LDAR Program Services

What Fugitive Emissions Are and Why They Matter

Fugitive emissions are unintended releases of gas from equipment components: valves, flanges, connectors, pump seals, compressor seals, and pressure relief devices. They are called fugitive because they are not released through a stack or vent — they escape from leaks in the equipment itself. In oil and gas operations, fugitive emissions are primarily methane and volatile organic compounds (VOCs), both of which carry significant regulatory and environmental consequences.

EPA and TCEQ regulate fugitive emissions from oil and gas sources under multiple frameworks, including NSPS OOOOa (Quad O), NSPS OOOOb, and Texas air permit conditions. The core compliance mechanism for all of them is a Leak Detection and Repair (LDAR) program: a systematic process for monitoring components, identifying leaks, and repairing them within required timeframes.

What an LDAR Program Involves

An LDAR program is not a one-time inspection. It is an ongoing compliance obligation with specific monitoring frequencies, documentation requirements, and repair deadlines. The components of a compliant leak detection and repair program include:

Component Inventory: A complete, tagged inventory of all regulated components at the facility: valves, connectors, open-ended lines, pump and compressor seals, and pressure relief devices.
LDAR Monitoring: Periodic leak detection surveys using EPA Method 21 (instrument-based) or approved optical gas imaging (OGI) techniques, conducted on the schedule required by your applicable standard.
Leak Repair and Re-monitoring: Leaking components must be repaired within defined timeframes (typically 15 or 30 days) and re-monitored to confirm the leak is resolved.
Recordkeeping: Component-level records of every monitoring event, leak detection, repair attempt, and re-monitoring result. These records are what regulators audit.
Skip Period and Alternative Work Practice Monitoring: Programs that qualify may use approved alternative monitoring methods, including OGI surveys in place of Method 21, under specific conditions.

Smart LDAR and OGI Monitoring

EPA has approved optical gas imaging (OGI) cameras as an alternative monitoring method under certain conditions, commonly referred to as smart LDAR. OGI allows technicians to visually detect fugitive gas emissions across large component populations in a fraction of the time required by traditional Method 21 monitoring. For facilities with high component counts, smart LDAR approaches can significantly reduce the cost and labor burden of compliance while maintaining or improving detection sensitivity.

Tektite evaluates whether your facility qualifies for OGI-based monitoring and, where applicable, designs LDAR programs around it. We also support facilities that must use Method 21 as the primary detection method.

Building a Program From Scratch vs. Auditing an Existing One

New facilities, newly regulated sources, and operators who have never formalized their LDAR obligations often need a program built from the ground up. That starts with identifying your applicable standards, conducting an initial component inventory and tagging, establishing monitoring schedules, and creating a recordkeeping system. Tektite handles all of it.

Operators who already have a program in place but are unsure of its completeness or accuracy benefit more from an LDAR audit. We review your component inventory, monitoring frequency records, repair documentation, and any delinquent components to identify gaps before they surface in a regulatory inspection.

Frequently Asked Questions

What is an LDAR program?

A Leak Detection and Repair (LDAR) program is a regulatory compliance framework that requires facilities to systematically monitor equipment components for fugitive gas emissions, document the results, repair leaking components within required timeframes, and maintain records of all monitoring and repair activity. It is the primary compliance tool for EPA NSPS OOOOa and related air regulations.

Which EPA regulations require an LDAR program?

The primary EPA LDAR requirements for oil and gas operators come from NSPS OOOOa (40 CFR Part 60, Subpart OOOOa) and its successor NSPS OOOOb. TCEQ air permit conditions may impose additional or parallel LDAR obligations. The specific requirements that apply to your facility depend on the construction or modification date of your affected sources and the category of equipment involved.

How often does LDAR monitoring need to happen?

Monitoring frequency depends on the applicable standard and component type. Under NSPS OOOOa, monitoring frequencies range from quarterly to annually depending on the equipment. Alternative work practice approvals, skip period rules, and low-emission component designations can modify these schedules. A properly designed program documents the specific frequency and basis for every component class.

Can OGI cameras replace Method 21 monitoring?

In many cases, yes. EPA has approved OGI as an alternative monitoring method under specific conditions. The eligibility criteria depend on the applicable standard and the facility's monitoring history. For facilities that qualify, OGI-based smart LDAR approaches are typically faster and more cost-effective than traditional instrument-based surveys.