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Notice of Public Comment Period - Draft Air Quality Permit 7161-R1 and Proposal to Incorporate Language into the District's SIP

PUBLIC NOTICE

Draft Air Quality Permit 7161-R1, U.S. General Services Administration, Modification and operation of an existing 250 MMBTU/hr dual-fuel boiler (Boiler No. 6) at the Central Heating and Refrigeration Plant, 325 13th Street SW, with proposal to incorporate a permit requirement into the District's State Implementation Plan (SIP)

Notice is hereby given that, pursuant to 20 DCMR §210, the Air Quality Division (AQD) of the Department of Energy and Environment (DOEE), located at 1200 First Street NE, 5th Floor, Washington, DC, intends to issue Permit No. 7161-R1 to the U.S. General Services Administration (GSA) to install a flue gas recirculation (FGR) system on and operate existing Boiler No. 6, a 250 MMBTU/hr rated heat input dual-fuel boiler, capable of burning both natural gas and No. 2 grade ultra-low sulfur fuel oil at the Central Heating and Refrigeration Plant (CHRP) located at 325 13th  Street SW, Washington DC 20407. The contact person for the facility is George Korvah, Branch Manager – Environmental and Water Chemistry Branch, at (202) 690-9719 or [email protected].

In addition to standard permit issuance, with this action, DOEE is proposing to submit, to the U.S. Environmental Protection Agency (EPA), the requirements contained in Condition II(g) of the draft permit for inclusion in the District’s State Implementation Plan (SIP), found at 40 CFR § 52, Subpart J, and specifically 40 CFR §§ 52.470(d) and 52.479. DOEE is proposing to include the requirements of this permit condition in the SIP in order to ensure federal enforceability of an Alternative NOx RACT Plan submitted by GSA pursuant to 20 DCMR 805.2. Comments on this plan were previously taken pursuant to a public notice posted in the D.C. Register (Vol. 70 – No. 25, 008868 – 008869) and on the Department’s website (https://doee.dc.gov/node/1665741) on June 23, 2023.

Emissions Estimates:

 

Emissions of oxides of nitrogen (NOx) from the boiler are expected to decrease as a result of the installation of the new FGR system. Estimated potential emissions before and after installation of the new burners are listed in the summary table below. Note that the potential emissions in the table reflect limits on fuel oil usage and annual operating hours found in the permit.

 

Pollutant

Potential Emissions Before FGR Installation (tons/yr)

Potential Emissions After FGR Installation (tons/yr)

Net Change (tons/yr)

Volatile Organic Compounds (VOCs)

5.42

5.42

0 (no change)

Oxides of Nitrogen (NOx)

116.02

71.98

44.04 (reduction)

Sulfur Dioxide (SO2)

0.87

0.87

0 (no change)

Total Particulate Matter (PM Total)

9.68

9.68

0 (no change)

Carbon Monoxide (CO)

37.16

37.16

0 (no change)

Total Hazardous Air Pollutants (HAPs)

1.86

1.86

0 (no change)

Includes both condensable and filterable particulate matter.

The proposed emission limits are as follows:

    1. Emissions from the boiler shall not exceed the following rates [20 DCMR 201]:

Pollutant

Emissions Burning Natural Gas

(lb/hr)

Emissions Burning No. 2 Fuel Oil (lb/hr)

Oxides of Nitrogen (NOx)

15.0

32.5

Carbon Monoxide (CO)

10.0

10.0

Sulfur Dioxide (SO2)

0.15

0.38

Total Particulate Matter [PM Total]

1.25

5.0

Includes both condensable and filterable particulate matter.

b.   Total suspended particulate matter emissions from the boiler shall not be greater than 0.05 pounds per million BTU. [20 DCMR 600.1]

c.   Oxides of nitrogen (NOx) emissions from the boiler shall not exceed:

1.   When burning natural gas:     

i.    0.05 pounds per MMBTU based on a calendar day average, on days when the equipment is powered exclusively by natural gas. [20 DCMR 805.5(e)(2)(B)]; and
ii.   0.2 pounds per MMBTU maximum two (2) hour average, expressed as NO2. .[20 DCMR 804.1 and 20 DCMR Chapter 8, Appendix 8-1];
2.   When burning No. 2 fuel oil:
i.    0.12 pounds per MMBTU based on a calendar day average, on days when the equipment is powered by fuel oil or a combination of fuel oil and natural gas. [20 DCMR 805.5(e)(2)(A)]; and
ii.   0.3 pounds per MMBTU maximum two (2) hour average, expressed as NO2. [20 DCMR 804.1 and 20 DCMR Chapter 8, Appendix 8-1];

d.   Visible emissions shall not, at any time, exhibit opacity more than ten percent (10%) (unaveraged) from the unit except that discharges shall be permitted for two (2) minutes during any startup, cleaning, adjustment of combustion or operational controls, or regeneration of emission control equipment, provided that such discharges shall not exceed the following opacities [20DCMR 606.1(a)(3) and 20 DCMR 606.2]:

1.   When burning exclusively natural gas, twenty percent (20%); and

2.   When burning fuel oil or a combination of fuel oil and natural gas, twenty-seven percent (27%).

e.   NOx and CO emissions from the boiler shall not exceed those achieved with the performance of annual combustion adjustments on the boiler, performed per Conditions III(e) and (f). [20 DCMR 805.5(b) and 20 DCMR 805.9]

f.    An emission into the atmosphere of odorous or other air pollutants from any source in any quantity and of any characteristic, and duration which is, or is likely to be injurious to the public health or welfare, or which interferes with the reasonable enjoyment of life or property is prohibited. [20 DCMR 903.1]

Violation of the requirements of this condition that occur as a result of unavoidable malfunction, despite the conscientious employment of control practices, shall be an affirmative defense for which the owner or operator shall bear the burden of proof. A malfunction shall not be considered unavoidable if the owner or operator could have taken, but did not take, appropriate steps to eliminate the malfunction within a reasonable time, as determined by the Department. [20 DCMR 903.13(b)]
  - Note: This condition is District enforceable only.

g.   Facility-wide emissions of NOx from the Central Heating and Refrigeration Plant shall not exceed 268 tons in any 12-consecutive-month period. [20 DCMR 201 and 20 DCMR 805.2] For purposes of determining compliance with this condition, NOx emissions shall be determined as follows:

      1. For all temporary and permanently-installed boilers and the combined heat and power (CHP) system (also known as Combustion Turbines 1 and 2 and Boiler 5), emissions shall be determined based on the results of monitoring using properly certified Continuous Emissions Monitoring Systems (CEMS) for NOx, except that another method may be specified for units that may be installed after the date of this permit, as authorized by District and federal laws and regulations; and
      1. Emissions from all emergency engines shall be determined based on manufacturer-specified emission factors and assuming the maximum horsepower of the engine for the period of operation during each 12-consecutive-month period, unless other unit-specific factors are developed based on emissions testing, in which case, these factors may be used in lieu of the manufacturer-specified factors, upon approval of the Department.

h.   In addition to the above emission limitations, the Permittee shall comply with all plant-wide emission limits found in Chapter 3 (Title V) Permit No. 032.       

The permit application and supporting documentation, along with the draft permit are available for public inspection at AQD and copies may be made available between the hours of 8:15 A.M. and 4:45 P.M. Monday through Friday. Interested parties wishing to view these documents should provide their names, addresses, telephone numbers and affiliation, if any, to Stephen S. Ours at (202) 535-1747. Copies of the draft permit and related technical support memorandum are also available at https://doee.dc.gov/service/public-notices-hearings.

Interested persons may submit written comments or may request a public hearing on this subject within 30 days of publication of this notice. The written comments must also include the person’s name, telephone number, affiliation, if any, mailing address and a statement outlining the air quality issues in dispute and any facts underscoring those air quality issues. All relevant comments will be considered both in issuing the final permit and submitting the requirements of the aforementioned permit condition as part of the District’s SIP.

 

Comments on the proposed permit or SIP amendment and any request for a public hearing should be addressed to:

 

Stephen S. Ours     
Chief, Permitting Branch - Air Quality Division

 

Department of Energy and Environment

1200 First Street NE, 5th Floor

Washington, DC 20002


[email protected]

 

No comments or hearing requests submitted after January 8, 2024 will be accepted.

 

For more information, please contact Stephen S. Ours at (202) 498-8143.