DRAFT: 5/19/15

CITY OF PHILADELPHIA 

Department of Public Health 

Environmental Protection Division 

Air Management Services 

InterOffice Memo 

To: File 

From: Kassahun Sellassie 

Date: May 19, 2015 

Subject: 1997 8-Hour RACT Analysis for Veolia-Energy Efficiency (PA) LLC 

Introduction: 

The Clean Air Act (CAA) requires that moderate (or worse) ozone nonattainment areas implement reasonably 

available control technology (RACT) controls on all major sources of Volatile Organic Compounds (VOC) and 

Nitrogen Oxides (NOx). Philadelphia County is part of the Philadelphia-Wilmington-Atlantic City moderate ozone 

nonattainment area for the 1997 8-hour ozone NAAQS. This document presents the findings of the reevaluation of 

NOx RACT for the 1997 8-hour ozone standard for this facility 

Company Description: 

Veolia Energy Efficiency PA (LLC), which owns and operates a steam generating facility at 2600 Christian Street, 

Philadelphia, PA 19146. The facility has two (2) new 297.91 MMBTU/hr boilers burning natural gas and No.2 fuel 

oil that were installed in 2013. 

Applicability for NOx and VOC RACT: 

Veolia –Schuylkill Station, Energy Efficiency is a major source of NOx due to having potential NOx emissions 

greater than 100 tons per year, the major source threshold in Philadelphia County that is applicable to NOx RACT 

for the 1997 8-hour ozone NAAQS. Veolia Energy Efficiency is also part owner of the adjacent Grays Ferry 

Cogeneration Partnership (GFCP) which owns and operates an electric generating unit facility at 2600 Christian 

Street, Philadelphia, PA 19146. GFCP started operating on July 27, 2000. Equipment used at GFCP includes one 

(1) front wall fired boiler, and one (1) combined cycle combustion turbine (CT). The RACT for GFCP has been 

evaluated in separate memo. They are not a major source of VOC, due to having potential VOC emissions not 

greater than 50 tons per year, the major source threshold in Philadelphia County that is applicable to NOx RACT for 

the 1997 8-hour ozone. Veolia Energy Efficiency is been evaluated for RACT for the first time. 

RACT Evaluation: 

The two 297.91 MMBTU/hr boilers burn natural gas and #2 oil. Each boiler is currently equipped with ULNB. 

Each boiler has the following NOx emission limits, Plan Approval No. 10277A, dated on Feb13, 2013, each on a 

rolling 30-day average: 0.01 lbs/MMBTU while burning gas and 0.08 lbs/MMBTU while burning oil. The boilers 

have a combined NOx emission limit of 52.31 tons per rolling 12-month period, also from Plan Approval No. 

10277A. 

The following were considered possible additional NOx controls as RACT for the boilers: (1) Selective Catalytic 

Reduction (SCR), (2) Ultra Low-NOx Burners (ULNB) and Overfire Air (ULNB with OFA), (3) Selective NonCatalytic Reduction (SNCR), and (4) Low NOx Burners (LNB). 

SCR injects ammonia upstream of a catalyst. NOx, ammonia (NH3), and oxygen (O2) react on the surface of the 

catalyst to form nitrogen (N2) and water (H20). NOx emissions are reduced by around 80% for Boilers #1 and #2. 

ULNB with OFA reduce NOx emissions by around 70% for Boilers #1 and #2 

SNCR reduce NOx emissions by around 55% for Boilers #1 and #2 

LNB are burners designed to create a larger, lower temperature flame. They would reduce NOx emissions by 

around 50% for Boilers #1 and #2. 
5/8/15

The NOx emissions for Boilers #1 and #2 were determined based on the rated capacity of 297.91 MMBTU/hr, 8,760 

hours per year, and a 0.0.08 lbs/MMBTU NOx emission limit. The NOx emissions are 104.4 tons per year for 

Boilers #1 and #2 

The following NOx controls were determined technologically feasible for Boilers #1 and #2. 

Source Control Tec Baseline NOx 

Emissions 

(tpy) 

NOx 

Reduction 

(%) 

NOx 

Reduction 

(tpy) 

Total 

Annualized 

Cost ($) 

Cost 

Effectiveness 

($/Ton) 

Boiler # 1and 

#2 (each) 

SCR 104.4 80 83.52 710,448 8,506 

 OFA 104.4 45 46.98 196,775 4,188 

SNCR 104.4 55 57.42 539,579 9,397 

LNB 104.4 50 52.2 210,359 4,031 

 

All of these control options have been determined economically unreasonable. 

Because ULNB is currently installed on each boiler, it has been determined to be both technically and economically 

feasible for controlling NOx emissions of Boilers #1 and #2. 

ULNB has been determined RACT for each boiler. The plan approval NOx emission limits of 0.01 lbs/MMBTU on 

a rolling 30-day average while burning gas and 0.08 lbs/MMBTU on a rolling 30-day average while burning oil 

have been determined RACT. The separate startup and shutdown emission limits are not on a rolling 30-day 

average, do not affect the rolling 30-day emission limits, and are not being carried into RACT. 

Conclusions and Recommendations: 

- AMS has determined that the existing controls for Boilers #1 and #2 (ULNB) is NOx RACT for the 1997 

8-hour ozone standard for Veolia Energy Efficiency LLC. The emission limitations for Boilers #1 and #2 is 

0.08 lbs of NOx/MMBTU on a rolling 30-day average when firing oil and 0.01 lb of NOx/MMBTU on a 

rolling 30-day average when firing gas. The facility shall monitor and record compliance based on NOx 

CEMs for Boilers #1 & #2. 

5/19/15

Edward Wiener, Chief of Source Registration Date 
5/8/15

RACT Calculations for Veolia-Energy Efficiency LLC- Boilers #1 and #2

Table 1- Detailed Calculations for SCR on Boilers #1 and #2 

 SCR, 297.91 MMBTU/hr Each Total capital Cost

Total Capital Investment Cost 

(TCI) 

$2,650,722 Based EPA Cost Control Manual of 

$6000/MMBTU/Hr. Escalate 1997 $ using 

the Marshall and swift Index (page 2-3) 

Capital Recovery $423,585 0.1598 20 yrs @15% CRF=0.15981

 

Annual Operating Costs 

Direct Annual Cost1 

Electricity Cost2 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr 

Operator1 $16,425 0.5hr/shift, 3 shift/day, $30/hr 

Supervisor1 $2,463.75 15% of Operator 

Maintenance1 $19,162.50 0.5hr/shift, 3 shift/day, $35/hr 

Material1 $19,162.50 100% of Maintenance 

Ammonia $39,476 Ammonia 

Cost=(17/30)*2/2moles*1.05*104.4*410*1.

55 

 

Annual Catalyst Replacement 

Cost1

$11,466 Catalyst Cost1

= $70,000 

Sinking Fund Factor = 0.1638 for 10% and 

5 years 

Total Direct Annual Cost $169,337 

 

Indirect Annual Cost 

Overhead $11,498 60% of maintenance-OAQPS1

Administrative Charge3 $53,014 2% of TCI-OAQPS1

Property Taxes3 $26,507 1% of TCI-OAQPS1

Insurance3 $26,507 1% of TCI-OAQPS1

 

Total Indirect Annual Cost $117,526 

 

Total Annual Operating Costs $710,448 

 NOx Baseline Emissions (TPY) 104.4 Based on the rated capacity of 

297.91MMBTU/hr, 8,760 hours per year, 

and a 0.08 lbs/MMBTU NOx emission 
5/8/15

limit. 

NOx Emission Reduction (TPY) 83.52 Based on 80 % of NOx removed 

Cost Effectiveness ($/ton NOx 

removed) 

$8,506 

Table 2- Detailed Calculations for OFA on Boilers #1 and #2 

Total Capital Investment 

Cost (TCI) 

$290,108 TCI from original BART proposal from 

Veolia plus inflation adjustment . 

Capital Recovery $46,359 0.1598 20 yrs @15% CRF=0.15981

Annual Operating Costs 

Direct Annual Cost 

Electricity Cost $70,080 100kw @ $0.08/kwh, 8760 hrs/yr (PA DEP 

RACT State Implementation Plan (SIP) 

revision, Sep, 2006, page 18) 

Operator $16,425 0.5hr/shift, 3 shift/day, $30/hr 

Supervisor $2,463.75 15% of Operator 

Maintenance $19,162.50 0.5hr/shift, 3 shift/day, $35/hr 

Material $19,162.50 100% of Maintenance 

Total Direct Annual Cost $127,294 

 

Indirect Annual Cost 

Overhead $11,498 60% of maintenance-OAQPS1

Administrative Charge $5,802 2% of TCI-OAQPS1

Property Taxes $2,901 1% of TCI-OAQPS1

Insurance $2,901 1% of TCI-OAQPS1

              

Total Indirect Annual Cost $23,102 

 

Total Annual Operating Costs $196,775 

 

NOx Emission Reduction 

(TPY) 

46.98 

Cost Effectiveness ($/ton NOx 

removed) 

$4,188 
5/8/15

Table 3 Detailed Calculations for SNCR on Boilers #1 and #2 

 SNCR 297.91 each MMBTU/hr each Total capital Cost

Direct Capital Cost 

$1,558,993 Based EPA Cost Control Manual 

(($950/mmmbtu/hr)*Qb(MMBTU/hr)*(2375 

MMBTU/hr/Qb)^0.557*(0.66 + 0.85 uNOx). 

Qb= bolier size (mmbtu/hr); n = NOx removal 

efficiency (page 1-31) 

Indirect Capital Cost 311,799 Based on EPA Cost Manual page 2-6 

 

Total Capital Investment Cost 

(TCI) 

$1,870,792 

Capital Recovery (annual cost) $298,953 0.1598 20 yrs @15% CRF=0.15981

 

Annual Operating Costs 

Direct Annual Cost 

Electricity Cost $70,080 100kw @ $0.08/kwh, 8760 hrs/yr (PA DEP 

RACT State Implementation Plan (SIP) 

revision, Sep, 2006, page 18) 

Operator $16,425 0.5hr/shift, 3 shift/day, $30/hr 

Supervisor $2,463.75 15% of Operator 

Maintenance $19,162.50 0.5hr/shift, 3 shift/day, $35/hr 

Material $19,162.50 100% of Maintenance 

Ammonia $39,476 Ammonia 

Cost=(17/30)*2/2moles*1.05*104.4*410*1.55 

Total Direct Annual Cost $166,769 

 

Indirect Annual Cost 

Overhead $11,498 60% of maintenance-OAQPS1

Administrative Charge $31,180 2% of TCI-OAQPS1

Property Taxes $15,590 1% of TCI-OAQPS1

Insurance $15,590 1% of TCI-OAQPS1

 

Total Indirect Annual Cost $73,857 

 

Total Annual Operating Costs $539,579 

 

NOx Emission Reduction (TPY) 57.42 

Cost Effectiveness ($/ton NOx 

removed) 

$9,397 
5/8/15

Table 4 Detailed Calculations for LNB on Boilers #1 and #2 

Total Capital Investment Cost 

(TCI) 

$358,370 TCI from original BART proposal from 

Veolia plus inflation adjustment. 

Capital Recovery $57,268 0.1598 20 yrs @15% CRF=0.15981

Annual Operating Costs 

Direct Annual Cost 

Electricity Cost $70,080 100kw @ $0.08/kwh, 8760 hrs/yr (PA DEP 

RACT State Implementation Plan (SIP) 

revision, Sep, 2006, page 18) 

Operator $16,425 0.5hr/shift, 3 shift/day, $30/hr 

Supervisor $2,463.75 15% of Operator 

Maintenance $19,162.50 0.5hr/shift, 3 shift/day, $35/hr 

Material $19,162.50 100% of Maintenance 

Total Direct Annual Cost $127,294 

 

Indirect Annual Cost 

Overhead $11,498 60% of maintenance-OAQPS1

Administrative Charge $7,167 2% of TCI-OAQPS1

Property Taxes $3,584 1% of TCI-OAQPS1

Insurance $3,584 1% of TCI-OAQPS1

              

Total Indirect Annual Cost $25,832 

 

Total Annual Operating Costs $210,359 

 

NOx Emission Reduction 

(TPY) 

52.2 

Cost Effectiveness ($/ton NOx 

removed) 

$4,031 
5/8/15

References

1. Office of Air Quality Planning and standards (OAQPS), Environmental Protection 

Agency (EPA) Air Pollution Control Manual, Sixth Edition, EPA/452/B-02-001, January 

2002. 

2. Electricity cost: EPA cost manual, Appendix A-NOx Control Analysis 

3. Capital Recovery = Convert from P (present) to A(Annual amount), A=P(A/P,i%,n), 

(1 ) 1

(1 )

 

  n

n

i

i i CR 15% interest and 20 yrs = A/P=0.1598; Annual Cost =TCI * CFR 

4. Catalyst Cost of SCR: The catalyst life is 5 years. The annual cost is given by the sinking 

fund factor (SFF). The SFF is the amount of money the facility will need to set aside each 

year to be able to replace the catalyst at the end of its life, based on the lifespan of the 

catalyst and the interest rate. 

5. SFF = Convert from F (Future) to A(Annual amount), A=F(A/F,i%,n), 

(1 ) 1  n i

i SFF 10% interest and 5 yrs = A/F=0.1638 

Where i= Annual interest Rate (10%); n= catalyst system life (5 years); 

Catalyst Annual Cost = SFF x Catalyst Cost 

6. Ammonia Cost: 

2NH3 + 2NO + 1/2O2 2N2 + 3H2O 

Annual Ammonia Cost = (17/30 * 2moles of NH3/2 moles of NO *1.05 * NOx emission (tpy) *$410/ton 

yrs x 1.55) 

NH3 = Ammonia, NO = Nitric Oxide; O2 = Oxygen; H2O = Water; 1.05= Ammonia slip and excess 

ammonia, 55% cost increament)