Memorandum

Subject:		Meeting with Johnson Controls International (JCI)

Location:		U.S. Environmental Protection Agency, RTP, NC
	
Date:			September 28, 2011

Participants:	 	Chuck French, EPA
			Nate Topham, EPA
			Colin Boswell, EPA
			Steve Silverman, EPA
			Bernie Hawkins, Nelson Mullins
			Michael Carr, JCI
			Keith McCoy, JCI
			Tim LaFond, JCI
			Gil Cubia, JCI
			Donna Lazzari, ERG
			Mike Burr, ERG

The U.S. Environmental Protection Agency (EPA) met with representatives of Johnson Controls  Battery Group, Inc. (JCI).  The purpose of the meeting was to discuss the proposed rule for the secondary lead smelting source category.  A brief summary of the key points that were discussed is outlined below.

   * JCI gave background information on the company and the existence of the Florence Recycling Center, which commenced construction  in Florence, SC prior to the proposed Subpart X revisions.  This included a discussion of JCI's collaboration with environmental groups during the planning phase for the facility.  JCI also described the types of emission controls that will be implemented at the facility.

   * JCI had comments and/or asked for clarification on specific aspects of the proposed rules.  These included:
         o JCI first stated their support for EPA's conclusions in the proposed rule regarding the Wet Electrostatic Precipitator (WESP) technology.  JCI added that lack of technical feasibility provided additional grounds supporting EPA's conclusion. 
         o JCI questioned the necessity of the proposed stack lead emissions limit and expressed concern about its appropriateness for all stacks, with a specific example of a battery breaker stack given.
         o JCI also expressed concern about the total hydrocarbon (THC) and dioxin and furan (D/F) emission limits proposed for rotary furnaces.  They stated that it would not be appropriate to derive a limit for rotary furnaces based on other furnace types.  They also stated  an important variable affecting emissions from a furnace was the operating environment of the furnace (i.e., temperature), in addition to  the types of material processed in the furnace.  JCI also questioned the rationale for establishing limits for THC and D/F in the proposed rule.
         o JCI expressed concern about EPA's proposal to require lead continuous emission monitoring systems (CEMS) for any sources and encouraged EPA to forego the CEMS requirements until more information regarding cost and technical feasibility is available.
         o JCI recommended a more flexible approach regarding the fugitive emission work practices.  They stated that a complete menu of prescribed practices is not necessary, and that facilities should have the option to choose work practices that are effective at their specific facility.  JCI stated that necessary changes could be implemented in the source's standard operating procedures plan. Specific work practices that JCI pointed out as unnecessary were the roof washing requirement,  the requirement to measure both differential pressure and inflow velocity in the total enclosures and, to the extent EPA requires an inflow velocity, a requirement for a specific minimum velocity value (versus simply a demonstration of negative flow).
         o JCI reiterated that it was not waiving any of the other comments it submitted in writing to EPA on July 26, 2011. 

