From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Thursday, August 20, 2015 1:14:58 PM
To: 
David Ailor [mailto:dailor@accci.org]
Subject: 
first complete draft of ICR for coke 08-20-15 - for industry review


David - Attached is the first complete DRAFT of the ICR for your and the industry's review. This will be undergoing internal division review at the same time. I can let you take as much time in your review as it takes for EPA to do our review. But in order to not get caught short, it would be a good idea to send me comments as they come in. I'm looking for both editorial as well as technical comments, but you can assume that EPA will catch most of the editorial corrections. I am looking corrections for clarity as well, so these corrections may be editorial in nature.

I am sorry that I missed the spring version we had discussed. I had planned on sending you the test tables only in the spring, as I recall. Unfortunately, we were still discussing these test tables until just recently therefore I was prevented from sending it to you any earlier. As I mentioned in my previous email (below), I am looking for industry-wide issues with any of the requests, for testing or for information. If any one facility has a particular situation that doesn't fit under this ICR, I can work with them after the ICR goes out.

You can make your edits in the text, in redline/strikeout or in a separate document. If you use a separate document, please make sure you identify which enclosure and which question. Also , referring to the page, e.g., page x of y, is helpful as well.

Let me know if you have any questions, at any point in this process. As an fyi - this ICR for coke is similar in scope to the ICR  I sent and received from the Integrated Steel industry. However, due to a petition issue, I needed to send the steel ICR, both questionnaire and testing, to all facilities.

Regards,
Donna Lee Jones, Ph.D.
Senior Technical Advisor, Metals Sector
U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards Sector Policies and Programs Division / Metals & Inorganic Chemicals Group (D243-02) Research Triangle Park, NC  27711  Tele:  (919)  541-5251  Fax  (919)  541-3207 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
"Reasonableness never fails to be appreciated."  - anon.


<< Coke ICR Intro&Enclosure I-DRAFT-08-20-15.docx >>
<< Coke ICR-Enclosure 2-DRAFT-8-20-15.doc >>



________________________________________
From: Jones, DonnaLee
Sent: Wednesday, August 19, 2015 5:33 PM
To: David Ailor
Subject: RE: Parent Company representatives and mailing addresses

Thanks for your offer to help. We don't have much flexibility in the timing. If I had sent this to you in the spring it just would have gone out sooner. We don't usually leave a big period of time for industry review. What we are looking for in any industry review is not to reach consensus with industry but for industry to correct any technical errors and any industry-wide testing difficulties that would need to be accommodated for everyone. We can work with any one facility on their special situation after we send the ICR out. One example of a technical correction is my recent question as to whether to ask for tons of coke pushed or coal charged. So I am looking for more of a technical proofread which one could do on one read through. Hope this simplifies the task somewhat.

_____________________________________________________________
Regards,
Donna Lee Jones, Ph.D.
Senior Technical Advisor, Metals Sector
U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards Sector Policies and Programs Division / Metals & Inorganic Chemicals Group (D 243-02) Research Triangle Park, NC  27711  Tele:  (919)  541-5251  Fax  (919)  541-3207 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
"Reasonableness never fails to be appreciated."  - anon.

From: David Ailor [mailto:dailor@accci.org]
Sent: Wednesday, August 19, 2015 5:13 PM
To: Jones, DonnaLee
Subject: RE: Parent Company representatives and mailing addresses

Thanks, Donna Lee.  I'll connect with my member companies and get back to you as soon as possible.

I hope EPA can be flexible in terms of the timing on distribution of the ICR.  Once I receive the draft ICR, I'm going to need some time  -  perhaps, quite a bit  -  to vet it within my membership.  We were expecting the draft ICR in the spring and, needless to say, we're months beyond that now.

DCA

David C. Ailor, P.E.
President
American Coke and Coal Chemicals Institute
25 Massachusetts Avenue, N.W.
Suite 800
Washington, D.C. 20001
Phone: 703-795-3541
eFax.: 866-422-7794
dailor@accci.org<mailto:dailor@accci.org>
www.accci.org<http://www.accci.org/>

From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov]
Sent: Wednesday, August 19, 2015 4:02 PM
To: David Ailor (dailor@accci.org<mailto:dailor@accci.org>) <dailor@accci.org<mailto:dailor@accci.org>>
Subject: Parent Company representatives and mailing addresses

Hello David  - I wanted to let you know will be sending you a DRAFT complete ICR by end of week. Shooting for Thursday afternoon, but hopefully by Friday. Worst case Monday. Everyone should keep in mind that this is a DRAFT and not make any business decisions based on this version of the ICR. In the meantime, I've compiled the company list based on my records, which was updated a couple years ago by Bruce. See attached file. What I need is the complete mailing address of the PARENT companies and the name (and title, if available) of the "official" company representative who needs to receive any letter we send. The place for this information is highlighted YELLOW in the spreadsheet I've also tried to guess which companies are owned by the same owner ("Separate Companies" column). This is important information for EPA purposes. In some cases, as I have seen in other industries, what appears to be the same (parent) company is actually a subsidiary of the parent company and, therefore, is really another company for our purposes. So I need to know which facilities are under the parent company or under a subsidiary company, if applicable. Also, anything else on this spreadsheet that is not accurate should be corrected. Please have companies put their corrections in RED so I can see easily what has been changed.

The ICR will have two parts. One part (Enclosure 1) will be a Questionnaire that asks questions about the company and all of the operations at their coke facility(ies). The second part (Enclosure 2), will be a testing request and will include all of the details of where and how to test. We will be mailing the ICR along with spreadsheets that facilities must use to report their information and test data. The only exception will be for certain test data that can be sent directly via the EPA's Electronic Reporting Tool (ERT) Version 3, which is available online (http://www.epa.gov/ttn/chief/ert/ert_tool.html.). The ICR explains which data needs to be reported using the ERT and which is not.

We will be asking that the companies send us their completed questionnaires in three months from when they receive it. I am hoping to be able to sen it out in September/October time frame. We understand that sometimes nothing goes on business-wise the last 2 weeks in December, which is same case here at EPA, so I take this lull period into account when I set the date. Most likely the Questionnaire will be due in early January 2016. The complete testing results will likely not be due until June 2016, but there are much earlier deadlines (January) for reporting test dates and submitting test plans. The test plans will be short (could be 2 pages) and only for one or two of the tests.

As far as who will receive the letters, we would like to send Questionnaires to all of the facilities because this lets us know about the industry to inform us in our rulemaking. If by chance we cannot send an "official" letter to all companies, I would appreciate your help in requesting the companies not on the "official" list to submit a questionnaire voluntarily. This can only help the company since if there are differences in their operations in any way, we will be able to take this into account in any rule decisions, but only if we have information to do so. Lack of information on our part never leads to a good end point for the industry. But we will cross this bridge when or if we come to it.

For the testing request, in order to minimize the financial burden on the industry we will be sending out only as many requests as we absolutely need. However, we need to have enough data so that statistically we have enough data if calculations are made, especially if we are looking at subsets of facilities within the data set. We have learned the hard way on other rules. In some cases, we have had to require more testing. Or worse, have had to make estimates that people were not happy with.

For by-product plants, we are thinking about picking six facilities to tests. We will try to distribute the requests to different companies so that no one company gets the majority of the test requests. We will not be sending a testing request to Tonawanda because of the recent EPA activity there. We WILL most definitely be sending a test request to USS's Clairton plant since it is the largest facility in the U.S. and also has at least one novel feature (the new battery).

For the heat recovery plants, we have no choice except to send the requests to Suncoke since they own all of them. However, we likely will be picking only three of the hat recovery type. We likely will not request testing at Vansant because it is not heat recovery and no plants are likely to be built like this one in the future.

If you have any questions, feel free to send me an email. I will set up a call to discuss your question(s) after that, if needed.
_____________________________________________________________
Regards,
Donna Lee Jones, Ph.D.
Senior Technical Advisor, Metals Sector
U. S. Environmental Protection Agency
Office of Air Quality Planning and Standards Sector Policies and Programs Division / Metals & Inorganic Chemicals Group (D 243-02) Research Triangle Park, NC  27711  Tele:  (919)  541-5251  Fax  (919)  541-3207 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
"Reasonableness never fails to be appreciated."  - anon.





