DTE Energy/EES Coke PTI 51-08C FactSheet

STATE OF MICHIGAN
Rick Snyder, Governor

DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION
CONSTITUTION HALL 525 WEST ALLEGAN STREET P.O. BOX 30260 LANSING, MICHIGAN 48909-7760
www.michigan.gov/air

PUBLIC PARTICIPATION DOCUMENTS
For
EES Coke Battery, LLC
River Rouge, Michigan

PERMIT APPLICATION NUMBER

51-08C

October 1, 2014

EES Coke Battery, LLC Page 1
Permit No. 51-08C October 1, 2014
FACT SHEET
October 1, 2014

Purpose and Summary

The Michigan Department of Environmental Quality (MDEQ), Air Quality Division (AQD), is
proposing to act on Permit to Install (PTI) application No. 51-08C from EES Coke Battery, LLC
(EES Coke). The permit application is for a proposed modification to the existing coke oven
battery. The proposed project is subject to permitting requirements of the MDEQs Rules for Air
Pollution Control as well as state and federal Prevention of Significant Deterioration (PSD)
regulations. Prior to acting on this application, the AQD is holding a public comment period and
a public hearing to allow all interested parties the opportunity to comment on the proposed PTI.
All relevant information received during the comment period and hearing, will be considered by
the decision maker prior to taking final action on the application.

Background Information and the Proposed Project

EES Coke owns and operates a by-product recovery coke oven battery consisting of eighty-five,
six-meter high ovens with an integral heating system; a by-product recovery plant; and a coke
oven gas (COG) flare. The following emission control devices are part of the battery:
overpressure bleeder flares, pushing emission control system (PECS) baghouse, and a quench
tower. Material handling processes in support of the operation of the battery include coal and
coke transfer as well as screening and transport. The coke oven battery converts coal into
metallurgical coke for use in the iron and steel industry.

The by-product recovery coke oven battery began operation in 1992. National Steel
Corporation - Great Lakes Division originally owned and operated the battery as well as the
steel-making operations on Zug Island in River Rouge, Michigan. The coke oven battery was
modified in 1996 to correct emission rates of nitrogen oxides (NO
x
) and carbon monoxide (CO)
to reflect actual operations after the battery was built. In 1997, National Steel Corporation sold
the battery to EES Coke but continued to manage the coke operations. In 2003, the U.S. Steel
Corporation (US Steel) acquired the iron and steel assets from the National Steel Corporation,
and in 2004, EES Coke assumed sole responsibility for the coke operations. EES Coke (State
Registration No. P0408) and US Steel (State Registration No. A7809) are considered to be the
same stationary source.

The by-product recovery coke oven battery, the by-product recovery plant and the material
handling processes are all currently operating under to PTI Nos. 51-08, 71-13 (temporary PTI),
and 124-09. Also, the source has a Renewable Operating Permit (ROP) identified as
No. 199600132d which is currently in the process of being renewed.

The project that EES Coke is proposing in this application is to remove the daily and annual
heat input restrictions on the combustion of COG that is used to heat the battery, and to
increase the material throughput limit on the amount of coal that can be processed in the
battery. Some additional modifications to the material handling processes are also proposed.

Present Air Quality

The facility is located in Wayne County, which is currently in attainment with the National
Ambient Air Quality Standards (NAAQS) for CO, nitrogen dioxide (NO
2
), particulate matter that
has an aerodynamic diameter less than or equal to a nominal 10 microns (PM10), particulate
matter that has an aerodynamic diameter less than or equal to a nominal 2.5 microns (PM2.5),
ozone, lead, and the 3-hour NAAQS for sulfur dioxide (SO
2
). This area is currently designated
as nonattainment for the 1-hour NAAQS for SO
2
. There is no NAAQS for volatile organic
compounds (VOC) nor greenhouse gases (GHGs) as carbon dioxide equivalent (CO
2
e).

Pollutant Emissions

The EES Coke facility is an existing PSD source and a major nonattainment source for SO
2
.
This means that the potential emissions from the facility are greater than the PSD thresholds of
100 tons per year (tpy) for one or more regulated pollutants, and greater than 100 tpy for a
nonattainment pollutant. The proposed project results in a significant net emission increase in
NO
x
and GHGs. Therefore, the proposed project will be a major modification to an existing PSD
source, and subject to the PSD regulations in Part 18 of the Michigan Air Pollution Control Rules
and the federal PSD regulations. The following table provides the estimated net emission
increase for each regulated pollutant from the proposed project:

Facility Emission Increases
Pollutant
Net Emission
Increase (tpy)
Significant Emission
Rate (tpy)
Subject to PSD
Review?
CO - 0 - 100 No
GHGs (as CO
2
e)* 82,229 75,000 Yes
NO
x
668 40 Yes
Particulate Matter (PM) - 0 - 25 No
PM10 - 0 - 15 No
PM2.5 1.4 10 No
SO
2
19.5 40 No
VOC - 0 - 40 No
Lead - 0 - 0.6 No
Sulfuric Acid Mist
(H
2
SO
4
)
1.6 3 No
Hydrogen Sulfide (H
2
S) 2.5 7 No
Total Reduced Sulfur
(TRS) / Reduced Sulfur
Compounds (RSC)
2.7 10 No
* A recent decision by the Supreme Court (Utility Air Regulatory Group v. United States
Environmental Protection Agengy (USEPA), No. 12-1146 (June 23, 2014)) determined that PSD
review for GHGs is only required if one or more of the other regulated pollutants exceeds a PSD
threshold.

Key Permit Review Issues
The AQD staff evaluated the proposed project to identify all state rules and federal regulations
which are, or may be, applicable. The tables in Appendix 1 summarize these rules and
regulations.

PSD Regulations The project was reviewed under the PSD rules which require Best
Available Control Technology (BACT) and an air quality impact analysis for each regulated
air pollutant for which the project will result in a significant net emission increase. The
pollutants subject to PSD review are NO
x
and GHGs (as CO
2
e) as discussed in Appendix 2
and Appendix 3.

Minor Modification Determination for Nonattainment Pollutants The facility is located
in Wayne County which is currently designated as nonattainment for the 1-hour NAAQS for
SO
2
. The facility is an existing major offset source for SO
2
. An increase in SO
2
emissions
above the significant level of 40 tpy will result in the proposed project being subject to
nonattainment new source review (NANSR) for SO
2
. The emission increase of SO
2
from the
proposed project is 19.5 tpy which is less than the significant level. As such, the proposed
SO
2
increase is not subject to NANSR.

Federal NESHAP Regulations - National Emission Standards for Hazardous Air Pollutants
(NESHAP) were established under 40 Code of Federal Regulations (CFR) Part 61 and
Part 63. The existing by-product recovery coke oven battery is subject to the provisions of
Subpart L (40 CFR Part 63); and the coke ovens, the pushing, soaking, quenching, and
battery stacks are subject to the provisions of Subpart CCCCC (40 CFR Part 63). The by-
product recovery plant is subject to the provisions of Subpart L (40 CFR Part 61), Subpart V
(40 CFR Part 61), and Subpart FF (40 CFR Part 61). These standards were reviewed and
permit conditions were updated to reflect any changes in the standards.

Rule 225 Toxics Analysis The MDEQ Rules for Air Pollution Control require the ambient
air concentration of any toxic air contaminant (TAC) be compared against health-based
screening levels. Air dispersion modeling was used to evaluate the impact of TAC
emissions from the proposed project. The TAC impacts from the proposed project were
significantly less than their respective initial threshold screening level (ITSL) or initial risk
screening level (IRSL), and will therefore comply with the requirements of R 336.1225
(Rule 225). For any TAC that is also a hazardous air pollutant (HAP), the provisions of
Rule 225 do not apply because a residual risk standard in Subpart L (40 CFR Part 63) has
been assessed for the by-product recovery coke oven battery.

Rule 702 VOC Emissions This rule requires an evaluation of the following four items to
determine what will result in the lowest maximum allowable emission rate of VOC:
a. BACT or a limit listed by the MDEQ on its own initiative
b. New Source Performance Standards (NSPS)
c. VOC emission rate specified in another permit
d. VOC emission rate specified in the Part 6 rules for existing sources

An evaluation of these four items determined that a VOC BACT limit per R 336.1702(a)
would dictate the lowest maximum allowable emission rate of VOC from the coke oven
battery. The analysis determined that VOC BACT is based on good combustion practices
for the underfire combustion stack on the coke oven battery and COG flare, a limit on the
volatile matter content of the coke produced, and proper operation of the PECS on the coke
oven battery.

Criteria Pollutants Modeling Analysis - Computer dispersion modeling was performed to
predict the ambient impacts of the emissions of NO
2
, PM10, PM2.5, and 3-hour SO
2
.
Emissions from the proposed facility were evaluated against both the NAAQS and the PSD
increments. The NAAQS are intended to protect public health. The PSD increments are
intended to allow industrial growth in an area, while ensuring that the area will continue to
meet the NAAQS. The maximum impacts are all below their applicable NAAQS and the
PSD increments. The air quality impact analysis is summarized in Appendix 3.

A secondary formation assessment addresses the formation of ozone from the precursors of
NO
x
and VOC, and the formation of PM2.5 from the precursors of NO
x
and SO
2
. The
secondary formation assessment is also summarized in Appendix 3.

Additional Impact Analysis An additional impact analysis is required for a major
modification pursuant to R 336.2815 (Rule 1815). This analysis is necessary to evaluate the
impacts from the proposed project for soils, vegetation, visibility and growth. The proposed
project is not anticipated to have a negative impact on soils, vegetation, visibility, and will
have no impact on growth.

Other The project will result in a significant emissions increase of NO
x
. The nearest
Class I areas (Seney, Otter Creek Wilderness Area, and Isle Royale) are located greater
than 300 kilometers from the proposed project, and notification to the Federal Land Manager
was not necessary for this project.

Key Aspects of Draft Permit Conditions

The draft permit conditions contain the emission limits, material limits, process/operational
restrictions, NESHAP requirements, monitoring, recordkeeping, and reporting requirements that
are necessary for an enforceable permit that meets all regulatory requirements. The following is
a brief discussion of the key aspects of the draft permit conditions:

NO
x
Emissions The draft permit requires that the coke oven battery operate with staged
combustion for the underfire combustion system and in accordance with best combustion
practices for the COG flare. For the underfire combustion system, the assessed BACT
emission limitations represent proper operation of the staged combustion system along with
the requirement to continuously measure the emissions of NO
x
from the underfire
combustion stack. For the PECS, the BACT emission limitations assessed represent proper
operation of the coke oven battery during pushing.

SO
2
Emissions The draft permit has both short-term and long-term SO
2
mass emission
limitations that are continuously measured on the underfire combustion stack from the coke
oven battery.

CO and VOC Emissions The draft permit has short-term emission limitations to
demonstrate good combustion control of CO and VOC emissions. Emissions of CO are
measured continuously on the underfire combustion stack from the coke oven battery.

Particulate Emissions The draft permit includes emission limitations on PM in
accordance with the original nonattainment review for the coke oven battery. Also, the draft
permit includes emission limitations on PM10 and PM2.5 to demonstrate compliance with
the air quality standards.

Usage Limits - The draft permit includes limits on the input of dry coal, heavy tar sludge and
No. 2 fuel oil charged to the battery.

Process/Operational Restrictions - The draft permit requires all emission control devices
to be installed, maintained, and operated in a satisfactory manner. Satisfactory manner
includes operating and maintaining each control device in accordance with an approved
Malfunction Abatement Plan (MAP).

Federal Regulations The draft permit includes the NESHAP requirements for emissions
of HAPs. Proper operation of the coke oven battery, control equipment, periodic emission
testing, and continuous emission monitoring will serve to make the emission limits
enforceable as a practical matter.

Emission Control Device Requirements The draft permit includes emission control
device requirements. The coke oven battery will be required to control the following:
NO
x
by staging combustion and proper operation of the coke oven battery.
Particulate emissions by good combustion practices and proper operation of the PECS
baghouse.

Testing and Monitoring Requirements The draft permit includes the following
requirements for the emission monitoring:
Verify PM, PM10, PM2.5, and VOC emission rates through performance testing.
Maintain a Continuous Emission Monitoring System (CEMS) for CO, NO
x
, and SO
2
on
the underfire combustion stack of the coke oven battery.
Maintain a Continuous Opacity Monitoring System for the underfire combustion stack of
the coke oven battery.

Coal and Coke Material Handling Systems - The draft permit includes the following
requirements for the material handling systems:
- Visible emissions monitoring.
- A fugitive dust control program outlining control measures and work practice standards
intended to minimize the opportunity for fugitive particulate emissions from vehicle traffic,
material handling, and material storage piles. The facilitys existing fugitive dust control
program will be amended to include the new material handling operations as approved
by the AQD District Supervisor.

Conclusion

Based on the analyses conducted to date, the AQD staff concludes that the proposed project
would comply with all applicable state and federal air quality requirements. The AQD staff also
concludes that this project, as proposed, would not violate any of the MDEQ rules, nor NAAQS
and PSD increments.

Based on these conclusions, the AQD staff has developed draft permit terms and conditions
which would ensure that the proposed facility design and operation are enforceable and that
sufficient monitoring, recordkeeping, and reporting would be performed by the applicant to
determine compliance with these terms and conditions. If the permit application is deemed
approvable, the delegated decision maker may determine a need for additional or revised
conditions to address issues raised during the public participation process.

If you would like additional information about this proposal, please contact Ms. Julie Brunner,
AQD, at 517-284-6789.

Appendix 1
STATE AIR REGULATIONS
State Rule Description of State Air Regulations
R 336.1201
Requires an Air Use Permit for new or modified equipment that emits, or could emit, an air
pollutant or contaminant. However, there are other rules that allow smaller emission
sources to be installed without a permit (see Rules 336.1279 through 336.1290 below).
Rule 336.1201 also states that the Department can add conditions to a permit to assure the
air laws are met.
R 336.1205
Outlines the permit conditions that are required by the federal Prevention of Significant
Deterioration (PSD) Regulations and/or Section 112 of the Clean Air Act. Also, the same
types of conditions are added to their permit when a plant is limiting their air emissions to
legally avoid these federal requirements. (See the Federal Regulations table for more
details on PSD.)
R 336.1224
New or modified equipment that emits toxic air contaminants must use the Best Available
Control Technology for Toxics (T-BACT). The T-BACT review determines what control
technology must be applied to the equipment. A T-BACT review considers energy needs,
environmental and economic impacts, and other costs. T-BACT may include a change in
the raw materials used, the design of the process, or add-on air pollution control equipment.
This rule also includes a list of instances where other regulations apply and T-BACT is not
required.
R 336.1225 to
R 336.1232
The ambient air concentration of each toxic air contaminant emitted from the project must
not exceed health-based screening levels. Initial Risk Screening Levels (IRSL) apply to
cancer-causing effects of air contaminants and Initial Threshold Screening Levels (ITSL)
apply to non-cancer effects of air contaminants. These screening levels, designed to protect
public health and the environment, are developed by Air Quality Division toxicologists
following methods in the rules and U.S. EPA risk assessment guidance.
R 336.1279 to
R 336.1290
These rules list equipment to processes that have very low emissions and do not need to
get an Air Use permit. However, these sources must meet all requirements identified in the
specific rule and other rules that apply.
R 336.1299(2)(b)
Adopts by reference the provisions of 40 CFR 63.40 to 63.44 (2002) and 40 CFR 63.50 to
63.56 (2002), the federal hazardous air pollutant regulations governing constructed or
reconstructed major sources.
R 336.1301
Limits how air emissions are allowed to look at the end of a stack. The color and intensity of
the color of the emissions is called opacity.
R 336.1331
The particulate emission limits for certain sources are listed. These limits apply to both new
and existing equipment.
R 336.1370
Material collected by air pollution control equipment, such as dust, must be disposed of in a
manner, which does not cause more air emissions.
R 336.1401 and
R 336.1402
Limit the sulfur dioxide emissions from power plants and other fuel burning equipment.
R 336.1601 to
R 336.1651
Volatile organic compounds (VOCs) are a group of chemicals found in such things as paint
solvents, degreasing materials, and gasoline. VOCs contribute to the formation of smog.
The rules set VOC limits or work practice standards for existing equipment. The limits are
based upon Reasonably Available Control Technology (RACT). RACT is required for all
equipment listed in Rules 336.1601 through 336.1651.
R 336.1702
New equipment that emits VOCs is required to install the Best Available Control Technology
(BACT). The technology is reviewed on a case-by-case basis. The VOC limits and/or work
practice standards set for a particular piece of new equipment cannot be less restrictive than
the Reasonably Available Control Technology limits for existing equipment outlined in Rules
336.1601 through 336.1651.
R 336.1801
Nitrogen oxide emission limits for larger boilers and stationary internal combustion engines
are listed.
R 336.1901
Prohibits the emission of an air contaminant in quantities that cause injurious effects to
human health and welfare, or prevent the comfortable enjoyment of life and property. As an
example, a violation may be cited if excessive amounts of odor emissions were found to be
preventing residents from enjoying outdoor activities.

STATE AIR REGULATIONS
State Rule Description of State Air Regulations
R 336.1910 Air pollution control equipment must be installed, maintained, and operated properly.
R 336.1911
When requested by the Department, a facility must develop and submit a malfunction
abatement plan (MAP). This plan is to prevent, detect, and correct malfunctions and
equipment failures.
R 336.1912
A facility is required to notify the Department if a condition arises which causes emissions
that exceed the allowable emission rate in a rule and/or permit.
R 336.2001 to
R 336.2060
Allow the Department to request that a facility test its emissions and to approve the protocol
used for these tests.
R 336.2801 to
R 336.2804
Prevention of
Significant
Deterioration
(PSD)
Regulations

Best Available
Control
Technology
(BACT)
The PSD rules allow the installation and operation of large, new sources and the
modification of existing large sources in areas that are meeting the National Ambient Air
Quality Standards (NAAQS). The regulations define what is considered a large or significant
source, or modification.
In order to assure that the area will continue to meet the NAAQS, the permit applicant must
demonstrate that it is installing the BACT. By law, BACT must consider the economic,
environmental, and energy impacts of each installation on a case-by-case basis. As a
result, BACT can be different for similar facilities.
In its permit application, the applicant identifies all air pollution control options available, the
feasibility of these options, the effectiveness of each option, and why the option proposed
represents BACT. As part of its evaluation, the Air Quality Division verifies the applicants
determination and reviews BACT determinations made for similar facilities in Michigan and
throughout the nation.
R 336.2901 to
R 336.2903 and
R 336.2908
Applies to new major stationary sources and major modifications as defined in R
336.2901. These rules contain the permitting requirements for sources located in
nonattainment areas that have the potential to emit large amounts of air pollutants. To help
the area meet the NAAQS, the applicant must install equipment that achieves the Lowest
Achievable Emission Rate (LAER). LAER is the lowest emission rate required by a federal
rule, state rule, or by a previously issued construction permit. The applicant must also
provide emission offsets, which means the applicant must remove more pollutants from the
air than the proposed equipment will emit. This can be done by reducing emissions at other
existing facilities.
As part of its evaluation, the AQD verifies that no other similar equipment throughout the
nation is required to meet a lower emission rate and verifies that proposed emission offsets
are permanent and enforceable.

FEDERAL AIR REGULATIONS
Citation Description of Federal Air Regulations or Requirements
Section 109 of the
Clean Air Act
National Ambient
Air Quality
Standards
(NAAQS)
The United States Environmental Protection Agency has set maximum permissible levels
for seven pollutants. These NAAQS are designed to protect the public health of
everyone, including the most susceptible individuals, children, the elderly, and those with
chronic respiratory ailments. The seven pollutants, called the criteria pollutants, are
carbon monoxide, lead, nitrogen dioxide, ozone, particulate matter less than 10 microns
(PM10), particulate matter less than 2.5 microns (PM2.5), and sulfur dioxide. Portions of
Michigan are currently non-attainment for either ozone or PM2.5. Further, in Michigan,
State Rules 336.1225 to 336.1232 are used to ensure the public health is protected from
other compounds.

FEDERAL AIR REGULATIONS
Citation Description of Federal Air Regulations or Requirements
40 CFR 52.21
Prevention of
Significant
Deterioration
(PSD) Regulations

Best Available
Control
Technology
(BACT)
The PSD regulations allow the installation and operation of large, new sources and the
modification of existing large sources in areas that are meeting the NAAQS. The
regulations define what is considered a large or significant source, or modification.
In order to assure that the area will continue to meet the NAAQS, the permit applicant
must demonstrate that it is installing BACT. By law, BACT must consider the economic,
environmental, and energy impacts of each installation on a case-by-case basis. As a
result, BACT can be different for similar facilities.
In its permit application, the applicant identifies all air pollution control options available,
the feasibility of these options, the effectiveness of each option, and why the option
proposed represents BACT. As part of its evaluation, the Air Quality Division verifies the
applicants determination and reviews BACT determinations made for similar facilities in
Michigan and throughout the nation.
40 CFR 60
New Source
Performance
Standards (NSPS)
The United States Environmental Protection Agency has set national standards for
specific sources of pollutants. These New Source Performance Standards (NSPS) apply
to new or modified equipment in a particular industrial category. These NSPS set
emission limits or work practice standards for over 60 categories of sources.
40 CFR 63
National
Emissions
Standards for
Hazardous Air
Pollutants
(NESHAP)
The United States Environmental Protection Agency has set national standards for
specific sources of pollutants. The National Emissions Standards for Hazardous Air
Pollutants (NESHAP) (a.k.a. Maximum Achievable Control Technology (MACT)
standards) apply to new or modified equipment in a particular industrial category. These
NESHAPs set emission limits or work practice standards for over 100 categories of
sources.

Notes: An Air Use Permit, sometimes called a Permit to Install, provides permission to emit air contaminants
up to certain specified levels. These levels are set by state and federal law, and are set to protect health and
welfare. By staying within the levels set by the permit, a facility is operating lawfully, and public health and air
quality are protected.

The Air Quality Division does not have the authority to regulate noise, local zoning, property values, off-
site truck traffic, or lighting.

These tables list the most frequently applied state and federal regulations. Not all regulations listed may be
applicable in each case. Please refer to the draft permit conditions provided to determine which regulations
apply.


Appendix 2 Best Available Control Technology Analysis
(Rule 336.2810)

By-Product Recovery Coke Oven Battery

A requirement of PSD New Source Review is a BACT analysis. For review of this application, the top-
down BACT approach per the USEPA DRAFT New Source Review Workshop Manual (October 1990)
was utilized. The top-down approach considers all available emission reduction options and proceeds
in a five-step process as follows:

1. Identify all control technologies;
2. Eliminate technically infeasible options;
3. Rank the remaining control technologies by control effectiveness;
4. Evaluate the most effective controls and document the results;
5. Select BACT (e.g., the most effective option not rejected is BACT).

BACT for NOx
NO
x
is generated thermally when nitrogen reacts with oxygen in the combustion air in a high
temperature environment, and from oxidation of organic nitrogen compounds in the fuel (fuel NO
x
).
Fuel properties have a significant impact on NO
x
formation. In a coke oven battery, metallurgical coke
is produced from the heating of bituminous coal to vaporize volatile constituents and concentrate the
carbon for steel making. NO
x
emissions result from the combustion of fuel to heat the battery, and
from the process of producing metallurgical coke from coal.

The coke oven battery consists of 85 individual ovens that are heated with an underfire combustion
system. A by-product of heating the coal to produce coke (coking) is COG. The COG from the
battery is processed on-site in the by-product recovery plant that removes tars, light oils and
ammonia. The COG is then used to heat the battery, sent to US Steel or sent offsite. Any excess
COG is combusted in the on-site COG flare. The coke oven battery was originally permitted to be
heated with a mix of blast furnace gas (BFG) and COG. Due to a system failure in the coke oven
battery, BFG is no longer combusted in the underfire combustion system that is used to heat the
battery. The combustion of only COG to heat the battery results in higher emissions of NO
x
due to the
nature of the fuel.

The coke oven battery operates at temperatures in excess of 1,800F and under positive pressure.
During the coking process, NO
x
can be emitted as fugitives from door leaks, bypass bleeder flares,
and soaking and pushing at the end of the coking process. Soaking is the start of opening a coke
oven in preparation of pushing the still hot coke out of the oven.

The proposed modification of the coke oven battery is to remove the heat input limits on the
combustion of COG and to increase the allowable coke production. The project results in a significant
increase in NO
x
emissions requiring a BACT analysis.


During the BACT analysis, several combustion and post combustion control technologies were
reviewed for the control of NO
x
emissions. Combustion and post combustion control technologies
were identified and evaluated as follows:

Process Combustion and Post Combustion Controls
Underfire Combustion
System
Staged combustion
Low-NOx Burners (LNBs)
Selective Catalytic Reduction (SCR)
Selective Non-Catalytic Reduction (SNCR)
Non-Selective Catalytic Reduction (NSCR)
EM
x
(SCONO
x
)
COG Flare and Bypass
Bleeder Flares
Good combustion practices
PECS Post combustion controls on the PECS stack
Best operating/work practice standards
Fugitive Sources Door
leaks, Soaking, Pushing
PROven (Pressure Regulated Oven)
Work practice standards

Underfire Combustion System
The review of combustion and post combustion controls for the underfire combustion system on the
coke oven battery is summarized below.

Staged combustion is commonly used on coke oven batteries to lower NO
x
emission rates. The
first stage of combustion takes place in a zone consisting of high temperature and little or no
excess air. The second stage of combustion consists of lower temperatures and more excess air.
Therefore, thermal NO
x
formation is inhibited in the first stage due to no excess air and in the
following stage due to lower combustion temperature. The NO
x
formation is minimized by
completing combustion in an air-lean environment.

LNBs control fuel and air mixing ratios in the burner in order to reduce flame temperature and
reduce thermal NO
x
formation. LNBs are used on boilers but not on coke oven batteries. The fuel
used in a coke oven battery is not combusted through burners, but in heating flues contained
within the walls that separate the individual coke ovens. This technology has not been used on
coke oven batteries and is considered a technically infeasible control alternative.

SCR is a post combustion system that can reduce NO
x
emissions at 80% to 95% efficiency. SCR
consists of an ammonia injection system and a catalytic reactor. Ammonia is injected into the flue
gas where it reacts with NO
x
in the presence of the catalyst to form molecular nitrogen and water.
This reaction occurs at flue gas temperatures of 600F to 800F. The efficiency of the SCR
system operation depends on catalyst reactivity, routine replacement of the catalyst, and
maintaining a proper ammonia injection rate. Coke ovens do not contain sections within the unit
where the temperature is consistently in the range where SCR can be effectively utilized. This
technology has not been used on coke oven batteries and is considered a technically infeasible
control alternative.


SNCR involves injecting urea or ammonia into the exhaust gases where temperatures exceed
1,500F. The urea or ammonia then reacts with NO
x
forming elemental nitrogen and water without
the need for a catalyst. Instead of a catalyzed reaction, the NO
x
reduction reactions are driven by
the thermal decomposition of urea or ammonia and the subsequent chemical reaction reduction of
NO
x
. SNCR systems can control NO
x
with efficiencies up to about 75%. The ideal temperature
window for SNCR is 1,600F to 2,100F. The temperature window and location for injecting urea
or ammonia into the gas stream is highly variable in the underfire combustion system of the coke
oven battery. Therefore, SNCR is not considered a technically feasible option for a coke oven
battery since there is not an appropriate temperature window for urea or ammonia injection and
adequate reduction of NO
x
in the exhaust gases.
NSCR is similar to an SCR but uses a different catalyst and different process conditions. NSCR
requires specific operating ranges for oxygen content, and inlet concentrations of NO
x
, CO and
VOC because the catalyst promotes the reaction of these compounds to reduce the emissions of
each. The ideal temperature window for SNCR is 800F to 1,200F. This technology has been
used for internal combustion engines, but is not considered a technically feasible control
alternative for a coke oven battery.

EM
x
(SCONO
x
) works by oxidizing nitrogen oxide to NO
2
, and collecting the NO
2
compounds as
nitrates or nitrites on a potassium carbonate catalyst bed. The catalyst bed is regenerated with
steam and a hydrogen vapor stream, to produce water and diatomic nitrogen. EM
x
(SCONO
x
)
operates best when treating gases that have a steady temperature in the range of 300F to 700F.
This technology has been used for combustion turbines, but is not considered a technically
feasible control alternative for a coke oven battery.

Staged combustion is considered the only technically feasible NO
x
control technology for this
application, and the coke oven battery currently operates using staged combustion.

The coke oven battery was originally permitted with NO
x
short-term emission limits of 563.5 pounds
per hour (pph) for combustion of rich gas (85% by volume of COG / 15% by volume of BFG) and
132.7 pph for combustion of lean gas (10% by volume of COG / 90% by volume of BFG). Also, long-
term NO
x
emission limits of 493.6 tpy of rich gas and 581.2 tpy of lean gas, and 959.5 tpy for all
combustion gases. In order to develop BACT emission limitations for this application, the current
performance of the coke oven battery was reviewed along with emission limitations from other coke
oven batteries.

It is proposed that BACT for NO
x
emissions from the underfire combustion system is based on the
combustion control technology of staged combustion. BACT is represented by emission limits of 1.25
pound per million British thermal unit (lb/MMBtu) on a 24-hour rolling average, and 0.75 lb/MMBtu on
a 12-month rolling average. To protect PSD increment and the National Ambient Air Quality Standard
(NAAQS), mass emission limits of 563.5 pph and 1,411 tpy on a 12-month rolling time period will
apply at all times. Compliance with these limits will be monitored using a NO
x
CEMS to measure NO
x

emissions in the exhaust gas from the underfire combustion stack.

COG Flare and Bypass Bleeder Flares
The COG flare is used to combust excess COG that is not used in the underfire combustion system of
the coke oven battery and by other offsite sources. The flare oxidizes sulfur and organic compounds,
and the only feasible alternative to reduce NO
x
emissions is to operate the flare according to good
combustion practices. Good combustion practices include proper maintenance and operation of the
flare, and maintaining an automatic ignition system.


The individual coke ovens are equipped with bypass bleeder flares so that emissions of raw COG are
not released to the ambient air during the coking process. Good combustion practices and
maintaining an automatic ignition system are used on the bypass bleeder flares.

PECS
When a coke oven has completed coking the coal, the oven doors are removed and the still hot coke
is pushed out the side of the battery. The emissions from pushing are captured by a hood and
directed to a baghouse. The exhaust gas temperature of the pushing emissions control system is
approximately 110F. This temperature is below the feasible temperatures of any post combustion
controls for NO
x
. Best operating/work practice standards are used while pushing to minimize NO
x

emissions. These standards include not pushing coke out of the oven until the coking cycle is
complete, and emissions due to coking are minimized. Based on stack testing from the PECS stack, a
NO
x
emission limit of 2.61 pph was assessed as BACT and protective of PSD increment and NAAQS.
Compliance with the NO
x
emission limit will be demonstrated through stack testing of the PECS every
two (2) years.

Fugitive Sources
NO
x
can be emitted from many fugitive sources on the coke oven battery such as door leaks, soaking,
and pushing. During the coking cycle, the PROven technology has been utilized on coke oven
batteries. This technology regulates the pressure within each oven chamber to minimize fugitive
leaks. Since this technology is built into the design of a coke oven battery, this technology is not
technically feasible on the existing coke oven battery. Work practice standards such as repairing and
maintaining doors, door seals, and jambs minimize fugitive leaks from the coke ovens during coking,
and proper maintenance of the PECS. Fugitive emissions from soaking and pushing are also
minimized through not pushing coke out of the oven until the coking cycle is complete.

BACT for GHGs (as CO
2
e)
GHGs are generated when fuel is combusted. GHGs are regulated as a single air pollutant defined
as the aggregate mix of six well-mixed GHGs. The six GHGs are carbon dioxide (CO
2
), methane
(CH
4
), nitrous oxide (N
2
O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF
6
). Some of these GHGs have a higher global warming potential than others. To
address this, GHGs are converted to carbon dioxide equivalents (CO
2
e). Emissions of gases other
than CO
2
are translated into CO
2
e by using the gases global warming potential. Total GHG emissions
are calculated by summing the CO
2
e emissions of all six constituent GHGs. Efficient combustion
results in the conversion of carbon in the fuel to CO and CO
2
, with only trace amounts of CH
4
and
N
2
O. HFCs, PFCs, and SF
6
are not produced with the combustion of COG. Since CH
4
and N
2
O have
higher global warming potential, less efficient combustion results in higher CO
2
e emissions.
Combustion of BFG in the underfire combustion system of the coke oven battery results in higher
emissions of CO
2
then when combusting COG. Since BFG can no longer be combusted to heat the
battery, a reduction in GHGs will occur with the proposed increase in combustion of COG. The BFG
that is no longer being combusted in the battery will be used to heat various processes at US Steel or
flared at US Steel causing a net increase of GHGs for the proposed project.

A BACT analysis is required for each proposed emission unit at which a net emissions increase in the
pollutant will occur as a result of a physical change or change in method of operation. The coke oven
battery is undergoing a change in the method of operation that results in a net reduction of GHG
emissions. Therefore, BACT does not apply to the emission of GHGs from the coke oven battery.
BACT also does not apply to emission units at US Steel that combust BFG. A physical change or
change in the method of operation is not occurring at US Steel due to the combustion of BFG.
Therefore, a BACT analysis for GHGs is not required for any emission units affected by the proposed
project.


Appendix 3 - Air Quality Impact Analysis
(R 336.2803, R 336.2804, 40 CFR 52.21(c) and (d))

For this project, the air quality impact analysis involves modeling of NO
2
, SO
2
, PM10, and PM2.5
emissions against the PSD increment and the NAAQS. The air quality impact analysis is performed in
two phases: (1) a preliminary analysis, and (2) a full impact analysis. The preliminary analysis models
only the increase in potential emissions from the proposed modification.

PRELIMINARY ANALYSIS

The USEPA has promulgated significant impact levels (SIL) for a majority of the criteria pollutants. If
the modeled ambient air impact, for each pollutant is less than the SIL, the emissions for that pollutant
will not be considered to cause or contribute to any violation of the federal air quality standards. If the
results determine the modeled impacts exceed the SIL, then a facility-wide NAAQS and PSD
increment modeling analysis is required.

Use of the SIL for PM2.5 needs additional consideration due to recent federal court action. The
USEPA guidance issued March 4, 2013, which states that if the SIL is less than the difference
between the background concentration and the NAAQS, this is sufficient for the permitting authority to
determine that a source with a PM2.5 modeled impact less than the SIL will not cause or contribute to
a violation of the NAAQS. In this case, the PM2.5 SILs qualify for this purpose, for these reasons:

1. The court decision does not preclude the use of SILs for PM2.5, but requires that the USEPA
correct the error in the SIL regulations for PM2.5 in 40 CFR 51.166(k)(2) and 40 CFR 52.21(k)(2).
In the interim, the USEPA believes permitting authorities may continue to apply SILs for PM2.5 to
support a permitting decision;
2. The regional background, as defined by the most representative monitor is 26.1 g/m
3
(24-hr) and
11.4 g/m
3
(annual);
3. The addition of net impacts less than the SIL (1.2 g/m
3
24-hr and 0.3 g/m
3
annual) will be less
than the NAAQS (35 g/m
3
24-hr and 12 g/m
3
annual).

If it can be demonstrated that the project emissions will not increase ambient concentrations by more
than the prescribed SIL shown below in Table 1, no further modeling is required.

TABLE 1
PRELIMINARY ANALYSIS
Pollutant
Averaging
Time
SIL
(g/m
3
)
Predicted
Impact (g/m
3
)
Additional
Modeling?
NO
2
1-hr 7.6 6.78 None
NO
2
Annual 1 0.46 None
SO
2
3-hr 25 3.71 None
PM2.5* 24-hr 1.2 0.92 None
PM2.5* Annual 0.3 0.22 None
PM10 24-hr 5 3.97 None
* The PM2.5 significant impact levels were vacated and remanded by the U.S. Court of Appeals on
January 22, 2013.

Preliminary modeling for the project indicates that NO
2
, SO
2
, PM10, and PM2.5 ambient impacts from
the project will be below the respective SIL, and a full impact analysis is not required.


SECONDARY FORMATION ASSESSMENT

The USEPAs draft guidance specifies that only the secondary impacts of significant precursor
emissions need to be assessed. For this project, NO
x
emissions exceed the significant threshold of
40 tpy and NO
x
is a precursor to the formation of PM2.5 and ozone.

The following methodology is consistent with the USEPAs guidance for conducting a qualitative
analysis for the purpose of demonstrating that the secondary formation of PM2.5 and ozone from the
NO
x
precursor will not cause or significantly contribute to a violation of the NAAQS.

For PM2.5, recent examples of secondary pollutant impacts from the USEPA demonstrate that the
use of the interpollutant trading ratio (ITR) for NO
x
is adequate to demonstrate compliance with
secondary PM2.5 impacts. The trading ratio for NO
x
to PM2.5 is generally accepted to be 200 to 1.
This means that for every 200 tons of NO
x
emitted, 1 ton can be assumed to convert to secondary
PM2.5. As such, the secondary PM2.5 impact can be determined by reducing the NO
x
predicted
impact by the 200 to 1 ratio. Table 2 demonstrates possible secondary PM2.5 impacts.

TABLE 2
ANALYSIS OF SECONDARY PM2.5 IMPACTS
Parameter
Short-Term Impact
(g/m
3
)
Long-Term Impact
(g/m
3
)
Direct emissions PM2.5 impact 0.92 0.22
NO
x
ITR 200/1 conversion to secondary PM2.5 0.034 0.002
Combined PM2.5 impact (direct + secondary) 0.95 0.22

PM2.5 24-hour and annual SIL 1.2 0.3

Based on the above analysis, the proposed project is predicted to have an insignificant impact on the
formation of secondary PM2.5.

For ozone, the USEPA Cross-State Air Pollution Rule (CSAPR) modeling was used to approximate a
single source ozone impact. The CSAPR analysis looked at the emissions difference between a
current base case and a future control scenario and predicted an ozone reduction via a photochemical
model. For this project, a ratio was applied to the calculated CSAPR ozone reduction (0.3 ppb) using
the project NO
x
increase (668 tpy) and the CSAPR NO
x
decrease (6,799 tpy). The projected increase
in ozone from the project was calculated as follows: 668/6,799 x 0.3 ppb = 0.029 ppb. This impact is
added to the design value (DV) of the most representative monitor (Allen Park) for comparison to the
NAAQS.

TABLE 3
ANALYSIS OF SECONDARY OZONE IMPACTS
Parameter 8-Hour Impact (ppb)
Allen Park monitor DV (2011-2013) 72.0
Predicted ozone impact 0.029
Combined ozone impact (DV + secondary) 72.03

Ozone 8-hour NAAQS threshold 75

Based on the above analysis, the proposed project is predicted to have an insignificant impact on the
formation of ozone.

DTE Energy/EES Coke PTI 51-08C FactSheet

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

DTE Energy/EES Coke PTI 51-08C FactSheet

Uploaded by

Copyright:

Available Formats

STATE OF MICHIGAN

Rick Snyder, Governor

You might also like