U.
S.
Environmental
Protection
Agency
Office
of
Water
(
4303T)
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
EPA­
821­
B­
03­
001
Development
Document
For
The
Final
Effluent
Limitations
Guidelines
and
Standards
For
The
Metal
Products
&
Machinery
Point
Source
Category
EPA­
821­
B­
03­
001
Christine
Todd
Whitman
Administrator
G.
Tracy
Mehan,
III
Assistant
Administrator,
Office
of
Water
Geoffrey
H.
Grubbs
Director,
Office
of
Science
and
Technology
Sheila
E.
Frace
Director,
Engineering
and
Analysis
Division
Marvin
Rubin
Chief,
Energy
Branch
Shari
Z.
Barash
Technical
Coordinator
Jan
S.
Matuszko
Technical
Coordinator
Carey
A.
Johnston,
P.
E.
Project
Manager
February
2003
U.
S.
Environmental
Protection
Agency
Office
of
Water
Washington,
DC
20460
ACKNOWLEDGMENTS
AND
DISCLAIMER
The
Agency
would
like
to
acknowledge
the
contributions
of
Shari
Barash,
Yu­
Ting
Guilaran,
Carey
Johnston,
Jan
Matuszko,
Marvin
Rubin,
Marla
Smith,
and
Richard
Witt
to
development
of
this
technical
document.
In
addition,
EPA
acknowledges
the
contribution
of
Eastern
Research
Group,
Westat,
Abt
Associates,
and
Science
Applications
International
Corporation.

Neither
the
United
States
government
nor
any
of
its
employees,
contractors,

subcontractors,
or
other
employees
makes
any
warranty,
expressed
or
implied,
or
assumes
any
legal
liability
or
responsibility
for
any
third
party s
use
of,
or
the
results
of
such
use
of,
any
information,
apparatus,
product,
or
process
discussed
in
this
report,
or
represents
that
its
use
by
such
a
third
party
would
not
infringe
on
privately
owned
rights.
References
to
proprietary
technologies
are
not
intended
to
be
an
endorsement
by
the
Agency.

Questions
or
comments
regarding
this
technical
document
should
be
addressed
to:

Mr.
Carey
A.
Johnston,
P.
E.
Environmental
Engineer
Engineering
and
Analysis
Division
(
4303T)
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460
(
202)
566
­
1014
johnston.
carey@
epa.
gov
Table
of
Contents
TABLE
OF
CONTENTS
Page
1.0
SUMMARY
AND
SCOPE
OF
THE
REGULATION
...........................
1­
1
1.1
Overview
of
the
MP&
M
Point
Source
Category..................
1­
1
1.2
Overlap
with
Other
Effluent
Guidelines
........................
1­
5
1.3
Summary
of
Applicability
...................................
1­
7
1.4
Promulgated
Effluent
Limitations
Guidelines
and
Standards
........
1­
8
1.5
Protection
of
Confidential
Business
Information
..................
1­
9
2.0
BACKGROUND
..................................................
2­
1
2.1
Legal
Authority
...........................................
2­
1
2.2
Regulatory
Background
.....................................
2­
1
2.2.1
Clean
Water
Act.....................................
2­
1
2.2.2
Section
304(
m)
Requirements
..........................
2­
5
2.2.3
Pollution
Prevention
Act
..............................
2­
5
2.2.4
Regulatory
Flexibility
Act
(
RFA)
as
Amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
of
1996
(
SBREFA)
.........................................
2­
6
2.2.5
Regulatory
History
of
the
Metals
Industry.................
2­
8
3.0
DATA
COLLECTION
ACTIVITIES
.....................................
3­
1
3.1
Industry
Questionnaires
.....................................
3­
1
3.1.1
3.1.2
3.1.3
3.1.4
3.1.5
The
1989
Industry
Surveys
............................
3­
2
3.1.1.11989
Screener
Survey
..........................
3­
2
3.1.1.21989
Detailed
Survey...........................
3­
8
The
1996
Industry
Surveys
...........................
3.1.2.11996
Screener
Survey
.........................
3.1.2.21996
Long
Detailed
Survey
.....................
3.1.2.31996
Short
Detailed
Survey
.....................
3.1.2.4
1996
Municipality
Detailed
Survey
...............
3.1.2.5
1996
Federal
Facilities
Detailed
Survey
...........
3.1.2.61996
POTW
Detailed
Survey
...................
1997
Iron
and
Steel
Industry
Survey
Data
................
Data
Submitted
by
the
American
Association
of
Railroads
(
AAR)
...........................................
National
Estimates
..................................
3­
12
3­
13
3­
16
3­
19
3­
21
3­
23
3­
25
3­
26
3­
32
3­
33
3­
34
3­
35
3­
38
3­
38
3­
39
3­
40
3.2
SiteVisits...............................................
3.2.1
Criteria
for
Site
Selection.............................
3.2.2
Information
Collected
...............................
3.3
EPA
MP&
M
Sampling
Program
.............................
3.3.1
Criteria
for
Site
Selection.............................
3.3.2
Information
Collected
...............................

i
Table
of
Contents
TABLE
OF
CONTENTS
(
Continued)

Page
3.3.3
Sample
Collection
and
Analysis
.......................
3.4
Other
Sampling
Data
......................................
3.5
Other
Industry­
Supplied
Data
...............................
3.6
Other
Data
Sources
.......................................
3.6.1
3.6.2
3.6.3
3.6.4
3.6.5
3.6.6
EPA/
EAD
Databases
................................
Fate
of
Priority
Pollutants
in
Publicly
Owned
Treatment
Works
Database
....................................
National
Risk
Management
Research
Laboratory
(
NRMRL)
Treatability
Database
................................
The
Domestic
Sewage
Study
..........................
Toxics
Release
Inventory
(
TRI)
Database
................
Discharge
Monitoring
Reports
from
EPA s
Permit
Compliance
System
.................................
3­
41
3­
46
3­
48
3­
49
3­
50
3­
50
3­
51
3­
51
3­
52
3­
52
3­
53
3.7
References
..............................................

INDUSTRY
DESCRIPTION
...........................................
4­
1
4.1
Overview
of
MP&
M
facilities
................................
4­
1
4.1.1
Number
and
Size
of
MP&
M
Facilities
...................
4­
2
4.1.2
Geographic
Distribution...............................
4­
3
4.1.3
Wastewater­
Discharging
Facilities
......................
4­
4
4.1.4
Non­
Wastewater­
Discharging
Facilities
..................
4­
9
4.2
Proposed
MP&
M
Operations................................
4­
11
4.2.1
Types
of
Unit
Operations.............................
4­
12
4.2.2
Description
of
Proposed
MP&
M
Operations
.............
4­
14
4.2.2.1
Description
of
MP&
M
Oily
Operations
............
4­
17
4.2.2.2
Description
of
MP&
M
Metal­
bearing
Operations
....
4­
22
4.2.3
Metals
Processed
...................................
4­
34
4.2.4
Estimated
Annual
Wastewater
Discharge
................
4­
34
4.3
Trends
in
the
Industry
.....................................
4­
41
4.4
References
..............................................
4­
41
5.0
WASTEWATER
CHARACTERISTICS
...................................
5­
1
5.1
Process
Water
and
Rinse
Water
..............................
5­
1
5.2
Influent
to
Oily
Wastewater
Treatment
Systems
.................
5­
13
6.0
INDUSTRY
SUBCATEGORIZATION
....................................
6­
1
6.1
Methodology
and
Factors
Considered
for
Basis
of
Subcategorization
.
6­
1
6.1.1
Factors
Contributing
to
the
Subcategorization
Structure
Evaluated
for
the
Final
Rule
...........................
6­
2
6.1.2
Factors
That
are
Not
a
Basis
For
MP&
M
Subcategorization
.
6­
13
ii
4.0
Table
of
Contents
TABLE
OF
CONTENTS
(
Continued)

Page
6.2
General
Description
of
Facilities
in
Each
Subcategory
Evaluated
for
the
Final
Rule
.........................................
6­
17
6.2.1
General
Metals
Subcategory
Evaluated
for
the
Final
Rule
...
6­
17
6.2.2
Metal
Finishing
Job
Shops
Subcategory
Evaluated
for
the
Final
Rule
.........................................
6­
19
6.2.3
Non­
Chromium
Anodizing
Subcategory
Evaluated
for
the
Final
Rule
.........................................
6­
19
6.2.4
Printed
Wiring
Board
Subcategory
Evaluated
for
the
Final
Rule
.............................................
6­
20
6.2.5
Steel
Forming
and
Finishing
Subcategory
Evaluated
for
the
Final
Rule
.........................................
6­
20
6.2.6
Oily
Wastes
Subcategory
.............................
6­
20
6.2.7
Railroad
Line
Maintenance
Subcategory
Evaluated
for
the
Final
Rule
.........................................
6­
22
6.2.8
Shipbuilding
Dry
Dock
Subcategory
....................
6­
23
SELECTION
OF
POLLUTANT
PARAMETERS
.............................
7­
1
7.1
Identification
of
Pollutants
of
Concern
.........................
7­
1
7.2
Regulated
Pollutants
......................................
7­
12
7.3
References
..............................................
7­
14
8.0
POLLUTION
PREVENTION
PRACTICES
AND
WASTEWATER
TREATMENT
TECHNOLOGIES
.......................................
8­
1
8.1
Flow
Reduction
Practices
...................................
8­
1
8.1.1
Rinse
Tank
Design
and
Innovative
Configurations
..........
8­
2
8.1.2
Additional
Design
Elements
...........................
8­
7
8.1.3
Rinse
Water
Use
Control
..............................
8­
8
8.1.4
Pollution
Prevention
for
Process
Baths
...................
8­
9
8.2
In­
Process
Pollution
Prevention
Technologies
...................
8­
9
8.2.1
8.2.2
8.2.3
8.2.4
8.2.5
8.2.6
8.2.7
8.2.8
Activated
Carbon
Adsorption
.........................
Carbonate
 
Freezing 
................................
Centrifugation
and
Pasteurization
of
Machining
Coolants
...
Centrifugation
and
Recycling
of
Painting
Water
Curtains
...
Electrodialysis
.....................................
Electrolytic
Recovery
................................
Evaporation
.......................................
Filtration
..........................................
8.2.8.1Ion
Exchange
(
in­
process)
......................
8.2.8.2Reverse
Osmosis
.............................
8.3
Best
Management
Practices
and
Environmental
Management
Systems
for
Pollution
Prevention
.............................
8­
12
8­
13
8­
13
8­
14
8­
16
8­
17
8­
19
8­
20
8­
21
8­
24
8­
25
iii
7.0
Table
of
Contents
TABLE
OF
CONTENTS
(
Continued)

Page
8.3.1
Pollution
Prevention
for
Cleaning
and
Degreasing
Operations
........................................
8­
27
8.3.2
Pollution
Prevention
for
Machining
Operations
...........
8­
28
8.3.3
Painting
Operations
.................................
8­
29
8.3.4
Pollution
Prevention
for
Printed
Wiring
Board
Manufacturing
.....................................
8­
29
8.4
Preliminary
Treatment
of
Segregated
Wastewater
Streams
.........
8­
30
8.4.1
Chromium­
Bearing
Wastewater
.......................
8­
31
8.4.2
Concentrated
Metal­
Bearing
Wastewater
................
8­
36
8.4.3
Cyanide­
Bearing
Wastewater..........................
8­
36
8.4.3.1Alkaline
Chlorination..........................
8­
37
8.4.3.2Ozone
Oxidation
.............................
8­
38
8.4.4
Chelated­
Metal­
Bearing
Wastewater
....................
8­
39
8.4.4.1Reduction
to
Elemental
Metal
...................
8­
39
8.4.4.2
Precipitation
as
an
Insoluble
Compound
...........
8­
40
8.4.4.3Physical
Separation
...........................
8­
41
8.4.5
Oil­
Bearing
Wastewater..............................
8­
41
8.4.5.1Chemical
Emulsion
Breaking
...................
8­
42
8.4.5.2Oil
Skimming................................
8­
44
8.4.5.3Flotation
of
Oils
or
Solids
......................
8­
46
8.4.5.4Ultrafiltration
................................
8­
47
8.5
End­
of­
Pipe
Wastewater
Treatment
and
Sludge­
Handling
Technologies
............................................
8­
48
8.5.1
Chemical
Precipitation
for
Metals
Removal
..............
8­
48
8.5.1.1
Gravity
Clarification
for
Solids
Removal
..........
8­
54
8.5.1.2
Microfiltration
for
Solids
Removal
...............
8­
55
8.5.1.3
Optimization
of
Existing
Chemical
Precipitation
Treatment
System
............................
8­
56
8.5.2
Oil
Removal.......................................
8­
57
8.5.3
Polishing
Technologies
..............................
8­
58
8.5.3.1Multimedia
Filtration..........................
8­
58
8.5.3.2Activated
Carbon
Adsorption
...................
8­
59
8.5.3.3Reverse
Osmosis
.............................
8­
59
8.5.3.4Ion
Exchange
................................
8­
59
8.5.4
Sludge
Handling....................................
8­
60
8.5.4.1Gravity
Thickening
...........................
8­
60
8.5.4.2Pressure
Filtration
............................
8­
61
8.5.4.3Vacuum
Filtration
............................
8­
62
8.5.4.4Sludge
Drying
...............................
8­
63
8.6
References
..............................................
8­
63
iv
Table
of
Contents
TABLE
OF
CONTENTS
(
Continued)

Page
9.0
TECHNOLOGY
OPTIONS
...........................................
9­
1
9.1
Technology
Evaluation
Methods
..............................
9­
1
9.2
General
Metals
Subcategory
.................................
9­
2
9.2.1
Best
Practicable
Control
Technology
Currently
Available
(
BPT)
.............................................
9­
2
9.2.2
Best
Conventional
Pollutant
Control
Technology
(
BCT)
.....
9­
8
9.2.3
Best
Available
Technology
Economically
Achievable
(
BAT)
.
9­
9
9.2.4
New
Source
Performance
Standards
(
NSPS)
..............
9­
10
9.2.5
Pretreatment
Standards
for
Existing
Sources
(
PSES)
.......
9­
11
9.2.6
Pretreatment
Standards
for
New
Sources
(
PSNS)
..........
9­
13
9.3
Metal
Finishing
Job
Shops
Subcategory
.......................
9­
14
9.3.1
BPT,
BCT,
and
BAT
................................
9­
14
9.3.2
NSPS
............................................
9­
15
9.3.3
PSES
............................................
9­
16
9.3.4
PSNS
............................................
9­
17
9.4
Non­
Chromium
Anodizing
Subcategory
.......................
9­
18
9.4.1
BPT,
BCT,
and
BAT
................................
9­
18
9.4.2
NSPS
............................................
9­
19
9.4.3
PSES
and
PSNS....................................
9­
19
9.5
Printed
Wiring
Board
Subcategory
...........................
9­
20
9.5.1
BPT,
BCT,
and
BAT
................................
9­
20
9.5.2
NSPS
............................................
9­
20
9.5.3
PSES
............................................
9­
21
9.5.4
PSNS
............................................
9­
22
9.6
Steel
Forming
and
Finishing
Subcategory
......................
9­
23
9.6.1
BPT,
BCT,
and
BAT
................................
9­
23
9.6.2
NSPS
............................................
9­
24
9.6.3
PSES
............................................
9­
24
9.6.4
PSNS
............................................
9­
24
9.7
Oily
Wastes
Subcategory
...................................
9­
25
9.7.1
BPT
.............................................
9­
25
9.7.2
BCT
.............................................
9­
28
9.7.3
BAT
.............................................
9­
28
9.7.4
NSPS
............................................
9­
28
9.7.5
PSES
............................................
9­
29
9.7.6
PSNS
............................................
9­
30
9.8
Railroad
Line
Maintenance
Subcategory.......................
9­
31
9.8.1
BPT
.............................................
9­
31
9.8.2
BCT
.............................................
9­
33
9.8.3
BAT
.............................................
9­
34
v
Table
of
Contents
TABLE
OF
CONTENTS
(
Continued)

Page
9.8.4
NSPS
............................................
9­
34
9.8.5
PSES
and
PSNS....................................
9­
34
9.9
Shipbuilding
Dry
Dock
Subcategory
..........................
9­
35
9.9.1
BPT
.............................................
9­
35
9.9.2
PSES
and
PSNS....................................
9­
36
9.10
Summary
of
Technology
Options
Considered
and
Selected
for
the
Final
MP&
M
Rule
........................................
9­
36
10.0
LIMITATIONS
AND
STANDARDS:
DATA
SELECTION
AND
CALCULATION
....
10­
1
10.1
Overview
of
Data
Selection
.................................
10­
1
10.2
Episode
and
Data
Selection
.................................
10­
2
10.3
Data
Aggregation
.........................................
10­
9
10.3.1
Aggregation
of
Field
Duplicates
......................
10­
11
10.3.2
Aggregation
of
Grab
Samples
........................
10­
11
10.4
Overview
of
Limitations
..................................
10­
12
10.4.1
Objective
........................................
10­
12
10.4.2
Selection
of
Percentiles
.............................
10­
13
10.4.3
Compliance
with
Limitations.........................
10­
14
10.5
Calculation
of
the
Limitations
..............................
10­
15
10.6
Evaluation
of
the
Limitations...............................
10­
16
10.6.1
Comparison
to
Data
................................
10­
17
10.6.2
Comparison
to
Proposed
and
NODA
Values
.............
10­
21
11.0
COSTS
OF
TECHNOLOGY
BASES
FOR
REGULATIONS
.....................
11­
1
11.1
Summary
of
Costs
........................................
11­
1
11.2
Development
of
Cost
Model
Inputs...........................
11­
6
11.2.1
Model
Site
Development
...........................
11­
6
11.2.2
Wastewater
Streams
and
Flow
Rates
..................
11­
7
11.2.3
Wastewater
Pollutant
Concentrations
..................
11­
9
11.2.4
Technology
in
Place
..............................
11­
10
11.2.4.1
Baseline
Model
Runs
...................
11­
15
11.2.4.2
Post­
Compliance
Model
Runs
............
11­
16
11.2.4.3
New
Source
Model
Runs
................
11­
16
11.3
General
Methodology
for
Estimating
Costs
of
Treatment
Technologies
...........................................
11­
17
11.3.1
Components
of
Cost
..............................
11­
18
11.3.1.1
Total
Annualized
Costs
.................
11­
19
11.3.2
Sources
and
Standardization
of
Cost
Data
.............
11­
20
11.3.3
Development
of
the
Cost
Model.....................
11­
25
11.3.3.1
Modeling
Technology
Options
...........
11­
26
11.3.3.2
Modeling
Flow
Reduction
...............
11­
30
vi
Table
of
Contents
TABLE
OF
CONTENTS
(
Continued)

Page
11.3.3.3
Modeling
End­
of­
Pipe
Treatment
for
Metal
Bearing
Subcategories
..................
11­
30
11.3.3.4
Modeling
End­
of­
Pipe
Treatment
for
Oily
Subcategories
.........................
11­
31
11.3.3.5
Model
Output.........................
11­
31
11.3.4
General
Assumptions
Made
During
the
Costing
Effort
...
11­
31
11.4
Specific
Methodology
and
Assumptions
Used
to
Estimate
Costs
for
Treatment
Technologies...................................
11­
34
11.4.1
NODA
Cost
Estimates
............................
11­
35
11.4.2
Post­
NODA
Cost
Estimates
........................
11­
37
11.5
Costing
Methodologies
for
Direct
Discharging
Oil­
Bearing
Subcategories
...........................................
11­
39
11.5.1
Oily
Wastes
Costing
Methodology...................
11­
39
11.5.2
Railroad
Line
Maintenance
Costing
Methodology
.......
11­
40
11.5.3
Shipbuilding
Dry
Dock
Costing
Methodology
..........
11­
40
11.6
Design
and
Costs
of
Individual
Pollution
Control
Technologies
...
11­
40
11.6.1
Countercurrent
Cascade
Rinsing.....................
11­
41
11.6.2
Centrifugation
and
Pasteurization
of
Machining
Coolant
.
11­
41
11.6.3
Centrifugation
of
Painting
Water
Curtains
............
11­
42
11.6.4
Contracting
for
Off­
Site
Treatment
and
Disposal
........
11­
49
11.6.5
Feed
Systems
and
Chemical
Dosages.................
11­
49
11.6.6
Chemical
Emulsion
Breaking
and
Gravity
Oil/
Water
Separation
......................................
11­
52
11.6.7
Dissolved
Air
Flotation............................
11­
53
11.6.8
Ultrafiltration
System
for
Oil
Removal
...............
11­
54
11.6.9
Batch
Oil
Emulsion
Breaking
with
Gravity
Flotation
.....
11­
54
11.6.10
Chemical
Reduction
of
Hexavalent
Chromium
.........
11­
55
11.6.11
Cyanide
Destruction
..............................
11­
56
11.6.12
Chemical
Reduction/
Precipitation
of
Chelated
Metals
...
11­
57
11.6.13
Chemical
Precipitation
............................
11­
57
11.6.14
Sedimentation
by
Slant­
Plate
Clarifier
................
11­
58
11.6.15
Multimedia
Filtration
.............................
11­
59
11.6.16
Microfiltration
for
Solids
Removal
...................
11­
59
11.6.17
Sludge
Thickening
...............................
11­
60
11.6.18
Sludge
Pressure
Filtration
..........................
11­
60
11.7
References
.............................................
11­
61
vii
Table
of
Contents
TABLE
OF
CONTENTS
(
Continued)

Page
12.0
POLLUTANTLOADING
AND
REDUCTION
ESTIMATES
....................
12.1
Estimation
of
Unit
Operation
Wastewater
Pollutant
Concentrations
.
12.1.1
Unit
Operation
Wastewater
Data
Collection
............
12.1.2
Calculation
of
Pollutant
Concentrations
for
Each
Unit
Operation
for
Each
Sampling
Point
from
EPA
or
Industry­
Supplied
Sampling
Data
............................
12.1.3
Estimation
of
Pollutant
Concentrations
for
Each
Subcategory
and
Unit
Operation
......................
12.1.3.1
12.1.3.2
12.1.3.3
12.1.3.4
Identification
of
Unit
Operations
Reported
in
the
Detailed
Surveys
....................
Estimation
of
Wastewater
Pollutant
Concentrations
for
Each
Unit
Operation/
Subcategory
Combination
................
Estimation
of
Applied
Metal
Concentrations
Using
Available
Analytical
Data
...........
Modeling
of
Pollutant
Concentrations
for
Each
Model
Site
Unit
Operation
...........
12.2
Estimation
of
Industry
Baseline
Pollutant
Loadings
..............
12­
1
12­
2
12­
2
12­
3
12­
4
12­
4
12­
5
12­
7
12­
8
12­
9
12.2.1
Estimation
of
Baseline
Pollutant
Concentrations
from
Sites
in
the
Metal­
Bearing
Subcategories
..............
12­
10
12.2.1.1
Estimation
of
Effluent
Pollutant
Concentrations
for
Untreated
Streams
......
12­
10
12.2.1.2
Estimation
of
Effluent
Pollutant
Concentrations
for
Treated
Streams
........
12­
11
12.2.1.3
Estimation
of
Commingled
Effluent
Pollutant
Concentrations
from
Sites
...............
12­
14
12.2.2
Estimation
of
Baseline
Pollutant
Concentrations
from
Sites
in
the
Oil­
Bearing
Subcategories
................
12­
15
12.2.2.1
Estimation
of
Baseline
Pollutant
Concentrations
from
Sites
in
the
Shipbuilding
Dry
Dock
Subcategory
..................
12­
15
12.2.2.2
Estimation
of
Baseline
Pollutant
Concentrations
from
Sites
in
the
Railroad
Line
Maintenance
Subcategory
...........
12­
16
12.2.2.3
Estimation
of
Baseline
Pollutant
Concentrations
from
Sites
in
the
Oily
Wastes
Subcategory
..........................
12­
16
12.2.3
Estimation
of
Model
Site
Baseline
Loadings
...........
12­
17
12.2.4
Estimation
of
Industry­
Wide
Baseline
Pollutant
Loadings
.
12­
17
viii
Table
of
Contents
TABLE
OF
CONTENTS
(
Continued)

Page
12.3
Estimation
of
Industry
Option
Pollutant
Loadings
..............
12­
18
12.3.1
Estimation
of
Industry
Option
Pollutant
Loadings
for
Sites
in
the
Metal­
Bearing
Subcategories..................
12­
18
12.3.2
Estimation
of
Industry
Option
Pollutant
Loadings
for
Sites
in
the
Shipbuilding
Dry
Dock
Subcategory
............
12­
19
12.3.3
Estimation
of
Industry
Option
Pollutant
Loadings
for
Sites
in
the
Railroad
Line
Maintenance
Subcategory
.........
12­
19
12.3.4
Estimation
of
Industry
Option
Pollutant
Loadings
for
Sites
in
the
Oily
Wastes
Subcategory
.....................
12­
19
12.4
Estimation
of
Pollutant
Reductions
..........................
12­
20
13.0
NON
­
WATER
QUALITY
IMPACTS
...................................
13­
1
13.1
Energy
Requirements......................................
13­
1
13.2
Air
Emissions
Impacts
.....................................
13­
2
13.3
Solid
Waste
Generation
....................................
13­
3
13.4
References
..............................................
13­
4
14.0
LONG­
TERM
AVERAGES
AND
EFFLUENT
LIMITATIONS
AND
STANDARDS
....
14­
1
14.1
General
Metals
Subcategory
................................
14­
1
14.2
Metal
Finishing
Job
Shops
Subcategory
.......................
14­
2
14.3
Non­
Chromium
Anodizing
Subcategory
.......................
14­
2
14.4
Printed
Wiring
Board
Subcategory
...........................
14­
2
14.5
Steel
Forming
and
Finishing
Subcategory
......................
14­
2
14.6
Oily
Wastes
Subcategory
...................................
14­
2
14.6.1
Best
Practicable
Control
Technology
(
BPT)
.............
14­
2
14.6.2
Best
Conventional
Pollutant
Control
Technology
(
BCT)
...
14­
4
14.6.3
Best
Available
Technology
Economically
Achievable
(
BAT)
..........................................
14­
4
14.6.4
New
Source
Performance
Standards
(
NSPS)
............
14­
4
14.6.5
Pretreatment
Standards
for
Existing
Sources
(
PSES)
......
14­
4
14.6.6
Pretreatment
Standards
for
New
Sources
(
PSNS)
........
14­
4
14.7
Railroad
Line
Maintenance
Subcategory.......................
14­
5
14.8
Shipbuilding
Dry
Dock
Subcategory
..........................
14­
5
15.0
IMPLEMENTATION
...............................................
15­
1
15.1
Applicability
of
the
MP&
M
Effluent
Guidelines
................
15­
1
15.1.1
MP&
M
Industrial
Sectors
...........................
15­
2
15.1.2
Regulated
Subcategory
in
the
MP&
M
Effluent
Guidelines
.
15­
3
15.1.3
Facilities
Not
Subject
to
the
MP&
M
Effluent
Guidelines
..
15­
3
15.2
Compliance
Dates
........................................
15­
9
15.3
Limits
Development.......................................
15­
9
ix
Table
of
Contents
TABLE
OF
CONTENTS
(
Continued)

Page
15.4
Compliance
Monitoring...................................
15­
12
15.5
References
.............................................
15­
13
16.0
GLOSSARY
OF
TERMS
............................................
16­
1
Appendix
A
­
EXAMPLE
NAICS
AND
SIC
CODES
FOR
THE
METAL
PRODUCTS
&
MACHINERY
FINAL
EFFLUENT
LIMITATIONS
GUIDELINES
AND
STANDARDS
Appendix
B
­
ANALYTICAL
METHODS
AND
BASELINE
VALUES
FOR
THE
METAL
PRODUCTS
AND
MACHINERY
INDUSTRY
Appendix
C
­
WASTEWATER
CHARACTERISTICS
Appendix
D
­
POLLUTION
PREVENTION
AND
WATER
CONSERVATION
PRACTICES
Appendix
E
­
MODIFIED
DELTA­
LOGNORMAL
DISTRIBUTION
x
List
of
Tables
LIST
OF
TABLES
Page
1­
1
Clarification
of
Coverage
by
Proposed
MP&
M
Subcategory
..............
1­
6
1­
2
Technology
Bases
for
Promulgated
MP&
M
Limitations
and
Standards
......
1­
9
1­
3
Effluent
Limitations
Guidelines
for
the
MP&
M
Point
Source
Category
(
40
CFR
438)
...................................................
1­
9
2­
1
Summary
of
Regulatory
Levels
of
Control
............................
2­
4
2­
2
Summary
of
Metals
Industry
Effluent
Guidelines
.......................
2­
9
3­
1
1989
and
1996
MP&
M
Survey
Mailout
Results
........................
3­
5
3­
2
Summary
of
1996
Detailed
Survey
Information
by
Question
Number
......
3­
18
3­
3
Number
of
Sites
Visited
Within
Each
Proposed
Industrial
Sector
.........
3­
35
3­
4
Number
of
Sites
Sampled
Within
Each
Proposed
Industrial
..............
3­
39
3­
5
Metal
Constituents
Measured
Under
the
MP&
M
Sampling
Program
.......
3­
42
3­
6
Organic
Constituents
Measured
Under
the
MP&
M
Sampling
Program
.....
3­
43
3­
7
Additional
Parameters
Measured
Under
the
MP&
M
Sampling
Program
....
3­
47
4­
1
Wastewater­
Discharging
MP&
M
facilities
by
Sector
....................
4­
5
4­
2
Types
of
Proposed
MP&
M
operations
..............................
4­
13
4­
3
List
of
MP&
M
Oily
Operations
....................................
4­
15
4­
4
List
of
MP&
M
Metal­
Bearing
Operations............................
4­
16
4­
5
Estimated
Number
of
MP&
M
Facilities
Discharging
Process
Wastewater
by
Proposed
MP&
M
Operation
and
Estimated
Annual
Discharge
for
Each
Proposed
MP&
M
Operation
...............................
4­
36
5­
1
Number
of
Process
Water
and
Rinse
Water
Samples
For
Oily
Operations
....
5­
2
5­
2
Process
Water
Pollutant
Concentration
Data
for
Oily
Operations
...........
5­
3
xi
List
of
Tables
LIST
OF
TABLES
(
Continued)

Page
5­
3
Rinse
Water
Pollutant
Concentration
Data
for
Oily
Operations
............
5­
8
5­
4
MP&
M
Pollutant
Concentration
Data
for
the
Influent
to
Oily
Wastewater
Treatment
Systems..............................................
5­
14
6­
1
Final
Subcategories
Evaluated
in
the
Final
Rule
........................
6­
2
6­
2
Oily
Operations
as
Defined
by
the
Final
Rule
..........................
6­
3
6­
3
Metal­
Bearing
Operations
as
Defined
by
the
Final
Rule
..................
6­
4
6­
4
Percentage
of
Facilities
Performing
Proposed
MP&
M
Operations
Using
Multiple
Metal
Types
by
Subcategory...........................
6­
6
6­
5
Percentage
of
Facilities
Performing
Proposed
MP&
M
Operations
by
Subcategory
Using
Each
Metal
Type
..............................
6­
8
7­
1
Pollutants
Not
Detected
in
Any
Samples
Collected
During
the
Phase
I
and
Phase
II
MP&
M
Sampling
Programs
.......................
7­
4
7­
2
Pollutants
Detected
in
Less
Than
Three
Samples
Collected
During
the
Phase
I
and
Phase
II
MP&
M
Sampling
Programs
..............
7­
6
7­
3
Pollutants
Detected
at
Average
Concentrations
of
Less
Than
Five
Times
the
Minimum
Level
During
the
Phase
I
and
Phase
II
MP&
M
Sampling
Programs
..............................................
7­
7
7­
4
Summary
of
Pollutants
of
Concern
Information
........................
7­
8
7­
5
Pollutants
Considered
for
Regulation
for
Direct
Dischargers
in
the
Oily
Wastes
Subcategory
.........................................
7­
15
8­
1
MP&
M
Flow
Reduction
Technologies
...............................
8­
3
8­
2
MP&
M
In­
Process
Pollution
Prevention
Technologies
..................
8­
10
8­
3
MP&
M
Preliminary
and
End­
of­
Pipe
Treatment
Technologies
...........
8­
32
9­
1
Technology
Options
by
Subcategory
................................
9­
37
9­
2
Summary
of
Technology
Bases
for
the
Final
Rule
.....................
9­
38
xii
List
of
Tables
LIST
OF
TABLES
(
Continued)

Page
10­
1
Oily
Wastes
Subcategory
Oil/
Water
Separation
.......................
10­
3
10­
2
Unit
Operations
at
Each
Episode
...................................
10­
5
10­
3
Effluent
Data
Before
Aggregation
.................................
10­
10
10­
4
Data
After
Aggregation
(
i.
e.,
Daily
Values)
.........................
10­
11
10­
5
Episode
Long­
Term
Averages
and
Daily
Variability
Factors
............
10­
15
10­
6
Option
Long­
Term
Averages,
Daily
Variability
Factors,
and
Limitations
..
10­
17
10­
7
Daily
Maximum
Limitations:
Proposal,
NODA,
and
Final
Rule
.........
10­
22
11­
1
Incremental
Capital
and
O&
M
Costs................................
11­
2
11­
2
Incremental
Annualized
Costs
.....................................
11­
4
11­
3
Information
Contained
in
MSP1
...................................
11­
8
11­
4
Information
Contained
in
MSP2
..................................
11­
10
11­
5
Treatment
Technologies
Considered
Equivalent
to
the
Option
Technologies
.................................................
11­
13
11­
6
Information
Contained
in
MSP3
..................................
11­
15
11­
7
Components
of
Total
Capital
Investment
...........................
11­
19
11­
8
Costs
for
Contracted
Off­
Site
Treatment/
Disposal
of
Various
Waste
Types
11­
21
11­
9
RS
Means
Building
Construction
Historical
Cost
Indexes
..............
11­
22
11­
10
Monitoring
Frequencies
Used
to
Develop
Part
438
Limitations
Considered
for
Metal­
Bearing
Subcategories
.................................
11­
23
11­
11
Wastewater
Treatment
Technologies
and
Source
Reduction
and
Recycling
Practices
for
Which
EPA
Developed
Cost
Modules
...................
11­
26
11­
12
List
of
Unit
Operations
Feeding
Each
Treatment
Unit
or
In­
Process
Technology
..................................................
11­
27
xiii
List
of
Tables
LIST
OF
TABLES
(
Continued)

Page
11­
13
MP&
M
Equipment
Cost
Equations
................................
11­
43
11­
14
Logic
Used
for
Off­
Site
Treatment
and
Disposal
Cost
Estimates
.........
11­
50
11­
15
Treatment
Technologies
That
Use
Feed
Systems
.....................
11­
51
11­
16
Treatment
Dosage
Information
...................................
11­
52
12­
1
POTW
Removal
Percentages
For
Each
MP&
M
Pollutant
of
Concern
....
12­
22
12­
2
Summary
of
Baseline
Annual
Pollutant
Loadings
Discharged
by
Subcategory
..................................................
12­
26
12­
3
Summary
of
Selected
Option
Annual
Pollutant
Loadings
Discharged
by
Subcategory
..................................................
12­
28
12­
4
Industry
Pollutant
Removals
in
Pounds
(
for
Direct
Dischargers)
.........
12­
30
12­
5
Industry
Pollutant
Removals
in
Pound­
Equivalents
...................
12­
31
13­
1
Energy
Usage
for
the
Selected
Technology
Option
.....................
13­
1
13­
2
Waste
Oil
Removed
by
the
Selected
Option
..........................
13­
3
14­
1
BPT
Effluent
Limitations
for
the
Oily
Wastes
Subcategory
..............
14­
3
15­
1
Clarification
of
Coverage
by
MP&
M
Subcategory
Evaluated
for
the
Final
Rule..................................................
15­
5
15­
2
Effluent
Limitations
Guidelines
for
the
MP&
M
Point
Source
Category
(
40
CFR
438)
.................................................
15­
11
16­
1
Priority
and
Nonconventional
Organic
Pollutants
Comprising
the
Total
Organics
Parameter............................................
16­
12
xiv
List
of
Figures
LIST
OF
FIGURES
Page
3­
1
Percentage
of
1989
and
1996
MP&
M
Surveys
Returned
and
Percentage
of
Survey
Respondents
Performing
Proposed
MP&
M
Operations
............
3­
6
3­
2
Number
of
Facilities
Performing
Proposed
MP&
M
Operations
Visited
and
Sampled
by
Industrial
Sector
......................................
3­
36
4­
1
Percentage
of
Wastewater­
Discharging
MP&
M
facilities
and
Percentage
of
Annual
Wastewater
Discharge
by
Number
of
Employees
.................
4­
3
4­
2
Estimated
Number
of
Wastewater­
Discharging
MP&
M
facilities
by
EPA
Region..................................................
4­
4
4­
3
Percentage
of
Wastewater­
Discharging
MP&
M
facilities
and
Percentage
of
Total
Annual
Discharge
by
Activity
.................................
4­
7
4­
4
Percentage
of
Wastewater­
Discharging
MP&
M
facilities
and
Percentage
of
Total
Annual
Discharge
by
Discharge
Status
..........................
4­
8
4­
5
Percentage
of
Wastewater­
Discharging
MP&
M
facilities
and
Percentage
of
Total
Annual
MP&
M
Discharge
by
Flow
Rate
Range
...................
4­
9
4­
6
Percentage
of
Screener
Survey
Respondents
Using
Each
Zero
Discharge
Method
.......................................................
4­
11
4­
7
Percentage
of
Wastewater­
Discharging
MP&
M
facilities
by
Number
of
Metal
Processed
................................................
4­
35
6­
1
Percentage
of
Wastewater
­
Discharging
Facilities
Evaluated
for
the
Final
Rule
by
Decade
Built
...........................................
6­
15
8­
1
Countercurrent
Cascade
Rinsing
....................................
8­
5
8­
2
Machine
Coolant
Recycling
System
................................
8­
14
8­
3
Centrifugation
and
Recycling
of
Painting
Water
Curtains
...............
8­
15
8­
4
Electrodialysis
Cell
.............................................
8­
17
8­
5
Membrane
Filtration
Unit
........................................
8­
21
xv
List
of
Figures
LIST
OF
FIGURES
(
Continued)

Page
8­
6
Ion
Exchange
..................................................
8­
22
8­
7
Chemical
Reduction
of
Hexavalent
Chrome
..........................
8­
35
8­
8
Cyanide
Destruction
Through
Alkaline
Chlorination
...................
8­
37
8­
9
Chemical
Reduction
/
Precipitation
of
Chelated
Metals
.................
8­
40
8­
10
Continuous
Chemical
Emulsion
Breaking
Unit
with
Coalescing
Plates
.....
8­
42
8­
11a
Disk
Oil
Skimming
Unit
.........................................
8­
44
8­
11b
Belt
Oil
Skimming
Unit
.........................................
8­
45
8­
12
Dissolved
Air
Flotation
Unit
......................................
8­
47
8­
13
Continuous
Chemical
Precipitation
System
with
Lamella
Clarifier
........
8­
49
8­
14
Effect
of
pH
on
Hydroxide
and
Sulfide
Precipitation
...................
8­
51
8­
15
Center­
Feed
Rim
Flow
Clarifier
...................................
8­
55
8­
16
Multimedia
Filtration
System
.....................................
8­
58
8­
17
Gravity
Thickening
.............................................
8­
60
8­
18
Plate­
and­
Frame
Filter
Press
......................................
8­
61
8­
19
Rotary
Vacuum
Filter............................................
8­
62
9­
1
End­
of­
Pipe
Treatment
Train
for
Options
1
and
2
Considered
for
the
Following
Subcategories:
General
Metals,
Metal
Finishing
Job
Shops,
Non­
Chromium
Anodizing,
Printed
Wiring
Board,
and
Steel
Forming
and
Finishing
.....................................................
9­
39
9­
2
In­
Process
Water
Use
Reduction
Technologies
for
Options
2
and
4
Considered
for
the
Following
Subcategories:
General
Metals,
Metal
Finishing
Job
Shops,
Non­
Chromium
Anodizing,
Printed
Wiring
Board,
and
Steel
Forming
and
Finishing
...................................
9­
40
xvi
List
of
Figures
LIST
OF
FIGURES
(
Continued)

Page
9­
3
End­
of­
Pipe
Treatment
Train
for
Options
3
and
4
Considered
for
the
Following
Subcategories:
General
Metals,
Metal
Finishing
Job
Shops,
Non­
Chromium
Anodizing,
Printed
Wiring
Board,
and
Steel
Forming
and
Finishing
..................................................
9­
41
9­
4
End­
of­
Pipe
Treatment
Train
for
Options
5
and
6
Considered
for
the
Following
Subcategories:
Oily
Wastes
and
Railroad
Line
Maintenance
.....
9­
42
9­
5
End­
of­
Pipe
Treatment
Train
for
Option
7
and
8
Considered
for
the
Following
Subcategories:
Oily
Wastes,
Railroad
Line
Maintenance,
Shipbuilding
Dry
Dock
..........................................
9­
42
9­
6
End­
of­
Pipe
Treatment
Train
for
Options
9
and
10
Considered
for
the
Following
Subcategories:
Railroad
Line
Maintenance
and
Shipbuilding
Dry
Dock
.....................................................
9­
43
11­
1
Relationship
Between
In­
Process
and
End­
of­
Pipe
Technologies
and
Practices
.....................................................
11­
62
11­
2
Components
of
Total
Capital
Investment
...........................
11­
63
11­
3
Logic
Used
to
Apply
End­
of­
Pipe
Technologies
and
Practices
for
the
Following
Subcategories:
General
Metals,
Metal
Finishing
Job
Shops,
Non­
Chromium
Anodizing,
Printed
Wiring
Board,
and
Steel
Forming
and
Finishing
.................................................
11­
64
11­
4
Logic
Used
to
Apply
End­
of­
Pipe
Technologies
and
Practices
for
the
Following
Subcategories30:
Oily
Wastes,
Railroad
Line
Maintenance,
and
Shipbuilding
Dry
Dock
......................................
11­
65
11­
5
Example
Treatment
Facility
for
General
Metals
Subcategory
Direct
Discharger
...................................................
11­
66
15­
1
MP&
M
Permitting
Process
Flow
Chart.............................
15­
10
xvii
1.0
­
Summary
and
Scope
of
the
Regulation
1.0
SUMMARY
AND
SCOPE
OF
THE
REGULATION
This
section
presents
a
brief
overview
of
the
Metal
Products
and
Machinery
(
MP&
M)
Point
Source
Category,
discusses
the
applicability
of
the
MP&
M
effluent
limitations
guidelines
and
standards
for
the
category,
and
presents
the
applicability
interface
between
the
final
rule
and
other
regulations
for
the
metals
industry.
This
section
also
briefly
summarizes
the
final
rule
and
describes
the
Agency s
efforts
to
protect
confidential
business
information.
This
section
is
organized
as
follows:

&
 
Section
1.1
­
Overview
of
the
MP&
M
Point
Source
Category;

&
 
Section
1.2
­
Overlap
with
other
effluent
guidelines;

&
 
Section
1.3
­
Summary
of
applicability;

&
Section
1.4
­
Promulgated
effluent
limitations
guidelines
and
standards;
and
&
 
Section
1.5
­
Protection
of
confidential
business
information.

1.1
Overview
of
the
MP&
M
Point
Source
Category
The
MP&
M
Point
Source
Category
includes
facilities
that
discharge
wastewater
from
processing
metal
parts,
metal
products,
and
machinery.
This
processing
can
be
described
by
two
types
of
activities:
manufacturing
and
rebuilding/
maintenance.
Manufacturing
is
the
series
of
unit
operations
necessary
to
produce
metal
products
and
is
generally
performed
in
a
production
environment.
Rebuilding/
maintenance
is
the
series
of
unit
operations
necessary
to
disassemble
used
metal
products
into
components,
replace
the
components
or
subassemblies
or
restore
them
to
original
function,
and
reassemble
the
metal
product.
Rebuilding
and
maintenance
operations
are
intended
to
keep
metal
products
in
operating
condition
and
can
be
performed
in
either
a
production
or
a
nonproduction
environment.
The
MP&
M
Point
Source
Category
encompasses
manufacturing,
rebuilding,
or
maintenance
of
metal
parts,
products,
or
machines
for
use
in
the
following
industrial
sectors:

&
 
Aerospace;

&
 
Aircraft;

&
 
Bus
and
Truck;

&
 
Electronic
Equipment;

&
 
Hardware;

&
 
Household
Equipment;

&
 
Instruments;

&
 
Mobile
Industrial
Equipment;

&
 
Motor
Vehicle;

&
 
Office
Machine;

1­
1
1.0
­
Summary
and
Scope
of
the
Regulation
&
 
Ordnance;

&
 
Precious
Metals
and
Jewelry;

&
 
Railroad;

&
 
Ships
and
Boats;

&
 
Stationary
Industrial
Equipment;
and
&
 
Miscellaneous
Metal
Products.

EPA
also
evaluated
manufacturing,
rebuilding,
or
maintenance
of
metal
parts,
products,
or
machines
used
in
two
other
industrial
sectors
(
Job
Shops
and
Printed
Wiring
Board)
but
has
decided
not
to
regulate
them
as
part
of
the
final
rule.

These
sectors
considered
by
EPA
for
regulation
manufacture,
maintain,
and
rebuild
metal
products
under
more
than
200
different
Standard
Industrial
Classification
(
SIC)
codes.
Appendix
A
includes
a
list
of
example
SIC
codes
and
North
American
Industrial
Classification
System
(
NAICS)
codes
that
apply
to
the
above
industrial
sectors.
EPA
is
not
revising
limitations
and
standards
for
three
proposed
industrial
sectors
(
i.
e.,
job
shops,
printed
wiring
board,
and
steel
forming
and
finishing).

The
final
rule
does
not
apply
to
maintenance
or
repair
of
metal
parts,
products,
or
machines
that
takes
place
only
as
ancillary
activities
at
facilities
not
included
in
the
16
MP&
M
industrial
sectors.
EPA
estimates
that
these
ancillary
repair
and
maintenance
activities
would
typically
discharge
de
minimis
quantities
of
process
wastewater.
For
example,
wastewater
discharges
from
repair
of
metal
parts
at
oil
and
gas
extraction
facilities
(
40
CFR
435)
are
not
subject
to
the
final
rule.
The
Agency
has
determined
that
permit
writers
are
establishing
limits
using
best
professional
judgment
(
BPJ)
to
regulate
wastewater
discharges
from
ancillary
waste
streams
for
direct
dischargers
(
see
66
FR
433).

Facilities
in
any
one
of
the
16
industrial
sectors
in
the
MP&
M
Point
Source
Category
are
subject
to
the
final
rule
only
if
they
directly
discharge
process
wastewater
resulting
from
one
or
more
of
the
following
 
oily
operations: 

&
 
Abrasive
Blasting;

&
 
Adhesive
Bonding;

&
 
Alkaline
Cleaning
for
Oil
Removal;

&
 
Alkaline
Treatment
Without
Cyanide;

&
 
Aqueous
Degreasing;

&
 
Assembly/
Disassembly;

&
 
Burnishing;

&
 
Calibration;

&
 
Corrosion
Preventative
Coating
(
as
specified
at
40
CFR
438.2(
c)
and
Appendix
C
of
Part
438);

&
 
Electrical
Discharge
Machining;

&
 
Floor
Cleaning
(
in
Process
Area);

&
 
Grinding;

1­
2
1.0
­
Summary
and
Scope
of
the
Regulation
&
 
Heat
Treating;

&
 
Impact
Deformation;

&
 
Iron
Phosphate
Conversion
Coating;

&
 
Machining;

&
 
Painting­
Spray
or
Brush
(
Including
Water
Curtains);

&
 
Polishing;

&
 
Pressure
Deformation;

&
 
Solvent
Degreasing;

&
 
Steam
Cleaning;

&
 
Testing
(
e.
g.,
hydrostatic,
dye
penetrant,
ultrasonic,
magnetic
flux);

&
 
Thermal
Cutting;

&
 
Tumbling/
Barrel
Finishing/
Mass
Finishing/
Vibratory
Finishing;

&
 
Washing
(
Finished
Products);

&
 
Welding;

&
 
Wet
Air
Pollution
Control
for
Organic
Constituents;
and
&
 
Suboperations
within
the
operations
listed
above
(
see
Section
5.0).

These
operations
are
defined
in
Appendix
B
to
40
CFR
438
and
also
in
Section
4.0.

In
addition,
the
final
rule
covers
process
wastewater
resulting
from
associated
rinses
that
remove
materials
that
the
processes
listed
above
deposit
on
the
surface
of
the
work
piece.
The
final
rule
does
not
apply
to
direct
discharges
of
wastewaters
that
are
otherwise
covered
by
other
effluent
limitations
guidelines.

The
final
rule
also
covers
direct
discharges
of
process
wastewater
generated
from
oily
operations
related
to
maintenance
and
repair
of
metal
products,
parts,
and
machinery
at
military
installations
(
i.
e.,
federal
facilities)
as
well
as
facilities
owned
or
operated
by
state
or
local
governments.
For
example,
the
final
rule
covers
direct
discharges
of
process
wastewater
generated
from
oily
operations
related
to
maintenance
and
repair
of
aircraft,
cars,
trucks,
buses,
tanks
(
or
other
armor
personnel
carriers),
and
industrial
equipment.
These
operations
are
commonly
performed
at
military
installations
and
state
or
local
government
maintenance
facilities.
However,
the
final
rule
does
not
apply
to
wastewater
discharges
introduced
into
a
federally
owned
and
operated
Treatment
Works
Treating
Domestic
Sewage
(
TWTDS),
as
defined
at
40
CFR
122.2.

The
MP&
M
Point
Source
Category
evaluated
for
the
final
rule
encompasses
more
than
41,000
facilities
that
manufacture,
rebuild,
or
maintain
metal
parts,
products,
or
machines
for
use
in
the
16
MP&
M
industrial
sectors.
Approximately
29,000
of
these
facilities
annually
discharge
5.02
billion
gallons
of
process
wastewater.
Of
the
facilities
discharging
process
wastewater,
EPA
estimates
that
91.6
percent
are
indirect
dischargers,
8.4
percent
are
direct
dischargers,
and
0.1
percent
discharge
both
directly
and
indirectly.
The
Agency
estimates
that
the
remaining
facilities
(
an
estimated
12,000)
fall
into
one
of
three
categories:

1­
3
1.0
­
Summary
and
Scope
of
the
Regulation
&
Zero
discharge.
A
zero­
discharging
facility
does
not
discharge
pollutants
to
waters
of
the
United
States
or
to
a
POTW.
Included
in
this
definition
are
discharge
or
disposal
of
pollutants
by
way
of
evaporation,
deep­
well
injection,
off­
site
transfer
to
a
treatment
facility,
and
land
application.

&
Non­
water­
using.
A
non­
water­
using
facility
does
not
use
process
wastewater
(
i.
e.,
water
that
comes
into
direct
contact
with
or
results
from
the
production
or
use
of
any
raw
material,
intermediate
product,
finished
product,
by­
product,
or
waste
product)
at
its
oily
operation.

&
Contract
haulers.
Contract
hauling
is
the
removal
of
any
waste
stream
from
a
facility
by
a
company
authorized
to
transport
and
dispose
of
the
waste,
excluding
discharges
to
sewers
or
surface
waters.

The
MP&
M
final
rule
does
not
regulate
indirect
dischargers
and
discharges
to
federally
owned
and
operated
TWTDS.
There
are
approximately
2,400
direct
dischargers
regulated
by
the
MP&
M
final
rule.

MP&
M
sites
evaluated
for
the
final
rule
perform
a
wide
variety
of
process
unit
operations
on
metal
parts,
products,
or
machines.
In
general,
MP&
M
unit
operations
can
be
characterized
as
belonging
to
one
of
the
following
types
of
unit
operations:

&
 
Assembly/
disassembly
operations;

&
 
Metal
shaping
operations;

&
 
Organic
chemical
deposition
operations;

&
 
Surface
finishing
operations;
and
&
 
Surface
preparation
operations.

EPA
also
evaluated
the
following
types
of
unit
operations
but
has
decided
not
to
regulate
them
as
part
of
the
final
rule:

&
 
Dry
dock
operations;
and
&
 
Metal
deposition
operations.

Specifically,
EPA
decided
not
to
regulate
 
metal­
bearing
operations 
as
defined
in
40
CFR
438.2(
d)
and
Appendix
C
to
Part
438.
The
list
of
unit
operations
not
regulated
by
the
final
rule
is
also
given
in
Section
4.0.

At
a
given
MP&
M
facility,
the
specific
unit
operations
performed
and
the
sequence
of
those
operations
depend
on
many
factors,
including
the
activity
(
i.
e.,
manufacturing,
rebuilding,
or
maintenance),
industrial
sector,
and
type
of
product
processed.
The
extent
to
which
a
facility
uses
process
water
for
these
unit
operations
also
varies
from
site
to
site.

1­
4
1.0
­
Summary
and
Scope
of
the
Regulation
The
approximately
2,400
sites
regulated
by
the
MP&
M
final
rule
discharge
approximately
267
million
gallons
of
process
wastewater
per
year.
This
wastewater
typically
contains
total
suspended
solids,
oil
and
grease,
and
organic
pollutants.
MP&
M
wastewater
may
also
contain
some
metals
(
e.
g.,
zinc,
tin,
aluminum),
often
in
suspended
or
particulate
phase.

1.2
Overlap
with
Other
Effluent
Guidelines
EPA
has
previously
established
effluent
limitations
guidelines
and
standards
for
13
industries
that
may
perform
unit
operations
or
process
parts
that
are
sometimes
found
at
MP&
M
sites.
These
effluent
guidelines
are:

&
 
Electroplating
(
40
CFR
413);

&
 
Iron
and
Steel
Manufacturing
(
40
CFR
420);

&
 
Nonferrous
Metals
Manufacturing
(
40
CFR
421);

&
 
Ferroalloy
Manufacturing
(
40
CFR
424);

&
 
Metal
Finishing
(
40
CFR
433);

&
 
Battery
Manufacturing
(
40
CFR
461);

&
 
Metal
Molding
and
Casting
(
40
CFR
464);

&
 
Coil
Coating
(
40
CFR
465);

&
 
Porcelain
Enameling
(
40
CFR
466);

&
 
Aluminum
Forming
(
40
CFR
467);

&
 
Copper
Forming
(
40
CFR
468);

&
 
Electrical
and
Electronic
Components
(
40
CFR
469);
and
&
 
Nonferrous
Metals
Forming
&
Metal
Powders
(
40
CFR
471).

In
1986,
the
Agency
reviewed
coverage
of
these
regulations
and
identified
a
significant
number
of
metals­
processing
facilities
discharging
wastewater
that
these
13
regulations
did
not
cover.
Based
on
this
review,
EPA
performed
a
more
detailed
analysis
of
these
unregulated
sites
and
identified
the
discharge
of
significant
amounts
of
pollutants
(
see
Section
1.1
of
the
rulemaking
record,
DCN
M432).
This
analysis
resulted
in
the
decision
to
develop
national
limitations
guidelines
and
standards
for
the
 
Metal
Products
and
Machinery 
(
MP&
M)
Point
Source
Category
(
see
Section
2.2.5).

Table
1­
1
summarizes
the
coverage
of
industrial
operations
by
each
MP&
M
subcategory
for
which
EPA
proposed
regulations.
Additionally,
the
MP&
M
final
rule
does
not
apply
to
process
wastewaters
from
metal­
bearing
operations
(
as
defined
at
§
438.2(
d)
and
Appendix
C
of
Part
438)
or
process
wastewaters
that
are
subject
to
the
limitations
and
standards
of
other
effluent
limitations
guidelines
(
e.
g.,
Metal
Finishing
(
40
CFR
433)
or
Iron
and
Steel
Manufacturing
(
40
CFR
420)).

1­
5
1.0
­
Summary
and
Scope
of
the
Regulation
Table
1­
1
Clarification
of
Coverage
by
Proposed
MP&
M
Subcategory
Proposed
Subcategory
Continue
to
Cover
Under
40
CFR
413
(
Electroplating)
Continue
to
Cover
Under
40
CFR
433
(
Metal
Finishing)
Cover
Under
40
CFR
438
(
Metal
Products
&
Machinery)

General
Metals
(
Including
Continuous
Electroplaters)
Existing
indirect
dischargers
covered
by
Part
413.
New
and
existing
direct
and
indirect
dischargers
covered
by
Part
433.
None
Metal
Finishing
Job
Shops
Existing
indirect
dischargers
covered
by
Part
413.
New
and
existing
direct
and
indirect
dischargers
covered
by
Part
433.

Non­
Chromium
Anodizing
Existing
indirect
dischargers
covered
by
Part
413.
New
and
existing
direct
and
indirect
dischargers
covered
by
Part
433.

Printed
Wiring
Board
(
Printed
Circuit
Board)
Existing
indirect
dischargers
covered
by
Part
413.
New
and
existing
direct
and
indirect
dischargers
covered
by
Part
433.

Steel
Forming
and
Finishinga
NA
NA
Oily
Wastes
NA
NA
Railroad
Line
Maintenance
NA
NA
None
None
None
None
All
new
and
existing
direct
dischargers
(
see
438.10).

None
Shipbuilding
Dry
Dock
NA
NA
None
NA
­
Not
applicable.
a
These
facilities
will
remain
subject
to
40
CFR
420.

1­
6
1.0
­
Summary
and
Scope
of
the
Regulation
1.3
Summary
of
Applicability
The
MP&
M
effluent
limitations
guidelines
and
standards
regulate
process
wastewater
from
oily
operations
at
existing
or
new
direct
dischargers
engaged
in
manufacturing,
rebuilding,
or
maintenance
of
metal
parts,
products,
or
machines
used
in
any
of
the
16
industrial
sectors
listed
in
Section
1.1.
The
guidelines
and
standards
do
not
apply
to
wastewater
from
oily
operations
in
certain
circumstances
(
e.
g.,
if
they
are
subject
to
other
national
effluent
limitations
or
standards).
The
MP&
M
regulation
does
not
regulate
any
of
the
other
subcategories
for
which
it
proposed
regulations.
These
subcategories
are
the
General
Metals,
Metal
Finishing
Job
Shops,
Non­
Chromium
Anodizing,
Printed
Wiring
Board,
Steel
Forming
and
Finishing,
Railroad
Line
Maintenance,
and
Shipbuilding
Dry
Dock.
Process
wastewater
is
defined
in
§
438.2.

EPA
defines
process
wastewater
for
the
final
rule
to
include
wastewater
discharges
from
oily
operations
for
the
manufacturing,
rebuilding,
or
maintenance
of
metal
parts,
products,
or
machinery
for
use
in
any
of
the
16
MP&
M
industrial
sectors
and
wastewater
from
air
pollution
control
devices.

EPA
notes
that
direct
discharges
resulting
from
the
washing
of
cars,
aircraft,
or
other
vehicles,
when
performed
as
a
prepatory
step
prior
to
one
or
more
successive
manufacturing,
rebuilding,
or
maintenance
operations,
are
subject
to
the
MP&
M
rule.

Nonprocess
wastewater
discharges
are
not
subject
to
the
final
rule.
Nonprocess
wastewater
means
sanitary
wastewater,
noncontact
cooling
water,
water
from
laundering,
and
noncontact
stormwater.
Nonprocess
wastewater
for
this
part
also
includes
wastewater
discharges
from
nonindustrial
sources
such
as
residential
housing,
schools,
churches,
recreational
parks,
shopping
centers
as
well
as
wastewater
discharges
from
gas
stations,
utility
plants,
and
hospitals.

In
addition
to
nonprocess
wastewater,
the
final
rule
does
not
apply
to
wastewater
generated
from:
(
1)
gravure
cylinder
and
metallic
platemaking
conducted
within
or
for
printing
and
publishing
facilities;
(
2)
the
washing
of
cars,
aircraft
or
other
vehicles
when
it
is
performed
only
for
aesthetic/
cosmetic
purposes;
(
3)
MP&
M
operations
at
gasoline
stations
(
SIC
Code
5541)
or
vehicle
rental
facilities
(
SIC
Codes
7514
or
7519);
or
(
4)
unit
operations
performed
by
drum
reconditioners/
refurbishers
to
prepare
metal
drums
for
reuse.

As
noted,
EPA
is
also
not
promulgating
limitations
and
standards
for
facilities
in
the
proposed
Shipbuilding
Dry
Dock
Subcategory.
The
final
rule
does
not
cover
wastewater
generated
on­
board
ships
and
boats
when
they
are
afloat
(
that
is,
not
in
dry
docks
or
similar
structures),
flooding
water,
and
dry
dock
ballast
water
(
see
66
FR
445).
For
U.
S.
military
ships,
EPA
is
in
the
process
of
establishing
standards
to
regulate
discharges
of
wastewater
generated
on­
board
these
ships
when
they
are
in
U.
S.
waters
and
are
afloat
under
the
Uniform
National
Discharge
Standards
(
UNDS)
pursuant
to
section
312(
n)
of
the
Clean
Water
Act
(
CWA)
(
see
64
FR
25125,
May
10,
1999).

1­
7
1.0
­
Summary
and
Scope
of
the
Regulation
Finally,
as
previously
stated,
the
final
rule
does
not
apply
to
maintenance
or
repair
of
metal
parts,
products,
or
machines
that
takes
place
only
as
ancillary
activities
at
facilities
not
included
in
the
16
MP&
M
industrial
sectors.

See
Section
15.0
for
a
more
detailed
discussion
regarding
applicability.

1.4
Promulgated
Effluent
Limitations
Guidelines
and
Standards
EPA
proposed
effluent
limitations
and
standards
for
eight
subcategories.
However,
for
reasons
discussed
in
Section
9.0
and
Section
VI
of
the
preamble
to
the
final
rule,
the
final
rule
establishes
effluent
limitations
guidelines
and
standards
for
new
and
existing
direct
dischargers
in
one
subcategory:
Oily
Wastes.

EPA
may
divide
a
point
source
category
(
e.
g.,
MP&
M)
into
groupings
called
 
subcategories 
to
provide
a
method
for
addressing
variations
between
products,
raw
materials,
processes,
and
other
factors
that
result
in
distinctly
different
effluent
characteristics.
Regulation
of
a
category
using
subcategories
allows
each
subcategory
to
have
a
uniform
set
of
effluent
limitations
that
take
into
account
technological
achievability
and
economic
impacts
unique
to
that
subcategory.
Grouping
similar
facilities
into
subcategories
increases
the
likelihood
that
the
regulations
are
practicable,
and
diminishes
the
need
to
address
variations
between
facilities
through
a
variance
process.
The
CWA
requires
EPA,
in
developing
effluent
limitations
guidelines
and
pretreatment
standards,
to
consider
a
number
of
different
subcategorization
factors.
(
See
Section
6.0
for
a
list
of
the
factors
considered
for
the
final
MP&
M
rule
and
a
detailed
discussion
of
subcategorization.)

EPA
is
promulgating
concentration­
based
limits
and
standards
for
direct
dischargers
for
the
Oily
Wastes
Subcategory.
However,
the
CWA
authorizes
permit
writers
to
decide
when
it
is
most
appropriate
to
implement
mass­
based
limits.
Guidance
for
setting
limits
is
included
in
Section
15.0.

Table
1­
2
summarizes
the
regulatory
levels
of
control
and
selected
technology
bases
EPA
used
in
promulgating
the
limitations
and
standards
presented
in
Table
1­
3,
Section
14.0,
and
40
CFR
438,
Subpart
A
(
Oily
Wastes
Subcategory).
Section
15.0
provides
guidance
to
permit
writers.

1­
8
1.0
­
Summary
and
Scope
of
the
Regulation
Table
1­
2
Technology
Bases
for
Promulgated
MP&
M
Limitations
and
Standards
Regulatory
Level
Selected
Technology
Option
Subcategory
Oily
Wastes
BPT/
BCT/
NSPS
Pollution
prevention;
chemical
emulsion
breaking
and
oil/
water
separation
(
Option
6).
n
9.7.
See
Sectio
BAT
No
limitations
established
under
Part
438.

PSES/
PSNS
No
standards
established
under
Part
438.

Table
1­
3
Effluent
Limitations
Guidelines
for
the
MP&
M
Point
Source
Category
(
40
CFR
438)

BPT/
BCT/
NSPS
­
Oily
Wastes
Subcategory
Regulated
Parameter
Maximum
Daily
mg/
L
(
ppm)

Total
Suspended
Solids
(
TSS)
62
Oil
and
Grease
(
as
HEM)
46
pH
a
aDischarges
must
remain
within
the
pH
range
6
to
9.

Protection
of
Confidential
Business
Information
Whenever
EPA
is
required
to
develop
effluent
limitations,
pretreatment
standards,
or
other
standards,
Section
308(
a)
of
the
CWA
authorizes
the
Agency
to
require
owners
or
operators
of
point
sources
to
provide
certain
information.
Various
statutes
under
which
EPA
operates
contain
special
provisions
concerning
the
entitlement
to
confidential
treatment
of
certain
business
information
(
CBI).
In
compliance
with
these
statutes
and
EPA s
implementing
regulations,
the
Agency
has
withheld
CBI
from
the
public
record
in
the
Water
Docket,
but
retains
CBI
in
the
nonpublic
version
of
the
rulemaking
record.
In
addition,
the
Agency
has
withheld
from
disclosure
some
data
not
claimed
as
CBI
because
the
release
of
these
data
could
indirectly
reveal
CBI.
Furthermore,
EPA
has
aggregated
certain
data
in
the
public
record,
masked
facility
identities,
or
used
other
strategies
to
prevent
the
disclosure
of
CBI.
The
Agency s
approach
to
CBI
protection
ensures
that
the
data
in
the
public
record
both
explain
the
basis
for
the
final
rule
and
provide
the
opportunity
for
public
comment,
without
compromising
data
confidentiality.

1­
9
1.5
2.0
­
Background
2.0
BACKGROUND
This
section
presents
background
information
supporting
the
development
of
effluent
limitations
guidelines
and
standards
for
the
Metal
Products
and
Machinery
(
MP&
M)
Point
Source
Category.
Section
2.1
presents
the
legal
authority
to
regulate
the
MP&
M
industry.
Section
2.2
discusses
the
Clean
Water
Act,
Pollution
Prevention
Act,
Regulatory
Flexibility
Act
(
as
amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
of
1996),
and
prior
regulation
of
the
metals
industry.

2.1
Legal
Authority
EPA
is
promulgating
these
regulations
under
the
authority
of
Sections
301,
304,
306,
307,
308,
402,
and
501
of
the
Clean
Water
Act,
33
U.
S.
C.
1311,
1314,
1316,
1317,
1318,
1342,
and
1361
and
under
authority
of
the
Pollution
Prevention
Act
of
1990
(
PPA),
42
U.
S.
C.
13101
et
seq.,
Public
Law
101­
508,
November
5,
1990.

2.2
Regulatory
Background
2.2.1
Clean
Water
Act
Congress
adopted
the
Clean
Water
Act
(
CWA)
to
  
restore
and
maintain
the
chemical,
physical,
and
biological
integrity
of
the
Nation s
waters  
(
Section
101(
a),
33
U.
S.
C.
1251(
a)).
To
achieve
this
goal,
the
CWA
prohibits
the
discharge
of
pollutants
into
navigable
waters
except
in
compliance
with
the
statute.
The
CWA
confronts
the
problem
of
water
pollution
on
a
number
of
different
fronts.
Its
primary
reliance,
however,
is
on
establishing
restrictions
on
the
types
and
amounts
of
pollutants
discharged
from
various
industrial,
commercial,
and
public
sources
of
wastewater.

Congress
recognized
that
regulating
only
those
sources
that
discharge
effluent
directly
into
the
nation s
waters
would
not
be
sufficient
to
achieve
the
CWA s
goals.
Consequently,
the
CWA
requires
EPA
to
promulgate
nationally
applicable
pretreatment
standards
that
restrict
pollutant
discharges
for
those
who
discharge
wastewater
indirectly
through
sewers
flowing
to
publicly
owned
treatment
works
(
POTWs)
(
Sections
307(
b)
and
(
c),
33
U.
S.
C.
1317(
b)
and
(
c)).
National
pretreatment
standards
are
established
for
those
pollutants
in
wastewater
from
indirect
dischargers
that
may
pass
through
or
interfere
with
POTW
operations.
Generally,
pretreatment
standards
are
designed
to
ensure
that
wastewater
from
direct
and
indirect
industrial
dischargers
are
subject
to
similar
levels
of
treatment.
In
addition,
EPA
requires
POTWs
to
implement
local
pretreatment
limits
applicable
to
their
industrial
indirect
dischargers
to
satisfy
any
local
requirements
(
40
CFR
403.5).

Direct
dischargers
must
comply
with
effluent
limitations
in
National
Pollutant
Discharge
Elimination
System
(  
NPDES  )
permits;
indirect
dischargers
must
comply
with
pretreatment
standards.
EPA
establishes
these
limitations
and
standards
by
regulation
for
2­
1
2.0
­
Background
categories
of
industrial
dischargers
and
bases
them
on
the
degree
of
control
that
can
be
achieved
using
various
levels
of
pollution
control
technology.

1.
Best
Practicable
Control
Technology
Currently
Available
(
BPT)
(
Section
304(
b)(
1)
of
the
CWA)

BPT
effluent
limitations
guidelines
are
applicable
to
direct
dischargers
(
i.
e.,
sites
that
discharge
wastewater
to
surface
water).
BPT
effluent
limitations
guidelines
are
generally
based
on
the
average
of
the
best
existing
performance
by
facilities
of
various
sizes,
ages,
unit
processes
or
other
common
characteristics
within
the
category
or
subcategory
for
control
of
conventional,
priority,
and
nonconventional
pollutants.
Section
304(
a)(
4)
designates
the
following
as
conventional
pollutants:
biochemical
oxygen
demand
(
BOD5
),
total
suspended
solids
(
TSS),
fecal
coliform,
pH,
and
any
additional
pollutants
defined
by
the
Administrator
as
conventional.
The
Administrator
designated
oil
and
grease
as
an
additional
conventional
pollutant
on
July
30,
1979
(
44
FR
44501).
EPA
has
identified
65
pollutants
and
classes
of
pollutants
as
toxic
pollutants,
of
which
126
specific
substances
have
been
designated
priority
toxic
pollutants.
See
Appendix
A
to
Part
403
(
reprinted
after
40
CFR
423.17).
All
other
pollutants
are
considered
to
be
nonconventional.

In
establishing
BPT
effluent
limitations
guidelines,
EPA
first
considers
the
total
cost
of
applying
the
control
technology
in
relation
to
the
effluent
reduction
benefits.
The
Agency
also
considers
the
age
of
the
equipment
and
facilities
involved,
the
processes
employed
and
any
required
process
changes,
engineering
aspects
of
the
control
technologies,
non­
water
quality
environmental
impacts
(
including
energy
requirements),
and
such
other
factors
as
the
EPA
Administrator
deems
appropriate
(
CWA
304(
b)(
1)(
B)).
Traditionally,
EPA
establishes
BPT
effluent
limitations
based
on
the
average
of
the
best
performances
of
facilities
within
the
industry
of
various
ages,
sizes,
processes
or
other
common
characteristics.
Where
existing
performance
is
uniformly
inadequate,
EPA
may
require
higher
levels
of
control
than
are
currently
in
place
in
an
industrial
category
if
the
Agency
determines
that
the
technology
can
be
practically
applied.

2.
Best
Conventional
Pollutant
Control
Technology
(
BCT)
(
Section
304(
b)(
4)
of
the
CWA)

The
1977
amendments
to
the
CWA
established
BCT
for
discharges
of
conventional
pollutants
from
existing
industrial
point
sources.
BCT
effluent
limitations
guidelines
are
applicable
to
direct
discharging
sites.
In
addition
to
other
factors
specified
in
Section
304(
b)(
4)(
B),
the
CWA
requires
that
EPA
establish
BCT
limitations
after
consideration
of
a
two­

2­
2
2.0
­
Background
part
"
cost­
reasonableness"
test.
EPA
explained
its
methodology
for
the
development
of
BCT
limitations
in
1986
(
51
FR
24974;
July
9,
1986).

3.
Best
Available
Technology
Economically
Achievable
(
BAT)
(
Sections
304(
b)(
2)
of
the
CWA)

BAT
effluent
limitations
guidelines
are
applicable
to
direct
discharging
sites.
In
general,
BAT
effluent
limitations
guidelines
represent
the
best
available
economically
achievable
performance
of
plants
in
the
industrial
subcategory
or
category.
The
CWA
establishes
BAT
as
the
principal
national
means
of
controlling
the
direct
discharge
of
priority
pollutants
and
nonconventional
pollutants
to
waters
of
the
United
States.
The
factors
considered
in
assessing
BAT
include
the
cost
of
achieving
BAT
effluent
reductions,
the
age
of
equipment
and
facilities
involved,
the
processes
employed,
potential
process
changes,
non­
water
quality
environmental
impacts
(
including
energy
requirements),
and
such
factors
as
the
Administrator
deems
appropriate.
The
Agency
retains
considerable
discretion
in
assigning
the
weight
to
be
accorded
to
these
factors.
As
with
BPT,
where
existing
performance
is
uniformly
inadequate,
EPA
may
base
BAT
upon
technology
transferred
from
a
different
subcategory
within
an
industry
or
from
another
industrial
category.
In
addition,
BAT
may
include
process
changes
or
internal
controls,
even
when
these
technologies
are
not
common
industry
practice.

4.
New
Source
Performance
Standards
(
NSPS)
(
Section
306
of
the
CWA)

NSPS
are
applicable
to
new
direct
discharging
sites
and
are
based
on
the
best
available
demonstrated
treatment
technology.
New
facilities
have
the
opportunity
to
install
the
best
and
most
efficient
production
processes
and
wastewater
treatment
technologies.
As
a
result,
NSPS
should
represent
the
greatest
degree
of
effluent
reduction
attainable
through
the
application
of
the
best
available
demonstrated
control
technology
for
all
pollutants
(
i.
e.,
conventional,
nonconventional,
and
priority
pollutants).
In
establishing
NSPS,
the
CWA
directs
EPA
to
take
into
consideration
the
cost
of
achieving
the
effluent
pollutant
reduction
and
any
non­
water
quality
environmental
impacts
(
including
energy
requirements).

5.
Pretreatment
Standards
for
Existing
Sources
(
PSES)
(
Section
307(
b)
of
the
CWA)

PSES
are
applicable
to
indirect
discharging
sites
(
i.
e.,
sites
that
discharge
to
a
POTW).
The
CWA
requires
PSES
for
pollutants
that
pass
through,
interfere
with,
or
are
otherwise
incompatible
with
POTW
treatment
2­
3
2.0
­
Background
processes
or
sludge
disposal
methods.
The
CWA
specifies
that
pretreatment
standards
are
to
be
technology­
based
and
analogous
to
the
BAT
effluent
limitations
guidelines.

The
General
Pretreatment
Standards,
which
set
forth
the
framework
for
implementing
categorical
pretreatment
standards,
are
found
at
40
CFR
403.

6.
Pretreatment
Standards
for
New
Sources
(
PSNS)
(
Section
307(
c)
of
the
CWA)

PSNS
are
applicable
to
new
indirect
discharging
sites.
Like
PSES,
PSNS
are
designed
to
prevent
the
discharges
of
pollutants
that
pass
through,
interfere
with,
or
are
otherwise
incompatible
with
the
operation
of
POTWs.
PSNS
are
to
be
issued
at
the
same
time
as
NSPS.
New
indirect
dischargers
have
the
opportunity
to
incorporate
into
their
plants
the
best
available
demonstrated
technologies.
The
Agency
considers
the
same
factors
in
promulgating
PSNS
that
it
considers
in
promulgating
NSPS.

The
following
table
summarizes
these
regulatory
levels
of
control
and
the
pollutants
controlled.

Table
2­
1
Summary
of
Regulatory
Levels
of
Control
Type
of
Sites
Regulated
BPT
BCT
BAT
NSPS
PSES
PSNS
Existing
Direct
Dischargers
New
Direct
Dischargers
Existing
Indirect
Dischargers
New
Indirect
Dischargers
X
X
X
X
X
X
Pollutants
Regulated
BPT
BCT
BAT
NSPS
PSES
PSNS
Priority
Pollutants
Nonconventional
Pollutants
Conventional
Pollutants
X
X
X
X
X
X
X
X
X
X
X
X
X
Source:
Clean
Water
Act.

EPA
typically
does
not
establish
pretreatment
standards
for
conventional
pollutants
(
e.
g.,
BOD5
,
TSS,
oil
and
grease)
since
POTWs
are
designed
to
treat
these
pollutants,
but
EPA
has
exercised
its
authority
to
establish
categorical
pretreatment
standards
for
conventional
pollutants
as
surrogates
for
toxic
or
nonconventional
pollutants
or
to
prevent
interference.
For
example,
EPA
established
categorical
pretreatment
standards
for
new
and
existing
sources
with
a
one­
day
maximum
concentration
of
100
mg/
L
oil
and
grease
in
the
2­
4
2.0
­
Background
Petroleum
Refining
Point
Source
Category
(
40
CFR
419)
to
"
minimize
the
possibility
of
slug
loadings
of
oil
and
grease
being
discharged
to
POTWs"
(
see
Section
24.4
of
the
rulemaking
record,
DCN
17949).

2.2.2
Section
304(
m)
Requirements
Section
304(
m)
of
the
CWA,
added
by
the
Water
Quality
Act
of
1987,
requires
EPA
to
establish
schedules
for:
(
1)
reviewing
and
revising
existing
effluent
limitations
guidelines
and
standards;
and
(
2)
promulgating
new
effluent
guidelines.
On
January
2,
1990,
EPA
published
an
Effluent
Guidelines
Plan
(
see
55
FR
80),
in
which
schedules
were
established
for
developing
new
and
revised
effluent
guidelines
for
several
industry
categories,
including
the
metal
products
and
machinery
industry.

Natural
Resources
Defense
Council,
Inc.
(
NRDC)
and
Public
Citizen,
Inc.
challenged
the
Effluent
Guidelines
Plan
in
a
suit
filed
in
the
U.
S.
District
Court
for
the
District
of
Columbia,
(
NRDC
et
al
v.
Browner,
Civ.
No.
89­
2980).
On
January
31,
1992,
the
Court
entered
a
consent
decree
(
the
"
304(
m)
Decree"),
which
establishes
schedules
for,
among
other
things,
EPA's
proposal
and
promulgation
of
effluent
guidelines
for
a
number
of
point
source
categories.
The
consent
decree,
as
amended,
requires
EPA
to
take
final
action
on
the
Metal
Products
and
Machinery
effluent
guidelines
by
February
14,
2003.

2.2.3
Pollution
Prevention
Act
The
Pollution
Prevention
Act
of
1990
(
PPA)
(
42
U.
S.
C.
13101
et
seq.,
Public
Law
101­
508,
November
5,
1990)
"
declares
it
to
be
the
national
policy
of
the
United
States
that
pollution
should
be
prevented
or
reduced
whenever
feasible;
pollution
that
cannot
be
prevented
should
be
recycled
in
an
environmentally
safe
manner,
whenever
feasible;
pollution
that
cannot
be
prevented
or
recycled
should
be
treated
in
an
environmentally
safe
manner
whenever
feasible;
and
disposal
or
release
into
the
environment
should
be
employed
only
as
a
last
resort..."
(
Sec.
6602;
42
U.
S.
C.
13101
(
b)).
In
short,
preventing
pollution
before
it
is
created
is
preferable
to
trying
to
manage,
treat
or
dispose
of
it
after
it
is
created.
The
PPA
directs
the
Agency
to,
among
other
things,
"
review
regulations
of
the
Agency
prior
and
subsequent
to
their
proposal
to
determine
their
effect
on
source
reduction"
(
Sec.
6604;
42
U.
S.
C.
13103(
b)(
2)).
EPA
reviewed
this
effluent
guideline
for
its
incorporation
of
pollution
prevention.

According
to
the
PPA,
source
reduction
reduces
the
generation
and
release
of
hazardous
substances,
pollutants,
wastes,
contaminants,
or
residuals
at
the
source,
usually
within
a
process.
The
term
source
reduction
"
include[
s]
equipment
or
technology
modifications,
process
or
procedure
modifications,
reformulation
or
redesign
of
products,
substitution
of
raw
materials,
and
improvements
in
housekeeping,
maintenance,
training
or
inventory
control.
The
term
 
source
reduction'
does
not
include
any
practice
which
alters
the
physical,
chemical,
or
biological
characteristics
or
the
volume
of
a
hazardous
substance,
pollutant,
or
contaminant
through
a
process
or
activity
which
itself
is
not
integral
to
or
necessary
for
the
production
of
a
product
or
the
providing
of
a
service."
42
U.
S.
C.
13102(
5).
In
effect,
source
reduction
means
reducing
the
2­
5
2.0
­
Background
amount
of
a
pollutant
that
enters
a
waste
stream
or
that
is
otherwise
released
into
the
environment
prior
to
out­
of­
process
recycling,
treatment,
or
disposal.

EPA
gathered
information
on
pollution
prevention
practices
used
by
the
MP&
M
industry
from
site
visits,
survey
responses,
and
other
references.
Typical
pollution
prevention
practices
include
reducing
water
use,
extending
the
life
of
process
bath
constituents,
or
adding
recycle
or
reuse
technologies.
See
Section
8.0
for
a
detailed
discussion
of
these
practices.
EPA
supports
pollution
prevention
technology
by
including
pollution
prevention
in
its
technology
bases
for
the
final
MP&
M
effluent
limitations
and
new
source
performance
standards.
This
includes
water
conservation
and
reuse
of
lubricants
and
solvents.
Technology
options
considered,
as
well
as
selected,
as
the
basis
for
the
MP&
M
effluent
limitations
guidelines
and
standards
include
pollution
prevention
practices
and
are
discussed
in
Section
9.0.

2.2.4
Regulatory
Flexibility
Act
(
RFA)
as
Amended
by
the
Small
Business
Regulatory
Enforcement
Fairness
Act
of
1996
(
SBREFA)

The
RFA
generally
requires
an
agency
to
prepare
a
regulatory
flexibility
analysis
of
any
rule
subject
to
notice
and
comment
rulemaking
requirements
under
the
Administrative
Procedure
Act
or
any
other
statute
unless
the
agency
certifies
that
the
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
Small
entities
include
small
businesses,
small
organizations,
and
small
governmental
jurisdictions.

For
assessing
the
impacts
of
the
final
rule
on
small
entities,
a
small
entity
is
defined
as:
(
1)
a
small
business
according
to
the
Regulations
of
the
Small
Business
Administration
(
SBA)
at
13
CFR
121.201,
which
define
small
businesses
for
Standard
Industrial
Classification
(
SIC)
codes;
(
2)
a
small
governmental
jurisdiction
that
is
a
government
of
a
city,
county,
town,
school
district
or
special
district
with
a
population
of
less
than
50,000;
and
(
3)
a
small
organization
that
is
any
not­
for­
profit
enterprise
that
is
independently
owned
and
operated
and
is
not
dominant
in
its
field.

In
accordance
with
Section
603
of
the
RFA,
EPA
prepared
an
initial
regulatory
flexibility
analysis
(
IRFA)
for
the
proposed
rule
and
convened
a
Small
Business
Advocacy
Review
Panel
to
obtain
advice
and
recommendations
of
representatives
of
the
regulated
small
entities
in
accordance
with
Section
609(
b)
of
the
RFA
(
see
66
FR
519).
The
results
of
IRFA
are
provided
in
Chapter
10
of
the
Economic,
Environmental,
and
Benefits
Analysis
(
EEBA)
(
EPA­
821­
B­
03­
002).
The
January
2001
proposed
rule
(
see
66
FR
523)
presents
a
summary
of
the
Panel s
recommendations
and
the
full
Panel
Report
(
see
Section
11.2,
DCN
16127)
presents
a
detailed
discussion
of
the
Panel s
advice
and
recommendations.

A
regulatory
flexibility
analysis
addresses:

 
The
need
for,
objectives
of,
and
legal
basis
for
a
rule.

2­
6
2.0
­
Background
 
A
description
of,
and
where
feasible,
an
estimate
of
the
number
of
small
entities
to
which
a
rule
would
apply.

 
The
projected
reporting,
recordkeeping,
and
other
compliance
requirements
of
a
rule,
including
an
estimate
of
the
classes
of
small
entities
that
would
be
subject
to
a
rule
and
the
types
of
professional
skills
necessary
for
preparation
of
the
report
or
record.

 
An
identification,
where
practicable,
of
all
relevant
federal
rules
that
may
duplicate,
overlap,
or
conflict
with
a
rule.

 
A
description
of
any
significant
regulatory
alternatives
to
a
rule
that
accomplish
the
stated
objectives
of
applicable
statutes
and
that
minimize
any
significant
economic
impact
of
a
rule
on
small
entities.
Consistent
with
the
stated
objectives
of
the
CWA,
the
analysis
discusses
significant
alternatives
such
as:

­
Establishing
differing
compliance
or
reporting
requirements
or
timetables
that
take
into
account
the
resources
available
to
small
entities.

­
Clarifying,
consolidating,
or
simplifying
compliance
and
reporting
requirements
under
the
rule
for
such
small
entities.

­
Using
performance
rather
than
design
standards.

­
Excluding
from
coverage
of
a
rule,
or
any
part
thereof,
such
small
entities.
Based
on
the
regulatory
flexibility
analysis
and
other
factors,
EPA
considered
an
exclusion
to
eliminate
disproportionate
impacts
on
small
businesses,
which
reduced
the
number
of
small
businesses
that
would
be
affected
by
a
rule.

The
Small
Business
Advocacy
Review
Panel
comprised
representatives
from
three
federal
agencies:
EPA,
the
Small
Business
Administration,
and
the
Office
of
Management
and
Budget.
The
Panel
reviewed
materials
EPA
prepared
in
connection
with
the
proposed
rule
IRFA,
and
collected
the
advice
and
recommendations
of
small
entity
representatives.
For
the
Small
Business
Advocacy
Review
Panel,
the
small
entity
representatives
included
nine
small
MP&
M
facility
owner/
operators,
one
small
municipality,
and
these
six
trade
associations
representing
different
sectors
of
the
industry:

 
National
Association
of
Metal
Finishers
(
NAMF)/
Association
of
Electroplaters
and
Surface
Finishers
(
AESF)/
MP&
M
Coalition;

 
Association
Connecting
Electronics
Industries
(
also
known
as
IPC);

2­
7
2.0
­
Background
 
Porcelain
Enamel
Institute;

 
American
Short
Line
Railroad
Association
(
ASLRA);

 
Electronics
Industry
Association
(
EIA);
and
 
American
Wire
Producers
Association
(
AWPA).

The
Panel
provided
background
information
and
analysis
to
the
small
entity
representatives
and
conducted
meetings
with
the
representatives.
The
Panel
asked
the
small
entity
representatives
to
submit
written
comment
on
the
MP&
M
proposed
rule
in
relation
to
the
elements
of
the
proposal
IRFA.
The
Panel
carefully
considered
these
comments
when
developing
their
recommendations.
The
Panel s
report
summarizes
their
outreach
to
small
entities
and
the
comments
submitted
by
the
small
entity
representatives.
The
Panel s
report
also
presented
their
findings
on
issues
related
to
the
elements
of
the
proposal
IRFA
and
recommendations
regarding
the
rulemaking.
Based
on
this
input,
EPA
made
several
changes
to
the
January
2001
proposal
that
reduced
the
number
of
small
entities
regulated
and
the
level
of
impact
to
small
entities
that
remain
within
the
scope
of
the
regulation.

In
the
final
rule,
EPA
excluded
direct
dischargers
in
seven
of
eight
proposed
subcategories
and
indirect
dischargers
in
all
eight
proposed
subcategories.
Consequently,
EPA
excluded
most
small
entities
from
additional
regulation
(
see
Section
VI
of
the
MP&
M
preamble
to
the
final
rule
and
Chapter
10
of
the
EEBA).
To
assess
the
potential
economic
impact
of
the
final
rule
on
small
entities
regulated
by
the
final
rule,
EPA
drew
on:
(
1)
a
comparison
of
compliance
costs
to
revenue;
and
(
2)
the
firm
and
facility
impact
analyses
discussed
in
Chapters
9
and
10
of
the
EEBA.

First,
EPA
performed
an
analysis
comparing
annualized
compliance
costs
to
revenue
for
small
entities
at
the
firm
level.
EPA
found
that
none
of
the
small
firms
are
estimated
to
incur
compliance
costs
equaling
or
exceeding
one
percent
of
annual
revenue.
Second,
EPA
drew
on
the
facility
impact
analysis,
which
estimated
facility
closures
and
other
adverse
changes
to
financial
condition
(
referred
to
as
 
moderate
impacts ).
See
Chapter
5
of
the
EEBA
for
details
of
EPA s
analysis
of
closures
and
moderate
impacts
for
privately
owned
businesses.
This
analysis
indicated
that
the
final
rule
would
cause
no
regulated
facilities
owned
by
small
entities
to
close
or
to
incur
moderate
impacts.
From
these
analyses,
EPA
determined
that
the
final
rule
will
not
have
a
significant
economic
impact
on
a
substantial
number
of
small
entities.
See
Chapter
10
of
the
EEBA
for
the
final
rule
for
a
more
detailed
discussion
of
the
economic
impacts
on
small
entities.

2.2.5
Regulatory
History
of
the
Metals
Industry
EPA
has
promulgated
effluent
limitations
guidelines
and
standards
for
13
metals
industries.
These
regulations
cover
metal
manufacturing,
metal
forming,
and
component
finishing,
as
summarized
below.

2­
8
2.0
­
Background
Table
2­
2
Summary
of
Metals
Industry
Effluent
Guidelines
Coverage
Area
Title
CFR
Reference
Metal
and
Metal
Alloy
Manufacturing
Iron
and
Steel
Manufacturinga
Nonferrous
Metals
Manufacturing
Ferroalloy
Manufacturing
40
CFR
420
40
CFR
421
40
CFR
424
Metal
Forming
Iron
and
Steel
Manufacturinga
Metal
Molding
and
Casting
Aluminum
Forming
Copper
Forming
Nonferrous
Metals
Forming
and
Metal
Powders
40
CFR
420
40
CFR
464
40
CFR
467
40
CFR
468
40
CFR
471
Component
Finishing
Electroplating
Iron
and
Steel
Manufacturinga
Metal
Finishing
Battery
Manufacturing
Coil
Coating
Porcelain
Enameling
Electrical
and
Electronic
Component
Manufacturing
40
CFR
413
40
CFR
420
40
CFR
433
40
CFR
461
40
CFR
465
40
CFR
466
40
CFR
469
Source:
Code
of
Federal
Regulations
,
Part
40.
a
The
Iron
and
Steel
Manufacturing
category
includes
metal
manufacturing,
metal
forming,
and
component
finishing.

In
1986,
the
Agency
reviewed
these
13
regulations
and
identified
a
significant
number
of
metals­
processing
facilities
discharging
wastewater
that
these
regulations
did
not
cover.
Based
on
this
review,
EPA
performed
a
detailed
analysis
of
these
unregulated
sites
and
identified
the
discharge
of
significant
amounts
of
pollutants.
This
analysis
resulted
in
a
preliminary
decision
to
consider
new
regulations
for
a
Machinery
Manufacturing
and
Rebuilding
(
MM&
R)
Point
Source
Category.
In
1989,
the
Agency
published
a
Preliminary
Data
Summary
(
PDS)
for
the
MM&
R
industry,
which
is
located
in
the
MP&
M
Public
Record
(
Section
1.1,
DCN
M432).
The
preliminary
study
of
the
unregulated
MP&
M
facilities
indicated
the
following:

 
The
number
of
facilities,
wastewater
flow,
and
toxic
and
nonconventional
pollutant
loads
were
significant;

 
The
large
quantities
of
toxic
pollutants
discharged
threatened
the
treatment
capability
of
many
POTWs
as
found
by
the
Domestic
Sewage
Study;

 
There
were
gaps
in
federal
regulatory
coverage
in
the
electroplating,
metal
finishing,
and
electrical
and
electronic
components
categories;

 
Pollutant
concentrations
were
at
treatable
levels
and
at
levels
as
high
and
sometimes
higher
than
concentrations
in
wastewater
from
other
regulated
categories;
and
2­
9
2.0
­
Background
 
Some
MP&
M
operations
generate
hazardous
solid
waste
and
sludge
that
could
impact
hazardous
waste
disposal.

Based
on
information
contained
in
the
PDS,
EPA
divided
the
MM&
R
category
into
two
phases
by
major
industrial
groups
or
sectors.
The
Agency
announced
its
schedule
for
the
development
of
effluent
guidelines
for
two
separate
MM&
R
phases
in
EPA s
January
2,
1990
Effluent
Guidelines
Plan
(
55
FR
80).
One
of
the
primary
reasons
for
dividing
the
category
into
two
phases
was
the
large
number
of
facilities
(
over
900,000)
identified
in
the
PDS
as
potentially
included
in
the
MM&
R
Point
Source
Category.
On
May
7,
1992,
EPA
changed
the
category
name
to
Metal
Products
and
Machinery
(
MP&
M)
to
clarify
the
coverage
of
the
category
(
57
FR
19748).
Many
questionnaire
respondents
found
the
MM&
R
label
confusing
and
interpreted
the
category
to
apply
only
to
machinery
sites.
The
Agency
believes
that
the
MP&
M
title
more
accurately
describes
the
coverage
of
the
category.

As
mentioned
in
Section
2.2.2,
NRDC
and
Public
Citizen,
Inc.
challenged
the
Effluent
Guidelines
Plan
in
a
suit
filed
in
U.
S.
District
Court
for
the
District
of
Columbia
(
NRDC
et
al.
v.
Browner,
Civ.
No.
89­
2980).
Under
a
consent
decree
in
this
litigation,
EPA
developed
a
plan
to
promulgate
effluent
guidelines
for,
among
others,
the
MP&
M
Point
Source
Category.
The
1992
Effluent
Guidelines
Plan
provided
for
EPA
to
propose
effluent
guidelines
for
the
MP&
M
Phase
I
Category
by
November
1994
and
take
final
action
by
May
1996.
Based
on
a
motion
filed
by
EPA
on
September
28,
1994,
the
court
granted
an
extension
for
proposal
and
promulgation
of
the
final
regulation.
To
make
the
regulation
more
manageable,
EPA
initially
divided
the
industry
into
two
phases
based
on
industrial
sectors.
The
Phase
I
proposal
included
the
following
industry
sectors:
Aerospace;
Aircraft;
Electronic
Equipment;
Hardware;
Mobile
Industrial
Equipment;
Ordnance;
and
Stationary
Industrial
Equipment.
At
that
time,
EPA
planned
to
propose
a
rule
for
the
Phase
II
sectors
approximately
three
years
after
the
MP&
M
Phase
I
proposal.
Phase
II
sectors
included:
Bus
&
Truck,
Household
Equipment,
Instruments,
Job
Shops,
Motor
Vehicles,
Office
Machines,
Precious
Metals
and
Jewelry,
Printed
Wiring
Boards,
Railroad,
Ships
and
Boats,
and
Miscellaneous
Metal
Products.

On
May
30,
1995,
EPA
published
the
MP&
M
Phase
I
proposal
(
60
FR
28210).
EPA
proposed
effluent
limitations
guidelines,
pretreatment
standards,
and
new
source
performance
standards
for
the
seven
MP&
M
Phase
I
industrial
sectors.
EPA
received
over
350
public
comments
on
the
Phase
I
proposal
requesting
that
the
Agency
combine
all
MP&
M
industrial
sectors
into
one
effluent
guideline.
Commentors
raised
concerns
regarding
the
regulation
of
similar
facilities
with
different
compliance
schedules
and
potentially
different
limitations
solely
based
on
whether
they
were
in
a
Phase
I
or
Phase
II
MP&
M
industrial
sector.
Furthermore,
many
facilities
performed
work
in
multiple
sectors.
In
such
cases,
permit
writers
and
control
authorities
(
e.
g.,
POTWs)
would
need
to
decide
which
MP&
M
rule
(
Phase
I
or
II)
applied
to
a
facility.

Based
on
these
comments
and
after
negotiations
with
NRDC,
EPA
proposed
merging
the
two
phases
into
one
rule
(
61
FR
35042;
July
3,
1996).
In
1997,
EPA
obtained
approval
from
the
U.
S.
District
Court
for
the
District
of
Columbia
to
combine
MP&
M
Phases
I
2­
10
2.0
­
Background
and
II
into
a
single
regulation
for
the
18
MP&
M
industrial
sectors
and
to
extend
the
effluent
guidelines
schedule
(
62
FR
8726;
February
26,
1997).
Extension
of
the
schedule
allowed
EPA
to
use
POTW
survey
data
to
develop
more
precise
estimates
of
administrative
burden
and
allowed
more
extensive
stakeholder
involvement
for
data
collection.
Under
the
Consent
Decree
as
amended,
EPA
is
required
to
take
final
action
on
the
MP&
M
rule
by
February
14,
2003.

EPA
published
a
new
proposal
on
January
3,
2001
(
66
FR
424),
which
completely
replaced
the
1995
proposal.
EPA
proposed
to
establish
new
effluent
limitations
and
guidelines
and
standards
for
18
MP&
M
industrial
sectors
(
without
any
designation
of
 
Phase
I
or
II )
and
divided
the
industry
into
eight
regulatory
subcategories:
General
Metals,
Metal
Finishing
Job
Shops,
Printed
Wiring
Board,
Non­
Chromium
Anodizing,
Steel
Forming
and
Finishing,
Oily
Wastes,
Railroad
Line
Maintenance,
and
Shipbuilding
Dry
Dock
(
see
66
FR
439
for
a
discussion
of
the
proposal
subcategorization
scheme).

EPA
found
two
basic
types
of
waste
streams
in
the
industry:
(
1)
wastewater
with
high
metals
content
(
metal­
bearing),
and
(
2)
wastewater
with
low
concentration
of
metals
and
high
oil
and
grease
content
(
oil­
bearing).
When
looking
at
facilities
generating
metal­
bearing
wastewater
(
with
or
without
oil­
bearing
wastewater),
EPA
identified
five
groups
of
facilities
that
could
potentially
be
subcategorized
by
dominant
product,
raw
materials
used,
and/
or
nature
of
the
waste
generated
(
i.
e.,
General
Metals,
Metal
Finishing
Job
Shops,
Printed
Wiring
Board,
Non­
Chromium
Anodizing,
and
Steel
Forming
and
Finishing).
When
evaluating
facilities
with
only
oil­
bearing
wastewater
for
potential
further
subcategorization,
EPA
identified
two
types
of
facilities
(
i.
e.,
Railroad
Line
Maintenance
and
Shipbuilding
Dry
Dock)
that
were
different
from
the
other
facilities
in
the
Oily
Wastes
Subcategory
based
on
size,
location,
and
dominant
product
or
activity.
This
subcategorization
scheme
allowed
EPA
to
more
accurately
assess
various
technology
options
in
terms
of
compliance
costs,
pollutant
reductions,
benefits,
and
economic
impacts.

EPA
proposed
new
limits
and
standards
for
direct
dischargers
in
all
eight
MP&
M
subcategories
and
proposed
pretreatment
standards
for
all
indirect
dischargers
in
three
subcategories
(
i.
e.,
Metal
Finishing
Job
Shops,
Printed
Wiring
Board,
and
Steel
Forming
and
Finishing);
pretreatment
standards
for
facilities
above
a
certain
wastewater
flow
volume
in
two
subcategories
(
i.
e.,
General
Metals
and
Oily
Wastes);
and
no
national
pretreatment
standards
for
facilities
in
three
subcategories
(
i.
e.,
Non­
Chromium
Anodizing,
Railroad
Line
Maintenance,
and
Shipbuilding
Dry
Dock).
EPA
received
over
1,500
comment
letters
on
the
2001
proposal.

On
June
5,
2002,
EPA
published
a
Notice
of
Data
Availability
(
NODA)
at
67
FR
38752.
In
the
NODA,
EPA
discussed
major
issues
raised
in
comments
on
the
2001
proposal;
suggested
revisions
to
the
technical
and
economic
methodologies
used
to
estimate
compliance
costs,
pollutant
loadings,
and
economic
and
environmental
impacts;
presented
the
results
of
these
suggested
methodology
changes
and
incorporation
of
new
(
or
revised)
data;
and
summarized
the
Agency s
thinking
on
how
these
results
could
affect
the
Agency s
final
decisions.

2­
11
2.0
­
Background
The
NODA
also
included
a
discussion
of
possible
alternative
options
for
certain
subcategories
based
on
comments,
including
an
Environmental
Management
System
(
EMS)
alternative
in
lieu
of
Part
438
limitations
and
standards,
and
a
discussion
of
 
upgrading 
sites
currently
regulated
under
the
Electroplating
regulations
(
40
CFR
413)
to
meet
the
Metal
Finishing
regulations
(
40
CFR
433)
(
see
67
FR
38797).
Finally,
the
NODA
included
preliminary
revised
effluent
limitations
and
pretreatment
standards
for
all
eight
proposed
subcategories.
EPA
received
over
300
comment
letters
on
the
NODA.
EPA s
responses
to
comments
on
the
May
1995
proposal,
January
2001
proposal,
and
June
2002
NODA
can
be
found
in
Section
20.3
of
the
rulemaking
record.

2­
12
3.0
­
Data
Collection
Activities
3.0
DATA
COLLECTION
ACTIVITIES
This
section
summarizes
the
Agency s
data
collection
activities
for
the
MP&
M
rulemaking
effort.
Section
3.1
summarizes
the
1989
and
1996
MP&
M
industry
questionnaires
including
their
purpose,
recipient
selection
process,
types
of
information
collected,
and
uses
of
data.
Sections
3.2
and
3.3
summarize
the
site
visit
and
field
sampling
programs,
respectively,
conducted
at
facilities
performing
proposed
MP&
M
operations.
1
Sections
3.4,
3.5,
and
3.6
discuss
other
data
sources.

3.1
Industry
Questionnaires
EPA
distributed
two
screener
and
six
detailed
questionnaires
(
surveys)
as
part
of
the
data
collection
effort
for
the
MP&
M
rulemaking.
As
discussed
in
Section
2.0,
EPA
initially
divided
the
MP&
M
Point
Source
Category
into
two
phases
by
major
industrial
sectors.
The
surveys
distributed
for
the
seven
Phase
I
industrial
sectors
requested
data
reflecting
1989
operations,
and
the
surveys
distributed
for
the
11
Phase
II
industrial
sectors
requested
data
reflecting
1996
operations.
The
table
below
lists
the
industry
surveys
and
the
distribution
dates.
Sections
3.1.1
and
3.1.2
discuss
these
questionnaire
efforts.

Distribution
of
the
MP&
M
Industry
Surveys
Type
of
Survey
Survey
Name
Distribution
Date
Screener
1989
Screener
Survey
1996
Screener
Survey
1996
Benefits
Screener
8/
90
12/
96
10/
98
Detailed
1989
Detailed
Survey
1996
Long
Detailed
Survey
1996
Short
Detailed
Survey
1996
Municipality
Detailed
Survey
1996
POTW
Detailed
Survey
1996
Federal
Detailed
Survey
1/
91
6/
97
9/
97
6/
97
11/
97
4/
98
During
the
same
time
that
EPA
was
developing
the
MP&
M
Point
Source
Category
rulemaking,
EPA
was
also
updating
the
effluent
limitations
guidelines
and
standards
for
the
Iron
and
Steel
Point
Source
Category.
As
part
of
the
revised
Iron
and
Steel
rulemaking,
EPA
distributed
detailed
and
short
surveys
to
iron
and
steel
facilities.
Following
receipt
of
the
1997
Iron
and
Steel
Surveys,
EPA
evaluated
whether
some
facilities
may
be
more
appropriately
covered
under
the
MP&
M
Point
Source
Category.

1Note:
EPA
evaluated
a
number
of
unit
operations
for
the
May
1995
proposal,
January
2001
proposal,
and
June
2002
NODA
(
see
Tables
4­
3
and
4­
4).
However,
EPA
selected
a
subset
of
these
unit
operations
for
regulation
in
the
final
rule
(
see
Section
1.0).
For
this
Section,
the
term
 
proposed
MP&
M
operations 
means
those
operations
evaluated
for
the
two
proposals,
NODA,
and
final
rule.
The
term
 
final
MP&
M
operations 
means
those
operations
defined
as
 
oily
operations 
(
see
Section
1.0,
40
CFR
438.2(
f),
and
Appendix
B
to
Part
438)
and
regulated
by
the
final
rule.

3­
1
3.0
­
Data
Collection
Activities
EPA
included
data
from
154
iron
and
steel
surveys
in
the
MP&
M
survey
database
and
proposed
to
create
a
new
subcategory,
the
Steel
Forming
and
Finishing
Subcategory
in
the
MP&
M
Point
Source
Category
(
see
66
FR
424).
Based
on
comments
on
the
January
2001
proposal
and
June
2002
NODA
EPA
concluded
that
those
operations
included
in
the
proposed
Steel
Forming
and
Finishing
Subcategory
should
remain
subject
to
effluent
guidelines
at
the
Iron
and
Steel
Point
Source
Category
(
40
CFR
420).
See
Section
6.0
for
further
discussion
of
subcategorization.

For
this
final
rule,
EPA
also
evaluated
portions
of
the
iron
and
steel
surveys
to
determine
if
continuous
electroplaters
would
be
more
appropriately
covered
under
the
MP&
M
Point
Source
Category,
as
described
in
the
Notice
of
Data
Availability
(
NODA)
(
67
FR
38752;
June
5,
2002).
EPA
included
these
facilities
in
the
General
Metals
Subcategory
for
evaluating
options
for
the
final
rule.
See
Section
6.0
for
further
discussion
of
this
determination.
EPA
has
data
for
47
continuous
electroplating
lines
at
24
sites.
The
data
for
these
lines
were
evaluated
in
developing
the
final
MP&
M
effluent
limitation
guidelines
and
standards
(
see
Section
3.1.3
for
further
discussion).
A
blank
copy
of
the
Iron
and
Steel
Surveys
and
the
relevant
data
from
the
24
surveys
are
available
in
Section
5.3.6,
DCN
16147
and
Section
15.4.3
of
the
rulemaking
record.

3.1.1
The
1989
Industry
Surveys
EPA
distributed
a
screener
and
a
detailed
survey
for
the
Phase
I
MP&
M
proposed
regulation
to
manufacturing,
rebuilding,
and/
or
maintenance
facilities
engaged
in
the
following
seven
industrial
sectors:

 
Aerospace;

 
Aircraft;

 
Electronic
Equipment;

 
Hardware;

 
Mobile
Industrial
Equipment;

 
Ordnance;
and
 
Stationary
Industrial
Equipment.

The
1989
screener
and
detailed
surveys
are
discussed
below.
EPA
describes
in
detail
the
recipient
selection,
stratification
schemes,
and
the
type
and
potential
use
of
the
requested
information
in
the
Information
Collection
Request
(
ICR)
for
the
1989
screener
and
detailed
MP&
M
industry
surveys.
The
ICR
can
be
found
in
Section
3.6.2
of
the
rulemaking
record,
DCN
M15738.

3.1.1.1
1989
Screener
Survey
In
August
and
September
1990,
EPA
mailed
8,342
screener
surveys
(
also
referred
to
as
the
Mini
Data
Collection
Portfolio
(
MDCP))
to
sites
believed
to
be
engaged
in
manufacturing,
rebuilding,
or
maintenance
activities
in
one
of
the
seven
industrial
sectors
listed
above.
Mailout
of
the
screener
was
the
preliminary
step
in
an
extensive
data­
gathering
effort
for
3­
2
3.0
­
Data
Collection
Activities
these
seven
industrial
sectors.
The
purpose
of
the
screener
was
to
identify
sites
to
receive
the
more
detailed
survey
and
to
make
a
preliminary
assessment
of
these
seven
industrial
sectors.

1989
Screener
Recipient
Selection
and
Distribution
EPA
identified
potential
recipients
from
a
Dun
&
Bradstreet
database
using
Standard
Industrial
Classification
(
SIC)
codes.
The
Agency
identified
more
than
190
SIC
codes
applicable
to
the
seven
industrial
sectors
listed
in
Section
3.1.1.
Within
each
sector,
EPA
identified
between
1
and
40
SIC
codes.
EPA
calculated
the
number
of
sites
to
receive
the
screener
within
each
SIC
code
by
a
coefficient
of
variation
(
CV)
minimization
procedure,
described
in
the
Statistical
Summary
for
the
Metal
Products
&
Machinery
Industry
Surveys
(
Section
10.0,
DCN
16118).
Based
on
the
number
of
sites
selected
within
each
SIC
code,
the
Agency
purchased
a
list
of
randomly
selected
names
and
addresses
from
the
Dun
&
Bradstreet
database
for
each
SIC
code.
This
list
included
twice
the
number
of
sites
specified
by
the
CV
minimization
procedure
for
each
SIC
code.

EPA
deleted
sites
from
the
purchased
Dun
&
Bradstreet
list
for
the
following
reasons:
sites
had
SIC
codes
that
were
inconsistent
with
company
names;
sites
were
corporate
headquarters
without
manufacturing,
rebuilding,
or
maintenance
operations;
or
sites
had
insufficient
mailing
addresses.
EPA
then
randomly
selected
30
to
60
sites
within
each
SIC
code
and
assigned
each
site
a
randomly
selected
identification
number.
EPA
assigned
each
site
identification
number
a
corresponding
barcode
to
track
the
distribution
and
processing
of
the
screeners.

To
examine
trends
and
similarities
in
manufacturing
across
the
industry
sectors,
EPA
also
sent
screener
surveys
to
some
facilities
performing
manufacturing
in
the
following
eight
industrial
sectors:

 
Bus
and
Truck;

 
Household
Equipment;

 
Instruments;

 
Motor
Vehicles;

 
Office
Machines;

 
Precious
and
Nonprecious
Metals;

 
Railroad;
and
 
Ships
and
Boats.

The
Agency
did
not
send
the
screener
to
sites
whose
SIC
codes
indicated
that
they
were
engaged
in
only
rebuilding
or
maintenance
(
i.
e.,
not
manufacturing)
operations
in
the
eight
industrial
sectors
listed
above.

EPA
maintained
a
toll­
free
helpline
from
August
through
October
of
1990
to
assist
screener
recipients
in
completing
the
survey.
This
helpline
received
approximately
900
calls
from
screener
recipients.
Additional
information
about
the
screener
mailing
(
e.
g.,
a
copy
of
3­
3
3.0
­
Data
Collection
Activities
the
screener,
specific
mailing
and
processing
procedures,
non­
CBI
screener
responses,
follow­
up
letters,
and
notes
from
helpline
telephone
conversations)
is
contained
in
Sections
3.7,
3.8
and
5.3
of
the
rulemaking
record.

1989
Screener
Mailout
Results
EPA
mailed
8,000
screener
surveys
in
August
1990.
Based
on
the
number
of
surveys
returned
undelivered,
EPA
mailed
an
additional
342
in
September
1990.
In
addition,
EPA
received
22
unsolicited
responses
to
the
survey.
Of
the
8,364
potential
respondents
to
the
screener,
including
those
who
provided
unsolicited
responses,
7,846
received
the
screener.
Screeners
for
the
remaining
518
were
returned
to
EPA
as
undeliverable.
EPA
assumed
these
sites
to
be
out
of
business.
Of
the
total
potential
respondents,
84
percent
(
6,981)
returned
the
screener
to
EPA.
A
blank
copy
of
the
screener
form
and
nonconfidential
portions
of
the
completed
screeners
are
contained
in
the
rulemaking
record
(
see
Section
3.7.2,
DCN
17223,
and
Sections
3.7.1
and
5.3.7).
Table
3­
1
and
Figure
3­
1
summarize
the
mailout
results
for
the
1989
and
1996
survey
efforts.

Information
Collected
The
Agency
requested
the
following
site­
specific
information
in
the
1989
screener:

 
Name
and
address
of
facility;

 
Contact
person;

 
Parent
company;

 
Sectors
in
which
the
site
manufactures,
rebuilds,
or
maintains
machines
or
metal
components;

 
SIC
codes
corresponding
to
products
at
the
site;

 
Number
of
employees;

 
Annual
revenues;

3­
4
­­­­­­
3.0
­
Data
Collection
Activities
Table
3­
1
1989
and
1996
MP&
M
Survey
Mailout
Results
Survey
Type
Mailed
Returned
Undelivered
Returned
(%)
Not
Returned
(%)
Respondents
Performing
Proposed
MP&
M
Operations
(%)
Respondents
Not
Performing
Proposed
MP&
M
Operations
and
Respondents
Performing
only
Dry
Proposed
MP&
M
Operations
(%)

1989
Screener
Survey
8,342
518
6,981a
(
84)
865
(
11)
3,598
(
52)
3,373
(
48)

1989
Detailed
Survey
1,020
0
998b
(
98)
22
(
2)
792
(
79)
199
(
20)
e
1996
Screener
Survey
5,325
579
4,248d
(
80)
497
(
10)
2,424
(
57)
1,824
(
43)

1996
Benefits
Screener
1,750
155
1,392
(
80)
161
(
10)
1,354
(
97)
38(
3)

1996
Long
Detailed
Survey
353
1
311b
(
88)
41
(
12)
303c
(
97)
8
(
3)
e
1996
Short
Detailed
Survey
101
1
83
(
82)
17
(
17)
59
(
71)
24
(
29)

1996
Municipality
Detailed
Survey
150
2
147
(
98)
1
(
1)
144
(
53)
f
3
(
47)
f
1996
Federal
Detailed
Survey
51
(­­)
44
(
86)
7
(
14)

3­
5
Source:
1989
and
1996
Survey
Tracking
Systems
(
see
Section
8.8.1,
DCN
16331,
and
Section
5.3,
DCN
16330
of
the
rulemaking
record).

a
Includes
22
unsolicited
responses.

b
Seven
of
the
1989
detailed
surveys
and
two
of
the
1996
long
detailed
surveys
were
returned
too
late
to
be
incorporated
into
the
detailed
survey
database.

c
Includes
long
survey
respondents
that
discharge
<
1
mgy.

d
Does
not
include
one
duplicate
survey
received.

e
Number
of
respondents
also
includes
sites
with
classified
process
information
(
1989
detailed
survey),
sites
with
insufficient
data
(
1996
long
survey),
and
surveys
returned
too
late
to
incorporate
into
the
database
(
1996
long
survey).
The
data
from
these
surveys
were
not
incorporated
into
the
survey
databases.

f
For
the
municipality
survey,
these
numbers
represent
the
number
and
percentage
of
POTWs
receiving
wastewater
from
facilities
evaluated
in
the
final
rule,
and
the
number
and
percentage
of
POTWs
not
receiving
wastewater
from
facilities
evaluated
in
the
final
rule.

­­
Not
applicable
to
the
survey.
3.0
­
Data
Collection
Activities
1996
Federal
Detailed
1996
POTW
Detailed
1996
Municipality
Detailed
1996
Short
Detailed
1996
Long
Detailed
1996
Benefits
Screener
1996
Screener
1989
Detailed
1989
Screener
52%
84%

79%
98%

57%
80%
97%

80%
97%

88%

71%
82%

53%
90%
98%

98%

86%

NA
3­
6
Survey
Type
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%

Percentage
Surveys
Returned
Respondents
Engaged
in
MP&
M
Operations
NA
­
The
number
of
federal
surveys
distributed
is
not
certain,
and
the
percentage
of
returned
surveys
cannot
be
calculated.

Figure
3­
1.
Percentage
of
1989
and
1996
MP&
M
Surveys
Returned
and
Percentage
of
Survey
Respondents
Performing
Proposed
MP&
M
Operations
3.0
­
Data
Collection
Activities
 
 
Unit
operations
performed
at
the
site;

 
€
Whether
there
is
process
water
use
and/
or
wastewater
discharge
for
each
unit
operation
performed
at
the
site;
and
 
 
Base
metal(
s)
on
which
each
unit
operation
is
performed.

The
Agency
used
a
computerized
database
system
(
MS
Access
97)
to
store
and
analyze
data
received
from
the
screeners.
The
database
dictionary
and
all
nonconfidential
screener
surveys
are
located
in
Section
5.3.7
of
the
rulemaking
record.

EPA
determined
the
number
of
sites
engaged
in
proposed
MP&
M
operations
by
responses
to
the
screener.
As
shown
in
Table
3­
1,
approximately
52
percent
of
the
1989
screener
survey
respondents
reported
that
their
sites
were
engaged
in
proposed
MP&
M
operations
and
approximately
48
percent
reported
no
or
only
dry
proposed
MP&
M
operations
at
their
sites.
EPA
could
not
determine
the
status
of
10
of
the
sites
because
they
returned
incomplete
screeners
and
did
not
respond
to
follow­
up
efforts.

The
Agency
contacted
a
statistically
representative
sample
of
the
nonrespondent
sites
(
i.
e.,
sites
that
did
not
return
the
screener)
and
sites
reporting
 
not
engaged 
in
proposed
MP&
M
operations
to
determine
whether
their
responses
were
due
to
confusion
over
the
scope
of
the
industry.
Based
on
the
results
of
this
follow­
up,
EPA
adjusted
the
survey
weights
for
misclassification
and
incorrect
responses.
The
methodology
for
calculating
the
adjustment
factors
is
provided
in
the
Statistical
Summary
for
the
Metal
Products
&
Machinery
Industry
Surveys
(
Section
10.0,
DCN
16118).

1989
Screener
Data
Entry,
Engineering
Coding,
and
Analysis
EPA
reviewed
all
of
the
screener
surveys
prior
to
data
entry.
As
part
of
this
effort,
the
Agency
reviewed
all
documentation
provided
by
the
site,
corrected
errors
and
deficiencies,
and
coded
the
information
for
data
entry.
In
some
cases,
these
revisions
required
telephone
contact
with
site
personnel.
The
Agency
contacted
more
than
1,100
screener
recipients
to
resolve
survey
deficiencies
and
code
information
for
data
entry.
Following
preliminary
review,
EPA
entered
the
scannable
data
(
i.
e.,
responses
to
multiple­
choice,
Mark
Sense
 
questions)
into
the
database
using
a
Scantron
 
reader.
EPA
scanned
each
form
twice
and
compared
the
information
using
a
computer
program
as
a
quality
control
check.
The
Agency
performed
double
key­
entry
of
nonscannable
data,
resolved
any
inconsistencies,
and
converted
the
data
to
database
files.

Based
on
the
screener
mailout
results,
EPA
developed
an
industry
profile
for
the
seven
sectors.
The
screener
database
report
provides
estimates
of
the
national
population
for
sites
in
these
industrial
sectors
with
regard
to
water
use
characteristics,
size,
location,
sector,
unit
operations,
and
metal
types.
The
Statistical
Summary
for
the
Metal
Products
&
Machinery
3­
7
3.0
­
Data
Collection
Activities
Industry
Surveys
(
Section
10.0,
DCN
16118)
discusses
the
sample
size
determination
and
statistical
procedures
for
developing
national
estimates
for
the
industry.

3.1.1.2
1989
Detailed
Survey
Based
on
responses
to
the
1989
screener,
EPA
sent
a
more
detailed
survey
to
a
select
group
of
water­
using
facilities
performing
proposed
MP&
M
operations.
This
survey,
also
referred
to
as
the
data
collection
portfolio
(
DCP),
was
designed
to
collect
detailed
technical
and
financial
information
reflecting
a
site s
1989
operations.
EPA
used
this
information
to
characterize
these
facilities
from
the
seven
industrial
sectors,
develop
pollutant
loadings
and
reductions,
and
develop
compliance
cost
estimates,
as
discussed
later
in
this
document.

EPA
mailed
896
detailed
surveys
in
January
1991.
Based
on
the
number
of
detailed
surveys
returned
undelivered,
EPA
mailed
an
additional
124
detailed
surveys
in
January
and
February
1991,
for
a
total
of
1,020
detailed
surveys
mailed.
A
blank
copy
of
the
1989
detailed
survey
(
Section
3.7.2,
DCN
17224)
and
copies
of
the
nonconfidential
portions
of
the
completed
detailed
surveys
are
located
in
Section
5.3.8
of
the
rulemaking
record.

1989
Detailed
Survey
Recipient
Selection
and
Distribution
EPA
selected
1,020
sites
to
receive
detailed
surveys
from
the
following
three
groups
of
sites:

 
 
Water­
discharging
1989
screener
respondents
(
860
sites);

 
€
Water­
using
1989
screener
respondents
that
did
not
discharge
process
water
(
74
sites);
and
 
€
Water­
discharging
sites
from
key
companies
performing
proposed
MP&
M
operations
that
did
not
receive
the
1989
screener
(
86
sites).

The
methods
used
to
select
sites
within
each
group
are
described
below.

The
Agency
mailed
the
1989
detailed
survey
to
all
860
water­
discharging
screener
respondents.
EPA s
intent
in
collecting
detailed
data
from
all
860
sites
was
to
characterize
the
potential
variations
in
unit
operations
performed
and
water­
use
practices
among
water­
discharging
sites
in
these
seven
industrial
sectors.

The
Agency
mailed
the
1989
detailed
survey
to
a
probability
sample
of
50
screener
respondents
that
reported
using
but
not
discharging
process
water.
EPA
selected
these
sites
to
provide
information
on
water­
use
practices
at
sites
that
use
but
do
not
discharge
process
water,
and
to
determine
if
 
zero­
discharge 
practices
used
at
those
sites
could
be
used
at
other
facilities
performing
proposed
MP&
M
operations.
In
addition
to
the
50
probability
sample
sites,
EPA
mailed
the
1989
detailed
survey
to
24
screener
respondents
that
reported
using
but
not
3­
8
3.0
­
Data
Collection
Activities
discharging
process
water.
The
Agency
selected
these
sites
because
they
performed
unit
operations
that
were
not
expected
to
be
sufficiently
characterized
by
detailed
surveys
mailed
to
other
sites.
The
unit
operations
that
EPA
expected
at
each
of
the
24
sites
are
listed
in
Section
3.8.2
of
the
rulemaking
record.

EPA
mailed
the
1989
detailed
survey
to
86
sites
that
did
not
receive
the
1989
screener.
The
Agency
identified
these
sites
as
representing
key
companies
in
the
industry
that
EPA
did
not
select
as
1989
detailed
survey
recipients
based
on
the
screener
mailout.
EPA
identified
key
companies
from
Dun
&
Bradstreet
company
lists,
the
Thomas
Register
,
Fortune
Magazine s
list
of
the
top
500
U.
S.
companies,
and
MP&
M
site
visits
at
companies
with
annual
revenues
of
$
50
million
or
more
that
EPA
believed
to
be
leading
companies
in
their
particular
industrial
sector.
The
Agency
contacted
each
of
the
key
companies
to
identify
sites
within
the
company
that
were
performing
proposed
MP&
M
operations
and
used
process
water
to
perform
these
operations.
Records
of
these
follow­
up
telephone
calls
are
located
in
the
MP&
M
rulemaking
record
(
see
Section
3.8.2).
EPA
did
not
use
these
86
surveys
for
developing
the
national
estimates
because
the
Agency
did
not
randomly
select
these
facilities.

EPA
operated
a
toll­
free
telephone
helpline
from
January
until
July
1991
to
assist
recipients
in
completing
the
1989
detailed
survey.
The
helpline
received
approximately
1,400
calls
from
detailed
survey
recipients.
Callers
to
the
1989
detailed
survey
helpline
typically
requested
the
following:

 
€
Assistance
with
the
technical
sections
of
the
detailed
survey
(
e.
g.,
technical
clarification
of
unit
operation
definitions);

 
 
Additional
time
to
complete
the
survey;

 
€
Assistance
with
the
financial
sections
of
the
detailed
survey
(
these
calls
were
referred
to
a
separate
economics
helpline);
or
 
€
Clarification
of
the
applicability
of
the
survey
(
i.
e.,
did
the
survey
apply
to
the
site?).

Records
for
nonconfidential
telephone
calls
to
the
helpline
and
to
EPA
personnel
are
located
in
Section
5.3.8
of
the
rulemaking
record.

1989
Detailed
Survey
Mailout
Results
Table
3­
1
summarizes
the
results
of
the
detailed
survey
mailout.
Of
the
1,020
sites
that
received
the
detailed
survey,
998
responded
to
the
survey
and
22
did
not.
EPA
did
not
include
199
of
the
1,020
sites
that
responded
in
the
detailed
survey
database
for
one
of
the
following
reasons:

 
 
The
site
was
out
of
business;

3­
9
3.0
­
Data
Collection
Activities
 
 
The
site
did
not
use
process
water;

 
 
The
site
was
not
performing
proposed
MP&
M
operations;
or
 
€
Process
information
at
the
site
was
Department
of
Defense
or
Department
of
Energy
classified
information.

Specific
reasons
for
not
using
data
from
these
sites
are
documented
in
Section
5.3.8.2
of
the
rulemaking
record.

Upon
review
of
the
detailed
surveys
submitted
by
these
sites,
EPA
determined
87
sites
to
be
in
the
other
11
industrial
sectors
rather
than
the
seven
sectors
identified
in
Section
3.1.1.
Because
the
scope
of
the
detailed
survey
mailout
effort
included
only
sites
from
the
seven
industrial
sectors
listed
in
Section
3.1.1,
EPA
did
not
include
these
87
sites
in
the
detailed
survey
database.

Information
Collected
The
Agency
designed
the
1989
detailed
survey
to
collect
information
necessary
to
develop
effluent
limitations
guidelines
and
standards
for
the
MP&
M
rulemaking.
EPA
divided
the
detailed
survey
into
the
following
parts:

 
 
Part
I
­
General
Information;

 
 
Part
II
­
Process
Information;

 
 
Part
III
­
Water
Supply;

 
 
Part
IV
­
Wastewater
Treatment
and
Discharge;

 
 
Part
V
­
Process
and
Hazardous
Wastes;
and
 
 
Part
VI
­
Financial
and
Economic
Information.

The
detailed
survey
instructions
and
the
ICR
for
this
project
contain
further
details
on
the
types
of
and
potential
uses
for
information
collected.
These
documents
are
located
in
Section
3.7.2
of
the
rulemaking
record,
DCN
17224.

Part
I
(
questions
1
through
13)
requested
information
necessary
to
identify
the
site,
to
characterize
the
site
by
certain
variables,
and
to
confirm
that
the
site
was
performing
proposed
MP&
M
operations.
This
information
included:
site
name,
address,
contact
person,
number
of
employees,
facility
age,
average
energy
usage,
discharge
permit
status,
and
MP&
M
activity
(
manufacturing,
rebuilding,
or
maintenance).

Part
II
(
questions
14
through
21)
requested
detailed
information
on
products,
production
levels,
unit
operations,
activity,
water
use
for
unit
operations,
wastewater
discharge
from
unit
operations,
miscellaneous
wastewater
sources,
waste
minimization
practices
(
e.
g.,
pollution
prevention),
and
air
pollution
control
for
unit
operations.
EPA
requested
the
site
to
provide
detailed
technical
information
(
e.
g.,
water
balance,
chemical
additives,
metal
type
3­
10
3.0
­
Data
Collection
Activities
processed,
disposition
of
wastewater)
for
each
proposed
MP&
M
operation
and
air
pollution
control
device
using
process
water.
This
section
also
requested
information
on
unique
and/
or
auxiliary
operations.
EPA
used
this
information
to
evaluate
raw
waste
characteristics,
water
use
and
discharge
practices,
and
sources
of
pollutants
for
each
proposed
MP&
M
operation.

Part
III
(
question
22)
requested
information
on
the
water
supply
for
the
site.
EPA
requested
the
site
to
specify
the
source
water
origin,
average
intake
flow,
average
intake
operating
hours,
and
the
percentage
of
water
used
for
proposed
MP&
M
operations.
EPA
used
this
information
to
evaluate
overall
water
use
for
the
site.

Part
IV
(
questions
23
through
33)
requested
detailed
information
on
influent
and
effluent
wastewater
treatment
streams
and
wastewater
treatment
operations.
The
information
requested
included:
the
origin
of
each
stream
contributing
to
the
site s
overall
wastewater
discharge;
a
block
diagram
of
the
wastewater
treatment
system;
detailed
technical
information
(
e.
g.,
wastewater
stream
flow
rates,
treatment
chemical
additives,
system
capacity,
disposition
of
treatment
sludge)
for
each
wastewater
treatment
operation;
self­
monitoring
data;
and
capital
and
operating
cost
data.
EPA
collected
this
information
on
facilities
performing
proposed
MP&
M
operations
to:
(
1)
evaluate
treatment
in
place
at
these
facilities;
(
2)
develop
and
design
a
cost
model
to
estimate
various
control
options;
and
(
3)
assess
the
long­
term
variability
of
effluent
streams.

Part
V
(
question
34)
requested
detailed
information
on
the
types,
amounts,
and
composition
of
wastewater
and
solid/
hazardous
wastes
generated
during
production
or
waste
treatment,
and
the
costs
of
solid
waste
disposal.
EPA
collected
this
information
to
evaluate
the
types
and
amounts
of
wastes
currently
discharged,
the
amount
of
waste
that
is
contract
hauled
off
site,
and
the
cost
of
contract
hauling
wastes.

Part
VI
requested
detailed
financial
and
economic
information
from
the
site
and
the
company
owning
the
site.
EPA
collected
this
information
to
calculate
the
economic
impacts
of
the
regulatory
options
considered
for
the
MP&
M
rulemaking.

1989
Detailed
Survey
Review,
Coding,
and
Data
Entry
The
Agency
completed
an
engineering
review
of
the
detailed
surveys,
including
coding
responses
to
questions
from
Parts
I
through
V
to
facilitate
entry
of
technical
data
into
a
database.
The
MP&
M
DCP
Database
Dictionary
identifying
all
database
codes
developed
for
this
effort
and
the
database
dictionary
for
Section
VI
of
the
detailed
survey
are
located
in
Section
5.3.8.2
of
the
rulemaking
record,
DCN
17387.

The
Agency
followed
up
with
telephone
calls
to
all
respondents
who
did
not
provide:
(
1)
information
on
operations
(
manufacturing,
rebuilding,
or
maintenance)
or
sectors;
(
2)
metal
type
or
unit
operation
descriptions
for
each
water­
using
unit
operation;
or
(
3)
descriptions
for
each
wastewater
treatment
operation.
EPA
also
made
follow­
up
calls
to
3­
11
3.0
­
Data
Collection
Activities
clarify
incomplete
or
contradictory
technical
or
economic
information.
EPA
confirmed
all
information
obtained
from
follow­
up
calls
by
sending
a
letter
to
the
site.

EPA
developed
a
database
to
store
all
technical
data
provided
in
the
detailed
surveys.
After
engineering
review
and
coding,
the
Agency
entered
data
from
the
detailed
surveys
into
the
database
using
a
double
key­
entry
and
verification
procedure.
EPA
coded
and
entered
data
from
792
detailed
survey
respondents
determined
to
be
performing
proposed
MP&
M
operations
into
the
detailed
survey
database.
The
MP&
M
DCP
Database
Dictionary
presents
the
database
structure
and
defines
each
field
in
the
detailed
survey
database
and
the
codes
that
describe
data
in
these
fields.

The
Economic,
Environmental,
and
Benefits
Analysis
of
the
Proposed
Metal
Products
and
Machinery
Rule
,
which
is
located
in
Section
8.1
of
the
rulemaking
record,
DCN
2000,
discusses
EPA s
review
of
Section
VI
of
the
detailed
survey.

1989
Detailed
Survey
Data
Analysis
EPA
used
the
information
collected
in
the
detailed
survey
to
develop
an
industry
profile
and
to
identify
the
baseline
of
treatment
in
place
and
estimate
the
amount
of
pollutant
discharges
from
facilities
performing
proposed
MP&
M
operations.
Section
4.0
of
this
document
provides
estimates
of
the
national
population
of
these
facilities
that
discharge
water
with
regard
to
size,
location,
sector,
unit
operations,
metal
types,
and
discharge
flows,
and
discusses
the
statistical
procedures
for
developing
national
estimates
for
the
industry.
Section
11.0
and
12.0
present
the
methodologies
used
to
estimate
pollutant
discharges
and
compliance
costs,
respectively.

3.1.2
The
1996
Industry
Surveys
Between
1996
and
1998,
EPA
distributed
one
screener
and
five
detailed
surveys,
requesting
data
representing
the
survey
recipients 
1996
operations.
The
five
detailed
surveys
included
the
long,
short,
municipality,
federal,
and
publicly
owned
treatment
works
(
POTW)
surveys.
The
Agency
distributed
the
1996
surveys
to
commercial
and
government
(
federal,
state,
and
local)
facilities
that
manufacture,
rebuild,
or
maintain
metal
products
or
parts
to
be
used
in
one
of
the
following
11
industrial
sectors:

 
Bus
and
Truck;

 
Household
Equipment;

 
Instruments;

 
Job
Shops;

 
Motor
Vehicles;

 
Office
Machines;

 
Precious
Metals
and
Jewelry;

 
Printed
Wire
Boards;

 
Railroad;

3­
12
3.0
­
Data
Collection
Activities
 
Ships
and
Boats;
and
 
Miscellaneous
Metal
Products.

The
1996
screener
and
detailed
surveys
are
discussed
below.
Recipient
selection,
stratification
schemes,
and
the
type
and
potential
use
of
the
information
requested
are
described
in
more
detail
in
the
ICR
for
the
1996
screener
(
see
Section
3.5.1,
DCN
15766).

3.1.2.1
1996
Screener
Survey
In
December
1996
and
February
1997,
EPA
distributed
5,325
screener
surveys
to
sites
believed
to
be
engaged
in
manufacturing,
rebuilding,
or
maintenance
activities
in
one
of
the
11
industrial
sectors
listed
in
Section
3.1.2.
The
purpose
of
the
screener
surveys
was
to
identify
sites
to
receive
the
more
detailed
survey
and
to
make
a
preliminary
assessment
of
the
industry
for
the
11
industrial
sectors.
EPA
sent
an
additional
1,750
screeners
to
facilities
located
in
Ohio
(
a
state
with
a
high
concentration
of
facilities
performing
proposed
MP&
M
operations)
as
part
of
a
benefits
study.
The
Agency
used
these
screeners
to
collect
data
to
analyze
environmental
benefits.

1996
Screener
Recipient
Selection
and
Distribution
As
discussed
above,
EPA
sent
the
1996
screener
survey
to
5,325
randomly
selected
facilities
performing
proposed
MP&
M
operations
(
includes
replacement
sites).
The
Agency
selected
potential
recipients
from
the
Dun
&
Bradstreet
database
based
on
the
industrial
sector
(
using
the
SIC
code),
activity
(
i.
e.,
manufacturing,
maintenance,
or
rebuilding),
size
as
measured
by
number
of
employees,
and
wastewater
discharge
flow
rate.

The
Agency
identified
more
than
126
SIC
codes
applicable
to
the
11
industrial
sectors.
Within
each
sector,
EPA
identified
between
1
and
26
SIC
codes.
EPA
calculated
the
number
of
sites
to
receive
the
1996
screener
within
each
SIC
code
by
a
coefficient
of
variation
(
CV)
minimization
procedure
described
in
the
Statistical
Support
Document
located
in
Section
10.0
of
the
rulemaking
record,
DCN
16119.
Based
on
the
number
of
sites
selected
within
each
SIC
code,
the
Agency
obtained
a
list
of
randomly
selected
names
and
addresses
from
Dun
&
Bradstreet.
This
list
included
twice
the
number
of
sites
specified
by
the
CV
minimization
procedure
for
each
SIC
code.
EPA
randomly
selected
the
initial
list
of
sites
from
the
Dun
&
Bradstreet
database
for
each
SIC
code.

After
reviewing
the
potential
sites,
EPA
deleted
sites
for
the
following
reasons:

 
The
site
was
a
corporate
headquarters
without
manufacturing,
rebuilding,
or
maintenance
operations;

 
The
site
received
a
1989
screener
or
detailed
survey;

3­
13
3.0
­
Data
Collection
Activities
 
The
site
was
a
duplicate
of
another
facility
in
the
list
of
potential
facilities
performing
proposed
MP&
M
operations;

 
The
site
had
an
SIC
code
that
was
inconsistent
with
company
name;
or
 
The
site
had
an
insufficient
mailing
address.

EPA
established
a
toll­
free
telephone
helpline
and
an
electronic
mail
address
to
assist
screener
recipients
in
completing
the
survey.
EPA
received
helpline
calls
and
electronic
mail
inquiries
from
more
than
600
screener
recipients.
Nonconfidential
notes
from
helpline
and
review
follow­
up
calls
are
located
in
Section
5.3.1
of
the
rulemaking
record.

1996
Screener
Mailout
Results
EPA
initially
mailed
4,900
surveys
in
December
1996.
The
Agency
distributed
surveys
to
an
additional
425
sites
to
replace
surveys
that
were
returned
undelivered.
EPA
assumed
the
undeliverable
survey
sites
to
be
out
of
business.
Of
the
5,325
surveys
mailed,
80
percent
(
4,248)
of
the
recipients
returned
completed
surveys
to
EPA.
A
blank
copy
of
the
1996
screener
(
see
Section
3.7.1,
DCN
16367)
and
nonconfidential
portions
of
the
completed
screeners
are
located
in
the
public
record
for
this
rulemaking
(
see
Section
5.3.1.1).
Table
3­
1
and
Figure
3­
1
summarize
the
MP&
M
survey
mailout
results.

The
Agency
contacted
a
statistically
representative
sample
of
nonrespondent
sites
to
determine
whether
these
sites
were
performing
proposed
MP&
M
operations
and
discharged
process
wastewater.
Only
24
percent
of
the
nonrespondents
contacted
were
performing
proposed
MP&
M
operations,
and
approximately
half
of
these
facilities
did
not
discharge
process
wastewater.

Information
Collected
The
Agency
requested
the
following
site­
specific
information
in
the
screener:

 
Name
and
address
of
facility;

 
Contact
person;

 
Whether
process
water
is
used
at
the
site;

 
Destination
of
process
wastewater
discharged;

 
Volume
of
process
wastewater
discharged;

 
Number
of
employees;

3­
14
3.0
­
Data
Collection
Activities
 
Annual
revenue;

 
Sectors
in
which
the
site
manufactures,
rebuilds,
or
maintains
machines
or
metal
components;
and
 
Unit
operations
performed
at
the
site
and
whether
there
is
water
use
and/
or
wastewater
discharge
for
each
unit
operation
performed
at
the
site.

The
Agency
used
a
computerized
database
system
(
MS
Access
97)
to
store
and
analyze
data
received
from
the
1996
screeners.
Nonconfidential
portions
of
the
screener
surveys
(
see
Section
5.3.1.1)
and
the
database
dictionary
are
located
in
the
public
record
for
this
rulemaking
(
see
Section
5.3.1.2,
DCN
15393).

1996
Screener
Data
Review
and
Data
Entry
EPA
reviewed
the
1996
screener
survey
responses
for
accuracy
and
consistency
and
formatted
the
information
for
data
entry.
The
Agency
contacted
approximately
1,800
screener
respondents
to
resolve
deficient
and
inconsistent
information
prior
to
data
entry.
Following
review,
EPA
double
key
entered
and
compared
the
data
from
the
formatted
screeners,
using
a
computer
program,
as
a
quality
control
check.
The
Agency
then
reviewed
the
database
files
for
deficiencies
and
inconsistencies,
and
resolved
all
issues
for
the
final
survey
database.

1996
Benefits
Screener
Survey
For
an
environmental
benefits
study,
EPA
sent
the
1996
screener
survey
to
1,750
(
including
replacement
sites)
randomly
selected
sites
in
Ohio,
a
state
with
a
large
number
of
facilities
performing
proposed
MP&
M
operations.
The
selection
criteria
and
sampling
frame
for
the
benefits
screener
recipients
are
described
in
more
detail
in
memoranda
located
in
Section
3.8.1.7
of
the
rulemaking
record,
DCN
16333.

The
Agency
initially
mailed
the
benefits
screener
to
1,600
facilities
in
October
1998.
EPA
mailed
screeners
to
an
additional
150
facilities
in
February
1999
to
replace
surveys
that
were
returned
undelivered.
The
Agency
assumed
the
undeliverable
survey
sites
to
be
out
of
business.
Of
the
1,750
surveys
mailed,
80
percent
(
1,392)
of
the
recipients
returned
completed
screeners
to
EPA.
A
blank
copy
of
the
1996
benefits
screener
(
see
Section
3.7.1,
DCN
16367)
and
nonconfidential
portions
of
the
completed
benefits
screeners
(
see
Section
8.8.1)
are
located
in
the
public
record
for
this
rulemaking.
Table
3­
1
and
Figure
3­
1
summarize
the
MP&
M
mailout
results.

EPA
established
a
toll­
free
telephone
helpline
and
an
electronic
mail
address
to
assist
screener
recipients
in
completing
the
survey.
EPA
received
helpline
calls
and
electronic
mail
inquiries
from
more
than
900
benefits
screener
recipients.
Nonconfidential
notes
from
helpline
and
review
follow­
up
calls
are
located
in
Section
8.8.1
of
the
public
record
for
this
rulemaking.

3­
15
3.0
­
Data
Collection
Activities
The
Agency
followed
the
same
review,
data
entry,
and
database
development
procedures
used
for
the
original
1996
screener
survey.
EPA
contacted
more
than
400
screener
respondents
to
resolve
deficient
and
inconsistent
information
prior
to
data
entry.
The
benefits
screener
database
is
discussed
in
the
Economic,
Environmental,
and
Benefits
Analysis
of
the
Proposed
Metal
Products
and
Machinery
Rule
.

3.1.2.2
1996
Long
Detailed
Survey
EPA
distributed
the
long
detailed
surveys
(
long
survey)
in
June
1997
to
353
wastewater­
discharging
facilities
performing
proposed
MP&
M
operations.
EPA
designed
this
survey
to
gather
detailed
technical
and
economic
information
required
to
develop
the
MP&
M
effluent
limitations
guidelines
and
standards.
The
long
survey
is
discussed
below.

1996
Long
Survey
Recipient
Selection
and
Distribution
In
June
1997,
EPA
sent
the
long
survey
to
all
353
1996
screener
respondents
who
indicated
they
performed
operations
in
one
of
the
11
industry
sectors
listed
in
Section
3.1.2
and
discharged
one
million
or
more
gallons
of
MP&
M
process
wastewater
annually.
EPA
established
a
toll­
free
telephone
helpline
and
an
electronic
mail
address
to
assist
long
survey
recipients
in
completing
the
survey.
EPA
received
helpline
calls
and
electronic
mail
inquiries
from
approximately
200
long
survey
recipients.
Nonconfidential
notes
from
helpline
and
review
follow­
up
calls
are
located
in
Section
5.3.2.1
of
the
public
record
for
this
rulemaking.

1996
Long
Survey
Mailout
Results
Of
the
353
surveys
mailed,
88
percent
(
311)
of
the
recipients
returned
completed
surveys
to
EPA.
One
survey
was
returned
as
undelivered
and
EPA
assumed
the
facility
to
be
out
of
business.
A
blank
copy
of
the
1996
long
survey
(
Section
3.7.1,
DCN
713)
and
nonconfidential
portions
of
the
completed
long
surveys
are
located
in
Section
5.3.2.1
of
the
public
record
for
this
rulemaking.
Table
3­
1
and
Figure
3­
1
summarize
the
MP&
M
survey
mailout
results.

Information
Collected
EPA
divided
the
long
detailed
survey
into
the
following
sections:

 
Section
I:
General
Site
Information;

 
Section
II:
General
Process
Information;

 
Section
III:
Specific
Process
Information;

3­
16
3.0
­
Data
Collection
Activities
 
Section
IV:
Economic
Information;
and
 
Section
V:
Voluntary
Supplemental
Information.

Table
3­
2
summarizes
the
information
requested
in
the
1996
long,
short,
federal,
and
municipality
detailed
surveys
by
question
number.
EPA
designed
these
surveys
to
collect
similar
detailed
process
information
from
different
audiences,
as
discussed
below
for
each
survey.
Further
details
on
the
types
of
information
collected
and
the
potential
uses
of
the
information
are
contained
in
the
ICR
for
this
data
collection
(
see
Section
3.5.1,
DCN
15766)
and
in
the
survey
instructions
that
are
located
in
Section
3.7.1
of
the
rulemaking
record,
DCN
713.

Section
I
requested
information
to
determine
if
the
facility
was
performing
proposed
MP&
M
operations.
Question
1
requested
the
site
to
identify
the
industry
sector
and
type
of
activity
(
manufacturing,
rebuilding,
or
maintenance)
performed.

Section
II
requested
information
to
identify
the
site
location
and
contact
person,
number
of
employees,
facility
age,
process
wastewater
discharge
status
and
destination,
and
wastewater
discharge
permits
and
permitting
authority.
This
section
also
requested
general
information
about
metal
types
processed,
products
and
production
levels,
water
use
for
unit
operations,
and
wastewater
discharge
from
unit
operations.
EPA
used
the
process
information
to
evaluate
water
use
and
discharge
practices
and
sources
of
pollutants
for
each
proposed
MP&
M
operation.

Section
III
requested
detailed
information
on
wet
proposed
MP&
M
operations,
pollution
prevention
practices,
wastewater
treatment
technologies,
costs
for
water
use
and
wastewater
treatment
systems,
and
wastewater/
sludge
disposal
costs.
EPA
also
requested
the
site
to
provide
block
diagrams
of
the
production
process
and
the
wastewater
treatment
system.
The
unit
operation
information
requested
included:
metal
types
processed,
production
rate,
operating
schedule,
chemical
additives,
volume
and
destination
of
process
wastewater
and
rinse
waters,
in­
process
pollution
prevention
technologies,
and
in­
process
flow
control
technologies.
The
information
requested
for
each
wastewater
treatment
unit
included:
operating
flow
rate,
design
capacity,
operating
time,
chemical
additives,
and
unit
operations
discharging
to
each
treatment
unit.
In
addition,
EPA
requested
the
site
to
provide
the
type
of
any
wastewater
sampling
data
collected.
EPA
used
these
data
to
characterize
the
industry,
to
perform
subcategorization
analyses,
to
identify
best
management
practices,
to
evaluate
performance
of
the
treatment
technology
for
inclusion
in
the
regulatory
options,
and
to
develop
regulatory
compliance
cost
estimates.

Section
IV
requested
detailed
financial
and
economic
information
about
the
site
or
the
company
owning
the
site.
EPA
collected
this
information
to
calculate
the
economic
impacts
of
the
regulatory
options
considered
for
the
MP&
M
rulemaking.

Section
V
requested
supplemental
information
on
other
facilities
performing
proposed
MP&
M
operations
owned
by
the
company.
EPA
included
this
voluntary
section
to
3­
17
­­­

­­­­­­

­­­­­­

­­­­­­

­­­­­­

­­­­­­

­­­­­­

­­­­­­

­­­­­­­­­

­­­

­­­

­­­

­­­

­­­

­­­
3.0
­
Data
Collection
Activities
measure
the
combined
impact
of
proposed
MP&
M
effluent
guidelines
on
companies
with
multiple
facilities
Table
3­
2
Summary
of
1996
Detailed
Survey
Information
by
Question
Number
Survey
Question
Number
Type
of
Information
Requested
Long
and
Federal
Short
Municipality
Section
I
1
Section
I
1
Part
II
1
Industrial
sector
activities
Section
II
2­
5
Section
II
2­
5
2­
5
Site
location
and
facility
contact
6,
7
6,
7
5,
6
Number
of
employees
and
age
of
site
8,
9
8,
9
7,
8
Discharge
status
and
destination
10
10
9
Permits
under
miscellaneous
categorical
effluent
guidelines
11­
12
10­
11
Types
of
end­
of­
pipe
wastewater
treatment
units
11
13
12
Metal
types
processed
12
15
13
5
major
products
(
quantity
and
sector)

13
16
14
Unit
operations:
water
use
and
associated
rinses
Section
III
14­
15
General
water
use
and
costs
16
Production
process
diagram
17­
23
Detailed
description
of
wet
unit
operations
performed
24­
29
Section
II
17
16
In­
process
pollution
prevention
technologies
or
practices
30
Wastewater
treatment
(
WWT)
diagram
31­
41
Detailed
design
and
operating
parameters
of
WWT
units
42
WWT
costs
by
treatment
unit
43­
44
Section
II
14
15
Wastewater
sampling
and
analysis
conducted
45
Contract
haul
and
disposal
costs
Facility
comments
page
Section
IV
1­
9
Section
IV
1­
8
Part
I
1­
3
Financial
and
economic
data
Section
V
1
Section
V
1
Parent
firm
name
and
contact,
number
of
other
facilities
performing
proposed
MP&
M
operations
2
2
Number
of
employees
for
other
facility(
ies)

3
3
Industrial
and
activity
2,
4
2,
4
Discharge
status
and
destination
5
5
Unit
operations:
water
use
and
discharge
status
Question
is
not
applicable
to
this
survey.

3­
18
3.0
­
Data
Collection
Activities
performing
proposed
MP&
M
operations
that
discharge
process
wastewater.
This
section
requested
the
same
information
collected
in
the
1996
MP&
M
screener
survey.
Responses
to
questions
in
this
section
provided
the
size,
industrial
sector,
revenue,
unit
operations,
and
water
usage
of
the
company s
other
facilities
performing
proposed
MP&
M
operations.

1996
Long
Survey
Data
Review
and
Data
Entry
EPA
completed
a
detailed
engineering
review
of
Sections
I
through
III
of
the
detailed
long
survey
to
evaluate
the
accuracy
of
technical
information
provided
by
the
respondents.
During
the
engineering
review,
EPA
coded
responses
to
facilitate
entry
of
technical
data
into
the
long
survey
database.
The
MP&
M
1996
Long
Survey
Database
Dictionary
identifies
the
database
codes
developed
for
this
project,
and
is
located
in
Section
5.3.2.2
of
the
rulemaking
record,
DCN
15773.
EPA
contacted
approximately
240
long
survey
respondents,
by
telephone
and
letter,
to
clarify
incomplete
or
inconsistent
technical
information
prior
to
data
entry.

The
Agency
developed
a
database
for
the
technical
information
provided
by
survey
respondents.
After
engineering
review
and
coding,
EPA
entered
data
from
303
long
surveys
into
the
database
using
a
double
key­
entry
and
verification
procedure.
The
MP&
M
1996
Long
Survey
Database
Dictionary
presents
the
database
structure
and
defines
each
field
in
the
database
files.
EPA
did
not
include
data
from
8
long
survey
respondents
in
the
database
for
the
following
reasons:

 
The
site
was
out
of
business;

 
The
site
did
not
use
process
water;

 
The
site
was
not
performing
proposed
MP&
M
operations;
or
 
The
site
provided
insufficient
data
and
the
survey
was
returned
too
late
to
enter
into
the
database.

The
Economic,
Environmental,
and
Benefits
Analysis
of
the
Proposed
Metal
Products
and
Machinery
Rule
,
which
is
located
in
Section
8.1
of
the
rulemaking
record,
DCN
2000,
discusses
EPA s
review
of
Section
IV
of
the
detailed
survey.

3.1.2.3
1996
Short
Detailed
Survey
EPA
distributed
the
short
detailed
survey
(
short
survey)
in
September
1997
to
101
wastewater­
discharging
facilities
performing
proposed
MP&
M
operations.
EPA
designed
this
survey
to
gather
additional
technical
and
economic
information
required
to
develop
the
MP&
M
effluent
limitations
guidelines
and
standards.
The
short
survey
is
discussed
below.

3­
19
3.0
­
Data
Collection
Activities
1996
Short
Survey
Recipient
Selection
and
Distribution
EPA
initially
sent
100
short
surveys
in
September
1997
and
mailed
one
additional
survey
to
a
site
to
replace
a
short
survey
that
was
returned
undelivered.
EPA
assumed
the
undeliverable
site
to
be
out
of
business.
The
Agency
sent
the
short
surveys
to
randomly
selected
1996
screener
respondents
who
performed
operations
in
one
of
the
11
industry
sectors
identified
in
Section
3.1.2
and
indicated
they
discharged
less
than
one
million
gallons
of
MP&
M
process
wastewater
annually.
The
selection
criteria
and
sampling
frame
for
short
survey
recipients
are
described
in
more
detail
in
the
Statistical
Summary
for
the
Metal
Products
&
Machinery
Industry
Surveys
(
Section
10.0,
DCN
16118).

EPA
established
a
toll­
free
telephone
helpline
and
an
electronic
mail
address
to
assist
short
survey
recipients
in
completing
the
survey.
EPA
received
helpline
calls
and
electronic
mail
inquiries
from
approximately
20
short
survey
recipients.
Nonconfidential
notes
from
helpline
and
review
follow­
up
calls
are
located
in
Section
5.3.3.1
of
the
public
record
for
this
rulemaking.

1996
Short
Survey
Mailout
Results
Of
the
101
surveys
mailed,
82
percent
(
83
surveys)
of
the
recipients
returned
completed
surveys
to
EPA.
A
blank
copy
of
the
1996
short
survey
(
Section
3.7.1,
DCN
16368)
and
nonconfidential
portions
of
the
completed
short
surveys
(
Section
5.3.3.1)
are
located
in
the
public
record
for
this
rulemaking.
Table
3­
1
and
Figure
3­
1
summarize
the
MP&
M
survey
mailout
results.

Information
Collected
The
information
collected
in
the
1996
short
survey
included
the
identical
general
site
and
process
information
and
economic
information
collected
in
Sections
I,
II,
IV,
and
V
of
the
long
detailed
survey
(
see
Section
3.1.2.2).
To
minimize
the
burden
on
facilities
discharging
less
than
one
million
gallons
of
process
wastewater,
EPA
did
not
require
these
facilities
to
provide
the
detailed
information
on
proposed
MP&
M
operations
or
treatment
technologies
that
EPA
requested
in
Section
III
of
the
long
survey.
The
ICR
for
this
data
collection
and
the
survey
instructions
contain
further
details
on
the
types
of
information
collected
and
the
potential
uses
of
the
information.

EPA
divided
the
short
survey
into
the
following
sections:

 
Section
I:
General
Site
Information;

 
Section
II:
General
Process
Information;

 
Section
IV:
Economic
Information;
and
 
Section
V:
Voluntary
Supplemental
Information.

3­
20
3.0
­
Data
Collection
Activities
Section
III,
Specific
Process
Information,
consisted
of
a
statement
that
EPA
was
not
requesting
this
information
to
reduce
burden
on
sites
discharging
less
than
one
million
gallons
of
process
wastewater
per
year.
Table
3­
2
summarizes
the
1996
short
survey
information
by
question
number.

1996
Short
Survey
Data
Review
and
Data
Entry
EPA
completed
a
detailed
engineering
review
of
Sections
I
and
II
of
the
short
survey
to
evaluate
the
accuracy
of
technical
information
provided
by
the
respondents.
During
the
engineering
review,
EPA
coded
responses
to
facilitate
entry
of
technical
data
into
the
short
survey
database.
The
MP&
M
1996
Short
Survey
Database
Dictionary
identifies
the
database
codes
developed
for
this
project
and
is
located
in
Section
5.3.3.2
of
the
rulemaking
record,
DCN
15772.
EPA
contacted
more
than
60
short
survey
respondents,
by
telephone
and
letter,
to
clarify
incomplete
or
inconsistent
technical
information
prior
to
data
entry.

The
Agency
developed
a
database
for
the
technical
information
provided
by
survey
respondents.
After
engineering
review
and
coding,
EPA
entered
data
for
75
short
surveys
into
the
database
using
a
double
key­
entry
and
verification
procedure.
The
MP&
M
1996
Short
Survey
Database
Dictionary
presents
the
database
structure
and
defines
each
field
in
the
database
files.
EPA
did
not
include
data
from
eight
short
survey
respondents
in
the
database
for
the
following
reasons:

 
The
site
was
out
of
business;

 
The
site
did
not
use
process
water;
or
 
The
site
was
not
performing
proposed
MP&
M
operations.

The
Economic,
Environmental,
and
Benefits
Analysis
of
the
Proposed
Metal
Products
and
Machinery
Rule
,
which
is
located
in
Section
8.1
of
the
rulemaking
record,
DCN
2000,
discusses
EPA s
review
of
Section
IV
of
the
short
survey.

3.1.2.4
1996
Municipality
Detailed
Survey
EPA
distributed
the
municipality
surveys
in
June
1997
to
150
city
and
county
facilities
that
might
operate
facilities
performing
proposed
MP&
M
operations.
EPA
designed
this
survey
to
measure
the
impact
of
this
rule
on
municipalities
and
other
government
entities
that
perform
certain
maintenance
and
rebuilding
operations
(
e.
g.,
bus
and
truck,
automobiles).

Recipient
Selection
and
Distribution
The
Agency
sent
the
municipality
survey
to
150
city
and
county
facilities
randomly
selected
from
the
Municipality
Year
Book­
1995
based
on
population
and
geographic
location.
EPA
allocated
60
percent
of
the
sample
to
municipalities
and
40
percent
to
counties.
The
60/
40
distribution
was
approximately
proportional
to
their
aggregate
populations
in
the
frame.
The
Agency
divided
the
municipality
sample
and
the
county
sample
into
three
size
3­
21
3.0
­
Data
Collection
Activities
groupings
as
measured
by
population.
For
municipalities,
the
population
groupings
were:
less
than
10,000
residents,
10,000
­
50,000
residents,
and
50,000
or
more
residents.
For
counties,
the
population
groupings
were:
less
than
50,000
residents,
50,000
­
150,000
residents,
and
150,000
or
more
residents.
The
geographic
stratification
conformed
to
the
Census
definitions
of
Northeast,
North
Central,
South,
Pacific,
and
Mountain
states.

EPA
established
a
toll­
free
telephone
helpline
and
an
electronic
mail
address
to
assist
municipality
survey
recipients
in
completing
the
survey.
EPA
received
helpline
calls
and
electronic
mail
inquiries
from
more
than
50
municipality
survey
recipients.
Notes
from
helpline
and
review
follow­
up
calls
are
located
in
Section
5.3.4.1
of
the
rulemaking
record.

1996
Municipality
Survey
Mailout
Results
Of
the
150
municipality
surveys
mailed,
three
surveys
were
returned
undelivered
and
135
surveys
(
90
percent)
of
the
recipients
returned
completed
surveys
to
EPA.
A
blank
copy
of
the
1996
municipality
survey
(
Section
3.7.1,
DCN
16366)
and
nonconfidential
portions
of
the
completed
municipality
surveys
(
Section
5.3.4.1)
are
located
in
the
public
record
for
this
rulemaking.
Table
3­
1
and
Figure
3­
1
summarize
the
MP&
M
survey
mailout
results.

Information
Collected
The
1996
municipality
survey
collected
economic
information
for
the
entire
municipality
and
site­
specific
process
information
for
each
facility
performing
proposed
MP&
M
operations
operated
by
the
municipality.

EPA
divided
the
municipality
detailed
survey
into
the
following
parts:

 
Part
I:
Economic
and
Financial
Information;
and
 
Part
II:
General
Site­
Specific
Process
Information.

Table
3­
2
summarizes
the
1996
municipality
survey
information
by
question
number.
The
ICR
for
this
data
collection
(
Section
3.5.1,
DCN
15766)
and
the
survey
instructions
(
Section
3.7.1,
DCN
15366)
contain
further
details
on
the
types
of
information
collected
and
the
potential
uses
of
the
information
and
are
located
in
the
rulemaking
record.

Part
I
requested
information
on
the
site
location
and
contact
person,
number
of
employees,
detailed
financial
and
economic
information
about
the
entire
municipality,
and
information
necessary
to
determine
if
the
municipality
owned
and
operated
facilities
performing
proposed
MP&
M
operations
in
any
of
the
proposed
industrial
sectors.

Part
II
requested
site­
specific
process
information
for
each
facility
performing
proposed
MP&
M
operations
owned
and
operated
by
the
municipality.
Question
1
requested
the
site
to
identify
the
industry
sector
and
type
of
activity
(
manufacturing,
rebuilding,
or
maintenance)
performed.
The
remaining
questions
were
identical
to
Section
II
of
the
short
3­
22
3.0
­
Data
Collection
Activities
detailed
survey
and
requested
facility
age,
process
wastewater
discharge
status
and
destination,
wastewater
discharge
permits
and
permitting
authority,
general
information
about
metal
types
processed,
products
and
production
levels,
water
use
for
unit
operations,
and
wastewater
discharge
from
unit
operations.
The
Agency
used
the
process
information
to
evaluate
water
use
and
discharge
practices
and
sources
of
pollutants
for
each
proposed
MP&
M
operation.

1996
Municipality
Survey
Data
Review
and
Data
Entry
EPA
completed
a
detailed
engineering
review
of
Part
II
of
the
municipality
survey
to
evaluate
the
accuracy
of
technical
information
provided
by
the
respondents.
During
the
engineering
review,
the
Agency
coded
responses
to
facilitate
entry
of
technical
data
into
the
municipality
survey
database.
The
MP&
M
1996
Municipality
Survey
Database
Dictionary
identifies
the
database
codes
developed
for
this
project,
and
is
located
in
Section
5.3.4.2
of
the
rulemaking
record,
DCN
15771.
EPA
contacted
more
than
50
municipality
survey
respondents
by
telephone
to
clarify
incomplete
or
inconsistent
technical
information
prior
to
data
entry.

The
Agency
developed
a
database
for
the
technical
information
provided
by
survey
respondents.
After
engineering
review
and
coding,
EPA
entered
data
from
209
municipality
facilities
into
the
database
using
a
double
key­
entry
and
verification
procedure.
This
number
is
greater
than
the
number
of
respondents
because
some
municipalities
had
more
than
one
facility
performing
proposed
MP&
M
operations.
The
MP&
M
1996
Municipality
Survey
Database
Dictionary
presents
the
database
structure
and
defines
each
field
in
the
database
files.

The
Economic,
Environmental,
and
Benefits
Analysis
of
the
Proposed
Metal
Products
and
Machinery
Rule
,
which
is
located
in
Section
8.1
of
the
rulemaking
record,
DCN
2000,
discusses
EPA s
review
of
Part
I
of
the
municipality
survey.

3.1.2.5
1996
Federal
Facilities
Detailed
Survey
In
April
1998,
EPA
distributed
the
federal
facilities
detailed
survey
(
federal
survey)
to
the
following
seven
federal
agencies:

 
Department
of
Energy;

 
Department
of
Defense;

 
National
Aeronautics
and
Space
Administration
(
NASA);

 
Department
of
Transportation
(
including
the
United
States
Coast
Guard);

 
Department
of
Interior;

 
Department
of
Agriculture;
and
 
United
States
Postal
Service.

EPA
used
this
survey
to
assess
the
impact
of
the
MP&
M
effluent
limitations
guidelines
and
standards
on
federal
agencies
that
operate
facilities
performing
proposed
MP&
M
operations.

3­
23
3.0
­
Data
Collection
Activities
Recipient
Selection
and
Distribution
There
was
no
specific
sampling
frame
for
the
federal
survey.
EPA
distributed
the
survey
to
federal
agencies
likely
to
perform
industrial
operations
on
metal
products
or
machinery.
EPA
requested
representatives
of
seven
federal
agencies
to
voluntarily
distribute
copies
of
the
survey
to
sites
they
believed
performed
proposed
MP&
M
operations.
The
selection
criteria
for
federal
survey
recipients
are
described
in
more
detail
in
the
ICR
for
the
1996
MP&
M
industry
surveys.
Because
the
sample
was
not
randomly
selected,
EPA
did
not
use
data
from
these
surveys
to
develop
national
estimates.

EPA
established
a
toll­
free
telephone
helpline
and
an
electronic
mail
address
to
assist
federal
survey
recipients
in
completing
the
survey.
EPA
received
helpline
calls
and
electronic
mail
inquiries
from
approximately
20
federal
survey
recipients.
Nonconfidential
notes
from
helpline
and
review
follow­
up
calls
are
located
in
Section
5.3.5.1
of
the
public
record
for
this
rulemaking.

1996
Federal
Survey
Distribution
Results
The
Agency
received
51
completed
federal
surveys,
39
from
Department
of
Defense
facilities
and
12
from
NASA
facilities.
A
blank
copy
of
the
1996
federal
survey
(
Section
3.7.1,
DCN
721)
and
nonconfidential
portions
of
the
completed
federal
surveys
are
located
in
Section
5.3.5.1
of
the
public
record
for
this
rulemaking.

Information
Collected
The
information
requested
in
Sections
I
and
III
of
the
1996
federal
survey
was
identical
to
the
long
survey
(
see
Section
3.1.2.2).
The
financial
and
economic
questions
in
Section
IV
were
revised
to
obtain
this
information
for
only
the
MP&
M
activities
on
a
federal
site.
The
ICR
for
this
data
collection
and
the
survey
instructions
contain
further
details
on
the
types
of
information
collected
and
the
potential
uses
of
the
information.
Table
3­
2
summarizes
the
1996
federal
detailed
survey
information
by
question
number.

Data
Review
and
Data
Entry
EPA
completed
a
detailed
engineering
review
of
Sections
I
through
III
of
the
federal
survey
to
evaluate
the
accuracy
of
technical
information
provided
by
the
respondents.
During
the
engineering
review,
the
Agency
coded
responses
to
facilitate
entry
of
technical
data
into
the
federal
survey
database.
The
MP&
M
1996
Federal
Survey
Database
Dictionary
identifies
the
database
codes
developed
for
this
project
and
is
located
in
Section
5.3.5.2
of
the
rulemaking
record,
DCN
15991.

The
Agency
developed
a
database
for
the
technical
information
provided
by
survey
respondents.
After
engineering
review
and
coding,
EPA
entered
data
from
44
federal
surveys
into
the
database
using
a
double
key­
entry
and
verification
procedure.
The
Agency
did
3­
24
3.0
­
Data
Collection
Activities
not
include
data
from
seven
federal
survey
responses
in
the
database
because
the
sites
did
not
use
MP&
M
process
water.
The
MP&
M
1996
Federal
Survey
Database
Dictionary
presents
the
database
structure
and
defines
each
field
in
the
database
files.

The
Economic,
Environmental,
and
Benefits
Analysis
of
the
Proposed
Metal
Products
and
Machinery
Rule
,
which
is
located
in
Section
8.1
of
the
rulemaking
record,
DCN
2000,
discusses
EPA s
review
of
Section
IV
of
the
federal
survey.

3.1.2.6
1996
POTW
Detailed
Survey
EPA
distributed
the
POTW
survey
to
150
sites
in
November
1997.
The
Agency
designed
this
survey
to
evaluate
benefits
associated
with
the
MP&
M
regulations
and
to
estimate
possible
costs
and
burden
that
POTWs
might
incur
in
writing
and
maintaining
MP&
M
permits
or
other
control
mechanisms.

Recipient
Selection
and
Distribution
The
Agency
sent
the
POTW
survey
to
150
POTWs
with
flow
rates
greater
than
0.50
million
gallons
per
day.
EPA
randomly
selected
the
recipients
from
the
1992
Needs
Survey
Review,
Update,
and
Query
System
Database.
EPA
divided
the
POTW
sample
into
two
strata
by
daily
flow
rates:
0.50
to
2.50
million
gallons,
and
2.50
million
gallons
or
more.
The
selection
criteria
and
sampling
frame
for
POTW
survey
recipients
are
described
in
more
detail
in
the
ICR
for
the
1996
surveys.

EPA
established
a
toll­
free
telephone
helpline
and
an
electronic
mail
address
to
assist
POTW
survey
recipients
in
completing
the
survey.
EPA
received
helpline
calls
and
electronic
mail
inquiries
from
approximately
50
POTW
survey
respondents.
Nonconfidential
notes
from
helpline
and
review
follow­
up
calls
are
located
in
Section
8.7
of
the
public
record
for
this
rulemaking.

1996
POTW
Survey
Mailout
Results
Of
the
150
POTW
surveys
mailed,
two
surveys
were
returned
undelivered
and
98
percent
(
147)
of
the
recipients
returned
completed
surveys
to
EPA.
A
blank
copy
of
the
1996
POTW
survey
(
Section
3.7.1,
DCN
16369)
and
nonconfidential
portions
of
the
completed
POTW
survey
(
Section
8.7)
are
located
in
the
public
record
for
this
rulemaking.
Table
3­
1
and
Figure
3­
1
summarize
the
MP&
M
survey
mailout
results.

Information
Collected
The
POTW
survey
requested
data
required
to
estimate
benefits
and
costs
associated
with
implementation
of
the
MP&
M
regulations.
The
ICR
for
this
data
collection
and
the
survey
instructions
contain
further
details
on
the
types
of
information
collected
and
the
potential
uses
of
the
information.
EPA
divided
the
POTW
survey
into
the
following
parts:

3­
25
3.0
­
Data
Collection
Activities
 
Part
I:
Introduction
and
Basic
Information;

 
Part
II:
Administrative
Permitting
Costs;
and
 
Part
III:
Sewage
Sludge
Use
or
Disposal
Costs.

Part
I
requested
site
location
and
contact
information
and
the
total
volume
of
wastewater
treated
at
the
site.
EPA
used
the
wastewater
flow
information
to
characterize
the
size
of
the
POTW.

Part
II
requested
the
number
of
industrial
permits
written,
the
cost
to
write
the
permits,
the
permitting
fee
structure,
the
percentage
of
industrial
dischargers
covered
by
National
Categorical
Standards
(
i.
e.,
effluent
guidelines),
and
the
percentage
of
permits
requiring
expensive
administrative
activities.
EPA
used
this
information
to
estimate
administrative
burden
and
costs.

Part
III
requested
information
on
the
use
or
disposal
of
sewage
sludge
generated
by
the
POTW.
EPA
required
only
POTWs
that
received
discharges
from
facilities
performing
proposed
MP&
M
operations
to
complete
Part
III.
The
sewage
sludge
information
requested
included
the
amount
generated,
use
or
disposal
method,
metal
levels,
use
or
disposal
costs,
and
the
percentage
of
total
metal
loadings
at
the
POTW
from
facilities
performing
proposed
MP&
M
operations.
The
Agency
used
this
information
to
assess
the
potential
changes
in
sludge
handling
resulting
from
the
MP&
M
rule
and
to
estimate
economic
benefits
to
the
POTW
related
to
sludge
disposal
and
reduction
in
upsets/
interference.

Data
Review
and
Data
Entry
EPA
performed
a
detailed
review
of
the
POTW
survey
to
evaluate
the
accuracy
of
information
provided
by
the
respondents.
During
the
review,
the
Agency
coded
responses
to
facilitate
entry
of
data
into
the
POTW
survey
database.
The
database
dictionary
for
the
POTW
survey
identifies
the
database
codes
developed
for
this
project,
and
is
located
in
Section
8.7
of
the
rulemaking
record.
EPA
contacted
more
than
95
POTW
survey
respondents
by
telephone
to
clarify
incomplete
or
inconsistent
information
prior
to
data
entry.

The
Agency
developed
a
database
for
the
information
provided
by
survey
respondents.
After
review
and
coding,
EPA
entered
data
from
147
POTW
surveys
into
the
database
using
a
double
key­
entry
and
verification
procedure.
The
database
dictionary
presents
the
database
structure
and
defines
each
field
in
the
database
files.

3.1.3
1997
Iron
and
Steel
Industry
Survey
Data
As
part
of
its
effort
to
review
and
revise
effluent
limitations
guidelines
and
standards
for
the
Iron
and
Steel
Point
Source
Category
(
40
CFR
420),
EPA
distributed,
reviewed,
and
coded
the
iron
and
steel
industry
detailed
and
short
surveys
of
402
iron
and
steel
facilities
in
November
1998.

3­
26
3.0
­
Data
Collection
Activities
EPA
included
data
from
154
iron
and
steel
surveys
in
the
MP&
M
survey
database.
EPA
used
these
154
Iron
&
Steel
surveys
to
create
a
new
subcategory,
Steel
Forming
and
Finishing,
in
the
January
2001
proposal.
Based
on
comments
to
the
January
2001
proposal
and
June
2002
NODA,
EPA
concluded
that
those
operations
included
in
the
proposed
Steel
Forming
and
Finishing
Subcategory
of
the
MP&
M
Point
Source
Category
should
remain
subject
to
the
effluent
guidelines
and
standards
at
the
Iron
and
Steel
Point
Source
Category
(
40
CFR
420).
See
Section
6.0
for
further
discussion
of
subcategorization.

As
discussed
in
the
June
2002
NODA
(
67
FR
38752),
EPA
considered
establishing
a
segment
of
the
Steel
Forming
and
Finishing
Subcategory
for
discharges
resulting
from
continuous
electroplating
of
flat
steel
products
(
e.
g.,
strip,
sheet,
and
plate).
EPA
examined
its
database
for
facilities
that
perform
continuous
steel
electroplating
and
found
that
continuous
electroplaters
do
not
perform
operations
similar
to
facilities
in
the
proposed
Steel
Forming
and
Finishing
Subcategory.
Rather,
continuous
electroplaters
perform
operations
included
in
the
proposed
General
Metals
Subcategory.
Therefore,
in
evaluating
options
for
the
final
rule,
EPA
included
continuous
electroplaters
in
the
proposed
General
Metals
Subcategory.
See
Section
6.0
for
a
detailed
discussion
of
subcategorization.
For
this
reason,
EPA
incorporated
the
information
on
these
operations
reported
in
24
iron
and
steel
surveys
into
the
MP&
M
database.
Operations
on
the
continuous
electroplating
lines
may
include:

 
Acid
cleaning;

 
Alkaline
cleaning;

 
Conversion
coating
(
e.
g.,
passivation,
surface
activation/
fluxing);

 
Electroplating;

 
Rinsing;
and
 
Sealing.

All
24
sites
with
electroplating
lines
processing
steel
flat­
rolled
products
discharge
process
wastewater.
The
Agency
coded
and
entered
process
and
wastewater
treatment
information
from
the
47
lines
in
the
24
iron
and
steel
surveys
into
the
MP&
M
cost
model.
A
blank
copy
of
the
1997
iron
and
steel
detailed
and
short
surveys
and
nonconfidential
portions
of
the
24
completed
iron
and
steel
surveys
are
located
in
Sections
5.3.6
and
15.1
of
the
public
record
for
this
rulemaking.
As
discussed
in
Section
9.0,
EPA
rejected
establishing
limitations
and
standards
for
the
proposed
General
Metals
Subcategory.
Continuous
electroplaters
remain
subject
to
the
Metal
Finishing
Point
Source
Category
(
40
CFR
433),
as
applicable.

1997
Iron
and
Steel
Survey
Recipient
Selection
and
Distribution
The
Agency
consulted
with
industry
trade
associations
and
visited
a
number
of
sites
to
develop
the
survey
instruments
and
to
ensure
an
accurate
mailing
list.

3­
27
3.0
­
Data
Collection
Activities
EPA
distributed
four
industry
surveys:

 
U.
S.
EPA
Collection
of
1997
Iron
and
Steel
Industry
Data
(
detailed
survey);

 
U.
S.
EPA
Collection
of
1997
Iron
and
Steel
Industry
Data
(
Short
Form)
(
short
survey);

 
U.
S.
EPA
Collection
of
Iron
and
Steel
Industry
Wastewater
Treatment
Capital
Cost
Data
(
cost
survey);
and
 
U.
S.
EPA
Analytical
and
Production
Data
Follow­
Up
to
the
Collection
of
1997
Iron
and
Steel
Industry
Data
(
analytical
and
production
survey).

In
October
1998,
EPA
mailed
the
detailed
survey
to
176
iron
and
steel
sites
and
the
short
survey
to
223
iron
and
steel
sites.
EPA
designed
the
detailed
survey
for
those
iron
and
steel
sites
that
perform
any
iron
and
steel
manufacturing
process.
Those
sites
include
integrated
and
non­
integrated
steel
mills,
as
well
as
sites
that
were
initially
identified
as
stand­
alone
cokemaking
plants,
stand­
alone
sinter
plants,
stand­
alone
direct­
reduced
ironmaking
plants,
stand­
alone
hot
forming
mills,
and
stand­
alone
finishing
mills.
The
short
survey
is
an
abbreviated
version
of
the
detailed
survey.
It
was
designed
for
stand­
alone
iron
and
steel
sites
with
the
exceptions
of
those
that
received
the
detailed
survey.
EPA
mailed
the
cost
survey
and
the
analytical
and
production
survey
to
subsets
of
the
facilities
that
received
the
detailed
or
short
survey
to
obtain
more
detailed
information
on
wastewater
treatment
system
costs,
analytical
data,
and
facility
production.
EPA
mailed
the
cost
survey
to
90
iron
and
steel
sites
and
the
analytical
and
production
survey
to
38
iron
and
steel
sites.

EPA
mailed
the
iron
and
steel
industry
surveys
by
mail
to
facilities
that
were
identified
from
the
following
sources:

 
Association
of
Iron
and
Steel
Engineers 
1997
and
1998
Directories:
Iron
and
Steel
Plants
Volume
1,
Plants
and
Facilities
;

 
Iron
and
Steel
Works
of
the
World
(
11th
and
12th
editions)
directories;

 
Iron
and
Steel
Society s
The
Steel
Industry
of
Canada,
Mexico,
and
the
United
States:
Plant
Locations
;

 
Member
lists
from
the
following
trade
associations:
­
American
Coke
and
Coal
Chemicals
Institute,
­
American
Galvanizers
Association,
­
American
Iron
and
Steel
Institute,
­
American
Wire
Producers
Association,
­
Cold
Finished
Steel
Bar
Institute,

3­
28
3.0
­
Data
Collection
Activities
­
Specialty
Steel
Industry
of
North
America,
­
Steel
Manufacturers
Association,
­
Steel
Tube
Institute
of
North
America,
and
­
Wire
Association
International;

 
Dun
&
Bradstreet
Facility
Index
Database
;

 
EPA s
Permit
Compliance
System
(
PCS)
Database
;

 
EPA s
Toxic
Release
Inventory
(
TRI)
Database
;

 
Iron
and
Steel
Society s
Iron
and
Steelmaker
 
Roundup 
editions;

 
33
Metalproducing
 
Roundup 
editions
(
Reference
3­
22);

 
33
Metalproducing
 
Census
of
the
North
American
Steel
Industry ;
and
 
Thomas
Register
.

The
Agency
cross­
referenced
these
sources
with
one
another
to
develop
a
list
of
individual
sites.
Based
on
these
sources,
EPA
identified
822
candidate
facilities
to
receive
surveys.
To
minimize
the
burden
on
the
respondents,
EPA
grouped
facilities
into
12
strata.
In
general,
EPA
determined
the
strata
based
on
its
understanding
of
the
manufacturing
processes
at
each
facility.

Depending
on
the
amount
or
type
of
information
EPA
required
for
the
rulemaking,
EPA
either
solicited
information
from
all
facilities
within
a
stratum
(
i.
e.,
a
census
or
 
certainty 
stratum)
or
selected
a
random
sample
of
facilities
within
a
stratum
(
i.
e.,
statistically
sampled
stratum).
EPA
sent
a
survey
to
all
facilities
in
the
certainty
strata
(
strata
5
and
8)
because
the
Agency
determined
it
was
necessary
to
capture
the
size,
complexity,
or
uniqueness
of
the
steel
operations
at
these
sites.
EPA
also
sent
surveys
to
all
facilities
in
strata
1
through
4
(
all
cokemaking
sites,
integrated
steelmaking
sites,
and
sintering
and
direct­
reduced
ironmaking
sites)
because
of
the
relatively
low
number
of
sites
in
each
stratum
and
because
of
the
size,
complexity,
and
uniqueness
of
raw
material
preparation
and
steel
manufacturing
operations
at
these
sites.
The
Agency
statistically
sampled
the
remaining
sites
in
strata
6,
7,
and
9
through
12.
EPA
calculated
survey
weights
for
each
selected
facility
based
on
the
facility s
probability
of
selection.
If
the
Agency
sent
a
survey
to
every
facility
in
a
stratum,
each
selected
facility
represents
only
itself
and
has
a
survey
weight
of
one.
For
statistically
sampled
strata,
each
selected
facility
represents
itself
and
other
facilities
within
that
stratum
that
were
not
selected
to
receive
an
industry
survey.
These
facilities
have
survey
weights
greater
than
one.
See
the
Development
Document
for
Final
Effluent
Limitations
Guidelines
and
Standards
for
the
Iron
and
Steel
Manufacturing
Point
Source
Category
(
EPA­
821­
R­
02­
004)
for
more
details.

3­
29
3.0
­
Data
Collection
Activities
Of
the
822
candidate
facilities,
EPA
mailed
either
a
detailed
survey
or
a
short
survey
to
399
facilities.
2
Detailed
survey
recipients
included
integrated
mills,
non­
integrated
mills,
stand­
alone
cokemaking
sites,
stand­
alone
sintering
sites,
stand­
alone
direct­
reduced
ironmaking
sites,
stand­
alone
hot
forming
sites,
and
stand­
alone
finishing
sites.
Short
survey
recipients
included
stand­
alone
cold
forming
sites,
stand­
alone
pipe
and
tube
sites,
stand­
alone
hot
dip
coating
sites,
and
stand­
alone
wire
sites.

Once
the
Agency
completed
a
review
of
the
detailed
and
short
surveys
and
defined
the
technology
options,
EPA
identified
survey
respondents
who
had
installed
wastewater
treatment
systems
in
the
last
10
years
(
since
1990)
that
were
similar
to
the
technology
options
and
mailed
them
the
cost
survey.
EPA
selected
38
facilities
to
receive
the
analytical
and
production
survey
who
had
indicated
in
the
detailed
or
short
survey
that:
(
1)
they
had
treatment
trains
similar
to
the
treatment
technology
options,
(
2)
they
had
collected
analytical
data
for
that
treatment
train,
(
3)
they
had
a
treatment
train
with
a
dedicated
outfall
from
which
EPA
could
evaluate
performance,
and
(
4)
they
did
not
add
excessive
dilution
water
to
the
outfall
before
sampling.

1997
Iron
and
Steel
Survey
Information
Collected
The
detailed
and
short
surveys
were
divided
into
two
parts:
Part
A:
Technical
Information
and
Part
B:
Financial
and
Economic
Information.
The
 
Part
A 
technical
questions
in
the
detailed
survey
comprised
four
sections,
with
Sections
3
and
4
being
combined
in
the
short
survey,
as
follows:

 
Section
1:
General
Site
Information;

 
Section
2:
Manufacturing
Process
Information;

 
Section
3:
In­
Process
and
End­
of­
Pipe
Wastewater
Treatment
and
Pollution
Prevention
Information;
and
 
Section
4:
Wastewater
Outfall
Information.

The
financial
and
economic
information
in
Part
B
of
the
detailed
survey
also
comprised
four
sections,
as
shown
below:

 
Section
1:
Site
Identification;

 
Section
2:
Site
Financial
Information;

 
Section
3:
Business
Entity
Financial
Information;
and
2Before
the
surveys
were
actually
mailed,
the
Agency
notified
potential
survey
recipients.
One
site,
randomly
selected
from
stratum
12
and
notified
that
it
would
be
receiving
a
survey,
notified
the
Agency
that
it
was
not
engaged
in
iron
and
steel
activities.
The
Agency
decided
not
to
mail
a
survey
to
that
site.
Therefore,
this
site
was
not
included
in
the
399
facilities
receiving
surveys.

3­
30
3.0
­
Data
Collection
Activities
 
Section
4:
Corporate
Parent
Financial
Information.

Part
B
of
the
short
survey
contained
a
single
section
for
site
identification
and
financial
information.
More
detailed
descriptions
of
financial
data
collection
and
analysis
are
included
in
the
Economic
Analysis
of
Final
Effluent
Limitations
Guidelines
and
Standards
for
the
Iron
and
Steel
Manufacturing
Point
Source
Category
(
EPA
821­
R­
02­
006).

The
detailed
survey
requested
detailed
descriptions
of
all
manufacturing
processes
and
treatment
systems
on
site.
The
short
survey
contained
manufacturing
process
questions
for
only
forming
and
finishing
operations.
EPA
eliminated
the
cokemaking,
ironmaking,
and
steelmaking
questions
from
the
short
survey
because
those
processes
were
not
applicable
to
the
facilities
that
received
the
short
survey.
The
Agency
also
reduced
the
amount
of
detail
requested
in
the
short
survey.
EPA
used
the
detailed
descriptions
of
hot
forming
mills
from
the
integrated,
non­
integrated,
and
stand­
alone
hot
forming
mills
to
make
assumptions
about
industry
trends.

Part
A
Section
1
requested
site
contacts
and
addresses
and
general
information
regarding
manufacturing
operations,
age,
and
location.
The
Agency
used
this
information
to
develop
the
proposed
subcategorization
and
applicability
statements.

Part
A
Section
2
requested
information
on
products,
types
of
steel
produced,
production
levels,
unit
operations,
chemicals
and
coatings
used,
quantity
of
wastewater
discharged
from
unit
operations,
miscellaneous
wastewater
sources,
flow
rates,
pollution
prevention
activities,
and
air
pollution
control.
The
Agency
used
these
data
to
evaluate
manufacturing
processes
and
wastewater
generation,
to
develop
the
model
production­
normalized
flow
rates,
and
to
develop
regulatory
options.
EPA
also
used
these
data
to
develop
the
proposed
subcategorization
and
applicability
and
to
estimate
compliance
costs
and
pollutant
removals
associated
with
the
regulatory
options
EPA
considered
for
the
final
rule.

Part
A
Section
3
requested
detailed
information
(
including
diagrams)
on
the
wastewater
treatment
systems
and
discharge
flow
rates,
monitoring
analytical
data,
and
operating
and
maintenance
cost
data
(
including
treatment
chemical
usage).
The
Agency
used
these
data
to
identify
treatment
technologies
in
place,
to
determine
regulatory
options,
and
to
estimate
compliance
costs
and
pollutant
removals
associated
with
the
regulatory
options
considered
for
the
final
rule.

Part
A
Section
4
requested
permit
information,
discharge
locations,
wastewater
sources
to
each
outfall,
flow
rates,
regulated
pollutants
and
limits,
and
permit
monitoring
data.
EPA
used
this
information
to
calculate
baseline
or
current
loadings
for
each
facility.
The
Agency
also
used
this
information
to
calculate
the
pollutant
loadings
associated
with
the
regulatory
options
considered
for
the
final
rule.

The
cost
survey
requested
detailed
capital
cost
data
on
selected
wastewater
treatment
systems
installed
since
1993,
including
equipment,
engineering
design,
and
installation
costs.
(
EPA
chose
1993
because
1997
was
the
base
year
for
the
detailed
and
short
surveys,
and
3­
31
3.0
­
Data
Collection
Activities
this
provided
the
Agency
with
a
five­
year
range
for
collecting
cost
data
on
recently
installed
treatment
systems.)
EPA
incorporated
these
data
into
a
costing
methodology
and
used
them
to
determine
incremental
investment
costs
and
incremental
operating
and
maintenance
costs
associated
with
the
regulatory
options
considered
for
the
final
rule.

The
analytical
and
production
survey
requested
detailed
daily
analytical
and
flow
rate
data
for
selected
sampling
points,
and
monthly
production
data
and
operating
hours
for
selected
manufacturing
operations.
The
Agency
used
the
analytical
data
collected
to
estimate
baseline
pollutant
loadings
and
pollutant
removals
from
facilities
with
treatment
in
place
similar
to
the
technology
options
considered
for
the
final
rule,
to
evaluate
the
variability
associated
with
iron
and
steel
industry
discharges,
and
to
establish
effluent
limitations
guidelines
and
standards.
The
Agency
used
the
production
data
collected
to
evaluate
the
production
basis
for
applying
the
proposal
in
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permits
and
pretreatment
control
mechanisms.

1997
Iron
and
Steel
Surveys
Data
Review
and
Data
Entry
EPA
completed
a
detailed
engineering
review
of
the
detailed
surveys
to
evaluate
the
accuracy
of
technical
information
provided
by
the
respondents.
During
the
engineering
review,
EPA
coded
responses
to
facilitate
entry
of
technical
data
into
the
survey
database.
EPA
contacted
survey
respondents,
by
telephone
and
letter,
to
clarify
incomplete
or
inconsistent
technical
information
prior
to
data
entry.

The
Agency
developed
a
database
for
the
technical
information
provided
by
survey
respondents.
After
engineering
review
and
coding,
EPA
entered
data
from
the
surveys
into
the
database
using
a
double
key­
entry
and
verification
procedure.
During
the
engineering
review,
EPA
coded
responses
to
facilitate
entry
of
technical
data
into
the
survey
database.

3.1.4
Data
Submitted
by
the
American
Association
of
Railroads
(
AAR)

As
noted
in
the
June
2002
NODA
(
67
FR
38752),
EPA
conducted
another
review
of
all
railroad
line
maintenance
(
RRLM)
facilities
in
the
MP&
M
questionnaire
database
to
determine
the
destination
of
discharged
wastewater
(
i.
e.,
either
directly
to
surface
waters
or
indirectly
to
POTWs
or
both)
and
the
applicability
of
the
final
rule
to
discharged
wastewaters.
As
a
result
of
this
review,
EPA
determined
its
questionnaire
database
did
not
accurately
represent
direct
dischargers
in
this
subcategory.
Consequently,
EPA
used
information
supplied
during
the
comment
period
by
the
American
Association
of
Railroads
(
AAR)
as
a
basis
for
its
analyses
and
conclusions
on
direct
dischargers
in
this
subcategory.

AAR
is
a
trade
association
which
currently
represents
all
facilities
in
the
RRLM
Subcategory.
As
discussed
in
the
NODA
(
see
67
FR
38755),
for
each
RRLM
direct
discharging
facility
known
to
them,
AAR
provided
current
permit
limits,
treatment­
in­
place,
and
summarized
information
on
each
facility s
measured
monthly
average
and
daily
maximum
values.
AAR
also
3­
32
3.0
­
Data
Collection
Activities
provided
a
year s
worth
of
long­
term
monitoring
data
for
each
facility
(
see
Section
15.1
of
the
rulemaking
record
for
the
AAR
surveys).

AAR
provided
information
on
27
facilities.
EPA
reviewed
the
information
on
each
of
these
facilities
to
ensure
they
were
direct
dischargers,
discharged
wastewaters
resulting
from
operations
subject
to
this
final
rule,
and
discharged
"
process"
wastewaters
as
defined
by
the
final
rule.
As
a
result
of
this
review,
EPA
concluded
18
of
the
facilities
for
which
AAR
provided
information
do
not
directly
discharge
wastewaters
exclusively
from
oily
operations.
Therefore,
EPA's
final
database
consists
of
nine
direct
discharging
RRLM
facilities.

3.1.5
National
Estimates
EPA
used
the
data
collected
in
the
MP&
M
and
iron
and
steel
industry
surveys
to:
(
1)
calculate
national
estimates
of
the
number
and
types
of
facilities
performing
proposed
MP&
M
operations;
(
2)
develop
the
industry
profile
presented
in
Section
4.0;
(
3)
estimate
the
current
pollutant
discharges
from
facilities
performing
proposed
MP&
M
operations;
and
(
4)
identify
the
baseline
of
treatment
in
place.
The
Agency
assigned
each
survey
a
specific
survey
weight
to
use
as
a
multiplier
for
national
estimates.

Sampling
Frame
To
produce
a
mailing
list
of
facilities
for
the
MP&
M
and
the
iron
and
steel
surveys,
EPA
developed
a
sampling
frame
of
the
industry.
A
sampling
frame
is
a
list
of
all
members
(
sampling
units)
of
a
population,
from
which
a
random
sample
of
members
will
be
drawn
for
the
survey.
Therefore,
a
sample
frame
is
the
basis
for
the
development
of
a
sampling
plan
to
select
a
random
sample.
A
sample
frame
size
(
N)
is
the
total
number
of
members
in
the
frame.

EPA
mailed
MP&
M
industry
surveys
to
all
of
the
facilities
in
the
sample.
Based
on
the
survey
responses,
EPA
determined
that
some
facilities
were
 
out
of
scope 
or
 
ineligible 
because
the
regulation
would
not
apply
to
them.
EPA
also
made
a
nonrespondent
adjustment
to
the
weights
(
see
below).

Calculation
of
Sample
Weights
The
next
step
in
developing
national
estimates
is
to
calculate
the
base
weights,
nonresponse
adjustments,
and
the
final
weights.
The
base
weights
and
nonresponse
adjustments
reflect
the
probability
of
selection
for
each
facility
and
adjustments
for
facility­
level
nonresponses,
respectively.
Weighting
the
data
allows
inferences
to
be
made
about
all
eligible
facilities,
not
just
those
included
in
the
sample,
but
also
those
not
included
in
the
sample
or
those
that
did
not
respond
to
the
survey.
Also,
the
weighted
estimates
have
a
smaller
variance
than
unweighted
estimates.
In
its
analysis,
EPA
applied
sample
weights
to
survey
data.

3­
33
3.0
­
Data
Collection
Activities
Calculation
of
National
Estimates
For
each
characteristic
of
interest
(
e.
g.,
number
of
sites
using
a
particular
unit
operation
or
annual
discharge
flow
from
a
particular
unit
operation),
EPA
estimated
totals
for
the
entire
U.
S.
industry
performing
proposed
MP&
M
operations
(
i.
e.,
national
estimates).
Each
national
estimate,
Yst
,
was
calculated
as:

(
3­
1)

where:
h
=
Survey
where
h
=
1,2,
...
T;
T
=
Total
number
of
surveys;
FINALWTh
=
Final
weight
for
survey
h;
and
yhi
=
ith
value
from
the
sample.

The
development
of
survey
weights
and
national
estimates
for
the
MP&
M
surveys
are
discussed
in
greater
detail
in
the
Statistical
Summary
for
the
Metal
Products
&
Machinery
Industry
Surveys
(
Section
10.0,
DCN
16118)
and
DCNs
36086
and
36087,
Section
19.5.

Each
national
estimate
for
the
entire
U.
S.
iron
and
steel
industry,
 
st
,
was
calculated
as:

(
3­
2)

where:

h
=
Stratum
and
h=
1,2,...
12
since
there
are
12
strata;
FINALWTh
=
Final
weight
for
the
stratum
h;
and
yih
=
Ith
value
from
the
sample
in
stratum
h.

The
development
of
the
iron
and
steel
survey
weights
and
national
estimates
are
discussed
in
greater
detail
in
the
Development
Document
for
Final
Effluent
Limitations
Guidelines
and
Standards
for
the
Iron
and
Steel
Manufacturing
Point
Source
Category
(
EPA­
821­
R­
02­
004).

3.2
Site
Visits
The
Agency
visited
234
facilities
performing
proposed
MP&
M
operations
and
iron
and
steel
sites
between
1986
and
2001
to
collect
information
about
proposed
MP&
M
operations,
water
use
practices,
pollution
prevention
and
treatment
technologies,
and
waste
disposal
methods,
and
to
evaluate
sites
for
potential
inclusion
in
the
MP&
M
sampling
program
(
described
in
Section
3.3).
In
general,
the
Agency
visited
sites
to
encompass
the
range
of
sectors,
unit
operations,
and
wastewater
treatment
technologies
within
the
industry
(
discussed
in
Section
3­
34
3.0
­
Data
Collection
Activities
3.2.1).
Table
3­
3
lists
the
number
of
sites
visited
within
each
industrial
sector.
The
total
number
of
site
visits
presented
in
this
table
exceeds
234
because
some
sites
had
operations
in
more
than
one
sector.
Figure
3­
2
presents
the
number
of
facilities
visited
and
sampled
by
industrial
sector.
Table
3­
3
and
Figure
3­
2
also
include
site
visits
initially
conducted
as
part
of
the
iron
and
steel
rulemaking,
the
results
of
which
were
incorporated
into
the
MP&
M
rulemaking.

Table
3­
3
Number
of
Sites
Visited
Within
Each
Proposed
Industrial
Sector
Industrial
Sectors
Total
Number
of
Sites
Visited
Industrial
Sectors
Total
Number
of
Sites
Visited
Aerospace
Aircraft
Bus
and
Truck
Electronic
Equipment
Hardware
Household
Equipment
Instrument
Job
Shops
Miscellaneous
Metal
Products
Mobile
Industrial
Equipment
Motor
Vehicle
13
32
8
23
15
4
4
25
0
7
20
Office
Machines
Ordnance
Precious
Metals
and
Jewelry
Printed
Wiring
Boards
Railroad
Ships
and
Boats
Stationary
Industrial
Equipment
Steel
Continuous
Electroplatinga
Steel
Forming
and
Finishing:
Wire
Drawinga
5
15
2
17
10
7
14
15
4
Source:
MP&
M
and
Iron
and
Steel
Site
Visits.

a
The
number
of
sites
visited
is
listed
separately
for
steel
forming
and
finishing
and
steel
continuous
electroplating
sites
instead
of
by
industrial
sector.

3.2.1
Criteria
for
Site
Selection
The
Agency
selected
sites
for
visits
based
on
information
contained
in
the
MP&
M
and
iron
and
steel
surveys.
The
Agency
also
contacted
regional
EPA
personnel,
state
environmental
agency
3­
35
3.0
­
Data
Collection
Activities
3­
36
Industrial
Sector
Steel
Forming
and
Finishing
­
Wire
Draw
ing
Steel
Continuous
Electroplating
Stationary
Industrial
Equipment
Ships
and
Boats
Railroad
Printed
Wiring
Boards
Precious
Metals
and
Jew
elry
Ordnance
Office
Machines
Motor
Vehicles
Mobile
Industrial
Equipment
Miscellaneous
Metal
Products
Job
Shop
Metal
Finishing
Instruments
Household
Equipment
Hardware
Electronic
Equipment
Bus
and
Truck
Aircraft
Aerospace
13
2
329
84
234
15
4
4
2
4
2
2510
NA
7
2
20
9
5
2
15
3
2
(
both)
17
5
104
73
144
6
2
42
Number
of
Sites
Sampled
Number
of
Sites
Visited
0
5
101520253035
Number
of
Sites
Figure
3­
2.
Number
of
Facilities
Performing
Proposed
MP&
M
Operations
Visited
and
Sampled
by
Industrial
Sector
3.0
­
Data
Collection
Activities
personnel,
and
local
pretreatment
coordinators
to
identify
facilities
performing
proposed
MP&
M
operations
believed
to
be
operating
in­
process
source
reduction
and
recycling
technologies
and/
or
well­
operated
end­
of­
pipe
wastewater
treatment
technologies.
For
visits
to
iron
and
steel
sites
prior
to
receipt
of
any
completed
survey,
EPA
used
information
collected
from
the
sources
used
to
develop
the
iron
and
steel
survey
receipt
list
(
discussed
in
Section
3.1.3).

The
Agency
used
the
following
four
general
criteria
to
select
sites
that
encompassed
the
range
of
sectors
and
unit
operations
within
the
industry:

1.
The
site
performed
proposed
MP&
M
operations
in
one
of
the
industrial
sectors.
To
assess
the
variation
of
unit
operations
and
water­
use
practices
across
sectors,
the
Agency
visited
sites
in
18
industrial
sectors.

2.
The
site
performed
proposed
MP&
M
operations
that
needed
to
be
characterized
for
development
of
the
regulation.

3.
The
site
had
water­
use
practices
that
were
believed
to
be
representative
of
the
best
sites
within
an
industrial
sector.

4.
The
site
operated
in­
process
source
reduction,
recycling,
or
end­
of­
pipe
treatment
technologies
EPA
was
evaluating
in
developing
the
MP&
M
technology
options.

The
Agency
also
visited
sites
of
various
sizes.
EPA
visited
sites
with
wastewater
flows
ranging
from
less
than
200
gallons
per
day
(
gpd)
to
more
than
1,000,000
gpd.

EPA
selected
iron
and
steel
sites
to
visit
based
on
the
type
of
site
(
steel
forming
and
finishing,
integrated,
non­
integrated),
the
manufacturing
operations
at
each
facility,
the
type
of
steel
produced
(
carbon,
alloy,
stainless),
and
the
wastewater
treatment
operations.
The
Agency
wanted
to
visit
all
types
of
iron
and
steel
manufacturing
operations
as
well
as
all
types
of
wastewater
treatment
operations,
including
recently
installed
treatment
systems.
After
EPA
evaluated
the
completed
surveys
and
in
response
to
comments
received
on
the
proposed
rule,
the
Agency
used
information
provided
by
the
sites
to
select
additional
iron
and
steel
sites
to
visit.

Site­
specific
selection
criteria
are
discussed
in
site
visit
reports
(
SVRs)
prepared
for
each
site
visited
by
EPA.
The
SVRs
are
located
in
Sections
5.1
and
15.2
of
the
rulemaking
record.

3­
37
3.0
­
Data
Collection
Activities
3.2.2
Information
Collected
During
the
site
visits,
EPA
collected
the
following
types
of
information:

 
Types
of
unit
operations
performed
at
the
site
and
the
types
of
metals
processed
through
these
operations;

 
Purpose
of
unit
operations
performed
and
purpose
of
any
process
water
and
chemical
additions
used
by
the
unit
operations;

 
Types
and
disposition
of
wastewater
generated
at
the
site;

 
Types
of
in­
process
source
reduction
and
recycling
technologies
performed
at
the
site;

 
Cross­
media
impacts
of
in­
process
source
reduction
and
recycling
technologies;

 
Types
of
end­
of­
pipe
treatment
technologies
performed
at
the
site;
and
 
Logistical
information
required
for
sampling.

This
information
is
documented
in
the
SVRs
for
each
site.
Nonconfidential
SVRs
can
be
found
in
the
MP&
M
rulemaking
record
(
see
Sections
5.1
and
15.2).

EPA
MP&
M
Sampling
Program
The
Agency
conducted
sampling
episodes
at
84
sites
between
1986
and
2001
to
obtain
data
on
the
characteristics
of
wastewater
and
solid
wastes.
In
addition,
EPA
performed
sampling
episodes
to
assess
the
following:
(
1)
the
loading
of
pollutants
to
surface
waters
and
POTWs
from
facilities
performing
proposed
MP&
M
operations;
(
2)
the
effectiveness
of
technologies
designed
to
reduce
and
remove
pollutants
from
wastewater;
and
(
3)
the
variation
of
wastewater
characteristics
across
unit
operations,
metal
types
processed
in
each
unit
operation,
and
sectors.
Table
3­
4
indicates
the
number
of
sites
sampled
within
each
industrial
sector.
The
number
of
sampled
sites
presented
in
the
table
does
not
equal
84
because
EPA
conducted
multiple
sampling
episodes
at
some
sites,
and
some
sites
had
operations
in
multiple
sectors.
Figure
3­
2
presents
the
number
of
sites
visited
and
sampled
by
industrial
sector.
Table
3­
4
and
Figure
3­
2
also
include
sites
initially
sampled
as
part
of
the
iron
and
steel
rulemaking,
the
results
of
which
were
incorporated
into
the
MP&
M
rulemaking.

3­
38
3.3
3.0
­
Data
Collection
Activities
Table
3­
4
Number
of
Sites
Sampled
Within
Each
Proposed
Industrial
Industrial
Sectors
Total
Number
of
Sites
Sampled
Industrial
Sectors
Total
Number
of
Sites
Sampled
Aerospace
Aircraft
Bus
and
Truck
Electronic
Equipment
Hardware
Household
Equipment
Instruments
Job
Shops
Miscellaneous
Metal
Products
Mobile
Industrial
Equipment
Motor
Vehicle
2
9
4
4
4
2
2
10
0
2
9
Office
Machines
Ordnance
Precious
Metals
and
Jewelry
Printed
Wiring
Boards
Railroad
Ships
and
Boats
Stationary
Industrial
Equipment
Steel
Continuous
Electroplatinga
Steel
Forming
and
Finishing:
Wire
Drawinga
2
3
2
5
4
3
4
5
2
Source:
MP&
M
and
Iron
and
Steel
Sampling
Episodes.

a
The
number
of
sites
sampled
is
listed
separately
for
steel
forming
and
finishing
and
steel
continuous
electroplater
sites
instead
of
by
industrial
sector.

3.3.1
Criteria
for
Site
Selection
The
Agency
used
information
collected
during
MP&
M
site
visits
to
identify
candidate
sites
for
sampling.
The
Agency
used
the
following
general
criteria
to
select
sites
for
sampling:

 
The
site
performed
proposed
MP&
M
operations
EPA
was
evaluating
for
the
MP&
M
regulation;

 
The
site
processed
metals
through
proposed
MP&
M
operations
for
which
the
metal
type/
unit
operation
combination
needed
to
be
characterized
for
the
sampling
database;

 
The
site
performed
in­
process
source
reduction,
recycling,
or
end­
of­
pipe
treatment
technologies
that
EPA
was
evaluating
for
technology
option
development;
and
 
The
site
performed
unit
operations
in
a
sector
that
EPA
was
evaluating
for
the
MP&
M
regulation.

The
Agency
also
sampled
at
sites
of
various
sizes,
with
wastewater
flows
ranging
from
less
than
200
gpd
to
more
than
1,000,000
gpd.

3­
39
3.0
­
Data
Collection
Activities
EPA
selected
iron
and
steel
sampling
sites
using
the
following
criteria:

 
The
site
performed
operations
either
currently
regulated
under
40
CFR
420
or
identified
in
the
Preliminary
Study
or
otherwise
identified
as
iron
and
steel
operations;

 
The
site
performed
high­
rate
recycling,
in­
process
treatment,
or
end­
of­
pipe
treatment
operations
that
EPA
believed
may
represent
potential
model
pollutant
control
technology;
and
 
The
site s
compliance
monitoring
data
indicated
that
it
was
among
the
better
performing
pollutant
control
systems
in
the
industry,
based
on
comparisons
of
monitoring
data
from
other
facilities
with
limits
from
the
1982
regulation
in
their
permits.

In
response
to
comments
received
on
the
proposed
rule,
EPA
conducted
wastewater
sampling
at
four
additional
sites
between
November
2000
and
April
2001.
EPA
selected
these
additional
sites
for
the
following
reasons:

 
As
a
collaborative
effort
between
the
American
Iron
and
Steel
Institute
and
EPA,
to
supplement
the
1997/
1998
sampling
results
by
further
characterizing
raw
sinter
plant
wastewater,
specifically
the
amount
of
dioxins
and
furans
generated
by
this
industry,
and
to
evaluate
wastewater
treatment
system
performance;
and
 
To
further
characterize
untreated
wastewater
generated
by
continuous
casting
and
hot
forming
operations
at
non­
integrated
steel
mills.

After
it
selected
a
site
for
sampling,
the
Agency
prepared
a
detailed
sampling
and
analysis
plan
(
SAP),
based
on
the
information
contained
in
the
SVR
and
follow­
up
correspondence
with
the
site.
EPA
prepared
the
SAPs
to
ensure
samples
collected
would
be
representative
of
the
sampled
waste
streams.
The
SAPs
contained
the
following
types
of
information:
site­
specific
selection
criteria
for
sampling;
information
about
site
operations;
sampling
point
locations
and
sample
collection,
preservation,
and
transportation
procedures;
site
contacts;
and
sampling
schedules.

3.3.2
Information
Collected
In
addition
to
wastewater
and
solid
waste
samples,
the
Agency
collected
the
following
types
of
information
during
each
sampling
episode:

 
Dates
and
times
of
sample
collection;

 
Flow
data
corresponding
to
each
sample;

3­
40
3.0
­
Data
Collection
Activities
 
Production
data
corresponding
to
each
sample
of
wastewater
from
proposed
MP&
M
operations;

 
Design
and
operating
parameters
for
source
reduction,
recycling,
and
treatment
technologies
characterized
during
sampling;

 
Information
about
site
operations
that
had
changed
since
the
site
visit
or
that
were
not
included
in
the
SVR;
and
 
Temperature
and
pH
of
the
sampled
waste
streams.

EPA
documented
all
data
collected
during
sampling
episodes
in
the
sampling
episode
report
(
SER)
for
each
sampled
site.
SERs
are
located
in
Sections
5.2
and
15.3
of
the
rulemaking
record.

3.3.3
Sample
Collection
and
Analysis
The
Agency
collected,
preserved,
and
transported
all
samples
according
to
EPA
protocols
as
specified
in
EPA s
Sampling
and
Analysis
Procedures
for
Screening
of
Industrial
Effluents
for
Priority
Pollutants
(
1)
(
Section
4.2,
DCN
17334)
and
the
MP&
M
Quality
Assurance
Project
Plan
(
QAPP)
(
Section
4.4,
DCN
17366).
These
documents
are
located
in
the
rulemaking
record.
Appendix
B
presents
the
analytical
methods
and
baseline
values.

In
general,
EPA
collected
composite
samples
from
wastewater
streams
with
compositions
that
the
Agency
expected
to
vary
over
the
course
of
a
production
period
(
e.
g.,
overflowing
rinse
waters,
wastewater
from
continuous
recycling
and
treatment
systems).
The
Agency
collected
grab
samples
from
unit
operation
baths
or
rinses
that
the
facility
did
not
continuously
discharge
and
that
the
Agency
did
not
expect
to
vary
over
the
course
of
a
production
period.
EPA
also
collected
composite
samples
of
wastewater
treatment
sludge
at
11
facilities.
EPA
collected
the
required
types
of
quality
control
samples
as
described
in
the
MP&
M
QAPP,
such
as
blanks
and
duplicate
samples,
to
verify
the
precision
and
accuracy
of
sample
analyses.

The
Agency
shipped
samples
via
overnight
air
transportation
to
EPA­
approved
laboratories,
where
the
samples
were
analyzed
for
metal
and
organic
pollutants
and
additional
parameters
(
including
several
water
quality
parameters).
EPA
analyzed
metal
pollutants
using
EPA
Method
1620
(
2),
volatile
organic
pollutants
using
EPA
Method
1624
(
3),
and
semivolatile
organic
pollutants
using
EPA
Method
1625
(
4).
Tables
3­
5
and
3­
6
list
the
metal
and
organic
pollutants,
respectively,
analyzed
using
these
methods.
Table
3­
5
also
lists
additional
metal
pollutants
that
EPA
analyzed
in
the
MP&
M
sampling
program,
but,
as
specified
by
EPA
Method
1620,
were
not
subject
to
the
rigorous
quality
assurance/
quality
control
procedures
established
by
the
QAPP.

3­
41
3.0
­
Data
Collection
Activities
Table
3­
5
Metal
Constituents
Measured
Under
the
MP&
M
Sampling
Program
(
EPA
Method
1620)

Metal
Constituents
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
BORON
CADMIUM
CALCIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MAGNESIUM
MANGANESE
MERCURY
MOLYBDENUM
NICKEL
SELENIUM
SILVER
SODIUM
THALLIUM
TIN
TITANIUM
VANADIUM
YTTRIUM
ZINC
Additional
Metal
Constituentsa
Not
Subject
to
Rigorous
QA/
QC
Procedures
Per
Method
1620
BISMUTH
CERIUM
DYSPROSIUM
ERBIUM
EUROPIUM
GADOLINIUM
GALLIUM
GERMANIUM
GOLD
HAFNIUM
HOLMIUM
INDIUM
IODINE
IRIDIUM
LANTHANUM
LITHIUM
LUTETIUM
NEODYMIUM
NIOBIUM
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SILICON
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THORIUM
THULIUM
TUNGSTEN
URANIUM
YTTERBIUM
ZIRCONIUM
Source:
EPA
Method
1620.
a
Analyses
for
these
metals
were
used
primarily
for
screening
purposes
3­
42
3.0
­
Data
Collection
Activities
Table
3­
6
Organic
Constituents
Measured
Under
the
MP&
M
Sampling
Program
(
EPA
Methods
1624
and
1625)

Volatile
Organic
Constituents
(
EPA
Method
1624)

ACRYLONITRILE
BENZENE
BROMODICHLOROMETHANE
BROMOMETHANE
CARBON
DISULFIDE
CHLOROACETONITRILE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CHLOROMETHANE
CIS­
1,3­
DICHLOROPROPENE
CROTONALDEHYDE
DIBROMOCHLOROMETHANE
DIBROMOMETHANE
DIETHYL
ETHER
ETHYL
CYANIDE
ETHYL
METHACRYLATE
ETHYLBENZENE
IODOMETHANE
ISOBUTYL
ALCOHOL
M­
XYLENE
METHYL
METHACRYLATE
METHYLENE
CHLORIDE
O+
P­
XYLENE
TETRACHLOROETHENE
TETRACHLOROMETHANE
TOLUENE
TRANS­
1,2­
DICHLOROETHENE
TRANS­
1,3­
DICHLOROPROPENE
TRANS­
1,4­
DICHLORO­
2­
BUTENE
TRIBROMOMETHANE
TRICHLOROETHENE
TRICHLOROFLUOROMETHANE
VINYL
ACETATE
VINYL
CHLORIDE
1,1­
DICHLOROETHANE
1,1­
DICHLOROETHENE
1,1,1­
TRICHLOROETHANE
1,1,1,2­
TETRACHLOROETHANE
1,1,2­
TRICHLOROETHANE
1,1,2,2­
TETRACHLOROETHANE
1,2­
DIBROMOETHANE
1,2­
DICHLOROETHANE
1,2­
DICHLOROPROPANE
1,2,3­
TRICHLOROPROPANE
1,3­
BUTADIENE,
2­
CHLORO
1,3­
DICHLOROPROPANE
1,4­
DIOXANE
2­
BUTANONE
2­
CHLOROETHYL
VINYL
ETHER
2­
HEXANONE
2­
PROPANONE
2­
PROPEN­
1­
OL
2­
PROPENAL
2­
PROPENENITRILE,
2­
METHYL­
3­
CHLOROPROPENE
4­
METHYL­
2­
PENTANONE
ACROLEIN
3­
43
3.0
­
Data
Collection
Activities
Table
3­
6
(
Continued)

Semivolatile
Organic
Constituents
(
EPA
Method
1625)

ACENAPHTHENE
ACENAPHTHYLENE
ACETOPHENONE
ALPHA­
TERPINEOL
ANILINE
ANILINE,
2,4,5­
TRIMETHYL­
ANTHRACENE
ARAMITE
BENZANTHRONE
BENZENETHIOL
BENZIDINE
BIS(
2­
CHLOROETHOXY)
METHANE
BIS(
2­
CHLOROETHYL)
ETHER
BIS(
2­
CHLOROISOPROPYL)
ETHER
BIS(
2­
ETHYLHEXYL)
PHTHALATE
BUTYL
BENZYL
PHTHALATE
CARBAZOLE
CHRYSENE
CIODRIN
CROTOXYPHOS
DI­
N­
BUTYL
PHTHALATE
DI­
N­
OCTYL
PHTHALATE
DI­
N­
PROPYLNITROSAMINE
DIBENZO(
A,
H)
ANTHRACENE
DIBENZOFURAN
DIBENZOTHIOPHENE
DIETHYL
PHTHALATE
DIMETHYL
PHTHALATE
DIMETHYL
SULFONE
DIPHENYL
ETHER
DIPHENYLAMINE
DIPHENYLDISULFIDE
ETHANE,
PENTACHLOROETHYL
METHANESULFONATE
ETHYLENETHIOUREA
FLUORANTHENE
FLUORENE
HEXACHLOROBENZENE
HEXACHLOROBUTADIENE
HEXACHLOROCYCLOPENTADIENE
HEXACHLOROETHANE
HEXACHLOROPROPENE
HEXANOIC
ACID
INDENO(
1,2,3­
CD)
PYRENE
BENZO(
A)
ANTHRACENE
BENZO(
A)
PYRENE
BENZO(
B)
FLUORANTHENE
BENZO(
GHI)
PERYLENE
BENZO(
K)
FLUORANTHENE
BENZOIC
ACID
BENZONITRILE,
3,5­
DIBROMO­
4­
HYDROXY­
BENZYL
ALCOHOL
BETA­
NAPHTHYLAMINE
BIPHENYL
BIPHENYL,
4­
NITRO
N­
EICOSANE
N­
HEXACOSANE
N­
HEXADECANE
N­
NITROSODI­
N­
BUTYLAMINE
N­
NITROSODIETHYLAMINE
N­
NITROSODIMETHYLAMINE
N­
NITROSODIPHENYLAMINE
N­
NITROSOMETHYLETHYLAMINE
N­
NITROSOMETHYLPHENYLAMINE
N­
NITROSOMORPHOLINE
N­
NITROSOPIPERIDINE
N­
OCTACOSANE
N­
OCTADECANE
N­
TETRACOSANE
N­
TETRADECANE
N­
TRIACONTANE
N,
N­
DIMETHYLFORMAMIDE
NAPHTHALENE
NITROBENZENE
O­
ANISIDINE
O­
CRESOL
O­
TOLUIDINE
O­
TOLUIDINE,
5­
CHLORO­
P­
CHLOROANILINE
P­
CRESOL
P­
CYMENE
P­
DIMETHYLAMINOAZOBENZENE
P­
NITROANILINE
PENTACHLOROBENZENE
PENTACHLOROPHENOL
PENTAMETHYLBENZENE
PERYLENE
PHENACETIN
3­
44
3.0
­
Data
Collection
Activities
Table
3­
6
(
Continued)

Semivolatile
Organic
Constituents
(
EPA
Method
1625)

ISOPHORONE
ISOSAFROLE
LONGIFOLENE
MALACHITE
GREEN
MESTRANOL
METHAPYRILENE
METHYL
METHANESULFONATE
N­
DECANE
N­
DOCOSANE
N­
DODECANE
STYRENE
THIANAPHTHENE
THIOACETAMIDE
THIOXANTHE­
9­
ONE
TOLUENE,
2,4­
DIAMINO­
TRIPHENYLENE
TRIPROPYLENEGLYCOL
METHYL
ETHER
1­
BROMO­
2­
CHLOROBENZENE
1­
BROMO­
3­
CHLOROBENZENE
1­
CHLORO­
3­
NITROBENZENE
1­
METHYLFLUORENE
1­
METHYLPHENANTHRENE
1­
NAPHTHYLAMINE
1­
PHENYLNAPHTHALENE
1,2­
DIBROMO­
3­
CHLOROPROPANE
1,2­
DICHLOROBENZENE
1,2­
DIPHENYLHYDRAZINE
1,2,3­
TRICHLOROBENZENE
1,2,3­
TRIMETHOXYBENZENE
1,2,4­
TRICHLOROBENZENE
1,2,4,5­
TETRACHLOROBENZENE
1,2:
3,4­
DIEPOXYBUTANE
1,3­
DICHLORO­
2­
PROPANOL
1,3­
DICHLOROBENZENE
1,3,5­
TRITHIANE
1,4­
DICHLOROBENZENE
1,4­
DINITROBENZENE
1,4­
NAPHTHOQUINONE
1,5­
NAPHTHALENEDIAMINE
2­(
METHYLTHIO)
BENZOTHIAZOLE
2­
CHLORONAPHTHALENE
2­
CHLOROPHENOL
2­
ISOPROPYLNAPHTHALENE
2­
METHYLBENZOTHIOAZOLE
2­
METHYLNAPHTHALENE
PHENANTHRENE
PHENOL
PHENOL,
2­
METHYL­
4,6­
DINITRO­
PHENOTHIAZINE
PRONAMIDE
PYRENE
PYRIDINE
RESORCINOL
SAFROLE
SQUALENE
2­
NITROANILINE
2­
NITROPHENOL
2­
PHENYLNAPHTHALENE
2­
PICOLINE
2,3­
BENZOFLUORENE
2,3­
DICHLOROANILINE
2,3­
DICHLORONITROBENZENE
2,3,4,6­
TETRACHLOROPHENOL
2,3,6­
TRICHLOROPHENOL
2,4
­
DICHLOROPHENOL
2,4­
DIMETHYLPHENOL
2,4­
DINITROPHENOL
2,4­
DINITROTOLUENE
2,4,5­
TRICHLOROPHENOL
2,4,6­
TRICHLOROPHENOL
2,6­
DI­
TERT­
BUTYL­
P­
BENZOQUINONE
2,6­
DICHLORO­
4­
NITROANILINE
2,6­
DICHLOROPHENOL
2,6­
DINITROTOLUENE
3­
METHYLCHOLANTHRENE
3­
NITROANILINE
3,3'­
DICHLOROBENZIDINE
3,3'­
DIMETHOXYBENZIDINE
3,6­
DIMETHYLPHENANTHRENE
4­
AMINOBIPHENYL
4­
BROMOPHENYL
PHENYL
ETHER
4­
CHLORO­
2­
NITROANILINE
4­
CHLORO­
3­
METHYLPHENOL
4­
CHLOROPHENYL
PHENYL
ETHER
4­
NITROPHENOL
4,4'­
METHYLENEBIS(
2­
CHLOROANILINE)
4,5­
METHYLENE
PHENANTHRENE
5­
NITRO­
O­
TOLUIDINE
7,12­
DIMETHYLBENZ(
A)
ANTHRACENE
N­
NITRODOSI­
N­
PROPYLAMINE
Source:
EPA
Methods
1624
and
1625.

3­
45
3.0
­
Data
Collection
Activities
The
Agency
used
these
metals
analyses
for
screening
purposes
and
did
not
select
the
metals
for
regulation
in
this
rulemaking
(
see
Section
7.0).
EPA
analyzed
additional
parameters,
including
several
water
quality
parameters,
using
analytical
methods
contained
in
EPA s
Methods
for
Chemical
Analysis
of
Water
and
Wastes
(
5).
Table
3­
7
lists
these
parameters,
along
with
the
method
and
technique
used
to
analyze
for
each
parameter.
Method
descriptions
are
included
in
the
MP&
M
QAPP.
The
specific
parameters
measured
in
each
sample
are
listed
in
the
SER
for
each
sampling
episode.

Quality
control
measures
used
in
performing
all
analyses
complied
with
the
guidelines
specified
in
the
analytical
methods
and
in
the
MP&
M
QAPP.
EPA
reviewed
all
analytical
data
to
ensure
that
these
measures
were
followed
and
that
the
resulting
data
were
within
the
QAPP­
specified
acceptance
criteria
for
accuracy
and
precision.

As
discussed
previously,
upon
receipt
and
review
of
the
analytical
data
for
each
site,
EPA
prepared
an
SER
to
document
the
data
collected
during
sampling,
the
analytical
results,
and
the
technical
analyses
of
the
results.
The
SAPs
and
correspondence
with
site
personnel
are
included
as
appendices
to
the
SERs.

Other
Sampling
Data
The
Association
of
American
Railroads
(
AAR),
the
Hampton
Roads
Sanitation
District
(
HRSD),
the
Los
Angeles
County
Sanitation
Districts
(
LACSD),
and
the
Association
Connecting
Electronic
Industries
(
IPC)
proposed
potential
sampling
sites
to
the
Agency,
and
EPA
visited
these
sites
to
identify
candidates
for
sampling.
After
conducting
site
visits,
EPA
selected
six
sites
for
sampling
episodes.

EPA
selected
the
six
sites
to
characterize
end­
of­
pipe
treatment
technologies
in
metal
finishing
and
aircraft
parts
job
shops
and
the
railroad
and
shipbuilding
industrial
sectors.
AAR
sampled
a
railroad
line
maintenance
that
used
dissolved
air
flotation
(
DAF)
to
treat
MP&
M
process
wastewater.
HRSD
sampled
a
ship
manufacturer
that
uses
DAF,
chemical
precipitation,
and
cyanide
destruction
to
treat
process
wastewater.
LACSD
sampled
two
metal
finishing
job
shops
and
one
aircraft
parts
manufacturing
job
shop.
EPA
selected
the
LACSD
sites
to
provide
data
for
cyanide
treatment
and
also
conducted
effluent
variability
sampling
at
one
of
the
metal
finishing
job
shops.
The
IPC
site
is
a
printed
wiring
board
facility
that
uses
chemical
precipitation
with
chelation
breaking,
cyanide
destruction
and
batch
treatment
to
treat
process
wastewater.

EPA
prepared
detailed
SAPs
based
on
the
information
collected
during
the
six
site
visits,
and
AAR,
HRSD
and
LACSD
collected
the
wastewater
samples.
EPA
also
prepared
the
sampling
episode
reports.
In
addition
to
the
wastewater
samples,
sampling
personnel
documented
the
collection
date
and
time,
sample
flow
data,
treatment
unit
design
and
operating
parameters,
and
temperature
and
pH
of
the
sampled
waste
streams.
All
data
collected
during
sampling
episodes
are
documented
in
the
SER
for
each
sampled
site,
which
are
located
in
the
3­
46
3.4
3.0
­
Data
Collection
Activities
Table
3­
7
Additional
Parameters
Measured
Under
the
MP&
M
Sampling
Program
Parameter
EPA
Method
Acidity
305.1
Alkalinity
310.1
Ammonia
as
Nitrogen
350.1
BOD
5­
Day
(
Carbonaceous)
405.1
Chemical
Oxygen
Demand
(
COD)
410.1
410.2
Chloride
325.3
Chromium,
Hexavalent
218.4
Cyanide,
Amenable
335.1
Cyanide,
Total
335.2
Cyanide,
Weak
Acid
Dissociable
(
WAD)
1677
Fluoride
340.2
Nitrogen,
Total
Kjeldahl
351.2
Oil
and
Grease
413.2
Oil
and
Grease
(
as
HEM)
1664
pH
150.1
Phenolics,
Total
Recoverable
420.2
Phosphorus,
Total
365.4
Sulfate
375.4
Sulfide,
Total
376.1,
376.2
Total
Dissolved
Solids
(
TDS)
160.1
Total
Organic
Carbon
(
TOC)
415.1
Total
Petroleum
Hydrocarbons
(
as
SGT­
HEM)
1664
Total
Suspended
Solids
(
TSS)
160.2
Ziram
(
zinc
dimethyldithiocarbamate)
630.1
Source:
EPA
Methods
for
Chemical
Analysis
of
Water
and
Wastes
(
5).

3­
47
3.0
­
Data
Collection
Activities
MP&
M
rulemaking
record
(
see
Sections
5.2
and
15.3).
EPA
combined
these
data
with
data
collected
from
the
MP&
M
sampling
program.
For
a
discussion
of
sample
collection
and
the
sampling
protocols
for
the
IPC
site,
see
the
SER
(
DCN
16684)
in
Section
15.3.7
of
the
MP&
M
rulemaking
record.

AAR,
HRSD,
and
LACSD
collected,
preserved,
and
transported
all
samples
according
to
EPA
protocols
as
specified
in
EPA s
Sampling
and
Analysis
Procedures
for
Screening
of
Industrial
Effluents
for
Priority
Pollutants
(
Section
4.2,
DCN
17334)
and
the
MP&
M
QAPP.
Procedures
for
shipping
and
analysis
of
the
samples
were
similar
to
those
discussed
in
Section
3.3
with
the
exception
that
some
samples
were
shipped
directly
to
internal
sanitation
district
laboratories
for
analysis.
Pollutant
parameters
and
analytical
methods
were
agreed
upon
by
EPA,
AAR,
HRSD,
and
LACSD
and
were
treated
as
equivalent
to
those
in
the
EPA
MP&
M
sampling
program.

Other
Industry­
Supplied
Data
EPA
evaluated
other
industry
data
in
developing
the
MP&
M
effluent
guidelines.
The
data
sources
reviewed
included:

 
Public
comments
to
the
May
1995
Proposal,
January
2001
proposal,
and
June
2002
NODA;

 
The
Metal
Finishing
F006
Benchmark
Study
(
6);

 
Data
supporting
the
Final
Rule
for
the
F006
Accumulation
Time
Extension
(
65
FR
12377,
March
8,
2000);

 
Data
provided
by
the
Aluminum
Anodizing
Council
(
AAC),
the
American
Wire
Producers
Association
(
AWPA),
and
the
Aerospace
Association;
and
 
Surveys
provided
by
the
North
Carolina
Pretreatment
Consortium.

EPA
also
reviewed
data
from
stormwater
pollution
prevention
plans
provided
by
several
shipbuilding
sites,
dry
dock
data
from
a
shipbuilding
site,
and
data
from
periodic
compliance
monitoring
reports/
discharge
monitoring
reports
for
19
sites
that
were
part
of
the
Agency s
wastewater
sampling
program.

The
Agency
included
data
submitted
with
comments
on
the
1995
MP&
M
Proposed
Rule,
the
2001
MP&
M
Proposed
Rule,
or
the
2002
MP&
M
NODA
in
the
establishment
of
effluent
limitations
and
standards
if
they
met
the
following
criteria:

 
Measurements
of
daily
effluent
concentration
were
provided;

3­
48
3.5
3.0
­
Data
Collection
Activities
 
Data
represented
effluent
from
a
treatment
system
equivalent
to
EPA s
BAT
options;

 
Samples
represented
fully
treated
effluent
(
as
defined
by
Options
2,
6,
or
10
as
appropriate);
and
 
Treated
pollutants
were
identified
and/
or
unit
operations
contributing
pollutants
were
described.

In
addition,
the
North
Carolina
Pretreatment
Consortium
conducted
a
survey
of
POTWs
in
that
state.
EPA
evaluated
the
results
of
these
surveys
and
used
the
results
as
appropriate
to
verify
and
supplement
information
from
the
previous
MP&
M
POTW
survey
on
loadings,
number
of
facilities
performing
proposed
MP&
M
operations
served,
and
administrative
costs.
The
results
of
EPA s
analysis
of
this
data
is
in
the
Comment
Response
Document,
Issue
Codes
4
and
20G.
The
AMSA
and
North
Carolina
Pretreatment
Consortium
surveys
can
be
found
in
Section
17.6
of
the
rulemaking
record.

Other
Data
Sources
In
developing
the
MP&
M
effluent
guidelines,
EPA
evaluated
the
following
existing
data
sources:

1.
EPA
Engineering
and
Analysis
Division
(
EAD)
databases
from
development
of
effluent
guidelines
for
miscellaneous
metals
industries;

2.
The
Fate
of
Priority
Pollutants
in
Publicly
Owned
Treatment
Works
(
50
POTW
Study)
database;

3.
The
Office
of
Research
and
Development
(
ORD)
National
Risk
Management
and
Research
Laboratory
(
NRMRL)
treatability
database;

4.
The
Domestic
Sewage
Study;

5.
The
Toxics
Release
Inventory
(
TRI)
database;
and
6.
Discharge
Monitoring
Reports
(
DMR)
from
EPA s
Permit
Compliance
System
(
PCS).

These
data
sources
and
their
uses
for
the
development
of
the
MP&
M
effluent
guidelines
are
discussed
below.

3­
49
3.6
3.0
­
Data
Collection
Activities
3.6.1
EPA/
EAD
Databases
As
discussed
in
Section
2.0,
EPA
had
earlier
promulgated
effluent
guidelines
for
13
metals
industries.
In
developing
these
past
effluent
guidelines,
EPA
collected
wastewater
samples
to
characterize
the
unit
operations
and
treatment
systems
at
sites
in
these
industries.
Facilities
performing
proposed
MP&
M
operations
operate
many
of
the
same
or
similar
sampled
unit
operations
and
treatment
systems;
therefore,
EPA
evaluated
these
data
for
transfer
to
the
MP&
M
effluent
guidelines
development
effort.

For
the
pollutant
loading
and
wastewater
characterization
efforts,
EPA
reviewed
the
data
collected
for
unit
operations
performed
at
both
facilities
performing
proposed
MP&
M
operations
and
at
sites
in
the
other
metals
industries.
EPA
reviewed
the
Technical
Development
Documents
(
TDDs),
sampling
episode
reports,
and
supporting
rulemaking
record
materials
for
the
other
metals
industries
to
identify
available
data.
EPA
used
these
data
for
the
preliminary
assessment
of
the
industry,
but
did
not
use
these
data
to
estimate
pollutant
loadings
because
EPA
obtained
sufficient
data
from
the
MP&
M
sampling
program
to
characterize
the
proposed
MP&
M
operations.

For
the
MP&
M
technology
effectiveness
assessment
effort,
EPA
reviewed
sampling
data
collected
to
characterize
treatment
systems
for
the
development
of
effluent
guidelines
for
miscellaneous
metals
industries.
For
several
previous
effluent
guidelines,
EPA
used
treatment
data
from
metals
industries
to
develop
the
Combined
Metals
Database
(
CMDB),
which
served
as
the
basis
for
developing
limits
for
these
industries.
EPA
also
developed
a
separate
database
used
as
the
basis
for
limits
for
the
Metal
Finishing
category.
EPA
used
the
CMDB
and
Metal
Finishing
data
as
a
guide
in
identifying
well­
designed
and
well­
operated
treatment
systems.
EPA
did
not
use
these
data
in
developing
the
MP&
M
technology
effectiveness
concentrations,
since
the
Agency
collected
sufficient
data
from
facilities
performing
proposed
MP&
M
operations
to
develop
technology
effectiveness
concentrations.

3.6.2
Fate
of
Priority
Pollutants
in
Publicly
Owned
Treatment
Works
Database
In
September
1982,
EPA
published
the
Fate
of
Priority
Pollutants
in
Publicly
Owned
Treatment
Works
(
7),
referred
to
as
the
50­
POTW
Study.
The
purpose
of
this
study
was
to
generate,
compile,
and
report
data
on
the
occurrence
and
fate
of
the
129
priority
pollutants
in
50
POTWs.
The
report
presents
all
of
the
data
collected,
the
results
of
preliminary
evaluations
of
these
data,
and
the
results
of
calculations
to
determine
the
following:

 
The
quantity
of
priority
pollutants
in
the
influent
to
POTWs;

 
The
quantity
of
priority
pollutants
discharged
from
the
POTWs;

 
The
quantity
of
priority
pollutants
in
the
effluent
from
intermediate
process
streams;
and
3­
50
3.0
­
Data
Collection
Activities
 
The
quantity
of
priority
pollutants
in
the
POTW
sludge
streams.

EPA
used
the
data
from
this
study
to
assess
removal
by
POTWs
of
pollutants
of
concern
(
see
Section
7).
To
provide
consistency
for
data
analysis
and
establishment
of
removal
efficiencies,
EPA
reviewed
the
50­
POTW
Study
and
standardized
the
reported
minimum
levels
of
quantitation
(
MLs)
for
use
in
the
MP&
M
final
rule.
EPA s
review
of
the
50­
POTW
Study
is
described
in
more
detail
in
the
development
document
for
the
MP&
M
proposed
regulation
located
in
Section
7.2
of
the
rulemaking
record,
DCN
16377,
and
in
memoranda
located
in
Section
6.4
of
the
rulemaking
record.

3.6.3
National
Risk
Management
Research
Laboratory
(
NRMRL)
Treatability
Database
EPA s
ORD
developed
the
NRMRL
(
formerly
RREL)
treatability
database
to
provide
data
on
the
removal
and
destruction
of
chemicals
in
various
types
of
media,
including
water,
soil,
debris,
sludge,
and
sediment.
This
database
contains
treatability
data
from
POTWs
as
well
as
industrial
facilities
for
various
pollutants.
The
database
includes
physical
and
chemical
data
for
each
pollutant,
the
types
of
treatment
used
for
specific
pollutants,
the
types
of
wastewater
treated,
the
size
of
the
POTW
or
industrial
plant,
and
the
treatment
concentrations
achieved.
EPA
used
the
NRMRL
database
to
estimate
pollutant
reductions
achieved
by
POTWs
for
MP&
M
pollutants
of
concern
that
were
not
found
in
the
50­
POTW
database.
The
Agency
used
these
percent
removal
estimates
in
calculating
the
pollutant
loads
removed
by
indirect
discharging
facilities
performing
proposed
MP&
M
operations.
Because
the
50­
POTW
database
contained
sufficient
data,
EPA
did
not
use
these
percent
removal
estimates
in
the
pass­
through
analysis.
EPA
used
only
treatment
technologies
representative
of
typical
POTW
secondary
treatment
operations
(
i.
e.,
activated
sludge,
activated
sludge
with
filtration,
aerated
lagoons).
The
Agency
further
edited
these
files
to
include
information
pertaining
only
to
domestic
or
industrial
wastewater.
EPA
used
pilot­
scale
and
full­
scale
data,
and
eliminated
bench­
scale
data
and
data
from
less
reliable
references.

3.6.4
The
Domestic
Sewage
Study
In
February
1986,
EPA
issued
the
Report
to
Congress
on
the
Discharge
of
Hazardous
Wastes
to
Publicly
Owned
Treatment
Works
(
8),
referred
to
as
the
Domestic
Sewage
Study
(
DSS).
This
report,
which
was
based
in
part
on
the
50­
POTW
Study,
revealed
a
significant
number
of
sites
discharging
pollutants
to
POTWs.
These
pollutants
are
a
threat
to
the
treatment
capability
of
the
POTW.
These
pollutants
were
not
regulated
by
national
effluent
regulations.
Some
of
the
major
sites
identified
were
in
the
metals
industries,
particularly
one
called
equipment
manufacturing
and
assembly.
This
industry
included
sites
that
manufacture
such
products
as
office
machines,
household
appliances,
scientific
equipment,
and
industrial
machine
tools
and
equipment.
The
DSS
estimated
that
this
category
discharges
7,715
metric
tons
per
year
of
priority
hazardous
organic
pollutants,
which
are
presently
unregulated.
Data
on
priority
hazardous
metals
discharges
were
unavailable
for
this
category.
Further
review
of
the
DSS
revealed
miscellaneous
categories
that
were
related
to
metals
industries,
namely
the
motor
3­
51
3.0
­
Data
Collection
Activities
vehicle
category,
which
includes
servicing
of
new
and
used
cars
and
engine
and
parts
rebuilding,
and
the
transportation
services
category,
which
includes
railroad
operations,
truck
service
and
repair,
and
aircraft
servicing
and
repair.
EPA
used
the
information
in
the
DSS
in
developing
the
1989
Preliminary
Data
Summary
(
PDS)
for
the
MP&
M
rulemaking.

3.6.5
Toxics
Release
Inventory
(
TRI)
Database
The
TRI
database
contains
specific
toxic
chemical
release
and
transfer
information
from
manufacturing
facilities
throughout
the
United
States.
This
database
was
established
under
the
Emergency
Planning
and
Community
Right­
to­
Know
Act
of
1986
(
EPCRA),
which
Congress
passed
to
promote
planning
for
chemical
emergencies
and
to
provide
information
to
the
public
about
the
presence
and
release
of
toxic
and
hazardous
chemicals.
Each
year,
manufacturing
facilities
meeting
certain
activity
thresholds
must
report
the
estimated
releases
and
transfers
of
listed
toxic
chemicals
to
EPA
and
to
the
state
or
tribal
entity
in
whose
jurisdiction
the
facility
is
located.
The
TRI
list
includes
more
than
600
chemicals
and
30
chemical
categories.

EPA
considered
using
the
TRI
database
in
developing
the
MP&
M
effluent
guidelines.
However,
EPA
did
not
use
TRI
data
on
wastewater
discharges
from
facilities
performing
proposed
MP&
M
operations
because
sufficient
data
were
not
available
for
effluent
guidelines
development.
Also,
many
of
the
reported
discharges
are
estimates,
not
based
on
measurement.
For
example,
in
developing
the
MP&
M
effluent
guidelines,
EPA
uses
wastewater
influent
concentrations
to
characterize
a
facility s
wastewater
and
to
calculate
treatment
efficiency
(
i.
e.,
percent
removal
across
the
treatment
system).
The
TRI
database
does
not
provide
concentrations
for
the
influent
to
a
facility s
treatment
system.
EPA
also
did
not
use
the
data
on
wastewater
discharge
because
many
facilities
performing
proposed
MP&
M
operations
do
not
meet
the
reporting
thresholds
for
the
TRI
database.

3.6.6
Discharge
Monitoring
Reports
from
EPA s
Permit
Compliance
System
The
PCS
provides
information
on
companies
which
have
been
issued
permits
to
discharge
wastewater
into
surface
water.
Users
can
review
information
on
when
a
permit
was
issued
and
expires,
how
much
the
company
is
permitted
to
discharge,
and
the
actual
monitoring
data
showing
what
the
company
has
discharged.
Respondents
to
MP&
M
surveys
and
commentors
on
the
May
1995
proposal,
January
2001
proposal,
and
June
2002
NODA
supplied
facility
specific
DMR
data.
In
addition,
EPA
retrieved
facility
limits
and
process
wastewater
monitoring
data
from
facilities
performing
proposed
MP&
M
operations
for
selected
pollutant
parameters
(
e.
g.,
metals,
oil
and
grease).
EPA
used
DMR
data
to
estimate
industry
baseline
pollutant
loadings.
Section
12.3
discusses
the
estimation
of
baseline
pollutant
loadings
using
PCS
data.

3­
52
3.0
­
Data
Collection
Activities
3.7
References
1.
U.
S.
Environmental
Protection
Agency.
Sampling
and
Analysis
Procedures
for
Screening
of
Industrial
Effluents
for
Priority
Pollutants
,
April
1977.

2.
U.
S.
Environmental
Protection
Agency.
Method
1620
Draft
­
Metals
by
Inductively
Coupled
Plasma
Atomic
Emission
Spectroscopy
and
Atomic
Absorption
Spectroscopy
,
September
1989.

3.
U.
S.
Environmental
Protection
Agency.
Method
1624
Revision
C
­
Volatile
Organic
Compounds
by
Isotope
Dilution
GCMS
,
June
1989.

4.
U.
S.
Environmental
Protection
Agency.
Method
1625
Revision
C
­
Semivolatile
Organic
Compounds
by
Isotope
Dilution
GCMS
,
June
1989.

5.
U.
S.
Environmental
Protection
Agency.
Methods
for
Chemical
Analysis
of
Water
and
Wastes
.
EPA­
600/
4­
79­
020,
Washington,
DC,
March
1979.

6.
U.
S.
Environmental
Protection
Agency.
Metal
Finishing
F006
Benchmark
Study
.
Washington,
DC,
September
1998.

7.
U.
S.
Environmental
Protection
Agency.
Fate
of
Priority
Pollutants
in
Publicly
Owned
Treatment
Works
.
EPA
440/
1­
82/
303,
Washington,
DC,
September
1982.

8.
U.
S.
Environmental
Protection
Agency.
Report
to
Congress
on
the
Discharge
of
Hazardous
Wastes
to
Publicly
Owned
Treatment
Works
.
EPA
530­
SW­
86­
004,
Washington,
DC,
February
1986.

9.
U.
S.
Environmental
Protection
Agency.
Development
Document
for
Final
Effluent
Limitations
Guidelines
and
Standards
for
the
Iron
and
Steel
Manufacturing
Point
Source
Category
(
EPA­
821­
R­
02­
004).

3­
53
4.0
­
Industry
Description
4.0
INDUSTRY
DESCRIPTION
As
discussed
in
Section
1.0,
EPA
has
promulgated
effluent
limitations
for
the
MP&
M
Point
Source
Category
that
regulate
directly
discharged
process
wastewaters
from
oily
operations
at
facilities
engaged
in
manufacturing,
rebuilding,
or
maintenance
of
metal
parts,
products,
or
machines
for
use
in
one
or
more
of
the
following
16
industrial
sectors:

 
Aerospace;

 
Aircraft;

 
Bus
and
Truck;

 
Electronic
Equipment;

 
Hardware;

 
Household
Equipment;

 
Instruments;

 
Mobile
Industrial
Equipment;

 
Motor
Vehicle;

 
Office
Machine;

 
Ordnance;

 
Precious
Metals
and
Jewelry;

 
Railroad;

 
Ships
and
Boats;

 
Stationary
Industrial
Equipment;
and
 
Miscellaneous
Metal
Products.

This
section
describes
these
facilities.
For
the
final
rule,
EPA
evaluated
facilities
in
the
16
MP&
M
industrial
sectors
above
and
Job
Shop,
Printed
Wiring
Board,
and
Steel
Forming
and
Finishing
industrial
sectors
(
i.
e.,
Iron
&
Steel
Wire
Drawers
and
Steel
Electroplaters).
For
the
purposes
of
this
section,
EPA
is
identifying
all
facilities
evaluated
for
the
final
rule
as
 
MP&
M
facilities. 
Section
4.1
presents
an
overview
of
MP&
M
facilities;
Section
4.2
provides
a
general
discussion
of
unit
operations
performed,
types
of
metal
processed,
and
volumes
of
wastewater
discharged
at
MP&
M
facilities;
Section
4.3
discusses
trends
at
MP&
M
facilities;
and
Section
4.4
lists
the
references
used
in
this
section.

4.1
Overview
of
MP&
M
facilities
This
subsection
discusses
the
number
and
size
of
MP&
M
facilities
evaluated
for
regulation,
the
geographic
distribution
of
these
facilities,
the
number
of
wastewater­
discharging
MP&
M
facilities,
and
the
number
of
MP&
M
facilities
that
do
not
discharge
wastewater.

4­
1
4.0
­
Industry
Description
4.1.1
Number
and
Size
of
MP&
M
Facilities
Based
on
information
in
the
MP&
M
survey
database,
there
are
an
estimated
57,000
MP&
M
facilities
in
the
United
States.
1
Results
of
the
detailed
surveys
indicate
there
are
an
estimated
44,000
MP&
M
facilities
that
discharge
process
wastewater
(
i.
e.,
wastewater­
discharging
MP&
M
facilities).
The
remaining
13,000
facilities
fall
into
one
of
three
categories:
zero
dischargers,
non­
water­
users,
or
contract
haulers.
A
zero
discharger
is
a
facility
that
does
not
discharge
process
wastewater
to
a
treatment
system,
a
non­
water­
user
is
a
facility
that
does
not
use
process
water
in
their
unit
operations,
and
a
contract
hauler
is
a
facility
that
has
all
of
their
process
wastewater
contract
hauled.
For
the
purposes
of
the
evaluating
options
for
the
final
rule,
EPA
considers
MP&
M
facilities
that
discharge
wastewater
exclusively
to
privately
owned
treatment
works
to
be
zero
dischargers
that
contract
haul
their
wastewater
to
centralized
wastewater
treatment
facilities.

Wastewater­
discharging
MP&
M
facilities
range
in
size
from
facilities
with
less
than
10
employees
to
facilities
with
thousands
of
employees.
As
shown
in
Figure
4­
1,
91
percent
of
the
wastewater­
discharging
MP&
M
facilities
have
500
or
fewer
employees.
These
facilities
discharge
55
percent
(
i.
e.,
43
billion
gallons
per
year)
of
the
total
annual
wastewater
discharge
for
the
MP&
M
industry.
The
9
percent
of
the
wastewater­
discharging
MP&
M
facilities
that
have
more
than
500
employees
discharge
35
billion
gallons
of
wastewater
annually,
or
45
percent
of
the
total
annual
wastewater
discharge
for
the
MP&
M
category.

1More
information
on
how
the
MP&
M
survey
database
was
used
to
generate
national
estimates
is
in
the
MP&
M
rulemaking
record
(
see
Section
10.0,
DCN
16118
and
Section
19.5,
DCNs
36086
and
36087).

4­
2
4.0
­
Industry
Description
60
47%

1%
17%

7%
9%
8%
18%
39%

8%
9%

2%
22%

<
1%
13%

<
1%
1%
Percentage
of
MP&
M
Wastewater­
Discharging
Sites
Percentage
of
Total
Annual
MP&
M
Discharge
Flow
50
40
Percentage
30
20
10
0
<=
10
11­
50
51­
100
101­
500
501­
1,000
1,001­
5,000
5,001­
10,000
>
10,000
Number
of
Employees
Source:
MP&
M
Survey
Database.
Note:
There
are
44,000
wastewater­
discharging
MP&
M
facilities.
Total
MP&
M
wastewater
flow
is
78.2
billion
gallons
per
year.

Figure
4­
1.
Percentage
of
Wastewater­
Discharging
MP&
M
facilities
and
Percentage
of
Annual
Wastewater
Discharge
by
Number
of
Employees
4.1.2
Geographic
Distribution
Wastewater­
discharging
MP&
M
facilities
are
located
throughout
the
United
States.
They
are
mostly
concentrated
in
industrialized
areas,
with
the
highest
concentration
of
facilities
in
California,
Pennsylvania,
and
Illinois.
The
following
map
shows
the
estimated
number
of
wastewater­
discharging
MP&
M
facilities
located
in
each
EPA
region.

4­
3
4.0
­
Industry
Description
4­
4
Figure
4­
2.
ated
Number
of
Wastewater­
Discharging
MP&
M
facilities
by
EPA
Region
4.1.3Wastewater­
Discharging
Facilities
EPA
evaluated
MP&
M
facilities
in
20
industrial
sectors
for
the
final
rule.
Table
4­
1
summarizes
the
number
of
wastewater­
discharging
MP&
M
facilities
by
industrial
sector.
Because
some
MP&
M
facilities
perform
operations
or
make
products
used
in
more
than
one
sector,
the
sum
of
wastewater­
discharging
MP&
M
facilities
by
sector
exceeds
the
total
number
of
wastewater­
discharging
MP&
M
facilities
identified
in
the
surveys.
As
shown
in
Table
4­
1,
the
ordnance
sector
has
the
smallest
number
of
wastewater­
discharging
facilities
(
405)
and
the
job
shop
sector
has
the
largest
number
of
wastewater­
discharging
facilities
(
14,589).
Estim
4.0
­
Industry
Description
Table
4­
1
Wastewater­
Discharging
MP&
M
facilities
by
Sector
Sector
Estimated
Number
of
MP&
M
Facilities
That
Discharge
Process
Wastewatera
Aerospace
712
Aircraft
1,598
Bus
and
Truck
3,522
Electronic
Equipment
2,644
Hardware
6,223
Household
Equipment
3,137
Instruments
3,902
Iron
and
Steel
Wire
Drawersb
,
c
153
Job
Shop
c
14,589
Miscellaneous
Metal
Products
5,316
Mobile
Industrial
Equipment
1,079
Motor
Vehicle
13,070
Office
Machine
1,092
Ordnance
405
Precious
Metals
and
Jewelry
1,860
Printed
Circuit
Boards
c
1,456
Railroad
5,181
Ships
and
Boats
1,367
Stationary
Industrial
Equipment
1,724
Steel
Electroplatersb
,
c
28
Source:
MP&
M
Survey
Database.
a
Because
some
facilities
perform
unit
operations
in
more
than
one
sector,
the
sum
of
facilities
by
sector
exceeds
the
total
number
of
facilities
that
discharge
wastewater
(
44,000).
b
Technical
surveys
for
these
facilities
did
not
include
sector
information;
therefore,
they
were
listed
separately
for
this
table.
c
These
industrial
sectors
are
not
included
in
the
final
rule.

4­
5
4.0
­
Industry
Description
In
addition
to
description
by
industrial
sector,
MP&
M
operations2
that
were
proposed
for
regulation
can
be
described
by
two
types
of
activities:
manufacturing
and
rebuilding/
maintenance.

 
Manufacturing
is
the
series
of
unit
operations
necessary
to
produce
metal
products,
and
is
generally
performed
in
a
production
environment.

 
Rebuilding/
maintenance
is
the
series
of
unit
operations
necessary
to
disassemble
used
metal
products
into
components,
replace
the
components
or
subassemblies
or
restore
them
to
original
function,
and
reassemble
the
metal
products.
These
operations
are
intended
to
keep
metal
products
in
operating
condition
and
can
be
performed
in
either
a
production
or
a
nonproduction
environment.

Figure
4­
3
presents
the
percentage
of
wastewater­
discharging
MP&
M
facilities
and
percentage
of
the
total
annual
wastewater
discharge
by
activity.
Eighty­
two
percent
of
the
annual
wastewater
discharge
is
discharged
by
facilities
with
only
manufacturing
operations.
These
facilities
represent
35
percent
of
the
total
wastewater­
discharging
MP&
M
facilities.
The
highest
percentage
of
the
MP&
M
facilities
(
i.
e.,
50
percent)
have
only
rebuilding
and
maintenance
operations.

2EPA
evaluated
a
number
of
unit
operations
for
the
May
1995
proposal,
January
2001
proposal,
and
June
2002
Notice
of
Data
Availability
(
NODA)
(
see
Tables
4­
3
and
4­
4).
However,
EPA
selected
a
subset
of
these
unit
operations
for
regulation
in
the
final
rule
(
see
section
1.0).
For
this
section,
the
term
 
proposed
MP&
M
operations 
means
those
operations
evaluated
for
the
two
proposals,
NODA,
and
final
rule.
The
term
 
Final
MP&
M
operations 
means
those
operations
defined
as
 
oily
operations 
(
see
Section
1.0,
40
CFR
438.2(
f),
and
Appendix
B
to
Part
438)
and
regulated
by
the
final
rule.

4­
6
4.0
­
Industry
Description
80
70
60
50
15%

12%
35%
82%

50%

6%
Percentage
of
MP&
M
Wastewater­
Discharging
Sites
Percentage
of
Total
Anuual
MP&
M
Discharge
Flow
Percentage
40
30
20
10
0
Manufacturing
and
Manufacturing
Only
Rebuilding/
Maintenance
Only
Rebuilding/
Maintenance
Activity
Source:
MP&
M
Survey
Database.
Note:
There
are
44,000
wastewater­
discharging
MP&
M
facilities.
Total
MP&
M
wastewater
flow
is
78.2
billion
gallons
per
year.

Figure
4­
3.
Percentage
of
Wastewater­
Discharging
MP&
M
facilities
and
Percentage
of
Total
Annual
Discharge
by
Activity
Wastewater­
discharging
MP&
M
facilities
include
direct
dischargers,
indirect
dischargers,
and
those
that
are
both
direct
and
indirect
dischargers.
A
direct
discharger
is
a
facility
that
discharges
wastewater
to
a
surface
water
(
e.
g.,
river,
lake,
ocean).
An
indirect
discharger
is
a
facility
that
discharges
wastewater
to
a
publicly
owned
treatment
works
(
POTW).
Figure
4­
4
presents
the
percentage
of
wastewater­
discharging
MP&
M
facilities
and
the
percentage
of
the
total
annual
wastewater
discharge
by
discharge
status.
This
figure
shows
that
the
highest
percentage
of
wastewater­
discharging
MP&
M
facilities
are
indirect
dischargers,
and
those
facilities
account
for
85
percent
of
the
total
annual
discharge
from
all
MP&
M
facilities.

4­
7
4.0
­
Industry
Description
100
90
80
70
60
Percentage
50
40
30
20
10
0
Direct
and
Indirect
Direct
Indirect
<
1%
<
1%
6%
15%
94%

85%
Percentage
of
MP&
M
Wastewater­
Discharging
Sites
Percentage
of
Total
Annual
MP&
M
Discharge
Flow
Discharge
Destination
Source:
MP&
M
Survey
Database.
Note:
There
are
44,000
wastewater­
discharging
MP&
M
facilities.
Total
MP&
M
wastewater
flow
is
78.2
billion
gallons
per
year.

Figure
4­
4.
Percentage
of
Wastewater­
Discharging
MP&
M
facilities
and
Percentage
of
Total
Annual
Discharge
by
Discharge
Status
Wastewater
discharge
flow
rates
for
MP&
M
facilities
range
from
less
than
100
gallons
per
year
to
greater
than
100
million
gallons
per
year.
Figure
4­
5
presents
the
percentage
of
wastewater­
discharging
MP&
M
facilities
and
the
percentage
of
the
annual
MP&
M
wastewater
discharge
by
range
of
wastewater
flow
rates.
As
this
figure
shows,
MP&
M
facilities
discharging
more
than
one
million
gallons
per
year
(
approximately
12
percent
of
the
total
facilities)
account
for
approximately
95
percent
of
the
total
annual
wastewater
discharge
for
all
MP&
M
facilities.
In
contrast,
facilities
discharging
less
than
100,000
gallons
per
year
(
approximately
62
percent
of
the
total
facilities)
account
for
less
than
one
percent
of
the
total
annual
wastewater
discharge
for
all
MP&
M
facilities.

4­
8
4.0
­
Industry
Description
50
45
40
35
30
5%

<
1%
30%

<
1%
10%

<
1%
17%

<
1%
25%

5%
9%
18%

3%
47%

<
1%
30%
Percentage
of
MP&
M
Wastewater­
Discharging
Sites
Percentage
of
Total
Annual
MP&
M
Discharge
Flow
Percentage
25
20
15
10
5
0
0­
100
101­
1,000
1,001­
10,000
10,001­
100,001­
1,000,001­
10,000,001­>
100,000,000
100,000
1,000,000
10,000,000
100,000,000
Discharge
Flow
Range
(
GPY)

Source:
MP&
M
Survey
Database.
Note:
There
are
44,000
wastewater­
discharging
MP&
M
facilities.
Total
MP&
M
wastewater
flow
is
78.2
billion
gallons
per
year.

Figure
4­
5.
Percentage
of
Wastewater­
Discharging
MP&
M
facilities
and
Percentage
of
Total
Annual
MP&
M
Discharge
by
Flow
Rate
Range
4.1.4
Non­
Wastewater­
Discharging
Facilities
Based
on
the
results
of
the
detailed
MP&
M
surveys,
an
estimated
13,000
MP&
M
facilities
either
generate
process
water
and
do
not
discharge
wastewater
(
i.
e.,
zero
discharge
or
contract
haulers)
or
do
not
use
process
water
(
dry
facilities).
Information
from
the
MP&
M
detailed
surveys,
site
visits,
and
technical
literature
indicates
these
facilities
achieve
zero
discharge
of
process
wastewater
in
one
of
the
following
ways:

 
Contract
haul
all
process
wastewater
generated
on
site;

 
Discharge
process
wastewater
to
either
on­
site
septic
systems
or
deep­
well
injection
systems;

4­
9
4.0
­
Industry
Description
 
Perform
end­
of­
pipe
treatment
and
reuse
all
process
wastewater
generated
on
site;

 
Perform
either
in­
process
or
end­
of­
pipe
evaporation
to
eliminate
wastewater
discharges;
or
 
Perform
in­
process
recirculation
and
recycling
to
eliminate
wastewater
discharges.

As
discussed
in
Section
3.0,
EPA
mailed
the
1989
detailed
survey
to
a
probability
sample
of
50
screener
respondents
that
reported
using
but
not
discharging
process
water.
Based
on
the
survey
responses,
5
of
these
facilities
contract
hauled
all
wastewater
generated
on
site,
8
actually
discharged
process
wastewater,
18
had
no
process
wastewater
discharges,
and
19
were
not
engaged
in
proposed
MP&
M
operations.
The
Agency
also
mailed
the
1989
detailed
survey
to
an
additional
24
screener
respondents
that
reported
using
but
not
discharging
process
water.
As
discussed
in
Section
3.0,
EPA
selected
these
facilities
because
they
performed
unit
operations
that
were
not
expected
to
be
characterized
sufficiently
by
detailed
surveys
mailed
to
other
facilities.
Of
the
additional
24,
14
actually
discharged
process
wastewater,
2
had
no
process
wastewater
discharges,
and
8
were
not
engaged
in
proposed
MP&
M
operations.
Of
the
74
screener
respondents
that
received
the
1989
detailed
survey,
only
20
reported
no
discharge
of
process
water.

In
addition
to
the
20
facilities
discussed
above
that
do
not
discharge
process
wastewater,
205
of
the
1996
screener
survey
respondents
reported
eliminating
wastewater
discharges
by
in­
process
or
end­
of­
pipe
evaporation,
end­
of­
pipe
treatment
and
reuse,
in­
process
recirculation
and
recycling,
or
other
unspecified
means.
Figure
4­
6
shows
the
percentage
of
the
facilities
using
each
type
of
zero
discharge
method.
Note
that
Figure
4­
6
provides
the
percentage
of
survey
respondents,
not
industry
percentages,
because
this
information
was
available
for
only
a
subset
of
the
industry.
The
methods
used
by
the
225
survey
facilities
to
eliminate
wastewater
discharges
are
discussed
below.

In­
Process
or
End­
Of­
Pipe
Evaporation.
Forty­
one
percent
of
the
screener
survey
respondents
(
i.
e.,
92
respondents)
reported
discharging
wastewater
to
either
evaporators,
on­
site
ponds,
or
lagoons
to
evaporate
process
wastewater.
None
of
these
facilities
reported
recovering
the
process
wastewater.
Facilities
reported
contracting
for
off­
site
disposal
of
sludge
from
the
evaporation
units.

End­
Of­
Pipe
Treatment
and
Reuse.
Eight
percent
of
the
screener
survey
respondents
(
i.
e.,
18
respondents)
reported
eliminating
wastewater
discharges
through
end­
of­
pipe
treatment
and
reuse
of
all
wastewater
generated
on
site.

4­
10
4.0
­
Industry
Description
U
nknow
n
M
ethods
­
O
f­
Other
I
n
­
P
ro
ce
s
s
o
r
E
n
d
I
n
­
P
ro
ce
s
s
12
%

Pipe
Evaporation
16%
41%

End­
O
f­
Pip
e
Recirculation
and
Treatment
and
Reuse
Recy
cling
8%
23%

Note:
There
are
225
survey
facilities
that
have
eliminated
wastewater
discharge.

Figure
4­
6.
Percentage
of
Screener
Survey
Respondents
Using
Each
Zero
Discharge
Method
In­
Process
Recirculation
and
Recycling.
Twenty­
three
percent
of
the
screener
survey
respondents
(
i.
e.,
52
respondents)
reported
eliminating
wastewater
discharges
through
in­
process
recirculation
and
recycling.
Several
facilities
used
a
stagnant
bath
in
their
heat
treating
operations.
Some
facilities
used
stagnant
baths
in
their
surface
finishing
operations
(
e.
g.,
alkaline
cleaning
and
chemical
conversion
coating).
Make­
up
water
is
added
to
the
stagnant
baths
to
account
for
losses
of
bath
water
through
evaporation.

Other.
Sixteen
percent
of
the
screener
survey
respondents
(
i.
e.,
36
respondents)
reported
eliminating
wastewater
discharge
through
a
variety
of
other
methods
including
land
application
and
septic
tank
systems
or
contract
hauling
through
a
centralized
waste
treater
(
CWT)
or
privately
owned
treatment
works
(
PrOTW).

4.2
Proposed
MP&
M
Operations
This
subsection
discusses
the
proposed
MP&
M
operations
and
presents
a
brief
description
of
each
unit
operation.
It
also
discusses
the
metals
processed
in
proposed
MP&
M
operations,
and
presents
an
estimate
of
the
annual
wastewater
discharge
for
each
proposed
MP&
M
operations.

4­
11
4.0
­
Industry
Description
4.2.1
Types
of
Unit
Operations
MP&
M
facilities
perform
several
different
types
of
unit
operations
and
associated
rinses
on
metal
parts,
products,
and
machines.
Section
4.2.2
describes
these
unit
operations.

The
types
of
proposed
MP&
M
operations
include:

 
Metal
shaping;

 
Surface
preparation;

 
Metal
deposition;

 
Organic
material
deposition;

 
Surface
finishing;

 
Assembly;

 
Dry
dock;
and
 
Specialized
printed
wiring
board
operations.

Metal
shaping
is
a
mechanical
operation
that
alters
the
form
of
raw
materials
into
intermediate
and
final
products.
Surface
preparation
includes
chemical
and
mechanical
operations
that
remove
unwanted
materials
from
or
alter
the
chemical
or
physical
properties
of
the
part
surface
prior
to
subsequent
proposed
MP&
M
operations.
Metal
deposition
applies
a
metal
coating
to
the
part
surface
by
chemical
or
physical
means.
Organic
material
deposition
applies
an
organic
material
to
the
part
by
chemical
or
physical
means.
Facilities
may
perform
metal
and
organic
material
deposition
to
protect
the
surface
from
wear
or
corrosion,
modify
the
electrical
properties
of
the
surface,
or
alter
the
appearance
of
the
surface.
Surface
finishing
protects
and
seals
the
surface
of
the
treated
part
from
wear
or
corrosion
by
chemical
means.
Facilities
also
may
use
surface
finishing
to
alter
the
appearance
of
the
part
surface.
Assembly
is
performed
throughout
the
manufacturing,
rebuilding,
or
maintenance
process.
Dry
dock
operations
are
proposed
MP&
M
operations
performed
at
ship
and
boat
facilities
within
dry
docks
or
similar
structures
and
incorporate
many
types
of
proposed
MP&
M
operations.
Printed
wiring
board
unit
operations
are
those
specific
to
the
manufacture
or
rebuilding/
maintenance
of
wiring
boards
(
e.
g.,
carbon
black
deposition,
solder
flux
cleaning,
and
photo
image
developing).
Specialized
printed
wiring
board
operations
do
not
include
those
performed
at
assembly­
only
facilities.
Table
4­
2
lists
examples
of
the
different
types
of
proposed
MP&
M
operations.

4­
12
4.0
­
Industry
Description
Table
4­
2
Types
of
Proposed
MP&
M
operations
Type
of
Unit
Operations
Example
Metal
Shaping
Machining,
Grinding,
Deformation
Surface
Preparation
Alkaline
Cleaning,
Acid
Treatment
Metal
Deposition
Electroplating,
Vapor
Deposition
Organic
Material
Deposition
Painting
Surface
Finishing
Chemical
Conversion
Coating
Assembly
Testing
(
e.
g.,
leak
testing),
Assembly
Dry
Dock
Welding
Specialized
Printed
Wiring
Board
Solder
Leveling,
Photoresist
Applications
At
a
given
MP&
M
facility,
the
specific
unit
operations
and
the
sequence
of
operations
depend
on
many
factors,
including
the
activity
at
the
facility
(
i.
e.,
manufacturing,
rebuilding/
maintenance),
industrial
sector,
and
type
of
product
processed.
As
a
result,
MP&
M
facilities
perform
many
different
combinations
and
sequences
of
unit
operations.
For
example,
MP&
M
facilities
that
repair,
rebuild
or
maintain
products
often
conduct
preliminary
operations
that
may
not
be
performed
at
manufacturing
facilities
(
e.
g.,
disassembly,
cleaning,
or
degreasing
to
remove
dirt
and
oil
accumulated
during
use
of
the
product).
In
general,
however,
MP&
M
products
are
processed
in
the
following
order:

 
The
raw
material
(
e.
g.,
bar
stock,
wire,
rod,
sheet
stock,
plates)
undergoes
some
type
of
metal­
shaping
process,
such
as
impact
or
pressure
deformation,
machining,
or
grinding.
In
these
operations,
the
raw
material
is
shaped
into
intermediate
forms
for
further
processing
or
into
final
forms
for
assembly
and
shipment
to
the
customer.
Facilities
typically
clean
and
degrease
the
parts
between
some
of
the
shaping
operations
to
remove
lubricants,
coolants,
and
metal
fines.
Facilities
also
may
heat
a
part
between
shaping
operations
to
alter
its
physical
characteristics.

 
After
shaping,
the
part
typically
undergoes
some
type
of
surface
preparation,
such
as
alkaline
cleaning,
acid
treatment
(
pickling),
or
barrel
finishing.
The
specific
operation
depends
on
the
subsequent
unit
operations
and
the
final
use
of
the
products.
For
example,
prior
to
electroplating,
parts
typically
go
through
acid
pickling
(
i.
e.,
acid
cleaning)
to
prepare
the
part
surface
for
electroplating.
Before
assembly,
parts
typically
go
through
alkaline
cleaning
or
barrel
finishing.
Parts
go
through
surface
preparation
at
various
stages
of
the
production
process.
Additional
cleaning
and
degreasing
steps
precede
metal
deposition,
organic
material
deposition,
surface
finishing,
and
assembly.

4­
13
4.0
­
Industry
Description
 
Metal
and
organic
material
deposition
typically
follow
shaping
and
surface
preparation,
and
precede
surface
finishing
and
final
assembly.
For
example,
electroplating
usually
follows
alkaline
and
acid
treatment,
while
painting
usually
follows
phosphate
conversion
coating
and
alkaline
treatment.

 
Surface
finishing
operations
typically
are
performed
after
shaping
and
surface
preparation.
Some
surface
finishing
is
performed
after
metal
deposition.
For
example,
chromate
conversion
coating
typically
follows
acid
cleaning,
although
this
operation
is
sometimes
performed
as
a
sealant
operation
after
electroplating
(
e.
g.,
chemical
conversion
coating
of
cadmium
plated
parts).
Surface
finishing
also
is
done
prior
to
applying
organic
coatings.
For
example,
phosphate
conversion
coating
frequently
precedes
painting
to
enhance
the
paint
adhesion.

 
Disassembly
may
be
the
first
step
in
the
rebuilding
process.
Assembly,
on
the
other
hand,
is
done
during
many
steps
of
the
manufacturing
and
rebuilding
process
to
prepare
the
final
product.
Assembly
also
may
involve
some
final
shaping
(
e.
g.,
drilling
and
grinding)
and
surface
preparation
(
e.
g.,
alkaline
cleaning).
Final
assembly
usually
is
the
last
operation
prior
to
shipment
to
the
customer.

Some
MP&
M
facilities
conduct
all
of
these
types
of
unit
operations
in
manufacturing
or
rebuilding
products,
while
others
may
perform
only
some
types.
For
example,
a
facility
that
manufactures
products
used
in
the
hardware
sector
may
start
with
bar
stock
and
manufacture
a
final
hardware
product,
performing
machining,
cleaning,
electroplating,
conversion
coating,
painting,
degreasing,
and
assembly.
Another
hardware
product
manufacturing
facility
may
only
clean
and
paint
the
parts.
A
third
hardware
product
manufacturing
facility
may
only
shape
the
parts,
and
perform
only
machining,
cleaning,
and
degreasing
operations.

4.2.2
Description
of
Proposed
MP&
M
Operations
EPA
described
the
operations
above
as
either
metal­
bearing
operations
or
oily
operations.
This
section
describes
each
of
the
MP&
M
operations
for
which
EPA
considered
new
regulations.
Oily
operations
(
as
defined
in
40
CFR
438.2(
f))
are
listed
in
Table
4­
3.
Metal­
bearing
operations
(
as
defined
in
40
CFR
438.2(
d))
are
listed
in
Table
4­
4.

4­
14
4.0
­
Industry
Description
Table
4­
3
List
of
MP&
M
Oily
Operations
 
Abrasive
Blasting
 
Iron
Phosphate
Conversion
Coating
 
Adhesive
Bonding
 
Machining
 
Alkaline
Cleaning
for
Oil
Removal
 
Painting­
spray
or
Brush
(
Including
Water
Curtains)

 
Alkaline
Treatment
Without
Cyanide
 
Polishing
 
Aqueous
Degreasing
 
Pressure
Deformation
 
Assembly/
Disassembly
 
Solvent
Degreasing
 
Burnishing
 
Steam
Cleaning
 
Calibration
 
Testing
(
e.
g.,
Hydrostatic,
Dye
Penetrant,
Ultrasonic,
Magnetic
 
Corrosion
Preventive
Coating
Flux)

 
Electrical
Discharge
Machining
 
Thermal
Cutting
 
Floor
Cleaning
(
In
Process
Area)
 
Tumbling/
Barrel
Finishing/
Mass
Finishing/
Vibratory
Finishing
 
Grinding
 
Washing
(
Finished
Products)

 
Heat
Treating
 
Welding
 
Impact
Deformation
 
Wet
Air
Pollution
Control
for
Organic
Constituents
Note:
This
list
is
replicated
at
40
CFR
438.2(
f)
with
definitions
at
Appendix
B
to
Part
438.

4­
15
4.0
­
Industry
Description
Table
4­
4
List
of
MP&
M
Metal­
Bearing
Operations
 
Abrasive
Jet
Machining
 
Mechanical
and
Vapor
Plating
 
Acid
Pickling
Neutralization
 
Metallic
Fiber
Cloth
Manufacturing
 
Acid
Treatment
With
Chromium
 
Metal
Spraying
(
including
Water
Curtain)

 
Acid
Treatment
Without
Chromium
 
Painting­
immersion
(
including
Electrophoretic,
"
E­
coat")

 
Alcohol
Cleaning
 
Photo
Imaging
 
Alkaline
Cleaning
Neutralization
 
Photo
Image
Developing
 
Alkaline
Treatment
With
Cyanide
 
Photoresist
Application
 
Anodizing
With
Chromium
 
Photoresist
Strip
 
Anodizing
Without
Chromium
 
Phosphor
Deposition
 
Carbon
Black
Deposition
 
Physical
Vapor
Deposition
 
Catalyst
Acid
Pre­
dip
 
Plasma
Arc
Machining
 
Chemical
Conversion
Coating
Without
Chromium
 
Plastic
Wire
Extrusion
 
Chemical
Milling
(
or
Chemical
Machining)
 
Salt
Bath
Descaling
 
Chromate
Conversion
Coating
(
or
Chromating)
 
Shot
Tower
­
Lead
Shot
Manufacturing
 
Chromium
Drag­
out
Destruction
 
Soldering
 
Cyanide
Drag­
out
Destruction
 
Solder
Flux
Cleaning
 
Cyaniding
Rinse
 
Solder
Fusing
 
Electrochemical
Machining
 
Solder
Masking
 
Electroless
Catalyst
Solution
 
Sputtering
 
Electroless
Plating
 
Stripping
(
paint)

 
Electrolytic
Cleaning
 
Stripping
(
metallic
coating)

 
Electroplating
With
Chromium
 
Thermal
Infusion
 
Electroplating
With
Cyanide
 
Ultrasonic
Machining
 
Electroplating
Without
Chromium
or
Cyanide
 
Vacuum
Impregnation
 
Electropolishing
 
Vacuum
Plating
 
Galvanizing/
Hot
Dip
Coating
 
Water
Shedder
 
Hot
Dip
Coating
 
Wet
Air
Pollution
Control
 
Kerfing
 
Wire
Galvanizing
Flux
 
Laminating
Note:
This
list
is
replicated
at
40
CFR
438.2(
d)
with
definitions
at
Appendix
C
to
Part
438.

4­
16
4.0
­
Industry
Description
EPA
also
evaluated
process
wastewater
from
 
Bilge
Water 
and
 
Dry
Dock/
Stormwater 
for
the
final
rule.
These
two
processes
generate
mainly
oily
or
organic
wastewater
but
are
not
included
in
the
final
definition
of
 
oily
operations 
(
as
defined
in
40
CFR
438.2(
f))
as
these
unit
operations
only
occur
at
facilities
EPA
decided
should
not
be
subject
to
the
final
rule
(
see
40
CFR
438.1(
e)(
5)).
EPA
used
the
following
definitions
for
 
Bilge
Water 
and
 
Dry
Dock/
Stormwater 
for
the
final
rule:

 
Bilge
Water
is
water
that
collects
in
the
inner
hull
of
a
ship.
When
a
ship
is
in
a
dry
dock
or
similar
structure,
the
bilge
water
is
collected
and
then
treated
and
disposed
of.

 
Dry
Dock/
Stormwater
.
Maintenance
operations
performed
on
a
ship/
boat
in
a
dry
dock
that
either
use
process
water
or
are
exposed
to
stormwater.

The
following
descriptions
are
provided
to
aid
the
reader
in
understanding
the
described
processes
and
do
not
supersede
regulatory
definitions
of
unit
operations
in
the
final
MP&
M
rule.
Moreover,
the
definitions
in
this
section
should
not
be
used
to
differentiate
between
the
six
 
core 
metal
finishing
operations
(
i.
e.,
Electroplating,
Electroless
Plating,
Anodizing,
Coating
(
chromating,
phosphating,
and
coloring),
Chemical
Etching
and
Milling,
and
Printed
Circuit
Board
Manufacture)
and
40
 
ancillary 
process
operations
listed
at
40
CFR
433.10(
a).

4.2.2.1
Description
of
MP&
M
Oily
Operations
Abrasive
Blasting
involves
removing
surface
film
from
a
part
by
using
abrasive
directed
at
high
velocity
against
the
part.
Abrasive
blasting
includes
bead,
grit,
shot,
and
sand
blasting,
and
may
be
performed
either
dry
or
with
water.
The
primary
applications
of
wet
abrasive
blasting
include:
removing
burrs
on
precision
parts;
producing
satin
or
matte
finishes;
removing
fine
tool
marks;
and
removing
light
mill
scale,
surface
oxide,
or
welding
scale.
Wet
blasting
can
be
used
to
finish
fragile
items
such
as
electronic
components.
Also,
some
aluminum
parts
are
wet
blasted
to
achieve
a
fine­
grained
matte
finish
for
decorative
purposes.
In
abrasive
blasting,
the
water
and
abrasive
typically
are
reused
until
the
particle
size
diminishes
due
to
impacting
and
fracture.

Adhesive
Bonding
involves
joining
parts
using
an
adhesive
material.
Typically,
an
organic
bonding
compound
is
used
as
the
adhesive.
This
operation
usually
is
dry;
however,
aqueous
solutions
may
be
used
as
bonding
agents
or
to
contain
residual
organic
bonding
materials.

Alkaline
Cleaning
for
Oil
Removal
is
a
general
term
for
the
application
of
an
alkaline
cleaning
agent
to
a
metal
part
to
remove
oil
and
grease
during
the
manufacture,
maintenance,
or
rebuilding
of
a
metal
product.

This
unit
operation
does
not
include
washing
of
the
finished
products
after
routine
use
(
as
defined
in
 
Washing
(
Finished
Products) 
in
this
subsection),
or
applying
an
alkaline
cleaning
4­
17
4.0
­
Industry
Description
agent
to
remove
nonoily
contaminants
such
as
dirt
and
scale
(
as
defined
in
 
Alkaline
Treatment
Without
Cyanide 
in
this
subsection
and
 
Alkaline
Treatment
With
Cyanide 
in
Section
4.2.2.2).
Wastewater
generated
includes
spent
cleaning
solutions
and
rinse
waters.

 
Alkaline
cleaning
is
performed
to
remove
foreign
contaminants
from
parts.
This
operation
usually
is
done
prior
to
finishing
(
e.
g.,
electroplating).

 
Emulsion
cleaning
is
an
alkaline
cleaning
operation
that
uses
either
complex
chemical
enzymes
or
common
organic
solvents
(
e.
g.,
kerosene,
mineral
oil,
glycols,
and
benzene)
dispersed
in
water
with
the
aid
of
an
emulsifying
agent.
The
pH
of
the
solvent
usually
is
between
7
and
9,
and,
depending
on
the
solvent
used,
cleaning
is
performed
at
temperatures
from
room
temperature
to
82
°
C
(
180
°
F).
This
operation
often
is
used
as
a
replacement
for
vapor
degreasing.

Alkaline
Treatment
Without
Cyanide
is
a
general
term
used
to
describe
the
application
of
an
alkaline
solution
not
containing
cyanide
to
a
metal
surface
to
clean
the
metal
surface
or
prepare
the
metal
surface
for
further
surface
finishing.

Aqueous
Degreasing
involves
cleaning
metal
parts
using
aqueous­
based
cleaning
chemicals
primarily
to
remove
residual
oils
and
greases
from
the
part.
Residual
oils
can
be
from
previous
operations
(
e.
g.,
machine
coolants),
oil
from
product
use
in
a
dirty
environment,
or
oil
coatings
used
to
inhibit
corrosion.
Wastewater
generated
by
this
operation
includes
spent
cleaning
solutions
and
rinse
waters.

Assembly/
Disassembly
involves
fitting
together
previously
manufactured
or
rebuilt
parts
or
components
into
a
complete
metal
product
or
machine
or
taking
a
complete
metal
product
or
machine
apart.
Assembly/
disassembly
operations
are
typically
dry;
however,
special
circumstances
can
require
water
for
cooling
or
buoyancy.
Also,
rinsing
may
be
necessary
under
some
conditions.

Burnishing
involves
finish
sizing
or
smooth
finishing
a
part
(
previously
machined
or
ground)
by
displacing,
rather
than
removing,
minute
surface
irregularities
with
smooth
point
or
line­
contact,
fixed
or
rotating
tools.
Lubricants
or
soap
solutions
can
be
used
to
cool
the
tools
used
in
burnishing
operations.
Wastewater
generated
during
burnishing
include
process
solutions
and
rinse
water.

Calibration
is
performed
to
provide
reference
points
for
the
use
of
a
product.
This
unit
operation
typically
is
dry,
although
water
may
be
used
in
some
cases
(
e.
g.,
pumping
water
for
calibration
of
a
pump).
Water
used
in
this
unit
operation
usually
does
not
contain
additives.

Corrosion
Preventive
Coating
involves
applying
removable
oily
or
organic
solutions
to
protect
metal
surfaces
against
corrosive
environments.
Corrosion
preventive
coatings
include,
but
are
not
4­
18
4.0
­
Industry
Description
limited
to:
petrolatum
compounds,
oils,
hard
dry­
film
compounds,
solvent­
cutback
petroleum­
based
compounds,
emulsions,
water­
displacing
polar
compounds,
and
fingerprint
removers
and
neutralizers.
Corrosion
preventive
coating
does
not
include
electroplating
or
chemical
conversion
coating
operations.

Many
corrosion
preventive
materials
also
are
formulated
to
function
as
lubricants
or
as
a
base
for
paint.
Typical
applications
include:
assembled
machinery
or
equipment
in
standby
storage;
finished
parts
in
stock
or
spare
parts
for
replacement;
tools
such
as
drills,
taps,
dies,
and
gauges;
and
mill
products
such
as
sheet,
strip,
rod
and
bar.

Wastewater
generated
during
corrosion
preventive
coating
includes
spent
process
solutions
and
rinses.
Process
solutions
are
discharged
when
they
become
contaminated
with
impurities
or
are
depleted
of
constituents.
Corrosion
preventive
coatings
typically
do
not
require
an
associated
rinse,
but
parts
are
sometimes
rinsed
to
remove
the
coating
before
further
processing.

Electrical
Discharge
Machining
involves
removing
metals
by
a
rapid
spark
discharge
between
different
polarity
electrodes,
one
the
part
and
the
other
the
tool,
separated
by
a
small
gap.
The
gap
may
be
filled
with
air
or
a
dielectric
fluid.
This
operation
is
used
primarily
to
cut
tool
alloys,
hard
nonferrous
alloys,
and
other
hard­
to­
machine
materials.
Most
electrical
discharge
machining
processes
are
operated
dry;
however,
in
some
cases,
the
process
uses
water
and
generates
wastewater
containing
dielectric
fluid.

Floor
Cleaning
(
in
Process
Area)
removes
dirt,
debris,
and
process
solution
spills
from
process
area
floors.
Floors
can
be
cleaned
using
wet
or
dry
methods,
such
as
vacuuming,
mopping,
dry
sweeping,
and
hose
rinsing.
Nonprocess
area
floor
cleaning
in
offices
and
other
similar
nonprocess
areas
is
not
included
in
this
unit
operation.

Grinding
involves
removing
stock
from
a
part
by
using
abrasive
grains
held
by
a
rigid
or
semirigid
binder.
Grinding
shapes
or
deburrs
the
part.
The
grinding
tool
usually
is
a
disk
(
the
basic
shape
of
grinding
wheels),
but
can
also
be
a
cylinder,
ring,
cup,
stick,
strip,
or
belt.
The
most
commonly
used
abrasives
are
aluminum
oxide,
silicon
carbide,
and
diamond.
The
process
may
use
a
grinding
fluid
to
cool
the
part
and
remove
debris
or
metal
fines.

Wastewater
generated
during
grinding
includes
spent
coolants
and
rinses.
Metal­
working
fluids
become
spent
for
a
number
of
reasons,
including
increased
biological
activity
(
i.
e.,
the
fluids
become
rancid)
or
decomposition
of
the
coolant
additives.
Rinse
waters
typically
are
assimilated
into
the
working
fluid
or
treated
on
site.

Heat
Treating
involves
modifying
the
physical
properties
of
a
part
by
applying
controlled
heating
and
cooling
cycles.
This
operation
includes
tempering,
carburizing,
cyaniding,
nitriding,
annealing,
aging,
normalizing,
austenitizing,
austempering,
siliconizing,
martempering,
and
malleablizing.
Parts
are
heated
in
furnaces
or
molten
salt
baths,
and
then
may
be
cooled
by
quenching
in
aqueous
solutions
(
e.
g.,
brine
solutions),
neat
oils
(
pure
oils
with
little
or
no
impurities),
or
oil/
water
emulsions.
Heat
treating
typically
is
a
dry
operation,
but
is
considered
a
4­
19
4.0
­
Industry
Description
wet
operation
if
aqueous
quenching
solutions
are
used.
Wastewater
includes
spent
quench
water
and
rinse
water.

Impact
Deformation
involves
applying
impact
force
to
a
part
to
permanently
deform
or
shape
it.
Impact
deformation
may
include
mechanical
processes
such
as
hammer
forging,
shot
peening,
peening,
coining,
high­
energy­
rate
forming,
heading,
or
stamping.

Natural
and
synthetic
oils,
light
greases,
and
pigmented
lubricants
are
used
in
impact
deformation
operations.
Pigmented
lubricants
include
whiting,
lithapone,
mica,
zinc
oxide,
molybdenum
disulfide,
bentonite,
flour,
graphite,
white
lead,
and
soap­
like
materials.

These
operations
typically
are
dry,
but
wastewater
can
be
generated
from
lubricant
discharge
and
from
rinsing
operations
associated
with
the
operation.

Iron
Phosphate
Conversion
Coating
is
the
process
of
applying
a
protective
coating
on
the
surface
of
a
metal
using
a
bath
consisting
of
a
phosphoric
acid
solution
containing
no
metals
(
e.
g.,
manganese,
nickel,
or
zinc)
or
a
phosphate
salt
solution
(
i.
e.,
sodium
or
potassium
salts
of
phosphoric
acid
solutions)
containing
no
metals
(
e.
g.,
manganese,
nickel,
or
zinc)
other
than
sodium
or
potassium.
Any
metal
concentrations
in
the
bath
are
from
the
substrate.

Machining
involves
removing
stock
from
a
part
(
as
chips)
by
forcing
a
cutting
tool
against
the
part.
This
includes
machining
processes
such
as
turning,
milling,
drilling,
boring,
tapping,
planing,
broaching,
sawing,
shaving,
shearing,
threading,
reaming,
shaping,
slotting,
hobbing,
and
chamfering.
Machining
processes
use
various
types
of
metal­
working
fluids,
the
choice
of
which
depends
on
the
type
of
machining
being
performed
and
the
preference
of
the
machine
shop.
The
fluids
can
be
categorized
into
four
groups:
straight
oil
(
neat
oils),
synthetic,
semisynthetic,
and
water­
soluble
oil.

Machining
operations
generate
wastewater
from
working
fluid
or
rinse
water
discharge.
Metal­
working
fluids
periodically
are
discarded
because
of
reduced
performance
or
development
of
a
rancid
odor.
After
machining,
parts
are
sometimes
rinsed
to
remove
coolant
and
metal
chips.
The
coolant
reservoir
is
sometimes
rinsed,
and
the
rinse
water
is
added
to
the
working
fluid.

Painting
­
Spray
or
Brush
(
Including
Water
Curtains)
involves
applying
an
organic
coating
to
a
part.
Coatings
such
as
paint,
varnish,
lacquer,
shellac,
and
plastics
are
applied
by
spraying,
brushing,
roll
coating,
lithographing,
powder
coating,
and
wiping.

Water
is
used
in
painting
operations
as
a
solvent
(
water­
borne
formulations)
for
rinsing,
for
cleanup,
and
for
water­
wash
(
or
curtain)
type
spray
booths.
Paint
spray
booths
typically
use
most
of
the
water
in
this
unit
operation.
Spray
booths
capture
overspray
(
i.
e.,
paint
that
misses
the
product
during
application),
and
control
the
introduction
of
pollutants
into
the
workplace
and
environment.

4­
20
4.0
­
Industry
Description
Polishing
involves
removing
stock
from
a
part
using
loose
or
loosely
held
abrasive
grains
carried
to
the
part
by
a
flexible
support.
Usually,
the
objective
is
to
achieve
a
desired
surface
finish
or
appearance
rather
than
to
remove
a
specified
amount
of
stock.
Buffing
is
included
in
this
unit
operation,
and
usually
is
performed
using
a
revolving
cloth
or
sisal
buffing
wheel,
which
is
coated
with
a
suitable
compound.
Liquid
buffing
compounds
are
used
extensively
for
large­
volume
production
on
semiautomated
or
automated
buffing
equipment.
Polishing
operations
typically
are
dry,
although
liquid
compounds
and
associated
rinses
are
used
in
some
polishing
processes.

Pressure
Deformation
involves
applying
force
(
other
than
impact
force)
to
permanently
deform
or
shape
a
part.
Pressure
deformation
may
include
rolling,
drawing,
bending,
embossing,
sizing,
extruding,
squeezing,
spinning,
necking,
forming,
crimping
or
flaring.

These
operations
use
natural
and
synthetic
oils,
light
greases,
and
pigmented
lubricants.
Pigmented
lubricants
include
whiting,
lithapone,
mica,
zinc
oxide,
molybdenum
disulfide,
bentonite,
flour,
graphite,
white
lead,
and
soap­
like
materials.

Pressure
deformation
typically
is
dry,
but
wastewater
is
sometimes
generated
from
the
discharge
of
lubricants
or
from
rinsing
associated
with
the
process.

Solvent
Degreasing
removes
oils
and
grease
from
the
surface
of
a
part
using
organic
solvents,
including
aliphatic
petroleum
(
e.
g.,
kerosene,
naphtha),
aromatics
(
e.
g.,
benzene,
toluene),
oxygenated
hydrocarbons
(
e.
g.,
ketones,
alcohol,
ether),
and
halogenated
hydrocarbons
(
e.
g.,
1,1,1­
trichloroethane,
trichloroethylene,
methylene
chloride).

Solvent
cleaning
takes
place
in
either
the
liquid
or
vapor
phase.
Solvent
vapor
degreasing
normally
is
quicker
than
solvent
liquid
degreasing.
However,
ultrasonic
vibration
is
sometimes
used
with
liquid
solvents
to
decrease
the
required
immersion
time
of
complex
shapes.
Solvent
cleaning
often
is
used
as
a
precleaning
operation
prior
to
alkaline
cleaning,
as
a
final
cleaning
of
precision
parts,
or
as
surface
preparation
for
some
painting
operations.
Solvent
degreasing
operations
typically
are
not
followed
by
rinsing,
although
rinsing
is
performed
in
some
cases.

Steam
Cleaning
removes
residual
dirt,
oil,
and
grease
from
parts
after
processing
though
other
unit
operations.
Typically,
additives
are
not
used
in
this
operation;
the
hot
steam
removes
the
pollutants.
Wastewater
is
generated
when
the
cleaned
parts
are
rinsed.

Testing
(
e.
g.,
hydrostatic,
dye
penetrant,
ultrasonic,
magnetic
flux)
involves
applying
thermal,
electrical,
mechanical,
hydraulic,
or
other
energy
to
determine
the
suitability
or
functionality
of
a
part,
assembly,
or
complete
unit.
Testing
also
may
include
applying
surface
penetrant
dyes
to
detect
surface
imperfections.
Other
examples
of
tests
frequently
performed
include
electrical
testing,
performance
testing,
and
ultrasonic
testing;
these
tests
typically
are
dry
but
may
generate
wastewater
under
certain
circumstances.
Testing
usually
is
performed
to
replicate
some
aspect
of
the
working
environment.
Wastewater
generated
during
testing
includes
spent
process
solutions
and
rinses.

4­
21
4.0
­
Industry
Description
Thermal
Cutting
involves
cutting,
slotting,
or
piercing
a
part
using
an
oxy­
acetylene
oxygen
lance,
electric
arc
cutting
tool,
or
laser.
Thermal
cutting
typically
is
a
dry
process,
except
for
the
use
of
contact
cooling
waters
and
rinses.

Tumbling/
Barrel
Finishing/
Mass
Finishing/
Vibratory
Finishing
involves
polishing
or
deburring
a
part
using
a
rotating
or
vibrating
container
and
abrasive
media
or
other
polishing
materials
to
achieve
a
desired
surface
appearance.
Parts
to
be
finished
are
placed
in
a
rotating
barrel
or
vibrating
unit
with
an
abrasive
media
(
e.
g.,
ceramic
chips,
pebbles),
water,
and
chemical
additives
(
e.
g.,
alkaline
detergents).
As
the
barrel
rotates,
the
upper
layer
of
the
part
slides
toward
the
lower
side
of
the
barrel,
causing
the
abrading
or
polishing.
Similar
results
can
be
achieved
in
a
vibrating
unit,
where
the
entire
contents
of
the
container
are
in
constant
motion,
or
in
a
centrifugal
unit,
which
compacts
the
load
of
media
and
parts
as
the
unit
spins
and
generates
up
to
50
times
the
force
of
gravity.
Spindle
finishing
is
a
similar
process,
where
parts
to
be
finished
are
mounted
on
fixtures
and
exposed
to
a
rapidly
moving
abrasive
slurry.

Wastewater
generated
during
barrel
finishing
includes
spent
process
solutions
and
rinses.
Following
the
finishing
process,
the
contents
of
the
barrel
are
unloaded.
Process
wastewater
is
either
discharged
continuously
during
the
process,
discharged
after
finishing,
or
collected
and
reused.
The
parts
are
sometimes
given
a
final
rinse
to
remove
particles
of
abrasive
media.

Washing
(
Finished
Products)
involves
cleaning
finished
metal
products
after
use
or
storage
using
fresh
water
or
water
containing
a
mild
cleaning
solution.
This
unit
operation
applies
only
to
the
finished
products
that
do
not
require
maintenance
or
rebuilding.

Welding
involves
joining
two
or
more
pieces
of
material
by
applying
heat,
pressure,
or
both,
with
or
without
filler
material,
to
produce
a
metallurgical
bond
through
fusion
or
recrystallization
across
the
interface.
This
includes
gas
welding,
resistance
welding,
arc
welding,
cold
welding,
electron
beam
welding,
and
laser
beam
welding.
Welding
typically
is
a
dry
process,
except
for
the
occasional
use
of
contact
cooling
waters
or
rinses.

Wet
Air
Pollution
Control
for
Organic
Constituents
involves
using
water
to
remove
organic
constituents
that
are
entrained
in
air
streams
exhausted
from
process
tanks
or
production
areas.
Most
frequently,
wet
air
pollution
control
devices
are
used
with
cleaning
and
coating
processes.
A
common
type
of
wet
air
pollution
control
is
the
wet
packed
scrubber
consisting
of
a
spray
chamber
that
is
filled
with
packing
material.
Water
is
continuously
sprayed
onto
the
packing
and
the
air
stream
is
pulled
through
the
packing
by
a
fan.
Pollutants
in
the
air
stream
are
absorbed
by
the
water
droplets
and
the
air
is
released
to
the
atmosphere.
A
single
scrubber
often
serves
numerous
process
tanks.

4.2.2.2
Description
of
MP&
M
Metal­
bearing
Operations
Abrasive
Jet
Machining
includes
removing
stock
material
from
a
part
by
a
high­
speed
stream
of
abrasive
particles
carried
by
a
liquid
or
gas
from
a
nozzle.
Abrasive
jet
machining
is
used
for
deburring,
drilling,
and
cutting
thin
sections
of
metal
or
composite
material.
Unlike
abrasive
4­
22
4.0
­
Industry
Description
blasting,
this
process
operates
at
pressures
of
thousands
of
pounds
per
square
inch.
The
liquid
streams
typically
are
alkaline
or
emulsified
oil
solutions,
although
water
also
can
be
used.

Acid
Pickling
Neutralization
involves
using
a
dilute
alkaline
solution
to
raise
the
pH
of
acid
pickling
rinse
water
that
remains
on
the
part
after
pickling.
The
wastewater
from
this
operation
is
the
acid
pickling
neutralization
rinse
water.

Acid
Treatment
With
Chromium
is
a
general
term
used
to
describe
any
application
of
an
acid
solution
containing
chromium
to
a
metal
surface.
Acid
cleaning,
chemical
etching,
and
pickling
are
types
of
acid
treatment.

Chromic
acid
is
used
occasionally
to
clean
cast
iron,
stainless
steel,
cadmium
and
aluminum,
and
bright
dipping
of
copper
and
copper
alloys.
Also,
chromic
acid
solutions
can
be
used
for
the
final
step
in
acid
cleaning
phosphate
conversion
coating
systems.
Chemical
conversion
coatings
formulated
with
chromic
acid
are
defined
at
 
Chromate
Conversion
Coating
(
or
Chromating) 
in
this
subsection.

Wastewater
generated
during
acid
treatment
includes
spent
solutions
and
rinse
waters.
Spent
solutions
typically
are
batch
discharged
and
treated
or
disposed
of
off
site.
Most
acid
treatment
operations
are
followed
by
a
water
rinse
to
remove
residual
acid.

Acid
Treatment
Without
Chromium
is
a
general
term
used
to
describe
any
application
of
an
acid
solution
not
containing
chromium
to
a
metal
surface.
Acid
cleaning,
chemical
etching,
and
pickling
are
types
of
acid
treatment.

Wastewater
generated
during
acid
treatment
includes
spent
solutions
and
rinse
waters.
Spent
solutions
typically
are
batch
discharged
and
treated
or
disposed
of
off
site.
Most
acid
treatment
operations
are
followed
by
a
water
rinse
to
remove
residual
acid.

Alcohol
Cleaning
involves
removing
dirt
and
residue
material
from
a
part
using
alcohol.

Alkaline
Cleaning
Neutralization
involves
using
a
dilute
acid
solution
to
lower
the
pH
of
alkaline
cleaning
rinse
water
that
remains
on
the
part
after
alkaline
cleaning.
Wastewater
from
this
operation
is
the
alkaline
cleaning
neutralization
rinse
water.

Alkaline
Treatment
With
Cyanide
is
the
cleaning
of
a
metal
surface
with
an
alkaline
solution
containing
cyanide.

Wastewater
generated
during
alkaline
treatment
includes
spent
solutions
and
rinse
waters.
Alkaline
treatment
solutions
become
contaminated
from
the
introduction
of
soils
and
dissolution
of
the
base
metal.
They
usually
are
treated
and
disposed
of
on
a
batch
basis.
Alkaline
treatment
typically
is
followed
by
a
water
rinse
that
is
discharged
to
a
treatment
system.

4­
23
4.0
­
Industry
Description
Anodizing
With
Chromium
involves
producing
a
protective
oxide
film
on
aluminum,
magnesium,
or
other
light
metal,
usually
by
passing
an
electric
current
through
an
electrolyte
bath
in
which
the
metal
is
immersed.
Anodizing
may
be
followed
by
a
sealant
operation.

Chromic
acid
anodic
coatings
have
a
relatively
thick
boundary
layer
and
are
more
protective
than
are
sulfuric
acid
coatings.
For
these
reasons,
chromic
acid
is
sometimes
used
when
the
part
cannot
be
rinsed
completely.
These
oxide
coatings
provide
corrosion
protection,
decorative
surfaces,
a
base
for
painting
and
other
coating
processes,
and
special
electrical
and
mechanical
properties.

Wastewaters
generated
during
anodizing
include
spent
anodizing
solutions,
sealants,
and
rinse
waters.
Because
of
the
anodic
nature
of
the
process,
anodizing
solutions
become
contaminated
with
the
base
metal
being
processed.
These
solutions
eventually
reach
an
intolerable
concentration
of
dissolved
metal
and
require
treatment
or
disposal.
Rinse
water
following
anodizing,
coloring,
and
sealing
typically
is
discharged
to
a
treatment
system.

Anodizing
Without
Chromium
involves
applying
a
protective
oxide
film
to
aluminum,
magnesium,
or
other
light
metal,
usually
by
passing
an
electric
current
through
an
electrolyte
bath
in
which
the
metal
is
immersed.
Phosphoric
acid,
sulfuric
acid,
and
boric
acid
are
used
in
anodizing.
Anodizing
also
may
include
sealant
baths.
These
oxide
coatings
provide
corrosion
protection,
decorative
surfaces,
a
base
for
painting
and
other
coating
processes,
and
special
electrical
and
mechanical
properties.

Wastewater
generated
during
anodizing
includes
spent
anodizing
solutions,
sealants,
and
rinse
waters.
Because
of
the
anodic
nature
of
the
process,
anodizing
solutions
become
contaminated
with
the
base
metal
being
processed.
These
solutions
eventually
reach
an
intolerable
concentration
of
dissolved
metal
and
require
treatment
or
disposal.
Rinse
water
following
anodizing,
coloring,
and
sealing
steps
typically
is
discharged
to
a
treatment
systems.

Carbon
Black
Deposition
involves
coating
the
inside
of
printed
circuit
board
holes
by
dipping
the
circuit
board
into
a
tank
that
contains
carbon
black
and
potassium
hydroxide.
After
excess
solution
dips
from
the
circuit
boards,
they
are
heated
to
allow
the
carbon
black
to
adhere
to
the
board.

Catalyst
Acid
Pre­
Dip
uses
rinse
water
to
remove
residual
solution
from
a
part
after
the
part
is
processed
in
an
acid
bath.
The
wastewater
generated
in
this
unit
operation
is
the
rinse
water.

Chemical
Conversion
Coating
without
Chromium
is
the
process
of
applying
a
protective
coating
on
the
surface
of
a
metal
without
using
chromium.
Such
coatings
are
applied
through
phosphate
conversion
(
except
for
 
Iron
Phosphate
Conversion
Coating, 
see
section
4.2.2.1),
metal
coloring,
or
passivation.
Coatings
are
applied
to
a
base
metal
or
previously
deposited
metal
to
increase
corrosion
protection
and
lubricity,
prepare
the
surface
for
additional
coatings,
or
formulate
a
special
surface
appearance.
This
unit
process
includes
sealant
operations
that
use
additives
other
than
chromium.

4­
24
4.0
­
Industry
Description
 
In
phosphate
conversion,
coatings
are
applied
for
one
or
more
of
the
following
reasons:
to
provide
a
base
for
paints
and
other
organic
coatings;
to
condition
surfaces
for
cold
forming
operations
by
providing
a
base
for
drawing
compounds
and
lubricants;
to
impart
corrosion
resistance
to
the
metal
surface;
or
to
provide
a
suitable
base
for
corrosion­
resistant
oils
or
waxes.
Phosphate
conversion
coatings
are
formed
by
immersing
a
metal
part
in
a
dilute
solution
of
phosphoric
acid,
phosphate
salts,
and
other
reagents.

 
Metal
coloring
by
chemical
conversion
coating
produces
a
large
group
of
decorative
finishes.
Metal
coloring
includes
the
formation
of
oxide
conversion
coatings.
In
this
operation,
the
metal
surface
is
converted
into
an
oxide
or
similar
metallic
compound,
giving
the
part
the
desired
color.
The
most
common
colored
finishes
are
used
on
copper,
steel,
zinc,
and
cadmium.

 
Passivation
forms
a
protective
coating
on
metals,
particularly
stainless
steel,
by
immersing
the
part
in
an
acid
solution.
Stainless
steel
is
passivated
to
dissolve
embedded
iron
particles
and
to
form
a
thin
oxide
film
on
the
surface
of
the
metal.

Wastewater
generated
during
chemical
conversion
coating
includes
spent
solutions
and
rinses
(
i.
e.,
both
the
chemical
conversion
coating
solutions
and
post­
treatment
sealant
solutions).
These
solutions
commonly
are
discharged
to
a
treatment
system
when
contaminated
with
the
base
metal
or
other
impurities.
Rinsing
normally
follows
each
process
step,
except
when
a
sealant
dries
on
the
part
surface.

Chemical
Milling
(
or
Chemical
Machining)
involves
removing
metal
from
a
part
by
controlled
chemical
attack,
or
etching,
to
produce
desired
shapes
and
dimensions.
In
chemical
machining,
a
masking
agent
typically
is
applied
to
cover
a
portion
of
the
part's
surface;
the
exposed
(
unmasked)
surface
is
then
treated
with
the
chemical
machining
solution.

Wastewater
generated
during
chemical
machining
includes
spent
solutions
and
rinses.
Process
solutions
typically
are
discharged
after
becoming
contaminated
with
the
base
metal.
Rinsing
normally
follows
chemical
machining.

Chromate
Conversion
Coating
(
or
Chromating)
involves
forming
a
conversion
coating
(
protective
coating)
on
a
metal
by
immersing
or
spraying
the
metal
with
a
hexavalent
chromium
compound
solution
to
produce
a
hexavalent
or
trivalent
chromium
compound
coating.
This
also
is
known
as
chromate
treatment,
and
is
most
often
applied
to
aluminum,
zinc,
cadmium
or
magnesium
surfaces.
Sealant
operations
using
chromium
also
are
included
in
this
unit
operation.

4­
25
4.0
­
Industry
Description
Chromate
solutions
include
two
types:
(
1)
those
that
deposit
substantial
chromate
films
on
the
substrate
metal
and
are
complete
treatments
themselves,
and
(
2)
those
that
seal
or
supplement
oxide,
phosphate,
or
other
types
of
protective
coatings.

Wastewater
generated
during
chromate
conversion
coating
includes
spent
process
solutions
(
i.
e.,
both
the
chromate
conversion
coating
solutions
and
post­
treatment
sealant
solutions)
and
rinses.
These
solutions
typically
are
discharged
to
a
treatment
system
when
contaminated
with
the
base
metal
or
other
impurities.
Also,
chromium­
based
solutions,
which
are
typically
formulated
with
hexavalent
chromium,
lose
operating
strength
when
the
hexavalent
chromium
reduces
to
trivalent
chromium
during
use.
Rinsing
normally
follows
each
process
step,
except
for
sealants
that
dry
on
the
surface
of
the
part.

Chromium
Drag­
out
Destruction
is
a
unit
operation
performed
following
chromium­
bearing
operations
to
reduce
hexavalent
chromium
that
is
 
dragged
out 
of
the
process
bath.
Parts
are
dipped
in
a
solution
of
a
chromium­
reducing
chemical
(
e.
g.,
sodium
metabisulfite)
to
prevent
the
hexavalent
chromium
from
contaminating
subsequent
process
baths.
This
operation
typically
is
performed
in
a
stagnant
drag­
out
rinse
tank
that
contains
concentrated
chromium­
bearing
wastewater.

Cyanide
Drag­
out
Destruction
involves
dipping
the
part
in
a
cyanide
oxidation
solution
(
e.
g.,
sodium
hypochloride)
to
prevent
cyanide
that
is
 
dragged
out 
of
a
process
bath
from
contaminating
subsequent
process
baths.
This
operation
typically
is
performed
in
a
stagnant
drag­
out
rinse
tank.

Cyaniding
Rinse
is
generated
during
cyaniding
hardening
of
a
part.
The
part
is
heated
in
a
molten
salt
solution
containing
cyanide.
Wastewater
is
generated
when
excess
cyanide
salt
solution
is
removed
from
the
part
in
rinse
water.

Electrochemical
Machining
is
a
process
in
which
the
part
becomes
the
anode
and
a
shaped
cathode
is
the
cutting
tool.
By
pumping
electrolyte
between
the
electrodes
and
applying
a
current,
metal
is
rapidly
but
selectively
dissolved
from
the
part.
Wastewater
generated
during
electrochemical
machining
includes
spent
electrolytes
and
rinses.

Electroless
Catalyst
Solution
involves
adding
a
catalyst
just
prior
to
an
electroless
plating
operation
to
accelerate
the
plating
operation.

Electroless
Plating
involves
applying
a
metallic
coating
to
a
part
using
a
chemical
reduction
process
in
the
presence
of
a
catalysis.
An
electric
current
is
not
used
in
this
operations.
The
metal
to
be
plated
onto
a
part
typically
is
held
in
solution
at
high
concentrations
using
a
chelating
agent.
This
plates
all
areas
of
the
part
to
a
uniform
thickness
regardless
of
the
configuration
of
the
part.
Also,
an
electroless­
plated
surface
is
dense
and
virtually
nonporous.
Copper
and
nickel
electroless
plating
operations
are
the
most
common.

4­
26
4.0
­
Industry
Description
Sealant
operations
(
i.
e.,
other
than
hot
water
dips)
following
electroless
plating
are
considered
separate
unit
operations
if
they
include
any
additives.

Wastewater
generated
during
electroless
plating
includes
spent
process
solutions
and
rinses.
The
wastewater
contains
chelated
metals,
which
require
separate
preliminary
treatment
to
break
the
metal
chelates
prior
to
conventional
chemical
precipitation.
Rinsing
follows
most
electroless
plating
processes
to
remove
residual
plating
solution
and
prevent
contamination
of
subsequent
process
baths.

Electrolytic
Cleaning
involves
removing
soil,
scale,
or
surface
oxides
from
a
part
by
electrolysis.
The
part
is
one
of
the
electrodes
and
the
electrolyte
is
usually
alkaline.
Electrolytic
alkaline
cleaning
and
electrolytic
acid
cleaning
are
the
two
types
of
electrolytic
cleaning.

 
Electrolytic
alkaline
cleaning
produces
a
cleaner
surface
than
do
nonelectrolytic
methods
of
alkaline
cleaning.
This
operation
uses
strong
agitation,
gas
evolution
in
the
solution,
and
oxidation­
reduction
reactions
that
occur
during
electrolysis.
In
addition,
dirt
particles
become
electrically
charged
and
are
repelled
from
the
part
surface.

 
Electrolytic
acid
cleaning
sometimes
is
used
as
a
final
cleaning
before
electroplating.
Sulfuric
acid
is
most
frequently
used
as
the
electrolyte.
As
with
electrolytic
alkaline
cleaning,
the
mechanical
scrubbing
effect
from
the
evolution
of
gas
enhances
the
effectiveness
of
the
process.

Wastewater
generated
during
electrolytic
cleaning
includes
spent
process
solutions
and
rinses.
Electrolytic
cleaning
solutions
become
contaminated
during
use
due
to
the
dissolution
of
the
base
metal
and
the
introduction
of
pollutants.
The
solutions
typically
are
batch
discharged
for
treatment
or
disposal
after
they
weaken.
Rinsing
following
electrolytic
cleaning
removes
residual
cleaner
to
prevent
contamination
of
subsequent
process
baths.

Electroplating
with
Chromium
involves
producing
a
chromium
metal
coating
on
a
surface
by
electrodeposition.
Electroplating
provides
corrosion
protection,
wear
or
erosion
resistance,
lubricity,
electrical
conductivity,
or
decoration.

In
electroplating,
metal
ions
in
acid,
alkaline,
or
neutral
solutions
are
reduced
on
the
cathodic
surfaces
of
the
parts
being
plated.
Metal
salts
or
oxides
typically
are
added
to
replenish
the
solutions.
Chromium
trioxide
often
is
added
as
a
source
of
chromium.

In
addition
to
water
and
the
metal
being
deposited,
electroplating
solutions
often
contain
agents
that
form
complexes
with
the
metal
being
deposited,
stabilizers
to
prevent
hydrolysis,
buffers
for
pH
control,
catalysts
to
assist
in
deposition,
chemical
aids
to
dissolve
anodes,
and
miscellaneous
ingredients
that
modify
the
process
to
attain
specific
properties.
Sealant
operations
performed
after
this
operation
are
considered
separate
unit
operations
if
they
include
any
additives
(
i.
e.,
other
than
hot
water
dips).

4­
27
4.0
­
Industry
Description
Wastewater
generated
during
electroplating
includes
spent
process
solutions
and
rinses.
Electroplating
solutions
occasionally
become
contaminated
during
use
due
to
the
base
metal
dissolving
and
the
introduction
of
other
pollutants,
diminishing
the
effectiveness
of
the
electroplating
solutions.
Spent
concentrated
solutions
typically
are
treated
to
remove
pollutants
and
reused,
processed
in
a
wastewater
treatment
system,
or
disposed
of
off
site.
Rinse
waters,
including
some
drag­
out
rinse
tank
solutions,
typically
are
treated
on
site.

Electroplating
with
Cyanide
involves
producing
metal
coatings
on
a
surface
by
electrodeposition
using
cyanide.
Electroplating
provides
corrosion
protection,
wear
or
erosion
resistance,
electrical
conductivity,
or
decoration.

In
electroplating,
metal
ions
in
acid,
alkaline,
or
neutral
solutions
are
reduced
on
the
cathodic
surfaces
of
the
parts
being
plated.
The
metal
ions
in
solution
typically
are
replenished
by
dissolving
metal
from
anodes
contained
in
inert
wire
or
metal
baskets.
Sealant
operations
performed
after
this
operation
are
considered
separate
unit
operations
if
they
include
any
additives
(
i.
e.,
any
sealant
operations
other
than
hot
water
dips).

In
addition
to
water
and
the
metal
being
deposited,
electroplating
solutions
often
contain
agents
that
form
complexes
with
the
metal
being
deposited,
stabilizers
to
prevent
hydrolysis,
buffers
to
control
pH,
catalysts
to
assist
in
deposition,
chemical
aids
to
dissolve
anodes,
and
miscellaneous
ingredients
that
modify
the
process
to
attain
specific
properties.
Cyanide,
usually
in
the
form
of
sodium
or
potassium
cyanide,
frequently
is
used
as
a
complexing
agent
for
zinc,
cadmium,
copper,
and
precious
metal
baths.

Wastewater
generated
during
electroplating
includes
spent
process
solutions
and
rinses.
Electroplating
solutions
occasionally
become
contaminated
during
use
due
to
dissolution
of
the
base
metal
and
the
introduction
of
other
pollutants,
diminishing
the
performance
of
the
electroplating
solutions.
Spent
concentrated
solutions
typically
are
treated
to
remove
pollutants
and
reused,
processed
in
a
wastewater
treatment
system,
or
disposed
of
off
site.
Rinse
waters,
including
some
drag­
out
rinse
tank
solutions,
typically
are
treated
on
site.

Electroplating
without
Chromium
or
Cyanide
involves
the
production
of
metal
coatings
on
a
surface
by
electrodeposition,
without
using
chromium
or
cyanide.
Commonly
electroplated
metals
include
nickel,
copper,
tin/
lead,
gold,
and
zinc.
Electroplating
provides
corrosion
protection,
wear
or
erosion
resistance,
lubricity,
electrical
conductivity,
or
decoration.

In
electroplating,
metal
ions
in
acid,
alkaline,
or
neutral
solutions
are
reduced
on
the
cathodic
surfaces
of
the
parts
being
plated.
The
metal
ions
in
solution
typically
are
replenished
by
dissolving
metal
from
anodes
contained
in
inert
wire
or
metal
baskets.
Sealant
operations
performed
after
this
operation
are
considered
separate
unit
operations
if
they
include
any
additives
(
i.
e.,
any
sealant
operations
other
than
hot
water
dips).

In
addition
to
water
and
the
metal
being
deposited,
electroplating
solutions
often
contain
agents
that
form
complexes
with
the
metal
being
deposited,
stabilizers
to
prevent
hydrolysis,
buffers
to
4­
28
4.0
­
Industry
Description
control
pH,
catalysts
to
assist
in
deposition,
chemical
aids
to
dissolve
anodes,
and
miscellaneous
ingredients
that
modify
the
process
to
attain
specific
properties.

Wastewater
generated
during
electroplating
without
chromium
or
cyanide
includes
spent
process
solutions
and
rinses.
Electroplating
solutions
occasionally
become
contaminated
during
use
due
to
dissolution
of
the
base
metal
and
the
introduction
of
other
pollutants,
diminishing
the
effectiveness
of
the
electroplating
solutions.
Spent
concentrated
solutions
typically
are
treated
for
pollutant
removal
and
reused,
processed
in
a
wastewater
treatment
system,
or
disposed
of
off
site.
Rinse
waters,
including
some
drag­
out
rinse
tank
solutions,
typically
are
treated
on
site.

Electropolishing
involves
producing
a
highly
polished
surface
on
a
part
using
reversed
electrodeposition
in
which
the
anode
(
part)
releases
some
metal
ions
into
the
electrolyte
to
reduce
surface
roughness.
When
current
is
applied,
a
polarized
film
forms
on
the
metal
surface,
through
which
metal
ions
diffuse.
In
this
operation,
areas
of
surface
roughness
on
parts
serve
as
high­
current
density
areas
and
are
dissolved
at
rates
greater
than
the
rates
for
smoother
portions
of
the
metal
surface.

Metals
are
electropolished
to
improve
appearance,
reflectivity,
and
corrosion
resistance.
Base
metals
processed
by
electropolishing
include
aluminum,
copper,
zinc,
low­
alloy
steel,
and
stainless
steel.
Common
electrolytes
include
sodium
hydroxide
and
combinations
of
sulfuric
acid,
phosphoric
acid,
and
chromic
acid.

Wastewater
generated
during
electropolishing
includes
spent
process
solutions
and
rinses.
Eventually,
the
concentration
of
dissolved
metals
increases
to
the
point
where
the
process
becomes
ineffective.
Typically,
a
portion
of
the
bath
is
decanted
and
either
fresh
chemicals
are
added
or
the
entire
solution
is
discharged
to
treatment
and
replaced
with
fresh
chemicals.
Rinsing
can
involve
several
steps
and
can
include
hot
immersion
or
spray
rinses.

Galvanizing/
Hot
Dip
Coating
involves
using
various
processes
to
coat
an
iron
or
steel
surface
with
zinc.
In
hot
dipping,
a
base
metal
is
coated
by
dipping
it
into
a
tank
that
contains
a
molten
metal.

Hot
Dip
Coating
involves
applying
a
metal
coating
(
usually
zinc)
to
the
surface
of
a
part
by
dipping
the
part
in
a
molten
metal
bath.
Wastewater
is
generated
in
this
operation
when
residual
metal
coating
solution
is
removed
from
the
part
in
rinse
water.

Kerfing
uses
a
tool
to
remove
small
amounts
of
metal
from
a
product
surface.
Water
and
synthetic
coolants
may
be
used
to
lubricate
the
area
between
the
tool
and
the
metal,
to
maintain
the
temperature
of
the
cutting
tool,
and
to
remove
metal
fines
from
the
surface
of
the
part.
This
operation
generates
oily
wastewater
that
contains
metal
fines
and
dust.

Laminating
involves
applying
a
material
to
a
substrate
using
heat
and
pressure.

4­
29
4.0
­
Industry
Description
Mechanical
and
Vapor
Plating
involves
applying
a
metallic
coating
to
a
part.
For
mechanical
plating,
the
part
is
rotated
in
a
drum
containing
a
water­
based
solution,
glass
beads,
and
metal
powder.
In
vapor
plating,
a
metallic
coating
is
applied
by
atomizing
the
metal
and
applying
an
electric
charge
to
the
part,
which
causes
the
atomized
(
vapor
phase)
metal
to
adhere
to
the
part.

Wastewater
generated
in
this
operation
includes
spent
solutions
from
the
process
bath
and
rinse
water.
Typically,
the
wastewater
contains
high
concentrations
of
the
applied
metal.

Metallic
Fiber
Cloth
Manufacturing
involves
weaving
thin
metallic
fibers
to
create
a
mesh
cloth.

Metal
Spraying
(
Including
Water
Curtain)
involves
applying
a
metallic
coating
to
a
part
by
projecting
molten
or
semimolten
metal
particles
onto
a
substrate.
Coatings
can
be
sprayed
from
rod
or
wire
stock
or
from
powdered
material.
The
process
involves
feeding
the
material
(
e.
g.,
wire)
into
a
flame
where
it
is
melted.
The
molten
stock
then
is
stripped
from
the
end
of
the
wire
and
atomized
by
a
high­
velocity
stream
of
compressed
air
or
other
gas
that
propels
the
material
onto
a
prepared
substrate
or
part.

Metal
spraying
coatings
are
used
in
a
wide
range
of
special
applications,
including:
insulating
layers
in
applications
such
as
induction
heating
coils;
electromagnetic
interference
shielding;
thermal
barriers
for
rocket
engines;
nuclear
moderators;
films
for
hot
isostatic
pressing;
and
dimensional
restoration
of
worn
parts.

Metal
spraying
is
sometimes
performed
in
front
of
a
 
water
curtain 
(
a
circulated
water
stream
used
to
trap
overspray)
or
a
dry
filter
exhaust
hood
that
captures
the
overspray
and
fumes.
With
water
curtain
systems,
water
is
recirculated
from
a
sump
or
tank.
Wastewater
is
generated
when
the
sump
or
tank
is
discharged
periodically.
Metal
spraying
typically
is
not
followed
by
rinsing.

Painting­
Immersion
(
Including
Electrophoretic,
 
E­
coat )
involves
applying
an
organic
coating
to
a
part
using
processes
such
autophoretic
and
electrophoretic
painting.

 
Autophoretic
Painting
involves
applying
an
organic
paint
film
by
electrophoresis
when
a
part
is
immersed
in
a
suitable
aqueous
bath.

 
Electrophoretic
Painting
is
coating
a
part
by
making
it
either
anodic
or
cathodic
in
a
bath
that
is
generally
an
aqueous
emulsion
of
the
organic
coating
material.

 
Other
Immersion
Painting
includes
all
other
types
of
immersion
painting
such
as
dip
painting.

Water
is
used
in
immersion
paint
operations
as
a
carrier
for
paint
particles
and
to
rinse
the
part.
Aqueous
painting
solutions
and
rinses
typically
are
treated
through
an
ultrafiltration
system.
The
concentrate
is
returned
to
the
painting
solution,
and
the
permeate
is
reused
as
rinse
water.
Sites
4­
30
4.0
­
Industry
Description
typically
discharge
a
bleed
stream
to
treatment.
The
painting
solution
and
rinses
are
batch
discharged
periodically
to
treatment.

Photo
Imaging
is
the
process
of
exposing
a
photoresist­
laden
printed
wiring
board
to
light
to
impact
the
circuitry
design
to
the
board.
Water
is
not
used
in
this
operation.

Photo
Image
Developing
is
an
operation
in
which
a
water­
based
solution
is
used
to
develop
the
exposed
circuitry
in
a
photoresist­
laden
printed
wiring
board.
Wastewater
generated
in
this
operation
includes
spent
process
solution
and
rinse
water.

Photoresist
Application
is
an
operation
that
uses
heat
and
pressure
to
apply
a
photoresist
coating
to
a
printed
wiring
board.
Water
is
not
used
in
this
operation.

Photoresist
Strip
involves
removing
organic
photoresist
material
from
a
printed
wiring
board
using
an
acid
solution.

Phosphor
Deposition
is
the
application
of
a
phosphorescent
coating
to
a
part.
Wastewater
generated
in
this
unit
operation
includes
water
used
to
keep
the
parts
clean
and
wet
while
the
coating
is
applied,
and
rinse
water
used
to
remove
excess
phosphorescent
coating
from
the
part.

Physical
Vapor
Deposition
involves
physically
removing
a
material
from
a
source
through
evaporation
or
sputtering,
using
the
energy
of
the
vapor
particles
in
a
vacuum
or
partial
vacuum
to
transport
the
removed
material,
and
condensing
the
removed
material
as
a
film
onto
the
surface
of
a
part
or
other
substrate.

Plasma
Arc
Machining
involves
removing
material
or
shaping
a
part
by
a
high­
velocity
jet
of
high­
temperature,
ionized
gas.
A
gas
(
nitrogen,
argon,
or
hydrogen)
is
passed
through
an
electric
arc,
causing
the
gas
to
become
ionized,
and
heated
to
temperatures
exceeding
16,650
°
C
(
30,000
°
F).
The
relatively
narrow
plasma
jet
melts
and
displaces
the
material
in
its
path.
Because
plasma
arc
machining
does
not
depend
on
a
chemical
reaction
between
the
gas
and
the
part,
and
because
plasma
temperatures
are
extremely
high,
the
process
can
be
used
on
almost
any
metal,
including
those
that
are
resistant
to
oxygen­
fuel
gas
cutting.
The
method
is
used
mainly
for
profile
cutting
of
stainless
steel
and
aluminum
alloys.

Although
plasma
arc
machining
typically
is
a
dry
process,
water
is
used
for
water
injection
plasma
arc
torches.
In
these
cases,
a
constricted
swirling
flow
of
water
surrounds
the
cutting
arc.
This
operation
also
may
be
performed
immersed
in
a
water
bath.
In
both
cases,
water
is
used
to
stabilize
the
arc,
to
cool
the
part,
and
to
contain
smoke
and
fumes.

Plastic
Wire
Extrusion
involves
applying
a
plastic
material
to
a
metal
wire
through
an
extrusion
process.

Salt
Bath
Descaling
involves
removing
surface
oxides
or
scale
from
a
part
by
immersing
the
part
in
a
molten
salt
bath
or
hot
salt
solution.
Salt
bath
descaling
solutions
can
contain
molten
salts,

4­
31
4.0
­
Industry
Description
caustic
soda,
sodium
hydride,
and
chemical
additives.
Molten
salt
baths
are
used
in
a
salt
bath­
water
quench­
acid
dip
sequence
to
remove
oxides
from
stainless
steel
and
other
corrosion­
resistant
alloys.
In
this
process,
the
part
typically
is
immersed
in
the
molten
salt,
quenched
with
water,
and
then
dipped
in
acid.
Oxidizing,
reducing,
or
electrolytic
salt
baths
can
be
used
depending
on
the
oxide
to
be
removed.
Wastewater
generated
during
salt
bath
descaling
includes
spent
process
solutions,
quenches,
and
rinses.

Shot
Tower
­
Lead
Shot
Manufacturing
involves
dropping
molten
lead
from
a
platform
on
the
top
of
a
tower
through
a
sieve­
like
device
and
into
a
vat
of
cold
water.

Soldering
involves
joining
metals
by
inserting
a
thin
(
capillary
thickness)
layer
of
nonferrous
filler
metal
into
the
space
between
them.
Bonding
results
from
the
intimate
contact
produced
by
the
metallic
bond
formed
between
the
substrate
metal
and
the
solder
alloy.
The
term
soldering
is
used
where
the
melting
temperature
of
the
filler
is
below
425
°
C
(
800
°
F).
Some
soldering
operations
use
a
solder
flux,
which
is
an
aqueous
or
nonaqueous
material
used
to
dissolve,
remove,
or
prevent
the
formation
of
surface
oxides
on
the
part.

Except
for
the
use
of
aqueous
fluxes,
soldering
typically
is
a
dry
operation;
however,
a
quench
or
rinse
sometimes
follows
soldering
to
cool
the
part
or
remove
excess
flux
or
other
foreign
material
from
its
surface.
Recent
developments
in
soldering
technology
have
focused
on
fluxless
solders
and
fluxes
that
can
be
cleaned
off
with
water.

Solder
Flux
Cleaning
involves
removing
residual
solder
flux
from
a
printed
circuit
board
using
either
an
alkaline
or
alcohol
cleaning
solution.

Solder
Fusing
involves
coating
a
tin­
lead
plated
circuit
board
with
a
solder
flux
and
then
passing
the
board
through
a
hot
oil.
The
hot
oil
fuses
the
tin­
lead
to
the
board
and
creates
a
solder­
like
finish
on
the
board.

Solder
Masking
involves
applying
a
resistive
coating
to
certain
areas
of
a
circuit
board
to
protect
the
areas
during
subsequent
processing.

Sputtering
is
a
vacuum
evaporation
process
in
which
portions
of
a
coating
material
are
physically
removed
from
a
substrate
and
deposited
a
thin
film
onto
a
different
substrate.

Stripping
(
Paint)
involves
removing
a
paint
(
or
other
organic)
coating
from
a
metal
basis
material.
Stripping
commonly
is
performed
as
part
of
the
manufacturing
process
to
recover
parts
that
have
been
improperly
coated
or
as
part
of
maintenance
and
rebuilding
to
restore
parts
to
a
usable
condition.

Organic
coatings
(
including
paint)
are
stripped
using
thermal,
mechanical,
and
chemical
means.
Thermal
methods
include
burn­
off
ovens,
fluidized
beds
of
sand,
and
molten
salt
baths.
Mechanical
methods
include
scraping
and
abrasive
blasting
(
as
defined
in
 
Abrasive
Blasting 
in
4­
32
4.0
­
Industry
Description
Section
4.2.2.1).
Chemical
paint
strippers
include
alkali
solutions,
acid
solutions,
and
solvents
(
e.
g.,
methylene
chloride).

Wastewater
generated
during
organic
coating
stripping
includes
process
solutions
(
limited
mostly
to
chemical
paint
strippers
and
rinses).

Stripping
(
Metallic
Coating)
involves
removing
a
metallic
coating
from
a
metal
basis
material.
Stripping
is
commonly
part
of
the
manufacturing
process
to
recover
parts
that
have
been
improperly
coated
or
as
part
of
maintenance
and
rebuilding
to
restore
parts
to
a
usable
condition.

Metallic
coating
stripping
most
often
uses
chemical
baths,
although
mechanical
means
(
e.
g.,
grinding,
abrasive
blasting)
also
are
used.
Chemical
stripping
frequently
is
performed
as
an
aqueous
electrolytic
process.

Wastewater
generated
during
metallic
coating
stripping
includes
process
solutions
and
rinses.
Stripping
solutions
become
contaminated
from
dissolution
of
the
base
metal.
Typically,
the
entire
solution
is
discharged
to
treatment.
Rinsing
is
used
to
remove
the
corrosive
film
remaining
on
the
parts.

Thermal
Infusion
uses
heat
to
infuse
metal
powder
or
dust
onto
the
surface
of
a
part.
Typically,
thermal
infusion
is
a
dry
operation.
In
some
cases,
however,
water
may
be
used
to
remove
excess
metal
powder,
metal
dust,
or
molten
metal.

Ultrasonic
Machining
involves
forcing
an
abrasive
liquid
between
a
vibrating
tool
and
a
part.
Particles
in
the
abrasive
liquid
strike
the
part,
removing
any
microscopic
flakes
on
the
part.

Vacuum
Impregnation
is
used
to
reduce
the
porosity
of
the
part.
A
filler
material
(
usually
organic)
is
applied
to
the
surface
of
the
part
and
polymerized
under
pressure
and
heat.
Wastewater
is
generated
in
this
unit
operation
when
rinse
water
is
used
to
remove
residual
organic
coating
from
the
part.

Vacuum
Plating
involves
applying
a
thin
layer
of
metal
oxide
onto
a
part
using
molten
metal
in
a
vacuum
chamber.

Water
Shedder
involves
applying
a
dilute
water­
based
chemical
compound
to
a
part
to
accelerate
drying.
This
operation
typically
is
used
to
prevent
a
part
from
streaking
when
excess
water
remains
on
the
part.

Wet
Air
Pollution
Control
involves
using
water
to
remove
chemicals,
fumes,
or
dusts
that
are
entrained
in
air
streams
exhausted
from
process
tanks
or
production
areas.
Most
frequently,
wet
air
pollution
control
devices
are
used
with
electroplating,
cleaning,
and
coating
processes.
A
common
type
of
wet
air
pollution
control
is
the
wet
packed
scrubber
consisting
of
a
spray
chamber
that
is
filled
with
packing
material.
Water
is
continuously
sprayed
onto
the
packing
and
the
air
stream
is
pulled
through
the
packing
by
a
fan.
Pollutants
in
the
air
stream
are
absorbed
by
4­
33
4.0
­
Industry
Description
the
water
droplets
and
the
air
is
released
to
the
atmosphere.
A
single
scrubber
often
serves
numerous
process
tanks;
however,
the
air
streams
typically
are
segregated
by
source
into
chromium,
cyanide,
and
acid/
alkaline
sources.
Wet
air
pollution
control
can
be
divided
into
several
suboperations,
including:

 
Wet
Air
Pollution
Control
for
Acid
Alkaline
Baths;

 
Wet
Air
Pollution
Control
for
Cyanide
Baths;

 
Wet
Air
Pollution
Control
for
Chromium­
Bearing
Baths;
and
 
Wet
Air
Pollution
Control
for
Fumes
and
Dusts.

Wire
Galvanizing
Flux
involves
using
flux
to
remove
rust
and
oxide
from
the
surface
of
steel
wire
prior
to
galvanizing.
This
provides
long­
term
corrosion
protection
for
the
steel
wire.

4.2.3
Metals
Processed
MP&
M
facilities
perform
proposed
MP&
M
operations
on
a
variety
of
metals.
EPA
identified
29
different
metals
processed
at
MP&
M
facilities
from
survey
results.
Of
these,
iron,
aluminum,
and
copper
are
the
metals
most
frequently
processed.
Nickel,
tin,
lead,
gold,
and
zinc
frequently
are
used
in
electroplating
operations.

Many
MP&
M
facilities
process
more
than
one
metal.
Figure
4­
7
shows
the
percentage
of
wastewater­
discharging
MP&
M
facilities
by
number
of
metals
processed.
As
shown
in
Figure
4­
7,
65
percent
of
the
wastewater­
discharging
MP&
M
facilities
that
provided
metal
use
information
process
more
than
one
metal.

4.2.4
Estimated
Annual
Wastewater
Discharge
Process
wastewater
is
generated
in
many
of
the
proposed
MP&
M
operations
listed
in
Section
4.2.2.
Some
operations
may
be
performed
with
or
without
water
(
wet
or
dry)
depending
on
the
purpose
of
the
operation,
raw
materials
used,
and
final
product
use.
For
example,
some
machining
operations
(
e.
g.,
drilling)
are
performed
without
a
coolant,
while
other
machining
operations
(
e.
g.,
milling)
require
a
coolant.
Process
wastewater
may
be
recirculated,
recycled
or
reused
as
described
in
Section
4.1.4;
however,
process
wastewater
generally
is
discharged
to
a
treatment
system
or
disposed
of
through
other
means
(
e.
g.,
transfer
to
CWT).

Based
on
survey
results,
the
most
commonly
performed
wet
proposed
MP&
M
operations
are
floor
cleaning
and
acid
treatment.
Survey
results
also
show
the
most
commonly
performed
proposed
MP&
M
operations
do
not
generate
the
largest
volumes
of
wastewater.
Of
the
volume
of
wastewater
discharged,
79
percent
is
generated
from
rinses,
with
chemical
conversion
coating
rinsing,
acid
treatment
rinsing,
and
alkaline
treatment
rinsing
generating
the
highest
volume
of
wastewater.
Table
4­
5
lists
the
proposed
MP&
M
operations
and
presents
the
estimated
number
of
MP&
M
facilities
that
discharge
wastewater
generated
in
each
proposed
MP&
M
operation
and
the
estimated
annual
discharge
for
the
proposed
MP&
M
operation.
Note
that
MP&
M
facilities
typically
conduct
more
than
one
proposed
MP&
M
operation.

4­
34
4.0
­
Industry
Description
Five
or
More
Metal
Types
36%
7%

Three
Metal
Types
22%
F
our
M
e
ta
l
Ty
pe
s
12%
On
e
M
e
t
a
l
Ty
p
e
Two
Metal
Types
24%

Source:
MP&
M
Survey
Database.
Note:
Although
there
are
44,000
wastewater­
discharging
MP&
M
facilities
only
15,470
are
represented
in
the
above
pie
chart.
The
1996
short
and
municipality
surveys
did
not
request
metal
use
information.
Additionally,
several
1989
and
1996
long
survey
recipients
did
not
provide
this
information.

Figure
4­
7.
Percentage
of
Wastewater­
Discharging
MP&
M
facilities
by
Number
of
Metal
Processed
4­
35
4.0
­
Industry
Description
Table
4­
5
Estimated
Number
of
MP&
M
Facilities
Discharging
Process
Wastewater
by
Proposed
MP&
M
Operation
and
Estimated
Annual
Dischargea
for
Each
Proposed
MP&
M
Operation
Survey
Unit
Operation
Number
Unit
Operation
Estimated
Number
of
MP&
M
Facilities
Discharging
Wastewater
from
Unit
Operation
Estimated
Annual
Dischargeb
(
gpy)

1
Abrasive
Blasting
1,140
38,136,192
1R.
Abrasive
Blasting
Rinse
2,714
294,364,698
2
Abrasive
Jet
Machining
1,802
32,882,557
3
Acid
Treatment
With
Chromium
789
4,119,176
3R.
Acid
Treatment
With
Chromium
Rinse
1,139
514,116,041
4
Acid
Treatment
Without
Chromium
21,518
307,274,559
4R.
Acid
Treatment
Without
Chromium
Rinse
25,886
9,877,473,513
5
Alkaline
Cleaning
for
Oil
Removal
15,194
1,017,415,369
5R.
Alkaline
Cleaning
for
Oil
Removal
Rinse
10,918
7,007,305,341
6
Alkaline
Treatment
With
Cyanide
447
4,260,538
6R.
Alkaline
Treatment
With
Cyanide
Rinse
529
43,781,206
7
Alkaline
Treatment
Without
Cyanide
16,200
276,426,070
7R.
Alkaline
Treatment
Without
Cyanide
Rinse
12,937
4,782,461,104
8
Anodizing
With
Chromium
275
271,552
8R.
Anodizing
With
Chromium
Rinse
358
145,962,877
9
Anodizing
Without
Chromium
1,090
5,430,253
9R.
Anodizing
Without
Chromium
Rinse
1,587
1,303,183,805
10
Aqueous
Degreasing
41,220
669,348,451
10R.
Aqueous
Degreasing
Rinse
28,923
517,175,686
11
Assembly/
Disassembly
2,031
18,107,602
11R.
Assembly/
Disassembly
Rinse
2,189
796,489
12
Barrel
Finishing
14,632
640,037,840
12R.
Barrel
Finishing
Rinse
6,694
539,294,744
13
Burnishing
4,920
132,891,318
13R.
Burnishing
Rinse
2,881
326,955,097
14
Chemical
Conversion
Coating
Without
Chromium
9,357
564,137,211
4­
36
4.0
­
Industry
Description
Table
4­
5
(
Continued)

Survey
Unit
Operation
Number
Unit
Operation
Estimated
Number
of
MP&
M
Facilities
Discharging
Wastewater
from
Unit
Operation
Estimated
Annual
Dischargeb
(
gpy)

14R.
Chemical
Conversion
Coating
Without
Chromium
Rinse
11,582
6,042,069,830
15
Chemical
Milling
1,466
41,355,172
15R.
Chemical
Milling
Rinse
2,323
645,522,600
16
Chromate
Conversion
Coating
5,071
54,795,746
16R.
Chromate
Conversion
Coating
Rinse
5,980
1,707,025,516
17
Corrosion
Preventive
Coating
2,262
41,326,563
17R.
Corrosion
Preventive
Coating
Rinse
1,015
287,465,378
18
Electrical
Discharge
Machining
1,323
934,885
18R.
Electrical
Discharge
Machining
Rinse
559
3,368,479
19
Electrochemical
Machining
294
329,427,414
19R.
Electrochemical
Machining
Rinse
258
34,587,020
20
Electroless
Plating
2,583
18,034,222
20R.
Electroless
Plating
Rinse
3,664
565,437,766
21
Electrolytic
Cleaning
5,280
33,756,614
21R.
Electrolytic
Cleaning
Rinse
6,886
1,501,249,740
22
Electroplating
With
Chromium
1,019
37,242,632
22R.
Electroplating
With
Chromium
Rinse
1,937
678,282,897
23
Electroplating
With
Cyanide
1,958
38,162,499
23R.
Electroplating
With
Cyanide
Rinse
8,885
686,691,868
24
Electroplating
Without
Chromium
or
Cyanide
4,558
92,968,816
24R.
Electroplating
Without
Chromium
or
Cyanide
Rinse
13,644
3,778,033,165
25
Electropolishing
442
633,484
25R.
Electropolishing
Rinse
458
70,178,477
26
Floor
Cleaning
49,002
797,062,121
26R.
Floor
Cleaning
Rinse
3,580
45,391,545
27
Grinding
8,738
169,740,183
27R.
Grinding
Rinse
263
72,465,147
28
Heat
Treating
1,609
156,660,147
28R.
Heat
Treating
Rinse
1,315
2,186,067,713
29
Impact
Deformation
404
40,582,591
29R.
Impact
Deformation
Rinse
148
8,237,308
30
Machining
16,935
585,628,906
4­
37
4.0
­
Industry
Description
Table
4­
5
(
Continued)

Survey
Unit
Operation
Number
Unit
Operation
Estimated
Number
of
MP&
M
Facilities
Discharging
Wastewater
from
Unit
Operation
Estimated
Annual
Dischargeb
(
gpy)

30R.
Machining
Rinse
683
149,922,705
31
Metal
Spraying
91
866,823,774
32
Painting
­
Spray
or
Brush
2,303
3,009,847,635
32R.
Painting
­
Spray
or
Brush
Rinse
688
726,589,166
33
Painting
­
Immersion
450
164,139,746
33R.
Painting
­
Immersion
Rinse
404
190,487,578
34
Plasma
Arc
Machining
547
10,728,876
35
Polishing
1,111
113,097,868
35R.
Polishing
Rinse
2,745
567,887,844
36
Pressure
Deformation
520
241,040,874
36R.
Pressure
Deformation
Rinse
249
783,831,607
37
Salt
Bath
Descaling
99
62,703
37R.
Salt
Bath
Descaling
Rinse
111
53,938,360
38
Soldering/
Brazing
1,258
425,688,291
38R.
Soldering/
Brazing
Rinse
4,905
231,488,012
39
Solvent
Degreasingc
2,288
8,128,901
39R.
Solvent
Degreasing
Rinse
824
108,089,561
40
Stripping
(
paint)
1,730
68,326,631
40R.
Stripping
(
paint)
Rinse
2,720
295,059,493
41
Stripping
(
metallic
coating)
2,929
5,855,277
41R.
Stripping
(
metallic
coating)
Rinse
3,867
943,853,805
42
Testing
5,947
3,713,880,058
42R.
Testing
Rinse
1,093
46,615,860
43
Thermal
Cutting
228
35,395,401
43R.
Thermal
Cutting
Rinse
64
2,940,934
44
Washing
Finished
Products
17,276
1,975,525,613
44R.
Washing
Finished
Products
Rinse
5,378
651,385,578
45
Welding
1,003
1,177,301,469
45R.
Welding
Rinse
360
44,297,886
46AA
Wet
Air
Pollution
Control
for
Acid
Alkaline
Baths
2,726
1,335,631,480
46CN
Wet
Air
Pollution
Control
for
Cyanide
Baths
189
43,321,771
46CR
Wet
Air
Pollution
Control
for
Chromium­
Bearing
Baths
942
234,814,961
4­
38
4.0
­
Industry
Description
Table
4­
5
(
Continued)

Survey
Unit
Operation
Number
Unit
Operation
Estimated
Number
of
MP&
M
Facilities
Discharging
Wastewater
from
Unit
Operation
Estimated
Annual
Dischargeb
(
gpy)

46FD
Wet
Air
Pollution
Control
for
Fumes
and
Dusts
657
30,596,886
46OR
Wet
Air
Pollution
Control
for
Organic
Constituents
347
19,613,181
50
Carbon
Black
Deposition
20
31,848
50R.
Carbon
Black
Deposition
Rinse
43
2,377,389
51
Bilge
Water
11
69,949,548
51R.
Bilge
Water
Rinse
8
304,839
54R.
Galvanizing/
Hot
Dip
Coating
Rinse
69
225,928,671
56
Mechanical
Plating
246
27,717,634
56R.
Mechanical
Plating
Rinse
240
202,002,940
57
Photo
Image
Developing
1,456
430,595,569
57R.
Photo
Image
Developing
Rinse
1,531
603,943,807
58
Photo
Imaging
9
27,900
58R.
Photo
Imaging
Rinse
9
497,022
59
Photoresist
Applications
15
7,157
59R.
Photoresist
Applications
Rinse
17
180,161
62
Solder
Flux
Cleaning
99
1,694,799
62R.
Solder
Flux
Cleaning
Rinse
461
214,927,721
63
Solder
Fusing
27
5,739,846
63R.
Solder
Fusing
Rinse
280
55,114,403
65
Steam
Cleaning
26
18,130,100
65R.
Steam
Cleaning
Rinse
16
15,851,628
66
Vacuum
Impregnation
8
649,893
66R.
Vacuum
Impregnation
Rinse
98
10,144,137
70
Kerfing
30
7,429,800
71
Adhesive
Bonding
186
525,950
72
Calibration
55
2,467
73R.
Cyanide
Rinsing
Rinse
22
33,490
74
Hot
Dip
Coating
9
692
74R.
Hot
Dip
Coating
Rinse
75
28,135,640
76
Thermal
Infusion
62
138,939
78
Phosphor
Deposition
11
4,283
78R.
Phosphor
Deposition
Rinse
11
42,826
80
Chromium
Drag­
out
Reduction
8
857,994
4­
39
4.0
­
Industry
Description
Table
4­
5
(
Continued)

Survey
Unit
Operation
Number
Unit
Operation
Estimated
Number
of
MP&
M
Facilities
Discharging
Wastewater
from
Unit
Operation
Estimated
Annual
Dischargeb
(
gpy)

83
Acid
Pickling
Neutralization
8
22,761
83R.
Acid
Pickling
Neutralization
Rinse
16
22,497,118
87
Tin
Catalyst
385
295,415
87R.
Tin
Catalyst
Rinse
468
102,883,125
88
Catalyst
Acid
Pre­
Dip
961
680,949
88R.
Catalyst
Acid
Pre­
Dip
Rinse
1,108
64,173,379
90
Photoresist
Strip
439
8,039,179
90R.
Photoresist
Strip
Rinse
732
312,703,073
Source:
MP&
M
Survey
Database.
a
EPA
used
MP&
M
survey
information
to
generate
the
estimated
facility
counts
and
estimated
annual
discharge.
b
These
totals
do
not
include
facilities
generating
process
wastewater
that
is
contract
hauled
off
site
or
not
discharged.
c
Solvent
degreasing
operations
that
use
process
water
are
included
under
alkaline
treatment
(
see
unit
operation
5).

4­
40
4.0
­
Industry
Description
4.3
Trends
in
the
Industry
To
develop
the
MP&
M
rule,
EPA
collected
data
from
the
MP&
M
industry
for
over
10
years,
including
detailed
information
from
surveys
in
1990,
1996,
and
1997.
Survey
data
and
results
of
industry
site
visits
and
sampling
episodes
showed
numerous
changes
in
the
industry
between
1990
and
1996.
Survey
data
indicate
a
greater
than
30­
percent
industry
increase
in
the
use
of
wastewater
treatment
systems
between
1990
and
1996.
Many
facilities
also
have
begun
to
implement
advanced
treatment
systems
that
include
ultrafiltration
for
increased
organic
pollutant
removal
and
microfiltration
units
to
improve
clarification.
The
MP&
M
survey
database
indicates
that
in
1990,
260
of
the
MP&
M
facilities
with
wastewater
treatment
in
place
were
using
membrane
filtration.
By
1996,
that
number
increased
to
700.
In
addition,
facilities
are
moving
toward
greater
implementation
of
pollution
prevention
and
water
reduction,
including
progression
to
zero
discharge
when
possible.
Fifty­
three
percent
currently
have
in­
process
pollution
prevention
or
water
use
reduction
practices
in
place,
and
over
27
percent
of
discharging
facilities
report
having
wet
unit
operations
with
zero
discharge.
Improvements
in
treatment
controls
are
allowing
for
more
automated
process
controls,
which
leads
to
more
consistent
wastewater
treatment.
Advances
in
wastewater
treatment
chemicals
also
result
in
higher
treatment
efficiencies.

4.4
References
1.
Cubberly,
William
H.
(
ed.).
Tool
and
Manufacturing
Engineers
Handbook
,
Desk
Edition.
Society
of
Manufacturing
Engineers,
Dearborne,
MI,
1989.

2.
Detrisac,
M.
Arthur.
"
Treatable
Cleaners,"
Metal
Finishing
.
September
1991.

3.
U.
S.
Environmental
Protection
Agency.
Development
Document
for
Effluent
Limitations
Guidelines
and
Standards
for
the
Metal
Finishing
Point
Source
Category
.
EPA
440/
1­
83/
091,
June
1983.

4.
Mohler,
J.
B.
"
Alkaline
Cleaning
for
Electroplating,"
Metal
Finishing
.
September
1984.

5.
Wood,
William
G.
(
Coordinator).
The
New
Metals
Handbook
,
Vol.
5.
Surface
Cleaning,
Finishing,
and
Coating.
American
Society
for
Metals,
May
1990.

6.
Lowenheim,
Frederick
A.
Electroplating
Fundamentals
of
Surface
Finishing
.
McGraw­
Hill
Book
Company,
New
York,
NY,
1978.

7.
Murphy,
Michael
(
ed.).
Metal
Finishing
Guidebook
and
Directory
Issue
'
93
,
Metal
Finishing.
January
1993.

4­
41
