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Draft Title V and Ch-2 Air Quality Operating Permit for American University

PUBLIC NOTICE

AIR QUALITY TITLE V OPERATING PERMIT AND
GENERAL PERMIT FOR AMERICAN UNIVERSITY

Notice is hereby given that American University has applied for a Title V air quality permit pursuant to the requirements of Title 20 of the District of Columbia Municipal Regulations, Chapters 2 and 3 (20 DCMR Chapters 2 and 3) to operate the following notable emission units: two 62.82 million BTU per hour boilers, one 25.50 million BTU per hour boiler, one 5.86 million BTU per hour boiler, fourteen (14 ) small boilers, each having a capacity of five million or fewer BTUs per hour of heat input, thirty (30) water heaters and twenty emergency generators, at American University located at 4400 Massachusetts Avenue, NW, Washington DC.  The contact person for the facility is Juan Allen, Chief Engineer, Central Plant Operations, at (202) 885-2336.

With the potential to emit approximately 153 tons per year of nitrogen oxides and 103 tons per year of sulfur dioxide, the facility has the potential to emit greater than the District’s major source thresholds of 25 tons per year of nitrogen oxides and 100 tons per year of sulfur dioxide.  Therefore, the facility is classified as a major source of air pollution and is subject to 20 DCMR Chapter 3.

Emission Information for Emission Units being Permitted for the First Time

Small boiler at the McCabe Building:

Of the fourteen (14) small boilers, only one of those is new and it is being permitted for the first time. It is located in the McCabe Building of American University.  The unit has a capacity of 0.88 million BTU per hour of heat input. Under the provisions of 20 DCMR 200.11 any fuel burning equipment which has a capacity of five million or fewer BTUs per hour of heat input and which uses for fuel only gaseous fuels or distillate oils, does not require a Chapter 2 permit.  Although this new boiler is not required to have a Chapter 2 permit, it is still subject to emissions limitations.  Consequently this requirement has been incorporated into the facility’s Title V permit.

The proposed emission limits for the new small boiler are as follows:

Particulate matter emissions from [the] boiler shall not exceed 0.13 pounds per million BTU.  Note that the Permittee is deemed to have complied with this requirement by burning only natural gas with a maximum sulfur content of 2.5 grains per 100 standard cubic feet unless other credible evidence of a violation of this limit is identified.

The estimated emissions from the unit are as follows:

Pollutant

Emission Rate (lb/hr)

Maximum Annual Emissions (tons/yr)

PM (Total)

0.0014

0.00634

SOx

0.00046

0.0020

NOx

0.076

0.334

VOC

0.0042

0.0184

CO

0.0639

0.280

Emergency generators requiring permits: Eleven (11) emergency standby generators that are subject to the New Source Performance Standards (NSPS) for stationary compression ignition internal combustion engines are listed below:

Equipment Location

Emission Unit Description

Equipment Serial Number

Transmitter Building

One (1) TB 450 kW Cummins  Diesel Generator

B100097232

Nebraska Hall

One (1) NEH 60 kW Cummins Generator

D070045800

Bender Library

One (1) BL 60 kW Cummins Diesel Generator

A100092569

Letts Hall

One (1) LTH 200 kW Cummins Diesel Generator

A100092571

Leonard  Hall

One (1) LNH 250 kW Caterpillar Diesel Generator

K060991203

Brandywine

One (1) BDW.250 kW Generac Diesel Generator

131049-0906

McDowell Generator

One (1) MDH 200 kW Cummins Diesel Generator

F110223068

Sport Center Bender Arena

One (1) SCB 350 kW Cummins Diesel Generator

E080185469 SPEC

School of International Svc. Bldg.

One (1) ISB 250 kW Cummins Diesel Generator

G090018479

Asbury Building

One (1) ASB 500 kW Cummins Diesel Generator

J070113585 SPECF

McKinley Building

One (1) MB 242 kW Cummins Diesel Generator

Model #QSB7-G5NR3

These new eleven (11) emergency generators have not been previously incorporated into the Title V operating permit, although Chapter 2 permits have been issued.  By way of this notice, the requirements of the Chapter 2 permits for these new emergency generators are hereby incorporated into the facility’s Title V operating permit.  The emergency generators are subject to the requirements of the New Source Performance Standards (NSPS), and these form the basis of the emission limits listed below.

The proposed emission limits for the new emergency generators are as follows:

a.     Emissions shall not exceed those found in the following table [40 CFR 60.4205(b) 40 CFR 60.4202(a) and 40 CFR 89.112(a)]

Emission Standards (g/kW-hr)

 

Columns by Engine Size (kW)

Pollutant

60

200

242

250

350

450

500

NMHC+NOx

4.7

4.0

4.0

4.0

4.0

4.0

4.0

CO

5.0

3.5

3.5

3.5

3.5

3.5

3.5

PM

0.40

0.20

0.20

0.20

0.20

0.20

0.20  

b.     Visible emissions shall not be emitted into the outdoor atmosphere from stationary sources (excluding fuel-burning equipment placed in initial operation before January 1, 1977); Provided, that discharges not exceeding forty percent (40%) opacity (unaveraged) shall be permitted for two (2) minutes in any sixty (60) minute period 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]

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]

The estimated emissions from each emergency generator are as follows:

Transmitter Building Emergency Generator

Pollutant

Emission Rate (lb/hr)

Maximum Annual Emissions (tons/yr)

PM (Total)

1.32

0.3300

SOx

1.23

0.3075

NOx

18.6

4.6500

VOC

1.482

0.3705

CO

4.008

1.0020

Nebraska Hall Building Emergency Generator

Pollutant

Emission Rate (lb/hr)

Maximum Annual Emissions (tons/yr)

PM (Total)

0.176

0.0440

SOx

0.164

0.0410

NOx

2.480

0.6200

VOC

0.200

0.0494

CO

0.534

0.1336

Bender Library Emergency Generator

Pollutant

Emission Rate (lb/hr)

Maximum Annual Emissions (tons/yr)

PM (Total)

0.176

0.0440

SOx

0.164

0.0410

NOx

2.480

0.6200

VOC

0.200

0.0494

CO

0.534

0.1336

Letts Hall Emergency Generator

Pollutant

Emission Rate (lb/hr)

Maximum Annual Emissions (tons/yr)

PM (Total)

0.587

0.1467

SOx

0.547

0.1367

NOx

8.267

2.0667

VOC

0.659

0.1647

CO

1.781

0.4453

Leonard Hall Emergency Generator

Pollutant

Emission Rate (lb/hr)

Maximum Annual Emissions (tons/yr)

PM (Total)

0.733

0.1833

SOx

0.683

0.1708

NOx

10.333

2.5833

VOC

0.823

0.2058

CO

2.227

0.5567

Brandywine Emergency Generator

Pollutant

Emission Rate (lb/hr)

Maximum Annual Emissions (tons/yr)

PM (Total)

0.733

0.1833

SOx

0.683

0.1708

NOx

10.333

2.5833

VOC

0.823

0.2058

CO

2.227

0.5567

McDowell Emergency Generator

Pollutant

Emission Rate (lb/hr)

Maximum Annual Emissions (tons/yr)

PM (Total)

0.587

0.1467

SOx

0.547

0.1367

NOx

8.267

2.0667

VOC

0.659

0.1647

CO

1.781

0.4453

Sport Center Bender Arena Emergency Generator

Pollutant

Emission Rate (lb/hr)

Maximum Annual Emissions (tons/yr)

PM (Total)

1.027

0.2567

SOx

0.957

0.2392

NOx

14.467

3.6167

VOC

1.153

0.2882

CO

3.117

0.7793

School of International Service Building Emergency Generator

Pollutant

Emission Rate (lb/hr)

Maximum Annual Emissions (tons/yr)

PM (Total)

0.00432

0.0108

SOx

0.00013

0.00338

NOx

18.6

4.6500

VOC

1.482

0.3705

CO

4.008

1.0020

Asbury Building Emergency Generator

Pollutant

Emission Rate (lb/hr)

Maximum Annual Emissions (tons/yr)

PM (Total)

0.4668

0.1167

SOx

0.008

0.0020

NOx

16.00

4.0000

VOC

0.47

0.1175

CO

4.008

1.0020

McKinley Building Emergency Generator

Pollutant

Emission Rate (lb/hr)

Maximum Annual Emissions (tons/yr)

PM (Total)

0.0908

0.0227

SOx

0.000904

0.000226

NOx

2.992

0.7480

VOC

0.7244

0.1811

CO

4.008

1.0020

The District Department of the Environment (DDOE) 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 #013-R2 has been prepared.

The application, the draft permit, and all other materials submitted by the applicant [except those entitled to confidential treatment under 20 DCMR 301.1(c)] considered in making this preliminary determination are available for public review during normal business hours at the offices of the District Department of the Environment, 1200 First Street NE, 5th Floor, Washington DC 20002.

A public hearing on this permitting action will not be held unless DDOE 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.  Hearing requests or comments should be directed to Stephen S. Ours, DDOE Air Quality Division, 1200 First Street NE, 5th Floor, Washington DC 20002.  Questions about this permitting action should be directed to John C. Nwoke at (202) 724-7778 or john.nwoke@dc.gov.  Comments or hearing requests will not be accepted after May 13, 2013.