From: 
David Ailor <dailor@accci.org>
Sent:
Monday, February 22, 2016 7:50 PM
To: 
'Jones, DonnaLee' <Jones.Donnalee@epa.gov>
Cc:
Raymond, Gabrielle <graymond@rti.org>; 'French, Chuck' <French.Chuck@epa.gov>; 'Volker Schmid' <vschmid@cleanair.com>; Bill Osborn <bosborn@abccoke.com>; Bryan Kresak <bmkresak@uss.com>; Charles Jones <cjones@erpcoke.com>; Chris Hardin <cwhardin@uss.com>; Chris.Potts@aksteel.com; Coleen Davis <cdavis@uss.com>; Dan Belack <dbelack@uss.com>; Dave Hacker <dwhacker@uss.com>; David Ailor <dailor@accci.org>; David Fanning <fanningd@dteenergy.com>; Ed Dinsmore <edinsmore@tonawandacoke.com>; hardenb@dteenergy.com; James Hosfield <jhosfield@uss.com>; Janis Deitch <jdeitch@accci.org>; Jay Cornelius <jcornelius@abccoke.com>; Joe Hanning <jehanning@uss.com>; John Hill <john.hill@arcelormittal.com>; Jonelle Scheetz <jsscheetz@uss.com>; Julianne Kurdila <julianne.kurdila@arcelormittal.com>; Katie Kistler <katie.kistler@aksteel.com>; Keith Nagel <keith.nagel@arcelormittal.com>; Krista Armentrout <kdarmentrout@uss.com>; Marian Gammon <marian.gammon@arcelormittal.com>; Mark Poling <mpoling@abccoke.com>; May, Jeffrey X <Jeffrey.May@arcelormittal.com>; Mike Dzurinko <mdzurinko@uss.com>; Nicole Siviy <nasiviy@uss.com>; Parker Adams <phadams@uss.com>; Patrick Smith <patrick.smith@mscarbonllc.com>; Peter Libell <libellp@dteenergy.com>; Randy Wiler <rwiler@eriecoke.com>; Rich Zavoda <rich.zavoda@arcelormittal.com>; russ.dudek@aksteel.com; Scott Kiechle <fredric.kiechle@arcelormittal.com>; Solomon Nyathi <solomon.nyathi@arcelormittal.com>; Taylor Mackey <taylor.mackey@arcelormittal.com>; Tishie Woodwell <TWoodwell@uss.com>; Traci Self <traci.self@arcelormittal.com>; Victoria Morton <vlmorton@uss.com>; zervas@dteenergy.com
Subject: 
RE: final drafts of enclosure 1&2 for coke ovens - facility lists


Donna Lee:

As I reported to you on January 7, the COETF engaged CleanAir Engineering (Pittsburgh, PA) (CAE) early in 2016 to assist us in conducting an in-depth review of draft ICR Enclosure 2.  We and CAE have just completed that review, and the resulting comments are attached (see "COETF Comments on ICR Draft Enclosure 2.pdf").

As the comments explain, the draft version of Enclosure 2 on which we and CAE focused was that dated November, 17, 2015, "... taking into consideration modifications communicated via email to the COETF [since then]..." by yourself.  As we have not had an opportunity yet to review the "final draft" of Enclosure 2 you sent last week, the comments do not address that draft.  We are targeting the end of this week to send you our comments on that draft, as well as the "final draft" of  Enclosure 1.

Please note that the comments we are submitting today on draft Enclosure 2 are loosely divided into four groups:

 Issues related to the testing at intermittent emission sources, addressing method challenges and biases, as well as general test program logistical issues due to the extended test durations at these sources, especially under reduced operating conditions;
      
 Specific issues with testing at quench towers, including non-conformance of test locations with standard EPA methods, expected low flows and the impact of saturated flue gas conditions with entrained water droplets and subsequent consequences for the sampling strategies for water soluble compounds;

 Issues with proposed test methodologies and inconsistences in testing approaches for some target analytes and process parameters at specific sources; and,

 Burden of the proposed test program to the industry, framing the current production rate of the industry and establishing a cost estimate for testing activities in accordance with the current draft ICR.

Also, please note that CAE estimates that implementing the test program as proposed by the draft ICR Enclosure 2 "... will exceed $700,000 per facility, at current prevalent coke oven operating conditions (extended coking times).  This does not account for any modifications necessary to accommodate testing at some sources and to provide safe access to them."

Considering the dire economic condition of the industry, we urge you to give serious consideration to our comments.  Please contact me if you have any questions.  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


<< COETF Comments on ICR Draft Enclosure 2.pdf >>



From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov] 
Sent: Wednesday, February 17, 2016 3:01 PM
To: David Ailor (dailor@accci.org) <dailor@accci.org>; KMBATTEN@suncoke.com
Cc: GABRIELLE RAYMOND <graymond@rti.org>
Subject: final drafts of enclosure 1&2 for coke ovens - facility lists

Hello. As promised, here are the final versions of the enclosures for the coke ICR. I've also included the facility lists. Unfortunately, because of the dual nature of the ICR for the by-product industry, in terms of extended coking standards vs normal operating standards, I don't have the flexibility to allow switching out one facility for another in the case of multiple facilities under one company. I believe this only applied to one company. 

I know, David, you had said that the ACCCI had been working with a test consultant on getting additional comments on enclosure 2 to me by February 10[th]. I don't know if you all are delayed or maybe your issues were addressed in the comments I sent a few weeks ago in response to SunCoke's comments on enclosure 2. Regardless, it will take us about 2 weeks to get the packages together and the letters signed, so if I get comments in the next two weeks, I will still take a look at them. Since we have discussed all of the testing issues a number of time, I doubt if there would be any broad changes at this point to the test requests. But if there are facility=specific issues that are still a problem, we can discuss these on an individual facility basis even after the letters go out.

If either of you have any comments or see any errors with the two enclosures in the next 2 weeks, let me know. Again, not expecting to be able to make broad changes but interested in correcting errors and also adding any flexibility we can, as long as the integrity of the rule is not jeopardized.

_____________________________________________________________
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.







