Even with a heightened awareness of LDAR compliance requirements among monitoring technicians and plant Environmental and Operations personnel, there are some persistent compliance issues commonly found during third-party LDAR audits beyond the low-hanging fruit of open-ended lines and missing delay of repair tags that you will not necessarily find from an annual HRVOC audit. This presentation will discuss several common issues identified from the past few years of LDAR program audits within the chemical industry at sites in Texas and Louisiana as well as some areas of inquiry that EPA has been recently exploring. The goal is to help identify questions to take back to your plant to ensure that your LDAR program can withstand an outside audit or agency investigation.