From: 
David Ailor <dailor@accci.org>
Sent:
Tuesday, January 18, 2022 12:28 PM
To: 
Jones, DonnaLee <jones.donnalee@epa.gov>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: question about door seals


Hello again, Donna Lee.

I canvassed the COETF members regarding your question.  We are not aware of any specific information or more recent reports on the conceptual recommendations from the Battelle study.  But, more generally and as you know, U.S. coke batteries have been constructed and re-constructed since the mid-1970s, and we believe those batteries would have incorporated the available designs and measures for door seals, jambs, etc.  Any door leak emission improvements from these types of measures would have been considered in the coke batteries Subpart L reg. neg. in the 1990s, and reflected in the original Subpart L NESHAP.

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


<< 1975-Batelle-AISI- EPA-Door-Leak-report.pdf >>


From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov] 
Sent: Thursday, January 6, 2022 8:55 PM
To: David Ailor <dailor@accci.org>
Cc: 'Raymond, Gabrielle' <graymond@rti.org>
Subject: RE: [SPAM-Sender] RE: question about door seals

Soon. 3 weeks?

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: David Ailor <dailor@accci.org> 
Sent: Thursday, January 6, 2022 8:51 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: 'Raymond, Gabrielle' <graymond@rti.org>
Subject: [SPAM-Sender] RE: question about door deals

How quickly do you need an answer?  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

From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov] 
Sent: Thursday, January 6, 2022 8:26 PM
To: David Ailor (dailor@accci.org) <dailor@accci.org>
Cc: Raymond, Gabrielle <graymond@rti.org>
Subject: question about door deals

Hi. Another hopefully easily answered question. I ran across this old document that seemed very thorough and had the conclusions listed below. Would your members say that the recommendations were followed or accomplished in the many years that followed? If you have more recent reports, I'd be interested in seeing them.

Study of Concepts for Minimizing Emissions from Coke-Oven Door Seals. Prepared by Battelle Columbus Laboratories, Columbus, OH, for the U.S. Environmental Protection Agency, Office of Research and Development, National Environmental Research Center, Research Triangle Park, North Carolina 27711. July 1975.

In 1974, a research project was performed by Batelle's Columbus laboratory to study concepts for minimizing emissions from coke-oven door seals. The study was funded jointly by the EPA and the American Iron and Steel Institute (AISI), and was monitored by the EPA. The major objective was to derive, originate, and evaluate practical concepts for significantly improved systems for retrofittable sealing of coke-oven doors. 

The recommendations included (1) the use of more-flexible and more heat-resistant metal door seals; (2) development of a more dimensionally stable door jambs for both new coke-oven batteries and replacement of some jambs at existing batteries; and (3) evaluating the performance of various sealants because using sealants of some variety between the door and the jamb surface has the potential for totally eliminating door emissions.



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.





