What are the compliance deadlines for bulk gasoline terminals under the new EPA rules?

For NESHAP 6B and MACT R with Appendix K, existing sources must comply by May 8, 2027, while new sources must comply upon startup. If you construct, modify, or reconstruct your facility after June 10, 2022, you are subject to NSPS XXa and must comply upon startup following construction, modification, or reconstruction.

What regulations currently apply to bulk gasoline terminals?

All bulk gasoline terminals currently fall under one of two regulations: 40 CFR 63 Subpart R (MACT R) for Major Sources of HAP, or 40 CFR 63 Subpart BBBBBB (NESHAP 6B) for Area Sources of HAP.

What is the difference between Method 21 and OGI monitoring?

Method 21 uses a portable hydrocarbon detector to measure concentration at individual components, requiring physical access to each valve, flange, pump seal, and connector. Optical Gas Imaging (OGI) utilizes infrared camera technology to visually detect hydrocarbon emissions across broad areas without requiring component-by-component contact.

What are the advantages of OGI monitoring over Method 21?

OGI cameras survey significantly more equipment per day than Method 21, operating 6x to 22x faster. They eliminate the need for manlifts or scaffolding, reducing both safety risks and costs. OGI also removes the requirement to maintain a detailed component inventory, requiring only identification of equipment subject to LDAR requirements and a route map. Overall, OGI reduces technician headcount, minimizes risk exposure, and simplifies data management.

Does NSPS XXa have different compliance dates?

Yes. If you construct, modify, or reconstruct your affected facility after June 10, 2022, you are subject to NSPS XXa, which requires a quarterly Method 21 or OGI LDAR program as outlined in Appendix K upon startup following construction, modification, or reconstruction.

What LDAR services does Alliance Technical Group provide for bulk gasoline terminals?

Alliance provides nationwide Method 21 and OGI expertise backed by certified camera operators, licensed drone pilots, and experienced LDAR professionals. Services include determining applicability, preparing compliance plans, conducting inspections, managing LDAR programs, and preparing reports to help facilities meet evolving survey requirements.

Bulk Gasoline Terminal Compliance: New Monitoring Requirements and Key Deadlines

Q: What is Appendix K and how does it affect bulk terminals?

Appendix K modifications require instrument monitoring in place of AVO (Audio, Visual, Olfactory) requirements. Facilities must choose between Method 21 or OGI (Optical Gas Imaging) monitoring as outlined in Appendix K to meet compliance requirements.

Alliance Technical Group
9 hours ago
2 min read

All Bulk Gasoline Terminals currently fall under one of two regulations:

40 CFR 63 Subpart R (MACT R) for Major Sources of HAP

40 CFR 63 Subpart BBBBBB (NESHAP 6B) for Area Sources of HAP

What Changed: Appendix K Requirements for Bulk Gasoline Terminals

The modifications to these regulations require instrument monitoring in place of AVO requirements. Facilities must choose between Method 21 or OGI monitoring, as outlined in Appendix K, to comply with bulk gasoline terminal requirements.

Compliance Deadline: NESHAP 6B and MACT R with Appendix K

Existing sources: May 8, 2027

New sources: Upon startup

NSPS XXa: Earlier Compliance Dates May Already Apply

If you construct, modify, or reconstruct your affected facility after June 10, 2022, you are subject to NSPS XXa. This requires a quarterly Method 21 or OGI LDAR program, as outlined in Appendix K upon startup following construction, modification, or reconstruction.

Choosing Your Monitoring Method: Method 21 vs OGI

Method 21 uses a portable hydrocarbon detector to measure concentration at individual components. Surveyors physically access each valve, flange, pump seal, and connector with the instrument.
Optical Gas Imaging (OGI) monitoring, as outlined in Appendix K, utilizes infrared camera technology to visually detect hydrocarbon emissions across broad areas without requiring component-by-component contact.

When OGI Makes Sense

OGI cameras survey significantly more equipment per day than Method 21, operating 6x to 22x faster.
They eliminate the need for manlifts or scaffolding—depending on your site’s configurations—which reduces both safety risks and costs.
OGI also removes the requirement to maintain a detailed component inventory. Instead, facilities only need to identify equipment subject to LDAR requirements and provide a route map, allowing for less burdensome compliance documentation.

Overall, OGI reduces technician headcount, minimizes risk exposure, and simplifies data management.

Please note that Method 21 may be a better fit for sites with an existing component inventory or state- or local-level Method 21 requirements already in place.

End-to-End LDAR Solutions for Bulk Gasoline Terminal Compliance

If your facility is subject to these regulations or you expect to become subject, now is the time to prepare.

We can help you determine applicability, prepare a plan, conduct inspections, manage the program, and prepare your reports.

Alliance provides nationwide Method 21 and OGI expertise backed by certified camera operators, licensed drone pilots, and experienced LDAR professionals. Our team helps facilities meet evolving survey requirements and strengthen their compliance programs with complete, reliable coverage.

Let's talk.