From: 
David Ailor [dailor@accci.org]
Sent:
Thursday, December 17, 2015 10:01 PM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc:
Bill Osborn; Bryan Kresak; Charles Jones; Chris Hardin; Chris.Potts@aksteel.com; Coleen Davis; Dan Belack; Dave Hacker; David Ailor; David Fanning; Ed Dinsmore; hardenb@dteenergy.com; James Hosfield; Janis Deitch; Jay Cornelius; Joe Hanning; John Hill; Jonelle Scheetz; Julianne Kurdila; Katie Kistler; Keith Nagel; Krista Armentrout; Marian Gammon; Mark Poling; May, Jeffrey X; Mike Dzurinko; Nicole Siviy; Parker Adams; Patrick Smith; Peter Libell; Randy Wiler; Rich Zavoda; russ.dudek@aksteel.com; Scott Kiechle; Solomon Nyathi; Taylor Mackey; Tishie Woodwell; Traci Self; Victoria Morton; zervas@dteenergy.com
Subject: 
RE: Coke ICR


Donna Lee:  The COETF's comments on draft Enclosure 1 are highlighted in the attached.  Thanks, 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
www.accci.org



<< For-Redline-11-17-15-Coke ICR Intro-Enclosure I-COETF 121715.docx >>



-----Original Message-----
From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov]
Sent: Monday, December 14, 2015 12:16 PM
To: David Ailor <dailor@accci.org>
Cc: KMBATTEN@suncoke.com
Subject: Coke ICR

Hi David & Katie - We met with our division head this morning to discuss the coke ICR and issues with extended coking and industry economic status. We were told to go ahead with the ICR, but with a non-urgent schedule for the testing, meaning that we can provide ample time for facilities to get bids and schedule the testing around other obligations such as the questionnaire.
We will be looking at both extended coking and normally operating facilities in a mix to get the same 6 (by-product) +3 (heat recovery). The reduced number of facilities that would test air emissions at quench towers can remain.

I still plan to incorporate industry's request for staged-submission of the questionnaire. I had asked that the industry mark the questions (regardless of their current order) into groups based on their ease of answering, to allow more time for questions that are more difficult to answer. The industry will need to do that in their comments to be submitted end of this week/next Monday. I had made some basic cuts myself, but I think industry wanted to further subdivide, which is fine with me.

I was able to get the fenceline testing out of the ICR, I believe. So that's good news. What may be bad news from your perspective is that we were told to include processes that come under subpart L (some were already in the
ICR) so that EPA can get a head start on the LAER RTR for subpart L that's due no later than 2020. The MACT track for subpart L is also up for technology review (TR) under 112(d)(6) as of 2013 (8 yrs from 2005), which is the TR part of a RTR, so all subpart L facilities still would be included using the subpart 5C ICR.

We will try to be as stream-lined as possible with the test requests; we are still brain storming about that. Im glad fenceline is out.

I realize that this is not the outcome you had hope for. I will do as much as I can to ease the burden within these guidelines.
_____________________________________________________________
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.





