CITY OF PH ILADELPHIA Department of Public Health

Environmental Protection Division Air Management Services



### InterOffice Memo

To: File

From: Biji Pandisseril & Edward Wiener

Date: August 29, 2014

Subject: 1997 8-Hour RACT Analysis for Philadelphia Gas Works- Richmond (PLID # 04922)

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 National Ambient Air Quality Standards (NAAQS). This document presents the findings of a RACT evaluation for the 1997 8-hour ozone standard for this facility.

Company Description:

Philadelphia Gas Works (PGW) - Richmond Plant owns and operates a natural gas utilit y at 3100 East Venango Street in Philadelphia, Pennsylvania.

Applicability for NOx and VOC RACT:

PGW Richmond is a major source of NOx having potential NOx emissions greater than 100 tons per year, the major source threshold in Philadelphia County that is applicable to NOx RACT under the 1997 8-hour ozone NAAQS. The facility is not a major source of VOC having potential VOC em issions of less than 50 tons per year, the major source threshold in Philadelphia County that is applicable to VOC RACT under the 1997 8-hour ozone NAAQS.

The facility is subject to RACT under the 1-hour ozone NAAQS. As a result of a 1-hour RACT determination, AMS issued the1-hour RACT Plan Approval (PA Permit Number 51-4922) dated July 26, 1999 for PGW - Richmond, which was approved by EPA as part of the State Implementation Plan (SIP) on October 31, 2001 (66 FR 54947).

Process Descriptions:

The emissions units in PGW Richmond include the following: six (6) Liquefied Natural Gas (LNG) vaporizer heaters between 94.1 and 105.0 MMBTU/hr, five (5) boile r/heaters of 11 MMBTU/hr or less(H-2 Boiloff Heater, H3 Regen Gas Heater, Uniflux/Exotherm (26), GasMaster Boiler (19A-1), and Gas Master Boiler (19B-1)), four (4) simple cycle combustion turbin es of 13.7 MMBTU/hr or less (two Solar Gas Turbine compressor and two Solar gas turbine electric generators), two (2) 170 HP emergency ge nerators,, and three (3) Catrepillar 295 HP engines for fire pumps. These are the only NOx emission sources at the facility.

RACT Analysis:

Shut Down Units At the time of the 1-hour RACT analysis, the facility also had four Clark engines, two Clark Stand-by engines, two Ingersoll-Rand stand-by boil-off compressors, two Kewane e boilers, two facility heaters, and two AO Smith Undertank heating system, but since then these sources have shut down are not listed in the current Title V operating permit for the facility (No. V11-034).

Case-by-case RACTThe four Clark engines were subject to case-by-case RACT requirements under 1-hour RACT. These requirements are no longer applicable as these units have been shut down and permanently removed from the facility.

AMS is requesting to remove the applicable requirements for these units from the 1-hour RACT plan approval.

Presumptive RACT

In accordance, with 25 PA Code 129.93 (a) all of the re maining sources at the facility are subject to presumptive

RACT limitations.

The facility complies with the presumptive RACT requir ements of 25 PA Code 129.93(c)(5) for the large LNG Vaporizer Heaters by operating the heat ers to less than 5% annual capacity . To ensure compliance with the 5% annual capacity, the heater s are limited to a total combined annual natural gas usage of 257 MMcf/yr. These requirements are part of th e SIP-approved 1-hour RACT.

The five boilers/heaters (H-2 Boiloff Heater, H-3 Regen Gas Heater, Uniflux/Exotherm (26), GasMaster Boiler (19A-1), and Gas Master Boiler (19B-1)) are less the 20 MMBTU/hr and comply with 25 PA Code 129.93(c)(1) presumptive RACT requirements for installation, maintenance, and operation in accordance with manufacturers specifications.

The four single cycle combustion turb ines (two Solar Gas Turbine compresso r and two Solar gas turbine electric generators), which are less than 25 MMBTU/hr and are used for natural gas distribution, will comply with the presumptive RACT 25 PA Code 129.93(c)(2) by insta lling, maintaining, and operating in accordance with manufacturers specifications.

Each emergency generator complies with presumptive RACT 25 PA Code 129.93(c)(5) by operating less than 500 hours in consecutive 12-month period.

Each of the 294 HP engines for fire pumps complies with presumptive RACT 25 PA Code 129.93(c)(5) by operating less than 500 hours in consecutive 12-month period.

The following removed sources were also subject to pr esumptive RACT requirements : two (2) Clark stand-by engines and, two (2) Ingersoll-Rand standby boil-off compressors. AMS is requesting to remove the applicable requirements for these units form the 1-hour RACT.

Summary Table - Applicable Presumptive RACT Sources Presumptive RA CT Six (6) Vaporizer Heater between 94.1 and 105.0 MMBTU/hr 25 PA Code 129.93(c)(5) Two (2) Heater 11 MMBTU/hr or less 25 PA Code 129.93(c)(1) Four (4) turbines 13.7 MMBTU/hr or less three 25 PA Code 129.93(c)(2) Three (3) boilers/heater less than 10 MMBTU/hr 25 PA Code 129.93(c)(1) Three (3) 295 HP engines for fire pumps 25 PA Code 129.93(c)(5) Two (2) 170 HP emergency generators 25 PA Code 129.93(c)(5)

Conclusions and Recommendations:

The case-by-case requirements under the previous 1-hour RACT determination are no longer applicable, since sources subject to these requirements have been shut down. All existing sources at the facility are covered by presumptive RACT. AMS proposes these requirements continue to represent RACT under the 1997 8-hour

ozone standard..

Changes to the SIP-approved 1-hour RACT

AMS is requesting changes to the 1-hour RACT to remove any requirements for shutdown sources.

(Strikethrough is used to show requirements to be removed)1

. T h e p u r p o s e o f t h i s P l a n A p p r o v a l i s t o e s t a b l i s h N i t r o g e n O x i d

e s ( N O x ) R e a s o n a b l y A v a i l a b l e C o n t r o l

T e c h n o l o g y ( R A C T ) f o r P G W T h i s i n c l u d e s t h e f o l l o w i n g e m i s s i o n s o u r c e s a n d c o n t r o l e q u i p m e n

t :

A

. E m i s s i o n S o u r c e s :

Unit Description Fuel Type Full Rated Capacity

Four Clark HLA

- 8T (C2A, C2B, C3A, C3B) Natural Gas 2,350 horsepower LNG vaporization Heater Natural Gas 94.1 MMBTU/hr LNG vaporization Heater Natural Gas 94.1 MMBTU/hr LNG vaporization Heater Natural Gas 96.6 MMBTU/hr LNG vaporization Heater Natural Gas 102.1 MMBTU/hr LNG vaporization Heater Natural Gas 105.0 MMBTU/hr LNG vaporization Heater Natural Gas 105.0 MMBTU/hr Two Standby Clark HLA

- 8T (C1A, C1B) Natural Gas 2,350 horsepower Two Standby Ingersoll

- Rand boiloff compressors KVG

- 83FL/HL Natural Gas 800 horsepower

B

. C o n t r o l E q u i p m e n

t

(1) Four Clark HLA

- 8T 2,350 horsepower Units (C2A, C2B, C3A, and C3B) shall be retrofitted with new high energy ignition systems, AFR controls, a turbocharger system enhancement along with new fuel

valves

.

(2) Limit the following units’ operating schedule to five percent of their maximum operating capacity:

LNG vaporization Heater 94.1 MMBTU/hr LNG vaporization Heater 94.1 MMBTU/hr LNG vaporization Heater 96.6 MMBTU/hr LNG vaporization Heater 102.1 MMBTU/hr LNG vaporization Heater 105.0 MMBTU/hr LNG vaporization Heater 105.0 MMBTU/hr Two Standby Clark HLA

- 8T 2,350 horsepower (C1A, C1B) Units Two Standby Ingersoll

- Rand boiloff compressors KVG

- 83FL/HL 800 horsepower Units

2. This approval requires and authorizes:

A. Four Clark HLA

- 8T 2,350 horsepower units, respectively C2A, C2B, C3A and C3B shall be retrofitted with new high

- energy ignition systems, AFR controls, a turbocharger system enhancement along with new

fuel valves.

B. Based on a rolling 12

- month period, the a nnual fuel consumption for the four Clark HLA

- 8T 2,350 horsepower units shall be limited to 570 MMCF of natural gas.

C. PGW shall comply with the requirements as specified in the RACT requirements of 25 PA Code 129.91(f); pertaining to expeditious compliance.

D. The following sources shall comply with presumptiv e RACT requirement requirements of 25 PA Code 129.93(c)(5):

( 1 ) C a l c u l a t e d o n a 1 2

- m o n t h r o l l i n g p e r i o d t h e t o t a l a n n u a l f u e l u s a g e f o r t h e S i x L N G v a p o r i z a t i o n
H e a t e r s 1 0 3 M M B T U / h

r U n i t s i s l i m i t e d t o 2 5 7 M M C F o f n a t u r a l g a s

.

(2) Calculated on a 12

- month rolling period, the annual fuel usage for the Two Standby Clark HLA

- 8T 2,350 horsepower (C1A, C1B) Units shall be limited to 14.8 MMCF of natural gas.

(3) Calculated on a 12

- month rolling period, the annual fuel usage for Two Standby Ingersoll

- Rand boiloff compressors KVG

- 83FL/HL 800 horsepower Units is limited to 6.7 MMCF of natural gas.

3

. E m i s s i o n L i m i t a t i o n s :A. The maximum air contaminant emissions from the equipment listed in the “Sou rces” section of this RACT Permit shall have the following limitations:

(1) Nitrogen Oxides (NOx):

a) Each of the four Clark HLA

- 8T 2,350 horsepower units (C2A,C2B, C3A, C3B ) shall have

individual stack emission limitations of 5grams per Brake Horse Power per Hour for Oxides of Nitrogen (NOx). Compliance with these limitations shall be demonstrated by using appropriate emission calculation procedures which are approved by AMS. (See 5.Testing Requirements).

b) Each of the four Cla rk HLA

- 8T 2,350 horsepower units (C2A,C2B, C3A, C3B) shall have

individual stack emission limitations of 25.9 lbs. of Oxides of Nitrogen (NOx) per hour. Compliance with these limitations shall be demonstrated by using appropriate emission calculation pro cedures, which are approved by AMS. (See 5.Testing Requirements).

c) The four Clark HLA

- 8T 2,350 horsepower units (C2A, C2B, C3A, and C3B) shall have a total

emission limitation of 320 tons of Oxides of Nitrogen (NOx) per year, calculated on a 12

- month rolling period. Compliance with these limitations shall be demonstrated by using appropriate emission calculation procedures that are approved by AMS. (See 5.Testing requirements)

4. RACT Implementation Schedule:

A. Upon issuance of this approval, PGW shall begin imme diate implementation of the measures necessary to comply with this RACT permit.

B. PGW shall operate NOx controls on the Four Clark HLA_8T Units (C2A, C2B, C3A, and C3B) by May
31, 1997.

5. Testing Requirements:

A. PGW must conduct performance testing on the Four Clark HLA_8T Units (C2A,C2B, C3A, and C3B) once every five years to demonstrate compliance with this RACT permit. Compliance testing shall be performed between the calendar period of July 1 and September 1 of each scheduled test year.

B. PGW shall submit to AMS a proposed stack testing protocol at least (60) days prior to the scheduled date for that stack testing.

C. If at any time AMS has cause to believe that air contaminant emissions from any source(s) listed in Section A of this permit may be in excess of the lim itations specified in this permit, or established pursuant to, any applicable rule or regulation contained in 25 PA Code Article III, the Permittee shall be required to conduct whatever tests are deemed necessary by AMS to de termine the actual emission rate(s).

6. Monitoring Requirements:

A. Engine mapping conducted in conj unction with the initial compliance testing of the Clark HLA

- 8T 2350 horsepower units shall be used to establish coeffi cients for the control algorithms of each engine, including air/fuel ratio, ignition timing and air manifold temperature control.

No changes are proposed in Conditions 7 through 9.

1 / 9 / 1 5

Edward Wiener, Chief of Source Registration Date