Conrad Chin/RTP/USEPA/US 

11/29/2007 01:48 PM	To

Conrad Chin/RTP/USEPA/US@EPA

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Subject

Clarification on AFS Comments

	

		

		On page 38 in Section VIII (Opacity Limit) of AFS comments dated
November 

1, 2007, AFS proposed to use EPA Method 22 as a screening tool to 

demonstrate compliance with the proposed opacity limit for the area
source 

foundries rule.  In the comments, AFS stated that if NO fugitive
emissions 

are visible from the facility, the proposed opacity would be met.  If 

fugitive emissions are visible from the facility, then the foundry could


conduct a (EPA) Method 9 test to demonstrate compliance with the opacity


limit.

		

		A call was initiated by Conrad Chin to Christian Richter of AFS on 

November 28 for clarification on:

		1) the frequency of the proposed Method 22 observation

		2) confirmation that AFS was proposing that Method 9 would be followed
if 

fugitive emissions are observed during the Method 22 screening test

		

		A phone message was left by Jeff Hannapel of AFS to Conrad Chin on the


same day in response to EPA's inquiry:

		1) AFS preferred Method 22 to be performed on an annual basis.

		2)  AFS confirmed that Method 22 is the preferred screening tool to 

demonstrate compliance with the opacity limit.  Jeff Hannapel reiterated


that, since Method 22 does not require a certified observer, it will 

minimize burden on smaller foundries.  AFS confirmed that if no visible 

emissions are observed for Method 22, then the semi-annual Method 9
would 

not be required.

		

		

		Conrad K. Chin

Mail Code D243-02

Metals and Minerals Group

Sector Policies and Programs Division

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

919-541-1512 (voice)

919-541-3207 (fax)

