From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Friday, June 24, 2016 4:14 PM
To: 
Self, Traci I <traci.self@arcelormittal.com>
Cc:
Zavoda, Rich <Rich.Zavoda@arcelormittal.com>; Hill, John R <john.hill@arcelormittal.com>; Shelton, Randy E <Randy.Shelton@arcelormittal.com>; Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: Coke ICR Quench Tower Testing Ongoing Concerns and Selection - USEPA Response Requested


Hello all - I have read the concerns in your attached letter and have responded to them in the FAQ #3, new question #17 which I sent separately. I have duplicated the question and our response below. Have a good weekend.
 
17.  It seems like because the quench tower tests are not being done exactly by EPA method protocols, the test data will not be valid and, therefore, will not useful in developing an emission limit. Since this might be a big expense for my company, why should we do the testing if the data will not be able to be used for an emission limit?
 
Coke companies always have had have the choice of doing the quench tower testing exactly as the methods are written. However, EPA has been sensitive to industry concerns about safety and the difficulty of the tests, so we have allowed certain deviations that we believe are not "deal breakers" and would allow us to set emission limits, if needed, and to develop representative values to be used within the risk model. Minimally, the emissions data you collect will inform EPA of the nature of the quench tower emissions, which may be sufficient for our purposes. 
 
In summary, the required quench tower methodology for the Coke ICR is as follows, with a choice available for all facilities:
 
(1)     Perform all quench tower air testing according to prescribed EPA methods that include the following specifications: 24 (or 25) traverse points from each sample port according to EPA Method 1; isokinetic flow for particulate-related samples as per EPA Method 5; and sampling points sufficiently above the last baffle, or otherwise positioned between baffles, so that the air flow at the sampling points is not impacted by upstream obstructions (as per EPA Method 1); OR
(2)     Perform any quench tower tests with the following modifications for safety purposes: at least 12 traverse points from each sample port described in EPA Method 1; samples collected at locations where the sampling flowrate is as close as possible to the preferred isokinetic range in Method 5 and recording of percent isokinetic flow during the tests; and, in instances when the quench towers do not meet the upstream/downstream flow disturbance requirements of Method 1, you will not be required to conduct alternative site selection procedure (Method 1, Section 11.5.1) since the flowrate may not be high enough to conduct these tests.
 
The EPA is requesting quench tower testing to understand the nature of the air emissions as a minimum goal. And we are requesting both air emissions data and simultaneous quench water samples in order to fully understand the relationship between the characteristics of the quench water effluent and the quench tower air emissions (see FAQ #16 for clarification of the sampling location for the quench tower water tests). We will develop an emissions value for risk modelling from these quench tower data that we believe best represents the quench tower emissions at all facilities that may be based on individual facility data, pooled estimates from some or all facilities, an overall industry average, or combinations of the above. If emissions limits need to be developed, any fluctuations due to non-optimum sampling conditions will be incorporated into the calculation of the emissions limit in the UPL equation that EPA uses to develop emission limits. We may not know if we need to set an emission limit until we run the risk assessment. 
 
In addition, we have ways to interpolate and/or interpret test data when it is not obtained by standard procedures. For example, isokinetics outside the prescribed window in Method 5 is permitted within the method (with "Administrator approval", see Method 5, section 8.6) and can be corrected for moderate amount of non-isokinetics when it is needed, i.e., with PM-related constituents. [Note, sampling of gases does not need isokinetic flow.] If flow disturbances are experienced when sampling is performed between the baffles, as opposed to above the baffles, and also if reduced sampling points are used, there likely will be more fluctuation in the data rom run to run. These fluctuations will be accounted for by taking an overall test average and, if a standard is develop, by the UPL equation which uses statistical terms to incorporate run-to-run variability.
 
Finally, the air and water emissions data from the quench tower will enable EPA to fully evaluate an appropriate standard for such units, if needed, be it an air emissions standard, a work practice standard, revised water limits in the format currently in the rule, or substantiate (i.e., keep) the water limits currently in the rule.
 
_____________________________________________________________
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.
 
 
-----Original Message-----
From: Self, Traci I [mailto:traci.self@arcelormittal.com] 
Sent: Friday, June 10, 2016 1:56 PM
To: GABRIELLE RAYMOND <graymond@rti.org>; Jones, DonnaLee <Jones.Donnalee@epa.gov>; French, Chuck <French.Chuck@epa.gov>
Cc: Zavoda, Rich <Rich.Zavoda@arcelormittal.com>; Hill, John R <john.hill@arcelormittal.com>; Shelton, Randy E <Randy.Shelton@arcelormittal.com>
Subject: Coke ICR Quench Tower Testing Ongoing Concerns and Selection - USEPA Response Requested
 
 
Dr. Jones,
 
ArcelorMittal Monessen LLC timely submits the attached correspondence in response to the April 4, 2016 US EPA Section 114 Coke Information Collection Request (Coke ICR). In Enclosure 2 of the Coke ICR, US EPA requires ArcelorMittal notification to inform US EPA at which facility Quench tower testing will be conducted. The attached letter includes a continuation of our testing concerns and the notification of the facility selected to perform testing pending the requested response from USEPA. Also attached is a February 29th submittal from the COETF outlining previously communicated testing issues. We look forward to your response.
 
Regards,
 
Traci I. Self | Environmental Manager
ArcelorMittal Monessen LLC
 
Monessen Coke Plant | 345 Donner Ave
Monessen, PA 15062
 
T +1 724-684-1009 | F +1 724-684-1087 | traci.self@arcelormittal.com<mailto:traci.self@arcelormittal.com>


