Lizzy Morrison


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  • This section specifies the process and procedures required to identify and respond to leaks indicated by audio, visual, and/or olfactory (AVO) methods, in conjunction with fugitive emissions monitoring programs in compliance with EPA Method 21.



  • Internal compliance with the AVO policy and procedures will ensure the LDAR program is in compliance with regulatory requirements and EPA Method 21 protocols for fugitive emissions monitoring programs.
  • Internal assessments and QA /QC checks will identify potential continuous improvement steps for the AVO policy to the improvement of the LDAR program.
  • For AVO-detected leaks, the component repair must be attempted within 5 days, and final repair completed within 15 days.
  • Delay-of-repair of leaking equipment will be allowed upon a demonstration to the Administrator that repair within 15 days is not feasible.
  • This document details the proper use of the AVO Log.

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