From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Monday, July 6, 2020 4:43 PM
To: 
Zavoda, Rich <Rich.Zavoda@arcelormittal.com>; Raymond, Gabrielle <graymond@rti.org>
Cc:
Skolnekovich, Danielle L <Danielle.Skolnekovich@arcelormittal.com>; Benoit, Simonne T <Simonne.Benoit@arcelormittal.com>
Subject: 
Coke ICR QA - EPA follow-up comments 7/6 - Monessen Response 7/2


Hello all  - We reviewed your file and email comments. See further below in red for our responses to your minor issues. Note we will be using our data for  "Column BG Concentration -- NOT ADJUSTED for non-detectable values" and "Column BQ Emission Rate -- NOT ADJUSTED for non-detectable values" unless we hear back from you that you need to review these data.  
       
      If you want to review these data, let us know you are doing this by sending an mail first, and then work on sending us any revisions into the columns we specified for your revision file: 
       
            Any further revisions, please fill into Columns BJ-BL respectively for concentration values. 
             
            Any further revisions, please fill into Columns BS-BT respectively for emission rate values.
 
Your email: 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."  
EPA used the file "ArcelorMittal Monessen EPA Section 114 Request Emissions Test Report 16-093.pdf" to fill in the data that you submitted originally. We received 13 pdf files via two emails on 6/19/2020 with 2016 results for the Battery Combustion Stack #2 2016 test results and Pushing Baghouse 2016 test results. We compared the data provided in these 13 pdf reports to what we had already compiled and confirmed the data values were the same. We do NOT to have a file named "Arcelor Mittal Combustion Stack ICR Test Report 16-051.pdf"  But if the data are the same between the files EPA used and your ".....ICR Test Report 16-051.pdf" we would not need to reference the other report. We will note this duplicate report in our records. 
 Rows 39-41 and 549-551: Should not be PM2.5 Filterable, should just be PM filterable.  Change made in red.
      EPA will update.
 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.
      EPA will update.
 It is assumed that Column BQ is in units of lbs/hr.  We suggest that USEPA clarify the column by adding the units.  
      EPA will add. Yes, column BQ "Emission Rate -- NOT ADJUSTED for non-detectable values" is units of lbs/hr. We will make sure the final test data spreadsheet is clear in the headings that Emission Rate are units of lbs/hr. 
 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.  
EPA will update.  
 No data on Total OCDD and Total OCDF to provide.
Noted.
 
 Thank you!


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: Zavoda, Rich <Rich.Zavoda@arcelormittal.com>
Sent: Thursday, July 2, 2020 2:56 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: 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 - Monessen 7/2/20 response to EPA 6/23/20 request 
 
Dr. Jones, 
 
Be Safe and Keep Well in these very interesting times. Enjoy the holiday weekend too.
 
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: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Thursday, July 2, 2020 2:47 PM
To: Zavoda, Rich <Rich.Zavoda@arcelormittal.com>; Raymond, Gabrielle <graymond@rti.org>
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 - Monessen 7/2/20 response to EPA 6/23/20 request
 
Thank you for your review and comments. We will get back to you soon, likely next week. Hope you all are well and will have a good holiday weekend. 
 
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: 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
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
 
EXTERNAL:  This email originated from outside of the organization.  Do not click links or open attachments unless you recognize the sender and know the content is safe.
 
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.


