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CITY OF PHILADELPHIA

Department of Public Health 

Environmental Protection Division 

Air Management Services 

InterOffice Memo 

To: File 

From: Rahel Gebrekidan 

Date: Dec 08, 2014 

Subject: 1997 8-hour ozone RACT Summary for Newman and Company, Inc. 

Introduction: 

The Clean Air Act (CAA) requires that moderate (or worse) ozone nonattainment areas 

implement reasonably available control technology (RACT) controls on all major sources of 

Volatile Organic Compounds (VOC) and Nitrogen Oxides (NOx). Philadelphia County is part of 

the Philadelphia-Wilmington-Atlantic City moderate ozone nonattainment area for the 1997 8-

hour ozone NAAQS. This document presents the findings of a RACT evaluation for the 1997 8-

hour ozone standard for this facility. 

Company Description: 

Newman and Company, Inc. owns and operates a paperboard manufacturing facility located at 

6101 Tacony Street, Philadelphia, PA 19135. The facility’s air emissions' sources include a 118 

MMBTU/hr boiler (Boiler #1), twenty nine space heaters less than 0.5 MMBTU/hr, and two 

power washers. The facility also has a stage II vapor recovery system for a 3,000 gallon gasoline, 

a 973,000 BTU/hr fire pump, and a trim waste blower system. 

Applicability for NOx RACT: 

Newman and Company, Inc is a major source of NOx due to having potential emissions greater 

than 100 tons per year, the major source threshold in Philadelphia County that is applicable to 

NOx RACT. This facility is not a major source of VOC having potential emissions less than 50 

tons per year, the major source threshold in Philadelphia County that is applicable to VOC 

RACT for the 1997 8-hour ozone NAAQS. 

The following are NOx emitting units in the facility: one (1) water tube boiler with a maximum 

heat input rating of 118 MMBTU per hour, firing natural gas as its primary fuel and #6 fuel oil as 

auxiliary fuel (Boiler #1); twenty-nine (29) natural gas fired space heaters with less 500,000 

BTU/hr heat capacity; two (2) natural gas fired power washers with less 500,000 BTU/hr heat 

capacity; and one (1) 973,000 BTU/hr #2 oil burning fire pump. 

Summary of 1-Hour RACT Determination

AMS determined a case-by-case RACT for Boiler #1 for the 1-hour ozone standard. As a result 

of this case-by-case RACT determination, a 1-hour RACT plan approval (51-)3489 was issued 

on September 18, 1998 (effective on June 11, 1997), and approved in the SIP by EPA on October 

30, 2001 (66 FR 54691). 
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Emission limits for the 1-hour RACT for Boiler #1 are the following: 

 0.43 lbs/MMBTU when firing #6 oil 

 0.37 lbs/MMBTU when firing natural gas 

 Total NOx emissions from the boiler may not exceed 121 tons per rolling 12-month 

period. 

Newman demonstrates compliance with the above emission limits by performing stack test every 

five years. 

Case-by-case RACT Analysis: 

Union Cogeneration Boiler (Boiler #1) 

The following section presents a detailed evaluation of Case-by-Case RACT for boiler#1

The Union Cogeneration boiler (Boiler #1) is a Union Iron Works water tube boiler with a 

maximum heat input rating of 118 MMBTU per hour. The boiler was installed in 1963 and fires 

natural gas as its primary fuel. The boiler is also equipped to fire #6 fuel oil, as Newman’s 

contract for natural gas is interruptible at the discretion of the utility. 

The boiler is equipped with super heaters to produce superheated steam to a steam turbine which 

can produce nearly 2 MW of electricity to the Mill. 

Newman has issues in maintain safe and reliable operation at the full capacity of this boiler. In 

order to avoid refractory damage and furnace tube failure, Newman has limited the heat input of 

this Boiler to 95 MMBtu/hr through restrictions to fuel firing rate. This limitation has ensured 

that potential emissions of the Boiler remain lower than the emissions that would result from full 

load operation at full capacity and both the short term and annual emission limits are consistent 

with operation at the lower heat input capacity. The original lb/MMBtu RACT limits and the tpy 

were based on stack testing at a load around the 95 MMBTU/Hr rate. The stack test data shows 

some variability in emission range between 0.23-0.345 lb/MMBTU while burning natural gas 

and 0.37-0.395 lb/MMBTU while burning No.6 fuel oil and lower emission limits cannot be 

achieved effectively without add-on controls. 

In addition to existing 1-hour approved RACT controls, other control strategies that 

may be considered for Boiler #1 for NOx RACT are as follows: 

Flue Gas Recirculation (FGR) 

The FGR to reduce NOx by an estimated 20% when firing natural gas; however, the FGR does 

not provide a benefit when firing #6 Fuel Oil. 

The design involves installing the following equipment and modifications. 

 FGR fan with VFD drive. The fan is required to overcome negative pressures in this balanced 

draft boiler. 

 Ductwork to the FGR fan. 

 Ductwork from the FGR to the existing Combustion Air Fan (FD Fan), including a manifold 

on the fan inlet. 

 Burner modifications to add a center fired gas gun for flame stability. (The Boiler has three 

burners to modify) 

 A VFD has already been installed on the FD Fan (60 hp) 

 VFD and motor for the ID Fan (100 hp). 

 Combustion control modifications. 

 Technical Feasibility: This project is technically feasible
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Low NOx burners (LNB)/Ultra Low NOx Burners 

 The manufacturer estimated that the new burners could reduce the NOx by 60%. However the 

project requires the replacement of the existing Natural Gas burners with Low NOx burners. The 

Low NOx burners would have staged combustion, thus changing the existing flame patterns with 

longer and wider flames. The Union Boiler was originally designed with a coal grate option and 

is designed with a shorter than usual furnace box. The combustion flames would most likely 

need to be angled upward, which is a different configuration than the current burner system. This 

would also change the flow of heat through the boiler and is anticipated to potentially change the 

superheating capability of the boiler. 

The Low NOx burners may adversely affect the superheat capability of the boiler, which would 

cause the same issues as described for Feedwater Economizer. Thus the Low NOx burners 

(LNB)/Ultra Low NOx Burners is considered to be technically infeasible. 

The following NOx control was determined technologically feasible for the Boilers;

Economic Feasibility: 

Control 

Technology 

Baseline 

NOx(tpy) 

NOx % 

Reduction 

NOx 

Reduction 

Total Annualized Cost Effectiveness ($/ton) 

FGR 121* 20 24 85,535 3,564 

Conclusion: The FGR is economically unreasonable.

* Federally enforceable emission limits per RACT NOx limit approved in the SIP by EPA on October 30, 2001. 

The above control is determined economically unreasonable.

 For more detailed calculations, please see Appendix.

Conclusion 

AMS has evaluated the above add-on controls and found it to be economically/technically 

infeasible and determines that the 1-hour ozone RACT determination, dated June 11, 1997 and 

SIP-approved by EPA on October 30, 2001 still be considered to represent NOx RACT for the 

1997 8-hour ozone standard for Boiler #1. The boiler shall maintain the NOx emission limits not 

to exceed 0.43 lbs/MMBTU when firing #6 oil and 0.37 lbs/MMBTU when firing natural gas, 

the total NOx emissions limit of 121 tons per rolling 12-month period. 

 

Presumptive RACT Sources 

The following sources meet the various presumptive RACT emission limitations and criteria 

specified in 25 Pa. Code 129.93. 

Table 1-1 lists sources that meet the presumptive RACT requirements specified in 25 Pa Code 

129.93(c), operation and maintenance of boilers per manufacturer specifications, which are the 

following: the 29 space heaters and the 2 power washers. 
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Table 1-1 Small space heaters 

Source Capacity Fuel Type 

Building No. 6 Space Heater 1 400,000 BTU/hr natural gas

Building No. 6 Space Heater 2 400,000 BTU/hr natural gas

Building No. 6 Space Heater 3 400,000 BTU/hr natural gas

Building No. 6 Space Heater 4 400,000 BTU/hr natural gas

Building No. 6 Space Heater 5 400,000 BTU/hr natural gas

Building No. 6 Space Heater 6 400,000 BTU/hr natural gas

Truck Shop Space Heater <500,000 BTU/hr natural gas

Truck Shop Space Heater <500,000 BTU/hr natural gas

Truck Shop Space Heater <500,000 BTU/hr natural gas

Truck Shop Space Heater <500,000 BTU/hr natural gas

Office Heater <500,000 BTU/hr natural gas

Shop Space Heater <500,000 BTU/hr natural gas

Powerhouse Space Heater <500,000 BTU/hr natural gas

Garage Space Heater <500,000 BTU/hr natural gas

Garage Space Heater <500,000 BTU/hr natural gas

Office Water Heater <500,000 BTU/hr natural gas

Mill Water Heater <500,000 BTU/hr natural gas

Mill Water Heater <500,000 BTU/hr natural gas

Power Washer - Shop <500,000 BTU/hr natural gas

Power Washer - Powerhouse <500,000 BTU/hr natural gas

USC Building Space Heater 1 <500,000 BTU/hr natural gas

USC Building Space Heater 2 <500,000 BTU/hr natural gas

USC Building Space Heater 3 <500,000 BTU/hr natural gas

USC Building Space Heater 4 <500,000 BTU/hr natural gas

Skid Shop Space Heater 1 <500,000 BTU/hr natural gas

Skid Shop Space Heater 2 <500,000 BTU/hr natural gas

Skid Shop Space Heater 3 <500,000 BTU/hr natural gas

Truck Shop Water Heater <500,000 BTU/hr natural gas

Building No. 6 Furnace <500,000 BTU/hr natural gas

USC Building Space Heater 5 <500,000 BTU/hr natural gas

USC Building Boiler 1 <500,000 BTU/hr natural gas

Table 1-2 identifies the presumptive RACT requirement specified in 25 Pa Code 129.93(c)(5) 

[operation and maintenance of engines per manufacturer specifications and use limited to 500 

hours per year or less], that applies to the 973,000 BTU/hr fire pump.

Table 1-2 Fire Pump 

Source Capacity Fuel Type 

Ferman Warehouse Fire Pump 973,000 BTU/hr #2 Oil 
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1/9/15

Edward Wiener, Chief of Source Registration Date 

 

 
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Appendix 

EPA Cost Manual, 6th Edition , Jan 2002, Appendix A.2.3 3

Electricity cost: we assume 100 kw@ $0.08/kw-hr for one year. Reference PA DEP RACT State Implementation Plan (SIP) revision, Sep, 2006, page 18; EPA Cost Calculation, Appendix ANOx Control Analysis, A.1 Vendor Information, A-2 Cost Calculation 4

From US Bureau of Labor Statics 

o 5Cost calculations for each elements are from references: North East States for Coordinated Air Use Management (NESCAUM), EPA' s Office of Air Quality Planning and standards 

(OAQPS) edition 6, 2002; Cost analysis and engineering economics book (Michael R. Lindeburg), from Facility, and PADEP Guidelines for RACT SIP revision under the 8-hr Ozone 
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NAAQS, Sep 2006 (Most elements of costs are taken from this doc of page 5 and 18) and from 1Office of Air Quality Planning and standards (OAQPS) Environmental Protection Agency (EPA) 

Air Pollution Control Manual, Six Edition, EPA/452/B-02-001, January 2002 (page 2-27(2.5.5), I-52 table 1.13, Appendix A) and other States