Good Neighbor Agreement, Section Annual Report ESCO Corporation, Portland, Oregon Calendar Year 2013

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1 Good Neighbor Agreement, Section Annual Report ESCO Corporation, Portland, Oregon Calendar Year Introduction This Annual Report has been prepared by ESCO Corporation (ESCO) for the Neighborhood Advisory Committee (NAC), in accordance with Section of the Good Neighbor Agreement effective November 22, 211 (GNA): Annual Report. At least once each year, ESCO shall provide the complaint log described in paragraph 5.4 for NAC review, and present an annual report at a regular NAC meeting. The annual report shall include: a) General summary of the state of ESCO s business, including a qualitative assessment of its success and challenges as an on-going business. b) Report on air emissions, monitoring activity, and excess emissions events during the preceding year, including a copy of any reports provided to Neighbor Groups pursuant to paragraph 2 of this Agreement. c) Summary of complaints received and how complaints were resolved. d) Summary of any inspections or enforcement actions by DEQ or EPA during the preceding year and ESCO s corrective action as needed. e) The annual report shall be made available to the public on the NAC webpage described in paragraph Corporate Overview ESCO celebrated 1 years in July, with several events across the globe and in Portland to commemorate this achievement. Though 1 years strong, change continued to be a theme in, as ESCO reorganized its business structure into three functional groups that serve distinct industry segments: Mining, Construction and Industrial, and Oil and Gas. This allows better focus on customer needs and strategically growing our business. ESCO also completed the construction of a state-of-the-art Innovation Center in Portland in December, where engineers explore new technical opportunities and product designs that address our customers challenging long-term needs. In, ESCO employed 4,7 people worldwide. Market demand continued at similar levels to those in the second half of, which was reduced in comparison to ESCO purchases goods and services from hundreds of Oregon-based businesses and supports more than a dozen jobs in the state for every ten jobs at ESCO.

2 Calendar Year Summary of Air Emissions Emissions from ESCO s Portland plants were reduced in compared to. This decrease in emissions is explained by three main factors: Reduced Production Due to market conditions, production at the Main Plant and Plant 3 continued at a similar rate to the second half of. Because emission calculations are largely dependent upon the tons of metal poured, emissions from the Main Plant and Plant 3 were reduced compared to. Construction Projects and Process Improvements There were three construction projects at the Main Plant that resulted in a reduction in emissions. In May, a lime silo used with the Argon Oxygen Decarburization (AOD) process was connected to dust collection to minimize dust when the tank is filled weekly. A new spray gun is being used in the Upper Core Room (UCR) for the application of core wash. The new high volume, low pressure (HVLP) gun replaced a conventional compressed air spray gun. The HVLP gun has significantly reduced overspray, minimizing waste of core wash and reducing emissions. A dust collector was reconstructed and connected to welding stations used in fabrication support services, capturing the categorically insignificant process emissions. Good Neighbor Agreement - Attachment A Project Implementation There has been notable progress on many of the Attachment A projects leading to further emission reductions. Some reductions are quantifiable while others are more qualitative, and a status report on all Attachment A projects is included. As of December, two dust collectors are operating to improve capture and control of Doghouse Pouring-Cooling-Shakeout emissions. One collector captures emissions from the pouring floor, while the other captures emissions from the shakeout-unload table. This is discussed in more detail in the next section. In July, Plant 3 converted to a lower phenol binder system. This system was tested in August, and the calculated reduction of emissions per the method specified in the permit was 7.5%. The permit requirement of at least a 35-4% reduction has been met. This is a great accomplishment to significantly reduce emissions without adversely affecting operations. Page 2 of 12

3 Calendar Year Bag leak detection probes have been installed on the Main Plant Electric Arc Furnace (EAF) dust collector, AOD dust collector, Plant 3 EAF dust collectors, and Plant 3 Pouring-Cooling-Shakeout dust collector. The probes have been calibrated and are operational as of December. The probes provide early detection of filter wear and prevent failures that result in particulate emissions. ESCO performed required monitoring activity during the year, and resulting corrective actions were completed. ESCO staff performs monthly inspections at the Portland sites, which include monitoring for visible emissions from dust collectors, building openings and vents. If there are items that need attention, corrective actions are undertaken on an expedited basis. Also, ESCO performs preventive maintenance work on the dust collectors weekly, monthly and semiannually. Finally, a third party conducts a comprehensive inspection of the dust collectors at least semi-annually. Progress Update on GNA Emission Reduction Projects The following list shows the Control Strategy for each Emission Reduction Project, followed by a short update on the project. If the Method of Confirmation is complete, then it is noted in the heading next to the item number, indicating no further action is required: Project 1 Control Strategy: Improve capture and control of Doghouse and Side Floor PCS fugitives. Ensure cooling in the Doghouse occurs in the controlled section of the building. Two dust collectors have been installed and are operational to improve capture and control of Doghouse Pouring-Cooling-Shakeout emissions. One collector captures emissions from the pouring floor, while the other captures emissions from the shakeoutunload table. The collectors were tested in January 214, with results sent to DEQ in March. Upon DEQ approval of the source tests, the reports will be shared with the NAC. The dust captured by each collector was weighed for at least one month and correlated to tons of metal poured. Results are shown in the table below: Shakeout-Unload Start Date End Date Weight of dust Tons of Metal (lbs) Poured lbs/tmp 12/2/ 1/29/ /3/214 2/25/ Average 5.75 Pouring Loop Start Date End Date Weight of dust Tons of Metal (lbs) Poured lbs/tmp 12/2/ 3/14/ Page 3 of 12

4 Calendar Year Project 2 - Complete Control Strategy: Add control to Air Arc Cutting Lower Finishing The Main Plant, Lower Finishing Area (LFA) Bay-1 Air Arc Cutting emissions were routed to the existing Bay-2 Powder Burn dust collector; this was completed March 7, 211. Installation of an additional dust collector, the LFA Bay-2 Air Arc dust collector, was completed August 12, 211. As the method of confirmation, the Bay-2 Air Arc dust collector dust was weighed for six consecutive months, averaging 5-6 pounds of dust collected per month of operation. Project 3 - Complete Control Strategy: Add control to Air Arc Cutting Upper Finishing The Main Plant, Upper Finishing Area (UFA) chain table filtration unit is functioning. For the method of confirmation, one month of data was collected, totaling 4.4 pounds of dust. Project 4 - Complete Control Strategy: Seal leaks and openings on P3 Pouring Cooling Shakeout In the Plant 3 cooling room, pouring and shakeout areas, we increased our inspection frequency by ESCO maintenance personnel to semi-annually in an effort to reduce potential fugitive emissions. The cooling room enclosure is also inspected monthly. Project 5 - Complete Control Strategy: Elect either a. or b. a. Install thermal oxidation or alternative control technology on sand coating pug mill. b. Substitute a low phenol binder system for the binder system on which the phenol emissions factors in the Title V Permit are based. The new low phenol binder system will achieve a combined reduction in phenol emissions from all Plant 3 sources of at least 35 to 4%. In July, Plant 3 converted to a lower phenol binder system. This system was tested in August, and the calculated reduction of emissions per the method specified in the permit was 7.5%. The permit requirement of at least a 35-4% reduction has been met. Project 6 Control Strategy: Continue alternative binder studies, especially for chain castings. We continue our commitment to alternative binders at the Main Plant and conducted several trials in the second half of. We tested two poly-urethane no-bake binder alternatives as well as a sodium silicate binder. All of the trialed binders had some benefits of reduced emissions and lower odor. Prior to making any binder changes we must assess the quality of the castings produced, cost of the products, and the impact to our production processes to determine whether they are viable alternatives. Page 4 of 12

5 Calendar Year Project 7 - Complete Control Strategy: Install bag leak detection on EAF and AOD baghouses. We have installed bag leak detection probes. The Main Plant Electric Arc Furnace (EAF) dust collector, AOD dust collector, Plant 3 EAF dust collectors and Plant 3 Pouring- Cooling-Shakeout dust collector all have probes installed and operational. The alarm settings and response procedures have been added to the Air Emission Control Device Operating Plan. Project 8 - Complete Control Strategy: Modify operational specifications to limit door and other openings to improve capture on EAF and AOD processes. ESCO modified its Overhead Door Plan to better address issues associated with capture at the EAFs and AOD process. Project 9 - Complete Control Strategy: Add/improve procedures on EAF operations that directly affect capture. Evaluate additional control mechanisms for EAF capture systems and high canopy hood dampers. Optimize operating procedures and provide routine training. The EAF operating procedures were reviewed and updated to optimize capture of particulate matter. Project 1 - Complete Control Strategy: Take corrective actions to reduce fugitives on thermal sand reclaim baghouse by installing course fraction separator to improve collection and reduce wear on baghouse. We installed a coarse fraction separator in January 211 to reduce wear on the thermal sand reclaim baghouse filters. Due to wear in the bottom portion of the cyclone, it was replaced in-kind in June. We then designed a longer-term solution, which included a 1 ceramic liner and this was installed in July. The Plant 3 thermal sand reclaim dust collector and the coarse fraction separator are inspected per the permit by ESCO staff. Projects 11 and 12 - Complete Control Strategy: Identify and implement operating changes to reduce emissions at dump back and transfer points. The production teams at the Main Plant and Plant 3 modified their procedures to reduce the use of the dump back processes at both plants. Jim Karas and Fred Tanaka visited both Plants on June 28 and 29,, viewing the dump back process in use as well as progress in reducing the use of the dump back process. A report was prepared to recap their visit. Project 13 Control Strategy: Conduct study to quantify emissions from thermal sand reclaim and to determine if thermal sand reclaim can be operated at recommended temperature. Page 5 of 12

6 Calendar Year The engineering study continues to determine if modifications are necessary for the Plant 3 thermal sand reclaimer to operate at the recommended temperature. This project is scheduled to be complete by December 214. Project 14 Control Strategy: Modify operations at the AOD to improve capture. Work on the Main Plant AOD capture efficiency has been on hold, due to the volume of work associated with other Attachment A projects. This project is to be completed by March 31, 215. Project 15 - Complete Control Strategy: Ensure operators use control equipment at workbench stations in finishing. Additional ventilation snorkels were installed at workbenches. Operating procedures were revised so operators are required to use the snorkels and channel air from the workbenches to pollution control and capture equipment. Work Instructions are posted in these areas. Project 16 Control Strategy: Develop and implement Incident (Atypical) Investigation Plan This project is on track for completion by the due date of September 214. Project 17 Control Strategy: Perform an engineering study of feasible capture and control methods for emissions from pour points in slinger bay, including estimates of potential reductions. Alternatively, ESCO may propose a different study or emission reduction project, which it shall implement instead of the slinger bay study, if approved by the NAC. Work on the Main Plant slinger bay engineering study is on hold, due to the volume of work associated with other Attachment A projects. Project is due to be completed in April 217. Summary of Portland Air Complaints ESCO began using a formal complaints process through EthicsPoint, also known as the ESCO Environmental Hotline, on May 1,. The process is designed to be responsive and provide meaningful data to ESCO and the NAC. ESCO selected EthicsPoint to address the following key objectives: 1. Neighbors with an ESCO-specific environmental concern should communicate with a live person, through either phone conversation or submission of information to a website, 24 hours per day, seven days per week. 2. The data collected should provide the NAC with useful information. 3. The data collected should provide ESCO with information that helps identify and resolve environmental concerns. Page 6 of 12

7 Calendar Year The following trends summarize complaints received via EthicsPoint during. ESCO received 55 complaints for ; all were entered into Ethicspoint. All were odor-related. Based on wind direction and production schedules, odor described in 45 of the 55 complaints may have come from ESCO. The other ten complaints were likely not related to ESCO activities, or there was insufficient information provided; so they are not included in further analysis. o Six complaints were made during times at which no recent plant-related activity was occurring. o One complaint was made at a time when the wind direction was such that the complainant s location was not downwind of ESCO. o One complaint, during follow-up communication with ESCO s Community Relations, described odor not related to ESCO processes. o Two complaints had unspecified times; it is not clear whether ESCO was the source of the odor. Relevant production activities are molten metal pours and refractory cures that occurred up to two hours prior to the time of complaint, and three hours for pouring in the Main Plant Chain Room. Of those 45 complaints, 38 occurred at times relevant to production at ESCO s Main Plant facility. The facility pours in four separate areas: the Doghouse, V-Process, Main Floor, and the Chain Room. The complaints are distributed among these processes; more than one area may have relevance to each complaint. o 16 complaints occurred at times relevant to Doghouse pouring processes. o 7 complaints occurred at time relevant to Main Floor pouring processes. o 7 complaints occurred at times relevant to V-Process pouring processes. o 3 complaints occurred at times relevant to Chain Room pouring processes. o 7 complaints occurred during ladle curing and other non-pouring processes. Of those 45 complaints, 31 occurred at times relevant to Plant 3 production. Production may have occurred at both Main Plant and Plant 3 at the same time, so there is overlap between potential sources. After receiving an air complaint, ESCO begins investigation within one business day of receipt and completes the investigation within five business days, or within such longer time as is reasonably necessary. The investigations provide the information used to analyze the air complaints. The above analysis shows that the greatest potential contributors to odors are Plant 3 and the Main Plant Doghouse. These areas are already addressed in the GNA, Attachment A, with Item 1 related to the Doghouse and Item 5 related to Plant 3. The completion of these projects is intended to reduce both emissions and odors. The known air complaint totals for ESCO in Portland over the previous five years, 29 through, are presented in Figure 1. These data demonstrate a 26% average year over-year reduction in complaints. Figure 2 gives the total complaints for each quarter since ESCO began Page 7 of 12

8 Calendar Year using its Environmental Hotline. The number of complaints that may have been relevant to production at the Main Plant and Plant 3 is also provided # Complaints Year Figure 1: Annual air complaints at ESCO Portland since 29. Data based on combined records from DEQ and ESCO. On May 1,, a new complaint process was launched. The process considers specific pouring processes and their potential contribution to odor. Page 8 of 12

9 Calendar Year 8 # Complaints Received Complaints Relevant to Main Plant Production Relevant to Plant 3 Production Unlikely/Indeterminate 2 1 Q1 Year & Quarter Figure 2: Quarterly odor complaints by relevancy of occurrence time to production activities at Main Plant and Plant 3. On May 1,, a new complaint process was launched. The process considers specific pouring processes and their potential contribution to odor. Odor complaints relevant to Main Plant production are distributed among five processes. Figure 3 shows that distribution since ESCO began using its Environmental Hotline. Page 9 of 12

10 Calendar Year 6 Plant 3 25 Doghouse # of Complaints Note: Plant 3 data on different scale than Main Plant # of Complaints Q1 Q1 25 Main Floor 25 V-Process # of Comlpaints # of Complaints Q1 Q1 25 MP Ladles/Cures 25 Chain Room # of Complaints # of Complaints Q1 Q1 Figure 3: Quarterly odor complaints by relevancy of occurrence time to production activities. On May 1,, a new complaint process was launched. The process considers specific pouring processes and their potential contribution to odor. Page 1 of 12

11 Calendar Year Summary of ESCO Air Permit - Events, Inspections & Enforcement Actions in Portland The following is a summary of DEQ Air Permit deviation events and enforcement actions for ESCO s Portland operations. ESCO submitted three Air Permit deviation reports to DEQ in, which were provided to the NAC and are summarized below. Two of these were related to the same area and resulted in an enforcement action, which is also summarized below. 1. Letter to George Davis, from Fran Erickson, Regarding ESCO Title V Permit No , Permit Deviation Reporting Doghouse Pouring Floor Dust Collector (Equipment No. 3111) January 22, SUMMARY: The Doghouse pouring floor dust collector controls were inadvertently reset during maintenance work. The default settings upon startup the next morning resulted in the dust collector shutting down during pouring operations, without operators noticing. The control system was modified to prevent a similar event. 2. Letter to George Davis, from Allan Wedderburn, Regarding ESCO Corporation, Title V Air Permit No , Permit Deviation Reporting Main Plant, Building 15, Lime Silo Connection to AOD Dust Collector (Equipment Number 3125), May 31, SUMMARY: A vent line on a lime silo in the Slinger Bay was connected into an existing dust collector without notification to DEQ. This project reduced overall emissions from the process, but notification should have been made prior. 3. Letter to George Davis, from Jay Fagan, Regarding ESCO Corporation, Title V Air Permit No , Permit Deviation Reporting Main Plant, Doghouse Pouring Floor Dust Collector (Equipment No. 3111), July 15, SUMMARY: The Doghouse pouring floor dust collector was inadvertently turned off using a fan-stop button, and it went unnoticed the following morning when operations began. A new control system was implemented to prevent a recurrence. 4. Letter to Leah K. Feldon, from Jay Fagan, Regarding Notice of Civil Penalty Assessment and Order; Case No. AQ/V-NWR-13-15, October 25, SUMMARY: In response to the deviation reports regarding the Doghouse pouring floor dust collector, DEQ issued a Civil Penalty Assessment for $22. ESCO paid the full penalty and responded with a summary of corrective actions implemented to prevent recurrence. Availability of This Report This annual report is available on the NAC webpage at Page 11 of 12

12 Calendar Year Conclusion There were many improvements made to air pollution prevention equipment this past year, reducing overall air emissions. The completion of ten of the seventeen Attachment A projects, within the timeframe they were due, with one ongoing project and another waiting DEQ approval, indicates a successful year for ESCO and the neighborhood. Page 12 of 12