Pennsylvania Department of Environmental Protection --=- . = " - ~ -· " - -~ =-

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 

301 391

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. 

Chair 

Lee Harrison, M.D. 

Vice Chair 

AI M. 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 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 May 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 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 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 comment 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 forward the hard copies and disk to the U.S. EPA Region ill with a recommendation for 

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 

Bruce W. Dixon, 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 391h 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. 

Chair 

Lee Harrison, M.D. 

Vice Chair 

AI M. Ahmed, P.E. 

Rev. Ricky V. Burgess 

Donald S. Burke, M.D. 

Hon. Joan Cleary, R.N. 

James M. Flynn, Jr. 

Lidia C. Turzai, M.D. 

William Youngblood 

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 Pennsylvania 

State Implementation Plan (SfP) made on behalf of ACHD and received by EPA on June 20, 2007. This 

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 Standard 

requirements are met. 

Concurrent with this withdrawal request, ACHD will also be submitting to PA DEP a revised version (attached 

here for information only) of the document sent to you in June 2007, addressing the same subject, with several 

changes made to it, including the removal of the reference to "Dry Cleaning Facilities" 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 Petroleum Dry Cleaners, 

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 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 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. 

25-093008 
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 approval. 

Enclosure 

James 

~ 

Thompson, Manager 

Air Quality Program 
Alleg4.eny <ttnunty i1.ealt4 il.epartm.ent 

DIRECTOR 

Bruce W. Dixon, 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 391h 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. 

Chair 

Lee Harrison, M.D. 

Vice Chair 

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 Control of Volatile Organic Emissions from Large 

Petroleum Dry 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 comment 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 

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 Control 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 Certification under the 8-Hour Ozone 

NAAQS 

3. Negative Declaration List 

4. Certification of NOx RACT Requirements 

Table 2: NOx RACT List and Certification Under the 8-Hour Ozone 

NAAQS 

5. Case-By-Case Evaluation 

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

B. Documentation of First 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 

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 Dry Cleaners Negative Declaration Letters
A. 

Reasonably Available Control Technology (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 Implementation 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 Air Pollution Agencies 

Background and Requirements: 

The federal Clean Air Act (CAA) of 1990 gives the states primary responsibility for 

achieving the National Ambient Air Quality Standards (NAAQS). The NAAQS are 

established by the U.S. Environmental Protection 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 responsibilities under the CAA. Once 

approved by the EPA, a SIP is a legally binding document under both state and federal 

law. 

 Ground level ozone, one of the principal components 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 causing breathing problems, throat irritation, 

coughing, chest pains, and increase susceptibility to respiratory infection. High levels of 

ozone also cause serious damage to forests and agricultural crops, which results in 

economic loss to logging and farming operations. 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-Beaver 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 emission 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 reasonably available considering technological and economic 

feasibility (44 FR 53761 at 53762, September 17, 1979). Section 182 of the CAA sets 

forth two separate RACT requirements for 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 second requirement, set forth in section 182(b)(2) of the CAA, 

applies to moderate or worse ozone NAAs as well 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 categories covered by a Control Technique 

Guideline (CTG) issued by EPA. 

 Under section 183 of the CAA, EPA was required to issue several guidance 

documents for RACT controls that would help states meet the requirements of section 

182(b)(2). This requirement upon EPA includes developing (1) CTGs for controls of 

VOC emissions from stationary sources, and (2) Alternate Control Techniques (ACTs) 

for controls of VOC and NOX emissions from stationary sources. 

 The EPA issued three groups of CTG documents, establishing a “presumptive 

norm” for RACT for various categories of VOC sources: 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. Sources 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 RACT 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 quality problem. The entire Commonwealth of Pennsylvania is 

considered a ‘moderate’ ozone non-attainment 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 standard 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 major, non-CTG sources as a revision to their 

SIPs. Such demonstrations can be made with either a new RACT determination or a 

certification that previously required RACT controls represent RACT for the 8-hour 

ozone standard. A certification shall be accompanied by appropriate supporting 

information such as consideration of information received during the public comment 

period and consideration of new data. These 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 demonstration plan, which is also a SIP submittal. 

 

 Allegheny County Health Department has developed a RACT SIP revision that 

demonstrates as of the July 2007 SIP deadline, 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 have 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 standards, to represent RACT control levels 

under the new 8-hour ozone NAAQS. 

Summary: 

 Allegheny County Health Department (ACHD) 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-covered source categories are addressed at the 

emission thresholds set in the CTG. This certification is based on a combination of: 1) 

certification that previously adopted RACT controls in Allegheny County’s portion of the 

Pennsylvania SIP that were approved by EPA under the 1-hour ozone NAAQS are based 

on the currently available technically and economically feasible controls, and that they 

represent RACT for 8-hour implementation purposes, 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 rounds 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 39th Street, Pittsburgh, PA 15201. There were no public comments. 

The Department subsequently made a change for petroleum solvent dry cleaners to 

remove reference to Article XXI, Section 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 for preparing and submitting this document 

is Allegheny County Health Department, under the Department’s Director, Dr. Bruce 

Dixon. The working responsibility for air quality planning falls within Air Quality under 

Mr. James Thompson. 

2. CERTIFICATION OF VOC AND NOx RACT REQUIREMENTS

Discussion: 

The Air Quality Program operates under the approval 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 to, or more stringent than, those standards 

established by the DEP for emissions (25 Pa Code 133.4 (b) (2)). Since the early 1990s, 

Allegheny County has implemented numerous RACT 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 covered by existing RACT regulations, or when new data or 

technical information indicates that a previously adopted RACT measure does not 

represent a newly-available RACT control level. RACT Requirements were identified, 

implemented and approved into the SIP under the 1-hour ozone NAAQS through caseby-case RACT and Article XXI. Environmental 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 Article XXI or PA DEP Code. These require, in 

general, major VOC emitting sources to comply 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 sections 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 control applicability and requirements. 

• Column 6: Certifies whether or not the current rule represents RACT under the 8-hour 

ozone NAAQS. Where Allegheny County has certified that a current SIP approved 

regulation represents RACT under the 8-hour ozone standard, ACHD 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 source or source category is cost effective 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 controlled by RACT level or better controls. 
Table 1: VOC RACT List and Certification under the 8-Hour Ozone NAAQ

Source Information RACT Basis Document Effective 

Date of 

Article XXI 

EPA Approval 

Date 

RACT Rule Applicability an

Requirements 

Major Source of Nitrogen Oxides and Volatile Organic Compounds Article XXI §2105.06 

 10/20/95 10/7/02 

67FR62389 

This section applies to all majosources of NOx or VOC in existence as of November 1, 1992, for which no applicable emission limitations have been established by regulation undeArticle XXI. 

VOC Sources Surface Coating Processes Allegheny County Article XXI §2105.10 

CTG: Control of Volatile Organic Emissions from Existing Stationary Sources, Volume II: Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty Trucks, EPA-450/2-77-008, May 1977 CTG: Control of Volatile Organic Emissions from Existing Stationary Sources, Volume III: Surface Coating of Metal Furniture, EPA450/2-77-032, December 1977 

10/20/95 7/10/03 

11/14/02 67FR 68935 6/24/05 70 FR 36511 

This section applies to coating operations at automobile and liduty truck assembly plants, and any can, coil, paper, fabric, or vcoating unit and establishes maximum allowable VOC emissions per unit of coating solids. This section applies to the coatof metal furniture, and establishmaximum allowable VOC emissions per unit of coating solids. 
CTG: Control of 

Volatile Organic Emissions from Existing Stationary Sources, Volume IV: Surface Coating for Insulation of Magnet Wire, EPA450/2-77-033, December 1977 CTG: Control of Volatile Organic Emissions from Existing Stationary Sources, Volume V: Surface Coating of Large Appliances, EPA450/2-77-034, December 1977 CTG: Control of Volatile Organic Emissions from Existing Stationary Sources, Volume VI: Surface Coating of Miscellaneous Metal Parts and Products, EPA450/2-78-015, June 1978 

This section applies to the coatof magnetic wire and establishemax allowable VOC emissions unit of coating solids. This section applies to the coatof large appliances and establishes max allowable VOC emissions per unit of coating solids. This section applies to any miscellaneous metal parts coatline, and establishes max allowable VOC emissions per uof coating solids. 
VOC Sources 

Graphic Arts Systems Allegheny County Article XXI §2105.11 

CTG: Control of Volatile Organic Emissions from Existing Stationary Sources, Volume VIII: Graphic Arts - Rotogravure and Flexography, EPA450/2-78-033, December 1978 

10/20/95 11/14/02 

67 FR 68935 

This section applies to any rotogravure or flexographic printing process at a facility witpotential uncontrolled VOC emission greater than 100 tons per year. The rule establishes tlimits of VOC contents in coatinand inks used in the covered facilities and specifies standardfor control devices for various printing processes. 

VOC Sources Volatile Organic Compound Storage Tanks Allegheny County Article XXI §2105.12 

CTG: Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks, EPA-450/2- 78-047, December 1978 CTG: Control of Volatile Organic Emissions from Storage of Petroleum Liquids in Fixed Roof Tanks, EPA-450/2- 77-036, December 1977 

10/20/95 11/14/02 

67 FR 68935 

This section applies to petroleuliquid tanks with external floatinor fixed roofs and with a capacgreater than or equal to 2,000 gallons but less than or equal t40,000 gallons. This section applies to petroleuliquid tanks with external floatinor fixed roofs with a capacity greater than 40,000 gallons. The rule establishes sealing standards for storage tanks, including a vapor collection and recovery system. 
Gasoline Loading 

Facilities Allegheny County Article XXI §2105.13 

CTG: Control of Volatile Organic Emissions from Bulk Gasoline Plants, EPA-450/2- 77- 035, December 1977 CTG: Design Criteria for Stage I Vapor Control Systems - Gasoline Service Stations, November 1975 

10/20/95 11/14/02 

67FR 68935 

This section applies to all unloading, loading, and storage operations at bulk gasoline planand to any gasoline tank truck delivering or receiving gasoline a bulk gasoline plant. Requirements include the use ovapor balance, and various equipment and work practice standards. 

Degreasing Operations Allegheny County Article XXI §2105.15 

CTG: Control of Volatile Organic Emissions from Solvent Metal Cleaning, EPA450/2-77-022, November 1977 

10/20/95 11/14/02 

67FR 68935 

This section applies to solvent cleaning machines that exceed square feet. This regulation establishes standards for (1) bacold cleaning machines, (2) batvapor cleaning machines, and (3) inline cleaning machines. 

Cutback Asphalt Paving Allegheny County Article XXI §2105.16 

CTG: Control of Volatile Organic Compounds from Use of Cutback Asphalt, EPA450/2-77-037, December 1977 

10/20/95 11/14/02 

67FR 68935 

This section establishes requirements related to the use cutback asphalt and establisheVOC content limits for emulsifieasphalt. 

Ethylene Production Facilities Allegheny County Article XXI §2105.17 

 10/20/95 11/14/02 

67FR 68935 

This section establishes controrequirements for waste gas streams from ethylene productplants. 
Synthetic Organic 

Chemical and Polymer Manufacturing – Fugitive Emissions Allegheny County Article XXI §2105.19 

CTG: Control of Volatile Organic Compound Fugitive Emissions from Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment, EPA450/3-83-006, March 1984 

10/20/95 11/14/02 

68FR 68935 

This section establishes provisfor minimizing leaks, and establishes a leak detection anrepair program for process equipment. 

Petroleum Refineries Allegheny County Article XXI §2105.70 

 10/20/95 11/14/02 

67 FR 68935 

This section applies to vacuumproducing systems, wastewateseparators, and process unit turnaround at petroleum refiner

Section §2105.71: Pharmaceutical Products 

CTG: Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products, 450/2- 78-029, December 1978 

10/20/95 11/14/02 

67 FR 68935 

This section applies to VOC sources at synthesized pharmaceutical manufacturing facilities including: reactors, distillation operations, crystallizcentrifuges, and vacuum dryersThe rule establishes standards controlling and reducing VOC emissions from all covered sources. 

Manufacture of Pneumatic Rubber Tires Allegheny County Article XXI §2105.72 

CTG: Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires, EPA-450/2- 78-030, December 1978 

10/20/95 11/14/02 

67 FR 68935 

This section establishes VOC emissions limits for pneumatic rubber tire manufacturing operations. 
Aerospace 

Manufacturing And Rework Allegheny County Article XXI §2105.74 

CTG: Aerospace (CTG & MACT) (see 59 FR 29216, June 6, 1994); CTG (Final), EPA453/R-97-004, December 1997 

7/10/2003 6/24/2005 

70FR 36511 

This section applies to any aerospace manufacturing and rework facility. The regulation establishes vappressure limits, VOC content limits, emission limits and/or wopractice standards for: (a) handwipe, spray gun, or flush cleaning operations, (b) primertopcoat, self-priming topcoat, aspecialty coating operations, (cchemical milling maskant application, (d) depainting of aerospace vehicles, and (e) handling and storing of VOC. 

Mobile Equipment Repair and Refinishing Allegheny County Article XXI §2105.75 

ACT: Automobile Body refinishing ACT (EPA 453/R- 94-031, April 1994) 

7/10/2003 6/24/2003 

70FR 36511 

This section applies to any perswho applies coatings to mobile equipment. 

Wood Furniture Manufacturing Operations Allegheny County Article XXI §2105.76 

CTG: Wood Furniture (CTGMACT) - draft MACT out 5-94; Final CTG, EPA453/R-96-007, April 1996; see also 61 FR 25223, and, 61 FR 50823, September 27, 1996 

7/10/2003 6/24/2005 

70FR 36511 

This section establishes VOC emission limitations and work practice standards for wood furniture manufacturing operatiwith the potential to emit 25 tpy greater of VOC. 
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 Emissions from Air Oxidation Processes in 

Synthetic Organic Chemical Manufacturing 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 from Large Petroleum Dry Cleaners, EPA-450/3-

82-009, September 1982. 

An updated negative declaration letter for the Large Petroleum Dry Cleaners was sent in 

January, 2009. A copy of this letter, 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 Department NOx RACT control regulation, 

the RACT basis for the regulation, SIP revision 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 regulation represents RACT under the 8-hour ozone 

standard, ACHD states that it is not aware 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 continue to represent RACT for the 8-hour 

ozone NAAQS because NOx control technologies have not substantially changed since 

the mid-1990s. 

Although the capital costs for certain control technologies, such as SCR and lowNOx burners, have remained fairly constant, the annual operating costs have significantly 

increased due to price increases for urea, electricity, and operating labor. Generally, 

replacement low NOx burners are not available 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 ozone standard are representative of RACT 

for the 8-hour NAAQS. 
Table 2 - NOx RACT List and Certification 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 establishes 

provisions for case-bycase determinations of 

RACT for major 

NOx sources. 

In addition, it establishes 

requirements 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 sources 

subject 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 were subject to, and instituted, a 1-hour RACT plan, were 

re-evaluated as to the adequacy of that plan to the 8-hour RACT requirements. The 

Department certifies that theses sources have 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 certifies that the requirements of 40CFR Subpart 

wwww are adequate for the 8-hour ozone 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 CONTROL TECHNOLOGY FOR OZONE 

The Allegheny County Health Department will hold a public hearing on a proposed 

change to the Allegheny 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 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. EPA as a revision to the Pennsylvania State 

Implementation Plan. 

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

2007, at the Allegheny County Health Department 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 412-578-8325 
No. T~·---------- Proof of Publication of Notice in Pittsburgh Post-Gazette 

Under Act No 587, Approved May !6, !929, PL !784, as laSt am~nded by Act No 409 nfSqitember 29, !951 

mmoowealth of Pennsylvania, County of Allegheny, ss M. Gooclwin , being duly sworn, deposes and says that !be 

ittSburgh Post-Gazene, a newspaper of general circulanoo published in the City of PattSburah, County and Codll!loowealth aforesaid, ......, 

established in 1993 by the mergina of the Piasburgh Post-Gazette and Sun-Telegraph and Tbe PittSburgh Press and the PittSburp PostGazette and Sun-Telegraph was established in 1960 and the PittSburgh POSI-Gazette was established in 1927 by the metging of the 

PittSburgh Guene established in 1786 and the PittSburgh Post, established in 1842, since wbieh date the said PittSburgh Post-Gazcuc h.u 

been regularly assued in said County and that a copy of said printed notiCe or publication as attached hereto exactly as the same \ViU 

printed ODd published in the regular edition& and issues of the said Pittsburgh Post-G~tte a 

newspaper of general circulation on the fullowing dates, viz: 

23 of AprU, 2001 

Affiant further deposes that be/she is an agent for the PG Publishing Company, a corporatioo and publisher of the Pittsburgh Post-Gazelle, 

that, as such agent, affiant is duly authorized to verify the foregoing st.ttement under oath, tl1at affiant is nor interested in the subject matter 

of the afore said notice or publication. and that aU allegations in the furegoing statement as to time, place and character of publi~tion arc 

true. 

-

COPY Of NOTICE OR PUBLICATION 

~OF: ~. 

~~~~.'· 

=-'f~ llfASOOA8tV • •. 

·~r.:~ , OROlllNE . 

no10 t~~~=~ a pubttc. ,...,,,.on a Pto~osed cNn.a• co ,,. A teaneny co"n•r. 

e=or~o~~ 

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1 ~ h·otl,l~~~" ~~~ ' mvSI be P':e-:te"hedl.lled O'f C~lt\ '"12·57 eoGt no less fn,r'l..2.t \:ours e~ rlor to thl ne•rl111 , wriutn eootes orcom· 

mtntS~~~~~ "• 

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--- [§~ •••mlnM bjf'IUIIntl Tullday .... tl" 24tn: 2001. aa ~~>• e.hen~ 

, ~~r.r··~~:-J.r.: • 

I'(; N>listVc ~"''' Sworn to aad subscribed before me this day of: 

April 23, 2007 

COMMONWEALTH OF PENNSYLVANIA 

Nctanal Seal 

lJndi1 M Gaemet. Nctaly PYtlk: 

~I 01 PctsWgn. A.~ COIIIIY 

My <n!mss100 E><ptes Jan. 31. 2011 

STATEME 'T OF ADVERTISING COSTS 

ALCTY HEALTH-LEGAL- FORBES AVE 

JANET NORKUS 

3333 FORBES AVE 

PITTSBURGH PA 15213 

To PG Publishing Company 

Total-----·- - ----····---·-·· $541.20 

t•om a:JO .-un••• s:3Q Publtsber•s Receipt for Advertising Costs 

G P PM MondiV tll<U ,ctday:J 1

. h . gh . . P UB on tne Ala..,...., c~lNY, pub ts er of the Ptttsbur Post-Gazette, a newspaper of general ctrculauon, 

hereby ac ~~j~~:iio~· t of the aforsaid advertising and publication costs and ce.rtifies that the same have been full to requul l . ..,.u.o ~~~~~~~ t>eo~~~~~.rul' '!r':r PG Publishing Company. a Corporauon, Publi5her of 

34 Boulev aurna •n ~ no1 Piusbur"' Post-Gnene a Newspaper of General Circulation . leul"fian ;tc.~..... .,, • 

~!_!C~ tt'::Yth lftl!'~~ 

PmSBURI~!:~~ ~~~k:,~b,!,h~ ' Phone 41 De nmKoo to trve min· 

~:.tc':: ~~1~ I hereby cenif~...- ~ l the oriaioal Proof of Publication and receipt for the Advatisina costs in the SUbJect maner of 

u•d notice. ~ -:f.::,lCcii>t ---- __ _ _ _ ;:;, u.-.::~'~'t.~tt .. '"*' OQ)rU20CJ>. bl' 

m~~..;;., . :~ 

~~:"1M1 ·-· ... .. -...... .. ... 

By 

Atklnlq For 
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 draft 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 draft 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 draft 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 County 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 Implementation Plan (SIP) to demonstrate that 

Reasonably Available Control 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 understanding, such proceedings were in full 

compliance with all applicable State and 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 For The Proposed SIP Revision 60 

RACT Plan Amendments for 8-Hour Ozone NAAQS. 

May 24, 2007 Public Hearing 

No comments were received during the public 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 CONTROL TECHNOLOGY FOR OZONE 

The Allegheny County Health Department will hold a public hearing on a proposed 

Update to the Amendment to the Allegheny 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 Center, 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 Department Library, Building 7, Clack Health 

Center, from 8:30 AM until 3:30 PM Monday thru Friday; at the Allegheny County Law 

Library, 921 City County Building, 414 Grant Street; 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 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 412-578-8325 
No. Term, _ ____ _ 

Proof of Publication of Notice in Pittsburgh Post-Gazette 

Under Act No 587, Approved May 16, 1929, PL 1784, as last am~nded by Act No 409 of September 29, 1951 

Commonwealth of Pennsylvania, County of Allegheny, ss M. G9Qdwin , being duly sworn, deposes and says that the 

Pittsburgh Post-Gazette, a newspaper of general circulation published in the City ofPittsburgh, County and Commonwealth aforesaid, was 

established in 1993 by the merging of the Pittsburgh Post-Gazette and Sun-Telegraph and The Pittsburgh Press and the Pittsburgh PostGazette and Sun-Telegraph was established in 1960 and the Pittsburgh Post-Gazette was established in 1927 by the merging of the 

Pittsburgh Gazette established in 1786 and the Pittsburgh Post, established in 1842, since which date the said Pittsburgh Post-Gazette has 

been regularly issued in said County and that a copy of said printed notice or publication is attached hereto exactly as the same was 

printed and published in the regular editiotts and issues of the said Pittsburgh Post-Gazette a 

newspaper of general circu13tion on the following dates, viz: 

13 of J anuary, 2009 

Affiant further deposes that he/she is an agent for the PG Publishing Comp any, a corporation and publisher of the Pittsburgh Post-Gazette, 

that, as such agent, affiant is duly authorized to verify the foregoing statement under oath, that affiant is not interested in the subject matter 

of the afore said notice or publicatiou, and that all allegations in the foregoing statement as to time, place and character of publication are 

ttue. 

COPY OF NOTICE OR PUBLICATION 

, NOnCE Of P.liBU·HfARING FOR PROf'<}~D UPOATE. 

~GHENY COUNTY PlAN FOR . REASoNABLY AVA.II..A8l.£ 

CONTROl. TECHNOlOGY FOROZON£ 

He~ it.AJ=r:xe~u!fX hold a public hearing on a pr o.pose<J Ul)dat e to the ·Amendment to the 

~~~f:l~~X ~:,un~~v~~ft; St ate Implementation Plan (SJP) to-demo·n- .strate tha.t Reasonably Available control Tech· 

~~Of-~~~~d~~"n~~ 

r~:~eec~:ot~~~st~; ~~ wednesday. F,ebruary 

~g o~ t~ ~~~~~~:r! 

=~~~ ~~~~ ~~a~::: 2!:~~ ter. 301 39tn St., Pitts· 

~eP~~~ to the Amendment to the Plan removes references to rctrol<:uni !;otvent Or)C' Cleaners, sinCe none· extsts tn the' COUnty, and · does not Jinpose any new reQuirements· on 

~r~.~~~e8Xaf8~~ ed plan will be submit· ted to u.s. EPA as a rtNI- Sion to the Pennsylvania state Implementation """'· ~~~:;,~~,fm~'bp~ re e.xamlneo beginning Monoay, Januar y 19, 2009. at the Allegheny 

~~rt~b~:a t~flafrc;r~: Clack He~th center, 

P() Pub!isl>oog Colt9l3rtt 

Sworn to and subscribed before me this day of: 

January 13, 2009 

COMMONWEALTH OF PENNSYLVANIA 

NOI3ilal Seal 

linda M. Gaertner, Notary Pubic 

City 01 Pittsbull1'. Allegheny County 

My CommisSion Expires Jan. 31, 2011 

Member. Pennsylvania Assoele ~ of Nolarie• 

STATEMENT OF ADVERTISING COSTS 

ALCTY HEALTH-LEGAL- FORBES AVE 

JANET NORKUS 

3333 FORBES AVE 

PITTSBURGH PA 15213 

To PG Publishing Company 

Total------------------------------ $426.80 

'-----1 ~~mM~3a~~~~~i~~;~ ------l t~:.:'t~~~~h~"4 <;o~?~ Publisher's Receipt for Advertising Costs 

PG PUBL' g~.~~~~<~~~~fi\e l~.NY, publisher of the Pittsburgh Post-Gazette, a newspaper of general circulation, 

h b ,, legheny county HMitll f th ~: .d d . . d bl' · d · fi th th h ere y ac. ~~~ 1'r~~~n'Zrbo~ \;?t o e atorsai a vertlsmg an pu 1catton rosts an cert1 es at 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 of 

Pittsburgh Post-Gazette, a Newspaper of General Circulation 

By utes and should bring a wri tt en copy 6f·thelr 

I hereby ccrti co~~!rd will ac o~t the rigi~ Proof of Publication and receipt for the Advertising costs in the subject matter of 

sa1d notice. written testinion.Y r>egin-

~~~ ~M,~ ~~~· d~~~~ ing wednesday. Febru· ary 18. 2009, by mall to: • Board of Health 3333 ForbeS Avenue 

<~'rt0PA 5213 

! ~~!a:'.('O · . 

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

DIRECTOR 

Bruce W. Dixon, M.D. 

Ms. Judith Katz, Director 

Air Protection Division 

U.S. Environmental Protection Agency 

Region lli (3APOO) 

1650 Arch Street 

Philadelphia, PA 19103-2029 

Dear Ms. Katz: 

AIR QUALITY PROGRAM 

301 39'" Street - Bldg. #7 

Pittsburgh, PA 15201-1891 

Phone: {412) 578-8115 

Fax: {412) 578-8144 

January 8, 2009 

sPARD OF HEALTH 

Paul M. King, Esq., Q.E.P. Olair 

Lee Harrison, M.D. 

Vice Chair 

AI M. Ahmed, P.E. 

Rev. Ricky V. Burgess 

Qonald S. Burke, M.D. 

Hon. Joan Cleary, R.N. 

'James M. Flynn, Jr. 

Lidia C. Turzai, M.D. 

William Youngblood 

Enclosed are a Notice of Public Hearing and a draft 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. This draft 

submittal deletes references to Petroleum Based Solvent Dry Cleaners, since there are no so¥rces of this type in 

Allegheny County, and as such, is an update to a previous submittal which was the subject of an earlier public 

hearing on May 24, 2007. 

Your comments are welcome. 

cc: File 

Enclosures 

2S.09300S 

Notice of Public Hearing 

Proposed ACHD Document 60 

Sincerely, 

~d~ James E. Thompson 

Manager 
i\llegf1eny C!rnunty fhiealt4 ilepartment 

I 

DIRECTOR 

Bruce W. Dixon, M.D. 

Ms. Joyce Epps, Director 

Bureau of Air Quality 

Department of Environmental Protection 

Rachel Carson Building 

400 Market Street 

P 0 Box 8468 

Harrisburg, PA 17105-8468 

Dear Ms. Epps; 

AIR QUALITY PROGRAM 

301 39111 Street- Bldg. #7 

Pittsburgh,. PA 15201-1891 

Phone: (412) 578-8115 

Fax: (412) 578-8144 

January 8, 2009 

BOARD OF HEALTH 

Paul M. King, Esq., Q.E.P. 

01air 

Lee Harrison, M.D. 

Vice Chair 

j AIM. Ahmed, P.E. 

Rev. Ricky V. Burgess 

Donald S. Burke, M.D. 

Hon. Joan Cleary, R.N. 

James M. Flynn, Jr. 

Lidia C. Turzal, M.D. 

William Youngblood 

Enclosed are a Notice of Public Hearing and a draft 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. This draft 

submittal deletes references to Petroleum Based Solvent Dry Cleaners, since there are no sources of this type in 

Allegheny County, and as such, is an update to a previous submittal which was the subject of an earlier public 

hearing on May 24, 2007. 

Your comments are welcome. 

cc: File 

Enclosures 

2~093008 

Notice of Public Hearing 

Proposed ACHD Document 60 

Sincerely, 

fs~ James E. Thompson 

Manager 
i\l~glJ.eny Qrnunty i;.ealtlJ 1B.epartm.ent 

I 

DIRECTOR 

Bruce W. Dixon, M.D. 

Mark Wayner, Manager - Air Quality 

Department of Environmental Protection 

Southwest Regional Office - Air Quality 

400 Waterfront Drive 

Pittsburgh, PA 15222-4745 

Dear Mr. Wayner: 

AIR QUALITY PROGRAM 

301 39'" Street- Bldg. #7 

Pittsburgh, PA 15201-1891 

Phone: (412) 578-81 15 

Fax: (412) 578-8144 

January 8, 2009 

BOARD OF HEALTH 

Paul M. King, Esq., Q.E.P. 

Chair 

Lee Harrison, M.D. 

Vice Chair 

. Al M. Ahmed, P.E. 

~ev. Ricky v. Burgess 

Donald 5. Burke, M.D. 

Hon. Joan Cleary, R.N. 

James M. Aynn, Jr. 

Udia C. Turzai, M.D. 

William Youngblood 

Enclosed are a Notice of Public Hearing and a draft submittal to the County's portion ofthe;PA State 

Implementation Plan related to the Ozone 8-Hour RACT plan analysis for Allegheny Count)' sources. This draft 

submittal deletes references to Petroleum Based Solvent Dry Cleaners, since there are no sources of this type in 

Allegheny County, and as such, is an update to a previous submittal which was the subject of an earlier public 

hearing on May 24,2007. 

Your comments are welcome. 

cc: S. Hepler (DEP) 

File 

Enclosures 

• Notice of Public Hearing 

Proposed ACHD Document 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 County Health Department and hereby certifies 

that a Public Hearing was held on February 18, 2009 on the revision to Allegheny 

County’s 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; 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 January 13, 2009; and 

to the best of his knowledge, belief and understanding, such proceedings were in full 

compliance with all applicable State and 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 For 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 public 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. Judith Katz 

Air Protection Division 

U.S. Environmental Protection Agency 

Region ill (3APOO) 

1650 Arch Street 

Philadelphia, PA 19103-2029 

Dear Ms. Katz 

AIR QUALITY PROGRAM 

301 39"' Street - Bldg. #7 

Pittsburgh, PA 15201-1891 

Phone: (412) 578-8115 

Fax: {4 12) 578-8144 

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 

Donald S. Burke, M.D. 

Hon. Joan Oeary, R-N. 

James M. Flynn, Jr. 

Lidia C. Turzai, M.D. 

William Youngblood 

The Air Quality Division wishes to provide definitive information 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 cleaner as categorized by this CTG is one that emits more than I 00 tons 

per year ofVOC. There are no plants of this size in Allegheny County, consequently no regulation is 

required. 

cc: File (SIP Rev. 60) 

25-1)93008 

Jim 

6~ Thompson, Chief 

Air Quality Program 
COUNTY CO-ISSIONERS 

TOM fOERHER dl41i!11"4n 

PETE FLAHERTY 

BARB.AAA HAFER 

N. MARK RICHAROS,M..O. 

dil.c.or 

Mr . Glenn Hanson 

Chief, Pa/IWa Sec tion 

U. S. EPA, Region III 

6th and lla l nut Stree ts 

Phil adel phia, PA 19106 

Dear Mr. Hanson: 

BUREAU OF AIR POLLUTION CONTROL 

301 Thirty-ni nth Street 

Pittsburgh, Pennsyl vania 15201 

412-578- 8101 

f"ebruary 12, 1985 

BOARD OF HEALTH 

ROY L. TITCHWORTH, M.D. eh•lrm.,.. 

M.ARTIN KR'AUSS. 0.0. 

viol C:"-lrmtn 

CONSTANCE BILSKI 

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 provide definitive information with regard to two categories of Group III CTC's sources in Allegheny County . The situation i~ 

summarized here \o.,tth: 

Vol a tile Organic Emissions from Large Petroleum Dry Cleaners, EPA-450/3-82-009 

A large pet r ol e um dry cleane r as categori zed by this CTG i s one that emits 

more t han 100 ~ns per year o f VOC . There are no plants of this size ;n Allegheny 

County, consequently no regulat ion is required. 

Cont rol of Volacile Organic Compouod Leaks f rom Synthetic Organi c Chemical and 

Polymer Manufacturing Equipment - EPA-450/3- 83- 006 

There is one plant in All egheny County in the group covered by this CTG, that 

produces maleic anhyd ride from petroleum-based feedstock. Acco rdingly, the Bureau 

will develop a regulation to mcCt the requiremen ts of t he CTG. Our intent will be 

t o maintain cons.istency with t he provisi ons of t he comparable regulation that is 

currently being developed by Pennsylvania DER. 

s~ :p k 

cc: c. J. Goetz 

R. C. Wes t man 

Sincerel y yours, 

? . -t.Q~.Q __ O..f J,_. __ J.'-. ~ChJe o ki , Deputy Direct.or 

Air Pollution Co trol Bureau