From: 
BATTEN, KATIE M [mailto:KMBATTEN@SUNCOKE.COM]
Sent:
Friday, February 17, 2017 1:41 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


Hi Donna Lee,

Attached is our draft test protocol for the ICR testing.  There are several test method deviations that we are requesting.  Several of these have already been discussed with EPA and the remaining are minor deviations.  I have included a list of these deviations in the table below and they are included, with more details, in the draft protocol.  Please let me know if you would like to set up a call or a meeting to discuss the deviations or the test protocol.  

                                   Deviation
                              Location in Report
                                    Comment
Modified traverse for bypass vent stacks
3.2.4.1, 3.2.8.2, 3.2.9.1, 3.2.10.2, 3.2.11.1
Protect air-cooled integrated nozzle/probe where there is restricted working space and access
Alternate HCN impinger solution
3.2.7.1
Use of 2% zinc acetate
Combine M26 and OTM-29 trains
3.2.7.2
Reduced number of sampling trains
Alternate solvents for CARB 428/429 train
3.2.8.1
Eliminate field use of methylene chloride
Alternate nozzle
3.2.7.3, 3.2.9.2, 3.2.10.1
Glass nozzle likely to break in PCM and hot car stacks
Collect sample for H2S in gas bags
3.2.12.1
Based on discussion in ICR Frequently Asked Questions (Set #6)
Alternate times for opacity observations
3.2.14.1
Pushing and charging performed at night
Demonstrate no leaks by negative pressure instead of visible observations
3.2.15.1
Use MACT procedure
Using CEMs on flat push hot car
3.2.17.1
Monitor continuously
CO2 and O2 on moving equipment
3.2.17.2
Bag sample
Analysis procedure for mercury
3.2.18.1
Expand measured concentration range

Thanks and have a great weekend.

Katie


<< SunCoke ICR Test Plan for EPA 20170217.pdf >>



-----Original Message-----
From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov] 
Sent: Friday, February 10, 2017 9:30 AM
To: BATTEN, KATIE M; Robert Brager; Seidman, Emily
Cc: Kakade, Seema
Subject: Re: SunCoke CAA 114 Request - Meeting Follow Up - EPA response

Thank you for your note. Yes, it will be OK with me for Suncoke to switch testing to accommodate production shifts in the company.

Looking forward to your draft test plan.

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: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Sent: Thursday, February 9, 2017 8:14:22 PM
To: Jones, DonnaLee; Robert Brager; Seidman, Emily
Cc: Kakade, Seema
Subject: RE: SunCoke CAA 114 Request - Meeting Follow Up - EPA response

Hi Donna Lee,

Thank you for speaking with me the other day regarding the facility location where we will perform the Enclosure 2 testing.  As I explained, our Haverhill facility is on reduced charge weights due to customer demand for the remainder of this year.  Our Middletown facility was originally planned to be operating at normal charge weights; however there has been some very recent discussion of reducing charge weights at the Middletown facility as well, although any reduction has not been finalized.  SunCoke feels that the test results (for pushing, charging, main stack and quench water) will be most representative of normal heat-recovery coking operations if the testing is performed under normal charge weights.  SunCoke has reviewed operations and customer contracts for the two sites and has determined that the Middletown facility can more feasibly support conducting the ICR testing under normal charge weights.  The Middletown facility will either be already operating at normal charge weights when the testing occurs, or the facility would ramp up charge weights prior to beginning the ICR testing and maintain normal charge weights for the duration of the testing.  A short term ramp up in charge weights can be done more easily and more feasibly at the Middletown facility due to customer agreements and overall plant operational capability.

During our call, you indicated that SunCoke may choose which facility it plans to conduct the testing at.  Therefore, SunCoke plans to conduct the testing (pushing, charging, main stack and quench water) at the Middletown facility, not the Haverhill facility, for the reasons outlined above.  The bypass vent stack testing will still be completed at the Granite City facility in May.

We have nearly completed the draft test protocol for your review and will send it early next week.  Please let me know if you have any questions.

Thanks,

Katie

Katie Batten
Corporate Environmental Manager

1011 Warrenville Road, 6th Floor
Lisle, IL  60532

off: 630-824-1786
cell: 740-370-8710
off: 740-355-9871





