CITY OF PHILADELPHIA 

APR 2 :~. 2013 

EPA. REGION Ill 

omCEOFREGIONAL APMINISTRATOR 

Honorable Shawn M. Garvin 

Regional Administrator 

U.S. Environmental Protection Agency, Region III 

1650 Arch Street, Mail Code 3RAOO 

Philadelphia, Pennsylvania 19103-2029 

Honorable E. Christopher Abruzzo 

Acting Secretary 

Department of Environmental Protection 

Bureau of Air Quality 

Rachel Carson State Office Building 

P.O. Box 2063 

Harrisburg, Pennsylvania 17105-2063 

Dear Regional Administrator and Acting Secre~ary: 

DEPARTMENT OF PUBLIC HEALTH 

Donald F. Schwarz, MD, MPH 

Deputy Mayor for Health & Opportunity 

Health Commissioner 

Nan Feyler, JD, MPH 

Chief of Staff 

Air Management Services 

Thomas Huynh 

Director 

321 University Avenue, 2nd Floor 

Philadelphia, P A 19104 

Telephone (215) 685-7586 

Fax (215)685-7593 

April 17, 2013 

The Pennsylvania Department ofEnvironmenta1 Protection (DEP) has submitted to the U.S. 

Environmental Protection Agency (EPA), on behalf of the City of Philadelphia Department of 

Public Health, Air Management Services (Alv.lS)i various revisions to the Commonwealth of 

Pennsylvania's State Implementation Plan (SIP) ,in order to meet the Reasonably Available 

Control Technology (RACT) requirements for the 1997 8-hour Ozone National Ambient Air 

Quality Standard (NAAQS) set forth in the Clean Air Act for Philadelphia County. 

Through this letter, AMS is committing to submit, for EPA's r<::view, revisions to the 

Commonwealth of Pennsylvania's SIP addressing Philaddp'1ia County's 8-hour RACT 

requirements specified below as expeditiously as practicable, but no later than twelve months 

from the date EPA gives final, conditional approval ofthe 8-hour Ozone RACT SIP for 

Philadelphia County. The revisions to the 8-hour Ozone RACT SIP for Philadelphia County will 

consist of the following: 

• Source-specific RACT detem1inations for the 8-hour Ozone NAAQS, to be incorporated 

in operating pennits, for the following clectr:c generating units (EGUs) in Philadelphia 
County that had previously relied on emissions reductions from EPA's Nitrogen Oxide 

(NOx) SIP Call Rule: 

o Exelon- Delaware Station 

o Exelon- Richmond Station 

o Exelon - Schuylkill Station 

o Veolia- Edison Station (formerly Trigen- Edison Station) 

o Veolia- Schuylkill Station (formerly Trigen- Schuylkill Station) 

• Source-specific RACT determinations for the 8-hour Ozone NAAQS , to be incorporated 

in operating permits, for the following non-EGUs in Philadelphia County: 

o Philadelphia Energy Solutions Refinery (fonnerly Sunoco Refinery) 

o Kraft Nabisco (formerly Nabisco Biscuit Company) 

o Temple University, Health Sciences Center 

o GATX Terminals Corporation 

o Honeywell (formerly Sunoco Chemicals, Frankford Plant) 

• Certification that the previously adopted source-specific RACT approved by EPA in the 

Commonwealth ofPennsylvania's SIP under the 1-hour Ozone NAAQS for the 

remaining facilities in Philadelphia County (as listed in 40 CFR 52.2020(d)(l)) continues 

to adequately represent RACT for 8-hour Ozone NAAQS. See Final Rule To Implement 

the 8-Hour Ozone National Ambient Air Quality Standard--Phase 2, 70 Fed. Reg. 71612 

(Nov. 29, 2005). 

AMS understands that this commitment will result in a conditional approval by EPA ofthe 

previously submitted 8-hour Ozone RACT SIP for Philadelphia County. Upon EPA's approval 

of the SIP revisions satisfying the rulema\9.ng commitments, EPA's conditional approval to the 

8-hour ozone RACT SIP for Philadelphia County will become a full approval. 

AMS also requests that DEP submit a copy of this letter, as well as any future revisions to 

Philadelphia County's 8-hour Ozone RACT SIP addressing these rulemaking commitments, to 

EPA on our behalf. 

Thank you for your support of our mission to a~ hi eve cleaner ·air in Phila4elphia Ccunty. Shouid 

you have any questions, please do not hesitate to contact me at 215-685-7584 or 

Thomas.huynh@phila.gov. 

Sincerely, 

Thomas Hu 1h, Director 

City of Philadelphia, Department of Public Health 

Air Management Services 
Enclosures 

cc: Nan Feyler, Chief of Staff 

Patrick O'Neill, Divisional Deputy City Solicitor