CITY OF PH ILADELPHIA Department of Public Health Environmental Protection Division Air Management Services



### InterOffice Memo
To: File

From: Maryjoy Ulatowski

Date: 12/12/2014 Subject: RACT Analysis for Southwest Pollution Control Plant (PLID # 09515)

Company Description:

Southwest Water Pollution Control Plant is a water treatment plant located at 8200 Enterprise Avenue, Philadelphia, PA 19153. The facility’s air emission sources include liqui d treatment processes, solids treatment processes, four 20-50 MMBTU/hr boilers, five boilers <10 MMBTU/hr, four digester gas flares , a steam cleaner and 10 cold degreasers.

Applicability for NOx and VOC RACT:

Southwest Pollution Control Plant (PWPCP) is not a major source for Nitrogen Oxides (NOx) emission having potential NOx emissions less 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.

The facility is not a major source of Volatile Organic Compounds (VOC) having potential VOC emissions is greater than 50 tons per year, the major source threshold in Phila delphia County that is applicable to VOC RACT for the 1997 8-hour ozone NAAQS.

The facility is being re-evaluated for RACT under the 1 997 8-hour Ozone National Ambient Air Quality Standards (NAAQS).

NOx Emission Sources an d NOx RACT Analysis:

Process Descriptions – NOx Sources: SWPCP NOx emission sources include combustion sources such as boilers, flares, and cogeneration facility. Below is a list of NOx sources at th e NWPCP and the potential to emit (PTE). The combined NOx were calculated based AP-42 factors. The combined NOx poten tial emission is less than 61 tpy. Therefore the facility is not applicable to NOx RACT requirements.

Following is the PTE calculation based on AP-42 factors using the worst-case scenario for NOx:

Boilers

Title V Permit ID No. Source Description Ca pacity btu/hr Fuel Type NOX Tons
per year CU-001 Cleaverbrooks Boiler 5,320,000 #2 Oil, Digester Gas 3.329 CU-002 Cleaverbrooks Boiler 5,320,000 #2 Oil, Digester Gas 3.329 CU-003 Burnham Boiler 26,780,000 #2 Oil, Digester Gas 16.757 CU-004 Burnham Boiler 26,780,000 #2 Oil, Digester Gas 16.757 CU-005 Burnham Boiler 26,780,000 #2 Oil, Digester Gas 16.757 CU-006 Burnham Boiler 26,780,000 #2 Oil, Digester Gas 16.757 CU-007 Weather Right Boiler 5,320,000 #2 Oil, Digester Gas 3.329 CU-014 HB Smith Boiler 4,853,000 #2 Oil, Digester Gas 3.037 CU-015 HB Smith Boiler 4,853,000 #2 Oil, Digester Gas 3.037Flares Title V Permit ID No. Source Description Capacity SCF/hr Fuel Type NOX Tons
per year CU-010 SW Digester Gas Flare 51,300 #Digester Gas 0.08 CU-011 SW Digester Gas Flare 51,300 #2 Oil, Digester Gas 0.08 CU-012 SW Digester Gas Flare 51,300 #2 Oil, Digester Gas 0.08 CU-013 SW Digester Gas Flare 51,300 #2 Oil, Digester Gas 0.08

Steamer

Title V Permit ID No. Source Description Capacity btu/hr Fuel Type NOX Tons
per year MISC003 08 Steam Cleaner 600, 000 Natural Gas 0.26

Total NOx PTE 60.2 tpy

VOC RACT Analysis:

SWPCP VOC emission sources include combustion sources an d wastewater treatment plan t operations. Below a list of VOC sources at the SWPCP and the potentia l to emit (PTE) calculation for the facility.

Combustion Sources:

Heating Capacity(Btu/hr) *Natural Gas Input (SCF/hr) VOC Factor a (lbs NOx/10 6 SCF) Operating hours per
year Voc Tons per
year 5,320,000 5216 5.5 8760 0.13 5,320,000 5216 5.5 8760 0.13 26,780,000 26255 5.5 8760 0.63 26,780,000 26255 5.5 8760 0.63 26,780,000 26255 5.5 8760 0.63 26,780,000 26255 5.5 8760 0.63

5,320,000 5216 5.5 8760 0.13 4,853,000 4758 5.5 8760 0.11 4,853,000 4758 5.5 8760 0.11

600,000 588 5.5 8760 0.01
3.150 *Assuming the heating value of natural gas is 1020 Btu/scfFlares:

Heating capacity(10 6 Btu/hr) *Natural Gas Input (SCF/hr) VOC Factor - AP42 Table 13.5-2 (lbs VOC/10 6 Btu) Operating hours per year VOC Tons per
year 47 45860 0.55 8760 0.01
47 45860 0.55 8760 0.01
47 45860 0.55 8760 0.01
47 45860 0.55 8760 0.01
0.051

Wastewater treatment plant operations including pretreatment, The potential to emit for VOC at the SWPCP for wastewater treatment operations is estimated to be 10.5 tons per year. This number was obtained by looking at facility’s m onthly VOC estimates for the last three years (July 2011- June 2014) and the highest monthly estimate was used and multiplied by 12, for a yearly PTE number. These estimates were developed using the TOXCHEM model that was tailored for wastewater facilities. The TOXCHEM model is an EPA-approved proprietary software package developed and distributed by Enviromega, Ltd. The model essentially is a sophisticated mass balance that incorporat ed kinetic equations to determine the fate of organic compound. Influent VOC concentrations and plant flows were used in the model to estimate the monthly concentration of VOC.



### MONTH 2014
lbs Carbon /month 

### 2013
lbs Carbon /month 

### 2012
lbs Carbon /month 

### 2011
lbs Carbon /month



### JAN 1219 1,301 1,025 FEB 1536 1,085 1,014 MAR 1559 1,331 1,066 APR 1528 1,009 1,453 MAY 1656 864 1,192 JUN 1743 1,059 1,092 JUL 1,118 1,176 1163 AUG 1,366 1,381 1433 SEP 1,108 1,068 1367
OCT 947 985 1291
NOV 911 864 928
DEC 999 937 1215PTE VOC = (1743/2000) *12 = 10.5 tpy

10 Cold Degreasers VOC PTE (tpy) Following is the PTE VOC calculation for the degreaser is based on using AP-42 factor, 3.3 Section, Table 4.6-2: VOC PTE = AP-42 emission factor x (number of unit) VOC PTE = (0.33 tons/year/unit) X 10 unit VOC PTE = 3.3 tons/year

Cold-cleaning degreasing operations at the facility shall complying with the RACT requirements of 25 PA Code 129.63

The total VOC PTE for the facility is less than 17 tpy.

Conclusions and Recommendations: Since the potential for VOC and NOx sources are below the ap plicable RACT limits, the facility is not applicable to RACT under he 1997 8-hour ozone standard..

1 / 9 / 1 5

Edward Wiener, Chief of Source Registration Date