CITY OF PHILADELPHIA

DEPARTMENT OF PUBLIC HEALTH

AIR MANAGEMENT SERVICES

RACT PLAN APPROVAL

Effective Date: January 9, 2015

Expiration Date: None

Replaces Permit No. PA-51-1566 issued April 10, 1995

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: Paperworks, LLC

Owner: Paperworks Industries, inc

Location: 5000 Flat Rock Road, Philadelphia, PA 19127 Mailing Address: 5000 Flat Rock Road, Philadelphia, PA 19127 SIC Code(s): 2631

Plant ID: 01566

Facility Contact: Frank DelGrego

Phone: (215) 984-7000

Permit Contact: Frank DelGrego

Phone: (215) 984-7000

Responsible

Official: Frank DelGrego

Title: General Manager

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, C h i e f o f S o u r c e R e g i s t r a t i o n D a t eRACT PLAN APPROVAL Paperworks Page 2

1 / 9 / 1 5 The RACT plan approval is subjec t to the following conditions:

1) The purpose of this plan approval is to estab lish Nitrogen oxide and ( NOx) Reasonably available control technology (RACT) for Paperworks, LLC. This includes the following emission source and control equipment.

A. Emission Sources (i) Boiler#1, Riley boiler with heat input limit of 156 MMBTU/hr (previously rated capacity of 240 MMBTU/hr) and firing natura l gas as primary fuel and #6 oil fuel as a back-up, equipped with Low NOx burners (LNB) with overfire air (ii) Boiler #3: Rated 92.27 MMBTU/hr and burns natu ral gas equipped with Low NOx burners (LNB) and flue gas recirculation (FGR). (iii)Boiler #4: Rated 92.27 MMBTU/hr and burns natural gas equipped with Low NOx burners (LNB) and flue gas recirculation (FGR).

2) Emission Limts (i) NOx emissions from Boiler #1 sh all not exceed the following: (a) 0.20lbs/MMBTU on a 30 day rolling averag e basis when burning natural gas and (b) 0.30 lbs/MMBTU on 30 day rolling average basis while burning No.6 oil (c) 138 tons/ rolling 12 month period calculated monthly (ii) NOx emissions from Boiler #3 & #4 shall not exceed the following; (a) 0.025 lbs/MMBTU while burning natural gas (b) 10.15 tons per ro lling 12-month peri od for each boiler

3) Control Equipment (i) Boiler #1 shall installed with or modifi ed and operate Low NOx burners with

overfire air (ii) Boiler #3 & #4 shall be equipped with and operate LNB and FGR

4) Work Practice Standard (i) Boiler No.1 shall only burn natural gas and No.6 fuel oil. Boiler #1 shall burn #6 fuel oil for no more than 168 hours per rolling 12-m onth period, solely for emergency, and to keep pipes from freezing in cas e of natural gas interruption. (ii) The maxiumum heat imput shall be limited to 156 MMBTU/hr for Boiler #1 (iii) Boiler No.3 & 4 shall on ly burn natural gas.

5) Testing Requirements

A. Continuos nitrogen oxides, and oxygen monitors and recorders shall be installed and operated

in order to measure and record the concentr ations of these gases emitted from the boiler

stacks. The continuos emission monitors must conform to USEPA performance specifications in 40 CFR part 60, Appendix B and PA. DER continuos Source Monitering Manual Rev. No.4, July 1987

B. Paperworks shall conduct a NOx performance te st on Boiler #3 & #4 every five years.

C. Paperworks shall obtain approval of the te st protocol prior to the test date.

6 ) M o n i t o r i n g , R e c o r d k e e p i n g a n d R e p o r t i n g R e q u i r e m e n t s

A. Boiler #1 (i) Daily and monthly natural gas usage,RACT PLAN APPROVAL Paperworks Page 3

1 / 9 / 1 5 (ii) Daily and monthly No.6 oil usage for Boiler No.1 (iii) 30-day rolling average of NOx emissions per lbs/mmbtu when burning No. 6 oil, and natural gas (iv) NOx emission calculation per rolling twel ve month period calculated monthly (v) Average hourly heat input records for Boiler No.1,and (vi) Operating hours of the boiler while burning No.6 fuel oil and (vii) Records of the reasoning of burning fuel oil each time

B. Boiler #3 & #4 (i) Paperworks shall monitor and record monthly fuel usage fo r each boiler, and calculate monthly NOx emission for each boil er per rolling 12-month period.

C. Paperworks shall maintain a file containing all the records and other data that are required to be collected to demonstrate compliance with NOx/VOC RACT requirements of 25 PA Code

129.91 - 129.94.

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

E. Data or information required to determine compliance shall be recorded and maintained in a time frame consistent with the averaging period of the requirement.

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

G. 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 equipment recording visual observations, as the Department deems necessary and proper for performing its duties and for the effective

enforcement of the Air Pollution Control Act.

H. Revisions to conditions approve d as RACT by EPA will require resubmission as revision to the PA State Implementation Plan. The applican t shall bear the cost of public hearing and notification required for EPA approval as stipulated in 25 PA Code §129.91(h).

7) RACT Implementation Schedule

A. Upon issuance of this approva l Paperwork shall begin immediate implementation of the measures necessary to comply with the approved RACT requirements.