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Draft Air Quality Permits 7214, 7215, 7216, and 7217 - Georgetown University

Friday, April 5, 2019

PUBLIC NOTICE

Draft Air Quality Permits 7214, 7215, 7216, and 7217, Georgetown University, Construction and operation of a 119.8 MMBTU/hr boiler and installation of low NOx burners and stack modifications on three existing boilers at the Central Utility Plant, 3700 O Street 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 air quality permit Nos. 7214, 7215, 7216, and 7217 to Georgetown University to construct and operate one 119.8 MMBTU/hr boiler (Boiler 4) and install low NOx burners and modify stacks on three existing boilers (Boilers 1, 2, and 3) at the Central Utility Plant located at 3700 O Street NW, Washington DC 20057. The contact person for facility is Bob Sidner, CEM, Senior Air Permitting Manager/Engineer, Eastern Research Group, Inc. (a consultant for Georgetown University), at (703) 375-9775 or [email protected].

Emissions Estimates:

The maximum potential to emit air pollutants from the new Boiler 4, under the fuel usage limitation contained in the draft permit, has been estimated to be as follows:

                                                   

Maximum Annual Emissions

Pollutant

(tons/yr)

Total Particulate Matter (PM Total)

2.7

Sulfur Oxides (SOx)

0.3

Nitrogen Oxides (NOx)

8.0

Volatile Organic Compounds (VOC)

2.1

Carbon Monoxide (CO)

19.6

The maximum potential to emit air pollutants from each of Boilers 1 and 2, under the fuel usage limitation contained in the draft permits, has been estimated to be as follows:

                                                  

Maximum Annual Emissions

Pollutant

(tons/yr)

Total Particulate Matter (PM Total)

2.9

Sulfur Oxides (SOx)

0.3

Nitrogen Oxides (NOx)

8.5

Volatile Organic Compounds (VOC)

2.2

Carbon Monoxide (CO)

20.9

The maximum potential to emit air pollutants from the Boiler 3, under the fuel usage limitation contained in the draft permit, has been estimated to be as follows:

                                                  

Maximum Annual Emissions

Pollutant

(tons/yr)

Particulate Matter (PM Total)

2.7

Sulfur Oxides (SOx)

0.3

Nitrogen Oxides (NOx)

8.1

Volatile Organic Compounds (VOC)

2.1

Carbon Monoxide (CO)

19.8

The overall impact on the potential to emit of the facility related to the project, including installation of Boiler 4 as well as retrofits of low NOx burners on Boilers 1, 2, and 3 are expected to result in the following estimated overall changes in emissions:

                                                  

Change in Emissions

(+ is an increase, - is a decrease)

Pollutant

(tons/yr)

Particulate Matter (PM Total)

-0.9

Sulfur Oxides (SOx)

+0.3

Nitrogen Oxides (NOx)

-96.5

Volatile Organic Compounds (VOC)

-0.2

Carbon Monoxide (CO)

-52.9

Emission Limitations:

The proposed emission limits for the equipment are as follows:

a.   Emissions from Boiler 4 shall not exceed the following emission rates [20 DCMR 201]:

Pollutant

Emissions Burning Natural Gas (lb/hr)

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

Oxides of Nitrogen (NOx)

1.7

11.0

Carbon Monoxide (CO)

4.4

10.2

Volatile Organic Compounds (VOC)

0.5

0.6

Sulfur Dioxide (SO2)

0.1

0.2

Total Particulate Matter [PM(total)]

0.6

2.1

      PM Total includes both filterable and condensable fractions .

b.   Emission from each of Boilers 1 and 2 shall not exceed the following emission rates [20 DCMR 201]:

Pollutant

Emissions Burning Natural Gas (lb/hr)

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

Oxides of Nitrogen (NOx)

1.8

12.3

Carbon Monoxide (CO)

4.7

11.3

Volatile Organic Compounds (VOC)

0.5

0.6

Sulfur Dioxide (SO2)

0.1

0.3

Total Particulate Matter [PM(total)]

0.6

2.3

      PM Total includes both filterable and condensable fractions

c.   Emission from Boiler 3 shall not exceed the following emission rates [20 DCMR 201]:

Pollutant

Emissions Burning Natural Gas (lb/hr)

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

Oxides of Nitrogen (NOx)

1.7

11.7

Carbon Monoxide (CO)

4.5

10.7

Volatile Organic Compounds (VOC)

0.5

0.6

Sulfur Dioxide (SO2)

0.1

0.2

Total Particulate Matter [PM(total)]

0.6

2.2

      PM Total includes both filterable and condensable fractions

d.   NOx emissions (expressed as NO2) from each of Boilers 1, 2, 3, and 4 shall not be greater than the following:

1.   For Boiler Nos. 1, 2, 3, and 4 [20 DCMR 804.1 and 20 DCMR Chapter 8, Appendix 8-1]:

i.    0.2 pound per million BTU (lb/MMBTU) heat input, maximum two-hour average, when natural gas is burned; and

ii.   0.3 lb/MMBTU, maximum two-hour average, when No. 2 fuel oil is burned;

2.   For Boiler Nos. 3 and 4: 0.20 lb/MMBTU on a 30-day average of one-hour averages basis when burning natural gas or No. 2 fuel oil. [40 CFR 60.44b(l)(1)]; and

3.   For Boiler Nos. 1, 2, 3, and 4 [20 DCMR 805.5(c)(2)]:

i.    0.25 lb/MMBTU, based on a calendar day average, when combusting fuel oil or a combination of fuel oil and natural gas; and

ii.   0.20 lb/MMBTU, based on a calendar day average, when combusting natural gas only.

e.   Total suspended particulate matter (TSP) (also known as total filterable PM) emissions shall not exceed  the following:

1.   0.06 lb/MMBTU heat input from each of Boiler Nos. 1, 2, and 3, and 4, as measured by 40 CFR 60, Appendix A, Method 5 and in accordance with 20 DCMR 600.2 and 600.4. This standard applies at all times. [20 DCMR 600.1]; and

2.   0.030 lb/MMBTU heat input from Boiler No. 4, as measured by 40 CFR 60, Appendix A, Method 5. [20 DCMR 1410.1, 40 CFR 60.43b(h)(1), 40 CFR 60.46b(d)(2)(i), 40 CFR 63.11201(a), and 40 CFR 63, Subpart JJJJJJ, Table 1] This standard does not apply during startup or shutdown. [40 CFR 60.46b(a) and 40 CFR 63.11201(d)] Note that this is a streamlined requirement. 40 CFR 60.46b(a) also exempts times of malfunction, but because this is not exempted in 40 CFR 63.11201(d), it is not exempted here, otherwise the standards are identical.

f.    Visible emissions in excess of five percent (5%) opacity shall not be emitted into the outdoor atmosphere from Boilers Nos. 3 or 4, 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 and 20 DCMR 606.3*]

g.   In addition to complying with Condition II(f), the Permittee shall not discharge from Boiler Nos. 3 or 4 any emissions that exhibit greater than 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity. [40 CFR 60.43b(f)] This standard does not apply during periods of startup, shutdown, or malfunction. [40 CFR 60.43b(g)]

h.   Visible emissions whose opacity is in excess of ten percent (10%) (unaveraged), at any time  shall  not be permitted into the outdoor atmosphere from Boiler Nos. 1 and 2; 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 Condition II(h)(i), 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)]

j.    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]

k.   NOx and CO emissions shall not exceed those achieved with the performance of annual combustion adjustments on each boiler, performed per Conditions III(f) and (g). [20 DCMR 805.8(a)]

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 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 May 6, 2019 will be accepted.

 

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