UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103-2029

DATE: May 5, 2016

SUBJECT: Technical Support Document for the Philadelphia 

County, Pennsylvania Reasonably Available Control 

Technology Under the 1997 8-hour Ozone National 

Ambient Air Quality Standards

FROM: Emlyn Velez-Rosa, EIT, Environmental Engineer \s\

Office of Air Program Planning (3AP30)

TO:

REVIEWED 

BY:

SIP Docket File, EPA-R03-OAR-2008-0603

Cristina Fernandez, Associate Director \s\

Office of Air Program Planning (3AP30)

I. Affected Regulation

The Commonwealth of Pennsylvania (Pennsylvania) submitted to the U.S. Environmental 

Protection Agency (EPA) various revisions to its state implementation plan (SIP) affecting 

Philadelphia County (Philadelphia). The SIP revisions pertain to the demonstration that 

Philadelphia meets the requirements of reasonably available control technology (RACT) for 

major sources of nitrogen oxides (NOx) and volatile organic compounds (VOC) for the 1997 8-

hour ozone national ambient air quality standards (NAAQS), as set forth in the Clean Air Act 

(CAA). This technical support document (TSD) provides EPA’s rationale for proposing 

approval of the aforementioned SIP revisions to satisfy our conditional approval of previous SIP 

revisions addressing Philadelphia RACT requirements under the 1997 8-hour ozone NAAQS.

II. Background

 A. General

Ground level ozone pollution (commonly referred to as smog) is formed when VOC react 

with NOx in the presence of sunlight. In order to reduce ozone concentrations in the ambient air, 

the CAA requires all nonattainment areas to apply control on VOC and NOx emission sources to 
2

achieve emission reductions. Among effective control measures, RACT controls are a major 

group for reducing VOC and NOx emissions from stationary sources.

Since the 1970’s, EPA has consistently interpreted RACT to mean the lowest emission limit 

that a particular source is capable of meeting by the application of the control technology that is 

reasonably available considering technological and economic feasibility.

1 Section 172(c)(1) of 

the CAA provides that SIPs for nonattainment areas must include reasonably available control 

measures (RACM) for attainment of the NAAQS, including emissions reductions from existing 

sources through adoption of RACT. Section 182(b)(2) and 182(f)(1) of the CAA requires states 

with moderate, or worse, ozone nonattainment areas implement RACT controls on each category 

of stationary sources covered by a control technique guideline (CTG) document issued by EPA 

and on all major stationary sources of VOC and NOx emissions located in the area.

2

 Pursuant to 

section 184(b) of the CAA, the same requirements for sources of NOx and VOC apply to any 

areas in an ozone transport region (OTR) established under section 184(a), therefore including 

marginal and moderate nonattainment areas as well attainment areas within an OTR. A single 

OTR has been established, comprising of 12 eastern states and the District of Columbia 

(hereafter, “the OTR”). The entire Commonwealth of Pennsylvania is part of the OTR. 

On July 18, 1997 (62 FR 38856), EPA revised the NAAQS for ground-level ozone, setting it 

at 0.08 parts per million (ppm) averaged over an 8-hour time frame. On April 15, 2004, EPA 

issued final designations for the 1997 8-hour ozone NAAQS, which included Philadelphia 

County as part of the Philadelphia-Wilmington-Atlantic City, PA-NJ-MD-DE moderate ozone 

nonattainment area. 69 FR 23858, at 23931 (April 30, 2004). At the same time, EPA published 

the first phase of its final rule to implement the 1997 8-hour ozone NAAQS (Phase I Ozone 

Implementation Rule), in which EPA revoked the previous 1-hour ozone NAAQS for most areas 

of the country, effective on June 15, 2005, and established anti-backsliding principles to 

transition from implementing the revoked 1-hour ozone NAAQS to the more protective 1997 8-

hour ozone NAAQS, as codified in 40 CFR 51.905.3 The nonattainment designation for 

Philadelphia under the 1997 8-hour ozone NAAQS, and its location in the OTR, triggered the 

State’s obligation to submit a SIP revision addressing how it meets the CAA RACT requirements 

in Philadelphia under the standard.

On March 12, 2008 (73 FR 16436), EPA significantly strengthened the 8-hour ozone 

NAAQS by revising the primary 8-hour ozone standard to a level of 0.075 ppm. On March 6, 

 

1 See 44 FR 53782 (September 17, 1979); EPA’s 1976 memorandum from Roger Strelow, Assistant Administrator 

for Air and Waste Management to Regional Administrators, “Guidance for Determining Acceptability of SIP 

Regulations in Non-attainment Areas” (December 9, 1976); and also, 72 FR 20586 at 20610 (April 25, 2007).

2 A major source in an ozone nonattainment area is defined as any stationary source that emits or has the potential to 

emit NOx and VOC emissions above certain applicability threshold that is based on the classification of the ozone 

nonattainment area. See “major stationary source” in 40 CFR 51.165.

3

“Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard—Phase 1,” 69 FR 23951 

(April 30, 2001).
3

2015 (80 FR 12264), EPA published a final rule for the implementation of the 2008 8-hour ozone 

NAAQS, while at the same time revoking the 1997 8-hour ozone NAAQS, effective on April 6, 

2015.4 Consistent with EPA’s previous approach, the 2008 8-Hour Ozone Implementation Rule 

established anti-backsliding principles to transition from implementing the revoked 1997 8-hour 

ozone NAAQS to the 2008 8-hour ozone NAAQS, as codified in 40 CFR 51.1100. In this rule, 

EPA clarified that RACT under the 1997 8-hour ozone NAAQS, among other requirements, 

continues to apply to a nonattainment area, in accordance with its designation and classification 

for the 1997 8-hour ozone NAAQS at the time of the revocation of the standard. Therefore, 

1997 8-hour ozone RACT continues to be an applicable requirement for Philadelphia.

The implementation of RACT controls under the 1997 8-hour ozone NAAQS is required in 

Philadelphia for each category of VOC sources covered by a CTG document issued by EPA (i.e., 

CTG RACT) and all other major stationary sources of NOx and VOC (major source RACT), as 

defined for a moderate nonattainment area. Philadelphia was also subject to the CAA RACT 

requirements under the 1-hour ozone NAAQS, as it was designated as part of the PhiladelphiaWilmington-Trenton, PA-NJ-DE-MD severe ozone nonattainment area under the 1-hour ozone 

NAAQS. See 56 FR 56694, at 56822 (November 6, 1991). As a result, the Pennsylvania 

Department of Environment (PADEP) and Philadelphia Air Management Services (AMS) 

implemented numerous RACT controls in Philadelphia to meet the statutory RACT requirements

under this previous standard. 

B. EPA’s Requirements under the 1997 8-hour Ozone RACT

In Phase I Ozone Implementation Rule, EPA provides that a nonattainment area previously 

designated under the 1-hour ozone NAAQS remains subject to certain 1-hour ozone obligations 

until the area attains the 1997 8-hour ozone NAAQS, such obligations include RACT.

Furthermore, 40 CFR 51.905(b) provides that such obligations cannot be removed from a SIP, 

even if the area is redesignated to attainment for the 1-hour ozone NAAQS, but must remain in 

the SIP as applicable requirements or contingency measures, as appropriate. 

On November 29, 2005, EPA published the second phase to its implementation rule to 

address nonattainment SIP requirements for the 1997 8-hour ozone NAAQS (the Phase 2 Ozone 

Implementation Rule).5 This rule addressed, among other things, control and planning 

obligations as they apply to nonattainment areas under the 1997 8-hour ozone NAAQS, 

including RACT and RACM. In this rule, EPA specifically required that states meet the RACT 

requirements under the 1997 8-hour ozone NAAQS, either through a certification that previously 

adopted RACT controls in their SIP revisions approved by EPA under the 1-hour ozone NAAQS 

continue to represent adequate RACT control levels for 1997 8-hour ozone NAAQS attainment 

 

4

“Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan 

Requirements” Final Rule, 80 FR 12264 (March 6, 2015).

5

“Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard—Phase 2,” 70 FR 71612-

71705 (November 29, 2005).
4

purposes, or through the adoption of new or more stringent regulations that represent RACT 

control levels.

6

 A certification must be accompanied by appropriate supporting information such 

as consideration of information received during the public comment period and consideration of 

new data. This information may supplement existing RACT guidance documents that were 

developed for the 1-hour standard, such that the State’s SIP accurately reflects RACT for the 

1997 8-hour ozone standard based on the current availability of technically and economically 

feasible controls. Adoption of new RACT regulations will occur when states have new 

stationary sources not covered by existing RACT regulations, or when new data or technical 

information indicates that a previously adopted RACT measure does not represent a newly 

available RACT control level. Additionally, states are required under the 1997 ozone NAAQS to 

submit a negative declaration if there are no sources of NOx and/or VOC emissions in a source 

category covered by a CTG within the nonattainment area, in lieu of a certification.

EPA particularly addressed controls for NOx emissions from electric generating units 

(EGUs) in the Phase 2 Ozone Implementation Rule. EPA determined that the regional NOx 

emissions reductions that result from either the NOx SIP Call or the Clean Air Interstate Rule 

(CAIR) for addressing interstate transport of ozone pollution, would meet the NOx RACT 

requirement for EGUs located in states included within the respective geographic regions. Thus, 

EPA concluded that the states did not need to perform a NOx RACT analysis for sources subject 

to the state’s emission cap-and-trade program where such program has been adopted by the state 

and approved by EPA as meeting the NOx SIP Call requirements or, in states achieving the 

CAIR reductions solely from EGUs, the CAIR NOx requirements. 

In November 2008, several parties challenged the Phase 2 Ozone Implementation Rule, 

particularly, EPA’s determination that compliance by EGUs with the requirements of the NOx 

SIP and/or CAIR could also be construed as compliance with RACT under the 1997 8-hour 

ozone NAAQS. As a result of this litigation, the United States Court of Appeals for the District 

of Columbia Circuit (D.C. Circuit) decided that such presumptions and determinations by EPA 

in the Phase 2 Ozone Implementation Rule were inconsistent with the statutory requirements of 

section 172(c)(1) of the CAA. Because region-wide RACT-level emissions reductions do not 

meet the statutory requirement that the reductions be from sources in the nonattainment area, the 

D.C. Circuit found that EPA has not shown that compliance with NOx SIP Call will result in at 

 

6 For more information, see the preamble of the final Phase 2 Ozone Implementation Rule for a discussion of EPA’s 

interpretation of the CAA RACT requirements for the 1997 8-hour ozone NAAQS, in 70 FR 71652-71659 

(November 29, 2005).
5

least RACT-level reductions in emissions from sources within each nonattainment area. See

NRDC v. EPA, 571 F.3d 1245 (DC Cir. 2009).

7

 C. EPA’s Conditional Approval for Philadelphia’s 1997 8-hour Ozone RACT 

Demonstration 

On September 29, 2006, PADEP submitted, on behalf of AMS, a SIP revision purporting to 

address the RACT requirements for Philadelphia under the 1997 8-hour ozone NAAQS. The 

2006 SIP revision consisted of a RACT demonstration for Philadelphia, including (1) a 

certification that previously adopted RACT regulations that were approved by EPA in 

Pennsylvania’s SIP for Philadelphia under the 1-hour ozone NAAQS continue to represent

RACT for the 1997 8-hour ozone NAAQS implementation purposes; (2) the adoption of 

federally enforceable permits that represent RACT control levels for four major VOC sources; 

and (3) a negative declaration that certain VOC source categories that are covered by CTG 

documents do not exist in Philadelphia. 

On August 26, 2008 (73 FR 50270), EPA published a notice of proposed rulemaking (NPR) 

proposing approval of the 2006 SIP revision. However, after further evaluation, EPA identified 

two deficiencies in the 2006 SIP revision which precluded EPA’s approval. First, the 2006 SIP 

revision included as RACT certain provisions that relied on the NOx SIP Call, which in light of 

the 2009 D.C. Circuit decision in NRDC v. EPA regarding the inappropriateness of the NOx SIP 

Call as RACT, precluded EPA from approving the 2006 SIP revision. Specifically, the 2006 SIP 

certified as RACT the following PADEP regulations: 25 Pa Code sections 145.1-145.100 (“NOx 

Budget Trading Program”), 25 Pa Code sections 145.111-145.113 (“Emissions of NOx from 

Stationary Internal Combustion Engines”), and 25 Pa Code sections 145.141-144 (“Emissions of 

NOx from Cement Manufacturing”). Second, EPA also determined that the Philadelphia 2006 

SIP revision did not sufficiently address the source-specific RACT requirements for 46 major 

sources of NOx and/or VOC that were previously approved under the 1-hour ozone NAAQS, per 

the SIP approved regulation in 25 Pa Code sections 129.91-92, which AMS certified as RACT 

under the 1997 8-hour ozone NAAQS. 

On June 22, 2010, PADEP submitted another RACT SIP revision addressing certain CTG 

RACT requirements that superseded portions of the RACT demonstration in the 2006 SIP 

 

7 The D.C. Circuit addressed whether reductions from the NOx SIP call could address NOx RACT. The issue as to 

whether CAIR satisfies NOx RACT for EGUs was not addressed by the D.C. Circuit because the D.C. Circuit had 

already remanded CAIR to EPA for further analysis at that time. See North Carolina v. EPA, 531 F.3d 896;

modified by 550 F.3d 1176 (D.C. Cir. 2008). In subsequent litigation, the rule that EPA promulgated to replace 

CAIR (i.e., the Cross State Air Pollution Rule or CSAPR) was initially vacated by the D.C. Circuit but upheld by the 

U.S. Supreme Court. EPA v. EME Homer City Generation, L.P., 134 S. Ct. 1584 (2014). EPA began implementing 

CSAPR in January 2015. See 79 FR 71663 (December 3, 2014) (interim final rulemaking issued after D.C. Circuit 

lifted stay on CSAPR). Thus, EPA decided it would be appropriate to reconsider its prior determination that CAIR 

could satisfy NOx RACT in light of the earlier decision in NRDC v. EPA. See 79 FR 32892 (June 9, 2014) 

(proposing removal of prior determination that CAIR could be NOx RACT).
6

revision. The 2010 SIP revision consisted of two new CTG regulations, Air Management 

Regulation (AMR) V section XV (“Control of Volatile Organic Compounds (VOC) from Marine 

Vessel Coating Operations”) and AMR V section XVI (“Synthetic Organic Manufacturing 

Industry (SOCMI) Air Oxidation, Distillation, and Reactor Processes”), and related amendments 

to AMR V Section I (“Definitions”), as adopted by AMS on April 26, 2010 effective upon 

adoption; and a negative declaration demonstrating that no sources existing in Philadelphia for 

the CTG source category of natural gas and gasoline processing plants. The CTG regulations 

adopted in 2010 superseded source-specific RACT determinations provided in the 2006 SIP 

revision, because the new provisions are as, if not more, stringent than those RACT requirements 

previously submitted in 2006.8 Additionally, the 2010 SIP revision clarified that in the 2006 SIP 

submission AMS had erroneously defined two sources in Philadelphia under the CTG category 

for natural gas and gasoline processing plants, and for which AMS submitted source-specific 

RACT determinations in the 2006 SIP revision. For these reasons, EPA determined that the 

provisions in the 2006 and 2010 SIP revisions were related in addressing Philadelphia’s 1997 8-

hour ozone NAAQS RACT obligation and were not separable for approval purposes as each SIP 

revision contained provisions addressing RACT obligations.

 

Pursuant to section 110(k)(4) of the CAA, on April 26, 2013, PADEP submitted, on behalf of 

AMS, a letter in which AMS committed to submit the SIP revisions addressing the sourcespecific RACT requirements for Philadelphia under the 1997 8-hour ozone NAAQS, including 

EGUs that were presumed to rely on the NOx SIP Call provisions to meet RACT. In the April 

26, 2013 letter, AMS identified five sources that since the approval of the 1-hour ozone sourcespecific RACT determinations have adopted or will adopt additional controls that it believed 

represent RACT under the 1997 8-hour ozone NAAQS, and for which it would submit new 

source-specific RACT determinations: (1) Philadelphia Energy Solutions Refining and 

Marketing, LLC (formerly Sunoco Inc. (R&M)- Philadelphia), (2) Kraft Nabisco (formerly 

Nabisco Biscuit Co, and presently Mondelez), (3) Temple University- Health Sciences Campus, 

(4) GATX Terminals Corporation (presently, Kinder Morgan Liquids terminals, LLC), and (5) 

Honeywell International- Frankford Plant (formerly Sunoco Chemicals – Frankford Plant). 

Additionally, AMS indicated it would submit source-specific RACT determinations for five 

EGU sources in Philadelphia that relied on emissions reductions under the NOx SIP Call as 

RACT including: (1) Exelon Generating Company – Delaware Station, (2) Exelon Generating 

Company– Richmond Station, (3) Exelon Generating Company– Schuylkill Station, (4) Veolia 

Energy – Edison Station (formerly TRIGEN- Edison Station), and (5) Veolia Energy– Schuylkill 

Station (formerly TRIGEN- Schuylkill Station). AMS needed to submit source-specific RACT 

 

8 AMR V section XV and AMR V section XVI address EPA’s RACT requirements as specified in the following 

CTGs: (1) “Control Techniques Guidelines for Shipbuilding and Ship Repair Operations (Surface Coating)” (61 FR 

44050, August 27, 1996), (2) “Control of Volatile Organic Compound Emissions from Air Oxidation Processes in 

Synthetic Organic Chemical Manufacturing Industry” (EPA-450/3-84-015, December 1984), and (3) “Control of 

Volatile Organic Compound Emissions from Reactor Processes and Distillation Operations in Synthetic Organic 

Chemical Manufacturing Industry” (EPA-450/4-91-031, August 1993). 
7

determinations or alternative certifications to address RACT for any major NOx sources, such as 

EGUs, for which AMS relied in prior SIP submissions on the NOx SIP Call to address RACT for 

the 1997 8-hour ozone NAAQS, because EPA cannot approve as RACT provisions relying on 

the NOx SIP Call. See NRDC v. EPA, 571 F.3d 1245.

On June 19, 2013, in addition to its withdrawal the previous proposal, EPA proposed 

conditional approval of the Philadelphia 1997 8-hour ozone RACT demonstration included in

both the 2006 and 2010 RACT SIP revisions, based upon AMS’s commitment to submit 

additional SIP revisions to correct the deficiencies previously identified by EPA. In the June 19, 

2013 proposed conditional approval, EPA proposed that in order to correct deficiencies in the 

Philadelphia 1997 8-hour ozone RACT demonstration, AMS needed to provide a source-specific 

RACT analysis for each major NOx/VOC source subject to 25 Pa Code 129.91-92 for which 

current controls do not currently and adequately represent RACT for the 1997 8-hour ozone 

NAAQS, including each of the 10 major NOx and/or VOC sources identified by AMS in the 

April 26, 2013 letter, or alternatively provide a certification that source-specific RACT controls 

for all other major sources of NOx and VOC in Philadelphia previously approved by EPA in 

Pennsylvania’s SIP for the 1-hour ozone NAAQS continue to adequately represent RACT for the 

1997 8-hour ozone NAAQS. 

On December 13, 2013 (78 FR 75902), EPA finalized its conditional approval of the 

Philadelphia 1997 8-hour ozone RACT demonstration, as provided in the 2006 and 2010 SIP 

revisions, with the conditions that Pennsylvania, on behalf of AMS, submits additional SIP 

revisions addressing the deficiencies in the former 2006 RACT SIP revision. As stated in the 

December 13, 2013 final action, once EPA determines that AMS has satisfied these conditions, 

EPA shall remove the conditional nature of such approval and the Philadelphia 1997 8-hour 

ozone RACT demonstration will receive at that time a full approval status. For a detailed 

discussion of EPA’s conditional approval of Philadelphia’s 1997 8-hour ozone RACT 

demonstration and the identified deficiencies of the 2006 SIP revision, see 78 FR 75902 

(December 13, 2013) (final action) and 78 FR 36716 (June 19, 2013) (proposed action).

 

Based on our previous evaluation of the 2006 and 2010 SIP revisions, EPA finds that the

Philadelphia 1997 8-hour ozone RACT demonstration as provided in those submittals adequately 

meets RACT under the CAA, with exception of the source-specific requirements in 25 PA Code 

sections 129.91-92 and the NOx SIP Call related provisions in the Pennsylvania SIP in 25 Pa 

Code sections 145.1-145.100, 25 Pa Code sections 145.111-145.113, and 25 Pa Code sections 

145.141-144. EPA finds that the certified and recently adopted NOx and VOC regulations 

provided in the 2006 and 2010 SIP revisions as meeting RACT under the 1997 8-hour ozone 

NAAQS, are consistent with the latest available information and EPA’s guidance. EPA 

specifically finds that the provisions in AMR V sections XV and XVI, submitted as part of the 

2010 SIP revision, are as stringent as EPA’s RACT requirements specified in the applicable 
8

CTGs. EPA’s evaluation of the 2006 and 2010 SIP revision is provided in the June 19, 2013 

proposed conditional approval and related technical support document dated May 22, 2013, and 

will not be restated here. See 78 FR 36716. 

III. Summary of SIP Revisions

To satisfy EPA’s conditional approval, PADEP has submitted to EPA, on behalf of AMS, 

subsequent SIP revisions addressing the source-specific RACT requirements for major sources in 

Philadelphia subject to 25 Pa Code 129.91-92. On June 27, 2014, February 18, 2015, and April 

26, 2016, PADEP submitted to EPA, on behalf of AMS, three separate SIP revisions pertaining 

to the Philadelphia 1997 8-hour ozone RACT demonstration (hereafter collectively referred to as 

“the Philadelphia RACT SIP revisions”). AMS provided documentation in the Philadelphia 

RACT SIP revisions to support that RACT has been met for all major sources of NOx and/or 

VOC in Philadelphia, including source-specific RACT determinations for affected emission units 

at each major source subject to 25 Pa Code 129.91-92.9 Specifically, AMS evaluated a total of 

25 major NOx and/or VOC sources in Philadelphia for RACT. 

On April 26, 2016, PADEP also submitted a letter, on behalf of AMS, withdrawing from the 

2006 SIP revision the certification of the Pennsylvania rules related to the NOx SIP Call as 1997 

8-hour ozone RACT, specifically 25 Pa Code sections 145.1-145.100, 25 Pa Code sections 

145.111-145.113, and 25 Pa Code sections 145.141-144. In the letter, PADEP reaffirms that 

AMS is no longer relying on the SIP approved provisions related to the NOx SIP Call as 1997 8-

hour ozone RACT for any sources in Philadelphia. On May 4, 2016, EPA submitted a letter 

accepting PADEP’s request for withdrawal of these provisions from the 2006 SIP revision, and 

acknowledging that this portion of the submittal is no longer pending before EPA for a final 

action. 

The June 27, 2014 SIP revision consists of a source-specific RACT determination for certain 

emissions units (6 process heaters) at Philadelphia Energy Solutions Refining and Marketing, 

LLC (PES). The February 19, 2015 SIP revision addresses RACT requirements for the 25 major 

sources of NOx and/or VOC in Philadelphia, including the remaining emissions units in PES that 

were not addressed on the June 27, 2014 SIP revision. The March 26, 2016 SIP revision amends 

the RACT determinations for 15 sources that were previously addressed in the February 19, 2015 

SIP revision. See Appendix C for EPA’s Clarification on superseded documentation in the 2015 

SIP Revision.

 

9 The applicable “major source” thresholds for 1997 8-hour ozone RACT purposes are 50 tons per year (TPY) of 

VOC and 100 TPY of NOx or greater of potential emissions for each respective pollutant, in light of the moderate 

ozone classification of Philadelphia for the 1997 8-hour ozone NAAQS, as well as its location in the OTR. 
9

In the Philadelphia RACT SIP revisions, AMS includes a RACT determination for each 

major source of NOx and/or VOC in Philadelphia, documented as RACT technical 

memorandums. AMS provided a RACT memorandum for each major NOx and/or VOC source 

in Philadelphia, including those that are not subject to source-specific RACT under 25 Pa code 

129.91-92. The RACT technical memorandums include a discussion of all applicable RACT 

requirements for the existing emissions units in each major source, including CTG RACT, 

presumptive RACT requirements, and source-specific RACT requirements. The CTG RACT 

requirements are those specified in regulations in the Pennsylvania SIP and are consistent with 

EPA’s CTGs for the affected source categories. Presumptive RACT requirements are those 

specified in 25 Pa Code section 129.93.10 

Table 1 below lists the 25 major sources of NOx and/or VOC in Philadelphia subject to 1997 

8-hour ozone RACT, all which were evaluated by AMS in the Philadelphia RACT SIP revisions. 

Table 1 also identifies whether each source is subject to a previous source-specific RACT 

determination under the 1-hour ozone standard and continues to be major for NOx, VOC, or both 

pollutants under the 1997 8-hour ozone NAAQS, in addition to listing the types of RACT 

requirements that apply to the emissions unit at the source. The last column of Table 1 indicates 

if AMS has adopted new or revised existing source-specific RACT controls for each major NOx 

and/or VOC source subject to 25 Pa Code section 129.91-92, to meet the CAA requirements 

under the 1997 8-hour ozone NAAQS. An evaluation of the Philadelphia RACT SIP revisions to 

meet the conditional approval is provided in the next section of this TSD, in support of EPA’s 

proposed approval. 

Table 1. Major NOx and/or VOC Sources in Philadelphia Subject to 1997 8-hour ozone 

RACT 

Major Source Plant ID 

Number

1-Hr

Ozone

RACT 

Source?

Major 

Source

Pollutant

Applicable RACT Requirements

CTG Presump

-tive

SourceSpecific

Aker Philadelphia 

Shipyard, Inc.-

Philadelphia Naval 

Business Center

01569 VOC x x

Allied Tube & Conduit 

Corp. 03363 VOC x x

Cardone Industries Inc.-

Rising Sun Avenue and 

Whitaker Avenue a

03887/ 

02287 x VOC x x

 

10 An owner or operator of a major NOx source subject to 25 Pa Code 129.91-93 may perform a source-specific 

RACT evaluation, or elect to alternatively comply with the presumptive NOx emissions limits specified in section 

129.93, when applicable (referred to “presumptive RACT” in this discussion).
10

Major Source Plant ID 

Number

1-Hr

Ozone

RACT 

Source?

Major 

Source

Pollutant

Applicable RACT Requirements

CTG Presump

-tive

SourceSpecific

Exelon Generating 

Company- Delaware

Station

04901 x NOx x x

Exelon Generating 

Company- Richmond

Station

04903 x NOx x

Exelon Generating

Company- Schuylkill 

Station

04904 x NOx x x

Exelon Generating 

Company- Southwark

Station

04905 NOx x

Honeywell- Frankford 

Plant [formerly, Sunoco 

Chemical- Frankford Plant]

01551 x

NOx and 

VOC x x x

Inolex Chemical Company 02059 NOx x

Kinder Morgan Liquids 

Terminals, LLC [formerly, 

GATX Terminals Corp.]

05003 x VOC x x x

MIPC, LLC 05004 VOC x x

Naval Foundry and 

Propeller Center 09702 NOx x

Naval Surface Warfare 

Center, Carderock Division 

(NSWCCD) 

09724 x NOx x x

Newman & Company, Inc. 03489 x NOx x x

PaperWorks Industries, 

Inc. [formerly, Jefferson 

Smurfit, Corp./ Container 

Corp. of America)

01566 x NOx x

Philadelphia Energy 

Solutions- Refining and 

Marketing, LLC [formerly, 

Sunoco Inc. (R&M)-

Philadelphia]

01501 / 

01517 x

NOx and 

VOC x x x

Philadelphia Gas WorksRichmond Plant 04922 x NOx x x
11

Major Source Plant ID 

Number

1-Hr

Ozone

RACT 

Source?

Major 

Source

Pollutant

Applicable RACT Requirements

CTG Presump

-tive

SourceSpecific

Philadelphia Prison System 09519 NOx x x

Plain Products Terminals, 

LLC [formerly, Maritank 

Philadelphia, Inc. and 

Exxon Company, USA]

05013 x VOC x x x

Sunoco Partners Marketing 

& Terminals L.P.- Belmont 

Terminal

01507 VOC x x

Temple - Health Sciences 

Campus 08906 x NOx x x

Temple - Main Campus 08905 NOx x x

University of Pennsylvania 08912 NOx x

Veolia Energy- Edison 

Station [formerly 

TRIGEN- Edison Station] 

04902 x NOx x

Veolia Energy- Schuylkill 

Station [TRIGENSchuylkill Station] / 

Grays Ferry Cogeneration 

Partnership / 

Veolia- Energy Efficiency, 

LLC b

04942 / 

04944 / 

10459

x NOx x

a

 Formerly, Cardone owned various adjacent facilities, from which two facilities were subject to source-specific RACT under the 

1-hour ozone standard. The facilities have two separate source-specific RACT determinations approved in the Pennsylvania SIP 

under the 1-hour ozone standard, corresponding to PLIDs 03887 and 02237. After 1-hour RACT, various adjacent facilities 

owned by Cardone were aggregated and evaluated for RACT as one major source. 

b

 Gray Ferry Cogeneration Plant, Veolia Schuylkill and Veolia Energy Efficiency have been aggregated as a single major source 

after the 1-hour RACT determination. AMS submitted RACT documentation for each facility separately, although considering 

RACT applicability as a single major source of NOx. 

IV. EPA’s Evaluation of SIP Revisions 

AMS submitted RACT technical memorandums for all major NOx/VOC sources in 

Philadelphia. The technical memorandums included in the Philadelphia RACT SIP revisions 

address how each major source of NOx and/or VOC in Philadelphia is complying with RACT 

under the 1997 8-hour ozone NAAQS, including source-specific RACT determinations for 

affected emissions units in each major source subject to 25 Pa Code sections 129.91-92. EPA 

has reviewed all documentation submitted by PADEP, on behalf of AMS, supporting its 
12

conclusion it has addressed its RACT obligations under the 1997 8-hour ozone NAAQS for 

Philadelphia, including the information listed in Appendix B attached to this TSD. EPA’s 

evaluation of the Philadelphia RACT SIP revisions, as provided in this section, focuses on the 

source-specific RACT determinations prepared by AMS for 16 major sources, in order to satisfy 

the December 15, 2013 conditional approval. EPA has also evaluated the revisions submitted to 

the previous RACT determination for Cardone Industries Inc., as summarized in section IV-B of 

this TSD.

A. Source-Specific RACT Determinations under the 1997 8-Hour Ozone NAAQS

The source-specific RACT determinations submitted by AMS consist of an evaluation of all

reasonably available controls at this time for each affected emissions unit, resulting in AMS 

determination of what specific control requirements, if any, satisfy RACT for that particular unit. 

For sources subject to source-specific RACT determinations approved for the 1-hour ozone 

NAAQS, AMS evaluated new or additional controls for each affected emissions unit, resulting in 

either a certification that previously adopted RACT controls continue to adequately represent 

RACT for the 1997 8-hour NAAQS, or alternatively the adoption of new or more stringent 

controls as determined to represent RACT for the 1997 8-hour NAAQS (i.e., a new RACT 

determination). For sources newly subject to RACT, AMS evaluated new or additional controls 

for each affected emissions unit, resulting in adoption of controls that were determined to be 

reasonable to satisfy RACT under the 1997 8-hour ozone NAAQS. 

The adoption of new or additional controls or the revisions to existing controls as RACT 

were specified as requirements in new or revised federally enforceable permits (hereafter “RACT 

permits”) issued by AMS for the source. The new or revised RACT Permits have been 

submitted as part of the Philadelphia RACT SIP revisions for EPA’s approval in the 

Pennsylvania SIP under 40 CFR 52.2020(d)(1). For sources subject to previous RACT 

determinations specified in RACT permits under 40 CFR 52.2020(d)(1) for which AMS is 

revising or adopting additional source-specific controls, the revised RACT permits, once 

approved by EPA, will supersede those permits currently in the SIP.

AMS identified 16 major sources in Philadelphia that are subject to Pennsylvania’s sourcespecific RACT requirements to meet RACT under the 1997 8-hour ozone NAAQS, as 

summarized in Table 2 below, including 14 major sources subject to previous source-specific 

RACT determinations and 2 major sources newly subject to source-specific RACT. As 

explained earlier, EPA’s December 13, 2013 conditional approval required AMS to submit 

source-specific RACT determinations for ten major sources of NOx and/or VOC in Philadelphia, 

in addition to a certification that source-specific RACT controls approved under the 1-hour

ozone NAAQS in the Pennsylvania SIP for major sources in Philadelphia, continue to adequately 

represent RACT for the 1997 8-hour ozone NAAQS. AMS submitted source-specific RACT 

determinations for nine of the ten major sources identified in EPA’s conditional approval. 
13

Precisely, AMS did not submit the required source-specific RACT determination for Kraft 

Nabisco (formerly Nabisco Biscuit Co, and presently Mondelez), because this source is no 

longer considered a major source of NOx and VOC for 1997 8-hour ozone RACT. See section 

IV-C of this TSD for further discussion on Mondelez. 

Table 2. Major NOx and/or VOC Sources in Philadelphia Subject to Source-Specific 

RACT under the 1997 8-hour Ozone NAAQS

Major Source Plant ID 

Number

1-Hr

Ozone

RACT 

Source?

Major 

Source

Pollutant

New or Revised

Source-Specific 

Determination?

(“Yes” or 

“No”)

New or Revised 

RACT Permit 

(Effective Date)

Exelon Generating 

Company- Delaware

Station

04901 x NOx No -

Exelon Generating 

Company- Richmond

Station

04903 x NOx Yes PA-51-4903 

(02/09/16)

Exelon Generating

Company- Schuylkill 

Station

04904 x NOx No -

Honeywell- Frankford 

Plant [formerly, Sunoco 

Chemical- Frankford Plant]

01551 x

NOx and 

VOC Yes PA-51-1151 (02/09/16)

Kinder Morgan Liquids 

Terminals, LLC [formerly, 

GATX Terminals Corp.]

05003 x VOC Yes PA-51-5003 

(02/09/16)

Naval Surface Warfare 

Center, Carderock Division 

(NSWCCD) 

09724 x NOx Yes PA-51-9724 

(02/09/16)

Newman & Company, Inc. 03489 x NOx No -

PaperWorks Industries, 

Inc. [formerly, Jefferson 

Smurfit, Corp./ Container 

Corp. of America)

01566 x NOx Yes PA-51-1566 

(01/09/15)

Philadelphia Energy 

Solutions- Refining and 

Marketing, LLC [formerly, 

Sunoco Inc. (R&M)-

Philadelphia]

01501 / 

01517 x

NOx and 

VOC Yes

PA-51-01501 

and PA-51-

01517

(02/09/16)

Philadelphia Gas WorksRichmond Plant 04922 x NOx Yes PA-51-4922 

(01/09/15)

Philadelphia Prison System 09519 NOx Yes PA-51-9519

(02/09/16)
14

Major Source Plant ID 

Number

1-Hr

Ozone

RACT 

Source?

Major 

Source

Pollutant

New or Revised

Source-Specific 

Determination?

(“Yes” or 

“No”)

New or Revised 

RACT Permit 

(Effective Date)

Plain Products Terminals, 

LLC [formerly, Maritank 

Philadelphia, Inc. and 

Exxon Company, USA]

05013 x VOC Yes PA-51-05013

(02/09/16)

Temple- Health Sciences 

Campus 08906 x NOx Yes PA-51-8906 (01/09/15)

Temple- Main Campus 08905 NOx Yes PA-51-8905 

(01/09/15)

Veolia Energy- Edison 

Station [formerly 

TRIGEN- Edison Station] 

04902 x NOx Yes PA-51-4902 

(01/09/15)

Veolia Energy- Schuylkill 

Station [TRIGENSchuylkill Station] / 

Grays Ferry Cogeneration 

Partnership / 

Veolia Energy Efficiency, 

LLC a

04942 / 

04944 / 

10459

x NOx Yes

PA-51-4942 

(02/09/16) / 

PA-51-4944 

(01/09/15) / 

PA-51-10459 

(01/09/15)

a Grays Ferry Cogeneration Plant, Veolia Schuylkill and Veolia Energy Efficiency have been aggregated as a single major source 

after the 1-hour RACT determination. AMS submitted RACT documentation for each facility separately, although considering 

RACT applicability as a single major source of NOx. 

A summary of the source-specific RACT determinations submitted by AMS is provided 

below for each source. For simplicity, the following discussion is provided separately for 

sources previously subject to source-specific RACT and for new sources subject to sourcespecific RACT. 

A-1. Sources with Previous Source-Specific RACT Determinations 

1. Exelon Generating Company - Delaware Station (PLID- 04901)

Exelon Generating Company- Delaware Station (Exelon- Delaware) is as an electric 

generating utility located at 1325 North Beach Street, Philadelphia, Pennsylvania. The facility is 

a major source of NOx and operates four combustion turbines firing number 2 fuel oil, three 

rated 15.5 megawatt (MW) and one rated 17.5 MW.

EPA’s December 13, 2013 conditional approval required AMS to submit a source-specific 

RACT determination for this source, as AMS had indicated it was relying on the NOx SIP Call 

for RACT compliance. AMS has clarified that this source was previously evaluated under the 1-

hour ozone standard and has been subject to a source-specific RACT determination under 25 Pa 

Code sections 129.91-92. The 1-hour ozone RACT determination for Exelon- Delaware is 

specified in RACT Permit PA-51-4901, effective on July 11, 2001 and approved in the SIP on 
15

October 31, 2001. 66 FR 54947. EPA confirms that the 1-hour RACT determination for 

Exelon- Delaware does not rely on the presumption that compliance with the NOx SIP Call 

constituted RACT for any of its emissions units. AMS has re-evaluated RACT for each 

emissions unit to ensure compliance with 25 Pa Code sections 129.91-92. 

At the time of the 1-hour RACT determination, the facility also operated three boilers and 

one emergency generator that were subject to source-specific RACT requirements, but have

permanently been retired. As part of the 1-hour RACT, each combustion turbine accepted a 5

percent (%) annual capacity factor in order to comply with the presumptive RACT requirement 

of 25 Pa Code section 129.93(c)(5) to install, maintain, and operate each unit in accordance with 

manufacturers specifications. The capacity factors for each turbine were incorporated into the 

RACT Permit and approved into the SIP. EPA notes that these additional restrictions (i.e., 

capacity factors) were required to be adopted and made permanent and federally enforceable, in

order for the combustion turbines to be allowed to comply with 25 Pa Code section 129.93(c)(5). 

At the time of the 1-hour ozone RACT, AMS elected to adopt these restrictions by approving 

them as source-specific requirements in the RACT permit and submitted for approval into the 

SIP. At this time, AMS is certifying that these source-specific requirements determined as 

RACT under the 1-hour ozone standard continue to represent RACT under the 1997 8-hour 

ozone NAAQS for Exelon- Delaware.

EPA finds that the RACT determination provided by AMS is reasonable and appropriately 

considered technically and economically feasible controls while setting lowest achievable limits. 

Thus, EPA finds that the source-specific RACT controls currently approved in the SIP 

adequately meet RACT under the 1997 8-hour ozone NAAQS for Exelon- Delaware.

2. Exelon Generating Company- Richmond Station (PLID- 04903) 

Exelon Generation Company- Richmond Station (Exelon- Richmond) is as an electric 

generating utility located at 3901 North Delaware Avenue, Philadelphia, Pennsylvania. The 

facility is a major source of NOx, operating two simple cycle combustion turbines, each rated 66 

MW (or 838 million British thermal units per hour (MMBTU/hr) of heat input) and firing 

number 2 fuel oil. 

EPA’s December 13, 2013 conditional approval required AMS to submit a source-specific 

RACT determination for this source, as AMS had indicated it was relying on the NOx SIP Call 

for RACT compliance. AMS has clarified that this source was previously evaluated under the 1-

hour ozone standard and has been subject to a source-specific RACT determination under 25 Pa 

Code sections 129.91-92. The 1-hour ozone RACT determination for Exelon- Richmond is 

specified in RACT Permit PA-51-4903, effective on July 11, 2001 and approved in the SIP on 

October 30, 2001. 66 FR 54704. EPA confirms that the 1-hour RACT determination for 

Exelon- Richmond does not rely on the presumption that compliance with the NOx SIP Call 
16

constituted RACT for any of its emission units. However, AMS has re-evaluated RACT for each 

emissions unit to ensure compliance with 25 Pa Code sections 129.91-92. 

A NOx emissions limit of 0.70 pounds per heat input rate in million British Thermal Units 

(lb/MMBTU) and a 15% capacity factor limit (based on net generation) were previously 

determined as RACT for each combustion turbine under the 1-hour ozone NAAQS and continue 

to be applicable for the emissions units. AMS evaluated additional controls for the combustion 

turbines, including water/steam injection, selective catalytic reduction (SCR), and conversion to 

natural gas. AMS determined that these additional controls are not technically and/or 

economically reasonable for the combustion turbines and thus do not constitute RACT. 

Specifically, AMS determined that switching to natural gas was unreasonable as there is no 

access to a gas pipeline. AMS is proposing to strengthen the applicable NOx emission limit by 

revising it from 0.70 to 0.68 lb/MMBTU, based on current stack testing data. EPA expects this 

revision to result in additional potential NOx reductions, in terms of pounds per hour (lb/hr) and 

tons per year (tpy), as shown in Table 3 below.

Table 3. Summary of Proposed RACT Revisions for Combustion Turbines at 

Exelon- Richmond

Approved RACT Requirements Proposed Revisions to RACT Requirements

Heat 

Output 

Rating 

(MW)a

Capacity 

Factor (%)b

NOx 

emissions 

rate (lb/ 

MMBTU) 

Potential 

NOx 

Emissions 

(lb/hr)

Potential 

NOx 

Emissions 

(tpy)

Capacity 

Factor (%)b

NOx 

emissions 

rate (lb/ 

MMBTU)

Potential 

NOx 

Emissions 

(lb/hr)

Potential 

NOx 

Emissions 

(tpy)

66 15 0.70* 157.5 103.5 15 0.68* 153.0 100.5

* Denotes federally enforceable limits.

a Conversion factor is 1 MW-hr = 3.4095 million British thermal unit (MMBTU)

b

 Based on net generation

AMS determined that these revisions to the 1-hour ozone RACT determination represent 

RACT under the 1997 8-hour ozone NAAQS. The revised source-specific RACT requirements 

for Exelon- Richmond have been incorporated in the revised RACT Permit PA-51-4903, 

effective in February 9, 2016, and submitted for approval into the SIP to replace the previously 

approved RACT Permit dated July 11, 2001. 

EPA finds that the RACT determination provided by AMS is reasonable and appropriately 

considered technically and economically feasible controls while setting lowest achievable limits. 

Thus, EPA finds that the proposed source-specific RACT controls adequately meet RACT under 

the 1997 8-hour ozone NAAQS for Exelon- Richmond.

3. Exelon Generation Company- Schuylkill Station (PLID 04904)

Exelon Generation Company- Schuylkill Station (Exelon- Schuylkill) is as an electric utility 

located at 2800 Christian Street, Philadelphia, Pennsylvania. The facility is a major source of 
17

NOx and only contains as NOx emissions units two simple cycle combustion turbines, one with 

heat output rating of 68 MW (or 233 MMBTU/hr of heat input) and another with heat output 

rating of 83 MW (or 284 MMBTU/hr of heat input), both firing number 2 fuel oil and kerosene; 

and an emergency generator rated 2.75 MW and firing number 2 fuel oil or kerosene.

EPA’s December 13, 2013 conditional approval required AMS to submit a source-specific 

RACT determination for this source, as AMS had indicated it was relying on the NOx SIP Call 

for RACT compliance. AMS has clarified that this source was previously evaluated under the 1-

hour ozone standard and has been subject to a source-specific RACT determination under 25 Pa 

Code sections 129.91-92. The 1-hour ozone RACT determination for Exelon- Schuylkill is 

specified in RACT Permit PA-51-4904, effective on July 11, 2001 and approved in the SIP on 

October 30, 2001. 66 FR 54704. EPA confirms that the 1-hour RACT determination for 

Exelon- Schuylkill does not rely on the presumption that compliance with the NOx SIP Call 

constituted RACT for any of its emissions units. AMS has re-evaluated RACT for each 

emissions unit to ensure compliance with 25 Pa Code sections 129.91-92. 

At the time of the 1-hour RACT determination, the facility also operated a boiler with 1530 

MMBTU/hr and firing number 6 and number 3 fuel oils, but it was permanently retired in 2012. 

As part of the 1-hour RACT, each combustion turbine accepted a 5% annual capacity factor in 

order to comply with the presumptive RACT requirement of 25 Pa Code section 129.93(c)(5) to 

install, maintain, and operate each unit in accordance with manufacturers specifications. Also as 

a result of the 1-hour RACT determination, the emergency generator is subject to a restriction in 

hours of operation of 500 hours per 12-month rolling average, in order to comply with the 

presumptive RACT requirement of 25 Pa Code section 129.93(c)(5). Both restrictions for each 

turbine and the emergency generator were incorporated into the RACT Permit and approved into 

the SIP. EPA notes that these additional restrictions (i.e., capacity factors and limit in hours of 

operation) were required to be adopted and made permanent and federally enforceable, in order 

for the combustion turbines to be allowed to comply with 25 Pa Code section 129.93(c)(5). At 

the time of the 1-hour RACT, AMS elected to adopt these restrictions by submitting them as 

source-specific requirements in the RACT permit for approval into the SIP. 

At this time, AMS is certifying that these source-specific requirements in addition to the 

presumptive requirements determined as RACT under the 1-hour ozone standard continue to 

represent RACT under the 1997 8-hour ozone for Exelon- Schuylkill. 

EPA finds that the RACT determination provided by AMS is reasonable and appropriately 

considered technically and economically feasible controls while setting lowest achievable limits. 

Thus, EPA finds that the proposed source-specific RACT controls adequately meet RACT under 

the 1997 8-hour ozone NAAQS for Exelon- Schuylkill.
18

4. Honeywell International- Frankford Plant (formerly, Sunoco Chemical- Frankford

Plant (PLID- 01551)

Honeywell International- Frankford Plant (Honeywell) is a chemical manufacturing facility 

located at 4700 Bermuda Street, Philadelphia, Pennsylvania. The facility is a major source of 

both NOx and VOC and is subject to a 1-hour ozone RACT determination under its former 

name, Sunoco Chemicals- Frankford Plant, specified in RACT Permit PA-51-1551, effective on 

July 27, 1999 and approved into the SIP on October 30, 2001. 66 FR 54710. EPA’s December 

13, 2013 conditional approval required AMS to submit a source-specific RACT determination 

for Honeywell, as AMS had indicated the facility has adopted or will adopt additional controls 

after the 1-hour RACT determination that should represent RACT under the 1997 8-hour ozone 

NAAQS.

Honeywell contains the following NOx emissions units: Two 260 MMBTU/hr boilers firing 

waste phenol residue, natural gas, or number 6 fuel oil (Boilers #1 and #2); a 381 MMBTU/hr 

boiler firing natural gas or number 6 fuel oil (Boiler #3); a smaller boiler located at the barge 

loading facility with a heat input rating of less than 20 MMBTU/hr (barge loading boiler); six 

emergency generators firing diesel; and two emergency fire pumps firing diesel. The source

contains the following VOC emission units: Distillation columns, oxidation processes, and 

reactors used in manufacturing organic synthetic organic chemicals, barge loading operations,

truck, rail and drum loading, rail car cleaning, various storage tanks, wastewater treatment plants, 

and VOC fugitive emissions from equipment leaks (pumps, valves, flanges, compressors, 

pressure relief valves, and rupture disks). 

The barge loading boiler, the six emergency generators, and the two emergency fire pumps 

are subject to the presumptive RACT requirements of 25 Pa Code section 129.93(c). The 

oxidation processes, reactors, distillation columns, all storage tanks (with the exception of VT609 and VT-610), and fugitive emissions are covered under CTG regulations approved into the 

Pennsylvania’s SIP. Specifically, the oxidation processes, reactor and distillation columns are 

subject to AMR V Section XVI; the majority of the storage tanks are subject to 25 Pa Code 

section 129.56 or 129.57 (based on storage capacity); and the fugitive emissions are subject to 

AMR V section XIII. AMS has previously found that these requirements continue to adequately 

represent RACT under the 1997 8-hour ozone NAAQS for these sources.

Source-specific RACT requirements were approved under the 1-hour ozone RACT 

determination for Boilers #1, #2, and #3, the barge loading operations, rail car cleaning, two 

storage tanks (VT-609 and VT-610), and the wastewater treatment plants. As provided in the 

SIP approved RACT Permit, the source is not allowed to load from or to barges any VOC with a 

vapor pressure in excess of 1.5 psia at 20 degrees Celsius of temperature. This restriction results 

in potential VOC emissions of only 4.2 tpy. In the RACT Permit, the VOC emissions from rail 

car cleaning are limited to 2.7 tons per 12-month rolling period. Because the potential VOC 
19

emissions from the barge loading operations and the rail car cleaning are small with these 

restrictions, AMS certifies that the 1-hour ozone RACT requirements approved in the SIP 

continue to adequately represent 1997 8-hour ozone RACT for these emissions units.

Per the SIP approved RACT Permit, the source is also required to install and maintain 

internal floating roofs on tanks VT 609-and VT-610. The tanks currently store phenol and 

wastewater, both VOCs with vapor pressures of less than 1.5 psia. EPA notes that there are no 

CTG regulations in Pennsylvania for storage tanks that contain VOCs with such small vapor 

pressures. The RACT Permit also requires the source to operate a thermal oxidizer to control 

VOC emissions from the air stripper at the wastewater facility, with a destruction efficiency of 

95% or greater. AMS indicates that in light of the required control, the potential VOC emission 

from the wastewater facility is 1.6 tpy. Absent any additional information regarding regulation 

of these sources, AMS determines that the 1-hour ozone RACT requirements approved in the 

SIP continue to adequately represent 1997 8-hour ozone RACT for the tanks.

The only source not previously addressed by the 1-hour ozone source-specific RACT 

determination or covered by presumptive or CTG RACT requirements is the truck, rail and drum 

loading. Because the potential VOC emissions from truck, rail and drum loading are very small

(1.6 tpy) and thus considered “de minimis”, AMS determined that no controls are reasonable for 

this emissions unit. Thus, RACT for truck, rail and drum loading under the 1997 8-hour ozone 

NAAQS is no controls. 

AMS has evaluated available controls for Boilers #1, #2, and #3, which are subject to sourcespecific RACT. Boilers #1 and #2 are subject to the following NOx RACT requirements per the 

1-hour RACT determination: To burn phenol residue to a minimum of 51% of heat input value 

(in terms of BTU); NOx emissions for each boiler are limited to 0.35 lb/MMBTU; during ozone 

season (May 1st– September 30th of any given year), the boilers are required to only burn natural 

gas and phenol residue, except if there is a natural gas emergency or testing, at which times 

number 6 fuel oil may be used; combined NOx emissions are limited to 272 tpy; and the source

is required to perform annual combustion tune-up on each boiler at a minimum as specified in 25 

Pa Code section 129.93(b)(2)-(3). 

Per a federally enforceable consent decree, EPA and other air permitting agencies required 

the source to eliminate number 6 fuel oil burning in Boilers #1 and #2, except during natural gas 

curtailments, losses of supply, and during stack test programs.11 As a result, AMS issued in 2013 

a permit to update the relevant RACT requirements to extend the restriction of number 6 oil 

burning to apply throughout the year, rather than only during ozone season. See Plan Approval 

No. 07163 dated January 23, 2013. Since the number 6 fuel oil restriction is more stringent than 

 

11 Referring to the Second Amendment to a Consent Decree between EPA, several states, the City of Philadelphia, 

and Sunoco, Inc, the previous owner of the Frankford plant. (Civil Action No.05-02866).
20

the SIP approved RACT limit for number 6 oil burning on Boilers #1 and #2, AMS considered 

this restriction in evaluating additional controls for RACT. 

AMS evaluated the feasibility of the following available NOx controls on Boilers #1 and #2: 

SCR, selective non-catalytic reduction (SNCR), low NOx burner (LNB), ultra-low NOx burner 

(ULNB), switching to natural gas as fuel, flue gas recirculation (FGR), and staged combustion 

air (SCA). AMS determined each of the controls to be technically infeasible and thus do not 

represent RACT at this time for Boilers #1 and #2. Particularly, AMS found that the operation 

of ULNB, LNB, FGR & SCA would prevent compliance of the boilers with an existing limit of 

carbon monoxide, in addition to impeding proper combustion of waste phenol as a fuel. 

AMS is determining that the newer number 6 oil restriction adequately meets RACT for 

Boilers #1 and #2, and thus is adopting such restriction in replacement of the ozone season 

restriction for number 6 fuel oil that is currently approved as RACT. AMS finds that the current 

NOx RACT limit of 0.35 lb/MMBTU represents the NOx emissions from the boilers when

combusting number 6 fuel oil, thus AMS proposes this RACT NOx limit specifically for number 

6 fuel oil. Alternatively, when burning natural gas, waste phenol, or combination of these fuels, 

AMS finds that a NOx emissions limit of 0.28 lb/MMBTU represents the lowest achievable 

emissions rate for Boilers #1 and #2 for these fuels, based on stack testing data, and thus is 

determining this NOx emissions limit as meeting RACT. AMS finds that the existing combined 

annual NOx emissions limit of 272 tpy and the requirement to perform annual combustion tuneup as specified in 25 Pa Code sections 129.93(b)(2)-(3) continue to meet RACT. 

AMS explained that the source has been recently having a difficult time producing sufficient 

waste phenol to meet the minimum 51% heat input limit, and thus AMS is proposing to remove 

from the SIP the phenol restriction. Since number 6 fuel oil has been almost completely 

restricted, the potential NOx emissions from the boilers have already been reduced. The highest 

NOx emissions expected from the boilers at this time would be from waste phenol combustion. 

Removing the phenol waste restriction would provide the source the flexibility to produce less 

phenol waste and increase its reliance on natural gas on Boilers #1 and #2, a less NOx emitting 

fuel, inherently resulting in greater NOx reductions. Additionally, the combined NOx emissions

limit for both boilers continues to be the most stringent requirement ensuring the lowest 

achievable emissions level based on reasonably available controls. 

Table 4 below, as provided in AMS technical memorandum, presents a comparison of NOx 

emissions based on revisions to RACT requirements. Based on this comparison, AMS 

concluded that the proposed modifications will result at least in the same level of NOx emissions 

from both boilers. EPA finds AMS’ demonstration adequate and finds that the proposed 

revisions for Boilers #1 and #2, removing the phenol waste restriction and the change in number 

6 combustion, will result in equivalent or greater reduced potential NOx emissions, and thus 
21

should not interfere with attainment of the NAAQS or any statutory requirement, pursuant to 

section 110(l) of the CAA

Table 4. Summary of Proposed RACT Revisions for Boilers #1 and #2 at Honeywell

* Denotes federally enforceable limits.

a Potential emissions for the 1-hour RACT scenario are based on the 51% heat input limit for phenol and assuming 

49% heat input used for number 6 fuel oil and operating boilers at full capacity. 

b Potential emissions for the 8-hour RACT scenario are based in the assumptions of phenol burning and operation of

boilers at full capacity. 

Boiler #3, with 381 MMBTU/hr heat input rating and firing natural gas or number 6 fuel oil,

is subject to the following source-specific requirements as specified in the SIP approved RACT 

Permit: Operation and maintenance of LNB, combustion tune-up, and a NOx emissions limit of 

0.3 lb/MMBTU. AMS explained that the RACT Permit does not reflect the control that has been

in place to meet the RACT NOx emission limit of 0.3 lb/MMBTU. The facility proposed in 

1995 to achieve the NOx limit of 0.3 lb/MMBTU by installing and operating LNB and 

“wallports.” The SIP approved RACT Permit (PA-51-1551 dated July 27, 1999) mistakenly 

excluded the requirement to maintain and operate the wall ports in addition of the LNB. AMS 

has confirmed that the facility installed the wall ports along with the LNBs at the time of the 1-

hour RACT determination and both controls have been operated in order to comply with the 

NOx RACT limit. AMS at this time determines that the SIP approved RACT permit should be 

revised to reflect the correct control in place.

Per the federally enforceable consent decree described above, Boiler #3 is also no longer 

allowed to combust number 6 fuel oil, except during natural gas curtailments, losses of supply, 

and during stack test programs.12 AMS evaluated as RACT the installation and operation of 

additional controls for Boiler #3, including water/steam injection, ULNB, SNCR, SCR, FGR, 

ULNB with FGR, and staged combustion air. AMS found these controls to be technically and/or 

economically unreasonable, and thus do not represent RACT at this time for Boiler #3. 

 

12 Referring to the Second Amendment to a Consent Decree between EPA, several states, the City of Philadelphia, 

and Sunoco, Inc., the previous owner of the Frankford plant (Civil Action No.05-02866).

Approved RACT Requirements a Proposed Revisions to 

RACT Requirements b

Heat Input 

(MMBTU/

hr)

Fuel

NOx 

emissions 

rate (lb/ 

MMBTU)

Heat Input 

Basis (%)

Annual 

NOx 

Emissions 

(tpy)

NOx 

emissions 

rate (lb/ 

MMBTU)

Annual 

NOx 

Emissions 

(tpy)

260 Phenol (alone or combined with 

Natural Gas) 0.28 51* 162.6 0.28* 318.9

No. 6 Oil 0.35* 49 195.3 0.35* -

Natural Gas (only) 0.18 - - 0.18 -

Maximum NOx Emissions per Boiler 357.9 - 318.9

Combined NOx Emissions (Both Boilers) 272.0* - 272.0*
22

AMS is adopting the number 6 oil restriction as RACT, as it represents a more stringent level 

of control than currently approved in the SIP for Boilers #3. AMS finds that the current RACT 

limit of 0.3 lb/MMBTU represents the NOx emissions from the boiler when combusting number 

6 fuel oil, thus AMS proposes this RACT limit to apply to the boiler when allowed to burn 

number 6 fuel oil. AMS determines that the NOx emissions from Boiler #3 when burning 

natural gas should be limited to 0.12 lb/MMBTU as RACT, based on stack testing data

supporting this rate as lowest achievable by operation of existing controls. In addition, AMS is 

clarifying the control requirement to include the operation of “wall ports” in combination with 

LNB. AMS determines that altogether these requirements meet RACT under the 1997 8-hour 

ozone NAAQS for Boiler #3.

Table 5. Summary of Proposed RACT Revisions for Boiler #3 at Honeywell

Approved RACT Requirements Proposed Revisions to RACT 

Requirements

Heat Input

Rating 

(MMBTU/

hr)

NOx 

emissions 

rate (lb/ 

MMBTU) 

Potential 

NOx 

Emissions 

(lb/hr)

Potential 

NOx 

Emissions 

(tpy)

NOx 

emissions 

rate (lb/ 

MMBTU)

Potential 

NOx 

Emissions 

(lb/hr) a

Potential 

NOx

Emissions 

(tpy) a

381 0.30* 114.3 500.6 0.12* (gas) 

0.30* (oil)

45.7 200.2

* Denotes federally enforceable limits.

a Since number 6 oil burning has been restricted in most instances, the estimated potential NOx emissions for the 

proposed RACT revisions is based on burning of natural gas as primary fuel.

AMS determined the requirements discussed above to represent NOx RACT under the 1997 

8-hour ozone NAAQS for Boilers #1, #2, and #3 and, thus, is requesting to update the SIP 

approved RACT determination to incorporate them accordingly. The revised source-specific 

RACT requirements for Honeywell have been incorporated in the revised RACT Permit PA-51-

1151, effective in February 9, 2016, and submitted for approval into the SIP.

EPA finds that the RACT determination provided by AMS is reasonable and appropriately 

considered technically and economically feasible controls while setting lowest achievable limits. 

Thus, EPA finds that the proposed source-specific RACT controls adequately meet RACT under 

the 1997 8-hour ozone NAAQS for Honeywell. EPA also finds that the proposed revisions to 

meet RACT will result in equivalent if not additional reductions of NOx emissions and thus 

should not interfere with any applicable requirement concerning attainment or reasonable further 

progress with the NAAQS or interfere with other applicable CAA requirement. 
23

5. Kinder Morgan Liquids Terminal, LLC (formerly, GATX Terminals Corp.) (PLID05003)

Kinder Morgan Liquids Terminals, LLC (Kinder Morgan) is a bulk liquid storage and 

distribution facility located at 3300 North Delaware Avenue, Philadelphia, Pennsylvania. The 

facility is a major source of VOC and is subject to a 1-hour ozone RACT determination under its 

former name, GATX Terminals Corporation, specified in RACT Permit PA-51-5003, effective 

on May 29, 1995 and approved into the SIP on October 31, 2001. 66 FR 54936. EPA’s 

December 13, 2013 conditional approval required AMS to submit a source-specific RACT 

determination for Kinder Morgan, as AMS had indicated the source has adopted or will adopt 

additional controls after the 1-hour RACT determination that should represent RACT under the 

1997 8-hour ozone NAAQS.

Kinder Morgan stores a variety of petroleum chemicals that are transported into or out of the 

facility by ship or barge (marine), rail car, or tank trucks and then the chemicals are stored in 

fixed roof and internal floating roof storage tanks. VOC emissions units at the source include 

tank truck and rail car loading, marine vessel loading (two berths), a large number of storage 

tanks, two 48 HP air compressors, a 490 HP emergency generator (Emergency Generator #1), 

VOC fugitive emissions from process piping pumps, valves, and flanges, and some other 

insignificant sources. There are also two NOx emissions units subject to presumptive RACT, a 

12.6 MMBTU/hr boiler (Boiler #1) and a 13.4 MMBTU/hr (Boiler #2). 

The 1-hour ozone RACT determination specified source-specific requirements for the tank 

truck and rail car loading, the marine vessel loading, and the VOC fugitive emissions. AMS 

notes that there was a 6.7 MMBTU/hr boiler in operation at the time of the 1-hour RACT 

determination that was removed and replaced by Boiler #2 (13.4 MMBTU/hr). The emergency 

generators and the boilers are subject to presumptive requirements of 25 Pa Code 129.93(c). The 

facility has 108 storage tanks, 81 of the tanks with capacities greater than 40,000 gallons and 27 

tanks with capacities less than or equal to 40,000 gallons. The tanks are subject to the CTG 

requirements of 25 Pa Code 129.56 and 129.57, respectively. 

Kinder Morgan also operates some smaller VOC sources, including the soil vapor extraction 

(SVE) remediation system and tank cleaning and degassing operations, with VOC potential 

emissions of 2.7 and 1.8 tons per year respectively. Based on its engineering knowledge and 

experience, AMS has determined that installing control devices on both de minimis emission 

sources is technically and economically unreasonable. AMS also listed other de minimis sources 

that are generally considered insignificant for permitting purposes. See Table V-3 of AMS’s 

RACT technical memorandum for Kinder Morgan; see also Title V Operating Permit V95-044.

The fugitive VOC emissions from pumps, valves, and flanges are subject to source-specific 

RACT from the 1-hour RACT determination. The source is required under the SIP approved 
24

RACT Permit to implement a quarterly leak detection and repair (LDAR) program for all pumps, 

valves, and flanges containing VOC. The RACT Permit also requires the quarterly inspection of 

any valves, pumps, and flanges which process organic liquids with Reid Vapor Pressure (RVP)

of 4.0 psi or greater for visual leaks. At this time, fugitive emissions from Kinder Morgan are 

also subject to AMR V section XIII, which prohibit fugitive emissions of VOC in the 

concentration of 10,000 ppmv, or greater, as measured by PADEP’s approved test methods. 

Because the requirements of AMR V section XIII apply at all times and establish specific leak 

threshold, AMS finds these requirements to be more stringent than the source-specific RACT 

requirements. AMS has determined that the requirements in AMR V section XIII will supersede 

the source-specific LDAR requirements specified in the SIP. Consequently, AMS proposes to 

remove the source-specific requirement for fugitives from the SIP approved RACT 

determination. 

Loading at tank car and truck loading racks is subject to source specific RACT. Petroleum 

chemicals are transferred between a tank car or truck and the storage tank (loading) and vice 

versa (unloading). The loading racks consist of multiple loading positions; each position 

connected to a specific storage tank. The source-specific requirements for the loading racks 

provided in the SIP approved RACT Permit depend on the volatility of the organic chemicals 

loaded (related to RVP), consistent with the CTG RACT requirements in 25 Pa Code section 

129.59 for bulk gasoline terminals. As defined in 25 Pa Code section 121.1, gasoline is defined 

as a petroleum distillate with a RVP of 4.0 psi or greater, and which is liquid at standard 

temperature and pressure.13 As provided in 25 Pa Code 129.59(a), the loading of gasoline into 

tanks from a bulk gasoline terminal is prohibited in Pennsylvania, unless the loading racks are 

equipped with a vapor collection and disposal system capable of limiting VOC emissions to 

0.0668 pounds (lb) (measured as propane) per 100 gallons of gasoline loaded. 

The SIP approved RACT Permit identifies the tank car and truck loading racks as either 

“controlled” or “uncontrolled,” as the racks would be either connected or not respectively to the 

existing thermal oxidation unit. Per the SIP approved RACT Permit, the “controlled” loading 

racks are A, B, E, F, M and V; while the remaining racks, C, D, G, H, N, O, P, R, R-1, T and X, 

are “uncontrolled.” The “controlled” racks are required in the RACT Permit to comply with 25 

Pa Code section 129.59. Thus, the “controlled” racks are allowed to load organic liquids with 

RVP of 4.0 psi or greater, while required to control VOC emissions through the operation of the

thermal oxidation unit. The SIP approved RACT Permit requires “uncontrolled” racks to only 

allow loading of organic liquids with RVP of less than 4.0 psi and to comply with a combined 

VOC emissions limit of 129 tpy of VOC. 

The loading racks have been modified several times since the 1-hour ozone RACT Permit was 

 

13 EPA also notes that Kinder Morgan is a bulk gasoline terminal due to having a daily throughput of less than 

20,000 gallons (76,000 liters), as defined in 25 Pa Code section 121.1.
25

issued, as specified in the technical memorandum. Four additional loading racks have been 

installed since the 1-hour ozone RACT determination: DSP, Rail Sliding 1, Rail Sliding 2, and 

Rail Sliding 3. In most cases, the facility requested to modify the existing loading racks to allow 

connecting or disconnecting them to the thermal oxidizer, in order to be accommodate liquid 

organic chemicals with different volatilities and satisfy customer demand. As explained by 

AMS, the SIP approved RACT requirements for the loading racks have not been modified to this 

date, and continue to be applicable.

In 2010, the facility clarified through a permit modification application that the connections 

to the existing control are made to individual loading positions, rather than the entire loading 

rack, as each position is connected to a storage tank, each tank used for storing different liquid 

organic chemicals. The facility also clarified that some “controlled” racks include loading 

positions that are connected to the control and some positions that are not connected. Although 

some positions in the “controlled” racks were operated without the use of the thermal oxidation 

unit (i.e., uncontrolled), these positions were only allowed to load organic liquids with RVP of 

less than 4.0 psi to remain in compliance with the RACT requirements in 25 Pa Code section 

129.59, as required by the SIP approved RACT Permit. As explained earlier, 25 Pa Code 

129.59(a) prohibits uncontrolled loading of organic liquids with RVP of 4.0 psi or greater. Prior

to 2010, the facility had further presumed that these “uncontrolled” positions at “controlled” 

racks were also subject to the 129 tons per year limit specified for the “uncontrolled” loading 

racks. 

The facility requested in the 2010 permit application that the RACT requirements be revised 

to specify the VOC emissions sources as the loading positions, rather than the racks, and to 

clarify the applicable requirements for “controlled” and “uncontrolled” loading. To avoid 

burdensome permit modifications and SIP revisions, Kinder Morgan also requested to remove 

the identification of the specific racks or positions from the RACT Permit, so that the facility can

operate the racks in any configuration, but limited to the compliance of the specified RACT 

requirements. AMS issued this permit modification (AMS Permit 09105) in January 19, 2010.

14

Currently, the loading racks with “controlled” loading positions are A, D, E, F, M, and Rail 

Sliding 1, and the loading racks with “uncontrolled” positions are B, C, G, H, N, O, P, R, R-1, V, 

X, DSP, Rail Sliding 2, and Rail Sliding 3. Table 6 summarizes the current configuration of the 

loading racks, including the number of positions per rack and if each position is “controlled” or 

“uncontrolled.” 

 

14 AMS had not previously requested any permit modifications to be reflected in the applicable RACT determination 

and SIP approved RACT Permit until the present SIP revisions under review in this rulemaking. 
26

Table 6. Existing Configuration of Tank Car and Truck Loading Positions 

at Kinder Morgan

Rack ID “Controlled” Loading 

Allowed? 

(“Yes” /“No”)

No. of “Controlled” 

Positions

No. of 

“Uncontrolled” 

Positions

A Yes 2 2

D Yes 2 3

E Yes 1 6

F Yes 2 2

M Yes 2 4

Rail Sliding 1 Yes 1 5

B No - 2

C No - 2

G No - 4

H No - 2

N No - 2

O No - 4

P No - 2

R No - 4

R-1 No - 2

T No 4

V No - 1

X No - 2

DSP No - 1

Rail Sliding 2 No - 12

Rail Sliding 3 No - 7

For the loading of organic liquids with RVP of 4.0 psi or greater (in “controlled” loading 

positions), AMS proposes that RACT should continue to be compliance with 25 Pa Code 129.59, 

as this requirement continues to represent the most stringent level of control. In order to further 

ensure VOC reductions, AMS is also proposing as RACT to include an additional VOC limit of 

57 lb/hr for all “controlled” loading positions. 

AMS evaluated RACT controls for the loading of organic liquids with RVP of less than 4.0 

psi in “uncontrolled” loading positions, based on the current configuration of the racks as

specified in Table 6. AMS evaluated available VOC controls, including thermal oxidation, 

carbon adsorption, bioreactor, scrubber, and condensation. AMS determined that these controls 

are not technically nor economically reasonable for the loading of organic liquids with RVP of 

less than 4.0 psi, and thus do not constitute RACT. Therefore, AMS certifies that 1-hour ozone 

RACT requirements continue to represent RACT under the 1997 8-hour ozone NAAQS. In 

order to further ensure compliance with the 129 tons of VOC per year limit, AMS is proposing

additional VOC limits per “uncontrolled” loading position of 9.0 tpy and 18.1 lb/hr. A summary 

of the revised RACT requirements for Kinder Morgan’s tank car and truck loading is provided in 

Table 7 below.
27

Table 7. Summary of Proposed RACT Revisions for Tank Car and Truck Loading 

at Kinder Morgan

Loading Type Approved RACT Requirements Proposed Revisions to RACT 

Requirements

VOC Emissions 

Limit, per 

Position 

VOC Emissions 

Limit, All 

Positions 

VOC Emissions 

Limit, per 

Position 

VOC Emissions 

Limit, All 

Positions 

Loading of Liquids 

with RVP of 4.0 psi 

or greater (i.e., 

“controlled loading 

positions”)

- 129 tpy* 18.0 lb/hr*

9.0 tons per 12-

month rolling 

period*

129 tons per 12-

month rolling 

period*

Loading of Liquids 

with RVP of less than 

4.0 psi (i.e., 

“uncontrolled loading 

positions”)

0.0668 lb/ 100 

gallons of 

gasoline loaded*

- 0.0668 lb/ 100 

gallons of 

gasoline loaded*

57 lb/hr*

* Denotes federally enforceable limits.

Kinder Morgan operates two marine vessel berths, Berth 1 and 2, for the loading of organic 

liquids from barges into the source’s storage tanks, and vice versa. Per the SIP approved RACT 

Permit, marine vessel loading at the source is limited to organic liquids with RVP of less than 4 

psi and its VOC emissions are limited to 59 tpy. 

On September 19, 1995, EPA finalized a rule for the regulation of VOC and air toxics

emissions from marine tank vessel loading operations, as codified in 40 CFR part 63, subpart Y

(Subpart Y).

15

 60 FR 48399. Pursuant to section 183(f)(1) of the CAA, EPA’s Subpart Y rule 

requires large marine loading terminals which load at least 200 million barrels per year of crude 

oil or 10 million barrels per year of gasoline, to reduce emissions of VOC by 95 percent using 

RACT. Subpart Y also requires separate requirements for marine loading terminals which are 

major sources of hazardous air pollutants (HAPs), in order to meet the maximum achievable 

control technology (MACT) as required under the air toxics provisions of the CAA.16 Because

Kinder Morgan’s marine loading operations have been required in the SIP approved RACT 

Permit (effective in May 29, 1995) to load non-gasoline liquid organics (with RVP of less than 

4.0 psi), the source is not subject to the RACT requirements of 40 CFR part 63, subpart Y.

Consequently, the loading operations continue to be subject to source-specific RACT under 25 

Pa code section 129.91-92 for the 1997 8-hour ozone NAAQS. 

 

15 Since its original approval in 1995, the regulation in Subpart Y has been subsequently amended by EPA. For the 

latest version of the rule as well as references to EPA’s rulemaking notices approving these amendments, see 40 

CFR part 63, subpart Y.

16 EPA’s definition of gasoline under Subpart Y is consistent with Pennsylvania’s approved definition of gasoline in 

25 Pa. Code 121.1 (as previously discussed in this TSD). See 40 CFR 63.561.
28

In 2012, Kinder Morgan increased the storage of cumene, and consequently the marine

loading operations of this chemical. Cumene is a VOC producing organic liquid that is also 

considered a HAP. While this operational increase has not affected compliance with previously 

determined RACT, the facility determined it would affect its ability to comply with an existing 

federally enforceable facility-wide limit of HAPs. As a result, Kinder Morgan installed a marine 

vapor combustor unit (MVCU) that was purchased by the client to control HAP emissions from 

cumene loading, and consequently VOC emissions. The MVCU was specifically designed for

controlling cumene emissions, thus it can only handle organics with a true vapor pressure below 

0.4 psi which greatly restricts its operation. Based on this technical limitation and the legal 

agreements between Kinder Morgan and the client that purchased the MVCU which require 

using the existing control for cumene loading only for this particular client, AMS determined 

that the MVCU is not a reasonably available control option for all VOC emissions from marine 

loading, and that it does not represent RACT.

AMS evaluated as RACT for the marine loading the installation and operation of new VOC 

controls, including thermal oxidation, carbon adsorption, bioreactor, scrubber, and condensation. 

AMS determined that these controls are not technically nor economically reasonable for the 

marine loading of organic liquids with RVP of less than 4.0 psi, and thus do not constitute 

RACT. To ensure additional reductions of VOC emissions, AMS is proposing to revise the

existing RACT limit of 59 tpy to 51 tons per 12-month rolling. A summary of the revised RACT 

requirements for Kinder Morgan’s marine loading is provided in Table 8.

Table 8. Summary of Proposed RACT Revisions for Marine Vessel Loading at Kinder 

Morgan

Approved RACT 

Requirements

Proposed Revisions to 

RACT Requirements

VOC Emissions Limit VOC Emissions Limit 

59 tpy* 51 tons per 12-month 

rolling period*

* Denotes federally enforceable limits.

AMS determined the revised requirements discussed above to represent VOC RACT under 

the 1997 8-hour ozone NAAQS for the fugitive emissions, tank car and truck loading, and 

marine vessel loading at Kinder Morgan, respectively. Thus, AMS is requesting to update the 

SIP approved RACT determination to incorporate them accordingly. The revised source-specific 

RACT requirements for Kinder Morgan have been incorporated in the revised RACT Permit PA51-5003, effective in February 9, 2016, and submitted for approval into the SIP.

EPA finds that the RACT determination provided by AMS is reasonable and appropriately 

considered technically and economically feasible controls while setting lowest achievable limits. 

Thus, EPA finds that the proposed source-specific RACT controls adequately meet RACT under 
29

the 1997 8-hour ozone NAAQS for Kinder Morgan. EPA also finds that the proposed revisions 

to meet RACT (for fugitive VOC emissions) should not increase emissions of VOC; thus these 

revisions should not interfere with any applicable requirement concerning attainment or 

reasonable further progress with the NAAQS or interfere with other applicable CAA 

requirement.

6. Naval Surface Warfare Center- Carderock Division (PLID- 09724)

Naval Surface Warfare Center- Carderock Division (NSWCCD) is a Navy research and 

development facility located in 5001 South Broad Street, Philadelphia, Pennsylvania. The 

facility is a major source of NOx and is subject to two separate RACT determinations under the 

1-hour ozone standard as specified in the RACT Permit PA-51-9724, effective on December 27, 

1997, and the RACT Permit PA-4108, effective on October 18, 2004, both approved into the SIP 

on October 30, 2001 and April 29, 2005, respectively. See 66 FR 54710 and 70 FR 22257. 

As detailed in the submitted AMS technical memorandum, NSWCCD currently operates a 

number of NOx emitting combustion units, including 20 smaller boilers and heaters, each less 

than 10 MMBTU/hr; a 202 MMBTU/hr wall-fired boiler firing diesel located in Building 633 

(DDG-15); 9 emergency generators firing diesel fuel or natural gas; 5 diesel fired gas turbines;

and 13 diesel fired engines. The source has been significantly modified since the time of the 

previous RACT determination. The SIP approved RACT Permit PA-51-9724 establishes sourcespecific requirements for various combustions units, but most units have been permanently 

removed with the exception of a 200 KW diesel fired emergency generator located in Building 

77 High, a 25 KW diesel fired emergency generator, and the wall-fired boiler with heat input 

rating of 202 MMBTU/hr and firing diesel, located in Building 633 (Boiler DDG-15). The 1-

hour ozone RACT determination, as approved in the RACT Permit PA-51-9724, addressed

specific requirements for the two diesel fired emergency generators and a general requirement 

for all boilers (including Boiler DDG-15), diesel engines, and gas turbines in the source to 

adhere to the standard Navy Planned Maintenance Program as defined for shipboard use. 

The 20 small boilers and heaters (each less than 10 MMBTU/hr) and all emergency 

generators are currently subject to presumptive RACT requirements of 25 Pa Code section 

129.93(c) to be installed, maintained, and operated in accordance with the manufacturer’s 

specifications. Each of the small boilers and heaters, all installed after the 1-hour ozone RACT 

determination, are subject to 25 Pa Code section 129.93(c)(1). All emergency generators have 

taken federally enforceable restrictions to operate less than 500 hours per 12-month rolling 

period, and thus are subject to the presumptive requirement of 25 Pa Code section 129.93(c)(5). 

For the two diesel fired emergency generators existing at the time of the 1-hour RACT

determination (200 KW and 25 KW), these operational restrictions have been approved into the 

RACT Permit PA-51-9724 and approved into the SIP as source-specific RACT. See also the 

Title V Operating Permit V13-009 for all other units.
30

The diesel engines, gas turbines, and Boiler DDG-15 are currently subject to source-specific 

RACT requirements of 25 Pa Code 129.91-92. Boiler DDG-15 is used for testing of marine 

boilers. The testing engines and turbine engines, all installed after the 1-hr RACT determination,

have the same testing functions and purposes as the testing engines and turbines that were 

existing at the time of the 1-hour ozone RACT evaluation. To meet the definition of testing 

units, the engines, the turbines, and the boiler must be configured exactly as their counterpart on 

a Navy ship and must be conditioned to mimic an at-sea environment. AMS evaluated all 

available controls for Boiler DDG-15, including LNB and FGR, and for all turbines and engines, 

including water/steam injection, dry low NOx emissions, SCR, and SCNR. Because NSWCCD 

must equip and operate most of its sources like their shipboard counterparts to achieve effective 

testing platforms, the installation of controls would impede the use of the units with the purpose 

of research and development for national security for Department of Defense. For this reason, 

AMS has previously determined and continues to determine that the installation and operation of 

controls is technically infeasible for the testing application of the units. 

In addition, per 25 Pa Code 129.91(i) and as specified in the SIP approved RACT Permit PA51-9724, the source was required to determine a NOx emissions rate for any boiler with heat 

input greater than 100 MMBTU/hr through either stack testing or modeling. This requirement is 

applicable to the one remaining boiler at the source, Boiler DDG-15, with heat input rating of 

202 MMBTU/hr. AMS explains that although this boiler has not been in regular used since 

2003, NSWCCD has indicated it does not plan to shut it down completely, thus this requirement 

is still in effect. AMS is setting a NOx emissions rate of 0.38 MMBTU/hr for this boiler, based 

on the stack testing conducted in 2003, since no stack testing has being completed since then. 

AMS has committed to re-evaluate the NOx limit based on future stack testing.

At this time, AMS is certifying that the 1-hour ozone RACT requirement to adhere to the

standard Navy Planned Maintenance Program as defined for shipboard use, continues to 

represent RACT under the 1997 8-hour ozone NAAQS for the remaining emissions units

previously subject to this requirement. AMS also determines that it is reasonable to require 

newer boilers, diesel engines, and gas turbines in the facility that have been installed after the 1-

hour ozone RACT determination to adhere to this program.

AMS proposes that the NOx requirements discussed above represent RACT under the 1997 

8-hour ozone NAAQS for NSWCCD, thus, is requesting to update the SIP approved RACT 

determination accordingly. The new and revised source-specific RACT requirements for 

NSWCCD have been incorporated in the revised RACT Permit PA-51-9724, effective in 

February 9, 2016, which has been submitted for approval into the SIP to replace the previously 

approved RACT Permit dated December 27, 1997. The revised RACT permit no longer lists the 

shutdown emissions units that were listed in the earlier version of this permit, as currently 
31

approved in the SIP. AMS is also requesting to remove from the SIP the RACT Permit PA4108, effective on October 18, 2004, because the affected units addressed in the permit have 

been permanently shut down. Since these emissions units have been shutdown, EPA does not 

expect any effects on air quality impacts as a result of this revision. 

EPA finds that the RACT determination provided by AMS is reasonable and appropriately 

considered technically and economically feasible controls while setting lowest achievable limits. 

Thus, EPA finds that the proposed source-specific RACT controls adequately meet RACT under 

the 1997 8-hour ozone NAAQS for NSWCCD. EPA also finds that the proposed revisions to the 

RACT determinations in the SIP should not result in any increase emissions of NOx or VOC, as 

these sources are no longer in operation, thus should not interfere with any applicable 

requirement concerning attainment or reasonable further progress with the NAAQS or interfere 

with other applicable CAA requirement.

7. Newman & Company, Inc. (PLID- 03489)

Newman and Company, Inc. (Newman) is a paperboard manufacturing facility located at

6101 Tacony Street, Philadelphia, Pennsylvania. The facility is a major source of NOx and is 

subject to a 1-hour ozone RACT determination specified in RACT Permit PA-51-3489, effective 

on June 11, 1997 and approved into the SIP on October 30, 2001. See 66 FR 54691. The source

contains the following NOx emissions units: A water-tube boiler with a maximum heat input 

rating of 118 MMBTU/hr firing natural gas and number 6 fuel oil (Boiler #1); 29 natural gas 

fired space heaters with heat input ratings of less than 0.5 MMBTU/hr; two natural gas fired 

power washers with heat input ratings of less than 0.5 MMBTU/hr; and a number 2 fuel oil fired 

fire pump with 973,000 BTU/hr.

The 29 small space heaters, the fire pump, and the two washers are small combustion units 

subject to the presumptive RACT requirements of 25 Pa Code section 129.93(c). Boiler #1 is the 

only emissions unit in Newman subject to source-specific RACT under 25 Pa Code sections 

129.91-92. The following NOx limits were previously determined as RACT under the 1-hour 

ozone NAAQS and continue to be applicable for Boiler #1: 0.43 lbs/MMBTU when firing 

number 6 oil, 0.37 lbs/MMBTU when firing natural gas, and total NOx emissions limited to 121 

tons per rolling 12-month period. AMS evaluated additional controls for Boiler #1, including 

FGR and LNB. AMS determined that additional controls are not technically nor economically 

reasonable for Boiler #1 and thus do not constitute RACT. Therefore, AMS certifies that 1-hour 

ozone RACT determination continues to represent RACT under the 1997 8-hour ozone NAAQS.

EPA finds that the RACT determination provided by AMS is reasonable and appropriately 

considered technically and economically feasible controls while setting lowest achievable limits. 

Thus, EPA finds that the source-specific RACT controls currently approved in the SIP 

adequately meet RACT under the 1997 8-hour ozone NAAQS for Newman. 
32

8. Paperworks Industries, Inc. (formerly, Jefferson Smurfit, Corp./ Container Corp. of 

America) (PLID- 01566)

Paperworks Industries, Inc. (Paperworks) is a paperboard manufacturing facility located at

5000 Flat Rock Road, Philadelphia, Pennsylvania. The facility is a major source of NOx and is 

subject to a 1-hour ozone RACT determination, under its former name, Jefferson Smurfit

Corp./Containers Corp. of America, as specified in RACT Permit PA-51-1566, effective on April 

10, 1995 and approved into the SIP on October 31, 2001. See 66 FR 54947. The source contains 

the following NOx emissions units: A Riley boiler with a capacity of 156 MMBTU/hr (Boiler 

#1) firing number 6 oil and natural gas and two 92.27 MMBTU/hr, natural gas fired boilers 

(Boilers #3 and #4). At the time of the 1-hour RACT determination, the source also operated a 

Riley boiler with a capacity of 225 MMBTU/hr (Boiler #2) firing coal, number 6 oil and natural 

gas; and four natural gas fired infrared heaters, each with 2.9 MMBTU/hr heat input capacity. 

Boiler #2 and the four infrared heaters were shutdown in 2008. 

Source-specific NOx RACT was determined under the 1-hour ozone NAAQS for Boiler #1, 

Boiler #2 and the four infrared heaters. Boiler #1 was permitted and operated at the time with a 

capacity of 240 MMBTU/hr and fired coal, number 6 oil, and natural gas. The following NOx 

limits were determined as 1-hour RACT for both Boilers #1 and #2: 0.20 lbs/MMBTU while 

burning natural gas, 0.30 lbs/MMBTU while burning number 6 oil, and 0.50 lbs/MMBTU while 

burning coal, all limits on a 30-day rolling average; and total combined NOx emissions were 

limited to 1,018 tpy. Also, Boilers #1 and #2 were required to install and operate a LNB with 

overfire air as RACT. 

In 2014, Boiler #1 was modified to limit its heat input rating to 156 MMBTU/hr, prohibit

burning coal, and allow the combustion of number 6 fuel oil solely during emergencies or in 

cases of natural gas interruptions. The use of number 6 oil combustion was also limited to 169 

hours per 12-month rolling. See Plan Approval No. 08179A, issued by AMS on December 19, 

2014. Considering the most stringent applicable requirements to date, AMS evaluated as RACT 

additional controls for Boiler #1, including FGR, SNCR, and SCR. AMS determined that these 

additional controls are not technically nor economically feasible. Thus, AMS determined that 

the current operation of the existing RACT controls in addition to recent operational restrictions 

for Boiler #1 represent RACT under the 1997 8-hour ozone NAAQS. AMS is requesting to 

update the SIP approved RACT determination accordingly. As indicated by AMS, the proposed 

RACT revisions to Boiler #1 should result in additional reductions of potential NOx emissions, 

as presented in Table 9 below. 
33

Table 9. Summary of Proposed RACT Revisions for Boiler #1 at Paperworks

Fuel

Approved RACT Requirements a

Proposed Revisions to RACT 

Requirements b

Heat Input 

(MMBTU/

hr)

NOx 

emissions 

rate (lb/ 

MMBTU)

Annual 

NOx 

Emissions 

(tpy)

Heat Input 

(MMBTU/

hr)

NOx 

emissions 

rate (lb/ 

MMBTU)

Annual 

NOx 

Emissions 

(tpy)

Coal 240 0.50* 525.6 156* - -

Number 6 Oil 0.30* - 0.30* 3.9

Natural Gas 0.20* - 0.20* 134.0

Total NOx Emissions 525.6 - - 137.9

* Denotes federally enforceable limits.

a Potential annual emissions on this scenario are based on coal combustion, the highest emitting fuel allowed under 

1-hour RACT, and operation of the boiler at full capacity. Note that coal usage is no longer allowed, but emissions 

are presented as currently permitted for RACT purposes.

b

 Potential annual emissions on this scenario are based on natural gas and number 6 oil combustion, the limit on 

number 6 oil usage, and the operation of the boiler at full capacity. Note that coal usage is no longer allowed.

Boilers #3 and #4 are in operation since 2009. Although originally allowed to burn number 6 

oil and natural gas, Boilers #3 and #4 were restricted from burning number 6 fuel oil in 2014. 

See Plan Approval No. 08179 dated December 30, 2008 and Plan Approval No. 08179A issued 

by AMS on December 19, 2014. The currently applicable federally enforceable requirements for 

Boiler #3 and Boiler #4 are: NOx emissions limits of 0.025 lbs/MMBTU burning natural gas

and 10.15 tons per rolling 12-month period; operation of LNB and FGR controls; and restriction 

to only burn natural gas (per Plan Approval No. 08179A). AMS determined these requirements 

to represent NOx RACT under the 1997 8-hour ozone NAAQS and, thus is requesting to update 

the SIP approved RACT determination to incorporate them accordingly. 

Additionally, AMS is updating the SIP approved RACT determination to remove any 

references to the retired emissions units, Boiler #2 and the four infrared heaters. Since these 

emissions units have been shutdown, EPA does not expect any effects on air quality impacts as a 

result of this revision. The new and revised source-specific RACT requirements for Paperworks

have been incorporated in the revised RACT Permit PA-51-1566, effective in January 9, 2015, 

and submitted for approval into the SIP. The revised RACT permit will replace the previous 

version of the RACT Permit dated April 10, 1995, as approved in the SIP. 

EPA finds that the RACT determination provided by AMS is reasonable and appropriately 

considered technically and economically feasible controls while setting lowest achievable limits 

and that the proposed source-specific RACT controls adequately meet RACT under the 1997 8-

hour ozone NAAQS for Paperworks. EPA also finds that the proposed revisions to meet RACT 

will result in equivalent or additional reductions of NOx emissions and thus should not interfere 

with any applicable requirement concerning attainment or reasonable further progress with the 

NAAQS or interfere with other applicable CAA requirement.
34

9. Philadelphia Energy Solutions- Refining and Marketing, LLC (formerly, Sunoco Inc. 

(R&M)- Philadelphia) (PLID- 01501 and 01517)

Philadelphia Energy Solutions- Refining and Marketing, LLC (PES) is a petroleum refinery 

located at 3144 Passyunk Avenue, Philadelphia, Pennsylvania. The refinery is a major source of 

both NOx and VOC and is subject to a 1-hour ozone RACT determination, as specified in RACT 

Permits PA-51-1501 and 51-1517 for the former owner Sunoco, Inc. (R&M)- Philadelphia

(issued as a single document), effective on August 1, 2000 and approved into the SIP on October 

31, 2001. 66 FR 54942. EPA’s December 13, 2013 conditional approval required AMS to 

submit a source-specific RACT determination for PES, as AMS had indicated the source has 

adopted or will adopt additional controls after the 1-hour RACT determination that should 

represent RACT under the 1997 8-hour ozone NAAQS. AMS submitted two separate sourcespecific RACT determinations for PES: The first determination, included in the June 27, 2014

SIP revision, addresses 7 specific process heaters that were recently modified; and the second 

determination, included in the March 26, 2016 SIP revision, addresses the remaining emissions 

units at PES.

The facility’s NOx and VOC emission units include 33 process heaters, 3 boilers, 2 fluid 

catalytic cracking units (FCCUs), 5 diesel-fired non-emergency reciprocating internal 

combustion engines (RICE) with heat input ratings of less than 2 MMBTU/hr, 11 emergency

generators and fire pumps, a large number of storage tanks (i.e., tank farm), two stormwater 

tanks (Tanks 7308 and 7300), cooling towers, truck loading operations, marine vessel loading 

operations, oil-water separators and degreasers, fugitive emissions from cooling towers, and 

fugitive emissions from valves, flanges, and pumps. The SIP approved RACT Permits include

source-specific requirements for numerous heaters, the 3 boilers, one of the FCCUs, fugitive 

emissions from cooling towers, and fugitive emissions from valves, pumps, flanges and 

compressors. The following units are currently subject to source-specific RACT: Process 

heaters, boilers, FCCUs, the engines, some truck loading operations, and marine vessel loading 

operations. 

The eleven emergency generators and fire pumps are subject to the presumptive RACT

requirement of 25 PA Code Section 129.93(c)(5) to be installed, maintained, and operated in 

accordance with manufacturer’s specifications. Each unit is limited to a federally enforceable 

restriction to operate less than 500 hours per rolling 12-month period. See Title V/State 

Operating Permit No. V06-016. 

The following VOC emissions units at PES are subject to CTG RACT requirements: 

Wastewater treatment plant, oil/water separators, degreasers, storage tanks, stormwater tank, and 

truck loading operations. The wastewater treatment plant and oil/water separators are subject to 

25 Pa Code section 129.55. Degreasers are subject to 25 Pa Code section 129.63. Storage tanks 
35

and the two stormwater tanks (Tanks 7308 and 7300) are subject to 25 Pa Code sections 129.56 

and 129.57. Truck loading operations for liquid organic materials with a RVP of 4.0 psi or 

greater are subject to the CTG RACT requirements of AMR V, section V. AMS has previously 

certified that these requirements continue to represent RACT under the 1997 8-hour ozone 

NAAQS.

AMS indicates VOC emissions from truck loading operations for liquid organic materials

with a RVP of less than 4.0 psi are small and thus considered de minimis. At this time, the 

source only loads cumene (with a RVP below 4.0 psi), which has potential VOC emissions of 2 

tpy. Based on AMS permitting and engineering knowledge, AMS determines that installing any 

control technology on such small source of VOC emissions (i.e., de minimis source) is both 

technically and economically unreasonable.

The fugitive VOC emissions from pumps, valves, and flanges are subject to 1-hour ozone 

source-specific RACT requirements. PES is required under the SIP approved RACT Permits to 

implement a quarterly LDAR program for all pumps, valves, and flanges, and compressors in 

VOC service. Fugitive emissions from equipment leaks are also subject to the CTG RACT 

requirements in 25 Pa Code section 129.58. AMS finds that the provisions in 25 Pa Code section 

129.58 are more stringent than the source-specific LDAR requirement, because it has more 

frequent monitoring and a specific leak threshold. AMS determines that the requirements of 25 

Pa Code section 129.58 satisfy RACT under the 1997 8-hour ozone NAAQS for fugitive 

emissions at PES. Accordingly, AMS is requesting to remove the quarterly LDAR program 

from the SIP. EPA anticipates equivalent or additional reductions from this revision and 

compliance with the CTG RACT requirements.

As explained in the technical memorandum, fugitive VOC emissions are emitted from 

cooling towers as a result of the evaporation of organics dissolved in the cooling water streams 

that are processed in the towers. The SIP approved RACT Permits require PES to reduce 

fugitive emission through the inspection, maintenance, and monitoring of the cooling towers. 

PES is currently subject to EPA’s requirements for refineries codified at 40 CFR 63, subpart CC 

(“National Emissions Standards for Hazardous Air Pollutants from Petroleum Refineries”). The 

regulation requires the source to implement a rigorous LDAR program that includes regulation 

of fugitive emissions from cooling towers. AMS determines that these requirements are more 

stringent than the RACT requirements approved under the 1-hour ozone NAAQS, and 

determines that compliance with 40 CFR 63, subpart CC should represent RACT under the 1997 

8-hour ozone NAAQS. AMS is replacing the source-specific RACT requirement in the SIP for 

cooling towers with the requirement of compliance with 40 CFR 63, subpart CC. 

The 5 diesel-fired non-emergency engines have potential emission of NOx and VOC of less 

than 2 tpy. Thus, based on its permitting and engineering knowledge, AMS determined that 
36

installing any controls on these de minimis sources is technically and economically 

unreasonable.

As indicated earlier, PES operates 33 process heaters and 3 boilers, as identified in Table 10 

below. All heaters and boilers with heat input ratings of 50 MMBTU/hr and above are subject to 

source-specific RACT; while units with heat input ratings under 50 MMBTU/hr are subject to 

the presumptive RACT requirements in 25 Pa Code section 129.93(b)(2) to perform annual 

adjustment or tune-up on the combustion process (hereafter “annual tune-up”). AMS determines 

that these presumptive requirements continue to meet RACT under the 1997 8-hour ozone 

NAAQS for heaters and boilers with heat input ratings under 50 MMBTU/hr. The approved 

source-specific RACT requirements under the 1-hour ozone NAAQS are summarized as well in 

Table 10. A number of heaters and boilers addressed in the SIP approved RACT Permits have 

shut down since the previous RACT determination, as identified in the AMS’s technical 

memorandum. Three additional heaters have been installed after the 1-hour RACT 

determination, 859-1H1, 870-H01, and 870-H02.

Table 10. Process Heaters and Boilers at PES and Applicable Source-specific 

RACT Requirements under the 1-hour Ozone NAAQS

Emissions Unit Applicable RACT 

Requirement

1-hour Ozone Source-Specific RACT Requirements

Heat Input 

Rating 

(MMBTU/hr)

Control 

Requirement

NOx Emissions 

Limit* 

(lb/MMBTU)

Potential 

NOx 

Emissions 

(tpy)d

Heater 210-H101 a Source-specific 183.0 Annual tune-up

0.089 (gas) 

0.400 (oil) 320.6

Heater 210-H201 

A/B a

Source-specific 242.0* Annual tune-up

0.173 (gas) 

0.400 (oil) 424.0

Heater 210-13H1 Source-specific 235.4 Annual tune-up

0.104 (gas)

0.400 (oil) 412.4

Heater 231-101 a Source-specific 91.0* Annual tune-up 0.122 (gas) 48.6

Heater 859-1H1 b Source-specific 98.0 - - -

Heater 860- 2H2 Source-specific 69.8 Annual tune-up

0.350 (gas) 

0.400 (oil) 122.3

Heater 860-2H3 Source-specific 174.7 Annual tune-up

0.163 (gas)

0.400 (oil) 306.1

Heater 860-2H4 Source-specific 99.4 Annual tune-up

0.270 (gas)

0.400 (oil) 174.1

Heater 860-2H5 Source-specific 155.0 Annual tune-up

0.163 (gas)

0.400 (oil) 271.6

Heater 860-2H7 Source-specific 59.0 Annual tune-up

0.157 (gas)

0.400 (oil) 103.4

Heater 860-2H8 Presumptive 49.6* - - -

Heater 864-PH1 Source-specific 80.0 Annual tune-up 0.167 (gas) 140.2
37

0.400 (oil)

Heater 864-PH7 Presumptive 45.5* - - -

Heater 864-PH11 Source-specific 74.0 Annual tune-up

0.145 (gas)

0.400 (oil) 129.6

Heater 864-PH12 Source-specific 85.1 Annual tune-up

0.119 (gas)

0.400(oil) 149.1

Heater 865-11H1 a Source-specific 72.2 Annual tune-up

0.113 (gas) 

0.400 (oil) 126.5

Heater 865-11H2 a,c Source-specific 49.9* - - -

Heater 866-12H1 a, c Source-specific 43.0* - - -

Heater 868-8H101 a,c Source-specific 40.0* - - -

Heater 870-H01 b Source-specific 97.0 - - -

Heater 870-H02 b Source-specific 53.0 - - -

Heater 137 F-1 Source-specific 415.0* Annual tune-up

0.230 (gas, oil) 

(30-day rolling 

average) 

418.1

Heater 137 F-2 Source-specific 155.0* Annual tune-up

0.257 (gas) 

0.4 (oil) 271.6

Heater 137 F-3 Source-specific 60.0 Annual tune-up 0.400 (oil) 105.1

Heater 1332 H-1 Presumptive 45.0 - -

Heater 1332 H-2 Source-specific 60.0 Annual tune-up 0.300 (gas) 78.8

Heater 1332 H-3 Presumptive 43.0 - - -

Heater 1332 H-400 Source-specific 186.0* Annual tune-up 0.156 (gas) 127.1

Heater 1332 H-401 Source-specific 233.0 Annual tune-up 0.156 (gas) 159.2

Heater 1332 H-601 Presumptive 48.0 - - -

Heater 1332 H-602 Presumptive 49.0 - - -

Heater 433 H-1 Source-specific 243.0*

ULNB and

annual tune-up

0.060 (gas) 63.9

Heater 1232 B-104 Source-specific 70.0*

ULNB and 

annual tune-up

0.177 (gas) 54.3

Boiler #37 Source-specific 495.0* ULNB 0.330 (gas, oil) 715.5

Boiler #39 Source-specific 495.0* ULNB 0.330 (gas, oil) 715.5

Boiler #40 Source-specific 660.0* ULNB 0.330 (gas, oil) 715.5

* Denotes federally enforceable limits.

a AMS addressed RACT for these 7 heaters in a separate RACT determination submitted as part of the June 27, 

2014 RACT SIP revision. 

b This unit has been installed after the 1-hour RACT determination, and thus there are no RACT requirements 

approved in the SIP.

c Heat input rating for this heater has been revised to exceed 50 MMBTU/hr, and thus the unit is currently subject to 

source-specific RACT.

d Potential NOx emissions based on combustion of oil, the highest emitting fuel allowed at the time.

EPA notes that all units currently burn refinery gas, but were allowed to combust refinery 

fuel oil and/or refinery gas at the time of the 1-hour ozone RACT determination. Per a federally 

enforceable consent decree, EPA and other air permitting agencies required the source to 

eliminate fuel oil burning in the heaters and boilers, except during natural gas curtailments, 
38

losses of supply, and during stack test programs.17 The source phased out entirely the use of 

combusting refinery oil in 2010. 

As summarized in Table 10, only a few heaters and boilers are required under the 1-hour 

ozone RACT determination to operate specific NOx controls, while annual tune-up is performed

on all other units. The SIP approved RACT Permits also specify NOx emissions limits for each 

of these boilers and heaters, and heat input limits in MMBTU/hr for some of the affected units. 

The source is required to monitor fuel input in a daily basis for the boilers subject to heat input 

limits to determine compliance. 

Since the previous RACT determination, a number of heaters and boilers have been modified 

and/or are subject to more stringent federally enforceable NOx requirements, as summarized in 

Table 11 below. EPA notes that eight of these heaters have been modified to allow higher heat 

input rates than those previously approved to meet RACT; however, AMS has also adopted for 

these heaters more stringent NOx emissions limits to offset potential emissions increases and 

impacts to air quality. AMS shows that the revisions to these 8 units result in equivalent or 

additional reductions of NOx emissions, therefore EPA finds that these modifications are 

consistent with section 110(l) of the CAA. All federally enforceable NOx requirements listed 

below are being submitted to meet RACT under the 1997 8-hour ozone NAAQS. Table 11 also 

provides the federally enforceable NOx requirements that apply to the 3 heaters that were

installed after the 1-hour ozone RACT determination.

Table 11. New and Modified Process Heaters and Boilers at PES

Emissions Unit

NOx Requirements Approved After 1-hour Ozone RACT

Heat Input 

Rating 

(MMBTU/hr)

Heat Input 

Rating 

(MMBTU/ 

rolling 365 day 

period)

Control 

Requirement*

NOx Emissions 

Limit* 

(lb/MMBTU) c

Potential 

NOx 

Emissions 

(tpy)

Heater 210-H101 a 192.0 1,681,920 Annual tune-up 0.089 74.8

Heater 210- 

201A/B a b

254.0 2,225,040 ULNB 0.03 33.4

Heater 231- B101 a 104.5 915,420 ULNB 0.03 13.2

Heater 859 1H1 98.0 - ULNB 0.035 8.6

Heater 865-11H1 a 87.3 764,748 ULNB 0.03 11.5

Heater 865-11H2 a b 61.2 562,392 Annual tune-up 0.113 30.3

Heater 866-12H1 a b 61.2 536,112 Annual tune-up 0.113 30.3

Heater 868-8H101 a

b

60.0 525,600 Annual tune-up 0.113 29.7

 

17 Second Amendment to a Consent Decree between EPA, several states, the City of Philadelphia, and Sunoco, Inc. 

(Civil Action No.05-02866).
39

Heater 870-H01 53.0 - ULNB 0.035 14.9

Heater 870-H02 98.0 - ULNB 0.035 8.1

Heater 137 F-3 60.0 - ULNB 0.06 15.8

Heater 1332 H-2 60.0 - ULNB 0.04 10.5

Heater 1332 H-400 186.0* - SCR 0.06 48.9

Heater 1332 H-401 233.0 - SCR 0.06 61.2

Heater 433 H-1

a 260.0* -

ULNB and 

annual tune-up

0.035 39.9

Boiler #37 495.0* -ULNB and 

FGR 0.04 86.7

Boiler #39 495.0* -ULNB and 

FGR 0.04 86.7

Boiler #40 660.0* -ULNB and 

FGR 0.04 115.6

* Denotes federally enforceable limits.

a The hourly heat input rating for this heater has been increased; however a more stringent NOx emissions limit has 

been adopted to avoid any emissions increases.

b Since the permitted hourly heat input rating of this heater has been revised to exceed 50 MMBTU/hr, the heater is 

now subject to source-specific RACT.

c NOx emissions limits are for the combustion of refinery gas, as the source is no longer allowed to burn refinery 

fuel oil. 

AMS evaluated the following additional NOx controls for all boilers and heaters subject to 

source-specific RACT under 25 Pa Code sections 129.91-92: ULNB, SCR, SNCR, ULNB and 

SCR, LNB and SCR, and LNB and FGR. Considering the emissions reductions already 

achieved by existing controls, AMS determined that these additional controls are not technically 

and/or economically reasonable for each of the boilers and heaters, and thus do not represent 

RACT under the 1997 8-hour ozone NAAQS. 

To ensure that NOx RACT represents the most stringent level of control for the combustion 

units, AMS is proposing to adopt as RACT the most stringent NOx limits and controls that apply 

to certain heaters and boilers at this time, as provided in Table 11. Also, AMS is removing from 

the SIP the NOx limits for burning refinery oil that were approved as RACT under the 1-hour 

ozone NAAQS for all units that were allowed to burn under the previous determination. These 

modifications altogether result in equivalent or additional potential NOx emissions reductions, as 

summarized in Table 12 below. AMS is also removing from the SIP any source-specific RACT 

requirements that were approved for those boilers and heaters that have been permanently shut 

down. 
40

Table 12. Summary of Proposed RACT Revisions for Process Heaters and Boilers at PES 

Emissions Unit

Proposed Revisions to RACT Requirements Potential NOx 

Emissions 

Reductions 

(tpy) Heat Input a

Rating 

(MMBTU/hr)

Control 

Requirement

NOx 

Emissions 

Limit* 

(lb/MMBTU)

Potential NOx 

Emissions 

(tpy)

Heater 210-H101 192.0 Annual tune-up 0.089 74.8 245.8

Heater 210-H201 

A/B 254.0 ULNB 0.030 33.4 390.6

Heater 210-13H1 235.4 Annual tune-up 0.104 107.2 305.2

Heater 231-101 104.5 ULNB 0.030 13.7 34.9

Heater 859-1H1 98.0 ULNB 0.020 8.6 -

Heater 860- 2H2 69.8 Annual tune-up 0.350 107.0 15.3

Heater 860-2H3 174.7 Annual tune-up 0.163 124.7 181.3

Heater 860-2H4 99.4 Annual tune-up 0.270 117.6 56.6

Heater 860-2H5 155.0 Annual tune-up 0.163 110.7 160.9

Heater 860-2H7 59.0 Annual tune-up 0.157 40.6 62.8

Heater 864-PH1 80.0 Annual tune-up 0.167 58.5 81.6

Heater 864-PH11 74.0 Annual tune-up 0.145 47.0 82.7

Heater 864-PH12 85.1 Annual tune-up 0.119 44.4 104.7

Heater 865-11H1 87.3 ULNB 0.030 11.5 115.0

Heater 865-11H2 61.2 Annual tune-up 0.113 30.3 -

Heater 866-12H1 61.2 Annual tune-up 0.113 30.3 -

Heater 868-8H101 60.0 Annual tune-up 0.113 29.7 -

Heater 870-H01 97.0 ULNB 0.035 14.9 -

Heater 870-H02 53.0 ULNB 0.035 8.1 -

Heater 137 F-1 415.0 Annual tune-up 0.230 418.1 -

Heater 137 F-2 155.0 Annual tune-up 0.257 174.5 97.1

Heater 137 F-3 60.0 ULNB 0.060 15.8 89.4

Heater 1332 H-2 60.0 ULNB 0.040 10.5 68.3

Heater 1332 H400 186.0 SCR 0.060 48.9 78.2

Heater 1332 H401 233.0 SCR 0.060 61.2 98.0

Heater 433 H-1 260.0 ULNB and 

annual tune-up

0.035 39.9 24.0

Heater 1232 B104 70.0 ULNB and 

annual tune-up

0.177 54.3 0.0

Boiler #37 495.0 ULNB and 

FGR 0.040 86.7 628.7

Boiler #39 495.0 ULNB and 

FGR 0.040 86.7 628.7
41

Boiler #40 660.0 ULNB and 

FGR 0.040 115.6 838.3

* Denotes federally enforceable limits.

a Potential NOx reductions expected when compared to the implementation of 1-hour ozone RACT requirements, as 

provided in Table 10.

AMS determined that there are no reasonably available VOC controls for the heaters and 

boilers at PES. Additionally, AMS indicates that most of the combustion units at the facility 

have potential VOC emissions below 5 tpy.

PES operates two FCCUs, unit 868 and unit 1232, that are significant sources of NOx and 

produce some VOC emissions. FCCU unit 868 is a full-burning unit and is subject to sourcespecific RACT under the previous determination. The SIP approved RACT Permits specify for

FCCU unit 868 a NOx emissions limit of 569 tons per rolling 12-month period and requires the 

source to follow good combustion practices and use a carbon monoxide (CO) promoter in the 

regenerator. After the 1-hour RACT determination, FCCU unit 868 has been subject to federally 

enforceable limits to process 50,000 barrels in a single day and 47,500 barrels per day on a 

rolling 365-day average, and a NOx limit of 50 parts per million, volumetric on dry basis 

(ppmvd) at 0% oxygen. See Plan Approval No. 00184 dated March 22, 2002 and the Second 

Amendment of Civil Action No.05-02866 Consent Decree. 

AMS evaluated NOx controls as RACT for FCCU unit 868, including SCR, SNCR and a low 

temperature oxidation device (LoTOx), and determined that none of these controls are 

economically reasonable. AMS determines that the NOx RACT control requirements approved 

for the FCCU 868 under the previous determination continue to represent RACT under the 1997 

8-hour ozone NAAQS. Further, AMS is adopting as NOx RACT for the FCCU 868 the 

currently applicable NOx limit of 50 ppmvd at 0% oxygen and an additional NOx limit of 130.2 

tons per rolling 365-day period that represents the highest allowed emissions based on the most 

stringent limit of 47,500 barrels per day on a rolling 365-day. There are no feasible controls of 

VOC for full-burn FCCUs.

FCCU unit 1232 is not subject to any requirements under the previous RACT determination. 

FCCU unit 1232 is a partial-burn unit, and is currently required to operate a SCR for controlling 

NOx emissions to comply with a federally enforceable NOx emissions rate of 40 ppmdv at 0% 

oxygen on a 7-day rolling average. At this time, the unit is also restricted to operate up to 

100,000 barrels in a single day and 90,000 barrels per day on a rolling 365 day average period. 

AMS finds that the existing SCR and corresponding NOx limit represent the most stringent level 

of control, and that they should satisfy NOx RACT for this unit under the 1997 8-hour ozone 

NAAQS. Thus, AMS is adopting as NOx RACT for FCCU unit 1232 a requirement to operate 

the SCR and the NOx emissions limit of 40 ppmdv at 0% oxygen on a 7-day rolling average, as 

well as an additional limit of 208.29 tons per rolling 365-day period that represents the highest 
42

allowed emissions based on the most stringent limit of 490,000 barrels per day on a rolling 365 

day average period. 

FCCU unit 1232 is required to operate a boiler with the purpose of reducing the significant 

CO emissions produced (CO boiler), which results in some reductions of VOC emissions. There 

are no other technically feasible VOC controls for partial-burning FCCUs than the CO boiler. 

Therefore, AMS determines the CO boiler to represent VOC RACT for FCCU 1232. 

Marine loading operations at PES occur in two different areas of the facility, at Girard Point 

and at Point Breeze. The Girard Point Barge Loading Process handles liquid organic materials 

with a RVP of 4 psi or greater and is required to operate a thermal oxidizer to achieve a 

minimum of 98% VOC capture and destruction efficiency or an outlet VOC concentration of 20 

ppmv, consistent with 25 Pa Code section 129.81. The Point Breeze Marine Barge Loading 

Process currently handles liquid organic materials with a RVP of less than 4 psia. 

As noted in the technical memorandum, AMS determined as 1-hour ozone RACT for marine 

vessel loading of materials with a RVP of 4 psi or greater to be those requirements specified in 

25 Pa Code section 129.81. However, AMS is no longer relying on these provisions to meet 

RACT under the 1997 8-hour ozone NAAQS. AMS notes that the Point Breeze Marine Barge 

Loading Process did handle liquid organic materials with a RVP of 4 psi or greater at the time of 

the 1-hour ozone RACT determination, and was required then to operate a marine vapor 

collection and control system (MVCCS) to comply with 25 Pa Code section 129.81. Since the 

barge loading of such organics no longer occurs at Point Breeze, the control requirements in 25 

Pa Code section 129.81 are no longer applicable, and the MVCCS has been permanently 

removed. 

Pursuant to section 183(f)(1) of the CAA, EPA’s Subpart Y rule requires large marine 

loading terminals which load at least 200 million barrels per year of crude oil or 10 million 

barrels per year of gasoline, to comply with RACT standards for reducing VOC emissions. 

Because the maximum throughput of marine loading process at Girard Point has never exceeded 

the applicable thresholds under Subpart Y, this process is not subject to EPA’s RACT standards. 

Additionally, Subpart Y is not applicable to the Point Breeze marine loading process, because

gasoline products are no longer loaded. Consequently, both loading operations are currently

subject to source-specific RACT under 25 Pa code section 129.91-92 for the 1997 8-hour ozone 

NAAQS. 

AMS has evaluated all additional VOC controls for the Girard Point Barge Loading Process, 

including but not limited to thermal incinerator, flare, carbon adsorption, and condenser.

Considering the emissions reductions already achieved by the existing control (thermal oxidizer), 

AMS determined that these additional controls are not technically nor economically reasonable, 
43

and thus do not represent RACT under the 1997 8-hour ozone NAAQS. AMS proposes to adopt 

into the SIP as source-specific RACT for the Girard Point Barge Loading Process the VOC 

emission limits and control requirement currently in place.

AMS has evaluated all additional VOC controls for the Point Breeze Barge Loading Process, 

including but not limited to thermal incinerator, flare, carbon adsorption, and condenser. AMS 

determined that these controls are not economically reasonable, and thus do not represent RACT

under the 1997 8-hour ozone NAAQS for the Point Breeze Marine Barge Loading Process. 

AMS proposes to adopt into the SIP as source-specific RACT a VOC emissions limit of 25.99 

tons per rolling 12-month period. 

The new and revised source-specific RACT requirements for PES have been incorporated in 

the revised RACT Permits PA-51-1501 and 51-1517, effective in February 9, 2016, which was 

submitted for approval into the SIP. EPA notes that a revised RACT permit for PES was also 

submitted as part of the June 27, 2014 SIP revision, however this version of the permit has being 

superseded by the latest revision of the RACT permit (effective in February 9, 2017) submitted 

in the March 26, 2016 SIP revision. EPA finds that the RACT determinations provided by AMS 

is reasonable and appropriately considered technically and economically feasible controls while 

setting lowest achievable limits and that the source-specific RACT controls currently approve in 

the SIP for the remaining sources adequately meet RACT under the 1997 8-hour ozone NAAQS 

for PES. EPA also finds that the proposed SIP revisions to meet RACT will result in equivalent 

or additional reductions of NOx and/or VOC emissions and thus should not interfere with any 

applicable requirement concerning attainment or reasonable further progress with the NAAQS or 

interfere with other applicable CAA requirement.

10. Philadelphia Gas Works (PGW)- Richmond Plant (PLID- 04922)

Philadelphia Gas Works- Richmond Plant (PGW) is a natural gas utility at 3100 East 

Venango Street, Philadelphia, Pennsylvania. The facility is a major source of NOx and is subject 

to a 1-hour ozone RACT determination, as approved in RACT Permit PA-51-4922, effective on 

July 26, 1999 and approved into the SIP. See 66 FR 54947 (October 31, 2001). The facility 

contains the following NOx emissions units: Six liquefied natural gas (LNG) vaporizer heaters 

with heat capacities between 94.1 and 105.0 MMBTU/hr, five boiler/heaters with heat capacities 

of 11 MMBTU/hr or less, four simple cycle combustion turbines with heat capacity of 13.7 

MMBTU/hr or less, two 170 horse power (HP) emergency generators, and three 295 HP engines 

for fire pumps. 

The 1-hour RACT determination includes source-specific requirements for the 6 LNG 

vaporizer heaters and four Clark engines. All other remaining emissions units at the source are 

subject to presumptive RACT requirements of 25 Pa Code section 129.93. The four Clark 

engines are no longer operating. Therefore, AMS is requesting to remove from the SIP the 

previously approved RACT requirements for the four engines at PGW. Since these emissions 
44

units have been shutdown, EPA does not expect any effects on air quality impacts as a result of 

this revision. Thus, EPA finds that the proposed revision should not interfere with any 

applicable requirement concerning attainment or reasonable further progress with the NAAQS or 

interfere with other applicable CAA requirement.

The six LNG vaporizer heaters are subject to the 5% annual capacity limit, the presumptive 

RACT requirement specified in 25 Pa Code section 129.93(c)(5). To ensure compliance with the 

annual capacity limit, the source accepted a limit for combined annual natural gas usage of 257 

million cubic feet per year (MMcf/yr), which was approved into the 1-hour ozone source-specific 

RACT determination. This is the only source-specific requirement currently applicable from the 

previous RACT determination. AMS determines this requirement for the six LNG heaters to 

continue to meet RACT under the 1997 8-hour ozone NAAQS. 

The revised source-specific RACT requirements for PGW have been incorporated in the 

revised RACT Permit PA-51-4922, effective in January 9, 2015, which was submitted for 

approval into the SIP. The revised RACT Permit intends to replace the previous version of this 

permit dated July 7, 1999 which was approved in the SIP. 

EPA finds that the RACT determinations provided by AMS is reasonable and appropriately 

considered technically and economically feasible controls while setting lowest achievable limits

and that the source-specific RACT controls currently approve in the SIP for the remaining 

sources adequately meet RACT under the 1997 8-hour ozone NAAQS for PGW. 

11. Plain Products Terminals, LLC (formerly, Maritank Philadelphia, Inc. and Exxon 

Company, USA) (PLID- 05013)

Plain Products Terminals, LLC (Plain Products) is a bulk liquid storage and distribution 

facility located at 3400 South 67th Street, Philadelphia, Pennsylvania, and is a major source of 

VOC. Plain Products has two terminals, North Terminal and South Terminal, that were formerly 

two separate but adjacent facilities, Maritank Philadelphia, Inc. (Maritank) (PLID- 05013) and 

Exxon Company, USA (Exxon) (PLID- 05008). Since the terminals are adjacent and finally 

operated by a common owner, they were determined a single source for permitting and RACT 

purposes. The source’s VOC emissions units include 36 petroleum/organic products storage 

tanks, truck loading operations, marine loading operations, loading at two recovery tanks, 

fugitive emissions from pumps, valves, and flanges, tank cleaning and repair, and lubricity 

additive systems. There are other NOx emissions units in operation: Two oil fired boilers with 

rating of 20 and 4.74 MMBTU/hr heat input ratings and six small space heating units (0.25 

MMBTU/hr each).

Plain Products is subject to two separate 1-hour ozone RACT determinations for Maritank

and Exxon, as specified in RACT Permits PA-51-5013 (effective on December 28, 1995) and 
45

PA-51-5008 (effective May 29, 1995), respectively, both which were approved by EPA into SIP. 

See 66 FR 54947 and 66 FR 54936 (October 31, 2001). The RACT Permit for Maritank 

(currently Plain Products’ North Terminal) specifies source-specific requirements for marine 

loading operations, loading at five recovery tanks, two oil fired boilers of 30 MMBTU/hr and 7 

MMBTU/hr (Boilers A and B, respectively), and fugitive emissions. The two boilers and three 

of the five recovery tanks have shut down. The 1-hour ozone RACT determination for Exxon 

(currently Plain Products’ South Terminal) contains source-specific requirements for fugitive 

emissions. 

The boilers and space heaters are subject to presumptive RACT requirements in 25 Pa Code 

section 129.93. The 20 MMBTU/hr boiler is controlled by performing annual combustion tuneup, pursuant to 25 PA Code 129.93(b)(2). The smaller boiler and the heaters are subject to 25 Pa 

Code 129.93(c)(5) to be installed, operated, and maintained in accordance with the 

manufacturer’s specifications. The source has 13 storage tanks with capacities greater than 

40,000 gallons, each storing petroleum organic products (i.e., volatile organic compounds) with a 

vapor pressure of less than 11 psia under actual storage conditions. The tanks are subject to the 

CTG requirements of 25 Pa Code 129.56(a)(1). 

Plain Products operates a number of emissions units whose VOC emissions are insignificant, 

and for which RACT has been determined to be no controls. The remaining 23 storage tanks 

store petroleum organic compounds of lower volatility (with vapor pressures of less than 1.5 

psia) and have each potential VOC emissions of less than 1.0 tons per year. Truck loading 

operations in the North and South Terminals have been limited to certain loading capacity of 

distillate oil per rolling 12-month period, resulting in potential VOC emissions of 1.1 and 2.1 

tons per year, respectively. See Title V/State Operating Permit V10-025. Truck loading at the 

recovery tanks occurs a few times per year at the two recovery tanks with VOC potential 

emissions of 1.2 pounds per year (lb/yr) of VOC. The lubricity additive systems at the North and 

South Terminals each have VOC potential emissions of less than 1.0 tpy of VOC. Based on its 

permitting and engineering knowledge, AMS determined that installing any control technology 

on these de minimis sources is both technically and economically unreasonable.

At the time of the 1-hour RACT determination, fugitive emissions from pumps, valves, and 

flanges were identified as VOC sources in both Maritank and Exxon. Per the SIP approved 

RACT Permits, the source is required to implement quarterly leak detection and repair (LDAR) 

program for all pumps, valves, and flanges in VOC service. At this time, fugitive emissions of 

Plain Products are also subject to AMR V section XIII, which prohibits fugitive emissions of 

VOC in the concentration of 10,000 ppmv or greater, as measured by Pennsylvania’s approved 

test methods. Because the requirements of AMR V section XIII apply at all times and establish 

specific leak threshold, AMS finds these requirements to be more stringent than the sourcespecific RACT requirements. AMS has determined that the requirements in AMR V section 

XIII will supersede the source-specific LDAR requirements specified in the SIP. Consequently, 
46

AMS proposes to replace the existing source-specific requirements in the SIP with a condition 

requiring compliance with AMR V section XIII.

The 1-hour ozone RACT determination identified five recovery tanks which stored material 

recovered from the barge cleaning plant. At the time, the tanks were emptied from the recovered 

barge cleaning material once the maximum capacity was reached, by loading the material into 

trucks. Per the Maritank RACT Permit, the source is required to connect the tanks to a vapor 

recovery system to recover any vapors from organic materials being loaded into trucks. Since 

the 1-hour RACT plan approval was issued, the barge cleaning plant was shut down and three of 

the five recovery tanks were removed. Currently, the remaining two recovery tanks store a 

recovered mixture of number 2 and number 6 oil (both with a RVP well below 4 psi) and water 

from a groundwater remediation process. Truck loading from the remaining recovery tanks 

continue to occur. Once the two recovery tanks are utilized to maximum capacity, the tanks are 

emptied by loading the materials into trucks, which now usually occurs only two or three times 

per year. 

AMS explains that the potential VOC emissions from loading the recovered barge cleaning 

material from the recovery tanks into trucks prior the operation of the required vapor recovery 

control (i.e., uncontrolled) was 2 tpy. VOC emissions were expected to be reduced to 400 lb/yr

for the loading operations, assuming the expected overall control efficiency of 90% for the 

required vapor recovery system. AMS estimated that based on the current use of the tanks, the 

uncontrolled potential emissions from the truck loading at the recovery tanks is 1.2 lb/yr of 

VOC. Due to the current level of uncontrolled potential emissions, AMS believes that the air 

quality benefit from the operation of the vapor recovery or any other control would be 

insignificant, thus making operation of controls cost ineffective and unreasonable. Therefore, 

AMS concludes that there is no need to continue to require vapor recovery unit or any other 

control for this source. AMS requests to remove the control requirement from the SIP for the 

truck loading at the two remaining recovery tanks given the changes in operation and subsequent 

ineffectiveness of controls. EPA does not expect any emissions increases to result from this 

particular revision.

Marine loading was referred to as the dock transfer station in the SIP approved RACT permit 

for Maritank. The Maritank RACT Permit required the source to cease by September 28, 1994

the loading at the dock transfer station of gasoline, or any organic liquid with RVP of 4 psi or 

greater, by Pennsylvania’s approved definitions. Because Plain Product is not allowed to load 

gasoline liquid organics (with RVP of 4.0 psi or greater), the source is not subject to the RACT 

requirements of Subpart Y. Consequently, the loading operations continue to be subject to 

source-specific RACT under 25 Pa code section 129.91-92.

AMS evaluated available controls for the Plain Products’s marine loading operations, 
47

including thermal oxidation, carbon adsorption, bioreactor, wet scrubbers, and condensation via 

refrigeration. AMS determined that these additional controls are not technically and/or 

economically reasonable for the marine loading operations and thus do not represent RACT. 

AMS estimated VOC potential emissions from the marine loading operations of 6.6 tpy, based 

on number 2 fuel oil, the highest VOC emitting material that is loaded at the source. AMS has 

adopted as RACT an additional VOC emissions limit of 6 tpy for the source’s marine loading 

operations, in addition to the existing 1-hour ozone RACT requirements to represent VOC 

RACT under the 1997 8-hour ozone standard for the marine vessel loading operations in Plain

Products. 

All new and revised source-specific RACT requirements for Plain Products have been 

incorporated in the revised RACT Permit PA-51-5013, effective in February 9, 2016, which was 

submitted for approval into the SIP to replace the previous version of this permit dated 

December 28, 1995. AMS is revising the SIP to remove the RACT Permit PA-PA-51-5008 for 

Exxon (effective May 29, 1995), as all applicable source-specific requirements have been 

subsumed into the outstanding RACT Permit PA-51-5013.

EPA finds that the RACT determination provided by AMS is reasonable and appropriately 

considered technically and economically feasible controls while setting lowest achievable limits

and that the proposed source-specific RACT controls adequately meet RACT under the 1997 8-

hour ozone NAAQS for Plain Products. EPA also finds that the proposed SIP revisions to meet 

RACT will not result in additional VOC emissions and thus should not interfere with any 

applicable requirement concerning attainment or reasonable further progress with the NAAQS or 

interfere with other applicable CAA requirement.

12. Temple- Health Sciences Campus (PLID- 08906)

Temple University is an educational institution providing heat, power, and hot water to 

numerous institutional buildings. The Health Sciences Campus (Temple- Health), located in 

3401 North Broad Street, Philadelphia, Pennsylvania, is a major source of NOx. The facility

operates the following NOx emission units: Three 76.4 MMBTU/hr boilers (Boilers #1, #2, and 

#3), two boilers with heat input capacities of less than 2 MMBTU/hr, and 20 emergency 

generators and fire pumps. The source is subject to a 1-hour ozone RACT determination, as 

specified in RACT Permit PA-51-8906, effective on May 27, 1995 and approved into the SIP on 

December 15, 2000. 65 FR 78418. EPA’s December 13, 2013 conditional approval required 

AMS to submit a source-specific RACT determination for Temple- Health, as AMS had 

indicated the source has adopted or will adopt additional controls after the 1-hour RACT 

determination that should represent RACT under the 1997 8-hour ozone NAAQS.

The two smaller boilers and 20 emergency generators and fire pumps are subject to the 

presumptive RACT requirements of 25 Pa Code section 129.93. Only Boilers #1, #2, and #3 are 
48

subject to source-specific RACT at this time. The 1-hour RACT determination includes sourcespecific requirements for Boilers #1, #2 and #3 and a medical waste incinerator, the latter has 

since shutdown. The three boilers share a common stack and are allowed to combust both 

natural gas and number 6 fuel oil. The following NOx RACT requirements are approved for the 

boilers: Boiler #2 to utilize FGR and low excess air combustion and Boilers #1 and #3 to operate 

a fuel flow governing devices limiting the fuel heat input to 50 MMBTU/hr each. The heat input 

limit on Boilers #1 and #3 allowed each boiler to be subject to the presumptive requirements in 

25 Pa Code section 129.93(b)(2) instead of source-specific controls, which specifies RACT as 

the performance of an annual adjustment or tune-up on the combustion process. 

After the 1-hour RACT plan approval was issued, Temple- Health discovered that installing 

the FGR was technically infeasible for Boiler #2. Installation of the FGR was not possible due to 

a number of technical difficulties that were encountered by the source when attempting to 

engineer its application in Boiler #2, as further discussed in the AMS technical memorandum. 

As a result, Temple- Health proposed to modify the RACT requirements to replace the approved

control and heat input restrictions with burner modifications for each of the three boilers. 

Additionally, the source proposed the following NOx emissions limits for each boiler: 0.067 

lbs/MMBTU while burning natural gas and for combusting number 6 fuel oil either 0.25 

lb/MMBTU for fuel oil with nitrogen content (N) of 0.25 or less or a variable NOx emissions 

rate for fuel oil with N greater than 0.25 lb/MMBTU based on a correlation between N and the 

fuel heating value of the fuel oil (X) (in MMBTU per gallons (MMBTU/gal)), specifically 0.25 + 

(0.073059 / X) * (N-0.25).

18

 The source also proposed the following restrictions for the three 

boilers: combined NOx emissions limit of 56.5 lb/hr and combined heat input limit of 673,894 

MMBTU per rolling 12-month period.19 

The number 6 fuel oil emissions limits proposed by the source were based on the fact that 

NOx emissions from burning the fuel would be affected by variations in nitrogen content. To 

improve enforceability of the RACT requirements, AMS is proposing to revise the two-prong 

NOx emissions limit for number 6 oil combustion to an absolute value NOx emissions limit of 

0.40 lbs/MMBTU. The revised limits were determined by AMS based on historical fuel 

shipment data from the source indicating that 0.57 is the highest nitrogen content received and 

the assumed correlation for NOx emissions from number 6 fuel oil combustion. AMS is 

proposing the combined NOx emissions limit and the combined heat input limit to adequately 

meet RACT at this time.

 

18 In estimating the NOx emissions limit for number 6 fuel oil with N greater than 0.25, the source has often relied 

on a standard number oil heating value of 0.15 MMBTU/gal. 

19 The source requested revisions to the RACT requirements to be approved into a permit. AMS issued Plan 

Approval 05198 dated April 16, 2008. However, such permit conditions were not submitted to EPA as RACT for 

approval into the SIP. EPA has not treated such modification as RACT until this time. 
49

AMS has shown that the revised limits and controls will achieve additional reductions of 

NOx emissions than those expected by the implementation of 1-hour RACT, as specified in the 

SIP approved RACT Permit. Table 13 below summarizes the NOx emissions resulting from the 

approved RACT requirements and the proposed revisions to RACT, based on combustion of 

number 6 fuel oil, the highest emitting fuel. The revisions will result in reductions of hourly 

NOx emissions of 25.6 lb/hr, based on the combined hourly NOx limit of 56.3 lb/hr, and 

reductions of annual NOx emissions of 223.9 tons per year, based on the combined annual heat 

input limit of 673,894 MMBTU per rolling 12-month period. This shows that the proposed 

revisions to the NOx RACT will result in additional benefits to air quality, and thus will not 

interfere with the attainment of the ozone NAAQS or any other NAAQS, thus addressing 

requirements in CAA section 110(l) for this revised RACT.

Table 13. Summary of Proposed RACT Revisions for Boilers #1, #2, and #3 at TempleHealth

Approved RACT Requirements Proposed Revisions to RACT Requirements

Heat Input 

(MMBTU/

hr)

NOx 

emissions 

rate (lb/ 

MMBTU) a

Potential 

NOx 

Emissions 

(lb/hr)

Potential

NOx 

Emissions 

(tpy)

Heat Input 

(MMBTU/

hr)

NOx 

emissions 

rate (lb/ 

MMBTU)

Potential 

NOx 

Emissions 

(lb/hr)

Potential 

NOx 

Emissions 

(tpy)

Boiler #1 50* 0.53 26.68 116.86 76.4 0.40* 30.56 133.85

Boiler #2 76.4 0.37 28.54 125.00 76.4 0.40* 30.56 133.85

Boiler #3 50* 0.53 26.68 116.86 76.4 0.40* 30.56 133.85

Combined - - 81.90 358.72 56.3* 134.78 b

* Denotes federally enforceable limits.

a NOx emissions rates provided are based on EPA’s AP-42 methodology, the historical highest nitrogen content 

observed (0.57) and the standard heating value for number 6 fuel oil (0.15 MMBTU/hr). For Boiler #2 particularly, 

the emissions rate also assumes a 30% NOx reduction.

b

 Combined annual NOx emissions are based on the combined annual limit for heat input capacity of 673,894 

MMBTU per 12-month rolling basis.

Further, AMS’s technical memorandum indicates that Boilers #1, #2, and #3 have almost 

exclusively burned natural gas in recent years, with number 6 oil combusted on occasions when 

natural gas is interrupted. AMS has determined RACT for the 1997 8-hour ozone standard for 

Boilers #1, #2, and #3 to be the requirement to burn natural gas as primary fuel during ozone 

season (April 1 through October 31) of any given year, except when natural gas supply is 

interrupted or curtailed, at which time burning of number 6 fuel oil is allowed. AMS explains 

that the number 6 fuel oil restriction (i.e., to combust gas as primary fuel) is unreasonable during 

colder months outside the ozone season for any given year due to frequent price increases of 

natural gas as a result of higher demand of the natural gas fuel during that time; and also since

significantly lower NOx emissions are generally emitted in Philadelphia during the colder 

months, resulting in lower impacts to attainment of the NAAQS.
50

AMS evaluated additional controls for RACT for each of the boilers, including SCR, SNCR, 

ULNB, switching from number 6 oil fuel to number 2 fuel oil, and completely eliminating 

number 6 fuel oil burning (i.e., 100% natural gas combustion). As explained in the technical 

memorandum, Temple-Health is a certified healthcare facility and must have a backup fuel 

available at all times in order to prevent loss of use of life-critical equipment should the primary 

fuel supply be interrupted. Thus, switching to natural gas combustion alone is not a reasonable 

nor feasible option as determined by AMS. EPA finds this determination reasonable based on 

the critical operational function of Temple-Health. Additionally, AMS has shown that switching 

to number 2 fuel oil is not economically reasonable based on the expected NOx emissions 

reductions from the fuel switch. AMS determined that no additional controls were technically 

and/or economically reasonable. Thus, AMS proposed as RACT under the 1997 8-hour ozone 

RACT the NOx emissions limits and controls proposed by the facility, with the exception of 

revising the proposed NOx emissions limit for number 6 fuel oil burning to 0.40 lb/MMBTU and 

adding a restriction to primarily burn natural gas during ozone season of any year, unless there is 

gas curtailment or interruption during the allocated time frame, in which time number 6 fuel oil 

is allowed. AMS determined these requirements to represent NOx RACT under the 1997 8-hour 

ozone NAAQS for Temple- Health’s Boilers #1, #2 and #3 and, thus, is requesting to update the 

SIP approved RACT determination to incorporate them accordingly. 

The revised source-specific RACT requirements for Temple- Health have been incorporated 

in the revised RACT Permit PA-51-8906, effective on January 9, 2015, and submitted for 

approval into the SIP. EPA finds that the RACT determination provided by AMS is reasonable

and appropriately considered technically and economically feasible controls while setting lowest 

achievable limits and that the proposed source-specific RACT controls adequately meet RACT 

under the 1997 8-hour ozone NAAQS for Temple-Health. EPA also finds that the proposed 

revisions to meet RACT will result in equivalent or additional reductions of NOx emissions and 

thus should not interfere with any applicable requirement concerning attainment or reasonable 

further progress with the NAAQS or interfere with other applicable CAA requirement.

 

13. Veolia Energy- Edison (formerly TRIGEN- Edison Station) (PLID- 04902)

Veolia Energy Philadelphia- Edison Station (Veolia- Edison) is as steam generating facility 

located at 908 Samson Street, Philadelphia, Pennsylvania. The facility is a major source of NOx 

and contains the following NOx emissions units: Two boilers rated 283 MMBTU/hr (Boilers #1 

and #2) and two boilers rated 335 MMBTU/hr (Boilers #3 and #4); all front-fired and burning 

number 6 oil as the primary fuel and number 2 oil as the ignition fuel. 

EPA’s December 13, 2013 conditional approval required AMS to submit a source-specific 

RACT determination for this source, as AMS had indicated it was relying on the NOx SIP Call 

for RACT compliance. AMS has clarified that this source was previously evaluated under the 1-

hour ozone standard and has been subject to a source-specific RACT determination under 25 Pa 
51

Code sections 129.91-92. The 1-hour ozone RACT determination for Veolia- Edison is specified 

in RACT Permit PA-51-4902 under the facility’s former name TRIGEN- Edison Station, 

effective on May 29, 1995 and approved in the SIP on December 15, 2000. 65 FR 78418. EPA 

confirms that the 1-hour RACT determination for Veolia-Edison does not rely on the 

presumption that compliance with the NOx SIP Call constituted RACT for any of its emissions 

units. AMS has re-evaluated RACT for each emissions unit to ensure compliance with 25 Pa 

Code sections 129.91-92. EPA also notes that the conditional approval identified this source as 

an EGU, however, AMS has clarified that Veolia- Edison is dedicated solely to steam generation 

and not electricity generation.

As part of the 1-hour ozone RACT determination, the following NOx RACT requirements 

apply to the four boilers: Each boiler is subject to a NOx limit of 0.50 lb/MMBTU and all 

boilers have a combined number 6 oil limit of 65,526,316 gallons and a combined NOx 

emissions limit of 2,195 tons, both limits per 12-month rolling period. Since the 1-hour RACT 

determination, each boiler is subject to a federally enforceable restriction of an annual 30% 

capacity factor based on hourly maximum heat input, which significantly has reduced operations 

of each unit and the source’s potential NOx emissions. See Title V Permit V11-021 issued May 

13, 2013 and AMS Plan Approval 06167A, dated March 11, 2013.

AMS evaluated the following controls for the boilers: ULNB, SCR, SNCR, FGR, ULNB 

with natural gas, and other combustion modifications. AMS determined that these controls are 

not technically nor economically reasonable for the boilers and thus do not represent RACT. 

However, to reflect lowest achievable emissions limits for RACT, AMS is proposing to reduce 

the NOx emissions limits for Boilers #1 and #2 from 0.50 to 0.39 lb/MMBTU and to add a NOx 

limit of 145.02 tons per 12-month rolling period, based on the 30% capacity factor. EPA 

anticipates that these revisions should result in reductions of potential NOx emissions of 475 tons 

in any given year, as provided in Table 14 below.

Table 14. Summary of Proposed RACT Revisions for Boilers #1 and #2 at Veolia- Edison

(Per Boiler)

Heat Input 

(MMBTU/

hr)

Approved RACT Requirements Proposed Revisions to RACT 

Requirements

NOx 

emissions 

rate (lb/ 

MMBTU)

Potential

NOx 

Emissions 

(lb/hr)

Potential 

NOx 

Emissions 

(tpy)

NOx 

emissions 

rate (lb/ 

MMBTU)

Potential 

NOx 

Emissions 

(lb/hr)

Potential 

NOx 

Emissions 

(tpy)

283 0.50* 141.5 619.77 0.39* 110.37 145.02*

* Denotes federally enforceable limits.

AMS is also proposing to reduce the NOx emissions limits for Boilers #3 and #4 from 0.50 to 

0.38 lb/MMBTU and to add a NOx limit of 167.28 tons per 12-month rolling period, based on 

the 30% capacity factor. EPA anticipates that these revisions should result in reductions of 
52

potential NOx emissions of 566 tons in any given year, as provided in Table 15 below.

Table 15. Summary of Proposed RACT Revisions for Boilers #3 and #4 at Veolia- Edison

(Per Boiler)

Approved RACT Requirements Proposed Revisions to RACT Requirements

Heat Input 

(MMBTU/

hr)

NOx 

emissions 

rate (lb/ 

MMBTU)

Potential 

NOx 

Emissions 

(lb/hr)

Potential 

NOx 

Emissions 

(tpy)

Heat Input 

(MMBTU/

hr)

NOx 

emissions 

rate (lb/ 

MMBTU)

Potential 

NOx 

Emissions 

(lb/hr)

Potential 

NOx 

Emissions 

(tpy)

335 0.50* 167.5 733.65 335 0.38* 127.3 167.28*

* Denotes federally enforceable limits.

By revising the existing RACT requirements and taking additional NOx emissions limits on 

the boilers, the combined NOx emissions from Boilers #1, #2, #3, and #4 have been reduced to 

624.6 tons per year, which is lower than the combined NOx emission limit approved as RACT. 

AMS also indicated that the potential NOx emissions achieved by the original number 6 fuel 

usage limit is 1,539.8 tons in any given year (based on 47 pounds of NOx produced when 

burning a thousand gallons of the fuel), thus the new restrictions will result in lower NOx 

emissions than this limit. Since the combined NOx emissions limit and the combined fuel usage 

limit do no longer represent the lowest level of NOx control, AMS is proposing to remove both 

conditions. 

AMS determined the revised NOx requirements altogether represent NOx RACT under the 

1997 8-hour ozone NAAQS for Veolia-Edison’s Boilers #1, #2, #3 and #4, and, thus, is 

requesting to update the SIP approved RACT determination to incorporate them accordingly. 

The revised source-specific RACT requirements for Veolia- Edison have been incorporated 

in the revised RACT Permit PA-51-4902, effective on January 9, 2015, which was submitted for 

approval into the SIP. EPA finds that the RACT determination provided by AMS is reasonable 

and appropriately considered technically and economically feasible controls while setting lowest 

achievable limits and that the proposed source-specific RACT controls adequately meet RACT 

under the 1997 8-hour ozone NAAQS for Veolia- Edison. EPA also finds that the proposed 

revisions to meet RACT will result in additional reductions of NOx emissions and thus should 

not interfere with any applicable requirement concerning attainment or reasonable further 

progress with the NAAQS or interfere with other applicable CAA requirement.

14. Veolia Energy- Schuylkill Station (formerly TRIGEN- Schuylkill Station) (PLID04942); Grays Ferry Cogeneration Partnership (PLID- 04944); Veolia- Energy 

Efficiency (PLID- 10459)

Veolia Energy- Schuylkill Station (Veolia- Schuylkill), Grays Ferry Cogeneration 

Partnership (Grays Ferry), and Veolia- Energy Efficiency have been determined a single source 

for permitting and RACT purposes for being located adjacently at 2600 Christian Street, 
53

Philadelphia, Pennsylvania and having common ownership. The three facilities altogether are 

considered a major source of NOx. AMS submitted separate technical memorandums for each 

facility. EPA is discussing the submitted RACT evaluation for each facility below.

a. Veolia- Schuylkill (PLID- 04942)

Veolia- Schuylkill is as steam generating facility containing the following NOx emissions 

units: a tangentially fired boiler rated 795 MMBTU/hr (Boiler #23) and a front-wall fired boiler 

rated 761 MMBTU/hr (Boiler #26); both burning number 6 oil as the primary fuel and number 2 

oil as the ignition fuel. 

EPA’s December 13, 2013 conditional approval required AMS to submit a source-specific 

RACT determination for this source, as AMS had indicated it was relying on the NOx SIP Call 

for RACT compliance. AMS has clarified that this source was previously evaluated under the 1-

hour ozone standard and has been subject to a source-specific RACT determination under 25 Pa 

Code sections 129.91-92. The 1-hour ozone RACT determination for Veolia- Schuylkill is

specified in RACT Permit PA-51-4942, issued on December 1, 1999 and approved into the SIP. 

See 65 FR 78418 (December 15, 2000). EPA confirms that the 1-hour RACT determination for 

Veolia- Schuylkill does not rely on the presumption that compliance with the NOx SIP Call 

constituted RACT for any of its emissions units. AMS has re-evaluated RACT for each 

emissions unit to ensure compliance with 25 Pa Code sections 129.91-92. EPA also notes that 

the conditional approval identified this source as an EGU, however, AMS has clarified that 

Veolia - Schuylkill is dedicated solely to steam generation and not electricity generation.

The 1-hour ozone RACT determination addressed Boilers #23 and #26 in addition to Boiler 

#24, a tangentially fired boiler rated 795 MMBTU/hr that was shutdown in 2014. See Plan 

Approval 10277. As part of the 1-hour ozone RACT determination, Boilers #23 and #24 are

subject to a NOx limit of 0.35 lb/MMBTU; Boiler #26 is subject to a NOx limit of 0.36 

lb/MMBTU on a 30-day rolling average and the requirement to operate a LNB; and all boilers 

have a combined number 6 oil limit of 65,526,316 gallons per 12-month rolling period and a 

combined NOx emissions limit of 1,646 tons per 12-month rolling period. AMS evaluated 

additional NOx controls for Boilers #23 and #26, including SCR, SNCR, ULNB, ULNB with 

natural gas, LNB, FGR, and other burner modifications. AMS determined that these controls are 

not technically nor economically reasonable for the boilers and thus do not represent RACT. 

Since the 1-hour RACT determination, Boiler #23 is subject to a federally enforceable 

restriction to operate up to 30% of its hourly maximum heat input in any given year (i.e., 

capacity factor), which significantly has reduced operations of the emissions unit and its

potential NOx emissions. See Title V Permit V11-014 issued May 24, 2012. AMS is proposing 

to reduce the NOx emissions limits for Boilers #23 from 0.35 to 0.34 lb/MMBTU and to add a 

NOx limit of 355.15 tons per 12-month rolling period, based on the 30% capacity factor. EPA 
54

anticipates that these revisions should result in reductions of potential NOx emissions of 863 tons 

in any given year, as provided in Table 16 below.

Table 16. Summary of Proposed RACT Revisions for Boilers #23 at Veolia- Schuylkill

Heat Input 

(MMBTU/

hr)

Approved RACT Requirements Proposed Revisions to RACT Requirements

NOx 

emissions 

rate (lb/ 

MMBTU)

Potential 

Fuel Usage 

(gal/year) a

Potential 

NOx 

Emissions 

(lb/hr)

Potential 

NOx 

Emissions 

(tpy)

NOx 

emissions 

rate (lb/ 

MMBTU)

Potential 

Fuel Usage 

(gal/year) b

Potential 

NOx 

Emissions 

(lb/hr)

Potential 

NOx 

Emissions 

(tpy)

795 0.35* 46,428,000 278.25 1218.74 0.34* 13,928,400 270.30 355.15*

* Denotes federally enforceable limits.

a Refers to number 6 fuel oil usage and was estimated assuming standard heating value of 0.15 MMBTU/gal. 

b Refers to number 6 fuel oil usage and was estimated assuming standard heating value of 0.15 MMBTU/gal and a 

30% capacity factor. 

AMS finds that the existing RACT requirements for Boiler # 26, including the NOx limit of 

0.36 lb/MMBTU on a 30-day rolling average, continue to represent RACT. In addition, to 

ensure lower NOx emissions during shorter time periods, AMS is proposing to add as RACT the 

NOx emissions limit of 0.41 lbs/MMBTU limit and its equivalent limit of 312.01 lbs/hr, both not 

to be exceeded in an hourly basis. Compliance with the hourly limits will be determined with 

NOx continuous emissions monitoring system (CEMS). EPA expects equivalent emission 

reductions of NOx emissions on an annual basis. 

AMS indicates that the additional proposed restrictions on Boilers #23 and #26 and the 

shutdown of Boiler #24 result in lower number 6 oil usage and combined NOx emissions than 

the 1-hour RACT combined limits for the three boilers. Therefore, AMS is proposing to remove 

these two combined limits from the SIP, as well as any reference to Boiler #24. EPA does not 

expect any emissions increases from removing these requirements. 

AMS determined the revised NOx requirements altogether represent NOx RACT under the 

1997 8-hour ozone NAAQS for Boilers #23 and #26 at Veolia- Schuylkill, and, thus, is 

requesting to update the SIP approved RACT determination to incorporate them accordingly. 

The revised source-specific RACT requirements for Veolia- Schuylkill NAAQS have been 

incorporated in the revised RACT Permit PA-51-4942, effective on February 9, 2016, which was

submitted for approval into the SIP to replace the previous version of this permit dated May 29, 

1995.

EPA finds that the RACT determination provided by AMS is reasonable and appropriately 

considered technically and economically feasible controls while setting lowest achievable limits 

and that the proposed source-specific RACT controls adequately meet RACT under the 1997 8-

hour ozone NAAQS for Veolia- Schuylkill. EPA also finds that the proposed revisions to meet 

RACT will result in equivalent or additional reductions of NOx emissions and thus should not 
55

interfere with any applicable requirement concerning attainment or reasonable further progress 

with the NAAQS or interfere with other applicable CAA requirement.

b. Grays Ferry (PLID- 04944)

Grays Ferry is as an electric utility operating one front wall-fired boilers rated 1119 

MMBTU/hr (Boiler # 25) and one combined cycle combustion turbine rated 1515 MMBTU/hr 

(135 MW), with a Heat Recovery Steam Generator (HRSG). Both emissions units combust 

natural gas and number 2 fuel oil. 

Currently, Boiler #25 is subject to the following federally enforceable NOx requirements: 

NOx emissions limits of 0.10 lb/MMBTU when firing natural gas and 0.15 lb/MMBTU when 

firing number 2 fuel oil, and the operation of LNB and FGR. See AMS Plan Approval 97019 

dated March 8, 2001. AMS evaluated additional NOx controls for Boiler #25, including: SCR, 

SNCR, ULNB, and ULNB with overfire air. AMS determined that these additional controls are 

not technically nor economically reasonable for the boiler and thus do not represent RACT. 

AMS determined that the currently applicable NOx limits and controls represent RACT under 

the 1997 8-hour ozone NAAQS.

The combustion turbine is currently subject to the following federally enforceable NOx 

requirements: NOx emissions limits of 0.0344 lb/MMBTU when firing gas, 0.1683 lb/MMBTU 

when firing number 2 fuel oil, and 255 lb/hr, and the operation of SCR and dry low NOx (DLN) 

when firing natural gas and SCR and water injection when firing number 2 fuel oil. 

Additionally, the combined NOx emissions from the combustion turbine and the HRSG are 

limited to 298.8 lb/hr. See AMS Plan Approval 97019 dated March 8, 2001. AMS determined 

that the current controls, with a 90-98% control efficiency, represent the most stringent NOx 

control option for this unit. AMS determined that the lb/hr NOx limit and current controls 

represent RACT under the 1997 8-hour ozone NAAQS. 

The new RACT requirements for Grays Ferry have been incorporated in the RACT Permit

PA-51-4944, effective on January 9, 2015, which was submitted for approval into the SIP. EPA 

finds that the RACT determination provided by AMS is reasonable and appropriately considered 

technically and economically feasible controls while setting lowest achievable limits and that the 

proposed source-specific RACT controls adequately meet RACT under the 1997 8-hour ozone 

NAAQS for Grays Ferry. 

c. Veolia- Energy Efficiency (PLID- 10459)

Veolia- Energy Efficiency is a steam generating facility that started operations in 2013. Its 

NOx emissions units are two new 297.91 MMBTU/hr boilers burning natural gas and number 2 

fuel oil. Each boiler is currently equipped with ULNB and is subject to the following federable 

enforceable NOx emission limits: 0.01 lbs/MMBTU while burning gas and 0.08 lbs/MMBTU 
56

while burning oil each on a 30-day rolling average, and a combined NOx emissions limit of 

52.31 tons per rolling 12-month period. See Plan Approval No. 10277A, dated on February 13, 

2013. 

AMS evaluated additional NOx controls as RACT for each of the boilers, including SCR, 

SNCR, ULNB, ULNB with overfire air, and LNB. AMS determined these control options to be 

neither technically nor economically reasonable, and thus not represent RACT. AMS 

determined that the currently applicable NOx limits and controls for the three boilers represent 

RACT under the 1997 8-hour ozone NAAQS. The new source-specific RACT requirements for 

Veolia- Energy Efficiency have been incorporated in the RACT Permit PA-51-10459, effective 

on January 9, 2015, which was submitted for approval into the SIP.

EPA finds that the RACT determination provided by AMS is reasonable and appropriately 

considered technically and economically feasible controls while setting lowest achievable limits 

and that the proposed source-specific RACT controls adequately meet RACT under the 1997 8-

hour ozone NAAQS for Veolia- Energy Efficiency. 

A-2. New RACT Sources with Source-Specific RACT Determinations 

1. Philadelphia Prison System (PLID- 09519)

Philadelphia Prison System is a correctional institution located at 8001 State Road, 

Philadelphia, Pennsylvania. The facility is a major source of NOx operating the following NOx 

emissions units: 57 boilers rated under 15 MMBTU/hr burning number 2 oil fuel and natural 

gas, 10 diesel-burning emergency generators with rating of 2,200 HP or less, and a 365 HP 

chiller burning natural gas.

The 57 small boilers and the emergency generators are subject to presumptive requirements 

of 25 Pa Code section 129.93(c). The 365 HP chiller is the only emissions unit subject to sourcespecific RACT under the 1997 8-hour ozone NAAQS. The chiller is currently subject to the 

following federally enforceable requirements for NOx emissions: NOx emission limit of 2.0 

grams per brake horsepower-hour and the operation of a SNCR. See AMS Plan Approval 11052. 

AMS finds that the SNCR is the most stringent control for the type of emissions unit. Therefore, 

AMS determines that these requirements represent RACT under the 1997 8-hour ozone NAAQS 

for the chiller, as the limit is the lowest achievable emission rate achieved with the most stringent 

control technology available. 

The source-specific RACT requirements for Philadelphia Prison System under the 1997 8-

hour ozone NAAQS have been incorporated in RACT Permit PA-51-9519, effective on February 

9, 2016, which was submitted for approval into the SIP. EPA finds that the RACT determination 

provided by AMS is reasonable and appropriately considered technically and economically 

feasible controls while setting lowest achievable limits and that the proposed source-specific 

RACT controls adequately meet RACT under the 1997 8-hour ozone NAAQS for Philadelphia 
57

Prison System. 

2. Temple- Main Campus (PLID- 08905)

Temple University is an educational institution providing heat, power, and hot water to 

numerous institutional buildings. The Main Sciences Campus (Temple-Main), located in Broad

Street and Montgomery Avenue, Philadelphia, Pennsylvania, is a major source of NOx, for

operating the following NOx emitting units: Ten natural gas fired electric generators with 

capacity of 1,600 kilowatts (kW); three water-tube boilers firing natural gas or oil with heat input 

ratings of 91.3 MMBTU/hr for natural gas and 86.8 MMBTU/hr for number 2 fuel oil; and other 

smaller combustion units, including 59 emergency generators and fire pumps and 21 heaters or 

boilers with heat input capacities of less than 50 MMBTU/hr. The three larger boilers and the 

electric generators are subject to the source-specific requirements of 25 Pa Code sections 129.91-

92. The smaller combustion units are subject to the presumptive RACT requirements of 25 Pa 

Code section 129.93. 

The three water-tube boilers are subject to the following federally enforceable NOx 

requirements: Each with NOx emissions limits of 0.036 lb/MMBTU when firing natural gas and 

0.110 lb/MMBTU when firing number 2 fuel oil; the combined NOx emissions limit of 15.5 tons 

per 12-month rolling period; and the operation of LNB and FGR on each unit. See AMS Plan 

Approval 07132 dated November 27, 2007. AMS evaluated additional NOx controls as RACT 

for each of the boilers, including SCR, SNCR, and water/steam injection. AMS determined 

these control options to be neither technically nor economically reasonable, and thus do not 

represent RACT. AMS determined that the currently applicable NOx limits and controls for the 

three boilers represent RACT under the 1997 8-hour ozone NAAQS.

The 10 electricity generating units are 4-stroke lean-burn natural gas fired engines. The 

engines are currently subject to the following federally enforceable NOx requirements: NOx 

emission limits from each unit are limited to 2.00 grams per boiler horsepower per hour (g/bHPhr) and combined NOx emissions are limited to 99 lb/hr; and also hour of operation are limited 

to 500 hours per 12-month rolling period. See AMS Plan Approval 92087 dated October 2, 

1992. AMS evaluated NOx controls available to date for the generators, including SCR and 

SNCR, and determined them to be technically and/or economically unreasonable, and thus not 

RACT. AMS is determining the applicable NOx emissions limits and controls for the 10 electric 

generating units to represent RACT under the 1997 8-hour ozone NAAQS. 

The source-specific RACT requirements for Temple- Main have been incorporated in the 

RACT Permit PA-51-8905, effective on January 9, 2015, which has been submitted for approval 

into the SIP in replacement of the previous version of this permit dated May 27, 1995. EPA 

finds that the RACT determination provided by AMS is reasonable and appropriately considered 

technically and economically feasible controls while setting lowest achievable limits and that the 
58

proposed source-specific RACT controls adequately meet RACT under the 1997 8-hour ozone 

NAAQS for Temple- Main. 

B. Other Revisions to Previous Source-Specific RACT Determinations 

1. Cardone Industries, Inc.- Rising Sun Avenue Plant (PLID- 03887) and Whitaker 

Avenue Plant (PLID- 02287)

Cardone Industries (Cardone) owns and operates an automotive parts manufacturing facility 

in two adjacent plants located at 5660 Rising Sun Avenue and 5501 Whitaker Avenue in 

Philadelphia, Pennsylvania. The facility is a major VOC source and is subject to 1-hour ozone 

RACT. The source’s emissions units include the following: 8 spray booths for surface coating 

operations; cold degreasing operations (5 degreasers); 11 burnout ovens with less than 20 

MMBTU/hr; a diesel-fired emergency generator with rating of 1.9 MMBTU/hr; and various 

minor combustion units with less than 20 MMBTU/hr, such as washers, ovens, cleaners, heaters, 

and pumps. 

At the time of the 1-hour ozone RACT determination, Cardone operated five plants in 

Philadelphia: 321 Chew Street (PLID- 02237); 500 East Erie Avenue (PLID- 03888); 5500 

Tabor Road (PLID- 03233); 5501 Whitaker Avenue (PLID- 02287); and 5660 Rising Sun 

Avenue, (PLID- 03887). Only the Chew Street and Rising Sun Avenue Plants were major 

sources of VOC at that time, and thus are subject source-specific RACT requirements approved 

under the 1-hour ozone NAAQS, as specified in RACT Permits PA-51-2237 and PA-51-3887

respectively, both effective on May 29, 1995 and approved into the SIP. See 66 FR 54710

(October 30, 2001). Currently, the Chew Street Plant has shut down entirely, and only the Rising 

Sun Avenue and the Whitaker Avenue Plants remain in operation were evaluated for RACT as a 

major VOC source. 

Source-specific RACT requirements under the 1-hour ozone NAAQS were approved for the 

degreasing operations in both Chew Street and Rising Avenue Plants, as specified in each SIP 

approved RACT Permit. Since all operations at Cardone’s Chew Street Plant have been 

permanently shut down, AMS is revising the SIP to remove the RACT Permit PA-51-2237 for 

Cardone’s Chew Street Plant. The SIP approved RACT Permit PA-51-3887 specifies sourcespecific RACT requirements for the degreasing operations with solvent recovery (of Stoddard 

solvents) and application of miscellaneous architectural coatings at Cardone’s Rising Sun 

Avenue Plant. AMS explains that Cardone no longer uses Stoddard solvents in its degreasing 

operations or architectural coatings, thus the existing source-specific RACT requirements are no

longer applicable. Consequently, AMS is revising the SIP to remove the RACT Permit PA-51-

3887 for Cardone’s Rising Sun Avenue. EPA does not expect these SIP revisions (to remove 

previous RACT determinations) to have any impacts to emission reductions or air quality; thus 

should not interfere with any applicable requirement concerning attainment or reasonable further 

progress with the NAAQS or interfere with other applicable CAA requirement.
59

All operating units to date in Cardone at the Chew Street and Rising Sun Avenue Plants are 

subject to presumptive or CTG RACT requirements. Surface coating operations are subject to 

25 Pa code 129.52. Degreasing operations are subject to 25 PA Code 129.63 and AMR V 

section XIII.A. The combustion units, the burn off ovens, and the emergency generator are 

subject to the presumptive requirements of 25 Pa Code 129.93(c)(5). The emergency generator 

is subject to a federally enforceable restriction to operate less than 500 hours in any consecutive 

12-month period. The presumptive and CTG requirements discussed above represent RACT for 

Cardone under the 1997 8-hour ozone NAAQS. 

EPA finds AMS’ evaluation reasonable and proposes to remove the RACT permits from the 

SIP for Cardone Chew Street and Rising Sun Avenue as these are no longer applicable. This 

proposed SIP revision will not lead to additional NOx or VOC emissions and thus not interfere 

with any NAAQS or applicable CAA requirement. EPA finds reasonable AMS’ conclusion that 

presumptive and CTG requirements discussed adequately address RACT for Cardone’s 

remaining emission units for the 1997 8-hour ozone NAAQS.

C. Revisions and Certifications For Sources No Longer Subject to 1997 8-hour Ozone 

RACT 

In the February 18, 2015 RACT SIP Revision, AMS included the November 1, 2014 

technical memorandum entitled “1-Hour RACT Facilities not in 8-hour RACT” identifying 27 

facilities subject to source-specific RACT determinations for the 1-hour ozone NAAQS, that are 

no longer subject to RACT for purposes of the 1997 8-hour ozone NAAQS. AMS indicates that 

18 of these facilities have permanently shut down, while the remaining 9 are no longer

considered major sources of NOx/VOC emissions for RACT under the 1997 8-hour ozone 

NAAQS (i.e., less than 100 or 50 tpy, respectively). Sources that remain in operation must still 

comply with the SIP approved 1-hour ozone RACT determinations, although not subject to 1997 

8-hour ozone RACT.

In 2013, AMS identified Kraft Nabisco, now named Mondelez, as having adopted additional 

RACT controls, based on the previously approved source-specific RACT determination. For this 

reason, EPA’s December 13, 2013 conditional approval required AMS to submit a sourcespecific RACT determination for this source. Mondelez is subject to a previous source-specific 

RACT determination approved in the SIP under the 1-hour ozone standard, as specified in the 

RACT Permit PA-51-3201 under its former name Nabisco Biscuit Co. (effective on April 10, 

1995), for it was considered a major source of NOx and VOC at the time. See 65 FR 78418

(December 15, 2000). AMS has clarified that in 2012 Mondelez took federally enforceable 

facility-wide limits of 25 tons per year for both NOx and VOC emissions, restricting the 

facility’s potential emissions under the applicable thresholds for 1997 8-hour RACT. See

Synthetic Minor Operating Permit No. S11-017, effective on May 7, 2012. In the November 1, 
60

2014 technical memorandum, AMS lists Mondelez as no longer being considered a major source 

of NOx and VOC emissions for RACT under the 1997 8-hour ozone NAAQS and concludes it 

should not subject to RACT under the 1997 8-hour ozone NAAQS. EPA concurs with this 

conclusion and thus determines that the condition in the December 13, 2013 conditional approval

to submit a source-specific RACT determination under the 1997 8-hour ozone NAAQS for this 

source is no longer applicable. AMS has further indicated that the facility has ceased production 

and is in the process of being permanently decommissioned. As noted by AMS and 

acknowledged by EPA, while operational, Mondelez will continue to be subject to the sourcespecific RACT determination approved in the SIP. 

As part of the February 18, 2015 RACT SIP Revision, AMS submitted a source-specific 

RACT determination for Sun Chemical- General Printing Ink Division (Sun Chemical) (PLID02052), a commercial printing ink manufacturer located at 3301 West Hunting Park Avenue in 

Philadelphia, Pennsylvania. This facility is a major source of VOC and is subject to a 1-hour 

ozone RACT determination, as specified in RACT Permit PA-51-2052, effective on July 14, 

2000, and approved in the SIP. See 66 FR 54710 (October 30, 2001). However, in the March 

26, 2016 RACT SIP revision, AMS submitted a new technical memorandum clarifying that the 

facility is no longer a major source of VOC, after adopting in 2015 a facility-wide limit of VOC

of 49 tons per year, and thus requesting to withdraw the source-specific RACT determination 

previously submitted in 2015. See Permit No. 15173 (effective on August 12, 2015). Sun

Chemical continues to be subject to the source-specific RACT determination under the 1-hour 

ozone standard as approved in the SIP. EPA agrees that a source-specific RACT determination 

is not applicable under the 1997 8-hour ozone NAAQS for this source and concurs with AMS 

request to withdraw this determination from the February 18, 2015 RACT SIP revision.

On March 26, 2016, AMS submitted the December 14, 2015 memorandum entitled 

“Certifications Regarding Facilities Previously Subject to Source-Specific RACT Determinations 

under the 1-hour Ozone Standard; and Clarifications on De-Minimis Determinations.” In this 

memorandum, AMS, among other things, formally requests to remove from the SIP the sourcespecific RACT determinations from the shutdown facilities identified in the November 1, 2014 

technical memorandum, as codified in 40 CFR 52.2020(d)(1). AMS certifies that none of these 

shutdown facilities have active operating permits or air pollution licenses for any equipment, and 

that under Pennsylvania and Philadelphia regulations, they cannot operate until further 

notification and issuance of applicable permits. The shutdown facilities and their respective SIP 

approved RACT Permits are listed in Table 17. EPA has reviewed this list and concurs with 

AMS’ recommendation to remove these RACT permits from the Pennsylvania SIP as these 

sources have permanently shut down. 
61

Table 17. Shutdown Major Sources of NOx and/or VOC in Philadelphia Subject to 

Previous Source-Specific RACT Determinations

Source SIP Approved RACT 

Permit (Effective Date) EPA’s SIP Approval Date

Aldan Rubber Company PA-51-1561 (07/21/00) 10/30/01, 66 FR 54691

Amoco Oil Company PA-51-5011 (05/29/15) 10/31/01, 66 FR 54936

Arbill Industries, Inc PA-51-3811 (07/27/99) 10/30/01, 66 FR 54691

Braceland Brothers, Inc PA-51-3679 (07/14/00) 10/30/01, 66 FR 54691

Budd Company PA-51-1564 (12/28/95) 12/15/00, 65 FR 78418

Eastman Chemical [formerly, 

McWhorter Technologies, Inc.] PA-51-3542 (07/27/99) 10/30/01, 66 FR 54691

Graphic Arts, Incorporated PA-51-2260 (07/14/00) 10/30/01, 66 FR 54691

Interstate Brands Corporation PA-51-5811 (04/10/95) 12/15/00, 65 FR 78418

Kurz Hastings, Inc. PA-51-1585 (05/29/95) 10/31/01, 66 FR 54936

Lawrence McFadden, Inc. PA-51- 2074 (06/11/97) 10/31/01, 66 FR 54936

O'Brien (Philadelphia) 

Cogeneration, Inc.—Northeast 

Water Pollution Control Plant

PA-51-1533 (07/21/00) 10/30/01, 66 FR 54691

O'Brien (Philadelphia) 

Cogeneration, Inc.—Southwest 

Water Pollution Control Plant

PA-51-1534 (07/21/00) 10/30/01, 66 FR 54691

Pearl Pressman Liberty PA-51-7721 (07/24/00) 10/30/01, 66 FR 54691

Philadelphia Baking Company PA-51- 3048 (04/10/95) 10/31/01, 66 FR 54936

Rohm and Haas CompanyPhiladelphia PA-51-1531 (07/27/99) 10/31/01, 66 FR 54942

Tasty Baking Co. PA-51-2054 (04/04/95) 10/31/01, 66 FR 54942

Transit America, Inc. PA-51- 1563 (06/11/97) 11/5/01, 66 FR 55880

SBF Communications PA-51-2197 (07/21/00) 10/31/01, 66 FR 54942

V. EPA’s Conclusion

After thorough review and evaluation of the information provided by AMS in the 

Philadelphia RACT SIP revisions for major sources of NOx and/or VOC in Philadelphia, EPA 

finds that the AMS source-specific RACT determinations and conclusions provided are 
62

reasonable and address RACT requirements for Philadelphia for the 1997 8-hour ozone NAAQS 

in accordance with the Phase 2 Ozone Implementation Rule and latest available information. 

EPA finds that the proposed source-specific RACT controls and emissions limits in the 

Philadelphia RACT SIP revisions adequately meet the CAA RACT requirements for the 1997 8-

hour ozone NAAQS for each major source of NOx and VOC in Philadelphia not covered by 

Pennsylvania RACT regulations. 

EPA also finds that the all proposed revisions to previously SIP approved RACT 

requirements, as discussed in the Philadelphia RACT SIP revisions will result in equivalent or 

additional reductions of NOx and/or VOC emissions and should not interfere with any applicable 

requirement concerning attainment or reasonable further progress with the NAAQS or interfere 

with other applicable CAA requirement in section 110(l) of the CAA. In the case of AMS 

removal of RACT requirements from the SIP that are no longer applicable, as the sources have 

been permanently removed, EPA finds these SIP revisions to be adequate and will not have any 

adverse impact to air quality. 

As discussed earlier, EPA determined in the December 15, 2013 conditional approval that 

the Philadelphia 1997 8-hour ozone RACT demonstration as provided in the 2006 and 2010 SIP 

revisions adequately met RACT under the CAA, with exception of the source-specific RACT 

requirements in 25 PA Code sections 129.91-92 and the NOx SIP Call related provisions in the 

Pennsylvania SIP in 25 Pa Code sections 145.1-145.100, 25 Pa Code sections 145.111-145.113, 

and 25 Pa Code sections 145.141-144. In this proposed rulemaking action, EPA finds that the 

subsequent Philadelphia RACT SIP revisions adequately correct the two deficiencies identified 

by EPA on the Philadelphia RACT demonstration, as provided in the 2006 and 2010 SIP 

revisions, and thus satisfy the December 15, 2013 conditional approval. Based on PADEP’s 

withdrawal of the certified provisions relying on NOx SIP Call as RACT from the 2006 SIP 

revision, EPA finds that the remaining certified NOx and/or VOC regulations, the CTG negative 

declarations, and the recently adopted regulatory provisions in AMR V sections XV and XVI, 

submitted as part of the 2006 and 2010 SIP revisions, are consistent with the latest available 

information and EPA’s guidance and therefore adequately meet RACT for the 1997 8-hour 

ozone NAAQS.

Consequently, EPA finds that the Philadelphia 1997 8-hour ozone RACT demonstration, 

as provided within the RACT SIP revisions submitted to EPA from 2006 to 2016, address RACT 

under the 1997 8-hour ozone NAAQS for all NOx and/or VOC major sources in Philadelphia 

through: (1) compliance with previously approved RACT regulations in the Pennsylvania SIP, 

including but not limited to CTG regulations (in the 2006 and 2010 SIP revisions); (2) 

submission of negative declarations (in the 2006 and 2010 SIP revisions) for CTG source 

categories; (3) the adoption of additional source-specific controls and/or limits in major sources, 

included in federally enforceable permits and submitted as part of the SIP revisions; and/or (4) 
63

certifications for major sources subject to source-specific RACT controls previously approved 

into the SIP, which controls continue to represent RACT under the 1997 8-hour ozone NAAQS. 

For these reasons, EPA is proposing approval of the Philadelphia RACT SIP revisions, as 

meeting the conditions established by EPA in its December 13, 2013 conditional approval, and 

consequently proposing to remove the conditional nature of the previous approval for the 

Philadelphia 1997 8-hour ozone RACT demonstration. 

Attachments

Appendix A: Abbreviations and Units

Appendix B: List of RACT Documentation by Source Submitted by PADEP/AMS as part of the 

Philadelphia 1997 8-hour ozone RACT SIP Revisions

Appendix C: EPA’s Clarification on Superseded RACT Documents from the 2015 SIP Revision
APPENDIX A- Abbreviations and Units

Abbreviations

AMS- Philadelphia Air Management Services

CAIR- Clean Air Interstate Rule 

CEMS- continuous emissions monitoring system

CTG- control technique guideline

DLN- dry low NOx

EGU- electric generating unit

FCCU- fluid catalytic cracking unit

FGR- flue gas recirculation

HAP- hazardous air pollutant

HRSG- heat recovery steam generator

LNB- low NOx burner

LoTOx- low temperature oxidation device

MACT- maximum achievable control technology

MVCCS- marine vapor collection and control system

MVCU- marine vapor control unit

NAAQS- national ambient air quality standards

NOx- nitrogen oxides

OTR- ozone transport region 

PADEP- Pennsylvania Department of Environmental 

Protection

RACM- reasonably available control measures

RACT- reasonably available control technology

RICE- reciprocating internal combustion engine

SCA- staged combustion air

SCR- selective catalytic reduction

SIP- state implementation plan

SNCR- selective non-catalytic reduction

TSD- technical support document

ULNB- ultra low NOx burner

VOC- volatile organic compounds

Units

%- percent

g/bHP-hr- grams per boiler horsepower per hour 

HP- horsepower

kW- kilowatts

lb- pounds

lb/hr- pounds per hour (emissions rate)

lb/MMBTU- pounds per million British Thermal 

Units (emissions rate)

MMBTU- million British Thermal Units (energy)

MMBTU/hr- million British Thermal Units per hour 

(heat input rating)

MMCf/yr- million cubic feet per year (volumetric 

rate)

MW- megawatts (energy output rating)

ppm- parts per million (concentration)

ppmv- parts per million, volumetric (concentration)

psia- pounds per square inch (pressure)

psia- pounds per square inch, absolute (pressure)

RVP- Reid Vapor Pressure 

tpy- tons per year (emissions rate)