Implementation of Leak Detection and Repair Program for Control of Fugitive Emissions from Enhanced Nitrogen Removal Facilities

In 2011, the District of Columbia Water and Sewer Authority (DC Water) was issued an Clean Air Act permit which required the implementation of a Leak Detection and Repair (LDAR) plan for their Enhanced Nitrogen Removal Facility (ENRF). This paper discusses the regulatory and technical challenges faced by DC Water during their implementation of each stage of the LDAR program related to the ENRF including: a) identifying and tagging each regulated component, b) determining the best location and detection method for leaks from different components, c) workflow and staffing challenges regarding leaking components and their repair, and d) effective procedures for documenting monitoring, leaks, and repairs. In addition, this paper includes a description of the methods used and the procedure used to determine the appropriate methods, frequencies, and thresholds for monitoring.