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Proposed Air Quality Permit 6618-C-R1 - The George Washington University

Friday, March 4, 2016

PUBLIC NOTICE

Proposed Air Quality Permit 6618-C-R1, The George Washington University, Construction and Operation of a cogeneration facility at Ross Hall, Foggy Bottom Campus, 2300 I Street NW

Notice is hereby given that, pursuant to 40 C.F.R. Part 51.161, D.C. Official Code §2-505, and 20 DCMR §210, the Air Quality Division (AQD) of the Department of Energy and Environment (DOEE), located at 1200 First Street NE, Washington, DC, intends to issue a permit (#6618-C-R1) to George Washington University (GWU) to construct a cogeneration facility.  This is a renewal of a permit issued in 2013 to allow continued construction of the facility and subsequent operation.  The facility consists of combined heat and power emission units and ancillary support equipment to be located in the Central Utility Plant within Ross Hall, Foggy Bottom Campus, 2300 I Street NW, Washington, DC. The contact person for the facility is Doug Spengel, Energy and Environmental Manager, Facilities Services, phone number: 202-994-6067.

The project involves installation of a combustion gas turbine (CT) and heat recovery steam generator (HRSG)/Duct Burner in the Ross Hall utility plant.  The natural gas fired combustion turbine has the capacity to produce 4.6 megawatts (MW) of electrical power.  The HRSG/Duct Burner which is also natural gas fired, will produce steam for process use and additional power supply via an existing steam turbine.  The HRSG Duct Burner has a rated capacity of 15.2  million Btu/hr, lower heating value (LHV) basis.

The proposed facility will use natural gas to operate a highly efficient cogeneration heat and power system, thereby reducing GWU’s carbon footprint.

The facility’s components are described below:

  • Combined Heat and Power (CHP) Emission Units:
  • One (1) Solar Centaur 50-T6200S Combustion Gas Turbine (CT) rated at 52.9 MMBtu/hr heat input firing natural gas (NG) only; and
  • One (1) Cleaver Brooks Slant Series S4-2816 Heat Recovery Steam Generator (HRSG) equipped with supplemental firing by COEN Duct Burner rated at 15.2 MMBtu/hr heat input on a net lower heating value (LHV) basis (16.8 MMBTU/hr higher heating value (HHV) basis), firing NG;
  • CHP Ancillary Equipment and Appurtenances:
  • One (1) 4,600 kW Centaur 50 Gas Turbine Generator;
  • One (1) 24,500 lb/hr Water Tube Steam Boiler for the HRSG;
  • One (1)2,974 lbm/hr Deaerator;
  • One (1) Water Treatment System;
  • One (1) Heat Exchanger for Condensate Return; and
  • One (1) Existing Steam – Receiving Turbine Generator.

Emission Limitations for Emission Units

Proposed emission limits for the combustion gas turbine and heat recovery steam generator/duct burner are listed below:

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

5.0

Oxides of Sulfur (SOx)

1.1

Oxides of Nitrogen (NOx)

21.3

Volatile Organic Compounds (VOC)

2.3

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

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)

1.1

SOx

0.3

NOx

4.9

VOC

0.5

CO

4.9

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.   Particulate emissions (total filterable only) from the gas combustion turbine shall not exceed 0.069 pound 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) 15.2MMBtu/hr heat input (NG) Cleaver Brooks Heat Recovery Steam Generator/Duct Burner (HDB).

1.   Emission Limitations:

A.  The HRSG/Duct Burner (HDB), shall not emit pollutants in excess of 0.1 lb NOx/MMBtu and those in Condition III, Table 2. [20 DCMR 201]

B.   Particulate emissions (total filterable only) from the HDB shall not exceed 0.087 pounds per million Btu [20 DCMR 600.1]

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

D.  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 III(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.

E.   NOx emissions from CT/HDB train shall not exceed 5.20 lb/hr (the cumulative lb/hr emission rate contained in Condition III, Table 2 of this permit) as measured at the HRSG exhaust. [20 DCMR 201]

The application to construct and operate these emission units and the draft permits are available for public inspection at AQD and copies may be made 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.

Interested persons may submit written comments, a written request for a public hearing, or both, on the draft permit action within thirty (30) days of publication of this notice. The written comments or a written request for a public hearing 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 or outcome from a public hearing will be considered in issuing the final permit. 

Comments or a 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

No written comments postmarked after April 4, 2016 will be accepted.

For more information, please contact Stephen S. Ours at (202) 535-1747.