A turnaround at a facility such as a refinery, chemical/petrochemical plant, or O&G asset is a planned periodic shutdown, either partial or total, of an integral process unit or the entire plant for maintenance. The industry average for major turnarounds is once every four to five years, but minor shutdowns can occur as often as every year. Process changes stemming from turnaround activities can bear significant compliance challenges, especially for the leak detection and repair (LDAR) compliance program.
LDAR is a program regulated by the U.S. Environmental Protection Agency and also by state and local agencies that require monitoring of equipment in VOC or HAPs service. Once a leak is found to be above the regulated leak definition, the regulation stipulates that the leaks must be repaired within a certain time frame. Regulated types of equipment that are subject to LDAR include pumps, valves, compressors, agitators, sampling systems, pressure relief devices or vents, instrumentation systems, capped/plugged lines, connectors/flanges, and process drains (in some areas).
A significant amount of industrial equipment is subject to these requirements. Many petroleum refineries, for example, have 200,000-plus pieces of equipment that require monitoring on a quarterly basis, which equates to more than 1 million inspections per year. As you can see, it is a significant challenge for facilities to remain in compliance with all LDAR-related requirements, especially following the LDAR inventory and monitoring impacts resulting from turnaround activities.
What to Do During a Turnaround
The following checklist contains the steps that our turnaround team considers essential during a turnaround for LDAR compliance.
Before the Turnaround
- Develop a Standard Operating Procedure to QA newly tagged areas. Before turnaround LDAR planning begins, it is beneficial to develop a procedure for verifying the quality of tagging to ensure consistency.
- Ensure that maintenance work orders are set up for all LDAR-required activities. Identify delay of repairs (DORs), chronic leakers (i.e., “bad valves”), and other pieces of equipment to be replaced and track them in your facility’s work order management system (e.g., SAP) before the turnaround.
- Obtain a turnaround scope list, such as work lists, work orders, and management of change (MOC) documents. Turnaround maintenance planners and/or process engineers develop these lists to manage turnaround planning and execution, and these documents can be used to identify LDAR impacts to all fugitive components in VOC or HAPs service.
- Discuss stream speciation and/or process changes with process engineers. Any changes to process stream composition can affect LDAR applicability; therefore, the specific changes should be researched and discussed with process engineers to determine the associated LDAR compliance impacts.
- Review the MOC list for new equipment or equipment to be taken out of order. Obtain the piping and instrumentation diagrams (P&IDs) that depict the changes. Ensure that all new equipment is inventoried and monitored within the applicable regulations time frame.
- Evaluate NSPS Subpart GGGa applicability. Minor changes to process units (e.g., installing several new valves) have been shown to trigger NSPS Subpart GGGa applicability as a “modification” for some refinery process units. Identify the number of new equipment installations and the associated emissions impacts to determine if a “modification” has been triggered.
- Develop a time table to address all TA-LDAR items. The quantity of LDAR work that needs to be addressed during a turnaround is immense, and combined with all of the mechanical work being performed simultaneously during a turnaround, it is essential to develop a thorough and flexible plan to address all LDAR items within regulatory time frames.
- Develop a plan to return all tags to a centralized location. Ensure that all maintenance contractors are aware of the importance of saving the LDAR tags, and ensure that the LDAR contractor retrieves all tags, to maintain database accuracy.
During the Turnaround
- Understand and communicate the various elements of LDAR compliance to turnaround contractors. Detail the importance of compliance with consent decree, local, state, and federal rules, and explain the cost of noncompliance to the facility.
- Ensure tag retention and database accuracy. Look for tags in the bone yard and collecting areas during each shift for LDAR tags on removed equipment, and update your database.
- Implement and track the progress of all tagging activities. Turnaround schedules often change, as does the work scope of the turnaround, making it important to have a clear picture of which LDAR activities have been completed and what needs to be completed. This allows for accurate allocation of resources to minimize costs.
- Provide support to the LDAR contractor. Answering questions from the LDAR contractor and providing supporting information (in the form of highlighted P&IDs, MELs, etc.) for turnaround items they are addressing is crucial to effectively performing tagging activities during a turnaround.
- Continuously monitor the turnaround scope to ensure that all newly added LDAR items are addressed. As new work orders are created, it is essential to monitor the changes to ensure that the LDAR work scope is updated to include all applicable items.
- Walk through the process areas using the “blind” and “system” list from maintenance to determine how to better allocate resources when the units are started up again.
- Ensure that tags are not ruined. Understand where the insulator and painting crews will be working, cover up or remove tags, and have the LDAR contractor re-hang them.
- Have a physical field presence to ensure that the importance of LDAR is understood by all personnel working during the turnaround.
After the Turnaround
- Schedule and complete LDAR inspections of “new” and “like-in-kind” equipment. After the turnaround is complete and units have been started up, LDAR inspections should be scheduled and completed for all affected equipment. Remember, in “existing” process units, tagging and follow-up monitoring is required for all “new” equipment for light liquid/gas-vapor service within 30 days (see NSPS Subpart VV/VVa) of start-up. For “new” process units subject to NSPS Subpart VVa, inventory and monitoring are required within 180 days of start-up for valves in light liquid/gas-vapor service. Chronic leakers or DORs should be completed within 15 days of start-up.
- Prepare a report of recommendations to implement during the next turnaround. Every completed turnaround is an opportunity to learn and prepare for the LDAR activities of the facility’s next turnaround. Inefficiencies that have been identified will be prepared into a report that can be used to guide the facility’s next turnaround.
Best Management Practices
- Recognize the importance of tag retention. It is expensive to replace tags, both in material and labor costs. Depending on the way you manage your tagging system, you can expect to spend $50 to $150 to replace one tag. You can reduce this cost if you remove tags or replace them during the turnaround.
- Develop an LDAR Turnaround Compliance Manual. The purpose of this manual is to provide project management and oversight structure to the turnaround, as well as field quality assurance for a comprehensive LDAR equipment inventory during the turnaround activities. It also provides a path forward to guarantee that all new equipment gets inspected properly and within the appropriate time frame after the turnaround is completed.
- Understand that planning is the key to understanding potential cost savings. Ensuring LDAR compliance after a major turnaround can be very expensive, so if you can plan for these costs accordingly and well before the scope freeze of the turnaround, you can use capital project funds appropriately rather than using your existing HSE budget, which may already be set for that year.
- Instill best practices, which should include an “evergreen” program. An evergreen LDAR program is one that is constantly being reviewed, QA/QC’d, and walked down. This includes marking up your P&IDs for changes so they remain fresh, speciating the lines for emissions calculations and rule applicability, walking down applicable lines for missing tags, and conducting midnight maintenance activities and “replacement in kinds” that were not brought forth during the MOC process.
Sage Serves You
Sage recently assisted one of its petroleum refinery clients by providing LDAR compliance oversight and QA/QC support during a major shutdown that lasted 10 weeks and involved more than 3,500 contractors working on various projects. Sage provided three full-time engineers and scientists to assist the LDAR contractor (whose staff doubled during the turnaround) in identifying jobs that impacted the LDAR program, generating work packages to complete the required LDAR tasks, and completing QA/QC of a large population of MOC and non-MOC work completed by the LDAR contractor. In the end, more than 15,000 LDAR components were impacted and Sage’s involvement, together with the client and LDAR contractor’s contributions, ensured a high level of compliance during this challenging effort.
Want more information about LDAR turnarounds? Contact our experts:
Ron Clark: 484-425-0179 or
Shane Kling: 303-681-6640 or