DEPARTMENT OF PUBLIC HEALTH 

Donald F. Schwarz, MD, MPH 

Deputy Mayor/or Health & Opportunity 

Health Commissioner 

CITY OF PHILADELPHIA Nan Fcyler, JD, MPH 

ChiefofStalJ 

Ms. Joyce Epps 

Department of Enviromnental Protection 

Bureau of Air Quality 

Rachel Carson Building 

400 Market Street, P. O. Box 8468 

Harrisburg, PA 17105-8468 

Dear Ms. Epps: 

Air Management Services 

Thomas Huynh 

Director 

321 University Avenue, 2nd Floor 

Philadelphia, PA 19104 

Telephone (215) 685-7584 

Fax (215) 685-9451 

May 1,2014 

On December 13,2013 (78 FR 75902), the U.S. Environmental Protection Agency (EPA) 

conditionally approved Philadelphia's 1997 8-hour ozone Reasonably Available Control 

Technology (RACT) demonstration provided in the 2006 and 2010 Pennsylvania State 

Implementation Plan (SIP) revisions, based upon a commitment from Philadelphia Air 

Management Services (AMS) to submit additional SIP revisions to provide source-specific RACT 

determinations for certain major sources of VOC and NOx in Philadelphia and a certification that 

previously adopted source-specific RACT controls approved by EPA in the Pennsylvania's SIP 

under the I-hour ozone National Ambient Air Quality Standards (NAAQS) for the remaining 

sources in Philadelphia Connty (as listed in 40 CFR 52.2020(d)(I)) continue to adequately 

represent RACT for the 1997 8-hour ozone NAAQS. 

To fulfill that commitment, AMS is submitting the 1 st of several SIP revisions to meet the 1997 8-

hour ozone RACT. AMS is providing an updated RACT determination / RACT plan approval for 

seven heaters at Philadelphia Energy Solutions Refining and Marketing LLC (PES). Attached with 

this letter is a CD that contains the following documentation: 

Description FileName 

RACT Statement of Basis PES 7 Heaters -12195 RACT Statement of 

Basis.pdf 

RACT Plan Approval Application PES 7 Heaters - RACT Plan Approval 

Application REDACTED OCR.pdf 

Public Notice in newspaper PES 7 Heaters - Daily News Public Notice.pdf 

Public Notice proof of publication PES 7 Heaters - Daily News Proof Of 

Publication 121213600.pdf 
Public Notice in PA Bulletin PES 7 heaters - PA Bulletin 20131214.pdf 

Notification to neighboring states PES 7 Heaters - Notification to Neighboring 

States.pdf 

Comment response document PES 7 Heaters - Corrunent Response 

Document.pdf 

Public hearing transcript PES 7 heaters - Public Hearing Official 

transcript.pdf 

RACT Plan Aooroval PES 7 Heaters - RACT Plan Aoproval.pdf 

Plan Approval PES 7 Heaters - Plan Approval.pdf 

SIP revision link on AMS website to meet PA SIP revision link on AMS website to meet PA 

ACT 27 ACT 27.txt 

The public comment period for this SIP Revision took place from December 14, 2013 to January 

13,2014. AMS received comments fi'om William O'Sullivan, Director, Division of Air Quality, 

New Jersey Department of Environmental Protection. 

AMS followed all of the applicable procedural requirements of the Commonwealth's laws and 

constitution in conducting and completing the adoption/issuance of the SIP revision. We request 

that the Pennsylvania Department of Environmental Protection approve this revision and forward it 

to EPA Region III with a recommendation for approval. 

Thomas Huynh 

Director 

Cc: IGrit Dalal, P ADEP 

Christina Fernandez, EPA Region III 

Enclosure