OGI camera survey
Proposal to Standardize OGI Survey Protocols Presents Seismic Shift in Burden to the Oil and Gas Industry

On November 15, 2021, the Environmental Protection Agency (EPA) published its proposed methane reduction regulations New Source Performance Standards (NSPS) OOOOb and OOOOc in the Federal Register. NSPS OOOOb and OOOOc have received much of the attention related to this rulemaking, but stakeholders should also be aware of the proposed protocol for conducting optical gas imaging (OGI) surveys, provided in Appendix K: Determination of Volatile Organic Compound and Greenhouse Gas Leaks Using Optical Gas Imaging.

Appendix K was developed to standardize a written protocol for OGI survey requirements in the upstream and downstream oil and gas sectors. Prior to the release of this proposed protocol, OGI camera operator certification requirements were not clearly addressed. The newly proposed protocol provides requirements for monitoring equipment, survey procedures, camera operator training, and recordkeeping. While we agree that having a certification requirement for OGI camera operators is overdue, the proposed requirements in Appendix K may prove challenging to implement in the field.

Key Methane Reduction Rulemaking Dates:

  • November 15, 2021: Proposed rule published
  • November 30, 2021, and December 1, 2021 (11:00 AM - 9:00 PM): Virtual Public Hearing on EPA's Proposal to Reduce Methane and Other Harmful Emissions from the Oil and Natural Gas Industry (REGISTER HERE)
  • December 15, 2021: Comments due on the information collection provisions for consideration by the Office of Management and Budget (OMB)
  • January 31, 2022: Comments due to EPA

Over the next month, Trihydro will provide a series of brief articles breaking down proposed requirements in Appendix K that have the greatest consequence and burden to completing OGI surveys. Our articles will identify specific protocol requirements and provide examples of how new requirements could impact future OGI surveys at oil and gas facilities, resulting in decreased benefits of implementing an OGI program.

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

Jeremy has more than 18 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.

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