Optical Gas Imaging (OGI) in Regulatory Framework Panel, Ned Shappley, Will Shutt, Jared Metcalf

Moderator - The One, The Only Craig O'Neill • Will Shutt, Sr. Environmental Engineer and EHS Specialist at Coterra Energy:   / willshutt   • Ned Shappley, Physical Scientist at US EPA:   / ned-shappley-7b03116   • Jared Metcalf, VP of Air Compliance at Montrose Environmental:   / jared-metcalf-014433b   • MODERATOR: Craig O’Neill, Business Development Director at FLIR:   / craigroneill   GENERAL QUESTIONS • Explain your typical OGI and LDAR process? • Why has OGI in the hands of a skilled technician remained the “go-to” technology for detecting emissions going on a decade now? • Besides OGI for compliance, how have you used your OGI camera for non-OGI applications? • Can you provide an example of a time when you (or your team) have used OGI to solve an internal problem or found an unusual event? (OGI or general IR) • Operationally, how much more efficient are OGI programs vs. non-OGI programs? REGULATORY QUESTIONS • There’s a considerable amount of activity in regulatory framework currently tied to OGI. What do you see as a positive? Negative of these proposed regulations? What do you think that “should” have been done? • What are your thoughts of Appendix K / Subpart W / OOOOabc? • General thoughts about the current regulatory framework in process and how it applies to OGI? • Positives of App K? • Challenges with App K? • How do you see the various state regulations aligning with the proposed EPA regulations? Opportunities? Challenges? • For “new, modified or reconstructed” components • For “existing” components • How do you envision the new federal regulations that include monitoring “existing facilities” thorough state Emission Guidelines (OOOOc) affecting your organization? • Do you see any opportunities for OGI to be more involved in regulations? For example: • Appendix K applied to other “referenced subparts” • Use of OGI for specific requirements in facilities or processes….e.g., BWON inspections • What do you foresee as the next big step in regulations for LDAR (quantification, new tech., etc.)? • Do you feel that QOGI should be included in OOOOb or Subpart W? REPORTING QUESTIONS • How do you keep track of reporting for your LDAR process? • How do you envision Regulations (Appendix K; Subpart W, WEC) changing the way operators report? • How much time do you spend on the “Backend” of the reporting? WRAP UP QUESTIONS • What future challenges do you see tied to OGI? • Tell me one thing you are excited about related to the future of LDAR? • If you could change only ONE aspect of regulation for LDAR, what would it be?