From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Thursday, October 29, 2020 11:43 AM
To: 
BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc:
Raymond, Gabrielle <graymond@rti.org>; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Subject: 
Re: (Draft) Coke Model file "shell" for industry review


Hi Katie - Thanks for the information. Yes, I would like the contact information for Coke Energy. We will need to include the emission source in the modeling, but we will correct the "facility" name. This source is currently in between category and noncategory classifications, meaning that its not currently regulated but might be in the future. We include noncategory emissions in the model file along with category, so regardless of the current classification, it will get modeled.

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: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Sent: Thursday, October 29, 2020 10:26 AM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: GABRIELLE RAYMOND <graymond@rti.org>; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Subject: RE: (Draft) Coke Model file "shell" for industry review 
 
Hi Donna Lee,
 
Thank you for providing us with the opportunity to comment on these files and make corrections where needed.  
 
As we were reviewing the information in the spreadsheet, we noticed that a main stack associated with SunCoke's Indiana Harbor facility was included in the modeling file.  See for example Tab 3, Row 118.  This main stack should not be included in the modeling because it (as well as the heat recovery steam generators and FGD upstream of the stack) is owned and operated by another company, Cokenergy LLC.  Accordingly, emissions from this stack are permitted and reported separately from Indiana Harbor Coke Company.  At any rate, we would not be able to verify the parameters of this main stack because it is not ours, but I could provide you with contact information for someone at Cokenergy if needed.
 
Thanks,
 
Katie Batten
Director of Health, Safety and Environmental
 
SunCoke Energy, Inc.
kmbatten@suncoke.com
cell: 740-370-8710
 
From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Thursday, October 15, 2020 3:44 PM
To: Jay Cornelius <jcornelius@abccoke.com>; Bill Osborn <bosborn@abccoke.com>; Katie.Kistler@aksteel.com; Chris.Potts@aksteel.com; Marian.Gammon@arcelormittal.com; 'Charles Jones' <cjones@bluestonecoke.com>; Brenna M Harden <brenna.harden@dteenergy.com>; Robert B Sanch <robert.sanch@dteenergy.com>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>; BJTunno@uss.com; JSScheetz@uss.com; Patrick Smith <patrick.smith@mscarbonllc.com>; Rich.Zavoda@arcelormittal.com
Cc: GABRIELLE RAYMOND <graymond@rti.org>; David Ailor <dailor@accci.org>
Subject: (Draft) Coke Model file "shell" for industry review
Importance: High
 
 
Hello all (hope I got everyone this time😀): Thank you again for your review comments on the emission factors and ICR data. While we are processing your comments, a good use of our time would be for you all to review the physical parameters in the model file, what we call the "shell" of the model file. 
 
The modeling file is currently organized in four main tabs (model "shell" only, i.e., not including emissions yet):
 
 Coke Category CCCCC  -  pushing, quench tower, combustion stack, HRSG main stack, HRSG bypass/waste stack, flares, and fugitive pushing
 Coke Noncategory  Coke 63L -  charging, lids, offtakes, doors
 Coke Noncategory Byproduct Chemical Plant
 Coke Noncategory, Other  -  boilers and all other units available from 2014 HAP NEI
The physical parameters in the model shell include data such as stack heights (point and fugitive heights), diameters, latitude and longitude (to five decimal places, confirmed in Google Maps),* flowrate, temperature, and velocity that were reported in the Coke ICR Enclosure 1, obtained from the 2014 or the 2017 EIS,[1][1] or estimated (calculated from other stack parameters, e.g., velocity from stack diameter and flowrate), values from the 2003 RTR modeling report, values from 2001 BID, values from EPA's Stack Parameter Default database, or values from Coke Enclosure 2 test data (e.g., Temperature and Velocity) for facilities that did not participate in the ICR. The model shell includes battery physical dimensions of fugitive length, fugitive width, and fugitive height that have been updated with your comments on the emission factor data we received in the last few weeks.
 
* Stacks/point sources will have one (1) set of lat/long (control device exhaust and quench tower): Y_COORDINATE and X_COORDINATE. Fugitive 2-dimensional sources (all coke fugitives) will have 2 sets of lat/long for fugitive emissions originating from batteries for modeling purposes (mobile BP/HNR pushing; BP/HNR charging; pushing fugitives; and subpart L sources for door, lids, and offtakes): 
 
      FUGITIVE_2D_MIDPOINT1_Y_COORDINATE
      FUGITIVE_2D_MIDPOINT1_X_COORDINATE
      FUGITIVE_2D_MIDPOINT2_Y_COORDINATE
      FUGITIVE_2D_MIDPOINT2_X_COORDINATE
 
Please review this attached Excel file and provide your additions or corrections in the comment columns. You can expand the width of the comment columns as needed (we have made them narrow in attached file to make viewing easy).
 
Please provide your comments by Monday, November 9, 2020. While you and your company are reviewing the model shell, we will be incorporating your comments on the previous emission factor file and developing emission estimates for all emission points and all facilities. I also will send out this completed emissions file for industry review, which will likely be about same time we receive your comments on the model file.  
 
Soon after we receive your comments on the complete emissions file and model file shell, we may want to have a conference call to discuss all the changes and final files.
 
The last step will be to copy the annual emissions from the emissions file into the model file and send the model for EPA QA review. A revised model file will be posted to the coke oven subpart CCCCC NESHAP web page simultaneous with start of preliminary risk modelling. 
 
Thank you again for all your work on these files.
 

[2][1] Note, NEI 2017 is not complete at this time; the NEI 2014 has stack parameters that the NEI 2017 does not have right now, which were needed to populate the modeling file. However, we were able to obtain an advance copy of the 2017 Emission Inventory System (EIS), which will feed into the 2017 NEI. We used the most recent data, where available.
 
 
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.


