MEMORANDUM   

DATE:		08/12/2022

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   
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Summary

      A Microsoft(TM) TEAMS conference call was held on August 9, 2022, between the EPA, the Coke Oven Environmental Task Force (COETF) of the American Coke and Coal Chemicals Institute (ACCCI), and coke ovens company representatives to discuss the 2022 section 114 information request for Coke Ovens.  
      
      The COETF with the support of Trinity Consultants, prepared a presentation of their safety, technical, and schedule concerns with the section 114 information request for Coke Ovens. The presentation is attached to these minutes.
      
      The following are highlights of the meeting. More detail is shown in the attached COETF presentation.
      
Flare Testing 
	Industry representatives explained the safety concerns with the proximity of the flare flame to the top of the battery (heat due to proximity to battery). They went further to explain that testing the flare per the section 114 Enclosure 2 requirements would not be representative of flare operations (which are highly variable and unpredictable).

Door Leak Observations
      Industry representatives explained the safety concerns with taking observations on the bench side of the battery (heat, proximity to battery, and moving pushing equipment) and that observations on the bench side would not be representative of normal operations since facilities would have to alter their pushing schedule for safety reasons. They explained that all the facilities required to do the Method 303 testing have tall batteries that would have an obstructed view of the door. Additionally, they expressed their concern with the availability of certified Method 303 observers, of which they said there are only 33 in the U.S. The COETF recommended these testing requirements be removed from the section 114 request. The COETF also added that they did not see how they could safely obtain data to update the 1981 study data, but suggested there could be other analyses of the 1981 data that could be conducted, but did not explain further. 

Fugitive Interior Monitoring
	Industry representatives stated that the location of sources would make it difficult to distinguish between coke by-product recovery plant (CBRP) sources and coke oven battery sources of emissions for locating fugitive interior monitors. They expressed that existing Method 21 leak detection and repair (LDAR) data could be used in lieu of interior facility monitoring. The EPA questioned if the data would be speciated or would it be a combined volatile organic compounds (VOC value). They responded that the 40 CFR part 61 subpart L and V require VOC but said they would investigate the possibility of speciating the VOC and get back to the EPA. The COETF recommended this testing be removed from the section 114 request.

Fugitive Fenceline Monitoring
	Industry representatives noted that there are no accredited laboratories for performing Method TO-15A. The EPA clarified that they would allow Method TO-15 in this situation. Industry representatives continued with their concerns with the number of monitors required for Method 325A&B and suggested that existing ambient air quality monitoring data could be used in lieu of fenceline monitoring. The EPA asked if upwind and downwind data would be available in conjunction with ambient air quality monitoring data to determine facility impacts. Industry representatives responded that they would have to investigate it. The COETF recommended this testing be removed from the section 114 request.

CBRP Testing  -  Cooling Towers
	Industry representatives explained that they do not expect any VOC emissions from the CBRP cooling systems because they are closed loop recirculation systems using non-contact cooling water in the heat exchange process. The EPA clarified that there is a potential for leaks that would contaminate the water. Industry representative continued with their concerns with using the Texas Commission on Environmental Quality (TCEQ) method because it is not an approved EPA method. The EPA clarified that the TCEQ method has been incorporated by reference for four NESHAP rulemakings (40 CFR part 63, subparts CC, XX, FFFF, and HHHHHHH). Industry said that any VOCs that could be present would have boiling points above 140ºF. The EPA clarified that the TCEQ method (along with a TO-15 finish) has provisions for boiling points above 140ºF. Industry representatives proposed that existing available data could be used instead of new testing. The EPA said that existing data would be useful to provide. The COETF recommended this testing be removed from the section 114 request. 

Previous Test Reports
	Some industry representatives asked if EPA would allow previous test reports in lieu of testing. U.S. Steel said that they believe they have tests of their sulfur recovery unit (SCOT). The EPA specified that the previous tests can be submitted if they are within the last 5 years.

Schedule
	Industry representatives requested that more time be built into the schedule for Enclosure 1 survey responses and Enclosure 2 testing. They noted that the next submittal deadline is 8/13/2022 (Saturday) for the fenceline monitoring plan. The EPA agreed that this could be extended to Monday 8/15/2022. Industry provided a table with their suggested changes to the timetable (previously submitted with their 8/2/2022 COETF Concerns Regarding EPA's June 28, 2022 Coke Ovens Section 114 Information Collection Requests (ICRs) letter), which basically doubled all response time periods. Table 1 shows these requested changes to the schedule.
         
      The EPA thanked the industry for their comments and concerns and agreed to provide responses in a timely manner. 
      
        Table 1. COETF suggested changes to Coke section 114 timeline.
                                   ICR Task
                             Time Provided In ICRs
                                 Time Request
Submit Enclosure 1 Responses
                                    65 days
                                   120 days
Submit Fugitive (monitoring plan, test plan,& QAPP)
                                    45 days
                                    90 days
Submit Schedule(s) for Stack Testing
                                    85 days
                                   180 days
Begin Fugitive Monitoring
                               40 days from plan
                                   approval
                               90 days from plan
                                   approval*
First 3 months of Fugitive Monitoring Data
                              140 days from plan
                                   approval
                           60 days after monitoring
                                     ends
Second 3 months of Fugitive Monitoring Data
                              230 days from plan
                                   approval
                           60 days after monitoring
                                     ends*
Submit Stack Test Reports & Data
Spreadsheets
                                   154 days
                              Submit report &
                           spreadsheet 60 days after
                                test completed
* Trinity's recommendation is that fugitive monitoring requirements be removed from the ICR. The
schedule shown above is for informational purposes to reflect the minimum time that would be needed to
complete the requirements of EPA's current proposal.

                                       
                                       
ATTENDEES

EPA
Owen Daly, EPA/OAQPS
Chuck French, EPA/OAQPS
Steve Fruh, EPA/OAQPS
Donna Lee Jones, EPA/OAQPS
Walter Lin, EPA/OAQPS
Kevin McGinn, EPA/OAQPS
Ned Shappley, EPA/OAQPS
Gabrielle Raymond, RTI International

COETF
David Ailor, President, ACCCI
Jeffrey Knight, COETF counsel, Pillsbury Winthrop Shaw Pittman, LLP
Ted Palma, COETF consultant

Trinity Consultants, COETF consultant 
Ian Donaldson 
Ron Hawks
George Mesing
Christi Wilson

ABC Coke 
Blake Andrews
Jay Cornelius 
Abby Dolby
John Steward

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

DTE - EES
Brenna Harden

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

            ATTACHMENT - COETF Slides from 8/9/22 Meeting with EPA

                                       




                                       

                                       

                                       
                                       














                                       
                                       
                                       

                                       

                                       

                                       










