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, NC

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

SUBJECT:	Coke Ovens Risk and Technology Review: Data Summary
_________________________________________________________________________________________
1.0	INTRODUCTION AND BACKGROUND
This memorandum describes the data acquired to support 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) and technology review of Coke Ovens (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) subpart CCCCC 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 Ovens, subpart L, NESHAP was promulgated on October 27, 1993 (58 FR 57898) and set standards for leaks from oven doors, lids, and offtake, and for charging. The RTR for Coke Ovens, subpart L, 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 Ovens, subpart L, NESHAP was due in 2013.
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 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 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.
The purpose of this memorandum is to describe the emissions and related data obtained for coke production facilities and their emission units, the review and quality control (QC) checks performed on the data; and development of the emission estimates used in the Coke Oven Emissions and Risk Modeling Databases. See the memorandum titled HAP Emissions from Coke Oven Facilities (EPA, 2023) for summaries of the emissions developed for the sources. See below for the table of contents and a list of abbreviations used.

A Table of Contents and List of Tables follows, along with list of Abbreviations.

                                  TABLE OF CONTENTS
1.0	INTRODUCTION	1
TABLES	6
ABBREVIATIONS	9
2.0	DATA USED TO DEVELOP THE COKE OVEN EMISSIONS DATABASE	11
2.1	Coke 114 Request Questionnaire Responses	16
2.2	Coke 114 Request Source Test Data	20
2.3	Process Data Submitted with Coke 114 Request Test Data	23
2.4	Unit Conversion and Emissions Factor Development in the Coke Oven Emissions Database	24
2.5	Speciation Factors	24
2.5.1	Speciated Chromium Emissions Estimates	24
2.5.2	Speciated Mercury Emissions Estimates	25
2.6	Multiple Stacks in the Coke Oven Emissions Database	25
2.7	Dioxins/Furans Unit Conversions Coke Oven Emissions Database	25
2.8	Data Quality Classifications and Treatment of Non-detected Values for Data Obtained via Test Methods with Multiple Fractions	26
2.9	Treatment of BDL, DLL, and ADL Values Used for MACT Floor and APCD Cost Effectiveness Calculations vs. Coke Oven Risk Modeling	27
3.0	COKE 114 REQUESTS DATA QUALITY CONTROL (QC) CHECKS	27
3.1	Internal EPA QC Checks	28
3.1.1 Laboratory Report QC for D/F	28
3.1.2 Inadvertent Omitted HAP	28
3.1.3 Facility and/ or Unit Operating Status Changes after 2016 Coke 114 Request Data Received	28
3.1.4 Suspect Data Evaluations	29
3.2	Coke Industry Review of Coke 114 Request Data	30
4.0	COKE OVEN EMISSONS DATABASE	30
4.1	Actual Annual Emissions for Coke PQBS Source Category	31
4.1.1 Emissions Developed from 2016 and 2022 Coke 114 Request Enclosure 2 Stack Test Data	31
4.1.2 Fugitive Pushing Emission Estimates	39
4.2	Actual Annual Emissions for Noncategory Emissions	41
4.2.1 Noncategory Emissions Developed from Coke 114 Request Enclosure 2 Stack Test Data	41
4.2.3 Coke Ovens Subpart L Emissions Estimates	45
4.2.4 2017 Noncategory Sources	58
4.2.5 Co-located II&S sources	58
for II&S RTR modeling file were used in the Coke Emissions Database. See Appendix B and C for the co-located II&S sources included in the Coke Oven Emissions Database and Coke Oven Risk Modeling Database.	61
4.3	Opacity Data	61
4.4	Allowable HAP Emissions for Coke PQBS and Noncategory Sources	62
4.4.1 ByP Pushing (CD) and HNR Pushing (CD)	62
4.4.2 EP-10 Quench Tower	65
4.4.3 EP-3 ByP Battery (Combustion) Stack	66
4.4.4 EP-8 HNR Charging (CD)	67
4.4.5 ByP Charging, Doors, Lids, and Offtakes	68
4.4.6 EP-4 ByP Boiler stacks	72
4.4.7 Co-located II&S sources	72
4.5	Acute Emissions for Coke PQBS and Noncategory Sources	72
4.6	Coke Industry Review of the Coke Oven Emissions Database	73
5.0	COKE OVEN RISK MODELING DATABASE	73
5.1	Facility Qualifiers	73
5.1.2 Facility Location Qualifiers	73
5.1.2 Facility NAICS Codes	73
5.1.3 Facility Category	73
5.2	Unit Qualifiers	75
5.2.1 Unit Identifications	75
5.2.2 Modeling Release Point Information by Unit	76
5.2.3 Unit Control Information	76
5.2.4 Unit Stack Parameters	76
5.2.5 Unit Stack Latitude and Longitude Coordinate QC	76
5.2.6 Unit Non-Stack Parameters	78
5.2.8 Unit Operating Hours	80
5.3	Emissions Data Qualifiers	80
5.4	Coke Industry Review of Coke Oven Risk Modeling Database	81
6.0	COKE BY-PRODUCT RECOVERY PLANT	84
6.1 Cooling Tower Inlet	84
6.2 Light Oil Condenser (if venting to atmosphere)	86
6.3 Sulfur Recovery/Desulfurization	87
6.4 Flares	87
7.0	REFERENCES	89
APPENDIX A:	1
Coke 114 Request QUESTIONNAIRE RESPONSES	1
APPENDIX B:	1
COKE OVEN EMISSIONS DATABASE	1
APPENDIX C:	1
COKE OVEN RISK MODELING DATABASE	1
APPENDIX D:	1
ERIE COKE DATA	1
APPENDIX E:	1
SOURCE CLASSIFICATION CODES	1

                                    TABLES

Table 1. Coke Facilities, Companies, Locations, Facility Type, and 114 Request Status	13
Table 2. Details of 2016 CAA Section 114 Request and Portions Requested	15
Table 3. Details of 2022 CAA Section 114 Request and Portions Requested	15
Table 4. Number of Coke PQBS Emission Units[1] by Facility in Coke Oven Emissions Database	17
Table 5. Number of Noncategory Emission Units[1] by Facility in Coke Oven Emissions Database	19
Table 6. Individual HAP within HAP Groups	20
Table 7. Summary of Required Emissions Tests for the Coke 114 Request	21
Table 8. Default Speciation Factors Used to Estimate Speciated Chromium Emissions	24
Table 9. Default Speciation Factors Used to Estimate Speciated Mercury Emissions	25
Table 10. Units with Multiple Stacks	25
Table 11. Dioxin/Furan Toxicity Equivalence Factors (TEF)	26
Table 12. Specific HAP and their Sources Omitted from Coke 114 Request Stack Tests	28
Table 13. Suspect 114 Requests Data Not Included in the Coke Oven Emissions Database	29
Table 14. Coke Facility Units Providing Test Data for the Coke PQBS RTR	31
Table 15. Calculation Methodology for Coke PQBS Units with Coke 114 Requests Stack Test Data	32
Table 16. Pushing (CD) Default Emission Factors[1] per Coke Type	32
Table 17. ByP Battery Stack Default Emission Factors[1] per Coke Type	33
Table 18. HRSG Main Stack and HRSG Bypass/Waste Heat Stack Default Emission Factors	34
Table 19. Quench Tower Default Emission Factors	36
Table 20. Similar Units Used with Surrogate Data	36
Table 21. Annual Coke Production Values, by Facility and Battery	37
Table 22. Annual Operating Hours for HRSG Main Stacks and HRSG Bypass/Waste Heat Stacks	38
Table 23. HNR Pushing Control Device Efficiency Correction Factors	39
Table 24. Pushing Device PM Capture Efficiencies, as Fraction of Total PM Emissions	40
Table 25. Coke Noncategory Units Tested as Part of the Coke 114 Request Enclosure 2	41
Table 26. Calculation Methodology for Noncategory Units with Coke 114 Request Stack Test Data	42
Table 27. ByP Boiler Default Emission Factors[1] per Coke Type	42
Table 28. HNR Charging Default Emission Factors	43
Table 29. Annual Wet Coal Charged Values	43
Table 30. Annual Boiler COG Usage (mmscf/yr)	44
Table 31. Coke PQBS Noncategory Unit Counts - Coke Ovens Subpart L	45
Table 32. Calculation Methodology for Emission Sources for Coke Ovens, Subpart L--	46
Table 33. 2016 Charging COE Emission Calculation Elements and Results	48
Table 34. 2022 Charging COE Emission Calculation Elements and Results	48
Table 35. 2016 Doors COE Emission Calculation Elements and Results	49
Table 36. 2022 Doors COE Emission Calculation Elements and Results	51
Table 37. 2016 Lids COE Emission Calculation Elements and Results	51
Table 38. 2022 Lids COE Emission Calculation Elements and Results	52
Table 39. 2016 Offtake COE Emission Calculation Elements and Results	53
Table 40. 2022 Offtake COE Emission Calculation Elements and Results	54
Table 41. Summary of By-Product Facility 2016 Coke 114 Request Method 303 Performance and COE Emissions Data	55
Table 42. Summary of By-Product Facility 2022 Coke 114 Request Method 303 Performance and COE Emissions Data	56
Table 43. Noncategory Actual Emissions: By-Product Chemical Plant Facility and Default Emissions	59
Table 44. Noncategory Actual Emissions: Flare Emissions by Facility and Default Emissions	60
Table 45. Opacity Data for Pushing and Battery Combustion Stacks	61
Table 46. Pushing Capture and Controls at Coke Facilities	62
Table 47. Allowables-to-Actuals Ratios for Pushing Units with PM Test Data	64
Table 48. Default Allowables-to-Actuals Ratios for Pushing	64
Table 49. Allowables-to-Actuals Ratios for Pushing Units (CD and Fugitive Emissions)	65
Table 50. Allowables-to-Actuals Ratios for Quench Towers with TDS Test Data	65
Table 51. Allowables-to-Actuals Ratios for All Quench Tower Units	66
Table 52. Allowables-to-Actuals Ratios for Battery Stack Units with Opacity Test Data	66
Table 53. Default Allowables-to-Actuals Ratios for Battery Stack Units	67
Table 54. Allowables-to-Actuals Ratios for Battery Stack Units	67
Table 55. Allowables-to-Actuals Ratios for HNR Charging (with PM Test Data	67
Table 56. Allowables-to-Actuals Ratios for HNR Charging Units	68
Table 57. ByP Charging Limits	68
Table 58. ByP Door Leak Limits	68
Table 59. ByP Lid Leak Limits	69
Table 60. Offtake Leak Limits	69
Table 61. Allowables-to-Actuals Ratios for ByP Charging	70
Table 62. Allowables-to-Actuals Ratios for ByP Door Leaks	70
Table 63. Allowables-to-Actuals Ratios for ByP Lid Leaks	71
Table 64. Allowables-to-Actuals Ratios for ByP Offtakes Leaks	71
Table 65. Allowables-to-Actuals Ratios for Boilers	72
Table 66. Coke Facility Location Information in the Coke Oven Modeling Database	74
Table 67. Coke Facility NACIS Codes in the Coke Oven Modeling Database	75
Table 68. Facility Categories in the Coke Oven Modeling Database	75
Table 69. Release Points by Type for Coke Processes in the Coke Oven Modeling Database	77
Table 70. Control Measure Codes and Descriptions	77
Table 71. Regulatory Codes by Process ID	78
Table 72. Stack Default Flags in the Coke Oven Modeling Database	78
Table 73. Fugitive Two-dimensional Line Source Modeling Parameters	79
Table 74. Data Start and End Dates in the Coke Oven Modeling Database	81
Table 75. Emission Calculation Method Codes in the Coke Ovens Risk Database	82
Table 76. Data Sources and Types in the Coke Oven Risk Modeling Database.	83
Table 77. Cooling Tower Inlet Submissions	84
Table 78. Cooling Tower Inlet Data Summary	84
Table 79. Cooling Tower Inlet Submissions	86
Table 80. Sulfur Recovery/Desulfurization Submissions	87
Table 81. Sulfur Recovery/Desulfurization Data Summary	87
Table 82. CBRP Flares and Emergency Battery Flare Submissions	87
Table 83. CBRP Flares and Emergency Battery Flare Method 21 and 22 Data Summary	88
Table 84. CBRP Flares and Emergency Battery Flare Composition Data Summary	89
Table B-1. Coke Oven Total Facility Emissions (TPY)	2
Table B-2. Coke Oven Total Facility Emissions (TPY)	3
Table B-3. Coke Oven Total Facility Emissions by Process (TPY)	4
Table B-3. Pushing (CD) Default Emission Factors per Coke Type	6
Table B-4. ByP Battery Stack Default Emission Factors per Coke Type	7
Table B-4. Coke Oven Total Facility Emissions by Process (TPY)	5
Table B-5. HRSG Main Stack and HRSG Bypass/Waste Heat Stack Default Emission Factors	9
Table B-6. Quench Tower Default Emission Factors	11
Table B-7. ByP Boiler Default Emission Factors per Coke Type	12
Table D-1. Erie Coke Facility Information and 114 Request Status	1
Table D-2. Erie Coke Units Tested for the Coke 114 Request	1
Table D-3. Pushing (CD) Default Emission Factors[1] per Coke Type	2
Table D-4. ByP Battery Stack Default Emission Factors[1] per Coke Type	3
Table D-5. ByP Boiler Default Emission Factors[1] per Coke Type	4
Table D-6. Erie Coke Annual Coke Production by Battery	5
Table D-7. Erie Coke PQBS Noncategory Unit Counts - Coke Ovens Subpart L	5
Table D-8. Erie Coke Charging COE Emission Calculation Elements and Results	5
Table D-9. Erie Coke Doors COE Emission Calculation Elements and Results	5
Table D-10. Erie Coke Lids COE Emission Calculation Elements and Results	5
Table D-11. Erie Coke Offtakes COE Emission Calculation Elements and Results	6
Table D-12. Development of Default Allowables-to-Actuals Ratios for Pushing Units	6
Table D-13. Development of Default Allowables-to-Actuals Ratios for Battery Stack Units	6
Table E-1. SCC for Coke PQBS Sources at Coke Oven Facilities	1
Table E-2. SCC for Noncategory Sources at Coke Facilities	2

                                 ABBREVIATIONS
acfm
actual cubic feet per minute
ACCCI
American Coke and Coal Chemicals Institute
ADL
above detection limit
BDL
BF
BOPF
below detection limit
blast furnace
basic oxygen process furnace
BSO
benzene-soluble organic
ByP
by-product coke production process
˚C
degrees Celsius
CAA
Clean Air Act
CAP
criterial air pollutant
CD
control device
CO
carbon monoxide
CO2
carbon dioxide
COE
coke oven emissions
COETF
Coke Oven Environmental Task Force
COG
coke oven gas
Cr
chromium
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
EDL
estimated detection limit
EIS
EPA's Emission Inventory System
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
II&S
Integrated Iron and Steel source category
LAER
lowest achievable emissions rate
lb/hr
pounds per hour
lb/mmscf
pounds per millions of standard cubic feet
lb/ton
pounds per ton
m
meter
MACT
maximum achievable control technology
MDL
method detection limit
mg/dscm
milligrams per dry standard cubic meter
mg/L
milligrams per liter
mmscf/hr
millions of standard cubic feet per hour
mmscf/yr
millions of standard cubic feet per year
NEI
EPA's National Emission Inventory
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
PLD
percent leaking doors
PLL
percent leaking lids
PLO
percent leaking offtakes
PM filterable
filterable particulate matter
PM2.5
PM that is 2.5 micrometers or less in diameter, both filterable and condensable
ppm
parts per million
PQBS
Pushing, Quenching, and Battery Stacks
QC
quality control
RDL
reportable detection limit
RTR
s/charge
residual risk and technology review
seconds of visible emissions per charge of coal into the oven
SCC
source classification codes
SDA
spray dryer absorber
SO2
sulfur dioxide
TEF
toxicity equivalence factors
TEQ
toxic equivalency
tph
tons per hour
tpy
tons per year
TDS
total dissolved solids
TSO
toluene soluble organics
ug/dscm
micrograms per dry standard cubic meter
um
micrometer
UOM
units of measurement
VOHAP
speciated volatile HAP
WHO
World Health Organization

2.0	DATA USED TO DEVELOP THE COKE OVEN EMISSIONS DATABASE
The primary sources of data for the Coke RTR were the responses to two CAA section 114 requests (Coke 114 request) sent to selected facilities in the coke industry in April 2016 and June 2022 that included a questionnaire and a source test request. The EPA sent out the Coke 114 requests under the authority of section 114 of the CAA (42 U.S.C. 7414) to acquire the necessary data for the RTR for Coke PQBS and the technology review for Coke Ovens, subpart L. The questionnaire portion of the Coke 114 requests included questions pertaining to inventory, process, and control device information for the emission units at the coke facilities. The source test request portion of the Coke 114 requests described the source tests, the test methods to be used, the pollutants to test, and other details concerning the requested testing. Copies of the Coke 114 requests and responses received by the EPA are included in dockets for both coke ovens rules, subparts CCCCC and L (Docket ID No.'s EPA-HQ-OAR-2002-0085 (subpart CCCCC); and Docket ID No.'s EPA-HQ-OAR-2003-0051 (subpart L)).
Table 1 lists the coke facilities and companies that were operating in 2016 and 2022, the type of coke they produced, whether the facilities submitted data and/or performed source testing in response to the Coke 114 requests, and the estimated typical annual coke production.
      The questionnaire portion of the 2016 Coke 114 request was sent to nine Coke companies that included 11 coke facilities operating in 2016: Mountain State Carbon, LLC (later purchased by AK Steel); AK Steel Corporation (that owned two coke facilities in 2016 and owned three coke facilities by 2020); ArcelorMittal Burns Harbor LLC; ArcelorMittal Monessen LLC; ArcelorMittal Warren LLC; Erie Coke Corporation; DTE Energy Services, Inc.; Sun Coke Energy, Inc. (which owns three of the coke facilities receiving the 2016 Coke 114 request) and U.S. Steel Clairton. There are four other operating coke facilities that did not receive the 2016 Coke 114 request that are currently operating (or on stand-by): ABC Coke; Bluestone Coke; Sun Coke Indiana Harbor Coke; and SunCoke Jewell Coke and Coal. The test request portion of the 2016 Coke 114 request was sent to seven of the 11 facilities. Table 2 shows the details of the 2016 CAA section 114 request in terms of companies that received the request and the parts of the request they were requested to do. 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 questionnaire portion of the 2022 Coke 114 request was sent to six companies that included eight facilities at coke companies operating in 2022: ABC Coke; Cleveland-Cliffs, Inc. (3 facilities); DTE Energy Services, Inc.; Sun Coke Energy, Inc. (2 facilities), U.S. Steel, and Cokenergy. The test request portion of the 2022 Coke 114 request was sent to eight facilities. Table 3 shows the companies and facilities that received the 2022 114 request and the parts of the request applicable to each facility.

The 2016 and 2022 Coke 114 requests included request for test data, along with physical and operating information about the emission units, were used to populate the Coke Oven Emissions Database. The emissions in the database, along with modeling release point information such as stack heights, air flowrates, and geographical locations, were used to develop the Coke Oven Risk Modeling Database for estimating the residual risk after implementation of the 2003 MACT standards for the Coke PQBS source category. The emissions data are also available to be used for developing any new MACT standards, if appropriate. The emissions data in the two databases -- emissions vs. modeling -- were almost identical except in the treatment of test measurements that were below the detection limit (BDL), which are described below in detail in Section 2.9. Development of emission data for all coke facilities and their processes are described in detail below.
Appendix A contains a summary of the facility responses to the Coke 114 request Questionnaire. Appendix B contains the Coke Oven Emissions Database and other relevant information, such as tables of individual HAP emissions reported as Total D/F, PAH, and VOHAP in Section 4. Appendix C contains the Coke Oven Risk Modeling Database.

Table 1. Coke Facilities, Companies, Locations, Facility Type, and 114 Request Status
                                 Facility Name
                                 Company Name
                            [Previous Company Name]
                                  Facility ID
                            [Previous Facility ID]
                                     City
                                     State
                         Type of Coke and Facility[1]
                     2016 Coke 114 Request Submissions[2]
                     2022 Coke 114 Request Submissions[2]
                        Typical Annual Coke Production
                                   (tons)[3]
ABC Coke
Drummond Company
ABC-Tarrant-AL
Tarrant
                                      AL
                                    Foundry
                                      No
                                    Yes (T)
                                    525,685
Bluestone Coke
Bluestone
BLU-Birmingham-AL
Birmingham
                                      AL
                                    Foundry
                                      No
                                      No
                                    348,713
Cleveland-Cliffs Follansbee Works
Cleveland-Cliffs [Mountain State Carbon, LLC]
CC-Follansbee-WV
[AKS-Follansbee-WV]
Follansbee
                                      WV
                                    BF, ByP
                                      Yes
                                      No
                                    561,862
Cleveland-Cliffs Middletown Works
Cleveland-Cliffs
[AK Steel Corporation]
CC-Middletown-OH
[AKS-Middletown-OH]
Middletown
                                      OH
                                    BF, ByP
                                    Yes (T)
                                      No
                                    401,752
Cleveland-Cliffs Burns Harbor
Cleveland-Cliffs [ArcelorMittal Burns Harbor LLC]
CC-BurnsHarbor-IN
[AM-BurnsHarbor-IN]
Burns Harbor
                                      IN
                                    BF, ByP
                                    Yes (T)
                                    Yes (T)
                                   1,888,153
Cleveland-Cliffs Monessen
Cleveland-Cliffs [ArcelorMittal Monessen LLC]
CC-Monessen-PA
[AM-Monessen-PA]
Monessen
                                      PA
                                    BF, ByP
                                    Yes (T)
                                    Yes (T)
                                    336,022
Cleveland-Cliffs  Warren
Cleveland-Cliffs [ArcelorMittal Warren LLC]
CC-Warren-OH
[AM-Warren-OH]
Warren
                                      OH
                                    BF, ByP
                                      Yes
                                    Yes (T)
                                    359,281
EES Coke Battery
DTE Energy Services, Inc.
EES-RiverRouge-MI
River Rouge
                                      MI
                                    BF, ByP
                                      Yes
                                    Yes (T)
                                    981,765
Indiana Harbor Coke
SunCoke Energy, Inc.
SC-EastChicago-IN
East Chicago
                                      IN
                                    BF, HNR
                                      No
                                      No
                                   1,300,000
Haverhill Coke
SunCoke Energy, Inc.
SC-FranklinFurnace-OH
Franklin Furnace
                                      OH
                                    BF, HNR
                                      Yes
                                    Yes (T)
                                    683,313
Gateway Energy and Coke
SunCoke Energy, Inc.
SC-GraniteCity-IL
Granite City
                                      IL
                                    BF, HNR
                                    Yes (T)
                                      No
                                    428,412
Middletown Coke Company
SunCoke Energy, Inc.
SC-Middletown-OH
Middletown
                                      OH
                                    BF, HNR
                                    Yes (T)
                                      No
                                    357,010
Jewell Coke and Coal
SunCoke Energy, Inc.
SC-Vansant-VA
Vansant
                                      VA
                                    BF, HNR
                                      No
                                    Yes (T)
                                    710,000
US Steel-Clairton
U.S. Steel
USS-Clairton-PA
Clairton
                                      PA
                                    BF, ByP
                                    Yes (T)
                                    Yes (T)
                                   3,776,244
Cokenergy[4]
Coke Energy
CC-EastChicago-IN
East Chicago
                                      IN
                                    BF, HNR
                                      No
                                    Yes (T)
                                   1,300,000
1 BF = blast furnace. ByP = by-product. HNR = heat and/or nonrecovery.
2 T = Facility also performed testing as part of Coke 114 request. Other facilities that responded to Coke 114 request but did not test submitted Enclosure 1 questionnaire.
3 Typical production as estimated by one or more of the following: (1) facilities in their Coke 114 request Enclosure 1 responses: (2) industry during the Coke 114 request review process; (3) 1998 coke production values from the NESHAP for Coke Ovens: Pushing, Quenching, and Battery Stacks  -  Background Information for Proposed Standards (EPA, 2001a); or (4) 55 percent capacity utilization of coke production design capacity from Coke 114 request Enclosure 1 responses for facilities that did not provide actual coke production values. See Section <IP_ADDRESS> below for details.
[4] Cokenergy operates a combined heat and power system that uses the waste heat in the flue gas from Indiana Harbor Coke Company's (IHCC) metallurgical coke facility to produce steam and electricity for the Cleveland-Cliffs Indiana Harbor integrated steel mill. Cokenergy owns and operates the 16 heat recovery steam generators (HRSG) to recover heat from the flue gas to allow for environmental treatment by the flue gas desulfurization system.

    Table 2. Details of 2016 CAA Section 114 Request and Portions Requested
                               Facility/Location
                            2016 Enclosure 1 Survey
                                   12 Months
                                   Leak Data
                      2016 Enclosure 2 Testing Sources:
Pushing, Battery Stack, Quench Tower, Boiler, HRSG Main stack, HNR Bypass Stack, HNR charging
CC-BurnsHarbor-IN
                                       X
                                       X
Pushing, Battery Stack
CC-Follansbee-WV
                                       X
                                       X
None
CC-Middletown-OH
                                       X
                                       X
Pushing, Battery Stack
CC-Monessen-PA
                                       X
                                       X
Pushing, Battery Stack, Quench Tower, Boiler
CC-Warren-OH
                                       X
                                       X
None
EES-RiverRouge-MI
                                       X
                                       X
None
SC-FranklinFurnace-OH
                                       X
                                      --
None
SC-GraniteCity-IL
                                       X
                                      --
Pushing, Bypass/Waste Stack
SC-Middletown-OH
                                       X
                                      --
Pushing, HRSG Main Stack, Charging
USS-Clairton-PA
                                       X
                                       X
Battery Stack, Quench Tower

    Table 3. Details of 2022 CAA Section 114 Request and Portions Requested
                               Facility/Location
                                     2022
                         Enclosure 1 Survey Sections:
                                   12 Months
                                   Leak Data
2022 Enclosure 2 Testing Sources: CBRP Stacks (2), Flares, Fugitives, ByP Oven Doors
ABC-Tarrant-AL
                                 A, B, C, D, E
                                       X
CBRP, Flares, Fugitives
CC-BurnsHarbor-IN
                                 A, B, C, D, E
                                       X
CBRP, Doors, Flares, Fugitives
CC-Monessen-PA
                                 A, B, C, D, E
                                       X
Flares
CC-Warren-OH
                                 A, B, C, D, E
                                       X
Flares
EES-RiverRouge-MI
                                 A, B, C, D, E
                                       X
Flares, Fugitives
USS-Clairton-PA
                                 A, B, C, D, E
                                       X
CBRP, Doors, Flares, Fugitives
SC-FranklinFurnace-OH
                                    A and E
                                      --
Fugitives; HNR Bypass/Waste Heat Stack
SC-Vansant-VA
                                    A and E
                                      --
--
SC-EastChicago-IN (Cokenergy)
                                    A and E
                                      --
HRSG Main Stack

Coke 114 Request Questionnaire Responses
The Enclosure 1 questionnaire portion of the 2016 Coke 114 request was composed of the following parts:

 	Owner Information
II.		General Facility Information
III.		Regulatory Information
IV.		Process Flow Diagrams and Plot Plans
V.		Emission Points
VI.		Process and Emission Unit Operations
VII.		Air Pollution Control and Monitoring Equipment
VIII.		Economics/Costs
IX.		Startup and Shutdown
X.		Management Practices

The Enclosure 1 questionnaire portion of the 2022 Coke 114 request was composed of the following parts:

Part A. Background Facility Information from 2016 114 Request  -  Verify and Update, or Provide New
Part B. Coke By-Product Recovery Plants
Part C. Coke Oven Doors, Lids, Offtakes, and Charging at By-product Coke Oven Facilities
Part D. Coke By-product Battery Stack Opacity Data
Part E. Miscellaneous: Emergency Battery Flares; Community Issues; Paperwork Reduction Act Estimates

Specific information about the HAP-emitting process units was provided by coke companies in the 2016 Coke 114 request Enclosure 1 questionnaire Parts IV-VI and the 2022 Coke 114 request Enclosure 1 questionnaire Part A. The information about HAP-emitting units formed the basis of the Coke Oven Emissions Database. Coke facilities also provided the operating hours of each unit, stack diameters, stack heights, exhaust velocity, exhaust temperature, stack latitude and longitude, and other information related to their operations or HAP emissions at the facility that were used in the Coke Oven Risk Modeling Database (see Section 5 and Appendix C).
The primary HAP-emitting PQBS operating units at coke facilities are: pushing (ByP and HNR), battery stacks (ByP only), heat recovery steam generator (HRSG) main stacks (HNR only), HRSG bypass/waste heat stacks (HNR only), fugitive pushing emissions from the ovens (ByP and HNR), and quench towers (ByP and HNR). The other HAP emissions operating units at coke facilities are: Coke Ovens, subpart L, sources: charging (both ByP and HNR); ByP lids, doors (on both coal (push) and coke sides of the oven), and offtakes; ByP chemical recovery plants; boilers; flares; II&S (40 CFR part 63, subpart FFFFF) co-located sources; and other miscellaneous units not in the coke source categories. Table 4 summarizes the number of Coke PQBS units of each type at the coke facilities that are represented in the Coke Oven Emissions Database that were identified through the Coke 114 requests and discussions with industry representatives. Note that the number of units in Table 4 and the number of modeling release points in the Coke Oven Risk Modeling Database do not have a one-to-one correspondence because of some units that exhaust to multiple release points and multiple units that combine into one release point or are modeled as if combined through one release point. Table 5 summarizes the number of primary noncategory units of each type at the coke facilities that are represented in the Coke Oven Emissions Database.

Table 4. Number of Coke PQBS Emission Units[1] by Facility in Coke Oven Emissions Database
                                   Facility
                               No. of Batteries
                           No. of Ovens, by Battery#
                             ByP & HNR Pushing
                                Control Systems
                      Fugitive Pushing (batteries/ ovens)
                                 Quench Tower
                               ByP Battery Stack
                                HRSG Main Stack
                                  [No. HRSGs]
                         HRSG Bypass/ Waste Heat Stack
ABC-Tarrant-AL
                                       3
                                    #1: 78
                                    #5: 25
                                    #6: 29
                                     3[2]
                                     3/132
                                       2
                                       2
                                      --
                                      --
BLU-Birmingham-AL
                                       3
                                    #3: 30
                                    #4: 30
                                    #6: 60
                                     1[8]
                                     3/120
                                       2
                                       2
                                      --
                                      --
CC-Follansbee-WV
                                       4
                                    #1: 47
                                    #2: 47
                                    #3: 51
                                    #8: 79
                                     2[3]
                                     4/224
                                       3
                                       4
                                      --
                                      --
CC-Middletown-OH
                                       1
                                    #1: 76
                                     1[4]
                                     1/76
                                       1
                                       1
                                      --
                                      --
CC-BurnsHarbor-IN
                                       2
                                    #1: 82
                                    #2: 82
                                     2[5]
                                     2/164
                                       2
                                       2
                                      --
                                      --
CC-Monessen-PA
                                       2
                                    #1B: 37
                                    #2: 19
                                     1[6]
                                     2/56
                                       1
                                       2
                                      --
                                      --
CC-Warren-OH
                                       1
                                    #1: 85
                                     1[7]
                                     1/85
                                       1
                                       1
                                      --
                                      --
EES-RiverRouge-MI
                                       1
                                     #1:85
                                     1[9]
                                     1/85
                                       1
                                       1
                                      --
                                      --
SC-EastChicago-IN / CE-EastChicago-IN
                                       4
                                    #A: 67
                                    #B: 67
                                    #C: 67
                                    #D: 67
                                     1[10]
                                     4/268
                                       2
                                      --
                                    1 [16]
                                      16
SC-FranklinFurnace-OH
                                       4
                                    #A: 60
                                    #B: 40
                                    #C: 60
                                    #D: 40
                                     2[11]
                                     4/200
                                       2
                                      --
                                     2 [6]
                                      10
SC-GraniteCity-IL
                                       3
                                    #A: 40
                                    #B: 40
                                    #C: 40
                                     1[12]
                                     3/120
                                       1
                                      --
                                     1 [7]
                                       6
SC-Middletown-OH
                                       3
                                    #A: 40
                                    #B: 20
                                    #C: 40
                                     1[12]
                                     3/100
                                       1
                                      --
                                     1 [5]
                                       5
SC-Vansant-VA
                                       6
                                    #2D: 18
                                    #2E: 27
                                    #3B: 26
                                    #3C: 36
                                    #3F: 17
                                    #3G: 18
                                     6[13]
                                     6/142
                                       2
                                      --
                                      --
                                      16
USS-Clairton-PA
                                      10
                                    #1: 64
                                    #2: 64
                                    #3: 64
                                    #13: 61
                                    #14: 61
                                    #15: 61
                                    #19: 87
                                    #20: 87
                                    #B: 75
                                    #C: 84
                                     5[14]
                                    10/708
                                       7
                                      10
                                      --

Total Units
                                      47
                                     2,538
                                      17
                                     2,538
                                      28
                                      25
                                    5 [34]
                                      53
Total Modeling
Release Points

                                      51
                                      47
                                      28
                                      25
                                       5
                                      53
1 In the Coke Oven Risk Modeling Database, the number of units and number of modeling release points do not have a one-to-one correspondence because of units exhausting to multiple modeling release points and multiple units combined to singular modeling release point.
[2] Two control units serving one battery and one control unit serving two batteries.
3 One control unit has 14 stacks serving three batteries and one control unit serving one battery.
4 One control unit has five stacks serving one battery.
[5] Two control units serving one battery each.
6 One control unit serving two batteries.
[7] One mobile pushing control device serving one battery.
[8] One control unit serving three batteries.
[9] One control unit serving one battery.
[10] One control unit serving four batteries.
[11] Two mobile pushing control devices serving two batteries each.
[12] One mobile pushing control device serving three batteries.
[13] Cokeside shed settling chamber for each battery.
[14] Two control units serving three batteries each, one control unit serving two batteries, and two control units serving one battery each.

Table 5. Number of Noncategory Emission Units[1] by Facility in Coke Oven Emissions Database
                                  Facility ID
                   ByP & HNR Charging (batteries/ ovens)
                      ByP Doors (batteries/ ovens/doors)
                        ByP Lids (batteries/ ovens/lids)
                    ByP Offtakes (batteries/ ovens/offtakes)
                                    Boilers
                                    Flares
                                      ByP
                            Chemical Recovery Plant
                   Other Miscellaneous Units/Release Points
                        II&S Plants/ Release Points
ABC-Tarrant-AL
                                     3/132
                                   3/132/264
                                   3/132/582
                                   3/132/132
                                     3[2]
                                       1
                                       1
                                      --
                                      --
BLU-Birmingham-AL
                                     3/120
                                     3/120
                                     3/120
                                     3/120
                                       3
                                       1
                                       1
                                      --
                                      --
CC-Follansbee-WV
                                     4/224
                                   4/224/448
                                   4/224/896
                                   4/224/303
                                     5[3]
                                       1
                                       1
                                      1/1
                                      --
CC-Middletown-OH
                                     1/76
                                   1/76/152
                                   1/76/228
                                   1/76/152
                                       4
                                       1
                                       1
                                     20/31
                                      1/8
CC-BurnsHarbor-IN
                                     2/164
                                   2/164/328
                                   2/164/656
                                   2/164/164
                                       6
                                       1
                                       1
                                     12/15
                                     1/17
CC-Monessen-PA
                                     2/56
                                   2/56/112
                                   2/56/224
                                   2/56/112
                                     2[2]
                                       1
                                       1
                                      --
                                      --
CC-Warren-OH
                                     1/85
                                   1/85/170
                                   1/85/255
                                   1/85/170
                                       3
                                       1
                                       1
                                      2/2
                                      --
EES-RiverRouge-MI
                                     1/85
                                   1/85/170
                                   1/85/340
                                   1/85/170

                                       1
                                       1
                                      --
                                      --
SC-EastChicago-IN /
CE-EastChicago-IN
                                     4/268
                                      --
                                      --
                                      --
                                      --
                                      --
                                      --
                                      1/1
                                    1/0[5]
SC-FranklinFurnace-OH
                                     4/200
                                      --
                                      --
                                      --
                                      --
                                      --
                                      --
                                      2/2
                                      --
SC-GraniteCity-IL
                                     4/120
                                      --
                                      --
                                      --
                                      --
                                      --
                                      --
                                      1/1
                                      --
SC-Middletown-OH
                                     3/100
                                      --
                                      --
                                      --
                                      --
                                      --
                                      --
                                      --
                                      --
SC-Vansant-VA
                                     6/143
                                      --
                                      --
                                      --
                                      --
                                      --
                                      --
                                      2/2
                                      --
USS-Clairton-PA
                                    10/708
                                 10/708/1,416
                                 10/708/2,916
                                 10/708/1,332
                                     6[4]
                                      --
                                       1
                                      1/1
                                      --
Total Emission Units
                                   47/2,480
                                27/1,650/3,300
                                27/1,650/6,697
                                27/1,650/2,655

Total Modeling Release Points
                                      47
                                      54
                                      27
                                      27
                                      25
                                       8
                                       9
                                      56
                                      25
[1] In the Coke Oven Risk Modeling Database, the number of emission units and number of modeling release points do not have a one-to-one correspondence in some cases because some units exhaust to multiple modeling release points and multiple emission units are combined to singular modeling release point.
[2] 1 modeling release point.
[3] 4 units go to 1 modeling release point; 1 unit goes to another modeling release point.
[4] 5 modeling release points.
[5] See Section 4.2.5 for an explanation of the II&S facility at SC-East Chicago-IN

Coke 114 Request Source Test Data
The Coke 114 request Enclosure 2 source test data requested included the following pollutants or parameters: particulate matter (PM) including filterable PM (PM filterable) and PM that is 2.5 micrometers (um) or less in diameter (PM2.5) both filterable and condensable; hazardous air pollutant (HAP) metal compounds; hydrogen chloride (HCl), hydrogen fluoride (HF), and hydrogen cyanide (HCN); hydrogen sulfide (H2S) and sulfur dioxide (SO2); carbon monoxide (CO);carbon dioxide (CO2), toluene soluble organics (TSO), speciated volatile HAP (VOHAP); semi-volatile HAP such as polycyclic aromatic hydrocarbons (PAHs) and dioxin/furans; air flow rate/velocity and the related parameters of O2/CO2 and moisture; opacity and/or visible emissions; and the water soluble versions of many of the above air pollutants as well as pH and total dissolved solids (TDS) in quench tower discharge water. Table 6, below, lists the individual pollutants in the HAP groups.

      The following is a list of the emission process (EP) units required to be tested at both by-product (ByP) and HNR coke oven batteries, including the control devices (CD) on these units:

      2016 Coke 114 Request
      EP-1 ByP Pushing (CD and oven)
      EP-2 ByP Charging (oven port only)
      EP-3 ByP Battery (Combustion)Stack
      EP-4 ByP Boiler stacks
      EP-5 Flares (inlet)
      EP-6 HRSG Main Stacks
      EP-7 HRSG Bypass/Waste Heat Stacks
      EP-8 HNR Charging (CD and oven)
      EP-9 HNR Pushing (CD and oven)
      EP-10 Quench Towers
EP-11 Lids, Doors, and Offtakes

2022 Coke 114 Request
Door Leaks, Bench and Yard
Cooling Tower Inlet
Light Oil Condenser (if venting to atmosphere)
Sulfur Recovery/Desulfurization
      CBRP Flares
Emergency Battery Flare
HNR Main Stack (after HRSG+CD)
      HNR Bypass Stacks
HNR Waste Heat Stacks
      Fugitive emissions at the fenceline, and at interior facility locations near: (1) coke oven batteries and (2) CBRP

                   Table 6. Individual HAP within HAP Groups
                                   HAP Group
                                Individual HAP
HAP Metals
antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium.
Acid Gases
hydrogen chloride, hydrogen fluoride
Speciated Volatile Organic HAP
formaldehyde, acrylonitrile, benzene, bromoform, bromomethane, carbon disulfide, carbon tetrachloride,
chlorobenzene, chloroethane, chloroform, chloromethane,
1,2-dichloroethane, 1,1-dichloroethene, 1,2-dichloropropane, ethylbenzene, iodomethane, methylene chloride, styrene, 1,1,2,2-tetrachloroethane, tetrachloroethene, toluene, 1,1,1-trichloroethane, 1,1,2-trichloroethane, trichloroethene, vinyl chloride, and xylenes
PAH
acenaphthene, acenaphthylene, anthracene, benz[a]anthracene, benzo[a]pyrene, benzo[b]fluoranthene,
benzo[g,h,i]perylene, benzo[k]fluoranthene, chrysene,
dibenz[a,h]anthracene, fluoranthene, fluorene, indeno (1,2,3-cd) pyrene, naphthalene, phenanthrene, perylene,
pyrene
Dioxin/furans
2,3,7,8-tetrachlorodibenzo-p-dioxin,
1,2,3,7,8-pentachlorodibenzo-p-dioxin,
1,2,3,4,7,8-hexachlorodibenzo-p-dioxin,
1,2,3,6,7,8-hexachlorodibenzo-p-dioxin,
1,2,3,7,8,9-hexachlorodibenzo-p-dioxin,
1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin, octachlorodibenzo-p-dioxin,
2,3,7,8-tetrachlorodibenzofuran,
1,2,3,7,8-pentachlorodibenzofuran,
2,3,4,7,8-pentachlorodibenzofuran,
1,2,3,4,7,8-hexachlorodibenzofuran,
1,2,3,6,7,8-hexachlorodibenzofuran,
2,3,4,6,7,8-hexachlorodibenzofuran,
1,2,3,7,8,9-hexachlorodibenzofuran,
1,2,3,4,6,7,8-heptachlorodibenzofuran,
1,2,3,4,7,8,9-heptachlorodibenzofuran, octachlorodibenzofuran

The source test data was compiled into the Coke Oven Emissions Database. Table 7 summarizes the emission process units and corresponding pollutants tested for the Coke 114 request.

     Table 7. Summary of Required Emissions Tests for the Coke 114 Request
                          Emission Process (EP) Unit
                              Pollutant(s) Tested
                             2016 Coke 114 Request
       Both By-Product (ByP) Process and Heat/Non-Recovery (HNR) Process
EP-1: ByP Pushing Operations (production side): Control Device (CD) stack and Oven Doors (fugitive), and

EP-9: HNR Pushing Operations (production side): CD stack and Oven Door (fugitive)
Oven only: Opacity
CD only: Toluene-soluble organics (TSO), carbon monoxide (CO), carbon dioxide (CO2), HAP metals (including vapor phase Hg) and PM filterable, hydrogen chloride (HCl), hydrogen cyanide (HCN), hydrogen fluoride (HF), hydrogen sulfide (H2S), PM2.5 filterable&condensible, semi-volatile HAP (Semi-vol) which includes PAHs and dioxin/furans, sulfur dioxide (SO2), speciated volatile organic HAP (VOHAP)
EP-10: Quench Towers
Air only: TSO, CO2, PM filterable, PM2.5 filterable& condensible
Water only: pH, total dissolved solids (TDS)
Air&Water: HAP metals (including vapor phase Hg in air samples), HCl, HCN, HF, H2S (Water: total sulfide), Semi-vol, SO2 (Water: total sulfate), VOHAP
                            By-Product Process Only
EP-2: ByP Charging Operations (port)
Visible emissions (leaks)
EP-3: ByP Battery stack
TSO, CO, CO2, HAP metals (including vapor phase Hg) and PM filterable, HCl, HCN, HF, H2S, opacity, PM2.5 filterable&condensible, Semi-vol, SO2, VOHAP
EP-4: ByP Boiler Stacks
TSO, CO, CO2, HAP metals (including vapor phase Hg) and PM filterable, HCl, HCN, HF, opacity, PM2.5 filterable&condensible, Semi-vol
EP-11: Lids, Doors, and Offtakes
Visible emissions (leaks)
                   Heat and Non-Recovery Process (HNR) Only
EP-6: Main Stack After Heat Recovery Steam Generators (HRSG)
TSO, CO, CO2, HAP metals (including vapor phase Hg) and PM filterable, HCl, HCN, HF, opacity, PM2.5 filterable&condensible, Semi-vol
EP-7: Heat Recovery Steam Generator (HRSG) Bypass Stacks
TSO, CO, CO2, HAP metals (including vapor phase Hg) and PM filterable, HCl, HCN, HF, H2S, opacity, PM2.5 filterable&condensible, Semi-vol, SO2, VOHAP
EP-8: HNR Charging Operations (CD stack)
CD only: TSO, CO2, HAP metals (including vapor phase Hg) and PM filterable
EP-8: HNR Charging Operations (oven)
Oven only: opacity
Door only: Visible emissions (leaks)
                             2022 Coke 114 Request
                             Coke ByP Process Only
Door Leaks, Bench and Yard
Visible emissions (leaks)
                      Coke ByP Recovery Plant (CBRP) Only
Cooling Tower Inlet
BTEX, TO-15A analytes, H2S, COS, CS2
Light Oil Condenser (if venting to atmosphere)
BTEX, H2S, COS, CS2
Sulfur Recovery/Desulfurization
SO2, H2S, COS, CS2
CBRP Flares
Emergency Battery Flare
Visible emissions, gas composition (proximate/ultimate analysis), flow rate, and heat content
                   Heat and Non-Recovery Process (HNR) Only
HNR Main Stack (after HRSG+CD)
Filterable PM & HAP metals, CO2, CO, NOx, formaldehyde, HCl, HF, HCN, PAH, D/F, opacity (stack), SO2, BTEX
HNR Bypass Stacks
HNR Waste Heat Stacks
Filterable PM & HAP metals, CO2, CO, NOx, formaldehyde, HCl, HF, HCN, PAHs, D/F, opacity (stack), SO2, BTEX
  Fugitive Emission Testing at Facility Fenceline//Interior Facility Grounds
Fugitive emissions at the fenceline, and at interior facility locations near: (1) coke oven batteries and (2) CBRP
1,3 Butadiene, BTEX, PAHs, volatile organic compounds (VOC) (Table 1, EPA Method TO-13A for PAHs and Table 1-1, EPA Method TO-15A for VOC

Process Data Submitted with Coke 114 Request Test Data
From each Coke 114 request test report submitted, the following testing information data and process parameters were compiled for each test run into the Coke Oven Emissions Database:

       Testing Information
Test date
Exhaust gas flow rate, in actual cubic feet per minute (acfm) and dry standard cfm (dscfm)
Sample volume, in dry standard cubic feet (dscf) and dry standard cubic meters (dscm)
Stack moisture, in percent (%)
Stack gas temperature, in degrees Fahrenheit (˚F)
Sampling velocity, in feet per second (fps)
Isokinetic sampling percent (%)
Oxygen content of stack gas, in percent (%)
Carbon dioxide content of stack gas, in percent (%)
Reported pollutant concentration, in parts per million (ppm), milligrams per dry standard cubic meter (mg/dscm), or grains per dry standard cubic foot (gr/dscf), etc.
Reported pollutant emission rate, lb/hr
Data quality classifications, e.g., above detection limit (ADL), BDL, or detection level limited (DLL)
Latitude and longitude of stack tested (decimal degrees, six decimal places)

       Process Parameters
       Emission unit(s) ID  -  Use same ID as in processes and emissions flow (P&EF) table in the Coke 114 request Enclosure 1
Type of process (pushing, charging, quenching)
Type of air control device (e.g., baghouse, scrubber, ESP, other)
Latitude of stack (decimal degrees, 5 decimal places)
Longitude of stack (decimal degrees, 5 decimal places)
Date of test
Battery ID number/name
ID numbers of ovens pushed/charged
Location of oven(s) tested within battery
Number of ovens pushed during testing
Type of coal charged during testing
Average coking time per oven(s) tested (hours)
Average temperature of coking per oven(s) tested (degrees Fahrenheit)
Dry coal processed per oven(s) during testing (tons)
Coke produced during test period (tons)
Pushing period during testing (minutes)
Charging period during testing (minutes)
Quantity of coke oven gas burned in power plant (millions of standard cubic feet per hour (mmscf/hr) during tests)
Quantity of coke oven gas burned in coke battery (mmscf/hr during tests)
Quantity of natural gas burned in coke battery (mmscf/hr during tests)
Quantity of coke oven gas generated (including gas recovered and used in ovens) (mmscf/hr during tests)
Unit Conversion and Emissions Factor Development in the Coke Oven Emissions Database
All reported emissions data compiled into the Coke Oven Emissions Database were converted to micrograms per dry standard cubic meter (ug/dscm) and lb/hr. Data for multiple runs in each test were averaged together for an overall average for the source test. Where possible, emission factors were calculated in pounds per ton (lb/ton) or lb/mmscf using the emission rate (lb/hr) and either coke produced during test (tph), wet coal charged during test (tph), or COG burned during test (mmscf/hr).
Speciation Factors
Speciated Chromium Emissions Estimates
For facilities that measured total chromium for the Coke 114 requests with EPA Method 29, the total chromium emissions were speciated into two chromium species for risk modeling purposes in the Coke Oven Emissions Database, as follows: Chromium III and Chromium VI (Pope, A., 2016). Default chromium speciation factors are typically used in risk modeling for industrial sources unless information is provided otherwise. Table 8 shows the chromium speciation factors used for the Coke Oven Emissions Database and Coke Oven Risk Modeling Database. Speciated emissions were calculated as follows:
Total Chromium Method 29  *  Speciation Factor Chromium Specie  =  Speciated Chromium Emissions Chromium Specie

Table 8. Default Speciation Factors Used to Estimate Speciated Chromium Emissions
             in the Coke Oven Emissions Database (Pope, A., 2016)
                               Chromium Species
Speciation Factor
Chromium III
                                     0.97
Chromium VI
                                     0.03

Speciated Mercury Emissions Estimates

For facilities that measured total mercury for the Coke 114 requests with EPA Method 29, the total mercury emissions were speciated into three mercury species for risk modeling purposes in the Coke Oven Emissions Database, as follows: elemental gaseous, gaseous divalent, and particulate divalent mercury (EPA, 2020). Default mercury speciation factors are typically used in risk modeling for industrial sources unless information is provided otherwise. Table 9 summarizes the mercury speciation factors used for the Coke Oven Emissions Database and Coke Oven Risk Modeling Database. Speciated mercury emissions were calculated as follows:

 Total Mercury Method 29  *  Speciation Factor Mercury Specie  =  Speciated Mercury Emissions Mercury Specie

Table 9. Default Speciation Factors Used to Estimate Speciated Mercury Emissions
                in the Coke Oven Emissions Database (EPA, 2020)
                                Mercury Species
Speciation Factor
Elemental gaseous Hg
                                     0.80
Gaseous divalent Hg
                                     0.15
Particulate divalent Hg
                                     0.05

Multiple Stacks in the Coke Oven Emissions Database
For some coke process units, there are multiple stacks. For the emissions and modeling databases, the emissions were split between each stack. Table 10 lists the units that had multiple stacks.

                     Table 10. Units with Multiple Stacks
                                  Facility ID
                                    Unit ID
                               Number of Stacks
                             EP-1 ByP Pushing (CD)
CC-Follansbee-WV
Batteries #1, #2, and #3 Pushing Baghouse
                                      14
CC-Middletown-OH
Wilputte Coke Oven Battery - PEC Baghouse
                                       5

Dioxins/Furans Unit Conversions Coke Oven Emissions Database
Emissions of 17 individual dioxin/furan congeners were required to be tested in the Coke 114 requests for purposes of estimating health risk. These 17 specific dioxin/furan congener mass values reported in the laboratory analysis of the test reports were compiled and converted to nanograms per dry standard cubic meter (ng/dscm) and lb/hr emissions values. The 17 dioxin/furan congener values, expressed as mass rates, were entered in the Coke Oven Emissions Database for each facility and unit. The mass rates are used in the risk assessment.
The 17 specific dioxin/furan congener mass values also 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 in the Coke Oven Emissions Database. Total TEQ toxicity values are used to establish MACT, if needed, but not for risk modeling. Table 11 lists the 17 specific dioxin/furan congeners of interest and the corresponding WHO 2005 TEF.

Table 11. Dioxin/Furan Toxicity Equivalence Factors (TEF)
Dioxin/furan Congener
Abbreviation
WHO 2005 TEF
2,3,7,8-tetrachlorodibenzo-p-dioxin
2,3,7,8-TCDD
1
1,2,3,7,8-pentachlorodibenzo-p-dioxin
1,2,3,7,8-PeCDD
1
1,2,3,4,7,8-hexachlorodibenzo-p-dioxin
1,2,3,4,7,8-HxCDD
0.1
1,2,3,7,8,9-hexachlorodibenzo-p-dioxin
1,2,3,6,7,8-HxCDD
0.1
1,2,3,6,7,8-hexachlorodibenzo-p-dioxin
1,2,3,7,8,9-HxCDD
0.1
1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin
1,2,3,4,6,7,8-HpCDD
0.01
Octachlorodibenzo-p-dioxin
OCDD
0.0003
2,3,7,8-tetrachlorodibenzofuran
2,3,7,8-TCDF
0.1
1,2,3,7,8-pentachlorodibenzofuran
1,2,3,7,8-PeCDF
0.03
2,3,4,7,8-pentachlorodibenzofuran
2,3,4,7,8-PeCDF
0.3
1,2,3,4,7,8-hexachlorodibenzofuran
1,2,3,4,7,8-HxCDF
0.1
1,2,3,6,7,8-hexachlorodibenzofuran
1,2,3,6,7,8-HxCDF
0.1
2,3,4,6,7,8-hexachlorodibenzofuran
2,3,4,6,7,8-HxCDF
0.1
1,2,3,7,8,9-hexachlorodibenzofuran
1,2,3,7,8,9-HxCDF
0.1
1,2,3,4,6,7,8-heptachlorodibenzofuran
1,2,3,4,6,7,8-HpCDF
0.01
1,2,3,4,7,8,9-heptachlorodibenzofuran
1,2,3,4,7,8,9-HpCDF
0.01
Octachlorodibenzofuran
OCDF
0.0003
      Note: TEF obtained from an EPA report on toxicity factors (EPA, 2010).

Data Quality Classifications and Treatment of Non-detected Values for Data Obtained via Test Methods with Multiple Fractions
The tests for metal HAP (EPA Method 29) include numerous test fractions and containers that are isolated for analytical purposes, as follows:
 Front Half (all HAP metals), Fraction 1: Container 1 filter, Container 2 acetone probe rinse, and Container 3 acid probe rinse
 Back Half (all HAP metals), Fraction 2A and Fraction 2B: Container 4 HNO3/H2O2 (nitric acid/ hydrogen peroxide) impingers
 Back Half (Hg Only), Fraction 3A: Container 5A HNO3
 Back Half (Hg Only), Fraction 3B: Container 5B KMnO4/H2SO4 (potassium permanganate/sulfuric acid) absorbing solution
 Back Half (Hg Only), Fraction 3C: Container 5C HCl rinse and dilution
For any test fractions in the metal HAP tests where the laboratory results were classified as BDL, the method detection limit (MDL) or similar value was used as the mass of the fraction in the Coke Oven Emissions Database, as per EPA protocol for developing emissions estimates that potentially could be used to develop standards. For risk assessment purposes and in this memorandum, BDL data are handled differently, as described below in Section 2.9, The entire run was considered BDL only if all fractions of a test run were BDL. Similarly, the entire run was considered ADL only if all fractions of a test run were ADL. If there was a mix of fractions classified as either BDL or ADL in a run, then the run was labelled DLL. Note that only tests with more than one fraction could be possibly classified as DLL. For pollutants that did not have multiple fractions in the testing, the data was classified as either ADL or BDL, for mass values above or below the MDL, respectively.

       The tests for dioxin/furans (EPA Method 23) measures multiple individual dioxin/furan congeners. For each congener, the run was classified as BDL if the congener mass was below the Estimated Detection Limit (EDL). For each congener mass that was below the EDL, the EDL mass was used for the fraction/congener mass in the Coke Oven Emissions Database and in emissions calculations for total TEQ. Like the situation with the HAP metals test, the total TEQ value is comprised of multiple congeners that comprise the total TEQ mass in each run. Therefore, like HAP metals, the run was classified as BDL only if all the individual congener masses were below the EDL and the test runs data are classified ADL only if all congeners were above the EDL. The runs are considered DLL if one or more congeners, but not all, were below the EDL.

Treatment of BDL, DLL, and ADL Values Used for MACT Floor and APCD Cost Effectiveness Calculations vs. Coke Oven Risk Modeling
      In the Coke Oven Emissions Database, for stack run data where values were at or below detection, the 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. (See details in Section 2.8 above). 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 . In order to provide emissions for the Coke Oven Risk Modeling Database, for run data below detection, the emissions for the run were converted to half of the MDL (or EDL) for use in developing the test run value, as per EPA policy for performing risk assessments. This type of data is classified as "adjusted for nondetected" values. Both sets of data can be found in the Coke Oven Emissions Database, whereas only "adjusted for nondetected" data are used in the Coke Oven Risk Modeling Database. Note that for test runs classified as "DLL" or "ADL," there were no adjustments made to the test run values for either database. Although both "adjusted" and "not adjusted" for nondetected data are in the Coke Oven Emissions Database, only "adjusted for nondetected" data are shown in this memorandum and the Coke Oven Risk Modeling Database.

3.0	COKE 114 REQUESTS DATA QUALITY CONTROL (QC) CHECKS
After the data were compiled into the Coke Oven Emissions Database and appropriate conversions and calculations were made, as described above in Section 2.4, several rounds of review were performed by both the EPA project team and representatives from the coke industry to ascertain the accuracy of reported data and subsequent calculations. See Appendix B for all data relevant to emission estimates and the calculations performed (with supporting documents included in Coke PQBS docket (EPA-HQ-OAR-2002-0085). A final QC was performed by the risk database QA staff at the EPA.
 3.1	Internal EPA QC Checks
 3.1.1 Laboratory Report QC for D/F
A review of the laboratory reports for dioxin/furan Coke 114 requests Enclosure 2 stack test data was performed to confirm that emissions were calculated correctly. The mass values from the laboratory reports were used to calculate the emissions and compared to the reported dioxin/furan emissions.
 3.1.2 Inadvertent Omitted HAP
There were a few HAP for which Coke 114 requests Enclosure 2 stack test data was not obtained. These include perylene and total OCDD and OCDF. Table 12 lists the HAP and their sources omitted from the Coke 114 requests responses. The circumstances of the omissions are described below.

Perylene:
USS Clairton, PA noted in their stack test reports that that the compound perylene had not been subjected to Maxxam's standard validation procedure for this matrix; as such, no perylene was reported for their samples for 2016 Coke 114 request submissions.

Total OCDD and Total OCDF:
An inadvertent omission was made in the list of HAP in 2016 Coke 114 request Enclosure 2 for octachlorodibenzo-p-Dioxin (Total OCDD) and octachlorodibenzofuran (Total OCDF) dioxin/furan congeners. Some facilities still had their labs analyze for Total OCDD and Total OCDF congeners, while other facilities followed the exact list of HAP in the 2016 Coke 114 request Enclosure 2 and, therefore, did not analyze for Total OCDD and Total OCDF.

Table 12. Specific HAP and their Sources Omitted from Coke 114 Request Stack Tests
                                  Facility ID
                               Emission Unit ID
                                  Process ID
                         Pollutant Name in Coke Oven
                              Emissions Database
CC-Monessen-PA
Battery Combustion Stack #2
EP-3 ByP Battery Stack
                                  Total OCDD
CC-Monessen-PA
Battery Combustion Stack #2
EP-3 ByP Battery Stack
                                  Total OCDF
CC-Monessen-PA
Boiler #1 and #2
EP-4 ByP Boiler stacks
                                  Total OCDD
CC-Monessen-PA
Boiler #1 and #2
EP-4 ByP Boiler stacks
                                  Total OCDF
CC-Monessen-PA
Pushing Baghouse Stack
EP-1 ByP Pushing (CD)
                                  Total OCDD
CC-Monessen-PA
Pushing Baghouse Stack
EP-1 ByP Pushing (CD)
                                  Total OCDF
CC-Monessen-PA
Quench Tower Stack
EP-10 Quench Tower
                                  Total OCDD
CC-Monessen-PA
Quench Tower Stack
EP-10 Quench Tower
                                  Total OCDF
EC-Erie-PA
Battery Combustion Stack (805)
EP-3 ByP Battery Stack
                                  Total OCDD
EC-Erie-PA
Battery Combustion Stack (805)
EP-3 ByP Battery Stack
                                  Total OCDF
EC-Erie-PA
Boiler #1 Stack
EP-4 ByP Boiler stacks
                                  Total OCDD
EC-Erie-PA
Boiler #1 Stack
EP-4 ByP Boiler stacks
                                  Total OCDF
USS-Clairton-PA
Battery B Combustion Stack (S012)
EP-3 ByP Battery Stack
                                   Perylene
USS-Clairton-PA
P052-Quench Tower No. 7A& 8
EP-10 Quench Tower
                                   Perylene

 3.1.3 Facility and/ or Unit Operating Status Changes after 2016 Coke 114 Request Data Received
The Erie Coke facility received the Coke 114 request and conducted testing from August through October 2016 on several units: ByP Pushing, ByP Battery Stack, and Boiler Stack. However, as work was being finalized for developing coke emissions for the coke industry, the EPA was notified that the Erie Coke facility was being shut down in late 2019. Therefore, the emissions for Erie Coke were used, as planned, to develop emission factors for other coke facilities that produce foundry coke and did not perform testing, but the Erie Coke units and emissions were not included in the Coke Oven Risk Modeling Database. Appendix D summarizes the Erie 2016 Coke 114 request data that were received.
      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 Bluestone Birmingham, AL; Cleveland Cliffs Follansbee, WV; and Cleveland Cliffs Middletown, OH facilities were not operating during the development of the 2022 Coke 114 request and did not receive the request.
 3.1.4 Suspect Data Evaluations
Early in the development of the Coke Oven Emissions Database, suspect data were identified based on test report comments. The EPA test method experts reviewed the suspect data and made the decisions to include or not include the data in the Coke Oven Emissions Database. Table 13 below summarizes the Coke 114 requests data that was not included in the Coke Oven Emissions Database.
Table 13. Suspect 114 Requests Data Not Included in the Coke Oven Emissions Database
          Facility ID
          Unit ID
          Unit Type
          Pollutant Tested
          Test Method
          Run(s)
          Start Test Date
                                 Suspect Data
CC-Middletown-OH
Pushing Baghouse
EP-1 ByP Pushing (CD)
HCl & HF
EPA Method 26
1
8/23/2016
The EPA did not use CC-Middletown-OH EPA Method 26 Run 1 data, failed isokinetic test.
CC-BurnsHarbor-IN
#2 Coke Battery Pushing Emission Control Baghouse Stack
EP-1 ByP Pushing (CD)
MeCl Method 0031
1-3
8/30-9/1/2016
The EPA did not use CC-BurnsHarbor-IN SW 846 0031 methylene chloride data. Methylene chloride (MeCl2) results for all condensate samples were much higher than anticipated. It is believed that cross contamination occurred between the Method 23/0010 MeCl2 samples and the Method 0031 condensate samples as these samples were transported to Maxxam Analytics, Inc., in the same batch. In addition, the methylene chloride that was used in the field recovery of Method 23/0010, was in close proximity to where the Method 0031 condensate samples were recovered. Consequently, the Method 0031 condensate data was not considered representative of actual emissions from the source.
CC-BurnsHarbor-IN
#2 Coke Battery Pushing Emission Control Baghouse Stack
EP-1 ByP Pushing (CD)
Toluene
SW846 Method 0031
1-3
8/30-9/1/2016
The EPA did not use CC-BurnsHarbor-IN SW 846 0031 toluene data, because results biased high likely due to cross contamination from the recovery reagents used for the Method 23/0010 sampling train.
CC-Monessen-PA
Quench Tower Stack
EP-10 Quench Tower
All Pollutants Tested
All Methods
1-3
10/25-11/2/2016
The EPA did not use CC-Monessen-PA quench data because of high velocity (confirmed in facility test report). Velocity values shown are based on measurements taken only at the start of a quench and are considered maximum velocity readings.
SC-GraniteCity-IL
Coke Oven Battery C - Bypass Vent 5
EP-7 HRSG Bypass/waste heat stacks
HCN
Zinc Acetate Method
1-3
5/3-5/2017
The EPA did not use hydrogen cyanide from SC-GraniteCity-IL test data because it appears there was excessive breakthrough (higher HCN values in the backup impinger) making these results invalid. Note that the EPA abandoned the zinc acetate approach in mid-2017 due to its limited dynamic range of measurement, i.e., poor and inconsistent sample recovery.
SC-FranklinFurnace-OH
Bypass Vent Stack 6
EP-7 HRSG Bypass/waste heat stacks
Formaldehyde
EPA Method 320
2
10/1-2/2022

At 00:01 on 10/2 (p 256), the formaldehyde spiked as high as 65 ppm. The moisture increased to an average of 6% on that run, also measured by the FTIR. It appears they did not have anything else going on at the same time. The average flow rate was used for all three runs vs an independent measurement during the test run.

EPA emailed facility Mon 1/9/2023 5:37 PM to inquire if the test was conducted during normal operations vs a small upset. The facility has not provided a response.

Run 2 was an outlier when tested with all other formaldehyde runs and was not used for MACT or Cost calculations, but was in the risk modeling file.

 3.2	Coke Industry Review of Coke 114 Request Data
      Numerous reviews of the source emissions from the Coke 114 request data were performed by the facilities in the coke industry. Beginning in September 2019, the EPA sent the coke industry their processed data to review, first individually to each facility. In August 2020, the EPA sent the draft of the combined Coke 114 request data to the whole industry with all facilities' data. The EPA continued to work with industry to finalize and correct the emission estimates.

4.0	COKE OVEN EMISSONS DATABASE
      The Coke Oven Emissions Database, and other information pertinent to the modeling of HAP emissions that were requested in the Coke 114 request (e.g., stack diameter, stack height, and operating hours), was developed in part to provide a repository of emissions data to be used to populate the Coke Oven Risk Modeling Database (described in Section 5). The following sections discuss the data from the Coke Oven Emissions Database used to develop the emissions for the Coke Oven Risk Modeling Database ("adjusted for nondetected" data). All emission calculations and supporting files are included in Appendix B along with the complete Coke Oven Emissions Database.
 4.1	Actual Annual Emissions for Coke PQBS Source Category
      The HAP emissions from the 2016 and 2022 Coke 114 request Enclosure 2 and 1998 uncontrolled stack test data for fugitive pushing HAP profile (EPA, 1999a and EPA, 1999b) were used to develop the Coke Oven Emissions Database "actual" annual HAP emissions estimates for all HAP-emitting Coke PQBS units at coke facilities (pushing, battery combustion stack, HRSG main stack, HRSG bypass/waste heat stack, quench tower, and fugitive pushing). All emissions, calculations, and supporting files are described in Appendix B.). The Coke Oven Emissions Database was then used to populate the Coke Oven Risk Modeling Database described in Section 5.

 4.1.1 Emissions Developed from 2016 and 2022 Coke 114 Request Enclosure 2 Stack Test Data
      A number of Coke PQBS sources were requested to conduct testing as per the 2016 and 2022 Coke 114 request Enclosure 2 stack tests. Table 14 summarizes the units for facilities from which the EPA received 2016 and 2022 Coke 114 request Enclosure 2 stack test data that were used to estimate emissions from other facilities in the industry and other units at the facilities that were not tested.

    Table 14. Coke Facility Units Providing Test Data for the Coke PQBS RTR
                                  Facility ID
                                    Unit ID
                                 Type of Coke
                               Coke 114 Request
                             EP-1 ByP Pushing (CD)

CC-Middletown-OH
Pushing Baghouse
Blast furnace
                                     2016
CC-BurnsHarbor-IN
#2 Battery Pushing Baghouse
Blast furnace
                                     2016
CC-Monessen-PA[1]
Pushing Baghouse Stack
Blast furnace
                                     2016
EC-Erie-PA[2]
Coke Side Shed Baghouse (802)
Foundry
                                     2016
                            EP-3 ByP Battery Stack

CC-Middletown-OH
Combustion Stack
Blast furnace
                                     2016
CC-BurnsHarbor-IN
Coke Battery No. 2 Underfire Stack
Blast furnace
                                     2016
CC-Monessen-PA[1]
Battery Combustion Stack #2
Blast furnace
                                     2016
EC-Erie-PA[2]
Battery Combustion Stack (805)
Foundry
                                     2016
USS-Clairton-PA
Battery B Combustion Stack (S012)
Blast furnace
                                     2016
                             EP-6 HRSG Main Stacks

SC-Middletown-OH
P90-Coke Oven Battery A-C-Main Stack
Blast furnace
                                     2016
CE-EastChicago-IN

Blast furnace
                                     2022
                      EP-7 HRSG Bypass/waste heat stacks

SC-GraniteCity-IL
Coke Oven Battery C - Bypass Vent 5
Blast furnace
                                     2016
SC-FranklinFurnace-OH
Bypass Vent Stack 6
Blast furnace
                                     2022
                             EP-9 HNR Pushing (CD)

SC-GraniteCity-IL
Gateway Flat Push Hot Car
Blast furnace
                                     2016
SC-Middletown-OH
Middletown Flat Push Hot Car
Blast furnace
                                     2016
                             EP-10 Quench Tower[3]

USS-Clairton-PA
7A Quench Tower (P052)
Blast furnace
                                     2016
[1] CC-Monessen-PA did not test for OCDD and OCDF due to an EPA omission. Default emission factors were used instead for this facility. See Section 3.1.2
2 While Erie Coke data was used to develop foundry emissions for the Coke PQBS RTR, because the facility is now permanently closed, the data for this facility was not modeled.
[3] Despite a conscientious testing effort, the CC-Monessen-PA Quench Tower Stack results were not able to be used. See Section 3.1.4, for more explanation.

	Table 15 summarizes the calculations used to develop coke oven facility emission estimates in tons per year (TPY) from 2016 and 2022 Coke 114 request stack test data. The individual components of the calculations are described in the sections that follow.

Table 15. Calculation Methodology for Coke PQBS Units with Coke 114 Requests Stack Test Data
                                  Process ID
                        Test Data/ Emission Factor UOM
                     Calculation of Actual Emissions (TPY)
EP-1 ByP Pushing (CD)
lb/ton coke produced
= lb/ton coke x Coke Production TPY / 2000
EP-3 ByP Battery Stack
lb/ton coke produced
= lb/ton coke x Coke Production TPY / 2000
EP-6 HRSG Main Stacks
lb/hr
= lb/hr x hr/yr / 2000
EP-7 HRSG Bypass/waste heat stacks
lb/hr
= lb/hr x hr/yr / 2000
EP-9 HNR Pushing (CD)
lb/ton coke produced
= lb/ton coke x Coke Production TPY / 2000
EP-10 Quench Tower
lb/ton coke produced
= lb/ton coke x Coke Production TPY / 2000

<IP_ADDRESS> Emission Factors Developed from Coke 114 Requests Enclosure 2 Stack Test Data

      The 2016 and 2022 Coke 114 request Enclosure 2 stack test data ("adjusted for nondetected") was used to create default industry emission factors by coke type (i.e., foundry coke vs. blast furnace coke), process ID and pollutant to use for all other facilities and units that were not required to test to develop the Coke Emissions Database. The emissions for Erie Coke were used to develop emission factors for facilities that produce foundry coke (see Section 3.1.3). Tables 16 - 19 summarize the emission factors and units of measurement (UOM) for each default industry emission factor per process ID and coke type, as applicable. See Appendix B for a complete listing of the units for each facility and individual HAP emission factors used in the Coke Oven Emissions Database.

       Table 16. Pushing (CD) Default Emission Factors[1] per Coke Type
                                      HAP
                           Default Emission Factor
                           (lb/ton coke produced[2])

                                    ByP  -
                              Blast Furnace Coke
                                   ByP  -
                                 Foundry Coke
                                   HNR  -
                              Blast Furnace Coke
                                  HAP Metals
Antimony
                                   1.23E-07
                                   1.54E-07
                                   2.34E-06
Arsenic
                                   1.39E-07
                                   2.10E-07
                                   2.02E-05
Beryllium
                                   5.32E-08
                                   3.86E-08
                                   2.90E-07
Cadmium
                                   6.91E-08
                                   1.27E-07
                                   1.42E-07
Chromium (total)[3]
                                   5.41E-06
                                   3.53E-06
                                   5.14E-06
     Chromium III[3]
                                   5.24E-06
                                   3.43E-06
                                   4.98E-06
     Chromium VI[3]
                                   1.62E-07
                                   1.06E-07
                                   1.54E-07
Cobalt
                                   1.14E-07
                                   1.15E-07
                                   9.19E-07
Lead
                                   4.51E-07
                                   4.36E-07
                                   2.52E-05
Manganese
                                   4.91E-06
                                   4.58E-05
                                   6.91E-06
Mercury (total)[3]
                                   1.91E-07
                                   1.01E-07
                                   1.22E-07
     Elemental gaseous Hg[3]
                                   1.53E-07
                                   8.08E-08
                                   9.77E-08
     Gaseous divalent Hg[3]
                                   2.86E-08
                                   1.51E-08
                                   1.83E-08
     Particulate divalent Hg[3]
                                   9.54E-09
                                   5.05E-09
                                   6.11E-09
Nickel
                                   3.54E-06
                                   3.54E-06
                                   3.68E-06
Selenium
                                   1.24E-06
                                   6.70E-07
                                   3.63E-06
                              Other (Gaseous) HAP
Carbon disulfide
                                   5.30E-06
                                   1.34E-04
                                   1.15E-05
Formaldehyde
                                   3.01E-06
                                   7.58E-06
                                   1.38E-05
Hydrogen chloride
                                   1.12E-03
                                   1.00E-03
                                   1.34E-03
Hydrogen cyanide
                                   5.19E-04
                                   4.49E-04
                                   2.40E-05
Hydrogen fluoride
                                   1.49E-04
                                   4.37E-04
                                   3.20E-04
Total D/F[4,5]
                                   1.13E-11
                                   3.68E-11
                                   1.21E-11
Total PAH[4]
                                   3.60E-05
                                   6.44E-04
                                   4.11E-06
Total VOHAP[5,6,7][,8]
                                   3.57E-04
                                   1.12E-02
                                   4.35E-06
[1] See Table 14 for the data source for each type of emissions factor.
[2] Estimated SC-Middletown-OH and SC-GraniteCity-IL Coke produced using the Erie Coke Wet Coal Charged Capacity/Coke Produced Capacity ratio value of 1.3, applied to the wet coal charged values reported by SunCoke.
[3] For Hg and Cr speciation factors, see Section 2.5. Total Hg and Cr provided for information purposes only.
[4] See Appendix B for the individual HAP in the groups.
[5] For CC-Monessen-PA and EC-Erie-PA, data for some congeners were not available. See Section 3.1.2.
[6] The CC-BurnsHarbor-IN SW 846 0031 data for methylene chloride and toluene were not used in the average. See Section 3.1.4
7 Although formaldehyde is a VOHAP, because formaldehyde is a separately CAA-listed HAP and was measured in a separate and different test method than VOHAP, it is listed here separately.
[8] Although carbon disulfide was measured with the same test method as the VOHAP, it is an inorganic HAP and, as such, is listed here separately.

     Table 17. ByP Battery Stack Default Emission Factors[1] per Coke Type
                                      HAP
                           Default Emission Factor
                            (lb/ton coke produced)

                              ByP & HNR  -
                              Blast Furnace Coke
                                   ByP  -
                                 Foundry Coke
Antimony
                                   1.49E-06
                                   1.97E-06
Arsenic
                                   1.61E-05
                                   2.87E-05
Beryllium
                                   2.86E-07
                                   4.92E-07
Cadmium
                                   5.02E-07
                                   7.34E-07
Chromium (total)[2]
                                   2.08E-04
                                   1.20E-04
     Chromium III[2]
                                   2.02E-04
                                   1.16E-04
     Chromium VI[2]
                                   6.24E-06
                                   3.59E-06
Cobalt
                                   1.90E-06
                                   7.41E-06
Lead
                                   2.15E-05
                                   3.01E-05
Manganese
                                   3.53E-05
                                   7.71E-05
Mercury (total)[2]
                                   7.83E-06
                                   4.99E-06
     Elemental gaseous Hg[2]
                                   6.26E-06
                                   3.99E-06
     Gaseous divalent Hg[2]
                                   1.17E-06
                                   7.49E-07
     Particulate divalent Hg[2]
                                   3.91E-07
                                   2.50E-07
Nickel
                                   1.12E-04
                                   1.52E-04
Selenium
                                   2.66E-05
                                   1.79E-05
Carbon disulfide
                                   1.31E-04
                                   3.49E-05
Formaldehyde
                                   9.62E-06
                                   7.29E-05
Hydrogen chloride
                                   2.48E-02
                                   8.29E-03
Hydrogen cyanide
                                   1.45E-03
                                   3.77E-03
Hydrogen fluoride
                                   9.17E-04
                                   2.69E-04
Total D/F[3,4]
                                   5.98E-10
                                   8.63E-10
Total PAH[3]
                                   6.14E-04
                                   4.60E-03
Total VOHAP[3,5,6]
                                   8.51E-03
                                   1.95E-03
[1] See Table 14 for the data source for each type of emissions factor.
[2] For Hg and Cr speciation factors, see Section 2.5. Total Hg and Cr provided for information purposes only.
[3] See Appendix B for the individual HAP in the groups.
4 For CC-Monessen-PA and EC-Erie-PA, data for some congeners were not available. See Section 3.1.2.
5 Although formaldehyde is a VOHAP, because formaldehyde is a separately CAA-listed HAP and was measured in a separate and different test method than VOHAP, it is listed here separately.
[6] Although carbon disulfide was measured with the same test method as the VOHAP, it is an inorganic HAP and, as such, is listed here separately.

Table 18. HRSG Main Stack and HRSG Bypass/Waste Heat Stack Default Emission Factors[1]
                                      HAP
                        Default Emission Factor (lb/hr)

                               HRSG Main Stack
                          HNR  -  Blast Furnace Coke
                         HRSG Bypass/Waste Heat Stack
                          HNR  -  Blast Furnace Coke
                                 HAP Metals
Antimony
                                   4.45E-04
                                   3.15E-03
Arsenic
                                   8.26E-04
                                   2.67E-02
Beryllium
                                   3.51E-05
                                   2.36E-04
Cadmium
                                   1.99E-04
                                   1.25E-03
Chromium (total)[2]
                                   2.64E-03
                                   1.55E-03
     Chromium III[2]
                                   2.56E-03
                                   1.50E-03
     Chromium VI[2]
                                   7.92E-05
                                   4.65E-05
Cobalt
                                   1.99E-04
                                   1.11E-03
Lead
                                   1.97E-03
                                   7.18E-02
Manganese
                                   4.55E-03
                                   1.06E-03
Mercury (total)[2]
                                   8.40E-03
                                   2.55E-03
     Elemental gaseous Hg[2]
                                   4.20E-04
                                   1.28E-04
     Gaseous divalent Hg[2]
                                   1.26E-03
                                   3.83E-04
     Particulate divalent Hg[2]
                                   6.72E-03
                                   2.04E-03
Nickel
                                   2.51E-03
                                   7.03E-03
Selenium
                                   9.69E-03
                                   1.49E-02
                              Other (Gaseous) HAP
Carbon disulfide
                                      --
                                   3.07E-04
Formaldehyde[7][,8]
                                   5.19E-01
                                   9.11E-02
Hydrogen chloride
                                   3.87E+01
                                   2.97E+01
Hydrogen cyanide
                                   3.31E-01
                                  2.37E-02[4]
Hydrogen fluoride
                                   1.81E-01
                                   8.02E-01
Total D/F[3]
                                   4.24E-08

                                   1.28E-08
Total PAH[3]
                                   1.80E-03

                                   2.87E-04
Total VOHAP[3][,5][,6]
                                      --
                                   5.67E-03
BTEX[8]
                                   5.71E-01

[1] See Table 14 for the data source for each type of emissions factor.
[2] For Hg and Cr speciation factors, see Section 2.5. Total Hg and Cr provided for information purposes only.
[3] See Appendix B for the individual HAP in the groups.
[4] Not using SC-GraniteCity-IL Hydrogen Cyanide values, see Section 3.1.4.
5 Although formaldehyde is a VOHAP, because formaldehyde is a separately CAA-listed HAP and was measured in a separate and different test method than VOHAP, it is listed here separately.
[6] Although carbon disulfide was measured with the same test method as the VOHAP, it is an inorganic HAP and, as such, is listed here separately.
[7] HRSG bypass/waste heat stack emission factor developed for modeling file includes all three of SunCoke Franklin Furnace runs along with SunCoke Granite City run data..
[8] Only Cokenergy main stack was tested for formaldehyde and benzene toluene, ethylbenzene, and xylenes (BTEX).

               Table 19. Quench Tower Default Emission Factors1
                                      HAP
                Default Emission Factor (lb/ton coke produced)

                              ByP & HNR  -
                    Blast Furnace Coke & Foundry Coke
                                   Metal HAP
Antimony
                                   3.39E-06
Arsenic
                                   6.92E-05
Beryllium
                                   2.64E-07
Cadmium
                                   2.12E-07
Chromium (total)[2]
                                   2.67E-06
     Chromium III[2]
                                   2.59E-06
     Chromium VI[2]
                                   8.00E-08
Cobalt
                                   5.96E-07
Lead
                                   7.43E-06
Manganese
                                   2.51E-06
Mercury (total)[2]
                                   1.14E-06
     Elemental gaseous Hg[2]
                                   9.10E-07
     Gaseous divalent Hg[2]
                                   1.71E-07
     Particulate divalent Hg[2]
                                   5.69E-08
Nickel
                                   2.51E-06
Selenium
                                   6.50E-06
                              Other (Gaseous) HAP
Carbon disulfide
                                   9.75E-05
Formaldehyde
                                   1.28E-05
Hydrogen chloride
                                   3.27E-04
Hydrogen cyanide
                                   1.53E-04
Hydrogen fluoride
                                   9.46E-05
Total D/F[3]
                                   1.30E-10
Total PAH[3]
                                   7.45E-05
Total VOHAP[3,4,5][,6]
                                   2.55E-04
[1] See Table 14 for the data source for each type of emissions factor.
[2] For Hg and Cr speciation factors, see Section 2.5. Total Hg and Cr provided for information purposes only.
[3] See Appendix B for the individual HAP in the groups.
[4] USS-Clairton-PA did not have Perylene values, see Section 3.1.2.
5 Although formaldehyde is a VOHAP, because formaldehyde is a separately CAA-listed HAP and was measured in a separate and different test method than VOHAP, it is listed here separately.
[6] Although carbon disulfide was measured with the same test method as the VOHAP, it is an inorganic HAP and, as such, is listed here separately.

<IP_ADDRESS> Similar Units Used with Surrogate Data

      The EPA used the 2016 and 2022 Coke 114 request Enclosure 2 stack test data ("adjusted for nondetected") for similar units at the test facilities as "surrogate" data. Table 20 summarized the units where data from similar units were used for those units at the same facility that were not required to test.

               Table 20. Similar Units Used with Surrogate Data
                                  Facility ID
                                  Unit Tested
                                 Similar Unit
                             EP-1 ByP Pushing (CD)
CC-BurnsHarbor-IN
EU512-14 pushing #2
EU512-06 pushing #1
                            EP-3 ByP Battery Stack
CC-BurnsHarbor-IN
EU512-16 battery #2 underfiring
EU512-08 battery #1 underfiring
CC-Monessen-PA
Coke Oven Battery 2 underfiring
Coke Oven Battery 1B underfiring
USS-Clairton-PA
Coke Oven B Battery underfiring
Coke Oven Battery 1, 2, 3, 13, 14, 15, 19, 20, C underfiring

<IP_ADDRESS> Coke Production and Operating Hours Data

      The calculation of emissions for coke process units from emission factors required knowledge of coke production or operating hours, depending on the units of the emission factors, i.e., lb HAP per ton coke produced or lb HAP per hour. The annual coke facility production and operating hours obtained for this purpose are summarized in Tables 21 and 22 below, respectively. The information was obtained from the 2016 Coke 114 request, previous EPA reports, or communication with the COETF.

       Table 21. Annual Coke Production Values, by Facility and Battery
                                  Facility ID
                                  Battery ID
                             2016 Coke 114 Request
                         "Actual" Coke Production TPY
ABC-Tarrant-AL
Coke Battery #1
                                  377,606[1]
ABC-Tarrant-AL
Coke Battery #5
                                   68,555[1]
ABC-Tarrant-AL
Coke Battery #6
                                   79,524[1]
BLU-Birmingham-AL
Coke Battery No. 3
                                  105,038[1]
BLU-Birmingham-AL
Coke Battery No. 4
                                   98,007[1]
BLU-Birmingham-AL
Coke Battery No. 5
                                  145,668[1]
CC-Follansbee-WV
No. 1 ,2 , 3 Battery
                                 36,2641 each
CC-Follansbee-WV
No. 8 Battery
                                  453,069[2]
CC-Middletown-OH
Coke Oven Battery
                                  401,752[2]
CC-BurnsHarbor-IN
Battery #1
                                  932,178[2]
CC-BurnsHarbor-IN
Battery #2
                                  955,975[2]
CC-Monessen-PA
Battery 1B
                                  222,015[2]
CC-Monessen-PA
Battery 2
                                  114,007[2]
CC-Warren-OH
No. 4 Battery
                                  359,281[2]
EES-RiverRouge-MI
Coke Battery #5
                                  981,765[2]
SC-EastChicago-IN
Battery A, B, C, D
                                 325,0003 each
SC-FranklinFurnace-OH
A, C Battery
                                 204,9944 each
SC-FranklinFurnace-OH
B, D Battery
                                 136,6634 each
SC-GraniteCity-IL
Battery A, B, C
                                142,804[4] each
SC-Middletown-OH
A, C Battery
                                 142,8044 each
SC-Middletown-OH
B Battery
                                   71,402[4]
SC-Vasant-VA
Battery 2D, 3G
                                 90,0003 each
SC-Vasant-VA
Battery 2E
                                  135,000[3]
SC-Vasant-VA
Battery 3B
                                  130,000[3]
SC-Vasant-VA
Battery 3C
                                  180,000[3]
SC-Vasant-VA
Battery 3F
                                   85,000[3]
USS-Clairton-PA
Battery 1, 2, 3
                                 217,2242 each
USS-Clairton-PA
Battery 13, 14, 15
                                 225,7242 each
USS-Clairton-PA
Battery 19, 20
                                 424,3072 each
USS-Clairton-PA
B Battery
                                  718,216[2]
USS-Clairton-PA
C Battery
                                  880,570[2]
[1] Value reported by industry (COETF). See docket for the rule (EPA-HQ-OAR-2004-0085) for records of communications with COETF.
[2] Value reported by facility to 2016 Coke 114 request Enclosure 1 (Q29.b-pt.8). Total production for year 2015 (tpy).
[3] 1998 coke production values from the NESHAP for Coke Ovens: Pushing, Quenching, and Battery Stacks  -  Background Information for Proposed Standards, February 2001, EPA-453/R01-006 (EPA, 2001a).
[4] Typical operation using 2016 Coke 114 request Enclosure 1 (Q28.i). Coke production design capacity multiplied by average capacity utilization (55%)

Table 22. Annual Operating Hours for HRSG Main Stacks and HRSG Bypass/Waste Heat Stacks
                                  Facility ID
                                 Emission Unit
                            Annual Operating Hours
                             EP-6 HRSG Main Stacks
SC-EastChicago-IN
HRCCF Main Stack 001
                                     8,760
SC-FranklinFurnace-OH
FGD - Main Stacks AB and CD
                                  8,760 each
SC-GraniteCity-IL
FGD - Main Stack
                                     8,760
SC-Middletown-OH
FGD - Main Stack
                                     8,760
                      EP-7 HRSG Bypass/Waste Heat Stacks
SC-EastChicago-IN
Venting Stack 1-16
                                  1,139 each
SC-FranklinFurnace-OH
HRSG Bypass Vent Stack 1-10
                                   192 each
SC-GraniteCity-IL
HRSG Bypass Vent Stack 1-6
                                   312 each
SC-Middletown-OH
HRSG Bypass Vent Stack 1-5
                                   312 each
SC-Vansant-VA
Venting 1-16 Stack
                                  8,760 each

<IP_ADDRESS> Control Device Efficiency Corrections

      The emission factors for the EP-9 HNR Pushing (CD) units were developed from test data at SunCoke's Middletown-OH facility from units with a multiclone control device. Although two other SunCoke facilities (Haverhill and Franklin Furnace) also use multiclones, the SC-Vansant-VA facility utilizes cokeside sheds and the SC-EastChicago-IN facility utilizes a baghouse for their pushing controls. As such, a control device efficiency correction was calculated for these two facilities and applied to the emission factors developed from multiclone tests. In the SunCoke permit application for Middletown, the estimated particulate control efficiency of the multiclone is 98% (based on AP-42 factors in Table 12.2-6 and AP-42, Appendix B.2, Figure B.2-1  (EPA, 2001b). Table 23 summarizes the control device efficiency correction factors used for cokeside shed and baghouse pushing controls.

      Table 23. HNR Pushing Control Device Efficiency Correction Factors
                              HNR Pushing Control
                  Control Device Efficiency Correction Factor
                    Control Device Efficiency Calculations

                     Control Device Efficiency Correction
                                  References
Cokeside Shed
                                     0.76
74% control efficiency for cokeside shed divided by 98% control efficiency for multiclone
AP-42, Table 12.2-6.
(EPA, 2001b)
Baghouse
                                      1.0
99% control efficiency for baghouse divided by 98% control efficiency for multiclone
AP-42, Appendix B.2, Figure B.2-1.
(EPA, 2001b)

<IP_ADDRESS> Oven to HRSG Bypass/Waste Heat Stack Adjustment

      The EPA estimated emissions for HRSG bypass/waste heat stacks based on the emission factors developed from source testing at the SunCoke Gateway facility in Granite City, IL, in units of lb HAP/hr. For the SC-Vansant-VA facility, this approach was adjusted to account for the SC-Vansant-VA facility having fewer ovens per stack as compared to the SunCoke Gateway facility. The SC-Vansant-VA facility has 143 ovens and 16 HRSG bypass/waste heat stacks resulting in approximately 9 ovens per stack. However, the SC-GraniteCity-IL facility has 120 ovens and 6 HRSG bypass/waste heat stacks resulting in 20 ovens per stack. Therefore,  the SC-Vansant-VA stack emissions were multiplied by the ratio of the number of ovens per stack for each facility, or 9/20, to account for the lower number of ovens per stack at SC-Vansant-VA.

 4.1.2 Fugitive Pushing Emission Estimates
      The basis for calculating metal HAP and PAH "surrogate" emissions for fugitive pushing emissions from the ovens were data from two stack tests: Arcelor Burns Harbor in 1998 (EPA report EPA-454-R-99-001a; Docket No. A-2000-34, Document No. II-A-15) (EPA, 1999a) and ABC Coke in 1998 (EPA report EPA-454-R-99-002a; Docket No. A-2000-34, Document No. II-A-16) (EPA, 1999b). The test data from ArcelorMittal Burns Harbor applies to blast furnace coke facilities (ByP and HNR), while the test data from ABC Coke applies to foundry coke facilities. The COETF provided battery-specific capture efficiencies for 27 batteries at nine facilities (COETF, 2021a). A capture efficiency of 95 percent was used as default for facilities that did not provide specific capture efficiencies per battery, where all data were <4% opacity by Method 9. Table 24 summarizes the capture efficiencies used for each battery and the source.

Table 24. Pushing Device PM Capture Efficiencies, as Fraction of Total PM Emissions
                                  Facility ID
                                  Battery ID
                       Pushing PM Capture Fraction[1,2]
ABC-Tarrant-AL
Coke Battery #1
                                    0.9502
ABC-Tarrant-AL
Coke Battery #5 & #6
                                    0.9497
CC-Follansbee-WV
No. 1 Battery
                                    0.9658
CC-Follansbee-WV
No. 2 Battery
                                    0.9667
CC-Follansbee-WV
No. 3 Battery
                                    0.9663
CC-Follansbee-WV
No. 8 Battery
                                    0.9519
CC-Middletown-OH
Coke Oven Battery
                                     0.973
CC-BurnsHarbor-IN
Battery #1 & #2
                                     0.962
CC-Monessen-PA
Battery 1B & 2
                                    0.9768
CC-Warren-OH
No. 4 Battery
                                    0.9516
BLU-Birmingham-AL
Coke Battery No. 3, 4, 5
                                      0.9
EES-RiverRouge-MI
Coke Battery #5
                                     0.95
SC-EastChicago-IN
Battery A, B, C, D
                                0.95 (default)
SC-FranklinFurnace-OH
Battery A, B, C, D
                                0.95 (default)
SC-GraniteCity-IL
Battery A, B, C
                                0.95 (default)
SC-Middletown-OH
Battery A, B, C
                                0.95 (default)
SC-Vasant-VA
Battery 2D, 2E, 3B, 3C, 3F, 3G
                                0.95 (default)
USS-Clairton-PA
Battery 1
                                    0.9903
USS-Clairton-PA
Battery 2
                                    0.9924
USS-Clairton-PA
Battery 3
                                    0.9936
USS-Clairton-PA
Battery 13
                                    0.9931
USS-Clairton-PA
Battery 14
                                    0.9944
USS-Clairton-PA
Battery 15
                                    0.9988
USS-Clairton-PA
Battery 19
                                    0.9968
USS-Clairton-PA
Battery 20
                                    0.9975
USS-Clairton-PA
B Battery
                                    0.9996
USS-Clairton-PA
C Battery
                                    0.9998
[1] Where more than one battery is listed, fraction applies to each battery.
[2]The COETF (2021a) provided the documentation for the pushing capture efficiencies in most cases. A value of 0.95 was used as a conservative default factor where no information was available.

      The annual battery coke production values from the 2016 Coke 114 request Enclosure 1 from Table 21 above, as revised by industry where applicable, also were used in the following equation to calculate TPY emissions for metal HAP and PAHs:

      HAPi = FPM * SFi * (1  -  Capture) / Coke Pushed * Coke Production

      Where:
      HAPi = Emission rate of HAP i (ton/yr)
      FPM = Uncontrolled filterable PM emission rate (lb/hr)
      SFi = Speciation factor of HAP i (dimensionless)
      Capture = Pushing capture efficiency (fraction)
      Coke Pushed (ton/hr) from ABC Coke and ArcelorMittal Burns Harbor stack tests
      Coke Production (ton/yr)

      For acid gases, semi-volatile HAP, and D/F, the industry default emission factors, as described in Section 4.1.1, were used with the pushing capture efficiencies provided by industry in the following equation to calculate TPY "surrogate" emissions for Acid Gases, Semi-Volatile HAP and D/Fs.

      HAPi = ((HAPi EF * Coke Production / 2000) / Capture) * (1 - Capture)

      Where:
      HAPi = Emission rate of HAP i (ton/yr)
      HAPi EF = Industry default emission factors (lb/ton coke)
      Coke Production (ton/yr)
      Capture = Pushing capture efficiency (fraction)

 4.2	Actual Annual Emissions for Noncategory Emissions
      The HAP emissions from the 2016 and 2022 Coke 114 request Enclosures 1&2 and EPA's 2017 National Emission Inventory (NEI)/ Emission Inventory System (EIS) data were used to develop the Coke Oven Emissions Database "actual" annual HAP emissions estimates for all HAP-emitting noncategory units at coke facilities. The noncategory HAP emissions operating units at coke facilities are: Coke Ovens, subpart L, sources: charging (both ByP and HNR); ByP lids, doors and offtakes; ByP chemical recovery plants; boilers; flares; II&S (40 CFR part 63, subpart FFFFF) sources, i.e., BF, BF stoves, BOPF control devices, ladle metallurgy, hot metal transfer skimming and desulfurization, sinter plant windbox, sinter plant discharge end, and BF cooling tower; and other miscellaneous units not related to coke manufacturing (e.g., process heaters, metal finishing, steel pickling, annealing furnaces, coating line pot heaters, reheat furnaces, thermal coal dryers, etc.). All emission calculations are show in Appendix B. Supporting files are included in the Coke PQBS docket (EPA-HQ-OAR-2002-0085). The Coke Oven Emissions Database was used to populate the Coke Oven Risk Modeling Database described in Section 5.

 4.2.1 Noncategory Emissions Developed from Coke 114 Request Enclosure 2 Stack Test Data
<IP_ADDRESS> Noncategory Emission Factors Developed from Coke 114 Request Enclosure 2 Stack Test Data

      Table 25 summarizes the units tested as part of the Coke 114 request Enclosure 2 test request.

Table 25. Coke Noncategory Units Tested as Part of the Coke 114 Request Enclosure 2
                                  Facility ID
                                    Unit ID
                                 Type of Coke
                               ByP Boiler Stacks
CC-Monessen-PA
Boiler #1 and #2
Blast furnace
EC-Erie-PA
Boiler #1 Stack
Foundry
                               HNR Charging (CD)
SC-Middletown-OH
Pushing/Charging Machine (PCM)
Blast furnace
Note: While Erie Coke data was used to develop foundry emissions for the Coke PQBS RTR, because the facility is now permanently closed, the data for this facility was not modeled.

      Table 26 summarizes the methodology used to develop coke oven facility emission estimates in TPY for the coke noncategory sources with Coke 114 request stack test data. The development of the individual components of the calculation are described in the sections that follow.

Table 26. Calculation Methodology for Noncategory Units with Coke 114 Request Stack Test Data
                                  Process ID
                        Test Data/ Emission Factor UOM
                     Calculation of Actual Emissions (TPY)
EP-4 ByP Boiler stacks
lb/COG mmscf
= lb/ COG mmscf x COG mmscf/yr / 2000
EP-8 HNR Charging (CD)
lb/ton wet coal charged
= lb/ton wet coal x Wet Coal Charged TPY / 2000

      The EPA used the 2016 Coke 114 request Enclosure 2 stack test data to create default industry emission factors per coke type (i.e., foundry coke vs. blast furnace coke), per process ID, and per pollutant, to use for all other units that were not required to test as "surrogate" data. Tables 27 and 28 summarize the emission factors and UOM for each default industry emission factor per process ID.

        Table 27. ByP Boiler Default Emission Factors[1] per Coke Type
                                      HAP
                    Default Emission factor (lb/mmscf COG)

                           ByP - Blast Furnace Coke
                              ByP - Foundry Coke
                                  HAP Metals
Antimony
                                   5.64E-05
                                   2.58E-04
Arsenic
                                   3.18E-04
                                   1.61E-02
Beryllium
                                   9.60E-06
                                   6.44E-05
Cadmium
                                   9.60E-06
                                   1.31E-03
Chromium (total)[2]
                                   8.59E-04
                                   4.27E-02
     Chromium III[2]
                                   8.33E-04
                                   4.14E-02
     Chromium VI[2]
                                   2.58E-05
                                   1.28E-03
Cobalt
                                   1.55E-04
                                   1.62E-03
Lead
                                   1.34E-04
                                   4.56E-03
Manganese
                                   5.37E-04
                                   2.25E-02
Mercury (total)[2]
                                   7.20E-04
                                   5.42E-04
     Elemental gaseous Hg[2]
                                   5.76E-04
                                   4.34E-04
     Gaseous divalent Hg[2]
                                   1.08E-04
                                   8.13E-05
     Particulate divalent Hg[2]
                                   3.60E-05
                                   2.71E-05
Nickel
                                   1.45E-03
                                   1.06E-01
Selenium
                                   2.52E-04
                                   5.59E-03
                              Other (Gaseous) HAP
Hydrogen chloride
                                   1.31E-01
                                   2.33E+00
Hydrogen cyanide
                                   1.39E-01
                                   3.59E-01
Hydrogen fluoride
                                   1.39E-02
                                   6.29E-02
Total D/F[3,4]
                                   4.21E-09
                                   2.66E-08
Total PAH[3]
                                   4.09E-03
                                   2.40E+00
[1] See Table 25 for the data source for each type of emissions factor.
[2] For Hg and Cr speciation factors, see Section 2.5. Total Hg and Cr provided for information purposes only.
[3] See Appendix B for the individual HAP in the groups.
4 For CC-Monessen-PA and EC-Erie-PA, data for some congeners were not available. See Section 3.1.2.

              Table 28. HNR Charging Default Emission Factors[1]
                                  HAP Tested
                           Default Emission Factor
                         (lb HAP/ton Wet Coal Charged

                          HNR  -  Blast Furnace Coke
                                  HAP Metals
Antimony
                                   2.52E-07
Arsenic
                                   8.41E-07
Beryllium
                                   2.46E-08
Cadmium
                                   4.99E-08
Chromium (total)[2]
                                   1.27E-06
     Chromium III[2]
                                   1.23E-06
     Chromium VI[2]
                                   3.81E-08
Cobalt
                                   9.43E-08
Lead
                                   8.23E-07
Manganese
                                   1.79E-06
Mercury (total)[2]
                                   8.93E-08
     Elemental gaseous Hg[2]
                                   7.14E-08
     Gaseous divalent Hg[2]
                                   1.34E-08
     Particulate divalent Hg[2]
                                   4.46E-09
Nickel
                                   1.34E-06
Selenium
                                   2.48E-07
[1] See Table 25 for the data source for each type of emissions factor.
[2] For Hg and Cr speciation factors, see Section 2.5. Total Hg and Cr provided for information purposes only.

<IP_ADDRESS> Wet Coal Charged Data for Calculating HNR Charging Emissions

      For the noncategory HNR charging units tested and using default industry emission factors shown in Table 28, the HNR charging HAP emissions (TPY) were calculated by process ID and individual HAP using annual wet coal charged (in TPY), shown in Table 29 below.

                   Table 29. Annual Wet Coal Charged Values
                                  Facility ID
                                    Battery
                         Annual Wet Coal Charged (TPY)
SC-EastChicago-IN
Battery A, B, C, D
                                 487,939 each
SC-FranklinFurnace-OH
Battery A, C
                                 467,784 each
SC-FranklinFurnace-OH
Battery B, D
                                 311,856 each
SC-GraniteCity-IL
Battery A, B, C
                                 324,850 each
SC-Middletown-OH
Battery A, C
                                 324,850 each
SC-Middletown-OH
Battery B
                                    162,425
SC-Vansant-VA
Battery 2D, 3G
                                 117,500 each
SC-Vansant-VA
Battery 2E
                                    176,250
SC-Vansant-VA
Battery 3F
                                    110,972
SC-Vansant-VA
Battery 3B
                                    169,722
SC-Vansant-VA
Battery 3C
                                    235,000

<IP_ADDRESS> Boiler COG Usage Data for Calculating Boiler Emissions

      For the noncategory boiler units tested and using default industry emission factors, the boiler HAP emissions (TPY) were calculated using boiler COG usage (mmscf/yr), shown in Table 30 below.

                 Table 30. Annual Boiler COG Usage (mmscf/yr)
                                  Facility ID
                  Emission Unit and Modeling release Point ID
                                Regulatory Code
                                     Fuel
                             COG Usage (mmscf/yr)
ABC-Tarrant-AL
Boilers 7, 8, and 9 combined stack
Boilers 7 and 8: JCDH Section 6.1.1, 6.3, and 7.1.1;
Boiler 9: JCDH Section 6.1.1 and 6.4.1
NSPS Subpart Db
                                      COG
                                     2,628
BLU-Birmingham-AL
No. 1, 3 steam generator
JCDH Section 6.1.1, 6.3, and 7.1.1
                                      COG
                                  781 (each)
BLU-Birmingham-AL
No. 4 steam generator
JCDH Section 6.1.1 and 6.3.1
NSPS Subpart Db
                                      COG
                                      590
CC-Follansbee-WV
Boilers 6, 7, 9, and 10 combined stack
WV 45 CSR2-3.1 and 45 CSR2-4.1
WV SIP
                                      COG
                                     3,370
CC-Follansbee-WV
Boiler No. 8
63DDDDD
                                      NG
                                      N/A
CC-Middletown-OH
Boiler No.1, 2, 3, 4
63DDDDD
                                      COG