In at least one regard, the proposed rule does take a step toward the reduction goal as it recognizes the cost-effective and emissions-reducing capabilities of Optical Gas Imaging (OGI). Groups OOOOb and OOOOc of the proposal require OGI inspections at new, reconstructed, and existing oil and natural gas facilities, with the frequency of OGI inspections being determined by a facility’s purpose, location, size, and components.
Many industry professionals are of the opinion that both groups of actions are the result of thoughtful and earnest collaboration between regulators and industry experts, to the extent that they are inclined to agree with the following language found in the proposal itself:
“The proposed NSPS OOOOb and EG OOOOc consists of reasonable, proven, cost-effective technologies and practices that reflect the evolutionary nature of the Oil and Natural Gas Industry and proactive regulatory and voluntary efforts.”
The issue for many lies with Appendix K. Since OOOOb and OOOOc codify OGI inspections in a way never done on a federal level, the group of actions that make up Appendix K are intended to regulate the operation of OGI cameras for the technicians in the field, as well as OGI inspection training. And while it was written with the intention of supplementing OOOOb, OOOOc, and any future OGI regulations, the majority of industry experts who have used OGI VOC detection technology platforms over the last decade, feel strongly that it was written in a silo.
The Counter Intuitive Nature of Appendix K
While OOOOb and OOOOc help support the oil and natural gas industry to integrate more efficient and cost-effective leak detection technologies like OGI, Appendix K significantly throttles back the potential and anticipated progress. Through unnecessary and overly prescriptive requirements that undermine the stated goals of OOOOb and OOOOc, Appendix K goes out of its way to eliminate all OGI efficiencies.
What is perplexing is that Appendix K even provides and reviews its own detailed cost analysis of OGI, and it acknowledges that OGI is safer, more efﬁcient, and cost-effective at reducing VOC emissions than traditional EPA Method 21 inspections:
Because more regulated components can be effectively monitored in ‘scenes,’ OGI VOC surveys are safer and can be conducted much more efficiently. Depending on the size of the LDAR compliance program, the annualized cost of conducting bimonthly OGI surveys can reduce costs approximately 35-45% compared to half the annualized cost of EPA Method 21 and OGI LDAR programs reduce loss of product. Therefore, the costs of the LDAR programs are offset to some degree to the emissions reduced.
Yet, despite this acknowledgement, Appendix K seems to lack a fundamental understanding of what makes OGI such an efficient, cost-effective, and powerful technology for the reduction of carbon emissions.
OGI Works Differently Than Appendix K Thinks it Does
For example, let us consider a standard natural gas processing cryogenic unit. It will take a technician using Method 21 no less than 124 hours to complete a full inspection of all the unit’s components. With current industry standards, a technician using an OGI camera requires only five hours to complete a full inspection.
Here Is How Appendix K Sabotages That Efficiency.
First, Appendix K requires a dwell time of five seconds per component in a scene (dwell time is how long a technician must keep a component in frame on the OGI camera). The current industry standard only requires a 3-second dwell time per scene, which is accepted by the Texas Commission on Environmental Quality. So, for example, a subsection with five components will require a minimum dwell time of 25 seconds, compared to 15 seconds without Appendix K. But that is not all. Appendix K also requires that an OGI technician captures components at multiple angles. This requirement balloons the dwell time in the above example to at least 50 seconds.
Appendix K Does Not Account for the Way OGI Technicians Work
The disconnect between Appendix K and real-world applications is rather straightforward. With OGI technology, the number of components in the camera’s viewfinder is irrelevant. While searching for fugitive emissions, an OGI technician is not aiming the camera at specific components; they are evaluating a scene consisting of inanimate pipes, valves, and containers. Any movement in the scene suggests a leak and warrants further inspection. It does not matter if there are 1,000 components or only one within the camera frame.
Appendix K Creates Unnecessary Safety Risks
A key benefit of OGI technology is the ability to keep employees safe while monitoring hard-to-reach components. Traditional Method 21 devices must be held as close as possible to a component to detect a leak. However, an OGI camera enables a technician to stand several feet, or even yards, away from components and successfully monitor the presence of fugitive emissions. That is a huge benefit of an OGI camera as it allows a technician to quickly and thoroughly inspect components that are tough to access.
Unfortunately, Appendix K would restrict the viewing area of the OGI camera to 1 meter squared. This puts the technician roughly five or six feet away from the component they want to capture in the camera’s frame.
Imagine an OGI technician and a Method 21 technician standing underneath pipes that run across a 15-foot ceiling. The Method 21 technician is limited by their technology, so they have no choice but to break out a ladder and get close enough to inspect the components. This practice puts LDAR technicians at a higher risk of injury. On the other hand, an OGI technician could simply tilt their camera up and identify a leak without ever having to leave the ground.
With Appendix K in effect, suddenly the OGI technician would also have to break out a ladder, merely to close the distance between themselves and the leak they have already detected. Not only is this redundant (i.e., inefficient), but it also introduces the additional safety risk of using a ladder when it is not needed.
It should also be noted that certain leaks do not plume until they are six feet or more away from the source. Therefore, by restricting an OGI technician to within five feet or so of a component, Appendix K creates potential blind spots where leaks can hide.
Tallying Up the Inefficiencies that Appendix K Creates
With Appendix K there is an increased dwell time from three seconds per scene to five per component and a viewing area restricted to 1 ometer squared. Adding to this inefficiency equation are the prescribed technician breaks found within Appendix K. It proposes that a technician receive a 5-minute break for every 20 minutes of survey time. This extends every OGI survey by 25%, automatically. What would take five and a half hours now takes a full 24 hours to complete – essentially three full workdays. Quite frankly, this is excessive. OGI technicians keep their cameras lowered as they move about a facility, only holding the cameras up for a span of three seconds (under current standards) to inspect components. If one revisits the 15-foot pipe rack scenario for a second, imagine the OGI technician tilting their camera up and seeing a leak from one of the components 15 feet above. Instead of flagging the leak and moving on, they are now forced to waste approximately 15 minutes to retrieve and set up a ladder so they can capture the leak they have already seen. In addition, it has now been six minutes since their last break. It quickly become apparent how the inefficiencies can add up.
Looking at it mathematically, it has already been noted that it will take a technician using Method 21 no less than 124 hours to complete a full inspection of a natural gas processing cryogenic unit. Currently, an OGI technician can inspect the same unit in five hours. But if we bog that technician down with these Appendix K requirements, they will likely need at least 22.5 hours to do what they were doing in a fraction of the time. This chips away at OGI efficiencies, negatively impacting the oil and natural gas industry and, more importantly, the environment. And for what reason?
Putting the Restraints on the Promise of OGI
One of the great benefits of OGI is how it makes frequent inspections throughout the year more cost-effective. If we look at this on a granular level, roughly 75% of all components within a facility are only inspected once a year using traditional Method 21, largely due to the labor and time costs associated with the technology. But what if a leak occurs one day after that annual Method 21 inspection? How much product will be lost before the leak is detected? What will the impact be on the environment? Now one can image multiple leaks in multiple facilities, occurring at different points throughout the year. Meanwhile, OGI makes it efficient and practical for us to capture these leaks much, much faster. Yet, instead of embracing the full potential of OGI to conserve both product and environment, Appendix K forces innovative technology to adhere to inherent Method 21 limitations – simply, it seems, because both technologies serve the same purpose.
Appendix K Keeps the Inefficiencies Coming
There are other problematic areas in Appendix K to note as well. For example, large segments of the proposal are devoted to OGI inspection training. It dictates that training must be conducted by a “senior OGI camera operator,” which it defines as a technician who has performed a minimum of 500 site surveys over the entirety of their career. But Appendix K does not define what constitutes a ‘site.’ Facilities come in all shapes and sizes. Some are vast. Others are relatively small. Should a survey conducted at a small facility with only a few hundred components count toward this 500-site minimum the same as a much larger facility with thousands of components? As for OGI technician trainees, Appendix K requires they perform 100 surveys before their training is considered complete. Again, what constitutes a ‘survey’ in the eyes of Appendix K? Is this a week’s worth of work or a year’s worth? Additionally, some trainees will naturally move at a much faster pace than others, and they could arguably be ready to conduct surveys on their own within a month. This makes the 100-survey requirement feel arbitrary.
Another factor is the mandated Delta T checks an OGI technician must conduct during the survey. The Delta T function (difference in temperature between the emitted process gas temperature and the surrounding background temperature) is how OGI cameras operate; they detect and display temperature variation. Technicians are trained to spot those variations and discern which scenes are appropriate to image leaks and which ones are simply void of a Delta T due to the surrounding environment. Should the scene have no difference in temperature, its image is gray-washed to the point that not even the components in the scene stand out anymore. In other words, if the Delta T is not there, it is immediately clear to the technician the second they look through the camera and views the screen.
What OOOOb and OOOOc giveth, Appendix K taketh away. The way to reduce significant amounts of greenhouse gases and other harmful pollutants from the atmosphere is to welcome demonstrably effective innovative technologies with open arms – not put regulatory restraints on that force them to conform to the limitations of what came before. So one must ask themselves what purpose Appendix K serves. If its goal is to cut emissions, then why does it seem more intent to throttle the very technology that helps us better protect both product and environment?
ABOUT THE AUTHOR
Jared Metcalf has over 20 years of Oil & Gas Industry experience. He currently Heads the US OGI Division as Vice President. With a B. Sc. in Industrial Technology and Instrumentation Jared provides logistical and operational support to Montrose’s USA OGI crews. He is the lead contact for interacting with clients in both office and field settings. Jared’s extensive experience in providing professional fugitive emission monitoring services across North America and internationally has given him the expertise to help Montrose clients meet their compliance/voluntary requirements. Jared specializes in the design, setup, and implementation of LDAR programs using Optical Gas Imaging.