CITY OF PH ILADELPHIA Department of Public Health Environmental Protection Division Air Management Services

InterOffice Memo To: File
From: Edward Wiener
Date: November 1, 2014 Subject: 1-Hour RACT Facilities not in 8-Hour RACT

Introduction: The Clean Air Act (CAA) requires that mode rate (or worse) ozone nonattainment areas implement reasonably available control technolo gy (RACT) controls on all major sources of VOC and NOx. Philadelphia County is part of the Philadelphia-Wilmi ngton-Atlantic City moderate ozone nonattainment ar ea for the 1997 8-hour ozone NAAQS. 

### This document discusses facilities that were in the 1- hour RACT State Implementation Plan (SIP) but were not applicable to 8-hour RACT.

Applicability for NOx and VOC RACT:

A facility is a major source of Nitrogen Oxides (NOx) if it ha s potential NOx emissions of 100 tons per year or greater, the major source thresh old in Philadelphia County that is applicable to NOx RACT for the 1997 8-hour ozone NAAQS.

A facility is a major source of Volatile Or ganic Compounds (VOC) if it has potential VOC emissions greater than 50 tons per year, the majo r source threshold in Philadelphia County that is applicable to VOC RACT fo r the 1997 8-hour ozone NAAQS.

Minor NOx and VOC Facilities

The following facilities were applicable to 1- hour RACT for NOx or VOC but are now minor sources and are not applicab le to 8-hour RACT for ei ther of these pollutants:

 Northeast Water Pollution Contro l Plant (3899 Richmond Street)

 Southwest Water Pollution Control Plant (8200 Enterprise Avenue)

 Mondelez (formerly Nabisco) (12000 East Roosevelt Blvd.) – Synthetic Minor Operating Permit No. S11-017

 The Bellevue (200 South Broad Street) – Na tural Minor Operating Permit No. N11-025

 Plains Products Terminals, formerly Amerada Hess (1630 South 51 st Street) – Synthetic Minor Operating Permit No. S13-001

 Philadelphia Gas Works – Passyunk Plant (3100 Passyunk Avenue) – Synthetic Minor Operating Permit No. S10-023

 The Philadelphian Condominium (2401 Pe nnsylvania Avenue) – Synthetic Minor Operating Permit No. S09-012

 SEPTA – Berridge/Courtland (200 West Wyomi ng Avenue) – Synthetic Minor Operating Permit No. S10-003

 Smith-Edwards-Dunlap (2867 East Allegheny Avenue) – Synthetic Minor Operating Permit No. S12-022Facilities with Synthetic Minor or Natural Minor opera ting permits are limited to less than 25 tons per year of both NOx and VOC emissions.

Shutdown Facilities

The following facilities were applicable to 1-hour RACT for NOx or VOC but have since shutdown:

 Interstate Brands (formerly Contin ental Baking) (9801 Blue Grass Road)

 Budd Company (2450 West Hunting Park Avenue)

 Amoco Oil (63 rd Street and Passyunk Avenue)

 Kurz-Hastings (10901 Dutton Road)

 Lawrence-McFadden (7430 State Road)

 Philadelphia Baking Company (Grant Avenue and Roosevelt Blvd.)

 Rohm and Haas (5000 Richmond Street)

 SBF Communications (3747 Ridge Avenue)

 Tasty Baking (2801 Hunting Park Avenue)

 Aldan Rubber (2701 East Tioga Street)

 Braceland Brothers (7625 Suffolk Avenue) – Pe arl Pressman Liberty opened a facility at the same location with completely new equipmen t. This facility is a minor source of both NOx and VOC.

 Graphic Arts (4100 Chestnut Street)

 O’Brien Cogeneration (later Calpine) – Northeast (3900 Richmond Street)

 O’Brien Cogeneration (later Calpine) – Southwest (8200 Enterprise Avenue)

 Pearl Pressman Liberty (912 North 5 th Street)

 Arbill (2207 West Glenwood Ave.)

 Eastman Chemical (formerly Mc Whorter) (7600 State Road)

 Transit America (One Red Lion Road)

None of these facilities have act ive operating permits or air polluti on licenses for any equipment. Under Pennsylvania and Philadelphia regulations, they cannot install new air pollution processes without first obtaining a plan appr oval or installa tion permit.

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Edward Wiener, Chief of Source Registration Date