From:
"Jones, DonnaLee" <Jones.Donnalee@epa.gov>
Sent:
Wed, 05 Oct 2022 17:45:31 
To:
"David Ailor (dailor@accci.org)" <dailor@accci.org>
Subject:
follow-up to call on method 303 tests

Hello again David  -  This is a follow-up email to summarize what we discussed on a TEAMS call earlier this afternoon to discuss the requested method 303 testing from both the battery bench and yard at two COETF coke facilities. As I explained, we have reviewed the information that was sent to the Coke Oven NESHAP Team along with your email of Friday, August 19, 2022 3:19 PM (attached) concerning the previous fatal accidents at coke facilities and photos of the conditions on the bench. We discussed this information as well as reviewed the opinions provided by Jerry Crowder, PhD, PE, of Crowder Environmental Associates, Inc., Allen, Texas [jerry@cea303.com] who, as you know, is the national trainer for Method 303 readers. 
 
Jerry believes that if all moving equipment is shut down, there should not be any danger in performing the EPA method 303 readings from the bench and that the current pool of method 303 readers are capable of obtaining the bench and yard observations. Jerry's opinions are very important in light of the list of accidents you sent, which, while not during method 303 readings, were all due to moving equipment. I thought of another possible scenario that I shared with you today, if facilities did not want to totally shut down pushing equipment, where readers could perform method 303 tests on ovens that were at least 30 ovens or more away at all times from any door removal and pushing equipment. Because we chose large facilities to perform the tests [Cleveland Cliffs Burns Harbor and US Steel Clairton] in the recent 2022 section 114 information request and the facilities were permitted to choose which batteries to test, I would expect this separation distance to be possible. We also estimate that the total test time to complete the entire battery testing is a total of 4 hours, so, hopefully, there would be minimal disruption to production activities by the independent method 303 test staff. In addition, the testing does not need to be continuous, which allows flexibility, but testing on any single battery should be completed in the same day.
 
One of the reasons the EPA would like these tests to be performed from the bench and yard is to compare any new data to the data used to develop the current AP-42 equation to estimate door leaks, that is based on 1981 data obtained from US Clairton, as well as to compare any new data to the revised equation Kevin McGinn and I developed from the same 1981 study, which produces significantly different emissions estimates. See attached memorandum we previously shared with the industry. In addition, as I also mentioned on our call today, we need new data because the 1981 study was performed on "short" doors, which were the standard door size back in 1981, whereas most facilities now have "tall" doors." These facts and the fact that door leaks have been found in the past to have a large effect on facility risk makes an update to the door leak rates important and necessary at this time as we continue to work on the Coke Oven NESHAP RTR.
 
To conclude our call, I asked you if you thought the industry would like to discuss these issues further or provide the EPA with any additional responses. As you are likely on vacation now, I wait until the week of October 17th to contact you again as to the path forward. If no further discussion is thought to be necessary, we will prepare a letter to be sent to the two facilities previous selected to perform the method 303 tests with a revised schedule data submission.
 
Nice talking to you today. Take care.
 
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.

<<Doors-Revised-Equation-Memo-08-02-21.pdf>>
<<8-19-22-COETF-follow-up-email-hazard photos & accident-reports-etc.pdf>>
