From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Thursday, January 13, 2022 8:49 PM
To: 
SINGLETON, KRIS E. <KESINGLETON@SUNCOKE.COM>
Cc:
BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>; Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: Do you have time for a quick call


Thank you for your input to the EU cost estimates for a new heat recovery plant. I thought the numbers might be low. I will still cite the EU estimates but will add yours also.

As you may know, we will be deliberating about the rule and possibly re-running analyses right up to proposal, therefore I don't want to risk telling you something that might change. However, you will be able to respond in as much detail as you like during the comment period. The comment period starts when the rule is published in the FR but EPA posts the EPA version of the file on our website when it is signed. I can let you know where and when that is so you can get a head start. Sometimes the FR office makes more editorial changes after it leaves EPA and before it is published, but these are usually small changes.

I know you told me that Jewell does not have the space to add HRSGs, but I don't recall why Indiana Harbor-East Chicago cannot have more HRSGs to avoid the high number of bypass hours allowed by the state or if there is any other reason for the high number of hours as compared to the other 3 facilities. While you are doing this, you may add to the explanation for Jewell if you like, especially if there is more than just a space issue.

Thanks for getting back to me. Hope you are having a good start to the new year.

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: Thursday, January 13, 2022 8:20 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>; GABRIELLE RAYMOND <graymond@rti.org>
Subject: RE: Do you have time for a quick call

Hi Donna Lee,

I hope you had a wonderful holiday season and start to 2022.  I wanted to get back to you about the attached email and also ask you a follow up question or two regarding the information you provided below.

First, in response to the attached email, we cannot tell from the data provided whether it was intended to include HRSG costs, and that figure would be low even without HRSGs.  Based on our estimates, the cost of a new heat recovery plant with HRSGs would be on the order of $750 million for that size plant.

Regarding your email below, we greatly appreciate the information you've shared and EPA's willingness to incorporate some of our recommendations.  Can you also please give us an idea where EPA landed on cancer risk for nonrecovery plants?

More importantly, we are wondering what your current thinking is on potential updates to the standards for nonrecovery ovens in light of risk findings.  We know that you asked a number of questions late in 2021 about bypass venting in general and Jewell in particular, and we were hoping to minimize the possibility of new requirements that are not technically feasible being introduced in a proposed rule.  For instance, each plant is rather unique and that is why the bypass venting requirements vary among them.  We are happy to have a conversation with you and provide additional information to clarify anything.

Thanks!

Kris

Kris Singleton
Corporate Engineer  -  
Health, Environmental & Safety

 SunCoke Energy
office:  513-727-5518
cell:  513-649-1371


