Prepare now for Clean Air Act; despite lacking a specific implementation date for CAA, foundries are advised to begin documenting emissions sources now.
During the two years since the Clean Air Act (CAA) reauthorization was signed into law, few clear signals have come from EPA about the various standards to be promulgated and the structure of operating permits.
In addition, the White House, EPA and industry representatives disagree about key components of the rules, causing long delays in rule definition.
"We try to anticipate regulations that may be coming down the road," said Richard Veach, manager of human resources at the Navistar international foundry in Waukesha, Wisconsin. "With respect to CAA, there are a number of components that will affect our operations. Right now, we're weighing our options, but our actions will depend to a large extent on how EPA and the White House resolve certain issues."
Operating permits and the potential delays the process could cause if the rules are promulgated in their present form are an area of debate.
For instance, the regulations allow foundries to obtain a single permit for multiple sources. While this would appear to streamline and speed the permitting process, it actually has the opposite effect. Permit regulations require more detailed emissions testing, monitoring and record keeping for individual emissions sources.
After promulgation, permits will be treated as legally binding documents, defining specific emission limits and detailed information about compliance. With such detail in the permits, minor changes in production or raw materials could trigger a full regulatory review.
Permits must contain some flexibility through systems like internal emissions trading so facilities can make routine production adjustments. Otherwise, the permitting system will put a strangle-hold on foundries because they will have to wait for a regulatory review (with a public comment period) before minor changes can be made.
Defining the term "minor" and limiting public comment periods are issues the White House and EPA are attempting to resolve. If the rules remain as written, they could make foundries less competitive because they will not be able to respond to market changes quickly or efficiently.
And, while EPA and the White House debate these issues, foundries are still required to meet regulatory deadlines.
"Unlike in the past, the permit data content burden will be placed squarely on the shoulders of companies submitting permit applications," said Dale Ziege, chief of the permit section, Bureau of Air Management for the Wisconsin Dept. of Natural Resources. "It will be a source's responsibility to identify which regulations apply to its facility, submit the permit application in the proper format and include the appropriate information."
However, foundries can act now to prepare for the regulations. The first is to work closely with their state regulatory agencies. Under CAA, each state is required to submit its permit program plans to EPA no later than November 1993.
EPA then must approve or disapprove the programs within a year from when the documents were submitted. Individual sources are required to submit permit application to the appropriate state agencies by November 15, 1995.
Wisconsin and several other states are already working with industrial sources - and foundries - to develop a simple permit application that contains all required information.
"This is mutually beneficial because it allows us to resolve any problem areas before we submit our state implementation plan," Ziege said. "Wisconsin's forms are expected to be completed by spring 1993, which will allow companies to anticipate our requirements, emissions standards and monitoring programs."
It is important for foundries to be aware of state monitoring programs because EPA has not decided how often emission sources must demonstrate compliance through periodic testing.
The types of emissions records and documentation that foundries will be required to keep should be available soon, but there is no doubt that detailed documentation will be needed. Foundries that do not have up-to-date records sufficient to conduct an emissions inventory and compliance audit are cautioned to begin gathering data as soon as possible.
After the emissions inventory is completed, foundries should factor in anticipated growth over the next five years and project the impact of that growth on emissions. Before submitting emissions forecasts, however, it is wise to include line staffs in all discussions.
Staff involvement in the planning of meetings can save time and add validity to the compliance estimates. Such input also can help estimate how production expansion, changes or modifications may affect production by-products and their probable effects on emissions.
On the federal level, foundries can work with associations - such as AFS - to gain insights on regulatory intents.
"We stay in contact with our trade organizations and other industry leaders so we have an idea of the direction EPA will take," Veach said. "These groups are also working with EPA concerning development of the [emission] standards, which is very important because it helps ensure that the regulators consider the industry viewpoint."
Another aspect of the program raising some eyebrows is the administrative fee. Current rules indicate fees must be set at a minimum of $25 a ton annually, but some states are considering even higher fees.
"With the high cost of waste disposal in general, and now adding permitting fees, we're considering ways to reduce all of our waste streams," Veach said. "Implementing a waste minimization program is a wise approach, no matter which regulations your foundry must comply with.
"...The key in business today is not merely to comply with today's standards, but to try to exceed them if it is economically feasible. Regulations will only become more stringent, so the more active foundries can be with respect to minimizing their manufacturing waste streams, the better it will be for its economic well-being."
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|Title Annotation:||Health, Safety & Environmental Issues Facing Foundries|
|Date:||Feb 1, 1993|
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