                                  MEMORANDUM

DATE:	May 1, 2023

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

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

SUBJECT:	Coke Ovens Risk and Technology Review: Compliance Costs
______________________________________________________________________________
                                   CONTENTS
1.0	INTRODUCTION AND BACKGROUND	2
2.0	MACT/BTF COMPLIANCE COSTS FOR COKE PQBS NESHAP	3
2.1	MACT/BTF Testing Costs	3
2.2	MACT/BTF Recordkeeping and Reporting Costs for PQBS NESHAP	7
2.3	Total MACT/BTF Compliance Costs for Testing, Recordkeeping, and Reporting for PQBS NESHAP	7
3.0	FENCELINE FUGITIVE MONITORING COSTS FOR COKE OVEN BATTERIES NESHAP	9
3.1	Fenceline Fugitive Monitoring Testing Costs	9
3.2	Fenceline Fugitive Monitoring Recordkeeping and Reporting Costs	10
3.3	Total Fenceline Fugitive Monitoring Costs	10
4.0	TOTAL COMPLIANCE COSTS	10
Appendix A Coke Costs: All Testing	1
                                LIST OF TABLES

Table 1. MACT/BTF Total Proposed Annualized Compliance Costs By Test Method for Coke
	PQBS NESHAP	3
Table 2. Pushing MACT Proposed Compliance Testing Costs per Unit for PQBS NESHAP	4
Table 3. ByP Battery Combustion Stack MACT Compliance Testing Costs PQBS NESHAP	5
Table 4. HNR HRSG Main Stack MACT Proposed Compliance Testing Costs	5
Table 5. HNR HRSG Bypass/Waste Heat Stack MACT/BTF Proposed Compliance Testing Costs
	for PQBS NESHAP	6
Table 6. Total MACT/BTF Proposed Compliance Testing Costs for PQBS NESHAP  -
	Annualized Costs for Testing Every 5 Years	7
Table 7. MACT/BTF Recordkeeping and Reporting Costs per Facility by Method and
	Facility Type for Proposed Compliance Testing PQBS NESHAP	8
Table 8. Total MACT/BTF Proposed Recordkeeping and Reporting Costs for Compliance
Testing at Coke Facilities for PQBS NESHAP	8
Table 9. Total MACT/BTF Proposed Annual Compliance Costs for Testing, Recordkeeping,
	and Reporting By Facility and Total Industry for PQBS NESHAP	9
Table 10. Fenceline Fugitive Monitoring, Recordkeeping, and Reporting Proposed Costs	10
Table 11. Total Proposed Testing Compliance Costs per Facility or the Coke NESHAPs	11

1.0	INTRODUCTION AND BACKGROUND
This memorandum describes the compliance costs due to testing that are estimated for facilities to comply with the proposed Residual Risk and Technology Review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Coke Ovens: Pushing, Quenching, and Battery Stacks (Coke PQBS NESHAP) (40 CFR part 63, subpart CCCCC) and technology review of Coke Oven Batteries NESHAP (40 CFR part 63, subpart L).
In accordance with section 112(d)(2) and (3) of the Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) promulgated a NESHAP for coke oven facility sources under Coke PQBS NESHAP on April 14, 2003 (68 FR 18008). The 2003 Coke PQBS NESHAP established maximum achievable control technology (MACT) standards for pushing, quenching, and battery stacks. The MACT for the Coke Oven Batteries NESHAP was promulgated on October 27, 1993 (58 FR 57898) when the EPA set standards for leaks from oven doors, lids, and offtake, and for charging. The RTR for Coke Oven Batteries NESHAP was promulgated on April 15, 2005 (72 FR 19992). Under section 112(f)(2) of the CAA, the EPA is required to perform a residual risk analysis of MACT standards within eight years of promulgation. In addition, the EPA is required to perform a technology review of MACT standards every eight years under section 112(d)(6) of the CAA. The Coke PQBS RTR was due in 2011. The technology review of Coke Oven Batteries NESHAP was due in 2013.
As a result of the Louisiana Environmental Action Network (LEAN) v. EPA, 955 F3d at 1091-1099 (D.C. Cir. 2020) litigation, the EPA is required to address any previously unregulated or underregulated HAP emissions as part of its periodic review of MACT standards under CAA section 112(d)(6). Thus, the EPA is required to regulate all HAP that are emitted from source categories, such coke ovens, that are listed under CAA section 112(c) and subject to CAA section 112(d)(2)/(3). Therefore, concurrent with the RTR, the EPA evaluated coke oven sources for unregulated or under-regulated HAP. This memorandum describes the results of this evaluation and the MACT standards being proposed.
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 PQBS 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 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 by-product (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 exhaust (and is regulated under Coke Oven Batteries NESHAP); for nonrecovery plants (i.e., no chemical recovery) with heat recovery, the coke oven gases are sent to a heat recovery steam generator (HRSG) that produces power for sale and also to units that perform gas cleaning; for nonrecovery plants without heat recovery (NR), oven exhaust gases are released to the air through waste heat stacks.
The purpose of this memorandum is to describe the compliance costs for the proposed coke rules that include testing, recordkeeping, and reporting costs for the proposed MACT and beyond-the-(MACT) floor (BTF) limits, and testing, recordkeeping, and reporting costs for the proposed fenceline fugitive monitoring for benzene.

2.0	MACT/BTF COMPLIANCE COSTS FOR COKE PQBS NESHAP
The Coke PQBS NESHAP proposed rule includes requirements for compliance testing with 17 proposed HAP emissions limits (15 MACT and 2 BTF) for metal HAP using particulate matter (PM) as a surrogate (metal HAP/PM), mercury (Hg), acid gases (AG), hydrogen cyanide (HCN), dioxin/furan (as toxic equivalents) (D/F TEQ), polycyclic aromatic hydrocarbons (PAH), and formaldehyde developed for sources under the Coke PQBS NESHAP.
2.1	MACT/BTF Testing Costs
To comply with the MACT/BTF standards under the Coke PQBS NESHAP, facilities would be required to conduct regular performance testing to demonstrate they are complying with the proposed standards. The proposed Coke PQBS NESHAP includes a requirement for MACT/BTF compliance testing every 5 years. Table 1 summarizes the proposed compliance testing costs per test method annualized over 5 years for tests performed every 5 years. Tables 2 through 5 summarize the proposed annualized compliance testing costs by emission source: ByP and HNR pushing; ByP battery combustion stacks; HNR HRSG stacks; and HNR HRSG bypass/waste heat stack. Table 6 summarizes the annualized industry-wide costs for the proposed compliance testing for MACT/BTF limits for the Coke PQBS NESHAP, by facility.

 Table 1. MACT/BTF Total Proposed Annualized Compliance Costs By Test Method
                             for Coke PQBS NESHAP
                                   Parameter
                                 HAP/PM Metals
                                      Hg
                                      AG
                                      HCN
                                      AG+
                                      HCN
                                    D/F TEQ
                                      PAH
                                 Formalde-hyde
Method
                                   Method 5
                                   Method 29
                                 Method 26/26A
                                  Method 320
                                  Method 320
                                   Method 23
                                   CARB 429
                                  Method 316
Unit Test Cost
                                    $18,500
                                    $23,500
                                    $22,800
                                    $40,000
                                    $42,000
                                    $27,600
                                    $31,800
                                    $22,800
Interest Rate
                                                                            7.5
                                                                            7.5
                                                                            7.5
                                                                            7.5
                                                                            7.5
                                                                            7.5
                                                                            7.5
                                                                            7.5
Annual Interest Rate (fraction):
                                                                          0.075
                                                                          0.075
                                                                          0.075
                                                                          0.075
                                                                          0.075
                                                                          0.075
                                                                          0.075
                                                                          0.075
Testing Frequency (years)
                                                                              5
                                                                              5
                                                                              5
                                                                              5
                                                                              5
                                                                              5
                                                                              5
                                                                              5
Capital Recovery Factor:
                                                                    0.247164718
                                                                    0.247164718
                                                                    0.247164718
                                                                    0.247164718
                                                                    0.247164718
                                                                    0.247164718
                                                                    0.247164718
                                                                    0.247164718
Annualized Testing Costs
(over 5-yr period)
                                                                         $4,573
                                                                         $5,808
                                                                         $5,635
                                                                         $9,887
                                                                        $10,381
                                                                         $6,822
                                                                         $7,860
                                                                         $5,635

Table 2. Pushing MACT Proposed Compliance Testing Costs per Unit for PQBS NESHAP
                                    Facility
                                 Emission Unit
                           Annualized Testing Costs$

                                      Hg
                                    AG+HCN
                                      PAH
                                     Total
ABC-Tarrant-AL
1 Baghouse 1
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
ABC-Tarrant-AL
1 Baghouse 2
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
ABC-Tarrant-AL
5 &6 Baghouse
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
AKS-Follansbee-WV
Baghouse for Batteries 1-2-3 CO1 (Stack 1-14)
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
AKS-Follansbee-WV
Venturi Scrubber Battery #8 CO2 (Stack 06)
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
AKS-Middletown-OH
B918-3 PEC Baghouse Exhaust Stack 1-5
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
AM-BurnsHarbor-IN
EP512-3018
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
AM-BurnsHarbor-IN
EP512-3024
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
AM-Monessen-PA
PRO 802
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
AM-Warren-OH
B901-1 Pushing along Battery No. 4
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
BLU-Birmingham-AL
57772612
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
EES-RiverRouge-MI
PECS Baghouse Stack
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
SC-EastChicago-IN
Baghouse 204
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
SC-FranklinFurnace-OH
Pushing multiclone Stack AB
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
SC-FranklinFurnace-OH
Pushing multiclone Stack CD
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
SC-GraniteCity-IL
Flat push hot car with multiclone
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
SC-Middletown-OH
Flat push hot car with multiclone
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
SC-Vansant-VA
Cokeside Shed Settling Chamber Pushing along Battery 2D
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
SC-Vansant-VA
Cokeside Shed Settling Chamber Pushing along Battery 2E
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
SC-Vansant-VA
Cokeside Shed Settling Chamber Pushing along Battery 3B
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
SC-Vansant-VA
Cokeside Shed Settling Chamber Pushing along Battery 3C
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
SC-Vansant-VA
Cokeside Shed Settling Chamber Pushing along Battery 3F
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
SC-Vansant-VA
Cokeside Shed Settling Chamber Pushing along Battery 3G
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
USS-Clairton-PA
ACHD Permit # 0052-I011 P001
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
USS-Clairton-PA
P050
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
USS-Clairton-PA
P052-PEC Baghouse 13-15
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
USS-Clairton-PA
P053
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049
USS-Clairton-PA
P054
                                    $5,808
                                    $10,381
                                    $7,860
                                    $24,049

Table 3. ByP Battery Combustion Stack MACT Compliance Testing Costs for PQBS NESHAP
                                    Facility
                                Emission Unit
                           Annualized Testing Costs$

                                      Hg
                                     HAP
                                    Metals
                                    AG+HCN
                                     Total
ABC-Tarrant-AL
Underfiring stack #4, serving batteries #5 and #6
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
ABC-Tarrant-AL
Underfiring stack #1, serving battery #1
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
AKS-Follansbee-WV
Battery #1 combustion
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
AKS-Follansbee-WV
Battery #2 combustion
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
AKS-Follansbee-WV
Battery #3 combustion
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
AKS-Follansbee-WV
Battery #8 combustion
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
AKS-Middletown-OH
Wilputte coke oven battery - combustion stack
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
AM-BurnsHarbor-IN
EU512-08 battery #1 underfire
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
AM-BurnsHarbor-IN
EU512-16 battery #2 underfire
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
AM-Monessen-PA
Coke oven battery 1b underfiring (combustion stack)
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
AM-Monessen-PA
Coke oven battery 2 underfiring (combustion stack)
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
AM-Warren-OH
No. 4 Coke oven battery - Oven Underfiring
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
BLU-Birmingham-AL
Underfiring stack of coke batteries no. 3 & 4
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
BLU-Birmingham-AL
Underfiring stack of coke battery no. 5
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
EES-RiverRouge-MI
Battery heating stack
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
USS-Clairton-PA
Coke oven battery 1 underfiring
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
USS-Clairton-PA
Coke oven battery 2 underfiring
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
USS-Clairton-PA
Coke oven battery 3 underfiring
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
USS-Clairton-PA
Coke oven battery 13 underfiring
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
USS-Clairton-PA
Coke oven battery 14 underfiring
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
USS-Clairton-PA
Coke oven battery 15 underfiring
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
USS-Clairton-PA
Coke oven battery 19 underfiring
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
USS-Clairton-PA
Coke oven battery 20 underfiring
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
USS-Clairton-PA
Coke oven b battery underfiring
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762
USS-Clairton-PA
Coke oven c battery underfiring
                                                                         $5,808
                                                                         $4,573
                                                                        $10,381
                                                                        $20,762

Table 4. HNR HRSG Main Stack MACT Proposed Compliance Testing Costs for PQBS NESHAP
                                    Facility
                                 Emission Unit
                           Annualized Testing Costs$

                                      Hg
                                     HAP/
                                      PM
                                      AG
                                      PAH
                                     Total
SC-EastChicago-IN
HRCCF main stack 001
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                        $23,876
SC-FranklinFurnace-OH
P901- battery A&B - main stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                        $23,876
SC-FranklinFurnace-OH
P902- battery C&D - main stack CD
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                        $23,876
SC-GraniteCity-IL
0005 - battery A&B&C - main stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                        $23,876
SC-Middletown-OH
P901- battery A-C - main stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                        $23,876

Table 5. HNR HRSG Bypass/Waste Heat Stack MACT/BTF Proposed Compliance Testing Costs
                               for PQBS NESHAP
                                    Facility
                                 Emission Unit
                           Annualized Testing Costs$

                                      Hg
                                      PM
                                      AG
                                      PAH
                                     Form
                                     Total
SC-EastChicago-IN
Venting Stack 1
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 2
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 3
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 4
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 5
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 6
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 7
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 8
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 9
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 10
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 11
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 12
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 13
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 14
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 15
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-EastChicago-IN
Venting Stack 16
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-FranklinFurnace-OH
HRSG Bypass Vent Stack 1
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-FranklinFurnace-OH
HRSG Bypass Vent Stack 2
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-FranklinFurnace-OH
HRSG Bypass Vent Stack 3
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-FranklinFurnace-OH
HRSG Bypass Vent Stack 4
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-FranklinFurnace-OH
HRSG Bypass Vent Stack 5
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-FranklinFurnace-OH
HRSG Bypass Vent Stack 6
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-FranklinFurnace-OH
HRSG Bypass Vent Stack 7
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-FranklinFurnace-OH
HRSG Bypass Vent Stack 8
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-FranklinFurnace-OH
HRSG Bypass Vent Stack 9
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-FranklinFurnace-OH
HRSG Bypass Vent Stack 10
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-GraniteCity-IL
HRSG Bypass Vent Stack 1
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-GraniteCity-IL
HRSG Bypass Vent Stack 2
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-GraniteCity-IL
HRSG Bypass Vent Stack 3
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-GraniteCity-IL
HRSG Bypass Vent Stack 4
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-GraniteCity-IL
HRSG Bypass Vent Stack 5
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-GraniteCity-IL
HRSG Bypass Vent Stack 6
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Middletown-OH
HRSG Bypass Vent Stack 1
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Middletown-OH
HRSG Bypass Vent Stack 2
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Middletown-OH
HRSG Bypass Vent Stack 3
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Middletown-OH
HRSG Bypass Vent Stack 4
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Middletown-OH
HRSG Bypass Vent Stack 5
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 1 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 2 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 3 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 4 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 5 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 6 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 7 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 8 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 9 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 10 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 11 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 12 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 13 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 14 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 15 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511
SC-Vansant-VA
Venting 16 Stack
                                                                         $5,808
                                                                         $4,573
                                                                         $5,635
                                                                         $7,860
                                                                         $5,635
                                                                        $29,511

Table 6. Total MACT/BTF Proposed Compliance Testing Costs for PQBS NESHAP  -
                  Annualized Costs for Testing Every 5 Years
                                   Facility
Annualized Costs* ($/year) for Testing Every 5 Years to Meet Proposed MACT Limits

                          Pushing
[Hg, AG, HCN, PAH]
                     Battery Combustion
[Hg, PM, AG, HCN]
                          HRSG Main
[Hg, PM, AG, PAH]
                   Bypass/Waste Heat
[Hg, PM, AG, PAH, Form]
                                Facility Total
ABC-Tarrant-AL
                                    $72,147
                                    $41,524

                                   $113,671
CC-BurnsHarbor-IN
                                    $48,098
                                    $41,524

                                    $89,622
CC-Monessen-PA
                                    $24,049
                                    $41,524

                                    $65,573
CC-Warren-OH
                                    $24,049
                                    $20,762

                                    $44,811
EES-RiverRouge-MI
                                    $24,049
                                    $20,762

                                    $44,811
SC-EastChicago-IN
                                    $24,049

                                    $23,876
                                   $472,183
                                   $520,109
SC-FranklinFurnace-OH
                                    $48,098

                                    $47,752
                                   $295,115
                                   $390,965
SC-GraniteCity-IL
                                    $24,049

                                    $23,876
                                   $177,069
                                   $224,994
SC-Middletown-OH
                                    $24,049

                                    $23,876
                                   $147,557
                                   $195,483
SC-Vansant-VA
                                   $144,295

                                   $472,183
                                   $616,478
USS-Clairton-PA
                                   $120,246
                                   $207,618

                                   $327,864
Industry Total
                                   $577,179
                                   $373,713
                                   $119,381
                                  $1,564,108
                                  $2,634,380
*Annualized over 5 years.

2.2	MACT/BTF Recordkeeping and Reporting Costs for PQBS NESHAP
The proposed rule requires compliance testing with 17 proposed emissions limits (15 MACT and 2 BTF) which have associated recordkeeping and reporting requirements. Table 7 summarizes the costs for recordkeeping and reporting of MACT/BTF proposed compliance testing by method and facility-type basis (e.g., ByP, HR, and NR) on a per-facility basis. Table 8 summarizes the total annual recordkeeping and reporting costs for the proposed MACT/BTF compliance testing for each coke facility. Additional details on MACT/BTF compliance recordkeeping, and reporting can be found in Table 1 of the supporting statement OMB Burden ICR 1995.09 for the Coke PQBS NESHAP proposed rulemaking, Docket ID No. EPA-HQ-OAR-2002-0085.
2.3	Total MACT/BTF Compliance Costs for Testing, Recordkeeping, and Reporting for PQBS NESHAP
      Table 9 summarizes the total MACT/BTF costs for testing, recordkeeping, and reporting due to proposed compliance testing for the PQBS NESHAP.

Table 7. MACT/BTF Recordkeeping and Reporting Costs per Facility by Method and Facility Type for Proposed Compliance Testing for PQBS NESHAP
                           Cost Item by Test Method
                                 Annual Costs$

                                Industry Total
                              Per Facility Costs

                                      ByP
                                      HR
                                      NR
Recordkeeping Requirements
Method 29, 320, and CARB 429 - Pushing
                                    $19,489
                                    $1,392
                                   $1,392 9
                                    $1,392
Method 29, 5, and 320 - ByP Battery Combustion
                                    $17,540
                                    $1,948
                                      NA
                                      NA
Method 29, 5, 26/26A, and CARB 429 - HNR HRSG Main Stack
                                    $4,826
                                      NA
                                    $1,206
                                      NA
Method 29, 5, 26/26A, CARB 429, 316 - HNR HRSG Bypass/Waste Heat
                                    $61,484
                                      NA
                                    $12,297
                                    $12,297
Reporting Requirements
Method 29 [Hg]- Pushing
                                    $32,482
                                    $2,320
                                    $2,320
                                    $2,320
Method 320 [AG+HCN] - Pushing
                                    $32,482
                                    $2,320
                                    $2,320
                                    $2,320
CARB 429 [PAH] - Pushing
                                    $32,482
                                    $2,320
                                    $2,320
                                    $2,320
Method 29 [Hg] - ByP Battery Combustion Stack
                                    $29,233
                                    $3,248
                                      NA
                                      NA
Method 5 [PM] - ByP Battery Combustion Stack
                                   $29,233.
                                    $3,248
                                      NA
                                      NA
Method 320 [AG+HCN] - ByP Battery Combustion Stack
                                    $29,233
                                    $3,248
                                      NA
                                      NA
Method 29 [Hg] - HNR HRSG Main Stack
                                    $6,032
                                      NA
                                    $1,508
                                      NA
Method 5 [PM] - HNR HRSG Main Stack
                                    $6,032
                                      NA
                                    $1,508
                                      NA
Method 26/26A [AG] - HNR HRSG Main Stack
                                    $6,032
                                      NA
                                    $1,508
                                      NA
CARB 429 [PAH] - HNR HRSG Main Stack
                                    $6,032
                                      NA
                                    $1,508
                                      NA
Method 29 - HNR HRSG Bypass/Waste Heat Stack
                                    $61,484
                                      NA
                                    $12,296
                                    $12,297
Method 5 - HNR HRSG Bypass/Waste Heat Stack
                                    $61,484
                                      NA
                                    $12,296
                                    $12,297
Method 26/26A - HNR HRSG Bypass/Waste Heat Stack
                                    $61,484
                                      NA
                                    $12,296
                                    $12,297
CARB 429 - HNR HRSG Bypass/Waste Heat Stack
                                    $61,484
                                      NA
                                    $12,296
                                    $12,297
Method 316 - HNR HRSG Bypass/Waste Heat Stack
                                    $61,484
                                      NA
                                    $12,296
                                    $12,297
Total Recordkeeping and Reporting
                                   $620,037
                                    $20,046
                                    $89,372
                                    $82,133
Note: NA = not applicable because unit is not present at the facility type.

Table 8. Total Annual MACT/BTF Proposed Recordkeeping and Reporting Costs for Compliance Testing at Coke Facilities for PQBS NESHAP
                                    Facility
                                 Facility Type
Total Annual MACT/BTF Recordkeeping and Reporting Costs for Compliance Testing
ABC-Tarrant-AL
                                      ByP
                                    $20,046
CC-BurnsHarbor-IN
                                      ByP
                                    $20,046
CC-Monessen-PA
                                      ByP
                                    $20,046
CC-Warren-OH
                                      ByP
                                    $20,046
EES-RiverRouge-MI
                                      ByP
                                    $20,046
SC-EastChicago-IN
                                      HR
                                    $89,372
SC-FranklinFurnace-OH
                                      HR
                                    $89,372
SC-GraniteCity-IL
                                      HR
                                    $89,372
SC-Middletown-OH
                                      HR
                                    $89,372
SC-Vansant-VA
                                      NR
                                    $82,133
USS-Clairton-PA
                                      ByP
                                    $20,046

Table 9. Total MACT/BTF Proposed Annual Compliance Costs for Testing, Recordkeeping, and Reporting By Facility and Total Industry for PQBS NESHAP
                                    Facility
                                   Facility
                                     Type
                                 Annual Costs$

                                   MACT/BTF
                                    Testing
                                 Recordkeeping
                                      and
                                   Reporting
MACT/BTF
Facility Total
ABC-Tarrant-AL
ByP
                                                                       $113,671
                                                                        $20,046
                                                                       $133,717
CC-BurnsHarbor-IN
ByP
                                                                        $89,622
                                                                        $20,046
                                                                       $109,668
CC-Monessen-PA
ByP
                                                                        $65,573
                                                                        $20,046
                                                                        $85,619
CC-Warren-OH
ByP
                                                                        $44,811
                                                                        $20,046
                                                                        $64,857
EES-RiverRouge-MI
ByP
                                                                        $44,811
                                                                        $20,046
                                                                        $64,857
SC-EastChicago-IN
HNR
                                                                       $520,109
                                                                        $89,372
                                                                       $609,481
SC-FranklinFurnace-OH
HNR
                                                                       $390,965
                                                                        $89,372
                                                                       $480,337
SC-GraniteCity-IL
HNR
                                                                       $224,994
                                                                        $89,372
                                                                       $314,366
SC-Middletown-OH
HNR
                                                                       $195,483
                                                                        $89,372
                                                                       $284,855
SC-Vansant-VA
HNR
                                                                       $616,478
                                                                        $82,133
                                                                       $698,612
USS-Clairton-PA
ByP
                                                                       $327,864
                                                                        $20,046
                                                                       $347,910
                                                                          Total

                                                                     $2,634,380
                                                                       $559,899
                                                                     $3,194,280

3.0	FENCELINE FUGITIVE MONITORING COSTS FOR COKE OVEN BATTERIES NESHAP
The proposed rule for the Coke Oven Batteries NESHAP includes requirements for fenceline monitoring of fugitive benzene emissions at all coke facilities. The testing, recordkeeping, and reporting costs are discussed below.
3.1	Fenceline Fugitive Monitoring Testing Costs
For sampling and analysis of fugitive benzene emissions at the fenceline of coke facilities, a cost of $100 per tube was estimated, where the cost of the tube, including the analysis, is approximately $75, and the costs associated with setting-up and recovering the tube and reviewing and reporting the data are $25. Typically, the sorbent housing is provided by the analytical laboratory; these costs are relatively minimal.
The EPA Method 325A requires a minimum of 12 sampling locations, but depending on facility size and complexity, more sample locations may be required. To be conservative in the estimate of costs, 24 sample locations were used in the cost estimates. The total annual per-facility costs for the tubes are as follows:
Total Annual Cost Per Monitor Site (Facility)
Tubes ($100 x 24 locations)		=	$2,400 per 14-day sampling period
26 x 14-day sampling periods		 = 	$62,400 annual cost ($2023) per facility

To account for any first-year planning costs, the total facility costs for testing were rounded up to $70,000 per facility, inclusive of analytical and labor costs. These costs are shown in Table 10 along with recordkeeping and reporting costs. It is assumed that there will be 11 coke facilities incurring costs for this rule in the 5 years after promulgation of the rule due to inactivity at three other coke plants.

3.2	Fenceline Fugitive Monitoring Recordkeeping and Reporting Costs
The per-facility recordkeeping and reporting costs associated with the fenceline fugitive monitoring testing are shown in Table 10, costs. A cost of $36,745 for recordkeeping and reporting was estimated for each facility. Additional details can be found in Table 1 of the supporting statement OMB Burden ICR 1362.13 for the Coke Oven Batteries NESHAP proposed rulemaking, Docket ID No. EPA-HQ-OAR-2002-0085.
3.3	Total Fenceline Fugitive Monitoring Costs
A total of $106,745 per facility was estimated for fenceline fugitive monitoring, which included $70,000 per facility for fenceline monitoring tests and $36,745 for recordkeeping and reporting. Total industry and individual facility costs for the proposed fenceline fugitive monitoring for 11 coke facilities expected to be operating in 5 years from promulgation are shown in Table 10. Total industry costs for fenceline testing at 11 coke facilities, including recordkeeping and reporting, was estimated at $1,174,199.
Table 10. Fenceline Fugitive Monitoring, Recordkeeping, and Reporting Proposed Costs
                        for Coke Oven Batteries NESHAP
                                   Cost Item
                                 Annual Costs$

                                   Industry
                                   Facility
                               Monitoring Costs
Fenceline monitoring testing
                                   $770,000
                                    $70,000
                          Recordkeeping Requirements
Required fenceline monitoring records
                                   $306,898
                                    $27,900
Develop alternative monitoring plan for fenceline monitoring
                                    $63,804
                                    $5,800
                            Reporting Requirements
Write quarterly fenceline monitoring report
                                    $12,761
                                    $1,160
Enter information into fenceline monitoring reports
                                    $20,736
                                    $1,885
                    Total Recordkeeping and Reporting Costs
Total recordkeeping and reporting
                                   $404,199
                                    $36,745
                                 Overall Costs
Total fenceline monitoring, recordkeeping, and reporting
                                  $1,174,199
                                   $106,745

4.0	TOTAL COMPLIANCE COSTS
Table 11 summarizes the total facility compliance costs for MACT/BTF testing for PQBS NESHAP and fenceline monitoring for Coke Oven Batteries NESHAP, including recordkeeping and reporting, for each of the 11 operating coke facilities and the total for industry. Appendix A contains a spreadsheet with the calculations shown in this memorandum.
Table 11. Total Proposed Testing Compliance Costs per Facility for the Coke NESHAPs
                                    Facility
                                 Facility Type
                               Annualized Costs$

                                    Testing
                          Recordkeeping and Reporting
                                Facility Total

                                     MACT/
                                      BTF
                                   Fenceline
                                  Monitoring
                                   MACT/ BTF
                                   Fenceline
                                   Testing

ABC-Tarrant-AL
                                      ByP
                                                                       $113,671
                                                                        $70,000
                                                                        $20,046
                                                                        $36,745
                                                                       $240,463
CC-BurnsHarbor-IN
                                      ByP
                                                                        $89,622
                                                                        $70,000
                                                                        $20,046
                                                                        $36,745
                                                                       $216,413
CC-Monessen-PA
                                      ByP
                                                                        $65,573
                                                                        $70,000
                                                                        $20,046
                                                                        $36,745
                                                                       $192,364
CC-Warren-OH
                                      ByP
                                                                        $44,811
                                                                        $70,000
                                                                        $20,046
                                                                        $36,745
                                                                       $171,602
EES-RiverRouge-MI
                                      ByP
                                                                        $44,811
                                                                        $70,000
                                                                        $20,046
                                                                        $36,745
                                                                       $171,602
SC-EastChicago-IN
                                      HR
                                                                       $520,109
                                                                        $70,000
                                                                        $89,372
                                                                        $36,745
                                                                      $716,226
SC-FranklinFurnace-OH
                                      HR
                                                                       $390,965
                                                                        $70,000
                                                                        $89,372
                                                                        $36,745
                                                                      $587,082
SC-GraniteCity-IL
                                      HR
                                                                       $224,994
                                                                        $70,000
                                                                        $89,372
                                                                        $36,745
                                                                      $421,111
SC-Middletown-OH
                                      HR
                                                                       $195,483
                                                                        $70,000
                                                                        $89,372
                                                                        $36,745
                                                                      $391,600
SC-Vansant-VA
                                      NR
                                                                       $616,478
                                                                        $70,000
                                                                        $82,133
                                                                        $36,745
                                                                      $805,357
USS-Clairton-PA
                                      ByP
                                                                       $327,864
                                                                        $70,000
                                                                        $20,046
                                                                        $36,745
                                                                       $454,656
Industry Total

                                                                     $2,634,380
                                                                       $770,000
                                                                       $559,899
                                                                       $404,199
                                                                     $4,368,479

                                  APPENDIX A

                            Coke Costs: All Testing