Beneficial Reuse of Spent, Non-Toxic Foundry Sand

In May 2003, Ohio EPA DSW Policy 400.007 was revoked. OCMA was a key member of the working group formed by the Ohio EPA to create Policy 400.007 in 1994. The policy had been the regulatory document governing the beneficial reuse of exempt solid wastes including spent foundry sand since November 1994. Under the old policy, OCMA members were able to make significant progress towards moving away from disposing spent foundry sand to beneficially reusing foundry sand. Although the Ohio EPA has continued to follow the spirit of old Policy 400.007, it has failed to complete a rule-making process that was begun soon after the revocation of the policy.

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. The study was completed in 2008, and the authors of the study, Rob Dungan and Rufus Chaney, ARS, reported that their was overwhelming evidence that the constituents found in spent foundry sand do not pose a danger to the environment, but rather, are often cleaner than native soils.

The completion of the USDA ARS research has documented that spent foundry sand does not warrant environmental concern, but instead it provides an opportunity to reuse spent foundry sand in numerous applications including agricultural and horticultural uses.

Unfortunately, the USEPA has not moved beyond peer-reviewing the study which was completed in 2009. Although the peer-review process did not result in any objections to the study’s conclusions, the USEPA has failed to issue the study or provide recommendations to the states. OCMA, working with the American Foundry Society (AFS) Washington Office has engaged in conversations with Rep. Marcy Kaptur and other representatives in Congress asking them to encourage the USEPA to finally complete the study and provide these recommendations to the states. In October 2011, Congresswoman Kaptur sent a letter to the USEPA asking them to expedite the completion of this study. The letter was signed by several representatives from the states of Ohio, Pennsylvania, and Indiana.

The effort to expand the opportunities for the beneficial reuse of spent foundry sand has been a long and frustrating one. However, OCMA will not rest until environmental regulations are written to permit these sands to be used beneficially.

Other Key Issues

Electricity Regulation
OCMA supported the legislative efforts to deregulate electricity generation in Ohio. As a member of the Coalition for Choice in Electricity, OCMA provided grass-root support for the deregulation effort. Unfortunately, a competitive market for electricity was never established in Ohio and in 2008, the Ohio General Assembly enacted Senate Bill 221 to prevent market pricing of electricity beginning January 1, 2009. Major users of electricity feared that market pricing would have led to significant "rate shock" that would have endangered jobs and economic development in Ohio. To prevent that from occurring, the new law provides unprecedented power to the Ohio Public Utilities Commission to set electricity rates. However, despite the best efforts of the Ohio General Assembly, electricity rates have increased dramatically in several service territories across the state. OCMA members in First Energy territory have been subjected to increases as high as 30%! OCMA Treasurer John Burke and Executive Director Russ Murray attended a public forum to protest AEP's request for three consecutive increases of 15% across-the board, a cumulative increase of more than 50%!
Moreover, the new legislation also includes two provisions that are likely to cause electricity rates for Ohio metal casters to increase despite efforts to keep them within reason. First of all, the new legislation requires that by the year 2025, twenty-five per cent (25%) of electricity sold in Ohio must be generated from renewable and advanced energy sources. Given the fact that renewable energy generation is significantly more expensive than fossil fuel or nuclear energy generation, it can be anticipated that this mandate will cause electricity rates to rise significantly during the next fifteen years.
Additionally, the legislation also called for significant efficiency savings by electricity consumers. In fact, by the end of 2025, Ohio's utilities are required to have increased electricity efficiencies by 22%. Any costs associated with the efforts of the investor-owned utilities to achieve these mandates will be completely passed on to electricity consumers primarily industrial and commercial customers. Creating even more problems with the new legislation, the Ohio PUCO has a very unusual understanding of what activities of industry qualify for energy efficiency improvements which has made this effort even more difficult. The bottom line is that the unprecedented power given to the Ohio PUCO is unlikely keep electricity rates low, but rather, electricity rates for industrial customers are likely to increase significantly in the coming years. OCMA will be working with the Ohio Manufacturers Association to address these concerns.

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