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 Cont rol Technology (RACT) proposal received under the Pennsylvania Code, T itle 25, Chapter 129.91 thru 129.95, of the rules and regulations of the Pennsylvania Department of Environmental Pr otection (PADEP), Air Management Services (AMS) approved the RACT proposal of the Facility below for the s ource(s) listed in section

1.A. Emission Sources of the a ttached 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 S ource Registration DateRACT PLAN APPROVAL Veolia Edison Station Page 2

12/16/2014 The RACT plan approval is su bject to the following conditions:

1. The purpose of this Plan Approval is to establ ish Nitrogen Oxides (NOx) Reasonably Available Control Technology (RACT) for Veolia – Edison St ation. This includes the following emission sources and control equipment:

A. Emission Sources

(1)Boiler #1: Riley/Stoker Corporation boiler wi th 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 MMB TU/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 Wilc ox boiler with a capacity of 335 MMB TU/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 be gin immediate implementation of the measures necessary to comply with the approved RACT proposal.

5. Testing Requirements and St ack Emission LimitationsRACT 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 prio r 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 th e 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 comp liance 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 comp liance 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 c onsist of the arithmetic means of results of at least three separate runs for each source te st using U.S.E.P.A. Reference Methods 5 and 202, 7E, and 10. NOx emissions using annual em ission performance stack test data.

D. Records shall be retained for at least two year s 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 sp ecified in Section 123.41, particulate matter in excess of the limitations specified in Section 123.11 or sulfur oxi des in excess of the limitations specified in Section 123.22, all Sections of Chapte r 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 limitati ons specified in, or established pursuant to, any other applicable rule or regula tion 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 e quipment recording visual observations, as the Department deems necessary and proper for pe rforming its duties and for the effective

enforcement of the Air Pollution Control Act.

9. Revisions to any emission limitations incor porated in this RACT Approval will require resubmission as revision to the PA State Implementa tion Plan. The applicant shall bear the cost of public hearing and notification re quired for EPA approval as sti pulated in 25 PA Code §129.91(h).