From: 
Allen Dittenhoefer <adittenhoefer@montrose-env.com>
Sent:
Wednesday, October 14, 2020 3:45 PM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc:
Knight, Jeffrey A. <jeffrey.knight@pillsburylaw.com>
Subject: 
Pushing Capture Efficiencies


Dear Dr. Jones,
 
As a follow-up to our July 29, 2020 virtual meeting and our August 24, 2020 submittal, attached is a table summarizing the pushing capture efficiency estimates for the by-products recovery coke industry.  These estimates were based on: a) one or more years of battery-specific pushing opacity data and b) the theoretical relationship between plume opacity and pollutant concentration, as described in Item #3 of our August 24 submittal.  I have also attached the raw plant data files that support the pushing capture efficiency estimates. 
 
As before, the table below identifies the plant codes for each by-product recovery plant.  Coke plant codes were used in the COETF's submission in order to maintain company proprietary information as confidential.  We also request that EPA treat these plant identifiers as confidential.  
 

                                  Plant Code
                                  Plant Name
               Proprietary and Company Confidential Information
                      Subject to 40 CFR Part 2, Subpart B
 
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




Proprietary and Company Confidential Information
Subject to 40 CFR Part 2, Subpart B

<< Pushing Capture Efficiencies Final 101420.pdf >>
<< Middletown PushOpacityTracking 2019 to August 2020.xls >>
<< ArcelorMittalMonessen_Pushing_Tracking_Nov 2018  9.29.20.xlsx >>
<< Pushing Capture BurnsHarbor 20190101 to 20200630 081120.xlsx >>
<< Clairton Batt 123 2019 Push Opacity 082720.xlsx >>
<< Clairton 2019 Push Opacity 13 14 15 Batteries 082820.xlsx >>
<< Clairton 2019 Push Opacity 19 20 Batteries 082820.xlsx >>
<< Clairton 2019 Push Opacity Battery B 082820.xlsm >>
<< Clairton 2019 Push Opacity Battery C 082820.xlsx >>
<< ABC Coke 2016 Push Method 9.xlsx >>
<< Mountain State Pushing Fugitives M9 2019 to present All Batteries.xlsx >>
<< Warren Push Data 2012-2019.xlsx >>


