SPRING OCMA NEWS

OCMA & AFS CONTINUE THEIR FULL COURT PRESS RE: THE IRON & STEEL FOUNDRY MACT PROPOSAL AT THE AFS GAC

As outlined in the Fall & Winter OCMA News, the USEPA proposed Iron & Steel Foundry MACT has triggered both anger and disbelief in our industry. The USEPA MACT proposal would impose significant economic burdens upon existing foundries and could, if adopted, make it prohibitively expensive to expand or site a new foundry in the United States.

As reported in the Winter OCMA News, OCMA led by its Vice President for Environmental Affairs Kurt Braun, Ford Motor Company, Cleveland Casting Operations, and assisted by Jeet Radia, Keramida Environmental Inc. Craig Schmeisser, RMT, Inc. and OCMA Executive Director Russ Murray presented more than forty (40) pages of comments to the USEPA prior to the February 21, 2003 deadline.

The AFS Government Affairs Conference in Washington, DC, March 30-April 1, presented the next opportunity for OCMA members to educate USEPA and other government officials about the potential devastating impact of the proposed Iron & Steel Foundries MACT standard. OCMA again led the way with nineteen (19) foundry and supplier participants at the conference where attendance barely exceeded one hundred (100).

One of the highlights from the second day of the conference was the appearance of Jeff Holmstead, Assistant Administrator for Air & Radiation, USEPA. Mr. Holmstead reports directly to Administrator Christine Whitman. He began his presentation with the welcome announcement that based upon the comments received from industry, USEPA had reconsidered its position concerning having the Office of Management & Budget (OMB) review the proposed standard. Initially, USEPA had determined that the proposed standard’s economic impact was less than the threshold for such a review and therefore had denied our industry the opportunity to have the proposed standard reviewed by OMB. This is a major victory for the metal casting industry and OCMA. OCMA had made the review by OMB one of its significant goals in the comments presented to USEPA.

During the question and answer period, OCMA Executive Director Russ Murray, commented that USEPA estimates that 900 tons of Hazardous Air Pollutants (HAPs) will be removed from the atmosphere once compliance is achieved. However, the metal casting industry estimates that the capital costs for the required air pollution control devices will exceed $600 million. This represents a cost of nearly $650,000 per ton of HAP removed. Similarly, industry estimates the cost of replacing the present wet scrubber collection systems throughout industry with bag houses to meet the proposed standard would cost approximately $400 million to remove an USEPA estimated 120 tons of HAPs, a cost of more than $3 million per ton. Director Murray suggested that USEPA would need to “get creative” in order to solve the wet scrubber problem because of previous court rulings and interpretations of the Clean Air Act.

Mark Dine, St. Marys Foundry, alerted Mr. Holmstead about the problems his small business could face because of the proposed MACT standard. Ray Ostrowski, Griffen Wheel, introduced him to the fact that steel foundries were included in the Iron & Steel Foundries MACT at the last minute even though their production and HAP emissions are miniscule compared to steel mini-mills that were excluded from coverage of MACT standards. Mr. Holmstead took notes and promised that USEPA would work with the metal casting industry to address its concerns.

Monday afternoon presented a first-time event, a White House Briefing at the Executive Office Building. More than 100 AFS GAC participants took a brisk walk to the Executive Office Building to meet with high-level Administration officials from the OMB, USEPA, and Commerce Department. Paul Noe, Counselor to the Administrator, OMB, reaffirmed Jeff Holmstead’s statement that the OMB will now be reviewing the final Iron & Steel Foundries MACT standard. He indicated that OMB’s task was to limit the economic impact of USEPA regulations without infringing upon the goal of environmental improvement. OCMA Director Russ Murray informed Mr. Noe that the potential harm to the U.S. iron and steel foundry industry posed by the MACT standard proposal is not limited to the significant compliance costs. He explained that the proposed MACT has the potential to radically alter the manner in which the industry survives the cycles of the U.S. economy. The proposal would bring about a significant reduction in U.S. production capacity and a substantial increase in U.S. dependence upon imported castings.

Marianne Horinko, Assistant Administrator for Solid Waste and Emergency Response, USEPA, delivered some good news to the metal casters and suppliers in the briefing. She announced that the USEPA is expanding its efforts in support of recycling and specifically the beneficial reuse of industrial by-products. She indicated she has been working with Amy Blankenbiller, Waterman Associates, AFS Washington Office, to remove barriers to the beneficial reuse of spent, non-toxic foundry sand and to increase potential uses.

The most important task of the OCMA delegation was reserved for Tuesday, April 1, 2003, and it was no joking matter. Beginning with an early morning meeting with Elizabeth Belleville from Senator Mike DeWine’s staff and ending with a 4:00 PM meeting with staff from Rep. Paul Gillmor’s (R-Tiffin/Defiance) office, the OCMA delegation had a long day. Fifteen offices were visited on Tuesday and the message was Iron & Steel Foundries MACT and unfair trade practices of China. The meetings were very productive. Senator DeWine’s office promised to write a letter to USEPA about the proposed MACT standard. Brian Mormino, Senator Voinovich’s staff indicated that the Senator’s position as Chairman of the Senate Subcommittee on Clean Air, Climate Change & Nuclear Safety would allow him to be very helpful to our industry if discussions with USEPA were not fruitful. Rep. Pat Tiberi promised to write a letter to Administrator Whitman expressing his concern about the proposed MACT standard.

OCMA President Lynn Bierly, Mansfield Castings, presents an honorary OCMA Iron Pourer Award to Rep. Nancy Kaptur, (D-Toledo) for her assistance securing research funds for beneficial reuse of foundry sand. Assisting in the presentation are Kai Spande and Tim Hall, GM-Powertrain, Defiance.

But perhaps the most productive meeting was held with Rep. Marcy Kaptur, (D-Toledo) and her Chief of Staff Roger Szemraj who had been instrumental in securing funding for the USDA to perform research on the potential beneficial reuse of spent sand for agricultural and horticultural applications. We were accompanied by Elizabeth Olenbush, FIRST, and carried a Kent State University AFS student chapter Iron Pourer Award to present to Rep. Kaptur. We met at the Capitol in the historical Rayburn Room with a portrait of President George Washington looking over our shoulders.

Tim Hall and Kai Spande, GM-Powertrain - Defiance, OCMA President Lynn Bierly, and OCMA Executive Director Russ Murray reviewed the MACT standard issue with Rep. Kaptur. Under the circumstances, we did not anticipate a deep interest on her part. Boy, were we mistaken! She continued to ask questions and Tim and Kai tutored her well on the wet scrubber issue and its impact upon the GM and Ford foundries in Ohio. She seemed very concerned about the ultimate impact upon not only the metal casting industry, but also manufacturing in general. Of course, we told her that Ohio was the largest foundry state and that castings were present in 90% of all manufactured products.

The next day, Wednesday, April 2, 2003, USEPA Administrator Christina Whitman was before the Appropriations Committee explaining the USEPA budget request for FY 2003-2004. During questioning by members of the committee, Rep. Marcy Kaptur asked the Administrator about the proposed Iron & Steel Foundries MACT standard and presented her concerns about the possible impact on Ohio. She stated that Ohio was the largest foundry state and that the two largest foundries in Ohio, GM and Ford, could be forced to invest more than $50 million each to totally replace the wet scrubber air pollution control systems at their foundries. Rep. Kaptur stated that metal casting was critical to basic manufacturing and something should be done to fix the proposed rule.

Fortunately for Administrator Whitman, Jeff Holmstead, Assistant Administrator for Air & Radiation, who spoke Monday morning at the AFS GAC was accompanying Ms. Whitman. He replied to Rep. Kaptur that the Agency was aware of the problems the industry had brought to their attention through comprehensive comments, that USEPA was talking with industry, and they believed that the problems could be worked out to everyone's satisfaction. Rep. Kaptur indicated that she would be monitoring the situation and that she was very concerned about the possible detrimental impact.

This is a powerful reminder of how important it is for our industry to inform our leaders about the issues affecting our ability to compete in the global economy and about the importance of the metal casting industry to all U.S. manufacturing. The AFS GAC presents this opportunity annually and OCMA has nearly always had the largest delegation to the conference. We must not only, continue this legacy but also, increase the number of Ohio participants next year.

Serious Business - OCMA members prepare for their visits to Capitol Hill.

The AFS GAC presented an excellent opportunity for OCMA members to educate and influence our Congressional delegation and their staff about the importance of the metal casting industry to Ohio and the potential devastating impact the proposed Iron & Steel Foundries MACT standard could have in Ohio. OCMA took full advantage of this opportunity and it bodes well for the final outcome.

MEETING UPDATE

On Thursday, April 10, 2003, approximately 60 representatives of OCMA member companies participated in a tour of the GM-Powertrain foundry in Defiance. Although the highlight of the tour was the new aluminum lost foam foundry, the production of thousands of crankshafts a day was pretty impressive as well. However, the difference between the two processes is compelling. Going through the door from the aluminum foundry to the iron foundry or vice versa provided a monumental change in sights and sounds, two completely different work environments.

GM Powertrain Foundry Tour Host Walt Chaput welcomes OCMA members during the luncheon at Kettenring Country Club.	GM Powertrain - Defiance Personnel Director Pete Felton listens intently to a question from the audience

The lost foam aluminum foundry will be casting the blocks and heads for the new GM Vortec 3500/2800 Inline 5/4 engine. Once in production, the foundry will produce more than 2000 blocks per day and approximately 1400 heads. The lost foam process includes the conversion of raw styrofoam beads to form patterns/slices that are then put together with other slices to form a complete foam cluster. The complete foam cluster is then coated, dried, loaded on the casting line in a flask filled with sand, and melted by the high grade molten aluminum to create the block and/or head. It is quite a sight to see.

OCMA Vice President Walt Chaput hosted the tour assisted by Tim Hall, Plant Engineering Manager, Kai Spande, Lost Foam Manager, and Karen Hackworth, Administrative Assistant to Plant Manager Mike Chapman. The luncheon was held at the Kettenring Country Club and Personnel Director Pete Felton shared with the OCMA audience a presentation that was delivered to all of GM’s employees concerning the challenges to remaining competitive in today’s auto markets. Our thanks to GM Powertrain for a great tour.

Posing after learning about the lost foam slices forming a cluster are Nick Cannell, EMTEC, Ted Settlage, Ross Aluminum Foundries, Dave Montambeau, Ford Motor Company, Cleveland Casting Plant, unidentified GM-Powertrain guide, Craig Schmeisser, RMT, Inc., and Mark Spagnuolo, Ford Motor Company (CCP).	Ed Myers, Morris Bean & Company, Bud Tibbits, Hill & Griffith Co., and Carl Weiffenbach, Keener Sand & Clay Co. check out a lost foam cluster while Steve Chan and Kurt Braun, Ford Motor Company observe.

OCMA President and Executive Director Attend FIRST Briefing with Federal Agencies

OCMA President Lynn Bierly, Mansfield Castings, and Executive Director Russ Murray postponed their return to Ohio after the AFS GAC to attend a briefing with key federal agencies involved with the potential recycling of spent, non-toxic foundry sand. The briefing was sponsored by FIRST and hosted by the USEPA.

The outcome of the briefing provided both good news and bad news for the foundry industry in Ohio. The good news is that the USDA ARS research project to determine the viability of using spent, non-toxic foundry sand for agricultural and horticultural applications is moving forward and additional funding has been provided by Congress. Additionally, for the first time ever, the Federal Highway Administration, (FHWA) has expressed a strong interest in advocating the use of spent, non-toxic foundry sand for highway construction. On the other hand, the presentations from the USEPA and Department of Energy (DOE) suggested that their activities supporting the recycling of spent, non-toxic foundry sand were diminishing.

OCMA President Lynn Bierly, Mansfield Castings, and OCMA Executive Director Russ Murray take notes during the FIRST Foundry Sand Federal Agency Briefing.

FIRST Executive Director Elizabeth Olenbush discusses the ARS foundry research project with Dr. Larry Sikora, ARS.

Dr. Ron Korcak, Associate Area Director of the Beltsville Agricultural Research Center, Dr. Robert Dungan, newly hired soil scientist who will lead the project, and Dr. Larry Sikora outlined a research plan extending over a three year time period. Foundry representatives suggested that a more expedited schedule including field studies without compromising the integrity of the research was needed. Dr. Dungan signaled his willingness to look for areas where the research time line could be speeded up without overlooking needed steps in the research plan.

Mr. Tommy Beatty, Director of FHWA’s Division of Pavement Technology provided a presentation entitled, “FHWA’s Interest in Foundry Sands as a Recycle Material.” Mr. Beatty affirmed that it is a stated policy of FHWA to promote the use of recycled materials, and that the agency has a Recycled Material Team in place to do so. The agency recognizes that materials such as foundry sand represent an opportunity for FHWA, state highway agencies, and industry to work together to provide win-win solutions.

Mr. Beatty then reviewed some of the research that FHWA has undertaken to evaluate prospective use of foundry sands in highway construction. He presented charts showing drainage requirements in pavements and described how the combination of binder material and gradation gives foundry sand the necessary strength and permeability for highway construction. One important consideration for FHWA is that foundry sand can be placed using current highway construction methods. Mr. Beatty then showed photographs of several construction projects that FHWA staff have evaluated.

FHWA has concluded that “foundry sands are a viable material for highway construction.” Referring to recent discussions with Ms. Olenbush and other FIRST representatives, Mr. Beatty suggested that foundry sand promotion should be regional in nature, as the material’s availability is limited by the availability of large volume foundry sites and hauling distances to projects from foundries.

After concluding his prepared remarks, Mr. Beatty went on to state that FHWA had reviewed the draft “Foundry Sand Facts for Civil Engineers” prepared by FIRST contractor Ted Ferragut. Mr. Beatty announced that FHWA would not only endorse the fact book, but would help to print and distribute it. He stated he and his staff are working out a targeted distribution plan in specific regions and states where foundry sand is widely available. Additionally, Mr. Beatty announced that FHWA would work with FIRST to develop and distribute a series of fact sheets that provide additional technical detail about how to work with foundry sand as a highway construction material.

Jerry Newsome, USEPA Office of Policy, Economics and Innovation, introduced the USEPA report, “Beneficial Reuse of Foundry Sand: A Review of State Practices and Regulations”. This report is the result of a more than two year effort; one in which FIRST and OCMA were deeply involved in the initial stages of the beneficial reuse task force. The report is not likely to assist foundries in Ohio because Ohio has one of the best beneficial reuse programs in the country. Mr. Newsome also outlined a new focus of EPA’s Sector Strategy Division that seemed to suggest that his division’s efforts to promote the beneficial reuse of spent, non-toxic foundry sand were ending.

However, David Hockey, Director of the USEPA’s new Resource Conservation Challenge (RCC), indicated in his presentation a potential opportunity for additional assistance from USEPA under this new recycling initiative. Mr. Hockey described the RCC as an effort to refocus USEPA’s efforts more fully on resource conservation, pollution prevention and recycling. Eight cluster groups have been identified as the initial stakeholder groups upon which the RCC will focus. “Industrial Waste” or byproducts is one of the targeted groups. Mr. Hockey closed his remarks by inviting FIRST to participate in the Key Stakeholder Meeting scheduled in June.

Harvey Wong, the metal casting team leader for U.S. Department of Energy’s (DOE) Industries of the Future (IOF) program, attempted to convey a continued effort within DOE to promote beneficial reuse of spent, non-toxic foundry sand but realistically, DOE is taking a very different path. The overall budget request for the IOF program was slashed by 50% and the metal casting program budget by more than 60%. DOE is focusing its efforts to decrease energy use in metal casting by supporting more research to develop improved melting processes.

ENVIRONMENTAL UPDATE

Iron and Steel MACT Standards (See first page story)

The first indication of whether the comments and meetings with Congressional leadership had any affect on the formulation of the final MACT proposal was provided at a meeting on Tuesday, April 22, 2003, with USEPA staff, members of the Auto Alliance (Chryslers, Ford, and GM), and Gary Mosher representing the AFS Ad Hoc MACT Committee. In Gary’s report he stated “ it is clear that our message has been heard up and down the chain of command at EPA. This is a result of written comments as well as the advocacy of the foundry industry with both elected officials as well as Agency personnel during the recent AFS Government Affairs Conference.”

OCMA Vice President of Environmental Affairs Kurt Braun who attended the meeting via phone indicated that the USEPA gave the clear impression it was trying to correct many of the problems in the proposed MACT, but that there were clearly limits to what the Agency was prepared to offer. The Agency intends to meet the August deadline for a final version. To reach this goal, the Agency’s final proposal must be completed by June and provided to OMB for their review. This leaves very little time for making the needed progress.

HR UPDATE

OCMA Members Present Outstanding Workshop at BWC Safety Congress

On April 2, 2003, OCMA members, Jeff Dine, Dine Compliance Inc., Renee Harmeyer, Kenton Iron Products, Inc. and Rhonda Puckett, G & C Foundry Company, Inc. presented a series of ergonomic success stories on a panel for the Foundry Section of the BWC Safety Congress. OCMA members Criss LaMoncha, Humtown Products, Paul Rance, Col Pump Company, Inc., Steve Wilson, Flowserve Corporation, and John Lalley, formerly with Globe Metallurgical Inc. coordinated the Foundry Section presentations. The attendance at the sessions was outstanding. For the last session featuring the OCMA panel there was standing room only.

Join Us This Summer

The OCMA annual meeting will be held on Thursday, July 17, 2003. For more information, contact Russ Murray at 614-876-5100.

Beneficial Reuse Policy 400.007 Revoked; New Rules to Be Developed and Promulgated

As previously announced by e-mail (if you have not provided your e-mail address to OCMA, please do so), Ohio EPA DSW Policy 400.007 has been revoked. According to the Ohio EPA, the revocation does not reflect a change in policy, but a recognition that Ohio EPA is prohibited from regulating by policy under recently enacted legislation. This action will now require the development and promulgation of new rules covering the beneficial reuse of exempt wastes including foundry sand. It will also require legislation to provide Ohio EPA with the authority to promulgate the new rules.

OCMA has contacted Ohio EPA to express our intent to play a major role in the development of the new rules affecting the beneficial reuse of spent, non-toxic foundry sand. An OCMA Beneficial Reuse Subcommittee has been formed and additional volunteers are welcome. Please contact Russ at OCMA if you are interested.

Photos courtesy of Jim Dingus and Kai Spande, GM Powertrain - Defiance