From: 
D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com>
Sent:
Friday, December 18, 2020 5:54 PM
To: 
Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc:
Stuart, Eric <stuart@steelnet.org>; Balserak, Paul <pbalserak@steel.org>; Green, Joseph J. <JGreen@KelleyDrye.com>
Subject: 
RE: Steel Industry's Proposed Redlines to Subpart AAa NSPS for EAF and AOD


Thank you, Dr. Jones.  Our proposed edit were based on input from a number of companies and so it will take a bit of time to compile responses to you questions.  We'll get to work on those answers and expect to be able to be able to provide answers next month.  Thanks very much for your thoughtful review.  We look forward to discussing these proposed changes with you.   Happy holidays and best wishes for 2021!
Best,
Wayne


WAYNE D'ANGELO

Kelley Drye & Warren LLP
Tel: (202) 342-8525
Cell: (202) 329-3977

From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Friday, December 18, 2020 5:14 PM
To: D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com>
Cc: Stuart, Eric <stuart@steelnet.org>; Balserak, Paul <pbalserak@steel.org>; Green, Joseph J. <JGreen@KelleyDrye.com>
Subject: RE: Steel Industry's Proposed Redlines to Subpart AAa NSPS for EAF and AOD

Hi Wayne, et al. Thanks again for the mark-up of AAa. The EAF rule team found many of the edits useful/good edits. Others we might not be able to or want to make, which we can discuss at a later time. There are some edits for which we wanted more information as to why industry thought the changes were warranted and/or industry background experience with enforcement. In some cases, we have provided potential alternative text. All these changes are in the attached documents.

Let  me know if you have any questions. We can discuss after the new year. Happy holidays to everyone!

From: D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com> 
Sent: Tuesday, November 24, 2020 10:47 AM
To: Jones, DonnaLee <Jones.Donnalee@epa.gov>
Cc: Stuart, Eric <stuart@steelnet.org>; Balserak, Paul <pbalserak@steel.org>; Green, Joseph J. <JGreen@KelleyDrye.com>
Subject: Steel Industry's Proposed Redlines to Subpart AAa NSPS for EAF and AOD


Dear Dr. Jones,    I hope you are doing well.  On behalf of the Steel Manufacturers Association (SMA), American Iron & Steel Institute (AISI), and Specialty Steel Industry of North America (SSINA), I am attaching the steel industry's proposed redline edits to the Subpart AAa NSPS for Electric Arc Furnaces (EAFs) and Argon-Oxygen Decarburization vessels (AOD).   We recognize that it has taken us a long time to get these to you, but the time was not wasted; We were able to compile and coordinate feedback and recommendations from all three steel associations and each of their participating member companies.  And as a result of that collaborative process, I believe we were able to develop recommendations that can help EPA clarify and improve the structure of the NSPS.  
 
We appreciate you allowing us to provide these proposed edits and recommendations, and we look forward to discussing them with you at your convenience.  To that end, I plan to reach out to you again in early December to schedule a follow-up discussion with representatives of the three steel associations (copied here).   In the meantime, please let me know if you have any questions or issues you would like to discuss.  Until then, I hope you and yours have a very happy Thanksgiving.
 
Best wishes,
Wayne
 
WAYNE D'ANGELO
Partner
Kelley Drye & Warren LLP
Washington Harbour
3050 K Street NW, Suite 400
Washington, DC 20007
Tel: (202) 342-8525
Cell: (202) 329-3977

WWW.KELLEYDRYE.COM

wdangelo@kelleydrye.com


