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Camouflage Compliance

Buzz Harris, Chris Lehmann, and David Heller

Sage Environmental Consulting

14th LDAR SymposiumMay 18-22, 2013New Orleans, LA

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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 7 years 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

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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

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

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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

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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

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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

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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

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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

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Case 1 Detailed Summary

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UnitTotal

ComponentsGhost Tags

Percent Ghost Tags

Overlooked Overlooked

PercentTotal Missed

Percent

A 2243 1 0.04% 1 0.04% 0.09%B 1326 1 0.08% 5 0.38% 0.45%C 384 7 1.82% 0 0.00% 1.82%D 446 2 0.45% 0 0.00% 0.45%E 1427 12 0.84% 0 0.00% 0.84%F 5042 51 1.01% 15 0.30% 1.31%G 944 20 2.12% 0 0.00% 2.12%H 5259 86 1.64% 62 1.18% 2.81%I 1469 39 2.65% 0 0.00% 2.65%J 10084 221 2.19% 26 0.26% 2.45%K 7980 439 5.50% 14 0.18% 5.68%L 1768 1 0.06% 2 0.11% 0.17%M 4776 12 0.25% 35 0.73% 0.98%N 13619 14 0.10% 70 0.51% 0.62%

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

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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

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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

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Case Study #4 Detailed Summary

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Unit CodeNot

DocumentedMis-

DocumentedTotal MEL

ReviewTotal

Inspected

Percent of MEL w/Documentaion

Problems

Percent of Total w/Documentaion

ProblemsA 0 0 195 376 0.0% 0.0%B 12 1 76 1215 17.1% 1.1%C 6 18 121 1737 19.8% 1.4%D 5 2 153 939 4.6% 0.7%E 0 4 66 319 6.1% 1.3%F 7 6 86 281 15.1% 4.6%G 1 0 19 188 5.3% 0.5%H 0 0 20 87 0.0% 0.0%I 1 0 50 503 2.0% 0.2%J 1 0 29 503 3.4% 0.2%K 4 2 139 1947 4.3% 0.3%L 3 18 137 1372 15.3% 1.5%M 14 1 40 591 37.5% 2.5%N 9 0 149 1756 6.0% 0.5%O 3 0 155 884 1.9% 0.3%P 34 12 122 1220 37.7% 3.8%Q 4 1 141 821 3.5% 0.6%R 0 2 82 137 2.4% 1.5%S 17 0 28 37 60.7% 45.9%T 32 5 141 653 26.2% 5.7%U 24 17 232 2319 17.7% 1.8%V 0 3 11 148 27.3% 2.0%

Facility 177 92 2192 21943 12.3% 1.2%

Results Summary

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Case StudyTotal Components

InspectedGhost Tags / Overlooked #

Ghost Tags / Overlooked %

No. 1 56,767 906/230 1.6% / 0.4%

No. 2 7330 18 / 910 0.2% / 12%

No. 3 1481 1 / 142 0.1% / 9.6%

No. 4 22,000 269 / 2,478 1.2% / 11.2%

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

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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

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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

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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

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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

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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

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Remove the Camouflage

• We would like to propose a new name for the ghost tag problem:

Camouflage ComplianceIt 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

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