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Notice Requesting Public Comment on Synthetic Minor Air Quality Operating Permit

Friday, May 26, 2023


Notice Requesting Public Comment on Draft Facility-Wide Synthetic Minor Air Quality Operating Permit and Permit to Construct for Verizon Washington DC, Inc. - Metro Communication Center, 1200 H Street NW

Notice is hereby given that Verizon Washington DC, Inc. has applied for an air quality permit pursuant to the requirements of Title 20 of the District of Columbia Municipal Regulations, Chapter 2 (20 DCMR Chapter 2) to continue operation of the following emission units at the facility located at 1200 H Street NW, Washington, DC 20005:

  • Three (3) 1,500 kWe emergency generator sets powered by 2,200 hp diesel engines (designated EG1, EG2, and EG3).

In addition, the applicant has also applied for an air quality permit to install and operate the following emission unit at the same facility:

  • One (1) 1,500 kWe emergency generator set powered by a 2,328 hp diesel engine (designated EG4).

The contact person for the facility is Mr. David P. Leland, Regional Environmental Manager, (469) 886-4483 or [email protected].

The applicant has requested that limitations on the operation of the emergency generator sets be established in the permit pursuant to 20 DCMR § 200.6 to avoid the applicability of 20 DCMR § 300.1. Specifically, the applicant has requested operational limit of 200 hours in any 12-consecutive-month period for each of the emergency generator sets (EG1, EG2, EG3 and EG4).

Factoring in these operational limits, the following is an estimate of the overall potential emissions from the facility:




Potential Emissions with 20 DCMR 200.6 Limits

Sulfur Dioxide (SO2)


Oxides of Nitrogen (NOx)


Particulate Matter (PM)


Volatile Organic Compounds (VOCs)


Carbon Monoxide (CO)


      NOx emissions are slightly overestimated and VOC emissions are slightly underestimated as the manufacturer’s emissions factors for EG4 combine NOx emissions with hydrocarbon emissions; for that unit only, both are reflected in the NOx estimate and not in the VOC estimate.

Independently, the emergency generator set to be both installed and operated under the authority of this permit (EG4), taking into account the operational limit of 200 hours per 12-month rolling period, requested pursuant to 20 DCMR 200.6, is estimated to have the following potential to emit:




Potential Emissions with 20 DCMR 200.6 Limits



NOx + Non-Methane Hydrocarbons (NMHC)


Particulate Matter (PM)


Carbon Monoxide (CO)


The proposed emission limits for EG4 are as follows:

A.  Emissions from this unit shall not exceed those in the following table as measured according to the procedures set forth in 40 CFR 89, Subpart E for NMHC, NOx, and CO and 40 CFR 89.112(c) for PM. [40 CFR 60.4205(b), 40 CFR 60.4202(a)(2) and 40 CFR 1039, Appendix I]:

Pollutant Emission Limits (g/kWm-hr)







B.  Visible emissions shall not be emitted into the outdoor atmosphere from this generator set, 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, or malfunction of the equipment [20 DCMR 606.1].

Note that 20 DCMR 606 is subject to an EPA-issued call for a State Implementation Plan (SIP) revision (known as a “SIP call”) requiring the District to revise 20 DCMR 606. See “State Implementation Plans: Response to Petition for Rulemaking; Restatement and Update of EPA’s SSM Policy Applicable to SIPs; Findings of Substantial Inadequacy; and SIP Calls To Amend Provisions Applying to Excess Emissions During Periods of Startup, Shutdown and Malfunction”, 80 Fed. Reg. 33840 (June 12, 2015). It is likely that this federal action will result in changes to the requirements of 20 DCMR 606. Any such changes, once finalized in the DCMR, will supersede the language of Condition (B) as stated above.

C.  In addition to Condition III(b)(1)(B), exhaust opacity, measured and calculated as set forth in 40 CFR 1039.501(c), shall not exceed [40 CFR 60.4205(b), 40 CFR 60.4202(a)(2), and 40 CFR 1039.105]:

i.    20 percent during the acceleration mode;
ii.   15 percent during the lugging mode;
iii.  40 percent during the peaks in either the acceleration or lugging modes. Note that this condition is streamlined with the requirements of 20 DCMR 606.1.

D. 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]

With the operational limitations included in the draft permit, the Verizon Washington DC, Inc, Metro Communication Center facility has the potential to emit approximately 11.04 tons per year of oxides of nitrogen (NOx), which is below the District’s major source threshold of 25 tons per year of NOx. Similarly, all other pollutants’ potential emissions are below their respective major source thresholds. As such, the facility is properly classified as a synthetic minor source pursuant to 20 DCMR § 300.3(c) and can avoid the applicability of a permit pursuant to 20 DCMR § 300.1.

The Department of Energy and Environment (DOEE) 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 No. 7320-SM has been prepared and, pursuant to 20 DCMR §210, with this notice, the Air Quality Division (AQD) of DOEE provides notice of its proposal to issue this permit to Verizon Washington DC, Inc.

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 also available in the attachments section below.

A public hearing on this permitting action will not be held unless DOEE 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. The written comments must 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 draft 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 26, 2023 will be accepted.

For more information, please contact Stephen S. Ours at (202) 535-1747 or [email protected].