From: 
SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Sent:
Saturday, November 14, 2020 2:30 PM
To: 
Jones, DonnaLee <jones.donnalee@epa.gov>
Cc:
Raymond, Gabrielle <graymond@rti.org>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Subject: 
RE: (Draft) Coke Model file "shell" for industry review


Hi Donna Lee,

Thank you for the opportunity to provide comments and revisions. We have a number of revisions to provide, which are described below in each section. We have used the comment columns in the spreadsheet to provide revised values according to the sections below. For your convenience, the spreadsheet tabs `3-CCCCC' and `4-Noncategory-63L' are filtered for SunCoke facilities only, and show only columns where revised values are provided, which are highlighted in orange.

Section 1: Gateway Energy & Coke Co., Haverhill Coke Co., Middletown Coke Co.
 Pushing stack: the Gateway and Middletown facilities should have a single point source to represent pushing emissions from all batteries and the Haverhill facility should have two point sources, as listed in the ICR reports for each facility. The single point source represents the flat push hot car stack, through which pushing emissions are discharged.  The flat push hot car has one stack that is controlled by a multiclone.   The flat push hot car is shared among all the batteries at the Middletown and Gateway facilities.  At the Haverhill facility, Haverhill 1 has a flat push hot car, which is shared between all 100 ovens on the A and B batteries and Haverhill 2, has a flat push hot car that is shared between all 100 ovens on the C and D batteries.  
 Charging stack (noncategory, 63L): the Gateway and Middletown facilities should have a single point source to represent charging emissions from the pusher/charger machine (PCM) stack from all batteries and the Haverhill facility should have two point sources for the two PCM stacks, as listed in the ICR reports for each facility. The single point source represents the emission point for this source, a single stack that is controlled by a baghouse.  The pusher/charge machine is shared among all the batteries at the Middletown and Gateway facilities.  At the Haverhill facility, Haverhill 1 has a pusher/charger machine, which is shared between all 100 ovens on the A and B batteries and Haverhill 2, has a pusher/charger machine that is shared between all 100 ovens on the C and D batteries.  
 Revisions to various source parameters (e.g. release height, stack temperature, etc.) to be consistent with the ICR reports and other stack test data for each facility.
 Revisions to total annual hours of operation: pushing, charging and quenching occur for 8 hours/day at Gateway and Middletown facilities, and 16 hours/day at the Haverhill facility.  Please note that this is total for the facility each day, not for each battery, therefore, hours for each battery will be a fraction of the total daily hours.  Bypass vent stacks operate intermittently and are permitted to emit for a limited number of hours per year:
 SC-GraniteCity-IL: 312 hours per stack (pg. 21, section 4.1.5, 1872 total permitted stack-hours per year divided by 6 bypass stacks)
 SC-FranklinFurnace-OH: 192 hours per stack for 10 stacks (a total of 1920 hours per year for ten stacks - pg. 38, "P901, Waste Gas from Coking, Charging, & Pushing (AB Battery)" and pg. 88, "P902, Waste Gas from Coking, Charging, & Pushing (CD Battery)")
 SC-Middletown-OH: 312 hours per stack (pg. 98, section 6.b, 1560 total permitted stack-hours per year divided by 5 bypass stacks)
Section 2: Jewell Coke and Coal
 Pushing sheds: pushing emissions are controlled by sheds, which are best represented as four buoyant line sources. Additional parameters for buoyant line sources are provided in a separate spreadsheet (Suncoke_BuoyantLineParameters.xlsx). 
 Charging stack (noncategory, 63L): should have four (4) rather than six (6) point sources to represent charging emissions from each of the four PCM stacks.
 Pushing fugitives: revisions to release height.
 Quench towers and vent stacks: revisions to source parameters.
 Revisions to total annual hours of operation: pushing, charging and quenching occur for 8 hours/day. Please note that this is total for the facility each day, not for each battery, therefore, hours for each battery will be a fraction of the total daily hours.  
Section 3: Indiana Harbor Coke Co.
 Charging stack (noncategory, 63L): should have two (2) point sources to represent charging emissions from the PCM stack shared by batteries A/B and the PCM stack shared by batteries C/D.
 Pushing fugitives: revisions to release height.
 Pushing stack, quench towers, and vent stacks: revisions to source parameters.
 Main stack:  As we've discussed, the main stack associated with Indiana Harbor is independently owned and operated by another company, Cokenergy, LLC, so SunCoke is unable to comment on the parameters associated with this stack.
 Revisions to total annual hours of operation: pushing, charging and quenching occur for 16 hours/day.  Please note that this is total for the facility each day, not for each battery, therefore, hours for each battery will be a fraction of the total daily hours.  Bypass vent stacks operate intermittently and are permitted to emit for a limited number of hours per year: 1139 hours per year for each stack (13% annual venting limit, equal to 0.13*8760 = 1,139 hours total per year, pg. 36, section D.1.9(c)).

Thank you for the additional time to review the files. I think the provided data will answer most of the questions from your 10/14 email, however, I will review and follow-up on any additional questions you raised. Please let us know if you have additional questions.
Thanks,

Kris

Kris Singleton
Corporate Engineer  -  
Health, Environmental & Safety

 SunCoke Energy
office:  513-727-5518
cell:  513-649-1371

<< Suncoke_BuoyantLineParameters.xlsx >>
<< CokeOven_CategoryNonCategory_RTR_ModFile_20201015-Suncoke_comments.xlsx >>
From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Tuesday, November 10, 2020 11:02 AM
To: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: GABRIELLE RAYMOND <graymond@rti.org>; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Subject: Re: (Draft) Coke Model file "shell" for industry review

Yes, that's fine.

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: Tuesday, November 10, 2020 8:46 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,
 
Sorry for the delayed response, but I was out of the office for a few days.  The contact person for Cokenergy is Luke Ford.  His contact info is below.  As for our comments on the modeling file, would it be ok if we get those to you by the end of this week?  
 
 
Luke E. Ford
Director EH&S
Primary Energy 
3210 Watling St.
MC 2-991
East Chicago, IN 46312
 
Email  lford@primaryenergy.com
Office   (219) 397-4626
 
 
Katie Batten
Director of Health, Safety and Environmental
 
SunCoke Energy, Inc.
kmbatten@suncoke.com
cell: 740-370-8710





