LDAR

How the Revised SP001 Standard Affects Your SPCC Plan

March 21, 2018

An industry standard that is incorporated into many Spill Prevention, Control, and Countermeasure (SPCC) Plans has been updated. How does it affect your facility’s SPCC Plan?

Spill prevention and countermeasures – SCS Engineers

The Steel Tank Institute (STI) recently released an updated version of SP001 – Standard for the Inspection of Aboveground Storage Tanks. This document is the industry standard used in most SPCC Plans for inspection guidelines and integrity testing for shop-fabricated aboveground storage tanks. In a typical SPCC Plan prepared by SCS Engineers, your monthly and annual inspection forms, and tank integrity testing frequency requirements, are based on the criteria provided in SP001.

Summary of Key SPCC-related Items in the Revised SP001 Standard:

  • Monthly and annual inspection forms have been updated.
    • The inspection forms include revised questions that should help facility staff with improved clarity on inspection criteria.
    • The inspection forms have been reformatted and the length of the forms has been reduced.
  • The integrity testing inspection schedule and evaluation criteria remain consistent with the previous SP001 edition.
  • There is a new appendix with guidance aimed at inspection of hot-mix asphalt tanks.

Do you need to amend your SPCC Plan because of this revised industry standard?
No. We recommend incorporating the updated inspection forms during your next SPCC Plan Amendment or 5-year renewal.

How do the changes affect the implementation of your SPCC Plan?
The inspection criteria have been simplified, and more flexibility is allowed with the revised inspection forms. This will help make your inspection process easier and of higher quality.

 

Need help sorting out the details of the revised standard, or have an SPCC Plan that needs amending or is due for a 5-year review?

Call Jared M. Omernik, PE or Christopher J. Jimieson, PE to stay on top of  your SPCC needs  in Iowa and Wisconsin. SCS has professionals with the expertise to support businesses with SPCC plans in every state.

Please contact to speak with your local expert.

 

 

Posted by Diane Samuels at 6:00 am

Leak Detection and Repair – LDAR Fugitive Emissions

March 7, 2016

 

Fugitive emissions come in all shapes and sizes, are found in several industry types, and the constituents entrained in them generally have potential negative impacts on our health and the environment.  That being said, no wonder they are called “fugitive” emissions.  It seems to be in our human nature to seek out, capture, and prevent any sort of fugitive activity.

 

LDAR and other environmental and compliance services are available from SCS Engineers.
LDAR and other environmental and compliance services are available from SCS Engineers.

Long story short, an escapee from San Quentin and any uncontrolled methane air molecule may be more similar than we may presume.  In fact, a common LDAR practice is to use an infrared imaging camera; similar to the camera often used in search of fugitive criminals.

On a serious note, fugitive emissions are something that both industry and regulators have been focused on for decades, and the past and present efforts made to limit them are no less than remarkable.

Specific to Onshore Oil and Gas Exploration & Production, the Federal Regulations applicable to fugitive emissions are fairly young.  Finalized in 2012, NSPS OOOO is no longer a toddler and is in the middle of growing into NSPS OOOOa (Public Comment Deadline March 11, 2016).  On a national scale, NSPS OOOOa will expand fugitive emission monitoring and control requirements (VOC’s and methane) to several facility types associated with the industry and is expected to be finalized before the close of 2016.

In California, fugitive emissions from Onshore Oil and Gas Exploration & Production have been regulated for a long time.  In fact, the O&G industry in Santa Barbara County has dealt with fugitive emission requirements since 1979.  Since then SCS Engineers has been assisting with fugitive emission monitoring for our valued clients.  Today, SCS Engineers provides the Oil and Gas Exploration and Production industry with efficient and effective LDAR services.

So fear not, SCS Engineers is ready to supply the knowledge and skill set you need to stay compliant, maintain your operations, and respect your bottom line.  Remember, unless the doors are closed, pumps are turned off, and equipment is flushed and plugged; fugitive emissions requirements and LDAR will likely still apply. 

If you are considering a new LDAR program, restoring an existing program, or are still trying to figure out what LDAR actually is, below are a few basic pieces of advice:

Applicability:  Determining Federal vs. State oversight is the first step.  Non-Major Source Oil and Gas Production facilities are either subject to NSPS OOOO (soon to be OOOOa) or a related State specific rule (i.e. Colorado Regulation 7).  Once oversight is determined, then there may still be exemptions for your facility (i.e. facility constructed before August 23, 2011).  And finally, once regulatory oversight is confirmed and you determine that LDAR is required for your facility, then the last step is to figure out which equipment is applicable (i.e. VOC content > 10% by weight).  Basically, an applicability determination can be daunting.

Equipment: EPA’s Method 21 is historically and currently referenced in all LDAR regulations.  Method 21 requires an instrument such as the Flame Ionization Detector (FID) or Photo Ionization Detector (PID).  More recently the Optical Gas Imaging (OGI) Camera has been included in LDAR regulations and utilized in LDAR programs.  Presently, there are several instrument technologies that exist and are in the works, but not yet mainstream in Oil and Gas sector.  Ultimately, if you were to find yourself conducting LDAR monitoring at your oil and gas facility tomorrow per an established regulation, you would most likely need to use an FID or OGI.

Recordkeeping:   Personally, I like the simplicity of using paper forms for field notes; however, the old-fashioned way comes with risk. The up-front and ongoing data involved with an LDAR program is too much for maintaining a paper to computer process, regardless of how organized you think you are. Therefore, a computer database platform is recommended and necessary for managing your LDAR recordkeeping. Beyond just recordkeeping, a database platform can organize schedules, alerts, generate reports, extract trends, and many other applications to help keep your LDAR program compliant.  One such platform worth considering is SCSeTools™.  This cloud-based software can provide the database capabilities used on the desktop, but almost more importantly, provides mobile data input capabilities with the SCS MobileTools™ application fit for Android and IOS systems. Keep the fugitives from escaping, and document containment for the authorities!

If you are not already implementing an LDAR program at your Oil and Gas Production Facility, it may be on the near horizon; especially after Leo’s recent Academy Award speech.

 

Marsalek_LucasAbout Lucas Marsalek: Lucas has been an Environmental Consultant for over 8 years; he applies his expertise as a leader for oil and gas production environmental and regulatory compliance projects. Marsalek has a B.S. in Forestry and Natural Resource Management from California Polytechnic State University, San Luis Obispo, CA.

Whether you want to discuss LDAR or Dodger baseball, don’t hesitate to contact me, or SCS Engineers.

 

Resources:

Learn more on the SCS service pages and read SCS project case studies from across the nation to help fine tune your program.

 

 

Outside links to the EPA proposed rulemaking website:

 

Posted by Diane Samuels at 6:00 am