­­
!
l;
4CHM
tt­"
DUKHAMI
NC
Docket
No.
A­
79­
15
Item
No.
XII­
C­
8
@\
T@
ST498
2
3
UNITED
STATES
ENVfRONMENTAL
PROTECTION
AGENCY
RESEARCH
TRIANGLE
PARK.
NC
27711
OFFICE
Of
SEP
2
5
2001
AIR
QUALITY
PLANNING
AND
STANOARW
Mr.
David
C.
Ailor
American.
Coke
and
Goal
Cheniicsils
Institute
1255
Twmiy­
third
St.,
N.
W.
i
Washington,
D.
C.
20037
i
Dear
Dave:

Ai3
a
follow­
up
to
ourtelecon
of
September
24*,
I
amforwarding
the
documentation
of
the
emission
estimates
for
the
coke
ovens
risk
analysis
and
a
table
that
indicates
the
percent
complimce
with
LAER
hits
for
h4ACT
track
batteries.
Please
contact
meat
919­
541­
2910,
if
you
have
any
questions
regarding
this
idormation.

Sincerely,

Lula
13.
Melton
Emission
Standards
Division
Enclosures
m
E
E
=
i
c4
W
c
c;
l
M
3
P
0
0
I+

0e
r
I
lo
i
Docket
No.
A­
79­
15
Item
No.
XII­
C­
8
Attachment
1
of
2
DOCUMENTATION
OF
THE
EMISSION
ESTIMATES
FOR
THE
COKE
OVENS
RISK
ANALYSIS
September
12,2001
DOCUMENTATION
OF
THE
EMISSION
ESTIMATES
FOR
THE
COKE
OVENS
RISK
ANALYSIS
1.
Purpose
and
Approach
The
purpose
of
this
technical
note
is
to
document
how
the
emissions
were
estimated
for
the
coke
ovens
risk
analysis.
This
documentation
includes
a
description
of
the
estimating
procedures,
example
calculations,
the
results
for
each
battery
and
emission
point,
and
references.

The
approach
for
estimating
emissions
from
the
coking
process
(
starting
with
charging
coal
to
the
oven
and
ending
when
the
coke
is
quenched)
is
based
on
using
extractable
organic
emissions
as
a
surrogate
for
coke
oven
emissions.
Data
are
available
for
benzene
soluble
organics
(
BSO)
and
methylene
chloride
soluble
organics
(
MCSO).
Estimates
for
individual
compounds
in
the
coke
oven
emissions
are
derived
from
the
ratio
of
the
compound
to
the
BSO
or
MCSO.
Benzene
is
the
primary
pollutant
of
concern
in
emissions
from
the
by­
product
recovery
plant.
Estimates
for
other
hazardous
air
pollutants
(
toluene
and
xylene)
are
based
on
their
typical
ratio
to
benzene.

2.
BSO
from
Charging,
Doors,
Lids,
and
Offtakes
The
estimates
for
charging,
doors,
lids,
and
offtakes
are
based
on
battery­
specific
data
for
the
number
of
doors,
lids,
and
offtakes
on
each
battery
and
the
number
of
charges
per
year.
The
battery
characteristics
are
given
in
Table
1
and
were
obtained
from
an
EPA
survey
of
the
industry 
and
from
an
EPA
report
that
assessed
control
performance
for
these
emission
points. 

Estimates
are
provided
for
two
cases:
one
based
on
data
from
Method
303
inspections
(
actual
visible
emissions)
summarized
in
Table
2
and
another
based
on
emission
limits
(
allowable
emissions)
given
in
Table
3.
The
Method
303
data
were
obtained
from
Reference
2
and
supplemented
by
more
recent
data
provided
by
two
of
the
The
estimating
procedures
are
from
the
revised
draft
of
AP­
42:
and
relevant
excerpts
are
given
in
Appendix
A.
BSO
emissions
from
door
leaks
are
based
on
an
emission
rate
of
0.04
lbhr
per
leak
for
leaks
visible
from
the
yard
(
as
determined
by
EPA
Method
303)
and
0.023
lbhr
for
leaks
visible
only
from
the
bench
(
estimated
as
6
percent
of
the
doors).
The
observations
from
the
yard
as
specified
in
Method
303
are
made
roughly
50
to
100feet
from
the
doors.
EPA
I
studies
have
found
that
when
observationsare
made
from
the
bench
just
inches
from
the
doors,

more
leaks
are
observed.
One
study
found
that
an
additional
6
percent
of
the
doors
were
found
to
be
leaking
when
observed
from
the
bench.
6
In
addition,
the
coke
oven
NESHAP
(
40
CFR
Part
63,
Subpart
L)
allows
6
percent
of
the
door
leaks
to
be
subtracted
when
they
are
observed
from
the
bench
under
a
cokeside
shed
to
put
them
on
a
basis
similar
to
Method
303
yard
observations.

Lid
and
offtake
leaks
are
based
on
0.0075
Ib
BSOh
per
leak
as
presented
in
the
draft
revisions
to
AP­
42.5
Charging
emissions
are
based
on
0.0093
lb
BSO
for
each
10
seconds
of
emission^.^

Results
based
on
Method
303
are
given
in
Table
4
and
those
based
on
emission
limits
are
given
in
Table
5.
Example
calculationsare
given
below.

ExamDle
calculationfor
AK
Ashland
Batterv
3
based
on
Method
303
data:

Charging:
(
3.74
skharge)
*
(
34,675
charges&)
*
(
0.0093
lb/
10
seconds)
=
121
Ib/
yr
=

0.06
tpy
BSO
Doors:
(
152
doors)
*
(
2.43
percent
leaking)/
lOO*
(
0.04
Ib/
hr)
+
(
152
doors)
*
(
6
percent
leaking)/
100*
(
0.023
Ibh)
=
0.36
Ib/
hr
=
1.6
tpy
BSO
Lids:
(
228
lids)
*
(
0.13
percent
leaking)/
100
*
(
0.0075
Ib/
hr)
=
0.0022
Ibhr
=

0.01
tpy
BSO
Offtakes:
(
76
offtakes)
*
(
0.82
percent
leaking)/
100
*
(
0.0075
Ibh)
=
0.0047
Ibh
=

0.02
tpy
BSO
TABLE
4.
BSO
ESTIMATES
BASED
ON
METHOD
303
II
II
ITONS
PER
YEAR
OF
BENZENE
SOLUBLE
ORGANICS
(
BSO)
I
ID
BASED
ON
METHOD
303
INSPECTIONS
(
ACTUAL)
PLANT
DOORS
I
LIDS
IOFFTAKES
I
CHARGING
I
TOTAL
AKSteel,
Ashland,
KY
3
'
TABLE
5.
BSO
ESTIMATES
BASED
ON
EMISSION
LIMITS
3.
Emissionsfrom
Pushing,
Quenching,
and
Battery
Stacks
The
procedure
for
estimating
MCSO
emissions
is
described
in
"
NationalEmission
Standardsfor
Hazardous
Air
Pollutants
(
NESHAP)
for
Coke
Ovens:
Pushing,
Quenching,
and
Battery
Staclzs­
Background
Informationfor
Proposed
Standards.''
I
The
relevant
excerpt
is
given
in
Applendix
B.
The
estimates
from
this
document
are
based
on
the
emissions
expected
after
the
standards
for
pushing,
quenching,
and
battery
stacks
are
implemented.
The
estimates
for
pushing
and
battery
stacks
are
derived
from
two
EPA
tests,
one
at
a
battery
producing
foundry
coke?
and
one
at
a
battery
producing
blast
furnace
coke?
Emissions
from
quench
towers
are
based
on
a
1977
EPA
test."

The
emission
factors
are
a
function
of
the
tons
of
coke
produced
or
the
tons
of
coal
charged.
Sitespecific
information
on
tons
of
coal
charged
and
tons
of
coke
produced
were
obtained
from
an
EPA
survey'
of
the
industry
and
from
data
compiled
from
a
survey
conducted
by
ICF
Consulting."

3.1
Fugitive
Pushing
Emissions
MCSO
fugitive
emissions
from
pushing
are
estimated
as
0.0116lb/
ton
coke
produced
for
plants
with
control
devices
and
0.018
Ib/
ton
coke
produced
for
batteries
without
control
devices.

As
discussedl
in
Appendix
B,
these
emission
factors
are
based
on
0.5
percent
of
the
pushes
being
severely
green
and
a
10
percent
capture
efficiency,
5
percent
of
the
pushes
being
moderately
green
and
a
40percent
capture
efficiency,
and
94.5
percent
of
the
pushes
being
non­
green
and
a
90
percent
capture
efficiency.
The
emission
estimates
for
each
battery
are
given
in
Table
6,
and
an
example
calculation
is
given
below.

4
Example
calculations
for
MCSO
for
AK
Steel
Ashland
Batterv
3:

Pushing
fugitives
=
376,000
tpy
coke
*
0.01
16
lb/
ton
=
4,400
lb/
yr
=
2.2
tpy
MCSO
New
Boston,
Portsmouth,
OH"
2
353,000
3.2
Tonawanda,
Buffalo,
NYa
2
218,701
2.0
a
These
plants
do
not
have
a
control
device
for
pushing
emissions.

3.2.
Pushing
Emission
Control
Device
The
EPA
conducted
two
source
tests
in
19988.9to
evaluate
emissions
from
control
devices
applied
to
pushing
emissions.
One
test
was
conducted
on
Battery
No.
2
at
Bethlehem
Steel,
Bums
Harbor,
IN,
and
the
other
was
conducted
on
Batteries
5
and
6
at
ABC
Coke
in
Tarrant,
AL.
Bethlehem
Steel
produces
furnace
coke,
and
ABC
Coke
produces
foundry
coke.

Both
batteries
use
pulse
jet
baghouses
as
the
control
devices
for
pushing
emissions.
Battery
2
at
Bums
Harbor
is
the
newest
battery
in
the
U.
S.
(
1994),
and
it
has
a
new
state­
of­
the
art
baghouse.
The
baghouse
at
ABC
Coke
is
older
(
1986),
and
the
batteries
are
much
older
(
1951).
For
this
analysis,
the
results
from
ABC
Coke
are
used
because
the
battery
age,
battery
condition,
and
control
device
are
expected
to
be
more
representative
of
batteries
on
the
MACT
track.
The
performance
of
the
baghouse
at
Burns
Harbor
was
somewhat
better:
99%
removal
of
the
7­
PAHs
vs.
97%
at
ABC
Coke
and
99.8%
removal
of
PM
vs
98.9%
at
ABC
Coke.

Emission
factors
for
PAHs
and
metals
for
the
ABC
Coke
test
are
given
in
Tables
7
and
8,
respectively.
The
PAH
results
are
based
on
the
averages
from
Runs
2
and
3
and
do
not
include
Run
1.
There
was
a
severely
green
push
during
Run
1.
The
severely
green
push
5
occurred
from
an
oven
that
was
adjacent
to
an
oven
that
had
been
taken
out
of
service
for
repair,
which
can
cause
inadequate
coking
on
the
side
of
the
oven
that
shares
flues
with
the
empty
oven.
This
push
exhibited
opacity
that
approached
loo%,
and
the
high
opacity
continued
during
travel
to
the
quench
tower.
This
is
expected
to
be
a
rare
occurrence
after
the
MACT
stantlard
is
in
place
because
the
proposed
rule
requires
that
actions
be
taken
to
mitigate
the
effect
on
adjacent
ovens
when
an
oven
is
taken
out
of
service.
In
addition,
the
frequency
of
occurrence
during
Run
1
(
1
in
21
pushes)
is
not
representative
of
the
performance
of
batteries
on
which
M.
ACT
is
based.
The
MACT
batteries
rarely
have
pushes
that
exceed
an
average
opacity
of
50%.
Consequently,
Run
1
at
ABC
Coke
is
not
representative
of
emissions
levels
expected
aftler
the
implementation
of
MACT.

TABLE
7.
PAH
EMlSSlON
FACTORS
FOR
THE
PUSHING
EMISSION
CONTROL
DEVICE
AT
ABC
COKE
I
PAHs
Benzo(
a)
anthracene
Benzo(
a)
pyrene
Benzo(
b)
fluoranthene
Benzo(
k)
fluoranthene
Chrysene
Dibenzo(
a,
h)
anthracene
Indeno(
1,2,3­~
d)
pyrene
Acenaphthene
Acenaphthylene
Anthracene
Benzo(
g,
h,
i)
perylene
Fiuoranthene
Fluorene
Naphthalene
Phenanthrene
Pyrene
2­
Methylnaphthalene
Benzo(
e)
pyrene
_

Pervlene
ND=
not
detected
BAGHOUSE
OUTLET
(
Wton)
Run2
Run3
Average
3.7e­
07
3.7e­
07
3.7e­
07
ND
ND
ND
2.8e­
07
3.3e­
07
3.
le­
07
2.4e­
07
2.2e­
07
2.3e­
07
9.8e­
07
l.
le­
06
1.
Oe­
O6
ND
ND
ND
ND
ND
ND
3.8e­
06
5Se­
06
4.7e­
06
3.4e­
05
2.7e­
05
3.1e­
05
5.0e­
06
8.0e­
06
6.5e­
06
ND
ND
ND
5.0e­
06
8.0e­
06
6.5e­
06
l.
le­
05
1.4e­
05
1.3e­
05
1.4e­
04
1.7e­
04
1.
k­
04
6.9e­
05
4.2e­
05
5.6­
05
1.2e­
05
1.
Oe­
05
l.
le­
05
3.7e­
05
5.6e­
05
4.7e­
05
ND
1.7e­
07
8.5e­
08
ND
ND
ND
6
TABLE
8.
METALS
EMISSION
FACTORS
FOR
THE
PUSHING
EMISSION
CONTROL
DEVICE
AT
ABC
COKE
BAGHOUSE
OUTLET
(
Ibhon)
Run1
Run2
Run3
Average
ND
ND
ND
ND
4.6E­
7
5.7E­
7
8.4E­
7
6.2E­
7
7.5E­
6
9.9E­
6
1.3E­
5
1.
OE­
5
ND
4.3E­
8
6.7E­
8
3.7E­
8
1.4E­
7
1.7E­
7
1.2E­
7
1.4E­
7
2.9E­
6
4.3E­
6
5.9E­
6
4.4E­
6
ND
ND
ND
ND
4.3E­
6
5.2E­
6
7.4E­
6
5.6E­
6
1.8E­
6
3.6E­
6
2.7E­
6
2.7E­
6
3.8E­
6
6.5E­
6
9.1E­
6
6.4E­
6
ND
ND
ND
ND
ND
2.6E­
6
2.
OE­
6
1.5E­
6
2.4E­
5
2.2E­
5
3.4E­
5
2.7E­
5
ND
8.6E­
7
ND
2.9E­
7
ND
ND
ND
ND
ND
ND
ND
ND
1.7E­
5
1.9E­
5
2.5E­
5
2.
OE­
5
ND
=
not
detected
The
only
available
data
for
benzene
emissions
from
the
control
device
were
from
a
source
test
conducted
at
Bethlehem
Steel,
Bums
Harbor
in
1995?
4
Benzene
results
for
three
runs
in
Ib/
ton
of
coke
were
3.77
x
lod,
2.54
x
and
9.94x
10 .
The
average
value
of
2.43
x
1OdIb/
ton
of
coke
was
used
to
estimate
benzene
emissions
from
the
control
device.

Site­
specific
information
on
the
tons
of
coke
produced
at
each
of
the
MACT
track
batteries
was
obtained
from
an
EPA
survey 
of
the
industry
and
from
data
compiled
from
a
survey
conducted
by
ICF
Consulting. 
The
coke
production
in
tons
per
year
was
multiplied
by
the
emission
factors
(
lb/
ton
of
coke)
to
estimate
the
annual
emissions
in
Ibs/
yr
given
in
Table
9.

7
TABLE
9.
EMISSION
ESTIMATES
FOR
PUSHING
EMISSION
CONTROL
DEVICES
Plant
Battery
Coke
(
tPY)
PAHs:
Benzo(
alanthracc
Benzo(
b)
fluoranl
Benzo(
klfluoran1
Chrysene
Acenaphthene
Acenaphthylene
Anthracene
Fluoranthene
Fluorene
Naphthalene
Phenanthrene
Pyrene
2­
Methylnaphtha
Benzo(
e)
pyrene
Metals:
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Manganese
Nickel
Phosphorus
Selenium
Zinc
Benzene
:
Benzo(
a)
anthracene=
376,000
tpy
coke
x
3.7
x
lb/
ton
=
0.139
Ib/
yr
Arsenic
=
376,000
tpy
coke
K
6.2
x
lb/
ton
=
0.233
lb/
yr
Benzene
=
376,000
tpy
coke
x
2.43
x
lo4
lb/
ton
=
91
lb/
yr.

8
3.3
Quenching
Emissions
MCSO
emissions
from
quenching
are
based
on
0.00706
lb/
ton
of
coal
charged.

Additional
details
are
given
in
Appendix
B.
Emission
estimates
are
given
in
Table
10,
and
an
example
calculation
is
given
below.

Example
calculationsfor
MCSO
for
AK
Steel
Ashland
Batterv
3:

Quenching
=
533,000
tpy
coal
*
0.00706
lb/
ton
=
3,800
Ib/
yr
=
1.9
tpy
MCSO
TABLE
10.
EMISSION
ESTIMATES
FOR
QUENCHING
METHYLENE
AK
Steel,
Ashland,
KY
3.4.
Battery
Stacks
Emissions
estimates
for
PAHs
and
metals
from
battery
stacks
are
also
derived
from
the
two
EPA
tests8­
9 
22
and
the
ABC
Coke
results.
The
test
results
for
ABC
Coke
are
used
because
the
battery
condition
(
specifically
the
oven
walls)
is
more
representative
of
the
MAC 
track
batteries
than
the
new
battery
at
Bums
Harbor
would
be.
However,
emissions
are
scaled
based
on
opacity
and
volumetric
flow
rate
as
explained
in
the
Background
Information
Document
for
the
MACT
standard. 
For
example,
the
average
opacity
at
ABC
Coke
was
1.7%,
and
the
average
opacity
after
MACT
is
implemented
is
estimated
to
be
a
maximum
of
5%
(
the
batteries
used
to
establish
the
MACT
standard
for
battery
stacks
average
2%
to
5%
opacity).

Consequently,
emissions
are
scaled
up
by
a
factor
of
2.9.
In
addition,
the
mass
emission
rate
at
a
given
concentration
is
proportional
to
the
volumetric
flow
rate,
which
was
83,000
acfm
at
9
ABC
Coke.
Emissions
for
a
given
battery
are
estimated
from
the
Ib/
hr
measured
at
ABC
Coke
from
the
folllowing
equation:

Emissions
(
lbfir)=
lbhr
(
at
ABC
Coke)
x
2.9
(
opacity
adjustment)
*
(
acfm)/(
83,000acjh).

The
test
results
for
the
PAHs
and
metals
at
ABC
Coke
are
given
in
Tables
11
and
12,

respectively.
The
annual
emission
estimates
for
PAHs
and
metals
for
the
MACT
track
batteries
are
given
in
Table
13,
and
an
example
calculation
is
given
below
for
Battery
3
at
AK
Steel,
Ashland:

Benzo(
a)
anthracene=
5.1
x
IO6
Ibhr
*
2.9
*
54,200
acfm/
83,000acfm
=
9.66
x
lo4
Ibh
=
0.085
lb/
yr
Arsenic
=
2.0
x
Ibhr
*
2.9
*
54,200
acfm
/
83,000
acfm
=
3.79
x
lo4
lbhr
=
3.3
lb/
yr.

The
results
of
tests
for
benzene
from
battery
stacks
at
four
batteries
were
reviewed
to
derive
an
emission
factor.
The
test
results
are
summarized
in
Table
14.
For
this
analysis,
the
test
results
in
Table
14
for
Kaiser
Steel
and
Bethlehem
Steel
were
used.
Benzene
emissions
from
battery
stacks
are
based
on
a
concentration
of
3
ppm
(
6.07
x
lo=]
lb/
dscf)
and
the
site­

specific
vohmetric
flow
rate
in
dscfm.
The
emission
estimates
are
given
in
Table
15,
and
an
example
calculation
is
given
below
for
Battery
3
at
AK
Steel,
Ashland:

31,773
dscfm
*
6.07
x
lb/
dscf
=
0.0193
lb/
min
=
10,100
lb/
yr.

10
TABLE
11.
PAH
TEST
RESULTS
FOR
BATTERY
STACKS
­­
ABC
COKE
EMISSIONS
(
lbhr)
Run
1
Run2
Run3
'
Run4
Average
8.6E­
06
4.7E­
06
ND
7.2E­
06
5.1E­
06
1.2E­
05
9.9E­
06
ND
7.7E­
06
7.5E­
06
1SE­
05
2.
OE­
05
1.1E­
05
1.3E­
05
1.4E­
05
ND
1.2E­
07
ND
1.4E­
07
6.4E­
08
2.
OE­
05
2.2E­
05
1SE­
05
2.5E­
05
2.
OE­
05
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1SE­
05
1.1E­
05
6.
OE­
06
1.2E­
05
1.1E­
05
B.
6E­
04
3.2E­
03
6.5E­
04
ND
1.2E­
03
3.3E­
07
4.1E­
07
1.1E­
05
3.6E­
07
3.
OE­
06
ND
ND
ND
ND
ND
2.9E­
04
5.6E­
04
2.4E­
04
3.4E­
04
3.6E­
04
LOE­
05
3.2E­
05
1.8E­
05
6.3E­
05
4.1E­
05
5.3E­
03
6.1E­
03
33E­
03
4.8E­
03
5.
OE­
03
5.9E­
04
9.4E­
04
4.9E­
04
8.5E­
05
5.3E­
04
1SE­
04
9.9E­
04
1.7E­
04
2.2E­
04
3.8E­
04
1SE­
04
1.1E­
04
7.9E­
05
2.1E­
04
1.4E­
04
1.6E­
05
6.6E­
05
1.8E­
05
1.4E­
05
2.8E­
05
ND
ND
ND
ND
ND
ND
=
not
detected
TABLE
12.
METALS
TEST
RESULTS
FOR
BATTERY
STACKS
­­
ABC
COKE
Metal
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Phosphorus
Selenium
Silver
Thallium
Zinc
ND
=
not
detected
Emissions
(
lbhr)
Run
1
Run
2
Run
4
Average
ND
ND
ND
ND
1.2E­
4
2.4E­
4
2.3E­
4
2.
OE­
4
2.4E­
4
5.7E­
4
4.0E­
4
4.1E­
4
8.9E­
7
3.3E­
6
1SE­
6
1.9E­
6
1.4E­
5
1.7E­
5
2.3E­
5
1.8E­
5
2.3E­
4
5.1E­
4
2.8E­
4
3.4E­
4
ND
ND
ND
ND
2.2E­
4
2.4E­
4
2.8E­
4
2.5E­
4
3.6E­
4
4.
OE­
4
2.6E­
4
3.4E­
4
1.1E­
4
2.7E­
4
3.
OE­
4
2.2E­
4
ND
ND
ND
ND
4.9E­
5
1.4E­
4
7.8E­
5
8.8E­
5
6.7E­
4
1.7E­
3
1SE­
3
1.3E­
3
8.9E­
5
2.
OE­
4
2.5E­
4
1.8E­
4
ND
ND
ND
ND
4.
OE­
5
4.8E­
5
3.9E­
5
4.2E­
5
1.2E­
3
1SE­
3
1.5E­
3
1.4E­
3
11
TABLE;
13.
EMISSION
ESTIMATES
OF
PAHS
AND
METALS
FOR
BATTERY
STACKS
12
TABLE
14.
TEST
RESULTS
FOR
BENZENE
FROM
BATTERY
STACKS
Plant
Benzene
emissions
from
battery
stacks
Bethlehem
PPm
Iblton
of
coal
tons/
yr
J&
L
Steel,
Battery
P­
4,
Pittsburgh,
PA,
0.6
to
1.6
0.0045
to
0.01
1.5
to
3.4
May
1979  

National
Steel
Battery
C,
Granite
City,
IL,
July
0.1
to
0.2
0.0022
to
0.0031
0.3
to
0.4
197912
Kaiser
Steel
Battery
B,
Fontana,
CA,
September
1.8
to
4.1
0.029
to
0.066
3.5
to
7.9
1979 

Steel
Battery
1,
Bums
Harbor,
IN,
I
2.6
to
3.2
I
0.023
to
0.028
1
15t018
I
March
199513
TABLE
15.
BENZENE
EMISSION
ESTIMATES
FOR
BATTERY
STACKS
Plant
Stack
Battery
Stack
gas
flow
rate
(
dscfm)
Benzene
(
lb/
yr)
AK
Steel,
Ashland,
KY
9
3
31,773
10,100
AK
Steel,
Ashland,
KY
15
4
111,882
35,700
AK
Steel,
Middletown,
OH
1
W
91,577
29,200
Erie
Coke,
Erie,
PA
1
A,
B
22,209
7,090
New
Boston,
Portsmouth,
OH
2
2
35,570
11,300
Tonawanda,
Buffalo,
NY
2
2
56,842
18,100
4.
Benzene
Emissions
from
Process
Equipment
in
the
By­
product
Recovery
Plant
Estimates
of
benzene
emissions
from
process
equipment
in
the
by­
product
recovery
plant
are
based
on
the
emission
factors
in
Ib/
ton
of
coke
from
AP­
425
(
see
the
excerpt
provided
in
Appendix
C).
The
emission
factors
are
given
in
Table
16
­­
one
set
for
furnace
coke
and
one
for
foundry
coke.
Tonawanda
and
Erie
Coke
produce
foundry
coke,
and
the
other
plants
produce
furnace
coke.
Most
of
the
emission
factors
are
for
sources
with
emissions
controlled
by
gas
blanketing
as
required
by
the
benzene
NESHAP
for
by­
product
recovery
plants
(
40
CFR
Part
61,
Subpart
L).
The
exceptions
are
the
excess
ammonia
liquor
tanks
and
light
oil
storage
tanks
for
foundry
coke
batteries,
which
are
not
required
to
be
controlled.

13
r'

3:
0
3
N
It
b,
C:
9­
Ei
c)

E
.­
C
p.
L
Site­
specific
information
on
the
processes
present
at
each
plant
is
used
to
estimate
emissions.
For
example,
when
emissions
from
processes
are
labeled
as
 
None 
in
Table
16,
it
means
that
the
process
is
not
present
or
that
it
is
a
closed
vent
system
operated
under
negative
pressure
(
no
leaks).
AK
Steel­
Middletown
and
Erie
Coke
do
not
have
a
light
oil
recovery
process;
consequently
they
do
not
have
a
light
oil
condenser,
light
oil
storage,
and
other
process
vessels
associated
with
light
oil
recovery.

The
estimate
for
the
ammonia
still
for
Tonawanda
Coke
was
provided
by
the
company.

Erie
Coke
does
not
have
an
ammonia
still,
New
Boston
Coke
vents
it
to
the
coke
oven
gas
system,

and
AK
Steel
vents
it
to
a
thermal
oxidizer.

Example
calculation
for
AK
Steel
Ashland:

Light
oil
storage
=
964,977
tpy
coke
*
0.00024
Ib/
ton
=
232
lb/
yr
5.
Benzene
Emissions
from
Equipment
Leaks
Benzene
emissions
from
equipment
leaks
are
estimated
from
the
procedures
in
 
Protocol
for
Equipment
Leak
Emission
Esrimates. 
I4
The
protocol
for
estimating
emissions
is
determined
by
the
amount
of
information
that
is
available.
If
there
are
no
Method
21
data
available,

emissions
are
based
on
a
single
set
of
default
emission
factors.
If
there
is
information
on
the
number
of
leaking
components
but
no
screening
values
from
Method
21,
the
protocol
applies
one
set
of
emission
factors
to
non­
leaking
components
and
another
set
to
leaking
components.
The
most
refined
approach
is
based
the
actual
screening
value
that
is
measured
for
a
leaking
component.
Emissions
are
estimated
for
each
leaking
component,
and
a
small
default
emission
factor
is
applied
to
non­
leaking
components.

The
plants
with
equipment
in
benzene
service
are
those
that
recover
light
oil
(
a
mixture
of
benzene,
toluene,
and
xylene).
AK
Steel
Ashland,
New
Boston
Coke,
and
Tonawanda
Coke
have
light
oil
recovery
systems
and
equipment
in
benzene
service.
AK
Steel
Ashland 
and
New
Boston
Coke4provided
Method
21
data
for
inspections
of
their
light
oil
system.
Consequently,

their
emissions
were
estimated
from
correlations
for
the
Method
21
screening
values.
Default
emission
factors
from
the
protocol
were
applied
to
the
equipment
components
for
Tonawanda
15
Coke.
Each
of
the
plants
provided
the
number
of
equipment
components
(
pumps,
valves,
flanges,

pressure
relief
devices)
in
benzene
service
and
the
concentration
of
benzene
in
the
process
stream."

Results
are
given
in
Table
17
for
AK
Steel
Ashland,
Table
18
for
Tonawanda
Coke,
and
Table
19
for
]
New
Boston
Coke.

Example
calculation
for
AK
Steel
Ashland
0
One
valve
leaking
at
a
screening
level
of
5,000
ppm
handling
light
oil
(
75%

benzene)
during
one
quarterly
inspection
(
2,190
hr/
yr):

2.29E­
06
*
(
5,000)
0,746
=
0.0013
kg/
hr
*
2,190
hdyr
*
0.75
(
fraction
benzene)
=
2.2
kgyr
=

4.8
lbJyr
0
One
valve
with
screening
level
pegged
at
10,000ppm
inspected
annually:

6.4E­:!
kg/
hr
*
8,760
hr/
yr
*
0.75
(
fractionbenzene)
=
420
kg/
yr
=
925
Ib/
y
ExamDle
of
default
approach
for
Tonawanda
Coke
0
36
valves
handling
light
oil
with
65%
benzene
­
default
emission
factor
is
0.0109
kg/
hr
per
valve:

36
valves
*
0.0109
kg/
hr/
valve
*
0.65
(
fraction
benzene)
*
2.2
Ib/
kg
*
8,760
hdyr
=

4,916
Ib/
yr
16
TABLE
17.
BENZENE
EMISSIONS
FROM
EQUIPMENT
LEAKS
­
AK
STEEL
ASHLAND
TABLE
18.
BENZENE
EMISSIONSFROM
EQUIPMENT
LEAKS
­
TONAWANDA
COKE
ISTREAM
I
%
BENZENE
I
COMPONENT
I
NUMBER
IEMISSION
FACTOR
IBENZENE
(
lb/
yr)
l
Light
oil
65
Pump
1
1.14E­
01
1,428
Flange
37
2.5OE­
04
116
Valve
36
1.09E­
02
4,916
Open
end
line
1
2.3OE­
03
29
Total
6,500
(
kghrlsource)

TABLE
19.
BENZENE
EMISSIONSFROM
EQUIPMENT
LEAKS
­
NEW
BOSTON
COKE
STREAM
PERCENT
COMPONENT
NUMBER
EMISSION
FACTOR
BENZENE
BENZENE
(
kp/
hrhource)
(
lb/
vr)
Light
oil
67
2.4OE­
05
2.8
Flange
848
3.1OE­
07
3.4
Valve
122
7.8OE­
06
12.3
Open
end
line
72
2.
OOE­
06
1.9
Gas
10
Pressure
relief
8
see
Tables
20
and
21
42.1
devices
I
I
Total
I
63
17
TABLE
20.
EMISSIONS
FROM
LEAKING
PRESSURE
RELIEF
DEVICES
­
NEW
BOSTON
COKE
assumed
10,
OOO
ppm
reported
­
assumed
141Ihr
fnr
Ad
mnnthc
=
A2
Ihr/
v:

18
TABLE
21.
EMISSION
ESTIMATES
FOR
NON­
LEAKINGPRESSURERELIEF
DEVICES­­
NEW
BOSTON
COKE
NOV­
00
I
8
I
4.
OOE­
06
I
10
I
0.0051
Dee­
00
8
I
4.
OOE­
06
I
10
0.0051
I
0.21
Ibs
for
44
months
=
0.06
Ibs/
yr
I
19
6.
Benzene
Emissions
from
Product
Loading
Benzlene
emissions
occur
when
tar
and
light
oil
are
loaded
into
tank
trucks.
Emission
estimates
for
product
loading
(
based
on
AP­
42
loading
equations)
were
provided
by
AK
Steel
and
Tonawanda
Coke.
AK
Steel
reported
5,600
lbs/
yr
of
benzene
emitted
from
loading
light
oil.

Based
on
a
coal
usage
rate
of
1,305,000
tpy,
the
emission
factor
is
4.3
x
Ib/
ton
of
coal.

Tonawanda
reported
840
lbs/
yr,
which
gives
an
emission
factor
of
3.1
x
10 
lb/
ton
of
coal
based
on
coal
usage
of
275,000
tpy.
The
average
of
these
emission
factors
(
3.7
x
10 
Ib/
ton)
was
applied
to
the
other
plants
to
estimate
emissions
from
loading
light
oil.

AK
Steel
reported
540
lbs/
yr
of
benzene
emissions
from
loading
tar,
which
gives
an
emission
factor
of
4.1
x
Ib/
ton
of
coal.
In
the
absence
of
other
information,
this
emission
factor
was
applied
to
each
of
the
other
plants
to
estimate
benzene
emissions
from
tar
loading.

The
results
are
summarized
in
Table
22.

7.
Benzlene
Emissions
from
Wastewater
Benzene
emissions
from
wastewater
were
estimated
from
information
provided
by
the
plants
on
the
quantity
of
benzene
in
wastewater
and
an
estimate
that
85%
is
emitted
(
from
the
EPA
document
 
Locating
and
Estimating
Air
Emissionsfrom
Sources
of
Benzene ).
16
Benzene
emissions
from
wastewater
are
controlled
because
the
benzene
waste
NESHAP
(
40
CFRPart61,

Subpart
FF)
applies
to
these
plants.
Results
are
given
in
Table
22.

20
TABLE
22.
BENZENE
EMISSIONS
FROM
PRODUCT
LOADING
AND
Plant
AK
Ashland
AK
Middletown
Tonawanda
Erie
New
Boston
WASTEWATER
Product
Benzene
from
loading
Source
Benzene
from
Wyr)
wastewater
(
Ib/
yr)

TW
540
AP­
42a
900
Light
oil
5,600
AP­
42a
TW
940
AP­
42"
730
TW
120
Emission
factor"
510
Light
oil
840
AP­
42"

TW
120
Emission
factorb
120
TW
220
Emission
factor"
nild
Light
oil
2,000
Emission
factof
"
From
site­
specific
data
and
AP­
42procedures.
From
AK
Steel
(
Ashland)
emission
factor
of
4.1
x
lo4
Ib/
ton
coal
charged.
From
average
emission
factor
of
3.7
x
10"
Ib/
ton
coal
charged
from
AK
Steel
(
Ashland)
and
Tonawanda
Coke.
This
plant
installed
a
new
wastewatertreatment
system
in
1999.
The
system
is
enclosed/
coveredand
vented
to
a
control
system,
and
emissions
are
negligible.

8.
Ratios
of
Other
Constituents
to
Extractable
Organics
Data
from
12
coke
plants
supplied
by
the
American
Coke
and
Coal
Chemicals
Institute"

indicates
that
EPA's
group
of
7
PAHs
comprise
4.5%
of
the
BSO
based
on
analyses
of
coal
tar.

TABLE
23.
7
PAHs
IN
BSO
7
PAHs
Average
(%)
Benzo(
a)
anthracene
Benzo(
a)
pyrene
Benzo(
b)
fluoranthene
Benzo(
k)
fluoranthene
Chrysene
Dibenzo(
a,
h)
anthracene
Ideno(
1,2,3­~
d)
pyrene
Total
0.90
0.84
0.68
0.59
11
0.052
0.37
4.5
0.46­
1.3
0.37
­
1.0
0.015
­
0.1
1
Data
from
other
sources
(
as
well
as
the
results
in
Table
23)
indicate
that
benzo(
a)
pyrene,

traditionally
used
as
an
indicator
of
coke
oven
emissions,
is
about
one
percent
of
the
BSO.''.
I9v2O
EPA
conducted
a
source
test
in
1978
that
measured
BSO
and
PAHs
in
a
lid
leak
during
the
first
21
hour
of
coking?
l
The
results
for
additional
PAHs
(
other
than
the
7
PAHs
listed
in
Table
23)
are
given
in
Table
24.
Other
constituentsin
coke
oven
emissions
from
the
revised
AP­
425
are
given
in
Table
25.

Table
24.
ADDITIONAL
PAHs
IN
BSO 

PAH
Fhoranthene
huorene
~____~
~~

Naphthalene
Phenanthrene
Pvrene
I
Total
%
of
BSO
2.3
.
I
1.1
I
10.5
4.2
2.4
I
20.5
1
TABLE
25.
OTHER
CONSTITUENT
IN
COKE
OVEN
EMISSIONS5
Compound
Carbon
monoxide
Carbon
dioxide
Hydrogen
sulfide
Ammonia
Hydrogen
cyanide
Methane
Ethane
Propane
Butane
Ethylene
Propylene:
Propyne
Butene
Pentene
Benzene
Toluene
Xylene
Acetylene
Butadiene:
Ratio
to
BSO
1.1
0.5
0.15
0.15
0.05
2.7
0.3
0.03
0.02
0.4
0.08
0.003
0.07
0.01
0.5
0.04
0.005
0.009
0.009
0.001
0.001
22
Compound
Thiophenes
Ammonia
and
acids:
HCl
HF
"
03
H,
SO,
Metals:
Arsenic
Mercurv
Selenium
Semivolatiles:
Benzofuran
Benzonitrile
Dibenzofuran
Dimethyl
phenol
Hexanoic
acid
djoctylester
2­
methyl
phenol
4­
methyl
phenol
Phenol
Propanenitrile
Propynyl
benzene
Pyridine
Trimethyl
benzene
Volatile
organics:
Methylethyl
benzene
Ratio
to
BSO
0.003
0.0009
5x1OT6
7x105
0.0007
2x
10­
7
2x
10=
1
2x
10­
7
7x
10'
5
2x10­
5
9x
10"
9x
10"
2x10­
5
7x10­
5
2x10"'
6x
10"'
9x
1o­
6
2x10­
5
0.0002
5x10"

0.003
For
pushing
emissions,
data
are
available
from
EPA
tests
that
quantified
semivolatile
organics
and
metals.
The
results
are
presented
in
Table
26
for
PAHs
and
Table
27
for
metals
based
on
their
ratio
to
methylene
chloride
soluble
organics.

23
­­
TABLE
26.
PAHs
IDENTIFIED
IN
FUGITIVE
PUSHING
EMISSIONS*

Perylene
0.0001
Total
­­
all
PAHs
0.0840
TABLE
27.
RATIOS
OF
METALS
TO
EXTRACTABLE
ORGANICS
FOR
FUGITIVE
PUSHING
EMISSIONS
Se
5.9E­
04
I
2.2E­
03
Total
1.3E­
02
4.6E­
02
24
9.
Ratio
of
Xylene
and
Toluene
to
Benzene
in
By­
Product
Recovery
Plant
Emissions
Data
from
several
sources
were
examined
and
are
listed
below.
The
ratio
of
xylene
to
benzene
ranges
from
0.01
to
0.055,
and
the
ratio
of
toluene
to
benzene
ranges
from
0.06
to
0.16
a.
From
 
The
Making,
Shaping,
and
Treating
of
Steel 
=­­
Composition
of
light
oil
(
benzene,
toluene,
and
xylene)

%
Midrange
%
Ratio
to
benzene
Benzene
60
­
85
72.5
Toluene
6­
17
11.5
0.16
Xylene
1­
7
4
0.055
b.
From
draft
AP­
42
Table
12.2.5 ­­
components
of
raw
coke
oven
gas
Ratio
to
BSO
Ratio
to
benzene
Benzene
0.5
Toluene
0.04
0.08
Xylene
0.005
0.01
c.
From
 
Identity
and
Chemical
and
Physical
Properties
of
Compounds
in
Coke
Oven
Emissions ­
Minor
Constituentsin
Coke
Oven
Gas 

mg/
m3
Benzene
35,800
23,900
21,400
average
27,000
Toluene
3,000
1,520
average
2,260
Xylene
500
Ratio
to
benzene
0.08
0.02
d.
From
 
Identity
and
Chemical
and
Physical
Properties
of
Compounds
in
Coke
Oven
Emissions ­­
Selected
Vapor
Concentrations
in
the
Coke
Oven
Battery
Environment
at
Five
U.
S.
Coke
Plant~. ~

Mean
mg/
m3
Ratio
to
benzene
Benzene
9.5
Toluene
0.6
0.06
Xylene
0.3
0.03
25
10.
References
1.
Memorandum
with
attachments,
S.
Burns,
RTI,
to
the
docket,
enclosing
data
compiled
from
IZPA
Section
114
survey
responses,
July
1998.
Docket
Item
II­
1­
45
in
Docket
Number
A­
2000­
34.

2.
U.
S.
:
Environmental
Protection
Agency.
Method
303
Inspections
of
By­
Product
Coke
Oven
Batteries
­
Compliance
with
the
NESHAP.
September
1999.

3.
Memorandum.
Stephen
Felton,
AK
Steel,
to
Dennis
Pagano,
US
EPA.
Enclosing
AK
Steel s
responses
to
EPA s
residual
risk
questionnaire.
May
15,2001.

4.
Memorandum.
Thomas
Decamp,
New
Boston
Coke
Corp.,
to
Dennis
Pagano,
US
EPA.
Enclosing
residual
risk
data
submission.
May
24,2001.

5.
US.
Environmental
Protection
Agency.
Emission
Factor
Documentation
for
AP­
42
Section
12.2:
Coke
Production.
Revised
Draft
Version
as
of
July
2001.

6.
U.
S.
Environmental
Protection
Agency.
Method
Development
Test
Report
No.
1.
U.
S.
Steel
[
ClairtonCoke
Works
Batteries
7,8,
and
9.
Dee&­­
A­
54
insacket
A­
79­
15.
August
1981.

7.
U.
S.
Environmental
Protection
Agency.
National
Emission
Standardsfor
Hazardous
Air
Pollutants
(
NESHAP)
for
Coke
Ovens:
Pushing,
Quenching,
and
Battery
Stacks­
Background
Information
for
Proposed
Standards.
EPA­
453/
R­
01­
006.
February
2001.

8.
U.
S.
Environmental
Protection
Agency.
Emissions
Testing
of
Combustion
Stack
and
Pushing
Operations
at
Coke
Battery
No.
5/
6
at
ABC
Coke
in
Birmingham,
Alabama.
EPA454
Rl­
99­
002a.
February
1999.

9.
U.
S.
Environmental
Protection
Agency.
Emissions
Testing
of
Combustion
Stack
and
Pushing
Operations
at
Coke
Battery
No.
2
at
Bethlehem
Steel
Corporation sBums
Harbor
Division
in
Chesterton,
Indiana.
EPA­
454/
R­
99­
001a.
February
1999.

10.
U.
S.
Environmental
Protection
Agency.
Coke
Quench
Tower
Emission
Testing
Program.
EPA­
1600/
2­
79­
082.
April
1979.

11.
Memorandum.
D.
Paul,
ICF
Consulting,
to
T.
Palma,
US
EPA.
Revised
Emission
Estimates
for
Coke
Oven
Emissions.
August
21,
2000.

12.
 
U.
S.
Environmental
Protection
Agency.
Coke
Oven
Battery
Stacks­
Background
Infomation
for
Proposed
Standards.
Preliminary
Draft.
US
EPA
Office
of
Air
Quality
Planning
and
Standards.
May
1980.

26
13.

14.

15.

16.

17.

18.

19.

20.

21.

22.

23.

24.
Mostardi­
Platt
Associates,
Inc.
Particulate
and
Gaseous
Emission
Diagnostic
Study
Performed
for
Bethlehem
Steel
at
the
Number
1
Underfire
Stack,
Burns
Harbor,
Indiana.
March
20
to
22,
1995.

U.
S.
Environmental
Protection
Agency.
Protocol
for
Equipment
Leak
Emission
Estimates.
EPA­
453/
R­
95­
017.
November
1995.

Memorandum.
Stephen
Felton,
AK
Steel,
to
Marvin
Branscome,
RTI.
Enclosing
AK
Steel's
Method
21
Inspection
Results.
May
10,2001.

U.
S.
Environmental
Protection
Agency.
Locating
and
Estimating
Air
Emissions
from
Sources
of
Benzene.
EPA­
454/
R­
98­
011.
June
1998.

Data
supplied
by
David
Ailor,
American
Coke
and
Coal
Chemicals
Institute.
September
2000.

Mabey,
W.
R.
Identity
and
Chemical
and
Physical
Properties
of
Compounds
in
Coke
Oven
Emissions.
Stanford
Research
Institute.
September
1977.

Suta,
Benjamin.
Human
Population
Exposures
to
Atmospheric
Coke
Oven
Emissions.
SRI
International.
October
1978.

White,
L.
et
al.
Atmospheric
Emissions
of
Coking
Operations
­
a
Review.
University
of
Cincinnati.
EPA
Docket
No.
A­
79­
15,
Item
II­
1­
9.

Hartman,
M.
W.
Source
Test
at
U.
S.
Steel
Clairton
Coke
Ovens.
Prepared
for
US
EPA's
Emissions
Measurement
Branch.
1978.

E­
mail
from
Michael
Maret,
PES,
to
Lula
Melton,
EPA.
Transmitting
revised
test
report
tables.
June
15,2001.

United
States
Steel.
The
Makmg,
Shaping,
and
Treating
of
Steel.
Association
of
Iron
and
Steel
Engineers.
10"
Edition.
1985.

Mostardi­
Platt
Associates,
Inc.
Particulate
and
Gaseous
Emission
Diagnostic
Study
Performed
for
Bethlehem
Steel
at
the
Number
1Coke
Battery
Pushing
Control
Stack,
Burns
Harbor,
Indiana.
March
21
to
23,1995.

27
APPENDIX
A.
EXCERPTS
FROM
REVISED
AP­
42
A­
1
Emission
Factor
Documentation
for
AP­
42
Section
12.2
Coke
Production
Revised
Draft
Report
(
For
internal
review
­
July
2001)

For
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Emission
Factor
and
Inventory
Group
EPA
Purchase
Order
7D­
1554­
NALX
MRI
Project
No.
4864
November
1998
A­
2
NOTICE
This
document
is
a
preliminary
draft.
It
has
not
been
formally
released
by
the
U.
S.
Environmental
Protection
Agency
and
should
not
at
this
stage
be
construed
to
represent
Agency
policy.
It
is
being
ciirculated
for
comments
on
its
technical
merit
and
policy
implications.

A­
3
4.1.2
Develo~
mentof
Candidate
Emission
Factors
for
Leaks
and
Charging
The
emission
data
for
uncontrolled
or
poorly
controlled
door
leaks
are
given
in
Table
4­
1.
The
results
from
References
1
through
4
are
averaged
to
generate
an
emission
factor
of
0.5
lb/
ton
(
0.25
kg/
Mg)
of
coal
charged
for
filterable
PM.
Door
leaks
controlled
at
the
pre­
NESHAP
level
are
also
.
given
in
Table
4­
1
in
terms
of
coke
pushed.
The
ratios
of
BS0:
filterable
PM
(
1.1)
and
condensible:
filterable
PM
(
0.6)
were
taken
from
Reference
3.

As
door
leak
control
has
improved
over
the
past
20
years,
observations
and
theoretical
models
suggest
that
the
nature
of
the
leaks
have
changed
from
large
leaks
(
with
occasional
door
leak
fires)
to
much
smaller
leaks.
Reference
5
has
a
higher
leak
rate
than
that
reported
in
Reference
3
although
the
percent
leaking
doors
was
higher.
Table
4­
2
summarizes
data
from
References
3
and
5
that
show
BSO
leak
rates
of
0.4
to
1.3
Ib
BSOhr
(
0.19
to
0.58
kg/
hr)
per
leaking
door
for
average
levels
of
70
and
29
percent
leaking
respectively.
The
difference
may
represent
variability
between
batteries
that
could
be
due
to
differences
in
collecting
main
pressure,
type
of
coal,
or
the
coking
cycle
(
e.
g.,
30
hours
in
Reference
3
and
18
hours
in
Reference
5).
A
theoretical
exponential
model
was
developed
in
Reference
6
to
extrapolate
from
the
data
presented
in
References
3
and
5
and
used
in
Reference
9
to
estimate
emissions
from
coke
oven
doors
at
improved
performance
levels.
This
exponential
model
results
in
a
predicted
range
of
0.02to
0.26
Ibhr
(
0.01
to
0.12
kg/
hr)
for
10
percent
leaking
doors.
The
midrange
of
these
predicted
emission
rates
is
0.14
Ibhr
(
0.063kg/
hr)
and
is
the
value
recommended
for
doors
controlled
to
the
pre­
NESHAP
levels.

Door
leak
data
from
References
7
and
39
are
given
in
Table
4­
3.
Because
the
calculations
in
both
reports
did
not
follow
standard
practices,
the
data
for
all
leaks
were
recalculated
for
these
tests.
This
recalculation
had
the
most
effect
for
the
Category
0,0.5
and
1leaks
from
Reference
7
because
of
the
high
blank
corrections,
the
use
of
negative
numbers
in
calculations
and
an
inappropriate
method
for
determining
the
minimum
detectible
weights.
The
use
of
solvents
with
lower
solids
and
the
negative
numbers
problem
was
corrected
in
the
subsequent
test
reported
in
Reference
39.
The
Category
4
results
for
BSO
(
0.49
Ibhr)
are
in
the
same
range
as
those
reported
in
References
3
and
5
for
heavy,
uncontrolled
door
leaks
but
are
not
representative
of
the
current
level
of
emission
control.
The
BSO
results
for
the
smallest
leaks
(
Categories
0.5
and
1)
were
not
statistically
different
and
averaged
0.023
and
0.026
Ibhr
(
0.011
and
0.012
kg/
hr)
respectively.
The
BSO
emission
rate
increased
as
the
visible
size
of
the
leak
increased
with
averages
of
0.061
and
0.11
Ibhr
(
0.028
and
0.05
kg/
hr)
for
Categories
2,
and
3,
respectively.
The
average
emission
rate
for
leak
rate
Category
3
compares
very
favorably
with
the
midrange
values
predicted
by
the
exponential
model
in
Reference
9,
which
estimated
rates
of
0.14
Ibhr
(
0.063kg/
hr)
for
an
average
of
10percent
leaking
doors.
This
implies
that
at
least
one
door
would
be
visibly
leaking
at
about
the
Category
4
level.
At
the
NESHAP
performance
level,
it
is
expected
that
the
visible
door
leaks
would
be
dominated
by
Category
0.5
and
1
leaks
with
some
Category
2
leaks
and
a
few
Category
3
leaks.
The
available
data
for
Categories
0.5
through
3
leaks
are
dominated
by
the
18
Category
0.5
and
1
tests
with
only
5
Category
2
tests
and
3
Category
3
tests.
The
run
by
run
average
leak
rate
for
Categories
0.5
through
3
in
Table
4­
3
is
0.041
Ibhr
(
0.019kg/
hr),
which
is
very
close
to
the
model
prediction
of
0.05
Ibhr
(
0.023kg/
hr)
for
an
average
of
5
percent
leaking
doors
and
is
the
value
recommended
for
well­
controlled
doors
with
emissions
visible
from
the
yard
as
measured
by
EPA
Method
303.

There
are
several
reasons
for
not
applying
the
exponential
model
results
from
the
NESHAP
background
document
for
percent
leaking
doors
less
than
10percent
in
this
analysis.
First,
the
A­
4
­.

exponential
model
is
not
applicable
for
levels
below
5
percent
leaking
doors
because
it
does
not
account
for
the
higher
oven
pressures
in
the
first
five
to
10
minutes
after
charging.
In
addition,
the
model
does
not
account
for
emissions
that
are
visible
from
the
bench
(
3
to
15
feet
distance)
but
not
the
yard
(
50
to
75
feet
distance).
Lastly,
the
model
is
based
on
the
self­
sealing
mechanism,
and
many
batteries
are
now
using
improved
door
seal
designs
and/
or
sodium
silicate
as
a
supplemental
sealant
to
reduce
the
number
of
leaking
doors.
The
improved
performance
of
the
newer
door
seal
designs
and
the
use
of
the
sealant
are
not
accounted
for
by
the
model
and
does
not
relate
to
the
calculations
of
sealing
time
(
due
to
tar
condensation)
that
the
model
uses.
Heavy
door
leaks,
which
should
be
uncommon
under
the
NESHAP,
would
have
a
higher
emission
rate
than
0.06
lbhr
(
0.027
kg/
hr),
and
doors
with
only
small
wisps
of
emissions
would
have
a
lower
rate.
The
data
from
References
7
and
39
provides
additional
support
in
that
even
the
smallest
visible
leaks
(
in
Categories
0.5
and
1)
have
higher
emission
rates
than
would
be
predicted
by
the
exponential
model
for
very
low
levels
of
percent
leaking
doors.
Consequently,
the
use
of
the
exponential
model
prediction
for
levels
below
5
percent
leaking
doors
would
result
in
a
significant
underestimate
of
emissions.

As
implied
above,
EPA
Method
303
does
not
identify
all
of
the
doors
that
have
visible
emissions.
A
subset
of
tlhe
data
from
References
7
and
39
can
be
used
to
quantify
emissions
from
doors
that
are
visibly
leaking
when
observed
from
the
bench
but
are
not
counted
as
visibly
leaking
by
EPA
Method
303.
EPA
Method
303
includes
an
adjustment
of
6%
for
doors
observed
from
the
bench
rather
than
the
yard.
As
a
result
there
may
be
7
to
8
doors
at
a
typical
battery
of
62
ovens
that
have
leaks
that
would
be
visible
from
the
bench
that
would
not
be
counted
by
EPA
Method
303.
Doors
with
visible
emissions
from
the
benlch
but
not
the
yard
are
assigned
an
emission
rate
of
0.023
lbhr
(
0.011kglhr).
This
is
the
average
emission
rate
of
doors
with
the
lowest
(
0.5)
graded
visible
emissions.
This
grade
level
represents
visible
emissions
that
are
barely
perceptible
and
may
be
missed
during
EPA
Method
303
observations.
Given
that
the
measured
emissions
from
the
lowest
two
graded
visible
emissions
were
not
statistically
different,
it
is
plausible
that
emissions
that
are
only
visible
from
the
bench
would
also
have
comparable
emissions.

Data
from
References
7,39
and
181
suggest
that
emissions
may
exist
when
there
are
no
visible
emissions
even
from
the
bench.
There
are
plausible
reasons
why
emissions
may
exist
when
there
are
no
visible
emissions
from
doors
during
normal
operations.
Data
from
Reference
39
documented
detectible
levels
of
emissions
from
doors
on
ovens
that
were
empty.
These
measured
emissions
were
about
three
times
lower
uhan
the
smallest
visible
leak
class
and
were
at
least
five
times
higher
than
the
background
BSO
results.
The
measured
emissions
from
the
empty
ovens
shown
in
the
report
ranged
from
0.006
to
0.016
lb
BSOh
(
0.0026to
0.007
kg
BSOh).
The
above
emissions
are
based
upon
a
limit
of
detection
of
three
times
tlhe
average
blank
value.
However,
the
Emission
Measurement
Center
(
EMC)
guidance
on
limits
of
detection
and
quantification
(
http://
www.
epa.
gov/
ttn/
emc/
facts.
html#
lab)
indicates
that
the
limit
of
detection
is
generally
based
upon
a
value
of
three
times
the
standard
deviation
of
the
blank
value.
When
this
criteria
is
used,
only
the
middle
value
is
changed
from
0.007
lb
BSO/
h
to
0.005
lb
BSOh.
At
the
detection1
limit,
there
is
a
99.9%
probability
that
the
value
could
be
between
zero
and
twice
the
value,
a
99%
probability
that
the
value
could
be
between
22%
of
the
value
and
1.5
times
the
value
and
a
90%
probability
that
the
value
could
be
between
0.57
of
the
value
and
1.4
times
the
value
The
EMC
guidance
also
indicates
that
values
less
than
ten
times
the
standard
deviation
of
the
blank
value
are
considered
to
be
below
the
limit
of
quantification.
At
the
limit
of
quantification,
there
is
a
99.9%
probability
that
the
measured
value
is
between
69%
and
130%
of
the
actual
value,
a
99%
probability
that
the
measured
value
is
between
77%
and
120%
of
the
actual
value
and
a
90%
probability
that
the
measured
value
is
between
87%
and
110%
of
the
actual
value.
Based
upon
the
reported
values,
two
of
the
three
samples
were
A­
5
between
the
limit
of
detection
and
the
limit
of
quantification.
As
a
result,
the
uncertainty
of
the
measured
emissions
is
greater
than
those
typically
used
to
quantify
a
sources
emissions.
In
addition,
some
of
the
reported
masses
are
questionable.
The
probe
catch
for
run
2
and
the
second
filter
catch
for
run
6
may
be
anomalies
when
compared
to
all
other
runs.
The
value
reported
for
the
probe
catch
for
run
2
appears
to
be
a
typographical
error
in
that
the
value
is
an
order
of
magnitude
higher
that
the
other
two
runs.
The
second
filter
catch
for
run
6
has
the
highest
weight
gain
of
all
the
second
filters
although
this
is
only
slightly
above
the
minimum
detection
limit.
If
these
two
anomalous
values
are
excluded,
all
three
tests
of
empty
ovens
would
be
between
the
detection
limit
and
the
quantification
limit.
The
average
emission
rate
for
emptyho
visible
leak
ovens
with
these
two
values
included
is
0.009
lbhr
(
0.004
kg/
hr)
but
with
these
two
values
excluded
is
0.005
Ibhr
(
0.002
kg/
hr).
The
average
emission
rate
for
emptyho
visible
leak
ovens
with
the
two
values
excluded
is
assigned
to
ovens
with
no
visible
emissions.
Because
these
emission
rates
are
based
on
test
data
that
are
somewhat
above
the
detection
limit
but
are
substantially
below
the
quantification
limit
the
uncertainty
associated
with
the
resulting
emission
factor
is
greater
than
most
source
test
based
emission
factors.
Quantitatively
the
uncertanties
are
closest
to
data
at
the
limit
of
detection.
Therefore,
a
footnote
will
be
included
in
the
emission
factor
that
indicates
the
high
degree
of
uncertainty
associated
with
the
non­
visibly
leaking
door
portion
of
the
emission
factor.

When
any
of
the
recommended
emission
factors
are
applied,
the
user
should
be
aware
that
there
is
a
significant
amount
of
uncertainty
in
the
estimate.
The
uncontrolled
emission
factor
is
based
upon
tests
of
two
batteries
with
significantly
different
performance
and
with
emission
rates
that
are
not
consistent
with
their
relative
visual
performance.
The
pre­
NESHAP
and
NESHAP
emission
factors
are
based
upon
more
data
that
is
more
consistent,
there
is
still
a
significant
amount
of
uncertainty.
For
the
EPA
Method
303
visible
leaks
portion
of
the
emission
factor,
there
are
no
data
available
on
the
distribution
of
sizes
among
door
leaks,
which
probably
include
both
small
and
large
leaks.
For
leaks
that
are
visible
from
the
bench
but
not
the
yard,
there
is
some
uncertainty
that
this
class
of
leaks
are
adequately
represented
by
the
measured
emissions
from
the
lowest
grade
of
leak.
Lastly
the
emission
estimates
for
doors
that
are
not
visibly
leaking
from
the
bench
are
quantified
by
only
four
test
runs
that
are
very
near
the
limit
of
detection
of
the
method
and
have
at
least
one
component
of
the
test
excluded
due
to
anomalous
values.
Therefore,
depending
on
the
number
of
leaks
and
the
typical
leak
sizes,
actual
emissions
from
a
given
Battery
may
be
several
times
higher
or
lower
than
the
estimate
provided
by
these
emission
factors.

For
leaks
from
lids
and
offtakes,
a
range
of
0.0075
to
0.048
Ib
BSOh
(
0.0033
to
0.021
kg
BSOh)
is
recommended
from
the
topside
test
measuring
a
0.3­
to
2­
meter
(
1­
to
6­
foot)
plume
in
Reference
8.
It
is
recommended
that
emissions
of
0.0075
Ib
BSOh
(
0.0033kg
BSOh)
be
used
for
the
NESHAP
level
of
control
and
that
emissions
of
0.048
lb
BSOh
(
0.021kg
BSOh)
be
used
for
the
pre­
NESHAP
level
of
control.
Lacking
other
data,
this
emission
rate
can
also
be
applied
to
other
leaks
on
the
topside
of
the
battery,
such
as
leaks
from
refractory
or
flue
caps.

Very
few
data
are
available
for
charging
emissions.
However,
visible
emission
observations
have
shown
that
the
implementation
of
stage
charging
over
the
past
20
years
has
resulted
in
dramatic
reductions
in
emissions.
When
charging
was
uncontrolled,
clouds
of
emissions
occurred
throughout
the
3­
to
5­
minute
charging
period
and
obscured
the
charging
car.
Today,
emissions
are
limited
to
a
few
seconds
per
charge
(
through
the
use
of
steam
aspiration
and
stage
charging)
and
are
characterized
primarily
as
wisps
or
puffs
of
emissions.
To
meet
the
current
NESHAP
limit
of
12
seconds
of
visible
emissions
per
charge,
most
batteries
will
need
to
average
about
10
seconds
of
emissions
per
charge.

A­
6
The
information
available
for
uncontrolled
charging
is
summarized
in
Table
4­
4.
The
recommended
emission
factor
for
filterable
PM
is
0.7
lb/
ton
of
coal
charged
(
0.35
kg/
Mg)
based
on
the
average
of
the
three
results
in
the
table.
To
estimate
controlled
emissions
from
charging,
the
NESHAP
background
document
(
Reference
9)
used
an
exponential
model
to
predict
mass
emissions
when
visible
emissions
are
reduced
to
a
few
seconds
per
charge
in
duration.
The
pre­
NESHAP
control
level
for
most
batteries
was
on
the
order
of
25
to
30
seconds
per
charge.
Reference
9
estimates
BSO
emissions
as
0.029
to
0.16
lb
BSO
(
13
to
75
g
BSO)
per
charge.
For
an
average
of
10
seconds
per
charge
(
NESHAP
level),
the
emissions
are
estimated
as
about
0.0001
to
0.018
Ib
BSO
(
0.06to
8.3
g
BSO)
per
charge.
These
estimates
of
emissions
from
charging
are
the
most
uncertain
of
the
estimates
in
this
section
and
are
further
complicated
by
the
expectation
that
charging
emissions
may
have
a
composition
somewhat
different
from
that
of
raw
coke
oven
gas.
In
addition,
if
occasional
uncontrolled
or
poorly­
controlled
charges
occur,
the
emission
rate
given
above
could
significantly
underestimate
the
quantity
of
emissions.
For
this
analysis,
a
midrange
value
of
0.0093
lb
BSO
per
charge
(
4.2
g
BSO
per
charge)
is
recommended
to
estimate
elmissions
from
batteries
controlled
at
the
NESHAP
level
when
they
are
averaging
about
10
seconds
of
visible
emissions
per
charge.
For
the
pre­
NESHAP
level,
a
midrange
estimate
of
0.097
lb
BSO
per
charge
(
44
g
BSO
per
charge)
is
recommended.
From
References
12
and
13,
the
BSO
emission
rate
is
estimated
as
1.2
times
the
filterable
PM
emission
rate.
One
Battery
in
the
U.
S.
uses
a
scrubber
to
capture
emissions
in
addition
to
stage
charging.
Reference
4
reports
an
emission
factor
of
0.014
lb/
ton
(
0.007
k@
g)
for
filterable
PM.

[
Note:
There
are
no
batteries
in
the
U.
S.
that
use
pipeline
charging,
and
no
batteries
are
expected
to
be
constructed
using
this
technology.
Consequently,
pipeline
charging
is
not
considered
in
this
analysis.
Currently
(
1993,
there
is
only
one
Battery
that
uses
a
scrubber
system
(
lime­
based)
for
charging
emissions
and
another
Battery
charges
dry
coal
with
a
Redler
conveyor.
However,
these
batteries
must
meet
the
NESHAP
limits
for
visible
emissions,
and
the
emission
estimates
given
above
should
also
apply
to
those
emissions
that
escape
capture
during
charging.]

A­
7
TABLE
4­
1.
SUMMARY
OF
1
VCONTROLLED
AND
CONTROLLED
DOOR
LEAK
EMISSIONS
No.
of
I
Emission
factor
I
Range
Rating
Filterable
PM
0.4­
1.0
0.72
D
Uncontrolled
0.2­
0.5
0.36
I
I
Filterable
PM
3
0.08­
0.8
0.44
D
Uncontrolled
0.04­
0.4
0.22
3
1
Filterable
PM
0.4­
0.9
0.57
D
Uncontrolled
0.2­
0.5
0.29
'
Condensible
0.1­
0.5
0.36
D
PM
0.05­
0.3
0.18
Uncontrolled
0.6­
0.7
0.62
D
BSO
0.3­
0.4
0.31
Uncontrolled
4
Filterable
PM
0.3­
0.5
Ib/
ton
D
166
Filterable
PM
0.066
Ib/
tonb
E
pre­
NESHAP
Controlled
0.02­
0.1
krngb
Uncontrolled
:::!
I
1
kg/
Mg
"
Based
on
Ib/
ton
or
kg/
Mg
of
coal
charged
unless
otherwise
specified.
bConvertedfrom
Ib/
ton
of
coke
pushed
using
factors
of
0.69
for
lb/
ton
and
0.345
for
kg/
Mg.

~
Percent
leaking
BSO
rate
per
door
Reference
doors
kg/
hr
Ibhr
Comment
29
0.58
1.3
Coke
side
shed
test
70
0.19
0.42
Coke
side
shed
test
5
0.0036­
0.041
0.008­
0.089
Model
predictiona
10
0.01­
0.12
0.02­
0.26
Model
predictiona
"
Model
prediction
estimates
from
reference
9
are
extrapolated
from
test
data
from
references
3
and
5.

A­
8
TABLE
4­
3.
DOOR
LEAK
EMISSIONS
DATA
Leak
categories
are
based
on
range
of
light
leaks
to
dense
leaks
with
0.5
as
the
leak
category
with
least
visible
or
intermittently
visible
leaks
and
4
as
the
leak
category
with
the
highest
density.
The
PM
incluldes
filterable
and
condensible
PM.
Two
BSO
emissions
rate
values
are
presented,
the
first
is
as
was
presented
in
the
test
report
which
used
three
times
the
average
blank
value
as
the
detection
limit,
the
second
(
revised)
uses
a
detection
limit
of
three
times
the
standard
deviationof
the
blank
values
for
test
reference
39
where
individual
blank
results
were
available
and
for
test
reference
7
recalculates
emission
rates
by
using
a
zero
weight
gain
for
filters
that
showed
weight
loss.
All
emissions
estimates
for
Catagory
0
leaks
are
highly
suspect
because
samples
were
near
the
detection
limit
and
anomolies
that
exist
with
individual
sample
portions.

A­
9
TABLE
4­
4.
DATA
FOR
UNCONTROLLEDCHARGING
Pollutant
FilterablePM
Benzene
soluble
organics
Condensible
PM
FilterablePM
FilterablePM
REFERENCES
FOR
SECTION4
Emission
factor
kglMg
lb/
ton
Rating
0.055
0.11
D
0.065
0.13
D
0.055
0.11
D
0.26
0.52
D
0.75
1.5
D
1.

2.

3.

4.

5.

6.

7.

8.

9.
Source
Testing
of
a
Stationary
Coke­
Side
Enclosure:
Great
Lakes
Carbon
Corporation,
St.
Louis,
MO,
EPA­
340/
1­
76­
014(
a)
and
(
b),
U.
S.
Environmental
Protection
Agency,
Washington,
DC,
August
1977.

Source
Testing
of
a
Stationary
Coke­
Side
Enclosure:
Bums
Harbor
Plant,
Bethlehem
Steel
Corporation,
Chesterton,
IN,
EPA­
340/
1­
76­
012,
U.
S.
Environmental
Protection
Agency,
Washington,
DC,
May
1977.

Emission
Testing
at
a
Byproduct
Coke
Oven
Battery,
WisconsinSteel,
Chicago,
IL,
EMB
77­
CKO­
11,
U.
S.
Environmental
Protection
Agency,
Washington,
DC,
May
1978.

Particulate
Emission
Factors
Applicable
to
the
Iron
and
Steel
Industry,
EPA­
45014­
79428,
U.
S.
Environmental
Protection
Agency,
Research
Triangle
Park,
NC,
September
1979.

Emission
Test
Report:
Annco
Steel,
Houston,
ZX.
EMB
79­
CKO­
22.
U.
S.
Environmental
Protection
Agency,
Research
Triangle
Park,
NC,
November
1979.

C.
Allen,
A
Model
to
Estimate
Hazardous
Emissionsfrom
Coke
Oven
Doors,
EPA
Contract
No.
68­
02­
1408,
Docket
Item
II­
A­
38
in
Docket
No.
A­
79­
15,
March
1980.

Final
Phase
I
Method
ValidationReportfor
Quantitative
Coke
Oven
Door
LeakMeasurement
Study,
ENSR
Consulting
and
Engineering,
for
American
Iron
and
Steel
Institute,
Washington,
DC.
December
1991.

Emission
Test
Report
­
US.
Steel
Corporation,
Clairton,
Pennsylvania,
EMB
Report
NO.
7
78­
CKO­
13.
TRW,
hc.
July
1980.

Coke
Oven
EmissionsfromWet­
CoalCharged
Byproduct
Coke
Oven
Batteries
­
Background
Informationfor
Proposed
Standards,
EPA­
450/
3­
85­
028aYU.
S.
EnvironmentalProtectionAgency,
Research
Triangle
Park,
NC.
April
1987.

A­
10
.
10.
Memorandum
from
Ackerman,
E.,
USEPA
Region
UI,
to
A.
Agnew,
EPNOAQPS.
Transmitting
information
on
bypassed
coke.
oven
gas.
April
8,1991.

11.
Coke
Owen
Gas
Study
Performed
for
Bethlehem
Steel
Corporation,
Mostardi­
Platt
Associates,
Inc.,
December
1992.

12.
R
W.
Bee
et
al,
Coke
Oven
Charging
Emission
Control
Test
Program,
EPA­
650/
2­
74­
062,
U.
S.
Environmental
Protection
Agency,
July
1974.

13.
A.
Trenholm
and
L.
Beck,
Assessment
ofHazardous
Organic
Emissionsfrom
Slot
Type
Coke
Oven
Batteries,
unpublished
paper,
U.
S.
Environmental
Protection
Agency,
Research
Triangle
Park,
NC,
March
1978.

39.
Draft
Final
Phase
I1Method
Validation
Report
for
Quantitative
Coke
Oven
Door
Leak
Measurement
Study,
ENSR
Consulting
and
Engineering,
for
American
Iron
and
Steel
Institute,
Washington,
DC.
January
1992.

181.
Sampling
and
Analysis
of
Coke­
Oven
Door
Emissions,
EPA­
600/
2­
77­
213,
U.
S.
Environmental
Protection
Agency,
Washington,
DC,
October
1977.

A­
1
1
APPENDIX
B.
EXCERPT
FROM
THE
BACKGROUND
INFORMATIONDOCUMENT
FOR
PUSHING,
QUENCHING,
AND
BATTERY
STACKS
United
States
OfficeOf
Air
Quaiity
EPA­
453/
R­
01­
006
Environmental
Protection
Planning
And
Standards
February
2001
Agency
ResearchTrianglePark,
NC
27711
FINAL
REPORT
Air
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
Coke
Ovens:
Pushing,
Quenching,
and
Battery
Stacks
­
Background
Information
for
Proposed
Standards
Final
Report
5.
ENVIRONMENTAL
IMPACTS
This
chapter
focuses
on
the
environmental
impacts
associated
with
achieving
the
MACT
level
of
control.
The
primary
impact
is
the
reduction
of
emissions
of
HAP
when
MACT
is
implemented.
Secondary
impacts,
such
as
the
generation
of
solid
waste
and
increased
energy
usage,
are
also
discussed.
Emission
reductions
of
HAP
are
expressed
in
terms
of
the
listed
HAP
 
coke
oven
emissions 
which
includes
a
variety
of
organic
compounds.
Methylene
chloride
extractables
is
used
as
a
surrogate
measure
for
coke
oven
emissions
and
includes
organic
particulate
matter
(
semivolatile
organics)
such
as
POM
and
PAH.

5.1
DERIVATION
OF
EMISSION
FACTORS
FOR
PUSHING
Coke
oven
emissions
from
pushing
originate
when
coal
has
not
been
completely
coked,

which
produces
 
green
coke. 
During
pushing
green
coke
generates
emissions
of
a
variety
of
volatile
and
semivolatile
organic
compounds
that
are
not
captured
or
controlled
effectively
by
pushing
emissions 
capture
and
control
systems.
Emissions
from
pushing
depend
on
the
frequency
and
extent
that
green
pushes
occur.
Some
of
the
best
controlled
batteries
have
very
few
green
pushes,
and
others
have
higher
levels
as
indicated
by
the
high
opacity
of
emissions
that
escape
capture.

The
EPA
conducted
tests
of
pushing
emissions
at
Bethlehem
Steel
(
Burns
Harbor,
IN) 

and
ABC
Coke
(
Birmingham,
AL)*.
These
two
plants
had
very
few
green
pushes
during
the
tests;
however,
the
results
can
be
used
to
derive
emission
factors
for
green
coke
and
coke
that
is
not
green.
Because
most
of
the
emissions
from
green
coke
are
not
captured
and
controlled,
the
actual
sampling
results
must
be
used
in
combination
with
estimates
of
capture
efficiency
and
the
number
of
green
pushes
observed
during
the
test
to
derive
emission
factors.

Table
5­
1
summarizes
the
results
for
the
test
conducted
at
Bethlehem
Steel.
There
were
three
pushes
during
Runs
1
and
3
that
were
characterized
as
partially
to
moderately
green
(
opacity
on
the
order
of
30%
to
50%
observed
during
the
push)
compared
to
six
pushes
of
a
similar
nature
during
Run
2.
The
emissions
of
the
pollutants
of
interest
were
highest
during
Run
2,
which
reflects
the
higher
emissions
from
these
moderately
green
pushes.
For
example,
the
5­
1
1
2
3
4
5
6
7
extractable
organics
during
Run
2
were
0.0057
lbhon
compared
to
an
average
of
0.0045
lb/
ton
during
Runs;
1
and
3.

TABLE
5­
1.
PAH
RESULTSFOR
PUSHING
­
BETHLEHEM,
BURNSHARBOR'

BAGHOUSE
INLET
(
Ib/
ton)
BAGHOUSE
OUTLET
7
PAH
Run1
Run2
Run3
Average
Benzo(
a);
mthracene
7.1E­
07
5.7E­
07
1.3E­
07
4.7E­
07
Benzo(
a)
pyrene
4.8E­
07
3.2E­
07
1.3E­
07
3.1E­
07
Benzo@)
jBuoranthene
5.9E­
06
6.1E­
06
3.
OE­
06
5.
OE­
06
Benzo(
k)
fluoranthene
2.3E­
06
2.3E­
06
8.5E­
07
1.8E­
06
Chrysene
4.3E­
06
4.4E­
06
1.9E­
06
3.6E­
06
Dibenzo(
a,
h)
anthracene
8.6E­
07
8.1E­
07
2.5E­
07
6.4E­
07
Ideno(
lY2,3­
cd)
pyrene
2.1E­
06
2.
OE­
06
4.6E­
07
1.5E­
06
Total
7
PAH
1.7E05
1.73­
05
6.73­
06
1.33­
05
16
PAH
8
Acenaphthene
5.4E­
07
3.5E­
07
5.4E­
07
4.8E­
07
9
Acenaphtliylene
4.3E­
06
4.4E­
06
2.7E­
06
3.8E­
06
10
Anthracene
5.7E­
07
5.1E­
07
6.5E­
07
5.8E­
07
11
Benzo(
gylnyi)
perylene
1.7E­
06
1.6E­
06
3.3E­
07
1.2E­
06
12
Fluoranthme
l.
lE­
05
1.3E­
05
6.8E­
06
1.
OE­
05
13
Fluorene
1.7E­
06
1.3E­
06
1.3E­
06
1.5E­
06
14
Naphthalene
2.1E­
05
2.6E­
05
2.9E­
05
2.5E­
05
15
Phenanthrene
1.6E­
05
1.9E­
05
2.
OE­
05
1.8E­
05
16
Pyrene
1.7E­
06
1.9E­
06
3.9E­
07
1.3E­
06
Taital
16
PAH
7.43­
05
8.43­
05
6.93­
05
7.63­
05
Other
PAH
2­
Methylnaphthalene
6.2E­
06
5.
OE­
06
3.1E­
06
4.7E­
06
Benzo(
e)
pyrene
1.6E­
06
1.4E­
06
4.
OE­
07
l.
lE­
06
Perylene
7.8E­
08
O.
OE+
OO
O.
OE+
OO
2.6E­
08
Total
Other
PAH
7.83­
06
6.43­
06
3.53­
06
5.93­
06
Total
­
all
PAH
8.23­
05
9.
OE­
05
7.23­
05
8.23­
05
Extractableorganics
(
Ib/
hr)
4.93­
03
5.73­
03
4.03­
03
4.93­
03
Number
of
moderately
green
pushes
3
6
3
Number
of
nongreen
pushes
43
41
39
Total
number
of
pushes
46
47
42
Percent
green
7
13
7
(
Ib/
ton)
Run1
Run2
Run3
Average
3.6E­
08
2.4E­
08
1.2E­
08
2.4E­
08
3.1E­
08
1.5E­
08
1.
OE­
08
1.9E­
08
4.7E­
08
3.4E­
08
1.9E­
08
3.4E­
08
4.4E­
08
1.8E­
08
1.3E­
08
2SE­
08
7.1E­
08
7.6E­
08
3.2E­
08
6.
OE­
08
9.1E­
09
O.
OE+
OO
O.
OE+
OO
3.
OE­
09
4.1E­
08
1.6E­
08
1.3E­
08
2.3E­
08
2.83­
07
1.8E­
07
9.93­
08
1.93­
07
9.1E­
08
6.6E­
08
4.9E­
08
6.9E­
08
1.9E­
07
1.5E­
07
1.7E­
07
1.7E­
07
5.5E­
08
2.1E­
08
1.
OE­
08
2.8E­
08
9.1E­
09
2.5E­
09
3.3E­
09
4.9E­
09
3.1E­
07
1.3E­
07
7.6E­
08
1.7E­
07
1.9E­
07
1.5E­
07
1.
OE­
07
1.5E­
07
4.7E­
06
4.8E­
06
4.7E­
06
4.7E­
06
7.6E­
07
5.2E­
07
3.1E­
07
5.3E­
07
1.8E­
07
9.8E­
08
4.9E­
08
1.1E­
07
6.83­
06
6­
13­
06
5.53­
06
6­
13­
06
1.
OE­
06
1.4E­
06
8.6E­
07
l.
lE­
06
3.1E­
08
1.8E­
08
1.2E­
08
2.
OE­
08
7.1E­
09
7.1E­
09
0.0Et­
00
4.7E­
09
l.
lE06
1.43­
06
8.73­
07
1.13­
06
7.9606
7.53­
06
6.43­
06
7.33­
06
3.1E­
03
2.43­
03
2.73­
03
2.73­
03
5­
2
The
results
for
ABC
Coke
are
given
in
Table
5­
2
and
show
that
there
were
4
green
pushes
identified
for
each
of
the
3
runs.
Most
of
these
pushes
were
moderately
green
(
inthe
range
of
30%

to
50%
opacity);
however,
during
Run
1,
a
severely
green
push
was
observed
that
had
an
opacity
on
the
order
of
95%
during
both
the
push
and
travel,
and
a
yellow
brown
plume
came
from
the
quench
tower
during
quenching.
The
oven
that
was
pushed
was
adjacent
to
an
oven
that
had
been
taken
out
of
service
for
repair.
The
effect
of
this
green
push
on
the
emissions
is
evident
with
emission
levels
two
to
three
times
higher
for
Run
1
than
for
the
other
runs.
For
example,
extractable
organics
during
Run
1
were
0.016
lb/
ton
compared
to
0.0078
lb/
ton
during
Runs
2
and
3.

TABLE5­
2.
PAH
RESULTS
FOR
PUSHING
­­
ABC
COKE 

BAGHOUSE
INLET
(
Ib/
ton)
BAGHOUSE
OUTLET
(
ib/
ton)
7
PAH
Run1
Run2
Run3
Average
Run1
Run2
Run3
Average
1
Benzo(
a)
anthracene
2.3E­
05
1.3E­
05
1SE­
05
1.7E­
05
4.7E­
07
3.7E­
07
3.7E­
07
4.
OE­
07
2
Benzo(
a)
pyrene
9.8E­
06
3.4E­
06
2.4E­
06
5.2E­
06
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
3
Benzo@)
fluoranthene
2.6E­
05
9.3E­
06
8.2E­
06
1.5E­
05
3.3E­
07
2.8E­
07
3.3E­
07
3.1E­
07
4
Benzo(
k)
fluoranthene
1.4E­
05
6.6E­
06
4.9E­
06
8.6E­
06
3.3E­
07
2.4E­
07
2.2E­
07
2.6E­
07
5
Chrysene
4.
OE­
05
2.1E­
05
2.4E­
05
2.9E­
05
1.2E­
06
9.8E­
07
l.
lE­
06
l.
lE­
06
6
Dibenzo(
a,
h)
anthracene
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
7
Ideno(
1,2,3­
cd)
pvrene
1.7E­
05
7.7E­
06
5.3E­
06
1.
OE­
05
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
Total
7
PAH
1.3E­
04
6.13­
05
6.
OE­
05
8.43­
05
2.33­
06
1.9E­
06
2.
OE­
06
2.1E­
06
16
PAH
8
Acenaphthene
2.3E­
05
7.7E­
06
8.5E­
06
1.3E­
05
l.
lE­
05
3.8E­
06
5.5E­
06
6.9E­
06
9
Acenaphthylene
1.4E­
04
6.4E­
05
4.5E­
05
8.2E­
05
8.1E­
05
3.4E­
05
2.7E­
05
4.7E­
05
10
Anthracene
2.5E­
05
7.7E­
06
1.2E­
05
1.5E­
05
3.3E­
05
5.
OE­
06
8.0E­
06
1SE­
05
11
Benzo(
g,
h,
i)
perylene
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
12
Fluoranthene
7.7E­
05
3.2E­
05
3.4E­
05
4.8E­
05
3.3E­
05
5.
OE­
06
8.
OE­
06
1SE­
05
13
Fluorene
5.3E­
06
2.9E­
05
2.4E­
05
1.9E­
05
3.4E­
05
l.
lE­
05
1.4E­
05
2.
OE­
05
14
Naphthalene
5.6E­
04
2.1E­
04
2.2E­
04
3.3E­
04
4.7E­
04
1.4E­
04
1.7E­
04
2.6E­
04
15
Phenanthrene
2.5E­
04
9.5E­
05
8.9E­
05
1.4E­
04
l.
lE­
04
6.9E­
05
4.2E­
05
7.3E­
05
16
Pyrene
5.1E­
05
2.3E­
05
2.4E­
05
3.3E­
05
2.6E­
05
1.2E­
05
1.
OE­
05
1.6E­
05
Total
16
PAH
1.3E­
03
5.33­
04
5.1E­
04
7.73­
04
8.03­
04
2.93­
04
2.93­
04
4.63­
04
Other
PAH
2­
Methylnaphthalene
1.2E­
04
4.3E­
05
5.5E­
05
7.2E­
05
8.9E­
05
3.7E­
05
5.6E­
05
6.1E­
05
Benzo(
e)
pyene
1.
OE­
05
4.6E­
06
4.5E­
06
6.4E­
06
2.1E­
07
O.
OE+
OO
1.7E­
07
1.3E­
07
Perylene
1.7E­
06
5.
OE­
07
3.8E­
07
8.6E­
07
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OEt­
00
Total
Other
PAH
1­
33­
04
4.83­
05
6.03­
05
7­
93­
05
9.03­
05
3.73­
05
5­
63­
05
6.1E­
05
Total
­
all
PAH
1.4E­
03
5.83­
04
5.73­
04
8.43­
04
8.93­
04
3.23­
04
3.43­
04
5.2E­
04
Extractable
organics
(
lbhr)
1.6E­
02
9.83­
03
5.83­
03
1.
OE­
02
2.43­
02
4.93­
03
2.43­
03
1.
OE­
02
Number
of
severely
green
pushes
1
0
0
Number
of
moderately
green
pushes
3
4
4
Number
of
nongreen
pushes
17
17
18
Total
number
of
pushes
21
21
22
Percent
green
19
19
18
5­
3
5.1,1
Derivation
of
an
Emission
Factor
from
the
Bethlehem
Steel
Test
Results
The
Bethlehem
Steel
results
were
used
to
derive
an
emission
factor
for
moderately
green
pushes.
This
estimate
assumes
a
capture
efficiency
of
90%
for
non­
green
pushes
and
40%
for
moderately
green
pushes.
An
example
is
given
below
for
the
extractable
organics
and
involves
solving
two
independent
equations
with
two
unknowns.

During
Run
2,
six
pushes
were
moderately
green
and
4
1
were
not;
the
emission
rate
was
0.0057
lb/
t.

0
During
Runs
1
and
3,
three
pushes
were
moderately
green
and
41
(
average)
were
not;
the
emission
rate
averaged
0.0045
lb/
t.

0
Let
 ,
x 
equal
the
emission
factor
foruncontrollednon­
green
pushes
and
  
y 
the
emission
factor
for
uncontrolled
moderately
green
pushes.

Equations
cam
be
written
for
the
test
runs
based
on
the
number
of
each
type
of
push
and
the
capture
efficiencyfor
each
type,
which
corresponds
to
what
was
captured
and
measured
at
the
baghouse
inlet.
The
equation
for
Run
2
(
for
extractable
organicsmeasured
at
the
baghouse
inlet)

is:

[(
41)(
0.9)(
x)+
(
6)(.
4)(
y)]/
47
=
0.0057
lb/
t
or
36.9
x
+
2.4
y
=
0.27
Equation
(
1)

The
equation
for
Runs
1
and
3
is:

[(
41)(
0.9)(
x)
+
(
3)(.
4)(
y)]/
44
=
0.0045
lb/
t
or
36.9
x
+
1.2
y
=
0.20
Equation
(
2)

5­
4
Solving
the
Equations
(
1)
and
(
2)
for
x
and
y
yields:

x
=
0.0035
lb/
t
(
uncontrolled
non­
green
pushes)

y
=
0.058
lb/
t
(
uncontrolled
moderately
green
pushes).

The
procedure
was
repeated
for
the
other
pollutants
of
interest
with
the
results
in
Table
5­
3.

TABLE
5­
3.
EMISSION
FACTORS
FROM
THE
BETHLEHEM
STEEL
TEST
Pollutant
Ib/
t
for
non­
green
Ib/
t
for
moderately
green
Ratio
7
PAH
6.7
x
lo4
2.3
x
10 
34
16
PAH
6.4
x
lo5
6.7~
10 
10
~~

Extractable
organics
3.5
10­
3
I
5.8
x
lo­*
16
The
ratios
in
the
table
indicate
that
the
emissions
from
moderately
green
pushes
are
on
the
order
of
10
to
34
times
higher
than
those
of
non­
green
pushes.

5.1.2
Derivation
of
an
Emission
Factor
from
the
ABC
Coke
Test
Results
An
approach
similar
to
that
used
for
the
Bethlehem
Steel
test
was
used
to
derive
an
estimate
of
the
contribution
of
green
pushes
to
overall
emissions
from
the
ABC
Coke
test.
In
this
case,
three
equations
and
three
unknowns
were
used
for
the
7­
PAH
and
16­
PAH
to
derive
emission
factors
for
non­
green,
moderately
green,
and
severely
green
pushes.
An
example
is
given
below
for
the
7­
PAH
and
assumes
a
capture
efficiency
of
90%
for
the
non­
green
pushes,

40%
for
the
moderately
green
pushes,
and
10%
for
the
severely
green
push.

0
Let
 
x 
equal
the
uncontrolled
emissions
in
lb/
ton
for
the
non­
green
pushes.

0
Let
 
y)
equal
the
uncontrolled
emissions
in
lb/
ton
for
the
moderately
green
pushes.

0
Let
 
z 
equal
the
uncontrolled
emissions
in
lb/
ton
for
the
severely
green
push
during
Run
1.

0
The
emissions
of
7­
PAH
were
1.3
E­
4,6.1
E­
5,
and
6.0
E­
5
lb/
ton
for
Runs
1,2,
and
3,
respectively.

5­
5
The
equation
for
Run
1
with
17
non­
green
pushes,
3
moderately
green
pushes,
and
1
severely
green
push
is:

[(
17)(
0.9)(
x)+
(
3)(
0.4)(
y)
+
(
1)(
0.1)(~)]/
21=
0.00013
lb/
ton
or
15.3
x
+
1.2
y
+
0.1
z
=
0.00273
Equation
(
1)

The
equation
for
Run
2
with
17
non­
green
pushes
and
4
moderately
green
pushes
is:

[(
17)(
0.9)(
x)+
(
4)(
0.4)(~)]/
21=
0.000061
lb/
ton
or
15.3
x
+
1.6
y=
0.00128
Equation
(
2)

The
equation
for
Run
3
with
18
non­
green
pushes
and
4
moderately
green
pushes
is:

or
[(
18)(
0.9>(
x)+
(
4)(
0.4)(~)]/
21=
0.000060
lb/
ton
16.2
x
+,
1.6
y
=
0.00126
Equation
(
3)

Solving
Equations
(
l),
(
2),
and
(
3)
for
x,
y,
and
z
yields
the
following
emission
factors
for
the
7­
PAH:

x
=
4.3
E­
5for
non­
green
pushes
y
=
3.0
E­
4
for
moderately
green
pushes
z
=
1.6
E­
2
for
severelygreen
pushes.

The
procedure
was
repeated
to
derive
emission
factors
for
the
16­
PAH.
Thisapproach
could
not
be
used
for
,
the
extractable
organics
for
ABC
Coke
because
of
the
anomalous
results
for
Run2,

which
appear
to
be
highby
a
factor
of
twobased
on
the
7­
PAH
and
16­
PAH
results.
For
example,
the
16­
PAH
were
8%
to
9%
of
the
extractable
organics
for
Runs
1
and
3
compared
to
about
5%
for
Run
2.
A
similar
discrepancy
is
seen
with
the
7­
PAH
results.
Consequently,

emission
factors
for
extractable
organics
were
derived
based
on
a
ratio
of
0.08
for
16­

PAH:
extractables.
Results
for
both
of
the
tests
are
summarized
in
Table
5­
4.
.

5­
6
iPAH
Pollutant
Non­
green
Moderately
green
Severely
green
BSC
ABC
BSC
ABC
ABC
6.4
E­
5
1.0
E­
4
6.7
E­
4
6.0
E­
3
1.9
E­
1
3.5
E­
3
6.7
E­
6
I
4.3
E­
5
I
2.3
E­
4
I
3.9E­
4
I
7­
PAH
I
6.7E­
3.9
E­
I
1.6
E­
2
I
16­
PAH
Extractables
1.3
E­
3
5.8
E­
2
7.5
E­
2
2.3
5.1.3
Frequency
of
Green
Pushes
Information
on
the
frequency
of
green
pushes
at
different
batteries
is
needed
to
use
the
emission
factors
derived
in
the
previous
section.
A
model
battery
approach
is
developed
here
because
pushing
data
are
not
available
for
every
battery.
Based
on
the
data
available,
individual
batteries
are
classifiedBs:
(
1)
batteries
currently
operate
at
the
MACT
level
of
control
(
Group
l),

(
2)
batteries
that
will
require
moderate
improvement
to
achieve
MACT
(
Group
2),
and
(
3)
batteries
that
will
have
to
achieve
significant
reductions
in
green
pushes
to
achieve
MACT
(
Group
3).

Data
for
several
batteries
show
green
pushes
occur,
even
on
batteries
that
are
among
the
best
controlled.
However,
severely
green
pushes
with
opacity
greater
than
50%
are
rare
for
well­

controlled
batteries.
For
example,
our
database
shows
that
16
well
controlled
batteries
exceeded
50%
opacity
only
once
in
3,700
observations.
For
the
model
battery
approach,
we
will
use
a
conservative
estimate
of
0.5%
severely
green
pushes
for
the
Group
1
batteries
(
MACT
level
of
control).
For
moderately
green
pushes
in
the
range
of
30%
to
50%
opacity,
the
well­
controlled
batteries
averaged
0%
to
about
5%
of
the
pushes
in
this
range.
We
will
use
a
conservative
estimate
of
5%
green
pushes
for
the
Group
1
batteries.

Two
batteries
that
are
less
well
controlled
(
USS
Clairton
Batteries
19
and
20)
averaged
2%
of
the
pushes
over
50%
opacity.
An
estimate
of
2%
severely
green
pushes
(
over
50%

opacity)
was
chosen
for
this
analysis
to
develop
conservative
estimates
of
emissions
for
Group
2
batteries
(
moderate
improvement
required).
For
these
same
two
batteries,
about
15%
of
the
pushes
were
in
the
range
of
30%
to
50%
opacity
(
moderately
green).
Similarly,
at
Tonawanda
5­
7
Coke
about
:
20%
of
the
pushes
were
in
the
range
of
30%
to
50%
opacity.
For
this
analysis,
a
conservative:
value
of
20%
moderately
green
pushes
was
used
for
Group
2
batteries.

Data
for
Gulf
States
Steel
from
the
observation
of
275
pushes
were
used
to
characterize
the
frequency
of
green
pushes
for
Group
3
batteries.
Approximately
20%
of
the
pushes
averaged
over
50%
opacity,
and
35%
were
in
the
range
of
30%
to
50%
opacity.

The
distribution
of
pushes
for
the
three
groups
is
summarized
in
Table
5­
5.

Group
Percent
of
pushes
in
each
category
Severely
green
Moderately
green
Non­
green
 
1
0.5
5
94.5
2
2
20
78
3
20
35
45
5.1.4
Estimates
of
Nationwide
Emissions
The
approach
to
estimate
nationwide
emissions
for
pushes
is
based
on
developing
emission
factors
for
each
type
or
group
of
battery,
assigning
each
actual
battery
to
one
of
the
groups,
and
summing
emissions
across
batteries.
The
average
emission
factors
for
extractable
organics
from
the
tests
at
ABC
Coke
and
Bethlehem
Steel
are
summarized
in
Table
5­
6.

TABLE
5­
6.
.
AVERAGE
UNCONTROLLED
EMISSION
FACTORS
FOR
PUSHING
I
Type
Extractable
organics
(
Ib/
ton
of
coke)

INon­
green
0.0024
0.067
Severely
green
2.3
5­
8
I
­
The
emission
estimates
are
based
on
the
following
assumptions:

0
A
non­
green
push
is
defined
as
one
with
an
average
opacity
less
than
30%,
moderately
green
is
30%
to
less
than
50%,
and
severely
green
is
50%
or
greater.

0
For
batteries
that
have
capture
and
control,
capture
efficiencies
are
assumed
to
be
90%
for
non­
green,
40%
for
moderately
green,
and
10%
for
severely
green
pushes.

0
Emissions
from
the
control
device
are
estimated
as
0.0064
lbhon
from.
the
average
of
the
test
results
at
Bethlehem
Steel
and
ABC
Coke
(
0.0027
and
0.01
lb/
ton,
respectively).

An
emission
factor
for
the
Group
1batteries
is
estimated
as
follows:

(
1)
Emissions
from
non­
green
pushes:

Fraction
non­
green
x
emissionfactorfor
non­
greenpushes
xfiaction
not
captured
=

0.945
x
0.0024
lb/
tonx
(
1
­
0.9)
=
0.0002
Zb/
ton
(
2)
Emissions
from
moderately
green
pushes:

Fraction
moderately
green
x
emissionfactorfor
moderately
greenpushes
x
fraction
not
captured
0.05
x
0.067
lb/
ton
x
(
1
­
0.6)
=
0.0013
Ib/
ton
(
3)
Emissions
from
severely
green
pushes:

Fraction
severely
green
x
emissionfactorfor
severely
green
pushes
xfiaction
not
captured
=

0.005
x
2.3
lb/
tonx
(
1
­
0.1)=
0.010
lb/
ton
(
4)
Emissions
from
the
control
device:

0.0064
Ib/
ton
(
5)
Total
for
Group
1:

0,0002
+
0.0013
+
0.010
+
0.0064
=
0.018
lb/
ton.

A
similar
procedure
was
used
for
the
other
groups
to
develop
the
emission
factors
given
in
Table
5­
7.
Some
batteries
in
Group
2
do
not
have
capture
and
controls
for
pushing
emissions;

consequently,
emission
factors
were
developed
for
both
the
controlled
and
uncontrolled
cases.

None
of
the
batteries
inGroup
3
have
capture
and
control;
therefore,
only
uncontrolled
emission
factors
were
developed
for
this
group.

5­
9
Group
1
­
controlled
2
­
controlled
2
­
uncontrolled
3
­
uncontrolled
Extractable
organic
emissions
(
lb/
ton)

0.018
0.053
0.061
0.48
Each
battery
was
assigned
to
one
of
the
groups
listed
in
Table
5­
7
based
on
pushing
emissions
data,
a
best
guess
when
no
data
were
available,
and
the
presence
or
absence
of
a
capture
and
control
system.
The
emission
factors
were
then
applied
to
each
plant
to
estimate
emissions.
The
emission
estimates,
assignments,
and
emission
factors
are
given
in
Table
5­
8.

5.2
EMIlSSIQNS
FROM
BATTERY
STACKS
Estimates
of
emissions
of
extractable
organics
from
battery
stacks
are
based
on
the
tests
conducted
by
EPA.
The
test
results
are
summarized
in
Tables
5­
10
and
5­
11
for
Bethlehem
Steel
(
Burns
Harbor,
IN)
and
ABC
Coke
(
Birmingham,
AL),
respectively.
The
results
are
reasonably
consistent
except
for
Run
3
at
Burns
Harbor.
This
run
had
about
10
times
more
naphthalene
and
3
times
more
extractable
organics
than
the
other
runs.
In
addition,
the
extractable
organics
were
20
to
30
times
higher
at
Bethlehem
Steel,
but
the
PAHwere
the
same
order
of
magnitude
as
at
ABC
Coke.
These
results
indicate
that
extractable
organics
are
not
a
good
surrogate
for
POM
for
the
Bethlehem
test
because
it
may
include
compounds
that
are
not
POM
or
PAH.
Consequently,

emission
estimates
for
battery
stacks
are
based
on
the
test
results
for
ABC
Coke
to
avoid
overestimating
emissions
if
the
Bethlehem
Steel
test
results
were
used.

5.2.1
Relationship
Between
Opacity
and
Concentration
The
theoretical
relationship
between
opacity
expressed
as
a
fraction
(
Op)
and
mass
concentration
(
C)
is
given
by
Equation
13*
4:

C
=­
In
(
1.0
­
Op)/
constant
Equation
(
I)

5­
10
TABLE
5­
8.
NATIONWIDE
ESTIMATES
OF
EXTRACTABLE
ORGANICS
EMISSIONSFROM
PUSHING
Plant
TABLE
5­
9.
CONCENTRATION
ADJUSTMENTSFOR
OPACITY
Opacity
(
YO)

1.7
5
10
15
­
In
(
1
­
Opacity/
l00)
Ratio
to
1.7%
opacity
1.7
1
5.1
3
10.5
6.2
16
9.4
5­
1
1
1
2
3
4
5
6
7
TABLE
5­
10.
TEST
RESULTSFOR
STACKS
­­
BETHLEHEM,
BURNS
HARBOR'

7
PAHs
Benzo(
a)
anthracene
Benzo(
a)
pyrene
Benzo(
b)
fluoranthene
Benzo(
k)
fluoranthene
Chrysene
Dibenzo(
a,
h)
anthracene
Ide:
no(
1,2,3­
cd)
pyrene
Total
7
PAHs
16
PAHs
8
Acenaphthene
9
Aclenaphthylene
10
Anthracene
11
Beizo(
g,
h,
i)
perylene
12
Fluoranthene
13
Fluorene
14
Naphthalene
15
Phenanthrene
16
Pyrene
Total
16
PAHs
Other
PAHs
2­
Methylnaphthalene
Benzo(
e)
pyrene
Perylene
Total
Other
PAHs
Total
­
all
PAHs
Extractable
Organics
(
Iblhr)
Average
Opacity
(
9'
0)
EMISSIONS
(
Ibhr)
Run1
Run2
Run3
Average
5.5E­
06
3.
OE­
06
7.4E­
06
5.3E­
06
5.8E­
06
2.9E­
06
3.3E­
06
4.
OE­
06
9.3E­
06
5.5E­
06
6.6E­
06
7.1E­
06
6.1E­
06
3.8E­
06
4.
OE­
06
4.6E­
06
1SE­
05
7.2E­
06
1.6E­
05
1.3E­
05
1SE­
06
O.
OE+
OO
O.
OE+
OO
4.9E­
07
5.4E­
06
3.9E­
06
3.6E­
06
4.3E­
06
4.83­
05
2.6E­
05
4.1E­
05
3­
93­
05
2.3E­
05
1.3E­
05
4.6E­
05
2.8E­
05
1.2E­
04
3.5E­
05
2.7E­
04
1.4E­
04
6.3E­
06
2.4E­
06
8.9E­
06
5.8E­
06
1.
OE­
05
9.5E­
06
6.5E­
06
8.6E­
06
5.3E­
05
2.7E­
05
6.4E­
05
4.8E­
05
1.
OE­
04
2.8E­
05
1.3E­
04
8.7E­
05
1.3E­
03
3.7E­
03
1.9E­
02
7.8E­
03
1.9E­
04
8.6E­
05
1.7E­
04
1.5E­
04
2.1E­
05
9.7E­
06
2.3E­
05
1.8E­
05
1.9E­
03
3.93­
03
1.9E­
02
8.43­
03
7.1E­
04
2.4E­
04
8.4E­
04
6.
OE­
04
5.2E­
06
3.9E­
06
3.5E­
06
4.2E­
06
1.5E­
06
O.
OE+
OO
O.
OE+
OO
4.9E­
07
7.1E04
2.43­
04
8.43­
04
6.0E­
04
2.63­
03
4.23­
03
2.
OE­
02
9.
OE­
03
~
~~

4.5
3.7
12.4
6.9
4.7
5.8
4.7
5.1
5­
12
7
1
2
3
4
5
6
TABLE
5­
11.
TEST
RESULTS
FOR
STACKS
­­
ABC
COKE2
7
PAHs
Benzo(
a)
anthracene
Benzo(
a)
pyrene
Benzo(
b)
fluoranthene
Benzo(
k)
fluoranthene
Chrysene
Dibenzo(
a,
h)
anthracene
Ideno(
ly2,3­
cd)
pyrene
Total
7
PAHs
16
PAHs
8
Acenaphthene
9
Acenaphthylene
10
Anthracene
11
Benzo(
g,
h,
i)
perylene
12
Fluoranthene
13
Fluorene
14
Naphthalene
15
Phenanthrene
16
Pyrene
Total
16
PAHs
Other
PAHs
2­
Methylnaphthalene
Benzo(
e)
pyrene
Perylene
Total
Other
PAHs
Total
­
all
PAHs
Extractable
Organics
(
Ibhr)
Average
Opacity
(
YO)
EMISSIONS
(
lb/
hr)
Run
1
Run2
Run3
Run4
Average
8.6E­
06
4.7E­
06
O.
OE+
OO
7.2E­
06
5.
lE­
06
1.2E­
05
9.9E­
06
O.
OE+
OO
7.7E­
06
7.5E­
06
1.5E­
05
2.
OE­
05
l.
lE­
05
1.3E­
05
1.4E­
05
O.
OE+
OO
1.2E­
07
O.
OE+
OO
1.4E­
07
6.4E­
08
2.
OE­
05
2.2E­
05
1.5E­
05
2.5E­
05
2.
OE­
05
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
5.63­
05
5.63­
05
2.53­
05
5.33­
05
4­
73­
05
1.5E­
05
1.1E­
05
6.
OE­
06
1.2E­
05
1.1E­
05
8.6E­
04
3.2E­
03
6.5E­
04
O.
OE+
OO
1.2E­
03
3.3E­
07
4.
lE­
07
l.
lE­
05
3.6E­
07
3.
OE­
06
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
2.9E­
04
5.6E­
04
2.4E­
04
3.4E­
04
3.6E­
04
5.
OE­
05
3.2E­
05
1.8E­
05
6.3E­
05
4.1E­
05
5.3E­
03
6.1E­
03
3.8E­
03
4.8E­
03
5.
OE­
03
5.9E­
04
9.4E­
04
4.9E­
04
8.5E­
05
5.3E­
04
1.5E­
04
9.9E­
04
1.7E­
04
2.2E­
04
3.8E­
04
7.33­
03
1.2E02
5.43­
03
5.53133
7.53.03
1.5E­
04
l.
lE­
04
7.9E­
05
2.1E­
04
1.4E­
04
1.6E­
05
6.6E­
05
1.8E­
05
1.4E­
05
2.8E­
05
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
O.
OE+
OO
1.7E­
04
1.8E­
04
9.73­
05
2.23­
04
1.7E­
04
7.53­
03
1.2E­
02
5.53­
03
5­
73­
03
7.73.03
0.23
0.20
0.36
0.09
0.22
1.8
1.6
2.8
0.7
1.7
By
applying
Taylor s
expansion;
the
equation
reduces
to
a
linear
relationship
between
opacity
and
concentration
for
dilute
concentrations(
low
opacities):

C=
constant
x
Op.
Equation
(
2)

The
stack
opacity
at
ABC
Coke
averaged
only
1.7%;
consequently,
an
adjustment
must
be
made
when
extrapolating
the
results
to
batteries
with
higher
opacitiesto
reflect
the
higher
concentrations.
The
concentration
adjustments
for
batteries
with
opacities
of
5%,
lo%,
and
15%

are
given
in
Table
5­
9
and
are
based
on
the
relationship
in
Equation
1.

5­
13
For
example,
if
the
AE3C
Coke
test
results
are
extrapolated
to
a
battery
with
15%
opacity,
the
ABC
Coke
emission
rate
is
multiplied
by
9.4
to
adjust
for
the
higher
concentration
when
the
opacity
is
15%.

5.2.2
Adjustment
for
Volumetric
Flow
Rate
The
adjustment
for
opacity
corrects
the
mass
concentration.
However,
the
mass
emission
rate
is
the
prloduct
of
concentration
and
volumetric
flow
rate.
Therefore,
an
adjustment
must
be
made
for
volumetric
flow
rate
when
extrapolating
the
results
to
another
battery.
For
example,
the
volumetric
flow
rate
at
ABC
Coke
was
83,000
ach.
If
the
results
are
used
to
estimate
mass
emissions
from
a
battery
with
a
stack
flow
rate
of
150,000
acfm,
the
mass
emission
rate
(
in
lbh)

for
ABC
Coke
are
multiplied
by
150,000/
83,000or
1.8.

5.2.3
Extrapolation
to
Other
Batteries
Infonnation
on
stack
opacity
and
volumetric
flow
rate
are
needed
to
extrapolate
the
results
from
Ithe
test
at
ABC
Coke
to
other
batteries.
Data
are
available
on
stack
gas
flow
rate
from
an
EPA
survey
of
the
industry.
However,
only
limited
data
are
available
on
stack
opacity.

Table
5­
12
summarizes
the
average
stack
opacity
from
batteries
that
provided
data
collected
by
COMS.
These
data
are
used
to
develop
typical
opacity
levels
for
two
conditions:
(
1)
the
baseline
level
with
no
MACT
standard
and
(
2)
the
level
after
MACT
is
in
place.
For
this
analysis,
a
typical
value
of
10%
is
used
as
the
baseline
for
batteries
not
at
the
MACTlevel
based
on
the
range
of
7.5%
to
10.5%
at
USS
Gary.

The
results
in
Table
5­
12
for
the
USS
Clairton
and
Bethlehem
Steel
(
Burns
Harbor)

batteries
are
used
to
estimate
the
level
achievable
by
MACT.
The
average
opacityranges
from
1.5%
to
4.5%.
For
this
analysis,
a
conservative
estimate
of
5%
opacity
is
used
to
estimate
the
performance
level
that
will
be
achieved
by
MACT.

An
example
calculation
is
given
below
for
Acme
Steel
Battery
1
with
an
assumed
baseline
opacity
of
10%
and
a
volumetric
flow
rate
of
30,000
cfin.

0.22
lbhr
(
ABC)
x
6.2
(
adjustmentfor
10%
opacit&[(
30,000
acfm)+(
ABC
acfm
of
83,000)]
=

0.49
lbhr
=
2.2tpy
5­
14
A
similar
procedure
was
used
for
the
other
batteries
to
give
the
results
shown
in
Table
5­
13.

Plant
Battery
USS
Gary
2
3
5
7
Range
(
baselinebefore
MACT)
1.

USS
Clairton
13
14
15
20
Average
opacity
("/
I
10.5
8.8
7.5
9.6
7.5
to
10.5
2.1
1.8
2.9
1.5
~~
~
~

B
4.3
Bethlehem,
Burns
Harbor
1
4.5
2
3.8
Range
(
after
MACT)
1.5
to
4.5
Dates
3/
97
through
6/
98
3/
97
through
6/
98
3/
97
through
6/
98
3/
97
through
6/
98
1/
99
through
3/
99
1/
99through
3/
99
1/
99
through
3/
99
1/
99
through
3/
99
1/
99
through
3/
99
8/
93
through
7/
99
12/
94through7/
99
5­
15
I
TABLE
5­
13.
ESTIMATES
OF
EXTRACTABLE
ORGANIC
EMISSIONS
FROM
BATTERY
STACKS
Koppers,
Monessen,
PA
2
19,196­
1.4
0.7
LW
Steel,
Chicago,
IL
2
94,280
6.8
3.3
LTV
Steel,
Warren,
OH
4
187,170
13.5
6.5
National
Steel,
Ecorse,
MI
5
343,000
24.7
11.9
National
Steel,
Granite
City,
IL
A
83,700
6.0
2.9
National
Steel,
Granite
City,
IL
B
103,700
7.5
3.6
New
Boston,
Portsmouth,
OH*
2
35,000
2.5
1.2
Shenango,
Pittsburgh,
PA
1
101,000
7.3
3.5
Sloss
Industries,
Birmingham,
AL*
3&
4
85,000
6.1
3.0
Sloss
Industries,
Birmingham,
AL*
5
85,000
6.1
3.0
Tonawanda,
Buffalo,
NY
2
97,000
7.0
3.4
USS,
Clairtm,
PA
1
82,100
2.9
2.9
USS,
Clairtm,
PA
2
90,750
3.2
3.2
USS,
Clairtm,
PA
3
74,150
2.6
2.6
5­
16
TABLE
5­
13.
ESTIMATES
OF
EXTRACTABLE
ORGANIC
EMISSIONS
FROM
BATTERY
STACKS
(
continued)

Extractable
organic
Plant
Wheeling­
Pittsburgh,
East
Steubenville,
WV*
3
37,000
2.7
Wheeling­
Pittsburgh,
East
Steubenville,
WV*
8
164,000
11.8
TOTALS
337
*
Volumetric
flow
rate
was
estimated
from
the
industry
average
of
0.3
acfin/
tpy
coke.

5­
17
1.3
5.7
195
5.3
EMISSIONS
FROM
QUENCHING
5.3.1
HAP
Data
for
Quenching
The
most
useful
test
report
for
quenching
was
from
testing
performed
at
US
Steel's
coke
plant
in
Lorain,
Ohio,
in
1977by
York
Research
under
contract
to
EPA.'
The
testing
included
15
runs
(
four
to
six
quenches
per
run)­­
six
runs
for
quenching
using
clean
quench
water
with
nongreen
coke,
:
fivewith
clean
water
when
green
coke
was
quenched,
and
four
using
contaminated
water
(
flushing
liquor
from
the
byproduct
plant)
with
non­
green
coke.
The
analyses
focused
on
organic
compounds,
especially
PAH;
results
were
also
obtained
for
BSO,
PM,
and
benzene.

The
test
results
are
summarized
in
Table
5­
14.
The
major
HAP
were
PAH,
including
BaP,
both
of
which
are
indicators
of
coke
oven
emissions.
The
PAH
found
in
the
greatest
quantity
was
naphthalene.
Dirty
water
(
from
the
coke
by­
product
plant)
was
the
major
contributor
l,
oemissions
of
organic
compounds
during
quenching;
however,
most
plants
no
longer
use
contaminated
water.
Grab
samples
taken
for
benzene
showed
low
levels
of
0.01to
0.13
g/
Mg
of
coal
(
0.005
to
0.04
ppm);
total
hydrocarbons
ranged
from
30
to
60
g/
Mg
(
8.5
to
17
PPm).
The
report
indicated
that
a
great
deal
of
effort
went
into
identifylng
and
trying
to
solve
potential
sampling
problems,
including
the
use
of
a
high
volume
sampler
(
because
of
the
short
duration
of
quenches),
obtaining
a
velocity
profile
(
velocity
varies
with
time),
using
a
sorbent
trap
in
the
back
half
of
the
train
to
capture
organics,
and
training
of
observers
to
identify
and
grade
green
pushes.
However,
some
reviewers
commented
that
the
PM
results
are
not
representative
of
most
quench
towers
and
should
be
used
only
for
tallquench
towers.
The
Lorain
tower
was
very
tall
(
sampling
was
performed
95
feet
above
the
ground),
it
had
missing
baffles,

and
the
steam
plume
velocity
was
higher.

The
test
report
confirmed
that
the
PM
emissions
contained
more
larger
particles,
captured
in
the
cyclone
that
preceded
the
filter,
than
had
been
seen
in
previous
tests.
Thisprobably
resulted
from
an
open
area
where
baffles
were
missing.
However,
the
report
noted
that
the
PAH
were
almost
all
found
in
the
sorbent
trap,
which
indicated
that
they
were
in
vapor
form
or
were
particles
less
than
0.3
microns.
Consequently,
the
concerns
expressed
about
the
PM
do
not
5­
18
apply
to
the
organics.
In
summary,
the
test
report
provides
the
only
useful
information
found
with
which
tlo
estimate
HAP
emissions
fiom
quenching.

5.3.2
Extraipolation
to
Other
Batteries
The
estimates
of
quenching
emissions
are
based
on
the
EPA
tests
at
the
USS
Lorain
coke
plant
and
the:
results
for
the
16­
PAHs
in
Table
5­
14.
The
16­
PAH
are
assumed
to
be
8%
of
the
EOM
based
on
the
pushing
test
results
for
ABC
Coke:

For
non­
green
pushes
and
clean
water:

16­
PAH
(
lbhon
coal)
=
0.29
g/
Mg
x
0.002
(
g/
Mg
to
lbhon)
=
0.00058
EOM
(
lb/
ton
coal)
=
0.00058
+
0.08
=
0.007
For
green
pushes
and
clean
water:

16­
PAH
(
lbhon
coal)
=
0.68
g/
Mg
x
0.002
(
g/
Mg
to
lb/
ton)
=
0.0014
EOM
(
lb/
ton
coal)
=
0.0014
+
0.08
=
0.018
Factor
for
pushes
not
severely
green
Factor
for
severely
green
pushes
(
lb/
ton
coal)
(
lb/
ton
coal)
I
16­
PAH
EOM
16­
PAH
EOM
0.00058
0.007
0.0014
0.018
The
estimates
in
Section
5.1
(
Pushing
Emissions)
used
values
of
OS%,
2%
and
20%
for
severely
green
pushes
for
Groups
1,2,
and
3.
The
same
group
assignmentswere
used
in
Table
5­
15
to
estimate
emissions
fiom
quenching.
An
example
calculation
is
given
below
for
ABC
Coke
assuming
0.5%
of
the
pushes
are
severely
green:

(
0.007
Ib/
ton
x
0.995
+
0.018
Ib/
ton
x
0.005)
x
1,160,000
tpyx
1
tod2,
OOO
lb
=
4.1
tpy.

[
99.5%
not
severely
green][
0.5%
severely
green][
coal
usage]
[
Ibs
to
tons]

5­
20
I
rABLE
5­
15.
ESTIMATES
OF
EXTRACTABLEORGANIC
EMISSIONS
FROM
QUENCHING
­
No.

­

1
­

2
­

­
3
­
4
6
­

7
­
8
9
10
­
11
­
12
­
15
­
16
­
18
­
19
­
20
­
21
­
22
­
23
24
Tonawanda,
Buffalo,
NY
218,701
316,958
2
7.22e­
3
1.1
1.1
­
25
USS,
Clairton,
PA
3,900,000
5,652,174
0.5
7.06e­
3
20.0
20.0
(
1,2,3,7,8,9,13,14,15,
B)
25
USS,
Clairton,
PA
(
198~
20)
1,100,000
1,594,203
2
7.22e­
3
5.8
5.6
­
26
USS,
Gary,
IN
1,813,483
2,628,236
2
7.22e­
3
9.5
9.3
­
27
Wheeling­
Pitt,
East
Steubenville,
WV
1,346,176
1,950,980
2
7.22e­
3
7.0
6.9
­
TOTALS
106.6
104.3
*
Estimate
based
on
a
typical
yield
of
0.69
ton
of
coke
per
ton
of
coal.

5­
21
5.4
OTHER
ENVIRONMENTALIMPACTS
The
bulk
of
this
chapter
focuses
on
emissions
and
reductions
associated
with
coke
oven
emissions
with
methylene
chloride
extractables
as
a
surrogate
measure.
The
extractable
organics
represent
organic
PM,
and
VOC
are
not
included
in
the
extractable
organics.
Although
no
data
are
available
to
quantifLthese
volatiles,
benzene,
toluene,
xylene
and
other
hazardous
volatile
organics
are
known
to
be
present
in
coke
oven
emissions.
MACT
will
reduce
emissions
of
these
volatile
HAl 
as
well
as
the
extractables
(
POM
and
PAH).
MACT
will
also
achieve
reductions
in
total
PM.

For
battery
stacks,
MACT
is
achieved
through
pollution
prevention
techniques
such
as
sealing
craclcs
in
oven
walls,
repairing
damaged
ovens,
and
other
work
practices
that
reduce
the
amount
of
coke
oven
gas
leaking
through
the
walls.
Similarly,
MACT
for
pushing
focuses
on
preventing
green
pushes,
and
if
they
occur,
taking
corrective
actions
to
prevent
their
reoccurrence.
Consequently,
these
pollution
prevention
measures
do
not
result
in
any
significant
secondary
impacts,
such
as
the
generation
of
solid
waste,
wastewater,
or
increased
usage
of
energy.

5.5
REFERENCES
1.
Report,
Emissions
Testing
of
Combustion
Stack
and
Pushing
Operations
at
Coke
Battery
No.
2
at
Bethlehem
Steel
Corporation s
Burns
Harbor
Division
in
Chesterton,
Indiana,
EPA454LR­
99­
001a,
February
1999.

2.
Report,
Emissions
Testing
of
Combustion
Stack
and
Pushing
Operations
at
Coke
Battery
No.
5/
6
at
ABC
Coke
in
Birmingham,
Alabama,,
EPA­
454/
R­
99­
002a,
February
1999.

3.
Repart,
Study
on
Benefits
of
Continuous
Opacity
Monitors
Applied
to
Portland
Cement
Kilns­­
Chapter
3:
Relationships
Between
Opacity
and
Concentration
of
Particulate
Emissions,
EPA,
May
15,1991.

4.
Repolrt,
Investigation
of
Opacity
and
Particulate
Mass
Concentrations
from
Hot
Metal
Operations,
prepared
by
David
Ensor
for
EPA,
September
1981.

5.
Report,
Coke
Quench
Tower
Emission
Testing
Program,
EPA­
600/
2­
79­
082,
April
1979.

5­
22
APPENDIX
C.
EMISSION
FACTORS
FOR
BY­
PRODUCT
RECOVERY
PROCESSES
IN
REVISED
AP­
42
Docket
No.
A­
79­
15
Item
No.
XI­
c­
8
Attachment
2
of
2
