CITY OF PHILADELPHIA

Department of Public Health 

Environmental Protection Division 

Air Management Services 

InterOffice Memo 

To: File 

From: Edward Wiener & Kassahun Sellassie 

Date: June 24, 2015 

Subject: 1997 8-Hour RACT Analysis for Exelon Generating Company - Richmond 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 NAAQS. This document presents the findings of the reevaluation of 

NOx RACT for the 1997 8-hour ozone standard for this facility 

Company Description: 

Exelon Generation Company - Richmond Generating Station owns and operates an electric utility at 3901 North 

Delaware Avenue, Philadelphia, PA, 19137. Equipment used at the facility includes two (2) simple cycle 

combustion turbines. The facility was owned by PECO Energy Company at the time of the original RACT plan 

approval, but changed to ownership to Exelon in October 2000. 

Applicability for NOx and VOCRACT 

Exelon - Richmond is a major source of NOx due to having potential NOx emissions greater than 100 tons per year, 

the major source threshold in Philadelphia County that is applicable to NOx RACT for the 1997 8-hour ozone 

NAAQS. They are not a major source of VOC, due to having potential VOC emissions not greater than 50 tons per 

year, the major source threshold in Philadelphia County that is applicable to NOx RACT for the 1997 8-hour ozone. 

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 51-4903) dated 7/11/01, approved into the SIP by EPA on 10/30/01 

(66 FR 54704). All two simple cycle combustion turbines, were covered by 1-hour RACT determination, and thus 

are required a re-evaluation for the 1997 8-hour RACT standard. 

Process Descriptions: 

Exelon - Richmond Station currently has two simple cycle combustion turbines, each rated 66 MW. Each burns No. 

2 oil. 

NOx RACT Analysis for the 1997 8-hour Ozone Standard: 

The two Turbines, each has a NOx emission limit of 0.70 lbs/MMBTU from the 1-hour RACT 

determination, now the emission limitation reduced to0.68 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. 

The following were considered possible NOx controls for each combustion turbine: Water/steam Injections, 

Selective Catalytic Reduction (SCR), and conversion to natural gas. To switch to NG would result in NOx emissions 

reductions of around 65%. This option requires the installation of a new gas pipeline and a pressure regulating 

station. Conversion to natural gas was determined technologically feasible, but there is no gas service to this 
6/24/15

building currently. Estimation from PGW have been in the neighborhood of four (4) million dollars to run this line 

(permits, survey and staking, cleaning & grading, trenching, pipe stringing, lowering in & backfilling, hydrostatic 

testing, cleanup & restoration, and pipe and accessories cost). This cost does not include the pressure regulating 

station. 

SCR injects ammonia upstream of a catalyst. NOx, ammonia (NH3), and oxygen (O2) react on the surface of the 

catalyst to form nitrogen (N2) and water (H20). NOx emissions would be reduced by around 80%. Water/Steam 

Injection increases thermal mass by dilution which reduces peak temperatures in the flame zone. This control would 

reduce NOx emissions by around 60%. 

Baseline NOx emissions for each unit was determined based on an 838 MMBTU/hr capacity, 8,760 hours per year, a 

proposed 0.68 lbs/MMBTU NOx emission limit, and a 15% capacity factor limit from the original RACT Plan 

Approval (PA Permit Number 51-4903) issued on July, 2001. Baseline emissions are 374.38 tons per year for each 

unit. The proposed 0.68 lbs/MMBTU limit lowers a 0.7 lbs/MMBTU limit in the original RACT plan approval and 

isbased based on past stack test results. The sulfur in fuel limit was added because a 2005 study from the 

Brookhaven National Laboratory indicates that ultra low sulfur fuel can reduce NOx emissions 

Source Control 

Technologies 

Baseline NOx 

Emissions 

(tpy) 

NOx 

Reduction 

(%) 

NOx 

Reduction 

(tpy) 

Total 

Annualized 

Cost 

Cost Effectiveness 

($/Ton) 

Exelon 

Richmond 

Water/Steam 

Injection 

374.38 60 224.63 $725,492 3,230 

SCR 374.38 80 299.50 $2,913,987 9,730 

Conversion to NG 374.38 65 243.34 $1,664,829 6,842 

All of these control options have been determined economically unreasonable. Additionally, these units typically 

operate no more than 10 hours in a month or 20 hours annually, with actual emissions a fraction of their potential to 

emit 

Thus, AMS proposes as RACT foreach combustion turbine a rolling 12-month capacity factor limit of less than 15% 

(based on net generation), a NOx emission limit of 0.68 pounds per MMBTU, and a requirement to install, maintain, 

and operate the unit in accordance with manufacturer’s specifications. 

Conclusions and Recommendations: 

AMS proposes as RACT for the 8-hour ozone standard the following revisions to the SIP-approved RACT Plan 

Approval (PA Permit Number 51-4903) for the Exelon - Richmond Station: 

 Replacing the NOx emission limits of each combustion turbine, of 0.7 lbs/MMBTU, with 0.68 

lbs/MMBTU and 569.84 lbs/hr. 

6/24/15

Edward Wiener, Chief of Source Registration Date 
6/24/15

Detail Calculations Summary Estimating Approach and Basis 

Estimates of Total Capital Investment (TCI), annual costs, Potential emission reductions, and cost effectiveness are 

prepared for each of the feasible control technology cases above. 

‐ EPA’s Air Pollution Control Cost Estimate Manual, January 2002, 6th edition was used 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) to A(Annual amount), A=P(A/P,i%,n), 

(1 ) 1

(1 )

 

  n

n

i

i i CR 15% interest and 20 yrs = A/P=0.1598 

Where i= Annual interest Rate; n= control system life; Annual cost = TCI x CRF 

References for Cost Calculations for all cost elements

North East States for Coordinated Air Use Management (NESCAUM); 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; Cost analysis and engineering 

economics book (Michael R. Lindeburg) and PADEP Guidelines for RACT SIP revision under 

the 8-hr Ozone NAAQS, Sep 2006 (Most elements of costs are taken from this document of 

pages 5 and 18) and from 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 (page 2-27(2.5.5), I-52 table 1.13, Appendix A) and from other States 

Reference for Consumer Price Index (CPI) is used to adjusted for inflation by taking percentage 

increases from 1999 to 2014 (for each $1,000,000 of 2013 it is $1,004,000 for 2014 (0.4%) from 

United States Department of Labor-Bureau of Labor Statistics, which is considered as very 

minimum increment. www.bls.gov

1. From US Bureau of Labor Statics 

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

The big change is from 2004 through 2007 control equipment increase by 70% 

For the Catalyst, The catalyst life is 5 years. The annual cost is given by the sinking fund factor, 

the amount of money the facility will need to set aside each year to be able to replace the catalyst 

at the end of its life, based on the lifespan of the catalyst and the interest rate. 

Sinking Fund Factor (SFF) = Convert from F (Future) to A(Annual amount), A=F(A/F,i%,n), 

(1 ) 1  n i

i SFF 8% interest and 5 yrs = A/F=0.1705 

Where i= Annual interest Rate (8%); n= catalyst system life (5 years); 

Catalyst Annual Cost = SFF x Catalyst Cost 
6/24/15

EXELON RICHMOND

Table 1 Detail Calculations for Exelon Richmond Turbines SCR 

 Exelon Richmond Data Factors used 

Turbine Capacity 66 MW (each) 15 % Capacity Factor 

 Total capital Cost 

 

Total Capital Investment Cost (TCI) $17,414,613 TCI from original 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. 

 

Annual Operating Costs 

Direct Annual Cost 

Electricity Cost3 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr 

(PA DEP RACT State 

Implementation Plan (SIP) 

revision, Sep, 2006, page 18) 

Operator4 $16,425 0.5hr/shift, 3 shift/day, $30/hr 

Supervisor4 $2,463.75 15% of Operator 

Maintenance4 $19,162.50 0.5hr/shift, 3 shift/day, $35/hr 

Material4 $19,162.50 100% of Maintenance 

Catalyst cost4 $190,000 total catalyst 

Sinking Fund Factor 0.1705 

Total catalyst Replacement Cost2 $32,395 

Total Direct Annual Cost $159,689 

 

Indirect Annual Cost 

Overhead4 $11,497 60% of maintenance-OAQPS1

Administrative Charge4 $348,292 2% of TCI-OAQPS1

Property Taxes4 $174,146 1% of TCI-OAQPS1

Insurance4 $174,146 1% of TCI-OAQPS1

Capital Recovery $2,046,217 20 yrs @10% -OAQPS1

Total Indirect Annual Cost $2,754,298 

 

Total Annual Operating Costs $2,913,987 

NOx Emission Reduction (TPY) 299.50 

Cost Effectiveness ($/ton NOx 

removed) 

$9,730 

o 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. 

o 2 Sinking Fund Factor: For the Catalyst, The catalyst life is 5 years. The annual cost is given by the sinking fund factor. Sinking Fund 

Factor (SFF) = Convert from F (Future cost) to A(Annual amount), A=F(A/F,i%,n), Catalyst Annual Cost = SFF x Catalyst Total Cost 

o 3 Electricity cost: we assume 75 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 A- NOx Control Analysis, A.1 Vendor Information, A-2 Cost Calculation

o 4Cost 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 NAAQS, Sep 2006 (Most elements of 

costs are taken from this doc of page 5 and 18) and from 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 (page 2-27(2.5.5), I-52 table 1.13, Appendix A) 

and from other States 
6/24/15

Table 2 Detail Calculations for Exelon Richmond Turbines Water Injection 

 Exelon Richmond Data Factors used 

Turbine Capacity 66 MW (each) 15 % Capacity Factor 

 Total capital Cost 

 

Total Capital Investment Cost (TCI) $3,725,099 TCI from original 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. 

 

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-OAQPS 

Administrative Charge $74,501 2% of TCI-OAQPS1

Property Taxes $37,251 1% of TCI-OAQPS1

Insurance $37,251 1% of TCI-OAQPS1

Capital Recovery $437,699 20 yrs @10%-OAQPS1

Total Indirect Annual Cost $598,198 

 

Total Annual Operating Costs $725,492 

NOx Emission Reduction (TPY) 224.63 

Cost Effectiveness ($/ton NOx 

removed) 

$3,230 

o 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. 
6/24/15

Table 3 Detail Calculations for Exelon Richmond switching to NG from fuel oil 

Exelon Richmond Factors used 

Turbine Capacity 838 MMBTU/hr 

(66 MW) 

 

Sub Total Capital 

Investment Cost (TCI) 

$4,438,629 Natural gas price from USA Energy 

Information Administration (EIA)4 

=($6.5/1000 ft3)* (1/127 kwh/1000 ft3) 

*(66000 kw * 8760 hr/yr*15%)5

Sub TCI with NG Line 

 

$4,000,000 For NG Line 

construction 

from PGW $4.0 

million 

TCI from other similar source (Veolia 

Edisson) RACT proposal plus inflation 

adjustment and Prorated based on capacity. 

Total TCI 

 

$8,438,629 

Capital Recovery $1,348,493 0.1598 20 yrs @15% -Original RACT Proposal 

Annual Operating Costs 

Direct Annual Cost 

Electricity Cost3 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr (PA DEP 

RACT State Implementation Plan (SIP) 

revision, Sep, 2006, page 18)4

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 $88,773 2% of TCI-OAQPS1

Property Taxes $44,386 1% of TCI-OAQPS1

Insurance $44,386 1% of TCI-OAQPS1

Total Indirect Annual 

Cost 

$189,043 

 

Total Annual Operating 

Costs 

$1,664,829 

 

NOx Emission 

Reduction (TPY) 

243.34 

Cost Effectiveness ($/ton 

NOx removed) 

$6,842 

o

5

US Energy Information Administration (EIA) 

http://www.eia.gov/dnav/ng/ng_pri_sum_dcu_SPA_m.htm

http://www.eia.gov/naturalgas/weekly/

127 kwh per Mcf of NG; $6.5/Mcf natural gas; 15% capacity factor