From: 
Allen Dittenhoefer <adittenhoefer@montrose-env.com>
Sent:
Wednesday, October 14, 2020 3:08 PM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc:
Knight, Jeffrey A. <jeffrey.knight@pillsburylaw.com>
Subject: 
COETF Comments on EPA "Whole Industry Test Data" Spreadsheet and "Estimates and Assumptions" Document


Dear Dr. Jones,
 
In response to your email of August 26, 2020, attached please find responses on behalf of the Coke Oven Environmental Task Force (COETF) on the EPA "Whole Industry Test Data" spreadsheet and the "Estimates and Assumptions" document.
 
Please note that our input on the Whole Industry Test Data spreadsheet is summarized in the "Review Instructions" worksheet, with recommended corrections highlighted in yellow within the various referenced worksheets.  We have also added an additional worksheet, labeled ADL_BDL, which provides our recommended changes to HAP metal emission rates that have split (i.e., ADL and BDL) run flag designations.  As explained in Item #10 of our responses on the Estimates and Assumptions document, the COETF supports the adjustment of emission rates at the fraction level (i.e., assigning one-half the detection level to sample fractions labeled as below detection), instead of assuming that the BDL fraction is 100% of the detection limit.
 
With regard to Item #6 of the Estimates and Assumptions document, the COETF is recommending an alternate approach to estimating COG-fired boiler emissions.  This alternate method is based on the development of lb/mmscf COG emission factors, rather than the lb/hr values proposed by EPA.  Attachment II to the Estimates and Assumptions document contains a listing of all COG-fired boilers, including their rated capacities, 2015 COG usage, and estimated potential annual COG usage. 
 
Please let me and Jeff Knight know if EPA has any questions regarding this submission. 
 
Allen C. Dittenhoefer, Ph.D.
Principal
 

 
Environmental Planning Specialists, Inc.
45 U.S. Highway 46 East
Suite 601
Pine Brook, NJ 07058
Direct:    (973) 575-2555 (Ext. 12705)
Mobile    (205) 447-6225
adittenhoefer@montrose-env.com
www.envplanning.com



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