MEMORANDUM 

DATE:	May 1, 2023

FROM:	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, Research Triangle Park, North Carolina
		
TO:	Coke Oven (RTR) Dockets, EPA-HQ-OAR-2002-0085 (40 CFR part 63, subpart CCCCC); and Docket ID No.'s EPA-HQ-OAR-2003-0051 (40 CFR part 63,subpart L)
		
SUBJECT:	Technology Review for NESHAP for Coke Ovens: Pushing, Quenching, and Battery Stacks (40 CFR part 63, subpart CCCCC), and NESHAP for Coke Oven Batteries (40 CFR part 63, subpart L)
__________________________________________________________________________________________
                                   CONTENTS
1.0	INTRODUCTION AND BACKGROUND	3
2.0	COKE OVENS PUSHNG, QUENCHING, AND BATTERY STACKS NESHAP PROCESSES	5
2.1	Pushing	5
2.1.1	Current Pushing Control Technology	5
2.1.2	Potential Control Technology for Pushing	6
2.2	Quenching	7
2.2.1	Current Quenching Control Technology	7
2.2.2	Potential Control Technology for Quenching	7
2.3	By-product Battery (Combustion) Stacks	9
2.3.1	Current Battery Stack Control Technology	9
2.3.2	Potential Control Technology for Battery Stacks	11
2.3.3	1-Hour Battery Stack Opacity Standards	11
2.4	By-product Soaking Emissions	11
2.5	Heat Recovery Steam Generators (HRSG) Main Stacks	12
2.5.1	Current HRSG Control Technology	12
2.5.2	Potential Control Technology for HRSG Main Stacks	13
2.6 	HNR Bypass/Waste Heat Stacks	13
2.6.1	Current Bypass/Waste Heat Stacks Control Technology	13
2.6.2	Potential Control Options for Bypass/Waste Heat Stacks	13
3.0	COKE OVEN BATTERIES NESHAP PROCESSES	14
3.1	Currently Required Leak Control at By-product Coke Oven Facilities (COB NESHAP)	15
3.2	Current Leak Control at By-product Coke Oven Facilities	19
3.3	Doors: Work Practice, Equipment, And Other Measures Used Currently Or In The Past To Minimize Leaks From Doors	19
3.4	Doors General Work Practices Required by 40 CFR Part 63 Subpart L for Preventing or Minimizing By-product Coke Oven Door Leaks	19
3.5	Doors - Specific Work Practices In Use for Minimizing Door Leaks	21
3.6	By-product Doors - Recommendations for Minimizing Door Leaks	21
3.6.1	Minimizing Door Leaks	21
3.6.2	U.S. Steel Battery Leak Rate as Best Available Control Technology (RBLC)	22
3.7	HNR Door Leaks	22
3.8	Lids- Work Practice, Equipment, And Other Measures Used Currently Or In The Past To Minimize Leaks For Lids	23
3.9	Lids - General Work Practices Required by 40 CFR Part 63 Subpart L for Preventing or Minimizing By-product Coke Oven for Lid Leaks	23
3.10	Lids - Specific Work Practices for Lid Leaks	23
3.11	Lids - Recommendation for Minimizing Leaks of Lids at By-product Facilities	23
3.12	Offtakes-Work Practice, Equipment, And Other Measures Used Currently Or In The Past To Minimize Leaks For Offtakes	23
3.13	Offtakes -General Work Practices Required by 40 CFR Part 63 Subpart L for Preventing or Minimizing By-product Coke Oven for Offtake Leaks	31
3.14	Offtakes -Specific Work Practices for Offtake Leaks	31
3.15	Offtakes - Recommendation for Minimizing Leaks of Offtakes at By-product Facilities	33
3.16	By-product Charging - Potential Charging Control Technologies	33
3.16.1	PROven Control Technology	33
3.16.2	Other Charging Technologies	33
3.17	HNR Charging Emissions at HNR Facilities	34
3.17.1	Current Charging Control at HNR Facilities	34
3.17.2	Potential HNR Charging Control Technology	34
3.18	Summary of Changes Being Proposed to COB NESHAP Processes under Technology Review	34
4.0	BY-PRODUCT CONVERSION OF BY-PRODUCT FACILITIES TO HEAT RECOVERY COKE FACILITIES	35
5.0	OVERALL COKE OVEN BATTERY OPTIMIZATION	35
6.0	OTHER TECHNOLOGY REVIEW SUBJECTS NOT INCLUDED HERE	37
7.0	REFERENCES	37
APPENDIX A	1
APPENDIX B	1
APPENDIX C	1
APPENDIX D	1
APPENDIX E	1
APPENDIX F	1

1.0	INTRODUCTION AND BACKGROUND

This memorandum describes the results of the technology review of the processes and practices in the coke industry as part of the Residual Risk and Technology Review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Coke Ovens: Pushing, Quenching, and Battery Stacks (40 CFR part 63, subpart CCCCC), and the NESHAP for Coke Oven Batteries (40 CFR part 63, subpart L). Appendix A lists the 14 coke oven facilities, their owners and locations, acronyms used for each facility name, process type, coke product type, and typical annual production.
There are two main process types of coke facilities: (1) by-product recovery, where chemical by-products are recovered from coke oven gas (COG) in a co-located chemical plant; or (2) nonrecovery, where chemicals are not recovered but heat may be recovered from the exhaust gas and referred to in this memorandum as heat and/or nonrecovery (HNR). There are 14 coke plants in the U.S., owned by six companies, located in 8 states. Nine of the 14 facilities are by-product facilities and five are HNR facilities, where four of the five HNR facilities recover heat from the process.
In accordance with section 112(d)(2) and (3) of the Clean Air Act (CAA), the United State (U.S.) Environmental Protection Agency (EPA) promulgated a NESHAP for Coke Ovens: Pushing, Quenching, and Battery Stacks (Coke PQBS) on April 14, 2003 (68 FR 18008). The COKE PQBS NESHAP established maximum achievable control technology (MACT) standards that included particulate matter (PM) limits as a surrogate for HAP metals for pushing, opacity limits for PM/HAP metals[1] from battery stacks of oven combustion air, and a work practice standard to limit PM and volatile HAP emissions for quenching.
The NESHAP for Coke Oven Batteries (COB) was promulgated on October 27, 1993 (58 FR 57898) and set standards for leaks of coke oven emissions (COE) from oven doors, lids, and offtakes, and for COE and PM from charging. The COB NESHAP limits the number of seconds of visible emissions (VE) during a charge or the percent of visible leaks from doors, lids, offtakes, where VE and visible leaks are determined by measurements made according to EPA Method 303 or 303a. Coke facilities were required by the CAA (CAA § 112(i)(8)) to choose to be regulated under one of two regulatory racks: either a MACT track or lowest achievable emissions rate (LAER) track, by 1993. (58 FR 57898.) The 1993 COB NESHAP established increasing stringent standards for doors, lids, offtakes, and charging in subsequent years for COB under the MACT track (1995 and 2003) and LAER track (1993, 1998, and 2010) in a tiered approach that was developed in a regulatory negotiation process. New coke facilities built after 1992 were required by the 1993 COB MACT to have zero percent leaking doors, lids, and offtakes, which in effect necessitated the use of NR technology for all new facilities. The RTR for COB, subpart L MACT track, was promulgated on April 15, 2005 (72 FR 1992). The RTR for COB subpart L LAER track was to be done by 2020 but was not done at that time. Only one of the nine by-product coke oven facilities remains as a MACT track facility today (Cleveland Cliffs, Middletown, OH). The other eight existing by-product facilities are on the LAER track. Four of the five existing HNR coke oven facilities are on the MACT track with only one, SC-Vansant-VA, on the LAER track.
Under the authority of CAA section 114 (42 U.S.C. 7414), the EPA sent an information collection request (hereafter referred to as the Coke CAA section 114 request) to selected facilities in the coke industry in April 2016, June 2022, and July 2022, that included questionnaires and source test requests to acquire the necessary data for the RTR for the Coke PQBS NESHAP and the technology review for COB NESHAP. The Coke Ovens Risk and Technology Review: Data Summary describes the 114 requests and the data received. See the memorandum titled Coke Ovens Risk and Technology Review: Data Summary located in the dockets for these rules (Docket ID No.'s EPA-HQ-OAR-2002-0085 (subpart CCCCC); and Docket ID No.'s EPA-HQ-OAR-2003-0051 (subpart L)).
The questionnaire portion of the Coke CAA section 114 requests included questions pertaining to inventory, process, and control device information for the emission units at the coke facilities. The source test request portions of the Coke CAA section 114 requests described the source tests, the test methods to be used, the pollutants to test, and other details concerning the requested testing. Copies of the Coke CAA section 114 requests and responses received by the EPA are included in dockets for both coke ovens rules, subparts CCCCC and L (Docket ID No.'s EPA-HQ-OAR-2002-0085 (subpart CCCCC); and Docket ID No.'s EPA-HQ-OAR-2003-0051 (subpart L)).
Under section 112(d)(6) of the CAA The EPA is required to perform a technology review of MACT standards every eight years. The EPA's technology review focuses on the identification and evaluation of developments in practices, processes, and control technologies that have occurred since the MACT standards were promulgated. In addition to reviewing the practices, processes, and control technologies that were considered at the time the NESHAP was originally developed (or last updated), a variety of data sources are reviewed in the investigation of potential practices, processes, or control technology to consider. Where developments in technology are identified, their technical feasibility, and estimated costs and other impacts are analyzed. The emission reductions associated with applying each development are also considered. This analysis informs EPA's decision as to whether it is necessary to revise the emissions standards. The appropriateness of requiring control technology for new sources versus retrofitting existing sources are taken into account in these decisions. 
For the technology review, as per CAA section 112(d)(6), any of the following can be considered to be a development:
Any add-on control technology or other equipment that was not identified and considered during development of the original MACT standards;
Any improvements in add-on control technology or other equipment (that were identified and considered during development of the original MACT standards) that could result in additional emissions reduction;
Any work practice or operational procedure that was not identified or considered during development of the original MACT standards;
Any process change or pollution prevention alternative that could be broadly applied to the industry and that was not identified or considered during development of the original MACT standards; and
Any significant changes in the cost (including cost effectiveness) of applying control techniques installed since the MACT (including control technology considered during the development of the original MACT standards).
The following two sections (Sections 2.0 and 3.0) address the review of technologies relevant to the processes and emission sources addressed in the COKE PQBS and COB NESHAPs, respectively. Section 4.0 addresses the conversion of by-product facilities to heat recovery coke facilities. Section 5.0 addresses technologies identified for overall coke plant operations. Section 6.0 addresses other technology review subjects that are not included in this memorandum, but in their own stand-alone memorandum. References are listed in Section 7.0.
2.0	COKE OVENS PUSHNG, QUENCHING, AND BATTERY STACKS NESHAP PROCESSES 

This rule addresses the pushing of coke out of the ovens, quenching the hot coke after it is pushed, and battery stacks of combustion air. The rule addresses emissions from both by-product and HNR facilities. However, HNR facilities do not have battery stacks and instead have waste heat stacks (for NR) or send the combustion air to a heat recovery steam generator (HRSG) or through bypass stacks if the HRSG are not available to accept the oven exhaust. 
The following sections discuss the current technology used for each type of emissions source and any new technology with better emissions control.
2.1	Pushing
During the pushing process, coke oven doors are opened at both ends of the coke oven and a pusher machine positioned next to the ovens pushes the incandescent coke from the coke side of the oven using a ram that is extended from the coal or push end of the oven to the coke end, where coke then leaves the oven. 
2.1.1	Current Pushing Control Technology 
Particulate emissions that escape from open ovens during pushing are collected via capture devices such as a moveable hood, belt-sealed duct, coke-side enclosed shed, or enclosed coke guide. Control devices for the captured PM from pushing include wet scrubbers, fabric filters, and multicyclones. These capture and control devices control HAP metals[1] that are in the form of PM. Table 1 shows the coke facilities and the pushing capture and control techniques. The Coke PQBS NESHAP includes limits for PM emissions (as a surrogate for metal HAP) from the pushing control device, ranging from 0.01 to 0.04 pound (lb) per ton (lb/ton), depending on whether the control device is mobile or stationary, and whether the battery is tall or short. Opacity during pushing is also limited to by the NESHAP to 30 or 35 percent, depending on whether the battery is short or tall, respectively.
Table 1. Pushing Capture and Control Techniques at Coke Facilities
                                 Facility Name
                                     City 
                                     State
                              Pushing Capture[1]
                         Pushing Control Technology 2
ABC Coke
Tarrant
                                      AL 
hood, duct
stationary
3FF
Cleveland Cliffs Middletown
Middletown
                                      OH
hood, duct, guide
stationary
FF
Cleveland Cliffs Monessen
Monessen
                                      PA
hood, duct, guide
stationary
FF
Cleveland Cliffs Burns Harbor
Burns Harbor
                                      IN
hood, duct, guide
stationary
2FF
Cleveland Cliffs Warren
Warren
                                      OH
guide, intake flow[3] 
mobile
wet scrubber car
EES Coke Battery
Detroit (River Rouge)
                                      MI
hood, duct, guide
stationary
FF
Cleveland Cliffs Follansbee
Follansbee
                                      WV
hood, duct, guide;
guide & shed
stationary
wet scrubber; FF
U.S. Steel Clairton Works
Clairton
                                      PA
hood & duct; shed
stationary
5FF
Bluestone
Birmingham
                                      AL
hood, duct
stationary
FF
SunCoke Gateway Energy & Coke
Granite City
                                      IL
hood, duct
mobile
multicyclone car
SunCoke Haverhill North Coke
Franklin Furnace
                                      OH
hood, duct
mobile
multicyclone car
SunCoke Indiana Harbor Coke
East Chicago
                                      IN
hood
stationary
FF
SunCoke Middletown Coke
Middletown
                                      OH
hood, duct
mobile
multicyclone car
SunCoke Jewell Coke and Coal
Vansant
                                      VA
shed
stationary
total enclosure
[1] Moveable hood (hood), belt-sealed duct (duct), cokeside shed (shed), or enclosed coke guide (guide).
[2] FF = fabric filter (baghouse). 
[3] Chemico(TM) System. Envirotech/Chemico Pushing Emissions Control System Analysis Fina I Report. EPA-340/ 1-83-019. Stationary Source Compliance Series. Office of Air Quality, Planning and Standards, Environmental Protection Agency, Washington DC 20460. April 1983.


Test data for pushing operations were obtained for the following facilities in the Coke CAA section 114 request: CC-Middletown-OH, CC-BurnsHarbor-IN, CC-Monessen-PA. and EC-Erie-PA. These facilities tested their pushing emissions for the following pollutants: acid gases (hydrogen chloride (HCl) and hydrogen fluoride (HF)), formaldehyde, hydrogen cyanide (HCN), mercury, particulate matter (PM)/non-mercury metal HAP, [1] polycyclic aromatic hydrocarbons (PAH), dioxins/furans (D/F), and volatile organic HAP (VOHAP). For formaldehyde, D/F, and VOHAP, more than 50 percent of the data were below the detection limits (BDL) and considered not valid for developing standards. For acid gases, HCN, mercury, and PAH, which had 50 or less percent BDL data, MACT standards being proposed along with periodic testing (PM emissions from pushing are already controlled by a 40 CFR part 63, subpart CCCCC MACT standard). The Coke CAA section 114 request emission data from all the tested sources, and emissions estimated for the other coke facilities from the test data, were at or below the MACT standards we are proposing for pushing. See details in the memorandum titled Maximum Achievable Control Technology Standard Calculations, Cost Impacts, and Beyond-the-Floor Cost Impacts for Coke Ovens Facilities under 40 CFR Part 63, Subpart CCCCC , hereafter called the "Coke RTR MACT Memorandum," located in the docket for this rule.
2.1.2	Potential Control Technology for Pushing 
Additional control technology for pushing were evaluated for the MACT pollutants to further reduce the HAP emissions from pushing. These technologies include activated carbon injection (for mercury and PAH) and wet alkaline scrubbers (for acid gases and HCN) as additional control devices collecting the exhaust of the current control devices. These additional technologies were not found to be cost-effective. See the Coke RTR MACT Memorandum for more details on the MACT and beyond-the-MACT floor cost impacts.[5] No capture technology has been identified that demonstrates reduced emissions from pushing beyond the current technologies in use; therefore, no recommendations are made to pushing capture or control technology under this review.
2.2	Quenching
The incandescent coke pushed from the ovens is received by rail quench cars that travel to a nearby quench tower. In the quenching process, several thousand gallons of water are sprayed from multiple ports within the quench tower onto the coke mass to cool it. The quench towers have baffles along the inside walls to condense any steam and coke aerosols, which then fall down the inside of the tower and exit as wastewater.
2.2.1	Current Quenching Control Technology 
The Coke PQBS requires that baffles limit the quench towers to 5 percent open space and for the dissolved solids in the quench water to be no greater than 1,100 milligrams per liter (mg/L). The Coke PQBS also requires the use of clean quench water.
Test data for quenching operations were obtained from USS-Clairton-PA in the Coke CAA section 114 request. Due to the difficulty in testing, no other valid facility test data were available. The USS-Clairton-PA facility tested the quenching emissions for the following pollutants: acid gases (HCl and HF), formaldehyde, HCN, mercury, PM/non-mercury metal HAP,[1] PAH, D/F, and VOHAP. For the HAP without current MACT limits, more than 50 percent of the data were below the detection limits (BDL) and not considered valid to develop standards, where needed (PM and acid gases are already controlled by 40 CFR part 63, subpart CCCCC MACT work practice standards). For details, see the memorandum titled Coke Ovens Risk and Technology Review: Data Summary.[4] 
2.2.2	Potential Control Technology for Quenching 
The potential control technologies for quenching have been divided into wet quenching and dry quenching because the potential technologies vary by type. Both techniques are discussed below.
Wet Quenching
In the European Union's (EU) 2013 (latest) document on best available technology (BAT) for the iron and steel industry, it was stated that optimum solutions to reduce the emissions of dust from wet quench towers include the use of lamella (thin layer) stack baffles, which are currently in use at U.S. facilities and is required by the rule (§ 63.7294). It is noted in the EU BAT document[6] that many quench towers around the world are equipped with emissions reduction baffles and that good operational performance has been reported with these baffles. Because quench towers are frequently in use, e.g. every 15 minutes, in order to reduce emissions, it was stated in the EU BAT document[6] that a restricted number of hours per month (e.g., four hours) be scheduled for maintenance. A way to increase maintenance and, thereby, decrease emissions is to have a standby (second) quenching tower. More than half (8 of 14) U.S. coke plants have more than one quench tower on site, but only two of the eight facilities have multiple quench towers for the same battery. Theoretically, all eight facilities with more than one quench tower would be able to use another on-site quench tower for a short period of time to enable maintenance. 
The EU BAT document[6] provided a methodology for the measurement of particulate emission from a wet, low-emission technology using Mohrhauer probes. The Mohrhauer method consists of capturing a part of the steam plume by the probe. Vapor enters the probe through the square-shaped inlet port and vapor leaves the probe through the outlet with a fabric (e.g., gauze) with minimal flow resistance. The dust deposited in the probe is transferred quantitatively to the containers after removing the back cover of the probe. The deposition of particulates in the probe is caused by a change of flow direction, centrifugal force, decreasing vapor flow rate, and filter effect of the fabric. The emissions that could be achieved as determined using this measurement technique and considered BAT in the EU document was less than 25 g dust/tonne (g/Mg) coke. This is equivalent to 0.05 lb/ton. Although the Mohrhauer method is not isokinetic, whereas EPA Method 5 is isokinetic, the upper prediction limit value calculated for U.S. quench towers based on EPA Method 5 test data obtained in 2016 at U.S. Steel Clairton (in PM tests performed for information purposes only because PM is already regulated) is 0.027 lb/ton (13.5 g/Mg), which is below the emissions achievable at a quench tower specified in the EU BAT document.[6] Other European researchers note the drawback of not using isokinetic sampling, but also note the difficulty, in general, of sampling quench tower exhaust, citing the unique conditions in a quench tower, e.g. high vapor content, highly unsteady vapor flow velocity varying between up to 15 meters per second (m/s) and near 0 m/s within one quench procedure.  Consequently, even if EPA Method 5 is used, this method does not allow strict conformance for use at quench towers and can be used only with certain drawbacks and with the same difficulties mentioned above as a practical matter.
Researchers from Poland attempted to verify the conclusions in the EU BAT document[6] for the emissions level that could be achieved in the wet quenching process, at 25 g/Mg coke, as determined using the Mohrhauer measurement method at three quench towers. The researchers found that in retesting the three quench towers using the Mohrhauer method, two of the three quench towers did not meet the values included in the BAT conclusions, where higher emissions were found, at 87 and 61 g/Mg coke, respectively. The lowest particulates emissions were recorded on the third quench tower and amounted to 22.5 g/Mg coke, and, therefore, did not exceed the reported EU BAT limit.[6]
U.S. Steel recently reported on their new low emissions quench towers (LEQTs) that have been installed at U.S. Steel Clairton-PA facility for C Battery (Quench Tower C), Batteries 13-15 (Quench Tower 5A), and Batteries 19-20 (Quench Tower 7A). U.S. Steel, in their 2020 Operations and Environmental Report for their Clairton-PA facility,[10] state that the LEQT are taller, have a larger cross-sectional area, and have a state-of-the-art double-baffle configuration that leads to significant reductions of particulate emissions during the coke quenching operation compared to conventional quenching (estimated to achieve 80 percent or more reduction in PM).[10] The US. Steel LEQTs also have an optimized water settling plant to clean the quench water, combined low moisture (LOMO) spray and sump quenching, intense and short single-spot quenching, which leads to a flat surface of the coke bed and, thereby, homogeneous coke moisture.[10] In addition, the U.S. Steel LEQT has greater height for generation of draught, a double baffle system with plastic baffles at the top of the tower and stainless steel baffles at the bottom, upper baffle plume spray for additional scrubbing of the plume, and an upper baffle cleaning system. The upper-level baffles aim mainly for fine dust separation and have smaller inner distances between the louvers than the lower-level baffles and have a separation efficiency of 74 percent for separation of the relevant PM size. The lower-level steel baffles, designed as such to eliminate any burning risk, have greater inner distances for the separation of coarser dust. The separation efficiency of the lower baffles for course PM is estimated at 92 percent. From both separation systems, a combined separation efficiency of 98 percent results.[8]
Dry Quenching
A coke dry quenching plant (CDQ plant) design consists of the shaft-like cooling unit, a waste heat boiler, and a gas recycling system. Coke is cooled in the cooling shaft chambers by means of circulation gas. The circulation gas is a mixture consisting mainly of nitrogen and other inert gases. This mixture is formed when the oxygen burns out during the start-up stage of the cycle. The temperature of the circulation gas after the chamber is about 780°C and, after the waste heat boiler, about 150°C. The temperature of the coke charged to the dry quenching chamber is about 1050°C and after the chamber, about 180°C. In a CDQ plant, the coke flows through the chamber in about five hours. The nominal capacity of a typical CDQ plant is less than 100 ton per hour per chamber. A unit working at full capacity produces about 25 tons per hour high pressure steam (93 bar). Coke is transported with belt conveyors from the CDQ plant to the coke screening station.[6]
Benefits of dry quenching include recovery of heat, slight improvement of coke quality, and is more practical in very cold countries where the wet system water can freeze. Drawbacks include high capital investment costs, economical only in countries with high energy prices where recovery of heat can offset the capital cost, (more) dust emissions during coke handling and, overall, a more complex technology than wet quenching. 
While the new technologies and innovations are promising, insufficient cost and feasibility experience are available currently to consider applying these techniques to the U.S. coke industry; therefore, no new technology is recommended at this time.
2.3	By-product Battery (Combustion) Stacks
The battery stack collects the underfire hot gases from the by-product coke oven flues and discharges to the atmosphere. If the oven wall brickwork is damaged, coal fines and coking decomposition products may leak from the coke oven into combustion exhaust gases. Conventional gas cleaning equipment, including electrostatic precipitators and fabric filters, have been installed on battery combustion stacks in the past. However, where coke oven walls are well maintained, the uncontrolled air emissions from combustion stacks have been found to equal controlled air emissions from combustion stacks at other coke batteries. 
2.3.1	Current Battery Stack Control Technology 
Battery stack HAP emissions are limited by the current Coke PQBS NESHAP to 15 percent opacity during normal operation and to 20 percent during extended coking, which is the period when the coke ovens are operated at a lower temperature to slow down the coke-making process. No add-on controls are currently used on battery stacks. The BACT/LAER Clearinghouse identified 15 percent opacity as best available control technology (BACT) for prevention of significant deterioration purposes in 2015 for the U.S. Steel Clairton coke facility (RBLC ID# PA-0295[13]).
In the 2016 Coke CAA section 114 request sent by the EPA to coke facilities, the battery stack opacity was reported as follows: 
For normal coking, one facility tested opacity from their battery stacks over a two-day period with a continuous opacity monitoring system (COMS) and reported an average of 3.7 percent opacity, which is 25 percent of the 15-percent opacity limit for normal coking in the rule. Another facility reported less than 1 percent opacity as measured by EPA Method 9 during normal coking, which is 7 percent of the 15-percent opacity limit for normal coking in the rule.
For extended coking, two facilities tested opacity from the battery stacks with a COMS over 11 and 13 days, respectively, and reported <1 and 7.4 percent opacity, respectively, which are <5 percent and 37 percent, respectively, of the 20-percent opacity limit for extended coking in the rule. Another facility reported less than 3.6 percent opacity as measured by EPA Method 9 during extended coking, which is 18 percent of the 20-percent opacity limit for extended coking in the rule.

Table 2 summarizes the battery stack opacity information submitted in the 2016 Coke CAA section 114 request using COMS over periods from 2 to 13 days.
Table 2. Battery Stack Opacity Obtained with COMS from the 2016 Coke CAA Section 114 Request
                                  Facility ID
                                  Battery ID
                                 Type of Coke
                                Type of Coking
                                   Operation
                             No. Days of COMS Data
                           Average Opacity (percent)
                            Opacity Limit (percent)
                      Average Opacity as Percent of Limit
                                 Normal Coking
CC-BurnsHarbor-IN
Battery #2 Stack
                                      BF
Normal
                                       2
                                      3.7
                                      15
                                      25
                                Extended Coking
CC-Middletown-OH
Battery Stack
                                      BF
Extended
                                      13
                                      7.4
                                      20
                                      37
USS-Clairton-PA
Battery B Stack
                                      BF
Extended
                                      11
                                     <1
                                      20
                                     <5
Note: BF = blast furnace coke.

In the 2016 Coke CAA section 114 request, the EPA requested testing for HAP emissions from battery stacks at the following facilities: CC-Middletown-OH, CC-BurnsHarbor-IN, CC-Monessen-PA, EC-Erie-PA, and USS-Clairton-PA. These facilities tested their battery stacks for the following pollutants: acid gases (HCl and HF), formaldehyde, HCN, mercury, PM/non-mercury metal HAP, [1] PAH, D/F, and VOHAP. For formaldehyde, D/F, PAH, and VOHAP, more than 50 percent of the data were BDL For acid gases, HCN, mercury, and PM (as a surrogate for metal HAP), [1] MACT standards we are proposing along with periodic testing to determine if facilities are at or below the standard. The Coke CAA section 114 requested emission data from all tested sources, and emissions estimated for the other coke facilities from the test data were at or below the MACT standards we are proposing for battery stacks. See details in the Coke RTR MACT Memorandum,[5] located in the docket for this rule.
2.3.2	Potential Control Technology for Battery Stacks
Because of the low opacity seen in the CAA section 114 responses (see Table 2), additional control technology for battery stacks to further reduce HAP emissions was not expected to be cost effective using the traditional control technology of activated carbon injection (for mercury) and wet alkaline scrubbers (for acid gases, HCN, and non-mercury metal HAP). Details can be found in the Coke RTR MACT Memorandum,[5] located in the docket for this rule. Because no other add-on control technology was identified, a control strategy based on control device technology for battery stacks is not recommended at this time.
2.3.3	1-Hour Battery Stack Opacity Standards
We acquired 1-hour battery stack opacity data as part of the 2022 CAA section 114 test request and also obtained information about work practices that are performed on ovens by current coke facilities to maintain oven integrity, which minimizes battery stack opacity. We are considering whether an additional 1-hour battery stack MACT standard is warranted to support the current 24-hour by-product battery stack standard in Coke Ovens: Pushing, Quenching, and Battery Stacks NESHAP. We are not proposing a 1-hour limit in this action because of the large quantities of data needed to develop 1-hour emissions and also for the analysis of reported oven wall work practices needed to determine if there is a correlation between these work practices and lower stack opacities in both the 24-hr and 1-hour time frames. Therefore, we are soliciting comments and information regarding these issues in the proposal, to potentially include comments regarding whether or not the EPA should include such a standard in the NESHAP in the final rule and an explanation as to why or why not; and what work practices would reduce high opacity on an hourly or 24-hr basis. 
The 1-hour opacity and work practice data collected as part of the 2022 CAA section 114 request are summarized in a memorandum titled Preliminary Analysis and Recommendations for Coke Oven Combustion Stacks, Technology Review for NESHAP for Coke Ovens: Pushing, Quenching, and Battery Stacks (40 CFR part 63, subpart CCCCC), which also graphically shows the 1-hour data, and is located in the docket to this rule.
2.4	By-product Soaking Emissions
The Coke Ovens: Pushing, Quenching, and Battery Stacks NESHAP regulates soaking emissions from coke ovens via work practice standards. Under 40 CFR section 63.7294, coke oven facilities must prepare and operate according to a written work practice plan for soaking emissions. The plan must include measures and procedures to identify soaking emissions that require corrective actions, such as procedure for dampering off ovens; determining why COE do not ignite automatically and, if not, then to manually do so; whether raw coke oven gas is leaking into the collecting main and if there is incomplete coking; and whether the oven damper needs to be reseated or other equipment needs to be cleaned. 
Soaking, for the purposes of the NESHAP, means the period in the coking cycle that starts when an oven is dampered off the collecting main and vented to the atmosphere through an open standpipe prior to pushing, and ends when the coke begins to be pushed from the oven. Visible soaking emissions occur from the discharge of coke oven via open standpipes during the soaking period due to either incomplete coking or leakage into the standpipe from the collecting main. 
Emissions from soaking are most pronounced with "green" coke, i.e., coke that has not completed the coking process. Work practice standards for soaking, covered in §63.7294, do not include opacity limits or control device requirements and rely on subjective observations from facility personnel. Furthermore, operational practices may prevent topside workers from seeing soaking emissions, which is a prerequisite for the current soaking work practice standards to apply. Currently, EPA Method 303A observations do not consider soaking emissions because intentional standpipe cap opening during pushing is not considered a leak from the oven and, therefore, is not included in the visible emissions observation field for ovens. We also are asking for comment on whether techniques exists to measure soaking emissions.
In addition, we are asking for estimates of HAP emissions from soaking to better understand the scope and scale of these emissions. We also are asking for comments on options for capturing and controlling these emissions using a secondary collecting main that routes standpipe exhaust to a control device with or without an associated emissions limit and for establishing an opacity limit for soaking emissions. We are not proposing controls or an opacity limit in this current action for soaking; however, we solicit comment and information regarding soaking emissions, including comments as to whether or not the EPA should include such a standard in the NESHAP in the final rule or a future rule and an explanation as to why or why not. We also solicit comments on changes to the soaking work practice requirements currently in the Coke Ovens: Pushing, Quenching, and Battery Stacks NESHAP. See the memorandum describing the experience by an EPA regional enforcement inspector in regard to soaking emissions titled Soaking Emissions from Coke Ovens: Mountain State Carbon LLC, Follansbee, WV, Inspection June 15-16, 2021. 
2.5	Heat Recovery Steam Generators (HRSG) Main Stacks
2.5.1	Current HRSG Control Technology 
The current HNR facilities control their HRSGs' exhaust gases a with flue gas desulfurization for sulfur dioxide (SO2) control followed by a fabric filter for PM control, and then discharge the treated gases to the atmosphere through the main stack. These control technologies are state-of-the-art for PM and SO2.
Test data for HRSG main stacks were obtained from SC-Middletown-OH, as part of the 2016 CAA section 114 test request, and CE-IndianaHarbor-IN, as part of the 2022 CAA section 114 test request. These facilities tested their HRSG main stack emissions for the following pollutants: acid gases (HCl and HF), HCN, mercury, PM/non-mercury metal HAP, [1] PAH, and D/F, and additionally BTEX and formaldehyde from CE-Indiana-Harbor-IN. For HCN, D/F, formaldehyde, and BTEX, a significant amount of the data were BDL. 
For acid gases, we are proposing PAH, mercury, and PM (surrogate for metal HAP), [1] MACT standards along with periodic testing to determine if facilities are at or below the standard. The Coke CAA section 114 request emission data from the tested sources, and emissions estimated for the other coke facilities from the test data, were at or below the MACT standards we are proposing for HRSG main stacks. See details in the Coke RTR MACT Memorandum,5 located in the docket for this rule. 
2.5.2	Potential Control Technology for HRSG Main Stacks 
No technology has been identified that demonstrates reduced emissions from HRSG stacks beyond the current control technology in use. However, better operation of the HRSG and/or sufficient alternate HRSG units would reduce the need for bypass events and subsequent uncontrolled emissions being emitted when one or more HRSG are off line and cannot process oven exhaust (as discussed in Section 2.5 below). Operational details leading to HRSG shut down are specific to the facility and not available to the EPA at this time. Because the facility generates a saleable product from the HRSG, the shutdown of these units is very likely not desirable to the facility and is unavoidable in the current state of HRSG operation.
2.6 	HNR Bypass/Waste Heat Stacks
2.6.1	Current Bypass/Waste Heat Stacks Control Technology 
Test data for HRSG bypass/waste heat stacks were obtained for SC-GraniteCity-IL as part of the 2016 CAA section 114 test request and SC-FranklinFurnace-OH as part of the 2022 CAA section 114 test request. These facilities tested their HRSG bypass/waste heat stack emissions for the following pollutants: acid gases (HCl and HF), HCN, mercury, PM/non-mercury metal HAP, [1] PAH, formaldehyde, VOHAP, and D/F. For VOHAP and D/F, more than 50 percent of the data were BDL and not used; for HCN, the SC-GraniteCity-IL test data was considered suspect and also not used while the SC-FranklinFurnace-OH had more than 50 percent of the data as BDL. For acid gases, we are proposing PAH, and formaldehyde MACT standards along with periodic testing to determine if facilities are at or below the standard. For mercury, and PM (surrogate for metal HAP), [1] we are proposing BTF standards along with periodic testing to determine if facilities are at or below the standard. The Coke CAA section 114 request emission data from the tested sources, and emissions estimated for the other coke facilities from the test data, were at or below the MACT standards we are proposing for HRSG main stacks. See details in the Coke RTR MACT Memorandum,[5] located in the docket for this rule. 
Based on the Coke CAA section 114 request, bypass/waste heat stacks were estimated to emit the following HAP in measurable quantities, based on the source testing described above: acid gases (HCl, HF), formaldehyde, mercury, PM/HAP metals,[1] and PAH. These HAP are emitted uncontrolled from bypass stacks when the HRSG are not able to accept the coke oven exhaust, i.e., bypass event, and at all times for the one HNR facility without any HRSG. Table 3 below shows the permitted hours of uncontrolled exhaust for each bypass/waste heat stack at HNR facilities.
2.6.2	Potential Control Options for Bypass/Waste Heat Stacks 
Potential control options for bypass/waste heat stacks identified include a reduction in bypass hours and control devices on bypass/waste heat stacks that exhaust to the atmosphere at all times. These two options are discussed below.
Table 3. Bypass/Waste Heat Permitted Hours for HNR Facilities
                                   Facility
  Maximum Permitted Hours per Year for Each Bypass/Waste Stacks Can Be Used 
                      Number of Bypass/Waste Heat Stacks
                 Total Hours of Bypass Permitted for Facility
SC-FranklinFurnace-OH
                                      192
                                      10
                                    1,920 
SC-GraniteCity-IL
                                      312
                                       6
                                    1,872 
SC-Middletown-OH
                                      312
                                       5
                                     1,560
SC-EastChicago-IN
                                     1,139
                                      16
                                    18,224 
SC-Vansant-VA
                                     8,760
                                      16
                                   140,160 

Reduction in Bypass Hours
The bypass hours at HNR facilities that are heat recovery (in all cases except for one) are well below the bypass hours of the nonrecovery facility, SC-Vansant (VA), that is not heat recovery and consequently emits coke oven exhaust to the atmosphere at all times. Discussion with the SunCoke corporate staff indicate that there is not enough space at the SC-Vansant (VA) facility to build HRSGs that would reduce the number of bypass hours. 
The next highest HNR per-stack and total bypass hours is at SC-EastChicago-IN. The 1,139 per-stack bypass hours permitted at SC-EastChicago-IN is allowed under a state permit condition and is over 3.5 times more than the next highest level at the other three heat recovery facilities, at 312 hours per stack. Because SC-EastChicago-IN has the most bypass stacks, at 16 stacks, the total bypass hours for the facility at 18,224 hours is almost 10 times the next highest heat recovery facility, which has only 1,920 total bypass hours. Since the SC-EastChicago-IN is owned by the same company as the other heat recovery facilities with much lower bypass hours, it is assumed that lower levels of bypass hours are not easily achievable at the SC-EastChicago-IN facility in its current form. However, further reduction in the bypass stack hours at this facility could be explored by the State of Indiana considering the reductions we are proposing by the EPA for SC-Vansant (VA) in this rulemaking, which would then make SC-EastChicago-IN the highest emitting HNR facility due to the number of bypass hours permitted.
Control Technology for Bypass/Waste Heat Stacks
Because of the potential health risk from the HAP emitted via by-pass stacks at SC-Vansant (VA), control technologies we are proposing for this facility as a beyond-the-floor measure. The controls will reduce the lifetime excess cancer risks to the individual most exposed to emissions from the source category to less than one in one million, as per CAA section 112 (f)(2). However, the costs of control for bypass/waste heat stacks at heat recovery facilities are not considered cost-effective. For details on these analysis, see the memorandum titled Maximum Achievable Control Technology Standard Calculations, Cost Impacts, and Beyond-the-Floor Cost Impacts[5] located in the docket for this rule. 
Because the SC-Vansant (VA) bypass stacks emit HAP uncontrolled at all times, control technology was explored to reduce these emissions because hours of bypass, or waste heat in this case, cannot be reduced. See the Coke RTR MACT Memorandum for costs and emissions with add-on control technology of activated carbon injection (ACI), wet alkaline scrubber, and regenerative thermal oxidizer for mercury, acid gases, total PAH, and formaldehyde and a second analysis of ACI and baghouse for mercury and non-mercury metal HAP, HAP.[5] For the heat recovery bypass stacks at the four other HNR, which are heat recovery facilities, no additional technology was found to be cost-effective, also reported in the Coke RTR MACT Memorandum,[5] and, therefore, no control technology is recommended at this time for heat recovery bypass stacks. 
      
3.0	COKE OVEN BATTERIES NESHAP PROCESSES

The COB NESHAP (40 CFR part 63, subpart L) addresses COE leaks from doors, charging port lids, and offtakes, and charging emissions. Doors are located on both sides of the ovens. Door leaks are COE emissions from coke oven doors when they are closed and the oven is in operation. The COB NESHAP includes leak limits for both by-product and HNR facilities. The offtake system, only used at by-product facilities, includes ascension pipes and then the collector main offtake ducts that are located on the top of the coke oven and battery. The offtake system operates at all times the battery is operating, which is 24 hours per day. The COB NESHAP includes VE leak limits for offtake ducts at by-product facilities The charging process for by-product facilities includes opening the lids on the charging ports on the top of the ovens and discharging of coal from hoppers of a car that positions itself over the oven port and drops coal into the oven. Lids are replaced after charging is completed. The COB NESHAP includes VE leak limits for lids at by-product facilities. There are no lids at HNR ovens because charging is done via the doors one side of the battery (called the "coal side") o using a pushing/charging machine (PCM) equipped with a large ram. [Coke is pushed out of the opposite side of a HNR oven, and is called the "push side" of the oven.] Charging is limited at both by-product and HNR facilities under the COB NESHAP. 
3.1	Currently Required Leak Control at By-product Coke Oven Facilities (COB NESHAP)
When the COB NESHAP was first promulgated, by-product coke oven batteries were required to prepare and submit a written emission control work practice plan for each coke oven battery per §63.306 on or before November 15, 1993. A summary of the specific components in the required plan are summarized in Table 4, which shows the required plan components for doors, lids, and offtakes as written in 40 CFR sections 63.306(b)(1), (2), (4), and (5). A summary of the requirements of the training program and work practice plan under § 63.306 is as follows:
 Training program for personnel responsible for minimizing leaks from doors, lids, and offtakes. (§63.306(1) A plan that describes the training program that includes: lists of personnel required to be trained; subjects to be covered; description of training method(s) that will be used; duration of and frequency of training; methods to be used to document successful completion of the training (for attendees) and training program (for the facility).
 For minimizing leaks from doors (§63.306(b)(2)):
 Develop a program for inspection, adjustment, repair, and replacement of coke oven doors and jambs, and any other equipment for controlling emissions and preventing leak exceedances from doors, which addresses the frequency of inspections, method used to evaluate how well the operating program for each type of equipment is followed, and how the facility will audit the effectiveness of the program. 
 The program should include the following:
 Procedures to be used for identifying leaks from malfunction of the emissions control equipment, including a clearly defined chain of command for communicating information and procedures to be used for corrective action;
 Procedures and schedule or frequency for cleaning all sealing surfaces of each door and jamb including identification of the equipment that will be used for batteries equipped with hand-luted doors, procedures for luting and reluting to prevent leak exceedances;
 Procedures for maintaining an adequate number of spare coke oven doors and jambs located onsite; and
 Procedures for monitoring and controlling collecting main back pressure, including corrective action if pressure control problems occur.
 Door leaks on batteries are controlled by repairing and maintaining doors, door seals, and jambs to prevent large gaps between the metal seal and the jamb. The manual application of a supplemental sealant such as sodium silicate is used at some plants to further reduce door leaks. A few batteries control door leaks by the external application of a luting material (mud or clay) to provide a seal (called hand-luted doors). 
 For minimizing leaks from topside port lids (§63.306(b)(4)):
 Develop a program for the inspection, adjustment, repair, and replacement of lids, to include:
 Procedures for equipment inspection and replacement or repair of topside port lids and port lid mating and sealing surfaces, including frequency of inspections, method to be used to evaluate conformance with operating specifications for each type of equipment, and method to be used to audit the effectiveness of the inspection and repair program for preventing exceedances; and
 Procedures for sealing topside port lids after charging, for identifying topside port lids that leak, and procedures for resealing.
 For lids, a luting material is applied to the edge of the lids after charging of the coal is completed and the lids are replaced.
 For minimizing leaks from offtake system(s) (§63.306(b)(5)):
 Develop a program for the inspection, adjustment, repair, and replacement offtakes, to include:
 Procedures for equipment inspection and replacement or repair of offtake system components, including the frequency of inspections, the method to be used to evaluate conformance with operating specifications for each type of equipment, and the method to be used to audit the effectiveness of the inspection and repair program for preventing exceedances;
 Procedures for identifying offtake system components that leak and procedures for sealing leaks that are detected; and Procedures for dampering off ovens prior to a push.
 For offtakes, procedures are required to be established for sealing leaks and for dampering off ovens from the offtakes prior to a push.
          For charging on by-product ovens, procedures are required to be established to ensure that larry car hoppers are filled properly with coal; that the larry car is aligned of over the oven to be charged, for correctly filling the oven in either staged or sequential charging; and for ensuring that the coal is leveled in the oven after charging.
          For charging HNR ovens, procedures are required to be established for cleaning coal from the door sill area after charging and before replacing the push side door; for filling gaps around the door perimeter with sealant material, if applicable; and for cleaning the door sill area before replacing the coke oven door.  


Table 4. Training and Leak Plan Components and Procedures for Controlling Emissions from 
Coke Ovens at By-product Coke Oven Batteries (§63.306(b))
Component/Citation
             Training and Leak Programs Components and Procedures
Training
§63.306(b)(1)
An initial and refresher training program for all coke plant operating personnel with responsibilities that impact emissions, including contractors, in job requirements related to emission control and the requirements of this subpart, including work practice requirements. Contractors with responsibilities that impact emission control may be trained by the owner or operator or by qualified contractor personnel; however, the owner or operator shall ensure that the contractor training program complies with the requirements of this section. The training program should be described in a plan that must include: 
(i) A list, by job title, of all personnel that are required to be trained and the emission point(s) associated with each job title; 
(ii) An outline of the subjects to be covered in the initial and refresher training for each group of personnel; 
(iii) A description of the training method(s) that will be used (e.g., lecture, video tape); 
(iv) A statement of the duration of initial training and the duration and frequency of refresher training; 
(v) A description of the methods to be used at the completion of initial or refresher training to demonstrate and document successful completion of the initial and refresher training; and 
(vi) A description of the procedure to be used to document performance of plan requirements pertaining to daily operation of the coke oven battery and its emission control equipment, including a copy of the form to be used, if applicable, as required under the plan provisions implementing paragraph (b)(7) of this section
Doors
§63.306(b)(2)(i)
A program for the inspection, adjustment, repair, and replacement of coke oven doors and jambs, and any other equipment for controlling emissions from coke oven doors, including a defined frequency of inspections, the method to be used to evaluate conformance with operating specifications for each type of equipment, and the method to be used to audit the effectiveness of the inspection and repair program for preventing exceedances; 
§63.306(b)(2)(ii)
Procedures for identifying leaks that indicate a failure of the emissions control equipment to function properly, including a clearly defined chain of command for communicating information on leaks and procedures for corrective action; 
§63.306(b)(2)(iii)
Procedures for cleaning all sealing surfaces of each door and jamb, including identification of the equipment that will be used and a specified schedule or frequency for the cleaning of sealing surfaces; 
§63.306(b)(2)(iv)
For batteries equipped with self-sealing doors, procedures for use of supplemental gasketing and luting materials, if the owner or operator elects to use such procedures as part of the program to prevent exceedances; 
§63.306(b)(2)(v)
For batteries equipped with hand-luted doors, procedures for luting and reluting, as necessary to prevent exceedances; 
§63.306(b)(2)(vi)
Procedures for maintaining an adequate inventory of the number of spare coke oven doors and jambs located onsite; and 
§63.306(b)(2)(vii)
Procedures for monitoring and controlling collecting main back pressure, including corrective action if pressure control problems occur. 
Topside Port Lids

§63.306(b)(4)(i)
Procedures for equipment inspection and replacement or repair of topside port lids and port lid mating and sealing surfaces, including the frequency of inspections, the method to be used to evaluate conformance with operating specifications for each type of equipment, and the method to be used to audit the effectiveness of the inspection and repair program for preventing exceedances; and
§63.306(b)(4)(ii)
Procedures for sealing topside port lids after charging, for identifying topside port lids that leak, and procedures for resealing.
Offtake System(s)
§63.306(b)(5)(i)
Procedures for equipment inspection and replacement or repair of offtake system components, including the frequency of inspections, the method to be used to evaluate conformance with operating specifications for each type of equipment, and the method to be used to audit the effectiveness of the inspection and repair program for preventing exceedances;
§63.306(b)(5)(ii)
Procedures for identifying offtake system components that leak and procedures for sealing leaks that are detected; and
§63.306(b)(5)(iii)
Procedures for dampering off ovens prior to a push.
 

3.2	Current Leak Control at By-product Coke Oven Facilities
The COB NESHAP limits COE leaks from doors, lids and offtakes, and charging based on the number of seconds of visible emissions (VE), as determined by measurements made according to EPA Method 303. The NESHAP limits for percent leaking doors, lids, and offtakes, and during charging for the current by-product coke facilities are shown in Table 5 and are based on the regulatory "track" of the facilities and, for some emission points, the size of the battery. Table 5 also shows the overall coke facilities' average facility leak rate for 2022 along with the facility average as a percent of the limit.
As seen in Table 5, coke facilities on the average are achieving much lower leak levels from doors and, to a lesser extent, lids and offtakes than that allowed under the current COB NESHAP, as follows: 
 Doors: The 2022 facility-average data showed a high of 46 percent of the standard for tall doors (standard 4.0 percent); a high of 52 percent of the standard for all other doors, i.e., not tall (standard 3.3 percent); and a high of only 36 percent of the standard for foundry (standard 4.0 percent);
 Lids: The 2022 facility-average data ranged from a minimum of 0 percent the standard (standard 0.4 percent) and a maximum of 22 percent of the standard. The average value was 8.0 percent and the median of 3.3 percent of the standard. 
 Offtakes: The 2022 facility-average data ranged from a minimum of 0.25 percent of the standard (standard 2.5 percent) and a maximum of 52 percent of the standard. The average value was 14 percent and the median of 10 percent of the standard. 
Charging: The 2022 facility-average data ranged from a minimum of 15 percent of the standard (12 seconds of VE per charge) and a maximum of 70 percent of the standard. The average value was 40 percent and the median of 38 percent of the standard. 
3.3	Doors: Work Practice, Equipment, And Other Measures Used Currently Or In The Past To Minimize Leaks From Doors
A summary of responses to questions in the 2022 CAA section 114 information request to by-product coke facilities about work practices to prevent leaks from doors that are not considered confidential business information (CBI) follows below. Appendix B contains the tabulated individual non-CBI company responses to work practices to prevent leaks from doors. 
3.4	Doors General Work Practices Required by 40 CFR Part 63 Subpart L for Preventing or Minimizing By-product Coke Oven Door Leaks
The following are non-CBI descriptions of general work practices used currently or in the past to prevent or minimize by-product coke oven door leaks as reported in the 2022 CAA section 114 responses from by-product coke facilities by four coke facilities. These work practices required by the rule are listed below. 
 Internal written procedures and job written SOPs, as required by rule;
 Battery foreman daily rounds (per shift) and documentation in battery shift turn report;
 Onsite door repair;
 Door inspection or repair program;
                                                                    (continued)
      
Table 5. Summary of By-Product Facility Method 303 Performance and COE Emissions Data from 2022 Coke 114 Request
                             Method 303 Parameters
  2022 Coke 114 Request Method 303 Data by By-productFacility[1] and Process 

                                ABC-Tarrant-AL
                               CC-Follansbee-WV
                               CC-Middletown-OH
                               CC-BurnsHarbor-IN
                                CC-Monessen-PA
                                 CC-Warren-OH
                               BLU-Birmingham-AL
                               EES-RiverRouge-MI
                                USS-Clairton-PA
Regulatory Track[1]
                                     LAER
                                     LAER
                                     MACT
                                     LAER
                                     LAER
                                     LAER
                                     LAER
                                     LAER
                                     LAER
No. Batteries
                                       3
                                       4
                                       1
                                       2
                                       2
                                       1
                                       3
                                       1
                                      10
No. Ovens
                                      132
                                      224
                                      76
                                      164
                                      56
                                      85
                                      120
                                      85
                                      708
                                   Charging
Seconds per Charge
Limit
                                      12
                                      12
                                      12
                                      12
                                      12
                                      12
                                      12
                                      12
                                      12

Facility Average
                                      4.7
                                      6.6
                                      5.8
                                      8.4
                                      4.4
                                      4.5
                                      4.0
                                      1.8
                                      2.4
Facility Average as % of Limit
                                      39%
                                      55%
                                      49%
                                      70%
                                      36%
                                      38%
                                      34%
                                      15%
                                      20%
COE Emissions (TPY)
                                     0.070
                                     0.068
                                     0.089
                                     0.29
                                     0.056
                                     0.074
                                     0.056
                                     0.035
                                     0.29
                                     Doors
                                Percent Leaking
                                     Limit
                                     4.0%
                                 3.3%/4.0%[3]
                                     3.3%
                                     4.0%
                                     3.3%
                                     3.3%
                                     4.0%
                                     4.0%
                                  3.3/4.0%[4]

                                 Door Type[2]
                                    foundry
                               all other/tall[3]
                                   all other
                                     tall
                                   all other
                                   all other
                                    foundry
                                     tall
                               all other/tall[4]

Facility Average
                                     0.85%
                                     0.44%
                                     1.7%
                                     1.8%
                                     0.11%
                                     1.2%
                                     1.4%
                                     0.12%
                                     0.46%
                        Facility Average as % of Limit
                                      21%
                                  13%/11%[3]
                                      52%
                                      46%
                                     3.4%
                                      36%
                                      36%
                                     2.9%
                                  14%/11%[4]
COE Emissions (TPY)
Existing Equation 
                                      2.3
                                      3.2
                                      1.4
                                      3.0
                                     0.70
                                      1.4
                                      2.0
                                      1.1
                                      9.7
COE Emissions (TPY)
Revised Equation
                                      1.0
                                     0.71
                                     0.70
                                      1.6
                                     0.031
                                     0.54
                                     0.87
                                     0.053
                                      1.7
                                     Lids
                                Percent Leaking
                                     Limit
                                     0.4%
                                     0.4%
                                     0.4%
                                     0.4%
                                     0.4%
                                     0.4%
                                     0.4%
                                     0.4%
                                     0.4%

                               Facility Average
                                    0.014%
                                    0.0023%
                                    0.053%
                                    0.075%
                                     0.0%
                                    0.084%
                                    0.087%
                                    0.013%
                                    0.0054%
Facility Average as % of Limit
                                     3.5%
                                     0.57%
                                     1.3%
                                      19%
                                     0.0%
                                      21%
                                      22%
                                     3.3%
                                     1.4%
COE Emissions (TPY)
                                    0.0032
                                    0.00095
                                    0.00040
                                     0.019
                                       0
                                    0.0070
                                     0.016
                                    0.0015
                                    0.0057
                                   Offtakes
                                Percent Leaking
                                     Limit
                                     2.5%
                                     2.5%
                                     2.5%
                                     2.5%
                                     2.5%
                                     2.5%
                                     2.5%
                                     2.5%
                                     2.5%

Facility Average
                                    0.0061%
                                     0.25%
                                    0.014%
                                     0.36%
                                    0.023%
                                     1.3%
                                     0.69%
                                    0.068%
                                     0.42%
Facility Average as % of Limit
                                     0.25%
                                     9.9%
                                     0.56%
                                      14%
                                     0.91%
                                      52%
                                      27%
                                     2.7%
                                      17%
COE Emissions (TPY)
                                    0.00020
                                     0.049
                                    0.00069
                                     0.019
                                    0.00084
                                     0.072
                                     0.028
                                    0.0038
                                     0.19
[1]All facilities except CC Middletown-OH are subject to the LAER 1/1/2010 limits. CC Middletown-OH is subject to the MACT Track RTR 7/2005 limits. 
[2]Tall doors are doors greater than 6 meters (20 ft) in height. "All other" doors are either not tall or not at a foundry coke facility. HNR facilities are not permitted to have any leaking doors and do not have lids or offtakes.
[3] Three of 4 batteries at CC Follansbee WV are "all other" with door limits of 3.3% and the fourth battery is "tall" with door limit of 4.0%. Data presented for both.
[4] Eight of the 10 batteries at USS Clairton PA are "all other" with door limits of 3.3% and two batteries are "tall" with door limits of 4.0%. Data presented for both.


Table 6. Costs, Labor, and Control Efficiency Responses Reported for Work Practices, Equipment, and Other Measures Minimize Leaks for Doors 
                                   Cost Item
                                   Estimates
Capital Purchases
Negligible
Annual Operating Expenses
<$100K - <$500K ($2022)
Labor Hours

                                                                        Per Day
2 *
                                                                       Per Week
14* 
                                                                       Per Year
730* 
Type of Labor
Manager, operator, operator and contractor, operator and manager, skilled trades, skilled trades and operator, skilled trades, operator and contractor
Estimated Control Efficiency of Work Practice
Varies 
*Respondents provided an estimate, but stated that the value varies.
      
      
 Adjustment of new or repaired doors;
 Spare door inspection;
 Jamb and door cleaning cycle inspection; 
 Door jamb inspection, repair and replacement;
 Boarding of door machine in and out of service;
 Inspect and clean door machine door cleaner blades;
 Cleaning and inspection of chuck doors;
 Cleaning of oven doors and jambs (if not automatic);
 Pusher operator pre-job inspection; and
 Inspect and clean pusher side door cleaning blades.
      
    Two facilities' responses were entirely CBI and are not included here. One company claimed as CBI the cost and labor information of internal written procedures and job written standard operating practices (SOPs), also not included here. Table 6 summarizes the responses to questions about the cost, labor, and control efficiency of the general work practices to prevent or minimize leaks from by-product coke oven doors.
3.5	Doors - Specific Work Practices In Use for Minimizing Door Leaks
Specific work practices for minimizing door leaks reported (non-CBI) as being used currently or in the past by by-product coke facilities are summarized below in Table 7. The work practices that are beyond the required work practices in 40 CFR part 63, subpart L (shown in Table 4) are noted. The entire (non-CBI) responses by each facility are included in Appendix B. 
3.6	By-product Doors - Recommendations for Minimizing Door Leaks
3.6.1	Minimizing Door Leaks
Due to improvements in leak control at coke oven facilities, we are proposing to lower the door leak limits in the NESHAP under the technology review for the Coke Oven Batteries source category for both MACT track and LAER track by-product coke facilities. We are proposing for facilities with coke production capacity of more than 3 million tpy coke to lower the allowable leaking door limit from the current limit of 4 percent to 1.5 percent for tall leaking doors and from 3.3 percent to 1.0 percent for "not tall" leaking doors observed from the yard. The standards we are proposing for existing and new facilities would only apply currently to U.S. Steel Clairton. For Coke Oven Batteries facilities that have coke production capacity less than 3 million tpy coke, we are proposing an allowable leaking door limit of 3.0 percent leaking doors observed from the yard for all sizes of doors (currently 4.0 and 3.3 percent allowable leaking doors for tall and not tall doors, respectively, as described earlier in this preamble). Both changes we are proposing to the allowable limits would ensure continued low emissions from leaking doors. The reduced levels reflect improvements in performance of the facilities to minimize leaks from doors.
3.6.2	U.S. Steel Battery Leak Rate as Best Available Control Technology (RBLC)
Insight into the best available technology for leaks at by-product coke plants can be seen in the results of the RBLC[13] BACT evaluations for U.S. Steel Clairton in 2010 (RBLC ID# PA-0295[13]), for leaking doors, leaking lids, and charging VE. U.S. Steel Clairton is by far the largest coke plant in the U.S., with coke capacity over three times the next largest facility. For leaking doors, the 2 percent leaking doors (current standard is 4 percent) was BACT in the RBLC[13] for U.S. Steel Clairton, where the average reported value for 2022 in the CAA section 114 request for U.S. Steel Clairton was 0.46 percent leaking doors, as a facility average. For leaking lids, in the RBLC[13] 0.15 percent leaking lids (current standard is 0.4 percent) was specified as BACT U.S. Steel Clairton, where the average reported for 2022 in the Coke CAA section 114 request was 0.0054 percent leaking lids, as a facility average. For charging, the BACT for VE during charging in the RBLC[13] at U.S. Steel Clairton was 12 seconds of VE (the current standard), where the average reported for 2022 in the Coke CAA section 114 request was 2.4 seconds of VE during charging, as a facility average. 
3.7	HNR Door Leaks
The current method of assessing HNR oven doors for leaks under the Coke Oven Battery NESHAP (40 CFR section 63.303(b)) is through the use of EPA Method 303 or 303A, methods based on observing VE emanating from the ovens and seen with the unaided eye, excluding steam or condensing water, by trained human observers. While VE has been used as an effective surrogate for monitoring door leaks in the past, especially for by-product facilities, the EPA is soliciting comment on whether there are other surrogates or practices which could be applied to HNR door leaks. The EPA is also soliciting comment on the potential use of alternative monitoring approaches or techniques which could be applied for determining leaks from HNR doors using the existing or other surrogate approaches or techniques. For those alternative techniques that could be applied to measuring door leaks, the EPA is soliciting information on equivalency studies that have been performed against Method 303 and/or 303A, and any potential training requirements and/or associated monitoring procedures for the alternative techniques. 
Monitoring pressure in the ovens and common tunnel to establish negative oven pressure and establish leaks of 0.0 for HNR doors currently is allowed as an alternate method to observing leaks with EPA Method 303A under 40 CFR section 63.303(b). We are proposing to require both methods, EPA Method 303A and pressure monitoring, to establish negative pressure in the ovens and 0.0 leaks. The current practice at HNR facilities is to operate one pressure monitor per common tunnel that may connect to 15 to 20 ovens and is, therefore, not very sensitive to pressure loss at one oven. Despite leaking emissions in one oven, a common tunnel with one pressure transducer may still show negative pressure within the tunnel. Also, facilities often only have one pressure transducer per oven, which might not be sufficient to monitor and establish negative pressure. We are considering a requirement for HNR facilities to develop and submit a monitoring plan to their delegated authority to ensure that there are sufficient pressure monitors in the ovens and common tunnels to be able to determine that all ovens are operated under negative pressure. We are not proposing this requirement at this time, however we are soliciting comment on this potential requirement and whether the EPA should allow each facility to suggest a site-specific number of monitors needed as part of the monitoring plan that they submit to the delegated authority for review and approval or whether EPA should establish a prescriptive minimal number of pressure monitors for each of the ovens and common tunnels in the NESHAP.
3.8	Lids- Work Practice, Equipment, And Other Measures Used Currently Or In The Past To Minimize Leaks For Lids
A summary of non-CBI responses to questions in the 2022 CAA section 114 information request to by-product coke facilities about work practices to prevent leaks from lids follows below. Appendix C contains the tabulated individual non-CBI company responses to work practices to prevent leaks from lids. 
3.9	Lids - General Work Practices Required by 40 CFR Part 63 Subpart L for Preventing or Minimizing By-product Coke Oven for Lid Leaks
The following are non-CBI descriptions of general work practices used currently or in the past to prevent or minimize by-product coke oven lid leaks as reported in the 2022 CAA section 114 responses from by-product coke facilities. Cost, labor, and control efficiency are summarized in Table 8. Appendix C contains tabulated individual company responses to work practices for offtakes. Two companies' responses were entirely CBI. One company claimed as CBI the cost and labor information of internal written procedures and job written SOPs. 
 Written general procedures and job-specific SOPs;
 Inspection, cleaning, repair and replacement of topside port lids;
 Sealing and resealing of topside port lids; and
Audit of lid inspection and repair program.
3.10	Lids - Specific Work Practices for Lid Leaks
Specific work practices for lid leaks that are currently reported (non-CBI) as being used currently or in the past by by-product coke facilities are summarized in Table 9. The work practices that are beyond the required work practices in Table 4 are noted. Entire non-CBI facility responses are included in Appendix C. 
3.11	Lids - Recommendation for Minimizing Leaks of Lids at By-product Facilities
Due to improvements in operation by the coke facilities, where actual emissions are much lower than allowable limits in many cases, we also are proposing to lower the lid leak allowable limits in the NESHAP under the technology review for the Coke Oven Batteries source category. The current NESHAP includes a limit of 0.4 percent leaking lids. We are proposing a revised leaking lid limit of 0.2 percent leaking lids. The change we are proposing to the limit would ensure continued low emissions from leaking lids. These reduced levels reflect improvements in performance of the facilities to minimize leaks from lids.
3.12	Offtakes-Work Practice, Equipment, And Other Measures Used Currently Or In The Past To Minimize Leaks For Offtakes
A summary of non-CBI responses to questions in the 2022 CAA section 114 information request to by-product coke facilities about work practices to prevent leaks from offtakes follows below. Appendix D contains the tabulated individual non-CBI company responses to work practices to prevent leaks from offtakes. 
      
      
Table 7. Specific Work Practices, Equipment, and Other Measure Reported as Used to Minimize Leaks for Doors
             Work Practice / Equipment / Other Measure Description
                   Required or Beyond Minimum Requirements 
                        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 (%)
                           1. Program for Inspection
Program for the inspection, adjustment, repair, and replacement of coke oven doors and jambs, and any other equipment for controlling emissions from coke oven doors, including a defined frequency of inspections, the method to be used to evaluate conformance with operating specifications for each type of equipment, and the method to be used to audit the effectiveness of the inspection and repair program for preventing exceedances
                                   Required
                                       6
                                   <$100K
                                  $100K-$17M
                                     <8
                                    <40
                                   <2,080
                                 subcontractor
                                    >50%
Per shift inspection by battery foreman and pusher operator
                          Beyond Minimum Requirements
                                       1
                                       
                                   $815,381
                          2 hr/day  foreman rounds; 
                         2 hr/day for each other item 
                                      154
                                     8,030
                               foreman+ workers
                                       
Daily inspections, and cleaning if needed, of door, jambs, and door machine cleaning blades, and cleaning cycle
                          Beyond Minimum Requirements
                                       1
                                       
                                    $72,463
                                   2 hr/day 
                                      14
                                      730
                               battery operators
                                       
                   2. Procedures for Identifying Door Leaks
Procedures for identifying door leaks that indicate a failure of the emissions control equipment to function properly, including a clearly defined chain of command for communicating information on leaks and procedures for corrective action
                                   Required
                                       6
                                   <$100K
                                       
                                <$100K-$324K
                                       1
                                       7
                                      364
                           subcontractor / operators
                                    >50%
Tracking problem doors and when and if they are to be repaired in place or replaced with a new door
                          Beyond Minimum Requirements
                                       1
                                       
                                    $36,231
                                       1
                                       7
                                      365
                               battery operators
                                       
Procedures for cleaning all sealing surfaces of each door and jamb, including identification of the equipment that will be used and a specified schedule or frequency for the cleaning of sealing surfaces
                                   Required
                                       6
                                   <$100K
                                   <$100K
                                     <8
                                    <16
                                    <832
                                   operators
                                    >50%
               3. For Batteries Equipped with Self-Sealing Doors
Procedures for use of supplemental gasketing and luting materials, if the owner or operator elects to use such procedures as part of the program to prevent exceedances
                                   Required
                                       6
                                   <$100K
                                   <$100K
                                     <8
                                    <40
                                   <2,080
                           subcontractor / operators
                                    >50%
                4. For Batteries Equipped with Hand-Luted Doors
Procedures for luting and reluting, as necessary to prevent exceedances; procedures for maintaining an adequate inventory of the number of spare coke oven doors and jambs located onsite; and procedures for monitoring and controlling collecting main back pressure, including corrective action if pressure control problems occur
                                   Required
                                       
                                       5
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                            5. Flexible Door Seals
Flexible door seals
                          Beyond Minimum Requirements
                                       3
                                   <$100K
                                   <$100K
                                     <8
                                    <16
                                    <832
                                   operators
                                    >50%
                    6. Periodic Complete Overhaul of Doors
Complete dismantling of all individual parts, cleaning and reassembling; readjustment of the sealing elements
                                   Required
                                       6
                                  $100K-$250K
                                  $100K-$250K
                                       8
                                      40
                                     2,080
                          operators / subcontractors
                                    >50%
Periodic replacement of damaged door bricks; (complete rebricking of the door may be necessary)
                                   Required
                                       5
                                  $100K-$250K
                                  $100K-$250K
                                       8
                                      40
                                     2,080
                          operators / subcontractors
                                    >50%
Careful cleaning of the door and its frame at each coke push
                                   Required
                                       6
                                   <$100K
                                   <$100K
                                     <8
                                    <16
                                    <832
                                   operators
                                    >50%
                         7. Gas Channels Inside Doors
Gas channels inside doors
                          Beyond Minimum Requirements
                                       4
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                                      CBI
                                      CBI
      
                                       

Table 8. Cost, Labor, and Control Efficiency Reported for Work Practices, Equipment, and Other Measure Descriptions Used Currently or in the Past to Minimize Leaks for Lids
                                     Item
                                     Value
Cost - Capital Purchases and Year$
                                  Negligible
Cost - Annual Operating Expenses and Year$
                                   <$100K
Labor (hrs/day)
                                       2
Labor (hrs/week)
                                      14
Labor (hrs/yr)
                                      730
Type of Labor 
Manager, operator
Estimated Control efficiency (%) of Work Practice
                                    Varies
   
      
      
Table 9. Specific Work Practice, Equipment, and Other Measure Used to Minimize Leaks for Lids
             Work Practice / Equipment / Other Measure Description
                    Required or Beyond Minimum Requirements
                        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 (%)
Procedures for equipment inspection and replacement or repair of topside port lids and port lid mating and sealing surfaces, including the frequency of inspections, the method to be used to evaluate conformance with operating specifications for each type of equipment, and the method to be used to audit the effectiveness of the inspection and repair program for preventing exceedances
                                   Required
                               §63.306(b)(4)(i)
                                       6
<$100K
<$100K - $1.4M
1
7
365
Operators
>50%
Procedures for sealing topside port lids after charging, for identifying topside port lids that leak, and procedures for resealing
                                   Required
                              §63.306(b)(4)(ii)
                                       6
<$100K
<$100K
<8
<40
<2,080
Subcontractors
>50%
Luted lids
                     Beyond Minimum Requirements for Lids
                                       6
<$100K
<$100K
<8
<40
<2,080
Subcontractors
>50%)
      

3.13	Offtakes -General Work Practices Required by 40 CFR Part 63 Subpart L for Preventing or Minimizing By-product Coke Oven for Offtake Leaks
The following are non-CBI descriptions of general work practices used currently or in the past to prevent or minimize by-product coke oven offtakes leaks as reported in the 2022 CAA section 114 responses from one coke company.[17] The reported costs, labor, and control efficiency of these work practices are shown in Table 10. Two companies' responses were entirely CBI. One company claimed as CBI the cost and labor information of internal written procedures and job written SOPs. 
 Internal written procedures and job written SOPs, as required by rule.
 Inspection and cleaning (decarbonization) of the following;
 Standpipe cap;
 Gooseneck;
 Damper and main duct;
 Oven roof;
 Charging hole; and
 Liquor system;
 Utility worker offtake system review;
 Audit of offtake system inspection and repair program;
Dampering ovens prior to push. (required)

Table 10. Cost, Labor, and Control Efficiency Details for Work Practice, Equipment, and Other Measure Descriptions Used Currently or in the Past to Minimize Leaks for Offtakes
                                     Item
                                     Value
Cost - Capital Purchases and Year$
                                  Negligible
Cost - Annual Operating Expenses and Year$
                                   <$100K
Labor (hrs/day)
                                  Varies to 2
Labor (hrs/week)
                               Varies to 2 - 14
Labor (hrs/yr)
                              Varies to 104 - 730
Type of Labor 
                               Manager, operator
Estimated Control efficiency (%) of Work Practice
                                    Varies
      
3.14	Offtakes -Specific Work Practices for Offtake Leaks
Specific work practices for minimizing offtake leaks reported (non-CBI) as being used currently or in the past by By-product coke facilities are summarized below in Table 11. The entire non-CBI facility responses are included in Appendix D. 
      
Table 11. Specific Work Practice, Equipment, and Other Measure Used to Minimize Leaks for Offtakes
             Work Practice / Equipment / Other Measure Description
             Work Practice Required or Beyond Minimum Requirements
                        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 (%)
Procedures for equipment inspection and replacement or repair of offtake system components, including the frequency of inspections, the method to be used to evaluate conformance with operating specifications for each type of equipment, and the method to be used to audit the effectiveness of the inspection and repair program for preventing exceedances
                                   Required
                               §63.306(b)(5)(i)
6
<$100K
<$100K - $10M 
1
7
364
subcontractor/ operators
>5%
Procedures for identifying offtake system components that leak and procedures for sealing leaks that are detected
                                   Required
                              §63.306(b)(5)(ii)
6
<$100K
<$100K 
1
7
364
subcontractor/ operators
>50%
Procedures for dampering off ovens prior to a push
                                   Required
                              §63.306(b)(5)(iii)
6
<$100K
<$100K 
<8
<40
<2080
subcontractors
>50%


3.15	Offtakes - Recommendation for Minimizing Leaks of Offtakes at By-product Facilities
Due to improvements in operation by the coke facilities, where actual emissions are much lower than allowable limits in many cases, we also are proposing to lower the offtake leak allowable limits in the NESHAP under the technology review for the Coke Oven Batteries source category. The current NESHAP includes a limit of 2.5 percent leaking offtakes. We are proposing a revised offtake limit of 1.2 percent leaking offtakes. The change we are proposing to the limit would ensure continued low emissions from leaking offtakes. These reduced levels reflect improvements in performance of the facilities to minimize leaks from offtakes.
3.16	By-product Charging - Potential Charging Control Technologies 
No technology other than that currently in use was cited by coke facilities that reduce charging emissions in the 2016 or 2022 Coke CAA section 114 request responses. No technology has been identified as generally applicable to charging emissions in the U.S. beyond the current control technology in use; therefore, no recommendations are being made at this time. Potential control options for charging were identified in the EU BAT document[6], one of which is in use by the largest coke facility in the U.S. (the German PROven control technology), are discussed below. The EU BT document also cited U.S. charging practices as BAT. These EU BAT technologies and recommendations are discussed below.
3.16.1	PROven Control Technology 
A control technology identified for potentially reducing emissions during charging is the PROven control technology (for Pressure Regulated Oven (PRO)), which works by decoupling the oven pressure from the collecting main pressure. The collecting main operates with negative pressure and the pressure inside each oven is controlled individually. Charging gases are sucked off by the negative pressure collecting main. See Appendix F for details provided by the PROven company (DMT GmbH & Co. KG, Essen, Germany). No data on emission reductions or costs of the technology were provided by the German company on EPA's request. 
The only known application of this technology in the U.S. is on Battery C at U.S. Steel-Clairton. The representatives of U.S. Steel said it was possible to construct Battery C with PROven technology because the technology was included as part of the original design prior to the battery that started up in November 2012. The U.S. Steel representatives said that the cost of the technology was included in the original battery construction costs; therefore, they lack any information regarding the itemized cost of the PROven technology separate from the other components of the battery. All of the other USS-Clairton batteries were constructed before Battery C. The American Coke and Coal Chemicals Institute's Coke Ovens Environmental Task Force (COETF) members (coke facilities) are not aware of any applications of PROven technology - either the original generation or the "next generation" of the technology described in the vendor's presentation materials (Appendix F) to existing batteries in the U.S. Hence, the COETF members said they have no information on the feasibility, efficacy, or cost of retrofitting PROven on existing coke ovens.[18] The EPA is soliciting specific information on control efficiency and costs of this control technology process. 
3.16.2	Other Charging Technologies 
In the EU BAT document[6] it was stated that emissions from charging are difficult to quantify, but that less than 30 seconds of visible emissions per charge is generally achievable (12 seconds or less is required in the COB NESHAP). In the EU BAT document,[6] three charging work practice techniques were identified as BAT for charging at by-product plants, as listed below, but without any cost or emission reduction information. The third technique is already in use in the U.S.
 Gas-tight connections between the coke oven and the charging car (by-product coke) that provide smokeless charging. Suction is generated by steam or water injection in the gooseneck of the ascension pipe.
 Charging with telescope sleeves (`Japanese charging') by simultaneous charging many charging ports via enclosed `telescope sleeves' from which the gases are extracted and sent to control devices.
Sequential/stage charging, which involves charging one port at a time; with the resulting induced suction, no/little emissions occur. In the EU BAT document,[6] it was noted that many plants in the U.S. use sequential/stage charging and that the limit in the U.S. (EPA method 303) for by-product COB is 12 seconds of visible emissions per charge, with values less than 5 seconds measured in practice on many U.S. batteries.
3.17	HNR Charging Emissions at HNR Facilities
Charging at HNR facilities involves opening one of the two doors on an oven and loading coal into the oven using the PCM. For HNR facilities operating before 1995, the COB NESHAP requires good operating and maintenance practices to minimize emissions during charging. This requirement for charging only affects the SC-Vansant-VA facility, which is a nonrecovery coke facility. For HNR facilities operating after 1995, which includes the other four HNR facilities (that are heat recovery) and any future HNR facilities, the NESHAP regulates charging emissions via a requirement for a PM control device, PM and opacity limits, and work practices for minimizing visible emissions during charging. 
3.17.1	Current Charging Control at HNR Facilities 
Fabric filters are used to reduce PM emissions from charging at four of the five HNR facilities subject to the COB NESHAP under the new source limits, to achieve a charging limit of 0.0081 lb PM/ton coke. The one "existing" HNR facility currently operating is required to perform good air pollution control practices and other work practices to limit charging emissions, which include any special procedures for minimizing air infiltration during charging, maximizing the draft on the oven, and for replacing the door promptly after charging. Charging at "new' HNR facilities also is required to not exceed 10 percent opacity from control devices and 20 percent opacity from charging fugitives.
3.17.2	Potential HNR Charging Control Technology 
No technology has been identified that demonstrates reduced emissions from HNR charging beyond the current control technology in use; therefore, no recommendations are being made at this time. The use of fabric filters is considered state-of-the art for controlling PM emissions.
3.18	Summary of Changes Being Proposed to COB NESHAP Processes under Technology Review
Due to improvements in leak control at coke oven facilities, we are proposing to lower the door leak limits in the NESHAP under the technology review for the Coke Oven Batteries source category for both MACT track and LAER track ByP coke facilities. Table 12 summarizes the changes being proposed under the technical review performed to fulfill CAA section 112(d)(6) for compared to the current rule requirements under the COB NESHAP. Table 13 shows the estimated allowable emissions before and after the changes being proposed to the limits for leaking doors, lids, and offtakes at byproduct coke oven facilities under the COB NESHAP.
4.0	BY-PRODUCT CONVERSION OF BY-PRODUCT FACILITIES TO HEAT RECOVERY COKE FACILITIES 

New sources of COB under the COB NESHAP are required to achieve zero leaks from doors, lids, and offtakes, making the current by-product technology unlikely to be used or retrofitted for new sources. Building a new heat recovery facility would be the only option for a new source, but this would require building an entirely new facility on a separate track of land either on-site or on an adjacent site while the current by-product facility continued to operate. 
In the EU BAT document,[6] costs for a new heat recovery facility were estimated (including the coke ovens) in $1998. Converting to $2020 and U.S. tons, the estimated costs for a new greenfield heat recovery plant producing 1.34 million tons per year (tpy) coke were estimated at $550 million (US $2020) and included the COB, coal handling/blending, and the power generating units. Costs per ton of coke for the full facility including the power-generating units are then $252/ton ($2020) based on the EU estimates. For a nominal coke facility producing 550,000 tpy coke, capital costs would be approximately $130M based on the EU estimates. A higher value for a new heat recovery facility, at approximately $750 million for same size plant, was provided by the company that owns all of these facilities in the U.S. 
Neither of these values for conversion of by-product facilities to heat recovery coke facilities are considered cost-effective; therefore, this technology was not considered viable under the current technology review.
5.0	OVERALL COKE OVEN BATTERY OPTIMIZATION

In the EU BAT document,[6] information on an overall plant optimization in order to minimize emissions was presented, as follows:
      "A smooth and undisturbed operation of the coke oven is one of the most important process-integrated measure for emissions control. Failure to do so leads to severe temperature fluctuations and increased chances of coke sticking during pushing. This has an adverse effect on the refractory and on the coke oven itself and may lead to increased leakage and an increase in abnormal operating conditions. A significant part of the coke oven plants emissions is caused by leakage through cracks between the heating chamber and the oven chamber and as a result of deformed doors, door frames, buck stays, etc. These emissions can be prevented, to a large extent, by a more smooth and undisturbed operation of the coke oven plant. Furthermore, this technique may significantly increase the duration of the life of the coke oven plant. Recorded images can be used to investigate and identify emissions and to clarify exactly where they came from and what was happening in the plant at the time. This analysis provides valuable information for the prevention of future abnormal incidents." 

Table 12. Changes Being Proposed for COB NESHAP Limits
                              COB Emission Source
                                Basis of Limit
                                 Leak Limits 

                                       
                                   Category
                                 Current Rule
                                 Proposed Rule
Doors
% leaking
                                coke capacity 
                                  >3M tpy 
                                    Tall[a]
                                      4.0
                                      1.5


                                       
                                  Not Tall[a]
                                      3.3
                                      1.0

% leaking
                                coke capacity 
                                  <3M tpy 
                                    Tall[a]
                                      4.0
                                      3.0


                                       
                                  Not Tall[a]
                                      3.3
                                      3.0
Lids
% leaking
                                      all
                                      all
                                      0.4
                                      0.2
Offtakes
% leaking
                                      all
                                      all
                                      2.5
                                      1.2
Charging
No. seconds VE
                                      all
                                      all
                                      12
                                      12
[a] Tall = x meters (x ft). Not tall = 


Table 13. Estimated Allowable Emissions Before and After Changes Being Proposed to the Limits For Leaking Doors, Lids, and Offtakes at Byproduct Coke Oven Facilities (COB NESHAP)
                                  Facility ID
                           Allowable Emissions (tpy)
                                       
                           With Current Leak Limits
                           With Proposed Leak Limits
                                       
                                  Doors[a,b]
                                     Lids
                                   Offtakes
                                     Total
                                   Doors[c]
                                     Lids
                                   Offtakes
                                     Total
ABC-Tarrant-AL
                                      3.4
                                     0.076
                                     0.11
                                      3.6
                                      3.0
                                     0.038
                                     0.052
                                      3.1
BLU-Birmingham-AL
                                      3.1
                                     0.079
                                     0.099
                                      3.3
                                      2.7
                                     0.039
                                     0.047
                                      2.8
CC-Follansbee-WV
                                      5.5
                                     0.12
                                     0.25
                                      5.9
                                      5.1
                                     0.059
                                     0.12
                                      5.2
CC-Middletown-OH
                                      1.8
                                     0.030
                                     0.12
                                      2.0
                                      1.7
                                     0.015
                                     0.060
                                      1.8
CC-BurnsHarbor-IN
                                      4.3
                                     0.086
                                     0.13
                                      4.5
                                      3.7
                                     0.043
                                     0.065
                                      3.8
CC-Monessen-PA
                                      1.3
                                     0.029
                                     0.092
                                      1.4
                                      1.3
                                     0.015
                                     0.044
                                      1.3
CC-Warren-OH
                                      2.0
                                     0.034
                                     0.14
                                      2.2
                                      1.9
                                     0.017
                                     0.067
                                      2.0
EES-RiverRouge-MI
                                      2.2
                                     0.045
                                     0.14
                                      2.4
                                      1.9
                                     0.022
                                     0.067
                                      2.0
USS-Clairton-PA
                                      17
                                     0.38
                                      1.1
                                      19
                                      11
                                     0.19
                                     0.53
                                      12
Total
                                      41
                                     0.88
                                      2.2
                                      44
                                      33
                                     0.44
                                      1.0
                                      34
[a] Door emissions are calculated using the revised equation.
[b] For doors, two limits apply in the current rule: 4 percent leaking doors for tall ovens (equal to or greater than 6 meters or 29 feet) and 3.3 percent leaking doors for all other shorter ovens (less than 6 meters). c For facilities with coke production capacity more than 3 million tpy coke, proposed limits from doors are 1.5 percent leaking doors for tall ovens and 1.0 percent leaking doors for all other shorter ovens; for facilities with coke production capacity less than 3 million tpy coke, proposed limits from doors is 3.0 percent leaking doors for all doors sizes.


The following methods were included in the EU BAT document[6] as examples of ways to optimize coke oven battery operation:
 Infrared measuring system of the surface temperature of the two heating coke oven walls;
 Infrared pyrometer with an integral data memory for taking manual measurements at the heating flues;
 Infrared thermal camera system that allows all abnormal events (e.g., plumes) to be recorded and a later analysis to link abnormal events with the identified causes, and also effects of defect correction (charging height and heating adjustments, charge quality modifications, cleaning operations, etc.);
 Video cameras strategically located to monitor air emissions from the coke ovens. Some can be mounted within the coke oven plant and others can be mounted at certain distances to provide an overview of the operations. The cameras transmit images to the control room operators and these images can be recorded and archived for analytical purposes;
 Automation of the coke making process;
 Computer system to calculate the amount of heat required in each battery;
 System to automatically push and charge to assist operating crews; and
System to control gas treatment plants.
However, no information was provided on the costs and potential emission reductions of these measures; therefore, these measures were not recommended for the purposes of this coke oven technology review. See Appendix E for more information regarding EU leak control practices for doors.
6.0	OTHER TECHNOLOGY REVIEW SUBJECTS NOT INCLUDED HERE

Three additional technology review subjects: battery stack opacity, fugitive emissions, and revised oven door leak equation, are not discussed in detail in this memorandum and are discussed in separate memoranda located in the docket to this rule: See Preliminary Analysis and Recommendations for Coke Oven Combustion Stacks, Technology Review for NESHAP for Coke Ovens: Pushing, Quenching, and Battery Stacks (40 CFR part 63, subpart CCCCC),[14] Fugitive Monitoring at Coke Oven Facilities (40 CFR part 63, subpart L), and Revised Equation to Estimate Coke Oven Emissions from Oven Doors. 
7.0	REFERENCES

European Union (EU), 2013. Best Available Techniques (BAT) Reference Document for Iron and Steel Production. Industrial Emissions Directive 2010/75/EU (Integrated Pollution Prevention and Control). Chapter 5 Coke Ovens. R. Remus, M. A. Aguado-Monsonet. S. Roudier, L. D. Sancho. European Commission, Joint Research Centre, Institute for Prospective Technological Studies. European IPPC Bureau, Seville, Spain. Luxembourg Publications Office of the European Union. doi:10.2791/97469. 2013. See https://ec.europa.eu/jrc/en/publication/reference-reports/best-available-techniques-bat-reference-documentforiron-and-steel-productionindustrial-emissions.
Huhn, F. Improvement of the environmental performance of coke quenching. ThyssenKrupp Uhde GmbH. Presentation at the AIST Cokemaking Committee Meeting, Pittsburgh, PA. September 18, 2013. Available at: https://ucpcdn.thyssenkrupp.com/_legacy/UCPthyssenkruppBAIS/assets.files/download_1/ coke_plant/coke_quenching_and_environment_uhde_aist_2013.pdf
Huhn, F. and F. Krebber. Technological Developments for Improvement of the Environmental Performance of Conventional Coke Plants. 6th International Congress on the Science and Technology of Ironmaking  -  ICSTI, 42nd International Meeting on Ironmaking and 13th International Symposium on Iron Ore. October 14 to 18, 2012, Rio de Janeiro, Brazil. 2012. Available at: https://ucpcdn.thyssenkrupp.com/_legacy/UCPthyssenkruppBAIS/assets.files/download_1/coke_plant/improve_environmental_performance_icsti2012_uhde_paper.pdf 
Komosiński, B., B. Bobik, T. Konieczny, and E. Cieślik. Dust emission from wet, low-emission coke quenching process. Polish Academy of Sciences, Institute of Environmental Engineering, M. Skłodowskiej-Curie 34, 41-819 Zabrze, Poland. E3S Web of Conferences 28, 01002. 2018. Available at" https://doi.org/10.1051/e3sconf/20182801002. 
Personal communication (email). D. Ailor, American Coke and Coal Chemicals Institute, Coke Ovens Environmental Task Force, to D.L. Jones, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. December 29, 2021. Retrofitting PROven on existing coke ovens.
Personal communication (email). K. Singleton, SunCoke Energy, Cincinnati OH, to D.L. Jones, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. January 13, 2022. Costs for a new heat recovery facility.
U.S. Environmental Protection Agency. Emission Factor Documentation for AP-42, Section 12.2: Coke Production. Revised Draft Version, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina. Updated July 2001.
U.S. Environmental Protection Agency. Revised Equation to Estimate Coke Oven Emissions from Oven Doors. D.L. Jones and K. McGinn, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina. August 2021. 
U.S. Environmental Protection Agency. Coke Ovens Risk and Technology Review: Data Summary. Jones, D.L., U.S. Environmental Protection Agency, Research Triangle Park, NC, and G. Raymond, RTI International, Research Triangle Park, NC. May 1, 2023. Docket ID No.'s EPA-HQ-OAR-2002-0085 (subpart CCCCC) and EPA-HQ-OAR-2003-0051 (subpart L). May 1, 2023.
U.S. Environmental Protection Agency. Maximum Achievable Control Technology Standard Calculations, Cost Impacts, and Beyond-the-Floor Cost Impacts for Coke Ovens Facilities under 40 CFR Part 63, Subpart CCCCC. D.L. Jones, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina, and G. Raymond, RTI International, Research Triangle Park, North Carolina. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. Docket ID No. EPA-HQ-OAR-2002-0085 (subpart CCCCC). May 1, 2023.
U.S. Environmental Protection Agency. Preliminary Analysis and Recommendations for Coke Oven Combustion Stacks, Technology Review for NESHAP for Coke Ovens: Pushing, Quenching, and Battery Stacks (40 CFR part 63, subpart CCCCC). J. Carpenter, U.S. Environmental Protection Agency Region IV, Atlanta, GA; K. Healy, U.S. Environmental Protection Agency, Region V; D.L. Jones, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina; and G.E. Raymond, RTI International. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. May 1, 2023.
U.S. Environmental Protection Agency. Fugitive Monitoring at Coke Oven Facilities. D.L. Jones, K. Boaggio, K. McGinn, and N. Shappley, U.S. Environmental Protection Agency, Research Triangle Park, North Carolina; and G.E. Raymond, RTI International, Research Triangle Park, North Carolina. U.S. Environmental Protection Agency, Research Triangle Park, North Carolina. Docket ID No. EPA-HQ-OAR-2003-0051). May 1, 2023.
U.S. Environmental Protection Agency. Soaking Emissions from Coke Ovens: Mountain State Carbon LLC, Follansbee, WV, Inspection June 15-16, 2021. P. Miller, U.S. Environmental Protection Agency, Region V and D. L. Jones, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. May 1, 2023.
U.S. Environmental Protection Agency. Clean Air Technology Center, RACT/BACT/LAER. Clearing House. U.S. Environmental Protection Agency, Research Triangle Park, North Carolina. See https://www.epa.gov/catc/ractbactlaer-clearinghouse-rblc-basic-information. 
U.S. Steel Mon Valley Works Clairton Plant Operations and Environmental Report. 2020. Available at: https://www.ussteel.com/documents/40705/71641/U.+S.+Steel+Clairton+Plant+2020+Report.pdf/379b7d75-09b4-6aac-8cc6-9c9ff9c81b16?t=1614861060003
 
APPENDIX A
                             COKE OVEN FACILITIES

                                 Facility Name
                                 Company Name
                            [Previous Company Name]
                                  Facility ID
                            [Previous Facility ID]
                                     City
                                     State
                         Type of Coke and Facility[1]
                     2016 Coke 114 Request Submissions[2]
                     2022 Coke 114 Request Submissions[2]
                        Typical Annual Coke Production
                                   (tons)[3]
ABC Coke
Drummond Company
ABC-Tarrant-AL
Tarrant
                                      AL
                                    Foundry
                                      No
                                    Yes (T)
                                    525,685
Bluestone Coke
Bluestone
BLU-Birmingham-AL
Birmingham
                                      AL
                                    Foundry
                                      No
                                      No
                                    348,713
Cleveland-Cliffs Follansbee Works
Cleveland-Cliffs [Mountain State Carbon, LLC]
CC-Follansbee-WV 
[AKS-Follansbee-WV]
Follansbee
                                      WV
                                    BF, ByP
                                      Yes
                                      No
                                    561,862
Cleveland-Cliffs Middletown Works
Cleveland-Cliffs 
[AK Steel Corporation]
CC-Middletown-OH 
[AKS-Middletown-OH]
Middletown
                                      OH
                                    BF, ByP
                                    Yes (T)
                                      No
                                    401,752
Cleveland-Cliffs Burns Harbor
Cleveland-Cliffs [ArcelorMittal Burns Harbor LLC]
CC-BurnsHarbor-IN 
[AM-BurnsHarbor-IN]
Burns Harbor
                                      IN
                                    BF, ByP
                                    Yes (T)
                                    Yes (T)
                                   1,888,153
Cleveland-Cliffs Monessen
Cleveland-Cliffs [ArcelorMittal Monessen LLC]
CC-Monessen-PA 
[AM-Monessen-PA]
Monessen
                                      PA
                                    BF, ByP
                                    Yes (T)
                                    Yes (T)
                                    336,022
Cleveland-Cliffs l Warren
Cleveland-Cliffs [ArcelorMittal Warren LLC]
CC-Warren-OH 
[AM-Warren-OH]
Warren
                                      OH
                                    BF, ByP
                                      Yes
                                    Yes (T)
                                    359,281
EES Coke Battery
DTE Energy Services, Inc.
EES-RiverRouge-MI
River Rouge
                                      MI
                                    BF, ByP
                                      Yes
                                    Yes (T)
                                    981,765
Indiana Harbor Coke
SunCoke Energy, Inc.
SC-EastChicago-IN
East Chicago
                                      IN
                                    BF, HNR
                                      No
                                      No
                                   1,300,000
Haverhill Coke
SunCoke Energy, Inc.
SC-FranklinFurnace-OH
Franklin Furnace
                                      OH
                                    BF, HNR
                                      Yes
                                    Yes (T)
                                    683,313
Gateway Energy and Coke
SunCoke Energy, Inc.
SC-GraniteCity-IL
Granite City
                                      IL
                                    BF, HNR
                                    Yes (T)
                                      No
                                    428,412
Middletown Coke Company
SunCoke Energy, Inc.
SC-Middletown-OH
Middletown
                                      OH
                                    BF, HNR
                                    Yes (T)
                                      No
                                    357,010
Jewell Coke and Coal
SunCoke Energy, Inc.
SC-Vansant-VA
Vansant
                                      VA
                                    BF, HNR
                                      No
                                    Yes (T)
                                    710,000
US Steel-Clairton
U.S. Steel
USS-Clairton-PA
Clairton
                                      PA
                                    BF, ByP
                                    Yes (T)
                                    Yes (T)
                                   3,776,244
Cokenergy[4]
Coke Energy
CC-EastChicago-IN
East Chicago
                                      IN
                                    BF, HNR
                                      No
                                    Yes (T)
                                   1,300,000
1 BF = blast furnace. ByP = by-product. HNR = heat and/or nonrecovery. 
2 T = Facility also performed testing as part of Coke 114 request. Other facilities that responded to Coke 114 request but did not test submitted Enclosure 1 questionnaire.
[3] Typical production as estimated by one or more of the following: (1) facilities in their Coke 114 request Enclosure 1 responses: (2) industry during the Coke 114 request review process; (3) 1998 coke production values from the NESHAP for Coke Ovens: Pushing, Quenching, and Battery Stacks  -  Background Information for Proposed Standards (EPA, 2001a); or (4) 55 percent capacity utilization of coke production design capacity from Coke 114 request Enclosure 1 responses for facilities that did not provide actual coke production values. See Section 4.1.1.3 below for details.
[4] Cokenergy operates a combined heat and power system that uses the waste heat in the flue gas from Indiana Harbor Coke Company's (IHCC) metallurgical coke facility to produce steam and electricity for the Cleveland-Cliffs Indiana Harbor integrated steel mill. Cokenergy owns and operates the 16 heat recovery steam generators (HRSG) to recover heat from the flue gas to allow for environmental treatment by the flue gas desulfurization system.
APPENDIX B
          INDIVIDUAL COMPANY RESPONSES SUBMITTED FOR WORK PRACTICES 
                           FOR MINIMIZING DOOR LEAKS
      
      
      This appendix presents the tabulated individual company non-CBI CAA section 114 responses to questions about work practices for minimizing doors leaks. 
      Table B-1. General Work Practice, Equipment, and Other Measures Used to Minimize Leaks from Doors
                                  Facility ID
             Work practice / Equipment / Other measure Description
                      Cost - Capital Purchases and Year$
                  Cost - Annual Operating 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
ABC-Tarrant-AL
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CC-BurnsHarbor-IN
Internal Written Procedures: SOPs and work practices for the inspection, adjustment, repair, replacement and cleaning of coke oven doors and jamb, as well as the use of sealants to stop and prevent leaks. 
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
CC-Monessen-PA
Job Written SOPs for the inspection, adjustment, repair, replacement and cleaning of coke oven doors and jamb, as well as the use of sealants to stop and prevent leaks. 
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
CC-Warren-OH
Internal Written Procedures: SOPs and work practices for the inspection, adjustment, repair, replacement and cleaning of coke oven doors and jamb, as well as the use of sealants to stop and prevent leaks. 
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
EES-RiverRouge-MI
Shift Battery Foreman Daily Rounds and documenting on Battery Turn Report
Negligible
<$100K
2
14
730
Manager
Varies
EES-RiverRouge-MI
Onsite Door Repair
Negligible
<$100K
Varies
Varies
Varies
Skilled Trades
Varies
EES-RiverRouge-MI
Jamb and Door Cleaning Cycle Inspection
Negligible
<$100K
2
14
730
Manager
Varies
EES-RiverRouge-MI
Pusher Operator Pre-Job Inspection
Negligible
<$100K
2
14
730
Operator
Varies
EES-RiverRouge-MI
Inspect and Clean Pusher Side Door Cleaning Blades
Negligible
<$100K
2
14
730
Operator
Varies
EES-RiverRouge-MI
Boarding of Door Machine In and Out of Service
Negligible
<$100K
2
14
730
Operator
Varies
EES-RiverRouge-MI
Inspect and Clean Door Machine Door Cleaner Blades
Negligible
<$100K
2
14
730
Operator
Varies
EES-RiverRouge-MI
Cleaning and Inspection of Chuck Doors
Negligible
<$100K
2
14
730
Operator
Varies
EES-RiverRouge-MI
Cleaning of Oven Doors and Jambs (Automatic)
Negligible
<$100K
Varies
Varies
Varies
Operator
Varies
EES-RiverRouge-MI
Door Program
Negligible
<$500K
Varies
Varies
Varies
Operator & Contractor
Varies
EES-RiverRouge-MI
Adjustment of New or Repaired Doors
Negligible
<$100K
2
14
730
Skilled Trades & Operator
Varies
EES-RiverRouge-MI
Spare Door Inspection
Negligible
<$100K
2
14
730
Operator & Manager
Varies
EES-RiverRouge-MI
Door Jamb Inspection, Repair and Replacement
Negligible
<$100K
Varies
Varies
Varies
Skilled Trades, Operator & Contractor
Varies
USS-Clairton-PA
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
                                          

                                          
Table B-2. Specific Work Practice, Equipment, and Other Measures Used to Minimize Leaks from Doors
                                  Facility ID
       Indicate if currently using, tried in past, or considered in past
                        Describe how well it works/ed; 
                        Describe why not using anymore
              Describe Measure (Work Practice/ Equipment /Other)
                         Capital Purchases and Year$;
                       Annual O&M Expenses and Year$
                               Labor (hrs/day);
                                  (hrs/week);
                                   (hrs/yr)
                                       
       Type of Labor (e.g., (technician, skilled worker, manager, etc.)
        Estimated Control Efficiency (%) of Work Practice or Equipment
1. A program for the inspection, adjustment, repair, and replacement of coke oven doors and jambs, and any other equipment for controlling emissions from coke oven doors, including a defined frequency of inspections, the method to be used to evaluate conformance with operating specifications for each type of equipment, and the method to be used to audit the effectiveness of the inspection and repair program for preventing exceedances
ABC-Tarrant-AL

Designed program works well
ABC currently uses our Work Practice Plan. In addition to these practices, ABC hired Montrose for our 3rd party 303 and Meth. 9 readings. These are done 7 days per week as well as our Environmental dept. readings completed daily by certified staff. ABC has implemented a daily work order plan for tracking problem doors and when and if they are to be repaired in place or replaced with a new door. ABC repairs doors onsite and keeps an inventory as stated in the WPP. ABC uses "smoke packers" to do "in situ" repairs and adjustments.
$27,000.00 per month (Montrose)
The other costs are incorporated into our oven budget

                                       
                                       
CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using when required in accordance with Subpart L as detailed in the Work Practice Plan
Work Practice Plan (Subpart L) not required to be implemented until the 2nd independent exceedance in any consecutive 6-month period. This plan has not been implemented in full over the last 5 years because there has not been a Subpart L exceedance.
Internal written procedures work well as shown by Method 303 results.



                                       
                                       
EES-River Rouge-MI
Currently using
Excellent, door leaks can consistently meet zero over several days & door fires have greatly reduced
Doors are on a schedule or based on actual performance moved up to be repaired. They are taken out of service and sent to an offsite contractor to repair / adjust doors according to a specification
<$100K;
$100K-$250K
<8;
<40;
<2080
subcontractor
>50%
USS-Clairton-PA
Currently using
Works well
CBI
CBI;
CBI
CBI;
CBI;
CBI
CBI
CBI
2. Procedures for identifying leaks that indicate a failure of the emissions control equipment to function properly, including a clearly defined chain of command for communicating information on leaks and procedures for corrective action
ABC-Tarrant-AL
                                       
ABC feels our designed program works well. ABC also takes into consideration any successful program can be affected by equipment failure or operator error and must deal with these inevitable failures.
ABC currently uses our Work Practice Plan. In addition to these practices, ABC hired Montrose for our 3rd party 303 and Meth. 9 readings. These are done 7days per week as well as our Environmental dept. readings completed daily by certified staff. ABC has implemented a daily work order plan for tracking problem doors and when and if they are to be repaired in place or replaced with a new door. ABC repairs doors onsite and keeps an inventory as stated in the WPP. ABC uses "smoke packers" to do "in situ" repairs and adjustments.
Work Practice and Equipment and implementation is described in WPP.
27,000.00 per month (Montrose)  The other costs are incorporated into our oven budget
                                       
                                       
                                       
CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using when required in accordance with Subpart L as detailed in the Work Practice Plan
Work Practice Plan (Subpart L) not required to be implemented until the 2nd independent exceedance in any consecutive 6-month period. This plan has not been implemented in full over the last 5 years because there has not been a Subpart L exceedance.
Internal written procedures work well as shown by Method 303 results.
                                       
                                       
                                       
                                       
                                       
EES-River Rouge-MI
Currently using
SOPs are created and trained, inspection and repair triggered by levels of emissions, documentation is submitted to Management and Environmental
Method 303 completed daily; additionally operations are empowered to identify and act to mitigate any door leaks regardless of whether they were observed during Method 303 inspection
<$100K;
<$100K
1;
7;
364
subcontractor / operators
>50%
USS-Clairton-PA
Currently using
works well
CBI
CBI;
CBI
CBI;
CBI;
CBI
CBI
CBI
3. Procedures for cleaning all sealing surfaces of each door and jamb, including identification of the equipment that will be used and a specified schedule or frequency for the cleaning of sealing surfaces
ABC-Tarrant-AL

ABC feels our designed program works well. ABC also takes into consideration any successful program can be affected by equipment failure or operator error and must deal with these inevitable failures.
PSDM and CSDM clean jambs and doors after each push on each battery.
Work Practice and Equipment and implementation is described in WPP.




CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using when required in accordance with Subpart L as detailed in the Work Practice Plan
Work Practice Plan (Subpart L) not required to be implemented until the 2nd independent exceedance in any consecutive 6-month period. This plan has not been implemented in full over the last 5 years because there has not been a Subpart L exceedance.

Internal written procedures well as shown by Method 303 results.





EES-River Rouge-MI
Currently using
SOPs are created and trained
SOPs for operations for each job type include these "specials" Operators are trained for over 6 months prior to being qualified to complete these SOPs
<$100K
<8;
<16;
<832
operators
>50%
USS-Clairton-PA
Currently using
works well
CBI
CBI;
CBI
CBI;
CBI;
CBI
CBI
CBI
4. For batteries equipped with self-sealing doors, procedures for use of supplemental gasketing and luting materials, if the owner or operator elects to use such procedures as part of the program to prevent exceedances
ABC-Tarrant-AL

ABC feels our designed program works well. ABC also takes into consideration any successful program can be affected by equipment failure or operator error and must deal with these inevitable failures.
Supplemental door seal is used on each door and smoke packer uses materials and lute if needed.
Work Practice and Equipment and implementation is described in WPP




CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using when required in accordance with Subpart L as detailed in the Work Practice Plan
Work Practice Plan (Subpart L) not required to be implemented until the 2nd independent exceedance in any consecutive 6-month period. This plan has not been implemented in full over the last 5 years because there has not been a Subpart L exceedance.

Internal written procedures work well as shown by Method 303 results.





EES-River Rouge-MI
Currently using
SOPs are created and trained, inspection and repair triggered by levels of emissions, documentation is submitted to Management
SOPs are created and trained, inspection and repair triggered by levels of emissions, documentation is submitted to Management
<$100K;
<$100K
<8;
<40;
<2080
subcontractors / operators
>50%
USS-Clairton-PA
Currently using
Works well
CBI
CBI;
CBI
CBI;
CBI;
CBI
CBI
CBI
5. For batteries equipped with hand-luted doors, procedures for luting and reluting, as necessary to prevent exceedances; procedures for maintaining an adequate inventory of the number of spare coke oven doors and jambs located onsite; and procedures for monitoring and controlling collecting main back pressure, including corrective action if pressure control problems occur
ABC-Tarrant-AL

Well
Smoke packer lutes and re-lutes doors as needed. Shift heaterman checks backpressure each shift and recorder output is watched on each battery by shift foreman. If controller fails, heaterman puts butterfly in manual and controls it manually until automatic controller is repaired.
Work Practice and Equipment and implementation is described in WPP




CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using when required in accordance with Subpart L as detailed in the Work Practice Plan
Work Practice Plan (Subpart L) not required to be implemented until the 2nd independent exceedance in any consecutive 6-month period. This plan has not been implemented in full over the last 5 years because there has not been a Subpart L exceedance.
Internal written procedures work well as shown by Method 303 results.





EES-River Rouge-MI
NA
NA
N/A
N/A
N/A
N/A
N/A
USS-Clairton-PA
Currently using
Works well
CBI
CBI;
CBI
CBI;
CBI;
CBI
CBI
CBI
6. Flexible door seals
ABC-Tarrant-AL
Yes
Flexible seals works well if seal does not get bent in replacing door
Work Practice and Equipment and implementation is described in WPP




CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Not using
N/A





EES-River Rouge-MI
Currently using
SOPs are created and trained, inspection and repair triggered by levels of emissions, documentation is submitted to Management
SOPs are created and trained, inspection and repair triggered by levels of emissions, documentation is submitted to Management
<$100K;
<$100K
<8;
<16;
<832
operators
>50%
USS-Clairton-PA
Currently using
works
CBI
CBI;
CBI
CBI;
CBI;
CBI
CBI
CBI
7. Complete overhaul of the doors; complete dismantling of all individual parts, cleaning and reassembling; readjustment of the sealing elements
ABC-Tarrant-AL

It works well - it is a totally remanufactured door.
If a door has been diagnosed by Ovens manager to need replacing. It is first taken to our door shop, dismantled and completely overhauled. If door is deemed bent, it is then hauled offsite, straightened and returned to our onsite door shop and refitted with new seal, bolts, etc..
pressure washer, presses, grinders, bolts, planers, seals and cranes.




CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using
Works well as shown by Method 303 results.





EES-River Rouge-MI
Currently using
This is part of door management program that is subcontracted
Work is subcontracted and usually per a schedule and repairs can be prioritized upon identification of repairs needed during inspection
$100K-$250K;
$100K-$250K
8;
40;
2080
operators / subcontractors
>50%
USS-Clairton-PA
Currently performing
Works well
CBI
CBI;
CBI
CBI;
CBI;
CBI
CBI
CBI
8. Replacement of damaged door bricks; complete rebricking of the door may be necessary
ABC-Tarrant-AL
As needed






CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using
Works well as shown by Method 303 results.





EES-River Rouge-MI
Currently Using
Operators inspect ovens on a planned schedule and/or if there is an identified issue
Work is subcontracted upon identification of repairs needed during inspection
$100K-$250K;
$100K-$250K
8;
40;
2080
operators / subcontractors
>50%
USS-Clairton-PA
N/A
No longer using bricks in any coke oven doors. Castable plugs are now used.
CBI
CBI
CBI;
CBI;
CBI
CBI
CBI
9. Careful cleaning of the door and its frame at each coke push
ABC-Tarrant-AL
Done each push

Cleans jambs and doors of excessive carbon to help in sealing and leakage.
CSDM and PSDM




CC-BurnsHarbor-IN
Used when equipment is available.
Works well as shown by Method 303 results





CC-Monessen-PA;
CC-Warren-OH
Currently using
Works well as shown by Method 303 results





EES-River Rouge-MI
Currently using
SOPs are created and trained
SOPs for operations for each job type include these "specials" Operators are trained for over 6 months prior to being qualified to complete these SOPs
<$100K;
<$100K
<8;
<16;
<832
Operators
>50%
USS-Clairton-PA
Currently using
Works well
CBI
CBI;

CBI;

CBI
CBI
10. Gas channels inside the doors
ABC-Tarrant-AL
N/A






CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using
Works well as shown by Method 303 results





EES-River Rouge-MI
Not in Use
N/A
N/A
N/A
N/A
N/A
N/A
USS-Clairton-PA
Currently using
Works well
CBI
CBI;

CBI;
CBI
CBI
      
APPENDIX C
          INDIVIDUAL COMPANY RESPONSES SUBMITTED FOR WORK PRACTICES 
                           FOR MINIMIZING LID LEAKS 


      This appendix presents the tabulated individual company non-CBI CAA section 114 responses to questions about work practices for minimizing leaks from lids. 
      
      
      
                                       
Table C-1. General Work Practice, Equipment, and Other Measures Used to Minimize Leaks from Lids
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                  Facility ID
             Work practice / Equipment / Other measure Description
                      Cost - Capital Purchases and Year$
                  Cost - Annual Operating 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
ABC-Tarrant-AL
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CC-BurnsHarbor-IN
Internal Written Procedure: SOPs and work practices for inspection, sealing and replacement of lids. 
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
CC-Monessen-PA
Job Written SOPs for inspection, sealing and replacement of lids. 
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
CC-Warren-OH
Internal Written Procedure: SOPs and work practices for inspection, sealing and replacement of lids. 
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
EES-RiverRouge-MI
Inspection, Cleaning, Repair and Replacement of Topside Port Lids
Negligible
<$100K
2
14
730
Operator
Varies
EES-RiverRouge-MI
Sealing and Resealing of Topside Port Lids
Negligible
<$100K
2
14
730
Operator
Varies
EES-RiverRouge-MI
Audit of Lid Inspection and Repair Program
Negligible
<$100K
2
14
730
Manager
Varies
USS-Clairton-PA
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
      
      
      
      
      
                                       
Table C-2. Specific Work Practice, Equipment, and Other Measures Used to Minimize Leaks from Lids
                                  Facility ID
       Indicate if currently using, tried in past, or considered in past
                      Describe how well it works/ worked
                        Describe why not using anymore
              Describe Measure (Work Practice/ Equipment /Other)
                         Capital Purchases and Year$;
                       Annual O&M Expenses and Year$
                               Labor (hrs/day);
                                  (hrs/week);
                                   (hrs/yr)
       Type of Labor (e.g., (technician, skilled worker, manager, etc.)
        Estimated Control Efficiency (%) of Work Practice or Equipment
1. Procedures for equipment inspection and replacement or repair of topside port lids and port lid mating and sealing surfaces, including the frequency of inspections, the method to be used to evaluate conformance with operating specifications for each type of equipment, and the method to be used to audit the effectiveness of the inspection and repair program for preventing exceedances
ABC-Tarrant-AL


Replaced and Repaired as needed. If Lid is leaking it is cleaned and reluted. Larry Car is machine involved with Lids.




CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using when required in accordance with Subpart L as detailed in the Work Practice Plan
Work Practice Plan (Subpart L) not required to be implemented until the 2nd independent exceedance in any consecutive 6-month period. This plan has not been implemented in full over the last 5 years because there has not been a Subpart L exceedance.
Internal written procedures as detailed in Question 4 work well as shown by Method 303 results.





EES-River Rouge-MI
Currently using
Operators inspect lids on a planned schedule and/or if there is an identified issue
SOPs are created and trained, inspection and repair triggered by levels of emissions, documentation is submitted to Management
<$100K;
<$100K
1;
7;
365
Operators
>50%
USS-Clairton-PA
Currently using
Works well
CBI
CBI;
CBI
CBI;
CBI;
CBI
CBI
CBI
2. Procedures for sealing topside port lids after charging, for identifying topside port lids that leak, and procedures for resealing
ABC-Tarrant-AL


Replaced and Repaired as needed.  If Lid is leaking it is cleaned and reluted.




CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using when required in accordance with Subpart L as detailed in the Work Practice Plan
Work Practice Plan (Subpart L) not required to be implemented until the 2nd independent exceedance in any consecutive 6-month period. This plan has not been implemented in full over the last 5 years because there has not been a Subpart L exceedance.
Internal written procedures as detailed in Question 4 work well as shown by Method 303 results.





EES-River Rouge-MI
Currently using
SOPs are created and trained, inspection and repair triggered by levels of emissions, documentation is submitted to Management
SOPs for operations for each job type include these "specials" Operators are trained for over 6 months prior to being qualified to complete these SOPs
<$100K;
<$100K
<8
<40
<2080
Subcontractors
>50%
USS-Clairton-PA
Currently using
Works well
CBI
CBI;
CBI
CBI
CBI
CBI
CBI
CBI
3. Using luted lids
ABC-Tarrant-AL
Yes
It either seals or doesn't. If it doesn't reseal the lid
 Larry Car is machine involved with
Lids.




CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using
Works well as shown by Method 303 results.





EES-River Rouge-MI
Currently using
SOPs are created and trained, inspection and repair triggered by levels of emissions, documentation is submitted to Management
SOPs for operations for each job type include these "specials" Operators are trained for over 6 months prior to being qualified to complete these SOPs
<$100K;
<$100K
<8
<40
<2080
Subcontractors
>50%
USS-Clairton-PA
Currently using
We manually lute lids after charging with silica based liquid material (mud) to seal lids.
CBI
CBI;
CBI
CBI
CBI
CBI
CBI
CBI
      
      
      
APPENDIX D
  INDIVIDUAL COMPANY RESPONSES SUBMITTED FOR WORK PRACTICES FOR OFFTAKE LEAKS

      This appendix presents the tabulated individual company non-CBI CAA section 114 responses to general and specific work practices for offtakes. 

      
Table D-1. General Work Practice, Equipment, and Other Measures Used to Minimize Leaks from Offtakes
                                  Facility ID
             Work practice / Equipment / Other measure Description
                      Cost - Capital Purchases and Year$
                  Cost - Annual Operating 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
ABC-Tarrant-AL
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CC-BurnsHarbor-IN
Internal Written Procedure: SOPs and work practice for the installation, sealing and replacement of offtakes, caps and standpipes; procedures for stopping/preventing leaks. 
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
CC-Monessen-PA
Job Written SOPs for installation, sealing and replacement of offtakes, caps and standpipes; procedures for stopping/preventing leaks. 
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
CC-Warren-OH
Internal Written Procedure: SOPs and work practice for the installation, sealing and replacement of offtakes, caps and standpipes; procedures for stopping/preventing leaks. 
CBI
CBI
CBI
CBI
CBI
CBI
Unknown
EES-RiverRouge-MI
Standpipe Inspection & Cleaning (Decarbonization)
Negligible
<$100K
2
14
730
Operator
Varies
EES-RiverRouge-MI
Standpipe Cap Inspection & Cleaning
Negligible
<$100K
2
14
730
Operator
Varies
EES-RiverRouge-MI
Gooseneck Inspection & Cleaning
Negligible
<$100K
2
14
730
Operator
Varies
EES-RiverRouge-MI
Damper & Main Inspection & Cleaning
Negligible
<$100K
Varies
Varies
Varies
Operator
Varies
EES-RiverRouge-MI
Oven Roof Inspection & Cleaning
Negligible
<$100K
Varies
Varies
Varies
Operator
Varies
EES-RiverRouge-MI
Charging Hole Inspection & Cleaning
Negligible
<$100K
2
2
104
Operator
Varies
EES-RiverRouge-MI
Liquor System Inspection & Cleaning
Negligible
<$100K
2
2
104
Operator
Varies
EES-RiverRouge-MI
Utilityman Offtake System Review
Negligible
<$100K
2
14
730
Operator
Varies
EES-RiverRouge-MI
Audit of Offtake System Inspection & Repair Program
Negligible
<$100K
2
2
104
Manager
Varies
EES-RiverRouge-MI
Dampering Ovens Prior to Push
Negligible
<$100K
2
14
730
Operator
Varies
USS-Clairton-PA
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
                                          
                                          

TABLE D-2. Specific Work Practice, Equipment, and Other Measures Used to Minimize Leaks from Offtakes
                                  Facility ID
       Indicate if currently using, tried in past, or considered in past
                      Describe how well it works/ worked
                        Describe why not using anymore
              Describe Measure (Work Practice/ Equipment /Other)
                         Capital Purchases and Year$;
                       Annual O&M Expenses and Year$
                               Labor (hrs/day);
                                  (hrs/week);
                                   (hrs/yr)
       Type of Labor (e.g., (technician, skilled worker, manager, etc.)
        Estimated Control Efficiency (%) of Work Practice or Equipment
1. Procedures for equipment inspection and replacement or repair of offtake system components, including the frequency of inspections, the method to be used to evaluate conformance with operating specifications for each type of equipment, and the method to be used to audit the effectiveness of the inspection and repair program for preventing exceedances
ABC-Tarrant-AL

Works well in preventing exceedances.
Standpipes & Caps are inspected by the Larry Car Operator prior to charging the oven. Cleaning will take place using high pressure water. Lid will be cleaned and stand pipe will be cleaned to maintain a 12 inch opening from the oven to the collecting main. Operator will check liquor spray, steam spray, standpipe, lid, and gooseneck. This is done before each charge. If there are problems, ABC has a work order system in place. Shift foreman puts in a work order for repairs and the repair process is started. Oven repair supervisors make visual observation daily to note possible problems and Oven Repair Dept. retains mechanics at their disposal to process and repair problems or potential problems that may arise.
                                       
                                       
                                       
                                       
CC-BurnsHarbor-IN
Currently using when required
Work Practice Plan (Subpart L) not required to be implemented until the 2nd independent exceedance in any consecutive 6-month period. This plan has not been implemented in full over the last 5 years because there has not been a Subpart L exceedance. Internal written procedures as detailed in Question 4 work well as shown by Method 303 results.




CC-Monessen-PA
Currently using when required
Work Practice Plan (Subpart L) not required to be implemented until the 2nd independent exceedance in any consecutive 6-month period. This plan has not been implemented in full over the last 5 years because there has not been a Subpart L exceedance. Various written Job SOPs work well as shown by Method 303 results.




CC-Warren-OH
Currently using when required
Work Practice Plan (Subpart L) not required to be implemented until the 2nd independent exceedance in any consecutive 6-month period. This plan has not been implemented in full over the last 5 years because there has not been a Subpart L exceedance. The measures detailed in Question 4 work well as shown by Method 303 results.




EES-River Rouge-MI
Currently using
SOPs are created and trained, inspection and repair triggered by levels of emissions, documentation is submitted to Management and Environmental
Method 303 completed daily; additionally operations are empowered to identify and act to mitigate any offtake leaks regardless of whether they were observed during Method 303 inspection
<$100K;
<$100K
1;
7;
364
Subcontractor / operators
>50%
USS-Clairton-PA
Currently using
Works well
CBI
CBI;
CBI
CBI;
CBI;
CBI
CBI
CBI
2. Procedures for identifying offtake system components that leak and procedures for sealing leaks that are detected
ABC-Tarrant-AL


Standpipes & caps are inspected by the Larry car operator prior to charging the oven. Cleaning will take place using high pressure water. Lid will be cleaned and stand pipe will be cleaned to maintain a 12 inch opening from the oven to the collecting main. Operator will check liquor spray, steam spray, standpipe, lid, and gooseneck. This is done before each charge. If there are problems, ABC has a work order system in place. Shift foreman puts in a work order for repairs and the repair process is started. Oven repair supervisors make visual observation daily to note possible problems and Oven Repair Dept. retains mechanics at their disposal to process and repair problems or potential problems that may arise.




CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using 
Using when required in accordance with Subpart L, as detailed in the Work Practice Plan




EES-River Rouge-MI
Currently using
SOPs are created and trained, inspection and repair triggered by levels of emissions, documentation is submitted to Management
SOPs for operations for each job type include these "specials" Operators are trained for over 6 months prior to being qualified to complete these SOPs
<$100K;
<$100K
1;
7;
364
subcontractor / operators
>50%
USS-Clairton-PA
Currently using
Works well
CBI
CBI;
CBI
CBI;
CBI;
CBI
CBI
CBI
3. Procedures for dampering off ovens prior to a push
ABC-Tarrant-AL


Standpipes & caps are inspected by the Larry car operator prior to charging the oven. Cleaning will take place using high pressure water. Lid will be cleaned and stand pipe will be cleaned to maintain a 12 inch opening from the oven to the collecting main. Operator will check liquor spray, steam spray, standpipe, lid, and gooseneck. This is done before each charge. If there are problems, ABC has a work order system in place. Shift foreman puts in a work order for repairs and the repair process is started. Oven repair supervisors make visual observation daily to note possible problems and Oven Repair Dept. retains mechanics at their disposal to process and repair problems or potential problems that may arise.




CC-BurnsHarbor-IN;
CC-Monessen-PA;
CC-Warren-OH
Currently using 
Work practice plan (Subpart L) not required to be implemented until the 2nd independent exceedance in any consecutive 6-month period. This plan has not been implemented in full over the last 5 years because there has not been a Subpart L exceedance. Internal written procedures/ various written job SOPs work well, as shown by Method 303 results.




EES-River Rouge-MI
Currently using
SOPs are created and trained by personnel in order to be qualified for their position, on the job training is extensive before allowing qualification
SOPs for operations for each job type Operators are trained for over 6 months prior to being qualified to complete these SOPs
<$100K;
<$100K
<8;
<40;
<2080
subcontractors
>50%
USS-Clairton-PA
Currently using
works well
CBI
CBI;
CBI
CBI;
CBI;
CBI
CBI
CBI
Note: WPP = work practice plan. OP = standard operating procedures 
                                       
APPENDIX E 
                                       
                      EU LEAK CONTROL PRACTICES FOR DOORS
                                       
      In the EU BAT document,[6] improving door seals by use of flexible door seals was cited as one BAT measure that could be used to reduce leaking doors. Emissions from flexible sealed doors were cited as a way to achieve much lower emissions than with conventional doors, where VE below 5 percent (using EPA Method 303) as a weekly average of all the coke oven doors was achievable. In the EU BAT document,[6] it was noted that VE values below 4 percent have been achieved at U.S. COB.
      
      In the EU BAT document,[6] it was also noted that periodically a complete oven overhaul should be considered for each oven every five years, on average, depending on the state of the ovens. In the EU BAT document,[6] it was stated that the overhaul entails leaving the oven empty for a week while the operations listed below are carried out. The maintenance can be performed in one time period or continuously. No fixed or minimum period of maintenance can be set. Maintenance should follow a systematic program and be carried out by specially-trained maintenance personnel. This was considered a common technique carried out by all coke operators in the EU.[6] It was stated in the EU BAT document[6] that an oven overhaul includes the following:
      
 Inspection of the oven;
 Degraphitizing of all deposits within the chamber (walls, ceiling, ascension pipes);
 Oxy-thermic welding of cracks, holes and surface damage of the refractory brickwork;
 Repair of the oven chamber floor by flooding with cement;
 Injection of dust into fine cracks;
 Complete overhaul of the doors; complete dismantling of all individual parts, cleaning and reassembling; readjustment of the sealing elements;
 Replacement of damaged door bricks; complete rebricking of the door may be necessary; and
 Use of coke oven chamber wall diagnosing-repairing apparatus.

      The costs cited in the EU BAT document[6] were converted to U.S. dollars in 2020 and resulted in cost estimates of $2.41 US$ per ton of coke produced, which translates to approximately $3M per yr per average U.S. by-product plant. In the EU BAT document,[6] it was noted that personnel costs for skilled workers carrying out the maintenance program are considerable, but that better skilled operators contribute to higher productivity and, thus, compensates for the higher hourly costs. No potential emission reductions were provided in the EU BAT document,[6] although it can assumed there would be a measurable amount but that it would vary by facility and the state of the ovens prior to the overhaul.
      

APPENDIX F
                                       
                DETAILS OF PROVEN TECHNOLOGY PROVIDED BY VENDOR
                                       
