Appendix K of the Environmental Protection Agency’s (EPA’s) proposed updates to New Source Performance Standards (NSPS) establishes optical gas imaging (OGI) camera operator training requirements for the oil and gas industry, as well as camera operator performance audits. These training and audit requirements represent a significant change to camera operator requirements that could substantially impact the costs of conducting OGI surveys. The following sections provide a summary of the proposed training and audit procedures.
Camera Operator Training
Historically, OGI camera operator training requirements have not been clearly defined. The proposed Appendix K protocol establishes the role of “senior OGI camera operator” and establishes stringent training requirements that are directed by a person in this role. Below is the definition of a senior OGI camera operator, as well as a summary of training requirements.
- Senior OGI camera operator definition:
- A camera operator who has conducted OGI surveys at a minimum of 500 sites over the entirety of their career, including at least 20 sites in the past 12 months, and has completed or developed the classroom camera operator training.
- Companies must establish an OGI training plan containing the following minimum requirements:
- Classroom training elements covering fundamental OGI technology, parameters that affect image detection, calibration and monitoring survey procedures, recordkeeping requirements, common pitfalls and best practices, and discussion of regulatory requirements.
- Initial camera operator training comprised of 10 site surveys where trainee observes surveys, performs 40 side-by-side comparative surveys, and performs 50 independent surveys supervised by a senior OGI operator.
- A final site survey test is required with zero missed leaks relative to a senior OGI operator survey before the trainee may conduct surveys independently.
- OGI camera operators must attend an annual classroom training refresher and a camera operator who has not conducted a monitoring survey in over 12 months must be retrained.
Currently, there are no regulatory requirements related to auditing OGI camera operator performance. However, if Appendix K is adopted as proposed, performance audits for all OGI camera operators must occur on a quarterly basis with at least one month between audits. Two options are permissible to fulfill this requirement:
- Comparative monitoring in near real-time whereby an OGI camera operator conducts a survey of at least four hours, and a senior OGI camera operator replicates the same survey to ensure that no persistent leaks were missed.
- A performance audit by video review where the camera operator being audited must submit four hours of unedited and uncut video footage of their OGI survey technique to a senior OGI camera operator for review of techniques and any missed leaks.
If the performance audit finds that the camera operator missed a persistent leak or failed to follow techniques as described in the monitoring plan, the audited camera operator will need to repeat a portion of the initial field training requirements.
The proposed Appendix K protocol suggests EPA wants to ensure OGI camera operators can navigate a variety of situations prior to conducting independent surveys. As proposed, the method requires significant resources and equipment, likely increasing the cost of conducting surveys for companies that have hired third-party contractors. Previously untrained parties, such as facility operations and maintenance personnel, will no longer be able to certify leak repairs for compliance purposes under the proposed training requirements.
Owners and operators are advised to review the term “site surveys” for training purposes. This term is significantly different depending on the industry segment. A site survey of a well site is vastly different from a refinery or gas plant. This discrepancy leads to considerably different training burdens between upstream, midstream, and downstream industry segments.
The proposed quarterly frequency of performance audits will be required at the same or similar frequency as surveys at a facility. The 4-hour senior OGI operator review requirement is significant and may force many senior OGI operators into a primary auditing role for other operators instead of completing surveys.
As proposed, the cost and time investment for training, classroom refreshers, and performance audits appears substantial. These costs will directly impact program budgets when using a third-party contractor and could impact operating companies’ ability to self-perform this work. In addition, as will be discussed in a future article, the proposed recordkeeping requirements to document OGI operator training will be extensive and may require significant data management resources.
Stay tuned for the next article in our series, which will focus on the mechanics of conducting OGI surveys. If you missed our last article on proposed Appendix K, covering OGI survey equipment and pre-survey operating requirements, you can catch up here.
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