CITY OF PHILADELPHIA 

DEPARTMENT OF PUBLIC HEALTH 

 AIR MANAGEMENT SERVICES 

 RACT PLAN APPROVAL 

Effective Date: January 9, 2015 

Expiration Date: None 

Replaces Permit No. PA-51-1566 issued April 10, 1995 

In accordance with provisions of the Air Pollution Control Act, the Act of January 8, 1960, P.L. 2119, 

as amended, and after due consideration of a Reasonably Available Control Technology (RACT) 

proposal received under the Pennsylvania Code, Title 25, Chapter 129.91 thru 129.95, of the rules and 

regulations of the Pennsylvania Department of Environmental Protection (PADEP), Air Management 

Services (AMS) approved the RACT proposal of the Facility below for the source(s) listed in section 

1.A. Emission Sources of the attached RACT Plan Approval. 

Facility: Paperworks, LLC 

Owner: Paperworks Industries, inc 

Location: 5000 Flat Rock Road, Philadelphia, PA 19127 

Mailing Address: 5000 Flat Rock Road, Philadelphia, PA 19127 

SIC Code(s): 2631 

Plant ID: 01566 

Facility Contact: Frank DelGrego 

Phone: (215) 984-7000 

Permit Contact: Frank DelGrego 

Phone: (215) 984-7000 

Responsible 

Official:

Frank DelGrego 

Title: General Manager 

1/9/2015

Edward Wiener, Chief of Source Registration Date
RACT PLAN APPROVAL Paperworks Page 2 

1/9/15

The RACT plan approval is subject to the following conditions: 

1) The purpose of this plan approval is to establish Nitrogen oxide and (NOx) Reasonably available 

control technology (RACT) for Paperworks, LLC. This includes the following emission source 

and control equipment. 

A. Emission Sources 

(i) Boiler#1, Riley boiler with heat input limit of 156 MMBTU/hr (previously rated capacity 

of 240 MMBTU/hr) and firing natural gas as primary fuel and #6 oil fuel as a back-up, 

equipped with Low NOx burners (LNB) with overfire air 

(ii) Boiler #3: Rated 92.27 MMBTU/hr and burns natural gas equipped with Low NOx burners 

(LNB) and flue gas recirculation (FGR). 

(iii)Boiler #4: Rated 92.27 MMBTU/hr and burns natural gas equipped with Low NOx burners 

(LNB) and flue gas recirculation (FGR). 

2) Emission Limts 

(i) NOx emissions from Boiler #1 shall not exceed the following: 

(a) 0.20lbs/MMBTU on a 30 day rolling average basis when burning natural gas and 

(b) 0.30 lbs/MMBTU on 30 day rolling average basis while burning No.6 oil 

(c) 138 tons/ rolling 12 month period calculated monthly 

(ii) NOx emissions from Boiler #3 & #4 shall not exceed the following; 

(a) 0.025 lbs/MMBTU while burning natural gas 

(b) 10.15 tons per rolling 12-month period for each boiler 

3) Control Equipment 

(i) Boiler #1 shall installed with or modified and operate Low NOx burners with 

overfire air 

(ii) Boiler #3 & #4 shall be equipped with and operate LNB and FGR 

4) Work Practice Standard 

(i) Boiler No.1 shall only burn natural gas and No.6 fuel oil. Boiler #1 shall burn #6 fuel oil 

for no more than 168 hours per rolling 12-month period, solely for emergency, and to 

keep pipes from freezing in case of natural gas interruption. 

(ii) The maxiumum heat imput shall be limited to 156 MMBTU/hr for Boiler #1 

(iii) Boiler No.3 & 4 shall only burn natural gas. 

5) Testing Requirements 

A. Continuos nitrogen oxides, and oxygen monitors and recorders shall be installed and operated 

in order to measure and record the concentrations of these gases emitted from the boiler 

stacks. The continuos emission monitors must conform to USEPA performance 

specifications in 40 CFR part 60, Appendix B and PA. DER continuos Source Monitering 

Manual Rev. No.4, July 1987 

B. Paperworks shall conduct a NOx performance test on Boiler #3 & #4 every five years. 

C. Paperworks shall obtain approval of the test protocol prior to the test date. 

6) Monitoring, Recordkeeping and Reporting Requirements

A. Boiler #1 

(i) Daily and monthly natural gas usage, 
RACT PLAN APPROVAL Paperworks Page 3 

1/9/15

(ii) Daily and monthly No.6 oil usage for Boiler No.1 

(iii) 30-day rolling average of NOx emissions per lbs/mmbtu when burning No. 6 oil, and 

natural gas 

(iv) NOx emission calculation per rolling twelve month period calculated monthly 

(v) Average hourly heat input records for Boiler No.1,and 

(vi) Operating hours of the boiler while burning No.6 fuel oil and 

(vii) Records of the reasoning of burning fuel oil each time 

B. Boiler #3 & #4 

(i) Paperworks shall monitor and record monthly fuel usage for each boiler, and calculate 

monthly NOx emission for each boiler per rolling 12-month period. 

C. Paperworks shall maintain a file containing all the records and other data that are required to 

be collected to demonstrate compliance with NOx/VOC RACT requirements of 25 PA Code 

129.91 - 129.94. 

D. The records shall provide sufficient data and calculations to clearly demonstrate that the 

requirements of §129.91-129.94 are met. 

E. Data or information required to determine compliance shall be recorded and maintained in a 

time frame consistent with the averaging period of the requirement. 

F. Records shall be retained for at least five years and shall be made available to AMS on request. 

G. The company shall not impose conditions upon or otherwise restrict AMS's access to the 

aforementioned source(s) and/or any associated air cleaning device(s) and shall allow AMS to 

have access at any time to said source(s) and associated air cleaning device(s) with such 

measuring and recording equipment, including equipment recording visual observations, as 

the Department deems necessary and proper for performing its duties and for the effective 

enforcement of the Air Pollution Control Act. 

H. Revisions to conditions approved as RACT by EPA will require resubmission as revision to 

the PA State Implementation Plan. The applicant shall bear the cost of public hearing and 

notification required for EPA approval as stipulated in 25 PA Code §129.91(h). 

7) RACT Implementation Schedule 

A. Upon issuance of this approval Paperwork shall begin immediate implementation of the 

measures necessary to comply with the approved RACT requirements.