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 not ified 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, addre sses 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 sec ondary 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 attachmentsFrom: 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

propo sed 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 t o 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