CITY OF PHILADELPHIA

Department of Public Health 

Environmental Protection Division 

Air Management Services 

InterOffice Memo 

To: File 

From: Rahel Gebrekidan 

Date: 7/22/2015 

Subject: 8-Hour RACT Analysis for Sun Chemical - (PLID # 02052) 

Introduction: 

The Clean Air Act (CAA) requires that moderate (or worse) ozone nonattainment areas implement reasonably 

available control technology (RACT) controls on all major sources of VOC and NOx. Philadelphia County is part of 

the Philadelphia-Wilmington-Atlantic City moderate ozone nonattainment area for the 1997 8-hour ozone NAAQS. 

This document presents the findings of a RACT evaluation for the 1997 8-hour ozone standard for this facility. 

Company Description: 

Sun Chemical manufactures and distributes commercial printing ink in Philadelphia, Pennsylvania. Specifically, the 

manufacturing process at the Philadelphia facility produces solvent-based and water-based printing ink for the 

packaging industry, and middle distillate oil-based printing ink for the web publication industry. 

Applicability for NOx and VOC RACT: 

Sun Chemical is not a major source for Nitrogen Oxides (NOx) emission having potential NOx emissions 

less than 100 tons per year, the major source threshold in Philadelphia County that is applicable to NOx 

RACT for the 1997 8-hour ozone NAAQS. Sun Chemical was a major Volatile Organic Compounds 

(VOC) at the time of the previous RACT determination in 1994. 

1-Hour Case-by-case RACT 

AMS determined a case-by-case RACT analysis for the 1-hour ozone standard in June, 1994. As a result, 

AMS issued a RACT plan approval (PA-51-2052) on July 14, 2000, which was approved by EPA as a SIP 

revision on 10/30/2001 (66 FR 54710). VOC RACT was determined for INKMAKER computerized 

blending, conventional blending, rotor stator mixer, horizontal mill, ball mill, kady mill, varnish 

production , dye room mixer ,transfers and storage tanks, as described below; 

1. Lids will be placed on all mixing tanks; excluding water based and paste inks. 

2. Covers will be placed over all storage vessels, except during filling and removing the contents, excluding water 

based and paste inks. 

3. Monthly inspections of the facility will be made and recorded by plant personnel to ensure proper housekeeping 

practices. 

4. The vapor return lines on the storage tanks shall be used when a delivery tank truck is equipped with a vapor 

return line connection 

 On 6/16/2015 the facility submitted an Installation Permit Application No. 15173 to accept a facility-wide VOC 

emission limit of 49 tons per year. Once approved, the VOC limit will be incorporated into the facility’s Title V 

operating permit V10-015. Based on this restriction, RACT would no longer be an applicable requirement for Sun 

Chemical under the 1997 8-hour ozone NAAQS, and no RACT determination is needed. Thus, AMS requests to 

replace the RACT submission made to EPA for Sun Chemical on June 27, 2014 with this document. The facility must 

still comply with its original RACT plan approval requirements which were made part of the State Implementation 

Plan (SIP) to continue to satisfy RACT for the 1-hour ozone standard. 

 
 2 

7/22/15

Edward Wiener, Chief of Source Registration Date