CITY OF PHILADELPHIA 

DEPARTMENT OF PUBLIC HEALTH 

 AIR MANAGEMENT SERVICES 

RACT PLAN APPROVAL 

Effective Date: January 9, 2015 

Expiration Date: None 

Replaces PA Permit Number 51-4922 effective July 7, 1999 

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

2119, as amended, and after due consideration of a Reasonably Available Control 

Technology (RACT) proposal received under the Pennsylvania Code, Title 25, Chapter 

129.91 thru 129.95, of the rules and regulations of the Pennsylvania Department of 

Environmental Protection (PADEP), Air Management Services (AMS) approved the RACT 

proposal of the Facility below for the source(s) listed in section 1.A. Emission Sources of the 

attached RACT Plan Approval. 

Facility: Philadelphia Gas Works, Richmond Plant 

 

Owner: City of Philadelphia 

Location: 3100 E. Venango St. Philadelphia, PA 19134 

Mailing Address: 3100 Passyunk Avenue, Philadelphia, PA 19145 

SIC Code(s): 4925 

Plant ID: 4922 

 

Facility Contact: James McLaughlin

Phone: (215) 787-5065 

Permit Contact: Lisa Popovics

Phone: (215) 684-6551 

Responsible Official: Raymond Snyder

Title: Director, GasProcessing

 1/9/15 

 

Edward Wiener, Chief of Source Registration Date 
RACT PLAN APPROVAL Philadelphia Gas Works, Richmond Plant Page 2

1/9/15

The RACT plan approval is subject to the following conditions:

1. The purpose of this Plan Approval is to establish Nitrogen Oxides (NOx) Reasonably Available Control Technology

(RACT) for PGW This includes the following emission sources and control equipment:

A. Emission Sources:

Unit Description Fuel Type Full Rated Capacity

LNG vaporization Heater Natural Gas 94.1 MMBTU/hr

LNG vaporization Heater Natural Gas 94.1 MMBTU/hr

LNG vaporization Heater Natural Gas 96.6 MMBTU/hr

LNG vaporization Heater Natural Gas 102.1 MMBTU/hr

LNG vaporization Heater Natural Gas 105.0 MMBTU/hr

LNG vaporization Heater Natural Gas 105.0 MMBTU/hr

B. Control Equipment

(1) Limit the following units’ operating schedule to five percent of their maximum operating capacity:

LNG vaporization Heater 94.1 MMBTU/hr

LNG vaporization Heater 94.1 MMBTU/hr

LNG vaporization Heater 96.6 MMBTU/hr

LNG vaporization Heater 102.1 MMBTU/hr

LNG vaporization Heater 105.0 MMBTU/hr

LNG vaporization Heater 105.0 MMBTU/hr

(2) Set and maintain the timing of the three Caterpillar Engines 135G2U 295 horsepower Units engine at four degree

retarded relative to the standard timing.

2. This approval requires and authorizes:

A. PGW shall comply with the requirements as specified in the RACT requirements of 25 PA Code 129.91(f); pertaining

to expeditious compliance.

B. The following sources shall comply with presumptive RACT requirement requirements of 25 PA Code 129.93(c)(5):

(1) Calculated on a 12-month rolling period the total annual fuel usage for the Six LNG vaporization Heaters 103

MMBTU/hr Units is limited to 257 MMCF of natural gas.

3. Emission Limitations:

A. None

4. RACT Implementation Schedule:

A. Upon issuance of this approval, PGW shall begin immediate implementation of the measures necessary to comply

with this RACT permit.

B. removing

5. Testing Requirements:

A. If at any time AMS has cause to believe that air contaminant emissions from any source(s) listed in Section A of this

permit may be in excess of the limitations specified in this permit, or established pursuant to, any applicable rule or
RACT PLAN APPROVAL Philadelphia Gas Works, Richmond Plant Page 3

1/9/15

regulation contained in 25 PA Code Article III, the Permittee shall be required to conduct whatever tests are deemed

necessary by AMS to determine the actual emission rate(s).

6. Recordkeeping and Reporting Requirements:

A. PGW shall maintain a file containing all the records and other data that are required to be collected to demonstrate

compliance with NOx RACT requirements of 25 PA Code §129.91- 129.94.

B. The records shall provide sufficient data and calculations to clearly demonstrate that the requirements of §129.91-

129.94 are met.

C. Data or information required to determine compliance shall be recorded and maintained in a time frame consistent

with the averaging period of the requirement.

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

7. The company shall not impose conditions upon or otherwise restrict the AMS' access to the aforementioned source(s)

and/or any associated air cleaning device(s) and shall allow AMS to have access at any time to said source(s) and

associated air cleaning device(s) with such measuring and recording equipment, including equipment recording visual

observations, as AMS deems necessary and proper for performing its duties and for the effective enforcement of the Air

Pollution Control Act.

8. Revisions to any emission limitations incorporated in this RACT Approval shall require resubmission as revision to the PA

State Implementation Plan. The applicant shall bear the cost of public hearing and notification required for EPA approval

as stipulated in 25 PA Code §129.91(h).

.