From:
"BATTEN, KATIE M" <KMBATTEN@SUNCOKE.COM>
Sent:
Fri, 16 Sep 2022 13:34:05 
To:
"Jones; DonnaLee" <Jones.Donnalee@epa.gov>
Cc:
Coke ICR2 <Coke.ICR2@rti.org>; Mcginn, Kevin <mcginn.kevin@epa.gov>; Shappley, Ned <Shappley.Ned@epa.gov>; French, Chuck <French.Chuck@epa.gov>; Raymond, Gabrielle <graymond@rti.org>; STARKWEATHER, DIANA M. <DMSTARKWEATHER@suncoke.com>
Subject:
RE: Analysis of Coke Oven Gas for BTEX
	 

Hi Donna Lee,
 
Thank you for the prompt response to SunCoke's August 31, 2022 letter.  Based on the altered ICR requirements described in your email, we are optimistic that SunCoke and EPA will be able reach agreement on the scope and timing of the ICR.  
 
We have been working hard on evaluating the feasibility of these requests since receiving your email, and would like to clarify several details around the Enclosure 2 stack testing as we continue our planning for the imminent testing at Haverhill this month.  The trailers are being loaded today and shipped early next week to Haverhill, so it would be very helpful to receive a response to these questions as soon as possible.
 
1. Your email appears to be asking for 3 dscm of PM, metals, and acid gases (HCl and HF).  However, the official ICR only requests 1 dscm for acid gases.  We assume 1 dscm is sufficient, but please let us know if that is not the case and the reason for the change.
 
2. We want to just confirm for you that it is not feasible to test prior to the HRSG, so we will assume the Enclosure 2, Table 3 tests are no longer required.  This may also facilitate some of the other testing EPA is requesting at Haverhill.
 
3. Given the time constraints, we are not going to be able to submit a formal test plan to EPA in advance of this testing, which we anyway understood to be optional, not a requirement.  We will provide a schedule once finalized.  Please confirm that will be acceptable.
 
4.	Your email notes that the testing for dioxins/furans and VOHAPs are lower priority.  We agree, but can you please help us understand why that is the case from your perspective?  
 
5. Your email appears to be stating that the ICR stack testing request from Jewell could instead be satisfied at Haverhill (subject to the changes described in your email), and not be required at Jewell in the spring of 2023 as we proposed in our letter.  Conducting this testing at Haverhill now will require extraordinary efforts from AECOM and our plant team on short notice, while we are still trying to conduct other testing required under our CD and permit.  However, as described in our letter, Jewell has been dealing with a great deal of adversity from recent major weather events, so we are highly motivated to alleviate the operational burden on them to the greatest extent possible and not have stack testing done there, even next spring.  And it is looking promising for us to be able to arrange the testing at Haverhill for the constituents you identified at the sample volumes you requested (although we are almost certainly not going to be able to conduct more than 3 runs given the limited timeframe while the stacks are open).  Given all this, we would appreciate confirmation that conducting the testing at Haverhill this month will completely satisfy the ICR test requirements from Jewell.
 
Thanks,
 
Katie Batten
Director of Health, Safety and Environmental
 
SunCoke Energy, Inc.
kmbatten@suncoke.com <mailto:kmbatten@suncoke.com> 
cell: 740-370-8710

 
From: Jones, DonnaLee <Jones.Donnalee@epa.gov> Sent: Monday, September 12, 2022 4:04 PMTo: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>Cc: Coke.ICR2@rti.org; Mcginn, Kevin <mcginn.kevin@epa.gov>; Shappley, Ned <Shappley.Ned@epa.gov>; French, Chuck <French.Chuck@epa.gov>; GABRIELLE RAYMOND <graymond@rti.org>Subject: RE: Analysis of Coke Oven Gas for BTEX
 
Hi Katie: Sorry for the delay, but we wanted to make sure we provided all the information that was needed.
 
In response to the points made in the SunCoke letter of 8/31/22, we would like to point out that the Clean Air Act (CAA) provides EPA with authority to request information for the development of any emission standard under CAA section 112 of the Act. As such, EPA's authority to request information from SunCoke is not limited by the scope of the action to be taken to satisfy the court's order in Citizen's for Pennsylvania's Future, et al., v. Wheeler, Case No. 3:19-cv-02004 (N.D. Cal.). The EPA also may at any time list additional categories and subcategories of source of hazardous air pollutants. 
 
We carefully considered SunCoke letter of 8/31/22 and email of 9/6/22. In this regard, we are continuing with our plan for the CAA section 114 information request to SunCoke, but with the following modifications:
 
We accept SunCoke's offer to use the upcoming bypass event at Haverhill due to flue gas desulfurization maintenance to meet some of SunCoke's CAA section 114 testing obligations of bypass stacks. We agree that three valid runs for each pollutant is sufficient. However, in order to accept the bypass stack testing at Haverhill scheduled for late September, the volume collected will need to meet the specification of the CAA section 114 request, as follows: 3 dscm for particulate matter (PM), metals, and acid gas testing, as opposed to the approximate test volumes of 2 dscm, 1.3 dscm and 1 dscm, respectively, that were mentioned in Attachment 1 of SunCoke's 8/31/22 letter. The PM may be collected separate from or simultaneously with either the EPA method 29 metals sampling or the EPA method 26A sampling train. Since the contractor is currently performing continuous emissions monitoring testing (EPA methods 6C and 7E for SO2 and NOx, and possibly method 3A for O2 and CO2), we request that the carbon monoxide (CO) testing by EPA method 10 also be performed at the same time, since CO gases are readily available, and the addition of the CO monitoring will not require any additional personnel or any additional time beyond calibration of the analyzer. This testing then would meet all of the testing obligations for SO2, NOx, and CO, as required in the CAA section 114 request. Additional testing, minimally, for PM, metals, formaldehyde, acid gases (HCL and HF), and HCN are still necessary. Therefore, we strongly recommend that SunCoke also test for these pollutants in September 2022 at the Haverhill facility to obtain a minimum of 3 valid test runs for each pollutant. We recommend more runs, if possible, in order to obtain a more robust data set, but understand that may not be possible. The required testing for the bypass stack can be added to the upcoming Haverhill testing (in lieu of testing at the Jewell facility described in our June 28, 2022 CAA section 114 request) at the sample volumes required by Enclosure 2 of the CAA section 114 request. The testing for dioxin/furans and VOHAP are lower priority and can be completed at a later date at the Jewell Coke facility, if necessary. 
 
Per SunCoke's request for alternative sampling and analysis of the Enclosure 2 Table 3 coke oven gas sampling, if it is not feasible to test prior to the HRSG, the Enclosure 2 Table 3 tests are no longer required. If the coke oven gas can be sampled prior to the HRSG, EPA method TO-15 is not an applicable solution because it is an ambient air method. The methods in Table 3 should be used. The use of a passivated evacuated canister is appropriate for sampling the coke oven gas, although the EPA recommends that, in order to prevent condensation in the canister, the canister not be filled completely, and a partial vacuum maintained on the canister.
 
We also considered the previous fugitive data obtained from Haverhill over the period 2004-2014, as SunCoke requested. However, because of the age of the data and how these (and other) measurement approaches (e.g., method 325A/B) are being applied in this sector now as part of EPA's section 114 request efforts, we must request current fugitive sampling, as follows:
 
o        Testing should include EPA methods 325A&B, and TO-13A and 15, as described in the original CAA section 114 request (dated June 28, 2022).
o        No interior fugitive tests are required.
o        The fugitive monitoring plan is due to EPA 30 days from the date of this email.
o        Fugitive monitoring must begin within 40 days of the date EPA approves the monitoring plan (typically less than a 2-week EPA turn around).
o        Nine (9) weeks of fugitive monitoring must be performed and the resulting data submitted within 110 days from the date that EPA approves the monitoring plan. The EPA is permitting the reduced fenceline monitoring requirements in recognition of the previous monitoring efforts at/near the facility. 
 
::        We accept SunCoke's proposed schedule for Enclosure 1 information from the SunCoke August 31, 2022, letter for submitting the information from Jewel (Vansant) and Haverhill (Franklin Furnace).
 
Let me know if you have any further questions. We greatly appreciate your help with our test 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: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM <mailto:KMBATTEN@SUNCOKE.COM> > Sent: Friday, September 9, 2022 11:08 AMTo: Jones, DonnaLee <Jones.Donnalee@epa.gov <mailto:Jones.Donnalee@epa.gov> >Cc: Coke.ICR2@rti.org <mailto:Coke.ICR2@rti.org> ; STARKWEATHER, DIANA M. <DMSTARKWEATHER@suncoke.com <mailto:DMSTARKWEATHER@suncoke.com> >Subject: FW: Analysis of Coke Oven Gas for BTEX
 
Hi Donna Lee,
 
Please see the information below.  Will this be acceptable to EPA?
 
Thanks and have a good weekend,
 
Katie Batten
Director of Health, Safety and Environmental
 
SunCoke Energy, Inc.
kmbatten@suncoke.com <mailto:kmbatten@suncoke.com> 
cell: 740-370-8710

 
From: Workman, Gerald <jerry.workman@aecom.com <mailto:jerry.workman@aecom.com> > Sent: Tuesday, September 6, 2022 1:00 PMTo: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM <mailto:KMBATTEN@SUNCOKE.COM> >Cc: Aron H. Schnur <ASchnur@bdlaw.com <mailto:ASchnur@bdlaw.com> >; STARKWEATHER, DIANA M. <DMSTARKWEATHER@suncoke.com <mailto:DMSTARKWEATHER@suncoke.com> >Subject: Analysis of Coke Oven Gas for BTEX
 
Katie,
Table 3 in Enclosure 2 requires collection of three gas-phase mercury samples and three BTEX samples from the HRSG inlet or outlet.  Because of the high temperature of the gas stream at the HRSG inlet, it will be most practical to collect these samples from the HRSG outlet.  Table 3 specifies GPA Standard 2286 (2014) for BTEX analysis; however this method is specifically intended for compositional analysis of natural gas samples by GC.  The gas stream downstream of the HRSG is essentially flue gas (not like natural gas at all).  Table 3 of Enclosure 2 also does not specify a BTEX sample collection method.  AECOM suggests that samples for BTEX at the HRSG outlet be collected in evacuated canisters and analyzed using EPA Compendium Method TO15, this approach and GC analytical method being more suitable for the overall composition of the exhaust gas.
-Jerry
 
 
Jerry Workman, P.E.
Pronouns: he, him, his
 
Air Measurements East Supervisor
Environmental Business Unit
D +1-919-461-1289
M +1-919-949-9445
jerry.workman@aecom.com <mailto:jerry.workman@aecom.com> 
AECOM
5438 Wade Park Boulevard
Suite 200
Raleigh, NC 27607, USA
T +1-919-461-1100
aecom.com 
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