Notice of Public Comment Period - Draft Air Quality Permits 7383 and 7384

PUBLIC NOTICE

Draft Air Quality Permits 7383 and 7384, Lucy Webb Hayes National Training School for Deaconesses and Missionaries D/B/A Sibley Memorial Hospital, Modification and operation of two existing 38.532 MMBTU/hr dual-fuel-fired (natural gas and No. 2 fuel oil) boilers at the Sibley Memorial Hospital, 5255 Loughboro Road NW, Washington DC.

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, proposes to issue Permit Nos. 7383 and 7384 to the Lucy Webb Hayes National Training School for Deaconesses and Missionaries D/B/A Sibley Memorial Hospital, to modify and operate two (2) Cleaver Brooks D-52-RH dual-fuel boilers (natural gas/No.2 fuel oil) hot water boilers (listed below), located at Sibley Memorial Hospital, 5255 Loughboro Road NW, Washington DC. The modifications consist of replacing each boiler's burner system with new PowerFlame Incorporated low NOx burners (LNB) with flue gas recirculation (FGR). The contact person for the facility is Robert Smith, Director of Plant Operations, Sibley Memorial Hospital, at (202) 537-4066 or [email protected].

The following boilers are to be permitted:

Boiler Identifier	Model	Natural Gas Rating (MMBTU/hr)	No. 2 Fuel Oil Rating (MMBTU/hr)	Serial Number	Permit Number
CU-1	Cleaver Brooks D-52-RH	38.532	38.532	CB42Z/10	7383
CU-2	Cleaver Brooks D-52-RH	38.532	38.532	CB42X/10	7384

Emissions:

The project will result in changes to the potential emissions from the equipment. The following table compares the historic potential emissions with the estimated potential emissions of the boilers after undergoing the proposed modifications. The potential to emit from the boilers post-modification also take into account the additional No. 2 fuel oil limits the facility has accepted to avoid applicability to 20 DCMR 209.

Effect of Modifications on Facility-Wide Potential To Emit (PTE) on Natural Gas (Tons per Year)
Pollutant	Total Old PTE of Both Boilers	Old PTE of Each Boiler	New PTE of Each Boiler	Total New PTE of Both Boilers	Difference†
Total Particulate Matter (PM Total)	2.54	1.27	1.26	2.52	-0.02
Oxides of Sulfur (SOx)	0.18	0.09	0.10	0.2	0.02
Oxides of Nitrogen (NOx)	33.11	16.56	6.24	12.49	-20.62
Volatile Organic Compounds (VOC)	1.82	0.91	0.91	1.82	0
Carbon Monoxide (CO)	27.77	13.88	6.24	12.49	-15.28

^† A negative number indicates a decrease in potential emissions as a result of the project, while a positive number indicates an increase in potential emissions.

Effect of Modifications on Facility-Wide Potential To Emit (PTE) on No.2 Fuel Oil (Tons per Year)‡
Pollutant	Total Old PTE of Both Boilers	Old PTE of Each Boiler	New PTE of Each Boiler	Total New PTE of All Boilers	Difference†
Total Particulate Matter (PM Total)	7.97	3.99	3.32	6.63	-1.34
Oxides of Sulfur (SOx)	11.23	5.62	4.58	9.16	-2.07
Oxides of Nitrogen (NOx)	48.18	24.09	16.17	32.35	-15.83
Volatile Organic Compounds (VOC)	0.49	0.25	5.34	10.69	10.18
Carbon Monoxide (CO)	12.09	6.04	5.20	10.41	-1.68

^† A negative number indicates a decrease in potential emissions as a result of the project, while a positive number indicates an increase in potential emissions.^‡ Use of No.2 fuel oil has been limited pursuant to 40 CFR 63.11237 to meet the definition of "gas-fired boiler". These PTE emissions are also assuming an annual No.2 fuel oil consumption limit of 2,009,000 gallons annually taken by the applicant to avoid 20 DCMR 209.

The proposed emission limits are as follows:

1. Each of the boilers shall not emit pollutants in excess of those specified in the following tables [20 DCMR 201]:

Boiler Emission Limits per Unit (CU-1 and CU-2)
Pollutant	Short-Term Limit (Natural Gas) (lb/hr)	Short-Term Limit (No. 2 Fuel Oil) (lb/hr)
Carbon Monoxide (CO)	1.43	1.43
Oxides of Nitrogen (NOx)	1.43	4.43
Total Particulate Matter (PM Total)1	0.29	0.91
Sulfur Dioxide (SO2)	0.02	1.25
Volatile Organic Compounds (VOC)	0.21	1.46

¹PM Total includes both filterable and condensable fractions.

1. Visible emissions shall not be emitted into the outdoor atmosphere from either boiler except that discharges shall be permitted for two (2) minutes during any startup, cleaning, adjustment of combustion or operational controls, or regeneration of emission control equipment, provided that such discharge shall not exceed the following opacities (unaveraged) [20 DCMR 606.1 and 606.2]:

1. When burning exclusively natural gas, twenty percent (20%); and

2. When burning fuel oil or a combination of fuel oil and natural gas, twenty seven percent (27%).

1. In addition to the requirements of Condition (b), whenever the boilers are operating using fuel oil, they shall not emit any gases into the atmosphere of gases that exhibit greater than 20 percent opacity (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity. This standard applies at all times except during periods of startup, shutdown, or malfunction. [40 CFR 60.43c(c) and (d)]]
2. Total suspended particulate matter (TSP) emissions from each of the boilers shall not be greater than 0.07 pounds per million BTU. [20 DCMR 600.1].
3. Oxides of nitrogen (NOx) emissions from the boiler shall not exceed:
4. 1. 0.05 pounds per MMBTU based on a calendar day average, on days when the equipment is powered exclusively by natural gas. [20 DCMR 805.5(e)(3)(C)]; and
5. 1. 0.12 pounds per MMBTU based on a calendar day average, on days when the equipment is powered by fuel oil or a combination of fuel oil and natural gas. [20 DCMR 805.5(e)(3)(B)]
      
6. 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 calendar year, not to exceed thirteen (13) months from the date of 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(a)]:
7. 1. As applicable, inspect the burner, and clean or replace any components of the burner as necessary for proper operation;
8. 1. 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;
9. 1. Inspect the system controlling the air-to-fuel ratio and ensure that it is correctly calibrated and functioning properly;
10. 1. 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
11. 1. 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;

If a boiler subject to this requirement is not operating on the required date for a tune-up, the tune-up must be conducted within 30 days of startup. [20 DCMR 805.9(b)]

1. 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 occurs 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)]

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 9:00 A.M. and 5:00 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) 498-8143 or [email protected]. Copies of the draft permit and related technical support memorandum are also available in 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 before taking final action on the permit application.

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, 5^th Floor
Washington, DC 20002

[email protected]

No comments or hearing requests submitted after September 9, 2024 will be accepted.

For more information, please contact Stephen S. Ours at (202) 498-8143.

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