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Stephanie Salmon, Artemis Strategies; Jeff Hannapel & Christian Richter, The Policy Group, Washington, D.C. WASHINGTON ALERT Thermal Reclamation Labeled Solid Waste Incineration


EPA CONCLUDED THAT CASTING SAND PROCESSED IN THERMAL RECLAMATION UNITS SHOULD BE SUBJECT TO NEW INCINERATOR STANDARDS.


(EPA) identified certain non-hazardous secondary materials that are solid waste when combusted, including casting sand processed in thermal reclamation units. Te identification in the Non-Hazard- ous Secondary Materials as Solid Waste rule provided that thermal reclama- tion units used to process metalcasting sand would be subject to new source performance standards for commercial and industrial solid waste incinerators pursuant to section 129 of the Clean Air Act (CAA), which was also published on March 21. EPA acknowledged that nothing


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in this new rule changes its existing “point of generation” position that cast- ing sands reused onsite in the primary production process on a continuous basis in the sand loop are not solid wastes. While reinforcing this point, EPA said it was not addressing the sta- tus of any thermal processing of sand. However, in the preamble to the


Non-Hazardous Secondary Materials as Solid Waste rule, EPA states “that the purpose of ‘processing’ foundry sand in a thermal reclamation unit is to destroy or dispose of the contaminants so that the foundry sand can be reused. As


ON THE HILL


House Passes Bill Blocking EPA Climate Regulations


On April 7, the U.S. House of Representatives approved the Energy Tax Prevention Act of 2011 (H.R. 910) in a 255-172 vote. The bill would stop the U.S. Environmental Protection Agency (EPA) from regulating greenhouse gases for stationary sources. EPA’s efforts to regulate carbon dioxide and other greenhouse gases have been controversial since the agency decided in 2009


the emissions posed a threat to human health, creating the foundation for several rule changes. Passage of the House bill comes on the heels of the U.S. Senate rejecting four amend- ments to small-business legislation that would have blocked or limited EPA climate rules.


Republican lawmakers likely will make further attempts to restrict the activities of EPA in the 2012 appro- priations bills and hold additional hearings in the weeks and months ahead on the impact of other current


and upcoming EPA regulations on manufacturers.


President Repeals 1099 Reporting Requirements On April 14, President Obama signed the Comprehensive 1099 Taxpayer Protection and Repayment of Exchange Subsidy Overpayments Act of 2011 (H.R. 4), which repeals the requirement from last year’s health care reform law that manufacturers and suppliers submit a Form 1099 for pay- ments made to a single vendor for goods and services that total more than $600 in a taxable year, beginning in 2012.


May 2011 MODERN CASTING | 19


n a final rule published in the Fed- eral Register on March 21, the U.S. Environmental Protection Agency


such, the burning of foundry sand in a thermal reclamation unit is burning for discard and, thus, would be considered a solid waste if combusted in such a unit, which would be subject to the section 129 CAA standards.” According to industry advocates,


casting sand thermal reclamation units are not solid waste incineration units and should not be regulated as such. Te American Foundry Society (AFS) submitted comments on the proposed rule arguing casting sand should not be


classified as a solid waste when reused in a metalcasting facility or used as an ingredient in a combustion unit, so long as it was not discarded in the first instance and satisfies the legitimacy criteria for ingredients. AFS claims EPA’s finding appears to be inconsis- tent with its own positions regarding the reclamation of other non-hazard- ous secondary materials.


Contact Jeff Hannapel, AFS Washington Office, at jhannapel@thepolicygroup.com for more informa- tion regarding the new regulation.


According to industry advocates, the EPA finding could thwart efforts to reuse sand within metalcast- ing facilities.


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