Key Provisions and Compliance Dates for NESHAP Ruling

In July the the U.S. Court of Appeals for the D.C. Circuit denied NASF’s legal challenge to the U.S. Environmental Protection Agency and upheld the final federal chromium electroplating and anodizing air emissions rule in its entirety. To assist our members in maintaining compliance, we have assembled this guide containing the ruling provisions and important compliance dates.

If you have any questions or would like additional information regarding the new requirements of the chromium electroplating and anodizing NESHAP and potential compliance options, please contact Jeff Hannapel with NASF at jhannapel@thepolicygroup.com, or Christian Richter at crichter@thepolicygroup.com.

Click here to download the report.

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Michigan Chapter Announces Speakers for 2nd Annual Midwest Seminar

Registration is now taking place for the 2nd annual Midwest Seminar Sponsored by the Michigan Chapter of NASF. The event, to be held at Boyne Highlands in beautiful Harbor Springs, Michigan, will be held September 24-26, 2015.

Speakers include:

  • Economist Brian Long
  • Business Research Manager David Riley
  • Kim Tress of Chrysler Group and many more.

Visit minasf.org for further details.  Reservation fill quickly and space is limited.
Contact Erin Burns erin@minasf.org. for answers to your questions and to register.

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EPA Reviews Finishing Discharges for Possible Regulation

New report this week highlights concerns, proposed restrictions could come in 2016

The EPA has issued a new set of reports that highlight concerns over metal finishing wastewater discharges. The package, issued by the agency’s Office of Water, summarizes the agency’s progress on evaluating and potentially regulating several priority industries. It was formally issued as the Final 2014 Effluent Guidelines Program Plan and 2014 Annual Review Report.

Over a decade ago, NASF challenged a major effort by EPA to finalize new nationwide metal finishing discharge standards as part of the Metal Products and Machinery (MP&M) rule. Based on several years of industry discussions and a large coalition effort led by the NASF to ensure EPA performed a proper analysis of the industry’s operations, the agency concluded then that no further regulations were needed.

EPA Points to Changes in the Industry

In EPA’s recent review of the industry, it concluded that the industry has not grown significantly in the last 30 years but has consolidated into larger companies that tend to compete better with the expanding global market. However, the agency contended that the industry is using new chemicals that improve surface finishing quality and eliminate the use of toxic chemicals, thereby changing the characteristics of metal finishing wastewater.

EPA also concluded that although a majority of the industry continues to meet the current federal metal finishing limits using conventional treatment technologies, at least some portion of the industry is employing more advanced wastewater treatment technologies, including zero discharge.

Key Topics for Further Agency Review

While EPA has not yet determined if it needs to revise the standards for metal finishing, the Agency identified the following topics that warrant further review.

  • Potential new pollutants of concern not currently regulated that are increasingly used in metal finishing processes;
  • Prevalence of potential pollutants of concern associated with wastewater generated from the use of wet air pollution control devices to control air emissions from metal finishing operations;
  • The application of advanced wastewater treatment technologies and the prevalence of zero discharge practices in the industry;
  • The need to eliminate or phase out 413 standards and require all metal finishing operations to comply with 433 standards.

Will New Limits Be Necessary?

Based on a review of these issues, EPA will determine if revisions are needed. NASF has been collecting data on the industry’s waste water treatment practices and has engaged EPA officials on this issue. NASF will be providing more accurate information on current industry practices on waste water treatment technology and is having further discussions with EPA and POTW officials regarding this issue.

The Final 2014 Plan, the Annual Review Report, EPA’s Fact Sheet, and other supporting documents, can be found on their website.

EPA also issued a Notice of Availability in the Federal Register announcing this action that is available on gpo.gov.

NASF will continue educating EPA officials regarding current industry practices for waste water treatment practices and working closely with POTW and state regulatory officials. If you have any questions or would like additional information regarding this issue, please contact Jeff Hannapel at jhannapel@thepolicygroup.com, or Christian Richter at crichter@thepolicygroup.com.

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