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

Senior Operator Requirements

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

Audits

Camera Performance and Technical Details

Dwell Time

Camera Requirements

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

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:

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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