# ' )' ,,,HEATH fCONSULTANTS Heath Consultants Incorporated June 13, 2014

Dear EPA, Iam writingthis e-mail in response tothe White PaperTitled "Oil 

### & Natural Gas Sector Leaks"- Review Panel- April 2014. The Paper describes in FULL detailthe use ofboth Method 21 screeningtools and the use ofthe 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 ofwhich I've attached and highlighted discusses the use of Infrared Laser Beam Illuminated Instruments alongwith Method 21 and Optical Gas Imaging Camera's (OGI). However in the EPA White Paperthere is only one mention ofInfrared Laser Beam Illuminated Instruments but doesn't really go into any detail regarding the use of such technology in this IndustrySector. 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 

## I distribute Method 21 screening tools with technologies of Flameionization (DP-4), Optical infrared (DP-IR) and Catalytic 

## I Thermal Conductivity devices like the GMI3-500. We also distribute the Opgal EyeCGas Imaging Camera that is similar to the FUR Optical Gas Imaging Camera. We also distribute the HiFiow Sampler that is mentioned in the White Paper for leak quantification. We also manufacturethe Remote Methane Leak Detector (RMLD) that is atunable diode laser absorption spectroscopy (TDLAS) instrument that in effect is the Infrared Laser Beam Illuminated Instrument as referenced in the EPA Final Rule document.

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 Phone: (713) 844-1300 • Fax: (713) 844-1309The 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 ofthe OGI Camera but rather than to image the leak itgives appm-m concentration ofthe leak rate. The 

### RMLD hasthefollowing uniquefeatures; Abletocalibrate easily in thefield on adaily basis Repeatable readings in sunlight, darkness and temperaturevariations Operates in awide range ofambient and product (GHG) temperatures IntrinsicallySafe Portable Easyto Operate Sells for approximately$20,000 or 1/5the cost ofan OGI Camera so is very affordable Can detectsmall leaks downtoseveral"ppm-m"thattheOGI Camera can't detect Minimal operatortraining 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 butthis 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.

Paul D. Wehnert



## enio~/ice President - S

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## I e-mail listed below and Iappreciate yourtime.