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.