From: 
D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com>
Sent:
Friday, February 12, 2021 10:50 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>; Raymond, Gabrielle <graymond@rti.org>
Subject: 
RE: Another question re: NSPS for EAF


Dr. Jones,   Attached please find the steel associations' answers to your questions on our proposed edits to the EAF NSPS.   I apologize again that it has taken so long to get these to you.    I'm hopeful we are now in a position to respond more quickly and am looking forward a continued dialogue.   As such, please let me know if you have questions about our responses.    

To your questions below, please note that we believe there are two EAFs that remain subject to Subpart AA:
1.           Timken, Harrison, OH (confirmed through OH Title V permit database)
2.           Gerdau, Jackson Michigan (presently idled)

The EAFs at the Gerdau mills in Jackson, Tennessee; St. Paul, Minnesota; and Wilton, Iowa are all now subject to Subpart AAa. 
You are correct that the EAF at Alton Steel is not subject to the NSPS.   I will need to get back to you regarding the EAF at the Beaumont, Texas mill.  That mill is identified below as owned by Gerdau in your table below.  It has since been acquired by Opimus Steel.  I've reached out to the company to see if they have become subject to Subpart AAa and will get back to you.   I will also need to get back to your more recent email asking the steel associations to review and suggest revisions to the spreadsheet of domestic EAFs subject to the NSPS.   The steel associations are reviewing the lists and reaching out to member companies.   I will compile those answers/insights and get them to you as quickly as possible.   

Thanks again for your patience.  Once you have reviewed our edits, I would like to schedule a zoom conference with you and the representatives of the steel associations to discuss our proposed edits, any other input EPA has received on the Subpart AAa review, and to better understand the Agency's overall process/information needs.   Please let me know if you are amenable to such a meeting.

Thanks again and be well,
Wayne

WAYNE D'ANGELO

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

<< Steel response to EPA NSPS questions v1.docx >>

From: Jones, DonnaLee <Jones.Donnalee@epa.gov> 
Sent: Thursday, February 4, 2021 11:07 AM
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>; Raymond, Gabrielle <graymond@rti.org>
Subject: RE: Another question re: NSPS for EAF


Great! Thank you. I will be looking forward to your comments.

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: D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com> 
Sent: Thursday, February 4, 2021 9:03 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: RE: Another question re: NSPS for EAF

Happy New Year Dr. Jones.   I apologize for the delay in getting back to you.  I confess the delay was very much my doing.  I had an incredibly busy January and didn't take the time necessary to finish gathering feedback from the three associations and their members.  I will be able to do so on Monday (2/8) or shortly after.  We've finally managed to schedule a conference with all the relevant associations and facility personnel.  I expect that the our industry conference on Monday will provide the remaining input I need to send you a response.  I'm also hoping that our conference will allow us to nail down an approach that will allow me to provide you future responses more quickly.   

To your performance test question:  Yes, In my experience, EAF mills use Method 5 when conducting performance tests on negative pressure baghouse and 5D for positive pressure baghouses.  I'm not aware of state-by-state variability, but will ask this question as well during the steel industry's conference on Monday.  

Thank you again for your patience and please let me know if you need anything else.  I hope to get you answers to all your questions very soon.  

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: Wednesday, February 3, 2021 7:20 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: Another question re: NSPS for EAF

Happy New Year to everyone. Hope everyone is still doing well. I wanted to check to see if you had heard back from the facilities yet on our regulation questions, but also to ask another question.

Do EAF facilities perform EPA Method 5 PM testing for baghouse performance to meet the gr/dscf NSPS limit (and subpart 5Y NESHAP limit) as part of their permit (Title V?) renewals? I realize this might vary by state, so if you don't know for sure, what is your general collective sense of the testing frequency for the permits? 

Thanks in advance for any assistance with my questions. 

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: D'Angelo, Wayne J. <WDAngelo@KelleyDrye.com> 
Sent: Thursday, December 24, 2020 10:01 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>; GABRIELLE RAYMOND <graymond@rti.org>
Subject: RE: Another question re: NSPS for EAF

Dr. Jones,   Happy holidays.  Offhand, your information appears correct, but I will need to get back to you on the facilities that comply with AA vs. AAa.  I will also provide you an answer on the applicability of the edits.  Thanks very much and happy holidays to you and yours.
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: Wednesday, December 23, 2020 6:48 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>; GABRIELLE RAYMOND <graymond@rti.org>
Subject: RE: Another question re: NSPS for EAF

Wayne, et al  -  Another question or two. Do your edits also apply to subpart AA, if similar language is there? It would be easier for me to not include AA but I can do it if you think some facility would benefit. 

Also, do you know approximately how many facilities comply with subpart AA (built before 8.17.1983 but after 10.21.1974)? From my records, which I have thanks to the EPA ICR and SMA facility list updates (the latest of which was in 2018), I know of three facilities subject to AA, listed below . 

                                   Facility
Subject to NSPS?
                                  Which NSPS?
                                    Status
Ger-Jackson-TN
                                      Yes
                                  Subpart AA
                                     Open
Ger-StPaul-MN
                                      Yes
                                  Subpart AA
                                     Open
Tim-Harrison-OH
                               Yes (1 of 2 EAF)
                                  Subpart AA 
                                     Open
Alton-Alton-IL
                                      No
                                      NA
Open
Ger-Wilton-IA
                                      No
                                      NA
Open
Ger-Beaumont-TX
                                      No
                                      NA
Closed
. 


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.





