CITY OF PHILADELPHIA 

DEPARTMENT OF PUBLIC HEALTH 

 AIR MANAGEMENT SERVICES 

 RACT PLAN APPROVAL 

Effective Date: January 9, 2015

Expiration Date: None 

Replaces Permit No. PA-8906 effective on May 27, 1995 

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

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

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

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

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

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

Facility: Temple University – Health Sciences Campus 

Owner: Temple University 

Location: 3401 North Broad Street Philadelphia, PA 19140 

Mailing Address: 1009 West Montgomery Ave, Philadelphia, PA 19122 

SIC Code(s): 8221 

Plant ID: 08906 

Facility Contact: Kurt A. Bresser 

Phone: (215) 204-4515 

Permit Contact: Kurt A. Bresser 

Phone: (215) 204-4515 

Responsible 

Official:

Robert Siegfried, 

Title: Associate Vice President Facilities Management 

 1/9/2015

Edward Wiener, Chief of Source Registration Date 
PLAN APPROVAL Temple University – Health Sciences Campus Page 2

1/9/15

The RACT plan approval is subject to the following conditions: 

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

control technology (RACT) for Temple University, Health Science center. This includes the 

following emission source and control equipment. 

A. Emission Sources 

(i) Boiler #1: The Central Steam Plant (CSP) Boiler #1 is a Keeler CP units with heat input 

76.4 MMBTU/hr that combust both natural gas and #6 fuel oil 

(ii) Boiler #2: The Central Steam Plant (CSP) Boiler #2 is a Keeler CP units with heat input 

76.4 MMBTU/hr that combust both natural gas and #6 fuel oil 

(iii)Boiler #3: The Central Steam Plant (CSP) Boiler #3 is a Keeler CP units with heat input 

76.4 MMBTU/hr that combust both natural gas and #6 fuel oil 

2) This approval authorizes 

 

A. Installation of the following 

(i) CCA burner modifications shall be performed on each boiler, including each of the 

following: 

a. Installation of staged flame stabilizers (a.k.a. swirlers). 

b. Redesign and replacement of the atomizers. 

c. Replacement of the center-fired gas injection rings with gas manifolds having 

center-fired and poker gas injection. 

d. Installation of a NOx tempering system (water injection). 

B. Emission limits 

(i) The combined heat input for Boilers #1, #2, and #3 shall not exceed 673,894 MMBTU per 

rolling 12-month period. 

(ii) Nitrogen Oxides (NOx)emissions from each boiler shall not exceed the following 

(a) 0.067 lbs/MMBTU while burning natural gas. Compliance shall be determined 

based on stack test and shall be the average of three one hour separate test runs for 

each source.

(b) 0.40 lbs/MMBTU while burning No.6 fuel oil. Compliance shall be determined 

based on stack test and shall be the average of three one hour separate test runs for 

each source.

(c) Nitrogen Oxides (NOx) emissions from Boilers #1, #2, and #3 combined shall not 

exceed 56.3 lbs/hr. 

(iii)During the ozone season (April 1 – October 31), each boiler shall burn natural gas as the 

primary fuel. Each boiler may only burn No. 6 fuel oil during periods of gas curtailment 

and natural gas interruption. 

 

3) Testing Requirements 

A. Temple University – Health Sciences Campus shall conduct a NOx performance test on each 

of the three boilers every five years while burning No. 6 oil and natural gas. 

B. At least (30) days prior to the test, Temple universtiy shall sumbit to AMS for approval the 

procedures for the test and sketch with dimentions indicating the loctation of sampling ports 

and other data to ensure the collection of representative samples
PLAN APPROVAL Temple University – Health Sciences Campus Page 3

1/9/15

4) Monitoring, Recordkeeping and Reporting Requirements 

A. Temple University shall maintain a file containing all the records and the data that are 

required to be collected to demonstrate compliance with NOx RACT requirement 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. Temple shall monitor and record the monthly fuel usage for each boiler 

E. Temple shall monitor and record verification of compliance with the NOx emission limits. 

Compliance with the NOx limit shall be based on AMS approved stack test data. 

F. Temple shall keep records of the fuel manifests documenting the nitrogen content of No. 6 

fuel oil. 

G. Temple shall keep hourly records of NOx emissions from the boilers calculated on a weekly 

basis. 

H. Temple shall keep records of the reasoning of burning fuel oil during the ozone season (April 

1 – October 31), 

I. Temple shall monitor and record the combined heat input of the boilers per rolling 12-month 

period. 

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

request. 

5) RACT Implementation Schedule 

A. Upon issuance of this approval Temple University – Health Sciences Campus shall begin 

immediate implementation of the measures necessary to comply with the approved RACT 

proposal. 

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

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

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

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

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

enforcement of the Air Pollution Control Act. 

7) Revisions to any conditions approved as RACT by EPAwill 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).