ENV-09-27 Case Study: The LDAR Alternate Work Practice: An AWP Primer and Guide to Practical Implementation and AWP Cost-Effectiveness

Description:

EPA recently released its final rule for the Alternative Work Practice (AWP), allowing facilities subject to federal leak detection and repair (LDAR) regulations to perform optical imaging as an alternative leak detection work practice. Under the rule, facilities electing to implement the AWP must conduct a combined program with both optical imaging and the standard leak detection method, EPA Reference Method 21. An LDAR program based on optical imaging in place of Method 21 promises equal if not better emission reductions by finding the large leaks sooner than Method 21. However, because the final AWP rule still requires Method 21 monitoring and associated repairs of smaller leaks once per year, maintenance cost savings in the LDAR program are greatly reduced. In this paper, the authors explore the advantages of optical imaging over existing, Method 21-based LDAR programs, provide a brief overview of major AWP requirements, and summarize the results of a 9-month field AWP implementation study. Finally, a detailed analysis of AWP program costs is performed.