From: 
Allen Dittenhoefer <adittenhoefer@montrose-env.com>
Sent:
Friday, October 16, 2020 1:30 PM
To: 
Jones, DonnaLee <jones.donnalee@epa.gov>; Charles Jones <cjones@bluestonecoke.com>
Cc:
Don Wiggins <dwiggins@bluestonecoke.com>; Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: Bluestone Coke: Whole industry QA review of Coke data and calculations


Dr. Jones,
 
Thank you for your email of October 8, 2020, in which you responded to the comments we provided on the EPA Whole Industry Test Data Spreadsheet and the Estimates and Assumptions document.  Below I provide, on behalf of Bluestone Coke, further comments regarding your response to items #3 contained in your email. 
 
Item #3: Toluene Soluble Organic (TSO) and Methylene Chloride Extractable Matter (MCEM) Emissions not Applicable to Risk Assessment
You stated in your response to Item #3 regarding TSO and MCEM emissions that EPA will model the measured emissions of TSO/MCEM as benzene and not as Coke Oven Emissions (COE).  You later stated in your response that EPA will model the "individual constituents" of COE.  It is not clear from your response what you mean by "individual constituents." 
 
We agree that TSO/MCEM emissions should not be modeled using the Unit Risk Estimate (URE) of COE.  However, TSO/MCEM emissions should be modeled using the cumulative risk from the PAH constituents of COE, not as benzene emissions.  Benzene is a volatile organic compound, for which ICR testing using SW-846 Method 0031 for speciated volatile organic HAPs was conducted.  COE, on the other hand, is comprised mainly of PAHs, which are semi-volatile organic compounds that exist in vaporous form at the high temperatures inside the coke ovens and condense into particulate matter (PM) upon release to the cooler atmosphere.  The test method for TSO and MCEM (Method 315) basically uses a Method 5 sampling train designed to capture filterable and condensable PM, followed by extraction of organic material using a solvent (i.e., toluene or methylene chloride).  Accordingly, it would not be appropriate to model TSO/MCEM (PM emissions) as benzene (a volatile organic compound).  Because the PQBS risk assessment will also include the predicted risk from benzene emissions using Method 0031-derived test data, modeling of TSO/MCEM emissions as benzene would also improperly double-count benzene.
 
The modeling of the cumulative risk from the constituents of COE (i.e., PAH compounds) in place of COE emissions from control devices, such as pushing baghouses and quench towers, and combustion units such as battery stacks and boilers, is consistent with the approach EPA used in the MACT I (Subpart L) coke industry residual risk assessment (U.S. EPA, Risk Assessment Document for the Coke Oven MACT Residual Risk, December 22, 2003).  EPA stated that this is because the control device or combustion process alters the composition of the COE emission stream, such that the stream can no longer be identified as COE (e.g., see pp. 8 and 15).  On page 6 of this document, EPA stated that "benzene soluble organics (BSO) comprise the semi-volatile organic constituents of coke oven emissions that are soluble in benzene.  While some constituents are not benzene-soluble, BSO is considered an appropriate surrogate for quantifying coke oven emissions."    
 
In addition, we note that the URE for COE was derived from epidemiologic data for coke oven workers exposed to raw COG emissions at the battery tops and sides (i.e., coke battery charging, door and topside leaks, and fugitive pushing emissions), and not from exposure to emissions from battery and boiler stacks, nor from pushing control devices and quench towers.
 
In summary, the cancer risk assessment for emissions from battery stacks, pushing control devices, quench towers, and boilers should be modeled using the cumulative risk from the PAH constituents of COE, using the ICR PAH test database, and not as COE or benzene. 
 
Thank you for your consideration.
 
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
 
 

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.


