# 8'**~:~~~!~~E~A~~O~CTION** SECRETARY February 18, 2015

Mr

. Shawn M. Garvin Regional Administrator U.S. Environmental Protection Agency, Region III 1650 Arch Street, (Mail Code: 3RAOO) Philadelphia, PA 19103-2029 Dear Mr. Garvin: Enclosed for your approval are revisions to the Philadelphia County Portion ofthe Commonwealth ofPennsylvania's State Implementation Plan (SIP) pertainingto 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 submittedto the United States Environmental Protection Agency (EPA) bythe Department ofEnvironmental Protection (DEP) onbehalfofthe City ofPhiladelphia's Department ofPublic Health, Air Management Services (PhiladelphiaAMS). PhiladelphiaAMS is a local air pollution control program thathas been approved byDEP in accordance with Section 12(b) ofthe Pennsylvania Air Pollution Control Act to administer and enforce a local air pollution control program within itsjurisdiction. On December 13,2013, the EPA conditionally approved 1997 8-hour ozone RACT determinations provided in the 2006 and 2010 SIP revisions for Philadelphia County (78 FR75902). EPA's approval was based upon a commitment from Philadelphia AMS to submit additional SIP revisions to provide source-specific RACT determinations for certain major sources ofVOC and NOx in Philadelphia. The SIP submittal must also include a certificationthat previously adopted source-specific RACT controls approved bythe EPA in Pennsylvania's SIP (codified in 40 CFR 52.2020(d)(l)) for the I-hour ozone NAAQS for the remaining sources in Philadelphia County continue to adequately represent RACT for the 1997 8-hour ozone NAAQS. In order to fulfill the conditions ofapproval, PhiladelphiaAMS forwarded additional RACT determinations to DEP for the 1997 8-hour ozone RACT demonstration. I have enclosed, for your convenience and reference, a listing ofthe affected major sources for this RACT demonstration (Enclosure 1). The RACT determinations inPhiladelphia County for the 1997 8-hour ozone NAAQS are provided inAppendix A (relating to PhiladelphiaAMS SIP Reyision Tracking Number 20140626) and Appendix B (relating to PhiladelphiaAMS SIP Revision Tracking Number 20140918). The SIP submittal includes a certificationthat certain source-specific RACT controls ofmajor sources in Philadelphiapreviously approved by the EPA in Pennsylvania's SIP under the I-hour ozone NAAQS continue to adequately represent RACT for the 1997 8-hour ozone NAAQS. Additionally, the submittal includes a certificationthat

Rachel Carson State Office Building I P,O, Box 2063 I Harrisburg, PA 17105-2063 717,787,2814 

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### f.6(9 www.depweb.state.pa.usMr. Shawn M. Garvin

- 2- February 18, 2015

certain sources are currently minor sources or have shut down and are therefore not subjectto the 1997 8-hour ozone RACTrequirements. Please note that the documentation for Kinder Morgan Liquid Terminals includes a copy ofa copyrighted and confidential vendor quote for the John Zink® Marine Vapor Combustion System. Consistent with EPA guidance, the confidential business information is redacted in the enclosed copy. The JohnZink® Marine Vapor Combustion System document should not be uploaded to the Federal Document Management System. This SIP submittal includes one paper copy ofthe documents listed in the Tables ofContents for the appendices. The submission also includes one compact disc ofelectronic files that are exact duplicates ofthe paper copy documents, including a copy ofthe signed and dated transmittal letter.

- I also certify that the public participationrequirements of40 CFR § 51.102 were met for this SIP submittal including PhiladelphiaAMS SIP Revision TrackingNumbers 20140626 and 20140918. The Commonwealth also followed all ofthe applicable procedural requirements of the state's laws and constitution in conducting and completing the adoption and issuance ofthe SIP revisions. Thank you for your attention to this matter. Should you have questions regarding this submission, please contact Joyce E. Epps, Director ofthe Bureau ofAir Quality, bye-mail at jeepps@pa.gov orby telephone at 717.787.9702. You may also contact Thomas Huynh, Director, PhiladelphiaAirManagement Services, bye-mail atthomas.huynh@phila.gov orby telephone at 215.685.7584. Sincerely,

QUIgley Acting Secretary Enclosures