B03_-_Attachment_1_-_LDAR_SOW_updated_9_20_21_0001.pdf

STATEMENT OF WORK (SOW)

AMARILLO FIELD OFFICE

CLIFFSIDE HELIUM ENRICHMENT UNIT POTTER

COUNTY, TX

Leak Detection and Repair (LDAR) Program with Annual Greenhouse

Gas (GHG) Survey

Bureau of Land Management (BLM)

July 5, 2021

1.0 PROJECT INTRODUCTION

Project Name: Leak Detection and Repair (LDAR) Program with Annual Greenhouse Gas

(GHG) Survey

1.1 Background

Any affected facility that commenced construction, reconstruction, or modification after

January 20, 1984, and on or before August 23, 2011, is subject to requirements of NSPS 40

CFR Part 60 Subpart KKK - Standards of Performance for Equipment Leaks of VOCs from

Onshore Natural Gas Processing Plants. In 2014, 40 CFR 98 Subpart W required owners or operators of facilities that contain petroleum and natural gas systems and emit 25,000 metric tons or more of GHGs per year (expressed as carbon dioxide equivalents) to report GHG data to EPA.

These regulations apply to the BLM's Cliffside Helium Enrichment Unit (CHEU) located at

13301 Brickplant Road, Amarillo, TX 79124, 15 miles north of Amarillo, Texas.

The BLM operates a cryogenic gas processing plant that produces crude helium, natural gas, and natural gas liquids. The plant has approximately 25 on-site employees and produces approximately 8 million standard cubic feet of sales quality natural gas per day (MMSCFD) and 3 million cubic feet of enriched crude helium.

1.2. Project Objective:

1.2.1 LDAR KKK Program

Methane or VOCs leaks from process equipment are uncontrolled fugitive emissions or leaks. VOCs react with sunlight and nitrogen oxides to form ozone (smog), which can cause or aggravate respiratory disease particularly in children, asthmatics, and healthy adults who participate in exercise. Methane and VOC losses can be minimized and/or eliminated with a proper LDAR Program in place. Additional benefits of an LDAR Program include:

• Reduction of production loss- Estimated savings can add up to hundreds of thousands of dollars recovered in a year from product losses.

• Increase in Safety- Reduces potential gas leaks that increase Lower Explosive Limits

(LEL) levels through a gas processing facility.

1.2.2 Subpart W (GHG) Leak Survey Program

In 2009, the U.S. EPA found that GHGs pose a risk to the environment, and it was determined that GHGs endanger public health and welfare of current and future generations.

Under 40 CFR 98 Subpart W, owners and/or operators are required to perform an annual

GHG survey (expressed as carbon dioxide equivalents).

The BLM requires consultant services to perform routine LDAR services, in accordance with federal and state regulations, specifically 40 CFR Part 60 Subpart KKK, and 40 CFR

98 Subpart W (GHG) and 30 TAC 101.20.

The Contractor will work closely with the Air Specialist on site to verify gas streams in

KKK and GHG service, perform leak detection, and to deliver written products and reports.

The work for this contract will occur in the base year and option year(s).

1.3 Contractor Qualifications

The Contractor shall have knowledge of natural gas processing facilities or related petrochemical or cryogenic facilities. The Contractor shall be responsible for providing the necessary equipment, managerial, engineering, software, and clerical support necessary to support performance tasks and deliverables. The Contractor shall provide technically competent and appropriately qualified personnel.

Technically competent and appropriately qualified shall be defined as:

Having knowledge, with a minimum of 10 years of experience, in dealing with air quality compliance activities at natural gas processing facilities, including the most recent EPA and TCEQ LDAR compliance.

Specific air regulations the contractor must demonstrate experience and expertise with are:

a. 40 CFR Part 60- STANDARDS OF PERFORMANCE FOR NEW STATIONARY

SOURCES SUBPART A - General Provisions(§§ 60.1 - 60.19)

b. 40 CFR Part 60, Subpart KKK - Standards of Performance for Equipment Leaks of

VOC From Onshore Natural Gas Processing Plants for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before

August 23, 2011 https://www.law.comell.edu/cfr/text/40/60.631

c. 40 CFR Part 60, Subpart VV - Standards of Performance for Equipment Leaks of

VOC in the Synthetic Organic Chemicals Manufacturing Industry for which

Construction,...Commenced After January 5, 1981, and on or Before November 7, 2006 https://www.law.cornell.edu/c fr/text/40/part-60/subpa rt-VV

d. 40 CFR Part 98 Mandatory Greenhouse Gas Reporting

SUBPART W - Petroleum and Natural Gas Systems (§§ 98.230 - 98.238).

SUBPART C-General Stationary Fuel Combustion Sources(§§ 98.30 - 98.38) https://www.law.comet l.edu/cfr/text/40/part-98

e. 30 Texas Administrative Code (TAC) Chapter §101.20, Compliance with Environmental Protection Agency Standards.

http://www.law.comell.edu/cfr/text/40/60.631 http://www.law.cornell.edu/cfr/text/40/part-60/subpart-VV http://www.law.cornell.edu/cfr/text/40/part-60/subpart-VV http://www.law.cometl.edu/cfr/text/40/part-98 http://www.law.cometl.edu/cfr/text/40/part-98 http://www.law.cometl.edu/cfr/text/40/part-98

f. 30 Texas Administrative Code (TAC) Chapter §101, GENERAL AIR QUALITY

RULES

2.0 REQUIREMENTS

2.1 Method 21

Surveying methods shall be in accordance with EPA Method 21-Delerminalion of Volatile

Organic Compound Leaks. The contractor shall monitor and detect components and equipment for leaks with specified concentrations as outlined in EPA Method 21-Determination of Volatile

Organic Compound Leaks.

The contractor shall ensure the following in accordance with EPA's Method 21:

I. Calibration and Calibration Gases

2. Equipment and Supplies

3. Safety

4. Sample Collection, Preservation, Storage and Transport

2.2 General:

I. Review CHEU facility P&IDs and other documents as required to determine components and equipment in LDAR service for each of the applicable EPA regulations. The contractor shall perform a field audit to ensure list and diagrams accurately represent equipment installed by the plant.

2. Survey and monitor the CHEU facility to determine the components and equipment that are in LDAR service for each of the applicable EPA regulations.

3. Tag regulated components using a systematic approach as to identify the correct gas stream and LDAR program being monitored.

4. Use a unique numbering identification tag system to each component according to the applicable regulation.

5. Document the tag numbers into the handheld computer for upload into the LDAR database.

6. Demonstrate a quality control plan that includes calibration and standardization of equipment.

7. Provide LDAR equipment safety training to staff.

8. Contractor shall not use the OGI FLIR camera to survey in areas that are not intrinsically safe.

9. Maintain an LDAR database for the client and provide electronic reports.

10. Use an electronic data logger to improve accuracy as well as to provide an audit record.

11. Perform work using contractor-provided equipment and software, usually a TVA 1010 or

2020 gas analyzer and LDAR Tools, LeakDas, LeakTracker or equivalent software with the same capabilities as the aforementioned software.

12. Perform plant survey for methane, carbon dioxide, and nitrogen oxides (wt. % >= 10% by weight) (GHG), with frequency in accordance with 40 CFR 98 Mandatory Greenhouse Gas

Reporting for the applicable industry Subpart W. .

13. Use of the FLIR Camera is allowed as a surveying tool for the annual GHG survey in accordance with the rules and regulations of 40 CFR 60.18 (g)-(i), General control device and work practice requirements and 40 CFR 63.11 (c)-(e). There are instances as per regulation where OGI cannot Replace Method 21 requirements. In these instances, Method 21 must be utilized.

14. Provide a certified Optical Gas Imaging (OGI) FLI R camera specialist lo perform surveys.

15. Repair of Leaks and 1st Attempt in accordance with 40 CFR KKK and VV. Minor and first attempts at repair shall include but are not limited to, tightening bonnet bolts; replacing bonnet bolts; tightening packing gland nuts; and injecting lubricant into lubricated packing.

16. All methods will be performed in accordance with EPA 's Method 21-Determination of

Volatile Organic Compound Leaks.

17. General and Best Practices shall be performed in accordance wi.th EPA' s Leak Detection and Repair (Compliance Assistance Guide): A Best Practices Guide.

18. References from EPA's Leak Detection and Repair (Compliance Assistance Guide): A

Best Practices Guide shall be incorporated by reference and followed by contractor.

19. Any unspecified methods or procedures not exclusively called out in this section and document will follow Method 21, 40 CFR 60 Subparts VV & KKK, 40 CFR 98 Subpart

W, 40 CFR Subpart A 60.1-60.19.

3.0 PROJECT DETAILS

3.1 The LDAR Program

I. Identifying Components- The CHEU has already identified the components in

LDAR service. The contractor should use the existing identification system to develop and streamline the LDAR Program. This element includes a KKK component count of equipment as defined in 40 CFR Part 60 Subpart KKK and

40 CFR 98 Subpart W (GHG). The contractor will use P&IDs, plant-obtained lists, and other drawings to identify and compose a master list of all valves and components in methane (greater than 10% by weight) and VOC (greater than 10% by weight) service.

2. Leak Definition-Pumps and Valves shall be defined at 10,000 ppm (light liquids) and pressure relief devices that upset to atmosphere defined at 500 ppm (gas/vapor).

3. Monitoring Components-Please see Section 3.3 for the base year and option year monitoring schedule.

4. Repairing Components-When a leak is detected, it shall be repaired as soon as practicable, but no later than 15 calendar days after it is detected, except as provided in 60.482-9. A first attempt at repair shall be made no later than 5 calendar days after each leak is detected. First attempts at repair include, but are not limited to, the following best practices where practicable and appropriate:

tightening bonnet bolts; replacing bonnet bolts; tightening packing gland nuts; and injecting lubricant into lubricated packing.

5. Recordkeeping-The contractor shall incorporate and maintain an electronic database for storing and reporting LDAR data. The contractor shall utilize a data logging system, (i.e., LDAR Tools, LeakDas, LeakTracker,or equivalent software with the same capabilities as the aforementioned software) to store

LDAR data electronically in a GPS system that includes time/date stamps of each monitored component. Delivery of monitoring data electronically to the

BLM Air Specialist and/or other designated personnel shall occur within 48 hours of monitoring.

3.2 Estimated Tag Count

Table 1 includes the typical component counts of an average plant and the estimated component count of the CHEU. The CHEU has significantly less components than an average plant.

Table 1 Equipment Component Counts

Component Average at

Typical refinery orchemical plant.

EPA-IIQ-OAR-2005- .

0475-0105.

CHEU Components in KKK Estimated CHEU

Program-Method 21 Portable Components in Subpart Handheld W Program-Optical

Gas Imaging

Pumps 100 3 NA1

Valves 7,400 250-300 550-600

Connectors 12,000 Exempt 1500-17002 Open-ended lines 560 Plugged, capped or other Plugged and capped

Sampling connections 80 Exempt 20 Pressure Relief Valves 90 Exempt (majority)3

Exempt (majority) 3

Compressors Not provided. Exempt NA1

Meters Not provided. NA 25-30 Source: "Cost and Emission Reductions for Meeting Percent Leaker Requirements for HON Sources." Memorandum to

Hazardous Organic NESHAP Residual Risk and Review of Technology Standard Rule-making docket. Docket ID

EPA-HQ - OAR-2005-04 75-0 105.

NA-Not applicable to the program.

I. Pumps and compressors arc not subject to 40 CFR 98.232(d) (7) and will not be included in the GHG Program for Optical Gas Imaging.

2. Tubing systems ½ inch or less arc exempt from current Subpart W regulations.

3. Estimated number of pressure relief valves subject lo KKK monitoring is 5.

4. Compressors not subject to 40 CFR 98.232 (d) (7) and will not be included in the GHG Program for Optical Gas Imaging.

3.3 Monitoring Schedules

3.3.1 KKK Monitoring

Using Method 21, a two-man team should be able to monitor 500-700 components per day under the KKK Program. It should be noted that the entire CHEU plant is not subject to KKK monitoring. About one-third of the plant will be under KKK monitoring.

Additionally, compressors, connectors, and relief valves routed to a control device at the CHEU, are exempt from monitoring under KKK as per regulation. The Base Year Schedule includes the initial monitoring of the plant, which includes a higher number of components. After the initial monitoring, the number of monitored components will decrease fourfold to 250-300 per year during the annual monitoring session.

Table 2 LDAR KKK Base Year Schedule

Frequency Activities Estimated# of

Components Monitored

#of

Personnel l

Month 1 Days 1 &2: In-briefing with Air Specialist, Plant Manager and other key plant personnel to review rules and regulations, plant exemptions, existing LDAR Program, P&ID's and other Process Diagrams needed for program start up. Map out plan to tag and monitor equipment in VOC service. Identify difficult or unsafe to monitor components. Document exempt components; determine if a MOC status. Begin taggingequipment in VOC service.

Day 3: Finish tagging equipment in VOC service. Begin monitoring all components, pumps, valves, compressors, relief valves, non-detectable, closed vent systems, etc. In VOC service.

Day 4: Complete monitoring of equipment in VOC service. Begin writing up Initial Summary Component Report and initial LDAR Monitoring report.

Day 5: Complete Initial Summary Component Report and initial LDAR Monitoring report. Contractor Delivers out-briefing with Air Specialist. Plant Manager and other

1,000-1,050 2 LDAR

Technicians zwebber Highlight

I key plant personnel to deliver results of LDAR Program. Follow-up with full electronic output from software program.

- I - - ..

I

I

Month 2

Month 3

Monitor normal valves, pumps, and previous leaks if found.

Provide any follow-up monitoring.

Provide Monthly Report

Monitor pumps and previous leaks if found.

Provide any follow-up monitoring.

Provide Monthly Report

Monitor normal valves, pumps, and previous leaks if found.

Provide any follow-up monitoring.

Provide Monthly Report

Monitor pumps and previous leaks if found.

Provide any follow-up monitoring.

Provide Monthly Report

250-300

I

1 LDAR

Technician

3 1 LDAR

Technician

Month 4 Qtrly

250-300 1 LDAR

Technician

Month 5 3

I

1 LDAR

Technician

I

Month 6 Monitor pumps and previous leaks if found.

Provide any follow-up monitoring.

Provide Semiannual Summary Report

3 1 LDAR

Technician

Month 7/ Monitor normal valves, pumps, and 250-300 1 LDAR Qtrly previous leaks if found. Technician

Provide any follow-up monitoring.

Provide Monthly Report Month 8 Monitor pumps and previous leaks if 3 1 LDAR found. Technician Provide any follow-up monitoring.

Provide Monthly Report

Month 9 Monitor pumps and previous leaks if 3 1 LDAR found. Technician Provide any follow-up monitoring.

Provide Monthly Report Month 10 / Monitor normal valves, pumps, and 250-300 1 LDAR Qtrly previous leaks if found. Technician

Provide any follow-up monitoring.

Provide Monthly Report Month 11 Monitor pumps and previous leaks if 3 1 LDAR found. Technician Provide any follow-up monitoring.

Provide Monthly Report

Month 12 Monitor pumps and previous leaks if found.

Provide any follow-up monitoring.

Provide Semiannual Summary Report

I

1 LDAR

Technician

• Using Method 21-A two-man team should be able to monitor 500-700 components per day

{Reference). Time on-site for un LDAR Technician will vary und will depended on factors such, follow-up monitoring, annual monitoring, quarterly or monthly monitoring. The schedule attempts to provide a typical expected monitoring schedule for an LDAR KKK monitoring program.

Frequency Activities Estimated

# of

Components Monitored

# of

Personnel

Month 1 Qtrly

Monitor normal valves, pumps, and previous leaks if found.

Provide any follow-up monitoring.

Provide Monthly Report

250-300 1 LDAR

Technician

Month 2 Monitor pumps and previous leaks if 3 1 LDAR found. Technician Provide any follow-up monitoring.

Provide Monthly Report

Month 3 Monitor pumps and previous leaks if found.

Provide any follow-up monitoring.

Provide Monthly Report

3 1 LDAR

Technician

Month 4 Qtrly

Monitor normal valves, pumps, and previous leaks if found.

Provide any follow-up monitoring.

Provide Monthly Report

250-300 1 LDAR

Technician

Month 5

Monitor pumps and previous leaks if found.

Provide any follow-up monitoring.

Provide Monthly Report

3 1 LDAR

Technician

Month6 Monitor pumps and previous leaks if found.

Provide any follow-up monitoring.

Provide Semiannual Summary Report

3 1 LDAR

Technician

Month 7 Qtrly

Monitor normal valves, pumps, and previous leaks if found.

Provide any follow-up monitoring.

Provide Monthly Report

250-300 1 LDAR

Technician

Month 8 Monitor pumps and previous leaks if found.

3 1 LDAR

Technician

Provide any follow-up monitoring.

Provide Monthly Report

Month 9 Monitor pumps and previous leaks if found.

Provide any follow-up monitoring.

Provide Monthly Report

3 1 LDAR

technician

Month 10 Qtrly

Monitor normal valves. pumps, and previous leaks if found.

Provide any follow-up monitoring. Provide Monthly Report

250-300 1 LDAR

Technician

Month 11 Monitor pumps and previous leaks if found.

Provide any follow-up monitoring.

Provide Monthly Report

3 1 LDAR

Technician

Month 12 Monitor pumps and previous leaks if found.

Provide any follow-up monitoring.

Provide Semiannual Summary Report.

3 1 LDAR

Technician

* Using Method 21-A two-man team should be able to monitor 500-700 components per day (Reference).Time on-site for an LDAR Technician will vary and will depended on factors such as follow-up monitoring, annual monitoring, quarterly or monthly monitoring. The schedule attempts to provide a typical expected monitoring schedule for an LDAR KKK monitoring program.

3.3.2 LDAR GHG Schedule

Once per year a GHG Survey shall be completed with a summary of leak results provided to the air specialist. The performance of the GHG survey shall be in accordance with 40 CFR 98- Subpart W (GHG) Mandatory Greenhouse Gas Reporting. The CHEU Subpart W GHG inspection involves use of the Optical Imaging FLIR Camera or equivalent instrument in accordance with Subpart W. The CHEU falls under 40 CFR 98.232 (d) (7) in which reporting of equipment leaks from valves, connectors, open-ended lines, pressure relief valves and meters.

See above Table I for an estimate of the number of components subject to 40 CFR 98.232 (d) (7).

Table 4 LDAR GHG Base Year Schedule

Frequency Activities Estimated# #of of

Components

Monitored

Personnel

Month 1 Days 1 &2: In-briefing with Air Specialist, Plant Manager and other key plant personnel to review rules and regulations, plant exemptions, existing LDAR Program. P&ID's and other Process Diagrams needed for program start up. Map out plan to tag

2050-2300

1-2 LDAR

Technicians

Activities Estimated# of

Components Monitored

I

I

I

I I

1 LDAR

Technicians

I

2050-2300

Day 2: Continue monitoring of equipment in GHG service. Begin writing up Initial Summary Component Report and initial LDAR GHG Monitoring report.

I

Days 1: Monitor all components previously identified in survey:

valves, connectors, relief valves, open-ended lines and meters in GHG service

12 Months Post Previous Inspection

#of Personnel

Frequency and monitor equipment in GHG service. Identify difficult to monitor or unsafe to monitor components. Document exempt components; determine MOC requirements.

Begin tagging equipment in GHG service.

Day 3: Begin monitoring all components: valves, connectors, relief valves, open-ended lines and meters.

in OHG service Day 4: Continue monitoring of equipment in GHG service.

Begin writing up Initial Summary Component Report and initial LDAR GHG Monitoring report.

I

I .

I

I

I I

Day 5: Complete Initial Summary Component Report and initial LDAR GHG Monitoring report. Contractor Delivers out-briefing with Air Specialist, Plant Manager, and other key plant personnel to deliver results of LDAR GHG Program.

Follow-up with full electronic output.

I

Day 3: Complete LDAR GHG

Monitorin2 report and deliver results.

2.1. Work Hours and Holidays

The performance period established for this contract is based upon all work being conducted during regular working hours. Regular working hours for the purposes of this SOW shall be established as, the hours of 6am and 6pm, each day, Monday through Friday, excluding

Government holidays. The Contractor may assume a flexible schedule as coordinated with the

CO and/or COR.

FEDERAL HOLIDAVS

The following Federal Legal Holidays are observed by the Denver Federal Center and National

Operation Center:

New Year's Day

President's Day

Independence Day

Columbus Day

Thanksgiving Day

Martin Luther King, Jr. Day

Memorial Day

Labor Day

Veterans Day

Christmas

3.2 Government Furnished Items

Unless otherwise designated as Government Furnished, the Contractor shall provide all personnel, transportation, materials, and equipment (including Personal Protective Equipment) in performance of this contract.

The BLM will require all Contractor personnel to complete the Visitors, Contractors, &

Inspectors Safety Review prior to beginning any on-site work.

3.3 Required Meetings

The Contractor shall participate in an Introduction Meeting, Monthly Progress Meetings, and a

Close-Out Meeting with the BLM CO, COR or Project Lead, as designated, to review project accomplishments and plans for the upcoming month.

3.3.1. Introduction Meeting

The CO and COR shall arrange an Introduction Meeting with the Contractor prior to beginning work stated within this contract. The meeting is to review the project requirements and discuss administrative procedures including: safety, emergency procedure, relationship of the Government to Contractor personnel; and other relevant administrative information.

3.3.2. Monthly Meeting(s)-Shall occur on the first week of each month to discuss progress.

upcoming work, any adjustments to schedules or scope of work and other information as needed. Exact meeting times and location can be discussed with the CO and COR as required.

3.3.3. Close-Out Meeting

The CO and COR shall arrange a Close-Out Meeting at the end of each performance period to review project accomplishments and discuss administrative actions to close the contract term.

Project deliverables shall be all necessary documents to properly document the services performed and progress of the project, which includes, but is not limited to, program plan documents, photographs, schedules, and other related correspondence.

a. A written list of the initial survey (component count) of components and equipment in VOC and/or GIHG service.

b. Written electronic summary of components monitored and concentrations during each monitoring session shall be provided NLT 48 hours of a monitoring/survey session so that appropriate action can be taken to document and/or repair any leaks.

c. Written electronic summary report of concentration and leak analysis through an approved program such as LDAR Tools, Leak Das, Leak Tracker or some other approved industry standard software within NLT 48 hours of survey and monitoring.

d. Summary report shall at a minimum contain: % of Difficult to Monitor (DTM) components, monitoring schedule, percent leakers, delay of repair, shutdown list, detail list of all leaking sources, repair order and emissions calculations.

3.4. Inspection and Surveillance

A Quality Assurance/Quality Control shall be in place by the contractor to ensure accuracy, completeness, and to check for inconsistencies. The BLM Helium Cliffside plant reserves the right to perform an audit of performance, and recordkeeping annually in accordance with guidance from EPA's Leak Detection and Repair (Compliance

Assistance Guide): A Best Practices Guide. An audit to the LDAR Program shall be provided to ensure the correct equipment is being monitoring, equipment tagging is in place, Method 21 procedures are being followed, and the required records are being kept.

The BLM will review all documents and reports submitted by the Contractor and provide feedback if necessary and address any concerns. Errors will be corrected and re-submit to the BLM. Additionally, BLM will review the Contractor's Quality Assurance Plan. A

Quality Assurance Plan is some type of documented plan used by the project team to make sure that the products or services provided are of a specified quality. It addresses errors or margins of error and documents that the work has underwent some type of quality-related check for accuracy.