Webinar: Real-World Lessons on NESHAP Subpart BBBBBB (6B) and NSPS Subpart XXa
In May 2024, EPA finalized NESHAP Subparts R and BBBBBB (6B), as well as NSPS Subpart XXa, introducing more stringent air compliance requirements for gasoline terminals and pipeline facilities. As these requirements take effect, many midstream operators are evaluating how to prepare for compliance while navigating practical implementation challenges.
Join Trihydro for a webinar focused on lessons learned from early implementation efforts under NESHAP Subpart 6B and NSPS Subpart XXa. Drawing from field experience, presenters will share insights from Appendix K optical gas imaging (OGI) surveys, including both proactive and compliance-driven monitoring activities, along with observations on equipment types and operating conditions commonly associated with emissions.
The session will also explore practical approaches facilities are using to evaluate NSPS Subpart XXa modification determinations, including strategies for assessing component-level changes that may help avoid triggering modification requirements. In addition, attendees will gain firsthand insights into internal floating roof (IFR) tank lower explosive limit (LEL) measurements conducted in accordance with referenced Subpart Kc requirements, including key considerations for equipment selection, measurement methodologies, and effective field execution.
What We’ll Cover:
- Early field insights from NESHAP Subpart 6B and NSPS Subpart XXa implementation efforts
- Findings from proactive and compliance-driven OGI surveys
- Common equipment types and operating conditions associated with emissions
- Field implementation challenges and practical compliance considerations
- Approaches for evaluating NSPS XXa modification determinations, including component-level strategies
- Key considerations for IFR tank LEL measurements, equipment selection, and field execution
About the Presenters
Dan Wood, Senior Scientist, Trihydro
Daniel Wood is the Team Leader of Trihydro’s Air Compliance Services Team and a Senior OGI Operator with more than 10 years of experience in air quality consulting and regulatory compliance. He specializes in optical gas imaging (OGI), LDAR programs, Subpart W, NSPS OOOOa/b/c, and gasoline distribution regulations, including NESHAP Subparts 6B and R and NSPS XXa. Daniel has managed OGI and LDAR programs across the United States and provides technical leadership in emissions monitoring, compliance strategy, and regulatory implementation. He also serves as the Air Technical Lead for LeakTracker Pro®.
Nick Carlson, Associate Scientist, Trihydro
Nick Carlson is an Environmental Scientist and Senior OGI Operator with experience in air compliance, emissions monitoring, and regulatory support. He specializes in optical gas imaging (OGI), compressor vent flow measurements, emissions inventories, permitting, and compliance programs, including NSPS OOOOa/b/c, Gasoline Distribution Rules (NESHAP 6B, NESHAP R, and NSPS XXa), and EPA Greenhouse Gas Reporting Program Subpart W requirements. Nick provides project management and technical support for clients navigating federal, state, and local air quality regulations.
