Spring 2006 OCMA NEWS - Spring Update

ATTENTION: IF YOUR FOUNDRY IS NOT COVERED BY MACT, IT WILL BE COVERED BY GACT

As OCMA Vice President for Environmental Affairs Dennis Baker, Flowserve Corporation, has reported for the past year, USEPA is in the process of developing an area source rule containing Generally Available Control Technology (GACT) standards for those foundries that are not covered by MACT. The rule will affect any foundry with a potential to emit less than 10 tons/yr for a single Hazardous Air Pollutant (HAP) or less than 25 tons/yr for any combination of HAPs. If your facility is not covered by MACT, it will be covered by GACT. Therefore, it is imperative that you familiarize yourself with the potential regulations that may affect your operations and your bottom line and to communicate your concerns to OCMA. USEPA is using MACT as a starting point for the area source rules and the potential for harmful, excessive regulation is probable. It is important that Ohio metal casters become involved in the development of this rule so that the end result is one that will not create a tremendous burden that will handicap your ability to remain competitive in today’s tough marketplace. The items outlined below are generally current proposals and are subject to change.

THE FOLLOWING EMISSION LIMITS OR WORK PRACTICES (GACT STANDARDS) ARE BEING DISCUSSED AND SHOULD BE OF CONCERN TO EVERY OHIO METAL CASTER POSSIBLY AFFECTED:

Cupola: USEPA has proposed a limit of 0.07 gr/dscf or 0.5 lb of HAPs per ton melted. OCMA member foundries have indicated that this limit would be very difficult to attain.

Electric & Arc Melting Furnaces: USEPA has proposed a limit of 0.01 gr/dscf if a “conveyance” is in place to direct emissions to an air pollution control unit. Conveyance is defined as “a system of equipment that is designed to capture pollutants a the source, convey them through the ductwork, and exhaust them using forced ventilation.” OCMA member foundries have indicated that if this limit were applied without the conveyance language, meaning everyone would be compelled to meet the emission limit, it would create significant cost concerns.

Scrap Management Program: USEPA is proposing that a foundry “will purchase scrap according to specifications that require that scrap is “free” of mercury, lead, and organic liquid contamination.” It is expected that the final rule will have some type of scrap management program similar to that outlined in the MACT standard.

Fugitive Emissions: For those foundries that do not already have an opacity requirement within a federal or state permit, visual inspection of the building would be required to ensure “normal” emissions. “Normal operations” have not been defined at this time.

Operation & Maintenance Plan: Again for those foundries not covered already, they would be required to develop and comply with an O & M plan that contains the following components:

? Facility & contact information
? Purpose
? Training
? List of processes/equipment covered
? Description of monitoring parameters

Pollution Prevention: Foundries with a facility total HAP emission rate lower than 0.325 lbs/ton of metal poured would certify the emission rate and no additional requirements would apply. This is USEPA’s “carrot” to encourage metal casters to experiment with so-called “low emission binders or systems”.

Applicability Determination: Iron facilities melting less than 1,000 tons per year and steel facilities melting less than 500 tons per year would need only to certify production rate and no additional requirements would apply. This is an area where both OCMA and the AFS Area Source Working Group are concentrating their efforts. It is possible that these limits will increase, but they are not likely to increase without feedback from small foundries.

TEA Cold Box Mold or Core Production: If a foundry uses more than 1 ton of TEA per year, emissions must be controlled through a scrubber with pH to be maintained below 4.5 and facility verifying proper pump function and flow rate at a frequency to be determined.

OCMA members have been working closely with the AFS Area Source Working Group to minimize the impact of the new GACT rule. In addition to Dennis Baker, Flowserve Corporation, OCMA Trustee Craig Schmeisser, RMT, Inc., former OCMA VP for Environmental Affairs Kim Myers, Griffin Wheel Company, John & Ryan Burke, OSCO Industries, Inc., Clifford Glowacki, Technikon LLC, Gary Stahle, GM Powertrain, Jim Schifo, Keramida Environmental, Inc., and T.B. Whitte, Columbus Steel Castings. OCMA Executive Director Russ Murray is providing valuable input to the Workgroup from foundries unable to participate in Work Group meetings and/or conference calls. We believe that the development of the area source rule is one of the most important issues affecting our industry this decade. As an industry, we cannot fail to provide necessary feedback to the USEPA.

Please provide your comments to OCMA VP for Environmental Affairs Dennis Baker at (937) 232-6449 (cell) or Russ Murray at (614) 876-5100.

OCMA PLAYS KEY ROLE IN SUCCESSFUL EFFORT TO AMEND THE OHIO AIR POLLUTION CONTROL ACT

As reported last Spring, OCMA joined with the Ohio Manufacturers Association, (OMA), Ohio Chamber of Commerce, Ohio Contractors Association (OCA), Ohio Chemistry Technology Council, and the National Federation of Independent Businesses (NFIB) to urge the Ohio General Assembly to amend the Ohio Air Pollution Control Act to assure that Ohio’s program is consistent with and no more stringent than Federal regulation.

On May 2, 2006, Governor Bob Taft signed S. B. 265, which streamlines the permitting process for minor sources of air pollution and moves Ohio towards a more predictable and less burdensome experience. Although the coalition’s efforts to make the Ohio permitting process no more stringent than Federal regulation were not successful, the changes made to the former Air Pollution Control Act represent a substantial victory for the manufacturing community.

The environmental lobby pulled out all stops in their efforts to derail these amendments. Environmental groups Ohio Environmental Council, Ohio Public Interest Research Group (Ohio PIRG), and the Sierra Club used deceit and emotion in their campaign to stop the proposed amendments. John Paul, Supervisor, Regional Air Pollution Control Agency (Dayton) testified almost a half a dozen times in his personal effort to stop the Ohio General Assembly from adopting S. B. 265.

Major changes outlined in S. B. 265

1. Formerly, Ohio EPA would apply a case-by-case, unit-by-unit, pollutant-by-pollutant “Best Available Technology” (BAT) requirement to all sources- big or small. Under the new provisions, a new source of air pollution that will emit less than ten tons per year of emissions will not be required to utilize best available technology (BAT).

2. Presently, Ohio EPA utilizes an air toxic policy in order to review permit-to-install applications on a “case-by-case basis”. The policy serves as a guide by which the staff of Ohio EPA uses to establish limits for specific air pollutants. The bill incorporates the Toxic Air Policy into law. However, the Director of Ohio EPA must adopt an Ohio Administrative Code (OAC) Rule specifying that a PTI is required only for new or modified sources that emit air contaminants that are covered by the Clean Air Act or present a potentially adverse human health hazard. Scientific evidence must be provided in the rule-making process to justify its addition to the list of air contaminants.

3. S.B. 265 requires that the Ohio EPA must give consideration to the overall costs within Ohio of compliance with the new rules.

4. S.B. 265 prohibits the Director of Ohio EPA from imposing additional air quality monitoring requirements for an air contaminant source when a specific monitoring, record-keeping, or reporting requirement is established for that source under applicable federal regulations or state rules.

5. S.B. 265 specifies that beginning three years after its effective date, Ohio EPA must employ the term “best available technology”, that is equivalent and no more stringent than that term is defined by the Clean Air Act and federal law. The bill requires that BAT must be expressed by the following categories: 1) work practices, 2) source design characteristics or design efficiency of applicable air contaminant control devices, 3) raw material specifications or throughput limitations averaged over a twelve-month rolling period, or 4) monthly allowable emissions averaged over a twelve-month rolling period.

The passage of S.B. 265 represents the last leg of the tripod of reforms requested by the business community to return Ohio to a more business friendly environment. Those issues, tort, tax, and regulatory reform have all been addressed. The compromise legislation will definitely improve business conditions in Ohio and hopefully will help Ohio manufacturers to be more competitive in today’s world marketplace. The leadership provided by Ohio Senator Tom Niehaus, Chairman of the Senate Environment & Natural Resources Committee and Senator Robert Spada, sponsor of the bill, was quite refreshing. These individuals demonstrated tremendous staying power despite personal attacks and threats of political retribution from the environmental lobby. If you ever meet either of them, please thank them on behalf of the Ohio Cast Metals Association.

MEETING UPDATE

On Tuesday, May 9, 2006, approximately seventy (70) representatives of OCMA member companies participated in a tour of The Quality Castings Company in Orville. The Orrville facility features five electric furnaces, two Osborn Inliner automatic cope & drag lines, a Fischer-Plus squeeze molding system with 38x42x16x16 flasks operating at a rate of 50 per hour for castings up to 700 lbs., and a Hunter H20 matchplate molding line. The core room features four Laempe machines. The foundry has a complete pattern shop as well as machining capability on-site. Serving critical manufacturing industries since 1933, The Quality Castings Company is a recognized leader in both high volume and short run production of gray & ductile iron castings.

Dave & Tony Yonto and Dick & Matt Nicholas hosted the tour with the able assistance of Troy Higgins, Quality Control, Frank Jager, Quality Control, Tim Mastrine, Purchasing, Bruce Meyer, Engineering, and Bill Sampson, Head of Engineering. A special thanks goes to Kim Horton who assisted at the OCMA luncheon at The Pines.

AMERICAN FOUNDRY SOCIETY GOVERNMENT AFFAIRS CONFERENCE

Once again the OCMA delegation was the largest of any state represented at this year’s AFS Government Affairs Conference in Washington, DC on April 26-28, 2006. This year’s conference was highlighted by a presentation by Secretary of the U. S. Department of Commerce, Carlos Gutierrez and a visit to the Old Executive Building for a briefing from top government officials; Marcus Peacock, Deputy Administrator USEPA, Edwin Foulke Jr., Assistant Secretary of Labor for Occupational Safety & Health, and William J. Luti, Deputy Undersecretary of Defense for Near Eastern & South Asian Affairs.

Important issues discusses at the conference included trade and currency manipulation, small business health plan legislation, the development of the area source air pollution control rule, and increased use of spent, non-toxic foundry sand for highway projects. King Gee, Federal Highway Administration (FHWA) spoke of the FHWA’s efforts to educate highway engineers about the outstanding engineering characteristics of spent foundry sand for highway use. He encouraged our industry to continue its efforts to find funding for these technology transfer efforts. Concerning the area source rule containing Generally Available Control Technology or GACT, Steve Fruh, Standards Metals Group Leader, USEPA discussed the on-going efforts of both USEPA and the AFS Area Source Working Group to develop a rule that will not be too onerous. He also reiterated his thoughts that a nationwide mercury elimination program should also be established.

The most important task of the OCMA delegation was reserved for lobbying on Capital Hill on Thursday, April 27, 2006. OCMA delegates began their day with a 9:00 AM meeting with Senator Voinovich’s Legislative Assistant for Trade & Manufacturing, Patrick Delaney and ended the day with meetings with august Representative Ralph Regula. There were eighteen scheduled visits, the largest number for any of the AFS state delegations. One of the important themes for the day was urging Congress to end the Chinese currency manipulation. For the second year in a row, nearly everybody we met voiced strong support for reining in the Chinese juggernaut and pressuring them to eliminate their currency manipulation. However, there was very little, if any, consensus among Republicans and Democrats about how to do that. For that reason, it was a pretty frustrating day. Conferees most enjoyed the Thursday reception, where Tony Snow, former Fox Radio news celebrity who had just been named as the new White House chief spokesman, delivered an upbeat view of victories and important goals achieved by the Bush Administration.

The AFS GAC presented an excellent opportunity for OCMA members to remind our Congressional Delegation of the importance of metal casting to the manufacturing base in the state of Ohio. The uniform message that the Chinese threat is real and dangerous resonated with our leaders, they just seemed unsure about the action to take. Next year, it is important that we expand the number of Ohio metal casters and suppliers who make the trip to Washington DC to help them find the answer.

ENVIRONMENTAL UPDATE

OCMA Vice President for Environmental Affairs Dennis Baker, Flowserve Corporation, provided a brief report to the OCMA Board of Trustees at their meeting on Tuesday, May 9, 2006. The key issues are briefly outlined below:

Iron & Steel Foundry GACT

• Dennis accompanied the AFS GAC Work Group who met with USEPA staff at the Research Triangle Office in Raleigh, North Carolina. The USEPA notified the AFS representatives that the Agency was confident that with one major exception the rules outlined in the MACT would not be too burdensome on smaller iron & steel metal casters. USEPA has challenged the AFS Work Group to demonstrate that certain MACT standards are indeed too burdensome for small and medium sized metal casters and to provide USEPA with alternative suggestions to comply with the Clean Air Act requirements.

• Unlike the MACT standard, USEPA is looking seriously at developing an applicability standard using iron & steel production numbers to eliminate smaller facilities from coverage of the area source rule. These smaller entities would only be required to certify that they did indeed produce less than the trigger output. The USEPA recommended that those production limits should be 1000 tons/yr for iron foundries and 500 tons per/yr for steel foundries.

• Although the initial impetus for the area source rule was emphasis on reducing air pollution in urban areas, USEPA has adopted a position that all area sources regardless of location will be covered by the rule. The Agency argued that it did not wish to create an unfair competitive advantage for those facilities in a non-urban area and all foundries emit relatively high levels of hazardous air pollutants or HAPs, so they are determined to reduce these emissions.

• Regarding the use of so-called “low emitting” binders, USEPA indicated that they have no intention to require a foundry to use these binders. However, they do intend to use the area source rule development process to create incentives for metal casters to experiment with the use of low emissions binders.

Beneficial Reuse Update

• Ohio EPA is in the last stages of drafting a rule to replace Ohio EPA Policy 400.007. Ohio EPA has adopted a self-imposed deadline of December 31, 2006 for the completion of the rule-making process. OCMA drafted and submitted a position paper recommending changes in the former Policy 400.007. We anticipate an opportunity to comment on the Ohio EPA draft in the next few months.

Please Join Us this Summer

• The Ohio Cast Metals Association (OCMA) annual meeting will be held on Thursday, July 13, 2006. Ohio Speaker of the House, Jon Husted and Ryan Augsburger, OMA Political Analyst, will be our speakers. Contact Russ Murray at 614-876-5100 for more information.

Photos courtesy of Larry Boyd, EIO, Mike Dragomier, and Troy Higgins, The Quality Castings Company.

Matt & Dick Nicholas and Dave & Tony Yonto, The Quality Castings Company receive an Iron Pourer Wall Plaque from Mike Dragonmier, Kent State University for sponsoring the OCMA foundry tour. The plaque was produced by the Kent State University AFS Chapter.

A Quality Castings Company employee prepares sand cores.

Tour participants were able to view the pouring of castings during the OCMA tour of The Quality Castings Company.

The Quality Castings Company offers machining of its castings for their customer’s benefit.	The Quality Castings Company offers machining of its castings for their customer’s benefit.

	Jeff Tomski, T H Mfg., Inc. admires his OCMA member certificate.
Employees setting cores for the Georg Fischer Plus Squeeze Molding System.	OCMA President John Vaught presents a new member certificate to Cliff Glowacki, Technikon LLC.

The OCMA delegation prepares for its big day on Capitol Hill. Pictured below are:

Ken Seilkop, EPCOR Foundry, OCMA Vice President George Deckebach, Miami-Cast, Inc., Fred Corpuz, Foseco Metallurgical Inc., OCMA Secretary John Kurtz, Kurtz Bros., Inc., Ryan Burke, OSCO Industries, Inc., OCMA Past President Doug Rowe, OCMA Treasurer John Burke, OSCO Industries, Inc., Dan Salak, Foseco Metallurgical Inc., OCMA President John Vaught, Tri-Cast Ltd., OCMA Executive Director Russ Murray, Jack Staiger, Ellwood Engineered Castings, OCMA Trustee Craig Schmeisser, RMT, Inc., OCMA Trustee Mike Swartzlander, Ashland Casting Solutions, Jim Gary, GM Powertrain – Defiance, Craig Holman, Columbus Steel Castings Company, Dave Seilkop, EPCOR Foundry. Not pictured was Mike Dadas, Ford Motor Company, Cleveland Casting Plant.