From: 
BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Sent:
Wednesday, October 7, 2020 9:44 AM
To: 
Jones, DonnaLee <jones.donnalee@epa.gov>
Cc:
Raymond, Gabrielle <graymond@rti.org>; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Subject: 
RE: Suncoke - 10/7- Whole industry QA review of Coke data and calculations


Donna Lee,

Thank you for the opportunity to provide comments and revisions to these files. We have a number of comments to provide, which are included below, along with edits to the spreadsheet, which is attached.

Comment 1: HNR Pushing (SC-Vansant-VA and SC-EastChicago-IN only) 
 Pushing emissions for SC-Vansant-VA should apply a control efficiency for a cokeside shed. We recommend using a 74% control efficiency for all applicable pollutants for the cokeside shed (AP-42, Table 12.2-6, filterable PM capture efficiency from coke oven pushing).  The value shown in the spreadsheet uses an average of Middletown and Granite City emission factors for the multiclone.  The Vansant site does not have a multiclone, but instead has a shed enclosure for control; therefore, the Middletown and Granite City factors are not applicable here.
 Pushing emissions for SC-EastChicago-IN should apply a control efficiency for a baghouse. We recommend using a 99% control efficiency for the baghouse for all applicable pollutants (AP-42, Appendix B.2, Figure B.2-1 for fabric filter filterable PM collection efficiency). The value shown in the spreadsheet uses an average of Middletown and Granite City emission factors for the multiclone.  The East Chicago site does not have a multiclone, but instead has a shed enclosure with a baghouse for control; therefore, the Middletown and Granite City factors are not applicable here.
Comment 2: HRSG Main Stacks
Since the main stacks at all facilities operate continuously (up to 8,760 hours per year), except in the case of a flue gas desulphurization (FGD) system outage, main stack emissions are not related to coke production and main stacks emit during periods where charging does not occur, a more accurate method to calculate emissions is to use the measured lb/hour emission rate from the ICR source test and multiply by the annual hours/year to calculate an annual emission rate. Since the main stack activity is not tied to charging activity, using a lb/ton coke emission factor is not representative of the main stack emissions process.  When the FGD system is offline, the emissions are directed through the bypass vent stacks.

Comment 3: HRSG Bypass-Waste Heat
Bypass Vent Stacks (BVS) operate intermittently and their operation is not tied to coke production, therefore annual emissions in tons/year should not be based on annual coke production. We believe that a more accurate method to calculate emissions is to use the measured lb/hour emission rate from the ICR source test and multiply by the number of permitted hours of operation per year.  Applicable site permit limits for venting are shown below: 
 SC-GraniteCity-IL: 312 hours per BVS (a total of 1,872 permitted stack and FGD hours per year, divided by 6 bypass stacks) (pg. 21, section 4.1.5)
 SC-FranklinFurnace-OH: 1920 hours for all 10 stacks per year
 SC-Middletown-OH: 312 hours per BVS (a total of 1,560 permitted stack and FGD hours per year, divided by 5 bypass stacks)
 SC-EastChicago-IN: 13% annual venting limit, equal to 0.13*8760 = 1,139 hours total per year (pg. 35, section D.1.0.1)
 SC-Vansant-VA: 8,760 hours (operates continuously)
Comment 4: Specific Spreadsheet Changes
Other comments or changes/additions made to spreadsheets as well as questions on calculation methods:
CokeOvens-Enclosure 12 QA-Whole Industry Test Data-Aug 2020.xls
 Tab A-1
 General comment  -  We see that EPA has tried to create a lb/ton of coke emission factor for all sources by using the total amount of coal charged to each oven during the test.  However, this is not representative of a coking cycle, nor is it accurately calculated, in some cases, because the actual number of ovens pushed/charged doesn't appear to be included in this calculation.  Multiple ovens are pushed/charged during any test run.
 Main Stack EP-6
 As stated above in Comment 2, it makes more sense to use lb/hr factor because the main stack emissions are not directly tied to pushing and charging.
 Error in Column AQ for main stack test and bypass vent stack sources (coal charged during test run in tons/hr)
 For the main stack and bypass vent stack tests, the number shown in column AK (~42 - 46 tons) is the amount of tons charged to each oven, on average.  The calculation does not take into account the actual number of ovens charged.  Regardless, the lb/hr emission factor should be used for these sources as they are not tied to active pushing and charging. 
 HRSG BVS EP-7
 Same issue as noted above for EP-6.
 Tab A-3
 The pushing charging machine (PCM) emission factors would be more accurately represented as a lb/ton coal charged as the PCM solely charges coal into the ovens.
 Tab A-4
 Updated total oven count for SC-Vansant (changed from 143 to 142).
 Tab A-5
 Updated battery/oven data as needed.
Thanks,

Katie Batten
Director of Health, Safety and Environmental

SunCoke Energy, Inc.
kmbatten@suncoke.com
cell: 740-370-8710


<< CokeOvens-Enclosure 12 QA-Whole IndustryTest Data-Aug 2020 SCE comments final draft.xlsx >>

From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Thursday, September 24, 2020 4:18 PM
To: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: graymond@rti.org; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Subject: Re: Suncoke - 10/7- Whole industry QA review of Coke data and calculations

OK. We look forward to your comments on 10/7. We appreciate your conscientiousness in reviewing the data.

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 1:52 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: graymond@rti.org <graymond@rti.org>; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Subject: RE: Whole industry QA review of Coke data and calculations 
 
Donna Lee,
 
We have been working through reviewing the spreadsheet and found a couple of items that we are still working on correcting (e.g. calculation of lb/ton values).  Could we please have a few extra days to complete our review and return our comments to you by 10/7?
 
Thank you, 
 
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, August 26, 2020 11:32 AM
To: Rich.Zavoda@arcelormittal.com; Marian.Gammon@arcelormittal.com; 'Charles Jones' <cjones@bluestonecoke.com>; Brenna M Harden <brenna.harden@dteenergy.com>; Robert B Sanch <robert.sanch@dteenergy.com>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>; BJTunno@uss.com; JSScheetz@uss.com
Cc: David Ailor (dailor@accci.org) <dailor@accci.org>; Raymond, Gabrielle <graymond@rti.org>
Subject: Whole industry QA review of Coke data and calculations
 
Hello all - We have finished tabulating all of the test data and developing emissions (lb HAP/ton coke, lb HAP/hr, and/or ton HAP/year) from the test facilities, as well as generating default HAP emission factors (lb HAP/ton coke produced or lb HAP/hr) for facilities that did not test or did not do all tests. 
 
Please review and send your comments back (either in the spreadsheets themselves and/or with attached comments) on or before September 28, 2020 (Monday). 
 
I tried to send this email to at least two people per company for all facilities, to make sure I include at least one correct person who can  distribute this QA review to all their company's facilities. Please let me know if I should substitute or add someone else for future emails about the EPA Coke data or the QA.
 
The attached files are listed below with a description of their contents: 
1.    CokeOvens-Estimates&Assumptions-Aug_2020 (Word file) 
 Explains the assumptions and estimates used in the Excel spreadsheets. 
 
2.    CokeOvens-Example Emission Calcs-Aug_2020 (Excel file) 
 Example calculations for Antimony (Sb) emissions using test data from facilities who tested, for each source category process (EP-1 through EP-9*). The spreadsheet takes the calculations through a complete calculation sequence as an example of what will be done for all HAP tested. 
 Shows the default emission factors developed from the test data that will be used for Antimony, as an example HAP, for facilities without test data for the indicated process, to be done next for all HAP tested. 
 Shows the application of the default emission factors for Antimony to all facilities without test data for the indicated process to calculate tons Antimony (Sb)/year, to be done next for all HAP.
 
 The CU (Capacity Utilization) worksheet shows the production values reported to the EPA and the values estimated by the EPA for use in the emission calculations and estimates, for all coke facilities.  
 Erie production values from test data (wet/dry coal charged/pushed, and total coke) and ratios developed from these data, to be used to estimate production for facilities without complete production data. 
 
3.    CokeOvens-Enclosures-1&2-QA-Whole_Industry-Emissions-Test-Data-Aug_2020 (Excel file) 
 All of the previously reviewed (by individual facility) run-by-run stack test (air) data for all pollutants from test facilities and the EPA calculations made using the test data to produce lb HAP/hr and lb HAP/ton coke emission factors for all HAP.
 Industry default emission factors to be used as default for all HAP, for facilities without test data, developed as described for Antimony in Example Emissions Calcs file. 
 Battery (physical) dimensions to be reviewed by industry facilities. 
 Oven and battery count from the ICR and previous EPA report (2001 BID). 
 Same CU (Capacity Utilization) and Erie production worksheets, as described above for the Example Emissions Calcs file.   
 All other test data submitted in the ICR, such as water and opacity tests, COG tests, material tests, etc., which may not be completely summarized, as yet, by the EPA. 
 
Next step will be for EPA to use the approach shown in the Example Emission file and data in the Whole Industry Emissions file to generate all HAP emissions for all coke facilities.  
 
If you have any questions before 9/28/20, please contact Gabrielle AND me by email, and one of us will get back to you. 
 
  * EP-1 BP Pushing (CD), EP-9 HNR Pushing (CD), EP-3 BP Combustion Stacks, EP-4 BP Boiler Stacks, EP-6 HRSG Main Stacks, EP-7 HRSG Bypass-Waste Heat Stacks, EP-8 HNR Charging (CD), EP-10 Quench Tower.
 
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.





