CITY OF PHILADELPHIA

Department of Public Health 

Environmental Protection Division 

Air Management Services 

InterOffice Memo 

To: File 

From: Biji Pandisseril and Maryjoy Ulatowski 

Date: December 6, 2014. 

Subject: RACT Analysis for Sunoco Partners Marketing & Terminals L.P - Belmont Terminal 

(PLID # 01507) 

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 VOC and 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 a RACT evaluation for the 1997 8-hour ozone standard for this 

facility.

Company Description: 

The Sunoco Partners Marketing & Terminals L.P - Belmont Terminal (Sunoco - Belmont Terminal) is located at 

2700 Passyunk Avenue, Philadelphia, PA 19145. The facility’s air emission sources include a Gasoline Truck 

Loading with Vapor Control Units products loading racks, Distillate Truck Loading, a Emergency Generator, and 

nine (9) Storage Tanks (with vapor pressure > 1.5 psia). 

Applicability for NOx and VOC RACT: 

Sunoco - Belmont Terminal is not a major source of Nitrogen Oxides (NOx). The potential NOx emission as limited 

by the issued AMS permits is less than 100 tons per year, the major source threshold in Philadelphia County that is 

not applicable to NOx RACT. 

Sunoco - Belmont Terminal is a major source of Volatile Organic Compound (VOC) emissions having potential 

VOC emissions of greater than 50 tons per year , the major source threshold in Philadelphia County that is 

applicable to VOC RACT 1997 8-hour ozone NAAQS. 

Process Descriptions: 

The emissions units at Sunoco Belmont Terminal include the following: 

 Gasoline Truck Loading with Vapor Control Units products loading racks, 

 Distillate Truck Loading, 

 an Emergency Generator, and 

 nine (9) Storage Tanks (with vapor pressure > 1.5 psia. 

RACT Analysis: 

In accordance, with 25 PA Code 129.91 (a all e sources at the facility will comply with RACT requirements as 

follows: 

 The Gasoline Truck Loading Rack with Vapor Recovery Unit and Distillate Truck Loading will comply 

 with the requirements of 25 PA Code 129.59, 129.62 and AMR V Section V (CTG: Control of 

 Hydrocarbons form Tank Trucks Gasoline Loading Terminals) EPA 450/2-77-026) 

 The Storage Tanks will comply with the presumptive RACT requirement of 25 PA Code 129.57 (CTG: 

 Control of VOCs form Storage of Petroleum Liquids in fixed roof tanks EPA 450/2-77-036 and Control of 

 VOCs form Storage of Petroleum Liquids in external floating tanks EPA 450/2-78-047) 
For Light Liquid/Vapor Components Fugitives the facility is applicable to the process equipment leak 

requirements of the CTG RACT regulation AMR V, Section XIII. 

 

Presumptive RACT: 

 The emergency generator will comply with the presumptive RACT 25 PA Code 129.93(c)(5) by operating 

 less than 500 hours in consecutive 12-month period and will maintain & operate in accordance with 

 manufacturer's specifications. 

1/9/15

Edward Wiener, Chief of Source Registration Date