The project site is an 85,000-barrels per day petroleum refinery in the Rocky Mountain Region. The client
requested that Trihydro provide LDAR program monitoring and management support for compliance with the LDAR
requirements of New Source Performance Standard (NSPS) Subparts A, VV, VVa, GGG, and GGGa at the refinery.
The project also includes performing routine monthly BWON sampling, QQQ drain inspections, and transitioning
of the LDAR database.
In February 2012, Trihydro commenced the routine LDAR monitoring and management, BWON sampling, and QQQ
drain inspections at the refinery. At this time, the LDAR program consisted of approximately 16,000
components and involved approximately three full time personnel. Trihydro staff continually enhanced the
LDAR program to improve the component inventory, the LDAR database, quality assurance/quality control
(QA/QC) program, and management-of-change (MOC) process.
Trihydro performed many upgrades and improvements to the refinery LDAR program since being retained to
manage the program.
Over this time, the LDAR program has grown and changed significantly by adding new process units, upgrading
units, and units triggering new regulatory requirements such as NSPS GGGa.
Through collaboration with refinery staff and the LDAR Coordinator, we have been successful at keeping the
program up-to-date and compliant with the regulatory compliance and monitoring requirements. Additionally, a
variety of processes and procedures were implemented and refined to streamline and improve the program in
terms of efficiency, QA/QC, and compliance. These included transitioning calibration records to the LDAR
database for retention of calibration records, creating custom rules in the LDAR database to track
monitoring of vacuum trucks and Subpart QQQ inspections to improve data management, streamlining the
leak/repair procedure and DOR procedure, increasing LDAR awareness, ownership, and compliance between
environmental health and safety, operations, maintenance, and contractors, and reducing the number of
difficult-to-monitor (DTM) components to below the required 3% for each process unit.
These achievements contributed to a reduction in annual estimated emissions from 95 tons per year in 2012 to
25 tons per year in 2018.
The LDAR program at the refinery has been through four consent decree third-party LDAR audits since Trihydro
assumed management of the program. The initial audit was completed in June 2012, just three months after
Trihydro assumed management of the project. Each subsequent audit starting in 2014 has shown continued
improvement and a reduction in systemic compliance issues.
Since undertaking the project in 2012, the scope of the project has expanded to include monthly cooling
tower/heat exchanger monitoring and the LDAR program inventory has increased to approximately 26,000
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