"Jeff Hannapel" <jhannapel@thepolicygroup.com> 
10/12/2007 03:31 PM	To
Rhonda Minnick/DC/USEPA/US@EPA, Conrad Chin/RTP/USEPA/US@EPA
cc
Steve Fruh/RTP/USEPA/US@EPA, <cob@rti.org>, "Jeet Radia" 
<jradia@mcwane.com>, "Christian Richter" <crichter@thepolicygroup.com>
bcc

Subject
Mercury Switch Removal Requirement for Foundry Area Source Rule
	
	
	History:	
This message has been replied to.


Rhonda & Conrad,

 

Thank you very much for taking the time to discuss the mercury switch
removal program and its applicability in the iron and steel foundry area
source rule.  We certainly appreciate your willingness to address this 
issue
and would like to get acknowledgement from OSW that there is an appropriate
and constructive rationale for a phase-in for the mercury switch removal
requirement in the foundry area source rule. Our view is that additional
implementation time would not diminish the value and effectiveness of the
national mercury switch removal program.  Because the public comment period
does end on November 1, 2007, anything that you can do to resolve this 
issue
within the next two weeks would be appreciated

 

As we noted on the call, the American Foundry Society (AFS) supports the
efforts to remove mercury switches from the scrap metal supply chain, the
currently proposed provisions in the area source rule may end up being
inadvertently and unnecessarily onerous on the foundry industry,
particularly small operations.  It is our understanding that this same
provision is included in proposed area source rules for much larger steel
producing facilities that have substantially great market power as 
customers
in the scrap supply chain.  As more scrap suppliers implement this new
regulatory requirement to meet the demands of larger steel producers,
foundries will have more options to purchase scrap from EPA-approved scrap
suppliers.

 

We look forward to working with you and thank you again for your attention
to this matter.  If you have any questions or need additional information,
please contact Christian or me.  Thanks.

 

Jeff

 

 

Jeffery S. Hannapel

The Policy Group

202-457-0630 (Washington Office)

240-499-8105 (Maryland Office)

202-257-3756 (Mobile)

 

