CITY OF PHILADELPHIA

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 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 

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 has potential NOx emissions of 100 

tons per year or greater, the major source threshold in Philadelphia County that is applicable to 

NOx RACT for the 1997 8-hour ozone NAAQS. 

A facility is a major source of Volatile Organic Compounds (VOC) if it has potential VOC 

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

applicable to VOC RACT for 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 applicable to 8-hour RACT for either of these pollutants: 

 Northeast Water Pollution Control 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) – Natural Minor Operating Permit No. N11-025 

 Plains Products Terminals, formerly Amerada Hess (1630 South 51st 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 Pennsylvania Avenue) – Synthetic Minor 

Operating Permit No. S09-012 

 SEPTA – Berridge/Courtland (200 West Wyoming Avenue) – Synthetic Minor Operating 

Permit No. S10-003 

 Smith-Edwards-Dunlap (2867 East Allegheny Avenue) – Synthetic Minor Operating 

Permit No. S12-022 
Facilities with Synthetic Minor or Natural Minor operating 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 Continental Baking) (9801 Blue Grass Road) 

 Budd Company (2450 West Hunting Park Avenue) 

 Amoco Oil (63rd 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) – Pearl Pressman Liberty opened a facility at 

the same location with completely new equipment. 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 5th Street) 

 Arbill (2207 West Glenwood Ave.) 

 Eastman Chemical (formerly McWhorter) (7600 State Road) 

 Transit America (One Red Lion Road) 

None of these facilities have active operating permits or air pollution licenses for any equipment. 

Under Pennsylvania and Philadelphia regulations, they cannot install new air pollution processes 

without first obtaining a plan approval or installation permit. 

1/9/15

Edward Wiener, Chief of Source Registration Date