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Notice Requesting Public Comment on Draft Title V and Chapter 2 Air Quality Operating Permit for JBG/Federal Center

Friday, December 14, 2018

PUBLIC NOTICE
Notice Requesting Public Comment on Draft Title V and Chapter 2 Air Quality Operating Permit for JBG/Federal Center , L.L.C.

Notice is hereby given that the JBG/Federal Center, L.L.C. 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 United States Department of Transportation (USDOT) Headquarters facility located at 1200 New Jersey Avenue SE Washington, DC 20590:

  • One (1) Caterpillar diesel-fired emergency generator set, rated at 1,500 kW (owned by JBG);
  • One (1) Caterpillar diesel-fired emergency generator set, rated at 1,250 kW (owned by JBG);
  • Two (2) Caterpillar diesel-fired emergency generator sets, rated at 1,250 kW (owned by USDOT, operated by JBG);
  • Four (4) 10.5 MMBTU/hr dual fuel natural gas and No. 2 fuel oil-fired boilers (owned by JBG);
  • One 10,000 gallon above ground storage tank for diesel fuel; and
  • Four small water heaters, two make up air units, and various kitchen burners, all fired by natural gas and with heat input ratings less than 5 MMBTU/hr and considered insignificant activities for purposes of this permitting action.

The contact person for the facility is Ms. Lesley Morrison, Senior Property Manager, at (202) 863-4460 or [email protected].

The following is an estimate of overall potential emissions from the facility:

 

FACILITY-WIDE EMISSIONS SUMMARY [TONS PER YEAR]

Pollutants

Potential Emissions

Sulfur Dioxide (SO2)

0.71

Oxides of Nitrogen (NOx)

22.53

Total Particulate Matter (PM Total)

0.90

Volatile Organic Compounds (VOCs)

1.14

Carbon Monoxide (CO)

9.25

Total Hazardous Air Pollutants (HAPs)

0.19

JBG/Federal Center, L.L.C has the PTE 22.53 tons per year (TPY) of NOx. This value does not exceed the major source threshold in the District of Columbia of 25 TPY of NOx. However, the facility is required to obtain a Title V Operating permit as conditions of the Chapter 2 operating permits previously issued. 

Under normal maximum operating condition assumptions for PTE determinations (i.e., 500 hours per year per emergency generator and 8,760 hours per year of operation on the highest emitting fuel for the boilers), the combined emissions of the generators and the boilers would have exceeded the major source thresholds, and thus trigger an NNSR procedure during the Chapter 2 permit review process. In order to avert this possibility, the facility opted for operating hour restrictions (maximum 800 hours per year of operations for all four generators in aggregate and a total of 17,520 hours per year for all four boilers in aggregate, only 800 of which may be on the higher-emitting No. 2 fuel oil/diesel fuel) to keep their potential to emit NOx under the NNSR trigger source threshold. Since the District has no synthetic minor permitting program at this time, the Air Quality Division (“AQD”) of the Department of Energy and Environment (“DOEE” or “the Department”), as a matter of policy, uses the Title V Operating Permit program as a vehicle for establishing federally enforceable limits limiting the facility’s operations so as to not trigger NNSR and avoid the need to acquire emission offset and installation of lowest achievable emission rate (“LAER”) equipment.

DOEE 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 No. 046 has been prepared.

The application, the draft permit and associated Fact Sheet and Statement of Basis, 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 Department of Energy and Environment, 1200 First Street NE, 5th Floor, Washington DC 20002. Copies of the draft permit and related fact sheet are attached 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. 

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, 5th Floor

Washington, DC 20002


[email protected]


No comments or hearing requests submitted after January 14, 2019 will be accepted.


For more information, please contact Olivia Achuko at (202) 535-2997 or [email protected].