From Phil Edelstein of Phibrotech....

MP&M UPDATE: EPA REVIEWING PUBLIC COMMENT ON PROPOSED METAL PRODUCTS AND
MACHINERY EFFLUENT GUIDELINES
The Environmental Protection Agency has just begun it's efforts to read,
understand, and respond to the over 1,000 comments that were filed in
response to the agency's proposed regulation of metal products and
machinery
effluent guidelines (MP&M).  According to EPA, the majority of the comments
discuss the economic impact of the proposed rule.  Most of the commentors
stated that EPA had underestimated both the cost of the proposed rule as
well as the economic impact.  Additional comments questioned the
cost-effectiveness of the proposed rule; achievability of the proposed
limits; the amount of toxics that are not removed by publicly owned
treatment works (POTWs) to which most MP&M wastewater is discharged; and
the
effect the proposed rule will have on the global competitiveness of MP&M
industries.

Since the proposal, EPA has been re-evaluating its assumption that PWB
facilities could recover over 90% of the cost of compliance by passing
costs
through to customers through a price increase.  Initial analysis by EPA
indicates that a zero pass-through may be appropriate for the PWB and metal
finishing sectors, however, no formal decision has been made.  A change in
this assumption could have a significant effect on the economic impact
analysis by reducing both projected revenues and profits, likely increasing
the number of facilities expected to close as a result of the proposed
rule.

In addition to reconsidering some of its economic assumptions, EPA is
currently collecting additional data for refinement of its proposed rule.
During the months of July, August, and September, EPA collected wastewater
samples at 7 additional MP&M sites, including 3 PWB facilities:
Sanmina-Owego, NY; Photo Circuits-Glen Cove, NY; and Merix-Forest Grove,
OR.
Sampling at the Photo Circuits facility was started during the second week
of September, halted on September 11th, and has been rescheduled for the
second week in October.  This data, along with analysis of how it might
affect final limits, is expected to be published, for public review and
comment in a February 2002 Notice of Data Availability (NODA).

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