AFS leading the way on RCRA reauthorization.
The current reauthorization package for RCRA, the major federal mandate that regulates treatment, storage and disposal of hazardous and nonhazardous waste, represents the first significant revision of the law since 1984.
We Have A Plan
AFS has formulated a three-pronged approach to respond to this challenge. First, we recently unveiled a no-nonsense position paper that addresses RCRA initiatives being considered by Congress that will significantly impact foundries. Second, AFS has formulated a winning strategy of grassroots advocacy, education and lobbying to send a clear and effective message to Washington. Third, and most important, is the most crucial ingredient necessary for victory: your participation and commitment to seeing this effort through ! We Have A Message
The AFS position paper highlights four major objectives relative to RCRA reauthorization:
Goat #1-Establish a program within RCRA to encourage increased beneficial reuse of foundry sand.
U.S. foundries currently spend over $580 million to dispose of approximately eight million tons of waste each year. Spent molding sands account for about six million tons of that total waste volume.
Although the industry is working on its own to achieve safe and economically feasible management of its waste, only 4.2 percent of nonhazardous foundry sand is used annually as a raw material for beneficial reuse applications such as asphalt paving, concrete aggregate and building foundations.
Because of the significant reuse potential of foundry sand across a range of applications, the industry could benefit immensely from steps by Congress that encourage the beneficial reuse of this innocuous material. But if the current climate of debate is any indication, industry efforts to trim needless volumes of waste going to landfills will be curtailed.
It is imperative that we let Congress know that the foundry industry is already engaged in activities that achieve to the fullest extent possible such important environmental policy goals as preserving the nation's dwindling landfill capacity.
Goal #2-Maintain the current exclusion of nonhazardous foundry sand from the provisions of subtitle C hazardous waste) of RCRA.
Management of spent foundry sand is not yet regulated under federal hazardous waste laws, but foundries could run into major cost and operational impediments if Congress broadens the scope of RCRA to classify this material as a hazardous waste. The same will hold true if nonhazardous waste becomes subject to a stringent regulatory scheme.
Under either scenario, transportation and disposal fees for this material could see a tenfold increase. These soaring costs for foundries could severely weaken the competitive standing of U.S. foundries in the world cast metal products market.
Congress must recognize that foundries are already absorbing the increased costs for waste disposal that current RCRA permitting and siting requirements place on American industry, and that additional proposals that bind foundries to a new and complex regulatory scheme lack the foresight necessary to ensure the nation's competitiveness in the global marketplace.
Goal #3-Prevent inclusion of new restrictions to recycling of scrap metal by foundries.
According to an industry survey, U.S. foundries each year reuse more than 15-20 million tons of scrap metals. Although scrap metal materials are now exempt from RCRA'S hazardous waste management requirements, these materials are in serious danger of being classified as 'hazardous secondary materials" that will be regulated by EPA.
Under current proposals, if EPA is unable to issue standards for these materials within two years of the bill's passage, scrap metal would become subject to the comprehensive restrictions that currently apply to hazardous waste under subtitle C of RCRA.
In either case, the industry will not be able to cost-effectively make use of scrap metal. The increased costs are staggering, and could easily add up to more than $1 billion. That's nine zeroes, no kidding ! Congress will need to understand that the foundry industry already plays a major national recycling role by converting millions of tons of scrap metal to useful products for the country's manufacturing sector and the American consumer.
Goal #4-Prevent mandatory waste minimization programs that limit flexibility in the production process.
Changes eyed for RCRA regarding waste minimization focus on two major areas. Both involve highly restrictive measures that if enacted into law will fundamentally redefine the terms of this nation's production of consumer and industrial products.
First, the amendments would require foundries to develop plans and submit reports to EPA on the presence of hazardous substances in both products and solid or hazardous wastes generated. If an operation cannot limit production or generation of certain materials, an EPA audit is triggered and a foundry will be forced to adopt EPA-devised toxic source and use reduction goals and practices.
Second, the amendments propose to widen the definition of hazardous substances under RCRA to incorporate approximately 1100 materials currently regulated by EPA. This measure stretches the current hazardous waste definition to bring under regulatory control materials like iron, steel and aluminum.
What is stultifying is the fact that substances on EPA'S list need only be present in a product or waste at trace concentrations for EPA to impose on an operation various audits, plans and standards for disposal, manufacture and distribution of products.
Put simply the combined effect of these regulations is to make all castings and, hence, all manufactured products, hazardous substances. It is beyond anyone's guess how Congress could consider regulating as harmful items such products as cast brass door handles or cast aluminum ice cream scoops ! The bottom line is that toxics use and source reduction techniques need time to evolve. Programs should be put in place to maximize industry incentives for instituting production processes that utilize smaller volumes and lower levels of toxics.
But if the present mandatory restrictions pass, we are really in for a drubbing. The word must get to Congress that movement in this direction is unjustifiable on any terms. Surprisingly enough, these types of initiatives are being taken seriously in some quarters in this policy debate.
We Are Moving Ahead
Extensive planning and preparation for our lobbying effort has taken place in the past three months. In November, AFS committee members and state group chairmen convened for a two day legislative planning session in Washington to discuss RCRA reauthorization and other environmental issues. The group discussed the steps necessary to effectively educate Congress, and worked on refining industry goals and legislative strategy for RCRA.
In order to strengthen our case on the Hill and provide an accurate picture of the industry, its significance and the manifold challenges it faces on both the global and domestic fronts, AFS also has been engaged in gathering information from members to create an industry profile. Information from this data base will bring home to our elected representatives just how much is at stake for their constituencies.
But what we would really like is to inform Congress and the Administration of the simple merits of the issues the facts. That is why AFS has developed a well-argued position paper which addresses industry concerns about RCRA point by point. Work on this excellent piece progressed successfully with help from a host of contributors, and the final product is now available and will be distributed at the AFS Government Affairs Conference March 22-24, 1992 in Washington D.C..
This conference will officially kick off the grassroots segment of the RCRA legislative plan. The format will be a hard-hitting mix of information and congressional visits. We will fully prepare you with the information and materials necessary to discuss RCRA reauthorization in your congressional visits. We also will assist in scheduling those visits.
To bolster the effectiveness of our advocacy strategy in Congress, we have developed a list of primary congressional contacts. Since the environmental subcommittees in both houses may soon deliberate and vote on the RCRA package, we have targeted for meetings with foundry representatives key members of those subcommittees who represent the leading foundry states. in Washington, we already have taken our case to several members who will play a major role in the upcoming debate.
More important, we have zeroed in on home districts during the Congressional recess period. By organizing district meetings between members of Congress and foundry leaders, we got a head start on arguing our case before the flurry of activity begins again in Washington.
Recently, a delegation of Michigan industry representatives met with Rep. John Dingell (D-Michigan). As the powerful chairman of the House Energy and Commerce Committee, which has jurisdiction over RCRA, Rep. Dingell will be deeply involved in the issue throughout this session.
We Need You
To ensure the success of this major undertaking and avert the costly regulatory lockhold in store for the industry if RCRA revisions are ultimately passed, we need your help. We are building a team approach for this effort, so those involved will not be going it alone.' The Washington conference is quickly showing will demonstrate to our elected officials our resolve and commitment to getting the truth out on what the foundry industry is really all about.
Inform yourself about these issues and plan on being involved. One of the est routes of access to involvement is your local AFS chapter and state group. These groups will be updated continually with new information and will establish the linkage necessary to cover all the bases in getting through to our elected leaders.
The seriousness of the developments unfolding in Washington cannot be emphasized enough. The legislative proposals coming down the pike do not contemplate the profound problems they pose to our industry and the unintended effects of this bad medicine for our already-troubled national economy.
Be certain that AFS will assist you along the way, not only on how to become a participant in our campaign, but also on how to arm yourself with the main points of our message. Advocate the industry's position firmly and effectively both in your home state and in Washington.
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|Title Annotation:||American Foundrymen's Society; Resource Conservation and Recovery Act Amendments of 1991|
|Date:||Feb 1, 1992|
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