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Notice of Public Comment Period - Draft Air Quality Permit 7363 - Howard University

Friday, November 17, 2023


Draft Air Quality Permit 7363, Howard University, Construction and operation of an 8.27 MMBTU/hr natural gas-fired boiler at the Howard University Service Center, 2244 10th 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 Permit No. 7363 to Howard University to construct and operate one 8.27 million BTU per hour natural gas-fired boiler at the Howard University Service Center located at 2244 10th Street NW, Washington DC 20059. The contact person for Howard University is Ariel C. Triplett, Interim Director of Environmental, Health, and Safety, at (202) 860-4175.


The estimated maximum annual emissions from the 8.27 MMBTU/hr natural gas-fired boiler are expected to be as follows:


Maximum Annual Emissions for Each Boiler



Total Particulate Matter (PM Total)


Sulfur Dioxide (SO2)


Nitrogen Oxides (NOx)


Volatile Organic Compounds (VOC)


Carbon Monoxide (CO)


The proposed emission limits are as follows:

a.   This 8.27 MMBTU per hour natural gas fired boiler shall not emit pollutants in excess of those specified in the following table [20 DCMR 201]:

Boiler Emission Limits


Short-Term Limit (lb/hr)

Carbon Monoxide (CO)


Oxides of Nitrogen (NOx)


Total Particulate Matter (PM Total)


Sulfur Dioxide (SO2)


*PM Total includes both filterable and condensable fractions.

b.   Visible emissions shall not be emitted from the equipment covered by this permit except that discharges shall be permitted for two (2) minutes during any startup, cleaning, adjustment of combustion or operational controls, or regeneration of emissions control equipment; provided, that such discharges shall not exceed twenty percent (20%) opacity (unaveraged). [20 DCMR 606.1 and 606.2(a)(1)]

c.   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]

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)]

d.   Total suspended particulate matter (TSP) emissions from the boiler shall not exceed 0.11 pound per million BTU. [20 DCMR 600.1]

e.   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 two (2) years, not to exceed twenty-five (25) months from the date of last 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]:

  1. As applicable, inspect the burner, and clean or replace any components of the burner as necessary for proper operation;

ii.   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;

iii.  Inspect the system controlling the air-to-fuel ratio and ensure that it is correctly calibrated and functioning properly;

iv.  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

v. 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;

The permit application and supporting documentation, along with the draft permit is 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 also available at

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 in issuing the final permits.

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, 5th Floor
Washington DC 20002

[email protected]

No comments or hearing requests submitted after December 18, 2023 will be accepted.

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