_____ 

OAR Box 1770 

Prepped by Keeia Richards 

Document Number: 

39.XII-D-9 

Docket Number: 

A-79-15 

Printed 10/28/2008 10:20:29 AM Sheet 39 of 93 
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P.2 

Docket No. A-79-15 

Item No. XII-D-9 

,COAi 

American Coke and Coal Chemicals Institute 

1255 Twenty-Third Street, NW • Washington, DC 20037-1174 • (202) 452-1140 • Fax: (202) 833-3636 

December 23, 1999 

Walter A. Palmer 

ICF Inc. 

9300 Lee Highway 

Fairfax, VA 22031-1207 

"Re:reOETF-Comments-onieFs-Preliminary-Draft-_;ist-of-Model-lnput-Values~ 

Dear Walt: 

On Tuesday, November 2 Kamal Singh of ICF sent an e-mail to me setting 

forth the preliminary draft list of model input values being considered as default 

or "generic" inputs for the residual risk assessment that ICF is conducting for 

EPA of MACT Track coke oven batteries (see Enclosure 1)). Since then 

representatives of the coke industry group addressing the matter — the 

AISI/ACCCI Coke Oven Environmental Task Force (COETF (see Enclosure 

2)) — have met on several occasions to review/discuss this draft list towards 

providing EPA and ICF with respective comments and suggestions in an 

expeditious manner. On one such occasion, you and other ICF 

representatives kindly met with COETF representatives via conference call, 

which we very much appreciated. The COETF has completed it review of the 

draft list. Our comments are included with this letter (see Enclosure 3). 

Please note in your review of our comments on Table 6 that one document to 

which our comments refer — a Final Report on a COETF project to compile 

facility-specific Method 21 data and stream materials analysis data from four 

coke by-product plants — is not included because the project is not yet 

complete. As noted in our comments, the results to date of this project indicate 

that benzene emission levels from these plants are more than two orders of 

magnitude below those estimated using the draft AP-42 emission factors. 

These new factors, which should be used for coke by-product plants to reflect 

current (i.e., post-NESHAP) control levels, will be included in the Final Report. 

We plan to submit the Final Report to you upon its completion in January 

2000. 

Our comments also point out the importance of using plant-specific values, 

rather than default or generic values, whenever possible. Towards that end, we 

know that ICF has been in contact with the operators of MACT Track batteries, 

to obtain such information. We understand that the requested information either 

has been or soon will be forwarded to ICF. 
P.3 

ENCDDSURE 1 

Preliminary Draft List of Model Input Values 

ICF Consulting is conducting screening-level atmospheric dispersion modeling to project atmospheric 

concentrations and surface deposition rates of gaseous, vapor phase, and particulate air pollutants emitted 

from coke oven facilities. 

The model first simulates plume rise using1 USEPA guideline Buoyant Line Source Model (BLP) and 

second simulates dispersion and deposition using USEPA endorsed Industrial Source Complex (ISCST3) 

model. ICF has conducted a very preliminary screening run with this model, using hypothetical or default 

data from a combination of sources, and conservative assumptions. The inputs used for the screening run 

and the corresponding sources of information are listed below. 

Table 1: Model Inputs Used for the BLP Modeling. 

Parameter 

Buovancv Flux - Convective He 

Number of ovens for battery 

number 3 

Total number of ovens for 

plume rise calculations 

Height of oven 

Width of oven 

Length of oven 

Diameter of oven offtakes 

Offtake height 

Surface temp of oven door 

Surface temp of oven top 

Surface temp of offtake 

Ambient temp 

Average coal throughput 

Buovancv Flux - Fugitive Emiss 

Charging 

PMIO emission factor 

PMIO per unit volume per 

opacity % 

Percent opacity 

Exit temperature 

Door Leaks • 

PMIO emission factor 

PMIO per unit volume per 

opacity % 

Percent opacity 

Exit temperature 

Model 

Input 

Value 

at Transfer 

76 

76 

13.1 

2.2 

43.8 

2 

5 

425 

422 

422 

293 

0.90 

ions 

0.0004 

3.00E-07 

60 

626 

0.02 

3.00E-07 

60 

626 

Units 

ft 

ft 

ft 

ft 

ft 

K 

K 

K. 

K. 

ton coal/(hrovcn) 

(lb PMlO/ton 

coal) 

Ib/ft3 

% 

K 

(IbPMlO/ion 

coal) 

lb/ft. 

% 

K 

-

Source 

A K Steel, Middletown, Battery Number 3. 

A K Steel, Middletown (Batteries 1 and 2 shutdown 

on 12/31/95). 

"Coke Oven NESHAP Track Selection Table," 

ACCCI, March 1998. Data for A K Steel 

Middletown. 

"Site-Specific Modeling Methodology for Assessing 

Risk Associated with Emissions from Coke Oven 

Facilities," prepared by Sciences International Inc., 

1998. Data for Geneva Steel. Henceforth referred 

to as "Geneva Steel." 

Geneva Steel. 

Geneva Steel. 

Geneva Steel. 

Geneva Steel. 

Geneva Steel. 

Geneva Steel. 

Engineering judgement. 

Section 114 Coke Facilities Survey. Table 2: 

Summary of Battery Design and Operation. 1997 

data for A K Steel Middletown. 

Draft AP-42 Table 12.2-2. Assuming postNESHAP controls. 

Allegheny County Health Department (ACHD). 

1995. Liberty Borough PM-10 SIP Buoyancy 

Calculations. Henceforth referred to as "ACHD." 

ACHD. 

Geneva Steel. 

Draft AP-42 Table 12.2-2. Assuming postNESHAP controls. 

ACHD. 

ACHD. 

Geneva Steel. 
P.4 

Ambient temperature of 293 K, 

Anemometer height of 10-m, 

Surface pressure of 1000 mb, 

Rural dispersion curves, 

A nominal value of 0.10 meters (suburban) for surface roughness (_<,), 

Friction velocity, u.=ku /In (_/_<,), where k is von Karman constant of 0.4, 

No precipitation, 

Monin-Obukhov length as a function of surface roughness and stability class as defined by Golder 

(1972), 

State of Vegetation - Unstressed and Active, 

Default values for gases in vegetation/land: cuticle resistance, ground resistance and reference 

resistance of pollutant to reactivity through leaf- expressed in terms of SO2" cuticle resistance 30 s/cm, 

ground resistance = 10 s/cm, pollutant reference reactivity = 8, 

Incoming solar radiation: based on scheme implemented in MPPJvl (Irwin et al., 1988) - per Table 2, 

Leaf Area Index - ratio of leaf surface area divided by ground surface area; 0.2 based on a urban or 

built-up areaDeposition over land only, 

Pollutant-specific parameters for the two primary gas-phase pollutants from coke oven emissions, 

benzene and naphthalene, per Table 3 (molecular diffusivity from Fletcher et al., 1997; mesophyll 

resistance from EPA, 1993a), 

Benzene Soluble Organic (BSO) emission rates for fugitive emission points per Table 4. 

Table 2: Assumed Solar Radiation Values. 

Stability Class 

A 

B 

C 

D 

E andF 

Wind Speed 

(m/s) 

2to3 

<2 

3 to 5 

2to3 

<2 

>6 

5 to 6 

2 to 5 

>6 

5 to 6 

<5 

. 

Solar Radiation 

(W/m2) 

1050 

925 

925 

800 

425 

1050 

925 

425 

425 

175 

88 

0 

Table 3: Pollutant-Specific Parameters. 

Pollutant 

Benzene 

Naphthalene 

Molecular 

Diffusivity (Dm) 

0.0912 cm2/s 

0.0590 cm2/s 

Pollutant Reactivity 

Parameter (A) 

10 (moderate value) 

10 (moderate value) 

Mesophyll Resistance Term (.„) 

10 (high degree of solubility) 

100 (insoluble in water) 

Table 4: Emission Rate Inputs Used for the ISCST3 Modeling. 

Emission Point Best Estimate of 

BSO Emission 

Rate (lb/hr) 

Source 

Doors 1.0943 EPA method 303 observations 
P.5 

Emission Point 

Tar storage tank with gas blanketing 

Light-oil condenser vent with gas 

blanketing 

Light-oil sump with gas blanketing 

BTX storage with gas blanketing 

Benzene storage with gas blanketing 

Flushing liquor circulation tank with gas 

blanketing 

Excess-ammonia liquor tank with gas 

blanketing 

Wash-oil decanter with gas blanketing 

Wash-oil circulation tank with gas 

blanketing 

Benzene (Ib/hr) 

0.04 

0.18 

0.03 

0.01 

0.01 

0.03 

0.00 

0.01 

0.01 

BTX (Ib/hr) 

0.05 

0.25 

0.04 

0.02 

0.01 

0.04 

0.00 

0.01 

0.01 
P.6 

ENCLOSURE 2 

AISI/ACCCI Coke Oven Environmental Task Force 

Steve Felton, Chairman 

Mark Poling 

Jack Garzella 

Charlie Luthar 

W ade Kohlmann 

" Dannylrewis 

Russ Christensen 

Buster Stewart 

George Bradley 

Traci Self 

Rich Zavoda 

Jack Heintz 

Mike Mehalovich 

Nick Buchko 

Bobby Fisher 

Tim Huxley 

Mark Kamholz 

Bill Graeser 

Bill Samples 

AK Steel Corporation 

ABC Coke 

Acme Steel Company 

Bethlehem Steel Corporation 

CitizensGas&Coke Utility 

Empire Coke Company 

Geneva Steel 

Gulf States Steel, Inc. 

Indiana Harbor Coke Company 

Koppers Industries, Inc. 

LTV Steel Company 

National Steel Corporation 

New Boston Coke Corporation 

Shenango Inc. 

Sloss Industries Corporation 

Stelco Inc. 

Tonawanda Coke Corporation 

USS Clairton 

Wheeling-Pittsburgh Steel Corporation 

R024H.1/12-17-99 
P.7 

Table 6. Table 6 provides the by-product plant benzene and BTX emission factors 

(expressed as Ib/hr) for various emission sources, including storage tanks, process 

vessels, sumps, and other operations (e.g., cooling towers, light oil condenser vents, 

etc.). These are based on draft AP-42 emission factors, which were primarily derived 

from emission tests conducted in the 1980s in support of EPA's Coke By-Product 

Recovery Plant NESHAP. These emission factors are based on limited source test 

data and do not account for plant-specific process design, plant operating parameters 

(e.g., coal volatility, coking temperatures and cycles, etc.), and plant maintenance 

activities. 

The COETF supports the use of alternative emission models, such as EPA's TANKS 

program and AP-42 liquid loading equation, which incorporate facility-specific information 

such as tank orientation and dimensions, average vapor space height, liquid 

composition, tank temperature and throughput, and local climatological data into the 

emission calculations. 

Some of the sources listed in Table 6 (most notably the direct water cooling tower, 

which accounts for over 75 percent of the total benzene emissions listed in the table) 

were required, under the above referenced NESHAP, to be taken out of service and 

are no longer used by the industry. 

Table 6 failed to include benzene emission factors for equipment leaks (e.g. valves, 

flanges, pumps, exhausters, etc.). The COETF supports the use of refined emission 

estimation techniques for equipment leaks in lieu of the draft AP-42 emission factors, 

which are based on pre-1980 refinery leak data. The draft AP-42 factors were derived 

from limited test data from largely uncontrolled plants using sampling/analysis protocols 

which do not meet current EPA standards. Since the development of these factors, leak 

detection and repair requirements (e.g., EPA's Coke By-Product Recovery Plant 

NESHAP) and improved equipment design have resulted in much lower fugitive 

hydrocarbon leak rates throughout the chemical process industries, including the 

SOCMI, petroleum refinery, and coke by-product recovery industries. 

EPA has developed refined emission estimation methodologies which incorporate 

periodic facility equipment leak monitoring (i.e., Method 21) data, equipment-specific 

correlation equations relating monitored screening concentrations to mass emission rates, 

and default zero emission rates (for equipment components which screen at background 

concentrations). The 1995 EPA protocol document for equipment leak emission 

estimates (EPA-453/R-95- 017) contains the most recently derived leak rate correlation 

equations, which we recommend for use in estimating coke by-product plant benzene 

emissions. The COETF is nearing completion of a project to compile facility-specific 

Method 21 data and stream materials analysis data from four coke by-product plants, to 

which the EPA correlation equations and default zero emission rates were applied. The 

results of this project, which will discussed in a Rnal Report that we plan to submit to you 

upon its completion in January 2000, indicate that benzene emission levels from these 

plants are more than two orders of magnitude below those estimated using the draft 

AP-42 emission factors. These new factors should be used for coke by-product plants > 

to reflect current (i.e., post-NESHAP) control levels. 
P.8 

T 

TABLE 7-3. LID AND OFFTAKE LEAK BASELINE LIMITS AND 

ESTIMATED EMISSION RATES 

Lid limit Estimated average Offtake limit Estimated average3 

(PLL) (PLL) (PLO) (PLO) 

5 3.5 10 6.5 

4 2.6 6 3.5 

3 1.9 5 2.9 

2 1.1 4 . 2.2 

1 0.6 

aThe minimum estimated emission rate is 0.0033 kg/hr per leak. 

The maximum estimated emission rate is~0."021~ kg/hr" per'leak. 

7-6