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OCMA and Casting Industry
Recent OCMA Accomplishments |
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OCMA and Casting Industry
Recent OCMA Accomplishments |
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OCMA Speakers Awards |
OCMA ACCOMPLISHMENTS
In early 2009, a number of OCMA member foundries had undergone an OSHA inspection in which they have been cited for lack of compliance with NFPA 70E pertaining to the dangers of arc flash. These violations caught several foundry safety personnel by surprise because OSHA regulations do not provide detailed information about arc flash. This is where NFPA 70E comes in. OSHA requires employers to protect their employees from electrical hazards including shock and arc flash. However, as noted above OSHA regs do not cover these hazards. Instead OSHA uses NFPA 70E, a consensus standard of the National Fire Prevention Association to determine compliance with its general duty clause. At the July annual OCMA meeting, a panel of OCMA members who had undergone these inspections discussed their experiences. Members of the panel were OCMA Treasurer John Burke, OSCO Industries, Inc., OCMA Trustee Jeremiah Clegg, Burnham Foundry LLC, OCMA President Jim Flanagan, Babcock & Wilcox Company, and OCMA Trustee Angela Dine Molaskey, St. Marys Foundry, Inc. They pointed out that compliance with NEPA 70E calls for several actions beginning with an arc flash analysis. Costs for consultants to perform the analysis range from $10,000 to $40,000. Without the arc flash analysis, OSHA is citing companies that have not performed the analysis and then citing them for not implementing the protections such an analysis would yield. They are also often cited for not having appropriate training and essential personal protective equipment (PPE). OCMA members requested that OCMA sponsor an Arc Flash Workshop to provide an opportunity for foundry operators to become aware of their legal obligations under NFPA 70E. The workshop was held on Wednesday, September 23, 2009, at the Ashland Casting Solutions training center and more than 45 members and non-members attended. Two outstanding electrical engineering firms, DL Steiner, Inc. and PowerEdge Technologies, Inc. provided a comprehensive outline of what foundries needed to do to comply with NEPA 70E. Beneficial Reuse of Spent Foundry Sand OCMA has led the metal casting industry in striving to remove regulatory barriers to the beneficial reuse of spent, nontoxic foundry sand since its inception. In 1994, after considerable discussions with Ohio EPA, the most "industry friendly" regulations in the United States were adopted in Ohio. Although other states have improved their regulations, Ohio continues to lead in new projects and OCMA is pressing for new rules to govern beneficial reuse that will provide more opportunities to the industry. Perhaps most importantly in 2001, OCMA working with GM-Powertrain-Defiance, the FIRST Project, Inc. and Ohio Congresswoman Marcy Kaptur (Toledo-D) secured major federal funding for the study of utilizing spent, non-toxic foundry sand for agricultural and horticultural applications. As outlined below, that victory in 2001 is just about to open tremendous opportunities for metal casters throughout the Nation. In 2007, OCMA continued working with GM-Powertrain in Defiance, FIRST, Inc., and Ohio Congresswoman Marcy Kaptur to maintain funding for the USDA Agricultural Research Service (ARS) research program to determine the viability of using foundry sand as a soil amendment for agricultural and horticultural uses. The opening of these potential markets for Ohio foundries could present numerous opportunities for the beneficial reuse of spent, non-toxic foundry sand and eliminate foundry sand disposal, as we know it today. At the AFS EHS conference in October 2007, Dr. Rufus Chaney, world-renowned expert on beneficial uses of industrial by-products declared most iron and aluminum foundry sands “cleaner than soil”. On Tuesday, April 1, 2008, at the Beneficial Use of Industrial Materials Summit in Denver, Colorado, Rob Dungan, Project Manager, Agricultural Research Service (ARS) and Rufus Chaney, reported on their foundry sand research. They stated that there is overwhelming evidence that the metal constituents found in spent foundry sands are not only present at levels protective of human health and the environment, but they are present at levels that are very similar to those found in native soils. This is one of the greatest accomplishments of OCMA history! The USEPA is working on a follow-up document that will provide recommendations for use of spent foundry sand in agricultural and horticultural applications. OCMA Warns Member Foundries about OSHA Special Emphasis Program (SEP)
and Prepares Them for Inspections OCMA and its members are national leaders in working with OSHA on the revised silica exposure standards. OCMA led the battle against OSHA efforts to promulgate a more restrictive crystalline silica standard during the Clinton Administration. OCMA attended the stakeholder meetings, spearheaded a fly-in to OSHA headquarters for the stakeholder meeting at DOL, and recruited leaders from Congress to warn OSHA about the potential devastating impact the proposed regulation would have on small, medium and large foundries and their suppliers. OSHA was considering lowering the Personal Exposure Limit (PEL) to one-half of its present level. A standard this low would have imposed monumental compliance costs on all foundries. OSHA decided to forego this punitive standard and foundries in Ohio and throughout the industry benefited from OCMA's leadership. MACT - Mitigating the Impact of Poor Legislative Language On December 23, 2002, USEPA printed in the Federal Register the proposed Iron & Steel Foundry MACT. The proposed standards contained emission standards for pouring, cooling, and shakeout for new sources so restrictive that it would not have been possible to build a new foundry in the U.S. and remain competitive in the global market. The proposal called for the virtual elimination of wet scrubbers and placed severely restrictive emission standards on cupola operations. A new scrap inspection program with onerous record keeping requirements was also proposed. On February 21, 2003, OCMA submitted more than forty (40) pages of comments to the USEPA on the proposed Iron & Steel Foundry MACT standard. The OCMA comments along with those from AFS and its member companies had a significant impact upon the process. OCMA was speaking on behalf of all foundries in Ohio not just the large major source foundries such as those operated by the auto industry. The melding of the medium, large, and very large foundries provided information to the USEPA that demonstrated the onerous monetary impact several of its proposals would have on the industry. The final USEPA proposal for MACT, while not very “user friendly”, was much improved from the original proposal. This can be attributed to the comments provided by companies throughout the industry including those from OCMA. A large part of the problem with fighting these regulations was attributed to the fact that the Clean Air Act of 1990 did not allow the determination of whether the proposed regulations were economically feasible, only whether human health was protected. OCMA presented three MACT Workshops in 2003-2004 to assist foundries in Ohio affected by the MACT proposal. OCMA presented its third and last MACT Workshop in September 2004 to outline compliance strategies for those companies that could not escape MACT regulations and to present a “model” scrap inspection program. OCMA created the Scrap Inspection Program Subcommittee to discuss and develop a “model” scrap inspection procedure that would pass USEPA muster. Working with several auto industry representatives as well as other foundries, the OCMA Subcommittee developed a scrap inspection program that met the general needs of all affected companies. The proposed program can easily be amended to match the individual needs of individual companies. Fighting USEPA on Iron & Steel Foundry GACT On September 17, 2007 USEPA published a proposed standard for Hazardous Air Pollutants (HAPs) for Iron and Steel Foundries Area Sources. The proposed rule will affect all iron & steel foundries not covered by MACT. The new rule, GACT, for Generally Available Control Technology, requires USEPA to achieve a substantial reduction in emissions of hazardous air pollutants or HAPs from area sources. OCMA has participated in the AFS Working Group with OCMA Vice President for Environmental Affairs Ryan Burke, OSCO Industries, Inc., Craig Schmeisser, RMT, Inc., Kim Myers, Griffin Wheel Company, and OCMA Executive Director Russ Murray, along with several other members of the Environmental Affairs Committee. We began our efforts by insisting that small foundries be represented on the AFS Working Group even though those foundries may not be able to attend meetings in Des Plaines. We also argued that USEPA should not be able to impose these urban area rules to non-urban facilities. However those efforts were unsuccessful. That battle should have been fought in the late 1990’s when USEPA made it clear that they did indeed intend to extend these rules to non-urban areas. Our recent battle was to fight USEPA’s intent to impose MACT-like regulations on medium-sized foundries. USEPA, had in some cases, called for regulations that would be even more stringent than those under MACT. For example, USEPA proposed a restrictive emission limit for foundries utilizing Electric Induction Furnaces (EIFs) that would compel larger foundries to have or install a baghouse, a major capital investment. We personally contacted those foundries in Ohio that would be impacted by this proposal and urged them to comment on the proposed rule. Several of them did. Also, the AFS Working Group and OCMA submitted comments to oppose these restrictions. Despite these efforts we were unable to remove these restrictive proposals. However, on a positive note, the Working Group was successful in convincing USEPA to significantly reduce the impact on small foundries (less than 20,000 tons per year actual production). As a result, only a handful of Ohio foundries will be forced to comply with the more restrictive emission limits. VOC Exemption: A Major Breakthrough From 1995 to 1999, OCMA was involved in a significant regulatory action
pertaining to volatile organic compounds or VOCs. OCMA was able to negotiate
an exemption for foundries from volatile organic compound (VOC) control
requirements, the 8 and 40 rule, when using cold cure core resin (OAC
3745-21-07 G (9)(h). In 1995 the Ohio EPA required Ford to install an
incinerator to control emissions from the TMEP acid scrubber at CCP (estimated
$3 mil investment). A complete exemption of the rule for Ohio
foundries was issued by the Ohio EPA and accepted by the USEPA based
on research
conducted by OCMA members and OCMA negotiations with the agency. This
has saved the auto industry significant resources that would have been
required to conduct case-by-case impact studies to eliminate the requirement
for additional controls and has eliminated future risk altogether. |
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