AWPA can claim a big regulatory and environmental success in its fight and defeat of a potentially cost?prohibitive regulation. The Effluent Limitations Guidelines for the Metal Products & Machinery (MP&M) product category covering wire and wire products was recently promulgated as "no further regulation" to be imposed. This means the AWPA member companies remain covered under the Iron and Steel Point Source Category, and therefore the pretreatment standards and discharge limits covering the wastewaters generated from wire and wire products facilities remain the same as they are now. This decision came after a proactive and aggressive fight by AWPA member companies who participated in the regulatory process every step of the way. Some companies even opened up their facilities to EPA officials for testing and data collection. AWPA worked on this issue for over three years by: participating in the process that analyzed how the rule would affect small businesses; having sampling data taken from two AWPA member companies; submitting data from two others; conducting numerous in person meetings with EPA officials; and attending workshops all over the country. From the very start of the process, AWPA insisted that our industry belonged in the Iron and Steel Subcategory. In the end, we won that important argument. The rule, as written, could have cost AWPA member companies each about $200,000 in compliance expenses. EPA's own estimates showed the proposed rule's costs ($1.9 billion annually) would have outweighed its benefits by a nearly 3-1 margin. Considering that there are approximately 100 wire and wire producing facilities that would have been affected by this new regulation, our fight saved the industry about $15 to $20 million. Specifically with respect to the wire producing section of the rule, EPA had proposed to move operations that produce finished products, such as bars, wire, pipe and tubes, nails, chain link fencing, and steel rope into the MP&M rule (as the Steel Forming and Finishing subcategory). Our comments stated that these operations and resulting wastewaters are comparable to those at facilities subject to the Iron and Steel Manufacturing effluent guidelines and that these discharges should remain subject to part 420 ? the Iron & Steel Category. Additionally, we pointed out that part 420 adequately protects the environment from discharges associated with these manufacturing activities. Based on these comments, and the data collected from AWPA member companies, EPA determined that limitations and standards for the proposed Steel Forming and Finishing subcategory were not economically achievable, and would have resulted in the closure of 17% direct dischargers and 9% indirect dischargers of the existing facilities in this subcategory.
 American Wire Producers Association |
