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Voice of the Industry: in anticipation of the U.S. EPA's proposed standards regulating HAP emissions from iron and steel foundries (MACT Standards), what should a foundry do to prepare? (Shakeout).

At this point in time the official comment period on the proposed standards will have passed and the final standards should be published by late summer or early fall. Barring a delay in the imposition of the final standards due to a legal challenge, foundries covered by the rule will have to submit their compliance plans, a 112 (j) Part 2 application by October 30, 2003, to their local permitting authorities.

Knowing this, foundries should start working on gathering the information needed to complete this application. With the final standards still a few months off, companies should also let their elected officials know the costs and production impacts that these rules will have on their operations.

--Gary Mosher, Vice President--Environmental Health and Safety, AFS, Des Plaines, Illinois

If the proposed standards are approved without significant modification, every foundry should join in litigation to overturn the standard, as the proposal goes beyond the mandate U.S. EPA received in the Clean Air Act Amendments. Should these standards become the settled law of the land, major sources will have a problem complying.

In many instances of the proposed rules, it appears that there might be justification for a rule based on standards and "floors" required by the enabling legislation. However, the Agency seems to take what might have been a reasonable rule and pushed it beyond what is actually done in industry, making the proposal completely unreasonable.

--David Moyer, Plant Engineer, Advanced Cast Products, Inc., Cambridge Springs, Pennsylvania

First, a foundry should assess how the MACT could affect them in the future. The MACT could require the upgrading or replacement of several pollution control devices, which could be very expensive. An expansion or modification of a foundry could cause a different and tougher set of regulations to apply to the operation. It is best to know what these requirements will be before engineering is started.

Second, the foundry should start planning on how to evaluate its present pollution control devices that will be regulated by the MACT. Legal assistance might be required to do this since there is a chance that the data generated will show that the foundry is outside a permit condition. However, the foundry must generate this data to know what areas need to be worked on to comply with the MACT.

--Doug Linne, Environmental Coordinator, U.S. Foundry & Manufacturing Co., Medley, Florida

While some of the requirements of the Iron and Steel Foundry MACT proposed rule will probably change before it is promulgated as a final rule later this year, there are some steps that every foundry should take immediately. As a first step, each iron and steel foundry should determine if it is a major source and therefore subject to the MACT rule by developing an accurate estimate of its potential to emit HAPs. Knowing this now will provide the maximum amount of time for identifying options, selecting the best option and taking the necessary actions to comply with the requirements of the rule in a timely and cost-effective way. Major sources will be required to comply with the relatively costly requirements of the MACT rule within three years of the final rule. Therefore, evaluating the actions and costs required for compliance is essential for strategic business planning and budgeting purposes.

--Jeet Radia, Senior Vice President, Keramida Environmental, Inc., Columbus, Ohio
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Publication:Modern Casting
Date:Mar 1, 2003
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