From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Friday, August 5, 2022 2:32 PM
To: 
David Ailor (dailor@accci.org) <dailor@accci.org>
Cc:
Mcginn, Kevin <mcginn.kevin@epa.gov>; Shappley, Ned <Shappley.Ned@epa.gov>; Carpenter, Jacob <Carpenter.Jacob@epa.gov>; Raymond, Gabrielle <graymond@rti.org>; French, Chuck <French.Chuck@epa.gov>; Coke ICR2 <Coke.ICR2@rti.org>
Subject: 
some clarifications and questions RE: COETF Letter Detailing Concerns Regarding EPA's June 28, 2022 Coke Ovens Section 114 Information Collection Requests (ICRs)


Hello David  -  Thank you for sending me your comments on the upcoming Coke RTR 114 information requests. I am including all my notes and comments here for the COETF members as well separately in response to the individual facility emails I received. 

A few items to note:
-- Note, I sent a fugitive test data answer file with the emails to Cleveland Cliffs and U.S. Steel. Please confirm receipt or I can resend those emails. From the comments made by Trinity, I surmised there is some confusion about how to submit these data.
-- Note, we are not requiring testing of the flare flame zone nor requiring testing if no test ports are already installed at the flares. We would want COG analyses that represent COG upstream of the flares, if available.
--Note, the 85-day deadline is to tell us when the stack tests are happening and is not the deadline for the test results.
--Note, we can find no reference in the 114 for the stack tests to be performed concurrent with the fugitive sampling. If it is there, this is an error because we don't need these tests to be concurrent.

A few questions based on the emails and documents:
-- US Steel: What previous tests/methods/sources to submit, how old?
-- DTE/EES: For "existing" clean/processed COG analyses offered in lieu of flare testing (by EES), what does "existing" mean? Where is the clean/processed COG sample taken in terms of the batteries and CBRP? Where in the sample train is the COG sampled? Would these samples be considered representative of what is sent to flares? 

--COETF: What "EPA ambient data at fenceline" is available? What is the location (facility name, location of test monitors), dates of sampling, which EPA office/contact name performed or requested ambient testing? 
--COETF: What specific batteries (by name/number) have anticipated problems with testing bench&yard with method 303 for CCliffs Burns Harbor and US Steel only.
--COETF: Which states and what are the permit requirements for power installation (prior to installation of generators, including small, temporary units) at the three COETF facilities required in the coke 114 to perform fenceline monitoring (CCliffs Burns Harbor, DTE/EES, US Steel)
--COETF: How often are emergency flares used (what is the range in current COETF facilities), i.e., daily/weekly/monthly/ every 3,6,9 months/annually?

Looking forward to talking with everyone next week. 

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: 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


