October 31, 2007

Area Source NESHAP for Iron and Steel Foundries Docket

U.S. Environmental Protection Agency

Air and Radiation Docket and Information Center (Mailcode 2822T)

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

Re: Area Source NESHAP for Iron and Steel Foundries:

Proposed Rule

Docket ID No. EPA-HQ-OAR-2006-0359

Dear Sir or Madam:

The Griffin Wheel Company appreciates the opportunity to submit these
comments on the Area Source NESHAP for Iron and Steel Foundries proposed
by the U.S. Environmental Protection Agency on September 17, 2007 (72
Fed. Reg. 52984). Metal casting is the foundation of U.S. manufacturing
and serves as a vital building block for every nation's economic wealth.
This is especially true in Griffin Wheel's business as a supplier to the
U.S. railroads. The proposed rule will adversely impact U.S. iron and
steel foundries that have emissions of less than 25 tons of total
hazardous air pollutants (HAPs) or 10 tons of a single HAP annually.

In addition to these comments, we support the formal comments on this
proposal submitted by the American Foundry Society. We hereby submit
these comments via email and request that these comments be incorporated
as part of the administrative record for this rulemaking.

Our company and industry supports sound environmental management in
operating our business and our foundry operations are already
effectively regulated by existing federal, state and local air
regulations. If the regulation is allowed to be finalized as proposed,
our company will likely face a substantial economic burden -- more
significant than EPA has estimated in the proposed rule. For example if
our company had to eliminate the use of shredded automobile scrap as a
result of the rule, the potential cost would be almost \$4,000,000
annually. At the same time, the new provisions appear to yield extremely
marginal benefits

Provided below is a more detailed discussion of our comments.

**63.10885 Scrap Management Practices and Mercury Switch Removal
Program**

This section of the rule proposes that all area source foundries, both
large and small, must implement scrap management practices that include
mercury switch removal provisions to reduce HAP emissions. The specific
provisions for mercury switch removal programs for scrap metal used as
feedstock at foundries appear to be particularly onerous, especially the
requirements for site-specific plans.

First, most foundries will be unable technically to implement a
site-specific plan for mercury switch removal that meets the regulatory
requirements, including the provision to obtain assurances from scrap
providers that motor vehicle scrap provided to the facility meets the
scrap specification and obtaining estimates of the number of mercury
switches removed from motor vehicle scrap sent to your facility. This is
in part due to the fact that the scrap dealer is often not the scrap
preparer or automobile shredder and therefore will be reluctant to
provide information or certifications for work they did not perform.
Second, it is not reasonable to burden foundries with the requirement to
ensure that scrap providers and dismantlers are implementing appropriate
steps to remove and dispose of mercury switches. This would appear to be
a function more appropriate for a regulatory agency, not a private
business. These provisions, along with the corrective action
requirements, present significant obstacles to getting a site-specific
plan containing reasonable and achievable practices approved by the
agency. Griffin is also concerned that what constitutes an acceptable
site-specific plan will vary widely from region to region and foundry to
foundry, resulting in an uneven regulatory burden and competitive
advantages throughout the industry.

Requiring all foundries to use only those scrap suppliers that have an
EPA-approved mercury switch removal program could subject foundries to
difficulty obtaining scrap needed as feedstock. Foundries generally have
numerous scrap suppliers, but have little market power to demand that
these suppliers have an EPA-approved program for mercury switches. While
we fully support the Agency's efforts to remove mercury switches from
the scrap metal supply chain and are committed to working toward
achieving this goal, the requirement as proposed is unnecessarily
onerous on the foundry industry. It is our understanding that this same
provision is included in proposed area source rules for larger steel
producing facilities that have much greater market power with scrap
suppliers. Without the necessary market leverage to purchase scrap only
from EPA-approved suppliers and the inability to implement site-specific
plans, the proposed regulatory requirement applicable to mercury
switches in scrap metal would impose an unduly restrictive regulatory
barrier for foundries.

EPA should provide foundries five years to meet the regulatory
requirement and allow the mercury switch removal program to mature and
evolve, primarily through the market presence of larger steel producers.
Furthermore, the mercury switch removal requirements should not apply to
automotive scrap used by foundries that would not include any mercury
switches such as brake rotors and pump housings.

The mercury switch removal program is an appropriate *policy approach*.
It should not, however, be a regulatory requirement for the foundry
industry until more scrap suppliers have EPA-approved programs and a
more reliable supply of scrap that meets the regulatory requirement is
available for the foundry industry. We would support a provision where
the implementation period for small foundries would begin when a certain
number of scrap dealers (80%) are registered in the federal program.

Under the provisions of (d)(v) of the proposed rule, the facility must
submit semi-annual progress reports to the Administrator that provide
the number of mercury switches removed or the weight of the mercury
recovered. This is information that the foundry would not be able to
obtain and this information should be received directly from the scrap
dealers through their participation in the mercury switch removal
program. The proposed regulation does not address the use of scrap
brokers that supply a large majority of small foundries with their
scrap. This adds another layer of separation to the foundry and only
increases the burden of receiving information on the scrap used in their
process.

Finally, the Mercury switch provisions of the rule should contain a
sunset clause, beyond which these requirements no longer apply. The
reason for such a clause is that according to the ELVS Corporation's
2006 annual report auto manufactures phase-out the use of mercury
switches in new automobiles by January 2003. Therefore, the number of
pre-2003 automobiles which are recycled each year will decrease and
eventually get to a point where a minimal number of pre-2003 autos are
shredded and melted down. Unfortunately, Griffin Wheel does not possess
the information necessary to recommend a timeframe for this sunset
provision. However, information should be available to allow the agency
to estimate a point in the future where less than 5% or 10% of all
automobiles recycled are pre-2003 vehicles. This would seem to be an
appropriate point at which these onerous requirements cease to be a
significant environmental benefit and the requirements should lapse.

**63.10895 Standards and Management Practices**

63.10895 (c) (3) states that for each baghouse applied to emissions from
a metal melting furnace that is subject to the monitoring and inspection
requirements in 63.10897(c), you must maintain the pressure drop across
each baghouse cell within the range established during the initial or
subsequent performance test. Upper and lower operating pressure limits
for a baghouse should be based on manufacturer's recommendation and on
good engineering practices, ***not*** on limit range observed during a
stack test. Most operating permits have established acceptable operating
limits listed in the permit already. This requirement is also listed in
Table 3 to Subpart ZZZZZ of the rule. We request that the static
pressure range be based on manufacturer's recommendation and good
engineering practices if a static pressure range is not already listed
in an operating permit.

63.10895 (d) proposes an opacity limit of twenty percent for fugitive
emissions. To minimize the burden on small foundries, EPA should allow
facilities to use a simple visual test for fugitive emissions based on
qualitative opacity assessments similar to that currently contained in
Griffin Wheel Kansas City facility's Title V permit. Such a standard
would require a knowledgeable person make periodic qualitative opacity
assessment observations of each fugitive emission point to determine
whether the emissions appear normal for the give foundry operation(s)
along with other relevant information. Should abnormal emissions be
observed, a corrective action investigation would be required to be
initiated along with more frequent (i.e. daily) opacity assessments. A
copy of the appropriate section of our Kansas City Title V permit is
attached for your review.

The MACT standard requires that foundries do a Method 9 test during your
compliance stack test to comply with the fugitive limit and allows a
6-minute average on 27 percent opacity during this observation period.
The Area Source rule requirements should not be any more restrictive
than the MACT standard. The qualitative opacity assessment with a Method
9 test during stack testing would be adequate to demonstrate compliance
with the proposed opacity limit and, most importantly, it would minimize
the burden to the foundry industry.

**63.10896 Operation and Maintenance Requirements**

63.10896 (a) states that you must prepare and follow a written operation
and maintenance plan for each control device used to comply with the
requirements of this subpart. This is a big burden on a small operation
that does not have a full time person assigned to compliance issues. The
same purpose can be achieved without the requirement of a written plan.
Many states have issued Title V permits that require a facility to
measure and record pressure drop from the baghouses without the need to
write a plan. By requiring a written plan you are placing an unnecessary
burden of time and money on the facility with little environmental
benefit achieved. The goal is to assure the baghouse is operating
properly and by requiring the baghouse to operate within a prescribed
pressure drop and requiring daily checks on the static pressure and
regular inspections of the baghouse you will achieve your goal without
the need to require a written plan. The development of an O&M plan would
cost in the range of \$2000 - \$2500 for a small facility. We recommend
that you eliminate the need for a written plan in the final rule.

63.10897 (c) (1) states that you must measure and record the pressure
drop across each baghouse cell each day. The pressure drop should be
required to be measured and recorded across the entire baghouse, not a
particular cell. Many multi-cell baghouses do not have a pressure drop
gauge on each cell and this would increase the burden of this rule to
require a gauge to be installed on each cell of a dust collector. If a
baghouse does have pressure drop gauges on each compartment they are
often located at the compartment entrance and require the reader to
climb the baghouse. This takes additional time and effort and represents
additional safety risk when compared to recording a singe pressure drop
from the entire baghouse pressure drop device which is usually located
at ground level. Also, on multi-cell baghouses not all compartments are
on line at the same time (i.e. during the cleaning cycle, maintenance,
etc). The total pressure drop across a baghouse would give you a good
indication if the collector is operating properly. There are various
areas in the rule (i.e. 63.10896 (c)(3)) that refer to the pressure drop
across a cell and we request that this requirement be changed to "across
the baghouse" throughout the rule.

63.10897 (c) (3) states that you must check the compressed air supply
for pulse-jet baghouses each day. By requiring a daily pressure drop
reading of the baghouse this requirement of daily compressed air supply
checks should not be required. If the static pressure is higher than the
allowable range this would indicate that a problem with the cleaning
cycle exists and you would institute corrective action to address the
high static pressure. Requiring a daily check of the compressed air
supply would not provide assurance that the cleaning system is working
properly. You get a better indication as to the proper operation of the
cleaning system by recording the daily static pressure reading. We
recommend that you remove this requirement to check the compressed air
supply each day from the rule.

63.10897 (c) (6) Make monthly visual checks of bag tension on reverse
air and shaker-type baghouses to insure that bags are not kinked (kneed
or bent) or lying on their sides.

Most baghouse manufactures recommend that an internal inspection be
completed on a unit on a semi-annual basis. Most small companies do not
have the personnel to inspect these units in-house and contract this
work out. The most likely time to do this job without spending
additional monies on overtime is during the facilities shutdown periods.
Therefore it would be beneficial to require this inspection to be done
on a semi-annual basis where this work could be completed on regular
time during maintenance shutdown periods. By reducing the required
inspection from monthly to semi-annual the typical facility would
realize a saving of \$1200 -- \$1500 per year.

63.10897 (c) (7) Confirm the physical integrity of the baghouse through
quarterly visual inspections of the baghouse interior for air leaks.
Again, this is most likely a function that would be contracted out and
is best accomplished during shutdown periods are described above.

63.10897 (c) (8) Inspect fan for wear, material buildup, and corrosion
through quarterly visual inspections, vibration detectors, or equivalent
means. See response for (c) (6) above. Most dust collectors used at area
source facilities do not operate on a 24 hour schedule and therefore do
not see significant wear that would warrant a quarterly inspection of
the fan and housing. A semi-annual inspection would be sufficient to
insure good fan operations.

If a facility completed all of the required inspection as one
semi-annual inspection of the baghouse the combined savings for the
facility would be in the range of \$2,500 to \$3,000 per year. This
would be a significant savings for a small facility and would still be
an adequate inspection frequency to assure good operation of the
baghouse.

**63.10898 Performance Test Requirements**

63.10898 requires that you demonstrate initial compliance with the
proposed rule through stack testing of the source. We support your
proposal of allowing you to submit prior stack testing results if these
tests were conducted within the past 5 years and your process has not
changed. Section (2)(b) further states that you must conduct subsequent
performance testing every 5 years to demonstrate compliance with the
rule. We would request that you consider a provision that would
eliminate the required testing every 5 years if your initial stack test
results were less than 75% of the proposed regulatory limit provided
that your process has not changed. This provision would be a significant
savings to a small foundry.

**Title V Permit Exemption**

Finally, we agree with EPA's proposal that iron and steel foundries area
sources should be exempt from federal Title V permit requirements.
Adequate permitting and compliance requirements are already in place for
foundry area sources. Requiring federal Title V permit requirements in
addition to the requirements proposed in this rule (as well as other
applicable state and federal air regulatory requirements) would be
redundant and unnecessarily burdensome. Applying Title V permit
requirements to iron and steel foundry area sources would provide little
or no additional environmental or administrative safeguards yet would
impose unnecessary costs on foundries and additional administrative
burdens on regulatory agencies. The proposed Title V permit exemption is
an appropriate provision in this proposed rule.

On behalf of Griffin Wheel, thank you for the opportunity to submit
these comments. If you have any questions or would like additional
information, please contact me at (614) 836-2323 ext. 256.

> Sincerely,
>
> Kim Myers
>
> Environmental Specialist
>
> Griffin Wheel Company

cc: Ray Ostrowski -- Griffin Wheel