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 fo llowing facilities: Exelon – Delaware Station (1325 N. Beach Street, Philade lphia, PA 19125), Exelon Generating Company – Richmond Station (3901 N. De laware Avenue, Philadelphia, PA 19137), Exelon Generating Company – Schuylk ill Station (2800 Christian Street, Philadelphia, PA 19146), Veolia Energy Phila delphia – Edison Station (908 Sansom Street, Philadelphia, PA 19107), Veolia En ergy – Schuylkill Station (2600 Christian Street, Philadelphia, PA 19146)

CITY OF PHILADELPHIA
DEPARTMENT OF PUBLIC HEALTH
AIR MANAGEMENT SERVICES

COMMENT AND RESPONSE DOCUMENT

December 12, 2014PREAMBLE

On December 13, 2013 (78 FR 75902), EPA c onditionally approved Philadelphia’s 1997 8-hour ozone RACT demonstration provide d in the 2006 and 2010 SIP revisions, based upon a commitment from AMS to submit addi tional SIP revisions to provide sourcespecific RACT determinations for certain major sources of VOC and NOx in Philadelphia and a certification that previous ly 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 (a s 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 a nd one 17.5 MW combustion turbine.

 Exelon Generating Company – Richmond Station (3901 N. Delaware Avenue, Philadelphia, PA 19137), with tw o 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 Sta tion (908 Sansom Street, Philadelphia, PA 19107), with two 283 MMBTU/hr boile rs 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 MMB TU/hr combustion turbine.

On March 26, 2012, EPA determined that the Philadelphia area atta ined the 1997 8-hour ozone National Ambient Air Quality Standard.

On June 26, 2014, a notice was placed in th e Philadelphia Daily News announcing that the Philadelphia Department of Public He alth, Air Management Services Division (AMS), proposed to revise th e 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 equi valent notice was published in the Pennsylvania Bulletin on June 28, 2014. The no tices 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 clos ing date (AMS used latest not ice 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 heari ng, 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 Qualit y, 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 s horter 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-cyc le 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/MMBTU 1,2 (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/MMBTU 1,3

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 baselineemissions. Section 129.93 establishes “pre sumptive” 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 ec onomically 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 annua l NOx RACT limits for these units that are equivalent to a 30 % annual capacity factor.

The four turbines at Exelon – Delaware Sta tion and two turbines at Exelon – Schuylkill Station all meet the presumptive RACT requi rements 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 ca se-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 te st and, for Boiler #26, Continuous Emission Monitoring System (CEMS) data for the cas e-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 ro lling 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 combus tion turbines will be required to burn No. 2 oil with a sulfur limit of 15 ppmw or lower. A 2005 study from the BrookhavenNational Laboratory has shown th at reducing the sulfur conten t from standard levels to ultra low levels reduces NOx emissions by 20-30%.

With the exception of the Boiler #26, complia nce with all existing NOx RACT emission
limits at these fac ilities 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 incl udes 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 turb ines to no more than 15 ppmw, beginning July 1, 2015.

The modification to the RACT Plan Approva ls 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, 20152 PREAMBLE

On December 13, 2013 (78 FR 75902), EPA c onditionally approved Philadelphia’s 1997 8-hour ozone RACT demonstration provide d in the 2006 and 2010 SIP revisions, based upon a commitment from AMS to submit addi tional SIP revisions to provide sourcespecific RACT determinations for certain major sources of VOC and NOx in Philadelphia and a certification that previous ly 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 (a s 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-sp ecific 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 cer tifying 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 oz one 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 No rth Delaware Avenue); PaperWorks, formerly Jefferson Smurfit (5000 Flat Rock Road); Temple – Health Sciences (3401 North Broad Street); PES Re finery, formerly Sunoco Refinery (3144 Passyunk Avenue.

This SIP revision also include s 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 Effici ency (2600 Christian Street).

On March 26, 2012, EPA determined that the Philadelphia area atta ined the 1997 8-hour ozone National Ambient Air Quality Standard.

Notice that AMS proposed to revise or i ssue RACT plan approvals for the above referenced facilities was published in th e Philadelphia Daily News on September 18, 19, and 22 of 2014. Notice that AMS proposed to re vise 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 Penns ylvania 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 wa s scheduled for, October 22, 2014. Id. The public hearing was cancelled because no timely re quests 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 heari ng, so it was cancelled. During the public comment period, AMS received comments fr om five (5) commentators.
List of Commentators

1. David L. Arnold Acting Director, Air Protection Divi sion, United States Environmental Protection Agency, Region III (EPA)

2. William O’Sullivan Director, Division of Air Qualit y, New Jersey Department of Environmental Protection (NJDEP)

3. Ali Mirzakhalili Director, Division of Air Quality, St ate of Delaware Department of
Natural Resources & Envir onmental Control (DEDNREC)

4. Kristian Witt Technical Director, Compliance Ma nagement 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 “R easonably 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 e ffectiveness “benchmark” of $2,500 per ton of nitrogen oxides (NO
x ) 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 NO
x and VOC RACT comparable co st-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 c ontrols 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 ra tionale in its March 16, 1994 memorandum “Cost-Effective Nitrogen Oxides (NO
x ) Reasonably Available Control Technology (RACT).” 1 Thus, EPA strongly cautions AMS not to rigidly apply a
benchmark to exclude consideration of t echnically 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 ne arby states have adopted recent NO
x RACT limits with far higher average cost effectiveness than $2,500 per ton. For instance, New York State estimated that the proposed NO
x limits to take effect in 2015 would have an average cost eff ectiveness ranging from $2,600 to $5,463 per ton (Proposed revisions to Subpart 22 7-2 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
NO
x RACT of $3,000 per ton (in 1994 U.S. dollars) over which an “emission
source of VOC or NO
x will not be required to imp lement any emission reduction or control strategy that is more costly th an the established th reshold 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 NO
x costeffectiveness level used in the source-sp ecific RACT evaluations and indicate the applicable VOC cost-effectiveness level used, if any. AMS should consider in this justification the NO
x cost-effectiveness levels established by nearby states.

Finally, while cost effectiveness, as described above, is an important consideration, it must be noted that othe r factors should be integrated into a RACT analysis, such as emission redu ctions and environmental impact, among
others.

Response: AMS follows Pennsylvania Departme nt of Environmental Protection (PADEP) RACT regulations and policies. PA DEP 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-effectivene ss upper-bound of $2,800 per ton NOx c ontrolled.

It should be noted that Wisconsin’s RACT rule, using a $2,500 per ton cost benchmark, equivalent to approximately $2,700 in 2014 do llars, was approved as a SIP revision on
October 19, 2010.

It should also be noted that this evalua tion 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 requireme nts 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 av eraging is appropriate fo r RACT and any proposed
RACT emissions limits should include th is consideration. Because compliance
with the 1997 8-hour ozone national ambi ent 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 ba sed upon a short-term time period, such as daily or 24-hour rolling average ba sis, 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 NO
x 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 NO
x and VOC
emissions for each affected emissi ons source and associated supporting documentation. AMS should provide potenti al 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 assump tions 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 th e 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 avai lable controls as RACT for emissions sources that is subject to Pennsylva nia’s source-specific RACT requirements
under 25 Pa Code 129.91-94.

EPA has long defined RACT as the “lowes t emission limitation that a particular source is capable of meeting by the app lication of control technology that is reasonably available considering technol ogical 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 ra te 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 th e 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 cu rrently does not represent the lowest reasonably achievable rate to a more stri ngent level of emissions to satisfy RACT
under the 1997 8-hour standard. Such revisi ons would be consistent with the antibacksliding requirements of Clean Air Act (CAA) section 110(l).

As part of this demonstration, EPA re commends relying on actual emissions of7 NO
x and/or VOC for each emissions source su bject to source-specific RACT. In general, cost considerations should not be necessary for evaluating the appropriateness of existing RACT emissi ons 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 certa in 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, b ecause 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 pr ovided a list of “minor” and shutdown facilities in Philadelphia (p ages 14-15). EPA believes that AMS did not provide sufficient information to evaluate the proposed certification.

EPA believes it is appropriate to provid e 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 cas e that a facility ha s taken a facility-wide restriction on PTE to be under the app licable RACT major source thresholds, AMS should refer to the applicable perm it that allows such restriction. For facilities that have shutdown, AMS need s to show that these shutdowns are Federally-enforceable for the facility to not have to comply with RACT.

Response: AMS has added documentation as requeste d. 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 Philadelp hia Air Management Code Section 3-306.
Potential emission calculations have been added for the Northeast Water Pollution
Control Plant and the Southwest Water Polluti on Control Plant to s how 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 ma rine 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 ve ssel loading. CAA section 183(f)(4) provides that state regulations governi ng VOC emissions from marine tank
vessels must be at least as stringent as the Federal sta ndard. AMS needs to justify that the RACT provisions of 25 Pa C ode 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 re vise 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. Accordi ngly, for any revisions of SIP-approved RACT control measures, AMS must expl ain 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 whet her the SIP revision will allow for an
increase in actual emissions into the air over what is allo wed 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 reduc tions, in accordance with CAA section 110(l).

Response: AMS has included this analysis for ch anges 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 requi rements for source categories. These exemptions are generally based on the St ate’s determination that the required level of control is generally not reas onable, considering technological and economic feasibility, for the affected em issions 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 sh ould be determined based on technical and economic infeasibility of a determined leve l of control.

Major sources of NO
x and VOC in Philadelphia for which no other RACT requirement has been established are subj ect to source-specifi c requirements of 25 Pa Code 129.91-94. Under this regulation, RA CT is required to be determined on a case-by-case basis, based on the tec hnical 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 w ould not be appropria te to define a general de minimis level of VOC and NO
x , respectively, for the vast universe of9 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 s ource categories. In establishing such categories, AMS could consider purpos e, 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 ba sis, consistent with the RACT requirements of 25 PA Code 129.91-94. Any determination by AMS for defining de minimis levels of NO
x 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 boile r rated just below 20 MMBTU/hr with NOx emissions of 0.1 lbs/MMBTU (r oughly 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 ma nufacturer’s specifications under the SIP-approved CTG regulation 25 Pa Code 129.93(c)(1). Additi onal 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 th e 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 (P ES) (formerly Sunoco- R&M)
1. On page 17, AMS states that “PES, incl uding the Tank Farm, is subject to the 1- hour RACT determination (PA Perm it 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 Sunoc o 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 Plan t 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 bot h the Refinery and the Tank Farm. AMS has modified the supporting documentation to make this clearer.10 2. AMS must provide the actual and potent ial 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 Septembe r 2014 Revision” that AMS is adding to the SIP revision documentation.

3. The following existing NO
x emissions sources at the re finery, 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 memo randum: Unit 860- 2H1 (49 million British Thermal Unit per hour (MMBTU/hr) of h eat 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 restrict s PES from burning refinery oil except under certain circumstances, including ga s curtailments. Because “PES has completely stopped burning oil,” AMS is proposing to remove from the SIP the
NO
x emissions limits for emission sources burning refinery oil that were approved as RACT under the 1-hour oz one NAAQS. In order for EPA to approve the proposed remova l of the oil emissions limits, AMS needs to show that PES (or formerly Sunoco) has taken a Federally-enforceable limit to completely restrict burning refi nery oil throughout the facility.

Response: The heaters and boilers are not authori zed 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. Th e wording in the supporting documentation has been modified to clarify that specifically th e heaters and boilers no longer burn oil. The facility has IC engines which burn diesel.

5. AMS did not provide sufficient informati on to evaluate the control feasibility analysis provided for PES for emissi ons 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 fo r estimating cost-effectiveness of technically feasible controls. Without this information, EPA is unable to properly evaluate the source-specific NO
x 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 expl anation of the techni cal 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 NO
x and VOC RACT for the emissions sources at the facility. AMS should include the PES submittal as part
of the SIP revision to furthe r support AMS proposed RACT.

Response: This will be included. The document was available at AMS during the public comment period and available for pub lic review, upon request. The document was analysis supporting AMS’ proposed RACT for PES.

7. On page 29, AMS states that the potential NO
x 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, wh ile 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 da y. The potential annual emissions are based on the 365-day limit. Table 1 lists sh ort-term capacities, so the daily limit was listed. A footnote has been added to help cl arify this in Table 1 for both the 868 FCCU and 1232 FCCU, which also has throughput lim its 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.” Howe ver, 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 Titl e V operating permit (No. V95-038) does not list AMR V Section V as an appli cable 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 an d boilers as fuel. The Girard Point marine loading is cont rolled by a thermal oxidizer. Thermal oxidizers/vapor combustion is the most stringent control opt ion 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 loadi ng. This regulation is CTG RACT for the

source.12 9. AMS has not provided potential VOC em issions from the refinery cooling towers nor sufficiently evaluated av ailable 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 we re calculated using AP-42 emission factors
and the circulation rate of the unit. AMS has provided th e 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 NO
x emissions rates as RACT for various heaters and boilers in terms of pounds per mill ion 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 st ringency. 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 – Fr ankford Plant (Formerly S unoco Chemical – Frankford Plant)
1. In short, EPA believes AMS has not submitte d 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 NO
x emissions reduction, AMS must ensure that the pr oposed emissions limitations and fuel restrictions are practic ally enforceable.

AMS is proposing revisions to the RACT Plan Approval to rem ove the ability of
Boilers 1 and 2 to burn No. 6 fuel oil, except “if ther e 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 perf ormance testing, as required).”

AMS should clarify the following: How ar e supply losses expected to affect the boilers’ operation? Why should AMS a llow the burning of oil during stack testing programs when No.6 fuel oil is almost completely excluded? How would this testing result in NO
x emissions that are repr esentative of the boilers’ operations when burning natural gas and phenol?

For this condition to be practically enfo rceable, 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 w ith this requirement, EPA also believes the facility should be requir ed to record and timely notify AMS when these events

occur.13 AMS is proposing to establish a fuel re striction based on annual heat input: “Honeywell shall operate Boiler 1 and Bo iler 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 incons istent 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 doe s not establish spec ific heat input limits for each of the fuels, but a comb ined 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 rest riction is provided as a re lative limit, in terms of percentage, and not absolute limits. To ease practical enforceability of the proposed limits, EPA recommends to establis h absolute heat input limits, in terms of BTU, and not relative limits, in terms of percentages or fractions.

The proposed heat input restri ction is inconsiste nt 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 natu ral gas is not available. AMS should
establish fuel restrictions for each of th e possible operating scenarios. EPA also believes it is appropria te to establish a NO
x 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 ther e was not a sufficient supply of waste phenol residue at the time. This would cause the ope ration of the plant to be severely curtailed or ultimately shut down.

The condition allowing No. 6 oil burning duri ng stack tests was carried over from the
Second Amendment to a Consent Decree betw een EPA, several states, the City of Philadelphia, and Sunoco, Inc. (Civil Ac tion No.05-02866). This allows for better verification of CEMS performance during Rela tive Accuracy Test Audits (RATAs) and better combustion tuning due to a larger range of emissions. Better CEMS performance improves the monitoring of emissions at a ll 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 do n’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 natura l 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-hou r RACT requirement of 51% or greater phenol waste. Revised calculations of poten tial NOx emissions show that removing this condition does not increase pot ential NOx emissions on an annua l 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 Pl an Approval, Boilers 1 and 2 are also subject to the following restrictions: A NO
x 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 th e 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 NO
x 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 NO
x 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 c ontrol emissions from the boilers when burning phenol and natural gas. EPA recommends AMS establish a NO
x 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 con tinues to be appropr iate to represent
RACT.

Response: The CEMS data was an example fr om 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 o il, 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.” Fo r the proposed RACT limitations to be practicably enforceable, the releva nt testing, monitori ng, 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 NO
x 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 adde d to the RACT plan approval and supporting
documentation.

5. AMS includes a cost-effectiveness analys is for LNB. Boiler 3 is already required as RACT to maintain and opera te 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 NO
x burner (ULNB). AMS should explain th e difference between LNB and ULNB with respect technical op eration and expected cont rol efficiency; AMS should further explain whether a complete remova l of LNB and installation of the ULNB is required or merely a simple ‘upgrad e’ 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) esti mated for Boiler 3 is based on a 15 % of interest (i) and 10 years of useful life (n). Please ju stify 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 bo iler 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 fo r estimating emissions of ammonia (NH 3 ) necessary for the selec tive catalytic reduction (S CR) systems is incorrect. Thus, the ammonia costs estimate for SCR provided on page 42 is also incorrect.

Emissions of NO
x from combustion of fossil fuels are primarily in the form of nitrogen oxide (NO), rather than in the form of nitrogen dioxide (NO 2 ). Thus, the amount of ammonia needed should be estimated based on the reduction of NO,
rather than of NO 2 . The reduction of NO takes place when ammonia and oxygen (O 2 ) react with the NO, to produce nitrogen (N 2 ) and water vapor (H 2 O), by the following stoichiometric chemical reaction:16 2 NH 3 + 1⁄2 O 2 + 2 NO  2N 2 + 3H 2 O.

For more details, see page 2-5 of EP A’s January 2002 Air Pollution Control Cost Manual, Sixth Editi on, (EPA/452/B-02-001).

AMS provides the following methodology to estimate the annual cost of
ammonia:

Ammonia	Cost ൌ	ቆ 17

46 ∗ 4	moles	of	NH ଷ 2	moles	of	NO ଶ ∗ 1.05 ∗ NO ୶ emissions ∗ $410

ton
∗ 5	years ൰

Where NOx emissions are in tons per year.

First, AMS should correct the estima ted cost for ammonia, based on the
stoichiometric ratio of th e reduction of NO and molecular weight of NO, instead
of NO 2 . Second, because AMS uses potential annual NO
x 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 year s of operation, and the annual cost is
needed.

Additionally on page 42, AMS added a comm ent 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 estima tion of the total capital investment (TCI) costs of the cont rols evaluated for Boiler 3. AMS refers
to “the 2006 Best Available Contro l 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 wa s used because it is similar to RACT analysis and it is more recent.” AMS should include the referenced Best Available Control Technology (BACT) anal ysis, or at least provide a more substantive description of the BACT determination. Additionally, AMS should clearly identify, for each control evalua ted, whether vendor cost estimates or industry data were used in estimating TCI.

Response: The supporting documentati on should have said that the TCI comes from the
2006 Best Available Retrofit Technology (BART) s ubmittal. This has been corrected.17 As part of this submittal, th e facility contacted vendors to get cost es timates for various control options. This ha s been clarified in th e supporting documentation.

PaperWorks Industry (Forme rly Jefferson Smurfit Corp.)

1. In proposing revisions to the existing RA CT conditions in the SIP in accordance with CAA 110(l), AMS does not properly describe in the technical memorandum the existing RACT requirements approve d in the SIP under the 1-hour ozone standard for Paperworks Industry (Formerly Je fferson Smurfit Corp.).

At the time of the 1-hour RACT de termination, 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 oi l, and natural gas; for controlling NO
x emissions each boiler is requi red to operate a LNB when combusting coal and LNB with overfire when combusting No. 6 fuel oil and natural gas. Additionally, the combined NO
x emissions from the boilers were limited to the following emissions rate s: 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 docume ntation to delineate the listed requirements more clearly.

2. In evaluating RACT for Boiler 1, AMS doe s not accurately describe that the NO
x 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 b een 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 document ation 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 abil ity 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 Boile r 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 f acility is no longer
allowed to burn coal in Boiler 1 and that Bo iler 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. Although18 not supported in the memorandum, AMS is pr oposing to revise various conditions of the RACT Plan Approval relevant to these emissions sources: (1) To remove the ability of Boiler 1 to bur n coal and the applicable NO
x emission limits and (2) to remove all requirements of the reti red 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 co al and the associated emission limit from the revised RACT plan approval a nd supporting documentation. The retired
sources have been noted retired in the s upporting 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 st ates that “Boiler #1 is allowed to burn No. 6 fuel oil and natural gas, t hough the facility has been burning natural gas for the past five years.” Based on th is statement, EPA believes that there are two additional reasonably available c ontrol measures that would achieve significant additional NO
x 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 pe r 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 Boile rs 3 and 4 are inc onsistent 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 modificati on is in the public comment period and has not been issued yet.

6. Please, clearly describe all the applicable NO
x 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 th is plan approval, each boiler has LNB with FGR, can burn natura l 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 pe r rolling 12-month pe riod. Please note19 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 fo r Boilers 3 and 4 are inconsistent throughout the memorandum and the revi sed 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 Augus t 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 tech nical memorandum and/or the RACT Plan approval to be consistent with any pr oposed 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 bo ilers were permitted to burn No. 6 oil in the cited plan approval, but were never able to operate properly whil e burning this fuel. As noted in the response to Comment #6, the ab ility 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 a pproved in the SIP as RACT under the 1-
hour ozone standard.

Response: AMS has made this change.

2. The provided citation of the Federal Regi ster notice containing EPA’s approval of 1-hour RACT for the facility is incorrect . The citation to th e Federal Register
should be 66 FR 54691.

Response: AMS has made this change.

3. AMS proposed as RACT for Boiler 1 the existing RACT NO
x 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 NO
x 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 safe ty, the boiler cannot achieve lower limits under the existing technology.20 Temple University- Health Sciences Campus

1. As part of this proposed submission, AM S 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 NO
x requirements not approved by EPA for in clusion 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 th e 1-hour RACT Plan Approval) as case-by-case RACT for Temple University – Health Campus (Temple – Health). On April 26, 2008, AMS issued modificati ons to Plan Approval 05198 with the purpose of replacing the RACT requirement s for Boilers 1, 2, and 3 at Temple Health. Specifically, the modified Plan Approval 05198 required physical
modifications to Boilers 1 and 3 to re place 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 equivale nt to those than should have been achieved with implementation of FGR.

The modified Plan Approval 05198 requires the following NO
x 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 oi l and N is the percent nitrogen in the fuel oil; for N less than 0.25, the NO
x emissions are limited to 0.25 lbs/MMBTU; and (2) when burning natural gas, 0.067 lb s/MMBTU. The plan approval also
included a combined NO
x 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 NO
x RACT requirements of the 1-hour RACT Plan Approval con tinue 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 form ula in Plan Approval No. 05198 and inputting21 the historical highest No. 6 oil nitrogen c ontent of 0.57% and a standard BTU value of 150,000 BTU/gal for No. 6 oil. It has also been determined that thes e 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 RA CT 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 goa ls, in accordance with sect ion 110(l) of the CAA. Accordingly, AMS should explain how the proposed SIP revision that is modifying existing SIP-approved RACT cont rol measures does not interfere with attainment of the applicable ozone N AAQS, including both 1- hour ozone standard and the 1997 8-hour ozone standard, and any applicable reasonable further progress requirements. In evaluatin g whether a given SIP revision would
interfere with attainment or maintenan ce, as required by CAA section 110(l), EPA generally considers whether the SIP revisi on will allow for an increase in actual
emissions into the air over what is al lowed 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 demonstr ate that the proposed revision provides equivalent or additional emissions re ductions, in accordance with CAA section 110(l). EPA finds that the emissions dem onstration provided is technically
incorrect for a number of reasons.

EPA finds that the emissions factors used for estimating NO
x 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
NO
x 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 estima ting the emissions from the proposed requirements, AMS uses an emissions factor for No. 6 fuel oil that is based on the
NO
x limit Plan Approval 05198 as revised on April 26, 2008. AMS is not proposing this emissions limit as RACT; th erefore, 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 – Octobe r 31), each boiler shall burn natural gas as the primary fuel. Each boiler may onl y burn No. 6 fuel oil during periods of gas curtailment or gas supply interru ption.” 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 emi ssions 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 inco rrect. If proposing this rest riction for burning No. 622 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 emissi ons under the proposed RACT do not exceed those in the existing 1-hour RACT. AMS ha s provided justification for requiring natural gas as primary fuel during the ozone seas on as RACT, including showing that these boilers have burned natural gas almost exclusively in recent years.

4. EPA believes that the justification provi ded 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 justificati on. 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 subj ect to this regulation. AMS has identified each of the boilers as an emissions source, th us RACT should be evaluated for each
boiler. AMS estimated cost-effectiven ess for controlling the combined NO
x emissions from Boilers 1, 2, and 3, thus, EPA finds this analysis to be inconsistent with Pennsylvania’s source-sp ecific RACT requirements.

Consistently, in evaluating cost-effectiv eness 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 NO
x 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 docume ntation 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 ag rees that fuel switching may result in significant NO
x emissions reductions. In evaluating fuel switching as RACT for Boilers 1, 2, and 3, AMS should consider th e cost of retrofit ting or replacing the existing burners and any incremental cost s 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 th an 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 burner s to accommodate the combustion of No.
2 fuel oil.

Response: The cost of retrofitting or replacing th e burners is high and would increase the cost per ton controlled, which is cu rrently $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 uninte rrupted services to a healthcare facility. However, EPA finds that it is reasonable fo r 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 NO
x 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 th e events of natural gas curtailment. However, AMS does not provide any justifi cation to support this control option as RACT. In addition, AMS has not pr operly evaluated any other possible restrictions in burning No. 6 oil in determining RACT.

Response: AMS has provided justification for re quiring 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 dur ing cold weather and the negligible risk of exc eeding 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 facili ty when intending
to list the emission sources for this facil ity. Please clarify whether this is an editorial error and, if so, ma ke 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 regu lations 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 de tection 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 in correctly 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 collector s as the facility’s control devices related to VOC emissions. Baghouses a nd 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 su bmitted separate RACT determinations
for two facilities in Philad elphia identified as Cardone Industries, one facility on Rising Sun Avenue (PLID – 3887) and the s econd facility on Chew Street (PLID 2237). Please clarify whether the techni cal memorandum submitted is intended to
address RACT for either one of these fac ilities, or both. This should be clearly explained in the memorandum. If the me morandum 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 Car done 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 thei r close proximity and interrelatedness. The other three plants we re previously minor sources of VOC and NOx and not applicable to RACT.

The Chew Street facility ha d certain operational requirement s for its degreasers under 1- hour RACT. This requirement is being re placed by the more stringent 25 Pa Code Section 129.63(a), which has similar requirement s, 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 presumptiv e RACT regulations.

2. The memorandum and the proposed revisi ons to the RACT Plan Approval are inconsistent. AMS is proposing revisi ons to the SIP-approved RACT Plan Approval for the Rising Sun Avenue facili ty, 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 addi tive 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 a pplies 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 appli cable 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 (For merly 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 typograp hical 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 l eaks, for which case-by-case RACT requirements were established. The RA CT Plan Approval included the following conditions: Condition 2E: “The implementation of a qua rterly leak detection and repair program on all pum ps, valves and flange s containing VOC;” and Condition 5A: “GATX [Kinder Morgan] shall monitor all valv es, pumps, and flanges quarterly for visual leaks. GATX shall also monitor va lves, 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, connec tions, joints, fittings or other process equipment components not involving movi ng parts,” as well as VOC emissions from “leaking valves, pumps, compressors, safety pressure relie f devices or other26 process equipment components involving m oving parts.” The regulation prohibits VOC emissions from any of these leaki ng 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 requir ements for fugitive emissions. Please clarify.

Although both requirements are similar, EP A 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 SI P-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 greate r. Please explain how removing this requirement relates to AMS intended clar ification of the c ondition only applying
to the control of VOC emissions. AMS mu st also demonstrate that the proposed
SIP revision will not allow for an increas e in actual emissions into the air over what is allowed under the existing EPA-appr oved SIP, consistent with the section 110(l) of the CAA.

Response: The facility is applicable to the CT G 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 progr am is not a specific requirement for this facility in AMR V, Section XIII, it must rema in as a RACT requirement for the facility. Both are applicable to th e 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 Th ermal Oxidation Unit and 25 Pa Code
Section 129.93 has been deleted as it is cove red in the presumptive RACT section of the supporting documentation and does not direct ly apply to loading operations. The
reference to 25 Pa Code Secti on 129.56(a) has been removed.27 6. The tank truck/tank car load ing operations in Kinder Morgan are subject to the VOC source-specific requirements of th e RACT Plan Approval, which were approved in the SIP as RACT under the 1-hour ozone standard. AMS is proposing various revisions to the appli cable SIP requirements to allow more flexibility to the facility in operating th e 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 demonstr ation provided to sa tisfy 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 load ing position of the loading racks.

Second, AMS does not provide sufficient in formation 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 c ontrol of the thermal oxidize r, assumptions on hours of operations, and any other relevant assu mptions. Additionally, emissions are provided for the “controlled” and the “unc ontrolled” racks, where they should have been provided for each identified em ission source, in this case, for each loading rack.

Response: AMS has revised the documentation to clarify the calculati ons 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 th at 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 demonstrat ion, AMS interprets the existing RACT requirements to allow uncontrolled loadi ng of liquids with RVP under 4 psi on loading racks connected to the thermal oxi dizer. In support of this interpretation, please explain why the requirement s 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 Approva l, 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 load ing at these racks must be controlled. T he requirements of 25 Pa Code 129.59 require gasoli ne 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 dis tillate having a Reid vapor pressure (RVP) of 4 psi or greater and which is a liqui d at standard pressure and temperature, so of 25 Pa Code 129.59 does not re quire 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 loadi ng positions are connected to the NAO Thermal Oxidizer since these positions do no t load materials that are required to have control (e.g. benzene NE SHAP) or load materials w ith a vapor pressure great than 4 psia RVP.” This statement is inconsistent with the SIP approved RACT requirements. Condition 1A(1) of the RA CT 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 pos itions at these racks are not physically
connected to the control un it, how is the facility ab le 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. Conditi on 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 ps i or greater require controls. Non-VOC materials would not be required to have c ontrols 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 followi ng 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 no t operating the thermal oxidizer only when loading organics with RVP less than 4.0 psi. EPA recommends the condition should read as follows: “Organic liqui ds with a Reid Va por 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 gram s) 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 m odification to Condition 2D. AMS must continue to identify those racks that are not connected to a co ntrol unit, and must continue to restrict the loading of liq uids with RVP less than 4 RVP to those racks, in order for these racks to no t 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 wh ich are uncontrolled shall be limited to processing organic liquid with vapor pre ssure lower than 429 RVP.”

EPA recommends to further revise the proposed Condition 3A(1), for additional clarification, as follows: “Loading of organic liquids w ith RVP > 4 psi at all tank car/truck loading positions at the facility shall be limite d 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 rack s is technically incorrect for various

reasons.

First, AMS provides two analyses for uncont rolled loading of r acks, 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 loadi ng is limited to organic liquids with less than 4.0 psi of RVP. AMS is also propos ing to maintain the loading of organic liquids with less than 4.0 ps i of RVP on racks that are not physically connected to
the thermal oxidizer. AMS has evalua ted 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 de termining RACT. In evaluating RACT, AMS should evaluate the feasibility of the ex isting controls (the NAO thermal oxidizer and/or the applicable emissions limits ) and additional reas onably available
controls.

Second, AMS has evaluated RACT per load ing 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 ex isting and proposed RACT conditions, AMS has consistently defined the emissions sour ce 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 th is is a reasonable control option for multiple loading racks.

Baseline emissions used in the cost-effec tiveness analyses should be based on the existing Federally-enforceable emissions rest rictions that apply to the particular emissions source. Consequently, AMS cannot rely on a limit that is being30 proposed as RACT. Since there is no a pplicable Federally-enforceable limitation for each of the loading racks, the ba seline emissions should be based on the unrestricted maximum capacity of each rack.

AMS provides different and in consistent 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. Thes e corrections include accounting for physical limitations to the loading process which we re previously not addressed and which drastically reduce potential emissions.

Any loading position that is controlled is conne cted to the thermal oxidizer individually. It is appropriate to analyze these controls on a loading position basi s instead of a loading
rack basis.

As mentioned above, some of the potential emission calculations were corrected. The control requirements of 25 PA Code S ection 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 a pplicable requirement. An emi ssion 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 ta nk car/truck loading VOC emissions at the facility must be less than 57.0 lbs/hr (based on 25 PA C ode 129.59(a) and the thermal oxidizer capacity) and each unc ontrolled 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 em issions limit for each of the loading positions of the loading racks. To ease practicable enforceability, EPA recommends any emissions limit to be appl ied on a short-term averaging basis. Also, AMS should establish limits on the emission sources themselves, which has been consistently identified as the lo ading 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 ozone31 standard, or existing regu lations 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 es tablished 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 reco rd 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 ap pears this was not included in the SIP because the only case-by-cas e 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 Sh ipyard RACT plan approval related to the
shutdown of these boilers. This has been cl arified in the supporti ng documentation.

Grays Ferry Cogeneration Partnership

1. The proposed NO
x 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 requi rements 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 pr ovisions that create exemptions such that the excess emissions during start up, shutdown, malfunction, or emergencies are not violations of the applicable emi ssion limitations are inconsistent with the fundamental requirements of the CAA with respect to emission limitations in SIPs
and interfere with citizen suit enforcemen t 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 th em with existing permit limits of NOx limits of 255
lbs/hr for the Turbine and 298.9 lbs/hr fo r the Turbine and Heat Recovery Steam Generator (HRSG) to RACT, which apply at all times.

2. The methodology provided in page 148 fo r estimating emissions of ammonia necessary for the SCR and the selectiv e non-catalytic reducti on (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 NO
x 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 to ns per rolling 12-month period.

Based on heat input capacity, continuous operation of the boilers, and the NO
x 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 emi ssions 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 dur ing 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 fo r estimating emissions of ammonia necessary for the SCR and the SNCR syst ems 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 comme nt # 8 for Honeywe ll International –
Frankford Plant.

Response: AMS has made this correction.

Veolia Energy Efficiency33 1. The methodology provided in page 167 fo r 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 operati on; 0.08 lbs/MMBTU while burning oil during normal operation; 0.036 lbs/MMBT U while burning gas during startup, shutdown, or malfunction; and 0.08 lbs/MMB TU while burning oil during startup, shutdown, or malfunction. The boilers ha ve a combined NOx emission limit of 52.31 tons per rolling 12-month period. AM S’ 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 re quirements 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 vi olations, whether or not the state elects
to exercise its enforcement discretion. SI P provisions that create exemptions such that the excess emissions during start up, shutdown, malfunction, or emergencies are not violations of the applicable emi ssion limitations are inconsistent with the fundamental requirements of the CAA with respect to emission limitations in SIPs
and interfere with citizen suit enforcemen t of CAA violations. EPA believes that the inclusion of such an exemption is a substantial inadequacy and renders any proposed provision for a SIP impermissi ble. 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/malf unction when the boilers combust oil; however, presently, it appears the rate is id entical to the rate for normal state for combustion of oil. If AMS adjusts that ra te for oil to a higher limit during startup, shutdown or malfunction (SSM) (if it belie ves 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 correct s the rate for periods of SSM for the boilers while combusting o il 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 ra te 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 Emi ssions 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/Malfunc tion provisions in state SIPs. See 78 FR 12460 (February 22, 2013). However, in Section III.A of the 1999 Memorandum, EPA recommended very specif ic criteria that air agencies should consider including as part of any SIP pr ovision that was intended to apply to sources during startup and s hutdown 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 requirem ents applicable to the source during startup and shutdown should be narrowl y tailored and take into account
considerations such as th e technological limitations of the specific source category and the control technology that is feasible during startup and shutdown.

EPA continues to recommend the seven sp ecific criteria enumerated in Section
III.A of the Attachment to the 1999 SSM Gu idance as appropriate considerations for SIP provisions that a pply to startup and shutdown. AMS has so far not explained how these criteria apply to th e 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 shoul d analyze the potential worstcase emissions that could occur during star tup 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, th e facility must be operated in a manner consistent with good practice for minimizing emissions, and the source must have used best efforts regarding planning, desi gn, and operating procedures to meet the otherwise applicable emission limitation; and (7) the owner or operator's actions during startup and shutdown periods mu st 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 E fficiency for startup and shutdown in
accordance with the criteria in the 1 999 Memorandum. EPA believes that the
inclusion of these alternative limitations and automatic exemptions, which do not35 comply with the requirements of the CAA, render these provisions for Veolia Energy Efficiency impermissi ble for RACT and impermi ssible 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 t on 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. Ne w Jersey cost of NOx cont rol per ton of NOx removal
in our 1009 RACT rules was considerab ly higher, approaching $50,000 per ton for peaking units. Since peaking units (a lso 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 controll ed. Use of an annualized $/ton metric
fails to account for the cost effectivene ss 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 th an a base load unit that operates 300 days per year.

Response: AMS must follow PADEP RACT regulati ons 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 ta ble are based on a 30 day rolling average compliance period for CEMS. A 24 hour co mpliance period is more appropriate
because it will ensure low NOx emissions on hi gh 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 emissi on limits for all its utility
boilers with NOx continuous emission monitors.

As can be seen in Table 1, all four boile rs 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 ex ceed 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 recomme nd that Air Management Services lower the proposed RACT emission limits for these utility boilers to be no less stringent37 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 fo llow 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 Fe rry Cogeneration Boiler 25 under these, AMS has determined the proposed NOx emission limits as RACT.

Evaluating potential new NOx control techno logies for each Veolia boiler under case-bycase RACT, no additional NOx controls were determined both technically feasible and economically reasonable. Sc huylkill 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 te st and, for Boiler #26, Continuous Emission Monitoring System (CEMS) data for the cas e-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 to

0.2 lb./MMBTU)

Boiler #2 283 MMBTU/hr #6(Primary); #2(ignition) 0.50 lb/MMBTU 2.0 lb/MWhr (equivalent to

0.2 lb./MMBTU)

Boiler #3 335 MMBTU/hr #6(Primary); #2(ignition) 0.50 lb/MMBTU 2.0 lb/MWhr (equivalent to

0.2 lb./MMBTU)

Boiler #4 335 MMBTU/hr #6(Primary); #2(ignition) 0.50 lb/MMBTU 2.0 lb/MWhr (equivalent to

0.2 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/MMBTU 30 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 Boilers38 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 roll ing 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 lim its for industrial boilers.

The proposed NOx limits for the four i ndustrial 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 natu ral gas to 0.35 lb/MMBTU for No. 6 fuel oil. New Jersey’s RACT limits ar e 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 recomme nd 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 fo llow 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/MMBTU 30 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 Boilers40 State of Delaware Department of Natural Resources & Environmental Control (DEDNREC)

Comment 1: Technological feasibility determina tion: The EPA has defined RACT as the lowest emission limitation that a partic ular source is capable of meeting by the application of control technol ogy that a particular source is capable of meeting by the application of control te chnology 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 Pl ant. For boiler 1 and 2, the proposal indicates that Selective Non-Catalytic Re duction (SNCR) is not a feasible NOx control technology because, “load and NOx Concentrati on variations with the boilers makes placement of the catalyst difficult and make s it difficult to maintain a proper ammonia injection rate”. SN CR technology does not include catalyst, and can be engineered and in stall 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 depe ndent upon the reagent injector location and temperature to achieve proper reagent /flue gas mixing fo r 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 cont rols cannot be achieved effectively.

 Honeywell International, Frankford Plant. For Boiler 3, the proposal indicates that water/steam injection is technically in feasible, 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 feas ible for this installation. Delaware
recommends that AMS conduct additional t echnical evaluation for this control.

Response: Steam or water injection is used to reduce the peak flame temperature, therefore reducing the formati on 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 resi dence 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 efficiency 2,3

.41  Temple University – Health Science Campus. For boilers 1, 2, and 3, the proposal discusses the capability and abil ity of ultra low NOx burners (ULNBs) to operate in a retrofit situa tion. 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 installati ons. While there may be certain ULNBs designed specifically for this type of app lication, ULNB are av ailable in service for multiple firing configurations, including wall fired installations, and are also
available from some manufacturers for na tural draft, forced draft, and balance draft application. The Flue Gas Recircula tion 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/sh ape/dynamic of the development flame and not a traditional FGR system. Further, use of preheated air (maintaining th e 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 furthe r 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 replacemen t 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 (w ater 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 injec tion is not technologically f easible since the primary contributor to NOx emissions during oil fired combustion is fuel NOx (as opposed to thermal NOx) and that there is an e fficiency loss associated with the water injection. Water injection is a proven NOx reduction technology for oil fired
boilers that is in commercial use. Delawa re does not agree that water injection is technologically infeasible for these boilers. Delaware recommends further analysis, and that any additional operati ng costs associated with efficiency loss due to water injection be assessed in the cost effectiveness evaluation.

Response: The boiler fire box size does not prov ide sufficient minimum residence time for water injection at the combustion te mperature for acceptable steam generation.42 Furthermore, each boiler is equipped with LNB and FGR that Nitrogen Oxides (NO
x ) 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 (NO
x ) 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 technol ogy that a particular source is capable of meeting by the application of control technol ogy that is reasonably availa ble considering technological
and economic feasib ility (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 re quired in the SIPs of other states, particularly

states within the same nonattainme nt area boundaries, should not be discarded as economically unreasonable based on this low cost threshold. Delaware recommends that AMS revisit the following dete rminations, as additional emission controls appear economically reasonable.

• Philadelphia Energy Soluti ons Refining and Marketing LLC (PES). ULNB and

SNCR NOx control on Unit 860-2H 2, 860-2H4, 864-PHl , 137 F-1, and 137 F-2 appear economically reasonable at between $3104 and $4499/ton.

• Honeywell International, Frankford Pl ant. For the boiler 3, SCR appears43 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 Scien ces 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 regulati ons 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 fire d units in the proposal , in all cases, was based on tons per year estimates. In Delawa re's experience diesel-fired units are typically operated on a daily or hourly ba sis, 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 repr esentative of operation

with NOx emission controls such as water injection, ULNBs, etc.

Delaware suggests that AMS address daily emissions from diesel and combustion44 turbine units by adopting requireme nts 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 regulati ons 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 inte rest rate and cont rol equipment life,

which are major inputs to an economic analys is, are extremely variable throughout

the AMS proposal. Many appear unrealisticall y 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 Commi ssion (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 si gnificantly lo wer, ranging

from about 5% down to about 2% over th e last few years, reflecting the low Treasury rates and relatively low economi c growth. A 20 year life is reasonable given that the calculations include operating and maintenance costs (including catalyst replacement for SCR) that are antici pated to be needed to keep the control equipment functioning properly over the lif e of the control equipment. Delaware

recommends that AMS determine economic r easonableness using an interest rate of 6% and a control equipm ent life of 20 years.

Response: The interest rate and life usage depe nds on the company and the particular unit. The cost of raising f unds 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 atta ched 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 pl an 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 appr oval is expired and was inco rporated into the Title V operating permit.

Response: This was an error and as been re moved. 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 facilit y. Please remove references of GATX from the permit.

Response: This has been corrected.

3. Condition A.1 and condition 2.C. Do the cont rolled 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 c ontrolled loading positions?

Response: The specific controlled racks must be listed.

4. Condition 2.F. Although this was in th e original RACT Plan, Kinder Morgan requests Air Management Service provide the basis for this requirement.

Response: The RACT requirements for marine lo ading in the original RACT plan approval were approved based on it not pro cessing petroleum dist illate with vapor pressures greater than 4.0 RVP.

5. Condition 5.A. This condition requires Ki nder Morgan to implement and comply with the conditions of this permit no la ter 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 origin al 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 re quest more specific listing of the

records and what would be considered sufficient data by AMS for Kinder Morgan to ensure compliance. As is, these condi tions leave too much to interpretation of the records and types of da ta 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 th is condition be re moved since it is unrelated to RACT requirements. Kinde r 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 reque sts this condition be removed. Kinder Morgan does not have the authority to modify the State Implementation Plan. Kinder Morgan asserts this is the respons ibility of Air Management Services and

thus would never be able to cer tify 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 peri od and do not require a response. See e.g. 25 Pa. Code § 127.47(b) (no response required for prot ests filed outside of comment period for proposed plan approval). Nonetheless, AMS w ill 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 technol ogy” 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 AM S, 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 ex isting multi-fuel boilers during ozone season is a valid control technology that can be evalua ted and required as RACT for air pollution sources pursuant to the Fede ral 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
NO
x and fuel combustion techniques for the control of NO
x . ” Id. ( emphasis added ).47 Requiring the use of a particular fuel (e.g. natural gas) at part icular 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 su ch fuel without any physical changes. See
Id. EPA recognizes that requiri ng 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 Availabl e 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) Ques tions 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) Bo ilers (March 1994, EPA Office of Air and Radiation – Emissions Standards Division) (dis cussing 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 da ta provided by Temple and determined that requiring use of natural gas during oz one season to be cost-effective. From 2011 through 2013, Temple obtained and burned natu ral gas in the three, multi-fuel fired boilers in question over 99% perc ent 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 oc cur, the use of natu ral 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 th e 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 oz one 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 Scien ce 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 pr oposal 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 noti ce or opportunity to comment on the proposed maximum combined heat input li mit of 500,000 MMBtu/year for boilers No. 1-48 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 in cluded 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.