From: Tabor, Troy (EEC) <Troy.Tabor@ky.gov>

Sent: Monday, April 20, 2015 3:46 PM

To: Boyd, Rochelle

Cc: Fowler, Lane (EEC); Blacketer, Bill (EEC)

Subject: RE: Furnaces Switches

Hello Rochelle, I spoke with two Inspectors here at our office (Bill Blacketer and Lane 

Fowler) who also inspect secondary aluminum facilities. We are fortunate that the 

facilities in our region do not often switch back and forth between furnace operating

classifications. I only know of one instance in which one of our regulated facilities 

switched from operating as a group 1 to a group 2 furnace and that was only for a short 

time period.

That instance did not cause us a problem because the facility notified us of their plans 

and secured approval for the alternative operating scenario ahead of time.

As long as the facility in question, posts accurate labels, addresses the operating 

scenarios in their OMM plan, maintains accurate detailed records, addresses their 

operating methods in their permit required reporting, and does not have a history of 

noncompliance or criminal activity, we cannot think of new challenges that frequent 

classification switching would create for us.

I previously inspected a secondary aluminum facility that falsified records, purposefully 

operated at higher production rates than those at which they tested, and installed 

resistors on their control panels that provided inaccurate baghouse inlet temperature 

data. If a facility with a history of noncompliance, and criminal activity, were to propose 

to switch furnace operating classifications frequently, it would create a huge strain on 

our resources to continually confirm that they were operating in the manner that they 

were claiming.

We will continue to think on this issue and see if we can come up with supporting 

arguments for a limitation on furnace classification switching.

Best regards,

please consider the environment before printing this e-mail or its attachments
From: Boyd, Rochelle [mailto:Boyd.Rochelle@epa.gov] 

Sent: Wednesday, April 15, 2015 10:03 AM

To: Tabor, Troy (EEC)

Cc: Fowler, Lane (EEC)

Subject: Furnaces Switches

As per my question regarding furnace switching, I wanted to follow up with you on your 

thoughts about the problems and burdens that you could be faced with in allowing 

companies to switch back and forth between furnace classifications. We originally 

proposed back in 2012 that furnaces could switch from Group 1 to Group 2 (once/ 6 

month period) as long as they met certain requirements. We also added a whole new 

set of testing requirements to make them prove that the materials processed would be 

compliant under the new operating mode. Please let me know what challenges you 

may be faced with in allowing them to switch back and forth numerous times. Because 

of the numerous comments that we received on the 2012 proposal, we increased the 

number of switches to 4 times/ 6 month period in our 2014 supplemental proposal, but 

they are still asking for unlimited switches. Please let me know what challenges this 

may present. Thanks

Rochelle Boyd, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243-02

Ph: (919) 541-1390 Fax: (919) 541-3207