MEMORANDUM   

DATE:		11/07/2022

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 November 4, 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 EPA Method 303 door leak observations portion of the 2022 Clean Air Act (CAA) section 114 information request for Coke Ovens.  
      
      The COETF prepared a presentation of their safety, technical, and schedule concerns with the Coke Ovens CAA section 114 information request for Method 303 door leak observations. The presentation is attached to these minutes.
      
      The following are highlights of the meeting. More detail is shown in the attached COETF presentation.
      
 Industry representatives reiterated their safety and logistical concerns from the initial August 8, 2022, meeting with EPA and that any data collected wouldn't be representative of normal coking operating since they plan to shut down the pushing equipment for safety reasons. 

 Industry representatives confirmed that Method 303 observation would be performed at Cleveland Cliffs Burns Harbor, IN, and U.S. Steel Clairton, PA. They noted that there are only 33 certified Method 303 readers in the U.S. including the private company Keramida. Inc., that has nine readers. 

 Industry representatives reported that Keramida readers were approved to perform the EPA's Method 303 door leak observations portion of the 2022 CAA section 114 information request for Coke Ovens for Burns Harbor by Indiana Department of Environmental Management (IDEM). However, industry representatives reported that the Allegheny County Health Department (ACHD) claims that their contract with Keramida prohibits Keramida from performing the study at U.S. Steel Clairton facility due to "conflict of interest." U.S. Steel is concerned about using other readers who are not familiar with the Clairton plant. Industry asked the EPA to intervene with ACHD to request that Keramida be permitted to perform the observations at the Clairton plant. 

 Industry representatives presented the safety and study procedures that would be used during the Method 303 observations. Two batteries at each facility will be observed. Cleveland Cliffs noted that there are only two batteries at the Burns Harbor facility. The door machine and pusher machine controls will be secured off the battery. There will be four Method 303 readers in two teams. Two full sets of observations will take place. The readers will start on each side of the battery, two in the yard and two in the bench. 

 Industry representatives noted that the 1981 study was conducted in August. They expressed their concerns with conducting the observations in the winder as cold weather and snow would bring steam interference. Industry requested EPA approval to conduct the observations in April/May 2023. The EPA requested that industry submit the information on the observers and their credentials with their data submissions.  
 
      The EPA thanked the industry for their comments and concerns and agreed to contact ACHD before Thanksgiving with hope that a response would be received by ACHD before the December holidays. 
      
ATTENDEES

EPA
Donna Lee Jones, EPA/OAQPS
Chuck French, EPA/OAQPS
Owen Daly, 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 

ABC Coke 
Jay Cornelius 

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

DTE - EES
Brenna Harden


                                                                    (continued)
U.S. Steel
Mike Dzurinko
Christopher Hardin
Brett Tunno

            ATTACHMENT - COETF Slides from 11/4/22 Meeting with EPA

                                       




                                       

                                       

                                       














                                       
                                       
                                       

                                       

                                       

                                       
