Managing Appendix K Compliance for Natural Gas Leak Detection

Last month, we discussed the evolution of methane emissions regulations and how to prepare your oil and gas site for OOOOb and OOOOc compliance. The purpose of these regulatory updates is to establish consistent testing and reporting protocols for the natural gas industry and ensure that emissions data is accurate, reliable, and comparable across different facilities. In doing so, the U.S. Environmental Protection Agency aims to reduce the environmental impact of greenhouse gas emissions from these facilities.

Appendix K was mentioned as a subpart of these policy amendments, outlining specific requirements for all aspects of optical gas imaging (OGI) surveys. While OOOOb and OOOOc mandate more frequent leak detection and repair (LDAR) monitoring surveys, providing the “why, where, and when” for natural gas leak detection in the field, Appendix K provides the “how.”

Specifically, the appendix addresses the camera specifications; site monitoring plan and survey protocols; and operator criteria, including training, experience, observation, performance, and audits. Extensive quality assurance and quality control, as well as recordkeeping requirements, are also addressed. This new guidance is a significant departure from the previous Alternative Work Practice applied to OGI technology. Below are the most significant standard updates expressed in the appendix.

Appendix K Compliance: Significant Standard Updates

Camera Specifications

Optical gas imaging cameras must meet specifications for resolution, spectral absorption, thermal sensitivity, global positioning system, and more. The camera must also be able to record using full high-definition video format and adjustable brightness settings.

Site Monitoring Plan

The site monitoring plan for leak detection is now required to include a monitoring route map to ensure all required equipment is being surveyed, with critical components being viewed from two different angles. The survey must also be conducted within the “operating envelope” of the equipment in the range of conditions needed for successful and accurate results.

Monitoring Surveys

Following the site monitoring plan, the operator conducts the survey. New requirements include increased dwell time, time spent focusing on a particular group of equipment or components, and operator rest periods every 20 minutes. Each technician will need to record and store videos of their survey technique daily to demonstrate compliance.

Training and Experience

Operator training includes initial classroom training and field training. To become qualified, new operators will train with a senior operator, completing a total of about 100 surveys before performing independent work. Senior operators must have experience of more than 500 surveys. All technicians will be subject to quarterly operator audits.

Quality Assurance, Quality Control, and Recordkeeping

Appendix K includes a comprehensive list of requirements for quality assurance and recordkeeping to maintain compliance. A client-accessible database is recommended to manage this extensive amount of information.

Contact:

John Leitel
Client Manager
John.Leitel@APTIM.com