### CITY OF PHILADELPHIA

DEPARTMENT OF PUBLIC HEALTH

AIR MANAGEMENT SERVICES

RACT PLAN APPROVAL

Effective Date: February 9, 2016

Expiration Date: None

In accordance with provisions of the Air Pollution Control Act, the Act of January 8, 1960, P.L. 2119, as amended, and after due consideration of a Reasonably Available Cont rol Technology (RACT) proposal received under the Pennsylvania Code, T itle 25, Chapter 129.91 thru 129.95, of the rules and regulations of the Pennsylvania Department of Environmental Pr otection (PADEP), Air Management Services (AMS) approved the RACT proposal of the facility below for the s ource(s) listed in section

1.A. Emission Sources of the a ttached RACT Plan Approval.

Facility: Naval Surface Warfare Center - Carderock Division, Ship Systems Engineering St ation (NSWCCD-SSES)

Permittee: NSWCCD Location: 5001 South Broad Street, Code 02, Philadelphia, PA 19112 Mailing Address: 5001 South Broad Stre et, Code 02, Philadelphia, PA 19112

SIC Code(s): 9722

Plant ID: 9724

Facility Contact: Mark Donato Phone: (215) 897-7607

Permit Contact: Mark Donato Phone: (215) 897-7607

Responsible Official: Walter A. Coppeans III Title: Captain, US Navy Commanding Officer

2/9/2016 Edward Wiener, Chief of S ource Registration DateRACT PLAN APPROVAL NSWCCD-SSES Page 2

2/9/16 In accordance with provisions of the Pennsylvania Code, Title 25, Chapter 12 9.91 thru 129.95, Air Management Services (AMS) has approved the RACT proposal plans for Naval Surface Warfare Center - Carderock Division, Ship Systems Engineering Station (NSWCCD-SSES) on the ab ove indicated air contamination source(s).

The RACT plan approval is subject to the following conditions:

1. The purpose of this Plan Approval is to establish Nitrogen Oxides (NOx) Reasonably Available Control Technology (RACT) for NSWCCD-SSES. This includes the following emission sources and control equipment:

A. Emission Sources

i. One (1) 202 MMBTU/hr wall-fired ship’s boiler (DDG-15, CU-M108) used for testing.

ii. Eighteen (18) testing engines and turbines.

TVID Engines and Turbines Capacity Fuel CU-B108 B633; Boiler DDG-15 202.13 MMBTU/hr #2 Diesel 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

2. This approval authorizes:

A. NOx emissions from CU-B108 (Boiler DDG-15) shall not exceed 0.38 lb/MMBtu. AMS will re-evaluate this emission limit after the testing required in Condition 4.A.i is conducted.

B

. The boiler and testing engines/gas turbines will continue to adhere to the standard Navy Planned Maintenance program as defined for shipboard use.

3. RACT Implementation Schedule

A. Upon issuance of this approval, NS WCCD-SSES shall begin immediate implem entation of the measures necessary to comply with the approved RACT proposal.

4. Testing and Monitoring Requirements

A. As per 25 PA Code 129.91(i), following the implementation of the RACT requirements, for a combustion unit with a rated heat input greater than 100 MMBTU/hr and not subject to 25 PA Code 123.51 (DDG-15), NSWCCD-SSES shall determine the rate of NOx emissions from the combustion unit through an AMS approved source testing

program .

i. The boiler shall be tested with 12 mont hs of the effective date of this RA CT Plan Approval and within 5 ye ars ofRACT PLAN APPROVAL NSWCCD-SSES Page 3

2/9/16 the previous test.

ii The test in Condition 4.A.i may be postponed during any calendar year the boiler operated less than 50 hours.

iii. The boiler shall be tested once it reach es 100 hours of operation from the effective date of this RACT Pla n Approval if testing has not been co nducted under Conditions 4.A.i or 4.A.ii . If required, the test shal l be conducted within 60 days of reaching the 100-hour threshold

.

5. Recordkeeping and Reporting Requirements

A. NSWCCD-SSES shall maintain a file containing all the records and other data that are required to be collected to demonstrate compliance with RACT requirements of 25 PA Code § 129.91-129.94. These records shall include:

i. Fuel consumption and operation hours for the boiler;

ii. Details of the maintenance program for the boiler and testing engines/turbines at the facility.

iii. Boiler test results shall be submitted to AMS in a timely manner within 60 days of from the testing date or as approved by AMS.

B. Records shall be retained for at least five ye ars and shall be made available to AMS on request.

6. Revisions to any emission limitations incorporated in this RACT Approval will require resubmission as revision to the PA State Implementation Plan. The appli cant shall bear the cost of public h earing and notification required for EPA approval as stipulated in 25 PA Code § 129.91(h).