From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Thursday, October 8, 2020 8:09 PM
To: 
Charles Jones <cjones@bluestonecoke.com>
Cc:
Don Wiggins <dwiggins@bluestonecoke.com>; Allen Dittenhoefer <adittenhoefer@montrose-env.com>; Raymond, Gabrielle <graymond@rti.org>
Subject: 
Re: Bluestone Coke: Whole industry QA review of Coke data and calculations


Mr. Jones: Hello again. We have looked through your files and have some answers to some, maybe all, of your questions. If we find any more questions of yours or have some of our own, we will contact you again.

#1 Must adjust hourly emission rates for pushing sampling time, i.e., multiply lb/hr values in column BG by ratio of (column N)/(60*column M)
EPA Response: Okay, will make adjustment.
#2 Should rows 2968-2969 be ADL instead of BDL?
EPA Response: Yes, thank you.
#3 Toluene Soluble Organic (TSO) and Methylene Chloride Extractable Matter Emissions from Control Devices not Applicable to Risk Assessment
Rows 2514-2516               Not applicable; battery stack is a control device
Rows 2811-2813               Not applicable; pushing baghouse is a control device
Rows 3108-3110               Not applicable; boiler is a control device
Rows 4417-4419               Not applicable; quench tower is a control device
EPA Response: We do not agree that TSO/MCEM are not applicable to the risk assessment. We will NOT model the data as coke oven emissions (COE) but we will model the data as benzene, to represent the TSO/MCEM. It was never said by EPA that emissions of COE were not to be counted because the emissions were after the control device, just that they would be modeled as the individual constituents, not as COE. 
#4 Questionable DLL Run Flag Designations
EPA Response: EPA only adjusts the emissions (by dividing in half) for runs with BDL flags, which means all fractions are BDL. For runs with DLL flag, not all the fractions are BDL, some are ADL. Therefore, we do not adjust on the fraction level. 
#5 File: CokeOvens-EstimatesAssumptions-Aug_2020 BluestoneCoke Comments 092120.docx
#5A Provided ATTACHMENT I Bluestone Coke  -  Plant Characteristics
EPA Response: Thank you for providing values; we will update our records.
#5B Provided ATTACHMENT II Recommended Approach for Estimating Boiler Emissions
EPA Response: Thank you for providing this approach. It seems to be a viable, maybe even a  more direct method of estimating emissions from boilers, if the COG flow quantities (mmscf/yr) are available. We will follow up with you if we have any questions on this approach. 
 
Thank you again for all your efforts to support our rulemaking. It is much appreciated.

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: Charles Jones <cjones@bluestonecoke.com>
Sent: Monday, September 28, 2020 5:10 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: Don Wiggins <dwiggins@bluestonecoke.com>; Allen Dittenhoefer <adittenhoefer@montrose-env.com>
Subject: Bluestone Coke: Whole industry QA review of Coke data and calculations 
 
Bluestone Coke: Whole industry QA review of Coke data and calculations
Dr. Jones:
Attached are the comments and corrections for the whole industry emissions test spread sheet and the EPA Emissions and Assumptions document.  We have also included a second spreadsheet which lists our recommended Boiler Emission Factors for the Foundry Coke Industry, based on the Erie Coke Boiler Test Data.
Please include Dr. Al Dittenhoefer on any communications concerning comments or questions about the attached documents.
Thank you,
Charles
 
From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov] 
Sent: Wednesday, August 26, 2020 10:32 AM
To: Rich.Zavoda@arcelormittal.com; Marian.Gammon@arcelormittal.com; 'Charles Jones'; Brenna M Harden; Robert B Sanch; Katie Batten; kesingleton@suncoke.com; BJTunno@uss.com; JSScheetz@uss.com
Cc: David Ailor (dailor@accci.org); Raymond, Gabrielle
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.


