From: 
Allen Dittenhoefer <adittenhoefer@montrose-env.com>
Sent:
Tuesday, December 22, 2020 11:46 AM
To: 
Jones, DonnaLee <jones.donnalee@epa.gov>; Raymond, Gabrielle <graymond@rti.org>
Cc:
Jeff Knight <jeffrey.knight@pillsburylaw.com>; Contact <dailor@accci.org>
Subject: 
Non-Category Emissions Spreadsheets/Burns Harbor Test Data


Dr. Jones,
 
Attached for your review are the five emissions spreadsheets dealing with non-category emissions.  Major comments on each spreadsheet are summarized below, and additional comments are in the spreadsheets.  Although Bluestone Coke is not a member of the COETF, they have provided their data inputs and corrections which we have included in the attached spreadsheets for ease of EPA's review.
 
We are also attaching a memo from Mostardi Platt that further supports using all of the Burns Harbor ICR pushing test data for semi-volatile compounds, dioxins/furans, and volatile organics (except for the Methylene Chloride results).
 
 Coke Ovens Method 303:  We concur with the emissions equations to be used for BSO emissions from charging, door leaks, and leaking lids and offtakes.  We have provided missing 2015 Method 303 data for Mountain State Carbon, Clairton, and Bluestone Coke, as well as data for EES Coke on the number of charges per year, and made a correction to Middletown's PLD.  We also made note of the fact that Batteries 2 and 3 at AKS-Follansbee were hot idled and did not operate in 2015.  As a result of these additions/corrections, EPA should have a complete set of Method 303 data and will not have to use industry averages for seconds/charge, PLD, PLL, and PLO for missing data.  Please let us know if you are missing any data.  
 Coke Flare Emissions:  Because flares are control devices, COE should not be modeled from these emission units.  This is because flares alter the composition of the emission stream such that the stream can no longer be identified as COE, as EPA recognized in its MACT I analysis. 
 Coke Fugitive Pushing:  In the SUM-Fug Push TPY tab, we provide 2015 coke production rates for batteries with missing or incorrect coke production data.  We recommend EPA use the battery-specific pushing capture efficiencies, based on actual pushing opacity data (which has been provided), not an assumed 95% efficiency for each battery.  In this spreadsheet, we reference the memo from Mostardi Platt regarding use of the Burns Harbor ICR pushing test data for semi-volatile compounds, dioxins/furans, and volatile organics (except for the Methylene Chloride results).
 Coke Ovens Example Emissions Calc Boiler-New Method:  In the EP-4 BP Boiler Stacks tab, we added missing boiler information for Plants A (Boilers 1-4) and H (Boilers 6, 7, 9, and 10 emitting through a single stack and Boiler 8 firing natural gas only).  We also added a note that Plant H has a Title V permit limit that limits the annual amount of COG that can be combusted in facility boilers, and that COG allocation should be based on that limit.
 Coke Byproduct Chemical Plant Emissions:  Our review of the 2017 NEI indicated that the NEI did not include all HAP emission estimates that were reported by the facilities in their annual emission inventory reports.  We have updated the Byproduct Chemical HAP tab with 2017 facility-reported HAP emissions, as well as supplemental emission calculations based on industry emission factors and 2017 coal charge/coke production quantities.  We also updated emissions for the Warren facility.  These emissions updates are highlighted in yellow in spreadsheet columns that we added adjacent to each facility column.  These revised emissions will require that EPA calculate new industry average HAP emissions in tab 2017 HAP EIS Sum.  
 
 
 
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



<< Copy of CokeOvens-Method303_for Industry review_COETF Comments rev122220.xlsx >>
<< Coke_Flare_Emissions_for Industry review_COETF Comments rev122220.xlsx >>
<< Coke_Fugitive_Pushing_for Industry review_COETF Comments rev121820.xlsx >>
<< Copy of CokeOvens-Example_Emissions_Calc-Boiler-New-Method-11-25-2020-for-Industry-Review COETF Comments rev122220.xlsx >>
<< Coke_Byproduct_Chemical Plant_Emissions COETF Comments rev122120.xlsx >>
<< MostardiPlatt Coke ICR BH Pushing Methylene Chloride 12.16.20.pdf >>



