From: Henry Kim

To: "jeeps@state.pa.us"; "ali.mirzakhalili@state.de.us"; "bill.o"sullivan@dep.state.nj.us";

"gaburn@mde.state.md.us"; "esher.diana@epa.gov"

Cc: Thomas Huynh; Edward Wiener; Fernandez, Cristina; "Dalal, Kirit"

Bcc: Henry Kim; Ramesh Mahadevan; JiaZheng Li

Subject: Public Hearing Notice: Plan Approval and 8-hour Ozone RACT SIP Revision for 7 heaters at Philadelphia Energy

Solutions

Date: Tuesday, December 17, 2013 3:03:00 PM

All.

Sorry for the delay in sending out this notice.

This e-mail is written per 40 CFR §51.102(d) and is to inform you of a public notice issued

December 2, 2013, in the Philadelphia Daily News concerning notice of intent to approve the

increase of heat input capacity limits of 7 heaters at Philadelphia Energy Solutions and a proposed

revision to the state implementation plan to meet the requirements of reasonably available control

technology (RACT) set forth by the Clean Air Act (CAA) under the 8-hour ozone NAAQS.

Philadelphia Energy Solutions Refining and Marketing LLC (PES), formerly Sunoco, Inc. (R&M), (3144

Passyunk Ave. Phila., PA 19145) has submitted a plan approval application to replace hourly heat

input capacity limits on seven (7) heaters with annual heat input limits and install Ultra Low-NOx

Burners (ULNBs) on two (2) of the heaters. The heaters are limited to refinery fuel gas with

individual heat input limits that combine to 730.6 MMBTU/hr. The proposed annual heat input

limits total 6,806,000 MMBTU per rolling 12-month period. The increase in potential emissions in

the application due to the project are 140.1 tons of Nitrogen Oxides (NOx), 23.2 tons of Volatile

Organic Compounds (VOCs), 13.2 tons of both Particulate Matter with a diameter of 10

micrometers or less (PM10) and Particulate Matter with a diameter of 2.5 micrometers or less

(PM2.5), 191.6 tons of Carbon Monoxide (CO), 7.1 tons of Sulfur Dioxide (SO2), and Greenhouse

Gases (GHGs) of 255,372 metric tons Carbon Dioxide equivalent CO2e), all on a rolling 12-month

basis. The plan approval will contain work practice, testing, monitoring, recordkeeping, and

reporting requirements to ensure operation within all applicable requirements.

The proposed changes to the following are also intended to meet the reasonably available control

technology (RACT) requirements of the Clean Air Act (CAA) for the 1997 8-hour ozone National

Ambient Air Quality Standard (NAAQS): the removal of the MMBTU/hr heat input limit for each

heater, the addition of MMBTU heat input and NOx emission limits per rolling 12-month period

limit for each heater, the requirement to burn only refinery fuel gas for each heater, and the

installation of the addition of ULNBs on two heaters. A more detailed description and analysis can

be found in the Statement of Basis. The CAA requires Phila. to submit to the US Environmental

Protection Agency (EPA) a State Implementation Plan (SIP) revision demonstrating that Phila. has

implemented all necessary Reasonably Available Control Technology (RACT) controls on all major

stationary sources of volatile organic compounds (VOC) and oxides of nitrogen (NOx).In 2006, Air

Management Services (AMS) developed a RACT SIP revision demonstrating that it implemented

required RACT controls on all relevant stationary sources of VOC and NOx emissions and that all

RACT plans previously approved by EPA under the 1-hour ozone NAAQS were applicable to

represent RACT control levels under the new 8-hour ozone NAAQS. The SIP revision relied on the
NOx SIP Call emissions trading program. On July 10, 2009, the D.C. Circuit Court determined that

the NOx SIP Call did not meet the specific source RACT requirements as required by the CAA.

Accordingly, any air pollution source installed prior to the adoption of the 1997 8-hour Ozone

NAAQS that was applicable to the NOx SIP Call and did not have to install any controls in the

original case-by-case RACT must now conduct a new case by-case RACT determination to address

any changes in technologies that occurred since the prior 1-hour Ozone NAAQS was adopted and

implemented. Therefore, this notice is also intended to propose as a revision to the Phila. portion

of the PA SIP changes to NOx RACT controls for the seven (7) modified heaters in PES. For each of

these heaters RACT is determined to be annual emission limits, throughput limits, refinery fuel gas

burning, and, for two heaters, installation of ULNBs, as described above.

Copies of all documents and information concerning this plan approval and SIP revision are

available for review in the offices of AMS, Rm 218, 321 University Ave., Phila., PA 19104-4543

during normal business hours. Persons wishing to review these documents or to submit written

comments should contact Ms. Karen Smith (215-685-7572) at the above address. All written

comments must be received by January 3, 2014. Comments received by facsimile will not be

accepted. If requested, the Phila. Dept. of Public Health, (AMS) will conduct a public hearing to

receive comments on the preliminary determination to approve the application (Plan Approval No.

12195) at the following time and location:

Date: Monday, January 13, 2014

Time: 7:00 p.m.

Location: Mercy Wellness Center (2nd Floor)

2821 S. Island Avenue

(Island Ave. & Lindbergh Blvd.)

Philadelphia, PA 19153

Persons wishing to request a public hearing must submit the request in writing to Source

Registration, Air Management Services, 321 University Ave., Phila., PA 19104-4543 by January 3,

2014. If AMS does not receive any requests for a public hearing by this date, it will be cancelled. To

find out if the public hearing will be held, please visit the AMS web site at

http://www.phila.gov/health/ AirManagement/index.html or call AMS at 215-685-7572

____________________________________________________________

Henry Kim

Chief, Program Services

Air Management Services | Department of Public Health | City of Philadelphia

321 University Ave. Philadelphia, PA 19104

Phone: 215-685-9439 | Fax: 215-685-7593

E-mail: henry.kim@phila.gov