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Draft Air Quality Permit 6618-R1 - The George Washington University

Friday, May 10, 2019

PUBLIC NOTICE

Draft Air Quality Permit 6618-R1, The George Washington University, Operation of an existing cogeneration facility at Ross Hall, Foggy Bottom Campus, 2300 I Street NW

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 a permit (No. 6618 -R1) to George Washington University (GW) to operate a cogeneration facility. This is a renewal of a permit issued on April 10, 2018, and is intended to allow continued operation of the cogeneration facility at Ross Hall. The cogeneration facility consists of combined heat and power emission units and ancillary support equipment to be located in the Central Utility Plant within Ross Hall, Foggy Bottom Campus, 2300 I Street NW, Washington, DC. The contact person for the facility is Janine Helwig, Interim Director, Utilities & Engineering, phone number: (202) 994-5141. 

The equipment includes a combustion gas turbine (CT) and heat recovery steam generator (HRSG)/Duct Burner in the Ross Hall utility plant. The natural gas fired combustion turbine has the capacity to produce 4.6 megawatts (MW) of electrical power. The HRSG/Duct Burner which is also natural gas fired, will produce steam for process use and additional power supply via an existing steam turbine. The HRSG Duct Burner has a rated capacity of 15.2 million Btu/hr, lower heating value (LHV) basis.

The proposed facility will use natural gas to operate a highly efficient cogeneration heat and power system, thereby reducing GW’s carbon footprint.

The facility’s components are described below:

  • Combined Heat and Power (CHP) Emission Units:
    • One (1) Solar Centaur 50-T6200S Combustion Gas Turbine (CT) rated at 52.9 MMBtu/hr heat input firing natural gas (NG) only; and
    • One (1) Cleaver Brooks Slant Series S4-2816 Heat Recovery Steam Generator (HRSG) equipped with supplemental firing by COEN Duct Burner rated at 15.2 MMBtu/hr heat input on a net lower heating value (LHV) basis (16.8 MMBTU/hr higher heating value (HHV) basis), firing NG;
       
  • CHP Ancillary Equipment and Appurtenances:
    • One (1) 4,600 kW Centaur 50 Gas Turbine Generator;
    • One (1) 24,500 lb/hr Water Tube Steam Boiler for the HRSG;
    • One (1)2,974 lbm/hr Deaerator;
    • One (1) Water Treatment System;
    • One (1) Heat Exchanger for Condensate Return; and
    • One (1) Existing Steam – Receiving Turbine Generator.

Facility-Wide Emission Limits Applicable to the Cogeneration System

The following emission limits apply to the facility as a whole, and the equipment covered by this permit in particular:

1.   Visible emissions shall not be emitted into the outdoor atmosphere from the emission units and control equipment, 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, if any, or malfunction of the equipment [20 DCMR 606.1].

2.   Violation of standards set forth in Condition II(b)(1), as a result of unavoidable malfunction, despite the conscientious employment of control practices, shall constitute an affirmative defense on which the discharger shall bear the burden of proof.  Periods of malfunction shall cease to be unavoidable malfunctions if reasonable steps are not taken to eliminate the malfunction within a reasonable time.  [20 DCMR 606.4]

3.   Where the presence of uncombined water is the only reason for failure of an emission to meet the requirements of Condition II(b)(1), Condition II(b)(1) shall not be applicable. [20 DCMR 606.6]

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 prohibited. [20 DCMR 903.1] Note: This condition is District enforceable only. 

Emission Limitations Specific to the Emission Units Covered by This Permit

Emission limits for the combustion gas turbine and heat recovery steam generator/duct burner are listed below:

The Permittee shall not exceed the emission limits in the following tables as applicable: [20 DCMR 201]

Table 1: Total 12-Month Rolling Emission Limits from Permitted Equipment1

Pollutant

12-Month Rolling Emissions Limit

(tons/12 mo. rolling period)

Particulate Matter (PM) (Total)2,3

5.0

Oxides of Sulfur (SOx)

1.1

Oxides of Nitrogen (NOx)

21.3

Volatile Organic Compounds (VOC)

2.3

Carbon Monoxide (CO)

21.5

1. The equipment covered consists of one Solar Centaur 50 gas turbine, and one HRSG/duct burner.
2. PM (Total) is the sum of the filterable PM and condensable PM. 
3. All PM is expected to be smaller than 2.5 microns, so PM (Total) equals PM2.5

Table 2- Maximum Hourly Emissions (lbs/hr) when Operating Between 50% and 100 % Load, Inclusive

Pollutants

Solar Centaur 50 Gas Turbine (CT) and  HRSG/Duct Burner (HDB)

PM (Total)

1.1

SOx

0.3

NOx

4.9

VOC

0.5

CO

4.9

a.   Combustion Gas Turbine CT: One (1) Solar Centaur 50 combustion gas turbine (CT) rated at a heat input capacity of 52.9 MMBtu/hr, natural gas (NG).

1.   Emission Limitations:

A.  The gas combustion turbine shall not emit pollutants in excess of those specified in Tables 1 and 2. [20 DCMR 201]         

B.  Particulate emissions (total filterable only) from the gas combustion turbine shall not exceed 0.069 pound per million Btu. [20 DCMR 600.1]

C.  Sulfur dioxide (SO2) emissions from the gas turbine shall not exceed 0.060 lb SO2/MMBtu heat input for each calendar month when natural gas is burned. [40 CFR 60.4330]:

D.  NOx emissions from the turbine without supplemental firing shall not exceed 15 ppmvd at 15% O2. [40 CFR 60.4320 and 60.4325, 20 DCMR 201, and 20 DCMR 805.4 (a)(1)(A)(i)]  Note that this is a streamlined emission rate limit, and is more stringent than the limits found in 40 CFR 60, Subpart KKKK and 20 DCMR 805.4 for NOx emissions cited above. Compliance with this condition will ensure compliance with all three requirements.

E.   NOx emissions from the turbine when fired with supplemental duct burner firing shall not exceed 18 ppmvd at 15% O2.  [40 CFR 60.4320 and 60.4325, 20 DCMR 201, and 20 DCMR 805.4 (a)(1)(A)(i)]  Note that this is a streamlined emission rate limit, and is more stringent than the limits found in 40 CFR 60, Subpart KKKK and 20 DCMR 805.4 for NOx emissions cited above.  Compliance with this condition will ensure compliance with all three requirements.

b.   HRSG/Duct Burner HDB: One (1) Cleaver Brooks Slant Series S4-2816 Heat Recovery Steam Generator (HRSG) equipped with supplemental firing by COEN Duct Burner rated at 15.2 MMBtu/hr heat input on a net lower heating value (LHV) basis (16.8 MMBTU/hr higher heating value (HHV) basis), firing NG;

1.   Emission Limitations:

A.  The HRSG/Duct Burner (HDB), shall not emit pollutants in excess of 0.1 lb NOx/MMBtu and those in Condition III, Table 2. [20 DCMR 201]

B.  Particulate emissions (total filterable only) from the HDB shall not exceed 0.087 pounds per million Btu. [20 DCMR 600.1]

C.  Sulfur dioxide emissions shall not exceed 0.060 lb SO2/MMBtu heat input. [40 CFR 60.4305 and 40 CFR 60.4330(a)(2)]

D.  NOx emissions from the Combustion Turbine/HDB (CT/HDB) train exhaust (while supplemental firing with duct burner) shall not exceed 18 ppmvd at 15% O2 as required by Condition III(a)(1)(E). [20 DCMR 201, 40 CFR 60.4320, and 20 DCMR 805.4(a)(1)(A)(i)] Note that this is a streamlined permit condition and is more stringent than the requirements of both 40 CFR 60.4320 and 20 DCMR 805.4(a)(1)(A)(i), therefore compliance with the limit established pursuant to 20 DCMR 201 will ensure compliance with 40 CFR 60.4320 and 20 DCMR 805.4(a)(1)(A)(i).

E.   NOx emissions from CT/HDB train shall not exceed 5.0 lb/hr (the cumulative lb/hr emission rate contained in Table 2 above) as measured at the HRSG exhaust. [20 DCMR 201]

The application to operate these emission units and the draft renewal permit are available for public inspection at AQD and copies may be made 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.

Interested persons may submit written comments or may request a hearing on this subject within thirty (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 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 June 10, 2019 will be accepted.

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