From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Thursday, October 29, 2015 11:40 AM
To: 
David Ailor (dailor@accci.org) <dailor@accci.org>; KMBATTEN@suncoke.com
Subject: 
Will send ICR update list tomorrow - Friday 10/30/15


Hi David and Katie  -  We are almost finished with our work on addressing concerns brought forward about the testing planned for the coke oven ICR. I will send you late today or early tomorrow, the list of specific changes along with some supporting material. We did the best we could so I hope that this new plan is better for the industry. We made the following changes that you should appreciate:

 Combined testing for some HAP into one sampling method/train
 Reduced the number of tests that are required to be done simultaneously (now six groups of simultaneous test methods, with 1 to 3 tests in each group)
 Added alternate methods to be used on pushing machine that are more mobile than previous methods
 Eliminated all HAP tests at oven door (flow direction and opacity remain)
 Eliminated most of HAP tests during charging
 Added two options for quench tower testing at a reduced number of tests or facilities (the default is all facilities to all quench tower tests): 
 One option is for only two by-product facilities to do all the quench tower tests; 
 Second option is for each by-product facility to do one set of simultaneous tests at quench tower so that each test group is done at two facilities. 
 Nonrecovery choices are to do an entire test series at one facility or split the test method groups between all three heat recovery facilities.

On this last point, it may take some significant coordination on your part (for by-product side) to implement the testing options, since taking advantage of these options will involve either facilities volunteering to be one of the two test facilities (doubtful, right?) or for the industry to coordinate the cost of the tests so that the two facilities doing the testing do not have to bear the cost of the entire test series. My reason for allowing a reduced number of facilities to do entire test series is that some facilities may already have capability to test one of their quench towers (e.g., stairs alongside with test ports in place), and also that if a stand-alone platform is to be built for testing the towers, it would make sense for all the testing to be done at these facilities. The option for all by-product facilities to do one group of tests may be easier to implement from a management perspective.

I also looked into the small dataset issue and unfortunately from your perspective I will be increasing the test runs by one run (total of seven) because the small dataset is defined to be six or lower test runs. I will send supporting information about this decision. Hopefully the reduced number of sampling trains will compensate for the increased number of runs. There will be a payoff at the end if we end up having to set any new standards, since the UPL will be more statistically sound.

If you want to talk after you receive the information, I am free from other meetings all afternoon Friday this week, and then all day (for now) Monday, Wednesday, and Friday next week. 
_____________________________________________________________
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.


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