Notice of Public Comment Period
Draft Air Quality Permits 7328, 7343, and 7339 - Schuster Concrete Ready Mix LLC – 632 Howard Road SE Site

Notice is hereby given that, pursuant to 20 DCMR § 210, the Air Quality Division (AQD) of the Department of Energy and Environment (DDOE), located at 1200 First Street NE, 5^th Floor, Washington DC, intends to issue permit Nos. 7328, 7339, and 7343 to Schuster Concrete Ready Mix LLC to construct and operate one (1) temporary concrete batch plant with an onboard diesel engine and one (1) emergency generator set, powered by a diesel-fired engine, to be located at 632 Howard Rd SE, Washington DC.

Units to be Permitted

Emission Unit ID	Unit Description	Location	Assigned Chapter 2 Permit Number
Plant #1	CEMCO 150 Truck Mix Concrete Plant	632 Howard Rd SE Washington DC 20020	7328
Plant Gen # 1	One factory mounted (CEMCO) 99 hp John Deere diesel engine, Engine Family 3JDXL06.8116 (Model year 2011)	632 Howard Rd SE Washington DC 20020	7343
# 154 – emergency generator	One MQ Power WhisperWattTM, Model DCA70SSJU, 40 kWe standby generator set powered by a John Deere 4045TF 90 hp Diesel Engine (Model year 2003)	632 Howard Rd SE Washington DC 20020	7339

The contact person for the facility is Sherri Palmer at (443)-738-9921 or [email protected].

The applicant has requested that enforceable limitations on the operation of the portable concrete plant be established in the permit pursuant to 20 DCMR § 201. Specifically, the applicant has requested an operating hour limit for the CEMCO 150 plant at the site of 3,120 hours per 12-month rolling period. Limits on the concrete production rate of 100,000 cubic yards in any 12-consecutive-month period have also been requested for the plant.

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

FACILITY-WIDE EMISSIONS SUMMARY [TONS PER YEAR]
Pollutants	Potential Emissions with Limits
Sulfur Dioxide (SO2)	0.64
Oxides of Nitrogen (NOx)	1.27
Total Particulate Matter (PM Total)	0.74
Particulate Matter < 10 microns in diameter (PM10)	0.27
Volatile Organic Compounds (VOCs)	0.05
Carbon Monoxide (CO)	0.59

With the operational limitations included in the draft permit, the Schuster Concrete Ready Mix LLC facility has the potential to emit approximately 1.04 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 minor source and is not subject to 20 DCMR § 300.1.

Equipment-Specific Emissions Information:

The following units are being permitted through this permitting action. After each table of units, the estimated maximum potential to emit of the equipment and the proposed emission limits are specified.

Portable Concrete Mixing Plant: One (1) portable temporary portable concrete plant with an associated boiler with a heat input rating of 2.78 MMBTU per hour:

Emission Unit ID	Equipment Location	Concrete Plant Model	Rated Production Rate (yd3/hr)	Permit No.
Plant #1	632 Howard Rd SE Washington DC 20020	CEMCO 150	150	7328

Emissions Estimates:

Maximum annual emissions from the portable concrete plant, including stockpile fugitive emissions and emissions from the hot water boiler, assuming 3,210 hours per year of plant operations and 1,000 hours per year of hot water boiler operations (both maximum allowable under the draft permit), are expected to be as follows:

	Maximum Annual Emissions
Pollutant	(tons/yr)
Total Particulate Matter (PM Total)	0.71
Particulate Matter <10 microns in diameter (PM10)	0.27
Sulfur Oxides (SOx)	0.28
Nitrogen Oxides (NOx)	0.23
Carbon Monoxide (CO)	0.35

Emissions Limitations:

a. Emissions of dust shall be minimized in accordance with the requirements of 20 DCMR 605 and the “Operational Limitations” of this permit.

2. The emission of fugitive dust from any material handling, screening, crushing, grinding, conveying, mixing, or other industrial-type operation or process is prohibited. [20 DCMR 605.2]
3. The discharge of total suspended particulate matter (TSP) into the atmosphere from any process shall not exceed three hundredths (0.03) grains per dry standard cubic foot of the exhaust. [20 DCMR 603.1]
4. The discharge of TSP from the portable concrete plant shall not exceed 40 pounds per hour. [20 DCMR 603.1 and Appendix 6-1]
5. TSP emission from the No. 2 fuel-fired boiler shall not exceed 0.13 pound per million BTU of heat input. [20 DCMR 600.1]
6. Visible emissions shall not be emitted into the outdoor atmosphere from stationary sources; provided, that the 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, soot blowing, adjustment of combustion controls, or malfunction of the equipment. [20 DCMR 606.1]
7. 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]

Non-Emergency Compression Ignition Internal Combustion Engine (CI-ICE) subject to New Source Performance Standards (NSPS): One (1) non-emergency diesel-fired engine subject to NSPS (40 CFR 60) Subpart IIII as described in the following table:

Emission Unit ID	Emission Unit Description	Permit No.
Plant Gen #1	One factory mounted (CEMCO) 99 hp John Deere diesel engine, Engine Family BJDXL04.5144 (Model year 2011)	7343

Emissions Estimates:

Maximum annual emissions from the factory mounted 99 hp John Deere diesel engine, operating for the maximum allowable 3,120 hours per year, are expected to be as follows:

	Maximum Annual Emissions
Pollutant	(tons/yr)
Total Particulate Matter (PM Total)	0.03
Sulfur Oxides (SOx)	0.32
Nitrogen Oxides (NOx)	0.82
Volatile Organic Compounds (VOC)	0.04
Carbon Monoxide (CO)	0.20

Emissions Limitations:

1. 1. Emissions from the engine shall not exceed those emission standards specified in following table as tested pursuant to the applicable test methods in 40 CFR 1039, Subpart F [40 CFR Subpart IIII, 40 CFR 60.4204(b), 40 CFR 60.4201(a), 40 CFR 1039 Appendix I]:

Emission Unit ID	Pollutant Emission Limits (g/kW-hr)
	NOx+NMHC†	NOx	NMHC	CO	PM†
Plant Gen #1	3.9			5.0	0.18

^† These values are based on Family Emission Limits specified on the EPA Certificate of conformity.

1. 2. Visible emissions shall not be emitted into the outdoor atmosphere from this engine, 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]
2. 3. In addition to Condition II(b), exhaust opacity, measured and calculated as set forth in 40 CFR 1039.105(b) and 1039.501(c), shall not exceed [40 CFR 60.4201(a) and 40 CFR 60.4204(b)]:
3. 1. 1. 20 percent during the acceleration mode;
      2. 15 percent during lugging mode; and
      3. 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.
4. 4. The Permittee shall comply with the requirements for crankcase emissions, adjustable parameters, prohibited controls, and defeat devices specified in 40 CFR 1039.115

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]

Emergency Generator Set Powered by Compression Ignition Internal Combustion Engines (CI-ICE) subject to New Source Performance Standards (NSPS): One (1) emergency generator set powered by a diesel-fired engine not subject to NSPS (40 CFR 60) Subpart IIII as described in the following table:

Emission Unit ID	Emission Unit Description	Permit No.
#154 – Emergency Generator	One MQ Power WhisperWattTM, Model DCA70SSJU, 40 kWe standby generator set powered by a John Deere 4045TF 90 hp Diesel Engine (Model year 2003)	7339

Emissions Estimates:

Maximum annual emissions from the MQ Power WhisperWatt^TM emergency generator set, operating for the maximum allowable five hundred (500) hours per year, are expected to be as follows:

	Maximum Annual Emissions
Pollutant	(tons/yr)
Total Particulate Matter (PM Total)	0.01
Sulfur Oxides (SOx)	0.05
Nitrogen Oxides (NOx)	0.22
Volatile Organic Compounds (VOC)	0.01
Carbon Monoxide (CO)	0.04

Emissions Limitations:

1. 1. Visible emissions shall not be emitted into the outdoor atmosphere from the generator sets, 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 (24 hr.) period during start-up, cleaning, adjustment of combustion controls, or malfunction of the equipment [20 DCMR 606.1]
2. 2. 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]

DOEE has reviewed the permit applications 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 Nos. 7328, 7339, and 7343 have been prepared.

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. Copies of the draft permit and related technical support memorandum are also 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 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]ov

 

No comments or hearing requests submitted after March 13, 2023 will be accepted.

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