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 Conditi on 2.C. The existing wall ports in Boiler #3 were previously

mischaracterized as FGR.

The RACT plan approval is su bject 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 Cont rol Technology (RACT)

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

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

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

1.A. Emission Sources of the a ttached RACT Plan Approval.

Facility: Honeywell Intern ational – Frankford Plant

Owner: Honeywell International

Location: 4 7 0 0 B e r m u d a S t r e e t

, P h i l a d e l p h i a

, P A 1 9 1 3 7

- 1 1 9 3

Mailing Address: 4 7 0 0 B e r m u d a S t r e e t

, P h i l a d e l p h i a

, P A 1 9 1 3 7

- 1 1 9 3

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 S ource Registration DateRACT PLAN APPROVAL Honeywell Page 2

2

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/ 1 6 The RACT plan approval is su bject to the following conditions:

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

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

includes the following emission sources and control equipment:

A. Emission Sources

(1) Boilers: Boiler #1 (260 MMBTU/hr), firing wa ste 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 curt ailment, other loss of supply (e.g. PGW supply line failure or

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

annual combustion tuning, and combustion performa nce 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. Du ring such events No. 6 oil may be used.

C. Boiler #3: Honeywell shall maintain and operate the low NO X burners and wall ports on Boiler #3.

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

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

D. BARGE LOADING:RACT PLAN APPROVAL Honeywell Page 3

2

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/ 1 6 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 sha ll be installed and maintained on tanks VT-609 and VT-610.

F. RAIL CAR CLEANING:

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

G. WASTEWATER FACILITIES:

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

thermal oxidizer will have destruc tion 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 th e 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 31 st of each year not to exceed

12 months between tunings.

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

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

12 months between tunings.

4. Stack Emission Limitations

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

( 1 ) S h a l l n o t e x c e e d 0

. 2 8 p o u n d s o f N O x p e r M M B T U e a c h

, o n a r o l l i n g 3 0

- d a y a v e r a g e

,

w

h i l e b u r n i n g n a t u r a l g a s

, w a s t e p h e n o l r e s i d u e

, o r a c o m b i n a t i o n o f t h e s e f u e l s ; ( 2 ) S h a l l n o t e x c e e d a n d 0

. 3 5 p o u n d s o f N O x p e r M M B T U e a c h w h i l e b u r n i n g N o

. 6 o i l ; ( 3 ) T h e c o m b i n e d N O x e m i s s i o n s f o r B o i l e r # 1 a n d B o i l e r # 2 s h a l l n o t e x c e e d 2 7 2 t o n s p e r

y e a r

.

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 Co mpany, Inc. shall begin immediate implementation

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

6. Testing/Monitoring RequirementsRACT PLAN APPROVAL Honeywell Page 4

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/ 1 6 A. Continuous nitrogen oxides a nd oxygen monitors and recorders shall be operated on Boiler # 1,

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

from the boiler stack.

7. Recordkeeping and Reporting Requirements

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

collected to demonstrate compliance with NO X /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) C o n t i n u o u s n i t r o g e n o x i d e s a n d o x y g e n m o n i t o r r e c o r d s f o r B o i l e r # 1

, B o i l e r # 2

, a n d B o i l e r

# 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 comp liance shall be recorded and maintained in a time

frame consistent with the aver aging period of the requirement.

D. Records shall be retained for at least five year s and shall be made availa ble 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 sp ecified in Section 123.41, particulate matter in

excess of the limitations specified in Section 123.11 or sulfur oxi des in excess of the limitations

specified in Section 123.22, all Sections of Chapte r 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 limitati ons specified in, or established pursuant to, any

other applicable rule or regula tion 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 ai r 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 e quipment 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 appr oved as RACT by EPA will requir e resubmission as revision to

the PA State Implementation Plan. The applican t shall bear the cost of public hearing and

notification required for EPA approval as stipulated in 25 PA Code §129.91(h).