June
11,
2003
Here
is
an
explanation
from
the
facility
regarding
the
Coker
Boilers.
It
appears
that
they
would
not
be
classified
as
a
by­
product
coke
oven
battery
based
upon
the
definition
in
the
MACT;
however,
nonrecovery
coke
ovens
are
also
covered
and
it
seems
like
it
could
meet
this
definition.
Based
upon
common
sense,
I
would
think
these
Boilers
would
be
covered
under
the
new
Boiler
MACT;
however,
I
wanted
some
guidance
on
how
these
sources
would
be
exempt
from
the
Coke
Oven
MACT
based
upon
the
regulations/
definitions.
Thanks.
If
you
have
any
questions
please
feel
free
to
contact
me
by
phone
or
email.

The
equipment
used
in
the
Chemcoke
process
is
the
same
as
a
normal
underfeed
boiler.
In
fact,
we
do
add
enough
air
to
convert
the
coal
to
ash
while
starting
up
and
shutting
down.
The
coal
is
not
soaked
in
the
volatiles
and
they
burned
over
the
bed
as
liberated
as
in
the
case
of
a
normal
boiler.
The
volatiles
are
not
collected
and
do
not
escape.
In
fact
15%
of
the
fixed
carbon
is
lost
thru
oxidation
while
exposed
to
the
radiant
heat.

Coke
Ovens
are
built
entirely
different
in
that
they
are
an
enclosed
fixed
space
in
which
a
charge
of
coal
fills
the
space
which
is
then
sealed
and
remains
for
a
period
of
24
plus
or
minus
hours.
The
coal
goes
thru
a
slow
heat,
at
which
time
it
is
expanding
and
pressuring
against
the
oven
walls,
and
is
soaking
in
the
volatiles
until
they
are
removed
from
the
oven
thru
vents
for
distillation
or
burning.
At
the
end
of
the
coking
period
the
charge
is
pushed
out
into
the
open
and
quenched.
Volatiles
have
a
chance
to
escape
the
process
thru
oven
doors,
etc.
or
when
the
door
is
opened
and
the
load
shoved
out
to
be
quenched.
Our
Cokers
were
built
to
produce
small
coke,
"
Chemcoke",
and
to
provide
steam
for
the
plant.
The
Chemcoke
continuous
coking
process
and
trade
name
was
licensed
from
the
Peabody
Coal
Company
in
1965
and
four
such
Chemcoke
units
were
built
at
the
facility
that
year.
The
Chemcoke
process
consists
of
burning
of
coal
on
a
spray
stoker
grate
while
limiting
the
oxygen
and
burning
the
liberated
volatiles
overhead
in
the
boiler
section
under
negative
draft
as
a
boiler.
Our
coking
process
is
not
an
oven
where
coal
undergoes
destructive
distillation
under
positive
pressure.

In
short,
each
of
our
two
remaining
Cokers
is
configured
as
a
boiler
which
is
under
vacuum
in
the
firebox
and
does
not
and
not
intended
to
create
distilled
volatiles.
Our
Cokers
are
different
from
Coke
Ovens
and
therefore
would
not
be
classified
as
Coke
Ovens.

Daphne
Y.
Smart
Chemical
Branch
Air
Division
phone:
(
334)
271­
7731
fax:
(
334)
279­
3044
email:
ddy@
adem.
state.
al.
us
