GLIN==> Toledo/Oregon, OH coke oven issue

["Alex J. Sagady & Associates" <ajs@sagady.com>]

Yesterday, Ohio EPA issued an air permit to install for
the U.S. Coking Group proposed coke oven to be sited on
Maumee Bay of Lake Erie in Oregon/Toledo, OH.

Today's Toledo Blade has an article on this decision:

http://www.toledoblade.com/apps/pbcs.dll/article?AID=/20040615/NEWS06/406150357/-1/NEWS

This plant was originally projected to emit 680 lbs of mercury
and no mercury emission limitation was provided in the proposed permit.
The proposed permit also envisioned up to 336 hours of uncontrolled
venting emissions per month.

Ohio EPA revised the proposal to incorporate the following as
quoted from the Ohio EPA responsiveness summary:

"Ohio EPA/TDES decided to establish best available technology (BAT) limits 
for mercury. The
final permit contains a limit of 36 pounds of mercury per year. In addition 
to setting these
limits, Ohio EPA/TDES decided to require FDS Coke to have mercury testing 
done at another
similar facility prior to beginning construction of the FDS Coke facility. 
Based on the results of
this testing, the BAT limits we have established for FDS Coke may be 
adjusted downward. The
reason we required this testing to be done is because there is virtually no 
data available
concerning the expected emissions of mercury from coke plants.

In addition to the preconstruction testing, Ohio EPA/TDES is requiring FDS 
Coke to do the
following concerning mercury:

1. Conduct initial and periodic emissions testing for mercury following 
precise U.S. EPA
approved methods.

2. On an ongoing basis, analyze the coal that is used in the process for 
mercury and
chlorine content. (Some data suggests that the chlorine content may affect 
the resulting
mercury emissions.)

3. Install, calibrate and operate a continuous emissions monitor for 
mercury. This device
will measure the amount of mercury in the exhaust stack on a continuous basis.

Based on all of the above mercury requirements, Ohio EPA/TDES believes that 
the permit will:

1. Protect public health and welfare by limiting the allowed mercury 
emissions to
insignificant levels.

2. Put in place mechanisms to better quantify expected emissions of mercury 
from coke
facilities.

3. Meet the expectations of the 1988 Great Lakes States Air Permitting 
Agreement
concerning mercury emissions (see the response to comment number 178 for 
more details
on this issue)."

Ohio EPA is claiming this is the first time a mercury emission limitation has
ever been imposed on a coke oven in the U.S.

I'm still reviewing the final permit and summary, but Ohio EPA also
apparently decided to disallow uncontrolled venting from the proposed
plant as being inconsistent with a PSD BACT determination.

At this writing, the company has not yet said whether
they will accept or contest the Ohio EPA permit decision with an appeal.

Ohio EPA added a requirement to test for hydrogen chloride/HF and PCDD/PCDF.

The responsiveness summary is now posted at:
http://www.epa.state.oh.us/pic/citizen/response/uscoke_air_june04.pdf

The pti is now posted at:
http://www.epa.state.oh.us/pic/citizen/response/uscoke_air_pti_june04.pdf



==========================================
Alex J. Sagady & Associates        http://www.sagady.com

Environmental Enforcement, Permit/Technical Review, Public Policy,
Evidence Review and Litigation Investigation on Air, Water and
Waste/Community Environmental and Resource Protection
Prospectus at:  http://www.sagady.com/sagady.pdf

PO Box 39,  East Lansing, MI  48826-0039
(517) 332-6971; (517) 332-8987 (fax); ajs@sagady.com
==========================================



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