[author: Heidi Slinkard Brasher]
On May 31, 2012, plastic manufacturing company Saudi Basic Industries Corp. (SABIC) Innovative Plastics, LLC (formerly GE Plastics) agreed to a proposed consent decree with the EPA to settle alleged Clean Air Act (CAA) violations at its Indiana and Alabama chemical plants. Alleged violations were related to fugitive emissions from leaking equipment. This is just one of the many EPA efforts to crack down on manufacturers for CAA compliance issues related to hazardous air pollutant (HAP) emissions from equipment such as valves, pumps and drains, and as opposed to stack emissions. These fugitive emissions are generally controlled through leak detection and repair processes and procedures.
Not only did SABIC Innovative Plastics agree to improve its leak detection and control procedures, it now must also pay a $1,012,873 civil penalty, replace valves with “low emissions” valves and packing materials, engineer emissions controls for drains and trenches, control oil/water separator emissions, and further invest in process vent HAP emissions control projects – all for an estimated total cost of more than $6 million.
Some of the requirements imposed by the consent decree include:
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Leak detection and repair (LDAR) training;
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Quality assurance/quality control (QA/QC) monitoring/certification;
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LDAR audits and corrective action;
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Development of facility-wide documents for each covered facility describing the facility-wide LDAR program – including applicability of regulations to specific
equipment, leak definitions, and monitoring frequency;
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Tracking/management of change (MOC) program to integrate new equipment into LDAR program and removed unused or retired equipment;
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Description of employee and contractor roles and responsibilities with respect to LDAR functions at the facility;
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Assurance that the number of personnel assigned to LDAR tasks is sufficient for compliance with LDAR program;
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A plan for how the facility will implement the Enhanced Leak Detection and Repair Program (ELP), to be updated annually;
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Periodic monitoring of valves (quarterly), connectors (semiannually), pumps/agitators (monthly), and open-ended lines (quarterly); and
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Program regarding valve and connector replacement, repair, repacking and improvement.
