The Short-Term National Product Waiver for Stainless-Steel Nuts and Bolts used in Pipe Couplings, Restraints, Joints, Flanges and Saddles (www.epa.gov/sites/production/files/2017-01/documents/ss_waiver_extension_1_18_17_signed508.pdf) expires February 18, 2018. This short-term waiver permits the use of non-domestically produced stainless-steel nuts and bolts in bolting-type pipe couplings, restraints, joints, and repair saddles in iron and steel products for projects funded by the Clean Water or Drinking Water SRF. For the original approval and each subsequent renewal, the U.S. Environmental Protection Agency (EPA) conducted market research on the domestic supply of stainless-steel nuts and bolts for the products of interest and was unable to gather sufficient evidence of adequate domestic supply of stainless-steel fasteners. In each renewal period, the EPA learned of slight increases in potential domestic supplies.
For the current period, the EPA has fully reassessed the capacity and potential for domestic supply. The results of this reassessment can be found here. The EPA is soliciting public comment on its understanding of the domestic capacity of stainless-steel fasteners for the bolting-type products of interest in order to determine whether or not the short-term waiver should be extended. The Request for Public Comment: Stainless-Steel Nuts and Bolts used in Pipe Couplings, Restraints, Joints, Flanges and Saddles for State Revolving Fund (SRF) Projects can be found at https://www.epa.gov/cwsrf/request-public-comment-stainless-steel-nuts-and-bolts-used-pipe-couplings-restraints-joints-0. It is critical that WWEMA members potentially impacted by this waiver review the analysis and provide comments to EPA by January 31, 2018. To submit public comments, please address them to CWSRFWaiver@epa.gov and DWSRFWaiver@epa.gov.
Upon initial review of the analysis, it appears that while EPA’s findings indicate that there currently may not be adequate capacity, at least two manufacturers claimed that they could significantly increase their stainless-steel fastener production within 6 months to one year “should the demand increase.” One large stainless steel production mill indicated that there is adequate capacity to supply additional domestic stainless-steel wire and bar for the fastener industry. EPA does state that they do not possess an estimate of the national demand for stainless steel fasteners for products of interest, however, they did contact product users of stainless-steel fasteners as well as industry associations and general concern was expressed that there is currently an inadequate supply of domestic fasteners to meet their needs in a timely manner. Please note that the questions for which EPA is soliciting feedback appear to be directed at the product producers rather than the users. This is a bit of a chicken and egg situation where one side says there is not enough capacity and the other side says they can do it if there is sufficient demand. It is critical that manufacturers that use these products provide clear examples of what needs are currently not being met with as much product specificity as possible.
Please provide copies of your comments to Vanessa at vanessa@wwema.org.