From:
"Jones, DonnaLee" <Jones.Donnalee@epa.gov>
Sent:
Tue, 30 Aug 2022 13:44:56 
To:
Jay Cornelius <jcornelius@abccoke.com>
Subject:
RE: Coke Oven RTR, ICR Enclosure 2 (Part) - Test Plan/Fugitive Monitoring Plan - ABC Coke, Tarrant

Hello Jay  -  Thank you for the submission of your QAPP in response to the 2022 Clean Air Act section 114 test request for the Coke Ovens RTR. We reviewed your submission and had the following comments and requests:
 
"This test plan needs the GPS coordinates of the actual locations rather than only indicated on a map, so we can confirm the proper placement."
 
Please submit a revised QAPP documents addressing these deficiencies by Monday, September 12, 2022 COB.
 
Thank you for your efforts wth this 114 request.
 
 
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: 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 
