Appendix K continues to take shape. While there is not a final version to review quite yet, there is a pretty good idea of what Appendix K is going to look like after the ink is dry (barring any last-minute overhauls from regulators). This article will not delve into the nuts and bolts of Appendix K here; rather, the focus is to break down a few key elements of the regulation believed to have the biggest impact on LDAR monitoring programs, and offer recommendations on how to adapt ahead of time.
By Jared Metcalf, Vice President, U.S. OGI Operations, Montrose Environment Group, Inc.
What has Changed in Appendix K?
Limitations on Physical Distance
Any language, outside of the operating envelopes, suggesting a restriction on the physical distance between an OGI camera operator and a component being scanned has been removed. As drafters of the regulation have since explained, the intent was never to limit how close an OGI camera operator must be to a component while scanning it.
Mandatory Dwell Times
Another notable change in Appendix K is its reduction of mandatory dwell time from five seconds for each component within the scene to two seconds. It still requires that each component is viewed from multiple angles, bringing this to approximately five seconds per component when considering shifts to different views. Ultimately, this is considered a notch in the win column because the roughly six seconds being saved per component can add up to pretty significant time savings.
Originally, Appendix K quantified training and experience requirements based on the number of inspections a technician conducted. It now uses survey hours instead, which is a far more effective metric to train camera operators and gauge experience.
Facilities Impacted by Appendix K
Per OOOOb, only processing plants will fall under Appendix K regulation. However, we are seeing signs that many (if not all) states are going to adopt Appendix K. So, if one operates a facility under the purview of OOOOc, it is a safe bet to assume it will have to adhere to Appendix K as well.
The strong likelihood that Appendix K will apply to a facility—be it a compressor station, well site, and more, — leads to the first recommendation: take proactive measures yesterday. There are steps and best practices that can be put into place before Appendix K goes into effect that will help ensure an LDAR program remains compliant while still maximizing the efficiencies and cost-savings of OGI technology.
Staffing and Training OGI Technicians
In its current form, Appendix K defines a senior OGI camera operator as a technician with 1,400 hours of total scan time over the course of their career. If an eight-hour workday is assumed, that is 175 days of scanning needed to reach senior level. A senior OGI camera operator also needs 40 hours of scan time under their belt in the year prior to Appendix K’s effective date.
Senior OGI camera operators are must-haves to train new OGI technicians. It is recommended to get as many technicians to senior level as quickly as possible. If a technician is close to the 1,400-hour mark, get them out in the field—even if it is to do voluntary inspections. If a facility has a senior OGI camera operator who has not logged 40 hours of scanning in the last 365 days, they should make sure they get there by any means possible.
For New Trainee, Appendix K Will Require:
Classroom Training (In The Classroom or Online)
Classroom materials will need to cover the key fundamental concepts of OGI camera technology, how to operate and maintain the OGI camera, how weather and environmental conditions can impact OGI imaging, and best practices and common mistakes.
Once the classroom portion is complete, a trainee must observe the techniques and methods of a senior OGI camera operator in the field for a minimum of three hours. The trainee must then log 15 hours of scanning independently with the senior OGI camera operator present. Afterward, the trainee will conduct a final survey of at least two hours and must find no less than 90% of leaks.
The classroom and field training requirements fall in line with what many LDAR programs are doing already. The low bar Appendix K is setting for the trainee’s final survey is worth noting. A trainee should find 100% of the leaks, full stop. It is recommended that an LDAR program only passes the trainees who detect every leak during their final survey.
The reason is simple: a regulator will not accept anything less than a facility that is 100% free of leaks. That is what every LDAR program should strive to achieve.
It was previously noted that Appendix K reduced its mandatory dwell time from five seconds to two. Regulators have also adjusted the prescribed technician breaks to five minutes per every 30 minutes of continuous scanning (it was previously five minutes per every 20 minutes). Both changes win back some scanning time. Still, the total available scan time will be less than seven hours per day.
To put this into context, a technician can scan roughly 4,900 components in a day under Appendix K versus the typical 10,000 components under current industry standards. (A cryo train at a processing plant has between 7,000 to 10,000 components. For this situation, it is suggested to set aside two labor days of scanning per cryo unit.) Doing the necessary hiring and training now to make sure a company has the appropriate staff ready to absorb the increased time demands and labor burdens is ideal. Unfortunately, many will not be able to count on senior OGI technicians to serve as full-time inspectors, since they need to train new hires and conduct audits. Fortunately, some labor hours will be won back thanks to the elimination of the mandatory annual Method 21 inspections.
To help OGI camera operators reduce survey times, Appendix K does include a table outlining scenarios in which dwell time can be less than two seconds per component. Parameters include the number of components (10 or less) and variables such as distance, location and more. However, defaulting to the two-second dwell time regardless is recommended. This ensures that dwell times are compliant no matter what. Otherwise, an auditor interpreting the table in Appendix K differently than the technician is risked (e.g., counting a component in the background as an 11th component when the technician did not).
Methods for Conducting Surveys
Appendix K will require technicians to conduct surveys using one of three approaches (or any combination of the three).
- A route map with designated observation locations (already found in OOOOa).
- The use of visual cues.
- GPS route tracking.
Out of the three, methods one and two may be the easiest and most effective. Many facilities already utilize either a route map or visual cues. Specifically, most processing plant operators have visual cues as part of their LDAR program. These visual cues are flags, tags, color codes, etc., that mark which components to scan. For existing facilities that already use these cues, it may not be worth the effort of changing anything. However, for new facilities, marking the components that do not need to be scanned is recommended (so if it does not have a visual cue, scan it). This is because the number of non-regulated components is significantly less than the regulated components.
Leak Detection and Confirmation
One element of Appendix K that remains unclear is the actual confirmation of emission visibility when creating the operating envelopes. As written, Appendix K requires three out of four observers trained in OGI to agree that they see the emission when creating the operating envelopes in a lab environment. This establishes a new workflow, and, it could take weeks to create operating envelopes.
Whether this requirement falls to the OGI camera manufacturer or the LDAR monitoring program is unknown. Currently, there is no specific recommendation here (yet) aside from keep this on the radar and know that it may be necessary to spin up this workflow quickly.
Data and Equipment Considerations
Appendix K will necessitate more technicians, and those technicians will require at least one OGI camera each, and other gear to perform their duties. One piece of equipment that is highly recommended is something to measure distance, such as a rangefinder used on the golf course, or a laser measurer. Knowing distance between the camera and a component will help the technician stay inside the prescribed operating window.
There is also the matter of data storage and management. Under Appendix K, technicians have the option to record the entirety of each inspection. An LDAR program must save these recordings for at least five years, along with training records, compliance documentation, and paperwork dealing with leaks. For on-site recording, capturing the footage on external hard drives, saved in triplicate, should be implemented. This gives a decent safety net, should a hard drive become lost or malfunction. For data storage, cloud-based software that can handle the sheer volume of data, should be used, as it also makes organizing, retrieving, and sharing files intuitive and fast.
Prepare for Appendix K Today, and Be Better Off Tomorrow
Processing plants are the first in line to fall under Appendix K. But, any type of facility can be subject to Appendix K if it is referenced in a regulation. Give an LDAR program the best chance of success by taking proactive measures while available. Future operations and employees will be thankful.