Model Clearinghouse Information Storage and Retrieval System
Record Details

Issue:  EPA Region 3 is seeking concurrence from the Model Clearinghouse 
on an alternative modeling approach using a combination of the Buoyant 
Line and Point Source model (BLP) and the American Meteorological 
Society/Environmental Protection Agency Regulatory Model (AERMOD) to 
represent fugitive emissions from these four coke oven batteries at the
AK Steel – Mountain State Carbon, LLC Follansbee Plant (Mountain State 
Carbon) located in Follansbee, West Virginia. The proposed alternative 
modeling approach was applied in West Virginia’s 2010 1-hour SO2 National 
Ambient Air Quality Standard (NAAQS) Nonattainment Area State 
Implementation Plan (SIP) for the Steubenville, Ohio-West Virginia multi-
state nonattainment area. EPA Region 3 is seeking Model Clearinghouse 
concurrence with this alternative model approval based on the Model 
Clearinghouse’s recent action for using the BLP/AERMOD Hybrid technique 
for U. S. Steel Corporation’s Clairton Plant located in the City of 
Clairton, Allegheny County, Pennsylvania. Both facilities utilized similar 
alternative model approaches to simulate their coke oven fugitive 
emissions. Additionally, coking operations at both facilities are nearly 
identical, both facilities are located in similar terrain settings and 
both facilities are subject to complex terrain-induced wind patterns. 
These similarities are the basis for this concurrence request.

C/H Response:  The Model Clearinghouse has reviewed the model attainment 
demonstration included in the West Virginia 2010 1-hour SO2 NAAQS 
Nonattainment Area SIP for the Steubenville, Ohio-West Virginia multi
-state nonattainment area and associated EPA Region 3 technical assessment 
for the use of the alternative BLP/AERMOD Hybrid Approach for the 
assessment of the fugitive coke oven battery emissions at the Mountain 
State Carbon facility in Follansbee, West Virginia. The Model Clearinghouse 
finds that the requirements and recommendations of Section 3.2 of the 
Guideline were previously met for the BLP/AERMOD Hybrid method in the case 
of the U.S. Steel Mon Valley Works - Clairton Plant situation. Furthermore, 
a justifiable basis has been provided by EPA Region 3 for the application 
of this previously case-specific approved alternative model at the AK Steel 
– Mountain State Carbon, LLC Follansbee Plant given the unique similarities 
between the emissions sources at these two facilities, the similarities in 
complex topographical and meteorological settings surrounding these two 
facilities, and the similarities in alternative modeling approach for 
assessing the fugitive emissions from the coke oven batteries at 
these two facilities. The Model Clearinghouse hereby concurs with EPA 
Region 3 on the alternative model approval for the West Virginia SIP.

Memo:  Model Clearinghouse Review of the BLP/AERMOD Hybrid Alternative Model 
Approach for Modeling Fugitive Emissions from Coke Oven Batteries at the 
AK Steel – Mountain State Carbon facility located in Follansbee, Brooke County,
West Virginia
        Dated: October 26, 2018
        From:  George Bridgers, Model Clearinghouse Director
                 Air Quality Modeling Group, Air Quality Assessment Division, 
                 Office of Air Quality Planning and Standards
        To:    Timothy A. Leon Guerrero, Meteorologist
                 Office of Air Monitoring and Analysis, Air Protection Division, 
                 EPA Region 3
	       Alice Chow, Associate Director
                 Office of Air Monitoring and Analysis, Air Protection Division, 
                 EPA Region 3

Memo:  Concurrence Request for Approval of Alternative Model: BLP/AERMOD Hybrid 
Approach for Modeling Fugitive Emissions from Coke Oven Batteries at the 
AK Steel – Mountain State Carbon facility located in Follansbee, Brooke County,
West Virginia
        Dated: October 18, 2018
        From:  Timothy A. Leon Guerrero, Meteorologist
                 Office of Air Monitoring and Analysis, Air Protection Division, 
                 EPA Region 3
        Thru:  Alice Chow, Associate Director
                 Office of Air Monitoring and Analysis, Air Protection Division, 
                 EPA Region 3
        To:    George Bridgers, Model Clearinghouse Director
                 Air Quality Modeling Group, Air Quality Assessment Division, 
                 Office of Air Quality Planning and Standards