Notice Requesting Public Comment on Draft Air Quality Construction and Operation Permits for Schuster Concrete Ready Mix

PUBLIC NOTICE
Notice Requesting Public Comment on Draft Air Quality Construction and Operation Permits for Schuster Concrete Ready Mix LLC – 2662 Woodley Road NW SE Site

Notice is hereby given that, pursuant to 20 DCMR § 210, the Air Quality Division (AQD) of the Department of Energy and Environment (DDOE), located at 1200 First Street NE, 5^th Floor, Washington DC, intends to issue permit Nos. 7356, 7357, and 7358 to Schuster Concrete Ready Mix LLC to operate one (1) concrete batch plant with associated 2.1 MMBTU/hr natural gas-fired boiler, one (1) non-emergency engine and one (1) emergency generator set, powered by a diesel-fired engine, to be located at 2662 Woodley Road NW, Washington DC.

Units to be Permitted

Emission Unit ID	Unit Description	Location	Assigned Chapter 2 Permit Number
Plant #1	CEMCO 150 Truck Mix Concrete Plant	2662 Woodley Road NW Washington DC	7356
Plant Engine	One factory mounted (CEMCO) 84 hp John Deere model 4045D diesel engine	2662 Woodley Road NW Washington DC	7357
Emergency Generator #1	One MQ Power WhisperWattTM, Model DCA70SSJU, 40 kWe standby generator set powered by a John Deere 4045TF 99 hp Diesel Engine (Model year 2004)	2662 Woodley Road NW Washington DC	7358

The contact person for the facility is Sherri Palmer at (443) 738-9921 or [email protected].

The applicant has requested that enforceable limitations on the operation of the portable concrete plant be established in the permit pursuant to 20 DCMR §§ 200.7 and 201. Specifically, the applicant has requested an operating hour limit for the CEMCO 150 plant and its associated onboard engine (Plant Gen #1) at the site of 3,120 hours per 12-consecutive-month rolling period. Limits on the concrete production rate of 100,000 cubic yards in any 12-consecutive-month period have also been requested for the plant.

Factoring in these operational limits, the following is an estimate of the overall potential emissions from the facility:

FACILITY-WIDE EMISSIONS SUMMARY [TONS PER YEAR]
Pollutants	Potential Emissions with Limits
Sulfur Dioxide (SO2)	0.32
Oxides of Nitrogen (NOx)	4.96
Fine Particulate Matter (PM Total)	1.78
Volatile Organic Compounds (VOCs)	0.42
Carbon Monoxide (CO)	1.08

With the operational limitations included in the draft permit, the Schuster Concrete Ready Mix LLC facility has the potential to emit approximately 4.89 tons per year of oxides of nitrogen (NOx), which is below the District’s major source threshold of 25 tons per year of NOx. Similarly, all other pollutants’ potential emissions are below their respective major source thresholds. As such, the facility is properly classified as a minor source and is not subject to 20 DCMR § 300.1.

Emission Limits:

The following units are being permitted through this permitting action. After each table of units, the proposed emission limits are specified.

Portable Concrete Mixing Plant: One (1) portable temporary portable concrete plant with an associated boiler with a heat input rating of 2.1 MMBTU per hour:

Emission Unit ID	Equipment Location	Concrete Plant Model	Production Rate (cubic yd/hr)	Permit No.
Plant #1	2662 Woodley Road NW Washington DC	CEMCO 150	150	7356

Emissions:

The maximum estimated emissions from the concrete mixing plant with its associated 2.1 MMBTU/hr boiler are expected to be as follows:

	Maximum Annual Emissions
Pollutant	(tons/yr)
Particulate Matter (PM) (Total)	1.43
Sulfur Oxides (SOx)	<0.01
Nitrogen Oxides (NOx)	0.13
Volatile Organic Compounds (VOC)	0.04
Carbon Monoxide (CO)	0.04

Emissions Limitations:

a.   Emissions of dust shall be minimized in accordance with the requirements of 20 DCMR 605 and the “Operational Limitations” of this permit.

2. The emission of fugitive dust from any material handling, screening, crushing, grinding, conveying, mixing, or other industrial-type operation or process is prohibited. [20 DCMR 605.2]
3. The discharge of total suspended particulate matter (TSP) into the atmosphere from any process shall not exceed three hundredths (0.03) grains per dry standard cubic foot of the exhaust. [20 DCMR 603.1]
4. The discharge of TSP from the portable concrete plant shall not exceed 40 pounds per hour. [20 DCMR 603.1 and Appendix 6-1]
5. TSP emission from the No. 2 fuel-fired boiler shall not exceed 0.13 pound per million BTU of heat input. [20 DCMR 600.19(a)]
6. Visible emissions shall not be emitted from the equipment covered by this permit except that discharges shall be permitted for two (2) minutes during any startup, cleaning, adjustment of combustion or operational controls, or regeneration of emissions control equipment; provided, that such discharges shall not exceed the following opacities (unaveraged) for each of the following stationary sources [20 DCMR 606.1 and 606.2];

1.   Fuel-burning equipment burning fuel oil (the 2.1 MMBTU/hr No. 2 fuel oil-fired boiler), twenty percent (27%); and

2.   All other stationary sources covered by this permit, twenty-seven percent (27%).

7. 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]

Violation of the requirements of this condition that occur as a result of unavoidable malfunction, despite the conscientious employment of control practices, shall be an affirmative defense for which the owner or operator shall bear the burden of proof. A malfunction shall not be considered unavoidable if the owner or operator could have taken, but did not take, appropriate steps to eliminate the malfunction within a reasonable time, as determined by the Department. [20 DCMR 903.13(b)]

Non-Emergency Compression Ignition Internal Combustion Engine (CI-ICE) subject to National Emissions Standards for Hazardous Air Pollutants (NESHAP): One (1) non-emergency diesel-fired engine subject to NESHAP (40 CFR 63) Subpart ZZZZ as described in the following table:

Emission Unit ID	Emission Unit Description	Permit No.
Plant Engine	One factory mounted (CEMCO) 84 hp John Deere model 4045D diesel engine	7357

Emissions:

Maximum emissions for the factory mounted (CEMCO) John Deere model 4045D diesel engine, operating for 3,120 hours per 12-month rolling period, are expected to be as follows:

	Maximum Annual Emissions
Pollutant	(tons/yr)
Particulate Matter (PM) (Total)	0.29
Sulfur Oxides (SOx)	0.27
Nitrogen Oxides (NOx)	4.1
Volatile Organic Compounds (VOC)	0.32
Carbon Monoxide (CO)	0.88

Emissions Limitations:

a.   Visible emissions shall not be emitted from the equipment covered by this permit except that discharges shall be permitted for two (2) minutes during any startup, cleaning, adjustment of combustion or operational controls, or regeneration of emissions control equipment; provided, that such discharges shall not exceed twenty-seven percent (27%) opacity (unaveraged). [20 DCMR 606.1 and 606.2(d)]

b.   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]

Violation of the requirements of this condition that occur as a result of unavoidable malfunction, despite the conscientious employment of control practices, shall be an affirmative defense for which the owner or operator shall bear the burden of proof. A malfunction shall not be considered unavoidable if the owner or operator could have taken, but did not take, appropriate steps to eliminate the malfunction within a reasonable time, as determined by the Department. [20 DCMR 903.13(b)]

Emergency Generator Set Powered by Compression Ignition Internal Combustion Engines (CI-ICE) subject to National Emissions Standards for Hazardous Air Pollutants (NESHAP): One (1) emergency generator set powered by diesel-fired engines not subject to NSPS (40 CFR 60) Subpart IIII as described in the following table:

Emission Unit ID	Emission Unit Description	Permit No.
Plant Gen #1	One MQ Power WhisperWattTM, Model DCA70SSJU, 40 kWe standby generator set powered by a John Deere 4045TF 99 hp Diesel Engine (Model year 2004)	7358

Emissions:

Maximum emissions for the MQ Power WhisperWatt^TM emergency generator set, operating for five hundred (500) hours per year each, are to be expected to be as follows:

	Maximum Annual Emissions
Pollutant	(tons/yr)
Particulate Matter (PM) (Total)	0.06
Sulfur Oxides (SOx)	0.05
Nitrogen Oxides (NOx)	0.77
Volatile Organic Compounds (VOC)	0.06
Carbon Monoxide (CO)	0.17

Emissions Limitations:

a.   Visible emissions shall not be emitted from the equipment covered by this permit except that discharges shall be permitted for two (2) minutes during any startup, cleaning, adjustment of combustion or operational controls, or regeneration of emissions control equipment; provided, that such discharges shall not exceed twenty-seven percent (27%) opacity (unaveraged). [20 DCMR 606.1 and 606.2(d)]

b.   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]

Violation of the requirements of this condition that occur as a result of unavoidable malfunction, despite the conscientious employment of control practices, shall be an affirmative defense for which the owner or operator shall bear the burden of proof. A malfunction shall not be considered unavoidable if the owner or operator could have taken, but did not take, appropriate steps to eliminate the malfunction within a reasonable time, as determined by the Department. [20 DCMR 903.13(b)]

DOEE has reviewed the permit applications 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 Nos. 7356, 7357, and 7358 have been prepared.

The permit applications and supporting documentation, along with the draft permits 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 available 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 permits 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, 5^th Floor
Washington, DC 20002

No comments or hearing requests submitted after October 23, 2023 will be accepted.

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