CITY OF PHILADELPHIA

Department of Public Health 

Environmental Protection Division 

Air Management Services 

InterOffice Memo 

To: File 

From: Rahel Gebrekdian 

Date: October 16, 2015 

Subject: 8-Hour RACT Analysis for Allied Tube & Conduit 

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: 

Allied Tube & Conduit Corporation operates a tube and conduit manufacturing facility located at 11350 Norcom 

Road, Philadelphia, PA 19154. The facility’s air emission sources include three (3) mills, one (1) Mill 1 area space 

heater rated 3.76 MMBtu/Hr, and four (4) warehouse space heaters each rated 801,000 Btu/Hr. 

Applicability for NOx and VOC RACT: 

Allied Tube & Conduit is not a major source of Nitrogen Oxides (NOx) 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. 

Allied Tube & Conduit is a major source of Volatile Organic Compounds (VOC) having potential VOC emissions 

greater than 50 tons per year, the major source threshold in Philadelphia County that is applicable to VOC RACT for 

the 1997 8-hour ozone NAAQS. 

Process Descriptions: 

The three (3) mills route steel through a tube roll former. The mills emit VOCs during the inner-diameter (ID) 

coating part of the process which paints the inner-diameter of the conduit. Mill 1P has a capacity of 61,000 tons of 

product, Mill 2P has a capacity of 53,000 tons of product, and Mill 3P has a capacity of 50,000 tons of product. The 

Tube acid cleaning process which was included in the previous RACT determination is not a VOC emission source; 

for thus it is removed from the RACT evaluation. 

The facility’s air emission sources contributing to VOC emissions include: 

 Three (3) Mills 

 One (1) Mill 1 Area Space Heater with a capacity of 3.76 MMBtu/Hr. that burns natural gas; 

 Four (4) Warehouse Space Heaters each with a capacity of 801,000 Btr/Hr. and burning natural gas; 

Presumptive RACT: 

The following sources are covered by Presumptive RACT regulations, as is specified in the “Presumptive RACT 

Regulation” column of the table below: 

Space Heaters 
For each space heater, the presumptive RACT requirements are the installation, operation, and maintenance of the 

boiler as per the manufacturer’s specifications. 

CTG RACT: 

The following sources are covered by CTG RACT regulations, as is specified in the “CTG RACT regulation” 

column of the spreadsheet below. 

Mills 

For each of the above sources, the CTG RACT limitation is the VOC content limit in units of pound per gallon of 

coating solids, and the maintenance of records kept on a daily basis in order to demonstrate compliance with the 

VOC limitations. 

Case-by-Case RACT: 

None. 

Conclusions and Recommendations: 

All VOC emitting sources are covered by presumptive and CTG RACT. 

 10/16/15 

Edward Wiener, Chief of Source Registration Date 

Unit Heat Input (BTU/hr) Fuel Burned Presumptive RACT 

Regulation

MIL 1 Area Space Heater #1 (CU02) 3,760,000 Natural Gas 25 PA Code 129.93(c )(1)

Warehouse Space Heater #1 (CU04) 801,000 Natural Gas 25 PA Code 129.93(c )(1)

Warehouse Space Heater #2 (CU04) 801,000 Natural Gas 25 PA Code 129.93(c )(1)

Warehouse Space Heater #3 (CU04) 801,000 Natural Gas 25 PA Code 129.93(c )(1)

Warehouse Space Heater #4 (CU04) 801,000 Natural Gas 25 PA Code 129.93(c )(1)

Unit Capacity

(tons of product) CTG RACT Regulation

Mil 1P 61,000 25 PA Code 129.52(a)-(c )

Mil 2P 53,000 25 PA Code 129.52(a)-(c )

Mil 3P 50,000 25 PA Code 129.52(a)-(c )