CITY OF PHILADELPHIA

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 The Navy Foundry and Propeller Center 

 (PLID # 09702) 

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: 

The Navy Foundry and Propeller Center 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 facility 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 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 for the 1997 8-hour ozone NAAQS. This 

facility is not a major source of VOC having potential emissions of less 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: 

The Navy Foundry and Propeller Center currently 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 Gas 
 Stress 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 MMBTU/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 boilers 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 1029 
 2- Air rotating units 25 PA Code 129.93(c)(1)

 

The following source meets the presumptive RACT 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 rolling 12-month period under the 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 generator is less than 1 ton per year. Based on 

AMS permitting and engineering knowledge, AMS determines that installing any control 

technology on such small source is both technically and economically unreasonable. 

Conclusions and Recommendations: 

All significant NOx sources are covered by presumptive RACT. 

 6/22/15 

Edward Wiener, Chief of Source Registration Date