DIRE CTO R

Bruc e W

. f"l. D.



### Ms. Diana Esher

Air Protection Division

U.S. Environmental Protection Agency Region III ( 3APOO)

1650 Arch Street Philadelphia, PA 19103-2029



### Dear Ms. Esher; AIR QUALITY PROGRAM

301 39 t11 Street- Bfdg. #7

P i ttsburg h

, PA 1 5201-1891

Phone : ( 4 1 2 ) 5 78-810 3

Fax : ( 4 1 2 } 578-8 1 44



### March 9, 2012 BO ARD OF H EALTH

Le e M

. D.

Chai r

Rev. Ricky V. Burgess

Donald S. Burke, M.D.

Joan Oeary, R.N.
Anthony Ferraro
James M. Flynn, Jr.
Edith L Sh apira, M.D.
Elle n C. Ste w a rt, M.D.

W

illiam Y oung blood



### In 2009 The Pennsylvania Department of Environmental Protection submitted to you a State Implementation Plan regarding eight-hour ozone RACT plans within Allegheny County. In 2011 a replacement to that plan was submitted.

The enclosed is supplemental information regarding that plan, specifically, the internal staff

reviews of the case-by-case RACT for Allegheny County. Also included is an exact duplicate of this

paper copy on a computer disk in searchable pdf format. Twenty sources were re-evaluated to assure that their one-hour RACT plans were adequate for the eight-hour standard, and one newer source, Laurel Mountain Whirlpool

, was reviewed directly for the eight-hour standard.

The staff member assigned to ozone RACT reviews had left the program since the 2006

re views were made. We were unable to locate a few of the reviews, perhaps lost during a corruption of

our network at the end of 2007. In these cases our engineering staff reconstructed the re v iew. Other

files are s till marked draft

, wi th some supervisor note s.

Please contac t Jayme Graham at 412-578-8129

, jgraham@achd.net

, if you have any que stions

.

E n closure

25-CS-0911 

### Sincer1;;lely, 

## cCt L/

I

### t~**~**

s Thompson, Manager

Air Quality 

### Program

### ACHD CASE-BY-CASE EVALUATIONS

The Department has evaluated all eligible s ources case-by-case for applicability to NOx RACT. All sources that were subj ect to, and instituted, a 1-hour RACT plan, were re-evaluated as to the adequacy of that pl an to the 8-hour RACT requirement s. The Department certifies that theses sources have an adequate RACT demonstr ation for 8-hour ozone in their 1-hour plan. One source, Laurel Mountain Whirlpool, Inc. did not have a 1-hour RACT plan. This source, however, is subject to the National Emissi on Standards for Hazardous Air Pollutants for Reinforced Plastic Composites Production, 40 CF R subpart wwww. The Department certifies that the requirements of 40CFR Subpart wwww are adequate for the 8-hour ozone RACT for this

source.

TABLE 3: CASE-BY-CASE 8- HOUR RACT EVALUATION

2006 VOC & NOx RACT - Allegheny County

Plan
No. Permit No. Facility VOC NOx Has a
Ozone 1-hr
RACT Plan Sufficient
for 8 hr
RACT? Notes
1 0059 Allegheny Ludlum Corp. x x Yes Yes
2 0037 Ashland Specialty Chemical Co. x x Yes Yes
3 0079 Bay Valley Foods x Yes Yes

4 0047 Bellefield Boiler Plant x Yes Yes
5 0058 Eastman Chemical Resins, Inc. x x Yes Yes
6 0005 GE Lighting LLC x Yes Yes
7 0023 Guardian Industries Corp. x Yes Yes
8 0029 Koppers Industries, Inc. x Yes Yes
9 0014 Laurel Mountain Whirlpool, Inc. x No -- *1

10 0060 Neville Chemical Co. x x Yes Yes
11 0022 NRG Energy Center x Yes Yes

12 0056 Orion Power Brunot Island x x Yes Yes

13 0054 Orion Power Cheswick x Yes Yes

14 0044 PACT x Yes Yes

15 0008 Port Glenshaw Glass, LLC x x Yes Yes
16 0057 PPG Industries, Inc Springdale x Yes Yes
17 0032 Pressure Chemical Company x Yes Yes
18 0025 Shenango Inc. x x Yes Yes

19 0052 USSteel Clairton x x Yes Yes

20 0051 USSteel ET x x Yes Yes

21 0050 USSteel Irvin x x Yes Yes

Notes
*1 Laurel Mountain Whirlpool is subject to the MACT standards of 40CFR 63 subpart wwww;

this is sufficient for VOC RACT.ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM

December 1 6 , 2011

SUBJECT: Review of 8

- hour Ozone VOC RACT Submittal Allegheny Ludlum

– Brackenridge Plant
100 River Road Brackenridge, PA 15014

TO: Sandra L. Etzel Chief Engineer

FROM: Michael Dorman Air Quality Engineer

INTRODUCTION:

This document replaces the original 2006 document that was lost when files were corrupted.

Allegheny Ludlum (AL) is a major source of NOx and VOC emissions as defined in §2101.20 of Article XXI . This requires AL to evaluate VOC RACT for the facility and implement appropriate measures as necessary. These RACT requirements were made a part of Allegheny County’s port ion of the Pennsylvania SIP by way of a site specific SIP revision. A RACT review for th is facility was originally developed in 1994

. This review discusses those changes in the facility that took place between 1994 and 2006.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006; all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated
under t he rules for the 8

- hour SIP. This document presents the findings of the reevaluation of VOC RACT for the facility.

The facility is a major source of volatile organic compounds (VOCs), and nitrogen oxides (NOx), as defined in §2101.20 of Article XXI.

SO URCE DESCRIPTION:

The Allegheny Ludlum Brackenridge Plant, located at 100 River Road, Brackenridge, Allegheny County, PA, is a producer of stainless steel and silicon strip steel from scrap steel.

The only change at the facility impacting NOx and VOC emissions was the replacement of four (4) electric arc furnaces (EAFs) by two (2) larger capacity EAFs.

Additionally, i n 2010, the facility shut down its two (2) basic oxygen furnaces (BOFs), three (3) electric induction furnaces (EIF), two (2) EIF scrap preheaters, four (4) BOF ladle preheaters and two (2) BOF vessel preheaters.2 The following table lists the NOx and VOC emission s related to the change in EAFs at the Allegheny Ludlum Brackenridge Plant:

SOURCE RATING (tons/heat) CONTROLS MAXIMUM POTENTIA L
EMISSIONS 1 (tpy)

NOx VOC

EAF 31 70 DEC/baghouse

115.36 104.24 EAF 32 70 DEC/baghouse

EAF 33 60 DEC/baghouse

EAF 34 60 DEC/baghouse

EAF 1 112 DEC/baghouse 122.92 118.84 EAF 2 112 DEC/baghouse

DIFFERENCE + 7.56 + 14.60

1 Maximum Potential Emissions from TSD for IP No. 0062

- I006

Section 1.3 of RACT Order No. 260, dated December 19, 1996, states that:

“ALC shall maintain the following equipment in accordance with good engineering and air pollution control practices.

... 2. Electric arc furnaces No. 31 through No. 34...”

NOx RACT ANALYSIS :

The following technologies were identified during the re

- evaluation of RACT for the

c

onversion from four (4) to two (2) EAFs at the melt shop:

 Selective Non

- catalytic Reduction ( SNCR )
 Selective Catalytic Reduction ( SCR )

These control methods have not been applied to NOx emissions from an EAF. The only practicable place for installation is at the outlet of the baghouses. This location would extend the time until plugging of the cataly st occurred. However, the low temperature of the exhaust gas (under 2 0 0° F) would not allow the chemical reaction needed to convert NOx to N2 t o occur. Additionally, the fine particulate not captured by the baghouse contains lead and iron which will poison the catalyst in SCRs. Therefore, the use of SNCR or SCR for NOx reduction in EAFs is technically infeasible. RACT for the EAFs is proper maintenance and operation according to good engineering and air pollution control practices at all times.

VOC RACT ANALYSIS:

The following technologies were identified during the re

- evaluation of RACT for the conversion from four (4) to two (2) EAFs at the melt shop:

 Catalytic Oxidation
 Thermal Oxid ation3 These control methods differ primarily in the tempera tures at which they operate. A catalytic oxidizer will usually operate at between 600° F and 900° F. A thermal oxidizer must operate at a temperature above the auto ignitio n temperature of the VOC to be effective.

Catalytic Oxidizer:

A catalytic oxidizer could not be installed in the duct work before the baghouse because the heavy concentration of EAF dust in the effluent would blind the catalyst and the metals in the dust would poison the catalyst. It could not operate at the baghouse exhaust because the baghouse is of positive pressure design and does not have a stack. Instead, it exhausts through a roof monitor. The area above the bags is too la rge for a catalytic oxidizer to effectively process the effluent stream. Additionally, the burner would have to heat the exhaust air to greater than 600° F which would destroy the bags in the baghouse. Therefore, a catalytic oxidizer i s technically infea sible.

Thermal Oxidizer:

The baghouses are a positive pressure design. A thermal oxidizer could not operate at the baghouse exhaust because the burner would have to heat the exhaust air to greater than the auto ignition of the VOCs present in the effluent gas stream. S uch temperature would be greater than that of a catalytic oxidizer . This temperature would destroy th e bags in the baghouse. Therefore, a thermal oxidizer is technically infeasible at this location.

A thermal oxidizer could concei vably be installed into the EAF exhaust duct work prior to the baghouse. This has never been done for this type of facility. One would need to put a
thermal oxidizer in the duct from each of the canopy hood s to their respective baghouse s and in the duct from each EAF to the ir baghouse s

. This would require a minimum of four (4) thermal
oxidizers

, if done before the split to the two (2) EAF baghouses serving each furnace

.

From EPA Fact Sheet EPA

- 452/F

- 03

- 022 the capital costs are from $25.00 to $90.00 p er scfm for packaged thermal incinerators in 2002 dollars. The annual O & M costs range from $5.00 to $75.00 per scfm annually. Using stack test flow rates, the capital costs for installing thermal
oxidizers on the EAFs are as follows:

F1 Canopy = 401,1 00 scfm × $ 25/scfm = $ 10,027,500

F2 Canopy = 496,500 scfm × $25/scfm = $12,412,500

No. 1 A/B DEC BH = 77,000 scfm × $25/scfm = $1,925,000

No. 2 A DEC BH = 39,000 scfm × $25/scfm = $975,000

No. 2 B DEC BH = 39,000 scfm × $25/scfm = $975,000

Total capital cost for installing four (4) thermal oxidizers is equals $26,215,000

.

The VOC increase associated with converting from four (4) furnaces to two (2) furnaces is 14.6

tons

.

$26,215,000 ÷ 14.6 tons = $1,795,547.95/ton of VOC removed4 Based on the above calculations, it is economically infeasible to install thermal oxidation
controls for VOC removal. RACT for the EAFs is proper maintenance and operation according to good engineering and air pollution control practices at all times.

No thermal or c atalytic oxidizer has ever been used to control VOC emissions from EAFs per the RACT/BACT/LAER Clearing House

.

RECOMMENDATION:

The analyse s for NOX and VOC RACT for the 8

- hour ozone SIP has demonstrated that any NOX or VOC controls for the sources liste d in the Table

, above

, are technically or economically infeasible. It is recommended that the 1

- hour ozone RACT in RACT Plan Approval Order & Agreement No.2 60 , dated December 19 , 1996 still be considered NOX and VOC RACT (8

- hour ozone) for the facility.ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM

February 14 , 2012

SUBJECT: Review of 8

- hour Ozone VOC and NO X RACT Submittal

Ashland Inc.

2650 Neville Road Pittsburgh, PA 152 25

TO: Sandra L. Etzel Chief Engineer

FROM: JoAnn Truchan Air Quality Engineer

INTRODUCTION:

This document replaces the original 2006 document that was lost when files were corrupted.

In 2006, Ashland Inc. was a major source of NO X and VOC emissions as defined in §2101.20 of Article

XXI . This require d Ashland to evaluate NO X and VOC RACT for the facility and implement appropriate measures as necessary. These RACT requirements were made a part of Allegheny County’s portion of the Pennsylvan ia SIP by way of a site specific SIP revision. A RACT order for th is facility was originally issued on December 30, 1996 (#227)

. This review discusses any changes in the facility that took place

between 1996 and 2006.

The County is presently in non

- at tainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006; all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rule s for the 8

- hour SIP. This document presents the findings of the reevaluation of NO X RACT for the facility.

SOURCE DESCRIPTION:

The Ashland Inc. Neville Island facility, located at 2650 Neville Road, Neville Township, PA, is a manufacturer of polyester resins. The Polyester Resins Plant consists of two (2) reactors, three (3) cooling tanks, and three (3) thinning tanks. Emissions from the Polyester Resins process are controlled by a 9.0 MMBtu/hr thermal oxidizer, which also acts as an incinerator for aqueous wastes. The Terminal portion of the facility loads, stores, and off

- loads various materials (including plasticizers and 2

- e thyl hexanol) from other Ashland facilities. No plasticizers are produced on

- site. In addition to numerous

above

- ground storage tanks, the facility also has one 75 MMBtu/hr natural gas

- fired boiler, one 16.5 MMBtu/hr natural gas

- fired hot oil heater, and a 2,000 gallon/minute cooling tower.

Prior to 2006, the Ashland facility did not include the plasticizer terminal. However, it did have a 10 MMlb/yr Maleic Anhydride Plant, and an additional 113 MMBtu/hr boiler. At the time, both boilers

could combust both natural gas and fuel oil.

The facility shut down the Maleic Anhydride Plant in 2006, just prior to the Department’s request for aAshland Inc. (#00 37 )

2006 RACT Review

2 RACT update (see correspondence dated June 23, 2006). The closure of this operation resulted in the facility’s potentia l

- to

- emit (PTE) of VOC dropping below the major source threshold. Therefore, a review of VOC RACT is not required.

In 2006, t he facility consists of the following NO X emission sources:

SOURCE RATING (MMBtu/hr) FUEL CONTROLS MAXIMUM POTENTIAL

NO X EMISSI ONS 1 (tpy)

lb/ hr tpy

Main Boiler 113 n.g./fuel oil none 18.08 58.35 Back

- Up Boiler 75 n.g./fuel oil none 12.32

Thermal Oxidizer 9 n.g. none 8.74 36.28

1 Maximum Potential Emissions from TVOP

, issued February 5, 2007

.

As part of the Title V Operating Permit process, Ashland agreed to limit a limit on fuel use in the two boilers, as well as a facility

- wide limit of 98 tpy of NO X . The limit on fuel use is an enforceable permit condition, and results in the facility being a synthetic minor source of NO X . Therefore, a review of NO X RACT is not required.

RECOMMENDATION:

The analys i s for NO X and VOC RACT for the 8

- hour ozone SIP has demonstrated that the facility is a minor source of VOC and a synthetic minor source of NO X . It is recommend ed that the 1

- hour ozone RACT in RACT Plan Approval Order & Agreement No. 2 27 , dated December 30, 1996 still be

considered NO X and VOC RACT (8

- hour ozone) for the facility.ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM

February 7, 2012

SUBJECT: Review of 8

- hour Ozone NO X RACT Submittal Bay Valley Foods (formerly Del Monte Corporation)

10 75 Progress Avenue Pittsburgh, PA 15212

TO: Sandra L. Etzel Chief Engineer

FROM: JoAnn Truchan Air Quality Engineer

INTRODUCTION:

This document replaces the original 2006 document that was lost when files were corrupted.

Bay Valley Foods is a major source of NO X emissions as defined in §2101.20 of Article XXI . This requires Bay Valley to evaluate NO X RACT for the facility and implement appropriate measures as necessary. These RACT requirements were made a part of Allegheny County’s portion of the Pennsylvania SIP by way of a site specific SIP revision. A RACT review for th is facility was originally developed in 199 3 , and was amended in 200 5

. The 199 6 RACT order (#211) was submitted under Heinz USA; the 200 5 and 2006 RACT submittals, as well as Title V Operating Permit #0079 were submitted under Del Monte Corporation. This review discusses any chang es in the facility that took place between

2004 and 2006.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006; all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings of the reevaluation of NO X RACT for the facility.

SOURCE DESCRIPTION:

The Bay Valley Foods facility in Pittsburgh is a manufacturing and packaging facility for baby foods and soups, along with other specialty foods. In addition to the production and packaging equipment, the facility has five (5) operating boilers, which provide steam to the facility. F our of these are coal and natural gas fired; the fifth is natural gas fired. The facility is a major source of Particulate Matter (PM), Particulate Matter <10 μm (PM 10 ), Nitrogen Oxides (NO X ), Sulfur Oxides (SO X ), Carbon Monoxide (CO), and Hydrochloric Ac id (HCl).

The facility consists of the following NO X emission sources:Bay Valley Foods (#0079)

2006 RACT Review

2 SOURCE RATING (MMBtu/hr) FUEL CONTROLS MAXIMUM POTENTIAL

NO X EMISSIONS 1 (tpy)

lb/MMBtu tpy

#1 CE 91 coal/n.g. dry gas cyclone 0.45 111

#2 CE 91 coal dry gas cyclone 0.45 111

#3 B&W 61 coal/n.g. dry gas cyclone 0.64 74

#4 B&W 61 coal/n.g. dry gas cyclone 0.64 74

#8 Zurn 180 n.g. low NO X burners;

FGR 0.10 78

1 Maximum Potential Emissions from Consent Agreement #211, June 9, 2005, §1.1.

NO X RACT ANALYSIS :

The following control technologies were identified in the June 30, 2006 re

- evaluation of RACT for the subject boilers :

Fuel Control

**•** Ultra

- Low Nitrogen Fuels **•** Fuel Switching

Combustion Control

**•** Inject Air **•** Over Fire Air

**•** Inject Fuel **•** Air Staging

**•** Water/Steam Injection **•** Reduced Air Preheat

**•** Oxygen Instead of Air for Combustion **•** Catalytic Combustion

**•** Low NO X Burners **•** Off

- Stoichiometric or Staged Combustion

**•** Flue Gas Recirculation **•** Biased Burner Firing

**•** Combustion Optimization **•** Fuel Staging

**•** Burners Out of Service **•** Fuel Reburning

**•** Less Excess Air

Post

- Combustion Control

**•** Non

- Thermal Plasma Reactor **•** Selective Catalytic Reduction (SCR)

**•** Injection of Oxidant **•** Selective Non

- Catalytic Reduction (SNCR)

**•** Sorption (Adsorption/Absorption)

Boilers #1, #2, #3, and #4 are coal

- fired traveling grate (stoker) type. The following types of control technologies from the table above are not technically feasible with this type of boiler:Bay Valley Foods (#0079)

2006 RACT Review

3 **•** Burners Out of Service **•** Fuel Reburning **•** Injection of Oxidant

**•** Over Fire Air **•** Biased Burner Firing **•** Catalytic Combustion

**•** Low NO X Burners **•** Reduced Air Preheat **•** Non

- Thermal Plasma

**•** Air Staging **•** Off

- Stoichiometric or Staged Combustion **•** Sorption (Adsorption/ Absorption)

**•** Fuel Staging **•** Water/Steam Injection **•** Less Excess Air

**•** Oxygen instead of Air **•** Inject Air **•** Inject Fuel

Flue Gas Recirculation (FGR) FGR was attempted on Boilers #1 & #2. However, this did not result in any measurable NO X reduction. Due to their design, implementation of FGR on Boilers #3 & #4 would result in an extensive and costly redesign and rebuild of the boilers. Therefore, FGR is considered technically infeasible.

Combustion Optimization Combustion Optimization is currently being practiced on all boilers. This includes training of operators and the use of DCS and oxygen monitors currently installed.

Ultra

- Low Nitrogen Fuels

Thermal NO X , not fuel NO X , is the primary cause of NO X emissions from these boilers. Therefore lower nitrogen content in the fuel will not result in measurably lower NO X emissions.

Selective Catalytic Reduction (SCR) SCR has not been demonstrated on similar types of boilers. Furthermore, because these units are not

load

- based, the large swings in load would make it difficult to control ammonia/urea injection, resulting in either decreased effectiveness or a high degree of ammonia slip. Therefore, SCR is considered technically infeasible.

Selective Non

- Catalytic Reduction (SNCR) SNCR has not been demonstrated on similar types of boilers. Furthermore, because these units are not

load

- based, the large swings in load would make it difficult to control ammonia/urea injection, resulting in either decreased effectiveness or a high degree of ammonia slip. Additionally, given the boilers’ operating parameters, it is unlikely that the proper residence time or temperature window exist to properly complete the SNCR reactions. Therefore, SNCR is considered technically infeasible.

Fuel Switching Switching to a fuel with lower NO X emissions (such as natural gas) is technically feasible, although it would entail upgrading existing natural gas burners to low

- NO X burners and installing gas burners on

Boiler #2.

Neglecting the cost of changing to all low

- NO X burners, the cost of fuel switching is based on the following:

Cost of c oal = $62/ton (based on 2006 values) Heating v alue = 13,059 Btu/lb = 26.12 MMBtu/ton

Cost of c oal = $2.37/MMBtu

Cost of nat. gas = $8.24/mcf (based on 2006 values) Heating value = 1,045 Btu/scf Cost of nat. g as = $7.89/MMBtuBay Valley Foods (#0079)

2006 RACT Review

4 Gas NO X emissions = 50 lbs/mmcf = 0.048 lb/MMBtu (from AP

- 42, §1.4, for low

- NO X burners)

Cost of NO X reduction = (Δ cost $/MMBtu) ÷ ( Δ emissions lbs/MMBtu)

For Boilers #1 & #2:

Cost of NO X reduction = (7.89

– 2.37) $/MMBtu ÷ (0.45

– 0.048) lbs/MMBtu = $13.95/lb = $27,910/ton of NO X controlled

For Boilers #3 & #4:

Cost of NO X reduction = (7.89

– 2.37) $/MMBtu ÷ (0.64

– 0.048) lbs/MMBtu = $9.32/lb = $18,650/ton of NO X controlled

Based on fuel costs, fuel switching is not economically feasible for Boilers #1 through #4. Boiler #8 currently combusts only natural gas with low

- NO X burners.

RECOMMENDATION:

The analys i s for NO X RACT for the 8

- hour ozone SIP has demonstrated that any NO X controls for the

sources listed in the emission source t able above are technically or economically infeasible. It is

recommended that the 1

- hour ozone RACT in RACT Plan Approval Order & Agreement No. 211 , dated June 9, 2005 still be considered NO X RACT ( 8

- hour ozone) for the facility.

### ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

January 25, 2007

SUBJECT: Review of 8

- hour Ozone NO X RACT Submittal

Bellefield Boiler Plant

4400 Forbes Avenue Pittsburgh, Pennsylvania 15213

- 4080

TO: Sandra L. Etzel Chief Engineer

FROM: JoAnn T ruchan Air Quality Engineer

INTRODUCTION :

Bellefield Boiler (Title V Operating Permit No.0047a) is a major source of NO X emissions as defined in §2101.02 "Definitions", of Article XXI, ACHD, Rules and Regulations, Air Pollution Control and was subject to the County’s 1

- hour ozone SIP. This required the source to evaluate NO X RACT for the facility and take the appropriate measures to implement this RACT. In addition, these RACT requirements were made a part of Allegheny County’s portion of the Pennsylvan ia SIP by way of a site

- specific SIP revision.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006; all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings

of the reevaluation of NO X RACT for the facility.

SOURCE DESCRIPTION :

The Bellefield Boiler Plant, is a captive steam generation facility located on Boundary Street in the Oakland section of Pittsburgh, PA, which supplies steam for heating and refrigeration to institutional sites in that area. The plant is composed of six boilers exhausting to one stack, which fire coal, natural gas, No.2 fuel oil or combinations of fuels. The facility is a major source of nitrogen oxides (NO X ), and a minor source of volatile organic compounds (VOCs) as defined in §2101.20 of Article XXI.

The facility consists of the following NO X e mission sources:

Make/Model NO X Control Device(s) Maximum Capacity Fuel Maximum

Potential

Emissions

Boiler #1 Babcock & Wilcox

Overfeed Stoker None 124

MMBtu/hr Bituminous

Coal/Natural Gas 376 tpy

Boiler #3 Erie City

– VC Overfeed

Stoker None 128

MMBt u/hr Bituminous

Coal/Natural Gas/

No. 2 Fuel Oil 242 tpy

Boiler #5 Erie City

– VC Overfeed

Stoker None 134

MMBtu/hr Bituminous

Coal/Natural Gas 261 tpy

Boiler #6 Zurn Erie City

– Keystone

M21 FGR 179

MMBtu/hr Natural Gas/ No. 2

Fuel Oil 191 tpyMake/Model NO X Control Device(s) Maximum Capacity Fuel Maximum

Potential

Emissions

Boiler # 7 IBW

– WM 1500 Low NO X Burners / FGR 188

MMBtu/hr Natural Gas/ No. 2

Fuel Oil 65 tpy

Boiler #8 Nebraska (rental unit) Low NO X Burners / FGR 160

MMBtu/hr Natural Gas 21 tpy

POTENTIAL EMISSIONS:

The RACT emission limits for boilers No.1 through No.7 set forth in Plan Approval Order and Agreement Upon Consent (RACT Order) No.248, dated December 19, 1996 are the potential NO X emissions including all enforceable controls and restrictions for those units regardless of combustion of coal, fuel oil or natural gas. Coal fired boilers No.2 & No.4 were shut down in December 2003 and November 2002 respectively.

NO X Emission Unit Limit Basis lb/MMBtu tpy

Boiler #1 0.92 376 RACT Order No.248

Boiler #3 0.63 242 RACT Order No.248

Boiler #5 0.59 261 RACT Order N o.248

Boiler #6 0.28 191 RACT Order No.248

Boiler #7 0.20 65 RACT Order No.248

EXISTING CONTROLS / CURRENT RACT REQUIREMENTS:

The subject boilers presently have no controls for NO X emissions. Boilers No.6, No.7, and No.8 are natural gas

fired boiler s with existing control technologies already commensurate with RACT.

Current RACT Requirements include the following:

**•** Limits on emissions for Boilers No. 1 through No. 7 (listed under “Potential Emissions” above);

**•** Limit the average annual heat input to th e natural gas burner in Boiler No. 3 to 64 MMBtu/hr or 560,640 MMBtu/yr;

**•** Proper operation and maintenance of Boilers No. 1 through No. 7;

**•** Testing for NOX on Boilers No. 1 through No. 6 every five (5) years;

**•** NOX continuous emission monitoring (CEM) system o n Boiler No. 7; and

**•** Recordkeeping necessary to demonstrate compliance with the RACT requirements.

NO X RACT ANALYSIS:

Boilers No.1, No.3, No.5, No.6 & No.7

Bellefield Boiler’s RACT analysis, submitted in correspondence from Bellefield Boiler to the Depa rtment, dated August 4, 2006 was conducted with guidance from U.S. EPA's OAQPS Cost Manual and actual cost data from vendor

estimates.

The following NO X Control technologies were considered for coal

- fired boilers No.1, No.3, & No.5 and were found to

be te chnically feasible . However, all were found to be not economically feasible.1. Selective Non

- Catalytic Reduction (SNCR)

– this technology involves post combustion removal of NO X with ammonia or urea injection into the flue gas stream at a temperature betwe en 1,600°F to 2,000°F with a residence time of 1 to 2 seconds. Because of unfavorable temperature

- time profile and limited boiler height, vendor estimates predict a destruction efficiency of only 20%

- 25% (compared to 60

- 65% in a more ideal scenario). Fur thermore, maintaining this destruction efficiency would require a higher use of urea/ammonia, resulting in a higher ammonia slip.

2. Selective Catalytic Reduction (SCR)

– this technology involves post combustion removal of NO X with a catalytic reactor and a mmonia injection. SCR technology is technically feasible and would have a better destruction efficiency than SNCR, 60

- 70% reduction. However, the capital costs are higher due to the purchase of the catalyst, as well as a particulate control system to avo id plugging the catalyst bed. Additionally, Bellefield Boiler does not have enough space to allow for the addition of the catalyst bed, particulate control system, ammonia storage, etc. required in an SCR system.

3. Wet Scrubbing

– this technology involves converting NO in the flue gas to NO 2 by contacting it with an oxidizing agent such as ClO 2 . Then the gas is reduced in a second scrubber with a low

- cost reducing agent such as a bisulfate. This method has not been proven in industrial scale applications and would require similar capital equipment costs and space requirements as an SCR system.

4. Gas

- Fired Combustors / Low NO X Burners / Flue Gas Recirculation (FGR)

– this technology consists of replacing the burners on boilers No.1, No.3, & No.5. It is est imated that replacing the conventional gas burners

with low

- NO X burners could result in a 40

- 50% reduction in NO X . Based on the modifications required to piping, electrical systems, instrumentation, and controls (per the burner manufacturer’s recommendati on), as well as modifications to the boiler itself, the costs make the option unfeasible.

5. Fuel Switching

– NO X reductions can be achieved by using boilers No.6 and No.7 (with FGR and a low

- NO X burner, respectively) and boiler No.8 (with FGR and low

- NO X bu rners) instead of burning coal in boilers No.1, No.3, & No.5. This would result in a 50

- 60% reduction of NO X . However, there is a significant increase in

fuel costs.

6. Natural Gas Only

– Bellefield Boiler gives two scenarios for this option: the first is a switch to natural gas with no change in the existing boilers; the second alternative is to upgrade the burners on boilers No.1, No.3, & No.5

to low

- NO X burners. The capital costs associated with upgrading the burners make the alternative option

economic ally unfeasible.

Ranking of Technically Feasible Control Options:

Control Technology Potential Controlled

NO X Emission Rate (lbs/MMBtu) Control

Boiler: No.1 No.3 No.5

Uncontrolled 0.439 0.282 0.333

1 Natural Gas Only w/Existing Burners 0.100 0. 280 0.100

2 Natural Gas Only w/Low NO X Burners 0.070 0.140 0.070

3 Low NO X Burners Only 0.263 0.169 0.200 40%

4 Low NO X Burners (larger capacity) 0.220 0.141 0.167 50%

5 SNCR 0.340 0.219 0.258 22.5%

6 Fuel Switching 0.140* 0.140* 0.069*

* Using bo ilers No.6, No.7 and No.8 respectively.Summary of Cost Effectiveness:

Control Technology Fuel Type $/Ton Removed

SNCR Coal, Fuel Oil or N.G. 9,382

Low NO X Burners Only Coal, Fuel Oil or N.G. 6,546

Low NO X Burners (larger capacity) Coal, Fuel Oil o r N.G. 8,029

Low NO X Burners w/FGR Coal, Fuel Oil or N.G. 16,793

Fuel Switching Coal, Fuel Oil and N.G. 44,867
Natural Gas Only w/Low NO X Burners Natural Gas 1,976

RECOMMENDATION:

The analysis for NO X RACT for the 8

- hour ozone SIP has demonstrated that all NO X controls for boilers No.1, No.3 and No.5 are technically or economically infeasible using EPA’s Cost Control Manual, ACT document for ICI Boilers and the preamble to the amendments to 40 CFR 51 for the 8

- hour ozone SIP. It is recommended that the 1

- hour ozone RACT in RACT Plan Approval Order & Agreement No.248, dated December 19, 1996 still be considered NO X RACT (8

- hour ozone) for the facility.

### ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

September 27, 2006

SUBJECT: Review of 8

- hour Ozone NO X RACT Orion Power MidWest, L.P.

Cheswick Power Station

– Auxiliary Boiler Pittsburgh and Porter Street Springdale, PA 15144

TO: Sandra L. Etz el Chief Engineer

FROM: Erin J. O’Brian, P. E. Air Quality Engineer

INTRODUCTION :

Orion Power MidWest, L.P., Cheswick Power Station (title V Operating Permit No.0054) is a major source of NO X emissions as defined in section 2101.02 "Definitions", of Ar ticle XXI, ACHD, Rules and Regulations, Air Pollution Control and was subject to the County’s 1

- hour ozone SIP. This required the source to evaluate NO X RACT for the facility (Main boiler and auxiliary boiler) and take the appropriate measures to implemen t this RACT. In addition these RACT requirements were made a part of Allegheny County’s portion of the Pennsylvania SIP by way of a site

- specific

SIP revision. The NO X RACT for the auxiliary boiler consisted of a finding of “no NO X controls were required” due to technical and economic infeasibility.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006, all 1

- hour ozone S IP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings

of the reevaluation of NO X RACT for the auxiliary boiler.

SOURCE DESCRIPTION :

The Orion Power MidWest, L.P., Chesw ick Power Station is an electric generating facility located on Pittsburgh and Porter Streets in Springdale, PA. The plant is composed of one main boiler exhausting to one stack, which fires coal as the primary fuel and natural gas, and synfuel as auxiliar y fuels for startup, shutdown, and during upset conditions. Pollution control equipment for the main boiler includes low NOx burners, electrostatic precipitation with flue gas conditioning, and selective catalytic reduction. The plant also has a No. 2 oil fired auxiliary boiler which exhausts to a separate stack. The facility is a major source of nitrogen oxides (NO X ) and a minor source of volatile organic compounds (VOCs) as defined in section 2101.20 of Article XXI.

The facility consists of the followi ng NOx emission sources:

Make/Model Rating Controls Fuel Maximum

Potential

Emissions

Aux. Boiler Riley Stoker External

Combustion Boiler 160

MMBtu/hr None No. 2 fuel oil 37.54 tons/year

NOxPOTENTIAL EMISSIONS:

The NO X emission limit above for the auxiliary boiler set forth in Title V permit 0054, dated November 9, 1998 is the potential NO X emissions including all enforceable controls and restrictions for the unit.

NO X RACT ANALYSIS:

Auxiliary Boiler:

Orion’s RACT analysis, submitted in corr espondence from Duquesne Light Co. (previous owner) to the Department, dated November 1, 1994 was conducted with guidance from USEPA “Alternative Control Techniques Document

– NO X Emissions from Industrial/Commercial/Institutional (ICI) Boilers” (EPA

- 453 R

- 94

- 022), AP

- 42, 1.3, 9/98 and actual cost data. This analysis is not a part of Orion’s 1

- hour ozone RACT in RACT Plan Approval Order & Agreement No.217, dated March 8, 1996.

According to Figure 6.6 of the ACT document for ICI Boilers, low NO X burners ar e the most cost effective control devices for boilers of this size with oil firing only, therefore this technology will be the only one analyzed. The NO X control efficiency as per the ACT document is 50%.

1. Low NO X Burners

– approximately 50% reduction

– pe r unit basis

Ranking of Technically Feasible Control Options:

Control Technology NO X – Oil or N.G.

Potential Controlled

Emission Rate (lbs/MMBtu)

1 Low NO X With FGR 0.086

Uncontrolled emission rate = 0.1714 lbs/MMBtu of NO X as per AP

- 42, 1.3, 9/98. Uncontrolled tons/yr NO X = 0.1714 lbs/MMBtu x 160 MMBtu/hr x 8760 hrs/yr x 0.3125 capacity factor/2000 = 37.54 tons/yr NO X

The 31.25% capacity factor is equal to a 12

- month rolling heat input of 438,000 MMBtu, which is the heat input

limitation on the b oiler as per Orion’s Title V permit application 0054.

Existing controls:

The subject boilers presently have no controls for NO X emissions.

Summary of Cost Effectiveness 1 :

Control Technology Fuel Type $/Ton Removed in

91 Dollars

Low NO X Burners Only No.2 Fuel Oil 1,835 to 1,998

1 USEPA “Alternative Control Techniques Document

– NO X Emissions from Industrial/Commercial/Institutional (ICI) Boilers” (EPA

- 453 R

- 94

- 022), page D

- 13.

The above analysis was conducted in 1991 dollars. By inspection it is o bvious that the $/ton NO X removed would still be over the present threshold of approximately $1,500/ton NO X removed. No further analysis is required and no controls with a limit of 438,000 MMBtu per 12

- month period will be considered RACT for the boiler.RECOMMENDATION:

The analysis for NO X RACT for the 8

- hour ozone SIP has demonstrated that any NO X controls for the auxiliary boiler are technically or economically infeasible using ACT document for ICI Boilers and the preamble to the amendments to

40 CF R 51 for the 8

- hour ozone SIP. It is recommended that no controls and a 12

- month rolling limit on Btu input of 438,000 MMBtu be considered NO X RACT (8

- hour ozone) for the facility.ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM

March 8 , 2012

SUBJECT: Review of 8

- hour Ozone VOC and NO X RACT Submittal

Cheswick Power Station

– Main Boiler Pittsburgh & Porter Streets Springdale , PA 15 144

TO: Sandra L. Etzel Chief Engineer

FROM: David Good Air Quality Engineer

This document replaces the original 2006 document that was lost when files were corrupted.

Orion Power owns and operates Cheswick Power Station, a 570 MW coal

- fired electric generating station located on the Allegheny River in Springdale Borough, Allegheny County. The Station consists of the

main unit which is a coal

- fired steam generating boile r with a dedicated turbine generator and an oil

- fired station service auxiliary boiler. The facility is a major source of nitrogen oxides (NOx).

In 1996, for the 1

- hour ozone SIP, the Department determined that RACT for the Main Boiler at the

Cheswick Po wer Station was the operation of the Low NOx Concentric Firing System (LNCFS) Level II.

The incremental cost of the various technically feasible op tions ranged from $372 per ton for LNCFS

Level I I to $ 3704 per ton for SCR

.

Since the 1996 RACT, the following changes have occurred at the facility:

**•** In 1998, Pennsylvania Nitrogen Oxides Allowance Program regulations limited emissions during

the ozone season. (PADEP permit #02

- 0054 effective May 15,200 1 )

**•** In 2001, a permit was issued for installation of Selective Catalytic Reduction (SCR). The equipment was operational the following ozone season.

RECOMMENDATION: The 1996 RACT chose LNCFS II technology which reduces NOx by 35%. Since that time SCR was installed which reduces NOx by 80% . This technology al ong with L NCFS II significantly reduces emissions beyond the LNCFS II alone which was determined to be RACT for the 1

- hr ozone SIP. Low

NOx burners with SCR is sufficient for RACT for the 8

- hour ozone SIP

.

### ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM

February 24 , 2012

SUBJECT: Review of VOC RACT

Eastman Chemical Resins, Inc. State Highway 837 West Elizabeth, PA 15088

- 7311

TO: Sandra L. Etzel Chief Engineer

FROM: Helen O. Gurvich Air Quality Engineer

INTRODUCTION

This document replaces the original 2006 document that was lost when files were corrupted.

Eastman Chemical Resin s, Inc. is a major source of VOC emissions as defined in §2101.20 of Article XXI.

Thi s requires an evaluat ion of VO C RACT for the facility and implement ation of appropriate measures as

necessary. The previous RACT requirements w ere made a part of Allegheny County's portion of the Pennsylvania SIP by way of a site specific SIP revision. A RACT review for this facility w as originally developed in 1996. This review discusses those changes in the facility that took place between 1996 and 2006.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amend ments to 40 CFR 51, Subpart X, effective January 30, 2006; all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings of the reevaluation of VOC RACT for the facility.

SOURCE DESCRIPTION:

Eastman Chemical R esins, Inc., located at State Highway 837, West Elizabeth, Allegheny County, PA, is a producer of synthetic hydrocarbon resins in various batch and finishing processes which require heat at various stages

.

The plant is comprised of four polymerization processes (C

- 5, MP

- Poly, WW

- Poly and Thermal Poly), a resin hydrogenation process, five finishing processes (V

- 8, LTC 1, LTC 2, LTC 3 and C

- 5), and an emulsion process, five boilers ranging from 30 MM Btu/h r to 38.2 MM Btu/hr, a wastewater treatment plant, a pilot plant for testing formulations and processes and approximately 200 storage tanks of various sizes.

### The following table lists the changes at the facility after 1996 that impacted VOC emissions :

Permit No. Issued Date Project Description Controls Max PTE (tpy) 1



### 0058

- I002 05/27/1997 Expansion of the existing Solution Polymerization Unit (n ew 10 ,000 gallon reactor) and new tank T

- 1203

for toluene. Refrigerated water on

selected vent condensers

a nd wet scrubber. 19.7

0058

- I004 06/11/1997 Three condenser systems for the

control of VOC from the Water White Polymerization north and

south reactors and nuetralizer. Three chilled water refrigerated condenser

systems. - 39.0

0058

- I009 10/03/2002 Refrige rated condenser system followed by a carbon adsorption

unit for VOC control on tanks No. 4,

21 and 253. Refrigerated condenser system and a carbon adsorption unit - 0.43

005 8

- I010 10/09/2002 Modification to the V

- 8 unit for ink

oil resins. No changes in con trol

devices. - 0.09

0058

- I011 08/19/2004 Removal of the refrigerated condenser control system and install

thermal oxidizer to C

- 5 process. Thermal oxidizer 0.00

Total Difference

- 19.82

1 

### Maximum Potential Emissio ns from TSD for IPs.

The VOC RACT Orde r No.257, dated January 14, 1997, stated that:

" 1. 3.

.... Hercules shall complete installation of refrigerated condenser systems, for the pu rpose of reducing

VOC emissions... 1.4 By no later than August 1, 1997, Hercules shall commence operation of the refrigerated condenser systems, for the purpose of reducing VOC emissions..." "

RACT ANALYSIS

- 2006 :

Processes

All processes at the facility have either water

- cooled condensers or refrigerated condensers for VOC control with the exception of the Wastew ater treatment plant (WWTP). Based on the VOC RACT analysis from July
22, 1996

, that was conducted with guidance from EPA

- 453/R

- 93

- 017, "Control of volatile Organic Compound Emissions from Batch Processes" and EPA's OAQPS Cost Manual, the most inexpensive additional control options for Eastman were: 1. to add water cooled condensers to process units which are presently uncontrolled (was founded economically infeasible) ; 2. to upgrade existing cooling tower water condenser systems with refrigerated units (was cons idered the most inexpensive technically feasible options for most processes);

3. installation of separate thermal oxidation units as secondary treatment on the various plant processes (was considered the most inexpensive technically feasible control options, but also was founded that it is cost prohibitive) ; and

### 4. to install a thermal oxidation unit that would process the existing controlled emissions from the facility (was founded to be cost prohibitive and, also, would pose special problems in construction and operation)

.

Based on the conclusions above and conditions of RACT Order N.257, d uring the year 1997 Eastman completed projects for the installation of refrigerated condenser systems with total reduction of VOC emissions of 19.3 tons/yr (see table above, installation permits No. I002 and I004).

The new thermal oxidizer (98% efficiency) on the C

- 5 Process replaced the existing J

- 411 condenser system,

which is a VOC RACT

- applicable control device ( installation permit No. I011 ). Thermal oxidation is a

con siderably more effective VOC control technology than refrigerated condensation technology, and therefore, the current level of control achieved for VOC RACT purposes was exceed by this new installation.

Other replaceme nt technologies were considered for C

- 5 process , including a larger refrigeration unit, a wet scrubber, and carbon adsorption. Due to the desire to control both ammonia and VOC/HAP, a combination of these technologies would need to be employed to achieve this goal (e.g. install a new larger refrigeration system to condense the VOC/toluene and a secondary system to water scrub the ammonia gas) . Th is option

was not chosen because the cost of installing and maintaining two systems was prohibitive. The major reason for this is the large quantiti es of ammonia

- laden wastewater that would result from scrubbing that would need to be treated in the WWTP. Due to capacity and treatability limitations of the WWTP, any additional ammonia water would require a capital addition to the WWTP, thereby making t his option even more cost

intensive. The installation of a thermal oxidizer achieved a higher level of pollution control efficiency, is more reliable to operate, and requires minimal maintenance.

All VOC controls beyond existing controls for all other pro cess units are cost prohibitive. VOC RACT will be the continued proper operation and maintenance of all VOC emission units and VOC controls.

Storage tanks

The facility has approximately 200 storage tanks of various sizes. About 40 of these tanks are subj ect to §2105.12 of Article XXI, "Volatile Organic Compound Storage Tanks", and therefore

, have VOC RACT in place. All another tanks are not subject to the referenced regulation and are subject to VOC RACT analysis. VOC emission controls were analyzed (VOC RACT analysis from July 22, 1996) for:

1. the individual storage tank with the largest VOC potential to emit (the analysis of the possible control options, consist of thermal oxidation and refrigerated condenser systems, demonstrates that both of

that would b e cost prohibitive for a single tank) ; 2. a group of tanks with single control system ( that would be cost prohibitive for a group of tanks with the largest VOC potential to emit ; also, all group of tanks contain different VOC and this mean that any group of tanks would require numerous individual condensation or separation units to recover the mixed condensate from a single condensation unit).

Installation of a refrigerated condenser system followed by a carbon adsorption unit on tanks No.4, 21, and 253 ( in stallation permit No. I009 ) with a total control efficiency of 95% g a ve a reduction of VOC emissions for 0.43 tons/yr and considered VOC B ACT for these tanks, along with monitoring, recordkeeping and reporting requirements.

All VOC controls beyond existin g controls for storage tanks not regulated by § 2105.12 of Article XXI are

cost prohibitive , so VOC RACT for these sources will be proper operation and maintenance.

### Wastewater Treatment Plant (WWTP)

The installation of covers and refrigerated condenser system was considered the most inexpensive control system for this unit (VOC RACT analysis from July 22, 1996). This system is technically feasible, but cost prohibitive

. VOC RACT for these sources will be proper operation and maintenance.

Combustion So urces

Due to the low potential emissions (about 5 tons/year) no add on controls are considered cost effective and VOC RACT is the proper operation and maintenance of the system.

RECOMENDATIONS:

Because there has been a reduction in emissions at the fa cility and because t he analyses for VOC ha ve demonstrated that any VOC controls for the sources at Eastman Chemical Resins, Inc. are technically or economically infeasible. It is recommended that the 1

- hour ozone RACT in RACT Plan A pproval Order & Agreeme nt No.257, dated January 14, 1997 still be considered VOC RACT (8

- hour ozone) for the facility.

### ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

November 30, 2006

SUBJECT: Review of 8

- hour Ozone NO X RACT Submittal General Electric Lighting

– Bridgeville Glass Plant 540 Mayer Street Bridgeville, PA 15017

TO: Sandra L. Etzel Chief Engineer

FROM: James A. Lefik Air Pollution Control Engineer III

INTRODUCTION :

The General Electric Lighting

– Bridgeville (GE

- Bridgeville) glass plant is a major source of NO X emissions as defined in Section 2101.02 "Definitions," of Article XXI, ACHD, Rules and Regulations, Air Pollution Control and was subject to Allegheny County’s 1

- hour ozone State Implementation Plan (SIP). This required the source to evaluate NO X Reasonably Available Control Technology (RACT) for the facility and take the appropriate mea sures to implement this RACT plan. In addition, these RACT requirements were made a part of Allegheny County’s portion of the Pennsylvania SIP by way of a site

- specific SIP revision. The NO X RACT for the facility consisted of a finding of “no NO X controls were required” due to technical and economic infeasibility.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006, all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings

of the reevaluation of NO X RACT for the facility.

SOURCE DESCRIPTION :

The General Electric

- Bridgev ille Glass Plant (GE

- Bridgeville) is engaged in the manufacture of glass tubing using ceramic raw materials. The manufacturing process entails several steps which may generally be categorized as raw material receiving and storage, batch handling and mixing , melting and refining, glass forming and finishing. Glass manufacturing occurs in any of six (6) specialty glass furnaces housed within the plant (Simplex, 180, Special, Gas Electric, Frit, and Germicidal) based on customer glass type specifications and o rders. Raw materials are mixed with cullet (scrap glass) and fed into the furnaces, long length tubing is formed and drawn from the furnaces and cut into sticks. The sticks of glass tubing are either shipped directly to the customer or sent to the finishin g department where they are cut into shorter lengths and then subsequently shipped to the customer. The customers use this tubing in a variety of applications with the primary one being its use in manufacture of light bulbs. The facility is a major source of nitrogen oxides (NO

x ), particulate matter, particulate matter less than 10 microns in diameter (PM 10 ) and hazardous air pollutants (HAPs), and a minor source of carbon monoxide (CO), sulfur dioxide (SO 2 ), and volatile organic compounds (VOCs), as define d in §2101.20 of Article XXI.The facility consists of the following NOx emission sources:

Table 1: Glass Melting Furnaces



### Emission Unit Facility ID Existing NOx Reduction Technology Other

Emission

Controls Fuel Maximum

Potential

NOx

Emissions (tons/y r)

F2

- 8, Furnace #2 Simplex Furnace Electric Boost; Oxy

- firing ESP Natural Gas; Oxy

- fuel 172

F3

- 4, Furnace #3 Gas/Electric Furnace Electric Boost; Oxy

- firing ESP Natural Gas; Oxy

- fuel 31.3

F4

- 3, Furnace #4 Frit Furnace None ESP Natural Gas 21.9

F6

- 3, Furnace #6 Germicidal Furnace None None Natural Gas 43.9

F7

- 4, Furnace #7 Special Furnace Electric Boost ESP Natural Gas 16.7

F8

- 6, Furnace #8 180 Furnace Oxygen enhancement None Natural Gas 121.3

Table 2: Miscellaneous Combustion Sources



### Emission U nit Facility ID Maximum Heat Input Other

Emission

Controls Fuel Maximum

Potential

NOx

Emissions (tons/yr)

F8

- 2 180 Cullet Dryer 3.4 MMBTU/hr Dust

Collector Natural Gas 1.5

F7

- 7 Special Cullet Dryer 3.4 MMBTU/hr Dust

Collector Natural Gas 1.5

F2

- 5 Simpl ex Cullet Dryer 3.4 MMBTU/hr Dust

Collector Natural Gas 1.7

T

- 1 and T

- 2 Tube Drawing and Finishing 0.8 and 2.8 MMBTU/hr None Natural Gas 1.5

EG

- 1 and EG

- 2 Back

- up Generators 0.75 MMBTU/hr and 6.27

MMBTU/hr None Diesel 6.9/14.5

B

- 1 and B

- 2 Boilers 2.07 M MBTU/hr each None Natural Gas (oil back

up) 0.9/0.9

HW

- 1 Water Heaters 0.42 MMBTU/hr total None Natural Gas 0.2

SH

- 1 Space Heaters 0.825 MMBTU/hr total None Natural Gas 0.5

POTENTIAL EMISSIONS:

The RACT emission limits for the Simplex Furnace and the 180 Furnace set forth in Plan Approval Order and Agreement Upon Consent (RACT Order) No.251, dated December 19, 1998 are the potential NO X emissions including all enforceable controls and restrictions for those units regardless of combustion of fuel oil o r natural gas.Table 3: Existing RACT Limits



### Emission Unit Emission Limit (Lbs/hr) Emission Limit (Tons/yr) Basis

F2

- 8, Simplex Furnace 37.5 165 RACT Order

No.251

F8

- 6, 180 Furnace 27.72 122 RACT Order

No.251

NO X RACT ANALYSIS:

Simplex Furnace, Gas/Electric Furnace, Frit Furnace, Germicidal Furnace, Special Furnace, 180 Furnace

GE

- Bridgeville’s RACT analysis, submitted in correspondence to the Department, dated August 1, 2006 was conducted with guidance from U S EPA's OAQPS Cost Manual and actua l cost data. Based on the guidance, the following options were found to be potentially applicable for controlling NOx from the Glass Melting Furnaces identified in Table 1

above at the GE

- Bridgeville facility:

Combustion Modifications

**•** Low excess air

**•** Burn er and port geometry modifications

**•** Low NOx burners

**•** Oxygen enrichment/Oxy

- firing

Process Modifications

**•** Modified furnace

**•** Cullet preheat

**•** Electric boost

**•** Fuel switching

Post

- combustion Modifications

**•** Chemical reduction by fuel

**•** Selective catalytic reduction

**•** Selective non

- catalytic reduction

**•** Adherence to manufacturer’s specifications

The following NO X Control technologies are not demonstrated technologies in the pressed/blown glass sector, and therefore were found to be technically infeasible for the glass me lting furnaces as per the USEPA Alternative Control Techniques (ACT) document, NOx Emissions From Glass Manufacturing , EPA

- 453/R

- 94

- 037, June 1994.

1. Burner and Port Geometry Modifications, Modified Furnace Design and Fuel Switching

– all of the

furnaces ar e direct

- fired furnaces and for the three furnaces burning natural gas in air, the air and fuel are mixed within the natural gas burners. Burner and port geometry modifications imply that the natural gas and

combustion air are mixed outside of the natural gas burners; therefore, it cannot be applied to direct

- fired furnaces. Modified furnace design would imply a major redesign of the furnaces. All furnaces are currently fueled by natural gas; fuel switching refers to a switch to natural gas from coal or oil

.

2. Low NOx Burners

– These burners reduce NOx emissions by delaying combustion that in turn increases the flame length of the burners in the melters. Since these are narrow width furnaces, increasing the flame lengthwould increase the deterioration rate i n the melter breast walls and thus requiring annual repairs and shutdown of the furnaces. Each repair costs approximately $200,000 in addition to lost production. Without low

- NOx burners the useful life of the breast walls on the furnaces is 4 to 8 years.

3. Cullet Preheat

– Cullet preheating systems have been developed but cannot be easily retrofitted to existing furnaces and require a significant amount of floor space. Although cullet preheating reduces NOx emissions, it an increase emissions of other pollu tants such as particulate matter if a suitable cullet cleaning process is not available. In addition, cullet preheating cannot be used when furnace flue gases exhaust through an ESP since the minimum temperature of the gases entering the ESP must be 400 to 450 degrees F. The use of the exhaust gases to preheat the cullet would drop this temperature below the minimum levels required.

4. Selective Catalytic Reduction (SCR) and Selective Non

- Catalytic Reduction (SNCR)

– These technologies have not yet been prove n to be successful in reducing NOx emissions in the pressed/blown glass industry. The temperature of the air entering such systems would need to be raised significantly through preheating since the temperature of the exhaust gases from the furnaces is only 400 degrees F. SCR requires a temperature of 600 to 750 degrees F while SNCR requires a temperature of 1600 to 2100 degrees F. The installation of these systems would also require a significant amount of space within the flue gas pathway where the optimum temperatures can be achieved. Another drawback common to both systems is “ammonia slip” where a portion of the ammonia injected into the systems is emitted in the flue gases and therefore adds to the total emissions from the process since ammonia is a re gulated pollutant. The storage and handling of ammonia, an extremely hazardous substance under SARA Title III of the Clean Air Act, is also another disadvantage of SCR and SNCR.

The control technologies found to be technically feasible are electric boost, oxygen enrichment and oxy

- fuel firing. Additional control techniques found to be technically feasible include the use of cullet in the batch ingredients and adherence to manufacturer’s specifications.

Table 4: Summary of Baseline Levels of NOx Control

NOx Emission Unit Baseline Level of NOx Control

F2

- 8 Simplex Furnace Oxy

- firing

Low Excess Air

Electric Boost

Use of Cullet in Batches Adherence to Manufacturer’s Specifications

F3

- 4

Gas/Electric Furnace Oxy

- firing

Low Excess Air

Electric Boost

Use of Cullet in Batches Adherence to Manufacturer’s Specifications

F4

- 3

Frit Furnace Adherence to Manufacturer’s Specifications

F6

- 3

Germicidal Furnace Low Excess Air Adherence to Manufacturer’s Specifications

F7

- 4 Special Furnace Oxy

- firing

Low Excess Air

Electric Boost

Use of Cullet in Batches Adherence to Manufacturer’s Specifications

F8

- 6

180 Furnace Low Excess Air Oxygen Enrichment

Use of Cullet in Batches Adherence to Manufacturer’s SpecificationsThe NOx removal was estimated using the reductions achieved at GE’s Somerset, Kentucky facility with a glass furnace comparable in size to GE

- Bridgeville’s Simplex Furnace and was demonstrated during a stack test following the installation of oxy

- fuel firing. The NOx reduction level was lower than the EPA ACT document’s 85% potential reduction due to the following reasons:

o The removal level in the EPA ACT document is based on a range of efficiencies from a variety of glass melting

furnaces that do not resemble the furnaces at the GE

- Bridgeville facility.

o The Somerset, Kentucky facility is similar in design and operating characteristics to the furnaces at GE

Bridgeville.

Oxy

- firing is installed on the melter and refiner sections of the furnaces, and not on the forehearth section; therefore,

NOx reduction levels reflect only those achieved from these two sections. Table 5 summarizes the potential NOx reductions from the technologically feasible control options for GE

- Bridgeville’s furnaces:

Table 5: Summary of Technologically Feasible NOx Controls

NOx Emi ssion Unit NOx Control Technology Beyond Baseline NOx Reduction Beyond Baseline

F2

- 8 (Simplex Furnace) None 0

F3

- 4 ( Gas/Electric Furnace) None 0

F4

- 3 (Frit Furnace) Oxy

- firing 70%

F6

- 3 (Germicidal Furnace) Oxy

- firing 70%

F7

- 4 (Special Furnace) None 0

F8

- 6 (180 Furnace) Oxy

- firing 70%

Summary of Cost Effectiveness:

The capital and annualized costs for the technically feasible control options were obtained from Section 6 of the US

EPA ACT document. The 6 th Edition of the ACT document was not used since it does not address oxy

- firing for glass melting furnaces. Since the Simplex, Gas/Electric and Special furnaces are already equipped with oxy

- firing, no cost effectiveness analysis was performed.

Table 6 summarizes the results of the analyses perf ormed for the Frit Furnace, Germicidal Furnace, and the 180 Furnace. All results are based on the potential

- to

- emit. The full analyses can be found in GE

- Bridgeville’s RACT correspondence package dated August 1, 2006. As indicated in Table 6, oxy

- firing is cost

- prohibitive for the remaining

furnaces at GE

- Bridgeville.

Table 6: Summary of RACT Economic Analyses and Cost Effectiveness

Emission

Unit Technology Capital Cost Annualized

Cost NOx

Reduction (Tons/yr) Cost

Effectiveness ($/Ton)

Frit Furnace Oxy

- f iring $586,265 $214,458 15.3 13,989

Germicidal

Furnace Oxy

- firing $729,645 $266,907 30.7 8,691

180 Furnace Oxy

- firing $654,038 $239,249 85.4 2,802RACT for Miscellaneous NOx emission sources

All of the remaining NOx emission sources at GE

- Bridgeville (as listed in Table 2 above) are combustion units with individual maximum rated heat inputs of less than 20 MMBTU/hr, and two diesel fuel

- fired emergency generators. As per Section 2105.06 of Article XXI, GE

- Bridgeville shall comply with Presumptive RACT for these units, which is the installation, maintenance, and operation of the sources in accordance with manufacturer’s specifications at all times.

RECOMMENDATION:

The analysis for NO X RACT for the 8

- hour ozone SIP has demonstrated that any additional N O X controls for all of the glass meting furnaces and miscellaneous combustion sources are either technically or economically infeasible using EPA’s Cost Control Manual, ACT document for glass melting furnaces and the preamble to the amendments to 40 CFR

51 for the 8

- hour ozone SIP. RACT for the glass melting furnaces shall be the existing baseline controls as specified in Table 4 above. RACT for the miscellaneous combustion units shall be the installation, maintenance, and operation of

the sources in accord ance with manufacturer’s specifications at all times. It is recommended that the 1

- hour ozone RACT in RACT Plan Approval Order & Agreement No.251, dated December 19, 1998 still be considered NO X RACT (8

- hour ozone) for GE

- Bridgeville.ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM

February 29, 2012

SUBJECT: Review of 8-hour Ozone VOC and NO X RACT Submittal

Glenshaw Glass

2650 Neville Road Pittsburgh, PA 15225

TO: Sandra L. Etzel Chief Engineer

FROM: Melissa Jativa Air Quality Engineer

This document replaces the original 2006 documen t that was lost when files were corrupted.

In September 2004, the Glenshaw Glass furnaces were damaged in a flood and the facility shutdown on November 24, 2004. A maintenance plan was in pl ace for Furnace 3 and one was submitted for Furnace on October 7, 2004. Approximately one year later (N ovember 18, 2005) the facility was bought by Port

Glenshaw Glass and ERCs for Furnaces 1 and 2 we re applied for on November 23, 2005.

On September 15, 2006, the Department received an In stallation Permit application to “restart” Furnace 2. However, Furnace 2 ceased to exis t when the company applied for emission reduction credits. This required the Department to consider this to be a new source subject to BACT (§2102.04.b.6).

In 2006, the facility consisted of the following NO X emission sources:

SOURCE 1 RATING (tons glass/day) FUEL CONTROLS MAXIMUM POTENTIAL

NO X EMISSIONS 1 (tpy)

lb/hr tpy

Furnace 2 8.75 tons/hr

Natural gas none

none

none 27.2 119.0

Furnace 3 (deactivated 2001) 6.67 tons/hr Not operating

Furnace 4 (deactivated 2004) 7.08 tons/hr Not operating

1 Including associated finishing equipment.

RECOMMENDATION:

The analysis for NO X and VOC RACT for the 8-hour ozone SIP indicates the facility is no longer subject to RACT since the operating furnace has installe d BACT and the remaining furnaces are currently

deactivated. In the event Furnace 3 is reactivated BACT will be require d (§2103.13.d.8). Reactivation of

Furnace 4 before October 2009 woul d require extensive repair and if the burners are replaced the Department would require low NOx burners. If the furnace is reactivated after October 2009, BACT would be required.

### ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

December 12, 2006

SUBJECT: Review of 8

- hour Ozone NO X RACT Submittal Guardian Industries Corporation

– Floreffe Plant

1000 Glasshouse Road Jefferson Hills, PA 15025

- 1000

TO: Sandra L. Etzel

Chief Engineer

FROM: James A. Lefik Air Pollution Control Engineer III

INTRODUCTION :

The Guardian Industries Corporation, Floreffe (Guardian) glass plant is a major source of NO X emissions as defined in Section 2101.02 "Definitions," of Article XXI, ACHD, R ules and Regulations, Air Pollution Control and was subject to Allegheny County’s 1

- hour ozone State Implementation Plan (SIP). This required the source to evaluate NO X Reasonably Available Control Technology (RACT) for the facility and take the appropriat e measures to implement this RACT plan. In addition, these RACT requirements were made a part of Allegheny County’s portion of the Pennsylvania SIP by way of a site

- specific SIP revision. The NO X RACT for the facility consisted of a finding of “no NO X cont rols were required” due to technical and economic infeasibility.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006, all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings

of the reevaluation of NO X RACT for the Guardian facility.

SOURCE DESCRIPTION :

The Guardian fac ility is a “float” glass manufacturing plant located at 1000 Glasshouse Road in Jefferson Hills, Pennsylvania, and primarily manufactures flat glass for the automotive industry. The facility is composed of one glass

melting furnace capable of producing bet ween 250 and 400 tons of glass per day; however, Guardian’s Title V Operating Permit #0023 limits the glass production to 350 tons of glass per day. The raw materials are fed into the furnace after being transported, unloaded, stored and weighed in the “Ba tch House.” The raw materials are transported

on

- site via railroad and truck from various locations. After weighing and blending, the raw materials, including cullet, are conveyed to the furnace for melting, where a continuous ribbon of glass is pulled thr ough the furnace on a layer of molten tin. A computer

- controlled cutting system cuts the glass into the desired sizes as dictated by customer orders.

The facility is a major source of nitrogen oxides (NO

x ), sulfur dioxide (SO 2 ), particulate matter (PM), particulate matter less than 10 microns in diameter (PM 10 ), and hazardous air pollutants (HAPs); the facility is a minor source of carbon monoxide (CO), and volatile organic compounds (VOCs) emissions, as defined in §2101.20 of the Allegheny County

Health Department Rules and Regulations, Article XXI, Air Pollution Control.The facility consists of the following NOx emission source:

Table 1: NO

x Emission Source



### Emission Unit Facility ID Existing NOx Reduction Technology Other Emission

Controls Fuels

Melting Furnace S001 Electric Boost; Oxy

Firing; Low

- NO

x Burners; Cullet Recycling; Minimizing Nitrates; Minimizing Operating Temperature Dry Lime Scrubber

and Electrostatic Precipitator Natural Gas; Oxy

fuel

POTENTIAL EMISSIONS:

The RACT emission l imits for the Melting Furnace set forth in Plan Approval Order and Agreement Upon Consent (RACT Order) No.242, dated August 27, 1996 are the potential NO X emissions including all enforceable controls and restrictions for those units regardless of combustio n of fuel oil or natural gas.

Table 2: Existing NO

x RACT Limits



### Emission Unit Emission Limit
(Lbs/ton of Glass Pulled) Emission Limit (Tons/yr) Basis

Melting Furnace 40.0 2555 RACT Order

No.242

NO X RACT ANALYSIS:

Guardian’s RACT analysis, submit ted in correspondence to the Department, dated July 12 and July 25, 2006 was conducted with guidance from the USEPA Alternative Control Techniques (ACT) document, NOx Emissions From Glass Manufacturing , EPA

- 453/R

- 94

- 037, June 1994. Based on the guidance, t he following options were found to be potentially applicable for controlling NOx from the Melting Furnace identified in Table 1 above at the Guardian facility:

Combustion Modifications

**•** Low excess air

**•** Burner and port geometry modifications

**•** Low NO

x burners

**•** Oxy

- Firing

Process Modifications

**•** Modified furnace

**•** Cullet preheat

**•** Electric boost

**•** Fuel switching

**•** Maximizing cullet in batches

**•** Minimizing nitrates in batches

**•** Minimizing furnace operating temperature**•** Minimizing secondary air

.Post

- Combustion Modifications

**•** Chemical reduction by fuel

**•** Selective catalytic reduction

**•** Selective non

- catalytic reduction

**•** Adherence to manufacturer’s specifications

The following NO X Control technologies are not demonstrated technologies in the flat glass sector, and therefore were

f ound to be technically infeasible for the glass melting furnaces as per the USEPA Alternative Control Techniques (ACT) document, NOx Emissions From Glass Manufacturing , EPA

- 453/R

- 94

- 037, June 1994.

1. Burner and Port Geometry Modifications, Modified Furnace Design and Fuel Switching

– The furnace is

a direct

- fired furnace that burns natural gas in air; therefore, the air and fuel are mixed within the natural gas burners. Burner and port geometry modifications imply that the natural gas and combustion air are mixed outside of the natural gas burners; therefore, it cannot be applied to direct

- fired furnaces. Modified furnace design would imply a major redesign of the furnace. The furnace is currently fueled by natural gas; fuel switching refers to a switch to na tural gas from coal or oil.

2. Cullet Preheat

– Cullet preheating systems have been developed but cannot be easily retrofitted to existing furnaces and require a significant amount of floor space. Although cullet preheating reduces NO

x emissions, it

an incre ase the emissions of other pollutants such as particulate matter if a suitable cullet cleaning process is not available. In addition, cullet preheating using furnace flue gases could affect the quality of the glass produced in

the furnace. A review of the RACT/BACT/LAER Clearinghouse did not reveal any instances of cullet preheating being used on a float/flat glass

- melting furnace.

3. Selective Catalytic Reduction (SCR) and Selective Non

- Catalytic Reduction (SNCR)

– The temperature of the air entering such sy stems would need to be raised significantly through preheating at the ESP exhaust since the temperature of the exhaust gases from the furnace ranges from a low of 575 to a high of 670 degrees F. Insufficient temperatures lead to the formation of sodium bis ulfate. SCR requires a temperature of 650 to 800 degrees F while SNCR requires a temperature of 1600 to 2100 degrees F. The installation of these systems would also require a significant amount of space within the flue gas pathway where the optimum tempera tures can be achieved. Another drawback common to both systems is “ammonia slip” where a portion of the ammonia injected into the systems is emitted in the flue gases and therefore adds to the total emissions from the process since ammonia is a regulated pollutant. The storage and handling of ammonia, an extremely hazardous substance under SARA Title III of the Clean Air Act, is also another disadvantage of SCR and SNCR. Site

specific physical limitations, e.g., location of ammonia storage tanks, also make this option technically

infeasible.

The control technologies found to be technically feasible are electric boost, oxy

- fuel firing, and low NOx burners. Additional control techniques found to be technically feasible include the use of cullet and minimizi ng nitrates in the batch ingredients; minimizing operating temperatures and secondary air in the furnace; and, adherence to manufacturer’s specifications.

1. Low NOx Burners

– Guardian installed Laidlaw Drew WRASP low

- NOx burners in 2000 with an estimated

N Ox reduction of 25%. These burners have a central conical gas jet and a water

- cooled burner tip jack that limits excess air around the burner tips.

2. Supplemental Oxy

- Firing

– One set of burners (two burners at 8.0 MMBTU/hr each) was installed near the

char ging end of the melting furnace.

3. Electric Boost

– A 3

- KW capacity electric boost system was installed in 1999. The power level is varieddepending on the type of glass being manufactured and the required temperature.

4. Minimizing Secondary Air

– Positive p ressure is maintained within the furnace to prevent the entrance of secondary air. The burner tips fit in a water

- cooled jacket allowing for a tight seal, further reducing the introduction of secondary air. In addition, Guardian employs a full

- time furnace maintenance person who performs daily inspections and the needed maintenance on the furnace.

5. Minimizing Operating Temperature

– Although it is understood that high temperatures are required to produce high

- quality flat glass, it is Guardian’s policy to m aintain as low of a furnace temperature as possible while still producing a high

- quality product.

6. Minimizing nitrates in batches

– When soda niter (NaNO 3 ) is added to the batches, it results in increased NO 2 emissions. However, soda niter is only used in the production of the darkest color of glass, which is produced approximately 50% of the time; the remainder of the time the soda niter is only found in trace amounts in the

raw materials.

7. Maximizing cullet in batches

– This range depends on the amount of scrap and defective glass that is generated. Although less defective glass is being produced since the glass is being produced more efficiently and a larger percentage is being sold as finished product, the facility currently operates at the highest possib le

cullet

- recycling rate, which typically ranges from 10 to 35% of each batch.

Table 3: Summary of Baseline Levels of NO

x Control

NO

x Emission Unit Baseline Level of NO

x Control

S001: Melting Furnace Oxy

- firing

Low

- NOx burners

Minimize excess air

Elec tric boost

Maximize cullet in batches

Minimize nitrates in batches Minimize furnace temperatures Adherence to Manufacturer’s Specifications

Table 4 summarizes the potential NOx reductions from the technologically feasible control options for Guardian’s

f urnace:

Table 4: Summary of Technologically Feasible NO

x Controls

NO

x Emission Unit NO

x Control Technology Beyond Baseline NO

x Reduction Beyond Baseline

S001: Melting Furnace None 0

Summary of Cost Effectiveness:

No cost analyses were performed for the facility since all technically feasible control options and techniques are currently employed on the melting furnace.RACT for miscellaneous emission sources

The Tin Bath and Annealing Lehr Oven portions of the process are powered exclusively by electricity and have no combustion by

- products; therefore, no NOx emissions are present.

RECOMMENDATION:

The analysis for NO X RACT for the 8

- hour ozone SIP using EPA’s Cost Control Manual, the ACT document for glass melting furnaces and the preamble t o the amendments to 40 CFR 51 for the 8

- hour ozone SIP has demonstrated that any additional technically or economically feasible NO X controls for the glass

- melting furnace have already been installed and/or are being employed at the facility. Therefore, it is recommended that the NOx RACT for the 8

- hour ozone SIP for Guardian’s Floreffe Plant shall be the continued use of the existing baseline controls and techniques as specified in

Table 3 above.

### ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

January 24 , 2007

SUBJECT: Review of 8

- hour Ozone VOC RACT Submittal Koppers Inc.

– Clairton Tar Plant

300 North State Street

Clairton , Pennsylvania 15 025

TO: Sandra L. Etzel Chief Engineer

FROM: JoAnn Truchan Air Quality Engineer

INTRODUCTION :

Koppers Inc. (Title V Operating Permit No. 00 29 ) is a major source of VOC emissions as defined in §2101.02 "Definitions", of Article XXI, ACHD, Rules and Regulations, Air Pollution Control and was subject to the County’s 1

- hour ozone SIP. This required the source to evaluate VOC RACT for the facility and take the appropriate measures to implement this RACT. In addition, these RACT requirements were made a part of Allegheny County’s portion of the Pennsylv ania SIP by way of a site

- specific SIP revision. The VOC RACT for the facility consisted of the processing of all VOC emissions from the Tar Refining system through a natural gas

- blanketing system, then maintaining a

destruction efficie ncy of at least 95% for all VOC s collected by that system

. The RACT also included all appropriate recordkeeping and reporting to demonstrate compliance with the blanketing system and destruction efficiency. Although not part of the original RACT, equipment in benzene servi ce and the Creosote Blending Process are required to have a leak detection and repair system (LDAR) in place, per 40 CFR, Part 61

- Subpart L, and Part 63

- Subpart MMM. Also per Subpart MMM, VOC emissions from the Creosote Blending Process are vented to a th ermal oxidizer.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006; all 1

- hour ozone SIP RACT findings of

“no control s are required” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings

of the reevaluation of VOC RACT for the facility.

SOURCE DESCRIPTION :

Koppers Inc., Clairton Tar Plant, located at 300 North State Street, Clairt on, is a tar refining facility that distills primary crude tars into specification pitch and other coal tar distillates. The plant consists of a tar

- refining process (consisting of a series of process heaters and separation columns), a process for solidify ing liquid pitch, a debenzolized tar centrifuge, a creosote blending process, storage and blending tanks, and rail loading operations. The facility is a major source of volatile organic compounds (VOCs) , and a minor source of nitrogen oxides (NO X )

, as defi ned in §2101.20 of Article

XXI.

The facility consists of the following VOC emission sources:Source Description Control Device(s) Maximum Capacity Fuel / Raw Material Maximum

Potential

Emissions

Tar Refining Gas

- blanketed Tanks; LDAR program for

fu gitives 65.7 Mgal/year Crude Coal Tar, OLA

Tar 2.55

Debenzolized Tar Centrifuge n/a 31.5 Mgal/year Debenzolized Tar 1.96

Creosote Processing John Zink Thermal

Oxidizer 23.3 Mgal/year Coal Tar Distillates,

Correction Oil 0.48

Loading Operations n/a n/a C rude Tar, Crude Naphthalene, RCO, CBO,

Liquid & Solid Pitch,
Creosote, OLA Tar, NSR,

Correction Oil 47.84

Railcar Depressurization n/a 104 cars/year Pitch 5.86

Primary Heater, 2F

- 1A n/a 10.23 MMBtu/hr Natural Gas; Gas

Blanketing Gas 0.29

TI Heater, 2F

- 2 A n/a 8.15 MMBtu/hr Natural Gas; Gas

Blanketing Gas 0.23

Hot Oil Heater, 1F

- 2C n/a 2.89 MMBtu/hr Natural Gas; Gas

Blanketing Gas 0.08

Prill Oil Heater n/a 2.50 MMBtu/hr Natural Gas; Gas

Blanketing Gas 0.07

Secondary Heater, 2F

- 1C n/a 5.68 MMBtu/hr Natur al Gas; Gas

Blanketing Gas 0.16

Spare Hot Oil Heater,

1F

- 1C n/a 5.68 MMBtu/hr Natural Gas; Gas

Blanketing Gas 0.16

2T3 Reboiler n/a 3.98 MMBtu/hr Natural Gas 0.11

2T4 Reboiler n/a 2.89 MMBtu/hr Natural Gas 0.08

2T1 Heater n/a 2.28 MMBtu/hr Natural Gas 0.07

#1 Primary Flash n/a 10.23 MMBtu/hr Natural Gas 0.29

Naphthalene Hot Oil

Heater n/a 40.0 MMBtu/hr Natural Gas 1.13

Naphthalene Reactor

Heater n/a 6.76 MMBtu/hr Natural Gas 0.19

Storage Tanks Fixed roof; gas

blanketing on tar

refining process tank s various various 68.71*

* Total for all tanks. All tanks contain materials with a vapor pressure <1.5 psia.

VOC RACT ANALYSIS:

Equipment Fugitives (not currently regulated under a federal LDAR program)

LDAR (using the same program established under 40 CFR Part 61, Subpart L) is a technically feasible option for regulating fugitive VOC emissions from equipment not currently regulated by a federal LDAR program. At an estimated cost of $1,031 per ton of VOC removed, implementing an LDAR program is also economically feasible.Product Loading , Centrifuge Operation, Railcar Depressurization

In addition to LDAR, for product loading, operation of the centrifuge, and railcar depressurization for petroleum pitch products, the following control technologies were examined:

Thermal Oxidation Condensation Catalytic Oxidation Scrubbing Flaring Submerged Fill Carbon Adsorption

Thermal Oxidation Piping emissions from all three processes to the existing thermal oxidizer is technically feasible . However, ductw ork used for pitch loading operations would require additional heating to keep gases from condensing, causing the lines to plug. The estimated cost per ton of VOC removed is over $8,000, so thermal oxidation is not economically feasible.

Catalytic Oxidat ion

Off

- gas from pitch loading and from railcar depressurization is high in particulate matter; therefore, catalytic oxidation is not technically feasible for those operations. It is technically feasible for coal tar distillate loading and for centrif uge operation. The estimated cost per ton of VOC removed is approximately $15,000, so catalytic oxidation is not economically feasible.

Flaring The emission streams from all three processes have heat contents below that which would make flaring technically

f easible.

Carbon Adsorption

Off

- gases from pitch loading and from railcar depressurization must be maintained at temperatures above 200 °F to keep lines from plugging. Furthermore, the high molecular weights of the compounds in the off

- gas do not desorb e asily during carbon regeneration. Carbon adsorption is not technically feasible for pitch loading and railcar depressurization.

Off

- gases from distillate loading and from centrifuge operation would require cooling prior to adsorption, but carbon adsorpti on is technically feasible for these operations. The estimated cost per ton of VOC removed is $46,000, so carbon adsorption is not economically feasible.

Condensation Due to the number and types of organic compounds in the off

- gases of all three processe s, there is a very large temperature range for condensation. Furthermore, when these compounds condense, they form a thick sludge rather than a liquid, leading to plugging and removal problems. Condensation is not technically feasible for loading,

centri fuge, or railcar depressurization operations.

Scrubbing

The compounds in the off

- gases from all three processes are not readily soluble in water. Using another scrubbing solution, such as coal tar distillates, would result in more emissions than were bei ng removed. Scrubbing is not technically feasible for loading, centrifuge, or railcar depressurization operations.

Submerged Fill (product loading only) It is technically feasible to reduce emissions during loading operations by extending the fill pipe to a level below the fill line, thereby reducing splashing and turbulence. The estimated cost per ton of VOC removed is approximately $1,900. Submerged fill for product loading is economically feasible.Ranking of Technically Feasible Control Optio ns:

Control Technology Uncontrolled

Emissions (tpy) VOCs

Removed (tpy) Potential

Controlled

Emissions (tpy) Overall Efficiency 1 Cost / ton of

VOC

Removed

LDAR 36.63 18.26 18.37 50% $1,031

Submerged Fill 43.13 25.02 18.11 58% $1,873

Thermal Oxidation 51 .80 48.23 3.57 93.1% $8,885

Catalytic Oxidation 8.99 8.37 0.62 93.1% $14,993

Carbon Adsorption 8.99 8.11 0.88 90.3% $46,304

1. Overall efficiency is the product of the estimated capture efficiency and the destruction/reduction efficiency

Existing cont rols:

**•** All equipment in benzene service is required to have natural gas blanketing. A VOC destruction efficiency

of at least 95% must be maintained.

**•** Emissions from the Creosote Process are vented to a thermal oxidizer where a VOC destruction efficiency

mu st be maintained.

**•** A leak detection and repair (LDAR) system must be in place for all equipment subject to 40 CFR Part 61, Subpart L or 40 CFR Part 63, Subpart MMM.

**•** All records needed to demonstrate compliance with the above controls must be maintained and kept for a minimum of two (2) years.

RECOMMENDATION:

The analysis for VOC RACT for the 8

- hour ozone SIP has demonstrated that all VOC controls for processes at Koppers

Inc. are technically or economically infeasible using EPA’s Cost Control Manual and the preamble to the amendments

to 40 CFR 51 for the 8

- hour ozone SIP. It is recommended that , in addition to the 1

- hour ozone RACT in RACT Plan Approval Order & Agreement No.2 23 , dated August 27 , 1996 , Koppers extend the LDAR program to equipment not

cur rently subject to LDAR, and for product loading to be done using a submerged fill pipe

.Appendix A Cost Analysis to Implement LDAR Program

Assumes all heavy liquid service and operation 8,760 hrs/year Potential Emissions (before LDAR in place)

Descrip tion Number of Equipment Type V OC Emission Factors 1

(lb/hr/source)

P V PRV OEL FL P V PRV OEL FL

Crude Tar 3 73 4 10 240 0.00463 0.00051 0.09846 0.00330 0.00018

Debenz. Tar 12 363 16 75 715 0.00463 0.00051 0.09846 0.00330 0.00018

CBO 0 90 4 10 348 0.0 0463 0.00051 0.09846 0.00330 0.00018

RCO 2 158 3 30 311 0.00463 0.00051 0.09846 0.00330 0.00018

Pitch 24 455 30 80 843 0.00463 0.00051 0.09846 0.00330 0.00018

NSR 1 50 8 5 187 0.00463 0.00051 0.09846 0.00330 0.00018

Total 42 1,189 65 210 2,644

De scription V OC Potential Emissions (ton/year)

P V PRV OEL FL Total

Crude Tar 0.061 0.162 1.725 0.145 0.188 2.281

Debenz. Tar 0.243 0.805 6.900 1.085 0.559 9.592

CBO 0.000 0.200 1.725 0.145 0.272 2.342

RCO 0.041 0.351 1.294 0.434 0.243 2.363

Pitch 0.4 86 1.010 12.937 1.158 0.659 16.250

NSR 0.020 0.111 3.450 0.072 0.146 3.799

Total 0.851 2.639 28.031 3.039 2.067 36.627

Potential Emissions (after LDAR in place)

Description Number of Equipment Type V OC Emission Factors 2

(lb/hr/source)

P V PRV OEL FL P V PRV OEL FL

Crude Tar 3 73 4 10 240 0.00396 0.00115 0.00396 0.00024 0.00089

Debenz. Tar 12 363 16 75 715 0.00396 0.00115 0.00396 0.00024 0.00089

CBO 0 90 4 10 348 0.00396 0.00115 0.00396 0.00024 0.00089

RCO 2 158 3 30 311 0.00396 0.00115 0.00396 0.0 0024 0.00089

Pitch 24 455 30 80 843 0.00396 0.00115 0.00396 0.00024 0.00089

NSR 1 50 8 5 187 0.00396 0.00115 0.00396 0.00024 0.00089

Total 42 1,189 65 210 2,644

Description V OC Potential Emissions (ton/year)

P V PRV OEL FL Total

Crude Tar 0.05 2 0.368 0.069 0.010 0.936 1.435

Debenz. Tar 0.208 1.830 0.277 0.078 2.787 5.180

CBO 0.000 0.454 0.069 0.010 1.357 1.890

RCO 0.035 0.796 0.052 0.031 1.212 2.126

Pitch 0.416 2.293 0.520 0.083 3.286 6.598

NSR 0.017 0.252 0.139 0.005 0.729 1.142

Total 0. 728 5.993 1.126 0.217 10.307 18.371

Percent reduction: 50% 1. Factors from EPA’s “Protocol for Equipment Leak Emissions Estimates”, Nov. 1995. SOCMI screening range emission factors, screening value of 250 ppm.

2. Factors from EPA’s “Protocol for Equipment Leak Emiss ions Estimates”, Nov. 1995. EPA Correlation approach.Appendix A Cost Analysis to Implement LDAR Program (continued)

Initial Cost

Cost to implement initial plant

- wide LDAR (tagging, monitoring, database) = $21,000 Assumed

Annual Cost

Annual interest rate (fraction): 0.080 Assumed

Annualization frequency (years): 10 Assumed

Capital recovery factor: 0.1490

Taxes, insurance, admin. Factor: 0.10 Assumed

Operating factor (hr/yr): 8,760

Maintenance labor rate ($/hr): 25.00 Assumed

Ma intenance labor: 120.0 Assuming 10 hrs/month

Maintenance labor: $3,000

Supervisory labor: $600 20% of maintenance labor

Annualization of initial investment: $3,130

Taxes, insurance, admin. = $2,100

Estimated annual cost for implementation of an LD AR program: $10,000 Assumed

Total annual cost: $18,830

$/ton reduced

Potential emissions (equipment not under Subpart L) = 36.63 tons/yr (see table above)

Expected reduction = 50%

Final emissions = 18.37 tons/yr (see table above)

Emission red uction = 18.26 tons/yr

Cost ($/ton reduced) = $1,031Appendix B Cost Analysis to Implement Submerged Fill on Product Loading

Temp. Molec. Weight Vapor

Pressure Through

put VOC Emission

Factor 1 VOC Potential

Emissions Reduction
Splash

lb/M gal Submerg. lb/Mgal Splash ton/yr Submerg. ton/yr Commodity °R lb/lbmol psia Mgal/yr %

CCOT 610 90.85 0.1131 10,000 0.304 0.126 1.520 0.630 58.55

RCO (maximum) 2.714 1.123 58.61

RCO regular 620 120.11 0.0994 15,600 0.348 0.1 44 2.714 1.123

RCO co

- distill 620 121.16 0.0837 15,600 0.296 0.122 2.309 0.952

CBO (maximum) 0.189 0.081 57.14

CBO regular 610 109.64 0.0066 18,000 0.021 0.009 0.189 0.081

CBO co

- distill 610 137.00 0.0044 18,000 0.018 0.007 0.162 0.063

Creosote (maximum) 2.607 1.078 58.64

P1/P13 Creosote 610 99.91 0.0647 27,300 0.191 0.079 2.607 1.078

P2 Creosote 610 131.58 0.0110 27,300 0.043 0.018 0.587 0.246

Corrected Creosote 610 118.81 0.0171 27,300 0.060 0.025 0.819 0.341

Pitch (maximum) 36.100 14.951 58.59

Coal Tar Pitch 900 201.14 0.0700 42,900 0.283 0.117 6.070 2.510

Type A Pitch 900 429.47 0.1953 42,900 1.683 0.697 36.100 14.951

Total 43. 130 17.863 58.31

1. Based on the methodology outlined in AP

- 42, Section 5.2, Transportation and Marketing of Petroleum Liquids , January 1995. A saturation factor of 1.45 was used for splash loading, and a factor of 0.60 was used for submerged fill loadin g.Appendix B Cost Analysis to Implement Submerged Fill on Product Loading (continued)

Capital Costs

Capital cost to utilize submerged fill = $10,000 Per station, K. Probst, 07/31/06

Number of loading stations = 7 2 pitch and 5 distillate

Total ca pital cost = $70,000

Annual Cost

Annual interest rate (fraction): 0.080 Assumed

Control system life (years): 10 Assumed

Operating factor (hr/yr): 8,760

Operating labor rate ($/hr): 25.00 Assumed

Maintenance labor rate ($/hr): 25.00 Assumed

O perating labor factor (hr/shift): 0.5 Assumed

Maintenance labor factor (hr/shift): 0.5 Assumed

Operating labor: $13,688

Maintenance labor: $13,688

Supervisory labor: $2,053 15% of operating labor

Annualization of initial investment: $10,432

Taxes, insurance, admin. = $7,000

Total annual cost: $46,860

$/ton removed

Potential emissions = 43.130 tons/yr (see table above)

Expected reduction = 58.31%

Final emissions = 17.863 tons/yr (see table above)

Emission reduction = 25.267 tons/yr

C ost ($/ton reduced) = $1,873

### ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

November 14, 2006

SUBJECT: Review of 1

- hour VOC RACT Submittal Laurel Mountain Whirlpools, Inc.

1210 Airbrake Ave.

PO Box 190 Turtle Creek, PA 15145

TO: Sandra L. Etzel Chief Engineer

FROM: Hele n O. Gurvich Air Quality Engineer

INTRODUCTION :

Laurel Mountain Whirlpools, Inc. (title V Operating Permit No.0014) is a major source of VOC emissions as defined in section 2101.02 "Definitions", of Article XXI, ACHD, Rules and Regulations, Air Pollutio n Control. The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006; all major sources of VOC or NOX not subject to the

pre vious 1

- hour ozone SIP must be evaluated for RACT for these pollutants.

Upon evaluation and determination of RACT the RACT requirements will be made a part of Allegheny County’s portion of the Pennsylvania SIP by way of a site

- specific SIP revision. This document presents the findings of the evaluation of VOC RACT for the facility.

SOURCE DESCRIPTION :

The Laurel Mountain Whirlpool, Inc. is a manufacturer of acrylic and gel coat whirlpool bathtubs. The product line consists of various shapes and designs o f whirlpool bathtubs and showers. The area of the facility where most of the VOC emissions are generated captures the VOC emissions in a hood that is designed to maintain employee exposure to safe levels. All of the air exhausted by the facility is ducted to a single stack. The facility is a major source of volatile organic compounds (VOC), styrene and hazardous air pollutants as defined in section 2101.20 of Article XXI.Laurel Mountain RACT Technical Support Document Page 2

The facility consists of the following VOC emission sources:

I.D. Sou rce Description Maximum Capacity Controls Fuel/Raw Material Maximum

Potential Emissions,

tons/yr

P001 Vacuum form machine with 12 infrared heaters, 6 space heaters, 2 make up heaters 6.45 MM Btu/Hr

total None Natural Gas 0.16

P003 Laminating/Bonding coa t mixing and application 1,678 tons of resin None Laminating/bonding resins, filler, catalyst, fiberglass 46.42

P007 Gel coat application 315 tons of resin None Gel coat resin, wax, catalyst 34.26

P005 Underside painting 5,050 gallons None Various paint s 1.11

P006 Whirlpool assembly and protective coating 507 gallons

- glue, 1,006 gallons

coating None PVC glue, coatings, various assembly (parts) 8.02

D001 Fixed roof storage tank 5,000 gallons None Resin 0.02

Total 89.99

VOC RACT ANALYSIS:

The Laure l Mountain’s RACT analysis, submitted in correspondence from Laurel Mountain to the Department, dated July 2006 was conducted with guidance from U. S. EPA's OAQPS Control Cost Manual. All technologies were evaluated using EPA’s cost spreadsheets.

During t he preparation of this report, Laurel Mountain has:

1. Reviewed all technologies referenced in a literature search regarding emissions controls at facilities similar to Laurel Mountain’s (most notably a 1996 USEPA report entitled “Assessment of Styrene Emissi on Controls for FRP/C and Boat Building Industries”);

2. Performed an economic evaluation of each of the nine control technologies identified in the 1996 USEPA reference document entitled “Assessment of Styrene Emission Controls for FRP/C and Boat Building

In dustries”;

3. Solicited, received and evaluated two facility

- specific quotes from control technology vendors; and

4. Conducted a search of the USEPA’s RACT, BACT, and LAER (RBLC) Clearing House with respect to controls employed by similar facilities.

According to the above referenced 1996 USEPA report’s abstract: “Styrene emissions from open molding processes in fiberglass

- reinforced plastics/composites (FRP/C) and fiberglass boat building facilities are typically, diluted general ventilation, to ensure that wor ker exposures do not exceed OSHA standards. This practice tends to increase the potential cost to the facility of add

- on controls. Furthermore, add

- on styrene emission controls are currently not generally mandated by regulations. Therefore, emission contro ls are infrequently used in these industries at present.”

“Low concentrations and high air flow rates also have made conventional emission controls very expensive and, in some cases, less efficient in destroying the emissions.”

The economic analysis of t his reports supports the assertion. According to the report: “To provide technical and cost information to companies that might choose emission controls to reduce styrene emissions, several conventional and novel emission control technologies that have bee n used to treat styrene emissionsLaurel Mountain RACT Technical Support Document Page 3

in the United States and abroad and a few emerging technologies were examined. Control cost for these technologies were developed and compared for three hypothetical plant sizes.”

The 1996 USEPA report also included cost analysis procedures “...using the OAQPS CONTROL COST MANUAL,

EPA 450/3

- 90

- 006 format and approach.” The USEPA website included a series of spreadsheets for those technologies deemed to be most likely selections for implementation:

1. Environmental C&C Fluid Be d Concentrator

2. Durr Rotary Concentrator

3. Catalytic Oxidation (generic)

4. Condenser (generic)

5. MIAB

– Carbon adsorption

6. Polyad

– polymer bead adsorption

7. Thermal Oxidation (generic)

8. Thermatrix Padre (adsorption/desorption/condensation)

9. Biofiltration (generic)

E ach of these spreadsheets was completed using parameters specific to Laurel Mountain’s air stream. Additionally, two organizations were contacted, given the parameters of Laurel Mountain’s air stream and asked to provide a proposal based on any of the tech nologies they represent which would be most cost effective for Laurel Mountain. The two firms (and technologies) are:

1. Envirologic

– Regenerative Thermal Oxidizer

2. Pro

- Environmental, Inc.

– Direct Fired Thermal Oxidizer with Fluidized Bed Concentrator for S tyrene Composite Manufacturers

A third company (Carbitrol) was requested to quote and declined to do so. It was their opinion that their technology (carbon adsorption) would be prohibitively costly. They did provide information indicating (among other th ings) that 21,200 pounds of carbon would be requiring replacement every 20 days.

Summary of Control Technologies and Cost Effectiveness:

No. Technology Evaluated Cost

- Effectiveness (annualized dollars per ton)

1 Environmental C&C Fluid Bed Concentrator $4, 868

2 Durr Rotary Concentrator $5,565

3 Catalytic Oxidation (generic) $9,272

4 Condenser (generic) $859,843

5 MIAB

– Carbon adsorption $4,314 (least cost)

6 Polyad

– polymer bead adsorption $4,525

7 Thermal Oxidation (generic) $8,967

8 Thermatri x Padre (adsorption/desorption/condensation) $5,574

9 Biofiltration (generic) $5,417

10 Envirologic

– Regenerative Thermal Oxidizer $9,750

11 Pro

- Environmental, Inc.

– Direct Fired Thermal

Oxidizer with Fluidized Bed Concentrator $5,696

Annualized cos t effectiveness results ranged from a low $4,314 to $859, 843 per ton of styrene controlled. None of these technologies meet the assumed cost

- effectiveness threshold of $2,000 that would require implementation as RACT. Notwithstanding the costs presented, many of the technologies evaluated were not Reasonably Available (some have not been tested beyond the “experimental” stage).Laurel Mountain RACT Technical Support Document Page 4

Existing controls:

The 1996 USEPA report also indicates that: “Styrene emissions can be reduced by (1) using resin materials an d application equipment that generate less styrene emissions, (2) improving operator techniques to reduce overspray, (3) changing open

- molding processes to

closed

- molding processes, and (4) using add

- on emission control devices.”

Items 1 and 2 are reflect ing “changes in materials”, “changes in operation” or “alternative work practices” that have already been employed by facility. The MACT standard has stipulated those items that are reasonably available, and that compliance with MACT is indicating that the facility is doing all that it reasonably can.

Summary of Evaluation Considerations

1. Compliance with Pennsylvania’s BAT requirements, February 23, 1996

– The facility is already doing. Pennsylvania’s Best Available Technology criteria for Reinforced Fib erglass Plastic Manufacturing Facilities which states that: “The BAT criteria and guidelines will serve as a baseline for determining Best Available Control Technology BACT) ... and Lowest Achievable Emission Rate (LAER)...” and “If the stack concentration (pr ior to any dilution) exceeds 1,000 ppm, an add

- on control may be required.”

The requirements include: (1) do not exceed a modeled odor threshold; (2) minimize use of solvents; (3) use vapor suppressed resins or resins having less than 35% styrene content and (4) for normal spraying operations use airless, air

- assisted airless, or electrostatic spray equipment. Laurel Mountain is meeting the BAT requirements. It is noted that the facility’s stack concentration is approximately 36 ppm. It is also noted that BACT and LAER are both more stringent than RACT.

2. Compliance with the MACT Standard for FRP/C industry. Laurel Mountain’s costs have increased significantly (primarily through the increased cost of “compliant” resins). Since MACT standards are (theoretica lly) based on the average of the top performing 12% of facilities, compliance with MACT is indicative that it is at least meeting RACT (and possibly better than that).

3. Cost Evaluation. RACT was evaluated by comparing the results of this analysis to an “ec onomic

threshold” relative to the cost

- effectiveness of removing additional tons of VOCs. In making this evaluation, it is assumed RACT to be guided by an annual cost

- effectiveness of $2,000 per ton of VOC

“controlled”. The lowest cost

- effectiveness for an y of the eleven technologies evaluated is $4,314. On this basis, none of the technologies evaluated should be implemented at this time.

4. Review of USEPA’s RBLC database. The search of the database identified fifteen facilities matching the

search criteria. Conclusions of the RBLC report are:

**•** No known RACT determinations were recorded (a couple of “case

- by

- case” determinations were noted).

**•** Add

- on controls were only used at two facilities

– one in CA and one in OR. Both decisions were

BACT

- PSD more stringent than RACT.

**•** Only one determination mentioned cost in any way. Relative to a BACT

- PSD determination in Oregon, it was stated, “All add

- on control technologies were found to be cost prohibitive.”

**•** Relative to the only Pennsylvania facility, the requirement was to use resins with a styrene content of less than 35%. This is what is currently required of Laurel Mountain.

RECOMMENDATION:

On the basis of this analysis, which included a review of technologies, costs and applicable regulations, RACT is limited to ( or exceeded by) Laurel Mountain’s continued compliance with the MACT. In general terms, this means the incorporation of good work practices, use of low

- styrene resins and general “pollution prevention” as currently practiced by Laurel Mountain, Inc.Laurel Mountain RACT Technical Support Document Page 5

.

## APPENDIX A

Economic Evaluation

### ALLEGHENY COUNTY HEALTH DEPARTMENT
AIR QUALITY PROGRAM

November 27, 2006

SUBJECT: Review of 8

- hour Ozone VOC & NO X RACT Submittal Neville Chemical Company

2800 Neville Road Pittsburgh, PA 15225

- 1496

TO: Sandra L. Etzel Chief Engineer

FROM: Erin J. O ’Brian, P. E. Air Quality Engineer

INTRODUCTION

Neville Chemical Company (title V Operating Permit No.0060) is a major source of NO X & VOC emissions as defined in section 2101.02 "Definitions", of Article XXI, ACHD, Rules and Regulations, Air Pollution Control and was subject to the County’s 1

- hour ozone SIP. This required the source to evaluate NO X & VOC RACT for the facility and take the appropriate measures to implement this RACT. In addition these RACT requirements were made a part of Allegheny Co unty’s portion of the Pennsylvania SIP by way of a site

specific SIP revision. The NO X & VOC RACT for the facility consisted of a finding of “no VOC controls were required” due to technical and economic infeasibility.

The County is presently in non

- atta inment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006, all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings of the reevaluation of VOC RACT for the facility.

SOURCE DESCRIPTION:

Neville Chemical Company (NCC) is located at 2800 Neville Road, Pittsburgh (Neville Township), PA 15225

- 1496 in the County of A llegheny. NCC manufactures synthetic hydrocarbon resins, plasticizers, plasticizing oils, and co

- product distillate oils and fuel oils. Also located onsite is ND Dispersions, LLC (NDD), a wholly owned subsidiary of NCC. NDD produces aqueous base resin p roducts.The facility consists of the following VOC emission sources:

Process Description Capacity 1 Controls Maximum
Potential/Allowable

Emissions Units 15, 16, 18, 19 & 43 Heat Polymerization
Units Confidential Thermal
Oxidizer 4.94 ton s/yr

Unit 30 Heat Polymerization
Unit Confidential None 87.35 tons/yr

Unit 20 Continuous Polymerization Unit Confidential Refrigerated
Condenser 58.10 tons/yr

Unit 21 Continuous Polymerization Unit Confidential Packed Bed
Scrubber 29.54 tons/yr

Unit 3 Continuous Resin

Distillation Confidential None 3.97 tons/yr

Unit 4 Continuous Resin

Distillation Confidential None 12.45 tons/yr

C5 Unit C5 Resin Polymerization Unit Confidential Refrigerated
Condenser 20.79 tons/yr

PC 2 Packaging Center 2 Confidentia l None 35.14 tons/yr

PC 3 Packaging Center 3 Confidential None 44.30 tons/yr

PC 5 Packaging Center 5 Confidential None 25.74 tons/yr

WWTP Wastewater Treatment
Plant 105 MG/Yr None 37.21 tons/yr

RRPR Resin Rework Product Recovery Confidential Water

- cool ed
Condenser 16.50 tons/yr

Screen Cleaning Screen Cleaning Tank Confidential Water

- cooled
Condenser 13.6 tons/yr

NA Groundwater

Remediation 44,000 gal/yr None 11.20 tons/yr

NDD Neville

- DRD Dispersions Confidential None 0.17 tons/yr

B013 Boiler No.6 4 7.5
MMBtu/hr None 1.37 tons/yr

B014 Boiler No.7 49.5
MMBtu/hr None 1.43 tons/yr

B012 Boiler No.8 24.5
MMBtu/hr None 1.97 tons/yr

NA 104 VOC Storage

Tanks Various Vapor Recovery

– 6
Tanks 51.70 tons/yr

NA Barge Loading Operations 4 x 10 6 gallons/yr None 0.57 tons/yr

NA Equipment Fugitives NA LDAR NA

NA Groundwater Remediation System NA None < 2 tons/yr

1 See confidential technical support document for Title V permit 0060 for confidential process capacities.The facility consists of the followin g NO X emission sources:

Process Description Capacity Controls Maximum
Potential/Allowable

Emissions Units 15, 16, 18, 19, 30 & 43 Process Heaters 4.0 to 7.5
MMBtu/Hr None 20.49 tons/yr

Units 3 & 4 Still Heaters 4.4 & 10.5
MMBtu/Hr None 7.68 tons/yr

C

- 5 Process Heater 4.13 MMBtu/Hr None 2.13 tons/yr Units 2PC, 3PC &
5 PC Packaging Center

Heaters 3.0 to 5.0
MMBtu/Hr None 6.14 tons/yr

Boiler 6 Facility Boiler 47.5 MMBtu/Hr None 65.62 tons/yr

Boiler 7 Facility Boiler 49.5 MMBtu/Hr None 80.84 tons/yr

Boi ler 8 Facility Boiler 24.5 MMBtu/Hr None 7.67 tons/yr Bldg. 50 Gas

House Process Heater 3.0 MMBtu/Hr None 1.29 tons/yr

QTL Heater Process Heater 3.0 MMBtu/Hr None 1.29 tons/yr Emergency
Generators 7 IC Generators 10 to 691 HP None NA

Unit 43 Thermal Ox idizer 18.9 MMBtu/Hr NA 9.74 tons/yr

POTENTIAL EMISSIONS:

The allowable VOC and NO X emission limits for process equipment set forth above are specified in Title V Operating Permit 0060, dated November 2, 2004 and are the potential VOC and NO X emissions including all
enforceable controls and restrictions for those units.

RACT ANALYSIS:

This RACT analysis, submitted in correspondence from Neville Chemical Company to the Department, dated August 1, 2006 was conducted with guidance from U. S. EPA's OAQPS Cost Manual (reference no.1), vender quotes and actual cost data.

NO X RACT ANALYSIS:

Boilers No.6, No.7 & No.8:

All three boilers have a rated heat input between 20 MMBtu/hr and 50 MMBtu/hr and presently comply with the presumptive RACT requirements of Article XXI, §2105.06.d.2 which requires an annual

combustion tune

- up as per the referenced regulation. The presumptive RACT requirements are specified in the 1

- hour ozone SIP in Neville Chemical’s Plan Approval and Order No.230 and are

considered NO X RAC T for the 8

- hour ozone SIP.

Process Heaters & Unit 43 Thermal Oxidizer:

Process heaters for units 15, 16, 18, 19 & 30, stills 3 & 4, the C

- 5 unit, packaging centers 2, 3 & 5, Bldg. 50 and the QTL are all rated with heat inputs of between 3.0 and 10.5 MMB tu/hr. The unit 43 thermal oxidizer has a rated heat input of 18.9 MMBtu/hr. These sources presently comply with the presumptive RACT requirements of Article XXI, §2105.06.d.6.A which requires installation, maintenance and operation in accordance with man ufacturer’s specifications. The presumptive RACT requirements are specified in the 1

- hour ozone SIP in Neville Chemical’s Plan Approval and Order No.230 and areconsidered NO X RACT for the 8

- hour ozone SIP.

Emergency Generators:

The facility’s seven emer gency generators all operate less than 500 hours per 12

- month period and comply with the presumptive RACT requirements of Article XXI, §2105.06.d.6.E which requires installation, maintenance and operation in accordance with manufacturer’s specifications.

VOC RACT ANALYSIS:

The following control technologies were found to be reasonably available:

Thermal Oxidation Catalytic Oxidation Absorption
Concentrator/oxidation Flaring Carbon Adsorption Condensation

The following technologies were found to be technically infeasible:

Flaring

– The heat content of emission streams from the VOC sources at the facility are well below the 300 Btu/scf required for proper flare operation as stated in 40 CFR 60.18 of the General Requirements for New
Source Performanc e Standards.

Absorption

– Scrubbing suitability is dependent on the solubility of the specific constituents to be controlled. All of the emission streams from the facility sources are composed of numerous volatile

constituents which makes a suitable scru bbing liquid infeasible.

The remaining control technologies are considered generally available and technically feasible for control of
VOC emissions from the facility sources.

Heat Polymerization Units 15, 16, 18, 19 & 43:

These units presently vent to the unit 43 thermal oxidizer as specified in condition V.A.1.a of permit

0060

- I006. The thermal oxidizer is required to have a destruction efficiency of 9 8% and is considered BACT for the installation. No further analysis is required and the thermal oxidizer at 98% destruction efficiency for VOCs will be considered VOC RACT for the 8

- hour ozone SIP.

Equipment Fugitives:

Fugitive VOC emissions from equipm ent components including pumps, valves, pressure relief devices, sampling connection systems, open

- ended lines and valves and flanges and other connectors are presently controlled by LDAR. The existing LDAR requirements are specified in the 1

- hour ozone S IP in Neville Chemical’s Plan Approval and Order No.230 and are considered VOC RACT for the 8

- hour
ozone SIP.

Groundwater Remediation System:

The system consists of groundwater treatment wells, an equalization tank, a liquid

- phase carbon adsorption
unit and the drywell no.2 and no.8 pump and treat systems. The system previously had an air stripper which has been permanently shut down. Due to the low potential emissions of less than 2 tons of VOCs per year,
no add on controls are considered cost effectiv e and VOC RACT is the proper operation and maintenance of the system.

Neville

- DRD Dispersions:This unit produces emulsified resins/rosins in water and has potential VOC emissions less than one ton per

12

- month period. Due to the low potential emissions of less than 2 tons of VOCs per year, no add on controls are considered cost effective and VOC RACT is the proper operation and maintenance of the system.

VOC Storage & Blend Tanks:

The facility has approximately 100 tanks all of fixed roof design. T hese tanks are regulated under Article XXI, §2105.12 which is VOC RACT by regulation.

Combustion Sources:

The potential VOC emissions from all combustion sources with the exception of the facility boilers, have insignificant VOC emissions and further ana lysis is not required. Each of the facility boilers has potential VOC emissions of less than 2 tons per 12

- month period. Due to the low potential emissions no add on controls are considered cost effective and VOC RACT is the proper operation and maintena nce of the system.

Barge Loading:

Due to the low potential emissions of less than 1 ton of VOCs per year, no add on controls are considered cost effective and VOC RACT is the proper operation and maintenance of the system.

Heat Polymerization Unit 30:

Presently this unit is deactivated with no intention of reactivation in the near future. In the event of
reactivation a RACT evaluation will be conducted for the unit.

C

- 5 Unit:

Presently this unit is deactivated with no intention of reactivation in t he near future. In the event of
reactivation a RACT evaluation will be conducted for the unit.

Wastewater Treatment Plant:

The treatment plant is composed of a biological treatment system and a group of open topped and fixed roof tanks. The VOC potenti al emissions from the biological treatment system (tanks TA

- 2 & TA

- 3) are approximately 12 tons/yr. At these potential emissions any add

- on controls would be cost prohibitive and RACT for the biological system will remain proper operation and maintenance of the system. The remaining emission sources are open and fixed tanks with intermittent emissions and extremely low VOC concentrations which makes any controls technically or economically infeasible. RACT for these sources will again be proper operation and maintenance.

Continuous Polymerization Unit 20:

The cost effectiveness of technically feasible add

- on controls at a VOC PTE of 29.54 tons/yr are as follows;

Control Technology Control Efficiency Capture Efficiency Reduction Efficiency Annualized Co st $ $/Ton VOC

Removed
Concentrator/oxidation 98% 95% 93.1% 254,645 4,707 Catalytic Oxidation 98% 95% 93.1% 256,936 4,750
Thermal Oxidation 98% 95% 93.1% 319,867 5,913
Carbon Adsorber 98% 95% 93.1% 343,966 6,359 Refrigerated condenser 90% 95% 85.5% 43 6,636 8,790See appendix A of this document for detailed cost analyses. The above cost effectiveness of add

- on controls were calculated even though controls are considered technically infeasible due to low volume, intermittent flow, a low VOC concentrat ion and multiple VOC constituents in the exhaust stream.

Continuous Polymerization Unit 21:

The cost effectiveness of technically feasible add

- on controls at a VOC PTE of 29.54 tons/yr are as follows;

Control Technology Control Efficiency Capture

Effic iency Reduction Efficiency Annualized Cost $ $/Ton VOC

Removed Catalytic Oxidation 98% 95% 93.1% 255,850 9,303
Concentrator/oxidation 98% 95% 93.1% 259,996 9,454
Thermal Oxidation 98% 95% 93.1% 381,718 13,880
Carbon Adsorber 98% 95% 93.1% 342,631 12,45 8 Refrigerated condenser 90% 95% 85.5% 423,131 16,753

No add

- on controls are considered cost effective and VOC RACT will be the proper operation and maintenance of the subject unit. See appendix A of this document for detailed cost analyses.

No.3 & No. 4 Stills:

The emissions from both units are combined for the cost analysis.

The cost effectiveness of technically feasible add

- on controls at a VOC PTE of 16.42 tons/yr are as follows;

Control Technology Control Efficiency Capture Efficiency Reduction Efficiency Annualized Cost $ $/Ton VOC

Removed Catalytic Oxidation 98% 95% 93.1% 213,643 13,975
Concentrator/oxidation 98% 95% 93.1% 259,996 17,008
Thermal Oxidation 98% 95% 93.1% 276,097 18,061 Refrigerated condenser 90% 95% 85.5% 270,864 19,294
Carb on Adsorber 98% 95% 93.1% 349,998 22,895

No add

- on controls are considered cost effective and VOC RACT will be the proper operation and maintenance of the subject units. See appendix A of this document for detailed cost analyses.

Packaging Center No.2:

The cost effectiveness of technically feasible add

- on controls at a VOC PTE of 35.14 tons/yr are as follows;

Control Technology Control Efficiency Capture Efficiency Reduction Efficiency Annualized Cost $ $/Ton VOC

Removed
Carbon Adsorber 98% 95% 93.1% 327,310 10,005
Concentrator/oxidation 98% 95% 93.1% 423,508 12,945 Catalytic Oxidation 98% 95% 93.1% 568,366 17,373
Thermal Oxidation 98% 95% 93.1% 853,067 26,075 Refrigerated condenser 90% 95% 85.5% 1,026,689 34,172

No add

- on controls are consider ed cost effective and VOC RACT will be the proper operation and maintenance of the subject unit. See appendix A of this document for detailed cost analyses.Packaging Center No.3:

The cost effectiveness of technically feasible add

- on controls at a VOC PT E of 44.30 tons/yr are as follows;

Control Technology Control Efficiency Capture Efficiency Reduction Efficiency Annualized Cost $ $/Ton VOC

Removed
Carbon Adsorber 98% 95% 93.1% 558,216 13,535
Concentrator/oxidation 98% 95% 93.1% 603,012 14,621 Cataly tic Oxidation 98% 95% 93.1% 853,378 20,691
Thermal Oxidation 98% 95% 93.1% 1,346,274 32,642 Refrigerated condenser 90% 95% 85.5% 2,163,003 57,107

No add

- on controls are considered cost effective and VOC RACT will be the proper operation and

maintenanc e of the subject units. See appendix A of this document for detailed cost analyses.

Packaging Center No.5:

The cost effectiveness of technically feasible add

- on controls at a VOC PTE of 25.74 tons/yr are as follows;

Control Technology Control Efficiency Capture Efficiency Reduction Efficiency Annualized Cost $ $/Ton VOC

Removed
Carbon Adsorber 98% 95% 93.1% 541,924 22,614
Concentrator/oxidation 98% 95% 93.1% 603,012 25,163 Catalytic Oxidation 98% 95% 93.1% 853,378 35,611
Thermal Oxidation 98% 95% 93. 1% 1,346,274 56,179 Refrigerated condenser 90% 95% 85.5% 2,282,351 103,707

No add

- on controls are considered cost effective and VOC RACT will be the proper operation and maintenance of the subject unit. See appendix A of this document for detailed cost analyses.

Resin Rework Operation:

The cost effectiveness of technically feasible add

- on controls at a VOC PTE of 16.50 tons/yr are as follows;

Control Technology Control Efficiency Capture Efficiency Reduction Efficiency Annualized Cost $ $/Ton VOC

Remo ved
Thermal Oxidation 98% 95% 93.1% 218,123 14,200 Catalytic Oxidation 98% 95% 93.1% 224,529 14,616
Concentrator/oxidation 98% 95% 93.1% 236,756 15,412
Carbon Adsorber 98% 95% 93.1% 350,441 22,813 Refrigerated condenser 90% 95% 85.5% 342,861 24,303

No add

- on controls are considered cost effective and VOC RACT will be the proper operation and maintenance of the subject unit. See appendix A of this document for detailed cost analyses.

Screen Cleaning:

The cost effectiveness of technically feasible a dd

- on controls at a VOC PTE of 13.6 tons/yr are as follows;Control Technology Control Efficiency Capture Efficiency Reduction Efficiency Annualized Cost $ $/Ton VOC

Removed Catalytic Oxidation 98% 95% 93.1% 188,750 14,907
Thermal Oxidation 98% 95% 93. 1% 218,123 17,227
Concentrator/oxidation 98% 95% 93.1% 236,756 18,699
Carbon Adsorber 98% 95% 93.1% 347,965 27,482 Refrigerated condenser 90% 95% 85.5% 342,861 29,486

No add

- on controls are considered cost effective and VOC RACT will be the proper ope ration and maintenance of the subject unit. See appendix A of this document for detailed cost analyses.

Existing controls:

The existing 1

- hour ozone SIP VOC RACT as specified in RACT Order and Agreement No. 230 shall be
considered VOC RACT for the 8

- hour ozone SIP. See Order No.230 for specific RACT control technology and operating requirements.

RECOMMENDATIONS:

The analysis for VOC RACT for the 8

- hour ozone SIP has demonstrated that any additional VOC controls for the facility are technically or econo mically infeasible using EPA’s Cost Control Manual and the preamble to
the amendments to 40 CFR 51 for the 8

- hour ozone SIP. It is recommended that the 1

- hour ozone RACT in RACT Plan Approval Order & Agreement No.230, dated December 13, 1996 still be cons idered VOC RACT (8

- hour ozone) for the facility.APPENDIX A

Economic Evaluation

### ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM

August 22, 2006

SUBJECT: Review of 8

- hour Ozone NO X RACT Submittal NRG Energy Center Pittsburgh, LLC

111 South Commons Avenue Pittsburgh, PA 15212 Allegheny County

Operating Permit No.0022

TO: Sa ndra L. Etzel Chief Engineer

FROM: Erin J. O’Brian, P. E. Air Quality Engineer

SOURCE DESCRIPTION:

The NRG Energy Center Pittsburgh, LLC (formerly Pittsburgh Thermal, L.P.) facility is a commercial direct heating and cooling plant located at 111 South Commons Avenue in the North Side section of Pittsburgh, PA. The plant supplies steam for space heating and sterilization processes at one hospital as well as chilled water for refrigeration and summer air conditioning to commercial and institutional sites in that area. The plant is composed of four boilers that fire natural gas as their primary fuel and have the capacity to fire no. 2 fuel oil. Additional equipment used for chilled water production includes various turbines, chillers and compressors, an 8

- c ell 30,000 gpm cooling tower and a 2

- cell 7,200 gpm cooling tower. The facility is a major source of nitrogen oxides (NO X ) and minor source of volatile organic compounds (VOCs) as defined in section 2101.20 of Article XXI.

NO X EMISSION UNITS:

Boiler No.1 : Boiler No.2:

Type: B & W, Type "D" Type: B &W, Type "D" Rating: 70,000 #/hr @ 275 psi Rating: 70,000 #/hr @ 275 psi Heating Surface: 5,190 sf Heating Surface: 5,190 sf Maximum Input Rating: 92 MMBtu/hr Maximum Input Rating: 92 MMBtu/hr

Installation date: 1965 Installation date: 1965

Boiler No.3: Boiler No.4:

Type: B &W, Type "D" Type: UNILUX Hot Water Boiler Rating: 100,000 #/hr @ 275 Maximum Input Rating: 24 MMBtu/hr Heating Surface: 5,925 sf Installation d ate: 2000 Maximum Input Rating: 131.1 MMBtu/hr

Installation date: 1965Generator No.1: Generator No.2:

Type: International Type: Cummins

Fuel: Natural Gas Fuel: Natural Gas Rating: 75 Kw Rating: 250 Kw Btu Rating: 0.7 MMBtu/hr Btu Rati ng: 2.9 MMBtu/hr Restrictions: Emergency use only Restrictions: Emergency use only Maximum 500 hrs/yr Maximum 500 hrs/yr

Generator No.3:

Type: Caterpillar

Fuel: Diesel Rating: 250 Kw Btu Rating: 2.7 MMBtu/hr Restrictions: Emergency use on ly Maximum 500 hrs/yr

8

- Hour Ozone RACT Components:

1. 1

- hour ozone RACT Order No.220 dated March 4, 1996

2. Amendment No.1 to Order No.220 dated June 9, 2005

1

- Hour Ozone RACT:

RACT Plan Approval Order & Agreement No.220, dated March 4, 1996 established RACT for NO X emissions from boilers no.1, no.2 and no.3. Boiler no.4 was not included due to installation in 2000 and the emergency generators were not addressed. The 1

- hour RACT for boilers no.1 through no.3 is as follows:

Order 1.1: NO X Emission limi ts

Boiler NO X lbs/MMBtu NO X tons/yr

1 0.145 54.2

2 0.145 54.2

3 0.145 77.3

Order 1.2: Boilers no.1 through no.3 and O2 trim equipment shall be properly operated and maintained according to good engineering practice at all times.

Order 1.3: N atural gas use only in boilers no.1 through no.3 except for fuel oil use during times of emergency or natural gas curtailment.

Order 1.4: NO X emission tests every two years on boiler no.3.

Order 1.5: Records and calculations shall be kept in order to d etermine compliance with the conditions of the RACT Order, to include, but not be limited to the following daily records:1. Total fuel consumed and type of fuel per boiler.

2. Amount of fuel usage per boiler.

3. Steam load per boiler.

4. Total operating hours per bo iler.

5. All records of boiler maintenance, calibration, inspection and replacement of combustion equipment.

Amendment No.1 to Order No.220

Amendment No.1 for RACT Plan Approval Order & Agreement No.220, dated June 9, 2005 allowed for the

unrestricted use o f no.2 fuel oil in boilers no.1 through no.3.

POTENTIAL EMISSIONS:

The RACT emission limits for boilers no.1 through no.3 set forth in Order No.220 are the potential NO X emissions including all enforceable controls and restrictions for those units regard less of combustion of fuel oil or natural gas. Potential emissions for boiler no.4 are set forth in installation permit

NO X EMISSION

UNIT N.G. NO. 2 FUEL OIL

BASIS LBS/MM

BTU TPY LBS/MM

BTU TPY

No.1 0.145 54.2 0.145 54.2 RACT Order

No.220

N o.2 0.145 54.2 0.145 54.2 RACT Order

No.220

No.3 0.145 77.3 0.145 77.3 RACT Order

No.220

No.4 0.038 4.00 0.100 0.60 IP No. 0022

- I001

Generator No.1 3.17 0.55 NA NA AP

- 42, 3.2, 7

- 2000

Generator No.2 3.17 2.30 NA NA AP

- 42, 3.2, 7

- 2000

Generator No.3 NA NA 4.41 2.98 AP

- 42, 3.3, 10

- 1996

REGULATORY ANALYSIS:

NRG Energy Center Pittsburgh is a major source of NO X emissions as defined in section 2101.02 "Definitions", of Article XXI, ACHD, Rules and Regulations, Air Pollution Control and was subje ct to the County’s 1

- hour ozone SIP. This required the source to evaluate NO X RACT for the facility and take the appropriate measures to implement this RACT. In addition these RACT requirements were made a part of Allegheny County’s portion of the Pennsy lvania SIP by way of a site

- specific SIP revision. The

NO X RACT for the facility consisted of a finding of “no NO X controls were required” due to technicaland economic infeasibility.

The County is presently in non

- attainment for the 8

- hour ozone standar d and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006, all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings

of the reevalua tion of NO X RACT for the facility.

NO X RACT ANALYSIS:

Boilers No.1, No.2 & No.3:

The RACT analysis was conducted with guidance from U. S. EPA's OAQPS Cost Manual and actual cost data, provided by NRG, derived from retro

- fits within associated plants.

I n evaluating the costs of retrofit NO X control technology, estimates were prepared for Boiler #3; similar costs would be expected for the two smaller units. The analysis will concentrate on Boiler #3 as any

conclusions drawn toward the cost effectiveness for this boiler will be less favorable for Boilers #1 and #2 due to comparable costs at lower reduction potential.

The following NO X Control technologies were found not to be feasible for NG

- fired packaged water tube

boilers.

1. Reburn Technology

– this te chnology relies on a second tier of burners to limit the formation of

thermal NO X . Package boilers do not have the space available for a second elevation of burners thus this technology is not feasible for the subject boilers.

2. SCONOX

– this technology us es an oxidation

- absorption

- regeneration cycle across multiple catalyst beds to achieve back

- end (tail

- pipe) reductions in NO X .. This technology could be applied to the subject boilers on a per unit basis or as a group. There is no known use of

SCONOX on small ICI boilers in the U.S. and therefore the technology has not been

demonstrated as feasible for this size of boilers.

3. Selective Catalytic Reduction (SCR)

– this technology involves post combustion removal of NO X with a catalytic reactor and ammonia injection. SCR technology has shown difficulty in achieving consistent NO X reductions from oil

- fired unit such as the Puerto Rico Electric Power Authority’s Arecibo facility. This technology has not been successfully demonstrated for duel oil

and natural gas fired units and is considered technically infeasible.

The following NO X Control technologies were found to be available for NG

- fired packaged water tube

boilers.

1. Low NO X Burners

– 0.035 to 0.05 lbs/MMBtu

– per unit basis

2. Flue Gas Recirculation (FGR )

– per unit basis

3. Low NO X Burners with Flue Gas Recirculation

– per unit basisRanking of Technically Feasible Control Options: Control Technology NO X – Oil lbs/MMBtu NO X – N.G. lbs/MMBtu

1 Low NO X With FGR 0.057 0.029

2 Low NO X Burners Only 0.086 0.058

Lbs/MMBtu for low NO X burners represent a 60% reduction from uncontrolled levels. Lbs/MMBtu for low NOx burners with FGR are based on 30 ppm NOx emissions firing natural gas and 90 ppm NO X emissions firing no.2 fuel oil which equates to an 80% re duction in NO X emissions from uncontrolled.

Existing controls:

The subject boilers presently have no controls for NO X emissions. The boilers are equipped with oxygen

trim which reduces the formation of NO X by limiting the amount of O 2 available for combu stion.

Summary of Cost Effectiveness:

Control Technology Fuel Type $/Ton Removed

Low NO X With FGR Natural Gas 3,800

Low NO X With FGR Natural Gas 5,300

Low NO X Burners Only No.2 Fuel Oil 2,900

Low NO X Burners Only No.2 Fuel Oil 4,600

The above $/to n removed figures were based on an annual uncontrolled NO X emission rate of 88.3 tons/year in the economic evaluation in Appendix A. The previous RACT Order limited uncontrolled emissions to 77.3 tons/yr which would increase the $/ton figures above. The control technology considered is even more cost prohibitive.

Boiler No.4:

Boiler No.4 was installed in 2000/2001 under installation permit no. 0022

- I001, issued September 11, 2000. A BACT determination was made by the Department that low NO X burners and annual combustion

“tune

- ups” are NO X BACT and therefore RACT for the boiler. This determination is still considered valid by the Department and no further analysis is required.

Generators No.1, No.2 & No.3:

By inspection of the potential emissions from these units shown above, it is clear that no add on control technology is economically feasible for these units. NO X RACT will be the proper operation and

maintenance of the units.

RECOMMENDATIONS:

The analysis for NO X RACT for the 8

- hour ozone SIP has demonstrated that any NO X controls for boilers no.1 through no.3 are technically or economically infeasible. It is recommended that the 1

- hour ozone RACT in RACT Plan Approval Order & Agreement No.220 as amended, dated March 4, 1996 still be

considered N O X RACT for the facility.

### APPENDIX A

Economic Evaluation

### ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

October 4, 2006

SUBJECT: Review of 8

- hour Ozone NO X & VOC RACT Submittal Orion Power MidWest, L.P.

Brunot Island Power Plant Combustion Turbines 1A, 1B & 1C Brunot Island, Pittsburgh, PA

TO: San dra L. Etzel Chief Engineer

FROM: Erin J. O’Brian, P. E. Air Quality Engineer

INTRODUCTION :

Orion Power MidWest, L.P., Brunot Island Power Plant (title V Operating Permit No.0056) is a major source of NO X and VOC emissions as defined in section 2101 .02 "Definitions", of Article XXI, ACHD, Rules and Regulations, Air Pollution Control and was subject to the County’s 1

- hour ozone SIP. This required the source to evaluate VOC and

NO X RACT for the facility and take the appropriate measures to implement t his RACT. In addition these RACT requirements were made a part of Allegheny County’s portion of the Pennsylvania SIP by way of a site

- specific SIP

revision. The VOC and NO X RACT for combustion turbines 1A, 1B & 1C at the facility consisted of a finding of “no

VOC or NO X controls were required” due to technical and economic infeasibility.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effecti ve January 30, 2006, all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings

of the reevaluation of VOC and NO X RACT for combustion turbines 1A, 1B & 1C a t the facility.

SOURCE DESCRIPTION :

The Orion Power MidWest, Brunot Island Power Plant is a commercial electrical power generation facility. The source is composed of three 50.5 MW natural gas fired combined cycle combustion turbines and three 22 MW no.2 fuel oil

fired simple cycle combustion turbines which are the subject of this analysis. The simple cycle combustion turbines

have no emission controls for NO X or VOC control.

The facility is a major source of nitrogen oxides (NO X ) and volatile organic compounds (VOCs) as defined in section

2101.20 of Article XXI.The facility consists of the following VOC and NOx emission sources that are subject to this analysis:

Description Rating Controls Fuel Maximum

Potential

NOx Emissions Maximum

Potentia l

VOC Emissions

1A Combustion Turbine in Simple Cycle Mode 22 MW

- 300

x 10 6 btu/hr None No.2 Fuel Oil 275.2 14.54

1B Combustion Turbine in Simple Cycle Mode 22 MW

- 300

x 10 6 btu/hr None No.2 Fuel Oil 275.2 14.54

1C Combustion Turbine in Simple Cycle Mode 22 MW

- 300

x 10 6 btu/hr None No.2 Fuel Oil 275.2 14.54

POTENTIAL EMISSIONS:

The RACT emission limits for turbines 1A, 1B & 1C set forth Title V Permit No. 0056 dated February 16, 2006 are the potential NO X and VOC emissions including all enf orceable controls and restrictions for those units regardless of combustion of fuel oil or natural gas.

NO X RACT ANALYSIS:

Combustion Turbines 1A, 1B and 1C:

The 1

- hour Ozone SIP RACT analysis, conducted on December 5, 1995 was reevaluated by the Depar tment with guidance from EPA

- 453/R

- 93

- 007, "Alternative Control Techniques Document

-- NO

x Emissions from Stationary Gas Turbines", January 1993. and actual cost data.

According to Figures 6.4 through 6.6 of the ACT document, wet injection is the most cost effective control device for turbines of this size with oil firing only, therefore this technology will be the only one analyzed. The NO X control efficiency as per the ACT document is 69.2%.

1. Wet Injection

– approximately 69.2% reduction

– per unit basis

Control technology efficiencies are taken from EPA

- 453/R

- 93

- 007, "Alternative Control Techniques Document

-- NO

x Emissions from Stationary Gas Turbines", January 1993

Ranking of Technically Feasible Control Options:

Control Technology NO X – Oil or N.G.

P otential Controlled Emission Rate 1990 $ (tons/yr)

1 Wet injection at36% annual capacity factor 84.76

Uncontrolled emission rate = 275.2 tons/yr of NO X at a 36% annual capacity factor

Existing controls:

The subject turbines presently have no controls for NO X emissions..Summary of Cost Effectiveness in 1990 $:

Control Technology Fuel Type $/Ton Removed Wet injection No.2 Fuel Oil 1,900

The cost analysis applied the maximum allowable NO X emission rate of 275.2 tons/yr of NO X at a 36% annual

cap acity factor.

NO X RACT ANALYSIS:

By inspection of the maximum potential emissions of VOCs for the combustion turbines 1A, 1B and 1C it is

obvious that no add

- on VOC controls would be cost effective.

RECOMMENDATION:

The analysis for VOC & NO X RACT fo r the 8

- hour ozone SIP has demonstrated that any NO X or VOC controls for turbines 1A, 1B & 1C are technically or economically infeasible using ACT document for combustion turbines and the preamble to the amendments to 40 CFR 51 for the 8

- hour ozone SIP. I t is recommended that the 1

- hour ozone VOC &

NO X RACT in RACT Plan Approval Order & Agreement No.214, dated May 20, 1996 still be considered VOC & NO X RACT (8

- hour ozone) for the facility.APPENDIX A

NO X ECONOMIC ANALYSESECONOMIC ANALYSIS FOR UNITS 1A , 1B AND 1C IN SSC MODE:

NO

x - Wet Injection:

1. Gas Turbine Model: MS

- 5001P, 26.3 MW

- each 2. Maximum hours of operation: 1,500 each 3. Annual capacity factor: 3,153/8,760 = 36%

4. Capital Cost (Table 6

- 4) = $50/KW 5. Capital reco very (Table 6

- 5) = $174,000 6. Total Annual Recovery (Table 6

- 5) = $359,000 7. G & H, Taxes and Insurance (Table 6

- 5) = $52,800

8. Items 4, 5 & 7 are fixed independent of capacity factor.

9. Variable Costs = $359,000

- $174,00 0

- $52,800 = $132,200/Yr = $41.93/Hr ($132,200/3153 Hrs)

10. Uncontrolled Emissions = 275.2 Tons/Yr @ 3,153 Hrs/Yr 11. Emission Reduction for Wet Injection (Table 6

- 6) = 69.2% (273 TPY

- 84.2 TPY)/273 TYP = 69.2%

12. Emissions Reduction = 275.2 TPY x 0.692 = 190.44 Tons/Yr = 0.072 Tons/Hr @ 3,153 Hrs/Yr

13. Cost effectiveness:

Y = (174,000 + 52,800) + (41.93) x (3153) (0.060) x (3153)

Y = $1,897/Ton NO

x removed @ 3,153 Hrs/Yr = $1,900/ton removed

Recommendation: Annual capacity factor for units 1A, 1B and 1C in the simple cycle combustion mode of operation should be (3,153/8,760) = 36.0%.

### ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM

August 28, 2006

SUBJECT: Review of 8

- hour Ozone NO X RACT Submittal Pittsburgh Allegheny County Thermal, Ltd. Law & Finance Building 429 Fourth. Avenue, Suite 806 Pittsburgh, Pennsylvania 15219

TO: Sandra L. Etzel Chief Engineer

FROM: Erin J. O’Brian, P. E. Air Quality Engineer

INTRODUCTION

Pittsburgh Allegheny County Thermal (title V Operating Permit No.0044) is a major source of NO X emissions as defined in section 2101.02 "Definitions", of Arti cle XXI, ACHD, Rules and Regulations, Air Pollution Control and was subject to the County’s 1

- hour ozone SIP. This required the source to evaluate NO X RACT for the facility and take the appropriate measures to implement this RACT. In addition these RACT requirements were made a part of Allegheny County’s portion of the Pennsylvania SIP by way of a site

- specific SIP revision. The NO X RACT for the facility consisted of a finding of “no NO X controls were required” due to technical and economic infeasibility.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006, all 1

- hour ozone SIP RACT findings of “no controls are required ” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings

of the reevaluation of NO X RACT for the facility.

SOURCE DESCRIPTION:

The Pittsburgh Allegheny County Thermal, Ltd., Stanwix Street facility is a commercial st eam generation plant located at 120 Cecil Way in the downtown section of Pittsburgh, PA, which supplies steam for heating and refrigeration to commercial and institutional sites in that area. The plant is composed of four boilers, with one common stack, wh ich fire natural gas as their primary fuel and have the capacity to fire no. 2 fuel oil, in lieu of natural gas at times of emergency or natural gas curtailment. The facility is a major source of nitrogen oxides (NO X ) and a minor source of volatile organic compounds (VOCs) as defined in section 2101.20 of Article XXI.

The facility consists of the following NOx emission sources:

Make/Model Rating Controls Fuel Maximum

Potential

Emissions

Boilers No. 1, 2, 3,

and 4 Zurn Industries Model: M21 Keystone

Ty pe: “O” package

boiler 150

MMBtu/hr

each None? Natural gas with no.

2 fuel oil in case of

curtailment or

emergency 126.5 tons/year NOx (each)POTENTIAL EMISSIONS:

The RACT emission limits for boilers no.1 through no.4 set forth in Order No.265, dated November 9, 1998 are the potential NO X emissions including all enforceable controls and restrictions for those units regardless of combustion of fuel oil or natural gas.

NO X EMISSION

UNIT N.G. NO. 2 FUEL OIL

BASIS LBS/MM

BTU TPY LBS/MM

BTU TPY

No.1 0. 22 126.5 0.22 126.5 RACT Order

No.265 dated November 9, 1998

No.2 0.22 126.5 0.22 126.5 RACT Order

No.265 dated November 9, 1998

No.3 0.22 126.5 0.22 126.5 RACT Order

No.265 dated November 9, 1998

No.4 0.22 126.5 0.22 126.5 RACT Order

No.265 dat ed November 9, 1998

NO X RACT ANALYSIS:

Boilers No.1, No.2, No.3 & No.4:

PACT’s RACT analysis, submitted in correspondence from PACT to the Department, dated August 16, 2006 was conducted with guidance from U. S. EPA's OAQPS Cost Manual and actual cost data.

The following NO X Control technologies were found not to be feasible for NG

- fired packaged water tube boilers.

1. Reburn Technology

– this technology relies on a second tier of burners to limit the formation of thermal NO X

. Package boilers do not hav e the space available for a second elevation of burners thus this technology is not feasible for the subject boilers.

2. SCONOX

– this technology uses an oxidation

- absorption

- regeneration cycle across multiple catalyst beds to

achieve back

- end (tail

- pipe) r eductions in NO X .. This technology could be applied to the subject boilers on a per unit basis or as a group. There is no known use of SCONOX on small ICI boilers in the U.S. and therefore the technology has not been demonstrated as feasible for this siz e of boiler.

3. Selective Catalytic Reduction (SCR)

– this technology involves post combustion removal of NO X with a catalytic reactor and ammonia injection. SCR technology has shown difficulty in achieving consistent NO X reductions from oil

- fired unit such as the Puerto Rico Electric Power Authority’s Arecibo facility. This technology has not been successfully demonstrated for dual oil and natural gas fired units and is considered technically infeasible. In addition, SCR requires a reactor to be placed in the flue gas path where the temperature is high enough for efficient operation. This reactor has to be accessible for catalyst maintenance. There is no floor space available inside or outside the facility to accommodate a reactor.

4. Selective Non

- Catalyti c Reduction (SNCR)

– this technology involves post combustion removal of NO X withammonia or urea injection into the flue gas stream at a temperature between 1,600°F to 2,000°F with a residence time of 1 to 2 seconds. The subject boilers are small package water

- tube units that dissipate heat efficiently. The boiler design for these units lists a boiler furnace temperature range of 2,100°F to 2,500°F and a boiler exit temperature range of 400°F to 500°F. The fast heat dissipation does not allow for proper placement of injection nozzles or provide for sufficient residence time for proper NO X control. In addition the loading on the different boilers is highly variable increasing the problems with proper injection and adequate residence

time.

The following N O X Control technologies were found to be available for NG

- fired packaged water tube boilers. It is assumed that the same reductions are good for both oil and natural gas firing.

1. Low NO X Burners

– approximately 50% reduction

– per unit basis

2. Flue Gas Reci rculation (FGR)

– approximately 40% reduction

- per unit basis

3. Low NO X Burners with Flue Gas Recirculation

– approximately 55% reduction per unit basis

Control technology efficiencies are taken from USEPA “Alternative Control Techniques Document

– NO X E missions from Industrial/Commercial/Institutional (ICI) Boilers” (EPA

- 453 R

- 94

- 022).

Ranking of Technically Feasible Control Options:

Control Technology NO X – Oil or N.G.

Potential Controlled

lbs/MMBtu

1 Low NO X With FGR 0.10

2 Low NO X Burners Only 0.1 1

3 FGR Only 0.13

Uncontrolled emission rate = 0.22 lbs/MMBtu of NO X

Existing controls:

The subject boilers presently have no controls for NO X emissions. The boilers are equipped with oxygen trim which

reduces the formation of NO X by limiting the amou nt of O 2 available for combustion.

Summary of Cost Effectiveness:

Control Technology Fuel Type $/Ton Removed

Low NO X With FGR No.2 Fuel Oil or N.G. 19,555

Low NO X Burners Only No.2 Fuel Oil or N.G. 12,563 FGR Only No.2 Fuel Oil or N.G. 24,068

The c ost analysis applied the maximum allowable NO X emission rate of 0.22 lbs/MMBtu to the maximum heat input for oil firing of 144 MMBtu/hr for annual potential uncontrolled NO X emissions of 138.8 tons/yr. The

allowable uncontrolled annual NO X emissions under the 1

- hour ozone RACT are 126.5 tons/yr. This makes the economic evaluation more conservative from a regulatory standpoint.

RECOMMENDATIONS:

The analysis for NO X RACT for the 8

- hour ozone SIP has demonstrated that any NO X controls for boilers no.1 thro ugh no.4 are technically or economically infeasible using EPA’s Cost Control Manual, ACT document for ICI Boilers and the preamble to the amendments to 40 CFR 51 for the 8

- hour ozone SIP. It is recommended that the 1

- hour ozoneRACT in RACT Plan Approval Order & Agreement No.265, dated November 9, 1998 still be considered NO X RACT (8

- hour ozone) for the facility.

## APPENDIX A

Economic Evaluation

### ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

February 1 2, 2007

SUBJECT: Review of 8

- hour Ozone VOC RACT Submittal PPG Industries, Inc.

– Springdale Plant

125 Colfax Street Springdale, Pennsylvania 15144

- 1506

TO: Sandra L. Etzel Chief Engineer

FROM: JoAnn Truchan Air Quality Engineer

INTRODUCTION :

PPG Springdale (Title V Operating Permit No.0057) is a major source of VOC emissions as defined in §2101.02 "Definitions", of Article XXI, ACHD, Rules and Regulations, Air Pollution Control and was subject to the County’s 1

- hour ozone SIP. This required the source to evaluate VOC RACT for the facility and take the appropriate measures to implement this RACT. In addition, these RACT requirements were made a part of Allegheny County’s portion of the Pennsylvania SIP by way of a site

- specific SIP revision.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006; all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings of the reevaluation of VOC RACT for the facility.

SOURCE DESCRIPTION :

The PPG Industries, Inc., Spring dale Plant consists of a paint manufacturing plant and a research and development plant. The paint plant produces coatings for aluminum extrusions, automotive refinish, general industrial and coil coating. The research and development plant provides scale

- up support for resin manufacture and tests new resins used in coatings. The facility is a major source of volatile organic compounds ( VOC s ) and a minor source of nitrogen oxides (NO X ) as defined in §2101.20 of Article XXI.

The facility consists of the fol lowing VOC emission sources:

Paint Plant

**•** Preassembly & Premix

**•** Pigment Grinding or Milling

**•** Product Finishing

**•** Product Filling

**•** Equipment Cleaning Research & Development Center

**•** “Large Side” Resin Reactors

**•** K13/K15 and R2000 Reactors

**•** “Small Side” Resin Reacto rs

**•** Batch Resin Strippers

**•** Thin Film Evaporator

**•** Storage Tanks

**•** Laboratory

- scale Paint Spray BoothsSource Description Control Device(s) Fuel / Raw Material Maximum Potential

Emissions

Paint Manufacturing (controlled) REECO Thermal

Oxidizer resins, solv ents, pigments, tints, reactants, extenders, oils &

plasticizers and additives 22.9 tpy

Paint Manufacturing (uncontrolled) n/a 114 tpy

Small

- Side Reactors REECO Thermal

Oxidizer

various reactants, solvents, catalysts, and additives to produce experiment al resins 0.02 tpy

Resin Strippers REECO Thermal

Oxidizer 4.7 tpy

Thin

- Film Evaporator REECO Thermal

Oxidizer 0.3 tpy

Large

- Side Reactors REECO Thermal

Oxidizer 6.7 tpy

K13/K15 and R2000

Reactors REECO Thermal

Oxidizer 0.1 tpy

Storage Tanks n/a va rious 2.0 tpy

Fugitive Emissions n/a various 1.3 tpy

#1 Boiler

– 25.11 MMBtu/hr n/a natural gas or fuel oil 0.6 tpy

#2 Boiler

– 25.11 MMBtu/hr n/a natural gas or fuel oil 0.6 tpy

EXISTING CONTROLS / CURRENT RACT REQUIREMENTS:

The existing RACT Order #254 includes conditions for the Resin Plant. That facility is no longer in operation, so those RACT requirements are no longer needed. Currently there are no RACT requirements for external control of VOC emissions from the Paint Plant or the Developmen t Center. However, emissions from both are vented to the REECO Thermal Oxidizer, which has been demonstrated to have a destruction efficiency of 94.5%. Current RACT Requirements include the following:

**•** All stationary mixers must be equipped with covers th at completely enclose the mixer openings, except for an opening no larger than necessary to allow for safe clearance for a mixer shaft. Such covers shall either extend at least 1⁄2” beyond the outer rim of the vessel or be attached to the rim.

**•** All covers on stationary mixers must be closed at all times except when production, sampling, maintenance, or inspection procedures otherwise requires access.

**•** Portable and stationary vessels shall not be used at the facility to process products containing VOCs unless

t he covers are maintained in good condition, such that when in place, they maintain contact with their respective rims for at least 90% of the circumference of the rim.

**•** Dispensing systems shall not be used unless they are of closed design or minimize free

- f all of liquids.

**•** Filling of solvent

- borne coatings shall not be performed unless they are in a closed system.

**•** All grinding mills shall be of completely closed design at all times.

**•** All process and control equipment shall be properly operated and maintained a ccording to good engineering and air pollution control practices at all times.

**•** Process equipment cleaning shall be conducted to minimize VOC emissions.

**•** Floor cleaning operations shall employ water

- based cleaners. The use of solvents will be limited to spo t cleaning.

**•** Records shall be kept to demonstrate compliance with the above requirements. Records shall include, but not be limited to, records of specific solvents and quantities used and records of paint production rates by number of batches and quantity of paint produced in each batch.

**•** Records shall be kept for at least five years and shall be made available to the ACHD upon request.VOC RACT ANALYSIS:

PPG Springdale’s RACT analysis, submitted in correspondence from PPG Springdale to the Department, d ated July

27 , 2006 was conducted with guidance from U.S. EPA's OAQPS Cost Manual , NSR Workshop Manual (October 1990), and other resources referenced in section 3.1 of the RACT analysis submitted July 27, 2006

.

In additions to RACT controls already in plac e at the facility, t he following VOC Control technologies were

considered :

**•** existing process heaters

**•** existing thermal oxidizer

**•** thermal oxidation

**•** catalytic oxidation **•** volume concentrators

**•** flares

**•** emerging technologies

**•** adsorption **•** scrubbing

**•** condensation

**•** biofi ltration

**•** membrane technology

The following technologies were deemed technically infeasible:

Control Technology Reason for Technical Infeasibility

Use of existing process heaters and/or

boilers Low heat recovery in emissions streams; Not located near VO C

sources

Volume Concentrators Flowrates aren’t high enough

Flares Resultant noise, smoke, heat radiation, and light

Emerging VOC Control Technologies N ot yet proven reliable for industrial

- scale applications

Adsorption Not effective due to varying mix ture of VOCs in emissions streams

Scrubbing Varying mixture of VOCs in emissions streams makes it infeasible to obtain reliable vapor/liquid equilibrium data

Condensation Too wide of a range of VOCs in the emissions streams

Biofiltration Not good for em issions containing polyaromatic compounds; Not yet proven reliable for industrial

- scale applications

Membrane Separation Too wide of a range of VOCs in the emissions streams

Summary of Technically Feasible Control Options:

Control Technology Post

- Contr ol

Emissions (tpy) Emission

Reductions 1
(tpy) Removal Efficiency 2 Cost per ton

of VOC

Removed

Use of Existing Thermal Oxidizer

5.7 108.3 95% $5,800

Catalytic Oxidation $11,630

Thermal Oxidation $7,750

RECOMMENDATION:

The analysis for VOC RACT for the 8

- hour ozone SIP has demonstrated that all VOC controls beyond what is already in place for the Paint Plant and the Research and Development Center are technically or economically

infeasible. It is recommended that the 1

- hour ozone RACT in RACT P la n Approval Order & Agreement No. 254

, dated December 19, 1996 still be considered VOC RACT (8

- hour ozone) for the facility.

### ALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM

September 25, 2006

SUBJECT: Review of 8-hour Ozone VOC RACT Submittal Pressure Chemical Company

3419 Smallman Street Pittsburgh, PA 15201-1915

TO: Sandra L. Etzel Chief Engineer

FROM: Erin J. O’Brian, P. E. Air Quality Engineer

INTRODUCTION

Pressure Chemical Company (title V Operating Permit No. 0032) is a major source of VOC emissions as defined in section 2101.02 "Definitions", of Article XXI, ACHD, Rules and Regulations, Air Pollution Control and was subject to the County’s 1-hour ozone SIP. This required the source to evaluate VOC RACT for the facility and take the appropriate measures to implement this RACT. In additi on these RACT requirements were made a part of Allegheny County’s portion of the Pennsylvania SIP by way of a site -specific SIP revision. The VOC RACT for the facility consisted of a finding of “no VOC c ontrols were required” due to t echnical and economic infeasibility.

The County is presently in non-attainment for the 8-hour ozone National Ambient Air Qu ality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effectiv e January 30, 2006, all 1-hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the ru les for the 8-hour SIP. This document presents the findings of the reevaluation of VOC RACT for the facility.

SOURCE DESCRIPTION:

The Pressure Chemical, Co., is a researcher and developer of chemical manufacturing processes for eventual large-scale application by customers. Organic and inorganic chemicals, polymers, and pharmaceutical intermediates are manufactured in small batch reactors ranging from glassware to 1,000gallon pressure vessels. The type, size and duration of the equipment used and the development runs being customer dependent are extremely variable with no fixed set of process equipment. The process equipment typically used at the facility include s glass lined, high-pressure, tubular high-pressure, alloy high-pressure and special alloy react ors, a glass pilot plant, short path distillation, internal and external condensers and filtration, drying and process heating equipment.

The facility is a major source of volatile organic com pounds (VOCs) and a minor source of nitrogen oxides (NO X ) as

defined in section 2101.20 of Article XXI.The facility consists of the following VOC emission sources:

Description Capacity Controls Maximum

Potential/Allowable

Emissions

Reactors Glass lined, tubular, high pressure, special alloy & glass pilot plant system <5 gallons to 1,000 gallons Caustic

Scrubber

66.7 tons/yr Short path

distillation

apparatus NA < 10 liters Caustic

Scrubber

Filtration, drying and

process heating equipment NA NA None

POTENTIAL EMISSIONS:

The allowable VOC emission limits for process equipment set forth above are specified in Title V Operating Permit 0032, dated November 2, 2004 and are the potential NO X emissions including all enforceable controls and restrictions

for those units.

NO X RACT ANALYSIS:

Pressure Chemical Company manufactures a variety of chem icals and operates as a contract pilot plant producing small quantities of organic and inorganic chemicals for commercial use or R&D purposes. The various types of batch processes vent VOC emissions indoors or through several external vents, however, the exact configuration of the process equipment cannot be readily defined as it chang es frequently to meet customer requirements. Pressure Chemical cannot therefore delineate which process vents through a specific emission point. Raw materials, unit operations and products are c onstantly changing to meet market demands. The following RACT analysis will therefore treat the entire plant as one emission source.

This RACT analysis, submitted in correspondence from Pressure Chemical to the Department, dated July 7, 2006 was conducted with guidance from U. S. EP A's OAQPS Cost Manual (reference no.1), Control Technologies for Hazardous Air Pollutants, EPA June 1991 (refere nce no.2) and actual cost data.

The annual potential to emit as per the Title V permit for the fac ility is 66.7 tons/yr that equates to an emission stream of 15.2 lbs/hr. The facility has three scrubbers with the following exhaust flow-rates:

High Bay Scrubber – 20,000 scfm TJ Scrubber – 10,000 scfm Glass Lab Scrubber – 2,500 scfm

The highest VOC concentration results if all emissi ons go through the High bay Sc rubber, which equals 152 ppm V

. Putting all emissions through either of the other two scrubbers results in an impractical exhaust rate.

The following VOC Control technologies were found not to be feasible for the facility:1. Carbon/Zeolite Adsorption – Adsorption systems are eff ective only on VOC streams with concentrations of 700 to 10,000 ppm as per reference 2, table 3-1.

2. Absorbtion – Scrubbing is only effective on VOC streams of 250 to 10,000 ppm concentration as per reference 2, table 3-1 and with a suitable scrubbing liquid for the VOCs in the exhaust stream. Based on this information

it is unreasonable to think that an increase in the approximate 70% VOC reduction achieved by the present scrubbers is feasible. Any additional modifications to the scrubbers, if possible would not achieve VOC

reductions above 70% that w ould be cost effective.

3. Condensation – This technology requires a minimum of 500 ppm concentration of VOCs just to achieve approximately 50% reductions. As per reference 2 above, condensers are effective with VOC concentrations of 5,000 ppm to 10,000 ppm.

4. Flares – This technology requires high temperatures to ach ieve VOC reduction in the 90% plus range which is

not feasible. In addition a flare in the area of the f acility is not feasible due to the closeness of business and residential buildings.

5. Biofiltration – The variability of organics in the waste stream makes this technology infeasible. This type of treatment requires stable filters which cannot be achieved with such variable waste gas.

The following VOC Control technologies were found to be available for use at Pressure Chemical:

1. Regenerative thermal oxidizer – 99% VOC control efficiency.

2. Thermal incinerator - 99% VOC control efficiency.

3. Catalytic incinerator – 98% VOC control efficiency.

Control technology efficiencies are taken from reference no.2, figure 3.1)

Ranking of Technically Feasible Control Op tions and Summary of Cost Effectiveness:

Control Technology Emission Reduction tons/yr Annualized Cost $ Cost $/ton

removed 1 Regenerative thermal oxidizer 66.03 682,493 10,336
2 Thermal incinerator 66.03 2,390,019 36,196 3 Catalytic incinerator 65.37 1,343,414 20,551

Uncontrolled emissions = 66.7 tons/year of VOCs

Existing controls:

The facility presently has scrubbers for control of VOCs with approximate VOC control efficiencies of 70% plus when

tested with toluene..

RECOMMENDATIONS:

The analysis for VOC RACT for the 8-hour ozone SIP has demonstrated that any additional VOC controls for the facility are technically or economically infeasible usi ng EPA’s Cost Control Manual, Control Technologies for Hazardous Air Pollutants, EPA June 1991and the preamble to th e amendments to 40 CFR 51 for the 8-hour ozone SIP.

It is recommended that the 1-hour ozone RACT in RACT Plan Approval Order & Agreement No.261, dated June 11,

1997 still be considered VOC RACT (8-hour ozone) for the facility.

## APPENDIX A

Economic EvaluationALLEGHENY COUNTY HEALTH DEPARTMENT AIR QUALITY PROGRAM

March 1, 2012

SUBJECT: Review of RACT Submittal Shenango Incorporated Neville Island, PA 15225

TO: Sandra L. Etzel

Chief Engineer

FROM: Hafeez Ajenifuja Air Quality

INTRODUCTION:

This document replaces the original 200 6 RACT review

.

The Shenango Incorporated operates a coke production facility on Neville Island in Allegheny County. The facility consists of one coke battery, four boilers and a chemical byproducts recovery plant. This facility is a major stationary source o f NOx and VOC emissions as defined in §2101.20 of Article XXI. This requires Shenango to evaluate NO X and VOC RACT for the facility and implement appropriate measures as necessary. These RACT requirements were made a part of Allegheny County’s portion of the Pennsylva nia SIP by way of a site specific SIP revision. A RACT review for this facility was originally developed in 199 6 . This review discusses those changes in the facility that took place between

199 6 and 2006.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006; all 1

- hour ozone SIP RACT findings of “no controls are required” m ust be reevaluated under the rules for the 8

- hour SIP. This document presents the findings of the reevaluation of NO X and VOC RACT for the facility.

The facility is a major source of volatile organic compounds (VOCs), and nitrogen oxides (NOx), as

define d in §2101.20 of Article XXI.

SOURCE DESCRIPTION:

Shenango Incorporated Neville Island Plant, located at 200 Neville Road, Pittsburgh, Allegheny County, PA is a coke production facility.

The only change at the facility impacting NOx and VOC emissions w as the replacement of four (4) boilers by four (4) more efficient Low NO

x Burner boilers.2 The following table lists the NOx and VOC emissions related to the change in boilers at the Shenango

I ncorporated Neville Island Plant :

SOURCE RAT ED

CAPACITY ( MMBTU / HR ) CONTROLS MAXIMUM POTENTIAL

EMISSIONS 1 (tpy)

NOx VOC

Boiler #7 130 None

836 4.8 Boiler #8 130 None

Boiler #9 400 None

Boiler #10 532 None

Boiler #1 71.6 Low NOx Burners

with Flue Gas

Recirculation

105.20 8.85 Boiler #2 96.8 Low NOx Burners

with Flue Gas

Recirculation

Boiler #3 96.8 Low NOx Burners

with Flue Gas

Recirculation

Boiler #4 96.8 Low NOx Burners

with Flue Gas

Recirculation

DIFFERENCE

- 730.80 + 4.05

1 Maximum Potential Emission from IP No. 0025

- I004 & RACT Review 1996

Section 1. 1 of RACT Order No. 2 33 , dated December 30 , 1996 states that:

Shenango shall maintain the following equipment in accordance with good engineering and air pollution control practices.

Boilers 7, 8, 9 and 10

NOx RACT ANALYSIS :

Boilers 7, 8, 9 and 10

The following technologies were identified during the re

- evaluation of RACT for the replacement of four (4) old boilers with new and more efficient four (4) boilers :

 Selective Non

- catalytic Reduction ( SNCR )
 Selective Catalytic Reduction ( SCR )
 Low NO

x Burners with Flue Gas Recirculation

 Selective Non

- catalytic Reduction (SNCR) : This involves the injection of ammonia, urea, or other nitrogen containing compounds into the flue gas to convert NOx to nitrogen and water.3 Under optimum operatin g conditions of flue gas temperature ( 1600 o F

- 1900 o F ), residence time of combustion gases at peak flame temperature (>1 sec), and fuel (natural gas ) , SNCR is only 20

– 50% effective in controlling NOx emissions. Operating conditions of typical COG fired boi lers ( i.e. , significantly lower and variable exhaust gas temperatures and residence times) do not meet these criteria. Consequently, there have been no successful demonstrations of the SNCR process

on COG

- fired boilers. Accordingly, application of SNCR to COG

- fired boilers is not considered

feasible.

 Selective Catalytic Reduction (SCR) : In this process, ammonia is injected into the flue gas upstream of a catalyst bed which operates within a temperature range of about 500 o F

- 750 o F, or

600 o F

- 950 O F, depending on the type of catalyst used. The ammonia is usually injected at about 5% concentration through a nozzle grid, using compressed air to steam as the carrier fluid

. A dequate ammonia mixing with the flue gas and proper ammonia flow control are cr itical to the efficient operation of SCR. Also

, SCR efficiency for NOx removal is temperature sensitive. Below the optimum catalyst operating range, ammonia is oxidized to form NOx, damage to the catalyst from thermal stress may also occur.

SCR systems ha ve provided the highest potential NOx removal efficiencies of any technology to date ( i.e.

, NOx removal rates of 80 to 90 percent and higher). The impact of the SCR unit on plant
operations, its performance capability, and capital/operation costs depend on the type of power
system and fluid used. SCR is more easily applied to gas turbines and engines firing only natural
gas than to boilers fired by sulfurous fuels, waste to energy plants and engines burning diesel
fuels. Some potential problems with SCR app lications to combustion units firing fuel oil include
poisoning and erosion of the catalyst by fly ash and SO 3 formation that leads to fouling and
plugging of downstream components by ammonia bisulfate.

No applications of SCR have been found for COG fired boilers. Because there have been no successful demonstrations of SCR on COG fired boilers, and because there is a serious potential for reactor fouling from sulfuric emissions, SCR is considered only ma rginally technology

feasible for these boilers.

 Low NO

x Burners with Flue Gas Recirculation (LNB + FGR) : LNBs are specially designed burners which employ a variety of principles, including low excess air, off

- stoichiome tric or staged combustion, and F G R i n order to minimize NOx formation while maintaining acceptable combustion of carbon and hydrogen in the fuel. FGR involves the recirculation of a portion of the flue gas, usually between 10 to 20 percent of the combustion air, to primary combustion zone to reduce peak flame temperature and to a lesser extent, to lower the oxygen concentration in the primary flame zone, thus reducing the thermal NOx formation.

The use of LNB + FGR in the Shenango COG fired new package boilers wa s selected as BACT

for NO

x e mission control , which is better than RACT. SCR for NOx emission control is ruled out due to environmental impacts and high economic costs. Other environmental concerns include the use of ammonia and the disposal of the catalyst which would need to be mana ged as a hazardous

waste.

VOC RACT ANALYSIS:

RACT for the package boilers VOC is proper combustion technology/design, use of clean fuels (coke oven gas and natural gas) and boiler operation and maintenance according to good engineering and air pollution control practices at all times.4 NOx & VOC RACT

- PEC Baghouse

NO X : At the potential to emit of 7.6 tons/yr, no control technologies are technically or economically

feasible

.

VOC: At the potential to emit of 1 9 tons VOCs/yr, o peration and maintenance costs alone make any control technology addition, cost prohibitive.

Proper operation and maintenance according to good engineering and air pollution control practices will

be considered VOC and NO

x RACT for this emission unit.

NOx & VOC RACT

- Quench Tower:

NO

x : At the potential to emit of 1.77 t ons NO

x /y r no control technologies are technically or

e conomi cally feasible.

VOCs: At the potential to emit of 14.95 tons VOCs / y r operation and maintenance costs alone make any control technology addition, cost prohibitive.

Proper operation and maintenance according to good engineering and air pollution control practices will

be considered VOC and NO

x RACT for this emission unit.

NOx & VOC RACT

- Emission Units with an Existing Nitrogen Blanketing System:

NO

x : There are no NO

x emissions from these units.

VOCs: The following VOC emission units are regulated by the Benzene NESHAP, which requires a

95% control of benzene emissions from these units. The facility complies with the NESHAP requirements by employing a nitrogen gas blanketing system o n the subject units.

VOC RACT will be proper ope ration and maintenance of the N 2 blanketing system on the subject units

at all times while they emit VOC emissions.

1) Tar Storage Tanks 2) Light Oil Storage Tanks 3) Wash Oil Storage Tanks 4) Flushing Liquor Storage Tanks

There are no NO

x emissions from these units NOx & VOC

- Tar Truck and Light Oil Loading:

VOCs: At a combined potential to emit of 4.3 tons VOC/yr

, operation and maintenance costs alone make any control technology addition, cost prohibitive.

Proper operation and maintenance according to good engineering and air po ll ution control practices wi1l

be considered VOC RACT for these emission u nits

.5 RECOMMENDATION:

The analysis for NO

x RACT has demonstrated that the use of Low NO

x Burner and Flue Gas

Recirculation control on the four new boilers with heat input capacity of 265.2 MMBtu/hr (71.6 + 96.8 + 96.8) is technically feasible and was considered BACT, which is better than RACT. Although the design heat input to all four boilers is 362.0 MMBtu/hr, Shenango has agreed to limit the hourly heat input to

265.2 MMBtu/hr Boilers

.

It is recommended that proper combustion technology/design, use of clean fuels (coke oven gas and natural gas) and boiler operation and maintenance according to good engineering and air pollution control practices at all times is considered VOC RACT.

Nitrogen blanketing system has b een installed on the majority of the VOC sources associated with the by

product plant. It is recommended that prope r combustion technology/design, operation and maintenance

of all other emission units according to good engineering and air pollution control practices at all times is

considered NO

x and VOC RACT

.

### ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

November 9, 2006

SUBJECT: Review of Re

- Evaluation of RACT for Clairton Works

U.S. Steel Clairton Works

400 State Street Clairton, Pennsylvania 15025

TO: Sandra L. Etzel Chief Engineer

FROM: Thomas M. Heron Air Quality Engineer

INTRODUCTION :

U.S. Steel Clairton Works is a major source of NO X 

### and VOC emissions as defined in Section 2101.02 "Definitions", of Article XXI, ACHD, Rules and Regulations, Air Pollution Control and was subject to the

Count y’s 1

- hour ozone SIP. This required the source to evaluate NO X 

### and VOC RACT for the facility and take the appropriate measures to implement this RACT. In addition these RACT requirements were made a part of Allegheny County’s portion of the Pennsylvania SIP by way of a site

- specific SIP revision. The NO X 

### and VOC RACT for the facility consisted of a finding of “no NO X 

### or VOC controls were required” due to technical and economic infeasibility.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006, all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour

SIP. This d ocument presents the findings of the reevaluation of NO X 

### and VOC RACT for the facility.

SOURCE DESCRIPTION : The coke and coal chemicals production facilities at U. S. Steel Clairton Works (Clairton Works) are comprised of a complement of twelve by

- product coke batteries with an annual capacity of approximately 8.2 million tons of coal charged. The by

- products plant at Clairton includes facilities for recovery of clean coke oven gas (COG), coal tar, coke oven light oil, anhydrous ammonia and elemental sulfu r. Environmental facilities include a wastewater treatment plant and a Claus carbonate COG desulfurization unit. The plant produces a significant fraction of its electricity requirements and is self

- sufficient in steam and cooling water.

Sources that are n ot regulated by another applicable technology or operational requirement in Section 2105 of Article XXI of the Allegheny County Air Pollution Control Regulations, or are not covered by a presumptive RACT requirement in Section 2105.06, are included in a ca se

- by

- case RACT analysis. U.S. Steel Clairton Works source categories that are included in the analysis, based on this criteria, consist of:

**•** Coke battery underfire combustion stacks (NOx and VOCs)

**•** Coke battery fugitives, including baghouse stack, travelin g hot car and uncontrolled pushing (NOx and VOCs)

**•** Boilers (NOx and VOCs)

**•** Desulfurization plant (NOx and VOCs)

### • Flares (NOx and VOCs)

**•** Coke by

- products recovery plant (VOCs only)

**•** Wastewater treatment units (VOCs only)

**•** Miscellaneous methanol usage (VOCs only)

Table 1 lists the NO X 

### and VOC emission sources at the Clairton Works:

### Table 1

NO X 

### and VOC Sources at the U. S. Steel Clairton Works

SOURCE MAKE/MODEL RATING CONTROLS FUEL Maximum Potential Emissions, tpy

NO X 

### VOC

Coke Batteries

1

- 3 and 7

- 9,

Under fire

Stacks Koppers & Wilputte Approximately 148 MMBtu/hr,

each None Coke

Oven Gas 601.6,

each stack 28.0, each

stack

Coke Batteries 13, 14 & 15

Underfire

Stacks Carl Still Approximately 156 MMBtu/hr,

each None Coke

Oven Gas 374.4, each

stack 29.5, each

s tack

Coke Batteries

19 and 20

Underfire

Stacks Koppers

- Becker Approximately 286 MMBtu/hr,

each None Coke

Oven Gas 1,377.2,

each stack 54.2, each

stack

Coke Battery B

Underfire

Stack Carl Still Approximately

426 MMBtu/hr None Coke

Oven Gas 850.9 80.6

Cok e Battery Pushing and Fugitive

Emissions All Batteries except B Traveling Hood/Stationary Baghouse NA

Battery B Coke

- Side Shed & Baghouse NA

Boiler 1 Cyclone 760 MMBtu/hr COG &

NG 1,740.0 21.05

Boiler 2 Wall

- fired 481 MMBtu/hr COG &

NG 1,285.0 13.33

Boilers R1 &

R2 Package Wall

fired 229 MMBtu/hr,

each COG &

NG 525, each 6.34, each

Boilers T1 &

T2 Package Wall

fired 156 MMBtu/hr,

each COG &

NG 358, each 4.32, each

Desulfurization

Plant SCOT Plant

Incinerator 2.6 38.9

Coke By

Products

R ecovery Plant Gas Blanketing System for VOC

Emissions 124.3

Ammonia

Flare 12.5 MMBtu/hr 12.5 MMBtu/hr 19.03 0.5

Methanol Usage Gas Blanketing System for Storage Tanks 71.61

1. Heat input ratings for coke oven battery underfiring based on maxim um hourly coke oven gas usage from Title V Application.

### POTENTIAL EMISSIONS: Section 1.1 of the Plan Approval Order and Agreement No. 234 Upon Consent (RACT Order 234), dated December 30, 1996, required that the following process equipment be properly ma intained and operated according to good engineering and air pollution control practices at all times:

1. Coke Batteries No. 1, 2, 3, 7, 8, 9, 13, 14, 15, 19, 20 and battery B

2. Pushing Emission Control Systems for the batteries specified in 1. above.

3. Boilers 1 , 2, R1, R2, T1 and T2

4. By

- Products Plant Clean Coke Oven Gas Blanketing System and all process units blanketed by this

system
5. SCOT Plant Incinerator

6. Wastewater Treatment Plant

Section 1.2 of RACT Order 234 specified the following NO X 

### emission limits (lbs/ MMBtu and tons/year) for Boilers No.1, 2, R1, R2, T1 and T2:

NO X 

### EMISSION UNIT Coke Oven Gas and/or

Natural Gas BASIS

Lbs/MMBtu TPY

Boiler No. 1 0.54 1,740 RACT Order No.234

Boiler No. 2 0.54 1,285 RACT Order No.234

Boiler No. R1 0.54 525 RAC T Order No.234

Boiler No. R2 0.54 525 RACT Order No.234

Boiler No. T1 0.54 358 RACT Order No.234

Boiler No. T2 0.54 358 RACT Order No.234

NO X 

### RACT ANALYSIS:

1. Coke Battery Underfiring

The Re

- Evaluation of RACT study identified the following co ntrols as potentially technically feasible for coke battery underfiring:

**•** Low

- NO X 

### Burners (LNBs) and Ultra

- Low NO X 

### Burners (UNLBs)

**•** Flue Gas Recirculation (FGR)

**•** Selective Non

- Catalytic Reduction (SNCR)

**•** Selective Catalytic Reduction (SCR)

LNBs and UNLBs are not a technically feasible retrofit technology because the coke ovens are direct

fired and each battery contains more than 1,600 burners. Also, UNLBs have not been applied to coke

### oven gas. FGR is not technically feasible for battery underfiring because of the large volume of fuel gas that is handled and the existing design of the underfire system. SCR and SNCR technologies have not been applied to coke battery underfiring and is not considered reasonably available for this application.

2. Pushing Emissi on Control Systems

After the coking cycle is completed, the incandescent coke is pushed from the oven into a traveling hot car. For all batteries except battery B, coke pushing is controlled by a traveling hood that is exhausted to a stationary baghouse. B

- battery uses a coke

- side shed that is also exhausted to a stationary baghouse. NO X 

### emission estimates for the pushing operation are contained in a draft AP

- 42 document and the emission factor has a rating of E. Because of the volume of air exhausted to the baghouse and atmosphere, NO X 

### concentrations are in the ppb range; therefore, controlling these emissions is not practical or economically feasible.

3. Boilers No.1, 2, R1, R2, T1 and T2

RACT Order 234 limits boilers 1, 2, R1, R2, T1 and T2 to a shor t term NO X 

### emission rate of 0.54 lbs/MMBtu. Stack testing indicates that these boilers are achieving NO X 

### levels significantly less than

this limit.

During the ozone season, operators change the way they fire boilers 1 and 2 to reduce NO X 

### emissions. The No. 1 boiler has 3 cyclone burners oriented in the shape of a triangle. No. 2 boiler has 4 burners (two on top and two on the bottom). During the ozone season, the operators run the top burners (one burner on No. 1 boiler and 2 burners on No. 2 boiler) on each boiler at minimum gas flow and maximum airflow to the top burners. The bottom burners are run with minimal airflow and maximum gas flow. The boilers are less efficient from a steam generation and

temperature standpoint when run in this manner dur ing the ozone season. Since steam requirements are less during the ozone season, this is not a problem. NO X 

### generation is also higher on the operating boiler during an outage of the other boiler.

According to Section 4.2.2 of the July 17, 2006 Re

- Evalu ation of RACT submitted by U.S. Steel , the

NO X 

### emission rates for boilers R1, R2, T1 and T2 are generally lower than emission rates commonly associated with packaged natural gas fired boilers that employ low

- NO X 

### burners. Stack testing performed in October 2001 and April 2004 indicates NO X 

### emission levels for these boilers range from 0.14 to 0.19 lbs/MMBtu. Testing was conducted while the boilers were firing primarily COG. The

NO X 

### emission factor for natural gas

- fired large wall

- fired boilers (>100 MMBtu/ hr) in Table 1.4

- 1 of

AP

- 42 is 0.14 lbs/MMBtu. This would indicate that these boilers are achieving NO X 

### emission rates equal to or greater than (not lower than) similar sized natural gas

- fired boilers. However, retrofitting

low

- NO X 

### burners in these boile rs may not significantly reduce the NO X 

### levels they are currently achieving. The July 17, 2006 study did not consider combustion controls (low

- NO X 

### burners) to be a technically feasible control option; therefore, a cost analysis was not provided. A cost ef fectiveness analysis was performed for post combustion controls (SNCR) for boilers R1, R2, T1 and T2. The cost efficiency for these boilers was greater than $20,000 per ton of NO X 

### removed.

4. SCOT Plant Incinerator

Stack testing of the SCOT Plant Incinera tor for NO X 

### emissions was conducted in July 2001 and December 2004. The average NO X 

### emission rate for both tests was 0.4 lb/hr. Based on these results,

### the addition of controls to further reduce NO X 

### emissions is not required ; therefore, RACT is to

prope rly maintain and operate this equipment according to good engineering and air pollution control practices at all times.

VOC RACT ANALYSIS

1. 

### Coke Oven Batteries

VOC emissions from coke oven batteries are controlled by properly operating and maintaining the batteries according to good engineering and air pollution control practices at all times. During the coking operation, the volatiles released from the coal are collected and exhausted to the By

- Products plant for further separation into tars and light oi l. The NESHAP regulation in 40 CFR Part 63, Subpart L

- National Emission Standards for Coke Oven Batteries addresses good operating practices that minimize VOC emissions. Therefore, no additional control of VOC emissions from coke oven batteries, includ ing the combustion stacks and pushing emission control systems, is required.

2. 

### Boilers No.1, 2, R1, R2, T1 and T2

VOC controls were reviewed in the previous RACT analysis and the cost effectiveness was more than $100,000 per ton of VOC reduction. This pre vious RACT analysis and the July 17, 2006 Re

Evaluation of RACT concluded that good combustion practices will minimize VOC and these practices constitute RACT for boilers 1, 2, R1, R2, T1 and T2.

**3.** 

### By

- Products Plant

Emissions of VOCs from the by

- product s plant are controlled by a clean coke oven gas blanketing system that captures approximately 98% of the emissions. The carrier gas is mixed with coke oven gas which is used as fuel for the boilers at the Clairton Works and other downstream boilers and

fur naces. This gas blanketing is considered RACT for the by

- products plant

. Further controls are cost prohibitive.

4. 

### Desulfurization Plant

Tail gas from the desulfurization plant is treated by the SCOT plant incinerator. Thermal oxidation

is considered to be the most cost effective means of red ucing VOC emissions. This is considered RACT for this process

.

5. 

### Methanol Usage

Methanol is used in three places at the Clairton Works:

**•** Injected into compressed air lines in winter months to prevent condensate from freezing;

**•** Added to coke battery sealing material during winter months to prevent freezing; and

**•** Used to wash cryogenic process vessel packing (quartzite stones) in preparation for

maintenance or turnaround activities.

The methanol injected into compressed air lines and methanol added to the sea ling material is released to the atmosphere from several locations. Good engineering and air pollution control practices are considered RACT for these two uses of methanol to prevent freezing during the winter months.

### The methanol used to wash the reg enerator stones is stored in tanks that are controlled by the by

products plant gas blanketing system. After washing, the methanol is returned to one of the methanol tanks. VOC emission controls for this process are considered RACT.

RECOMMENDATION:

The analysis for NO X 

### and VOC RACT for the 8

- hour ozone SIP has demonstrated that any NO X 

### or VOC controls for the sources listed in Table 1 above, are technically or economically infeasible.. It is

recommended that the 1

- hour ozone RACT in RACT Plan Approval Order & Agreement No.234, dated December 30, 1996 still be considered NO X 

### and VOC RACT (8

- hour ozone) for the facility.

### ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

November 9, 2006

SUBJECT: Review of Re

- Evaluation of RACT U.S. Steel Edgar Thomson Works

13 th 

### Street & Braddock Avenue Braddock, Pennsylvania 15104

TO: Sandra L. Etzel Chief Engineer

FROM: Thomas M. Heron Air Quality Engineer

INTRODUCTION :

U.S. Steel Edgar Thomson Works is a major source of NO X 

### and VOC emissions as defined in Section 2101.02 "Definitions", of Article XXI, ACHD, Rules and Regulations, Air Pollution Control and was subject

to the County’s 1

- hour ozone SIP. This required the source to evaluate NO X 

### and VOC RACT for the facility and take the appropriate measures to implement this RACT. In addition these RACT requirements were made a part of Allegheny County’s portion of the Pennsylv ania SIP by way of a site

- specific SIP revision. The NO X 

### and VOC RACT for the facility consisted of a finding of “no NO X 

### or VOC controls were required” due to technical and economic infeasibility.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006, all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour

SIP. T his document presents the findings of the reevaluation of NO X 

### and VOC RACT for the facility.

SOURCE DESCRIPTION :

The Edgar Thomson plant is an iron and steel processing facility that mainly produces steel slabs. Raw materials such as coke, iron ore, scra p and fluxes are charged to blast furnaces. Molten metal is tapped from the furnaces at the casthouse, where the metal is transferred to ladles. Hot metal is then transferred to a hot metal mixer or directly poured, in preparation for desulfurization. From there a reagent is added to the hot metal, causing sulfur and other impurities to rise to the surface where it can be removed. The metal is then poured into a basic oxygen process (BOP) furnace where the metal is combined with other metals, fluxes and lan ced using oxygen. Steel from the BOP is transferred to the ladle metallurgy facility (LMF) or vacuum degaser, where metal refining occurs. Metal is then poured into a dual strand continuous caster to create steel slabs. From there the slabs are finished (c ut / ground) and shipped off

- site.

Facility NOx and VOC sources consist of:

**•** Two Blast furnace casthouses (NOx and VOCs)

**•** Two Blast furnace stoves (NOx and VOCs)

**•** BOP (NOx and VOCs)U. S. Steel Edgar Thomson Works 2006 RACT Technical Support Document Page 2



### • Three Boilers (NOx and VOCs)

**•** Ladle Metallurgy Furnace (VOCs)

The followi ng table lists the NO X 

### and VOC emission sources at the Edgar Thomson Works:

Table 1

NO X 

### and VOC Sources at the U. S. Steel Edgar Thomson Works

SOURCE RATING CONTROLS FUEL Maximum Potential Emissions, tpy

NO X 

### VOC

Blast Furnace

No. 1 Stoves Approximat ely

324 MMBtu/hr None BFG, COG

& NG 27.7 2.1

Blast Furnace

No. 1

Casthouse 1,350,000 ton/yr of Hot

Metal Flame Suppression/ Baghouse Coke Oven

Gas 5.6 [1] 

### 11.4

Blast Furnace

No. 3 Stoves Approximately

324 MMBtu/hr None BFG, COG

& NG 27.7 2.1

Blast Furna ce No. 3

Casthouse 1,132,000 ton/yr of Hot

Metal Flame Suppression/ Baghouse Coke Oven

Gas 5.4 [1] 

### 9.6

Basic Oxygen Process (BOP)

Furnace 3,000,000 ton/yr

of Steel Primary

- Venturi

Scrubber/ Secondary

- Baghouse 82.0 [2] 

### 25.5

Riley Boiler 1 428 MMBtu/hr None BFG, COG

& NG 800 9.7

Riley Boiler 2 428 MMBtu/hr None BFG, COG

& NG 800 9.7

Riley Boiler 3 428 MMBtu/hr None BFG, COG

& NG 800 9.7

Ladel Metallurgy Furnace (LMF) 3,000,000 ton/yr

of Steel Baghouse COG & NG 1.0

1. Potential NO X emissions from the casthouse based on hot metal production of 1,350,000 ton/yr for #1 Blast Furnace and 1,132,000 for #3 Blast Furnace. Maximum coke oven gas used for flame suppression was assumed to 100 mmcf/year for each furnace. NO X Emission factors are: Casthouse Bagho use = 0.018 lb/THM; Roof Monitor = 0.006 lb/THM; and Flame Suppression = 80 lb/mmcf

- COG. Control efficiency for the casthouse baghouse and roof monitor emissions is 90%.



### 2. Potential NO X emissions from the BOP furnace are based on maximum steel production o f 3,000,000 tons/yr and maximum coke oven gas and natural gas usage of 500 mmcf/yr and 280 mmcf/yr, respectively. NO X emission factors are:

BOP Scrubber = 0.032 lbs/ton

- steel; COG = 80 lbs/mmcf and NG = 100 lbs/mmcf.



### POTENTIAL EMISSIONS:

Section 1.1 of the Plan Approval Order and Agreement No. 235 Upon Consent (RACT Order 235), dated December 30, 1996, required that the following process equipment be properly maintained and operated according to good engineering and air pollution control practices at all times:U. S. Steel Edgar Thomson Works 2006 RACT Technical Support Document Page 3



### 1. Boilers 1 through 3

2. Blast Furnace Stoves and Casthouses #1 and #3

3. Dual Strand Continuous Caster

4. Basic Oxygen Furnace Vessels F & R

5. Blast Furnace Gas Flare

6. Hot Metal Transfer and Desulfurization unit

7. Blast Furnace Ramming Mix Operations

Sectio n 1.2 of RACT Order 235 specified the following NO X 

### emission limits (lbs/MMBtu and tons/year) for Riley Boilers No.1, 2 and 3:

NO X 

### EMISSION UNIT Blast Furnace Gas, Coke

Oven Gas and/or

Natural Gas BASIS

Lbs/MMBtu Annual Emissions, tons/year

Riley Boiler No. 1 0.55 800 RACT Order No.235

Riler Boiler No. 2 0.55 800 RACT Order No.235

Riley Boiler No. 3 0.55 800 RACT Order No.235

NO X 

### RACT ANALYSIS:

1. Blast Furnaces No. 1 and No. 3 Stoves

The Re

- Evaluation of RACT study identified the fol lowing controls as potentially technically feasible

for the blast furnace stoves:

**•** Low

- NO X 

### Burners (LNBs), and

**•** Ultra

- Low NO X 

### Burners (UNLBs)

The primary fuel used for the blast furnace stoves is blast furnace gas. Potential NO X 

### emissions for

each set of stoves is approximately 28 tons/year and actual emissions for 2005 were approximately 17 tons/year. Combusting blast furnace gas in these stoves results in relatively low NO X 

### emissions (approximately 0.013 lb

- NO X 

### /MMBtu based on stack testing performed in 1993). LNBs and UNLBs are not a technically feasible retrofit technology for this application because these burners have not been applied to equipment that combusts blast furnace gas . Therefore, RACT for the Blast Furnace No. 1 and No. 3 stoves is proper maintenance and operation according to good engineering and air pollution control practices at all times.

2. Blast Furnace No. 1 and No. 3 Casthouses

Emissions from the casting of hot metal are controlled by a baghouse that evacuates emissions at theU. S. Steel Edgar Thomson Works 2006 RACT Technical Support Document Page 4



### tap h ole and to some extent from the iron runners. The iron runners are covered and ignited coke oven gas is applied to areas that are not covered to suppress the generation of iron oxide fumes. According to the 2005 emission inventory, NO X 

### emissions from both casthouses, including the NO X 

### generated by the COG fume suppression system, were less than 9 tons/year and potential emissions are less than 11 tons/year. There are no practical methods to control NO X 

### and VOC emissions from the casthouses and

uncontrolled NO X 

### emissions from the casthouses are minimal. Therefore, RACT for the Blast Furnace No. 1 and No. 3 casthouses is proper maintenance and operation according to good engineering and air pollution control practices at all times.

3. Basic Oxygen Process (BOP ) Furnace

The following control technologies were identified in the July 17, 2006 Re

- Evaluation of RACT as potentially feasible for the control of NO X 

### emissions from the BOP scrubber stack:

**•** SNCR

**•** SCR

These control methods have not been applied to emissio ns of NO X 

### from a BOP scrubber stack and conditioning the low temperature (approximately 120 o 

### F) saturated exhaust gas prior to treatment in an SCR or SNCR system would be energy intensive and not cost effective. The cost analysis indicates

that the cost e fficiency for an SCR system is $182,654 per ton of NO X 

### removed . Therefore, RACT for the BOP furnace is proper maintenance and operation according to good engineering and air pollution control practices at all times

.

4. Boilers No. 1, 2 & 3

RACT Order 23 5 limits each of the three boilers to a short term NO X 

### emission rate of 0.55 lbs/MMBtu. Stack testing indicates that these boilers are achieving NO X 

### levels significantly less than this limit. The primary fuel for these boilers is blast furnace gas and co mbusting this fuel results in very low NO X 

### emissions. Potential NO X 

### emissions for each of these boilers is 800 tons/year; however, actual 2005 emissions were less than 50 tons/year for each boiler. LNBs or ULNBs are not available for boilers combusting b last furnace gas and SCR and SNCR systems have not been applied to boilers that combust primarily blast furnace gas . Therefore, RACT for these boilers continues to be proper maintenance and operation according to good engineering and air pollution contro l practices at

all times and the short term and annual NO X 

### emission limitations of 0.55 lbs/MMBtu and 800 tons per year, respectively.U. S. Steel Edgar Thomson Works 2006 RACT Technical Support Document Page 5



### VOC RACT ANALYSIS

1. 

### Blast Furnaces No. 1 and No. 3 Stoves

Potential VOC emissions from the blast furnace stoves are 2.1 tons/year for each blast furnace. Based on these annual emission rates, VOC control for the blast furnace stoves is not practical and cost

prohibitve . Therefore, RACT for the blast furnace stoves is proper maintenance and operation according to good engineering and air pollution control practices at all times.

2. 

### Blast Furnace No. 1 and No. 3 Casthouses

The VOC concentration in the casthouse baghouse exhaust is quite low and is not amenable to any cost effective control technology that would reduce VOC emissions. Ther efore, RACT for the blast furnace casthouses is proper maintenance and operation according to good engineering and air pollution control practices at all times.

3. 

### Basic Oxygen Process (BOP) Furnace

Potential VOC emissions from the BOP shop are approximatel y 25 tons/year. The concentration of VOCs in the scrubber exhaust are approximately 100 ppb according to the July 17, 2006 Re

Evaluation of RACT submitted by U.S. Steel . Fugitive VOC emissions released through the BOP building and VOC emissions exhausted through the secondary em ission control system baghouse are also quite low. According to the cost analyses conducted in the July 17, 2006 report, control of VOC emissions from these sources is not cost effective. Therefore, RACT for the BOP shop is proper maintenance and operatio n according to good engineering and air pollution control practices at all

times

.

4. 

### Riley Boilers No.1, 2 and 3

VOC controls were reviewed in the previous RACT analysis and the cost effectiveness was more than $100,000 per ton of VOC reduction. This prev ious RACT analysis and the July 17, 2006 Re

Evaluation of RACT concluded that good combustion practices will minimize VOC and these practices constitute RACT for boilers 1, 2 and 3.

RECOMMENDATION:

The analysis for NO X 

### and VOC RACT for the 8

- hour ozon e SIP has demonstrated that any NO X 

### or VOC controls for the sources listed in Table 1 above, are technically or economically infeasible. It is recommended

that the 1

- hour ozone RACT in RACT Plan Approval Order & Agreement No.235, dated December 30, 1996

s till be considered NO X 

### and VOC RACT (8

- hour ozone) for the facility.

### APPENDIX A

Economic Evaluation

### ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

November 9, 2006

SUBJECT: Review of Re

- Evaluation of RACT

U.S. Steel Irvin Plant Camp Hollow Road West Mifflin, Pennsylvania 15122

TO: Sandra L. Etzel Chief Engineer

FROM: Thomas M. Heron Air Qua lity Engineer

INTRODUCTION :

The U.S. Steel Irvin Plant is a major source of NO X 

### and VOC emissions as defined in Section 2101.02 "Definitions", of Article XXI, ACHD, Rules and Regulations, Air Pollution Control and was subject to the County’s 1

- hour ozone SIP. This required the facility to evaluate NO X 

### and VOC sources and take appropriate measures to implement RACT. In addition, these RACT requirements were made a part of Allegheny County’s portion of the Pennsylvania SIP by way of a site

- specific SIP re vision. The NO X 

### and VOC RACT for the facility consisted of a finding of “no NO X 

### or VOC controls were required” due to technical and economic infeasibility.

The County is presently in non

- attainment for the 8

- hour ozone National Ambient Air Quality Standa rd (NAAQS) and according to amendments to 40 CFR 51, Subpart X, effective January 30, 2006, all 1

- hour ozone SIP RACT findings of “no controls are required” must be reevaluated under the rules for the 8

- hour SIP. This document presents the findings of the reevaluation of NO X 

### and VOC RACT for the facility.

SOURCE DESCRIPTION :

The U. S. Steel Irvin Plant is a secondary steel processing facility located in West Mifflin Borough, Allegheny County, Pennsylvania. The Irvin Plant receives steel slabs and perform s one of several finishing processes on the steel slabs. The finishing processes commonly referred to as secondary steel processes, include hot and cold rolling, continuous pickling, annealing, galvanizing, and terne coating. Boilers are also operated at the facility for purposes of supplying process steam requirements.

Facility NOx and VOC sources consist of reheat furnaces, annealing furnaces, galvanizing line furnaces and pots, teme coating (cleaning, etching and plating), process gas flares, steam bo ilers and space heaters.

These sources are identified in Table 1 below.

Sources that are not regulated by another applicable technology or operational requirement in Section

2105 of Article XXI of the Allegheny County Air Pollution Control Regulations, or are not covered by a presumptive RACT requirement contained in Section 2105.06, are included in a case

- by

- case RACT analysis. U.S. Steel Irvin source categories that are included in the analysis, based on this criteria, consist

of :U. S. Steel Edgar Thomson Works 2006 RACT Tech nical Support Document Page 2



### • Five 80

- inch Hot Stri p Mill Reheat furnaces (NOx and VOCs)

**•** Melt Pot for the #1 Galvanizing Line process (NOx and VOCs)

**•** Coke Oven Gas Flares ( VOCs)

**•** Boilers #1 and 2 (NOx and VOCs)

**•** Boilers #3 and 4 and Space Heaters (VOCs)

Sources that are excluded from further RACT analysis, based on presumptive RACT or other applicable RACT control requirements that are already in

- place, consist of the following source categories:

**•** Space heaters (presumptive RACT, Section 2105.06.d, for NOx)

**•** Boilers #3 and #4 (presumptive RACT, Section 2105.0 6.d.2, for NOx)

**•** Coke Oven Gas Flares (presumptive RACT, Section 2105.06.d.6.D, for NOx)

**•** Continuous Teme Line (presumptive RACT, Section 2105.06.d.6.A, for NOx)

**•** Batch, Continuous and Open Coil Annealing Furnaces (presumptive RACT, Section

21 05.06.d.6.A. fo r NOx)

Section 1.1 of the Plan Approval Order and Agreement No. 258 Upon Consent (RACT Order 258), dated December 30, 1996, required that the following process equipment be properly maintained and operated according to good engineering and air pollution c ontrol practices at all times:

1. Boilers 1 through 4 (B001

- B004)

2. 80” Hot Strip Mill Reheat Furnaces 1 through 5 (P001

- P005)

3. No. 1 Continuous Galvanizing Line Preheat Furnace (P012)

4. No. 1 Continuous Galvanizing Line Galvaneal Furnace (P012)

5. No. 2 Continuous Galvanizing Galvalum Preheat Furnace (P013)

6. Terne Line Lead Melt Pot Heater (P014)

7. Open Coil Annealing Furnaces No. 1 through 13 (P010)

8. Continuous Annealing Furnace (P011)

9. HPH Box Annealing Furnaces (P009)

10. No. 1 through 5 Stands Cold Reduction Mill (P008)

11. 80” Hot Strip Mill Rolling Stands

Section 1.2 of RACT Order 258 required an annual adjustment on the combustion processes of the following equipment:

1. 80” Hot Strip Mill Reheat Furnaces No. 1 through No. 5

2. Boiler Nos. 1, 2, 3 & 4

3. Continuous Annealing Furn ace (P011)U. S. Steel Edgar Thomson Works 2006 RACT Tech nical Support Document Page 3



### Table 1

NO X 

### and VOC Sources at the U. S. Steel Irvin Plant

I.D. SOURCE DESCRIPTION CONTROL DEVICE(S) MAXIMUM

CAPACITY FUEL/RAW

MATERIAL Potential Emissions, tpy

NO X VOC

P001

to
P005 80

- Inch Hot Strip Mill Reheat

Furnaces No. 1 to No . 5 None 140 MMBtu/hr,

each Coke Oven Gas

and Natural Gas 197.5,

each 3.9,

each

P008 Cold Reduction Mill (Mill Stands No. 1 to No. 5) Cyclone

Mist

Eliminator 2,500,000 tons/yr Steel Coils and Rolling Oil

Solution 31.3

P009 HPH Batch Annealing Furnaces ( 31 individual furnaces) None 4.9 MMBtu/hr,

each furnace Coke Oven Gas

and Natural Gas 4.0,

each 0.14,

each

P010 Open Coil Annealing

Furnaces No. 1 to No. 9 None 7.2 MMBtu/hr,

each Coke Oven Gas

and Natural Gas 5.8,

each 0.20,

each

P010 Open Coil Annealin g Furnaces No. 10 to No. 13 None 9.0 MMBtu/hr,

each Coke Oven Gas

and Natural Gas 7.3,

each 0.25,

each

P010 Open Coil Annealing Furnace

No. 14 None 5.4 MMBtu/hr Coke Oven Gas

and Natural Gas 5.2 0.13

P010 Open Coil Annealing Furnace

Nos. 15 & 16 None 7.4 7 MMBtu/hr,

each Coke Oven Gas

and Natural Gas 1.5,

each 0.19,

each

P011 Continuous Annealing None 45 MMBtu/hr Coke Oven Gas

and Natural Gas 36.3 1.3

P012 No.1 Continuous Galvanizing

Galvaneal Furnace None 18 MMBtu/hr Natural Gas 9.1 0.50

P012 No.1 Con tinuous Galvanizing

Preheat Furnace None 50 MMBtu/hr Natural Gas 25.2 1.4

P013 No. 2 Continuous Galvanizing Galvalum

Preheat Furnace None 18MMBtu/hr Natural Gas 9.1 0.50

P014 Terne Line Lead Melt Pot None 10 MMBtu/hr Natural Gas 5.0 0.28

P015 Coke Oven Gas Flares No. 1

to No.4 None 46 MMBtu/hr,

each Coke Oven Gas 48.2,

each 44.6,

each

P015 Peachtree Coke Oven Gas

Flare None 46 MMBtu/hr Coke Oven Gas 48.2 44.6

B001 Boiler No. 1 None 79.8

MMBtu/hr Coke Oven Gas

and Natural Gas 64.3 2.2

B001 Boiler No. 2 None 84.6

MMBtu/hr Coke Oven Gas

and Natural Gas 68.2 2.34

B003 Boiler No. 3 None 41.6

MMBtu/hr Coke Oven Gas

and Natural Gas 33.5 1.2

B004 Boiler No. 4 None 41.6

MMBtu/hr Coke Oven Gas

and Natural Gas 33.5 1.2U. S. Steel Edgar Thomson Works 2006 RACT Tech nical Support Document Page 4



### NO X 

### RACT ANALYSIS:

1. 80

- Inch Ho t Strip Mill (HSM) Reheat Furnaces

The five HSM Reheat Furnaces are identical and the primary fuel is coke oven gas. The Re

Evaluation of RACT study identified low

- NO X 

### burners (LNBs) as a technically feasible control option

for the HSM Reheat Furnaces. A n SCR system has been used on a slab reheat furnace ; however,

estimated NO X 

### emission reductions have never been achieved and the catalyst degrades very quickly. SNCR systems have not been used in this application ; therefore, SCR and SNCR are not technic ally feasible control applications for the HSM Reheat Furnaces. The cost effectiveness of LNBs, assuming a control efficiency of 25 %, is $6,586 per ton of NO X 

### removed . Based on this cost estimate, LNBs are

not considered RACT for these furnaces.

**2.** No.1 Continuous Galvanizing Line Preheat Furnace

The preheat furnace is used to melt the zinc coating before galvanizing. The furnace is of vertical movement design rated at 50 MMBtu/hr and provides a direct flame impingement on the strip from

240 burners loca ted throughout the furnace. On the reduction side of the furnace the system is operated fuel rich with cold air. According to the Re

- Evaluation of RACT study submitted by U.S.

Steel , SCR and SNCR are control technologies that are amenable to this furnace. Exhaust gases

would have to be preheated before entering the SNCR unit.

LNBs and/or FGR or overfire air were also considered to be technically feasible. Each of the 240 burners would have to be replaced with a burner of similar design; however, due to each burners size,

len gth and flame pattern, vendors were not aware of replacement LNBs that match these specifications. Therefore, LNBs were not considered RACT for the preheat furnace.

The cost effectiveness of installing an SCR or SNCR system to reduce NO X 

### emissions exceede d $14,000 per ton of NO X 

### removed; therefore, these control technologies were not considered RACT for

the N o.1 Continuous Galvanizing Line Preheat Furnace

.

3. Boilers No.1 & 2

Boilers No. 1 and 2 have rated heat input capacities of 79.8 MMBtu/hr and 84.6 M MBtu/hr, respectively. The primary fuel for both boilers is coke oven gas, however, they have the capability of firing natural gas. According to the July 17, 2006 Re

- Evaluation of RACT, the following NO X 

### controls were considered to be technically feasible for Boilers No. 1 and 2:

**•** LNBs,

**•** SCR, and

**•** SNCR

The cost effectiveness of installing low

- NO X 

### burners (LNBs) in these boilers was greater than $3,000 per ton of NO X 

### reduction and the cost effectiveness of installing and operating SCR and SNCR systems in t hese boilers exceeded $4,000 per ton of NO X 

### removed . Based on this cost analysis, LNBs,

SCR and SNCR were not considered to be RACT for these boilers.U. S. Steel Edgar Thomson Works 2006 RACT Tech nical Support Document Page 5



### VOC RACT ANALYSIS

According to the July 17, 2006 Re

- Evaluation of RACT, the potential application of VOC controls for the combustion sources evaluated above would not result in any significant reduction in emissions below the estimated VOC concentration of 30 ppb in the exhaust gases. Therefore, the addition of VOC controls is not

considered RACT for these sources.

RECOMMENDATION:

The analysis for NO X 

### and VOC RACT for the 8

- hour ozone SIP has demonstrated that any NO X 

### or VOC controls for the sources listed in Table 1 above, are technically or economically infeasible. It is recommended

that the 1

- ho ur ozone RACT in RACT Plan Approval Order & Agreement No.258, dated December 30, 1996

still be considered NO X 

### and VOC RACT (8

- hour ozone) for the facility.

### APPENDIX A

Economic Evaluation