From: 
David Ailor <dailor@accci.org>
Sent:
Monday, October 4, 2021 6:32 PM
To: 
Moeller, Michael <moeller.michael@epa.gov>
Cc:
Woody, Matt <Woody.Matt@epa.gov>; French, Chuck <French.Chuck@epa.gov>; Jones, DonnaLee <Jones.Donnalee@epa.gov>
Subject: 
RE: COETF REQUEST THAT EPA POST THE SOURCE CATEGORY-ONLY HEM4 INPUT FILES FOR THE PQBS SOURCE CATEGORY


Hello again, Mike and Matt.  Thank you again for posting the HEM4 input files.
 
Based on the COETF's review of them, we have concluded that the input files have been set to override the urban dispersion configuration in favor of rural dispersion for a number of facilities including, most significantly, the USS-Clairton Coke Plant.  That, together with the use of different coke battery buoyancy parameters compared to the buoyancy parameters approved by EPA and ACHD for a recent modeling application for USS-Clairton, would result in significant and unjustified risk overprediction.  
 
Bob Paine with AECOM and Dr. Allen Dittenhoefer with Montrose Environmental have prepared the attached technical analysis and conclusions (see "Urban Dispersion and Battery Buoyancy at Clairton 100421.pdf") regarding the selection of urban vs. rural dispersion conditions and appropriate coke battery buoyancy parameters for USS-Clairton, and the hybrid modeling approach that has previously been approved by EPA for USS-Clairton.  The COETF requests that EPA review Bob and Al's analysis/conclusions and reconsider using a rural dispersion setting and different coke battery buoyancy parameters from those previously approved by EPA.  We also request a meeting with EPA in the coming days to discuss EPA's approach and any questions you may have.  
 
Thank you for your prompt attention to this request.  I will be in contact soon to arrange a meeting date and time.  In the interim, 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


<< Urban Dispersion and Battery Buoyancy at Clairton 100421.pdf >>



From: Moeller, Michael [mailto:moeller.michael@epa.gov] 
Sent: Thursday, September 23, 2021 1:34 PM
To: David Ailor (ACCCI) <dailor@accci.org>
Cc: Woody, Matt <Woody.Matt@epa.gov>; French, Chuck <French.Chuck@epa.gov>; Jones, DonnaLee <Jones.Donnalee@epa.gov>
Subject: RE: COETF REQUEST THAT EPA POST THE SOURCE CATEGORY-ONLY HEM4 INPUT FILES FOR THE PQBS SOURCE CATEGORY

Hi David,

The HEM4 input files have been publicly posted and can be found on the source category EPA webpage located here : https://www.epa.gov/stationary-sources-air-pollution/coke-ovens-pushing-quenching-and-battery-stacks-national-emission

They are in a .zip file titled `HEM4 inputs for the pre-proposal Coke Ovens risk modeling (zip)'

Thanks,

-Mike





