Good Neighbor Agreement, Section Annual Report ESCO Corporation, Portland, Oregon Calendar Year 2012

Transcription

1 Good Neighbor Agreement, Section Annual Report ESCO Corporation, Portland, Oregon Calendar Year 2012 Introduction This 2012 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, 2011 (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 The past year was one of significant change for ESCO. We expanded into a new market with the purchase of Ulterra Technologies, which makes PDC drill bits for the oil and gas industry. We also sold our Turbine Technologies division, which we believed was not core to our business. We launched new products and continued to grow our direct presence in key markets which allows us to serve our customers where they do business was not without challenges. Market demands for the first half of 2012 were strong, which kept production levels comparable to However, a drop in market demand in the remainder of the year led to decreased production at the Main Plant and Plant 3 compared to Page 1 of 9

2 Summary of Air Emissions Estimated air emissions from ESCO s Portland Plants decreased in 2012 compared to This decrease in estimated emissions resulted from developments in four main categories: GNA - Emission Reduction Project Implementation There has been notable progress on many of the GNA Emission Reduction Projects, which has led to further emission reductions. Some of these emission reductions are quantifiable, while others are qualitative in nature. See the next section, Progress Update on Emission Reduction Projects for more information on these projects. Production Improvement Projects There were two production improvement projects at the Main Plant that resulted in a qualitative reduction in emissions. In September, the Fuller dust collector, which services the Main Plant Doghouse Shakeout System and the Upper Core Room Sand System, was redesigned to allow for more filter area, improved efficiency and improved capture performance. In November, two sand bins were added in the Upper Core Room. These bins vent to the Fuller dust collector. Prior to this upgrade, the emissions from the manual handling of these sand products were uncontrolled. Emission Factor Changes The new Title V Permit went into effect on March 1, 2012, which implemented new and improved emission factors in calculating estimated emissions. Many of these emission factors provide a more accurate accounting of emissions and estimate less emissions compared to previous calculations. Production Decrease Due to a more unfavorable business climate in the second half of 2012, which led to a decrease in production, emissions from both the Main Plant and Plant 3 decreased compared to Required monitoring activity was performed during the year and corrective actions resulting from this monitoring 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 a weekly, monthly and quarterly basis for the dust collectors. Finally, a third party conducts a comprehensive inspection of the dust collectors at least semi-annually. Page 2 of 9

3 Progress Update on GNA Emission Reduction Projects The following list shows the Control Strategy for each GNA Emission Reduction Project, followed by a short update on the project. If the Method of Confirmation as required by GNA - Attachment A is complete, then it is noted in the heading next to the Item #, and which indicates no further action is required: Item 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. The control solution for the Main Plant doghouse and side floor pouring/cooling/shakeout has been defined, budgeted, and approved. This project is on track to be constructed in the summer of 2013, with completion and operation by December Item 2 Control Strategy: Add control to Air Arc Cutting Lower Finishing The Main Plant, Lower Finishing Area Bay-1 Air Arc Cutting emissions were routed to the existing Bay-2 Powder Burn dust collector; this was completed March 7, Installation of an additional dust collector, the LFA Bay-2 Air Arc dust collector, was completed August 12, As the method of confirmation, the Bay-2 Air Arc dust collector dust has been weighed for six consecutive months, averaging pounds of dust collected per month of operation. NAC representatives inspected these accomplishments on January 17, NAC has requested additional information before confirming project completion. Item 3 Control Strategy: Add control to Air Arc Cutting Upper Finishing The Main Plant, Upper Finishing Area (UFA) chain table filtration unit is installed and functioning, with one month of data collected, totaling 4.4 pounds of dust. Item 4 (Complete and Confirmed) Control Strategy: Seal leaks and openings on P3 Pouring Cooling Shakeout We sealed leaks and openings in the pouring, cooling and shakeout areas, and installed additional control curtains at the cooling room. We increased our inspection frequency to semi-annually in an effort to reduce potential fugitive emissions. These maintenance inspections were performed on June 27 and December 29 last year. The cooling room enclosure is also inspected monthly as part of the monthly dust collector inspections. NAC representatives inspected these accomplishments on June 28, Item 5 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 40%. In March 2011 we initiated a Plant 3 binder review to determine if a lower free-phenol resin is available and viable. This project has the potential to substantially reduce phenol Page 3 of 9

4 emissions at Plant 3. In February 2012, a production trial using an alternative binder/resin was performed. Further trialing and testing of this alternative binder/resin is planned for summer Item 6 Control Strategy: Continue alternative binder studies, especially for chain castings. We continue our commitment to alternative binders at the Main Plant. A literature review of binders and ongoing work with vendors was the primary focus in Trials of products from current and alternative vendors are being planned for 2013 for chain castings at the Main Plant. Item 7 Control Strategy: Install bag leak detection on EAF and AOD baghouses. We have installed new programmable logic controllers (PLCs) in anticipation of bag leak detection at the Main Plant and Plant 3. These PLCs will help ESCO monitor the operation of its dust collectors. Development of our bag leak detection program software and installation of the probes is on schedule. This strategy is on track for completion by December Item 8 (Complete and Confirmed) Control Strategy: Modify operational specifications to limit door and other openings to improve capture on EAF and AOD processes. ESCO has modified its Main Plant and Plant 3 Overhead Door Plans to better address issues associated with capture at the EAFs and AOD. The overhead doors are inspected as a part of our monthly inspections. NAC representatives inspected these accomplishments on June 28, Item 9 (Complete and Confirmed) 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 for the Main Plant and Plant 3 have been reviewed and updated to optimize capture of particulate matter. The Plants trained operators in these procedures. Monthly inspections of the EAF dust collector capture systems are performed. In addition, ESCO plans to review, on an annual basis, the furnace capture systems to evaluate and optimize their continued effectiveness. NAC representatives inspected these accomplishments on January 17, Item 10 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. The bottom portion of the Plant 3 coarse fraction separator cyclone was replaced on June 16, The replaced portion has a reinforced composite coating applied to slow the internal wear. The Plant 3 thermal sand reclaim dust collector and the coarse fraction separator are inspected on a monthly basis. ESCO is designing a longer-term solution with a more robust liner, currently planned for installation in summer Page 4 of 9

5 Items 11 and 12 (Complete and Confirmed) 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 have modified operational 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, 2012, viewing the dump back and non-dump back processes. Their report estimated the emission reduction of PM emissions for both plants at 3 tons per year. NAC representatives inspected these accomplishments on June 28, Item 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. We have initiated a ventilation engineering study of the Plant 3 thermal sand reclaimer. Contingent upon the engineering findings, including air flow and temperature testing, the reclaim process may be adjusted to optimize control and flame temperature. This project is scheduled to be complete by December Item 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 Emission Reduction Projects. This project is to be completed by March 31, Item 15 (Complete and Confirmed) Control Strategy: Ensure operators use control equipment at workbench stations in finishing. Additional ventilation snorkels have been installed at Main Plant finishing workbenches. Operating procedures have been revised so operators use the snorkels and channel air from the workbenches to pollution control and capture equipment. Work Instructions are posted in these areas. NAC representatives inspected these accomplishments on June 28, Item 16 Control Strategy: Develop and implement Incident (Atypical) Investigation Plan This project is on track for completion by the due date of September Item 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 Emission Reduction Projects. Project is due to be completed in April Page 5 of 9

6 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 in place today is designed to be responsive and provide meaningful data to ESCO and the NAC. ESCO selected EthicsPoint as its provider 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. The following trends summarize air complaints received at ESCO Portland, for the calendar year ESCO Corporation received 100 complaints for the full year 2012; 96 were entered into Ethicspoint, while four were not entered into Ethicspoint as they were received prior to implementation of the complaints program on May 1, All were odor-related. Seven of the odor complaints included qualitative descriptions that also suggested potential visible emissions. The complaint investigation team reported no visible emissions during respective time periods relevant to those complaints. Based on wind direction and production schedules, odor described in 87 of the 100 complaints may have come from ESCO. Of those 87 complaints, 72 occurred at times relevant to production at ESCO s Main Plant facility, and 75 occurred at times relevant to Plant 3 production. Production may be occurring just at one facility or at both facilities at the same time. Relevant production activities are molten metal pours and refractory cures that have occurred up to two hours prior to the time of complaint; with the exception of the Main Plant Chain Room activities, which is 3 hours prior to the time of complaint. The 72 complaints that occurred at times relevant to Main Plant production are distributed among its processes; more than one area may have relevance to each complaint. (ESCO s Main Plant facility conducts pouring processes in four separate areas: the Doghouse, V-Process, Main Floor and the Chain Room. Plant 3 has a single pouring process area.): o 32 complaints occurred at times relevant to Doghouse pouring processes. o 15 complaints occurred at times relevant to V-Process pouring processes. o 14 complaints occurred at times relevant to Main Floor pouring processes. o 10 complaints occurred at times relevant to Chain Room pouring processes o 10 complaints occurred during ladle curing and other non-pouring processes. Page 6 of 9

7 No. Air Complaints The 75 complaints that occurred at times relevant to Plant 3 production are distributed among its processes: o 74 complaints occurred at times relevant to the pouring process. o 7 complaints occurred during ladle curing and other non-pouring processes. Ten complaints were made during times at which no recent plant-related activities had been performed; therefore ESCO was not likely to be the source of these odors. An additional three complaints had either unspecified or very large time periods; consequently, it is not clear whether ESCO was the source of the odor. ESCO begins investigation of each air complaint that is received 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 compile an analysis of the air complaints. The above analysis shows that the greatest potential contributors to odors are Plant 3 and the Main Plant Doghouse. These areas will be addressed by the GNA Emission Reduction Projects, with Item 1 related to the Doghouse (scheduled for completion by the end of 2013) and Item 5 related to Plant 3 (scheduled for completion early in 2015). 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 four years, 2009 through 2012, are presented in Figure 1. These data demonstrate an average year over-year reduction in complaints of 19%. Figure 2 shows the number of complaints ESCO received for investigation from DEQ or from neighbors directly. The difference in the two charts is due to the intake method for complaints and whether they were sent to ESCO by DEQ for investigation. The establishment of a new complaint process in the GNA and the renewed permit means more complaints are investigated Year Figure 1 Number of air complaints at ESCO Portland for each of the past four years, from a combination of data at DEQ and ESCO. Page 7 of 9

8 No. Air Complaints Received for Investigation Year Figure 2 Number of air complaints for each of the past four years that ESCO - Portland received to conduct an investigation. Summary of ESCO Air Permit - Events, Inspections & Enforcement Actions in Portland The following is a summary of DEQ Air Permit inspections, deviation events and enforcement actions for ESCO s Portland operations. INSPECTIONS: The State of Oregon, Department of Environmental Quality (DEQ) completed a routine Air Permit inspection at the Main Plant and Plant 3 on September 11 and 12, The DEQ physically inspected the sites and conducted a records review. A formal report summarizing the inspection is available to the public on the NAC webpage. In addition, four other DEQ staff members took part in a tour of the Main Plant on September 11, 2012, which provided education on how a foundry works and on some of the specific issues unique to a foundry that operates in an urban setting. The inspection resulted in no non-compliance findings and no follow-up actions were necessary. AIR PERMIT DEVIATIONS: ESCO submitted three Air Permit deviation reports to DEQ in 2012, which were provided to the NAC and are summarized below: 1. Letter to George Davis, from J. Carter Webb, Regarding Deviation Report Pursuant to Title V Permit (No ) Condition 84, May 3, 2012 SUMMARY: The Plant 3 coarse fraction separator installed under Attachment A, Item 10 presented many maintenance issues, primarily with the abrasion of the steel cyclone resulting in constant repairs. The purpose of the cyclone was to reduce wear on the baghouse that controls the process. ESCO staff inappropriately decided to stop using the Page 8 of 9

9 separator until a new system was engineered. There were no excess emissions because the baghouse continued to perform properly during that period. Upon realizing this was a deviation from the permit, it was placed back into operation, DEQ was notified, and a new engineering solution was developed. In response to this deviation report, DEQ issued a warning letter to ESCO. ESCO provided a progress report on May 29, 2012 describing an intermediate-term solution and plans to develop a longer-term solution, which is scheduled for installation in summer DEQ has taken no further action. 2. Letter to George Davis, from Frances Erickson, Regarding ESCO Corporation, Title V Air Permit No , Permit Deviation Reporting Slinger Bay Sand Bin Dust Collector (Equipment No ), August 9, 2012 SUMMARY: This deviation report was in response to a Main Plant electrical relay failure that allowed a process to run for a short duration without its associated dust collector. The relays were replaced and the system functioned normally afterward. This was an unforeseeable equipment malfunction. DEQ has not formally responded to the deviation report. 3. Letter to George Davis, from Frances Erickson, Regarding ESCO Corporation, Title V Air Permit No , Permit Deviation Reporting Doghouse Pouring Floor Dust Collector (Equipment No ), October 3, 2012 SUMMARY: This deviation report was in response to a breakdown of a Main Plant dust collector for the Doghouse Pouring Floor, which occurred as a result of an electrical grounding issue. ESCO failed to notify DEQ within one hour of the breakdown, and therefore deviated from the permit. DEQ has not formally responded to this event. Availability of This Report This annual report is available on the NAC webpage at Conclusion There were many improvements made to air pollution prevention equipment this past year, reducing overall air emissions. The completion of seven of the seventeen Emission Reduction Projects, within the timeframe they were due, indicates a successful year for ESCO and the Neighborhood. ESCO is on track to maintain the completed Emission Reduction Projects and to work on other projects in This includes improving capture at the Main Plant Doghouse and trialing a new low phenol binder for substitution at Plant 3. ESCO is looking forward to further improvements to air quality to achieving a goal shared with our neighbors of reducing emissions and odors. Page 9 of 9