MEMORANDUM   

DATE:		08/25/2021

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 Microsoft TEAMS conference call was held on August 25, 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 part of the residual risk and technology review (RTR) for Pushing, Quenching, and Battery Stacks (PQBS) NESHAP (40 CFR part 63, subpart CCCCC). 
      
      Industry representatives expressed their concern with AERMOD and stated that there was a modeling code error in the buoyant line plume (BLP) model. Industry representatives said that the error would result in overstated risk values. Industry representatives requested that EPA work to prioritize the error before modeling for the PQBS industry and were concerned about public comments on the results if the error was not fixed. The EPA thanked industry for the information. The industry said they would be checking the NESHAP site for the corrected AERMOD input file. 
      
ATTENDEES
      
Matthew Woody, EPA/OAQPS
Mike Moeller, EPA/OAQPS
Donna Lee Jones, EPA/OAQPS
Chuck French, EPA/OAQPS
Gabrielle Raymond, RTI International

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

Cleveland Cliffs (previously AK Steel and ArcelorMittal USA)
Rich Zavoda

ABC Coke 
Jay Cornelius 
Abby Dolby

DTE - EES
Robert Sanch

U.S. Steel
Christopher Hardin
Jonelle Scheetz
Brett Tunno

