Notice Requesting Public Comment on Draft Title V and Chapter 2 Air Quality Operating Permit for Washington Metropolitan Area Transit Authority (WMATA)

PUBLIC NOTICE

Notice Requesting Public Comment on Draft Title V and Chapter 2 Air Quality Operating Permit for Washington Metropolitan Area Transit Authority (WMATA) – Bladensburg Bus Facility

Notice is hereby given that Washington Metropolitan Area Transit Authority (WMATA)

 has applied for a Title V air quality permit pursuant to the requirements of Title 20 of the District of Columbia Municipal Regulations, Chapters 2 and 3 (20 DCMR Chapters 2 and 3) to operate two 14.7 million BTU per hour boilers, seven paint booths, six emergency generators, one gasoline dispensing station, one 8,000 gallon capacity gasoline storage tank, and miscellaneous other smaller equipment at the Bladensburg Bus Facility located at 2250 and 2251 26^th Street NE, Washington, DC. The contact person for the facility is Carla A. Grano, Deputy Chief, Environmental Management & Industrial Hygiene at (202) 962-5077.

With the potential to emit approximately 49.92 tons per year of oxides of nitrogen (NO_x), the source has the potential to emit greater than the District’s major source threshold of 25 tons per year of NO_x.  Therefore, the facility is classified as a major source of air pollution and is subject to 20 DCMR Chapter 3 and must obtain an operating permit under that regulation.

Emission Information for Emission Units being Permitted for the First Time:

For the two 14.7 million BTU/hour boilers:

Maximum annual potential emissions from each boiler are as follows:

Pollutant	Maximum Annual Emissions tpy
Carbon Monoxide (CO)	10.60
Oxides of Nitrogen (NOx)	18.40
Total Particulate Matter (PM)	3.04
Volatile Organic Compounds (VOC)	0.69
Sulfur Dioxide (SO2)	66.23

The proposed emission limits for the boilers are as follows:

1. Each boiler shall not emit pollutants in excess of those specified in the following table [20 DCMR 201]:

Boiler Hourly Emission Limits (By Fuel)
Pollutant	Natural Gas (lb/hr)	No. 2 Fuel Oil (lb/hr)
Carbon Monoxide (CO)	1.210	0.525
Oxides of Nitrogen (NOx)	0.519	2.100
Total Particulate Matter (including condensables)	0.110	0.347
Volatile Organic Compounds (VOC)	0.079	0.034
Sulfur Dioxide (SO2)	0.009	7.560

2. Total suspended particulate matter (TSP) emissions from each boiler shall not exceed 0.09 pounds per million BTU. [20 DCMR 600.1]

3. No visible emissions shall be emitted into the outdoor atmosphere from each boiler; except that no greater than 40% opacity (unaveraged) shall be permitted for two minutes per hour and for an aggregate of twelve minutes per 24-hour period during start-up, cleaning, soot blowing, adjustment of combustion controls, or malfunction. [20 DCMR 606.1]

4. NO_x and CO emissions shall not exceed those achieved with the performance of annual combustion adjustments on each boiler. To show compliance with this condition, the Permittee shall, each calendar year, perform boiler combustion process adjustments with following characteristics [20 DCMR 805.1(a) and 20 DCMR 805.8(a) and (b)]:       

i.    Inspection, adjustment, cleaning or replacement of fuel burning equipment, including the burners and moving parts necessary for proper operation as specified by the manufacturer;

ii.   Inspection of the flame pattern or characteristics and adjustments necessary to minimize total emissions of NO_x and, to the extent practicable, minimize emissions of CO;

iii.  Inspection of the air-to-fuel ratio control system and adjustments necessary to ensure proper calibration and operation as specified by the manufacturer; and

iv.  Adjustments shall be made such that the maximum emission rate for any contaminant does not exceed the maximum allowable emission rate as set forth in this section.

For the Emergency Generators Subject to New Source Performance Standards (NSPS): one (1) 1500 kW Caterpillar engine (EG5) and one (1) Cummins Engine (EG6).

Maximum annual potential emissions from each unit are as follows:

	Maximum Annual Emissions - EG5	Maximum Annual Emissions - EG6
Pollutant	(tons/yr)	(tons/yr)
Particulate Matter (PM) (Total)1	0.09	0.12
Sulfur Oxides (SOx)	0.01	0.33
Nitrogen Oxides (NOx)	10.01	8.44
Volatile Organic Compounds (VOC)	0.24	0.17
Carbon Monoxide (CO)	0.78	0.29

The proposed emission limits for each NSPS emergency generator are as follows:

1. Emissions from each engine shall not exceed those found in the following table as measured following the procedures in 40 CFR 89, Subpart E. [40 CFR 60.4205(b) 40 CFR 60.4202(a) and 40 CFR 89.112(a)]

Pollutant Emission Limits (g/kW-hr)
NMHC+NOx	CO	PM
6.4	3.5	0.2

2. Visible emissions shall not be emitted into the outdoor atmosphere from stationary sources (excluding fuel-burning equipment placed in initial operation before January 1, 1977); Provided, that discharges not exceeding forty percent (40%) opacity (unaveraged) shall be permitted for two (2) minutes in any sixty (60) minute period for an aggregate of twelve (12) minutes in any twenty-four hour (24 hr.) period during start-up, cleaning, soot blowing, adjustment of combustion controls, or malfunction of equipment. [20 DCMR 606.1]

3. 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]

For the Non-NSPS Emergency Generators (EG1, EG2, EG3, and EG4):  one (1) 80 kW Detroit Diesel engine (EG1), one (1) 100 kW Kohler Power System engine (EG2), and Two (2) 200 kW Cummins Onan engines (EG3 and EG4) all diesel emergency generators.

Maximum annual potential emissions from each unit are expected to be as follows:

	EG1 & EG2	EG3 & EG4
Pollutant	(tons/yr)	(tons/yr)
Particulate Matter (PM) (Total)1	0.07	0.15
Sulfur Oxides (SOx)	0.07	0.14
Nitrogen Oxides (NOx)	1.04	2.08
Volatile Organic Compounds (VOC)	0.08	0.17
Carbon Monoxide (CO)	0.22	0.45

The proposed emission limits for each non-NSPS emergency generator are as follows:

1. Visible emissions shall not be emitted into the outdoor atmosphere from stationary sources (excluding fuel-burning equipment placed in initial operation before January 1, 1977); Provided, that discharges not exceeding forty percent (40%) opacity (unaveraged) shall be permitted for two (2) minutes in any sixty (60) minute period for an aggregate of twelve (12) minutes in any twenty-four hour (24 hr.) period during start-up, cleaning, soot blowing, adjustment of combustion controls, or malfunction of equipment. [20 DCMR 606.1]

2. 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]

For the seven (7) Paint booths PB1, PB2, PB3, PB4, PB5, PB6 and PB7: The emission limits are as follows:    

Maximum annual potential emissions from each unit are expected to be as follows:

	PB1 – PB6	PB7
Pollutant	(tons/yr)	(tons/yr)
Particulate Matter (PM) (Total)1	1.70	0.07
Volatile Organic Compounds (VOC)	0.64	0.20

The proposed emission limits for the paint booths are as follows:

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

2. Paints and refinishing coatings that contain volatile organic compounds (VOCs) in excess of the limits specified in the table below, including any VOC containing materials added to the original coating supplied by the manufacturer, shall be prohibited. [20 DCMR 718.3]

Allowable Content of VOCs in Mobile Equipment Repair and Refinishing Coatings (as applied)
Coating Type	Weight (pounds per gallon)	Limit* (grams per liter)
Automotive pretreatment primer	6.5	780
Automotive primer-surfacer	4.8	575
Automotive primer-sealer	4.6	550
Automotive topcoat:
single stage-topcoat	5.0	600
2 stage basecoat/clearcoat	5.0	600
3 or 4-stage basecoat/clearcoat	5.2	625
Automotive multi-colored topcoat	5.7	680
Automotive specialty coating	7.0	840

*Weight of VOC per volume of coating (minus water and non-VOC solvents)

3. 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]

4. Visible emissions shall not be emitted into the outdoor atmosphere from the paint booth. [20 DCMR 201, 606, and 903.1]

For Gasoline Dispensing Station (D1):

Maximum annual potential emissions from the gasoline dispensing station are expected to be as follows:  0.64 tons per year of VOCs.

The proposed emission limit for the gasoline dispensing station is as follows:

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 District Department of the Environment (DDOE) has reviewed the permit application 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 #039 has been prepared.

The application, the draft permit, and all other materials submitted by the applicant [except those entitled to confidential treatment under 20 DCMR 301.1(c)] considered in making this preliminary determination are available for public review during normal business hours at the offices of the District Department of the Environment, 1200 First Street NE, 5^th Floor, Washington DC 20002. Copies of the draft permit and related fact sheet are available below.

A public hearing on this permitting action will not be held unless DDOE 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.  Hearing requests or comments should be directed to Stephen S. Ours, DDOE Air Quality Division, 1200 First Street NE, 5^th Floor, Washington DC 20002.  Questions about this permitting action should be directed to Olivia Achuko at (202) 535-2997 or [email protected].  Comments or hearing requests will not be accepted after March 10, 2014.