### Memorandum

**Subject:** Meeting with Johnson Controls I nternational (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 L aFond, JCI Gil Cubia, JCI Donna Lazzari, ERG Mike Burr, ERG The U.S. Environmental Protection Agency (EPA) met with representatives of Johnson Controls Batte ry 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 an d the existence of the Florence Recy cling 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 facili ty . JCIalso described the ty pes of emission controls that will be implemented at the facilit y.

 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 conclusio ns in the proposed rule regarding the Wet Electrostatic Precipitator (WESP) technology . JCIadded 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 hy drocarbon (THC) and dioxin and furan (D/F) emission limits proposed for r otary furnaces. They

stated that it would not be appropriate to derive a limit for rotary furnaces based on other furnace t ypes . They

also stated a n important variable affecting emissions from a furnace was the operating environment of the furnace (i.e. , temperature), inaddition to the ty pes 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 sy stems (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 practic es. 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 . JCIstated that necessary changes could be implemented in th e source's standard operating procedures plan. Specific work practices that JCIpointed 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 ext ent 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.