Proposed Appendix K: Recordkeeping

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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Jeremy Sell headshot
Jeremy Sell, PE
Vice President, Air & Process Services, Laramie, WY

Jeremy has more than 20 years of experience conducting and managing environmental projects at sites across the western United States. He supports air compliance programs including leak detection and repair (LDAR), Benzene Waste Operations NESHAP (BWON), annual air emission inventories (AEI), cooling tower Maximum Achievable Control Technology (MACT), and refinery sector rule gap assessments.
Dan Wood headshot
Dan Wood
Assistant Project Scientist, Laramie, WY

Dan supports regulatory compliance for companies affected by federal, state, and local air environmental regulations. He specializes in regulations related to optical gas imaging (OGI). His project experience includes OGI surveying using an infrared camera, natural gas compressor vent flow measurements, permitting assistance, emissions modeling, calculation of oil and gas emissions, Method 21 monitoring, and consent decree compliance.

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