AP42 Section:

Reference:

Title:

12.2

78

Compliance Demonstration No. 13 Battery Combustion Stack, USS Clairton Works, Clairton, PA, Advance Technology Systems, Inc., Monroeville, PA,

August 1994.

Report on

COMPLIANCE DEMONSTRATION NO. 13 BATTERY COMBUSTION STACK

AUGUST 1994

USS CLAIRTON WORKS A D M S I O N OF USX CORPORATION

C W R T O N , PENNSYLVANIA

Report on

COMPLIANCE DEMONSTRATION NO. 13 BATTERY COMBUSTION STACK

AUGUST 1994

Prepared By Advanced TechnologV Systems, Inc.

3000 Tech Center Drive Monroeville, Pennsylvania 15146

Project No. IKM-0202

clairton Works A M Slate Street

on, PA 15025.1855 ~.--. Clairt

August 24, 1994 DEPUTY DIRECTOR'S OFFICE Bureau 01 Environmental (iIJa1'v

.._---. Allegheny Coun tJ1 Health Department Department of Air Quality 301 Thirty-nlnth Street Pittsburgh, PA 15201

Director Deputy Director Bureau of Air Quality Control Department of Environmental Resources P.O. Box 2063 Harrisburg, PA 17120

US. Environmental Protection Agency Region 111 Western Region 841 Chestnut Building Department of Environmental Resources Philadelphia, PA 19017

Office of Chief Counsel

400 Waterfront Drive Pittsburgh, PA 15222-4745

Gentlemen:

Subject: #13 Battery Stack Compiance Demonstration USS Clairton Works

I am enclosing with this letter the mass emission report on #13 Battery Combustion Stack. The compliance demonstration was conducted at USS Clairton Works, a division of USX Corporation, on July 28-29, 1994.

For questions regarding these reports please call William C. Graeser at (412) 233-1467

Very truly yours, ...

47& G: . Weber,

,' General Mafdger USS Clairton Works

GTWIBAC Enclosure

U. S. Steel Group A unit of USX Corporation

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY ................................................................................................................ 111

1.0 INTRODUCTION .................................................................................................................. 1

2.0 METHODOLOGIES ............................................................................................................. 2

3.0 RESULTS ................................................................................................................................ 4

...

LIST OF TABLES

Table 1 Particulate Matter Emissions Daru ......................................................................... 6

APPENDICES

APPENDIX A TEST PROTOCOL, FIELD DATA SHEETS, CALIBRATION RESULTS

APPENDIX B PLANT OPERATIONAL DATA APPENDIX C GRAVIMETRIC AND ANALYTICAL RESULTS, EMISSIONS

CALCULAnONS

USS Clairtoo Works m-mz 08/94 -11-

m ADVANCED TECHNUOGV SYSTEMS. INC.

EXECUTIVE SUMMARY

On July 28 and 29, 1994, a compliance test program was conducted for USS Clairton Works, Clairton, Pennsylvania, on the #13 B3ttery Combustion Stack. The purpose of the testing was to determine the (1) concentration and mass emission rate of particulate matter, and (2) presence and extent of visible emissions from the stack as required by the Second Consent Decree (Civil Action Nos. 79-709, 91-329), Chapter V (Compliance Requirements - Clainon Works), Section F (Combustion Stacks), Specific Items 2 through 4.

The results of the testing showed an average particulate matter concentration and emission rate of 0.0120 grains per dry standard cubic foot (gr/dscf) and 3.43 pounds per hour (lb/hr), respectively. As promulgated by the Second Consent Decree, Chapter V, Section F . 2 4 the allowable particulate matter concentration for #13 Battery Combustion Stack is 0.015 gr/dscf (a Lowest Achievable Emission Rate (LAER] standard). Thus, the particulate matter emissions from the stack are less than the allowable concentration.

During the test periods, the greatest three-minute average opacity was less than 5 percent. The maximum opacity observed was 5 percent. As promulgated by the Second Consent Decree, Chapter V, Sections F.2.b and F.3, the visible emissions shall not equal or exceed 20 percent opacity for a period or periods aggregating in excess of 3 minutes in any 60- minute period and shall never equal or exceed 60 percent opacity. Thus, the observed opacities were less than the allowable values.

. .

USS Clairton Works I K M - m 08/94 ...

-uI-

ADVANCED TECHNOCCGY SYSTEMS. INC.

1.0 INTRODUCITON

On July 28 and 29, 1994. a compliance test p+ogram was conducted for USS Clairton Works, Clairton, Pennsylvania, on the #13 Battery Combustion Stack. The purpose of the testing was to determine the (1) concentration and mass emission rate of particulate matter, and (2) presence and extent of visible emissions from the stack as required by the Second Consent Decree (Civil Action Nos. 79-709, 91-329), Chapter V (Compliance Requirements - Clairton Works), Section F (Combustion Stacks), Specific Items 2 through 4.

Testing was performed by Messrs. Richard Casselberry and Thomas Morgan of Advanced Technology Systems, Inc. (previously the Monroeville, Pennsylvania-based Air Emissions Measurement Group of Chester Environmental) and Mr. Brian Fajtak of Environmental Technical Services under the direction of Mr. Bernie Clark of Chester Environmental. All test procedures were witnessed by Mr. Phil Lawrence of the Allegheny County Health Department - Department of Air Quality (DAQ).

The test program required two days to complete the field work activities due to a delay in the operation of the Battery #13. Since no ovens in Battery #13 were pushed or charged from approximately 1000 to 1235 on July 28, 1994, no emissions testing was completed during this time period. Once normal operations of the battery resumed (about 1245), emissions testing was resumed. Since there was an insufficient amount of daylight remaining after fhe completion of the second test run. the third test run was conducted on the following day, July 29, 1994.

USS Clairton Works IKMMOZ 08/94 .1-

m ADVANCED TECHNOLOGY SYSTEMS. INC.

2.0 METHODOLOGIES

The compliance test program was conducted in accordance with the emissions measurement test protocol, which can be found in Appendix A.

Particulate matter sampling was performed in accordance with EPA Stationary Source Sampling Methods 1 through 5, Sections 139.11 and 139.12 of the Pennsylvania Department of Environmental Resources (PA DER) Source Testing Manual, and Appendix A of the Amended Installation Permit for USS Clairton Works Nos. 13, 14, and 15 Batteries. Three two-hour tests were executed during normal operating conditions. Greater than 50 dry standard cubic feet of sample gas was collected during each test run.

The process exhausts through a 120 inch diameter stack. A total of 24 traverse points (12 per diameter) were sampled; the traverse points were calculated in accordance with EPA Method 1. Sampling was conducted through four equally spaced ports, with six traverse points sampled per port. Each point was sampled for 5 minutes, thus bringing the total sampling time to 120 minutes.

In accordance with EPA Method 2, velocities and volumetric flow rates of the exhaust gas were determined using a calibrated S type pitor tube. Positive and negative pitot lines were leak-checked at the beginning and end of each test run. Gas velocity differential pressures along with stack gas temperatures were recorded at each sampling point.

At the beginning and end of each test, gas concentrations of carbon dioxide (COz), oxygen (Oz), and nitrogen (N2 - by difference) were determined with the use of Fyrite apparatus as specified by EPA Method 3. Gas concentrations were used to obtain dry molecular weight of the process gas.

Percent moisture content, by volume, of the exhaust gas was determined by measuring the weight gain of the four sample train impingers in accordance with EPA Method 4.

As specified by EPA Method 5, each sample [rain was assembled as required by the method, leak-checked on site at the beginning and end of each test run, and operated such that isokinetic conditions are maintained. Clean up of the sampling train will include a

u s Clairton Works IKM-0202 08\94 -2-

ADVANCED TECHNaMjY SYSTEMS, INC.

water rinse followed by an acetone rinse of both the front-half and back-half components of the sample train, as per PA DER particulate matter test methods. The water soluble and water insoluble portions of the front-half of the sampling train were determined as a total; that is, the water rinse was not filtered to determine soluble and insoluble portions. Front- half acetone and water rinses were evaporated to dryness, desiccated, and weighed to a constant weight. The water soluble and water insoluble portions of the back-half were determined separately in accordance with Section 139.12 of the PA DER Source Testing Manual. The back-half water rinses and first three impinger solutions were combined and then filtered under suction through a preweighed 0.22 micrometer membrane filter. The fdter used to capture the insoluble material was dried, desiccated, and weighed to a constant weight. After filtration, the soluble back-half water was extracted with chloroform and ethyl ether. The extracts were evaporated to dryness, desiccated, and weighed to a constant weight. The filtrate, or remaining water from the extraction process, was evaporated to dryness, desiccated, and weighed to a constant weight. Following the gravimetric analyses for the filtrate residue, the residue was resolubilized and the solution submitted for sulfate analysis via ion chromatography. Back-half acetone rinses were evaporated to dryness, desiccated, and weighed to a constant weight. Sample train filters were desiccated for 24 hours, and particulate matter weight was determined gravimetrically. Rinse residue weights and filter weights were measured to the nearest 0.1 mg. One acetone blank and one deionized distilled water blank were prepared in the same manner as the test sample rinses. The blank residue weights were subtracted from the test sample residue weights. After blank correction, front-half water and acetone rinse residue weights, sample train filter weights, and back-half water insoluble filter weights were used to determine total particulate matter catch.

All visible emissions determinations were performed in accordance with EPA Stationary Source Sampling Method 9. Visible emission readings were recorded for the duration of each particulate matter test.

U S Clairtao Works lKhfM02 08/94 .3.

m ADVANCED TECHNUOGY SYSTEMS, INC.

i! P

1

A report summarizing the compliance test program will be submitted within 60 days following comptetion of field work. The report will describe test methodologies utilized and present a textual and tabular summary of the emissions results and related sampling information. Copies of operational data will be included in the report to verify that all testing was performed during periods of normal plant operation. Also incorporated into the report will be copies of the pre-test calibration results, post-test calibration results, the results of an audit conducted with a critical orifice provided by the Allegheny County Health Department - Department of Air Quality, field data sheets for the particulate matter sampling and visible emissions determinations, emissions calculations sheets, and analytical results for each test.

USS Clairton Works 3934-4543 5/94

-3- CHESTER ENVIUONMENTAL

water rinse followed by an acetone rinse of both the front-half and back-half components Of

the sample train, as per PA DER paniculate matter test methods. The water soluble and water insoluble portions of the front-half of the sampling train will he determined as a total; that is, the water rinse will not be filtered to determine soluble and insoluble portions. Front-half acetone and water rinses will be evaporated to dryness, desiccated, and weighed to a constant weight. The wirer soluble and water insoluble portions of the back-half will be determined separately in accordance with Section 139.12 of the PA DER Source Testing Manual. The back-half water rinses and first three impinger solutions will be combined and then filtered under suction through a preweighed 0.22 micrometer membrane filter. The filter used to capture the insoluble material will be dried, desiccated, and weighed to a constant weight. After filtration, the soluble back-half water will be extracted with chloroform and ethyl ether. The extracts will be evaporated to dryness, desiccated, and weighed to a constant weight. The filtrate, or remaining water from the extraction process, will be evaporated to dryness, desiccated, and weighed to a constant weight. Following,the gravimetric analyses for the filtrate residue, the residue will be resolubilized and the solution submitted for sulfate analysis via ion chromatography. Back- half acetone rinses will be evaporated to dryness, desiccated, and weighed to a constant weight. Sample train filters will be desiccated for 24 hours, and particulate matter weight wi l l be determined gravimetrically. Rinse residue weights and filter weights will be measured to the nearest 0.1 mg. One acetone blank and one deionized distilled water blank will be prepared in the same manner as the test sample rinses. The blank residue weights will be subtracted from the test sample residue weights. After blank correction, front-half water and acetone rinse residue weights, sample train filter weights, and back- half water insoluble filter weights will be used to determine total particulate matter catch.

All visible emissions determinations will be performed in accordance with EPA Stationary Source Sampling Method 9. Visible emission readings will be recorded for the duration of each particulate matter test.

U S Clairton Works 3934-4563 5/94

CHESTER ENVIRONMENTAL

TEST PROTOCOL COhlPLXANCE DEMONSTRATION

#I3 BA’ITERY COMBUSTION STACK

USS CIAIRTON WORKS CLAIRTON, PA

Particulate matter sampling will be performed in accordance with EPA Stationary Source Sampling Methods 1 through 5 , Sections 139.11 and 139.12 of the Pennsylvania Department of Environmental Resources (PA DER) Source Testing Manual, and Appendix A of the Amended Installation Permit for USS Clairton Works Nos. 13, 14, and 15 Batteries. Three two-hour tests will be executed during normal operating conditions. Greater than SO dry standard cubic feet of sample gas will be collected during each test run.

The process exhausts through a 120 inch diameter stack. A total of 24 traverse points (12 per diameter) will be sampled; the traverse points will be calculated in accordance with EPA Method 1. Sampling will be conducted through four equally spaced ports, with six traverse points sampled per port. Each point will be sampled for S minutes, thus bringing the total sampling time to 120 minutes.

In accordance with EPA Method 2 , velocities and volumetric flow rates of the exhaust gas will be determined using a calibrated S type pitor tube. Positive and negative pitot lines will be leak-checked at the besinning and end of each test run. Gas velocity differential pressures along with stack gas temperatures sill be recorded at each sampling point.

At the beginning and end of each test, gas concentrations of C02, 02, and N2 (by difference) will be determined with the use of a Fyrite apparatus as specified by EPA Method 3. Gas concentrations will be used to obtain molecular weight of the process gas.

Percent moisture content, by volume, of the exhaust gas will determined by measuring the weight gain of the four sample train impingers in accordance with EPA Method 4.

As specified by EPA Method 5, each sample train will be assembled as required by the method, leak-checked on sire at the beginning and end of each test run, and operated such that isokinetic conditions are maintained. Clean up of the sampling train will include a

us Clairton Works 3934-45-03 SI94

-1- CHESTER ENVIRONMENTAL

CO3IPLUNCE DERlOSSTRAl’ION NO. 13 BAlTERY COhlBUSTlON STACK

USS CLAIRTON WORKS A DMSION OF USX CORPORATION

CLAIRTON, PENNSYLVANIA

APPENDIX A

TEST P ROTO C 0 L,, FIELD DATA SHEETS, RESULTS

CALIBRATION

ADVANCED TECHNCCCGV SYSTEMS. INC.

All testing was performed during periods of normal plant operation. Copies of the plant operational data can be found in Appendix B.

The gravimetric and analytical results (including the results of the sulfate analyses of the back-half Titrate from the sample trains) and the emissions calculations for each test can be found in Appendix C.

USS Clairton Works IKM62M 08/94

Grs ADVANCED TECHNOLOGY SYSTEMS INC.

Test Number Test Date

Mass Emissions h t e and Concentration

Particulate Matter ( I b h ) (gr/dscO

Stack Conditions

Flow Rate (acfm) (scfm) (dscfm)

Temperature (OF)

Moisture Content (%t )

Samdine Conditions

Test times

Sampling Time (minutes) Sample Volume ( k c 0 Isokinctics (%)

USS Clainon Worb

USS CLAIRTON WORKS CLAIRTON. PA

TABLE I

#I3 BA'lTERY COMBUSTION STACK PARTICULATE M A T E R EMISSIONS DATA

Run I Run 2 Run 3 CLR-BS#13-I CLR-BW3-2 CLR-BW3-3

07-28-94 07-28-94 07-29-94

3.19 3.11 3.69 0.0121 0.0109 0.0129

73700 73900 73500 39800 39800 39800 33600 33200 33400

496 498 495 15.5 16.6 16.2

0830 to 0900

0906 LO 0936

0939 to I009

1242 to 1312

I20 70.923

105.4

-6-

1340 to 1410

1414 to 1444

1447 to 1517

1.520 to 1550

120 70.515

106.2

0740 to 0810

0813 to 0843

0846 to 0916

0919 to 0949

120 69.046

103.4

Average

3.43 0.0120

73700 39800 33400

496 16.1

MM4202 08/94

ADVANCED TECHNOCCGV SYSTEMS, INC.

3.0 RESULTS

The test results have been summarized in Table 1. The results of the testing showed an average particulate matter concentration and emission rate of 0.0120 grains per dry standard cubic foot (gr/drcf) and 3.43 pounds per hour (lb/hr), respectively. As promulgated by the Second Consent Decree, Chapter V, Section F.24 the allowable particulate matter concentration for #13 Battery Combustion Stack is 0.015 gr/dscf (a Lowest Achievable Emission Rate (LAER] standard). Thus, the particulate matter emissions from the stack are less than the allowable concentration.

Table 1 also lists other pertinent stack and sampling parameters which include stack gas flow rate in units of actual cubic feet per minute (acfm), standard cubic feet per minute (scfm), and dry standard cubic feet per minute (dscfrn), stack gas temperature (OF), moisture content of the stack gas (percent by volume), gas volume sampled for each test in units of dry standard cubic feet (dscf), and the isokinetics value for each test. The isokinetics value is equal to the ratio of the average linear gas velocity sampled through the probe nozzle to the average stack gdi velocity. An irokinetics value between 90 percent and 110 percent is considered acceptable. All isokinetic values were within the acceptable range of values. The gas volume sampled for each 120 minute test was greater than 50 dry standard cubic feet. Actual test sampling times have also been included in Table 1.

Copies of all field data sheets, including the visible emissions readings, can be found in Appendix k As promulgated by the Szcond Consent Decree, Chapter V, Sections F.2.b and F.3, the visible emissions shall not equal or exceed 20 percent opacity for a period or periods aggregating in excess of 3 minutes in any 60-rninu1e period and shall never equal or exceed 60 percent opacity. During the test periods, the greatest three-minute average opacity was less than 5 perceni. The rnaxinium opacity observed was 5 percent. Thus, the observed opacities were less than the allowable values.

All sampling equipment was calibrated and operated in accordance with EPA Stationary Source Sampling Methods 1 through 5 . Copies of the pre-test calibration results, post-test calibration results, and the results of an audit conducted with a critical orifice provided by the Allegheny County Health Department DAQ can be found in Appendix A.

U S Clairton Works 1KM-0202 08/94 -4-

m ADVANCED TECHNOLffiY SYSTEMS. W.

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CORIPLLAIVCE DERIONSTRATION NO. 13 BATTERY COXIBUSTIOX STACK

uss CLAIRTOS \\‘ORKS A DMSIOK OF USS CORPORA‘I’ION c u1 l w 3 s, I’E s N 51’L\’.A.Y 1A

PLANT

APPENDIX B

OPERATIONAL DATA

ADVANCED TECHNOLOGY SYSTEMS. INC.

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co n 1 P L u.Y c E u E h 1 0 N S'I'IL%T10 N NO. 13 Ba'Iv1TI?Y C0.9IUL'S7'10N S'I'.ACK

uss cLmwoN WORKS A DIVISION OF USX CORPORATION

C U I R T O N , PENNSYL\ 'ANu

APPENDIX C

CALC U LG'I'IO h'S auvmmxic AND ANALYIICAL RESULTS, EwssroNs

AOVANCEO TECHNOLOGY SYSTEMS, INC.

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STACK SAhhlYLlNG CALCULATIONS

CLIENT: USS CLAIRTON WORKS TEST SITE f l 3 BATTERY COMBUSTION STACK

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KK.

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PitM Cafiicicnt Ca Mdcr Coslficicm Slack Diamctur

Stack Arcs N o d s DianiEIei

N 4 s Arc" Avsrags Stack T s m ~ m t u r c

Avcrvp Stack Temperature Avcragc Mcter Tsmpemturr: Averags Mctcr Temp;riliurc Candsirrvte Vuluuic Absorbd H?O Total H2O Filter Weigh, Probe Wcipht

Impingcr Wcighi

Toed Wclght hlstcrul Cas Volume Corrcckc h.(cterd Gas Vo1urr.r

H20 Gar \'ulumc

Told S4rnplc Velum< Pcrcent H?O Gar Volume Slimplcd Crab! Loadhe

TEST DATE: 07-28-94 TEST NUMBER: CLR-BM13-I

29.10 h Hg -1.0 in. H 2 0 .~ ~

29.?3 "1. Hg [A*(B/13.6)1

29.39 in. H g . [A+(D113.6)1 1.21 in. H20

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STACK SMIPLING CALCULATIONS

CLIENT: USS CLAIRTON WORKS TEST DATE: 07-28-94 TEST SITE #I3 BATTERY COMBUSTION STACK TEST NUMBER: CLR-BWI3-2

A. E. C. D. E. F. a. H. I. J. K. L. M. N. 0. P. Q. R. s. T. U. V. W. X. Y. 2. A A 88. cc. DD. EE.

FF. GG. HH. U. JJ. KK.

29.30 "1. Hg

29.39 in. Hg [A*(D/13.6)1 0.0: in H20 0.81

1.0172 I20 in

76.54 fi:

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STACK SrUiiPLlNG CALCULATIONS

CLIENT: USS CLMRTON WORKS TEST SITE #I3 BATTERY COhlBUSTION STACK

A B. C. D. E. F. a. H. 1. 1. K. L. M. N . 0. P. Q. It. S. T. U. V . W. X. Y. 2. AA. 88. cc. DD. EE.

FF. GG. HH. D. 11. KK.

TEST DATE: 07-29-95 'TEST N U M E E K : C L R - B S # I ~ - ~

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