Notice of Public Comment Period - Draft Air Quality Permit 7338-A1, Office of the Chief Administrative Officer

PUBLIC NOTICE

Draft Air Quality Permit 7338-A1, Office of the Chief Administrative Officer (CAO), Operation of an existing non-automotive spray paint booth and construction and operation of a carbon adsorption system for emission control at the Rayburn House Office Building, U.S. House of Representatives, Washington DC

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, 5^th Floor, Washington DC, is proposing to issue an air quality permit (No. 7338-A1) to the Office of Chief Administrative Officer (CAO), a support agency serving the U.S. House of Representatives, to operate an existing modified cross draft non-automotive paint spray booth (SB-1) that uses two high-volume low pressure (HVLP) Aircoat spray guns. Additionally, the proposed permit would authorize the installation and operation of a carbon adsorption system (CAS-1), designed to control volatile organic compound (VOC) emissions, hazardous air pollutant (HAP) emissions, and odors from SB-1. CAS-1 is a PureAir AC-X extruded activated carbon/filter compact module. The activated carbon is encased in a 4 mm diameter cylinder and is estimated to be capable of controlling volatile organic compound (VOC) emissions at 90% efficiency or greater.  The equipment will be in the new Chief Administrative Officer Finishing Shop at the Rayburn House Office Building of the U.S. House of Representatives, Washington DC 20515. The contact person for the facility is Melissa Space, Director of Safety and Personnel Security at [email protected] or by telephone (202) 226-408.

Emissions Estimate:

CAO has estimated that the potential to emit VOCs and HAPs from the non- automotive paint spray booth will not exceed 2.7 tons per year without consideration of CAS-1. Use of CAS-1 is expected to reduce the potential to emit to 0.9 tons per year, but no guarantee of performance was provided by the manufacturer of CAS-1, so, since the installation is voluntary, and primarily focused on odor control, the applicant has opted to not take credit for any such reductions in the permit evaluation process.

Emissions Limits:

The proposed emission limits for the equipment are as follows:

1. Except for emissions resulting from operations subject to Conditions (d), (e), and 20 DCMR 743 through 749 (adhesives and sealants requirements), the Permittee shall not discharge into the atmosphere more than fifteen (15) pounds of volatile organic compound (VOC) emissions in any one (1) day, nor more than three pounds (3 lb.) in any one (1) hour, from all operations that occur in the equipment covered by this permit and any other combination of articles, machines, units, equipment, or other contrivances at a facility, not covered by a section of 20 DCMR Chapter 7 other than Section 700, unless the uncontrolled VOC emissions are reduced by at least ninety percent (90%) overall capture and control efficiency. [20 DCMR 700.1 and 700.2]

2. 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 occurs because 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 DMR 903.13(b)]
Note that this condition is District-enforceable only.

3. Visible emissions shall not be emitted into the outdoor atmosphere from the paint spray booth. [20 DCMR 102, 20 DCMR 201, and 20 DMCR 606]

4. The Permittee shall not discharge into the atmosphere more than forty pounds (40 lb.) of non-photochemically reactive solvents in any one (1) day, nor more than eight pounds (8 lb.) in any one (1) hour, from any article, machine, equipment, or other contrivance, unless the uncontrolled organic emissions are reduced by at least eighty-five percent (85%). [20 DCMR 708.2]

5. Emissions of VOCs from the use of any cleaning solvent, except those listed in Conditions II(e)(1) through (5) below (which are included in the accounting for compliance with Condition II(a)) shall be maintained below fifteen (15) pounds in any one (1) day from all such sources at the facility. [20 DCMR 201 and 20 DCMR 770.1]

1. Emissions from cleaning and surface preparation operations subject to Condition III(b);
2. Emissions from products used to strip cured inks, coatings, and adhesives;
3. Emissions from cleaning products used for janitorial purposes, including graffiti remover products;
4. Emissions from products used to clean resin, coating, ink, and adhesive mixing, molding, and application equipment; and
5. Emissions from cleaning and surface preparation operations related to application of coatings subject to regulation under 20 DCMR 773 to 778 (AIM) to the extent the coatings are used as architectural and industrial maintenance coatings.

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 available in the attachments section below.

A public hearing on this permitting action will not be held unless DOEE has received a request for such a hearing within 30 days of the publication of this notice. Interested parties may also submit written comments on the permitting action. The written comments must 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 in issuing the final permit.

Comments on the draft permit 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, 5^th Floor
Washington DC 20002

[email protected]

No comments or hearing requests submitted after February 12, 2024 will be accepted.

For more information, please contact Stephen S. Ours at (202) 498-8143 or [email protected].