From: 
Cornelius, Jay <jcornelius@abccoke.com>
Sent:
Tuesday, August 16, 2022 12:08 PM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc:
Freeman, Caroline <Freeman.Caroline@epa.gov>; French, Chuck <French.Chuck@epa.gov>; coke.icr@rti.org; rwg@adem.alabama.gov; David Ailor <dailor@accci.org>
Subject: 
Coke Oven RTR, ICR Enclosure 2 (Part) - Test Plan/Fugitive Monitoring Plan - ABC Coke, Tarrant


Dr. Jones,

Attached please find ABC Coke's Draft Test Plan in response to CAA Section 114 request, ICR for Coke Ovens RTR, Enclosure 2, Section 1.7.  Also included is a Draft Fugitive Monitoring Plan (including Quality Manual and SOPs), and QAPP prepared by our subcontractor, Alliance, detailing the proposed approach for the fenceline and interior monitoring at our facility in Tarrant, AL.

Some of these documents remain in DRAFT due to the limited time allotted for their development and the likely need to finalize the plan prior to implementation.  It is important to note that at this point, the challenge of supplying reliable power to remote fenceline monitoring stations nearly a half-mile from the plant is unresolved.  The installation of temporary power poles/lines to these stations is a substantial effort and neither ABC nor our consultants have come up with an acceptable and reasonable solution.  A simple option is to use alternative air sampling methods that do not require power.  Another significant yet unresolved concern is the security of sampling devices positioned at the ABC property boundary, but away from the plant proper and/or outside the security fence.  To date, dependable measures to deter theft/tampering of the devices and disrupting sample collection has not been developed.  Lacking viable solutions to these issues, the monitoring approach/methodology proposed in these draft documents may require revision to include acceptable alternatives.

Regards,

Jay Cornelius
Manager  -  Environmental Control

Office: (205) 849-1342
jcornelius@abccoke.com


<< ABC Coke Test Plan-DRAFT.pdf >>
<< ABC Coke-Birmingham_Draft Fugitive Monitoring Plan_081222 (003).pdf >>
<< ABC Coke-Birmingham_Figures 1 and 2_Draft_081222.pdf >>
<< ABC Coke-Birmingham_Draft Quality Assurance Procedure Plan_Draft_081222.pdf >>
<< ABC Coke-Birmingham_Attachment 1. SGS Quality Manual Rev 28 May 20 2022.pdf >>
<< ABC Coke-Birmingham_Attachment 1. SGS SOPs.pdf >>
