Page 1 of 8

20140626 SIP Revision

City of Philadelphia 

Department of Public Health

Air Management Services (AMS)

Reasonably Available Control Technology (RACT)

State Implementation Plan (SIP) Revision 

under the 1997 8-Hour Ozone 

National Ambient Air Quality Standards (NAAQS) 

20140626 SIP Revision 

Final January 8, 2015 

 
Page 2 of 8

20140626 SIP Revision

Table of Contents 

Statutory Authority: page 3 

Background: page 3 

SIP Revision: page 4 

Technical Analysis Memos 

 Exelon – Delaware Station (1325 N. Beach Street, Philadelphia, PA 19125): page 7 

 Exelon Generating Company – Richmond Station (3901 N. Delaware Avenue, 

Philadelphia, PA 19137): page 7 

 Exelon Generating Company – Schuylkill Station (2800 Christian Street, Philadelphia, 

PA 19146): page 7 

 Veolia Energy Philadelphia – Edison Station (908 Sansom Street, Philadelphia, PA 

19107): page 7 

 Veolia Energy – Schuylkill Station (2600 Christian Street, Philadelphia, PA 19146): page 

7 

RACT Plan Approvals

 Exelon Generating Company – Richmond Station (3901 N. Delaware Avenue, 

Philadelphia, PA 19137): page 7 

 Veolia Energy Philadelphia – Edison Station (908 Sansom Street, Philadelphia, PA 

19107): page 7 

 Veolia Energy – Schuylkill Station (2600 Christian Street, Philadelphia, PA 19146): page 

7 

Documentation of Public Hearing and Certifications 

 Public Hearing Notice: page 8 

 Proof of Publication: page 8 

 Notices to EPA and PADEP: page 8 

 Summary of Comments and responses: page 8 

 William O’Sullivan, Director, Division of Air Quality, New Jersey Department of 

Environmental Protection comments (original): page 8 

 
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20140626 SIP Revision

Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) 

Revision for the 1997 8-hour Ozone National Ambient Air Quality Standard (NAAQS) 

Statutory Authority:

 25 Pennsylvania Code Subpart C Article III 

 Philadelphia Air Management Code 3-301 of the Philadelphia Code 

Background: 

The federal Clean Air Act (CAA) of 1990 gives states primary responsibility for achieving the 

National Ambient Air Quality Standards (NAAQS). The NAAQSs are established by the U.S. 

Environmental Protection Agency (EPA) as the maximum concentrations in the atmosphere for 

specific air contaminants to protect public health and welfare. The principal mechanism at the 

state and local level for complying with the CAA is the State Implementation Plan (SIP). A SIP 

outlines the programs, actions, and commitments a state will carry out to implement its 

responsibilities under the CAA. Once approved by the EPA, a SIP is a legally binding document 

under both state and federal law. 

In June 2004, EPA designated 126 areas of the country as “non-attainment” under the 1997 8-

hour ozone NAAQS. Among those non-attainment areas is the Philadelphia-Wilmington-Atlantic 

City Moderate Non-Attainment Area (NAA) that includes three counties in Delaware, five 

counties in eastern Pennsylvania, and eight counties in southern New Jersey. 

On November 29, 2005, EPA published an ozone implementation rule to address nonattainment 

SIP requirements for the 1997 8-hour ozone NAAQS (the Phase 2 Ozone Implementation Rule; 

70 FR 71612). In the Phase 2 Ozone Implementation Rule, EPA required that states meet the 

RACT requirements under the 1997 8-hour ozone NAAQS, either through a certification that 

previously adopted RACT controls in their SIP approved by EPA under the 1-hour ozone 

NAAQS continue to represent adequate RACT control levels for 8-hour ozone attainment 

purposes, or through the adoption of new or more stringent regulations that represent RACT 

control levels (70 FR 71655). 

On September 29, 2006, PADEP submitted on behalf of AMS a SIP revision for Philadelphia 

County to meet the RACT requirements for the 1997 8-hour ozone NAAQS. The 2006 SIP 

revision consisted of a demonstration that Philadelphia County has met the RACT requirements 

for Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOC), and included: (1) A 

certification that previously adopted RACT controls in Pennsylvania's SIP that were approved by 

EPA for Philadelphia County under the 1-hour ozone NAAQS are based on the currently 

available technically and economically feasible controls, and continue to represent RACT for the 

8-hour implementation purposes; (2) the adoption of federally enforceable permits that represent 

RACT control levels for four major VOC sources; and (3) a negative declaration that certain 

VOC sources do not exist in Philadelphia County. 
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20140626 SIP Revision

In November 2008, several parties challenged EPA's Phase 2 Ozone Implementation Rule. In 

particular, EPA's determination that compliance with the NOx SIP Call could satisfy NOx RACT 

requirements for EGUs in nonattainment areas was challenged. As a result of this litigation, the 

Court decided that the provisions in the Phase 2 Ozone Implementation Rule providing that a 

state need not perform (or submit) a NOx RACT analysis for EGU sources subject to a cap-andtrade program in accordance with the NOx SIP Call were inconsistent with the statutory 

requirements of section 172(c)(1) of the CAA. In the 2006 SIP Revision, AMS certified as 

RACT, 25 PA Code Chapter 145 Subchapter A, which established a NOx budget and trading 

program for EGUs and other large sources to control transport emissions. 

On June 22, 2010, PADEP submitted another SIP revision supplementing Philadelphia County's 

RACT demonstration under the 1997 8-hour ozone standard. The 2010 SIP revision consisted of: 

(1) The adoption of two regulations to meet control technique guidelines (CTG) RACT 

requirements, and (2) a negative declaration for a CTG source category. 

On August 26, 2008 (73 FR 50270), EPA published a notice of proposed rulemaking (NPR) 

proposing approval of the 2006 SIP revision. On June 19, 2013 (78 FR 36716), EPA withdrew 

its August 26, 2008 proposed rule due to the Court decision regarding the Phase 2 Ozone 

Implementation Rule EPA determined it could not approve the presumption in the 2006 SIP 

submittal that the NOx SIP Call constitutes RACT for EGU sources in Philadelphia County. In 

addition, EPA also determined that the 2006 SIP revision did not specifically and sufficiently 

address source-specific RACT controls for the 1997 8-hour ozone NAAQS required under 25 Pa 

Code 129.91-94. AMS had previously determined source-specific RACT controls for 46 major 

sources in Philadelphia County under the 1-hour ozone NAAQS, for which AMS needs to 

determine RACT under the 1997 8-hour ozone NAAQS. 

On June 19, 2013, EPA also proposed conditionally approval of the Philadelphia County's RACT 

demonstration under the 1997 8-hour ozone NAAQS, as provided in the 2006 and the 2010 SIP 

revisions. The conditional approval was finalized on December 13, 2013 (78 FR 75902). The 

conditional approval was based upon PADEP’s April 26, 2013 letter in which AMS committed 

to submit to EPA additional SIP revisions to address the deficiencies in the current RACT 

demonstration for Philadelphia County. The SIP revisions will provide source-specific RACT 

determinations for 10 major sources of VOC and NOx in Philadelphia County, as listed in EPA’s 

final notice, and a certification that previously adopted source-specific RACT controls approved 

by EPA in Pennsylvania's SIP for the 1-hour ozone NAAQS for the remaining sources in 

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

On June 26, 2014, a notice was placed in the Philadelphia Daily News announcing that the 

Philadelphia Department of Public Health, Air Management Services Division (AMS), proposed 

to revise the State Implementation Plan (SIP) to meet the requirements of the Reasonable 

Available Control Technology (RACT) set forth by the Clean Air Act under the 8-hour Ozone 
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20140626 SIP Revision

NAAQS. An equivalent notice was published in the Pennsylvania Bulletin on June 28, 2014. 

The notices informed the public that AMS was accepting written public comments on the 

proposed permit issuance and set 30 days from the publication date as the closing date (AMS 

used latest notice to set the closing date). The notices also informed the public that a public 

hearing would be held on July 31, 2014, if requested by 4 PM on July 28, 2014. 

There were no requests for a public hearing. During the public comment period, AMS received 

comments from William O’Sullivan, Director, Division of Air Quality, New Jersey Department 

of Environmental Protection (NJDEP). 

 
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20140626 SIP Revision

SIP Revision: 

This SIP revision is intended to partially satisfy AMS’ commitment by addressing sourcespecific RACT determinations for the following major sources of NOx: 

 Exelon – Delaware Station (1325 N. Beach Street, Philadelphia, PA 19125), with three 

15.5 MW combustion turbines and one 17.5 MW combustion turbine 

 Exelon Generating Company – Richmond Station (3901 N. Delaware Avenue, 

Philadelphia, PA 19137), with two 66 MW combustion turbines 

 Exelon Generating Company – Schuylkill Station (2800 Christian Street, Philadelphia, 

PA 19146), with one 233 MMBTU/hr combustion turbine, one 284 MMBTU/hr 

combustion turbine, and one 2.75 MW emergency generator 

 Veolia Energy Philadelphia – Edison Station (908 Sansom Street, Philadelphia, PA 

19107), with two 283 MMBTU/hr boilers and two 335 MMBTU/hr boilers 

 Veolia Energy – Schuylkill Station (2600 Christian Street, Philadelphia, PA 19146), with 

two 795 MMBTU/hr boilers and one 761 MMBTU/hr boiler 

AMS is providing technical analysis memos to demonstrate RACT for the 1997 8-hour ozone 

standard. 

In addition, due to comments from NJDEP, this SIP revision includes revisions to the RACT 

Plan approvals for the following facilities: 

 Veolia Energy Philadelphia – Edison Station (908 Sansom Street, Philadelphia, PA 

19107) 

 Exelon Generating Company – Richmond Station (3901 N. Delaware Avenue, 

Philadelphia, PA 19137) 

 Veolia Energy – Schuylkill Station (2600 Christian Street, Philadelphia, PA 19146) 
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20140626 SIP Revision

Technical Memos / RACT Plan Approvals 

(files attached separately) 

 Exelon – Delaware Station (1325 N. Beach Street, Philadelphia, PA 19125) 

Exelon – Delaware Station [04901] - TECHNICAL MEMO.pdf 

 Exelon Generating Company – Richmond Station (3901 N. Delaware Avenue, 

Philadelphia, PA 19137) 

Exelon Generating Company – Richmond Station [04903] - TECHNICAL MEMO.pdf 

Exelon Generating Company – Richmond Station [04903] - RACT PLAN APPROVAL.pdf 

 Exelon Generating Company – Schuylkill Station (2800 Christian Street, Philadelphia, 

PA 19146) 

Exelon Generating Company – Schuylkill Station [04904] - TECHNICAL MEMO.pdf 

 Veolia Energy Philadelphia – Edison Station (908 Sansom Street, Philadelphia, PA 

19107) 

Veolia Energy Philadelphia – Edison Station [04902] - TECHNICAL MEMO.pdf 

Veolia Energy Philadelphia – Edison Station [04902] - RACT PLAN APPROVAL.pdf 

 Veolia Energy – Schuylkill Station (2600 Christian Street, Philadelphia, PA 19146) 

Veolia Energy – Schuylkill Station [04942] - TECHNICAL MEMO.pdf 

 Veolia Energy – Schuylkill Station [04942] - RACT PLAN APPROVAL.pdf 

 
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20140626 SIP Revision

Documentation of Public Hearing and Certifications 

(files attached separately)

 Public Hearing Notice 

Public Notice - Daily News published 20140626 - 1997 Ozone RACT - 5 EGUs.pdf 

Public Notice - PA Bulletin published 20140628 - 1997 Ozone RACT - 5 EGUs.pdf 

 Proof of Publication 

Public Notice - Daily News published 20140626 - 1997 Ozone RACT - 5 EGUs __ PROOF 

OF PUBLICATION.pdf 

 Notices to EPA and PADEP 

Notification to Neighboring States.pdf 

 Summary of Comments and responses 

EGU Comment Response 20141212 FINAL.pdf 

 William O’Sullivan, Director, Division of Air Quality, New Jersey Department of 

Environmental Protection comments (original) 

NJDEP RACT comments_20140724_132824.pdf 
Page 1 of 19

20140918 SIP Revision

City of Philadelphia 

Department of Public Health

Air Management Services (AMS)

Reasonably Available Control Technology (RACT)

State Implementation Plan (SIP) Revision 

under the 1997 8-Hour Ozone 

National Ambient Air Quality Standards (NAAQS) 

20140918 SIP Revision 

Final January 12, 2015 

 
Page 2 of 19

20140918 SIP Revision

Table of Contents 

Statutory Authority: page 4 

Background: page 4 

SIP Revision: page 5 

Technical Analysis Memos 

 Philadelphia Energy Solutions Refining and Marketing LLC (including Tank Farm) (3144 

Passyunk Ave): page 17 

o September 2014 – Revision B RACT Update 

 Honeywell International (Formerly Sunoco Chemical) – Frankford Plant (4700 Bermuda Street); 

page 17 

 Paperworks Industries (5000 Flat Rock Road): page 17 

 Sun Chemical (3301 Hunting Park Avenue): page 17 

 Newman and Company, Inc. (6101 Tacony Street) : page 17 

 Exelon (formerly PECO) – Southwark Station (2501 S. Delaware Avenue) : page 17 

 Naval Surface Warfare Center Cardrock Division (formerly NAVSSES) (5001 South Broad 

Street) : page 17 

 Temple – Health Sciences (3401 N. Broad Street): page 17 

 Sunoco Partners Marketing & Terminals L.P - Belmont Terminal (2700 Passyunk Avenue) : page 

17 

 Aker Philadelphia Shipyard, Inc. (2100 Kitty Hawk Avenue) : page 17 

 Inolex Chemical Company (Swanson & Jackson Streets) : page 17 

 Allied Tube & Conduit Corporation (11350 Norcom Road) : page 17 

 Cardone Industries (5660 Rising Sun Avenue) : page 18 

 MIPC LLC - Philadelphia Terminal (formerly ConocoPhillips) (G Street & Hunting Park 

Avenue): page 18 

 University of Pennsylvania (3451 Walnut Street) : page 18 

 Philadelphia Prison System (8001 State Road) : page 18 

 Kinder Morgan: page 18 

o Vendor Quote (redacted) 

 Philadelphia Gas Works - Richmond (3100 East Venango St) : page 18 

 Plains Products Terminal LLC (3400 South 67th Street) : page 18 

 Navy Foundry and Propeller Center (Navy Yard, Building 592) : page 18 

 Grays Ferry Cogeneration Partnership (2600 Christian Street): page 18 

 Temple University – Main Campus (Broad Street and Montgomery Avenue): page 18 

 Veolia-Energy Efficiency (PA) LLC (2600 Christian Street): page 18 

 Sources no longer applicable to 1997 8-hour RACT: see page 18 

 Sources no longer applicable to 1997 8-hour RACT, NE Water Pollution Control Plant: see page 

18 

 Sources no longer applicable to 1997 8-hour RACT, SW Water Pollution Control Plant: see page 

18 

RACT Plan Approvals 

 Honeywell, formerly Sunoco Chemicals (4700 Bermuda Street) : page 17 

 Kinder Morgan, previously GATX (3300 North Delaware Avenue) : page 17 

 PaperWorks, formerly Jefferson Smurfit (5000 Flat Rock Road) : page 17 
Page 3 of 19

20140918 SIP Revision

 Temple – Health Sciences (3401 North Broad Street) : page 17 

 PES Refinery, formerly Sunoco Refinery (3144 Passyunk Avenue): page 17 

 Philadelphia Gas Works – Richmond (3100 East Venango Street): page 17 

 Cardone Industries (5660 Rising Sun Avenue): page 18 

 Temple University – Main Campus (Broad Street and Montgomery Avenue): page 18 

 Grays Ferry Cogeneration Partnership (2600 Christian Street): page 18 

 Veolia Energy Efficiency (2600 Christian Street): page 18 

Documentation of Public Hearing and Certifications 

 Public Hearing Notice: page 19 

 Proof of Publication: page 19 

 Notices to EPA and PADEP: page 19 

 Summary of Comments and responses: page 19 

 David L. Arnold, Acting Director, Air Protection Division, United States Environmental 

Protection Agency, Region III comments; page 19 

 William O’Sullivan, Director, Division of Air Quality, New Jersey Department of Environmental 

Protection comments: page 19 

 Ali Mirzakhalili, Director, Division of Air Quality, State of Delaware Department of Natural 

Resources & Environmental Control comments: page 19 

 Kristian Witt, Technical Director, Compliance Management International, On behalf of Kinder 

Morgan Liquid Terminals comments: page 19 

 Brendan K. Collins, Ballard Spahr LLP, On behalf of Temple University comments: page 19 

 
Page 4 of 19

20140918 SIP Revision

Reasonably Available Control Technology (RACT) State Implementation Plan (SIP) 

Revision for the 1997 8-hour Ozone National Ambient Air Quality Standard (NAAQS) 

Statutory Authority:

 25 Pennsylvania Code Subpart C Article III 

 Philadelphia Air Management Code 3-301 of the Philadelphia Code 

Background: 

The federal Clean Air Act (CAA) of 1990 gives states primary responsibility for achieving the National Ambient Air 

Quality Standards (NAAQS). The NAAQSs are established by the U.S. Environmental Protection Agency (EPA) as 

the maximum concentrations in the atmosphere for specific air contaminants to protect public health and welfare. 

The principal mechanism at the state and local level for complying with the CAA is the State Implementation Plan 

(SIP). A SIP outlines the programs, actions, and commitments a state will carry out to implement its responsibilities 

under the CAA. Once approved by the EPA, a SIP is a legally binding document under both state and federal law. 

In June 2004, EPA designated 126 areas of the country as “non-attainment” under the 1997 8-hour ozone NAAQS. 

Among those non-attainment areas is the Philadelphia-Wilmington-Atlantic City Moderate Non-Attainment Area 

(NAA) that includes three counties in Delaware, five counties in eastern Pennsylvania, and eight counties in 

southern New Jersey. 

On November 29, 2005, EPA published an ozone implementation rule to address nonattainment SIP requirements 

for the 1997 8-hour ozone NAAQS (the Phase 2 Ozone Implementation Rule; 70 FR 71612). In the Phase 2 Ozone 

Implementation Rule, EPA required that states meet the RACT requirements under the 1997 8-hour ozone NAAQS, 

either through a certification that previously adopted RACT controls in their SIP approved by EPA under the 1-hour 

ozone NAAQS continue to represent adequate RACT control levels for 8-hour ozone attainment purposes, or 

through the adoption of new or more stringent regulations that represent RACT control levels (70 FR 71655). 

On September 29, 2006, PADEP submitted on behalf of AMS a SIP revision for Philadelphia County to meet the 

RACT requirements for the 1997 8-hour ozone NAAQS. The 2006 SIP revision consisted of a demonstration that 

Philadelphia County has met the RACT requirements for Nitrogen Oxides (NOx) and Volatile Organic Compounds 

(VOC), and included: (1) A certification that previously adopted RACT controls in Pennsylvania's SIP that were 

approved by EPA for Philadelphia County under the 1-hour ozone NAAQS are based on the currently available 

technically and economically feasible controls, and continue to represent RACT for the 8-hour implementation 

purposes; (2) the adoption of federally enforceable permits that represent RACT control levels for four major VOC 

sources; and (3) a negative declaration that certain VOC sources do not exist in Philadelphia County. 

In November 2008, several parties challenged EPA's Phase 2 Ozone Implementation Rule. In particular, EPA's 

determination that compliance with the NOx SIP Call could satisfy NOx RACT requirements for EGUs in 

nonattainment areas was challenged. As a result of this litigation, the Court decided that the provisions in the Phase 

2 Ozone Implementation Rule providing that a state need not perform (or submit) a NOx RACT analysis for EGU 

sources subject to a cap-and-trade program in accordance with the NOx SIP Call were inconsistent with the statutory 

requirements of section 172(c)(1) of the CAA. In the 2006 SIP Revision, AMS certified as RACT, 25 PA Code 

Chapter 145 Subchapter A, which established a NOx budget and trading program for EGUs and other large sources 

to control transport emissions. 

On June 22, 2010, PADEP submitted another SIP revision supplementing Philadelphia County's RACT 

demonstration under the 1997 8-hour ozone standard. The 2010 SIP revision consisted of: (1) The adoption of two 

regulations to meet control technique guidelines (CTG) RACT requirements, and (2) a negative declaration for a 

CTG source category. 
Page 5 of 19

20140918 SIP Revision

On August 26, 2008 (73 FR 50270), EPA published a notice of proposed rulemaking (NPR) proposing approval of 

the 2006 SIP revision. On June 19, 2013 (78 FR 36716), EPA withdrew its August 26, 2008 proposed rule due to the 

Court decision regarding the Phase 2 Ozone Implementation Rule EPA determined it could not approve the 

presumption in the 2006 SIP submittal that the NOx SIP Call constitutes RACT for EGU sources in Philadelphia 

County. In addition, EPA also determined that the 2006 SIP revision did not specifically and sufficiently address 

source-specific RACT controls for the 1997 8-hour ozone NAAQS required under 25 Pa Code 129.91-94. AMS had 

previously determined source-specific RACT controls for 46 major sources in Philadelphia County under the 1-hour 

ozone NAAQS, for which AMS needs to determine RACT under the 1997 8-hour ozone NAAQS. 

On June 19, 2013, EPA also proposed conditionally approval of the Philadelphia County's RACT demonstration 

under the 1997 8-hour ozone NAAQS, as provided in the 2006 and the 2010 SIP revisions. The conditional 

approval was finalized on December 13, 2013 (78 FR 75902). The conditional approval was based upon PADEP’s 

April 26, 2013 letter in which AMS committed to submit to EPA additional SIP revisions to address the deficiencies 

in the current RACT demonstration for Philadelphia County. The SIP revisions will provide source-specific RACT 

determinations for 10 major sources of VOC and NOx in Philadelphia County, as listed in EPA’s final notice, and a 

certification that previously adopted source-specific RACT controls approved by EPA in Pennsylvania's SIP for the 

1-hour ozone NAAQS for the remaining sources in Philadelphia County continue to adequately represent RACT for 

the 1997 8-hour ozone NAAQS. 

Notice that AMS proposed to revise or issue RACT plan approvals for the above referenced facilities was published 

in the Philadelphia Daily News on September 18, 19, and 22 of 2014. Notice that AMS proposed to revise the SIP 

to meet the requirements of the RACT set forth by the Clean Air Act under the 8-hour Ozone NAAQS was 

published in the Philadelphia Daily News on September 18, 2014 only. Notice of both proposed actions was also 

published in the Pennsylvania Bulletin on September 20, 2014. See 44 Pa. B. 5975. Written comments on the 

proposed actions were due to AMS by, and a public hearing on the proposed actions was scheduled for, October 22, 

2014. Id. 

There were no requests for a public hearing. During the public comment period, AMS received comments from five 

(5) commentators: David L. Arnold, Acting Director, Air Protection Division, United States Environmental 

Protection Agency, Region III (EPA); William O’Sullivan, Director, Division of Air Quality, New Jersey 

Department of Environmental Protection (NJDEP); Ali Mirzakhalili, Director, Division of Air Quality, State of 

Delaware Department of Natural Resources & Environmental Control (DEDNREC); Kristian Witt, Technical 

Director, Compliance Management International (CMI), On behalf of Kinder Morgan Liquid Terminals (KMLT); 

Brendan K. Collins, Ballard Spahr LLP, On behalf of Temple University (Temple). 

SIP Revision: 

This SIP revision is intended to partially satisfy AMS’ commitment by addressing source-specific RACT 

determinations for certain major sources of VOC and/or NOx; certifying that previously adopted source-specific 

RACT controls approved by EPA in the Pennsylvania’s SIP under the 1-hour ozone NAAQS continue to adequately 

represent RACT for the 1997 8-hour ozone NAAQS; and certifying that certain sources that were applicable to the 

1-hour ozone RACT are now minor sources or have shut down and are no longer applicable to the 1997 8-hour 

ozone RACT for the following facilities. 

Table 1 provides a list of all major sources of NOx and/or VOC, emission sources subject to RACT, and the page 

number for the RACT technical memos. The technical memos address source-specific RACT determinations and/or 

provide certifications that the 1-hour ozone NAAQS continue to adequately represent RACT for the 1997 8-hour 

ozone NAAQS. 

Table 2 provides a list of sources not applicable to the 1997 8-hour ozone RACT because they are now minor 

sources or shut down. AMS is certifying that the sources listed in Table 2 are no longer applicable to the 1997 8-

hour ozone RACT (see technical memos). 
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20140918 SIP Revision

This SIP revision also includes revisions to the approved RACT plan approvals for the following facilities: 

Honeywell, formerly Sunoco Chemicals (4700 Bermuda Street); Kinder Morgan, previously GATX (3300 North 

Delaware Avenue); PaperWorks, formerly Jefferson Smurfit (5000 Flat Rock Road); Temple – Health Sciences 

(3401 North Broad Street); PES Refinery, formerly Sunoco Refinery (3144 Paasyunk Avenue); Philadelphia Gas 

Works – Richmond (3100 East Venango Street); Cardone Industries (5660 Rising Sun Avenue). 

This SIP revision also includes new RACT plan approvals which were not part of the 1-hour ozone RACT for the 

following facilities: Temple University – Main Campus (Broad Street and Montgomery Avenue); Grays Ferry 

Cogeneration Partnership (2600 Christian Street); Veolia Energy Efficiency (2600 Christian Street). 
Page 7 of 19

20140918 SIP Revision

Table 1 List of Major Sources of NOx and/or VOC subject to RACT1

Facility Name / Address 

Major 

Source of RACT Emission Sources 

NOx VOC 

Philadelphia Energy Solutions Refining and Marketing LLC (including Tank Farm) (3144 Passyunk Ave) 

X X 

• 27 refinery fuel gas-fired process heaters • 3 refinery fuel gas-fired boilers • Two(2) Fluid Catalytic Cracking Units (FCCUs) • Five (5) diesel-fired non-emergency reciprocating internal combustion engines (RIC• Eleven (11) emergency generators and fire pumps • storage tanks • Eight (8) cooling towers • Two (2) loading operations • oil-water separators • degreasers vats PES Tank Farm

• twenty one (21) internal floater storage tanks with capacities between 2.6-4.9 million • two (2) open floater tanks, each with a capacity of 4.8144 million gallons • one (1) oil-water separator • one (1) propane loading rack with flare (60,000 lbs/hr) firing propane/butane • Fugitive emissions • two (2) diesel fire pumps (one 290 hp and the other 255 hp) 

Honeywell International (Formerly Sunoco Chemical) – Frankford Plant (4700 Bermuda Street) 

X X 

• two (2) 260 MMBTU/hr, firing waste residue, gas or #6 fuel oil boilers • one (1) 381MMBTU/hr, firing gas or #6 fuel oil boiler •50 HP (below 20 MMBTU/hr), firing #2 fuel oil boiler • Oxidation Processes OX-501, OX-401, OX-301/302, OX-201/202 • twenty-five (25) Distillation Columns • seven (7) Reactors • Barge Loading •Tank Truck, Rail Car, and Drum Loading • forty (40) Storage tanks • Fugitive Emission Sources: pumps, valves, flanges, compressors, pressure relief valves, rupt

• Rail Car Cleaning • Wastewater Facilities 

Paperworks Industries X • two (2) 92.27 MMBTU/hr boilers 

1 In case of any discrepancy between data listed in Table 1 and the technical memos, the technical memos represent the most accurate s
Page 8 of 19

20140918 SIP Revision

(formerly Jefferson Smurfit) (5000 Flat Rock Road) 

• one (1) 240 MMBTU/hr boiler 

Sun Chemical (3301 Hunting Park Avenue) X 

• The Manufacturing Group 140 – Conventional Blends include 25 mixers, 3 bench-toand 2 tanks.• The Manufacturing Group 140 – Rotor Stator Production include 5 mixers. • The Manufacturing Group 142 – Horizontal Mill Station include 2 mixers • The Manufacturing Group 141 – Ball Mill Production include 1 ball mill • The Manufacturing Group 143 – Kady Mill Production include 4 kady mills. 

Newman and Company, Inc. (6101 Tacony Street) X 

• 118 MMBTU/hr water tube boiler • twenty-nine (29) natural gas fired space heaters with less 500,000 BTU/hr heat capa• two (2) natural gas fired power washers with less 500,000 BTU/hr heat capacity • one (1) 973,000 BTU/hr #2 oil burning fire pump. 

Exelon (formerly PECO) – Southwark Station (2501 S. Delaware Avenue) 

X 

• four 15.5 MW combustion turbines burning No.2 oil 

Naval Surface Warfare Center Cardrock Division (formerly NAVSSES) (5001 South Broad Street) 

X 

Combustion units. • Bldg 633 - 202 MMBTU/hr wall-fired ship's boiler • Twenty (20) new small boilers/heaters each less than 10 MMBTU/hr Emergency Units• B77H 268 bhp diesel fired Emergency Generator • B4 88 bhp natural gas fired Emergency Generator G1 • B4 154 bhp natural gas fired Emergency Generator G2 • B29 54 bhp natural gas fired Emergency Generator • B1000 186 bhp natural gas fired Emergency Generator • B485 208 hp diesel fired Fire Pump • B485 208 hp diesel fired Fire Pump • B542 115 hp diesel fired Fire Pump Engines and Turbines • B77H 16.42 MMBTU/hr Marine Engine Test Cell 1 • B77H 206.9 MMBTU/hr Engine Testing Gas Turbine DDG51 (LM-2500A) • B77H 206.9 MMBTU/hr Engine Testing Gas Turbine DDG51 (LM-2500B) • B77H 40.6 MMBTU/hr Engine Testing Gas Turbine CG-47 (K-17) • B77H 37.4 MMBTU/hr Engine Testing Gas Turbine GTG#2 (K-34) • B633 51.2 MMBTU/hr Engine Testing LSD-41 ALPHA • B633 51.2 MMBTU/hr Engine Testing LSD-41 Bravo 
Page 9 of 19

20140918 SIP Revision

• B633 ≤ 42.1 MMBTU/hr Engine Testing TF-40 Gas Turbine Test Cell 2 

• B77H 37.4 MMBTU/hr Engine Testing Gas Turbine GTG#1 (K-34) • B77H 4.72 MMBTU/hr Engine Testing Gas Turbine Auxiliary (RIMMS) • B87 2.56 MMBTU/hr Engine Testing Diesel Generator • B633 238 MMBTU/hr P-104 Test Cell • B77H 311.8 MMBTU/hr DD(X) MT-30 • B77H 51.4 MMTU/hr DD(X) LM-500 • B77H 55.6 MMTU/hr DD(X) RR-4500 • DDX Test Cell 418.8 MMTU/hr • B87 80 kW Caterpillar D80-4 Test Engine Generator • B77H 4.79 MMBTU/hr Diesel Engine Testing EDG, CAT C-18 

Temple University – Health Sciences Campus (3401 N. Broad Street) 

X 

•one (1) 76.4 MMBTU/hr boiler • two (2) <2 MMBTU/hr boilers •Twenty (20) emergency generators and fire pumps 

Sunoco Partners Marketing & Terminals L.P - Belmont Terminal (2700 Passyunk Avenue) 

 X 

• Gasoline Truck Loading with Vapor Control Units products loading racks 

• Distillate Truck Loading • one (1) Emergency Generator • nine (9) Storage Tanks (with vapor pressure > 1.5 psia) 

Aker Philadelphia Shipyard, Inc. (2100 Kitty Hawk Avenue) 

 X 

• Two (2) 12.6 MMBtu/Hr boilers burning natural gas; • Five (5) boilers each rated less than 2 MMBtu/Hr burning natural gas • Two (2) 4 MMBtu/Hr boilers burning natural gas • Painting operations 

Inolex Chemical Company (Swanson & Jackson Streets) 

X 

• One (1) 49 MMBtu/Hr. boiler • One (1) 20 MMBtu/hr. boiler • One (1) 6.5 MMBtu/Hr. boiler 

Allied Tube & Conduit Corporation (11350 Norcom Road) 

 X 

• One (1) tube mill acid cleaning process • One (1) Mill 1 Area Space Heater with a capacity of 3.76 MMBtu/Hr • Four (4) Warehouse Space Heaters each with a capacity of 801,000 Btr/Hr. 

Cardone Industries (5660 Rising Sun Avenue) 

 X 

Surface Coating • Electrostatic Disk Spray Booth • Manual Spray Booth Post Spray • Floor Type Spray Booth Pre-Spray • Touch-up Spray Booth • Touch-up Spray Booth • Manual Spray Booth • Manual Spray Booth • Manual Spray Booth 
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Cold-Cleaning Degreasers • Vibrator Flowthru 55ft • Vibrator 6ft • Ultra Tub Vibrator 17 (5 ft) • Ultra Tub Vibrator 3 (5ft) • Ultra Tub Vibrator (3ft) • Small Parts Tank (4sq ft) • Small Parts Tank (4sq ft) • Small Parts Tank (4sq ft) • Auger Tumbler Hurricane Combustion Units • Conveyorized Forced Air Drying Oven; 1.5 MMBTU/hr • Goff Hydropulse Washer; 0.5 MMBTU/hr • Goff Hydropulse Washer; 0.5 MMBTU/hr • Tally Washer; 0.3 MMBTU/hr • Washer, American Metal Wash; 0.3 MMBTU/hr • Parts Washer Beltwasher 2310; 0.8 MMBTU/hr • Water Heaters (2) Instant; 0.94 MMBTU/hr • Parts Washing Machine; 0.4 MMBTU/hr • Ransohoff tunnel washer: 1.9 MMBTU/hr • Goff Hydropulse HP-6 Washer; 0.3 MMBTU/hr • Goff Hydropulse HP-3SC (Autoline); 0.3 MMBTU/hr • Goff Hydropulse HP-63 Washer; 0.3 MMBTU/hr • Fulton Thermal Liquid Heater; 2.4 MMBTU/hr • Fulton Thermal Liquid Heater 2.4 MMBTU/hr • Propane Backup System Vaporizer; 0.84 MMBTU/hr • Hot Water Washing Machine (Kuhl); 4.65 MMBTU/hr • Hot Water Washing Machine (Ransohoff); 5.3 MMBTU/hr • HPI Belt Washer System #3; 0.44 MMBTU/hr • HPI Belt Washer 1610WR-SO; 0.44 MMBTU/hr • Detergent Belt Washer 0.8 MMBTU/hr • Steam Cleaner; 257,600 BTU/hr • Steam Cleaner; 257,600 BTU/hr • Lakeview water evaporator; 0.9 MMBTU/hr • Acid Dip tank with tumbler 0.4 MMBTU/hr • Backup Propane System Burner; 0.84 MMBTU/hr 

• Boiler Hot Water; 2.2 MMBTU/hr 
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• Two (2) Hot Air Unit; 0.4 MMBTU/hr 

• Hot Air Unit; 0.8 MMBTU/hr • Two (2) Hot Air Unit; 2.2 MMBTU/hr • Eight (8) Carrier HVAC 48TJD020 Roof unit; 0.270 MMBTU/hr • Three (3) Carrier HVAC 48DKD028 Roof unit; 0.255 MMBTU/hr • Two (2) Cambridge HVAC C390 Roof unit; 0.4 MMBTU/hr • Seven (7) Cambridge HVAC C600 Roof unit; 0.582 MMBTU/hr • Twenty-five (25) Cambridge HVAC C900 Roof unit; 0.9 MMBTU/hr 

• Three (3) Cambridge HVAC C1200 Roof unit; 1.2 MMBTU/hr • Cambridge HVAC M-136; 4.8 MMBTU/hr Burnout Ovens • Burnout Oven (8 bskt) w/ Integral Afterburner; 2 MMBTU/hr • Two (2) Burnout Oven (8 bskt) w/ Integral Afterburner; 3 MMBTU/hr • Six (6) Burnout Oven (12 bskt) w/ Integral Afterburner; 3 MMBTU/hr • Seghers Fluid Bed Oven B-3111/RAN; 0.93 MMBTU/hr • Burnout Oven w/ Integral Afterburner (Guspro 12 basket); 3 MMBTU/hr • Burnout Oven w/ Integral Afterburner (1 basket); 0.70 MMBTU/hr Emergency Generator Onan Backup Generator System – Diesel; 1.9 MMBTU/hr 

MIPC LLC - Philadelphia Terminal (formerly ConocoPhillips) (G Street & Hunting Park Avenue) 

 X 

• One Truck Loading Rack with Vapor Recovery Unit and Transmix Loading Spot, • Five Light Petroleum Storage Tanks (#1303, #1322, #1311, #1312, & #1314), • Three Additive Storage Tanks (#1300, #1350, & #1351), • One Transmix Storage Tank (#1330), • Two Oil/Water Separators, and • Light Liquid/Vapor Components Fugitives. 

University of Pennsylvania (3451 Walnut Street) 

X 

• Nine (9) heaters and furnaces rated less than 10 MMBTU/hr each burn natural gas; • 15 emergency generators with capacities ranging between 75 kW - 750 kW that each natural gas; • 41 emergency generators with capacities ranging between 150 kW – 1,750 kW that diesel; • Two (2) fire pumps with capacities ranging between 150 hp – 187 hp each burn dies• One (1) peak-shaving generator with a capacity of 2,000 kW and has Selective CataReduction (SCR) that burns diesel. 

Philadelphia Prison System (8001 State Road) X 

• 57 boilers rated less than 15 MMBtu/Hr burning No. 2 oil/ natural gas; • 10 emergency generators less than or equal to 2,200 hp burning diesel; • One (1) 365 hp chiller burning natural gas 
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Kinder Morgan 

 X 

• One (1) 490 hp emergency • Two (2) 85 hp air compressors • One (1) 13.4 MMBtu/Hr boiler • One (1) 6.7 MMBtu/Hr boiler • 112 storage tanks (81 storage tanks with capacities greater than or equal to 40,000 gstorage tanks with capacities less than 40,000 gallons) • Marine vessel loading • Tank truck/tank car loading • Fugitive emissions from process piping pumps, valves, & flanges • Tank cleaning and degassing operation • Soil vapor extraction system with CatOx • Sand blasting of tanks (listed as “insignificant sources” on Title V Operating Permit • Painting of tanks (listed as “insignificant sources” on Title V Operating Permit V95• Sump tank (listed as “insignificant sources” on Title V Operating Permit V95-044) • Catch basins (listed as “insignificant sources” on Title V Operating Permit V95-044

• Two oil water separator (Receives <200 gallons of organic materials per day, listed “insignificant sources” on Title V Operating Permit V95-044) • Drumming operations (listed as “insignificant sources” on Title V Operating Permit 

• Steam cleaning of equipment (listed as “insignificant sources” on Title V Operating 044) • Chemical dryers (listed as “insignificant sources” on Title V Operating Permit V95-• Pipe cleaning (listed as “insignificant sources” on Title V Operating Permit V95-044• Flushing of tanks with incoming products (listed as “insignificant sources” on Title 

Permit V95-044) • Fire equipment (listed as “insignificant sources” on Title V Operating Permit V95-0• Mobile tanks (500 gallons each, listed as “insignificant sources” on Title V OperatinV95-044) • Tanks 1 (Emergency containment tank, listed as “insignificant sources” on Title V OPermit V95-044) • Tanks 2 and 3 (Emergency containment tank, listed as “insignificant sources” on TitOperating Permit V95-044) • Tank no. 471 (#2 oil for the vapor incinerator, listed as “insignificant sources” on TiOperating Permit V95-044) • Tank no. 420 (#2 oil for the boilers, listed as “insignificant sources” on Title V Oper

V95-044) 

Philadelphia Gas Works - Richmond (3100 East Venango St) X 

• six (6) Liquefied Natural Gas (LNG) vaporizer heaters between 94.1 and 105.0 MM•five (5) boiler/heaters of 11 MMBTU/hr or less • four (4) simple cycle combustion turbines of 13.7 MMBTU/hr or less(two Solar Gas compressor and two Solar gas turbine electric generators) 
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20140918 SIP Revision

• two (2) 170 HP emergency generators • three (3) 295 HP engines for fire pumps 

Plains Products Terminal LLC (3400 South 67th St) 

 X 

• One (1) 20 MMBTU/hr thermal fluid heater; • One (1) 4.74 MMBtu/Hr boiler; • Six (6) 0.25 MMBTU/hr space heating units (listed as “insignificant sources” on TitOperating Permit V10-025); • 13 petroleum/organic products storage tanks each with a capacity greater than or equgallons; • 7 petroleum/organic products storage tanks each with a capacity less than or equal to 

gallons; • 23 storage tanks each with a capacity each less than 4,725,000 gallons (listed as “ins

sources” on Title V Operating Permit V10-025); • Truck loading process including loading trucks at Rack and at Recovery Tanks;

• Non-gasoline marine loading of petroleum/organic products with a Reid Vapor Presof less than 4.0; • Fugitive emissions from light liquids and gasoline from pumps, valves, & flanges; • Removal of tank water bottoms (listed as “insignificant sources” on Title V Operatin

V10-025);• Tank cleaning and repair (listed as “insignificant sources” on Title V Operating Perm

025); • Parts cleaner (listed as “insignificant sources” on Title V Operating Permit V10-025• Additional fugitive emissions source (listed as “insignificant sources” on Title V OpPermit V10-025); • Lubricity additive system at the North Terminal (listed as “insignificant sources” on 

Operating Permit V10-025); • Lubricity additive system at the South Terminal (listed as “insignificant sources” on Operating Permit V10-025); • Miscellaneous activities and equipment (listed as “insignificant sources” on Title V Permit V10-025).

Navy Foundry and Propeller Center (Navy Yard, Building 592) 

X X 

NOx Souces Building 20• Reverbatory Furnace; 18 MMBTU/hr Natural Gas • 2 Sand Core Ovens; 15 MMBTU/hr total Natural Gas • 2 Crucible Furnaces; <20 MMBTU/hr eachNatural Gas • Stress Relieving Oven; 20 MMBTU/hr Natural Gas • 2 Heat Treating Ovens; 8.8 MMBTU/hr each Natural Gas • 6 Ladle Preheaters; <20 MMBTU/hr each Natural Gas • 2 Small Ovens; <20 MMBTU/hr each Natural Gas • 5- air rotating units; 1.875 MMBTU/hr Natural Gas Powrmatic (Model # TE41) 
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• 7- make-up air units; 3.0 MMBTU/hr Natural Gas Powrmatic (Model # GA-227) • 1- air handling unit; 0.4 MMBTU/hr Natural Gas Johnson York (Model # J20ZJN3• 1- Make-up air unit; 1.25 MMBTU/hr Natural Gas Powermatic (Model # MA-100) • 1-Rooftop heater; 0.250 MMBTU/hr Natural Gas Reznor (Model # RDH-250) • Emergency Generator; 20 KW Natural Gas Building 546 • 3- Air rotating units; 2.2 MMBTU/hr Natural gas Powrmatic (Model # TE41) • 2-Heater; 0.125 MMBTU/hr Natural Gas Modine (Model # HDS-125) Building 592 • 1- Air rotation unit; 2.2 MMBTU/hr Natural gas Powrmatic (Model # TE41) Building 712 • 2- boilers; 0.52 MMBTU/hr Natural gas Weil McLain (Model # LGB-05-S) Building 1029 • 2- Air rotating units; 2.2 MMBTU/hr Natural gas Powrmatic (Model # TE51)

VOC Sources Building #20 • Film Developing (X-ray, NDT room) Hydroquinone Building #1029 • Propeller Cleaning • Simple Green Industrial/ Keynote Cleaner 

Grays Ferry Cogeneration Partnership (2600 Christian Street) 

X 

• one (1) front wall fired boilers rated 1119 MMBTU/hr • one (1) combined cycle combustion turbine rated 1515 MMBTU/hr (135 MW) 

Temple University – Main Campus (Broad Street and Montgomery Avenue) X 

• 16 Boilers and hot water heaters <20 MMBTU/hr • 5 Boilers >= 20 MMBTU/Hr and <50 MMBTU/Hr • three (3) BMCEP Boilers (Victory Energy Models VS-4-68), with a natural gas heat of 91.3 MMBTU/Hr and a #2 fuel oil heat input rating of 86.8 MMBTU/Hr • 10 Standby Electric Generating units each 2250 HP • 59 emergency generators and fire pumps, and 20 catalyst oxidizers

Veolia-Energy Efficiency (PA) LLC (2600 Christian Street) 

X 

• two (2) new 297.91 MMBTU/hr boilers
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Table 2 – Facilities not applicable to the 1997 8-hour RACT2

Facility (Address) Determination 

Philadelphia Ship Repair Inc. 

(5195 South 19th Street) 

Not a major source of NOx or VOC 

Children’s Hospital of Philadelphia 

(34th & Civic Center Boulevard) 

Not a major source of NOx or VOC 

Northeast Water Pollution Control 

Plant 

(3899 Richmond Street) 

Not a major source of NOx or VOC 

Southwest Water Pollution Control 

Plant 

(8200 Enterprise Avenue) 

Not a major source of NOx or VOC 

Mondelez (formerly Nabisco) 

(12000 East Roosevelt Blvd.) 

Not a major source of NOx or VOC 

The Bellevue 

(200 South Broad Street) 

Not a major source of NOx or VOC 

Amerada Hess 

(1630 South 51st Street) 

Not a major source of NOx or VOC 

Philadelphia Gas Works – Passyunk 

Plant 

(3100 Passyunk Avenue) 

Not a major source of NOx or VOC 

The Philadelphian Condominium 

(2401 Pennsylvania Avenue) 

Not a major source of NOx or VOC 

SEPTA – Berridge/Courtland 

(200 West Wyoming Avenue) 

Not a major source of NOx or VOC 

Smith-Edwards-Dunlap 

(2867 East Allegheny Avenue) 

Not a major source of NOx or VOC 

Interstate Brands (formerly Continental 

Baking) 

 (9801 Blue Grass Road) 

Shut Down 

Budd Company 

(2450 West Hunting Park Avenue) 

Shut Down 

Amoco Oil 

(63rd Street and Passyunk Avenue) 

Shut Down 

Kurz-Hastings 

(10901 Dutton Road) 

Shut Down 

Lawrence-McFadden 

(7430 State Road) 

Shut Down 

Philadelphia Baking Company 

(Grant Avenue and Roosevelt Blvd.) 

Shut Down 

Rohm and Haas 

(5000 Richmond Street) 

Shut Down 

SBF Communications 

(3747 Ridge Avenue) 

Shut Down 

Tasty Baking 

(2801 Hunting Park Avenue) 

Shut Down 

Aldan Rubber 

(2701 East Tioga Street) 

Shut Down 

Braceland Brothers 

(7625 Suffolk Avenue) 

Shut Down 

Graphic Arts Shut Down 

 

2

 See technical memos for more details. 
Page 16 of 19

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(4100 Chestnut Street) 

O’Brien Cogeneration (later Calpine) – 

Northeast 

 (3900 Richmond Street) 

Shut Down 

O’Brien Cogeneration (later Calpine) – 

Southwest 

(8200 Enterprise Avenue) 

Shut Down 

Pearl Pressman Liberty 

(912 North 5th Street) 

Shut Down 

Arbill 

(2207 West Glenwood Ave.) 

Shut Down 

Eastman Chemical (formerly 

McWhorter) 

(7600 State Road) 

Shut Down 

Transit America 

(One Red Lion Road) 

Shut Down 

 
Page 17 of 19

20140918 SIP Revision

Technical Memos / RACT Plan Approvals 

(files attached separately) 

 Philadelphia Energy Solutions Refining and Marketing LLC (including Tank Farm) (3144 Passyunk Ave) 

Philadelphia Energy Solutions Refining and Marketing LLC (including Tank Farm) [01501] - TECHNICAL MEMO.pdf 

Philadelphia Energy Solutions Refining and Marketing LLC (including Tank Farm) [01501] - RACT PLAN APPROVAL.pdf 

Philadelphia Energy Solutions Refining and Marketing LLC [01501] - Sept 2014 RACT Update.pdf 

 Honeywell International (Formerly Sunoco Chemical) – Frankford Plant (4700 Bermuda Street) 

Honeywell International (Formerly Sunoco Chemical) – Frankford Plant [01551] - TECHNICAL MEMO.pdf 

Honeywell International (Formerly Sunoco Chemical) – Frankford Plant [01551] - RACT PLAN APPROVAL.pdf 

Honeywell International (Formerly Sunoco Chemical) – Frankford Plant [01551] - BART ANALYSIS.pdf 

 Paperworks Industries (5000 Flat Rock Road) 

Paperworks Industries [01566] - TECHNICAL MEMO.pdf 

Paperworks Industries [01566] - RACT PLAN APPROVAL.pdf 

 Sun Chemical (3301 Hunting Park Avenue) 

Sun Chemical [02052] - TECHNICAL MEMO.pdf 

 Newman and Company, Inc. (6101 Tacony Street) 

Newman and Company, Inc [03489] - TECHNICAL MEMO.pdf 

 Exelon (formerly PECO) – Southwark Station (2501 S. Delaware Avenue) 

Exelon (formerly PECO) – Southwark Station [04905] - TECHNICAL MEMO 

 Naval Surface Warfare Center Cardrock Division (formerly NAVSSES) (5001 South Broad Street) 

Naval Surface Warfare Center Cardrock Division (formerly NAVSSES) [09724] - TECHNICAL MEMO.pdf 

 Temple – Health Sciences (3401 N. Broad Street) 

Temple – Health Sciences [08906] - TECHNICAL MEMO.pdf 

Temple – Health Sciences [08906] - RACT PLAN APPROVAL.pdf 

 Sunoco Partners Marketing & Terminals L.P - Belmont Terminal (2700 Passyunk Avenue) 

Sunoco Partners Marketing & Terminals L.P - Belmont Terminal [01507] - TECHNICAL MEMO.pdf 

 Aker Philadelphia Shipyard, Inc. (2100 Kitty Hawk Avenue) 

Aker Philadelphia Shipyard, Inc [01569] - TECHNICAL MEMO.pdf 

 Inolex Chemical Company (Swanson & Jackson Streets) 

Inolex Chemical Company [02059] - TECHNICAL MEMO.pdf 

 Allied Tube & Conduit Corporation (11350 Norcom Road) 

Allied Tube & Conduit Corporation [03363] - TECHNICAL MEMO.pdf 

 Cardone Industries (5660 Rising Sun Avenue) 
Page 18 of 19

20140918 SIP Revision

Cardone Industries [03887] - TECHNICAL MEMO.pdf 

Cardone Industries [03887] - RACT PLAN APPROVAL.pdf 

 MIPC LLC - Philadelphia Terminal (formerly ConocoPhillips) (G Street & Hunting Park Avenue) 

MIPC LLC - Philadelphia Terminal (formerly ConocoPhillips) [05004] - TECHNICAL MEMO.pdf 

 University of Pennsylvania (3451 Walnut Street) 

University of Pennsylvania [08912] - TECHNICAL MEMO.pdf 

 Philadelphia Prison System (8001 State Road) 

Philadelphia Prison System [09519] - TECHNICAL MEMO.pdf 

 Kinder Morgan 

Kinder Morgan [05003] - TECHNICAL MEMO.pdf 

Kinder Morgan [05003] - RACT PLAN APPROVAL.pdf 

Kinder Morgan [05003] – Vendor Quote (redacted).pdf 

 Philadelphia Gas Works - Richmond (3100 East Venango St) 

Philadelphia Gas Works - Richmond [04922] - TECHNICAL MEMO.pdf 

Philadelphia Gas Works - Richmond [04922] - RACT PLAN APPROVAL.pdf 

 Plains Products Terminal LLC (3400 South 67th Street) 

Plains Products Terminal LLC [05013] - TECHNICAL MEMO.pdf 

 Navy Foundry and Propeller Center (Navy Yard, Building 592) 

Navy Foundry and Propeller Center [09702] - TECHNICAL MEMO.pdf 

 Grays Ferry Cogeneration Partnership (2600 Christian Street) 

Grays Ferry Cogeneration Partnership [04944] - TECHNICAL MEMO.pdf 

Grays Ferry Cogeneration Partnership [04944] - RACT PLAN APPROVAL.pdf 

 Temple University – Main Campus (Broad Street and Montgomery Avenue) 

Temple University – Main Campus [08905] - TECHNICAL MEMO.pdf 

Temple University – Main Campus [08905] - RACT PLAN APPROVAL.pdf 

 Veolia-Energy Efficiency (PA) LLC (2600 Christian Street) 

Veolia-Energy Efficiency (PA) LLC [10459] - TECHNICAL MEMO.pdf 

Veolia-Energy Efficiency (PA) LLC [10459] - RACT PLAN APPROVAL.pdf 

 Sources no longer applicable to 1997 8-hour RACT 

Former RACT - TECHNICAL MEMO 

Former RACT - NE Water Pollution Control Plant [09513] - TECHNICAL MEMO 

Former RACT - SW Water Pollution Control Plant [09515] - TECHNICAL MEMO 

 
Page 19 of 19

20140918 SIP Revision

Documentation of Public Hearing and Certifications 

(files attached separately)

 Public Hearing Notice 

Public Notice Daily News published 20140918.pdf 

Public Notice PA Bulletin 20140920.pdf 

 Proof of Publication 

Public Notice Daily News published 20140918 Proof of Publication.pdf 

 Notices to EPA and PADEP 

Notification to Neighboring States.pdf 

 Summary of Comments and responses 

RACT Comment Response FINAL __20150112.pdf 

 David L. Arnold, Acting Director, Air Protection Division, United States Environmental Protection 

Agency, Region III comments 

EPA Comments to Proposed RACT SIP_10 16 14.pdf 

 William O’Sullivan, Director, Division of Air Quality, New Jersey Department of Environmental 

Protection comments 

NJDEP RACT SIP Revision - State of New Jersey.pdf 

 Ali Mirzakhalili, Director, Division of Air Quality, State of Delaware Department of Natural Resources & 

Environmental Control comments 

DNREC Comments to RACT SIP Proposal.pdf 

 Kristian Witt, Technical Director, Compliance Management International, On behalf of Kinder Morgan 

Liquid Terminals comments 

CMI response.pdf 

 Brendan K. Collins, Ballard Spahr LLP, On behalf of Temple University comments 

Temple Comments on Proposed Permit Revision.PDF