TO:	EPA Docket No. EPA-HQ-OAR-2006-0359

		

FROM:	Conrad Chin, EPA/SPPD 

DATE:	October 24, 2007

SUBJECT:	Meeting with Foundry Industry Representatives on October 4,
2007

I.	Participants

Foundry Representatives:

Christian Richter

Jeff Hannapel

Jeet Radia

Steve Lewallen

Craig Schmeisser

Ann Neudorfer

Ray Ostrowski

EPA Representatives

Steve Fruh

Conrad Chin

EPA Contractor

Jeff Coburn

II.	Summary of Discussion

Representatives of the iron and steel foundry industry requested a
meeting at RTP with EPA to discuss their concerns on the proposed 
National Emission Standards for Hazardous Air Pollutants (NESHAP) for
Iron and Steel Foundries Area Sources.

Industry provided information and opinion on the following topics during
the meeting:

Cost effectiveness/cost impact of the proposed rule

Stack test and pressure drop range for baghouses

Scrap management practices and mercury switch removal program

Capture/collection requirements for melting furnaces

Title V permit exemption

Specific Discussion

Industry representatives provided a handout (attached) to demonstrate
their claim that the uncontrolled emission factor should be less than 2
lb/ton for EIFs.  They suggested that the emission factor should be 1.36
lb/ton.  According to the industry, the cost effectiveness of  the
proposed rule would decrease by using the recommended emission factor.

Regarding stack testing, industry suggested that establishing an
operating range for a baghouse pressure drop would be technically
infeasible.

Regarding scrap management, industry informed EPA that foundries are
having difficulties in identifying scrap suppliers who participate in
EPA-approved programs.  Industry suggested that foundries would need
additional time to comply with this provision.  Industry also suggested
that the scrap management practices should not be imposed on auto
components other than shredded auto because auto components do not
contain mercury.

Regarding monitoring, industry claimed the capture requirements were
inconsistent in the rule, and requested clarification.

Regarding permitting, industry raised the issue of Title V and suggested
that area source foundries should be exempt from Title V permits.  

Meeting Minutes Memorandum – October 4, 2007, Foundries Meeting

  PAGE  2 

Meeting Minutes Memorandum

