UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION Ill 

1650 Arch Street 

Philadelphia, Pennsylvania 19103-2029 

Ms. Karen Smith 

Air Management Services 

Department of Public Health 

City of Philadelphia 

321 University Avenue, 2nd Floor 

Philadelphia, Pennsylvania 19104 

Dear Ms. Smith: 

OCT :.16 2014 

Thank you for the opportunity to comment on the proposed "Reasonably Available 

Control Technology (RACT) State Implementation Plan (SIP) Revision under the 1997 8-Hour 

Ozone National Ambient Air Quality Standard (NAAQS)," published on September 18,2014. 

The U.S. Environmental Protection Agency (EPA) comments are provided in the enclosure to 

this letter. 

We look forward to working with you to resolve these comments. Please do not hesitate 

to contact me, or have your staff person contact Ms. Emlyn Velez-Rosa, (215) 814-2038 of my 

staff for any questions pertaining to these comments. 

Enclosure 

cc: Thomas Huynh, Director 

Edward Wiener, Chief, Source Registration 

Henry Kim, Chief, Program Services 

Sincerely, 

//Li Acting Director 

Air Protection Division 

0 Printed on I 00% recycled/recyclable paper with I 00% post-consumer fiber and process chlorine free. 

Customer Service Hotline: 1-800-438-2474 
U.S. Environmental Protection Agency's (EPA's) Comments to Philadelphia Air 

Management Services (AMS) Proposed "Reasonably Available Control Technology 

(RACT) State Implementation Plan (SIP) Revision under the 1997 8-Hour Ozone National 

Ambient Air Quality Standard (NAAQS)," Published on September 18,2014 

General Comments Applicable to All Facilities: 

1. In the proposed SIP Revision, a cost effectiveness "benchmark" of $2,500 per ton of 

nitrogen oxides (NOx) reduced was used as a maximum cost effectiveness cut-off in 

evaluating source-specific RACT. AMS has not provided a cost-effectiveness 

benchmark for volatile organic compounds (VOC) RACT. In determining NOx and VOC 

RACT comparable cost-effectiveness levels, EPA believes that it is appropriate to focus 

on a range of cost effectiveness. The range is appropriate due to the variability of the 

actual cost effectiveness that is expected from unit to unit. In general, the actual cost and 

emission reductions achieved from the implementation of controls on an individual 

source, and consequently the cost-effectiveness levels, will vary from unit to unit, 

because the emission sources themselves vary in age, condition, and size, among other 

considerations. See EPA's detailed rationale in its March 16, 1994 memorandum "CostEffective Nitrogen Oxides (NOx) Reasonably Available Control Technology (RACT)." 1 

Thus, EPA strongly cautions AMS not to rigidly apply a benchmark to exclude 

consideration of technically feasible controls, but should rather consider a broader range 

of cost effectiveness to see if some level of additional control falls within that range. 

Additionally, EPA notes that other nearby states have adopted recent NOx RACT limits 

with far higher average cost effectiveness than $2,500 per ton. For instance, New York 

State estimated that the proposed NOx limits to take effect in 2015 would have an average 

cost effectiveness ranging from $2,600 to $5,463 per ton (Proposed revisions to Subpart 

227-2 published in the NYS Register on December 23, 2009).2 New York State 

Department of Environmental Conservation (NY DEC) started with a higher cost 

effectiveness threshold for NOx RACT of$3,000 per ton (in 1994 U.S. dollars) over 

which an "emission source ofVOC or NOx will not be required to implement any 

emission reduction or control strategy that is more costly than the established threshold 

adjusted over time for inflation."3 Using the Bureau of Labor Statistics "Consumer Price 

Index (CPI) inflation calculator," NY DEC determined that $3,000 in 1994 equates to 

$4,638 in 2012, which was then rounded up to $5,000 to ensure a level of conservatism.4 

AMS should justify the appropriateness ofthe NOx cost-effectiveness level used in the 

1 Available at hitp://www.er.a.gov/tto/caaa/t 1/memoranda/costcon.pdf. 

2 A copy ofNew York's proposed rule is docketed at www.regulations.gov as an attachment to document EPA-R02-

0AR-2013-0l80-0004 in docket EPA-R02-0AR-2013-0l80. 

3 DAR-20: Economic and Technical Analysis for Reasonably Available Control Technology (RACT) Networks, 

Effective October 18,2013, available on-line at http://www.dec.ny.go /chemical/91851 .hllnl. Applying the BLS 

"CPI inflation calculator" to adjust $3,000 in 1994 dollars to 1990 dollars will yield $2,645 per ton. Also, $1,500 in 

1990 dollars is equivalent to $1,700 in 1994 dollars. 

4 Id. 

1 
source-specific RACT evaluations and indicate the applicable VOC cost-effectiveness 

level used, if any. AMS should consider in this justification the NOx cost-effectiveness 

levels established by nearby states. 

Finally, while cost effectiveness, as described above, is an important consideration, it 

must be noted that other factors should be integrated into a RACT analysis, such as 

emission reductions and environmental impact, among others. 

2. In proposing source-specific RACT limitations under 25 Pa Code 129.91-94, AMS needs 

to ensure that the requirements· are practically enforceable, by including specific emission 

limits and independently enforceable operating restrictions, short-term averaging times 

(no more than 12-month rolling), and monitoring, record keeping, and any other 

compliance requirements sufficient to determine compliance. 

EPA believes short-term averaging is appropriate for RACT and any proposed RACT 

emissions limits should include this consideration. Because compliance with the 1997 8-

hour ozone national ambient air quality standard (NAAQS or standard) is determined 

over an 8-hour period, EPA has preferred RACT emission standards for the ozone 

NAAQS to be based upon a short-term time period, such as daily or 24-hour rolling 

average basis, although typically a 30-day rolling average emission rate (as an average of 

all hourly data for the proceeding 30 operating days) has been approved as an acceptable 

averaging period for NOx RACT (57 FR 55620, November 25, 1992). 

3. In accordance with the source-specific RACT requirements of25 Pa Code 129.92(a)(4), a 

RACT proposal must include actual and potential NOx and VOC emissions for each 

affected emissions source and associated supporting documentation. AMS should 

provide potential and actual emissions for each of the emissions sources in each facility 

evaluated for RACT. For each emissions source evaluated, AMS should include or refer 

to any technical and economic data, calculations, methodology, and assumptions relevant 

to the proposed RACT determinations, including any submittals made by the facilities in 

compliance with 25 Pa Code 129.92. 

4. In this proposed SIP revision, AMS is proposing to certify that f'previously adopted 

source-specific RACT controls approved by EPA in the Pennsylvania SIP under the 1-

hour ozone NAAQS continue to adequately represent RACT for the 1997 8-hour ozone 

NAAQS." As part ofthis certification, AMS has provided technical memorandums for 

each facility evaluating the technical and economic feasibility of implementing additional 

available controls as RACT for emissions sources that is subject to Pennsylvania's 

source-specific RACT requirements un,der 25 Pa Code 129.91-94. 

EPA has long defined RACT as the "lowest emission limitation that a particular source is 

capable of meeting by the application of control technology that is reasonably available 

considering technological and economic feasibility" (57 FR 55620 at 55624, November 

25, 1992, both citing 44 FR 53761 at 53762, September 17, 1979). Thus, to support this 

certification, AMS should also demonstrate that the level of any proposed emissions rate 

as RACT represents the lowest emissions limitation that is currently feasible for that 

particular emissions source. This demonstration would also apply to any emissions limits 

2 
that have already been approved as RACT under the 1-hour ozone standard, in order to 

properly evaluate whether these limits continue to adequately represent RACT for an 

emissions source. Accordingly, AMS would need to revise any previously approved 

RACT emission limitation that currently does not represent the lowest reasonably 

achievable rate to a more stringent level of emissions to satisfy RACT under the 1997 8-

hour standard. Such revisions would be consistent with the anti-backsliding requirements 

of Clean Air Act (CAA) section 11 0(1). 

As part of this demonstration, EPA recommends relying on actual emissions ofNOx 

and/or VOC for each emissions source subject to source-specific RACT. In general, cost 

considerations should not be necessary for evaluating the appropriateness of existing 

RACT emissions limits, as EPA does not anticipate that updating the emissions limits 

would have a significant economic impact to the facility. 

5. AMS is also proposing to certify that certain facilities that were applicable to RACT 

requirements under the 1-hour ozone standard are not affected sources under RACT for 

the 1997 8-hour NAAQS, because either they are under the applicable "major source" 

thresholds (i.e., minor sources), as defined by EPA, or have shut down. To support this 

certification, AMS has provided a list of "minor" and shutdown facilities in Philadelphia 

(pages 14-15). EPA believes that AMS did not provide sufficient information to evaluate 

the proposed certification. 

EPA believes it is appropriate to provide the following information: AMS should 

provide the potential-to-emit (PTE) of each facility to confirm that certain facilities are 

not major sources. In the case that a facility has taken a facility-wide restriction on PTE 

to be under the applicable RACT major source thresholds, AMS should refer to the 

applicable permit that allows such restriction. For facilities that have shutdown, AMS 

needs to show that these shutdowns are Federally-enforceable for the facility to not have 

to comply with RACT. 

6. AMS is proposing to certify that 25 Pa Code 129.81 continues to represent RACT for the 

1997 8-hour ozone NAAQS, which EPA approved into the Pennsylvania SIP on 

September 28, 1993 (58 FR 50517) to satisfy the RACT requirements under section 

183(f) of the CAA. CAA section 183(f) requires EPA to promulgate VOC RACT 

standards for marine vessel loading and unloading by November 15, 1992. At the time of 

EPA's SIP-approval of regulation 25 P A Code 129.81, EPA had not promulgated yet any 

Federal RACT standards. On September 19, 1995 (60 FR 48388), EPA promulgated 

"National Emission Standards for Marine Tank Vessel Loading Operations," codified at 

40 CPR Part 63, Subpart Y. The rule established RAc:r and maximum available control 

technology (MACT) standards for marine vessel loading. CAA section 183(±)(4) 

provides that state regulations governing VOC emissions from marine tank vessels must 

be at least as stringent as the Federal standard. AMS needs to justify that the RACT 

provisions of25 Pa Code 129.81 are more stringent than the Federal RACT standards of 

40 CR 63, Subpart Y. 

7. In general, whenever a state chooses to revise its SIP, the State must demonstrate that the 

revision would not interfere with air quality goals, in accordance with section 11 0(1) of 

the CAA. Accordingly, for any revisions of SIP-approved RACT control measures, 

3 
AMS must explain how the proposed SIP revision does not interfere with attainment of 

the applicable ozone NAAQS, including both 1-hour ozone standard and the 1997 8-hour 

ozone standard, and any applicable reasonable further progress requirements. In 

evaluating whether a given SIP revision would interfere with attainment or maintenance, 

as required by CAA section 11 0(1), EPA generally considers whether the SIP revision 

. will allow for an increase in actual emissions into the air over what is allowed under the 

existing EPA-approved SIP. Thus, in proposing to modify the SIP-approved 

requirements, AMS must demonstrate that the proposed revision provides equivalent or 

additional emissions reductions, in accordance with CAA section 11 0(1). 

8. AMS has identified various "de minimis" or "insignificant" emissions sources for which 

it has determined that RACT is not an applicable requirement or for which RACT has not 

been determined. AMS must justify why RACT is not applicable to the sources 

identified as "de minimis" in this proposal. 

EPA recognizes that it is possible for certain emissions sources at a major facilities to be 

so small that it would not be reasonable to consider technological and economic 

feasibility and thus to determine RACT. In general, states and local regulatory agencies 

have included exemptions for very small emissions sources in establishing specific 

RACT requirements for source categories. The$e exemptions are generally based on the 

State's determination that the required level of control is generally not reasonable, 

considering technological and economic feasibility, for the affected emissions sources 

under certain size or capacity or whose potential emissions are under certain level (i.e., de 

minimis level). A de minimis level should not be set arbitrarily, but should be 

determined based on technical and economic infeasibility of a determined level of 

control. 

Major sources ofNOx and VOC in Philadelphia for which no other RACT requirement 

has been established are subject to source-specific requirements of25 Pa Code 129.91-

94. Under this regulation, RACT is required to be determined on a case-by-case basis, 

based on the technical and economic feasibility of the available controls for each 

particular emissions source. As stated earlier, feasibility of controls on an individual 

source will vary from unit to unit, because the sources themselves vary in age, condition, 

and size, among other considerations. Thus, EPA believes it would not be appropriate to 

define a general de minimis level ofVOC and NOx, respect~vely, for the vast universe of 

emissions sources that are subject to RACT under 25 Pa Code 129.91-94. EPA 

recommends AMS to not apply a general de minimis level, but to rather establish specific 

de minimis levels for emissions sources that are similar, such that different levels would 

apply to different source categories. In establishing such categories, AMS could consider 

purpose, capacity, emissions levels, and/or operation of the emissions sources. 

Alternatively, EPA believes AMS should evaluate the feasibility of controls on a case-bycase basis, consistent with the RACT requirements of25 PA Code 129.91-94. Any 

determination by AMS for defining de minimis levels ofNOx and VOC, respectively, 

should be provided as a SIP revision for EPA's evaluation. 

9. AMS should consider proposing to revise the SIP to update the names and facility 

4 
information for the sources subject to source-specific RACT requirements under 40 CFR 

52.2020(d)(l) which have changed ownership or name. 

Comments by Facilities 

Philadelphia Energy Solutions (PES) (formerly Sunoco- R&M) 

1. On page 17, AMS states that "PES, including the Tank Farm, is subject to the 1-hour 

RACT determination (P A Permit Numbers 51-1501 and 51-1517) dated August 1, 2000, 

and approved into the SIP by EPA on October 31,2001,66 FR 54942 under the facility's 

former name Sunoco Inc. (R&M) - Philadelphia." This statement is incorrect, since the 

1-hour RACT determination approved by EPA did not address RACT for the Tank Farm. 

2. AMS must provide the actual and potential emissions of each emissions source at PES. 

To support PTE, AMS should specify the most stringent Federally-enforceable 

limitation that applies to each source, and all appropriate assumptions used. 

3. The following existing NOx emissions sources at the refinery, that are subject to the 

presumptive RACT requirements of25 PA Code Sections 129.93(b)(2)-(5), were not 

listed as part ofthe memorandum: Unit 860- 2Hl (49 million British Thermal Unit per 

hour (MMBTU/hr) of heat input rating), Unit 860- 2H6 (36.7 MMBTU/hr), Unit 860-

2H8 (49.6 MMBTU/hr), Unit 864-PH2 (45 MMBTU/hr), Unit 1332 H-1 (45 

MMBTU/hr), Unit 1332 H-3 (43 MMBTU/hr), Unit 1332 H-600 (21 MMBTU/hr), Unit 

1332 H-601 (48 -MMBTU/hr), and Unit 1332 H-602 (49 MMBTU/hr). 

4. AMS explains in the memorandum that PES is subject to a Federally-enforceable 

Consent Decree that restricts PES from burning refinery oil except under certain 

circumstances, including gas curtailments. Because "PES has completely stopped 

burning oil," AMS is proposing to remove from the SIP the NOx emissions limits for 

emission sources burning refinery oil that were approved as RACT under the 1-hour 

ozone NAAQS. In order for EPA to approve the proposed removal ofthe oil emissions 

limits, AMS needs to show that PES (or formerly Sunoco) has taken a Federallyenforceable limit to completely restrict burning refinery oil throughout the facility. 

5. AMS did not provide sufficient information to evaluate the control feasibility analysis 

provided for PES for emissions sources subject to source-specific RACT. AMS did not 

provide justification for determining technical infeasibility of the controls evaluated for 

each emissions source, and did not provide a discussion of the methodology used for 

estimating cost-effectiveness of technically feasible controls. Without this information, 

EPA is unable to properly evaluate the source-specific NOx and VOC RACT 

evaluations provided for the emissions sources at PES. 

6. On pages 20 and 33 of the proposed SIP, AMS explains that PES has submitted a 

RACT proposal to determine source-specific NOx and VOC RACT for the emissions 

sources at the facility. AMS should include the PES submittal as part of the SIP 

revision to further support AMS proposed RACT. 

5 
7. On page 29, AMS states that the potential NOx emissions of the fluid catalytic cracking 

unit (FCCU) 868 are based on the applicable limit of 47,500 barrels per day on a rolling 

365 day-rolling average, while in Table 1, page 18 AMS states a potential capacity of 

50,000 barrels per day. Please clarify. 

8. AMS needs to adequately address RACT for the marine vessel and tank truck loading 

operations at PES. AMS has identified the refinery's "loading operations" at wharf and 

tank truck as VOC emission sources, and has stated that both sources are subject to· the 

RACT requirements of AMR V Section V "Organic Loading Operations." However, 

AMR V Section V only applies to VOC emissions from loading of organic materials 

into tank truck, tank car, or trailers from any loading facility, and is not applicable to 

marine vessel loading operations. Additionally, the PES Title V operating permit (No. 

V95-038) does not list AMR V Section V as an applicable requirement for the tank 

truck loading operations at the refinery. Please clarify. 

9. AMS has not provided potential VOC emissions from the refinery cooling towers nor 

sufficiently evaluated available controls for controlling VOC emissions from the 

towers. 

10. On page 27, AMS proposes NOx·emissions rates as RACT for various heaters and 

boilers in terms of pounds per million British Thermal Units (lb/MMBTU) per rolling 

365-day basis. These limits are essentially annual limits that are measured on a daily 

basis for more stringency. As explained earlier, EPA believes short-term averaging is 

appropriate in setting emissions limits for RACT, typically a 30-day rolling average. 

AMS should provide justification of why these limits adequately represent RACT for 

these emissions sources. 

Honeywelllntemational - Frankford Plant (Formerly SlUloco Chemical- Frankford Plant) 

1. In short, EPA believes AMS has not submitted an adequate analysis to support the 

proposed RACT modification for Boilers 1 and 2. Although the proposed restriction for 

combustion ofNo. 6 fuel oil should result in NOx emissions reduction, AMS must ensure 

that the proposed emissions limitations and fuel restrictions are practically enforceable. 

AMS is proposing revisions to the RACT Plan Approval to remove the ability of Boilers 

1 and 2 to bum No.6 fuel oil, except "ifthere is a natural gas curtailment and other losses 

of supply (e.g. PGW supply line failure or maintenance activity) or during stack testing 

programs (e.g. annual CEM RATA testing, annual combustion tuning, and combustion 

performance testing, as required)." 

AMS should clarify the following: How are supply losses expected to affect the boilers' 

operation? Why should AMS allow the buming of oil during stack testing programs 

when No.6 fuel oil is almost completely excluded? How would this testing result in NOx 

emissions that are representative of the boilers' operations when burning natural gas and 

phenol? 

6 
For this condition to be practically enforceable, AMS must clearly identify the specific 

circumstances in which the facility would be allowed to bum No.6 oil in Boilers 1 and 2. 

To show compliance with this requirement, EPA also believes the facility should be 

required to record and timely notify AMS when these events occur. 

AMS is proposing to establish a fuel restriction based on annual heat input: "Honeywell 

shall operate Boiler 1 and Boiler 2 each on waste phenol residue and natural gas 

combined 51% or greater." EPA finds that this condition is not practically enforceable 

and that is inconsistent with the proposed restriction of combusting No.6 fuel oil. 

The proposed condition does not specify that the limit applies to annual heat input based 

on BTU. The proposed condition does not establish specific heat input limits for each of 

the fuels, but a combined limit for both natural gas and waste phenol and implies a 

restriction for No. 6 fuel oil. For the condition to be practically enforceable, fuel 

restrictions should apply to each of the fuels been combusted in Boilers 1 and 2. 

The proposed heat input restriction is provided as a relative limit, in terms of percentage, 

and not absolute limits. To ease practical enforceability of the proposed limits, EPA 

recommends to establish absolute heat input limits, in terms of BTU, and not relative 

limits, in terms of percentages or fractions. 

The proposed heat input restriction is inconsistent with the proposed condition to limit 

the instances where burning No. 6 fuel oil is allowed. Since the boilers would primarily 

bum natural gas and/or phenol, in most cases there would be no other fuel comprising the 

remaining 49% of annual heat input during that time. The proposed fuel restriction does 

not appropriately reflect the two possible operating scenarios: (1) Burning ofphenol 

and/or natural gas, and (2) burning of phenol and/or No.6 fuel oil, when natural gas is 

not available. AMS should establish fuel restrictions for each of the possible operating 

scenarios. EPA also believes it is appropriate to establish a NOx emissions limit or fuel 

restriction for No. 6 fuel oil, because the proposed conditions would allow combustion of 

No.6 fuel oil during specific circumstances. 

2. As part of the SIP-approved RACT Plan Approval, Boilers 1 and 2 are also subject to the 

following restrictions: A NOx emissions limitation of0.35 lb/MMBTU for each ofthe 

boilers and a combined emissions limitation of 272 tons per year. EPA finds that the 0.35 

lb/MMBTU limit may no longer be appropriate to represent RACT and that it is 

inconsistent with the proposed ~CT revisions. 

First, emissions data from Continuous Emissions Monitoring System (CEMS) included in 

. the proposal indicates that each of the boilers were able to achieve much lower NOx 

emissions rates per heat input, specifically: 0.29lb/MMBTU for No.6 oil, 0.19 

lb/MMBTU for waste phenol residue, and 0.12 lb/MMBTU for natural gas. The CEMS 

data provided shows that the current 0.35 lb/MMBTU limit is only appropriate for 

controlling NOx emissions from burning No.6 oil. The boilers are able to achieve lower 

emissions rates when burning phenol or natural gas. Since No.6 fuel oil has been 

restricted from primary use, AMS should establish additional limits to control emissions 

from the boilers when burning phenol and natural gas. EPA recommends AMS establish 

a NOx emissions limit per fuel for each boiler, and to consider actual emissions data when 

7 
establishing such limits. AMS must also justify that the existing RACT emissions limit 

of272 tons per year continues to be appropriate to represent RACT. 

3. On page 38, AMS states that "(a)ll testing, monitoring, and record keeping are in the Title 

V operating permit for the facility." For the proposed RACT limitations to be practicably 

enforceable, the relevant testing, monitoring, and recordkeeping requirements for each of 

the RACT limits must be included. 

4. For Boiler 3, AMS has evaluated the economic feasibility of flue gas recirculation (FGR) 

in combination with low NOx burner (LNB). Because Boiler 3 is already required to 

maintain and operate an LNB, AMS should only consider the cost of installation of FGR, 

as the LNB is already in place. 

5. AMS includes a cost-effectiveness analysis for LNB. Boiler 3 is already required as 

RACT to maintain and operate LNB as of 1995. Thus, this cost-effectiveness evaluation 

is irrelevant. 

6. AMS has also evaluated feasibility of FGR in combination with ultra-low NOx burner 

(ULNB). AMS should explain the difference between LNB and ULNB with respect 

technical operation and expected control efficiency; AMS should further explain whether 

a complete removal of LNB and installation of the ULNB is required or merely a simple 

'upgrade' to the current burner system. · 

7. The capital recovery factor (CRF) estimated for Boiler 3 is based on a 15% of interest (i) 

and 10 years of useful life (n). Please justify why AMS assumes useful life (n) for each 

control of 1 0 years, when it is typically estimated to be 20 years. 

8. The methodology provided in pages 41 for estimating emissions of ammonia (NH3) 

necessary for the selective catalytic reduction (SCR) systems is incorrect. Thus, the 

ammonia costs estimate for SCR provided on page 42 is also incorrect. 

Emissions ofNOx from combustion of fossil fuels are primarily in the form of nitrogen 

oxide (NO), rather than in the form of nitrogen dioxide (NOz). Thus, the amount of 

ammonia needed should be estimated based on the reduction of NO, rather than ofNOz. 

The reduction ofNO takes place when ammonia and oxygen (Oz) react with the NO, to 

produce nitrogen (Nz) and water vapor (HzO), by the following stoichiometric chemical 

reaction: 

For more details, see page 2-5 of EPA's January 2002 Air Pollution Control Cost 

Manual, Sixth Edition, (EP A/452/B-02-00 1 ).. 

AMS provides the following methodology to estimate the annual cost of ammonia: 

(

17 4molesofNH3 $410 ) 

Ammonia Cost= 46 * 2 1 f 0 * 1.05 * NOx emissions*--* 5 years 

mo es o N 2 ton 

Where NOx emissions are in tons per year. 

8 
First, AMS should correct the estimated cost for ammonia, based on the stoichiometric 

ratio oftl).e reduction ofNO and molecular weight ofNO, instead ofN02. Second, 

because AMS uses potential annual NOx emissions of the boiler in tons per year, the cost 

would already be estimated on an annual basis. It is unnecessary to multiply the cost by 5 

years, as this would result in the total cost for the amount of ammonia for 5 years of 

operation, and the annual cost is needed. 

Additionally on page 42, AMS added a comment that indicates that the sinking fund 

factor (SFF) was used in estimated annual cost of ammonia. If using the revised equation 

as described in previous comment, the cost of ammonia will be estimated in an annual 

basis, and AMS will not need to use the SFF for annualization. The SFF should only be 

used in estimating the replacement cost of the catalyst, as AMS explained on page 41. 

9. AMS provides inadequate references to support their estimation of the total capital 

investment (TCI) costs of the controls evaluated for Boiler 3. AMS refers to "the 2006 

Best Available Control Technology submittal plus inflation adjustment to 2014 US 

dollars" and states that "(t)he TCI includes equipment cost estimates from vendorsupplied estimates for similar units or industry data gathered for similar projects. This 

was used because it is similar to RACT analysis and it is more recent." AMS should 

include the referenced Best Available Control Technology (BACT) analysis, or at least 

provide a more substantive description of the BACT determination. Additionally, AMS 

should clearly identify, for each control evaluated, whether vendor cost estimates or 

industry data were used in estimating TCI. 

Paperworks Industry (Formerly Jefferson Smurfit Corp.) 

1. In proposing revisions to the existing RACT conditions in the SIP in accordance with 

CAA 11 0(1), AMS does not properly describe in the technical memorandum the existing 

RACT requirements approved in the SIP under the 1-hour ozone standard for Paperworks 

Industry (Formerly Jefferson Smurfit Corp.). 

At the time of the 1-hour RACT determination, RACT was evaluated and determined for 

Boiler 1 (240 MMBTU/hr), Boiler 2 (225 MMBTU/hr), and four infrared heaters (2.9 

MMBTU/hr each). Under 1-hour RACT determination, Boilers 1 and 2 are allowed to 

burn coal, No. 6 fuel oil, and natural gas; for controlling NOx emissions each boiler is 

required to operate a LNB when combusting coal and LNB with overfire when 

combusting No.6 fuel oil and natural gas. Additionally, the combined NOx emissions 

from the boilers were limited to the following emissions rates: 0.50 lb/MMBTU on 30 

day-rolling average when burning coal, 0.30 lb/MMBTU on 30 day-rolling average when 

burning No. 6 fuel oil, 0.20 lb/MMBTU on 30 day-rolling average when burning natural 

gas, and 1,018 tons per year total. 

2. In evaluating RACT for Boiler 1, AMS does not accurately describe that the NOx 

emission limits currently approved as RACT apply to the combined emissions of Boilers 

1 and 2. Further, in proposing the existing RACT limits for Boiler 1, AMS should also 

9 
demonstrate that the level of these RACT emissions rates continue to represent the lowest 

emissions limitations that are currently feasible for Boiler 1. Since Boiler 2 has been 

removed, AMS must justify why the existing RACT emissions limits are appropriate to 

adequately limit emissions from Boiler 1 alone. 

3. The proposed RACT requirements for Boiler 1, Boiler 2, and the infrared heaters are 

inconsistent throughout the technical memorandum and the revised RACT Plan 

Approval. In the memorandum, AMS indicates that the facility is no longer allowed to 

bum coal in Boiler 1 and that Boiler 2 and the four infrared heater have been shutdown, 

and yet, AMS. does not propose any updates to the existing SIP-approved requirements 

for Boiler 1, Boiler 2, or the infrared heaters. Although not supported in the 

memorandum, AMS is proposing to revise various conditions of the RACT Plan 

Approval relevant to these emissions sources: (1) To remove the ability of Boiler 1 to 

bum coal and the applicable NOx emission limits and (2) to remove all requirements of 

the retired emissions sources. AMS must update the technical memorandum and/or the 

RACT Plan Approval to be consistent with any proposed changes to the SIP-approved 

RACT requirements. 

4. EPA believes AMS should evaluate additional control measures for Boiler 1. In the 

technical memorandum (page 48), AMS states that "Boiler #1 is allowed to bum No.6 

fuel oil and natural gas, though the facility has been burning natural gas for the past five 

years." Based on this statement, EPA believes that there are two additional reasonably 

available control measures that would achieve significant additional NOx emissions, 

which AMS should evaluate in determining RACT for Boiler 1: (1) Switching from 

burning both No.6 fuel oil and naturai gas to burning natural gas only, and (2) 

establishing restrictions to limit how much No. 6 fuel is allowed to bum as to primarily 

bum natural gas. · 

5. The proposed RACT requirements for Boilers 3 and 4 are inconsistent throughout the 

technical memorandum and the revised RACT Plan Approval. On page 48 of the 

technical memorandum, AMS indicates that Boilers 3 and 4 are currently permitted under 

Plan Approval No. 08179, issued in December 30 2008, to bum both natural gas and No. 

6 fuel oil, and states that on August 19, 2014 the facility requested to modify the plan 

approval to remove the ability of the boilers to bum No.6 fuel oil. AMS does not clearly 

provide if this modification has been approved as a permit action. 

6. Please, clearly describe all the applicable NOx requirements of Boilers 3 and 4 under Plan 

Approval No. 08179, issued in December 30 2008, including the limitation to bum No.6 

fuel oil. 

7. The AMS proposed RACT requirements for Boilers 3.and 4 are inconsistent throughout 

the memorandum and the revised RACT Plan Approval. The feasibility analysis of 

additional controls on Boilers 3 and 4, provided in pages 48-49 of the memorandum, is 

based on the boilers' ability to only burn natural gas. On page 49 of the memorandum, 

AMS proposes as RACT the emissions limits and existing controls required under Plan 

Approval No. 08179 issued in December 30 2008, which does not contain the August 

2014 modification requested by the facility for restricting to bum No.6 fuel oil. Finally, 

in the proposed revisions to the RACT Plan Approval, AMS does not include any 

10 
limitations for burning No.6 fuel oil. AMS must update the technical memorandum 

and/or the RACT Plan approval to be consistent with any proposed changes to the SIPapproved RACT requirements. 

Newman and Company, Inc. 

1. On page 69, EPA recommends that AMS include the permit ID number for the RACT 

Plan Approval that has been approved in the SIP as RACT under the 1-hour ozone 

standard. 

2. The provided citation ofthe Federal Register notice containing EPA's approval of 1-hour 

RACT for the facility is incorrect. The citation to the Federal Register should be 66 FR 

54691. 

3. AMS proposed as RACT for Boiler 1 the existing RACT NOx emissions limit as 

approved by EPA under the 1-hour ozone standard: 0.43 lbs/MMBTU when firing No.6 

oil, 0.37lbs/MMBTU when firing natural gas, and a total NOx emission limit of 121 tons 

per rolling 12-monthperiod. To support this proposal, AMS should demonstrate that 

each of the emission rates approved as RACT represent the lowest achievable rate that is 

feasible for Boiler 1. 

Temple University- Health Sciences Campus 

1. As part of this proposed submission, AMS sh~mld clearly describe the currently 

applicable RACT requirements for Temple Health, as approved in the SIP under the 1-

hour ozone standard, as well as any other currently applicable NOx requirements not 

approved by EPA for inclusion into the SIP, but approved by AMS. 

On December 15,2001 (65 FR 78418), EPA approved AMS Plan Approval 05198, 

effective on May 27, 1995, (hereafter the 1-hour RACT Plan Approval) as case-by-case 

RACT for Temple University- Health Campus (Temple- Health). On April 26, 2008, 

AMS issued modifications to Plan Approval 05198 with the purpose of replacing the 

RACT requirements for Boilers 1, 2, and 3 at Temple Health. Specifically, the modified 

Plan Approval 05198 required physical modifications to Boilers 1 and 3 to replace the 

fuel governing device limiting the heat input of each boiler to 50 MMBTU/hr, and to 

Boiler 2 to upgrade the burners to achieve reductions equivalent to those than should 

have been achieved with implementation ofFGR. 

The modified Plan Approval 05198 requires the following NOx emissions limits for each 

boiler: (1) When burning No.6 fuel oil, 0.25 + e·07

;

059

) * (N- 0.25), where X is the 

MMBTU/gal of the fuel oil and N is the percent nitrogen in the fuel oil; for N less than 

0.25, the NOx emissions are limited to 0.25 lbs/MMBTU; and (2) when burning natured 

gas, 0.067lbs/MMBTU. The plan approval also included a combined NOx emissions 

limit of 56.3 lbs/hr and a combined heat input limit of 673,894 MMBTU per rolling 12-

month period. 

11 
This modified Plan Approval was never submitted to EPA as a revision to the SIP to be 

evaluated and approved as RACT. Therefore, the NOx RACT requirements of the 1-hour 

RACT Plan Approval continue to represent RACT for Temple Health until a SIP revision 

is submitted and approved by EPA. 

2. AMS is not proposing as RACT, for Boilers 1, 2, and 3, the existing requirements of the 

modified Plan Approval 05198 issued on April 26, 2008. AMS should further justify 

why the existing permit requirements are not adequate to satisfy RACT, if they intended 

to replace the SIP-approved RACT requirements for restricting the heat input of Boilers 1 

and 3, and for operating the FGR on Boiler 2. 

3. AMS is proposing significant revisions to the applicable RACT requirements of Boilers 

1, 2, and 3 ofTemple Health, as approved into the SIP. Whenever a state chooses to 

revise its SIP, the state must demonstrate that the revision would not interfere with air 

quality goals, in accordance with section 110(1) ofthe CAA. Accordingly, AMS should 

explain how the proposed SIP revision that is modifying existing SIP-approved RACT 

control measures does not interfere with attainment of the applicable ozone NAAQS, 

including both 1-hour ozone standard and the 1997 8-hour ozone standard, and any 

applicable reasonable further progress requirements. In evaluating whether a given SIP 

revision would interfere with attainment or maintenance, as required by CAA section 

11 0(1), EPA generally considers whether the SIP revision will allow for an increase in 

actual emissions into the air over what is allowed under the existing EPA-approved SIP. 

Thus, in proposing to modify the SIP-approved requirements for Boilers 1, 2, and 3 in 

Temple Health, AMS must demonstrate that the proposed revision provides equivalent or 

additional emissions reductions, in accordance with CAA section 11 0(1). EPA finds that 

the emissions demonstration provided is technically incorrect for a number of reasons. 

EPA finds that the emissions factors used for estimating NOx emissions from burning No. 

6 fuel oil of Boilers 1, 2, and 3 under both the existing and proposed RACT requirements 

are inadequate or need to be further justified. In estimating NOx emissions from the 

existing RACT conditions, AMS uses an AP-42 emissions factor for No.6 fuel oil that is 

a function of nitrogen content (N). AMS assumes a "worst-case N content" of 55%, but 

does not provide any information to support this assumption. In estimating the emissions 

from the proposed requirements, AMS uses an emissions factor for No.6 fuel oil that is 

based on the NOx limit Plan Approval 05198 as revised on April 26, 2008. AMS is not 

proposing this emissions limit as RACT; therefore, the emissions estimated are irrelevant 

to the 11 0(1) emissions demonstration. 

The emissions demonstration provided by AMS does not completely address the 

proposed RACT requirements included in the SIP revision. On page 85 of the proposed 

SIP, AMS proposes as RACT the following requirement: "During the ozone season; 

(between May 1 -September 30), each boiler shall bum natural gas as the primary fuel. 

Each boiler may only burn No. 6 fuel oil during periods of gas cmtailment or gas supply 

interruption." AMS has not provided any justification that this requirement should 

adequately represent RACT. 

Additionally, the estimated emissions from the proposed RACT rely on the assumption 

that the maximum allowed emissions result from burning No.6 fuel oil throughout the 

12 
year (8760 hours per year), yet the proposed requirement would restrict burning No. 6 

fuel oil during ozone season. Thus, the emissions calculations provided are incorrect. If 

proposing this restriction for burning No.6 fuel oil as RACT, AMS would need to 

consider the emissions from burning primarily natural gas during ozone season and No.6 

fuel oil during the remaining ofthe year in the 110(1) emissions demonstration. 

4. EPA believes that the justification provided on page 83 for determining that the 

installation ofULNB on Boilers 1, 2, and 3 is technically infeasible is insufficient. 

5. Per 25 Pa Code 129.91, a RACT proposal should be provided for each emissions source 

at a major facility subject to this regulation. AMS has identified each of the boilers as an 

emissions source, thus RACT should be evaluated for each boiler. AMS estimated costeffectiveness for controlling the combined NOx emissions from Boilers 1, 2, and 3, thus, 

EPA finds this analysis to be inconsistent with Pennsylvania's source-specific RACT 

requirements. 

Consistently, in evaluating cost-effectiveness of controls for each boiler, AMS should 

consider the most stringent Federally Enforceable allowable emissions rate that applies to 

each of the boilers. Thus, AMS needs to identify what is the most stringent NOx 

emissions level that is currently allowed from the boilers. AMS does not provide 

sufficient information to evaluate how the baseline emissions for each boiler was 

calculated. 

6. AMS has evaluated switching completely from No.6 fuel oil to No.2 oil for Boilers 1-3 

as a control measure. EPA agrees that fuel switching may result in significant NOx 

emissions reductions. In evaluating fuel switching as RACT for Boilers 1, 2, and 3, AMS 

should consider the cost of retrofitting or replacing the existing burners and any 

incremental costs for operating the boilers with No. 2 fuel oil, rather than with No. 6 fuel 

oil. Fuel switching should not require significant incremental costs in operation of the 

boiler, other than any increases in fuel cost. AMS has estimated incremental costs of 

fuel, but needs to justify the fuel prices assumed in the analysis provided. EPA 

recommends AMS to consider costs from modifying the existing burners to 

accommodate the combustion of No.2 fuel oil. 

7. AMS evaluated switching completely from No.6 fuel oil to natural gas for Boilers 1, 2, 

and 3 as a control measure. EPA understands that Temple must have a back-up fuel to be 

able to provide uninterrupted services to a healthcare facility. However, EPA finds that it 

is reasonable for Temple to take fuel restrictions to limit the amount ofNo. 6 fuel oil 

allowed to be burned on Boilers 1, 2, a~d 3, as this would result in significant NOx 

emissions reductions. This control option would allow Temple to continue to have a 

back-up fuel at all times, especially when natural gas supply is interrupted. AMS has 

proposed to restrict burning No. 6 fuel oil during ozone season, except in the events of 

natural gas curtailment. However, AMS does not provide any justification to support this 

control option as RACT. In addition, AMS has not properly evaluated any other possible 

restrictions in burning No.6 oil in determining RACT. 

Sunoco Partner Marketing & Terminals L.P.- Belmont Terminal 

13 
1. In the memorandum (page 91 ), AMS refers to MIPC, LLC facility when intending to list 

the emission sources for this facility. Please clarify whether this is an editorial error and, 

if so, make the necessary corrections. 

2. In general when evaluating RA T for emissions sources, AMS should only rely on 

regulations that have been submitted as RACT for the 1997 8-hour ozone standard, or 

existing regulations approved under the-1-hour ozone standard, which AMS has certified 

as RACT for the 1997 8-hour ozone standard. AMS should specify under what 

regulation the leak detection and repair (LDAR) program for the VOC fugitive emissions 

in the facility is required, and explain that this regulation has been approved or submitted 

as RACT for the 1997 8-hour ozone standard. 

Aker Philadelphia Shipyard, Inc. - Plula. Naval Business Center 

1. AMS lists 22 baghouses and 10 dust collectors as the facility's control devices related to 

VOC emissions. Baghouses and dust collectors are not VOC control devices. 

Allied Tube & Conduit 

1. AMS should identify which portion of25 Pa Code 129.93(c) is applicable to the five 

space heaters listed in the table on page 98 of the proposed SIP revision. 

Cardone Industries 

1. Under the 1-hour ozone standard, AMS submitted separate RACT determinations for two 

facilities in Philadelphia identified as' Cardone Industries, one facility on Rising Sun 

Avenue (PLID- 3887) and the second facility on Chew Street (PLID 2237). Please 

clarify whether the technical memorandum submitted is intended to address RACT for 

either one of these facilities, or both. This should be clearly explained in the 

memorandum. If the memorandum intends to address RACT for only one of the facilities, 

then AMS w~uld still need to provide a RACT evaluation for the remaining facility. 

2. The memorandum and the proposed revisions to the RACT Plan Approval are 

inconsistent. AMS is proposing revisions to the SIP-approved RACT Plan Approval for 

the Rising Sun Avenue facility, but the revisions are not mentioned or proposed in the 

memorandum. 

MIPC, LLC- Philadelphia Terminal 

1. AMS did not address RACT for three additive storage tanks that were identified as VOC 

emission sources in the memorandum. 

University of Pennsylvania 

14 
1. On page 106 of the proposed SIP revision, AMS lists the heaters and furnaces and the 

presumptive RACT requirement that applies to each unit. AMS should clarify which 

portion of25 Pa Code 129.93(c) is applicable to each unit. 

Philadelphia Prison System 

1. AMS should clarify that the capacities of emergency generators, subject to presumptive 

RACT requirements of25 PA Code 129.92(c)(2), that are listed on page 111 of the 

proposed SIP revision are in units of horsepower (HP) and not ofMMBTU/hr. 

Kinder Morgan Liquids Terminal (Formerly GATX Terminals Corporation) 

1. On page 113, the capacities of Boilers 1 and 2 are given as 12.5 HP and 13.4 HP, 

respectively, and as 12.5 MMBTU/hr and 13.4 MMBTU/hr. Please, clarify and correct 

the working units for the capacity of each boiler. 

2. On page 114, AMS should correct the typographical error on the effective date of the 1-

hour RACT Plan Approval for GATX Terminals. 

3. On pages 115-116, AMS lists the RACT applicable requirements for storage tanks. 

AMR V Section II is listed, but not described. Please, further describe applicability of 

this requirement. 

4. Under the 1-hour RACT, AMS identified as a VOC source the fugitive emissions from 

flanges, valves, and pumps leaks, for which case-by-case RACT requirements were 

established. The RACT Plan Approval included the following conditions: Condition 2E: 

"The implementation of a quarterly leak detection and repair program on all pumps, 

valves and flanges containing VOC;" and Condition 5A: "GATX [Kinder Morgan] shall 

monitor all valves, pumps, and flanges quarterly for visual leaks. GATX shall also 

monitor valves, pumps, and flanges which process organic liquid greater than or equal to 

4 RVP for leaks of greater than 10,000 ppmv." 

AMS also identifies AMR V Section XIII as an applicable RACT requirement for VOC 

fugitive emissions. AMR V Section XIII applies to fugitive emissions from "leaking 

flanges, gaskets, seals, connections, joints, fittings or other process equipment 

components not involving moving parts," as well as VOC emissions from "leaking 

valves, pumps, compressors, safety pressure relief devices or other process equipment 

components involving moving parts." The regulation prohibits VOC emissions from any 

of these leaking process equipment component greater than 10,000 part per million by 

volume (ppmv) in concentration. AMS has contradictory concluding statements on pages 

117 and 118 of the memorandum about the stringency of these two requirements for 

fugitive emissions. Please clarify. 

Although both requirements are similar, EPA finds that AMR V Section XIII also applies 

to additional VOC fugitive emission sources that are not controlled by the case-by-case 

requirement. Please, explain whether AMS has considered fugitive VOC emissions from 

"leaking flanges, gaskets, seals, connections, joints, fittings or other process equipment 

15 
components not involving moving parts" in Kinder Morgan and how RACT should be 

addressed for these fugitive emissions, as not provided by the RACT Plan Approval. 

AMS interprets Condition SA of the SIP-approved RACT Plan Approval to be broadly 

applicable to fugitive emissions from leaks ofboth VOC and non-VOC products. 

Consequently, AMS is requesting to modify this condition to require only monitoring of 

VOC emissions. Condition SA is proposed to be revised to: "The Permittee shall 

monitor all valves, pumps, and flanges in VOC service quarterly for visual leaks for 

greater than 10,000 ppmv." 

The proposed revision removes the previous specification for the requirement to apply to 

processing of organic liquids with Reid Vapor Pressure (RVP) of 4.0 pounds per square 

inch (psi) or greater. Please explain how removing this requirement relates to AMS 

intended clarification of the condition only applying to the control ofVOC emissions. 

AMS must also demonstrate that the proposed SIP revision will not allow for an increase 

in actual emissions into the air over what is allowed under the existing EPA-approved 

SIP, consistent with the section 11 0(1) of the CAA. 

S. AMS should verify the provided citations to Pennsylvania regulations on page 120 that 

would apply to tank truck/tank car loading operations at the facility. 

6. The tank truck/tank car loading operations in Kinder Morgan are subject to the VOC 

source-specific requirements of the RACT Plan Approval, which were approved in the 

SIP as RACT under the 1-hour ozone standard. AMS is proposing various revisions to 

the applicable SIP requirements to allow more flexibility to the facility in operating the 

loading racks. AMS must demonstrate that the proposed SIP revisions will not allow for 

an increase in actual emissions into the air over what is allowed under the existing EPAapproved SIP, consistent with the section 110(1) ofthe CAA. 

EPA believes that the emissions demonstration provided to satisfy section 11 0(1) CAA is 

inconclusive. First, AMS's demonstration does not address emission changes from the 

proposed SIP revisions listed in the memorandum on page 120 and the proposed 

limitation to each loading position of the loading racks. 

Second, AMS does not provide sufficient information to assess the emissions estimation 

provided. EPA recommends including at least the following information: Loading 

capacity of each loading rack, VOC emissions factors used, the capacity and level of 

control of the thermal oxidizer, assumptions on hours of operations, and any other 

relevant assumptions. Additionally, emissions are provided for the "controlled" and the 

"uncontrolled" racks, where they should have been provided for each identified emission 

source, in this case, for each loading rack. 

7. As part of the emissions demonstration, AMS interprets the existing RACT requirements 

to allow uncontrolled loading of liquids with RVP under 4 psi on loading racks connected 

to the thermal oxidizer. In support ofthis interpretation, please explain why the 

requirements of2S Pa Code 129.S9 would allow uncontrolled VOC emissions from 

loading racks A, B, E, F, M, and V, per condition 2C of the RACT Plan Approval, while 

16 
condition 1A(l) and 2B would require the operation ofthe NAO Thermal Oxidizer. 

8. In pages 120-121, AMS states that "(r)acks A, B, E, F, M, and V have control 

capabilities; however, not all loading positions are connected to the NAO Thermal 

Oxidizer since these positions do not load materials that are required to have control (e.g. 

benzene NESHAP) or load materials with a vapor pressure great than 4 psia RVP." This 

statement is inconsistent with the SIP approved RACT requirements. Condition 1A(1) of 

the RACT Plan Approval specifically requires loading racks A, B, E, F, M, and V to be 

connected to the NAO Thermal Oxidizer. If some of the loading positions at these racks 

are not physically connected to the control unit, how is the facility able to comply with 

the applicable RACT requirement? 

Also, AMS should specify what materials, other than those with RVP ofless than 4.0 psi, 

would not require to have controls. 

9. EPA recommends AMS to further revise the proposed condition 2C for additional 

clarification ofthe following requirements: (1) The continuous operation ofthe NAO 

Thermal Oxidizer when loading products with RVP greater than or equal to 4.0 psi; (2) 

the applicable emissions limit when operating the NAO Thermal Oxidizer; and (3) the 

flexibility of not operating the thermal oxidizer only when loading organics with RVP 

less than 4.0 psi. EPA recommends the condition should read as follows: "Organic 

liquids with a Reid Vapor Pressure (RVP) greater than or equal to 4.0 psi shall only be 

loaded at racks A, E, F, M, or D and shall comply with the requirements of 25 Pa Code 

129.59(a) by continuously operating NAO Thermal Oxidation Unit. The NAO Thermal 

Oxidation Unit shall be operated such that 0.0668 pounds (30.3 grams) of organic liquids 

(measured as propane) are emitted to the atmosphere for every 100 gallons (380 liters) of 

gasoline loaded. Uncontrolled loading at racks A, E, F, M, and D shall be allowed when 

loading organic liquids with a RVP less than 4.0 psi." 

EPA does not agree with the proposed modification to Condition 2D. AMS must 

continue to identify those racks that are not connected to a control unit, and must 

continue to restrict the loading of liquids with RVP less than 4 RVP to those racks, in 

order for these racks to not be subject to 25 Pa Code 129.59. EPA recommends AMS to 

modify the existing condition as follows: "Tank car/truck loading racks- B, C, G, H, N, 

0, P, R, R-1, T, V & X which are uncontrolled shall be limited to processing organic 

liquid with vapor pressure lower than 4 RVP." 

EPA recommends to further revise the proposed Condition 3A(1), for additional 

clarification, as follows: "Loading of organic liquids with RVP > 4 psi at all tank 

car/truck loading positions at the facility shall be limited to 129 tons ofVOC per year." 

10. The RACT evaluation for the loading racks is technically incorrect for various reasons. 

First, AMS provides two analyses for 'uncontrolled loading of racks, but it is not clear for 

what specific loading racks the analyses is provided. AMS is proposing to allow loading 

racks that are connected to the thermal oxidizer, A, E, F, M, or D, to remain uncontrolled 

whenever loading is limited to organic liquids with less than 4.0 psi ofRVP. AMS is 

also proposing to maintain the loading of organic liquids with less than 4.0 psi ofRVP on 

17 
racks that are not physically connected to the thermal oxidizer. AMS has evaluated on 

pages 122-123 the feasibility of"adding a control device while loading VOC materials 

with an RVP < 4.0 psi." 

According to AMS' s estimated potential emissions, uncontrolled emissions of loading 

racks A, E, F, M, or D from liquids with RVP of 4.0 psi or less would produce significant 

potential emissions of VOC. Thus, EPA believes AMS must determine RACT for the 

uncontrolled operation of these racks. Additionally, AMS must evaluate the 

appropriateness of the existing RACT requirements for loading racks A, E, F, M, or Din 

determining RACT. In evaluating RACT, AMS should evaluate the feasibility of the 

existing controls (the NAO thermal oxidizer and/or the applicable emissions limits) and 

additional reasonably available controls. 

Second, AMS has evaluated RACT per loading position. In accordance with 25 Pa Code 

129.92, AMS must evaluate and determine RACT for each emissions source in a major 

facility. Per the existing and proposed RACT conditions, AMS has consistently defined 

· the emissions source as the loading racks, not the loading positions within racks. In 

evaluating RACT, if AMS finds that no available controls are technically and 

economically feasible for each rack, EPA finds it would be acceptable to evaluate 

controls for emissions of combined emissions sources. The control ofVOC emissions 

from racks A, B, E, F, M, and V with a single thermal oxidizer suggests that this is a 

reasonable control option for multiple loading racks. 

Baseline emissions used in the cost-effectiveness analyses should be based on the 

existing Federally-enforceable emissions restrictions that apply to the particular 

emissions source. Consequently, AMS cannot rely on a limit that is being proposed as 

RACT. Since there is no applicable Federally-enforceable limitation for each of the 

loading racks, the baseline emissions should be based on the unrestricted maximum 

capacity of each rack. 

AMS provides different and inconsistent control efficiencies for the thermal and catalytic 

oxidizer throughout the analysis provided. 

11. AMS is proposing a 70 ton per year emissions limit for each of the loading positions of 

the loading racks. To ease practicable enforceability, EPA recommends any emissions 

limit to be applied on a short-term averaging basis. Also, AMS should establish limits on 

the emission sources themselves, which has been consistently identified as the loading 

racks not the loading positions. AMS must provide further justification for determining 

that this proposed limit adequately represents RACT. 

Plains Product Terminal LLC 

1. In general, when evaluating RACT for emissions sources, AMS should only rely on 

regulations that have been submitted as RACT for the 1997 8-hour ozone standard, or 

existing regulations approved under the 1-hour ozone standard, which AMS has certified 

as RACT for the 1997 8-hour ozone standard. On page 137, AMS should specify under 

what regulation the LDAR program is required for controlling fugitive emissions from 

pumps, valves, and flanges in the facility, and explain that this regulation has been 

18 
approved or submitted as RACT for the 1997 8-hour ozone standard. 

Navy Foundry and Propeller Center 

1. AMS indicates in the memorandum (page 138) that "(t)he 1-hour ozone RACT in the 

RACT Plan Approval dates April20, 1999 was issued to Philadelphia Naval Shipyard." 

EPA does not have any record ofthe Philadelphia Navy Shipyard having a 1-hour RACT 

determination approved in the SIP for this facility. Please, clarify. 

Grays Ferry Cogeneration Partnership 

1. The proposed NOx RACT limits for the combustion turbine excludes startup and 

shutdown emissions. These limits are inappropriate for approval into the SIP. 

The CAA does not allow for exemptions from otherwise applicable SIP emission 

limitations, whether automatic or through the exercise of a state official's discretion. In 

accordance with the requirements ofCAA section 110(a)(2)(A), SIPs must contain 

emission limitations and, in accordance with the definition of "emission limitations" in 

CAA section 302(k), such emission limitations must be continuous. Thus, any excess 

emissions above the level of the applicable emission limitation must be considered 

violations, whether or not the state elects to exercise its enforcement discretion. SIP 

provisions that create exemptions such that the excess emissions during startup, 

shutdown, malfunction, or emergencies are not violations of the applicable emission 

limitations are inconsistent with the fundamental requirements of the CAA with respect 

to emission limitations in SIPs and interfere with citizen suit enforcement of CAA 

violations. EPA believes that the inclusion of such an exemption is a substantial 

inadequacy and renders any proposed provision for a SIP impermissible. 

2. The methodology provided in page 148 for estimating emissions of ammonia necessary 

for the SCR and the selective non-catalytic reduction (SNCR) systems is incorrect. Thus, 

the ammonia costs estimates for SCR and SNCR provided on pages 144 and 147 are also 

incorrect. Please refer to EPA's comment 8 for Honeywell International- Frankford 

Plant. 

Temple University- Main Campus 

1. Temple has 3 boilers firing natural gas and No. 2 fuel oil, with 91.3 MMBTU/hr and 86.8 

MMBTU/hr of heat input capacity for each fuel, respectively. The boilers are currently 

required to operate LNB and FGR. Each boiler is subject to the NOx emissions limit of 

0.036lbs/MMBTU while burning natural gas and 0.110 lbs/MMBTU while burning No. 

2 fuel oil for each boiler, in addition to the combined emissions limit of 15.5 tons per 

rolling 12-month period. 

Based on heat input capacity, continuous operation of the boilers, and the NOx permitted 

19 
rates for each fuel, each boiler can potentially emit 41.8 tons per year when burning No; 2 

fuel oil alone, or 14.4 tons per year when burning natural gas alone. The combined 

emissions limit for the three boilers is significantly more stringent, considering the 

potential emissions achieved for each boiler alone when burning either of the fuels 

allowed. How is the facility able to comply with such stringent combined emissions 

limit? Is the facility operating these boilers continuously during the year? 

2. The methodology provided in page 156 for estimating emissions of ammonia necessary 

for the SCR and the SNCR systems is incorrect. Thus, the ammonia costs estimates for 

SCR and SNCR provided on pages 158 and 159 are also incorrect. Please refer to EPA's 

comment# 8 for Honeywell International- Frankford Plant. 

V eolia Energy Efficiency 

1. The methodology provided in page 167 for estimating emissions of ammonia necessary 

for the SCR system is incorrect. Thus, the ammonia costs estimate for SCR provided on 

pages 163 is also incorrect. Please refer to EPA's comment # 8 for Honeywell 

International- Frankford Plant. 

2. Each boiler at Veolia Energy Efficiency has the following NOx emission limits in a plan 

approval, each on a rolling 30-day average: O.Ollbs/MMBTU while burning gas as 

during normal operation; 0.08 lbs/MMBTU while burning oil during normal operation; 

0.036lbs/MMBTU while burning gas during startup, shutdown, or malfunction; and 0.08 

lbs/MMBTU while burning oil during startup, shutdown, or malfunction. The boilers 

have a combined NOx emission limit of 52.31 tons per rolling 12-month period. AMS' 

Memo indicates these NOx rates are proposed as RACT for the facility. 

The CAA does not allow for exemptions from otherwise applicable SIP emission 

limitations, whether automatic or through the exercise of a state official's discretion. In 

accordance with the requirements ofCAA section 110(a)(2)(A), SIPs must contain 

emission limitations and, in accordance with the definition of "emission limitations" in 

CAA section 302(k), such emission limitations must be continuous. Thus, any excess 

emissions above the level of the applicable emission limitation must be considered 

violations, whether or not the state elects to exercise its enforcement discretion. SIP 

provisions that create exemptions such that the excess emissions during startup, 

shutdown, malfunction, or emergencies are not violations of the applicable emission 

limitations are inconsistent with th~ fundamental requirements of the CAA with respect 

to emission limitations in SIPs and interfere with citizen suit enforcement of CAA 

violations. EPA believes that the inclusion of such an exemption is a substantial 

inadequacy and renders any proposed provision for a SIP impermissible. AMS is 

proposing to exempt automatically emissions between 0.01- 0.036lb/MMBTU when the 

boilers combust gas during startup, shutdown or malfunction. AMS is proposing a 

"separate" rate for startup/shutdown/malfunction when the boilers combust oil; however, 

presently, it appears the rate is identical to the rate for normal state for combustion of oil. 

20 
If AMS adjusts that rate for oil to a higher limit during startup, shutdown or malfunction 

(SSM) (if it believes it made a mistake), then such alternative rate would also exempt 

automatically emissions between 0.08 lb/MMBtu and any higher rate selected. If AMS 

corrects the rate for periods of SSM for the boilers while combusting oil by creating a 

higher rate than during normal operations, such a change would be impermissible if 

submitted for SIP approval. 

EPA notes that while the CAA does not allow for exemptions for excess emissions, it 

does allow states to develop alternative emission limitations or other forms of 

enforceable control measures or techniques that apply during startup or shutdown. EPA 

emphasizes this alternative rate may not apply to malfunctions. See Memorandum from 

Steven A. Herman, Assistant Administrator for Enforcement and Compliance Assurance, 

and Robert Perciasepe, Assistant Administrator for Air and Radiation, U.S. EPA on State 

Implementation Plans (SIPs): Policy Regarding Excess Emissions During Malfunctions, 

Startup, and Shutdown to Regional Administrators, Regions I-X (Sept. 20, 1999) (1999 

Memorandum). EPA has affirmed this in a separate rulemaking proposal concerning 

Startup/Shutdown/Malfunction provisions in state SIPs. See 78 FR 12460 

(February 22, 2013). However, in Section III.A ofthe 1999 Memorandum, EPA 

recommended very specific criteria that air agencies should consider including as part of 

any SIP provision that was intended to apply to sources during startup and shutdown in 

lieu of the otherwise applicable emission limitations. In order to revise the otherwise 

applicable emission limitation in the SIP, EPA recommended that in order to be 

approvable (i.e., meet CAA requirements), the new special requirements applicable to the 

source during startup and shutdown should be narrowly tailored and take into account 

considerations such as the technological limitations of the specific source category and 

the control technology that is feasible during startup and shutdown. 

EPA continues to recommend the seven specific criteria enumerated in Section III.A of 

the Attachment to the 1999 SSM Guidance as appropriate considerations for SIP 

provisions that apply to startup and shutdown. AMS has so far not explained how these 

criteria apply to the boilers at Veolia Energy Efficiency. These criteria are: (1) The 

revision must be limited to specific, narrowly defined source categories using specific 

control strategies (e.g., cogeneration facilities burning natural gas and using selective 

catalytic reduction); (2) use of the control strategy for this source category must be 

technically infeasible during startup or shutdown periods; (3) the frequency and duration 

of operation in startup or shutdown mode must be minimized to the maximum extent 

practicable; ( 4) as part of its justification of the SIP revision; the state should analyze the 

potential worst-case emissions that could occur during startup and shutdown; (5) all 

possible steps must be taken to minimize the impact of emissions during startup and 

shutdown on ambient air quality; ( 6) at all times, the facility must be operated in a 

manner consistent with good practice for minimizing emissions, and the source must 

have used best efforts regarding planning, design, and operating procedures to meet the 

otherwise applicable emission limitation; and (7) the owner or operator's actions during 

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startup and shutdown periods must be documented by properly signed, contemporaneous 

operating logs, or other relevant evidence. See 78 FR 12460 (February 22, 2013). 

AMS's limitations for Veolia do not comply with the EPA's policy on SSM. Automatic 

exemptions for SSM which AMS has created are impermissible for the SIP as explained 

above. In addition, AMS has not explained any alternative emission limitations for 

V eolia Energy Efficiency for startup and shutdown in accordance with the criteria in the 

1999 Memorandum. EPA believes that the inclusion of these alternative limitations and 

automatic exemptions, which do not comply with the requirements of the CAA, render 

these provisions for Veolia Energy Efficiency impermissible for RACT and 

impermissible as a SIP provision. 

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