From: 
BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM
Sent:
Tuesday, September 29, 2020 4:33 PM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc:
GABRIELLE RAYMOND <graymond@rti.org>; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Subject: 
RE: HCl at Jewel NEI and TRI



Donna Lee,
 
Yes, all of the SunCoke facilities have vent stacks.  The difference between Jewell and the other facilities is that the other, newer facilities were able to install heat recovery steam generators (HRSGs) when first built, so instead of the combusted flue gases going out the vent stacks, as they do at Jewell, they are routed through the HRSGs and then to a spray dryer absorber (SDA) and baghouse for SO2 and PM control (flue gases at the other facilities will only go through the vent stacks if the associated HRSG is offline).  The spray dryer absorber also controls HCl, so emissions of HCl at the other facilities are lower.  However, the footprint of the Jewell facility, among other factors, does not allow for HRSG installation there, which is necessary to sufficiently cool the gases to be routed through an SDA and baghouse. 
 
Jewell does have a coal dryer onsite that can be used to dry coal before it is charged into the coke ovens.  The coal dryer uses the heat from the flue gases from one of the Jewell batteries to dry the coal and that air is sent through a venturi scrubber for PM and SO2 control.  There may be some HCl emissions from the dryer stack, but the majority of HCl emissions are from the vent stacks on the ovens.  I am not sure why the coal dryer was shown in the NEI, but I can dig into that if it would be helpful. 
 
Thanks,
 
Katie Batten
Director of Health, Safety and Environmental
 
SunCoke Energy, Inc.
kmbatten@suncoke.com
cell: 740-370-8710
 
From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Thursday, September 24, 2020 4:47 PM
To: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: GABRIELLE RAYMOND <graymond@rti.org>
Subject: Re: HCl at Jewel NEI and TRI
 
Sort of. Do the other Suncoke facilities have these same vents? Do they also have same HCl emissions? If not, why not? The other facilities are using same coal. also, right? Also, why was "coal dryer" used to characterize emissions in NEI? 
 
Regards,
Donna Lee Jones, Ph.D.
Senior Technical Advisor, Metals Sector
U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Sector Policies and Programs Division / Metals & Inorganic Chemicals Group (D243-02)
Research Triangle Park, NC  27711  Tele:  (919)  541-5251  Fax  (919)  541-3207
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
"Reasonableness never fails to be appreciated."  - anon.
 
Pronouns - She/Her/Hers
Salutation - Dr./Ms.
 
 
                                       
From: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Sent: Thursday, September 24, 2020 4:18 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: GABRIELLE RAYMOND <graymond@rti.org>
Subject: RE: HCl at Jewel NEI and TRI 
 
Hi Donna Lee,
 
The HCl emissions reported from Jewell are from the 16 oven vent stacks, and result from the coking of coal.  The emissions are based on a 2016 stack test using a lb of HCl/ton of coal charged emission factor to calculate.  Does that answer your question?

Thanks,
 
Katie Batten
Director of Health, Safety and Environmental
 
SunCoke Energy, Inc.
kmbatten@suncoke.com
cell: 740-370-8710
 
From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Wednesday, September 23, 2020 12:48 PM
To: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: GABRIELLE RAYMOND <graymond@rti.org>
Subject: HCl at Jewel NEI and TRI
 
 
Hi Katie - We have run across what we thought might be an anomaly (or state error) in the NEI in regard to HCl emissions from Jewel. But we checked the TRI and it's self reported there for a number of years (2005-2017) so not just a NEI error. And its labelled air stack emissions. The NEI says its from a coal dryer and estimated from mass balance. Do you have any more details on how the mass balance was done? Is it HCL from coal as fuel or from coal being dried for use in coke ovens? (This question doesn't affect anything in rule applicability or in the RTR, just to help with figuring out the emission estimates).
 
Regards,
Donna Lee Jones, Ph.D.
Senior Technical Advisor, Metals Sector
U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Sector Policies and Programs Division / Metals & Inorganic Chemicals Group (D243-02)
Research Triangle Park, NC  27711  Tele:  (919)  541-5251  Fax  (919)  541-3207
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
"Reasonableness never fails to be appreciated."  - anon.
 
Pronouns - She/Her/Hers
Salutation - Dr/Ms



<< JEWELL COKE CO LP_TRI_HCl.xlsx >>
