From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Monday, April 25, 2016 12:05 PM
To: 
Zavoda, Rich <Rich.Zavoda@arcelormittal.com>
Cc:
chuck.french@epa.gov; David Ailor (dailor@accci.org) <dailor@accci.org>
Subject: 
RE: USEPA 114 Request - Coke Ovens (63 Subpart CCCCC Pushing, Quenching, Battery Stack - Information Collection Request (Coke ICR)


Hello Rich- Now that my shock at your shock has settled down, I can see perhaps where you may have been confused by some of the discussion leading up to the ICR mailout. Much of our discussion prior to the ICR mail out was focused on Enclosure 2 and who should do the testing because EPA believes that Enclosure 1 is not as much of a burden as the testing part of the ICR. I had always planned to send out Enclosure 1 to every plant that was eligible, considering the nine maximum letters. The facilities who are not receiving any part of the ICR are involved in some kind of legal activity with EPA and I had been asked not to send anything to these companies. The one exception is SunCoke's Vansant (Jewel) plant, which did not receive the ICR because this plant uses an obsolete process (nonrecovery) and SunCoke was already testing at two of their facilities but completing Enclosure 1 for all three remaining plants. One of the SunCoke three plants is actually involved in a minor legal action but I was not asked to avoid it, so I did not.

Im sorry for the misunderstanding and, as I said in my previous email, we can work with you on schedule for Enclosure 1 for Warren facility. Submit what you can for each group of questions required by the schedule and note which ones you will do later. 
_____________________________________________________________
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.


From: Jones, DonnaLee 
Sent: Friday, April 22, 2016 12:15 PM
To: Zavoda, Rich <Rich.Zavoda@arcelormittal.com>
Cc: chuck.french@epa.gov; David Ailor (dailor@accci.org) <dailor@accci.org>
Subject: Re: USEPA 114 Request - Coke Ovens (63 Subpart CCCCC Pushing, Quenching, Battery Stack - Information Collection Request (Coke ICR) 

I was told that these facilities were separately incorporated. Therefore, I had to send two separate letters which then took up two slots of my nine letter maximum to comply with the Paperwork Reduction Act. Consequently, this prevented me from sending an ICR to another facility and limited the data collection ability of the Coke ICR. So for your company to tell me now that these facilities are in fact one company sounds to me like wanting to have your cake and eat it too. If I had been able to consider these facilities under one parent company, I would have made the considerations you have recently requested. Its also rather late in the game to tell me this since you received the attached tables some time ago, as per their date, which was before the mail out of the ICR which you and David Ailor and all others in the industry knew was impending. Therefore, unless you or David Ailor can convince another facility in the industry to take your place, I will need to stand by EPA's request. We can work with you on schedule, however.

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.

                                       
From: Zavoda, Rich <Rich.Zavoda@arcelormittal.com>
Sent: Friday, April 22, 2016 11:41 AM
To: Jones, DonnaLee
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


