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Proposed Air Quality Permit 7161 - U.S. General Services Administration

Friday, July 14, 2017


Proposed Air Quality Permit 7161, U.S. General Services Administration (GSA), Modification and operation of an existing 250 MMBTU/hr dual fuel-fired boiler at the Central Heating and Refrigeration Plant (CHRP), 325 13th 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, 5th Floor, Washington, DC, intends to issue Permit No. 7161 to the U.S. General Services Administration (GSA) to replace antiquated burners in Boiler No. 6 (250 million BTU/hr rated heat input) with like-kind ZEECO-manufactured dual-fuel low-NOx burners 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.

Emissions Estimate:


Emissions from the boiler are expected to decrease as a result of the installation of the new burners. Estimated potential emissions before and after installation of the new burners are listed in the summary table below.



Potential Emissions Before New Burner Installation (tons/yr)

Potential Emissions After New Burner Installation (tons/yr)

Net Change (tons/yr)

Volatile Organic Compounds (VOCs)



0 (no change)

Oxides of Nitrogen (NOx)



152.07 (reduction)

Sulfur Dioxide (SO2)



0 (no change)

Particulate Matter less than 10 microns in aerodynamic diameter (PM10)



50.58 (reduction)

Carbon Monoxide (CO)



45.2 (reduction)

Total Hazardous Air Pollutants (HAPs)



0 (no change)

The proposed emission limits are as follows:

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


Emissions Burning Natural Gas


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

Oxides of Nitrogen (NOx)



Carbon Monoxide (CO)



Sulfur Dioxide (SO2)



Total Particulate Matter [PM Total]*



* 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. 0.20 pounds per MMBTU based on a calendar day average. [20 DCMR 805.5(c)(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.    0.25 pounds per MMBTU based on a calendar day average. [20 DCMR 805.5]; 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 whose opacity is in excess of ten percent (10%) (unaveraged), at any time shall not be permitted into the outdoor atmosphere.  The visible emissions standard shall apply at all times, except: [20 DCMR 606.2]

1.   Opacity not in excess of forty percent (40%) (unaveraged) shall be permitted for two (2) minutes in any sixty (60) minutes  period and for an aggregate of twelve (12) minutes in any twenty-four (24) hours period other than during start-up of the equipment. [20 DCMR 606.2(a)]

2.   During start-up of equipment, opacity not in excess of forty percent (40) (averaged over six (6) minutes) shall be permitted for an aggregate of five (5) times per start-up; and [20 DCMR 606.2(b)]

3.   In addition to the emissions permitted under § 606.2(a), during shutdown of equipment, opacity not in excess of fifteen percent (15%) (unaveraged) shall be allowed and in addition, opacity not in excess of thirty percent (30)(averaged over three (3) minutes) shall be permitted for an aggregate of three (3) times per shutdown. [20 DCMR 606.2(c)]

Note that 20 DCMR 606 is subject to an EPA-issued call for a State Implementation Plan (SIP) revision (known as a “SIP call”) requiring the District to revise 20 DCMR 606. See “State Implementation Plans: Response to Petition for Rulemaking; Restatement and Update of EPA’s SSM Policy Applicable to SIPs; Findings of Substantial Inadequacy; and SIP Calls To Amend Provisions Applying to Excess Emissions During Periods of Startup, Shutdown and Malfunction”, 80 Fed. Reg. 33840 (June 12, 2015). It is likely that this federal action will result in changes to the requirements of 20 DCMR 606.  Any such changes, once finalized in the DCMR, will supersede the language of Condition II(d) as stated above.

e.   NOx and CO emissions shall not exceed those achieved with the performance of annual combustion adjustments (tune-ups) on the boiler. Such tune-ups shall be performed while burning the type of fuel that provided the majority of the heat input to the boiler over the 12 months prior to the combustion adjustment. To show compliance with this condition, the Permittee shall, each calendar year, perform adjustments of the combustion processes of the boiler with the following characteristics [20 DCMR 805.8(a) and (b)]:

1.   Inspection, adjustment, cleaning or replacement of fuel burning equipment, including the burners and moving parts necessary for proper operation as specified by the manufacturer;

2.   Inspection of the flame pattern or characteristics and adjustments necessary to minimize total emissions of NOx and, to the extent practicable, minimize emissions of CO;

3.   Inspection of the air-to-fuel ratio control system and adjustments necessary to ensure proper calibration and operation as specified by the manufacturer; and

4.   Adjustments shall be made such that the maximum emission rate for any contaminant does not exceed the maximum allowable emission rate as set forth in this section.

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] Note: This condition is District enforceable only.

g.   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.

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 in issuing the final permit.

Comments on the proposed 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, 5th Floor

Washington, DC 20002

[email protected]

No comments or hearing requests submitted after August 14, 2017 will be accepted.

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