From: 
Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov]
Sent:
Friday, September 25, 2020 2:58 PM
To: 
David Ailor <dailor@accci.org>
Cc:
'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: 
Re: Whole industry QA review of Coke data and calculations - schedule



If you need that long. We would prefer if facilities sent their information individually because we can only process one at a time anyway, so better for our workload. Can you send any before Oct. 19?

We will be sending the next set of data for review by 9/28. Our schedule is below and attached. We need to do the first model run in December before Ted leaves and finalize the risk results in January 2021 in order to make a December 2021 proposal date.

          Schedule for Coke Model File  -  Subpart CCCCC Risk Review
                                       
                                     Item
                                      EPA
                                   Industry
                                Tentative Date
                                       1
Develop file of emission factors and ICR data
 
                                     done
                                       2
 
Review of EF and ICR data
                                   Due 9/28
                                       3
Develop model "shell"
 
                                  Ready 9/28
                                       4
 
Review model "shell"-receive
                                 Receive 9/29
                                       5
Incorporate industry comments on EF&ICR data
 
                                   10/12/20
                                       6
Develop full emission file
 
                                   10/16/20
                                       7
 
Review model "shell"-due
                                   Due 10/19
                                       8
 
Review full emissions file-receive
                                 Receive 10/19
                                       9
Incorporate industry comments on model shell
 
                                   10/23/20
                                      10
 
Review full emissions file-due
                                   Due 11/09
                                      11
Conference call
Conference call
                                Week of 11/19?
                                      12
Prepare complete model file
 
                                     11/25
                                      13
Submit model file to EPA QA
 
                                   12/01/20
                                      14
Revise model file as needed
Respond to EPA questions
                                  12/2-12/17
                                      15
Final model file  -  post to website
 
                                   12/18/20
                                      16
Proposal target date
 
                                    12/2021


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.

Pronouns - She/Her/Hers
Salutation - Dr./Ms.


<< schedule-table.docx >>


                                       
From: David Ailor <dailor@accci.org>
Sent: Friday, September 25, 2020 2:32 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: 'GABRIELLE RAYMOND' <graymond@rti.org>
Subject: RE: Whole industry QA review of Coke data and calculations - 2nd group (left out of 1st email)- Sorry! 
 
Hi, Donna Lee.  Hope you're well.
 
I'm following up with you insofar as your Monday, September 28, deadline for the COETF's comments on the spreadsheets.  May we have an extension to Monday, October 19, to send you our comments?  Our review of them is taking a bit longer than we had hoped.  DCA
 
David C. Ailor, P.E.
President
American Coke and Coal Chemicals Institute
25 Massachusetts Avenue, N.W.
Suite 800
Washington, D.C. 20001
Phone: 703-795-3541
eFax.: 866-422-7794
dailor@accci.org
www.accci.org


 
From: Jones, DonnaLee [mailto:Jones.Donnalee@epa.gov] 
Sent: Wednesday, August 26, 2020 6:26 PM
To: Jay Cornelius <jcornelius@abccoke.com>; Bill Osborn <bosborn@abccoke.com>; 'Katie Kistler' <katie.kistler@aksteel.com>; Chris.Potts@aksteel.com; patrick.smith@mscarbonllc.com
Cc: GABRIELLE RAYMOND <graymond@rti.org>; David Ailor (dailor@accci.org) <dailor@accci.org>
Subject: Whole industry QA review of Coke data and calculations - 2nd group (left out of 1st email)- Sorry!
 
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.





