From: 
David Ailor <dailor@accci.org>
Sent:
Friday, March 5, 2021 7:18 PM
To: 
Jones, DonnaLee <jones.donnalee@epa.gov>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: coke model files have gone to EPA division QA


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

Thanks again for the compiled modeling files you sent us on March 1.  The consultants who are assisting the Coke Oven Environmental Task Force (COETF) in the RTR effort, Montrose and AECOM, have started reviewing the populated emissions files.  They have identified several questions/issues that we wanted to call to your attention right away, so EPA does not get too far along in its QA review without correcting them.

Below is a list of questions/issues identified so far (we may have others as we continue our review):

PQBS category source file
 Industry average emissions factors vs. ICR test data at the same facilities  -  The emissions spreadsheet uses industry average emissions factors for all emission units that were not ICR tested, even when the same type of emission unit was tested at the same facility.  For example, for Burns Harbor baghouse #2 (which was tested), the spreadsheet uses the ICR test data-derived emission factors, but for baghouse #1 (which was not tested) the spreadsheet uses industry average emissions factors.  When ICR test data are available for a facility, we believe those data should be used for all similar emission units at the facility because ICR test data best reflect the particular type of coal, the same coking time and other operating practices, etc. and, so, is more representative than industry average emission factors.  We ask EPA to correct the spreadsheet to use the ICR test-derived emissions factors for all similar emission units at ICR tested facilities.
      
 Allowable emission rates  -  In many instances the allowable emission rates are orders of magnitude higher than the expected values based on maximum production levels.  It is unclear how EPA derived these values and some of the resulting emission rates are wholly implausible.  The allowable emission rate for each emission unit should be derived (as EPA did in the Taconite RTR, for example) by multiplying the actual emission rate of the emission unit by the ratio of the maximum production rate for the facility to the actual production rate for that facility in a representative year.  The COETF discussed this issue with EPA previously and provided the actual and maximum production rates for all COETF member facilities (see Table 1 below).  We ask that EPA use the actual-to-allowable ratios in Table 1 to calculate the allowable emission rates for each facility.

 Fugitive pushing emissions  -  The fugitive pushing emissions for gaseous pollutants are up to orders of magnitude higher than the correct values.  We believe this problem stems from the use of PM speciation factors for gaseous pollutants in the Coke_Fugitive_Emissions spreadsheet.  The PM speciation factor approach we recommended is applicable only to particulate pollutants, such as the HAP metals and semi-volatiles that were tested at the ABC Coke and Burns Harbor baghouse inlets by EPA in 1998.  Fugitive pushing emissions for gaseous pollutants, including the volatile HAPs and acid gases (HCl, HF, and HCN), should be calculated using the appropriate PQBS ICR industry test data-derived emission factor times the annual coke production, adjusted for the capture efficiency.  These emission factors, taken from the most recent (2/15/2021) Whole Industry Test Data Spreadsheet (Tab A-3. Industry Default EFactors), are listed in Table 2 below.

      For example, the HCl pushing emission factor for foundry coke plants is 1.00E-03 lb/ton coke.  For ABC Coke Battery No. 1, which produced 377,606 tons of coke in 2015, the total HCl emission from pushing would be:

      (1.00E-03 lb/ton coke)(377,606 tons coke/year)/(2000 lb/ton) = 0.189 ton/year
      
      Accounting for the pushing capture efficiency of 95.02%, the fugitive HCl emissions would be:

                  (0.189 tons/year)(1  -  0.9502) = 0.009 ton/year
                                          
      The Category Source file lists ABC Coke actual fugitive HCl emissions for Battery No. 1 at 6.68 tons/year, a factor of about 700 higher.  We ask that EPA correct these values using the appropriate ICR test data emission factors.
      
 Pushing baghouse emissions (ABC Coke)  -  The pushing baghouse emissions factors at ABC Coke are also significantly overstated.  It's unclear how the spreadsheet values were derived, so we ask EPA to provide the calculations, including the emissions factor that was used, so we can respond more fully.
      
 Production rates (ABC Coke)  -  The spreadsheet applies the coke production rate for Battery 1 to the North tower and the coke production rate for Battery 5-6 to the South tower.  These should be reversed.

Non-category source file
 Allowable emission rates  -  As with the source category file, the allowable emission rates for non-category sources are orders of magnitude higher than the expected values.  We ask that the actual-to-allowable ratios in Table 1 below be used to calculate the allowable emission rates for non-category sources.
      
 Acute emissions multiplier  -  The spreadsheet uses an annual-to-hourly emissions multiplier of 2.0 for all sources except flares, which has a multiplier of 10.  Why did EPA not use the same 2.0 multiplier?

 Inconsistent source heights  -  

          Cells AP4, 5, 7, 8, 10, 11, 13, 14, 16, 17 for ABC Coke have inconsistent battery heights in comparison to AP3, 6, 9, 12, and 15.  Please revise.
      
          Cells AP100-102, 104-106, 108-110, 112-114, 116-118 for AKS-Follansbee (Mountain State Carbon) have inconsistent battery heights in comparison to AP104, 107, 111, 115.  Please revise.

            *           *           *           *           *           *           *           *           *           *           *           *            *           *           *           *           *           *           *           *           *           *           *           *

We greatly appreciate your efforts addressing these questions/issues and look forward to EPA's responses.  Given the time sensitivity of EPA's QA review, the COETF can provide the corrected emissions files if doing so would be helpful and if EPA indicates that it will use the corrected files.  Please let us know.
Thanks, DCA

                        *           *           *           *           *           *           *           *           *           *           *           *           *           *           *           *           *           *           *           *           *           *           * *

Table 1:  Ratios of Actual-to-Potential Coal Charge to be Used for Estimating Potential Emissions from Actual Emissions
                                       
Table 2:  Pushing Emission Factors to be Used in the Calculation of Fugitive Pushing Emissions for Gaseous Pollutants
                                       

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: David Ailor [mailto:dailor@accci.org] 
Sent: Monday, March 1, 2021 1:07 PM
To: 'Jones, DonnaLee' <Jones.Donnalee@epa.gov>; 'KMBATTEN@suncoke.com' <KMBATTEN@suncoke.com>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: RE: coke model files have gone to EPA division QA

Agreed!  Thanks, Donna Lee.  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: Monday, March 1, 2021 12:46 PM
To: David Ailor (dailor@accci.org) <dailor@accci.org>; KMBATTEN@suncoke.com
Cc: GABRIELLE RAYMOND <graymond@rti.org>
Subject: coke model files have gone to EPA division QA

Hello David and Katie. Here are the compiled modeling files that I sent to my division for QA. It may take a couple of weeks (or more) for this review. We use an outside contractor to check these files, mostly for proper coding and mathematical inconsistencies.  At that point, if no errors or after errors are corrected, the files go on to the risk modelers who check for consistencies in modeling parameters and locations. At that point, if no errors or after correction of errors, we will post the files to the public NESHAP website while the risk modeling is being done. I will keep you both posted on all steps in the process. 

Thanks to you and your staff and collaborators for the help working with us to get the data in best condition possible. It's been a long, sometimes hard journey to this point, so we should all congratulate ourselves!

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.


