# CITY OF PHILADELPHIA

APR 2**:~.** 

## 2013

EPA. REGION Ill omCEOFREGIONALAPMINISTRATOR

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 ofEnvironmental Protection Bureau ofAir Quality Rachel Carson State Office Building P.O. Box 2063 Harrisburg, Pennsylvania 17105-2063

DearRegional Administrator and Acting**Secre~ary:** DEPARTMENT OF PUBLIC HEALTH Donald F. Schwarz, MD, MPH DeputyMayor 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 PennsylvaniaDepartment ofEnvironmenta1Protection (DEP) has submitted to the U.S. Environmental Protection Agency (EPA), onbehalfofthe City ofPhiladelphiaDepartment of Public Health, AirManagement Services (Alv.lS)i various revisions to the Commonwealth of Pennsylvania's State ImplementationPlan (SIP),in orderto 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. Throughthis letter, AMS is committing to submit, for EPA's r<::view, revisions to the Commonwealth ofPennsylvania's SIP addressing Philaddp'1ia County's 8-hourRACT requirements specifiedbelow as expeditiously as practicable, but no later thantwelve 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 ofthe following:

• Source-specific RACT detem1inations for the 8-hour OzoneNAAQS, to be incorporated in operatingpennits, for the following clectr:c generating units (EGUs) in PhiladelphiaCounty that hadpreviouslyrelied on emissions reductions from EPA'sNitrogen 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 operatingpermits, for the following non-EGUs in Philadelphia County:

o Philadelphia Energy Solutions Refinery (fonnerly Sunoco Refinery) o KraftNabisco (formerlyNabisco 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 byEPA in the Commonwealth ofPennsylvania's SIP under the 1-hour Ozone NAAQS for the remaining facilities inPhiladelphia 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 byEPA ofthe previously submitted 8-hour Ozone RACT SIP for Philadelphia County. Upon EPA's approval ofthe SIP revisions satisfying the rulema\9.ng commitments, EPA's conditional approval to the 8-hour ozone RACT SIP for Philadelphia Countywill become a full approval. AMS also requests that DEP submit a copy ofthis letter, as well as any future revisions to Philadelphia County's 8-hour Ozone RACT SIP addressing these rulemaking commitments, to EPA on ourbehalf. Thank you for your support ofourmission to**a~**hieve 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 ofPhiladelphia, Department ofPublic Health Air Management Services

### Enclosures

cc: Nan Feyler, ChiefofStaff Patrick O'Neill, DivisionalDeputy City Solicitor