Internal audit, consent-decree third-party audit, or an EPA inspection — they all pull the same threads. Here’s what actually gets checked, so nothing surprises you.
1. Applicability & the component list
- Are all regulated components identified, tagged, and in the database?
- Is each on the correct subpart with the right leak definition (e.g. 500 ppm valves, 2,000 ppm pumps under NSPS GGGa)?
- Do the counts in the field match the counts on paper?
2. Monitoring records
- Was every component monitored on the required frequency?
- Do the Method 21 readings, routes, and dates reconcile with the schedule?
- Are there gaps, missed components, or unexplained “no access” entries?
3. Repair timeliness
- First attempt within 5 days, repair within 15 (40 CFR 60.482-7/-9)?
- Do re-monitor readings confirm the repair worked?
4. Delay of repair
- Does every DOR component meet a valid criterion and carry documentation?
- Is each tied to a shutdown and re-monitored after startup?
5. Calibration & instruments
- Daily calibration logs, drift checks, and gas certs?
- Response factor and calibration precision within Method 21 limits?
6. Recordkeeping & reporting
- Are deviations reported and periodic reports complete and on time?
- Does the whole record tell one consistent story?
Frequently asked
What trips up most LDAR programs in an audit?
Records that don’t reconcile. The monitoring data, repair logs, and delay-of-repair list have to tell one consistent story. When they disagree, an auditor keeps pulling — and that’s where deviations surface.
How often should we self-audit?
At least annually, and before any known EPA attention or consent-decree milestone. A self-audit that mirrors how a third party works is the cheapest way to find problems while you can still fix them quietly.
What is a third-party audit under a consent decree?
Many consent decrees require an independent auditor to review the LDAR program on a set schedule against decree-specific terms — often stricter leak definitions and monitoring frequencies than the baseline rule. We’ve stood up and run programs under exactly that scrutiny.
This is general information, not a regulatory applicability determination. How these requirements 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 make your next LDAR audit easier
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.
QuickScope™
Database-driven field inspections powered by the same rules engine as the Hub — built to make LDAR surveys faster and audit-ready.