Validation for EPA’s NSPS 40 CFR Part 60, Subpart OOOOa
In 2016, the US EPA released a regulation, called Subpart OOOOa that recommends leak detection and repair (LDAR) for oil and gas operations sites. It recommends Optical Gas Imaging as the BSER (Best System of Emission Reduction) to use for leak detection.
NPL's miniature Controlled Release Facility (mini-CRF) provides a system to test compliance of OGI cameras to the OOOOa standard. It contains an array of Mass Flow Controllers (MFCs) that control the flow of gas from cylinders of propane and methane and a balance gas of air or nitrogen. These are used to achieve the required test gas mix by dynamic dilution, following guidance in BS EN ISO 6145-7:2010.
The miniature Controlled Release Facility (mini-CRF) provides a system to test compliance of OGI cameras to the OOOOa standard. It controls the flow of gas from cylinders of propane and methane to an emission node where it provides a test source for demonstrating compliance with the OOOOa sensitivity requirement.
The summary specifications are:
In addition to providing the required hydrocarbon release defined in the regulation, NPL has the capability to control other parameters which influence successful gas detection by OGI systems. These include:
In addition to the mini-CRF, NPL can also provide other controlled sources of emissions for testing and training purposes. This includes the larger CRF facility for fugitive emissions system validation and the leak simulation facility that can generate controlled gas leaks from a wide range of realistic sources, including pipe flanges.
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