Some of the biggest management challenges facing the metals industries are driven by customers rather than regulators. Recently, Ford, General Motors and Toyota have announced that they will require their first tier suppliers to comply with the ISO 14000 standard for Environmental Management Systems. Most, if not all, metals industries have adopted environmental management practices for operating their production facilities, maintaining their control equipment, and monitoring their compliance status. However, the metals industries have not embraced a standard set of environmental management practices with the same widespread enthusiasm as the chemical industry has adopted the "Responsible Care" program.

Also, the metals industry management systems designed to demonstrate compliance with federal, state and local regulations will not necessarily satisfy the requirements of ISO 14000. The jump to ISO 14000 compliance may therefore be troublesome for many affected metals industries companies. One benefit for these companies is that most of them are already certified under ISO 9000 guidelines, and so the documentation aspects of complying with 14000 will not be entirely new.

Another new management challenge will be accounting for NOx allowances, a new form of environmental currency to be banked, bought, and traded. Similar accounting skills will be needed for facilities that accept Plantwide Emission Limits (PALs). Emission Reduction Credits (ERC) are yet another currency "earned" by curtailing an existing operation or controlling its emissions beyond regulatory requirements. ERCs are valuable commodities that can be sold to other facilities or used where generated to offset potential new emissions from plant additions/modifications. ERCs are also required for non-attainment New Source Review permitting approval.

Finally, metals industries face the removal of production bottlenecks as it affects the triggering of New Source Review-Prevention of Significant Deterioration (NSR/PSD). Much of the environmental innovation within metals industries has been directed towards relieving environmental bottlenecks (production restrictions related to environmental compliance). For example, a metals production facility is typically limited to a maximum opacity for its stack or roofline emissions. By experience (and sometimes also by permit), that plant may restrict its production rate to avoid falling out of opacity compliance. By installing new control equipment or by making the existing equipment work better, this type of restrictive bottleneck may be relieved, thus enabling an increase in production rate without exceeding any opacity limits or permit conditions.

Although this type of "de-bottlenecking" by improved environmental performance should be encouraged, the requirement for NSR/PSD permitting for the removal of bottlenecks creates a major deterrent to such control improvements. The current NSR/PSD permitting process is viewed almost universally among industries as introducing lengthy delay and uncertainty to any project. For entirely new projects, NSR/PSD review has become accepted as a normal step in the project development cycle. If the program is applied more broadly, however, as suggested by the above-mentioned recent EPA enforcement actions, it will discourage innovative environmental "de-bottlenecking" and modernization. The NSR/PSD process will likely be a major concern among metals industries for many years to come.

CONCLUSION

Although there is no single "metals industry," the companies engaged in iron, steel, and aluminum production and processing do share some common traits. They are entering the new millennium with a record of significant environmental accomplishment, but with equally significant challenges and opportunities ahead. Even if metal could be melted in a panel of solar cells and rolled in a windmill, would anyone bet on the length of the permitting process to approve it?

The past few decades have not been especially kind to the metals industries and, at least in terms of environmental issues, no relief is in sight. A squeeze play may well be developing in which U.S. industries will be facing increasingly tough standards not matched by those facing many of their competitors. The solution is not to relax standards on domestic metals industries but rather to level the playing field internationally and to encourage innovations in energy conservation, waste reduction, treatment efficiency and material management. By such innovations-many of which are already underway-the goals of improved environmental performance and enhanced profitability can converge, making metals industries sustainable, both environmentally and economically. IH

ABOUT THE AUTHOR

Joe Duckett is the Vice President for Environmental Engineering at Eichleay Engineers Inc., a Pittsburgh, PA based design and construction firm. He can be reached by phone at 412/365-3707 or e-mail at jduckett@eichleay.com.