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

Описание: 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?