ddoe

Department of Energy & Environment
 

DC Agency Top Menu

-A +A
Bookmark and Share

Notice Requesting Public Comment on Draft Title V and Chapter 2 Air Quality Operating Permit for The George Washington University

Friday, May 15, 2015

PUBLIC NOTICE

Notice is hereby given that The George Washington University has applied for a facility-wide Title V air quality permit pursuant to the requirements of Title 20 of the District of Columbia Municipal Regulations, Chapters 2 and 3 (20 DCMR Chapters 2 and 3) to operate the following emission units and miscellaneous sources of air emissions at the university:

  • Twenty-one (21) large boilers (greater than 5 MMBTU/hr): including five (5) dual fuel boilers permitted to fire natural gas and No. 2 fuel oil, nine (9) dual fuel boilers classified as “gas-fired” and burning No. 2 fuel oil in the event of gas service interruptions; and seven (7) natural gas fired only;
  • One (1) natural gas fired cogeneration system consisting of a 52.9 MMBTU/hr combustion turbine, a heat recovery steam generator, and one (1) 16.8 MMBTU/hr duct burner;
  • Eighty-one (81) natural gas small boilers (less than 5 MMBTU/hr): including five (5) dual fuel boilers operating as “gas-fired” and burning No. 2 fuel oil in the event of gas interruptions.  The other small boilers burn only natural gas;
  • Seventy-seven (77) natural gas hot water heaters;
  • Forty-five (45) emergency generators, including forty (40) diesel and five (5) natural gas generators;
  • Three (3) natural gas fired air handler units;
  • Three (3) natural gas fired humidifiers;
  • Two (2) steamed humidifiers;
  • One (1) diesel fired pump engine;
  • One-hundred five (105) above ground storage tanks;
  • Twelve (12) underground storage tanks;
  • One-hundred twenty-eight (128) laboratory fume hoods;
  • Two (2) solvent storage areas;
  • Six (6) space heater/furnaces;
  • Four (4) natural gas kilns;
  • One-hundred twenty-six (123) natural gas dryers;
  • Thirty-two (32) packaged heating ventilation and cooling units;
  • Natural gas kitchen equipment;
  • Laboratory fume hoods, solvent storage area(s), and painting operations;
  • Woodworking operations;
  • Cooling towers;

The above listed sources of emissions and insignificant activities are located at the George Washington University (GWU) located at 2025 F Street, NW, Washington, DC.  The contact person for the facility is Ms. Alicia Knight, Senior Associate Vice President for Operations, at (202) 994-2371.

The George Washington University (GW) has the potential to operate twenty-four (24) hours per day, seven (7) days per week, fifty-two (52) weeks per year.  In this capacity the facility has the potential to emit (PTE) approximately 473 tons per year (TPY) of nitrogen oxides (NOx), 746 TPY of oxides of sulfur (SOx), and 233 TPY of carbon monoxide (CO). The values for these criteria pollutants exceed the major source threshold in the District of Columbia of 25 TPY of NOx or VOC, and/or 100 TPY of any other criteria pollutant.  Because potential emissions of NOx, SOx, and CO exceed the relevant major source thresholds, pursuant to 20 DCMR 300.1(a), the source is subject to Chapter 3 and must obtain an operating permit in accordance with that regulation and Title V of the federal Clean Air Act.  The facility also has approximate PTEs of total particulate matter of 46.9 TPY and volatile organic compounds (VOCs) of 23.6 TPY, values below the respective major source thresholds for these pollutants.

Description and Emission Information for a Modification to Permitted Equipment

Combined heat and power emission units are part of GW’s cogeneration facility at Ross Hall.  The cogeneration facility was issued a pre-construction Permit No. 6618-C on January 3, 2013. However, since that permit was issued, the permitted duct burner was changed from a NATCOM duct burner to a COEN brand rated at a lower capacity than the NATCOM model.  Consequently, this change resulted in minor differences in potential emissions criteria pollutants.

Specifically, potential emissions of carbon monoxide have increased by 0.1 TPY while potential emissions of total particulate matter decreased by 2.34 TPY, sulfur dioxide decreased by 0.08 TPY, VOC decreased by 0.12 TPY, and NOx decreased by 1.7 TPY.

The PTE of this cogeneration facility as modified is reflected by the emission limits in Table 1 below.

The following represent the emission limits placed upon the cogeneration facility, as revised by this permitting action:

The Permittee shall not exceed the emission limits in the following tables as applicable:

Table 1: Total 12-Month Rolling Emission Limits from Permitted Equipment1

Pollutant

12-Month Rolling Emissions Limit

(tons/12 mo. rolling  period)

Particulate Matter (PM) (Total)2,3

4.96

Oxides of Sulfur (SOx)

1.12

Oxides of Nitrogen (NOx)

21.3

Volatile Organic Compounds VOC)

2.28

Carbon Monoxide (CO)

21.5

1. The equipment covered consists of one Solar Centaur 50 gas turbine and one HRSG/duct burner.

2. PM Total is the sum of the filterable PM and condensable PM.

3. All PM is expected to be smaller than 2.5 microns, so PM (Total) equals PM2.5.  The manufacturer specifications note PM as PM10 and PM2.5 for the gas turbine but PM10 for the duct burner.

Table 2- Maximum Hourly Emissions (lbs/hr) when Operating Between 50% and 100 % Load, Inclusive

Pollutants

Solar Centaur 50 Gas Turbine (CT) and  HRSG/Duct Burner (HDB)

PM Total

1.13

SOx

0.26

NOx

4.87

VOC

0.52

CO

4.91

The proposed emission limits for the separate parts of the cogeneration equipment (one gas turbine and one HRSG/duct burner) are as follows:

a.   Combustion Gas Turbine CT: One (1) Solar Centaur 50 combustion gas turbine (CT) rated at a heat input capacity of 52.9 MMBtu/hr, natural gas (NG).

1.   Emission Limitations:

A.        The gas combustion turbine shall not emit pollutants in excess of those specified in Tables 1 and 2. [20 DCMR 201]   

B.  Total Suspended Particulate (TSP) emissions (i.e. total filterable only) from the gas combustion turbine shall not exceed 0.07 pounds per million Btu. [20 DCMR 600.1]

C.  Sulfur dioxide (SO2) emissions from the gas turbine shall not exceed 0.060 lb SO2/MMBtu heat input for each calendar month when natural gas is burned. [40 CFR 60.4330]:

D.  NOx emissions from the turbine without supplemental firing shall not exceed 15 ppmvd at 15% O2. [40 CFR 60.4320 and 60.4325 and 20 DCMR 201]  Note that this is a streamlined emission rate limit, and is more stringent than the limits found in 40 CFR 60, Subpart KKKK for NOx emissions cited above.  Compliance with this condition will ensure compliance with both requirements.

E.   NOx emissions from the turbine when fired with supplemental duct burner firing shall not exceed 18 ppmvd at 15% O2.  [40 CFR 60.4320 and 60.4325 and 20 DCMR 201]  Note that this is a streamlined emission rate limit, and is more stringent than the limits found in 40 CFR 60, Subpart KKKK for NOx emissions cited above.  Compliance with this condition will ensure compliance with both requirements.

b.   HRSG/Duct Burner HDB: One (1) 16.8MMBtu/hr heat input (natural gas) Rentech Boiler Services Heat Recovery Steam Generator/Duct Burner (HDB).

1.   Emission Limitations:

A.  The HRSG/Duct Burner (HDB) shall not emit pollutants in excess of those specified in the tables 1 and 2 above.

B.  The HDB shall not emit pollutants in excess of 0.1 lb NOx/MMBtu. [20 DCMR 201]

C.  Total Suspended Particulate (TSP) emissions (i.e. total filterable only) from the HDB shall not exceed 0.091 pounds per million Btu. [20 DCMR 600.1]

D.  Sulfur dioxide emissions shall not exceed 0.060 lb SO2/MMBtu heat input. [40 CFR 60.4305 and 40 CFR 60.4330(a)(2)]

E.   NOx emissions from the Combustion Turbine/HDB (CT/HDB) train exhaust (while supplemental firing with duct burner) shall not exceed 18 ppmvd at 15% O2 as required by Condition (a)(1)(E). [20 DCMR 201 and 40 CFR 60.4320] Note that this is a streamlined permit condition and is more stringent than the requirements of 40 CFR 60.4320, therefore compliance with the limit established pursuant to 20 DCMR 201 will ensure compliance with 40 CFR 60.4320.

F.   NOx emissions from CT/HDB train shall not exceed 4.87 lb/hr (the cumulative lb/hr emission rate contained in Condition Table 2 above) as measured at the HRSG exhaust. [20 DCMR 201]

The District Department of the Environment (DDOE) has reviewed the permit application and related documents and has made a preliminary determination that the applicant meets all applicable air quality requirements promulgated by the U.S. Environmental Protection Agency (EPA) and the District.  Therefore, draft permit #020-R2 has been prepared.

The application, the draft permit, and all other materials submitted by the applicant [except those entitled to confidential treatment under 20 DCMR 301.1(c)] considered in making this preliminary determination are available for public review during normal business hours at the offices of the District Department of the Environment, 1200 First Street NE, 5th Floor, Washington DC 20002.

A public hearing on this permitting action will not be held unless DDOE 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.  Hearing requests or comments should be directed to Stephen S. Ours, DDOE Air Quality Division, 1200 First Street NE, 5th Floor, Washington DC 20002.  Questions about this permitting action should be directed to John C. Nwoke at (202) 724-7778 or [email protected].  Comments or hearing requests submitted after June 15, 2015 will not be accepted.