Notice of Public Comment Period - Draft Air Quality Permit 7359 - Washington Metropolitan Area Transit Authority

PUBLIC NOTICE

Draft Air Quality Permit 7359, Washington Metropolitan Area Transit Authority (WMATA), Construction and operation of an automotive paint spray booth with two associated 3.78 MMBTU/hr natural gas-fired heaters at the Bladensburg Bus Facility, 2250 26th Street NE

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, 5^th Floor, Washington DC, intends to issue an air quality permit (No. 7359) to the Washington Metropolitan Area Transit Authority (WMATA) to construct and operate one new automotive paint spray booth with two associated natural gas-fired heaters, each with a 3.78 MMBTU/hr heat input capacity, at the Bladensburg Bus facility located at 2250 26^th Street NE, Washington DC. The contact person for the facility is Claire Fox, Deputy Chief, Office of Environmental Management and Compliance (EMAC), at (301) 618-7508 or [email protected].

Emissions Estimate:

WMATA has estimated that the following are the maximum potential emissions from the paint booth, including the two natural gas-fired heaters:

	Maximum Annual Emissions
Pollutant	(tons/yr)
Total Particulate Matter (PM Total)	0.25
Sulfur Oxides (SOx)	0.02
Nitrogen Oxides (NOx)	3.25
Volatile Organic Compounds (VOC)	3.30
Carbon Monoxide (CO)	2.73
Total Hazardous Air Pollutants (HAPs)	0.06

The proposed emission limits are as follows:

a.   No chemical strippers containing methylene chloride (MeCl) shall be used for paint stripping at the facility. [20 DCMR 201.1]

b.   The Permittee shall not use or apply to a motor vehicle, mobile equipment, or associated parts and components, an automotive coating with a VOC regulatory content calculated in accordance with the methods specified in this permit that exceeds the VOC content requirements of Table I below. [20 DCMR 718.3]

Table I. Allowable VOC Content in Automotive Coatings for Motor Vehicle and Mobile Equipment Non-Assembly Line Refinishing and Recoating

Coating Category	VOC Regulatory Limit As Applied*
	(Pounds per gallon)	(Grams per liter)
Adhesion promoter	4.5	540
Automotive pretreatment coating	5.5	660
Automotive primer	2.1	250
Clear coating	2.1	250
Color coating, including metallic/iridescent color coating	3.5	420
Multicolor coating	5.7	680
Other automotive coating type	2.1	250
Single-stage coating, including single-stage metallic/iridescent coating	2.8	340
Temporary protective coating	0.50	60
Truck bed liner coating	1.7	200
Underbody coating	3.6	430
Uniform finish coating	4.5	540

*VOC regulatory limit as applied = weight of VOC per volume of coating (prepared to manufacturer’s recommended maximum VOC content, minus water and non-VOC solvents)

c.   Each cleaning solvent present at the facility shall not exceed a VOC content of twenty-five (25) grams per liter (twenty-one one-hundredths (0.21) pound per gallon), calculated in accordance with the methods specified in this permit, except for [20 DCMR 718.4]:

1.  Cleaning solvent used as bug and tar remover if the VOC content of the cleaning solvent does not exceed three hundred fifty (350) grams per liter (two and nine-tenths (2.9) pounds per gallon), where usage of cleaning solvent used as bug and tar remover is limited as follows:

A.  Twenty (20) gallons in any consecutive twelve-month (12) period for an automotive refinishing facility and operations with four hundred (400) gallons or more of coating usage during the preceding twelve (12) calendar months;

B.  Fifteen (15) gallons in any consecutive twelve-month (12) period for an automotive refinishing facility and operations with one hundred fifty (150) gallons or more of coating usage during the preceding twelve (12) calendar months; or

C.  Ten (10) gallons in any consecutive twelve-month (12) period for an automotive refinishing facility and operations with less than one hundred fifty (150) gallons of coating usage during the preceding twelve (12) calendar months;

2.   Cleaning solvents used to clean plastic parts just prior to coating or VOC-containing materials for the removal of wax and grease provided that non-aerosol, hand-held spray bottles are used with a maximum cleaning solvent VOC content of seven hundred eighty (780) grams per liter and the total volume of the cleaning solvent does not exceed twenty (20) gallons per consecutive twelve-month (12) period per automotive refinishing facility;

3.   Aerosol cleaning solvents if one hundred sixty (160) ounces or less are used per day per automotive refinishing facility; or

4.   Cleaning solvent with a VOC content no greater than three hundred fifty (350) grams per liter may be used at a volume equal to two-and-one-half percent (2.5%) of the preceding calendar year’s annual coating usage up to a maximum of fifteen (15) gallons per calendar year of cleaning solvent.

d.   The Permittee may not possess either of the following [20 DCMR 718.9]:

1.   An automotive coating that is not in compliance with Condition (b) (relating to coating VOC content limits); and

2.  A cleaning solvent that does not meet the requirements of Condition (c) (relating to cleaning solvent VOC content limits).

e.   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]

6. Visible emissions shall not exceed the following:
   1. No visible emissions shall be emitted into the outdoor atmosphere from the painting operations in the booth. [20 DCMR 201 and 20 DCMR 606]; and
   2. No visible emissions shall be emitted into the outdoor atmosphere from the natural gas-fired heaters except that discharges shall be permitted for two (2) minutes during any startup, cleaning, adjustment of combustion or operational controls, or regeneration of emission control equipment; provided that such discharges shall not exceed twenty percent (20%), unaveraged.

 j.    Total Suspended Particulate matter (TSP) emissions shall not exceed 0.13 pounds per MMBTU from the natural gas-fired heaters. [20 DCMR 600.1]

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) 498-8143. Copies of the draft permit and related technical support memorandum are available in the attachments section 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 permit.
 

Comments on the proposed permits and any request for a public hearing should be addressed to:
 

Stephen S. Ours, P.E.
Chief, Permitting Branch - Air Quality Division
Department of Energy and Environment
1200 First Street NE, 5^th Floor
Washington DC 20002

[email protected]

 

No written comments or hearing requests submitted after February 12, 2024 will be accepted.

For more information, please contact Stephen S. Ours at (202) 498-8143.