pennsylvania 

DEPARTMENT OF ENVIRONMENTAL PROTECTION 

SECRETARY 

June 27, 2014 

Mr. Shawn 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 is a revision to the Philadelphia County Portion of the 

Commonwealth of Pennsylvania's State Implementation Plan (SIP). This SIP revision pertains 

to the source-specific Reasonably Available Control Technology (RACT) determination for 

seven heaters at Philadelphia Energy Solutions Refining and Marketing LLC (PES) in 

Philadelphia (formerly Sunoco Philadelphia Refinery) for the 1997 8-hour ozone National 

Ambient Air Quality Standard (NAAQS). This SIP revision is being submitted to the 

U.S. Environmental Protection Agency (EPA) for approval in accordance with Section 110 of 

the Clean Air Act, 42 U.S.C.A. § 7410. 

On April 17, 2013, Philadelphia Air Management Services (AMS) submitted a letter to EPA 

committing to submit additional SIP revisions to provide source-specific RACT determinations 

for certain major sources of volatile organic compounds and oxides of nitrogen in Philadelphia 

County and a certification that source-specific RACT controls previously adopted under the 

I-hour ozone NAAQS for the remaining sources continue to adequately represent RACT for the 

1997 8-hour ozone NAAQS. The commitment resulted in EPA's conditional approval of 

Philadelphia County's 1997 8-hour ozone RACT demonstration (78 FR 75902; 

December 13,2013). The enclosed SIP submittal concerning the "updated RACT 

determinationlRACT plan approval" for seven heaters at PES is the first of several sourcespecific RACT SIP revisions that AMS will forward to DEP for processing and submittal to your 

agency. 

Philadelphia AMS is part of a local health agency that is provided its enabling authority by 

Title 3, Air Management Code, whose powers and duties include the enforcement of laws 

relating to public health within the City of Philadelphia. 

I have enclosed one hard copy and one compact disc copy of the entire submittal. The SIP 

revision includes the Plan Approval Application, RACT analysis, proof of publication, the 

P A Bulletin notice, notification to neighboring states, the public hearing transcript, the comment 

and response document, the Plan Approval, and Statement of Basis. I certify that the electronic 

files are exact duplicates of the hard copies. 

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

717.787.2814 r:AJ. Printed on Recycled Paper \6'"fJ www.depweb.state.pa.us 
Mr. Shawn Garvin - 2-

The Commonwealth followed all of the applicable procedural requirements of the 

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

the SIP revision. 

Thank you for your attention to this matter. Should you have any questions concerning this SIP 

revision, 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, Air Management Services, Philadelphia Department of Public Health, bye-mail at 

thomas.huynh@phila.gov or by telephone at 215.685.7584. 

Sincerely, 

E. Christopher Abruzzo 

Secretary 

Enclosures