From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Wednesday, May 18, 2016 2:59 PM
To: 
Kiechle, Fredric S <Fredric.Kiechle@arcelormittal.com>; May, Jeffrey X <Jeffrey.May@arcelormittal.com>
Cc:
Zavoda, Rich <Rich.Zavoda@arcelormittal.com>; Hill, John R <john.hill@arcelormittal.com>; Maciel, Robert A <Robert.Maciel@arcelormittal.com>; Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: Requested details quench tower and comment: Testing Related Deviations ArcelorMittal Burns Harbor for Coke MACT ICR Letter Dated April 4th, 2016


Thank you for the information. We will discuss and get back to you. I'd like some elaboration on one of your points. "...take into account operational and work practice differences and how these will affect what is represented by the data collected." Can you elaborate? I don't need an answer this week but if I can get it before testing is done, best if before our response to FAQs in next couple weeks, I can add some questions into the amended testing procedure so that we can collect this information at the same time as the testing.
_____________________________________________________________
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: Kiechle, Fredric S [mailto:Fredric.Kiechle@arcelormittal.com] 
Sent: Wednesday, May 18, 2016 2:43 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>; May, Jeffrey X <Jeffrey.May@arcelormittal.com>
Cc: Zavoda, Rich <Rich.Zavoda@arcelormittal.com>; Hill, John R <john.hill@arcelormittal.com>; Maciel, Robert A <Robert.Maciel@arcelormittal.com>; GABRIELLE RAYMOND <graymond@rti.org>
Subject: Requested details quench tower and comment: Testing Related Deviations ArcelorMittal Burns Harbor for Coke MACT ICR Letter Dated April 4th, 2016

Dr. Jones we appreciate your promptness in responding to our inquiry about testing concerns.  We believe your response to the 201A question may need to be re-evaluated based on the following site specific operational details at the PEC baghouses at our facility:

Method 201A vs Method 5 on Pushing Emission Control System (PECS); uses a stationary baghouse
   ·         Sample using Method201A throughout the entire pushing time period and do not turn off sampling when moving from door to door until the full volume required by the method (2 dscm) is collected. 
   Normal operation of our PEC ( controlled through process automation with specific permissives) is for the baghouse ID Fan inlet damper to be tightly closed when not in a push.  When an oven door is removed and the guide moved in place the baghouse inlet damper opens and once a performance level is reached the ram is released to push the coke mass.  Once the quench car of hot pushed coke leaves from under the coke side hood, the baghouse inlet closes and stack flow approaches zero.  There might be a minimal token stack flow between pushes at best.  If we were to sample as suggested from beginning of a push until we reach 2 dscm through X number of pushes, much of the sampled gas potentially would be ambient air back drafting in the stack or residual air from after a push was completed.  Of the 15 minutes push to push, 12 minutes is at near zero stack flow and three minutes is flow during the push proper.  This also will reduce the number of ovens pushed during testing.  Not necessarily.  Given that 201A requires you to sample based on average flow, and the average will be 12 minutes near zero and three minutes at normal pushing flows, the new flow average used to determine the sampling rate will not be representative of the batch release of actual PEC emissions and may still require the same number of ovens.  All other test methods will be sampled comparable to Method 5 requirements and the ability to correlate between M5 and M201A collected data, due to different sampling periods and representative emissions captured, may be lost.  ·         We understand that this testing may result in data that is significantly different from data collected at facilities with PCMs or sheds, i.e., data collected during sampling that is started and stopped for the pushes. Because there are at least three facilities with PECS, we will be examine the data collected and if significantly different can create a subcategory for regulatory purposes.  Certainly testing results may merit future development of subcategories but as part of the consideration, care must be taken to ensure comparisons  take into account operational and work practice differences and how these will affect what is represented by the data collected.

Request To Sample Single Points For Quench Tower

To aid you in determining  our request for sampling locations at the quench tower, we are providing the following added details.
            Our quench tower has a single set of baffles near the top of the structure.  The slats in the baffle assembly are oriented north to south in uniformly spaced groups.  East and west halves are symmetrical as are the north and south halves.  The assemblies rise from the east and west sides from a low point near the perimeter wall to a central peak in the center of the structure.  See attached picture of a partial assembly prior to installation and attached drawing.  Within the baffle assembly, the low point elevation to the high point change is 4 feet 5.5 inches.  Our proposed sampling location would be at three points above the baffles in the north east quadrant of the quench tower at three different points between the north/south centerline of the baffle assembly and the perimeter wall and at heights above the baffles that offered representative flows.

   ·         What is the vertical distance between baffles? From lowest slat to highest slat in the baffle assembly, a 4 foot 5.5 inch change in elevation occurs.  The vertical elevation change from the top of the quench car to bottom of the baffle assembly is 41 feet.  If baffle positions vary over the length of the quench tower, provide a table listing all levels of baffles with their height from ground.  Top of rail ground elevation is 616 feet above mean sea level.  Baffle slat heights within the baffle assembly as follows- see table below.  Slat height is constant north to south.  NOTE : values represent slats on one half ( east or west ) of tower similar to stairs rising.  The pattern reverses from highest to lowest ( center to perimeter) in the mirrored half of the quench tower.
   




F. Scott Kiechle  Sr. Engineer-Environmental
ArcelorMittal Burns Harbor
Maintenance, Environmental & Utilities | 250 W. U.S. Highway 12 Burns Harbor, IN 46304-9745
T +219 787 4968 | F +219 787 4973  | M +219 313 2661  | www.arcelormittal.c 
 Qapla'!

From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov] 
Sent: Monday, May 16, 2016 3:33 PM
To: May, Jeffrey X
Cc: Zavoda, Rich; Hill, John R; Maciel, Robert A; Kiechle, Fredric S; GABRIELLE RAYMOND
Subject: RE: Testing Related Deviations ArcelorMittal Burns Harbor for Coke MACT ICR Letter Dated April 4th, 2016

Here are our answers with one question for you all. We will respond to the quench tower question once we receive your response to our question below.

Method 201A vs Method 5 on Pushing Emission Control System (PECS); uses a stationary baghouse
   ·         Sample using Method201A throughout the entire pushing time period and do not turn off sampling when moving from door to door until the full volume required by the method (2 dscm) is collected. This also will reduce the number of ovens pushed during testing.
   ·         We understand that this testing may result in data that is significantly different from data collected at facilities with PCMs or sheds, i.e., data collected during sampling that is started and stopped for the pushes. Because there are at least three facilities with PECS, we will be examine the data collected and if significantly different can create a subcategory for regulatory purposes.

Request To Sample Single Points For Quench Tower
   ·         What is the vertical distance between baffles? If baffle positions vary over the length of the quench tower, provide a table listing all levels of baffles with their height from ground.

Coal Sampling Request To Take Composite Sample During Day Rather Than One During Each Run
   ·         Approved.


_____________________________________________________________
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: May, Jeffrey X [mailto:Jeffrey.May@arcelormittal.com] 
Sent: Friday, May 13, 2016 2:54 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: Zavoda, Rich <Rich.Zavoda@arcelormittal.com>; Hill, John R <john.hill@arcelormittal.com>; Maciel, Robert A <Robert.Maciel@arcelormittal.com>; Kiechle, Fredric S <Fredric.Kiechle@arcelormittal.com>
Subject: Testing Related Deviations ArcelorMittal Burns Harbor for Coke MACT ICR Letter Dated April 4th, 2016

Find Attached the current ICR related testing issues for ArcelorMittal Burns Harbor, LLC, in accordance with the Coke MACT ICR requirements.
Jeffrey May | Sr. Engineer-Environmental
ArcelorMittal Burns Harbor
Maintenance, Environmental, and Utilities | 250 W US Hwy. 12
Burns Harbor, Indiana 46304 
T +1 219 787 4964 | F +1 219 787 4973 | M +1 219 728 8902 


