From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Thursday, September 8, 2016 2:36 PM
To: 
William Cowell <WCowell@montrose-env.com>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
Re: Coke Industrry ICR Testing-remaining issues


Ok. Make sure you note this in your test report and ERT submission

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: William Cowell <WCowell@montrose-env.com>
Sent: Thursday, September 8, 2016 2:26 PM
To: Jones, DonnaLee
Cc: GABRIELLE RAYMOND
Subject: RE: Coke Industrry ICR Testing-remaining issues

We do run the condenser pump continually, and I'm sure the trap itself is cold.  But the thermocouple position, and the fact that part of the thermocouple sticks out into the ambient air where it gets hit by sunlight and radiates heat down towards the tip when no air is flowing, leads it to read higher than the actual trap temperature.  This is a common problem we experience on Point 1 in a continuous  run train, and by the end of a 5 minute point, the temperatures are to the required levels but sometimes, for the first few minutes they are not yet reading what they should.  For the exit temperature, same issue.  Almost all sampling trains probably use a metal gooseneck piece to measure the impinger exit temperature, and this, being metal, is affected greatly during non-sampling times by the ambient conditions.  We will do the best we can and at nighttime, it is not an issue, but during mid-day, it can be.

Thank you for your quick responses



William P. Cowell, QSTI
Client Project Manager
Montrose Air Quality Services, LLC.
1050 William Pitt Way, Pittsburgh, PA, 15238
T: 412.826.3636 | M: 412.527.5750 |F: 412.826.3640 wcowell@montrose-env.com www.montrose-env.com

-----Original Message-----
From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov]
Sent: Thursday, September 08, 2016 2:16 PM
To: William Cowell
Cc: GABRIELLE RAYMOND
Subject: Re: Coke Industrry ICR Testing-remaining issues

Mr. Cowell - I received an answer already on your other issues, as follows:

Your approach to the temperature issues is reasonable. You should note any out of ordinary circumstances in both in the test report and in the appropriate ERT place.  What you should do is make sure the train is iced, the pump is on, and train is covered during down periods.  Additionally, if not already planning to do so, you should run the condenser pump continually. Basically, do all that you can to keep the train cool.


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: Jones, DonnaLee
Sent: Thursday, September 8, 2016 11:23 AM
To: William Cowell
Cc: GABRIELLE RAYMOND
Subject: Re: Coke Industrry ICR Testing

30 sec is ok.  But we don't want any longer nonprocess sampling so continuing on after the process stops is not good for this batch situation. However, waiting until pushing stabilizes is a good idea and then continue when it starts back up. I don't believe we specified any time period for the push just that it's the entire push. So you aren't obligated to get exactly 2.5 sec per push as long as:
(a) you are only sampling during a push, give or take an occasional 30 sec delay in communication,
(b) you sample the minimum total volume of air , and
(c) you cover the entire pushing period during each push, from beginning to end.

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: William Cowell <WCowell@montrose-env.com>
Sent: Thursday, September 8, 2016 11:11:45 AM
To: Jones, DonnaLee
Cc: Matthew Dallesasse; John Wilson; Terrence Mulhern; Cody Shifflett; 'Randy G. Wiler'
Subject: RE: Coke Industrry ICR Testing

Dr. Jones,

But even in this case, we would still be say at least 30 seconds into the 2.5 minute sampling period.  There is no way to undo what we have already sampled.  Our general guidance/procedures has been to always finish an individual test point when you start, lets say in a batch industry, where maybe the process ends during a sampling period, we would always continue on for the full duration of an individual point.    Or would you prefer us to maybe if we find out 30 seconds in, stop then, and then continue on with the other 2 minutes after they reattempt the push so we are still sampling each oven/push for a total 2.5 minutes?



William P. Cowell, QSTI
Client Project Manager
Montrose Air Quality Services, LLC.
1050 William Pitt Way, Pittsburgh, PA, 15238
T: 412.826.3636 | M: 412.527.5750 |F: 412.826.3640 wcowell@montrose-env.com www.montrose-env.com

-----Original Message-----
From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov]
Sent: Thursday, September 08, 2016 11:00 AM
To: William Cowell
Cc: Matthew Dallesasse; John Wilson; Terrence Mulhern; Cody Shifflett
Subject: Re: Coke Industrry ICR Testing

On the second issue of unplanned shutdowns, you should add a staff person to be the communicator from on the pushing side via walky talky or cell phone to alert you when pushing stops for stickers.

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: William Cowell <WCowell@montrose-env.com>
Sent: Thursday, September 8, 2016 10:12:27 AM
To: Jones, DonnaLee
Cc: Matthew Dallesasse; John Wilson; Terrence Mulhern; Cody Shifflett
Subject: Re: Coke Industrry ICR Testing

Okay, I understand, but we will probably be on run 3 for this set of tests by mid next week.  We will apply whatever your decision is to future test runs and parameters, but continue on as I described until I hear otherwise.

Bill Cowell

Get Outlook for Android<https://aka.ms/ghei36>



On Thu, Sep 8, 2016 at 9:57 AM -0400, "Jones, DonnaLee" <Jones.Donnalee@epa.gov<mailto:Jones.Donnalee@epa.gov>> wrote:

I wanted to let you know I received your message. I have forwarded your question to our measurement team. We will get back to you as soon as we can discuss, however this may not be until early next week because of some team members are on travel.

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: William Cowell <WCowell@montrose-env.com>
Sent: Thursday, September 8, 2016 8:24:53 AM
To: Jones, DonnaLee
Cc: Matthew Dallesasse; John Wilson; Terrence Mulhern; Cody Shifflett
Subject: Coke Industrry ICR Testing

Dr. Jones,

We are in the early stages of the PECs testing at Erie Coke, and I have a few observations and abnormalities I wanted to discuss for you.  This place is a little different than most other places that push every 15 minutes, as there are only 20 pushes per day, so we usually wait at least an hour in between sampling, and only sample for 2.5 minutes per push (so for us to do a 3 hour Method 23 run, this is taking us nearly 4 days to complete one run even though we are testing 24 hours/day).

Anyways, for the Method 23 run, both the condenser temperature and the exit temperature heat up during the downtime to 90+ degrees.  When we start train back up, they both decrease but they often don't get to below 68 degrees b/c thermocouples take a few minutes to cool down themselves.  There is not much we can do about this.  The impinger train is kept iced and even covered with a jacket to keep cool air in, but when ambient temps are near 90, the thermocouples do read close to that until actual sampling resumes.

Another thing we are experiencing is "stickers".  We are informed a push is coming, and as soon as they start, we begin our sample point, and continue on it for 2.5 minutes.  However, when they have a "sticker", they stop the push, but we don't stop our sampling (because we usually don't find out about it until after our sampling period ended anyway and there would still be some amount of emissions coming from oven).  They then may try it again 15 minutes later and we again sample it again.  So for our 72 pushes this test, it may actually only be 68-70 real pushes (ovens) and 2-4 partially aborted pushes.  Is our approach acceptable?  We will note it in our test report (as well as the temperature issues mentioned above) in a deviations and abnormality section of the report, but I just wanted to hear from you before we continue.


William P. Cowell, QSTI
Client Project Manager
Montrose Air Quality Services, LLC.
1050 William Pitt Way, Pittsburgh, PA, 15238
T: 412.826.3636 | M: 412.527.5750 |F: 412.826.3640 wcowell@montrose-env.com<mailto:wcowell@montrose-env.com>
www.montrose-env.com<http://www.montrose-env.com/<http://www.montrose-env.com<http://www.montrose-env.com/>>


