Camouflage Compliance

1. 14th LDAR SymposiumMay 18-22, 2013New Orleans, LA Camouflage Compliance Buzz Harris, Chris Lehmann, and David Heller Sage Environmental Consulting

2. Presenter Information • Buzz Harris holds a BS in Chemical Engineering with 44 years experience and still learning • Chris Lehmann holds a BS in Chemical Engineering with 7years experience, and he is Sage’s subject matter expert on stream speciation and tagging for LDAR • David Heller holds a BS in Physics with 8 years of experience including several complete tag verification projects

3. Overview • Ghost tag introduction • Mis-Documented introduction • Size of problem • Four case studies • Prevention • Corrective actions • QA/QC during tagging/documentation • Training technicians to question unmonitored valves with tags • Continuous tag verification programs • Conclusions

4. Intro to “Ghost Tags” • Means a physical tag hanging in the field that is not documented in the database.  • VV states “Component must be uniquely identified” • Tag identifies the component in a way • Without documentation, however; • It will not be scheduled for monitoring • Without monitoring, repairs will not be made • Records are incomplete • Reports are inaccurate (Federal, State, and CD) • Emissions are under-reported (EI, TRI, state, etc.) • Most Ghost tags of concern are found on VOC/HAP streams with either light liquid or gas/vapor service

5. The origin of the ghost tags? • Factors contributing to developing ghost tags • During any tagging project, technicians may hang and/or document hundreds of components per day, which leaves plenty of room for error • The tagging technician may not follow what the documenting technician sees as the “logical route” • The tagging technician may drop tags where they are irretrievable (i.e., into an oily sump) creating tag number gaps that the documenting technician becomes used to seeing • Documenting tags can become a mundane repetitive task and a technician may simply miss documenting a tag in the field right in his route order • Documenting technician may forget his/her place after breaks or lunch and miss several tags • Documenting technician may miss whole areas of a unit, particularly where they are separate from the main unit

6. Documentation QA/QC • QA/QC • QA/QC process should catch all of the tags. • If tags 1-1000 are hung, 1-1000 should be accounted for: • Each tag hung on a regulated component should be documented in the database • Any tags that are dropped, lost, or damaged beyond use should be recorded as not used for regulated component tagging • Failure to implement proper QA/QC will allow these tag gaps to be unchecked • Some will be valid tags not documented • Others will be ghost tags will haunt your program until discovered

7. Mis-Documentation • Other documentation errors may cause a component to be monitored less than is required: • Pumps incorrectly documented as: • Dual mechanical seals with barrier fluid system • No detectable emissions • Diaphragm, canned or magnetic drive • Valves incorrectly documented as: • Difficult or Unsafe to monitor • No detectable emissions • Closed vent system • Inaccessible • Pressure relief devices incorrectly documented as: • Light liquid service • Closed vent system • Compressors incorrectly documented as H2 service

8. The size of the problem • We all know that ghost tags can occur, but we thought that their numbers were insignificantly low.  • Ghost tags may persist for years without anyone performing required monitoring and repair.  • The longer they remain undetected, • The more likely that they will persist • We have case studies on 4 facilities that had an in-depth tag verification review that can provide a more quantitative view of the potential size of the ghost tag and mis-documentation issues

9. Case Study #1 • Large Facility (approximately 100,000 total tagged components) • Tag verification was performed • Prepared a new set of highlighted P&IDs • Walked down P&IDs in the field • Walked down the database Master Equipment List (MEL) • Looked for anything in VOC/HAP service and G/V & LL categories without tags that were not documented in database (Overlooked) • Looked for components tagged in the field but not documented in the database (ghost tags) • Looked for components documented improperly such that they would not be scheduled for the proper frequency of monitoring (mis-documented) • Table on the following slide presents details by unit for ghost tags and overlooked components

10. Case 1 Detailed Summary

11. Case Study #2 • Small facility (around 10,000 components in database) • In-depth tag verification was done on about two-thirds of the total tags. • Walked down newly highlighted P&IDs • Walked down the entire Master Equipment List • Found over 900 total major tagging problems (ghost tags and overlooked components) or about 12% of total tags missed • Ghost tags accounted for only 18 of those major tagging problems or about 0.25% of components verified

12. Case Study #3 • Small site, one unit has about 3300 components tagged • In-depth tag verification was performed for 1481 components or about half of the total • Walked down the Master Equipment List • Found 142 major tagging problems (ghost tags and overlooked components), or about 9.6% of components verified • Ghost tags accounted for only 1 of these major tagging issues or about 0.07% of components verified

13. Case Study #4 • Medium sized • Complete walk down of all units performed • Included MEL check for about 10% of tags to: • Identify undocumented tags (ghost tags) • Identify mis-documented tags that would cause missed monitoring • Detailed summary of results in table on next page

14. Case Study #4 Detailed Summary

15. Results Summary

16. Why they are not caught in the field • Plant may hang the same shape and color tags on components that are not normally monitored: • Heavy liquid service • Connectors • Vacuum service • Liquid pressure relief devices • Closed vent systems • Ideally these non-monitored or less frequently monitored components should have a visibly distinctive tag • If not, technicians get used to passing by tags that never get monitored without questioning why • Lack of technician training and awareness • Bad routing can also cause a technician to get used to passing by tagged components without monitoring

17. Tag Gap Reviews • Some facilities can use tag gaps as the quickest way to identify and correct ghost tags • Newly tagged units, or • Existing units that generally maintain numeric tag sequence, • Search your database for tag gaps: • Check the “Old Tag” field to see if any of the gaps were caused by replacing a tag with a different tag number

18. Tag Gap Reviews (Cont’d) • Prioritize tag gaps by size • Focus first on units with gaps of more than 10 undocumented numbers • Consider walking down all gaps on units that had a major gap identified while you are authorized for work there • Then focus on units going from largest gaps to smallest • For each gap: • Find the first documented tag before the gap and the first after the gap • Inspect all of the area between, around, above, and below to see if you can find any tags within the numbered gap • Review applicability for each gap tag found: • Document in database if appropriate and • Remove the tag if not

19. Full Tag Verification • Many facilities cannot take advantage of tag gap reviews because they replace missing tags with new numbers • Start with a review of highlighted PFDs/P&IDs • Walk down P&IDs looking for untagged equipment on regulated streams • Walk down Master Equipment List looking for tagged components not documented in the database (ghost tags) • Also look for critical mis-documentation such as inappropriate use of exemptions • Check documentation for connectors using parent/child approach • Most are not tagged • Check to see the number and sizes in field correspond to database • Some sites use this type of verification on a continuous basis to find anything the MOC misses

20. Issues with Over-Tagging • In addition to ghost tags and mis-documented tags, conservatively over-tagged components pose a few potential problems: • They reduce the leak percent, which might be an issue if the site is using performance-based monitoring frequency (skip period) • They can provoke citations for uncontrolled OELs • A missing plug on a tagged valve is likely to be cited by an agency inspector • Hard to get operator to keep it plugged, because s/he thinks of it as water, nitrogen, air, etc. • They can provoke citations for sample system flushing control issues • The site is often not consistent on over-tagging, which may result in overlooked findings for untagged components in same service as others that are tagged

21. Camouflage Compliance • Since an auditor in the field will see a tag and assume the component is in compliance, we would like to propose a new name for this problem: camouflage compliance. • Audits focus on comparative monitoring when camouflage compliance • Spotting untagged component issues is difficult enough • Spotting ghost tags and mis-documentation is nearly impossible • Check tag gaps or conduct a full tag verification to correct your Camouflage Compliance • Doing so can reduces impacts on an LDAR and other Environmental programs

22. Remove the Camouflage • We would like to propose a new name for the ghost tag problem: Camouflage Compliance It looks OK But it ain’t necessarily so • Audits focus on spotting untagged components • Spotting ghost tags and mis-documentation is nearly impossible without a time-consuming MEL check • Check tag gaps or conduct a full tag verification to correct your Camouflage Compliance • Train your technicians to question every tag that does not appear on their route