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Notice Requesting Public Comment on Draft Title V and Chapter 2 Air Quality Operating Permit for Potomac Creek Associates

Friday, July 10, 2020



Notice is hereby given that Potomac Creek Associates, L.L.C. has applied for a 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 continue operation of the following equipment at L’Enfant Plaza, located at L’Enfant Plaza SW, Washington DC 20024:

  • Two (2) 21.106 MMBTU/hr natural gas-fired boilers;
  • Two (2) 13.69 MMBTU/hr dual fuel-fired (natural gas and No. 2 fuel oil) boilers;
  • Two (2) diesel-fired emergency generator sets;
  • Two (2) diesel-fired fire pumps;
  • Seven (7) cooling towers;
  • One (1) 20,000 gallon above ground storage tank for No. 2 fuel oil;
  • Six (6) above ground storage tanks for ultra-low sulfur diesel fuel with capacities ranging from 25 gallons to 750 gallons; and
  • Seven (7) small external combustion units burning natural gas only, each with a rated heat input less than 1 MMBTU/hr.

The contact person for the facility is Kathy Guy, CPM, Senior Vice President, Management Services at (240) 333-7716 or [email protected].

The following is an estimate of overall potential emissions from the equipment to be covered by this permit:



Potential Emissions

Sulfur Dioxide (SO2)


Oxides of Nitrogen (NOx)


Total Particulate Matter (PM Total)


Volatile Organic Compounds (VOCs)


Carbon Monoxide (CO)


Total Hazardous Air Pollutants (HAPs)


For purposes of Title V applicability, the equipment covered  by this permit is being aggregated with that of the Southeast Office Building owned by JBG/L’Enfant Plaza Southeast, L.L.C., but under the common control of JBG Smith, which controls both limited liability companies.

With the emission limitations included in the draft permit, in combination with a small contribution of 0.92 tons per year of nitrogen oxides (NOx) from the Southeast Office Building, the facility has the potential to emit approximately 24.64 tons per year of NOx, just under the District’s major source threshold of 25 tons per year of NOx. Under normal maximum operating conditions for determination of the potential emissions of the facility (i.e. 500 hours per year per emergency generator), the combined emissions of the equipment would have exceeded the major source threshold for NOx. In order to avoid major source status, the facility opted for operating hour restrictions to keep their potential to emit NOx under the major source threshold. The Chapter 3 permitting process is being used in this case to make these limits federally enforceable and enforceable as a practical matter.

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. 016-R2 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 available in the attachments 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 August 10, 2020 will be accepted.

For more information, please contact Stephen Ours at (202) 535-1747 or [email protected].