Respondent owns and operates a coke oven in Tonawanda, NY. The facility was inspected during the week of April 13, 2009 and reinspected for compliance with NESHAP Part 61 Subpart L the week of October 11, 2010. Numerous violations of both the NESHAPs and the MACT were found. Respondent became a furnace manufacturer in 2007 and 2008 and therefore, a number of process tanks previously not controlled were now required to be controlled. Also, the Respondent did not implement a proper LDAR program to detect equipment leaks. For the BWON requirements, the Respondent failed to identify all the waste streams to determine the facility TAB. With respect to the MACT regulations, the Respondent failed to document when repairs were made to leaks in the collector main and failed to provide annual refresher training to the coke oven operators. Respondent also failed to submit test protocol to complete emissions testing on the main under-fire stack, the boiler stack and for the ammonia stripper inlet waste and failed to submit a QAPP for DIAL testing at the coke oven. This order requires the Respondent to conduct work practice standards and improve equipment in the facility's by-product plant.