February
7,
2004
SUMMARY
OF
DISCUSSIONS
WITH
THE
COKE
OVEN
ENVIRONMENTAL
TASK
FORCE
(
COETF)
FOR
DOCKET
ID
NUMBER
OGC­
2004­
0004
I.
Purpose
The
purpose
of
this
note
is
to
summarize
discussions
between
the
Environmental
Protection
Agency
(
EPA)
and
COETF
that
were
held
in
December
2004
for
final
resolution
of
issues
associated
with
the
proposed
settlement
agreement
(
69
FR
31372,
June
3,
2004).

II.
Dates
Conference
calls
were
held
on
December
7,
2004;
December
15,
2004;
and
December
22,
2004.

III.
Attendees
Dave
Ailor,
American
Coke
and
Coal
Chemicals
Institute
Steve
Brakefield,
ABC
Coke
Marvin
Branscome,
Research
Triangle
Institute
Nick
Buchko,
Shenango,
Inc.
Steve
Fruh,
EPA,
Emissions
Standards
Division
Jeff
Knight,
Shaw
Pittman
Wade
Kohlman,
Citizens
Gas
&
Coke
Utility
Bill
Kubiak,
U.
S.
Steel
Josh
Levin,
Department
of
Justice
Bob
Mason,
ABC
Coke
Mark
Poling,
ABC
Coke
Steve
Silverman,
EPA,
Office
of
General
Counsel
Tishie
Woodwell,
U.
S.
Steel
IV.
Discussion
°
The
EPA
explained
that
one
adverse
comment
had
been
received
on
the
direct
final
amendments
published
on
October
13,
2004
(
69
FR
60813).
These
amendments
were
published
to
resolve
concerns
raised
by
COETF
in
their
petition
for
review
challenging
the
final
standards.

°
The
direct
final
amendments
will
be
partially
withdrawn
to
address
the
adverse
comment
(
70
FR
1670,
January
10,
2005).
Those
amendments
not
affected
by
the
comment
will
not
be
withdrawn
and
will
become
effective
on
January
11,
2005.
The
adverse
comment
will
be
addressed
and
a
final
amendment
will
be
issued
for
that
part
of
the
amendments
that
was
withdrawn.
2
°
The
commenter
objected
to
the
proposed
requirement
that
would
have
allowed
the
owner
or
operator
an
additional
30
days
(
a
total
of
60
days)
to
repair
a
defect
in
the
capture
system
applied
to
pushing
emissions.
If
more
than
60
days
are
needed,
the
owner
or
operator
would
have
to
request
approval
from
the
permitting
authority.

°
The
industry
representatives
indicated
that
repairs
times
exceeding
30
days
would
be
very
rare.
The
capture
system
for
pushing
emissions
that
uses
a
moveable
hood
is
very
complex
in
design
and
operation,
and
it
is
exposed
to
extremes
of
mechanical
wear
and
high
temperatures.
In
some
cases,
additional
time
may
be
need
to
evaluate
unpredictable
structural
or
mechanical
problems,
schedule
the
repair
at
a
time
that
it
can
be
done
safely,
and
obtain
a
contractor
to
make
the
repair.

°
The
industry
representatives
were
also
concerned
that
if
a
request
was
submitted
to
the
permitting
authority
and
was
not
approved
within
a
reasonable
time,
the
owner
or
operator
could
be
subject
to
a
violation
for
the
entire
period
that
the
request
was
being
considered
by
the
permitting
authority.

°
The
EPA
suggested
that
since
most
repairs
could
be
made
within
30
days,
the
owner
or
operator
should
request
approval
from
the
permitting
authority
for
those
rare
cases
when
additional
time
was
needed.
