From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Friday, August 5, 2022 2:33 PM
To: 
Hardin, Christopher W <CWHardin@uss.com>
Cc:
Jeffrey, Mark A <MJeffrey@uss.com>; Hacker, David W <DWHacker@uss.com>; Dzurinko, Mike G <MDzurinko@uss.com>; Tunno, Brett J <BJTunno@uss.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: U. S, Steel Concerns Regarding EPA's June 28, 2022 Coke Ovens Section 114 Information Collection Requests (ICRs)


Mr. Hardin, 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 the 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: Hardin, Christopher W <CWHardin@uss.com> 
Sent: Wednesday, August 3, 2022 12:49 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>; French, Chuck <French.Chuck@epa.gov>; Coke.ICR2@rti.org
Cc: Jeffrey, Mark A <MJeffrey@uss.com>; Hacker, David W <DWHacker@uss.com>; Dzurinko, Mike G <MDzurinko@uss.com>; Tunno, Brett J <BJTunno@uss.com>
Subject: U. S, Steel Concerns Regarding EPA's June 28, 2022 Coke Ovens Section 114 Information Collection Requests (ICRs)

Dear Mr. French and Dr. Jones:

Please see attached U. S. Steel's comments and concerns with the ICRs from EPA related to the 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 that includes testing, interior and fenceline monitoring, and other information collection activities related to potential new regulations for coke byproduct recovery plants (CBRP).  

U. S. Steel, in coordination with 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 with the proposed ICR testing requirements and other information collection activities.  U. S. Steel and the COETF requests that EPA make a number of changes to the ICRs as detailed in the attachment.

Thank you for your consideration and please feel free to reach out with any questions.

Chris


Christopher W. Hardin
Environmental Affairs
United States Steel Corporation
Office: 412-433-5904
Cell: 412-735-8097
Fax: 412-433-5920
Email: cwhardin@uss.com


