1/25/21 - CD FILED BY THE COURT - ABC Coke produces metallurgical coke and has 2 related industrial processes at its facility including the coke battery process, which is a series of coke ovens where coal is heated to create coke, and the coke byproduct recovery process where coke oven gas produced during the coking process is piped from the coke batteries for further processing. Coke oven gas is a HAP as specified in Section 112 of CAA and contains benzene, toluene, and xylene. The coke byproduct recovery plant processes the coke oven gas so that it can be re-used as fuel to heat boilers in the coke making process. Other re-usable chemical byproducts resulting from the coke byproduct recovery process are sold to various industries, including steelmaking, oil, and agriculture. In 2011, EPA R4, EPA?s NEIC and JCBH conducted an inspection at the facility as part of the EPA Air Toxics National Initiative. Based on the inspection, EPA and JCBH alleged that the byproduct plant was out of compliance EPA and JCBH conducted additional inspections of the coke byproduct recovery process in 2014 and 2018.
The purpose of Subparts L and V are to control and reduce fugitive emissions of HAPs and VOCs that can occur during the coke byproduct recovery process. The regulations require ABC Coke to regularly monitor equipment and components such as valves, pumps, connectors, flanges, and tanks for emissions of HAPs and VOCs that exceed established leak threshold concentrations. Facilities