In a world that patiently awaits a full return to life as we previously knew it, a potential regulatory blockbuster that could forever change the LDAR industry is getting ready to come out. This coming attraction, like last year’s slate of movies, may not be released as early as first hoped, but it is still expected to have a significant impact on the fugitive emissions monitoring industry. Industry has been advocating for the development of an amended Alternative Work Practice (AWP) to upgrade the existing one and bring optical gas imaging (OGI) back to the forefront as a leak detection method. With EPA still developing a new OGI monitoring protocol, this sneak preview comes without the benefit of seeing the draft document.
By Deever Bradley, P.E. – Senior Principal, SLR International Corporation
Many environmental professionals are aware of OGI technology and its application for Leak Detection and Repair (LDAR). Since it was published by EPA on December 2, 2008, however, the AWP it has not lived up to its expected billing as a truly transformative technology to replace conventional Method 21 monitoring for equipment leaks of volatile organic compounds (VOCs). Aside from the handful of facilities who have received approval for an alternate means of compliance (AMOC) to use OGI for annual monitoring of difficult-to-monitor components – those that require a technician to be elevated more than two meters above a support surface – OGI has been more beneficial to operations and maintenance departments than to environmental monitoring personnel. But the fate of OGI may soon change for petroleum refineries under a new protocol and amended AWP for optical gas imaging being drafted by EPA and expected to be issued in tandem later this year.
This new OGI protocol will ultimately reside in Appendix K of 40 CFR Part 60, Standards of Performance for New Stationary Sources (NSPS), alongside EPA test methods and other emission-related provisions. A comprehensively detailed draft Technical Support Document summarizing the historical technology development and numerous field and laboratory studies that led to the adoption and commercialization of OGI was published by EPA’s con-tractor, Eastern Research Group, in August 2015.
The upstream oil and gas industry, whose regulations under NSPS Subparts OOOO and OOOOa were promulgated following the AWP, incorporates optical gas imaging into fugitive emission rules without having to opt into the AWP, thereby avoiding the onerous (and costly) annual Method 21 monitoring requirement with a flame ionization detector. Despite technological advancements from camera makers featured in a recent Fugitive Emissions Journal article, the AWP and LDAR rules for the hydrocarbon processing industry have not changed to match the leak detection abilities currently available. Several years of experience with OGI surveys and the corresponding data have, however, helped build the case for a new AWP.
Read the full article online here in the March issue of Fugitive Emissions Journal: https://www.fugitive-emissions-journal.com/pdf/fej_march_techarticle_deever.pdf.