From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Friday, March 18, 2016 1:27 PM
To: 
David Ailor <dailor@accci.org>
Cc:
French, Chuck <French.Chuck@epa.gov>; Raymond, Gabrielle <graymond@rti.org>; Allen Dittenhoefer <adittenhoefer@montrose-env.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 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>; 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; KMBATTEN@suncoke.com
Subject: 
RE: MARCH 18 CONFERENCE CALL OF THE COETF WITH EPA TO DISCUSS METHODS AND QUESTIONS RELATED TO PQBS ICR TESTING (2:00 pm EST/1:00 pm CST)


Hello. I had morning appointment so just got in. Here below and attached are my answers. I think there are just a few that we might need to discuss further. My responses
A few questions/comments we would like to discuss relative to Enclosure 2, as well as Enclosure 1:
·       3/11/16 EPA Responses to Selected Industry Comments on Coke ICR  -  from 2/23/16 Industry document (COETF comments are added in blue font below to EPA's Response that used black and red fonts)
Ø       3. Concern about Method 201A/202 testing run durations being more than 66 hours per run
EPA: We will reduce the required sample volume to 2 dscm for Method (201A)/202 samples 
[COETF: Please update 3/11/16 Enclosure 2 Table 1-B Summary of Required Test Methods on page 11 of 38 for Method 201A/202 minimum sample volume states, "105 dscf (2 dscm)" and should be "70 dscf (2 dscm)."] OK
Ø       5. Quench towers, Comment 4 (pg 9): Extrapolating stack emissions from a single point that is not in conformance with EPA Method 1 requirements is an inconsistent approach. EPA should confirm that it is willing to accept ICR test data that do not conform to EPA Method 1 requirements nor have been generated using true isokinetic sampling, and base regulatory decisions on such a potentially inconsistent data set.
EPA: We do not see any mention of the "single point" in the ICR or any of the drafts. The current ICR is written to request that the facilities attempt to achieve isokinetic sampling but not repeat tests beyond what is bearable to the facility and to report whatever the best test and percent of isokinetic flow that is achieved.
COETF Clean Air Engineering 2/22/16 Submittal to EPA (revised 3/16/16), as noted below using strikeout deletions and underline additions:
Testing Issues at Quench Towers [No revisions to the 5 paragraphs originally submitted] - Comment 4: Extrapolating  sStack emissions from a single traverse point measurements performed at a locations that is are not in conformance with EPA Method 1 requirements is an inconsistent approach. EPA should confirm that it is willing to accept ICR test data that do not conform to EPA Method 1 requirements nor have been generated using true isokinetic sampling, and base regulatory decisions on such a potentially inconsistent data set. 
See footnote 2, pg 6 of 38. All quench tower tests should be done above last baffle, if at all possible, with diligent attempts to obtain isokinetic sampling where required by the methods. The percent isokinetic flow during test should be reported whether method limits on isokinetic flow are achieved or not. All tests will be accepted regardless of percent isokinetic; however, in extreme cases or where results are suspect or outliers, the data may not be included in industry averages.
Ø       7. Similar analogy for "quench" tower testing (pg 10), where EPA Coke ICR team recently re-defined quench test period to be as soon as coke car enters tower to when it leaves. Industry suggested we change it to "as soon as quench water starts and until 30 seconds after water stops.
EPA: We have amended the quench start time to when the quench water starts to flow and have changed the quench end time to the following: (1) 15 minutes after the quench water is turned off; or (2) when no fumes or steam can be seen emanating from the coke car; or (3) when the quench car and/or coke leaves the tower area, whichever is earliest. 
[COETF Clarifying Question: Did EPA intend to state "15 seconds" instead of "15 minutes"]
[COETF: Same comment is being made to the Enclosure 2 Footnote 11 on page 10 of 38 that uses the term "15 minutes"]
Ø       [COETF: The ability to traverse across a quench tower may be tower- and facility-specific depending on tower and platform construction and facility safety requirements.  The upstream/ downstream requirements cannot be met at any known By-Product Coke Plant Quench Tower.  Please confirm that EPA is willing to accept these deviations to Method 1.] 
We need to discuss timing. Im open to shorter time frame but want to make sure we catch all of the off gassing/visible emissions coming from the coke car, hence the phrase "whichever is sooner" so 15 minutes is just an outside limit.
·       3/11/16 EPA's Coke Ovens ICR Enclosure 2
Ø       Table 1-A Summary of Required Emission Testing for Coke Oven Plants-by Emission Process on page 8 of 38
EP-3 BP Combustion (Battery) stack[5]
EP-4: BP Boiler Stacks[5]
[5] For battery combustion stacks (EP-3) and boiler stacks (EP-4), test a minimum of two one stacks of EP-3 and EP-4 at each facility, if applicable, if two or more are present. 
[COETF Clarifying Question: Based on the reduced testing requirements implemented elsewhere, did EPA intend to reduce this requirement from "two" to "one."] 
No, we meant two. Stacks should not be difficult to test. We don't know in advance the most representative stack so getting two will be fine. We could have said "all stacks", which is what's normally done but wanted to limit the impact of testing, so we came DOWN to two.
Ø       Table 1-B Summary of Required Emission Testing for Coke Oven Plants-by Emission Process on page 16 of 38
[COETF Clarifying Question: Should the Units of Measure for EP-8 and EP-11 be % leaking?] Yes.
Ø       Table 1-D Testing Options for Quench Tower Tests  -  quench tower water tests: all six (6)
[COETF Clarifying Question: Based on EPA's 3/11/16 Facility Testing Scheme, quench tower water testing is requested to only be required at the 3 facilities conducting quench tower stack testing]
Water tests are quite easy to take and run and will give us useful information in case the air tests do not work out.
Ø       The draft Coke ICR-Enclosure 2 includes BSO testing requirements for the following Coke By-Product Plant (BP) emission units: BP Pushing (CD only), BP Combustion Stacks, BP Boiler Stacks, Flares (inlet), and Quench Towers.  It is noted that, in previous risk assessments, EPA has used BSO emissions as a surrogate for Coke Oven Emissions (COE) for fugitive coke battery emissions (i.e., charging, door and topside leaks), fugitive (uncaptured) pushing emissions, and emissions from quench towers.  In these assessments, EPA took the position, which the coke industry supports, that emissions from coke pushing control devices, battery combustion stacks, boilers, and flares are sufficiently altered by the control device or combustion process such that their emission streams may no longer be classified as COE.  For these emission units, EPA evaluated the cancer health risks associated with individual constituents of BSO (e.g., PAH compounds), rather than apply the unit risk estimate for COE.  We believe this is the route EPA should take in the upcoming MACT II residual risk assessment.
We plan to do so as far as risk, but everyone should want to do BSO for compliance if it turns out to be needed. As I've said many times before and in writing, it would be to industry advantage to have a single surrogate test to use in case there is a risk. The only way we can know if the surrogate is useful is to do the test at same time as the individual HAP testing.
·       3/11/16 EPA's Coke Ovens ICR Enclosure 1
Ø       Question 88i. Typical cycle time (total hours) on page 11 of 16
[COETF Clarifying Question:  To what cycle time is this referring?]
Charging cycle.

_____________________________________________________________
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.



<< Few-questionsDLJ-03-18-16.docx >>



From: David Ailor [mailto:dailor@accci.org] 
Sent: Friday, March 18, 2016 11:37 AM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: French, Chuck <French.Chuck@epa.gov>; graymond@rti.org; Allen Dittenhoefer <adittenhoefer@montrose-env.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>; 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: MARCH 18 CONFERENCE CALL OF THE COETF WITH EPA TO DISCUSS METHODS AND QUESTIONS RELATED TO PQBS ICR TESTING (2:00 pm EST/1:00 pm CST) 

Donna Lee:  The COETF appreciates your dialoguing with us over the last few months relative to the various questions/comments/concerns we have raised on ICR testing being planned relative to the Agency's Risk and Technology Review (RTR) Project for Coke Pushing, Quenching and Battery Stacks (PQBS).  We look forward to continue our dialogue later today, when our call will focus on methods and questions related to ICR Enclosure 2 (ICR testing).
Below in preparation for the call are a few questions/comments we would like to discuss relative to Enclosure 2, as well as Enclosure 1:
·       3/11/16 EPA Responses to Selected Industry Comments on Coke ICR  -  from 2/23/16 Industry document (COETF comments are added in blue font below to EPA's Response that used black and red fonts)
Ø       3. Concern about Method 201A/202 testing run durations being more than 66 hours per run
EPA: We will reduce the required sample volume to 2 dscm for Method (201A)/202 samples 
[COETF: Please update 3/11/16 Enclosure 2 Table 1-B Summary of Required Test Methods on page 11 of 38 for Method 201A/202 minimum sample volume states, "105 dscf (2 dscm)" and should be "70 dscf (2 dscm)."]
Ø       5. Quench towers, Comment 4 (pg 9): Extrapolating stack emissions from a single point that is not in conformance with EPA Method 1 requirements is an inconsistent approach. EPA should confirm that it is willing to accept ICR test data that do not conform to EPA Method 1 requirements nor have been generated using true isokinetic sampling, and base regulatory decisions on such a potentially inconsistent data set.
EPA: We do not see any mention of the "single point" in the ICR or any of the drafts. The current ICR is written to request that the facilities attempt to achieve isokinetic sampling but not repeat tests beyond what is bearable to the facility and to report whatever the best test and percent of isokinetic flow that is achieved.
COETF Clean Air Engineering 2/22/16 Submittal to EPA (revised 3/16/16), as noted below using strikeout deletions and underline additions:
Testing Issues at Quench Towers [No revisions to the 5 paragraphs originally submitted] - Comment 4: Extrapolating  sStack emissions from a single traverse point measurements performed at a locations that is are not in conformance with EPA Method 1 requirements is an inconsistent approach. EPA should confirm that it is willing to accept ICR test data that do not conform to EPA Method 1 requirements nor have been generated using true isokinetic sampling, and base regulatory decisions on such a potentially inconsistent data set.
Ø       7. Similar analogy for "quench" tower testing (pg 10), where EPA Coke ICR team recently re-defined quench test period to be as soon as coke car enters tower to when it leaves. Industry suggested we change it to "as soon as quench water starts and until 30 seconds after water stops.
EPA: We have amended the quench start time to when the quench water starts to flow and have changed the quench end time to the following: (1) 15 minutes after the quench water is turned off; or (2) when no fumes or steam can be seen emanating from the coke car; or (3) when the quench car and/or coke leaves the tower area, whichever is earliest. 
[COETF Clarifying Question: Did EPA intend to state "15 seconds" instead of "15 minutes"]
[COETF: Same comment is being made to the Enclosure 2 Footnote 11 on page 10 of 38 that uses the term "15 minutes"]
Ø       [COETF: The ability to traverse across a quench tower may be tower- and facility-specific depending on tower and platform construction and facility safety requirements.  The upstream/ downstream requirements cannot be met at any known By-Product Coke Plant Quench Tower.  Please confirm that EPA is willing to accept these deviations to Method 1.]
·       3/11/16 EPA's Coke Ovens ICR Enclosure 2
Ø       Table 1-A Summary of Required Emission Testing for Coke Oven Plants-by Emission Process on page 8 of 38
EP-3 BP Combustion (Battery) stack[5]
EP-4: BP Boiler Stacks[5]
[5] For battery combustion stacks (EP-3) and boiler stacks (EP-4), test a minimum of two one stacks of EP-3 and EP-4 at each facility, if applicable, if two or more are present. 
[COETF Clarifying Question: Based on the reduced testing requirements implemented elsewhere, did EPA intend to reduce this requirement from "two" to "one."]
Ø       Table 1-B Summary of Required Emission Testing for Coke Oven Plants-by Emission Process on page 16 of 38
[COETF Clarifying Question: Should the Units of Measure for EP-8 and EP-11 be % leaking?]
Ø       Table 1-D Testing Options for Quench Tower Tests  -  quench tower water tests: all six (6)
[COETF Clarifying Question: Based on EPA's 3/11/16 Facility Testing Scheme, quench tower water testing is requested to only be required at the 3 facilities conducting quench tower stack testing]
Ø       The draft Coke ICR-Enclosure 2 includes BSO testing requirements for the following Coke By-Product Plant (BP) emission units: BP Pushing (CD only), BP Combustion Stacks, BP Boiler Stacks, Flares (inlet), and Quench Towers.  It is noted that, in previous risk assessments, EPA has used BSO emissions as a surrogate for Coke Oven Emissions (COE) for fugitive coke battery emissions (i.e., charging, door and topside leaks), fugitive (uncaptured) pushing emissions, and emissions from quench towers.  In these assessments, EPA took the position, which the coke industry supports, that emissions from coke pushing control devices, battery combustion stacks, boilers, and flares are sufficiently altered by the control device or combustion process such that their emission streams may no longer be classified as COE.  For these emission units, EPA evaluated the cancer health risks associated with individual constituents of BSO (e.g., PAH compounds), rather than apply the unit risk estimate for COE.  We believe this is the route EPA should take in the upcoming MACT II residual risk assessment.
·       3/11/16 EPA's Coke Ovens ICR Enclosure 1
Ø       Question 88i. Typical cycle time (total hours) on page 11 of 16
[COETF Clarifying Question:  To what cycle time is this referring?]
Please contact me if you have any questions in advance of the call.  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





