From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Friday, December 18, 2015 2:25 PM
To: 
BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>; David Ailor (dailor@accci.org) <dailor@accci.org>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
All industry comments on Coke ICR


Hello  -  In the interest of total visibility, Im providing you each with the other groups comments. All comments will be considered and I will try to make as many as I can. 

To bring Katie up to speed on the meetings I had last week at EPA, we presented upper management with the information about status of the by-product industry, where some facilities are on extended coking and some not, and the general downward trend in steel sales and, as a result, coke. I was not able to delay the testing part of the ICR, per se, but was told to proceed in a non-urgent manner which will allow facilities to adequately prepare for the testing. We will require testing from extended as well as normal operating by-product facilities, but looks like we can keep to the 6 by-product test facilities, which will be broken down to 3 extended and 3 normal operation. Facilities cannot claim their extended status as CBI, but the details of their operation, i.e., coking hours and temperatures, can be treated as CBI. I will be adding to Enclosure 1 to obtain nonCBI information on extended coking history at all plants, specifically in the last 12 months but also last 5 years if available. The main question, besides how many weeks/months of operation on extended coking, is how many times the facility has complied with the extended coking opacity standard for battery stacks in subpart CCCCC rather than the normal operation standard.

In addition, management has asked that we add subpart L test locations to inform the current risk assessment with an eye towards the 2020 risk assessment deadline for LAER sources under subpart L. So we will be keeping the charging control device test location in Enclosure 2. I am currently looking at the 2005 RTR to identify highest risk sources so that we can limit adding any other tests at subpart L locations to the most important sources from a risk perspective.

Thank you both for your help with this effort.
_____________________________________________________________
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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