As has been reported to the AWPA membership, EPA is currently in the process of writing new, and more stringent, Effluent Limitation Guidelines (ELG) for all industries as required by the Clean Water Act. As part of this process, EPA has proposed to move wire manufacturers into a new Point Source Category Metal Products and Machinery (MP&M),
and out of the Iron and Steel (I&S) category.
We have been told the reason for the proposed move is due to the fact that the processes involved in wire manufacturing (i.e., zinc phosphate coating) is, in EPA's view, more of a "finishing" operation. In their effort to "compartmentalize" facilities, agency staffers have decided to move these "finishing" facilities to MP&M.
AWPA has stated its opposition to this move in a meeting with EPA, and further outlined our concerns in a follow-up letter. During our meeting, we were briefed on the new regulations for the MP&M category that are soon to be released
for comment.
The most important and interesting highlight was that EPA has revised its interpretation of facilities that will be covered under the MP&M category. Now EPA is including all wire manufacturing facilities in MP&M. This means that
integrated mini-mills, which manufacture both rod and wire products, will be covered by both I&S and MP&M regulations. If they cannot separate their waste streams by manufacturing process, they will be required to abide by a "combined
waste stream" formula.
The MP&M staffers are very receptive to working with AWPA as they draft the industry's regulations. We were assured that wire manufacturers would probably be given its own sub-category with its own specific regulations. Additionally,
the regulations for our industry probably will be "mass-based" to keep on par with those guidelines being drafted for the Iron & Steel Category.
The MP&M staffers are choosing between two Best Available Technology (BAT) options:
- segregation of
streams, preliminary treatment steps (O/W separation by emulsion breaking), chemical precipitation and sedimentation
(plus pollution prevention); or
- segregation of streams, preliminary treatment steps (O/W separation by ultrafiltration),
chemical precipitation and microfiltration (plus pollution prevention).
EPA estimates that 70,000 facilities will be affected by this rule. Option 1 will cost $260,000 per facility at a one million gallon cutoff level; and Option 2, $295,600 per facility. These cost estimates do not include pollution prevention
treatments, which EPA believes will lower compliance costs for some industries.
Following this meeting, AWPA and the Environmental Affairs Subcommittee members drafted a detailed memo to EPA describing our industry, as well as outlining some specific language we would like to see in the proposed regulation.
To keep track of ELG rulemaking developments, go to the MP&M website at www.epa.gov/ost/guide/mpm/.
AWPA would like to thank the following AWPA member company representatives who came to Washington in order to participate in the EPA meeting:
- Nick Johannes, Leggett & Platt;
- Pete Josendale, Wire Rope Corporation;
- Dan Collins, Taubensee Steel & Wire Company;
- Keith Buell, American Spring Wire Corporation; and
- Richard Starr, Insteel Industries.
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American Wire Producers Association
6232 Roudsby Lane Alexandria, VA 22315-5285
Tel (703) 971-6454 | Fax (703) 971-6997 | E-mail info@awpa.org
