5/20/15

CITY OF PHILADELPHIA 

Department of Public Health 

Environmental Protection Division 

Air Management Services 

InterOffice Memo 

To: File 

From: Edward Wiener & Kassahun Sellassie 

Date: May 20, 2015 

Subject: 1997 8-Hour RACT Analysis for Veolia Energy – Schuylkill 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: 

Veolia Energy Philadelphia - Schuylkill Station (Veolia – Schuylkill) owns and operates a steam generating facility 

in 2600 Christian Street, Philadelphia, PA 19146. Equipment used at the facility includes three (3) boilers. The 

facility was 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: 

In addition to owning Veolia – Schuylkill, Veolia is part owner of the Veolia Energy Efficiency PA (LLC), a steam 

generating facility, and Grays Ferry Cogeneration Partnership (GFCP), an electric generating facility, all facilities 

adjacently located at 2600 Christian Street, Philadelphia, PA 19146. The three facilities have been determined a 

single source since Plan Approval Application No. 10277 was submitted for the new Veolia Energy Efficiency 

boilers on October 25, 2010. The three facilities as a single source are major for 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. The three facilities as a single source are not major for 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. Veolia Schuylkill is subject to 1-hour ozone 

RACT, as approved into the SIP by EPA on December 15, 2000 (65 FR 78418), and is being evaluated for 1997 8-

hour ozone RACT as documented in this memo. RACT determinations for GFCP and Veolia Energy Efficiency 

have been provided in separate memos. 

Process Descriptions: 

Veolia - Schuylkill Station currently has two (2) tangential-fired boilers rated 795 MMBTU/hr (CU02 and CU01-

Boilers No. 23 and No. 24) and one (1) front wall-fired boiler rated 761 MMBTU/hr (CU05-Boiler No. 26). Each 

boiler burns No. 6 oil as the primary fuel. Boilers No. 23 and No. 24 both burn No. 2 oil as the ignition fuel. 

These boilers do not operate at maximum capacity for 365 days per year. The boilers at Schuylkill Station operate 

seasonally and predominately supply district steam heat as such the boilers operate at peak capacity in the non-ozone 

season and operate minimally or not at all during ozone season. See emissions inventories in Appendix. 

NOx RACT Evaluation: 
Veolia Schuylkill’s three boilers, Boiler #23, #24, and 26, are subject to 1-hour RACT. As a result of AMS case-bycase-RACT determination, the facility is subject to a RACT Plan Approval (PA Permit Number 51-04942) issued on 

December 1, 1999 and approved into the SIP by EPA on December 15, 2000 (65 FR 78418). 

In the 1-hour RACT Plan Approval, the boilers were given a combined No. 6 oil limit of 65,526,316 gallons per 

rolling 12-month period and a combined NOx emissions limit of 1,646 tons in any rolling 12-month period. Also, 

Boilers No. 23 and No. 24 each were given NOx emission limits of 0.35 pounds per MMBTU. Boiler No. 26 was 

required to have low NOx burners (LNB) installed and was given a NOx emission limit of 0.36 pounds per 

MMBTU on a 30-day rolling average. 

 

Boiler No. 24 was shut down in January 2014 as part of Plan Approval No. 10277 and thus is not being re-evaluated 

for RACT. 

The following were considered possible NOx controls for Boilers #23 and #26: (1) Selective Catalytic Reduction 

(SCR), (2) Ultra Low-NOx Burners and switch to natural gas (ULNB with NG), (3) Selective Non-Catalytic 

Reduction (SNCR), (4) Flue Gas Recirculation (FGR), (5) Low NOx Burner (LNB) without switching fuel type, (6) 

Ultra Low NOx Burners (ULNB), and (7) Burners Out of Service (BOOS) and other combustion modifications. 

The following were determined technologically infeasible for all boilers: Burners-out-of-service and other 

combustion modifications were determined technologically infeasible for both boilers because they would cause a 

reduction in boiler capacity, which could cause issues during peak periods. Selective Non-Catalytic Reduction was 

determined to be technologically infeasible for both boilers because the boilers have frequent load changes and 

periods of low load operation. 

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

around 30% for Boiler #23 and around 12.3% for Boiler #26 (the reduction for Boiler #26 is lower because it was 

modified with Low-NOx Burners as a result of the 1 hr case-by-case RACT). 

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

around 20% for Boiler #23. Boiler #26 was modified with Low-NOx Burners as a result of the 1 hr case-by-case 

RACT. 

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. FGR is determined technologically infeasible for Boiler No. 23 due to space 

limitations. NOx emissions from Boiler No. 26 are expected to be reduced by around 40 % with this technology. 

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

by around 57.2% for Boiler #23 and around 34.4% for Boiler #26 (the reduction is greater than ULNB alone due to 

the switch from oil to lower emitting natural gas, Boiler #26 has a lower reduction because it has Low-NOx Burners 

from the 1 hr case-by-case RACT). 

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 are reduced by around 80%. SCR is determined 

technologically infeasible for Boiler No. 23 due to space limitations. 

Boiler No. 23 has a NOx emission limit of 0.35 lbs/MMBTU from the 1-hour RACT determination. This limit is 

being reduced to 0.34 lb/MMBTU, based on stack test data. , 

Additionally, under the facility’s Title V/State Operating Permit No. V11-014 issued May 24, 2012 (Section D. 2 

(b)(3)), the boiler is restricted to operate up to 30% of its hourly heat input capacity on an annual basis. This heat 

input limit is Federally enforceable and thus considered in this RACT analysis. 

The following NOx controls were determined technologically feasible for Boilers No. 23 and No. 26. A summary of 

cost effectiveness is provided below. The RACT baseline NOx emissions for Boiler No. 23 are 355.15 tons per year 

based on the applicable capacity factor of 30% and revised NOx emissions rate[795 mmbtu/hr *8760 hr/yr * 0.34 

lb/mmbtu *0.3= 355.15 tons per year]. The RACT baseline emissions for Boiler No. 26 are 1199.9 tons per year 

and was determined based on the rated capacity of 761 MMBTU/hr, 8,760 hours per year, and the 0.36 lbs/MMBTU 

NOx emission limit from the 1-hour RACT determination. 

For more detailed calculations, please see the Appendix. 
 

Source Control 

Technology 

Baseline NOx 

Emissions (tons 

per year) 

NOx 

Reduction 

(%) 

NOx 

Reduction 

(tpy) 

Total Annualized 

Cost ($/year) 

Cost 

Effectiveness 

($/Ton) 

Schuylkill 

Boiler #23 

ULNB 355.15 30 106.54 1,049,236 9,848 

LNB 355.15 20 71.03 986,193 13,884 

ULNB with NG 315.15 57.2 203.14 1,972,937 9,712 

Schuylkill 

Boiler #26 

ULNB 1199.9 12.3 147.59 653,905 4,431 

ULNB with NG 1199.9 34.4 412.77 1,552,809 3,762 

FGR 1199.9 40 479.96 1,357,452 2,828 

SCR 1199.9 80 959.92 3,342,088 3,482 

All of these control options have been determined economically unreasonable. Additionally, these boilers seldom 

operate during the ozone season, as noted in the Appendix. Actual NOx emissions for each boiler are a fraction of 

the potential emissions listed above. 

Although no additional RACT controls are reasonable for Boiler #23, the existing 30% capacity factor limit 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 355.15 tons per 12-month rolling NOx emissions limit based on the 30% 

capacity factor for Boilers # 23. Additionally, after evaluating public comments, the boiler is being given an 

additional 270.30 lbs/hr limit, which corresponds to the lbs/MMBTU limit and capacity. 

Currently allowed RACT emissions for Boiler #23: 1,183.8 tons per rolling of 12 months 

Proposed allowed RACT emissions for Boiler #23: 355.15 tons per rolling of 12 months 

AMS finds that the existing RACT limits for Boiler No. 26 continue to represent RACT. After evaluating public 

comments, Boiler No 26 is being given additional 0.41 lbs/MMBTU and 312.01 lbs/hr limits, both on an hourly 

basis, so there are additional shorter-term limits. AMS determined the boiler could achieve these shorter term limits 

under existing technology based on CEM data.

By taking the heat input restriction on Boiler #23, the total potential emissions from Boilers #23 and #26 (1,555.1 

tons per year) are less than the 1-hour RACT combined emissions limit of 1,646 tons in any rolling 12-month 

period. AMS is proposing to remove the 1,646 tons per year limit. 

With the removal of Boiler #24 and the 30% capacity factor restriction on Boiler #23, the combined potential #6 oil 

usage for Boilers #23 and #26 is 58,370,800 gallons per rolling 12-month period (based on the rated capacities, 

8,760 hrs/yr, 0.15 MMBTU/gal of No. 6 oil, and a 30% capacity factor for Boiler #23). Since this is lower than the 

existing combined No. 6 oil limit of 65,526,316 gallons per rolling 12-month period, the existing limit is being 

removed. 

Conclusions and Recommendations: 

AMS is determining the 365.6 tons of NOx per rolling 12-month period emission limit for Boiler #23 as an 

additional RACT requirement. AMS requests this limit to be approved into the SIP. Also, AMS requests to remove 

the combined NOx emissions limit and the combined No. 6 oil usage limit for Boilers 23 and 26. 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 Schuylkill. 

The following requirements are recommended as RACT:

- Boiler No. 23 NOx emission shall not exceed 0.34 pounds per MMBTU and 355.15 tons of NOx per rolling 

12-month period. 

- Boiler No. 26 is required to have low NOx burners (LNB). Its NOx emissions shall not exceed 0.36 

pounds per MMBTU on a 30-day rolling average. Boiler No 26 was given the additional NOx limits of 

0.41 lbs/MMBTU on an hourly basis and 312.01 lbs/hr on an hourly basis. 

- Compliance shall be monitored and recorded based on annual NOx stack tests for each boiler 

and NOx CEMS for Boiler #26. 
- Compliance shall be monitored and recorded based on annual NOx stack tests for each boiler 

and NOx CEMS for Boiler#26. The facility shall monitor and record compliance with them based on daily 

hours of operation, fuel type, fuel usage, fuel sulfur content for each boiler, and NOX CEMs for boiler #26 

and annual stack test for Boiler #23 compliance with them based on fuel usage and the annual NOx stack 

tests 

5/20/15

Edward Wiener, Chief of Source Registration Date 

Appendix

Ozone Season Emission Inventory for Veolia Schuylkill Boiler #26 & Boiler 23 combined that indicated that 

during ozone season the emissions are zero (0) and yearly emissions combined two boilers #23 & #26 is 

5.36 tpy in April, 2013. Based on emission data, the boiler #26 which has LNB doesn’t need to install SCR or 

other control device. 

Year of 

Inventory 

Month of 

Inventory 

NOx Emissions 

(tons) 

2011 April 17.85

2011 May 0.00

2011 June 0.10

2011 July 0.00

2011 August 0.00

2011 September 0.35

2011 October 12.24

2012 April 9.32

2012 May 0.00

2012 June 0.00

2012 July 0.39

2012 August 0.00

2012 September 1.09

2012 October 0.05

2013 April 5.36

2013 May 0.00

2013 June 0.05

2013 July 0.00

2013 August 0.00

2013 September 0.00

2013 October 0.00

Detailed Calculations Summary

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

technology: 
‐ Total Capital Investment (TCI) 

‐ NOx Emission Reduction (tons/yr) 

‐ Cost Effectiveness ($/ton) 

‐ 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 20% interest and 10 yrs = A/P=0.2385; Annual Cost = TCI x CRF 

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 10% interest and 5 yrs = A/F=0.1638 

Where i= Annual interest Rate (10%); n= catalyst system life (5 years); 

Catalyst Annual Cost = SFF x Catalyst Cost 

Ammonia Cost 

2NH3 + 2NO + 1/2O2 2N2 + 3H2O 

Ammonia Cost = (17/30 * 2moles of NH3/2 moles of NO *1.05 * NOx emission (tpy) *$410/ton) 

NH3 = Ammonia, NO = Nitric Oxide; O2 = Oxygen; H2O = Water; 1.05= Ammonia slip and excess ammonia 
Veolia - Schuylkill Boiler #23

Table 1 Detail Calculations for Veolia - Schuylkill Boiler for ULNB with NG 

Veolia SCH Boiler # 23 Factors used CF=30% Summer time no NOx 

emission or very low NOx <1 tpy 

Boiler Capacity 795 MMBTU/hr 

 Total capital Cost

Total Capital Investment Cost 

(TCI) 

$6,585,800 TCI from 1 hour RACT Proposal plus 

inflation adjustment. Original TCI includes 

equipment and installation cost estimates 

from ABB Power Plan Service Sales and 

JACA Corp4

. 

Capital Recovery $1,570,713 0.2385 10 yrs @20% from 1 hr RACT; A/P=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 $11,498 60% of maintenance-OAQPS1

Administrative Charge $131,716 2% of TCI-OAQPS1

Property Taxes3 $65,858 1% of TCI-OAQPS1

Insurance3 $65,858 1% of TCI-OAQPS1

Total Indirect Annual Cost $274,930 

 

Total Annual Operating Costs $1,972,937 

 NOx Baseline Emissions (TPY) 355.15 Based on 795 mmbtu/hr, 8760 hr/yr , 0.34 

lb/mmbtu RACT limit, and 0.3 capacity 

factor 

NOx Emission Reduction (TPY) 203.14 Based on 57.2 % of NOx removed. 
Cost Effectiveness ($/ton NOx 

removed) 

$9,712 
Table 2 Detail Calculations for Veolia Schuylkill Boiler ULNB 

Veolia SCH Boiler # 23 

 

 Factors used CF=30% Summer time no NOx 

emission or very low NOx <1 tpy 

Boiler Capacity 795 mmbtu/hr 

 Total capital Cost

Total Capital Investment 

Cost (TCI) 

$3,269,100 TCI from 1 hr RACT proposal plus inflation 

adjustment. Original TCI includes equipment and 

installation cost estimates from ABB Power Plan 

Service Sales and JACA Corp. 

Capital Recovery $779,680 0.2385 10 yrs @20% -from 1-hr RACT ; A/P=0.2385 

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-OAQPS 

Administrative Charge $65,382 2% of TCI-OAQPS1

Property Taxes $32,691 1% of TCI-OAQPS1

Insurance $32,691 1% of TCI-OAQPS1

              

Total Indirect Annual Cost $142,262 

 

Total Annual Operating 

Costs 

$1,049,236 

 NOx Baseline Emissions 

(TPY) 

 355.15 Based on 795 mmbtu/hr, 8760 hr/yr , 0.34 

lb/mmbtu RACT limit, and 0.3 capacity factor 

NOx Emission Reduction 

(TPY) 

106.54 Based on 30 % of NOx removed. 

Cost Effectiveness ($/ton 

NOx removed) 

$9,848 
Table 3 Detail Calculations for Veolia Schuylkill Boiler LNB 

Veolia SCH Boiler # 23 

 

 Factors used CF=30% Summer time no NOx 

emission or very low NOx <1 tpy 

 Boiler #23 Capacity 795 MMBTU/hr 

Total capital Cost

 

 LNB is 2-5% less in TCI than ULNB EPA 454/R-94-

0022; NOx Control report, Northeast States for 

Coordinated Air Use Management, Dec 

2000(NESCAUM) 

Total Capital Investment 

Cost (TCI) 

$3,105,645 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 $740,696 0.2385 10 yrs @20% -from 1 hr RACT 

Annual Operating Costs 

Direct Annual Cost 

Electricity Cost 

$52,560 

75kw @ $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 $109,774 

 

Indirect Annual Cost 

Overhead $11,498 60% of maintenance-OAQPS1

Administrative Charge $62,113 2% of TCI-OAQPS1

Property Taxes $31,056 1% of TCI-OAQPS1

Insurance $31,056 1% of TCI-OAQPS1

              

Total Indirect Annual Cost $135,723 

 

Total Annual Operating 

Costs 

$986,193 

 NOx Baseline Emissions 

(TPY) 

 355.15 Based on 795 mmbtu/hr, 8760 hr/yr , 0.34 lb/mmbtu 

RACT limit, and 0.3 capacity factor 

NOx Emission Reduction 

(TPY) 

71.03 Based on 20 % of NOx removed. 

Cost Effectiveness ($/ton 

NOx removed) 

$13,884 
Veolia - Schuylkill Boiler #26

Table 4 Detail Calculations for Veolia - Schuylkill Boiler for SCR 

Grays ferry Factors used 

 

761 MMBTU/hr 

 

 Total capital Cost

 

Total Capital 

Investment Cost 

(TCI) 

$6,385,200 Based EPA Cost Control Manual of 

$6000/MMBTU/Hr. Escalate 1997 $ using 

the Marshall and swift Index. 

Capital Recovery $1,020,355 0.1598 20 yrs @15% -from 1-hr RACT 

Annual Operating 

Costs 

 

Direct Annual Cost 

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

RACT State Implementation Plan (SIP) 

revision, Sep, 2006, page 18) 

Maintenance3 $95,778.00 1.5%x TCI 

Catalyst cost3 $190,000 0.1638 $190,000 total catalyst from litrature and 

vendors 

Sinking Fund Factor year 5, interest10%= A/F=0.1638 

Total catalyst 

Replacement Cost3

$31,122 

Ammonia cost 3

 

$453,709 (17/30 * 1.05 * 2 mole NH3/2 mole NO 

*NOx emission (1199.9tpy) 

*$410/ton*5yr*1.55 

Total Direct Annual 

Cost 

$650,689 

Indirect Annual 

Cost3

$1,020,355 Capital Recovery 

Total Annual Cost $1,671,044 

 

Total Annual 

Operating Costs 

$3,342,088 

 

NOx Emission 

Reduction (TPY) 

959.92 

Cost Effectiveness 

($/ton NOx 

removed) 

$3,482 
Table 5 Detail Calculations for Veolia Schuylkill Boiler FGR 

Veolia SCH Boiler # 26 

 

 No Factors used but Summer time no NOx 

emission or very low NOx <1 tpy 

Boiler Capacity 761 MMBTU/hr 

 Total capital Cost

Total Capital Investment 

Cost (TCI) 

$4,375,800 TCI from 1 hr RACT proposal plus inflation 

adjustment. Original TCI includes equipment and 

installation cost estimates from Sierra 

Environmental Engineering, Inc. 

Capital Recovery $1,043,628 0.2385 10 yrs @20% -from 1-hr RACT; ; A/P=0.2385 

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 $87,516 2% of TCI-OAQPS1

Property Taxes $43,758 1% of TCI-OAQPS1

Insurance $43,758 1% of TCI-OAQPS1

              

Total Indirect Annual Cost $186,530 

 

Total Annual Operating 

Costs 

$1,357,452 761 mmbtu/hr *8760 hr/yr * 0.36 lb/mmbtu 

NOx Baseline Emissions 

(TPY) 

1199.9 Based on 761 mmbtu/hr, 8760 hr/yr, and 0.36 

lb/mmbtu RACT limit 

NOx Emission Reduction 

(TPY) 

479.96 Based on 40 % of NOx removed. 

Cost Effectiveness ($/ton 

NOx removed) 

2,828 
Table 6 Detail Calculations for Veolia Schuylkill Boiler ULNB with NG 

Veolia SCH Boiler # 26 

 

 No Factors used but Summer time no NOx 

emission or very low NOx <1 tpy 

Boiler Capacity 761 MMBTU/hr 

 Total capital Cost

 

Total Capital Investment 

Cost (TCI) 

$5,077,264 TCI from 1 hr RACT proposal plus inflation 

adjustment. Original TCI includes equipment 

and installation cost estimates from Sierra 

Environmental Engineering, Inc.; A/P=0.2385 

Capital Recovery $1,210,927 0.2385 10 yrs @20% -from 1-hr RACT 

Annual Operating Costs 

Direct Annual Cost 

Electricity Cost $70,080 75kw @ $0.08/kwh, 8760 hrs/ 

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 $101,545 2% of TCI-OAQPS1

Property Taxes $50,773 1% of TCI-OAQPS1

Insurance $50,773 1% of TCI-OAQPS1

              

Total Indirect Annual Cost $214,588 

 

Total Annual Operating 

Costs 

$1,552,809 

 NOx Baseline Emissions 

(TPY) 

 1199.9 Based on 761 mmbtu/hr, 8760 hr/yr, and 0.36 

lb/mmbtu RACT limit 

NOx Emission Reduction 

(TPY) 

412.77 Based on 34.4 % of NOx removed. 

Cost Effectiveness ($/ton 

NOx removed) 

$3,762 
Table 7 Detail Calculations for Veolia Schuylkill Boiler ULNB 

Veolia SCH Boiler # 26 

 

 No Factors used but Summer time no NOx 

emission or very low NOx <1 tpy 

Boiler Capacity 761 MMBTU/hr 

 Total capital Cost

Total Capital Investment 

Cost (TCI) 

$1,849,600 TCI from 1 hr RACT proposal plus inflation 

adjustment. Original TCI includes equipment 

and installation cost estimates from Sierra 

Environmental Engineering, Inc. 

 

Annual Operating Costs 

Direct Annual Cost 

Electricity Cost $70,080 75kw @ $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 $36,992 2% of TCI-OAQPS1

Property Taxes $18,496 1% of TCI-OAQPS1

Insurance $18,496 1% of TCI-OAQPS1

Capital Recovery $441,130 0.2385 10 yrs @20% -from 1-hr RACT 

Total Indirect Annual Cost $526,611 

 

Total Annual Operating 

Costs 

$653,905 

 NOx Baseline Emissions 

(TPY) 

 1199.9 Based on 761 mmbtu/hr, 8760 hr/yr, and 

0.36 lb/mmbtu RACT limit 

NOx Emission Reduction 

(TPY) 

147.59 Based on 12.3 % of NOx removed. 

Cost Effectiveness ($/ton 

NOx removed) 

$4,431 

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