AFS - EH&S Issues 2008
The American Foundry Society (AFS) assists members with issues related to production, marketing, human resources and regulatory compliance. AFS hosts several meetings each year to promote the interchange of information among members. This column covers EPA-related topics, and next month’s column will discuss OSHA-related topics from the August 2008 meeting.
Greenhouse Gases:Not unexpectedly, the topic of greatest interest was greenhouse gases (GHG). Because energy is so fundamental to the metalcasting industry, AFS prepared a white paper on GHG entitled “Climate Change Principles,” which can be found on their website (www.afsinc.org). At the outset, the white paper asserts that U.S. metalcasters have already implemented many energy- and waste-saving processes, which collectively help them emit up to two-thirds less GHG per ton of castings shipped than competing metalcasters in China, India or Brazil. The white paper also noted a recent surge in castings produced for the renewable-energy market, including wind-turbine blades, geothermal pump casings and solar heat-exchanger components, which position the industry as an important player in the mission to reduce atmospheric GHG.
With regard to new regulations, AFS supports a nationwide program that preempts state climate-change laws, includes all sectors of the economy and recognizes the importance of carbon capture and sequestration. Finally, the white paper concludes that energy requirements based on the physical and chemical realities (thermodynamic laws) of melting metal should be exempt from regulatory GHG limits as should emissions related to the use of metallurgical coke.
CO2 Reporting:Although Congress did not pass S 2191 (Lieberman-Warner Climate Security Act of 2007) in the current term, this legislation is considered as the leading proposal on GHG regulation. Until enacted, the final makeup of the law cannot be anticipated with certainty. There is, however, virtually no doubt that CO2 reporting will be a hallmark of any new legislation. Several states (California, Oregon and Iowa were mentioned) have already set timetables for implementing such reporting requirements, with fuel-use accounting expected to be the most likely reporting method.
Foundry MACT:Modifications to the 2004 MACT standard for ferrous foundries (40 CFR Part 63, Subpart EEEEE) were published in February 2008. Among these are new opacity limits (20%) for fugitive emissions from buildings with foundry processes, new leak-detection requirements for baghouses and a change in the method of determining “total metal HAP,” including a new manner of counting non-detects and the identification of 11 metals that comprise the HAP total: antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel and selenium.
Attendees were advised of the January 2009 deadline to report their 2008 metal melt production to the EPA as the basis for initial size classification. Under the new MACT rule, existing iron and steel foundries with annual metal melt production of 20,000 tons or less are considered “small area source foundries” and those with greater than 20,000 tons are considered “large area source foundries,” with different rules applied to each class.
EPA also completed several new standards for ancillary metal fabrication processes in 2008. These include “Area Source Iron & Steel Foundry MACT,” “Area Source Surface Coating,” “Area Source Plating & Polishing” and “Area Source Metal Fabrication and Finishing.”
Magnesium Production:The International Magnesium Association has entered into a voluntary agreement with the EPA to eliminate the use of sulfur hexafluoride (SF6) – a potent GHG – from magnesium production and casting operations by 2010. Some U.S. manufacturers have proposed SF6 capture and recycling as an alternate option for reducing these emissions.
Lead NAAQS:AFS staff reported that the National Ambient Air Quality Standard (NAAQS) for lead (Pb) is likely to be revised downward from 1.5 µg/m3 to approximately 0.2 µg/m3. Also proposed are an increase in sampling frequency from a 1-in-6 format (one 24-hour sample taken every six days) to a 1-in-3 format and a decrease in averaging time from one calendar quarter to one month. Public commenting on the proposed rulemaking ended recently, with final rulemaking expected by October 15, 2008. This change could impact facilities with Pb air emissions that are currently in compliance with applicable regulations but might be at risk for exceeding the new ambient threshold at the facility’s fenceline under the new rules.IH