PMI POSITION STATEMENT
ON EFFLUENT GUIDELINES
Issue:
Under the effluent guideline program, EPA imposes limits on the amount of pollutants that a new or existing industrial facility can discharge into surface waters or into publicly owned treatment works (POTWs). These limits are implemented through the national pollutant discharge elimination system permits for dischargers to surface waters, and through a pretreatment program for facilities that discharge waste water into POTWs.
Member companies of the Plumbing Manufacturers Institute (PMI) are interested in the process of setting effluent limitations generally. They also have specific interest in EPA's development of the proposed Metal Products and Machinery (MP&M) rule, which would set wastewater discharge limitations for metal products and machinery facilities, including facilities that manufacture, rebuild or maintain metal products, parts or machines. EPA proposed this rule on January 3, 2001.
The MP&M proposed regulation would establish expensive and unwarranted technology-based effluent limitations and pretreatment standards for wastewater discharges for new and existing MP&M facilities. It threatens significant harm to PMI member companies involved in the manufacture of plumbing fittings.
The original comment period was extended an additional 60 days and ended on July 2, 2001. The EPA is sorting between 1,100 and 1,200 comments for review and is collecting analytical data regarding wastewater. The EPA is expecting to meet its court-ordered deadline of December 2002 for a final rulemaking. In the meanwhile, the EPA will analyze comments and send out a notice of data availability (NODA) approximately in February, on comment results and data collection, which would relate whether or not to revise effluent limitations for final promulgation.
Position:
PMI believes human health and the environment must be protected. Effluent limitations generally, and the MP&M rule in particular, must produce benefits that justify the costs. In the case of the MP&M rule, the proposed rule should be significantly revised so that benefits will justify costs, or set aside.
Revision of original statement adopted in February 1997