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What counts as a foundry coke plant?
Here, a foundry coke plant is a facility that produces foundry coke—not an iron and steel foundry, where metal is melted and poured into castings. EPA’s May 2008 AP-42 emission-factor documentation uses a specific definition for NESHAP purposes: foundry coke is made from raw materials containing less than 26 percent volatile material by weight and undergoes a coking period of 24 hours or more. Under that same definition, a foundry-coke by-product recovery plant serves batteries for which at least 75 percent of annual coke production is foundry coke. These are regulatory categories, not universal commercial definitions.
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Air emissions can arise at many points in coke production, not just from a stack. The equipment and sources present vary with the process configuration and how the plant operates. EPA’s AP-42 Chapter 12.2, a July 2007 draft technical reference, describes emissions and example controls; it is not current regulatory text and does not establish that every example is required or appropriate at every facility.
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Where emissions arise and what pollutants are involved
EPA identifies particulate matter (PM), sulfur dioxide (SO2), nitrogen oxides (NOx), and organic compounds such as volatile organic compounds (VOCs) and polycyclic organic matter (POM) among coke-production emissions. Organic hazardous air pollutants (HAPs) identified in EPA materials include benzene, toluene, xylenes, cyanide compounds, naphthalene, phenol, and POM. EPA’s current coke-oven rule summary also describes amendments addressing benzene, mercury, lead, and arsenic. A pollutant’s presence and release point depend on the plant; these lists do not mean that every compound is emitted at every facility or at every process step.
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| Operation or source | Emissions EPA identifies | Example control approach |
|---|---|---|
| Coal unloading, storage, transfer, crushing, screening, mixing, and blending | PM from handling and preparation | Use cyclones or traveling hoods connected to a baghouse where appropriate. |
| Charging and oven operation | PM and organic emissions, including releases from oven leaks; EPA also identifies SO2, NOx, and carbon monoxide from oven leaks | Use staged charging and steam aspiration to reduce charging leaks; seal leaking doors, lids, and offtakes; maintain oven walls. |
| Pushing and coke-side door areas | PM and VOCs, including emissions associated with pushing and leaks | Capture emissions in a coke-side shed and route them to a PM control device, typically a baghouse. A hooded quench car with a scrubber or baghouse is another EPA-described option for pushing and travel to the quench area. |
| Hot-coke quenching | PM and VOCs | Use quench-tower baffles to impede particulate flow and clean quench water. |
| Combustion stacks | PM, SO2, and NOx are among the pollutants identified for coke production | Maintain oven walls and use devices such as electrostatic precipitators (ESPs) or baghouses for PM where suitable. |
| Bleeder or bypass stack | Gaseous emissions | A flare may be used to control gaseous emissions from a bleeder or bypass stack. |
| Coke crushing, sizing, screening, handling, and storage | PM from coke handling | Use cyclones or traveling hoods ducted to a baghouse where appropriate. |
| Ancillary operations, such as boilers, wastewater treatment, cooling towers, and roads | Emissions vary by source and operation | Assess these sources individually; a coke-oven control device may not address them. |
How controls work: prevent, capture, then treat
Prevent or reduce releases at the source
Operating and maintenance practices reduce emissions before they need to be collected. EPA’s AP-42 examples include staged charging and steam aspiration to reduce charging leaks, sealing leaking joints at doors, lids, and offtakes, and maintaining oven walls. At quench towers, baffles impede particulate movement and clean quench water is an identified control measure. The right combination depends on the operation and applicable requirements.
Capture emissions close to the operation
Capture equipment gathers emissions that would otherwise escape into the work area or outdoors. A coke-side shed can collect pushing emissions and coke-side door leaks and duct them to a PM control device. A hooded quench car is another described way to capture PM during pushing and while coke travels toward quenching. Hoods and ducts only help control the emissions they actually capture, so coverage and operation matter as much as the downstream device.
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Treat the captured stream
A baghouse filters particles from a ducted gas stream; ESPs remove particles using an electrical charge, and scrubbers use liquid contact to remove pollutants from a gas stream. EPA also identifies cyclones for handling-related dust and flares as an option for gaseous emissions from a bleeder or bypass stack. These devices address different streams and pollutants, so they are not interchangeable by default.
There is no universally best device established by the cited EPA material. A plant-specific selection should account for process configuration (including by-product or heat-recovery non-recovery operation), emission point and pollutant, capture coverage, control-device suitability, operating and maintenance needs, applicable rule or permit, and the method used to demonstrate compliance. EPA’s technical reference gives examples, not a current plant-by-plant performance ranking or a general control-efficiency percentage.
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What emissions monitoring measures—and what it does not
“Monitoring emissions” can mean different measurements and reporting programs. EPA’s Coke Ovens Batteries NESHAP summary describes requirements for coke-oven leaks and benzene at the facility fenceline. These measurements do not serve the same purpose as greenhouse-gas reporting, nor should a result from one be treated as a substitute for another.
| Monitoring or reporting activity | What EPA describes | What it is for |
|---|---|---|
| Oven door, lid, and offtake leak provisions | The 2024 amendments described by EPA include lower leak limits for doors, lids, and offtakes. | Assess compliance with coke-oven leak requirements. |
| High-temperature non-recovery provisions | EPA’s NESHAP summary describes a zero-percent door-leak limit and pressure monitoring for applicable high-temperature non-recovery batteries. | Address requirements specific to those batteries; do not assume they apply to every coke-oven configuration. |
| Benzene fenceline monitoring | The rule summary describes a work-practice action level and corrective action after an exceedance. | Identify and respond to benzene concentrations at the fenceline under the applicable rule provisions. |
| Performance tests and compliance reports | EPA describes electronic reporting of performance-test results and compliance reports, and removal of startup, shutdown, and malfunction exemptions. | Document testing and compliance under the applicable standards. |
| Greenhouse-gas reporting under Subpart Q | For applicable process CO2, EPA’s Subpart Q information sheet describes continuous emissions monitoring systems (CEMS), carbon mass balance, or site-specific emission-factor methods, subject to the rule’s details. Reporting includes unit identification, annual emissions, production capacity, and operating hours, with additional information depending on the method. | Report greenhouse-gas emissions under that program; it is not a replacement for HAP leak observations, benzene fenceline monitoring, or performance tests. |
EPA’s Subpart Q guidance identifies process CO2 from specified iron and steel processes, including non-recovery coke-oven battery combustion stacks and coke pushing. The reporting method and required information depend on the applicable rule provisions and selected method. A plant’s greenhouse-gas reports therefore answer a different question from whether it has met coke-oven HAP controls.
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How to check which requirements apply today
EPA’s coke-oven rule pages say that a 2025 final rule withdrew the interim final rule issued July 8, 2025, which had extended compliance deadlines for the 2024 coke-oven standards and related requirements. EPA’s rule-summary page lists the final rule on October 2, 2025. The interim extension should not be presented as the current deadline status.
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- Identify the facility and process configuration, including whether the relevant operation is a by-product or non-recovery battery.
- Determine which current federal standards cover the battery and its emission points; use the current CFR text and EPA rule documents rather than relying on a technical emissions reference for legal obligations.
- Review the facility air permit and jurisdiction-specific requirements for monitoring, reporting, and deadlines.
- Match each required observation, test, or report to the pollutant and emission point it addresses; do not treat Subpart Q CO2 reporting as proof of compliance with HAP requirements.
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