April 26 , 20 16 

Mr. Shawn M. Garvin 

Regional Administrator 

U.S. Environmental Protection Agency, Region III 

1650 Arch Street, (Mail Code: 3RAOO) 

Philadelphia, PA 19103-2029 

Dear i-b~fn:

RECEIVED 

APR 2 h 2016 

EPA. hEGJO:-.: ]II 

OFFICEOI·JH:.GIONAL All:~ I!,\'"· I i~ATOI: 

Enc losed for your approval are revisions to the Phi ladelphia County Portion of the Commonwealth of 

Pennsylvania's State Implementation Plan (SIP) pertaining to the Clean Air Act requirements for 

Reasonably Available Control Technology (RACT) for the 1997 8-hour ozone National Ambient Air 

Quality Standard (NAAQS). The revisions are being submitted to the United States Environmental 

Protection Agency (EPA) by the Pennsylvania Department of Environmental Protection (DEP) on 

behalf of the City of Philadelphia's Department of Public Health, Air Management Services 

(Philadelphia AMS). Philadelphia AMS is a local air pollution control program that has been 

approved by DEP in accordance with Section 12(b) ofthe Pennsylvania Air Poll ution Control Act to 

administer and enforce the program, in Philadelphia County. 

On December 13, 20 13, the EPA conditionally approved Philadelphia's RACT demonstration for the 

1997 8-hour ozone NAAQS as provided in two separate revisions to the Pennsylvania State 

Implementation Plan (SIP) submitted to EPA on September 13, 2006 and June 17, 20 I 0 (78 FR 

75902). This approval was conditioned upon a commitment by Philadelphia AMS to submit 

add itional SIP revisions to provide source-specific RACT determinations for spec ific major sources 

of volatile organic compounds (VOC) and nitrogen oxides (NOx) in Philadelphia. In addition, the 

Sl P submittal must include a certification that previously adopted source-specific RACT controls for 

certain sources in Philadelphia that were approved by EPA in Pennsylvania's SIP under the 1-hour 

ozone NAAQS (as listed in 40 CFR 52.2020(d)(1)) continue to adequately represent RACT for the 

1997 8-hour ozone NAAQS. 

In an effort to satisfy this commitment to EPA, the DEP submitted SIP rev isions to EPA on June 27, 

2014, and February 18, 2015, on behalf of Philadelphia AMS, to satisfy RACT requirements for the 

1997 8-hour ozone NAAQS. The June 27, 2014, SIP revision provided source-specific RACT 

determinations for seven heaters at Philadelphia Energy Solutions Refining and Marketing, LLC 

(PES). The February 18, 20 15, submittal included two RACT SIP revisions including Phi ladelphia's 

source-specific RACT determinations for all major VOC and NOx ~o urces (including additional 

emissions units in PES) and a certification that previously adopted source-specific RACT controls 

approved by EPA in Pennsylvania's SIP under the 1-hour ozone NAAQS for certain sources 

continue to adequately represent RACT for the 1997 8-holll· ozone NAAQS. The February 18, 2015, 

SIP revision also included a certification that certain sources that were subject to RACT for the Ihour ozone NAAQS are now minor sources or shutdown sources that are no longer subject to RACT 

for the 1997 8-hour ozone NAAQS. The February 18, 2015, SIP submittal included revised RACT 

Plan Approvals for certain faci lities to be incorporated into the Philadelphia County portion of the 

Commonwealth's SIP. * 

Rachel Carson State Office Building I P.O. Box 2063 I Harrisburg, PA 17105-2063 

717.787.2814 Pnnted on Recycled Paper@ www .dep.pa.gov 
Mr. Shawn M. Garvin - 2 - Apri l 26 , 2016 

Philadelphia AMS recently submitted to OEP revisions to the February 18, 2015, SIP submittal in 

order to revise de minimis detem1inations and the case-by-case RACT analysis for certain sources. 

The enclosed SIP revision (Philadelphia 1\MS SIP Revision Tracking Number20 1508 12) provides 

revised technical memoranda, revised and new RACT Plan Approvals for certain major NOx and 

VOC sources previously addressed in the February 18, 20 15, Sl P revision (see enclosed letter). This 

submittal also includes a memorandum providing clarifying RACT certifications and de minimis 

determinations for the 1997 ozone NAAQS. The revised documents provided in this Sl Prevision are 

intended to supersede the documentation provided in previous RACT SIP submitta ls. The enclosed 

SIP revision addresses the following major NOx and VOC facilities in Philadelphia County: (I) 

Philade lphia Energy Solutions Refining and Marketing, LLC (Plant ID-01501) (excluding the 7 

heaters previously addressed); (2) Honeywell Internationa l- Frankford Plant (Plant I 0-0 1551 ); (3) 

Sun Chemical (Plant ID-02052); (4) Allied Tube & Conduit Corporation (Plant 10-03363); (5) 

Cardone Industries (Plant IDs-03887,02287); (6) Exelon Generating Company - Richmond Station 

(Plant ID-04903); (7) Veolia Energy - Schuylkill Station (Plant 10-04942); (8) Kinder Morgan (Plant 

10-05003); (9) MIPC LLC- Philadelphia Terminal (Plant ID-05004); (I 0) Plains Products Terminal 

LLC (Plant 10-050 13); ( II ) University of Pennsylvania (Plant 10 -0891 2); ( 12) Philadelphia Prison 

System (Plant 10-095 19); ( 13) Navy Foundry and Propeller Center (Pl ant ID-09702); ( 14) Naval 

Surface Warfare Center Carderock Division (Plant 10-09724); and ( 15) Veolia-Energy Efficiency 

(PA), LLC (Plant ID-1 0459). Table I of the enclosed SIP Revision (Philadelphia AMS SIP Revision 

Tracking Number 20 15081 2) provides a summary of the updated documentation. 

Philadelphia AMS provided a public comment period for this Sl Prevision from August 12, 20 15, to 

September 30, 2015. A public hearing was held on September 17, 2015. The written comments and 

testimony provided during the public hearing are addressed in the SIP revision. 

I certify that the public participation requirements of 40 CFR § 51.102 were met for this 

SIP submittal and that Philadelphia AMS followed all of the applicable procedural requirements of 

the Commonwealth's laws and constitution in conducting and completing the enclosed SIP revision. 

A paper copy of each document and a compact disc containing electronic copies are enclosed. I 

further certify that the electronic files are exact duplicates of the hard copies of the documents. 

Thank you in advance for the expedited processing of the enclosed SIP revision. Please contact 

Joyce E. Epps, Director of the Bureau of Air Quality, by e-mail atjeepps@pa.gov or by telephone at 

7 17.787.9702, if necessary. You may also contact Kassa hun Sellassie, Acting Director, Philadelphia 

Air Management Services, by e-mail at kassahun.sellassie@phila.gov or by telephone at 

215.685.7584. 

Sincerely, 

John Quigley 

Secretary 

Enclosures