From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Tuesday, November 3, 2015 3:03 PM
To: 
BATTEN, KATIE M <KMBATTEN@suncoke.com>; David Ailor (dailor@accci.org) <dailor@accci.org>
Cc:
Bullock, David <dbullock@rti.org>; Raymond, Gabrielle <graymond@rti.org>
Subject: 
revised (draft) Table 1-B (11-03-15); revised schedule, and draft submittal groups for Enclosure 1


Hi  - Since SunCoke had asked for an updated Table 1B to review before they submitted comments on the methods, I wanted to send it to both of you at same time. This is close to final, but I am still looking into the optical flow measurement technique with the vendor so this is highlighted as "pending". I have almost given up on getting a grab organic sample from oven area during pushing so it's labelled as "CD only;" however, if we can come up with a good way to get total organic carbon from a grab sample I may add it back in. [I had to use a pdf so that the footnotes were accurate; if you really need a Word version I can send it to you, but it will not have the correct footnotes]

Keep in mind the footnote to the quench tower air tests includes reference to the two reduced testing options I had sent you both late last week (below). There is a new section in the ICR that includes these options, just as I sent them to you. I am also considering allowing reduced testing for the flow measurement, if the (by-product) industry can do the coordination needed for quench towers. 

I will likely have a complete revised draft Enclosure 2 by the end of the week which I will also send to both of you. Good news (for me) is that I have a contractor now. I plan to revisit Enclosure 1 with your comments that are pending on November 12, and any further comments on Enclosure 2 by both groups, and send out the ICR packages the first week of December, trying to avoid anything planned for me (or RTI) to do after December 11. I have delineated the submittal groups for Enclosure 1 based on a simple sequential grouping of the current questions. But I know that some of the questions may be moved around in priority after our meeting Nov 12 and/or edited. The current groups in Enclosure 1 for timing purposes are: Group 1, sections I through V; Group 2, sections VI and VII; Group 3, VIII through X. Im flexible on these groupings and the order of the current questions.

The revised (draft) schedule for both enclosures is as follows:

Schedule for Submissions*
Submit e-copy of most recent air permit ..............................within 5 working days of receipt of EPA letter
Submit detailed explanation and photographs of testing problems.................................by February 1, 2016
Submit names of Quench Tower testing facilities and tests.........................................by February 1, 2016
Submit previous test reports and request for exemption from new testing........................by February 1, 2006
Submit Questionnaire responses-Group 1 (Enclosure 1)..........................................by February 15, 2016
Submit test plans for selected tests.........................................................................by March 1, 2016
Submit schedule for new testing (Enclosure 2).........................................................by March 22, 2016
Notify your state of upcoming tests..................................................................21 days before testing
Submit Questionnaire responses-Group 2 (Enclosure 1)...............................................by April 25, 2016
Submit Questionnaire responses-Group 3 (Enclosure 1).................................................by July 5, 2016
Submit Test Reports and Data Spreadsheets (Enclosure 2)**..........................................by August 15, 2016

_____________________________________________________________
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.


<< Table1B-draft-CLEAN-EPA-V4-11-03-15-Coke ICR-Enclosure 2-DRAFT-8-20-15-DLJ.pdf >>


From: BATTEN, KATIE M [mailto:KMBATTEN@suncoke.com] 
Sent: Tuesday, November 03, 2015 10:06 AM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Subject: RE: ICR update - Friday 10/30/15

Donna Lee,

Do you have an updated Table 1-B from Enclosure 2?  

Thanks,

Katie Batten
Corporate Environmental Manager


 
 off: 630-824-1786
 cell: 740-370-8710

From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov] 
Sent: Friday, October 30, 2015 1:22 PM
To: David Ailor (dailor@accci.org); BATTEN, KATIE M
Subject: ICR update - 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. 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 (reflected in attached revised Table 1-C)
·         Reduced the number of tests that are required to be done simultaneously (reflected in attached revised Table 1-C; changes will be made also in Table 1-B)
·         Added alternate methods to be used on pushing machine that are more mobile than previous methods (reflected in attached revised Table 1-C))
·         Eliminated all HAP tests at oven door (flow direction and opacity remain)
·         Eliminated most of HAP tests during charging (BSO and HAP metals/filterable at CD, and opacity at lids remain)
·         Added two options for quench tower testing at a reduced number of facilities (the default is all facilities doing testing also do all of the quench tower tests), See attached new Table 1-D. I have no preference as to which facilities do the testing under both Options, as long as I there are data from at least two BP and one HR test facilities from among the facilities who are doing the source tests, performing each quench tower test method group, 
      o   For by-product (BP) facilities: 
            §  One option is for two BP facilities to do one group of test methods at their quench towers, so that each test method group performed by (at least) two BP facilities;
            §  Second option is for two BP facilities to do all the quench tower tests. 
      o   For Nonrecovery (NR), the choices are to do an entire test series at one NR facility or split the test method groups between the three heat recovery facilities.
      
Quench Towers Facility Choices: It may take some significant coordination on your part (by-product side) to take advantage of the most reduced test Option 2 (all tests done by same two BP facilities) since choosing this option will involve either two facilities volunteering (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 quench tower test series. My reason for allowing a reduced number of facilities to do entire quench tower test series under both options is that some facilities may already have capability to test at one of their quench towers (e.g., stairs alongside with test ports in place). Or, alternatively, if a stand-alone platform is to be built for testing at quench towers, it would make sense for all or more of the testing to be done at these facilities. The first option (1) for each by-product test facility to do one or two groups of quench tower tests may be easier to implement from a management perspective.

Small Data Set and Number of Test Runs: 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/limited dataset is defined to be six or lower test runs. I am sending the Primary Aluminum memo which along with Ferro Alloy memo, supports this decision. I had not read the Ferro Alloy memo closely enough the first time. 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 with seven replicates.

Flow measurement: I spoke with our expert on testing and he advised that we test flow both upstream and downstream from ovens during pushing and then on top. However, he said that hot wire anemometers can be fixed and unmanned to the PCM, with remote readout and data recording. I've reduced then number of pushes for this to three (3) consecutive oven pushes. I may have information about optical methods soon that could be done all remotely. 

If you want to talk after you receive the information, I am free from other meetings the rest of the afternoon today, all afternoon on Monday (after 1:30 pm), all day 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.





