From: 
SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Sent:
Wednesday, July 7, 2021 9:22 PM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc:
BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Subject: 
RE: Coke Oven MACT RTR


Hi Donna Lee,

Thanks for the update below.  

We wanted to send EPA a few more updates on the SunCoke facilities:
 Based on the modeling files provided to SunCoke by EPA on March 1, 2021 ("modeling files"), SunCoke understands that EPA is estimating emissions from bypass vent stacks at SunCoke facilities based on source testing at the Gateway facility in Granite City, IL.  While this approach generally makes sense, we believe this approach is not appropriate for SunCoke's Jewell facility because Jewell has fewer ovens per vent stack compared to other SunCoke facilities.  Jewell only has 8.875 ovens per stack, compared to 20 ovens per stack at Gateway.  Based on this, we request that EPA reduce the emissions at Jewell to 44.4% (i.e., 8.875/20) of the values included in EPA's modeling files to account for the lower number of ovens per stack (and resulting emissions) at Jewell.  
 Based on the modeling files, SunCoke understands that EPA is estimating HAP emissions from SunCoke's pushing operations by using average emission factors calculated from source testing of the pushing operations at SunCoke's Middletown and Granite City facilities.  While this approach seems appropriate for Middletown, Granite City, and Haverhill, it does not make sense for Indiana Harbor because that facility utilizes a cokeside shed with emissions routed to a baghouse, unlike the hot car multiclone present at Middletown, Haverhill and Granite City.  EPA's modeling files confirm this and specify a control measure code of 100, which corresponds to a baghouse.  However, the emissions estimated by EPA do not appear to account for the control efficiency of the baghouse.  We request that EPA apply a 99% control efficiency for the baghouse for all applicable pollutants, which is the low end of the range of control efficiencies for fabric filters presented in EPA's AP-42, Appendix B.2, Table B.2-3.  
 SunCoke understands that EPA will be evaluating acute risks as part of the RTR.  For recent RTRs, EPA has estimated acute risks using the Human Exposure Model (HEM), which approximates the facility boundary by using a polar ring of receptors that is centered at the facility centroid and extends to the outermost modeled source at the facility.  This approach to approximating the facility boundary can lead to misidentification of offsite receptors, especially for elongated facilities.  In the past, EPA has attempted to rectify this by reviewing the HEM results and adding or removing receptors, as needed, in order to better capture impacts near the facility boundary.  To assist EPA with these refinements, SunCoke is providing EPA with maps of the approximate facility boundaries (see attached Figures 1-5).  SunCoke requests that EPA use this information to avoid estimating onsite risks.  Note that the Indiana Harbor facility is co-located with the Cleveland Cliffs facility, so the larger (blue) approximate boundary in Figure 2 should be used for that facility.  Similarly, the Gateway (Granite City) facility is co-located with the US Steel facility, so the larger (blue) approximate boundary in Figure 3 should be used for that facility.  

Thank you in advance for taking these comments into consideration.  We are continuing to review EPA's modeling files and will let you know if we identify additional updates or revisions in the future.   

Finally, we wanted to confirm a couple items:
 EPA has previously indicated its intention to separate the risk modeling for non-recovery plants vs. byproduct plants.  We just wanted to reconfirm this is still EPA's plan.
 In your email below, when you say "once the file is posted you can assume the modeling is done," are you referring to EPA's initial run?  What is the process for accepting comments after this initial run is completed, and will EPA accept revisions to modeling parameters should it be needed?

Thanks,

Kris


<< Facility Boundaries.pptx >>


From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Tuesday, June 22, 2021 8:33 PM
To: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Cc: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Subject: RE: Coke Oven MACT RTR

 
Hi. COETF just contacted me also on same question. I had just sent an email to the modeler (Matt) to see what he thinks about posting the model file. He was going to do one more thing in terms of modeling. I have not heard back yet. I will let you know when it will be ready to post. Once the file is posted you can assume the modeling is done.

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: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM> 
Sent: Tuesday, June 15, 2021 4:27 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Subject: Coke Oven MACT RTR

Hi Donna Lee,

We just wanted to reach out to you to see if you have any updates on the status of the Coke Oven MACT RTR. Any updates on where EPA stands in the modeling process? Any idea when EPA's modeling files will be available? Any updates are appreciated.
Thanks!

Kris 

Kris Singleton
Corporate Engineer  -  
Health, Environmental & Safety

 SunCoke Energy
office:  513-727-5518
cell:  513-649-1371





