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Notice of Second Public Comment Period - Draft Air Quality Permits 7263-7268 - MedStar Washington Hospital Center

Friday, September 4, 2020

PUBLIC NOTICE

Draft Air Quality Permits 7263 through 7268, MedStar Washington Hospital Center, Modification and operation of four 52.0 MMBTU/hr and two 54.0 MMBTU/hr dual fuel-fired boilers at 110 Irving 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 Permit Nos. 7263 through 7268 to MedStar Washington Hospital Center, to modify and operate six (6) Babcock & Wilcox dual-fuel boilers (natural gas/No.2 fuel oil) hot water boilers (listed below), located  at Washington Hospital Center, 110 Irving Street NW, Washington DC. The modification consists of installation of new low oxides of nitrogen (NOx) burners and flue gas recirculation equipment. The contact person for the facility is Odell Hall, Director, Engineering Department, Medstar Washington Hospital Center, phone number: (202) 877-6810.

This is a revision to a previous public notice issued on March 20, 2020.

The following boilers are to be permitted:

Equipment Location

Boiler Name

Model

Natural Gas Rating (MMBTU/hr)

No. 2 Fuel Oil Rating (Gallon/hr)

Permit Number

Lower Plant

Boiler #1

Model  FF15-36

52.0

52.0

7263

Lower Plant

Boiler #2

Model  FF15-36

52.0

52.0

7264

Lower Plant

Boiler #3

Model  FF15-36

52.0

52.0

7265

Lower Plant

Boiler #4

Model  FF15-36

52.0

52.0

7266

Upper Plant

Boiler #5

Model DL-60

54.0

54.0

7267

Upper Plant

Boiler #6

Model DL-60

54.0

54.0

7268

Emissions:

The project will result in changes to the potential emissions from the equipment. The following table shows the estimated potential to emit of equipment, as modified, compared to the historic potential emissions. Potential to emit from the boilers take into account limits placed on the amount of No. 2 fuel oil permitted for use in the boilers.

 

Effect of Modifications on Facility-Wide Potential To Emit (PTE)

(Tons per Year)

Pollutant

Total Old PTE of All Boilers

New PTE of Each Boiler #1 - #4

New PTE of Each Boiler #4 and #5

Total New PTE of All Boilers

Difference

Total Particulate Matter (PM Total)

35.29

2.31

2.40

14.04

-21.25

Oxides of Sulfur (SOx)

35.57

0.42

0.43

2.54

-33.03

Oxides of Nitrogen (NOx)

144.50

10.20

10.50

61.80

-82.70

Carbon Monoxide (CO)

6.92

8.43

8.75

51.22

44.3

Volatile Organic Compounds (VOC)

8.07

1.14

1.18

6.92

-1.15

The change in SOx potential to emit relates to changes in regulatory standards for fuel sulfur content, not the project being permitted.

A negative number indicates a decrease in potential emissions as a result of the project, while a positive number indicates an increase in potential emissions.

The facility has legacy oil in its tanks. These estimates are based on the highest sulfur content oil in the tank per testing in 2018. As that oil is used and replaced by oil meeting the current 15 ppm sulfur by weight standard, the potential to emit SOx will decrease.

The proposed emission limits are as follows:

    1. Each of the boilers shall not emit pollutants in excess of those specified in the following tables [20 DCMR 201]:

Emission Limits for Boilers #1 through #4

Pollutant

 

Short-Term Limit

(Natural Gas) (lb/hr)

Short-Term Limit

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

Carbon Monoxide (CO)

1.92

1.87

Oxides of Nitrogen (NOx)

1.89

7.43

Total Particulate Matter (PM Total)1

0.47

1.25

Sulfur Dioxide (SO2)

0.03

1.24

1PM Total includes both filterable and condensable fractions.

Emission Limits for Boilers #5 through #6

Pollutant

 

Short-Term Limit

(Natural Gas) (lb/hr)

Short-Term Limit

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

Carbon Monoxide (CO)

2.00

1.94

Oxides of Nitrogen (NOx)

1.97

7.71

Total Particulate Matter (PM Total)1

0.49

1.30

Sulfur Dioxide (SO2)

0.03

1.28

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. In addition to the requirements of Condition (b), the boilers shall not emit any gases into the atmosphere of gases that exhibit greater than 20 percent opacity (6-minute average), except for one-minute period per hour of not more than 27 percent opacity. This standard applies at all times except during periods of startup, shutdown, or malfunction. [20 DCMR 205 and 40 CFR 60.43c(c) and (d)]
     
  2. Total suspended particulate matter (TSP) emissions from the each of the boilers shall not be greater than 0.07 pounds per million BTU. [20 DCMR 600.1].
     
  3. NOx emissions from each boiler shall not exceed the following [20 DCMR 201 and 20 DCMR 805.5(b)]:

1.   30 ppm by volume, dry basis, corrected to 3% oxygen when firing natural gas; and

2.   112 ppm by volume, dry basis, corrected to 3% oxygen when firing No. 2 fuel oil.

Note that this No. 2 fuel oil standard is a streamlined requirement. This standard is based on the permit application and established pursuant to 20 DCMR 201 and is more stringent than the 0.30 lb/MMBTU standard in 20 DCMR 805.5(b) and which is only applicable on a calendar day average basis when operating exclusively on No. 2 fuel oil.

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]

g.   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 805.8(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 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 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 October 5, 2020 will be accepted.

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