From: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Sent:
Thursday, June 18, 2020 3:29 PM
To: 
D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com>; Green, Joseph J. <JGreen@KelleyDrye.com>; Stuart, Eric <stuart@steelnet.org>
Cc:
Raymond, Gabrielle <graymond@rti.org>
Subject: 
Re: count of new EAF in progress?


Thats good to know. The state is looking into the case I'm following; maybe there is some miscommunication. I will let you know when I find out myself. Thanks for your help.

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.



From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Thursday, June 18, 2020 3:19 PM
To: Green, Joseph J. <JGreen@KelleyDrye.com>; D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com>; Stuart, Eric <stuart@steelnet.org>
Cc: Raymond, Gabrielle <graymond@rti.org>
Subject: Re: count of new EAF in progress?


Ok, good. Another control device is OK because that's already in the rule. The facility I referred to in my email had NO control device. 

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.



                                       
From: D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com>
Sent: Thursday, June 18, 2020 2:13 PM
To: Green, Joseph J. <JGreen@KelleyDrye.com>; Jones, DonnaLee <Jones.Donnalee@epa.gov>; Stuart, Eric <stuart@steelnet.org>
Cc: GABRIELLE RAYMOND <graymond@rti.org>
Subject: RE: count of new EAF in progress? 
 
Thanks Joe.  I have not seen or heard of an carbon steel EAF facility that does not utilize a baghouse.  
Be well,
Wayne
 
 
WAYNE D'ANGELO
Partner
Kelley Drye & Warren LLP
Tel: (202) 342-8525
Cell: (202) 329-3977
wdangelo@kelleydrye.com


From: Green, Joseph J. <JGreen@KelleyDrye.com> 
Sent: Thursday, June 18, 2020 2:01 PM
To: 'Jones, DonnaLee' <Jones.Donnalee@epa.gov>; D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com>; Stuart, Eric <stuart@steelnet.org>
Cc: GABRIELLE RAYMOND <graymond@rti.org>
Subject: RE: count of new EAF in progress?
 
Hi Dr. Jones  -  I know there was a stainless EAF that used to operate a wet scrubber in lieu of a baghouse at one of its two EAFs.  However, that facility replaced the wet scrubber with a baghouse about a decade ago (around 2009 I believe).  That is the only non-baghouse EAF of which I was ever aware, certainly from the SSINA side of things.  Will confirm with Eric and Wayne on the carbon side.
 
Regards
Joe
 
 
JOSEPH J. GREEN
Special Counsel
Kelley Drye & Warren LLP
(202) 342-8849
JGreen@KelleyDrye.com
Follow my blog: www.kelleygreenlawblog.com


From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Thursday, June 18, 2020 11:08 AM
To: D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com>; Stuart, Eric <stuart@steelnet.org>; Green, Joseph J. <JGreen@KelleyDrye.com>
Cc: GABRIELLE RAYMOND <graymond@rti.org>
Subject: Re: count of new EAF in progress?
 
                                       
Thanks. This is good, just to get an idea of the level of activity. I don't need anything more right now. We can revisit towards the end of the year. 
 
Also, it has come to my attention that there is one facility that has an EAF with no baghouse. There are other EAF at the facility with baghouses, however. Have you heard of this type of situation and why it might occur? It appears to be a loophole in the rule we may have to fix. 
 
Thanks for your research. Very helpful.
 
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.
 
                                       
From: D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com>
Sent: Thursday, June 18, 2020 9:14 AM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>; Stuart, Eric <stuart@steelnet.org>; Green, Joseph J. <JGreen@KelleyDrye.com>
Subject: RE: count of new EAF in progress? 
 
 
Hello Dr. Jones.    Sorry for the delay in getting back to you.  SMA does not have a strong basis for estimating the number of new EAFs that might be starting on the next 5 years.  For lots of reasons (including antitrust compliance), SMA and its members refrain from discussing any companies' long-range capital planning or any capital plans that have not been publically announced.   However, we are aware of the following publically announced plans to construct new EAF facilities in the next 18-24 months:
      1.           Nucor  -  Brandenburg (KY) Plate Mill; 
      2.           Nucor - Frostproof (FL) long product mill; 
      3.           Nucor - Sedalia (MO) long product mill; and,
      4.           SDI - Stinton TX long product mill.
 
I believe each of these projects was announced pre-pandemic, and I have no idea whether the current state of the economy has any impacts on these plans.  I suspect, however, that companies make planning decisions about large capital expenditures such as these do so on fairly long time horizons.  I should also note that these 4 plans are all carbon steel EAFs.   I am not aware of any stainless steel mills planning new EAFs but I am double checking with my colleague, Joe Green, who handles the environmental matters for the Specialty Steel Industry of North America ("SSINA").  I will also let you know if I become aware of any addition construction plans in the carbon steel EAF industry.   
 
I hope this is helpful to you.  As I've mentioned previously, we would like to be helpful in any way we can.  We know the EAF industry very well and have done significant work in both the carbon and stainless sectors.  If you are amenable, perhaps we can convene a call or web-meeting in July or August.  I can pull in the representatives from the key trades and we can talk through the type of information you'll need as you conduct this analysis.  Please let me know if you think that would be helpful.   And please let me know if you need anything else on this present question or otherwise.
 
Thanks for the outreach and be well!
Wayne
 
 
WAYNE D'ANGELO
Partner
Kelley Drye & Warren LLP
Tel: (202) 342-8525
Cell: (202) 329-3977
wdangelo@kelleydrye.com


From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Tuesday, June 16, 2020 11:38 AM
To: Stuart, Eric <stuart@steelnet.org>
Cc: D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com>
Subject: count of new EAF in progress?
 
Hi. Im working on the paperwork for the NSPS and I need to estimate how many new EAF might be starting in next 5 years. I thought maybe it was zero/0 because of current economics. What do/can you estimate?
 
Thanks in advance. 
 
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.


