CITY OF PHILADELPHIA

DEPARTMENT OF PUBLIC HEALTH

AIR MANAGEMENT SERVICES

RACT PLAN APPROVAL

Effective Date: January 9, 2015 Expiration Date: None Replaces Permit No. None

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 Efficiency

Permittee: Veolia Energy Philadelphia, Inc Location: 2600 Christian Street, Philadelphia, PA 19146 Mailing Address: 2600 Christian Street, Philadelphia, PA 19146 SIC Code(s): 4961

Plant ID: 10459

Facility Contact: Jessica Hartley Phone: (267) 350-5865

Permit Contact: Floyd Rupple Phone: (267) 350-5819

Responsible Official: Michael J Smedley

Title: VP and GM

1/9/2015 Edward Wiener, Chief of S ource Registration DateRACT PLAN APPROVAL Veolia En ergy Efficiency PA, LLC Page 2

1/9/2015 The RACT plan approval is subj ect 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 Energy Efficiency LLC. This includes the following emission sources and control equipment:

A. Emission Sources

(1) Boiler #1: Steam boiler with a capacity of 297.91 MMBTU/hr. The boiler fired and burns #2

oil and Natural Gas.

(2) Boiler #2: Steam boiler with a capacity of 297.91 MMBTU/hr. The boiler fired and burns #2

oil and Natural Gas.

B. Control Equipment

(1) Boiler #1 and #2 shall be modified with ultra low NOx burners.

2. This approval requires and authorizes:

A. Boiler #1 and #2 shall be modified with ultra low NOx burners.

B. The combined quantity of fuel oil burn ed by Boiler #1 and Boiler #2 shall not exceed 5,350,000 gallons in any roll ing 12-month period.

3. Stack Emission Limitations

A. The maximum air contaminant emissions from thes e sources shall be limited at stack outlet to:

(1) Nitrogen Oxides (NOx):

Nitrogen Oxide (NO

x ) emission from each boiler shall not exceed the following:

(a) Natural Gas 0.01 lb/MMBTU heat input 30- day rolling average (9 ppm @ 3% O2) No. 2 fuel oil 0.08 lb/MMBTU heat input 30- day rolling average (62 ppm @ 3% O2)

(b) Nitrogen Oxides (NO

x ) emissions from both boilers combined shall not exceed 52.31 tons per year, calculated on a 12- month rolling period.

4. RACT Implementation Schedule

A. Upon issuance of this approval, Veolia Energy Ef ficiency shall begin immediate implementation of the measures necessary to comply with the approved RACT proposal.

B. Veolia Energy Efficiency shall maintain u ltra low NOx burners (ULNB) on each Boiler.

5. Testing and Monitoring RequirementsRACT PLAN APPROVAL Veolia En ergy Efficiency PA, LLC Page 3

1/9/2015 A. Continuous nitrogen oxides and oxygen monitors a nd recorders shall be operated on each Boiler in

order to measure and record the concentrations of these gases emitted from the boiler outlet/stack

inlet. The continuous emission monitors must conform to USEPA performance specifications in 40 CFR Part 60, Appendix B and Pa. DER Conti nuous Source Monitoring Manual Rev. No. 4, July 1987.

6. Recordkeeping and Reporting Requirements

A. Compliance with the NOx emission limits shall be monitored and recorded based on NOx CEM data and AMS-approve d stack test data.

B. The facility shall monitor and record compliance w ith them based on fuel type, fuel usage, and

NOX CEMs for each boiler.

C. Veolia Energy Efficiency 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. These records shall include fuel consumption, fuel sulfur content, and

NOx emissions.

D. The records shall provide sufficient data and calculations to clearly demonstrate that the requirements of §129.91-129.94 are met.

E. Data or information required to determine complia nce shall be recorded and maintained in a time

frame consistent with the aver aging period of the requirement.

F. Records shall be retained for at least five year s and shall be made available to AMS on request.

G

. Revisions to any emission limitations incorpor ated in this RACT Approval will require resubmission as revision to the PA State Implemen tation Plan. The applicant shall bear the cost of public hearing and notificati on required for EPA approval as stipulated in 25 PA Code §129.91(h)