From: 
David Ailor <dailor@accci.org>
Sent:
Thursday, November 12, 2020 1:03 PM
To: 
Jones, DonnaLee <jones.donnalee@epa.gov>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: (Draft) Coke Model file "shell" for industry review


Hello again, Donna Lee.  Hope you're well.

Attached is the COETF's markup of the draft Coke Model file "shell" you sent us on October 15 for review.  Please note that:

 the markup does not include any information on facilities operated by Bluestone Coke or SunCoke, as neither is a member of the COETF; and,

 the markup includes two new tabs that the COETF added to provide information EPA requested - tabs 17 ("Method 303 Data") and 18 ("F Prime Data").

We are working diligently to complete the other action items from our October 29 meeting and will send them to you as soon as we can.

Please contact me if you have any questions.  DCA

David C. Ailor, P.E.
President
American Coke and Coal Chemicals Institute
25 Massachusetts Avenue, N.W.
Suite 800
Washington, D.C. 20001
Phone: 703-795-3541
eFax.: 866-422-7794
dailor@accci.org
www.accci.org



<< CokeOven_CategoryNonCategory_RTR_ModFile_20201111-COETF MARKUP 111220.xlsx >>



From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov] 
Sent: Monday, November 9, 2020 4:40 PM
To: David Ailor <dailor@accci.org>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: Re: (Draft) Coke Model file "shell" for industry review

That's fine. Do you have any idea in regard to timing for the remaining action items from our meeting, below?

 Industry will provide an email regarding ArcelorMittal Burns Harbor pushing semi-volatile HAP (PAH, D/F) test discarded results to be passed along to the EPA test method expert for additional review.
 Industry will provide any additional facility information needed to calculate subpart L source emissions.
 Industry will provide background data and equations to support revised F prime modeling parameters.


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: David Ailor <dailor@accci.org>
Sent: Monday, November 9, 2020 4:33 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: RE: (Draft) Coke Model file "shell" for industry review 
 
Hello again, Donna Lee.  Hope you're well.
 
I'm reaching out to report to you on where the COETF stands today on its review of the model "shell" file.
 
I'm sorry to report that, as of today, our review is still ongoing; and we will not be able to meet your deadline of today to comment.  That said, we do anticipate being able to send you our comments later this week, and hope you can accommodate us in this regard.
 
We appreciate your understanding in this regard, and hope this does not present a problem.  Please contact me if you have any questions.  DCA
 
David C. Ailor, P.E.
President
American Coke and Coal Chemicals Institute
25 Massachusetts Avenue, N.W.
Suite 800
Washington, D.C. 20001
Phone: 703-795-3541
eFax.: 866-422-7794
dailor@accci.org
www.accci.org


 
From: Jones, DonnaLee [mailto: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>; Katie Batten <kmbatten@suncoke.com>; 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.





