MEMORANDUM   

DATE:		12/20/2021

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 December 20, 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 three issues of concern with the current EPA modeling approach for the US Steel Clairton, PA, facility after reviewing the posted coke modeling AERMOD files on the EPA's coke modeling website in September 2021. Industry representatives said that the current approach is using a rural source characterization and the EPA should consider using an urban source characterization because using rural doesn't account for urban heat islands generated from coke facilities. Secondly, the industry representatives said the current dispersion modeling approach is not applicable to the complex hilly terrain surrounding US Steel and exacerbates the first issue as buoyant line modeling is only good for flat terrain. Thirdly, the industry representatives said that the EPA is using coke battery buoyancy parameters (F') that are lower than those used previously by Allegheny County Health Department (ACDH) modeling that were previously approved by EPA (Region III), and do not account for large convective heat transfer from battery surfaces.  
      
      Industry representatives were concerned that unless these model issues are addressed, the risk results will be overestimated and mislead the public. They requested that EPA correct these three issues before the proposal package is finalized. Industry representatives were concerned they would not have enough time to comment during a public comment period and EPA would not have enough time to fix the issues after the public comment period. 
      
      The EPA thanked industry for the information provided and had no further questions. 
      
ATTENDEES
Penny Lassiter, EPA/OAQPS
Chuck French, EPA/OAQPS
Donna Lee Jones, EPA/OAQPS
Kelly Rimer, EPA/OAQPS 
Mike Moeller, 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
Katie Kistler
Julianne Kurdila
Mike Long
Rob Beranek

ABC Coke 
Jay Cornelius 
Abby Dolby

DTE - EES
Brenna Harden

U.S. Steel
Christopher Hardin
David Hacker
Brett Tunno
Mike Dzurinko



