# Pennsylvania Department of Environmental Protection

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## Secretary

William C. Early Acting Regional Administrator Rachel Carson State Office Building P.O. Box 2063 Harrisburg, PA 17105-2063 May 5, 2009



## U.S. Environmental Protection Agency, Region III 1650 Arch Street (Mail Code: 3RAOO) Philadelphia, PA 19103-2029

Dear Mr. Early: 717-787-2814

The Department of Environmental Protection (DEP) is withdrawing a State Implementation Plan (SIP) revision pertaining to the certification that the requirements for Reasonably Available Control Technology (RACT) for the Eight-Hour Ozone National Ambient Air Quality Standard (NAAQS) have been met in Allegheny County. The U.S. Environmental Protection Agency (EPA) received the SIP revision on June 20, 2007.

Concurrently, DEP is submitting a revised version of the demonstration that RACT is in place for the Eight-Hour Ozone NAAQS on subject sources in Allegheny County for approval as

a revision to Allegheny County's portion of the SIP. The revision is identified as revision 60 for the Allegheny County Health Department's (ACHD) internal tracking.

The public comment period for this SIP revision took place from January 19, 2009, through February 18,2009. A public hearing was held on February 18,2009. No comments

were received. The Allegheny County Board of Health approved the SIP revision at its meeting

on March 4, 2009.

Thank you for your attention to this matter. Should you have any questions concerning this SIP revision, please contact Joyce E. Epps, Director of Air Quality, by e-mail at jeepps@state.pa.us or by telephone at 717-787-9702. You may also contact Mr. James E. Thompson, Acting Manager, Air Quality Program, ACHD, by e-mail at jthompson@achd.net or by telephone at 412-578-7963.

Enclosure

An Equal Opportunity Employer 

## Sincerely,

# ~~~ John Hanger Secretary

www.dep.state.pa.us Printed on Recycled Paper@

# Alleg}feny Otnunty i!;ealt}f ilepartment

DIRECTOR

Bruce W. Dixon, M

. D

.



### Ms

. Joyce Epps Department of Environmental Protection Bureau of Air Quality Rachel Carson Building 400 Market Street

, P

. 0. 

### Box 8468 Harrisburg, PA 17105-8468

Dear Ms. Epps: 

### AIR QUALITY PROGRAM
301 39 1 h Street- Bldg. #7 Pittsburgh, PA 15201-1891

Phone: (412) 578-8115

Fax : (412) 578-8144



### March 6, 2009 BOARD OF HEALTH

Paul M. King, Esq., Q

. E. P.
Cha i r Lee Harr i son, M.D.
Vice Cha i r



### AI M

. Ahmed, P.E

. Rev. R i cky 

### V

. Burgess
D onaldS

. Burke

, M

. D.
Ho n. Joan Cleary, R.N

.

James M

. F l ynn, Jr

. Lidia 

### C. Turzai, M

. D.
W i lliam Youngblood



### The Allegheny County Health Depa11ment (ACHD) requests that the Pennsylvania Department of Environmental Protection withdraw the submittal of a revision to the Pennsylvania State Implementation Plan (SIP) made on behalf of ACHD and received by EPA on June 20, 2007. This revision concerned certification that Allegheny County's portion ofthe Pennsylvania SIP for Reasonably Available Control Technology (RACT) for the 8-Hour Ozone National Ambient Air Quality Standard requirements are met. It 

### had been transmitted to PA DEP by our letter dated Ma y 30, 2007.

Concurrently, ACHD is herewith submitting to PA DEP a revised version ofthe previously described SIP submittal in the form of the enclosed two paper copies and a disk containing a pdf version of this revision to Allegheny County's portion ofthe Pennsylvania State Implementation Plan demonstrating that Reasonably Available Control Technology (RACT) is in place for 8-Hour Ozone on subject sources i n Allegheny Cou n ty. As before, this revision is being tracked as our internal tracking number Revision 60.

The changes made to the 2007 submittal include the removal of the reference to " Dry Cleaning Facilities " covered by Article XXI Section 21 05.18 from Table 1; the add it ion to Item 3, "Negative Declaration List, " of a reference to the related Control Techniques Guideline 

### Control of Volatile Organic Emissions from Large Petroleum Drv Cleaners

, EPA-450 /

3-82-009; and the addition of Appendix A which includes the January 8, 2009 Negative Declaration Letter for Large Petroleum Dry Cleaners previously sent to U.S. EPA.

The public comment period for this SIP Revision took place from January 19, 2009, through February 18, 2009 when the public hearing was held. There were no comments during the public commen t period. The County Board of Health approved the SIP revision at their meeting on March 4, 2009.

25

- 093008

### Allegheny County Health Department- Air Quality Program 8-Hr Ozone RACT Plan SIP submittal March 6, 2009 Page 2 of2

We request that the Pennsylvania Department of Environmental Protection request withdrawal fi·om U.S

. EPA of the submittal of a revision to the Pennsylvania State Implementation Plan (SIP) made on behalf of ACHD and received by EPA on June 20, 2007. We also request that P A DEP approve the current revision as represented by the enclosed materials and forwa r d the hard copies and disk to the U.S

. EPA Region 

### ill with a recommendation f o r approval.

Copies of this submittal have also been sent to your Region V Pittsburgh Office for their information and review.

cc: Arlene Shulman, DEP Steve Hepler, DEP Enclosures Sincerely

,

# c(~,

James Thompson, Manager Air Quality Program

# All£gq£ny Qtnunty i!;£alt4 ilepartment

DIRECTOR

Bru c e W

. D ixon

, M.D.



### Ms. Judith Katz Air Protection Division 

## U.S. Environmental Protection Agency Region III (3APOO) 1650 Arch Street Philadelphia, PA 19103-2029

Dear Ms. Katz: 

### AIR QUALITY PROGRAM
301 39 1 h Street- Bldg. #7 Pittsburgh, PA 15201-1891

Phone: (412) 578-8115

Fax: (412) 578-8144



### March 6, 2009 

### BOARD OF HEALTH

P

a u l M. King, Esq

. , Q

. E.P

. Chair Lee H ar r i son, M.D

. V i c

e Chai r

AI M

. A hmed

, P.E

. Rev

. R icky V

. Burgess
Don al d S. Burke, M .D.
H on

. Joan C l eary, R .N

.

James M

. Flynn

, Jr.
Lidia 

### C. Tu r za i

, M.D

. W i lliam Youngb l ood



### This is to inform you that the Allegheny County Health Department ( ACHD ) will be requesting that the Pennsylvania Department of Environmental Protection withdraw the submittal of a revision to the Pennsylvani a State Implementation Plan (SfP) made on behalf of ACHD and rece i ved by EPA on J u ne 20

, 2007. Th i s revision concerned certification that Allegheny County ' s portion of the Pennsylvania SIP for Reasonably Available Control Technology (RACT) for the 8-Hour Ozone National Ambient Air Quality S t andard requirements are met.

Concurrent with this withdrawal request, ACHD will also be submitting to PA DEP a revis e d version (attached here for information only) of the document sent to you in June 2007

, addressing the same subject

, with sever a l changes made to it

, including the removal of the reference to "Dry Cleaning Facilitie s " covered by Article XXI Section 2105.18 from Table I

, the addition to Item 3, "Negative Declaration List," of a reference to the related Control Techniques Guideline 

### Control of Volatile Organic Emissions from Large Petrol e um Dry 

### Clea n ers, EPA-45013-82-009, and the addition of Appendix A which includes the January 8, 2009 Negative Declaration Letter for Large Petroleum Dry Cleaners previously sent to EPA.

The enclosure is a revision to Allegheny County's portion of the Penns y lvania State Imple m entation Plan demonstratin g that Reasonably Available Control Technology (RACT) is in place for 8-Hour Ozone on subject sources in Alleghen y County. As before, this revision is being tracked as our internal tracking number Revision 60.

The public comment period for this SIP Revision took place from January 19

, 2009, through February 18, 2009 when the public hearing was held

. There were no comments during the public comment period. The County Board of Health approved the SIP revision at their meeting on March 4, 2009.

25

- 093 008

### Allegheny County Health Department- Air Quality Program 8-Hr Ozone RACT Plan SIP submittal March 6, 2009 Page 2 of2

This SIP revision, in paper copy and in pdf format on a cd

, has been sent to Ms. Joyce Epps of the Pennsylvania Depa11ment of Environmental Protection (DEP) Central Office and to Mr. Mark Wayner of DEP Region V for their review and approval, with a request that the document received by EPA on June 20

, 2007 be withdrawn and the revised submittal described herein be forwarded to you with their recommendation for appro v a l.

Enclosure

# ~

James Thompson

, Manager Air Quality Program

# Alleg4.eny <ttnunty i1.ealt4 il.epartm.ent

DIRECTOR

Bruce W

. D i xon, M

. D

.



### Mr. 

### Mark Wayner Regional Air Quality Manager 

### Department of Environmental Protection Southwest Regional Office- Region V 400 Waterfront Drive Pittsburgh, PA 15222-4745

Dear Mr. 

### Wayner: 

### AIR QUALITY PROGRAM 301 39 1 h Street- Bldg. #7 Pittsburgh

, PA 15201

- 1891

Phone: (412) 578-8115

Fax : (412) 578-8144



### March 6, 2009 

### BOARD OF HEALTH

Paul M. King, 

### Esq., Q.E.P

. Cha i r Lee Harrison, M

. D

. V i ce Cha ir

AIM

. Ahmed

, P.E.
Rev

. Ricky V. Burgess
DonaldS. Burke, M.D

. Hon. Joan Cleary, R.N

.

James M. Flynn, Jr

. Lidia 

### C. Turzai, M

. D

. William Youngblood



### The Allegheny County Health Department (ACHD) requests that the Pennsylvania Department of Environmental Protection withdraw the submittal of a revision to the Pennsylvania State Implementation Plan (SIP) made on behalf of ACHD and received by EPA on June 20, 2007. This revision concerned certification that Allegheny County ' s p01tion ofthe Pennsylvania SIP for Reasonably Available Control Technology (RACT) for the 8-Hour Ozone National Ambient Air Quality Standard requirements are met. It had been transmitted to PA DEP by our letter dated May 30

, 2007

.
Concurrently, ACHD is herewith submitting to PA DEP a revised version of the previously described SIP submittal in the form of the enclosed two paper copies and a disk containing a pdf version of this revision to Allegheny County's portion of the Pennsylvania State Implementation Plan demonstrating that Reasonably Available Control Technology (RACT) is in place for 8-Hour Ozone on subject sources in Allegheny County

. As before, this revision is being tracked as our internal tracking number Revision 60.

The changes made to the 2007 submittal include the removal of the reference to "Dry Cleaning Facilities " covered by Article XXI Section 2105

. 18 from Table 1 ; the addition to Item 3

, " Negative Declaration List

, " of a reference to the related Control Techniques Guideline 

### C ontrol of Volatile Organic Emissions from Larg e P e troleum Dry 

### Cleaners, EPA-450 /

3-82-009 ; and the addition of Appendix A which include s the January 8

, 2009 Negative Declaration Letter for Large Petroleum Dry Cleaners previously sent to U

. S. EPA.

The public comment period for this SIP Revision took place from January 19, 2009, through February 18, 2009 when the public hearing was held

. There were no comments during the public comment period. The County Board of Health approved the SIP revision at their meeting on March 4, 2009.

25-0 93008

### Allegheny County Health Department

- Air Quality Program 

## 8-Hr Ozone RACT Plan SIP submittal March 6, 2009 Page 2 of2

Copies of this submittal have been sent to Ms. Joyce Epps in Harrisburg for review, along with a request that the Pennsylvania Department of Environmental Protection request withdrawal from U.S. EPA of the submittal of a revision to the Pennsylvania State Implementation Plan (SIP) made on behalf of ACHD and received by EPA on June 20, 2007, and that PA DEP approve the current revision as represented by the enclosed materials and forward it
to the U.S

. EPA Region 

### ill with a recommendation for approval.

cc: Steve Hepler, DEP Enclosure Sincer /.

n

# ~·-~,0~ James Thompson, Manager Air Quality Program

## REVISION TO ALLEGHENY COUNTY’S PORTION

of the

PENNSYLVANIA STATE IMPLEMENTATION PLAN

for the

ATTAINMENT AND MAINTENANCE

of the

NATIONAL AMBIENT AIR QUALITY STANDARDS

__________________ _____________

(Revision Tracking No. 60)

Amendment to

Reasonably Available Contro l Technology (RACT) Plans

For the

8-Hour Ozone National Ambient Air Quality Standard

# ( Revision Tracking No. 60) Table of Contents

A. Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) Revision for the 8-Hour Ozone National Ambient Air Quality Standard (NAAQS)

1. Introduction

2. Certification of VOC and NOx RACT Requirements Table 1: VOC RACT List and Cert ification under the 8-Hour Ozone NAAQS

3. Negative Declaration List

4. Certification of NO x RACT Requirements Table 2: NOx RACT List and Cert ification Under the 8-Hour Ozone NAAQS

5. Case-By-Case Evaluation Table 3: Case-By-Case 8-Hour RACT Evaluation

B. Documentation of First Pub lic Hearing and Certifications

Public Hearing Notice Proof of Publication of Hearing Notices to US EPA and PA DEP Certification of Hearing Summary of Comments and Responses

C. Documentation of Second Public Hearing and Certifications

Public Hearing Notice Proof of Publication of Hearing Notices to US EPA and PA DEP Certification of Hearing Summary of Comments and Responses

APPENDIX A. Petroleum Solvent Dr y Cleaners Negative Declaration Letters

## A.

Reasonably Available Control Technol ogy (RACT) State Implementation Plan (SIP) Revision for the 8-Hour Ozone National Ambient Air Quality Standard (NAAQS)

## Reasonably Available Control Technology ( RACT) State Implementation Plan (SIP) Revision for the 8-Hour Ozone National Ambient Air Quality Standard (NAAQS)

1. INTRODUCTION

Proposed revision to the State Implemen tation Plan (SIP) identifying Reasonably Available Control Technology (RACT) under the 8-Hour Ozone National Ambient Air Quality Standards (NAAQS).

Statutory Authority: 25 Pennsylvania Code Subpart C Article III, Chapter 133: Local Ai r Pollution Agencies

Background and Requirements: The federal Clean Air Act (CAA) of 1990 give s the states primary responsibility for achieving the National Ambient Air Qua lity Standards (NAAQS). The NAAQS are established by the U.S. Environmental Pr otection Agency (EPA) as the maximum concentrations in the atmosphere for specific air contaminants, set to protect public health and welfare. The principal mechanism at the state and local level for complying with the CAA is the State Implementation Plan (SIP). A SIP outlines the programs, actions, and commitments that a state will carry out to fulfill its responsibilit ies under the CAA. Once approved by the EPA, a SIP is a legally bi nding document under both state and federal law.

Ground level ozone, one of the principal co mponents of “smog,” is a serious air pollutant that is known to affect human health and the environment. High levels of ozone can damage the respiratory system causi ng breathing problems, throat irritation, coughing, chest pains, and increase susceptibilit y to respiratory inf ection. High levels of ozone also cause serious damage to forest s and agricultural crops, which results in economic loss to logging and farming ope rations. In June 2004, EPA designated 126 areas of the country as “non-attainment ” under the 8-hour ozone NAAQS. Among those non-attainment areas is the Pittsburgh-B eaver Valley Ozone Non-Attainment Area (NAA) located in Pennsylvania.

Ozone is generally not directly emitted to the atmosphere; rather it is formed in the atmosphere by photochemical reactions between volatile organic compounds (VOC), oxides of nitrogen (NOx), and carbon monoxide (CO) in the presence of sunlight. In order to reduce ozone concentrations in the ambient air, the CAA requires all nonattainment areas to apply controls on VOC/NOx emission sources to achieve emission reductions. CO’s role in forming ozone is relatively insignificant; therefore the CAA does not specify requirements on CO emissi on reductions regarding ozone attainment. Among effective control measures, the Reasonably Available Control Technology (RACT) controls are a major group for reducing VOC and NOX emissions from stationary sources.

## The US Environmental Protection Agency (EPA) has defined RACT as the lowest emission limitation that a particular source is capable of meeting by the application of control technology that is r easonably available consideri ng technological and economic feasibility (44 FR 53761 at 53762, September 17, 1979). Section 182 of the CAA sets forth two separate RACT requirements fo r ozone non-attainment areas. The first requirement, contained in section 182(a)(2)(A) of the CAA, and referred to as RACT fixup, requires the correction of RACT rules for which EPA identified deficiencies before the Act was amended in 1990. Allegheny County has no deficiencies to correct under this Section of the CAA. The sec ond requirement, set forth in section 182(b)(2) of the CAA, applies to moderate or worse ozone NAAs as we ll as to marginal and attainment areas in ozone transport regions (OTRs) established pursuant to section 184 of the CAA. This requires NAAs to implement RACT controls on all major VOC and NOx emission sources and on all sources and source cat egories covered by a Control Technique Guideline (CTG) issued by EPA.

Under section 183 of the CAA, EPA wa s required to issu e several guidance documents for RACT controls that would help states meet the requirements of section 182(b)(2). This requirement upon EPA include s developing (1) CTGs for controls of VOC emissions from stationary sources, a nd (2) Alternate Contro l Techniques (ACTs) for controls of VOC and NOX emissi ons from stationary sources.

The EPA issued three groups of CTG documents, establishing a “presumptive norm” for RACT for various ca tegories of VOC sour ces: Group I, issued before January 1978 including 15 CTGs; Group II, issued in 1978 including 9 CTGs; and Group III, issued in the early 1980s with 5 CTGs. Sour ces not covered by the issued CTGs are referred to as non-CTG sources. Section 182(b)(2 ) of the CAA requires states with ozone non-attainment areas classified as moderate or worse to develop RACT controls for all pre-enactment (i.e., pre-1990) CTG source categories, for all sources subject to postenactment (i.e., post-1990) CTGs, and for all non-CTG major sources in their nonattainment areas. The EPA has also issued over a dozen ACTs for various categories of VOCs and NOx sources.

In general, states meet the CAA’s RA CT requirements by imposing controls that meet the control requirements established in final CTG documents and considering the information in ACT documents to relevant VOC and NOx sources in their moderate or worse non-attainment areas.

The CAA requires that states achieve the NAAQS by specified dates, based on the severity of an area’s air qua lity problem. The entire Commonwealth of Pennsylvania is considered a ‘moderate’ ozone non-attainme nt area for the new federal 8-hour ozone standard because it is in an Ozone Transport Region, and is required by the CAA to attain the federal 8-hour ozone st andard by June 15, 2010.

## According to the EPA’s Final Rule to Implement the 8-Hour Ozone NAAQS (70 FR 71612, November 29, 2005), areas classified as moderate non-attainment or higher must submit a demonstration that their current rules fulfill 8-hour ozone RACT requirements for all CTG categories and all ma jor, non-CTG sources as a revision to their SIPs. Such demonstrations can be made w ith either a new RACT determination or a certification that previously required RACT controls re present RACT for the 8-hour ozone standard. A certification shall be accompanied by appropriate supporting information such as consideration of info rmation received during the public comment period and consideration of new data. Th ese documents supplement existing RACT guidance documents that were developed for the 1-hour standard, to demonstrate that SIPs accurately reflect RACT for the 8-hour ozone NAAQS based on current availability of technically and economically feasible controls. The RACT SIP submittal is in addition to the area’s 8-hour ozone attainment demonstr ation plan, which is also a SIP submittal.

Allegheny County Health Department ha s developed a RACT SIP revision that demonstrates as of the July 2007 SIP dead line, that: 1) it has implemented required RACT controls on all relevant stationary sources of VOC and NOx emissions; 2) with exceptions noted below, all RACT controls ha ve been approved by EPA under the 1-hour ozone NAAQS; and 3) with exceptions noted below, all RACT controls have been certified, based on EPA’s guidance and standa rds, to represent RACT control levels under the new 8-hour ozone NAAQS.

Summary: Allegheny County Health Department (A CHD) is certifying through this SIP revision that the Allegheny County portion of the Pennsylvania SIP meets the CAA RACT requirements for the 50 ton per year (tpy) non-CTG major VOC sources and for 100 tpy NOx sources, and that all CTG-covere d source categories ar e addressed at the emission thresholds set in the CTG. This cer tification is based on a combination of: 1) certification that previously adopted RACT controls in Al legheny County’s portion of the Pennsylvania SIP that were approved by EP A under the 1-hour ozone NAAQS are based on the currently available technically and econom ically feasible cont rols, and that they represent RACT for 8-hour implementation purpo ses, and 2) the adoption of new or more stringent regulations that represent RACT control levels. Based on the foregoing, all ACHD rules that apply to ozone precursor emissions fulfill RACT requirements for the 8-hour ozone NAAQS. All CTG sources and major, non-CTG sources under ACHD jurisdiction are controlled to RACT or better standards.

## Notice of Public Comment:

SIP Revision 60 was the subject of two r ounds of public comment periods and public hearings. For the first round, during which the entire SIP revision was the subject, a Notice of Public Hearing and comment period was published in the April 23, 2007 edition of the Pittsburgh Post Gazette


# , and the public comment period was from April 24, 2007 through May 25, 2007. A public hearing was held on May 24, 2007 at the Clack Health Center, 301 39 th 

## Street, Pittsburgh, PA 15201. Ther e were no public comments.

The Department subsequently made a change for petroleum solvent dry cleaners to remove reference to Article XXI, Secti on 2105.18, and instead reference two negative declaration letters of 1985 and 2009. A public comment period was held from January 19, 2009 until February 18, 2009. A public hearing was held February 18, 2009.

Responsible Agency: The agency with direct responsibility fo r preparing and submitting this document is Allegheny County Health Department, unde r the Department’s Director, Dr. Bruce Dixon. The working responsibility for air qual ity planning falls within Air Quality under Mr. James Thompson.

2. CERTIFICATION OF VOC A ND NOx RACT REQUIREMENTS

Discussion: The Air Quality Program operates under the a pproval of the Pennsylvania Department of Environmental Protection in accordance with the provisions of 25 Pa Code Chapter 133. The Air Quality Program controls air pollution from sources by means of visible, mass, and concentration emission standards equal t o, or more stringent than, those standards established by the DEP for emissions (25 Pa Code 133.4 (b) (2)). Si nce the early 1990s, Allegheny County has implemented numerous RA CT controls to meet the CAA’s RACT requirements. RACT controls for VOC and NOx were promulgated in Allegheny County’s Article XXI, Part E “Source Emission and Operating Standards.”

Adoption of new RACT regulation(s) will occur when the County has new stationary sources not cove red by existing RACT regulati ons, or when new data or technical information indicates that a pr eviously adopted RACT measure does not represent a newly-available RACT control le vel. RACT Requirements were identified, implemented and approved into the SI P under the 1-hour ozone NAAQS through caseby-case RACT and Article XXI. Environmen tal Protection of the Pennsylvania Code Identification and certification of VOC RACT controls are provided in Table 1 below.

## Identification and certification of NOx RACT controls are provided in Table 2 below.

Explanations for each column of Table 1 are as follows:

• Column 1: Identifies each section of Artic le XXI or PA DEP Code. These require, in general, major VOC emitting sources to comp ly with the relevant provisions by May 31, 1995. Under the 1-hour ozone standard, the VOC RACT regulation defines a major VOC emitting source as a stationary source that emits VOCs at a rate equal to or greater than 10 tons per year (TPY). (Note - Some s ections are general implementing provisions necessary to implement RACT, not actual RACT controls.) • Column 2: Identifies the underlying basis for the RACT determination (CTG, ACT, ect) • Column 4: Identifies the date the rule was approved into the Pennsylvania SIP, along with the Federal Register citation. • Column 5: Explains RACT contro l applicability and requirements. • Column 6: Certifies whether or not the current rule repres ents RACT under the 8-hour ozone NAAQS. Where Allegheny County has ce rtified that a current SIP approved regulation represents RACT unde r the 8-hour ozone standard, AC HD affirms that it is not aware of any significant changes in control technology that affect the original RACT determination, unless otherwise explained in Column 6. Also, note that any discussion on cost effectiveness is relative only to this RACT SIP, and is not relevant as to whether or not control of a particular sour ce or source category is cost eff ective relative to the entire SIP. Allegheny County’s minor source permitting program requires a detailed administrative and technical review of sources that emit air contaminants far below the “major” threshold” and CTG cutoffs. This permitting program gives confidence that all major and CTG covered sources are contro lled by RACT level or better controls.Table 1: VOC RACT List and Certification under the 8-Hour Ozone NAAQSSource Information RACT Basis Document EffectiveDate ofArticle XXIEPA ApprovalDateRACT Rule Applicability andRequirementsRequirements at least asstringent as the 8-hourozone RACT?Major Source ofNitrogen Oxides andVolatile OrganicCompoundsArticle XXI§2105.0610/20/95 10/7/0267FR62389This section applies to all majorsources of NOx or VOC inexistence as of November 1,1992, for which no applicableemission limitations have beenestablished by regulation underArticle XXI.Yes.This section fullyimplements the CTGspecified control andrepresents current RACTcontrol level over theaffected sources under the8-hour ozone RACT.VOC SourcesSurface CoatingProcessesAllegheny CountyArticle XXI§2105.10CTG: Control ofVolatile OrganicEmissions fromExisting StationarySources, VolumeII: Surface Coatingof Cans, Coils,Paper, Fabrics,Automobiles, andLight-Duty Trucks,EPA-450/2-77-008,May 1977CTG: Control ofVolatile OrganicEmissions fromExisting StationarySources, VolumeIII: SurfaceCoating of MetalFurniture, EPA450/2-77-032,December 197710/20/957/10/0311/14/0267FR 689356/24/0570 FR 36511This section applies to coatingoperations at automobile and lightduty truck assembly plants, and toany can, coil, paper, fabric, or vinylcoating unit and establishesmaximum allowable VOCemissions per unit of coatingsolids.This section applies to the coatingof metal furniture, and establishesmaximum allowable VOCemissions per unit of coatingsolids.Yes.This section fullyimplements the CTGspecified control andrepresents current RACTcontrol level over theaffected sources under the8-hour ozone RACT.CTG: Control ofVolatile OrganicEmissions fromExisting StationarySources, VolumeIV: SurfaceCoating forInsulation ofMagnet Wire, EPA450/2-77-033,December 1977CTG: Control ofVolatile OrganicEmissions fromExisting StationarySources, VolumeV: SurfaceCoating of LargeAppliances, EPA450/2-77-034,December 1977CTG: Control ofVolatile OrganicEmissions fromExisting StationarySources, VolumeVI: SurfaceCoating ofMiscellaneousMetal Parts andProducts, EPA450/2-78-015,June 1978This section applies to the coatingof magnetic wire and establishesmax allowable VOC emissions perunit of coating solids.This section applies to the coatingof large appliances andestablishes max allowable VOCemissions per unit of coatingsolids.This section applies to anymiscellaneous metal parts coatingline, and establishes maxallowable VOC emissions per unitof coating solids.VOC SourcesGraphic ArtsSystemsAllegheny CountyArticle XXI§2105.11CTG: Control ofVolatile OrganicEmissions fromExisting StationarySources, VolumeVIII: Graphic Arts -Rotogravure andFlexography, EPA450/2-78-033,December 197810/20/95 11/14/0267 FR 68935This section applies to anyrotogravure or flexographicprinting process at a facility withpotential uncontrolled VOCemission greater than 100 tonsper year. The rule establishes thelimits of VOC contents in coatingsand inks used in the coveredfacilities and specifies standardsfor control devices for variousprinting processes.Yes.This section fullyimplements the CTGspecified control andrepresents current RACTcontrol level over theaffected sources under the8-hour ozone RACT.VOC SourcesVolatile OrganicCompound StorageTanksAllegheny CountyArticle XXI§2105.12CTG: Control ofVolatile OrganicEmissions fromPetroleum LiquidStorage in ExternalFloating RoofTanks, EPA-450/2-78-047, December1978CTG: Control ofVolatile OrganicEmissions fromStorage ofPetroleum Liquidsin Fixed RoofTanks, EPA-450/2-77-036, December197710/20/95 11/14/0267 FR 68935This section applies to petroleumliquid tanks with external floatingor fixed roofs and with a capacitygreater than or equal to 2,000gallons but less than or equal to40,000 gallons.This section applies to petroleumliquid tanks with external floatingor fixed roofs with a capacitygreater than 40,000 gallons.The rule establishes sealingstandards for storage tanks,including a vapor collection andrecovery system.Yes.This section fullyimplements the CTGspecified control andrepresents current RACTcontrol level over theaffected sources under the8-hour ozone RACT.Gasoline LoadingFacilitiesAllegheny CountyArticle XXI§2105.13CTG: Control ofVolatile OrganicEmissions from BulkGasolinePlants, EPA-450/2-77- 035, December1977CTG: DesignCriteria for Stage IVapor ControlSystems -Gasoline ServiceStations,November 197510/20/95 11/14/0267FR 68935This section applies to allunloading, loading, and storageoperations at bulk gasoline plantsand to any gasoline tank truckdelivering or receiving gasoline ata bulk gasoline plant.Requirements include the use ofvapor balance, and variousequipment and work practicestandards.DegreasingOperationsAllegheny CountyArticle XXI§2105.15CTG: Control ofVolatile OrganicEmissions fromSolvent MetalCleaning, EPA450/2-77-022,November 197710/20/95 11/14/0267FR 68935This section applies to solventcleaning machines that exceed 10square feet. This regulationestablishes standards for (1) batchcold cleaning machines, (2) batchvapor cleaning machines, and (3)(3) inline cleaning machines.Cutback AsphaltPavingAllegheny CountyArticle XXI§2105.16CTG: Control ofVolatile OrganicCompounds fromUse of CutbackAsphalt, EPA450/2-77-037,December 197710/20/95 11/14/0267FR 68935This section establishesrequirements related to the use ofcutback asphalt and establishesVOC content limits for emulsifiedasphalt.Yes.This section fullyimplements the CTGspecified control andrepresents current RACTcontrol level over theaffected sources under the8-hour ozone NAAQS.Ethylene ProductionFacilitiesAllegheny CountyArticle XXI§2105.1710/20/95 11/14/0267FR 68935This section establishes controlrequirements for waste gasstreams from ethylene productionplants.Yes. This section fullyimplements the CTGspecified control andrepresents current RACTcontrol level over theaffected sources under the8-hour ozoneNAAQS.Synthetic OrganicChemical andPolymerManufacturing –Fugitive EmissionsAllegheny CountyArticle XXI§2105.19CTG: Control of VolatileOrganic CompoundFugitive Emissions fromSynthetic OrganicChemical Polymer andResin ManufacturingEquipment, EPA450/3-83-006,March 198410/20/95 11/14/0268FR 68935This section establishes provisionsfor minimizing leaks, andestablishes a leak detection andrepair program for processequipment.Yes.This section fullyimplements the CTGspecified control andrepresents current RACTcontrol level over theaffected sources under the8-hour ozone NAAQS.PetroleumRefineriesAllegheny CountyArticle XXI§2105.7010/20/9511/14/0267 FR 68935This section applies to vacuumproducing systems, wastewaterseparators, and process unitturnaround at petroleum refineries.Yes.This section fullyimplements the CTGspecified control andrepresents current RACTcontrol level over theaffected sources under the8-hour ozone RACT.Section§2105.71:PharmaceuticalProductsCTG: Control of VolatileOrganic Emissions fromManufacture ofSynthesizedPharmaceutical Products,450/2- 78-029, December197810/20/9511/14/0267 FR 68935This section applies to VOCsources at synthesizedpharmaceutical manufacturingfacilities including: reactors,distillation operations, crystallizers,centrifuges, and vacuum dryers.The rule establishes standards forcontrolling and reducing VOCemissions from all coveredsources.Yes.This section fullyimplements the CTGspecified control andrepresents current RACTcontrol level over theaffected sources under the8-hour ozone RACT.Manufacture ofPneumatic RubberTiresAllegheny CountyArticle XXI§2105.72CTG: Control of VolatileOrganic Emissions fromManufacture ofPneumatic Rubber Tires,EPA-450/2- 78-030,December 197810/20/9511/14/0267 FR 68935This section establishes VOCemissions limits for pneumaticrubber tire manufacturingoperations.Yes.This section fullyimplements the CTGspecified control andrepresents current RACTcontrol level over theaffected sources under the8-hour ozone RACT.AerospaceManufacturing AndReworkAllegheny CountyArticle XXI§2105.74CTG: Aerospace(CTG & MACT) (see 59FR 29216,June 6, 1994);CTG (Final), EPA453/R-97-004,December 19977/10/2003 6/24/200570FR 36511This section applies to anyaerospace manufacturing andrework facility.The regulation establishes vaporpressure limits, VOC contentlimits, emission limits and/or workpractice standards for: (a)handwipe, spray gun, or flushcleaning operations, (b) primer,topcoat, self-priming topcoat, andspecialty coating operations, (c)chemical milling maskantapplication, (d) depainting ofaerospace vehicles, and (e)handling and storing of VOC.Yes.This section fullyimplements the CTGspecified control andrepresents current RACTcontrol level over theaffected sources under the8-hour ozone NAAQS.Mobile EquipmentRepair andRefinishingAllegheny CountyArticle XXI§2105.75ACT: Automobile Bodyrefinishing ACT (EPA453/R- 94-031, April1994)7/10/2003 6/24/200370FR 36511This section applies to any personwho applies coatings to mobileequipment.Wood FurnitureManufacturingOperationsAllegheny CountyArticle XXI§2105.76CTG: WoodFurniture (CTGMACT)- draftMACT out 5-94;Final CTG, EPA453/R-96-007,April 1996; seealso 61 FR 25223,and, 61 FR 50823,September 27,19967/10/2003 6/24/200570FR 36511This section establishes VOCemission limitations and workpractice standards for woodfurniture manufacturing operationswith the potential to emit 25 tpy orgreater of VOC.Yes.This section fullyimplements the CTGspecified control andrepresents current RACTcontrol level over theaffected sources under the8-hour ozone NAAQS.

## 3. NEGATIVE DECLARATION LIST Allegheny County found no emission sources that require this CTG requirement: Control of Volatile Organic Emissions from Existing Stationary Sources, Volume VII: Factory Surface Coating of Flat Wood Paneling, EPA-450/2-78-032, June 1978. Page 26 of 28 Processing Plants, EPA-450/2-83-007, December 1983. Shipbuilding/Repair ACT (EPA 453/R- 94-032, April 1994) and CTG, see 61 FR 44050, August 27, 1996. Control of Volatile Organic Compound Emi ssions from Air Oxidation Processes in Synthetic Organic Chemical Manufactu ring Industry, EPA-450/3-84-015, December 1984. Control of Volatile Organic Compound Emissions from Reactor Processes and Distillation Operations Processes in the Synthetic Organic Chemical Manufacturing Industry, EPA-450/4-91-031, August 1993. Control of Volatile Organic Emissions fr om Large Petroleum Dry Cleaners, EPA-450/3- 82-009, September 1982.

An updated negative declaration letter for th e Large Petroleum Dry Cleaners was sent in January, 2009. A copy of this le tter, as well as the original 1985 letter is attached in Appendix A.

4. CERTIFICATION OF NOX RACT REQUIREMENTS

Table 2 of this document lists each De partment NOx RACT control regulation, the RACT basis for the regulation, SIP re vision approval by EPA citations, the RACT Rule applicability and requirements, and certification that the existing regulation represents RACT under the 8-hour ozone NAAQS. Where Allegheny County has certified that a current SIP approved regulat ion represents RACT under the 8-hour ozone standard, ACHD states that it is not aw are of any significant changes in control technology that affect the original RACT determination. Consistent to Pennsylvania Department of Environmental Protection, the Department previously used a cost of $1,500/ton of NOx as a benchmark value when determining cost-effective control technology for NOx sources subject to the RACT requirements adopted for the 1-hour ozone NAAQS. These cost-effective controls co ntinue to represent RACT for the 8-hour ozone NAAQS because NOx control technologie s have not substantially changed since the mid-1990s.

Although the capital costs fo r certain control technologi es, such as SCR and lowNOx burners, have remained fairly constant, the annual operating cost s have significantly increased due to price increases for urea, electricity, and opera ting labor. Generally, replacement low NOx burners are not availa ble for older existing 100 MMBtu/hr boilers and smaller, but when they are available, they are not cost-effective as RACT. The RACT determinations made for the 1-hour oz one standard are repr esentative of RACT for the 8-hour NAAQS.

## Table 2 - NOx RACT List and Certifi cation Under the 8-Hour Ozone NAAQS Allegheny County Regulation RACT Basis Document SIP Revision Approved by EPA RACT Rule Applicability and Requirements Requirements at least as stringent as the 8-hour ozone RACT? Major Source of Nitrogen Oxides and Volatile Organic Compounds Article XXI § 2105.06 NOx RACT, CAA Section 182(b)(2) and Section 182(f) 10/7/02 67FR62389 This section establishesprovisions for case-bycase determinations of RACT for major NOx sources. In addition, it establishesrequirements for caseby-case RACT determinations for certain major NOx sources and establishes presumptive RACT limitations for certain classes of combustion units. Yes. This provision represents current NOx RACT control requirement under the 8-hour ozone NAAQS.

NOx Allowance Requirements 2105.100 These sections ensure that sourcessubject to the capand-trade program achieve RACT-level reductions because they meet the NOx SIP Call requirements. EPA believes that the SIP provisions for those sources subject to the State’s emission cap-and-trade program where the cap-and-trade program has been adopted by the State that meets the NOx SIP Call requirements meet the ozone NOx RACT requirement (70 FR 71652). Effective 3/31/98.

By County ordinance. Referenced state rule approved by EPA, 8/21/01, 66FR 43795 effective 9/20/01 This Section requires compliance with the PaDEP NOx budget and NOx allowance trading program for NOx affected sources located in Allegheny County and subject to 25 Pa Code Sections 123.101 through 123.120 and Appendix A, for the purpose of achieving the health based ozone ambient air quality standard. Yes. This provision represents current NOx RACT control requirement under the 8-hour ozone NAAQS.

Clean Air Interstate Rule (CAIR) This rule will require additional NOx reductions from EGU facilities. Allegheny County sources will be subject to the state rule.

## 5. CASE-BY-CASE EVALUATIONS
The Department has evaluated all eligible sources case-by-case for applicability to NOx RACT. All sources that we re subject to, and institute d, a 1-hour RACT plan, were re-evaluated as to the ade quacy of that plan to the 8-hour RACT requirements. The Department certifies that theses sources ha ve an adequate RACT demonstration for 8- hour ozone in their 1-hour plan. One source, Laurel Mountain Whirlpool, Inc. did not have a 1-hour RACT plan. This source, however, is subject to the National Emission Standards for Hazardous Air Pollutants for Reinforced Plastic Composites Production, 40 CFR subpart wwww. The Department certifie s that the requirements of 40CFR Subpart wwww are adequate for the 8-hour oz one RACT for this source.

TABLE 3: CASE-BY-CASE 8- HOUR RACT EVALUATION

2006 VOC & NOx RACT - Allegheny County

Plan No. Permit No. Facility VOC NOx Has a Ozone 1-hr RACT Plan Sufficient for 8 hr RACT? Notes 1 0059 Allegheny Ludlum Corp. x x Yes Yes 2 0037 Ashland Specialty Chemical Co. x x Yes Yes 3 0079 Bay Valley Foods x Yes Yes 4 0047 Bellefield Boiler Plant x Yes Yes 5 0058 Eastman Chemical Resins, Inc. x x Yes Yes 6 0005 GE Lighting LLC x Yes Yes 7 0023 Guardian Industries Corp. x Yes Yes 8 0029 Koppers Industries, Inc. x Yes Yes 9 0014 Laurel Mountain Whirlpool, Inc. x No -- *1 10 0060 Neville Chemical Co. x x Yes Yes 11 0022 NRG Energy Center x Yes Yes 12 0056 Orion Power Brunot Island x x Yes Yes 13 0054 Orion Power Cheswick x Yes Yes 14 0044 PACT x Yes Yes 15 0008 Port Glenshaw Glass, LLC x x Yes Yes 16 0057 PPG Industries, Inc Springdale x Yes Yes 17 0032 Pressure Chemical Company x Yes Yes 18 0025 Shenango Inc. x x Yes Yes 19 0052 USSteel Clairton x x Yes Yes 20 0051 USSteel ET x x Yes Yes 21 0050 USSteel Irvin x x Yes Yes

Notes *1 Laurel Mountain Whirlpool is subject to the MACT standards of 40CFR 63 subpart wwww; this is sufficient for VOC RACT.

## B.

Documentation of First Public Hearing and Certifications
Public hearing notice Proof of publication of notice of hearing Transmittals of hearing notice to EPA & PA DEP Certification of hearing Comment and response document

## NOTICE OF PUBLIC HEARING FOR PROPOSED ALLEGHENY COUNTY PLAN FOR REASONABLY AVAILABLE CONTRO L TECHNOLOGY FOR OZONE

The Allegheny County Health Department will hold a public hearing on a proposed change to the Allegheny Count y portion of the Pennsylvania State Implementation Plan (SIP) to demonstrate that Reasonably Availa ble Control Technology (R ACT) is in place for 8-hour ozone on subject sources in Allegheny County, on Thursday, May 24, 2007 beginning at 10:00 AM in the Conference Room of Building #7 of Clack Health Center, 301 39th St., Pittsburgh, PA, 15201.

The plan does not impose any new requirements on any Allegheny County source. The final plan will be submitted to U.S. EP A as a revision to the Pennsylvania State Implementation Plan.

Copies of the proposed amendments may be examined beginning Tuesday, April 24 th



## , 2007, at the Allegheny County Health Depart ment Library, Building 7, Clack Health Center, from 8:30 AM until 3:30 PM Monday thru Friday; on the Allegheny County Health Department web site: www.achd.net ; or by calling 412-578-8120 to request a mailed printed copy.

Oral testimony must be pre-scheduled by calling 412-578-8008 no less than 24 hours in advance of the public hearing. Speakers will be limited to five minutes and should bring a written copy of their comments.

The Board will accept written testimony beginning Tuesday, April 24, 2007 , and concluding Friday, May 25, 2007 , by mail to: Board of Health 3333 Forbes Avenue Pittsburgh, PA 15213 By email to BOH@achd.net

By Fax to 412-578-8325No

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### Pr oo f o f Publication of Notice 

### in Pittsburgh Post-Gazette
Under Act No 

### 587, Approved 

### May !6

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mmoowealth of Penns ylvani a, Co unty of Allegheny, ss M. Gooclwin

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......, esta blished in 1993 by the mergin a of the Piasburgh Post-Gazette and Sun-Telegraph and Tbe PittSburgh Pres s and the PittSburp Post

Gazette and Sun-Te legra ph was established in 1960 and the P i ttSburgh POSI -Gaz ette was e s tablished in 192 7 by the metging of the PittSburgh G uene es tab lished in 

### 1786 and the PittSburgh P ost, established in 

### 1842, since wbi eh date th e said PittSburgh P ost-G azcuc h.u been regularly assued in s aid Coun ty and that a copy of said printed notiCe o r publicati o n as attached hereto exa c tly as the same \ViU printed ODd pu blish ed in the regular editio n& and iss ues of the said Pittsburgh**Post-G~tte** a newspaper of general circulation on the fullowing dates, viz:

23 of AprU

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## matter
of the afore said notice or p ublication. and that a U a llegations in the furegoing statement as to time, place and c haracter of**publi~tion** arc tru e.



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### AIR QUALITY PROGRAM 301 Thirty-Ninth Street Pittsburgh, Pennsylvania 15201-1891

April 17, 2007

Ms. Judith Katz, Director Air Protection Division U.S. Environmental Protection Agency Region III (3AP00) 1650 Arch Street Philadelphia, PA 19103-2029

Dear Ms. Katz:

Enclosed is a Notice of Public Hearing and a dr aft submittal to the County’s portion of the PA State Implementation Plan related to the Ozone 8-Hour RACT plan analysis for Allegheny County sources.

Your comments are welcome.

Very truly yours,

Roger C. Westman Manager

cc: File

Enclosures

 Notice of Public Hearing

 Proposed ACHD Document 60

### AIR QUALITY PROGRAM 301 Thirty-Ninth Street Pittsburgh, Pennsylvania 15201-1891

April 17, 2007

Ms. Joyce Epps, Director Bureau of Air Quality Department of Environmental Protection Rachel Carson Building 400 Market Street P O Box 8468 Harrisburg, PA 17105-8468

Dear Ms. Epps:

Enclosed is a Notice of Public Hearing and a dr aft submittal to the County’s portion of the PA State Implementation Plan related to the Ozone 8-Hour RACT plan analysis for Allegheny County sources.

Copies of the Notice and related documents have also been sent to the DEP office at Region V.

Your comments are welcome.

Very truly yours,

Roger C. Westman Manager

cc: File

Enclosures

 Notice of Public Hearing

 Proposed ACHD Document number 60

### AIR QUALITY PROGRAM 301 Thirty-Ninth Street Pittsburgh, Pennsylvania 15201-1891

April 17, 2007

Mark Wayner, Manager – Air Quality Department of Environmental Protection Southwest Regional Office - Air Quality 400 Waterfront Drive Pittsburgh, PA 15222-4745

Dear Mr. Wayner:

Enclosed is a Notice of Public Hearing and a dr aft submittal to the County’s portion of the PA State Implementation Plan related to the Ozone 8-Hour RACT plan analysis for Allegheny County sources.

Copies of these documents have been sent to DEP in Harrisburg.

Your comments on these changes are welcome.

Very truly yours,

Roger C. Westman Manager

cc: Stephen Hepler

Enclosures

 Notice of Public Hearing

 Proposed ACHD Document 60

## SIP Revision 60

Certification of Hearing

Thomas F. Lattner deposes and says that he is an Air Pollution Control Engineer in the Air Quality Program of the Allegheny Count y Health Department and hereby certifies that a Public Hearing was held on May 24, 2007 on the revision to Allegheny County’s portion of the Pennsylvania State Implemen tation Plan (SIP) to demonstrate that Reasonably Available Contro l Technology (RACT) is in place for 8-Hour ozone on subject sources in Allegheny County; that the opportunity for written comments was given in accordance with the requirements of 40 CFR 51.102; that notice of such hearing was given by publication in a newspaper of general circulation on April 23, 2007; and to the best of his knowledge, belief and unde rstanding, such proceedings were in full compliance with all applicable State a nd Federal laws, regulations, and other requirements.

Thomas F. Lattner Air Pollution Control Engineer Air Quality Program Allegheny County Health Department

Date May 30, 2007

## Comment And Response Document Fo r The Proposed SIP Revision 60 RACT Plan Amendments for 8-Hour Ozone NAAQS. May 24, 2007 Public Hearing

No comments were received during the pub lic hearing, nor during the entire public comment period of April 24 through May 25, 2007.

## C.

Documentation of Second Public Hearing and Certifications Public hearing notice Proof of publication of notice of hearing Transmittals of hearing notice to EPA & PA DEP Certification of hearing Comment and response document

## NOTICE OF PUBLIC HEARING FOR PROPOSED UPDATE TO ALLEGHENY COUNTY PLAN FOR REASONABLY AVAILABLE CONTRO L TECHNOLOGY FOR OZONE

The Allegheny County Health Department will hold a public hearing on a proposed Update to the Amendment to the Alleghe ny County portion of the Pennsylvania State Implementation Plan (SIP) to demonstrate that Reasonably Available Control Technology (RACT) is in place for 8-hour ozone on subject sources in Allegheny County, on Wednesday, February 18, 2009 beginning at 10:00 AM in the Conference Room of Building #7 of Clack Health Ce nter, 301 39th St., Pittsburgh, PA, 15201.

The Update to the Amendment to the Plan removes references to Petroleum Solvent Dry Cleaners, since none exists in the County, and does not impose any new requirements on any Allegheny County source. The final updated plan will be submitted to U.S. EPA as a revision to the Pennsylvania State Implementation Plan.

Copies of the proposed amendments may be examined beginning Monday, January 19, 2009, at the Allegheny County Health Depart ment Library, Building 7, Clack Health Center, from 8:30 AM until 3:30 PM Monday th ru Friday; at the Allegheny County Law Library, 921 City County Building, 414 Gran t Street; on the Allegheny County Health Department web site: www.achd.net ; or by calling 412-578-8 120 to request a mailed printed copy.

Oral testimony must be pre-scheduled by calling 412-578-8008 no less than 24 hours in advance of the public hearing. Speakers will be limited to five minutes and should bring a written copy of their comments.

The Board will accept written testimony beginning Monday, January 19, 2009 , and concluding Wednesday, February 18, 2009 , by mail to: Board of Health 3333 Forbes Avenue Pittsburgh, PA 15213 By email to BOH@achd.net

By Fax to 412-578-8325No

. Term,

_ ____ _ 

### Proof of Publication of Notice in Pittsburgh Po s t-Gazette
Under Act No 587, Approved May 16, 1929, PL 1784, 

### as last**am~nded** by Act No 409 of September 29, 1951

Commonwea l th of Pennsylvania, County of Alleg h eny, ss M. G 9Qd win

, being duly swo rn , deposes and says tha t the Pitts b urgh Post-Gazette, a newspaper of general circulation pub l ished in the City ofPittsburgh, County and Commonwealth aforesaid, was

es t ablished in 1 993 by the merging of the Pittsburgh Post

- Gazette and Sun-Te l egraph and The Pittsburgh Press and the Pittsburgh Post

Gazette and Sun

- Telegraph was established in 1960 and the Pittsburgh Post-Gazette was estab l ished in 1927 by the me r g in g of the Pittsburgh Gazette established in 1786 and the Pittsburgh Post, establ i shed in 1842, since which date t he said Pittsburgh Post-Gazette has been regu l arly issued in said County and that a co p y of said printed notice or pub li cation i s attached hereto exactly as the same was printed and publish e d in th e regular editiotts and issues of the said P i ttsburgh Post-Gazette a newspaper of general circ u 13tion on the following dates

, viz:

1 3 o f J anu a ry, 2 0 0 9 A ffiant further deposes that h e/she i s an agent fo r the PG Publishing Com p any, a corporation and publis h e r of the Pittsburgh P ost-Gazette, that, as such agen t, affiant i s duly authorized to ve r ify the foregoing state m ent unde r oath, that affiant is n ot interested in the subject matter of the afore said notice or publicatiou, and that all allegations in t he foregoing statement as to tim e , p l ace and character of publication are ttue.
C OPY OF NOTI CE OR PUBLI CA TIO N

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COMM O NWEAL T H OF PENNSYLVA NI A
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'-----1**~~mM~3a~~~~~i~~;~** 

### ------l**t~:.:'t~~~~h~"4 <;o~?~**  

### Publi s her ' s Receipt for Advertising Co s ts PG PUBL'

## g~.~~~~<~~~~fi\e**l~.NY,** publis h er of the Pittsburgh Post-Gazette, a newspaper of general circulation, h b ,, l egheny county HMitll 

### f th**~:** . d d . . d bl' · d · 

### fi th th h ere y ac.**~~~ 1'r~~~n'Zr** **bo~ \;?t**  o e atorsai a vertlsmg an pu 1catto n rosts an cert1 es a t e same ave been fully**~:.\.~ ".** **·~:.; ~~~~**  copy

. . 

### 0 be**Or~~!i~~~8~Ye'2~:** 34 Bouleva**call~412 578** **8008** no PITTSBUR**~~ce 'l,f,** **e"~~o1fc**

Phone 41**~:~~~ft ~~ga,~.;~** **'7 ~~**  PO Publishing Company, a Corporation, Publisher o f Pittsburgh Post

- Gazette, a Newspaper o f Genera l Circulation

By utes and should b r ing a wr i t t en copy 6f·the l r I hereby ccrti**co~~!rd** will**ac o~t**  the**ri gi~**  Proof of Pub li cation and receipt for t he Advertis in g costs in the subject matter of sa1d notice. w ritt en testinion.Y r>egin-**~~~ ~M,~** **~~~· d~~~~**  ing wednesday. Feb ru · ary 1 8. 2009, by mall to : • Board of Health

3333 Fo r beS Avenue**<~'rt0PA 5213**  

### !**~~!a:'.('O ·**  . AncmcyFor

# J\ll£g}Jeny C!!nunty iijealt}J 1llepartment

DIRECTOR

Bruce W. Dixon, M. D

.

M s. Judith Katz, Dire ctor A ir Protection Divis i on U.S

. Enviro nm e nta l Protection Agency Region lli (3APOO) 1650 Arch Street Philadelphi a , PA 1 9103-2029

Dear M s. Kat z : AIR QUALITY PROGRAM 301 39'" Street

- B ld g. #7 Pittsburgh, PA 1 5201

- 1891

Ph on e: { 4 1 2 ) 578

- 8115

Fax : { 412) 578-8144



### Jan uary 

### 8

, 2009 sPARD OF HEALTH

Pau l M

. K

i ng, Esq., Q

. E.P

. Ola i r Lee Har rison, M

. D.

V i c

e Cha i r

A I M. Ah med

, P.E. Rev. Ricky V

. Burgess Qo nald S

. Burke, M. D

. Hon. Joan Cleary, R

. N.

' J ames M. Flyn n, J r. Lid ia C. Turza i

, M.D. W

ill iam Youngb l ood

E n

closed are a Not ice of Public Hearing an d a draft s ubmittal t o the Cou n ty ' s port io n of t h e PA State I mplementation Plan related to the O zone 8-H ou r RAC T plan analysis for Allegheny County sources. This draft submittal deletes re f erences to Petroleum Based Solvent Dry C l eaners, since there are no so¥rces of this type in Allegh e ny Co u nty , and 

### as such, is 

### an update to 

### a previous submittal which was th e subject of an ea rli er pub l ic hearing on Ma y 2 4

, 2007.

Your comments are welcome.

cc: File

Enclos ure s

2S.09300S Notice o f Public Hearing Proposed ACHD Docu ment 60 Sincerely,

# ~d~ James E

. Thompson Manager

# i\llegf1eny C!rnunty fhiealt4 ilepartment

I

DIRECTOR

Bruce W

. Dixon, M.D.

Ms. J o yce Epps, Directo r Bureau of Air Qua lity Department of Environmental Protection Rachel Carson Building 400 Market S tr eet P 0 Bo x 8468 Harrisburg, PA 17105-8468

Dear Ms. Epps ; AIR QUALITY PROGRAM
301 39 111 Street

- Bldg. #7 Pi tt sburgh,

. PA 1520 1- 1891

Phone : (412) 578-8115

Fax : (412) 57 8

- 8144

J anuary 

### 8, 2 0 09 BOARD OF HEALTH

P au l M. King, E sq

. , Q

. E.P.

01air Lee H arrison, M.D.

Vice C ha i r

j AIM. Ahmed, P .E. Rev

. Ricky V. Bur g ess Donald S. Burke, M.D.

H on. Joan Cleary, R .N.

J am es M

. Flynn, Jr. Lid ia C. Turza l, M. D

. Will i am Youngblood

Enclosed are a Notice of Pub l ic Hearing and a draft submitta l to the County's portion of the PA State Implementation Plan related to the Oz one 8-Hour RACT plan an alysis for Allegheny County sources. This draft submittal deletes references to Petroleum Based So lv en t Dry Cleaners, sinc e there are no sources of th i s type i n Allegheny County, an d 

### as such, is 

### an update to a previous sub mittal w h ich was the subject of 

### an ear li e r publ i c hearing on May 24, 2007.

Yo ur comments are wel co

me.

cc: F i le

Enclosur es**2~093008** No t i ce of Public Hearing Proposed ACHD Documen t 60 S i ncere l y,

# fs~ J ames E

. Thompson Manager

# i\l~glJ.eny 

# Qrnunty i;.ealtlJ 1B.epartm.ent

I

DIRECTOR

Bruce W. D i xon, M.D.

Mark Wayner, Manager

- Air Quality Department of Environmental Prote ction Southwest Regional Office

- Air Quality 400 Waterfront Dr i ve Pittsburgh, PA 15222-4745

Dear 

### Mr. Wayner: AIR QUALITY PROGRAM 301 39'" Street- B ldg. #7 P i ttsburgh, PA 15201 -189 1

Pho ne: (412) 578

- 81 15

Fax: ( 412) 578

- 8144



### January 8

, 2009 BOARD OF HEALTH

Pau l M. King, Esq., Q

. E.P.
Cha i r Lee Har ri son, M.D.
Vice Cha i r

. Al M. Ahmed, P.E.**~ev .**  Ricky v. Burgess Dona l d 5. Burke, M

. D. Hon. Joan C l eary, R.N. James M

. Aynn, Jr. Udia C. Turzai, M

. D. Will iam Youngb lood

E nclosed are a Not i ce of Public Hearing and a draft subm i ttal to the County ' s portion ofthe ; PA State Imp l ementation Plan re l ated to the Ozone 8-Hour RACT plan analysis for Allegheny Count)' sources

. This draft submitta l deletes references to Petroleum Based Solvent Dry Clean ers , since there are no sources of t his type in Allegheny County, an d as such, is an update to a previous submittal which was the su bjec t of an earlier public hearing on May 24,2007

.

Your comments are welcome

.

cc: S

. Hepler (DEP) File

Enclosures

• No tice of Pub li c Hearing Proposed ACHD Doc um en t 60

25-093008 Sincerely,

# ~~ James E. Thompson Manager

## SIP Revision 60

Certification of Hearing (Second Hearing)

Thomas F. Lattner deposes and says that he is an Air Pollution Control Engineer in the Air Quality Program of the Allegheny Count y Health Department and hereby certifies that a Public Hearing was held on Febr uary 18, 2009 on the revision to Allegheny County’s portion of the Pennsylvania State Implementation Plan (SIP) to demonstrate that Reasonably Available Control Technol ogy (RACT) is in place for 8-Hour ozone on subject sources in Allegheny County; thatthe opportunity for written comments was given in accordance with the requirements of 40 CFR 51.102; that notice of such hearing was given by publication in a newspaper of general circulation on January 13, 2009; and to the best of his knowledge, belief and understanding, such proceedings were in full compliance with all applicable State a nd Federal laws, regulations, and other requirements.

Thomas F. Lattner Air Pollution Control Engineer Air Quality Program Allegheny County Health Department

Date: February 19, 2009

## Comment And Response Document Fo r The Proposed SIP Revision 60 RACT Plan Amendments for 8-Hour Ozone NAAQS. February 18, 2009 Public Hearing (Second Hearing)

No comments were received during the pub lic hearing, nor during the entire public comment period of January 19, 2009 through February 18, 2009.

## APPENDIX A.

Petroleum Solvent Dry Cleaners Negative Declaration Letters

January 8, 2009 February 12, 1985

### DIRECTOR

Brure W

. Dixon

, M .D.

Ms. Judi th Katz Air Protection Division U

. S. E nvironmental Pr otection Agency Region ill (3APOO) 

### 1650 Arch Street 

### Phi la delphia, PA 19103-2029



### Dear Ms. Katz AIR QUALITY PROGRAM 301 39"' Street

- Bldg

. #7 Pittsburgh, PA 15201

- 1891

Phone : (41 2) 578-8115 Fax: { 4 12) 578

- 8 1 44



### January 8, 

### 2009 BOARD OF HEALTH

Paul M. King, Esq., Q

. E.P.
O..lf' Lee Harrison, M.D. V..ceChalr

AI M

. Ahmed, P.E

. Rev. Ricky V. Burgess Dona ld S. Burke, M.D.
Hon. Joa n Oeary, R-N.

J ames M

. F l ynn, Jr. Lidia C. Turzai, M.D.
W i llia m Youngblood



### The Air Qual i ty Division wishes to provide definitive i nformation with regard to one of the categories of CTG

- related sources in 

### Allegheny County. The situation is summarized herewith:

Volatile Organic Emissions from Large Petroleum Drv 

### Cleaners EPA-450 / 3-82-009 A large petroleum dry c l eaner 

### as categorized by thi s CTG is one that emits more t h an I 

### 00 tons per year ofVOC. There are no p lan ts of this size in 

### Allegheny County

, consequently no regulation i s required.

cc: File (SIP Rev. 60)

25-1)93008

# 6~ Jim 

### Thompson, Chief Air Qual i ty ProgramCOUNTY CO-ISSIONERS

TOM fO ERHER dl41i!11"4n

PETE FLA HER TY

BARB

. AAA HAFER

N

. MARK RICHAROS,M..O. dil.c.or

Mr

. Gl enn Han so n Chi ef

, P a/IWa Se c tion U

. S

. EPA, Regi on III 

### 6th and lla l nut S tre e ts Phi l a de l phia, PA 1 9 1 06



### Dear M r. Hanson: BUREAU OF AIR POLLUTIO N CONTROL 301 Thirty-n i nth Street P

ittsb urgh

, Pennsy l vania 15201 412-578

- 8101

f" ebruary 12

, 1985 BOARD OF HEALTH

ROY L

. T I TCHWORTH, M.D. eh•lrm.,..
M. ART IN KR ' AUSS. 0.0

. viol C:"-lrmtn

CONSTANCE B I LSKI MINONA CLINTON
MARY L

. GALLAGHER, U

. S. N

. NANCY J

. GASKEY, Pti

. O

. , C

. R

, N.A

. JAMES HAWES LEWIS H. KULLER, M. D

. , Or

. PH

CHARLES L

. WINEK, Ph.D,

The Bureau wishes t o provid e defin iti ve in f ormation wi th regard t o tw o cate

gories of Grou p II I CTC 's sources in Alleghe n y County

. The sit ua tio n**i~** summarized her e \o.,tth:

Vo l a tile Organic Emissions from La rge Petroleum Dry Cle aners, EPA-450 /3 -82-009 A large pet r o l e um dry clea n e r as c ategor i zed by thi s CTG i s o n e that e mit s
more t han 1 00**~ns** per year o f 

### VOC

. There ar e n o plants of this size ;n Allegheny County, co nsequ en tly n o regu la t ion is requ ired.

Con t rol of V ola ci le Organic Compouod Leaks f r o m Synthetic Organ i c Chemical an d Polymer Manufacturing Equip m e nt

- EP A-4 50/3

- 83

- 006 T here is one plant in Al l egheny County in the group covered by this CTG, tha t p r oduces maleic anhyd ride from pet rol eu m-b a sed feedstock. Acco r dingly, th e Bureau will develop a reg u lat io n to mcCt the requiremen t s of t he CTG. Our in te n t wi ll be
t o maint ai n cons

. istency with t he provis i on s of t h e co mparabl e r eg ulation that is

c urrently be in g de velo ped by Pen nsy lvania DER.**s~ :p** **k**

cc: 

## c

. J

. G oet z 

### R. C

. We s t man Sincere l y y our s, 

# ?

.**-t.Q~.Q** _ _ 

# O..f 

# J,_.

_ _ J

. '-

.**~ChJe** o ki

, D ep u ty Direct .o r Air Pollution Co tr ol Bureau