From: 
SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Sent:
Sunday, December 20, 2020 6:05 PM
To: 
Jones, DonnaLee <jones.donnalee@epa.gov>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: SunCoke's review - EPA review questions


Hello. Sorry for the delay in responding. I've been on vacation since 12/11.

To answer your question, some of the changes were due to more recent stack testing data. In other cases, the new data was from prior stack test reports for those facilities/emission points that were not specifically tested under the ICR. 

I probably should have discussed this with you first. Sorry if this has caused any confusion.  So what is the agency's position regarding:
 More recent test data (conducted after the ICR testing), and
 Site-specific test data for sources that were not tested under the ICR?

I will get back to you regarding your other questions/request for data later this week.
Thanks!

Kris

From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Thursday, December 10, 2020 6:14 PM
To: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: Raymond, Gabrielle <graymond@rti.org>
Subject: Re: SunCoke's review - EPA review questions

Hi. We are looking over your recent submissions and noticed differences in temperature and velocity for some sources compared to what was in the test reports that we received for the 114 ICR. These sources are listed below with the differences between the two sets of data. What is the rationale for these changes? Do you have more recent test reports with this new information? If so, please send. Otherwise, we will need to keep the ICR values that accompanied the emissions data we are using in the modeling.

The EP-9 HNR Pushing (CD) temp change is about 14% difference
 The EP-9 HNR Pushing (CD) velocity change is about 15% difference
 The EP-8 HNR Charging (CD) temp changes range from about 5% to 46% difference.
 The EP-8 HNR Charging (CD) velocity changes range from about 40% to 68% difference

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.


                                       
From: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Sent: Tuesday, November 24, 2020 12:16 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: Raymond, Gabrielle <graymond@rti.org>
Subject: RE: SunCoke's review - target date 
 
Ok. Thanks for the clarification!
 
Kris
 
From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Tuesday, November 24, 2020 12:13 PM
To: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: Raymond, Gabrielle <graymond@rti.org>
Subject: Re: SunCoke's review - target date
 
I forgot to mention that we are looking for all industry comments to be returned to EPA by 12/24 so we can work on the revisions between holiday breaks (when its quiet around EPA). 
 
The items we need from SunCoke are listed below:
 
Whole Industry EF and ICR Data:
   ·        Control efficiency from the pushing multiclone; 
   ·        How to calculate lb/ton coal charged for charging units;
   ·        Confirm lb/ton coke produced is okay for pushing units.
·  Modeling Shell:
 Review and respond to EPA's responses.
Other Emissions Files:
 Review and respond.
Thanks!
 
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.
 
 
                                       
From: SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Sent: Tuesday, November 24, 2020 9:02 AM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>; BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: Raymond, Gabrielle <graymond@rti.org>
Subject: RE: EPA responses to SunCoke's review of coke modeling file shell 
 
Thanks Donna Lee. We will let you know if we have any follow-up comments.
 
Hope you have a nice holiday as well!
 
Kris
 
From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Monday, November 23, 2020 5:10 PM
To: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>; SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Cc: Raymond, Gabrielle <graymond@rti.org>
Subject: EPA responses to SunCoke's review of coke modeling file shell
 
Hello Kris and Katie,
 
Thank you again for your review of the coke modeling file shell. Please see attached for EPA Responses to SunCoke's review of the coke modeling file shell. CokeOven_CategoryNonCategory_RTR_ModFile_20201015-Suncoke_comments_EPA-responses-11-23-20.xlsx.  Column F in this file has the EPA responses. Please provide any follow-up industry responses in Column E and also let us know if we have missed anything that already has been revised.
 
Color Key:
EPA concurs and will update
EPA has followup questions/does not concur
 
We noticed that SunCoke made revisions/comments to the model file shell in the following two main categories: 
-Changing pushing&charging units from mobile line sources to point sources.
-Combining pushing&charging units that serve multiple batteries. 
 
For EP-9 HNR Pushing (CD) line source units, the release point width will be the width of the stack. For fugitive pushing emissions, the source width will be the default width of 0.9 m (to represent edge of the battery where the escaping emissions would come from). For EP-8 HNR Charging (CD) line source units, the width will be the physical battery width. 
 
This is the same protocol used for all mobile units and pushing fugitives in the by-product industry.
 
We hope you both have a good holiday, as best as possible under these unique circumstances.
 
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.


