        April 28, 2015 
RLDWA Meeting with the American Foundry Society
Attendees
 American Foundry Society: Jerry Call, Steve Robison, Stephanie Salmon 
 EPA: Brian D'Amico, Erik Helm, Jeff Kempic
 Cadmus: Laura Dufresne, Anne Jaffe Murray
 Neptune Technology Group: Jim Valentine
 Mueller Co: Steve Crawford, Christy McEldowney, Dave Woollums
 A Y McDonald: Steve Tefft
 Ford Meter Box: Mike Jones
Meeting Purpose
The American Foundry Society (AFS) and manufacturers from the metalcasting industry met with EPA on April 28, 2015. The meeting purpose was to obtain input to refine costs estimates for the Agency's regulation, which clarifies the requirements of the Reduction of Lead in Drinking Water Act (RLDWA).
EPA RLDWA Rulemaking Overview
Brian D'Amico provided an overview of EPA's rulemaking process related to the RLDWA. He made the following points: 
 The impetus for EPA's rule is the RLDWA.
 The RLDWA:
 Reduces the allowable lead content of pipes, pipe fittings, plumbing fittings and fixtures to a maximum allowable lead content of 0.25% with respect to wetted surfaces. 
 Provides exemptions based on use and type of product.
 Removes federal requirements for third-party certification. 
 To address questions from industry, EPA developed frequently asked questions (FAQs). In the FAQs, EPA committed to developing a rule and when possible, to add requirements to make the law more consistent nationally. 
 EPA held a webinar on April 14[th] (Regulations Implementing Section 1417 of the Safe Drinking Water Act Webinar) to get input on the options that EPA is considering and to ground check how implementable they are. EPA presented potential regulatory requirements including: 
 Labeling options for potable and some exempted products. 
 Third-party and/or self-certification to document compliance with the lead-free requirements. 
 EPA is modeling the costs for these various options. Part of the purpose of today's discussion is to get information to help EPA develop the best rule possible from a feasibility and economic standpoint. 
 EPA is in the option development stage and assessing the impact on regulated entities. The goal is to propose a rule some time in 2016.
Mr. D'Amico thanked the participants for the information they produced in advance to the meeting. In response to Brian D'Amico's overview, one participant asked if the April 30, 2015 deadline set to provide input on the April 14, 2015 webinar also applied to today's meeting. In response, Mr. D'Amico replied that the webinar and this meeting are on separate tracks and that there is no set deadline to provide feedback on today's meeting.
Solicited Questions and Feedback from Participants
Erik Helm explained that EPA is working to develop a costing model to assess impacts on manufacturers. In advance of the meeting, EPA distributed general costing questions to which some answers were provided prior to the call. Mr. Helm thanked the participants for the information and clarified that during the call, he will ask questions to get more targeted feedback. 
Metalcasting Industry Overview
Below are questions posed by Erik Helm regarding the file, "Overview of US Metalcasting Industry - March 2015" and corresponding responses from foundry participants. When there are multiple responses, each bullet represents a different foundry participant.
 Erik Helm: The characterization of industry, payroll and total value are useful. On the first page, you indicate that 80% of firms have 100 or fewer employees. Why is this size breakout used when the Small Business Administration definition is 500 or fewer? 

Response: 
 Since such a large percentage is 100 or fewer employees we wanted to show this breakout. Small foundries make up the lion share and many are family owned. 
 It is a good benchmark for when we talk to Congress.

 Erik Helm: As we look to grouping manufacturers by size, are there industry standards?

Responses:
 We can look into that. 
 We do have some breakdown. Percent that have <= 50 employees, <= 25. We also have categories for 250 and 500 employees.  

 Erik Helm: We have been researching employee size and revenue for our analyses, which has been difficult because so many producers are private companies. How many of these companies are privately owned?

Responses: 
 We have 50 or fewer.
 We have 200 or fewer and can provide additional information to answer that question. 
         
 Erik Helm: The pie chart on page 2 shows the end-use of metalcasting by industry sector. Does 20% of "valves, pipes, and fittings" output involve casting or is 20% of the metalcasting sector's total production represented by "values, pipe, and fittings"?

Responses: 
 The latter.
 There is also 3% for municipal casting. That might be more pipe in terms of that segment.
 We also have manhole covers.
         
 Erik Helm: Do you know what percentage of the 23% might be involved in drinking water?

Responses:
 I can get back to you with more information. 
 Some may be dual use. Some could be used for oil and gas sector. 
      Reply from Erik Helm: It would be great to know dual use ones. I am trying to get a picture of how much of the industry is involved with casting drinking water products because it might impact our regulation.  
 Erik Helm: Are there specific foundries that specialize just in type of castings that would be used for drinking water?

Responses: 
 There are a number of foundries where drinking water would be a significant portion of their business.
 My company has captive manufacturing and we only product water meters.
 My company also has captive products and a lot match up with water meters. 
 My company makes a captive lot for wastewater, drinking water and gas. Some plumbing products have non-potable applications.
         
 Erik Helm: How do you define "captive"?

Responses:
 We do not sell to other businesses. Captive products are ones we make for our business.
 The companies do not sell to other companies. 
         
 Erik Helm: Are captive products packaged with other components at another facilities?

Responses:
 All are done at our facilities.
 We have other products outside drinking water. Some products are strictly consumed by their parent company.
         
 Erik Helm: What portion of facilities make primarily drinking water products, versus those that produce a variety of castings across other sectors and that are not heavily dependent on the drinking water sector?

Response: We will check on this.  Not sure if there are data.
         
 Erik Helm: On the third page, you describe value-added services of machining. How much work would be done in-house versus being subcontracted out if we required lettering on castings? In your report, finish machining is the most popular value added service. I can envision the most probable way to add or change lettering is to change molds or patterns. Would companies put the lead-free lettering into cast products in a post-casting production process?

Responses:
 Lettering would not be done in a machine shop.
 In general, we would add lettering to the pattern. Machining is more expensive.
         
 Erik Helm: How many foundries develop stamps or retool their molds in-house versus sending them out to be redone? 

Responses:
 That would be a business decision. I don't think we can make a guess.
 It's a mix. Some would do in-house, some outside and some both. For companies that literally have 1000s of patterns to change, it would be a time-intensive and expensive process. The process would be affected by the inventory of products already made.
         
 Stephanie Salmon: Give us a sense of the existing inventory and how long a change like this would take.

Responses: 
 We spent 15 years educating customers about the meaning of the symbol "NL". We have been selling lead-free products for about 15 years. Our volume increased with the enactment of California's lead-free law. We sell through distribution centers that sell to customers. There is extensive inventory out there already marked with "NL". 
 There is the cost of changing the messaging and to reeducate the public.
 We would also be building inventory while making this change to be able to keep up with product demand.
 In terms of how long it would take to get new products out there, it would be hard to guess.  We have at least a year's worth of inventory.
         
  As a follow-up question Mr. Helm asked for clarification on inventory at the manufacturer.  
          A participant said that the inventory is related to the product. They would turn it over multiple times a year. He doesn't have a good guess for the inventory at distribution centers.
         
 Erik Helm: So turnover a few times per year at the manufacturing facility and lengthier downstream?

Responses: 
          Turnover for mainstream products but 20% are C and D-level products that are slower moving. When we went to low lead, we saw shipment of things that we had not seen for a while. We would have to scrap inventory if we have to change our markings by a cutoff date. Our end users may have inventory turnover once or twice per year. 
          Normally we would produce C and D-level products when we get those orders.
         
 Erik Helm: Is lost-wax casting significant for drinking water products?

Response: I do not think investment casting is used in waterworks production. It is a premium process.
Metal Casting Industry Overview
Below are questions posed by Erik Helm regarding the file, EPA Q&A Mar 2015-rev and corresponding responses from foundry participants. When there are multiple responses, each bullet represents a different foundry participant.
 Erik Helm: My first question in this document was about the predominant form of labeling used by your industry. You indicated that the "NL" and "NSF 372" are prominent markings. In your comments on the FAQs (file: AFS Comments on EPA Draft FAQs for Reduction of Lead in Drinking Water June 2013) you also mentioned a few others like "LF". Can you give me rough percentages of those common markers? If EPA adopted one common mark, we could remove the percentage of industry that uses that mark from the cost model.

Response: Our main products predominantly use the "NSF 372". On smaller products, we use "NL". 
         
 Erik Helm: Is it common that on a small part, manufacturers will use "NL"?
      Response:  Manufacturers who participated in an AWWA call indicated that they used three marks: "NL" for small products like service brass and meters, NSF 61-G and NSF 372 for larger products. People understand when they see these symbols that the products meet the low-lead requirements.  
 Erik Helm: What percentage of cast products use one of these three marks?

Response: It should be 95% that use one of these three indicators.

 Erik Helm: What does larger versus smaller mean? 
      Response: We use a sticker with NSF 372 on our products when they are > 2 inches. We have some fire hydrants where NL is on the hydrant and we also have a sticker. Every hydrant manufacturer is different. 
 Erik Helm: What is the minimum size for lettering that is readable and can be reproduced in a sand cast? 

Responses: 
          The lettering has to be larger than 1/8" to be readable. However, the spacing between lettering is important too. Also cast indented lettering is not as easy to read as raised lettering. There is not a lot of real estate to add this. We use "NL" across the board on physical parts (100%). It's more than just size, it also depends on the design of the product
          We use NL across the board on the physical part, 100%.

 Erik Helm: How much of your current lettering occurs on a flat versus a curved surface? 

Responses:
          Ideally for casting, we would letter on a flat service that is parallel to the parting line (where the mold parts). This is the best case scenario but isn't always available.
          I am guessing it is 50-50. We use a flat surface if it is available. 
          Some components are completely machined and we etch in the "NL" symbol. 
            
 Erik Helm: If altering molds and patterns, what types of machining would you use? Would you use electrical discharge machining (EDM) to alter molds or use laser machining? If applying a stamp, would you have it custom made or use pre-made types that you would apply to the mold or pattern?

Responses:
 Most raised lettering are individual letters applied to the surface. We would have to grind the surface to remove the old lettering and apply new lettering.
 We might have to weld it, make a pocket to add lettering or remake the mold entirely. 
 For smaller products, we would most likely create a new pattern. We could probably machine out the letters for larger castings. 
 The method we choose will be based on economics. Some products may have a few impressions and others may have 50 letters or more. For the latter, it may make more sense to start over.
         
 Erik Helm: If machining is not an option the pattern would be remade. How often are patterns replaced?

Response: It varies based on the use. Higher volume ones are used and therefore replaced more often. Patterns that are not used often may take a while to replace. 

 Erik Helm: What is the replacement rate for patterns of high volume products? 

Responses: 
 Twice per year or every 2 years.
 I agree that twice per year or every 2 years makes sense if we are making hundreds of thousands or millions of these products. For those where we make only 1,000 products per year, we may have the same patterns for 75 years.
         
 Erik Helm: What percent of all production and types of product are high volume?

Response: A very small percentage is high volume, such as some of our meters. I estimate that fewer than 5% are high volumes that necessitate the replacement of a pattern every two years. Most patterns last a long time.   

 Erik Helm: What is the average life span of a pattern? 

Responses: 
 A higher number may have a replacement frequency of more than 10 years on average, so say 10 to 20 years.
 I think 15 to 20 years going by the average number of patterns we have (not the number of pieces we make). 
 We change the pattern when the job comes up.  It took our shop 2 years to change over to the current lead-free symbol. 
 I agree it took 2 years to make that change.
         
 Erik Helm: Do you ever use metal embossing bands to mark lettering on patterns?

Responses from two individuals: No. It is not desirable.

 Erik Helm: You don't usually screw on a machined metal product unless you are grinding out a location. Don't you normally attach it with screws to a pattern?

Responses from two individuals: Yes, we use screws. One elaborated that we will cast in a flat place to accomplish that.
         
 Erik Helm: Is that procedure followed for drinking water patterns? 
      Response: I have not seen that but I don't know what others make.
 Erik Helm: Can you provide a time estimate to machine and develop an insert, and change a single pattern? Thinking through it, this would involve: 1) pulling the pattern, 2) setting it in a machine, 3) doing your machining, 4) setting your blank for lettering in another piece of equipment and 5) applying it to a pattern. This would be important in terms of estimating labeling costs. 

Responses: 
 This would be difficult to estimate, but everyone can try to provide an estimate 
 There is tremendous variation in the number of individual parts to a pattern (e.g., one part or 30 parts). Each impression would need to be changed. 
 
 Erik Helm: Can you estimate the number of plates on a production line as a rule of thumb, and the number of patterns on a plate? 
       
       Response: The number of impressions on a plate depend on its size. As casting gets smaller, we can get more parts on a plate. How many parts we want for each impression is driven by economics.
 
 Erik Helm: What are the typical sizes of plates?
       
       Responses:
          It is driven by the type of equipment (e.g., if it is automated equipment).
          It will vary by machine tool. The pattern could be 10" x 20", 14" x 18", or 18" x 28". 
          Most patterns are automated (Another agreed).
          Very few patterns in the US are done by hand for this industry. I think mostly use automated molding machines.
          My company did about 2% - 5% by hand and these were low volume applications. You have to consider more than just the cost of the new pattern.
 
 Erik Helm: When you're using a metal mold versus sandcasting on a production line, how many molds is that, or is it done individually?
       
       Responses:
 I don't know if much is done in water industry with metal molds. Most is sandcasting.
 On the casting side I agree. Could have some forgings that are metal forms but our group does not do that.
          
 Erik Helm: What about faucets. Are some mold castings? 
       
       Response: None of the participants responded to this question.
 Erik Helm: Your response to my second question (in file EPA Q&A Mar 2015-rev) indicated that most parts are shipped with packaging. What method do you typically use - Tyvek, labeling, etc.
      Responses from two individuals: All products are boxed and a label is applied to the box that says no lead.  
 Erik Helm: Are labels pre-printed?

Response: Yes, we print them as we make them.

 Erik Helm: Do you apply the labels using fully-automated or semi-automated machinery or do you apply them manually?  

Responses:
 We do not do that. We have the identification on the product. (Another participant agreed.)
 Anyone can put a sticker on a product. We use our mark. Our customers want to see it physically cast in so they know we made that mark.
 For products that are packaged in a box, we apply labels manually. (Response from three participants.)
         
 Erik Helm: Besides applying a sticker to a product, how often do you use a tag versus using machining and etching "NL" into the product? 

Response: A very small percentage would not be cast. As a wild guess about 1%.

 Erik Helm: Do you use acid or lasers for etching?

Responses:
 We looked at it, but have never been able to justify the cost of doing it that way.
 If it is not cast in, we stamp it. We take a hammer and metal stamp to apply the label.
 We don't use ink. (Response from four individuals). We want a permanent mark.
 We roll stamp some larger parts in our C&C machining process. 
         
 Erik Helm: In one of your attachments, you indicated that you include markings to track products for scrapping or for internal process control. What are those markings and how do you change them?

Responses:
 We don't use bar codes.
 We may mark the casting so you can trace it back to when it was made.
 On some parts, we have some date coding but it is not the norm.
 Some have day codes on some of our products.

 Erik Helm: How do you use embossing tape? How do you change it out and could it be modified to include lead-free information?

Response: We use it on large products. I think it is a glued on the pattern. It is not practical for the majority of products because a large amount of real estate is needed.

 Erik Helm: Can you be more specific on the percentages for different type of labeling? You indicated that the majority are cast markings for foundry products. You indicated a small percent is etched. Seems like printing on products is rare. How about Tyvek tags?

Responses:
 We don't use Tyvek. We like casting or etching because a lot of this product gets buried into the ground so it has to last.
 From the waterworks side, tags can be removed or disintegrate. I have seen tags, stickers or bags for products that are used in the home. I have seen very small products in bags. It is about real estate. The goal is to use a method that allows the installers to see the lead-free mark. We only use tags when there is no other choice.
         
 Erik Helm: How often are patterns redesigned in general? How often are valves or other castings redesigned? How often do product manufacturers make changes to pattern design that you implement?

Responses:
          Valves and coupling patterns are rarely changed. Some are original ones or were changed when we went to low lead.
          We do not make product lines like computers, which are consistently changing. A lot of what we make will go into the ground for 50 to 100 years. 
         
 Erik Helm: When you are looking to make lettering changes, do you have enough pattern plates to alter them without slowing down production. Do you have extras in case of problems?

Responses:
 No. 
 No, only on high production products do we have multiples. We made new toolings when we transitioned to lead-free materials. We made permanent markings when we switched over. (Another participant agreed.)

 Erik Helm: Pouring is not a continuous process. Is there time to make changes in between pourings?

Responses: 
          We will make changes to pattern before we make a product. We change the pattern and then make molds before making the product.
          There is time when it is not on the machine. Next time the part is ordered, we make the change prior to going into production.
          We had different tracking numbers when we switched to low lead. To track 1,500 patterns and different casting with different messaging would be a mess.

 Erik Helm: What percent of all plumbing products are cast or have cast parts? Are valves a cast product?

Response: I don't know if we can answer that here. Waterworks brass is almost 100% cast. Plumbing in the home is a mixed bag. An extremely high percentage of products from the water main to water meter including the water meter are cast. After the water meter to the faucet is a PMI question.
Third-Party Certification
EPA and foundry participants discussed estimated costs for third-party certification and three NSF standards associated with lead. These discussions are provided below.
 Estimated Cost for Third-Party Certification
 Erik Helm: What is the typical cost for third-party certification for a product line?
      Response: It depends on the certification. Standard 372 certification is very straight forward. The certifier tests the product for lead. Performance-based assessment to NSF Standard 61 is very expensive. It is probably $10,000 per product. There are reoccurring costs for audits that include travel. When you have multiple product lines, can be 6 figures. 
NSF Standards
EPA and foundry participants also discussed the NSF standards that pertain to lead. One participant explained the differences among NSF Standard 61, NSF Standard 61-G, and NSF Standard 372 and made additional points as follows: 
 NSF Standard 61-G was the predecessor to NSF Standard 372. A product that meets NSF Standard 61-G meets both the performance and lead-free standard. A product that meets NSF Standard 372 meets the lead-free standard only. 
 A product with NSF Standard 61 on the packaging or product itself, may not comply with the current lead-free requirements. 
 I would be against specifying NSF Standard 61 as a marking for this rule. We took the NSF Standard 61 marking off products we sell for gas because these products contain lead. We marked them as non-potable because we don't want people to get confused. I think there are still some that are certified to NSF Standard 61 that do not comply with lead-free requirement.
Another participant explained how the lead leaching testing is done for the NSF Standard 61. He thought it was virtually impossible to meet the leaching standard in NSF Standard 61 and not meet the lead-free requirements of NSF Standard 61 (Note that another participant disagreed with this statement). He also provided additional information on the different standards:
 At one point we had NSF Standard 372 that provides the lead-free calculation method and then we had Annex G to Standard 61 that is identical to NSF Standard 372. 
 NSF is still supporting NSF 61-G mark but are doing away with Annex G. There are many end users that require NSF 61 and NSF 372 so instead of having two marks, NSF 61-G indicates that a product meet both requirements. 
Other comments included:
 I was surprised during the April 14, 2015 webinar that EPA has not decided which standard will be used for compliance. AFS would like to be part of that discussion.
 NSF Standard 61 is a leaching standard. NSF Standard 372 is a standard made specifically for the new lead-free laws. I think it is a huge leap to require compliance with NSF Standard 61.
 End user can go to the certifier's websites and see what products are certified. 
 The comments I provided on the webinar discuss the idea of imported materials and the need for regulations to also apply to imports. There needs to be a level playing field.
   In response to these other comments, Brian D'Amico explained that EPA wants feedback on third-party certification pertaining to questions asked during the webinar and not on the standard itself. Please provide your feedback to website provided during the webinar: leadfreeact@epa.gov. 
Wrap-Up and Action Items
Erik Helm thanked the meeting participants for their time and helpful input. He asked the participants to provide any costing information they had related to labeling or marking changes to meet the requirements of the RLDWA. 
Mike Jones from Ford Meter Box indicated that his company is willing to provide tour at his facility for Erik Helm.
Below is a table with action items from the meeting:
Action Item
Responsibility
Provide list of meeting attendees to Erik Helm.
Stephanie Salmon
Provide meeting summary to Stephanie Salmon for distribution to foundry participants.
Erik Helm
Provide additional information to Erik Helm:
 The number of privately owned firms. 
 Percentage of valves, pipes, fittings, and metal castings that pertain to drinking water and percentage that are dual use.
 Number of facilities where primary output is for drinking water versus castings across other sectors and are less dependent on revenue from the water sector.
 Industry employee size categories.
 Time estimates to: 1) pull the pattern, 2) set it in a machine, 3) do the machining, 4) set the blank for lettering in another piece of equipment and 5) apply it to a pattern. 
 Costing information related to labeling or marking changes to meet the requirements of the RLDWA.
Stephanie Salmon/Steve Robinson (#1-3)

Foundry participants (#4-#6)
Provide clarifications or corrections to meeting summary to Erik Helm
All participants
RESPONSES TO ACTION ITEMS: 
 The number of privately owned firms. 
 That is difficult to define and AFS cannot clearly identify the total number of privately owned firms vs. publically traded corporate firms. AFS estimates that 80% of the foundries have 100 or less employees Generally speaking, only the largest foundries (250+) would be publicity or corporately owned. 
 AFS estimates that there are currently about 1965 metal casters in the US. According to the chart below about 58% of those are 60 or less employees and are probably all privately owned. In addition, some of the medium size facilities (60-250) are also privately owned and a few of the large foundries (250+).  I would think it is safe to say that probably more than the 80% of the foundries in the U.S. are privately owned and operated. 
 Percentage of valves, pipes, fittings, and metal castings that pertain to drinking water and percentage that are dual use.
 No data on this issue. 
 Number of facilities where primary output is for drinking water versus castings across other sectors and are less dependent on revenue from the water sector.
 AFS produces estimates for the total weight and dollar value of shipments into each casting use sector, but does not keep figures on how many foundries are dedicated to a particular sector or product line.  
 AFS marketing report estimates that in 2015, $187 million of copper-base alloy castings we will produced for component application in NAICS 332913 (Plumbing fixtures fitting and trim manufacturing). Another $436.76 million will be produced for NAICS 332911 (Industrial valve manufacturing) which is primarily water works with some industrial valves that might be used in non-water applications. 
         
 Industry employee size categories.
 
(Source: AFS Metalcasting Directory database (ca. 2013 data).

 Time estimates to: 1) pull the pattern, 2) set it in a machine, 3) do the machining, 4) set the blank for lettering in another piece of equipment and 5) apply it to a pattern.
  I don't think this reflects a complete understanding of the process for changing lettering on tooling such as would be necessary for designating a nonleaded alloy with cast-in lettering. 
 Changing the pattern to replace letters for cast-in lettering probably rarely involves machining. More often the existing lettering is ground or sanded off and new letters glued or screwed on. It is a more manual operation than machining. On some larger metal patterns, there may be a machined insert that can be removed and then a new insert attached.  
 Costing information related to labeling or marking changes to meet the requirements of the RLDWA.
 Varies widely with the number of patterns on the mold. For a larger part, with only one or two patterns on the tooling, only the two patterns need to be changes. For smaller poarts, that may have b 10 or 20 (or more) patterns on the tooling plate, this becomes much more complex and difficult. 


Follow-up Questions from Eric Helm (06-03-15 email): 
As part of the follow-up to our AFS conference call I was hoping that you could give me a cost estimate for changing a pattern to include additional lettering.  I believe  -  but you know better and feel free to correct me  -  that the steps to changing a single pattern would be:

 adjusting CAD drawings for the pattern
 Probably no CAD work needed, except perhaps to correct the CAD model for future reference. 
 setting up pattern and tool in CNC machine
 Would typically not be done on a CNC machining. More likely a manual process (see above response). 
 grinding out and area for application of new lettering blank or tag (this is based on info AFS members gave in our conference call)
 making the blank (sub steps include machining and EDM work)
 More likely done in a pattern shop rather than the machine shop. If the pattern is a machined insert, then a new insert would need to be machined. (see above response)
 applying the lettering tag to the pattern by epoxy or screws
 If the raised lettering is not an insert, but letters applied singly, would need to procure lettering and applied to each pattern. If the raised lettering is applied manually, would need to procure lettering and apply manually.  (see above response)

If you could give me the time required for each step and the general cost of each step that would be most helpful in more accurately estimating the costs to your industry of any proposed lead free marking changes.
 Not certain we can get information to estimate each step that precisely since it will vary tremendously with the pattern size. See above response about large vs smaller patterns. We will try to see if we can obtain a better estimate or time and cost. 
I forgot to mention, you can assume hardened tool steel for the pattern and the tag to be inserted, and the insert would be on a curved surface and the insert would be 3/8 by (3/4) inch.
 Steel or aluminum tooling. If a separate insert is used, the insert size will be determined by the size of the pattern. 
