Purpose and Scope: | This procedure describes the repair attempt process for leaking equipment found during the annual fugitive emissions survey. In addition, it outlines the process for quarterly pump and compressor seal monitoring. | | | Personal Protective Equipment (PPE) Required: | Normal mandatory PPE for working in process areas required. Additional PPE may be required as per Refinery Standards and applicable Material Safety Data Sheets (MSDS). | | | References: | LDAR – OLT SWP Initiating Procedure LDAR – Monitoring ProcedureLDAR – Repair Attempts Log in FEMS ProcedureLDAR – Work Notification Entry Procedure | | | * * * PREREQUISITENA | * | * PROCEDURE INSTRUCTIONS | 1.0 | Manage First Attempt Repairs | 1.1 | * Immediately following the completion of fugitive emission monitoring in a unit, gather all the leaking equipment info into a spreadsheet format from the Integra monitoring technicians. The data should include the following: sub area, Tag ID, Description, Equipment, Size, Leak Source, PPM, Leak Tag #, Drawing # and Comments. Create a “Master List of Leakers” to compile all of the data. Please use this document as a guide. * ADD LINK | | | 1.2 | * Create the list of leakers for first attempt repairs in each unit using the template. The list should only include block valves and connections (drains, vents, etc) as operators do not attempt to fix flanges, control valves, or pump seals. \\file203\Environment\Records\Air\LDAR\Templates\1st Attempt Repairs Schedule - sample.xlsx - Update LINK | | | 1.3 | * Enter an FE work notification for these repairs (one notification per unit) to be performed by operators. Follow the “LDAR – Work Notification Entry Procedure. In addition, the list of leakers for 1st attempt repairs must be attached to the notification. | | | | * | | | | * NOTE * The FE notifications for 1st attempt repair should be entered 3 or 4 weeks in advance to reserve the date(s) for an operator to perform repairs. | | | | * | | | 1.3 | * Send an email to the appropriate Maintenance and Operations Coordinators to make them aware of the notification that was entered. Provide them with the notification number and a brief description. | | | | * | | | | * NOTE * First attempt repairs involve the operator tightening the plug or packing of leaking equipment. This equipment will be tightened using various wrenches that operations uses. If the operator cannot attempt to fix a piece of equipment using their tools, they will note this on the repair schedule. Then you must move the equipment to the second attempt process. | | | | * | | | 1.5 | After Operations completes the first attempt repairs, each leak must be re-monitored. The EH&S Intern will print out a list of all of the leakers and enter a safe work permit (SWP) into the Operator Log Tool (OLT), using the “LDAR - OLT SWP Initiating Procedure” as a guide. | | | 1.6 | * Monitor all leaking points for fugitive emissions (after picking up your permit from the control room). Record all of the leak rates. If the leak rate is >10,000 ppm, remove the green car seal. | | | 1.7 | * Enter all of the monitoring data into FEMS. See “LDAR – Repair Attempts Log in FEMS.doc”. Also update the “Master List of Leakers” spreadsheet. | | | | * | | | | * NOTE * For the upcoming 2014 LDAR survey, first attempt repairs will be discarded in favour of second attempt repairs. As a result, operators will not be performing first attempt repairs instead they will be assisting the pipefitters with second attempt repairs. | | | | * | 2.0 | Manage Second Attempt Repairs | 2.1 | * After the completion of fugitive emission monitoring in each unit, gather all the leaking equipment info from Integra monitoring technicians and prepare a list of leakers for second attempt repairs, using the template provided (see link below). The list should include block valves, flanges, connections (drains, vents, etc) and control valves with the exception of pump and compressor seals as pipefitters do not attempt these repairs. * UPDATE LINK | | | 2.2 | * Enter an FE work notification for these repairs (one notification per unit) to be performed by pipefitters and/or SIM Technicians. Follow the “LDAR – Work Notification Entry Procedure.” | | | | * | | | | * NOTE * The FE notifications for second attempt repairs should be entered 3 or 4 weeks in advance to reserve the date(s) which will be used to perform repairs. * In addition, ensure that a full list of leakers is attached to the second attempt FE notification after the annual monitoring in each plant has been completed. | | | | * | | | | * NOTE * To arrange for pipefitter and/or SIM technicians, a separate FE notification will be entered as required. * SIM technicians are required to tighten leaking control valves, whereas pipefitters do the repairs on all flanges, block valves, etc. | | | | * | | | 2.3 | * Send an email to the appropriate Maintenance and Operations Coordinators to make them aware of the notification that was entered. Provide them with the notification number and a brief description. | | | 2.4 | * Once the notification has been input into SAP, it will be reviewed by the Cross-Functional Team (CFT). The EH&S Intern will be contacted when a date is scheduled to complete the repairs by the pipefitters, operator and/or a SIM technician. | | | | * | | | | * NOTE * The intern can check the notification itself to see when the repairs are scheduled. In addition, the following link to the weekly maintenance schedule is useful to check in the event that there have been last minute changes to the scheduled repair date. * \\file203\common\Mtce Planning & Scheduling\SchedulingTool\ Master Weekly Schedule.xlsx | | | | * | | | 2.5 | * The day before the repairs, initiate a safe work permit in OLT, using the “LDAR - OLT SWP Initiating Procedure” as a guide. | | | 2.6 | * The day before the repairs, contact the appropriate Maintenance Coordinator to confirm a time and location as to when the pipefitter and an operator is meeting with an Integra Technician to perform repairs. In addition, please send an email to the Maintenance Coordinator, to ensure that the operators are taking photographs of components that failed in second attempt repairs. These photographs must be labeled appropriately and saved in the correct folder. Please provide them with appropriate link as to where photographs must be saved (see link below). | | | 2.7 | * On the day of the repair, please provide a list of leakers to an Integra Technician. | | | 2.8 | * Integra Technicians will monitor each point before and after it is repaired to allow the workers to know the exact location of the leak, and to determine whether or not the repair was successful. Record the new leak rate. | | | 2.9 | * Enter the repair data into FEMS using the “LDAR – Repair Attempts Log in FEMS.doc” procedure and update the “Master List of Leakers” spreadsheet. | | | | * | | | | * NOTE * Any equipment that is still leaking greater than 10,000 ppm should be moved to third attempt repairs. This essentially means that the leaking equipment cannot be fixed while in service, and requires isolation of a line or a unit outage/turnaround for repair. The CFTs will determine whether this work should be scheduled maintenance or Turnaround work. All LDAR Turnaround work should be put on the “Delay of Repair List.” | | | | * | 3.0 | Initiate Third Attempt Repairs | 3.1 | Update the “Master List of Leakers” to state which points were not successfully repaired in 2nd attempt repairs and must be moved to 3rd Attempts. | | | 3.2 | * Enter an FE work notification for each piece of equipment requiring a Third Attempt Repair. Follow the “LDAR - Work Notification Entry Procedure.” These will be reviewed by the Cross-Functional Teams who will determine whether this can be repaired as scheduled work or if it needs to be added to a Turnaround (TA) Scope. (Note – the cutoff for TA work request entries is typically 1 year prior to the TA.) | | | | * | | | | NOTE * Check the Delay of Repair list to see if this piece of equipment is already on the list. If so, review the existing notification to ensure it is still open and being planned for. In this case, do not create a new work notification. * Ensure that a photograph of a leaky component must be attached to an appropriate FE notification for third attempt repair. As a result, this would help the CFT determine the scope of repairs for the leakers. | | | | * | | | 3.3 | * Send an email to the appropriate Maintenance and Operations Coordinators to give them a heads-up of the notification that was entered. Provide them with the notification numbers and a brief description. | | | 3.4 | * Follow-up to determine whether the CFT assigned the notifications as scheduled maintenance or TA work. Record this info and add any TA notifications o the “Delay of Repair” list. | | | | * | 4.0 | Manage Pump & Compressor Seal Repairs | 4.1 | Immediately following the completion of the quarterly pump and compressor seal fugitive emissions monitoring, gather the leaking equipment data in a spreadsheet format from the Integra monitoring technicians. The data should include the following: sub area, Tag ID, Description, Equipment, Size, PPM, Leak Tag #, Drawing #, and Comments. If this report/Integra is not available, use the “FEMS - Create a Custom Report” procedure to create the report. | | | 4.2 | Update the “Leaking Pump & Compressor Seals” document using the report from step 4.1. State the concentration reading for all seals leaking >10,000 ppm, and update the table that summarizes the number of seals monitored. | | | 4.3 | Review previous fugitive emissions leak history for the seals that were identified to be leaking. | | | 4.4 | If there is already an open work notification for the leaking equipment (and has not been closed or rejected), add a comment to the Symptoms field of the existing notification to state the results from this quarter’s monitoring. | | | 4.5 | If there is not an open work notification for the leaking equipment, create a new FE notification. Follow the “LDAR Work Notification Entry Procedure.” | | | 4.6 | Send an email to each appropriate maintenance coordinator, identifying the leaking equipment in each area and provide the associated work notifications numbers. | | | 4.7 | Review all old notifications from previous quarters’ monitoring and update the status of each. Also add “comments” to explain the status. (Eg. rejected b/c MOC to install double seals.) | | | 4.8 | Update the PMP&CMP Leak Concentrations Graph. See the Instructions tab in the workbook for assistance. | | | | * | * END OF PROCEDURE |

REVISION LOG | Date(MM/DD/YYYY) | Revision | Section | Comments | Editor(Name) | 08/04/09 | 0 | | Original Issue of the procedure | | 04/26/13 | 1 | | Extensive changes made to Sections 1-3Added Section 4: Manage Pump and Compressor Seal RepairsConverted document to new Procedures Template | Merissa Wiebe | 08/20/13 | 2 | 4 | Expanded the steps for updating the spreadsheets associated with leaking pump and compressor seals. | Merissa Wiebe |