OTTAWA, IL - In their efforts to comply with both the Leak Detection and Repair (LDAR) requirements of HON and the Resource Conservation Recovery Act (RCRA), GE Plastics in Ottawa, IL, encountered what many facilities are now complaining of - the functional and organizational problems associated with a tag based fugitive emissions program.  Initially, the Ottawa site embraced the industry standard of tagging. 

It soon became apparent, however, that many tag materials could not withstand the environment in which they were placed.  The removal of tags during routine maintenance or piping modifications by contractors also undermined program integrity, and it became a costly, time consuming project to re-associate a tag with it's respective piping component.

Proactive Environmental Services, in Ottawa, IL, was asked to develop an alternative method of source identification.  They proposed using isometric drawings, that, unlike P&IDs, could easily represent all piping components.  

After addressing concerns as to whether regulations stipulate that a tag be physically hung from each source, GE chose to retrofit it's plant using the drawing based system.  Eventually, three additional process streams and one vent waste stream were included in the fugitive emissions program using this method. 

Both GE management and field technicians found the system advantageous.  The drawings provided excellent documentation and a means to easily identify exemptions.  Monitoring time was reduced as confusion in locating a particular source was minimized.  Changes to piping configurations were incorporated on the drawings and monitored as they were encountered, ensuring that all potential components were accounted for.  No specialized equipment, such as a bar code reader, was needed. Finally, there was no need to continually replace tags. 

Also, by using the isometric drawings, the safety department was able to document mechanical integrity information required by OSHA, eliminating redundancy in program set-up. 

GE Plastics has found that a tagless system of component identification can cut long-term maintenance costs, improve organization and be a cost effective multi-purpose tool.

- Pollution Engineering, July '95