From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Friday, November 6, 2015 5:06 PM
To: 
David Ailor (dailor@accci.org) <dailor@accci.org>; KMBATTEN@suncoke.com
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
summary of meeting with SunCoke on Coke ICR


Hi David  -  I spoke with the SunCoke people yesterday and here are the meeting notes. Katie is still running down one item which I have highlighted in yellow.
Although the entire meeting notes will be of interest to you, the items that specific effect by-product coke facilities in terms of the ICR are as follows:
 SunCoke said that previous test reports submitted in lieu of testing may not have as many test runs as required in the ICR. EPA acknowledged this fact, but is willing to accept the test data if valid.
 EPA said that we are open to reducing the number of facilities that do the flow tests, similar to the quench tests.
 SunCoke said that their baffles [at all facilities] are up to the top of the tower but SunCoke believes the baffles mostly remove PM. EPA suggested measuring the organics (not related to PM) below the baffles. [The semi-volatile tests would need to be included in PM group]
 EPA said that once the facility determines the highest practical height to construct the quench tower test platform, the testers should perform the PM-related tests despite possibly not achieving isokinetics (although should report the percent isokinetic in test report).
 EPA said that facilities only need to report upgrades from 2006 to present, since 2006 was the compliance date of the MACT. EPA's interest in upgrades is to look for (or document) better performance of some units as compared to others.
 EPA said that hand comments/drawings which are then made into pdfs are fine to use for process flow diagrams
 EPA said using Google Earth to get all digits of lat/longs is fine and is same procedure we use.
_____________________________________________________________
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
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"Reasonableness never fails to be appreciated."  - anon.



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