Philadelphia’s Air Toxics Regulations in Effect as of January 1, 2024
Posted: June 25th, 2024
Authors: Laura N.
The City of Philadelphia’s Air Management Services’ (AMS) new Air Management Regulation (AMR) VI Toxics Rule and health risk screening workbook went into effect January 1, 2024. The AMR VI rule had been finalized at an Air Pollution Control Board (APCB) meeting held on April 27, 2023. For every major source in Philadelphia with a Title V Operating Permit (TVOP), this rule will affect the process of installing new equipment or applying for a TVOP renewal. The rule also affects certain non-Tile V facilities as well.
AMR VI contains a list of 217 toxic air contaminants (TAC) which are the subject of the requirements of the rule. This TAC list includes nearly all 187 pollutants currently classified as hazardous air pollutants (HAP) by the United States Environmental Protection Agency (U.S. EPA) pursuant to Section 112 of the Clean Air Act (CAA). An applicant seeking an Installation Permit or Plan Approval from AMS for a new or modified source will be required to conduct risk screening if the source has the potential to emit at least one of the listed TAC in an amount above reporting thresholds, which are listed in the Technical Guidelines to the AMR VI. The reporting threshold is the annual emissions rate level in pounds per year from a source that, when exceeded, would trigger the requirement to conduct a health risk analysis. A source with potential TAC or HAP emissions below this reporting threshold would not require an air toxics risk assessment and would be considered an insignificant source (i.e., would not require a permit or certificate) assuming all other air permit exemption criteria were met.
The program that AMS has developed is nearly identical to the New Jersey Department of Environmental Protection (NJDEP) toxics program, which is a historically difficult process to navigate. The health risk screening workbook remains inconsistent with Technical Guidance as it contains many pollutants that are not covered by the AMR VI Rule, such as diesel particulate matter (DPM), hydrogen sulfide, sulfuric acid, and sodium hydroxide. Other than the AMS workbook, U.S. EPA’s air quality screening model, AERSCREEN, or an alternative air screening model, approved by AMS on a case-by-case basis, are given as options for conducting the health risk assessment.
If your facility has the potential to emit any of the 217 TACs subject to this requirement, do not hesitate to reach out to ALL4 for assistance. ALL4 has extensive experience in Air Toxics Modeling and with the health risk screening workbook, and is capable of working with facilities to navigate this new territory. Please reach out to info@all4inc.com.
Check out our previous articles on Philadelphia’s Air Toxics Regulations:
