February 20, 2003

Ashland Specialty Chemical Company

5200 Blazer Parkway, Dublin, OH 43017

Technical Contact: Ralph Showman

Iron and Steel Foundries NESHAP Docket

EPA Docket Center (Air Docket)

U.S. EPA West (MD-6102T)

Room B-108

1200 Pennsylvania Avenue, NW **Electronic Submittal**

Washington, DC 20460 **Paper Copy to Follow by Mail**

#### Attention: Docket ID No. OAR-2002-0034

Dear Sir or Madam:

The Casting Solutions business unit of Ashland Specialty Chemical
Company ("Ashland") appreciates the opportunity to provide comments on
the National Emission Standards for Hazardous Air Pollutants for Iron
and Steel Foundries published as a proposed rule on December 23, 2002
(67 *[Federal Register]{.underline}* 78273). Ashland Casting Solutions
is a global market leader in the production and distribution of iron and
steel foundry sand binder and coating products, and is dedicated to the
ongoing development of high performance products and technology for the
metal casting industry.

Ashland Casting Solutions supports the spirit of this proposed emission
standard as it serves to reinforce our industry's efforts to develop
lower HAP-containing resins that will improve the air quality of our
nation. Ashland is an active member of the American Chemistry Council.
As such, we adhere to the tenets of Responsible Care^1^. Casting
Solutions is also an active member of the American Foundry Society (AFS)
and Ohio Cast Metals Association (OCMA), and as such offer our support
of their comments on this proposed rule.

Casting Solutions operates three foundry product manufacturing locations
in the United States and Canada serving hundreds of potentially impacted
foundry customers. We provide our customers with technical service, new
and innovative products, and solutions created specifically for their
needs. As we have such a close relationship with the facilities to be
impacted by this proposed rule, I requested our broad-based team of
Ashland technical service, product development, and environmental
compliance experts to evaluate the draft emission standard. Their
findings and recommendations for EPA consideration are attached.

Ashland Specialty Chemical Company, a division of Ashland Inc., is a
leading, worldwide supplier of specialty chemicals serving industries
including adhesives, automotive, composites, foundry, merchant marine,
paint, paper, plastics and semiconductors.

As noted above, Mr. Ralph Showman (614 790-3976) serves as the technical
contact for these comments. We thank you in advance for consideration of
our comments and welcome any questions.

Respectfully yours,

Gregory M. MacIver

Global Business Director, Foundry Binder Solutions

Attachment

CC: Kevin Cavender

Metals Group (MD-C439-02)

Emission Standards Division

Office of Air Quality Planning and Standards

United States Environmental Protection Agency

Research Triangle Park, NC 27711

Comments on Iron & Steel Foundry NESHAP Standard

**Prepared by**

**Ashland Specialty Chemical Company -- Casting Solutions**

A.  Ashland Specialty Chemical Company (Ashland) respectfully requests
    the Agency reconsider the proposed outlet concentration of one part
    per million by volume (ppmv) for triethylamine (TEA) catalyst
    emissions from phenolic urethane cold box (PUCB) operations \[40 CFR
    63.7690(a)(8)\].

Ashland supports EPA's determination of an acid scrubber as the
technology best suited for controlling emissions from PUCB operations.
Acid scrubbing of PUCB emissions allows for catalyst reuse, reduces raw
material purchases, and promotes pollution prevention. However, Ashland
would like to comment on the reality of the proposed one ppmv outlet
concentration standard, EPA's basis for the MACT floor, and the effect
this emission limit will have on the benefits gained from using acid
scrubber technology.

Control efficiency ranges of 98 percent to 99.9 percent are referenced
in the preamble for acid scrubbers on PUCB operations. Scrubber
manufacturers specify the performance of their equipment as percent
control efficiency, with the outlet concentration being directly
dependent on the inlet concentration. Based on typical foundry
conditions, even the highest control efficiency referenced by EPA is not
reasonable to meet the outlet TEA concentration limit of one ppmv. For
example, typical scrubber inlet TEA concentrations range from 1,000 to
10,000 ppmv, and a 99.9 percent efficient scrubber would only be able to
produce an outlet concentration of one to ten ppmv, respectively.

In contrast to data referenced by EPA, scrubber vendors typically
specify performance at 98 percent. Therefore, at typical foundry
conditions the scrubber outlet concentrations could be as high as 200
ppmv. Although EPA correctly notes that over 12 percent of PUCB lines
are operated with acid scrubber emission control systems, they
incorrectly conclude that all these systems achieve control efficiencies
above 98 percent and outlet concentrations as low as one ppmv. Based on
the vendor specifications and operational considerations above, Ashland
believes this conclusion is not accurate.

The preamble notes that 335 of the 469 known PUCB lines are operated
with acid scrubber controls. However, EPA admits reliable stack test
data only exist for seven of these scrubbers. Ashland is concerned that
the type of equipment operated and their conditions during these stack
tests do not represent typical foundry conditions. The preamble notes
that the highest inlet TEA concentrations found during these seven tests
ranged from 209 to 255 ppmv. These results are much lower than the
typical foundry conditions described above, and Ashland is concerned
that these tests may not have been representative of PUCB lines
industry-wide.

Ashland is also concerned that the outlet stack tests referenced by EPA
do not represent acid scrubber performance achieved over the duration of
a typical scrubbing solution cycle. Stack tests conducted on scrubbers
that contain fresh acid scrubbing solutions can show higher emission
control than tests conducted on scrubbers that contain scrubbing
solution that has been used for several days. Properly sized acid
scrubber systems used for foundry applications operate on a scrubbing
solution cycle of one week or more. That is, depending on
facility-specific operational and scrubber conditions, spent scrubbing
solution will not be replaced with fresh acid until after one week or
more of use. Replacing scrubber solutions more frequently may provide
higher emission control, but it becomes impractical due to raw material
use and cost considerations.

Replacing scrubber solutions more frequently will certainly affect
pollution prevention and raw material reduction efforts that the
industry has made in recent years. Scrubber solution sludge produced
from acid scrubbers can be recycled by programs currently offered to the
U.S. metal casting industry, and these programs have been recognized by
the Ohio EPA as a pollution prevention tool. Each year in the U.S.,
between four to six million pounds of spent scrubber solution are
recycled and between one and one-half and two million pounds of amines
are purified to virgin specification and reused in foundry PUCB
operations.

The proposed one ppmv outlet concentration emission limit may threaten
these recycling efforts because foundries would be forced to decrease
scrubbing solution cycle times and charge fresh acid more frequently.
This scenario would change the balance between free sulfuric acid and
amines in spent scrubbing solutions. Recycling programs require that
spent scrubbing solutions meet certain specifications for free sulfuric
acid and amine content, and solutions generated under this scenario may
not meet these specifications. This scenario would therefore increase
the amount of acid and amine purchased and used by foundries, increase
the wastes generated, and actually lead to an increase in emissions to
the environment.

In summary, Ashland believes that the information EPA examined on PUCB
foundry operations and their associated acid scrubber control systems
was not adequate for establishing the MACT floor. Setting the floor at
one ppmv will threaten established pollution prevention and raw material
reduction efforts. Ashland therefore proposes a TEA emission control
standard of 98 percent be established for PUCB acid scrubbers at Iron
and Steel Foundries.

B.  Ashland respectfully requests that the Agency clarify and better
    define what ingredients may be added to a mold and/or core coating
    formulation \[40 CFR 63.7700(c)\].

First, Ashland would like to clarify that there is a difference between
a coating carrier and an active ingredient. While methanol was commonly
used as a coating carrier in the past, water-based carriers are more
widely used today. However, Ashland must note that methanol may also be
used as an ingredient in coatings, or may be present in an ingredient
such as a biocide or surfactant, in order to activate the solids that
provide the properties necessary in mold and core coatings. Methanol is
typically added for this purpose in amounts less than one percent.
Reformulating coatings to remove this small amount of methanol would
require a change in the solids suspension agents as well. This
reformulation would require extensive developmental work and would
trigger the supply-chain approval process throughout the industry.
Ashland notes that under 40 CFR 63.7735(a)(3), maintaining "appropriate"
material safety data sheets (MSDS) provides sufficient documentation
under the 63.7700(c) requirement. Ingredient information on
"appropriate" MSDS are only required for components above one percent
(or 0.1 percent for carcinogenic chemicals).

Ashland would also like to note that replacing methanol as a carrier in
solvent-based coating systems increases their cost roughly \$100 to
\$300 per ton of coating used. Other costs apparently not included in
EPA's evaluation include those associated with increased fuel or
electricity use for drying water-based coatings.

Second, hazardous air pollutants (HAP) can be minor components in the
materials commonly added as ingredients to coatings. These HAP chemicals
are not direct ingredients added to the coatings, but are typically
minor components, or even contaminants, in those ingredients.

Ashland respectfully requests that EPA revise 63.7700(c) to allow HAP
ingredients to be added to mold and core coating formulations at amounts
less than one percent (or 0.1 percent for carcinogenic chemicals), and
specifically define "coating ingredients" as "materials specifically
added to mold and core coatings during production." Ashland would like
to encourage EPA to continue allowing "appropriate" MSDS to satisfy the
recordkeeping requirement of 63.7735(a)(3).

C.  Ashland respectfully requests that the Agency clarify and better
    define what ingredients may be added to a furan warm box binder
    system formulation \[40 CFR 63.7700(d)\].

Similar to the coatings issue above, Ashland would like to clarify that
there is a difference between the resin and catalyst within a furan warm
box binder system. In the preamble, EPA notes that 42 percent of the
known furan warm box lines use a water based, HAP-free binder system.
While the catalyst portion of current systems is often water-based,
catalysts were commonly methanol-based in the past.

The resin portion of these systems has typically been solvent-based, and
current furan warm box resins can contain up to five percent methanol.
Methanol is used as stabilizer to keep the resin in a homogeneous state.
Ashland believes that EPA's statement in the preamble "according to
industry suppliers, the furan warm box system can be formulated without
methanol" should have referred only to the catalyst portion of these
systems.

Ashland therefore respectfully requests that EPA clarify that furan warm
box catalysts should be HAP-free, but allow furan warm box resins to
contain no more than five percent methanol by weight. Ashland notes that
as with coatings, any reformulation would trigger the supply-chain
approval process throughout the industry.

D.  Ashland respectfully requests that the Agency reconsider the
    required use of naphthalene-depleted solvents in PUCB or phenolic
    urethane no-bake (PUNB) binder system formulations \[40 CFR
    63.7700(e)\].

Binder system evaluations have shown that the use of
naphthalene-depleted solvents increases emissions of volatile organic
compounds (VOC). Also, naphthalene-depleted based PUCB or PUNB systems
are often less resistant to humidity and can affect benchlife. Ashland
believes EPA should consider some of the other mechanisms available to
reduce HAP emissions from PUCB and PUNB lines. These could include the
use of other solvents in combination with napthalene-containing
solvents, high strength systems that can reduce the amount of binder
used and thus total HAPs, or other base resins that may perform best
with napthalene containing solvents but reduce other HAPs.

Naphthalene-depleted solvents cost 50 to 64 percent more than
naphthalene-containing solvents. Current estimates place
naphthalene-depleted solvents at 21 cents per pound higher than their
naphthalene-containing counterparts. Another cost increase to the PUCB
and PUNB binder system market would be due to the cost of binder
reformulation. One binder system vendor has estimated this cost to be
around one million dollars for their 50 current naphthalene-containing
binder formulations, and as noted above any reformulation would trigger
the supply-chain approval process throughout the industry.

The cost estimates provided above would increase once this requirement
is finalized. Once naphthalene-depleted solvents are required for use in
PUCB and PUNB binder systems, their increased demand will drive cost
well above what it is today.

Ashland therefore respectfully requests that EPA reconsider the required
use of naphthalene-depleted solvents in PUCB or PUNB binder system
formulations. Ashland believes that further EPA research will likely
result in other, less costly mechanisms to reduce HAP emissions from
PUCB and PUNB lines.

E.  Ashland respectfully requests the Agency reconsider the requirement
    for foundries using binder systems other than PUCB, PUNB, or furan
    warm box to conduct a study to evaluate and identify available
    reduced-HAP binder formulations \[40 CFR 63.7700(f)\].

Ashland supports EPA's decision to set the MACT floor at "no change in
formulation" for these binder systems. However, the requirement to
conduct a initial study, and the repeated studies due upon a facility's
renewal of its operating permit, has not been well defined in the
proposed rule or preamble. There has been no attempt at defining, or
identifying, the baseline facilities should consider in evaluating
reduced-HAP formulations.

Ashland believes EPA used the PUCB 305/904-GR binder system as a
baseline during its development of this proposed rule. If this binder
system is considered the baseline, virtually every foundry resin binder
system used today could be considered to be reduced-HAP. If EPA
considers a foundry's current binder system to be the baseline, then
conducting a study every five years would most certainly find lower
HAP-containing binder systems and the foundry would be required to prove
changing to that system would be economically infeasible. Since
foundries typically use the same binder systems for much more than five
years, this seems to be a potential misuse of foundry resources.

Therefore, Ashland respectfully requests that EPA remove the requirement
to conduct these studies. If EPA decides not to remove this requirement,
Ashland requests that EPA specifically define the baseline to which the
industry will be compared, define how much reduction in HAP constitutes
a "reduced-HAP binder formulation," and define the terms "technically or
economically infeasible."