terms Only

Save and Run the Query


Step 1: Get Your Data into Access


Step 2: Select Tables Select Tables (e.g. Component,

Inspection History)


Step 3: Join The Tables Join Selected Tables in Access


Step 4: Select The Fields Select the Fields


Step 5: Apply The Criteria Apply the Criteria Using

Database Terms Only


Step 6: Save and Run Save and Run the Query


Typical Queries EPA Will Ask You to Run• Component Monitoring Analysis

• NTM• DTM

• Two Month Valve Monitoring Analysis• Repairs

• First Attempt• Final Attempt• DOR• Follow-Up Inspections

• 3% DTM Rule• Technician Monitoring Efficiency• LDAR Inventory Accuracy


Typical Queries EPA Will Ask You to RunNTM Components Monitoring Analysis :

• Valves

• Pumps and Agitators

• Connectors

• PRVs

• AVOs


Typical Queries EPA Will Ask You to RunDTM Monitoring Analysis:

• Equipment Category

• Date Placed Into Service

• Date Of Initial Monitoring

• Annual Monitoring Records


Typical Queries EPA Will Ask You to RunTwo Month Initial Valve Monitoring Analysis:

• Valves in LL/GV hydrocarbon service must be monitored for 2 consecutive months after being placed into service.


Typical Queries EPA Will Ask You to RunRepairs Within Required Timeframe:

• First Attempt Repair• Equipment Type

• Subject Regulation

• Monitoring Date

• Inspection Reading

• Date Of First Attempt At Repair



• Final Repair or DOR Assignment• Equipment Type

• Subject Regulation

• Monitoring Date

• Inspection Reading

• Date Of First Attempt At Repair

• Final Repair Date/DOR Assignment Date



• DOR Repair At Shutdown• Date Put On DOR

• Unit Shutdown History

• DOR Repair Date


Typical Queries EPA Will Ask You to RunFollow-up inspections:

• Tag Number

• Monitoring Date and Reading

• First Attempt Date and Reading

• Final Repair Date and Reading

• First Month Remonitoring Date and Reading

• Second Month Remonitoing Date and Reading


Typical Queries EPA Will Ask You to RunNSPS/HON 3% DTM Classification

• DTM percentage in newly constructed units (built after 1981) can not exceed 3%. This does not apply to units brought into VV, VVa or HON through reconstruction or modification. 0

1

2

3

4

5

Unit A Unit B Unit C Unit D

DTM Valves / All Valves

Unit A Unit B Unit C Unit D

1950 1985

1985

1950


Typical Queries EPA Will Ask You to RunTechnician Productivity and Method 21 Implementation Analysis:

• Monitoring Efficiency

• Time Between Monitoring Event


Typical Queries EPA Will Ask You to RunLDAR Inventory Accuracy:

• LDAR Inventory Changes

• Orphan Tags

• Instrument Use


Post-Processing Of Course……..Post Processing:

• Out Of Service

• Unit Shutdown

• Outside the Evaluation Period


Responding to An Database Audit Request


Responding to an Database Audit Request

Don’t Panic & Don’t Procrastinate

• Responding quickly, honestly and in a cooperative manner will benefit you in the long run.

• Remember – full disclosure of relevant information is required.



Bring in legal consul and have them involved in every step of the response process.


Responding to an Database Audit RequestDevelop an Action Plan and Timeline


Responding to an Database Audit RequestImmediately open discussions with the Agency



Begin investigation of potential compliance issues immediately

Include legal consul in on the investigations to protect the results under attorney client privilege & attorney work product doctrine.

Begin investigation of potential compliance issues immediately


The End……

Questions…..

Can Your LDAR Database Survive an EPA...

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