From:
"Cornelius, Jay" <jcornelius@abccoke.com>
Sent:
Fri, 09 Dec 2022 14:59:55 
To:
"Jones; DonnaLee" <Jones.Donnalee@epa.gov>; "Coke.ICR2@rti.org" <Coke.ICR2@rti.org>; "McGinn; Kevin" <mcginn.kevin@epa.gov>; "Shappley; Ned" <Shappley.Ned@epa.gov>; "graymond@rti.org" <graymond@rti.org>; "French; Chuck" <French.Chuck@epa.gov>
Cc:
Dolby, Abigail <adolby@abccoke.com>
Subject:
RE: ONE MORE THING - ABC Coke - Coke Oven RTR, ICR Enclosure 2 (Part) - Cooling Tower Testing Plan (REVISED)
No worries.  
 
ABC does operate a LO Condenser but it is a closed system and Enclosure 2 specified sampling only open systems.   It was also not included in our Emissions Inventory (the basis for our response to QB22), however the LO Condenser is included in our LDAR program.  
 
The cooling tower is also a closed system and not included in our emissions inventory (and therefore not listed in our response to QB22), but could be sampled for the purposes of the USEPA's ICR.   
 
We do NOT operate a sulfur recovery system.
 
If there are additional steps you'd like ABC to consider, please let me know.
 
Regards,
 
Jay Cornelius
Manager  -  Environmental Control


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

 
From: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent: Friday, December 9, 2022 12:58 PM
To: Cornelius, Jay <jcornelius@abccoke.com>; Coke.ICR2@rti.org; McGinn, Kevin <mcginn.kevin@epa.gov>; Shappley, Ned <Shappley.Ned@epa.gov>; graymond@rti.org; French, Chuck <French.Chuck@epa.gov>
Cc: Dolby, Abigail <adolby@abccoke.com>
Subject: RE: ONE MORE THING - ABC Coke - Coke Oven RTR, ICR Enclosure 2 (Part) - Cooling Tower Testing Plan (REVISED)
 
Jay Sorry, one more thing. Can you confirm that you do not have these units and, therefore, that's why you did not do testing:
 
Light Oil Condenser 
Sulfur Recovery/Desulfurization
 
I didn't see them listed in your enclosure 1 response to QB22 but then the cooling tower wasn't listed there either and testing was done on that unit.
 
Thanks
 
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: Jones, DonnaLee 
Sent: Friday, December 9, 2022 12:06 PM
To: Cornelius, Jay <jcornelius@abccoke.com>; Coke.ICR2@rti.org; McGinn, Kevin <mcginn.kevin@epa.gov>; Shappley, Ned <Shappley.Ned@epa.gov>; graymond@rti.org; French, Chuck <French.Chuck@epa.gov>
Cc: Dolby, Abigail <adolby@abccoke.com>
Subject: RE: ABC Coke - Coke Oven RTR, ICR Enclosure 2 (Part) - Cooling Tower Testing Plan (REVISED)
 
Thank you! Have a good weekend.
 
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: Friday, December 9, 2022 8:24 AM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>; Coke.ICR2@rti.org; McGinn, Kevin <mcginn.kevin@epa.gov>; Shappley, Ned <Shappley.Ned@epa.gov>; graymond@rti.org; French, Chuck <French.Chuck@epa.gov>
Cc: Dolby, Abigail <adolby@abccoke.com>
Subject: RE: ABC Coke - Coke Oven RTR, ICR Enclosure 2 (Part) - Cooling Tower Testing Plan (REVISED)
 
Good morning, Dr. Jones,
 
Please find attached the final draft of ABC Coke's Cooling Tower Testing Report prepared by Alliance Technical Group.  If you have any questions or need additional information, please let me know.
 
Regards,
 
Jay Cornelius
Manager  -  Environmental Control


Office: (205) 849-1342
jcornelius@abccoke.com 
 
 
From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Tuesday, December 6, 2022 12:29 PM
To: Cornelius, Jay <jcornelius@abccoke.com>; Coke.ICR2@rti.org; McGinn, Kevin <mcginn.kevin@epa.gov>; Shappley, Ned <Shappley.Ned@epa.gov>; graymond@rti.org; French, Chuck <French.Chuck@epa.gov>
Cc: Dolby, Abigail <adolby@abccoke.com>
Subject: RE: ABC Coke - Coke Oven RTR, ICR Enclosure 2 (Part) - Cooling Tower Testing Plan (REVISED)
 
Thank you very much for the data and the update. 
 
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, December 6, 2022 1:11 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>; Coke.ICR2@rti.org; McGinn, Kevin <mcginn.kevin@epa.gov>; Shappley, Ned <Shappley.Ned@epa.gov>; graymond@rti.org
Cc: Dolby, Abigail <adolby@abccoke.com>
Subject: RE: ABC Coke - Coke Oven RTR, ICR Enclosure 2 (Part) - Cooling Tower Testing Plan (REVISED)
 
Dr. Jones, 
 
Earlier this week, our cooling tower testing contractor requested additional information for their report, which we provided.  I expect their final report to be available shortly, but have reached out to them for an update.
 
As for the flare testing, ABC proposed that we submit Method 21 data from past actual emergency flare events (2019 to present) in lieu of testing our emergency flares during non-emergency conditions.  This data is attached.
 
 
Regards,
 
Jay Cornelius
Manager  -  Environmental Control


Office: (205) 849-1342
jcornelius@abccoke.com
 
 
From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Tuesday, December 6, 2022 11:44 AM
To: Cornelius, Jay <jcornelius@abccoke.com>; Coke.ICR2@rti.org; McGinn, Kevin <mcginn.kevin@epa.gov>; Shappley, Ned <Shappley.Ned@epa.gov>; graymond@rti.org
Cc: Dolby, Abigail <adolby@abccoke.com>
Subject: RE: ABC Coke - Coke Oven RTR, ICR Enclosure 2 (Part) - Cooling Tower Testing Plan (REVISED)

Hi Jay - We were wondering if you had your cooling tower test report ready? Also any flare testing.

Thanks in advance for your attention to this.

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.

-----Original Message-----
From: Cornelius, Jay <jcornelius@abccoke.com > 
Sent: Tuesday, September 27, 2022 1:27 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>; Coke.ICR2@rti.org; Mcginn, Kevin <mcginn.kevin@epa.gov>; Shappley, Ned <Shappley.Ned@epa.gov>; graymond@rti.org
Subject: ABC Coke - Coke Oven RTR, ICR Enclosure 2 (Part) - Cooling Tower Testing Plan (REVISED)

Good afternoon,

Please find revised Cooling Tower Testing Plan attached.

Jay Cornelius
ABC Coke

﻿ -----Original Message-----

Sorry. A correction. See below from Kevin.

"..there should be 7 runs for THC, so if they amended table 2-1, it should be to indicate THC on all testing runs, i.e. THC and VOHAP for the second line of testing and THC, H2S, COS, and CS2 for the 3rd. The first line would still be 1 for THC, and the subsequent lines would still be 3. They are doing 7 total runs, we just want to be sure that THC is included as a parameter in all 7 runs."

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.

-----Original Message-----
From: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent: Friday, September 23, 2022 2:43 PM
To: Cornelius, Jay <jcornelius@abccoke.com>; Coke.ICR2@rti.org; graymond@rti.org; Shappley, Ned <Shappley.Ned@epa.gov>; Mcginn, Kevin <mcginn.kevin@epa.gov>
Subject: RE: ABC Coke - Coke Oven RTR, ICR Enclosure 2 (Part) - Cooling Tower Testing Plan

Hi. We need some clarification and correction for your test plan. The 114 requires, in Table 1B "Perform at least seven (7) test runs of standard Appendix P, AND three (3) test runs of Appendix P with the TO-15A finish" (emphasis added with the "AND"). Then under TRS, the 114 requires facilities to "perform at least three (3) test runs on the cooling tower inlets." In Table 2-1 of the ABC plan, the schedule indicates THC testing only during Run 1 (i.e., # runs are equal to "1"). We want to confirm whether during subsequent runs (i.e., not just Run 1) the ABC plan also includes "performing the THC analysis that is standard with Appendix P to acquire the 7 test runs for THC required by the ICR" during ALL THREE runs? The bulleted list in the ABC plan's Section 2.1 seems to imply this, but to be sure that there is no confusion, we would like a clarification and correction.

Please submit a revised plan with this correction. In Table 2-1, in the row for THC, the number of runs should equal "3".

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.
