OGI and Preparing for Appendix K Compliance

Posted on June 2, 2023

In November 2022, the United States Environmental Protection Agency (EPA) proposed updates to Appendix K, which is the protocol for using OGI cameras to detect leaks on regulated equipment within onshore natural gas processing plants. As it currently stands, Appendix K drastically changes the performance requirements used for compliance, including standards for camera operators, camera performance and documentation, and site-specific monitoring plans. This update is being implemented in the oil & gas sector, but will likely apply to all industries (once fully adopted) if this Appendix is referenced.

Here is a summary of the updates/changes:

Operator Standards

Training

Initial training (classroom or in-person) on OGI fundamentals, best practices, and site plans, followed by refresher training every two years.
At least 30 hours of initial field training with a senior OGI camera operator, followed by a final field test lasting at least 2 hours. Field training requirements would allow for 10% missed leaks if there are more than 10 leaks total on the final test. Trainees that fail the field test may repeat the test after the senior OGI camera operator provides instruction on performance improvement.
Allowances are made for previous experience to meet initial training requirements.

Senior Operator Requirements

The senior OGI camera operator must meet all of the requirements below:

Have logged 1,400 survey hours during their career, including 40 hours in the past 12 months.
Either developed or completed the classroom training.

Audits

All OGI operators are required to complete a 2-hour audit four times per year.
These performance audits must be completed using real-time comparative monitoring or a video review by a senior OGI camera operator.

Camera Performance and Technical Details

Dwell Time

Dwell time is the time required to survey a scene and provide adequate probability of leak detection; it is the active time the operator is looking for a potential leak and does not begin until the scene is in focus and steady.
Dwell time is set at 2 seconds per component in the field of view.

Camera Requirements

Cameras must be capable of measuring emissions of 17 g/hr of methane and 5 g/hr of butane, or the same emissions of methane and 18 grams per hour of propane, as confirmed by an initial specification confirmation for an OGI camera model configuration.
Camera spectral range must overlap with the chemical target at the specified response factor.

Once the OGI camera operator meets these criteria for performance, the following requirements for conducting observations must be met:

Establish an operating envelope, which means the range of conditions (wind speed, delta-T, viewing distance, etc.) within which a survey must be conducted to achieve the quality objective.
The camera must be tested in each of these conditions.
The operating envelope may be determined by the owner/operator, camera manufacturer, or a third party.

Monitoring Plan Requirements

The OGI requirements will be summarized in a monitoring plan, either for each site or for multiple similar sites, addressing how the site complies with the following:

Daily verification checks for the OGI camera.
Demonstrating compliance with the operating envelope.
Documenting monitoring methodology to ensure all components are monitored, such as route maps, visual cues, or GPS tracking.
Procedure for component monitoring, including viewing angles, dwell time, and distance.
Plan for avoiding camera operator fatigue, including required breaks. Note: operators are required to take a break of at least 5 minutes after every 30 minutes of surveying.
Procedure for documenting monitoring surveys, which must include facility name, date, start/end times for each survey, and weather conditions.
Recordkeeping requirements for documenting the survey and observed leaks, including pictures and/or video clips.
Quality assurance verification video for each OGI operator.
Description of the processes used to ensure the validity of the monitoring data.

To view the complete information regarding Appendix K, please visit the EPA’s website.

Sources

“EPA’s Supplemental Proposal to Reduce Pollution from Oil and Natural Gas Operations to Fight the Climate Crisis and Protect Public Health: Using Optical Gas Imaging in Leak Detection (Appendix K).” U.S. Environmental Protection Agency, https://www.epa.gov/system/files/documents/2022-11/Proposed%20Changes%20to%20Appendix%20K.%20Fact%20Sheet.pdf.

“Determination of Volatile Organic Compound and Greenhouse Gas Leaks Using Optical Gas Imaging.” U.S. Environmental Protection Agency, https://www.epa.gov/system/files/documents/2022-11/Appendix%20K%20supplemental%20proposal.pdf

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