MEMORANDUM

Subject:	Summary of Meeting with Aluminum Association Representatives on
 			December 21, 2011

From:		Mark Bahner, RTI, International

To:		Rochelle Boyd, EPA/OAQPS

I.	Purpose

	The purpose of the meeting was to discuss Aluminum Association
Representatives’ comments on testing of uncontrolled furnaces. The
Environmental Protection Agency (EPA) is considering a requirement that
capture requirements similar to those that currently exist for
controlled furnaces (which must have hooding that meets American
Conference of Governmental Industrial Hygienists [ACGIH] guidelines)
apply to compliance testing of uncontrolled furnaces.  

II.	Place and Date

	The teleconference meeting was held between the EPA and aluminum
industry respresentatives between 10:00 AM and approximately 11:30 AM on
December 21, 2011. 

III.	Attendees

	Name			Affiliation

	Rochelle Boyd	*	EPA/Office of Air Quality Planning and Standards
(OAQPS)

	Chuck Johnnson*	Aluminum Association

	Mike Palazzolo*	Alcoa

	Lee Califf*		Alcoa

	Denis Fitzgibbons*	Novelis 

	Jason Perdion*	Baker Hostetler

	Mike Laney*		RTI, International

	Mark Bahner*		RTI, International

	Scott Throwe*		EPA/Office of Enforcement and Compliance Assessment
(OECA)

	Mark Kataoka*	EPA/Office of General Counsel (OGC)

	Jeff Gahris*		EPA/Region 5

	

* Attendance via teleconference.

IV.	Meeting Summary

	Industry representatives presented information on the types of furnaces
that are uncontrolled, such as side well, reverberatory round top,
reverberatory box, reverberatory spout, induction, and holding furnaces.
The typical charging capture techniques, charging practices, furnace
feeds, and furnace dwell times (amount of time from initial charge to
tapping) were described for each furnace. The EPA concluded the meeting
by requesting further information, such as: a) the types of furnaces for
which the industry thought it would not be possible to provide capture
during performance testing similar to the capture achieved by controlled
furnaces, b) the type of monitoring currently in place and that could be
developed for uncontrolled furnaces, and c) the type of work standards
that are currently in place or could be developed for these uncontrolled
furnaces.  	

