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Stephanie Salmon, Artemis Strategies; Jeff Hannapel & Christian Richter, The Policy Group, Washington, D.C. WASHINGTON ALERT


Thermal Sand Reclaimers Ruled Not Solid Waste Incinerators


AFTER PRESSURE FROM METALCASTERS, EPA NEGATES PREVIOUS RULING. T


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


ON THE HILL


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 www.afsinc.org. For further information, contact Stephanie Salmon, AFS Washington Office, ssalmon@afsinc.org or 202/842-4864.


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