2010 N O 2 NAAQS (75 F ed. R eg. 6474 )

District of Columbia Infrastructure SIP

May 2014

A TTACHMENT B

Section 110(a)(2)(D)(i) : Interstate Transport Provisions, Part I

Include an explanation in support of the conclusion that no source will contribute significantly to

nonattainment or interfere with maintenance of the SO2 NAAQS in another state.

The District of Columbia (District) was designated as an unclassifiable/at tainment area for the 2010

nitrogen dioxide (N O 2 ) national ambient air quality standards (NAAQS) 1 . This is at least in part

because n o source in the Distr ict contribute s significantly to nonattainment or interfere s with

maintenance of the 2010 N O 2 NAAQS in another state. N o source in the District has ever caused a

violation of the NO 2 NAAQS and no source emits quantities that are potentially of concern.

No N O 2 NAAQS Violations

Currently , the District operates t hree a mbient air monitors to measu re N O 2 : one at the River Terrace

site

, one at the McMillan NCore site , and one at a Takoma site 2

. N one of the monitors ha ve revealed a

violation of the 2010 N O 2 standard

. Figure 1 shows that the District’s design values for NO 2 have

remained well below the annual and 1

- hour NAAQS for years

.

Figure 1 . Monitored NO 2 Concentrations in the District Over Time (parts per billion)

1 Letter from the U.S. EPA to the Honorable Vincent C. Gray (June 29, 2011).

2 The NO 2 monitor at the Takoma School site stopped operating in 2011 due to a building fire. NO 2 monitoring resumed at a

nearby Takoma Recreation Center site in January 2013.CONTINUED: Monitored N O 2 Concentrations in the District Over Time (parts per billion)

Insignificant Contribution (Prong 1)

NO 2 is one component of oxides of nitrogen (NO

x ) and is generally used as an indicator for the larger

group of NO

x . Of all NO

x emissions generated in the Washington DC

- MD

- VA nonattainment area, the

District contributes a nominal portion

– about nine percent (2011 NEI Version 1). This implies that in

general, NO 2 emissions are small.

o Currently, there are no EGUs or other large

industrial sources of NO

x emissions in the

District

.

o The District has only one “ non

- EGU ” facility

with units large enough (>250 mmBTU/hr in

size) to be appli cable under EPA’s NO

x SIP

Call: the U.S. General Services Administration

(GSA).

o The only other source that comes anywhere

close to emitting roughly 100 tons per year is

the U.S. Capitol Power Plant (CPP).Figure 2. Point Source NO

x Emissions in the District (tons per year)

Facility 2008 2009 2010 2011 2012

GSA 193.5 215 214.6 195.5 185.9

CPP 107.1 137.7 106.1 105.5 94.7

All Major Sources 676.1 740.9 944.9 702.9 441.7

Both GSA and CPP have plant

- wide emissions limits in their Title V permits that will continue to at

least cap potential annual NO

x emissions 3 , and thus NO 2 emissions, into the future. Every other major

source currentl y operating in the District has emitted less than 30 tons per year (tpy) of NO

x since 2008.

There is also evidence that emissions of NO 2 will not increase significantly. Because the District was in

serious nonattainment of the 1

- hour ozone NAAQS, CAA anti

- backsliding provisions mean that the

major source permitting threshold for NO

x remains at 25 tpy (20 DCMR § 399). The District’s new

source review prog ram (20 DCMR Chapter 2) and prevention of significant deterioration federal

implementation plan (PSD FIP) will continue to sufficie ntly control emissions due to facility changes

. Additional NO

x controls in the District’s State Implementation Plan (SIP) include NO

x RACT (20

DCMR § 805)

, a high enhanced inspection and maintenance (I/M) program (see 40 C.F.R. § 52.470(c) )

, and numerous Federal NO

x measures

.

No Interference with Maintenance (Prong 2)

There are no nonattainment areas for NO 2 within a 50

- k ilometer radius of the District, which is the

standard distance generally considered by EPA for air dispersion modeling (Appendix W to 40 C.F.R.

Part 51). The m ost recent design values (DVs) computed using quality

- assured and cert ified ambient air

modeling data, based on the Federal Reference Method or an equivalent monitoring measurement, and

reported to EPA’s Air Quality System (AQS) i n states bordering the District are in Figure 3:

Figure 3. Recent Design Values at Monitors in Maryland and Virginia

State County Site 2008

-

2010 2009

-

2011 2010

-

2012

ANNUAL (53 ppb)

MD Baltimore 240053001 13 13 12

MD Baltimore city 245100040 18 18 16

MD Prince George's 240330030

- - 9

VA Arlington 510130020 13 12 12

VA Charles City 510360002 5 6 5

VA Hampton city 516500008

- 5 5

VA Henrico 510870014 11 10 9

VA Loudoun 511071005 8 8 7

3 CPP’s recently approved Title V permit reduced the plant

- wide emission limit from the equivalent of 925 tpy for NO

x down

to 197 tpy for NO

x (see DDOE, “District Issues Air Qua lity Permits for Cogeneration Equipment at the U.S. Capitol Power

Plant” (June 6, 2013), found at: http://ddoe.dc.gov/release/distric t

- issues

- air

- quality

- permits

- cogeneration

- equipment

- us

capitol

- power

- plant ). GSA’s existing Title V permit (as of July 28, 2000) includes annual plant

- wide emissions limits for

NOx of 268 tpy for the Central Heating and Refrigeration Plant (which no longe r exists) and 256 tpy for the West Heating

Plant.State County Site 2008

-

2010 2009

-

2011 2010

-

2012

VA Norfolk city 517100024

- 10 8

VA Prince William 511530009 5 6 5

VA Richmond city 517600024 12 10 10

VA Roanoke 511611004 8 7 7

VA Rockingham 511650003 10 9 9

1

- HOUR (100 ppb)

MD Baltimore 240053001 52 50 48

MD Baltimore city 245100040 57 58 57

VA Arlington 510130020 50 49 47

VA Charles City 510360002 57 55 52

VA Henrico 510870014

- 41 41

VA Loudoun 511071005 40 41 39

VA Prince William 511530009 30 28 28

VA Richmond city 517600024 54 52 51

VA Roanoke 511611004 38 38 39

Source: “Design Values” on EPA website at: http://www.epa.gov/airtrends/values.html ;

only data with completeness determinations

All nearby DVs are well below the NAAQS for NO 2

– none are close to half the annual NAAQS and all

are hovering near or below half the 1

- hour NAAQS

. Since there are also no nearby areas violating the

NO 2 NAAQS, the District has no reason to believe that any monitors identified in the table above may

have d ifficulty maintaining the NO 2 standards, particularly as a result of emissions from the District.

Conclusion

T he District does not have any substantial sources of NO 2 within its borders, nor is not aware of any

plans to establish a ny substantial new source s

. Federally enforceable SIP provisions that limit NO

x , and

thus NO 2 , will prevent emissions from increasing to worrisome levels. Thus, it is reasonable to

conclude that no source in the District will contribute significantly to nonattainment or interfere wi th

maintenance of t he NAAQS in any other state.