Just over two years ago, on November 2, 2021, the Environmental Protection Agency (EPA) unveiled a series of proposed changes to the Leak Detection and Repair (LDAR) practices, including a protocol for using optical gas imaging (OGI) cameras to detect leaks, otherwise known as Appendix K to 40 CFR Part 60. A year later, on November 8, 2022, the supplemental proposal incorporated comments that updated the proposed protocol under Appendix K.
The proposal for the Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review (NSPS rule), which includes an entire package of updates, extends from individual well sites (well heads) to compressor stations, boosting stations, petroleum refineries, onshore gas processing plants and gasoline distribution facilities (chemical plants were excluded). Although Appendix K, as currently proposed, would only apply to onshore natural gas processing plants, EPA noted that “…while this protocol is being proposed for use at onshore natural gas processing plants in this action at the proposed 40 CFR 60.5400b and 40 CFR 60.5400c, the applicability of the protocol is broader.” As a practical matter, we believe this statement indicates there is a strong possibility that eventually the Appendix K protocol and associated OGI technology requirements will be mandated for regulatory surveys of other Oil & Gas infrastructure. Until the final rule is issued, however, this remains an open question.
It is our understanding that the intent of the Appendix K modifications is to further the effectiveness of leak detection of methane, ethane, and volatile organic compounds (VOCs) by improving OGI LDAR practices. The changes focus on operator’s training, OGI camera performance standards, and frameworks for inspection requirements and monitoring plans. In this article, we briefly cover how EPA’s proposed Appendix K impacts each of these four areas.
LDAR Operator Training
Proposed Initial Training Requirements. The EPA’s proposal suggests comprehensive training for new (e.g., junior) LDAR operators. This includes courses in OGI fundamentals, best practices, and site-specific plans. The initial training will require candidates to complete a minimum of 30 hours of field training alongside a senior OGI camera operator (requirements to be a senior OGI camera operator are below). A final field test lasting at least 2 hours will be necessary to assess the operator’s competency. Exceptions to these requirements may be made for individuals with previous relevant experience.
Senior OGI Camera Operator Qualifications. The proposal defines a “Senior OGI camera operator” as someone with a career history of conducting 1,400 survey hours, including 40 hours in the past 12 months, and who have completed or developed the classroom training. This designation ensures that experienced professionals are leading leak detection efforts. For this, EPA is proposing to grandfather current OGI camera operators. However, camera operators may have to take biennial classroom training if their previous classroom training was more than two years from the publication of Appendix K.
Quarterly Performance Audits. To maintain the highest standards, all OGI camera operators would be subjected to quarterly (four times a year) performance audits. These audits involve a minimum 2-hour evaluation, with real-time comparative monitoring or video review by a senior OGI camera operator. Remedial training for at least 16 hours with a Senior OGI camera operator is mandatory if the operator misses more than 10% of leaks or a predetermined threshold. If the operator fails two consecutive audits, an initial training process is required. OGI camera operators in good standing that become inactive and decided to become active would be eligible to retrain rather than completing the initial training.
OGI Camera Performance
The EPA proposed the following specific performance requirements for OGI cameras:
- The camera’s spectral range must overlap with the chemical target at the specified response factor (i.e., camera tuned for specific gas sensitivity).
- The OGI camera must produce a detectable image of methane emissions of 17 grams per hour (g/hr) and the choice either propane emissions of 18 g/hr or butane emissions of 5 g/hr. These detections should be at a viewing distance of 2 meters and temperature differential (delta T) of 5 degrees Celsius, under calm wind conditions.
- An “operating envelope” (range of conditions in which a survey must be conducted) must be established for field use, considering various conditions such as temperature differences, viewing distances, and usage scenarios. The camera must be tested in each of these conditions, and imaging is prohibited outside of this operating envelope.
Th proposed OGI performance requirements are apparently designed to minimize incidents of missed leaks from using cameras outside their known effective operating ranges.
LDAR Inspection Requirements
The proposal also mandates not just when an LDAR inspection occurs and the equipment performance requirements for the cameras used, but also how the inspections themselves are performed.
- Two angles. The proposal mandates that each component within the field of view must be imaged from at least two different angles.
- Dwell time. A mandatory dwell time of two seconds per component is set to ensure thorough inspection.
- Regular breaks. OGI operators are also required to take at least 5-minute rest breaks every 30 minutes to reduce mental, physical and eye fatigue.
LEARN MORE: Encino Professional LDAR Inspection Services
Monitoring Plans
Operators are required to create monitoring plans for each site or for multiple similar sites. These plans must address:
- Daily verification checks for the OGI camera.
- Demonstrating compliance with the operating envelope.
- Documenting monitoring methodology, such as route maps, GPS tracking, and/or tagging.
- Procedure for component monitoring, including viewing angles, distance, and dwell time.
- Plans to prevent camera operator fatigue, including mandatory breaks.
- Recordkeeping requirements for documenting surveys and observed leaks.
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Implications for Operators
The proposed modifications represent a significant increase in LDAR compliance requirements. Operators will not only need to invest in advanced OGI technology, but in extensive training and rigorous auditing, which could lead to increased operational costs.
A crucial decision for many operators will be whether to keep LDAR in-house or outsource it to specialized service providers who are knowledgeable with current and evolving regulatory environment with the technical resources and equipment required to ensure compliance.
The Encino Environmental Advantage
Operators seeking to navigate these changes effectively can turn to Encino. We offer the most comprehensive lineup of environmental performance solutions, services, and expertise for mitigating emissions from Energy operations with a focus on Oil & Gas and Biogas markets.
We are a pioneer in emissions monitoring in the Energy sector, providing clients with a complete range of environmental services for helping comply with the anticipated changes to LDAR practices, including class-leading OGI equipment and professional LDAR crews.
We offer:
- CEMS (Continuous Emissions Monitoring Systems)
- Methane monitoring via Satlantis micro satellites (EmSat™)
- Emissions performance testing, stack testing
- LDAR (Leak Detection and Repair) inspections
- Advanced environmental data software
- Enviromech™ composite thief hatches for a durable, long-term seal of surface storage tanks
- Advisory services
Importantly, Encino can help design and tailor an emissions monitoring and performance program aligned with your operational needs, corporate strategy, and budget.
As an oilfield services company, Encino is dedicated to helping operators improve their environmental and economic sustainability for supplying the world with reliable and affordable energy.
Contact us today at (281) 201-3544 or support@encinoenviron.com for a free consultation and evaluation of how Encino can help you achieve environmental performance and compliance that generate economic results.
About Encino Environmental Services
Formed in 2010 and headquartered in Houston, Texas, Encino Environmental Services, LLC is an emissions performance testing and monitoring firm that specializes in environmental consulting, combustion analysis, LDAR (leak detection and repair) services, and CEMS (continuous emissions monitoring systems) technology.
Equipment from Sensia Solutions, a subsidiary of Encino, allows the integration of thermography and AI analytics for the leak detection and quantification (LDAQ) needs. Also, through its joint venture with Satlantis LLC, Encino hosts remote sensing technologies leveraging satellites for the monitoring of methane emissions, as well as advanced environmental data platforms for the measurement and minimization of emissions.
Encino supports permitting, regulatory compliance and strategic ESG initiatives across the U.S. covering all major oil and gas basins and select international markets.
