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Capitol Power Plant Proposed Air Quality Permits

Friday, November 16, 2012

Capitol Power Plant Proposed Air Quality Permits

Fiscal Year 2012

Notice of Public Hearing and Public Comment Period

Capitol Power Plant Proposed Air Quality Permits for Plantwide Applicability Limits for NOx and PM2.5, Installation of a Cogeneration Facility, and Operation of Existing Boiler #3

Notice is hereby given that, pursuant to 40 C.F.R. Part 51.161, and D.C. Official Code §2-505, the Air Quality Division (AQD) of the District Department of the Environment (DDOE) located 1200 First Street NE, Washington, DC, intends to issue  a series of air quality permits to the Architect of the Capitol for equipment and operations at the Capitol Power Plant, located at 25 E Street SE, Washington DC, 20003.  The contact person for the facility is Eva Malecki, Public Affairs Officer, Architect of the Capitol, at 202-228-1793.

The proposed air quality permits are summarized in the following table:

Permit Number

Type of Permit

Equipment Covered

Description

6576

Chapter 2 Operating Permit

Boiler #3

Existing 203 MMBTU/hr heat input dual fuel (natural gas and No. 2 fuel oil) boiler.

6577

Plantwide Applicability Limits (PALs) Permit

All facility equipment (seven boilers and miscellaneous other equipment)

This permit would establish plantwide emission limits for oxides of nitrogen (NOx) and fine particulate matter (PM2.5) for the entire Capitol Power Plant facility.

6663-C

Permit to Construct, to be followed by a Permit to Operate (without further public notice)

Combustion Turbine #1 (CT-1) and associated Heat Recovery Steam Generator #1 (HRSG-1)

This permit would allow the construction, and upon completion of construction in accordance with the permit, operation of a 7.5 MW Combustion Turbine, fired on natural gas with No. 2 fuel oil backup, with an associated heat recovery steam generating unit (HRSG) with a duct burner, rated at 71.9 MMBTUs per hour.

6664-C

Permit to Construct, to be followed by a Permit to Operate (without further public notice)

Combustion Turbine #2 (CT-2) and associated Heat Recovery Steam Generator #2 (HRSG-2)

This permit would allow the construction, and upon completion of construction in accordance with the permit, operation of a 7.5 MW Combustion Turbine, fired on natural gas with No. 2 fuel oil backup, with an associated heat recovery steam generating unit (HRSG) with a duct burner, rated at 71.9 MMBTUs per hour.

These permits are being processed together.  While the installation of the combustion turbines and related equipment will likely result in increased emissions from the facility, the PALs permit will limit emissions increases of NOx to less than 25 tons per year and increases of PM2.5 to less than 10 tons per year, the levels defining a “significant” increase in emissions from a facility.  It will also result in a hard cap on emissions from the facility, effectively capping potential emissions of these pollutants from the facility well below previous allowable levels.

Proposed emission limits for the combustion turbines and related equipment to be constructed are as follows:

a.  When burning natural gas, the combined nitrogen oxides (NOX) emissions from each combustion turbine and associated HRSG unit shall not exceed twenty-five parts per million (25 ppm) at fifteen percent oxygen (15% O2) or one hundred fifty (150) nanograms per Joule (150 ng/J) of useful output, equivalent to 1.2 pounds per megawatt-hour (lb/MWh). [40 C.F.R. § 60.4320(a) and Table 1 of Subpart KKKK of 40 C.F.R. § 60]

b.  When burning diesel oil the combined NOX emissions from each combustion turbine and associated HRSG unit shall not exceed seventy four (74) ppm at fifteen percent (15%) O2 or four hundred sixty (460) ng/J of useful output, equivalent to 3.6 lb/MWh. [40 C.F.R. § 4320(a) and Table 1 of Subpart KKKK of 40 C.F.R. § 60]  

c.  When burning diesel oil in combination with natural gas, if total heat input is greater than or equal to fifty percent (50%) natural gas, the owner or operator shall meet the natural gas emission limit for NOX in (a).  If total heat input is greater than fifty percent (50%) diesel oil, the owner or operator shall meet the diesel oil emission limit for NOX in (b). [40 C.F.R. § 60.4325]

d.  Each of the combustion turbines shall comply with one of the following emission limitations for sulfur dioxide (SO2).  [40 C.F.R. § 60.4330(a)]

  1. No discharge of gases to the atmosphere which contain SO2 in excess of one hundred ten (110) ng/J gross output, equivalent to 0.90 lb/MWh; or
  2. No fuel may be burned which contains total potential sulfur emissions in excess of twenty-six (26) ng SO2/J heat input, equivalent to 0.060 lb SO2/MMBtu.

e.  Facility-wide emissions of total hazardous air pollutants (HAPs) shall be less than twenty-five tons per year (25 tpy) on a rolling twelve (12) month basis. [20 DCMR § 201]

f.  Facility-wide emissions of each individual HAP, including hydrogen chloride (HCl), shall be less than ten (10) tpy on a rolling twelve (12) month basis. [20 DCMR § 201]

g.  Permit limits identified in Conditions (e) and (f) will become effective upon the earliest of the following dates:

  1. Initial “startup”, as defined in 40 C.F.R. § 63.2, of either combustion turbine;
  2. One week prior to the first substantive compliance date contained in 40 C.F.R. § 63, Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters, as amended; or
  3. Written notice from the Permittee to the District and EPA invoking the limitations of Conditions (e) and (f) administratively. Subsequently, as long as Conditions (e) and (f) are met by the applicable date above, the facility will be considered an area source of HAPs.   

h.  Visible emissions shall not be emitted into the outdoor atmosphere from these units, except 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 un any twenty-four hour (24 hr.) period during start-up, cleaning, adjustment of combustion controls, or malfunction of the equipment. [20 DCMR § 606.1]

i.  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] Note: This condition is District enforceable only.

j.   In addition to complying with the requirements of this permit document, the Permittee shall comply with all Plantwide Applicability Limits (PALs) established for the facility.

 

The proposed non-attainment pollutant PALs for NOx and PM2.5 are 196.7 tons per year of NOx and 35.4 tons per year of PM2.5.  PALs for attainment pollutants [course particulate matter (PM10), nitrogen dioxide (NO2), and greenhouse gases (GHGs)] are being established through a separate permitting process by direct authority of the U.S. Environmental Protection Agency (EPA).

The permit applications and supporting documentation, along with the draft permits and the Department’s analyses of the applications are all 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 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 permit.

A public hearing will be held at the District Department of the Environment offices at 1200 First Street NE, Washington DC on December 17, 2012 at 5:30 PM.  Interested parties wishing to testify at this hearing must submit in writing their names, addresses, telephone numbers, and affiliation, if any, to Mr. Stephen Ours at DDOE by 4:00 p.m. on Monday, December 17, 2012.

Comments on the proposed permits and requests to testify at the hearing should be addressed to:

Stephen S. Ours - Chief, Permitting Branch                                                                                                                            
Air Quality Division
District Department of the Environment
1200 First Street NE, 5th Floor
Washington DC 20002

Stephen.Ours@dc.gov

No written comments postmarked after December 17, 2012 will be accepted.

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