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 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 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) of the Pennsylvania 

Air Pollution Control Act to administer and enforce a local air pollution control program within 

its jurisdiction. 

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 FR 75902). 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 

certification that previously adopted source-specific RACT controls approved by the 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 of approval, Philadelphia AMS forwarded additional RACT 

determinations to DEP for the 1997 8-hour ozone RACT demonstration. I have enclosed, for 

your convenience and reference, a listing of the affected major sources for this RACT 

demonstration (Enclosure 1). The RACT determinations in Philadelphia County for the 

1997 8-hour ozone NAAQS are provided in Appendix A (relating to Philadelphia AMS SIP 

Reyision Tracking Number 20140626) and Appendix B (relating to Philadelphia AMS SIP 

Revision Tracking Number 20140918). The SIP submittal includes a certification that certain 

source-specific RACT controls of major sources in Philadelphia previously 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 certification that 

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

717,787,2814 ro Printed on Recycled Paper f.6(9 www.depweb.state.pa.us 
Mr. Shawn M. Garvin - 2- February 18, 2015 

certain sources are currently minor sources or have shut down and are therefore not subject to the 

1997 8-hour ozone RACT requirements. 

Please note that the documentation for Kinder Morgan Liquid Terminals includes a copy of a 

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 John Zink® Marine Vapor Combustion System document should not be 

uploaded to the Federal Document Management System. 

This SIP submittal includes one paper copy of the documents listed in the Tables of Contents for 

the appendices. The submission also includes one compact disc of electronic files that are exact 

duplicates of the paper copy documents, including a copy of the signed and dated transmittal 

letter. -

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

SIP submittal including Philadelphia AMS SIP Revision Tracking Numbers 20140626 and 

20140918. The Commonwealth also followed all of the applicable procedural requirements of 

the state's laws and constitution in conducting and completing the adoption and issuance of the 

SIP revisions. 

Thank you for your attention to this matter. Should you have questions regarding this 

submission, please contact Joyce E. Epps, Director of the Bureau of Air Quality, bye-mail at 

jeepps@pa.gov or by telephone at 717.787.9702. You may also contact Thomas Huynh, 

Director, Philadelphia Air Management Services, bye-mail at thomas.huynh@phila.gov or by 

telephone at 215.685.7584. 

Sincerely, 

QUIgley 

Acting Secretary 

Enclosures