From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Thursday, March 18, 2021 12:29 PM
To: 
David Ailor <dailor@accci.org>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
Adding comment RE: COMMENTS? -- coke model files have gone to EPA division QA


Hello David -  Gabrielle had a comment to add.

#3. Note, we are not modeling emergency flares. We are modeling the Excess Oven Coke Gas Flares and used an acute factor of 10 taken from the number of emergency flares. 


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: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Wednesday, March 17, 2021 8:27 PM
To: David Ailor <dailor@accci.org>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: RE: [SPAM-Sender] RE: COMMENTS? -- coke model files have gone to EPA division QA

Thank you for your responses. Please let me know when you think we can receive the remainder of your comments. 

A couple of additional points.

 The paragraph # 2 below under noncategory has mixed two different variables. Acute emissions are not the same as allowable emissions. Possibly this is a typo. Acute emissions are intended to reflect the highest hourly rate possible during the year.
 I spoke with my group leader who worked closely with the project leader for Taconite. My group leader said that I am determining allowables the way they should be determined, i.e., based on the standard and should continue to do so. I mentioned the Taconite rule as something you all were citing and he said to ignore the procedures used in the Taconite rule. I am not aware of the details of the Taconite rule so I can't discuss further but, as I mentioned, my other RTR was done the same way as we are doing now for coke allowables, for emissions where there is a standard.

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: Wednesday, March 17, 2021 7:04 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: [SPAM-Sender] 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


