Overview
PURPOSE
- This section specifies the process and procedures required to identify and respond to open-ended lines (OEL) in conjunction with fugitive emissions monitoring programs in compliance with EPA Method 21.
SCOPE
- Open-ended valves or lines must be double-blocked, flanged, capped, or plugged, except as necessary to make or remove temporary connections, such as required to perform equipment maintenance.
- Sample stations are open-ended lines and must be double-blocked when not in use.
- Open-ended valves or lines in an emergency shutdown system which are designed to open automatically in the event of a process upset are exempt.
- Open-ended valves or lines containing materials which would auto-catalytically polymerize or, would present an explosion, serious over-pressure, or other safety hazard if capped or equipped with a double-block and bleed system are exempt.
- Internal compliance with the OEL policy and procedures will ensure the LDAR program is in compliance with regulatory requirements and EPA Method 21 protocols for fugitive emissions monitoring programs.
- Internal assessments and QA /QC checks will identify potential continuous improvement steps for the OEL policy to the improvement of the LDAR program.
- This document details the proper use of the OEL Log.
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