The Environmental Protection Agency’s (EPA) proposed
Appendix K protocol establishes recordkeeping requirements for optical gas
imaging (OGI) that will impact processes used for data management. The
recordkeeping requirements address equipment, survey and leak data, training,
and auditing. These records are required
to be maintained for five years and readily accessible. Brief discussions of these recordkeeping
requirements, which will directly impact resource allocation and program budgets, are summarized below.
Equipment Records
Records begin with the initial OGI camera performance
verification, but also include camera maintenance records. Camera maintenance records are required to be
retained for the lifetime of the camera, potentially going beyond the five-year
general requirement.
Documentation, including videos related to establishing all
applicable operating envelopes, must be maintained. Sites must maintain a procedure detailing how
monitoring surveys are performed within those operating envelopes and retain
the associated records for each survey.
A daily camera verification video and a five-minute quality
assurance verification video are required to be retained to ensure the camera
is operating properly and that monitoring methods adhere to the site monitoring
plan.
Survey and Leak Data
Sites must have a procedure for conducting and documenting the
field and weather conditions and results for each monitoring survey. Detailed records of each survey must include start
and end date/times, weather conditions, daily maximum viewing distance, OGI
operator name(s), and camera identification.
Data to support the three approaches available for ensuring
all components are included (route map, visual cues, or GPS) must be logged
into the records. Dwell time, operator
pace, and fatigue management through operator breaks must be clearly
demonstrated in the records.
Leak detection records must provide details of each leak. Detected
leaks must be tagged in the field and documented with at least a 10-second video
retained to facilitate follow-up repairs. The proposed rule does not include a requirement to record videos if there are
no detected fugitive emissions on affected components.
Operator Training and Audit Records
Sites must document a training plan and maintain records for
OGI camera operator training, including documentation of classroom training
content and performance demonstrations. Training
records include initial field training for camera operators indicating which
surveys were observed by the operator, performed by the operator under
supervision, and performed independently. Final site survey testing, as well as annual classroom training for each
camera operator must be retained.
Additional records include operator performance audit
records including comparative monitoring surveys and/or four-hour video audits
performed by senior operators. It is critical
to document operator experience including the number of site surveys performed for
operator certification requirements.
Data Management Solutions
Proposed Appendix K includes data collection, recordkeeping,
and data retention requirements that will necessitate effective and robust data
management solutions. Since all records
need to be readily available to camera operators and maintenance personnel in
the field, spreadsheet and folder tracking will no longer be a realistic
option. The high volume of records over
time makes manual file management essentially infeasible and creates a high
risk for non-compliance.
Sites should consider using an efficient software-based
workflow to manage these complex data sets. Enterprise asset management (EAM) systems are commonly used for managing
industry workflows, but they are ill-suited to manage complex and variable
regulatory requirements (like Appendix K), and related data analysis and
reporting. Specialized leak detection software,
like Trihydro’s LeakTracker
ProTM ,
integrated with an EAM workflow can offer an efficient end-to-end workflow
solution.
Takeaways and Recap of the Article Series
Trihydro appreciates you taking the time to review our
articles on the proposed Appendix K and we hope that you have found them
valuable. Links to previous articles may be found here:
As an industry leader in performing OGI monitoring services, we recognize the need for providing a standardized approach to be used across the oil and gas industry. As proposed, Appendix K creates several logistical challenges to implementing a successful and cost effective OGI program. While it will initially only apply to OOOOb and OOOOc, once finalized, EPA has expressed intent to modify other regulations to make Appendix K applicable to OGI monitoring regulations across the oil and gas industry. EPA is requesting comments on the proposed Appendix K and has recently extended the comment period until January 31, 2022.
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