From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Friday, August 5, 2022 2:33 PM
To: 
Brenna M Harden <brenna.harden@dteenergy.com>
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>; Coke ICR2 <Coke.ICR2@rti.org>; French, Chuck <French.Chuck@epa.gov>; Mcginn, Kevin <mcginn.kevin@epa.gov>; Shappley, Ned <Shappley.Ned@epa.gov>; Carpenter, Jacob <Carpenter.Jacob@epa.gov>; Raymond, Gabrielle <graymond@rti.org>; David Ailor (dailor@accci.org) <dailor@accci.org>
Subject: 
some clarifications and questions RE: Concerns Regarding EPA's June 28, 2022 Coke Ovens Section 114 Information Collection Requests - Enclosure 2 Detailed Stack Test Problems


Ms. Harden, et al.: Thank you for sending me your comments and concerns on the upcoming Coke RTR 114 information requests. I am including all my notes and comments here for all COETF members as well as those specific to your company.

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 your 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: Brenna M Harden <brenna.harden@dteenergy.com> 
Sent: Wednesday, August 3, 2022 9:43 AM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>; French, Chuck <French.Chuck@epa.gov>; 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


