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OCMA and Casting Industry
State Industry Issues |
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OCMA and Casting Industry
State Industry Issues |
VOC Emissions from Resin Sands
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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In May 2003, Ohio EPA DSW Policy 400.007 was revoked.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, non-toxic foundry sand since November 1994. The revocation provides both a challenge and an opportunity to OCMA. The challenge is posed by the fact that the Ohio EPA will now create a rule that will regulate the beneficial reuse of both exempt and non-exempt solid waste. OCMA and others will need to insure that there is no backsliding not only, in opportunities for beneficial reuse for exempt wastes, but also, in testing and monitoring requirements in the new rule. The opportunity lies in the possibility of expanding beneficial reuses to include agricultural and horticultural applications.
OCMA has established a Beneficial Reuse Subcommittee and representatives from
the committee will be meeting with Ohio EPA officials in late summer to begin
the rule making process.
In a major victory, OCMA, working with member foundry, GM-Powertrain-Defiance, and the FIRST Project has helped to secure significant federal funding for the study of spent, non-toxic foundry sand for agricultural and horticultural applications. Ohio Congresswoman Marcy Kaptur, (Toledo-D) and her Chief of Staff, Roger Szemraj were instrumental in obtaining a $480,000 appropriation for the "Agricultural Research Service (ARS) and university/industry partners to evaluate the beneficial uses of foundry sand in agriculture and horticulture".
The effort to secure federal funding of this research has been on going for several years. The strategy driving the effort was an understanding that millions of tons of municipal sewage sludge or "biosolids" are used as soil amendments each year because intensive, peer-reviewed research was performed years ago to determine its environmental impact. Although foundry sand is much cleaner than biosolids, most state environmental agencies are loath to allow land application of spent, non-toxic foundry sand. In those cases where land application is allowed, the testing and record keeping requirements often make the reuse cost prohibitive. Our theory was, if the ARS could be persuaded to replicate this research for foundry sand, it would surely follow that spent, non-toxic foundry sand would be found to be environmentally safe. Armed with that research, foundry state associations should then be able to submit this information to their state environmental agency to demonstrate that opportunities for land application of spent, non-toxic foundry sand could be safely pursued. The only obstacle blocking this common sense approach was obtaining nearly one-half of one million dollars from Congress for the study!
Assisting OCMA efforts to obtain the research funds, was the fact that Congresswoman Marcy Kaptur is the Ranking Minority Member of the House Agriculture Appropriation Committee. As Ranking Minority Member of the committee, her recommendations receive close scrutiny and generally, support from other members of the committee including the Chairman. Coincidentally, although the GM-Powertrain-Defiance facility, the largest in the world, is not located in Rep. Kaptur's district, hundreds, if not thousands, of her constituents work at the foundry. Over time, top management at GM-Powertrain-Defiance had developed a good working relationship with Congresswoman Kaptur. That relationship came in very handy during this successful endeavor.
Writing a New EPA Policy 400.007
OCMA was a key member of the working group formed by Ohio EPA to revise Policy 4.07. OCMA worked closely with the Ohio EPA Division of Surface Water (DSW) to create a new policy that would facilitate greater opportunities for beneficial use of spent, non-toxic foundry sand.
In February 1994, OCMA provided a position paper outlining recommended revisions of Policy 4.07. The position paper was developed by the OCMA Environmental Affairs Committee with broad participation of the OCMA membership.
In November 1994, Ohio EPA issued new DSW Policy 0400.007 that includes many of the OCMA recommendations including revised, more achievable parameters for phenol, cyanide, and fluoride, self-implementing procedures, and greatly expanded opportunities for beneficial reuse of spent, non-toxic foundry sand.
Sustainable Industries Partnership Program
OCMA Executive Director Russ Murray was invited to join in an USEPA Work Group associated with the Sustainable Industries Partnership Program that met in Washington DC in May 2001. He encouraged the Working Group members to concentrate their efforts on allowing spent, non-toxic foundry sand to be used for soil amendment and agricultural uses. The recommendation has been incorporated into the Sustainable Industry Project focusing upon outlining potential uses of spent, non-toxic foundry sand. The Foundry Industry Recycling Starts Today (FIRST) Project is coordinating the metal casting industry's input.
Military Construction Projects
Finally, working with the AFS Washington office, FIRST Project, and C. Frank DeMeo, General Casting Company, we encouraged Congressman David Hobson to promote the use of foundry sand for military construction projects. Rep. Hobson, Chairman of the Appropriations Military Construction Committee, was able to secure language in the Military Construction Appropriations Bill that encouraged the Corps of Engineers to develop pilot military construction projects utilizing spent, non-toxic foundry sand.
During the Spring and Summer of 2000, Ohio EPA, Division of Air Pollution Control (DAPC) sent questionnaires to Ohio foundries requesting information about the types of charge materials being used. The data gathering effort was initiated by DAPC following the discovery of excessive mercury air emissions at Marion Steel, a mini-mill melting No. 2 frag or shredded scrap.
In December 2000, Buckeye Steel Castings Company in Columbus and GM-Powertrain Group in Defiance, received certified letters from Ohio EPA Director Chris Jones. The letters set forth a requirement for both companies to perform stack tests to determine potential mercury emissions.
The "request to test" letters posed significant potential costs for the two foundries. Buckeye Steel Castings Company was quoted approximately $10,000 for the testing and GM-Powertrain Group, which had been asked to test all of their cupolas, was looking at upwards of $40-50,000 for the testing.
OCMA Executive Director Russ Murray immediately contacted Paul Koval, DAPC, to request a meeting with Ohio EPA officials. A meeting was held on Friday, January 12, 2001. At that meeting OCMA Vice President for Environmental Affairs Kurt Braun, Ford Motor Company, Pete Maciejewski, GM Worldwide Facilities, Tim Hickey and Andy Huston, Buckeye Steel Castings Company, Craig Schmeisser, RMT, Inc., and Russ Murray, OCMA were briefed about the excessive mercury emissions at Marion Steel Company. Concerned about a potential threat to public health, Ohio EPA Director Chris Jones had also ordered additional testing at five (5) mini-mills.
OCMA and company representatives spent much of the meeting explaining to Ohio EPA representatives the differences between foundries and mini-mills. They also suggested that mercury emission testing data for foundries may be available in the public domain, and asked for the opportunity to present it to Ohio EPA. The significant costs of the testing were presented as a major concern. There was also considerable discussion about how to control or minimize the amount of potential mercury in the scrap. There was some agreement that removing the mercury before it was shredded and sent to the foundries for melting would be a far less expensive method than attempting to control mercury emissions from cupolas, arc, or induction furnaces.
As a result of the meeting, Ohio EPA granted OCMA and the companies until March 2001, to present data on emission tests at foundries, to provide information about potential controls at scrap dealers, and any other relevant information that would exempt Ohio foundries from additional testing. The testing at Buckeye Steel Castings Company and GM-Powertrain was put on a temporary hold pending the outcome of the presentation.
At the OCMA Environmental Affairs Committee meeting on Tuesday, February 6, 2001, a Mercury Task Force was formed with the following members: Bob Anderson, Envisage Environmental, Inc., Kurt Braun, Ford Motor Company, Harry Gulley, OSCO Industries, Inc., Tim Hickey, Buckeye Steel Castings Company, Pete Maciejewski, GM Worldwide Facilities, Craig Schmeisser, RMT, Inc., and Jim Stouch, Malcolm Pirnie, Inc.
On March 8, 2001, a follow-up meeting with Ohio EPA representatives was held. OCMA presented mercury emission testing results, charts showing that the average mini-mill was anywhere from five to ten times larger than the average large foundry in Ohio, and the charge or melt in the typical foundry contained somewhere between 30-60% of internal returns that are mercury-free. This contrasts with the typical mini-mill that melts 100% external scrap. GM-Powertrain was also able to demonstrate that its foundry does not melt scrap that contains mercury switches and therefore potential mercury emissions would be minimal.
A final decision on stack testing of Ohio foundries for potential mercury emissions has not been made by Ohio EPA. Additional information is being provided and the OCMA Mercury Task Force will continue to work with the Ohio EPA in an effort to minimize testing of Ohio foundries.
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. The legislation became effective on January 1, 2001 and the transition to competitively priced electricity has begun. This is a victory for all manufacturing, but especially for metal casting that is so dependent upon electricity.
At its June 2000 meeting, the OCMA Board of Trustees stepped boldly into the electricity deregulation fray, authorizing the Electricity Dereg Subcommittee to enter into an agreement with Alliant Energy Industrial Services Inc. to provide electric energy aggregation services to OCMA members. (Alliant Energy Industrial Services, Inc. and RMT, Inc. are divisions of Alliant Energy Inc.) The goal of the aggregation service was to provide members with electric energy cost savings by entering into an agreement with a large electricity supplier to provide electricity at lower, high volume prices. Participating members were to enter into individual contracts with the participating supplier; however, the price of the electricity would be set by a negotiated agreement between OCMA and the supplier. These steps followed the pattern set by the Pennsylvania Foundrymen's Association (PFA) where significant electricity cost reductions were attained.
Regrettably, an analysis by Alliant of the Public Utility Commission of Ohio (PUCO) settlement agreements with the investment owned utilities concluded that there are only limited opportunities for aggregation at this time in Ohio. Unfortunately, in the areas of the state where energy prices are the highest, the opportunities for aggregation are not viable. Simply put, the "shopping credits" or "price to beat" accepted by the PUCO in the services areas of First Energy and AEP Ohio Power are lower than the current wholesale market price of electricity. According to the Alliant analysis, it is unlikely that suppliers will enter the Ohio market in these areas because they will be unable to beat the shopping credit price.
It is only in the service areas of Cinergy, DPL, and AEP (Columbus Southern) that the Alliant analysis suggests that further investigation of an aggregation project make sense. OCMA has a significant number of members and non-members in these areas. OCMA sponsored a series of meetings in November to discuss this project with member and non-member companies. There was a significant interest in the aggregation project with more than 100 MW of electricity demand available to the pool. However, the wholesale price of electricity has not fallen to normal levels during this winter and virtually no suppliers have entered the market to provide electricity at costs lower than the shopping credits. OCMA will continue to monitor the electricity markets with the assistance of Alliant Energy. We are hopeful that there will be a window of opportunity in the latter part of this year.
In those areas with low shopping credits, all is not lost. Under the legislation that brought about electric deregulation, a market development period is set forth which requires at least a 20% switching of customers to alternative suppliers by the end of five years. If the PUCO reviews the state of competition in Ohio in a year or two and does not believe that the 20% target will be met, they have the authority and responsibility to increase the incentives for switching by increasing the shopping credits or by other means.
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OCMA supported the legislative reforms outlined by the Voinovich Administration to improve the operation of the Ohio Bureau of Workers' Compensation. OCMA was an active supporter of Issue 2, raising funds for the "vote yes" campaign and the Keep Ohio Working Coalition. Despite significant reforms in the program, workers' comp costs to Ohio metal casters are much higher than those of our competitors in many states. Much work remains to be done.
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© Copyright 2000 |
Ohio EPA Director Chris Jones 
Mike Frantz, Frantz Ward LLP