Hazardous Air Pollutants

Coke-Oven Pushing, Quenching,

and Battery Stacks

 

On April 14, 2003, the EPA published a final NESHAP for Coke Oven Pushing, Quenching and Battery Stack operations (68 FR18007].  The regulations apply to sources at Coke Plants that are also Major Hazardous Air Pollutant (HAP) Sources.

 

Major sources are those that emit 10 tons per year (TPY) of a single HAP or 25 TPY of a combination of HAPS.

 

The MACT Establishes:

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Emission limitations

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Work practice standards

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O&M requirements

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Initial & continuous compliance requirements

 

The compliance dates are:

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Existing sources by April 14, 2006

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New sources upon startup

 

Pushing:

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Limit: 0.01 gr/dscf  for a coke side shed

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Limit: 0.02 gr/dscf for a moveable hood vented to a control device

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Limit: 0.03 lb/ton or 0.01 lb/ton for mobile scrubber cars that do not capture during travel for a short or long battery, respectively

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Limit: 0.04 lb/ton for mobile scrubber car that does capture during travel

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A Venturi scrubber will require daily average pressure drop and scrubber water flow rate measurements

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A hot water scrubber will require daily average water pressure and water temperature measurements

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Each capture system will require daily average fan motor amperage or volumetric flow rate measurements at the inlet to the control device

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A baghouse will require a bag leak detection system, differential pressure monitoring across each cell daily, and visual inspections weekly and monthly

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Prepare a plan with procedures for inspections, preventative maintenance, and corrective actions for control device

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Prepare a written plan to minimize incomplete coking

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Conduct tests of any control device at least twice every 5 years

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Include compliance information in Semiannual Report

 

Quenching:

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Limit for quench water TDS of 1,100 mg/L or a site specific limit for the sum of benzene, benzo(a)pyrene and naphthalene

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Must use acceptable quench water

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Must allow no more than 5% of cross sectional area of tower to be open

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Must wash baffles once/day (if temp. > 30°F)

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Must continuously record ambient temperature on days baffles not washed

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Implement a baffle inspection, repair & replacement program

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Must conduct testing for TDS or alternative site specific limit

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Include compliance information in Semiannual Report

 

Battery Stacks:

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Install Continuous Opacity Monitoring Systems (COMS)

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Limit: < 15% for normal coking cycle, daily average

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Limit < 20% for extended coking cycle, daily average

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Prepare Quarterly Reports

 

Soaking:

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Prepare a Work Practice Plan

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Train operators to recognize emissions that need corrective action

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Damper the Oven off the collector Main prior to opening standpipe

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Take corrective actions for emissions of collector main or notify responsible party if emissions are caused by incomplete coking

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Include compliance information in Semiannual Report (SA)

 

General:
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Sources will be required to prepare written Startup, Shutdown and Malfunction (SSM) Plans

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Includes procedures for operating and a program of corrective action for malfunctioning process and air pollution control equipment

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Specific reporting requirements for malfunction events

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Include compliance information in SA Report

 

 Link to more info

Authors Jill Merrill, President and Nancy Hirko, Senior Environmental Engineer

Date:  05/16/03

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