leak detection and repair - rmehspg ldar.pdf · leak detection and repair lt environmental, inc. ....

Leak Detection and Repair

METHOD 21 AND OPTICAL GAS IMAGING

Leak Detection and RepairLT Environmental, Inc.

www.ltenv.com

Presenter

Presentation Notes

LTE has satellite offices in Durango, Mead, and Rifle, Colorado; Cheyenne and Rock Springs, Wyoming; Victor and Coeur d' Alene, Idaho; Roosevelt, Utah; Williston, North Dakota; and Gainesville, Florida


Today we will discuss:Method 21 DevicesCombining Optical Gas Imaging (OGI) with Method 21 Federal Programs:

Method 21 and Alternative Work PracticeNSPS Subpart OOOO revisions

Presenter

Presentation Notes

A lot of you have sat through these Optical Gas Imaging presentations before, so we didn’t want to just state things that have already been discussed. We want to take this time to talk about how Method 21 and OGI work together, when they’re appropriate, and choosing the right tool for the job. Will discuss federal regulations – examples of regulations that require Method 21 and the “alternative work practice” which may sometimes allow for the use of OGI


EPA Method 21 (40 CFR Part 60, Appendix A-7)“Determination of Volatile Organic Compound Leaks”Describes specific devices that can be used:

General requirements: Intrinsically safe Constant intake pumpDetect gas

Presenter

Presentation Notes

Method 21 quantifies the concentration of the leak – not a measurement of actual leak quantity.

Leak Detection and RepairAdvantages

Lightweight Easy Calibration

Disadvantages VOC only (no methane) May not calibrate to

meet all leak definitions

Photoionization Detector:

Presenter

Presentation Notes

I have not yet seen a PID that can calibrate to 10,000 ppm. There are certain lamps that can be purchased to allow for a calibration to 500ppm, but these are more expensive. PID on a gas stream consisting of ~70 methane will give a much lower ppm reading since the VOC concentration is comparatively low. It will not factor in non-VOC hydrocarbons into the reading (i.e. Methane, Ethane, etc..)

Leak Detection and RepairFlame Ionization Detector: Advantages

Detects methaneCan calibrate to multiple

leak definitions (500ppm, 10,000ppm, etc..)

Disadvantages: Bulky/Heavy Need UHP Hydrogen Pilot frequently goes out

Presenter

Presentation Notes

Has an internal tank for hydrogen I’ve had better luck with this unit as far as reliability You do not want to be carrying this around for an 8 hour day.

Leak Detection and RepairFlame Ionization Detector: MicroFID

Smaller, but same advantages/disadvantages

Presenter

Presentation Notes

This one is easier to carry around for an 8 hour day Refillable internal tank – must have your own tank of hydrogen

Leak Detection and RepairInfrared Absorption Detector: Advantages

Can detect methane LightweightCalibrates to multiple leak

definitions (500ppm or 10,000ppm)

Disadvantages Sensor reads in %LEL not

ppm, must convert to ppm (%LEL x 10,000)

Presenter

Presentation Notes

I don’t have much personal experience with this one, but so far it seems to combine the ease of use of the PID with the methane capabilities of a FID.

Leak Detection and RepairForward Looking Infrared (FLIR)

Presenter

Presentation Notes

In my opinion, this is the most user friendly leak detection tool, but requires that the operator be a seasoned professional to be able to determine what is/is not a gas leak. Although not required by rule at this time, it’s a good idea that the operator go through a training course; it seems obvious in the picture but in a real inspection the gas leaks aren’t so obvious. Other applications as seen in the top photo are thermal applications – determining tank levels

Leak Detection and RepairOr there’s always this…..

Presenter

Presentation Notes

I just thought this was pretty great… Robots replacing our jobs! In all seriousness this would have some good pipeline inspection applications, but that’s not what we’re talking about today.


Choose the right tool for the job PID calibrates with isobutylene (VOC) FID/Infrared Absorption calibrates with Methane (Hydrocarbon)

Most regulations are focused in “Hydrocarbon” leaks, which is a major component of natural gas (~70%)


ColoradoColorado Regulation 7 XVII.F.6.e. For leaks identified using an approved

instrument monitoring method or AVO, owners or operators have the option of either repairing the leak in accordance with the repair schedule set forth in Section XVII.F.7. or conducting follow-up monitoring using EPA Method 21 within five (5) working days of the leak detection. If the follow-up EPA Method 21 monitoring shows that the emission is a leak as defined in Section XVII.F.6., the leak must be repaired and remonitored in accordance with Section XVII.F.7.

State Leak Detection Regulations

Presenter

Presentation Notes

I know this is a lot of words, but I just wanted to show you the regulation language itself. The key part is the section that I underlined. I have not yet encountered a leak visible with the camera that has measured close to the 500ppm range; they’re typically much higher. FLIR.com does not give a ppm concentration at which methane is visible, but laboratory videos on their page show that methane at a rate of 0.8 g/hr is visible. Other VOCs are visible in the ~1 g/hr range


Colorado Leak definition = 500ppm “Hydrocarbon” PID vs FID


Presenter

Presentation Notes

Important to note that hydrocarbon does not mean just VOC, but also encompasses Methane and Ethane


ColoradoXVII.F.7.c. Leaks discovered pursuant to the leak detection methods of

Section XVII.F.6. shall not be subject to enforcement by the Division unless the owner or operator fails to perform the required repairs in accordance with Section XVII.F.7.


Presenter

Presentation Notes

Leaks that are discovered and are following the allowable repair deadlines of 5 days for a first attempt and 15 days for a repair are not subject to enforcement if the Division finds the leak during an inspection. The Division could reserve the right to enforce leaks that are discovered by the Division; this is up to their discretion. We have not yet encountered a situation like this, but that’s not to say that it can’t happen.


WyomingOperator must develop LDAR protocol Best Available Control Technology (BACT) >8 TPY (attainment area) or

>4 TPY (non-attainment area)Method 21, OGI Camera, AVO or a combination thereof Does not negate other Federal LDAR requirements : Kb, OOOO, KKK



Utah ILB.l0.a.1 (General Approval Order)A reading of 500 ppm or greater

with an analyzer or a TDLAS [tunable diode laser absorption spectroscopy] shall be considered a leak. Any emissions detected with an infrared camera shall be considered a leak unless the owner/operator evaluates the leak with an analyzer meeting U.S. EPA Method 21, 40 CFR Part 60, Appendix A no later than 5 calendar days after detection and the analyzer's reading is less than 500 ppm.


Presenter

Presentation Notes

Lengthy reg citation included just to be able to quote the language. Focus on the fact that a leak seen with the camera can be taken out of consideration with low method 21 readings


Utah In conversations with the State; VOC is the gas component of concern A PID analyzer calibrated to 500ppm


Presenter

Presentation Notes

If not using a camera for an inspection, calibrating a PID to 500ppm would be ideal to focus on VOC leaks


Optical Gas Imaging NSPS Subpart A §60.18(g) “Alternative Work Practice” IR Camera allowed for any NSPS requiring a Method 21 monitor except:

Closed Vent Systems

Equipment designated as “leakless”

Equipment identified as “no detectable emissions” (leak definition 500ppm)

Federal Leak Detection Regulations


Some Oil and Gas regulations that require monitoring: NSPS Subpart Kb NSPS Subpart KKK NSPS Subpart OOOO



NSPS Subpart Kb “Closed Vent” systems for storage tanks (after custody transfer) Method 21 only



NSPS Subpart OOOO “Closed Vent” system inspections

Method 21 only – Closed Vent

Natural gas processing plant inspections Method 21 only – 500ppm definition



NSPS Subpart KKK (applicable January 20, 1984 – August 23, 2011) Potential for alternative work practiceNot applicable for facilities constructed after August 23, 2011


Leak Detection and RepairProposed Changes to Federal Rule

NSPS Subpart OOOO Revisions Proposed changes to existing rule

Published September 18, 2015

EPA soliciting comments through November 17, 2015


Well Sites: Proposing facility-wide OGI camera inspections

Within 30 days of well completion/modification Inspections done semi-annuallyAlternate proposal would require annual inspections

Soliciting comment on requiring quarterly inspections


Well Sites: May exclude sites that are wellhead only May exclude low production sites (<15 bopd)


Compressor Stations: Proposing facility wide OGI camera inspections

Within 30 days after startup or modification Inspections done semi-annually


Re-inspections:

Proposing that Method 21 could be used for re-monitoringConsideration of cost of re-hiring OGI personnel for re-inspection

Repaired if re-monitor shows leak is <500ppm above background


Be informed Submit comments to EPA by November 17, 2015 Know your leak detection options

www.ltenv.com

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