Document gaegx8zZkdkYwnw31pjw4Mwgq
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III
Four Penn Center - 1600 John F Kennedy Blvd Philadelphia, Pennsylvania 19103-2852
Report Title: Inspection Date(s): Regulatory Program(s):
Clean Air Act Inspection of Armed Forces Retirement Home 02/02/2023 NESHAP, MACT, NSPS
Company Name: Facility Name: Facility Location:
Latitude: County/Parish:
Armed Forces Retirement Home Armed Forces Retirement Home 3700 North Capital Street NW Washington, D.C. 20317 38.936555 Washington D.C.
Longitude: -77.006885
AFS Number: Permit Number: NAICS Code: Unique Project #:
DC0000001100100011 017-R3-A1 62331 3E23CA018A
SIC: 8059
Facility Representatives:
Susan Bryhan, Administrator
Phone: 202-541-7534 Contact:
Susan.Bryhan@afrh.gov
Troy Phillips, Facilities Maintenance Project Manager
Phone: 202-437-5119 Contact:
N/A
Sunhee Park, EA Engineering
Phone: 443-765-1234 Contact:
spark@eaest.com
Patrick Benjamin, Campus Operations
Phone 202-445-0513 Contact:
Patrick.Benjami@afrh.gov
EPA Inspectors:
Carly Joseph, Air Inspector & Compliance Officer, 3ED21
Phone: 215-814-2127 Contact:
Joseph.Carly@epa.gov
Kim Laufenberg, Air Inspector & Compliance Officer, 3ED21
Phone: 215-814-2265 Contact:
Laufenberg.Kim@epa.gov
State/Local Inspectors:
Atakilti Tesfai, Environmental Engineer, DOEE
Phone: 202-671-5139
Contact: Tesfai.Atakilti@dc.gov
Ryan Insley, Environmental Engineer, DOEE
Phone: 202-400-0701
Contact: Ryan.Insley@dc.gov
Joseph,
Digitally signed by Joseph, Carly
EPA Lead Inspector
Carly
Date: 2023.03.22 11:24:34 -04'00'
Signature
Carly Joseph
EPA Region III Environmental Center- Suite 5350
701 Mapes Rd (3ED21)
Ft. Meade, MD 20755-5350
KRISTEN
Digitally signed by KRISTEN HALL
Supervisor
HALL
Date: 2023.03.23 06:24:32 -04'00'
Signature
Kristen Hall
Point of Contact
Date
Date
Section
Table of Contents
Page
I Introduction............................................................................ 3 A Summary of the Facility.................................................................................. 3 B Inspection Opening Conference...................................................................... 3
II Site Activity/Process Information.................................................................... 4
III Observations.................................................................................................... 5
IIII Records Review............................................................................................... 5
V Closing Conference......................................................................................... 8
VI List of Attachments.......................................................................................... 9
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I. Introduction
The United States Environmental Protection Agency (EPA) conducted a Clean Air Act (CAA) inspection at Armed Forces Retirement Home (AFRH or Facility) to verify compliance with applicable state and federal regulations. The Department of Energy and Environment (DOEE) was notified of the inspection on January 18, 2023, via email. On January 31, 2023, EPA notified the Facility of the planned inspection via phone and email. EPA emailed a list of records for review to Susan Bryhan, the Facility's Administrator, prior to the inspection (see Attachment 1). These records are listed in the Records Review section of the report.
A. Summary of the Facility
The Facility is located at 3700 North Capital Street NW, Washington, D.C. 20317. As stated on the company's website (https://www.afrh.gov/), "Armed Forces Retirement Home is the nation's premier life community for certain retired and former members of America's armed forces and their spouses".
The Facility received a Title V Operating Permit (Permit Number 017-R3-A1) from DOEE issued on January 24, 2018. AFRH applied for a synthetic minor permit in 2023 requesting an enforceable propane limit to lower the Facility's NOx emissions
Armed Forces Retirement Home is classified as major source for NOx. The Facility is subject to or potentially subject to the following federal regulations:
40 C.F.R. Part 60 Subpart IIII: New Source Performance Standards for Stationary Compression Ignition Internal Combustion Engines (NSPS 4I)
40 C.F.R. Part 60 Subpart JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (NSPS 4J)
40 C.F.R. Part 63 Subpart ZZZZ: National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (MACT 4Z)
B. Inspection Opening Conference
At 9:10 AM on February 2, 2023, EPA inspectors arrived at the Facility for a CAA Inspection and conducted a brief opening conference. Armed Forces Retirement Home was represented by Susan Bryhan, Facility Administrator; Troy Phillips, Facilities Maintenance Project Manager; Sunhee Park, Engineer; and Patrick Benjamin, Campus Operations. In addition to the EPA Region III inspectors, Tesfai Atakilti and Ryan Insley, from DOEE were present for the opening conference. EPA inspectors, Carly Joseph and Kim Laufenberg, presented their credentials and explained the purpose of the visit was to conduct a CAA inspection to determine compliance with their permit and any applicable regulations. Additionally, EPA informed the Facility representatives of their right to claim any confidential business information (CBI). At that time,
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Susan Bryhan did not claim any photos or documentation obtained during the inspection as CBI. Susan Bryhan submitted the signed CBI form to EPA via email on February 9, 2023.
II. Site Activity/Process Description
Riggs Farmland originally occupied the land before AFRH acquired the property. AFRH is currently comprised of 272 acres but once occupied over 500 acres. The land is currently shared with a Catholic University, a D.C. Charter School, and two chapels. Multiple parts of the campus are considered historical such as the Lincoln Cottage. The Facility consists of several buildings including: Scott Building, which was built in 2013; Sheridan Building, which was built in the 1960's and renovated in early 1990; Headquarters Building, which is partially rented out to the Catholic school; Security Building; and a Power Plant, which is no longer operational. The Facility also contains of a golf course and several ponds.
AFRH was established in 1851 as the Old Soldiers' Home. AFRH consists of two campuses: one in Washington D.C. and the other in Gulfport, Mississippi. The Facility is a Continuing Care Retirement Community only for enlisted duty retirees, injuries, and their spouses. Residents pay a fee based on their salary. In 1991, the AFRH became an independent Federal Agency funded from enlisted men and women serving in the U.S. Armed Forces and a trust fund that has operated since the AFRH was established. Congress allocates and Department of Defense (DOD) has oversight of these funds.
The Facility provides four levels of care: independent living, assisted living, memory support, and long-term care. There are currently 214 residents. The campus can support up to 500 residents with rooms of approximately 300 square feet each. All the food is cooked and prepared for residents in the Scott Building. AFRH has approximately 155 employees consisting of both health care providers and security. There are three shifts available, with employees generally working 5 days per week from 6:30 AM - 4:00 PM.
The Facility operates several boilers, emergency generators, and fuel tanks. There are currently 14 boilers, 5 emergency generators, and 5 fuel storage tanks used on-site. By building, the units were discussed and broken down below:
Scott Building o 2 Emergency Generators (B13 & B14) o 1 Propane Fuel Storage Tank (C23, 12,000-gallons) o 2 Comfort Heat Boilers (A26 & A27) o 3 Domestic Water Heaters (A37-A39)
Sheridan Building o 1 Emergency Generator (B5) o 2 Fuel Storage Tanks (C22 - propane, 12,000-gallons; C11 - diesel, 600-gallons) o 6 Domestic Water Heater (A28 - A33)
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North Converter o 3 Domestic Water Heaters (A34 - A36)
Sherman Building o 1 Emergency Generator (B11) o 1 Diesel Fuel Storage Tank (C21, 500-gallons)
Security Building o 1 Emergency Generator (B12) o 1 Diesel Fuel Storage Tank (C15, 110-gallons)
Eagle Gate o 1 Emergency Generator (B15)
The Facility representatives noted there are no newly installed units at AFRH, since 2019, and the emergency generator, B12, was decommissioned in 2017. The Facility also mentioned previous deviations including losing a feeder for five hours which affected the operation of the emergency generators (B13, B14, and B15). Propane is only to be used for alternative fuel testing. For regular maintenance and testing at AFRH, stack tests were conducted on emergency generators (B13 and B14) on October 31, 2022 and November 1, 2022, which was recently submitted to DOEE. Inspections of all the boilers are conducted annually. Operational hours for the emergency generators are logged and tracked via Excel utilizing the hour meters. Maintenance on the generators is completed by a 3rd party contractor. AFRH utilizes a checklist for the both the monthly generator and tank inspections. The Facility monitors the double-walled tank levels utilizing a monitor and the MyTank program.
The opening conference concluded at 10:07 AM.
IV. Observations
EPA inspectors were led on a walkthrough of the Facility at 10:10 AM by Sunhee Park and Patrick Benjamin of Armed Forces Retirement Home. Tesfai Atakilti and Ryan Insley of DOEE were also present for the walkthrough. EPA inspectors noted Kim Laufenberg would take photos during the Facility walkthrough (Attachment 2).
The inspection team began the walkthrough by exiting the meeting room located in Scott Building and taking an elevator to the fourth floor. The team observed natural gas fired emergency generator, B13, with 331 hours as indicated on its hours meter and B14 with 276.7 hours. Next, the inspection team observed boilers A26, A27, A37, A38, and A39 located on the fourth floor of Scott Building. Units A26 and A27 were noted to be comfort heat boilers, while units A37- A39 were comfort heating domestic hot water boilers. The inspection team then took the elevator to the first floor of the Scott Building and went outside to observe a 16,000-gallon underground propane tank. Water was seen over top the 16,000-gallon underground storage tank.
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Inspectors were unable to view the tank's identification label/plate. Patrick Benjamin indicated the accumulation of water was likely due to the recent rain events in the area. The inspection team then proceeded to the Sheridan Building to observe the boiler room. Inspectors viewed six boilers (A28-A33) which AFRH utilizes for comfort heat. Walking outside the Sheridan Building, C22, a 16,000-gallon underground propane tank was observed. Again, the identification label/plate for the unit could not be located. The inspection team then observed emergency generator, B5, which was observed to have 264.9 hours indicated on its hours meter.
The inspection team walked over to North Converter Building and observed comfort boilers, A34- A36. The inspection team continued to outside the Administrative Building where the emergency generator, B11, was observed. 3,598 hours was noted from hours meter. Next, the inspection team observed a 500-gallon diesel tank. Lastly, the inspection team observed the emergency generator, B12, with 240.2 hours indicated on its hours meter. It was stated the unit was decommissioned in 2017. EPA inspector, Kim Laufenberg, inquired whether there were any plans of removing B12 in the near future. Patrick Benjamin (AFRH) and Tesfai Atakilti (DOEE) indicated there are currently no plans of removing the unit from the campus.
The walkthrough concluded at 11:47 AM.
IV. Records Review
The records review commenced immediately after the plant walkthrough at 11:50 AM. EPA inspectors reviewed documents requested in the January 31, 2023, email to Susan Bryhan (see Attachment 1). Some records were provided at the time of the inspection by Sunhee Park. Below are the records requested and what was provided:
1. Provide a copy of the most recent Title V Permit issued by DOEE. Electronic copy dated August 30, 2021, submitted via email 2/9/2023.
2. Provide a hardcopy and electronic copy of a Facility plot plan which identifies the process units and associate emission points. AFRH provided a hard copy of the Facility plot plan on 2/2/2023. Site map also submitted electronically via email on 2/9/2023.
3. See the attached Excel spreadsheet related to all combustion sources at the Facility such as generators and boilers (`Combustion Unit' tab), which can be used to provide the following information. Completed Excel Spreadsheet provided copies of logs including operating hours and fuel consumption amounts provided for years 2019 to 1st half of 2022 via email on 2/9/2023. a. For each engine and/or boiler identified, provide: i. Unit description(s), ii. Make and number numbers, iii. Location of source(s), iv. Dates of installation (and potential removal), v. Fuel(s) combusted, vi. Applicable regulation(s),
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vii. Emission control(s), viii. Maximum heat input rating (MMBtu or kW/hr); b. Additionally, for each combustion source at the Facility (including boilers, emergency generators, fire pumps, etc.) on a monthly basis for the past 4 years, include:
i. Hours of operation (hrs); ii. Amount of fuel combusted (gallons, MSCF, etc.). 4. See the attached spreadsheet, `Stack Test' tab, which can be used to provide the following information. For each combustion unit provide the following information on any performance test completed in the past 4 years: Electronically submitted Stack Test Report for Units B13 and B14 tested October 31, 2022, and November 1, 2022. a. Date of each test, b. Test method(s) utilized, c. Each pollutant tested and the emission result (lb/hr, ton/yr, etc.), and d. Identify if the test was conducted for informational purposes or to determine compliance. 5. Identify any combustion units which are equipped with continuous emission monitoring systems (CEMS). See the `CEMS' tab of the attached Excel spreadsheet which can be used to provide the following information. For each unit that has a CEMS, provide: Not provided and stated as not applicable to AFRH. a. The date the CEMS was installed, b. Pollutants monitored, and c. Date of last relative accuracy test (RATA). 6. For each fuel tank (gasoline and propane), provide: a. Manufacturer specifications and design drawings, b. Monthly fuel throughput amounts (gallons) for the past 4 years, c. Leak records (testing and deviations) for the past four years. 7. Each exceedance of a permit condition for the past 4 years containing the following details: Stated as not applicable to AFRH. Reported no exceedances. a. Subject source, b. Time and date, c. Cause, d. Duration, e. Estimated rate of emissions, and f. Proposed corrective action. 8. Provide calculations of the potential to emit (PTE) for NOx, SO2, VOCs, PM, and HAPs for each combustion unit and facility wide along with supporting calculations for the previous 24 months (lbs/hr). These calculations should include each emission factor and its derivation (e.g., stack test, CEMS, AP-42, etc.). Submitted PTE calculations updated in 2023 for AFRH's synthetic minor permit application via email on 2/9/2023. 9. Provide copies of any emission statements submitted to DOEE for 2019 through 2023 including emissions of NOx, SO2, PM, VOCs, and HAPs. Also, provide calculations for the actual emissions generated and reported. Provided plant wide emission calculations for years 2019-2021 via email on 2/9/2023.
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10. Provide copies of any enforcement actions issued to Armed Forces Retirement Home by either EPA or DOEE for the past 4 years. Provided enforcement documents relating to an Administrative Order: DOEE-A-50001680 issued on 11/10/2021 for failure to conduct timely stack test. Records were provided electronically via email on 2/9/2023.
11. Provide copies of any initial notifications or notifications of compliance status submitted to EPA or DOEE by Armed Forces Retirement Home for any applicable regulation under 40 C.F.R. Parts 60 or 63. This includes, but is not limited to, 40 C.F.R. Part 60 Subparts Da, Db, Dc, IIII, JJJJ, KKKK and 40 C.F.R. Part 63 Subparts GG, YYYY, ZZZZ, DDDDD and JJJJJJ. B5, B11 and B12 are exempt from initial notification requirement as existing emergency stationary RICE per 63.6645(a)(5). AFRH stated all boilers are natural gas fired boilers exempt from NESHAP JJJJJJ regulation. Initial notifications for the emergency generators, B13 and B14, per NSPS JJJJ were not documented, but was reported in the semi-annual report for the reporting period from January 1 to June 30, 2013. AFRH provided a copy of this report via email on 2/9/2023.
12. Provide copies of any quarterly, semiannual, and annual reports submitted by the Facility to EPA and DOEE for any applicable regulation under 40 C.F.R. Parts 60 & 63 for the past 4 years. Annual compliance certifications for 2020-2021 and semi-annual compliance certification for 2020-2022 were provided via email on 2/9/2023.
V. Closing Conference
After the records review, EPA inspectors, DOEE inspectors, and Sunhee Park and Patrick Benjamin of Armed Forces Retirement Home had a brief closing conference to ask additional questions and discuss observations. The EPA inspectors noted that the investigation is on-going, and any areas of concern identified in the final reports do not necessarily reflect a violation or deviation, rather, they are areas that will require further investigation. EPA also noted that they would issue an inspection report within in 60 days, with a copy to the District. Simultaneously, EPA will perform a detailed review of records and may have additional questions. The inspection concluded at 12:22 AM.
No areas of concern were noted at the closing conference. EPA informed AFRH that they would be receiving a GoAnywhere portal link, on February 3, 2023, to submit their outstanding records including: manufacturer specifications for the AFRH's underground storage tanks, fuel (gasoline and diesel) delivery records, records of DOEE's administrative orders, and all applicable initial notifications.
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VI. List of Attachments
Attachment 1:
Email correspondence to Susan Bryhan of records requested to review during inspection
Attachment 2: Photo Log
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From: To: Cc: Subject: Date: Attachments:
Susan Bryhan
Joseph, Carly
Atakilti, Tesfai (DOEE); Laufenberg, Kim; Insley, Ryan (DOEE); Patrick.Benjamin
Re: EPA Armed Forces Inspection February 2, 2023
Tuesday, January 31, 2023 10:09:24 AM
4pillars-poster.png Armed Forces Retirement - Records Request.docx Armed Forces Combustion Source List - Spreadsheet Response.xlsx
Message received, we will expect you on Thursday at 0900. Please come to the Scott Building to check in. I've attached our 4 Pillars check in requirements. Thanks!
V/r, Susan Bryhan
Susan Bryhan, FACHE | Administrator, Armed Forces Retirement Home-Washington 3700 N Capitol St NW | Washington, DC 20011 | (O) 202-541-7534 (F) 202-541-7583
Visit the AFRH website: www.afrh.gov Like us on Facebook: www.facebook.com/AFRH.gov
CONFIDENTIALITY NOTICE: This message (including any attachments) is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. This document may contain information covered under the Privacy Act, 5 USC 522(a), and/or the Health Insurance Portability and Accountability Act (PL104-191) and its various implementing regulations and must be protected in accordance with those provisions. Healthcare information is personal and sensitive and must be treated accordingly. If this correspondence contains healthcare information it is being provided to you after appropriate authorization from the patient or under circumstances that don't require patient authorization. You, the recipient, are obligated to maintain it in a safe, secure and confidential manner. Redisclosure without additional patient consent or as permitted by law is prohibited. Unauthorized re-disclosure or failure to maintain confidentiality subjects you to application of appropriate sanction. If you have received this correspondence in error, please notify the sender at once and destroy any copies you have made.
From: Joseph, Carly <Joseph.Carly@epa.gov> Sent: Tuesday, January 31, 2023 9:56 AM To: Susan Bryhan <Susan.Bryhan@afrh.gov> Cc: Atakilti, Tesfai (DOEE) <tesfai.atakilti@dc.gov>; Laufenberg, Kim <laufenberg.kim@epa.gov>; Insley, Ryan (DOEE) <Ryan.Insley@dc.gov>
Subject: EPA Armed Forces Inspection February 2, 2023
Dear Mrs. Sharon Bryhan: As discussed on our voice message and later over the phone today, EPA Region 3 will be conducting a Clean Air Act (CAA) inspection of Armed Forces Retirement Home this Thursday, February 2, 2023. My colleague, Kim Laufenberg, and I anticipate arriving at 3700 North Capitol Street NW, Washington, D.C around 9:00 AM. We will be sure to bring our vaccine cards and wear masks as required by the Facility. The scope of the inspection will include, but may not be limited to: a brief opening conference reviewing historical operations and overview of the facility's processes, a facility walkthrough (during which photographs will be taken), and a review of records requested (see attached). The Department of Energy & Environment (DOEE) has been notified of the inspection and state inspectors, Atakilti Tesfai and Ryan Insley, plan to attend. To help facilitate the inspection, it would be appreciated if the records in the attached document were made available for review. Please confirm receipt of this message and don't hesitate to contact me with any questions. Sincerely,
Carly Joseph
US Environmental Protection Agency, Region III Enforcement and Compliance Assurance Division Air Section (3ED21) 4 Penn Center, 1600 JFK Blvd Philadelphia, PA 19103 (215) 814-2127 joseph.carly@epa.gov
ENFORCEMENT CONFIDENTIALITY NOTICE: This transmission is intended to be delivered only to the named addressee(s) and may contain information that is confidential, proprietary, attorney work-product or attorney-client privileged. If this information is received by anyone other than the named addressee(s), please notify the sender immediately, by reply e-mail and/or by telephone, to obtain instructions as to the disposal of the transmitted material. In no event shall this material be read, used, copied, reproduced, stored or retained by anyone other than the named addressee(s), except with the express written consent of the sender or the named addressee(s). Thank you.
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CONFIDENTIALITY NOTICE: This message (including any attachments) is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is proprietary, privileged or confidential or otherwise legally exempt from disclosure. If you are not the named addressee, you are not authorized to read, print, retain, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately by e-mail and delete all copies of the message.
APPENDIX B: PHOTO LOG
Facility: Armed Forces Retirement Home Location: 3700 North Capitol Street NW, Washington, DC 20317 Inspection Date: 2/2/2023 EPA Inspector(s): Carly Joseph Photographer: Kim Laufenberg
Photo Number: DSC00346 Photo Description: B13 Scott Building Emergency General Hours Meter
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Photo Number: DSC00347 Photo Description: B13 Scott Building Emergency General Hours Meter
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Photo Number: DSC00348 Photo Description: B13 Scott Building Generator Label
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Photo Number: DSC00349 Photo Description: B14 Scott Building Generator Hours Meter
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Photo Number: DSC00350 Photo Description: B14 Scott Building Generator Label
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Photo Number: DSC00351 Photo Description: Scott Building Generator Room Overview
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Photo Number: DSC00352 Photo Description: A26 Scott Building Comfort Boiler Label
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Photo Number: DSC00353 Photo Description: A27 Scott Building Comfort Boiler Label
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Photo Number: DSC00354 Photo Description: A39 Scott Building Hot Water Boiler Label
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Photo Number: DSC00355 Photo Description: A39 Scott Building Hot Water Boiler Label
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Photo Number: DSC00356 Photo Description: A38 Scott Building Hot Water Boiler Label
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Photo Number: DSC00357 Photo Description: A37 Scott Building Hot Water Boiler Label
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Photo Number: DSC00358 Photo Description: Scott Building Boiler Room Overview
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Photo Number: DSC00359 Photo Description: C23 12,000-Gallon Scott Building Propane Tank
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Photo Number: DSC00360 Photo Description: A28 Sheridan Building Domestic Water Boiler Label
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Photo Number: DSC00361 Photo Description: A29 Sheridan Building Comfort Water Boiler Label
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Photo Number: DSC00362 Photo Description: A30 Sheridan Building Comfort Water Boiler Label
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Photo Number: DSC00363 Photo Description: A31 Sheridan Building Comfort Water Boiler Label
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Photo Number: DSC00364 Photo Description: A32 Sheridan Building Comfort Water Boiler Label
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Photo Number: DSC00365 Photo Description: A33 Sheridan Building Comfort Water Boiler Label
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Photo Number: DSC00366 Photo Description: Sheridan Building Boiler Room Overview
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Photo Number: DSC00367 Photo Description: C22 12,000-Gallon Sheridan Building Propane Tank
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Photo Number: DSC00368 Photo Description: B5 Sheridan Building Generator Hours Meter
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Photo Number: DSC00369 Photo Description: B5 Sheridan Building Generator Label
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Photo Number: DSC00370 Photo Description: C11 600-Gallon Diesel Tank for B5 Sheridan Building Generator
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Photo Number: DSC00371 Photo Description: B5 Sheridan Building Generator Overview
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Photo Number: DSC00372 Photo Description: A34 North Building Converter Boiler Label
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Photo Number: DSC00373 Photo Description: A35 North Building Converter Boiler Label
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Photo Number: DSC00374 Photo Description: A36 North Building Converter Boiler Label
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Photo Number: DSC00375 Photo Description: North Building Boiler Room Overview
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Photo Number: DSC00376 Photo Description: B11 Sherman Building Generator Hours Meter
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Photo Number: DSC00377 Photo Description: B11 Sherman Building Generator Label
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Photo Number: DSC00378 Photo Description: C21 500-Gallon Diesel Tank for B11 Sherman Building Generator
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Photo Number: DSC00379 Photo Description: B11 Sherman Building Generator Overview
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Photo Number: DSC00380 Photo Description: B12 Security Building Decommissioned Generator Hours Meter
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Photo Number: DSC00381 Photo Description: B12 Security Building Decommissioned Generator Label
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Photo Number: DSC00382 Photo Description: B12 Security Building Decommissioned Generator Overview
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