(251) 308-5327 solutions@aim-env.com

OGI vs. Method 21: Which Leak Detection Method Does Your Refinery Need?

Teams ask us all the time whether they should be running Method 21 or OGI. Usually the applicable subpart already decided — but knowing why each exists keeps you from over-spending, or monitoring the wrong way.

The ruler

Method 21

EPA’s reference method (40 CFR Part 60, Appendix A-7) for measuring VOC leaks with a portable analyzer held at the component. It returns a ppm number — and that number is what your subpart’s leak definition is written against (e.g. 500 ppm valves, 2,000 ppm pumps under NSPS GGGa).

The camera

Optical Gas Imaging (OGI)

An infrared camera that lets you see a leak plume. Fast, great for hard-to-reach components and finding big emitters. EPA first allowed OGI as an Alternative Work Practice under 40 CFR 60.18; newer rules (NSPS OOOOa/OOOOb, the refinery and chemical NESHAPs) increasingly build it in.

Side by side

Method 21OGI
What it gives youA documented ppm concentration per componentA visual of the leak; find/fix, not a number
Best forCompliance counts against a leak thresholdWide sweeps, large emitters, hard-to-reach points
SpeedSlower — component by componentFast — scan many components at once
Regulatory basisReference method; most leak definitions written against itAlternative Work Practice (40 CFR 60.18) & built into newer NSPS/NESHAP

The rule usually decides

Where teams get burned is treating the two as interchangeable. An OGI survey doesn’t automatically satisfy a Method 21 monitoring requirement, and a Method 21 route won’t catch a leak on a component nobody scheduled. Read the controlling subpart first — then pick the tool.

How AIM runs both

OGI to sweep wide and catch the obvious leakers fast; Method 21 to put a defensible number on components when the rule requires a count and a repair clock. The camera finds it; the analyzer proves it — and we track every repair against the regulatory deadline.

Frequently asked

Is an OGI survey enough to meet a Method 21 requirement?

Not automatically. If your subpart is written against a Method 21 concentration and repair threshold, an OGI survey alone usually won’t satisfy it. OGI can qualify where the rule expressly allows it as an alternative work practice or building it in — read the controlling subpart before you swap methods.

Which is required at a refinery under Refinery MACT CC?

Refinery MACT (40 CFR Part 63, Subpart CC) and the NSPS subparts that apply to refinery equipment spell out the monitoring approach and leak definitions. Many refineries run Method 21 for compliance counts and use OGI where the applicable subpart permits it. The rule, not preference, sets the baseline.

What leak thresholds does Method 21 measure against?

It depends on the component and subpart — for example, 500 ppm for valves and 2,000 ppm for pumps under NSPS GGGa. Method 21 (40 CFR Part 60, Appendix A-7) gives the ppm reading; your subpart’s leak definition sets the number that counts.

Can you run both on our units?

Yes. We run OGI to sweep wide and catch large emitters fast, then Method 21 to put a defensible number on components when the rule requires a count — and we track every repair against the regulatory clock.

Not sure which your units require? AIM runs Method 21 and OGI at refineries and chemical plants every week. Talk to AIM →  ·  See our LDAR services

This is general information, not a regulatory applicability determination. How these methods apply depends on your equipment, permit, and the subpart you’re subject to. Confirm your obligations with a qualified professional or your permitting authority.

Two tools that keep your LDAR program ahead of the rule

The same regulatory engine we run for clients, put in your hands.

EHS Compliance Hub

Track every LDAR rule, Federal Register update, and compliance deadline that hits your facility — in one place, updated live. Free to use.

Open the EHS Hub →

QuickScope™

Database-driven field inspections powered by the same rules engine as the Hub — built to make LDAR surveys faster and audit-ready.

Explore QuickScope →