From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Wednesday, June 24, 2020 2:49 PM
To: 
BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
Re: Updated Enclosure 2 Data - May 20, 2020


Yes, of course we will deal with nonrecovery differently, especially for regulatory purposes, i.e., any changes to the current MACT. The by-product chemical recovery plants will be noncategory emissions and included in the risk assessment for by-product plants but the locations will indicate that these are not co-located at nonrecovery plants. 

You bring up a good point, however, about separating risk for subcategories. Although we are compiling all of the industry data together in same modelling file for ease of data entry and QA, we will likely want to separate the subcategories into separate modelling files before modeling. But we will report separate and combined risk in the preamble and risk documents, but we will only use the individual subcategory risk and emission data for any regulatory decisions. Even if combined, we would indicate zero risk reduction for nonrecovery plants if, for example, we lowered one of the emission limits for by-product, and vice versa.

I don't know anything off hand that we might need to do as far as "gap filling."  I will check with RTI on this to be sure. Did you have anything specifically in mind? For noncategory sources other than chemical recovery, we use the NEI, but the database has specific locations, which will indicate at which plants the noncategory sources are co-located, so that wont be a problem either.

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: Wednesday, June 24, 2020 2:16 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Subject: RE: Updated Enclosure 2 Data - May 20, 2020 
 
Hi Donna Lee,
 
You should now have all the reviewed Enclosure I and II data from SunCoke.   Thanks for your patience with us.  
 
I also wanted to reach out to you on a related MACT Subpart CCCCC RTR issue.  As you know, SunCoke plants have a different technology and different source profile than byproduct plants; there are numerous emissions units and processes at a byproduct plant that are not present at a nonrecovery plant, resulting in a very different emissions profile.  For example, some of those processes at byproduct plants are regulated under Part 61 Subpart L for benzene emissions.  Additionally, the MACT floor for Subpart CCCCC was set independently for nonrecovery and byproduct plants when those regulations were first promulgated, and as a result, different regulations apply to them.  
 
We are therefore wondering whether EPA is planning to conduct the risk assessment for nonrecovery plants separately from its risk assessment for byproduct plants?  SunCoke's view is that separate risk assessments should be conducted (i.e. determining cancer risk and hazard index independently) because they are distinct subcategories of sources.  We also have a concern that a joint risk assessment using the same gap-filling methodology to estimate emissions for both subcategories of sources would potentially overestimate emissions and risk for nonrecovery plants.
 
Please let us know your thoughts and if it would be helpful to discuss further.
 
Thanks,
 
Katie Batten
Director of Health, Safety and Environmental
 
SunCoke Energy, Inc.
kmbatten@suncoke.com
cell: 740-370-8710
 
From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Thursday, June 18, 2020 3:30 PM
To: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>; Raymond, Gabrielle <graymond@rti.org>
Cc: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Subject: Re: Updated Enclosure 2 Data - May 20, 2020
 
Yeh! Thank you very much, I appreciate all your work on this. Take care.
 
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: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Sent: Thursday, June 18, 2020 3:13 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>; Raymond, Gabrielle <graymond@rti.org>
Cc: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Subject: RE: Updated Enclosure 2 Data - May 20, 2020 
 
Hello,
 
Please see the attached updated Enclosure 2 data files for SunCoke Granite City and Middletown. Sorry for the delay.
Let us know if you have further questions.
Thanks,
 
Kris
 
Kris Singleton
Corporate Engineer  -  
Health, Environmental & Safety
 
 SunCoke Energy
office:  513-727-5518
cell:  513-649-1371
 
 
From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Wednesday, May 20, 2020 8:05 PM
To: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: Raymond, Gabrielle <graymond@rti.org>
Subject: Re: Updated Enclosure 2 Data - May 20, 2020
 
Thanks for letting me know. Look forward to your files. Take care.
 
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: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Sent: Wednesday, May 20, 2020 4:34 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: Raymond, Gabrielle <graymond@rti.org>
Subject: RE: Updated Enclosure 2 Data - May 20, 2020 
 
Hello! 
 
We haven't forgot about this and are actively working on it. Hope to get you something soon. As you can imagine, things have been a little crazy with COVID and all...
Sorry for the delay!
 
Kris
 
From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Wednesday, May 20, 2020 2:48 PM
To: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: Raymond, Gabrielle <graymond@rti.org>
Subject: Re: Updated Enclosure 2 Data - May 20, 2020
 
".... checking on the status of the Enclosure 2 data files for the SunCoke Granite City, IL and Middletown, OH facilities."
 
Hope you all are doing OK. 
 
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: Raymond, Gabrielle <graymond@rti.org>
Sent: Friday, May 8, 2020 10:59 AM
To: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Subject: Updated Enclosure 2 Data 
 
Hello,
 
Thank you for submitting the SunCoke test reports to the FTP site and the revised SunCoke Enclosure 1 data file.
 
We were just checking on the status of the Enclosure 2 data files for the SunCoke Granite City, IL and Middletown, OH facilities.  
 
Attached are the files sent to you on 9/4/2019 in case you need another copy.
 
Thank you,
Gabrielle
 
 
Gabrielle Raymond
RTI International
3040 Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709
Phone:  (919) 541-7015


