From: 
David Ailor <dailor@accci.org>
Sent:
Tuesday, August 2, 2022 2:53 PM
To: 
French, Chuck <French.Chuck@epa.gov>; Jones, DonnaLee <Jones.Donnalee@epa.gov>
Subject: 
COETF Letter Detailing Concerns Regarding EPA's June 28, 2022 Coke Ovens Section 114 Information Collection Requests (ICRs)


Dear Mr. French and Dr. Jones:

On June 29, 2022, the four member companies of the Coke Oven Environmental Task Force (COETF) received Clean Air Act Section 114 Information Collection Requests (ICRs) from EPA.  The ICRs relate to the ongoing Pushing, Quenching, and Battery Stacks (PQBS) 40 CFR Part 63 Subpart CCCCC Risk and Technology Review (RTR) and the technology review for Coke Batteries under 40 CFR Part 63 Subpart L, but also include testing, interior and fenceline monitoring, and other information collection activities related to potential new regulations for coke byproduct recovery plants (CBRP).  

The COETF engaged Trinity Consultants (Trinity) to assist us in assessing concerns with the ICRs.  Trinity has identified a number of safety, technical and schedule concerns insofar as the proposed ICR testing requirements and other information collection activities.  Attached to this e-mail is an August 2, 2022, letter from me to you setting forth the concerns of the COETF on the ICRs, reflecting the concerns identified to us by Trinity (see "August 2 2022 COETF Letter Detailing ICR Concerns.pdf"),.  In view of these concerns, the COETF requests that EPA make a number of changes to the ICRs.

In the coming days, I will contact you to schedule a date/time when we can meet to discuss these concerns with you.  In the meantime, please contact me if you have any questions.  David Ailor

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



<< August 2 2022 COETF Letter Detailing ICR Concerns.pdf >>


