CITY OF PHILADELPHIA 

Department of Public Health 

Environmental Protection Division 

Air Management Services 

InterOffice Memo 

To: File 

From: Edward Wiener & Kassahun Sellassie 

Date: December 5, 2014 

Subject: 1997 8-Hour RACT Analysis for Veolia Energy - Edison Station 

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 standard (NAAQS). This document 

presents the findings of the reevaluation of NOx RACT for the 8-hour ozone standard for this facility. 

Company Description: 

Veolia Energy Philadelphia - Edison Station owns and operates a steam generating facility at 908 Sansom Street, 

Philadelphia, PA 19107. Equipment used at the facility includes four (4) boilers. The facility was formerly named 

Trigen Philadelphia Energy Company, but adopted the name of its parent company Veolia Energy Philadelphia in 

December 2000. 

Applicability for NOx and VOC RACT: 

Veolia – Edison Station is a major source of NOx due to having potential NOx emissions greater than 100 tons per 

year but not applicable for VOC due to having potential VOC emissions not greater than 50 tons per year that is 

applicable to NOx RACT and VOC RACT, respectively. The facility is a 1-hour RACT source. As a result of a 

case-by-case RACT determination, the facility is subject to the RACT plan approval (PA Permit Number 51-4902) 

dated December 1, 1999, approved into the SIP by EPA on May 29, 1995 (65 FR 78418). All four boilers, Boiler 

#1, Boiler #2, Boiler #3, and Boiler #4 were covered by 1-hour RACT determination, and thus are required a reevaluation for the 1997 8-hour RACT standard. 

Process Descriptions: 

Veolia - Edison Station currently has two (2) boilers rated 283 MMBTU/hr (CU01 & CU02-boilers No. 1 and No. 2) 

and two (2) boilers rated 335 MMBTU/hr (CU03 & CU04-Boilers No. 3 and No. 4). Each boiler is front fired and 

burns No. 6 oil as the primary fuel and No. 2 oil as the ignition fuel. The emission limitation reduced from 0.50 

lb/hr to0.39 lbs/MMBTU. AMS has determined the new lbs/MMBTU limits to be RACT because stack test data has 

shown the boilers can comply with these limits under existing technology 

NOx RACT Evaluation: 

In the SIP-approved 1-hour RACT Plan Approval (PA Permit Number 51-04902) dated December 1, 1999, the 

boilers were given a combined No. 6 oil limit of 65,526,316 gallons per rolling 12-month period and a combined 

NOx emission limit 2,195 tons per rolling 12-month period. Also, each boiler was given a NOx emissions limit of 

0.50 pounds per MMBTU of heat input. 

The boilers are currently not equipped with NOx controls. The following were considered possible NOx controls for 

each boiler: Selective Catalytic Reduction (SCR), Ultra Low-NOx Burners and switch to natural gas (ULNB with 

NG), Selective Non-Catalytic Reduction (SNCR), Flue Gas Recirculation (FGR), Ultra Low NOx Burners without 

switching fuel type (ULNB), and Burners Out of Service (BOOS) and other combustion modifications. 
Burners-out-of-service and other combustion modifications for each boiler were determined technologically 

infeasible because they would cause a reduction in boiler capacity, which could cause issues during peak periods. 

Selective Catalytic Reduction was determined technologically infeasible for each boiler because of space 

limitations. Selective Non-Catalytic Reduction was determined to be technologically infeasible for each boiler 

because the boilers have frequent load changes and periods of low load operation. ULNB, ULNB with NG, and 

FGR are considered technologically feasible for all boilers. 

ULNB are burners designed to create a larger, lower temperature flame. They reduce NOx emissions by around 

30%. 

LNB are burners designed to create a larger, lower temperature flame. They reduce NOx emissions by around 20%. 

FGR takes some of the exhaust gas from the stack and ducts it to the burner. It lowers peak flame temperatures and 

lowers the oxygen content of the air, reducing NOx emission by around 40%. 

ULNB with NG are ULNB that are accompanied by a switch from oil to natural gas. They reduce NOx emissions 

by around 62%. This option requires the installation of a new gas pipeline and a pressure regulating station. 

Boilers #1 and #2: 

Boiler # 1and boiler #2 each has a NOx emission limit of 0.50 lbs/MMBTU from the 1-hour RACT determination, 

now the emission limitation reduced to0.39 lbs/MMBTU AMS has determined the new lbs/MMBTU limits to 

be RACT because stack test data has shown the boilers can comply with these limits under existing technology. 

Each boiler has a Federally enforceable annual 30% capacity limit based on hourly maximum heat input, as listed in 

Section D. 2 (a)(1) of Title V/State Operating Permit No. V11-021 issued May 13, 2013 and AMS Plan Approval 

06167A, dated 3/11/13. The baseline NOx emissions are 145.02 tons per year for each Boiler No. 1 & No.2 [283 

mmbtu/hr *8760 hr/yr * 0.39 lb/MMBTU *0.3= 145.02 tons per year]. 

The following NOx controls were determined technologically feasible for Boilers #1 & #2: ULNB, ULNB with NG, 

FGR, and LNB. The table below provides a summary of cost-effectiveness of each control on each boiler. For more 

details, refer to the Appendix. 

Source Control 

Technology 

NOx Emissions 

(tons per year) 

NOx 

Reduction 

(%) 

NOx 

Reduction 

(tpy) 

Total 

Annualized 

Cost ($/y) 

Cost 

Effectiveness 

($/Ton) 

Edison 

Boilers 

ULNB 145.02 30 43.50 $981,486 22,563 

ULNB with NG 145.02 62 89.91 $1,995,437 22,194 

FGR 145.02 40 58 $1,124,514 19,388 

LNB 145.02 20 29 $998,340 34,426 

The controls evaluated were determined economically unreasonable for Boilers #1 and #2. 

Although no additional RACT controls reasonable, the existing 30% capacity factor limit for each boiler #1 & #2 is 

more stringent than the current SIP-approved RACT limit on an annual basis. Thus, to further reduce NOx 

emissions AMS is proposing to incorporate as RACT a 145.02 tons per 12-month rolling NOx emissions limit based 

on the 30% capacity factor for boilers 1 and 2 and the 0.39 lb/MMBTU limit. 

Currently allowed RACT emissions: 619.77 tons per rolling of 12 months 

Proposed allowed RACT emissions: 145.02 tons per rolling of 12 months 

Boilers #3 and #4: 

Boiler #3 and Boiler #4 each has a NOx emission limit of 0.50 lbs/MMBTU from the 1-hour RACT determination, 

now the emission limitation reduced to 0.38 lbs/MMBTU. AMS has determined the new lbs/MMBTU limits to 

be RACT because stack test data has shown the boilers can comply with these limits under existing technology. 

Each boiler has a Federally enforceable annual 30% capacity limit based on hourly maximum heat input, as listed in 

Section D. 2 (a)(1) established in Title V/State Operating Permit No. V11-021 issued May 13, 2013 and AMS Plan 

Approval 06167A, dated 3/11/13. The baseline NOx emissions are 167.28 tons per year for Boilers No. 3 & No.4 
[335 mmbtu/hr *8760 hr/yr *0.38 lb/MMBTU *0.3= 167.28 tons per year]. Boilers #3 & #4 will be more stringent 

than the current SIP approved limit on an annual basis By taking the limit based on the 30%. Currently allowed 

RACT emissions: 733.67 tons per rolling of 12 months Proposed allowed RACT emissions: 167.28 tons per rolling 

of 12 months. 

The following NOx controls were determined technologically feasible for Boilers #3 & #4: ULNB, ULNB with NG, 

FGR, and LNB. The table below provides a summary of cost-effectiveness of each control on each boiler. For more 

details, refer to the Appendix. 

Source Control 

Technology 

NOx Emissions 

(tons per year) 

NOx 

Reduction 

(%) 

NOx 

Reduction 

(tpy) 

Total 

Annualized 

Cost ($/y) 

Cost 

Effectiveness 

($/Ton) 

Edison 

Boilers 

ULNB 167.28 30 50.18 $981,486 19,559 

ULNB with NG 167.28 62 103.71 $1,995,437 19,241 

FGR 167.28 40 66.91 $1,124,514 16,806 

LNB 167.28 20 33.46 $998,340 29,837 

The controls evaluated were determined economically unreasonable for Boilers #3 and #4. 

Although no additional RACT control is reasonable, the existing 30% capacity factor limit for each of boilers #3 & 

#4 is more stringent than the current SIP-approved RACT limit on an annual basis. Thus, to further reduce NOx 

emissions AMS is proposing to incorporate as RACT a 167.28 tons per 12-month rolling NOx emissions limit based 

on the 30% capacity factor for Boilers 3 and 4. 

By taking this restriction on Boilers #1,#2, #3, and #4, the total potential emissions from Boilers #1,#2, #3, and #4 

(624.56 tons per year) are: 

A. Less than the existing combined emissions limit of 2,195 tons in any rolling 12-month period. These 

combined limits are greater than the potential emissions of the boilers. AMS proposes that these combined 

limits cannot continue to represent RACT for the boilers as a result the combined emissions limit of 2,195 

tpy is being removed. 

B. Less than the existing combined fuel usage limit of 65,526,316 gal/yr potential emissions of the boilers to 

1539.8 tons per 12-month rolling (65,526,316 gal/yr * 47 lbs/103

 gal * 1 ton/2000 lbs= 1539.8 tons per 

rolling 12 months) period. These combined limits are greater than the potential emissions of the boilers. 

AMS proposes that these combined limits cannot continue to represent RACT for the boilers as a result the 

combined the combined fuel limit is being removed. 

Monitoring & Recordkeeping 

The facility shall monitor and record compliance with them based on fuel usage and the annual NOx stack tests. The 

facility 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.; including monthly records of fuel 

consumption, fuel sulfur content, and NOx emissions. 

Conclusions and Recommendations: 

AMS is replacing the 0.50 lbs/MMBTU NOx limit for each boiler with the following NOx limits: 0.39 lbs/MMBTU 

and110.37 lbs/hr for Boilers #1 and #2 (each) and 0.38 lbs/MMBTU and 127.3 lbs/hr for Boilers #3 and #4 (each). 

The lbs/hr limits were determined using the new lbs/MMBTU limits and the rated capacities of the boilers. AMS is 

determining the 145.02 tons of NOx per rolling 12-month period emission limit for Boiler #1 and Boiler #2 and the 

167.28 tons of NOx per rolling 12-month period emission limit for Boiler #3 and Boiler #4 as an additional RACT 

requirement. AMS requests these limits to be approved into the SIP. Also, AMS requests to remove the combined 

NOx emissions limit and a combined fuel limit for Boilers #1, #2, #3, #4. AMS recommends that these updates to 

the NOx RACT requirements currently approved in the SIP for the 1-hour ozone standard represent NOx RACT for 

the 1997 8-hour ozone standard for Veolia Edison. 
1/9/15

Edward Wiener, Chief of Source Registration Date 

Appendix

Detail Calculations Summary

The following costs are calculated in order to evaluate the cost effectiveness of each emission control technology: 

‐ Total Capital Investment (TCI) 

‐ Direct Annual Cost (DAC) ($/yr) 

‐ NOx Emission Reduction (tons/yr) 

‐ Cost Effectiveness ($/ton) 

o Capital Recovery = Convert from P (present Value) to A(Annual amount), A=P(A/P,i%,n), 

(1 ) 1

(1 )

 

  n

n

i

i i CR 20% interest and 10 yrs = A/P=0.2385 

Where i= Annual interest Rate; n= control system life; Annual Cost = TCI x CRF 
VEOLIA EDISON (Boilers #1, #2, #3, and #4)

Table 1- Detailed Calculations for Veolia-Edison Boilers (Boiler #1,2, 3, & 4) for ULNB 

 Veolia Edison Data Capacity Factor =30% 

Boilers Capacity 283 mmbtu/hr 

335 mmbtu/hr 

 

Total capital Cost 

 

 

Total Capital Investment Cost 

(TCI) 

$3,025,835 TCI from 1-hour RACT proposal plus 

inflation adjustment. Original TCI 

includes equipment cost estimates from 

Riley Stoker Corp. and installation cost 

estimates from JACA Corp4

. 

Capital Recovery $721,662 10 yrs @20% -from 1 hr RACT 

 CRF= 0.2385 

Annual Operating Costs 

Direct Annual Cost 

Electricity Cost2 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr 

Operator3 $16,425 0.5hr/shift, 3 shift/day, $30/hr 

Supervisor3 $2,463.75 15% of Operator 

Maintenance3 $19,162.50 0.5hr/shift, 3 shift/day, $35/hr 

Material3 $19,162.50 100% of Maintenance 

 

Total Direct Annual Cost $ 127,294 

Indirect Annual Cost 

Overhead3 $11,497 60% of maintenance-OAQPS1

Administrative Charge3 $60,517 2% of TCI-OAQPS1

Property Taxes3 $30,258 1% of TCI-OAQPS1

Insurance3 $30,258 1% of TCI-OAQPS1

 

Total Indirect Annual Cost $132,531 

Total Annual Operating Costs $981,486 

NOx Baseline Emissions (TPY) B#1 & 2 =145.02 

B#3 &4 = 167.28 

B#1 & 2 = 283 mmbtu/hr *8760 hr/yr * 

0.39 lb/MMBTU *0.3=145.02 tpy 

B#3 &4 = 335 mmbtu/hr *8760 hr/yr * 

0.38 lb/MMBTU *0.3= 167.28 tons per 

year 

NOx Emission Reduction (TPY) B#1 & 2 = 43.50 tpy 

B#3 &4 = 50.18 tpy 

Assumed 30% NOx removal. 

Cost Effectiveness ($/ton NOx $22,563 (B #1 ) 
removed) $19,559 (B #3 ) 

 

Table 2 Detail Calculations for Exelon Edison Boiler ULNB with NG 

Veolia Edison Capacity Factor =30% 

Turbine Capacity Boiler 1&2=283 MMBTU/hr & 

Boiler 3 & 4 =335 MMBTU/Hr 

 

 

 Total capital Cost 

Total Capital Investment 

Cost (TCI) 

$3,326,735 For NG Line 

construction from 

PGW $3.9 million 

TCI from 1 hr RACT proposal plus 

inflation adjustment. Original TCI includes 

equipment cost estimates from vendorsupplied estimates for similar units or 

industry data gathered for similar projects 

and new pipeline from PGW. 

TCI with NG Line $7,226,735 $3,900,000 

Capital Recovery $1,723,576 0.2385 10 yrs @20% -from 1 hr RACT 

Annual Operating Costs 

Direct Annual Cost 

Electricity Cost2 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr 

Operator3 $16,425 0.5hr/shift, 3 shift/day, $30/hr 

Supervisor3 $2,463.75 15% of Operator 

Maintenance3 $19,162.50 0.5hr/shift, 3 shift/day, $35/hr 

Material4 $19,162.50 100% of Maintenance 

Total Direct Annual Cost $127,294 

 

Indirect Annual Cost 

Overhead3 $11,498 60% of maintenance-OAQPS1

Administrative Charge3 $66,535 2% of TCI-OAQPS1

Property Taxes3 $33,267 1% of TCI-OAQPS1

Insurance3 $33,267 1% of TCI-OAQPS1

 

Total Indirect Annual Cost $144,567 

Total Annual Operating $1,995,437 
Costs 

 

NOx Emission Reduction 

(TPY) 

89.91 103.71 boiler #1 &2=89.91 ; Boiler #3  

=103.71 

Cost Effectiveness ($/ton 

NOx removed) 

$22,194 $19,241 

Table 3 Detail Calculations for Veolia Edison Boiler FGR 

 Veolia Edison Data Capacity Factor =30% 

Boilers Capacity 2 x 283 mmbtu/hr 

2 x 335 mmbtu/hr 

 

 Total capital Cost 

Total Capital Investment Cost 

(TCI) 

$3,539,400 TCI from 1-hour RACT proposal plus 

inflation adjustment. Original TCI includes 

cost estimates from Riley Stoker Corp. and 

JACA Corp. 

Capital Recovery $844,147 10 yrs @20% -from 1 hr RACT 

 

Annual Operating Costs 

Direct Annual Cost 

Electricity Cost $70,080 100kw @ $0.08/kwh, 8760 hrs/yr 

Operator $16,425 0.5hr/shift, 3 shift/day, $30/hr 

Supervisor $2,463.75 15% of Operator 

Maintenance $19,162.50 0.5hr/shift, 3 shift/day, $35/hr 

Material $19,162.50 100% of Maintenance 

 

Total Direct Annual Cost $ 127,294 

Indirect Annual Cost 

Overhead $11,497 60% of maintenance-OAQPS1

Administrative Charge $70,788 2% of TCI-OAQPS1

Property Taxes $35,394 1% of TCI-OAQPS1

Insurance $35,394 1% of TCI-OAQPS1

 

Total Indirect Annual Cost $153,074 

Total Annual Operating Costs $1,124,514 

NOx Emission Reduction (TPY) B#1 & 2 = 58 tpy 

B#3 &4 = 66.91 tpy 

Cost Effectiveness ($/ton NOx 

removed) 

$19,388 (B #1 ) 

$16,806 (B #3 ) 

 
Table 4 Detail Calculations for Veolia Edison Boiler LNB 

Veolia Edison Capacity Factor =30% 

 283 MMBTU/hr &335 MMBTU/Hr 

 Total capital Cost

Total Capital Investment 

Cost (TCI) 

$3,086,352 TCI from 1 hr RACT proposal plus 

inflation adjustment. Original TCI 

includes equipment cost estimates 

from vendor-supplied estimates for 

similar units or industry data gathered 

for similar projects. 

Capital Recovery $736,095 0.2385 10 yrs @20% -from 1 hr RACT 

Annual Operating Costs 

Direct Annual Cost 

Electricity Cost $70,080 100kw @ $0.08/kwh, 8760 hrs/yr 

Operator $16,425 0.5hr/shift, 3 shift/day, $30/hr 

Supervisor $2,463.75 15% of Operator 

Maintenance $19,162.50 0.5hr/shift, 3 shift/day, $35/hr 

Material $19,162.50 100% of Maintenance 

Total Direct Annual Cost $127,294 

 

Indirect Annual Cost 

Overhead $11,498 60% of maintenance-OAQPS1

Administrative Charge $61,727 2% of TCI-OAQPS1

Property Taxes $30,864 1% of TCI-OAQPS1

Insurance $30,864 1% of TCI-OAQPS1

 

Total Indirect Annual Cost $134,952 

Total Annual Operating 

Costs 

$998,340 

 

NOx Emission Reduction 

(TPY) 

29 33.46 boiler #1 &2= 29; Boiler #3  

=33.46 

Cost Effectiveness ($/ton 

NOx removed) 

$34,426 $29,837 
References

1. Office of Air Quality Planning and standards (OAQPS) Environmental Protection Agency (EPA) Air 

Pollution Control Manual, Six Edition, EPA/452/B-02-001, January 2002. 

2. Electricity cost: EPA cost calculation, Appendix A-NOx Control Analysis 

3. North East States for Coordinated Air Use Management (NESCAUM) 

4. http://new.abb.com/power-generation