Tues, June 1, 2004 FDS Coke oven Sent by email with attachments To: Matthew_Stanfield@ohio.epa.state.oh.us, sudhir.singhal@epa.state.oh.us, mike.hopkins@epa.state.oh.us, Karen.Granata@ci.toledo.oh.us, Tom.Tucker@epa.state.oh.us, Robert_Kossow@ohio.epa.state.oh.us, bill.spires@epa.state.oh.us From: Alex J. Sagady & Associates Dear Matt, Sudhir, Mike, Karen, Tom, Bob and Bill: I'm a firm believer in the old saying that "haste makes waste" and what is occurring with the air PTI permitting process with the FDS Coke ovens may ultimately reaffirm my faith in that old saying. I don't think anyone in Ohio EPA/Toledo has yet sought out any of the lessons learned in Indiana at the nonrecovery coke oven there in the haste to issue this proposed permit.....a facility just slightly larger than the proposed FDS plant and more representative than the Jewell facility. A long phone conversation with the IDEM inspector of the Indiana Harbor Coke Co. peaked my interest and I spent some time down in Indianapolis doing a file review on that plant. The sponsors of the Indiana Harbor facility gave the same song and dance that we are hearing now from FDS at the time of their original permitting..... no door leaks, very limited uncontrolled venting, good control of charging emissions, no green pushes, etc. etc. But the Indiana Harbor plant owners didn't meet these expectations. Because of failure to properly size the common, refractory lined exhaust tunnel, failure to properly size ductwork from heat recovery steam generators and induced draft fans, variability in coal volatility content, deposits on HRSG heat transfer surfaces and failure to install soot blowing equipment and HRSG downtime, failures to have in place proper staging procedures on charging operations, little or no margin on the overall CFMs in the exhaust system in light of potential adverse operating scenarios and coal volatility variability, etc..... the sponsors of this facility in Indiana sought relaxation of their permit to allow much more emission control bypass than was ever thought possible at the time of permitting....up to 19% on a 24 hr basis and up to 14% annual basis. None of your air quality assessments and BACT determinations on venting come close to considering this level of venting. Between Sandra Bihn and myself we have sought disclosure of all materials held by Matt and there is nothing in the file in Toledo which would come anywhere near to being close to giving strong technical detail to how FDS would avoid these problems in Toledo/Oregon. There are no detailed technical specifications for that common exhaust tunnel which is, for all practical purposes, an air pollution control device and no exposition of the margins of operating scenarios for this equipment in terms of CFMs for negative pressure operation. If you'd like you can talk with the IDEM inspector... Dave Sampias, 219 757 0265 I am attaching two documents.....one is the "venting report" on how and why Indiana Harbor ran into problems on this count.....the other is a charming little incident of 168 hours of venting by all 16 of the duct vents at Indiana Harbor after a power outage. Indiana Harbor Venting Report, Indiana Harbor Coke Company, Cokenergy Inc., Radian International, Oct 18, 2000, 536 KB pdf. Malfunction Report, Indiana Harbor Coke Company, East Chicago, Indiana, to Office of Air Managementr, Indiana Department of Environmental Mnagaement, Oct 29, 1999, 66 KB pdf. I also have all of the stack test summaries and the IDEM test evaluations that were done at that site. Indiana Harbor, by the way, shows that condensible PM is a much greater problem than was ever indicated by the Jewell plant and AP-42 data. It seems there is an inherent conflict between the need to generate steam and run with high volatility coal vs. spiking PM emissions and permit compliance. Given that Ohio EPA and Toledo Environmental Services never sought any information to be submitted at all about coal to be charged at FDS, this lack of information should give some pause on the condensible PM issue (as well as the possibility that this source is major for HAPs as a result of HCl and HF not being considered). Anyway, I thought this would be a nice way to start a Tuesday after the memorial day holiday. I hope that the FDS people and your top managers did not have you working through the weekend on this permit. Please make this email note and the attached files part of the public comment record. We will be submitting detailed technical comments by about 3 PM on 6/3 to Matt and Sudhir. [I'm hoping that I don't have problems with Ohio EPA's email filter...like I did a couple of months ago when I tried to submit comments on a proposed Title V permit at BP in Lima]. Regards, Alex Sagady Environmental Consultant to Sierra Club Ohio Chapter Alex J. Sagady & Associates Environmental Enforcement, Permit/Technical Review, Public Policy, Evidence Review and Litigation Investigation on Air, Water and Waste/Community Environmental and Resource Protection. Prospectus. P.O. Box 39 East Lansing, MI 48826-0039 (517) 332-6971 (517) 332-8987 (fax)