CITY OF PHILADELPHIA

Department of Public Health 

Environmental Protection Division 

Air Management Services 

InterOffice Memo 

To: File 

From: Maryjoy Ulatowski 

Date: January 22, 2016 

Subject: 8-Hour RACT Analysis for Naval Surface Warfare Center Carderock Division (NSWCCD) 

(PLID # 09724) 

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 VOC and 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 this facility. 

Company Description:

NSWCCD is a Navy research and development facility located in Philadelphia, Pennsylvania. Equipment used at the 

facility includes boilers and heater, emergency generators and fire pumps, diesel engines, test cell engines and gas turbines, 

and paint spray booth with dry filters 

Applicability for NOx and VOC RACT:

NSWCCD is a major source of Nitrogen Oxides (NOx) having potential NOx emissions greater than 100 tons per year, the 

major source threshold in Philadelphia County that is applicable to NOx RACT 8-hour ozone NAAQS. The facility is a 

minor source of Volatile Organic Compounds (VOC) having potential VOC emissions of less than 50 tons per year, the 

major source threshold in Philadelphia County that is applicable to VOC RACT 8-hour ozone NAAQS. 

NSWCCD has a 1-hr RACT Permit (PA Permit Number 51-9724) issued in 1995 under PLID 9724. The 1-hour RACT 

determination for the NSWCCD, dated December 27, 1997, was approved into the State Implementation Plant (SIP) by 

EPA on 10/30/01 (66 FR 54710). 

Subsequently, RACT Permit No. PA-04108 was issued in 2004 for NSWCCD and was approved into the SIP on 4/29/2005 

(70 FR 22257). The RACT Permit addressed 5 boilers under the custody of NSWCCD which were previous located at the 

former Philadelphia Naval Shipyard (PNSY) (PLID 09702), a separate facility located adjacently at Broad Street South of 

Pattison Avenue. PNSY shut down most of its operations in the late 1990s, although the Naval Foundry and Propeller 

Center continued to operate under PLID 09702. The 5 boilers were replaced by a new boiler plant owned by PAID Steam 

Boiler Plant (PLID:09715) located at 2000 Constitution Avenue on the former PNSY. The new boiler plant shut down in 

2012. 

1997 1-hr NOx RACT Soures:

Sources included in the 1-hr RACT Permits are below with the notes on the current status of the source: 

Location 1hr RACT Emission Source (s) 

Source Status as of June 

2015 

If Active, TVOP 

ID # 
Bldg 519 

Two 244 MMBTU/hr wall-fired ship’s boilers (DDG-37 

and CG-32) used for Navy testing. Removed 

Bldg 633 

317 MMBTU/hr wall-fired Baltimore ship’s boiler (No. 

3) used for Navy testing. Removed 

Bldg 633 

384 MMBTU/hr wall-fired ship’s boiler (CVA-60) used 

for Navy testing. #2 Diesel Removed 

Bldg 633 

202 MMBTU/hr wall-fired ship’s boiler (DDG-15) used 

for Navy testing. Active CU-B108 

Bldg 633 

6.95 MMBTU/hr combustion test facility with one 

burner, used to test burner firing techniques for Navy. Removed 

Bldg 633 

Vapor boiler with 2.176 MMBTU/hr saturated steam 

generator and a 0.6 MMBTU/hr. Removed 

Bldg 

781/782 2.58 MMBTU/hr boiler that provides space heating. Removed 

Located 

througho

ut the 

facility. 

Emergency Generators

 One 20 kW, one 25 kW burn diesel fuel, two 2.25 kW, 

two 5 kW, and one 6.5 kW burn gasoline

25 KW diesel generator 

is Active. In Title V, 

part of source group IN - 

Insignificant activities. 

Other sources removed 

from service. CU-G103 

Bldg 633 

Two 8,500 bhp Colt Pielstick PC2.5 V400 engines (LSD41 alpha and bravo) used for Navy testing 

CU-M115 (Alpha) 

CU-M116 (Bravo)

Bldg 633 

1,412 bhp Ship’s Service Detroit Diesel 16V-149T1 

engine (FFG-7) used for testing Removed 

Bldg 14 

 6 engine test stands, each can hold engines up to 400 hp. 

Two currently hold 90 hp Detroit Diesel engines. The 

stands and engines will be moved to Bldg 77-High in 

1996. Removed 

2 engine test cells, each can hold engines up to 2000 hp. 

One currently holds a 1500 hp Fairbanks Morse engine Removed 

Bldg 77 

High 

200 kW Detroit Diesel Allison diesel generator. Provides 

emergency power during Navy tests in Bldg 633 since 

1992. Active CU-G101 

Bldg 77 

High 

Two 19,575 kW General Electric gas turbines (LM2500-

2A and 2B) used as part of DDG-51 test site Active 

CU-M112 

CU-M111 

Bldg 77 

High 

2,400 kW Allison 501K17 gas turbine used as part of 

CG-47 test site Active CU-M113 

Bldg 77 

High 

 2,500 kW Allison 501K34 gas turbine used as part of 

DDG-51 test site. Active CU-M114 

Bldg 824 

2,811 kW Textron Lycoming TF-40 gas turbine used as 

part of the Small and Medium Gas Turbine Test Facility Active CU-M119 

Bldg 824 

60 kW Sunstrand Power Systems T-62 gas turbine that is 

part of the Small and Medium Gas Turbine Test 

Facility Removed 

Bldg 824 

Six Oil-Water Separators - Four collect excess lube oil 

from test sites, two collect marine diesel runoff from tank 

farms 

Active. Part of Source 

group IN -Insignificant 

Activities. 

P-M127, P-M128, 

P-M129, P-M130,

 P-M131, P-M132

Bldg 29 

Photo Lab - Located in Bldg 29, contains a Cibachrome 

Copier which uses bleach, neutralizer, developer, and 

fixer. Removed 

Bldg 77 

High 

Print Shop, uses an OCE White Printer along with 

miscellaneous cleaners and printing compounds Removed 
The paint booth with dry filters and the six water separators are VOC sources, but since VOC RACT is not applicable 

requirement for this facility; therefore, RACT was not evaluated for this source. 

 

RCSR Lab Fume Hood - Vents fumes from adhesives. Removed 

Five 125 MMBtu/hr boilers burning Natural gas or No. 6 

oil. (Former Philadelphia Naval Ship Yard) Removed 
Under the 1-hr RACT the emergency generators were applicable to presumptive RACT. The five 125 MMBtu/hr boilers 

were committed to a schedule to shut down and in the 2004 RACT permit were given a combined NOx emission limit of 

534 tpy. The other units were required to follow a Navy maintenance plan. 

The DDG-15 boiler was required to have a NOx emission limit established through an AMS-approved stack testing 

program, as per 25 Pa Code Section 129.91(i). An initial stack test was conducted in 2003. The result of the initial stack 

for the DDG-15 boiler for NOx was 0.36 lbs/MMBtu (based on an average of three (3) 60 minute runs). 

Since 2003, the Navy has not had regular use for the DDG-15 boiler. It has only operated a few hours per year to keep it 

running. The Navy does not have plans to operate the boiler on a regular bases in the near future, but does not plan to shut 

it down completely since it a unique boiler. 

1997 8-hr NOx RACT Soures:

Below is the inventory of NOx sources at NSWCCD: 

** Indicates sources were installed after the 1-hr RACT permit. 

Combustion units. 

 Bldg 633 - 202 MMBTU/hr wall-fired ship's boiler (DDG-15) 

 Twenty (20) small boilers/heaters, each less than 10 MMBTU/hr. The 20 small/boilers were installed after the 

1-hr RACT permit. 

TVID Combustion Unit Capacity Fuel 

CU-B108 B633; Boiler DDG-15 202.13 MMBTU/hr #2 Diesel Fuel 

**CU-B112 B77L; Boiler 8.4 MMBTU/hr Natural Gas 

**CU-B113 B77L; Boiler 8.4 MMBTU/hr Natural Gas 

**CU-B114 B77H; Boiler 8.4 MMBTU/hr Natural Gas 

**CU-B116a B77H; 4 Make-up Air Heaters 1.2 MMBTU/hr each Natural Gas 

**CU-B116b B77H; 6 Unit Heaters 0.3 MMBTU/hr each Natural Gas 

**CU-B120a B633 Futera Fusion Boiler # 1 0.75 MMBTU/hr Natural Gas 

**CU-B120b B633 Futera Fusion Boiler # 2 0.75 MMBTU/hr Natural Gas 

**CU-B121a B4 Lochinvar Boiler # 1 2.0 MMBTU/hr Natural Gas 

**CU-B121b B4 Lochinvar Boiler # 2 2.0 MMBTU/hr Natural Gas 

**CU-B121c B4 Lochinvar Boiler # 3 2.0 MMBTU/hr Natural Gas 

**CU-B121d B4 Lochinvar Boiler # 4 2.0 MMBTU/hr Natural Gas 

**CU-B122a B29 Lochinvar Boiler # 1 2.0 MMBTU/hr Natural Gas 

**CU-B122b B29 Lochinvar Boiler # 2 2.0 MMBTU/hr Natural Gas 

**CU-B123a B1000 Lochinvar Boiler # 1 2.0 MMBTU/hr Natural Gas 

**CU-B123b B1000 Lochinvar Boiler # 2 2.0 MMBTU/hr Natural Gas 

**CU-B123c B1000 Lochinvar Boiler # 3 2.0 MMBTU/hr Natural Gas 

**CU-B123d B1000 Lochinvar Boiler # 4 2.0 MMBTU/hr Natural Gas 

**CU-B130 B633 Prestige Solo Boiler 0.4 MMBTU/hr Natural Gas 

**CU-B131 B633 York Air Handler 2.5 MMBTU/hr Natural Gas 

**CU-B132 B633 Reznor HVAC Unit 0.8 MMBTU/hr Natural Gas 

Emergency Engines 

The following emergency engines were installed after the 1-hr RACT Permit: 

 Eight (8) emergency engines. 

TVID Emergency Engines Capacity Fuel 

**CU-G101 B77H; Emergency Generator 268 BHP #2 Diesel Fuel 

**CU-GT109 B4; Emergency Generator G1 88 BHP Natural Gas 

**CU-GT110 B4; Emergency Generator G2 154 BHP Natural Gas 
**CU-GT113 B29; Emergency Generator 54 BHP Natural Gas 

**CU-GT115 B1000; Emergency Generator 186 BHP Natural Gas 

**CU-M146 B485; North Fire Pump 208 HP #2 Diesel Fuel 

**CU-M147 B485; South Fire Pump 208 HP #2 Diesel Fuel 

**CU-M156 B542; Fire Pump 115 HP #2 Diesel Fuel

 CU-G103 (25kW/ 46 BHP), a diesel emergency generator, was in the 1-hr RACT Permit and considered an 

 insignificant source since the potential NOx emissions are less than 1 ton per year. 

Testing Engines and Turbines 

 Eighteen (18) testing engines/turbines. 

 

 The testing engines are turbines are only used for testing marine vessels and shipboard components. These 

engines are not used to supply power to the facility. The following are the testing engines and turbines. 

TVID Engines and Turbines Capacity Fuel

**CU-M110G 77H; Marine Engine Test Cell 1 16.42 MMBTU/hr #2 Diesel Fuel 

CU-M111 B77H; Engine Testing Gas Turbine DDG-51 206.9 MMBTU/hr #2 Diesel Fuel (LM-2500 2A) 

CU-M112 B77H; Engine Testing Gas Turbine DDG-51 206.9 MMBTU/hr #2 Diesel Fuel (LM-2500 2B) 

CU-M113 B77H; Engine Testing Gas Turbine CG-47 40.6 MMBTU/hr #2 Diesel Fuel (K-17) 

CU-M114 B77H; Engine Testing Gas Turbine GTG#2 37.4 MMBTU/hr #2 Diesel Fuel (K-34) 

CU-M115 B633; Engine Testing LSD-41 ALPHA 51.2 MMBTU/hr #2 Diesel Fuel 

CU-M116 B633; Engine Testing LSD-41 Bravo 51.2 MMBTU/hr #2 Diesel Fuel 

CU-M119 B824; Engine Testing TF-40 Gas Turbine ≤ 42.1 MMBTU/hr #2 Diesel Fuel Test Cell 2 

**CU-M139 B77H; Engine Testing Gas Turbine GTG#1 37.4 MMBTU/hr #2 Diesel Fuel (K-34) 

**CU-M142 B77H; Engine Testing Gas Turbine Auxiliary 4.72 MMBTU/hr #2 Diesel Fuel (RIMMS) 

**CU-M144 B87; Engine Testing Diesel Generator 377 HP #2 Diesel Fuel 

**CU-M149 B633; P-104 Test Cell 238 MMBTU/hr #2 Diesel Fuel 

**CU-M150 B77H; DD(X) MT-30 311.8 MMBTU/hr #2 Diesel Fuel 

**CU-M151 B77H; DD(X) LM-500 51.4 MMBTU/hr #2 Diesel Fuel 

**CU-M152 B77H; DD(X) RR-4500 55.6 MMBTU/hr #2 Diesel Fuel 

** DDX Test Cell 418.8 MMBTU/hr #2 Diesel Fuel 

**CU-M153 B87; Caterpillar D80-4 Test Engine Generator 80 kW #2 Diesel Fuel 

**CU-M155 B77H Diesel Engine Testing EDG, CAT C-18 4.79 MMBTU/hr #2 Diesel Fuel 

NOx RACT Analysis:

NSWCCD is a research and development facility and is required to equip and operate its sources like their shipboard or 

submarine counterparts to an effective test platforms. Including control technology particularly on its testing sources would 

change their mentioned operation, therefore is generally considered unreasonable. 

Combustion units 

DDG-15 Boiler (Bldg 633) 

Bldg 633 - 202 MMBTU/hr wall-fired ship's boiler (DDG-15) -The marine boiler is used for testing only and not used to 

provide heat to the facility. For marine boiler testing, testing of boilers need to be at similar conditions in an at-sea 

environment and therefore must be configured exactly on a ship. The implementation of the control device would be 

invalidate the naval boiler test result and therefore be infeasible. Installation of control device were also explored and were 

also determined to be technically infeasible as detailed below. 
Available NOx controls for the 202 MMBTU/hr ship boiler are Low NOx burner and flue gas recirculation 

(FGR). Installation of the low NOx burner and FGR on the boiler is not technically feasible for the following 

reasons: 

For Low NOx Burners 

 1) Naval boilers have extremely high power density compared to any industrial boiler of similar steam output. 

Naval boiler design requirements include compact size, high capacity, high temperature stem and the ability 

to respond to rapid load changes. Consequently, naval boiler furnace heat release rates and gas temperatures 

are very high. To achieve this, compact, high temperature flames are required. In comparison, the typical 

industrial boiler designed for low NOx burners cannot respond to rapid load changes due to the large size 

required to contain the very long and relatively low temperature flame within the furnace. 

 2) A low NOx flame will extend beyond the naval furnace, raising steam temperature beyond design. Tubes, 

headers and piping that come in contact with superheated steam will be damaged. It is also expected that 

portions of the low NOx flame will be quenched leaving the furnace upon contact with relative cold tube 

surfaces. This would result in incomplete combustion and acceptable stack emissions. 

For Flue Gas Recirculation 

 1) FGR is incompatible with naval boilers because increasing boiler gas flow 15-20% will increase the boiler 

draft loss by 30-45 percent., This is not insurmountable in a package boiler where the draft loss at the 

maximum is typically 15 inches of H2O. The full power draft loss of a typical marine boiler will increase 

from 50-70 inches of H2O with installation of FGR. This will require replacement of turbine-driven forced 

draft blowers with larger units, and strengthening of the boiler air casing. The increased gas velocity can 

cause flow-induced noise or potentially devastating tube vibration problems. 

 2) The boiler combustion air handling system will not allow sufficient time for FGR to mix with the combustion 

air before entering the burner. This will result in damaging vibration at all load conditions. 

 

The B633 DDG-15 boiler will continue to adhere to the standard Navy Planned Maintenance program as defined 

for shipboard use. The boiler at this time only operates less than 2 hours per year since 2003. Below is a history 

the NOx emissions from the boiler since 2003. 

NOx emissions from DDG-15 in tpy 

2003 2004 2005 2007 2008 2009 2010 2011 2012 2013 2014 

0.22 0.01 0.01 0.01 0.00 0.00 0.00 0.002 0.003 0.003 0.003 

AMS is keeping the test program in the RACT plan approval since the boiler could potentially operate regularly in 

the future. For a NOx emission limit, AMS has set the emission limit for NOx to 0.38 lbs/MMBtu based on the 

highest of the 3 runs from the initial test conducted in 2003. No other testing data is available for the boiler. AMS 

has determined that is a reasonable limit to account for fluctuations associated with performance testing. AMS 

will reevaluate this limit based on future stack tests. 

However, since AMS finds it is not reasonable to require stack testing on a boiler that is seldomly being operated, 

AMS is adding a condition that testing of the boiler will be applicable after the boiler reaches 50 hours per year in 

any year or a cumulative 100 hour of operation from the effective date of the RACT Plan Approval, whatever 

occurs first. AMS finds this is appropriate since the NOx emission from the boiler are still expected to be low 

even at these levels of operation, as shown in the calculations below (based on the rated capacity and the proposed 

RACT limit of 0.38 lb/MMBtu NOx emission rate). 

NOx emission (tpy) = (Operating Hours per Year) X (NOx Emission Factor) X (Boiler Max Rating) 

NOx emission (tpy) = (50 hours) X (0.38 lb NOx/MMBtu ) X (202 MMBtu/hr) = 1.9tpy 

NOx emission (tpy) = (Operating Hours per Year) X (NOx Emission Factor) X (Boiler Max Rating) 

NOx emission (tpy) = (100 hours) X (0.38 lb NOx/MMBtu ) X (202 MMBtu/hr) = 3.8 tpy 

Twenty (20) small boilers/heaters
The twenty new boilers/heaters, each less than 10 MMTU/hr, were installed after the 1-hr RACT permit was 

issued. Each are each less than 50 MMBTU/hr and thus are currently complying with the presumptive RACT 

requirement of 25 PA Code 129.93(c)(1). Per the facility's Title V Operating Permit No. V13-009 and AMS 

Installation Permit Nos. 11396-11403 and 11406-11410, the boilers/heaters are to be installed, maintained, and 

operated in accordance with the manufacturer's specifications. 

 

 Emergency Engines 

The emergency units (emergency generators and fire pumps) will comply with the presumptive RACT 

requirement of 25 PA Code 129.93(c)(5). Per the facility's Title V Operating Permit No. V13-009, each 

emergency engine will operate less than 500 hours per rolling 12 month period and shall be installed, maintained, 

and operated in accordance with manufacturer's specifications. 

 

 Testing Engines and Turbines 

The new testing engines and turbine engines installed after the 1-hr RACT permit was issued have the same 

testing functions and purposes as the testing engines and turbines included in the 1-hr RACT permit. 

For all testing engines and turbines currently at the facility, possible NOx controls include switching to natural gas 

combustion; pre-combustion controls such as water injection, and Dry Low Emissions (DLE); add-on controls 

such as Selective Catalytic Reduction (SCR), and Selective Non-Catalytic Reduction. Analysis of these options 

conducted by NWSCCD has shown that they would be technically infeasible for their testing applications. The 

purpose of the testing turbines and engines is to act as full scale test sites which house a variety of marine engines 

used for the research, development, test and evaluation of ship propulsion and power generation systems. These 

test facilities are used to evaluate equipment under shipboard conditions in an at-sea environment and therefore 

must be configured exactly as they are on a ship. There is currently no emission control equipment approved for 

or installed on a Navy ship. Additionally, all existing shipboard equipment is operated on liquid fuel oil. The 

implementation of any of the above control devices would invalidate test results and is therefore not feasible. 

RACT Determination: 

AMS has determined the following as 1997 8-hr ozone RACT for NSWCCD: 

1) Existing sources from the 1-hr RACT Permit (B633 DDG-15 Boiler- CU-B108, CU-M111, CU-M112, CU-M113, 

CU-M114, CU-M115, CU-M116 and CU-119) shall continue to adhere to the 1-hr RACT Permit (PA Permit 

Number 51-9724) and the Standard Navy Plan Maintenance program as defined for shipboard use. 

2) Boiler DDG-15 is limited to 0.38 lb/MMBtu and shall undergo an AMS-approved stack test program to establish 

determine compliance. Testing may be delayed d until the boiler reaching 50 hours per year or a cumulative 100 

hour of operation from the effective date of the RACT Plan Approval Permit, whatever occurs first. 

3) The new testing engines/turbines installed after the 1-hr RACT permit (CU-M110G, CU-M139, CU-M142, CUM144, CU-M149, CU-M150, CU-M151, CU-M152, DDX Test Cell, CU-M153, and CU-155) will also comply 

with the Standard Navy Plan Maintenance Program. 

4) The attached revised RACT Permit (PA Permit Number 51-9724) dated ___ (will be the date the plan approval is 

issued) is submitted for SIP approval and includes case-by-case RACT requirements per 25 PA Code 129.91-92 

for the above mentioned sources. 

5) Each small boiler/heater will comply with the presumptive RACT of 25 PA Code 129.93(c)(1). Emergency 

engines will comply with the presumptive RACT requirements of 25 PA Code 129.93(c)(5). A RACT 

determination for these presumptive sources is not submitted for SIP approval. 

Additionally, AMS requests to revise the SIP to remove Plan Approval No. 04108 (under PLID 9724), since the five (5) 

125 MMBTU/hr boilers are no longer in operation. The RACT permit (PA Permit Number 51-9724) has been revised 

primarily to remove sources that have shut down since the latest RACT determination and include new testing 

engines/turbines, and is included for SIP approval. 
 1/22/16 

 

Edward Wiener, Chief of Source Registration Date