Notice of Public Comment Period - Draft Air Quality Permits 7381 and 7382 - Smithsonian Institution/Board of Regents - National Zoological Park

PUBLIC NOTICE

Draft Air Quality Permits 7381 and 7382, Smithsonian Institution/Board of Regents, Modification and operation of two 20.17 MMBTU/hr dual fuel (natural gas and No. 2 fuel oil) boilers at the National Zoological Park, 3001 Connecticut Ave NW, Washington DC.

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, proposes to issue Permit Nos. 7381 and 7382 to the Smithsonian Institution/Board of Regents to modify and operate two (2) existing dual-fuel (No.2 oil and natural gas-fired) boilers at the National Zoological Park, Central Heating Plant, located at 3001 Connecticut Avenue NW, Washington DC. The boilers, designated CU-1 and CU-2, respectively, have a heat input rating of 20.17 MMBTU/hr when burning natural gas and 19.35 MMBTU/hr when burning No. 2 fuel oil. The modification consists of the installation of low NOx (oxides of nitrogen) burners in the existing boilers. The contact person for the facility is Joseph Cusick, Building Manager, at (202) 633-6258 or [email protected].

Emissions:

The estimated maximum annual emissions from each of the two (2) boilers are expected to be as follows:

	Maximum Annual Emissions for Each Boiler
Pollutant	(tons/yr)
Total Particulate Matter (PM Total)	2.00
Sulfur Dioxide (SO2)	0.13
Oxides of Nitrogen (NOx)	9.75
Volatile Organic Compounds (VOC)	0.32
Carbon Monoxide (CO)	3.33
Total Hazardous Air Pollutants (HAPs)	0.18

This burner modification is expected to reduce the potential to emit NOx from each boiler by 3.1 tons per year and the potential to emit CO from each boiler by 4.0 tons per year.

The proposed emission limits are as follows:

1. 1. Each of the boilers (identified as CU-1 and CU-2) shall not emit pollutants in excess of those specified in the following tables [20 DCMR 201]:

Emission Limits for Boilers CU-1 and CU-2
Pollutant	Short-Term Limit (Natural Gas) (lb/hr)	Short-Term Limit (No. 2 Fuel Oil) (lb/hr)
Carbon Monoxide (CO)	0.76	0.75
Oxides of Nitrogen (NOx)	0.71	2.22
Total Particulate Matter (PM Total)1	0.15	0.46
Sulfur Dioxide (SO2)	0.012	0.03

¹PM Total includes both filterable and condensable fractions.

1. 2. Visible emissions shall not be emitted into the outdoor atmosphere from either boiler 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 discharge shall not exceed the following opacities (unaveraged) [20 DCMR 606.1 and 606.2]:

1.   When burning exclusively natural gas, twenty percent (20%); and

2.   When burning fuel oil or a combination of fuel oil and natural gas, twenty seven percent (27%).

1. 3. Total suspended particulate matter (TSP) emissions from each of the boilers shall not be greater than 0.09 pounds per million BTU. [20 DCMR 600.1].
2. 4. 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 prohibite [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)]

1. 5. NOx and CO emissions shall not exceed those achieved with the performance of annual combustion adjustments on the boiler. To show compliance with this condition, the Permittee shall, every calendar year, not to exceed thirteen (13) months from the date of the last tune-up, and by November 1 of the year on which it is due, perform adjustments of the combustion processes of the boilers with the following characteristics [20 DCMR 805.1(a), 20 DCMR 805.5(b) and 20 DCMR 805.9(a)]:
2. 1. 1. As applicable, inspect the burner, and clean or replace any components of the burner as necessary for proper operation;
3. 1. 2. Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustments should be consistent with the manufacturer’s specifications, if available;
4. 1. 3. Inspect the system controlling the air-to-fuel ratio and ensure that it is correctly calibrated and functioning properly;
5. 1. 4. Optimize total emissions of NOx and to the extent possible, CO. This optimization should be consistent with the manufacturer’s specifications, if available, and shall be consistent with any NOx and CO requirements to which the unit is subject; and
6. 1. 5. Measure the concentrations in the effluent stream of CO and NOx is ppmvd and O₂ in percent by volume dry basis, before and after the adjustments are made. Measurements may be taken using a portable analyzer;

If a boiler subject to this requirement is not operating on the required date for a tune-up, the tune-up must be conducted within 30 days of startup. [20 DCMR 805.9(b)]

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 9:00 A.M. and 5:00 P.M. Monday through Friday, excluding holidays. 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 or [email protected]. Copies of the draft permit and related technical support memorandum are also available in the attachments section below.

Interested persons may submit written comments or may request a public 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 before taking final action on the permit application.
 

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

[email protected]

No comments or hearing requests submitted after March 17, 2025 will be accepted.

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