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System audits take pain out of Clean Air Act compliance.

Auditing your pollution control system can help reduce cost and liability while meeting federal requirements.

In the age of reduced plant engineering staffs, keeping sophisticated production systems "up to snuff" needs to take priority over pollution control. Many existing systems won't meet the new requirements without major overhauls or upgrades.

Like it or not, the Clean Air Act (CAA) amendments of 1990 are going to make performance of those unglamorous pollution control systems a serious issue for foundrymen.

In some cases, original system design parameters simply don't meet today's standards. Many systems haven't been maintained for proper performance, and plant ventilation equipment is often abused or poorly maintained. It's common for a system to pull only half of its original design flow because of lack of maintenance or "field expedient" modifications.

A system audit--before enforcement officials arrive at the door--can help sort out the problems and provide:

* accurate baseline of defensible performance data;

* an opportunity to correct immediate deficiencies before incurring penalties;

* more information and time for planning response and control strategies;

* room to explore cost-effective alternatives rather than risking mandated fixes to meet deadlines;

* dedicated expertise in air pollution control, allowing plant engineers to concentrate on competitive factors such as raising output, flexibility and quality.

Looking Toward Tomorrow

Although the 1977 CAA significantly improved air quality, the urban air pollution problems of ozone, carbon monoxide and PM-10 (particulate matter 10 microns or smaller) continue to grow. About 25 million people live in areas that don't meet the PM-10 standard, while 100 million live in areas not meeting the ozone standard.

The CAA amendments of 1990 clarify how the EPA designates localities as "attainment" or "nonattainment" areas, hinging on whether federal air standards are met. Depending on the classification as "moderate" or "serious," areas exceeding the particulate matter standard may have to implement reasonably available control technology (RACT) or best available control technology (BACT), among other requirements.

The CAA also calls for establishing a national permit program to make the act more workable, as well as an improved enforcement program to ensure compliance. Each "major source" (over 100 tons per year) will be required to have a fixed-term operating permit that outlines compliance requirements.

Many specific regulations remain to be drafted. When they are final, many foundries will find themselves attempting to meet codes with systems that won't comply. Much of the equipment in the field was installed because of the 1970 CAA. This equipment, however, may be unable to meet the more stringent requirements of this era.

For example, a small airstream component once considered insignificant by the EPA--such as the volatile organic compounds in foundry exhaust--can't be controlled with a baghouse and now falls under the regulations. More often, equipment has simply not been maintained, or a pollution control system has been "added on to," resulting in reduced flows and pressures at capture points.

Tasks of Auditing

Some foundries may decide to hire environmental engineering firms to audit their air pollution systems. An audit puts the system under a microscope, the same way most owners would if they had the internal resources. Cost is low, compared with potential liability, and it shows a good-faith effort to comply.

An audit encompasses several phases and covers the system from source to final discharge. The results can affect interior plant air quality and process discharge air quality, influencing compliance with both OSHA and EPA regulations.

A typical audit consists of two steps: field research and evaluation.

Under the field research phase, officials begin by obtaining original system design data if available. They then walk through the system, talk to process operators and maintenance staff, determine process variables and examine the system's physical condition. After doing so, tests are conducted to provide accurate fan rpm/amperage, temperatures, velocities, flows, static pressure readings and other useful data.

The second step of the audit is evaluation, which includes recommendations for the system. Officials develop single-line drawings if needed and prepare a report on system design capability and actual performance. They provide the company with recommendations rated for cost-effectiveness to improve performance to its desired level. Concerns such as maintenance, engineering and process changes are addressed in detail.

Stack testing may be needed as a complement to an audit. Stack tests include determining particulate emissions and particle size distribution, sulphur oxides, nitrogen oxides, volatiles organic compounds, metals, acid gases, air toxics and other pollutants. Tests should be conducted in accordance with EPA reference methods.

After an audit, changes in the pollution control system can be designed by the engineering firm. After implementation of these changes, the system should be audited on a periodic basis.

An 'Outside' Eye

Performance evaluations conducted by an independent party offer several advantages. Audits are performed by trained people who know the regulations and control technologies. They have specialized equipment and work to a schedule. Problems can be discovered while they are small and more manageable, making budgeting for improvements and replacements less of a surprise.

Auditors offer consistent evaluation that isn't possible otherwise, since maintenance people often rotate responsibilities, leaving no one individual working on the system long enough to notice trends. Auditing also allows owners to meet codes for minimal expenses and ensures efficient, low-cost operation of the system.

When hiring an auditing firm, look for one that is certified by organizations such as the National Environment Balancing Bureau. By selecting a certified auditor, you can be confident of the validity of air flow studies and balancing recommendations.

Whether applied to multiple systems and plants or a single dust collector or scrubber, an audit prescribes good preventive medicine for minimizing the cost and liability associated with CAA '90 compliance.

Audits Not Only Find What's Wrong, But Also What's Right

Contrary to popular belief, audits don't always bring the kind of news that make foundry managers pull out their hair. Professional auditors can also provide reinforcement that foundries are meeting CAA standards or offer small suggestions to improve.

A recent audit for a multi-plant operation of a Fortune 250 company demonstrates just how inefficient pollution control programs can become. The plant's owner commissioned a firm to find the baseline capability of all available systems and determine the best means to comply with OSHA and EPA regulations. More than 200 dust control systems were involved, some over 40 years old. Contaminants in the airstream included carbon black and high-alumina and silica dusts.

An inventory of available equipment, its performance evaluation and a thorough analysis of emissions gave the owner great latitude in meeting codes.

Auditors discovered most existing equipment could continue in-service with modifications and rerouting. A few systems were unnecessary at their existing locations and could be relocated, while some abandoned systems could be brought back into service at a low cost. In this case, very little new equipment was required to meet the codes.
COPYRIGHT 1992 American Foundry Society, Inc.
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 1992, Gale Group. All rights reserved. Gale Group is a Thomson Corporation Company.

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Title Annotation:includes related article; pollution control system evaluation
Author:Mayne, Robert J., Jr.
Publication:Modern Casting
Date:Sep 1, 1992
Words:1135
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