From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Friday, February 5, 2016 6:43 PM
To: 
BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc:
David Ailor (dailor@accci.org) <dailor@accci.org>; Raymond, Gabrielle <graymond@rti.org>
Subject: 
EPA response to SunCoke test requests and also responses to SunCoke replies on "a few questions about your latest review"


Hello. Attached is the EPA measurement experts' response to the test request changes presented by SunCoke in regard to the coke oven ICR. Changes apply to all facilities, not just for SunCoke. We were able to permit a few of the requests and some we could not, with explanation provided here. For the intermittent tests during pushing and quenching, we have added a requirement that we hope is a win-win. EPA wanted to make sure all of the possible emissions were collected so we extended the sampling period during one push or quench. I don't know if this is how you were intending to sample anyway, but if you were planning a shorter period, say only during the actual push or quench, then this would increase the sample volume and potentially cut down on the number of total pushes or quenches you needed to sample for the test runs.

My responses to SunCokes comments are below in CAPS (sorry for caps but I'm not in the office so I don't have same access to fonts as if I were there).

Ive included both a pdf and Word file. The pdf to permanently "capture" the EPA comments, and the Word file to make it easier in case you need to cut and paste.

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 (D243-02) Research Triangle Park, NC  27711  Tele:  (919)  541-5251  Fax  (919)  541-3207 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
"Reasonableness never fails to be appreciated."  - anon.


<< Coke-ICR-Enclosure 2-SunCoke-requests-EPA-MTG-response-02-05-16.pdf >>
<< Coke-ICR-Enclosure 2-SunCoke-requests-EPA-MTG-response-02-05-16.doc >>


________________________________________
From: BATTEN, KATIE M [KMBATTEN@SUNCOKE.COM]
Sent: Wednesday, February 3, 2016 4:06 PM
To: Jones, DonnaLee
Cc: David Ailor (dailor@accci.org)
Subject: RE: a few questions about your latest review

Donna Lee,

Please see answers to your questions below in blue font.

Thanks,

Katie Batten
Corporate Environmental Manager
off: 630-824-1786
cell: 740-370-8710


From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov]
Sent: Friday, January 15, 2016 2:34 PM
To: BATTEN, KATIE M
Cc: David Ailor (dailor@accci.org)
Subject: a few questions about your latest review

Hi Katie  -  Im in the process of looking over your comments on the Coke ICR and had a few questions I needed you to clarify.


1.    I didn't see any explanation in either document for why you crossed out H2S during pushing. if this is related to EPA's blanket 114 authority to request information about any and all emissions from a source as EPA chooses, then you don't need to reply.

Heat recovery pushing is an intermittent emission unit that is difficult to test because of limited space, high ambient temperatures at the test ports due to presence of 2,000°F coke, hot steam, and moving equipment. We recommend limiting the testing on heat recovery pushing operations to the same pollutants as heat recovery charging operations.

THE CHARGING EMISSIONS, THAT ARE BASICALLY FUGITIVE DUST FROM THE COAL BEING CHARGED, ARE COMPLETELY DIFFERENT THAN PUSHING EMISSIONS, WHICH IS A POST-COMBUSTION EMISSION SOURCE. THEREFORE, IT IS EXPECTED THAT DIFFERENT TESTS WOULD BE DONE FOR EACH EMISSION POINT. IT WOULD BE AS IF THE QUESTION WAS FOR THE SAME TESTS TO BE DONE WITH A COAL PILE VS BOILER EXHAUST. ITS ALSO THE REVERSE DECISION PROCESS. WE CONSIDERED IF THERE WERE MORE TESTS THAT WE NEEDED TO DO FOR CHARGING, BUT DID NOT THINK MORE WERE NEEDED

2.    On your "Comment I": I did not see any comment in Table 1-B asking to be able to use Method 10 for CO and Method 3A and 10 for O2 and CO2. Possible because these methods are already being requested, except Method 10 for O2/CO2. I did see a comment about using an on-site CEM for CO2 without PS certification. Please confirm that this is your only comment about CO, CO2, or O2 testing.

We believe it is appropriate to use CEMs data for SO2, CO, CO2, and O2 with two considerations.

-       The Performance Specification and Appendix F for CEMs apply to analyzers that are permanently installed and calibrated daily. When bringing analyzers to a site for testing, the EPA methods 6C for SO2, 10 for CO, and 3A for O2 and CO2 are appropriate and adequate. 
HAVE PERMITTED

-       For moving equipment, we suggest allowing the collection of a gas sample in a Tedlar bag that can be carried to and analyzed on site by a stationary CEM.  
HAVE NOT PERMITTED. SEE EXPLANATION IN DOCUMENT


We added these comments to Table I-B for SO2 and CO2. The same comments should have been added to CO and O2. Should we amend Table I-B and resubmit?
I WILL ADD SAME COMMENT FOR CO2. DO YOU REALLY INTEND TO USE A TEMPORARY CEM FOR O2? WE DON'T HAVE ANY CEM THERE NOW. I WILL CHECK ON THIS POINT AND ADD APPROPRIATE INFORMATION AS NEEDED.

Also, could you provide another estimate of your potential costs per facility for Enclosure 2 tests considering that (1) all tests are reduced to three runs where previously specified as seven; (2) no fenceline testing; and (3) no within-fenceline ambient tests around other units.

Reducing the number of runs to 3 instead of 7 will reduce the cost for testing at one facility. However, it is not a linear reduction since planning, mobilization, and equipment procurement are required for any number of samples. In addition, a similar number of quality control samples will still need to be analyzed. We estimate the cost of testing for 3 runs at one facility would cost $480,000. This includes $380,000 for labor and equipment, $80,000 for analysis of air samples, and $20,000 for analysis of water samples. This still represents a burdensome cost for SunCoke. UNDERSTAND NON LINEARITY OF COSTS.


You can provide the answers as you get them rather than wait until they are all answered. Your choice.

Thanks. Have a good weekend.

_____________________________________________________________
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.





