ddoe

Department of Energy & Environment
 

DC Agency Top Menu

-A +A
Bookmark and Share

Notice of Public Comment Period - Draft Air Quality Permit 7323 - U.S. Department of the Navy - Naval Research Laboratory

Friday, April 22, 2022

PUBLIC NOTICE 

Draft Air Quality Permit 7323, U.S. Department of the Navy, Construction and operation of a combustion turbine-based cogeneration system at the Naval Research Laboratory, Building 149, 4555 Overlook Avenue SW

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 a permit (No. 7323) to United States Department of the Navy, Naval Research Laboratory (NRL) to construct and operate a cogeneration facility. The equipment to be constructed and operated will be located on the NRL property located at 4555 Overlook Avenue SW, Washington, DC. The contact person for the facility is Lionel Vega, at (202) 404-2109 or [email protected]

The project involves installation of a combustion gas turbine (CT) and heat recovery steam generator (HRSG) in the area adjacent to, and south of Building 149.  The natural gas fired combustion turbine has the capacity to produce approximately 4.4 megawatts (MW) of electrical power. The HRSG will produce steam for process use.

The equipment to be constructed and operated pursuant to this permit consists of the following significant components:

  • Combined Heat and Power (CHP) Emission Unit:
  • One (1) Solar Mercury 50-6400R Combustion Gas Turbine (CT) rated at 40.06 MMBTU/hr heat input (LHV) or 43.1 MMBTU/hr heat input (HHV), firing natural gas (NG) only, ISO rate power output of 4,439 kWe. This equipment does not include duct burners or any other supplemental firing system; and
     
  • CHP Ancillary Equipment and Appurtenances:
  • One economizer;
  • Stack; and
  • One (1) 12,628 lbm/hr Rentech Heat Recovery Steam Generator (HRSG).

Emission Estimates

The expected maximum emissions from the equipment to be constructed are summarized below:

Maximum Emissions Estimates from Permitted Equipment1

 

Pollutant

Hourly Emission

(lb/hr)

Potential to Emit

(tons/12 month rolling period)

Total Particulate Matter (PM Total)2,3

0.65

2.9

Oxides of Sulfur (SOx)4

0.15

0.7

Oxides of Nitrogen (NOx)

0.81

3.6

Volatile Organic Compounds (VOC)

0.114

0.5

Carbon Monoxide (CO)

0.99

4.3

1.   The equipment covered consists of one Solar Mercury 50 gas turbine, and one HRSG (the latter of which has no independent emissions).

2.  PM (Total) is the sum of the filterable PM and condensable PM. 

3.  All PM is expected to be smaller than 2.5 microns, so PM (Total) equals PM2.5

4.  The maximum SOx emissions estimate used by the applicant, and reflected in this table, is based on AP-42 emission factors, but is, in reality, dependent upon the sulfur content in the natural gas being burned. Because the permit limit for fuel sulfur is based on an NSPS standard, the effective legal limit is substantially greater at approximately 11.3 tons per 12 month rolling period. However, the value listed in the table is expected to be a more accurate reflection of the worst case actual emissions based on the expected sulfur content of the natural gas fuel supply available in the area.

Emission Limitations for Emission Unit

Proposed emission limits for the combustion gas turbine and heat recovery steam generator are listed below:

A.  The gas combustion turbine shall not emit pollutants in excess of those specified in the following Tables 1 and 2: [20 DCMR 201]

Table 1: Total 12-Month Rolling Emissions Limits from Permitted Equipment

Pollutant

12-Month Rolling Emissions Limit

(tons/12 mo. rolling period)

Total Particulate Matter (PM Total)2,3

2.9

Oxides of Nitrogen (NOx)

3.6

Volatile Organic Compounds (VOC)

0.5

Carbon Monoxide (CO)

4.3

1. The equipment covered consists of one Solar Mercury 50 gas turbine, and one HRSG.

2. PM (Total) is the sum of the filterable PM and condensable PM. 

3. All PM is expected to be smaller than 2.5 microns, so PM (Total) equals PM2.5

Table 2: Maximum Hourly Emissions when Operating Between 50% and 100 % Load

Pollutants

Solar Mercury 50 Gas Turbine (CT) and HRSG (lb/hr)

PM Total

0.65

NOx

0.81

VOC

0.114

CO

0.99

B.  Total suspended particulate emissions (TSP) (i.e. total filterable particulate matter) from the gas combustion turbine shall not exceed 0.07 pound per million BTU. [20 DCMR 600.1]

C.  Sulfur dioxide (SO2) emissions from the gas turbine shall not exceed 0.060 lb SO2/MMBTU heat input. [40 CFR 60.4330]:

D.  NOx emissions from the turbine shall not exceed 5 ppmvd at 15% O2. [40 CFR 60.4320 and 60.4325 and 20 DCMR 201, and 20 DCMR 805.4(a)(3)] Note that this is a streamlined emission rate limit and is more stringent than the limits found in 40 CFR 60, Subpart KKKK and 20 DCMR 805.4(a)(3) for NOx emissions cited above.  Compliance with this condition will ensure compliance with both requirements, including 20 DCMR 805.

E.   Visible emissions shall not be emitted into the outdoor atmosphere from the emission units and control equipment, 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, if any, or malfunction of the equipment [20 DCMR 606.1].

F.   The Permittee shall ensure that any fugitive dust associated with the construction or installation of the equipment covered by this permit is minimized or controlled in accordance with applicable provisions of 20 DCMR 605. 

G.  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] Note: This condition is District enforceable only.

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. Copies of the draft permit and related technical support memorandum are also in the attachments section 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. The written comments must 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 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 May 23, 2022 will be accepted.

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