This page contains a Flash digital edition of a book.
Stephanie Salmon, Artemis Strategies; Jeff Hannapel & Christian Richter, The Policy Group, Washington, D.C. WASHINGTON ALERT

Thermal Sand Reclaimers Ruled Not Solid Waste Incinerators


he U. S. Environmental Pro- tection Agency (EPA) issued an applicability determina-

tion in July stating the commercial and industrial sold waste incinerator (CISWI) standards do not apply to thermal sand reclamation units. The initial nonhazardous second-

ary materials rule issued in March had indicated that when metalcast- ing sand is processed, the contami- nants in the sand are being burned for discard. At that time, the in- terpretation was that the material is a solid waste and thermal sand reclamation units would be subject to CISWI standards. This result occurred despite EPA never con- sidering thermal sand reclamation units specifically in setting the 2000 or 2011 CISWI standards. The American Foundry Society

(AFS), Schaumburg, Ill., and its member companies advocated heavily for the industry with data on the increase to their operational and capital costs if these thermal sand reclaimers were considered


Crystalline Silica Remains Top OSHA Priority

The U.S. Occupational Safety and Health Administration (OSHA) recently released its 2011 spring regulatory agenda, including hearings in October for the delayed pro- posed rule for crystalline silica.“Although publication of the proposed rule is taking longer than expected, OSHA continues to work diligently with the Office of Manage- ment and Budget (OMB) and is confident that the proposed rule will be published soon,” OSHA Deputy Assistant Secretary Jordan Barab said.

OSHA submitted its proposed rule for silica to OMB in February. This is the final review before it is published in the Federal Register.

The provisions of the proposed silica rule have not yet been publicized; however, it is anticipated the agency will likely propose a 50% reduction in the permissible exposure limit to a level of 50 µg/cu. m.

House to Vote on Bills to Change the Way Government Regulates Industry

In July, the Regulatory Flexibility Improve- ments Act (H.R. 527) and the Transparency in Regulatory Analysis of Impacts on the Nation Act of 2011 (H.R. 2401) were ap- proved out of key House committees. H.R. 527 aims to improve the regulatory process for small businesses by requiring federal agencies, such as the U.S. Environmental Protection Agency (EPA), to consider the indirect impact of federal regulations,

which could lead to a more accurate assessment of a regulation’s true cost to business. The legislation would require a broader analysis of the cumulative impact of all regulations on small businesses, which could set the stage for repealing or modifying existing regulations. H.R. 2401 would create an inter- agency federal committee tasked with conducting cost-benefit analyses of 10 specific EPA regulations aimed at curbing pollutants, such as heat-trapping gases, fine particulates, ozone, sulfur dioxide and nitrogen dioxide. These studies are intended to reveal the effects of clean air rules on consumers, small businesses, state and local governments, labor markets and agriculture.

August 2011 MODERN CASTING | 19

CISWI units. AFS discussed the rule with officials from EPA’s Air, Waste and Administrator’s offices, secured a letter to the EPA administrator from five senators [Sherrod Brown-(D- Ohio), Robert Casey Jr. (D-Pa.), Carl Levin-(D-Mich.), Claire McCaskill- (D-Mo.) and Debbie Stabenow- (D-Mich.)] requesting appropriate regulatory relief for the metalcast- ing industry on this issue, met with targeted congressional offices, submitted petitions and comments to

EPA challenging the rules and interpretations, and filed legal challenges to EPA’s rules. EPA now has indicated the 2000

CISWI standards do not apply to thermal sand reclamation units because of an existing exemption for “parts reclamation units.” EPA indicated the 2011 CISWI standards do not apply because EPA did not establish standards for thermal sand reclamation units. As a result of EPA’s applicability

determination, CISWI standards do not apply to thermal sand rec- lamation units. As part of its re- consideration of the 2011 CISWI rule, EPA may decide to develop new standards for thermal sand reclamation units. Any such future standards are expected to be based on emissions and performance data from thermal sand reclamation units.

Thermally reclaimed sand (bottom), shown with new sand (left) and used sand (right) is no longer considered a solid waste.

A copy of the applicability determination is available at For further information, contact Stephanie Salmon, AFS Washington Office, or 202/842-4864.

Page 1  |  Page 2  |  Page 3  |  Page 4  |  Page 5  |  Page 6  |  Page 7  |  Page 8  |  Page 9  |  Page 10  |  Page 11  |  Page 12  |  Page 13  |  Page 14  |  Page 15  |  Page 16  |  Page 17  |  Page 18  |  Page 19  |  Page 20  |  Page 21  |  Page 22  |  Page 23  |  Page 24  |  Page 25  |  Page 26  |  Page 27  |  Page 28  |  Page 29  |  Page 30  |  Page 31  |  Page 32  |  Page 33  |  Page 34  |  Page 35  |  Page 36  |  Page 37  |  Page 38  |  Page 39  |  Page 40  |  Page 41  |  Page 42  |  Page 43  |  Page 44  |  Page 45  |  Page 46  |  Page 47  |  Page 48  |  Page 49  |  Page 50  |  Page 51  |  Page 52  |  Page 53  |  Page 54  |  Page 55  |  Page 56  |  Page 57  |  Page 58  |  Page 59  |  Page 60  |  Page 61  |  Page 62  |  Page 63  |  Page 64  |  Page 65  |  Page 66  |  Page 67  |  Page 68