Your Comments Needed Today for Our Right To Breathe #FossilFreePhilly

There is fight over air quality in Philadelphia that needs your attention. Are you aware that Septa is planning to bring fossil fuels to our communities. Communities that currently have high asthma rates are being targeted to host Septa's natural gas plants. These plants would like to pipeline fracked gas from up state Pennsylvania into our city and this is not acceptable to many residents of Philadelphia and the surrounding area. Because this natural gas plant pollutes our air with harmful micro-particles.

Nitrogen oxides (NOx) – NOx contributes to the formation of ground -level ozone, also called smog. Ozone is linked to a range of respiratory illnesses including to the development of childhood asthma.

Particulate Matter – Contribute to or exacerbate asthma and heart disease. There is strong evidence linking particulates to dementia, impaired cognitive development in children, premature births, and other problems. The World Health Organization says there is no safe level of exposure.

Volatile Organic Compounds (VOCs) – Can cause eye, nose and throat irritation, shortness of breath, headaches, fatigue, nausea, dizziness, and skin problems. Higher concentrations may cause irritation of the lungs, as well as damage to the liver, kidney, or central nervous system.

Ultrafine Particulates – These particles are not yet regulated by the EPA, but many studies suggest that they are especially harmful to human health and that they are emitted in large quantities by natural gas power plants.

There is an Air Management Services public hearing on June 27th that is need of your public comment by June 24th. SEPTA’s plan to build a natural gas powered plant in the Midvale Complex has not been approved.  Any affected neighbor or citizen should submit written comments to express their objections or concerns about the SEPTA power plants. Written comments can be submitted to Ed Weiner of Air Management Services at 321 University Ave. The due date for comments in June 24, 2017. The focus of comments should be specifically about Air Quality issues.

How Did We Get To This Point?

City Council's budget hearing in May 2016: http://phlcouncil.com/wp-content/uploads/2016/05/wh051016.pdf.

COUNCIL PRESIDENT CLARKE: Okay. In your testimony, Page 3 of your testimony states the fleet enhancement are a key component of SEPTA's capital program. Bottom line, you're going to purchase a number of vehicles. So you probably may or may not be aware that there's this push because of the potential of the diversification of PGW, which is our company, the City of Philadelphia, and we support the region, and our ability to have additional fleets that use CNG will help the company significantly, particularly in this group and the expansion of our LNG plant. And I see here you want to purchase 525 hybrid electric buses, and it's kind of hard to argue against electric buses, hybrids, because they do -- is there an opportunity -- and I don't know how the vehicles are built -- that instead of using regular gas, that in a hybrid 6 vehicle you can use CNG? 

MR. KNUEPPEL: I don't believe without retrofitting the vehicle. SEPTA has investigated having our buses be CNG, and a couple years ago we did a study on that, and what it showed was that we had to do a significant amount of improvements at our garages where we store them, and we really in many cases are in very tight neighborhoods. If you think about our Allegheny bus garage, homes on three sides and school on a fourth, there's really not a lot of room to expand our footprint and be able to provide the facilities, additional facilities, we'd need for CNG. What we have looked more so is other ways to use gas, and we've converted most of our maintenance facilities and larger facilities all over to gas, and then now we have a very interesting project where what we are -- we're in the investment grade audit stage now. It's a GESA, Guaranteed Energy Savings Act, project. But we're looking to run a significant portion of the regional rail network off of gas and have a combined heat and power project up at our Wayne Junction area. That's the equivalent of over 300 buses, the amount of gas that that facility would use. So SEPTA is using gas. For us right now it's made more sense to utilize it for running regional rail, and that's what we're working on. Also in many ways for SEPTA, you heard that we just received money to start purchasing pure electric buses with batteries, and that has been something that if that technology really pans out, that will really help us and really seems to be that we'll jump over CNG and head to electric buses.

COUNCIL PRESIDENT CLARKE:  All right.  And this is an interesting  conversation, because when I talk to people representing PGW, they reference the fact that obviously electric is a cleaner-burning fuel source, but the origin of the electricity, I'm told those facilities are not as environmentally sound as the CNG-related activities.

MR. KNUEPPEL:  When we move to and we have this electric bus pilot, we're actually looking at having the charging station be fueled by natural gas.  So that is a conversation we've had with PGW and certainly with -

COUNCIL PRESIDENT CLARKE: Instead of coal and all the other things.

MR. KNUEPPEL:  Right.  And even with our regional rail project, getting away from PECO is going to provide a benefit to the region in terms of air quality and cleanliness.

COUNCIL PRESIDENT CLARKE:  All right.  You sound like you came prepared for that question.  I would like to follow up with you.  Can you just give  me -- because it may be helpful to what we're trying to do.  I don't know if the analysis that you did with respect to electric versus CNG -

MR. KNUEPPEL:  Okay. Certainly.

COUNCIL PRESIDENT CLARKE: if it was documented, could you get that to us, please.

MR. KNUEPPEL:  Yes. Absolutely.

COUNCIL PRESIDENT CLARKE: Because we have to make some decisions. We'll be making a determination on the expansion of PGW's plant and
diversification plan.  So that will be helpful to us.  Thank you.  Thank you very much.

Southeastern Pennsylvania Transit Authority (SEPTA)

Notice of Application for Plan Approval at the Midvale Bus Facility

Southeast Pennsylvania Transit Authority (SEPTA) has applied for approval of plans to install a Combined Head and Power Plant (CHP) at its Midvale Bus Facility located at 4130 Wissahickon Avenue, part of its Roberts Complex (SEPTA-Roberts). The CHP will consist of two 6113 horsepower (HP) natural gas-fired generators that will provide steam and electricity to the facility and supplemental electricity to SEPTA’s regional railcars. Each generator will be equipped with a Selective Catalytic Reduction (SCR) and Oxidation Catalyst (OC) System. The SCR reduces Nitrogen Oxide (NOx) emissions and the OC reduces Carbon Monoxide (CO), Volatile Organic Compound (VOC) and Formaldehyde (CH2O) emissions.

Estimated Emissions Impact of New Permit

The table below lists the potential increase in emissions (pollutants released into the air) associated with this project, expressed in tons per year:

Pollutant	Potential Emissions (tons/yr)
Nitrogen Oxides (NOx)	21.8
Volatile Organic Compounds (VOC)	16.4
Particulate Matter Less Than 10 Microns (PM10)	0.08
Carbon Monoxide (CO)	27.2
Sulfur Oxides (SOx)	0.09
Lead (Pb)	0.00

• Nitrogen Oxides (NOx) are gases made up of nitrogen and oxygen that are released during the burning of fuel.  In 2015, SEPTA-Roberts released 2.6 tons of NOx into the air. Under Federal regulations, a facility in Philadelphia is a major source of NOx if it has the potential to emit 25 tons in a year.   

• Sulfur Dioxide (SO2) is a colorless, irritating gas that is created when fuel containing sulfur is burned.  In 2015, SEPTA-Roberts released 0.9 tons of SOx into the air. Under Federal regulations, a facility in Philadelphia is a major source of SOx if it has the potential to emit 100 tons in a year.  

• Carbon Monoxide (CO) is a colorless, odorless gas that is formed when carbon in fuel is burned.  In 2015, SEPTA-Roberts released 3.0 tons of CO into the air. Under Federal regulations, a facility in Philadelphia is a major source of CO if it has the potential to emit 25 tons in a year.  

• Volatile Organic compounds (VOC) are chemicals that evaporate at room temperature.  In 2015, SEPTA-Roberts released 1.6 tons of VOC into the air. Under Federal regulations, a facility in Philadelphia is a major source of VOC if it has the potential to emit 25 tons in a year.  

• Particulate Matter Less Than 10 Microns (PM10) are very small substances, such as dust, dirt, soot, smoke, or drops of liquid, that are released into the air during the burning of fuel.  In 2015, SEPTA-Roberts released 2.3 tons of PM10 into the air. Under Federal regulations, a facility in Philadelphia is a major source of PM10 if it has the potential to emit 100 tons in a year.  

• Lead is a metal that can be released into the air during the burning of fuel.  In 2015, SEPTA-Roberts released a negligible amount of led into the air.

Permit Requirements

SEPTA–Roberts has a facility-wide Synthetic Minor operating permit which limits the total facility emissions below levels defined as major under Federal regulations. SEPTA-Roberts will maintain its Synthetic Minor operating permit and facility emission limits after the installation of the CHP. Since the facility will remain a minor facility, this plan approval application is not applicable to New Source Review (NSR) or Prevention of Significant Deterioration (PSD) requirements, regulations that only apply to major facilities.

The generators are applicable to the Federal Standards of Performance for Stationary Spark Ignition Internal Combustion Engines found in 40 CFR Subpart JJJJ. The requirements in this regulation include emission limits for NOx, CO, and Non-Methane Non-Ethane Hydrocarbons (NMNEHC, similar to VOC) on a grams per brake horsepower-hour (g/bhp-hr) basis. The draft plan approval includes emission limits for these pollutants that are significantly lower than the limits found in this regulation. The draft plan approval also includes emission limits for Formaldehyde and Ammonia.

Air Management Services (AMS) must ensure that the proposed target heater operation will comply with all applicable air quality requirements.  The final plan approval will include testing, monitoring, recordkeeping, and reporting requirements to ensure compliance.  These requirements will include initial emission tests for NOx, NMNEHC, CO, Formaldehyde, and Ammonia. SEPTA must conduct additional tests for NOx, NMNEHC CO, and Formaldehyde every 8,760 hours of operation or every 3 years, whichever comes first.

After a plan approval is issued and installation is complete, AMS will confirm by inspection that the units conform to the plan approval conditions and the information supplied in the permit application is accurate.  AMS will continue to monitor the units’ operation by reviewing facility reports and visually inspecting the facility on a regular basis.

Emissions Impact on Neighborhood:

AMS determined the project’s emission impact on the neighborhood using a computer model called AERSCREEN. The computer model projects the worst-case emission level in the area due to the project based on project characteristics such as the emission rate, exhaust stack details, and local geography. AMS ran the computer model for NOx emissions, the pollutant with the highest expected emissions due to the project.  AMS compared these results to the EPA standard for Nitrogen Dioxide (NO2), the main component of NOx. See Table 1 below for the results.

Table 1 – Project Emissions Impact in Parts Per Billion (ppb) NOx

Project	Background	Project + Background	EPA Standard
10.78 ppb	76 ppb	86.78 ppb	100 ppb

Project – This is the emission impact on the neighborhood due to the project. AMS input hourly NOx emissions (based on the emission limits in the draft plan approval); stack temperature, diameter, and height; and local geography into the model to determine the NOx emission concentration increase in the ambient air due to this project. The model determined the maximum 1-hour NOx concentration increase from the combined stack is 10.78 ppb.

Background – This is the existing pollution level in the area without the project. To be conservative, AMS used 76 ppb, the highest certified 1-hour level measured by AMS air monitors in Philadelphia since 2009, as the background level.

Project + Background – This is the maximum projected pollution level in the area after the project.

EPA Standard – This is the National Ambient Air Quality Standards (NAAQS) Primary Standard of 100 parts per billion (ppb) established by EPA for Nitrogen Dioxide (NO2). NAAQS primary standards provide public health protection, including protecting the health of "sensitive" populations such as asthmatics, children, and the elderly. For more information on NAAQS standards, see https://www.epa.gov/criteria-air-pollutants/naaqs-table.

The results of the computer model show that the total ambient pollutant concentrations of this project are below the primary standard for NO2. AMS finds that the proposed project does not have the potential for significant health and environmental effects.

Permitting Process

After AMS completed its review of the application, AMS had a public notice published in the Pennsylvania Bulletin, to alert community members of the proposed plan approval, the 30-day public comment period, and a public hearing scheduled on June 27, 2017, at 6 PM at the Panati Playground located at 3101 N. 22nd Street, Philadelphia, PA 19132. AMS will address any comments received during the comment period or public hearing before taking final action on the plan approval. You can also comment online at https://actionnetwork.org/forms/submit-a-comment-to-air-management-services

During the public comment period, copies of the application will be available for public review at Air Management Services, 321 University Ave, Philadelphia, PA 19104.  The public will be able to arrange a visit by calling (215) 685-7572.  Copies will also be available at the Falls of Schuylkill Branch (3501 Midvale Avenue, 215-685-2093) and the Nicetown-Tioga Branch (3720 North Broad Street, 215-685