' )' ,,, HEATH 

fCONSULTANTS 

Heath Consultants Incorporated 

June 13, 2014 

Dear EPA, 

I am writing this e-mail 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 Instruments along 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 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 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. 

Corporate Headquarters: 9030 Monroe Road, Houston, Texas 77061-5229 

Phone: (713) 844-1300 • Fax: (713) 844-1309 
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 ppm-m 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"ppm-m" 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. 

Paul D. Wehnert 

enio~/ice President -

Sales & Marketing 

ct me at the numbers I e-mail listed below and I appreciate your time.