From: 
SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Sent:
Thursday, February 3, 2022 9:53 AM
To: 
Jones, DonnaLee <jones.donnalee@epa.gov>
Cc:
BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>; Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: Do you have time for a quick call


Hi Donna Lee,

I hope you are having a good start to the year as well and that you are staying safe during this winter storm!  

Thanks for the additional feedback on these issues.  We are happy to provide more information explaining why Indiana Harbor does not have redundant HRSGs and why Jewell does not have any HRSGs.  These are issues that have been raised at various times by EPA and state agencies under other programs, so we have quite a bit of information on these points.  Please see our summary below for each facility guiding you through the attached documents.

Indiana Harbor
 First, please note that Indiana Harbor Coke Company (IHCC) was the first heat recovery plant in the world (i.e. a nonrecovery coke plant with HRSGs).  Accordingly, there are a number of design limitations and lessons learned that were incorporated into the heat recovery plants subsequently built at Haverhill, Granite City, and Middletown.  
 The first attached document is a presentation from 2013 when SunCoke, IHCC, and Cokenergy (an independent company that owns and operates the HRSGs and pollution control equipment downstream of IHCC's coke ovens) were negotiating with the United States and Indiana to resolve alleged violations of bypass venting limits at the facility.  (Please treat this document as CBI as per the label.) At that time, EPA was interested in the feasibility of a redundant HRSG at IHCC, as SunCoke and EPA had agreed upon in principle for the Haverhill and Granite City facilities. 
 The presentation to EPA describes some of the key differences between Indiana Harbor and the other SunCoke plants (slides 3-4), along with important considerations unique to IHCC including structural integrity of the ovens which were built on slag and not piled (slides 5-6, 10), equipment constraints such as smaller common tunnel size, induced draft fan limitations and SDA operation, lack of available space, and perhaps most importantly, structural limitations that prevent addition of more weight on top of the oven structure, concrete foundation, and other support structures.  A foundation study was actually conducted in December 2012 to evaluate the feasibility of adding another HRSG or other major equipment at the site, which concluded that it was impossible to do so (slide 13).  EPA and Indiana ultimately agreed that adding even one HRSG was not feasible for the reasons described on slides 17-22.
 Consequently, SunCoke, IHCC and Cokenergy agreed in the 2018 Consent Decree to permanently take on a slightly lower annual venting limit in their respective permits (and the state SIP regulations) by one percentage point from 14% to 13%.  Even so, there are exceptions for years in which a certain amount of HRSG retubing is undertaken by Cokenergy, in which case the annual limit reverts to 14%. The daily limit of 19% remained unchanged.  EPA and Indiana recognized in the course of negotiations that more aggressive reductions were not possible on a long term basis due to the technical feasibility issues and design constraints at the plant, and accepted that this reduction from 14% to 13% annual venting (in normal, non-HRSG retubing years) was the only feasible option to reduce venting at IHCC.

Jewell 
 Jewell was requested in late 2020 to conduct a Four Factor Analysis (4FA) by the Virginia Department of Environmental Quality (VDEQ) as part of the second planning period for the Regional Haze program.  Our initial Four Factor Analysis conducted by ERM was submitted to VDEQ on March 1, 2021 and subsequently revised in response to comments and resubmitted in August 2021, along with a Response to Comments document with photos of the facility, both of which are attached.
 Although the Four Factor Analysis focused on potential ways of reducing SO2, the conclusions from that analysis are directly applicable to whether HRSGs (or similar equipment) could be installed at Jewell to reduce venting because in any of these cases, hot gases from the bypass vent stacks would have to be cooled (i.e. the purpose of a HRSG) prior to being treated with air pollution control equipment.
 As explained on p.7 of the revised Four Factor Analysis, HRSGs are even less practical at Jewell than other hypothetical means of cooling the flue gas because the heat would be wasted and the higher capital cost of the additional heat recovery equipment would not be justified.  There is no need or use for more coal drying capacity, or for steam or hot water generated from heat recovery at the facility. The plant lacks space for electrical generation through addition of a HRSG and steam turbine, and the area does not have the infrastructure to accommodate a grid interconnection.  Because HRSGs are not feasible, the hypothetical engineering analysis focused instead on cooling the flue gas by adding ambient air to the flue gas stream. 
 As a result, the Four Factor Analysis evaluated the use of dilution air in conjunction with three hypothetical scenarios: dry sorbent injection, a spray dry absorber, and a circulating fluid bed scrubber.  The total minimum capital cost for theoretically installing these technologies at Jewell ranged from $325 million for DSI to $1.4 billion for a SDA.  Annual operating costs ranged from $70.6M for DSI to $248M for a SDA.  The costs per ton of SO2 removed were at least $21,000/ton in all cases.  See p.15.  ERM further determined that these cost estimates should be considered conservatively low.  See p.5. Although these estimates are for SO2 control, the same principles and equipment would apply in aiming to reduce bypass venting at Jewell.
 As part of the 4FA, Environmental Resources Management (ERM), a third party consultant retained by SunCoke to conduct the analysis, conducted a site visit in December 2020 and concluded that "Although the theoretical mechanisms for SO2 control are proven in practice elsewhere, the hypothetical design presented in this analysis should not be construed as in any way proven; in fact, it is unlikely that any such system could be constructed and operated in any feasible or reasonable manner."  See p.6.  This conclusion was based on numerous challenges unique to Jewell outlined on pp. 5-6, including the space constraints, the volume of air needed to sufficiently cool the gas stream, the impact of such equipment on oven structural integrity, water availability, electrical power demand, and other factors.
 As we've previously noted, the most significant problem is the space constraints at the plant.  ERM states on p.6 "there are many extreme challenges to applying any sort of control device at Jewell, and one of the most insurmountable challenges is the lack of space for new equipment. There is no space to accommodate the footprint of one or multiple control devices, nor is there space to include the multiple pieces of ancillary equipment, personnel and vehicles and maintenance access necessary to run and operate any of these units. As noted previously, the batteries are placed tightly in the river valley with extreme terrain on both sides of the valley. There is virtually no unused space on the property based on ERM's observations during a December 2020 site visit."  As a result of these issues, ERM found that "SO2 control technologies are considered to be both technically and economically infeasible." p.15.
 To further illustrate the space constraints that were raised in ERM's evaluation, we provided at the conclusion of our Response to Comments document a compilation of pictures of the site.  See PDF pp. 14-30 for those pictures. 

Thanks again for your time in working through these issues as part of the RTR.  Please let us know if you have any additional questions or if more information would be helpful.

Kris


<< IHCC EPA Presentation Foundations 071613 Final.pdf Privileged and Confidential  -  For Settlement Purposes Only >>
<< Jewell Four Factor Analysis Revised Aug 2021 Final.pdf >>
<< Response to Comments w Facility Photos.pdf >>



From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Thursday, January 13, 2022 8:49 PM
To: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Cc: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>; GABRIELLE RAYMOND <graymond@rti.org>
Subject: RE: Do you have time for a quick call

Thank you for your input to the EU cost estimates for a new heat recovery plant. I thought the numbers might be low. I will still cite the EU estimates but will add yours also.

As you may know, we will be deliberating about the rule and possibly re-running analyses right up to proposal, therefore I don't want to risk telling you something that might change. However, you will be able to respond in as much detail as you like during the comment period. The comment period starts when the rule is published in the FR but EPA posts the EPA version of the file on our website when it is signed. I can let you know where and when that is so you can get a head start. Sometimes the FR office makes more editorial changes after it leaves EPA and before it is published, but these are usually small changes.

I know you told me that Jewell does not have the space to add HRSGs, but I don't recall why Indiana Harbor-East Chicago cannot have more HRSGs to avoid the high number of bypass hours allowed by the state or if there is any other reason for the high number of hours as compared to the other 3 facilities. While you are doing this, you may add to the explanation for Jewell if you like, especially if there is more than just a space issue.

Thanks for getting back to me. Hope you are having a good start to the new year.

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
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