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



### InterOffice Memo

To: File

From: Noelle Helmstetter

Date: Dec 08, 2014
Subject: 8-Hour RACT Analysis for Aker Philadelphia Shipyard, Inc. – Phila. Naval Business

Center

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 ozon e 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:

Aker Philadelphia Shipyard, Inc. – Philadelphia Naval Bu siness Center is located at 2100 Kitty Hawk Avenue, Philadelphia, PA 19112. The facility performs the co nstruction of standard and specialized ships.

Applicability for NOx and VOC RACT:

Aker Philadelphia Shipyard, Inc. is not a major source of Nitrogen Oxides (NOx) having potential NOx emissions 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.

Aker Philadelphia Shipyard, Inc. is a major source of Volatile Organic Co mpounds (VOC) having potential VOC 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:

The painting operations, including painting at the paint shop, painting at the dry dock, and painting at Building 763 (formerly Prime Plate Industries) c ontribute significant levels of VOC emissions at the facility.

The facility’s air emission sources contributing to VOC emissions include:

 Two (2) 12.6 MMBtu/Hr boilers burning natural gas;

 Five (5) boilers each rated less than 2 MMBtu/Hr burning natural gas;

 Two (2) 4 MMBtu/Hr boilers burning natural gas;

 Painting operations;

The facility’s control devices related to VOC emissions include the following:

 A catalytic oxidizer at the Building 763 painting.

Presumptive RACT:

The following sources are covered by Presumptive RACT regulations, as is specified in the “Presumptive RACT Regulation” column of the table below:External Combustion Units

For each boiler, the presumptive RACT re quirements are the installation, operation, and maintenance of the boiler as per the manufacturer’s specifications.

CTG RACT:

The following sources are covered by CTG RACT regulations, as is specifi ed in the “CTG RACT regulation” column of the spreadsheet below.

Painting Operations

For each of the painting operation sources in the table ab ove, the CTG RACT limitation is the VOC content limit in units of pound per gallon (or grams/liter) of coating solids, cleanup requirements, and the maintenance of records kept on a daily basis in order to demonstrate compliance with the VOC limitations.

Case-by-Case RACT:

None.

Conclusions and Recommendations:

All VOC emitting sources are covered by presumptive and CTG RACT.

1 / 9 / 1 5

Edward Wiener, Chief of Source Registration Date Unit Description Heat Input (BTU/hr) Fuel Burned Presumptive RACT Regulation

CU-38 Paint Shop – Boiler #1 12,600,000 Natural Gas 25 PA Code 129.93(c )(1)
CU-39 Paint Shop – Boiler #2 12,600,000 Natural Gas 25 PA Code 129.93(c )(1)
CU-40 Building 620 Heater #1 (HV 620-1) 400,000 Natural Gas 25 PA Code 129.93(c )(1)
CU-41 Building 620 Heater #2 (HV 620-5) 300,000 Natural Gas 25 PA Code 129.93(c )(1)
CU-42 Building 620 Heater #3 (Compressor Room) 1,814,000 Natural Gas 25 PA Code 129.93(c )(1)
CU-43 Building 620 Heater #4 (HV 620-3) 400,000 Natural Gas 25 PA Code 129.93(c )(1)
CU-44 Building 620 Heater #5 (HV 620-4) 400,000 Natural Gas 25 PA Code 129.93(c )(1)
CU-45 Building 763 Pre-Heater 4,000,000 Natural Gas 25 PA Code 129.93(c )(1)
CU-46 Building 763 Cure Oven 4,000,000 Natural Gas 25 PA Code 129.93(c )(1)

Unit Description CTG RACT Regulation

P-29 Paint Shop – Painting Operations 25 PA Code 129.52 & AMR V, Section XV

CD-PS-9 Paint Shop “Paint Stop Filters” 25 PA Code 129.52 & AMR V, Section XV

P-31 Dry Dock – Painting Operations 25 PA Code 129.52 & AMR V, Section XV

P-47 Building 763 Paint Booth 25 PA Code 129.52 & AMR V, Section XV

CD-PB-12 Building 763 Catalytic Oxidizer 25 PA Code 129.52 & AMR V, Section XV