MEMORANDUM   

DATE:		05/19/2022

TO:	National Emission Standards for Hazardous Air Pollutants: Coke Ovens: Pushing, Quenching, and Battery Stacks Residual Risk and Technology Review; Docket ID: EPA-HQ-OAR-2002-0085

FROM:	Donna Lee Jones, U.S. EPA, Office of Air Quality Planning and Standards (OAQPS), Research Triangle Park, NC; Gabrielle Raymond, RTI International, Research Triangle Park, NC 

SUBJECT:	Conference call with Coke Industry Representatives   
--------------------------------------------------------------------------------


Summary

      A Microsoft(TM) TEAMS conference call was held on May 18, 2022, between the EPA, the Coke Oven Environmental Task Force (COETF) of the American Coke and Coal Chemicals Institute (ACCCI), SunCoke Energy Energy Partners, L.P., and coke ovens company representatives to provide a summary of the changes to the rule development plans for the residual risk and technology review (RTR) for Pushing, Quenching, and Battery Stacks (PQBS) NESHAP (40 CFR part 63, subpart CCCCC)  and subsequent upcoming draft section 114 information request for Coke Ovens. The EPA had provided a handout of summary material for discussion  during the Coke RTR status update meeting to David Ailor, COETF and Katie Batten, SunCoke, on May 16, 2022 (attached to this meeting memorandum).  
      
      The EPA began by presenting the information from the handout that included background to the rule development and an overview of the draft 2022 coke section 114 request. 
      
      Industry representatives were concerned with the EPA's filing to get an extension to the final rule deadline date to accommodate the change in rule focus. They expressed their opinion that the court order as written cannot legally allow the EPA to address any other rulemakings beyond 40 CFR part 63, subpart CCCCC (RTR) and part 63, subpart L (technology review). The EPA suggested a followup meeting between industry representatives and Office of General Council (OGC) to discuss the legality of the extension. 
      
      The EPA presented details of the draft 2022 coke section 114 request, as described in the handout, that included: stack testing of heat and non-recovery process (HNR) main stacks and heat recovery steam generator (HRSG) bypass/waste heat stacks, byproduct battery continuous opacity monitoring; a questionnaire to gather data and information on technologies and work practice standards to decrease emissions from leaks from doors, lids, offtakes, and charging; byproduct battery door leak testing; co-located coke by-product recovery (chemical) plant testing; and fenceline and interior facility fugitive monitoring. 
      
      The industry questioned who will receive the byproduct battery door leak testing request. The EPA stated that USS Clairton, PA, would be requested to do the byproduct battery door leak testing because the facility had performed the only tests done in 1981 that the EPA is attempting to verify or update, and then possibly another facility. 
      
      The SunCoke representative asked for the reasoning for the repeat testing on the HNR main stack and bypass/waste heat stack sources. The EPA explained that there was only one source test of 3-test runs each for the HNR main stack and bypass/waste heat stack received from the 2016 coke section 114. It is the EPA's best practice to request seven test runs of data to reduce limited data set issues when setting Maximum Achievable Control Technology (MACT) standards.. The EPA further cited the requirements to address unregulated pollutants emitted by this source category pursuant to the decision issued in Louisiana Envtl. Action Network v. EPA, 955 F. 3d. 1088 (D.C. Cir. 2020) ("LEAN"). SunCoke responded that the selection of facilities to conduct 2016 coke section 114 testing was negotiated between SunCoke and the EPA and they believe the testing was adequate. They further stated that the fenceline monitoring at the Haverhill facility would be redundant because there has been numerous studies done in nearby facility areas by state air quality staff. The EPA requested information about the studies so as to be able to obtain the results of the testing.
      
      Industry representative asked for clarification of interior monitoring and why it was needed. The EPA explained it will be used to refine the fugitive estimates in terms of where emissions are coming from around the facility. 
      
      Industry representatives expressed their concern with the 2022 coke section 114 and regulatory schedule that the EPA presented. They said that it did not seem to include any time for industry's review of the draft 2022 section 114 questionnaire or testing request. They questioned how they would be able to comment on the section 114 if there is not a reasonable amount of time to comment. They also expressed the difficulties with conducting testing in such a short timeframe and said that the schedule does not consider safety or the burden on industry. They further expressed concern that the schedule wouldn't include any time for industry review (i.e., quality assurance/quality control) of any test data compiled. They said that the EPA shared the draft section 114 with them in the past for the 2016 coke request and that there was a collective effort between the EPA and industry in finalizing the request which took a significant amount of time. Industry representatives indicated they want to review the draft 2022 coke section 114 request and need at least 45-60 days to review and comment . They noted that, additionally, many of their staff are currently busy with responding to the Integrated Iron and Steel. and Taconite Ore section 114 requests.
      
      The EPA thanked the industry for their comments and concerns and agreed to have a followup meeting at a later date. 
      
      
ATTENDEES
Chuck French, EPA/OAQPS
Donna Lee Jones, EPA/OAQPS
Kevin McGuinn, EPA/OAQPS
Ned Shappley, EPA/OAQPS
Gabrielle Raymond, RTI International

David Ailor, COETF/ACCCI

Jeffrey Knight, COETF counsel, Pillsbury Winthrop Shaw Pittman, LLP

Cleveland Cliffs (previously AK Steel and ArcelorMittal USA)
Rich Zavoda
Katie Kistler
Julianne Kurdila
Mike Long
Rob Beranek

ABC Coke 
Jay Cornelius 
Abby Dolby

DTE - EES
Brenna Harden

SunCoke
Katie Batten
Kris Singleton
Aron S.

U.S. Steel
Christopher Hardin
David Hacker
Brett Tunno
Mike Dzurinko
Jonelle Sheetz

Ted Palma, COETF consultant



                      Coke Ovens RTR: Section 114 Request
                      Informational Briefing for Industry

Purpose: To provide a summary of the changes to rule development plans for the Coke Ovens RTR and subsequent upcoming draft section 114 information request for Coke Ovens.  

BACKGROUND:
    Coke oven HAP emissions are addressed in two Clean Air Act (CAA) section 112 NESHAP:  subpart CCCCC (5C) for "Pushing, Quenching, and Battery Stacks (PQBS)" and subpart L "Coke Oven Batteries."
        Subpart 5C (promulgated in 2003): addresses emissions from pushing coke out of ovens, quenching hot coke, and battery stacks of oven combustion. 
        Subpart L (promulgated in 1993): addresses leaks from oven doors, lids, "offtake" ducts, and charging, and includes two groups of facilities based on the CAA: MACT track and Lowest Achievable Emissions Rate (LAER) track.
       In addition, there are co-located coke by-product recovery (chemical) plants (CBRPs) at by-product recovery facilities that are regulated under older 40 CFR part 61 NESHAP (the main rule, 61 subpart L, was promulgated in 1989) that requires facilities to duct emissions of certain CBRP process units and to implement a leak detection and repair (LDAR) program. The CBRPs are not listed or regulated under CAA section 112 because they were delisted from section 112 in 2001.
    In 2016, we sent a section 114 test request to 7 facilities to obtain hazardous air pollutants (HAP) emission data. 
        Data were obtained for pushing (6 facilities), quenching (1 facility), battery stacks (7 facilities), HNR charging (1 facility), HRSG main stacks and HRSG bypass/waste heat stacks (1 facility). 
        HAP emissions from the subpart 5C sources include: acid gases (HCl and HF), dioxin/furans (D/F), HAP metals, hydrogen cyanide (HCN), PAHs, volatile organic HAP (VOHAP), and formaldehyde.
    EPA currently has a court ordered deadline of December 26, 2022 to complete the risk and technology review (RTR) for subpart 5C and technology review for subpart L.
    During development of the RTR proposed rule during 2021-22, EPA work group members recommended that we consider fenceline monitoring to gain a better understanding of fugitive emissions. People also expressed the need for: more emissions test data for some subpart 5C sources, more data and information regarding oven door leaks, and more data and information regarding co-located CBRPs. With these additional data, EPA could develop a more robust and comprehensive sector-based rule. Our management agreed that we should pursue this path.
    We subsequently discussed this concept with the deadline litigants (Earthjustice) but also explained that in order to get such data and information we would need a significant extension to the deadline.  
    The litigants were supportive of this idea. Therefore, we are currently developing a section 114 request to gather additional data and we expect to receive an extension for the Coke Oven RTR final rule to Spring 2024.
    Our current plan is that the comprehensive sector-based rule will include a risk assessment for 40 CFR part 63, subpart L sources and MACT limits for 40 CFR part 61, subpart L sources under CAA section 112.
    This briefing document provides a summary of our draft section 114 request that we plan to send to companies by early June 2022.
   

OVERVIEW OF THE DRAFT SECTION 114 REQUEST, FIVE MAIN PARTS:
     For subpart 5C, we only have test data from 1 of the 5 HNR facilities for each of two emissions sources (i.e., one HRSG by-pass/waste heat stack and one HRSG main stack), which are currently unregulated. Therefore, we plan to require testing of these 2 emission sources at two additional HNR facilities for several organic HAPs (including D/F and PAHs), metal HAPs, HCl, HF and other pollutants, as shown in Table 1 below. We also plan to request battery continuous opacity monitoring (COMs) data and information regarding existing COMS-driven battery O&M work practices from by-product facilities, as described in detail below (bottom of page 4). 
     For subpart L under part 63, we lack data on technologies and work practices to reduce emissions from leaks from doors, lids, offtakes, and emissions from charging, and the costs and effectiveness of those technologies. Therefore, we plan to send a questionnaire/survey to gather data and information on this topic.
     Regarding door leak (fugitive) emissions, these emissions previously were estimated using an equation (from AP-42) based on a 1981 study. We are planning to require at least one facility to repeat this study, which will help us better quantify such emissions and update the equation. These door leak emissions were a main risk driver in our preliminary risk analysis as they were in the 2005 RTR. Details are discussed below in the expanded summary section and in the appendix.
     Regarding co-located CBRPs, there are significant uncertainties about the emissions and work practices performed for these sources. We plan to include an extensive questionnaire/survey to gather data on processes, control measures, and work practices for these chemical plants. We also plan to require stack testing for organic HAP and sulfuric pollutants at 6 by-product chemical plants for three units that have measurable exhaust points, as described in Table 1 below. 
     We also plan to request fenceline and interior facility monitoring.

EXPANDED SUMMARY OF THE DRAFT COKE OVENS SECTION 114 REQUEST
A. Source Tests

Table 1 below presents our current plans for the source test portion of the section 114 request, including the sources and specified HAP to be tested. 

Table 1 - Summary of Required Emissions Testing for Coke Oven Plants by Emission Process Unit
                             Emission Process Unit
                     Number of Facilities & Companies
                             Pollutant(s) to Test
           Part 63 subpart L:  Coke Ovens at By-product Plants Only
Doors, Bench and Yard
                                1-2 facilities
                                 1-2 companies
Visible emissions (leaks) to repeat the 1981 study that established the current AP-42 equation for estimating coke oven emissions (COE). Equation details described in the appendix.
                                                                    (continued)
                                                                               
                                                                               
                                                                               
  Part 61 subpart: Coke Ovens Chemical By-product Recovery Plants (CBRP) Only
Cooling Tower Inlet 
                                 6 facilities 
                                 (4 companies)
                                       
Volatile organic HAP (VOHAP): as benzene, ethyl benzene, toluene, and xylenes (BTEX), speciated; hydrogen sulfide (H2S), carbonyl sulfide (COS), carbon disulfide (CS2)
Light Oil Condenser 

VOHAP: as BTEX; H2S, COS, CS2

Sulfur Recovery/ Desulfurization Combustion Unit 

Sulfur dioxide (SO2)
H2S, COS, CS2
         Part 63 subpart 5C: Heat and Non-Recovery Process (HNR) Only
(1) HNR Main Stack after Heat Recovery Steam Generators (HRSG);  and
(2) HNR Bypass Stacks and HNR Waste Heat Stacks
                                 2 facilities,
                                   1 company
Toluene-soluble organics (TSO)
Filterable PM & HAP Metals 
PM2.5 filterable & condensable
CO2, CO, SO2
HCl, HF, HCN, PAHs and D/F
Opacity (stack)
VOHAP: as BTEX, and formaldehyde
Baghouse dust

Mercury
               Part 63, Subparts L and 5C, and Part 61 Subpart L
             Testing at Facility Fenceline & Interior Facility
Fugitives emissions at fenceline, and at interior facility locations near (1) the coke oven batteries and (2) the CBRP
6 Coke Oven By-Product facilities; and
1-2 HNR facilities (no interior CBRP test)
VOHAP: as BTEX, and 1,3 Butadiene
PAH and volatile organic compounds (VOC)

 We plan to require 7 test runs for the HAP pollutants (for which we may need to calculate MACT floor limits) and 3 test runs for the other pollutants (PM2.5, CO2, SO2), along with minimum test volumes. All the above items are specified to ensure good quality data.
 Process data will be requested for the duration of the testing, such as rate of coke production, type of coal charged during testing, and average coking time per oven(s) tested (hours).
 Physical data for stack and fugitive sources will be requested, such as stack height and diameter, fugitive source dimensions (LxWxH), location (latitude/longitude), gas temperature, and gas velocity dimensions of source (batteries, HRSG) for any sources for which we don't already have these data.
                                       

B. Door Leak Tests

In the testing to verify the door leak emissions equation, the selected facility will assess coke oven door leaks according to U.S. EPA Method 303 from both the yard and the bench. Two teams of two observers would be used. Each team would traverse the same side of the battery simultaneously, one team member at the bench and one at the yard. Team members would then switch position and re-traverse the battery to complete a set of observations. Four sets of observations (2 traverses, one for each team on 2 sides) will be performed at three different batteries. This procedure was used in 1981 to develop the original equation.

An example of the door leak test protocol is shown in Table 2, below, for a hypothetical battery "XYZ". A similar scheme will be requested for two more batteries for a total of three batteries. Abbreviations are as follows: O1 is Observer 1, O2 is Observer 2, etc.

More information regarding development of the original door leak equation and our current draft revision to the equation is provided in the appendix.

Table 2. Door Leak Testing Sequence at One Battery (XYZ)
Traverse No.
Battery XYZ  -  Coke Side
Battery XYZ  -  Coal Side

Bench
Yard
Bench
Yard
1A
O1, O2
O3, O4
O1, O2
O3, O4
1B
O3, O4
O1, O2
O3, O4
O1, O2
2A
O1, O3
O2, O4
O1, O3
O2, O4
2B
O2, O4
O1, O3
O2, O4
O1, O3
3A
O1, O2
O3, O4
O1, O2
O3, O4
3B
O3, O4
O1, O2
O3, O4
O1, O2
4A
O1, O3
O2, O4
O1, O3
O2, O4
4B
O2, O4
O1, O3
O2, O4
O1, O3


C. Questionnaire

The Coke Oven section 114 request questionnaire will be divided into four sections, as follows:

     Basic Company Information: Includes verification/update of data submitted in 2016, and new submittal of information for facilities that did not receive the 2016 section 114 request.

     Coke By-Product Recovery Plants: This section of the questionnaire will request detailed process unit descriptions, facility schematics, emissions calculations, applicable state and local regulations, methods of compliance with 40 CFR part 61, subpart L, and explanation and costs of work practices used or tried in the past to minimize emissions.
    
     Coke Oven Doors, Lids, Offtakes, and Charging at By-product Coke Oven Facilities: This section of the questionnaire will request details of the techniques used to minimize leaks and charging emissions, the emissions reductions and costs of these techniques that may include maintenance and other work practices, technology upgrades, and any other emission reduction techniques.
    
     Battery stacks: We plan to request 5 years of hourly COMS data along with the techniques used by the facility to explore the usefulness of these data to identify leaking or otherwise compromised coke ovens. We also plan to request two weeks of 1-minute COMs data along with oven charging and pushing schedules for correlative analyses. We plan to ask for descriptions of existing work practices for oven integrity and battery stack O&M.

We plan to send the questionnaire to five companies, covering a total of six operating by-product coke oven facilities, and two HNR facilities (that did not complete the 2016 114 request).

NEXT STEPS AND ANTICIPATED SCHEDULE
Milestones
                                     Dates
Presentation and meeting with industry
May 18, 2022
Comments and feedback from industry due
May 25, 2022
Brief SPPD Director regarding stakeholder input and comments
May 27, 2022
Complete revised Section 114 request based on input by stakeholders
May 30, 2022
Final section 114 request to SPPD DD for signature
May 30, 2022
EPA sends section 114 request to industry
June 2, 2022
Industry submits responses to enclosure 1 (survey)
July 15, 2022
Industry submits responses to enclosure 2 (testing results)
October 26, 2022
Industry submits 3-months of fenceline and interior monitoring data
November 26, 2022
Industry submits 6-months of fenceline and interior monitoring data
February 2023
Proposed Rule signature
July 2023
Final Rule signature
May 2024



                                    APPENDIX
  Inform or Confirm the Development of a Revised Coke Oven Door Leak Equation
                                       
INTRODUCTION

The 1993 NESHAP (subpart L) set maximum achievable control technology (MACT) standards for leaks of coke oven emissions (COE) from oven doors, lids, and offtakes, and other coke oven sources. COE are a separately-listed HAP consisting of approximately 71 chemicals, including volatile, semi-volatile organic HAP, and PM HAP. 
      For the by-product coke plants, MACT limits for subpart L sources were set based on the percent of oven doors, offtake gas ducts and oven charging lids that leak visible emissions, as measured using EPA Method 303. Because nonrecovery coke ovens operate under negative pressure, there are zero leaks from their doors, lids, and offtakes. Emissions of COE leaks from by-product coke ovens have historically been estimated using AP-42 emission factor equations that include the number of leaking doors, lids, and offtakes, and the seconds of visible emissions measured with EPA Method 303. 

This appendix discusses a revised equation to estimate emissions from oven doors that we think better reflects the technological improvements in today's coke industry.
BACKGROUND
In 2005, the EPA promulgated the residual risk and technology review (RTR) for subpart L (72 FR 19992). In the RTR for subpart L, COE from leaking oven doors, were estimated using the following equation taken from the estimating procedures in AP-42. The nonvisible emissions in the AP-42 equation were considered to be zero in the RTR but were acknowledged to contribute to the uncertainty in the estimates, where actual emissions were stated as potentially higher than estimated with an acknowledgment that they also could be lower (70 FR 20007).
      
COE-doors (lb/hr) = ND x (PLDyard/100) x (0.04 lb/hr) + ND x (PLDbench/100) x (0.023 lb/hr)
                                       
where:
ND		=	number of doors
PLD		=	percent leaking doors
bench		=	walking platform running next to the ovens (and doors)
yard		=	50 to 100 feet from the oven doors
PLDyard  	=	percent of doors with visible leaks visible from the yard 
PLDbench	=	percent of doors with visible leaks only visible from the bench, assumed to be 6%.  
Because of safety concerns, actual observations are not typically taken from bench and, therefore, this equation has historically included a default value of 6% for leaking doors visible only from the bench, as shown below:

COE-doors (lb/hr) = ND x (PLDyard/100) x (0.04 lb/hr) + ND x (6%/100) x (0.023 lb/hr)
 
All emissions estimates used in the initial draft 2021 RTR baseline risk assessment were based on application of the 6% default value for bench-only leaks from doors.

RE-ASSESSMENT OF DEFAULT DOOR LEAKS VISIBLE ONLY FROM BENCH

      The value of 6% leaking doors visible only from the bench originates from the July 2008 update to AP-42, where data from 1981 was used as the basis for the 6% value, as described in the 2008 AP-42 background document. In this document, it is stated that the data used to develop the 6% leaking doors that are visible only from the bench were derived from measurements where the percent leaking doors from the yard was 6.4% and the total percent leaking doors visible from the bench was 12.4%, which includes both leaks visible from the yard and leaks visible only from the bench.[4] The difference between 12.4% and 6.4%, at 6%, was taken to represent the percent leaking doors visible only from the bench. The data used to support these estimates are explained in the AP-42 background document,[6] as follows:

      "In August 1981, EPA conducted bench and yard observations of door leaks at the US Steel Clairton Works (Batteries 7, 8, and 9). The program was designed to obtain accurate data and to minimize the bias created by process and observer variance. There were four observers divided into two teams. Each team traversed the same side of the battery simultaneously, one from the bench and one from the yard. At the end of the traverse, the teams switched positions and conducted another traverse. Two traverses of the same side of the battery conducted in this manner are considered a set. A total of 25 sets of observations were made, and in all cases, more leaks were observed from the bench than from the yard. The average was 6.4 PLD from the yard and 12.4 PLD from the bench, which gives an average difference of 6 PLD. The difference ranged from 0.8 PLD to 14.5 PLD."
      
The 6% leaking doors visible only from the bench were presented as an absolute value and not set in relation to the percent leaking doors from the yard, which is the only measured value related to door emissions. Support for a revised equation can be found in the response to comments included in the July 2008 background document, where the EPA stated: "It is not clear that the difference should be a constant rather than a ratio, i.e., the difference between yard and bench leaks may change as the total number of leaks decreases."

      In the current coke industry, the percent leaking doors measured from the yard are now much lower, at 2.5% or less, based on 2016 source tests performed for an EPA information collection request. The facility that was used to establish the 6% leaking doors visible only from the bench in 1981 was U.S. Steel Clairton-PA, which had 6.4% leaking doors visible from the yard in 1981, but now has a facility average of 0.5% leaking doors visible from the yard. Therefore, we believe the default fixed value of 6% leaking doors visible only from the bench should be reevaluated so that the total emissions from doors are not over estimated and are in relation to the measured percent leaking doors from the yard and not a fixed value. 
      
      We are suggesting that a bench-to-yard "adjustment ratio" be used instead of the 6% fixed value for bench-only visible door emissions. The adjustment ratio would be based on the historic values measured in 1981, as the ratio of the percent leaking doors visible from the bench[4] to the percent leaking doors visible from the yard. This adjustment ratio would be used with the measured percent leaking doors from the yard (with EPA Method 303) to estimate percent leaking doors visible only from the bench. The ratio of bench-only visible emissions to yard emissions from 1981 is ((12.4-6.4)/6.4), equal to 6.0/6.4 or 0.94. This adjustment ratio (0.94) would be multiplied by data for percent leaking doors measured from the yard to estimate the bench-only component of door emissions in the equation for COE for doors from above, and shown below with the adjustment factor:
      
COE-doors (lb/hr) = ND x (PLDyard/100) x (0.04 lb/hr) + 
                                    ND x ((PLDyard x 0.94PLDbench/PLDyard)/100) x (0.023 lb/hr)

where:
ND	=	number of doors
PLD	=	percent leaking doors
yard	=	50 to 100 feet from the oven doors
bench	=	walking platform running next to the ovens (and doors)
0.94	=	ratio of PLDbench to PLDyard

      In this revised equation, the percent leaking doors visible only from the bench is still represented by the second term, which is now set equal to PLDyard. x 0.94.

COE-doors (lb/hr) = ND x (PLDyard/100) x (0.04 lb/hr) + ND x ((PLDyard x 0.94)/100) x (0.023 lb/hr)

CONCLUSION

      This revised equation is expected to provide more accurate estimates of total COE from doors that reflects advancements in preventing and reducing door leaks that have occurred since 1981. The term used to estimate unmeasured leaking doors visible only from the bench in the revised equation above still incorporates the historic measurements but also includes measured values at the facility. However, it would be helpful get additional data to inform the further development of the revised equation. Therefore, we are planning to require at least one coke facility to repeat this study in 2022, which will help us better quantify these emissions and update the equation. 

