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Notice of Public Comment Period - Draft Air Quality Permit 5197-R1, U.S. General Services Administration - Central Heating and Refrigeration Plant

Friday, July 22, 2022

PUBLIC NOTICE

Draft Air Quality Permit 5197-R1, U.S. General Services Administration, Operation of an existing cogeneration system at the Central Heating and Refrigeration Plant, 325 13th Street SW

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 air quality permit No. 5197-R1 to the U.S. General Service Administration (GSA) to operate an existing cogeneration system at the Central Heating and Refrigeration Plant, located at 325 13th Street SW, Washington DC 20407. The contact person for facility is George M. Korvah, Environmental Manager, at (202) 690-9719 or [email protected].

The equipment is already existing and operational at the site. It is described in the following table:

Equipment Location

Equipment Size

Description

Permit Number

GSA-Central Heating and Refrigeration Plant

Two (2) 58 MMBTU/hr LHV basis (approximately 64 MMBTU/hr HHV basis) combustion turbines

Two Dual fuel Solar Taurus Turbine 60 T7300S combustion turbines (natural gas and No. 2 fuel oil), identified as CT1 and CT2

5197-R1

Natural gas-fired duct burner system with six burner elements with a combined rating of 190 MMBTU/hr heat input LHV basis (approximately 211 MMBTU/hr HHV basis)

Modified (converted) Zurn Boiler #5 with installed natural gas-fired duct burners

Emissions Estimates:

The potential to emit of the equipment (operating at maximum allowable rates for maximum allowable time using the highest emitting fuel) is estimated to be as follows:

                                                  

Potential to Emit from Cogeneration System

Pollutant

(tons/yr)

Total Particulate Matter (PM Total) τ

76.14

Sulfur Dioxide (SO2)

2.41

Nitrogen Oxides (NOx)

258.6

Volatile Organic Compounds (VOC)

5.73

Carbon Monoxide (CO)

115.5

τ PM Total includes both filterable and condensable fractions.

The proposed emission limits are as follows:

  1. Emissions from the equipment covered by this permit shall not exceed those specified in the following table [20 DCMR 201]:

Allowable Emissions (lb/hr)

Pollutant

Each Combustion Turbine

Additional Allowable when Operating Duct Burners

Burning Natural Gas

Burning No. 2 Fuel Oil

Carbon Monoxide (CO)

5.25

0.21

17.38

Total Particulate Matter (PM total)

4.16

4.16

9.92

PM Total includes both filterable and condensable fractions.

This is a streamlined limit. The limit established pursuant to 20 DCMR 201 for duct burner emissions of PM Total is more stringent than that for total filterable particulate matter (also known as total suspended particulate matter or TSP) found in 20 DCMR 600.1, thus compliance with this limit will also ensure compliance with 20 DCMR 600.1.

b.   Except as specified in Condition II(c), the Permittee shall not discharge into the atmosphere from each of the combustion turbines any gas which contain nitrogen oxides (NOx) in excess of [40 CFR 60.332(a)(2) and (c)]:
      STD = 0.0150 x 14.4/Y + F           

Where:

STD = allowable ISO corrected (if required as given in 40 CFR 60.335(b)(1) NOx emission concentration (percent by volume at 15 percent oxygen and on a dry basis);

Y = manufacturer’s rated heat rate at manufacturer’s rated peak load (kilojoules per watt hour), or actual measured heat rate based on lower heating value of fuel as measured at actual peak load for the facility.  The value of Y shall not exceed 14.4 kilojoules per watt hour; and

F = NOx emissions allowance for fuel-bound nitrogen as defined in 40 CFR 60.332(a)(4).

c.   The Permittee is exempt from compliance with Condition II(b) when burning No. 2 fuel oil, as long as compliance with Condition III(b) is maintained. [40 CFR 60.332(k)]

d.   Emissions of NOx shall comply with the following:

1.   Emissions from each stationary combustion turbine alone shall not be greater than [20 DCMR 805.4(a)(2)(A)]:

i.    Twenty-five (25) ppmvd, corrected to fifteen percent (15%) O2 when fired on any combination of gaseous fuels; and

ii.   The Permittee shall comply with Conditions III(a) through (d) and V(e) and (f) [related to what fuels can be burned and when] in lieu of complying with the standard specified in 20 DCMR 805.4(a)(2)(A)(ii);

2.   Emissions from any stationary combustion turbine and all duct burners combined shall not be greater than twenty hundredths (0.20) pounds per million BTU, based on a calendar day average, when fired on any fuel or combination of fuels [20 DCMR 805.4(a)(2)(B)]; and

3.   Emissions from the equipment covered by this permit (the two combustion turbines plus the duct burners), combined with Boilers 3 and 4 at the facility, shall not exceed 25 tons per control period. The control period is defined as the period beginning May 1st of each year and ending on September 30th of the same year, inclusive [20 DCMR 1001.1 and 20 DCMR 1099.1]; and

4.   Emissions from either combustion turbine, alone or in combination with the duct burners, shall not exceed [20 DCMR 804.1 and 20 DCMR Chapter 8, Appendix 8-1]:

i.    Two tenths (0.2) lb. per million BTU heat input (0.36 g. per million cal.) maximum two (2) hour average, expressed in NO2, when natural gas is burned: and

ii.   Three tenths (0.3) lb. per million BTU heat input (0.54 g. per million cal.) maximum two (2) hour average, expressed as NO2, when No. 2 fuel oil is burned.

5.   NOx emissions from the system, expressed as NO2, whenever the duct burners are running, on a 30-day rolling average basis, shall not exceed 0.20 lb/MMBTU. [40 CFR 60.40b(i), 40 CFR 60.44b(a)(4)(i), 40 CFR 60.46b(f)(2)]

e.   Visible emissions whose opacity is in excess of five percent (5%) (unaveraged) shall not be emitted into the outdoor atmosphere from the equipment covered by this permit; provided 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, soot blowing, adjustment of combustion controls, or malfunction of equipment. [20 DCMR 606.1 and 606.3]

f.    Total suspended particulate matter (TSP) (also known as total filterable PM) emissions from the cogeneration system, when the duct burners are operational, shall not exceed 0.05 pounds per MMBTU. [20 DCMR 600.1]

g.   Total particulate matter (total filterable plus condensable fractions) shall not be emitted from the combustion turbines, when operating alone, in excess of 0.065 pounds per MMBTU. [20 DCMR 201; reference also previous permit 5197, Table 1]

h.   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 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) 535-1747. Copies of the draft permit and related technical support memorandum are availablein 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 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 August 22, 2022 will be accepted.

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