Foundries prepare for Clean Air Act's Title V showdown.

To make sum their foundries have their bases covered in the Clean Air Act (CAA) Title V Operating Permits, which are due in nearly all states next fall, 106 foundry representatives met at the Casting Industry Clean Air/Environmental Conference September 14-16 in Chicago.

Sponsored by Ashland Chemical Co. and RMT, Inc., the meeting featured 13 speakers and 16 workshops.

"Sometimes the challenges we face seem almost overwhelming," said Ron Claussen, Caterpillar Foundry. "To stay in business in the past you had to have good quality, excellent service and competitively priced products. Now there is another dimension--the environment.

"The bottom line--only by accepting your environmental responsibility today can you assure a future for your business tomorrow."

Title V Permits

In the past 20 years, more than 50,000 environmental laws were passed in the U.S. federal and state legislatures, according to George Booth, Casting Operations, Ford Motor Co. From 1971-1991, the foundry industry shrank by 32%. One of the most important pieces of environmental legislation was the Clean Air Act Amendments (CAAA) of 1990.

The goals of the CAAA of 1990, said Patricia Hanz, Briggs & Stratton Corp., are to:

* attain nationwide compliance with the national ambient air quality standards;

* reduce the emission of air toxics by at least 75%;

* cut S[O.sub.2] emissions by 10 million tons;

* phase out chlorofluorocarbons (CFCs) and similar compounds;

* have clean sources operating in the U.S.

The major impact of the amendments is the Title V Operating Permit, a comprehensive permit covering all aspects of a foundry's operations. "It specifies not only conditions under which you operate but also monitoring, maintenance, reporting and record-keeping requirements," Hanzsaid. "You can't legally operate without one."

Estimating that it takes 18 months to 3 years to put the application together, Hanz said her firm is in the home stretch (Wisconsin has an earlier deadline). She offered 10 steps for foundries in filing the application:

1. Identify all sources--Be prepared for surprises. This is a time-consuming activity and will require activities such as stack mapping of your facility, identifying all production materials, obtaining certified material safety data sheets (MSDSs) for materials and creating detailed process flow diagrams.

2. Prepare an emissions inventory--While the annual air emissions inventory is useful, be prepared to develop additional data as well.

3. Determine whether you are a covered source--If so, determine if you can make production changes to reduce emissions below the threshold criteria.

4. Compile and review existing permits--Compare them and other applicable legal requirements to actual operations.

5. Determine if your facility is in compliance with all applicable requirements--Don't expect to find your facility in compliance with each and every applicable legal requirement. Develop a plan of action that may require gathering additional data (emission testing), installing additional pollution control equipment and other similar actions.

For sources you aren't in compliance with, develop a compliance schedule. That schedule will become an enforceable part of your permit, and progress reports will need to be submitted to the state at least every six months.

6. Identify current, alternative and future operating scenarios--This requires meeting with production staffs and integrating long-range planning with operational needs and wants.

7. Devise operating, monitoring, reporting and record-keeping systems--EPA preaches flexibility in permits as one of its market-based regulatory approaches in the CAAA of 1990. Incorporate this to optimize minor production changes (such as changes in materials) without the need for permit modifications.

For monitoring, identify alternatives to direct measurement of emissions, if possible (lb/hr). EPA has allowed the use of surrogates and calculations based on emission factors in the past. Don't forget your malfunction prevention and abatement plan. Make sure employees know what it says and means from an operational point.

8. Meet with production and maintenance staff--Go over the operation, maintenance, reporting and record-keeping systems to make sure that they understand the systems and how these requirements will impact their work. Develop a training program, as well as a data management system, to assure continued compliance over time. All data and records must be kept for at least five years.

9. Draft a permit application--Review the draft with staff to make sure it says what you want it to say and that all of the supporting documentation is complete.

10. Submit the permit application--Recognize that your state must notify other states within 50 miles of the source and any state whose air quality may be impacted. Nearby states have an opportunity to comment onthe permit application.

"Your permit should be submitted two months prior to the due date," Hanz said, "to give the agency time to perform a preliminary review of the permit application and determine whether the application is complete, which makes you eligible for the permit shield. The permit shield protects you from the state's failure to timely issue the operating permit. The shield applies to existing sources, sources subject to new source review and prevention of significant deterioration determinations."

Critical Time

Claussen said environmental compliance adds to the cost of doing business, which directly affects the bottom line. For a foundry in compliance, he said 5% of its sales is typically spent on environmental control. And historically, foundries haven't had very high margins.

"There will be increased emphasis on reduction of wastes at their source," he said. "If industry is not environmentally responsible, we can expect more regulations that tell us how to operate our processes, instead of simply giving the discharge limits we must meet."

"The CAA is probably the most reaching legislation ever," said Jim White, Grede Foundries, Inc., who said the Title V application for one Grede plant was 737 pages, weighed 11.5 lb and cost the firm $58,000. "About 80% of the industry has fewer than 100 employees and limited capital. The number of foundries will decrease directly because of the CAA."