CITY OF PHILADELPHIA 

DEPARTMENT OF PUBLIC HEALTH 

 AIR MANAGEMENT SERVICES 

 RACT PLAN APPROVAL 

Effective Date: December 16, 2014 

Expiration Date: None 

Replaces Permit No. PA Permit Number 51-4902 dated December 1, 1999 

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: Veolia Energy Philadelphia - Edison Station 

Owner: Veolia Energy Philadelphia, Inc. 

Location: 908 Sansom Street, Philadelphia, PA 19107 

Mailing Address: 2600 Christian Street, Philadelphia, PA 19146 

SIC Code(s): 4961 

Plant ID: 04902 

Facility Contact: Jessica Hartley 

Phone: (267) 350-5819 

Permit Contact: Jessica Hartley 

Phone: (267) 350-5819 

Responsible Official: Michael J. Smedley 

Title: Vice President & General Manager 

 12/16/2014 

____________________________________ ______________________ 

 

Edward Wiener, Chief of Source Registration Date 
RACT PLAN APPROVAL Veolia Edison Station Page 2 

12/16/2014 

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 – Edison Station. This includes the following emission 

sources and control equipment: 

A. Emission Sources 

(1)Boiler #1: Riley/Stoker Corporation boiler with a capacity of 283 MMBTU/hr. The boiler is 

front fired and burns #6 oil as its primary fuel and #2 oil as an ignition fuel. 

 (2) Boiler #2: Riley/Stoker Corporation boiler with a capacity of 283 MMBTU/hr. The boiler is 

front fired and burns #6 oil as its primary fuel and #2 oil as an ignition fuel. 

(3) Boiler #3: Babcock and Wilcox boiler with a capacity of 335 MMBTU/hr. The boiler is front 

fired and burns #6 oil as its primary fuel and #2 oil as an ignition fuel. 

(4) Boiler #4: Babcock and Wilcox boiler with a capacity of 335 MMBTU/hr. The boiler is front 

fired and burns #6 oil as its primary fuel and #2 oil as an ignition fuel. 

2. This approval requires and authorizes: 

The Boiler #1, Boiler #2, Boiler #3 and Boiler #4 shall not exceed 

 

3. Stack Emission Limitations 

 

A. The maximum air contaminant emissions from these sources, controlled by the equipment above 

shall be limited at stack outlet to: 

 (1) Nitrogen Oxides (NOx): 

(a) Emissions from each of Boiler #1 and Boiler #2 shall not exceed 0.39 lbs/MMBTU or 

110.37 lbs/hr. 

(b) Emissions from each of Boiler #1 and Boiler #2 shall not exceed 145.02 tons per rolling of 

12-month period 

(c) Emissions from each of boiler #3 and Boiler #4, shall not exceed 0.38 lbs/MMBTU or 127.3 

lbs/hr. 

 (d) Emissions from each of Boiler #3 and Boiler #4 shall not exceed 167.28 tons per rolling of 

12-month period. 

4. RACT Implementation Schedule 

A. Upon issuance of this approval, Veolia shall begin immediate implementation of the measures 

necessary to comply with the approved RACT proposal. 

5. Testing Requirements and Stack Emission Limitations 
RACT PLAN APPROVAL Veolia Edison Station Page 3 

12/16/2014 

A. Veolia - Edison Station must conduct annual emission performance tests on Boilers #1, #2, #3, 

and #4. 

B. Veolia - Edison Station shall obtain approval of the test protocol prior to the test date. AMS must 

be notified at least 30 days prior to the actual testing in order that representatives from the agency 

may schedule to observe the conduct of the tests. 

6. Recordkeeping and Reporting Requirements 

A. Veolia - Edison Station 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 and NOx emissions. 

B. The records shall provide sufficient data and calculations to clearly demonstrate that the 

requirements of 129.91-129.94 are met. 

C. Data or information required to determine compliance shall be recorded monthly and maintained 

in a time frame consistent with the averaging period of the requirement which the 30 day rolling 

weighted average must be the average of the 24 hour daily weighted rate of the past 29 days and 

the evaluation day.. Compliance determination shall consist of the arithmetic means of results of 

at least three separate runs for each source test using U.S.E.P.A. Reference Methods 5 and 202, 

7E, and 10. NOx emissions using annual emission performance stack test data. 

D. Records shall be retained for at least two years and shall be made available to AMS on request. 

7. The operation of the aforementioned sources shall not at any time result in the emission of visible 

air contaminants in excess of the limitations specified in Section 123.41, particulate matter in 

excess of the limitations specified in Section 123.11 or sulfur oxides in excess of the limitations 

specified in Section 123.22, all Sections of Chapter 123 of Article III of the Rules and Regulations 

of the Department of Environmental Resources, or in the emission of any of these or any other 

type of air contaminant in excess of the limitations specified in, or established pursuant to, any 

other applicable rule or regulation contained in Article III. 

8. 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 the 

Department deems necessary and proper for performing its duties and for the effective 

enforcement of the Air Pollution Control Act. 

9. 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).