From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Monday, October 19, 2020 1:37 PM
To: 
Allen Dittenhoefer <adittenhoefer@montrose-env.com>; 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


Mr. Dittenhoefer-Good news. It was my error that I thought we did not have PAH data for quench towers. There was an error in the ICR summary tables and semi-vol was left off and not listed along with TSO for quench towers. So we will use the PAH data for quench towers for risk modeling. The purpose of including TSO in the coke ICR, with the specific HAP tests done at same time as TSO, was so that, if needed for any future standards, we could use TSO as a compliance method because its a simpler method. With concurrent test data we would be able to establish a correlation between the HAP modeled in risk assessment and TSO data. 

So we will NOT be using TSO in the risk assessment, but may use the TSO data if emissions standards need to be set. Due to the difficulty in testing anything in the quench towers, we could consider a work practice standard if standards need to be set. Hence, the other simultaneous nonair tests that were required during quench tower tests.  

Sorry for the confusion. 

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: 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


