From: 
David Ailor [dailor@accci.org]
Sent:
Friday, February 26, 2016 10:15 PM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc:
French, Chuck; Allen Dittenhoefer; 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: final drafts of enclosure 1&2 for coke ovens - facility lists


Donna Lee:

Thanks again for doing what you can to address our comments on the draft ICR enclosures.  Attached insofar as the "final drafts" of enclosures 1 and 2 you provided us on Wednesday, February 17, are COETF "markups" highlighting the COETF's questions/comments on those specific draft documents (see "022616 COETF Comments on Final-Draft-Coke ICR Intro-Enclosure I-DLJ-02-16-16.pdf" and "022616 COETF Comments on Final-Draft-Coke ICR-Enclosure 2-DLJ-02-16-16.pdf," respectively).

Please note in your review of our Enclosure 2 markup that on page 17 of 38 there is a reference to an "Alternative Testing Options" document we have developed for your consideration insofar as "Testing Options for Quench Tower Tests  -  Minimum Number of Facilities Required to Test" (Table 1-D).  This document is the last page in our markup of Enclosure 2.  We urge to give serious consideration to the options set forth in this document, as a way to reduce the cost burden of the ICR testing on the industry while delivering to EPA the data it needs for the rulemaking.

We would appreciate greatly the opportunity to meet with you, via conference call, to discuss our questions/comments "first hand."  Please let me know what your schedule looks like next week, and I'll send you an Outlook invitation for a time that works best.

Once again, thanks for doing what you can to address our comments.  Please contact me if you have any immediate questions.

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<mailto:dailor@accci.org>
www.accci.org<http://www.accci.org/>


<< 022616 COETF Comments on Final-Draft-Coke ICR Intro-Enclosure I-DLJ-02-16-16.pdf >>
<< 022616 COETF Comments on Final-Draft-Coke ICR-Enclosure 2-DLJ-02-16-16.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 10th. 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.





