FW: Oil & Natural Gas Sector Leaks White Paper Comments

Dear EPA,

I’m sending my original e­mail comments in a Word document.

I appreciate your consideration to my comments.

Take Care,

Paul

Paul D. Wehnert

Senior Vice President ­

Sales & Marketing

Heath Consultants Incorporated

9030 Monroe Road

Houston, Texas 77061 USA

Office: 713­844­1391 

Fax: 713­844­1309 

Mobile: 713­208­0411

Skype: paul.wehnert 

p.wehnert@heathus.com

www.heathus.com

Paul Wehnert <p.wehnert@heathus.com>

Fri 6/13/2014 12:36 PM

To:OilandGas.Whitepapers <OilandGas.Whitepapers@epa.gov>; 

 3 attachments

EPA Subpart W Rule.pdf; rmld-is_brochure.pdf; Letter - EPA - 06-13-14.pdf; 

FW: Oil & Natural Gas Sector Leaks White Paper Comm... - OilandGas.Whitepapers Page 1 of 4

https://pod51045.outlook.com/owa/OilandGas.Whitepapers@epa.gov/ 8/26/2014
From: Paul Wehnert [mailto:p.wehnert@heathus.com]

Sent: Tuesday, June 10, 2014 6:42 PM

To: 'oilandgas.whitepapers@epa.gov'

Cc: 'frish@psicorp.com'; 'Jim Rutherford'; 'milt.heath3@heathus.com'; 'Sean Epps'; 'Gerald V Sims'

Subject: Oil & Natural Gas Sector Leaks White Paper Comments

Dear EPA,

I am writing this e­mail in response to the White Paper Titled “Oil & Natural Gas Sector 

Leaks” – Review Panel – April 2014.

The Paper describes in FULL detail the use of both Method 21 screening tools and the 

use of the Optical Gas Imaging Camera (OGI) as the two (2) preferred methodologies for 

leak detection at both Oil and Natural Gas facilities.

In the EPA 40 CFR Part 98 ; Mandatory Reporting of Greenhouse Gas; Petroleum and 

Natural Gas; Final Rule of which I’ve attached and highlighted discusses the use of 

Infrared Laser Beam Illuminated Instrumentsalong with Method 21 and Optical Gas 

Imaging Camera’s (OGI).

However in the EPA White Paper there is only one mention of Infrared Laser Beam 

Illuminated Instruments but doesn’t really go into any detail regarding the use of such 

technology in this Industry Sector.

Heath Consultants Incorporated has been in the field of Natural Gas Leak Detection for 

over 80 years with over 1,100 employee’s doing leak detection field services and 

manufacturing leak detection technologies every day.

We currently manufacture / distribute Method 21 screening tools with technologies of 

Flame­ionization (DP­4), Optical infrared (DP­IR) and Catalytic / Thermal Conductivity 

devices like the GMI 3­500.

We also distribute the Opgal EyeCGas Imaging Camera that is similar to the FLIR Optical 

Gas Imaging Camera.

We also distribute the HiFlow Sampler that is mentioned in the White Paper for leak 

quantification.

We also manufacture the Remote Methane Leak Detector (RMLD) that is a tunable 

diode laser absorption spectroscopy (TDLAS) instrument that in effect is the Infrared 

Laser Beam Illuminated Instrument as referenced in the EPA Final Rule document.

FW: Oil & Natural Gas Sector Leaks White Paper Comm... - OilandGas.Whitepapers Page 2 of 4

https://pod51045.outlook.com/owa/OilandGas.Whitepapers@epa.gov/ 8/26/2014
The instrument can detect natural gas (methane) leakage at a distance of up to 30 

meters or 100 feet from the emission source similar to that of the OGI Camera but 

rather than to image the leak it gives a ppm­m concentration of the leak rate.

The RMLD has the following unique features;

­Able to calibrate easily in the field on a daily basis

­Repeatable readings in sunlight, darkness and temperature variations

­Operates in a wide range of ambient and product (GHG) temperatures

­Intrinsically Safe

­Portable

­Easy to Operate

­Sells for approximately $20,000 or 1/5 the cost of an OGI Camera so is very 

affordable

­Can detect small leaks down to several “ppm­m” that the OGI Camera can’t detect

­Minimal operator training

There are literally thousands (1,000’s) of these devices in service around the World 

locating leaks on a daily basis at Natural Gas Utilities as a common approved practice 

but this is never mentioned in the White Paper as an alternative method to both 

Method 21 and OGI Camera’s although is mentioned in the EPA Final Rule.

I’m not responding from a “commercial” aspect as there are other manufactures of 

Infrared Laser Beam Illuminated Instruments but feel these should be discussed in 

more detail as an option for affordable and reliable leak detection at Oil and Natural Gas 

Facilities.

Please feel free to contact me at the numbers / e­mail listed below and I appreciate your 

time.

Take Care,

Paul

Paul D. Wehnert

Senior Vice President ­

Sales & Marketing

FW: Oil & Natural Gas Sector Leaks White Paper Comm... - OilandGas.Whitepapers Page 3 of 4

https://pod51045.outlook.com/owa/OilandGas.Whitepapers@epa.gov/ 8/26/2014
Heath Consultants Incorporated

9030 Monroe Road

Houston, Texas 77061 USA

Office: 713­844­1391 

Fax: 713­844­1309 

Mobile: 713­208­0411

Skype: paul.wehnert 

p.wehnert@heathus.com

www.heathus.com

FW: Oil & Natural Gas Sector Leaks White Paper Comm... - OilandGas.Whitepapers Page 4 of 4

https://pod51045.outlook.com/owa/OilandGas.Whitepapers@epa.gov/ 8/26/2014