PROPOSED REVISION TO THE STATE IMPLEMENTATION PLAN 

TO MEET THE REQUREMENTS OF REASONABLY AVAILABLE CONTROL 

TECHNOLOGY SET FORTH BY THE CLEAN AIR ACT 

UNDER THE 8-HOUR OZONE NAAQS 

JUNE 26, 2014 Public Notice covering the following facilities: Exelon – Delaware 

Station (1325 N. Beach Street, Philadelphia, PA 19125), Exelon Generating 

Company – Richmond Station (3901 N. Delaware Avenue, Philadelphia, PA 19137), 

Exelon Generating Company – Schuylkill Station (2800 Christian Street, 

Philadelphia, PA 19146), Veolia Energy Philadelphia – Edison Station (908 Sansom 

Street, Philadelphia, PA 19107), Veolia Energy – Schuylkill Station (2600 Christian 

Street, Philadelphia, PA 19146) 

CITY OF PHILADELPHIA 

DEPARTMENT OF PUBLIC HEALTH 

AIR MANAGEMENT SERVICES 

COMMENT AND RESPONSE DOCUMENT 

December 12, 2014 

 
 

PREAMBLE 

On December 13, 2013 (78 FR 75902), EPA conditionally approved Philadelphia’s 1997 

8-hour ozone RACT demonstration provided in the 2006 and 2010 SIP revisions, based 

upon a commitment from AMS to submit additional SIP revisions to provide sourcespecific RACT determinations for certain major sources of VOC and NOx in 

Philadelphia and a certification that previously adopted source-specific RACT controls 

approved by EPA in the Pennsylvania’s SIP under the 1-hour ozone NAAQS for the 

remaining sources in Philadelphia County (as listed in 40 CFR 52.2020(d)(1)) continue to 

adequately represent RACT for the 1997 8-hour ozone NAAQS. 

This SIP revision is intended to partially satisfy AMS’ commitment by addressing 

source-specific RACT determinations for the following major sources of NOx: 

 Exelon – Delaware Station (1325 N. Beach Street, Philadelphia, PA 19125), with 

three 15.5 MW combustion turbines and one 17.5 MW combustion turbine. 

 Exelon Generating Company – Richmond Station (3901 N. Delaware Avenue, 

Philadelphia, PA 19137), with two 66 MW combustion turbines. 

 Exelon Generating Company – Schuylkill Station (2800 Christian Street, 

Philadelphia, PA 19146), with one 233 MMBTU/hr combustion turbine, one 284 

MMBTU/hr combustion turbine, and one 2.75 MW emergency generator. 

 Veolia Energy Philadelphia – Edison Station (908 Sansom Street, Philadelphia, 

PA 19107), with two 283 MMBTU/hr boilers and two 335 MMBTU/hr boilers. 

 Veolia Energy – Schuylkill Station (2600 Christian Street, Philadelphia, PA 

19146), with two 795 MMBTU/hr boilers, one 761 MMBTU/hr boiler, one 1119 

MMBTU/hr boiler, and one 1515 MMBTU/hr combustion turbine. 

On March 26, 2012, EPA determined that the Philadelphia area attained the 1997 8-hour 

ozone National Ambient Air Quality Standard. 

On June 26, 2014, a notice was placed in the Philadelphia Daily News announcing that 

the Philadelphia Department of Public Health, Air Management Services Division 

(AMS), proposed to revise the State Implementation Plan (SIP) to meet the requirements 

of the Reasonable Available Control Technology (RACT) set forth by the Clean Air Act 

under the 8-hour Ozone NAAQS. An equivalent notice was published in the 

Pennsylvania Bulletin on June 28, 2014. The notices informed the public that AMS was 

accepting written public comments on the proposed permit issuance and set 30 days from 

the publication date as the closing date (AMS used latest notice to set the closing date). 

The notices also informed the public that a public hearing would be held on July 31, 

2014, if requested by 4 PM on July 28, 2014. 

There were no requests for a public hearing, so it was cancelled. During the public 

comment period, AMS received comments from one (1) commentator. 
 

List of Commentators

1. William O’Sullivan 

Director, Division of Air Quality, New Jersey Department of 

Environmental Protection (NJDEP) 
 

COMMENTS AND RESPONSES 

Comment 1: AMS’ source-specific RACT limits should include lower NOx emission 

standards that apply on a daily basis, or shorter time period. Specifically, New Jersey’s 

NOx RACT limits should be considered for the No. 6 oil-fired boilers at Veolia – Edison 

Station; and the No. 2 oil-fired simple-cycle turbines at Exelon – Richmond Station, 

Exelon - Delaware Station, and Exelon – Schuylkill Station. 

NJDEP’s comments included the following comparison: 

A. No. 6 Fuel Oil-Fired Boilers 

1. NJ Limit – 0.20 lbs/MMBTU1,2 (daily limit during ozone season) 

2. Veolia – Edison, four boilers 

Philly Limit – 0.50 lbs/MMBTU each 

3. Veolia – Schuylkill Station, two boilers 

Philly Limits – 0.35 lbs/MMBTU (Boiler #23) and 0.36 lbs/MMBTU (Boiler 

#26), respectively 

B. No. 2 Fuel Oil-Fired Simple Cycle Combustion Turbines 

1. NJ Limit – 0.16 lbs/MMBTU1,3

2. Exelon – Richmond Station, two turbines 

Philly Limit – 0.7 lbs/MMBTU 

3. Exelon – Delaware Station, four turbines 

Philly Limit – None 

4. Exelon – Schuylkill Station, two turbines 

Philly Limit – None 

1

On and after May 1, 2015 

2

Conversion from 2.00 lb/MWh 

3

Conversion form 1.60 lb/MWh 

Response 1: AMS must review and determine the RACT for these facilities consistent 

with the Pennsylvania RACT regulations of 25 Pa Code §§129.91-95. Section 129.92 

establishes a “case-by-case” RACT process to determine RACT for a unit by evaluating 

whether additional control options are technically feasible and economically reasonable. 

The economic evaluation is based on the cost per ton of NOx or VOC emissions 

removed, using the annualized cost of the control option and the reduction of baseline 
 

emissions. Section 129.93 establishes “presumptive” RACT for certain categories of 

equipment as long as they meet certain requirements. 

 

Each Veolia boiler is applicable to case-by-case RACT. Evaluating potential new NOx 

control technologies for each unit under Pennsylvania, no additional NOx controls were 

determined both technically feasible and economically reasonable. Schuylkill Boiler #26 

has low NOx burners. The other boilers do not due to existing annual capacity factor 

limits of 30%. AMS has proposed adding annual NOx RACT limits for these units that 

are equivalent to a 30% annual capacity factor. 

The four turbines at Exelon – Delaware Station and two turbines at Exelon – Schuylkill 

Station all meet the presumptive RACT requirements of 25 Pa Code §129.93(c)(5). Each 

must maintain a rolling 12-month capacity factor of less than 5% and must be installed, 

maintained, and operated in accordance with manufacturer’s specifications. 

The Richmond turbines are applicable to case-by-case RACT. Evaluating potential new 

NOx control technologies for each unit under Pennsylvania, no additional NOx controls 

were determined both technically feasible and economically reasonable. Each turbine has 

an annual capacity factor limit of 15%. 

 

Upon further review of past stack test and, for Boiler #26, Continuous Emission 

Monitoring System (CEMS) data for the case-by-case RACT units, AMS has determined 

the following NOx emission limits: 

A. Veolia – Edison Station 

1. Boiler #1 – 0.39 lbs/MMBTU and 110.37 lbs/hr 

2. Boiler #2 – 0.39 lbs/MMBTU and 110.37 lbs/hr 

3. Boiler #3 – 0.38 lbs/MMBTU and 127.3 lbs/hr 

4. Boiler #4 – 0.38 lbs/MMBTU and 127.3 lbs/hr 

B. Veolia – Schuylkill Station 

1. Boiler #23 – 0.34 lbs/MMBTU and 270.30 lbs/hr 

2. Boiler #26 – 0.36 lbs/MMBTU on a 30-day rolling average (existing limit) 

and 0.41 lbs/MMBTU and 312.01 lbs/hr on an hourly basis (no previous 

hourly limit) 

C. Exelon – Richmond Station 

1. Combustion Turbine #91 – 0.68 lbs/MMBTU and 569.84 lbs/hr 

2. Combustion Turbine #91 – 0.68 lbs/MMBTU and 569.84 lbs/hr 

Additionally, beginning July 1, 2015, the combustion turbines will be required to burn 

No. 2 oil with a sulfur limit of 15 ppmw or lower. A 2005 study from the Brookhaven 
 

National Laboratory has shown that reducing the sulfur content from standard levels to 

ultra low levels reduces NOx emissions by 20-30%. 

With the exception of the Boiler #26, compliance with all existing NOx RACT emission 

limits at these facilities is determined by the average of three one hour stack test. Boiler 

#26, which has a NOx CEMS, currently has a NOx RACT emission limit on a 30-day 

rolling average. AMS agrees that for RACT, these units should have NOx RACT 

emission limits on a shorter term basis, so Boiler #26 will also be given an hourly NOx 

RACT emission limit of 0.41 lbs/MMBTU. 

The final revised RACT Plan Approvals includes the following revisions to the drafts 

proposed with the public notice: 

Veolia – Edison Station: 

 The NOx emission limit in Condition 3.A.1.(a) for Boiler #1, #2, #3, and #4 was 

changed from 0.50 lbs/MMBTU for each boiler to 0.39 lbs/MMBTU and 110.37 

lbs/hr for Boiler #1 and Boiler #2 and 0.38 lbs/MMBTU and 127.3 lbs/hr for Boiler 

#3 and Boiler #4. 

Veolia – Schuylkill Station 

 The NOx emission limit in Condition 3.A.1(a) for Boiler #23 was changed from 0.35 

lbs/MMBTU to 0.34 lbs/MMBTU and 270.30 lbs/hr. 

 The NOx emission limit in Condition 3.A.1(c) for Boiler #26 was changed to add 

0.41 lbs/MMBTU and 312.01 lbs/hr limits on an hourly basis. 

Exelon – Richmond Station 

 The NOx emission limit in Condition 3.A.1 for Combustion Turbines #91 and #92 

was changed from less than 0.7 lbs/MMBTU for each combustion turbine to 0.68 

lbs/MMBTU and 569.84 lbs/hr for each combustion turbine. 

 A new Condition 3.B has been added limiting the sulfur content of all No. 2 Oil 

burned in the combustion turbines to no more than 15 ppmw, beginning July 1, 2015. 

The modification to the RACT Plan Approvals for Veolia – Edison Station, Veolia – 

Schuylkill Station, and Exelon – Richmond Station were each issued on December 09, 

2014. 
1 

PROPOSED REVISION TO THE STATE IMPLEMENTATION PLAN 

TO MEET THE REQUREMENTS OF REASONABLY AVAILABLE CONTROL 

TECHNOLOGY SET FORTH BY THE CLEAN AIR ACT 

UNDER THE 8-HOUR OZONE NAAQS 

September 18, 2014 Public Notice 

CITY OF PHILADELPHIA 

DEPARTMENT OF PUBLIC HEALTH 

AIR MANAGEMENT SERVICES 

COMMENT AND RESPONSE DOCUMENT 

January 12, 2015 

 
2 

PREAMBLE 

On December 13, 2013 (78 FR 75902), EPA conditionally approved Philadelphia’s 1997 

8-hour ozone RACT demonstration provided in the 2006 and 2010 SIP revisions, based 

upon a commitment from AMS to submit additional SIP revisions to provide sourcespecific RACT determinations for certain major sources of VOC and NOx in 

Philadelphia and a certification that previously adopted source-specific RACT controls 

approved by EPA in the Pennsylvania’s SIP under the 1-hour ozone NAAQS for the 

remaining sources in Philadelphia County (as listed in 40 CFR 52.2020(d)(1)) continue to 

adequately represent RACT for the 1997 8-hour ozone NAAQS. 

This SIP revision is intended to partially satisfy AMS’ commitment by addressing 

source-specific RACT determinations for certain major sources of VOC and/or NOx; 

certifying that previously adopted source-specific RACT controls approved by EPA in 

the Pennsylvania’s SIP under the 1-hour ozone NAAQS continue to adequately represent 

RACT for the 1997 8-hour ozone NAAQS; and certifying that certain sources that were 

applicable to the 1-hour ozone RACT are now minor sources or have shut down and are 

no longer applicable to the 1997 8-hour ozone RACT for the following facilities. 

This SIP revision also includes revisions to the approved RACT plan approvals for the 

following facilities: Honeywell, formerly Sunoco Chemicals (4700 Bermuda Street); 

Kinder Morgan, previously GATX (3300 North Delaware Avenue); PaperWorks, 

formerly Jefferson Smurfit (5000 Flat Rock Road); Temple – Health Sciences (3401 

North Broad Street); PES Refinery, formerly Sunoco Refinery (3144 Passyunk Avenue. 

This SIP revision also includes new RACT plan approvals which were not part of the 1-

hour ozone RACT for the following facilities: Temple University – Main Campus (Broad 

Street and Montgomery Avenue); Grays Ferry Cogeneration Partnership (2600 Christian 

Street); Veolia Energy Efficiency (2600 Christian Street). 

On March 26, 2012, EPA determined that the Philadelphia area attained the 1997 8-hour 

ozone National Ambient Air Quality Standard. 

Notice that AMS proposed to revise or issue RACT plan approvals for the above 

referenced facilities was published in the Philadelphia Daily News on September 18, 19, 

and 22 of 2014. Notice that AMS proposed to revise the SIP to meet the requirements of 

the RACT set forth by the Clean Air Act under the 8-hour Ozone NAAQS was published 

in the Philadelphia Daily News on September 18, 2014 only. Notice of both proposed 

actions was also published in the Pennsylvania Bulletin on September 20, 2014. See 44 

Pa. B. 5975. Written comments on the proposed actions were due to AMS by, and a 

public hearing on the proposed actions was scheduled for, October 22, 2014. Id. The 

public hearing was cancelled because no timely requests to hold the hearing were made. 

Nonetheless, AMS received comments on the proposed actions from five (5) different 

commentators. 
3 

There were no requests for a public hearing, so it was cancelled. During the public 

comment period, AMS received comments from five (5) commentators. 

List of Commentators

1. David L. Arnold 

Acting Director, Air Protection Division, United States Environmental 

Protection Agency, Region III (EPA) 

2. William O’Sullivan 

Director, Division of Air Quality, New Jersey Department of 

Environmental Protection (NJDEP) 

3. Ali Mirzakhalili 

Director, Division of Air Quality, State of Delaware Department of 

Natural Resources & Environmental Control (DEDNREC) 

4. Kristian Witt 

Technical Director, Compliance Management International (CMI) 

On behalf of Kinder Morgan Liquid Terminals (KMLT) 

5. Brendan K. Collins 

Ballard Spahr LLP 

On behalf of Temple University (Temple) 
4 

COMMENTS AND RESPONSES 

U.S. Environmental Protection Agency’s (EPA’s) Comments to Philadelphia Air 

Management Services (AMS) Proposed “Reasonably Available Control Technology 

(RACT) State Implementation Plan (SIP) Revision under the 1997 8-Hour Ozone 

National Ambient Air Quality Standard (NAAQS),” Published on September 18, 

2014 and September 20, 2014 

General Comments Applicable to All Facilities:

1. In the proposed SIP Revision, a cost effectiveness “benchmark” of $2,500 per ton 

of nitrogen oxides (NOx) reduced was used as a maximum cost effectiveness cutoff in evaluating source-specific RACT. AMS has not provided a costeffectiveness benchmark for volatile organic compounds (VOC) RACT. In 

determining NOx and VOC RACT comparable cost-effectiveness levels, EPA 

believes that it is appropriate to focus on a range of cost effectiveness. The range 

is appropriate due to the variability of the actual cost effectiveness that is 

expected from unit to unit. In general, the actual cost and emission reductions 

achieved from the implementation of controls on an individual source, and 

consequently the cost-effectiveness levels, will vary from unit to unit, because the 

emission sources themselves vary in age, condition, and size, among other 

considerations. See EPA’s detailed rationale in its March 16, 1994 memorandum 

“Cost-Effective Nitrogen Oxides (NOx) Reasonably Available Control 

Technology (RACT).”1 Thus, EPA strongly cautions AMS not to rigidly apply a 

benchmark to exclude consideration of technically feasible controls, but should 

rather consider a broader range of cost effectiveness to see if some level of 

additional control falls within that range. 

Additionally, EPA notes that other nearby states have adopted recent NOx RACT 

limits with far higher average cost effectiveness than $2,500 per ton. For 

instance, New York State estimated that the proposed NOx limits to take effect in 

2015 would have an average cost effectiveness ranging from $2,600 to $5,463 per 

ton (Proposed revisions to Subpart 227-2 published in the NYS Register on 

December 23, 2009).2

 New York State Department of Environmental 

Conservation (NY DEC) started with a higher cost effectiveness threshold for 

NOx RACT of $3,000 per ton (in 1994 U.S. dollars) over which an “emission 

source of VOC or NOx will not be required to implement any emission reduction 

or control strategy that is more costly than the established threshold adjusted over 

time for inflation.”3

 Using the Bureau of Labor Statistics “Consumer Price 

 

1 Available at http://www.epa.gov/ttn/caaa/t1/memoranda/costcon.pdf. 

2

 A copy of New York’s proposed rule is docketed at www.regulations.gov as an attachment to document 

EPA-R02-OAR-2013-0180-0004 in docket EPA-R02-OAR-2013-0180. 

3 DAR-20: Economic and Technical Analysis for Reasonably Available Control Technology (RACT) 

Networks, Effective October 18, 2013, available on-line at http://www.dec.ny.gov/chemical/91851.html.  
5 

Index (CPI) inflation calculator,” NY DEC determined that $3,000 in 1994 

equates to $4,638 in 2012, which was then rounded up to $5,000 to ensure a level 

of conservatism.4

 AMS should justify the appropriateness of the NOx costeffectiveness level used in the source-specific RACT evaluations and indicate the 

applicable VOC cost-effectiveness level used, if any. AMS should consider in 

this justification the NOx cost-effectiveness levels established by nearby states. 

Finally, while cost effectiveness, as described above, is an important 

consideration, it must be noted that other factors should be integrated into a 

RACT analysis, such as emission reductions and environmental impact, among 

others. 

Response: AMS follows Pennsylvania Department of Environmental Protection 

(PADEP) RACT regulations and policies. PADEP did not establish a bright-line cost 

effectiveness threshold to determine RACT. PADEP used the BLS CPI index to adjust 

$1,500 in 1990 dollars to $2,750 in 2014 dollars for NOx and $3,000 in 1990 dollars to 

$5,500 in 2014 dollars for VOC to adjust past dollars per ton thresholds. PADEP used 

a NOx emission cost-effectiveness upper-bound of $2,800 per ton NOx controlled. 

It should be noted that Wisconsin’s RACT rule, using a $2,500 per ton cost benchmark, 

equivalent to approximately $2,700 in 2014 dollars, was approved as a SIP revision on 

October 19, 2010. 

 

It should also be noted that this evaluation is for 1997 8-hour RACT. AMS will conduct 

another evaluation for 2008 RACT in 2015. 

2. In proposing source-specific RACT limitations under 25 Pa Code 129.91-94, 

AMS needs to ensure that the requirements are practically enforceable, by 

including specific emission limits and independently enforceable operating 

restrictions, short-term averaging times (no more than 12-month rolling), and 

monitoring, record keeping, and any other compliance requirements sufficient to 

determine compliance. 

EPA believes short-term averaging is appropriate for RACT and any proposed 

RACT emissions limits should include this consideration. Because compliance 

with the 1997 8-hour ozone national ambient air quality standard (NAAQS or 

standard) is determined over an 8-hour period, EPA has preferred RACT emission 

standards for the ozone NAAQS to be based upon a short-term time period, such 

as daily or 24-hour rolling average basis, although typically a 30-day rolling 

 Applying the BLS “CPI inflation calculator” to adjust $3,000 in 1994 dollars to 1990 dollars will yield 

$2,645 per ton. Also, $1,500 in 1990 dollars is equivalent to $1,700 in 1994 dollars.

4

 Id. 
6 

average emission rate (as an average of all hourly data for the proceeding 30 

operating days) has been approved as an acceptable averaging period for NOx

RACT (57 FR 55620, November 25, 1992). 

Response: Short-term limits were added for units that only have RACT emissions limits 

with a greater than 30-day averaging period.

3. In accordance with the source-specific RACT requirements of 25 Pa Code 

129.92(a)(4), a RACT proposal must include actual and potential NOx and VOC 

emissions for each affected emissions source and associated supporting 

documentation. AMS should provide potential and actual emissions for each of 

the emissions sources in each facility evaluated for RACT. For each emissions 

source evaluated, AMS should include or refer to any technical and economic 

data, calculations, methodology, and assumptions relevant to the proposed RACT 

determinations, including any submittals made by the facilities in compliance 

with 25 Pa Code 129.92. 

Response: The requirement of 25 Pa Code 129.92(a)(4) applies to the RACT proposals 

required to be submitted by facilities in 1994. The potential and actual emissions have 

been provided for sources when needed for a RACT determination. 

4. In this proposed SIP revision, AMS is proposing to certify that “previously 

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

under the 1-hour ozone NAAQS continue to adequately represent RACT for the 

1997 8-hour ozone NAAQS.” As part of this certification, AMS has provided 

technical memorandums for each facility evaluating the technical and economic 

feasibility of implementing additional available controls as RACT for emissions 

sources that is subject to Pennsylvania’s source-specific RACT requirements 

under 25 Pa Code 129.91-94. 

EPA has long defined RACT as the “lowest emission limitation that a particular 

source is capable of meeting by the application of control technology that is 

reasonably available considering technological and economic feasibility” (57 FR 

55620 at 55624, November 25, 1992, both citing 44 FR 53761 at 53762, 

September 17, 1979). Thus, to support this certification, AMS should also 

demonstrate that the level of any proposed emissions rate as RACT represents the 

lowest emissions limitation that is currently feasible for that particular emissions 

source. This demonstration would also apply to any emissions limits that have 

already been approved as RACT under the 1-hour ozone standard, in order to 

properly evaluate whether these limits continue to adequately represent RACT for 

an emissions source. Accordingly, AMS would need to revise any previously 

approved RACT emission limitation that currently does not represent the lowest 

reasonably achievable rate to a more stringent level of emissions to satisfy RACT 

under the 1997 8-hour standard. Such revisions would be consistent with the antibacksliding requirements of Clean Air Act (CAA) section 110(l). 

As part of this demonstration, EPA recommends relying on actual emissions of 
7 

NOx and/or VOC for each emissions source subject to source-specific RACT. In 

general, cost considerations should not be necessary for evaluating the 

appropriateness of existing RACT emissions limits, as EPA does not anticipate 

that updating the emissions limits would have a significant economic impact to 

the facility. 

Response: AMS has re-evaluated RACT emission limits. 

5. AMS is also proposing to certify that certain facilities that were applicable to 

RACT requirements under the 1-hour ozone standard are not affected sources 

under RACT for the 1997 8-hour NAAQS, because either they are under the 

applicable “major source” thresholds (i.e., minor sources), as defined by EPA, or 

have shut down. To support this certification, AMS has provided a list of “minor” 

and shutdown facilities in Philadelphia (pages 14-15). EPA believes that AMS 

did not provide sufficient information to evaluate the proposed certification. 

EPA believes it is appropriate to provide the following information: AMS should 

provide the potential-to-emit (PTE) of each facility to confirm that certain 

facilities are not major sources. In the case that a facility has taken a facility-wide 

restriction on PTE to be under the applicable RACT major source thresholds, 

AMS should refer to the applicable permit that allows such restriction. For 

facilities that have shutdown, AMS needs to show that these shutdowns are 

Federally-enforceable for the facility to not have to comply with RACT. 

Response: AMS has added documentation as requested. Facilities with Synthetic Minor 

or Natural Minor operating permits have NOx and VOC PTE below major source 

thresholds. Shutdown facilities no longer have operating permits and must obtain a 

Federally-enforceable pre-construction permit prior to installing a new emission source, 

as per 25 Pa Code Section 127.11 and Philadelphia Air Management Code Section 3-306. 

Potential emission calculations have been added for the Northeast Water Pollution 

Control Plant and the Southwest Water Pollution Control Plant to show they are below 

major source thresholds. 

6. AMS is proposing to certify that 25 Pa Code 129.81 continues to represent RACT 

for the 1997 8-hour ozone NAAQS, which EPA approved into the Pennsylvania 

SIP on September 28, 1993 (58 FR 50517) to satisfy the RACT requirements 

under section 183(f) of the CAA. CAA section 183(f) requires EPA to 

promulgate VOC RACT standards for marine vessel loading and unloading by 

November 15, 1992. At the time of EPA’s SIP-approval of regulation 25 PA 

Code 129.81, EPA had not promulgated yet any Federal RACT standards. On 

September 19, 1995 (60 FR 48388), EPA promulgated “National Emission 

Standards for Marine Tank Vessel Loading Operations,” codified at 40 CFR Part 

63, Subpart Y. The rule established RACT and maximum available control 

technology (MACT) standards for marine vessel loading. CAA section 183(f)(4) 

provides that state regulations governing VOC emissions from marine tank 

vessels must be at least as stringent as the Federal standard. AMS needs to justify 

that the RACT provisions of 25 Pa Code 129.81 are more stringent than the 

Federal RACT standards of 40 CR 63, Subpart Y. 
8 

Response: AMS will withdraw this proposal. 

7. In general, whenever a state chooses to revise its SIP, the State must demonstrate 

that the revision would not interfere with air quality goals, in accordance with 

section 110(l) of the CAA. Accordingly, for any revisions of SIP-approved 

RACT control measures, AMS must explain how the proposed SIP revision does 

not interfere with attainment of the applicable ozone NAAQS, including both 1-

hour ozone standard and the 1997 8-hour ozone standard, and any applicable 

reasonable further progress requirements. In evaluating whether a given SIP 

revision would interfere with attainment or maintenance, as required by CAA 

section 110(l), EPA generally considers whether the SIP revision will allow for an 

increase in actual emissions into the air over what is allowed under the existing 

EPA-approved SIP. Thus, in proposing to modify the SIP-approved 

requirements, AMS must demonstrate that the proposed revision provides 

equivalent or additional emissions reductions, in accordance with CAA section 

110(l). 

Response: AMS has included this analysis for changes to RACT that could lead to 

emissions increases and has clarified or improved on the analyses when requested by 

EPA in the individual facility comments.

8. AMS has identified various “de minimis” or “insignificant” emissions sources for 

which it has determined that RACT is not an applicable requirement or for which 

RACT has not been determined. AMS must justify why RACT is not applicable 

to the sources identified as “de minimis” in this proposal. 

EPA recognizes that it is possible for certain emissions sources at a major 

facilities to be so small that it would not be reasonable to consider technological 

and economic feasibility and thus to determine RACT. In general, states and 

local regulatory agencies have included exemptions for very small emissions 

sources in establishing specific RACT requirements for source categories. These 

exemptions are generally based on the State’s determination that the required 

level of control is generally not reasonable, considering technological and 

economic feasibility, for the affected emissions sources under certain size or 

capacity or whose potential emissions are under certain level (i.e., de minimis 

level). A de minimis level should not be set arbitrarily, but should be determined 

based on technical and economic infeasibility of a determined level of control. 

Major sources of NOx and VOC in Philadelphia for which no other RACT 

requirement has been established are subject to source-specific requirements of 25 

Pa Code 129.91-94. Under this regulation, RACT is required to be determined on 

a case-by-case basis, based on the technical and economic feasibility of the 

available controls for each particular emissions source. As stated earlier, 

feasibility of controls on an individual source will vary from unit to unit, because 

the sources themselves vary in age, condition, and size, among other 

considerations. Thus, EPA believes it would not be appropriate to define a 

general de minimis level of VOC and NOx, respectively, for the vast universe of 
9 

emissions sources that are subject to RACT under 25 Pa Code 129.91-94. EPA 

recommends AMS to not apply a general de minimis level, but to rather establish 

specific de minimis levels for emissions sources that are similar, such that 

different levels would apply to different source categories. In establishing such 

categories, AMS could consider purpose, capacity, emissions levels, and/or 

operation of the emissions sources. Alternatively, EPA believes AMS should 

evaluate the feasibility of controls on a case-by-case basis, consistent with the 

RACT requirements of 25 PA Code 129.91-94. Any determination by AMS for 

defining de minimis levels of NOx and VOC, respectively, should be provided as 

a SIP revision for EPA’s evaluation. 

Response: AMS has used de minimis thresholds of 5 tons per year for NOx and 2.7 tons 

per year for VOC as general guidelines. Sources with these potential emissions are 

typically exempt from plan approvals. A gas-fired boiler rated just below 20 MMBTU/hr 

with NOx emissions of 0.1 lbs/MMBTU (roughly AP-42) would have potential NOx 

emissions of 8.7 tons per year and would only be required to be installed, maintained, and 

operated in accordance with manufacturer’s specifications under the SIP-approved CTG 

regulation 25 Pa Code 129.93(c)(1). Additional controls on sources with potential 

emissions below these levels will not result in significant emission reductions and as a 

result will not be cost-effective. 

9. AMS should consider proposing to revise the SIP to update the names and facility 

information for the sources subject to source-specific RACT requirements under 

40 CFR 52.2020(d)(1) which have changed ownership or name. 

Response: AMS will update name and ownership changes of companies that are still 

applicable to RACT. 

Comments by Facilities

Philadelphia Energy Solutions (PES) (formerly Sunoco- R&M) 

1. On page 17, AMS states that “PES, including the Tank Farm, is subject to the 1-

hour RACT determination (PA Permit Numbers 51-1501 and 51-1517) dated 

August 1, 2000, and approved into the SIP by EPA on October 31, 2001, 66 FR 

54942 under the facility’s former name Sunoco Inc. (R&M) – Philadelphia.” This 

statement is incorrect, since the 1-hour RACT determination approved by EPA 

did not address RACT for the Tank Farm. 

Response: The 1-hour RACT determination did address RACT for the Tank Farm. The 

RACT permit cited above and listed in the SIP includes 1517 under Plant ID, which is the 

Plant ID for the Tank Farm. The November 1999 RACT proposal for the facility also 

included the Tank Farm. The storage tanks are covered by CTG RACT regulations and 

were not included in the RACT plan approval. The LDAR requirement in Condition 2.K 

of the RACT plan approval applies to both the Refinery and the Tank Farm. AMS has 

modified the supporting documentation to make this clearer. 
10 

2. AMS must provide the actual and potential emissions of each emissions source 

at PES. To support PTE, AMS should specify the most stringent Federallyenforceable limitation that applies to each source, and all appropriate 

assumptions used. 

Response: Please see the response to Comment #3 under General Comments. 

However, these are included in the “PES RACT Update September 2014 Revision” that 

AMS is adding to the SIP revision documentation. 

3. The following existing NOx emissions sources at the refinery, that are subject to 

the presumptive RACT requirements of 25 PA Code Sections 129.93(b)(2)-(5), 

were not listed as part of the memorandum: Unit 860- 2H1 (49 million British 

Thermal Unit per hour (MMBTU/hr) of heat input rating), Unit 860- 2H6 (36.7 

MMBTU/hr), Unit 860- 2H8 (49.6 MMBTU/hr), Unit 864-PH2 (45 MMBTU/hr), 

Unit 1332 H-1 (45 MMBTU/hr), Unit 1332 H-3 (43 MMBTU/hr), Unit 1332 H600 (21 MMBTU/hr), Unit 1332 H-601 (48 MMBTU/hr), and Unit 1332 H-602 

(49 MMBTU/hr). 

Response: These have been added. Unit 860-2H1, Unit 860-2H6, Unit 864-PH2, and 

Unit 1332 H-600 are shutdown. 

4. AMS explains in the memorandum that PES is subject to a Federallyenforceable Consent Decree that restricts PES from burning refinery oil except 

under certain circumstances, including gas curtailments. Because “PES has 

completely stopped burning oil,” AMS is proposing to remove from the SIP the 

NOx emissions limits for emission sources burning refinery oil that were 

approved as RACT under the 1-hour ozone NAAQS. In order for EPA to 

approve the proposed removal of the oil emissions limits, AMS needs to show 

that PES (or formerly Sunoco) has taken a Federally-enforceable limit to 

completely restrict burning refinery oil throughout the facility. 

Response: The heaters and boilers are not authorized to burn oil in the current Title V 

operating permit for the facility (V06-016) or 1997 8-hour RACT Plan Approval, which 

will be incorporated into the SIP. The wording in the supporting documentation has 

been modified to clarify that specifically the heaters and boilers no longer burn oil. The 

facility has IC engines which burn diesel. 

5. AMS did not provide sufficient information to evaluate the control feasibility 

analysis provided for PES for emissions sources subject to source-specific 

RACT. AMS did not provide justification for determining technical infeasibility 

of the controls evaluated for each emissions source, and did not provide a 

discussion of the methodology used for estimating cost-effectiveness of 

technically feasible controls. Without this information, EPA is unable to 

properly evaluate the source-specific NOx and VOC RACT evaluations provided 

for the emissions sources at PES. 
11 

Response: AMS is adding the PES RACT Update September 2014 Revision to the SIP 

revision. It includes a more detailed explanation of the technical feasibility and 

economic analyses of control options for emission sources. 

6. On pages 20 and 33 of the proposed SIP, AMS explains that PES has submitted 

a RACT proposal to determine source-specific NOx and VOC RACT for the 

emissions sources at the facility. AMS should include the PES submittal as part 

of the SIP revision to further support AMS proposed RACT. 

Response: This will be included. The document was available at AMS during the 

public comment period and available for public review, upon request. The document 

was analysis supporting AMS’ proposed RACT for PES. 

7. On page 29, AMS states that the potential NOx emissions of the fluid catalytic 

cracking unit (FCCU) 868 are based on the applicable limit of 47,500 barrels per 

day on a rolling 365 day-rolling average, while in Table 1, page 18 AMS states a 

potential capacity of 50,000 barrels per day. Please clarify. 

Response: The 868 FCCU has permit limits of 47,500 barrels per day on a rolling 365-

day average and 50,000 barrels in a single day. The potential annual emissions are 

based on the 365-day limit. Table 1 lists short-term capacities, so the daily limit was 

listed. A footnote has been added to help clarify this in Table 1 for both the 868 FCCU 

and 1232 FCCU, which also has throughput limits both on a rolling 365-day average 

and an individual day. 

8. AMS needs to adequately address RACT for the marine vessel and tank truck 

loading operations at PES. AMS has identified the refinery’s “loading 

operations” at wharf and tank truck as VOC emission sources, and has stated 

that both sources are subject to the RACT requirements of AMR V Section V 

“Organic Loading Operations.” However, AMR V Section V only applies to 

VOC emissions from loading of organic materials into tank truck, tank car, or 

trailers from any loading facility, and is not applicable to marine vessel loading 

operations. Additionally, the PES Title V operating permit (No. V95-038) does 

not list AMR V Section V as an applicable requirement for the tank truck 

loading operations at the refinery. Please clarify. 

Response: The Point Breeze marine loading has a Marine Vapor Collection and Control 

System (MVCACS) which feeds collected vapors to process heaters and boilers as fuel. 

The Girard Point marine loading is controlled by a thermal oxidizer. Thermal 

oxidizers/vapor combustion is the most stringent control option for marine loading, so 

these controls will be carried into RACT along with a 98% control efficiency or 20 

ppmdv VOC outlet requirement. 

The Title V operating permit is incorrect and should list AMR V, Section V as an 

applicable requirement for tank truck loading. This regulation is CTG RACT for the 

source. 
12 

9. AMS has not provided potential VOC emissions from the refinery cooling 

towers nor sufficiently evaluated available controls for controlling VOC 

emissions from the towers. 

Response: AMS has listed the potential emissions for the individual cooling towers in 

addition to the combined cooling tower potential emissions that were previously listed. 

AMS has added an explanation that they were calculated using AP-42 emission factors 

and the circulation rate of the unit. AMS has provided the justification of no add-on 

controls for cooling towers and established the inspections, maintenance, and monitoring 

procedures as RACT requirements. 

10. On page 27, AMS proposes NOx emissions rates as RACT for various heaters 

and boilers in terms of pounds per million British Thermal Units (lb/MMBTU) 

per rolling 365-day basis. These limits are essentially annual limits that are 

measured on a daily basis for more stringency. As explained earlier, EPA 

believes short-term averaging is appropriate in setting emissions limits for 

RACT, typically a 30-day rolling average. AMS should provide justification of 

why these limits adequately represent RACT for these emissions sources. 

Response: AMS has added daily NOx emission limits for these units. 

Honeywell International – Frankford Plant (Formerly Sunoco Chemical – Frankford 

Plant)

1. In short, EPA believes AMS has not submitted an adequate analysis to support the 

proposed RACT modification for Boilers 1 and 2. Although the proposed 

restriction for combustion of No. 6 fuel oil should result in NOx emissions 

reduction, AMS must ensure that the proposed emissions limitations and fuel 

restrictions are practically enforceable. 

AMS is proposing revisions to the RACT Plan Approval to remove the ability of 

Boilers 1 and 2 to burn No. 6 fuel oil, except “if there is a natural gas curtailment 

and other losses of supply (e.g. PGW supply line failure or maintenance activity) 

or during stack testing programs (e.g. annual CEM RATA testing, annual 

combustion tuning, and combustion performance testing, as required).” 

AMS should clarify the following: How are supply losses expected to affect the 

boilers’ operation? Why should AMS allow the burning of oil during stack 

testing programs when No.6 fuel oil is almost completely excluded? How would 

this testing result in NOx emissions that are representative of the boilers’ 

operations when burning natural gas and phenol? 

For this condition to be practically enforceable, AMS must clearly identify the 

specific circumstances in which the facility would be allowed to burn No. 6 oil in 

Boilers 1 and 2. To show compliance with this requirement, EPA also believes 

the facility should be required to record and timely notify AMS when these events 

occur. 
13 

AMS is proposing to establish a fuel restriction based on annual heat input: 

“Honeywell shall operate Boiler 1 and Boiler 2 each on waste phenol residue and 

natural gas combined 51% or greater.” EPA finds that this condition is not 

practically enforceable and that is inconsistent with the proposed restriction of 

combusting No. 6 fuel oil. 

The proposed condition does not specify that the limit applies to annual heat input 

based on BTU. The proposed condition does not establish specific heat input 

limits for each of the fuels, but a combined limit for both natural gas and waste 

phenol and implies a restriction for No. 6 fuel oil. For the condition to be 

practically enforceable, fuel restrictions should apply to each of the fuels been 

combusted in Boilers 1 and 2. 

The proposed heat input restriction is provided as a relative limit, in terms of 

percentage, and not absolute limits. To ease practical enforceability of the 

proposed limits, EPA recommends to establish absolute heat input limits, in terms 

of BTU, and not relative limits, in terms of percentages or fractions. 

The proposed heat input restriction is inconsistent with the proposed condition to 

limit the instances where burning No. 6 fuel oil is allowed. Since the boilers 

would primarily burn natural gas and/or phenol, in most cases there would be no 

other fuel comprising the remaining 49% of annual heat input during that time. 

The proposed fuel restriction does not appropriately reflect the two possible 

operating scenarios: (1) Burning of phenol and/or natural gas, and (2) burning of 

phenol and/or No. 6 fuel oil, when natural gas is not available. AMS should 

establish fuel restrictions for each of the possible operating scenarios. EPA also 

believes it is appropriate to establish a NOx emissions limit or fuel restriction for 

No. 6 fuel oil, because the proposed conditions would allow combustion of No. 6 

fuel oil during specific circumstances. 

Response: AMS has revised the RACT modification and associated analysis for Boilers 

1 and 2. A loss of gas supply could significantly curtail or shut down the boilers if they 

were not allowed to burn No. 6 oil and there was not a sufficient supply of waste phenol 

residue at the time. This would cause the operation of the plant to be severely curtailed 

or ultimately shut down. 

The condition allowing No. 6 oil burning during stack tests was carried over from the 

Second Amendment to a Consent Decree between EPA, several states, the City of 

Philadelphia, and Sunoco, Inc. (Civil Action No.05-02866). This allows for better 

verification of CEMS performance during Relative Accuracy Test Audits (RATAs) and 

better combustion tuning due to a larger range of emissions. Better CEMS performance 

improves the monitoring of emissions at all times and better combustion tuning helps 

reduce emissions at all times. 

AMS has added recordkeeping requirements for times and reasons for loss of gas supply 

and times and basic descriptions of AMS-approved stack testing programs. We have 

added a reporting requirement for losses of gas supply, but don’t believe one is necessary 

for stack test programs as we review and approve stack tests and RATAs. 
14 

AMS has removed the 51% or greater natural gas and phenol waste condition (49% No. 6 

oil or lower). The new condition that only allows No. 6 oil during natural gas supply 

losses or testing programs is more stringent than this limit or—because natural gas 

burning historically emits lower emissions than phenol waste burning (over 30% lower 

during a one-month sample period)—the 1-hour RACT requirement of 51% or greater 

phenol waste. Revised calculations of potential NOx emissions show that removing this 

condition does not increase potential NOx emissions on an annual or hourly basis, due to 

the new limitation on No. 6 oil use and the existing combined annual NOx limit of 272 

tons per year for Boilers 1 and 2. 

2. As part of the SIP-approved RACT Plan Approval, Boilers 1 and 2 are also 

subject to the following restrictions: A NOx emissions limitation of 0.35 

lb/MMBTU for each of the boilers and a combined emissions limitation of 272 

tons per year. EPA finds that the 0.35 lb/MMBTU limit may no longer be 

appropriate to represent RACT and that it is inconsistent with the proposed RACT 

revisions. 

First, emissions data from Continuous Emissions Monitoring System (CEMS) 

included in the proposal indicates that each of the boilers were able to achieve 

much lower NOx emissions rates per heat input, specifically: 0.29 lb/MMBTU for 

No. 6 oil, 0.19 lb/MMBTU for waste phenol residue, and 0.12 lb/MMBTU for 

natural gas. The CEMS data provided shows that the current 0.35 lb/MMBTU 

limit is only appropriate for controlling NOx emissions from burning No. 6 oil. 

The boilers are able to achieve lower emissions rates when burning phenol or 

natural gas. Since No. 6 fuel oil has been restricted from primary use, AMS 

should establish additional limits to control emissions from the boilers when 

burning phenol and natural gas. EPA recommends AMS establish a NOx

emissions limit per fuel for each boiler, and to consider actual emissions data 

when establishing such limits. AMS must also justify that the existing RACT 

emissions limit of 272 tons per year continues to be appropriate to represent 

RACT. 

Response: The CEMS data was an example from one month and does not represent 

worst-case NOx emissions under current technology. The boilers have had results higher 

than these for all fuels. Both boilers periodically have NOx emissions near 0.35 

lbs/MMBTU hourly limit while burning No. 6 oil, which supports the limit for oil under 

current technology. A statistical analysis of CEM data shows that these boilers can 

comply with a 0.28 lbs/MMBTU NOx limit on a rolling 30-day average during normal 

operation (burning natural gas and/or phenol residue) under current technology. AMS 

has modified the limit to 0.28 lbs/MMBTU on a rolling 30-day average while burning 

natural gas, waste phenol residue, or a combination of the two and 0.35 lbs/MMBTU 

while burning No. 6 oil. 

3. On page 38, AMS states that “(a)ll testing, monitoring, and record keeping are in 

the Title V operating permit for the facility.” For the proposed RACT limitations 

to be practicably enforceable, the relevant testing, monitoring, and recordkeeping 

requirements for each of the RACT limits must be included. 
15 

Response: This statement has been removed. To clarify the recordkeeping requirements, 

more specific requirements such as fuel type and usage, records demonstrating 

compliance with the combined tons NOx per year limit for Boilers 1 and 2, and CEMS 

records have been added to the RACT plan approval and supporting documentation. 

4. For Boiler 3, AMS has evaluated the economic feasibility of flue gas recirculation 

(FGR) in combination with low NOx burner (LNB). Because Boiler 3 is already 

required to maintain and operate an LNB, AMS should only consider the cost of 

installation of FGR, as the LNB is already in place. 

Response: The LNB with FGR analysis has been removed. Additionally, Boiler 3 

already has FGR, so this has been added to the RACT plan approval and supporting 

documentation. 

5. AMS includes a cost-effectiveness analysis for LNB. Boiler 3 is already 

required as RACT to maintain and operate LNB as of 1995. Thus, this costeffectiveness evaluation is irrelevant. 

Response: The LNB analysis has been removed. 

6. AMS has also evaluated feasibility of FGR in combination with ultra-low NOx

burner (ULNB). AMS should explain the difference between LNB and ULNB 

with respect technical operation and expected control efficiency; AMS should 

further explain whether a complete removal of LNB and installation of the ULNB 

is required or merely a simple ‘upgrade’ to the current burner system. 

Response: ULNB is a description sometimes given to burners that emit very low levels 

of NOx. They typically have a longer flame than LNB, which increases the uniformity of 

temperature and reduces thermal NOx emissions. The estimated emission reductions are 

listed in the supporting documentation. 

7. The capital recovery factor (CRF) estimated for Boiler 3 is based on a 15 % of 

interest (i) and 10 years of useful life (n). Please justify why AMS assumes useful 

life (n) for each control of 10 years, when it is typically estimated to be 20 years. 

Response: The control technology installed on the boiler is not expected to last more 

than the expected life of the boiler. Since Boiler 3 is more than 50 years old, it is not 

expected to operate another 20 years. 

8. The methodology provided in pages 41 for estimating emissions of ammonia 

(NH3) necessary for the selective catalytic reduction (SCR) systems is incorrect. 

Thus, the ammonia costs estimate for SCR provided on page 42 is also incorrect. 

Emissions of NOx from combustion of fossil fuels are primarily in the form of 

nitrogen oxide (NO), rather than in the form of nitrogen dioxide (NO2). Thus, the 

amount of ammonia needed should be estimated based on the reduction of NO, 

rather than of NO2. The reduction of NO takes place when ammonia and oxygen 

(O2) react with the NO, to produce nitrogen (N2) and water vapor (H2O), by the 

following stoichiometric chemical reaction: 
16 

2 NH3 + 1⁄2 O2 + 2 NO  2N2 + 3H2O. 

For more details, see page 2-5 of EPA’s January 2002 Air Pollution Control Cost 

Manual, Sixth Edition, (EPA/452/B-02-001). 

AMS provides the following methodology to estimate the annual cost of 

ammonia: 

Ammonia	Cost

ൌ	ቆ17

46 ∗

4	moles	of	NHଷ

2	moles	of	NOଶ

∗ 1.05 ∗ NO୶	emissions ∗

$410

ton

∗ 5	years൰

Where NOx emissions are in tons per year. 

First, AMS should correct the estimated cost for ammonia, based on the 

stoichiometric ratio of the reduction of NO and molecular weight of NO, instead 

of NO2. Second, because AMS uses potential annual NOx emissions of the boiler 

in tons per year, the cost would already be estimated on an annual basis. It is 

unnecessary to multiply the cost by 5 years, as this would result in the total cost 

for the amount of ammonia for 5 years of operation, and the annual cost is 

needed. 

Additionally on page 42, AMS added a comment that indicates that the sinking 

fund factor (SFF) was used in estimated annual cost of ammonia. If using the 

revised equation as described in previous comment, the cost of ammonia will be 

estimated in an annual basis, and AMS will not need to use the SFF for 

annualization. The SFF should only be used in estimating the replacement cost of 

the catalyst, as AMS explained on page 41. 

Response: AMS had made this change. 

9. AMS provides inadequate references to support their estimation of the total 

capital investment (TCI) costs of the controls evaluated for Boiler 3. AMS refers 

to “the 2006 Best Available Control Technology submittal plus inflation 

adjustment to 2014 US dollars” and states that “(t)he TCI includes equipment cost 

estimates from vendor-supplied estimates for similar units or industry data 

gathered for similar projects. This was used because it is similar to RACT 

analysis and it is more recent.” AMS should include the referenced Best 

Available Control Technology (BACT) analysis, or at least provide a more 

substantive description of the BACT determination. Additionally, AMS should 

clearly identify, for each control evaluated, whether vendor cost estimates or 

industry data were used in estimating TCI. 

Response: The supporting documentation should have said that the TCI comes from the 

2006 Best Available Retrofit Technology (BART) submittal. This has been corrected. 
17 

As part of this submittal, the facility contacted vendors to get cost estimates for various 

control options. This has been clarified in the supporting documentation. 

PaperWorks Industry (Formerly Jefferson Smurfit Corp.)

1. In proposing revisions to the existing RACT conditions in the SIP in accordance 

with CAA 110(l), AMS does not properly describe in the technical memorandum 

the existing RACT requirements approved in the SIP under the 1-hour ozone 

standard for Paperworks Industry (Formerly Jefferson Smurfit Corp.). 

At the time of the 1-hour RACT determination, RACT was evaluated and 

determined for Boiler 1 (240 MMBTU/hr), Boiler 2 (225 MMBTU/hr), and four 

infrared heaters (2.9 MMBTU/hr each). Under 1-hour RACT determination, 

Boilers 1 and 2 are allowed to burn coal, No. 6 fuel oil, and natural gas; for 

controlling NOx emissions each boiler is required to operate a LNB when 

combusting coal and LNB with overfire when combusting No. 6 fuel oil and 

natural gas. Additionally, the combined NOx emissions from the boilers were 

limited to the following emissions rates: 0.50 lb/MMBTU on 30 day-rolling 

average when burning coal, 0.30 lb/MMBTU on 30 day-rolling average when 

burning No. 6 fuel oil, 0.20 lb/MMBTU on 30 day-rolling average when burning 

natural gas, and 1,018 tons per year total. 

Response: AMS has modified the supporting documentation to delineate the listed 

requirements more clearly. 

2. In evaluating RACT for Boiler 1, AMS does not accurately describe that the NOx

emission limits currently approved as RACT apply to the combined emissions of 

Boilers 1 and 2. Further, in proposing the existing RACT limits for Boiler 1, 

AMS should also demonstrate that the level of these RACT emissions rates 

continue to represent the lowest emissions limitations that are currently feasible 

for Boiler 1. Since Boiler 2 has been removed, AMS must justify why the 

existing RACT emissions limits are appropriate to adequately limit emissions 

from Boiler 1 alone. 

Response: AMS has modified the supporting documentation to address these comments. 

The Boiler #1 lbs/MMBTU NOx limits for No. 6 oil and natural gas are appropriate for 

the existing technology as CEMS data shows NOx emissions for this unit are periodically 

near these limits. AMS has removed the ability to burn coal and the associated NOx 

limit. The combined annual NOx limit for Boilers #1 and #2 has been replaced by a NOx 

limit of 138 tons per rolling 12-month period for Boiler #1. Boiler #1 is also being 

limited to a capacity of 156 MMBTU/hr. 

3. The proposed RACT requirements for Boiler 1, Boiler 2, and the infrared heaters 

are inconsistent throughout the technical memorandum and the revised RACT 

Plan Approval. In the memorandum, AMS indicates that the facility is no longer 

allowed to burn coal in Boiler 1 and that Boiler 2 and the four infrared heater have 

been shutdown, and yet, AMS does not propose any updates to the existing SIPapproved requirements for Boiler 1, Boiler 2, or the infrared heaters. Although 
18 

not supported in the memorandum, AMS is proposing to revise various conditions 

of the RACT Plan Approval relevant to these emissions sources: (1) To remove 

the ability of Boiler 1 to burn coal and the applicable NOx emission limits and (2) 

to remove all requirements of the retired emissions sources. AMS must update 

the technical memorandum and/or the RACT Plan Approval to be consistent with 

any proposed changes to the SIP-approved RACT requirements. 

Response: AMS has removed the ability to burn coal and the associated emission limit 

from the revised RACT plan approval and supporting documentation. The retired 

sources have been noted retired in the supporting documentation and removed from the 

revised RACT plan approval. 

4. EPA believes AMS should evaluate additional control measures for Boiler 1. In 

the technical memorandum (page 48), AMS states that “Boiler #1 is allowed to 

burn No. 6 fuel oil and natural gas, though the facility has been burning natural 

gas for the past five years.” Based on this statement, EPA believes that there are 

two additional reasonably available control measures that would achieve 

significant additional NOx emissions, which AMS should evaluate in determining 

RACT for Boiler 1: (1) Switching from burning both No. 6 fuel oil and natural 

gas to burning natural gas only, and (2) establishing restrictions to limit how 

much No. 6 fuel is allowed to burn as to primarily burn natural gas. 

Response: AMS has added a requirement to burn natural gas as primary fuel and limit 

No. 6 oil use to emergencies, gas interruptions, and if necessary to keep the pipes from 

freezing. No. 6 oil use is limited to 168 hours per year. Burning natural gas exclusively 

is not technically feasible due to the potential for emergencies, gas interruptions, and 

freezing pipes. 

5. The proposed RACT requirements for Boilers 3 and 4 are inconsistent throughout 

the technical memorandum and the revised RACT Plan Approval. On page 48 of 

the technical memorandum, AMS indicates that Boilers 3 and 4 are currently 

permitted under Plan Approval No. 08179, issued in December 30 2008, to burn 

both natural gas and No. 6 fuel oil, and states that on August 19, 2014 the facility 

requested to modify the plan approval to remove the ability of the boilers to burn 

No. 6 fuel oil. AMS does not clearly provide if this modification has been 

approved as a permit action. 

Response: AMS has clarified that the modification is in the public comment period and 

has not been issued yet. 

6. Please, clearly describe all the applicable NOx requirements of Boilers 3 and 4 

under Plan Approval No. 08179, issued in December 30, 2008, including the 

limitation to burn No. 6 fuel oil. 

Response: This change has been made. Under this plan approval, each boiler has LNB 

with FGR, can burn natural gas and No. 6 oil, has a NOx emission limit of 0.025 

lbs/MMBTU for gas, and has a NOx emission limit of 0.30 lbs/MMBTU for oil. Each 

boiler has a NOx emission limit of 10.15 tons per rolling 12-month period. Please note 
19 

that the ability to burn No. 6 oil is being removed in a proposed plan approval and is 

being incorporated into RACT.

7. The AMS proposed RACT requirements for Boilers 3 and 4 are inconsistent 

throughout the memorandum and the revised RACT Plan Approval. The 

feasibility analysis of additional controls on Boilers 3 and 4, provided in pages 48-

49 of the memorandum, is based on the boilers’ ability to only burn natural gas. 

On page 49 of the memorandum, AMS proposes as RACT the emissions limits 

and existing controls required under Plan Approval No. 08179 issued in December 

30 2008, which does not contain the August 2014 modification requested by the 

facility for restricting to burn No. 6 fuel oil. Finally, in the proposed revisions to 

the RACT Plan Approval, AMS does not include any limitations for burning No. 

6 fuel oil. AMS must update the technical memorandum and/or the RACT Plan 

approval to be consistent with any proposed changes to the SIP-approved RACT 

requirements. 

Response: AMS has modified the memo to clarify that these boilers are only allowed to 

burn natural gas in the proposed RACT. The boilers were permitted to burn No. 6 oil in 

the cited plan approval, but were never able to operate properly while burning this fuel. 

As noted in the response to Comment #6, the ability to burn No. 6 oil is being removed. 

Newman and Company, Inc.

1. On page 69, EPA recommends that AMS include the permit ID number for the 

RACT Plan Approval that has been approved in the SIP as RACT under the 1-

hour ozone standard. 

Response: AMS has made this change. 

2. The provided citation of the Federal Register notice containing EPA’s approval of 

1-hour RACT for the facility is incorrect. The citation to the Federal Register 

should be 66 FR 54691. 

Response: AMS has made this change. 

3. AMS proposed as RACT for Boiler 1 the existing RACT NOx emissions limit as 

approved by EPA under the 1-hour ozone standard: 0.43 lbs/MMBTU when 

firing No. 6 oil, 0.37 lbs/MMBTU when firing natural gas, and a total NOx

emission limit of 121 tons per rolling 12-month period. To support this proposal, 

AMS should demonstrate that each of the emission rates approved as RACT 

represent the lowest achievable rate that is feasible for Boiler 1. 

Response: NOx emission rates during stack tests on this boiler have been as high as #6 

0.39 lbs/MMBTU while firing No. 6 oil and as high as 0.329 lbs/MMBTU while firing 

natural gas. Allowing for a margin of safety, the boiler cannot achieve lower limits under 

the existing technology.
20 

Temple University- Health Sciences Campus

1. As part of this proposed submission, AMS should clearly describe the currently 

applicable RACT requirements for Temple Health, as approved in the SIP under 

the 1-hour ozone standard, as well as any other currently applicable NOx

requirements not approved by EPA for inclusion into the SIP, but approved by 

AMS. 

On December 15, 2001 (65 FR 78418), EPA approved AMS Plan Approval 

05198, effective on May 27, 1995, (hereafter the 1-hour RACT Plan Approval) as 

case-by-case RACT for Temple University – Health Campus (Temple – Health). 

On April 26, 2008, AMS issued modifications to Plan Approval 05198 with the 

purpose of replacing the RACT requirements for Boilers 1, 2, and 3 at Temple 

Health. Specifically, the modified Plan Approval 05198 required physical 

modifications to Boilers 1 and 3 to replace the fuel governing device limiting the 

heat input of each boiler to 50 MMBTU/hr, and to Boiler 2 to upgrade the burners 

to achieve reductions equivalent to those than should have been achieved with 

implementation of FGR. 

The modified Plan Approval 05198 requires the following NOx emissions limits 

for each boiler: (1) When burning No. 6 fuel oil, 0.25 ൅ ቀ଴.଴଻ଷ଴ହଽ

௑ ቁ ∗ ሺܰ െ 0.25ሻ, 

where X is the MMBTU/gal of the fuel oil and N is the percent nitrogen in the 

fuel oil; for N less than 0.25, the NOx emissions are limited to 0.25 lbs/MMBTU; 

and (2) when burning natural gas, 0.067 lbs/MMBTU. The plan approval also 

included a combined NOx emissions limit of 56.3 lbs/hr and a combined heat 

input limit of 673,894 MMBTU per rolling 12-month period. 

This modified Plan Approval was never submitted to EPA as a revision to the SIP 

to be evaluated and approved as RACT. Therefore, the NOx RACT requirements 

of the 1-hour RACT Plan Approval continue to represent RACT for Temple 

Health until a SIP revision is submitted and approved by EPA. 

Response: AMS revised the supporting documentation to more accurately describe the 

existing 1-hour RACT requirements for Temple Health, as approved in the SIP under the 

1-hour ozone standard, as well as the requirements of Plan Approval No. 05198. 

 

2. AMS is not proposing as RACT, for Boilers 1, 2, and 3, the existing requirements 

of the modified Plan Approval 05198 issued on April 26, 2008. AMS should 

further justify why the existing permit requirements are not adequate to satisfy 

RACT, if they intended to replace the SIP-approved RACT requirements for 

restricting the heat input of Boilers 1 and 3, and for operating the FGR on Boiler 

2. 

Response: To improve enforceability, AMS has determined a NOx emission limit of 0.40 

lbs/MMBTU while burning No. 6 oil instead of the formula in Plan Approval No. 05198. 

This limit was determined using the formula in Plan Approval No. 05198 and inputting 
21 

the historical highest No. 6 oil nitrogen content of 0.57% and a standard BTU value of 

150,000 BTU/gal for No. 6 oil. It has also been determined that these boilers shall burn 

natural gas as primary fuel between April 1 and October 31, except during emergencies 

and gas interruptions, as a result of the case-by-case RACT analysis. 

3. AMS is proposing significant revisions to the applicable RACT requirements of 

Boilers 1, 2, and 3 of Temple Health, as approved into the SIP. Whenever a state 

chooses to revise its SIP, the state must demonstrate that the revision would not 

interfere with air quality goals, in accordance with section 110(l) of the CAA. 

Accordingly, AMS should explain how the proposed SIP revision that is 

modifying existing SIP-approved RACT control measures does not interfere with 

attainment of the applicable ozone NAAQS, including both 1-hour ozone standard 

and the 1997 8-hour ozone standard, and any applicable reasonable further 

progress requirements. In evaluating whether a given SIP revision would 

interfere with attainment or maintenance, as required by CAA section 110(l), EPA 

generally considers whether the SIP revision will allow for an increase in actual 

emissions into the air over what is allowed under the existing EPA-approved SIP. 

Thus, in proposing to modify the SIP-approved requirements for Boilers 1, 2, and 

3 in Temple Health, AMS must demonstrate that the proposed revision provides 

equivalent or additional emissions reductions, in accordance with CAA section 

110(l). EPA finds that the emissions demonstration provided is technically 

incorrect for a number of reasons. 

EPA finds that the emissions factors used for estimating NOx emissions from 

burning No. 6 fuel oil of Boilers 1, 2, and 3 under both the existing and proposed 

RACT requirements are inadequate or need to be further justified. In estimating 

NOx emissions from the existing RACT conditions, AMS uses an AP-42 

emissions factor for No. 6 fuel oil that is a function of nitrogen content (N). AMS 

assumes a “worst-case N content” of 55%, but does not provide any information 

to support this assumption. In estimating the emissions from the proposed 

requirements, AMS uses an emissions factor for No. 6 fuel oil that is based on the 

NOx limit Plan Approval 05198 as revised on April 26, 2008. AMS is not 

proposing this emissions limit as RACT; therefore, the emissions estimated are 

irrelevant to the 110(l) emissions demonstration. 

The emissions demonstration provided by AMS does not completely address the 

proposed RACT requirements included in the SIP revision. On page 85 of the 

proposed SIP, AMS proposes as RACT the following requirement: “During the 

ozone season; (between April 1 – October 31), each boiler shall burn natural gas 

as the primary fuel. Each boiler may only burn No. 6 fuel oil during periods of 

gas curtailment or gas supply interruption.” AMS has not provided any 

justification that this requirement should adequately represent RACT. 

Additionally, the estimated emissions from the proposed RACT rely on the 

assumption that the maximum allowed emissions result from burning No. 6 fuel 

oil throughout the year (8760 hours per year), yet the proposed requirement would 

restrict burning No. 6 fuel oil during ozone season. Thus, the emissions 

calculations provided are incorrect. If proposing this restriction for burning No. 6 
22 

fuel oil as RACT, AMS would need to consider the emissions from burning 

primarily natural gas during ozone season and No. 6 fuel oil during the remaining 

of the year in the 110(l) emissions demonstration. 

Response: AMS modified the calculations in the supporting documentation to better 

demonstrate that the potential NOx emissions under the proposed RACT do not exceed 

those in the existing 1-hour RACT. AMS has provided justification for requiring natural 

gas as primary fuel during the ozone season as RACT, including showing that these 

boilers have burned natural gas almost exclusively in recent years. 

4. EPA believes that the justification provided on page 83 for determining that the 

installation of ULNB on Boilers 1, 2, and 3 is technically infeasible is insufficient. 

Response: AMS has expanded on this justification. This includes issues with ULNB on 

multi-burner boilers of this size and structural issues that prevent the desired flame length 

for ULNBs. 

5. Per 25 Pa Code 129.91, a RACT proposal should be provided for each emissions 

source at a major facility subject to this regulation. AMS has identified each of 

the boilers as an emissions source, thus RACT should be evaluated for each 

boiler. AMS estimated cost-effectiveness for controlling the combined NOx

emissions from Boilers 1, 2, and 3, thus, EPA finds this analysis to be inconsistent 

with Pennsylvania’s source-specific RACT requirements. 

Consistently, in evaluating cost-effectiveness of controls for each boiler, AMS 

should consider the most stringent Federally Enforceable allowable emissions rate 

that applies to each of the boilers. Thus, AMS needs to identify what is the most 

stringent NOx emissions level that is currently allowed from the boilers. AMS 

does not provide sufficient information to evaluate how the baseline emissions for 

each boiler was calculated. 

Response: AMS has modified the supporting documentation to better describe how the 

baseline emissions were determined. 

6. AMS has evaluated switching completely from No. 6 fuel oil to No. 2 oil for 

Boilers 1-3 as a control measure. EPA agrees that fuel switching may result in 

significant NOx emissions reductions. In evaluating fuel switching as RACT for 

Boilers 1, 2, and 3, AMS should consider the cost of retrofitting or replacing the 

existing burners and any incremental costs for operating the boilers with No. 2 

fuel oil, rather than with No. 6 fuel oil. Fuel switching should not require 

significant incremental costs in operation of the boiler, other than any increases in 

fuel cost. AMS has estimated incremental costs of fuel, but needs to justify the 

fuel prices assumed in the analysis provided. EPA recommends AMS to consider 

costs from modifying the existing burners to accommodate the combustion of No. 

2 fuel oil. 

Response: The cost of retrofitting or replacing the burners is high and would increase the 

cost per ton controlled, which is currently $34,801 per ton and economically 

unreasonable. 
23 

7. AMS evaluated switching completely from No. 6 fuel oil to natural gas for 

Boilers 1, 2, and 3 as a control measure. EPA understands that Temple must have 

a back-up fuel to be able to provide uninterrupted services to a healthcare facility. 

However, EPA finds that it is reasonable for Temple to take fuel restrictions to 

limit the amount of No. 6 fuel oil allowed to be burned on Boilers 1, 2, and 3, as 

this would result in significant NOx emissions reductions. This control option 

would allow Temple to continue to have a back-up fuel at all times, especially 

when natural gas supply is interrupted. AMS has proposed to restrict burning No. 

6 fuel oil during ozone season, except in the events of natural gas curtailment. 

However, AMS does not provide any justification to support this control option as 

RACT. In addition, AMS has not properly evaluated any other possible 

restrictions in burning No. 6 oil in determining RACT. 

Response: AMS has provided justification for requiring natural gas as primary fuel 

during the ozone season as RACT, including showing that these boilers have burned 

natural gas almost exclusively in recent years. This restriction has been limited to the 

ozone season due to periodic spikes in the price of natural gas during cold weather and 

the negligible risk of exceeding the National Ambient Air Quality Standard (NAAQS) for 

ozone during this period. 

Sunoco Partner Marketing & Terminals L.P. – Belmont Terminal

1. In the memorandum (page 91), AMS refers to MIPC, LLC facility when intending 

to list the emission sources for this facility. Please clarify whether this is an 

editorial error and, if so, make the necessary corrections. 

Response: This was an error. AMS has corrected it. 

2. In general, when evaluating RACT for emissions sources, AMS should only rely 

on regulations that have been submitted as RACT for the 1997 8-hour ozone 

standard, or existing regulations approved under the 1-hour ozone standard, which 

AMS has certified as RACT for the 1997 8-hour ozone standard. AMS should 

specify under what regulation the leak detection and repair (LDAR) program for 

the VOC fugitive emissions in the facility is required, and explain that this 

regulation has been approved or submitted as RACT for the 1997 8-hour ozone 

standard. 

Response: The specific LDAR program was listed incorrectly and is not an applicable 

RACT requirement. The memo has been corrected to state the facility must comply with 

AMR V, Section XIII for process equipment component fugitives. 

Aker Philadelphia Shipyard, Inc. – Phila. Naval Business Center

1. AMS lists 22 baghouses and 10 dust collectors as the facility’s control devices 

related to VOC emissions. Baghouses and dust collectors are not VOC control 

devices. 

Response: AMS has made this change. 
24 

Allied Tube & Conduit

1. AMS should identify which portion of 25 Pa Code 129.93(c) is applicable to the 

five space heaters listed in the table on page 98 of the proposed SIP revision. 

Response: They are applicable to 25 Pa Code 129.93(c)(1). 

Cardone Industries

1. Under the 1-hour ozone standard, AMS submitted separate RACT determinations 

for two facilities in Philadelphia identified as Cardone Industries, one facility on 

Rising Sun Avenue (PLID – 3887) and the second facility on Chew Street (PLID 

2237). Please clarify whether the technical memorandum submitted is intended to 

address RACT for either one of these facilities, or both. This should be clearly 

explained in the memorandum. If the memorandum intends to address RACT for 

only one of the facilities, then AMS would still need to provide a RACT 

evaluation for the remaining facility. 

Response: The RACT determination includes Cardone plants located at 5660 Rising Sun 

Avenue, 321 Chew Street, 500 East Erie Avenue, 5500 Tabor Road, and 5501 Whitaker 

Avenue. Beginning with the issuance of Title V/State Operating Permit No. V04-005 on 

April 11, 2005, these plants were treated as one facility due to their close proximity and 

interrelatedness. The other three plants were previously minor sources of VOC and NOx 

and not applicable to RACT. 

The Chew Street facility had certain operational requirements for its degreasers under 1-

hour RACT. This requirement is being replaced by the more stringent 25 Pa Code 

Section 129.63(a), which has similar requirements, plus many additional ones, such as a 

minimum freeboard ratio and limits on the type of solvent used. Cardone sources are 

now all covered by CTG or presumptive RACT regulations. 

2. The memorandum and the proposed revisions to the RACT Plan Approval are 

inconsistent. AMS is proposing revisions to the SIP-approved RACT Plan 

Approval for the Rising Sun Avenue facility, but the revisions are not mentioned 

or proposed in the memorandum. 

Response: AMS added the proposed changes to the supporting documentation. 

MIPC, LLC- Philadelphia Terminal 

1. AMS did not address RACT for three additive storage tanks that were identified 

as VOC emission sources in the memorandum. 

Response: This has been corrected. They are applicable to the presumptive RACT 

requirement of 25 PA Code Section 129.57. 
25 

University of Pennsylvania

1. On page 106 of the proposed SIP revision, AMS lists the heaters and furnaces and 

the presumptive RACT requirement that applies to each unit. AMS should clarify 

which portion of 25 Pa Code 129.93(c) is applicable to each unit. 

Response: The heaters and furnaces are applicable to 25 Pa Code 129.93(c)(1). 

Philadelphia Prison System

1. AMS should clarify that the capacities of emergency generators, subject to 

presumptive RACT requirements of 25 PA Code 129.92(c)(2), that are listed on 

page 111 of the proposed SIP revision are in units of horsepower (HP) and not of 

MMBTU/hr. 

Response: AMS has made this change. 

Kinder Morgan Liquids Terminal (Formerly GATX Terminals Corporation)

1. On page 113, the capacities of Boilers 1 and 2 are given as 12.5 HP and 13.4 HP, 

respectively, and as 12.5 MMBTU/hr and 13.4 MMBTU/hr. Please, clarify and 

correct the working units for the capacity of each boiler. 

Response: AMS has made this change. 

2. On page 114, AMS should correct the typographical error on the effective date of 

the 1-hour RACT Plan Approval for GATX Terminals. 

Response: AMS has made this change. 

3. On pages 115-116, AMS lists the RACT applicable requirements for storage 

tanks. AMR V Section II is listed, but not described. Please, further describe 

applicability of this requirement. 

Response: AMS has made this change. 

4. Under the 1-hour RACT, AMS identified as a VOC source the fugitive emissions 

from flanges, valves, and pumps leaks, for which case-by-case RACT 

requirements were established. The RACT Plan Approval included the following 

conditions: Condition 2E: “The implementation of a quarterly leak detection and 

repair program on all pumps, valves and flanges containing VOC;” and Condition 

5A: “GATX [Kinder Morgan] shall monitor all valves, pumps, and flanges 

quarterly for visual leaks. GATX shall also monitor valves, pumps, and flanges 

which process organic liquid greater than or equal to 4 RVP for leaks of greater 

than 10,000 ppmv.” 

AMS also identifies AMR V Section XIII as an applicable RACT requirement for 

VOC fugitive emissions. AMR V Section XIII applies to fugitive emissions from 

“leaking flanges, gaskets, seals, connections, joints, fittings or other process 

equipment components not involving moving parts,” as well as VOC emissions 

from “leaking valves, pumps, compressors, safety pressure relief devices or other 
26 

process equipment components involving moving parts.” The regulation prohibits 

VOC emissions from any of these leaking process equipment component greater 

than 10,000 part per million by volume (ppmv) in concentration. AMS has 

contradictory concluding statements on pages 117 and 118 of the memorandum 

about the stringency of these two requirements for fugitive emissions. Please 

clarify. 

Although both requirements are similar, EPA finds that AMR V Section XIII also 

applies to additional VOC fugitive emission sources that are not controlled by the 

case-by-case requirement. Please, explain whether AMS has considered fugitive 

VOC emissions from “leaking flanges, gaskets, seals, connections, joints, fittings 

or other process equipment components not involving moving parts” in Kinder 

Morgan and how RACT should be addressed for these fugitive emissions, as not 

provided by the RACT Plan Approval. 

AMS interprets Condition 5A of the SIP-approved RACT Plan Approval to be 

broadly applicable to fugitive emissions from leaks of both VOC and non-VOC 

products. Consequently, AMS is requesting to modify this condition to require 

only monitoring of VOC emissions. Condition 5A is proposed to be revised to: 

“The Permittee shall monitor all valves, pumps, and flanges in VOC service 

quarterly for visual leaks for greater than 10,000 ppmv.” 

The proposed revision removes the previous specification for the requirement to 

apply to processing of organic liquids with Reid Vapor Pressure (RVP) of 4.0 

pounds per square inch (psi) or greater. Please explain how removing this 

requirement relates to AMS intended clarification of the condition only applying 

to the control of VOC emissions. AMS must also demonstrate that the proposed 

SIP revision will not allow for an increase in actual emissions into the air over 

what is allowed under the existing EPA-approved SIP, consistent with the section 

110(l) of the CAA. 

Response: The facility is applicable to the CTG RACT requirements of AMR V, Section 

XIII for equipment component fugitives and an additional quarterly LDAR program from 

1-hour RACT. Since the quarterly LDAR program is not a specific requirement for this 

facility in AMR V, Section XIII, it must remain as a RACT requirement for the facility. 

Both are applicable to the facility. AMS has clarified this in the supporting 

documentation. 

AMS has modified the condition to clarify that the facility must check for visual leaks 

and for leaks of 10,000 ppm, with EPA Method 21 specified for the latter. 

5. AMS should verify the provided citations to Pennsylvania regulations on page 120 

that would apply to tank truck/tank car loading operations at the facility. 

Response: The paragraph referencing the NAO Thermal Oxidation Unit and 25 Pa Code 

Section 129.93 has been deleted as it is covered in the presumptive RACT section of the 

supporting documentation and does not directly apply to loading operations. The 

reference to 25 Pa Code Section 129.56(a) has been removed. 
27 

6. The tank truck/tank car loading operations in Kinder Morgan are subject to the 

VOC source-specific requirements of the RACT Plan Approval, which were 

approved in the SIP as RACT under the 1-hour ozone standard. AMS is 

proposing various revisions to the applicable SIP requirements to allow more 

flexibility to the facility in operating the loading racks. AMS must demonstrate 

that the proposed SIP revisions will not allow for an increase in actual emissions 

into the air over what is allowed under the existing EPA-approved SIP, consistent 

with the section 110(l) of the CAA. 

EPA believes that the emissions demonstration provided to satisfy section 110(l) 

CAA is inconclusive. First, AMS’s demonstration does not address emission 

changes from the proposed SIP revisions listed in the memorandum on page 120 

and the proposed limitation to each loading position of the loading racks. 

Second, AMS does not provide sufficient information to assess the emissions 

estimation provided. EPA recommends including at least the following 

information: Loading capacity of each loading rack, VOC emissions factors used, 

the capacity and level of control of the thermal oxidizer, assumptions on hours of 

operations, and any other relevant assumptions. Additionally, emissions are 

provided for the “controlled” and the “uncontrolled” racks, where they should 

have been provided for each identified emission source, in this case, for each 

loading rack. 

Response: AMS has revised the documentation to clarify the calculations and the 110(l) 

demonstration. Under both 1-hour RACT and 8-hour RACT, loading of liquids with a 

RVP of 4 psi or greater requires control that complies with 25 Pa Code Section 129.59 

and emissions from uncontrolled loading is limited to 129 tons of VOC per year. 

7. As part of the emissions demonstration, AMS interprets the existing RACT 

requirements to allow uncontrolled loading of liquids with RVP under 4 psi on 

loading racks connected to the thermal oxidizer. In support of this interpretation, 

please explain why the requirements of 25 Pa Code 129.59 would allow 

uncontrolled VOC emissions from loading racks A, B, E, F, M, and V, per 

condition 2C of the RACT Plan Approval, while condition 1A(1) and 2B would 

require the operation of the NAO Thermal Oxidizer. 

Response: Condition 1(A)(1) states that these racks are connected to the thermal 

oxidizer, but does not state that all loading at these racks must be controlled. The 

requirements of 25 Pa Code 129.59 require gasoline loading to have a vapor recovery and 

disposal system limiting emissions to 0.0668 pounds of gasoline for every 100 gallons 

loaded. Gasoline is defined in 25 Pa Code 121.1 as a petroleum distillate having a Reid 

vapor pressure (RVP) of 4 psi or greater and which is a liquid at standard pressure and 

temperature, so of 25 Pa Code 129.59 does not require controls when the RVP is less than 

4. Emissions from uncontrolled loading at the facility are limited to 129 ton spf VOC 

per year.
28 

8. In pages 120-121, AMS states that “(r)acks A, B, E, F, M, and V have control 

capabilities; however, not all loading positions are connected to the NAO 

Thermal Oxidizer since these positions do not load materials that are required to 

have control (e.g. benzene NESHAP) or load materials with a vapor pressure great 

than 4 psia RVP.” This statement is inconsistent with the SIP approved RACT 

requirements. Condition 1A(1) of the RACT Plan Approval specifically requires 

loading racks A, B, E, F, M, and V to be connected to the NAO Thermal 

Oxidizer. If some of the loading positions at these racks are not physically 

connected to the control unit, how is the facility able to comply with the 

applicable RACT requirement? 

Also, AMS should specify what materials, other than those with RVP of less than 

4.0 psi, would not require to have controls. 

Response: As stated above, Condition 1(A)(1) only states that these racks are connected 

to the thermal oxidizer, not that all loading is controlled. Condition 2.C requires loading 

at these racks to comply with 25 Pa Code 129.59, which only requires control for 

petroleum distillate with an RVP of 4 psi or greater. Not all loading positions at a 

loading rack are connected to the thermal oxidizer, only those positions connected to 

storage tanks that store materials that require control. 

All VOC materials with an RVP of 4.0 psi or greater require controls. Non-VOC 

materials would not be required to have controls under RACT, although they may require 

controls under other regulations or to prevent odor nuisances. 

9. EPA recommends AMS to further revise the proposed condition 2C for additional 

clarification of the following requirements: (1) The continuous operation of the 

NAO Thermal Oxidizer when loading products with RVP greater than or equal to 

4.0 psi; (2) the applicable emissions limit when operating the NAO Thermal 

Oxidizer; and (3) the flexibility of not operating the thermal oxidizer only when 

loading organics with RVP less than 4.0 psi. EPA recommends the condition 

should read as follows: “Organic liquids with a Reid Vapor Pressure (RVP) 

greater than or equal to 4.0 psi shall only be loaded at racks A, E, F, M, or D and 

shall comply with the requirements of 25 Pa Code 129.59(a) by continuously 

operating NAO Thermal Oxidation Unit. The NAO Thermal Oxidation Unit shall 

be operated such that 0.0668 pounds (30.3 grams) of organic liquids (measured as 

propane) are emitted to the atmosphere for every 100 gallons (380 liters) of 

gasoline loaded. Uncontrolled loading at racks A, E, F, M, and D shall be 

allowed when loading organic liquids with a RVP less than 4.0 psi.” 

EPA does not agree with the proposed modification to Condition 2D. AMS must 

continue to identify those racks that are not connected to a control unit, and must 

continue to restrict the loading of liquids with RVP less than 4 RVP to those 

racks, in order for these racks to not be subject to 25 Pa Code 129.59. EPA 

recommends AMS to modify the existing condition as follows: “Tank car/truck 

loading racks – B, C, G, H, N, O, P, R, R-1, T, V & X which are uncontrolled 

shall be limited to processing organic liquid with vapor pressure lower than 4 
29 

RVP.” 

EPA recommends to further revise the proposed Condition 3A(1), for additional 

clarification, as follows: “Loading of organic liquids with RVP > 4 psi at all tank 

car/truck loading positions at the facility shall be limited to 129 tons of VOC per 

year.” 

Response: Some organic liquids that have an RVP > 4 psi, such as acetone, are not 

VOCs and while they must be controlled under AMR V, Section V, they cannot be 

addressed in VOC RACT. AMS modified the condition to spell out the requirements of 

25 Pa Code 129.59(a), as suggested. 

10. The RACT evaluation for the loading racks is technically incorrect for various 

reasons. 

First, AMS provides two analyses for uncontrolled loading of racks, but it is not 

clear for what specific loading racks the analyses is provided. AMS is proposing 

to allow loading racks that are connected to the thermal oxidizer, A, E, F, M, or 

D, to remain uncontrolled whenever loading is limited to organic liquids with less 

than 4.0 psi of RVP. AMS is also proposing to maintain the loading of organic 

liquids with less than 4.0 psi of RVP on racks that are not physically connected to 

the thermal oxidizer. AMS has evaluated on pages 122-123 the feasibility of 

“adding a control device while loading VOC materials with an RVP < 4.0 psi.” 

According to AMS’s estimated potential emissions, uncontrolled emissions of 

loading racks A, E, F, M, or D from liquids with RVP of 4.0 psi or less would 

produce significant potential emissions of VOC. Thus, EPA believes AMS must 

determine RACT for the uncontrolled operation of these racks. Additionally, 

AMS must evaluate the appropriateness of the existing RACT requirements for 

loading racks A, E, F, M, or D in determining RACT. In evaluating RACT, AMS 

should evaluate the feasibility of the existing controls (the NAO thermal oxidizer 

and/or the applicable emissions limits) and additional reasonably available 

controls. 

Second, AMS has evaluated RACT per loading position. In accordance with 25 

Pa Code 129.92, AMS must evaluate and determine RACT for each emissions 

source in a major facility. Per the existing and proposed RACT conditions, AMS 

has consistently defined the emissions source as the loading racks, not the loading 

positions within racks. In evaluating RACT, if AMS finds that no available 

controls are technically and economically feasible for each rack, EPA finds it 

would be acceptable to evaluate controls for emissions of combined emissions 

sources. The control of VOC emissions from racks A, B, E, F, M, and V with a 

single thermal oxidizer suggests that this is a reasonable control option for 

multiple loading racks. 

Baseline emissions used in the cost-effectiveness analyses should be based on the 

existing Federally-enforceable emissions restrictions that apply to the particular 

emissions source. Consequently, AMS cannot rely on a limit that is being 
30 

proposed as RACT. Since there is no applicable Federally-enforceable limitation 

for each of the loading racks, the baseline emissions should be based on the 

unrestricted maximum capacity of each rack. 

AMS provides different and inconsistent control efficiencies for the thermal and 

catalytic oxidizer throughout the analysis provided. 

Response: AMS has modified the documentation to clarify the analyses. Each 

uncontrolled loading position has the same capacity and worst-case product, making their 

potential emissions and case-by-case RACT analyses the same. AMS has corrected some 

of the potential emission calculations. These corrections include accounting for physical 

limitations to the loading process which were previously not addressed and which 

drastically reduce potential emissions. 

Any loading position that is controlled is connected to the thermal oxidizer individually. 

It is appropriate to analyze these controls on a loading position basis instead of a loading 

rack basis. 

As mentioned above, some of the potential emission calculations were corrected. The 

control requirements of 25 PA Code Section 129.59(a) (0.0668 pounds per 100 gallons 

loaded) was used for PTE calculations for the loading of materials with a RVP of 4.0 psi 

or greater, since it is an applicable requirement. An emission factor from AP-42, Section 

5.2 was used for the loading of materials with a RVP < 4.0 psi because this loading is not 

applicable to that regulation. 

AMS has added the following VOC emission limits to help ensure there is not an increase 

in potential VOC emissions: total controlled tank car/truck loading VOC emissions at the 

facility must be less than 57.0 lbs/hr (based on 25 PA Code 129.59(a) and the thermal 

oxidizer capacity) and each uncontrolled loading position must emit less than 9.0 tons per 

year VOC and 18.1 pounds per hour VOC. 

11. AMS is proposing a 70 ton per year emissions limit for each of the loading 

positions of the loading racks. To ease practicable enforceability, EPA 

recommends any emissions limit to be applied on a short-term averaging basis. 

Also, AMS should establish limits on the emission sources themselves, which has 

been consistently identified as the loading racks not the loading positions. AMS 

must provide further justification for determining that this proposed limit 

adequately represents RACT. 

Response: After correcting the PTE calculations as noted above, this limit was replaced 

with 9.0 tons per year and 18.1 pounds per hour VOC limits for each uncontrolled 

loading position. 

Plains Product Terminal LLC

1. In general, when evaluating RACT for emissions sources, AMS should only rely 

on regulations that have been submitted as RACT for the 1997 8-hour ozone 
31 

standard, or existing regulations approved under the 1-hour ozone standard, which 

AMS has certified as RACT for the 1997 8-hour ozone standard. On page 137, 

AMS should specify under what regulation the LDAR program is required for 

controlling fugitive emissions from pumps, valves, and flanges in the facility, and 

explain that this regulation has been approved or submitted as RACT for the 1997 

8-hour ozone standard. 

Response: The LDAR program was a requirement established in the 1-hour RACT plan 

approval for the facility. It does not come from a specific regulation. AMS has modified 

the supporting documentation to make this clear. AMS is also noting that the facility 

must comply with AMR V, Section XIII for process equipment component fugitives. 

Navy Foundry and Propeller Center 

1. AMS indicates in the memorandum (page 138) that “(t)he 1-hour ozone RACT in 

the RACT Plan Approval dates April 20, 1999 was issued to Philadelphia Naval 

Shipyard.” EPA does not have any record of the Philadelphia Navy Shipyard 

having a 1-hour RACT determination approved in the SIP for this facility. Please, 

clarify. 

Response: AMS did issue a RACT plan approval to the facility. It appears this was not 

included in the SIP because the only case-by-case sources at the facility were five boilers 

on a schedule to be shut down in the RACT plan approval. The Naval Surface Warfare 

Center RACT Permit PA-04108 issued 10/18/04 and made part of the SIP on 4/29/05 

amends conditions in the Philadelphia Naval Shipyard RACT plan approval related to the 

shutdown of these boilers. This has been clarified in the supporting documentation. 

Grays Ferry Cogeneration Partnership

1. The proposed NOx RACT limits for the combustion turbine excludes startup and 

shutdown emissions. These limits are inappropriate for approval into the SIP. 

The CAA does not allow for exemptions from otherwise applicable SIP emission 

limitations, whether automatic or through the exercise of a state official's 

discretion. In accordance with the requirements of CAA section 110(a)(2)(A), 

SIPs must contain emission limitations and, in accordance with the definition of 

“emission limitations” in CAA section 302(k), such emission limitations must be 

continuous. Thus, any excess emissions above the level of the applicable emission 

limitation must be considered violations, whether or not the state elects to 

exercise its enforcement discretion. SIP provisions that create exemptions such 

that the excess emissions during startup, shutdown, malfunction, or emergencies 

are not violations of the applicable emission limitations are inconsistent with the 

fundamental requirements of the CAA with respect to emission limitations in SIPs 

and interfere with citizen suit enforcement of CAA violations. EPA believes that 

the inclusion of such an exemption is a substantial inadequacy and renders any 

proposed provision for a SIP impermissible. 
32 

Response: These were construction permit limits determined to be Best Available 

Technology (BAT) that the unit cannot meet during startup and shutdown, only regular 

operation. AMS has replaced them with existing permit limits of NOx limits of 255 

lbs/hr for the Turbine and 298.9 lbs/hr for the Turbine and Heat Recovery Steam 

Generator (HRSG) to RACT, which apply at all times. 

 

2. The methodology provided in page 148 for estimating emissions of ammonia 

necessary for the SCR and the selective non-catalytic reduction (SNCR) systems 

is incorrect. Thus, the ammonia costs estimates for SCR and SNCR provided on 

pages 144 and 147 are also incorrect. Please refer to EPA’s comment 8 for 

Honeywell International – Frankford Plant. 

Response: AMS has made this correction. 

Temple University- Main Campus

1. Temple has 3 boilers firing natural gas and No. 2 fuel oil, with 91.3 MMBTU/hr 

and 86.8 MMBTU/hr of heat input capacity for each fuel, respectively. The 

boilers are currently required to operate LNB and FGR. Each boiler is subject to 

the NOx emissions limit of 0.036 lbs/MMBTU while burning natural gas and 

0.110 lbs/MMBTU while burning No. 2 fuel oil for each boiler, in addition to the 

combined emissions limit of 15.5 tons per rolling 12-month period. 

Based on heat input capacity, continuous operation of the boilers, and the NOx

permitted rates for each fuel, each boiler can potentially emit 41.8 tons per year 

when burning No. 2 fuel oil alone, or 14.4 tons per year when burning natural gas 

alone. The combined emissions limit for the three boilers is significantly more 

stringent, considering the potential emissions achieved for each boiler alone when 

burning either of the fuels allowed. How is the facility able to comply with such 

stringent combined emissions limit? Is the facility operating these boilers 

continuously during the year? 

Response: These boilers do not operate near their annual capacity. They mostly provide 

steam for heating buildings that is required during cold months. They provide very little 

“process” steam that is needed throughout the year. Temple is also required to maintain a 

certain amount of back-up capacity. 

2. The methodology provided in page 156 for estimating emissions of ammonia 

necessary for the SCR and the SNCR systems is incorrect. Thus, the ammonia 

costs estimates for SCR and SNCR provided on pages 158 and 159 are also 

incorrect. Please refer to EPA’s comment # 8 for Honeywell International – 

Frankford Plant. 

Response: AMS has made this correction. 

Veolia Energy Efficiency
33 

1. The methodology provided in page 167 for estimating emissions of ammonia 

necessary for the SCR system is incorrect. Thus, the ammonia costs estimate for 

SCR provided on pages 163 is also incorrect. Please refer to EPA’s comment # 8 

for Honeywell International- Frankford Plant. 

Response: AMS has made this correction. 

2. Each boiler at Veolia Energy Efficiency has the following NOx emission limits in 

a plan approval, each on a rolling 30-day average: 0.01 lbs/MMBTU while 

burning gas as during normal operation; 0.08 lbs/MMBTU while burning oil 

during normal operation; 0.036 lbs/MMBTU while burning gas during startup, 

shutdown, or malfunction; and 0.08 lbs/MMBTU while burning oil during startup, 

shutdown, or malfunction. The boilers have a combined NOx emission limit of 

52.31 tons per rolling 12-month period. AMS’ Memo indicates these NOx rates 

are proposed as RACT for the facility. 

The CAA does not allow for exemptions from otherwise applicable SIP emission 

limitations, whether automatic or through the exercise of a state official’s 

discretion. In accordance with the requirements of CAA section 110(a)(2)(A), 

SIPs must contain emission limitations and, in accordance with the definition of 

“emission limitations” in CAA section 302(k), such emission limitations must be 

continuous. Thus, any excess emissions above the level of the applicable 

emission limitation must be considered violations, whether or not the state elects 

to exercise its enforcement discretion. SIP provisions that create exemptions such 

that the excess emissions during startup, shutdown, malfunction, or emergencies 

are not violations of the applicable emission limitations are inconsistent with the 

fundamental requirements of the CAA with respect to emission limitations in SIPs 

and interfere with citizen suit enforcement of CAA violations. EPA believes that 

the inclusion of such an exemption is a substantial inadequacy and renders any 

proposed provision for a SIP impermissible. AMS is proposing to exempt 

automatically emissions between 0.01 – 0.036 lb/MMBTU when the boilers 

combust gas during startup, shutdown or malfunction. AMS is proposing a 

“separate” rate for startup/shutdown/malfunction when the boilers combust oil; 

however, presently, it appears the rate is identical to the rate for normal state for 

combustion of oil. If AMS adjusts that rate for oil to a higher limit during startup, 

shutdown or malfunction (SSM) (if it believes it made a mistake), then such 

alternative rate would also exempt automatically emissions between 0.08 

lb/MMBtu and any higher rate selected. If AMS corrects the rate for periods of 

SSM for the boilers while combusting oil by creating a higher rate than during 

normal operations, such a change would be impermissible if submitted for SIP 

approval. 

EPA notes that while the CAA does not allow for exemptions for excess 

emissions, it does allow states to develop alternative emission limitations or other 

forms of enforceable control measures or techniques that apply during startup or 

shutdown. EPA emphasizes this alternative rate may not apply to malfunctions. 
34 

See Memorandum from Steven A. Herman, Assistant Administrator for 

Enforcement and Compliance Assurance, and Robert Perciasepe, Assistant 

Administrator for Air and Radiation, U.S. EPA on State Implementation Plans 

(SIPs): Policy Regarding Excess Emissions During Malfunctions, Startup, and 

Shutdown to Regional Administrators, Regions I-X (Sept. 20, 1999) (1999 

Memorandum). EPA has affirmed this in a separate rulemaking proposal 

concerning Startup/Shutdown/Malfunction provisions in state SIPs. See 78 FR 

12460 (February 22, 2013). However, in Section III.A of the 1999 

Memorandum, EPA recommended very specific criteria that air agencies should 

consider including as part of any SIP provision that was intended to apply to 

sources during startup and shutdown in lieu of the otherwise applicable emission 

limitations. In order to revise the otherwise applicable emission limitation in the 

SIP, EPA recommended that in order to be approvable (i.e., meet CAA 

requirements), the new special requirements applicable to the source during 

startup and shutdown should be narrowly tailored and take into account 

considerations such as the technological limitations of the specific source 

category and the control technology that is feasible during startup and shutdown. 

EPA continues to recommend the seven specific criteria enumerated in Section 

III.A of the Attachment to the 1999 SSM Guidance as appropriate considerations 

for SIP provisions that apply to startup and shutdown. AMS has so far not 

explained how these criteria apply to the boilers at Veolia Energy Efficiency. 

These criteria are: (1) The revision must be limited to specific, narrowly defined 

source categories using specific control strategies (e.g., cogeneration facilities 

burning natural gas and using selective catalytic reduction); (2) use of the control 

strategy for this source category must be technically infeasible during startup or 

shutdown periods; (3) the frequency and duration of operation in startup or 

shutdown mode must be minimized to the maximum extent practicable; (4) as part 

of its justification of the SIP revision, the state should analyze the potential worstcase emissions that could occur during startup and shutdown; (5) all possible steps 

must be taken to minimize the impact of emissions during startup and shutdown 

on ambient air quality; (6) at all times, the facility must be operated in a manner 

consistent with good practice for minimizing emissions, and the source must have 

used best efforts regarding planning, design, and operating procedures to meet the 

otherwise applicable emission limitation; and (7) the owner or operator's actions 

during startup and shutdown periods must be documented by properly signed, 

contemporaneous operating logs, or other relevant evidence. See 78 FR 12460 

(February 22, 2013). 

AMS’s limitations for Veolia do not comply with the EPA’s policy on SSM. 

Automatic exemptions for SSM which AMS has created are impermissible for the 

SIP as explained above. In addition, AMS has not explained any alternative 

emission limitations for Veolia Energy Efficiency for startup and shutdown in 

accordance with the criteria in the 1999 Memorandum. EPA believes that the 

inclusion of these alternative limitations and automatic exemptions, which do not 
35 

comply with the requirements of the CAA, render these provisions for Veolia 

Energy Efficiency impermissible for RACT and impermissible as a SIP provision. 

Response: The SSM limits have been deleted as they are not on a rolling 30-day average 

and do not affect the rolling 30-day limits. 

 
36 

New Jersey Department of Environmental Protection (NJDEP) 

1. New Jersey disagrees with the cost per ton that AMS has selected as the threshold 

for economic feasibility. AMS has proposed a cost per ton of greater than $2,500 

as not being reasonable. New Jersey cost of NOx control per ton of NOx removal 

in our 1009 RACT rules was considerably higher, approaching $50,000 per ton 

for peaking units. Since peaking units (also referred to as high energy demand 

day units) operate mostly on hot summer days, which tend to be high ozone days, 

it’s especially important these be controlled. Use of an annualized $/ton metric 

fails to account for the cost effectiveness of controlling such electrical generating 

units which operate infrequently, but do so on high ozone days. If a peaking unit 

only operates on 10 potentially high ozone days per year, the air quality value per 

ton of NOx reduction is 30 times higher than a base load unit that operates 300 

days per year. 

Response: AMS must follow PADEP RACT regulations and policies. Please see the 

response to EPA General Comment 1. 

2. Utility Boilers

The attached Table 1 is a comparison of the proposed NOx RACT emission limits to 

the 2009 New Jersey RACT limits for utility boilers. 

Compliance with several of the proposed emission limits in the table is solely based 

on annual stack tests. New Jersey RACT rules require all utility boilers to 

continuously monitor NOx emissions using a CEMS. 

Some of the emission limits in the table are based on a 30 day rolling average 

compliance period for CEMS. A 24 hour compliance period is more appropriate 

because it will ensure low NOx emissions on high ozone days, whereas limits that are 

based on 30 day rolling average could allow higher emissions to be emitted on high 

ozone days. New Jersey has already adopted 24 hour emission limits for all its utility 

boilers with NOx continuous emission monitors. 

As can be seen in Table 1, all four boilers at Veolia Energy Philadelphia – Edison 

Station with emission limits of 0.5 lb/MMBTU for NOx significantly exceed the New 

Jersey RACT limit of 0.2 lb/MMBTU (2.0 lb/MWhr) for heavy oil.

The emission limits of 0.35 lb/MMBTU and 0.36 lb/MMBTU for the 2 boilers at the 

Veolia Energy – Schuylkill Station also exceed the New Jersey RACT limit of 0.2 

lb/MMBTU (2.0 lb/MWhr) for heavy oil. 

While the natural gas emission limit for the boiler at Grays Ferry Cogeneration is 

equivalent to the New Jersey RACT limit, the No. 2 fuel oil emission limit is 50% 

higher than New Jersey’s limit. 

Based on the above comparison, we recommend that Air Management Services lower 

the proposed RACT emission limits for these utility boilers to be no less stringent 
37 

than NJ RACT limits, require NOx CEMS on all utility boilers, and adopt a 24 hour 

compliance period for CEMS. 

Response: As mentioned above, AMS must follow PADEP RACT regulations and 

policies. This includes a case-by-case analysis of potential additional control options to 

determine if any are both technically feasible and economically reasonable, as per 25 Pa 

Code Sections 129.91-92. Evaluating Grays Ferry Cogeneration Boiler 25 under these, 

AMS has determined the proposed NOx emission limits as RACT. 

Evaluating potential new NOx control technologies for each Veolia boiler under case-bycase RACT, no additional NOx controls were determined both technically feasible and 

economically reasonable. Schuylkill Boiler #26 has low NOx burners. The other boilers 

do not due to existing annual capacity factor limits of 30%. AMS has proposed adding 

annual NOx RACT limits for these units that are equivalent to a 30% annual capacity 

factor. 

Upon further review of past stack test and, for Boiler #26, Continuous Emission 

Monitoring System (CEMS) data for the case-by-case RACT units, AMS has determined 

the following NOx emission limits could be achieved under existing technologies: 

A. Veolia – Edison Station 

FACILITY Equipment Size Fuel RACT Limit NJ RACT Limit

Boiler #1

283

MMBTU/hr

#6(Primary);

#2(ignition) 0.50 lb/MMBTU 2.0 lb/MWhr (equivalent to0.2 lb./MMBTU)

Boiler #2

283

MMBTU/hr

#6(Primary);

#2(ignition) 0.50 lb/MMBTU 2.0 lb/MWhr (equivalent to0.2 lb./MMBTU)

Boiler #3

335

MMBTU/hr

#6(Primary);

#2(ignition) 0.50 lb/MMBTU 2.0 lb/MWhr (equivalent to0.2 lb./MMBTU)

Boiler #4

335

MMBTU/hr

#6(Primary);

#2(ignition) 0.50 lb/MMBTU 2.0 lb/MWhr (equivalent to0.2 lb./MMBTU)

Boiler #23

795

MMBTU/hr

#6(Primary);

#2(ignition) 0.35 lb/MMBTU 2.0 lb/MWhr (equivalent to

0.2 lb./MMBTU)

Boiler #26

761

MMBTU/hr #6

0.36 lb/MMBTU30 day rolling

avg

2.0 lb/MWhr (equivalent to

0.2 lb./MMBTU)

Grays Ferry Cogeneration

Partnership (2600 Christian

Street)

Boiler #25

1119

MMBTU/hr NG& #2

0.10 lb/MMBTU(NG); 0.15

lb/MMBTU(oil)

1.0 lb/MWhr (equivalent to

0.1 lb./MMBTU)

Veolia Energy Philadelphia –

Edison Station, formerly

Trigen – Edison (908 Sansom

Street)

Veolia Energy – Schuykill

Station, formerly Trigen –

Schuylkill (2600 Christian

Street)

Table 1: Utility Boilers
38 

1. Boiler #1 – 0.39 lbs/MMBTU and 110.37 lbs/hr 

2. Boiler #2 – 0.39 lbs/MMBTU and 110.37 lbs/hr 

3. Boiler #3 – 0.38 lbs/MMBTU and 127.3 lbs/hr 

4. Boiler #4 – 0.38 lbs/MMBTU and 127.3 lbs/hr 

B. Veolia – Schuylkill Station 

1. Boiler #23 – 0.34 lbs/MMBTU and 270.30 lbs/hr 

Boiler #26 – 0.36 lbs/MMBTU on a 30-day rolling average (existing limit) and 

0.41 lbs/MMBTU and 312.01 lbs/hr on an hourly basis (no previous hourly limit) 

3. Industrial Boilers

The attached Table 2 is a comparison of the proposed NOx RACT emission limits to 

the New Jersey RACT emission limits for industrial boilers. 

The proposed NOx limits for the four industrial boilers greater than 100 MMBTU/hr 

in Table 2 are well above the New Jersey RACT emission limits. Their emission 

limits range from 0.2 lb/MMBTU for natural gas to 0.35 lb/MMBTU for No. 6 fuel 

oil. New Jersey’s RACT limits are 0.1 lb/MMBTU for natural gas and 0.2 

lb/MMBTU for No. 6 fuel oil. 

Three of the boilers that burn No. 6 fuel oil have a NOx limit of 0.4 lb/MMBTU. 

New Jersey’s NOx RACT limit for No. 6 fuel oil is 0.2 lb/MMBTU. 

Based on the above comparison, we recommend that Air Management Services lower 

the proposed RACT emission limits for these industrial boilers to be no less stringent 

than NJ RACT. 
39 

Response: As mentioned above, AMS must follow PADEP RACT regulations and 

policies. Evaluating the listed industrial boilers under these, AMS has determined the 

proposed NOx emission limits as RACT. 

Please note that the stated NJ RACT limits are not automatic limits for all boilers, as 

N.J.A.C. 7:27-19.3(f) allows for alternative compliance methods, including an alternative 

maximum allowable emission rate for the unit, approved by the NJDEP pursuant to N.J.A.C. 

7:27-19.13. None of the boilers listed above emits near its potential. The Honeywell boilers 

and PaperWorks boiler have restrictions which prevent them from burning No. 6 oil during 

normal operation. These restrictions are being brought into RACT. The Temple – Health 

Sciences boilers are being given a RACT restriction that prevents them from burning No. 6 

oil during normal operation during the ozone season. The Temple – Main boilers have a 

combined NOx limit of 15.5 tons per year which is being brought into RACT. 

FACILITY Equipment Size Fuel RACT Limit NJ RACT Limit

Boiler #1

260

MMBTU/hr

Waste Residue,

Gas, or #6

0.35 lb/MMBTU

0.1 lb/MMBTU(gas)

0.2 lb/MMBTU(#6 oil and

other liquid fuel)

Boiler #2

260

MMBTU/hr

Waste Residue,

Gas, or #6

0.35 lb/MMBTU

0.1 lb/MMBTU(gas)

0.2 lb/MMBTU(#6 oil and

other liquid fuel)

Boiler #3

381

MMBTU/hr Gas or #6 0.3 lb/MMBTU

0.1 lb/MMBTU(gas)

0.2 lb/MMBTU(#6 oil and

other liquid fuel)

PaperWorks, formerly

Jefferson Smurfit (5000 Flat

Rock Road)

Boiler #1

240

MMBTU/hr NG/#6 back‐up

0.2 lb/MMBTU30 day rolling

avg (NG); 0.30 lb/MMBTU 30

day rolling avg (#6)

0.1 lb/MMBTU(gas)

0.2 lb/MMBTU(#6 oil and

other liquid fuel)

Boiler #1

76.4

MMBTU/hr NG& #6

0.067 lb/MMBTU(NG); 0.40

lb/MMBTU #6

0.05 lb/MMBTU (gas)

0.2 lb/MMBTU(#6 oil and

other liquid fuel)

Boiler #2

76.4

MMBTU/hr NG& #6

0.067 lb/MMBTU(NG); 0.40

lb/MMBTU #6

0.05 lb/MMBTU (gas)

0.2 lb/MMBTU(#6 oil and

other liquid fuel)

Boiler #3

76.4

MMBTU/hr NG& #6

0.067 lb/MMBTU(NG); 0.40

lb/MMBTU #6

0.05 lb/MMBTU (gas)

0.2 lb/MMBTU(#6 oil and

other liquid fuel)

Boiler #1 91.3(NG)/

86.8(#2) NG& #2

0.036 lb/MMBTU(NG); 0.110

(#2) 25 PA 127.1

0.05 lb/MMBTU (gas)

0..08 lb/MMBTU (#2 oil)

Boiler #2 91.3(NG)/

86.8(#2) NG& #2

0.036 lb/MMBTU(NG); 0.110

(#2) 25 PA 127.1

0.05 lb/MMBTU (gas)

0..08 lb/MMBTU (#2 oil)

Boiler #3 91.3(NG)/

86.8(#2) NG& #2

0.036 lb/MMBTU(NG); 0.110

(#2) 25 PA 127.1

0.05 lb/MMBTU (gas)

0..08 lb/MMBTU (#2 oil)

Temple University – Main

Campus (Broad Street and

Montgomery Avenue)

Honeywell, formerly Sunoco

Chemicals (4700 Bermuda

Street)

Temple – Health Sciences

(3401 North Broad Street)

Table 2: Industrial Boilers
40 

State of Delaware Department of Natural Resources & Environmental Control 

(DEDNREC) 

Comment 1: Technological feasibility determination: The EPA has defined RACT as 

the lowest emission limitation that a particular source is capable of meeting by the 

application of control technology that a particular source is capable of meeting by the 

application of control technology that is reasonably available considering 

technological and economic feasibility (44 FR 53762). Delaware request AMS revisit 

the following proposed technological feasibility determination. 

 Honeywell International, Frankford Plant. For boiler 1 and 2, the proposal 

indicates that Selective Non-Catalytic Reduction (SNCR) is not a feasible NOx 

control technology because, “load and NOx Concentration variations with the 

boilers makes placement of the catalyst difficult and makes it difficult to maintain 

a proper ammonia injection rate”. SNCR technology does not include catalyst, 

and can be engineered and install to be effective over a wide unit operating range. 

Delaware believes it is unlikely that SNCR is technically infeasible for these 

applications, and requests that AMS revisit this determination. 

Response: The supporting documentation incorrectly used the term “catalyst” and has 

been fixed. The correct term is “SNCR.” The SNCR by name is Selective Non-Catalytic 

Reduction that reduces NOx to Nitrogen and water vapor by reacting the flue gas with 

reagent Ammonia. It is dependent upon the reagent injector location and temperature to 

achieve proper reagent /flue gas mixing for NOx reduction. Honeywell's boiler load is 

constantly changing to accommodate the demands of the chemical process. As a result, 

accurate ammonia injection for NOx controls cannot be achieved effectively. 

 Honeywell International, Frankford Plant. For Boiler 3, the proposal indicates 

that water/steam injection is technically infeasible, indicating that it is ineffective 

for #6 fuel oil in boilers. Water/steam injection is technically feasible and an 

effective NOx reduction technique for boilers firing any fuel. It would seem likely 

that it would also be technically feasible for this installation. Delaware 

recommends that AMS conduct additional technical evaluation for this control.

Response: Steam or water injection is used to reduce the peak flame temperature, 

therefore reducing the formation of thermal NOx. This method is used in reducing NOx 

emissions from gas turbines, reciprocated engines, and ICE. The boiler configuration fire 

box does not provide sufficient minimum residence time for water injection at the 

combustion temperature for acceptable steam generation to prevent process upset.

Furthermore, this will not reduce fuel NOx and is not good for #6 oil boilers which have 

a direct reduction in thermal efficiency2,3. 
41 

 Temple University – Health Science Campus. For boilers 1, 2, and 3, the 

proposal discusses the capability and ability of ultra low NOx burners (ULNBs) to 

operate in a retrofit situation. There appear to be a number of misconceptions in 

the discussion. For example, the document indicates that ULNB and only be used 

in bottom fired, balance draft installations. While there may be certain ULNBs 

designed specifically for this type of application, ULNB are available in service 

for multiple firing configurations, including wall fired installations, and are also 

available from some manufacturers for natural draft, forced draft, and balance 

draft application. The Flue Gas Recirculation refered to for ULNB is typically a 

function of the flame shaping to bring the flue gas into the developing flame as an 

internal function/shape/dynamic of the development flame and not a traditional 

FGR system. Further, use of preheated air (maintaining the function of any 

existing air pre-heating device) is still possible using ULNBs. It appears that the 

inaccuracies may have contributed to the assessment that ULNBs are not feasible. 

Delaware recommends that AMS further evaluate controls based upon more 

recent ULNB capabilities. 

Response: Boiler 1,2 and 3 all have use the following requirements (CCA burner 

modification technology). 

1. Installation of staged flame stabilizers (a.k.a. swirlers). 

2. Re-design and replacement of the atomizers. 

3. Replacement of the center-fired gas injection rings with gas manifolds having 

centerfired and poker injection. 

4. Installation of a NOx tempering system (water injection to cool flame and reduce 

thermal NOx formation). 

This technology is better than ULNBs that only reduce 10-15% NOx for #6 oil 

(Constant problem of utilizing ULNB for #6 fuel oil) whereas the above 

technology reduces NOX by 33-50%, satisfying the RACT definition of lowest 

achievable emission rate. 

The use of ULNB is also not feasible due to the boilers’ sizes of 76 MMBTU/hr 

and operation limitations (MMBTU/yr), which are equivalent to around 25 

MMBTU/hr each. 

 Temple University –Main Campus. For the three BMCEP boilers, the proposal 

indicates that water injection is not technologically feasible since the primary 

contributor to NOx emissions during oil fired combustion is fuel NOx (as opposed 

to thermal NOx) and that there is an efficiency loss associated with the water 

injection. Water injection is a proven NOx reduction technology for oil fired 

boilers that is in commercial use. Delaware does not agree that water injection is 

technologically infeasible for these boilers. Delaware recommends further 

analysis, and that any additional operating costs associated with efficiency loss 

due to water injection be assessed in the cost effectiveness evaluation. 

Response: The boiler fire box size does not provide sufficient minimum residence time 

for water injection at the combustion temperature for acceptable steam generation. 
42 

Furthermore, each boiler is equipped with LNB and FGR that Nitrogen Oxides (NOx) 

emissions from the three boilers combined shall not exceed 15.5 tons per rolling 12-

month period. Each boiler has a limit of 0.036 lbs/MMBTU when fire gas and 0.110 

lbs/MMBTU while burning Fuel oil. These values are below the NJ, PA (0.20 lb/mmbtu 

when burning fuel oil and 0.08 lb/mmbtu when burning NG) limits and other states’ 

limits.

1. NOx Emissions from each boiler shall not exceed the following: [25 Pa Code 

§127.1] 

a) Nitrogen Oxides (NOx) emissions from the three boilers combined shall not 

exceed 15.5 tons per rolling 12-month period. 

b) Emissions from each boiler shall not exceed the following: [25 Pa Code 

§127.1] 

i) NOx: 0.036 lbs/MMBTU while burning natural gas and 

ii) 0.110 lbs/MMBTU while burning No.2 fuel oil 

2. Each boiler shall be equipped with Low NOx burners (LNB) and flue gas 

recirculation (FGR). 

Comment 2. Economic feasibility Determinations: The EPA has defined RACT as the 

lowest emission limitation that a particular source is capable of meeting by the 

application of control technology that a particular source is capable of meeting by the 

application of control technology that is reasonably available considering technological 

and economic feasibility (44 FR 53762). 

AMS has proposed a $2,500 per ton cost threshold to judge RACT economic

feasibility. Delaware and other States have determined, and required, emission

controls costing more than four times this threshold to be economically cost effective. 

Emission controls that are currently required in the SIPs of other states, particularly 

states within the same nonattainment area boundaries, should not be discarded as 

economically unreasonable based on this low cost threshold. Delaware recommends 

that AMS revisit the following determinations, as additional emission controls appear 

economically reasonable. 

• Philadelphia Energy Solutions Refining and Marketing LLC (PES). ULNB and 

SNCR NOx control on Unit 860-2H2, 860-2H4, 864-PHl , 137 F-1, and 137 F-2 

appear economically reasonable at between $3104 and $4499/ton. 

• Honeywell International, Frankford Plant. For the boiler 3, SCR appears
43 

economically reasonable, as AMS estimates it would reduce NOx by 85% (425 

tpy) at a cost of 3836 $/ton. 

• Paperworks Industries, Inc. For boiler 1, the following control options appear 

cost effective: $4481/ton for FOR, $3693/ton for SNCR, and 

 $4165/to for SCR. 

• Newman and Company, Inc. FOR on boiler 1 appears cost effective at 

 $3564/ton. 

• Temple University - Health Sciences Campus. SCR appears economically

reasonable at $3024/ton. 

• Grays Ferry Cogeneration Partnership. SNCR at $4407/ton, ULNB at 

 $3496/ton, and ULNB + OFA at $4063 all appear economically 

reasonable for boiler 25. 

• Veolia-Energy Efficiency (PA) LLC, September 4, 2014. For 

boilers 1 and 2, OFA and LNBs appear economically reasonable 

at $4674/ton for OFA and $4571/ton for LNBs. 

Response: AMS must follow PADEP RACT regulations and policies. Please see the 

response to EPA General Comment 1. 

Comment 3: Consideration of daily emissions. Emission control technology that was

deemed not cost effective on diesel fired units in the proposal, in all cases, was based on 

tons per year estimates. In Delaware's experience diesel-fired units are typically 

operated on a daily or hourly basis, and as such significantly contribute to episodic 

ozone concentrations. Evaluation of emission control cost effectiveness on a $/ton 

basis for units that operate in this fashion is not appropriate. 

For the Exelon Generating Company - Southwark Station, the proposal addresses 

four 15.5 MW combustion turbine EGUs firing #2 fuel oil. The proposal provides 

that the existing 5% annual capacity factor limitation represents RACT. Delaware 

does not agree that an annual capacity factor limitation adequately represents 

RACT. These combustion turbine EGUs tend to operate as peaking devices, 

operating at high outputs during periods of summertime high electric demand. These 

periods of summertime high electric demand tend to coincide with conditions 

conducive to ozone formation. These units should be subject to installation of 

emission controls or short term NOx emission rate limits representative of operation 

with NOx emission controls such as water injection, ULNBs, etc. 

Delaware suggests that AMS address daily emissions from diesel and combustion 
44 

turbine units by adopting requirements similar to what Delaware has done in 7 DE 

Admin. Code 1144, Control of Stationary Generator Emissions, and 7 DE Admin. 

Code 1148, Control of Stationary Combustion Turbine Electric Generating Unit 

Emissions. 

Response: AMS must follow PADEP RACT regulations and policies. Please see the 

response to EPA General Comment 1. PA RACT regulations do not allow for the 

evaluation of case-by-case RACT on a daily basis. Additionally, combustion turbines 

with an annual capacity factor of less than 5% are a applicable to the presumptive RACT 

requirements of 25 Pa Code Section 129.93(c)(5) instead of case-by-case RACT. 

Comment 4: Interest rate and life usage. The interest rate and control equipment life, 

which are major inputs to an economic analysis, are extremely variable throughout 

the AMS proposal. Many appear unrealistically conservative at 20% interest 

combined with a control equipment life of 10 years, and others appear reasonable at 

4% interest and 20 years. Unrealistically conservative values tend to greatly 

increase the calculated cost effectiveness values. 

Delaware and the Ozone Transport Commission (OTC) have been using 6% cost of

capital and a 20 year life for control equipment in estimating the cost and cost

effectiveness of emission control projects. 6% reflects a conservative value for a

long duration debt. In fact, current actual values are significantly lower, ranging

from about 5% down to about 2% over the last few years, reflecting the low

Treasury rates and relatively low economic growth. A 20 year life is reasonable

given that the calculations include operating and maintenance costs (including

catalyst replacement for SCR) that are anticipated to be needed to keep the control

equipment functioning properly over the life of the control equipment. Delaware

recommends that AMS determine economic reasonableness using an interest rate of 

6% and a control equipment life of 20 years. 

Response: The interest rate and life usage depends on the company and the particular 

unit. The cost of raising funds can be high for facilities. The life usage of a control 

option will not be as long for an old unit as the unit may only be expected to operate 

another 10 years. After further review, AMS revised the equipment life and the interest 

rate for some of the facilities. 

Compliance Management International (CMI) 

On behalf of Kinder Morgan Liquid Terminals (KMLT) 
45 

In addition to the edits shown in the attached marked up Draft RACT Plan approval, 

Kinder Morgan has the following comments. 

 

1. Cover Sheet, Page 1 of 4. Kinder Morgan is unsure why the plan approval is it 

replacing the 1 hour RACT Plan Approval. Kinder Morgan understanding was 

that this RACT evaluation was to comply with the 8 hour standard. In addition, 

the original RACT Plan approval is expired and was incorporated into the Title V 

operating permit. 

Response: This was an error and as been removed. Please note that RACT Plan 

Approvals do not expire, even after they are incorporated into a Title V operating permit. 

2. GATX was the former owner of the facility. Please remove references of GATX 

from the permit. 

Response: This has been corrected. 

3. Condition A.1 and condition 2.C. Do the controlled racks require to be listed? 

Since this may be changed in the future, we would not need to revise the State 

Implementation Plan (SIP) if such a change takes place under plan approval. Can 

the conditions refer just controlled loading positions? 

Response: The specific controlled racks must be listed. 

4. Condition 2.F. Although this was in the original RACT Plan, Kinder Morgan 

requests Air Management Service provide the basis for this requirement. 

Response: The RACT requirements for marine loading in the original RACT plan 

approval were approved based on it not processing petroleum distillate with vapor 

pressures greater than 4.0 RVP. 

5. Condition 5.A. This condition requires Kinder Morgan to implement and comply 

with the conditions of this permit no later than March 31, 1995. Since there are 

new requirements in this permit, Kinder Morgan cannot retroactively comply. 

Please revise to a date to a point in the future. 

Response: That was the requirement for the original RACT plan approval and cannot be 

changed. AMS will allow a new compliance date for any new installation requirements 

under the amended RACT plan approval. 

6. Conditions 7.C. and 7.D. Kinder Morgan request more specific listing of the 

records and what would be considered sufficient data by AMS for Kinder Morgan 

to ensure compliance. As is, these conditions leave too much to interpretation of 

the records and types of data needed for compliance. 
46 

Response: The proposed new Conditions 7.A. and 7.B were added to help clarify the 

requirements. Kinder Morgan may propose additional recordkeeping requirements.

7. Condition 8. Kinder Morgan requests this condition be removed since it is 

unrelated to RACT requirements. Kinder Morgan is already required to meet 

these requirements as stated in Title V permit and other permits issued since 

2005. 

Response: AMS will remove this condition. 

8. Condition 9. Kinder Morgan requests this condition be removed. Kinder 

Morgan does not have the authority to modify the State Implementation Plan. 

Kinder Morgan asserts this is the responsibility of Air Management Services and 

thus would never be able to certify compliance with this condition. 

Response: AMS will remove this condition since it is not a specific facility requirement 

and a similar condition is not included in most RACT plan approvals issued by AMS.

Ballard Spahr LLP 

On behalf of Temple University (Temple) 

Note: Responses to various written comments submitted on behalf of Temple, via letters 

dated October 20, 2014 and November 19, 2014, and via email dated October 16, 2014 

follow below. The written comments submitted via letter dated November 19, 2014, fall 

outside the relevant public comment period and do not require a response. See e.g. 25 Pa. 

Code § 127.47(b) (no response required for protests filed outside of comment period for 

proposed plan approval). Nonetheless, AMS will address even these untimely comments, 

in turn. 

Comment: Requiring natural gas to be burned in existing, multi-fuel fired boilers during 

ozone season is not a valid “control technology” that can be required by AMS to meet 

RACT NOx requirements under the Federal Clean Air Act and State Air Pollution 

Control Acts. See Letter from Ballard Spahr to AMS, Dated October 20, 2014 at *3. 

See also Letter from Ballard Spahr to AMS, Dated November 19, 2014 at *2. 

Response: AMS has reviewed applicable federal and state authorities and determined 

that restricting the type of fuel used in existing multi-fuel boilers during ozone season is a 

valid control technology that can be evaluated and required as RACT for air pollution 

sources pursuant to the Federal Clean Air Act, and State Air Pollution Control Act. A 

valid Case by Case RACT NOx analysis must examine all air pollution control 

technologies and techniques that have reasonable application for a particular source. See

25 Pa. Code § 129.92(b)(1). Air pollution control technologies and techniques “include 

the application of production process or methods, control systems for VOCs and 

NOx and fuel combustion techniques for the control of NOx.” Id. (emphasis added). 
47 

Requiring the use of a particular fuel (e.g. natural gas) at particular times of the year (e.g. 

ozone season) is a reasonable applicable fuel combustion technique for NOx control in an 

existing multi-fuel boiler that can combust such fuel without any physical changes. See

Id. EPA recognizes that requiring the combustion of a “cleaner fuel, such as natural gas, 

during the ozone season . . . and switch[ing] back to the ‘historic’ fuel for some or all of 

the non-ozone season” as a method to meet RACT NOx requirements. See e.g. Fuel 

Switching to Meet the Reasonable Available Control Technology (RACT) Requirements 

for Nitrogen Oxides (NOx) (July 30, 1993 Memo from Michael H. Shapiro to EPA 

Regional Offices). See also Nitrogen Oxides (NOx) Questions from Ohio EPA (March 

30, 1994 Memo from G.T. Helms to George Czerniak, Chief of EPA R5 Regional Air 

Compliance Branch); Alternative Control Techniques Document—NOx Emissions from 

Industrial/Commercial/Institutional (ICI) Boilers (March 1994, EPA Office of Air and 

Radiation – Emissions Standards Division) (discussing fuel restriction in ICI Boilers as a 

combustion modification technology to meet RACT NOx requirements). 

Comment: Requiring natural gas to be burned in existing, multi-fuel fired boilers during 

ozone season cannot be used to meet RACT NOx requirements because it is not cost 

effective. See Letter from Ballard Spahr to AMS, Dated October 20, 2014 at *3.

Response: AMS has reviewed historical fuel data provided by Temple and determined 

that requiring use of natural gas during ozone season to be cost-effective. From 2011 

through 2013, Temple obtained and burned natural gas in the three, multi-fuel fired 

boilers in question over 99% percent of the time, year round. See e.g. RACT 

Modification Summary for Temple University – Health Sciences Campus Memo, dated 

December 16, 2014 at *5. While price spikes occur, the use of natural gas as a primary 

fuel during ozone season was shown to be economically reasonable under current and 

projected prices. Most natural gas price spikes occur during the winter, such as those that 

occurred in January 2014 as demonstrated in Appendix C to Temple’s written comments 

from October 20, 2014, and are outside of ozone season, the designated time period from 

April 1 through October 31. 

Comment: The RACT analysis performed by AMS failed to consider the alternative 

RACT proposal for Temple Health Science Center, submitted by Temple on October 16, 

2014. See Email to AMS w/ Attached Temple Health Science Center RACT Proposal, 

Dated October 16, 2014. See also Letter from Ballard Spahr to AMS, Dated November 

19, 2014 at *2. 

Response: AMS has evaluated Temple’s alternative RACT proposal and determined it 

to be insufficiently protective pursuant to Federal and State RACT implementing 

regulations. A full analysis of this proposal can be found on page 9 of the RACT 

Modification Summary for Temple University – Health Sciences Campus Memo, Dated 

December 16, 2014. 

Comment: Temple does not have adequate notice or opportunity to comment on the 

proposed maximum combined heat input limit of 500,000 MMBtu/year for boilers No. 1-
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3 when burning No. 6 Oil at Temple Health Science Center. See Letter from Ballard 

Spahr to AMS, Dated November 19, 2014 at *1-*2. 

Repsonse: After further review, AMS has not included a maximum combined heat input 

limit of 500,000 MMBtu/year for Boilers No. 1-3 when burning No. 6 Oil at Temple 

Health Science Center in the relevant RACT plan approval.