P.1 

OAR Box 1770 

Prepped by Keeia Richards 

Document Number: 

35) XII-C-2 

Docket Number: 

A-79-15 

Printed 10/28/200810:20:28 AM Sheet 35 of 93 
. QQPrWyMJDSAtXtt 

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Palmer, Walter VA01.5/27/99 1:59 PM -0400,Coke Oven Residual Risk A 

From: WPalmereicfkaiser.com (Palmer, Walter VA01) Docket No . A-79-15 

To: dailor@accci. org (' dailortaccci. org') Item No. XII-C-2 

Mime-Version: 1.0 

Organization: ICF Kaiser International, Inc. 

Date: Thu, 27 May 1999 13:59:56 -0400 

Subject: Coke Oven Residual Risk Assessment 

David; 

I forward the attached for your information/interest. I'll call you later to discuss it 

Best Regards, 

Walter Palmer 

Project Manager 

ICF Consulting 

[[ DATA-1.DOC : 4402 in DATA-1.D0C ]] 

1§1DATA~I.DOC 

MAR - 9 2004 

EPA AIR DOCKET 

Printed for David Ailor <dailor@nopa.org> 
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COKE OVENS RESIDUAL RISK ASSESMENT: 

DATA LIKELY TO BE USED IN THE ASSESSMENT 

The following are types of data likely to be used in the residual risk assessment of coke ovens. 

1. Facilities 

The risk assessment will address facilities that are subject to MACT standards and 

are cunently in operation (not in shutdown status). A preliminary list of such facilities 

is presented in Table 1. It will be necessary to confirm this list in the early stages of 

the assessment. 

Table 1 

Initial List of Facilities and Batteries Subject to MACT Standards 

Facility 

AK Steel Middletown 

AK Steel Ashland 

Erie Coke 

Erie Coke 

Gulf States Steel 

Gulf States Steel 

New Boston Coke 

Tonawanda Coke 

Battery 

Designation 

3 

3 

A 

B 

2 

2 

2 

2 

Height 

(m) 

4.0 

4.0 

3.5 

3.5 

4.0 

4.0 

4.0 

4.0 

No. of Ovens 

76 

76 

23 

35 

65 

65 

70 

60 

NOTE: LTV Steel Pittsburgh and Toledo Coke are not included since they are in 

shutdown status. • 

2. Battery Configuration/Temperature Data 

The following data will be useful to the assessment: 

• battery dimensions: length and width of battery top; 

• distance between batteries; 

• for each battery: 

• surface temperature and area of the battery oven doors, tops and offtakes; 

• brief description of how these temperatures were measured and at what 

distance from each surface. 

3. Emissions Inventory Data 

The annual air emission inventory summaries routinely submitted by facilities to state 

or local agencies will be key data for the assessment. These data include annual 

and hourly actual emissions of criteria and toxic air pollutants, permitted levels, 

source parameters, operating schedule, emission controls and other relevant 

information. 
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4. Title V and/or NESHAP Compliance Data 

The Title V and/or NESHAP compliance data reported by each facility will be used as 

available. These data include emission sources, controls and control measures, leak 

monitoring data, source parameters, and other relevant information. 

5. TRIData 

The data that must be reported by facilities emitting SARA air toxics will be used in 

the assessment. 

6. Monitoring Data 

Any other monitoring reports, stack test data, etc. that may be available for 

emissions from coke oven batteries will be valuable to the assessment. Useful data 

(if available) include: PMi0 emission data; particle size distributions; percent opacity 

of emissions; and presence and concentration of specific chemical compounds. 

These data are desired for door, lid, offtake, charging, pushing, hot car, and 

decarbonizing emissions, where available. 

7. Alternate Data 

Information for each battery or facility as listed in Table 2 will be very useful for the 

assessment, particularly if the information described above (Items 2 through 5) is not 

available for any facilities. 

Table 2 

Data Requirement for Estimating Emissions 

Charging 

Doors 

Lids 

Offtake 

Pushing 

Volume of total charge j 

Is charging staged? 

Is charging done under steam aspiration? 

Is charging controlled? 

Type of control 

Control efficiency 

Percent leaking doors (post-NESHAP) 

Are door leaks controlled? 

Control practices | 

Control efficiency j 

Percent leaking lids (post-NESHAP) j 

Are lid leaks controlled? 

Control practices 

Control efficiency 

Percent offtake leaks (post-NESHAP) 

Are offtake leaks controlled? 

Control practices j 

Control efficiency 

Is pushing controlled? 

If yes, check each of the following that apply: 

• ESP 

• Venturi scrubber 

• Bag house 

• Hooded scrubber car 

• Coke guide 

• Other (specify) 

- — -
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Quenching 

Combustion stacks 

General operating data 

Check each of the following that apply. 

• Baffled tower 

• Uncontrolled dean water 

• Uncontrolled dirty water 

• Clean water, tall tower, and/or poor maintenance 

• Clean water, normal tower height and proper 

maintenance 

• Dirty water, tall tower, and/or poor maintenance 

• Dirty water, normal tower height, and proper 

maintenance 

Are emissions controlled? 

If yes, check each of the following that apply: 

• ESP 

• Baghouse 

• Other (specify) 

Coking cycle time, hrs 

Amount of coke per charge 

Average no. of pushing per day 

Daily and weekly operating profile 

NOTE: 

Table 2 covers coke oven sources only. If the risk assessment covers Trther 

sources (e.g. the byproduct plant, coal handling, and other operations) data will 

also be required for those sources. 

8. Ambient Monitoring Data 

Any ambient monitoring data collected near (< 3 km) the coke oven facility will be 

useful for comparison with and verification of model results. This includes any direct 

measurement of BSO, gases, particulate matter (including deposition 

measurements), PM size distribution, and mass and filter analyses. Filter analyses 

may include chemical analyses using: x-ray fluorescence for coarse mode particles 

such as Si, Mn, Al, Fe, Pb, Br, Ni, V; atomic absorption for other metals; and 

measurement of elemental and organic carbon from thermal optical reflectance 

analysis. Ideally, the monitoring time and averaging periods would be included with 

these data, and changes in operation of the subject coke ovens since the monitoring 

period would also be defined. 

K/o^