CITY OF PHILADELPHIA

DEPARTMENT OF PUBLIC HEALTH

AIR MANAGEMENT SERVICES

RACT PLAN APPROVAL

Effective Date: February 9, 2016

Expiration Date: None

Replaces Permit No. RACT Plan Approval issued on January 9, 2015

In accordance with provisions of the Air Pollution Control Act, the Act of January 8, 1960, P.L. 2119, as amended, and after due consideration of a Reasonably Available Cont rol Technology (RACT) proposal received under the Pennsylvania Code, T itle 25, Chapter 129.91 thru 129.95, of the rules and regulations of the Pennsylvania Department of Environmental Pr otection (PADEP), Air Management Services (AMS) approved the RACT proposal of the Facility below for the s ource(s) listed in section

1.A. Emission Sources of the a ttached RACT Plan Approval.

Facility: Veolia Energy Philadelphia – Schuylkill Station

Permittee: Veolia Energy Philadelphia, Inc Location: 2600 Christian Street, Philadelphia, PA 19146 Mailing Address: 2600 Christian Street, Philadelphia, PA 19146 SIC Code(s): 4961

Plant ID: 4942

Facility Contact: Floyd Rupple Phone: (267) 350-5865

Permit Contact: Floyd Rupple Phone: (267) 350-5865

Responsible Official: Michael J Smedley

Title: VP and GM

2/9/2016 Edward Wiener, Chief of S ource Registration DateRACT PLAN APPROVAL Veolia Schuylkill Station Page 2

2/9/16 The RACT plan approval is subj ect to the following conditions :

1. The purpose of this Plan Approval is to establ ish Nitrogen Oxides (NOx) Reasonably Available Control Technology (RACT) for Veolia – Schuylkill Station. This includes the following emission sources and control equipment:

A. Emission Sources

(1) Boiler #23: Combustion Engi neering boiler with a capacity of 795 MMBTU/hr. The boiler is tangential fired and burns #6 oil as its prim ary fuel and #2 oil as an ignition fuel.

(2) Boiler #26: Babcock and Wilcox boiler with a capacity of 761 MMBTU/hr. The boiler is

front wall fired and burns #6 oil.

B. Control Equipment

(1) Boiler #26 shall be modified with low NOx burners.

2. This approval requires and authorizes:

A. Boiler #26 shall be modified with low NOx burners.

3. Stack Emission Limitations

A. The maximum air contaminant emissions from thes e sources shall be limited at stack outlet to:

(1) Nitrogen Oxides (NOx):

(a) Boiler #23: emissions shall no t exceed andy of the following:

i. 0.34 lbs/MMBTU on an houlry basis

ii. 270.30 lbs/hr on an hourly basis

iii. 355.15 tons per rolling 12-month period (b) Boiler #26: emission rate shall not exceed any of the following:

i. 0.36 lbs/MMBTU on a 30-day rolling average

ii. 0.41 lbs/MMBTU on an hourly basis

iii. 312.01 lbs/hr on an hourly basis

4. RACT Implementation Schedule

A. Upon issuance of this approval, Veolia shall be gin immediate implementation of the measures necessary to comply with th e approved RACT proposal.

B. Veolia - Schuylkill Station shall begin insta llation of low NOx burners on Boiler #26 by May 31, 1996. Once construction has commenced, Boiler #26 sha ll not be operated until the installation is complete.RACT PLAN APPROVAL Veolia Schuylkill Station Page 3

2/9/16 5. Testing and Monitoring Requirements

A. Within 90 days of start-up and final constr uction acceptance of low NOx burners, Veolia - Schuylkill Station must conduct in itial emissions performance test s of Boiler #26 to demonstrate compliance with the emission limit above. Veolia must conduct annual emission performance

tests on Boiler #23and Boiler #26.

B. Veolia - Schuylkill Station shall obtain approval of the test protocol prior to the test date. AMS must be notified at least 30 days prior to the actual testing in order that representatives from the agency may schedule to observe the conduct of the tests.

C. Continuous nitrogen oxides and oxygen monitors and recorders shall be operated on Boiler #26 in

order to measure and record the concentrations of these gases emitted from the boiler outlet/stack

inlet. The continuous emission monitors must conform to USEPA performance specifications in 40 CFR Part 60, Appendix B and Pa. DER Conti nuous Source Monitoring Manual Rev. No. 4, July 1987.

6. Recordkeeping and Reporting Requirements

A. Compliance shall be monitored and recorded ba sed on annual NOx stack tests for each boiler and NOx CEMS for Boiler#26. The facility shall m onitor and record compliance with them based on daily hours of operation, fuel type, fuel usage, fuel sulfur contentf or each boiler, and NOX

CEMs for boiler #26 and annual stack test for Bo iler #23 compliance with them based on fuel usage and the annual NOx stack tests.

B. Veolia - Schuylkill Station shall maintain a file containing all the records and other data that are required to be collected to demonstrate comp liance with NOx RACT requirements of 25 PA

Code § 129.91-129.94. These records shall include fuel consumption, fuel sulfur content, and

NOx emissions.

C. The records shall provide sufficient data and calculations to clearly demonstrate that the requirements of § 129.91-129.94 are met.

D. Data or information required to determine complia nce shall be recorded and maintained in a time

frame consistent with the aver aging period of the requirement.

E. Records shall be retained for at least two year s and shall be made available to AMS on request.

7. The operation of the aforementioned sources shall not at any time result in the emission of visible air contaminants in excess of the limitations sp ecified in Section 123.41, particulate matter in excess of the limitations specified in Section 123.11 or sulfur oxi des in excess of the limitations specified in Section 123.22, all Sections of Chapte r 123 of Article III of the Rules and Regulations of the Department of Environmental Resources, or in the emission of any of these or any other type of air contaminant in excess of the limitati ons specified in, or established pursuant to, any other applicable rule or regula tion contained in Article III.RACT PLAN APPROVAL Veolia Schuylkill Station Page 4

2/9/16 8. The company shall not impose conditions upon or otherwise restrict AMS's access to the aforementioned source(s) and/or any associated air cleaning device(s) and shall allow AMS to have access at any time to said source(s) and associated air cleaning device(s) with such measuring and recording equipment, including e quipment recording visual observations, as AMS deems necessary and proper for performing its duties and for the effective enforcement of the Air

Pollution Control Act.

9. Revisions to any emission limitations incor porated in this RACT Approval will require resubmission as revision to the PA State Implementa tion Plan. The applicant shall bear the cost of public hearing and notification required for EPA approval as stipulated in 25 PA Code § 129.91(h).