What this is, and what it is not

You already have an LDAR program. Maybe it was set up by a previous contractor. Maybe an engineer wrote a one-page SOP in 2014 and nobody touched it. Maybe the program looks fine on paper but the inspector keeps writing the same finding. Whatever it is, you do not need someone to sell you software. You need someone to read the rule, walk the unit, and tell you in writing what is broken and how to fix it.

That is what this engagement does. We audit the program against the rule that actually applies (VV, VVa, GGG, GGGa, OOOO, OOOOa, OOOOb, MACT CC, HON Subpart H, whichever combination is yours). We document the gaps. Then we write a protocol that any competent LDAR contractor — including, but not limited to, us — can pick up and execute.

Phase 1 — The Deep Dive

Three to ten days on the ground, depending on facility size. We do the work an inspector would do, only without the citation at the end.

• Applicability determination. What rule actually applies to which units, and why. Documented with citation back to the CFR.
• Component inventory audit. Pull your current tag list, walk a statistically valid sample, find the components that are missing, mis-classified, or in the wrong service.
• Recordkeeping review. 2 to 5 years of monitoring records, delay-of-repair documentation, calibration logs, alternative monitoring requests. We tell you which records would not survive an EPA Section 114.
• Method 21 / OGI procedure observation. We watch your monitors work. Background readings, drift checks, dwell time, repair verification. Where the procedure deviates from Method 21 or OGI best practice, we say so.
• Permit cross-walk. Title V conditions, state SIP requirements, consent decree obligations — all mapped against the LDAR program to find the requirements you are not actually meeting.

Phase 2 — The Written Protocol

The deliverable is a written LDAR Program Protocol your team owns. We do not put it behind a login. We do not require you to use our software. The document covers, in operator-grade detail:

• Applicability matrix — every affected facility, the specific subpart, and the compliance date.
• Component tagging methodology — how to identify, classify, and ID new equipment as the unit changes.
• Monitoring schedule — component-by-component, with quarterly/monthly cadence and OGI vs Method 21 election documented.
• Leak definitions and repair procedures — 500 ppm, 2,000 ppm, 10,000 ppm thresholds applied where they actually apply.
• Delay-of-repair criteria and documentation forms — the language inspectors look for, ready to use.
• Recordkeeping requirements — what to keep, where to keep it, how long, and what format the regional EPA office expects.
• Reporting calendar — every semiannual, annual, or excess emission report tied to the rule, with submission method (CEDRI, paper, e-mail).
• QA/QC procedures — calibration, drift, audit trail, and the internal review process before any report goes out.
• Training requirements — what each role on the program needs to know, document, and renew.
• Contractor scope template — an Exhibit A you can attach to any vendor agreement. Defines deliverables, data formats, and acceptance criteria.

Why This Engagement Exists

We came up under the LDAR Busters banner doing this work for refineries and chemical plants across the Gulf. Almost every program we audited had the same problem: nobody on the operator side could point to a single document that said exactly what the LDAR program was supposed to do. The vendor had a procedure. The permit had requirements. The CFR had the rule. None of them agreed.

The protocol fixes that. Once it exists, the audit findings drop, the contractor relationship gets simpler, and the program survives staff turnover. That is the whole job.

Frequently Asked