Corporate-Wide Air Emissions Testing Partnership

Challenge
Waupaca Foundry, Inc. (WFI), operates three iron foundries in Wisconsin and additional foundries in Indiana and Tennessee. WFI excels in providing castings to a broad array of industries through constant attention to quality, innovation, collaboration and process improvements. This attention to continuous improvement results in a consistent flow of new initiatives and projects at the foundries that must be evaluated for impacts on air quality, compliance with air emission regulations and requirements for new and revised air permits. WFI strives to balance manufacturing excellence with environmental stewardship. Their numerous recognitions and awards for environmental achievement is a testament to these efforts.

The complex and interrelated nature of foundry operations offers significant challenges to demonstrate compliance with air quality requirements. The long lead time associated with air construction permits has the potential to negatively impact a foundry’s ability to implement improvements and respond to customer demands. TRC has been up to the challenge in assisting WFI in the air quality arena.

Solutions
TRC acts as an extension of WFI’s environmental staff to assist with all tasks related to air quality at WFI’s foundries around the country. TRC has maintained records of changes, precedents, air emission data and permit decisions for operations at the foundries throughout the past decades. TRC assists WFI staff almost daily to drive continuous improvement while demonstrating exemplary compliance with air quality requirements.

TRC’s air quality related assistance includes the following activities:

• Evaluation of planned capital projects and process
  modifications to assess whether air permits are
  required
• Review of new regulatory requirements to assess the
  impact on the foundries
• Prepare air construction permits (both major PSD and
  minor modifications), to obtain approval for facility
  changes and negotiations with agencies on behalf of
  WFI
• Respond to state and federal agency inquiries for
  information and documentation of compliance
• Prepare annual reports of air emissions
• Operating permit renewal applications and permit
  negotiations

Results
TRC works with WFI as an environmental partner; meaning
all results are a team effort. Recent accomplishments
include:

• Responding to USEPA Section 114 information requests
  at the three foundries. No violations have been issued
  by the agency.
• Four Title V renewal applications have been submitted,
  multiple facility modification permit applications
  prepared and issued as well as multiple permit
  applicability evaluations.
• Responding to state agency compliance inquiries with
  no violations issued and resulting agency rule
  interpretations being consistent with prior WFI
  determinations.