From: 
Raymond, Gabrielle
Sent:
Tuesday, February 16, 2021 4:31 PM
To: 
Allen Dittenhoefer <adittenhoefer@montrose-env.com>
Cc:
Jones, DonnaLee <jones.donnalee@epa.gov>; Contact <dailor@accci.org>; Katie.Kistler@aksteel.com; Knight, Jeffrey A. <jeffrey.knight@pillsburylaw.com>; Kaplan, Mary <mary.kaplan@aecom.com>
Subject: 
RE: Review of Whole Industry Test Data, Coke Byproduct Chemical Plant Emissions, and Revised Clairton Byproducts Spreadsheet


Hello,

Thank you very much for your review on all the emissions files.
Below are the EPA responses and revised files attached. 

Whole Industry Enc 1&2: 
COETF Comment: It is our understanding that the lb/hr emission rates in the Erie Coke pushing test report already accounted for pushing sampling time.  It was just the dioxins and furans emission rates that we believe EPA needed to correct in the August 2020 version of the spreadsheet. 
EPA Response: Re-reviewed industry's August 2020 and confirmed comment about adjusting for pushing was only for D/F emissions. Fixed the non-D/F emissions that were incorrectly adjusted. 
No followup questions.
Revised file attached:
CokeOvens-Enclosure 1&2 QA-Whole IndustryTest Data-POST-Aug 2020_IndReview_2.15.2021.xlsx 
Byproducts: 
COETF Comment: For the Coke Byproducts Chemical Plant spreadsheet, we noted that we failed to include emissions from the Clairton aeration basin and byproducts pitch traps, which we have added.  Accordingly, we are including the revised stand-alone Clairton byproducts emissions spreadsheet that lists these emissions.  Please note that we have included these revised Clairton emissions in the "Clairton" tab of the industry byproducts spreadsheet.  The addition of these Clairton byproducts emissions was noted in the Coke 2017 EIS-NEI noncategory-other-units spreadsheet that Mary Kaplan is sending today, and we wanted to alert EPA of any inadvertent "double-counting" of these emissions. 
EPA Response: 
Thank you, will update file for Clairton revisions, industry averages, and final facility TPY values. 
Will cross check the Coke 2017 EIS-NEI noncategory-other-units spreadsheet to delete any double counting of emissions.
No followup questions.
Revised file attached: Coke_Byproduct_Chemical Plant_Emissions_02-15-2021.xlsx
Method 303: 
COETF Comment: We have no comments
EPA Response: Thank you for your final review.
Fugitive Pushing: 
COETF Comment: We have no comments 
EPA Response: Thank you for your final review.
The Whole industry Enc 1&2 file revisions resulted in changes to the foundry emission factors used in this file, updated values.
Revised file attached:
Coke_Fugitive_Pushing_02-15-2021.xlsx
Boilers: 
COETF Comment: We have no comments
EPA Response: Thank you for your final review. 
Flares: 
COETF Comment: We have no comments
EPA Response: Thank you for your final review.


Thank you again for all your help!
Gabrielle


Gabrielle Raymond
she/her/hers 
RTI International
3040 Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709
Phone:  (919) 541-7015


<< CokeOvens-Enclosure 1&2 QA-Whole IndustryTest Data-POST-Aug 2020_IndReview_2.15.2021.xlsx >>
<< Coke_Byproduct_Chemical Plant_Emissions_02-15-2021.xlsx >>
<< Coke_Fugitive_Pushing_02-15-2021.xlsx >>


From: Allen Dittenhoefer <adittenhoefer@montrose-env.com> 
Sent: Friday, February 12, 2021 2:10 PM
To: Raymond, Gabrielle <graymond@rti.org>
Cc: Jones, DonnaLee <jones.donnalee@epa.gov>; Contact <dailor@accci.org>; Katie.Kistler@aksteel.com; Knight, Jeffrey A. <jeffrey.knight@pillsburylaw.com>; Kaplan, Mary <mary.kaplan@aecom.com>
Subject: Review of Whole Industry Test Data, Coke Byproduct Chemical Plant Emissions, and Revised Clairton Byproducts Spreadsheet


Hello Gabrielle,
 
Attached please find our comments on the latest Whole Industry Test Data and Coke Byproduct Chemical Plant spreadsheets, as well as a revised Byproducts spreadsheet for Clairton.
 
In the Whole Industry Test Data spreadsheet, we discovered that EPA apparently misinterpreted our Aug-Sept 2020 comments on the Erie Coke pushing test data and made push sample time adjustments to all of the pollutants, instead of just the dioxins and furans.  It is our understanding that the lb/hr emission rates in the Erie Coke pushing test report already accounted for pushing sampling time.  It was just the dioxins and furans emission rates that we believe EPA needed to correct in the August 2020 version of the spreadsheet.  
 
For the Coke Byproducts Chemical Plant spreadsheet, we noted that we failed to include emissions from the Clairton aeration basin and byproducts pitch traps, which we have added.  Accordingly, we are including the revised stand-alone Clairton byproducts emissions spreadsheet that lists these emissions.  Please note that we have included these revised Clairton emissions in the "Clairton" tab of the industry byproducts spreadsheet.  The addition of these Clairton byproducts emissions was noted in the Coke 2017 EIS-NEI noncategory-other-units spreadsheet that Mary Kaplan is sending today, and we wanted to alert EPA of any inadvertent "double-counting" of these emissions.  We apologize for any inconvenience this has caused.
 
We have no comments on the Method 303, fugitive pushing, boilers, and flare emissions spreadsheets.
 
Best regards,
 
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





