CHRIS CHRJSTJE 

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DEPARTMENT of ENVIRONMENTAL PROTECTION 

Division of Air Quality 

BOB MARTIN 

Governor Commissioner 

MAILCODE: 40 I -02 

KIM GUADAGNO 

Lt. Governor 

401 E. State Street, 2nd floor, P.O. Box 420 

Trenton, NJ 08625-0420 

Air Management Services 

321 University A venue 

2"d floor 

Philadelphia, P A 19104 

Attn: Karen Smith 

July 24, 2014 

RE: Proposed Revision to the State Implementation Plan to Meet the Requirements of 

Reasonably Available Control Technology Set Forth by the Clean Air Act under the 8-Hour 

OzoneNAAQS 

Dear Ms. Smith: 

Thank you for the opportunity to comment on the City of Philadelphia Department of Health Air 

Management Services (AMS) proposed Reasonably Available Control Technology (RACT) SIP 

revision for Philadelphia County (June 28, 2014 Proposed Revision to the State Implementation 

Plan to Meet the Requirements of Reasonably Available Control Technology Set Forth by the 

Clean Air Act under the 8-How- Ozone NAAQS). The State of New Jersey's air quality is 

directly impacted by transport of emissions of oxides of nitrogen (NOx) from Philadelphia 

County. The New Jersey Department of Environmental Protection (New Jersey) urges AMS to 

reconsider the proposed NOx RACT limits and adopt limits that are at least equivalent to those 

adopted by New Jersey five years ago (2009), and approved by the United States Environmental 

Protection Agency in 2010. 

The Clean Air Act requires implementation of current RACT for the 75 ppb ozone health 

standard. New Jersey's RACT limits for electric generating units are reasonable performance 

standards that are necessary to attain and maintain the ozone NAAQS throughout the region, 

especially on high electric demand days (HEDD) which occur on hot summer days. New 

Jersey's NOx RACT limits for No. 6 fuel oil-fired boilers and No. 2 fuel oil-fired simple cycle 

turbines used to generate electricity are substantially lower than the AMS corresponding 

proposed source-specific emission limits (see Enclosure 1). Also, the proposed annual NOx 

limits do not address daily NOx emissions, which is needed to address ozone, especially on high 

electric demand days. 

AMS' source-specific RACT limits should include lower NOx emission standards that apply on a 

daily basis, or shorier time period. Specifically, New Jersey's NOx RACT limits should be 

considered for the No. 6 oil-fired boilers at Veolia- Edison Station, Veolia - Schuylkill Station; 
and the No. 2 oil-fired simple-cycle turbines at Exelon - Richmond Station, Exelon - Delaware 

Station, and Exelon - Schuylkill Station. Implementing up-to-date daily RACT limits in 

Philadelphia County would contribute to improved air quality in Philadelphia and its downwind 

neighbors. 

Thank you for consideration of these comments. If you have any questions regarding New 

Jersey's RACT rules, please contact Margaret Gardner at (609) 292-7095. 

irector 

Division of Air Quality 

Enclosure (1) 

c: Thomas Huynh, Director of AMS 

Diana Esher, Director, Air Protection Division, USEP A Region III 

Joyce E. Epps, Director, Bureau of Air Quality, P ADEP 

Jane Herndon, Assistant Commissioner, NJDEP, Environmental Management 

Chris Salmi, Assistant Director, NJDEP, Air Quality Planning 

Francis Steitz, Assistant Director, NJDEP, Air Quality Permitting Program 

Margaret Gardner, Environmental Engineer 3, NJDEP, Air Quality Permitting Program 
Comparison of NJ NOx RACT Emission Limits and AMS Proposed Source-Specific NOx 

RACT Emission Limits for Existing Units that Generate Electricity 

A. No.6 Fuel Oil-Fired Boilers 

1. NJ Limit- 0.20 lb/MMBtu1

'

2 (daily limit during ozone season) 

2. Veolia- Edison Station, P A, four boilers 

Philly Limit - 0.50 lb!MMBtu each 

3. Veolia- Schuylkill Station, two boilers 

Philly Limits - 0.35 lb/MMBtu and 0.36 lb/MMBtu, respectively 

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

1. NJ Limit- 0.16 lb/MMBtu1

•

3 

2. Exelon- Richmond Station, two turbines 

Ph illy Limit - 0. 7 lb!MMBtu 

3. Exelon- Delaware Station, four turbines 

Philly limit- None 

4. Exelon- Schuylkill Station, two turbines 

Ph illy limit- None 

1 On and after May 1, 2015 2 Conversion from 2.00 lb/ MWh 3 Conversion from 1.60 lb/ MWh