MEMORANDUM

DATE:	May 1, 2023

FROM:	Donna Lee Jones, U.S. Environmental Protection Agency; Gabrielle Raymond, RTI International
	U.S. Environmental Protection Agency, Research Triangle Park

TO:		Coke Ovens Residual Risk and Technology Review (RTR) Project File

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SUBJECT:	Maximum Achievable Control Technology Standard Calculations, Cost Impacts, and Beyond-the-Floor Cost Impacts for Coke Ovens Facilities under 40 CFR Part 63, Subpart CCCCC
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                                   CONTENTS
1.0	INTRODUCTION AND BACKGROUND	3
2.0	HAP EMISSIONS MEASURED AT COKE FACILITIES	4
3.0	MACT FLOOR	7
3.1	Quantity of Below the Detection Limit (BDL) Data	8
3.2	HAP MACT Limit	9
4.0	MACT LIMIT IMPACTS	11
4.1	Units Meeting MACT Limits	11
4.2	Costs to Meet MACT Limits	18
5.0	BEYOND THE FLOOR ANALYSIS	18
5.1	Background	18
5.2	HAP Control Devices by MACT Process Type at Coke Facilities	18
5.3	Total BTF Annual Costs, Emissions Reductions, and Cost Effectiveness for APCD per Process Type at Coke Facilities	19
5.4	BTF Limits for HNR HRSG Bypass/Waste Heat Stacks (Existing & New Sources)	19
6.0	REFERENCES	24
APPENDIX A:	1
APPENDIX B:	1
MACT FLOOR DEVELOPMENT	1
B.1 Introduction	1
B.2 Process Units	1
B.3 MACT Floor Statistical Analyses - Upper Prediction Limit	1
Normally-Distributed Dataset	3
Lognormally-Distributed Dataset (Bhaumik and Gibbons, 2004)	4
Skewed/Unknown-Distributed Dataset (Non-Normal/Non-Lognormal) (Gayen, 1949)	4
B.4 Representative Detection Limit	5
B.5 MACT Floor Emissions Limit Development Methodology	5
Step 1.	5
Step 2.	6
Step 3.	9
Step 4.	10
Step 5.	11
Step 6.	14
Step 7.	21
B.6 Results of the MACT Floor Analyses	21
B.7 References for Appendix B	23
APPENDIX C:	1
BEYOND-THE-FLOOR COST DETAILS FOR COKE PQBS FACILITIES	1
C.1 Development of Input Parameters for BTF Analyses	1
C.2 Pushing BTF Analysis	1
Input Parameters for BTF Controls for Pushing	1
Development of Unit Costs for Ductwork for BTF Controls for Pushing	4
Development of Unit Costs for ACI for BTF Controls for Pushing	4
Development of Unit Costs for WAS for BTF Controls for Pushing	5
BTF Costs per Facility for Pushing	10
BTF Emission Reductions for Pushing	11
BTF Cost Effectiveness for Pushing	14
C.3 ByP Battery Combustion Stack BTF Analysis	14
Input Parameters for BTF Controls for ByP Battery Combustion Stacks	15
Development of Unit Costs for Ductwork for BTF Controls for ByP Battery Combustion Stacks	18
Development of Unit Costs for ACI for BTF Controls for ByP Battery Combustion Stacks	18
Development of Unit Costs for WAS for BTF Controls for ByP Battery Combustion Stacks	19
BTF Costs per Facility for ByP Battery Combustion Stacks	22
BTF Emission Reductions for ByP Battery Combustion Stacks	23
BTF Cost Effectiveness for ByP Battery Combustion Stacks	25
C.4 HNR HRSG Main Stack BTF Analysis	25
Input Parameters for BTF Controls for HNR HRSG Main Stacks	25
Development of Unit Costs for Ductwork for BTF Controls for HNR HRSG Main Stacks	26
Development of Unit Costs for ACI for BTF controls for HNR HRSG Main Stacks	27
Development of Unit Costs for WAS for BTF Controls for HNR HRSG Main Stacks	28
BTF Costs per Facility for HNR HRSG Main Stacks	29
BTF Emission Reductions for HNR HRSG Main Stacks	31
BTF Cost Effectiveness for HNR HRSG Main Stacks	32
C.5 HNR HRSG Bypass/Waste Heat Stack BTF Analysis	33
Input Parameters for BTF Controls for HNR HRSG Bypass/Waste Heat Stacks	33
Development of Unit Costs for Ductwork for BTF Controls for HNR HRSG Bypass/Waste Heat Stacks	34
Development of Unit Costs for ACI for BTF Controls for HNR HRSG Bypass/Waste Heat Stacks	38
Development of Unit Costs for WAS for BTF Controls for HNR HRSG Bypass/Waste Heat Stacks	42
Development of Unit Costs for RTO for BTF Controls for HNR HRSG Bypass/Waste Heat Stacks	44
BTF Costs per Facility for HNR HRSG Bypass/Waste Heat Stacks	44
BTF Emission Reductions for HNR HRSG Bypass/Waste Heat Stacks	46
BTF Cost Effectiveness for HNR HRSG Bypass/Waste Heat Stacks	47
C.6 References for Appendix C	49
APPENDIX D:	1
BTF ANALYSIS FOR HNR HRSG BYPASS/WASTE HEAT STACKS	1
D.1 Input Parameters for BTF Controls for HNR HRSG Bypass/Waste Heat Stacks	1
D.2 Development of Unit Costs for Ductwork for BTF Controls for HNR HRSG Bypass/Waste Heat Stacks	2
D.3 Development of Unit Costs for BTF Controls for ACI and BH for HNR HRSG Bypass/Waste Heat Stacks	6
D.4 BTF Costs for HNR HRSG Bypass/Waste Heat Stacks	12
D.5 BTF Emission Reductions for HNR HRSG Bypass/Waste Heat Stacks	12
D.6 BTF Cost Effectiveness for HNR HRSG Bypass/Waste Heat Stacks	14
D.7 References for Appendix D	16

1.0	INTRODUCTION AND BACKGROUND

      This memorandum discusses hazardous air pollutant (HAP) emissions and maximum achievable control technology (MACT) calculations for unregulated and under-regulated emission sources at coke oven facilities, as part of the Residual Risk and Technology Review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Coke Ovens: Pushing, Quenching, and Battery Stacks (PQBS) (40 CFR, part 63, subpart CCCCC), required under the Clean Air Act (CAA), sections 112(d)(2)&(3) and (d)(6). In addition, this memorandum evaluates beyond-the-floor (BTF) control techniques and the costs of the BTF air pollution control devices (APCD). See Appendix A for a list of applicable acronyms.

      In the coke production process, coal is heated in ovens in the absence of air to temperatures approaching 2,000°F (1,100[o]C), which drives off most of the volatile organic constituents of the coal, as gases and vapor, to form coke, which consists almost entirely of carbon. Coal is charged into the top or end of the oven, depending on the process, and the finished coke is pushed out using doors on both ends of the ovens. The hot coke product is cooled in quench towers that use water spray to cool hot coke in rail cars that drive into the bottoms of quench towers. The coke product is used either in blast furnaces in the integrated iron and steel industry (II&S) or at iron and steel foundries that produce iron molds for shaping molten metal. Coke oven temperatures are slightly higher to produce blast furnace coke than foundry coke. Coking lasts for 15 to 18 hours to produce blast furnace coke and 25 to 30 hours to produce foundry coke.

      The coke ovens are arranged in a series of adjacent ovens called batteries, where one battery may have up to 100 ovens and multiple batteries may be used by one facility. For the 14 coke facilities in the Coke Oven Risk Modeling Database, the number of batteries per facility ranged from 1 to 10, and the total number of ovens at the facility ranged from 56 to 708, with median values of 3 batteries per facility and 126 ovens total at the facility. Ovens at by-product (ByP) facilities are tall and narrow (approximately 20 ft/6 m by 1.3 ft/0.4 m; whereas, at heat and nonrecovery recovery (HNR) facilities, the ovens are short and wide (approximately 7.8 ft/2.4 m by 12 ft/3.6 m). ByP ovens are operated at positive pressure, whereas HNR ovens operate under negative pressure. The organic gases and vapors that evolve from the ovens are removed through an exhaust system: for ByP plants, gases are sent to a chemical recovery plant that recovers chemicals and other by-products for sale and also cleans the coke oven gas (and is regulated under 40 CFR part 61, subpart L NESHAP); for nonrecovery plants (i.e., no chemical recovery) with heat recovery, the oven gases are sent to a heat recovery steam generator that produces power for sale and also to units that perform gas cleaning; for nonrecovery plants without heat recovery, oven exhaust gases are released to the air through waste heat stacks.

2.0	HAP EMISSIONS MEASURED AT COKE FACILITIES

      Table 1 shows the facilities and process of the coke oven PQBS category units tested for the 2016 and 2022 coke oven CAA section 114 requests and the HAP measured that were used to develop MACT limits. The Erie Coke facility, which produced foundry coke, received the 2016 coke oven CAA section 114 request and, as required, conducted testing August through October 2016 on several coke category units: ByP pushing and ByP combustion stack. In 2020, the EPA was notified that the Erie Coke facility was shut down in late 2019. As such, the emissions for Erie Coke units and emissions were not included in the coke oven PQBS MACT floor calculations. In 2020, Cleveland-Cliffs Inc. acquired the AK Steel: Follansbee, WV (Mountain State Carbon) and Middletown, OH cokemaking facilities and the ArcelorMittal USA LLC: Burns Harbor, IN; Monessen, PA; and Warren, OH cokemaking facilities.

The existing work practice standards for quench towers are the most appropriate standards at this time, as truly repeatable testing is near impossible on these highly variable sources. There are also safety considerations with testing these quench tower sources. As such, no MACT limits were developed for quench towers.
                        Table 1. Coke Oven PQBS Tested Units
                                   Facility
                               Unit Description
                                 Facility Type
                         HAP Data Used for MACT Limits
                            Pushing Control Devices
CC-Middletown-OH
Moveable shed/hood&baghouse
Byproduct
                               Hg, AG, HCN, PAH
CC-Burnsharbor-IN
Coke Battery #2 moveable shed/hood&baghouse
Byproduct
                               Hg, AG, HCN, PAH
CC-Monessen-PA
Moveable shed/hood&baghouse
Byproduct
                               Hg, AG, HCN, PAH
SC-GraniteCity-IL
Flat Push Hot Car Mobile scrubber car&multiclone
HNR
                                      Hg
SC-Middletown-OH
Flat Push Hot Car Mobile scrubber car&multiclone
HNR
                               Hg, AG, HCN, PAH
                          Battery (Combustion) Stacks
CC-Middletown-OH
Combustion Stack
Byproduct
                                Hg, PM, AG, HCN
CC-Burnsharbor-IN
Coke Battery No. 2 Underfire Stack
Byproduct
                                Hg, PM, AG, HCN
CC-Monessen-PA
Battery Combustion Stack #2
Byproduct
                                Hg, PM, AG, HCN
USS-Clairton-PA
Battery B Combustion Stack (S012)
Byproduct
                                Hg, PM, AG, HCN
                             HNR HRSG Main Stacks
SC-Middletown-OH
P901- Coke Oven (Battery A-C) - Main Stack
HNR
                                Hg, PM, AG, PAH
CE-EastChicago-IN /
SC-EastChicago-IN
HRSG Main Stack
HNR
                                Hg, PM, AG, PAH
                       HNR HRSG Bypass/waste heat stacks
SC-GraniteCity-IL
Coke Oven Battery C - Bypass Vent 5
HNR
                             Hg, PM, AG, PAH, Form
SC-FranklinFurnace-OH
Bypass Vent Stack 6
HNR
                               Hg, PM, AG, Form
Note: Acronyms are as follows: acid gases (AG) that include hydrogen chloride (HCl) and hydrogen fluoride (HF); hydrogen cyanide (HCN); mercury (Hg); particulate matter (PM); polycyclic aromatic hydrocarbons (PAH); speciated volatile HAP (VOHAP); formaldehyde (form).

      Table 2 indicates the HAP at eight coke oven facilities measured during source tests at the various operating units submitted for the CAA section 114 information request (hereafter referred to as the "coke oven test data") and which were used to calculate MACT floor. The coke oven test data used in the MACT limit calculations and subsequent BTF analyses were "not adjusted for nondetected" values. For stack run data where values were at or below detection, for MACT limits the method detection limit (MDL) is used for the run/fraction mass, as per EPA protocol for developing emissions estimates that potentially could be used to develop emission standards. This protocol is opposed to the EPA's protocol for risk assessment data, which includes converting stack run data to half of the MDL, where values were at or below detection, in developing test run values for performing risk assessments. The HAP emissions and other operating and test information for each unit can be found in the responses to the coke oven CAA section 114 requests included in the docket for the rule as well as in the memorandum titled Coke Ovens Risk and Technology Review: Data Summary ( EPA, 2023A) located in the docket for this rule (Docket ID No. EPA-HQ-OAR-2002-0085).
.

Table 2. Valid Data Available for Unregulated and Under-regulated HAP Emissions by Process for PQBS Processes
HAP/
HAP Groups[1]
Pushing
(ByP & HNR)
ByP Battery Stack
HNR HRSG
Main Stacks
HNR HRSG Bypass/waste heat stacks
AG
√
√
√
√
Dioxin/furansTEQ[2]
BDL
BDL
BDL
BDL
Formaldehyde
BDL
BDL
√[6]
√
PM/HAP Metals (non-Hg)[3]
NA[4]
√
√
√
HCN
√
√
BDL
BDL[5]
Mercury
√
√
√
√
PAH (total)
√
BDL
√
√
VOHAP (total)
BDL
BDL
BDL[6]
BDL
1 For list of individual HAP in the HAP groups see Table 3. Note: NA = not applicable. BDL = above 50% of the data was below the detection limit. See Table 4.
[2] The 17 specific dioxin/furan congener mass values from testing were converted to 2,3,7,8-TCDD toxic equivalency (TEQ) values using the 2005 World Health Organization (WHO) toxicity equivalence factors (TEF). (EPA, 2010) The 17 congener TEQ values then were summed to calculate a total TEQ value for each stack test run.
[3] The HAP metals are as follows (non-Hg): antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, nickel, and selenium.
[4] A PM MACT standard for pushing, as a surrogate for HAP metals, is included in the current coke oven PQBS rule (§63.7290); therefore, MACT limits were not needed for HAP metals (non-Hg) from pushing.
[5] Data acquired through SC-GraniteCity-IL testing was considered invalid. Data quired through SC-FranklinFurnace-OH testing was BDL for all three runs. For more details, see the memorandum titled Coke Ovens Risk and Technology Review: Data Summary ( EPA, 2023A).
[6] Testing was not required during the 2016 Coke CAA section 114 request for this HAP because volatiles were not expected from the source due to the high temperatures. During the 2022 Coke CAA section 114 request, one source tested for Formaldehyde and benzene, toluene, ethylbenzene, and xylenes (BTEX).

                 Table 3. Individual HAP Within the HAP Groups
HAP Group
Individual HAP
AG
hydrogen fluoride,
hydrogen chloride
Total PAH
acenaphthene, acenaphthylene, anthracene, benz[a]anthracene, benzo[a]pyrene, benzo[b]fluoranthene, benzo[g,h,i,]perylene, benzo[k]fluoranthene, chrysene, dibenzo[a,h]anthracene, fluoranthene, fluorene, indeno[1,2,3-c,d]pyrene, naphthalene, phenanthrene, perylene, pyrene
Total D/F TEQ
2,3,7,8-tetrachlorodibenzo-p-dioxin TEQ,
1,2,3,7,8-pentachlorodibenzo-p-dioxin TEQ,
1,2,3,4,7,8-hexachlorodibenzo-p-dioxin TEQ,
1,2,3,6,7,8-hexachlorodibenzo-p-dioxin TEQ,
1,2,3,7,8,9-hexachlorodibenzo-p-dioxin TEQ,
1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin TEQ,
octachlorodibenzo-p-dioxin TEQ,
2,3,7,8-tetrachlorodibenzofuran TEQ,
1,2,3,7,8-pentachlorodibenzofuran TEQ,
2,3,4,7,8-pentachlorodibenzofuran TEQ,
1,2,3,4,7,8-hexachlorodibenzofuran TEQ,
1,2,3,6,7,8-hexachlorodibenzofuran TEQ,
2,3,4,6,7,8-hexachlorodibenzofuran TEQ,
1,2,3,7,8,9-hexachlorodibenzofuran TEQ,
1,2,3,4,6,7,8-heptachlorodibenzofuran TEQ,
1,2,3,4,7,8,9-heptachlorodibenzofuran TEQ,
Octachlorodibenzofuran TEQ
Total VOHAP
acrylonitrile, benzene, bromoform, methyl bromide, carbon disulfide, carbon tetrachloride, chlorobenzene, ethyl chloride, chloroform, methyl chloride, ethylene dichloride, vinylidene chloride, propylene dichloride, ethyl benzene, methyl iodide, methylene chloride, styrene, 1,1,2,2-tetrachloroethane, tetrachloroethylene, toluene, methyl chloroform, 1,1,2-trichloroethane, trichloroethylene, vinyl chloride, xylenes (mixed isomers)

3.0	MACT FLOOR

      In the Coke Oven Emissions Database, for stack run data where values were at or below detection, the method detection limit (MDL) or similar value was used for the run/fraction mass, as per EPA protocol for developing emissions estimates that potentially could be used to develop emission standards. This type of data is classified as data that is "not adjusted for nondetected" values and was used for the calculation of MACT limits and estimates of air pollution control device cost effectiveness in the Maximum Achievable Control Technology Standard Calculations, Cost Impacts, and Beyond-the-Floor Cost Impacts for Coke Ovens Facilities under 40 CFR Part 63, Subpart CCCCC memorandum. Note that for test runs classified as detection level limited (DLL) or above detection limit (ADL) there were no adjustments made to the test run values. For more information on the data sets used see the Coke Ovens Risk and Technology Review: Data Summary memorandum ( EPA, 2023A).

      The MACT analyses use the upper predictive limit (UPL) approach to identify the average emission limitation achieved by the best performing sources. The EPA uses this approach because it incorporates the average performance of the best performing sources as well as the variability of the performance during testing conditions. The UPL represents the value which one can expect the mean of a specified number of future observations (e.g., 3-run average) to fall below for the specified level of confidence (99 percent), based upon the results from the same population. In other words, the UPL estimates what the upper bound of future values will be based upon present or past background data. The UPL approach encompasses all the data point-to-data point variability in the collected data, as derived from the dataset to which it is applied. An average HAP emission value is calculated for each unit, and then the individual facility average emission values are ranked from lowest to highest value. The best performing sources per process type and HAP are identified from the rankings consistent with the criteria in CAA section 112(d)(3) for determining MACT standards for existing sources. These sources are referred to as the "MACT floor pool." The existing and new source MACT floor pool datasets were evaluated statistically to determine the distributions for both existing and new sources, by process type and by HAP. After determining the type of data distribution for the dataset, the UPL was calculated using the corresponding equation for the distribution for that dataset and groupings of emission points.

The results of the UPL calculations were compared to the 3xRDL values of the performance test method(s), as per EPA guidance ( EPA, 2011; Parker, 2018), to ensure that data measurement variability is addressed. In the comparison of the 3xRDL value to the calculated UPL, if the calculated UPL value is less than the 3xRDL value, the 3xRDL value is used as the basis for the standard because the 3xRDL value provides the lowest emission rate that can be measured using the performance test method while maintaining a relative method precision on the order of 10 to 20 percent of the measured value. If the UPL value is equal to or greater than the 3xRDL value, then the UPL value is used as the basis for the standard.

A MACT floor dataset based on fewer than 7 data points is considered to be a limited dataset. For the PQBS source category the pushing: Hg, AG, HCN, and PAH; ByP battery combustion stack: Hg, PM, AG, and HCN; HRSG main stack: Hg, PM, AG, PAH; and Bypass/waste heat stack Hg, PM, AG, PAH, and Formaldehyde datasets were limited. For limited datasets, each individual dataset can be further evaluated in order to ensure that the uncertainty associated with a limited dataset does not cause the calculated emission limit to be so high that it does not reflect the average performance of the units upon which the limit is based after accounting for variability in the emissions of those units. For limited datasets with less than seven data points, the steps outlined in the memorandum Approach for Applying the Upper Prediction Limit to Limited Dataset memorandum (EPA, 2023b) were followed. Each limited dataset is evaluated to determine whether it is appropriate to make any modifications to the approach to calculate MACT floors. The final selected data distribution ensures that the distribution best represents each dataset; ensures that the correct equation for the distribution was applied to the data; and compares individual components of each limited dataset to determine if the standards based on limited datasets reasonably represent the performance of the units included in the dataset. Based on the evaluation of limits based on limited data sets, no changes to the standard floor calculation procedure were determined to be warranted for the coke ovens limited datasets. For more details, see the memorandum Approach for Applying the Upper Prediction Limit to Limited Datasets located in the docket for this rule (EPA, 2023b).

3.1	Quantity of Below the Detection Limit (BDL) Data

      Every stack test run is assigned a "run flag". Run flags are determined by the facility/analytical laboratory for each run. They compare each analytical fraction mass to the method detection limit (MDL) or other detection limit values (e.g., reporting limit) as available. The run flag can be designated as above detection limit (ADL) or below detection limit (BDL). For EPA Method 29, mercury runs have five analytical fractions and the other HAP metals have two analytical fractions. The run flag is BDL if all of the fraction masses are below the MDL, detection level limited (DLL) if one or more of fraction masses are below the MDL, and ADL if all of the fraction masses are above the MDL.

      The run flags were examined for each process type and pollutant to determine the percentage of data that had a BDL flag ( EPA, 2014). For those datasets that had 50 or less percent BDL data, MACT standards were developed. Table 4 shows the percent BDL for each process type and pollutant.

             Table 4. Summary of BDL Values in Coke Oven PQBS Test Data
                       as Percent of MACT Floor Pool Test Data
                                    Process
                                      HAP

                                      Hg
                                      PM
                                     AG[1]
                                      HCN
                                    PAH[1]
                                  D/F TEQ[1]
                                   VOHAP[1]
                                     Form
Pushing
(ByP & HNR)
                                      40%
                                     NA[2]
                                      13%
                                      0%
                                      50%
                                      92%
                                      92%
                                      58%
ByP Battery (Combustion) Stack
                                      25%
                                      0%
                                      13%
                                      50%
                                      67%
                                      67%
                                      58%
                                     100%
HNR HRSG Main Stacks
                                      0%
                                      10%
                                      50%
                                     100%
                                      5%
                                     100%
                                    100%[3]
                                    29%[3]
HNR HRSG Bypass/ Waste Heat Stacks
                                      0%
                                      0%
                                      0%
                                    100%[4]
                                      24%
                                     100%
                                      60%
                                      20%
[1] For these group HAP, the percent BDL for each individual HAP was calculated and the average of individual BDL shown as the overall group BDL value.
[2] Pushing already has PM limits.
[3] HRSG main stack testing was not required during the 2016 Coke CAA section 114 request for this HAP because volatiles were not expected from the source due to the high temperatures. During the 2022 Coke CAA section 114 request, one source tested for Formaldehyde and BTEX.
[4] HCN data at SunCoke GraniteCity bypass/waste heat were suspect and were not used; SunCoke Franklin Furnace data were BDL for all three runs.

3.2	HAP MACT Limit

      For the coke oven PQBS RTR, MACT limits were developed from coke oven test data for Hg, PM, total AG, HCN, total PAH, and formaldehyde for pushing, ByP battery combustion, HNR HRSG main stacks, and HNR HRSG waste bypass/waste heat stacks, as applicable. Although, HNR process units of HRSG main stacks and HNR HRSG waste bypass/waste heat stacks were not in the original PQBS coke oven MACT, these units are part of the HNR coke-making process and, therefore, are addressed in the coke oven PQBS RTR.

      An upper predictive limit (UPL) was developed to determine a HAP MACT limit for existing sources and new sources. To ensure that measurement variability is adequately addressed in the MACT standard, a procedure described in Westlin and Merrill (2011) was used to address the variability in the MACT floors for coke facilities. In the Westlin and Merrill (2011) procedure, a list of representative detection levels (RDL) obtained from available HAP-specific method detection levels are used to account for the effect of measurement imprecision associated with the stack test data. The RDL values are multiplied by three to further account for measurement imprecision to produce "3xRDL" values. As described in Appendix B, the HAP specific 3xRDL value for existing sources, was compared to the calculated UPL value for each HAP UPL calculated per process type. According to the Westlin and Merrill (2011) procedure, the larger of the values, 3xRDL value vs. calculated UPL value, should be used for the MACT limit, to ensure that measurement variability is adequately addressed. See Appendix B for details of how UPLs were calculated, determination of 3xRDL value, and the MACT limits were determined for existing and new sources per HAP per process type. Table 5 shows the existing source and new source MACT limits for the coke oven PQBS source category.
         Table 5. Existing and New Source MACT limits for the Coke Industry
Process
                          Existing and/ or New Source
                                     UOM
                              HAP/HAP Group[1,2]

                                      Hg
                                     PM[3]
                                      AG
                                      HCN
                                      PAH
                                    D/F TEQ
                                     VOHAP
                                 Formal-dehyde
Pushing
(ByP & HNR)
                                   Existing
                                  lb/ton coke
                                    8.9E-07
                                     [UPL]
                                      [5]
                                    0.0052
                                     [UPL]
                                    0.0011
                                   [UPL[8]]
                                    3.4E-04
                                   [UPL[8]]
                                      [4]
                                      [4]
                                      [4]

                                      New

                                    3.4E-07
                                    [3xRDL]

                                    5.1E-04
                                     [UPL]
                                    3.8E-05
                                   [UPL[8]]
                                    1.4E-05
                                   [UPL[8]]

ByP Battery (Combustion) Stack
                                   Existing
                                  lb/ton coke
                                  (or gr/dscf
                                    for PM)
                                    5.8E-05
                                     [UPL]
                                     0.10
                                     [UPL]
                                     0.083
                                     [UPL]
                                    0.0039
                                   [UPL[8]]
                                      [4]
                                      [4]
                                      [4]
                                      [4]

                                      New

                                    7.1E-06
                                     [UPL]
                                     0.014
                                     [UPL]
                                     0.013
                                     [UPL]
                                    7.4E-04
                                   [UPL[8]]

HNR HRSG Main Stacks
                                   Existing
                                    gr/dscf
                                 2.4E-06 [UPL]
                                    0.0065
                                     [UPL]
                                     0.038
                                     [UPL]
                                      [4]
                                    4.7E-07
                                   [UPL[8]]
                                      [4]
                                     [4,6]
                                      [6]

                                      New

                                    1.5E-06
                                     [UPL]
                                 7.5E-04 [UPL]
                                 0.0029 [UPL]
                                      [4]
                               3.7E-07 [UPL[8]]
                                      [4]
                                     [4,6]
                                      [6]
HNR HRSG Bypass/ Waste Heat Stacks
                                   Existing
                                    gr/dscf

                                     0.013
                                     [UPL]
                                    [4, 7]
                                    2.4E-06
                                   [UPL[8]]
                                      [4]
                                      [4]
                                    0.0011
                                     [UPL]

                                      New

                                     0.070
                                     [UPL]

                                    1.9E-05
                                     [UPL]
HR HRSG Bypass/ Waste Heat Stack
                                   Existing
                                    gr/dscf
                                   1.7E-05
                                     [UPL]
                                     0.034
                                     [UPL]

                                      New

                                    7.8E-06
                                     [UPL]
                                    0.025
                                     [UPL]

NR HRSG Bypass/ Waste Heat Stack
                                   Existing
                                    gr/dscf
                               1.7E-06 [UPL[9]]
                                   6.6E-04
                                  [3xRDL[9]]

                                      New

                                   7.8E-07
                                   [UPL[9]]
                                   6.6E-04
                                  [3xRDL[9]]

1 For list of individual HAP in the HAP groups see Table 3.
2 MACT limit basis indicated in square brackets beneath value, where UPL = upper prediction limit. 3xRDL is three times representative detection limit. See Appendix B for more information regarding calculation of UPLs and 3xRDLs.
[3] PM, as a surrogate for non-Hg metal HAP.
[4] Dataset with greater than 50 percent BDL.
[5] Pushing already has PM limits in 40 CFR part 63, subpart CCCCC.
[6] HRSG main stack testing was not required during the 2016 Coke CAA section 114 request for this HAP because volatiles were not expected from the source due to the high temperatures. During the 2022 Coke CAA section 114 request, one source tested for formaldehyde and BTEX. Due to the low emission quantities with many, if not all, values BDL, the EPA is not setting numerical emission limits for formaldehyde and BTEX. See the "Data Memorandum" for details of the test results. (EPA, 2023a)
[7] HCN data at SC-GraniteCity-IL bypass/waste heat stack were suspect and were not used.
[8] No 3xRDL value available at this time.
[9] BTF limits, discussed in Section 5.4.

4.0	MACT LIMIT IMPACTS

4.1	Units Meeting MACT Limits

   The MACT limits from Table 5 were compared to the emissions from the coke facility units to determine which units meet the MACT limits. For the units that had coke oven CAA section 114 requests test data or were similar to a unit that was tested, their test data were used to compare to the MACT limits. For the units that did not have coke oven test data, their emissions were estimated to compare to the MACT limits. The following paragraphs describe the estimating methodology for each process type and the results of the comparisons.

      Using the MACT floor pollutant data sets (called the "MACT floor pool") for pushing and ByP battery combustion stacks, the average emissions and average annual coke production (TPY) were calculated. These values were used to estimate emissions for units that were not in the MACT floor pool using each unit's annual production (TPY) in the following equation:

Estimated EmissionsUnit i=Avg EmissionsMACT Floor Pool1xAnnual ProductionUnit iAvg Annual ProductionMACT Floor Pool

      For HNR HRSG main stack and HNR HRSG bypass/waste heat stack sources, the emissions for sources not tested were assumed equal to test data from SC-Middletown-OH and CE-EastChicago-IN HRSG main stack and test data from the SC-GraniteCity-IL and SC-FranklinFurnace-OH bypass/waste heat stack, respectively. The SunCoke representatives stated that emissions from these sources were not related to coke production (Batten, 2020).

      The estimated emissions for each unit at each facility were compared to the MACT limits to determine if each unit could meet the MACT limit. Table 6 shows the pushing emissions for each unit compared to the MACT limits. This comparison shows that all pushing units at all facilities meet the MACT limits for Hg, AG, HCN, and PAH. Table 7 shows the ByP battery combustion stack emissions for each unit compared to the MACT limits. This comparison shows that all ByP battery combustion stack units meet the MACT limits for Hg, PM, AG, and HCN. Table 8 shows the HNR HRSG main stack emissions for each unit compared to the MACT limits. This comparison shows that all HNR HRSG main stack units meet the MACT limits for Hg, PM, AG, and PAH. Table 9 shows the HNR HRSG bypass/waste heat stack emissions for each unit compared to the MACT limits. This comparison shows that all HNR HRSG bypass/waste heat stack units meet the MACT limits for Hg, PM, AG, PAH, and formaldehyde.

  Table 6. Pushing Hg, AG, HCN, and PAH Emissions Compared to the MACT Limits
                                   Facility
                                Emission Source
                    Unit Meets MACT Limit for Indicated HAP
                                 Hg MACT Limit
                              8.9E-07 lb/ton coke
                                 AG MACT Limit
                              0.0052 lb/ton coke
                                HCN MACT Limit
                              0.0011 lb/ton coke
                                PAH MACT Limit
                              3.4E-04 lb/ton coke

                                Hg lb/ton coke
                                AG lb/ton coke
                                HCN lb/ton coke
                                PAH lb/ton coke
ABC-Tarrant-AL
coke pushing operations for batteries 1 baghouse 1
                               Hg, AG, HCN. PAH
                                    6.9E-08
                                    0.00051
                                    0.00015
                                    1.4E-05
ABC-Tarrant-AL
coke pushing operations for batteries 1 baghouse 2
                               Hg, AG, HCN. PAH
                                    6.9E-08
                                    0.00051
                                    0.00015
                                    1.4E-05
ABC-Tarrant-AL
coke pushing operations for batteries 5 and 6 baghouse
                               Hg, AG, HCN. PAH
                                    5.4E-08
                                    0.00040
                                    0.00012
                                    1.1E-05
BLU-Birmingham-AL
pushing emissions for coke batteries # 3, 4 & 5
                               Hg, AG, HCN. PAH
                                    1.3E-07
                                    0.00094
                                    0.00028
                                    2.6E-05
CC-Follansbee-WV
batteries #1, #2, and #3 pushing baghouse
                               Hg, AG, HCN. PAH
                                    4.0E-08
                                    0.00029
                                    0.00009
                                    8.2E-06
CC-Follansbee-WV
battery #8 pushing venturi scrubber
                               Hg, AG, HCN. PAH
                                    1.7E-07
                                    0.00122
                                    0.00036
                                    3.4E-05
CC-Middletown-OH
wilputte coke oven battery - pec baghouse[1]
                               Hg, AG, HCN. PAH
                                    2.5E-08
                                    0.00029
                                    0.00011
                                    6.7E-06
CC-BurnsHarbor-IN
eu512-06 pushing #1[2]
                               Hg, AG, HCN. PAH
                                    1.7E-07
                                    0.00239
                                    0.00084
                                    3.6E-05
CC-BurnsHarbor-IN
eu512-14 pushing #2[1]
                               Hg, AG, HCN. PAH
                                    1.7E-07
                                    0.00239
                                    0.00084
                                    3.6E-05
CC-Monessen-PA
pushing baghouse[1]
                               Hg, AG, HCN. PAH
                                    4.8E-07
                                    0.00117
                                    0.00074
                                    1.1E-04
CC-Warren-OH
no. 4 coke oven battery - pushing - chemico system
                               Hg, AG, HCN. PAH
                                    1.3E-07
                                    0.00096
                                    0.00028
                                    2.7E-05
EES-RiverRouge-MI
pushing emission control system
                               Hg, AG, HCN. PAH
                                    3.6E-07
                                    0.00264
                                    0.00078
                                    7.4E-05
USS-Clairton-PA
pec baghouse 1-3
                               Hg, AG, HCN. PAH
                                    2.4E-07
                                    0.00175
                                    0.00051
                                    4.9E-05
USS-Clairton-PA
pec baghouse 13-15
                               Hg, AG, HCN. PAH
                                    2.5E-07
                                    0.00182
                                    0.00053
                                    5.1E-05
USS-Clairton-PA
pec baghouse 19-20
                               Hg, AG, HCN. PAH
                                    3.1E-07
                                    0.00228
                                    0.00067
                                    6.4E-05
USS-Clairton-PA
pec baghouse b
                               Hg, AG, HCN. PAH
                                    2.6E-07
                                    0.00193
                                    0.00057
                                    5.4E-05
USS-Clairton-PA
pec baghouse c
                               Hg, AG, HCN. PAH
                                    3.2E-07
                                    0.00236
                                    0.00070
                                    6.6E-05
SC-EastChicago-IN
pushing machine for batteries a, b, c and d
                               Hg, AG, HCN. PAH
                                    4.8E-07
                                    0.00349
                                    0.00103
                                    9.8E-05
SC-FranklinFurnace-OH
pushing multiclone stack ab
                               Hg, AG, HCN. PAH
                                    1.3E-07
                                    0.00092
                                    0.00027
                                    2.6E-05
SC-FranklinFurnace-OH
pushing multiclone stack cd
                               Hg, AG, HCN. PAH
                                    1.3E-07
                                    0.00092
                                    0.00027
                                    2.6E-05
SC-GraniteCity-IL
flat push hot car with multiclone abc
                               Hg, AG, HCN. PAH
                                    2.0E-07
                                    0.00115
                                    0.00034
                                    3.2E-05
SC-Middletown-OH
flat push hot car with multiclone abc[1]
                               Hg, AG, HCN. PAH
                                    4.5E-08
                                    0.00166
                                    0.00002
                                    4.1E-06
SC-Vansant-VA
cokeside shed settling chamber pushing along battery 2d
                               Hg, AG, HCN. PAH
                                    3.3E-08
                                    0.00024
                                    0.00007
                                    6.8E-06
SC-Vansant-VA
cokeside shed settling chamber pushing along battery 2e
                               Hg, AG, HCN. PAH
                                    5.0E-08
                                    0.00036
                                    0.00011
                                    1.0E-05
SC-Vansant-VA
cokeside shed settling chamber pushing along battery 3b
                               Hg, AG, HCN. PAH
                                    4.8E-08
                                    0.00035
                                    0.00010
                                    9.8E-06
SC-Vansant-VA
cokeside shed settling chamber pushing along battery 3c
                               Hg, AG, HCN. PAH
                                    6.6E-08
                                    0.00048
                                    0.00014
                                    1.4E-05
SC-Vansant-VA
cokeside shed settling chamber pushing along battery 3f
                               Hg, AG, HCN. PAH
                                    3.1E-08
                                    0.00023
                                    0.00007
                                    6.4E-06
SC-Vansant-VA
cokeside shed settling chamber pushing along battery 3g
                               Hg, AG, HCN. PAH
                                    3.3E-08
                                    0.00024
                                    0.00007
                                    6.8E-06
1 Tested unit.
[2] Similar unit to tested unit.
Table 7. ByP Battery Combustion Stack Hg, PM, AG, and HCN Emissions Compared to the MACT Limits
                                   Facility
                                Emission Source
                    Unit Meets MACT Limit for Indicated HAP
                                 Hg MACT Limit
                              5.8E-05 lb/ton coke
                                 PM MACT Limit
                                 0.10 gr/dscf
                                 AG MACT Limit
                               0.083 lb/ton coke
                                HCN MACT Limit
                              0.0039 lb/ton coke

                                Hg lb/ton coke
                                  PM gr/dscf
                                AG lb/ton coke
                                HCN lb/ton coke
ABC-Tarrant-AL
underfiring stack #1, battery #1
                                Hg, PM, AG, HCN
                                    1.1E-05
                                     0.020
                                     0.023
                                    0.0014
ABC-Tarrant-AL
underfiring stack #4, batteries #5 and #6
                                Hg, PM, AG, HCN
                                    4.2E-06
                                    0.0080
                                    0.0090
                                    0.00054
BLU-Birmingham-AL
underfiring stack of batteries no. 3 & 4
                                Hg, PM, AG, HCN
                                    5.7E-06
                                     0.011
                                     0.012
                                    0.00074
BLU-Birmingham-AL
underfiring stack of coke battery no. 5
                                Hg, PM, AG, HCN
                                    4.1E-06
                                    0.0079
                                    0.0089
                                    0.00053
CC-Follansbee-WV
battery #1 combustion
                                Hg, PM, AG, HCN
                                    1.0E-06
                                    0.0020
                                    0.0022
                                    0.00013
CC-Follansbee-WV
battery #2 combustion
                                Hg, PM, AG, HCN
                                    1.0E-06
                                    0.0020
                                    0.0022
                                    0.00013
CC-Follansbee-WV
battery #3 combustion
                                Hg, PM, AG, HCN
                                    1.0E-06
                                    0.0020
                                    0.0022
                                    0.00013
CC-Follansbee-WV
battery #8 combustion
                                Hg, PM, AG, HCN
                                    1.3E-05
                                     0.024
                                     0.028
                                    0.0016
CC-Middletown-OH
wilputte battery - combustion stack[1]
                                Hg, PM, AG, HCN
                                    4.2E-06
                                     0.029
                                     0.061
                                    0.0030
CC-BurnsHarbor-IN
eu512-08 battery #1 underfire[2]
                                Hg, PM, AG, HCN
                                    3.2E-05
                                     0.050
                                     0.016
                                    0.0024
CC-BurnsHarbor-IN
eu512-16 battery #2 underfire[1]
                                Hg, PM, AG, HCN
                                    3.2E-05
                                     0.050
                                     0.016
                                    0.0024
CC-Monessen-PA
battery 1b combustion stack[2]
                                Hg, PM, AG, HCN
                                    3.9E-06
                                    0.0067
                                     0.010
                                    0.00052
CC-Monessen-PA
battery 2 combustion stack[1]
                                Hg, PM, AG, HCN
                                    3.9E-06
                                    0.0067
                                     0.010
                                    0.00052
CC-Warren-OH
no. 4 battery - oven underfiring
                                Hg, PM, AG, HCN
                                    1.0E-05
                                     0.019
                                     0.022
                                    0.0013
EES-RiverRouge-MI
battery heating stack
                                Hg, PM, AG, HCN
                                    2.8E-05
                                     0.053
                                     0.060
                                    0.0036
USS-Clairton-PA
coke oven battery 1 underfiring[2]
                                Hg, PM, AG, HCN
                                    7.1E-06
                                    0.0047
                                     0.015
                                    0.00017
USS-Clairton-PA
coke oven battery 2 underfiring[2]
                                Hg, PM, AG, HCN
                                    7.1E-06
                                    0.0047
                                     0.015
                                    0.00017
USS-Clairton-PA
coke oven battery 3 underfiring[2]
                                Hg, PM, AG, HCN
                                    7.1E-06
                                    0.0047
                                     0.015
                                    0.00017
USS-Clairton-PA
coke oven battery 13 underfiring[2]
                                Hg, PM, AG, HCN
                                    7.1E-06
                                    0.0047
                                     0.015
                                    0.00017
USS-Clairton-PA
coke oven battery 14 underfiring[2]
                                Hg, PM, AG, HCN
                                    7.1E-06
                                    0.0047
                                     0.015
                                    0.00017
USS-Clairton-PA
coke oven battery 15 underfiring[2]
                                Hg, PM, AG, HCN
                                    7.1E-06
                                    0.0047
                                     0.015
                                    0.00017
USS-Clairton-PA
coke oven battery 19 underfiring[2]
                                Hg, PM, AG, HCN
                                    7.1E-06
                                    0.0047
                                     0.015
                                    0.00017
USS-Clairton-PA
coke oven battery 20 underfiring[2]
                                Hg, PM, AG, HCN
                                    7.1E-06
                                    0.0047
                                     0.015
                                    0.00017
USS-Clairton-PA
coke oven b battery underfiring[1]
                                Hg, PM, AG, HCN
                                    7.1E-06
                                    0.0047
                                     0.015
                                    0.00017
USS-Clairton-PA
coke oven c battery underfiring[2]
                                Hg, PM, AG, HCN
                                    7.1E-06
                                    0.0047
                                     0.015
                                    0.00017
[1] Tested unit.
2 Similar unit to tested unit.

Table 8. HNR HRSG Main Stack Hg, PM, AG, and Total PAH Emissions Compared to the MACT Limits
                                   Facility
                                Emission Source
                    Unit Meets MACT Limit for Indicated HAP
                                 Hg MACT Limit
                                2.4E-06 gr/dscf
                                 PM MACT Limit
                                0.0065 gr/dscf
                                 AG MACT Limit
                                 0.038 gr/dscf
                             Total PAH MACT Limit
                                4.7E-07 gr/dscf

                                  Hg gr/dscf
                                  PM gr/dscf
                                  AG gr/dscf
                               Total PAH gr/dscf
CE-EastChicago-IN /
SC-EastChicago-IN
HRSG main stack
                                Hg, PM, AG, PAH
                                    1.7E-06
                                    0.00036
                                    0.0082
                                    2.8E-07
SC-FranklinFurnace-OH
p901- coke ovens (battery a&b) - main stack ab
                                Hg, PM, AG, PAH
                                    1.5E-06
                                    0.0010
                                    0.0064
                                    3.1E-07
SC-FranklinFurnace-OH
p902- coke ovens (battery c&d) - main stack cd
                                Hg, PM, AG, PAH
                                    1.5E-06
                                    0.0010
                                    0.0064
                                    3.1E-07
SC-GraniteCity-IL
0005 -coke ovens (battery a&b&c) - main stack
                                Hg, PM, AG, PAH
                                    1.5E-06
                                    0.0010
                                    0.0064
                                    3.1E-07
SC-Middletown-OH
p901- coke oven (battery a-c) - main stack
                                Hg, PM, AG, PAH
                                    9.0E-07
                                    0.0027
                                    0.0022
                                    3.8E-07
Note: Tested units are SC-Middletown-OH Main Stack and CE-EastChicago-IN Main Stack. All other units have operating hours that are the same as the tested units.

Table 9. HNR HRSG Bypass/Waste Heat Stack Hg, PM, AG, Total PAH, and Formaldehyde
                     Emissions Compared to the MACT Limits
                                   Facility
                               Emission Sources
                    Unit Meets MACT Limit for Indicated HAP
                         Hg MACT Limit 1.7E-05 gr/dscf
                                 PM MACT Limit
                                 0.034 gr/dscf
                                AG MACT Limit
                                 0.13 gr/dscf
                             Total PAH MACT Limit
                                2.4E-06 gr/dscf
                            Formaldehyde MACT Limit
                               0.0011-05 gr/dscf

                                  Hg gr/dscf
                                  PM gr/dscf
                                  AG gr/dscf
                               Total PAH gr/dscf
                             Formaldehyde gr/dscf
SC-EastChicago-IN
venting stack 1-16
                         Hg, PM, AG, PAH, Formaldehyde
                                    6.1E-06
                                     0.017
                                     0.072
                                    6.5E-07
                                    4.3E-05
SC-FranklinFurnace-OH
bypass vent 1-5 and 7-10
                         Hg, PM, AG, PAH, Formaldehyde
                                    7.0E-06
                                     0.020
                                     0.086
                                    6.5E-07
                                    1.0E-04
SC-FranklinFurnace-OH
bypass vent 6
                         Hg, PM, AG, PAH, Formaldehyde
                                    7.0E-06
                                     0.020
                                     0.086
                                    6.5E-07
                                    1.0E-04
SC-GraniteCity-IL
bypass vent 1-4 and 6
                         Hg, PM, AG, PAH, Formaldehyde
                                    5.2E-06
                                     0.013
                                     0.058
                                    6.5E-07
                                    4.7E-06
SC-GraniteCity-IL
bypass vent 5
                         Hg, PM, AG, PAH, Formaldehyde
                                    5.2E-06
                                     0.013
                                     0.058
                                    6.5E-07
                                    4.7E-06
SC-Middletown-OH
bypass vent 1-5
                         Hg, PM, AG, PAH, Formaldehyde
                                    6.1E-06
                                     0.017
                                     0.072
                                    6.5E-07
                                    4.3E-05
SC-Vansant-VA
venting stack 1-16
                         Hg, PM, AG, PAH, Formaldehyde
                                    6.1E-06
                                     0.017
                                     0.072
                                    6.5E-07
                                    4.3E-05
Note: Tested units are SC-FranklinFurnace-OH Bypass Vent 6 and SC-GraniteCity-IL Bypass Vent 5. All other sources are assumed to have the same concentrations in the coke oven exhaust as the average of the tested source because all sources use the same HNR process.

4.2	Costs to Meet MACT Limits

   Because all sources were shown to meet the MACT limits, as discussed in Section 4.1, there are no APCD costs associated with compliance with the MACT limits. There are compliance costs for testing of the emission points with MACT limits, which has been proposed for every 5 years. For details of the proposed compliance costs, see the memorandum Coke Ovens Risk and Technology Review: Compliance Costs located in the docket for this rule (EPA, 2023c).

5.0	BEYOND THE FLOOR ANALYSIS

The following sections summarize the results of the BTF analysis for HAP emissions from the PQBS source category beyond what can be achieved by the MACT limits described above. The primary sources of emissions data and cost parameters for the BTF analysis were the responses to the coke oven CAA section 114 requests and other references cited below. Copies of the coke oven CAA section 114 requests and responses are included in docket for this rule (Docket ID No. EPA-HQ-OAR-2002-0085).

5.1	Background

To evaluate opportunities for emission reductions beyond those that would result from the new MACT limits, control techniques were identified and evaluated that can achieve an emissions level more stringent than the MACT limit. Identification of BTF control techniques and costs of BTF controls are described below.

5.2	HAP Control Devices by MACT Process Type at Coke Facilities

      Table 10 shows the APCD identified as BTF control for each HAP and process type and the expected control efficiencies of these APCD per HAP.

Table 10. BTF APCD and Control Efficiencies for Coke Oven MACT Limits by HAP and Process Type
                                 Process Type
                          HAP with MACT Limit[1][,2]
                                  BTF APCD[3]
                          Control Efficiency per HAP
ByP & HNR Pushing
                                      Hg
                                      ACI
                                      95%

                                      PAH

                                      80%

                                      AG
                                      WAS
                                     99.9%

                                      HCN

                                      95%
ByP Battery Combustion Stack
                                      Hg
                                      ACI
                                      95%

                                      PM
                                      WAS
                                      95%

                                      AG

                                     99.9%

                                      HCN

                                      95%
HNR HRSG Main Stack
                                      Hg
                                      ACI
                                      95%

                                      PAH

                                      80%

                                      PM
                                      WAS
                                      95%

                                      AG

                                     99.9%
HNR HRSG Bypass/Waste Heat Stack
                                      Hg
                                      ACI
                                      95%

                                      PM
                                      WAS
                                      95%

                                      AG

                                     99.9%

                                      PAH
                                      RTO
                                      98%

                                 Formaldehyde

                                      98%
HNR HRSG Bypass/Waste Heat Stack
                                      Hg
                                      ACI
                                      90%

                                      PM
                                      BH
                                     99.9%
[1] AG = acid gases, hydrogen chloride and hydrogen fluoride. HAP = hazardous air pollutants. HCN = hydrogen cyanide. Hg = mercury. PAH = polycyclic hydrocarbon. PM = particulate matter.
[2] PM, as a surrogate for non-Hg metal HAP.
[3] Wet alkaline scrubber (WAS); activated carbon injection (ACI); regenerative thermal oxidizer (RTO).

5.3	Total BTF Annual Costs, Emissions Reductions, and Cost Effectiveness for APCD per Process Type at Coke Facilities

   The total BTF annual costs were calculated by summing the individual unit costs per APCD at each process type per facility. The development of the BTF unit costs per APCD per process type are located in Appendix C. The baseline emissions were estimated using similar calculation methodology that was used to calculate the HAP emissions for the modeling file, as described in Coke Ovens Risk and Technology Review: Data Summary ( EPA, 2023A). In most cases, the baseline emissions are controlled emissions but, in some cases, the emissions are not. The development of the baseline emissions and calculation of emission reductions using BTF APCD control devices are described further in Appendix C. The unit emissions reductions were summed to calculate the BTF total emissions reductions for each APCD at each process type per facility. The cost effectiveness values for BTF APCD were calculated for the coke oven MACT sources by dividing the annualized costs by the emission reductions. Tables 11 through 15 show the total BTF annual costs, emissions reductions, and cost effectiveness per pollutant and APCD for each process at coke facilities. Note, the values presented were calculated from unrounded emissions. Compliance costs for testing are discussed in the memorandum Coke Ovens Risk and Technology Review: Compliance Costs located in the docket for this rule (EPA, 2023c).

5.4	BTF Limits for HNR HRSG Bypass/Waste Heat Stacks (Existing & New Sources)

      The EPA is proposing BTF limits for the nonrecovery (NR) HRSG bypass/waste heat stacks, see Table 16 below and Appendix D for more details. The limits are calculated using the following equation:

           BTF UPL Limit = MACT UPL Limit x (1-Control Efficiency).

Table 11. Pushing BTF Total Annual Costs, Emissions Reductions, and Cost Effectiveness per APCD
                                   Facility
                            Total Annual Costs ($)
                           HAP Emissions Reductions
                           due to BTF Controls (TPY)
                          Cost Effectiveness ($/Ton)

                                 Ductwork ($K)
                           ACI for Hg & PAH ($K)
                           WAS for AG & HCN ($M)
                                   Hg w/ ACI
                                  PAH w/ ACI
                                   AG w/ WAS
                                  HCN w/ WAS
                                   Hg w/ ACI
                                     ($B)
                                  PAH w/ ACI
                                     ($M)
                                AG w/ WAS ($M)
                                HCN w/ WAS ($M)
                                   Total HAP
                             w/ Ductwork +ACI+ WAS
                                     ($M)
ABC-Tarrant-AL
                                      $35
                                     $508
                                     $7.6
                                    2.5E-05
                                     0.14
                                    3.8E-01
                                    2.2E-01
                                      $20
                                     $3.7
                                      $20
                                      $34
                                      $11
BLU-Birmingham-AL
                                      $12
                                     $169
                                     $2.6
                                    1.7E-05
                                     0.091
                                    2.5E-01
                                    1.5E-01
                                      $10
                                     $1.9
                                      $10
                                      $17
                                     $5.6
CC-Follansbee-WV
                                      $23
                                     $339
                                     $5.1
                                    5.9E-05
                                     0.011
                                    3.6E-01
                                    1.4E-01
                                     $5.7
                                      $30
                                      $14
                                      $37
                                      $11
CC-Middletown-OH
                                      $12
                                     $169
                                     $2.6
                                    4.2E-05
                                    0.0080
                                    5.7E-02
                                    2.2E-02
                                     $4.0
                                      $21
                                      $45
                                     $118
                                      $32
CC-BurnsHarbor-IN
                                      $23
                                     $339
                                     $5.3
                                    2.0E-04
                                     0.038
                                    2.3E+00
                                    7.6E-01
                                     $1.7
                                     $8.9
                                     $2.3
                                     $7.0
                                     $1.9
CC-Monessen-PA
                                      $12
                                     $169
                                     $2.6
                                    3.6E-05
                                    0.0067
                                    2.0E-01
                                    1.2E-01
                                     $4.8
                                      $25
                                      $13
                                      $22
                                     $8.6
CC-Warren-OH
                                      $12
                                     $169
                                     $2.6
                                    3.8E-05
                                    0.0072
                                    2.3E-01
                                    8.9E-02
                                     $4.5
                                      $24
                                      $11
                                      $29
                                     $8.4
EES-RiverRouge-MI
                                      $12
                                     $169
                                     $2.6
                                    1.0E-04
                                     0.020
                                    6.3E-01
                                    2.4E-01
                                     $1.6
                                     $8.6
                                     $4.2
                                      $11
                                     $3.2
USS-Clairton-PA
                                      $59
                                     $846
                                     $13.1
                                    4.0E-04
                                     0.076
                                    2.4E+00
                                    9.3E-01
                                     $2.1
                                      $11
                                     $5.4
                                      $14
                                     $4.1
SC-EastChicago-IN
                                     $9.4
                                      $67
                                     $1.4
                                    7.6E-05
                                    0.0022
                                    1.1E+00
                                    1.5E-02
                                     $876M
                                      $31
                                     $1.3
                                      $91
                                     $1.3
SC-FranklinFurnace-OH
                                      $19
                                     $133
                                     $2.5
                                    4.0E-05
                                    0.0011
                                    5.7E-01
                                    7.8E-03
                                     $3.4
                                     $119
                                     $4.4
                                     $318
                                     $4.6
SC-GraniteCity-IL
                                     $9.4
                                      $67
                                     $1.3
                                    2.5E-05
                                    0.00070
                                    3.6E-01
                                    4.9E-03
                                     $2.7
                                      $95
                                     $3.5
                                     $257
                                     $3.7
SC-Middletown-OH
                                     $9.4
                                      $67
                                     $1.2
                                    2.1E-05
                                    0.00059
                                    3.0E-01
                                    4.1E-03
                                     $3.2
                                     $114
                                     $4.2
                                     $305
                                     $4.4
SC-Vansant-VA
                                      $57
                                     $401
                                     $7.2
                                    3.1E-05
                                    0.00088
                                    4.4E-01
                                    6.1E-03
                                      $13
                                     $454
                                      $16
                                     $1.2B
                                      $17
Industry Total
                                     $303
                                     $3.6M
                                      $62
                                    0.0011
                                     0.40
                                      10
                                      2.7
                                     $3.2
                                     $9.1
                                     $6.0
                                      $21
                                     $4.9
Note: B=Billion, M=Million, K=Thousand.

Table 12. ByP Battery Combustion Stack BTF Total Annual Costs, Emissions Reductions, and Cost Effectiveness per APCD[1,2]
                                   Facility
                            Total Annual Costs ($)
                           HAP Emissions Reductions
                           due to BTF Controls (TPY)
                          Cost Effectiveness ($/Ton)

                                 Ductwork ($K)
                                  ACI for  Hg
                                     ($K)
                 WAS for Non-Hg Metal HAP, AG, & HCN ($M)
                                   Hg w/ ACI
                            Non-Hg Metal HAP w/ WAS
                                   AG w/ WAS
                                  HCN w/ WAS
                                  Hg w/ ACI
                                     ($M)
                         Non-Hg Metal HAP w/ WAS ($M)
                                  AG w/ WAS
                                     ($K)
                                HCN w/ WAS ($M)
                       Total HAP w/ Ductwork + ACI + WAS
                                     ($K)
ABC-Tarrant-AL
                                      $24
                                     $334
                                     $4.0
                                    0.0012
                                     0.11
                                      2.2
                                     0.94
                                     $268
                                      $37
                                     $1.8M
                                     $4.1
                                     $1.3M
BLU-Birmingham-AL
                                      $24
                                     $334
                                     $4.0
                                    0.00083
                                     0.073
                                      1.5
                                     0.62
                                     $405
                                      $55
                                     $2.7M
                                     $6.1
                                     $2.0M
CC-Follansbee-WV
                                      $48
                                     $669
                                     $8.1
                                    0.0032
                                     0.11
                                      7.2
                                     0.41
                                     $211
                                      $71
                                     $1.1M
                                      $19
                                     $1.1M
CC-Middletown-OH
                                      $12
                                     $167
                                     $2.1
                                    0.00080
                                     0.075
                                      12
                                     0.58
                                     $210
                                      $28
                                     $169
                                     $3.4
                                     $174
CC-BurnsHarbor-IN
                                      $24
                                     $334
                                     $4.4
                                     0.029
                                      1.1
                                      15
                                      2.2
                                      $12
                                     $4.1
                                     $283
                                     $1.9
                                     $253
CC-Monessen-PA
                                      $24
                                     $334
                                     $4.0
                                    0.00062
                                     0.012
                                      1.7
                                     0.083
                                     $542
                                     $325
                                     $2.3M
                                      $46
                                     $2.4M
CC-Warren-OH
                                      $12
                                     $167
                                     $2.1
                                    0.0020
                                     0.073
                                      4.6
                                     0.26
                                      $83
                                      $28
                                     $446
                                     $7.5
                                     $452
EES-RiverRouge-MI
                                      $12
                                     $167
                                     $2.1
                                    0.0055
                                     0.20
                                      13
                                     0.72
                                      $30
                                      $11
                                     $170
                                     $2.8
                                     $172
USS-Clairton-PA
                                     $120
                                     $1.7M
                                      $20
                                     0.013
                                     0.11
                                      29
                                     0.31
                                     $131
                                     $190
                                     $716
                                      $63
                                     $768
Industry Total
                                     $299
                                     $4.2M
                                      $51
                                     0.056
                                      1.8
                                      86
                                      6.1
                                      $75
                                      $28
                                     $594
                                     $8.0
                                     $592
[1] PM MACT limit, as a surrogate for non-Hg metal HAP.
[2] M=Million, K=Thousand.

Table 13. HNR HRSG Main Stack BTF Total Annual Costs, Emissions Reductions, and Cost Effectiveness per APCD[1,2]
                                   Facility
                            Total Annual Costs ($)
              HAP Emissions Reductions due to BTF Controls (TPY)
                          Cost Effectiveness ($/Ton)

                                 Ductwork ($K)
                           ACI for Hg & PAH ($K)
                    WAS for Non-Hg Metal HAP & AG ($M)
                                   Hg w/ ACI
                                  PAH w/ ACI
                            Non-Hg Metal HAP w/ WAS
                                   AG w/ WAS
                                  Hg w/ ACI
                                     ($M)
                                  PAH w/ ACI
                                     ($M)
                         Non-Hg Metal HAP w/ WAS ($M)
                                  AG w/ WAS
                                     ($K)
                                   Total HAP
                         w/ Ductwork + ACI + WAS ($K)
SC-EastChicago-IN
                                      $20
                                     $486
                                     $6.1
                                     0.047
                                    0.0063
                                     0.046
                                      236
                                      $10
                                      $77
                                     $132
                                      $26
                                      $28
SC-FranklinFurnace-OH
                                      $40
                                     $973
                                      $12
                                     0.054
                                    0.0090
                                     0.16
                                      255
                                      $18
                                     $108
                                      $76
                                      $47
                                      $51
SC-GraniteCity-IL
                                      $20
                                     $486
                                     $6.0
                                     0.027
                                    0.0045
                                     0.079
                                      128
                                      $18
                                     $108
                                      $76
                                      $47
                                      $51
SC-Middletown-OH
                                      $20
                                     $486
                                     $6.0
                                    0.0074
                                    0.0027
                                     0.11
                                      19
                                      $66
                                     $179
                                      $54
                                     $314
                                     $338
Industry Total
                                     $100
                                     $2.4M
                                      $30
                                     0.14
                                     0.023
                                     0.40
                                      638
                                      $18
                                     $108
                                      $76
                                      $47
                                      $51
[1] PM MACT limit, as a surrogate for non-Hg metal HAP.
[2] M=Million, K=Thousand.

Table 14. HNR HRSG Bypass/Waste Heat Stack BTF Total Annual Costs and Emissions Reductions per APCD[1,2]
                                   Facility
                            Total Annual Costs ($)
              HAP Emissions Reductions due to BTF Controls (TPY)

                                 Ductwork ($K)
                                ACI for Hg ($M)
                      WAS for Non-Hg Metal HAP & AG
                                     ($M)
                      RTO for PAH & Formaldehyde ($M)
                                   Hg w/ ACI
                            Non-Hg Metal HAP w/ WAS
                                   AG w/ WAS
                                  PAH w/ RTO
                              Formaldehyde w/ RTO
SC-EastChicago-IN
                                     $182
                                     $2.9
                                      $12
                                      $23
                                     0.022
                                      1.1
                                      278
                                    0.0026
                                     0.021
SC-FranklinFurnace-OH
                                      $61
                                     $1.8
                                     $9.4
                                      $16
                                    0.0025
                                     0.11
                                      34
                                    0.00027
                                     0.042
SC-GraniteCity-IL
                                      $40
                                     $1.1
                                     $5.2
                                     $9.3
                                    0.0021
                                     0.12
                                      24
                                    0.00027
                                    0.0018
SC-Middletown-OH
                                      $33
                                     $902K
                                     $4.7
                                     $8.1
                                    0.0019
                                     0.096
                                      24
                                    0.00022
                                     0.018
SC-Vansant-VA
                                     $426
                                     $1.6
                                     $7.7
                                      $13
                                     0.076
                                      3.8
                                      955
                                    0.0089
                                     0.72
Industry Total
                                     $741
                                     $8.3
                                      $39
                                      $69
                                     0.104
                                      5.3
                                     1,314
                                     0.012
                                     0.99
[1] PM MACT limit, as a surrogate for non-Hg metal HAP.
[2] M=Million, K=Thousand.

Table 15. HNR HRSG Bypass/Waste Heat Stack Total BTF Cost Effectiveness per APCD[1,2]
                                   Facility
                          Cost Effectiveness ($/Ton)

                                  Hg w/ ACI
                                     ($M)
                           Non-Hg Metal HAP w/ WAS
                                     ($M)
                                AG w/ WAS ($K)
                              PAH ($/Ton) w/ RTO
                                     ($B)
                         Formaldehyde ($/Ton) w/ RTO
                                     ($M)
                            Total HAP
w/ Ductwork+
                               ACI+WAS+RTO ($K)
SC-EastChicago-IN
                                     $132
                                      $11
                                      $45
                                     $8.9
                                     $110
                                     $138
SC-FranklinFurnace-OH
                                     $712
                                      $82
                                     $277
                                      $59
                                     $384
                                     $810
SC-GraniteCity-IL
                                     $518
                                      $44
                                     $216
                                      $35
                                     $5.2B
                                     $644
SC-Middletown-OH
                                     $477
                                      $49
                                     $197
                                      $37
                                     $452
                                     $575
SC-Vansant-VA
                                      $21
                                     $2.0
                                     $8.1
                                     $1.4
                                      $18
                                      $23
Industry Total
                                      $80
                                     $7.5
                                      $30
                                     $5.7
                                      $70
                                      $89
[1] PM MACT limit, as a surrogate for non-Hg metal HAP.
[2] B=Billion, M=Million, K=Thousand.

Table 16. BTF Limits for NR HRSG Bypass/Waste Heat Stacks (Existing & New Sources)
                                      HAP
                          Existing and/or New Source
                                MACT UPL Limit
                              BTF Control Device
                            (% Control Efficiency)
                      Cost Effectiveness from BTF control
                                BTF UPL Limits
                                  BTF Limits
Non-Hg HAP Metals (PM)
                                   Existing
                                                               0.034 PM gr/dscf
                                  BH (99.9%)
                             $645K/ton HAP Metals
                                                             3.4E-05 PM gr/dscf
                                                     6.6E-04 PM gr/dscf [3xRDL]

                                      New
                                                               0.025 PM gr/dscf

                                                             2.5E-05 PM gr/dscf
                                                     6.6E-04 PM gr/dscf [3xRDL]
Mercury
                                   Existing
                                                                1.7E-05 gr/dscf
                                 ACI+BH (90%)
                                    $11K/lb
                                                                1.7E-06 gr/dscf
                                                          1.7E-06 gr/dscf [UPL]

                                      New
                                                                7.8E-06 gr/dscf

                                                                7.8E-07 gr/dscf
                                                          7.8E-07 gr/dscf [UPL]

6.0	REFERENCES

Batten, 2020. Personal communication (email). K. Batten, SunCoke, with D. L. Jones, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. Docket ID No. EPA-HQ-OAR-2002-0085. October 7, 2020.
EPA, 2010. Recommended Toxicity Equivalence Factors (TEFs) for Human Health Risk Assessments of 2,3,7,8-Tetrachlorodibenzo-p-dioxin and Dioxin-Like Compounds. Publication No. EPA/100/R - 10/005. U.S. Environmental Protection Agency, Washington, DC. December 2010.
EPA, 2011. Data and Procedure for Handling Below Detection Level Data in Analyzing Various Pollutant Emissions Databases for MACT and RTR Emissions Limits. P. Westlin and R. Merrill. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. 2011.
EPA, 2014. Determination of "non-detect" from EPA Method 29 (multi-metals) and EPA Method 23 (dioxin/furan) test data when evaluating the setting of MACT floors versus establishing work practice standards. Memorandum from S. Johnson, U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. June 5, 2014.
EPA, 2018. Development of Representative Detection Levels of Certain Organic HAP Expressed as Pounds per Million British Thermal Units of Fuel Input for RTR Risk Modeling Dataset for Coal- and Oil-fired EGUs. Memorandum from B. Parker, EPA/OAQPS/SPPD, to Docket ID No: EPA-HQ-OAR-2018-0794. U.S. Environmental Protection Agency, Research Triangle Park, NC. July 2018.
EPA, 2021. Use of the Upper Prediction Limit for Calculating MACT Floors. Memorandum from D. L Jones, EPA/OAQPS/SPPD, Research Triangle Park, North Carolina, to Docket No. EPA-HQ-OAR-2002-0083. September 2, 2021.
EPA, 2023a. Coke Ovens Risk and Technology Review: Data Summary. Jones, D. L., U.S. Environmental Protection Agency, Research Triangle Park, NC, and G. Raymond, RTI International, Research Triangle Park, NC. May 1, 2023. Docket ID No. EPA-HQ-OAR-2002-0085.
EPA, 2023b. Approach for Applying the Upper Prediction Limit to Limited Datasets. Memorandum from D.L. Jones, EPA/OAQPS/SPPD, to Docket No. EPA-HQ-OAR-2002-0083. May 1, 2023.
EPA, 2023c. Coke Ovens Risk and Technology Review: Compliance Costs. D. L. Jones, U.S. Environmental Protection Agency and G.E. Raymond, RTI International. U.S. Environmental Protection Agency, Research Triangle Park, North Carolina. May 1, 2023. Docket ID Nos. EPA-HQ-OAR-2002-0085 and EPA-HQ-OAR-2003-0051.

                                  APPENDIX A:
                          Acronyms and Abbreviations

acfm
actual cubic feet per minute
ACI
activated carbon injection
ADL
above detection limit
AG
acid gases
AKS
AK Steel (now Cleveland Cliffs, Inc.)
AM
Arcelor Mittal (now Cleveland Cliffs, Inc.)
APCD
air pollution control device
BH
baghouse
BDL
below detection limit
BTF
beyond-the-floor
ByP
by-product coke production process
˚C
degrees Celsius
CAA
Clean Air Act
df
degrees of freedom
D/F
dioxin/furans
DLL
detection level limited
dscf
dry standard cubic feet
dscfm
dry standard cubic feet per minute
dscm
dry standard cubic meters
EP
emission process
EPA
U.S. Environmental Protection Agency
˚F
degrees Fahrenheit
ft
feet
fps
feet per second
gr/dscf
grains per dry standard cubic foot
HAP
hazardous air pollutant
HCl
hydrogen chloride
HCN
hydrogen cyanide
HF
hydrogen fluoride
HNR
heat and/or nonrecovery
Hg
mercury
HRSG
heat recovery steam generator
hr/yr
hours per year
i
each individual unit
II&S
integrated iron and steel manufacturing source category
K
kurtosis statistic
kWhr
kilo watt hour
lb/hr
pounds per hour
lb/ton
pounds per ton
MACT
maximum achievable control technology
MDL
method detection limit
mg/dscm
milligrams per dry standard cubic meter
n
number of data points in MACT floor pool
NA
not applicable
NESHAP
National Emission Standards for Hazardous Air Pollutants
ng/dscm
nanograms per dry standard cubic meter
%
percent
PAHs
polycyclic aromatic hydrocarbons
PCM
pushing/charging machine
P&EF
processes and emissions flow table
PM
particulate matter
PM filterable
filterable particulate matter
PQBS
pushing, quenching, and battery stacks
RTO
regenerative thermal oxidizer
RDL
representative detection levels
RTR
residual risk and technology review
S
skewness statistic
SC
SunCoke, Inc.
SEK
standard error of the kurtosis statistic
SES
standard error of the skewness statistic
SO2
sulfur dioxide
TEF
toxicity equivalence factors
TEQ
toxic equivalency
tpy
tons per year
ug/dscm
micrograms per dry standard cubic meter
um
micrometer
UOM
units of measurement
UPL
upper predictive limit
USS
U.S. Steel Corporation
VOHAP
speciated volatile HAP
WAS
wet alkaline scrubber
WHO
World Health Organization

                                 APPENDIX B:
                            MACT FLOOR DEVELOPMENT

B.1 Introduction

      This appendix presents the methodology and the results of developing numerical MACT floor standards for coke oven existing and new sources. Calculations are provided in the accompanying Microsoft Excel(R) file. This MACT floor standard analysis used emissions and operating data collected in the coke oven CAA section 114 requests described in Section 2.0. For more details about the coke dataset, see the memorandum Summary of Coke Ovens Risk and Technology Review: Data Summary ( EPA, 2023a).

B.2 Process Units

The HAP emissions sources at coke facilities for which MACT floors were developed include pushing, battery combustion stacks, HRSG main stacks, and HRSG bypass/waste heat stacks. To develop existing and new source limits for each applicable HAP, information on individual unit stack test run by run data (concentration or lb/ton coke) from the coke oven CAA section 114 requests was used.

B.3 MACT Floor Statistical Analyses - Upper Prediction Limit

The MACT standard analysis for Coke PQBS uses an upper prediction limit (UPL) approach to identify the average emission limitation achieved by the best performing sources. The UPL approach is used in MACT standard analyses because it incorporates the average performance of the best performing sources and the variability of the performance during testing conditions. (EPA, 2021) The UPL represents the value which one can expect the mean of a specified number of future observations (e.g., 3-run average) to fall below for the specified level of confidence, based upon the results of an independent sample from the same population. The level of confidence represents the level of protection afforded to facilities whose emissions are in line with the best performers. For example, a 99 percent level of confidence means that a facility whose emissions are in line with the best performers has one chance in 100 of exceeding the MACT standard emission limit. A prediction interval for a single future observation (or an average of several test observations) is an interval that will, with a specified degree of confidence, contain the next (or the average of some other pre-specified number of) randomly selected observation(s) from a population. In other words, the UPL estimates what the upper bound of future values will be, based upon present or past background samples taken. The UPL approach encompasses all the data point-to-data point variability. The predictions derive from the dataset to which it is applied, and, thus, can be applied to any type of data.
There are different equations for calculating a UPL based on the distribution of the dataset. Data can be normally distributed, lognormally distributed, or neither and thus have a skewed distribution. The statistical tests of skewness and kurtosis was implemented to determine the distribution of the best performing sources' data. (EPA, 2021)

The skewness statistic (S) characterizes the degree of asymmetry of a given data distribution. Normally distributed data have an S value of zero. An S value that is greater than zero indicates that the data are asymmetrically distributed with a right tail extending towards positive values; similarly, an S value that is less than zero indicates that the data are asymmetrically distributed with a left tail extending towards negative values. The value of S can be approximated using the following equation (which is implemented in Microsoft Excel(R) using the "SKEW" function):

where:
n = sample size
 =	 mean of MACT floor pool
xi =	 individual source mean
                                   stdev =
As part of determining whether a data distribution can be considered normal, the S value must be compared to the standard error of the skewness statistic (SES). The SES value can be approximated using the following equation:

According to the skewness hypothesis test, if the absolute value of S is less than two times the absolute value of SES, the skewness of the data can be considered normal.
The kurtosis statistic (K) characterizes the degree of peakedness or flatness of a given data distribution in comparison to a normal distribution. Normally distributed data have a K value of zero. A K value that is greater than zero indicates a relatively peaked distribution. A K value that is less than zero indicates a relatively flat distribution. The estimate of K can be calculated one of two ways. For datasets with more than three run values, kurtosis can be estimated using the following equation (which is implemented in Microsoft Excel(R) using the "KURT" function):

This equation cannot be used for datasets with three run values (n=3) because there will be a zero in the denominator of the first and second term. Instead, for datasets with three run values, kurtosis is estimated using the following equation:

As part of determining whether a data distribution can be considered normal, the K value must be compared to the standard error of the kurtosis statistic (SEK). The SEK value can be approximated using the following equation:
	 for datasets with more than three runs (n>3)
	 for datasets with three runs (n=3)
According to the kurtosis hypothesis test, if the absolute value of K is less than two times the absolute value of SEK, the kurtosis of the data can be considered normal.

For this MACT standard analysis, if the results from both the skewness and kurtosis hypothesis tests indicated the dataset was normally distributed, the dataset was treated as normally distributed in subsequent UPL calculations. If either of these tests indicated the dataset was not normally distributed, the dataset was log-transformed, and the log-transformed dataset was evaluated for kurtosis and skewness. If both tests of the log-transformed data indicated the log-transformed dataset was normally distributed, the dataset was treated as lognormally distributed in subsequent UPL calculations. If either of these tests indicated that the raw data was normally distributed AND the log-transformed dataset was normally distributed the skewness/SES values from raw data were compared to the skewness/SES values from log-transformed data. The smaller skewness/SES value was selected as an indication of a larger likelihood of the data to come from the corresponding distribution. If either of these tests indicated the log-transformed dataset was not normally distributed, the dataset was treated as skewed distribution in subsequent UPL calculations.

      After completing the determination of the type of data distribution for each dataset, the UPL was calculated using the corresponding equation for the distribution for that dataset.

Normally-Distributed Dataset

where:
UPL =	 upper prediction limit
 =	 mean of the data calculated as
n =	 number of test runs =
m = 	number of future test runs in the compliance average
N =	 number of sources
s2 =	 pooled variance calculated as
tdf,0.99 = quantile of t-distribution at the 99 percent level of confidence with degrees of freedom (df); this value can be calculated with the Student's t-test statistical method, using the "TINV" function in Microsoft Excel(R) software
df =	 degrees of freedom calculated as
Lognormally-Distributed Dataset (Bhaumik and Gibbons, 2004)

where:
 = 	 = the average of the log transformed data from the data
 =	 = variance estimate of the log transformed data
Z0.99 =	the 99th-percentile of the log-normal distribution estimated using the trapezoidal rule approach from the following equation:

Skewed/Unknown-Distributed Dataset (Non-Normal/Non-Lognormal) (Gayen, 1949)

where:
UPL = 	upper prediction limit
 = 	mean of the data calculated as
n = 	number of test runs =
m = 	number of future test runs in the compliance average
N = 	number of sources
s2 = 	pooled variance calculated as
tdf,p = 	recalculated quantile of t-distribution based on specified level of confidence (i.e., 99 percent)
df = 	degrees of freedom calculated as

B.4 Representative Detection Limit

The imprecision of test method measurements is another component of data variability. At very low emissions levels, as encountered in some of the data in the coke dataset, the inherent imprecision in the pollutant measurement method has a large influence on the reliability of the data underlying a MACT standard emission limit. Of particular concern are those data that are reported near or below a test method's pollutant detection capability. Because of matrix effects, laboratory techniques, sample volume, and other factors, method detection limits normally vary from test to test. In the data gathering from the coke industry in the 2016 coke oven CAA section 114 requests, the coke facilities were requested to note data that were measured below the method detection limit and to report those values as equal to the test-specific method detection limit.

Variability of data due to measurement imprecision is inherently and reasonably addressed in calculating a MACT standard emission limit when most of the data are significantly above the method detection limit. For datasets with a large number of test results below the method detection limit (reported as method detection limit values), other techniques need to be used to account for data variability. Indeed, under such a shift, the data distribution becomes truncated on the lower end, leading to an artificial overabundance of values occurring at the method detection limit. There is a concern that a MACT standard emission limit based on a truncated data base (i.e., calculated using values at or near the method detection limit) may not account adequately for data measurement variability, because the measurement error associated with those values provides a large degree of uncertainty. The expected measurement imprecision for an emissions value occurring at or near the detection limit is about 40 to 50 percent. Relative pollutant measurement imprecision decreases to a consistent 10 to 15 percent for values measured at a level about three times the method detection limit (ASME, 2001).

      The approach taken to account for measurement variability includes defining a detection limit that is representative of the data used in establishing a MACT standard emission limitation and also minimizes the influence of an outlier test-specific method detection limit value. A list of representative detection levels (RDL) has been developed from available HAP-specific method detection levels ( EPA, 2011) (Parker, 2018). These RDL values are then multiplied by three to decrease measurement imprecision to around 10 to 15 percent (as noted in the previous paragraph), resulting in values referred to as "3xRDL" values. The appropriate 3xRDL value then is compared to the calculated UPL value for each HAP and individual emission unit or process group. The larger of the 3xRDL value and the calculated UPL value is used for the MACT standard emission limit to ensure that measurement variability is adequately addressed.

      For more information regarding the general use of the UPL and why it is appropriate for calculating MACT floors, see the memorandum Use of the Upper Prediction Limit for Calculating MACT Floors (EPA, 2021).

B.5 MACT Floor Emissions Limit Development Methodology

      The following are the seven discrete steps used in development of MACT floors for the coke industry.

Step 1.

The first step is calculation of an average emission value for each individual emission unit, by HAP and by each unit of measure in the available test data. For any run fractions marked as less than the method detection limit (or other reporting limit), the fraction was considered below the detection limit (BDL). For the EPA Method 29 multi-metals test, each metal laboratory analysis typically has two separate fractions: front-half (filter) and back-half (impinger catch); Hg can have three additional back-half fractions. For this analysis, the method detection limit (MDL) for each fraction was used as the mass to calculate a run value, e.g., pound per ton (lb/ton).

Step 2.

      Once an average HAP emission value was calculated for each unit, all of the individual average emission values were ranked from lowest to highest value. See Tables B-1  -  B-17 for the ranking of sources per pollutant emissions.

     Table B-1. Pushing  -  Hg Emissions Ranking from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                               Hg (lb/ton coke)
                                     Rank
                              Used in MACT Floor?
AKS-Middletown-OH
Pushing Baghouse
                                   2.50E-08
                                       1
                                      Yes
SC-Middletown-OH
Middletown Flat Push Hot Car
                                   4.48E-08
                                       2
                                      Yes
CC-Burnsharbor-IN
#2 Coke Battery Pushing Baghouse Stack
                                   1.66E-07
                                       3
                                      Yes
SC-GraniteCity-IL
Gateway Flat Push Hot Car
                                   2.00E-07
                                       4
                                      Yes
CC-Monessen-PA
Pushing Baghouse Stack
                                   4.77E-07
                                       5
                                      Yes

     Table B-2. Pushing  -  AG Emissions Ranking from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                      AG
                                 (lb/ton coke)
                                     Rank
                              Used in MACT Floor?
AKS-Middletown-OH
Pushing Baghouse
                                    0.00029
                                       1
                                      Yes
CC-Monessen-PA
Pushing Baghouse Stack
                                    0.0012
                                       2
                                      Yes
SC-Middletown-OH
Middletown Flat Push Hot Car
                                    0.0017
                                       3
                                      Yes
CC-Burnsharbor-IN
#2 Coke Battery Pushing Baghouse Stack
                                    0.0024
                                       4
                                      Yes

     Table B-3. Pushing  -  HCN Emissions Ranking from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                     HCN
                                 (lb/ton coke)
                                     Rank
                              Used in MACT Floor?
SC-Middletown-OH
Middletown Flat Push Hot Car
                                   0.000024
                                       1
                                      Yes
AKS-Middletown-OH
Pushing Baghouse
                                    0.00011
                                       2
                                      Yes
CC-Monessen-PA
Pushing Baghouse Stack
                                    0.00074
                                       3
                                      Yes
CC-Burnsharbor-IN
#2 Coke Battery Pushing Baghouse Stack
                                    0.00084
                                       4
                                      Yes

     Table B-4. Pushing  -  PAH Emissions Ranking from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                               PAH (lb/ton coke)
                                     Rank
                              Used in MACT Floor?
SC-Middletown-OH
Middletown Flat Push Hot Car
                                   4.11E-06
                                       1
                                      Yes
AKS-Middletown-OH
Pushing Baghouse
                                   6.75E-06
                                       2
                                      Yes
CC-Burnsharbor-IN
#2 Coke Battery Pushing Baghouse Stack
                                   3.57E-05
                                       3
                                      Yes
CC-Monessen-PA
Pushing Baghouse Stack
                                   1.08E-04
                                       4
                                      Yes
Table B-5. ByP Battery Combustion  -  Hg Emissions Ranking from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                               Hg (lb/ton coke)
                                     Rank
                              Used in MACT Floor?
CC-Monessen-PA
Battery Combustion Stack #2
                                   3.86E-06
                                       1
                                      Yes
AKS-Middletown-OH
Combustion Stack
                                   4.18E-06
                                       2
                                      Yes
USS-Clairton-PA
Battery B Combustion Stack (S012)
                                   7.13E-06
                                       3
                                      Yes
CC-Burnsharbor-IN
Coke Battery No. 2 Underfire Stack
                                   3.23E-05
                                       4
                                      Yes

Table B-6. ByP Battery Combustion  -  PM Emissions Ranking from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                 PM (gr/dscf)
                                     Rank
                              Used in MACT Floor?
USS-Clairton-PA
Battery B Combustion Stack (S012)
                                    0.0047
                                       1
                                      Yes
CC-Monessen-PA
Battery Combustion Stack #2
                                    0.0067
                                       2
                                      Yes
AKS-Middletown-OH
Combustion Stack
                                     0.029
                                       3
                                      Yes
CC-BurnsHarbor-IN
Coke Battery No. 2 Underfire Stack
                                     0.050
                                       4
                                      Yes

Table B-7. ByP Battery Combustion  -  AG Emissions Ranking from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                      AG
                                 (lb/ton coke)
                                     Rank
                              Used in MACT Floor?
CC-Monessen-PA
Battery Combustion Stack #2
                                     0.010
                                       1
                                      Yes
USS-Clairton-PA
Battery B Combustion Stack (S012)
                                     0.015
                                       2
                                      Yes
CC-BurnsHarbor-IN
Coke Battery No. 2 Underfire Stack
                                     0.016
                                       3
                                      Yes
AKS-Middletown-OH
Combustion Stack
                                     0.061
                                       4
                                      Yes

Table B-8. ByP Battery Combustion  -  HCN Emissions Ranking from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                     HCN
                                 (lb/ton coke)
                                     Rank
                              Used in MACT Floor?
USS-Clairton-PA
Battery B Combustion Stack (S012)
                                    0.00017
                                       1
                                      Yes
CC-Monessen-PA
Battery Combustion Stack #2
                                    0.00052
                                       2
                                      Yes
CC-Burnsharbor-IN
Coke Battery No. 2 Underfire Stack
                                    0.0024
                                       3
                                      Yes
AKS-Middletown-OH
Combustion Stack
                                    0.0030
                                       4
                                      Yes

Table B-9. HNR HRSG Main Stack  -  Hg Emissions Ranking from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                 Hg (gr/dscf)
                                     Rank
                              Used in MACT Floor?
SC-Middletown-OH
P901- Battery A-C - Main Stack
                                    9.0E-07
                                       1
                                      Yes
CE-EastChicago-IN /
SC-EastChicago-IN
HRSG Main Stack
                                    1.7E-06
                                       2
                                      Yes

Table B-10. HNR HRSG Main Stack  -  PM Emissions Ranking from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                 PM (gr/dscf)
                                     Rank
                              Used in MACT Floor?
CE-EastChicago-IN /
SC-EastChicago-IN
HRSG Main Stack
                                    0.00036
                                       1
                                      Yes
SC-Middletown-OH
P901- Battery A-C - Main Stack
                                    0.0027
                                       2
                                      Yes

Table B-11. HNR HRSG Main Stack  -  AG Emissions Ranking from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                 AG (gr/dscf)
                                     Rank
                              Used in MACT Floor?
SC-Middletown-OH
P901- Battery A-C - Main Stack
                                    0.0022
                                       1
                                      Yes
CE-EastChicago-IN /
SC-EastChicago-IN
HRSG Main Stack
                                    0.0082
                                       2
                                      Yes

Table B-12. HNR HRSG Main Stack  -  PAH Emissions Ranking from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                 PAH (gr/dscf)
                                     Rank
                              Used in MACT Floor?
CE-EastChicago-IN /
SC-EastChicago-IN
HRSG Main Stack
                                    2.8E-07
                                       1
                                      Yes
SC-Middletown-OH
P901- Battery A-C - Main Stack
                                    3.8E-07
                                       2
                                      Yes

    Table B-13. HNR HRSG Bypass/ Waste Heat Stack  -  Hg Emissions Ranking
                           from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                 Hg (gr/dscf)
                                     Rank
                              Used in MACT Floor?
SC-GraniteCity-IL
Coke Oven Battery C - Bypass Vent 5
                                    5.2E-06
                                       1
                                      Yes
SC-FranklinFurnace-OH
Bypass Vent Stack 6
                                    7.0E-06
                                       2
                                      Yes

    Table B-14. HNR HRSG Bypass/ Waste Heat Stack  -  PM Emissions Ranking
                           from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                 PM (gr/dscf)
                                     Rank
                              Used in MACT Floor?
SC-GraniteCity-IL
Coke Oven Battery C - Bypass Vent 5
                                     0.013
                                       1
                                      Yes
SC-FranklinFurnace-OH
Bypass Vent Stack 6
                                     0.020
                                       2
                                      Yes

    Table B-15. HNR HRSG Bypass/ Waste Heat Stack  -  AG Emissions Ranking
                           from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                 AG (gr/dscf)
                                     Rank
                              Used in MACT Floor?
SC-GraniteCity-IL
Coke Oven Battery C - Bypass Vent 5
                                     0.058
                                       1
                                      Yes
SC-FranklinFurnace-OH
Bypass Vent Stack 6
                                     0.086
                                       2
                                      Yes

   Table B-16. HNR HRSG Bypass/ Waste Heat Stack  -  PAH Emissions Ranking
                           from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                                 PAH (gr/dscf)
                                     Rank
                              Used in MACT Floor?
SC-GraniteCity-IL
Coke Oven Battery C - Bypass Vent 5
                                    6.5E-07
                                       1
                                      Yes

Table B-17. HNR HRSG Bypass/ Waste Heat Stack  -  Formaldehyde Emissions Ranking
                           from Coke Oven Test Data
                                   Facility
                                 Emission Unit
                            Formaldehyde (gr/dscf)
                                     Rank
                              Used in MACT Floor?
SC-GraniteCity-IL
Coke Oven Battery C - Bypass Vent 5
                                    4.7E-06
                                       1
                                      Yes
SC-FranklinFurnace-OH
Bypass Vent Stack 6
                                    1.0E-04
                                       2
                                      Yes

Step 3.

The best performing sources per process type and HAP were identified from the rankings shown in Tables B-1 through B-17, consistent with the criteria in CAA section 112(d)(3) for determining MACT standards for existing sources. These sources are referred to as the "MACT floor pool." For the existing source and new source MACT standards, the number of individual sources in the MACT floor pool was determined, as shown in Table B-18.

Table B-18. Number of Sources in Existing and New Source MACT Floor Pool
per Process Type and HAP
                                 Process Type
                                      HAP
                               Number of Sources
                                   with Data
                          Existing and/or New Source
                                No. Sources in
                                MACT Floor Pool
                    No. Data Points in MACT Floor Pool (n)
Pushing
                                      Hg
                                       5
                                   Existing
                                       5
                                      15

                                      New
                                       1
                                       3

                                 AG & PAH
                                       4
                                   Existing
                                       4
                                      12

                                      New
                                       1
                                       3

                                      HCN