Foundrymen discuss EHS issues.

Judging from the number of registrants at the AFS 9th Annual Environment Health and Safety Conference (EHS), the upcoming deadlines for compliance with the 1990 Clean Air Act Amendments (CAAA) and the upcoming maximum achievable control technology (MACT) standards are grabbing the attention of foundries across the country. The conference, held August 17-20 in Indianapolis, brought together 244 foundrymen and suppliers for a discussion of environmental issues facing the industry at the close of the century. During the two and a half-day event, attendees participated in 21 presentations on various EHS topics.

Much of the conference debate dealt with the MACT standards being developed for foundries. Representatives of foundries that are considered major sources of hazardous air pollutants (HAPs) expressed concern about the proposed regulation. The MACT standards will require major HAP producers to reduce emissions to the extent possible by installing technology specified by the U.S. Environmental Protection Agency (EPA). Though the MACT standards are not yet completed, consultants from August Mack Environmental recommended that foundries reduce their emissions below the major source threshold and obtain federally enforceable permit conditions so that MACT does not apply. This can be accomplished by process modifications, reduction in operating hours, testing actual emissions and installing control technology.

Jim Maysilles of the U.S. EPA further recommended that foundries step up their efforts to prepare for the future promulgation of MACT standards. Currently, the EPA is distributing short and long form questionnaires to ferrous foundries across the country. These questionnaires will be used to formulate the MACT standards. The EPA will be reviewing the surveys as early as November 1998. MACT standards compliance for foundries is set for 2003. The foundry industry is continuing to respond to the threat of MACT standards. Representatives of AFS reiterated the organization's efforts to work with EPA regarding the proposed regulation. Since the fall of 1996, groups of foundries and foundry associations have been meeting to discuss the development of the MACT standards, and have formed the MACT Task Force (MTF). The committee is backed by the AFS Board of Directors, which approved up to $50,000 in funding for the MTF's activities. Overall, foundrymen attending the EHS conference seemed supportive of the MTF's activities.

"No single response from one foundry will influence what the MACT will be - larger facilities may have greater impact - but small and large ferrous foundries need to work together and support the efforts of the MTF," said Tom Rarick, vice president of Keramida Environmental, an Indianapolis consulting firm.

VOC Emissions

As well as responding to the upcoming MACT standards, foundries need to be aware of a "hole" in environmental volatile organic compound (VOC) emissions regulation that could get them into trouble. VOCs generated by foundries have not previously been considered a source requiring regulatory action, but many foundries should be aware of a possible trend in the regulation of VOC emissions from foundries. Steve Wilson, Flowserve Corp. and Russ Murray, executive director of the Ohio Cast Metals Assn., (OCMA) presented a case study that demonstrated the need for concern about this issue. The Ohio EPA cited several Ohio foundries for violation of VOC emissions in 1995. The OCMA took notice, and started a project to study how the EPA intended to regulate such emissions.

According to Wilson, foundries using phenolic urethane nobake and coldbox type binders were determined to be the cause of the VOC emission violation. Under an Ohio administrative code, VOC emissions cannot exceed more than 8 lb per hr and/or 40 lb per day. OCMA argued that the "8 and 40" rule was not meant for foundries and contended that costly environmental controls could put some smaller foundries out of business. Following a meeting with Ohio EPA in December the OCMA moved forward with a second proposal that included protocol for testing foundry binder systems. Most of 1996 was spent trying to complete a memorandum of understanding outlining the various responsibilities of the two parties.

Eventually, the Ohio EPA agreed to a proposal to perform a best available technology (BAT) study of the "8 and 40" rule to support the RACT rule or a category exemption for core/moldmaking operations in foundries. In December 1996 and January 1997, OCMA supplier members Ashland Chemical Co., Borden and Delta Resins and Refractories tested representative core/moldmaking binder systems most commonly used by Ohio foundries to measure potential VOC emissions. Based on the consistent results from all three suppliers, OCMA recommended that the average values of the tests be used as the new VOC emissions factors for core and moldmaking operations. In March 1997, the Ohio EPA responded to the OCMA recommendations, and agreed to the proposed factors.

"Though unique, the VOC emission situation in Ohio could easily happen elsewhere, and foundries should be aware of what the regulations concerning VOCs are in their respective states," Murray said. "It is important that foundries work together with their state associations and be proactive - try to work with your EPA office - and remember that perseverance counts when dealing with these issues."