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COMMONWEALTH OF PENNSYLVANIA Department of Environmental Protection

Southwest Regional Office March 8, 2007

SUBJECT: Technical Support Document State Only Operating Permit Elliott Turbomachinery Company, Inc. Jeanette Facility Westmoreland County

TO: Air Quality Permit File OP-65-00051

FROM:

THROUGH:

Sharene D. Shealey lf;ffZ.___ Air Quality Engineer ./Y / Air Quality Control ~

Barbara R. Hatch, P.E. Chief, Facilities Permitti Air Quality Control Southwest Regional Office

BACKGROUND

AND:

()';frrl Mark A. Wayner, P.E. Regional Program Manager Air Quality Control Southwest Regional Office

Elliott Turbomachinery Company, Inc. (Elliott) manufactures steam turbines and compressors at their Jeanette facility. Welding, blasting, grinding, shaping, cleaning and painting of metal parts all occur at this facility. Elliott is located in Jeanette, Westmoreland County.

The Department received a Title V Permit Application in November 1995. This application was amended to a Synthetic Minor State Only Operating Permit Application on March 28, 1997. Proofs ofmunicipal notification have been verified and permit fees are current.

EMISSION INFORMATION AIMS reported emissions for the years 2001 through 2005 are listed in Table 1. Before synthetic minor limitations, the facility reports potential emissions of 230 tons CO, 350 tons NOx, 360 tons SOx, 52 tons PM 10, and 18 tons VOC per year.

The most significant sources of emissions at this facility are two large boilers: boiler lA, installed in 1998 and rated at 206 million BTU/hr, and boiler 2, installed January 1, 1948 and rated at 126 million BTU/hr. Boiler 1A is natural gas-fired and boiler 2 is capable of being fired by either natural gas or No.6 fuel oil. The primary function of boiler 1A is to

Elliott Turbomachinery, Inc. 2 SOOP 65-00051

generate large volumes of high-pressure steam needed to test the turbines and compressors once they are completed.

This facility also operates a variety of smaller combustion units used in fabrication processes (i.e., stress relief) and for building heat. These units are fired by natural gas and range in size from 0.10 to 13.5 million BTU/hr. In addition to the natural gas fired sources, Department records indicate that the facility also operates two Besler boilers, each rated at 36 million BTU/hr and fired by No. 2 fuel oil. According to the permit contact (personal conversation, March 6, 2007), these Besler boilers were removed from the facility prior to the year 2000.

Fabrication operations are performed throughout the facility. Blasting, grinding, machining, cutting, and welding operations either exhaust indoors or are controlled by various dust collectors. The thermal metal spray operation is controlled by a HEPA filter and generates approximately one drum of waste metal in six months.

Painting of metal parts is performed in a large spray room with floor filters. Because only small portions of a finished product are painted, emissions from surface coating are minimal. In 2004 and 2005 reported emissions from surface coating were 0.4 and 0.5 tons, respectively.

This facility has two 50,000-gallon underground storage tanks dedicated to No. 6 fuel oil. The facility has one 1,000-gallon gasoline storage tank.

This facility uses two fluorinated hydrocarbons, R-22 and R-134a, for some turbine and compressor tests. These compounds are regulated under Title VI of the Clean Air Act, and are exempted by definition from consideration as VOC (40 CFR 51.100(s)). Elliott reports emissions of these compounds as required by Title VI. No requirements relating to these compounds are included in this permit.

Emission limits in this permit are set at 49.0 tons VOC, 9.0 tons of a single HAP, and 24.0 tons of all HAP combined per consecutive 12-month period. Limits for CO, SOx, NOx, and PM 10 were each set at 99.0 tons per consecutive 12-month period. These limits were chosen so that Elliott remains below Title V thresholds.

Table 1: Facility wide AIMS reported emissions, in tons 2005 2004 2003 2002 2001

co 8.16 7.05 5.76 8.46 7.10 NOx 24.32 26.84 12.57 15.66 10.62 PMIO 2.64 1.57 0.82 1.58 0.47 SOx 0.13 0.12 0.10 0.12 0.09 voc 3.24 3.17 3.43 2.70 5.34 Single HAP 0.32 0.36 0.27 0.33 0.27 (identity) (hexane) (hexane) (hexane) (hexane) (hexane)

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PREVIOUS PLAN APPROVALS AND OPERATING PERMITS Plan Approval 65-302-063 was issued September 24, 1990 and expired December 31 , 1990 for the installation of a COEN model Fyr COMPAK DAF-42 boiler rated at 244 million BTU/hr. This boiler was used specifically for testing of steam generators for the Army Corps ofEngineers. It was used from November 1990 through April1991 and then removed from the facility.

RACT operating permit 65-000-051 was issued June 7, 1995 and expired June 8, 2000 for the operation of sources ofNOx emissions. This RACT permit was not incorporated into the SIP, as evidence by it not appearing in 40 CFR 52 Subpart NN. This permit limited facility-wide NOx emissions to 99 tons and required annual reporting of a list of sources, fuel consumption, NOx emissions, and emission factors .

Operating permit 65-307-077 was issued December 21 , 1995 and expired December 21 , 2000. This permit was issued for a Linde Plasma Burning Unit.

Operating permit 65-399-034 was issued June 6, 1996 and inactivated September 24, 1998. This permit was issued for the temporary operation (i .e., testing) of a gas turbine. Elliott tested this specific turbine in 1997 and then delivered it to a customer in Ras Laffan, Saudi Arabia. In 2001, Elliott requested that the turbine test stand constructed under this plan approval be considered a source of emissions in the operating permit, and the Department, in correspondence dated December 11 , 2001 , concurred. Including the turbine test stand as a source with appropriate monitoring, record keeping, and reporting requirements will allow Elliott to test specialty turbines manufactured for use outside of the United States without prior Department approval.

Plan approval PA-65-051A was issued August 7, 1997 for the installation and operation of boiler lA, rated at 206 million BTU/hr. This plan approval was converted to an operating permit, OP-65-051 A, with a term of September 18, 1998 to September 1, 2003. Boiler 1A replaced the boiler identified as boiler 1, rated at 126 million Btu/hr.

Boiler lA is fired by natural gas only, and is capable of producing up to 150,000 pounds of steam per hour. Boiler 1A has continuous emission monitors (CEMs) for NOx and 0 2.

Plan approval PA-65-051A limited emissions from boiler lA to 0.2 pounds PM 10 per million BTU, 30 ppm NOx, and 400 ppm CO. These emission limits are based on the boiler being fired at or near its maximum rate. Manufacturing processes at Elliott though, dictate that the firing rate of this boiler vary from idling to maximum capacity. For example, during a Level 2 CEM Audit on October 25, 2005 , at 60,000 to 80,000 lblhr of steam flow, the NOx CEM read 47 ppm. Because of the variability in firing rate, the PA-65-051 A NOx and CO limits were not included in this permit. The NOx limit is given by 40 CFR 60.44b(a) and is 0.20 lb/million BTU heat input. The PM 10 limit was not included in favor of25 Pa. Code§ 123.11 , which gives a particulate matter limit for this boiler as 0.18 lb particulate matter per million BTU heat input.

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Operating permit OP-65-051A limited annual emissions from boiler lA to 2 tons PM 10,

20 tons NOx, 85 tons CO, 0.5 tons SOx, and 1 ton VOC by limiting annual fuel consumption to 1100 MMCF of natural gas. These limits were imposed to ensure that facility-wide emissions would remain below Title V permitting thresholds. At the time of issuance, Elliott operated an additional natural gas-fired boiler, boiler 43 , rated at 128 million BTU/hr. This boiler was removed from service and inactivated in AIMS December 31 , 2002 . Since the configuration of the facility has changed, and boiler 1 A is now responsible for more ofthe facility ' s steam generating needs, the OP-65-051A annual emission limits are not appropriate. These limits have not been included in this operating permit.

REGULATORY The requirements established by 40 CFR 60 Subpart Db (Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units) were examined and determined to apply to one boiler at this facility, Boiler lA. The other boiler that meets the heat input capacity of Subpart Db (boiler 2) was constructed before the compliance date of June 19, 1984, and so the standards of this subpart are not applicable to it.

Since Boiler 1 A only combusts natural gas, the particulate matter and sulfur dioxide standards of Subpart Db are not applicable. Sections 60.42b (Standard for sulfur dioxide), 60.43b (Standard for particulate matter), 60.45b (Compliance and performance test methods and procedures for sulfur dioxide), and 60.47b (Emission monitoring for sulfur dioxide) were not included in this permit. The applicable portions of sections 60.44b (Standard for nitrogen oxides), 60.46b (Compliance and performance test methods and procedures for particulate matter and nitrogen oxides), 60.48b (Emission monitoring for particulate matter and nitrogen oxides), and 60.49b (Reporting and record keeping requirements) were included in this permit.

The necessity of operating the NOx CEMs on this boiler was given careful consideration. Boiler 1 A operates at approximately 15% of its annual capacity, so the NOx exemption of 40 CFR §60.44b(j) does not apply. Steam generating units subject to the NOx requirements of 40 CFR §60.44b are generally required to comply with the NOx monitoring requirements of 40 CFR §60.48b. In lieu ofNOx CEMs, parametric monitoring may be approved in accordance with 40 CFR §60.48b(g) and 40 CFR §60.49b(c). At this time, Elliott has not pursued this option.

The requirements of 40 CFR 63 , Subpart DDDDD (National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters) were considered but determined not to apply to this facility. Section 63.7485 excludes this facility from the requirements of this subpart because ofthe federally enforceable limits of9.0 tons per year of a single HAP and 24.0 tons per year of multiple HAP included in this permit. In accordance with 40 CFR §63.7545, Elliott notified the Department regarding the lack of applicability of this NESHAP on March 11 , 2005.

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The requirements established by Title 25 P A Code § 129.52 Surface Coating Processes were included in this permit because of historical surface coating VOC emissions from this facility. The applicable §129.52 Table I surface coating process category is miscellaneous metal parts & products, extreme performance coatings. The VOC content limit of this category is 6.67 lb VOC/gal coating solids.

The requirements of 40 CFR 63, Subpart MMMM (National Emission Standards for Surface Coating of Miscellaneous Metal Parts and Products) were considered but determined not to apply to this facility. Section 63.3881(b) excludes this facility from the requirements of this subpart because of the federally enforceable limits of9.0 tons per year of a single HAP and 24.0 tons per year of multiple HAP included in this permit.

The requirements established by Title 25 P A Code § 123.51 Monitoring Requirements (Nitrogen Compound Emissions) were considered but determined not to apply to this facility. This section only applies to combustion units with a rated heat input of250 million BTU per hour or greater.

The requirements established by Title 25 PA Code§§ 123.101 - 121 (relating to NOx Allowance Requirements) were considered but determined not to apply to this facility. This facility does not have a NOx affected source as defined in Title 25 P A Code § 121.1 .

Elliott assessed the requirements established by 40 CFR 60 Subpart GG (Standards of Performance for Stationary Gas Turbines) and determined that these requirements do not apply to the turbine test stand based on a May 20, 1982 "Determination Detail" from the U.S. EPA' s Applicability Determination Index database. The basis of this determination is that turbines tested on the test stand are for use outside of the United States. The gas turbines tested on the test stand are manufactured by General Electric and connected to an Elliott manufactured compressor string for performance testing. Once performance specifications are met, the turbine/compressor set is shipped to a foreign end-user. Conditions requiring adequate record keeping and limiting the length of test time for any individual turbine were included in this permit

The requirements of 40 CFR 60 Subpart KKKK (Standards of Performance for Stationary Combustion Turbines) were considered but determined not to apply to this facility. Section 60.4310(d) excludes turbine test stands from the requirements ofthis subpart.

CONCLUSIONS AND RECOMMENDATIONS I have completed my review of Elliott Turbomachinery Company, Inc.'s Synthetic Minor State Only Operating Permit application for their Jeanette facility. Elliott has met the regulatory requirements associated with this application submittal. The attached permit reflects terms and conditions as described in the permit application. It is my recommendation to issue a Synthetic Minor State Only Operating Permit for this facility with a permit term of 5 years .