From: 
David Ailor <dailor@accci.org>
Sent:
Wednesday, March 17, 2021 7:04 PM
To: 
Jones, DonnaLee <jones.donnalee@epa.gov>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: COMMENTS? -- coke model files have gone to EPA division QA


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

Thanks again for the time to respond on these issues.  Below are the COETF's responses to EPA's March 9, 2021, requests relating to "PQBS category source file" issue nos. 1, 3, 4 and 5 and "Non-category source file" issue nos. 2 and 3.  Note that we are still reviewing EPA's allowable emission rate files for both the PQBS category and Non-category source files and will provide separate responses on those issues as soon as possible. 

PQBS category source file

 Industry Average Emission Factors vs. ICR Test Data at Same Facility  -  EPA requested that the COETF identify the affected facilities/units where ICR test data should be used for untested units at the same facility.  The attached spreadsheet (see "Emissions for Non-Tested Units at Facilities that Tested 031621.xlsx") provides the corrected actual emissions (TPY) incorporating these changes.  The affected facilities and emission units are:
      
          Clairton Battery Stacks for Batteries 1, 2, 3, 13, 14, 15, 19, 20, and C (Battery B Stack was ICR tested);
          Monessen Battery 1B Stack (Battery 2 Stack was ICR tested); 
          Burns Harbor Battery 1 Stack (Battery 2 Stack was ICR tested); and,
          Burns Harbor Battery 1 Pushing Baghouse (Battery 2 Pushing Baghouse was ICR tested).
         
 Allowable Emission Rates  -  Under review
      
 Fugitive Pushing Emissions  -  The COETF agrees with EPA's responses dated March 9, 2021, on the fugitive pushing emissions for acid gases, dioxin/furans, and volatile HAPs.

 Pushing Baghouse Emissions (ABC Coke)  -  The COETF agrees with EPA's responses dated March 9, 2021, on the ABC Coke Pushing Baghouse emissions estimates.

 Production Rates (ABC Coke)  -  The COETF agrees with EPA's responses dated March 9, 2021, on the coke production rates as they are applied to the ABC Coke Quench Tower emission estimates.  Please note that the coke production rates applied to the Bluestone Coke Quench Towers should also be reversed.  The Bluestone Coke North Quench Tower serves Battery 5 and the South Tower serves Batteries 3 and 4.

Non-category source file

 Allowable Emission Rates  -  Under review
      
 Acute Emissions Multiplier  -  The COETF still believes that EPA should use an annual-to-hourly scale-up factor of 2.0 for all sources, including emergency flares.  The 2.0 factor is more appropriate because it is derived from maximum charging/pushing rates, while the 10 factor is simply based on the facility (Burns Harbor) that has the greatest number of emergency flares and is not related to allowable emissions.

 Inconsistent Source Heights  -  The COETF agrees with EPA's response dated March 9, 2021, on the physical battery heights.

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


<< Emissions for Non-Tested Units at Facilities that Tested 031621.xlsx >>



From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov] 
Sent: Friday, March 12, 2021 6:10 PM
To: David Ailor <dailor@accci.org>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: RE: COMMENTS? -- coke model files have gone to EPA division QA

Thanks for the update.

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: Friday, March 12, 2021 3:33 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: RE: COMMENTS? -- coke model files have gone to EPA division QA

Hi, Donna Lee.  Thanks for being patient with us on this.

Rest assured that our top priority at the moment is responding to you on the questions/comments you sent us this week.  We're working our way through all of them as quickly as we can.

We plan to respond to you by next Wednesday (March 17) on most of them, including those that pertain to "PQBS category source file" issue nos. 1, 3, 4 and 5 and "Non-category source file" issue no. 3.  On the remaining questions/comments, which pertain to files we had not seen until this week (i.e., "PQBS category source file" issue no. 2 and "Non-category source file" issue nos. 1 and 2), we are still working our way through them and do not have a definitive date for you yet.

Please contact me if you have 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: Friday, March 12, 2021 12:05 PM
To: David Ailor <dailor@accci.org>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: RE: COMMENTS? -- coke model files have gone to EPA division QA

Hi  -  When do you think the industry will have comments? We need to move forward next week. 

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: Tuesday, March 9, 2021 10:18 AM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: RE: coke model files have gone to EPA division QA

Glad to answer any questions you have, Donna Lee.

In that regard, the COETF is having a call Wednesday morning on several matters.  We'll target responding to you afterwards on your question on issue no. 1 with a list of emission units that should be changed from industry average values to ICR test values.

In advance of that call, we'd appreciate your questions/comments on the other issues we raised  -  particularly issue nos. 2 and 3 for the source category files.  That will allow us to make good use of our call and respond back to you expeditiously.

Thanks, 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 8, 2021 7:37 PM
To: David Ailor <dailor@accci.org>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: RE: coke model files have gone to EPA division QA

In regard to #1, other than Burns Harbor baghouse #2, what are the other facilities/units where there were units that were tested and could be used for untested units at same facility? This is a surprising comment because we provided in the first files we sent our approach to filling in missing data. Looking back in my notes, the discussion was focused heavily on whole facilities that did not test, and not on untested units at (partially) tested facilities. Since there weren't many facilities that tested, Im hoping there aren't too many of these cases because this change would propagate through a lot of files.


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: Friday, March 5, 2021 7:18 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: 'GABRIELLE RAYMOND' <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.





