From: 
Zavoda, Rich <Rich.Zavoda@arcelormittal.com>
Sent:
Thursday, July 2, 2020 2:38 PM
To: 
Raymond, Gabrielle <graymond@rti.org>; Jones, DonnaLee <jones.donnalee@epa.gov>
Cc:
Skolnekovich, Danielle L <Danielle.Skolnekovich@arcelormittal.com>; Benoit, Simonne T <Simonne.Benoit@arcelormittal.com>
Subject: 
FW: Coke ICR QA - EPA follow-up questions - Monessen Response to EPA's 5/22/20 Questions - EPA responses to Monessen 6/19/2020 email - Monessen 7/2/20 response to EPA 6/23/20 request


We checked the data added by EPA from the 114 Request Test Report (2016) results previously provided on 6/19/20.  See the orange rows in the attached file Tab A-1. 

Minor issues found:
 Rows 39-44, 174-176, 183-191, 549-554, 786-788: Column B (file name was added " Arcelor Mittal Combustion Stack ICR Test Report 16-051."  
      Rows 39-41 and 549-551: Should not be PM2.5 Filterable, should just be PM filterable.  Change made in red.
 Rows 39-44, 174-176, 183-191, 549-554, 786-788: Columns F-M were blank, added data in red so we knew what test was being referenced.  We did not enter any other blank data in columns.
 It is assumed that Column BQ is in units of lbs/hr.  We suggest that USEPA clarify the column by adding the units.  
 MCEM: Note that EPA added MCEM (Rows 174-176 and 786-788). EPA and parts of the test report call the pollutant "Methylene Chloride Emission Matter."  It should technically be Methylene Chloride Extractable Matter.  Change made in red.  
 No data on Total OCDD and Total OCDF to provide.
Please see revised file with the comments referenced above in red.  

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

<< Copy of EPAreview-AM-Monessen-PA_IndustryQA_CokeOvens-Enclosure2_AMMreply 6.19.20_EPAQuestions6.23.20_CBE_QA_20200625_stb070120.xlsx >>

From: Raymond, Gabrielle <graymond@rti.org> 
Sent: Tuesday, June 23, 2020 4:32 PM
To: Zavoda, Rich <Rich.Zavoda@arcelormittal.com>; Jones, DonnaLee <jones.donnalee@epa.gov>
Cc: Skolnekovich, Danielle L <Danielle.Skolnekovich@arcelormittal.com>; Benoit, Simonne T <Simonne.Benoit@arcelormittal.com>
Subject: RE: Coke ICR QA - EPA follow-up questions - Monessen Response to EPA's 5/22/20 Questions - EPA responses to Monessen 6/19/2020 email

Hello, 

Thank you for providing your responses for the Monessen facility to the 5/22/2020 EPA questions.

Please see the attached file:
"EPAreview2-AM-Monessen-PA_IndustryQA_CokeOvens-Enclosure2_AMMreply 6.19.20_EPAQuestions6.23.20.xlsx"

The EPA responses to the 6/19/2020 Monessen email are in first tab `Facility&EPA Emails 6.19&23.20'.

Please review and revise as soon as you can.

Let us know if there are any questions.

Thank you again for your help!
Gabrielle

Gabrielle Raymond
RTI International
3040 Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709
Cell Phone:  (704) 796-7444
Office Phone:  (919) 541-7015


From: Zavoda, Rich <Rich.Zavoda@arcelormittal.com> 
Sent: Friday, June 19, 2020 1:46 PM
To: Jones, DonnaLee <jones.donnalee@epa.gov>; Raymond, Gabrielle <graymond@rti.org>
Cc: Skolnekovich, Danielle L <Danielle.Skolnekovich@arcelormittal.com>; Benoit, Simonne T <Simonne.Benoit@arcelormittal.com>
Subject: FW: Coke ICR QA - EPA follow-up questions - Monessen Response to EPA's 5/22/20 Questions - Stay Safe During the COVID Pandemic 

Dr. Jones and Gabrielle,

Please see the attached ArcelorMittal Monessen Coke ICR data file that was updated to address your questions. We have also provided the following description of the revisions below to assist with your review.
Excel file Tab A-1 revisions:
 We added column AD (shaded light green) to show that EPA column AC data (Total Pushing process time of 12 minutes) is incorrect. Total Pushing time is only relevant to Pushing Baghouse test and Total Pushing process time needs to be deleted for Battery Combustion Stack #2 and Quench Tower testing. 
 Similarly, Total Charging process time of 11 minutes appears incorrect and is now column AE. This time is not relevant to Battery Combustion Stack #2 and Boiler #1 and #2, Pushing Baghouse tests or Quench Tower testing results and should be deleted. 
 We added, as comments, in Column BG in rows 812 & 815 showing the corrected lb/hr values for Quench tower testing PM filterable and PM2.5 Condensable. For the relevant Pushing Baghouse test only, we filled in new Column BI, shaded light green, (Pushing Time min/hr), and RTI/EPA said in the 5/22/20 email below that they would fill in BH (Industry Revised Emission Rate  -  NOT ADJUSTED for non-detectable values).  Please let us know when and how the emissions will be properly corrected to account for testing with non-detectable results so that EPA's emission estimates do not overestimate the emissions.
 Battery Combustion Stack #2  -  "USEPA is asking for PM2.5 filterable and PM2.5 condensable (highlighted orange in rows (39-44), TSO (Rows 174-176), SO2, CO and HCl (Rows 183-191).  In the test report (page 8 of pdf), it states that USEPA approved previously submitted testing which exempted them from conducting additional testing for TSO, HCl, PM2.5, condensable PM, SO2 and CO at the Battery 2 Combustion Stack.  Therefore, testing was not completed for the aforementioned constituents." Response: See attached Battery Combustion Stack #2 requested 2016 test results.
 Pushing Baghouse  -  "USEPA is asking for PM2.5 filterable and PM2.5 condensable (highlighted orange in rows (549-39-554, TSO (Rows 786-788), SO2, CO and HCl (Rows 795-803).  In the test report (page 8 of pdf), it states that USEPA approved previously submitted testing which exempted them from conducting additional testing for TSO, HCl, PM2.5, condensable PM, SO2 and CO at the Pushing Baghouse Stack.  Therefore, testing was not completed for the aforementioned constituents."  Response: Requested Pushing Baghouse 2016 test results will be provided in a second email due to the size of the requested test results files.

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
From: Raymond, Gabrielle <graymond@rti.org> 
Sent: Friday, May 22, 2020 9:33 AM
To: Jones, DonnaLee <jones.donnalee@epa.gov>; Zavoda, Rich <Rich.Zavoda@arcelormittal.com>
Cc: Gammon, Marian <Marian.Gammon@arcelormittal.com>; Skolnekovich, Danielle L <Danielle.Skolnekovich@arcelormittal.com>
Subject: RE: Coke ICR QA - EPA follow-up questions

Hello,

After sending the EPA follow-up questions file, Donna Lee realized we could enter the previous test data.

We've updated those EPA comments to "EPA will fill in previous data" in the attached file. 
EPAreview-AM-Monessen-PA_IndustryQA_CokeOvens-Enclosure2_EPA-Questions-R.xlsx

Thank you,
Gabrielle


Gabrielle Raymond
RTI International
3040 Cornwallis Road
P.O. Box 12194
Research Triangle Park, NC 27709
Phone:  (919) 541-7015

From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Thursday, May 21, 2020 8:04 PM
To: Zavoda, Rich <Rich.Zavoda@arcelormittal.com>
Cc: Gammon, Marian <Marian.Gammon@arcelormittal.com>; Skolnekovich, Danielle L <Danielle.Skolnekovich@arcelormittal.com>; Raymond, Gabrielle <graymond@rti.org>
Subject: Coke ICR QA - EPA follow-up questions


Hello Rich, et al. Hope everyone is doing OK. Thank you for your review of the ICR data for AM-Monessen-PA. We have comments and requests for corrections/additional data, and also responded to your questions&comments. These are listed in the first new worksheet (shown partially below) and in column BO of worksheet A-1.

Please provide your changes/additions in 30 days from receipt of this email. Thank you again for all your work on this ICR. Your effort is greatly appreciated.

EPA Questions for Facility
1. Please provide revised concentration data (in Column BC) and emission rate data (in Column BG) WITHOUT adjusting for non-detect runs.
2. Please provide the Pushing Time (min/hr) to use to adjust the pushing lb/hr values in column BH for the applicable pushing tests. [We tried using 12 minutes from Table 10 of test report, but that doesn't seem to match the revised values industry provided].
3. Please provide missing data highlighted in brown 
4. See EPA Review Comments of Industry QA Revisions/Comments in Column BO.

Note, EPA edits made in worksheet #A-1. Air Stack Tests" to fix transcription errors are in green font and are blue highlighted.

Facility email notes with added EPA responses/questions in green font, below.


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.





