NFFS, AFS in Cooperation with EPA on Area-Source Rule
Voluntary data-collection effort addressed at nonferrous foundries
Voluntary data-collection effort addressed at nonferrous foundries
The Non-Ferrous Founders’ Society and the American Foundry Society have agreed to cooperate with U.S. Environmental Protection Agency to develop new area-source rules for Hazardous Air Pollutant (HAP) emissions for Aluminum, Copper, and Other Nonferrous Foundries (non- diecasting.) EPA is under a deadline, set by a federal court, to issue new area-source rules for HAP emissions from 54 industry sectors by June 30, 2009.
EPA must draft a proposed rule by January 2009. To prepare the draft and support the rule, it needs to collect production and HAP emissions data from foundries. However, federal law (the Paperwork Reduction Act) limits the number of data questionnaires EPA can send to foundries: it can send just nine questionnaires to each of the 54 industry sectors; these must be answered voluntarily.
NFFS and AFS are providing additional, supplemental data on nonferrous foundries to EPA, for its information and consideration. Two survey forms have been posted online by the associations to collect the information voluntarily (visit NFFS and AFS for copies of the surveys.) One form concerns aluminum foundries, while the other address for copper-alloy and other nonferrous metal foundries (e.g., magnesium, titanium, zinc, lead, nickel-base and beryllium-base alloys.)
“Our goal in doing this is two-fold,” NFFS explained in a statement. “First, we want to assure that any rule issued by the EPA is based upon a complete analysis of the HAP emissions emanating from nonferrous foundries. Second, we hope to limit as much as possible the imposition of needless or contra-competitive costs and paperwork burdens on foundries by insuring that EPA’s new rule recognizes the practices and controls already in place and the positive effect those have had in reducing HAP emissions from the industry.”
NFFS and AFS plan to submit the collected data to EPA as a composite report.
Participation in the survey is voluntary. Facilities will not be identified by name or location, and no monitoring or emissions testing is required to respond.
“NFFS and AFS strongly urge your cooperation so we can achieve our objectives of offering EPA a general assessment of the industry for their rulemaking effort, and effectively representing the concerns and interests of copper and other nonferrous foundries that may be covered by EPA’s proposed area source rule,” the groups stated.
EPA must draft a proposed rule by January 2009. To prepare the draft and support the rule, it needs to collect production and HAP emissions data from foundries. However, federal law (the Paperwork Reduction Act) limits the number of data questionnaires EPA can send to foundries: it can send just nine questionnaires to each of the 54 industry sectors; these must be answered voluntarily.
NFFS and AFS are providing additional, supplemental data on nonferrous foundries to EPA, for its information and consideration. Two survey forms have been posted online by the associations to collect the information voluntarily (visit NFFS and AFS for copies of the surveys.) One form concerns aluminum foundries, while the other address for copper-alloy and other nonferrous metal foundries (e.g., magnesium, titanium, zinc, lead, nickel-base and beryllium-base alloys.)
“Our goal in doing this is two-fold,” NFFS explained in a statement. “First, we want to assure that any rule issued by the EPA is based upon a complete analysis of the HAP emissions emanating from nonferrous foundries. Second, we hope to limit as much as possible the imposition of needless or contra-competitive costs and paperwork burdens on foundries by insuring that EPA’s new rule recognizes the practices and controls already in place and the positive effect those have had in reducing HAP emissions from the industry.”
NFFS and AFS plan to submit the collected data to EPA as a composite report.
Participation in the survey is voluntary. Facilities will not be identified by name or location, and no monitoring or emissions testing is required to respond.
“NFFS and AFS strongly urge your cooperation so we can achieve our objectives of offering EPA a general assessment of the industry for their rulemaking effort, and effectively representing the concerns and interests of copper and other nonferrous foundries that may be covered by EPA’s proposed area source rule,” the groups stated.
