CITY OF PH ILADELPHIA Department of Public Health

Environmental Protection Division Air Management Services

InterOffice Memo

To: File

From: Rahel Gebrekidan

Date: June 22, 2015

Subject: 1997 8-Hour RACT Analysis for Th e Navy Foundry and Propeller Center

(PLID # 09702)

Introduction:

The Clean Air Act (CAA) requires that mode rate (or worse) ozone nonattainment areas implement reasonably available control technolo gy (RACT) controls on all major sources of VOC and NOx. Philadelphia County is part of the Philadelphia-Wilmington-Atlantic City

moderate ozone nonattainment ar ea 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:

The Navy Foundry and Propeller Ce nter is located at Navy Yard, Philadelphia, PA 19112. The Naval Foundry and Propeller Center is Navy facility with cement mixing, metal melting, metal stress relieving, and metal grit blasting f acility as per foundry operations and a machining, degreasing, painting and blasting of metal parts facility as per the machine shop.

Applicability for NOx and VOC RACT: The Navy Foundry and Propeller Center is a ma jor 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 for the 1997 8-hour ozone NAAQS. This facility is not a major source of VOC having potenti al emissions of less than 50 tons per year, the major source threshold in Philadelphia County th at is applicable to VOC RACT for the 1997 8- hour ozone NAAQS.

Process Descriptions:

The Navy Foundry and Propeller Center cu rrently has the following NOx Sources:

Location Combustion Sources Capacity Fuel 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 each Natural GasStress 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 7- Make-up air units 3.0 MMB TU/hr Natural Gas 1- Air handling unit 0.4 MMBTU/hr Natural Gas 1- Make-up air unit 1.25 MMBTU/hr Natural Gas 1-Rooftop heater 0.250 MMBTU/hr Natural Gas Emergency Generator 20Kw Natural Gas

Building 546 3- Air rotating units 2.2 MMBTU/hr Natural gas

2-Heater 0.125 MMBTU/hr Natural Gas Building 592 1- Air rotation unit 2.2 MMBTU/hr Natural gas Building 712 2- Boilers 0.52 MMBTU/hr Natural gas Building 1029 2- Air rotating units 2.2 MMBTU/hr Natural gas

RACT Evaluation: Presumptive RACT

The following sources have maximum heat input ratings of less than 20 MMBTU/hr and thus are subject to the presumptive RACT requirements specified in 25 Pa Code 129.93(c)(1), operation and maintenance of bo ilers per manufacturer specifications.

Location Combustion Sources RACT Requirement

Building 20 Reverbatory Furnace 25 PA Code 129.93(c)(1) 2 Sand Core Ovens 25 PA Code 129.93(c)(1) 2 Crucible Furnaces 25 PA Code 129.93(c)(1) 2 Heat Treating Ovens 25 PA Code 129.93(c)(1) 6 Ladle Preheaters 25 PA Code 129.93(c)(1) 2 Small Ovens 25 PA Code 129.93(c)(1) 5- Air rotating units 25 PA Code 129.93(c)(1) 7- Make-up air units 25 PA Code 129.93(c)(1) 1- Air handling unit 25 PA Code 129.93(c)(1) 1- Make-up air unit 25 PA Code 129.93(c)(1) 1-Rooftop heater 25 PA Code 129.93(c)(1) Building 546 3- Air rotating units 25 PA Code 129.93(c)(1) 2-Heater 25 PA Code 129.93(c)(1) Building 592 1- Air rotation unit 25 PA Code 129.93(c)(1) Building 712 2- Boilers 25 PA Code 129.93(c)(1) Building 10292- Air rotating un its 25 PA Code 129.93(c)(1)

The following source meets the presumptive RA CT requirements specified in 25 Pa Code 129.93(c)(5), the operation and maintenance of the source per manufacturer’s specifications, and a 5% annual capacity factor limit per rolli ng 12-month period under th e facility’s Title V operating permit # V13-002.

Location Combustion Sources RACT Requirement Building 20 Stress Relieving Oven 25 PA Code 129.93(c)(5)

De minimis Source

The 20 KW emergency generator, which is listed as insignificant source in the facility Title V operating permit # V13-002, is considered a de minimus source for RACT purposes. The potential NOx emission from the emergency gene rator is less than 1 ton per year. Based on AMS permitting and engineering knowledge, AM S determines that installing any control technology on such small source is both tech nically and economica lly unreasonable.

Conclusions and Recommendations:

All significant NOx sources ar e covered by presumptive RACT.

6/22/15

Edward Wiener, Chief of Source Registration Date