From: 
BATTEN, KATIE M [mailto:KMBATTEN@SUNCOKE.COM]
Sent:
Thursday, January 12, 2017 5:07 PM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>; Robert Brager <RBrager@bdlaw.com>; Seidman, Emily <seidman.emily@epa.gov>
Cc:
Kakade, Seema <Kakade.Seema@epa.gov>
Subject: 
RE: SunCoke CAA 114 Request - Meeting Follow Up - EPA response


Donna Lee,
 
Thank you for your response.  SunCoke has reviewed the information you provided below.  We think this testing scope is acceptable and plan to do the bypass vent stack testing at the Granite City facility in May and are working to schedule the other testing at Haverhill.  Unless we hear otherwise from you, we will do the quench water testing at Haverhill at the same time as the other testing.  Doing so would be consistent with your statement that water testing is required, but inconsistent with your statement in number 4 below that quench water testing being conducted at the same facility and in the same time period as air emissions testing, if air emissions testing is required.  As we have previously stated, we cannot safely conduct quench air emissions testing in a way that would yield accurate, representative data.  
 
We are proceeding with developing a test plan and will send the plan back to you within the next three weeks.  We ask that you review it quickly so we can move forward with preparing to conduct the testing.  We may have questions on the testing as we develop the plan and will request a conference call to discuss, if needed.

Hope you had a great Holiday!

Thanks,

Katie Batten
Corporate Environmental Manager
 
 off: 630-824-1786
 cell: 740-370-8710


From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov] 
Sent: Tuesday, December 13, 2016 6:47 PM
To: BATTEN, KATIE M; Robert Brager; Seidman, Emily
Cc: Kakade, Seema
Subject: Re: SunCoke CAA 114 Request - Meeting Follow Up - EPA response

Katie,
 
Thank you for providing the previous test reports that were discussed at our September 15, 2016, meeting. The test reports were very helpful to our evaluation of SunCoke's request to amend the testing requirements for the Coke Oven ICR. 
 
We have considered your requested changes to the testing requests as described in your letters and during our meetings.  After consulting with various EPA experts, the following are our decisions on SunCoke's requests to reduce the burden of the ICR:
 
 Metals Testing 
 We will accept reduced Method 29 (metals) tests of one (1) dscm sample volume for all Method 29 tests in the ICR instead of 3 dscm.
 Dioxin and PAH Testing
 We will accept (new) test data for dioxin&furans at the main stack in lieu of (new) tests for dioxin&furans during pushing.
 We are retaining the dioxin&furan/PAH sample volume of 4 dscm for all PAH and dioxin&furan tests (as combined tests or separate).
 We cannot allow for a reduction in dioxin&furan sample volume based on the data provided to EPA because the dioxin&furan fingerprint (after the HRSG) in these data was limited to mainly two congener species (HPCDD and OCDD) that have low emissions (TEQ); we cannot allow for reduction in PAH sample volume because we have no data for PAHs on which to base a decision since the previous test reports did not include PAH testing. Therefore, we must retain the minimum sample volume of 4 dscm for the dioxin&furan and PAH tests, either separately or combined.
 Note that we are retaining the PAH test volume of 4 dscm during pushing even though we are accepting the (new) dioxin&furan tests at the main stack in lieu of (new) dioxin&furan tests during pushing for the reasons described above.
 Number of Facilities Conducting Testing
 We will accept testing at SunCoke's Haverhill facility as the only SunCoke facility to perform the complete set of source tests in Enclosure 2 of the 2016 ICR. However, we may need to require additional testing at another SunCoke facility in the future if the data obtained from the entire coke industry in response to the 2016 Section 114 requests indicate that EPA needs additional data to complete our statutory obligations under Section 112 of the Clean Air Act. 
 In the test data SunCoke provided, Haverhill had the highest HAP emissions compared to the other two SunCoke facilities. We plan to use Haverhill's data for the other four SunCoke facilities for risk assessment purposes. We plan to scale Haverhill's data to each of the other SunCoke facilities using lb/ton emission values from the Haverhill tests and each facility's production level.
 We are retaining the requirement for emissions testing of a HRSG by-pass vent at one facility.  However, we are providing flexibility as to which facility and the timing of such testing (as long as it is completed in year 2017). For example, the testing of the HRSG by-pass vent could be done at the Gateway facility or Middletown facility during an HRSG outage in year 2017. This testing of the HRSG by-pass vent must include all of the tests specified for the by-pass vent in the April 2016 Section 114 Request, except that the "Filterable PM & HAP Metals" test (i.e., Method 29) can be done with a sample volume of 1 dscm for each run instead of 3 dscm, as described above. Also, one Filterable PM & Metals test series (i.e., Method 29 with three runs, using a minimum of 1 dscm sample volume for each run) must be done during pushing at the same facility (Middletown or Gateway) simultaneously with the by-pass testing in order to "benchmark" the data from the by-pass vent to what we will receive from Haverhill for the other HAP emission sources. 
 Quench Tower Air Emissions Tests
 We are delaying a decision on quench tower air emissions testing at SunCoke pending further EPA considerations.  If we decide to require quench tower testing, we plan to allow quench tower air tests be done at any of SunCoke's four heat recovery facilities.
 We are retaining the Section 114 requirement for Suncoke to test quench water samples. Quench water testing should be done at the same facility as quench air emissions testing (if we decide to require such air emissions testing) and in the same time period, as described in the 2016 ICR; if we decide that quench air emissions testing is not required for SunCoke, quench water testing should be done at Haverhill along with the other tests required in the ICR
I hope this response is helpful to Suncoke.   

Please let me know if you have any questions. 
 
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
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"Reasonableness never fails to be appreciated."  - anon.





