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 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 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 Source Registration Date 
RACT PLAN APPROVAL Veolia Energy Efficiency PA, LLC Page 2 

1/9/2015 

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 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 burned by Boiler #1 and Boiler #2 shall not exceed 5,350,000 

gallons in any rolling 12-month period. 

3. Stack Emission Limitations 

 

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

(1) Nitrogen Oxides (NOx): 

Nitrogen Oxide (NOx) 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 (NOx) 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 Efficiency shall begin immediate implementation 

of the measures necessary to comply with the approved RACT proposal. 

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

5. Testing and Monitoring Requirements 
RACT PLAN APPROVAL Veolia Energy Efficiency PA, LLC Page 3 

1/9/2015 

A. Continuous nitrogen oxides and oxygen monitors and 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 Continuous 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-approved stack test data. 

B. The facility shall monitor and record compliance with 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 compliance 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 compliance shall be recorded and maintained in a time 

frame consistent with the averaging period of the requirement. 

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

G.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)