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May 16, 1977 Emissions Offset Policy-City
of Philadelphia 25.2
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25.2
DATE: May 16, 1977 SUBJECT: Emissions Offset Policy-City of Philadelphia FROM: Director, Division of Stationary Source Enforcement TO: Howard R. Heim, Chief Air Programs Branch, Region III This is in response to your memo dated April 8, 1977, requesting a determination of applicability concerning a proposed refuse-fired steam generator to be located in the city of Philadelphia. After reviewing the information submitted in your original request and the consent order with the city of Philadelphia, subsequently submitted to this office, we have determined that the emission decrease effected by the closure of the Bartrum incinerator cannot be used to offset the emissions from the proposed new refuse-fired steam generator. Paragraph IV. C. (3) at page 55529 of the interpretative ruling states that "a source may be credited with emission reduction achieved by shutting down an existing source or permanently curtailing production or operating hours below that which existed at the time the new source application was submitted." Since the Bartrum incinerator was closed prior to submittal of the application for the new source, emission offsets allowed under this paragraph are not appropriate. The footnote to this paragraph further states "however, where an applicant can establish that it shut down or curtailed production after SIP approval as a result of enforcement action providing for a new source as a replacement for the shutdown or curtailment, credit for such shutdown or curtailment may be applied to offset emissions from the new source." The consent order states that the Bartrum incinerator shall cease operation commensurate with the date for the delivery of trucks needed for the run between various transfer facilities and the landfills. Since Bartrum was to be used after this date solely as a transfer station and its closure did not provide for the construction of the refuse-fired steam generator, emission offset credit cannot be allowed. If you have any questions on this please contact Rich Biondi (755-2564) of my staff.
SUBJECT: Acceptability of Emission Offsets Proposed by the City of Philadelphia FROM: Howard R. Heim, Chief Air Programs Branch, 3AH10 TO: John B. Rasnic, Chief Compliance Monitoring Branch, EN-341 Please advise us as to whether you consider the emission offsets proposed by the City of Philadelphia, and described below, acceptable under the Offset Policy. The City plans to construct a refuse-fired steam generator which will emit more than 100 tons per year of particulate matter. To comply with the requirements of the Policy, the City proposes to use as offset credit the particulate emissions reductions that resulted from the shutdown in 1975 of the City's Bartrum incinerator. This shutdown was required by a consent order between EPA and the City.
Although we believe the City may have a valid argument for its position, I am requesting your decision on this matter before we inform the City of the acceptability of the proposed offsets. Enclosed are relevant documents submitted to us by the City. If you have any questions concerning this issue, please contact me or Mr. Jim Sydnor of my staff at 8/597-8181.
In the Matter of: CITY OF PHILADELPHIA, DEPARTMENT OF STREETS
The omission of particulate matter from five of the incinerator facilities (excluding Northwest) of the Department of Streets, City of Philadelphia causes air pollution, as the term is defined in the Commonwealth of Pennsylvania Air Pollution Control Act, as amended, 35 P.S. Section 4001 et seq. That Act, as well as "Regulations of the Air Pollution Control Board, City of Philadelphia,
Relating to Control of Incinerators" are contained in the Implementation Plan which was approved in part by the Administrator of the Environmental Protection Agency on May 31, 1972, pursuant to Section 110 of the Clean Air Act of 1970, 42 USCA Section 1857 c-5, 40 CFR Section 52.202 et seq., 37 F.R. 10842, 10889, (May 31, 1972).
The following compliance program deals with three of the six incinerators. A similar program has been established for the other three incinerators.
Reports shall be in writing, and will be sent to the Air Compliance Branch, Enforcement Division, Region III office, with copies sent to Air Management Services, City of Philadelphia. AND NOW, this day of , 1974 the Environmental Protection Agency hereby issues this Order. ____________________________________ The City of Philadelphia, Department of Streets, hereby consents to the terms of this Order, and agrees to comply with all requirements contained herein. Furthermore, City of Philadelphia, Department of Streets, waives its right to receive a Notice of violation prior to the issuance of this Order, as required by Section 113(a)(1) of the Clean Air Act, (42 U.S.C. Section 1857c-8(a)(1)), and the right to request a conference as required by Section 113(a)(4) of the Clean Air Act (42 U.S.C. Section 1857c-8(a)(4)). AND NOW, this 3rd day of October , 1974 the City of Philadelphia, Department of Streets, by its duly authorized officer, consents to the issuance of this Order. City of Philadelphia BY _________________________ The City of Philadelphia, Air Management Services has been notified of the proceedings, and hereby concurs in the issuance and terms of this Consent Order. Air Management Services also waives its right to be notified, under Section 113(a)(1) of the Clean Air Act, of the violation. BY _________________________ |