# pennsylvania
DEPARTMENT OF ENVIRONMENTAL PROTECTION SECRETARY 

### April 26, 2013



### Mr. Shawn M. Garvin

- RegionaLAdministrator
_ U.S. Environmental Protection Agency, Region III 1650 Arch Street, Mail Code 3RAOO Philadelphia, PA 19103-2029 Dear Mr. Garvin: 

## APR 30 2013 Division Director (3APOO)



### As requested bythe U.S. Environmental ProtectionAgency (EPA), the Department of Environmental Protection (DEP) is hereby forwarding the enclosed letter submitted by PhiladelphiaAir Management Services (AMS) on April17, 2013. Inthe letter AMS commits to submit, for review by EPA, SIP revisions addressing specific requirements ofreasonably available control technology (RACT) for the 1997 8-hour ozone national ambient air quality standard (NAAQS) as set forth inthe Clean Air Act for sources located in Philadelphia County, Pennsylvania. When DEP receives, from AMS, the complete and approvable SIP revisions specified inthis letter, DEP will submit them to EPA onbehalfofAMS as formal revisions to the Commonwealth ofPennsylvania's SIP. Ifyou have any questions or need any additional information, please contact Joyce E. Epps, Director ofthe Bureau ofAir Quality, by e-mail atjeepps@pa.gov or by telephone at 717.787.9702. Youmay also contact Thomas Huynh, Director for PhiladelphiaAMS, by e-mail at Thomas.huynh@phila.gov or by telephone at 215.685.7584. Sincerely,

# E.**~s top**  erAbruzzo Acting Secretary Enclosure

Rachel Carson State Office Bu ilding 

### I P.O. Box 206 Harrisburg, PA 17105-2063 717.787.2814 Printed on Recycled Paper www.depweb.state.pa.us

# CITY OF PHILADELPHIA

Honorable Shawn M. Garvin Regional Administrator U.S. Environmental Protection Agency, Region III 1650 Arch Street, Mail Code 3RAOO Philadelphia, Pennsylvania 19103-2029 Honorable E. Christopher Abruzzo Acting Secretary Department ofEnvironmental Protection Bureau ofAir Quality Rachel Carson StateOffice Building 

### P.O. Box 2063 Harrisburg, Pennsylvania 17105-2063
DearRegional Administrator and Acting Secretary: DEPARTMENT OF PlJBLJC HEALTH Donald F. Schwarz, MD, MPH Depury Mayor for Health & Opportunity Health Commissioner Nan Feyler, JD, MPH Chief of

Staff Air Management Services Thomas Huynh Director 321 University Avenue, 2nd Floor Philadelphia, PA 19104 Telephone (215) 685-7586 Fax (215)685-7593 Apri117, 2013

The PennsylvaniaDepartment ofEnvirorunenta] Protection (DEP) has submitted to the U.S. Environmental Protection Agency (EPA), on behalfofthe City ofPhiladelphiaDepartment of Public Heatth, AirManagement Services (AMS), various revisions to the Commonwealth of Pennsylvania's State Implementation Plan (SIP) in order to meet the Reasonably Available Control Technology (RACT) requirements for the 1997 8-hour Ozone National Ambient Air Quality Standard (NAAQS) set forth in the Clean Air Act for Philadelphia County. Through this letter, AMS is committingto submit, for EPA's review, revisions to the Commonwealth ofPennsylvania's SIP addressingPhiladelphia County's 8-hour RACT requirements specified below as expeditiously as practicable, butno later than twelve months from the date EPA gives final, conditional approval ofthe 8-hour Ozone RACT SIP for Philadelphia County
. The revisions to the 8-hourOzone RACT SIP for PhiladelphiaCounty

### will consist ofthe following:
• Source-specific RACT determinations for the 8-hour OzoneNAAQS, to be incorporated in operating permits, for the following electric generating units (EGUs) in Philadelphia 

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# ICounty that had previouslyrelied on emissions reductions from EPA's Nitrogen Oxide (NOx) SIP Call Rule:


### o Exelon

- Delaware Station o Exelon

- Richmond Station o Exelon -· Schuylkill Station 

### o - Veolia- Edison Station (formerlyTrigen- Edison Station) 

### o Veolia- Schuylkill Station (formerly Trigen- Schuylkill Station) • Source

-specific RACT determinations for the 8-hour Ozone NAAQS , to be incorporated in operatingpermits, for the following non-EGUs in Philadelphia County:
o PhiladelphiaEnergy Solutions Refinery (formerly Sunoco Refinery) 

### o Kraft Nabisco (formerly Nabisco Biscuit Company) 

### o Temple University, Health Sciences Center 

### o GATX Tem1inals Corporation o Honeywell (fom1erly Sunoco Chemicals, Frankford Plant)
• Certification that the previously adopted source-specific RACT approved byEPA in the Commonwealth ofPennsylvania's SIP under the 1-hourOzone NAAQS for the remaining facilities in Philadelphia County (as listed in 40 CFR 52.2020(d)(l)) continues to adequately represent RACT for 8-hour Ozone NAAQS. _See Final Rule To Implement the 8-Hour Ozone National Ambient Air Quality Standard--Phase 2, 70 Fed. Reg. 71612 (Nov. 29, 2005)
. AMS understands that this commitment will result in a conditional approval by EPA ofthe previously submitted 8-hour Ozone RACT 

### SJP for Philadelphia County. Upon EPA's approval ofthe SIP revisions satisfying the rulemaking commitments, EPA's conditional approval to the 8-hour ozone RACT 

### SIP for Philadelphia Countywill become a full approval. AMS also requests that DEP submit a copy ofthis letter, as well as any future revisions to Philadelphia County's 8-hour Ozone RACT SIP addressing these rulemaking commitments, to EPA on our behalf
. Thank you for your support 

### ofourmission 

### to achieve cleaner air inPhiladelphia County. Should you have any questions, please do not hesitate to contact me at 215-685-7584 or Thomas.huynh@phila
.gov. Sincerely,

Thomas Hu 

### ilh, Director City ofPhiladelphia, Department ofPublic Hea lth Air Management Services 

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Enclosures


### cc: Nan Feyler, ChiefofStaff Patrick O'Neill, Divisional Deputy City 

### Solicitor 

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