CITY OF PHILADELPHIA

DEPARTMENT OF PUBLIC HEALTH

AIR MANAGEMENT SERVICES

RACT PLAN APPROVAL

Effective Date: January 9, 2015

Expiration Date: None

Replaces Permit No. None

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: Grays Ferry Cogenera tion Partnership – Schuylkill

Station

Permittee: Grays Ferry Cogeneration Partnership Location: 2600 Christian Street, Philadelphia, PA 19146 Mailing Address: 2600 Christian Street, Philadelphia, PA 19146 SIC Code(s): 4961

Plant ID: 4944

Facility Contact Floyd Rupple Phone: (267) 350-5846

Permit Contact: Floyd Rupple Phone: (267) 350-5846

Responsible Official: Michael J. Smedley Title: Vice President and General Manager

1/9/2015 ____ Edward Wiener, Chief of Source Registration DateRACT PLAN APPROVAL Grays Ferry Cogeneration Partnership-Schuylkill Station Page 2

1/9/15 The RACT plan approval is su bject 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 #25: Auxilary boile r with a capacity of 1119 MMBTU/hr. The boiler is front wall fired

burns #2 oil and Natural Gas.

(2) Turbine (with and without HRSG): Combus tion Turbine (CT) is a combined cycle turbine with a capacity of 1515 MMBTU/hr (135 MW). The CT can operate both with and withourt a Heat Recovery Steam Generating Unit (HRSG). The CT burns #2 oil and Natural Gas.

B. Control Equipment

(1) Boiler #25 shall be modified with low NOx (LNB ) burners and flue gas recirculation (FGR). (2) CT has SCR and in addition of low NOx (DLN) combustion for gas firing, and water injection (WI) for oil firing.

2. This approval requires and authorizes:

A. Boiler #25 shall be modified with low NOx burners and flue gas recirculation .

B. CT shall be modified with SCR and in additio n of low NOx (DLN) combustion for gas firing, and water injection for oil firing.

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 #25- NOx emissions shall not exceed 0.10 pounds per MMBTU when firing gas and 0.15 pounds per MMBTU when firing oil.

(b) The Combustion Turbine NOx emissions shall not exceed 255 pounds per hour.

(c) The Combustion Turbine with HRSG NOx em issions shall not exceed 298.9 pounds per

hour.

(d) The facility shall monitor and record compliance based on NOX CEMs for Boiler #25 and

CT.RACT PLAN APPROVAL Grays Ferry Cogeneration Partnership-Schuylkill Station Page 3

1/9/15 4. RACT Implementation Schedule

A. Upon issuance of this approval, Grays Ferry shall begin immediate implementation of the measures necessary to comply w ith the approved RACT proposal.

(1) Grays Ferry shall maintain low NOx burners and flue gas recircul ation on Boiler #25, and SCR and in addition of low NOx (DLN) combusti on for gas firing, and water injection for oil firing on CT

5. Testing and Monitoring Requirements

A. Continuous nitrogen oxides and oxygen monitors and recorders shall be operated on the exhaust

stacks of Boiler #25 and the CT/HRSG.

6. Recordkeeping and Reporting Requirements

A. Compliance shall be monitored and recorded based on NOx CEMS for Boiler#25 and CT.

B. Grays Ferry shall maintain a file containing all the records and other data th at are required to be collected to demonstrate compliance with NOx RACT requirements of 25 PA Code §129.91-

129.94.

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

D. Data or information required to determine compliance 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 five year s and shall be made available to AMS on request.

7. 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.

8. 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 re quired for EPA approval as sti pulated in 25 PA Code §129.91(h).