Page 1 of 10

20150812 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)

20150812 SIP Revision
Page 2 of 10

20150812 SIP Revision

Table of Contents

Statutory Authority: page 3

Background: page 3

SIP Revision: page 5

Technical Analysis Memos: page 6-7

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

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

 Sun Chemical (3301 Hunting Park Avenue)

 Allied Tube & Conduit Corporation (11350 Norcom Road)

 Cardone Industries (5660 Rising Sun Avenue)

 Exelon Generating Company – Richmond Station (3901 N. Delaware Avenue, Philadelphia, PA 19137)

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

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

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

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

 University of Pennsylvania (3451 Walnut Street)

 Philadelphia Prison System (8001 State Road)

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

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

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

RACT Plan Approvals: page 6-7

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

Avenue)

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

 Exelon Generating Company – Richmond Station (3901 N. Delaware Avenue, Philadelphia, PA 19137)

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

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

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

 Philadelphia Prison System (8001 State Road)

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

Documentation of Public Hearing and Certifications: files attached separately

 Public Hearing Notice

 Proof of Publication

 Notices to EPA and PADEP

 Public Hearing Testimony

 Summary of Comments and responses

 Written comments

o Diana Esher, Director, Air Protection Division, United States Environmental Protection Agency, 

Region III (EPA)

o Francis Steitz, Director, Division of Air Quality, New Jersey Department of Environmental 

Protection (NJDEP)

o Joseph Minott, Executive Director; Ben Hartung, Staff Attorney, Clean Air Council.

o Joseph Minott, Executive Director, Clean Air Council; Sam Bernhardt, Food and Water Watch; 

Craig Robbins, Action United 
Page 3 of 10

20150812 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 the 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 4 of 10

20150812 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.

On June 26, 2014 and September 20, 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. Notice that AMS proposed to revise or issue RACT plan approvals for certain facilities was published in the 

Philadelphia Daily News on September 18, 19, and 22 of 2014.

On February 18, 2015, PADEP, on behalf of AMS, submitted the completed 1997 8-hour Ozone RACT SIP to EPA. 

In a letter received March 3, 2015, EPA determined the SIP submittal to be administratively and technically 

complete.

Notice to revise or issue RACT plan approvals for certain facilities was published in the Philadelphia Daily News on 

August 12, 13, and 14 of 2015. 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 

August 12, 2015 only. Notice of both proposed actions was also published in the Pennsylvania Bulletin on August 

15, 2015. See 45 Pa. B. 4799. Written comments on the proposed actions were due to AMS by September 14, 2015 

but extended until September 30, 2015. A public hearing on the proposed actions was scheduled for September 17, 

2015.

A public hearing was held on September 17, 2015. The following people provided testimony: Elizabeth Arnold, 

E.D.G.E.; Ann Dixon, Protecting Our Waters; Peter Winslow, Board Member, Pennsylvania Interfaith Power and 

Light; Susan Saxe, Green Justice Philly; W. Francis Elling, Society of Friends Philadelphia Meeting/Unity Friends 

Meeting; Tamara Clements, Protecting Our Waters; Robert Munk, Citizen; Matt Walker, Community Outreach 

Director, Clean Air Council; Dr. Marta Guttenberg, Member, Clean Air Council; Ron White, Green Justice Philly; 

Ben Hartung, Staff Attorney, Clean Air Council; Mena Ranal on behalf of Dr. Poune Saberi, Physicians for Social 

Responsibility; Maxine McCleary, Action United. 

During the public comment period, AMS received comments from: Diana Esher, Director, Air Protection Division, 

United States Environmental Protection Agency, Region III (EPA); Francis Steitz, Director, Division of Air Quality, 

New Jersey Department of Environmental Protection (NJDEP); and Joseph Minott, (Executive Director), Ben 

Hartung, (Staff Attorney), Clean Air Council; Sam Bernhardt, Food and Water Watch; Craig Robbins, Action 

United. 
Page 5 of 10

20150812 SIP Revision

SIP Revision:

This SIP revision updates RACT plan approvals and technical memos provided in the February 18, 2015, Ozone 

RACT submission to EPA. Table 1 provides a list of facilities and the RACT documentation. Revised technical 

memos and revised RACT plan approval documents are intended to supersede previously submitted documentation.

In addition, this SIP revision includes new RACT plan approvals.

To provide additional clarity and unify the prior submitted documentation with the current SIP revision, AMS is 

providing:

 A summary of major sources of NOx and VOC addressed in the 1997 Ozone RACT submissions by 

Philadelphia Air Management Services (see Table 2).

 A memo providing clarifications regarding RACT certifications and de minimis determinations. (see 

“RACT Clarification Memo.pdf”, attached separately ).
Page 6 of 10

20150812 SIP Revision

Table 1 – Technical Memos / RACT Plan Approvals 

(files attached separately)

FACILITY NAME RACT DOCUMENTATION COMMENTS

Philadelphia Energy Solutions Refining and Marketing LLC 

(including Tank Farm) (3144 Passyunk Ave)

Technical Memo:

 [01501] – TECHNICAL MEMO.pdf

RACT Plan Approval: 

 [01501] – RACT PLAN APPROVAL.pdf

 [01501] – RACT Update July 2015 Rev E.pdf

 [01501] – RACT Cost Effectiveness Update 7-24-15.xlsx

 [01501] – RACT Attachment A.pdf

 [01501] – RACT Attachment B – blueprints.pdf

These files replace the Technical Memo and all RACT Plan 

Approval documents provided in the 20140918 SIP Revision.

The file [01501] – RACT Attachment B – blueprints.pdf is 

NEW.

Honeywell International (Formerly Sunoco Chemical) –

Frankford Plant (4700 Bermuda Street)

Technical Memo:

 [01551] – TECHNICAL MEMO.pdf

RACT Plan Approval:

 [01551] – RACT PLAN APPROVAL.pdf

 [01551] – Attachment A – BART Analysis for Costs.pdf

These files replace the Technical Memo and all RACT Plan 

Approval documents provided in the 20140918 SIP Revision.

Sun Chemical (3301 Hunting Park Avenue)

Technical Memo:

 [02052] – TECHNICAL MEMO.pdf This file replaces the Technical Memo provided in the 20140918 

SIP Revision.

Allied Tube & Conduit Corporation (11350 Norcom Road)

Technical Memo:

 [03363] – TECHNICAL MEMO.pdf This file replaces the Technical Memo provided in the 20140918 

SIP Revision.

Cardone Industries (5660 Rising Sun Avenue)

Technical Memo:

 [03887 – 02287] – TECHNICAL MEMO.pdf This file replaces the Technical Memo provided in the 20140918 

SIP Revision.

Exelon Generating Company – Richmond Station (3901 N. 

Delaware Avenue, Philadelphia, PA 19137)

Technical Memo:

 [04903] – TECHNICAL MEMO.pdf

RACT Plan Approval: 

 [04903] – RACT PLAN APPROVAL.pdf

These files replace the Technical Memo and all RACT Plan 

Approval documents provided in the 20140626 SIP Revision.

Veolia Energy – Schuylkill Station (2600 Christian Street, 

Philadelphia, PA 19146)

Technical Memo:

 [04942] – TECHNICAL MEMO.pdf

RACT Plan Approval:

 [04942] – RACT PLAN APPROVAL.pdf

These files replace the Technical Memo and all RACT Plan 

Approval documents provided in the 20140626 SIP Revision.

Kinder Morgan, previously GATX (3300 North Delaware 

Avenue)

Technical Memo:

 [05003] – TECHNICAL MEMO.pdf

 [05003] – Attachment F of Memo – Vendor Quote 

(redacted).pdf

 [05003] – Attachment G of the Memo – Affidavit for 

MVCU.pdf

These files replace the Technical Memo and all RACT Plan 

Approval documents provided in the 20140918 SIP Revision.

The file [05003] – Attachment G of the Memo – Affidavit for 

MVCU.pdf is NEW.
Page 7 of 10

20150812 SIP Revision

RACT Plan Approval: 

 [05003] – RACT PLAN APPROVAL.pdf

MIPC LLC - Philadelphia Terminal (formerly ConocoPhillips) 

(G Street & Hunting Park Avenue)

Technical Memo:

 [05004] – TECHNICAL MEMO.pdf This file replaces the Technical Memo provided in the 20140918 

SIP Revision.

Plains Products Terminal LLC (3400 South 67th Street)

Technical Memo: 

 [5013] – TECHNICAL MEMO.pdf

RACT Plan Approval: 

 [05013] – RACT PLAN APPROVAL.pdf

 [05013] – Degassing Calc Method Attachment.pdf

This file replaces the Technical Memo provided in the 20140918 

SIP Revision.

The RACT Plan approval documents are NEW, not 

submitted in prior SIP submission.

University of Pennsylvania (3451 Walnut Street)

Technical Memo:

 [08912] – TECHNICAL MEMO.pdf This file replaces the Technical Memo provided in the 20140918 

SIP Revision.

Philadelphia Prison System (8001 State Road) 

Technical Memo:

 [09519] – TECHNICAL MEMO.pdf

RACT Plan Approval:

 [09519] – RACT PLAN APPROVAL.pdf

This file replaces the Technical Memo provided in the 20140918 

SIP Revision.

The RACT Plan approval is NEW, not submitted in prior 

SIP submission.

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

Technical Memo:

 [09702] – TECHNICAL MEMO.pdf This file replaces the Technical Memo provided in the 20140918 

SIP Revision.

Naval Surface Warfare Center Cardrock Division (formerly 

NAVSSES) (5001 South Broad Street)

Technical Memo:

 [09724] – TECHNICAL MEMO.pdf

RACT Plan Approval: 

 [09724] – RACT PLAN APPROVAL.pdf

These files replace the Technical Memo and all RACT Plan 

Approval documents provided in the 20140918 SIP Revision.

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

Technical Memo:

 [10459] – TECHNICAL MEMO.pdf This file replaces the Technical Memo provided in the 20140918 

SIP Revision.
Page 8 of 10

20150812 SIP Revision

Table 2 – Summary of Major Sources of NOx and VOC Addressed in the 1997 Ozone RACT Submissions by Philadelphia Air Management Services

Facility PLIDi Address

1-hr 

RACT 

Source?

(• = yes)ii

Major 

NOx? 

(• = yes)iii

Major 

VOC? 

(• = yes)iv

SIP 

Submittal 

Date

Applicable RACT Requirements

Proposed 

RACT 

Controls 

Revised 

or Newly 

Adopted?v

CTGvi Presumptivevii SourceSpecificviii

Aker Philadelphia Shipyard, inc. 01569

Phila Naval Business 

Ctr., 2100 Kitty Hawk 

Avenue

• 2/18/15 • • No

Allied Tube & Conduit Corp. 03363 11350 Norcom Road • 3/16 • • No

Cardone Industries Inc.ix 03887/

02287

5660 Rising Sun Ave./ 

5501 Whitaker Ave. 

Chew St.

• • 3/16 • • Yes

Exelon Generation Company -

Delaware Station 04901 1325 N. Beach Street • • 2/18/15 • • No

Exelon Generation Company –

Richmond Generating Station 04903 3901 N. Delaware Street • • 3/16 • Yes

Exelon Generation CompanySchuylkill Generating Station 04904 2800 Christian Street • • 2/18/15 • • No

Exelon Generation CompanySouthwark Generating Station 04905 2501 S. Delaware 

Avenue • 2/18/15 • No

Grays Ferry Cogeneration 

Partnershipx 04944 2600 Christian Street • 2/18/15 • Yes

Honeywell International -

Frankford Plant [formerly 

Sunoco Chemical- Frankford 

Plant]

01551 4700 Bermuda Street • • • 3/16 • • • Yes

Inolex Chemical Company 02059 Jackson & Swanson Sts. • 2/18/15 • No

Kinder Morgan Liquids 

Terminals, LLC [formerly 

GATX Terminals Corp.]

05003 3300 N. Delaware 

Avenue • • 3/16 • • • Yes

Monroe Interstate Pipeline 

Company (MIPC), Limited 

Liability Corporation (LLC) -

Philadelphia Terminal

05004 G St & Hunting Park 

Avenue • 3/16 • • No
Page 9 of 10

20150812 SIP Revision

Facility PLIDi Address

1-hr 

RACT 

Source?

(• = yes)ii

Major 

NOx? 

(• = yes)iii

Major 

VOC? 

(• = yes)iv

SIP 

Submittal 

Date

Applicable RACT Requirements

Proposed 

RACT 

Controls 

Revised 

or Newly 

Adopted?v

CTGvi Presumptivevii SourceSpecificviii

Naval Foundry and Propeller 

Center 09702 Navy Yard, Philadelphia, PA 19112 • 3/16 • No

Naval Surface Warfare Center, 

Carderock Divisionxi 09724 5001 South Broad Street, Code 02 • • 3/16 • • Yes

Newman & Company, Inc. 03489 6101 Tacony Street • • 2/18/15 • • No

PaperWorks Industries, Inc. 

[formerly Jefferson Smurfit, 

Corp.]

01566 5000 Flat Rock Road • • 2/18/15 • Yes

Philadelphia Energy Solutions 

Refining and Marketing LLC 

[formerly Sunoco Inc. (R&M)-

Philadelphia]

01501 

-

01517

3144 Passyunk Ave. • • •

6/27/14; 

3/16 • • • Yes

Philadelphia Gas Works -

Richmond Plant 04922 3100 E Venango Street • • 2/18/15 • • Yes

Philadelphia Prison System 09519 8001 State Road • 3/16 • • Yes

Plain Products Terminals LLC 

[formerly Maritank Philadelphia] 05013 67th St. at Schuylkill River • • 3/16 • • Yes

Sunoco Partners Marketing & 

Terminals L.P.- Belmont 

Terminal

01507 2700 Passyunk Avenue • 2/18/15 • • No

Temple University - Health 

Sciences Campus 08906 3401 N. Broad St. • • 2/18/15 • • Yes

Temple University - Main 

Campus 08905 Broad and Montgomery Street • 2/18/15 • • Yes

University of Pennsylvania 08912 3451 Walnut St. • 3/16 • No

Veolia Energy Philadelphia –

Edison Station [formerly 

TRIGEN- Edison]

04902 908 Sansom Street • • 2/18/15 • Yes

Veolia Energy Philadelphia –

Schuylkill Station [formerly 

TRIGEN- Schuylkill]

viii

04942 2600 Christian Street • • 3/16 • Yes
Page 10 of 10

20150812 SIP Revision

Facility PLIDi Address

1-hr 

RACT 

Source?

(• = yes)ii

Major 

NOx? 

(• = yes)iii

Major 

VOC? 

(• = yes)iv

SIP 

Submittal 

Date

Applicable RACT Requirements

Proposed 

RACT 

Controls 

Revised 

or Newly 

Adopted?v

CTGvi Presumptivevii SourceSpecificviii

Veolia Energy Efficiency PA 

(LLC)

viii 10459 2600 Christian Street • 3/16 • Yes

 

i

PLID is the Plant Identification Number.

ii Facility is subject to source-specific RACT limits as specified in a Federally enforceable permit (i.e., RACT permit) and approved in the Pennsylvania SIP (40 CFR 

52.2020(d)(1)) under the 1-hour ozone standard, pursuant to 25 PA Code 129.91 and 129.92. 

iii A facility with potential to emit of NOx of 100 tons per year or greater.

iv A facility with potential to emit of VOC of 50 tons per year or greater.

v AMS is proposing to revise the Pennsylvania SIP ((40 CFR 52.2020(d)(1)) to adopt new, or revise existing, source-specific RACT requirements for the facility.

vi These requirements are specified in regulations in the Pennsylvania SIP that are consistent with EPA’s Control Technique Guidelines (CTGs) for the affected source categories.

vii Presumptive RACT requirements for certain emissions units are specified in 25 PA Code 129.93.

viii Source-specific requirements are/were proposed by the facility on a written RACT proposal and submitted to AMS for approval, pursuant to 25 PA Code 129.91 and 129.92. 

The source-specific requirements have been approved by AMS into a RACT permit for the facility.

ix Formerly Cardone owned various adjacent facilities, from which two facilities were subject to source-specific RACT permits under the 1-hour ozone standard. Facility has two 

separate RACT permits approved in the Pennsylvania SIP under the 1-hour ozone standard, corresponding to PLIDs 3887 and 2237. All adjacent facilities have been aggregated 

and evaluated for RACT as one major source.

x Gray Ferry Cogeneration Plant, Veolia Schuylkill and Veolia Energy Efficiency have been aggregated and are evaluated for RACT as one major source. 

xi

 Facility has two separate RACT permits approved in the Pennsylvania SIP under the 1-hour ozone standard.

ADDITIONAL NOTES: 

The supplemental SIP revision dated March 2016 revises RACT determinations for various facilities which were previously addressed in the February 18, 2015 

RACT SIP revision. All documents included in the supplemental SIP revision are intended to supersede the documents previously submitted.

Sun Chemical (3301 Hunting Park Avenue) was part of the February 18, 2015 RACT SIP Revision as it was a major source of VOC at that time. The facility is 

no longer a major source of VOC and is not part of the supplemental SIP revision dated February 2016.