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Clean Air Act needs planning, concerted action.

In 1990, just when American industry was beginning to meet world competition on many industrial fronts, President Bush signed the Clean Air Act amendments. With that action, he set into motion one of the world's most demanding and comprehensive pieces of environmental legislation. The amendments are toughest for heavy industry, the constituency of foundries, and will restructure industry's outlook on environmental controls and liabilities.

Although the Act is made up of a number of amendments, the amendments most affecting the foundry industry are Titles I, III, V and V Perhaps there was a time when management could ignore pay scant attention to environmental compliance rules and regulation, but no more. Not after the 1990 amendments became law. Not after the management must become well-versed on exactly what is expected from these Titles and what they must to to be in compliance with them. What follows is a brief synopsis of the key Titles and how they will affect foundry operations. Title I-Ambient Air Quality

The two most important w Title I for the foundryman are attainment and nonattainment areas. Nonattainment areas are defined as those geographical regions whose air quality does not meet federal air quality standards designed to protect public health. Attainment areas are those regions that are in federal compliance. Under this Title, state enforcement agencies are required to reduce emissions from existing facilities and make permits for new and modified facilities more difficult to obtain. Nonattainment areas are required to reach attainment no later than five years from the nonattainment designation date.

Hardest hit will be those who are currently not in compliance with ambient air standards for ozone levels. Ozone nonattainment areas are classified based on ozone design levels as marginal, moderate, serious, severe and extreme. Affected industries are those emitting unacceptable amounts of volatile organic compounds (VOCs) from such operations as painting, metal cleaning and stripping. Other nonattainment areas defined in this Title include carbon monoxide, particulate matter up to 10 microns, sulfur oxides, nitrogen dioxide, lead and others.

Under this Title, plant expansions and new plant construction in nonattainment areas will be negatively affected. Regulations stipulate that new or expanded facilities must obtain environmental pollution reductions at least equal to, or greater than, the anticipated increase of pollutants from the new or modified source. Title III-Air Toxics

The new law incorporates 189 toxic air pollutants listed alphabetically in the accompanying table. The EPA is charged with the responsibility for categorizing emission sources and developing emission standards (Maximum Achievable Control Technology or (MACT) for the materials and their sources.

Major sources will be defined as any stationary source of air pollutants that emit an aggregate of at least 10 tons per year of any hazardous pollutant or at least 25 tons per year of a combination of hazardous pollutants. There are some benefits for companies that voluntarily reduce emissions according to EPA guidelines. They will be allowed a six-year extension to achieve MACT requirements Title V-Permits

Under this section, the EPA establishes new permitting programs modeled after the National Pollution Discharge Elimination System (NPDES) for waste water discharge. Under the new law, states will issue permits after EPA approval of the permitting process. Each permit will be valid for five years. The states will levy and collect permit revenues, now expected to be about $25 per ton per pollutant with a maximum of $100,000 per pollutant. This aspect of the law is not completed at this printing, but foundry managers are advised to stay in close contact with state and local agencies before initiating any new construction of facility upgrades because these programs will be retroactive when implemented. Title VII-Enforcement

To strengthen EPA's authority, Congress increased the agency's ability to levy increased administrative penalties and field citations. The new law has shifted environmental responsibility from lower level staff members to senior corporate managers and made what used to be misdemeanors into felonies. It also provides a bounty hunter' reward of up to $10,000 to persons reporting environmental criminals. EPA now has new authority to levy administrative penalties up to $200,000 and filed citations of up to $6000 for lesser violations

As never before, it pays to be aware of current environmental laws, to keep extensive records, and to be honest, correct and timely in all reporting. Ignorance, lack of information and complacency are no longer an excuse. Compliance Planning

The new law makes management commitment imperative. Senior managers or corporate officers are the ultimate responsible "operators" of the manufacturing system. It is a management responsibility to see that leaks are fixed, equipment is maintained and permit information is accurate.

All of this takes planning and organization. The planning and organization team should include a senior manager or company officer who will sign all permits, thus verifying accuracy. Competent legal counsel, the plant engineer, chief environmental engineer, production manager and purchasing manager should also be included. Each will have his or her advisory role, but the drive must start at the top because the impact of this legislation will be one of the major business issues of the decade. It deserves the highest priority.

Most of the emission reduction plans will be keyed and accelerated for nonattainment areas. The prudent foundry manager will know his plant area and will monitor new state and local regulations as they are written.

Air permits should be updated because many provisions of the law deal with proof of emission reduction. The tendency is to routinely resubmit air permits that do not always reflect actual process rates or materials or that use outdated emissions information. For instance, changes in coremaking should be reflected on permits.

Actual emission data must be reflected on permits. Old equipment may not be achieving the efficiencies guaranteed at installation. Stacks should be checked and tested to ensure that emission values are accurate. New permit costs will be based on emission levels, and data from updated permits may prove to be the basis for reductions when processes are changed or improved. There are provisions in the law that encourage early actions for reduction of particulates and air toxics. Thus, an accurate baseline emissions history beginning at the earliest practical time can be an effective tool for reducing costs.

As a matter of fact, the Act considers a baseline year for determining emission reductions of air toxics. The baseline emissions, accurate and verifiable, are necessary to determine reductions and offsets. TABULAR DATA OMITTED
COPYRIGHT 1991 American Foundry Society, Inc.
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 1991, Gale Group. All rights reserved. Gale Group is a Thomson Corporation Company.

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Title Annotation:Air Quality Committee 10-E
Author:Mosher, Gary
Publication:Modern Casting
Date:Jul 1, 1991
Words:1068
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