From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Tuesday, January 17, 2023 4:25 PM
To: 
Brenna M Harden <brenna.harden@dteenergy.com>
Cc:
Rob Sanch <robert.sanch@dteenergy.com>; David W Fanning Jr <david.fanning@dteenergy.com>; Laura J Harris <laura.harris@dteenergy.com>; Tim Rodak <trodak@cleanair.com>; Mcginn, Kevin <mcginn.kevin@epa.gov>; Shappley, Ned <Shappley.Ned@epa.gov>; French, Chuck <French.Chuck@epa.gov>; Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: ICR Enclosure 2 Fugitive Monitoring - DTE Vantage EES Coke


Ms. Harden  -  Thanks for letting me know in detail about the issues impacting the deadline for DTE's EES Coke's fugitive emissions data. We would prefer you send any data as soon as you are ready to send. 

To summarize, please send "preliminary report on January 24 deadline with an amended report by February 10."

Please also provide in cover email for each set of data, what exactly is included, i.e., locations, methods, and dates of data.

Thank you for your work on this section 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: Brenna M Harden <brenna.harden@dteenergy.com> 
Sent: Tuesday, January 17, 2023 3:35 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: Rob Sanch <robert.sanch@dteenergy.com>; David W Fanning Jr <david.fanning@dteenergy.com>; Laura J Harris <laura.harris@dteenergy.com>; Tim Rodak <trodak@cleanair.com>
Subject: ICR Enclosure 2 Fugitive Monitoring - DTE Vantage EES Coke

Dr. Jones, I hope the new year finds you well. EES Coke has been diligently completing fugitive monitoring at the Island. As we prepare for the upcoming deadline, laboratory results have been taking longer than standard turn around times. I am sure some of it may have to do with the holidays but I believe that the majority of the delay revolves around labor shortage and delays in laboratory reports that the industry is observing since COVID. According to my notes the ICR would require the first three months of monitoring results for Fugitive Monitoring to be submitted by January 24, 2023. As of today, we have only received results from October 12, 2022 up to November 22, 2023 for Method BTEX (Method 324A/B) (three data sets). Additionally we have only received one data set for TO-13A (PAHs) and TO-15 (VOCs) from October 2022. Typically DTE likes to have a minimum of two weeks to review / correct any agency submission for good QA/QC protocols. After discussion with the subcontractor, we may receive one more set of data prior to January 24, 2023.

EES would love to meet the January 24, 2023 deadline but any report submitted by then would cover sampling results much less than the requested three months.  As EES is quite sure that EPA is eager to receive results, we can submit what we have for the January 24, 2023 deadline but it will be short several values. Subsequently, EES could send an amended 3-month report by February 10[th] based on current anticipated delivery of data, review and report generation. 

Dr. Jones, would EPA be OK with this approach (preliminary report on January 24 deadline with an amended report by February 10) or would you prefer all data at one report for the monitoring period on February 10[th]?

Regards,
Brenna Harden
DTE Vantage | EES Coke Battery, L.L.C., Senior Environmental Engineer
PO Box 18309, River Rouge, MI 48218
o 313.297.4183 | m 734.320.5255
dtevantage.com


