From: 
Brenna M Harden <brenna.harden@dteenergy.com>
Sent:
Wednesday, August 3, 2022 9:43 AM
To: 
Jones, DonnaLee <jones.donnalee@epa.gov>; french.chuck@epa.gov; Coke ICR2 <Coke.ICR2@rti.org>
Cc:
Marion M Krchmar <marion.krchmar@dteenergy.com>; Fadi K Mourad <fadi.mourad@dteenergy.com>; Robert B Sanch <robert.sanch@dteenergy.com>; Laura J Harris <laura.harris@dteenergy.com>; Andrea E Hayden <andrea.hayden@dteenergy.com>; Todd A Richards <todd.richards@dteenergy.com>; 'Jeff Knight' <jeffrey.knight@pillsburylaw.com>; Robert H Carlin <robert.carlin@dteenergy.com>
Subject: 
Concerns Regarding EPA's June 28, 2022 Coke Ovens Section 114 Information Collection Requests - Enclosure 2 Detailed Stack Test Problems


Dear Mr French and Dr. Jones:

On June 29, 2022, DTE Vantage (DTE) received Section 114 of the Clean Air Act Information Collection Request (ICR) in relation to development of Risk and Technology Review of Coke Oven Facilities related to 40 CFR Part 63, Subpart CCCCC, Pushing Quenching and Battery Stacks. The ICR also included risk and technology review, testing, interior and fenceline monitoring, and other information collection activities related to potential new regulations for coke byproduct recovery plants (CBRP) in relation to 40 CFR Part 63, Subpart L, Coke Oven Batteries. DTE owns and operates EES Coke Battery, L.L.C. (EES Coke) located in River Rouge, MI.

Attached is the letter of concern by EES Coke's affiliated industry group, American Coke and Coal Chemicals Institute (ACCCI). ACCCI has a subgroup of the Coke Oven Emission Task Force which is a group of member companies previously formed in 1996 to address major environmental issues collaboratively facing the US coke byproduct recovery industry. EES Coke is a member of the COETF. The COETF engaged Trinity Consultants (Trinity) to assist the COETF in assessing concerns with the ICRs. The enclosed August 2, 2022 letter reflects the industry's concerns regarding the ICR, including the detailed explanation of stack testing problems as required by the first task due within 35 days of the submission (August 3, 2022.) EES Coke has supplied an additional cover letter to emphasis points associated with this site. In addition, a hard copy will be submitted to Dr. Jones certified mail.

Regards,
Brenna Harden
DTE Vantage | EES Coke Battery, L.L.C., Senior Environmental Engineer
PO Box 18309, River Rouge, MI 48218
o 313.297.4183 | m 734.320.5255
dtevantage.com



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