From: 
Zavoda, Rich <Rich.Zavoda@arcelormittal.com>
Sent:
Sunday, February 9, 2020 9:21 PM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>; Raymond, Gabrielle <graymond@rti.org>
Cc:
Zavoda, Rich <Rich.Zavoda@arcelormittal.com>; Maciel, Robert A <Robert.Maciel@arcelormittal.com>; Benoit, Simonne T <Simonne.Benoit@arcelormittal.com>
Subject: 
FW: September 2019 QA/QC Review of Enclosure 2 Information for EPA 2016 ICR for ArcelorMittal (Excel file) Burns Harbor


Dr. Jones

Thanks for the opportunity to review the draft information.  Attached is the updated Coke ICR Enclosure 2 excel file for ArcelorMittal Burns Harbor. We reserve the right to provide additional information in the future as may be appropriate.

Toluene Soluble Organic (TSO) Lab Contamination Invalidates TSO Results
ArcelorMittal received the 2016 Coke ICR from USEPA on April 4, 2016.  The 2016 Coke ICR included the use of Method 315 (Particulate and Methylene Chloride Extraction Matter (MCEM), except that USEPA specifically required that the standard method extraction solvent of methylene chloride be substituted with the use of toluene to determine emissions of Toluene Soluble Organics (TSO).  The attached March 10, 2017 Maxxam laboratory evaluation (pages 29-34 of the Pushing Baghouse stack test report) concluded that the use of toluene (instead of methylene chloride, as the extraction solvent of the filter and probe rinse, resulted in significantly elevated toluene filter extraction blanks and toluene laboratory processed blank results that cannot be related to the sampled sources and must be considered when attempting to report the actual Method 315 values.  

See the previously submitted individual stack test reports for additional TSO lab contamination details, including the ArcelorMittal Burns Harbor No. 2 Battery Underfire Combustion Stack test report and the attached Pushing Baghouse stack test report. 

The attached Pushing Baghouse stack test report (page 25) stated, "These reported Modified Method 315 (TSO) results do not fully account for the magnitude of the documented blank contamination value. Please see Section 2.0 and Maxxam Analytics' Modified Method 315 (TSO) White Paper dated March 10, 2017 provided in Appendix A that states, "The toluene filter extractable blank 90% upper confidence interval of 11.18 mg of residue is 43 times the Method 315 acceptable methylene chloride blank value of 0.26 mg of residue. This suggests the use of toluene extraction solvent to be the cause of the high bias residue results." 

"The toluene laboratory processed blank of 8.5 mg of residue is more than 17 times the methylene chloride laboratory processed blank of 0.5 mg of residue. This again, would suggest the use of the toluene extraction solvent to be the cause of the high bias residue results." Please see Appendix E for sample calculations in laboratory weight sheet."

Rich Zavoda | Regional Manager, Air Quality Program
ArcelorMittal USA
Environmental Affairs| 4020 Kinross Lakes Parkway, Richfield, Ohio 44286-9000
T +1 330 659 9163 | F +1 330 659 7434 | www.arcelormittal.com

<< Burns Harbor Coke ICR Pushing Baghouse 4.7.17 Final pgs 1_35.pdf >>
<< AM-BH-IN-CokeOvens-Enclosure2-QA-Emissions-Data-Sept-2019-IndustryQA_AM-BurnsHarbor-IN AMBH 2.7.20.xlsx >>

From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Wednesday, September 4, 2019 5:05 PM
To: Zavoda, Rich <Rich.Zavoda@arcelormittal.com>
Cc: GABRIELLE RAYMOND <graymond@rti.org>
Subject: September 2019 QA/QC Review of Enclosure 2 Information for EPA 2016 ICR for ArcelorMittal (Excel file)

Rich  -  Thank you again for your efforts in providing your facility information. Now is the time to correct, update, or add to your responses from 2016 for Enclosure 2. Attached is your facilities' information in one Excel file each.

Please refer to the `Review Instructions' worksheet of the attached spreadsheet for specific review instructions.
The Enclosure 2 data are organized into three groups within the spreadsheet:
A. Air Stack Tests
B. Process Data
C. Non-Stack Test Data (e.g., Opacity, Water Tests, Material Tests, COG Tests, etc.)

Resources worksheets (tabs R-1 through R-4) also are available for your reference and use. 
Please review all data compiled by the EPA Contractor. If your data is not correct, please revise or add it to the applicable worksheet. Highlight (in yellow) any changes made with any cell and describe the change in the "Facility Review Comments" column of the applicable worksheet.
If any of the currently missing information is considered "confidential business information" (CBI), please note "CBI" in the empty data cell. Then please provide this CBI information using the CBI procedures described in the original ICR letter sent by EPA in 2016. We can provide again if needed.
If you have any questions, please first send an email to BOTH Gabrielle Raymond, the EPA contractor from RTI, and me at the email addresses below. If we need to speak on the phone, we can follow-up with a call, but we need an email first to ensure contact.
graymond@rti.org
jones.donnalee@epa.gov  

We will be entering your Enclosure 2 data into the Coke oven RTR subpart CCCCC Modelling file soon after the first of the year 2020, so we need to get all the QA/QC work done during the Fall 2019. 
Note that we will be summarizing CBI data in Enclosure 1 separately at some not yet determined point in the future. 
Thank you in advance for your work, time and expense helping us get good quality data. 
_____________________________________________________________
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 Gr (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.




