CITY OF PH ILADELPHIA Department of Public Health

Environmental Protection Division Air Management Services



### InterOffice Memo

To: File

From: Biji Pandisseril

Date: December 12, 2014

Subject: RACT Analysis for Northeast Water Pollution Control Plant (PLID # 09513)

Company Description:

Northeast Water Pollution Control Plant is a water treatment plant located at 3899 Rich mond Street, Philadelphia, PA 19137. The facility’s air emission sources include liqui d treatment processes, solids treatment processes, four 20-50 MMBTU/hr boilers, eight boilers <15 MMBTU/hr, four digester gas flares, and a cold degreaser

Applicability for NOx and VOC RACT:

Northeast Water Pollution Control Plant (NWPCP) is no t a major source for Nitrogen Oxides (NOx) emission having potential NOx emissions less 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 facility is not a major source of Volatile Organic Compounds (VOC) having potential VOC emissions is greater than 50 tons per year, the major source threshold in Phila delphia County that is applicable to VOC RACT for the 1997 8-hour ozone NAAQS.

The facility is being re-evaluated for RACT under the 1 997 8-hour Ozone National Ambient Air Quality Standards (NAAQS).

NOx Emission Sources an d NOx RACT Analysis:

Process Descriptions – NOx Sources:

NWPCP NOx emission sources include combustion sources such as boilers, flares, and cogeneration facility.

Below is a list of NOx sources at th e NWPCP and the potential to emit (PTE).

The combined NOx were calculated based AP-42 factors. The combined NOx poten tial emission is less than 68 tpy. Therefore the facility is not applicable to NOx RACT requirements.

Following is the PTE calculation based on AP-42 factors:

External Combustion Sources: Rating (MMBtu/hr) Fuel Types NOx PTE (tpy) Bryant Steam Corp Boiler 0.580 No. 2 Oil 0.36

Smith Boiler 0.661 Natural Gas 0.28

HB Smith Boiler 1.139 Natural Gas 0.49 Weil McLain Boiler (Admin Bldg) 1.632 Natural Gas 0.70 Two (2) Cleaver Brook Boilers 14.645 each No. 2 Oil /Digester Gas 18.32 Continental Boiler* 23.097 Digester Gas 9.92 Kewanee Boiler* 20.085 Digester Gas/Natural Gas 8.62 Two (2) Hurst Boiler* 20,085 eac h Digester Gas/Natural Gas 17.24

Jackson & Chruch Hot Air Furnace 1.510 Natural Gas 0.65 Broad USA Inc Absorption Chiller 0.750 Digester Gas/Natural Gas 0.24Flares: Capacity Fuel Types NOx PTE (tpy) Four (4) Digester Gas Flares 45,860 SCF/hr each Dige ster Gas 0.27

Cogeneration Engines Capacity Fuel Types NOx PTE (tpy Four (4) CoGeneration Units** 1417 kWeach Digester Gas/Natural Gas 10.81

Facility Total NOx PTE: 68 tpy

* The Continental, Kewanee, and Hursts are greater than 20 MMBTU/hr but less than 50 MMBTU/hr ** The facility has obtained a permit for five co-gen eration units but only four have been installed. The permit also allowed for the installation of the Siloxane Flare which has not been installed.

With the addition of the fift h co-generation unit and the Siloxane Flar e the PTE would not greater than 72 tpy.

Each co-generator unit is vented through a SCR.

VOC Sources and VOC RACT Analysis:

NWPCP VOC emission sources include combustion source s, cold degreaser, and wastewater treatment plant operations. Below a list of VOC sources at the NWPCP an d the potential to emit (PTE) calculation for the facility

External Combustion Sources: Rating (MMBtu/hr) Fuel Types VOC PTE (tpy) Bryant Steam Corp Boiler 0.580 No. 2 Oil 0.05

Smith Boiler 0.661 Natural Gas 0.02

HB Smith Boiler 1.139 Natural Gas 0.03 Weil McLain Boiler (Admin Bldg) 1.632 Natural Gas 0.04 Two (2) Cleaver Brook Boilers 14.645 each No. 2 Oil /Digester Gas 2.76 Continental Boiler* 23.097 Digester Gas 0.55 Kewanee Boiler* 20.085 Digester Gas/Natural Gas 0.47 Two (2) Hurst Boiler* 20,085 each Digester Gas/Natural Gas 0.94

Jackson & Chruch Hot Air Furnace 1.510 Natural Gas 0.4 Broad USA Inc Absorption Chiller 0.750 Digester Gas/Natural Gas 0.01

Flares: Capacity Fuel Types VOC PTE (tpy) Four (4) Digester Gas Flares 45,860 SCF/hr each Digest er Gas 0.05

Based of AP-42 Table 13.5-2 (8/2014 Draft) http://www.epa.gov/ttn/chief/ap42/ ch13/final/dc13s05_8-19-14.pdf

Cogeneration Engines Capacity Fuel Types VOC PTE (tpy) Four (4) CoGeneration Units** 1417 kWeach Digester Gas/Natural Gas 8.32

Cold Degreaser VOC PTE (tpy) Following is the PTE VOC calculation for the degreaser is based on using AP-42 factor, 0.33 Section, Table 4.6-2: VOC PTE = AP-42 emission factor x (number of unit) VOC PTE = (0.33 tons/year/unit) X 1 unit VOC PTE = 0.33 tons/year

Wastewater treatment plant operations including pretreatment, The potential to emit for VOC at the NWPCP for wastewater treatment operations is estimated to be 20 tons per year. This number was obtained by looking at facility’s m onthly VOC estimates for the last three years (July 2011- June 2014) and the highest monthly estimate was used and multiplied by 12, for a yearly PTE number. These estimates were developed using the TOXCHEM model that was tailored for wastewater facilities. The TOXCHEM model is an EPA-approved proprietary software package developed and distributed by Enviromega, Ltd. The model essentially is a sophisticated mass balance that incorporat ed kinetic equations to determine the fate of organiccompound. Influent VOC concentrations and plant flows were used in the model to estimate the monthly

concentration of VOC.



### MONTH 2014 2013 2012 2011

lbs Carbon

/month lbs Carbon /month lbs Carbon

/month lbs Carbon

/month



### JAN 3329 1,025 2,373
FEB 2941 1,014 3,323
MAR 2719 1,066 2,475
APR 2562 1,453 2,304
MAY 2467 1,192 3,227
JUN 2931 1,092 2,197
JUL 1,905 2,834 2139
AUG 2,045 2,690 3133
SEP 1,594 2,573 2792
OCT 1,784 3,251 2180
NOV 1,959 2,680 1883
DEC 1,633 2,474 2158

PTE VOC = (3329/2000) *12 = 20 tpy

The total VOC PTE for the facility is less than 34 tpy.

Conclusions and Recommendations: Since the potential for VOC and NOx sources are below the ap plicable RACT limits, the facility is not applicable to

RACT under the 1997 8-hour ozone standard.

1 / 9 / 1 5

Edward Wiener, Chief of Source Registration Date