UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 6 1445 ROSS

AVENUE, SUITE 1200
DALLAS, TX 75202-2733
MAR 3 0 2010

Mr. Vance Parr, P.E.

Environmental Manager
PL Propylene LLC
9822 La Porte Freeway
Houston, Texas 77017
Re: Applicability Determination Subject to NSPS Subpart KKKK
Dear Mr. Darr:
This is in response to your letter dated September 10, 2009, to John Blevins
requesting an applicability determination and approval of alternate performance testing
for combustion turbines and direct-fired heaters being installed as part of a process
modification at the PL Propylene plant site under the provisions of 40 C.F.R. Part 60,
Subpart KKKK (Standards of Performance for Stationary Combustion Turbines). You
stated that the four identical combustion turbines will be utilized to generate hot air for
catalyst regeneration and steam production and will not be associated with power
generation. You also stated that the exhaust from the turbines combines and goes through
a duct burner for additional heating, and then to the reactors for catalyst regeneration.
You further stated that after regeneration the reactor exhaust goes to a second duct burner
and a heat recovery steam generator (HRSG). You noted that the four gas turbines can
combust natural gas or a blend of natural gas and fuel gas, and the two duct burners will
combust fuel gas during normal operation. You further noted that the catalytic oxidation
and selective catalytic reduction (SCR) units are located downstream of the HRSG to
reduce the NOx and CO emissions from the combined facilities to below 10.5 ppmv and
8.75 ppmv respectively.
We have reviewed your request and have determined that the stationary
combustion turbines are subject to the requirements of 40 C.F.R. Part 60, Subpart KKKK.
The source you describe is comprised of four Subpart KKKK affected facilities
(stationary combustion turbines) that share duct burners, a HRSG unit, and have a
common steam header.
We approve your request to conduct one performance test downstream of the SCR,
and to apply reference method results from the NOx continuous monitoring system
(CEMS) certification for the initial demonstration of compliance with 40 C.F.R. Section
60.4320. This is supported by 40 C.F.R. Section 60.4333(b)(1) which allows gas turbines
with a common steam header to measure the emissions collectively at the common heat
recovery unit. There is no need for a performance test waiver since the regulation already
provides that you may test the combined emissions in this case, and that you may
demonstrate initial compliance using the NOx CEMS consistent with Section 60.4405.

However, testing must be conducted using the fuel or combination of fuels that would
result in the highest emissions.
This determination has been made in coordination with EPA Headquarters, and is
based on information you submitted to EPA Region 6. If any information is found that
would reverse this determination, then it would become invalid and a new determination
would be needed.
If you have any questions concerning this determination, please contact Tony
Robledo, of my staff, at 214.665.8182.
Sincerely yours,

David F. Garcia
Chief
Air/Toxics and Inspections
Coordination Branch