DIRECTOR 

Bruce 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 39t11 Street- Bfdg. #7 

Pittsburgh, PA 15201-1891 

Phone: (412) 578-8103 

Fax: (412} 578-8144 

March 9, 2012 

BOARD OF HEALTH 

Lee M.D. 

Chair 

Rev. Ricky V. Burgess 

Donald S. Burke, M.D. 

Joan Oeary, R.N. 

Anthony Ferraro 

James M. Flynn, Jr. 

Edith L Shapira, M.D. 

Ellen C. Stewart, M.D. 

William Youngblood 

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 

reviews 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 review. Other 

files are still marked draft, with some supervisor notes. 

Please contact Jayme Graham at 412-578-8129, jgraham@achd.net, if you have any questions. 

Enclosure 

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 sources case-by-case for applicability to NOx 

RACT. All sources that were subject to, and instituted, a 1-hour RACT plan, were re-evaluated 

as to the adequacy of that plan to the 8-hour RACT requirements. The Department certifies that 

theses sources have an adequate RACT demonstration 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 Emission Standards for Hazardous Air Pollutants for 

Reinforced Plastic Composites Production, 40 CFR 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 16, 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 portion of the Pennsylvania SIP by way of a site specific SIP revision. A RACT review 

for this 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 the 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.

SOURCE 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, in 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 emissions related to the change in EAFs at the 

Allegheny Ludlum Brackenridge Plant:

SOURCE RATING 

(tons/heat) CONTROLS

MAXIMUM POTENTIAL 

EMISSIONS1 (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 

conversion 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 catalyst occurred. However, the low temperature of the exhaust 

gas (under 200° F) would not allow the chemical reaction needed to convert NOx to N2 to 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 Oxidation
3

These control methods differ primarily in the temperatures 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 ignition 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 large 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 is

technically infeasible.

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. Such temperature would be greater 

than that of a catalytic oxidizer. This temperature would destroy the bags in the baghouse. 

Therefore, a thermal oxidizer is technically infeasible at this location.

A thermal oxidizer could conceivably 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 hoods to their respective baghouses and in 

the duct from each EAF to their baghouses. 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 per 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 = 401,100 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 removed
4

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 catalytic oxidizer has ever been used to control VOC emissions from EAFs 

per the RACT/BACT/LAER Clearing House.

RECOMMENDATION:

The analyses for NOX and VOC RACT for the 8-hour ozone SIP has demonstrated that 

any NOX or VOC controls for the sources listed 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.260, 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 NOX RACT Submittal

Ashland Inc.

2650 Neville Road

Pittsburgh, PA 15225

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 NOX and VOC emissions as defined in §2101.20 of Article 

XXI. This required Ashland to evaluate NOX 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 Pennsylvania SIP by way of a site specific SIP revision. A RACT order for this 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-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 NOX 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-ethyl 

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 a 
Ashland Inc. (#0037)

2006 RACT Review

2

RACT update (see correspondence dated June 23, 2006). The closure of this operation resulted in the 

facility’s potential-to-emit (PTE) of VOC dropping below the major source threshold. Therefore, a 

review of VOC RACT is not required.

In 2006, the facility consists of the following NOX emission sources:

SOURCE RATING 

(MMBtu/hr) FUEL CONTROLS

MAXIMUM POTENTIAL 

NOX EMISSIONS1 (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 NOX. The limit on fuel use is an enforceable permit 

condition, and results in the facility being a synthetic minor source of NOX. Therefore, a review of NOX

RACT is not required.

RECOMMENDATION:

The analysis for NOX 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 NOX. It is recommended that the 1-hour ozone 

RACT in RACT Plan Approval Order & Agreement No. 227, dated December 30, 1996 still be 

considered NOX 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 NOX RACT Submittal

Bay Valley Foods (formerly Del Monte Corporation)

1075 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 NOX emissions as defined in §2101.20 of Article XXI. This 

requires Bay Valley to evaluate NOX 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 this facility was originally 

developed in 1993, and was amended in 2005. The 1996 RACT order (#211) was submitted under Heinz 

USA; the 2005 and 2006 RACT submittals, as well as Title V Operating Permit #0079 were submitted 

under Del Monte Corporation. This review discusses any changes 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 NOX 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. Four 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 (PM10), Nitrogen Oxides (NOX), Sulfur Oxides (SOX), Carbon Monoxide 

(CO), and Hydrochloric Acid (HCl).

The facility consists of the following NOX emission sources:
Bay Valley Foods (#0079)

2006 RACT Review

2

SOURCE RATING 

(MMBtu/hr) FUEL CONTROLS

MAXIMUM POTENTIAL 

NOX EMISSIONS1 (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 NOX burners; 

FGR 0.10 78

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

NOX 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 NOX 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 NOX 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 NOX 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 NOX, not fuel NOX, is the primary cause of NOX emissions from these boilers. Therefore lower 

nitrogen content in the fuel will not result in measurably lower NOX 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 NOX emissions (such as natural gas) is technically feasible, although it 

would entail upgrading existing natural gas burners to low-NOX burners and installing gas burners on 

Boiler #2.

Neglecting the cost of changing to all low-NOX burners, the cost of fuel switching is based on the 

following:

Cost of coal = $62/ton (based on 2006 values)

Heating value = 13,059 Btu/lb = 26.12 MMBtu/ton

Cost of coal = $2.37/MMBtu

Cost of nat. gas = $8.24/mcf (based on 2006 values)

Heating value = 1,045 Btu/scf

Cost of nat. gas = $7.89/MMBtu
Bay Valley Foods (#0079)

2006 RACT Review

4

Gas NOX emissions = 50 lbs/mmcf = 0.048 lb/MMBtu (from AP-42, §1.4, for low-NOX burners)

Cost of NOX reduction = (Δ cost $/MMBtu) ÷ (Δ emissions lbs/MMBtu)

For Boilers #1 & #2:

Cost of NOX reduction = (7.89 – 2.37) $/MMBtu ÷ (0.45 – 0.048) lbs/MMBtu

= $13.95/lb = $27,910/ton of NOX controlled

For Boilers #3 & #4:

Cost of NOX reduction = (7.89 – 2.37) $/MMBtu ÷ (0.64 – 0.048) lbs/MMBtu

= $9.32/lb = $18,650/ton of NOX 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-NOX burners.

RECOMMENDATION:

The analysis for NOX RACT for the 8-hour ozone SIP has demonstrated that any NOX controls for the 

sources listed in the emission source table 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 NOX RACT (8-hour ozone) for the facility.
ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

January 25, 2007

SUBJECT: Review of 8-hour Ozone NOX RACT Submittal

Bellefield Boiler Plant

4400 Forbes Avenue

Pittsburgh, Pennsylvania 15213-4080

TO: Sandra L. Etzel

Chief Engineer

FROM: JoAnn Truchan

Air Quality Engineer

INTRODUCTION:

Bellefield Boiler (Title V Operating Permit No.0047a) is a major source of NOX 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 NOX 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 NOX 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 (NOX), and a minor source of volatile organic compounds (VOCs) as 

defined in §2101.20 of Article XXI.

The facility consists of the following NOX emission sources:

Make/Model NOX 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 MMBtu/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 tpy
Make/Model NOX Control 

Device(s)

Maximum

Capacity Fuel

Maximum 

Potential 

Emissions

Boiler #7 IBW – WM 1500 Low NOX

Burners / FGR

188 

MMBtu/hr

Natural Gas/ No. 2 

Fuel Oil 65 tpy

Boiler #8 Nebraska (rental unit) Low NOX

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 NOX 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.

NOX

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 No.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 NOX emissions. Boilers No.6, No.7, and No.8 are natural gasfired boilers 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 the 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 on Boiler No. 7; and

• Recordkeeping necessary to demonstrate compliance with the RACT requirements.

NOX 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 Department, 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 NOX Control technologies were considered for coal-fired boilers No.1, No.3, & No.5 and were found to 

be technically feasible. However, all were found to be not economically feasible.
1. Selective Non-Catalytic Reduction (SNCR) – this technology involves post combustion removal of NOX with 

ammonia 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. 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). Furthermore, 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 NOX with a 

catalytic reactor and ammonia 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 avoid 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 NO2 by contacting it with an 

oxidizing agent such as ClO2. 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 NOX Burners / Flue Gas Recirculation (FGR) – this technology consists of 

replacing the burners on boilers No.1, No.3, & No.5. It is estimated that replacing the conventional gas burners 

with low-NOX burners could result in a 40-50% reduction in NOX. Based on the modifications required to 

piping, electrical systems, instrumentation, and controls (per the burner manufacturer’s recommendation), as 

well as modifications to the boiler itself, the costs make the option unfeasible.

5. Fuel Switching – NOX reductions can be achieved by using boilers No.6 and No.7 (with FGR and a low-NOX

burner, respectively) and boiler No.8 (with FGR and low-NOX burners) instead of burning coal in boilers No.1, 

No.3, & No.5. This would result in a 50-60% reduction of NOX. 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-NOX burners. The capital costs associated with upgrading the burners make the alternative option 

economically unfeasible.

Ranking of Technically Feasible Control Options:

Control Technology

Potential Controlled 

NOX 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 NOX Burners 0.070 0.140 0.070

3 Low NOX Burners Only 0.263 0.169 0.200 40%

4 Low NOX 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 boilers 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 NOX Burners Only Coal, Fuel Oil or N.G. 6,546

Low NOX Burners (larger capacity) Coal, Fuel Oil or N.G. 8,029

Low NOX 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 NOX

Burners Natural Gas 1,976

RECOMMENDATION:

The analysis for NOX RACT for the 8-hour ozone SIP has demonstrated that all NOX 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 NOX RACT 

(8-hour ozone) for the facility.
ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

September 27, 2006

SUBJECT: Review of 8-hour Ozone NOX RACT 

Orion Power MidWest, L.P.

Cheswick Power Station – Auxiliary Boiler

Pittsburgh and Porter Street

Springdale, PA 15144

TO: Sandra L. Etzel

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 NOX

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 NOX RACT for the 

facility (Main boiler and auxiliary boiler) 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 NOX RACT for the auxiliary boiler consisted of a finding of “no NOX 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 NOX RACT for the auxiliary boiler.

SOURCE DESCRIPTION:

The Orion Power MidWest, L.P., Cheswick 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 auxiliary 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 (NOX) 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

Aux. Boiler Riley Stoker External 

Combustion Boiler

160 

MMBtu/hr None No. 2 fuel oil 

37.54 

tons/year 

NOx 
POTENTIAL EMISSIONS:

The NOX emission limit above for the auxiliary boiler set forth in Title V permit 0054, dated November 9, 1998 is the 

potential NOX emissions including all enforceable controls and restrictions for the unit.

NOX RACT ANALYSIS:

Auxiliary Boiler:

Orion’s RACT analysis, submitted in correspondence from Duquesne Light Co. (previous owner) to the Department, 

dated November 1, 1994 was conducted with guidance from USEPA “Alternative Control Techniques Document – NOX

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 NOX burners are 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 NOX

control efficiency as per the ACT document is 50%.

1. Low NOX Burners – approximately 50% reduction – per unit basis

Ranking of Technically Feasible Control Options:

Control Technology

NOX – Oil or N.G. 

Potential Controlled 

Emission Rate

(lbs/MMBtu)

1 Low NOX With FGR 0.086

Uncontrolled emission rate = 0.1714 lbs/MMBtu of NOX as per AP-42, 1.3, 9/98.

Uncontrolled tons/yr NOX = 0.1714 lbs/MMBtu x 160 MMBtu/hr x 8760 hrs/yr x 0.3125 capacity factor/2000 

= 37.54 tons/yr NOX

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 boiler as per Orion’s Title V permit application 0054. 

Existing controls:

The subject boilers presently have no controls for NOX emissions. 

Summary of Cost Effectiveness1:

Control Technology Fuel Type $/Ton Removed in 

91 Dollars

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

1

USEPA “Alternative Control Techniques Document – NOX 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 obvious that the $/ton NOX removed would 

still be over the present threshold of approximately $1,500/ton NOX 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 NOX RACT for the 8-hour ozone SIP has demonstrated that any NOX controls for the auxiliary boiler 

are technically or economically infeasible using 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 no controls and a 12-month rolling limit on Btu input of 

438,000 MMBtu be considered NOX 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 NOX RACT Submittal

Cheswick Power Station – Main Boiler

Pittsburgh & Porter Streets

Springdale, PA 15144

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 boiler 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 Power Station was the operation of the Low NOx Concentric Firing System (LNCFS) Level II. 

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

Level II 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 15,2001)

• 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 along with LNCFS 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 Resins, Inc. is a major source of VOC emissions as defined in §2101.20 of Article XXI.

This requires an evaluation of VOC RACT for the facility and implementation of appropriate measures as 

necessary. The previous 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 this facility was 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 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:

Eastman Chemical Resins, 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/hr 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 (new 10,000 

gallon reactor) and new tank T-1203 

for toluene.

Refrigerated water on 

selected vent condensers 

and 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 Refrigerated 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

0058-I010 10/09/2002 Modification to the V-8 unit for ink 

oil resins.

No changes in control 

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 Emissions from TSD for IPs.

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

"1.3. .... Hercules shall complete installation of refrigerated condenser systems, for the purpose 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 Wastewater 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 considered 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, during 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 Processreplaced the existing J-411 condenser system, 

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

considerably 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 replacement 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). This option

was not chosen because the cost of installing and maintaining two systems was prohibitive. The major reason 

for this is the large quantities 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 this 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 process 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 subject 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 be 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 (installation permit No. I009) with a total control efficiency of 95% gave a reduction of VOC emissions 

for 0.43 tons/yr and considered VOC BACT for these tanks, along with monitoring, recordkeeping and 

reporting requirements.

All VOC controls beyond existing 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 Sources

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 facility and because the analyses for VOC have

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 Approval Order & 

Agreement 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 NOX 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 NOX 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 NOX

Reasonably Available Control Technology (RACT) for the facility and take the appropriate 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 NOX RACT for the facility consisted of a finding of “no NOX 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 NOX RACT for the facility.

SOURCE DESCRIPTION:

The General Electric - Bridgeville 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 orders. 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 finishing 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 (NOx), particulate matter, particulate matter less than 10 microns in diameter (PM10) and hazardous air 

pollutants (HAPs), and a minor source of carbon monoxide (CO), sulfur dioxide (SO2), and volatile organic compounds 

(VOCs), as defined 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/yr)

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 Unit 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 Simplex 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 MMBTU/hr each None

Natural Gas 

(oil backup)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 NOX emissions including 

all enforceable controls and restrictions for those units regardless of combustion of fuel oil or 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

NOX 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 actual 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

• Burner 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 NOX Control technologies are not demonstrated technologies in the pressed/blown glass sector, and 

therefore were found 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 – all of the 

furnaces are 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 length 
would increase the deterioration rate in 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 pollutants 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 proven 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 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.

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 Specifications
The 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 GEBridgeville.

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 Emission 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 6th 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 performed 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-firing $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 2,802
RACT 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 NOX RACT for the 8-hour ozone SIP has demonstrated that any additional NOX 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 accordance 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 NOX 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 NOX 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 document 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 place for Furnace 3 and one was submitted for Furnace 

on October 7, 2004. Approximately one year later (November 18, 2005) the facility was bought by Port 

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

On September 15, 2006, the Department received an Installation Permit application to “restart” Furnace 2. 

However, Furnace 2 ceased to exist 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 NOX emission sources: 

SOURCE 1

RATING 

(tons 

glass/day) 

FUEL CONTROLS

MAXIMUM POTENTIAL 

NOX EMISSIONS1 (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 NOX and VOC RACT for the 8-hour ozone SIP indicates the facility is no longer subject 

to RACT since the operating furnace has installed BACT and the remaining furnaces are currently 

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

Furnace 4 before October 2009 would 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 NOX 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 NOX 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 NOX

Reasonably Available Control Technology (RACT) for the facility and take the appropriate 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 NOX RACT for the facility consisted of a finding of “no NOX 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 NOX RACT for the Guardian facility.

SOURCE DESCRIPTION:

The Guardian facility 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 glassmelting furnace capable of producing between 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 “Batch 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 through 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 (NOx), sulfur dioxide (SO2), particulate matter (PM), particulate matter 

less than 10 microns in diameter (PM10), 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: NOx Emission Source

Emission Unit Facility ID Existing NOx Reduction 

Technology

Other Emission 

Controls Fuels

Melting Furnace S001

Electric Boost; OxyFiring; Low-NOx Burners; 

Cullet Recycling; 

Minimizing Nitrates; 

Minimizing Operating 

Temperature

Dry Lime Scrubber 

and Electrostatic 

Precipitator

Natural 

Gas; Oxyfuel

POTENTIAL EMISSIONS:

The RACT emission limits 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 NOX emissions including all enforceable controls and 

restrictions for those units regardless of combustion of fuel oil or natural gas. 

Table 2: Existing NOx 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

NOX RACT ANALYSIS:

Guardian’s RACT analysis, submitted 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, the 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 NOx 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 NOX Control technologies are not demonstrated technologies in the flat glass sector, and therefore were 

found 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 natural 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 NOx emissions, it 

an increase 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 systems 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 bisulfate. 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 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 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. Sitespecific 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 minimizing 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 

NOx 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 

charging end of the melting furnace.

3. Electric Boost – A 3-KW capacity electric boost system was installed in 1999. The power level is varied 
depending on the type of glass being manufactured and the required temperature.

4. Minimizing Secondary Air – Positive pressure 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 maintain as low of a furnace temperature as possible 

while still producing a high-quality product.

6. Minimizing nitrates in batches – When soda niter (NaNO3) is added to the batches, it results in increased NO2

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 possible 

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

Table 3: Summary of Baseline Levels of NOx Control

NOx Emission Unit Baseline Level of NOx Control

S001: Melting Furnace

Oxy-firing

Low-NOx burners

Minimize excess air 

Electric 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 

furnace:

Table 4: Summary of Technologically Feasible NOx Controls

NOx Emission Unit NOx Control Technology 

Beyond Baseline

NOx 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 NOX RACT for the 8-hour ozone SIP using EPA’s Cost Control Manual, the ACT document for glass 

melting furnaces and the preamble to the amendments to 40 CFR 51 for the 8-hour ozone SIP has demonstrated that any 

additional technically or economically feasible NOX 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 15025

TO: Sandra L. Etzel

Chief Engineer

FROM: JoAnn Truchan

Air Quality Engineer

INTRODUCTION:

Koppers Inc. (Title V Operating Permit No. 0029) 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 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 efficiency of at least 95% for all VOCs 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 service 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 thermal 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 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:

Koppers Inc., Clairton Tar Plant, located at 300 North State Street, Clairton, 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 solidifying 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 (NOX), as defined 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 

fugitives

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

Crude 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; GasBlanketing Gas 0.29

TI Heater, 2F-2A n/a 8.15 MMBtu/hr Natural Gas; GasBlanketing Gas 0.23

Hot Oil Heater, 1F-2C n/a 2.89 MMBtu/hr Natural Gas; GasBlanketing Gas 0.08

Prill Oil Heater n/a 2.50 MMBtu/hr Natural Gas; GasBlanketing Gas 0.07

Secondary Heater, 2F-1C n/a 5.68 MMBtu/hr Natural Gas; GasBlanketing Gas 0.16

Spare Hot Oil Heater, 

1F-1C n/a 5.68 MMBtu/hr Natural Gas; GasBlanketing 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; gasblanketing on tarrefining process tanks

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, ductwork 

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 Oxidation

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 centrifuge 

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 

feasible.

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 easily 

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 

adsorption 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 processes, 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, 

centrifuge, 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 being 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 Options:

Control Technology

Uncontrolled 

Emissions

(tpy)

VOCs 

Removed 

(tpy)

Potential 

Controlled 

Emissions 

(tpy)

Overall 

Efficiency1

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 controls:

• 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 

must 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.223, dated August 27, 1996, Koppers extend the LDAR program to equipment not 

currently 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)

Description Number of Equipment Type VOC Emission Factors1

(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 0.00463 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

Description

VOC 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 0.486 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 VOC Emission Factors2

(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 0.00024 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

VOC Potential Emissions

(ton/year)

P V PRV OEL FL Total

Crude Tar 0.052 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 Emissions 

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

Maintenance 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 LDAR 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 reduction = 18.26 tons/yr

Cost ($/ton reduced) = $1,031
Appendix B

Cost Analysis to Implement Submerged Fill on Product Loading

Temp. Molec. 

Weight

Vapor 

Pressure

Throughput

VOC Emission 

Factor1

VOC Potential 

Emissions Reduction

Splash

lb/Mgal

Submerg.

lb/Mgal

Splash

ton/yr

Submerg.

Commodity ton/yr °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 0.144 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 loading.
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 capital 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

Operating 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

Cost ($/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: Helen 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 Pollution 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 

previous 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 of 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. Source 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 coat 

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 paints 1.11

P006 Whirlpool assembly and 

protective coating

507 gallons-glue, 

1,006 gallonscoating

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 Laurel 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 the 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 Emission 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 

Industries”;

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 worker 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 controls 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 this 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 been used to treat styrene emissions 
Laurel 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 Bed 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)

Each 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 technologies 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 Styrene 

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 things) 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 Thermatrix 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 cost 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 and 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 reflecting “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 Fiberglass 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 (prior 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 

(theoretically) 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 “economic 

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 any 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 & NOX 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 NOX & 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 NOX & 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 sitespecific SIP revision. The NOX & 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-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:

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

1496 in the County of Allegheny. 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 products. 
The facility consists of the following VOC emission sources:

Process Description Capacity1 Controls

Maximum

Potential/Allowable

Emissions

Units 15, 16, 

18, 19 & 43

Heat Polymerization 

Units Confidential Thermal Oxidizer 4.94 tons/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 Confidential 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-cooled 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 47.5 

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 106

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 following NOX 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

Boiler 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 Oxidizer 18.9 MMBtu/Hr NA 9.74 tons/yr

POTENTIAL EMISSIONS:

The allowable VOC and NOX 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 NOX 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.

NOX 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 NOX RACT 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 MMBtu/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 manufacturer’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 are 
considered NOX RACT for the 8-hour ozone SIP.

Emergency Generators:

The facility’s seven emergency 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 Performance 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 scrubbing 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 98% 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 equipment 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 SIP 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 effective 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. These 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 analysis 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 maintenance 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 the 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 potential 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 Cost $ $/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% 436,636 8,790
See 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 concentration 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 

Efficiency

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 12,458

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

Carbon 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 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.
Packaging Center No.3:

The cost effectiveness of technically feasible add-on controls at a VOC PTE 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

Catalytic 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 

maintenance 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 Removed

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 add-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 operation 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 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 the 1-hour ozone RACT in 

RACT Plan Approval Order & Agreement No.230, dated December 13, 1996 still be considered 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 NOX RACT Submittal

NRG Energy Center Pittsburgh, LLC

111 South Commons Avenue

Pittsburgh, PA 15212

Allegheny County

Operating Permit No.0022

TO: Sandra 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-cell 30,000 gpm cooling tower and a 2-cell 7,200 gpm cooling 

tower. The facility is a major source of nitrogen oxides (NOX) and minor source of volatile organic 

compounds (VOCs) as defined in section 2101.20 of Article XXI.

NOX 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 date: 2000

Maximum Input Rating: 131.1 MMBtu/hr

Installation date: 1965
Generator 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 Rating: 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 only

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 NOX

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: NOX Emission limits

Boiler NOX lbs/MMBtu NOX 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: Natural 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: NOX emission tests every two years on boiler no.3.

Order 1.5: Records and calculations shall be kept in order to determine 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 boiler.

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 of 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 NOX

emissions including all enforceable controls and restrictions for those units regardless of combustion of fuel 

oil or natural gas. Potential emissions for boiler no.4 are set forth in installation permit 

NOX

EMISSION 

UNIT

N.G. NO. 2 FUEL OIL

BASIS LBS/MM

BTU TPY LBS/MMBTU TPY

No.1 0.145 54.2 0.145 54.2 RACT Order 

No.220

No.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 NOX 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 NOX 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 

NOX RACT for the facility consisted of a finding of “no NOX controls were required” due to technical 
and economic infeasibility. 

The County is presently in non-attainment for the 8-hour ozone standard 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 NOX RACT for the facility.

NOX 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.

In evaluating the costs of retrofit NOX 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 NOX 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 NOX. 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 uses an oxidation-absorption- regeneration cycle across multiple 

catalyst beds to achieve back-end (tail-pipe) reductions in NOX.. 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 NOX

with a catalytic reactor and ammonia injection. SCR technology has shown difficulty in 

achieving consistent NOX 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 NOX Control technologies were found to be available for NG-fired packaged water tube 

boilers.

1. Low NOX Burners – 0.035 to 0.05 lbs/MMBtu – per unit basis

2. Flue Gas Recirculation (FGR) – per unit basis

3. Low NOX Burners with Flue Gas Recirculation – per unit basis 
Ranking of Technically Feasible Control Options:

Control Technology NOX – Oil lbs/MMBtu NOX – N.G. lbs/MMBtu

1 Low NOX With FGR 0.057 0.029

2 Low NOX Burners Only 0.086 0.058

Lbs/MMBtu for low NOX 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 NOX

emissions firing no.2 fuel oil which equates to an 80% reduction in NOX emissions from uncontrolled.

Existing controls:

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

trim which reduces the formation of NOX by limiting the amount of O2 available for combustion.

Summary of Cost Effectiveness:

Control Technology Fuel Type $/Ton Removed

Low NOX With FGR Natural Gas 3,800

Low NOX With FGR Natural Gas 5,300

Low NOX Burners Only No.2 Fuel Oil 2,900

Low NOX Burners Only No.2 Fuel Oil 4,600

The above $/ton removed figures were based on an annual uncontrolled NOX 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 NOX burners and annual combustion 

“tune-ups” are NOX 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. NOX RACT will be the proper operation and 

maintenance of the units.

RECOMMENDATIONS:

The analysis for NOX RACT for the 8-hour ozone SIP has demonstrated that any NOX 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 NOX RACT for the facility.

 

 

 
APPENDIX A

Economic Evaluation
ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

October 4, 2006

SUBJECT: Review of 8-hour Ozone NOX & VOC RACT Submittal

Orion Power MidWest, L.P.

Brunot Island Power Plant

Combustion Turbines 1A, 1B & 1C

Brunot Island, Pittsburgh, PA

TO: Sandra 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 NOX

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 

NOX 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 VOC and NOX RACT for combustion turbines 1A, 1B & 1C at the facility consisted of a finding of “no 

VOC or NOX 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 VOC and NOX RACT for combustion turbines 1A, 1B & 1C at 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 oilfired simple cycle combustion turbines which are the subject of this analysis. The simple cycle combustion turbines 

have no emission controls for NOX or VOC control. 

The facility is a major source of nitrogen oxides (NOX) 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

Potential

VOC Emissions

1A Combustion Turbine in 

Simple Cycle Mode

22 MW - 300 

x 106 btu/hr None No.2 Fuel Oil 275.2 14.54

1B Combustion Turbine in 

Simple Cycle Mode

22 MW - 300 

x 106 btu/hr None No.2 Fuel Oil 275.2 14.54

1C Combustion Turbine in 

Simple Cycle Mode

22 MW - 300 

x 106 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 NOX and VOC emissions including all enforceable controls and restrictions for those units regardless of 

combustion of fuel oil or natural gas. 

NOX RACT ANALYSIS:

Combustion Turbines 1A, 1B and 1C:

The 1-hour Ozone SIP RACT analysis, conducted on December 5, 1995 was reevaluated by the Department with 

guidance from EPA-453/R-93-007, "Alternative Control Techniques Document-- NOx 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 NOX 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-- NOx

Emissions from Stationary Gas Turbines", January 1993

Ranking of Technically Feasible Control Options:

Control Technology

NOX – Oil or N.G. 

Potential Controlled 

Emission Rate 1990 $

(tons/yr)

1 Wet injection at36% annual 

capacity factor 84.76

Uncontrolled emission rate = 275.2 tons/yr of NOX at a 36% annual capacity factor

Existing controls:

The subject turbines presently have no controls for NOX 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 NOX emission rate of 275.2 tons/yr of NOX at a 36% annual 

capacity factor. 

NOX 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 & NOX RACT for the 8-hour ozone SIP has demonstrated that any NOX 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. It is recommended that the 1-hour ozone VOC & 

NOX RACT in RACT Plan Approval Order & Agreement No.214, dated May 20, 1996 still be considered VOC & NOX

RACT (8-hour ozone) for the facility.
APPENDIX A

NOX ECONOMIC ANALYSES
ECONOMIC ANALYSIS FOR UNITS 1A, 1B AND 1C IN SSC MODE:

NOx - 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 recovery (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 - $174,000 - $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 NOx 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 NOX 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 NOX 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 NOX 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 NOX RACT for the facility 

consisted of a finding of “no NOX 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 NOX RACT for the facility.

SOURCE DESCRIPTION:

The Pittsburgh Allegheny County Thermal, Ltd., Stanwix Street facility is a commercial steam 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, which 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 (NOX) 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 

Type: “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 NOX emissions including all enforceable controls and restrictions for those units regardless of combustion of 

fuel oil or natural gas. 

NOX

EMISSION 

UNIT

N.G. NO. 2 FUEL OIL

LBS/MM BASIS

BTU TPY LBS/MMBTU 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 dated 

November 9, 1998

NOX 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 NOX 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 NOX. 

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 uses an oxidation-absorption- regeneration cycle across multiple catalyst beds to 

achieve back-end (tail-pipe) reductions in NOX.. 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 boiler.

3. Selective Catalytic Reduction (SCR) – this technology involves post combustion removal of NOX with a 

catalytic reactor and ammonia injection. SCR technology has shown difficulty in achieving consistent NOX

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-Catalytic Reduction (SNCR) – this technology involves post combustion removal of NOX with 
ammonia 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 NOX control. In addition the loading on 

the different boilers is highly variable increasing the problems with proper injection and adequate residence 

time.

The following NOX 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 NOX Burners – approximately 50% reduction – per unit basis

2. Flue Gas Recirculation (FGR) – approximately 40% reduction - per unit basis

3. Low NOX Burners with Flue Gas Recirculation – approximately 55% reduction per unit basis 

Control technology efficiencies are taken from USEPA “Alternative Control Techniques Document – NOX Emissions 

from Industrial/Commercial/Institutional (ICI) Boilers” (EPA-453 R-94-022).

Ranking of Technically Feasible Control Options:

Control Technology

NOX – Oil or N.G. 

Potential Controlled 

lbs/MMBtu

1 Low NOX With FGR 0.10

2 Low NOX Burners Only 0.11

3 FGR Only 0.13

Uncontrolled emission rate = 0.22 lbs/MMBtu of NOX

Existing controls:

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

reduces the formation of NOX by limiting the amount of O2 available for combustion.

Summary of Cost Effectiveness:

Control Technology Fuel Type $/Ton Removed

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

Low NOX Burners Only No.2 Fuel Oil or N.G. 12,563

FGR Only No.2 Fuel Oil or N.G. 24,068

The cost analysis applied the maximum allowable NOX emission rate of 0.22 lbs/MMBtu to the maximum heat 

input for oil firing of 144 MMBtu/hr for annual potential uncontrolled NOX emissions of 138.8 tons/yr. The 

allowable uncontrolled annual NOX 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 NOX RACT for the 8-hour ozone SIP has demonstrated that any NOX controls for boilers no.1 through 

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 ozone 
RACT in RACT Plan Approval Order & Agreement No.265, dated November 9, 1998 still be considered NOX RACT 

(8-hour ozone) for the facility.
APPENDIX A

Economic Evaluation
ALLEGHENY COUNTY HEALTH DEPARTMENT

AIR QUALITY PROGRAM

February 12, 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., Springdale 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 (VOCs) and a minor source of 

nitrogen oxides (NOX) as defined in §2101.20 of Article XXI.

The facility consists of the following 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 Reactors

• Batch Resin Strippers

• Thin Film Evaporator

• Storage Tanks

• Laboratory-scale Paint Spray Booths
Source Description Control Device(s) Fuel / Raw Material Maximum Potential 

Emissions

Paint Manufacturing 

(controlled)

REECO Thermal 

Oxidizer resins, solvents, 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 

experimental 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 various 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 Development 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 that 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 

the 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-fall 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 according 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 spot 

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, dated 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 place at the facility, the following VOC Control technologies were 

considered:

• existing process heaters

• existing thermal oxidizer

• thermal oxidation

• catalytic oxidation

• volume concentrators

• flares

• emerging technologies

• adsorption

• scrubbing

• condensation

• biofiltration

• 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 VOC 

sources

Volume Concentrators Flowrates aren’t high enough

Flares Resultant noise, smoke, heat radiation, and light

Emerging VOC Control Technologies Not yet proven reliable for industrial-scale applications

Adsorption Not effective due to varying mixture 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 emissions 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-Control 

Emissions 

(tpy)

Emission 

Reductions1

(tpy)

Removal 

Efficiency2

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 Plan 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 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 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-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 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 includes glass lined, high-pressure, 

tubular high-pressure, alloy high-pressure and special alloy reactors, 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 compounds (VOCs) and a minor source of nitrogen oxides (NOX) 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 NOX emissions including all enforceable controls and restrictions 

for those units. 

NOX RACT ANALYSIS:

Pressure Chemical Company manufactures a variety of chemicals 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 changes 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 constantly 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. EPA's OAQPS Cost Manual (reference no.1), Control Technologies for Hazardous 

Air Pollutants, EPA June 1991 (reference no.2) and actual cost data. 

The annual potential to emit as per the Title V permit for the facility 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 emissions go through the High bay Scrubber, which equals 152 ppmV. 

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 effective 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 would 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 achieve VOC reduction in the 90% plus range which is 

not feasible. In addition a flare in the area of the facility 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 Options 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 using EPA’s Cost Control Manual, Control Technologies for 

Hazardous Air Pollutants, EPA June 1991and 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.261, dated June 11, 

1997 still be considered VOC RACT (8-hour ozone) for the facility. 
 

APPENDIX A 

Economic Evaluation 
ALLEGHENY 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 2006 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 of NOx and VOC emissions as defined in §2101.20 of Article XXI. 

This requires Shenango to evaluate NOX 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 Pennsylvania SIP by way of a site specific SIP revision. A RACT review for this facility was 

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 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 NOX and 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.

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 was the replacement of four (4) 

boilers by four (4) more efficient Low NOx Burner boilers.
2

The following table lists the NOx and VOC emissions related to the change in boilers at the Shenango 

Incorporated Neville Island Plant:

SOURCE

RATED

CAPACITY

(MMBTU/HR)

CONTROLS

MAXIMUM POTENTIAL 

EMISSIONS1 (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. 233, 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 NOx 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 operating conditions of flue gas temperature (1600o

F-1900oF), 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 boilers 

(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 500o

F -750oF, or 

600o

F -950OF, 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. 

Adequate ammonia mixing with the flue gas and proper ammonia flow control are critical 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 have 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 applications to combustion units firing fuel oil include 

poisoning and erosion of the catalyst by fly ash and SO3 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 marginally technology 

feasible for these boilers.

 Low NOx Burners with Flue Gas Recirculation (LNB + FGR): LNBs are specially designed 

burners which employ a variety of principles, including low excess air, off-stoichiometric or 

staged combustion, and FGR in 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 was selected as BACT 

for NOx emission 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 managed 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

NOX: 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 19 tons VOCs/yr, 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 NOx RACT for this emission unit.

NOx & VOC RACT- Quench Tower:

NOx: At the potential to emit of 1.77 tons NOx/yr no control technologies are technically or 

economically feasible. 

VOCs: At the potential to emit of 14.95 tons VOCs/yr 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 NOx RACT for this emission unit.

NOx & VOC RACT-Emission Units with an Existing Nitrogen Blanketing System:

NOx: There are no NOx 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 on the subject units.

VOC RACT will be proper operation and maintenance of the N2 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 NOx 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 pollution control practices wi1l 

be considered VOC RACT for these emission units.
5

RECOMMENDATION:

The analysis for NOx RACT has demonstrated that the use of Low NOx 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 been installed on the majority of the VOC sources associated with the byproduct plant. It is recommended that proper 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 NOx 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 NOX 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 NOX 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 NOX

and VOC RACT for the facility consisted of a finding of “no NOX 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 document presents the findings of the reevaluation of NOX 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 sulfur. 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 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 in Section 2105.06, are included in a case-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, traveling 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 NOX and VOC emission sources at the Clairton Works:
Table 1

NOX and VOC Sources at the U. S. Steel Clairton Works

SOURCE MAKE/MODEL RATING CONTROLS FUEL

Maximum Potential

Emissions, tpy

NOX VOC

Coke Batteries 

1-3 and 7-9, 

Underfire 

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 

stack

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

Coke 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 Wallfired229 MMBtu/hr, 

each

COG & 

NG 525, each 6.34, each

Boilers T1 & 

T2

Package Wallfired156 MMBtu/hr, 

each

COG & 

NG 358, each 4.32, each

Desulfurization 

Plant

SCOT Plant 

Incinerator 2.6 38.9

Coke ByProducts 

Recovery 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 maximum 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 maintained 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 NOX emission limits (lbs/MMBtu and tons/year) for 

Boilers No.1, 2, R1, R2, T1 and T2: 

NOX 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 RACT 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

NOX RACT ANALYSIS:

1. Coke Battery Underfiring

The Re-Evaluation of RACT study identified the following controls as potentially technically feasible 

for coke battery underfiring:

• Low-NOX Burners (LNBs) and Ultra-Low NOX 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 directfired 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 Emission 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. NOX 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, NOX 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 short term NOX emission rate of 0.54 

lbs/MMBtu. Stack testing indicates that these boilers are achieving NOX levels significantly less than 

this limit. 

During the ozone season, operators change the way they fire boilers 1 and 2 to reduce NOX

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 during the ozone season. Since steam 

requirements are less during the ozone season, this is not a problem. NOX 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-Evaluation of RACT submitted by U.S. Steel, the 

NOX 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-NOX burners. Stack testing 

performed in October 2001 and April 2004 indicates NOX 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 

NOX 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 NOX emission rates 

equal to or greater than (not lower than) similar sized natural gas-fired boilers. However, retrofitting 

low-NOX burners in these boilers may not significantly reduce the NOX levels they are currently 

achieving. The July 17, 2006 study did not consider combustion controls (low-NOX burners) to be a 

technically feasible control option; therefore, a cost analysis was not provided. A cost effectiveness 

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 NOX removed. 

4. SCOT Plant Incinerator

Stack testing of the SCOT Plant Incinerator for NOX emissions was conducted in July 2001 and 

December 2004. The average NOX emission rate for both tests was 0.4 lb/hr. Based on these results, 
the addition of controls to further reduce NOX emissions is not required; therefore, RACT is to 

properly 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 oil. 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, including 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 previous RACT analysis and the July 17, 2006 ReEvaluation 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-products 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 

furnaces. 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 reducing 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 sealing 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 regenerator stones is stored in tanks that are controlled by the byproducts 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 NOX and VOC RACT for the 8-hour ozone SIP has demonstrated that any NOX 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 NOX 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

13th 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 NOX 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 NOX 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 NOX

and VOC RACT for the facility consisted of a finding of “no NOX 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 document presents the findings of the reevaluation of NOX 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, scrap 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 lanced 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

(cut / 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 following table lists the NOX and VOC emission sources at the Edgar Thomson Works:

Table 1

NOX and VOC Sources at the U. S. Steel Edgar Thomson Works

SOURCE RATING CONTROLS FUEL

Maximum Potential

Emissions, tpy

NOX VOC

Blast Furnace 

No. 1 Stoves

Approximately 

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 Furnace 

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 NOX 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. NOX Emission factors are: Casthouse Baghouse = 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 NOX emissions from the BOP furnace are based on maximum steel production of 3,000,000 tons/yr and 

maximum coke oven gas and natural gas usage of 500 mmcf/yr and 280 mmcf/yr, respectively. NOX 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

Section 1.2 of RACT Order 235 specified the following NOX emission limits (lbs/MMBtu and tons/year) for 

Riley Boilers No.1, 2 and 3: 

NOX 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

NOX RACT ANALYSIS:

1. Blast Furnaces No. 1 and No. 3 Stoves

The Re-Evaluation of RACT study identified the following controls as potentially technically feasible 

for the blast furnace stoves:

• Low-NOX Burners (LNBs), and

• Ultra-Low NOX Burners (UNLBs)

The primary fuel used for the blast furnace stoves is blast furnace gas. Potential NOX 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 NOX emissions 

(approximately 0.013 lb-NOX/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 the 
U. S. Steel Edgar Thomson Works 2006 RACT Technical Support Document 

Page 4

tap hole 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, NOX emissions from both casthouses, including the NOX 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 NOX and VOC emissions from the casthouses and 

uncontrolled NOX 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 NOX emissions from the BOP scrubber stack:

• SNCR

• SCR

These control methods have not been applied to emissions of NOX from a BOP scrubber stack and 

conditioning the low temperature (approximately 120 oF) 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 efficiency for an SCR system is $182,654 per ton of NOX 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 235 limits each of the three boilers to a short term NOX emission rate of 0.55 

lbs/MMBtu. Stack testing indicates that these boilers are achieving NOX levels significantly less than 

this limit. The primary fuel for these boilers is blast furnace gas and combusting this fuel results in 

very low NOX emissions. Potential NOX 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 blast 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 control practices at 

all times and the short term and annual NOX 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 costprohibitve. 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. Therefore, 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 approximately 25 tons/year. The concentration of 

VOCs in the scrubber exhaust are approximately 100 ppb according to the July 17, 2006 ReEvaluation of RACT submitted by U.S. Steel. Fugitive VOC emissions released through the BOP 

building and VOC emissions exhausted through the secondary emission 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 operation 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 previous RACT analysis and the July 17, 2006 ReEvaluation 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 NOX and VOC RACT for the 8-hour ozone SIP has demonstrated that any NOX 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 

still be considered NOX 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 Quality Engineer

INTRODUCTION:

The U.S. Steel Irvin Plant is a major source of NOX 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 NOX 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 revision. The NOX and VOC RACT 

for the facility consisted of a finding of “no NOX 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 document presents the findings of the reevaluation of NOX 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 performs 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 boilers 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 Technical Support Document 

Page 2

• Five 80-inch Hot Strip 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 2105.06.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. for 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 control 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 Furnace (P011)
U. S. Steel Edgar Thomson Works 2006 RACT Technical Support Document 

Page 3

Table 1

NOX 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

NOX 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 Annealing 

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

7.47 

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 Continuous 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 1.2
U. S. Steel Edgar Thomson Works 2006 RACT Technical Support Document 

Page 4

NOX RACT ANALYSIS:

1. 80- Inch Hot Strip Mill (HSM) Reheat Furnaces

The five HSM Reheat Furnaces are identical and the primary fuel is coke oven gas. The ReEvaluation of RACT study identified low-NOX burners (LNBs) as a technically feasible control option 

for the HSM Reheat Furnaces. An SCR system has been used on a slab reheat furnace; however, 

estimated NOX 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 technically 

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 NOX 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 located 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, 

length 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 NOX emissions exceeded 

$14,000 per ton of NOX removed; therefore, these control technologies were not considered RACT for 

the No.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 MMBtu/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 NOX

controls were considered to be technically feasible for Boilers No. 1 and 2:

• LNBs,

• SCR, and 

• SNCR

The cost effectiveness of installing low-NOX burners (LNBs) in these boilers was greater than $3,000 

per ton of NOX reduction and the cost effectiveness of installing and operating SCR and SNCR 

systems in these boilers exceeded $4,000 per ton of NOX 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 Technical 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 NOX and VOC RACT for the 8-hour ozone SIP has demonstrated that any NOX 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.258, dated December 30, 1996 

still be considered NOX and VOC RACT (8-hour ozone) for the facility.
APPENDIX A

Economic Evaluation