UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103

- 2029

DATE: May 5, 2016

SUBJECT: Technical Support Document for the Philadelphia

County, Pennsylvania Reasonably Available Control Technology Under the 19 97 8

- hour Ozone National Ambient Air Quality Standard s

FROM: Emlyn Velez

- Rosa, EIT, Environmental Engineer \ s \

Office of Air Program Planning (3AP30)

TO:

REVIEWED BY: SIP Docket File , EPA

- R03

- OAR

- 2008

- 0603

Cristina Fernandez, Associate Director \ s \ O ffice of Air Program Planning (3AP30)

I. Affected Regulation T he Commonwealth of Pennsylvania (Pennsylvania) submitted to the U.S. Environm ental Protection Agency (EPA ) various revisions to its s tate i mplementation p lan (SIP) affecting Philadelphia Cou nty (Philadelphia) . The SIP revisions pertain to the demonstration that Philadelphia meets the requirements of reasonably available control technology (RACT) for major sources of nitrogen oxides (NOx) and volatile organic compounds (VOC) for the 1997 8

- ho ur ozone n ational a mbient a ir q uality s tandard s (NAAQS) , as set forth in the Clean Air Act (CAA). This technical support document (TSD) provides EPA’s rationale for proposing approval of the aforementioned SIP revisions to satisfy our conditional approval of previous SIP revisions addressing Philadelphia RACT requirements under the 1997 8

- hour ozone NAAQS.

II

. Background A. General Ground level ozone pollution (commonly referred to as smog) is formed when VOC react with NOx in the presence of sunli ght. In order to reduce ozone concentrations in the ambient air, the CAA requires all nonattainment areas to apply control on VOC and NOx emission sources to2

achieve emission reductions. Among effective control measures, RACT controls are a major group f or reducing VOC and NOx emissions from stationary sources.

Since the 1970’s
, EPA has consistently interpreted RACT to mean the lowest emission limit that a particular source is capable of meeting by the application of the control technology that is

reason ably available considering technological and economic feasibility

. 1 Section 172(c)(1) of the CAA provides that SIPs for nonattainment areas must include reasonably available control measures (RACM) for attainment of the NAAQS, including emissions reductio ns from existing sources through adoption of RACT. Section 182(b)(2) and 182(f) (1) of the CAA requires states with moderate
, or w orse , ozone nonattainment areas implement RACT controls on each category of stationary sources covered by a control technique guideline (CTG) document issued by EPA and on all major stationary sources of VOC and NOx emission s located in the area

. 2 Pursuant to section 184 (b) of the CAA, the same requirements for sources of NOx and VOC apply to any areas in an ozone transport r egi on (OTR) established under section 184(a) , therefore including marginal and moderate nonattainment areas as well attainment areas with in an OTR. A single OTR has been established, comprising of 12 eastern states and the District of Columbia (hereafter, “t he OTR”). T he entire Commonwealth of Pennsylvania is part of the OTR.

On July 18, 1997 (62 FR 38856)
, EPA revised the NAAQS for ground

- level ozone, setting it at 0.08 parts per million (ppm) averaged over an 8

- hour time frame

. On April 15 , 2004, EPA i ssued final designations for the 1997 8

- hour ozone NAAQS, which included Philadelphia County as part of the Philadelphia

- Wilmington

- Atlantic City , PA

- NJ

- MD

- DE moderate ozone nonattainment area

. 69 FR 23858, at 23931 ( April 30, 2004). At the same time, EP A published the first phase of its final rule to implement the 1997 8

- h our o zone NAAQS (Phase I Ozone Implementation Rule), in which EPA revoked the previous 1

- hour ozone NAAQS for most areas of the country, effective on June 15, 2005, and established anti

- backsliding principles to transition from implementing the revoked 1

- hour ozone NAAQS to the more protective 1997 8

- hour ozone NAAQS, as codified in 40 CFR 51.905. 3 The nonattainment designation for Philadelphia under the 1997 8

- hour ozone NAAQS, and its location in the OTR, triggered the S tate ’s obligation to submit a SIP revision addressing how it meets the CAA RACT requirements in Philadelphia under the standard.

On March 12, 2008 (73 FR 16436) , EPA significantly strengthened the 8

- hour ozone NAAQS by revising the primary 8

- hour ozone standard to a level of 0.075 ppm. On March 6,

1 See 44 FR 53782 ( September 17, 1979 ) ; EPA’s 1976 memorandum from Roger Strelow, Assistant Administrator for Air and Waste Management to Regional Administrators, “Guidance for Determining Acceptability of SIP Regulations in Non

- attainm ent Areas” (December 9, 1976); and also, 72 FR 20586 at 20610 ( Ap ril 25, 2007).
2 A major source in an ozone nonattainment area is defined as any stationary source that emits or has the potential to emit NOx and VOC emissions above certain applicability th reshold that is based on the classification of the ozone nonattainment area. See “major stationary source” in 40 CFR 51.165.
3 “ Final Rule to Implement the 8

- Hour Ozone National Ambient Air Quality Standard

— Phase 1,” 69 FR 23951 (April 30, 2001).3

2015 (80 FR 12264) , EPA published a final rule for the implementation of the 2008 8

- hour ozone NAAQS, while at the same time revoking the 1997 8

- hour ozone NAAQS, effective on April 6, 2015. 4 Consistent with EPA’s previous approach, the 2008 8

- Hour Ozone Implementation Rule established anti

- backsliding principles to transition from implementing the revoked 1997 8

- hour ozone NAAQS to the 2008 8

- hour ozone NAAQS, as codified in 40 CFR 51.1100. In this rule, EPA clarified that RACT under the 1997 8

- hour ozone NAAQS, among other requirements, continues to apply to a nonattainment area, in accordance with its designation and classification for the 1997 8

- hour ozone NAAQS at the time of the revocation of the standard. Therefore, 1997 8

- hour ozone RACT continues to be an applicable requirement for Philadelphia.

The implementation of RACT controls under the 1997 8

- hour ozone NAAQS is required in Philadelphia for each category of V OC sources covered by a CTG document issued by EPA (i.e., CTG RACT) and all other major stat ionary sources of NOx and VOC (major source RACT) , as defined for a moderate nonattainment area

. Philadelphia was also subject to the CAA RACT requirements under t he 1

- hour ozone NAAQS, as it was designated as part of the Philadelphia

Wilmington

- Trenton, PA

- NJ

- DE

- MD severe ozone nonattainment area under the 1

- hour ozone NAAQS

. See 56 FR 56694, at 56822 (November 6, 1991). As a result, the Pennsylvania Department o f Environment (PADEP) and Philadelphia Air Management Services (AMS) implemented numerous RACT controls in Philadelphia to meet the statutory RACT requirements under this previous standard

. B. EPA’s Requirements under the 1997 8

- hour Ozone RACT In Phas e I Ozone Implementation Rule , EPA provides that a nonattainment area previously designated under the 1

- hour ozone NAAQS remains subject to certain 1

- hour ozone obligations until the area atta ins the 1997 8

- hour ozone NAAQS, such obligations includ e RACT

. Furthermore, 40 CFR 51.905(b) provides that such obligations cannot be removed from a SIP, even if the area is redesignated to attainment for the 1

- hour ozone NAAQS, but must remain in the SIP as applicable requirements or contingency measures, as appropr iate.

On November 29, 2005
, EPA published the second phase to its implementation rule to address nonattainment SIP requirements for the 1997 8

- hour ozone NAAQS (the Phase 2 Ozone Implementation Rule). 5 This rule addressed, among other things, control a nd planning obligations as they apply to nonattainment areas under the 1997 8

- hour ozone NAAQS, including RACT and RACM. In this rule, EPA specifically required that states meet the RACT requirements under the 1997 8

- hour ozone NAAQS, either through a cer tification that previously adopted RACT controls in their SIP revisions approved by EPA under the 1

- hour ozone NAAQS continue to represent adequate RACT control levels for 1997 8

- hour ozone NAAQS attainment

4 “ Imple mentation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements” Final Rule , 80 FR 12264 ( March 6, 2015). 5 “ Final Rule to Implement the 8

- Hour Ozone National Ambient Air Quality Standard

— Phase 2,” 70 FR 71612

- 71705 (November 29, 2005).4

purposes, or through the adoption of new or more stringent regulations that represent RACT control levels

. 6 A certification must be accompanied by appropriate supporting information such as consideration of information received during the public comment period and consideration of new data. This inform ation may supplement existing RACT guidance documents that were developed for the 1

- hour standard, such that the State’s SIP accurately reflects RACT for the 1997 8

- hour ozone standard based on the current availability of technically and economically feasi ble controls. Adoption of new RACT regulations will occur when states have new stationary sources not covered by existing RACT regulations, or when new data or technical information indicates that a previously adopted RACT measure does not represent a new ly available RACT control level. Additionally, states are required under the 1997 ozone NAAQS to submit a negative declaration if there are no sources of NOx and/or VOC emissions in a source category covered by a CTG within the nonattainment area
, in lieu of a certification.

EPA particularly addressed controls for NOx emissions from ele ctric generating units (EGUs) i n the Ph ase 2 Ozone Implementation Rule. EPA determined that the regional NOx emissions reductions that result from either the NOx SIP Call or the Clean Air Interstate Rule ( CAIR) for addressing interstate transport of ozone pollution
, would meet the NOx RACT requirement for EGUs located in states included within the respective geographic regions. Thus, EPA concluded that the states did not n eed to perform a NOx RACT analysis for sources subject to the state ’ s emission cap

- and

- trade program where such program has been adopted by the state and approved by EPA as meeting the NOx SIP Call requirements or, in s tates achieving the CAIR reductions s olely from EGUs, the CAIR NOx requirements.

In November 2008, several parties challenged the Phas e 2 Ozone Implementation Rule, particularly, E PA ’ s determination that compliance by EGUs with the requirements of the NOx SIP and/or CAIR could also be cons trued as compliance with RACT under the 1997 8

- hour ozone NAAQS. As a result of this litigation, the United States Court of Appeals for the District of Columbia Circuit ( D.C. Circuit ) decided that such presumptions and determinations by EPA in the Pha se 2 Ozone Implementation Rule were inconsistent with the statutory requirements of section 172(c)(1) of the CAA. Because region

- wide RACT

- level emissions reductions do not meet the statutory requirement that the reductions be from sources in the nonattainmen t area, the D.C. Circuit found that EPA has not shown that compliance with NOx SIP Call will result in at

6 For more information, s ee the preamble of the final Phase 2 Ozone Implementation Rule for a discussion of EPA’s interpretation of the CAA RACT requirements for the 1997 8

- hour ozone NAAQS, in 70 FR 71652

- 71659 (November 29, 20 05).5

least RACT

- level reductions in emissions from sources within each nonattainment area. See NRDC v. EPA, 571 F.3d 1245 (DC Cir. 2009)

. 7

C

. EPA ’s Conditional Approval for Philadelphia ’s 1997 8

- hour Ozone RACT Demonstration On September 29, 2006, PADEP submitted
, on behalf of AMS
, a SIP revision purporting to address the RACT requirements for Philadelphia under the 1997 8

- hour ozone NAAQS

. The 2006 SIP revision consisted of a RACT demonstration for Philadelphia, i nclud ing (1) a certification that previously adopted RACT regulation s that were approved by EPA in Pennsylvania’s SIP for Philadelphia under the 1

- hour ozone NAAQS continue to represent RACT for the 1997 8

- hour ozone NAAQS implementation purposes; (2) the adoption of f ederally enforceable permits that represent RACT control levels for four major VOC sources; and (3) a negative declaration that certain VOC source categorie s that are cover ed by CTG documents do not exist in Philadelphia

. On August 26, 2008 ( 73 FR 50270 ), EPA published a notice of proposed rulemaking (NPR) proposing approval of the 2006 SIP revision. However, after further evaluation, EPA identified two deficiencies in t he 2006 SIP revision which precluded EPA’s approval. First, the 2006 SIP revision included as RACT certain provisions that relied on the NOx SIP Call, which in light of the 2009 D.C. Circuit decision in NRDC v. EPA regarding the inappropriateness of the N Ox SIP Call as RACT, precluded EPA from approving the 2006 SIP revision. Specifically, the 2006 SIP certified as RACT the following PADEP regulations: 25 Pa Code sections 145.1

- 145.100 (“NOx Budget Trading Program”), 25 Pa Code sections 145.111

- 145.113 ( “Emissions of NOx from Stationary Internal Combustion Engines”), and 25 Pa Code sections 145.141

- 144 (“Emissions of NOx from Cement Manufacturing”). Second, EPA also determined that the Philadelphia 2006 SIP revision did not sufficiently address the sourc e

- specific RACT requirements for 46 major sources of NOx and/or VOC that were previously approved under the 1

- hour ozone NAAQS, per the SIP approved regulation in 25 Pa Code sections 129.91

- 92, which AMS certified as RACT under the 1997 8

- hour ozone NAAQS

. On June 22, 2010, PADEP submitted another RACT SIP revision addressing certain CTG RACT requirements that superseded portions of the RACT demonstration in the 2006 SIP

7 The D.C. Circuit addressed whether reductions from the NOx SIP call could address NOx RACT. The issue as to whether CAIR satisfies NOx RACT for EGUs was not addressed by the D.C. Circuit because the D.C. Circuit had already remanded CAIR to EPA for further analysis at that time. See North Carolina v. EPA, 531 F.3d 896; modified by 550 F.3d 1176 (D.C. Cir. 2008). In subsequent litigation, the rule that EPA promulgated to replace CAIR (i.e., the Cross State Air Pollution Rule or CSAPR) was initially vacated by the D.C. Circuit but upheld by the U.S. Supreme Court. EPA v. EME Homer City Generation, L.P. , 134 S. Ct. 1584 (2014). EPA began implementing CSAPR in January 2015. See 79 FR 71663 (December 3, 2014) (interim final rulemaking issued after D. C. Circuit lifted stay on CSAPR). Thus, EPA decided it would be appropriate to reconsider its prior determination that CAIR could satisfy NOx RACT in light of the earlier decision in NRDC v. EPA. See 79 FR 32892 (June 9, 2014) (proposing removal of prior determination that CAIR could be NOx RACT).6

revision . The 2010 SIP revision consisted of two new CTG regulations, Air Managemen t Regulation (AMR) V section XV ( “Control of Volatile Organic Compounds (VOC) from Marine Vessel Coating Operations”) and AMR V section XVI (“ Synthetic Organic Manufacturing Industry (SOCMI) Air Oxidation, Distillation, and Reactor Processes”), and related amendments to AMR V Section I (“Definitions”), as adopted by AMS on April 26, 2010 effective upon adoption ; and a negative declaration demonstrating that no sources existing in Philadelphia for the CTG source category of natural gas and gasoline processin g plants. The CTG regulations adopted in 2010 superseded source

- specific RACT determinations provided in the 2006 SIP revision, because the new provisions are as, if not more, stringent than those RACT requirements previously submitted in 2006. 8 Addition ally, the 2010 SIP revision clarified that in the 2006 SIP submission AMS had erroneously defined two sources in Philadelphia under the CTG category for natural gas and gasoline processing plants, and for which AMS submitted source

- specific RACT determinat ions in the 2006 SIP revision. For these reasons, EPA determined that the provisions in the 2006 and 2010 SIP revisions were related in addressing Philadelphia’s 1997 8

- hour ozone NAAQS RACT obligation and were not separable for approval purposes as each SIP revision contained provisions addressing RACT obligations.

Pursuant to section 110(k)(4) of the CAA, on April 26, 2013, PADEP submitted, on behalf of AMS, a letter in which AMS committed to submit the SIP revisions addressing the source

specifi c RACT requirements for Philadelphia under the 1997 8

- hour ozone NAAQS , including EGU s that were presumed to rely on the NOx SIP Call provisions to meet RACT

. In the April 26, 2013 letter, AMS identified five sources that since the approval of the 1

- hour ozone source

specific RACT determinations have adopted or will adopt additional controls that it believed represent RACT under the 1997 8

- hour ozone NAAQS, and for which it would submit new

source

- specific RACT determinations: (1) Philadelphia Energy Solu tions Refining and Marketing, LLC (formerly Sunoco Inc. (R&M)

- Philadelphia), (2) Kraft Nabisco (formerly Nabisco Biscuit Co, and presently Mondelez), (3) Temple University

- Health Sciences Campus, (4) GATX Terminals Corporation (presently, Kinder Morgan L iquids terminals, LLC), and (5) Honeywell International

- Frankford Plant (formerly Sunoco Chemicals

– Frankford Plant). Additionally, AMS indicated it would submit source

- specific RACT determinations for five EGU sources in Philadelphia that relied on emi ssions reductions under the NOx SIP Call as RACT including: (1) Exelon Generating Company

– Delaware Station, (2) Exelon Generating Company

– Richmond Station, (3) Exelon Generating Company

– Schuylkill Station, (4) Veolia Energy

– Edison Station (formerly TRIGEN

- Edison Station), and (5) Veolia Energy

– Schuylkill Station (formerly TRIGEN

- Schuylkill Station). AMS needed to submit source

- specific RACT

8 AMR V section XV and AMR V section XVI address EPA’s RACT requirements as specified in the following CTGs: (1) “Control Techniques Guidelines for Shipbuilding and Ship Repair Operations (Surface Coating)” (6 1 FR 44050, August 27, 1996), (2) “Control of Volatile Organic Compound Emissions from Air Oxidation Processes in Synthetic Organic Chemical Manufacturing Industry” (EPA

- 450/3

- 84

- 015, December 1984), and (3) “Control of Volatile Organic Compound Emissions from Reactor Processes and Distillation Operations in Synthetic Organic Chemical Manufacturing Industry” (EPA

- 450/4

- 91

- 031, August 1993).7

determinations or alternative certifications to address RACT for any major NOx sources, such as EGUs, for w hich AMS relied in prior SIP submissions on the NOx SIP Call to address RACT for the 1997 8

- hour ozone NAAQS, because EPA cannot approve as RACT provisions relying on the NOx SIP Call. See NRDC v. EPA, 571 F.3d 1245.

O n J une 19, 2013
, in addition to its withdraw al the previous proposal, EPA proposed conditional approval of the Philadelphia 1997 8

- hour ozone RACT demonstration included in both the 2006 and 2010 RACT SIP revision s , based upon AMS ’s commitment to submit additional SIP revisions to correct th e deficiencies previously identified by EPA

. In the June 19, 2013 proposed conditional approval, EPA proposed that in order to correct deficiencies in the Philadelphia 1997 8

- hour ozone RACT demonstration, AMS needed to provide a source

- specific RACT anal ysis for each major NOx/VOC source subject to 25 Pa Code 129.91

- 92 for which current controls do not currently and adequately represent RACT for the 1997 8

- hour ozone NAAQS, including each of the 10 major NOx and/or VOC sources identified by AMS in the Apr il 26, 2013 letter, or alternatively provide a certification that source

- specific RACT controls for all other major sources of NOx and VOC in Philadelphia previously approved by EPA in Pennsylvania’s SIP for the 1

- hour ozone NAAQS continue to adequately re present RACT for the 1997 8

- hour ozone NAAQS.

On December 13, 2013 (78 FR 75902), EPA finalized its conditional approval of the Philadelphia 1997 8

- hour ozone RACT demonstration , as provided in the 2006 and 2010 SIP revision s , with the conditions that P ennsylvania, on behalf of AMS, submit s additional SIP revisions addressing the deficiencies in the former 2006 RACT SIP revision. As stated in the December 13, 2013 final action, o nce EPA determine s that AMS has satisfied th ese condition s , EPA shall remov e the conditional nature of such approval and the Philadelphia 1997 8

- hour ozone RACT demonstration will receive at that time a full approval status. For a detailed discussion of EPA’s conditional approval of Philadelphia’s 1997 8

- hour ozone RACT demonstr ation and the identified deficiencies of the 2006 SIP revision, see 78 FR 75902 (December 13, 2013) (final action) and 78 FR 36716 ( June 19, 2013) (proposed action).

Based on our previous evaluation of the 2006 and 2010 SIP revisions
, EPA finds that the Philadelphia 1997 8

- hour ozone RACT demonstration as provided in those submittal s adequately

me e t s RACT under the CAA , with exception of the source

- specific requirements in 25 PA Code sections 129.91

- 92 and the NOx SIP Call related provisions in the Penns ylvania SIP in 25 Pa Code sections 145.1

- 145.100, 25 Pa Code sections 145.111

- 145.113, and 25 Pa Code sections 145.141

- 144. EPA f

inds that the certified and recently adopted NO x and VOC regulations provided in the 2006 and 2010 SIP revisions as meeting RA CT under the 1997 8

- hour ozone NAAQS
, are consistent with the latest available information and EPA ’s guidance. EPA specifically finds that the provisions in AMR V sections XV and XVI, submitted as part of the 2010 SIP revision, are as stringent as EPA’s R ACT requirements specified in the applicable8

CTGs. EPA’s evaluation of the 2006 and 2010 SIP revision is provided in the June 19, 2013 proposed conditional approval and related technical support document dated May 22, 2013, and will not be restated here. See 78 FR 36716

.

I II

. Summary of SIP Revisions To satisfy EPA’s conditional approval, PADEP has submitted to EPA, on behalf of AMS, subsequent SIP revisions addressing the source

- specific RACT requirements for major sources in Philadelphia subject to 25 Pa Code 129.91

- 92. On June 27, 2014, February 18, 2015, and April 26, 2016, PADEP submitted to EPA, on behalf of AMS, three separate SIP revisions pertaining to the Philadelphia 1997 8

- hour ozone RACT demonstration (hereafter collectively referred to as “the Philadelphia RACT SIP revisions”). AMS provided documentation in the Philadelphia RACT SIP revisions to support that RACT has been met for all major sources of NOx and/or VOC in Philadelphia, including source

- specific RACT determinations for affec ted emission units at each major source subject to 25 Pa Code 129.91

- 92. 9 Specifically, AMS evaluated a total of 25 major NOx and/or VOC sources in Philadelphia for RACT.

On April 26, 2016, PADEP also submitted a letter, on behalf of AMS, withdrawing f rom the 2006 SIP revision the certification of the Pennsylvania rules related to the NOx SIP Call as 1997 8

- hour ozone RACT, specifically 25 Pa Code sections 145.1

- 145.100, 25 Pa Code sections 145.111

- 145.113, and 25 Pa Code sections 145.141

- 144. In the l etter, PADEP reaffirms that AMS is no longer relying on the SIP approved provisions related to the NOx SIP Call as 1997 8

- hour ozone RACT for any sources in Philadelphia. On May 4 , 2016, EPA submitted a letter accepting PADEP’s request for withdrawal of t hese provisions from the 2006 SIP revision, and acknowledging that this portion of the submittal is no longer pending before EPA for a final action.

The June 27 , 2014 SIP revision consists of a source

- specific RACT determination for certain emissions un its (6 process heaters) at Philadelphia Energy Solutions Refining and Marketing, LLC (PES) . The February 19, 2015 SIP revision addresses RACT requirements for the 25 major sources of NOx and/or VOC in P hiladelphia , including the remaining emissions units in PES that were not addressed o n t he June 27, 2014 SIP revision

. The March 26 , 2016 SIP revision amends the RACT determinations fo r 15 sources that were previously addressed in the February 19, 2015 SIP revision. See Appendix C for EPA ’ s Clarification o n s uperseded documentation i n the 2015 SIP Revision

.

9 The applicable “major source” thresholds for 1997 8

- hour ozone RACT purposes are 50 tons per year (TPY) of VOC and 100 TPY of NOx or greater of potential emissions for each respective pollutant, in light of the moderate ozone classification of Philadelphia for the 1997 8

- hour ozone NAAQS, as well as its location in the OTR.9

In the Philadelphia RACT SIP r evisions
, AMS includes a RACT determination for each major source of NOx and/or VOC in Philadelphia
, documented as RACT technical memorandums. AMS provided a RA CT memorandum for each major NOx and/or VOC source in Philadelphia, including those that are not subject to source

- specific RACT under 25 Pa code 129.91

- 92. The RACT technical memorandums include a discussion of all applicable RACT requirements for the existing emissions units in each major source , including CTG RACT, presumptive RACT requirements, and sourc e

- specific RACT requirements. The CTG RACT requirements are those specified in regulations in the Pennsylvania SIP and are consistent with EPA’s CTGs for the affected source categories. Presumptive RACT requirements are those specified in 25 Pa Code secti on 129.93. 10

Table 1 below lists the 25 major sources of NOx and/or VOC in Philadelphia subject to 1997 8

- hour ozone RACT
, all which were evaluated by AMS in the Philadelphia RACT SIP r evisions

. Table 1 also identifies whether each source is subject to a previous source

- specific RACT determination under the 1

- hour ozone standard and continues to be major for NOx, VOC, or both pollutants under the 1997 8

- hour ozone NAAQS, in addition to listing the types of RACT requirements that apply to the emissions unit at the source. The last column of Table 1 indicates if AMS has adopted new or revised existing source

- specific RACT controls for each major NOx and/or VOC source subject to 25 Pa Code section 129.91

- 92, to meet the CAA requirements under the 1997 8

- hour ozone NAAQS. An evaluation of the Philadelphia RACT SIP r evisions to meet the conditional approval is provided in th e next section of this TSD, in support of EPA’s proposed approval.

Table 1. Major NOx and/or VOC Sources in Philadelphia Subject to 1997 8

- hour ozone RACT

Major Source Plant ID Number 1

- H r

Ozone RACT Source? Major

Source Pollutant Applicable RACT Requirements

CTG Presump

- tive Source

Specific Aker Philadelphia Shi pyard, I nc.

- Philadelphia Naval Business Center 01569 VOC x x

Allied Tube & Conduit Corp. 03363 VOC x x

Cardone Industries Inc.

- Rising Sun Avenue and Whitaker Avenue a 03887/ 0 2287 x VOC x x

10 A n owner or operator of a major NOx sour ce subject to 25 Pa Code 129.91

- 93 may perform a source

- specific RACT evaluation, or elect to alternatively comply with the presumptive NOx emissions limits specified in section 129.93 , when applicable (referred to “presumptive RACT” in this discussion)

.10

Major Source Plant ID Number 1

- H r

Ozone RACT Source? Major

Source Pollutant Applicable RACT Requirements

CTG Presump

- tive Source

Specific
Exelon Generating Company

- Delaware Station 04901 x NOx x x

Exelon Generating Company

- Richmond Station 04903 x NOx x

Exelon Generating Company

- Schuylkill Station 04904 x NOx x x

Exelon Generating Company

- Southwark Station 04905 NOx x

Ho neywell

- Frankford Plant [ formerly, Sunoco Chemical

- Frankford Plant] 01551 x NOx and VOC x x x

Inolex Chemical Company 02059 NOx x

Kinder Morgan Liquids Terminals, LLC [ formerly, GATX Terminals Corp.] 05003 x VOC x x x

MIPC, LLC 05004 VOC x x

Naval Foundry and Propeller Center 09702 NOx x

Naval Sur face Warfare Center, Carderock Division (NSWCCD) 09724 x NOx x x

Newman & Company, Inc. 03489 x NOx x x
PaperWorks Industries, Inc. [ formerly, Jefferson Smurfit, Corp./ Container Corp. of America) 01566 x NOx x

Philadelphia En ergy Solutions

- Refini ng and Marketing, LLC [ formerly, Sunoco Inc. (R&M)

- Philadelphia] 01501 / 01517 x NOx and VOC x x x

Philadelphia Gas Works

Richmond Plant 04922 x NOx x x11

Major Source Plant ID Number 1

- H r

Ozone RACT Source? Major

Source Pollutant Applicable RACT Requirements

CTG Presump

- tive Source

Specific

Philadelphia Prison System 09519 NOx x x

Plain Products Terminals
, LLC [ formerly, Maritank Phil adelphia , Inc. and Exxon Company, USA ] 05013 x VOC x x x

Sunoco Partners Marketing & Terminals L.P.

- Belmont Terminal 01507 VOC x x

Temple

- Health Sciences Campus 08906 x NOx x x

Temple

- Main Campus 08905 NOx x x

University of Pennsylvania 08912 NOx x

Veolia Energy

- Edison Station [ formerly TRIGEN

- Edison Station ] 04902 x NOx x

Veolia Energy

- Schuylkill Station [TRIGEN

Schuylkill Station ] / Grays Ferry Cogeneration Partnership / Veolia

- Energy Efficiency
, LLC b 04942 / 04944 / 10459 x NOx x

a Formerly
, Cardone owned various adjacent facilities, from which two facilities were subject to source

- specific RACT under the 1

- hour ozone standard. The f acilities have two separate source

- specific RACT determinations approved in the Pennsylv ania SIP under the 1

- hour ozone standard, corresponding to PLIDs 0 3887 and 0 2237. After 1

- hour RACT, various adjacent facilities owned by Cardone were aggregated and evaluated for RACT as one major source. b Gray Ferry Cogeneration Plant, Veolia Schuylk ill and Veolia Energy Efficiency have been aggregated as a single major sour ce after the 1

- hour RACT determination. AMS submitted RACT documentation for each facility separately, although considering RACT applicability as a single major source of NOx.

I V. EPA’s Evaluation of SIP Revisions AMS submitted RACT technical memorandums for all major NOx/VOC sources in Philadelphia. The technical memorandums included in the Philadelphia RACT SIP revisions address how each major source of NOx and/or VOC in Ph iladelphia is complying with RACT under the 1997 8

- hour ozone NAAQS , including source

- specific RACT determinations for affected emissions units in each major source subject to 25 Pa Code sections 129.91

- 92

. EPA has reviewed all documentation submitted by P ADEP, on behalf of AMS, supporting its12

conclusion it has addressed its RACT obligations under the 1997 8

- hour ozone NAAQS for Philadelphia
, including the information listed in Appendix B attached to this TSD. EPA’s evaluation of the Philadelphia RACT SIP r e visions , as provided in this section, focuses on the

source

- specific RACT determinations prepar ed by AMS for 16 major sources , in order to satisfy the December 15, 2013 conditional approval. EPA has also evaluated the revisions submitted to the previous RACT determination for Cardone Industries Inc. , as summarized in section IV

- B of this TSD

.

A. Source

- Specific RACT Determinations under the 1997 8

- H our Ozone NAAQS The source

- specific RACT determination s submitted by AMS consis t of an evaluation of all reasonabl y available controls at this time for each affected emissions unit, resulting in AMS determination of w hat specific control requirements, if any, satisfy RACT for that particular unit

. For sources subject to source

- specific RACT determinations approved for the 1

- hour ozone NAAQS , AMS evaluated new or additional controls for each affected emissions unit
, re sulting in either a certification that previously adopted RACT controls continue to adequately represent RACT for the 1997 8

- hour NAAQS, or alternatively the adoption of new or more stringent controls as determined to represent RACT for the 1997 8

- hour NAA QS (i.e., a new RACT determination) . For sources newly subject to RACT, AMS evaluated new or additional controls for each affected emissions unit, resulting i n adoption of controls that were determined to be reasonable to satisfy RACT under the 1997 8

- hou r ozone NAAQS.

The adoption of new or additional controls or the revisions to exi s ting controls as RACT were specified as requirements in new or revised federally enforceable permits (hereafter “ RACT permits ”) issued by AMS for the source

. The new or r evised RACT Permit s have been submitted as part of the Philadelphia RACT SIP revisions for EPA’s approval in the Pennsylvania SIP under 40 CFR 52.2020(d)(1)

. For sources subject to previous RACT determinations specified in RACT permits under 40 CFR 52.202 0(d)(1) for which AMS is revising or adopting additional source

- specific controls, the revised RACT permits, once approved by EPA, will supersede those permits currently in the SIP.

AMS identified 16 major sources in Philadelphia that are subject to Penns ylvania’s source

specific RACT requirements to meet RACT under the 1997 8

- hour ozone NAAQS , as summarized in Table 2 below, including 1 4 major sources subject to previous source

- specific RACT determinations and 2 major sources newly subject to source

- speci fic RACT. As explained earlier, EPA’s December 13, 2013 conditional approval required AMS to submit

source

- specific RACT det erminations for ten major sources of NOx and/or VOC in Philadelphia
, in addition to a certification that source

- specific RACT controls approved under the 1

- hour ozone NAAQS in the Pennsylvania SIP for major sources in Philadelphia
, continue to adequately

r epresent RACT for the 1997 8

- hour ozone NAAQS. AMS submitted source

- specific RACT determinations for nine of the ten major sources identified in EPA’s conditional approval.13

Precisely, AMS did not submit the required source

- specific RACT determination for Kraft Nabisco (formerly Nabisco Biscuit Co, and presently Mondelez), because this source is no longer considered a major source of NOx and VOC for 1997 8

- hour ozone RACT. See section IV

- C of this TSD for further discussion on Mondelez.

Table 2

. Major NOx and/or VOC Sources in Philadelphia Subject to Source

- Specific RACT under the 1997 8

- hour O zone NAAQS

Major Source Plant ID Number 1

- H r

Ozone RACT Source? Major

Source Pollutant New or Revised

Source

- Specific Determination ? (“Yes” or “No” ) New or Revised

RACT Permit (Effective Date)

Exelon Generating Company

- Delaware Station 04901 x NOx No

-

Exelon Generating Company

- Richmond Station 04903 x NOx Yes PA

- 51

- 4903 ( 02 / 09 / 16 )
Exelon Generating Company

- Schuylkill Station 04904 x NOx No

-
Honeywell

- Frankford Plant [ formerly, Sunoco Chemical

- Frankford Plant] 01551 x NOx and VOC Yes PA

- 51

- 1151 (02/09/16)
Kinder Morgan Liquids Terminals, LLC [ formerly, GATX Terminals Corp.] 05003 x VOC Yes PA

- 51

- 5003 (02/09/16)

Naval Surf

ace Warfare Center, Carderock Division (NSWCCD) 09724 x NOx Yes PA

- 51

- 9724 (02/09/16)

Newman & Company, Inc. 03489 x NOx No

-
PaperWorks Industries, Inc. [ formerly, Jefferson Smurfit, Corp./ Container Corp. of America) 01566 x NOx Yes PA

- 51

- 1566 (01/09/ 15)
Philadelphia En ergy Solutions

- Refining and Marketing, LLC [ formerly, Sunoco Inc. (R&M)

- Philadelphia] 01501 / 01517 x NOx and VOC Yes PA

- 51

- 01501 and PA

- 51

- 01517 (0 2 /09/1 6 )

Philadelphia Gas Works

Richmond Plant 04922 x NOx Yes PA

- 51

- 4922 (01/09/15)

Philadelphia Prison System 09519 NOx Yes PA

- 51

- 9519 (02/09/16)14

Major Source Plant ID Number 1

- H r

Ozone RACT Source? Major

Source Pollutant New or Revised

Source

- Specific Determination ? (“Yes” or “No” ) New or Revised

RACT Permit (Effective Date)

Plain Products Terminals
, LLC [ formerly, Maritank Philadelphia , Inc. and Exxon Company, USA ] 05013 x VOC Yes PA

- 51

- 05013 (02/09/16)

Temple

- Health Sciences Campus 08906 x NOx Yes PA

- 51

- 890 6 (01/09/15)

Temple

- Main Campus 08905 NOx Yes PA

- 51

- 8905 (01/09/15)

Veolia Energy

- Edison Station [ formerly TRIGEN

- Edison Station ] 04902 x NOx Yes PA

- 51

- 4902 (01/09/15) Veolia Energy

- Schuylkill Station [TRIGEN

Schuylkill Station] / Grays Ferr y Cogeneration Partnership / Veolia Energy Efficiency, LLC a 04942 / 04944 / 10459 x NOx Yes PA

- 51

- 4942 (02/09/16) / PA

- 51

- 4944 (01/09 /15) / PA

- 51

- 10459 (01/09/15)

a Gray s Ferry Cogeneration Plant, Veolia Schuylkill and Veolia Energy Efficiency have been aggregated as a single major sour ce after the 1

- hour RACT determination. AMS submitted RACT documentation for each facility separately, although considering RACT applicability as a single major source of NOx.
A summary of the source

- specific R ACT determinations submitted by AMS is provided below for each source . For simplicity, the following discussion is provided separately for sources previously subject to source

- specific RACT and for new sources subject to source

specific RACT.

A

- 1. So urce s with Previous Source

- Specific RACT Determinations 1. Exelon Generating Company

- Delaware Station ( PLID

- 04901) Exelon Generatin g Company

- Delaware Station (Exelon

- Delaware) is as an electric generating utility located at 1325 North Beach Street, Phil adelphia, P ennsylvania . The fa cility is a major source of NOx and operates four combustion turbines firing number 2 fuel oil, three rated 15.5 megawatt ( MW ) and one rated 17.5 MW.

EPA’s December 13, 2013 conditional approval required AMS to submit a sour ce

- specific RACT determination for this source , as AMS had indicated it was relying on the NOx SIP Call for RACT compliance. AMS has clarified that this source was previously evaluated under the 1

- hour ozone standard and has been subject to a source

- speci fic RACT determination under 25 Pa Code sections 129.91

- 9 2 . The 1

- hour ozone RACT determination for Exelon

- Delaware is specified in RACT P ermit PA

- 51

- 490 1 , effective on July 11, 2001 and approved in the SIP on15

October 3 1 , 2001. 66 FR 54947 . EPA confirm s that the 1

- hour RACT determination for Exelon

- Delaware does not rely on the presumption that compliance with the NOx SIP Call constituted RACT for any of its emissions units . AMS has re

- evaluated RACT for each emissions unit to ensure compliance with 2 5 Pa Code sections 129.91

- 9 2

.

At the time of the 1

- hour RACT determination, the facility also operated three boilers and one emergency generator that were subject to source

- specific RACT requirements, but have permanently been r etired

. As part of the 1

- hour RACT, each combustion turbine accepted a 5 percent ( % ) annual capacity factor in order to comply with the presumptive RACT requirement of 25 Pa Code section 129.93(c)(5) to install, maintain, and operate each unit in accordance with manufacturers spe cifications. The capacity factors for each turbine were incorporated into the RACT Permit and approved into the SIP. EPA notes that these additional restrictions (i.e., capacity factors) were required to be adopted and made permanent and f ederally enforc eable, in order for the combustion turbines to be allowed to comply with 25 Pa Code section 129.93(c)(5). At the time of the 1

- hour ozone RACT, AMS elected to adopt these restrictions by approving them as source

- specific requirements in the RACT permit an d submitted for approval into the SIP . At this time
, AMS is certifying that these source

- specific requirements determined as RACT under the 1

- hour ozone standard continue to represent RACT under the 1997 8

- hour

ozone NAAQS for E xelon

- Delaware.

EPA fi nds that the RACT determination provided by AMS is reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits. Thus, EPA finds that the source

- specific RACT controls currently approved in the SIP adequately meet RACT under the 1997 8

- hour ozone NAAQS for Exelon

- Delaware.

2. Exelon Generating Company

- Richmond Station (PLID

- 04903) Exelon Generation Company

- Richmond Station (Exelon

- Richmond) is as an electric generating utility located at 3901 North Delaware Avenue, Philadelphia, P ennsylvania

. The facility is a major source of NOx
, operating two simple cycle combustion turbines, each rated 66 MW (or 838 million British thermal units per hour (MMBTU/hr) of heat input) and firing number 2 f

uel oil.

EPA’s December 13, 2013 conditional approval required AMS to submit a source

- specific RACT determination for this source , as AMS had indicated it was relying on the NOx SIP Call for RACT compliance. AMS has clarified that this source was previ ously evaluated under the 1

- hour ozone standard and has been subject to a source

- specific RACT determination under 25 Pa Code sections 129.91

- 92. The 1

- hour ozone RACT determination for Ex elon

- Richmond is specified in RACT P ermit PA

- 51

- 4903, effective on July 11, 2001 and approved in the SIP on October 30, 2001. 66 FR 54704. EPA confirms that the 1

- hour RACT determination for Exelon

- Richmond does not rely on the presumption that compliance with the NOx SIP Call16

constituted RACT for any of its emission unit s . However, AMS has re

- evaluated RACT for each emissions unit to ensure compliance with 25 Pa Code sections 129.91

- 92.

A NOx emissions limit of 0 .70 pounds per heat input rate in million British Thermal Units (lb/MMBTU) and a 15% capacity factor li mit (based on net generation) were previously determined as RACT for each combustion turbine under the 1

- hour ozone NAAQS and continue to be applicable for the emissions unit s

. AMS evaluated additional controls for the combustion turbines, including water

/steam injection, selective catalytic reduction (SCR), and conversion to natural gas. AMS determined that these additional controls are not technically and/or economically reasonable for the combustion turbines and thus do not constitute RACT. Specifical ly, AMS determined that switching to natural gas was unreasonable as there is no access to a gas pipeline. AMS is proposing to strengthen the applicable NOx emission limit by revising it from 0.70 to 0.68 lb/MMBTU, based on current stack testing data. EP A expects this revision to result in additional potential NOx reductions , in terms of pounds per hour (lb/hr) and tons per year (tpy) , as shown in Table 3 below

.

Table 3

. Summary of Proposed RACT Revisions for Combustion Turbines at Exelon

- Ric hmond Approved RACT Requirements Proposed Revisions to RACT Requirements Heat Output Rating (MW) a Capacity

Factor (%) b NOx

emissions rate (lb/ MMBTU) Potential

NOx Emissions (lb/hr) Potential

NOx Emissions (tpy) Capacity

Factor (%) b NOx

emissions
rate (lb/ MMBTU) Potential

NOx Emissions (lb/hr) Potential

NOx Emissions (tpy) 66 15 0.70* 157.5 103.5 15 0.68* 153.0 100.5 * Denotes f

ederally enforceable limits.

a Conversion factor is 1 MW

- hr = 3.4 095 million British thermal unit ( MMBTU )
b Based on net generation

AMS determined that these revisions to the 1

- hour ozone RACT determination represent RACT under the 1997 8

- hour ozone NAAQS

. The revised source

- specific RACT requirements for Exelon

- Richmond have been incorporated in the revised RACT Permit P A

- 51

- 4903, effective in February 9, 2016 , and submitted for approval into the SIP to replace the previously approved RACT P ermit dated July 11, 2001

. EPA finds that the RACT determination provided by AMS is reasonable and appropriately considered tec hnically and economically feasible controls while setting lowest achievable limits. Thus, EPA finds that the proposed source

- specific RACT controls adequately meet RACT under the 1997 8

- hour ozone NAAQS for Exelon

- Richmond.

3. Exelon Generation Company

- S chuylkill Station ( PLID 04904) Exelon Generation Company

- Schuylkill Station (Exelon

- Schuylkill) is as an electric utility located at 2800 Christian Street , Philadelphia, P ennsylvania . The facility is a major source of17

NOx and only contains as NOx emissi ons units two simple cycle combustion turbines, one with heat output rating of 68 MW ( or 233 MMBTU/hr of heat input) and another with heat output rating of 83 MW ( or 284 MMBTU/hr of heat input ), both firing number 2 fuel oil and kerosene; and an emergency generator rated 2.75 MW and firing number 2 fuel oil or kerosene

.

EPA’s December 13, 2013 conditional approval required AMS to submit a source

- specific RACT determination for this source , as AMS had indicated it was relying on the NOx SIP Call for RACT co mpliance. AMS has clarified that this source was previously evaluated under the 1

- hour ozone standard and has been subject to a source

- specific RACT determination under 25 Pa Code sections 129.91

- 92. The 1

- hour ozone RACT determination for Exel on

- Schuyl kill is specified in RACT P ermit PA

- 51

- 4904, effective on July 11, 2001 and approved in the SIP on October 30, 2001. 66 FR 54704. EPA confirms that the 1

- hour RACT determination for Exelon

- Schuylkill does not rely on the presumption that compliance with the NOx SIP Call constituted RACT for any of its emissions units . AMS has re

- evaluated RACT for each emissions unit to ensure compliance with 25 Pa Code sections 129.91

- 92.

At the time of the 1

- hour RACT determination, the facility also operated a boi ler with 1530 MMBTU/hr and firing number 6 and number 3 fuel oils, but it was permanently retired in 2012. As part of the 1

- hour RACT, each combustion turbine accepted a 5% annual capacity factor in order to comply with the presumptive RACT requirement o f 25 Pa Code section 129.93(c)(5) to install, maintain, and operate each unit in accordance with manufacturers specifications

. Also as a result of the 1

- hour RACT determination, the emergency generator is subject to a restriction in hours of operation of 500 hours per 12

- month rolling average, in order to comply with the presumptive RACT requirement of 25 Pa Code section 129.93(c)(5). Both restrictions for each turbine and the emergency generator were incorporated into the RACT Permit and approved into th e SIP. EPA notes that these additional restrictions (i.e., capacity factors and limit in hours of operation) were required to be adopted and made permanent and f ederally enforceable, in order for the combustion turbines to be allowed to comply with 25 Pa Code section 129.93(c)(5). At the time of the 1

- hour RACT, AMS elected to adopt these restrictions by submitting them as

source

- specific requirements in the RACT permit for approv al into the SIP.

At this time, AMS is certifying that these source

- specif ic requirements in addition to the presumptive requirements determined as RACT under the 1

- hour ozone standard continue to represent RACT under the 1997 8

- hour ozone for Exelon

- Schuylkill

. EPA finds that the RACT determination provided by AMS is reaso nable and appropriately considered technically and economically feasible controls while setting lowest achievable limits. Thus, EPA finds that the proposed source

- specific RACT controls adequately meet RACT under the 1997 8

- hour ozone NAAQS for Exelon

- Sc huylkill.18

4. Honeywell International

- Frankford Plant (formerly, Sunoco Chemical

- Frankford

Plant (PLID

- 01551) Honeywell International

- Frankford Plant (Honeywell) is a chemical manufacturing facility located at 4700 Bermuda Street , Philadelphia, P ennsylvan ia . The facility is a major source of both NOx and VOC and is subject to a 1

- hour ozone RACT determination under its former name, Sunoco Chemicals

- Frankford Plant, specified in RACT P ermit PA

- 51

- 1551 , effective on July 27, 1999 and approved into the SIP on October 30, 2001. 66 FR 54710

. EPA’s December 13, 2013 conditional approval required AMS to submit a source

- specific RACT determination for Honeywell, as AMS had indicated the facility has adopted or will adopt additional controls after the 1

- hour RAC T determination that should represent RACT under the 1997 8

- hour ozone NAAQS

. Honeywell contains the following NOx emissions units : Two 260 MMBTU/hr boilers firing waste phenol residue , natural gas, or number 6 fuel oil (Boilers #1 and #2) ; a 381 MMBT U/hr boiler firing natural gas or number 6 fuel oil (Boiler #3) ; a smaller boiler located at the barge loading facility with a heat input rating of less than 20 MMBTU/hr ( b arge l oading b oiler ) ; six emergency generators firing diesel; and two emergency fire pumps firing diesel. The source contains the following VOC emission units: Distillation columns, oxidation processes, and
reactors used in manufacturing organic synthetic organic chemicals , barge loading operations,
t ruck, rail and drum loading
, rail ca r cleaning, various s torage tanks, wastewater treatment plant s , and VOC fugitive emissions from equipment leaks (pumps, valves, flanges, compressors, pressure relief valves, and rupture disks)

.

The barge loading boiler , the six emergency generators, and the two emergency fire pumps are subject to the presumptive RACT requirements of 25 Pa Code section 129.93 (c) . The

o xidation processes, reactors, distillation columns , all storage tanks (with the exception of VT

609 and VT

- 610), and fugitive emissions ar e covered under CTG regulations approved into the Pennsylvania’s SIP

. Specifically, the oxidation processes, reactor and distillation columns are subject to AMR V Section XVI; the majority of the storage tanks are subject to 25 Pa Code section 129.56 or 1 29.57 (based on storage capacity); and the fugitive emissions are subject to AMR V section XIII. AMS has previously found that these requirements continue to adequately represent RACT under the 1997 8

- hour ozone NAAQS for these sources

.

Source

- specific R ACT requirements were approved under the 1

- hour ozone RACT determination for Boilers #1, #2
, and #3, the barge loading operations , rail car cleaning, two storage tanks (VT

- 609 and VT

- 610), and the wastewater treatment plants. As provided in the SIP approv ed RACT Permit , the source is not allowed to load from or to barges any VOC with a vapor pressure in excess of 1.5 psia at 20 degrees Celsius of temperature

. This restriction results in potential VOC emissions of only 4.2 tpy. In the RACT Permit , the VOC emissions from rail car cleaning are limited to 2.7 tons per 12

- month rolling period. Because the potential VOC19

emission s from the barge loading operations and the rail car cleaning ar e small with these restrictions , AMS certif

ies that the 1

- hour ozone R ACT requirements approved in the SIP continue to adequately represent 1997 8

- hour ozone RACT for these emissions units

.
Per the SIP approved RACT Permit , the source is also required to install and maintain internal floating roofs on tanks VT 609

- and VT

- 6 10. The tanks currently store phenol and wastewater, both VOCs with vapor pressures of less than 1.5 psia. EPA notes that there are no CTG regulations in Pennsylvania for storage tanks that contain VOCs with such small vapor pressures. The RACT Permit a lso requires the source to operate a thermal oxidizer to control VOC emissions from the air stripper at the wastewater facility, with a destruction efficiency of 95% or greater. AMS indicates that in light of the required control, the potential VOC emissi on from the wastewater facility is 1.6 tpy. Absent any additional information regarding regulation of these sources, AMS determines that the 1

- hour ozone RACT requirements approved in the SIP continue to a dequately represent 1997 8

- hour ozone RACT for the tanks.

The only source not previously addressed by the 1

- hour ozone source

- specific RACT determination or covered by presumptive or CTG RACT requirements is th e truck, rail and drum loading. Because the potential VOC emissions from truck, rail and drum loading are very small (1.6 tpy ) and thus considered “de minimis” , AMS determined that no controls are reasonable for this emissions unit . Th us , RACT for truck, rail and drum loading under the 1997 8

- hour ozone NAAQS is no controls.

AMS has evaluated a vailable controls for Boilers #1, #2, and #3 , which are subject to source

specific RACT

. Boilers #1 and #2 are subject to the following NOx RACT requirements per the 1

- hour RACT determination : To burn phenol residue to a minimum of 51% of heat input valu e (in terms of BTU); NOx emissions for each boiler are limited to 0.35 lb/MMBTU; d uring ozone season (May 1 st

– September 30 th of any given year), the boilers are required to only burn natural gas and phenol residue
, except if there is a natural gas emerge ncy or testing, at which times number 6 fuel oil may be used; combined NOx emissions are limited to 272 tpy ; and the source is required to perform annual combustion tune

- up on each boiler at a minimum as specified in 25 Pa Code section 129.93(b)(2)

- ( 3 ).

Per a f ederally enforceable consent decree, EPA and other air permitting agencies required the source to eliminate number 6 fuel oil burning in Boilers #1 and #2, except during natural gas curtailments, losses of supply, and during stack test programs. 11 As a result, AMS issued in 2013 a permit to update the relevant RACT requirements to extend the restriction of number 6 oil burning to apply throughout the year, rather than only during ozone season. See Plan Approval No. 07163 dated January 23, 2013. Si nce t he number 6 fuel oil restriction is more stringent than

11 Referring to the S econd Amendment to a Consent Decree between EPA, several states, the City of Philadelphia, and Sunoco, Inc, the previous owner of the Frankford plant. (Civil Action No.05

- 02866).20

the SIP approved RACT limit for number 6 oil burning on Boilers #1 and #2
, AMS considered this restriction in evaluating additional controls for RACT.

AMS evaluated the feasibility of the foll owing available NOx controls on Boilers #1 and #2: SCR, selective non

- catalytic reduction ( SNCR )
, low NOx burner ( LNB )
, ultra

- low NOx burner ( ULNB ) , switching to natural gas as fuel, flue gas recirculation ( FGR ) , and staged combustion air (SCA). AMS dete rmined each of the controls to be technically infeasible and thus do not represent RACT at this time for Boilers #1 and #2. Particularly, AMS found that the operation of ULNB, LNB, FGR & SCA would prevent compliance of the boilers with an existing limit o f carbon monoxide, in addition to impeding proper combustion of waste phenol as a fuel.

AMS is determining th at th e newer number 6 oil restriction adequately meet s RACT for Boilers #1 and # 2 , and thus is adopting such restriction in replacement of the o zone season restriction for number 6 fuel oil that is currently approved as RACT

. AMS finds that the current NOx RACT limit of 0.35 lb/MMBTU represents the NOx emissions from the boilers when combusti ng number 6 fuel oil
, thus AMS proposes this RACT NOx l imit specifically for number 6 fuel oil. Alternatively, w hen burning natural gas, waste phenol, or combination of these fuels, AMS finds that a NOx emissions limit of 0.28 lb/MMBTU represents the lowest achievable emissions rate for Boilers #1 and #2 for these fuels
, based on stack test ing data , and thus is determining this NOx emissions limit as meeting RACT

. AMS finds that the existing combined annual NOx emissions limit of 272 tpy and the requirement to perform annual combustion tun e

up as specified in 25 Pa Code section s 129.93(b)(2)

- ( 3 ) continue to meet RACT.

AMS explained that the source has been recently having a difficult time producing sufficient waste phenol to meet the minimum 51% heat input limit, and thus AMS is proposing to remove from the SIP the phenol restriction. Since number 6 fuel oil has been almost completely restricted, the potential NOx emissions from the boilers have already been reduced. T he highest NOx emissions expected from the boilers at this time would be fro m waste pheno l combustion

. R emoving the phenol waste restriction would provide the source the flexibility to produce less phenol waste and increase its reliance on natural gas on Boilers #1 and #2 , a less NOx emitting fuel, inherently resulting in greater NOx reductio ns. Additionally, the comb ined NOx emissions limit for both boilers contin ues to be the most stringent requirement ensuring the lowest achievable emissions level based on reasonably available controls

.

Table 4 below , as provided in AMS technical memora ndum, pr esent s a comparison of NOx emissions based on revisions to RACT requirements. Based on this comparison, AMS concluded that the proposed modifications will result at least in the same level of NOx emissions from both boilers. EPA finds AMS’ demons tration adequate and finds that the proposed revisions for Boilers #1 and #2
, removing the phenol waste restriction and the change in number 6 combustion
, will result in equivalent or greater reduced potential NOx emissions, and thus21

should not interfere w ith attainment of the NAAQS or any statutory requirement, pursuant to section 110(l) of the CAA

Table 4

. Summary of Proposed RACT Revisions for Boilers #1 and #2 at Honeywell

* Denotes f

ederally enforceable limits.

a Potential emissions for the 1

- hour RACT scenario are b ased on the 51% heat input limit for phenol and assuming 49% heat input used for number 6 fuel oil and operating boilers at full capacity.
b Potential emissions for the 8

- hour RACT scenario are based in the assumptions of phenol burning and operati on of b oilers at full capacity.

Boiler #3
, with 381 MMBTU/hr heat input rating and firing natural gas or number 6 fuel oil, is subject to the following source

- specific requirements as specified in the SIP approved RACT Permit : O peration and maintenance of LNB , combustion tun e

- up , and a NOx emissions limit of 0.3 lb/MMBTU. AMS explained that the RACT Permit does not reflect the control that has been in place to meet the RACT NOx emission limit of 0.3 lb/MMBTU . The facility proposed in 1995 to achieve the NOx limit of 0.3 lb/MMBTU by installing and operating LNB and “wallports

. ” T he SIP approved RACT Permit ( PA

- 51

- 1551 dated July 27, 1999 ) mistakenly excluded the requirement to maintain and operate the wall ports in addition of the LNB . AMS has confirmed that the facility install ed the wall ports along with the LNBs at the time of the 1

- hour RACT determination and both controls have been operated in order to comply with the NOx RACT limit. AMS at this time determines that the SIP approved RACT p ermit should b e revised to reflect the correct control in place

.

P er the f ederally enforceable consent decree described above , Boiler #3 is also no longer allowed to combust number 6 fuel oil, except during natural gas curtailments, losses of supply, and during stack t est programs. 12 AMS evalu ated as RACT th e installation and operation of additional controls for Boiler # 3 , including water/steam injection, ULNB, SNCR, SCR , FGR, ULNB with FGR , and staged combustion air . AMS found these controls to be technically and/or

e conomically unreasonable, and thus do not represent RACT at this time for Boiler #3.

12 Referring to the Second Amendment to a Consent Decree be tween EPA, several states, the City of Philadelphia, and Sunoco, Inc.
, the previous owner of the Frankford plant (Civil Action No.05

- 02866). Approved RACT Requirements a Proposed Revisions to RACT Requirements b

Hea t Input (MMBTU/ hr) Fuel NOx emissions rate (lb/ MMBTU) Heat Input

Basis (%) Annual

NOx Emissions (tpy) NOx

emissions rate (lb/ MMBTU) Annual

NOx Emissions (tpy) 260 Phenol (alone or combined with

Natural Gas) 0.28 51* 162.6 0.28* 318. 9

No. 6 Oil 0.35* 4 9 195.3 0.35*

- Natural Gas ( only ) 0.18

- - 0.18

- Maximum NOx Emissions per Boiler 357.9

- 318. 9 Combined NOx Emissions (Both Boilers) 272 .0 *

- 272 .0 *22

AMS is adopting the number 6 oil restriction as RACT, as it represents a more stringent level of control than currently approved in the SIP for Boilers #3. AMS finds t hat the current RACT limit of 0.3 lb/MMBTU represents the NOx emissions from the boiler when combusting number 6 fuel oil, thus AMS proposes this RACT limit to apply to the boiler when allowed to burn number 6 fuel oil. AMS determine s that the NOx emissio ns from Boiler #3 when burning natural gas should be limited to 0. 12 lb/MMBTU as RACT, based on stack testing data supporting this rate as lowest achievable by operation of existing controls

. In addit i on, AMS is clarifying the control requirement to inclu de the operation of “wall ports” in combination with LNB. AMS determines that altogether these requirements meet RACT under the 1997 8

- hour ozone NAAQS for Boiler #3

.

Table 5

. Summary of Proposed RACT Revisions for Boiler #3 at Honeywell

Approved RACT R equirements Proposed Revisions to RACT Requirements Heat Input Rating ( MMBTU/ hr ) NOx

emissions rate (lb/ MMBTU) Potential

NOx Emissions (lb/hr) Potential

NOx Emissions (tpy) NOx

emissions rate (lb/ MMBTU) Potential

NOx Emissions (lb/hr) a Potential

NOx Emissions (tpy) a 381 0. 3 0* 114.3 500.6 0. 12 * (gas) 0.30* (oil) 45.7 200.2

* Denotes f

ederally enforceable limits.

a Since number 6 oil burning has been restricted in most instances, the estimated potential NOx emissions for the proposed RACT revisions is based on burning of natural gas as primary fuel.
AMS determined the requirements discussed above to represent NOx RACT under the 1997 8

- hour ozone NAAQS for Boilers #1, #2, and #3 and, thus, is requesting to update the SIP approved RACT determination to incorporate them accordingly. The r evised source

- specific RACT requirements for Honeywell have been incorporated in the revised RACT Permit PA

- 51

- 1151, effective in February 9, 2016 , and submitted for approval into the SIP.

EPA finds that the RACT det ermination provided by AMS is reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits. Thus, EPA finds that the proposed source

- specif ic RACT controls adequately meet RACT under the 199 7 8

- hour ozone NAAQS for Honeywell. EPA also finds that the proposed revisions to meet RACT will result in equivalent if not additional reductions of NOx emissions and thus should not interfere with any applicable requirement concerning attainment or reas onable further progress with the NAAQS or interfere with other applicable CAA requirement

.23

5. Kinder Morgan Liquids Terminal, LLC (formerly, GATX Terminals Corp.) (PLID

05003) Kinder Morgan Liquids Terminals, LLC (Kinder Morgan) is a bulk liquid storage a nd distribution facility located at 3300 North Delaware Ave nue , Philadelphia, P ennsylvania

. The facility is a major source of VOC and is subject to a 1

- hour ozone RACT determination under its former name, GATX Terminals Corporation, specified in RACT Perm it PA

- 51

- 5003 , effective on May 29, 1995 and approved into the SIP on October 31, 2001. 66 FR 54936. EPA’s December 13, 2013 conditional approval required AMS to submit a source

- specific RACT determination for Kinder Morgan, as AMS had indicated the sour ce has adopted or will adopt additional controls after the 1

- hour RACT determination that should represent RACT under the 1997 8

- hour ozone NAAQS

. Kinder Morgan stores a variety of petroleum chemicals that are transported into or out of the facility by sh ip or b arge (marine) , rail car, or tank trucks and then the chemicals are stored in fixed roof and internal floating roof storage tanks. VOC emissions units at the source include
tan k truck and rail car loading, marine vessel loading (two berths)
, a large number of storage tanks, two 48 HP air compressors, a 490 HP emergency generator (Emergency Generator #1)
, VOC fugitive emissions from process piping pumps, valves, and flanges, and some other insigni ficant sources. There are also two NOx emissions units subject to presumptive RACT
, a 12.6 MMBTU/hr boiler (Boiler #1) and a 13.4 MMBTU/hr (Boiler #2)

.
The 1

- hour ozone RACT determination specified source

- specific requirements for the tank truck and rail car loading, the marine vessel loading, and the VOC fugitive emissions. AMS notes that the re was a 6.7 MMBTU/hr boiler in operation at the time of the 1

- hour RACT determination that was removed and replaced by Boiler #2 (13.4 MMBTU/hr)

. The emergency generators and the boilers are subject to presumptive r equirements of 25 Pa Code 129.93(c). The facility has 1 08 storage tanks , 81 of the tanks with capacities greater than 40,000 gallons and 27 tanks with capacities less than or equal to 40,000 gallons . The tanks are subject to the CTG require ments of 25 Pa Code 129.56 and 129.57, respectively

. Kinder Morgan also operates some smaller VOC sources, including the soil vapor extraction (SVE) remediation system and tank cleaning and degassing operations, with VOC potential emissions of 2.7 and 1.8 tons per ye ar respectively. Based on its engineering knowledge and experience, AMS has determined that installing control devices on both de minimis emission sources is technically and economically unreasonable. AMS also listed other de minimis sources that are gen erally considered insignificant for permitting purposes. See Table V

- 3 of AMS’s RACT technical memorandum for Kinder Morgan; see also Title V Operating Permit V95

- 044.

The fugitive VOC emissions from pumps, valves, and flanges are subject to source

- speci fic RACT from the 1

- hour RACT determination . The source is required under the SIP approved24

RACT Permit to implement a quarterly leak detection and repair (LDAR) program for all pumps, valves, and flanges containing VOC. The RACT P ermit also requires the quarterly inspection of any valves, pumps, and flanges which process organic liquids with Reid Vapor Pressure ( RVP ) of 4.0 psi or greater for visual leaks. At this time, fugitive emissions from Kinder Morgan are also subject to AMR V section XIII, which p rohibit fugitive emissions of VOC in the concentration of 10,000 ppmv, or greater, as measured by PADEP’s approved test methods. Because the requirements of AMR V section XIII apply at all times and establish specific leak threshold, AMS finds these requi rements to be more stringent than the source

- specific RACT requirements. AMS has determined that t he requirements in AMR V s ection XIII will supersede the source

- specific LDAR requirements specified in the SIP. Consequently, AMS proposes to

remove the so urce

- specific requirement for fugitives from the SIP approved RACT determination

. Loading at t ank car and truck loading racks is subject to source specific RACT. Petroleum chemicals are transferred between a tank car or truck and the storage tank (load ing) and vice versa (unloading)

. The loading racks consist of multiple loading positions; each position connected to a specific storage tank

. The source

- specific requirements for the loading racks provided in the SIP approved RACT Permit depend on the vo latility of the organic chemicals loaded (related to RVP), consistent with the CTG RACT requirements in 25 Pa Code section 129.59 for bulk gasoline terminals

. As defined in 25 Pa Code section 121.1, gasoline is defined as a petroleum distillate with a RVP of 4.0 psi or greater, and which is liquid at standard temperature and pressure. 13 As provided in 25 Pa Code 129.59(a)
, the loading of gasoline into tanks from a bulk gasoline terminal is prohibited in Pennsylvania , unless the loading racks are equipped w ith a vapor collection and disposal system capable of limiting VOC emissions to 0.0668 pounds (lb) (measured as propane) per 100 gallons of gasoline loaded.

The SIP approved RACT Permit identifies the tank car and truck loading racks as either “controll ed” or “uncontrolled,” as the racks would be either connected or not respectively to the existing thermal oxidation unit

. Per the SIP approved RACT Permit , the “controlled” loading racks are A, B, E, F, M and V; while the remaining racks, C, D, G, H, N, O , P, R, R

- 1, T and X, are “uncontrolled.” The “controlled” racks are required in the RACT Permit to comply with 25 Pa Code section 129.59. Thus , the “controlled” racks are allowed to load organic liquids with RVP of 4.0 psi or greater, while required to control VOC emissions through the operation of the thermal oxidation unit. The SIP approved RACT Permit requires “uncontrolled” racks to only allow loading of organic liquids with RVP of less than 4.0 psi and to comply with a combined VOC emissions limit of 129 tpy of VOC.

The loading racks have been modified several times since the 1

- hour ozone RACT Permit was

13 EPA also notes that Kinder Morgan is a bulk gasoline terminal due to having a daily throughput of less than 20,00 0 gallons (76,000 liters), as defined in 25 Pa Code section 121.1.25

issued, as specified in the technical memorandum. Four additional loading racks have been installed since the 1

- hour ozone RACT determination: DSP, Rail Sliding 1, Rail Sliding 2, and Rail Sliding 3. In most cases, the facility requested to modify the existing loading racks to allow connecting or disconnecting them to the thermal oxidizer, in order to be accommodate liquid organic chemicals wi th different volatilities and satisfy customer demand. As explained by AMS, the SIP approved RACT requirements for the loading racks have not been modified to this date, and continue to be applicable.

In 2010, the facility clarified through a permit mod ification application that the connections to the existing control are made to individual loading positions, rather than the entire loading rack, as each position is connected to a storage tank , each tank used for storing different liquid organic chemicals . The facility also clarified that some “controlled” racks include loading positions that are connected to the control and some positions that are not connected

. Although some positions in the “controlled” racks were operated without the use of the therm al oxidation unit (i.e., uncontrolled)
, these positions were only allowed to load organic liquids with RVP of less than 4.0 psi to remain in compliance with the RACT requirements in 25 Pa Code section 129.59, as required by the SIP approved RACT Permit

. A s explained earlier, 25 Pa Code 129.59(a) prohibits uncontrolled loading of organic liquids with RVP of 4.0 psi or greater. Prior
to 2010, t he facility ha d further presumed that these “uncontrolled” posi tions at “controlled” racks we re also subject to the 129 tons per year limit specified for the “uncontrolled” loading racks

.

T he facility requested in the 2010 permit application that the RACT requirements be revised
to specify the VOC emissions sources as the loading positions, rather than the racks , a nd to clarify the applicable requirements for “controlled” and “uncontrolled” loading

. To avoid burdensome permit modifications and SIP revisions
, Kinder Morgan also requested to remove the identification of the specific racks or positions from the RACT P ermit, so that the facility can operate the racks in any configuration , but limited to the compliance of the specified RACT requirements. AMS i ssued this permit modification (AMS Permit 09105 ) in January 19, 2010

. 14 Currently, the loading racks with “cont rolled” loading positions are A, D, E, F, M, and Rail Sliding 1, and the loading racks with “uncontrolled” positions are B, C, G, H, N, O, P, R, R

- 1, V, X, DSP, Rail Sliding 2 , and Rail Sliding 3 . Table 6 summarizes the current configuration of the loadin g racks, including the number of positions per rack and if each position is “controlled” or “uncontrolled.”

14 AMS had not previously requested any permit modifications to be reflected in the applicable RACT determination and SIP approved RACT Permit until the present SIP revisions under review in this rulemaking.26

Table 6 . Existing Configuration of Tank Car and Truck Loading Positions at Kinder Morgan Rack ID “Controlled” Loading

Al lowed? (“ Yes” / “No” ) No. of “Controlled” Positions No. of

“ Unc ontrolled” Positions A Yes 2 2 D Yes 2 3 E Yes 1 6 F Yes 2 2 M Yes 2 4 Rail Sliding 1 Yes 1 5 B No

- 2 C No

- 2 G No

- 4 H No

- 2 N No

- 2 O No

- 4 P No

- 2 R No

- 4 R

- 1 No

- 2 T No 4 V No

- 1 X No

- 2 DSP No

- 1 Rail Sliding 2 No

- 12 Rail Sliding 3 No

- 7
For the loading of organic liquids with RVP of 4.0 psi or greater (in “controlled” loading positions) , AMS proposes that RACT should continue to be complian ce with 25 Pa Code 129.59, as this requirement continues to represent the most stringent level of control. In order to further ensure VOC reductions
, AMS is also proposing as RACT to include an additional VOC limit of 57 lb/hr for all “controlled” loading positions.

AMS evaluated RACT controls for the loading of organic liquids with RVP of less than 4.0 psi in “uncontrolled” loading positions
, based on the current configuration of the racks as specified in Table 6

. AMS evaluated available VOC controls
, i ncluding thermal oxidation, carbon adsorption, bioreactor, scrubber, and condensation. AMS determined that these controls are not technically n or economically reasonable for the loading of organic liquids with RVP of less than 4.0 psi, and thus do not c onstitute RACT . Therefore, AMS certifies that 1

- hour ozone RACT requirements continue to represent RACT under the 1997 8

- hour ozone NAAQS. I n order to further ensure compliance with the 129 tons of VOC per year limit, AMS is proposing additional VOC limi ts per “uncontrolled” loading position of 9.0 tpy and 18.1 lb/hr

. A summary of the revised RACT requirements for Kinder Morgan’s tank car and truck loading is provided in Table 7 below.27

Table 7

. Summary of Proposed RACT Revisions for Tank Car and Truck L oading at Kinder Morgan Loading Type Approved RACT Requirements Proposed Revisions to RACT Requirements VOC Emissions Limit , per Position VOC Emissions

Limit , All Positions VOC Emissions

Limit , per Position VOC Emissions

Limi t , All Positions Loading of Liquids with RVP of 4.0 psi or greater (i.e., “controlled loading positions”) - 129 tpy * 18.0 lb/hr * 9.0 tons per 12

- month rolling period * 129 tons per 12

-

month rolling period *

Loading of Liquids with RVP of less than 4.0 psi (i.e., “uncontrolled loading positions”) 0.0668 lb/ 100

gallons of gasoline loaded * - 0.0668 lb/ 100 gallons of gasoline loaded * 57 lb/hr*

* Denotes f

ederally enforceable limits.
Kinder Morgan operates two marine vessel berths, Berth 1 and 2, for the lo ading of organic liquids from barges into the source’s storage tanks, and vice versa

. Per the SIP approved RACT Permit , marine vessel loading at the source is limited to organic liquids with RVP of less than 4 psi and its VOC emissions are limited to 59 t py

.

O n September 19, 1995 , EPA finalized a rule for the regulati on of VOC and air toxics emissions from marine tank vessel loading operations , as codified in 40 CFR part 63, subpart Y (Subpart Y)

. 15 60 FR 48399. P ursuant to section 183(f)(1) of the CA A, EPA’s Subpart Y rule require s large marine loading terminals which load at least 200 million barrels per year of crude oil or 10 million barrels per year of gasol ine, to reduce emissions of VOC by 95 percent using RACT. Subpart Y also requires separate requirements for marine loading terminals which are major sources of hazardous air pollutants (HAPs)
, in order to meet the maximum achievable control technology (MACT) as required under the air toxics provision s of the CAA. 16 Because Kinder Morgan ’s marin e loading operations have been required in the SIP approved RACT Permit ( effective in May 29, 1995 ) to load non

- gasoline liquid organics (with RVP of less than 4.0 psi)
, the source is not subject to the RACT requirements of 40 CFR part 63, subpart Y. Cons equently, the loading operations continue to be subject to source

- specific RACT under 25 Pa code section 129.91

- 92 for the 1997 8

- hour ozone NAAQS.

15 Since its original approval in 1995, the regulation in Subpart Y has been subsequently amended by EPA. For the latest version of the rule as well as references to EPA’s rulemaking notices approving these amendments, see 40 CFR part 6 3, subpart Y. 16 EPA’s definition of gasoline under Subpart Y is consistent with Pennsylvania’s approved definition of gasoline in 25 Pa. Code 121.1 (as previously discussed in this TSD). See 40 CFR 63.561.28

In 2012, Kinder Morgan increased the storage of cumene , and consequently the marine loading operations of this chemical. Cumene is a VOC producing organic liquid that is also considered a HAP

. While this operational increase has not affect ed c ompl iance with previously determined RACT, the facility determined it would affect its ability to comply with an exi sting federally enforceable facility

- wide limit of HAPs. As a result, Kinder Morgan installed a m arine

v apor c ombustor u nit (MVCU) that was purchased by the client to control HAP emissions from cumene loading , and consequently VOC emissions. T he MVCU wa s specifically designed for controlling cumene emissions, thus it can only handle organics with a true vapor pressure below 0.4 psi which greatly restricts its operation

. Based on this technical limitation and the legal agreements between Kinder Morgan and the client that purchased the MVCU which require using the existing control for cumene loading only for this particular client , AMS determined that the MVCU is not a reasonably available control option for all VOC emissions from marine loading, and that i t does not represent RACT

.

AMS evaluated as RACT for the marine loading the installation and operation of new VOC controls , i ncluding thermal oxidation, carbon adsorption, bioreactor, scrubber, and condensation. AMS determined that these controls are not technically n or economically reasonable for the marine loading of organic liquids with RVP of less than 4.0 psi, and thus do not constitute RACT

. To ensure additional reductions of VOC emissions , AMS is proposing to revise the existing RACT limit of 59 t py to 51 tons per 12

- month rolling . A summary of the revised RACT requirements for Kinder Morgan’s marine loading is provided in Table 8

.

Table 8

. Summary of Proposed RACT Revisions for Marine Vessel Loading at Kinder Morgan Approved RACT Requirements Pr oposed Revisions to RACT Requirements VOC Emissions Limit VOC Emissions Limit 59 tpy* 51 tons per 12

- month rolling period* * Denotes f

ederally enforceable limits.

AMS determined the re vised re quirements discussed above to represent VOC RACT under
t he 1997 8

- hour ozone NAAQS for the fugitive emissions, tank car and truck loading, and marine vessel loading at Kinder Morgan , respectively. Thus, AMS is requesting to update the SIP approved RACT determination to incorporate them accordingly. The revise d source

- specific RACT requirements for Kinder Morgan have been incorporated in the revised RACT Permit PA

51

- 5003, effective in February 9, 2016, and submitted for approval into the SIP.

EPA finds that the RACT determination provided by AMS is reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits. Thus, EPA finds that the proposed source

- specific RACT controls adequately meet RACT under29

the 1997 8

- hour ozone NAAQS for Kinder Morgan. EPA also finds that the proposed revisions to meet RACT (for fugitive VOC emissions) should not increase emissions of VOC; thus these revisions should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement.

6. Naval Surface Warfare Cen ter

- Carderock Division (PLID

- 09724) Naval Surface Warfare Center

- Carderock Division ( NSWCCD ) is a Navy research and development facility located in 5001 South Broad Street, Philadelphia, Pennsylvania. The facility is a major source of NOx and is subject to two separate RACT determinations under the 1

- hour ozone standard as specified in the RACT Permit PA

- 51

- 9724, effective on December 27, 1997 , and the RACT Permit P A

- 4108, effective on October 1 8, 2004
, both approved into the SIP on October 30, 2001 and April 29, 2005, respectively. See 66 FR 54710 and 70 FR 22257.

As detailed in the submitted AMS technical memorandum, NSWCCD currently operates a number of NOx em itting combustion units , including 20 smaller boilers and heaters, each less than 10 MMBTU/hr; a 202 MMBTU/hr wall

- fired boiler firing diesel located in Building 633 (DDG

- 15) ; 9 emergency generators firing diesel fuel or natural gas ; 5 diesel fired gas tur bines; and 1 3 diesel fired engines. The source has been significantly modified since the time of the previous RACT determination. The SIP approved RACT Permit PA

- 51

- 9724 establishes source

specific requirements for various combustions units
, but most uni ts have been permanently removed with the exception of a 200 KW diesel fired emergency generator located in Building 77 High, a 25 KW diesel fired emergency generator, and the wall

- fired boiler with heat input rating of 202 MMBTU/hr and firing diesel, loca ted in Building 633 (Boiler DDG

- 15). T he 1

- hour ozone RACT determination , as approved in the RACT Permit PA

- 51

- 9724, addressed specific requirements for the two diesel fired emergency generators and a general requirement for all boilers (including Boiler DDG

- 15) , diesel engines, and gas turbines in the source to adhere to the standard Navy Planned Maintenance Program as defined for shipboard use.

The 20 small boilers and heaters (each less than 10 MMBTU/hr) and all emergency generators are currently sub ject to presumptive RACT requirements of 25 Pa Code section 129.93(c) to be installed, maintained, and operated in accordance with the manufacturer’s specifications

. Each of the small boilers and heaters , all installed after the 1

- hour ozone RACT determin ation, are subject to 25 Pa Code section 129.93(c)(1). All emer gency generators have taken f ederally enforceable restrictions to operate less than 500 hours per 12

- month rolling period, and thus are subject to the presumptive requirement of 25 Pa Code sec tion 129.93(c)( 5 ). For the two diesel fired emergency generators existing at the time of the 1

- hour RACT determination ( 200 KW and 25 KW ) , these operational restrictions have been approved into the RACT Permit PA

- 51

- 9724 and approved into the SIP as sourc e

- specific RACT. See also the Title V Operating Permit V13

- 009 for all other units.30

T he diesel engines , gas turbines
, and Boiler D D G

- 15 are currently subject to source

- specific RACT requirements of 25 Pa Code 129.91

- 92

. Boiler DDG

- 15 is used for testing of marine boilers. The t esting engines and turbine engines , all installed after the 1

- hr RACT determination
, have the same testing functions and purposes as the testing engines and turbines that were existing at the time of the 1

- hour ozone RACT evaluati on

. To meet the definition of testing units, the engines
, the turbines
, and the boiler must be configured exactly as their counterpart on a Navy ship and must be conditioned to mimic an at

- sea environment. AMS evaluated all available controls for Boiler D D G

- 15, including LNB and FGR , and for all turbines and engines, including water/steam injection, dry low NOx emissions, SCR, and SCNR. Because NSWCCD
must equip and operate most of its sources like their shipboard counterparts to achieve effective testin g platforms, the installation of controls would impede the use of the units with the purpose of research and development for national security for Department of Defense . For this reason, AMS has previously determine d and continues to determine that the in stallation and operation of controls is technically infeasible for the testing application of the units

. In addition, per 25 Pa Code 129.91(i) and as specified in the SIP approved RACT Permit PA

51

- 9724, the source was required to determine a NOx emissi ons rate for any boiler with heat input greater than 100 MMBTU/hr through either stack testing or modeling. This requirement is applicable to the one remaining boiler at the source , Boiler DDG

- 15, with heat input rating of 202 MMBTU/hr. AMS explains that although this boiler has not been in regular used since 2003
, NSWCCD has indicated it does not plan to shut it down completely, thus this requirement is still in effect. AMS is setting a NOx emissions rate of 0.38 MMBTU/hr for this boiler, based on the s tack testing conducted in 2003, since no stack testing has being completed since then. AMS has committed to re

- evaluate the NOx limit based on future stack testing

. At this time, AMS is certifying that the 1

- hour ozone RACT requirement to adhere to the standard Navy Planned Maintenance Program as defined for shipboard use, continues to represent RACT under the 1997 8

- hour ozone NAAQS for the remaining emissions units previously subject to this requirement

. AMS also determines that it is reasonable to r equire

newer boilers, diesel engines, and gas turbines in the facility that have been installed after the 1

- hour ozone RACT determination to adhere to this p rogram

. AMS proposes that the NOx requirements discussed above represent RACT under the 1997 8

- h our ozone NAAQS for NSWCCD , thus, is requesting to update the SIP approved RACT determination accordingly. The new and revised source

- specific RACT requirements for NSWCCD have been incorporated in the revised RACT Permit PA

- 51

- 9724, effective in February 9, 2016
, which has been submitted for approval into the SIP to replace the previously approved RACT Permit dated December 27, 1997

. T he revised RACT permit no longer list s the shutdown emissions units that were listed in the earlier version of this permi t, as currently31

approved in the SIP. AMS is also requesting to remove from the SIP the RACT Permit PA

4108, effective on October 18, 2004, because the affected units addressed in the permit have been permanently shut down. Since these emissions units have been shutdown, EPA does not expect any effects on air quality impacts as a result of this revision

. EPA finds that the RACT determination provided by AMS is reasonable and appropriately considered technically and economically feasible controls while se tting lowest achievable limits. Thus, EPA finds that the proposed source

- specific R ACT controls adequately meet RACT under the 1997 8

- hour ozone NAAQS for NSWCCD. EPA also finds that the proposed revision s to the RACT determinations in the SIP should not result in any increase emissions of NOx or VOC , as th ese sources are no longer in operation, thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable C AA requirement.

7. Newman & Company, Inc. (PLID

- 03489) Newman and Company, Inc. (Newman) is a paperboard manufacturing facility located at 6101 Tacony Street, Philadelphia, P ennsylvania . The facility is a major source of NOx and is subject to a 1

- hour ozon e RACT determination specified in RACT Permit PA

- 51

- 3489, effective

on June 11, 1997 and approved into the SIP on October 30, 2001

. See 66 FR 546 91

. The source contains the following NOx emissions units: A water

- tube boiler with a maximum heat input
rat ing of 118 MMBTU/hr firing natural gas and number 6 fuel oil (Boiler #1); 29 natural gas fired space heaters with heat input ratings of less than 0.5 MMBTU/hr; two natural gas fired power washers with heat input ratings of less than 0.5 MMBTU/hr; and a num ber 2 fuel oil fired fire pump with 973,000 BTU/hr.

The 29 small space heaters, the fire pump, and the two washers are small combustion units subject to the presumptive RACT requirements of 25 Pa Code section 129.93(c). Boiler #1 is the onl y emissions un it in Newman subject to source

- specific RACT under 25 Pa Code sections 129.91

- 9 2

. T he following NOx limits were previously determined as RACT under the 1

- hour ozone NAAQS and continue to be applicable for Boiler #1 : 0.43 lbs/MMBTU when firing number 6 oi l, 0.37 lbs/MMBTU when firing natural gas, and total NOx emissions limited to 121 tons per rolling 12

- month period. AMS evaluated a dditional controls for Boiler #1 , including FGR and LNB. AMS determined that additional controls are not technically n or ec onomically reasonable for Boiler #1 and thus do not constitute RACT

. Therefore , AMS certifies that 1

- hour ozone RACT determination continues to represent RACT under the 1997 8

- hour ozone NAAQS.

EPA finds that the RACT determination provided by AMS is rea sonable and appropriately considered technically and economically feasible controls while settin g lowest achievable limits. Thus, EPA finds that the source

- specific RACT controls currently approved in the SIP adequately meet RACT under the 1997 8

- hour ozo ne NAAQS for N ewman

.32

8. Paper w orks Industries, Inc. (formerly, Jefferson Smurfit, Corp. / Container Corp. of America ) (PLID

- 01566) Paper w orks Industries, Inc . ( Paperworks ) is a paperboard manufacturing facility located at 5000 Flat Rock Road, Philadelphia, Pennsylvania . The facility is a major source of NOx and is subject to a 1

- hour ozone RACT determination, under its former name, Jefferson Smurfit Corp./Containers Corp. of America, as specified in RACT P ermit PA

- 51

- 1566
, effective on April 10, 1995 and a pproved into the SIP on October 31, 2001

. See 66 FR 54947. The source contains the following NOx emissions units: A Riley boiler with a capacity of 156 MMBTU/hr (Boiler #1) firing number 6 oil and natural gas and two 92.27 MMBTU/hr, natural gas fired bo ilers (Boilers #3 and #4). At the time of the 1

- hour RACT determination, the source also operated a Riley boiler with a capacity of 225 MMBTU/hr (Boiler #2) firing coal, number 6 oil and natural gas; and four natural gas fired infrared heaters, each with 2 .9 MMBTU/hr heat input capacity. Boiler #2 and the four infrared heaters were shutdown in 2008.

S ource

- specific NOx RACT was determined under the 1

- hour ozone NAAQS for Boiler #1, Boiler #2 and the four infrared heaters. Boiler #1 was permitted and o perated at the time with a capacity of 240 MMBTU/hr and fired coal, number 6 oil, and natural gas. The following NOx limit s were determined as 1

- hour RACT for both Boilers #1 and # 2: 0.20 lbs/MMBTU while burning natural gas, 0.30 lbs/MMBTU while burning number 6 oil, and 0.50 lbs/MMBTU while burning coal
, all limits on a 30

- day rolling average ; and total combined NOx emissions were limited to 1,018 tpy . Also, Boilers #1 and #2 we re required to install and operate a LNB with overfire air as RACT

.

I n 20 14
, Boiler #1 was modified to limit its heat input rating to 156 MMBTU/hr
, prohibit burn ing coal, and allow the combustion of number 6 fuel oil solely during emergencies or in

cases of natural gas interruptions. The use of number 6 oil combustion was also limited to 169 hours per 12

- month rolling. See Plan Approval No. 08179A, issued by AMS on December 19, 2014. Considering the most stringent applicable requirements to date
, AMS evaluated as RACT additional controls for Boiler #1, including FGR, SNCR , an d SCR. AMS determined that these additional controls are not technically n or economically feasible. Thus, AMS determined that the current operation of the existing RACT controls in addition to recent operation al restrictions for Boiler #1 represent RACT under the 1997 8

- hour ozone NAAQS. AMS is requesting to update the SIP approved RACT determination accordingly. As indicated by AMS, t he proposed RACT revisions to Boiler #1 should result in a dditional reduction s of potential NOx emissions, as presented in Table 9 below.33

Table 9

. Summary of Proposed RACT Revisions for Boiler #1 at Paperworks

Fuel Approved RACT Requirements a Proposed Revisions to RACT Requirements b Heat Input (MMBTU/ hr) NOx

emissions rate (lb/ MMBTU) Annual

NOx Emissions (tpy) Heat Input

(MMBTU/ hr) NOx

emissions rate (lb/ MMBTU) Annual

NOx Emissions (tpy) Coal 240 0.50* 525.6 156*

- - Number 6 Oil 0.30*

- 0.30* 3.9 Natural Gas 0.20*

- 0.20* 134.0 Total NOx Emissions 525.6

- - 137.9 * Denotes f

ederally enforceable limits.

a Potential annual emissions on this scenario are based on coal combustion, the highest emitting fuel allowed under 1

- hour RACT, and operation of the boiler at full capacity

. Note that coal usage is no longer allowed, but emissions are presented as current ly permitted for RACT purposes.
b Potential annual emissions on this scenario are based on natural gas and number 6 oil combustion, the limit on number 6 oil usage, and the operation of the boiler at full capacity. Note that coal usage is no longer allow ed.
Boilers #3 and #4 are in operation since 2009. Although originally allowed to burn number 6 oil and natural gas, Boilers #3 and #4 were restricted from burn ing number 6 fuel oil in 2014. See Plan Approval No. 08179 dated December 30, 2008 and Plan A pproval No. 08179A issued by AMS on December 19, 2014. The currently applicable f ederally enforceable requirements for Boiler #3 and Boiler #4 are : NOx emissions limits of 0.025 lbs/MMBTU burning natural gas and 10.15 tons per rolling 12

- month period; op eration of LNB and FGR controls; and restriction to only burn natural gas (per Plan Approval No. 08179A). AMS determine d these requirements to represent NOx RACT under the 1997 8

- hour ozone NAAQS and
, thus is requesting to update the SIP approved RACT det ermination to incorporate them accordingly.

Additionally, AMS is updating the SIP approved RACT determination to remove any references to the retired emissions units, Boiler #2 and the four infrared heaters

. Since these emissions units have been shutdo wn, EPA does not expect any effects on air quality impacts as a result of this revision

. The new and revised source

- specific RACT requirements for Paperworks have been incorporated in the revised RACT Permit PA

- 51

- 1566 , effective in January 9, 2015
, and s ubmitted for approval into the SIP. The revised RACT permit will replace the previous version of the RACT Permit dated April 10, 1995, as approved in the SIP.

EPA finds that the RACT determination provided by AMS is reasonable and appropriately conside red technically and economically feasible controls while setting lowest achievable limits and that the proposed source

- specific RACT controls adequately meet RACT under the 1997 8

- hour ozone NAAQS for Paperworks. EPA also finds that the proposed revisions to meet RACT will result in equivalent or additional reductions of NOx emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requi rement.34

9. Philadelphia En ergy Solutions

- Refining and Marketing , LLC (formerly, Sunoco Inc. (R&M)

- Philadelphia) (PLID

- 01501 and 01517 ) Philadelphia Energy Solutions

- Refining and Marketing, LLC ( PES ) is a petroleum refinery located at 3144 P assyunk Avenue
, Philadelphia , Pennsylvania . The refinery is a major source of both NOx and VOC and is subject to a 1

- hour ozone RACT determination, as specified in RACT Permit s PA

- 51

- 1501 and 51

- 1517 for the former owner Sunoco, Inc. (R&M)

- Philadelphia (issued as a si ngle document) , effective on August 1, 2000 and approved into the SIP on October 31, 2001. 66 FR 54942. EPA’s December 13, 2013 conditional approval required AMS to submit a source

- specific RACT determination for PES, as AMS had indicated the source has adopted or will adopt additional controls after the 1

- hour RACT determination that should represent RACT under the 1997 8

- hour ozone NAAQS. AMS submitted two separate source

speci fic RACT determinations for PES : The first determination
, included in the J une 27, 2014 SIP revision, addresses 7 specific process heat ers that were recently modified ; and the second determination
, included i n the March 26 , 2016 SIP revision, address es the remaining emissions units at PES

. The facility’s NOx and VOC emission un its include 33 process heaters , 3 boilers, 2 fluid catalytic cracking units ( FCCUs), 5 diesel

- fired non

- emergency reciprocating internal combustion engines (RICE) with heat input ratings of less than 2 MMBTU/hr , 11 emergency generators and fire pumps, a la rge number of storage tanks (i.e., tank farm), two stormwater tanks (Tanks 7308 and 7300), cooling towers, t ruck loading operations, marine vessel loading operations, oil

- water separators and degreasers
, fugitive emissions from cooling towers, and fugitive emissions from valves, flanges, and pumps

. The SIP approved RACT Permit s include

source

- specific requirements for numerous heaters, the 3 boilers, one of the FCCUs, fugitive emissions from cooling towers, and fugitive emissions from valves, pumps, flange s and compressors

. The following units are currently subject to source

- specific RACT: Process heaters, boilers, FCCUs, the engines, some truck loading operations, and marine vessel loading operations.

T he eleven emergency generators and fire pumps are subject to the presumptive RACT requirement of 25 PA Code Section 129.93(c)(5) to be installed, maintained, and operated in accordance with manufacturer’s specifications. Each unit is limited to a federally enforceable restriction to operate less than 50 0 hours per rolling 12

- month period. See Title V/Sta te Operating Permit No. V06

- 016.

The following VOC emissions units at PES are subject to CTG RACT requirements: Wastewater treatment plant, oil/water separators, degreasers, storage tanks, stormwater tank, and truck loading operations. The wastewater treatment plant and oil/water separators are subject to 25 Pa Code section 129.55. Degreasers are subject to 25 Pa Code section 129.63. Storage tanks35

and the two stormwater tanks (Tanks 7308 and 7300) are subject to 25 Pa Code sections 129.56 and 129.57. Truck loading operations for liquid organic materials with a RVP of 4.0 psi or greater are subject to the CTG RACT requirements of AMR V, section V. AMS has previously certified that these requirement s continue to represent RACT under the 1997 8

- hour ozone NAAQS.

AMS indicates VOC emissions from t ruck loading operations for liquid organic materials with a RVP of less than 4.0 psi are small and thus considered de minimis . At this time, the

source only loads cumene ( with a RVP below 4.0 psi)
, which has potential VOC emissions of 2 tpy . Based on AMS permitting and engineering knowledge, AMS determines that installing any control technology on such small source of VO C emissions (i.e., de minimis source) is both technically and economically unreasonable.

The fugitive VOC emissions from pumps, valves, and flanges are subject to 1

- hour ozone

source

- specific RACT requirements. PES is required under the SIP approved RACT Permit s to implement a quarterly LDAR program for all pumps, valves, and flanges, and compressors in VOC service. Fugitive emissions from equipment leaks are also subject to the CTG RACT requirements in 25 Pa Code section 129.58. AMS finds that the provisions in 25 Pa Code section 129.58 ar e more stringent than the source

- specific LDAR requirement, because it has more frequent monitoring and a specific leak threshold. AM S determines that the requirements of 25 Pa Code section 129.58 satisfy RACT under the 1997 8

- hour ozone NAAQS for fugitiv e emissions at PES

. Accordingly , A MS is requesting to remove the quarterly LDAR program from the SIP. EPA anticipates equivalent or additional reductions from this revision and compliance with the CTG RACT requirements.

As explained in the technical memo randum, fugitive VOC emissions are emitted from cooling towers as a result of the evaporation of organics dissolved in the cooling water streams that are processed in the towers. The SIP approved RACT Permit s require PES to reduce fugitive emission throug h the inspection, maintenance, and monitoring of the cooling towers. PES is currently subject to EPA’s requirements for refineries codified at 40 CFR 63, subpart CC (“National Emissions Standards for Hazardous Air Pollutants from Petroleum Refineries”). The regulation requires the source to implement a rigorous LDAR program that includes regulation of fugitive emissions from cooling towers. AMS determines that these requirements are more stringent than the RACT requirements approved under the 1

- hour ozon e NAAQS, and determines that compliance with 40 CFR 63, subpart CC should represent RACT under the 1997 8

- hour ozone NAAQS. AMS is replacing the source

- specific RACT requirement in the SIP for cooling towers with the requirement of compliance with 40 CFR 63 , subpart CC.

The 5 diesel

- fired non

- emergency engines have potential emission of NOx and VOC of less than 2 tpy. Thus, based on its permitting and engineering knowledge, AMS determined that36

installing any controls on these de minimis sources is tech nically and economically unreasonable.

As indicated earlier, PES operates 33 process heaters and 3 boilers, as identified in Table 10 below. All heaters and boilers with heat input ratings of 50 MMBTU/h r and above are subject to

s ource

- specific RACT; whi le units with heat input ratings under 50 MMBTU/h r are subject to the presumptive RACT requirements in 25 Pa Code section 129.93(b)(2) to perform annual adjustment or tune

- up on the combustion process (hereafter “annual tune

- up”). AMS determines that thes e presumptive requirements continue to meet RACT under the 1997 8

- hour ozone NAAQS for heaters and boilers with heat input ratings under 50 MMBTU/hr. T he approved

source

- specific RACT requirements under the 1

- hour ozone NAAQS are summarized as well in Tab le 10. A number of heaters and boilers addressed in the SIP approved RACT Permit s have shut down since the previous RACT determination , as identified in the AMS’s technical memorandum

. Three additional heaters have been installed after the 1

- hour RACT de termination, 859

- 1H1, 870

- H01, and 870

- H02.

Table 10

. Process Heaters and Boilers at PES and Applicable Source

- s pecific RACT Requirements under the 1

- hour Ozone NAAQS

Emissions Unit Applicable RACT

Requirement 1

- hour Ozone Source

- Specific R ACT Requirements

Heat Input Rating (MMB T U/hr) Control

Requirement NOx Emissions

Limit * (lb/MMBTU) Potential

NOx Emissions (tpy) d

Heater 210

- H101 a Source

- specific 183 .0 Annual tune

- up 0.089 (gas) 0.400 (oil) 320.6

Heater 210

- H201 A/B a Source

- specific 242 .0 * Annual tune

- up 0.173 (gas) 0.400 (oil) 424.0

Heater 210

- 13H1 Source

- specific 235.4 Annual tune

- up 0.104 (gas) 0.400 (oil) 412.4

Heater 231

- 101 a Source

- specific 91 .0 * Annual tune

- up 0.122 (gas) 48.6 Heater 859

- 1H1 b Source

- specif ic 98 .0

- - -
Heater 860

- 2H2 Source

- specific 69.8 Annual tune

- up 0.350 (gas) 0.400 (oil) 122.3

Heater 860

- 2H3 Source

- specific 174.7 Annual t une

- up 0.163 (gas) 0.400 (oil) 306.1

Heater 860

- 2H4 Source

- specific 99.4 Annual t une

- up 0.270 (gas) 0. 400 (oil) 174.1

Heater 860

- 2H5 Source

- specific 155 .0 Annual t une

- up 0.163 (gas) 0.400 (oil) 271.6

Heater 860

- 2H7 Source

- specific 59 .0 Annual t une

- up 0.157 (gas) 0.400 (oil) 103.4

Heater 860

- 2H8 Presumptive 49.6 *

- - - Heater 864

- PH1 Source

- specific 80

. 0 Annual tune

- up 0.167 (gas) 140.237 0.400 (oil)

Heater 864

- PH7 Presumptive 45.5 *

- - - Heater 864

- PH11 Source

- specific 74 .0 Annual t une

- up 0.145 (gas) 0.400 (oil) 129.6

Heater 864

- PH12 Source

- specific 85.1 Annual t une

- up 0.119 (gas) 0.400(oil) 149.1

Hea ter 865

- 11H1 a Source

- specific 72.2 Annual tune

- up 0.113 (gas) 0.400 (oil) 126.5

Heater 865

- 11H2 a, c Source

- specific 49.9*

- - - Heater 866

- 12H1 a, c Source

- specific 43 .0 *

- - - Heater 868

- 8H101 a, c Source

- specific 40 .0 *

- - - Heater 870

- H01 b Source

- specific 97 .0

- - - Heater 870

- H02 b Source

- specific 53 .0

- - -

Heater 137 F

- 1 Source

- specific 415 .0 * Annual tune

- up 0.230 (gas, oil) (30

- day rolling average) 418.1

Heater 137 F

- 2 Source

- specific 155 .0 * Annual tune

- up 0.257 (gas) 0.4 (oil) 271.6

Heater 137 F

- 3 Source

- specific 60 .0 Annual tune

- up 0.400 (oil) 105.1 Heater 1332 H

- 1 Presumptive 45 .0

- - Heater 1332 H

- 2 Source

- specific 60 .0 Annual tune

- up 0.300 (gas) 78.8 Heater 1332 H

- 3 Presumptive 43 .0

- - - Heater 1332 H

- 400 Sourc e

- specific 186 .0 * Annual tune

- up 0.156 (gas) 127.1 Heater 1332 H

- 401 Source

- specific 233 .0 Annual tune

- up 0.156 (gas) 159.2 Heater 1332 H

- 601 Presumptive 48 .0

- - - Heater 1332 H

- 602 Presumptive 49 .0

- - -
Heater 433 H

- 1 Source

- specific 243 .0 * ULNB and annual tune

- up 0.060 (gas) 63.9

Heater 1232 B

- 104 Source

- specific 70 .0 * ULNB and annual tune

- up 0.177 (gas) 54.3

Boiler #37 Source

- specific 495 .0 * ULNB 0.330 (gas
, oil) 715.5 Boiler #39 Source

- specific 495.0 * ULNB 0.330 (gas
, oil) 715.5 Boiler #40 So urce

- specific 660 .0 * ULNB 0.330 (gas
, oil) 715.5 * Denotes federally enforceable limits.

a AMS addressed RACT for these 7 heaters in a separate RACT determination submitted as part of the June 27, 2014 RACT SIP revision. b This unit has been installed after the 1

- hour RACT determination, and thus there are no RACT requirements approved in the SIP

. c Heat input rating for th is heater has been revised to exceed 50 MMBTU/hr, and thus the unit is currently subject to

source

- specific RACT. d Potential NOx e missions based on combustion of oil, the highest emitting fuel allowed at the time.

EPA notes that all units currently burn refinery gas, but were allowed to combust refinery fuel oil and/or refinery gas at the time of the 1

- hour ozone RACT determination. P er a federally enforceable consent decree, EPA and other air permitting agencies required the source to eliminate fuel oil burning in the heaters and boilers, except during natural gas curtailments,38

losses of supply, and during stack test programs. 17 Th e source phased out entirely the use of combusting refinery oil in 2010.

As summarized in Table 10, only a few heaters and boilers are required under the 1

- hour ozone RACT determination to operate specific NOx controls, while annual tune

- up is performed on all other units. The SIP approved RACT Permit s also specif y NOx emissions limits for each of these boilers and heaters, an d heat input limits in MMBTU/h r for some of the affected units. The source is required to monitor fuel input in a daily basis fo r the boilers subject to heat input limits to determine compliance.

S ince the previous RACT determination
, a number of heaters and boilers have been modified and/or are subject to more stringent federally enforceable NOx requirements
, a s summarized in T able 11 below. EPA notes that eight of these heaters have been modifie d to allow higher heat input rates than those previously approved to meet RACT ; however , AMS has also adopted for these heaters more stringent NOx emissions limits to offset potential e missions increases and impacts to air quality

. AMS shows that the revisions to these 8 units result in equivalent or additional reductions of NOx emissions , therefore EPA finds that these modifications are consistent with section 110(l) of the CAA. All f ederally enforceable NOx requirements listed below are being submitted to meet RACT under the 1997 8

- hour ozone NAAQS

. Table 11 also provides the federally enforceable NOx requirements that apply to the 3 heaters that were installed after the 1

- hour ozone RACT determination.

Table 11

. New and Modified Process Heaters and Boilers at PES

Emissions Unit NOx Requirements Approved A fter 1

- hour Ozone RACT

Heat Input Rating (MMBTU/hr) Heat Input

Rating (MMBTU/ rolling 365 day period) Control

Requirement * NOx Emissions

Limit * (lb/MMBTU) c Potential

NOx Emissions (tpy)

Heater 210

- H101 a 192 .0 1,681,920 Annual tune

- up 0.089 74.8 Heater 210

- 201A/B a b 254 .0 2,225,040 ULNB 0.03 33.4

Heater 231

- B101 a 104.5 915,420 ULNB 0.03 13.2 Heater 859 1H1 98.0

- ULNB 0. 035 8.6 Heater 865

- 11H1 a 87.3 764,748 ULNB 0.03 11.5 Heater 865

- 11H2 a b 61.2 562,392 Annual tune

- up 0.113 30.3 Heater 866

- 12H1 a b 61.2 536,112 Annual tune

- up 0.113 30.3 Heater 868

- 8H101 a

b 60 .0 525,600 Annual tune

- up 0.113 29.7

17 Second Amendment to a Consent Decree between EP A, several states, the City of Philadelphia, and Sunoco, Inc. (Civil Action No.05

- 02866).39

Heater 870

- H01 5 3.0

- ULNB 0.035 14.9 Heater 870

- H02 98.0

- ULNB 0.035 8.1 Heater 137 F

- 3 60 .0

- ULNB 0.06 15.8 Heater 1332 H

- 2 60 .0

- ULNB 0.04 10.5 Heater 1332 H

- 400 186 .0 *

- SCR 0.06 48.9 Heater 1332 H

- 401 233 .0

- SCR 0.06 61.2

Heater 433 H

- 1 a 260 .0 *

- ULNB and

a nnual t une

- up 0.035 39.9

Boiler #37 495 .0 *

- ULNB and FGR 0.04 86.7

Boiler #39 495 .0 *

- ULNB and FGR 0.04 86.7

Boiler #40 660 .0 *

- ULNB and FGR 0.04 115.6 * Denotes federally enforceable limits.

a The hourly heat input rating for this heater has been increased; however a more stringent NOx emissions limit has been adopted to avoid any emissions increases. b Since the permitted hourly heat input rating of this heater has been revised to exceed 50 MMBTU/hr, the heater is now subject to source

- specifi c RACT.

c NOx emissions limit s are for the combustion of refinery gas , as the source is no longer allowed to burn refinery fuel oil

. AMS evaluated the following additional NOx controls for all boilers and heaters subject to

source

- specific RACT under 25 Pa Code sections 129.91

- 92 : ULNB, SCR, SNCR, ULNB and SCR, LNB and SCR, and LNB and FGR. Considering the emissions reductions already achieved by existing controls
, AMS determined that these additional controls are not technically and/or economically re asonable for each of the boilers and heaters
, and thus do not represent RACT under the 1997 8

- hour ozone NAAQS

. To ensure that NOx RACT represents the most stringent level of control for the combustion units, AMS is proposing to adopt as RACT the most s tringent NOx lim its and controls that apply to certain heaters and boilers at this time, as provided in Table 11. Also, AMS is removing from the SIP the NOx limits for burning refinery oil that were approved as RACT under the 1

- hour ozone NAAQS for all un its that were allowed to burn under the previous determination . These modifications altogether result in equivalent or additional potential NOx emissions reductions, as summarized in Table 12 below. AMS is also removing from the SIP any source

- specific R ACT requirements that were approved for those boilers and heaters that have been permanently shut down.40

Table 12

. Summary of Proposed RACT Revisions for Process Heaters and Boilers at PES

Emissions Unit Proposed Revisions to RACT Requirements Potential NOx Emissions Reductions (tpy) a Heat Input Rating (MMBTU/hr) Control

Requirement NOx

Emissions Limit* (lb/MMBTU) Potential NOx

Emissions (tpy)

Heater 210

- H101 192.0 Annual tune

- up 0.089 74.8 245.8 Heater 210

- H201 A/B 254.0 ULNB 0.030 33.4 390.6

Heat er 210

- 13H1 235.4 Annual tune

- up 0.104 107.2 305.2
Heater 231

- 101 104.5 ULNB 0.030 13.7 34.9 Heater 859

- 1H1 98.0 ULNB 0.02 0 8.6

- Heater 860

- 2H2 69.8 Annual tune

- up 0.350 107.0 15.3 Heater 860

- 2H3 174.7 Annual tune

- up 0.163 124.7 181.3 Heater 860

- 2H4 99.4 Annual tune

- up 0.270 117.6 56.6 Heater 860

- 2H5 155.0 Annual tune

- up 0.163 110.7 160.9 Heater 860

- 2H7 59.0 Annual tune

- up 0.157 40.6 62.8 Heater 864

- PH1 80.0 Annual tune

- up 0.167 58.5 81.6 Heater 864

- PH11 74.0 Annual tune

- up 0.145 47.0 82.7 Heate r 864

- PH12 85.1 Annual tune

- up 0.119 44.4 104.7 Heater 865

- 11H1 87.3 ULNB 0.030 11.5 115.0 Heater 865

- 11H2 61.2 Annual tune

- up 0.113 30.3

- Heater 866

- 12H1 61.2 Annual tune

- up 0.113 30.3

- Heater 868

- 8H101 60.0 Annual tune

- up 0.113 29.7

- Heater 870

- H 01 97.0 ULNB 0.035 14.9

- Heater 870

- H02 53.0 ULNB 0.035 8.1

- Heater 137 F

- 1 415.0 Annual tune

- up 0.23 0 418.1

- Heater 137 F

- 2 155.0 Annual tune

- up 0.257 174.5 97.1 Heater 137 F

- 3 60.0 ULNB 0.06 0 15.8 89.4 Heater 1332 H

- 2 60.0 ULNB 0.04 0 10.5 68.3 H eater 1332 H

400 186.0 SCR 0.06 0 48.9 78.2
Heater 1332 H

401 233.0 SCR 0.06 0 61.2 98.0

Heater 433 H

- 1 260.0 ULNB and annual tune

- up 0.035 39.9 24.0

Heater 1232 B

104 70.0 ULNB and annual tune

- up 0.177 54.3 0.0

Boiler #37 495.0 ULNB and FGR 0.04 0 86.7 6 28.7

Boiler #39 495.0 ULNB and FGR 0.04 0 86.7 628.741

Boiler #40 660.0 ULNB and FGR 0.04 0 115.6 838.3 * Denotes federally enforceable limits.

a P otential NOx reductions expected when compared to the implementation of 1

- hour ozone RACT requirements, as pro vided in Table 10.
AMS determined that there are no reasonably available VOC controls for the heaters and boilers at PES. Additionally, AMS indicates that most of the combustion units at the facility have potential VOC emissions below 5 t py

. PES operate s two FCCUs, unit 868 and unit 1232 , that are significant sources of NOx and produce some VOC emissions

. FCCU unit 868 is a full

- burning unit and is subject to source

specific RACT under the previous determination. The SIP approved RACT Permit s speci fy f or FCCU unit 868 a NOx emissions limit of 569 tons per rolling 12

- month period and require s the

source to follow good combustion practices and use a carbon monoxide ( CO ) promoter in the regenerator. After the 1

- hour RACT determination, FCCU unit 868 has b een subject to federally enforceable limits to process 50,000 barrels in a single day and 47,500 barrels per day on a rolling 365

- day average, and a NOx limit of 50 parts per million, volumetric on dry basis (ppmvd) at 0 % oxygen. See Plan Approval No. 001 84 dated March 22, 2002 and the Second Amendment of Civil Action No.05

- 02866 Consent Decree.

AMS evaluated NOx controls as RACT for FCCU unit 868 , including SCR, SNCR and a low temperature oxidation device ( LoTOx ) , and determined that none of these cont rols are economically reasonable. AMS determines that the NOx RACT control requirements approved for the FCCU 868 under the previous determination continue to represent RACT under the 1997 8

- hour ozone NAAQS. Further, AMS is adopting as NOx RACT for the FCCU 868 the currently applicable NOx limit of 50 ppmvd at 0% oxygen and an additional NOx limit of 1 30.2 tons per rolling 365

- day period that represents the highest allowed emissions based on the most stringent limit of 47,500 barrels per day on a rollin g 365

- day. There are no feasible controls of VOC for full

- burn FCCUs.

FCCU unit 1232 is not subject to any requirements under the previous RACT determination. FCCU unit 1232 is a partial

- burn unit, and is currently r equired to operate a SCR for controll ing NOx emissions to comply with a federally enforceable NOx emissions rate of 40 ppmdv at 0% oxygen on a 7

- day rolling average

. At this time, the unit is also restricted to operate up to 100,000 barrels in a single day and 90,000 barrels per day on a rol ling 365 day average period. AMS finds that the existing SCR and corresponding NOx limit represent the most stringent level of control, and that they should satisfy NOx RACT for this unit under the 1997 8

- hour ozone NAAQS. Thus, AMS is adopting as NOx RA CT for FCCU unit 1232 a requirement to operate the SCR and the NOx emissions limit of 4 0 ppmdv at 0% oxygen on a 7

- day rolling average, as well as an additional limit of 208.29 tons per rolling 365

- day period that represents the highest42

allowed emissions b ased on the most stringent limit of 4 90,000 barrels per day on a rolling 365 day average period

.

FCCU unit 1232 is required to operate a boiler with the purpose of reducing the significant CO emissions produced (CO boiler), which results in some reducti ons of VOC emissions. There are no other technically feasible VOC controls for partial

- burning FCCUs t han the CO boiler. Therefore, AMS determines the CO boiler to represent VOC RACT for FCCU 1232.

Marine loading operations at PES occur in two differe nt areas of the facility, at Girard Point and at Point Breeze. The Girard Point Barge Loading Process handles liquid organic materials with a RVP of 4 psi or greater and is required to operate a thermal oxidizer to achieve a minimum of 98% VOC capture and destruction efficiency or an outlet VOC concentration of 20 ppmv , c onsistent with 25 Pa Code section 129. 81. The Point Breeze Marine Barge Loading Process currently handles liquid organic materials with a RVP of less than 4 psia

.

As noted in the techn ical memorandum, AMS determined as 1

- hour ozone RACT for marine vessel loading of materials with a RVP of 4 psi or greater to be those requirements specified in 25 Pa Code section 129.81. However, AMS is no longer relying on these provisions to meet RACT under the 1997 8

- hour ozone NAAQS. AMS notes that the Point Breeze Marine Barge Loading Process did handle liquid organic materials with a RVP of 4 psi or greater at the time of the 1

- hour ozone RACT determination, and was required then to operate a marin e vapor collection and control system (MVCCS) to comply with 25 Pa Code section 129.81 . Since the barge loading of such organics no longer occurs at Point Breeze, the control requirements in 25 Pa Code section 129.81 are no longer applicable, and the MVCC S has been permanently removed.

P ursuant to section 183(f)(1) of the CAA, EPA’s Subpart Y rule require s large marine loading terminals which load at least 200 million barrels per year of crude oil or 10 million barrels per year of gasol ine, to comply wi th RACT standards for reducing VOC emissions

. Because the maximum throughput of marine loading process at Girard Point has never exceeded the applicable thresholds under Subpar t Y, this process is not subject to EPA’s RACT standards. Additionally, Subpar t Y is not applicable to the Point Breeze marine loading process, because gasoline products are no longer loaded. Consequently, both loading operations are currently subject to source

- specific RACT under 25 Pa code section 129.91

- 92 for the 1997 8

- hour oz one NAAQS.

AMS has evaluated all additional VOC controls for the Girard Point Barge Loading Process, including but not limited to thermal incinerator, flare, carbon adsorption, and condenser. Considering the emissions reductions already achieved by the e xisting control (thermal oxidizer), AMS determined that these additional controls are not technically n or economically reasonable,43

and thus do not represent RACT under the 1997 8

- hour ozone NAAQS

. AMS proposes to adopt into the SIP as source

- specific RACT for the Girard Point Barge Loading Process the VOC emission limits and control requirement currently in place.

AMS has evaluated all additional VOC controls for the Point Breeze Barge Loading Process, including but not limited to thermal incinerator, fla re, carbon adsorption, and condenser. AMS determined that these controls are not economically reasonable, and thus do not represent RACT under the 1997 8

- hour ozone NAAQS for the Point Breeze Marine Barge Loading Process

. AMS proposes to adopt into the S IP as source

- specific RACT a VOC emissions limit of 25.99 tons per rolling 12

- month period.

The new and revised source

- specific RACT requirements for PES have been incorporated in the revised RACT Permit s PA

- 51

- 1501 and 51

- 1517, effective in February 9, 2016
, which was submitted for approval into the SIP. EPA notes that a revised RACT permit for PES was also submitted as part of the June 27, 2014 SIP revision, however this version of the permit has being superseded by the latest revision of the RACT per mit ( effective in February 9, 2017 ) submitted in the March 26 , 2016 SIP revision

. EPA finds that the RACT determinations provided by AMS is reasonable and appropriately considered technically and economically feasible controls while setting lowest achieva ble limits and that the source

- specific RACT controls cur rently approve in the SIP for the remaining sources adequately meet RACT under the 1997 8

- hour ozone NAAQS for P ES

. EPA also finds that the proposed SIP revisions to meet RACT will result in equival ent or additional reductions of NOx and/or VOC emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement

.

10. Philadelphia Gas Works (PGW)

- Richmond Plant (PLID

- 04922) Philadelphia Gas Works

- Richmond Plant (PGW) is a natural gas utility at 3100 East Venango Street
, Philadelphia, Pennsylvania. The facility is a major source of NOx and is subject to a 1

- hour ozone RACT determina tion, as approved in RACT Permit PA

- 51

- 4922, effective on July 26, 1999 and approved into the SIP. See 66 FR 54947 (October 31, 2001). The facility contains the following NOx emissions units: Six liquefied natural gas (LNG) vaporizer heaters with heat c apacities between 94.1 and 105.0 MMBTU/hr, five boiler/heaters with heat capacities of 11 MMBTU/hr or less, four simple cycle combustion turbines with heat capacity of 13.7 MMBTU/hr or less, two 170 horse power (HP) emergency generators, and three 295 HP e ngines for fire pumps.

The 1

- hour RACT determination includes source

- specific requirements for the 6 LNG vaporizer heaters and four Clark engines. All other remaining emissions units at the source are subject to presumptive RACT requirements of 25 Pa Co de section 129.93. The four Clark engines are no longer operating. Therefore, AMS is requesting to remove from the SIP the previously approved RACT requirements for the four engines at PGW. Since these emissions44

units have been shutdown, EPA does not ex pect any effects on air quality impacts as a result of this revision

. Thus, EPA finds that the proposed revision should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with oth er applicable CAA requirement

. The six LNG vaporizer heaters are subject to the 5% annual capacity limit, the presumptive RACT requirement specified in 25 Pa Code section 129.93(c)(5). To ensure compliance with the annual capacity limit, the source accep ted a limit for combined annual natural gas usage of 257 million cubic feet per year (MMcf/yr), which was approved into the 1

- hour ozone source

- specific RACT determination. This is the only source

- specific requirement currently applicable from the previou s RACT determination. AMS determines this requirement for the six LNG heaters to continue to meet RACT under the 1997 8

- hour ozone NAAQS

.

The revised source

- specific RACT requirements for P GW have been incorporated in the revised RACT Permit PA

- 51

- 4922, effective in January 9, 2015
, which was submitted for approval into the SIP

. The revised RACT Permit intends to replace the previous version of this permit dated July 7, 1999 which was approved in the SIP.

EPA finds that the RACT determinations provid ed by AMS is reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the source

- specific RACT controls currently approve in the SIP for the remaining

sources adequately meet RAC T under the 1997 8

- hour ozone NAAQS for PGW

.

11. Plain Products Terminals, LLC (formerly, Maritank Philadelphia, Inc. and Exxon Company, USA) (PLID

- 05013) Plain Products Terminals, LLC (Plain Products) is a bulk liquid storage and distribution facility loc ated at 3400 South 67 th Street
, Philadelphia, Pennsylvania, and is a major source of VOC. Plain Products has two terminals, North Terminal and South Terminal, that were formerly two separate but adjacent facilities, Maritank Philadelphia, Inc. (Maritank) (PLID

- 05013 ) and Exxon Company , USA (Exxon) (PLID

- 05008). Since the terminals are adjacent and finally operated by a common owner, they were determined a single source for permitting and RACT purposes. The source ’s VOC emissions units include 36 petrol eum/organic products storage tanks, truck loading operations, marine loading operations, loading at two recovery tanks, fugitive emissions from pumps, valves, and flanges, tank cleaning and repair, and lubricity additive systems. There are other NOx emiss ions units in operation: T wo oil fired boilers with rating of 20 and 4.74 MMBTU /h r heat input ratings and six small space heati ng units (0.25 MMBTU/h r each).

Plain Products is subject to two separate 1

- hour ozone RACT determinations for Maritank and Exxo n , a s specified in RACT Permit s PA

- 51

- 5013 (effective on December 28, 1995) and45

PA

- 51

- 5008 (effective May 29, 1995)
, respectively, both which were approved by EPA into SIP. See 66 FR 54947 and 66 FR 54936 (October 31, 2001). The RACT Permit for Maritank (currently Plain Products’ North Terminal) specifies source

- specific requirements for marine loading operations, loading at five recovery tanks, two o il fired boilers of 30 MMBTU/hr and 7 MMBTU/h r (Boilers A and B, respectively), and fugitive emissions. T he two boilers and three of the five recovery tanks have shut down. The 1

- hour ozone RACT determination for Exxon (currently Plain Products’ South Terminal) contains source

- specific requirements for fugitive emissions.

The boilers and space heaters are subject to presumptive RACT requirement s in 25 Pa Code section 129.93

. The 20 MMBTU/hr boiler is controlled by performing annual combustion tune

up, pursuant to 25 PA Code 129.93(b)(2). The smaller boiler and the heaters are subject to 25 Pa Code 129.93 (c)(5) to be installed, operated, and maintained in accordance with the manufacturer’s specifications. The source has 13 storage tanks with capacities greater than 40,000 gallons, each storing petroleum organic products (i.e., volatile organic compounds) with a vapor pressure of less than 11 psia under actual storage conditions. The tanks are subject to the CTG requirements of 25 Pa Code 129.56(a)(1).
Plain Products operates a number of emissions units whose VOC emissions are insignificant, and for wh ich RACT has been determined to be no controls. The remaining 23 storage tanks store petroleum organic compounds of l ower volatility (with vapor pressures of less than 1.5 psia) and have each potential VOC emissions of less than 1.0 tons per year. Truck loading operations in the North and South Terminals have been limited to certain loading capacity of distillate oil per rolling 12

- month period, resulting in potential VOC emissions of 1.1 and 2.1 tons per year, respectively. See Title V/State Operating P ermit V10

- 025. Truck loading at the recovery tanks occur s a few times per year at the two recovery tanks with VOC potential emissions of 1.2 pounds per year (lb/yr) of VOC. The lubricity additive systems at the North and South Terminals each have VOC pot ential emissions of less than 1.0 tpy of VOC. Based on its permitting and engineering knowledge, AMS determined that installing any control technology

on these de minimis sources is both technically and economically unreasonable.

At the time of the 1

- ho ur RACT determination, fugitive emissions from pumps, valves, and flanges were identified as VOC sources in both Maritank and Exxon. Per the SIP approved RACT Permit s, the source is required to implement quarterly leak detection and repair (LDAR) program for all pumps, valves, and flanges in VOC service. At this time, fugitive emissions of Plain Products are also subject to AMR V section XIII, which prohibit s fugitive emissions of VOC in the concentration of 10,000 ppmv or greater, as measured by Pennsylv ania’s approved test methods. Because the requirements of AMR V section XIII apply at all times and establish specific leak threshold, AMS finds these requirements to be more stringent than the source

specific RACT requirements. AMS has determined that t he requirements in AMR V s ection XIII will supersede the source

- specific LDAR requirements specified in the SIP. Consequently,46

AMS proposes to re place the existing source

- specific requirements in the SIP with a condition requiring compliance with AMR V se ction XIII.

The 1

- hour ozone RACT determination identified five recovery tanks which stored material recovered from the barge cleaning plant. At the time, the tanks were emptied from the recovered barge cleaning material once the maximum capacity was rea ched, by loading the material into trucks. Per the Maritank RACT Permit , the source is required to connect the tanks to a vapor recovery system to recover any vapors from organic materials being loaded into trucks. Since the 1

- hour RACT plan approval was issued, the barge cleaning plant was shut down and three of the five recovery tanks were removed. Currently, the remaining two recovery tanks store a recovered mixture of number 2 and number 6 oil (both with a RVP well below 4 psi) and water from a groun dwater remediation process. Truck loading from the remaining recovery tanks continue to occur. Once the two recovery tanks are utilized to maximum capacity, the tanks are emptied by loading the materials into trucks, which now usually occur s only two or three times per year.
AMS explains that the potential VOC emissions from loading the recovered barge cleaning material from the recovery tanks into trucks prior the operation of the required vapor recovery control (i.e., uncontrolled) was 2 tpy . VOC em issions were expected to be reduced to 400 lb/yr for the loading operations, assuming the expected overall control efficiency of 90% for the required vapor recovery system. AMS estimated that based on the current use of the tanks, the uncontrolled potenti al emissions from the truck loading at the recovery tanks is 1.2 lb/yr of VOC. Due to the current level of uncontrolled potential emissions, AMS believes that the air quality benefit from the operation of the vapor recovery or any other control would be i nsignificant
, thus making operation of controls cost ineffective and unreasonable

. Therefore
, AMS concludes that there is no need to continue to require vapor recovery unit or any other control for this source. AMS requests to remove the control requirem ent from the SIP for the truck loading at the two remaining recovery tanks given the changes in operation and subsequent ineffectiveness of controls

. EPA does not expect any emissions increases to result from this particular revision.

Marine loading was referred to as the dock transfer station in the SIP approved RACT permit for Maritank . The Maritank RACT Permit required the source to cease by September 28, 1994 the loading at the dock transfer station of gasoline
, or any organic liquid with RVP of 4 ps i or greater, by Pennsylvania’ s approved definitions

. Because Plain Product is not allowed to load gasoline liquid organics (with RVP of 4.0 psi or greater), the source is not subject to the RACT requirements of Subpart Y. Consequently, the loading opera tions continue to be subject to

source

- specific RACT under 25 Pa code section 129.91

- 92.

AMS evaluated available controls for the Plain Product s ’ s marine loading operations,47

including thermal oxidation, carbon adsorption, bioreactor, wet scrubbers, and co ndensation via refrigeration . AMS determined that these additional controls are not technically and/or economically reasonable for the marine loading operations and thus do not represent RACT. AMS est imated VOC potential emissions from the marine loading operations of 6.6 tpy, based on number 2 fuel oil, the highest VOC emitting material that is loaded at the source

. AMS has adopted as RACT an additional VOC emissions limit of 6 tpy for the source ’s marine loading operations
, in addition to the existing 1

- hour ozone RACT requirements t o represent VOC RACT under the 1997 8

- hour ozone standard for the marine ves sel loading operations in Plain Products.

All new and revised source

- specific RACT requirements for Plain Products have been incorporated in the revised RACT Permit PA

- 51

- 5013, effective in February 9, 2016
, which was submitted for approval into the SIP to replace the previous version of this permit dated December 28, 1995

. AMS is revising the SIP to remove the RACT Permit PA

- PA

- 51

- 5008 for Exxon (effective May 29, 1995), as all applicable source

- specific requirements have been subsumed into the outstanding RACT Permit PA

- 51

- 5013.

EPA finds that th e RACT determination provided by AMS is reasonable and appropriately considered technically and econo mically feasible controls while setting lowest achievable limits and that the proposed source

- specific RACT controls adequately meet RACT under the 1997 8

- hour ozone NAAQS for Plain Products. EPA also finds that the proposed SIP revisions to meet RACT wil l not result in additional VOC emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement

.

12. Temple

- Health Sciences Campus ( PLID

- 08906) Temple University is an educational institution providing heat, power, and hot water to numerous institutional buildings . The Health Sciences Campus (Temple

- Health), located in 3401 North Broad Street, Philadelphia , Pennsylvania, is a major source of NOx . The facility operat es the following NOx e mission units: Three 76.4 MMBTU/hr boilers (Boilers #1, #2, and #3), two boilers with heat input capacities of less than 2 MMBTU/hr, and 20 emergency generators and fire pumps. The source is subjec t to a 1

- hour ozone RACT determination, as specified in RACT Permit PA

- 51

- 8906 , effective on May 27, 1995 and approved into the SIP on December 15, 2000. 65 FR 78418. EPA’s December 13, 2013 conditional approval required AMS to submit a source

- specific R ACT determination for Temple

- Health , as AMS had indicated the source has adopted or will adopt additional controls after the 1

- hour RACT determination that should represent RACT under the 1997 8

- hour ozone NAAQS.

The two smaller boilers and 20 emerge ncy generators and fire pumps are subject to the presumptive RACT requ irements of 25 Pa Code section 129.93

. Only Boilers #1, #2, and #3 are48

subject to source

- specific RACT at this time. The 1

- hour RACT determination includes source

specific requirements for Boilers # 1, #2 and # 3 a nd a medical waste incinerator
, the la tter has since shutdown. The three boilers share a common stack and are allowed to combust both natural gas and number 6 fuel oil. The following NOx RACT requirements are approved for the boil ers: Boiler #2 to utilize FGR and low excess air combustion and Boilers #1 and #3 to operate

a fuel flow governing devices limiting the fuel heat input to 50 MMBTU/hr each. The heat input limit on Boilers #1 and #3 allowed each boiler to be subject to th e presumptive requirements in 25 Pa Code s ection 129.93( b)(2) instead of source

- specific controls, which s pecifies RACT as the performance of an annual adjustment or tune

- up on the combustion process.

After the 1

- hour RACT plan approval was issued, Tem ple

- Health discovered that installing the FGR was technically infeasible for Boiler #2. Installation of the FGR was not possible due to a number of technical difficulties that were encountered by the source when attempting to engineer its application in Boiler #2 , as further discussed in the AMS technical memorandum

. As a result, Temple

- Health proposed to modify the RACT requirements to replace the approved control and heat input restrictions with burner modifications for each of the three boiler s

. Add itionally, the source proposed the following NOx emissions limits for each boiler: 0.067 lbs/MMBTU while burning natural gas and for combusting number 6 fuel oil either 0.25 lb/MMBTU for fuel oil with nitrogen content (N) of 0.25 or less or a variable NO x emissions
rate for fuel oil wit h N greater than 0.25 lb/MMBTU based on a correlation between N and the fuel heating value of the fuel oil (X) ( i n MMBTU per gallons (MMBTU/gal)), specifically 0.25 + (0.073059 / X) * (N

- 0.25)

. 18 The source also proposed th e following restrictions for the three boilers: combined NOx emissions limit of 56.5 lb/hr and combined heat input limit of 673,894 MMBTU per rolling 12

- month period. 19

The number 6 fuel oil emissions limit s proposed by the source were based on the fact that NOx emissions from burning the fuel would be affected by variations in nitrogen content. To improve enforceability of the RACT requirements, AMS is proposing to revis e the two

- prong NOx emissions limit for number 6 oil combustion to a n absolute valu e NOx emissions limit of 0.40 lbs/MMBTU. The revised l imit s w ere determined by AMS based on historical fuel shipment data from the source indicat ing that 0.57 is the highest nitrogen content received and the assumed correlation for NOx emissions from numb er 6 fuel oil combustion

. AMS is proposing the combined NOx emissions limit and the combined heat input limit to adequately meet RACT at this time.

18 In estimating the NOx emissions limit for number 6 fuel oil with N greate r than 0.25, the source has often relied

on a standard number oil heating value of 0.15 MMB TU/gal. 19 The source requested revisions to the RACT requirements to be approved into a permit. AMS issued Plan Approval 05198 dated April 16, 2008. However, such permit conditions were not submitted to EPA as RACT for approval into the SIP. EPA has n ot treated such modification as RACT until this time.49

AMS has shown that the revised limits and controls will achieve additional reductions of NOx emissions tha n those expected by the implementation of 1

- hour RACT, as specified in the SIP approved RACT Permit

. Table 1 3 below summarizes the NOx emissions resulting from the approved RACT requirements and the proposed revisions to RACT , based on combustion of numbe r 6 fuel oil, the highest emitting fuel

. T he revisions will resul t in reductions of hourly NOx emissions of 25.6 lb/hr , based on the combined hourly NO x limit of 56.3 lb/hr , and reductions of annual NOx emissions of 223 .9 tons per year , based on the combi ned annual heat input limit of 673,894 MMBTU per rolling 12

- month period

. This shows that the proposed revisions to the NOx RACT will result in additional benefits to air quality, and thus will not interfere with the attainment of the ozone NAAQS or any o ther NAAQS
, thus addressing requirements in CAA section 110(l) for this revised RACT

.

Table 1 3

. Summary of Proposed RACT Revisions for Boilers #1, #2, and #3 at Temple

Health Approved RACT Requirements Proposed Revisions to RACT Requirements

Heat Inp ut (MMBTU/ hr) NOx

emissions rate (lb/ MMBTU) a Potential

NOx Emissions (lb/hr) Potential

NOx Emissions (tpy) Heat Input

(MMBTU/ hr) NOx

emissions rate (lb/ MMBTU) Potential

NOx Emissions (lb/hr) Potential

NOx Emissions (tpy) Boiler #1 50 * 0.53 26.68 116.86 76.4 0.40* 30.56 133.85 Boiler #2 76.4 0.37 28.54 125.00 76.4 0.40* 30.56 133.85 Boiler #3 50 * 0.53 26.68 116.86 76.4 0.40* 30.56 133.85 Combined

- - 81.90 358.72 56.3* 134.78 b * Denotes f

ederally enforceable limits.

a NOx emissions rates provide d are based on EPA’s AP

- 42 methodology, the hi storical hi ghest nitrogen content observed (0.57) and the standard heating value for number 6 fuel oil (0.15 MMBTU/hr). For Boiler #2 particularly, the emissions rate also assumes a 30% NOx reduction.
b Combi ned a nnual NOx emissions are based on the combined annual limit for heat input capacity of 673,894 MMBTU per 12

- month rolling basis.

Further, AMS ’ s technical memorandum indicates that Boilers #1 , #2, and # 3 have almost exclusively burned natural gas in re cent years, with number 6 oil combusted on occasions when natural gas is interrupted. AMS has determined RACT for the 1997 8

- hour ozone standard for Boilers #1, #2, and #3 to be the require ment to burn natural gas as primary fuel during ozone season ( Apri l 1 through October 31) of any given year
, except when natural gas supply is interrupted or curtailed , at which time burning of number 6 fuel oil is allowed . AMS explains that the number 6 fuel oil r estriction (i.e., to combust gas as primary fuel) i s unr easonable during colder months outside the ozone season for any given year due to frequent price increases of natural gas as a result of higher demand of the natural gas fuel during that time; and also since significantly lower NOx emissions are generally emitted in Philadelphia during the colder months, resulting in lower impacts to attainment of the NAAQS

.50

A MS evaluated additional controls for RACT for each of the b oiler s , including SCR, SNCR, ULNB , switching from number 6 oil fuel to number 2 fuel oil, and completely eliminating number 6 fuel oil burning (i.e., 100% natural gas combustion). As explained in the technical memorandum , Temple

- Health is a certified healthcare facility and must have a backup fuel available at all times in order to prevent los s of use of life

- critical equipment should the primary fuel supply be interrupted. Thus, switching to natural gas combustion alone is not a reasonable

n or feasible option as determined by AMS

. EPA finds this determination reasonable based on the critical operational function of Temple

- Health. Additionally, AMS has shown that switching to number 2 fuel oil is not economically reasonable based on the expected NOx emissions reductions from the fuel switch

. AMS determined that no additional controls were te chnically and/or economically reasonable. Thus, AMS proposed as RACT under the 1997 8

- hour ozone RACT the NOx emissions limits and controls proposed by the facility, with the exception of revising the proposed NOx emissions limit for number 6 fu el oil bur ning to 0.40 lb/MMBTU and adding a restriction to primarily burn natural gas during ozone season of any year, unless there is gas curtailment or interruption during the allocated time frame , in which time number 6 fuel oil is allowed

. AMS determined these requirements to represent NOx RACT under the 1997 8

- hour ozone NAAQS for Temple

- Health’s Boilers #1, #2 and #3 and, thus, is requesting to update the SIP approved RACT determination to incorporate them accordingly.

The revised source

- specific RACT req uirements for Temple

- Health have been incorporated in the revised RACT Permit PA

- 51

- 8906, effective on January 9, 2015, and submitted for approval into the SIP. EPA finds that the RACT determination provided by AMS is reasonable and appropriately conside red technically and economically feasible controls while setting lowest achievable limits and that the proposed source

- specific RACT controls adequately meet RACT under the 1997 8

- hour ozone NAAQS for Temple

- Health. EPA also finds that the proposed revisi ons to meet RACT will result in equivalent or additional reductions of NOx emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA re quirement

.

13. V eolia Energy

- Edison (formerly TRIGEN

- Edison Station ) (PLID

- 04902) Veolia Energy Philadelphia

- Edison Station (Veolia

- Edison) is as steam generating facility located at 908 Samson Street, Philadelphia , Pennsylvania . The facility is a maj or source of NOx and contains the following NOx emissions units: Two boilers rated 283 MMBTU/hr (Boilers #1 and #2) and two boilers rated 335 MMBTU/hr (Boilers #3 and #4); all front

- fired and burning number 6 oil as the primary fuel and number 2 oil as the ignition fuel.

EPA’s December 13, 2013 conditional approval required AMS to submit a source

- specific RACT determination for this source , as AMS had indicated it was relying on the NOx SIP Call for RACT compliance. AMS has clarified that this source wa s previously evaluated under the 1

- hour ozone standard and has been subject to a source

- specific RACT determination under 25 Pa51

Code sections 129.91

- 92. The 1

- hour ozone RACT determination for Veolia

- Edison is specified in RACT P ermit PA

- 51

- 4902 under th e facility’s former name TRIGEN

- Edison Station, effective on May 29, 1995 and approved in the SIP on December 15, 2000. 65 FR 78418. EPA confirms that the 1

- hour RACT determination for Veolia

- Edison does not rely on the presumption that compliance with the NOx SIP Call constituted RACT for any of its emissions units . AMS has re

- evaluated RACT for each emissions unit to ensure compliance with 25 Pa Code sections 129.91

- 92. EPA also notes that the conditional approval identified this source as an EGU, ho wever, AMS has clarified that Veolia

- Edison is dedicated solely to steam generation and not electricity generation

. As part of the 1

- hour ozone RACT determination
, the following NOx RACT requirements apply to the four boilers : E ach boiler is subject to a NOx limit of 0.50 lb/MMBTU and all boilers have a combined number 6 oil limit of 65,526,316 gallons and a combined NOx emissions limit of 2,195 tons, both limits per 12

- month rolling period. Since the 1

- hour RACT determination, each boiler is subject to a f ederally enforceable restriction of an annual 30% capacity factor based on hourly maximum heat input, which significantly has reduced operations of each unit and the source ’s potential NOx emissions. See Title V P ermit V11

- 021 issued May 13, 2013 and AMS Plan Approval 06167A, dated March 11, 2013.

AMS evaluated the following controls for the boilers: ULNB, SCR, SNCR, FGR, ULNB wit h natural gas, and other combustion modifications. AMS determined that these controls are not technically n or economicall y reasonable for the boilers and thus do not represent RACT

. However, to reflect lowest achievable emissions limits for RACT, AMS is proposing to reduce the NOx emissions limits for Boilers #1 and #2 from 0.50 to 0.39 lb/MMBTU and to add a NOx limit of 14 5.02 tons per 12

- month rolling period, based on the 30% capacity factor. EPA anticipate s that these revisions sh ould result in reductions of potential NOx emissions of 47 5 tons in any given year , as provided in T able 1 4 below

.

Table 1 4

. Summary of Propos ed RACT Revisions for Boilers #1 and #2 at Veolia

- Edison (Per Boiler)

Heat Input (MMBTU/ hr) Approved RACT Requirements Proposed Revisions to RACT Requirements NOx emissions rate (lb/ MMBTU) Potential

NOx Emissions (lb/hr) Potential

NOx Emissions (tpy) N Ox

emissions rate (lb/ MMBTU) Potential

NOx Emissions (lb/hr) Potential

NOx Emissions (tpy) 283 0.50* 141.5 619.77 0.39* 110.37 145.02* * Denotes f

ederally enforceable limits.
AMS is also proposing to reduce the NOx emissions limits for Boilers #3 and #4 from 0.50 to 0.38 lb/MMBTU and to add a NOx limit of 167.28 tons per 12

- month rolling period, based on the 30% capacity factor. EPA anticipate s that these revisions sh ould result in reductions of52

potential NOx emissions of 566 tons in any given year , a s provided in T able 1 5 below

.

Table 1 5

. Summary of Proposed RACT Revisions for Boilers #3 and #4 at Veolia

- Edison (Per Boiler )

Approved RACT Requirements Proposed Revisions to RACT Requirements Heat Input (MMBTU/ hr) NOx

emissions rate (lb/ MMBTU) Potent ial

NOx Emissions (lb/hr) Potential

NOx Emissions (tpy) Heat Input

(MMBTU/ hr) NOx

emissions rate (lb/ MMBTU) Potential

NOx Emissions (lb/hr) Potential

NOx Emissions (tpy) 335 0.50 * 167.5 733.65 335 0.38 * 127.3 167.28 * * Denotes f

ederally enforceable lim its.
By revising the existing RACT requirements and taking additional NOx emissions limits on the boilers, the combined NOx emissions from Boilers #1, #2, #3, and #4 have been reduced to 624.6 tons per year , which is lower than the combined NOx emission l imit approved as RACT

. AMS also indicated that the potential NOx emissions achieved by the original number 6 fuel usage limit is 1,539.8 tons in any given year (based on 47 pounds of NOx produced when burning a thousand gallons of the fuel), thus the new restrictions will result in lower NOx emissions than this limit. Since the combined NOx emissions limit and the combined fuel usage limit do no longer represent the lowest level of NOx control, AMS is proposing to remove both conditions.

AMS determined the revised NOx requirements altogether represent NOx RACT under the 1997 8

- hour ozone NAAQS for Veolia

- Edison’s Boilers #1, #2, #3 and #4, and, thus, is requesting to update the SIP approved RACT determination to incorporate them accordingly.

The revi sed source

- specific RACT requirements for Veolia

- Edison have been incorporated in the revised RACT Permit PA

- 51

- 4902, effective on January 9, 2015, which was submitted for approval into the SIP. EPA finds that the RACT determination provided by AMS is re asonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source

- specific RACT controls adequately meet RACT under the 1997 8

- hour ozone NAAQS for Veolia

- Edison. EPA also finds that the proposed revisions to meet RACT will result in additional reductions of NOx emissions and thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with ot her applicable CAA requirement.

14. V eolia Energy

- Schuylkill Station (formerly TRIGEN

- Schuylkill Station ) (PLID

04942) ; Grays Ferry Cogeneration Partnership (PLID

- 04944); Veolia

- Energy Efficiency (PLID

- 10459) Veolia Energy

- Schuylkill Station (Veolia

- Schuylkill), Grays Ferry Cogeneration Partnership (Grays Ferry), and Veolia

- Energy Efficiency have been determined a single source for permitting and RACT purposes for being located adjacent ly at 2600 Christian Street,53

Philadelphia, Pennsylvania and havin g common ownership . The three facilities altogether are considered a major source of NOx. AMS submitted separate technical memorandums for each facility

. EPA is discussing the submitted RACT evaluation for each facility below

.

a. V eolia

- Schuylkill (PLID

- 04942) Veolia

- Schuylkill is as steam generating facility containing the following NOx emissions units: a tangentially fired boiler rated 795 MMBTU/hr (Boiler #23) and a front

- wall fired boiler rated 761 MMBTU/hr (Boiler #26); both burning number 6 oil as the primary fuel and number 2 oil as the ignition fuel.

EPA’s December 13, 2013 conditional approval required AMS to submit a source

- specific RACT determination for this source , as AMS had indicated it was relying on the NOx SIP Call for RACT complianc e. AMS has clarified that this source was previously evaluated under the 1

- hour ozone standard and has been subject to a source

- specific RACT determination under 25 Pa Code sections 129.91

- 92. The 1

- hour ozone RACT determination for Veol ia

- Schuylkill is specified in RACT P ermit PA

- 51

- 4942, issued on December 1, 1999 and approved into the SIP. See 65 FR 78418 ( December 15, 2000 ) . EPA confirms that the 1

- hour RACT determination for Veolia

- Schuylkill does not rely on the presumption that compliance with the NOx SIP Call constituted RACT for any of its emissions units . AMS has re

- evaluated RACT for each emissions unit to ensure compliance with 25 Pa Code sections 129.91

- 92. EPA also notes that the conditional approval identified this source as an EGU, ho wever, AMS has clarified that Veolia

- Schuylkill is dedicated solely to steam generation and not electricity generation.

The 1

- hour ozone RACT determination addressed Boilers #23 and #26 in addition to Boiler #24
, a tangentially fired boiler rated 795 MM BTU/hr that was shutdown in 2014. See Plan Approval 10277. As part of the 1

- hour ozone RACT determination , Boilers #23 and #24 are subject to a NOx limit of 0. 35 lb/MMBTU ; Boiler #26 is subject to a NOx limit of 0.36 lb/MMBTU on a 30

- day rolling average and the requirement to operate a LNB; and all boilers have a combined number 6 oil limit of 65,526,316 gallons per 12

- month rolling period and a combined NOx emissions limit of 1
, 646 tons per 12

- month rolling period

. AMS evaluated additional NOx controls for Boilers #23 and #26, including SCR, SNCR, ULNB, ULNB with natural gas, LNB, FGR
, and other burner modifications. AMS determined that these controls are not technically n or economically reasonable for the boiler s and thus do not represent RACT.

Sinc e the 1

- hour RACT determination, Boiler #23 is subject to a f ederally enforceable restriction to operate up to 30% of its hourly maximum heat input in any given year (i.e., capacity factor ) , which significantly has reduced operations of the emissions unit and its potential NOx emissions. See Title V P ermit V11

- 014 issued May 24, 2012. AMS is proposing to reduce the NOx emissions limits for Boilers #23 from 0. 35 to 0.3 4 lb/MMBTU and to add a NOx limit of 355.15 tons per 12

- month rolling period, based on th e 30% capacity factor. EPA54

anticipates that these revisions sh ould result in reductions of potential NOx emissions of 863 tons in any given year, as provided in T able 1 6 below.

Table 1 6

. Summary of Proposed RACT Revisions for Boilers #23 at Veolia

- Schuy lkill Heat Input (MMBTU/ hr) Approved RACT Requirements Proposed Revisions to RACT Requirements

NOx emissions rate (lb/ MMBTU) Potential

Fuel Usage (gal/year) a Potential

NOx Emissions (lb/hr) Potential

NOx Emissions (tpy) NOx

emissions rate (lb/ MMBTU) P otential

Fuel Usage (gal/year) b Potential

NOx Emissions (lb/hr) Potential

NOx Emissions (tpy) 795 0.35* 46,428,000 278.25 1218.74 0.34* 13
, 9 28, 4 00 270.30 355.15* * Denotes f

ederally enforceable limits.

a Refers to number 6 fuel oil usage and was estima ted assuming standard heating value of 0.15 MMBTU/gal.
b Refers to number 6 fuel oil usage and was estimated assuming standard heating value of 0.15 MMBTU/gal and a 30% capacity factor.

AMS fin ds that the existing RACT requirements for Boiler # 26 , in cluding the NOx limit of 0.36 lb/MMBTU on a 30

- day rolling average
, continue to represent RACT. In addition , to ensure lower NOx emissions during shorter time perio ds, AMS is proposi ng to add as RACT the NOx emissions limit of 0.41 lbs/MMBTU limit and its equivalent limit of 312.01 lbs/hr
, both not to be exceeded in an hour ly basis. Compliance with the hourly limits will be determined with NOx continuous emissions monitoring system (CEMS). EPA expects equivalent emission reductions of NOx emissions on an annual basis.

AMS indicates that the additional proposed restrictions on Boilers #23 and #26 and the shutdown of Boiler #24 result in lower number 6 oil usage and combined NOx emissions than
t he 1

- hour RACT combined limits for the three boilers. Theref ore, AMS is proposing to remove these two combined limits from the SIP, as well as any reference to Boiler #24. EPA does not expect any emissions increases from removing these requirements.

AMS determined the revised NOx requirements altogether represe nt NOx RACT under the 1997 8

- hour ozone NAAQS for Boilers #23 and #26 at Veolia

- Schuylkill, and, thus, is requesting to update the SIP approved RACT determination to incorporate them accordingly. The revised source

- specific RACT requirements for Veolia

- Schuylkill NAAQS have been incorporated in the revised RACT Permit PA

- 51

- 4942 , effective on February 9, 2016
, which was submitted for approval into the SIP to replace the previous version of this permit dated May 29, 1995

.

EPA finds that the RACT determ ination provided by AMS is reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source

- specific RACT controls adequately meet RACT under the 1997 8

- hour ozone NA AQS for Veolia

- Schuylkill . EPA also finds that the proposed revisions to meet RACT will result in equivalent or additional reductions of NOx emissions and thus should not55

interfere with any applicable requirement concerning attainment or reasonable furth er progress with the NAAQS or interfere with other applicable CAA requirement.

b. Grays Ferry (PLID

- 04944) Grays Ferry is as an electric utility operating one front wall

- fired boilers rated 1119 MMBTU/hr (Boiler # 25) and one combined cycle combustion turbi ne rated 1515 MMBTU/hr (135 MW), with a Heat R ecovery Steam Generator (HRSG). Both emissions units combust natural gas and number 2 fuel oil.

Currently, Boiler #25 is subject to the following f ederally enforceable NOx requirements: NOx emissions limit s of 0.10 lb/MMBTU when firing natural gas and 0.15 lb/MMBTU when firing number 2 fuel oil, and the operation of LNB and FGR. See AMS Plan Approval 97019 dated March 8, 2001. AMS evaluated additional NOx controls for Boiler #25, including: SCR, SNCR, ULN B, and ULNB with overfire air. AMS determined that these additional controls are not technically n or economically reasonable for the boiler and thus do not represent RACT. AMS determined that the currently applicable NOx limits and controls represent RAC T under the 1997 8

- hour ozone NAAQS.

The combustion turbine is currently subject to the following f ederally enforceable NOx requirements: NOx emissions limits of 0.0344 lb/MMBTU when firing gas, 0.1683 lb/MMBTU when firing number 2 fuel oil, and 255 lb/h r, and the operation of SCR and dry low NOx (DLN) when firing natural gas and SCR and water injection when firing number 2 fuel oil. Additionally, the combined NOx emissions from the combustion turbine and the HRSG are limited to 298.8 lb/hr. See AMS Pla n Approval 97019 dated March 8, 2001. AMS determined that the current controls, with a 90

- 98% control efficiency, represent the most stringent NOx control option for this unit. AMS determined that the lb/hr NOx limit and current controls represent RACT u nder the 1997 8

- hour ozone NAAQS.

The new RACT requirements for Grays Ferry have been incorporated in the RACT Permit PA

- 51

- 4944 , effective on January 9, 2015 , which was submitted for approval into the SIP

. EPA finds that the RACT determination provide d by AMS is reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source

- specific RACT controls adequately meet RACT under the 1997 8

- hour ozone NAAQS for Grays F erry.

c. Veolia

- Energy Efficiency (PLID

- 10459) Veolia

- Energy Efficiency is a steam generating facility that started operations in 2013. Its NOx emissions units are two new 297.91 MMBTU/hr boilers burning natural gas and number 2 fuel oil. Each boiler is currently equipped with ULNB and is subject to the following federable enforceable NOx emission limits: 0.01 lbs/MMBTU while burning gas and 0.08 lbs/MMBTU56

while burning oil each on a 30

- day rolling average, and a combined NOx emissions limit of 52.31 tons per rolling 12

- month period. See Plan Approval No. 10277A, dated on February 13, 2013.

AMS evaluated additional NOx controls as RACT for each of the boilers, including SCR, SNCR, ULNB, ULNB with overfire air, and LNB. AMS determined these control options to be

n either technically n or economically reasonable, and thus not represent RACT. AMS determined that the currently applicable NOx limits and controls for the three boilers represent RACT under the 1997 8

- hour ozone NAAQS. The new source

- speci fic RACT requirements for Veolia

- Energy Efficiency have been incorporated in the RACT Permit PA

- 51

- 10459 , effective on January 9, 2015, which was submitted for approval into the SIP.

EPA finds that the RACT determination provided by AMS is reasonable a nd appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source

- specific RACT controls adequately meet RACT under the 1997 8

- hour ozone NAAQS for Veolia

- Energy Efficiency.

A

- 2. New RACT Source s with Source

- Specific RACT Determinations 1. Philadelphia Prison System (PLID

- 09519) Philadelphia Prison System is a correctional institution located at 8001 State Road, Philadelphia, Pennsylvania . The facility is a major source of NOx operating the following NOx emissions units: 57 boilers rated under 15 MMBTU/hr burning number 2 oil fuel and natural gas, 10 diesel

- burning emergency generators with rating of 2,200 HP or less , and a 365 HP chiller burning natural gas.

The 57 small boi lers and the emergency generators are subject to presumptive requirements of 25 Pa Code section 129.93 (c)

. The 365 HP chiller is the only emissions unit subject to source

specific RACT under the 1997 8

- hour ozone NAAQS. The chiller is currently subject t o the following f

ederally enforceable requirements for NOx emissions: NOx emission limit of 2.0 grams per brake horsepower

- hour and the operation of a SNCR. See AMS Plan Approval 11052

. AMS finds that the SNCR is the most stringent control for the type of emissions unit. Therefore, AMS determines that these requirements represent RACT under the 1997 8

- hour ozone NAAQS for the chiller, as the limit is the lowest achievable emission rate achieved with the most stringent control technology available.

Th e source

- specific RACT requirements for Philadelphia Prison System under the 1997 8

- hour ozone NAAQS have been incorporated in RACT Permit PA

- 51

- 9519, effective on February 9, 2016 , which was submitted for approval into the SIP

. EPA finds that the RACT de termination provided by AMS is reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable limits and that the proposed source

- specific RACT controls adequately meet RACT under the 1997 8

- hour ozon e NAAQS for Philadelphia57

Prison System.

2. Temple

- Main Campus (PLID

- 08905) Temple University is an educational institution providing heat, power, and hot water to numerous institutional buildings . The Main Sciences Campus (Temple

- Main), located in Broad Street and Montgomery Avenue
, Philadelphia , Pennsylvania, is a major source of NOx , for

o perat ing the following NOx emitting units: T en natural gas fired electric generators with capacity of 1,600 kilowatts (kW); three water

- tube boilers firing natural g as or oil with heat input ratings of 91.3 MMBTU/hr for natural gas and 86.8 MMBTU/hr for number 2 fuel oil; and other smaller combustion units, including 59 emergency generators and fire pumps and 21 heaters or boilers with heat input capacities of less th an 50 MMBTU/hr. The three larger boilers and the electric generators are subject to the source

- specific requirements of 25 Pa Code sections 129.91

- 9 2

. The smaller combustion units are subject to the presumptive RACT requirement s of 25 Pa Code section 129 .93.

The three water

- tube boilers are subject to t he following f ederally enforceable NOx requirements: E ach with NOx emissions limits of 0.036 lb/MMBTU when firing natural gas and 0.110 lb/MMBTU when firing number 2 fuel oil; the combined NOx emissions limit of 15.5 tons per 12

- month rolling period; and the operation of LNB and FGR on each unit. See AMS Plan Approval 07132 dated November 27, 2007. AMS evaluated additional NOx controls as RACT for each of the boilers, including SCR, SNCR, and water/ste am injection. AMS determined these control options to be n either technically n or economically reasonable, and thus do not represent RACT. AMS determined that the currently applicable NOx limits and controls for the three boilers represent RACT under the 1997 8

- hour ozone NAAQS.

The 10 electricity generating units are 4

- stroke lean

- burn natural gas fired engines. The engines are currently subject to the following f ederally enforceable NOx requirements: NOx emission limits from each unit are limited to 2 .00 grams per boiler horsepower per hour (g/bHP

hr) and combined NOx emissions are limited to 99 lb/hr; and also hour of operation are limited to 500 hours per 12

- month rolling period. See AMS Plan Approval 92087 dated October 2, 1992. AMS evaluated NOx controls available to date for the generators, including SCR and SNCR, and determined them to be technically and/or economically unreasonable, and thus not RACT. AMS is determining the applicable NOx emissions limits and controls for the 10 electric gener ating units to represent RACT under the 1997 8

- hour ozone NAAQS.

The source

- specific RACT requirements for Temple

- Main have been incorporated in the RACT Permit PA

- 51

- 8905, effective on January 9, 2015, which has been submitted for approval into the SI P in replacement of the previous version of this permit dated May 27, 1995

. EPA finds that the RACT determination provided by AMS is reasonable and appropriately considered technically and economically feasible controls while setting lowest achievable lim its and that the58

proposed source

- specific RACT controls adequately meet RACT under the 1997 8

- hour ozone NAAQS for Temple

- Main.

B. Other Revisions to Previous Source

- Specific RACT Determinations 1. Cardone Industries, Inc.

- Rising Sun Avenue Plant (PLID

- 03 887) and Whitaker Avenue Plant ( PLID

- 02287 ) Cardone Industries (Cardone) owns and operates a n automotive parts manufacturing facility in two adjacent plants located at 5660 Rising Sun Avenue and 5501 Whitaker Ave nue in Philadelphia
, Pennsylvania

. The fac ility is a major VOC source and is subject to 1

- hour ozone RACT. The source’s emissions units include the following: 8 spray booths for surface coating operations; cold degreasing operations (5 degreasers) ; 11 burnout ovens with less than 20 MMBTU/hr; a d iesel

- fired emergency generator with rating of 1.9 MMBTU/hr; and various minor combustion units with less than 20 MMBTU/hr, such as washers, ovens, cleaners, heaters, and pumps.

At the time of the 1

- hour ozone RACT determination, Cardone operated five p lants in Philadelphia: 321 C hew Street (PLID

- 0 2237 ); 500 East Erie Avenue ( PLID

- 0 3888 ); 5500 Tabor Road ( PLID

- 0 3233 ); 5501 Whitaker Avenue ( PLID

- 0 2287 ); and 5660 Risin g Sun Avenue, ( PLID

- 0 3887 ). Only the Chew Street and Rising Sun Avenue Plants were major sources of VOC at that time, and thus are subject source

- specific RACT requirements approved under the 1

- hour ozone NAAQS , as specified in RACT Permit s PA

- 51

- 2237 and PA

- 51

- 3887 respectively , both effective on May 29, 1995 and approved into the SIP

. See 66 FR 54710 (October 30, 2001 )

. Currently, the Chew Street Plant has shut down entirely, and o nly the Rising Sun Avenue and the Whitaker Avenue Plants remain in operation were evaluated for RACT as a major VOC source

.

S ource

- specific RACT requirem ents under the 1

- hour ozone NAAQS were approved for the degreasing operations in both Chew Street and Rising Avenue Plants, as specified in each SIP approved RACT Permit

. Since all operations at Cardone ’s Chew Street Plant have been permanently shut down
, AMS is revising the SIP to remove the RACT Permit PA

- 51

- 2237 for Cardone’s Chew Street Plant. The SIP approved RACT Permit PA

- 51

- 3887 specifies source

specific RACT requirements for the degreasing operations with solvent recovery (of Stoddard solvents) a nd application of miscellaneous architectural coatings at Cardone’s Rising Sun Avenue P lant. AMS explains that Cardone no longer uses Stoddard solvents in its degreasing operations or architectural coatings, thus the existing source

- specific RACT requirem ents are no longer applicable. Consequently, AMS is revising the SIP to remove the RACT Permit PA

- 51

- 3887 for Cardone’s Rising Sun Avenue

. EPA does not expect these SIP revisions (to remove previous RACT determinations) to have any impacts to emission re ductions or air quality; thus should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement

.59

All operating units to date in Cardone at the Chew S treet and Rising Sun Avenue Plants are subject to presumptive or CTG RACT requirements. Surface coating operations are subject to 25 Pa code 129.52. Degreasing operations are subject to 2 5 PA Code 129.63 and AMR V section XIII.A. The combustion units, t he burn off ovens, and the emergency generator are subject to the presumptive requirements of 25 Pa Code 129.93(c)(5). The emergency generator is subject to a f

ederally enforceable restriction to operate less than 500 hours in any consecutive 12

- month per iod. The presumptive and CTG requirements discussed above represent RACT for Cardone under the 1997 8

- hour ozone NAAQS.

EPA finds AMS’ evaluation reasonable and proposes to remove the RACT permits from the SIP for Cardone Chew Street and Rising Sun Av enue as these are no longer applicable. This proposed SIP revision will not lead to additional NOx or VOC emissions and thus not interfere with any NAAQS or applicable CAA requirement. EPA finds reasonable AMS’ conclusion that presumptive and CTG require ments discussed adequately address RACT for Cardone’s remaining emission units for the 1997 8

- hour ozone NAAQS.

C. Revisions and Certifications For Sources No Longer Subject to 1997 8

- hour Ozone RACT In the February 18, 2015 RACT SIP Revision, AMS include d the November 1, 2014 technical memorandum entitled “1

- Hour RAC T Facilities not in 8

- hour RACT ” identifying 27 facilities subject to source

- specific RACT determinations for the 1

- hour ozone NAAQS
, that are
no longer subject to RACT for purposes of the 199 7 8

- hour ozone NAAQS

. AMS indicates that 18 of these facilities have permanently shut down, while the remaining 9 are no longer considered major sources of NOx/VOC emissions for RACT under the 1997 8

- hour ozone NAAQS (i.e., less than 100 or 50 tpy , respec tively)

. Sources that remain in operation must still comply with the SIP approved 1

- hour ozone RACT determinations , although not subject to 1997 8

- hour ozone RACT

.
In 2013, AMS identified Kraft Nabisco, now named Mondelez
, as having adopted additional RA CT controls, based on the previously approved source

- specific RACT determination. For this
reason, EPA’s December 13, 2013 conditional approval required AMS to submit a source

specific RACT determination for this source

. Mondelez is subject to a previous source

- specific RACT determination approved in the SIP under the 1

- hour ozone standard, as specified in the RACT Permit PA

- 51

- 3201 under its former name Nabisco Biscuit Co. ( effective on April 10, 1995 ), for it was considered a major source of NOx and VOC at the time. See 65 FR 78418 ( December 15, 2000 )

. AMS has clarified that in 2012 Mondelez t ook federally enforceable facility

- wide limits of 25 tons per year for both NOx and VOC emissions , restricting the facility’s potential emissions under the applic able thresholds for 1997 8

- hour RACT

. See Synthetic Minor Operating Permit No. S11

- 017 , effective on May 7, 2012

. I n the November 1,60

2014 technical memorandum , AMS lists Mondelez as no longer being considered a major source of NOx and VOC emissions for R ACT under the 1997 8

- hour ozone NAAQS and concludes it should not subject to RACT under the 1997 8

- hour ozone NAAQS. EPA concurs with this conclusion and thus determines that the condition in the December 13, 2013 conditional approval to submit a source

- s pecific RACT determination under the 1997 8

- hour ozone NAAQS for this source is no longer applicable. AMS has further indicated that the facility has ceased production and is in the process of being permanently decommissioned. As noted by AMS and acknowl edged by EPA, while operational, Mondelez will continue to be subject to the source

specific RACT determination approved in the SIP

. As part of the February 18, 2015 RACT SIP Revision , AMS submitted a source

- specific RACT determination for Sun Chemical

- General Printing Ink Division (Sun Chemical) (PLID

02052)
, a commercial printing ink manufacturer located at 3301 W est Hu nting Park Avenue in Philadelphia, P ennsylvania . This facility is a major source of VOC and is subject to a 1

- hour ozone RACT determ ination, as specified in RACT Permit PA

- 51

- 2052, effective on July 14, 2000, and approved in the SIP. See 66 FR 54710 (October 30, 2001). However, in the March 26, 2016 RACT SIP r evision , AMS submitted a new technical memorandum clarifying that the facil ity is no longer a major source of VOC, after adopting in 2015 a facility

- wide limit of VOC of 49 tons per year , and thus requesting to withdraw the source

- specific RACT determination previously submitted in 2015

. See Permit No. 15173 (effective on August 12, 2015 ). Sun Chemical continues to be subject to the source

- specific RACT determination under the 1

- hour ozone standard as approved in the SIP

. EPA agrees that a source

- specific RACT determination is not applicable under the 1997 8

- hour ozone NAAQS fo r this source and concurs with AMS request to withdraw this determination from the February 18, 2015 RACT SIP revision

.

On March 26 , 2016
, AMS s ubmitted the December 14, 2015 memorandum entitled “Certifications Regarding Facilities Previously Subject to Source

- Specific RACT Determinations under the 1

- hour Ozone Standard; and Clarifications on De

- Minimis Determinations.” In this memorandum, AMS , among other things, formally request s to remove from the SIP the source

specific RACT determinations from the s hutdown facilities identified in the November 1, 2014 technical memorandum , as codified in 40 CFR 52.2020(d)(1) . AMS certifies that none of these shutdown facilities have active operating permits or air pollution licenses for any equipment, and that under Pennsylvania and Philadelphia regulations, they cannot operate until further notification and issuance of applicable permits. The shutdown facilities and their respective SIP approved RACT Permit s are listed in Table 1 7

. E PA has reviewed this list and c oncurs with AMS’ recommendation to remove these RACT permits from the Pennsylvania SIP as these sources have permanently shut down.61

Table 1 7

. Shutdown Major Sources of NOx and/or VOC in Philadelphia Subject to Previous Source

- Specific RACT Determinations

Source SIP Approved RACT Permit (Effective Date) EPA’s SIP Approval Date

Aldan Rubber Company PA

- 51

- 1561 (07/21/00) 10/30/01, 66 FR 54691
Amoco Oil Company PA

- 51

- 5011 (05/29/15) 10/31/01, 66 FR 54936
Arbill Industries, Inc PA

- 51

- 3811 ( 0 7/27/99) 10/30/ 01, 66 FR 54691
Braceland Brothers, Inc PA

- 51

- 3679 (07/14/00) 10/30/01, 66 FR 54691
Budd Company PA

- 51

- 1564 (12/28/95) 12/15/00, 65 FR 78418
Eastman Chemical [formerly, McWhorter Technologies, Inc.] PA

- 51

- 3542 ( 0 7/27/99) 10/30/01, 66 FR 54691

Graphic A rts, Incorporated PA

- 51

- 2260 (07/14/00) 10/30/01, 66 FR 54691
Interstate Brands Corporation PA

- 51

- 5811 (04/10/95) 12/15/00, 65 FR 78418
Kurz Hastings, Inc

. PA

- 51

- 1585 ( 05/29/95) 10/31/01, 66 FR 54936
Lawrence McFadden, Inc. PA

- 51

- 2074 ( 0 6/11/97) 10/31/ 01, 66 FR 54936
O'Brien (Philadelphia) Cogeneration, Inc.

— Northeast Water Pollution Control Plant PA

- 51

- 1533 (07/21/00) 10/30/01, 66 FR 54691

O'Brien (Philadelphia) Cogeneration, Inc.

— Southwest Water Pollution Control Plant PA

- 51

- 1534 (07/21/00) 10/30/01 , 66 FR 54691

Pearl Pressman Liberty PA

- 51

- 7721 (07/24/00) 10/30/01, 66 FR 54691
Philadelphia Baking Company PA

- 51

- 3048 ( 0 4/10/95) 10/31/01, 66 FR 54936 Rohm and Haas Company

Philadelphia PA

- 51

- 1531 (07/27/99) 10/31/01, 66 FR 54942
Tasty Baking Co. PA

- 51

- 2054 (04/04/95) 10/31/01, 66 FR 54942
Transit America, Inc. PA

- 51

- 1563 ( 0 6/11/97) 11/5/01, 66 FR 55880

SBF Communications PA

- 51

- 2197 (07/21/00) 10/31/01, 66 FR 54942

V. EPA’s Conclusion After thorough review and evaluation of the information provided by AMS in the Philadelphia RACT SIP revisions for major sources of NOx and/or VOC in Philadelphia, EPA finds that the AMS source

- specific RACT determinations and conclusions provided are62

reasonable and address RACT requirements for Philadelphia f or the 1997 8

- hour ozone NAAQS in accordance with the Phase 2 Ozone Implementation Rule and latest available information. EPA finds that the proposed source

- specific RACT controls and emissions limits in the Philadelphia RACT SIP revisions adequately meet the CAA RACT requirements for the 1997 8

- hour ozone NAAQS for each major source of NOx and VOC in Philadelphia not covered by Pennsylvania RACT regulations.

EPA also finds that the all proposed revisions to previously SIP approved RACT requirements, as discussed in the Philadelphia RACT SIP revisions will result in equivalent or additional reductions of NOx and/or VOC emissions and should not interfere with any applicable requirement concerning attainment or reasonable further progress with the NAAQS or interfere with other applicable CAA requirement in section 110(l) of the CAA. In the case of AMS removal of RACT requirements from the SIP that are no longer applicable, as the sources have been permanently removed, EPA finds these SIP revisions to be ad equate and will not have any adverse impact to air quality.

As discussed earlier, EPA determined in the December 15, 2013 conditional approval that the Philadelphia 1997 8

- hour ozone RACT demonstration as provided in the 2006 and 2010 SIP revisions ade quately met RACT under the CAA, with exception of the source

- specific RACT requirements in 25 PA Code sections 129.91

- 92 and the NOx SIP Call related provisions in the Pennsylvania SIP in 25 Pa Code sections 145.1

- 145.100, 25 Pa Code sections 145.111

- 145.1 13, and 25 Pa Code sections 145.141

- 144. In this proposed rulemaking action, EPA finds that the subsequent Philadelphia RACT SIP revisions adequately correct the two deficiencies identified by EPA on the Philadelphia RACT demonstration, as provided in the 2006 and 2010 SIP revisions, and thus satisfy the December 15, 2013 conditional approval. Based on PADEP’s withdrawal of the certified provisions relying on NOx SIP Call as RACT from the 2006 SIP revision, EPA finds that the remaining certified NOx and/o r VOC regulations, the CTG negative declarations, and the recently adopted regulatory provisions in AMR V sections XV and XVI, submitted as part of the 2006 and 2010 SIP revisions, are consistent with the latest available information and EPA’s guidance and therefore adequately meet RACT for the 1997 8

- hour ozone NAAQS.

Consequently, EPA finds that the Philadelphia 1997 8

- hour ozone RACT demonstration, as provided within the RACT SIP revisions submitted to EPA from 2006 to 2016, address RACT under the 1997 8

- hour ozone NAAQS for all NOx and/or VOC major sources in Philadelphia through: (1) compliance with previously approved RACT regulations in the Pennsylvania SIP, including but not limited to CTG regulations (in the 2006 and 2010 SIP revisions); (2) sub mission of negative declarations (in the 2006 and 2010 SIP revisions) for CTG source categories; (3) the adoption of additional source

- specific controls and/or limits in major sources, included in federally enforceable permits and submitted as part of the SIP revisions; and/or (4)63

certifications for major sources subject to source

- specific RACT controls previously approved into the SIP, which controls continue to represent RACT under the 1997 8

- hour ozone NAAQS.

For these reasons, EPA is proposing approv al of the Philadelphia RACT SIP revisions, as meeting the conditions established by EPA in its December 13, 2013 conditional approval, and consequently proposing to remove the conditional nature of the previous approval for the Philadelphia 1997 8

- hour ozo ne RACT demonstration.

Attachment s
A ppendix A : Abbre v iations and Units Appendix B : List of RACT Documentation by Source Submitted by PADEP/AMS as part of the Philadelphia 1997 8

- hour ozone RACT SIP Revisions
Appendix C: EPA ’ s Clarification o n Superseded RACT Documents from the 2015 SIP RevisionAPPENDIX A

- Abbreviations and Units

Abbreviations AMS

- Philadelphia Air Management Services CAIR

- Clean Air Interstate Rule CEMS

- continuous emissions monitoring system CTG

- control technique guideline DLN

- dry low NOx EGU

- electric generating unit FCCU

- fluid catalytic cracking unit FGR

- flue gas recirculation HAP

- hazardous air pollutant HRSG

- heat recovery steam generator LNB

- low NOx burner LoTOx

- low temperature oxidation device MACT

- maximum achiev able control technology MVCCS

- marine vapor collection and control system MVCU

- marine vapor control unit NAAQS

- national ambient air quality standards NOx

- nitrogen oxides OTR

- ozone transport region PADEP

- Pennsylvania Department of Environmental Protec tion RACM

- reasonably available control measures RACT

- reasonably available control technology RICE

- reciprocating internal combustion engine SCA

- staged combustion air SCR

- selective catalytic reduction SIP

- state implementation plan SNCR

- selective non

- c atalytic reduction TSD

- technical support document ULNB

- ultra low NOx burner VOC

- volatile organic compounds Units %

- percent g/bHP

- hr

- grams per boiler horsepower per hour HP

- horsepower kW

- kilowatts lb

- pounds lb/hr

- pounds per hour (em issions rate) lb/MMBTU

- pounds per million British Thermal Units (emissions rate) MMBTU

- million British Thermal Units (energy) MMBTU/hr

- million British Thermal Units per hour (heat input rating) MMCf/yr

- million cubic feet per year (volumetric rate) MW

- megawatts (energy output rating) ppm

- parts per million (concentration) ppmv

- parts per million, volumetric (concentration) psia

- pounds per square inch (pressure) psia

- pounds per square inch, absolute (pressure) RVP

- Reid Vapor Pressure tpy

- tons per ye ar (emissions rate)