The United States has had a long history of implementing various regulations, especially in the area of reducing carbon emissions. With new technologies and methods evolving in a lock-step fashion to these legislative changes, the oil and gas industry has seen remarkable transformations in its LDAR methods over the past few decades. To better grasp the whys and wherefores of LDAR, it’s useful to have a basic knowledge of relevant regulatory history. Here are a few footnotes in a simplified timeline of the history of LDAR in America.
Although most LDAR methodologies used today by companies have come about in the last couple of decades, the idea of reducing emissions is one that stretches all the way back to the mid-twentieth century. Many modern-day programs have their genesis in the Air Pollution Control Act of 1955, which later morphed into the Clean Air Act of 1963, and eventually was amended in 1970 to include vehicle emissions.
This piece of legislation gave the Environmental Protection Agency (EPA) the authority to, among other things, establish universal air quality standards to protect the public and environment.
Establishment of LDAR Practices
During the eighties and nineties, legislation was amended yet again, to include petroleum refineries and chemical processing plants that emit volatile organic compounds (VOC’s) and hazardous air pollutants (HAPs). The agency began conducting audits and pursuing enforcement actions in these industries in hopes to reduce these emissions.
After many years of in-field efforts trying to figure out how to implement new LDAR programs, the EPA began it’s first enforcement initiative in the early 1990s. This was an initial version of Method 21 which was first promulgated in the early 1980’s, and would later become a staple in the industry.
However, by the late 1990’s, the EPA determined that many refineries were under-reporting emissions, and that the industry failed to implement Method 21 sufficiently to meet emission reduction targets. At the time, the agency estimated around 80 million pounds of undetected and unreported hydrocarbon emissions were being released annually in the US.
The Twenty-First Century
Between 1998 and 2008, non-compliant facilities were forced to institute formal LDAR programs with dedicated management. The early 2000’s saw many refineries agree to implement these programs to avoid litigation. Many changes included increased leak monitoring frequency and required LDAR program training, as well as third-party audits of facilities.
By 2008, reported fugitive emissions from toxic hydrocarbons had dropped by 42% compared to the start of the decade – a significant achievement.
The Present and the Future
Currently, the EPA continues to refine and develop its standards for the LDAR process, hoping to streamline and make these benchmarks more universal. One new development is that of optical gas imaging (OGI), which many hope will revolutionize LDAR by improving leak-scanning speeds as well as reducing repair costs and emissions in general. Although still an alternative detection methodology at the moment, OGI has been designated as one of the best systems of emission reduction by the agency.
An understanding of the evolution of LDAR technologies and regulations over past decades can not only give us an appreciation of where we are at now, but give us insights into where the future lies for emission reductions in general.