Larry Cottrell: A 'Foundryman' Tackling GM's Environmental Issues.
His views from both the production and environmental sides of foundries give him keen insight into one of the major obstacles facing metalcasting--government rules and regulations. It goes beyond mere compliance to protect the environment from harmful air emissions and hazardous waste, he explained; U.S. rules and regulations place additional burdens on U.S. foundries in the international marketplace.
"Time is important when competing in the global market," Cottrell said. "Beyond the paperwork, the process of getting an environmental permit can take from nine months to a year. That can be more time than a foundry can afford." Besides being detrimental to the environment, improper permitting can mean noncompliance, which can shut down a foundry and cease production, he added, costing a company like GM the competitive edge in the global marketplace.
This article describes what Cottrell's 43 years of experience have taught him about working with government regulators and the importance of foundries understanding the relationship between environmental and production pressures. Cottrell also discusses both the benefits and the new obstacles that technology contributes to environmental compliance.
From Student to Foundryman
In March 1958, Cottrell was attending General Motors Institute (GMI), which is now Kettering Univ., Flint, Michigan. "At that time you had to be a GM employee to attend," Cottrell said. The personnel manager took one look at Cottrell's 6 ft 2 in., 200-lb frame and assigned him to GM's foundry in Pontiac, Michigan.
In 1962, Cottrell earned an equivalent to an electrical engineering degree from GMI and was assigned to a position installing pollution control systems at the foundry. "It was a time (the 60s and 70s) when people were becoming more concerned about the environment," he said. The country was becoming more conscious of environmental issues and encouraging industrial legislation to reflect that. In 1969, the National Environmental Policy was enacted, followed by the Clean Air Act in 1970 and the Clean Water Act in 1972. For manufacturing plants and foundries, according to Cottrell, this resulted in establishing full-time environmental staffs.
In August 1977, Cottrell left the Pontiac foundry. He was promoted to corporate environmental auditor with GM's Environmental Activities staff, which oversaw all of GM's plants in North America. He traveled to various facilities, including foundries, to confirm their compliance with government regulations. If necessary, he developed plans for plants to follow to ensure continued compliance. From 1982-88, he worked in GM's corporate energy section, which handled utility and energy consumption. After that, Cottrell was part of a corporate management team on an 8-yr project to develop a waste management program.
In 1996, Cottrell returned to the foundry industry as GM began its full-scale implementation of lost foam casting. Someone was needed to lead the charge to obtain environmental permits by navigating state and federal regulators through a molding process unfamiliar to them.
The Critical Issue
Cottrell harbors a firm conviction that the most pressing issue facing the metalcasting industry is government regulations. In his opinion, the only solution is to intensify communication between the government and industry. Only through this communication will government agencies begin to understand the foundry's point of view.
Overall, Cottrell is more concerned with regulations at the state than federal level. Although the federal EPA is still the managing authority, state regulations have a more direct impact on foundries. "State regulations usually are more stringent than federal. They have to be," Cottrell said. "The federal government is allowing states more authority. States can create more stringent laws--which they do--but they cannot pass laws less strict than federal ones." State governments know better what concerns and benefits its citizens in each municipality, according to Cottrell. Also the federal government doesn't have to cope with the various industrial/environmental complexities and differences of each of the 50 states.
In its efforts to reduce the time factor, GM maintains an ongoing dialogue with the state agencies to expedite the permitting process. But even that takes time, Cottrell said.
"The agencies have to learn more about the foundry industry, but it takes time for both sides to get comfortable and trust each other. Even though top management on both sides buy into a program, sometimes those at the lower level are slower to react because of their understanding of what their job entails," he said.
This understanding requires face-to-face meetings, which is better than a phone call or written communication, he added. That allows for specific knowledge to be shared on issues like sand reclamation and lost foam emissions. Through the entire permitting process, GM holds face-to-face meetings with regulators onsite, in government offices or on neutral ground. "What matters is having the face-to-face," Cottrell emphasized.
The iron and steel Maximum Achievable Control Technology (MACT) standard offers an opportunity for ongoing dialogue between the industry and regulators. Cottrell has been a member of the AFS MACT Task Force.
"We've been trying to inform regulators what is achievable," said Cottrell. "For example, with MACT, cupolas are all different. Because below-door takeoff is different from above-door takeoff in cupolas, a higher temperature doesn't apply to both."
"With talk of temperature, requiring an afterburner to destroy the carbon monoxide (GO) is good if the CO is there. If there is no CO, then there is no need to maintain that high level of heat. There's no need to create an arbitrary temperature. If a cupola doesn't have the coke to convert to GO, there's less CO. These are some of the points we need regulators to learn so they can understand how the rules affect reality."
Another way GM maintains an ongoing dialogue with government agencies is through its regulation/legislation (reg/leg) group. The purpose of the reg/leg group is to keep informed on regulations and pending legislation. They sit on committees and issue bulletins when new regulations come down.
"When the Secondary Aluminum MACT came down, they knew what foundries would be affected and notified them. They told them what to check and what to comply with," said Cottrell.
As more companies grow leaner, they rely more on people whose sole job is to stay on top of new and proposed legislation. "That's why we have a corporate group to do this for the corporation," he explained.
The reg/leg group suggests smaller foundries keep up with federal environmental regulations through industrial organizations like AFS and the North American Die Casters Assn. To keep abreast of specific state issues, smaller foundries can contact a state's cast metals, industry and/or manufacturing associations.
In his 43 years, Cottrell cites the development of computer control and more sensitive sensors in the last decade as the greatest overall boon to environmental control technology in the foundry industry.
"For example, the new advanced baghouses have equipment that can successfully cool gases and reduce waste" he said. Also, GM originally used wet caps to lower air pollutant emissions from cupolas but is now using high-energy wet scrubbing. Cottrell also has seen GM shift from oil sand cores to hotboxes to polyurethane coldboxes; and from green sand molding to lost foam, all resulting in more precise castings as well as lower air pollutant emissions. "But it's still not an easy situation. We haven't arrived at a point where we can sit back and let the equipment run itself," he added.
With each new process comes a new set of problems.
With the lost foam process, for example, the environmental permit approval delay can be traced to a lack of data. The initial step to obtain a permit is gathering data to model the process for state approval. Not enough reliable data exists to determine the air pollutant emission factors for emission estimates with a new process like lost foam, but permits require that information. Oftentimes, permit-seekers refer to the estimates database provided in the EPA AP-42. The AP-42 is considered the "Bible" for air pollutant emission factors and inventories, but it's for more traditional processes, Cottrell said. Since the permit requires emission estimates to develop emission control strategies, an error, no matter how slight, will delay approval and make additional retesting mandatory, he added.
Because newer processes, like lost foam, produce lower emissions and are not detrimental to the environment, Cottrell believes broadening the range of emission estimates could speed up the process, generate more reliable data and keep U.S. industry on the cutting edge.
This drive for the cutting edge will allow U.S. foundries to compete globally despite the delays generated by government rules and regulations.
Larry D. Cottrell
Senior Administrator of General Motors Corp. Worldwide Facilities, Environmental Services, GM Corp.
Education/degree: Lawrence Technological Univ., Southfield, Michigan/BS in Mechanical Engineering, 1965; Wayne State Univ., Detroit/M.S. in Hazardous Materials Management, 1994.
Professional Assn.: Engineering Society of Detroit Certified Hazard Materials Management
Founded: 1908 (GM Corp.).
Metalcasting Operations: Saginaw, Michigan (Metalcasting Operations and Malleable Iron); Massena, New York; Defiance, Ohio; Bedford, Indiana; Spring Hill, Tennesee (Saturn).
Metals Cast: Gray, malleable and ductile iron, and aluminum.
2000 Shipments: 888,000 tons.
Metalcasting employees: 7350.
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|Title Annotation:||Environmental and production issues in foundry business|
|Comment:||Larry Cottrell: A 'Foundryman' Tackling GM's Environmental Issues.(Environmental and production issues in foundry business)|
|Date:||Jul 1, 2001|
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