From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Wednesday, June 7, 2023 3:29 PM
To: 
BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc:
STARKWEATHER, DIANA M. <DMSTARKWEATHER@suncoke.com>; Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: MACT RTR - Initial Comments


Thanks for the explanation. Yes, its too late at this point. The proposed rule had already gone through agency review when I got your email. We cant change anything after that and its now in OMB review. Sorry. 

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> 
Sent: Wednesday, June 7, 2023 2:43 PM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: STARKWEATHER, DIANA M. <DMSTARKWEATHER@suncoke.com>; GABRIELLE RAYMOND <graymond@rti.org>
Subject: RE: MACT RTR - Initial Comments

Hi Donna Lee,

Although this has not caused any significant problems for us, the current terminology has definitely resulted in confusion by state agencies whether we were in compliance with applicable requirements.  Typically, they would understand our position upon providing a detailed explanation that common tunnel pressure monitoring satisfies this requirement, and was the underlying intent behind the "except as otherwise provided" language.  But ultimately this language is a source of confusion that could be avoided if it just spelled out where those exceptions are located, as we propose.  We are not aware of any other regulations potentially covered by that "otherwise provided" language.

You mentioned that we should also submit these comments during the official comment period.  We were just wondering if that means it is too late for these comments to really be considered at the proposed rule stage? 

Thanks,

Katie Batten
Director of Health, Safety and Environmental

SunCoke Energy, Inc.
kmbatten@suncoke.com
cell: 740-370-8710

From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Thursday, May 25, 2023 7:00 PM
To: BATTEN, KATIE M <KMBATTEN@SUNCOKE.COM>
Cc: STARKWEATHER, DIANA M. <DMSTARKWEATHER@suncoke.com>; GABRIELLE RAYMOND <graymond@rti.org>
Subject: RE: MACT RTR - Initial Comments

 
Hi. I have a couple of simple questions about #1. Has this caused any problems for SunCoke in the past? What else could "otherwise provided" mean?

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 <Jones.Donnalee@epa.gov> 
Sent: Tuesday, May 23, 2023 11:28 AM
To: KMBATTEN@suncoke.com
Cc: STARKWEATHER, DIANA M. <DMSTARKWEATHER@suncoke.com>; GABRIELLE RAYMOND <graymond@rti.org>
Subject: FW: MACT RTR - Initial Comments

Thank you for this information. I am always looing for ways to make our rules better. You probably should also submit this document during the upcoming proposal comment period (sometime this summer). 

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> 
Sent: Tuesday, May 23, 2023 8:44 AM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: STARKWEATHER, DIANA M. <DMSTARKWEATHER@suncoke.com>
Subject: MACT RTR - Initial Comments

Hi Donna Lee,

While EPA is reviewing the data submitted by SunCoke and other companies to develop a proposed rule for the Coke Oven MACT Residual Risk & Technology Review (40 CFR Part 63, Subparts L and CCCCC), SunCoke has been working diligently to identify minor changes to the rules that we believe should be incorporated into EPA's upcoming proposed rule for technical accuracy and other non-controversial reasons (e.g., resulting in an environmental benefit in certain cases).  Please see the attached document for our proposed changes for EPA's consideration.  Feel free to reach out to me with any questions.

Thanks,

Katie Batten
Director of Health, Safety and Environmental 

SunCoke Energy, Inc.
1011 Warrenville Rd, 6[th] Floor
Lisle, IL 60532

kmbatten@suncoke.com
cell: (740) 370-8710





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