From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Tuesday, March 30, 2021 2:49 PM
To: 
David Ailor <dailor@accci.org>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: coke model files have gone to EPA division QA


David -- Here are the EPA responses to your last set of suggestions. We may not need to meet on this but likely might need to discuss the buoyancy. I will check with Matt and Chris to see when they can meet. Matt is out this week (and maybe previous week also) and wont be back until 4/5. 

Revisions Made
- Using emission factors from same facility testing to fill in for similar units and calculate TPY emissions, rather than industry-average emission factors.
- Fugitive Pushing units TPY emissions for Acid Gases, D/F, and Semi-volatile HAP: Removed the use of PM uncontrolled emissions from the calculation approach and corrected to only use ICR industry test data-derived emission factors with coke production and capture efficiency.
- TPY emissions for ABC Coke North and South Quench Towers: Reversed the applied coke production rate; corrected to: Battery 5-6 to the North tower and Battery 1 to the South tower; recalculated emissions.
- TPY emissions for Bluestone Coke North and South Quench Towers: reversed the applied coke production rate; corrected to: Battery 5 to the North tower and Battery 3-4 to the South tower; recalculated emissions.
-Revised Flare acute factor from 10 to 2: Corrected to align with factor used for all other sources.
-Revised AKS-Follansbee-WV Flare Mercury and Benzene values to reflect 2017 EIS/NEI coke oven gas flaring values only, 0.42 Benzene TPY and 0.000485 Mercury TPY.

Revisions Not Made - Allowables
EES Coke - quench tower
Monessen - Battery Stack
Warren - Battery Stack 
All charging, lids, doors, offtakes, 

Rationale: The EPA must use rule limits for allowables. Permits and SIPs can change; these are not permanent like rules. However, the information provided by facilities will be very useful if there are high risks showing with the modeling. We have used facility-specific information in the past when allowables were high risk for individual facilities. I believe we are looking for a trend in high risk for most of the facilities when we model emissions at the rule limit, i.e. allowables. I've not seen this situation happen myself or heard of anything, so I can't provide an example right now but I will ask. 

I don't think we need to meet on this but likely for the buoyancy issue. I will be in touch when Matt gets back.

Thanks again for everyone's help with the model file.

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 30, 2021 11:45 AM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: [SPAM-Sender] RE: coke model files have gone to EPA division QA

Hello again, Donna Lee.

I'm circling back to see if we can schedule a call with you and your project team to discuss our comments on the modeling files, as well as our F' White Paper.  Could we schedule something the week of Monday, April 5, by chance?  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


