From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Tuesday, September 8, 2020 12:19 PM
To: 
BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc:
SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>; Raymond, Gabrielle <graymond@rti.org>
Subject: 
Re: Whole industry QA review of Coke data and calculations


Hi. My comments below in red CAPS highlight. Please also copy RTI when you respond. I believe this request was in original email. 

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: Friday, September 4, 2020 1:21 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Subject: RE: Whole industry QA review of Coke data and calculations 
 
Hi Donna Lee,
Thank you for sending this over and giving an opportunity for us to provide input.  Before we send our comments back, it would be helpful to have your input on three questions:
 In the Excel file (Coke Ovens-Example Emission Calcs-Aug_2020.xlsx), we noticed that there is a column for industry comments, "COMMENTS" MAY INCLUDE REVISED VAUES BUT NOTE IN COVER EMAIL TO MAKE CLEAR. but no column for revised values. In recent RTRs, EPA has made a draft RTR emissions risk modeling file available, with fields to provide revised values for each input. For example, EPA made this type of file available for the Copper Smelting RTR on 2/26/2020: https://www.epa.gov/stationary-sources-air-pollution/primary-copper-smelting-national-emissions-standards-hazardous-air (see link for "DRAFT Primary Copper RTR Emissions Risk Modeling File" in the Additional Resources section). BEST TO LOOK AT STEEL RULES FOR MY PROTOCOLS. I DID THIS ALSO FOR INTEGRATED IRON AND STEEL (SUBPART FFFFF).
      Does EPA plan to provide a draft risk modeling file at a later date, YES or should we provide revised values at this time?  We expect to have a number of changes to emission factors to provide. PLEASE PROVIDE EMISSIONS NOW BUT CAN ALSO DO IT LATER. PREFER NOW BECAUSE WE ARE DOING EMISSIONS NOW. NEW INFO IN MODELING FILE IS MOSTLY LOCATION AND OTHER PHYSICAL DATA..
       
 Does EPA plan to estimate fugitive emissions from sources under this source category?  If so, what methodology will be used? WE WILL ESTIMATE PUSHING FUGITIVES, ESPECIALLY FOR BYPRODUCT. DO YOU HAVE ESTIMATES FOR YOUR FACILITIES?
       
 How does EPA plan to conduct the multi-pathway risk assessment if more than one facility results in risks above the Tier 2 multi-pathway threshold? WE HAVE DONE ALL NECESSARY FACILITIES IN PAST FOR STEEL SOURCES. FOR COKE, WE WILL NEED TO SEE SCREENING RESULTS FIRST. We have noticed that in recent RTRs, EPA does a site-specific risk assessment only for the facility with the highest Tier 2 multi-pathway screening value for each exposure scenario (e.g. fisher or farmer) and only for that exposure scenario. Do you expect to follow the same methodology for this RTR? WE DO WHAT IS APPROPRIATE FOR THE AREA. NEED NEARBY WATER BODIES FOR FISHER.
 
We look forward to your responses, and please let us know if you have any follow-up questions.  Have a good weekend!
 
Thank you,
 
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: Wednesday, August 26, 2020 11:32 AM
To: Rich.Zavoda@arcelormittal.com; Marian.Gammon@arcelormittal.com; 'Charles Jones' <cjones@bluestonecoke.com>; Brenna M Harden <brenna.harden@dteenergy.com>; Robert B Sanch <robert.sanch@dteenergy.com>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>; BJTunno@uss.com; JSScheetz@uss.com
Cc: David Ailor (dailor@accci.org) <dailor@accci.org>; Raymond, Gabrielle <graymond@rti.org>
Subject: Whole industry QA review of Coke data and calculations
 
 
Hello all - We have finished tabulating all of the test data and developing emissions (lb HAP/ton coke, lb HAP/hr, and/or ton HAP/year) from the test facilities, as well as generating default HAP emission factors (lb HAP/ton coke produced or lb HAP/hr) for facilities that did not test or did not do all tests. 
 
Please review and send your comments back (either in the spreadsheets themselves and/or with attached comments) on or before September 28, 2020 (Monday). 
 
I tried to send this email to at least two people per company for all facilities, to make sure I include at least one correct person who can  distribute this QA review to all their company's facilities. Please let me know if I should substitute or add someone else for future emails about the EPA Coke data or the QA.
 
The attached files are listed below with a description of their contents: 
1.    CokeOvens-Estimates&Assumptions-Aug_2020 (Word file) 
 Explains the assumptions and estimates used in the Excel spreadsheets. 
 
2.    CokeOvens-Example Emission Calcs-Aug_2020 (Excel file) 
 Example calculations for Antimony (Sb) emissions using test data from facilities who tested, for each source category process (EP-1 through EP-9*). The spreadsheet takes the calculations through a complete calculation sequence as an example of what will be done for all HAP tested. 
 Shows the default emission factors developed from the test data that will be used for Antimony, as an example HAP, for facilities without test data for the indicated process, to be done next for all HAP tested. 
 Shows the application of the default emission factors for Antimony to all facilities without test data for the indicated process to calculate tons Antimony (Sb)/year, to be done next for all HAP.
 
 The CU (Capacity Utilization) worksheet shows the production values reported to the EPA and the values estimated by the EPA for use in the emission calculations and estimates, for all coke facilities.  
 Erie production values from test data (wet/dry coal charged/pushed, and total coke) and ratios developed from these data, to be used to estimate production for facilities without complete production data. 
 
3.    CokeOvens-Enclosures-1&2-QA-Whole_Industry-Emissions-Test-Data-Aug_2020 (Excel file) 
 All of the previously reviewed (by individual facility) run-by-run stack test (air) data for all pollutants from test facilities and the EPA calculations made using the test data to produce lb HAP/hr and lb HAP/ton coke emission factors for all HAP.
 Industry default emission factors to be used as default for all HAP, for facilities without test data, developed as described for Antimony in Example Emissions Calcs file. 
 Battery (physical) dimensions to be reviewed by industry facilities. 
 Oven and battery count from the ICR and previous EPA report (2001 BID). 
 Same CU (Capacity Utilization) and Erie production worksheets, as described above for the Example Emissions Calcs file.   
 All other test data submitted in the ICR, such as water and opacity tests, COG tests, material tests, etc., which may not be completely summarized, as yet, by the EPA. 
 
Next step will be for EPA to use the approach shown in the Example Emission file and data in the Whole Industry Emissions file to generate all HAP emissions for all coke facilities.  
 
If you have any questions before 9/28/20, please contact Gabrielle AND me by email, and one of us will get back to you. 
 
  * EP-1 BP Pushing (CD), EP-9 HNR Pushing (CD), EP-3 BP Combustion Stacks, EP-4 BP Boiler Stacks, EP-6 HRSG Main Stacks, EP-7 HRSG Bypass-Waste Heat Stacks, EP-8 HNR Charging (CD), EP-10 Quench Tower.
 
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.


