CITY OF PHILADELPHIA 

DEPARTMENT OF PUBLIC HEALTH 

 AIR MANAGEMENT SERVICES 

 RACT PLAN APPROVAL 

Effective Date: February 9, 2016 

Expiration Date: None 

Replaces Permit No. PA Permit Number 51-1551 dated July 27, 1999 

Corrected on January 20, 2016 to correct typographical errors in Condition 2.B and correct the term 

“FGR” to “wall ports” in Condition 2.C. The existing wall ports in Boiler #3 were previously 

mischaracterized as FGR. 

The RACT plan approval is subject to the following conditions: 

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: Honeywell International – Frankford Plant 

 

Owner: Honeywell International 

Location: 4700 BermudaStreet,Philadelphia,PA19137-1193

Mailing Address: 4700 BermudaStreet,Philadelphia,PA19137-1193

SIC Code(s): 2869 

Plant ID: 1551 

 

Facility Contact: Paul Persing 

Phone: (215) 807-8442 

 

Permit Contact: Paul Persing 

Phone: (215) 807-8442 

 

Responsible Official: William F Rodebaugh 

Title: Plant Manager 

 2/9/2016 

Edward Wiener, Chief of Source Registration Date 
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2/9/16

The RACT plan approval is subject to the following conditions: 

1. The purpose of this Plan Approval is to establish Nitrogen Oxides (NOx)/Volatile Organic 

Compound (VOC) Reasonably Available Control Technology (RACT) for Honeywell. This 

includes the following emission sources and control equipment: 

A. Emission Sources 

(1) Boilers: Boiler #1 (260 MMBTU/hr), firing waste residue, gas or #6 fuel oil. 

 Boiler #2 (260 MMBTU/hr), firing waste residue, gas or #6 fuel oil. 

 Boiler #3 (381 MMBTU/hr), firing gas or #6 fuel oil only. 

 Boiler @ barge loading facility (< 250 MBTU/hr), firing #2 fuel oil. 

 (2) Barge Loading. 

 (3) Storage Tanks: VT-609, VT-610. 

(4) Fugitive Emission Sources: pumps, valves, flanges, compressors, pressure relief valves, 

and rupture disks. 

 (5) Rail Car Cleaning 

(6) Wastewater Facilities 

 B. Control Equipment 

(1) Thermal Oxidizer TR-602 

2. This approval requires and authorizes: 

A. Boiler #1 and Boiler #2 shall only burn natural gas and waste phenol residue except if there 

is a natural gas curtailment, other loss of supply (e.g. PGW supply line failure or 

maintenance activity) or during stack testing programs (e.g. annual CEM RATA testing, 

annual combustion tuning, and combustion performance testing, as required). During such 

events No. 6 fuel oil may be used. 

B. Boiler #3 shall only burn natural gas except if there is a natural gas curtailment, other loss of 

supply, or during stack tetsing programs. During such events No. 6 oil may be used. 

C. Boiler #3: Honeywell shall maintain and operate the low NOX burners and wall ports on Boiler #3. 

D. Honeywell shall perform, at a minimum, the annual combustion tuning specifications as cited in 

25 PA 129.93(b)(2) through (5) for Boilers #1, #2, and #3. 

D. BARGE LOADING: 
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Honeywell shall not load any VOC with a vapor pressure in excess of 1.5 psia at 20 degrees 

Celsius. 

E. STORAGE TANKS VT-609 and VT-610: 

 Internal floating roofs shall be installed and maintained on tanks VT-609 and VT-610. 

F. RAIL CAR CLEANING: 

Rail car cleaning emissions shall not exceed 2.7 tons per 12-month rolling period. 

G. WASTEWATER FACILITIES: 

 The thermal oxidizer will control VOC emissions from the air stripper at the wastewater facility. The 

thermal oxidizer will have destruction efficiency not less than 95%. 

3. RACT Implementation Schedule 

A. Upon issuance of this approval, Honeywell shall begin immediate implementation of the measures 

necessary to comply with the approved RACT proposal. 

B. Sources proposing combustion tuning to comply with RACT requirements of 25 PA Code 

129.91(f) shall perform the annual combustion tuning by December 31st of each year not to exceed 

12 months between tunings. 

C. Sources that have Low NOx Burners and FGR to comply with RACT requirements of 25 PA Code 

129.91(f) shall perform combustion tuning annually by December 31st of each year not to exceed 

12 months between tunings. 

4. Stack Emission Limitations 

 

A. The emission rates for Boiler #1& #2: 

(1) Shall not exceed 0.28 pounds of NOx per MMBTU each, on a rolling 30-day average,

while burning natural gas, waste phenol residue, or a combination of these fuels;

(2) Shall not exceed and 0.35 pounds of NOx per MMBTU each while burning No. 6 oil;

(3) The combined NOx emissions for Boiler #1 and Boiler #2 shall not exceed 272 tons per

year.

B. The emission rate of Boiler #3 shall not exceed 0.12 pounds of NOx per MMBTU on a rolling 30-

day average while burning natural gas or 0.3 pounds of NOx per MMBTU while burning No. 6 

oil. 

5. RACT Implementation Schedule 

A. Upon issuance of this approval, Honeywell Company, Inc. shall begin immediate implementation 

of the measures necessary to comply with the approved RACT proposal. 

6. Testing/Monitoring Requirements 
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A. Continuous nitrogen oxides and oxygen monitors and recorders shall be operated on Boiler # 1, 

Boiler #2, and Boiler #3 in order to measure and record the concentrations of these gases emitted 

from the boiler stack. 

7. Recordkeeping and Reporting Requirements 

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

collected to demonstrate compliance with NOX /VOC 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. These shall include: 

(1) Continuous nitrogen oxides and oxygen monitor records for Boiler # 1, Boiler #2, and Boiler

#3.

(2) Fuel type and monthly fuel usage. 

(3) Monthly records demonstrating compliance with the combined tons per year NOx limit for 

Boiler #1 and Boiler #2 in Condition 4.A. 

(4) Records of each time No. 6 oil is burned in Boilers #1, #2, or #3 and the reason why. If the 

reason is gas curtailment or other loss of supply, it shall be reported to AMS. 

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 five years and shall be made available to the AMS on request. 

 

8. The operation of the aforementioned sources shall not at any time result in the emission of visible 

air contaminants in excess of the limitations specified in Section 123.41, particulate matter in 

excess of the limitations specified in Section 123.11 or sulfur oxides in excess of the limitations 

specified in Section 123.22, all Sections of Chapter 123 of Article III of the Rules and Regulations 

of the Department of Environmental Resources, or in the emission of any of these or any other 

type of air contaminant in excess of the limitations specified in, or established pursuant to, any 

other applicable rule or regulation contained in Article III. 

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

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

AMS deems necessary and proper for performing its duties and for the effective enforcement of 

the Air Pollution Control Act. 

10. Revisions to any conditions approved as RACT by EPA will 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).