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Notice of Public Comment Period – Draft Air Quality Permits 7232 and 7233 - American University

Friday, October 5, 2018


Draft Air Quality Permits 7232 and 7233, American University, Construction and operation of two identical 6.0 MMBTU/hr natural gas-fired boilers at the East Campus, Federal Hall, 4400 Massachusetts Avenue NW

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 permits (Nos. 7232 and 7233) to American University to construct and operate two (2) 6.0 MMBtu/hr Aerco BMK 6000 natural gas-fired condensing boilers to be located at the American University East Campus, Federal Hall, 4400 Massachusetts Avenue NW, Washington DC. The contact person for the facility is Mark A. Freedman, Manager, Energy Utilities Operations, at (202) 885-2378.

The following boilers are to be permitted:



Emission Unit ID

Model Number

Natural Gas Rating (MMBTU/hr)

Permit Number

Federal Hall, American University East Campus

4400 Massachusetts Ave NW

Washington DC


Aerco BMK 6000



Federal Hall, American University East Campus

4400 Massachusetts Ave NW

Washington DC


Aerco BMK 6000




The estimated maximum annual emissions from the two 6.0 MMBTU/hr natural gas-fired boilers are expected to be as follows:



Maximum Annual Emissions for Each Boiler


Each Boiler

Both Boilers (Sum)

Total Particulate Matter (PM Total)



Sulfur Dioxide (SO2)



Nitrogen Oxides (NOx)



Volatile Organic Compounds (VOC)



Carbon Monoxide (CO)



The proposed emission limits are as follows:

    1. Each of the boilers (identified as PG-PT-BOILR001and PG-PT-BOILR002) shall not emit pollutants in excess of those specified in the following table [20 DCMR 201]:



Short-Term Limit

(Natural Gas) (lb/hr)

Carbon Monoxide (CO)


Oxides of Nitrogen (NOx)


Total Particulate Matter (PM Total)1


Sulfur Dioxide (SO2)


1PM Total includes both filterable and condensable fractions.

b.   Visible emissions shall not be emitted into the outdoor atmosphere from the boilers, except that discharges not exceeding forty percent (40%) opacity (unaveraged) shall be permitted for two (2) minutes in any sixty (60) minute period and for an aggregate of twelve (12) minutes in any twenty-four hour (24 hr.) period during start-up, cleaning, adjustment of combustion controls, or malfunction of the equipment [20 DCMR 606.1]

  1. Total suspended particulate matter (TSP) emissions from the each of the boilers shall not be greater than 0.11 pounds per million BTU. [20 DCMR 600.1].

d.   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]

e.   NOx and CO emissions shall not exceed those achieved with the performance of annual combustion adjustments on each boiler. To show compliance with this condition, the Permittee shall, each calendar year, perform adjustments of the combustion processes of the boilers with the following characteristics [20 DCMR 805.1(a)(4) and 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;
      1. 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;
      1.  Inspection of the air-to-fuel ratio control system and adjustments necessary to ensure proper calibration and operation as specified by the manufacturer; and
      2. 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 Condition II of this permit.          

The applications to construct and operate the boilers and the draft permits and supporting documents 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 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 permits.

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 November 5, 2018 will be accepted.

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