CITY OF PHILADELPHIA

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 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: 

Aker Philadelphia Shipyard, Inc. – Philadelphia Naval Business Center is located at 2100 Kitty Hawk Avenue, 

Philadelphia, PA 19112. The facility performs the construction 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 Compounds (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) contribute 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 requirements 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 specified in the “CTG RACT regulation” 

column of the spreadsheet below. 

Painting Operations 

For each of the painting operation sources in the table above, 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. 

1/9/15

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