MEMORANDUM   

DATE:		04/23/2021

TO:	National Emission Standards for Hazardous Air Pollutants: Coke Ovens: Pushing, Quenching, and Battery Stacks Residual Risk and Technology Review; Docket ID: EPA-HQ-OAR-2002-0085

FROM:	Donna Lee Jones, U.S. EPA, Office of Air Quality Planning and Standards (OAQPS), Research Triangle Park, NC; Gabrielle Raymond, RTI International, Research Triangle Park, NC 

SUBJECT:	Conference call with Coke Industry Representatives   
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Summary

      A telephone conference call was held on April 22, 2021, between the EPA, the Coke Oven Environmental Task Force (COETF) of the American Coke and Coal Chemicals Institute (ACCCI), and coke ovens company representatives as a follow-up to the ICR emissions data review performed by the COETF as part of the residual risk and technology review (RTR) for Pushing, Quenching, and Battery Stacks (PQBS) NESHAP (40 CFR part 63, subpart CCCCC), and for the technology review of Coke Oven Batteries (40 CFR part 63, subpart L). The main topic of discussion were the emissions to be used in risk modeling. 
      
      Industry representatives summarized their own development of F prime values used in the buoyant line plume (BLP) model. Industry representatives discussed the number of batteries, plume heights, coke production, and heat generation for the United States (U.S.) Steel Clairton plant as compared to other coke plants. Industry representatives also discussed the impacts of modeling combined batteries versus modeling them individually, specifically in regard to the U.S. Steel Clairton plant that has several parallel batteries. Industry representatives stated that more information about the U.S. Steel Clairton plant and its uniqueness could be provided, if needed. The EPA indicated that they believed they had what was needed, but if the COETF wanted to provide a written statement on U.S. Clairton's unique attributes it would be helpful for documentation purposes. 
      
      Industry representatives stated that they believed the Method 303 allowable emissions for subpart L sources should not be based on the emission limits in the rule (rolling monthly average as per § 63.309(d)). They believe adjustments are needed because the modeling is conducted on an annual basis, whereas the emission limits are based on 30-day (rolling) averages. Industry representatives stated that the limits could be adjusted to annual limits based on the methodologies used in the U.S. EPA, emission factor documentation for AP-42, Section 12.2, Coke Production: Final Report, Table 4-10, p. 4-147 (May 2008). Industry representatives stated there is a precedent for using adjusted limits for longer term, although they did not cite any examples. Industry representatives added that using 30-day average limits are more appropriate for acute modeling, not chronic risk modeling. 
      
      Industry representatives asked when updates to AERMOD would be made available and if they could get the latest BETA version. The EPA said that the updates to AERMOD will not be available for distribution in the near future. Industry representatives inquired if EPA would be posting a copy of the coke modeling file to the coke website for stakeholders to review. The EPA said they are continuing their internal QA and would post the coke modeling file to the Coke Oven PQBS NESHAP (subpart CCCCC) website in the near future to provide public availability. Industry representatives also asked if EPA would like onsite meteorological data that they have for a few facilities. The EPA said they would like to review the data. 
      Industry representatives stated that believed that EPA should use "urban" to classify all of the modeling areas at coke oven facilities. Industry representatives asked if EPA would be making improvements to urban modeling for complex terrains. The EPA said they would not. 
      
ATTENDEES
      
Matthew Woody, EPA/OAQPS
Chris Owen, EPA/OAQPS
Donna Lee Jones, EPA/OAQPS
Chuck French, EPA/OAQPS
Gabrielle Raymond, RTI International

David Ailor, COETF/ACCCI
Mary Kaplan, AECOM
Allen Dittenhoefer, Montrose, Inc.
Jeffrey Knight, Pillsbury Winthrop Shaw Pittman, LLP
Ted Palma, COETF consultant

Cleveland Cliffs (previously AK Steel and ArcelorMittal USA)
Katie Kistler
Rich Zavoda
Julianne Kurdila

ABC Coke 
Jay Cornelius 
Abigail Anderson 
Bill Osborn 

U.S. Steel
Christopher Hardin
Mike Dzurinko
Jonelle Scheetz

