From: 
BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Sent:
Thursday, April 13, 2017 11:04:56 AM
To: 
Jones, DonnaLee; RBrager@bdlaw.com; john.r.carson@aecom.com; ASchnur@bdlaw.com
Cc:
Shappley, Ned; Lowe, Theresa; Seidman, Emily; Kakade, Seema
Subject: 
RE: EPA Review of Test Plan for SunCoke Gateway By-pass Stack


Thank you, Donna Lee.

With the removal of the requirement for simultaneous testing, we believe we can conduct the testing in accordance with the methods.  We are revising our internal test plan based on our previous discussions.  We are currently planning to conduct the testing in May at our Granite City facility and in June at our Middletown facility.  We plan to have the data entered into the Electronic Reporting Tool no later than Nov 1st.

Please let me know if you  have any questions.

Thanks,
Katie



From: Jones, DonnaLee 
Sent: Tuesday, March 28, 2017 2:30 PM
To: KMBATTEN@suncoke.com; 'RBrager@bdlaw.com' <RBrager@bdlaw.com>; 'john.r.carson@aecom.com' <john.r.carson@aecom.com>; 'ASchnur@bdlaw.com' <ASchnur@bdlaw.com>
Cc: Shappley, Ned <Shappley.Ned@epa.gov>; Lowe, Theresa <Lowe.Theresa@epa.gov>; Seidman, Emily <seidman.emily@epa.gov>; Kakade, Seema <Kakade.Seema@epa.gov>
Subject: EPA Review of Test Plan for SunCoke Gateway By-pass Stack

Hello  -  As per the last issue remaining on the submitted SunCoke Test Plan for upcoming tests at Gateway at the by-pass stack, we have considered your request for a modification of the upcoming testing to only use two ports with a 7-foot probe, a less than a full traverse in each port, as opposed to the EPA method requirement for a full traverse with a 9-ft probe in two ports or 4 ports using the 7-ft probe. We retain the requirement for a full traverse with either 9-foot probes out of two ports, or 7-ft probes in all four ports. This is standard measurement testing protocol from which we cannot deviate, especially for a rulemaking ICR. However, we are offering one modification of your testing requirements to alleviate the difficulty of the testing as well as three suggestions to address safety.

 Remove the requirement in the ICR for simultaneous testing, as per Table 1-C and section 1.3 in the ICR, Enclosure 2 (dated 6/24/16). All the required tests still need to be done, just not simultaneously. However, we retain the requirement for a full traverse with either 9-foot probes out of two ports, or 7-ft probes in all four ports. 
 A suggestion from the test team to make it easier to test on both sides of the stack is to leave the impingers half-way between the two sets of ports so that the impingers do not have to be moved when switching from one side of the stack to the other.
 A suggestion to address issue of protecting testers from hot gases possibly coming down onto the test platform is to install a temporary (or permanent) cover or roof on the test platform to shield workers from any down flowing gas.
 Another suggestion to address hot gases coming down onto test platform is to install a second level of the test platform below the existing platform to enable workers to descend for safety in case of sudden wind change. This design was used recently by Arcelor Mittal at their Monessen facility to successfully test their quench tower for the ICR, another ICR test unit that has safety issues with hot gases.
         
If you would like a contact at Arcelor Mittal to discuss their two-story test platform, I can provide you with the information. Alternatively, David Ailor also has the Arcelor contact information.

If you have any questions about the above, please feel free to contact me.
_____________________________________________________________
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.


