MEMORANDUM 

DATE:	May 1, 2023

FROM:	Jacob Carpenter, U.S. Environmental Protection Agency Region IV, Atlanta, GA; Kathleen Healy, U.S. Environmental Protection Agency, Region V, Donna Lee Jones, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina, and Gabrielle Raymond, RTI International

TO:		Coke Ovens: Pushing, Quenching, and Battery Stacks (40 CFR part 63, subpart CCCCC) Docket

SUBJECT:	Preliminary Analysis and Recommendations for Potential Coke Oven Combustion Stack 1-hr Additional Standard Under Technology Review for NESHAP for Coke Ovens: Pushing, Quenching, and Battery Stacks (40 CFR part 63, subpart CCCCC)
__________________________________________________________________________________________
1.0	INTRODUCTION

This memorandum discusses the basis for considering an additional, less than 24-hour opacity standard for battery stacks for the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Coke Ovens: Pushing, Quenching, and Battery Stacks (40 CFR part 63, subpart CCCCC), referred hereafter as the Coke PQBS NESHAP. In the 2002 Coke PQBS NESHAP, the EPA established battery stack daily (24-hr) average emissions limits of 15% and 20% for by-product batteries on a normal coking cycle and an extended coking cycle, respectively. Each battery stack is required to be monitored for opacity at all times using a continuous opacity monitoring system (COMs). An additional battery stack opacity standard could be added to the Coke PQBS NESHAP as part of the technology review required in CAA section 112(d)(6).

2.0	BACKGROUND

Battery stack opacity is perhaps the best single indicator of the maintenance status of coke ovens and could be considered as an indicator of fugitive and excess HAP emissions from coke oven batteries. In the preamble to the final 2002 rule for the Coke PQBS NESHAP, the EPA described the linkages between oven wall condition, operating and maintenance (O&M) practices, battery stack opacity, and HAP emissions (see 68 FR 18019-18020). The EPA stated in the 2002 final rule preamble (68 FR 18019) that that the primary factor affecting battery stack opacity is the condition of oven walls, which deteriorate over time and cause leaks and increased emissions of coke oven emissions (COE). Well-maintained ovens will minimize the leakage of raw COE from within the ovens into the flues and to the combustion stack. A well-maintained oven also will decrease the likelihood of uneven and incomplete coking, which results in more particulate and HAP emissions and higher opacity during pushing (known as green pushes). Well-maintained ovens also result in fewer door leaks and minimize other oven sources of fugitive and excess COE emissions (§63.7296). 

3.0	TECHNOLOGY REVIEW OF COKE PQBS NESHAP BATTERY STACK OPACITY 

Based on a preliminary analysis of data acquired in the Clean Air Act (CAA) section 114 request for the Coke PQBS NESHAP in 2022 (hereafter referred to as the 2022 Coke Ovens CAA section 114 request), there are significant differences between the submitted battery stack COMs data among the six operating byproduct facilities in the coke industry. The battery stack COMS data show that some sources maintain battery stack opacities far below the 24-hr limits in Coke PQBS NESHAP (which are considered to be the well-controlled sources), while others operate consistently just under the limit and significantly higher than these well-controlled sources. The EPA anticipates that these well-controlled sources have utilized the analysis of short-term combustion stack opacity readings to direct the implementation of their O&M practices. That these sources consistently achieve low short-term and 24-hr opacity levels over many years provides evidence that their O&M practices are cost-effective. Therefore, it is possible that additional shorter-term battery stack standards, such as a 1-hr standard, could lower the opacity of facilities that are only achieving opacity slightly  less than the existing 24-hr limit in the Coke PQBS NESHAP, and reduce COE and other coke oven HAP emissions from coke batteries at these facilities. 

3.1	Approaches For Additional Shorter-term Battery Stack Standards

There are a number of approaches possible to lower the 24-hr battery stack opacity standards: (1) reduce the 24-hr battery stack opacity limit in terms of percent opacity; (2) add a shorter-term battery stack opacity requirement, such as 1-hr, with or without change to the opacity limit; or (3) replace the current 24-hr standard with a shorter-term battery stack opacity requirement, with or without change to the opacity limit. We have asked for comment on the use of a shorter-term limit in the current Coke PQBS NESHAP proposal (2023). 
      
Three facilities responding to the 2022 Coke Ovens section 114 request noted short-term opacity limits required by their state or local rules, that include:

 U.S. Steel Clairton (PA): no more than 3 minutes above 20% in any 60-minute period.
 Cleveland Cliffs (CC) Burns Harbor (IN): 6-minute rolling average 40% limit and a 2-hr rolling 20% limit.
 DTE/EES River Rouge (MI): 6- minute rolling average 20% limit with a single 6-minute average per hour up to 27%.

Table 1 documents the above state or local rule limits reported in the 2022 Coke Ovens CAA section 114 request along with the Coke PQBS NESHAP limits. Table 2 lists the federal (Coke PQBS NESHAP), state, local coke battery stack COMs requirements, ranked by decreasing averaging time periods.

3.2	COMS Data From 2022 Coke CAA Section 114 Request

The 1-hr battery stack COMS data obtained from the six byproduct coke facilities reporting in the 2022 Coke CAA section 114 request are shown in Appendix A. There is a wide variation between some of the COMs data from these facilities. Appendix B shows 1-minute battery stack COMs data from these same facilities, with similar wide variation.

4.0	WORK PRACTICES, EQUIPMENT, AND OTHER MEASURE USED TO MINIMIZE LEAKS FOR OVENS

As part of the 2022 Coke CAA section 114 request, the EPA received descriptions of work practices being performed by coke facilities to ensure the integrity of their ovens. The descriptions of work practices are shown in Appendix C. The health of the ovens can directly impact battery opacity, with higher battery stack opacity associated with oven cracks and degradation. An analysis of specific work practices at the better-controlled facilities is needed so that recommendations or requirements to control battery stack opacity at all times could be made.




         
Table 1. Summary of Less than 24-hr Battery Stack Opacity Limits at Currently Operating Coke Byproduct Facilities
                                   Facility
                      Shorter-term Opacity Permit Limits
                            Shorter Term Reference
                 Coke PQBS NESHAP Battery Stack Opacity Limit
                                    (24-Hr)
                                       
                            3 Minutes in any 1 Hour
                                    Rolling
                                   6 Minutes
                                 One 6-Minute
                                Average per Hr
                                    Rolling
                                     2 Hr
                                Never to Exceed
                                  Hard Limit
                                       
                                       
ABC Coke-AL
                                       
                                       
                                       
                                       
                                       

                                20% (extended)
CC Burns Harbor-IN
                                       
                                      40%
                                       
                                      20%
                                       
326 IAC 2
                                 15% (normal)
CC Monessen-PA
                                      20%
                                       
                                       
                                       
                                      60%
25 PA Code 123.41
                                 15% (normal)
CC Warren-OH
                                       
                                       
                                       
                                       
                                       

                                 15% (normal)
DTE/EES-MI
                                       
                                      20%
                                      27%
                                       
                                       
Michigan Admin. Code R. 336.1301
                                 15% (normal)
USS Clairton-PA
                                      20%
                                       
                                       
                                       
                                      60%
Allegheny County Code §2105.21.f
                                    15%/20%


     Table 2. Federal, State, Local Coke Battery Stack COMs Requirements 
                     Coke Battery Stack COMs Requirements 
                                    Opacity
                                     Rule
Coke PQBS NESHAP 24-hr-normal operation
15%
EPA 2002
Coke PQBS NESHAP 24-hr-extended coking operation
20%
EPA 2002 
3 minutes in any 1 hour
20%
PA
6 minutes in any 1 hour
27%
MI
Rolling 6 minutes
20%, 40%
MI, IN
Rolling 2 hour
20%
IN
Never to exceed
60%
PA
                                       
APPENDICES
                                       

APPENDIX A
                                       
1-HOUR CONTINUOUS OPACITY MONITOR (COMs) BATTERY STACK DATA 
FROM 2022 CAA SECTION 114 REQUEST

ABC Coke-AL 1-hour COMs Data -  

ABC Coke is currently subject only to the Coke PQBS NESHAP's 24-hr opacity limit of 15% for normal operation and 20% opacity for extended coking. 

  
USS Clairton-PA COMs 1-hour Data

USS Clairton has a local county limit of no more than 3 minutes above 20% in any 60 minute period.





	
 
CC-Burn Harbor-IN 1-hour COMs Data

CC-Burn Harbor has state limits of 6-minutes at 40% opacity and 2-hr average of 20% opacity.

 

CC Monessen 1-hour COMs Data

CC-Monessen has state limits of 20% limit for 3 minutes in any 1 hour and a 60% never-to-exceed opacity limit.

 


CC Warren 1-hour COMs Data

CC-Warren currently is subject only to the 24-hr opacity limit in the Coke PQBS NESHAP.












DTE/EES 1-hour COMS Data

DTE is subject to state limits of 20% for a rolling 6-minute average opacity and 27% for any one 6-minute average opacity per hour.



                                       
APPENDIX B
1-MINUTE COMS BATTERY STACK DATA 
FROM 2022 COKE CAA SECTION 114 REQUESTS
                                       
ABC Coke-AL 1-minute COMS Data from 2021

ABC is subject only to the 24-hour opacity limit in the Coke PQBS NESHAP. 

 

USS Clairton-PA 1-Minute COMS Data from 2021

USS Clairton has a limit of no more than 3 minutes above 20% in any 60 minute period.

 
 
 
 

















CC-Burns Harbor-IN 1-minute COMS Data from 2022

CC Burns Harbor is subject to a 6- minute 40% limit and a 2-hr 20% limit.

NOTE: regular artifacts around 40% opacity in data that should be ignored. This is likely associated with some COMs calibration.
 












CC-Monessen-PA 1-minute COMs Data from 2021

 


CC-Warren-OH 1-minute COMs Data from 2019




DTE/EES-MI 1-minute COMs Data from 2021






APPENDIX C
                                       
WORK PRACTICES TO REDUCE OVEN LEAKING INTO BATTERY STACKS EXHAUST

                                       
                                       
Appendix Table C-1: List of Unique Oven Leak Work Practices and Costs Reported in 2022 CAA Section 114 Responses
             Work Practice / Equipment / Other Measure Description
   Work Practice Required or Beyond Minimum Requirements in 40 CFR part 63, 
                                   Subpart L
                        No. Facilities Currently Using
                          Capital Purchases and Year
                       Annual O&M Expenses and Year$
                                Labor (hrs/day)
                               Labor (hrs/week)
                                     Labor
                                   (hrs/yr)
                                Type of Labor 
                       Estimated Control Efficiency (%)
Periodic complete oven overhaul: Inspection of the oven
                                   Required 
                                       6
                                  $100K-$250K
                                  $100K-$250K
                                       8
                                      40
                                     2,080
                          operators / subcontractors
                                    >50%
Periodic complete oven overhaul: Degraphitizing of all deposits within the chamber (walls, ceiling, ascension pipes)
                                   Required
                                       6
                                   <$100K
                                   <$100K
                                     <8
                                    <40
                                   <2,080
                                   operators
                                    >50%
Periodic complete oven overhaul: Oxy-thermic welding of cracks, holes and surface damage of the refractory brickwork
                                   Required
                                       6
                                  $100K-$250K
                                  $100K-$250K
                                       8
                                      40
                                     2,080
                          operators / subcontractors
                                    >50%
Periodic complete oven overhaul: Repair of the oven chamber floor by flooding with cement
                                   Required 
                                       3
                                  $100K-$250K
                                  $100K-$250K
                                       8
                                      40
                                     2,080
                          operators / subcontractors
                                    >50%
Periodic complete oven overhaul to include injection of dust into fine cracks
                                   Required 
                                       5
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                                      CBI
Periodic complete oven overhaul: Use of coke oven chamber wall diagnosing-repairing apparatus
                                   Required 
                                       1
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                                      CBI
      



Appendix Table C-2: Specific Oven Leak Work Practices, by Facility, Reported in 2022 CAA Section 114 Responses
Facility ID (2022 section 114 ICR)
Indicate if currently using, tried in past, or considered in past
Describe how well it works/ worked
Describe why not using anymore
Emission Source (specify)
Describe Measure (Work Practice/ Equipment /Other)
Capital Purchases and Year$
Annual O&M Expenses and Year$
Labor (hrs/day)
Labor (hrs/week)
Labor (hrs/yr)
Type of Labor (e.g., (technician, skilled worker, manager, etc.)
Estimated Control Efficiency (%) of Work Practice or Equipment
                        Periodic Complete Oven Overhaul
                            Inspection Of The Oven
CC-BurnsHarbor-IN
Currently using
Works well based on the results of the COMS data.
N/A

CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CC-Monessen-PA
Currently using
Works well based on the results of the COMS data.
N/A

CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CC-Warren-OH
Currently using
Works well based on the results of the COMS data.
N/A

CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
USS-Clairton-PA
Currently performing
works well
N/A
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
ABC-Tarrant-AL
Currently performing	
works well
 
002, 003, 004
Operators looks at each oven after a push, if problem is suspected. Operator informs shift foreman, who then notifies ovens foreman for decision on how to repair possible problem.
 
 
 
 
 
 
 
EES-River Rouge-MI
Currently Using
Operators inspect ovens on a planned schedule and/or if there is an identified issue
NA
Doors
SOPs are created and trained, inspection and repair triggered by levels of emissions, documentation is submitted to Management 
$100K-$250K
$100K-$250K
8
40
2080
operators / subcontractors
>50%
Degraphitizing Of All Deposits Within The Chamber (Walls, Ceiling, Ascension Pipes) 
CC-BurnsHarbor-IN
Currently using
Assume degraphitize means decarbonize. 
Works well. Completed for normal operation of oven for production purposes and proper heating. 
N/A

CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CC-Monessen-PA
Currently using
Assume degraphitize means decarbonize. 
Works well. Completed for normal operation of oven for production purposes and proper heating. 
N/A
N/A
 
 
 
 
 
 
 
 
CC-Warren-OH
Currently using
Assume degraphitize means decarbonize. 
Works well. Completed for normal operation of oven for production purposes and proper heating. 
N/A
N/A
 
 
 
 
 
 
 
 
USS-Clairton-PA
Currently performing
works well
N/A
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
ABC-Tarrant-AL
Currently performing
works well
 
002, 003, 004
De-Carbonization can occur in several ways. Ceiling is decarbonized in two ways. 1. Air injected into the oven as it is being pushed. 
2. Carbon cutters are mounted on tip of Pusher Ram to cut carbon as it passes through the oven while pushing. This is done on each oven pushed. The stand pipes are cleaned by high pressure water hose mounted on the Larry Car. The operator cuts the carbon out of the Stand Pipe before each charge. Walls are cleaned by the pushing process.
 
 
 
 
 
 
 
EES-River Rouge-MI
Currently Using
Operators inspect ovens on a planned schedule and/or if there is an identified issue
NA
Doors
SOPs are created and trained, inspection and repair triggered by levels of emissions, documentation is submitted to Management 
<$100K
<$100K
<8
<40
<2080
operators
>50%
Oxy-Thermic Welding Of Cracks, Holes And Surface Damage Of The Refractory Brickwork
CC-BurnsHarbor-IN
Currently using
Works well based on the results of the COMS data.
N/A

CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CC-Monessen-PA
Currently using
Works well based on the results of the COMS data.
N/A
Doors
Oxy-thermic welding of cracks, holes and surface damage of the refractory brickwork
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
CC-Warren-OH
Currently using
Works well based on the results of the COMS data.
N/A
Doors
Oxy-thermic welding of cracks, holes and surface damage of the refractory brickwork
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
USS-Clairton-PA
Currently performing
works well
N/A
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
ABC-Tarrant-AL
currently using
Does the job. 
 
002, 003, 004
Oven Repair has the door removed. Places fiber wool in the oven for a heat shield. Uses welder to "weld" up small holes and cracks. Also welds up brickwork around the door frames.
 
 
 
 
 
 
 
EES-River Rouge-MI
Currently Using
Operators inspect ovens on a planned schedule and/or if there is an identified issue
NA
Doors
Work is subcontracted upon identification of repairs needed during inspection
$100K-$250K
$100K-$250K
8
40
2080
operators / subcontractors
>50%
           Repair Of The Oven Chamber Floor By Flooding With Cement
CC-BurnsHarbor-IN
Currently using, as needed
Works well based on the results of the COMS data.
N/A

CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CC-Monessen-PA
Not using
N/A
N/A
N/A
 
 
 
 
 
 
 
 
CC-Warren-OH
Not using
N/A
N/A
N/A
 
 
 
 
 
 
 
 
USS-Clairton-PA
Not currently performing
works well when used
Currently ceramic welding is used for damage greater than 1" in depth and then use a plastic ram that melts and fills in floor deterioration. This is performed as needed. Floors are inspected on every oven that is out of service.
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
ABC-Tarrant-AL
ABC uses a product named Super 3000 made by Reno Refractories. 
According to Oven repair Dept. Works better than any used prior.
 
002, 003, 004
flood floor with super 3000
 
 
 
 
 
 
 
EES-River Rouge-MI
Currently Using
Operators inspect ovens on a planned schedule and/or if there is an identified issue
NA
Doors
Work is subcontracted upon identification of repairs needed during inspection
$100K-$250K
$100K-$250K
8
40
2080
operators / subcontractors
>50%
                      Injection Of Dust Into Fine Cracks
CC-BurnsHarbor-IN
Currently using
Works well based on the results of the COMS data.
N/A

CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CC-Monessen-PA
Currently using
Works well based on the results of the COMS data.
N/A
Doors
Injection of dust into fine cracks
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
CC-Warren-OH
Currently using
Works well based on the results of the COMS data.
N/A
Doors
Injection of powdered dust into fine cracks
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
USS-Clairton-PA
Currently performing
works well
N/A
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
ABC-Tarrant-AL
ABC uses this procedure. Oven repair dept. utilizes this practice on all three shifts. We normally do 8 - 10 ovens per shift.
helps in prevention of oven wall leakage.
 
002, 003, 004
Injector is placed over charging hole and dust is injected into the oven chamber.
 
 
 
 
 
 
 
EES-River Rouge-MI
Never Considered
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
         Use Of Coke Oven Chamber Wall Diagnosing-Repairing Apparatus
CC-BurnsHarbor-IN
Not using
N/A
N/A
N/A
 
 
 
 
 
 
 
 
CC-Monessen-PA
Not using
N/A
N/A
N/A
 
 
 
 
 
 
 
 
CC-Warren-OH
Tried in past
Works well
Used periodically for inspections
Coke Battery Stack
Water cooled camera
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
USS-Clairton-PA
currently using
works well
N/A
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
ABC-Tarrant-AL
visual
 
 
002, 003, 004
 
 
 
 
 
 
 
 
EES-River Rouge-MI
Not in Use
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA


