Getting Ready for Appendix K: A Few Recommendations for the Soon-to-Be Law of the Land

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.

Survey Hours

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.

Field Training

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).

  1. A route map with designated ob­servation locations (already found in OOOOa).
  2. The use of visual cues.
  3. 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.

ABOUT THE AUTHOR: Jared Metcalf is the VP of US OGI Operations for Montrose Environmental Group, Inc. Jared has a B.Sc. in Industrial Technology and Instrumentation provides logistical and operational support to Montrose Enviornmental’s United States crews. He is our lead contact for interacting with clients in both office and field settings
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