From: 
Self, Traci I <traci.self@arcelormittal.com>
Sent:
Thursday, September 15, 2016 3:17 PM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>; Raymond, Gabrielle <graymond@rti.org>
Cc:
Zavoda, Rich <Rich.Zavoda@arcelormittal.com>; Shelton, Randy E <Randy.Shelton@arcelormittal.com>
Subject: 
ICR proposed testing schedule- ArcelorMittal Monessen LLC.



Dr. Jones, 
Attached is the proposed testing schedule for the Monessen facility.  I apologize for the delay in responding.  
As you know, we had several technical issues with the testing and engaged in a dialogue with EPA to resolve these issues.    We have worked diligently to solicit and review proposals to conduct the Coke ICR testing.  However, the open technical issues resulted in the delay as summarized below.
Please note that on 6/9/16 we sent the attached request for the use of Prior Site Testing. You responded to our request on 6/24/16. 
 On 6/10/16, we sent the attached correspondence with Quench Tower Testing Concerns that included challenges to the proposed quench tower testing based on the use of non-promulgated Test Methods. Please note that we are the only byproduct coke plant being requested to test a quench tower who has not previously tested a quench tower. You responded on 6/24/16. We shared your feedback with stack testing consultants and requested that their proposals be updated based on the latest information. 
 We also shared your attached Frequently Asked Questions revision dated 8/30/16 with our contractors since new guidance was specifically provided for non-isokinetic testing of one-half of a quench tower using 12 traverse points from only one side of the tower that is specifically pertinent to the non-standard testing planned for Monessen's quench tower.  Please note that because of the location of the baffles and water sprays in the quench tower, it is not physically possible for the new ports that are to be located near the top of the tower to also meet the EPA Method 1 upstream and requirements criteria. There are still unresolved ongoing safety concerns with testing of the quench tower.  The temperature in the body of the steam cloud that can and does drift and bend over the top edge of the tower is 200 [o]F-210 [o]F and would scald workers on the test platform near the top of the quench tower which confirms that the testing crew cannot be on the testing platform during the quenching of hot coke.  This issue may not be resolved until testing is attempted and may impact the ability to complete the requested test.  
We hope this helps explain why additional time was necessary to submit the testing schedule.  Please be advised that we will notify you of any significant changes in the schedule dates.
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

<< ArcelorMittal Monessen LLC.  Proposed ICR Test Schedule.pdf >>
<< Coke ICR Quench Tower Testing Ongoing Concerns and Selection - USEPA Response Requested.msg >>
<< RE Coke ICR Quench Tower Testing Ongoing Concerns and Selection - USEPA Response Requested.msg >>
<< ArcelorMittal Monessen Prior Site Source Test Reports 2014-2016 for USEPA CAA Section 114 - in lieu of testing.msg >>
<< RE ArcelorMittal Monessen Prior Site Source Test Reports 2014-2016 for USEPA CAA Section 114 - in lieu of testing.msg >>



From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov] 
Sent: Wednesday, July 27, 2016 2:36 PM
To: Zavoda, Rich <Rich.Zavoda@arcelormittal.com>; Self, Traci I <traci.self@arcelormittal.com>; Shelton, Randy E <Randy.Shelton@arcelormittal.com>
Cc: GABRIELLE RAYMOND <graymond@rti.org>
Subject: testing schedule-Monessen

Hello All  -  We were looking through our records and we do not see any email or other correspondence relating to the ICR test schedule for your Monessen coke facility. Have you settled on a date yet? All other coke facilities replied by the deadline of 27-Jun-16. If you have already sent something by email, please resend. I apologize if I am the reason for the missing information.
_____________________________________________________________
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
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"Reasonableness never fails to be appreciated."  - anon.





