OAR Box 1770 

Prepped by Keeia Richards 

Document Number: 

37) XII-C-8 

Docket Number: 

A-79-15 

Printed 10/28/2008 10:20:29 AM Sheet 37 of 93 

P.1 
P.2 

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-4'_l .dd.dWOl 10-4£ m LMH DURHRU, INC Docket No. A-79-15 

Item No. XH-C-8 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

SEP 2 5 2001 OFFICE Of 

AIR OUAUTY PLANNING 

AND STANDARDS 

Mr. David C. Ailor 

American Coke and Coal Chemicals Institute 

1255 Twenty-third St., N.W. 

Washington, D.C. 2-0037 

Dear Dave: 

As a follow-up to our telecon of September 24*, I am forwarding the documentation of 

the emission estimates for the coke ovens risk analysis and a table that indicates the percent 

compliance with LAER limits for MACT track batteries. Please contact me at 919-541-2910, if 

you have any questions regarding this information. 

Sincerely, 

Lula H. Melton 

Emission Standards Division 

Enclosures 
PERCENT COMPLIANCE BY MACT TRACK BATTERIES WITH LAER LIMITS 

PLANT 

AK Steel, Ashland, KY 

AK Steel, Middletown, OH 

Erie Coke, Erie, PA 

New Boston, Portsmouth, OH 

Tonawanda, Buffalo, NY 

ID 

3 

3 

A 

B 

2 

2 

Dates 

From 

01/01/96 

01/01/96 

01/30/98 

01/30/98 

03/01/96 

08/29/97 

To 

04/30/01 

04/30/01 

11/30/98 

11/30/98 

04/30/01 

11/30/98 

Number 

1,948 

1,946 

304 

304 

1,653 

430 

Percent compliance with 1/1/10 LAER 

limits 

Charging 

100 

100 

100 

100 

100 

100 

Doors 

78* 

100 

100 

100 

94.5 

100 

Lids 

100 

100 

100 

100 

99.5 

100 

Offtakes 

100 

100 

100 

100 

99.2 

100 

This battery has been in compliance with the LAER 2010 limit for door leaks (3.3%) 100 percent of the time from 

1/1/98 through 4/30/01 for a total of 1,216 consecutive compliance determinations. 

CO 
P.4 

V*-

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 

industry1 and from an EPA report that assessed control performance for these emission points.2 

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 companies.3,4 

The estimating procedures are from the revised draft of AP-42,5 and relevant excerpts are 

given in Appendix A. BSO emissions from door leaks are based on an emission rate of 0.04 

lb/hr per leak for leaks visible from the yard (as determined by EPA Method 303) and 0.023 lb/hr 

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 100 feet from the doors. EPA 
TABLE 1. SITE-SPECIFIC BATTERY INFORMATION 

PLANT 

AK Steel, Ashland, KY 

AK Steel, Middletown, OH 

Erie Coke, Erie, PA 

New Boston, Portsmouth, OH 

Tonawanda, Buffalo. NY 

ID 

3 

4 

3 

A 

B 

2 

2 

NUMBER 

OF 

OVENS 

76 

70 

76 

23 

35 

70 

60 

NUMBER 

OF LIDS 

PER OVEN 

3 

4 

3 

4 

4 

3 

3 

NUMBER 

OF OFFTAKES 

PER OVEN 

1 

2 

2 

1 

1 

1 

1 

CYCLE 

TIME 

(HRS) 

19 

18 

20 

28 

28 

17 

28 

NUMBER 

OF 

DOORS 

152 

140 

152 

46 

70 

140 

120 

NUMBER 

OF 

LIDS 

228 

280 

228 

92 

140 

210 

180 

NUMBER 

OF 

OFFTAKES 

76 

140 

152 

23 

35 

70 

60 

CHARGES 

PER 

YEAR 

34,675 

33,692 

34,142 

7,196 

10,950 

36,071 

18.771 

TABLE 2. METHOD 303 INSPECTION DATA 

PLANT 

AK Steel, Ashland, KY 

AK Steel, Middletown, OH 

Erie Coke, Erie, PA 

New Boston, Portsmouth, OH 

Tonawanda, Buffalo, NY 

ID 

3 

4 

3 

A 

B 

2 

2 

Dates 

From 

01/01/96 

01/10/95 

01/01/96 

01/30/98 

01/30/98 

03/01/96 

08/29/97 

To 

04/30/01 

04/30/01 

04/30/01 

11/30/98 

11/30/98 

04/30/01 

11/30/98 

METHOD 303 INSPECTION DATA SUMMARY 

Number 

1,948 

2,302 

1,946 

304 

304 

1,653 

430 

Avg s/chg 

3.74 

2.64 

2.78 

3.82 

3.82 

7.09 

2.35 

Avg PLD 

2.43 

2.81 

2.05 

2.01 

1.58 

2.98 

2.49 

Avg PLL 

0.130 

0.080 

0.080 

0.037 

0.056 

0.150 

0.033 

Avg PLO 

0.82 

1.64 

0.72 

0.61 

0.87 

1.41 

0.33 

TABLE 3. EMISSION LIMITS 

PLANT 

AK Steel, Ashland, KY 

AK Steel, Middletown, OH 

Erie Coke, Erie, PA 

New Boston, Portsmouth, OH 

Tonawanda, Buffalo, NY 

ID 

3 

4 

3 

A 

B 

2 

2 

EMISSION LIMITS 

S/CHG 

12 

12 

12 

12 

12 

12 

12 

PLD 

5.0 

3.8 

5.0 

5.0 

5.0 

5.0 

5.0 

PLL 

0.60 

0.40 

0.60 

0.60 

0.60 

0.60 

0.60 

PLO 

3.0 

2.5 

3.0 

3.0 

3.0 

3.00 

3.00 

s/chg = seconds per charge; PLD = percent leaking doors; PLL = percent leaking lids; PLO = percent leaking offtakes 

b> 
P.7 

studies have found that when observations are 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 lb BSO/hr 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 emissions.5 

Results based on Method 303 are given in Table 4 and those based on emission limits are 

given in Table 5. Example calculations are given below. 

Example calculation for AK Ashland Battery 3 based on Method 303 data: 

Charging: (3.74 s/charge) * (34,675 charges/yr) * (0.0093 lb/10 seconds) = 121 lb/yr = 

0.06 tpy BSO 

Doors: (152 doors) * (2.43 percent leaking)/100 * (0.04 lb/hr) + (152 doors) * (6 percent 

leaking)/100 * (0.023 lb/hr) = 0.36 lb/hr = 1.6 tpy BSO 

Lids: (228 lids) * (0.13 percent leaking)/100 * (0.0075 lb/hr) = 0.0022 lb/hr = 

0.01 tpy BSO 

Offtakes: (76 offtakes) * (0.82 percent leaking)/100 * (0.0075 lb/hr) = 0.0047 lb/hr = 

0.02 tpy BSO 

TABLE 4. BSO ESTIMATES BASED ON METHOD 303 

PLANT 

AK Steel, Ashland, KY 

AK Steel, Middletown, OH 

Erie Coke, Erie, PA 

New Boston, Portsmouth, OH 

Tonawanda, Buffalo, NY 

ID 

3 

4 

3 

A 

B 

2 

2 

TONS PER YEAR OF BENZENE SOLUBLE ORGANICS (BSO) 

BASED ON METHOD 303 INSPECTIONS (ACTUAL) 

DOORS 

1.57 

1.54 

1.46 

0.44 

0.62 

1.58 

1.25 

LIDS 

0.010 

0.0074 

0.0060 

0.0011 

0.0026 

0.010 

0.0020 

OFFTAKES 

0.020 

0.075 

0.036 

0.0046 

0.010 

0.032 

0.0064 

CHARGING 

0.060 

0.041 

0.044 

0.013 

0.019 

0.12 

0.020 

TOTAL 

1.66 

1.66 

1.55 

0.46 

0.65 

1.74 

1.28 
P.8 

TABLE 5. BSO ESTIMATES BASED ON EMISSION LIMITS 

PLANT 

AK Steel, Ashland, KY 

AK Steel, Middletown, OH 

Erie Coke, Erie, PA 

New Boston, Portsmouth, OH 

Tonawanda. Buffalo, NY 

ID 

3 

4 

3 

A 

B 

2 

2 

rONS PER YEAR OF BENZENE SOLUBLE ORGANICS (BSO) 

BASED ON EMISSION LIMITS (ALLOWABLES) 

DOORS 

2.25 

1:78 

2.25 

0.68 

1.04 

2.07 

1.78 

LIDS 

0.045 

0.037 

0.045 

0.018 

0.028 

0.041 

0.035 

OFFTAKES 

0.07 

0.11 

0.15 

0.02 

0.03 

0.07 

0.06 

CHARGING 

0.19 

0.19 

0.19 

0.04 

0.06 

0.20 

0.10 

TOTAL 

2.56 

2.12 

2.64 

0.76 

1.16 

2.38 

1.98 

3. Emissions from Pushing, Quenching, and Battery Stacks 

The procedure for estimating MCSO emissions is described in "National Emission 

Standards for Hazardous Air Pollutants (NESHAP) for Coke Ovens: Pushing, Quenching, and 

Battery Stacks-Background Information for Proposed Standards. "7 The relevant excerpt is 

given in Appendix 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 coke8 and one at a battery producing blast furnace coke.9 Emissions from quench towers 

are based on a 1977 EPA test.10 

The emission factors are a function of the tons of coke produced or the tons of coal 

charged. Site-specific information on tons of coal charged and tons of coke produced were 

obtained from an EPA survey1 of the industry and from data compiled from a survey conducted 

by ICF Consulting.11 

3.1 Fugitive Pushing Emissions 

MCSO fugitive emissions from pushing are estimated as 0.0116 lb/ton coke produced for 

plants with control devices and 0.018 lb/ton coke produced for batteries without control devices. 

As discussed 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 40 percent 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. 
P.9 

Example calculations for MCSO for AK Steel Ashland Battery 3: 

Pushing fugitives = 376,000 tpy coke * 0.0116 lb/ton = 4,400 lb/yr = 2.2 tpy MCSO 

TABLE 6. ESTIMATES FOR FUGITIVE PUSHING EMISSIONS 

Plant 

AK Steel, Ashland, KY 

AK Steel, Ashland, KY 

AK Steel, Middletown, OH 

Erie Coke, Erie, PA 

Erie Coke, Erie, PA 

New Boston, Portsmouth, OH* 

Tonawanda, Buffalo, NYID 

3 

4 

3 

A 

B 

2 

2 

Coke (tpy) 

376,000 

589,000 

423,000 

65,000 

99,000 

353,000 

218,701 

METHYLENE 

CHLORIDE SOLUBLE 

ORGANICS (tpy) 

Pushing fugitives 

2.2 

3.4 

2.5 

0.4 

0.6 

3.2 

2.0 

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'

9

 to evaluate emissions from control 

devices applied to pushing emissions. One test was conducted on Battery No. 2 at Bethlehem 

Steel, Burns 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 Burns 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 
P.10 

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 100%, and the high opacity 

continued during travel to the quench tower. This is expected to be a rare occurrence after the 

MACT standard 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 MACT 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 after the implementation of MACT. 

TABLE 7. PAH EMISSION FACTORS FOR THE PUSHING EMISSION CONTROL 

DEVICE AT ABC COKE 

PAHs 

Benzo(a)anthracene 

Benzo(a)pyrene 

Benzo(b)fluoranthene 

Benzo(k)fluoranthene 

Chrysene 

Dibenzo(a,h)anthracene 

Indeno(l ,2,3-cd)pyrene 

Acenaphthene 

Acenaphthylene 

Anthracene 

Benzo(g,h,i)perylene 

Fluoranthene 

Euorene 

Naphthalene 

Phenanthrene 

Pyrene 

2-Methylnaphthalene 

Benzo(e)pyrene 

Perylene 

BAGHOUSE OUTLET (lb/ton) 

Run 2 

3.7e-07 

ND 

2.8e-07 

2.4e-07 

9.8e-07 

ND 

ND 

3.8e-06 

3.4e-05 

5.0e-06 

ND 

5.0e-06 

l.le-05 

1.4e-04 

6.9e-05 

1.2e-05 

3.7e-05 

ND 

ND 

Run 3 

3.7e-07 

ND 

3.3e-07 

2.2e-07 

l.le-06 

ND 

ND 

5.5e-06 

2.7e-05 

8.0e-06 

ND 

8.0e-06 

1.4e-05 

1.7e-04 

4.2e-05 

1.0e-05 

5.6e-05 

1.7e-07 

ND 

Average 

3.7e-07 

ND 

3.1e-07 

2.3e-07 

1.0e-06 

ND 

ND 

4.7e-06 

3.1e-05 

6.5e-06 

ND 

6.5e-06 

1.3e-05 

1.6e-04 

5.6e-05 

l.le-05 

4.7e-05 

8.5e-08 

ND 

ND = not detected 
P.11 

TABLE 8. METALS EMISSION FACTORS FOR THE PUSHING EMISSION 

CONTROL DEVICE AT ABC COKE 

Metal 

Antimony 

Arsenic 

Barium 

Beryllium 

Cadmium 

Chromium 

Cobalt 

Copper 

Lead 

Manganese 

Mercury 

Nickel 

Phosphorus 

Selenium 

Silver 

Thallium 

Zinc 

BAGHOUSE OUTLET (lb/ton) 

Runl 

ND 

4.6E-7 

7.5E-6 

ND 

1.4E-7 

2.9E-6 

ND 

4.3E-6 

1.8E-6 

3.8E-6 

ND 

ND 

2.4E-5 

ND 

ND 

ND 

1.7E-5 

Run 2 

ND 

5.7E-7 

9.9E-6 

4.3E-8 

1.7E-7 

4.3E-6 

ND 

5.2E-6 

3.6E-6 

6.5E-6 

ND 

2.6E-6 

2.2E-5 

8.6E-7 

ND 

ND 

1.9E-5 

Run 3 

ND 

8.4E-7 

1.3E-5 

6.7E-8 

1.2E-7 

5.9E-6 

ND 

7.4E-6 

2.7E-6 

9.1E-6 

ND 

2.0E-6 

3.4E-5 

ND 

ND 

ND 

2.5E-5 

Average 

ND 

6.2E-7 

1.0E-5 

3.7E-8 

1.4E-7 

4.4E-6 

ND 

5.6E-6 

2.7E-6 

6.4E-6 

ND 

1.5E-6 

2.7E-5 

2.9E-7 

ND 

ND 

2.0E-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 1995.24 Benzene results for three 

runs in lb/ton of coke were 3.77 x 107 2.54 x 10"4, and 9.94 x IO"5. The average value of 

2.43 x 10"4 lb/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 survey1 of the industry and from data compiled from a 

survey conducted by ICF Consulting.11 The coke production in tons per year was multiplied by 

the emission factors (lb/ton of coke) to estimate the annual emissions in lbs/yr given in Table 9. 
P.12 

TABLE 9. EMISSION ESTIMATES FOR PUSHING EMISSION CONTROL 

DEVICES 

Plant 

Battery 

Coke (tpy) 

PAHs: 

Benzo(a)anthracene 

Benzo(b)fluoranthene 

Benzo(k)fluoranthene 

Chrysene 

Acenaphthene 

Acenaphthvlene 

Anthracene 

Fluoranthene 

Fluorene 

Naphthalene 

Phenanthrene 

Pyrene 

2-Methylnaphthalene 

Benzo(e)pvrene 

Metals: 

Arsenic 

Barium 

Beryllium 

Cadmium 

Chromium 

Copper 

Lead 

Manganese 

Nickel 

Phosphorus 

Selenium 

Zinc 

Benzene 

AK Steel, 

Ashland, KY 

3 

376,000 

AK Steel, 

Ashland, KY 

4 

589,000 

FA 

0.139 

0.117 

0.086 

0.376 

1.77 

11.7 

2.44 

2.44 

4.89 

60 

21 

4.1 

18 

0.032 

0.233 

3.76 

0.014 

0.053 

1.65 

2.11 

1.02 

2.41 

0.56 

10 

0.109 

7.5 

91 

. 0.218 

0.183 

0.135 

0.589 

2.77 

18.3 

3.83 

3.83 

7.66 

94 

33 

6.5 

28 

0.050 

0.365 

5.89 

0.022 

0.082 

2.59 

3.30 

1.59 

3.77 

0.88 

16 

0.171 

11.8 

143 

AK Steel, 

Middletown, OH 

3 

423,000 

Erie Coke, 

Erie, PA 

A 

65,000 

Erie Coke, 

Erie, PA 

B 

99,000 

/HSSIONS 'lh/vrt 

0.157 

0.131 

0.097 

0.423 

1.99 

13.1 

2.75 

2.75 

5.50 

68 

24 

4.7 

20 

0.036 

0.262 

4.23 

0.016 

0.059 

1.86 

2.37 

1.14 

2.71 

0.63 

11 

0.123 

8.5 

103 

0.024 

0.020 

0.015 

0.065 

0.31 

2.0 

0.42 

0.42 

0.85 

10 

3.6 

0.7 

3.1 

0.006 

0.040 

0.65 

0.002 

0.009 

0.29 

0.36 

0.18 

0.42 

0.10 

1.8 

0.019 

1.3 

16 

0.037 

0.031 

0.023 

0.099 

0.47 

3.1 

0.64 

0.64 

1.29 

16 

6 

1.1 

4.7 

0.008 

0.061 

0.99 

0.004 

0.014 

0.44 

0.55 

0.27 

0.63 

0.15 

2.7 

0.029 

2.0 

24 

An example calculation is given below for Battery 3 at AK Steel, Ashland, KY: 

Benzo(a)anthracene = 376,000 tpy coke x 3.7 x IO"7 lb/ton = 0.139 lb/yr 

Arsenic = 376,000 tpy coke x, 6.2 x 10"7 lb/ton = 0.233 lb/yr 

Benzene = 376,000 tpy coke x 2.43 x IO"4 lb/ton = 91 lb/yr. 
P.13 

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 calculations for MCSO for AK Steel Ashland Battery 3: 

Quenching = 533,000 tpy coal * 0.00706 lb/ton = 3,800 lb/yr = 1.9 tpy MCSO 

TABLE 10. EMISSION ESTIMATES FOR QUENCHING 

Plant 

AK Steel, Ashland, KY 

AK Steel, Ashland, KY 

AK Steel, Middletown, OH 

Erie Coke, Erie, PA 

Erie Coke, Erie, PA 

New Boston, Portsmouth, OH 

Tonawanda, Buffalo, NY 

ID 

3 

4 

3 

A 

B 

2 

2 

Coal (tpy) 

533,000 

833,000 

592,000 

79,000 

120,000 

530,000 

275,000 

METHYLENE 

CHLORIDE 

SOLUBLE 

ORGANICS (tpy) 

1.9 

2.9 

21 

0.28 

0.42 

1.9 

1.0 

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 MACT 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.7 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 
P.14 

ABC Coke. Emissions for a given battery are estimated from the lb/hr measured at ABC Coke 

from the following equation: 

Emissions (lb/hr) = lb/hr (at ABC Coke) x 2.9 (opacity adjustment) * (acfm) I (83,000 acfm). 

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 10"* lb/hr * 2.9 * 54,200 acfm/83,000 acfm = 9.66 x 10-6 lb/hr = 0.085 lb/yr 

Arsenic = 2.0 x IO"4 lb/hr * 2.9 * 54,200 acfm / 83,000 acfm = 3.79 x IO"4 lb/hr = 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 IO"7 lb/dscf) and the sitespecific volumetric 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 IO"7 lb/dscf = 0.0193 lb/min = 10,100 lb/yr. 

10 
P.15 

TABLE 11. PAH TEST RESULTS FOR BATTERY STACKS » ABC COKE 

PAH 

Benzo(a)anthracene 

Benzo(a)pyrene 

Benzo(b)fluoranthene 

Benzo(k)fluoranthene 

Chrysene 

Dibenzo(a,h)anthracene 

Ideno( 1,2,3-cd)pyrene 

Acenaphthene 

Acenaphthylene 

Anthracene 

Benzo(g,h,i)peryIene 

Fluoranthene 

Fluorene 

Naphthalene 

Phenanthrene 

Pyrene 

2-Methylnaphthalene 

Benzo(e)pyrene 

Pervlene 

Runl 

8.6E-06 

1.2E-05 

1.5E-05 

ND 

2.0E-05 

ND 

ND 

1.5E-05 

8.6E-04 

3.3E-07 

ND 

2.9E-04 

5.0E-05 

5.3E-03 

5.9E-04 

1.5E-04 

1.5E-04 

1.6E-05 

ND 

EMISSIONS (Ib/hr) 

Run 2 

4.7E-06 

9.9E-06 

2.0E-05 

1.2E-07 

2.2E-05 

ND 

ND 

1.1E-05 

3.2E-03 

4.1E-07 

ND 

5.6E-04 

3.2E-05 

6.1E-03 

9.4E-04 

9.9E-04 

1.1E-04 

6.6E-05 

ND 

Run 3 

ND 

ND 

1.1E-05 

ND 

1.5E-05 

ND 

ND 

6.0E-06 

6.5E-04 

1.1E-05 

ND 

2.4E-04 

1.8E-05 

3.8E-03 

4.9E-04 

1.7E-04 

7.9E-05 

1.8E-05 

ND 

Run 4 

7.2E-06 

7.7E-06 

1.3E-05 

1.4E-07 

2.5E-05 

ND 

ND 

1.2E-05 

ND 

3.6E-07 

ND 

3.4E-04 

6.3E-05 

4.8E-03 

8.5E-05 

2.2E-04 

2.1E-04 

1.4E-05 

ND 

Average 

5.1E-06 

7.5E-06 

1.4E-05 

6.4E-08 

2.0E-05 

ND 

ND 

1.1E-05 

1.2E-03 

3.0E-06 

ND 

3.6E-04 

4.1E-05 

5.0E-03 

5.3E-04 

3.8E-04 

1.4E-04 

2.8E-05 

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 

Run l 

ND 

1.2E-4 

2.4E-4 

8.9E-7 

1.4E-5 

2.3E-4 

ND 

2.2E-4 

3.6E-4 

1.1E-4 

ND 

4.9E-5 

6.7E-4 

8.9E-5 

ND 

4.0E-5 

1.2E-3 

Emissions (Ib/hr) 

Run 2 

ND 

2.4E-4 

5.7E-4 

3.3E-6 

1.7E-5 

5.1E-4 

ND 

2.4E-4 

4.0E-4 

2.7E-4 

ND 

1.4E-4 

1.7E-3 

2.0E-4 

ND 

4.8E-5 

1.5E-3 

Run 4 

ND 

2.3E-4 

4.0E-4 

1.5E-6 

2.3E-5 

2.8E-4 

ND 

2.8E-4 

2.6E-4 

3.0E-4 

ND 

7.8E-5 

1.5E-3 

2.5E-4 

ND 

3.9E-5 

1.5E-3 

Average 

ND 

2.0E-4 

4.1E-4 

1.9E-6 

1.8E-5 

3.4E-4 

ND 

2.5E-4 

3.4E-4 

2.2E-4 

ND 

8.8E-5 

1.3E-3 

1.8E-4 

ND 

4.2E-5 

1.4E-3 

ND = not detected 

11 
P.16 

TABLE 13. EMISSION ESTIMATES OF PAHS AND METALS FOR BATTERY 

STACKS 

Plant 

Stack 

Battery 

Stack gas flow rate (acfm) 

PAHs: 

Benzo(a)anthracene 

Benzo(a)pyrene 

Benzo(b)fluoranthene 

Benzo(k)fluoranthene 

Chrysene 

Acenaphthene 

Acenaphthvlene 

Anthracene 

Fluoranthene 

Fluorene 

Naphthalene 

Phenanthrene 

Pyrene 

2-Methylnaphthalene 

Benzo(e)pvrene 

Metals: 

Arsenic 

Barium 

Beryllium 

Cadmium 

Chromium 

Copper 

Lead 

Manganese 

Nickel 

Phosphorus 

Selenium 

Thallium 

Zinc 

AK Steel, 

Ashland, KY 

9 

3 

54,200 

AK Steel, 

Ashland, KY 

15 

4 

191,000 

AK Steel, 

Middletown, OH 

1 

W 

156,000 

Erie Coke, 

Erie, PA 

1 

A,B 

37,900 

New Boston, 

Portsmouth, OH 

2 

2 

60,700 

Tonawanda, 

Buffalo, NY 

2 

2 

97,000 

EMISSIONS HWvH 

0.085 

0.124 

0.232 

0.0011 

0.332 

0.182 

19.9 

0.050 

6.0 

0.680 

83 

8.8 

6.3 

2.3 

0.464 

3.3 

6.8 

0.032 

0.299 

5.6 

4.1 

5.6 

3.6 

1.5 

21.6 

3.0 

0.697 

23.2 

0.298 

0.438 

0.818 

0.0037 

1.17 

0.643 

70.2 

0.175 

21.0 

2.40 

292 

31.0 

22.2 

8.2 

1.64 

11.7 

24.0 

0.111 

1.05 

19.9 

14.6 

19.9 

12.9 

5.1 

76.0 

10.5 

2.46 

81.8 

0.244 

0.358 

0.668 

0.0031 

0.955 

0.525 

57.3 

0.143 

17.2 

1.96 

239 

25.3 

18.1 

6.7 

1.34 

9.5 

19.6 

0.091 

0.859 

16.2 

11.9 

16.2 

10.5 

4.2 

62.1 

8.6 

2.01 

66.8 

0.059 

0.087 

0.162 

0.0007 

0.232 

0.128 

13.9 

0.035 

4.2 

0.476 

58 

6.1 

4.4 

1.6 

0.325 

2.3 

4.8 

0.022 

0.209 

3.9 

2.9 

0

 3.9 

2.6 

1.0 

15.1 

2.1 

0.487 

16.2 

0.095 

0.139 

0.260 

0.0012 

0.372 

0.204 

22.3 

0.056 

6.7 

0.762 

93 

9.8 

7.1 

2.6 

0.520 

3.7 

7.6 

0.035 

0.334 

6.3 

4.6 

6.3 

4.1 

1.6 

24.2 

3.3 

0.780 

26.0 

0.151 

0.223 

0.416 

0.0019 

0.594 

0.327 

35.6 

0.089 

10.7 

1.22 

148 

15.7 

11.3 

4.2 

0.831 

5.9 

12.2 

0.056 

0.534 

10.1 

7.4 

10.1 

6.5 

2.6 

38.6 

5.3 

1.25 

41.6 

12 
P.17 

TABLE 14. TEST RESULTS FOR BENZENE FROM BATTERY STACKS 

Plant 

J&L Steel, Battery P-4, Pittsburgh, PA, 

May 197912 

National Steel Battery C, Granite City, IL, July 

197912 

Kaiser Steel Battery B, Fontana, CA, September 

197912 

Bethlehem Steel Battery 1, Bums Harbor, IN, 

March 199513 

Benzene emissions from battery stacks 

ppm 

0.6 to 1.6 

0.1 to 0.2 

1.8 to 4.1 

2.6 to 3.2 

lb/ton of coal 

0.0045 to 0.01 

0.0022 to 0.0031 

0.029 to 0.066 

0.023 to 0.028 

tons/yr 

1.5 to 3.4 

0.3 to 0.4 

3.5 to 7.9 

15 to 18 

TABLE 15. BENZENE EMISSION ESTIMATES FOR BATTERY STACKS 

Plant 

AK Steel, Ashland, KY 

AK Steel, Ashland, KY 

AK Steel, Middletown, OH 

Erie Coke, Erie, PA 

New Boston, Portsmouth, OH 

Tonawanda, Buffalo, NY 

Stack 

9 

15 

1 

1 

2 

2 

Battery 

3 

4 

W 

A,B 

2 

2 

Stack gas flow rate (dscfm) 

31,773 

111,882 

91,577 

22,209 

35,570 

56,842 

Benzene (lb/yr) 

10,100 

35,700 

29,200 

7,090 

11,300 

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 lb/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 
TABLE 16. BENZENE EMISSIONS FROM PROCESS EQUIPMENT IN THE BY-PRODUCT PLANT 

Emission point 

Light oil storage tank 

Tar decanter 

Tar sump 

Tar dewatering 

Tar storage tank 

Light oil condenser 

Light oil sump 

Flush liquor circulation 

tank 

Excess ammonia liquor 

tank 

Wash oil decanter 

Wash oil tank 

Ammonia still 

Benzene emission factor 

(lb/ton of coke produced) 

furnace (lb/t) 

0.00024 

0.0022 

3.80E-04 

0.00084 

0.00076 

0.0036 

0.0006 

0.00052 

0.000056 

0.00015 

0.00015 

foundry (lb/ton) 

0.0062* 

0.001 

1.80E-04 

0.0004 

0.00036 

0.0019 

0.00032 

0.00038 

0.002* 

0.000082 

0.000082 

tpy of coke = 

type of coke = 

Total 

AK Steel, 

Ashland, KY 

964,977 

furnace 

AK Steel, 

Middletown, OH 

423,252 

furnace 

Erie Coke, 

Erie, PA 

164,123 

foundry 

New Boston, 

Portsmouth, OH 

353,091 

furnace 

Tonawanda, 

Buffalo, NY 

219,439 

foundry 

Benzene emissions (lb/yr) 

232 

2123 

367 

811 

733 

3474 

579 

502 

54 

145 

145 

None 

9,163 

None 

931 

161 

356 

322 

None 

None 

220 

24 

63 

None 

None 

2,076 

None 

None 

None 

None 

None 

None 

None 

None 

328 

None 

None 

None 

328 

85 

777 

134 

297 

268 

1271 

None 

184 

20 

53 

53 

None 

3,141 

1361 

None 

None 

None 

None 

None 

None 

None 

439 

None 

None 

2,800 

4,600 

* Uncontrolled emission factor. 

14 
P.19 

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 lb/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 Estimates. "H The protocol for estimating emissions is determined 

by the amount of information that is available. If there are no Mediod 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 Ashland15 and New 

Boston Coke4 provided 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 
P.20 

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.11 

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 

• 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)0746 = 0.0013 kg/hr * 2,190 hr/yr * 0.75 (fraction benzene) = 2.2 kg/yr = 

4.8 lb/yr 

• One valve with screening level pegged at 10,000 ppm inspected annually: 

6.4E-2 kg/hr * 8,760 hr/yr * 0.75 (fraction benzene) = 420 kg/yr = 925 lb/yr 

Example of default approach for Tonawanda Coke 

• 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 lb/kg * 8,760 hr/yr = 

4,916 lb/yr 

16 
P.21 

TABLE 17. BENZENE EMISSIONS FROM EQUIPMENT LEAKS - AK STEEL ASHLAND 

COMPONENT 

Valve 

Valve 

Pressure relief device 

Pressure relief device 

STREAM 

Light oil 

STREAM 

Rich wash oil 

Lean wash oil 

PERCENT 

BENZENE 

75 

75 

75 

75 

PERCENT 

BENZENE 

75 

PERCENT 

BENZENE 

3 

0.14 

EMISSIONS FROM LEAKING COMPONENTS 

SCREENING 

VALUE (SV) pDmv 

5000 

10000 

10000 

10000 

hrs/yr 

leaking 

2190 

8760 

4380 

4380 

kg/hr 

2.29E-06*(SV)074< 

6.40E-02 

7.30E-02 

7.30E-02 

Benzene 

Ob/vr) 

4.8 

925 

528 

528 

EMISSIONS FROM NON-LEAKING COMPONENTS 

COMPONENT 

Pump 

Range 

Valve 

Open end line 

COMPONENT 

Pump 

Flange 

Valve 

Open end line 

Pump 

Flange 

Valve 

Open end line 

NUMBER 

5 

46 

91 

30 

NUMBER 

3 

10 

116 

21 

3 

10 

131 

19 

EMISSION 

FACTOR 

(ke/hr/source) 

2.40E-05 

3.10E-07 

7.80E-06 

2.00E-06 

EMISSION 

FACTOR 

(ke/hr/source) 

1.14E-01 

2.50E-04 

1.09E-02 

2.30E-03 

1.14E-01 

2.50E-04 

1.09E-02 

2.30E-03 

Total 

Benzene 

Ob/yr) 

1.7 

0.2 

10.3 

0.9 

Benzene 

Ob/yr) 

198 

1 

731 

28 

9 

0.1 

39 

1 

3.000 

TABLE 18. BENZENE EMISSIONS FROM EQUIPMENT LEAKS - TONAWANDA COKE 

STREAM 

Light oil 

% BENZENE 

65 

COMPONENT 

Pump 

Flange 

Valve 

Open end line 

NUMBER 

1 

37 

36 

1 

EMISSION FACTOR 

(kg/hr/source) 

1.14E-01 

2.50E-04 

1.09E-02 

2.30E-03 

Total 

BENZENE (lb/yr) 

1,428 

116 

4,916 

29 

6,500 

TABLE 19. BENZENE EMISSIONS FROM EQUIPMENT LEAKS - NEW BOSTON COKE 

STREAM 

Light oil 

Gas 

PERCENT 

BENZENE 

67 

10 

COMPONENT 

Pump 

Flange 

Valve 

Open end line 

Pressure relief 

devices 

NUMBER 

9 

848 

122 

72 

8 

1 

EMISSION FACTOR 

(ke/hr/source) 

2.40E-05 

3.10E-07 

7.80E-06 

2.00E-06 

see Tables 20 and 21 

fotal 

BENZENE 

(Ib/vr) 

2.8 

3.4 

12.3 

1.9 

42.1 

63 

17 
P.22 

TABLE 20. EMISSIONS FROM LEAKING PRESSURE RELIEF DEVICES • NEW BOSTON COKE 

Date 

Jan-97 

May-97 

no data for 

Nov-97 

Feb-98 

Jul-98 

Sep-98 

Nov-98 

Sep-99 

Jun-00 

Sep-00 

Process 

flushing liquor tank 

tar tank 

tar tank 

flushing liquor tank 

tar storage 

wastewater tank 

July 1997 through Octwastewater tank 

wastewater tank 

secondary separator 

primary separator 

wash oil tank 

light oil tank 

tar storage 

tar receiver 

wash oil tank 

light oil tank 

wash oil tank 

primary separator 

secondary separator 

wash oil tank 

wastewater tank 

wastewater tank 

light oil tank 

light oil tank 

wash oil tank 

tar sump 

primary separator 

wastewater tank 

tar decanter 

tar decanter 

tar decanter 

wash oil tank 

Screening 

value (SV) 

890 

10000 

10000 

10000 

10000 

10000 

>ber 1997 

750 

10000 

1000 

750 

5000 

10000 

7500 

5000 

5000 

10000 

1000 

10000 

10000 

10000 

2000 

1000 

10000 

10000 

10000 

7000 

10000 

10000 

10000 

10000 

10000 

10000 

% 

Benzene 

0.16 

0.16 

0.16 

0.16 

0.16 

10 

10 

10 

10 

10 

10 

10 

0.16 

0.16 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

0.16 

10 

10 

0.16 

0.16 

0.16 

10 

kg/hr/source 

1.36E-5(SV)0589 

0.073 

0.073 

0.073 

0.073 

0.073 

136E-5(SV)0M9 

0.073 

1.36E-5(SV)0389 

1.36E-5(SV)0-

589 

1.36E-5(SV)0589 

0.073 

1.36E-5(SV)W89 

1.36E-5(SV)0-

589 

1.36E-5(SV)OJ89 

0.073 

1.36E-5(SV)°-S89 

0.073 

0.073 

0.073 

1.36E-5(SV)0589 

1.36E-5(SV)0389 

0.073 

0.073 

0.073 

1.36E-5(SV)0589 

0.073 

0.073 

0.073 

0.073 

0.073 

0.073 

Benzene 

(lbs/month) 

0.002 

0.185 

0.185 

0.185 

0.185 

11.6 

0.106 

11.6 

0.126 

0.106 

0.325 

11.6 

0.007 

0.005 

0.325 

11.6 

0.126 

11.6 

11.6 

11.6 

0.189 

0.126 

11.6 

11.6 

11.6 

0.006 

11.6 

11.6 

0.185 

0.185 

0.185 

11.6 

153 lbs f< 

Comment 

leak visually detectedassumed 10,000 ppm 

screening level not 

reported - assumed 

10,000 

)r 44 months = 42 Ibs/vr 

18 
P.23 

TABLE 21. EMISSION ESTIMATES FOR NON-LEAKING PRESSURE RELIEF DEVICES-NEW 

BOSTON COKE 

Date 

Jan-97 

Feb-97 

Mar-97 

Apr-97 

May-97 

Jun-97 

Nov-97 

Dec-97 

Jan-98 

Feb-98 

Mar-98 

Apr-98 

May-98 

Jun-98 

Jul-98 

Aug-98 

Sep-98 

Oct-98 

Nov-98 

Dec-98 

Jan-99 

Feb-99 

Mar-99 

Apr-99 

May-99 

Jun-99 

Jul-99 

Aug-99 

Sep-99 

Oct-99 

Nov-99 

Dec-99 

Jan-00 

Feb-00 

Mar-00 

Apr-00 

May-00 

Jun-00 

Jul-00 

Aug-00 

Sep-00 

Oct-00 

Nov-00 

Dec-00 

Number 

8 

8 

8 

8 

7 

8 

2 

8 

8 

5 

8 

8 

8 

8 

3 

8 

5 

8 

8 

8 

8 

8 

8 

8 

8 

8 

8 

8 

6 

8 

8 

8 

8 

8 

8 

8 

8 

8 

8 

8 

7 

8 

8 

8 

ke/hr/source 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

4.00E-06 

% benzene 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

lb/month 

0.0051 

0.0051 

0.0051 

0.0051 

0.0044 

0.0051 

0.0013 

0.0051 

0.0051 

0.0032 

0.0051 

0.0051 

0.0051 

0.0051 

0.0019 

0.0051 

0.0032 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0038 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0051 

0.0044 

0.0051 

0.0051 

0.0051 

0.21 lbs for 44 months = 0.06 lbs/yr 

19 
6. Benzene Emissions from Product Loading 

Benzene 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 IO"3 lb/ton of coal. 

Tonawanda reported 840 lbs/yr, which gives an emission factor of 3.1 x IO"3 lb/ton of coal based 

on coal usage of 275,000 tpy. The average of these emission factors (3.7 x 10'3 lb/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 10"4 lb/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. Benzene 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 Emissions from Sources of Benzene")}6 Benzene 

emissions from wastewater are controlled because the benzene waste NESHAP (40 CFR Part 61, 

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

20 
P.25 

TABLE 22. BENZENE EMISSIONS FROM PRODUCT LOADING AND 

WASTEWATER 

Plant 

AK Ashland 

AK Middletown 

Tonawanda 

Erie 

New Boston 

Product 

Tar 

Light oil 

Tar 

Tar 

Light oil 

Tar 

Tar 

Light oil 

Benzene from loading 

(lb/yr) 

540 

5,600 

940 

120 

840 

120 

220 

2,000 

Source 

AP-42' 

AP-42" 

AP-42" 

Emission factor11 

AP-42" 

Emission factor1" 

Emission factor1" 

Emission factor* 

Benzene from 

wastewater (lb/yr) 

900 

730 

510 

120 

nil" 

"From site-specific data and AP-42 procedures. 

b

 From AK Steel (Ashland) emission factor of 4.1 x 10"4 lb/ton coal charged. 

c

 From average emission factor of 3.7 x 10'3 lb/ton coal charged from AK Steel (Ashland) and Tonawanda Coke. 

d

 This plant installed a new wastewater treatment system in 1999. The system is enclosed/covered and 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 Institute17 

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 

Benzo(a)anthracene 

Benzo(a)pyrene 

Benzo(b)fluoranthene 

Benzo(k)fluoranthene 

Chrysene 

Dibenzo(a,h)anthracene 

Ideno( 1,2,3-cd)pyrene 

Total 

Average (%) 

0.90 

0.84 

0.68 

0.59 

1.1 

0.052 

0.37 

4.5 

Ranee (%) 

0.57-1.5 

0.46-1.3 

0.37-1.1 

0.37-1.0 

0.80 - 2.2 

0.015-0.11 

0.21 - 0.53 

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.18'

19'20 

EPA conducted a source test in 1978 that measured BSO and PAHs in a lid leak during the first 

21 
P.26 

hour of coking.21 The results for additional PAHs (other than the 7 PAHs listed in Table 23) are 

given in Table 24. Other constituents in coke oven emissions from the revised AP-425 are given 

in Table 25. 

Table 24. ADDITIONAL PAHs IN BSO21 

PAH 

Fluoranthene 

Fluorene 

Naphthalene 

Phenanthrene 

Pyrene 

Total 

% of BSO 

2.3 

1.1 

10.5 

4.2 

2.4 

20.5 

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 

Carbonyl sulfide 

Carbon disulfide 

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 
P.27 

Compound 

Thiophenes 

Ammonia and acids: 

HC1 

HF 

HN03 

H,SO_. 

Metals: 

Arsenic 

Mercury 

Selenium 

Semivolatiles: 

Benzofuran 

Benzonitrile 

Dibenzofuran 

Dimethyl phenol 

Hexanoic acid dioctylester 

2-methyl phenol 

4-methyl phenol 

Phenol 

Propanenitrile 

Propynyl benzene 

Pyridine 

Trimethyl benzene 

Volatile organics: 

Methylethyl benzene 

Ratio to BSO 

0.003 

0.0009 

5x10-* 

7xl0"5 

0.0007 

- 2xl0"7 

2xl0"7 

2xl0"7 

7xl0"5 

2xl0"5 

9X10"6 

9x10* 

2xl0"5 

7xl0'5 

2X10"4 

6x10"4 

9x10"* 

2xl05 

0.0002 

5xl0"5 

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 
P.28 

TABLE 26. PAHs IDENTIFIED IN FUGITIVE PUSHING EMISSIONS8 

7 PAHs 

Benzo(a)anthracene 

Benzo(a)pyrene 

Benzo(b)fluoranthene 

Benzo(k)fluoranthene 

Chrysene 

Dibenzo(a,h)anthracene 

Ideno( 1,2,3-cd)pyrene 

Total 7 PAHs 

16 PAHs 

Acenaphthene 

Acenaphthylene 

Anthracene 

Benzo(g,h,i)perylene 

Fluoranthene 

Ruorene 

Naphthalene 

Phenanthrene 

Pyrene 

Total 16 PAHs 

Other PAHs 

2-Methylnaphthalene 

Benzo(e)pyrene 

Perylene 

Total - all PAHs 

Ratio to MCSO 

0.0017 

0.0005 

0.0015 

0.0009 

0.0029 

0.0000 

0.0010 

0.0084 

Ratio to MCSO 

0.0013 

0.0082 

0.0015 

0.0000 

0.0048 

0.0019 

0.0330 

0.0140 

0.0033 

0.0770 

Ratio to MCSO 

0.0072 

0.0006 

0.0001 

0.0840 

TABLE 27. RATIOS OF METALS TO EXTRACTABLE ORGANICS FOR FUGITIVE 

PUSHING EMISSIONS 

Metal 

Sb 

As 

Be 

Cd 

Cr 

Co 

Pb 

Mn 

Hg 

Ni 

Se 

Total 

Ratio to extractables organics 

ABC Coke8 

2.3E-05 

1.8E-03 

6.2E-05 

5.3E-04 

1.6E-03 

2.9E-04 

2.6E-03 

3.2E-03 

ND 

2.8E-03 

5.9E-04 

1.3E-02 

Bethlehem9 

4.7E-04 

1.0E-02 

1.3E-04 

2.4E-04 

9.6E-04 

4.7E-04 

1.6E-02 

5.1E-03 

6.7E-05 

9.8E-03 

2.2E-03 

4.6E-02 

24 
P.29 

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"

 23

~ Composition of light oil 

(benzene, toluene, and xylene) 

Benzene 

Toluene 

Xylene 

% 

60-85 

6-17 

1-7 

Midrange % Ratio to benzene 

72.5 

11.5 0.16 

4 0.055 

From draft AP-42 Table 12.2.55-- components of raw coke oven gas 

Benzene 

Toluene 

Xylene 

Ratio to BSO 

0.5 

0.04 

0.005 

Ratio to benzene 

0.08 

0.01 

mg/m3 

35,800 

23,900 

21,400 

27,000 

3,000 

1,520 

2,260 

Ratio to benzene 

0.08 

From "Identity and Chemical and Physical Properties of Compounds in Coke Oven 

Emissions"- Minor Constituents in Coke Oven Gas18 

Benzene 

average 

Toluene 

average 

Xylene 500 0.02 

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 Plants.18 

Ratio to benzene 

0.06 

0.03 

25 

Benzene 

Toluene 

Xylene 

Mean 

mg/m3 

9.5 

0.6 

0.3 
P.30 

10. References 

1. Memorandum with attachments, S. Burns, RTI, to the docket, enclosing data compiled 

from EPA Section 114 survey responses, July 1998. Docket Item U-I-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. U.S. 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 Clairton Coke Works Batteries 7, 8, and 9. Dec-ket4temJI-A-54 inJDacket A-79-15. 

August 1981. 

7. U.S. Environmental Protection Agency. National Emission Standards for Hazardous Air 

Pollutants (NESHAP) for Coke Ovens: Pushing, Quenching, and Battery StacksBackground 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/R-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's Burns 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-600/2-79-082. 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 

Information for Proposed Standards. Preliminary Draft. US EPA Office of Air Quality 

Planning and Standards. May 1980. 

26 
P.31 

13. Mostardi-Platt Associates, Inc. Particulate and Gaseous Emission Diagnostic Study 

Performed for Bethlehem Steel at the Number 1 Underfire Stack, Bums Harbor, Indiana. 

March 20 to 22,1995. 

14. U.S. Environmental Protection Agency. Protocol for Equipment Leak Emission 

Estimates. EPA-453/R-95-017. November 1995. 

15. Memorandum. Stephen Felton, AK Steel, to Marvin Branscome, RTI. Enclosing AK 

Steel's Method 21 Inspection Results. May 10,2001. 

16. U.S. Environmental Protection Agency. Locating and Estimating Air Emissions from 

Sources of Benzene. EPA-454/R-98-011. June 1998. 

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

2000. 

18. Mabey, W.R. Identity and Chemical and Physical Properties of Compounds in Coke Oven 

Emissions. Stanford Research Institute. September 1977. 

19. Suta, Benjamin. Human Population Exposures to Atmospheric Coke Oven Emissions. 

SRI International. October 1978. 

20. White, L. et al. Atmospheric Emissions of Coking Operations - a Review. University of 

Cincinnati. EPA Docket No. A-79-15, Item 13-1-9. 

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

Emissions Measurement Branch. 1978. 

22. E-mail from Michael Maret, PES, to Lula Melton, EPA. Transmitting revised test report 

tables. June 15,2001. 

23. United States Steel. The Making, Shaping, and Treating of Steel. Association of Iron and 

• Steel Engineers. 10th Edition. 1985. 

24. Mostardi-Platt Associates, Inc. Particulate and Gaseous Emission Diagnostic Study 

Performed for Bethlehem Steel at the Number 1 Coke Battery Pushing Control Stack, 

Bums Harbor, Indiana. March 21 to 23,1995. 

27 
P.32 

APPENDIX A. EXCERPTS FROM REVISED AP-42 

A-1 
P.33 

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 
P.34 

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 circulated for comments on its technical merit and policy implications. 

A-3 
P.35 

4.1.2 Development of 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 BSO: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 lb BSO/hr (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 0.02 to 0.26 lb/hr (0.01 to 0.12 kg/hr) for 10 percent leaking doors. The 

midrange of these predicted emission rates is 0.14 lb/hr (0.063 kg/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 1 leaks 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 lb/hr) 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 lb/hr (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 lb/hr (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 lb/hr 

(0.063 kg/hr) for an average of 10 percent 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 lb/hr (0.019 kg/hr), which is very close to the 

model prediction of 0.05 lb/hr (0.023 kg/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 10 percent in this analysis. First, the 

A-4 
P.36 

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 lb/hr (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 the 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 bench but not the yard are assigned an emission rate of 0.023 lb/hr (0.011 kg/hr). 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 than 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 BSO/h (0.0026 to 0.007 kg BSO/h). The above emissions are based upon a limit of detection of 

three times the 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 BSO/h. At 

the detection 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 
P.37 

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 empty/no visible leak ovens with these two values included is 0.009 lb/hr (0.004 kg/hr) but with 

these two values excluded is 0.005 lb/hr (0.002 kg/hr). The average emission rate for empty/no 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 lb BSO/h (0.0033 to 0.021 kg 

BSO/h) 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 lb BSO/h (0.0033 kg BSO/h) be used for the 

NESHAP level of control and that emissions of 0.048 lb BSO/h (0.021 kg BSO/h) be used for the preNESHAP 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 
P.38 

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 lb BSO (0.06 to 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 emissions 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 kg/Mg) 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 (1995), 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 
P.39 

TABLE 4-1. SUMMARY OF UNCONTROLLED AND CONTROLLED DOOR LEAK EMISSIONS 

Reference 

1 

2 

3 

4 

166 

Pollutant 

Filterable PM 

Uncontrolled 

Filterable PM 

Uncontrolled 

Filterable PM 

Uncontrolled 

Condensible 

PM 

Uncontrolled 

BSO 

Uncontrolled 

Filterable PM 

Uncontrolled 

Filterable PM 

pre-NESHAP 

Controlled 

No. of 

runs 

3 

3 

4 

4 

4 

3 

3 

Emission factor 

Range 

0.4-1.0 

0.2-0.5 

0.08-0.8 

0.04-0.4 

0.4-0.9 

0.2-0.5 

0.1-0.5 

0.05-0.3 

0.6-0.7 

0.3-0.4 

0.3-0.5 

0.2-0.3 

0.03-0.2 

0.02-0.1 

Average 

0.72 

0.36 

0.44 

0.22 

0.57 

0.29 

0.36 

0.18 

0.62 

0.31 

0.36 

0.18 

0.066 

0.05 

Units3 

lb/ton 

kg/Mg 

lb/ton 

kg/Mg 

lb/ton 

kg/Mg 

lb/ton 

kg/Mg 

lb/ton 

kg/Mg 

lb/ton 

kg/Mg 

lb/tonb 

kg/Mgb 

Rating 

D 

D 

D 

D 

D 

D 

E 

"Based on lb/ton or kg/Mg of coal charged unless otherwise specified. 

"Converted from lb/ton of coke pushed using factors of 0.69 for lb/ton and 0.345 for kg/Mg. 

TABLE 4-2. BSO ESTIMATES FOR DOOR LEAKS 

Reference 

5 

3 

9 

9 

Percent leaking 

doors 

29 

70 

5 

10 

BSO rate per door 

kg/hr 

0.58 

0.19 

0.0036-0.041 

0.01-0.12 

lb/hr 

1.3 

0.42 

0.008-0.089 

0.02-0.26 

Comment 

Coke side shed test 

Coke side shed test 

Model prediction8 

Model prediction" 

1

 Model prediction estimates from reference 9 are extrapolated from test data from references 3 and 5. 

A-8 
P.40 

TABLE 4-3. DOOR LEAK EMISSIONS DATA 

Reference 

39 

39 

39 

7 

Run 

2h 

6h 

7h 

11 

Leak category" 

0 (empty oven) 

0 (empty oven) 

0 (empty oven) 

0 (no visible) 

Average 

39 

39 

39 

39 

39 

39 

7 

7 

7 

llh 

li e 

3h 

3c 

4h 

4c 

5 

10 

12 

0.5 

0.5 

0.5 

0.5 

0.5 

0.5 

0.5 

0.5 

0.5 

Average 

39 

39 

39 

39 

39 

39 

7 

7 

7 

5h 

5c 

lc 

lh 

10c 

lOh 

4 

6 

9 

1 

1 

1 

1 

1 

1 

1 

1 

1 

Average 

39 

39 

39 

39 

7 

9c 

9h 

8c 

8h 

3 

2 

2 

2 

2 

2 

Average 

7 

7 

7 

2 

1 

8 

3 

3 

3 

Average 

7 1 7 1 4 

Particulate matter, lb/hi*0 

Reported 

0.028 

0.019 

0.014 

0.010 

0.018 

0.O48 

0.033 

0.043 

0.068 

0.O45 

0.042 

0.029 

0.014 

-0.002 

0.036 

0.085 

0.062 

0.037 

0.046 

0.041 

0.058 

0.039 

0.033 

0.010 

0.046 

0.049 

0.055 

0.087 

0.089 

0.128 

0.082 

0.119 

0.088 

0.202 

0.136 

0.579 

Revised 

0.025 

0.011 

0.010 

0.010 

0.014 

0.044 

0.027 

0.043 

0.058 

0.044 

0.040 

0.029 

0.014 

0.016 

0.035 

0.085 

0.062 

0.031 

0.040 

0.041 

0.058 

0.039 

0.033 

0.013 

0.045 

0.048 

0.054 

0.086 

0.088 

0.130 

0.081 

0.124 

0.088 

0.202 

0.138 

0.580 

BSO, lb/hr* 

Reported 

0.016 

0.006 

0.007 

-0.009 

0.005 

0.052 

0.036 

0.019 

0.027 

0.018 

0.023 

0.008 

-0.005 

0.004 

0.020 

0.047 

0.042 

0.027 

0.033 

0.030 

0.024 

0.010 

0.008 

-0.002 

0.024 

0.030 

0.030 

0.065 

0.063 

0.109 

0.059 

0.086 

0.050 

0.164 

0.100 

0.485 

Revised 

0.016/0.002 

0.006/0.004 

0.005 

0.0075 

0.009/0.005 

0.052 

0.035 

0.018 

0.026 

0.016 

0.023 

0.018 

0.010 

0.012 

0.023 

0.047 

0.038 

0.024 

0.019 

0.030 

0.022 

0.020 

0.020 

0.013 

0.027 

0.028 

0.028 

0.065 

0.064 

0.120 

0.061 

0.096 

0.059 

0.173 

0.109 

0.494 

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 includes 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 deviation of 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 
P.41 

TABLE 4-4. DATA FOR UNCONTROLLED CHARGING 

Reference 

12 

12,13, 

4 

4 

Pollutant 

Filterable PM 

Benzene soluble organics 

Condensible PM 

Filterable PM 

Filterable PM 

Emission factor 

kg/Mg 

0.055 

0.065 

0.055 

0.26 

0.75 

lb/ton 

0.11 

0.13 

0.11 

0.52 

1.5 

Rating 

D 

D 

D 

D 

D 

REFERENCES FOR SECTION 4 

1. Source Testing of a Stationary Coke-Side Enclosure: Great Lakes Carbon Corporation, St. Louis, 

MO,EPA-340/l-76-014(a) and (b), U. S. Environmental Protection Agency, Washington, DC, 

August 1977. 

2. Source Testing of a Stationary Coke-Side Enclosure: Burns Harbor Plant, Bethlehem Steel 

Corporation, Chesterton, IN, EPA-340/1-76-012, U. S. Environmental Protection Agency, 

Washington, DC, May 1977. 

3. Emission Testing at a Byproduct Coke Oven Battery, Wisconsin Steel, Chicago, IL, 

EMB 77-CKO-ll, U. S. Environmental Protection Agency, Washington, DC, May 1978. 

4. Particulate Emission Factors Applicable to the Iron and Steel Industry, EPA-450/4-79-028, U. S. 

Environmental Protection Agency, Research Triangle Park, NC, September 1979. 

5. Emission Test Report: Armco Steel, Houston, TX. EMB 79-CKO-22. U. S. Environmental 

Protection Agency, Research Triangle Park, NC, November 1979. 

6. C. Allen, A Model to Estimate Hazardous Emissions from Coke Oven Doors, EPA Contract 

No. 68-02-1408, Docket Item B-A-38 in Docket No. A-79-15, March 1980. 

7. Final Phase I Method Validation Report for Quantitative Coke Oveti Door Leak Measurement 

Study, ENSR Consulting and Engineering, for American Iron and Steel Institute, Washington, DC. 

December 1991. 

8. Emission Test Report - U.S. Steel Corporation, Clairton, Pennsylvania, EMB Report 

No. 7 78-CKO-13. TRW, Inc. July 1980., 

9. Coke Oven Emissions from Wet-Coal Charged Byproduct Coke Oven Batteries - Background 

Information for Proposed Standards, EPA-450/3-85-028a, U. S. Environmental Protection Agency, 

Research Triangle Park, NC. April 1987. 

A-10 
P.42 

10. Memorandum from Ackerman, E., USEPA Region HI, to A. Agnew, EPA/OAQPS. Transmitting 

information on bypassed coke oven gas. April 8,1991. 

11. Coke Oven 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 of Hazardous Organic Emissions from Slot Type Coke Oven 

Batteries, unpublished paper, U. S. Environmental Protection Agency, Research Triangle Park, 

NC, March 1978. 

39. Draft Final Phase II Method 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-ll 
P.43 

APPENDIX B. EXCERPT FROM THE BACKGROUND INFORMATION DOCUMENT 

FOR PUSHING, QUENCHING, AND BATTERY STACKS 
P.44 

United States 

Environmental Protection 

Agency 

Office Of Air Quality 

Planning And Standards 

Research Triangle Park, NC 27711 

EPA-453/R-01-006 

February 2001 

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 
P.45 

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)1 

and ABC Coke (Birmingham, AL)2. 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 die 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 
P.46 

extractable organics during Run 2 were 0.0057 lb/ton compared to an average of 0.0045 lb/ton 

during Rims 1 and 3. 

TABLE 5-1. PAH RESULTS FOR PUSHING - BETHLEHEM, BURNS HARBOR1 

7 PAH 

1 Benzo(a)anthracene 

2 Benzo(a)pyrene 

3 Benzo(b)fluoranthene 

4 Benzo(k)fluoranthene 

5 Chrysene 

6 Dibenzo(a,h)anthracene 

7 Ideno(l,2,3-cd)pyrene 

Total 7 PAH 

16 PAH 

8 Acenaphthene 

9 Acenaphthylene 

10 Anthracene 

11 Benzo(g,h,i)perylene 

12 Fluoranthene 

13 Fluorene 

14 Naphthalene 

15 Phenanthrene 

16 Pyrene 

Total 16 PAH 

Other PAH 

2-Methylnaphthalene 

Benzo(e)pyrene 

Perylene 

Total Other PAH 

Total - all PAH 

Extractable organics (lb/hr) 

Number of moderately green 

pushes 

Number of nongreen pushes 

Total number of pushes 

Percent green 

Runl 

7.1E-07 

4.8E-07 

5.9E-06 

2.3E-06 

4.3E-06 

8.6E-07 

2.1E-06 

1.7E-05 

5.4E-07 

4.3E-06 

5.7E-07 

1.7E-06 

1.1E-05 

1.7E-06 

2.1E-05 

1.6E-05 

1.7E-06 

7.4E-05 

6.2E-06 

1.6E-06 

7.8E-08 

7.8E-06 

8.2E-05 

4.9E-03 

3 

43 

46 

7 

BAGHOUSE INLET (lb/ton) 

Run 2 

5.7E-07 

3.2E-07 

6.1E-06 

2.3E-06 

4.4E-06 

8.1E-07 

2.0E-06 

1.7E-05 

3.5E-07 

4.4E-06 

5.1E-07 

1.6E-06 

1.3E-05 

1.3E-06 

2.6E-05 

1.9E-05 

1.9E-06 

8.4E-05 

5.0E-06 

1.4E-06 

0.0E+00 

6.4E-06 

9.0E-05 

5.7E-03 

6 

41 

47 

13 

Run 3 

1.3E-07 

1.3E-07 

3.0E-06 

8.5E-07 

1.9E-06 

2.5E-07 

4.6E-07 

6.7E-06 

5.4E-07 

2.7E-06 

6.5E-07 

3.3E-07 

6.8E-06 

1.3E-06 

2.9E-05 

2.0E-05 

3.9E-07 

6.9E-05 

3.1E-06 

4.0E-07 

O.OE+00 

3.5E-06 

7.2E-05 

4.0E-03 

3 

39 

42 

7 

Average 

4.7E-07 

3.1E-07 

5.0E-06 

1.8E-06 

3.6E-06 

6.4E-07 

1.5E-06 

1.3E-05 

4.8E-07 

3.8E-06 

5.8E-07 

1.2E-06 

1.0E-05 

1.5E-06 

2.5E-05 

1.8E-05 

1.3E-06 

7.6E-05 

4.7E-06 

1.1E-06 

2.6E-08 

5.9E-06 

8.2E-05 

4.9E-03 

Runl 

3.6E-08 

3.1E-08 

4.7E-08 

4.4E-08 

7.1E-08 

9.1E-09 

4.1E-08 

2.8E-07 

9.1E-08 

1.9E-07 

5.5E-08 

9.1E-09 

3.1E-07 

1.9E-07 

4.7E-06 

7.6E-07 

1.8E-07 

6.8E-06 

1.0E-06 

3.1E-08 

7.1E-09 

1.1E-06 

7.9E-06 

3.1E-03 

BAGHOUSE OUTLET 

Run 2 

2.4E-08 

1.5E-08 

3.4E-08 

1.8E-08 

7.6E-08 

0.0E+00 

1.6E-08 

1.8E-07 

6.6E-08 

1.5E-07 

2.1E-08 

2.5E-09 

1.3E-07 

1.5E-07 

4.8E-06 

5.2E-07 

9.8E-08 

6.1E-06 

1.4E-06 

1.8E-08 

7.1E-09 

1.4E-06 

7.5E-06 

2.4E-03 

(lb/ton) 

Run 3 

1.2E-08 

1.0E-08 

1.9E-08 

1.3E-08 

3.2E-08 

0.0E+00 

1.3E-08 

9.9E-08 

4.9E-08 

1.7E-07 

1.0E-08 

3.3E-09 

7.6E-08 

1.0E-07 

4.7E-06 

3.1E-07 

4.9E-08 

5.5E-06 

8.6E-07 

1.2E-08 

0.0E+00 

8.7E-07 

6.4E-06 

2.7E-03 

Average 

2.4E-08 

1.9E-08 

3.4E-08 

2.5E-08 

6.0E-08 

3.0E-09 

2.3E-08 

1.9E-07 

6.9E-08 

1.7E-07 

2.8E-08 

4.9E-09 

1.7E-07 

1.5E-07 

4.7E-06 

5.3E-07 

1.1E-07 

6.1E-06 

1.1E-06 

2.0E-08 

4.7E-09 

1.1E-06 

7JE-06 

2.7E-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 (in the 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. 

TABLE 5-2. PAH RESULTS FOR PUSHING - ABC COKE2 

7 PAH 

1 Benzo(a)anthracene 

2 Benzo(a)pyrene 

3 Benzo(b)fluoranthene 

4 Benzo(k)fluoranthene 

5 Chrysene 

6 Dibenzo(a,h)anthracene 

7 Idenod ,2,3-ccnDvrene 

Total 7 PAH 

16 PAH 

8 Acenaphthene 

9 Acenaphthylene 

10 Anthracene 

11 Benzo(g,h,i)perylene 

12 Fluoranthene 

13 Fluorene 

14 Naphthalene 

15 Phenanthrene 

16 Pyrene 

Total 16 PAH 

Other PAH 

2-Methylnaphthalene 

Benzo(e)pyrene 

Perylene 

Total Other PAH 

Total - all PAH 

Extractable organics (Ib/hr) 

Number of severely green pushes 

Number of moderately green pushes 

Number of nongreen pushes 

Total number of pushes 

Percent green 

Runl 

2.3E-05 

9.8E-06 

2.6E-05 

1.4E-05 

4.0E-05 

0.0E+00 

1.7E-05 

1.3E-04 

2.3E-05 

1.4E-04 

2.5E-05 

O.OE+00 

7.7E-05 

5.3E-06 

5.6E-04 

2.5E-04 

5.1E-05 

1.3E-03 

1.2E-04 

1.0E-05 

1.7E-06 

1.3E-04 

1.4E-03 

1.6E-02 

1 

3 

17 

21 

19 

BAGHOUSE INLET (lb/ton) 

Run 2 

1.3E-05 

3.4E-06 

9.3E-06 

6.6E-06 

2.1E-05 

0.0E+00 

7.7E-06 

6.1E-05 

7.7E-06 

6.4E-05 

7.7E-06 

0.0E+00 

3.2E-05 

2.9E-05 

2.1E-04 

9.5E-05 

2.3E-05 

5.3E-04 

4.3E-05 

4.6E-06 

5.0E-07 

4.8E-05 

5.8E-04 

9.8E-03 

0 

4 

17 

21 

19 

Run 3 

1.5E-05 

2.4E-06 

8.2E-06 

4.9E-06 

2.4E-05 

0.0E+00 

5.3E-06 

6.0E-05 

8.5E-06 

4.5E-05 

1.2E-05 

0.0E+00 

3.4E-05 

2.4E-05 

2.2E-04 

8.9E-05 

2.4E-05 

S.1E-04 

5.5E-05 

4.5E-06 

3.8E-07 

6.0E-05 

5.7E-04 

5.8E-03 

0 

4 

18 

22 

18 

Average 

1.7E-05 

5.2E-06 

1.5E-05 

8.6E-06 

2.9E-05 

0.0E+00 

1.0E-05 

8.4E-05 

1.3E-05 

8.2E-05 

1.5E-05 

O.OE+00 

4.8E-05 

1.9E-05 

3.3E-04 

1.4E-04 

3.3E-05 

7.7E-04 

7.2E-05 

6.4E-06 

8.6E-07 

7.9E-05 

8.4E-04 

1.0E-02 

Runl 

4.7E-07 

0.0E+00 

3.3E-07 

3.3E-07 

1.2E-06 

0.0E+00 

0.0E+00 

2.3E-06 

1.1E-05 

8.1E-05 

3.3E-05 

0.0E+00 

3.3E-05 

3.4E-05 

4.7E-04 

1.1E-04 

2.6E-05 

8.0E-04 

8.9E-05 

2.1E-07 

0.0E+00 

9.0E-05 

8.9E-04 

2.4E-02 

BAGHOUSE OUTLET 0b/ton) 

Run 2 

3.7E-07 

O.OE+00 

2.8E-07 

2.4E-07 

9.8E-07 

0.0E+00 

0.0E+00 

1.9E-06 

3.8E-06 

3.4E-05 

5.0E-06 

0.0E+O0 

5.0E-06 

1.1E-05 

1.4E-04 

6.9E-05 

1.2E-05 

2.9E-04 

3.7E-05 

0.0E+00 

0.0E+00 

3.7E-05 

3.2E-04 

4.9E-03 

Run 3 

3.7E-07 

0.0E+00 

3.3E-07 

2.2E-07 

1.1E-06 

0.0E+O0 

0.0E+00 

2.0E-06 

5.5E-06 

2.7E-05 

8.0E-06 

0.0E+00 

8.0E-06 

1.4E-05 

1.7E-04 

4.2E-05 

1.0E-05 

2.9E-04 

5.6E-05 

1.7E-07 

O.OE+00 

5.6E-05 

3.4E-04 

2.4E-03 

Average 

4.0E-07 

0.0E+00 

3.1E-07 

2.6E-07 

1.1E-06 

0.0E+00 

0.0E+00 

2.1E-06 

6.9E-06 

4.7E-05 

1.5E-05 

0.0E+00 

1.5E-05 

2.0E-05 

2.6E-04 

7.3E-05 

1.6E-05 

4.6E-04 

6.1E-05 

1.3E-07 

0.0E+00 

6.1E-05 

5.2E-04 

1.0E-02 

5-3 
P.48 

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 41 were not; the emission rate was 

0.0057 lb/t. 

• During Runs 1 and 3, three pushes were moderately green and 41 (average) were not; the 

emission rate averaged 0.0045 lb/t. 

• Let "x" equal the emission factor for uncontrolled non-green pushes and "y" the emission 

factor for uncontrolled moderately green pushes. 

Equations can be written for the test runs based on the number of each type of push and the 

capture efficiency for each type, which corresponds to what was captured and measured at the 

baghouse inlet. The equation for Run 2 (for extractable organics measured at me 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: 

or 

[(41)(0.9)(x) + (3)(.4)(y)]/44 = 0.0045 lb/t 

36.9 x + 1.2 y = 0.20 Equation (2) 

5-4 
P.49 

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 

7 PAH 

16 PAH 

Extractable organics 

lb/t for non-green 

6.7 x IO"6 

6.4 x 10"5 

3.5 x 10"3 

lb/t for moderately green 

2.3 x IO"4 

6.7 x IO"4 

5.8 xlO"2 

Ratio 

34 

10 

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. 

• Let "x" equal the uncontrolled emissions in lb/ton for the non-green pushes. 

• Let "y" equal the uncontrolled emissions in lb/ton for the moderately green pushes. 

• Let "z" equal the uncontrolled emissions in lb/ton for die severely green push during Run 

1. 

• 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) + (l)(0.1)(z)]/21 = 0.00013 lb/ton 

or 

15.3 x + 1.2 y + 0.1 z = 0.00273 Equation (I) 

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

[(17)(0.9)(x) + (4)(0.4)(y)]/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: 

[(18)(0.9)(x) + (4)(0.4)(y)]/21 = 0.000060 lb/ton 

or 

16.2 x + 1.6 y = 0.00126 Equation (3) 

Solving Equations (1), (2), and (3) for x, y, and z yields the following emission factors for the 

7-PAH: 

x = 4.3 E-5 for non-green pushes 

y = 3.0 E-4 for moderately green pushes 

z = 1.6 E-2 for severely green pushes. 

The procedure was repeated to derive emission factors for the 16-PAH. This approach could not 

be used for the extractable organics for ABC Coke because of the anomalous results for Run 2, 

which appear to be high by a factor of two based 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 
P.51 

TABLE 5-4. UNCONTROLLED EMISSION FACTORS FOR PUSHING Ob/ton coke) 

Pollutant 

7-PAH 

16-PAH 

Extractables 

NonBSC 

6.7 E-6 

6.4 E-5 

3.5 E-3 

jreen 

ABC 

4.3 E-5 

1.0 E-4 

1.3 E-3 

Moderately green 

BSC 

2.3 E-4 

6.7 E-4 

5.8 E-2 

ABC 

3.9 E-4 

6.0 E-3 

7.5 E-2 

Severely green 

ABC 

1.6 E-2 

1.9 E-l 

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 classified as: (1) batteries currently operate at the MACT level of control (Group 1), 

(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 wellcontrolled 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 
P.52 

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. 

TABLE 5-5. DISTRIBUTION OF GREEN PUSHES FOR DIFFERENT GROUPS OF 

BATTERIES 

Group 

1 

2 

3 

Percent of pushes in each category 

Severely green 

0.5 

2 

20 

Moderately green 

5 

20 

35 

Non-green 

94.5 

78 

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 

Type 

Non-green 

Moderately green 

Severely green 

Extractable organics (lb/ton of coke) 

0.0024 

0.067 

2.3 

5-8 
P.53 

The emission estimates are based on the following assumptions: 

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. 

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. 

Emissions from the control device are estimated as 0.0064 lb/ton 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 1 batteries is estimated as follows: 

(1) Emissions from non-green pushes: 

Fraction non-green x emission factor for non-green pushes x fraction not captured = 

0.945 x 0.0024 lb/ton x (1 - 0.9) = 0.0002 lb/ton 

(2) Emissions from moderately green pushes: 

Fraction moderately green x emission factor for moderately green pushes x fraction not captured 

0.05 x 0.067 lb/ton x (1-0.6) = 0.0013 lb/ton 

(3) Emissions from severely green pushes: 

Fraction severely green x emission factor for severely green pushes x fraction not captured = 

0.005 x 2.3 lb/ton x (1 - 0.1) = 0.010 lb/ton 

(4) Emissions from the control device: 

0.0064 lb/ton 

(5) Total for Group 1: 

0.0002 + 0.0013 + 0.010 + 0.0064 = 0.018 Iblton. 

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 in Group 3 have capture and control; therefore, only uncontrolled emission 

factors were developed for this group. 

5-9 
P.54 

TABLE 5-7 PUSHING EMISSION FACTORS 

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 EMISSIONS FROM BATTERY STACKS 

Estimates of emissions of extractable organics from battery stacks are based on me tests 

conducted by EPA. The test results are summarized in Tables 5-10 and 5-11 for Bethlehem Steel 

(Bums Harbor, IN) and ABC Coke (Birmingham, AL), respectively. The results are reasonably 

consistent except for Run 3 at Bums Harbor. This run had about 10 times more naphthalene and 

3 times more extractable organics than the other runs, hi addition, the extractable organics were 

20 to 30 times higher at Bethlehem Steel, but the PAH were 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 l3,4: 

C = - In (1.0 - Op)/constant Equation (1) 

5-10 
TABLE 5-8. NATIONWIDE ESTIMATES OF EXTRACTABLE ORGANICS 

EMISSIONS FROM PUSHING 

No. 

1 

2 

3 

4 

6 

7 

8 

9 

10 

11 

12 

15 

16 

18 

19 

20 

21 

22 

23 

24 

25 

25 

26 

27 

Plant 

ABC Coke, Tarrant, AL 

Acme Steel, Chicago, IL 

AK Steel, Ashland, KY 

AK Steel, Middletown, OH 

Bethlehem Steel, Bums Harbor, IN 

Bethlehem Steel, Lackawanna, NY 

Citizens Gas, Indianapolis, IN 

Empire Coke, Holt, AL 

Erie Coke, Erie, PA 

Geneva Steel, Provo, UT 

Gulf States Steel, Gadsden, AL 

Koppers, Monessen, PA 

LTV Steel, Chicago, IL 

LTV Steel, Warren, OH 

National Steel, Ecorse, MI 

National Steel, Granite City, IL 

New Boston, Portsmouth,OH 

Shenango, Pittsburgh, PA 

Sloss Industries, Birmingham, AL 

Tonawanda, Buffalo, NY 

USS, Clairton, PA 

0.2.3,7,8,9,13,14,153) 

USS, Clairton, PA (19&20) 

USS, Gary, IN 

Wheeling-Pitt, East Steubenville, WV 

Coke (tpy) 

803369 

513568 

1013992 

428300 

1845810 

795412 

687664 

151520 

152759 

746862 

545550 

375554 

631530 

573642 

981608 

592580 

340500 

371844 

464306 

218701 

3900000 

1100000 

1813483 

1346176 

TOTALS 

TABLE 5-9. CONCENTRATION / 

Opacity (%) 

1.7 

5 

10 

15 

-In (1 - Opa 

1.7 

5.1 

lO.f 

16 

Control? 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

Yes 

Yes 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

Yes 

Yes 

No 

Yes 

Yes 

Yes 

Yes 

• 

LDJUST 

city/100] 

Group 

1 

1 

2 

2 

1 

2 

2 

3 

2 

2 

3 

2 

1 

1 

1 

2 

2 

2 

2 

2 

1 

2 

2 

2 

lb/ton 

0.018 

0.018 

0.053 

0.053 

0.018 

0.053 

0.053 

0.480 

0.053 

0.053 

0.480 

0.053 

0.018 

0.018 

0.018 

0.053 

0.061 

0.053 

0.053 

0.061 

0.018 

0.053 

0.053 

0.053 

MENTS FOF 

> 

EXTRAC 

ORGAN1 

BASELINE 

7 

4.6 

26.9 

11.4 

16.6 

21.1 

18.2 

36.4 

4.0 

19.8 

130.9 

10.0 

5.7 

5.2 

8.8 

15.7 

10.4 

9.9 

12.3 

6.7 

35.1 

29.2 

48.1 

35.7 

529.7 

.TABLE 

CS(tpy) 

After MACT 

7.2 

4.6 

9.1 

3.9 

16.6 

7.2 

6.2 

1.4 

1.4 

6.7 

4.9 

3.4 

5.7 

5.2 

8.8 

5.3 

3.1 

3.3 

4.2 

2.0 

35.1 

9.9 

16.3 

12.1 

183.6 

I OPACITY 

Ratio to 1.7% opacity 

1 

3 

6.2 

9.4 

5-11 
P.56 

TABLE 5-10. TEST RESULTS FOR STACKS -- BETHLEHEM, BURNS HARBOR1 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

7 PAHs 

Benzo(a)anthracene 

Benzo(a)pyrene 

Benzo(b)fluoranthene 

Benzo(k)fluoranthene 

Chrysene 

Dibenzo(a,h)anthracene 

Ideno(l ,2,3-cd)pyrene 

Total 7 PAHs 

16 PAHs 

Acenaphthene 

Acenaphthylene 

Anthracene 

Benzo(g,h,i)perylene 

Fluoranthene 

Fluorene 

Naphthalene 

Phenanthrene 

Pyrene 

Total 16 PAHs 

Other PAHs 

2-Methylnaphthalene 

Benzo(e)pyrene 

Perylene 

Total Other PAHs 

Total - all PAHs 

Extractable Organics (Ib/hr) 

Average Opacity (%) 

Runl 

5.5E-06 

5.8E-06 

9.3E-06 

6.1E-06 

1.5E-05 

1.5E-06 

5.4E-06 

4.8E-05 

2.3E-05 

1.2E-04 

6.3E-06 

1.0E-05 

5.3E-05 

1.0E-04 

1.3E-03 

1.9E-04 

2.1E-05 

1.9E-03 

7.1E-04 

5.2E-06 

1.5E-06 

7.1E-04 

2.6E-03 

4.5 

4.7 

EMISSIONS (Ib/hr) 

Run 2 

3.0E-06 

2.9E-06 

5.5E-06 

3.8E-06 

7.2E-06 

O.OE+00 

3.9E-06 

2.6E-05 

1.3E-05 

3.5E-05 

2.4E-06 

9.5E-06 

2.7E-05 

2.8E-05 

3.7E-03 

8.6E-05 

9.7E-06 

3.9E-03 

2.4E-04 

3.9E-06 

O.OE+00 

2.4E-04 

4.2E-03 

3.7 

5.8 

Run 3 

7.4E-06 

3.3E-06 

6.6E-06 

4.0E-06 

1.6E-05 

O.OE+00 

3.6E-06 

4.1E-05 

4.6E-05 

2.7E-04 

8.9E-06 

6.5E-06 

6.4E-05 

1.3E-04 

1.9E-02 

1.7E-04 

2.3E-05 

1.9E-02 

8.4E-04 

3.5E-06 

O.OE+00 

8.4E-04 

2.0E-02 

12.4 

4.7 

Average 

5.3E-06 

4.0E-06 

7.1E-06 

4.6E-06 

1.3E-05 

4.9E-07 

4.3E-06 

3.9E-05 

2.8E-05 

1.4E-04 

5.8E-06 

8.6E-06 

4.8E-05 

8.7E-05 

7.8E-03 

1.5E-04 

1.8E-05 

8.4E-03 

6.0E-04 

4.2E-06 

4.9E-07 

6.0E-04 

9.0E-03 

6.9 

5.1 

5-12 
TABLE 5-11. TEST RESULTS FOR STACKS - ABC COKE2 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

7 PAHs 

Benzo(a)anthracene 

Benzo(a)pyrene 

Benzo(b)fluoranthene 

Benzo(k)fluoranthene 

Chrysene 

Dibenzo(a,h)anthracene 

Ideno(l ,2,3-cd)pyrene 

Total 7 PAHs 

16 PAHs 

Acenaphthene 

Acenaphthylene 

Anthracene 

Benzo(g,h,i)perylene 

Fluoranthene 

Fluorene 

Naphthalene 

Phenanthrene 

Pyrene 

Total 16 PAHs 

Other PAHs 

2-Methylnaphthalene 

Benzo(e)pyrene 

Perylene 

Total Other PAHs 

Total - all PAHs 

Extractable Organics (Ib/hr) 

Average Opacity (%) 

Runl 

8.6E-06 

1.2E-05 

1.5E-05 

O.OE+00 

2.0E-05 

0.0E+00 

O.OE+00 

5.6E-05 

1.5E-05 

8.6E-04 

3.3E-07 

O.OE+00 

2.9E-04 

5.0E-05 

5.3E-03 

5.9E-04 

1.5E-04 

7.3E-03 

1.5E-04 

1.6E-05 

O.OE+00 

1.7E-04 

7.5E-03 

0.23 

1.8 

EMISSIONS (lb/hr) 

Run 2 

4.7E-06 

9.9E-06 

2.0E-05 

1.2E-07 

2.2E-05 

0.0E+00 

O.OE+00 

5.6E-05 

1.1E-05 

3.2E-03 

4.1E-07 

0.0E+00 

5.6E-04 

3.2E-05 

6.1E-03 

9.4E-04 

9.9E-04 

1.2E-02 

1.1E-04 

6.6E-05 

0.0E+00 

1.8E-04 

1.2E-02 

0.20 

1.6 

Run 3 

0.0E+00 

O.OE+00 

1.1E-05 

O.OE+00 

1.5E-05 

0.0E+00 

0.0E+00 

2.5E-05 

6.0E-06 

6.5E-04 

1.1E-05 

O.OE+00 

2.4E-04 

1.8E-05 

3.8E-03 

4.9E-04 

1.7E-04 

5.4E-03 

7.9E-05 

1.8E-05 

O.OE+00 

9.7E-05 

5.5E-03 

0.36 

2.8 

Run 4 

7.2E-06 

7.7E-06 

1.3E-05 

1.4E-07 

2.5E-05 

0.0E+00 

0.0E+00 

5.3E-05 

1.2E-05 

0.0E+00 

3.6E-07 

0.0E+00 

3.4E-04 

6.3E-05 

4.8E-03 

8.5E-05 

2.2E-04 

5.5E-03 

2.1E-04 

1.4E-05 

0.0E+00 

2.2E-04 

5.7E-03 

0.09 

0.7 

Average 

5.1E-06 

7.5E-06 

1.4E-05 

6.4E-08 

2.0E-05 

O.OE+00 

O.OE+00 

4.7E-05 

T.1E-05 

1.2E-03 

3.0E-06 

0.0E+00 

3.6E-04 

4.1E-05 

5.0E-03 

5.3E-04 

3.8E-04 

7.5E-03 

1.4E-04 

2.8E-05 

0.0E+00 

1.7E-04 

7.7E-03 

0.22 

* 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 opacities to reflect the higher 

concentrations. The concentration adjustments for batteries with opacities of 5%, 10%, and 15% 

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

5-13 
P.58 

For example, if the ABC 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 product 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 acfm. 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 lb/hr) 

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

5.2.3 Extrapolation to Other Batteries 

Information on stack opacity and volumetric flow rate are needed to extrapolate the 

results from the 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 MACT level 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 (Bums Harbor) 

batteries are used to estimate the level achievable by MACT. The average opacity ranges 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 cfm. 

0.22 lb/hr (ABQx 6.2 (adjustment for 10% opacity)x[(30,000 acfm)+(ABC acfm of 83,000)] = 

0.49 lb/hr = 2.2 tpy 

5-14 
P.59 

A similar procedure was used for the other batteries to give the results shown in Table 5-13. 

TABLE 5-12. SUMMARY OF BATTERY STACK OPACITY DATA 

Plant 

USS Gary 

Battery 

2 

3 

5 

7 

Range (baseline before MACT) 

USS Clairton 

Bethlehem, Burns Harbor 

13 

14 

15 

20 

B 

1 

2 

Range (after MACT) 

Average opacity 

(%) 

10.5 

8.8 

7.5 

9.6 

7.5 to 10.5 

2.1 

1.8 

2.9 

1.5 

4.3 

4.5 

3.8 

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 

1/99 through 3/99 

1/99 through 3/99 

1/99 through 3/99 

1/99 through 3/99 

8/93 through 7/99 

12/94 through 7/99 

5-15 
P.60 

« 

TABLE 5-13. ESTIMATES OF EXTRACTABLE ORGANIC EMISSIONS FROM 

BATTERY STACKS 

Plant 

ABC Coke, Tarrant, AL 

ABC Coke, Tarrant, AL 

Acme Steel, Chicago, IL 

Acme Steel, Chicago, IL 

AK Steel, Ashland, KY 

AK Steel, Ashland, KY 

AK Steel, Middletown, OH 

Bethlehem Steel, Burns Harbor, IN 

Bethlehem Steel, Burns Harbor, IN 

Bethlehem Steel, Lackawanna, NY 

Bethlehem Steel, Lackawanna, NY 

Citizens Gas, Indianapolis, IN 

Citizens Gas, Indianapolis, IN 

Citizens Gas, Indianapolis, IN 

Empire Coke, Holt, AL 

Erie Coke, Erie, PA 

Geneva Steel, Provo, UT 

Geneva Steel, Provo, UT 

Geneva Steel, Provo, UT 

Geneva Steel, Provo, UT 

Gulf States Steel, Gadsden, AL* 

Gulf States Steel, Gadsden, AL* 

Koppers, Monessen, PA 

Koppers, Monessen, PA 

LTV Steel, Chicago, IL 

LTV Steel, Warren, OH 

National Steel, Ecorse, MI 

National Steel, Granite City, EL 

National Steel, Granite City, IL 

New Boston, Portsmouth, OH* 

Shenango, Pittsburgh, PA 

Sloss Industries, Birmingham, AL* 

Sloss Industries, Birmingham, AL* 

Tonawanda, Buffalo, NY 

USS, Clairton, PA 

USS, Clairton, PA 

USS^Clairton, PA 

Battery 

5&6 

IA 

1 

2 

3 

4 

W 

1 

2 

7 

8 

E 

H 

1 

1,2 

A,B 

1 

2 

3 

4 

2 

3 

IB 

2 

2 

4 

5 

A 

B 

2 

1 

3 &4 

5 

2 

1 

2 

3 

Stack gas flow 

rate (acfm) 

185,000 

187,000 

30,000 

30,000 

70,900 

185,100 

137,400 

226,000 

164,000 

209,869 

176,013 

25,000 

25,000 

37,200 

94,545 

37,900 

80,000 

83,000 

100,000 

110,000 

100,000 

100,000 

37,645 

19,196 

94,280 

187,170 

343,000 

83,700 

103,700 

35,000 

101,000 

85,000 

85,000 

97,000 

82,100 

90,750 

74,150 

5-16 

Extractable organic 

emissions (tpy) 

Baseline 

6.4 

13.5 

2.2 

2.2 

5.1 

13.3 

9.9 

7.9 

5.7 

15.1 

12.7 

1.8 

1.8 

2.7 

6.8 

2.7 

5.8 

6.0 

7.2 

7.9 

7.2 

7.2 

2.7 

1.4 

6.8 

13.5 

24.7 

6.0 

7.5 

2.5 

7.3 

6.1 

6.1 

7.0 

2.9 

3.2 

2.6 

After MACT 

6.4 

6.5 

1.0 

1.0 

2.5 

6.4 

4.8 

7.9 

5.7 

7.3 

6.1 

0.9 

0.9 

1.3 

3.3 

1.3 

2.8 

2.9 

3.5 

3.8 

3.5 

3.5 

1.3 

0.7 

3.3 

6.5 

11.9 

2.9 

3.6 

1.2 

3.5 

3.0 

3.0 

3.4 

2.9 

3.2 

2.6 
P.61 

TABLE 5-13. ESTIMATES OF EXTRACTABLE ORGANIC EMISSIONS FROM 

BATTERY STACKS (continued) 

Plant 

USS, Clairton, PA 

USS, Clairton, PA 

USS, Clairton, PA 

USS, Clairton, PA 

USS, Clairton, PA 

USS, Clairton, PA 

USS, Clairton, PA 

USS, Clairton, PA 

USS, Clairton, PA 

USS, Gary, IN 

USS, Gary, IN 

USS, Gary, IN 

USS, Gary, IN 

Wheeling-Pittsburgh, East Steubenville, WV* 

Wheeling-Pittsburgh, East Steubenville, WV* 

Wheeling-Pittsburgh, East Steubenville, WV* 

Wheeling-Pittsburgh, East Steubenville, WV* 

Battery 

7 

8 

9 

13 

14 

15 

19 

20 

B 

2 

3 

5 

7 

1 

2 

3 

8 

Stack gas flow 

rate (acfm) 

79,950 

86,700 

88,700 

71,600 

76,000 

74,600 

149,000 

133,000 

207,500 

116,908 

179,959 

67,824 

80,070 

37,000 

37,000 

37,000 

164,000 

TOTALS 

Extractable organic 

emissions (tpy) 

Baseline 

2.8 

3.0 

3.1 

2.5 

2.6 

2.6 

5.2 

4.6 

7.2 

8.4 

13.0 

4.9 

5.8 

2.7 

2.7 

2.7 

11.8 

337 

After MACT 

2.8 

3.0 

3.1 

2.5 

2.6 

2.6 

5.2 

4.6 

7.2 

4.1 

6.3 

2.4 

2.8 

1.3 

1.3 

1.3 

5.7 

195 

* Volumetric flow rate was estimated from the industry average of 0.3 acfm/tpy coke. 

5-17 
P.62 

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 1977 by York Research under contract to EPA.5 The testing included 15 

runs (four to six quenches per run)— six runs for quenching using clean quench water with nongreen coke, five with 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 to emissions of organic compounds during quenching; however, most plants no 

longer use contaminated water. Grab samples taken for benzene showed low levels of 0.01 to 

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 identifying 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 tall quench 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. This probably 

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 
TABLE 5-14. RESULTS OF QUENCH TOWER EMISSION TESTS AND WATER ANALYSES5 

Pollutant 

7 PAH 

16 PAH 

Total PAH 

BaPc 

PM 

Aniline 

Phenol 

Toluidine 

Quench tower emissions (g/Mg coal)1 

Clean water 

Non-green 

pushes 

0.11 

0.29 

0.42 

Green 

pushes 

0.22 

0.68 

1.17 

Dirty water 

Non-green 

pushes 

3.6 

27 

32.1 

0.024 

790 

0.012 

620 

0.081 

1,100 

0.0008 

0.4 

0.0004 

0.0005 

0.8 

— 

2.8 

243 

1.0 

Quench water analyses (g/Mg coal) 

Clean water 

Supply 

0.052 

0.057 

0.081 

Nozzle" 

0.011 

0.029 

0.033 

Dirty water 

Flushing 

liquor 

3.2 

12.3 

16.6 

~ 

~ 

0.016 

— 

0.18 

~ 

— 

— 

— 

~ 

~ 

— 

1.8 

1.7 

1.2 

NozzIeb 

1.2 

4.2 

6.0 

0.27 

~ 

0.54 

1.4 

0.11 

Abbreviations: PAH=polycyclic aromatic hydrocarbons, BaP=benzo(a)pyrene, PM=particulate matter. 

" Divide by 500 (or multiply by 0.002) to convert to lb/ton of coal. 

b

 Water sprayed on the coke; sample taken at the nozzle 

c

 Results based on a special analysis with high sensitivity for BaP, a traditional indicator for coke oven emissions. 

5-19 
P.64 

apply to the organics. In summary, the test report provides the only useful information found 

with which to estimate HAP emissions from quenching. 

5.3.2 Extrapolation 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 (lb/ton coal) = 0.29 g/Mg x 0.002 (g/Mg to lb/ton) = 0.00058 

EOM (lb/ton coal) = 0.00058 + 0.08 = 0.007 

For green pushes and clean water: 

16-PAH (lb/ton 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 

0b/ton coal) 

16-PAH 

0.00058 

EOM 

0.007 

Factor for severely green pushes (lb/ton coal) 

16-PAH 

0.0014 

EOM 

0.018 

The estimates in Section 5.1 (Pushing Emissions) used values of 0.5%, 2% and 20% for 

severely green pushes for Groups 1,2, and 3. The same group assignments were used in 

Table 5-15 to estimate emissions from quenching. An example calculation is given below for 

ABC Coke assuming 0.5% of the pushes are severely green: 

(0.007 lb/ton x 0.995 + 0.018 lb/ton x 0.005) x 1,160,000 tpyxl ton/2,000 lb = 4.1 tpy. 

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

5-20 
ITABLE 5-15. ESTIMATES OF EXTRACTABLE ORGANIC EMISSIONS FROM 

QUENCHING 

No. 

1 

2 

3 

4 

6 

7 

8 

9 

10 

11 

12 

15 

16 

18 

19 

20 

21 

22 

23 

24 

25 

25 

26 

27 

Plant 

ABC Coke, Tarrant, AL 

Acme Steel, Chicago, IL 

AK Steel, Ashland, KY 

AK Steel, Middletown, OH 

Bethlehem Steel, Burns Harbor, IN 

Bethlehem Steel, Lackawanna, NY 

Citizens Gas, Indianapolis, IN 

Empire Coke, Holt, AL 

Erie Coke, Erie, PA 

Geneva Steel, Provo, UT 

Gulf States Steel, Gadsden, AL 

Koppers, Monessen, PA 

LTV Steel, Chicago, IL 

LTV Steel, Warren, OH 

National Steel, Ecorse, Ml 

National Steel, Granite City, IL 

New Boston, Portsmouth.OH 

Shenango, Pittsburgh, PA 

Sloss Industries, Birmingham, AL 

Tonawanda, Buffalo, NY 

USS, Clairton, PA 

(1,2,3,7,8,9,13,14,153) 

USS, Clairton, PA (19&20) 

USS, Gary, IN 

Wheeling-Pitt, East Steubenville, WV 

Coke 

(tpy) 

803,369 

513,568 

1,013,992 

428,300 

1,845,810 

795,412 

687,664 

151,520 

152,759 

746,862 

545,550 

375,554 

631,530 

573,642 

981,608 

592,580 

340,500 

371,844 

464,306 

218,701 

3,900,000 

1,100,000 

1,813,483 

1,346,176 

Coal 

(tpy)* 

1,164,303 

744,301 

1,469,554 

620,725 

2,675,087 

1,152,771 

996,614 

219,594 

221,390 

1,082,409 

790,652 

544,281 

915,261 

831,365 

1,422,620 

858,812 

493,478 

538,904 

672,907 

316,958 

5,652,174 

1,594,203 

2,628,236 

1,950,980 

Percent 

Severely 

Green 

0.5 

0.5 

2 

2 

0.5 

2 

2 

20 

2 

2 

20 

2 

0.5 

0.5 

0.5 

2 

2 

2 

2 

2 

0.5 

2 

2 

2 

lb/ton 

7.06e-3 

7.06e-3 

7.22e-3 

7.22e-3 

7.06e-3 

7.22e-3 

7.22e-3 

9.2e-3 

7.22e-3 

7.22e-3 

9.2e-3 

7.22e-3 

7.06e-3 

7.06e-3 

7.06e-3 

7.22e-3 

7.22e-3 

7.22e-3 

7.22e-3 

7.22e-3 

7.06e-3 

7.22e-3 

7.22e-3 

7.22e-3 

TOTALS 

EXTRACTABLE 

ORGANICS (tpy) 

BASELINE 

4.1 

2.6 

5.3 

2.2 

9.4 

4.2 

3.6 

1.0 

0.8 

3.9 

3.6 

2.0 

3.2 

2.9 

5.0 

3.1 

1.8 

1.9 

2.4 

1.1 

20.0 

5.8 

9.5 

7.0 

106.6 

After MACT 

4.1 

2.6 

5.2 

2.2 

9.4 

4.1 

3.5 

0.8 

0.8 

3.8 

2.8 

1.9 

3.2 

2.9 

5.0 

3.0 

1.7 

1.9 

2.4 

1.1 

20.0 

5.6 

9.3 

6.9 

104.3 

Estimate based on a typical yield of 0.69 ton of coke per ton of coal. 

5-21 
P.66 

5.4 OTHER ENVIRONMENTAL IMPACTS 

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 quantify these 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 HAP 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 cracks in oven walls, repairing damaged ovens, and other work practices that reduce the 

amount of coke oven gas leaking through me 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 Bums Harbor Division in Chesterton, Indiana, 

EPA-454/R-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. Report, 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. Report, 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 
P.67 

1 

_• 

APPENDIX C. EMISSION FACTORS FOR BY-PRODUCT RECOVERY PROCESSES 

IN REVISED AP-42 
TABLE 4-30. COKE BYPRODUCT PLANT EMISSION FACTORS FOR BENZENE AND BTXa 

EMISSION FACTOR RATING: E, EXCEPT AS NOTED 

Type of byproduct 

plant operation 

Light-oil storage 

tankb 

Tar decanter 

Naphthalene 

separation and 

processing 

Cooling tower 

Tar intercepting sump 

Tar dewatering tank 

Tar storage tank 

Light-oil condenser 

vent 

Light-oil sump 

BTX storage" 

Control device 

Uncontrolled 

Gas blanketing 

Uncontrolled 

Gas blanketing 

Uncontrolled 

Activated carbon 

Direct-water, 

uncontrolled 

Tar-bottom, 

uncontrolled 

Uncontrolled 

Uncontrolled 

Gas blanketing 

Uncontrolled 

Gas blanketing 

Uncontrolled 

Gas blanketing 

Uncontrolled 

Gas blanketing 

Uncontrolled 

Gas blanketing 

Benzene 

Furnace plant 

kg/Mg 

0.0058 

0.00012 

0.054c 

0.0011° 

0.11 

0.00035 

0.27 

0.070 

0.0095 

0.02 ld 

0.00045 

0.0066d 

0.00038 

0.089 

0.0018 

0.015" 

0.00030 

0.0058 

0.00012 

lb/ton 

0.0116 

0.00024 

0.108c 

0.0022c 

0.22 

0.00070 

0.54 

0.14 

0.019 

0.042d 

0.00084 

0.0132d 

0.00076 

0.178 

0.0036 

0.030-1 

0.00060 

0.0116 

0.00024 

Foundry plant 

kg/Mg 

0.0031 

0.00006 

0.025 

0.0005 

0.08 

0.00025 

0.20 

0.051 

0.0045 

0.0099 

0.00020 

0.0031 

0.00018 

0.048 

0.00097 

0.0081 

0.00016 

0.0031 

0.000060 

lb/ton 

0.0062 

0.00012 

0.050 

0.0010 

0.16 

0.00050 

0.40 

0.102 

0.0090 

0.0198 

0.00040 

0.0062 

0.00036 

0.096 

0.00194 

0.0162 

0.00032 

0.0062 

0.00012 

Bl 

Furnace plant 

kg/Mg 

0.0083 

0.00017 

0.077 

0.0016 

0.16 

0.00050 

0.69 

0.10 

0.014 

0.030 

0.00060 

0.0094 

0.00054 

0.13 

0.0026 

0.021 

0.00043 

0.0083 

0.00017 

lb/ton 

0.0166 

0.00034 

0.154 

0.0032 

0.32 

0.0010 

1.38 

0.20 

0.028 

0.060 

0.0012 

0.0188 

0.00108 

0.26 

0.0052 

0.042 

0.00086 

0.0166 

0.00034 

rx 

Foundry plant 

kg/Mg 

0.0049 

0.000094 

0.039 

0.00079 

0.13 

0.00039 

0.61 

0.080 

0.0071 

0.016 

0.00031 

0.0049 

0.00028 

0.076 

0.0015 

0.013 

0.0025 

0.0049 

0.000094 

lb/ton 

0.0098 

0.000188 

0.078 

0.00158 

0.26 

0.00078 

1.22 

0.16 

0.014 

0.032 

0.00062 

0.0098 

0.00056 

0.152 

0.0030 

0.026 

0.0050 

0.0098 

0.000188 

> ST 

H 3 

z re 3 

ft) _£• 

5 X o 

• • r > 

8, 9 •-• 

(sj oo "p 
O 

Type of byproduct 

plant operation 

Benzene storage" 

Flushing liquor 

circulation tank 

Excess-ammonia 

liquor tank 

Wash-oil decanter 

Wash-oil circulation 

tank 

Control device 

Uncontrolled 

Gas blanketing 

Uncontrolled 

Gas blanketing 

Uncontrolled 

Gas blanketing 

Uncontrolled 

Gas blanketing 

Uncontrolled 

Gas blanketing 

Benzene 

Furnace plant 

kg/Mg 

0.0058 

0.00012 

0.013c 

0.00026 

0.0014 

0.000028 

0.0038 

0.000076 

0.0038 

0.000076 

lb/ton 

0.0116 

0.00024 

0.026c 

0.00052 

0.0028 

0.000056 

0.0076 

0.00015 

0.0076 

0.00015 

Foundry plant 

kg/Mg 

0.0031 

0.00006 

0.0095 

0.00019 

0.0010 

0.000020 

0.0021 

0.000041 

0.0021 

0.000041 

lb/ton 

0.0062 

0.00012 

0.019 

0.00038 

0.0020 

0.000040 

0.0042 

0.000082 

0.0042 

0.000082 

BTX 

Furnace plant 

kg/Mg 

0.0058 

0.00012 

0.019 

0.00037 

0.0020 

0.000040 

0.0054 

0.00011 

0.0054 

0.00011 

lb/ton 

0.0116 

0.00024 

0.038 

0.00074 

0.0040 

0.00008 

0.0108 

0.00022 

0.0108 

0.00022 

Foundry plant 

kg/Mg 

0.0031 

0.00006 

0.015 

0.00030 

0.0016 

0.000031 

0.0033 

0.000065 

0.0033 

0.000065 

lb/ton 

0.0062 

0.00012 

0.030 

0.00060 

0.0032 

0.000062 

0.0066 

0.00013 

0.0066 

0.00013 

Emission factor units are kg/Mg and lb/ton of coke pushed. BTX = benzene, toluene and xylene. Benzene emission factors in this table are derived from 

References 29 through 38. The emission factors for BTX are estimated from equations given in the text and developed from References 26 and 27. 

Uncontrolled emission factors represent pre-byproduct plant pre-NESHAP control levels; controlled emission factors represent post-NESHAP control levels. 

No emissions are allowed from naphthalene processing. 

The reader may also use EPA's TANKS program to estimate emissions from this source. The program is available in electronic form through EPA's 

Technology Transfer Network. For information call (919) 541-5285. 

The benzene emission factor rating for this furnace plant operation is D. 

The benzene emission factor rating for this furnace plant operation is B.