On April 6, 2006, EPA proposed a voluntary alternative work practice (AWP) for leak detection and repair using optical gas imaging – technology that displays leaks on a video screen similar to the way night vision goggles are used to show the heat signature of objects. This amendment provides requirements for using the new technology, but facilities may continue to use existing approved work practices to detect leaks.
Changes to the proposed rule include:
- The minimum detection sensitivity level has been removed to avoid the possibility of creating an emissions loophole in high-purity systems.
- In one screening per year, owners/operators will be required to use the AWP to screen equipment using EPA Method 21 instead of the optical gas imaging instrument.
- Owners/operators will be allowed to re-screen equipment after being repaired using either current work practices or the AWP if leaks were detected using the AWP, and re-screening with the current work practice if the leaks were detected by the current work practice.
- Owners/operators must keep records of the equipment, process units or facilities that are to be included in the AWP to document that a facility has chosen to comply with AWP. They also must keep video records of the daily instrument check and leak survey results for 5 years.
This amendment modifies about 40 national rules requiring facilities to find and repair leaks from equipment, including pumps, valves and connectors; refineries; chemical production plants; and bulk liquid storage facilities. It will be effective upon publication in the Federal Register.