From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Thursday, August 11, 2022 1:09 PM
To: 
David Ailor <dailor@accci.org>
Cc:
Daly, Owen <Daly.Owen@epa.gov>; French, Chuck <French.Chuck@epa.gov>; Fruh, Steve <Fruh.Steve@epa.gov>; Lin, Walter <lin.walter@epa.gov>; Mcginn, Kevin <mcginn.kevin@epa.gov>; Raymond, Gabrielle <graymond@rti.org>; Shappley, Ned <Shappley.Ned@epa.gov>
Subject: 
RE: DRAFT LISTS OF COETF AND EPA "DO-OUTS" FROM YESTERDAY'S CALL ON 114 TESTING


Hello David:

 We are extending the date for submittal of fugitive monitoring plans, etc., to Tuesday, August 16, 2022.

 Fugitive (monitoring plan, test plan, & QAPP) (Enclosure 2) - Tuesday, August 16, 2022, COB.

 Also, I don't recall one item as being on "EPA's list"

::        Provide list of ambient monitoring stations for which EPA already has data.

I thought we had explained in our meeting Tuesday that ambient monitoring is not a substitute for fenceline monitoring? The one situation we mentioned that might be useful was where there is both upwind and downwind ambient monitors close to the facility. Since these monitors would need to be close by the facility fenceline to be useful, the four COETF facilities required to perform fenceline testing would be in a better position to know if ambient monitors were located in these positions, i.e., the monitors would be visible from facility property. If facilities need to check monitoring stations, see https://www.epa.gov/aqs. For planning purposes, I would assume there are not any data available that would provide the same information as what we are requesting through fenceline emissions testing in the coke RTR 2022 114.

 We will respond at a later time to the requests for extension for the other items on the coke RTR 2022 114 schedule, as per the discussion in our meeting Tuesday this week. We understand the need for timely resolution to the schedule for industry planning purposes. We are planning to discuss these issues soon within the EPA team. I would recommend that facilities proceed with the current schedule until told otherwise.


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: Wednesday, August 10, 2022 4:59 PM
To: Daly, Owen <Daly.Owen@epa.gov>; French, Chuck <French.Chuck@epa.gov>; Fruh, Steve <Fruh.Steve@epa.gov>; Jones, DonnaLee <Jones.Donnalee@epa.gov>; Lin, Walter <lin.walter@epa.gov>; Mcginn, Kevin <mcginn.kevin@epa.gov>; 'GABRIELLE RAYMOND' <graymond@rti.org>; Shappley, Ned <Shappley.Ned@epa.gov>
Subject: DRAFT LISTS OF COETF AND EPA "DO-OUTS" FROM YESTERDAY'S CALL ON 114 TESTING

Donna Lee et al.:

Thanks again for making the time to meet with the Coke Oven Environmental Task Force (COETF) yesterday to discuss 114 testing the Agency is requesting.  Below, as promised, are draft lists developed by the COETF inclusive of what we believe are the COETF and EPA "do-outs" from the call.  Please let us know ASAP of any errors/omissions you might identify.  Thanks, David Ailor

COETF Do-Outs:

 Provide close-up images of battery bench showing safety hazards  -  tight spaces, moving equipment, etc.
 Provide OSHA reports on previous injuries/fatalities
 Follow-up on EPA request for information on composition/speciation of VOC from byproduct plant processes (LDAR program)

EPA Do-Outs:

 Response to COETF's letter requesting changes to the ICR schedule (expedited response requested)
 Response to COETF's letter requesting changes to the ICR scope 
 Provide list of ambient monitoring stations for which EPA already has data 
 If any interior/fenceline fugitive monitoring remains in the ICR, confirm whether method can be limited to passive samplers and fenceline locations reduced to 1-2 upwind and 1 downwind
 Confirm whether EPA will accept USS SCOT plant stack test data in lieu of performing new testing
 Confirm whether EPA will accept DTE/EES COG sample data in lieu of performing new testing 


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


