

Date:
February 13, 2020
To:
Phil Mulrine, U.S. EPA
From:
Jeff Coburn
Subject:
Meeting Record for February 12, 2020, Teleconference Meeting between Representatives of American Foundry Society (AFS) and Representatives of U.S. Environmental Protection Agency (EPA)

Meeting Attendees:
 Chuck French, U.S. EPA, Office of Air Quality Planning and Standards (OAQPS)
 Phil Mulrine, U.S. EPA/OAQPS
 Kevin McGinn, U.S. EPA/OAQPS
 Rochelle Boyd, U.S. EPA/OAQPS
 Jon Averback, U.S. EPA, Office of General Counsel
 Jeff Coburn, RTI (contractor for U.S. EPA/OAQPS)
 Jeff Hannapel, The Policy Group (representing AFS)
 Jeet Radia, McWane (representing AFS)
 Craig Schmeisser, Mad River Strategies (representing AFS)
Purpose of Meeting:
      To better understand two unique comments submitted by AFS (Docket ID No. EPA-HQ-OQR-2019-0373-0068). The first comment is regarding the emission limit for volatile organic hazardous air pollutants (VOHAP) from cupolas during startup and shutdown. The second item is regarding the compliance time for the proposed startup, shutdown, and malfunction (SSM) revisions.
Discussion:
Issue 1. Compliance with cupola VOHAP limit during startup and shutdown.
	In their comments, AFS had recommended additional revisions to the definition of "off blast" and specific definitions for "cupola startup" and "cupola shutdown." EPA inquired why they thought these definitions were necessary. AFS representatives noted that there were several "preparatory steps" used to get the cupola ready prior to addition of metal. AFS intended these definitions, for example "Cupola Startup means the time beginning when molten metal is first tapped from a cupola that had previously been shut down," to exclude these preparatory steps from the VOHAP emissions limit. EPA noted that an emissions limit must apply whenever there are emissions from the source. AFS representatives expressed concern that the stack temperature during startup would be below 1,300 °F operating limit. Even though this operating limit only applies while the cupola is "on blast," the lower stack temperature may be seen as credible evidence by enforcement personnel that the unit is not meeting the emission limit. Additionally, even though the proposed rule specifies that performance tests be conducted during normal operations, the AFS representatives expressed concern regarding the liability of meeting the cupola VOHAP limit at all times. EPA noted that the emission limitations that apply during startup (or during these preparatory steps) do not have to be the same as the emission limits that apply during normal operation and could be in the form of a work practice standard. The EPA provided some examples startup and shutdown work practice standards and operating limits that that have been developed for other source categories. AFS representatives stated that they would have to confer with their members to see what emission limitation may be applicable for cupola startup and shutdown.  
Issue 2. Compliance date for the proposed SSM revisions.
      In their comments, AFS had recommended the compliance date related to the proposed SSM revisions be moved to six months from the date of the final rule. The EPA noted that the SSM provisions have been vacated for several years and requested additional information regarding why more time was needed to implement these revisions. AFS noted that many facilities have SSM plans integrated in their operating and maintenance (O&M) plans and needed time to extract the SSM plan from the O&M plan. Even if the SSM plan do not have to be extracted from the O&M plan (whether integrated or not), the O&M plans must be reviewed and perhaps revised to ensure compliance with the emission limits at all times and to revise recordkeeping and reporting procedures to comply with the proposed recordkeeping and reporting amendments. AFS noted that many facilities report based on their Title V permit, so reporting period ends at the end of the calendar year. They noted that aligning the compliance dates of the SSM revisions with the proposed electronic reporting revisions would help to ensure O&M plans can be revised, with sufficient time or review, and directly address any recordkeeping and reporting revisions. 
Next Steps:
      AFS will confer with their members and develop a strawman for emission limitations applicable for cupola startup and shutdown. There is an AFS committee meeting on March 4, 2020, where they will discuss the strawman and decide on final recommendations. AFS is to provide EPA the strawman emission limitations by February 28, 2020 and provide EPA their formal recommendations early the week of Mach 9, 2020.
      AFS will also provide additional details on the revisions required to the O&M plan, the review schedule, and additional detail why an additional 6-month period is needed to comply with the proposed SSM revisions. 
