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Notice of Public Comment Period - Draft Air Quality Permits 7330, 7331, and 7332, Gallaudet University

Friday, April 21, 2023

Draft Air Quality Permits 7330, 7331, and 7332, Gallaudet University
Construction and operation of three natural gas-fired internal combustion engine based combined heat and power units

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 permits (Nos. 7330, 7331 and 7332) to Gallaudet University to construct and operate three (3) 1,500 kWe combined heat and power (CHP) generator sets, each powered by a 2,095 hp natural gas-fired internal combustion engine, at the Central Utility Building of Gallaudet University, 800 Florida Avenue NE, Washington, DC.  The contact person for the facility is David Good, Director, Energy, Utilities, and Sustainability, at (202) 651-5758.

The following CHP units are to be permitted:

Equipment Location Address

Equipment Name

System Model

Engine Model

Generator Output (kWe)

Permit Number

Central Utility Building
800 Florida Ave. NE Washington, DC

CHP # -1

SMS1500G

GS16R2-PTK

1,500

7330

Central Utility Building
800 Florida Ave. NE Washington, DC

CHP # -2

SMS1500G

GS16R2-PTK

1,500

7331

Central Utility Building
800 Florida Ave. NE Washington, DC

CHP # -3

SMS1500G

GS16R2-PTK

1,500

7332

The proposed emission limits are as follows:

a.   Emissions from each engine, before the application of selective catalytic reduction (SCR), shall not exceed those in the following table [40 CFR 60.4233(e) and Subpart JJJJ, Table 1]:

Pollutant Emission Limits1

(g/HP-hr)

ppmvd at 15% O2

NOx

CO

VOC2

NOx

CO

VOC2

1.0

2.0

0.7

82

270

60

1The Permittee may choose to comply with the emission standards in this table in units of either g/HP-hr or ppmvd at 15 percent O2.

2For purposes of this requirement, when calculating emissions of VOCs, emissions of formaldehyde should not be included.

b.   After application of SCR, required per Condition III(c), emissions from each CHP unit shall not exceed those in the following table [20 DCMR 201 and 20 DCMR 805.7(a)(2)]:

Pollutant Emission Limits

(g/HP-hr)

ppmvd at 15% O2

NOx3

CO

VOC

(as NM-NEHC)

Formaldehyde

(HCHO)

NH3 Slip

0.07

0.2

0.125

0.072

10

3This is a streamlined emission limit. The requirements of 20 DCMR 805.7(a)(2) are less stringent than the manufacturer’s guarantee requested by the applicant and included pursuant to 20 DCMR 201. As such, compliance with this limit will ensure compliance with both regulations.

c.   Visible emissions shall not be emitted into the outdoor atmosphere from the generators, 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]

d.   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]

The estimated maximum emissions from the equipment are as follows:

Pollutant

Potential to Emit from Each Unit (tons/yr)

Total Potential to Emit from All Three Units Combined (tons/year)

PM (Total)

0.58

1.74

SOx

0.035

0.11

NOx

1.42

4.25

VOC

2.53

7.59

CO

4.05

12.15

The applications to construct and operate the CHP units 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. Copies of the draft permit and technical support memorandum are also available in the attachments sectuion below.

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 permits.
 

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 22, 2023 will be accepted.

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