COLORADO APCD IR Camera Survey Program Guidance/Protocol (rev. 11/8/11)

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1 COLORADO APCD IR Camera Survey Program Guidance/Protocol (rev. 11/8/11) Disclaimer: This document is designed to assist regulatory agency staff in conducting IR camera surveys at upstream and midstream oil & gas facilities as part of a compliance assurance program pursuant to Clean Air Act (CAA) regulatory requirements. This document briefly outlines how the IR camera is used and suggests specific equipment found to be common sources of leaks to observe using the IR camera. It does not address, nor intended to address, any necessary training, health and safety, evidence handling, or other such requirements necessary to conduct an IR camera survey. Adherence to this checklist, or lack thereof, does not prevent an agency from taking appropriate compliance assurance actions (i.e., seeking information, enforcement, etc.). APCD reserves the right to change this document, at any time, and without prior notice. I. General IR Camera Usage Tips A. Do s 1. Read and follow the IR camera manufacturer s guideline and specifications Allow about five minutes after starting the camera before beginning to film: when the camera initially starts, a sterling motor is engaged to cool the infrared sensing element. B. Don t 1. Point the camera at intense energy sources (e.g. the sun, lasers, etc.) it will damage the camera. 2. Do not charge the battery from a car lighter and only charge the battery in ambient temperatures of 32 to 113 F. 3. Do not over clean the IR camera lens. Over cleaning the IR camera lens can damage the chemical coating on the lens itself (if you need to clean lens, refer to manual). II. General IR Camera Calibration & Operation Practices A. The operator must follow the IR camera manufacturer s guideline and specifications. B. Set the current date and time in the camera and turn on the GPS setting. C. When performing a Leak Detection and Repair (LDAR) inspection of a gas plant for the purposes of NSPS KKK (e.g. to assess a leak rate of a random sample of components versus historical reported leak rates), the inspection must conform to the Alternative Work Practice (AWP) in 40 CFR 60.18(g) and the leak detection must be performed prior to using the IR camera. D. To survey a site, it is helpful to scan the environment in High Sensitivity Mode (HSM) to see gas movement and then switch to Auto or Manual mode to record leak. E. When emissions are found, they are reachable, and if the equipment is available, use a Toxic Vapor Analyzer (TVA), Organic Vapor Analyzer (OVA), Photo Ionization Detector (PID), or other similar tool to determine the concentration of the leak. III. Emission Point Details: Recording Emissions A. When recording a leak with the IR camera, switch recording from non-infrared mode to conventional mode to capture the emission point in the same frame/video number to show there is not steam present. B. Measure or estimate the distance, in feet, to the leak or emission source and note in Table 1-7. C. Record at least 30 seconds of footage in grayscale, white hot mode, holding the camera still. 1 This document was based on a FLIR GF-320 IR camera and some features may or may not be available on your specific camera.

2 D. If recording emissions from a thermally active source (e.g., flares, engines, turbines), pan the camera away from the thermal source until it is out of the viewing screen and hold it there for a few seconds to let the camera adjust. This will allow for a clearer plume contrast against the environment. Similarly, changing the equalization mode from manual to histogram will also help to minimize the contrast of the picture. E. If possible, obtain the chemical speciation of the leak from the site representative. F. If possible, obtain any information from the site representative regarding operating conditions (i.e., normal operating conditions versus upset conditions) at the time the leak or emissions are observed. G. Record any relevant quantitative process data available. H. Fill out the emission point details in Table 1-Table 7. IV. Specific Equipment to Observe at Oil and Gas facilities. A. Inspection points at well sites Piping routing emissions from storage tanks Enclosed flare/combustor (top) Wellhead, pumping jack B. Inspection points at compressor stations Piping routing emissions from storage tanks Pipe routing of emissions from glycol dehydrator A. Still vent emissions B. Flash tank emissions Reciprocating Internal Compression Engines (RICE)* Compressor skids* Emissions control device on the engine (pre-catalyst exhaust leaks)* Hydrocarbon dew point control/jt skids Unintentional gas carry-through (e.g. blowdown vent stacks) Enclosed flare/combustor (top) C. Inspection points at gas processing plants All the same inspection points as compressor stations Amine units (routing of still vent and flash tank emissions) Turbines* Flare tips*

3 Date (Month/Day/Year): Facility Name, Owner/Operator (company) & AIRS ID: Ambient Conditions, (e.g. Sky Conditions, Ambient Temperature, Humidity, Wind Speed & Direction): Inspector(s): Table 1 - Inspection Points at Compressor Stations and Gas processing plants EG/TEG/DEG Dehydrator or Amine Unit Emission Points Observation/ Inspection Point 1. The emissions routing of the Flash tank on the dehydrator or amine unit Emissions Found? Leak details Picture #: Picture #: 2. Glycol or amine regeneration still vents

4 Observation/ Inspection Point 3. Closed Vent system (all tank emissions that are routed to a control device) Emissions Found? Oil & Condensate Storage tanks Leak details Picture #: PLOT PLAN SKETCH OF TANKS (to clearly identify which leaks go with which tanks):

5 Observation/ Inspection Point Emissions Found? Flaring Enclosed or Candlestick Leak details Picture #: 4. Flare Tip* Remember to pan the camera away from the hot flare tip until it is out of the viewing screen and hold it there for a few seconds to let the camera adjust. This will allow for a clearer plume contrast against the environment. Follow the plume as far as possible. Describe: Visual (Flame - ugly orange, small blue flame, transparent, not visible, etc.; Steam plume exiting the tip) Sound (high pitch indicative of a lot of steam emanating from nozzles, fan running, etc.) NOTES: If extended hydrocarbon plumes are observed from the flare tip ask for the following information: Source(s) of waste gas stream(s) directed to the flare Volumetric flow rate of waste gas how could they estimate such if they do not measure (e.g. if dehydrator emissions routed to flare, use GLYCalc w/ contemperaneous operating parameters) BTU content of waste gas stream - how could they estimate such if they do not measure Volumetric flow rate of steam or air assist If they do not measure this, then ask for the fan speed or amperage of the fan (factory spec curves can also provide flow rate vs. rpm) for air assisted flares or note the valve position for the steam or air assist. For fans, also note whether single, dual, or variable speed. If possible, record further IR camera observations of the flare with the steam or air assist rate lowered.

6 Engines & Turbines Picture #: 5. RICE (Reciprocating Internal Compression Engine)* Picture #: 6. Turbines*

7 Compressor Skids & RICE/Turbine Emissions Control Device Picture #: 7. Compressor Skid* Picture #: 8. Emissions Control Device (pre-catalyst exhaust leaks)*

8 Observation/ Inspection Point Hydrocarbon dew point skids (a.k.a Joules Thompson or JT Skid) Emissions Found? Leak details 9. Where are the Hydrocarbon emissions from the skid routed? a. Is that point controlled? Picture #: 10. If answered no to #9 a., flash emissions recorded? 11. Piping, valves and fitting on the skid

9 Leaks & Unintentional Gas Carry Through 12. All Vent Stacks Blowdown Vent Stack Oil Sump Pit Glycol Drain Tank Other: Operator Informed of Leak? 13. All Vent Stacks Blowdown Vent Stack Oil Sump Pit Glycol Drain Tank Other: Operator Informed of Leak?

10 Leaks & Unintentional Gas Carry Through 14. All Vent Stacks Blowdown Vent Stack Oil Sump Pit Glycol Drain Tank Other: Operator Informed of Leak? 15. All Vent Stacks Blowdown Vent Stack Oil Sump Pit Glycol Drain Tank Other: Operator Informed of Leak? * - if emissions are found use section I.D to increase resolution of the camera in the range of the emissions.