CITY OF PH ILADELPHIA Department of Public Health
Environmental Protection Division Air Management Services



### InterOffice Memo

To: File

From: Maryjoy Ulatowski

Date: October 16, 2015
Subject: 1997 8-Hour RACT Analysis for Cardone Industries - Rising Sun, Chew Street, and
Whitaker Avenues

(PLID # 03887-2287)

Introduction: The Clean Air Act (CAA) requires that moderate (or worse) ozone nonattainment areas implement reasonably available control technology (RACT) controls on all major sources of volatile organic compounds (VOC) and nitrogen oxides (NOx). Philadelphia County is part of the Philadelphia-Wilmington-Atlantic City moderate ozone nonattainment area for the 1997 8-hour ozone NAAQS. This document presents the findings of a RACT evaluation for the 1997 8-hour ozone standard for Cardone Industries, LLC in Philadelphia. This document supersedes the RACT evaluation/determination submitted on February 18, 2015 for Cardone.

Company Description: Cardone Industries (Rising Sun and Whitaker) is an auto motive parts re-manufacturing company. The company’s air emission sources include spray booths, combustion units, burnout ovens and cold cleaning degreasers.

In the past, Cardone Industries operated several locations in Philadelphia. Starting in 2005, five (5) Cardone locations listed below operated under a Title V Opera ting (TVOP) No. V04-005 and eventually under TVOP No. V09-019. The five (5) locations were determined to be one single facility for air pollution purposes since the locations were close in proximity and interrelated.

1. 321 Chew Street, Philadelphia, PA 19120 (Plant 20) – PLID2237 2. 500 East Erie Avenue, Philadelphia, PA 19134 (Plants 15-17) – PLID 3888 3. 5500 Tabor Road, Philadelphia, PA 19120 (Plant 21) –PLID 3233/T0156 4. 5501 Whitaker Avenue, Philadelphia, PA 19124 (Plants 90-97) –PLID 2287 5. 5660 Rising Sun Avenue, Philadelphia, PA 19120 (Plants 11-14) – PLID 3887

Chew Street Facility The Cardone Chew Facility had a 1hr RACT VOC Permit in 1995 under PLID 2237 . The 1-hour RACT determination for the Chew Street facility (PA Permit Numb er 51-2237, PLID 2237 in 1995), dated May 29, 1995, was approved into the SIP by EPA on 10/30/01 (66 FR 54710). Sources in the 1-hr RACT Permit included:

(1) Degreasing operations with solvent reprocessing and storage (Stoddard Solvent).

As of January 2015, Cardone no longer owns and operate th e Chew Facility. Sources from the facility have either been moved to the Rising Sun or Whitaker Avenue locations, shut-down, or moved to other Cardone locations in the United States or other countries. AMS inspected the fac ility on May 2015 and observed that the facility is now a window and door warehouse and no operations or equipment from Cardone were at the facility.

East Erie Avenue and Tabor Road Locations. In 1997, the East Erie and Tabor Cardone Locations were minor sources for NOx and VOC; therefore, the locations were not applicable to the 1-hour RACT. Starting in 2005, sources from both the East Erie and Tabor Rd locations along with 3 other Cardone locations were also combined under Cardone 's TVOP No. V04-005 and V09-019. As of January 2015, Cardone no longer owns and operate the East Erie and Tabor Locations. As of May 2015, the East Erie Facility is a now a lighting warehouse (500-550 Erie) and a food distributor (428 East Erie). The Tabor10/16/2015 Road Facility (5500 Tabor) as of May 2015 is being renovate d into a church. Sources from the East Erie or Tabor locations have either been moved to the Rising Sun or Whitaker Avenue locations, shut-down, or moved to other
Cardone locations in the United States or other countrie s. AMS inspected the East Erie and Tabor Locations on May 2015 and observed that that and no opera tions or equipment from Cardone were at the locations.

Rising Sun and Whitaker Avenues Locations The Cardone Rising Sun Ave. Facility had a 1hr RACT VOC Permit in 1995 under PLID 3887 . The 1-hour RACT determination for the Rising Sun Ave facility (PA Perm it Number 51-3887), dated May 29, 1995, was approved into the SIP by EPA on 10/30/01 (66 FR 54710). Sources in the 1-hr RACT Permit included:

(1) Degreasing operations with solvent reprocessing and storage (Stoddard Solvent); and (2) Miscellaneous architectural coatings.

Degreasing Operations with Solvent Recovery For Rising Sun Avenue, the Solvent Recovery process was part of original 1-hour RACT analysis and required an installation of a vapor condenser. The solvent recovery process has been out of service because Cardone stopped using Stoddard solvents. The facility cannot re-start the solvent recovery process to process any VOC materials without first obtaining a pl an approval or installation permit. No Solvent Recovery is being conducted at the Whitaker and Rising Sun Aves. Any remaining degreasing operations at the Whitaker and Rising Sun facilities are listed in th e Cold-Cleaning Degreasers list and addressed in the following RACT analysis.

Architectural Coatings For Rising Avenue, the of original 1-hour RACT listed miscellaneous architectural coatings in the permit. Cardone's Rising Sun and Whitaker locations do not process or use architectural coatings.

There is no 1-hr RACT determination for the Whitaker Ave in 1995 since the facility was not a major source of
NOx or VOC at that time.

This memorandum will discuss RACT applicability for VOC and NOx sources at the 2 remaining Cardone locations (Rising Sun and Whitaker Avenues) in Philadelphia. Equipment used at the locations includes degreasing operations and combustion sources. Below is the facility information for the Rising Sun and Whitaker Locations.

1. 5660 Rising Sun Avenue, Philadelphia, PA 19120 (Plants 11-14) – PLID 3887 2. 5501 Whitaker Avenue, Philadelphia, PA 19124 (Plants 90-97) –PLID 2287

Applicability for NOx and VOC RACT: Cardone Industries (Rising Sun and Whitaker Avenues) is not a major source for NOx since the potential NOx emissions are less than 100 tons per year, the major source threshold in Philadelphia County that is applicable to NOx RACT for the 1997 8-hour ozone NAAQS.

Cardone Industries (Rising Sun and Whitaker Avenues) under Title V is a major source of VOC having potential emissions greater than 50 tons per year, the major source threshold in Philadelphia County that is applicable to VOC RACT for the 1997 8-hour ozone NAAQS.

Process Descriptions: Cardone Industries Rising -Whitaker VOC emission sources are as follows:

Surface Coating - 8 spray booths

Source ID Source Description SB01 Electrostatic Disk Spray Booth SB02 Manual Spray Booth Post Spray SB03 Floor Type Spray Booth Pre-Spray SB05 Touch-up Spray Booth SB07 Touch-up Spray Booth SB08 Manual Spray Booth SB10 Manual Spray Booth SB11 Manual Spray Booth10/16/2015 Cold-Cleaning Degreasers - 5 degreasers

Source ID Source Description

V01 Vibrator Flowthru 55ft

V08 Vibrator 6ft V15 Ultra Tub Vibrator 17 (5 ft) V18 Ultra Tub Vibrator 3 (5ft) V19 Ultra Tub Vibrator (3ft)

Combustion Units

Source ID Source Description Rated Capacity CU-SB04 Conveyorized Forced Air Drying Oven 1.5 MMBTU/hr CU-W12 Goff Hydropulse Washer 0.5 MMBTU/hr CU-W13 Goff Hydropulse Washer 0.5 MMBTU/hr CU-W15 Washer, American Metal Wash 0.3 MMBTU/hr

CU-W16 Parts Washer Beltwasher 2310 0.4 MMBTU/hr CU-W18 Parts Washing Machine 0.8 MMBTU/hr

CU-W19 Ransohoff tunnel washer 1.9 MMBTU/hr CU-W20 Goff Hydropulse HP-6 Washer 0.3 MMBTU/hr CU-W21 Goff Hydropulse HP-3SC (Autoline) 0.3 MMBTU/hr CU-W22 Kuhl Washing Machine 4.65 MMBTU/hr

CU-W35 Steam Cleaner 0.258MM BTU/hr CU-W36 Steam Cleaner 0.258,MMBTU/hr

CU-W46 JRI Washer 0.3 MMBTU/hr

CU-W48 CDC Front Washer 0.450 MMBTU/hr CU-B02 Fulton Thermal Liquid Heater 2.4 MMBTU/hr CU-B03 Fulton Thermal Liquid Heater 2.4 MMBTU/hr CU-B04 Propane Backup System Vaporizer 0.84 MMBTU/hr CU-B05 Backup Propane System Burner 0.84 MMBTU/hr

CU-B21 Carrier HVAC 48TJD020 Roof unit 0.270 MMBTU/hr

CU-B22 Carrier HVAC 48TJD020 Roof unit 0.270 MMBTU/hr

CU-B23 Carrier HVAC 48TJD020 Roof unit 0.270 MMBTU/hr

CU-B24 Carrier HVAC 48TJD020 Roof unit 0.270 MMBTU/hr

CU-B25 Carrier HVAC 48TJD020 Roof unit 0.270 MMBTU/hr

CU-B26 Carrier HVAC 48TJD020 Roof unit 0.270 MMBTU/hr

CU-B27 Carrier HVAC 48TJD020 Roof unit 0.270 MMBTU/hr

CU-B28 Carrier HVAC 48TJD020 Roof unit 0.270 MMBTU/hr

CU-B29 Carrier HVAC 48DKD028 Roof unit 0.255 MMBTU/hr

CU-B30 Carrier HVAC 48DKD028 Roof unit 0.255 MMBTU/hr

CU-B31 Carrier HVAC 48DKD028 Roof unit 0.255 MMBTU/hr CU-B32 Cambridge HVAC C390 Roof unit 0.4 MMBTU/hr CU-B33 Cambridge HVAC C390 Roof unit 0.4 MMBTU/hr CU-B34 Cambridge HVAC C600 Roof unit 0.582 MMBTU/hr CU-B35 Cambridge HVAC C600 Roof unit 0.582 MMBTU/hr CU-B36 Cambridge HVAC C600 Roof unit 0.582 MMBTU/hr CU-B37 Cambridge HVAC C600 Roof unit 0.582 MMBTU/hr CU-B38 Cambridge HVAC C600 Roof unit 0.582 MMBTU/hr CU-B39 Cambridge HVAC C600 Roof unit 0.582 MMBTU/hr CU-B40 Cambridge HVAC C600 Roof unit 0.582 MMBTU/hr CU-B41 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B42 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B43 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B44 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B45 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B46 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr10/16/2015 CU-B47 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr

Source ID Source Description Rated Capacity CU-B48 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B49 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B50 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B51 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B52 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B53 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B54 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B55 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B56 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B57 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B58 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B59 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B60 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B61 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B62 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B63 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B64 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B65 Cambridge HVAC C900 Roof unit 0.9 MMBTU/hr CU-B66 Cambridge HVAC C1200 Roof unit 1.2 MMBTU/hr CU-B67 Cambridge HVAC C1200 Roof unit 1.2 MMBTU/hr CU-B68 Cambridge HVAC C1200 Roof unit 1.2 MMBTU/hr CU-B70 Cambridge HVAC M-136 4.8 MMBTU/hr

Burnout Ovens

Source ID Source Description Rated Capacity CD-O05 Burnout Oven (12 bskt) w/ Integral Afterburner 3 MMBTU/hr CD-O06 Burnout Oven (12 bskt) w/ Integral Afterburner 3 MMBTU/hr CD-O07 Burnout Oven (12 bskt) w/ Integral Afterburner 3 MMBTU/hr CD-O09 Burnout Oven (12 bskt) w/ Integral Afterburner 3 MMBTU/hr CD-O11 Burnout Oven (12 bskt) w/ Integral Afterburner 3 MMBTU/hr CD-O12 Burnout Oven (8 bskt) w/ Integral Afterburner 3 MMBTU/hr CD-O14 Burnout Oven (12 bskt) w/ Integral Afterburner 3 MMBTU/hr CD-O19 Bayco Oven 3 MMBTU/hr CD-O15 Seghers Fluid Bed Oven B-3111/RAN 0.93 MMBTU/hr CD-O20 Burnout Oven (12 bskt) w/ Integral Afterburner (Replace

CD-01 3 MMBTU/hr

CD-O21 Burnout Oven (12 bskt) w/ Integral Afterburner ( 3 MMBTU/hr

Emergency Generator

Source ID Source Description Rated Capacity
CB-06 Onan Backup Generator System - Diesel Burnout Oven 1.9 MMBTU/hr

RACT Analysis: Surface Coating Each spraybooth at the facility is complying with the RACT requirements of 25 Pa Code §129.52 - Miscellaneous metal parts & products, air-dried coatings.10/16/2015 Cold Cleaning Degreasers – VOC fugitives The miscellaneous cold degreasing operations include dipping, soaking, and agitating tank operations as well as numerous workstation wiping operations throughout the facility. The potential emissions for the facility degreasing operations are linked to total prod uction capacity for the facility. Each cold-cleaning degreasing operation at the facility is complying w ith the RACT requirements of 25 PA Code 129.63

For the Chew Street facility the original RACT Pl an Approval required Cardone to use operational improvements and better work practices to control VOC emissions: Rags used to wipe solvent shall be stored in closed top containers, solvent collected in drip pans under drain plugs shall be removes promptly, tank lids shall be modified to promote ease of use. Th e Chew facility is now closed. For the cold cleaning operations at Whitaker and Rising Sun, this requi rement is replaced by the presumptive RACT requirements of Pa Code 129.63 and AMR V, Section XIII.A, which are more stringent.. Some of the detailed equipment and operation requirements of 25 PA Code 129.63 are listed below;

 129.63(a)(1)- Immersion cold cleaning machines shall have a free board ration of 0.50 or
greater,

 129.63(a)(2)- Immersion cold cleaning mach ines and remote reservoir cold cleaning machines Have a permanent, conspicuous label summarizing the operating requirements in paragraph129.63(a)(3).

 129.63(a)(3)(i) -Waste solvent shall be colle cted and stored in closed containers. The closed containers may contain a device that allows pressure relief, but does not allow liquid solvent to drain from the container.

 129.63(a)(3)(v) - Spills during solvent transfer and use of the cold cleaning machine shall be cleaned up immediately.

AMR V, Section XIII does not allow VOC emissions from leaking process equipment components of 10,000 ppmv VOC or greater or in a liquid state.

Combustion Units and Burnoff Ovens. Each combustion unit and burnoff oven is less than 20 million BTU and burns natural gas or propane. Thus, all combustion units are complying with 25 PA Code 129.93(c)(1) presumptive RACT requirements for installation, maintenance, and operation in accordance with manufacturer's specification.

Emergency Generator The emergency generator is complying with 25 PA Code 129.93(c)(5) presumptive RACT requirements to operate less than 500 hours in a consecutive 12-month period.

RACT Revisions/Modifications:

AMS has determined the following for the 8-hr RACT. 1) Revise the State Implementation Plan (SIP) to remove previous RACT determination/permits for the Cardone Chew Facility (PA Permit Number 51-2237, PL ID 2237 dated May 29, 1995) since the facility is no longer in operation. 2) A case-by-case RACT determination is no longer requir ed for Cardone since. all existing sources at Whitaker and Rising Sun are complying with presumptive or CTG RACT requirements as mentioned above. Thus AMS is revising the SIP to remove previous RACT determination/permit for the Cardone Rising Sun Facility (PA Permit 51-3887, PLID 3887 dated May 29,1995) since the previously approved case-by-case requirements do not apply. 3) AMS is withdrawing the Plan Approval (Cardone Industries, PLIDs 03387/03888/2287/0321/T0156 ) submitted for Cardone to EPA on February 18, 2015 as a revision to the SIP.10/16/2015 10/16/2015

Edward Wiener, Chief of Source Registration Date