Draft Air Quality Permits 6790-R1 and 6791-R1 - The George Washington University

PUBLIC NOTICE

Draft Air Quality Permits 6790-R1 and 6791-R1, The George Washington University, Operation of two existing 7.0 MMBTU/hr dual fuel-fired boilers at Lisner Hall, 2023 G 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, 5^th Floor, Washington, DC, intends to issue Permit Nos. 6790-R1 and 6791-R1 to The George Washington University to operate two 7.0 million BTU per hour Cleaver Brooks dual fuel fired (natural gas and No. 2 fuel oil ) boilers, located at The George Washington University’s Lisner Hall in Washington, DC. The contact person for the facility is Janine Helwig, Interim Director, Utilities & Engineering, phone number: (202) 994-5141. 

Boilers to be Permitted

Equipment Location	Address	Equipment Size (MMBTU/hr heat input)	Model/Serial Number	Emission Unit No.	Permit No.
Lisner Hall	2023 G Street NW	7.0	FLX-200-700- 15ST/08860-1-1	EUN-321	6790-R1
Lisner Hall	2023 G Street, NW	7.0	FLX-200-700- 15ST/08860-1-2	EUN-322	6791-R1

Emissions:

The estimated maximum annual emissions from each of the two (2) 7.0 MMBtu/hr dual fuel-fired (natural gas and No. 2 fuel-oil) boilers are expected to be as follows:

	Maximum Annual Emissions for Each Boiler
Pollutant	(tons/yr)
Total Particulate Matter (PM Total)	0.691
Sulfur Dioxide (SO2)	0.045
Oxides of Nitrogen (NOx)	4.19
Volatile Organic Compounds (VOC)	0.165
Carbon Monoxide (CO)	2.52

The proposed boiler emission limits are as follows:

1. 1. Each of the two (2) identical 7.0 million BTU per hour Cleaver Brooks dual-fueled boilers (identified as EUN 321 and EUN 322) shall not emit pollutants in excess of those specified in the following table [20 DCMR 201]:

Pollutant	Short-Term Limit (Natural Gas) (lb/hr)	Short-Term Limit (No. 2 Fuel oil) (lb/hr)
Carbon Monoxide (CO)	0.576	0.239
Oxides of Nitrogen (NOx)	0.686	0.956
Total Particulate Matter (PM Total)1	0.052	0.158
Sulfur Dioxide (SO2)	0.004	0.010
Volatile Organic Compounds (VOC)	0.038	0.017

¹PM Total includes both filterable and condensable fractions.

b.   Total suspended particulate matter (TSP) emissions from the each of the boilers shall not be greater than 0.11 pounds per million BTU. [20 DCMR 600.1].

c.   Visible emissions shall not be emitted into the outdoor atmosphere from the boilers, 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]

Violation of this standard, as a result of unavoidable malfunction, despite the conscientious employment of control practices, shall constitute an affirmative defense on which the Permittee 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 606.5]

d.   Where the presence of uncombined water is the only reason for failure of an emission to meet the requirements of Condition (c), the latter shall not be applicable. [20 DCMR 606.7]

e.   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]

f.    NOx 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 adjustments of the combustion processes of the boilers with the following characteristics [20 DCMR 805.1(a)(4) and 20 DCMR 805.8(a) and (b)]: Note that this condition does not establish a specific numeric standard with which the Permittee must continuously apply, but rather establishes a work practice that must be properly performed each year and tuned operational baseline where the unit must be operated.

1. 1. 1. Inspection, adjustment, cleaning or replacement of fuel burning equipment, including the burners and moving parts necessary for proper operation as specified by the manufacturer;
2. 1. 2. 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;
      3.  Inspection of the air-to-fuel ratio control system and adjustments necessary to ensure proper calibration and operation as specified by the manufacturer; and
      4. 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 Condition II of this permit.

The permit applications and supporting documentation, along with the draft permits 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.

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 set of permits.
 

Comments on the draft set of 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, 5^th Floor
Washington, DC 20002

[email protected]
 

No comments or hearing requests submitted after July 8, 2019 will be accepted.

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