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 Control Technology (RACT) 

proposal received under the Pennsylvania Code, Title 25, Chapter 129.91 thru 129.95, of the rules and 

regulations of the Pennsylvania Department of Environmental Protection (PADEP), Air Management 

Services (AMS) approved the RACT proposal of the Facility below for the source(s) listed in section 

1.A. Emission Sources of the attached RACT Plan Approval. 

Facility: Grays Ferry Cogeneration 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 Date 
RACT PLAN APPROVAL Grays Ferry Cogeneration Partnership-Schuylkill Station Page 2 

1/9/15 

The RACT plan approval is subject to the following conditions: 

1. The purpose of this Plan Approval is to establish 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 boiler 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): Combustion 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 addition 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 these 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 emissions 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 with the approved RACT proposal. 

(1) Grays Ferry shall maintain low NOx burners and flue gas recirculation on Boiler #25, and 

SCR and in addition of low NOx (DLN) combustion 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 that 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 calculations 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 averaging period of the requirement. 

E. Records shall be retained for at least five years 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 equipment 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 incorporated in this RACT Approval will require 

resubmission as revision to the PA State Implementation 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).