Alternative Work Practice (AWP)

40 CFR Part 60 A sec 60.18(g)

The Alternative Work Practice is an EPA approved method that allows for Optical Gas Imaging along with one annual Method 21 survey to be used in lieu of a full Method 21 LDAR program. Our model using the ‘AWP’ allows us to reduce facility emissions while saving LDAR programs up to 35% on their LDAR budget. We have over 20 years of combined experience utilizing the AWP at Processing and LNG Export facilities.

The AWP can be used for any regulation in 40 CFR Parts 60, 61, 63, and 65 that requires Method 21 monitoring. For more information about the AWP, CLICK HERE

“Numerous EPA air pollution standards require specific work practices for equipment leak detection and repair (LDAR). [Method 21] requires the use of a monitor which meets required performance specifications. This work practice is based on 25-year-old technology. New technology has been developed which we believe provides equal, or better, environmental protection than that provided by [Method 21]. This action proposes a voluntary alternative work practice (AWP) for finding leaking equipment using optical gas imaging.”

Environmental Protection Agency


Subpart OOOOa for Production, Transmission and Storage Facilities

40 CFR Part 60 Subpart OOOOa

We have extensive experience servicing OOOOa all over the country at well sites and compressor stations. In addition to providing OGI leak detection services, we also develop monitoring plans and walking paths required by the regulation.


Subpart W (Greenhouse Gas)

40 CFR Part 60 Subpart 98

The Greenhouse Gas (GHG) regulation went into effect in 2010. Facilities that emit >25,000 metric tons of CO2e from all stationary fuel combustion sources in a calendar year or that meet any of the parameters described HERE.

We have over a decade of experience performing GHG surveys in all regions of the US. We are well versed in providing both the Mandatory Measurement and Leak Survey portions of the GHG regulation. We also provide reporting services through our consulting partners.


Voluntary LDAR

 

We strive to be the premier facilitator of Voluntary OGI programs in the US. Our past experience has uniquely positioned us to develop client-specific Voluntary Programs to help minimize environmental impact while maximizing emission reduction. Contact us to find out about our reduced rates for the development and implementation of Voluntary OGI Programs.


CDPHE Reg 7 AIMM

 

We are experienced in performing AIMM surveys to satisfy CDPHE Reg 7 requirements. We are strategically positioned in Colorado to provide Reg 7 services at well sites and gathering stations. In addition, we are well versed in the recordkeeping and reporting process.


PA DEP GP-5/GP-5a

We have years of experience performing GP-5 surveys to satisfy PA DEP requirements. We are strategically positioned with an office in Pittsburgh, PA to competitively provide GP-5/a surveys. In addition, we are well versed in the recordkeeping and reporting process.


TCEQ 28 and 30 TAC - Chapter 115

 

We have experience implementing the AWP at several facilities, including Processing and LNG Export, that fall under Texas state regulations such as TCEQ 28 MID and TAC - Chapter 115.

NMAC 20.2.50.116: Oil and Gas Sector - Ozone Precursor Rule

The NMED published the Ozone Precursor Rule in Issue 14 of the New Mexico Register (effective 08/05/2022). CLICK HERE to see the final rule.