A compliant Leak Detection and Repair (LDAR) program is a system, not a checklist. Built well, it produces the timestamped, defensible record that turns a regulatory inspection into a routine verification; built poorly, it is the source of the missed-survey and late-repair citations that draw six-figure fines. This guide walks through building an LDAR program from scratch in three phases: mapping your obligations, standing up the system, and running it.
What is an LDAR program, and what does it require?
An LDAR program is the systematic process of finding and fixing equipment leaks, broken into three stages: identify, monitor, and repair. Under EPA NSPS Quad O, well sites and compressor stations must survey regulated components (valves, connectors, pumps, pressure-relief devices, open-ended lines) on a set schedule using Optical Gas Imaging (OGI) or EPA Method 21, flag any component at or above 500 ppm or with visible emissions as a leak, and repair it on a defined clock. The rest of this guide is how you build the program that does all of that reliably.
Phase 1: Inventory your components and map the rules
The program is only as good as the data it starts with. Two tasks define the scope.
Build a complete component inventory
Start with a full physical inventory of every regulated component at each facility, each with a unique tag and an entry in a master database. This inventory is the immutable basis of the whole program; an inaccurate or incomplete inventory cascades into systemic non-compliance because you cannot monitor what you have not catalogued.
Run a regulatory stack analysis
Map each site to the rules that apply to it, and design to the most stringent:
- EPA: determine applicability for 40 CFR Part 60 Subparts OOOO, OOOOa, OOOOb, and OOOOc. Each subpart has its own monitoring frequency, leak definition, and repair timeline.
- RRC: align with Texas rules such as Statewide Rule 32 on flaring and venting, which intersects with fugitive-emissions obligations.
- OSHA: document procedures for safely accessing components and managing chemical exposure for the crews conducting surveys.
| Requirement | NSPS OOOOa | NSPS OOOOb / OOOOc |
|---|---|---|
| Applicability | Sources constructed or modified after Sept 18, 2015 | Sources constructed or modified after Dec 6, 2022 (OOOOc covers existing sources via state plans) |
| Leak definition | 500 ppm (Method 21) or any visible emissions (OGI) | 500 ppm (Method 21) or any visible emissions (OGI) |
| Well site monitoring frequency | Semi-annually | Quarterly (may drop to semi-annually after 4 consecutive quarters below a 3% leak rate) |
| Repair timeline | Initial attempt within 30 days; final repair within 30 days of the attempt | Same 30/30 structure, with more prescriptive recordkeeping |
| Recordkeeping | All monitoring, repair attempts, and delays | Survey logs, OGI video, and detailed repair documentation |
Phase 2: Choose your method and build the system
Method 21, OGI, or both
The two approved methods serve different purposes. EPA Method 21 uses a portable analyzer to quantify concentration at each component. OGI cameras make leaks visible with infrared and survey far more equipment per day. They are not mutually exclusive, and the strongest programs use them together: OGI to rapidly find where leaks are, then a Method 21 reading to quantify how large. Document the rationale for your technology choice as part of the official record, so you can defend the methodology during an audit.
Stand up the data system
Your LDAR database is your primary defense in an audit, so treat the file like a litigation record. It must track every component, inspection date, monitoring result, repair attempt, and Delay of Repair justification, with every entry timestamped, auditable, and secure, and it must generate reports in the formats the EPA and RRC require.
Assign roles and write SOPs
Give every part of the program a clear owner: an LDAR manager, certified field technicians (in-house or third-party), and the maintenance personnel who make repairs. Write standard operating procedures for monitoring, repair verification, and reporting, and train all personnel on them. Ambiguous ownership is a direct path to a missed survey.
Phase 3: Run, repair, and self-audit
A compliant program is a continuous cycle, not a one-time build. Execute the monitoring schedule consistently, because when a leak is found, a strict clock starts.
| Step | Action | Deadline |
|---|---|---|
| 1. Detection | A leak is identified via OGI or Method 21 survey | Day 0 |
| 2. Initial repair attempt | First attempt to repair the leaking component | Within 30 calendar days of detection |
| 3. Repair verification | Re-monitor to confirm the repair held | Within 30 calendar days of the initial attempt |
| 4. Final repair | If the first attempt failed, complete the repair | Within 30 calendar days of the initial attempt |
| 5. Delay of Repair | If repair is not feasible in time, document a DOR with specific justification (e.g. awaiting a shutdown or parts) | Before the final repair deadline expires |
Finally, self-audit. The LDAR manager should run periodic internal audits against the requirements mapped in Phase 1 to catch gaps before regulators do, and every required semi-annual or annual report to the EPA and RRC must go in accurately and on time.
How Tektite helps
Building an LDAR program from scratch is precise, document-heavy work, and the failure modes (an incomplete inventory, the wrong applicable subpart, a missed repair deadline) are exactly the ones inspectors look for. Tektite builds and runs LDAR programs for Texas operators end to end, and you can check your applicable subpart and monitoring schedule in minutes with our free Quad O / LDAR compliance calculator.
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Frequently Asked Questions
What is the leak definition under NSPS OOOOa?
Under NSPS OOOOa, a leak is defined as 500 ppm using EPA Method 21, or any visible emissions detected via Optical Gas Imaging (OGI). The OOOOb/OOOOc rules apply the same 500 ppm and visible-emissions thresholds.
How often must well sites be monitored under NSPS OOOOa versus OOOOb?
NSPS OOOOa requires semi-annual monitoring of well sites, while OOOOb/OOOOc requires quarterly monitoring until the leak rate is below 3% for four consecutive quarters, after which it can drop to semi-annually. Determining the applicable framework is part of the regulatory stack analysis in proper LDAR program development.
What are the repair timelines after a leak is detected?
Under NSPS Quad O, the initial repair attempt must be made within 30 days of detection, and final repair completed within 30 calendar days of the initial attempt. If a repair is not feasible in that window, a Delay of Repair (DOR) must be documented with specific justifications before the deadline expires.
Which regulations must a Texas operator map for an LDAR program?
Operators must map federal EPA standards under 40 CFR Part 60 (Subparts OOOO, OOOOa, OOOOb, and OOOOc), Texas RRC rules such as Statewide Rule 32 governing flaring and venting, and OSHA requirements for the safety of the personnel conducting surveys.
