From: 
Zavoda, Rich <Rich.Zavoda@arcelormittal.com>
Sent:
Friday, April 22, 2016 11:41 AM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc:
chuck.french@epa.gov
Subject: 
USEPA 114 Request - Coke Ovens (63 Subpart CCCCC Pushing, Quenching, Battery Stack - Information Collection Request (Coke ICR)


Dr. Jones,
ArcelorMittal Burns Harbor LLC and ArcelorMittal Monessen LLC were selected by EPA in the 4/4/16 Section 114 request to complete a comprehensive information request (Enclosure 1) and to conduct extensive stack testing (Enclosure 2). EPA also selected ArcelorMittal Warren to complete the Coke ICR Enclosure 1, as noted in your attached 4/4/16 email.  These combined actions impose a disadvantage to ArcelorMittal compared to its competitors. 
EPA is not requiring any other byproduct coke plant entity to test at more than one coke plant or at more than one coke battery.  EPA did not request every byproduct coke plant to complete the comprehensive information request (Enclosure 1).  Several of our byproduct coke plant competitors were not required to complete either the information request (Enclosure 1) or to conduct stack testing (Enclosure 2).  
Attached is your 4/1/16 email that provided the table of ICR companies required to complete the Coke ICR Enclosure 1 and/or 2. 
Also attached is the list of all coke plants that David Ailor, American Coke and Coal Chemicals Institute, emailed to you on 4/1/16. 
ArcelorMittal respectfully requests that EPA not require ArcelorMittal Warren to complete the Coke ICR Enclosure 1.
Rich Zavoda | Regional Manager, Air Quality Program
ArcelorMittal USA
Environmental Affairs| 4020 Kinross Lakes Parkway, Richfield, Ohio 44286-9000
T +1 330 659 9163 | F +1 330 659 7434 | www.arcelormittal.com


