10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
10.0
LIMITATIONS
AND
STANDARDS:
DATA
SELECTION
AND
CALCULATION
This
section
describes
the
data
sources,
data
selection,
data
conventions,
and
statistical
methodology
used
by
EPA
in
calculating
the
long­
term
averages,
variability
factors,
and
daily
maximum
limitations.
The
effluent
limitations
and
standards1
are
based
on
long­
term
average
effluent
values
and
variability
factors
that
account
for
variation
in
treatment
performance
within
a
particular
treatment
technology
over
time.
As
explained
in
the
preamble
to
the
rule,
EPA
is
promulgating
daily
maximum
limitations
only
for
the
Oily
Wastes
Subcategory.
This
section
describes
the
data
selection
and
calculations
for
the
daily
maximum
limitations
for
total
suspended
solids
(
TSS)
and
oil
and
grease
measured
as
n­
hexane
extractable
material
(
O&
G).

Section
10.1
gives
a
brief
overview
of
data
sources
(
a
more
detailed
discussion
is
provided
in
Chapter
3)
and
describes
EPA s
evaluation
and
selection
of
episode
data
sets
that
are
the
basis
of
the
limitations.
Section
10.2
provides
a
more
detailed
discussion
of
the
selection
of
the
episodes
and
data
for
each
pollutant.
Section
10.3
presents
the
procedures
for
data
aggregation.
Section
10.4
provides
an
overview
of
the
daily
maximum
limitations.
Section
10.5
describes
the
procedures
for
and
summary
of
the
estimation
of
long­
term
averages,
variability
factors,
and
limitations.
Section
10.6
presents
an
evaluation
of
the
limitations.

10.1
Overview
of
Data
Selection
To
develop
the
long­
term
averages,
variability
factors,
and
limitations,
EPA
used
concentration
data
from
facilities
with
the
Option
6
technology
in
the
Oily
Wastes
Subcategory.
These
data
were
collected
from
two
sources,
EPA s
sampling
episodes
and
self­
monitoring
data.

All
sampling
episodes
were
conducted
using
the
EPA
sampling
and
chemical
analysis
protocols
as
described
in
Section
3.3.
Sampling
episode
reports
maintained
in
the
rulemaking
record
present
the
data
collected
during
each
sampling
episode.

In
comments
on
the
proposal
and
from
other
sources,
EPA
received
compliance
monitoring
data
from
industry.
These
data
are
sometimes
referred
to
as
 
Discharge
Monitoring
Report 
(
DMR)
or
self­
monitoring
data.
EPA
denoted
these
data
with
a
 
D 
appended
to
the
4­
digit
episode
identifier,
the
same
4­
digit
number
used
for
EPA
sampling
data
at
that
facility.
In
the
statistical
analyses,
the
self­
monitoring
data
are
treated
separately
from
the
EPA
sampling
data.
This
practice
is
consistent
with
other
guidelines
and
is
used
because
the
data
tend
to
be
associated
with
different
time
periods
and/
or
analytical
methods
than
EPA
sampling
data.

Following
the
2001
proposal
and
2002
NODA,
EPA
received
many
comments
on
its
selection
of
facilities
and
datasets
used
as
the
basis
of
its
limitations.
In
response
to
these
comments,
EPA
revisited
its
selection
of
facilities
operating
the
Option
6
technology
in
the
Oily
Wastes
Subcategory.
As
discussed
in
Section
10.2,
for
the
episode
datasets
that
were
used
to
1In
the
remainder
of
this
chapter,
references
to
 
limitations 
includes
 
standards. 

10­
1
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
develop
the
final
MP&
M
limitations,
EPA
performed
a
detailed
review
of
the
data
and
all
supporting
documentation
accompanying
the
data.
This
was
done
to
ensure
that
the
selected
data
represent
a
facility s
normal
operating
conditions
and
that
the
data
accurately
reflect
the
performance
expected
by
the
production
method
and
treatment
systems.
Thus,
EPA
evaluated
whether
the
data
were
collected
while
a
facility
was
experiencing
exceptional
incidents
(
upsets).

EPA
also
examined
the
range
of
unit
operations
covered
by
the
facilities.
As
part
of
its
detailed
review,
EPA
verified
that
it
had
selected
facilities
that
generated
wastewater
that
encompassed
the
unit
operations
that
generated
the
most
concentrated
types
of
wastewater
in
the
Oily
Wastes
Subcategory.
(
Section
IV.
A.
3.6
of
the
preamble
to
the
final
rule
identifies
the
unit
operations
in
the
Oily
Wastes
Subcategory.)

In
evaluating
the
data
for
the
rule,
EPA
relied
on
two
major
sources
of
data:
sampling
episode
reports
and
data
review
narratives.

The
sampling
episode
report
(
SER)
describes
the
collection,
analysis,
and
results
of
EPA s
comprehensive
sampling
at
a
facility
in
support
of
effluent
guidelines
rulemakings.
Each
SER
presents
a
general
overview
of
facility
operations,
includes
process
diagrams
of
treatment
operations,
summarizes
the
sample
fractions
collected
for
each
sample
point,
describes
any
deviations
from
the
sampling
and
analysis
plan,
provides
flow
and
production
information,
and
lists
the
analytical
data
results.
SERs
are
located
in
Sections
5.2
and
15.3
of
the
record.

The
data
review
narratives
(
DRNs)
present
an
assessment
of
the
quality
of
the
analytical
(
chemical)
data,
based
upon
a
five­
stage
review
process.
The
DRNs
are
included
as
an
attachment
to
each
SER.
Because
the
data
are
the
basis
of
the
limitations,
EPA
determined
that
an
additional
evaluation
of
the
laboratory
submissions
was
appropriate.
As
a
result
of
that
evaluation,
EPA
confirmed
that
its
previous
determinations
were
appropriate
for
the
TSS
data
and
most
oil
and
grease
data.
As
explained
in
Section
10.2,
EPA
excluded
some
oil
and
grease
data
as
a
result
of
the
evaluation.
(
See
DCN
36500
in
Section
28.5
of
the
record
for
a
summary
of
the
evaluation.)

10.2
Episode
and
Data
Selection
This
section
describes
the
episodes
selected
for
EPA s
evaluations
of
the
technology
option
for
the
Oily
Wastes
Subcategory.
Table
10­
1
summarizes
the
episode
and
sample
point
selections,
and
Table
10­
2
identifies
the
unit
operations
for
each
facility.

10­
2
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
10­
3
Table
10­
1
Oily
Wastes
Subcategory
Oil/
Water
Separation
Episode
No.
Treatment
Type
(
specific
information
on
treatment
from
LTA
folders,
batch
vs.
continuous)
1,2
Discharger
Type
(
indirect/

direct)
Type
of
Data
(
EPA
sampling,
industry
sampling
episode,

comment
data)
Influent
Sampling
Point
Effluent
Sampling
Point
Number
of
Effluent
Data
Points
4471
Process:
Eq,
skim,
CE,
O/
W,
CPT,
sed
Batch
vs.
Cont:
continuous
Additives:
H2SO4,
ferric
chloride,
lime,
polymer
Targets:
unspecified
Flow:
unspecified
Indirect
EPA
sampling
SP­
1
SP­
5
4
4851
Process:
API,
eq,
CE,
skim
Batch
vs.
Cont:
continuous
Additives:
CO2,
aluminum
chloride
Targets:
Oil
and
grease,
metals,
organics
Flow:
9,900­
12,000
gph
during
sampling
Indirect
EPA
sampling
SP­
11
SP­
13
5
4872
Process:
CE,
O/
W,
oil
cooking
Batch
vs.
Cont:
batch
Additives:
H2SO4,
NaOH,
alum,
polymer
Targets:
Oil
and
grease
Flow:
design
max
433,000
gal/
batch
×
2
batches/
day;

during
sampling
433,133
gal/
batch
×
1
batch/
day
Indirect
EPA
sampling
SP­
4
SP­
5
3
4872D
Same
as
above
Indirect
Industry­
supplied
DMR
data
N/
A
SP­
5
4
4876
Process:
CE,
O/
W,
gravity
flot,
DAF,
oil
cooking
Batch
vs.
Cont:
batch
Additives:
polymer,
alum,
NaOH,
H2SO4
Targets:
Oil
and
grease,
TSS
Flow:
152,000
gpd
Indirect
EPA
sampling
SP­
4
SP­
5
5
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
Table
10­
1
(
Continued)

Episode
No.
Treatment
Type
(
specific
information
on
treatment
from
LTA
folders,
batch
vs.
continuous)
1,2
Discharger
Type
(
indirect/

direct)
Type
of
Data
(
EPA
sampling,
industry
sampling
episode,

comment
data)
Influent
Sampling
Point
Effluent
Sampling
Point
Number
of
Effluent
Data
Points
4877
Process:
Eq,
CE,
O/
W,
oil
cooking
Batch
vs.
Cont:
batch
Additives:
polymer,
alum,
NaOH,
H2SO4,
floc
Targets:
unspecified
Flow:
100,000­
200,000
gpd
Indirect
EPA
sampling
SP­
4
SP­
5
5
1Process
abbreviations:

API
=
API
separator
CE
=
chemical
emulsion
breaking
CPT
=
chemical
precipitation
DAF
=
dissolved
air
flotation
Eq
=
flow
equalization
Gravity
flot
=
gravity
flotation
O/
W
=
oil/
water
separation
Sed
=
sedimentation
Skim
=
oil
skimmer
2Treatment
units
or
additives
represented
by
the
sampling
points
are
in
bold.

10­
4
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
Table
10­
2
Unit
Operations
at
Each
Episode
Unit
Operation
Description
4471
4851a
4872/
4872Db
4876
4877
01
Abrasive
Blasting
dry
dry
X
05
Alkaline
Cleaning
for
Oil
Removal
X
X
X
X
07
Alkaline
Treatment
Without
Cyanide
10
Aqueous
Degreasing
X
dry
X
11
Assembly/
Disassembly
dry
X
dry
X
dry
12
Barrel
Finishing
13
Burnishing
17
Corrosion
Preventative
Coating
X
18
Electrical
Discharge
Machining
26
Floor
Cleaning
X
X
X
X
27
Grinding
X
X
X
X
28
Heat
Treating
X
zero
29
Impact
Deformation
dry
X
X
30
Machining
X
X
X
X
X
32
Painting
(
Spray
or
Brush)
X
dry
zero
zero
35
Polishing
X
36
Pressure
Deformation
39
Solvent
Degreasing
X
42
Testing
(
Such
as
Hydrostatic,
Dye
Penetrant,
Ultrasonic,
Magnetic
Flux)
X
X
X
X
43
Thermal
Cutting
44
Washing
of
Final
Products
X
X
45
Welding
dry
dry
dry
46OR
Wet
Air
Pollution
Control
of
Organic
Constituents
zero
X
65
Steam
Cleaning
71
Adhesive
Bonding
72
Calibration
Iron
Phosphate
Conversion
Coating
X
a4851
also
performs
chromium
and
nickel
electroplating
(
nonoily
operations)
where
the
wastes
are
contract
hauled
and
plasma
arc
machining
(
a
nonoily
operation)
but
never
discharged
to
the
water
table.
b4872
also
has
manganese
phosphate
coating
and
leaking
hydraulic
oil
from
machines.

10­
5
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
As
a
first
step,
EPA
reviewed
all
of
its
data
from
facilities
with
the
Option
6
treatment
in
the
Oily
Wastes
Subcategory.
Table
10­
1
identifies
all
of
the
episodes
with
Oily
Wastes
Subcategory
oil/
water
separation
treatability
data
in
EPA s
database.
EPA
has
data
from
six
different
sampling
episodes:
five
are
EPA
sampling
episodes
(
4471,
4851,
4872,
4876,
4877)
and
one
is
industry­
supplied
DMR
data
(
4872D).
For
the
final
rule,
EPA
based
the
oil
and
grease
limitations
on
the
data
from
Episodes
4872,
4872D,
and
4877
and
the
TSS
limitation
on
the
data
from
Episode
4851.
The
following
describes
EPA s
evaluation
of
each
of
the
six
episodes
and
its
decisions
to
include
or
exclude
the
data.
As
shown
in
Table
10­
2,
these
episodes
encompass
a
variety
of
unit
operations
included
in
the
Oily
Wastes
Subcategory.

Episode
4471
was
conducted
at
a
facility
that
manufactured
magnum
tractors
for
the
farming
industry.
The
facility s
primary
water­
using
unit
operations
included
alkaline
cleaning,
grinding,
heat
treating,
painting,
and
testing
of
the
finished
product.
Episode
4471
operated
chemical
precipitation
and
sedimentation
following
the
Option
6
technology.
Consequently,
the
facility
did
not
need
to
rely
on
the
Option
6
technology
alone
to
meet
any
discharge
requirements,
and
most
likely
optimized
oil
and
grease
and
TSS
removals
following
during
the
chemical
precipitation
and
solids
separation
step.
Consequently,
its
Option
6
technology
performance
had
removal
rates
of
only
31
percent
for
TSS
and
42
percent
for
oil
and
grease
during
the
sampling
episode.
In
contrast,
the
other
facilities
had
removal
rates
of
over
90
percent
for
TSS
and
oil
and
grease
using
the
Option
6
technology.
In
addition,
EPA
measured
oil
and
grease
using
a
freon
method,
rather
than
a
hexane
extractable
method
used
for
the
other
episodes.
As
explained
in
the
NODA,
the
sampling
data
in
Phase
1
(
this
includes
Episode
4471)
had
been
analyzed
by
EPA
Method
413.2,
a
method
utilizing
freon
that
was
unlikely
to
produce
comparable
results
to
methods
approved
under
40
CFR
136
(
such
as
EPA
Method
413.1).
Thus,
EPA
did
not
use
these
data
in
determining
the
final
daily
maximum
oil
and
grease
limitation,
because
the
facility
had
not
optimized
its
Option
6
technology
(
because
it
did
not
need
to
do
so)
and
the
oil
and
grease
data
were
not
measured
by
a
method
comparable
to
those
approved
at
40
CFR
136.

Episode
4851
was
conducted
at
a
facility
that
repaired
and
manufactured
locomotives.
The
facility s
primary
water­
using
unit
operations
included
alkaline
cleaning,
machining,
and
testing
of
the
finished
product.
Episode
4851
operated
the
Option
6
technology
and
was
used
as
the
basis
of
the
final
TSS
daily
maximum
limitation
because
this
facility
had
the
highest
concentrations
of
TSS
in
the
influent
(
except
for
Episode
4876,
which
EPA
excluded
as
explained
below).
Episode
4851'
s
average
influent
TSS
concentration
was
833
mg/
L
compared
to
the
next
highest
TSS
influent
average
of
219
mg/
L
at
Episode
4872.
Although
this
facility,
on
average,
had
concentrated
TSS
influent,
it
also
had
the
lowest
daily
value
for
TSS
in
the
influent
that
EPA
observed
in
its
sampling
of
facilities
in
this
subcategory.
Because
EPA
was
concerned
that
this
value
might
not
represent
normal
operations
for
a
facility
that
normally
has
concentrated
TSS
in
its
influent,
it
excluded
this
one
value
from
its
calculations
of
the
limitation.
In
addition,
EPA
excluded
all
of
the
oil
and
grease
effluent
data
based
upon
a
review
of
the
laboratory
reports.
Over
the
five­
day
period
for
the
sampling
episode,
EPA
collected
36
oil
and
grease
samples
at
the
effluent
sample
point.
One
sample
(
36240)
broke
and
thus
was
not
analyzed.
For
31
other
samples
(
36232­
36239,
36241­
36263),
when
EPA
performed
a
final
review
of
the
10­
6
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
laboratory
reports,
it
realized
that
the
ongoing
precision
recoveries
(
OPR)
were
below
the
acceptable
range
of
79­
144
percent
that
is
specified
in
Method
1664.
For
the
four
remaining
samples
(
36264­
36267),
EPA
considered
these
values
to
be
 
minimum
values 
because
the
matrix
spike
and
its
matrix
sample
duplicate
(
MS/
MSD)
recoveries
were
outside
of
the
criteria
in
the
method.
For
these
reasons,
EPA
excluded
the
oil
and
grease
data
from
Episode
4851.

Episodes
4872
and
4872D
are
from
a
facility
that
manufactured
automotive
parts,
including
axles,
shafts,
tubes,
housings,
and
transmission
gear
sets.
The
facility s
unit
operations
included
machining,
polishing,
impact
deformation
(
punch
pressing),
heat
treatment
(
carburizing
and
tempering),
and
washing
of
the
components.
The
facility
also
performed
manganese
phosphate
coating
and
painting
operations.
In
general,
based
on
information
obtained
from
episode
4872,
the
facility
generated
approximately
70
percent
of
the
daily
process
wastewater
from
21
aqueous
parts
washers,
and
approximately
30
percent
from
14
machining
operations
containing
a
5­
percent
solution
of
machining
coolant.
Less
than
1
percent
of
the
wastewater
flow
was
generated
from
minor
water­
producing
operations,
including
the
paint
booth
water
curtain,
the
manganese
phosphate
coating
operation,
heat
treatment,
and
leaking
hydraulic
oil
from
machines
(
tramp
oil).
Because
this
facility
also
commingles
wastewater
generated
by
CFR
433
operations
(
i.
e.,
manganese
phosphate
coating)
with
wastewater
generated
by
oily
waste
operations,
it
would
be
subject
to
433
rather
than
4382
.
However,
EPA
determined
it
was
appropriate
to
retain
this
facility
in
its
Part
438
limitations
calculations
because
the
commingled
wastewater
from
this
facility
largely
comprises
wastewater
generated
from
oily
waste
operations
(>
99
percent).
Furthermore,
EPA
compared
the
influent
concentrations
of
the
regulated
parameters
at
this
facility
with
those
at
other
oily
waste
facilities
and
found
them
to
be
comparable.

During
the
time
periods
of
these
episodes,
this
facility
operated
the
Option
6
technology
to
treat
its
wastewater.
As
noted
in
Section
10.1,
EPA
has
treated
its
self­
monitoring
data
separately
from
the
EPA
sampling
data.
The
data
for
the
two
episodes
were
collected
about
two
years
apart
(
1997
for
the
sampling
episode
and
1999
for
the
self­
monitoring
episode).
EPA
expects
that
some
changes
in
process,
production
mix,
volume
of
production,
and
wastewater
treatment
systems
were
likely
to
have
occurred
during
the
two­
year
period
and
has
used
the
data
as
if
they
were
from
two
different
facilities.
EPA
also
notes
that
the
ranges
of
the
daily
oil
and
grease
effluent
concentrations
were
different
for
the
two
episodes,
with
Episode
4872
ranging
from
44.8
to
57.1
mg/
L
and
Episode
4872D
ranging
from
8.6
to
23.6
mg/
L.

For
Episode
4872,
the
treatment
system
consisted
of
a
large
batch
tank
in
which
the
facility
added
emulsion
breaking
chemicals
and
then
allowed
the
oil
to
separate
from
the
water.
The
facility
then
discharged
the
water
layer
(
i.
e.,
the
lower
layer).
Upon
review
of
the
operating
procedures
for
this
facility,
EPA
determined
that
the
approach
used
to
determine
when
to
stop
the
draw­
down
was
based
solely
on
tank
level,
as
opposed
to
being
based
on
any
type
of
measurement.
While
EPA
has
concerns
about
this
approach
and
has
incorporated
costs
in
this
rule
for
an
upgrade
to
remove
the
subjectivity,
EPA
determined
that
the
Episode
4872D
data
2See
438.2(
b)

10­
7
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
demonstrated
that
the
system
can
achieve
low
concentrations
of
oil
and
grease
when
the
treatment
system
is
operated
properly.
For
this
reason,
EPA
has
included
all
but
one
oil
and
grease
value
in
calculating
the
limitation.
EPA
excluded
the
concentration
value
of
25.8
mg/
L
from
the
third
grab
sample
(
38970)
on
Day
1
of
Episode
4872,
because
the
MS/
MSD
percent
recoveries
were
below
the
method
criteria
and
the
value
is
considered
to
be
a
minimum
value.
Because
its
field
duplicate
value
was
reported
with
a
higher
value
of
65.9
mg/
L
and
met
the
criteria
in
the
data
review
guidelines,
the
field
duplicate
value
was
used
in
calculating
the
oil
and
grease
limitation
instead
(
i.
e.,
sample
38970
was
excluded).
EPA
also
considered
excluding
the
data
value
for
the
fourth
grab
sample
(
38971)
on
Day
1,
because
the
MS
percent
recovery
was
below
the
method
criteria
and
the
relative
percent
difference
(
RPD)
between
the
MS
and
its
MSD
also
exceeded
the
method
criteria.
Despite
these
qualifiers,
EPA
decided
to
retain
this
sample
because
it
was
consistent
with
the
value
for
its
field
duplicate
(
105
mg/
L)
which
had
met
the
method
criteria.

Episode
4876
was
conducted
at
a
facility
that
manufactured
engines
for
automobiles
and
light
trucks.
The
primary
wastewater
generating
operations
at
this
facility
included
machining
and
grinding
operations,
which
require
a
water­
based
cutting
fluid.
The
facility
also
performed
alkaline
cleaning
operations.
Episode
4876
treated
its
wastewater
using
a
DAF
system
following
the
Option
6
technology.
When
EPA
reviewed
these
data
in
detail,
it
found
that
the
facility
appeared
to
be
optimizing
its
Option
6
portion
of
the
treatment
technology
for
TSS
removals,
but
not
oil
and
grease.
Because
the
system
was
not
optimized
for
oil
and
grease
removals
(
because
the
facility
additionally
used
the
DAF
system
for
this
purpose),
EPA
excluded
those
data
in
calculating
the
oil
and
grease
limitation.
Although
the
facility
had
a
removal
rate
of
99
percent
for
TSS,
EPA
excluded
the
TSS
effluent
data
values
because
EPA
had
collected
daily
grab
samples
at
this
sample
point,
rather
than
daily
composite
samples
that
EPA
expects
that
facilities
would
use
in
complying
with
the
final
TSS
daily
maximum
limitation3
.
As
explained
in
Section
10.5,
while
it
had
excluded
the
data
from
its
limitation
calculations,
EPA
ultimately
used
these
TSS
data
to
evaluate
the
limitation.

Episode
4877
was
conducted
at
a
facility
that
manufactured
and
assembled
automatic
transmissions
and
chassis
components.
Manufacturing
processes
included
machining,
grinding,
impact
deformation,
abrasive
blasting,
and
aqueous
degreasing
of
the
metal
components.
The
facility
also
performed
painting
operations;
however,
no
wastewater
was
generated
from
painting.
In
general,
the
facility
generated
approximately
75
percent
of
its
process
wastewater
from
60
aqueous
parts
washers
and
20
percent
from
18
machine
coolant
recirculation
filtration
systems
(
hydromation
pits),
containing
a
4­
to
12­
percent
solution
of
coolant
used
for
machining
and
grinding
operations.
Miscellaneous
wastewater
sources
such
as
floor
washing,
leaking
hydraulic
oil,
and
transmission
oil
from
hydrostatic
testing
were
included
in
the
remaining
5
percent
of
the
flow.
This
facility
treated
its
wastewater
using
the
Option
6
technology.
In
calculating
the
limitation,
EPA
excluded
the
oil
and
grease
data
from
the
second
day
because
operation
on
that
day
was
not
representative
of
the
normal
operating
conditions
for
3
This
system
was
a
batch
system
that
discharged
over
the
course
of
24
hours.
EPA
expects
that
facilities
with
this
type
of
system
would
conduct
continuous
compliance
monitoring.

10­
8
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
Option
6
technology.
As
documented
in
the
sampling
episode
report,
on
that
day
only,
the
operator
failed
to
add
the
proper
treatment
chemicals.
EPA
also
reviewed
the
laboratory
reports
and
identified
qualifiers
on
two
of
the
effluent
samples
used
to
calculate
the
oil
and
grease
limitation,
but
has
included
both
results
in
calculating
the
oil
and
grease
limitation.
These
samples
were
the
third
and
fourth
grab
samples
(
39564
and
39565)
collected
on
Day
1
of
the
sampling
episode.
For
both
samples,
the
RPD
between
the
MS
and
its
MSD
exceeded
the
method
criteria.
In
addition,
the
MSD
recovery
was
below
the
method
criteria
for
the
fourth
grab
sample.
In
conjunction
with
those
samples,
EPA
had
collected
field
duplicates.
The
oil
and
grease
limitation
was
calculated
using
daily
values
calculated
from
the
average
of
each
duplicate
pair.
When
EPA
calculated
the
daily
value
with
the
averages
of
each
duplicate
pair
(
see
Section
10.3),
it
found
virtually
no
difference
if
the
qualified
data
were
included
or
excluded.
Because
their
inclusion
results
in
a
minutely
higher
daily
value
for
Day
1,
the
values
for
samples
39564
and
39565
were
included
in
calculating
the
limitations.

10.3
Data
Aggregation
In
developing
the
limitations,
EPA
modeled
daily
data
values
rather
than
individual
sample
measurements.
EPA s
approach
of
aggregating
multiple
analytical
results
to
obtain
a
single
daily
value
is
consistent
with
standard,
conventional
practice
in
environmental
analytical
work.
This
approach
also
gives
one
day's
sampling
information
appropriate
weight
in
determining
effluent
limitations
and
is
consistent
with
requirements
of
NPDES
regulations
at
40
CFR
122
which
define
the
daily
discharge.

In
some
cases,
EPA
mathematically
aggregated
two
or
more
samples
to
obtain
a
single
value
that
could
be
used
in
other
calculations.
This
occurred
with
field
duplicates
and
grab
samples
collected
over
time
to
represent
a
single
waste
stream.
Table
10­
3
lists
these
values.
Table
10­
4
lists
the
influent
and
effluent
data
after
these
aggregations
were
completed
and
a
single
daily
value
was
obtained
for
each
day
for
each
pollutant.

In
all
aggregation
procedures,
EPA
considered
the
censoring
type
associated
with
the
data.
EPA
considered
measured
values
to
be
detected.
In
statistical
terms,
the
censoring
type
for
such
data
was
 
noncensored 
(
NC).
The
Agency
censored
measurements
reported
as
being
less
than
some
sample­
specific
detection
limit
(
e.
g.,
<
10
mg/
L)
and
considered
them
to
be
nondetected
(
ND).
In
the
tables
and
data
listings
in
this
document
and
the
rulemaking
record,
EPA
uses
the
abbreviations
NC
and
ND
to
indicate
the
censoring
types.
The
data
used
as
a
basis
for
the
final
limitations
are
all
NC
and
thus
all
aggregated
results
also
are
considered
to
be
NC.

This
subsection
describes
each
of
the
different
aggregation
procedures.
They
are
presented
in
the
order
that
the
aggregation
was
performed
(
i.
e.,
field
duplicates
were
aggregated
first
and
grab
samples
second).
Table
10­
3
lists
the
effluent
data
before
aggregation
and
Table
10­
4
lists
the
daily
influent
and
effluent
values
after
any
aggregation.

10­
9
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
Table
10­
3
Effluent
Data
Before
Aggregationa
Pollutant
Episode
Sample
Day
Original
Sample
Corresponding
Field
Duplicate
(
if
any)

Concentration
(
mg/
L)
Concentration
(
mg/
L)

Oil
and
Grease
4872
1
23.1
14.4
108.0
50.8
23.3
65.9
105.0
2
89.6
54.5
21.1
14.1
3
33.2
63.1
68.2
57.9
4877
1
25.0
21.0
33.0
20.0
26.0
15.0
20.0
32.0
3
12.0
16.0
10.0
21.0
4
21.0
11.0
24.0
29.0
5
13.0
31.0
8.0
8.0
TSS
4851
1
54.0
26.0
2
40.0
30.0
3
36.0
62.0
aThis
table
includes
only
values
that
were
later
aggregated
with
other
values.
See
Table
10­
4
for
all
daily
values.

10­
10
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
Table
10­
4
Data
After
Aggregation
(
i.
e.,
Daily
Values)

Pollutant
Episode
Sample
Day
Influent
Daily
Value
(
mg/
L)
Effluent
Daily
Value
(
mg/
L)

Oil
and
Grease
4872
1
2
3
696
2182
502
57.050
44.825
55.600
4872D
1
2
3
4
12.100
23.600
15.200
8.640
4877
1
3
4
5
557
997
544
469
24.000
14.750
21.250
15.000
TSS
4851
1
2
3
4
1720
508
373
615
40.000
35.000
49.000
48.000
10.3.1
Aggregation
of
Field
Duplicates
During
its
sampling
episodes,
EPA
collected
field
duplicates
for
quality
control
purposes.
Generally,
10
percent
of
the
number
of
samples
collected
were
duplicated.
Field
duplicates
are
two
samples
collected
for
the
same
sampling
point
at
the
same
time,
assigned
different
sample
numbers,
and
flagged
as
duplicates
for
a
single
sample
point
at
a
facility.
Because
the
analytical
data
from
each
duplicate
pair
characterize
the
same
conditions
at
that
time
at
a
single
sampling
point,
EPA
averaged
the
data
to
obtain
one
value
for
each
duplicate
pair.
This
aggregation
step
for
the
duplicate
pairs
was
the
first
step
in
the
aggregation
procedures.

10.3.2
Aggregation
of
Grab
Samples
During
its
sampling
episodes,
EPA
collected
two
types
of
samples:
grab
and
composite.
For
oil
and
grease,
EPA
collected
four
grab
samples
over
the
course
of
each
day
of
sampling
during
each
sampling
episode.
To
obtain
one
value
characterizing
the
oil
and
grease
levels
at
the
sample
point
on
a
single
day,
EPA
arithmetically
averaged
the
measurements
to
obtain
a
single
value
for
the
day.
In
developing
the
TSS
limitation,
EPA
used
the
concentration
values
of
daily
composite
samples
from
episode
4851,
and
thus,
this
aggregation
step
was
not
necessary.

10­
11
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
10.4
Overview
of
Limitations
The
preceding
subsections
discuss
the
data
selected
as
the
basis
for
the
limitations
and
the
data
aggregation
procedures
EPA
used
to
obtain
daily
values
in
its
calculations.
This
subsection
provides
a
general
overview
of
limitations.

The
oil
and
grease
and
TSS
limitations
are
provided
as
maximum
daily
discharge
limitations.
The
definition
provided
in
40
CFR
122.2
states
that
the
 
maximum
daily
discharge
limitation 
is
the
 
highest
allowable
daily
discharge. 
Daily
discharge
is
defined
as
the
 
discharge
of
a
pollutant
measured
during
a
calendar
day
or
any
24­
hour
period
that
reasonably
represents
the
calendar
day
for
purposes
of
sampling. 

EPA
did
not
establish
monthly
average
limitations
for
oil
and
grease
and
TSS
because
a
monthly
average
limitation
would
be
based
on
the
assumption
that
a
facility
would
be
required
to
monitor
more
frequently
than
once
a
month.
For
the
rule,
EPA
has
determined
that
one
monthly
monitoring
event
is
sufficient;
however,
if
permitting
authorities
choose
to
require
more
frequent
monitoring
for
oil
and
grease
and
TSS,
they
may
set
monthly
average
limitations
and
standards
based
on
their
best
professional
judgement.
(
See,
e.
g.,
40
CFR
430.24(
a)(
1),
footnote
b.)

The
following
three
subsections
describe
EPA s
objective
for
daily
maximum
limitations,
the
selection
of
the
percentile
for
those
limitations,
and
compliance
with
final
limitations.
EPA
has
included
this
discussion
in
Section
10.0
because
these
fundamental
concepts
are
often
the
subject
of
comments
on
EPA s
effluent
guidelines
regulations
and
in
EPA s
contacts
and
correspondence
with
industry.

10.4.1
Objective
In
establishing
daily
maximum
limitations,
EPA s
objective
is
to
restrict
the
discharges
on
a
daily
basis
to
a
level
that
is
achievable
for
a
facility
that
targets
its
treatment
at
the
long­
term
average.
EPA
acknowledges
that
variability
around
the
long­
term
average
results
from
normal
operations.
This
variability
means
that
occasionally
facilities
may
discharge
at
a
level
that
is
lower
than
or
greater
than
the
long­
term
average.
To
allow
for
possibly
higher
daily
discharges,
EPA
has
established
the
daily
maximum
limitation.
A
facility
that
discharges
consistently
at
a
level
near
the
daily
maximum
limitation
would
not
be
operating
its
treatment
system
to
achieve
the
long­
term
average,
which
is
part
of
EPA s
objective
in
establishing
the
daily
maximum
limitations.
That
is,
targeting
treatment
to
achieve
the
limitations
may
result
in
frequent
values
exceeding
the
limitations
due
to
routine
variability
in
treated
effluent.

In
estimating
the
limitations,
EPA
first
determines
an
average
performance
level
(
the
 
option
long­
term
average 
discussed
in
Section
10.5)
that
a
facility
with
well­
designed
and
operated
model
technologies
(
that
reflect
the
appropriate
level
of
control)
is
capable
of
achieving.
This
long­
term
average
is
calculated
from
the
data
from
the
facilities
using
the
model
technologies
for
the
option.
EPA
expects
that
all
facilities
subject
to
the
final
limitations
will
10­
12
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
design
and
operate
their
treatment
systems
to
achieve
the
long­
term
average
performance
level
on
a
consistent
basis
because
facilities
with
well­
designed
and
operated
model
technologies
have
demonstrated
that
this
can
be
done.

Next,
EPA
determines
an
allowance
for
the
variation
in
pollutant
concentrations
when
wastewater
is
processed
through
extensive
and
well­
designed
treatment
systems.
This
allowance
incorporates
all
components
of
variability,
including
shipping,
sampling,
storage,
and
analytical
variability.
This
allowance
is
incorporated
into
the
limitations
through
the
use
of
the
variability
factors
that
EPA
calculated
from
the
data
from
the
facilities
using
the
model
technologies.
If
a
facility
operates
its
treatment
system
to
achieve
the
relevant
option
long­
term
average,
EPA
expects
the
facility
will
be
able
to
comply
with
the
limitations.
Variability
factors
assure
that
normal
fluctuations
in
a
facility s
treatment
are
accounted
for
in
the
limitations.
By
accounting
for
these
reasonable
excursions
above
the
long­
term
average,
EPA s
use
of
variability
factors
results
in
limitations
that
are
generally
well
above
the
actual
long­
term
averages.

EPA
calculates
the
percentile
used
as
a
basis
for
the
daily
maximum
limitation
using
the
product
of
the
long­
term
average
and
the
daily
variability
factor.
The
following
subsection
describes
EPA s
rationale
for
selecting
the
99th
percentile
as
the
basis
for
the
daily
maximum
limitations.

10.4.2
Selection
of
Percentiles
EPA
calculates
limitations
based
upon
percentiles
chosen,
on
one
hand,
to
be
high
enough
to
accommodate
reasonably
anticipated
variability
within
control
of
the
facility
and,
on
the
other
hand,
to
be
low
enough
to
reflect
a
level
of
performance
consistent
with
the
Clean
Water
Act
requirement
that
these
effluent
limitations
be
based
on
the
 
best 
technologies.
The
daily
maximum
limitation
is
an
estimate
of
the
99th
percentile
of
the
distribution
of
the
daily
measurements.

The
99th
percentile
does
not
relate
to,
or
specify,
the
percentage
of
time
a
discharger
operating
the
 
best
available 
or
 
best
available
demonstrated 
level
of
technology
will
meet
(
or
not
meet)
the
limitations.
Rather,
EPA
used
this
percentile
in
developing
the
daily
maximum
limitation.
If
a
facility
is
designed
and
operated
to
achieve
the
long­
term
averages
on
a
consistent
basis
and
the
facility
maintains
adequate
control
of
its
processes
and
treatment
systems,
the
allowance
for
variability
provided
in
the
daily
maximum
limitations
is
sufficient
for
the
facility
to
meet
the
requirements
of
the
rule.
EPA
used
99
percent
to
draw
a
line
at
a
definite
point
in
the
statistical
distributions
(
100
percent
is
not
feasible
because
it
represents
an
infinitely
large
value),
while
setting
the
percentile
at
a
level
that
would
ensure
that
operators
work
hard
to
establish
and
maintain
the
appropriate
level
of
control.
By
targeting
its
treatment
at
the
long­
term
average,
a
well­
operated
facility
should
be
able
to
comply
with
the
limitations
at
all
times
because
EPA
has
incorporated
an
appropriate
allowance
for
variability
into
the
limitations.

In
conjunction
with
the
statistical
methods,
EPA
performs
an
engineering
review
to
verify
that
the
limitations
are
reasonable
based
upon
the
design
and
expected
operation
of
the
10­
13
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
control
technologies
and
the
facility
process
conditions.
As
part
of
that
review,
EPA
examines
the
range
of
performance
by
the
facility
datasets
used
to
calculate
the
limitations.
Some
facility
datasets
demonstrate
the
best
available
technology.
Other
facility
datasets
may
demonstrate
the
same
technology,
but
not
the
best
demonstrated
design
and
operating
conditions
for
that
technology.
For
these
facilities,
EPA
will
evaluate
the
degree
to
which
the
facility
can
upgrade
its
design,
operating,
and
maintenance
conditions
to
meet
the
limitations.
If
such
upgrades
are
not
possible,
then
EPA
will
modify
the
limitations
to
reflect
the
lowest
levels
that
the
technologies
can
reasonably
be
expected
to
achieve.

10.4.3
Compliance
with
Limitations
EPA
promulgates
limitations
with
which
facilities
can
comply
at
all
times
by
properly
operating
and
maintaining
their
processes
and
treatment
technologies.
EPA
uses
a
percentile
of
a
statistical
distribution
in
developing
the
daily
maximum
limitation
because
statistical
methods
provide
a
logical
and
consistent
framework
for
analyzing
a
set
of
effluent
data
and
determining
values
from
the
data
that
form
a
reasonable
basis
for
effluent
limitations.
EPA
establishes
the
limitations
on
the
basis
of
percentiles
estimated
using
data
from
facilities
with
well­
operated
and
controlled
processes
and
treatment
systems.
However,
because
EPA
uses
a
percentile
basis,
the
issue
of
exceedances
(
i.
e.,
values
that
exceed
the
limitations)
or
excursions
is
often
raised
in
public
comments
on
limitations.
For
example,
comments
often
suggest
that
EPA
include
a
provision
that
allows
a
facility
to
be
considered
in
compliance
with
permit
limitations
if
its
discharge
exceeds
the
daily
maximum
limitations
one
day
out
of
100.
This
issue
was,
in
fact,
raised
in
other
rules,
including
EPA s
final
Organic
Chemicals,
Plastics,
and
Synthetic
Fibers
(
OCPSF)
rulemaking.
EPA s
general
approach
there
for
developing
limitations
based
on
percentiles
is
the
same
in
this
rule,
and
was
upheld
in
Chemical
Manufacturers
Association
v.
U.
S.
Environmental
Protection
Agency
,
870
F.
2d
177,
230
(
5th
Cir.
1989).
The
Court
determined
that:

EPA
reasonably
concluded
that
the
data
points
exceeding
the
99th
and
95th
percentiles
represent
either
quality­
control
problems
or
upsets
because
there
can
be
no
other
explanation
for
these
isolated
and
extremely
high
discharges.
If
these
data
points
result
from
quality­
control
problems,
the
exceedances
they
represent
are
within
the
control
of
the
plant.
If,
however,
the
data
points
represent
exceedances
beyond
the
control
of
the
industry,
the
upset
defense
is
available.
Id.
at
230.

As
that
Court
recognized,
EPA s
allowance
for
reasonably
anticipated
variability
in
its
effluent
limitations,
coupled
with
the
availability
of
the
upset
defense,
reasonably
accommodates
acceptable
excursions.
Any
further
excursion
allowances
would
go
beyond
the
reasonable
accommodation
of
variability
and
would
jeopardize
the
effective
control
of
pollutant
discharges
on
a
consistent
basis
and/
or
bog
down
administrative
and
enforcement
proceedings
in
detailed
fact­
finding
exercises,
contrary
to
Congressional
intent.
See,
as
an
example,
Rep.
No.

10­
14
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
92­
414,
92d
Congress,
2d
Sess.
64,
reprinted
in
A
Legislative
History
of
the
Water
Pollution
Control
Act
Amendments
of
1972
at
1482;
Legislative
History
of
the
Clean
Water
Act
of
1977
at
464­
65.

EPA
expects
that
facilities
will
comply
with
promulgated
limitations
at
all
times.
If
an
exceedance
is
caused
by
an
upset
condition,
the
facility
would
have
an
affirmative
defense
to
an
enforcement
action
if
the
requirements
of
40
CFR
122.41(
n)
are
met.
If
the
exceedance
is
caused
by
a
design
or
operational
deficiency,
then
EPA
has
determined
that
the
facility s
performance
does
not
represent
the
appropriate
level
of
control.
For
promulgated
limitations
and
standards,
EPA
has
determined
that
such
exceedances
can
be
controlled
by
diligent
process
and
wastewater
treatment
system
operational
practices
such
as
frequent
inspection
and
repair
of
equipment,
use
of
back­
up
systems,
and
operator
training
and
performance
evaluations.

EPA
recognizes
that,
as
a
result
of
the
rule,
some
dischargers
may
need
to
improve
treatment
systems,
process
controls,
and/
or
treatment
system
operations
in
order
to
consistently
meet
the
effluent
limitations.
EPA
believes
that
this
consequence
is
consistent
with
the
Clean
Water
Act
statutory
framework,
which
requires
that
discharge
limitations
reflect
the
best
technology.

10.5
Calculation
of
the
Limitations
This
section
discusses
the
calculation
of
the
daily
maximum
limitations
for
TSS
and
oil
and
grease.

First,
EPA
calculated
the
episode
long­
term
average
and
daily
variability
factor
by
using
the
modified
delta­
lognormal
distribution
(
see
Appendix
E).
Table
10­
5
lists
these
episode­
specific
values.

Table
10­
5
Episode
Long­
Term
Averages
and
Daily
Variability
Factors
Pollutant
Episode
Episode
Long­
Term
Average
(
mg/
L)
Episode
Daily
Variability
Factor
Oil
and
grease
4872
52.6533
1.3489
4872D
15.2101
2.4403
4877
18.8921
1.7203
TSS
4851
43.1442
1.4312
Second,
EPA
calculated
the
option
long­
term
average
for
a
pollutant
as
the
median
of
the
episode­
specific
long­
term
averages
for
that
pollutant.
The
median
is
the
midpoint
of
the
values
ordered
(
i.
e.,
ranked)
from
smallest
to
largest.
For
oil
and
grease,
when
the
three
10­
15
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
episode
long­
term
averages
are
ordered,
this
midpoint
value
is
18.89
mg/
L
from
Episode
4877.
For
TSS,
this
midpoint
value
is
the
same
as
the
episode
long­
term
average
from
Episode
4851.

Third,
EPA
selected
the
option
daily
variability
factor.
For
oil
and
grease,
EPA
used
the
self­
monitoring
data,
Episode
4872D,
as
the
basis
of
the
option
daily
variability
factor.
In
the
proposal
and
NODA,
when
EPA
used
multiple
episodes
as
the
basis
of
a
limitation,
it
used
the
mean
of
the
episode
daily
variability
factors.
That
practice
was
consistent
with
EPA s
development
of
limitations
for
other
industries.
However,
for
this
pollutant
in
this
subcategory,
EPA
has
determined
that
it
is
appropriate
to
deviate
from
its
normal
practice,
because
each
of
the
self­
monitoring
measurements
were
obtained
several
months
apart
(
i.
e.,
2/
23/
99,
4/
29/
99,
8/
11/
99,
and
10/
28/
99).
As
explained
in
the
NODA,
EPA
intended
to
investigate
whether
autocorrelation
was
likely
to
be
present
in
the
data.
When
data
are
positively
autocorrelated,
it
means
that
measurements
taken
at
specific
time
intervals
(
such
as
1
day
or
2
days
apart)
are
related.
To
determine
autocorrelation
in
the
data,
many
measurements
for
each
pollutant
would
be
required
with
values
for
every
single
day
over
an
extended
period
of
time.
Despite
its
requests
to
industry,
the
data
were
not
made
available
to
EPA
for
Option
6
oily
wastes
effluent.
However,
by
selecting
the
self­
monitoring
data,
each
measured
several
months
apart,
as
the
basis
of
the
option
daily
variability
factor,
EPA
has
avoided
the
possibility
of
autocorrelation
existing
in
the
data
used
as
a
basis
of
the
option
daily
variability
factor
for
oil
and
grease.
For
TSS,
the
option
daily
variability
factor
is
the
same
as
the
episode
daily
variability
factor
from
Episode
4851,
because
EPA
used
the
data
from
that
facility
as
the
basis
for
the
limitation
as
explained
in
Section
10.2.
While
autocorrelation
might
exist
in
the
Episode
4851
data,
EPA
selected
a
facility
with
high
concentrations
of
TSS
in
the
influent
as
the
basis
of
the
option
daily
variability
factor.
EPA
notes
that
no
facilities
with
the
Option
6
technology
with
similar
high
concentrations
of
TSS
influents
provided
any
daily
measurements
of
TSS
effluent
concentrations.
From
the
information
that
EPA
had
available
to
it,
EPA
determined
that
the
allowance
for
variability
provided
by
the
Episode
4851
data
was
sufficient
and
the
limitation
was
demonstrated
to
be
achievable,
as
described
later
in
this
subsection.

Fourth,
EPA
calculated
each
daily
maximum
limitation
for
a
pollutant
using
the
product
of
the
option
long­
term
average
and
the
option
daily
variability
factor.
EPA
rounded
the
limitation
to
two
significant
digits.
The
rounding
procedure
rounds
up
values
of
five
and
above,
and
rounds
down
values
of
four
and
below.
Table
10­
6
provides
the
option
long­
term
average,
option
daily
variability
factor,
and
the
daily
maximum
limitation.

10.6
Evaluation
of
the
Limitations
To
evaluate
the
limitations,
EPA
compared
the
daily
maximum
limitations
to
all
of
the
effluent
data
that
it
had
received
from
facilities
in
the
Oily
Wastes
Subcategory.
In
addition,
EPA
compared
the
values
of
the
final
daily
maximum
limitation
to
the
values
presented
in
the
2001
proposal
and
the
2002
NODA.
The
following
subsections
describe
these
evaluations.

10­
16
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
Table
10­
6
Option
Long­
Term
Averages,
Daily
Variability
Factors,
and
Limitations
Pollutant
Option
Long­
Term
Average
(
mg/
L)
Option
Daily
Variability
Factor
Daily
Maximum
Limitation
(
mg/
L)

Oil
and
grease
19
2.4
46
TSS
43
1.4
62
10.6.1
Comparison
to
Data
This
section
compares
the
daily
maximum
limitations
to
all
of
the
data
that
EPA
had
available
to
it
from
the
Oily
Wastes
Subcategory.
In
the
following
subsections,
EPA
first
evaluated
the
TSS
limitation
and
then
the
oil
and
grease
limitation.
In
addition,
EPA
compared
the
data
from
each
facility
to
both
limitations,
because
it
had
received
many
comments
stating
that
facilities
would
have
difficulty
complying
with
multiple
limitations
simultaneously.
From
its
conclusions
about
the
data
comparisons,
EPA
has
determined
that
the
data
do
not
support
such
assertions.
As
a
result
of
the
data
comparisons
and
reviews
described
below,
EPA
has
concluded
that
facilities
that
properly
design
and
operate
to
achieve
the
option
long­
term
average
will
be
able
to
comply
with
the
limitations.

Total
Suspended
Solids
Limitation
For
TSS,
none
of
the
daily
values
from
Episode
4851
(
i.
e,
the
basis
of
the
limitation)
were
greater
than
the
daily
maximum
limitation
of
62
mg/
L.
EPA
performed
this
comparison
to
determine
whether
it
used
appropriate
distributional
assumptions
for
the
data
used
to
develop
the
limitations
(
i.
e.,
whether
the
curves
EPA
used
provide
a
reasonable
 
fit 
to
the
actual
effluent
data4
or
if
there
was
an
engineering
or
process
reason
for
an
unusual
discharge).
As
a
result
of
this
comparison,
EPA
determined
that
the
distributional
assumptions
appear
to
be
appropriate
for
these
data.
As
a
further
evaluation
of
these
limitations,
EPA
compared
the
individual
measurements
from
field
duplicate
pairs
and
also
found
that
none
of
the
individual
values
were
greater
than
the
limitation.

EPA
performed
additional
comparisons
of
the
limitation
to
other
EPA
sampling
data
obtained
from
the
Option
6
technology
in
the
Oily
Wastes
Subcategory,
although
they
were
not
used
as
a
basis
of
the
limitation.
EPA
compared
the
limitation
to
the
TSS
data
values
from
Episode
4876
(
see
Section
10.2
for
EPA s
reasons
for
excluding
these
data
from
its
limitation
4EPA
believes
that
the
fact
that
the
Agency
performs
such
an
analysis
before
promulgating
limitations
might
give
the
impression
that
EPA
expects
occasional
exceedances
of
the
limitations.
This
conclusion
is
incorrect.
EPA
promulgates
limitations
that
facilities
are
capable
of
complying
with
at
all
times
by
properly
operating
and
maintaining
their
treatment
technologies.

10­
17
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
calculations).
Although
this
episode
had
more
concentrated
TSS
influent
than
Episode
4851
(
which
was
the
basis
for
the
limitation),
all
of
its
TSS
effluent
data
values
were
considerably
less
than
the
daily
maximum
limitation.
In
addition,
none
of
the
individual
measurements
exceeded
the
option
long­
term
average
of
43
mg/
L.
For
the
episodes
that
EPA
excluded
from
the
limitations
calculations
because
they
had
less
concentrated
influents
(
Episodes
4872,
4872D,
and
4877),
all
of
the
daily
values
and
individual
values
in
each
field
duplicate
pair
were
below
the
option
long­
term
average,
except
for
the
data
from
the
second
sampling
day
during
Episode
4877
when
the
facility
did
not
add
the
proper
treatment
chemicals.
During
Episode
4471,
the
facility
achieved
levels
lower
than
the
limitation
on
three
sampling
days
even
though
the
facility
had
not
optimized
its
treatment
system.
EPA
notes
that
the
single
effluent
value
greater
than
the
limitation
was
also
greater
than
its
corresponding
influent
value,
and
thus,
the
system
did
not
demonstrate
any
removals
of
TSS
on
that
day.
(
See
DCNs
36000S
and
36034
in
Section
19.1
of
the
record
and
DCN
00573
in
Section
5.2.32.1.)

EPA
also
compared
the
TSS
limitation
to
the
sampling
episode
and
self­
monitoring
data
obtained
from
three
facilities
(
4819,
4820,
and
4824)
that
treated
oily
wastes
using
ultrafiltration
systems.
The
average
influent
concentrations
at
these
facilities
ranged
from
128
mg/
L
to
10,100
mg/
L.
During
the
sampling
episodes
and
their
own
self­
monitoring,
none
of
the
facilities
had
average
concentration
values
that
were
greater
than
12
mg/
L,
which
is
substantially
less
than
the
option
long­
term
average
of
43
mg/
L
used
in
calculating
the
limitation.
Furthermore,
during
EPA s
sampling
episodes,
none
of
the
effluent
data
values
were
greater
than
17
mg/
L.

EPA
compared
the
TSS
limitation
to
the
data
from
Episode
7052P
that
operated
DAF
technology
in
addition
to
the
Option
6
technology.
The
influent
values
ranged
from
212
to
4440
mg/
L.
This
facility
demonstrated
treatment
performance
levels
below
the
option
long­
term
average
for
each
of
the
four
days
that
the
facility
sampled.

As
a
further
evaluation
of
its
TSS
daily
maximum
limitation,
EPA
examined
TSS
monitoring
data
provided
by
the
questionnaire
respondents
that
operated
facilities
in
the
Oily
Wastes
Subcategory,
including
two
facilities
that
operated
the
Option
6
technology.
Each
facility
provided
the
average
of
its
TSS
concentrations
for
one
year,
but
not
the
individual
measurements
or
the
influent
concentrations
(
because
the
questionnaire
did
not
request
this
information).
For
both
Option
6
facilities,
the
average
TSS
concentrations
were
below
the
daily
maximum
limitation
as
well
as
the
long­
term
average.
Other
than
these
two
facilities,
the
questionnaire
respondents
in
the
Oily
Wastes
Subcategory
either
reported
that
they
used
a
different
technology
than
Option
6
or
did
not
provide
TSS
average
concentrations.
Except
for
two
facilities,
the
reported
TSS
long­
term
averages
were
all
less
than
the
option
long­
term
average.
One
of
the
two
exceptions
used
a
treatment
technology
that
was
less
sophisticated
than
Option
6,
and
thus,
it
is
to
be
expected
that
it
would
have
a
higher
TSS
average
concentration
than
demonstrated
by
Option
6.
The
other
exception
operated
a
carbon
adsorption
and
oil/
water
separation
treatment
system.
Operated
properly,
this
treatment
technology
is
equivalent
or
better
than
the
Option
6
technology.
EPA
did
not
receive
sufficient
information
in
the
survey
from
this
facility
to
conduct
a
detailed
engineering
analysis
of
their
unit
operations
and
treatment
system.
Using
the
limited
information
that
it
had,
EPA
compared
this
facility s
unit
operations
and
wastewater
generating
10­
18
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
operations
to
similar
facilities
in
this
subcategory,
and
found
no
factors
that
would
prevent
this
facility
from
achieving
the
demonstrated
TSS
removal
of
Option
6.
Furthermore,
this
facility
did
not
provide
comments
to
EPA
stating
that
it
would
be
unable
to
meet
the
TSS
limitations
in
the
proposed
rule
or
the
NODA.
EPA
considers
that
it
may
be
possible
that
the
carbon
adsorption
system
was
overloaded
on
one
or
more
occasions
resulting
in
large
TSS
discharges
that
affected
the
overall
average
TSS
value
reported
by
the
facility.
To
ensure
that
the
facility
would
be
capable
of
complying
with
the
limitation,
EPA
assigned
a
one­
time
unit
upgrade
cost
to
this
facility
which
includes
contractor
fees,
operator
training,
and
additional
treatment
controls.
With
this
cost
for
additional
system
optimization,
the
site
should
be
able
to
comply
with
the
daily
maximum
limitation.

Oil
and
Grease
Limitation
For
oil
and
grease,
EPA
compared
the
daily
maximum
limitations
to
the
data
from
Episodes
4872,
4872D,
and
4877
which
were
used
as
the
basis
of
the
limitation.
None
of
the
daily
values
or
even
the
individual
values
for
grab
samples
from
Episodes
4872D
and
4877
were
greater
than
the
daily
maximum
limitation
of
46
mg/
L.
For
Episode
4872,
EPA
found
some
daily
values
(
and
values
for
individual
grab
samples)
that
were
greater
than
the
daily
maximum
limitation.
While
EPA
recognizes
that
the
data
from
this
episode
forms
the
technology
basis
of
the
oil
and
grease
limitation,
based
upon
its
review
of
the
data,
EPA
concluded
that
improvements
to
its
system
would
optimize
its
treatment
performance.
Based
upon
this
review,
EPA
also
discussed
the
possibility
of
excluding
these
data
from
developing
the
daily
maximum
limitation
because
the
data
probably
reflect
less
than
optimal
performance.
5
EPA
decided
to
maintain
a
conservative
approach
by
retaining
these
data
in
developing
the
limitation.
6
As
a
result
of
this
comparison,
EPA
determined
that
the
distributional
assumptions
appear
to
be
appropriate
for
effluent
data
from
the
Option
6
technology.

EPA
performed
additional
comparisons
of
the
limitation
to
other
EPA
sampling
data
obtained
from
the
Option
6
technology
in
the
Oily
Wastes
Subcategory,
although
the
data
were
not
used
as
a
basis
of
the
limitation.
During
Episode
4876,
the
system
still
achieved
levels
lower
than
the
daily
maximum
limitation
on
two
of
the
sampling
days
although
it
was
not
optimized
for
oil
and
grease
removals.
Although
EPA
used
most
of
the
data
from
Episode
4877
in
calculating
the
limitation,
it
had
excluded
the
data
for
the
second
sampling
day
as
explained
in
Section
10.2.
This
daily
value
was
greater
than
the
limitation,
which
is
what
EPA
expects
from
a
system
operating
without
the
proper
treatment
chemicals.
EPA
did
not
compare
the
Episode
4177
and
4851
data
values
to
the
limitation
because
any
conclusions
would
have
been
hard
to
5A
review
of
the
treatment
technology
as
this
facility
demonstrates
that
this
facility
lacks
some
parts
of
the
Option
6
technology
basis
(
i.
e.,
skimmer).

6Because
EPA
did
not
include
this
facility
in
its
sample
for
the
questionnaire,
it
did
not
include
costs
for
it
in
the
rule.
Also,
as
explained
in
Sections
11.0
and
12.0,
EPA
only
estimated
compliance
costs
and
loadings
reductions
for
facilities
in
its
cost
and
loads
model
database.
Had
this
been
a
costed
facility,
EPA
would
have
included
cost
estimates
for
additional
energy,
labor
and
equipment
for
this
facility
to
improve
the
operation
of
its
current
systems
in
order
to
comply
with
the
daily
maximum
limitation.

10­
19
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
interpret.
As
explained
in
Section
10.2,
the
data
for
Episode
4177
and
4851
were
excluded
due
to
concerns
about
the
analytical
method
and
the
quality
of
the
data.
(
See
DCNs
36000S
and
36034
in
Section
19.1
of
the
record
and
DCN
00573
in
Section
5.2.32.1.)

EPA
also
compared
the
oil
and
grease
limitation
to
the
sampling
episode
and
self­
monitoring
data
obtained
from
the
three
ultrafiltration
facilities.
Two
facilities
(
4819
and
4820)
had
average
effluent
values
that
were
less
than
the
option
long­
term
average
of
19
mg/
L
used
in
calculating
the
limitation,
and
their
daily
effluent
values
during
EPA s
sampling
episodes
were
all
below
the
daily
maximum
limitation.
These
episodes
had
influent
values
ranging
from
90
to
144
for
Episode
4820
and
689
to
857
for
Episode
4819.
For
the
third
facility
(
4824),
EPA s
sampling
data
had
an
average
effluent
value
below
the
daily
maximum
limitation,
although
one
daily
value
at
78
mg/
L
was
greater
than
the
limitation.
During
the
sampling
episode,
the
facility s
oil
and
grease
influent
values
ranged
from
660
to
3670
mg/
L.
The
self­
monitoring
data
(
4824D)
for
that
facility
had
an
average
value
of
47
mg/
L,
which
is
greater
than
the
limitation.
However,
this
facility
demonstrated
poor
performance
of
the
ultrafiltration
system
during
EPA s
sampling
episode.
It
was
only
able
to
remove
about
half
of
the
5­
day
biochemical
oxygen
demand
(
BOD5
)
and
chemical
oxygen
demand
(
COD)
concentrations,
resulting
in
effluent
averages
of
1390
mg/
L
and
5450
mg/
L,
respectively.
Thus,
because
this
facility
did
not
achieve
typical
removal
rates
for
pollutants
generally
well
treated
by
ultrafiltration,
EPA
has
determined
that
its
concentrations
of
oil
and
grease
are
abnormally
high
and
can
be
corrected
by
improved
operations.

EPA
compared
the
oil
and
grease
limitation
to
the
data
from
the
DAF
facility
(
Episode
7052P).
The
effluent
average
concentration
was
below
the
option
long­
term
average,
with
each
daily
concentration
having
a
value
less
than
the
daily
maximum
limitation.
The
influent
levels
ranged
from
212
to
1020
mg/
L.

As
it
had
for
TSS,
EPA
examined
oil
and
grease
monitoring
data
provided
by
the
questionnaire
respondents
that
operated
facilities
in
the
Oily
Wastes
Subcategory,
including
three
facilities
that
operated
the
Option
6
technology.
For
two
of
the
three
Option
6
facilities,
the
average
oil
and
grease
concentrations
were
below
the
daily
maximum
limitation
as
well
as
the
long­
term
average.
For
the
third,
the
average
oil
and
grease
concentration
was
slightly
above
the
long­
term
average
(
21
as
compared
to
19
mg/
L),
but
well
below
the
daily
maximum
limitation.
In
the
questionnaire,
the
facility
reported
that
it
used
Method
413.1
to
measure
oil
and
grease.
Because
EPA
used
only
data
measured
by
Method
1664
in
developing
the
TSS
limitation,
the
slight
difference
between
the
averages
might
be
a
result
of
the
different
solvents
used
in
the
two
analytical
methods
or
just
normal
variability
that
has
been
incorporated
into
the
option
daily
variability
factor.
For
the
nonoption
6
facilities,
the
reported
oil
and
grease
long­
term
averages
were
all
less
than
the
option
long­
term
average,
except
for
the
one
facility
that
operated
a
less
sophisticated
treatment
technology,
resulting
in
a
higher
oil
and
grease
average
concentration
value.
In
developing
the
rule,
EPA
also
included
costs
for
this
facility
to
upgrade
its
treatment
system
to
comply
with
the
daily
maximum
limitation.

10­
20
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
Both
Limitations
To
respond
to
comments
that
stated
that
facilities
would
have
difficulties
complying
with
multiple
limitations
simultaneously,
EPA
compared
the
data
from
each
facility
to
both
limitations.

For
facilities
with
the
Option
6
technology
for
which
EPA
had
daily
data
values
for
both
TSS
and
oil
and
grease
concentrations,
only
Episode
4872
had
any
daily
values
that
were
greater
than
the
oil
and
grease
daily
limitation
and
none
were
greater
than
the
TSS
limitation.
Thus,
Episode
4872
was
still
able
to
treat
its
TSS
and
sometimes
its
oil
and
grease
influent
concentrations
to
low
levels
in
the
effluent,
although,
as
explained
above,
it
has
not
optimized
its
treatment
system.

For
facilities
with
the
ultrafiltration
technology,
two
had
average
effluent
values
that
were
below
both
limitations.
Although
the
third
facility
had
poor
removals
of
key
parameters
including
oil
and
grease,
it
still
had
adequate
TSS
removals
and
the
average
effluent
values
were
less
than
the
TSS
limitation.

The
facility
with
the
DAF
technology
had
daily
concentration
values
below
both
limitations
for
each
sampling
day.

For
the
seven
facilities
that
provided
averages
of
their
monitoring
data
in
the
questionnaire,
only
two
reported
effluent
averages
above
either
limitation.
One
facility
operates
a
technology
that
is
less
sophisticated
than
Option
6,
and
thus,
it
is
not
surprising
that
its
effluent
is
more
concentrated
than
Option
6
levels.
The
other
facility
reports
that
it
operates
the
Option
6
technology,
but,
while
it
was
able
to
treat
oil
and
grease
to
levels
below
detection,
it
had
an
average
value
greater
than
the
TSS
limitation.
As
explained
above,
EPA
has
incorporated
costs
into
the
rule
for
this
facility
to
improve
its
operations.

10.6.2
Comparison
to
Proposed
and
NODA
Values
EPA
compared
the
TSS
and
oil
and
grease
daily
maximum
limitations
to
the
values
in
the
2001
proposed
rule
and
the
2002
NODA.
Table
10­
7
shows
the
three
sets
of
values.
In
the
NODA,
EPA
requested
comment
on
an
approach
that
would
select
the
higher
value
of
the
proposed
and
revised
limitation.
In
general,
the
comments
that
EPA
received
did
not
address
this
approach,
but
rather
focused
on
the
data
selection
and
achievability
of
the
limitations.
Thus,
EPA
has
chosen
to
base
the
final
limitations
on
its
in­
depth
review
of
the
episodes,
as
explained
in
Sections
10.1
and
10.2.
As
a
result
of
these
changes,
the
final
oil
and
grease
daily
maximum
limitation
has
a
value
that
is
greater
than
the
proposed
and
NODA
values;
and
the
TSS
daily
maximum
limitation
has
a
value
that
is
slightly
less
than
the
proposed
and
NODA
values.
EPA
has
determined
that
these
are
reasonable
outcomes
of
its
in­
depth
review
of
the
data.

10­
21
10.0
­
Limitations
and
Standards:
Data
Selection
and
Calculation
Table
10­
7
Daily
Maximum
Limitations:
Proposal,
NODA,
and
Final
Rule
Pollutant
2001
Proposal
2002
NODA
Final
Rule
Oil
and
grease
(
mg/
L)
27
45.9
46
TSS
(
mg/
L)
63
63.0
62
10­
22
11.0
­
Costs
of
Technology
Bases
for
Regulations
11.0
COSTS
OF
TECHNOLOGY
BASES
FOR
REGULATIONS
This
section
presents
EPA s
estimates
of
costs
for
the
MP&
M
industry
to
comply
with
the
technology
options
considered
and
described
in
Section
9.0.
EPA
estimated
the
compliance
costs
for
each
technology
option
in
order
to
determine
potential
economic
impacts
on
the
industry.
EPA
also
weighed
these
costs
against
the
effluent
reduction
benefits
resulting
from
each
technology
option.
This
section
includes
cost
estimates
for
options
and
subcategorization
schemes
that
EPA
selected
for
promulgation
and
for
those
that
EPA
ultimately
rejected.
Section
12.0
presents
Agency
estimates
of
corresponding
annual
pollutant
loadings
and
removals.
The
Agency
is
reporting
estimates
of
potential
economic
impacts
associated
with
the
total
estimated
annualized
costs
of
the
regulation
separately,
in
the
Economic,
Environmental,
and
Benefit
Analysis
of
the
Final
Metal
Products
&
Machinery
Rule
(
EEBA).

Section
11.1
summarizes
the
costs
associated
with
each
stage
of
the
regulation
development
process.
The
remainder
of
this
section
discusses
the
following
information:

 
Section
11.2:
Selection
and
development
of
cost
model
inputs;

 
Section
11.3:
The
methodology
for
estimating
costs,
including
an
overview
of
the
cost
model;

 
Section
11.4:
The
specific
methodology
and
assumptions
used
to
estimate
costs
for
the
Notice
of
Data
Availability
(
NODA)
and
for
analyses
after
the
NODA;

 
Section
11.5:
Design
and
cost
elements
for
pollution
prevention
and
end­
of­
pipe
technologies;

 
Section
11.6:
Examples
of
how
sites
were
allocated
costs,
from
start
to
finish;
and
 
Section
11.7:
References
used
in
this
section.

Tables
are
presented
in
the
text
and
figures
are
located
at
the
end
of
this
section.

11.1
Summary
of
Costs
This
subsection
summarizes
EPA s
final
capital,
operating
and
maintenance
(
O&
M),
and
annualized
cost
estimates
for
each
final
regulatory
option.
Table
11­
1
summarizes
the
capital
and
O&
M
costs
and
Table
11­
2
summarizes
the
annualized
costs.
These
tables
also
present
costs
for
each
11­
1
11.0
­
Costs
of
Technology
Bases
for
Regulations
11­
2
Table
11­
1
Incremental
Capital
and
O&
M
Costs
Subcategory
Discharge
Status
Options
Evaluated
Since
Proposal
NODA
Costs
($
2001)
Final
Rule
Costs
($
2001)
Technology
Basis
for
Final
Rule?

Number
of
Sites
Capital
Costs
O&
M
Costs
Number
of
Sites
Capital
Costs
O&
M
Costs
General
Metals
Direct
Option
2
1,521
215,372,532
406,618,406
228
16,302,446
10,582,427
No
Indirect
Option
2,
1
MGY
cutoff
2,354
545,616,505
718,480,881
NA
No
Upgrade
Option
NA
429
65,548,547
36,159,912
No
50%
Local
Limits
NA
628
95,760,054
40,732,283
No
Metal
Finishing
Job
Shops
Direct
Option
2
24
6,136,725
3,952,333
NA
No
Indirect
Option
2
1,270
252,665,620
167,585,291
NA
No
Upgrade
Option
NA
314
51,694,660
11,409,399
No
Non­
Chromium
Anodizing
Direct
Option
2
(
model
site)
35
21,726,209
35,625,488
19
2,473,423
6,584,137
No
Indirect
Not
Proposed
NA
No
Printed
Wiring
Board
Direct
Option
2
4
1,117,553
222,423
NA
No
Indirect
Option
2
840
178,724,756
176,775,257
NA
No
Upgrade
Option
NA
354
51,588,250
17,942,002
Steel
Forming
and
Finishing
Direct
Option
2
41
12,089,100
28,744,590
Not
Covered
by
MP&
M
No
Indirect
Option
2
112
19,399,831
22,760,945
Not
Covered
by
MP&
M
No
Oily
Wastes
Direct
Option
6
2,749
14,578,563
34,841,549
2,382
6,505,602
13,110,283
Yes
Indirect
Option
6,
2
MGY
cutoff
288
16,338,598
94,408,489
NA
No
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
1
(
Continued)

Subcategory
Discharge
Status
Options
Evaluated
Since
Proposal
NODA
Costs
($
2001)
Final
Rule
Costs
($
2001)
Technology
Basis
for
Final
Rule?

Number
of
Sites
Capital
Costs
O&
M
Costs
Number
of
Sites
Capital
Costs
O&
M
Costs
Railroad
Line
Maintenance
Direct
Option
10
31
5,941,283
3
NA
No
Option
6
NA
9
See
Footnote
A
No
Indirect
Not
Proposed
NA
No
Shipbuilding
Dry
Dock
Direct
Option
10
6
601,172
3,152,880
6
See
Footnote
A
No
Indirect
Not
Proposed
NA
No
Source:
EPA
Costs
&
Loadings
Model.

Note:
Cost
estimates
presented
in
this
table
will
not
equal
those
presented
in
the
EEBA.
These
estimates
do
not
include
costs
for
facilities
that
are
projected
to
close
in
the
baseline.

NA
­
Not
applicable.

Footnote
A
­
Based
on
DMR
data
received
both
from
the
model
facilities
and
in
comments,
EPA
considered
the
final
removals
to
be
negligible.
Therefore,
the
Agency
did
not
calculate
exact
final
costs.

11­
3
11.0
­
Costs
of
Technology
Bases
for
Regulations
11­
4
Table
11­
2
Incremental
Annualized
Costs
Subcategory
Discharge
Status
Options
Evaluated
Since
Proposal
NODA
Costs
($
2001)
Final
Rule
Costs
($
2001)
Option
Promulgated?

Number
of
Sites
Annualized
Costs
Number
of
Sites
Annualized
Costs
General
Metals
Direct
Option
2
1,521
431,321,635
228
12,452,318
No
Indirect
Option
2,
1
MGY
cutoff
2,354
781,063,094
NA
No
Upgrade
Option
NA
429
43,678,331
No
50%
Local
Limits
NA
628
51,715,961
No
Metal
Finishing
Job
Shops
Direct
Option
2
24
4,656,215
NA
No
Indirect
Option
2
1,270
196,566,038
NA
No
Upgrade
Option
NA
314
17,338,777
No
Non­
Chromium
Anodizing
Direct
Option
2
(
model
site)
35
38,117,484
19
6,867,838
No
Indirect
Not
Proposed
NA
No
Printed
Wiring
Board
Direct
Option
2
4
350,606
NA
No
Indirect
Option
2
840
197,274,986
NA
No
Upgrade
Option
NA
354
23,859,174
No
Steel
Forming
and
Finishing
Direct
Option
2
41
30,131,210
Not
Covered
by
MP&
M
No
Indirect
Option
2
112
24,986,106
Not
Covered
by
MP&
M
No
Oily
Wastes
Direct
Option
6
2,749
36,513,710
2,382
13,856,475
Yes
Indirect
Option
6,
2
MGY
cutoff
288
96,282,526
NA
No
Railroad
Line
Maintenance
Direct
Option
10
31
681,469
NA
No
Option
6
NA
9
See
Footnote
A
No
Indirect
Not
Proposed
NA
No
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
2
(
Continued)

Subcategory
Discharge
Status
Options
Evaluated
Since
Proposal
NODA
Costs
($
2001)
Final
Rule
Costs
($
2001)
Option
Promulgated?

Number
of
Sites
Annualized
Costs
Number
of
Sites
Annualized
Costs
Shipbuilding
Dry
Dock
Direct
Option
10
6
3,221,834
6
See
Footnote
A
No
Indirect
Not
Proposed
NA
No
Source:
EPA
Costs
&
Loadings
Model.

Note:
Cost
estimates
presented
in
this
table
will
not
equal
those
presented
in
the
EEBA.
These
estimates
do
not
include
costs
for
facilities
that
are
projected
to
close
in
the
baseline.

NA
­
Not
applicable.

Footnote
A
­
Based
on
DMR
data
received
both
from
the
model
facilities
and
in
comments,
EPA
considered
the
final
removals
to
be
negligible.
Therefore,
the
Agency
did
not
calculate
exact
final
costs.

11­
5
11.0
­
Costs
of
Technology
Bases
for
Regulations
option
considered
following
proposal
of
the
rule
and
compares
EPA s
final
cost
estimates
to
those
presented
in
the
NODA.
Cost
estimates
presented
in
this
section
differ
from
those
presented
in
the
EEBA
because
of
additional
EEBA
annual
costs
(
e.
g.,
taxes
and
amortization).
In
addition,
the
EEBA
cost
estimates
exclude
facilities
that
EPA
projected
will
close
in
the
baseline
(
i.
e.,
facilities
already
financially
stressed
without
the
additional
compliance
costs
associated
with
this
rule).
The
remainder
of
this
section
discusses
the
methodology
EPA
used
to
calculate
its
final
cost
estimates.
For
a
discussion
of
the
costing
methodology
EPA
used
at
NODA,
see
Section
16
of
the
rulemaking
record.

11.2
Development
of
Cost
Model
Inputs
This
subsection
describes
the
key
inputs
to
the
cost
model:
model
sites,
wastewater
discharge
parameters,
pollutant
concentrations,
and
technology
in
place.
This
section
also
discusses
the
data
sources
used
to
determine
these
parameters.
Section
11.3
describes
how
the
cost
model
uses
the
input
data.

11.2.1
Model
Site
Development
The
Agency
used
a
model­
site
approach
to
estimate
costs
for
the
water­
discharging
sites
in
the
MP&
M
Point
Source
Category.
A
model
site
is
an
operating
MP&
M
survey
site
whose
regulatory
status,
and
unit
operation
and
treatment
information
were
used
as
input
to
the
cost
model.
EPA
selected
a
site­
by­
site
model
approach
to
estimate
compliance
costs,
as
opposed
to
a
more
generalized
approach,
to
better
characterize
the
variability
of
both
process
water
and
wastewater
discharges
in
the
MP&
M
industry.
EPA
selected
915
model
sites
from
the
1,563
sites
returning
surveys.
EPA
excluded
sites
if:

 
The
site s
operations
did
not
fall
within
the
scope
of
this
rulemaking;

 
The
site
did
not
discharge
wastewater
(
treated
or
untreated)
to
either
a
surface
water
or
publicly
owned
treatment
works
(
POTW);
or
 
The
site
did
not
supply
sufficient
technical
data
to
estimate
compliance
costs
and
pollutant
loading
reductions
associated
with
the
technology
options.

Each
of
the
915
facilities
is
considered
a
 
model 
facility
for
two
reasons.
First,
because
only
a
portion
of
the
MP&
M
universe
was
surveyed,
each
facility
represents
a
larger
number
of
similar
facilities
in
the
overall
industry
population,
as
determined
by
its
statistical
survey
weight.
Section
3.0
discusses
the
development
of
survey
weights.
The
surveyed
sites
represent
an
estimated
industry
population
of
more
than
44,000
sites
that
discharge
either
directly
to
surface
waters
or
indirectly
through
a
POTW.
Second,
because
only
a
portion
of
the
MP&
M
universe
was
sampled,
EPA
used
its
sampling
data
to
model
an
aggregated
influent
to
treatment
concentration
for
each
survey
site
based
on
the
survey
subcategory
and
the
unit
operations
the
site
performs.
Section
12.0
discusses
the
use
of
unit
operation
sampling
data.
Additionally,
the
11­
6
11.0
­
Costs
of
Technology
Bases
for
Regulations
Agency
made
engineering
assumptions
based
on
national
information
from
standard
engineering
costing
publications,
equipment
vendors,
and
industry­
wide
data.
Thus,
for
any
given
model
site,
the
estimated
costs
and
loads
may
deviate
from
those
that
the
site
would
actually
incur.
However,
EPA
considers
the
compliance
costs
to
be
accurate
when
evaluated
on
an
industry­
wide,
aggregate
basis.

11.2.2
Wastewater
Streams
and
Flow
Rates
EPA
used
wastewater
discharge
parameters
(
e.
g.,
production
rates,
flow,
and
operation
schedule)
to
calculate
wastewater
generation
and
discharge
rates.
The
cost
model
uses
these
flow
rates
to
estimate
the
capacity
of
treatment
units
needed
for
each
wastewater
stream.
Using
information
from
survey
responses,
follow­
up
letters,
and
phone
calls,
EPA
first
classified
each
process
wastewater
stream
by
the
type
of
unit
operation
generating
the
wastewater
(
e.
g.,
machining,
electroplating,
acid
treatment).
For
each
unit
operation,
EPA
then
determined
production
rate,
operating
schedule,
wastewater
discharge
flow
rate,
and
discharge
destination.
Some
sites
provided
all
the
information
needed
for
each
wastewater
stream,
but
others
did
not.
EPA
determined
the
wastewater
discharge
parameters
as
described
below:

 
Production
rate.
In
survey
responses,
sites
reported
production
rates
in
surface
area
processed,
mass
of
metal
removed,
or
air
flow
rate,
depending
on
the
unit
operation.
Production
expressed
in
terms
of
surface
area
represented
surface
finishing
or
cleaning
operations;
mass
of
metal
removed
represented
metal
removal
operations
such
as
machining
and
grinding;
and
air
flow
rate
represented
air
pollution
control
operations.
For
blank
responses,
EPA
statistically
imputed
production
rates
using
other
data
provided
in
the
site s
survey
or
by
using
data
for
similar
unit
operations
reported
in
other
MP&
M
surveys.
The
general
methodology
as
well
as
specific
production
calculations
can
be
found
in
DCN
36200
in
Section
28.2
of
the
rulemaking
record.

 
Operating
schedule.
EPA
used
survey
responses
to
represent
the
operating
rate
(
hours
per
day
(
hpd)
and
days
per
year
(
dpy))
of
each
unit
operation.
For
blank
responses,
EPA
used
the
following:

­
The
maximum
hpd
and
dpy
reported
by
the
site
for
other
unit
operations,
if
reported
by
the
site,
or
­
The
survey
response
for
wastewater
treatment
system
operating
schedule,
if
the
site
provided
a
wastewater
treatment
operation
schedule,
or
­
8
hpd
and
260
dpy.
This
estimate
represents
the
median
work
schedule
for
MP&
M
sites.

11­
7
11.0
­
Costs
of
Technology
Bases
for
Regulations
 
Wastewater
discharge
flow
rate.
For
each
process
wastewater
stream,
most
sites
reported
the
total
wastewater
discharge
flow
rate
from
the
unit
operation
and
associated
rinses.
For
sites
that
reported
performing
a
unit
operation
but
did
not
report
a
discharge
flow
rate,
EPA
statistically
imputed
wastewater
flow
rates
using
other
data
provided
in
the
site s
survey
or
by
using
data
for
similar
unit
operations
reported
in
other
MP&
M
surveys.
The
general
methodology
as
well
as
specific
calculations
for
sites 
wastewater
flow
rates
can
be
found
in
DCN
36200,
in
Section
28.2
of
the
rulemaking
record.

 
Discharge
destination.
EPA
used
survey
responses
to
determine
the
discharge
destination
of
each
unit
operation
(
surface
water,
POTW,
no
discharge,
contract
haul,
or
other
alternatives)
and
the
level
of
treatment
prior
to
discharge
(
none,
pollution
prevention,
chemical
precipitation,
sedimentation,
etc.).
In
many
cases,
a
site
had
multiple
discharge
destinations.
EPA
assumed
no
costs
would
be
incurred
at
baseline
for
wastewater
streams
not
discharged
to
POTWs
or
surface
waters
(
i.
e.,
those
contracted
for
off­
site
disposal,
deep­
well
injected,
discharged
to
septic
systems,
reused
on
site,
or
otherwise
not
discharged
(
recycled,
evaporated,
etc.)).
For
sites
that
did
not
report
a
discharge
destination
for
some
or
all
operations,
EPA
used
other
MP&
M
survey
information
(
e.
g.,
types
of
discharge
permits,
discharge
destination
of
other
unit
operations,
process
flow
diagrams)
to
determine
the
stream
discharge
destination.
For
details
on
determination
of
site
discharge
destination,
see
Section
24.6.1
of
the
rulemaking
record,
DCNs
17881,
17825,
and
17826.

EPA
then
used
the
completed
wastewater
discharge
information
to
create
the
first
of
three
cost
model
input
databases,
Model
Site
Profile
1
(
MSP1).
Table
11­
3
summarizes
the
information
contain
in
MSP1.

Table
11­
3
Information
Contained
in
MSP1
Field
Name
Description
SiteID
Random
Site
Identification
Number
assigned
by
EPA.

UPNum
Unit
operation
number
as
reported
in
the
survey.
(
See
Section
4.0
for
a
list
of
unit
operations
performed
at
MP&
M
facilities.)

UPExt
Unit
operation
extension.
Each
unique
unit
operation
was
given
a
new
extension
(
e.
g.,
electroless
nickel
plating
might
be
UP20­
1
and
electroless
copper
plating
might
be
UP20­
2).

UPRinse
Unit
operation
rinse
indicator.
"
0"
designates
a
unit
operation,
"
R"
designates
a
unit
operation
rinse.

11­
8
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
3
(
Continued)

Field
Name
Description
StreamID
A
consolidation
of
the
fields
UPNum,
UPRinse,
and
UPExt
used
by
the
cost
model
(
UPNum+
UPRinse"­"
UPExt).

SiteDest
Overall
site
wastewater
discharge
destination
as
determined
by
the
survey.

Weights
Industry
Weighting
Factor;
this
number
indicates
how
many
sites
the
survey
represents
on
a
national
basis
(
see
Section
3.0
for
more
information).

FLOW
Unit
operation
discharge
flow
in
gallons
per
hour.

PROD
Unit
operation
production
in
PNP
per
hour.

PNP
Production­
normalizing
parameter;
standard
cubic
feet
per
minute,
square
feet,
or
pounds
of
metal
removed
depending
on
the
unit
operation.

PNF
Production­
normalized
flow,
equivalent
to
FLOW/
PROD.

HPD
Hours
per
day
that
the
unit
operation
operates.

DPY
Days
per
year
that
the
unit
operation
operates.

TANKVOL
Unit
operation
tank
volume
in
gallons.

NUMUNITS
Number
of
individual
units
represented
by
the
unit
operation
(
e.
g.,
30
machines
performing
the
same
operation,
operating
the
same
hours
and
days,
and
using
the
same
process
chemicals
would
be
represented
by
one
unit
operation
in
MSP1
but
would
have
a
numunits
of
30).

BASEMET
Base
metal
of
the
part
on
which
the
operation
is
being
performed.

METAPPL
Metal
being
applied
by
the
unit
operation
(
where
appropriate).

DEST
Stream
discharge
destination
as
determined
by
the
detailed
unit
operation
information.

RinseCode
Rinse
water
code
used
to
determine
the
level
of
pollution
prevention
currently
in
place
at
the
site.
Refer
to
Section
5.3.2.2
of
the
rulemaking
record,
DCN
15773,
for
specific
code
definitions.

Equipment
Code
Equipment
code
used
to
determine
the
amount
of
equipment
currently
in
place
at
the
site.
Refer
to
pollution
prevention
documentation
for
specific
code
definitions.

MCTIP
Indication
of
whether
the
stream
has
machine
coolant
treatment
in
place
(
yes/
no).

IXTIP
Indication
of
whether
the
stream
has
ion
exchange
treatment
in
place
(
yes/
no).

PCTIP
Indication
of
whether
the
stream
has
paint
curtain
treatment
in
place
(
yes/
no).

11.2.3
Wastewater
Pollutant
Concentrations
EPA
developed
pollutant
concentrations
for
the
model
sites 
wastewater
streams.
The
cost
model
tracks
two
concentrations
for
each
wastewater
stream:
the
baseline
pollutant
concentration
and
the
post­
compliance
pollutant
concentration.
The
baseline
pollutant
concentration
represents
what
the
site
currently
discharges.
The
post­
compliance
pollutant
concentration
represents
what
the
site
would
discharge
after
installing
the
regulatory
option
technology.

EPA
assigned
each
wastewater
stream
a
baseline
pollutant
concentration
for
each
pollutant
of
concern
(
POC)
in
the
second
input
database
named
MSP2.
The
cost
model
used
this
11­
9
11.0
­
Costs
of
Technology
Bases
for
Regulations
information
to
calculate
both
costs
and
pollutant
loadings.
The
remainder
of
this
section
describes
how
the
cost
model
used
pollutant
concentration
data
to
estimate
costs.
Section
12.0
discusses
how
the
cost
model
used
these
data
to
estimate
pollutant
loadings.
Table
11­
4
summarizes
the
information
contained
in
MSP2.

Table
11­
4
Information
Contained
in
MSP2
Field
Name
Description
SiteID
Random
Site
Identification
Number
assigned
by
EPA.

StreamID
A
consolidation
of
the
fields
UPNum,
UPRinse,
and
UPExt
used
by
the
cost
model
(
UPNum+
UPRinse"­"
UPExt).

PollCode
Pollutant
identification
code
(
e.
g.,
CU,
NA,
TS).
Refer
to
analytical
data
documentation
(
Section
5.3.2.2
of
the
rulemaking
record,
DCN
15773)
for
specific
code
definitions.

CHEM_
NAM
Chemical
Name
(
e.
g.,
copper,
sodium,
total
suspended
solids).
Refer
to
analytical
data
documentation
for
specific
code
definitions.

PollConc
Pollutant
concentration
as
defined
through
analytical
data
(
mg/
L).
Refer
to
Section
12.0
for
concentration
development
information.

11.2.4
Technology
in
Place
The
term
 
technology
in
place 
refers
to
those
treatment
technologies
installed
and
operating
at
a
model
site.
EPA
recognizes
the
importance
of
identifying
which
wastewater
streams
were
already
being
treated.
For
example,
sites
with
technology
in
place
that
met
or
exceeded
the
option
technology
would
incur
no
additional
costs,
and
sites
with
some
technology
in
place
would
need
only
parts
of
the
option
technology.
Sites
with
technology
in
place
that
met
or
exceeded
the
option
technology
but
did
not
treat
all
of
the
required
streams
with
this
technology
would
incur
costs
to
increase
capacity,
if
required.
Therefore,
EPA
identified
technology
in
place
from
survey
responses,
which
documented
the
technology
in
place
at
the
time
of
the
survey
response.
EPA s
surveys
cover
two
base
years:
1989
and
1996.
Because
EPA
has
two
base
years
for
this
industry,
where
EPA
received
updated
TIP
information
up
to
the
later
base
year
of
1996,
EPA
incorporated
this
updated
information
in
its
analyses.
The
cost
model
used
these
data
to
determine
what
components
of
the
option
technology
a
site
would
need,
as
in
Example
11­
1
at
the
end
of
this
section.

The
regulatory
options
include
two
types
of
wastewater
treatment:
(
1)
in­
process
pollution
prevention
and
source
reduction
(
pollution
prevention)
and
(
2)
end
of
pipe.
EPA
determined
the
technologies
in
place
for
all
unit
operations,
both
pollution
prevention
and
end
of
pipe;
however,
some
sites
did
not
provide
information
on
the
pollution
prevention
technology
in
place.
The
following
paragraphs
describe
in
detail
how
EPA
determined
pollution
prevention
technologies
in
place
for
these
sites.

11­
10
11.0
­
Costs
of
Technology
Bases
for
Regulations
Determination
of
Pollution
Prevention
Technology
In
Place
Although
both
the
1989
and
1996
MP&
M
Detailed
Surveys
requested
detailed
information
on
end­
of­
pipe
treatment
in
place,
only
the
1996
MP&
M
Detailed
Survey
requested
information
about
a
site s
in­
process
pollution
prevention
technologies.
Where
available,
EPA
determined
pollution
prevention
technology
in
place
based
on
survey
responses
(
e.
g.,
for
all
1996
survey
respondents).
For
other
model
sites,
the
Agency
determined
pollution
prevention
technology
in
place
based
on
other
survey
information.
For
example,
EPA
examined
the
model
site s
production­
normalized
flow
rate
(
PNF).
The
PNF
is
the
volume
of
wastewater
generated
per
unit
of
production,
as
described
in
the
following
equation:

FLOW
PNF
=
(
11­
1)
PROD
where:

PNF
=
Production­
normalized
flow,
gallons
per
ton;
FLOW
=
Annual
wastewater
discharge,
gallons
per
year;
and
PROD
=
Annual
production,
tons
per
year.

Generally,
the
less
wastewater
generated
per
volume
of
production,
the
better
the
pollution
prevention
technology
in
place.
Therefore,
if
the
site
PNF
was
below
the
median
PNF
calculated
for
the
industry
for
that
pollution
prevention
technology,
then
EPA
assumed
the
site
had
the
pollution
prevention
technology
in
place.
For
example,
if
a
1989
survey
site
reported
a
machining
wastewater
stream
with
a
PNF
below
the
median
PNF
for
centrifugation
and
pasteurization
of
machining
coolants,
then
the
Agency
assumed
that
the
model
site
had
a
machining
coolant
regeneration/
recycling
system
in
place.
The
median
PNFs
estimated
for
each
technology
are
detailed
in
Section
24.6.1
of
the
rulemaking
record,
DCN
17885.

Determination
of
Rinse
Scheme
Technology
In
Place
EPA
used
a
similar
method
to
determine
which
sites
had
efficient
rinse
schemes.
For
unit
operations
without
the
option
rinse
technology
in
place,
EPA
estimated
costs
to
install
and
operate
a
two­
stage
countercurrent
cascade
rinse.
EPA
used
the
following
parameters
in
designing
rinse
technology
upgrades:

 
Rinse
technology
in
place.
EPA
determined
which
of
the
following
rinse
technologies
sites
had
in
place:

­
Two
overflow
rinse
tanks,
­
One
overflow
rinse
tank,
­
One
stagnant
tank
followed
by
one
overflow
tank,
­
One
spray
rinse,
or
­
Two­
stage
countercurrent
cascade
rinsing.

11­
11
11.0
­
Costs
of
Technology
Bases
for
Regulations
For
sites
that
did
not
provide
information
on
their
rinse
scheme,
EPA
classified
their
rinse
type
based
on
the
PNF
for
the
industry.
First
EPA
calculated
site­
specific
PNFs
for
all
rinses
with
data.
Next,
the
Agency
calculated
the
median
industry
PNFs
for
each
rinse
type.
Finally,
EPA
assigned
each
unknown
stream
a
rinse
type
corresponding
to
the
stream s
PNF.

For
more
information
on
the
median
PNF
calculations
and
the
PNFs
associated
with
each
rinse
type,
see
Section
24.6.1
of
the
rulemaking
record,
DCN
17885.

 
Tank
volume.
The
cost
model
uses
unit
operation
tank
volume
as
a
design
parameter
for
countercurrent
cascade
rinsing,
but
the
Agency
did
not
request
this
information
in
the
surveys.
EPA
estimated
additional
tank
volume
needed
based
on
the
annual
discharge
flow
rate.

EPA
then
estimated
what
new
pollution
prevention
equipment
a
site
would
need
to
meet
the
regulatory
option.
Sites
with
countercurrent
cascade
rinsing
in
place
would
not
require
rinse
upgrades.
Sites
with
parts
of
countercurrent
cascade
rinsing,
such
as
tanks
but
not
enough
piping,
were
allocated
costs
for
the
piping
and
pumps
needed.
Additional
information
on
the
rinse
flow
reduction
methodology
can
be
found
in
Section
24.6.1
of
the
rulemaking
record,
DCN
17885.
Section
11.3.3
also
discusses
flow
reduction
methodology.

Determination
of
End­
of­
Pipe
Technologies
in
Place
EPA
reviewed
survey
data
for
each
model
site
to
assess
the
end­
of­
pipe
technologies
in
place
(
e.
g.,
chemical
reduction
of
chromium,
sludge
pressure
filtration).
EPA
found
some
technologies
in
place
that
were
not
part
of
the
regulatory
options
but
achieve
removals
equivalent
to
the
option
technology.
For
example,
the
Agency
considered
vacuum
filtration
equivalent
to
pressure
filtration
for
sludge
dewatering.
EPA
also
assumed
that
some
sedimentation
and
oil
treatment
systems
qualified
as
treatment
in
place
for
multiple
options.
For
example,
if
a
site
had
microfiltration
in
place
for
solids
removal,
EPA
considered
that
equivalent
treatment
for
either
microfiltration
or
clarification.
If
a
site
had
a
clarifier
in
place,
EPA
considered
it
equivalent
for
clarification,
but
not
for
microfiltration.
Table
11­
5
lists
the
technologies
that
EPA
considered
equivalent
to
the
option
technologies.
EPA
also
found
technologies
that
it
did
not
consider
equivalent
to
option
technologies.
For
example,
EPA
did
not
consider
oil/
water
separation
equivalent
to
dissolved
air
flotation
in
the
advanced
technology
options.
Conversely,
the
Agency
considered
dissolved
air
flotation
to
achieve
equivalent
or
better
pollutant
removals
than
oil/
water
separation.
EPA
assumed
that
sites
specifying
only
chemical
precipitation
also
had
a
clarifier
and
vice
versa.
In
addition,
the
Agency
assumed
sites
with
treatment
systems
in
place
have
the
associated
chemical
feed
systems.
Assumptions
regarding
treatment
technologies
in
place
at
each
model
site
are
discussed
in
detail
in
Section
6.5,
DCN
15799,
and
Section
24.6.1,
DCN
17888,
of
the
rulemaking
record.

11­
12
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
5
Treatment
Technologies
Considered
Equivalent
to
the
Option
Technologies
Technology
Specified
by
Option
Technologies
Considered
Equivalent
or
Better
to
the
Option
Technologies
Chelated
metals
treatment
Chelated
metals
treatment
Chemical
emulsion
breaking
and
gravity
oil/
water
separation
Chemical
emulsion
breaking
and
gravity
oil/
water
separation
Chemical
emulsion
breaking
and
gravity
flotation
Dissolved
air
flotation
General
oil
water
separationa
Ultrafiltration
Chemical
precipitation
and
sedimentation
Chemical
precipitation
Sites
without
chemical
precipitation
and
(
1)
with
ion
exchange
were
assumed
to
have
technology
equivalent
to
chemical
precipitation
and
clarification
(
2)
with
dissolved
air
flotation
assumed
to
have
technology
equivalent
to
given
chemical
precipitation
and
clarificationa
(
3)
with
pH
adjustment
and
sludge
dewatering/
filter
press
were
assumed
to
have
technology
equivalent
to
chemical
precipitation,
clarification,
and
sludge
dewatering/
filter
pressa
Chromium
reduction
Chromium
reduction
Clarification
Clarification
Microfiltration
Dissolved
air
flotation
(
where
no
other
chemical
precipitation
is
present)
a
Cyanide
reduction
Cyanide
reduction
Ion
exchange
Dissolved
air
flotation
Dissolved
air
flotation
Ultrafiltration
Filter
press
Filter
press
Vacuum
filtration
Microfiltration
for
solids
removal
Microfiltration
Multimedia
filtration
Multimedia
filtration
Sludge
dewatering
Sludge
dewatering
Gravity
thickener
Sludge
settling
tank
Ultrafiltration
for
oil
removal
Ultrafiltration
for
oil
removal
aThese
technologies
are
considered
equivalent
only
for
the
purpose
of
defining
treatment
in
place,
not
as
a
proven
method
of
meeting
the
final
limits.

11­
13
11.0
­
Costs
of
Technology
Bases
for
Regulations
EPA
also
used
survey
data
to
determine
the
capacity
of
the
end­
of­
pipe
technologies
in
place
at
the
model
sites
for
the
following
parameters:

 
Operating
schedule.
EPA
used
the
operating
schedule
(
hpd
and
dpy)
for
each
treatment
unit
supplied
by
sites.
For
blank
responses,
EPA
determined
the
schedule
using
the
following:

­
The
maximum
hpd
and
dpy
reported
for
other
treatment
units,

­
The
maximum
hpd
and
dpy
reported
for
the
unit
operations,
if
all
hpd
and
dpy
responses
for
all
treatment
units
were
blank,

­
The
maximum
hpd
and
dpy
reported
by
the
site
for
other
unit
operations
associated
with
other
treatment
units,
or
­
8
hpd
and
260
dpy,
if
all
hpd
and
dpy
survey
responses
were
blank
for
unit
operations
and
treatment
units.

 
Wastewater
streams
treated.
For
blank
responses,
EPA
determined
which
wastewater
streams
were
treated
by
the
technology
in
place
using
survey
process
flow
diagrams
or
survey
responses
regarding
the
destination
of
individual
process
wastewater
streams.
If
this
information
was
not
provided,
EPA
used
the
cost
model
logic
described
in
Section
11.3
to
help
assign
streams
to
technologies
(
e.
g.,
EPA
assumed
that
cyanide­
bearing
streams
were
treated
through
cyanide
destruction,
if
the
site
currently
had
it
in
place).

EPA
used
the
operating
schedule
and
wastewater
stream
flows
treated
by
the
technology
to
define
the
capacity
needed
for
each
technology
using
the
following
equation:

Q
V
×
SA
=
(
11­
2)
HLR
where:

V
=
Volume
of
tank
needed,
gallons;
SA
=
Surface
area
of
tank,
gallons
per
foot;
Q
=
Discharge
flow,
gallon
per
minute;
and
HLR
=
Hydraulic
loading
rate.
EPA
set
the
HLR
to
1,000
gallons
per
square
foot
per
day.

The
Agency
determined
design
capacity
from
one
of
two
flows:
the
survey­
provided
design
capacity
flow
(
when
available)
or
the
model
design
capacity
flow
as
derived
from
the
122
percent
of
baseline
flow.
The
methodology
for
calculating
the
model
flow
is
11­
14
11.0
­
Costs
of
Technology
Bases
for
Regulations
discussed
in
detail
in
Section
11.3.4.
EPA
also
accounted
for
those
sites
that
may
need
to
increase
wastewater
treatment
capacity
as
a
result
of
the
process
changes
associated
with
some
of
EPA s
technology
options.
Section
11.3.4
presents
how
EPA
accounted
for
baseline
end­
of­
pipe
technologies
with
insufficient
capacity.
Also,
more
details
on
capacity
calculations
are
in
Section
6.7,
DCN
15902,
and
Section
24.6.1,
DCN
17903,
of
the
rulemaking
record.
All
stream­
by­
stream
treatment­
in­
place
information
was
then
incorporated
into
the
final
input
database
MSP3.
Table
11­
6
summarizes
the
information
contained
in
MSP3.

Table
11­
6
Information
Contained
in
MSP3
Field
Name
Description
SiteID
Sited
Identification
Number
assigned
by
EPA.

UPNum
Unit
operation
number
as
reported
in
the
survey.

UPPrefix
Identifier
that
indicates
if
the
UPNum
refers
to
a
unit
operation,
in­
process
pollution
prevention
operation,
or
treatment
unit.
EPA
used
this
field
to
aid
in
the
creation
of
MSP3
(
e.
g.,
UP
or
TU).

UPExt
Unit
operation
extension.
Each
unit
operation
was
given
a
new
extension
(
e.
g.,
electroless
nickel
plating
might
be
UP20­
1
and
electroless
copper
plating
might
be
UP20­
2).

OldExt
Field
used
in
the
creation
of
MSP1
and
MSP3.

UPSuffix
Unit
operation
rinse
indicator.
"
0"
designates
a
unit
operation,
"
R"
designates
a
unit
operation
rinse.

StreamID
A
consolidation
of
the
fields
UPNum,
UPRinse,
and
UPExt
used
by
the
cost
model
(
UPNum+
UPRinse"­"
UPExt).

MODULE
Indicates
which
treatment
units
the
site
currently
has
in
place.

HPD
Hours
per
day
that
the
treatment
unit
operates.

DPY
Days
per
year
that
the
treatment
unit
operates.

SITEDCF
The
design
capacity
flow
reported
by
the
site
in
survey
data
(
gph).

DCF
The
design
capacity
flow
populated
during
cost
model
operation.
This
is
equivalent
to
the
larger
of
the
following:
the
sitedcf
or
a
minimum
dcf
calculated
in
the
cost
model.
Refer
to
cost
model
documentation
(
Section
24.6.1,
DCN
17890)
for
complete
DCF
creation
information
(
gph).

11.2.4.1
Baseline
Model
Runs
The
baseline
run
simulated
the
current
treatment
practices
at
each
model
site.
The
cost
model
uses
baseline
costs
to
determine
the
incremental
costs
for
each
regulatory
option.
EPA
first
performed
a
baseline
run
of
the
cost
model
to
determine
the
following
parameters:

 
Estimated
baseline
O&
M
costs
incurred
by
sites
in
2001
dollars;

 
Estimated
baseline
non­
water
quality
impacts
such
as
electricity
usage,
sludge
generation,
and
waste
oil
generation;

11­
15
11.0
­
Costs
of
Technology
Bases
for
Regulations
 
Estimated
baseline
pollutant
effluent
concentrations
(
see
Section
12.0);
and
 
Capacity
flow
rate
of
each
wastewater
treatment
technology
in
place.

11.2.4.2
Post­
Compliance
Model
Runs
Following
the
baseline
model
run,
EPA
then
ran
a
post­
compliance
cost
model
run
for
each
regulatory
option.
Each
cost
model
run
calculated
the
following
values:

 
Incremental
capital
investment
costs
incurred
by
sites
in
2001
dollars;

 
O&
M
costs
incurred
by
sites
in
2001
dollars;

 
Non­
water
quality
impacts
such
as
electricity
usage,
sludge
operation,
and
waste
oil
generation;
and
 
Pollutant
loadings
discharged
after
installation
of
the
option
technology
(
see
Section
12.0).

EPA
calculated
incremental
O&
M
costs
as
the
difference
between
baseline
and
post­
compliance,
using
the
following
equation:

O&
M
CostsIncremental
=
O&
M
CostsTreated
­
O&
M
CostsBaseline
(
11­
3)

EPA
used
the
same
methodology
to
calculate
incremental
values
for
non­
water
quality
impacts
and
pollutant
loadings.

11.2.4.3
New
Source
Model
Runs
EPA
also
ran
new
source
cost
model
runs
for
the
General
Metals,
Metal
Finishing
Job
Shops,
Non­
Chromium
Anodizing,
Printed
Wiring
Board,
and
Oily
Wastes
Subcategories.
These
runs
estimated
the
costs
a
new
source
would
incur
in
meeting
the
new
source
standards
considered
for
Part
438.
Model
sites
were
used
to
calculate
total
construction
and
operating
costs
associated
with
a
brand
new
treatment
system
consisting
of
the
appropriate
option
technology.
Each
cost
model
run
calculated
the
following
values:

 
Total,
rather
than
incremental,
capital
investment
costs
incurred
by
sites
in
2001;

 
Total,
rather
than
incremental,
O&
M
costs
incurred
by
sites
in
2001
dollars;

11­
16
11.0
­
Costs
of
Technology
Bases
for
Regulations
 
Total,
rather
than
incremental,
monitoring
costs
incurred
by
sites
in
2001
dollars;

 
Non­
water
quality
impacts
such
as
electricity
usage,
sludge
operation,
and
waste
oil
generation;
and
 
Pollutant
loadings
discharged
after
installation
of
the
option
technology
(
see
Section
12.0).

The
model
estimated
total
costs
for
new
sources
to
meet
the
considered
438
limitations
as
follows:

Subcategorya
Discharge
Destination
Number
of
MP&
M
Sites
Capital
Costs
($
2001)
Annual
Costs
($
2001)
Annualized
Costs
($
2001)

General
Metals
Direct
794
116,844,985
310,919,560
324,321,680
Indirect
10,307
1,851,638,823
2,268,371,865
2,480,754,838
Metal
Finishing
Job
Shops
Direct
12
5,546,098
2,612,444
3,248,581
Indirect
1,542
372,340,073
276,027,559
318,734,965
Non­
Chromium
Anodizing
Direct
None
Identified
Indirect
122
76,369,114
112,525,473
121,285,010
Printed
Wiring
Board
Direct
8
3,128,633
2,697,791
3,056,645
Indirect
818
230,533,415
255,151,103
281,593,286
Oily
Wastes
Direct
2,585
79,678,368
101,830,335
110,969,444
Indirect
26,608
575,295,361
1,629,178,524
1,695,164,902
aEPA
did
not
perform
new
source
cost
model
runs
for
the
Railroad
Line
Maintenance
or
Shipbuilding
Dry
Dock
Subcategories
because,
as
discussed
in
the
preamble
to
the
final
rule,
EPA
determined
that
national
regulation
of
discharges
in
these
subcategories
is
unwarranted
at
this
time.

Note
that
for
metal­
bearing
subcategories,
EPA
then
costed
new
sources
to
operate
two
separate
chemical
precipitation
and
solids
separation
steps
in
series.
This
was
done
to
address
concerns
raised
by
commentors
that
single­
stage
precipitation
and
solids
separation
may
not
achieve
sufficient
removals
for
wastewaters
that
contain
significant
concentrations
of
a
wide
variety
of
metals
that
precipitate
at
disparate
pH
ranges.
To
calculate
the
addition
of
a
second
stage
of
treatment,
EPA
doubled
the
original
treatment
costs.

11.3
General
Methodology
for
Estimating
Costs
of
Treatment
Technologies
This
subsection
discusses
the
methodology
for
estimating
costs,
including
the
components
of
cost
(
Section
11.3.1),
the
sources
and
standardization
of
cost
data
(
Section
11.3.2),
the
cost
model
(
Section
11.3.3),
and
assumptions
made
during
the
costing
effort
(
Section
11.3.4).

11­
17
11.0
­
Costs
of
Technology
Bases
for
Regulations
11.3.1
Components
of
Cost
The
components
of
the
capital
and
annual
costs
and
the
terminology
used
in
developing
these
costs
are
presented
below.

Capital
Investment
Costs
The
capital
investment
costs
consist
of
two
major
components:
direct
capital
costs
and
indirect
capital
costs.
The
direct
capital
costs
include:

 
Purchased
equipment
cost,
including
ancillary
equipment
(
e.
g.,
piping,
valves,
controllers);

 
Delivery
cost
(
based
on
the
equipment
weight
and
a
shipping
distance
of
500
miles);
and
 
Installation/
construction
cost
(
including
labor
and
site
work).

EPA
derived
the
direct
components
of
the
total
capital
cost
separately
for
each
treatment
unit
or
pollution
prevention
technology.
When
possible,
EPA
obtained
costs
for
various
sizes
of
preassembled,
skid­
mounted
treatment
units
from
equipment
vendors.
If
costs
for
these
units
were
not
available,
EPA
obtained
catalog
prices
for
individual
system
components
(
e.
g.,
pumps,
tanks,
feed
systems)
and
summed
these
prices
to
estimate
the
cost
for
the
treatment
unit.

Indirect
capital
costs
consist
of
secondary
containment,
engineering,
contingency,
and
contractor
fees.
These
costs
together
with
the
direct
capital
costs
form
the
total
capital
investment.
EPA
estimates
the
indirect
costs
as
percentages
of
the
total
direct
capital
cost,
as
shown
in
Table
11­
7.

Annual
Costs
Annual
costs
include
the
following:

 
Raw
material
costs
­
Chemicals
and
other
materials
used
in
the
treatment
processes
(
e.
g.,
sodium
hydroxide,
sulfuric
acid,
sodium
hypochlorite);

 
Operating
labor
and
material
costs
­
The
labor
and
materials
directly
associated
with
operation
of
the
process
equipment;

 
Maintenance
labor
and
material
costs
­
The
labor
and
materials
required
for
repair
and
routine
maintenance
of
the
equipment;

11­
18
11.0
­
Costs
of
Technology
Bases
for
Regulations
 
Energy
costs
­
Calculated
based
on
total
energy
requirements
(
in
kiloWatt
hours
(
kW­
hrs));
and
 
Monitoring
and
analytical
costs
­
The
periodic
sampling
and
analysis
of
wastewater
effluent
samples
to
ensure
that
discharge
limitations
are
being
met.

Table
11­
7
Components
of
Total
Capital
Investment
Item
Number
Item
Cost
Source
1
Equipment
capital
costs
including
required
accessories
Total
equipment
cost
MP&
M
cost
model
capital
cost
curves
2
Site
work,
including
demolition,
concrete
repair,
and
build
out
3%
of
total
equipment
cost
Attachment
1
(
DCN
16027,
Section
6.7.1)

3
Shipping
cost,
based
on
weight
of
equipment
and
500­
mile
shipping
radius
Technology­
specific
cost,
see
individual
cost
module
Attachment
2
(
DCN
16027,
Section
6.7.1)

4
Installation,
based
on
estimated
number
of
hours
for
each
technology
at
a
rate
of
$
29.67/
hour
Technology­
specific
cost,
see
individual
cost
module
MP&
M
cost
modules
5
Direct
capital
cost
Sum
of
items
1
through
4
6
Engineering/
administrative
and
legal
costs
10%
of
item
5
Attachment
1
(
DCN
16027,
Section
6.7.1)

7
Secondary
containment/
land
costs
10%
of
item
5
Attachment
3
(
DCN
16027,
Section
6.7.1)

8
Total
plant
cost
Sum
of
items
5
through
7
9
Contingency
15%
of
item
8
Attachment
1
(
DCN
16027,
Section
6.7.1)

10
Contractor s
fee
5%
of
item
8
Attachment
1
(
DCN
16027,
Section
6.7.1)

11
Total
capital
investment
Sum
of
items
8
through
10
11.3.1.1
Total
Annualized
Costs
EPA
calculated
total
annualized
costs
(
TAC)
from
the
capital
and
annual
costs.
The
Agency
assumed
a
7­
percent
discount
rate
over
an
estimated
15­
year
equipment
life,
using
the
following
equation:

Annualized
Cost
=
(
Incremental
Capital
Cost)
×
0.1147
+
(
Incremental
Annual
Cost)(
11­
4)

11­
19
11.0
­
Costs
of
Technology
Bases
for
Regulations
11.3.2
Sources
and
Standardization
of
Cost
Data
EPA
obtained
capital
and
annual
cost
data
for
the
technologies
that
constitute
EPA s
technology
options
(
see
Section
9.0)
from
equipment
vendors,
literature,
and
MP&
M
sites.
The
Agency
used
specific
data
from
the
1989
and
1996
MP&
M
Detailed
Surveys
whenever
possible;
however,
the
required
types
of
data
were
often
either
not
collected
or
not
supplied
by
the
sites.
The
major
sources
of
capital
cost
data
were
equipment
vendors,
while
the
literature
sources
provided
most
of
the
annual
cost
information.

 
Capital
Equipment.
EPA
obtained
information
on
capital
equipment
from
vendors
in
1998;
specific
cost
estimates
for
technologies
are
included
in
Section
6.7.1
of
the
rulemaking
record.

 
Chemicals.
EPA
used
the
Chemical
Marketing
Reporter
from
December
1997
to
obtain
chemical
prices
(
2).
A
list
is
in
Section
6.7.1
of
the
rulemaking
record,
DCN
15890.

 
Water
and
Sewer
Costs.
EPA
based
water
and
sewer
use
prices
on
average
data
collected
through
an
EPA
Internet
search
of
various
public
utilities
located
throughout
the
United
States
for
years
ranging
from
1996
to
1999.
The
average
water
and
sewer
use
charges
were
$
2.03
per
1,000
gallons
and
$
2.25
per
1,000
gallons,
respectively.
The
results
of
the
Internet
search
can
be
found
in
Section
6.7.1
of
the
rulemaking
record,
DCN
15890.

 
Energy.
EPA
used
average
electricity
prices
from
the
U.
S.
Department
of
Energy s
Energy
Information
Administration.
The
average
electrical
cost
to
industrial
users
from
1994
to
1996
was
$
0.047
per
kW­
hr
(
see
Section
6.7.1
of
the
rulemaking
record,
DCN
15890).

 
Labor.
EPA
used
a
labor
rate
of
$
29.67
per
hour
to
convert
the
labor
requirements
of
each
technology
into
annual
costs.
The
Agency
obtained
the
base
labor
rate
from
the
Monthly
Labor
Review
,
which
is
published
by
the
U.
S.
Bureau
of
Labor
Statistics
of
the
U.
S.
Department
of
Labor.
Excluding
the
maximum
and
minimum
values,
EPA
used
the
largest
remaining
monthly
value
for
1997
for
production
labor
in
the
fabricated
metals
industry,
$
12.90
per
hour,
as
a
conservative
estimate.
The
Agency
added
15
percent
of
the
base
labor
rate
for
supervision
and
100
percent
for
overhead
to
obtain
the
labor
rate
of
$
29.67
per
hour
(
3).
See
Section
6.7.1
of
the
rulemaking
record,
DCN
15890.

 
Off­
Site
Treatment/
Disposal.
EPA
estimated
average
costs
of
contracting
for
off­
site
waste
treatment/
disposal
using
data
from
the
1996
MP&
M
Detailed
and
Screener
Surveys,
as
discussed
in
Section
11.4.4.

11­
20
11.0
­
Costs
of
Technology
Bases
for
Regulations
The
Agency
estimated
costs
to
dispose
of
RCRA
hazardous
metal
hydroxide
sludge
from
Pollution
Prevention
and
Control
Technology
for
Plating
Operations
(
4).
Table
11­
8
presents
the
treatment/
disposal
costs
for
various
waste
types.
See
Section
6.7.1
of
the
rulemaking
record,
DCN
16023.

 
Monitoring
Costs.
MP&
M
effluent
monitoring
costs
were
developed
based
on
sampling
frequency,
the
cost
per
analysis,
and
the
labor
to
collect
the
samples.
Monitoring
costs
vary
depending
on
the
current
regulatory
status
of
the
facility.
The
following
subsections
describe
the
MP&
M
monitoring
frequency
requirements
and
the
estimated
incremental
monitoring
costs
for
each
MP&
M
subcategory.

Table
11­
8
Costs
for
Contracted
Off­
Site
Treatment/
Disposal
of
Various
Waste
Types
Waste
Type
Cost
($/
gallon)

RCRA
hazardous
nonhazardous
paint
sludge
3.70
RCRA
hazardous
metal
hydroxide
sludge
(
3)
1.95
RCRA
nonhazardous
oil
0.86
Solvent
(
paint
and
paint
stripping
waste)
2.85
Oily
wastewater
1.33
General
metal­
bearing
wastewater
2.00
Cyanide­
bearing
wastewater
5.64
Hexavalent
chromium­
bearing
wastewater
3.51
Chelated
metal­
bearing
wastewater
1.40
Source:
1996
MP&
M
Detailed
and
Screener
Surveys.

EPA
standardized
capital
and
annual
cost
data
to
1996
dollars
(
the
most
current
year
for
which
EPA
collected
survey
data).
Final
industry
cost
estimate
numbers
are
then
converted
to
2001
dollars
using
the
Engineering
News­
Record
Construction
Cost
Index.
For
cases
where
EPA s
information
is
not
representative
of
1996,
EPA
adjusted
the
cost
estimates
using
RS
Means
Building
Construction
Historical
Costs
as
shown
in
Table
11­
9
(
see
Section
6.7.1
of
the
rulemaking
record,
DCN
15890).

11­
21
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
9
RS
Means
Building
Construction
Historical
Cost
Indexes
Year
Index
1989
92.1
1990
94.3
1991
96.8
1992
99.4
1993
101.7
1994
104.4
1995
107.6
1996
110.2
1997
112.8
1998
114.4
Source:
Historical
Cost
Indexes,
RS
Means
Building
Construction
Cost
Data
,
56th
Annual
Edition,
1998,
page
594
(
1).

Monitoring
Frequency
for
Metal­
Bearing
Subcategories
When
developing
costs
for
the
Part
438
effluent
limits
considered
for
the
metal­
bearing
subcategories,
EPA
considered
a
monitoring
frequency
of
once
per
week
for
regulated
pollutants.
EPA
calculated
the
costs
for
the
Part
438
limitations
assuming
the
monitoring
frequencies
listed
in
Table
11­
10.
See
Section
24.6.1
of
the
rulemaking
record,
DCN
17911.

Sampling
and
Analysis
Costs
EPA
developed
sampling
labor
and
equipment
requirements
based
on
its
experience
gained
during
the
MP&
M
sampling
episodes.
The
Agency
determined
laboratory
analysis
costs
for
each
regulated
pollutant
by
contacting
PEL
Laboratories
in
Tampa,
Florida.
Using
the
monitoring
frequency,
labor
hours
to
collect
samples,
the
loaded
labor
rate
($
29.67/
hour),
and
the
cost
per
analysis,
EPA
estimated
the
annual
monitoring
costs
for
various
facilities.

11­
22
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
10
Monitoring
Frequencies
Used
to
Develop
Part
438
Limitations
Considered
for
Metal­
Bearing
Subcategories
Regulated
Pollutant
Sample
Type
Samples/
week
Samples/
month
Samples/
year
Cadmium
Composite
1
4
48
Chromium
Composite
1
4
48
Copper
Composite
1
4
48
Lead
Composite
1
4
48
Nickel
Composite
1
4
48
Silver
Composite
1
4
48
Tin
Composite
1
4
48
Zinc
Composite
1
4
48
Cyanide
(
total)
Composite
1
4
48
Oil
and
grease
(
as
HEM)
Grab
4
12
192
pH
Composite
1
4
48
Total
Toxic
Organic
(
TTO)
parametera
Grab
0
1
12
aSum
of
volatile
organics,
semivolatile
organics,
pesticides
and
PCBs.

Incremental
monitoring
costs
for
metal­
bearing
MP&
M
facilities
depended
on
their
current
regulatory
status.
Incremental
costs
for
facilities
currently
regulated
by
Part
433
or
assumed
to
be
meeting
Part
433
(
e.
g.,
direct­
discharging
facilities
in
the
General
Metals
Subcategory)
to
comply
with
the
limits
considered
for
existing
and
new
source
Part
438
resulted
from:

 
Adding
tin
to
the
list
of
regulated
pollutants;

 
Lowering
the
effluent
limit
for
lead,
which
requires
analysis
by
graphite
furnace
atomic
adsorption
($
28/
sample)
rather
than
inductively
coupled
plasma
($
20/
sample);
and
 
Increasing
the
number
of
samples
for
oil
and
grease
from
one
to
four
during
each
sampling
event.

Incremental
sampling
labor
costs
result
from
the
need
to
collect
four
oil
and
grease
samples
rather
than
one
during
the
facility s
daily
processing
period.
The
annual
incremental
monitoring
cost
for
a
Part
433
facility
to
comply
with
the
limits
considered
for
Part
438
were
approximately
$
22,000
for
the
metal­
bearing
subcategories
(
see
Section
24.6.1
of
the
rulemaking
record,
DCN
17911).
These
incremental
monitoring
costs
are
conservative
(
e.
g.,
some
Part
433
facilities
may
be
currently
collecting
four
oil
and
grease
grab
samples
per
monitoring
day
and
some
that
generate
oily
waste
may
have
either
implemented
an
Organics
Management
Plan
or
are
already
collecting
12
TTO
samples
per
year).

11­
23
11.0
­
Costs
of
Technology
Bases
for
Regulations
Costs
for
new
source
facilities
(
not
including
existing
facilities
that
become
new
source
facilities)
result
from
the
purchase
or
rental
of
sampling
equipment,
sampling
labor,
and
laboratory
analysis.
The
monitoring
and
analytical
cost
for
these
new
source
facilities
to
comply
with
the
considered
effluent
limits
was
$
41,000
for
the
metal­
bearing
subcategories
(
see
Section
24.6.1
of
the
rulemaking
record,
DCN
17911).

Monitoring
Frequency
for
Oil­
Bearing
Subcategories
EPA
evaluated
monitoring
frequency
separately
for
the
Oily
Wastes,
Railroad
Line
Maintenance,
and
Shipbuilding
Dry
Dock
Subcategories
due
to
the
high
percentage
of
survey­
and
comment­
supplied
DMR
sampling
data
in
each
of
these
subcategories.
One
hundred
percent
of
the
direct
discharging
railroad
line
maintenance
facilities
supplied
sampling
data
and
some
associated
sampling
frequency
information.
Ninety­
two
percent
of
the
direct
discharging
oily
wastes
facilities,
with
treatment
in
place,
supplied
sampling
data
and
some
associated
sampling
frequency
information.
Fifty
percent
of
the
shipbuilding
dry
dock
facilities
supplied
sampling
data
and
some
associated
sampling
frequency
information.

Direct
discharging
MP&
M
facilities
in
the
Oily
Wastes
Subcategory
will
be
required
to
monitor
their
discharges
for
total
suspended
solids
(
TSS)
and
oil
and
grease.
Based
on
the
supplied
information,
for
the
Part
438
limitations,
EPA
calculated
incremental
monitoring
costs
assuming
all
direct
discharging
facilities
are
currently
analyzing
at
least
one
TSS
and
oil
and
grease
sample
per
month.
Therefore,
incremental
monitoring
costs
for
these
facilities
is
zero1
.
Monitoring
frequencies
are
determined
by
the
permit
writer
and
must
be
a
minimum
of
once
per
year.
The
monitoring
frequency
specified
in
MP&
M
National
Pollutant
Discharge
Elimination
System
(
NPDES)
permits
will
vary
depending
upon
the
size
of
the
facility,
potential
impacts
on
receiving
waters,
compliance
history,
and
other
factors,
including
monitoring
policies
or
regulations
required
by
permit
authorities.
EPA
encourages
permit
writers
to
require
all
facilities
subject
to
the
Part
438
limitations
to
collect
a
minimum
of
one
TSS
and
oil
and
grease
sample
per
month.
Facilities
may
monitor
more
frequently
than
specified
in
their
permits;
however,
the
results
must
be
reported
in
accordance
with
Part
122.41(
1)(
4)(
ii)
for
direct
dischargers.

1Based
on
the
information
in
its
database,
EPA
concludes
most
facilities
currently
collect
one
sample
per
month.
During
EPA
sampling
events,
EPA
collected
four
grab
samples
at
each
sampling
point
each
day.
These
samples
were
analyzed
individually
with
the
results
composited
mathematically
to
obtain
a
single
daily
concentration
for
each
pollutant
at
each
sampling
point.
While
the
final
limitations
are
based
on
these
composited
values,
the
analytical
method
allows
a
facility
to
composite
multiple
grab
samples
prior
to
analysis.
Therefore,
analytical
costs
should
remain
constant
for
these
facilities
even
if
permit
writers
require
them
to
collect
a
composite,
rather
than
grab
sample.

11­
24
11.0
­
Costs
of
Technology
Bases
for
Regulations
11.3.3
Development
of
the
Cost
Model
The
cost
model
consists
of
the
following
programming
components:

 
Model
shell;

 
Model
drivers;

 
Data
storage
files;
and
 
Technology
modules.

The
model
shell
includes
a
program
that
creates
various
menus
and
user
interfaces
that
accepts
user
inputs
and
passes
them
to
the
appropriate
memory
storage
areas.
The
model
drivers
are
programs
that
access
technology
modules
in
the
proper
order
for
each
option
and
process
model­
generated
data.
Data
storage
files
are
databases
that
contain
cost
model
input
and
output
data.
Information
typically
stored
in
data
storage
files
includes:

 
Flow,
production,
and
operating
data
associated
with
each
wastewater
stream;

 
Pollutant
concentrations
associated
with
each
wastewater
stream;
and
 
Site­
specific
data
regarding
existing
technologies
in
place
(
discussed
in
Section
11.2.4).

Technology
modules
are
programs
that
calculate
costs
and
pollutant
loadings
for
a
particular
pollution
control
technology.
EPA
developed
cost
modules
for
the
pollution
prevention
and
end­
of­
pipe
technologies
included
in
the
regulatory
options
for
the
MP&
M
industry.

The
technology
drivers
perform
the
following
functions
for
each
technology
costed
for
a
site
(
if
applicable):

 
Locate
and
open
necessary
input
data
files;

 
Store
input
data
entered
by
the
user;

 
Open
and
run
the
appropriate
technology
modules;
and
 
Calculate
and
track
model
outputs.

Table
11­
11
lists
the
treatment
technology
modules
that
are
used
in
the
cost
model.
Section
11.5
discusses
the
technology
modules.

In
the
context
of
the
MP&
M
cost
program,
 
model 
refers
to
the
overall
computer
program
and
 
module 
refers
to
a
computer
subroutine
that
generates
costs
and
pollutant
loadings
for
a
specific
in­
process
or
end­
of­
pipe
technology
or
practice
(
e.
g.,
chemical
precipitation
and
sedimentation,
contract
hauling).
EPA
adapted
some
modules
from
previous
11­
25
11.0
­
Costs
of
Technology
Bases
for
Regulations
EPA
rulemaking
efforts
for
the
metals
industry
and
developed
others
specifically
for
this
rulemaking
effort.

Table
11­
11
Wastewater
Treatment
Technologies
and
Source
Reduction
and
Recycling
Practices
for
Which
EPA
Developed
Cost
Modules
In­
Process
Technologies
and
Practices
End­
Of­
Pipe
Technologies
and
Practices
Countercurrent
cascade
rinsing
Centrifugation
and
pasteurization
of
machining
coolants
Chemical
reduction
of
hexavalent
chromium
Cyanide
destruction
Chemical
reduction
of
chelated
metals
Chemical
emulsion
breaking
and
gravity
oil/
water
separation
Chemical
emulsion
breaking
and
dissolved
air
flotation
Gravity
oil
emulsion
breaking
(
baseline
only,
see
Section
11.3.4)
Ultrafiltration
for
oil
removal
Contract
hauling
of
solvent
degreasing
wastewaters
Chemical
precipitation
Inclined
clarification
for
solids
removal
Microfiltration
for
solids
removal
Sludge
thickening
Sludge
pressure
filtration
Multimedia
filter
(
baseline
only,
see
Section
11.3.4)

Source:
MP&
M
Surveys,
MP&
M
Site
Visits,
Technical
Literature.

11.3.3.1
Modeling
Technology
Options
The
model
drivers
access
technology
modules
in
the
proper
order
for
each
technology
option
(
e.
g.,
in­
process
flow
control
and
pollution
prevention
followed
by
end­
of­
pipe
treatment).
The
drivers 
logic
dictates
which
unit
operations
feed
which
treatment
technologies.
EPA
assumed
wastewater
destination
based
on
unit
operation
wastewater
characteristics:
cyanide­
bearing
wastewater
feeds
cyanide
destruction
and
flowing
rinses
feed
countercurrent
cascade
rinsing.
Table
11­
12
lists
the
assigned
unit
operations
feeding
each
treatment
technology.
Note
that
a
unit
operation
can
feed
more
than
one
treatment
technology
or
in­
process
pollution
prevention
technology.
EPA
assumed
that
the
model
sites
commingled
all
MP&
M
wastewater
generated
for
treatment
by
chemical
precipitation,
inclined
clarification
or
microfiltration
for
solids
removal,
sludge
thickening,
and
sludge
pressure
filtration,
except
for
wastewater
from
the
Oily
Wastes,
Shipbuilding
Dry
Dock,
and
Railroad
Line
Maintenance
Subcategories,
and
except
for
solvent­
bearing
wastewater,
for
which
EPA
estimated
costs
for
off­
site
disposal.

11­
26
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
12
List
of
Unit
Operations
Feeding
Each
Treatment
Unit
or
In­
Process
Technology
Treatment
Technology/
Pollution
Prevention
Technology
Unit
Operations
Feeding
Technologya
Countercurrent
cascade
rinsing
Acid
treatment
with
chromium
rinse
Acid
treatment
without
chromium
rinse
Alkaline
cleaning
for
oil
removal
rinse
Alkaline
treatment
with
cyanide
rinse
Alkaline
treatment
without
cyanide
rinse
Anodizing
with
chromium
rinse
Anodizing
without
chromium
rinse
Aqueous
degreasing
rinse
Barrel
finishing
rinse
Chemical
conversion
coating
without
chromium
rinse
Chemical
milling
rinse
Chromate
conversion
coating
rinse
Corrosion
preventive
coating
rinse
Electrochemical
machining
rinse
Electroless
plating
rinse
Electrolytic
cleaning
rinse
Electroplating
with
chromium
rinse
Electroplating
with
cyanide
rinse
Electroplating
without
chromium
or
cyanide
rinse
Electropolishing
rinse
Heat
treating
rinse
Salt
bath
descaling
rinse
Solvent
degreasing
rinse
Stripping
(
paint)
rinse
Stripping
(
metallic
coating)
rinse
Testing
rinse
Washing
finished
products
rinse
Carbon
black
deposition
rinse
11­
27
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
12
(
Continued)

Treatment
Technology/
Pollution
Prevention
Technology
Unit
Operations
Feeding
Technologya
Countercurrent
cascade
rinsing
(
cont.)
Galvanizing/
hot
dip
coating
rinse
Mechanical
plating
rinse
Laundering
rinse
Cyanide
rinsing
Ultrasonic
machining
rinse
Phosphor
deposition
rinse
Centrifiguration
and
pasteurization
of
machining
coolant
Multiple
unit
operation
rinse
Grinding
Machining
Centrifugation
of
painting
water
curtains
Painting
­
spray
or
brush
Painting
­
immersion
Chemical
emulsion
breaking
and
oil/
water
separation
OR
Dissolved
air
flotation
OR
Ultrafiltration
system
for
oil
removal
Alkaline
cleaning
for
oil
removal
and
rinse
Alkaline
treatment
without
cyanide
Aqueous
degreasing
Assembly/
disassembly
Electrical
discharge
machining
rinse
Electrolytic
cleaning
Electroplating
without
chromium
or
cyanide
Floor
cleaning
and
rinse
Grinding
Grinding
rinse
Heat
treating
Impact
deformation
and
rinse
Machining
and
rinse
Painting
­
spray
or
brush
Painting
­
immersion
Pressure
deformation
Steam
cleaning
rinse
Stripping
(
paint)

11­
28
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
12
(
Continued)

Treatment
Technology/
Pollution
Prevention
Technology
Unit
Operations
Feeding
Technologya
Chemical
emulsion
breaking
and
oil/
water
separation
OR
Dissolved
air
flotation
OR
Ultrafiltration
system
for
oil
removal
Stripping
(
metallic
coating)
rinse
Testing
Thermal
cutting
rinse
Washing
finished
products
and
rinse
Bilge
water
Mechanical
plating
Photo
image
developing
Photo
imaging
Steam
cleaning
Vacuum
impregnation
Laundering
Calibration
Centrifugation
and
pasteurization
of
machining
coolant
Chemical
reduction
of
hexavalent
chromium
Acid
treatment
with
chromium
and
rinse
Anodizing
with
chromium
and
rinse
Chromate
conversion
coating
and
rinse
Electroplating
with
chromium
and
rinse
Stripping
(
paint)

Wet
air
pollution
control
­
chromium
Chromium
drag­
out
reduction
and
rinse
Chemical
reduction
of
chelated
metals
Electroless
plating
and
rinse
Cyanide
destruction
Alkaline
treatment
with
cyanide
and
rinse
Electroplating
with
cyanide
and
rinse
Cyanide
rinsing
and
rinse
Cyanide
drag­
out
destruction
and
rinse
Wet
air
pollution
control
­
cyanide
Solvent
hauling
Solvent
degreasing
aA
unit
operation
can
feed
more
than
one
treatment
technology
or
in­
process
pollution
prevention
technology.
EPA
assumed
that
the
model
sites
commingled
all
MP&
M
wastewater
generated
for
treatment
by
chemical
precipitation,
inclined
clarification
or
microfiltration
for
solids
removal,
sludge
thickening,
and
sludge
pressure
filtration,
except
for
wastewater
from
the
Oily
Wastes,
Shipbuilding
Dry
Dock,
and
Railroad
Line
Maintenance
Subcategories,
and
except
for
solvent­
bearing
wastewater,
for
which
EPA
estimated
costs
for
off­
site
disposal.

11­
29
11.0
­
Costs
of
Technology
Bases
for
Regulations
11.3.3.2
Modeling
Flow
Reduction
Figure
11­
2
shows
the
logic
used
by
the
cost
model
to
apply
the
in­
process
flow
reduction
to
each
model
site.
EPA
estimated
flow
reductions
resulting
from
applying
in­
process
pollution
prevention
technologies
to
any
streams
that
did
not
already
have
the
technology
in
place
(
see
Section
11.2.4).
The
estimated
flow
reductions
are
as
follows:

 
EPA
estimated
a
20­
to
80­
percent
flow
reduction
achieved
by
converting
the
current
rinse
scheme
in
place
to
countercurrent
cascade
rinsing
(
DCN
15993,
Section
6.7.1
of
the
rulemaking
record
and
Section
15.0
of
this
document
and
1996
survey
data).
The
flow
reduction
applied
depends
on
the
rinse
scheme
currently
in
place.
An
80­
percent
flow
reduction
corresponds
to
converting
a
high­
flow
two­
stage
continuous
overflow
rinse
to
a
two­
stage
countercurrent
cascade
rinse.
A
20­
percent
flow
reduction
corresponds
to
converting
a
stagnant
rinse
followed
by
a
continuous
overflow
rinse
to
a
two­
stage
countercurrent
cascade
rinse.
EPA
computed
the
flow
reductions
based
on
information
collected
in
the
MP&
M
surveys.

 
EPA
assumed
that
centrifugation
and
pasteurization
of
machining
coolants
reduced
coolant
use
by
80
percent
(
see
Section
6.7.1
of
the
rulemaking
record,
DCN
15802).
EPA
assumed
that
a
site
combined
all
wastewater
from
machining
operations
prior
to
centrifugation
and
pasteurization
of
machining
coolants.

 
EPA
assumed
that
centrifugation
of
painting
water
curtains
allowed
100
percent
reuse
of
the
treated
wastewater
in
the
painting
booth,
or
zero
discharge
(
sludge
removed
from
the
centrifuge
is
contract
hauled).
EPA
assumed
a
site
combined
wastewater
from
painting
streams
prior
to
paint
curtain
centrifugation.

11.3.3.3
Modeling
End­
of­
Pipe
Treatment
for
Metal
Bearing
Subcategories
The
logic
used
by
the
model
drivers
to
access
end­
of­
pipe
technologies
varies
depending
on
whether
the
subcategory
is
primarily
metal
bearing
or
oil
bearing.
Figure
11­
3
presents
the
logic
used
by
the
cost
model
to
apply
the
end­
of­
pipe
treatment
technologies
and
practices
for
the
following
metal­
bearing
wastewater
subcategories:
General
Metals,
Metal
Finishing
Job
Shops,
Non­
Chromium
Anodizing,
Printed
Wiring
Board,
and
Steel
Forming
and
Finishing.
In
developing
costs,
EPA
assumed
sites
would
segregate
wastewater
streams
according
to
pollutant
characteristics
(
chromium,
cyanide,
chelated
metals,
oil,
and
solvent).
Segregating
wastewater
streams
provides
the
most
efficient
and
effective
treatment
of
wastes.
Because
treating
solvent­
bearing
waste
streams
may
require
Treatment
Storage
and
Disposal
(
TS&
D)
permitting,
EPA
assumed
model
sites
would
contract
for
off­
site
disposal
of
solvent­
bearing
wastewater
streams,
while
the
other
segregated
wastewater
streams
would
receive
11­
30
11.0
­
Costs
of
Technology
Bases
for
Regulations
preliminary
treatment.
The
cost
model
assumed
that
effluent
from
preliminary
treatment
technologies
would
be
combined
with
other
wastewater
streams
that
did
not
require
preliminary
treatment
prior
to
estimating
the
cost
of
treating
the
combined
wastewater.
Model
drivers
also
direct
treatment
unit
order;
for
example,
sludge
from
chemical
precipitation
goes
to
thickening
and
pressure
filtration
prior
to
off­
site
disposal.
EPA
assumed
wastewater
from
chemical
precipitation
and
sedimentation
systems
would
be
discharged
to
either
a
surface
water
or
POTW
according
to
the
model
site s
current
discharge
destination
(
see
Section
11.3.4
for
general
discharge
status
assumptions
for
sites
with
multiple
discharge
destinations).

11.3.3.4
Modeling
End­
of­
Pipe
Treatment
for
Oily
Subcategories
The
model
drivers
access
modules
to
simulate
oily
wastewater
treatment.
Figure
11­
4
presents
the
logic
used
to
apply
the
end­
of­
pipe
treatment
technologies
and
pollution
prevention
practices
for
the
Oily
Wastes,
Railroad
Line
Maintenance,
and
Shipbuilding
Dry
Dock
Subcategories.
Each
of
these
subcategories
generates
wastewater
that
primarily
contains
oily
constituents
and
low
concentrations
of
dissolved
metals;
therefore,
EPA
did
not
include
chemical
precipitation
and
sedimentation
following
oil
treatment
for
these
subcategories.

11.3.3.5
Model
Output
The
model
drivers
track
output
including
the
following
site­
specific
information
for
each
technology:

 
Total
direct
capital
costs;

 
Total
direct
annual
costs;

 
Electricity
used
and
associated
cost;

 
Sludge
generation
and
associated
disposal
costs;

 
Waste
oil
generation
and
associated
disposal
costs;

 
Water­
use
reduction
and
associated
cost
credit;

 
Chemical
usage
reduction
and
associated
cost
credit;

 
Effluent
flow
rate;
and
 
Effluent
pollutant
concentrations.

Section
11.6
discusses
calculation
specifics
for
each
technology
module.

11.3.4
General
Assumptions
Made
During
the
Costing
Effort
This
subsection
presents
general
assumptions
that
EPA
included
in
the
cost
model.
Section
11.4
discusses
specific
assumptions
made
for
NODA
and
post­
NODA
analyses.
Section
11.6
discusses
technology­
specific
assumptions.

11­
31
11.0
­
Costs
of
Technology
Bases
for
Regulations
Baseline
Year
Determination
EPA
estimated
costs
for
the
MP&
M
industry
for
the
base
years
1989
and
1996
(
the
years
in
which
survey
data
were
collected).
The
Agency
included
sites
(
or
operations)
that
operated
during
the
1989
and
1996
calendar
years
in
the
cost
and
loadings
analyses
if
the
site
operated
at
least
one
day
during
the
respective
calendar
year.
If
a
site
(
or
operation)
shut
down
before
1996,
it
was
removed
from
the
costing
and
pollutant
loadings
analyses.
If
a
site
(
or
operation)
commenced
after
1989
(
Phase
I)
or
1996
(
Phase
II),
EPA
did
not
include
the
site
(
or
operation)
in
the
costing
or
pollutant
loadings
analyses.
See
Section
3.1
for
additional
information
regarding
EPA s
use
of
1996
as
the
base
year
for
its
analyses
for
this
rule.
Furthermore,
if
a
site
did
not
discharge
wastewater
to
surface
water
or
a
POTW
in
1989
(
Phase
I)
or
1996
(
Phase
II)
(
e.
g.,
was
a
zero
or
alternative
discharger),
then
EPA
excluded
the
site
from
the
costing
and
pollutant
loadings
analysis.

If
EPA
has
information
that
a
Phase
I
site
installed
or
significantly
altered
its
wastewater
treatment
systems
before
1996,
EPA
used
the
updated
data.
Also,
if
a
site
changed
its
discharge
status
before
1996,
EPA
used
the
updated
discharge
status
in
its
analyses.
Some
sites
provided
information
during
the
comment
period
that
corrected
information
submitted
with
their
survey.
For
example,
a
Phase
1
site
may
have
completed
its
survey
as
having
no
treatment
for
oily
discharges
but
submitted
information
during
comment
that
it
had
installed
treatment
prior
to
1996.
In
these
cases,
EPA
revised
the
input
data
to
reflect
the
corrected
site
information.

Capacity
of
End­
of­
Pipe
Technology
in
Place
For
sites
with
technology
in
place,
EPA
assessed
the
design
capacity
flow
for
each
treatment
unit
using
the
derived
design
capacity
flow
from
the
larger
of
two
values:
the
site s
reported
survey
design
capacity
flow
or
the
flow
calculated
by
the
cost
model
baseline
run,
as
described
in
Section
11.2.4,
assuming
the
baseline
flow
is
78
percent
of
the
design
capacity
flow.
MP&
M
survey
data
indicate,
on
average,
that
flow
entering
the
treatment
units
is
78
percent
of
the
design
flow
reported
by
the
survey
respondent.
Therefore,
rather
than
assuming
that
the
site
is
operating
at
100
percent
of
the
design
capacity
when
survey
information
is
unavailable,
EPA
assumed
the
site
is
operating
at
78
percent
of
the
design
capacity.
Therefore,
flows
can
increase
by
as
much
as
22
percent
over
the
current
flow
before
either
additional
treatment
capacity
or
contract
hauling
is
required
(
see
Section
6.7
of
the
rulemaking
record,
DCN
15902).
The
Agency
determined
the
need
for
greater
capacity
using
the
following
logic:

 
If
the
technology
was
not
in
place
at
the
model
site,
then
EPA
assigned
capital
costs
to
the
site
for
a
treatment
unit
of
sufficient
capacity.

 
If
the
technology
was
in
place
at
the
model
site
with
sufficient
capacity
to
treat
all
of
the
applicable
MP&
M
wastewater,
then
EPA
assigned
no
additional
capital
costs.

11­
32
11.0
­
Costs
of
Technology
Bases
for
Regulations
 
If
the
site
had
a
technology
in
place
equivalent
to
the
option
technology
but
with
insufficient
capacity
to
treat
all
the
applicable
MP&
M
wastewater,
then
EPA
assumed
the
site
would
operate
the
existing
system
at
full
capacity.
EPA
assigned
costs
for
the
option
technology
train
to
run
in
parallel
with
the
existing
treatment
to
handle
the
additional
flow.

Contracting
for
Off­
Site
Treatment/
Disposal
in
Lieu
of
Treatment
EPA
assessed
the
cost
to
contract
for
off­
site
treatment/
disposal
of
wastewater
compared
to
on­
site
treatment.
Because
many
MP&
M
sites
have
flow
rates
less
than
the
minimum
design
capacity
for
treatment,
EPA
determined
that
some
model
sites
would
contract
for
off­
site
disposal
of
wastewater
rather
than
treat
it
on
site.
If
off­
site
disposal
was
less
expensive
than
treatment
on
site,
EPA
assumed
the
site
would
dispose
of
the
wastewater
off
site.
EPA
compared
off­
site
disposal
versus
on­
site
treatment
for
individual
technologies
and
their
influent
flow
rates,
rather
than
on
the
total
site
wastewater
treatment
system.
For
example,
a
site
may
find
it
less
expensive
to
contract
for
off­
site
disposal
of
cyanide­
bearing
wastewater
than
to
install
and
operate
a
cyanide
destruction
treatment
system.
However,
it
would
still
be
less
expensive
to
treat
all
other
wastewater
streams
on
site.
To
determine
whether
treatment
on
site
was
less
expensive
then
contracting
for
off­
site
disposal,
EPA
compared
total
annualized
costs
assuming
an
equipment
life
expectancy
of
15
years
and
an
annual
interest
rate
of
7
percent.

EPA
used
MP&
M
survey
data
to
determine
the
unit
cost
($/
gal
or
$/
lb)
to
contract
for
off­
site
treatment/
disposal
for
various
waste
types
(
see
Section
6.7.1
of
the
rulemaking
record,
DCN
16023).
EPA
compared
the
costs
of
the
following
technologies
to
contracting
for
off­
site
disposal
in
lieu
of
treatment
costs:

 
Centrifugation
and
pasteurization
of
machining
coolants;

 
Centrifugation
of
painting
water
curtains
(
general
metal­
bearing
waste
and
paint
sludge);

 
Chemical
reduction
of
hexavalent
chromium;

 
Cyanide
destruction;

 
Chemical
reduction
of
chelated
metals;

 
Chemical
emulsion
breaking
and
gravity
oil/
water
separation;

 
Dissolved
air
flotation;

 
Ultrafiltration
for
oil
removal;

11­
33
11.0
­
Costs
of
Technology
Bases
for
Regulations
 
Chemical
precipitation
and
sedimentation;
and
 
Sludge
pressure
filtration.

In
the
case
of
wastewater
requiring
chemical
precipitation
and
sedimentation
treatment,
EPA
compared
the
costs
of
contracting
for
off­
site
disposal
of
the
untreated
end­
of­
pipe
wastewater
to
the
cost
of
the
entire
treatment
system,
which
includes
chemical
precipitation,
sedimentation
(
gravity
clarification
or
microfiltration),
sludge
thickening,
and
pressure
filtration.

Equipment
Size
Ranges
EPA
developed
equipment
cost
equations
for
each
component
of
the
treatment
technologies.
The
equations
are
valid
between
the
minimum
and
maximum
sizes
(
e.
g.,
flow
rates,
volume
capacities)
from
which
EPA
developed
the
equations.
For
wastewater
capacities
below
the
minimum
range
of
validity,
the
cost
model
designed
the
equipment
at
the
minimum
size.
For
wastewater
capacities
above
the
maximum
range
of
validity,
the
cost
model
designed
multiple
units
of
equal
capacity
to
operate
in
parallel.

Batch
Schedules
EPA
designed
either
batch
or
continuous
systems,
depending
on
each
model
site s
operating
schedule
and
discharge
flow
rate.
The
Agency
also
designed
wastewater
treatment
operations
such
that
the
minimum
system
would
be
operated
at
capacity.
For
example,
if
the
minimum
cyanide
destruction
system
was
480
gallons
per
batch,
and
a
site
generated
80
gallons
of
cyanide­
bearing
wastewater
per
day,
then
the
cost
model
designed
the
cyanide
destruction
system
to
treat
a
480­
gallon
batch
once
every
six
days.

Dilute
Influent
Concentrations
In
rare
cases,
high
wastewater
flow
rates
at
some
sites
resulted
in
pollutant
concentrations
below
the
long­
term
average
technology
effectiveness
concentrations
(
discussed
in
Section
10.0)
even
after
flow
reduction
from
in­
process
pollution
prevention
practices.
In
these
cases,
EPA
assumed
the
site
did
not
require
treatment
to
meet
the
EPA
option
for
that
wastewater
stream
and
therefore
did
not
include
end­
of­
pipe
costs.

11.4
Specific
Methodology
and
Assumptions
Used
to
Estimate
Costs
for
Treatment
Technologies
EPA
made
many
changes
in
cost
model
assumptions
and
methodology
made
based
on
comments
submitted
during
both
the
proposed
rule
and
the
NODA
comment
periods.
This
subsection
describes
the
changes
to
proposal
methodology
and
assumptions
that
EPA
used
to
estimate
both
the
costs
presented
in
the
NODA
and
those
developed
for
the
final
rule.
The
methodology
and
assumptions
used
for
the
costs
presented
in
the
Development
Document
for
the
Proposed
Effluent
Limitations
Guidelines
and
Standards
for
the
Metal
Products
&
Machinery
11­
34
11.0
­
Costs
of
Technology
Bases
for
Regulations
Point
Source
Category
(
EPA
821­
B­
00­
005)
are
discussed
in
that
document.
EPA
updated
information
regarding
unit
operations,
discharge
status,
operating
schedule,
and
flow
throughout
the
costing
effort,
based
on
industry
comments
and
corrections
to
submitted
survey
data.

11.4.1
NODA
Cost
Estimates
For
the
costs
presented
in
the
NODA,
EPA
revised
the
following
inputs
and
logic
of
the
proposed
cost
model:

 
Pollutant
concentration;

 
Subcategorization
scheme;

 
Discharge
status;

 
Wastewater
treatment
determination;

 
Wastewater
flow;

 
Treatment
modules;

 
Statistical
weighting
factors;
and
 
Post
processing.

EPA
also
added
an
option:
upgrading
treatment
from
40
CFR
413
standards
to
those
of
40
CFR
433.
The
remainder
of
this
subsection
describes
all
these
changes
in
detail.

Pollutant
Concentrations
EPA
revised
the
calculation
of
pollutant
concentrations
from
unit
operations.
First,
the
Agency
incorporated
additional
data
submitted
with
comments
and
from
the
Phase
III
sampling
(
see
Section
3.0
for
details
on
data
sources).
Next,
EPA
reclassified
sampling
data
unit
operations,
including
revising
one
sample
point
to
be
a
drag­
out
rinse
and
adding
more
printed
wiring
board
unit
operations
(
see
Section
12.0
for
details).
See
Section
24.7
of
the
rulemaking
record,
DCN
17890,
for
details
of
these
changes.

Subcategorization
Scheme
In
response
to
industry
comments,
EPA
made
the
following
adjustments
to
the
subcategorization
scheme
for
analyses
presented
in
the
NODA:

 
Printed
Wiring
Board
Assembly
facilities
in
the
Metal
Finishing
Job
Shops
Subcategory
were
moved
to
the
General
Metals
Subcategory.
Facilities
that
perform
only
Printed
Wiring
Board
Assembly
operations
remained
in
the
General
Metals
Subcategory.

 
Printed
Wiring
Board
Job
Shops
were
moved
from
the
Metal
Finishing
Job
Shops
Subcategory
into
the
Printed
Wiring
Board
Subcategory.

11­
35
11.0
­
Costs
of
Technology
Bases
for
Regulations
 
Additional
unit
operations
were
included
in
the
Oily
Wastes
Subcategory
based
on
new
sampling
data
and
data
submitted
with
comments.

 
Zinc
platers
were
defined
and
segregated
from
the
General
Metals
and
Metal
Finishing
Job
Shops
Subcategories
for
some
analyses
for
EPA s
consideration
of
a
zinc
platers
subcategory
or
segment.

Discharge
Status
For
NODA
analyses,
EPA
revised
the
discharge
status
determination
for
sites
submitting
MP&
M
Phase
I
surveys
to
better
reflect
the
MP&
M
Phase
II
discharge
status
hierarchy.
The
discharge
status
for
all
sites
was
thus
based
on
the
following
assumptions:

 
EPA
considered
a
site
with
a
direct
discharging
stream
as
direct,
regardless
of
any
indirect
or
zero­
discharging
streams
(
i.
e.,
all
streams
at
the
site
were
considered
to
be
direct);

 
EPA
considered
a
site
with
an
indirect
discharging
stream
and
no
direct
streams
as
indirect,
regardless
of
any
zero­
discharging
streams;
and
 
EPA
considered
a
site
with
no
direct
or
indirect
streams
a
contract­
haul,
reuse,
or
zero­
discharge
site.

Wastewater
Treatment
Determination
EPA
updated
the
treatment
in
place
based
on
the
following
additional
comment
data
and
new
assumptions:

 
In
response
to
industry
comments,
EPA
considered
end­
of­
pipe
ion
exchange
equivalent
to
cyanide
destruction
for
sites
discharging
cyanide­
bearing
wastewater.
See
Section
20.3
of
the
rulemaking
record,
DCN
17947,
for
the
industry
comment
information.

 
For
sites
responding
to
the
Short
and
Municipality
Surveys,
EPA
no
longer
considered
neutralization/
pH
adjustment
equivalent
to
chemical
precipitation.
EPA
considered
only
neutralization/
pH
adjustment
with
clarification
or
sludge
removal
equivalent
to
chemical
precipitation.

 
EPA
assumed
that
sites
with
baseline
pollutant
concentrations
less
than
the
option
technology
pollutant
concentrations
did
not
require
any
additional
treatment.

 
EPA
verified
cost
model
input
database
accuracy
versus
the
site
surveys
and
resolved
inconsistencies,
such
as
stream
discharge
destination.

11­
36
11.0
­
Costs
of
Technology
Bases
for
Regulations
Wastewater
Flow
EPA
revised
flow
imputations
for
sites
not
reporting
unit
operation
discharges.
The
sum
of
imputed
flows
was
verified
to
be
less
than
the
total
reported
facility
flow,
where
available.
Additionally,
EPA
excluded
recirculated
flow
from
the
imputation
to
reduce
the
potential
for
overinflated
imputations.
See
Section
16.6.1
of
the
rulemaking
record,
DCN
27711.

Statistical
Weighting
Factors
EPA
incorporated
new
statistical
weighting
factors.
The
Agency
adjusted
some
Phase
I
survey
weights
to
account
for
additional
zero
dischargers
and
to
exclude
ineligible
facilities.
See
Section
19.5
of
the
rulemaking
record,
DCN
36086.

Post
Processing
EPA
adjusted
model
logic,
allowing
treatment
costs
to
be
estimated
on
individual
wastestreams
for
the
Railroad
Line
Maintenance
and
Steel
Forming
and
Finishing
Subcategories.
EPA
also
allowed
for
cost
savings
from
the
addition
of
pollution
prevention
technologies.

40
CFR
413
to
433
Upgrade
Analysis
To
consider
the
industry
comment
that
the
proposed
standards
were
too
stringent,
EPA
examined
a
new
option:
to
upgrade
from
the
40
CFR
413
standards
to
40
CFR
433
standards.
EPA
approximated
compliance
costs
and
load
reductions
associated
with
upgrading
facilities
from
the
Electroplating
(
40
CFR
413)
rule
to
the
Metal
Finishing
(
40
CFR
433)
rule.
The
40
CFR
413
rule,
promulgated
in
1981,
is
based
on
older
technology
than
the
40
CFR
433
rule,
promulgated
in
1983.
Section
9.0
presents
the
option
technology
associated
with
the
Part
413
to
433
Upgrade
Analysis.
Section
11.5
discusses
how
EPA
estimated
costs
for
each
component
of
the
option
technology,
and
Section
12.0
discusses
how
EPA
estimated
the
pollutant
loadings
reductions
associated
with
the
Upgrade
Analysis.

11.4.2
Post­
NODA
Cost
Estimates
Following
receipt
of
industry
comment
on
the
analyses
presented
in
the
NODA,
EPA
revised
parts
of
the
costing
approach.
The
remainder
of
this
subsection
describes
the
changes
made
between
the
NODA
and
promulgation:
how
EPA
incorporated
new
data
received
and
revised
assumptions
and
parts
of
the
costing
methodology.

Treatment
Modules
Updates
EPA
revised
and
updated
treatment
modules.
Most
notably,
EPA
added
monitoring
costs
for
tin,
sulfide,
and
lead
for
all
sites.
EPA
revised
the
off­
site
disposal
methodology
to
haul
nickel­
bearing
wastewater
prior
to
chemical
precipitation
if
the
model
determines
not
to
treat
via
chemical
precipitation
and
sedimentation.
EPA
also
added
costs
for
11­
37
11.0
­
Costs
of
Technology
Bases
for
Regulations
sand
(
multimedia)
filters
as
a
technology
option.
For
more
details
on
these
and
other
revisions,
refer
to
Section
16.6.1,
DCN
16741,
and
Section
24.6.1,
DCN
17935,
of
the
rulemaking
record.

Discharge
Status
Post­
NODA,
EPA
altered
its
discharge
status
determination
to
allow
a
site
to
have
multiple
discharge
statuses
(
e.
g.,
direct
discharge,
indirect
discharge,
and
zero
discharge).
The
approach
was
changed
to
more
accurately
reflect
the
actual
site
situation.
At
the
time
of
the
proposed
rule
and
the
NODA,
EPA
classified
discharge
status
for
an
entire
site,
instead
of
each
wastestream.
For
analyses
after
the
NODA,
EPA
assigned
a
discharge
status
to
each
wastewater
treatment
system.

Flow
Estimates
EPA
revised
the
flow
imputation
methodology
used
to
estimate
flows
for
sites
that
did
not
provide
them.
The
new
methodology
allowed
for
zero
discharge
as
a
possible
imputation
result.
See
Section
28.2
of
the
rulemaking
record,
DCN
36200
for
more
detail
on
imputed
flows.

Treatment
in
Place
In
response
to
industry
comments
to
ensure
proper
consideration
of
the
baseline
treatment
in
place,
EPA
reconsidered
additional
treatment
technologies
equivalent
to
the
option
technologies:

 
EPA
now
considers
end­
of­
pipe
and
in­
process
ion
exchange
equivalent
to
cyanide
destruction
for
cyanide­
bearing
wastestreams
without
any
other
cyanide
treatment;

 
EPA
now
considers
end­
of­
pipe
and
in­
process
ion
exchange
equivalent
to
chemical
precipitation
plus
a
filter
press
for
metals­
bearing
wastestreams
without
other
metals
treatment;

 
Dissolved
air
flotation
is
considered
equivalent
to
chemical
precipitation
treatment
for
metals­
bearing
wastestreams
without
other
metals
treatment
for
the
413
to
433
Upgrade
option;

 
Any
type
of
oily
wastewater
treatment
(
e.
g.,
belt
skimming)
is
equivalent
to
chemical
emulsion
breaking
and
oil/
water
separation;
and
 
The
presence
of
a
holding
tank
and
sludge
removal
after
some
chemical
addition
is
now
considered
equivalent
to
chemical
precipitation
followed
by
clarification.

11­
38
11.0
­
Costs
of
Technology
Bases
for
Regulations
11.5
Costing
Methodologies
for
Direct
Discharging
Oil­
Bearing
Subcategories
Commentors
supplied
additional
DMR
and
sampling
data
during
the
post­
proposal
and
post­
NODA
comment
periods.
Due
to
the
small
number
of
model
facilities
in
each
of
the
oil­
bearing
subcategories
and
the
high
percentage
of
supplied
DMR
sampling
data,
EPA
was
able
to
use
site­
specific
effluent
discharge
information
as
a
major
part
of
the
costing
process.
(
One
hundred
percent
of
the
direct
discharging
railroad
line
maintenance
facilities
supplied
sampling
data
and
some
associated
sampling
frequency
information.
Ninety­
two
percent
of
the
direct
discharging
oily
wastes
facilities,
with
treatment
in
place,
supplied
sampling
data
and
some
associated
sampling
frequency
information.
Fifty
percent
of
the
shipbuilding
dry
dock
facilities
supplied
sampling
data
and
some
associated
sampling
frequency
information.)
The
methodology
used
in
each
of
the
oil­
bearing
subcategories
is
discussed
below.

11.5.1
Oily
Wastes
Costing
Methodology
For
the
Oily
Wastes
Subcategory,
EPA
calculated
the
costs
for
the
final
rule
through
the
following
methodology.
If
a
model
site
had
provided
DMR
data,
it
was
reviewed
to
determine
baseline
compliance
with
the
final
MP&
M
LTAs.
If
the
data
indicated
the
model
site
was
currently
meeting
the
LTAs,
no
additional
costs
were
applied
to
the
site.
If
the
DMR
data
indicated
the
model
site
was
not
currently
meeting
the
LTAs,
and
the
survey
indicated
that
the
facility
had
Option
6
technology
(
or
equivalent)
in
place,
then
the
cost
model
output
was
reviewed.
If
the
model
determined
that
pollution
prevention
(
P2)
could
be
added
to
the
site,
then
only
P2
costs
were
assigned.
It
was
assumed
that
adding
P2
would
lower
the
flow
into
the
treatment
system
and
help
increase
the
system
removals.
If
the
site
already
had
P2
in
place,
then
a
one­
time
upgrade
cost
was
added.
This
upgrade
cost
was
intended
to
help
the
facility
better
operate
their
treatment
system
through
use
of
a
consultant,
subsequent
operator
training,
and
some
additional
treatment
control
equipment.
The
upgrade
was
considered
a
capital
cost
and
totaled
$
10,700
($
2001).
This
is
made
up
of
the
costs
listed
below
(
for
more
details
on
how
each
of
these
costs
were
derived,
see
DCN
17906
located
in
Section
24.6.1
of
the
rulemaking
record):

 
$
5,500
for
consultant
fees;

 
$
2,200
for
operation
training;
and
 
$
3,000
for
a
new
pH
meter.

If
the
DMR
data
indicated
the
model
site
was
not
currently
meeting
the
LTAs,
and
the
survey
indicated
that
the
facility
did
not
have
Option
6
technology
(
or
equivalent)
in
place,
then
the
cost
model
output
was
used.

If
the
model
site
did
not
have
DMR
data,
it
was
reviewed
to
determine
the
level
of
treatment
in
place.
If
the
survey
indicated
the
facility
did
have
Option
6
technology
(
or
equivalent)
in
place,
then
EPA
set
the
baseline
discharge
concentrations
to
the
median
of
the
DMR
data.
Because
the
calculated
medians
for
oil
and
grease
and
TSS
were
below
the
final
MP&
M
LTA s,
no
additional
costs
were
added.
(
Note
that,
if
they
had
been
above
the
final
MP&
M
LTA s,
then
EPA
would
have
added
a
one­
time
upgrade
cost.)
If
the
survey
indicated
11­
39
11.0
­
Costs
of
Technology
Bases
for
Regulations
the
facility
did
not
have
Option
6
technology
(
or
equivalent)
in
place,
then
the
cost
model
output
was
used.

11.5.2
Railroad
Line
Maintenance
Costing
Methodology
For
the
Railroad
Line
Maintenance
(
RRLM)
Subcategory,
the
AAR
survey
information
discussed
in
Section
3.0
was
used.
Each
survey
contained
information
on
effluent
concentrations,
flow,
and
treatment
currently
in
place.
The
AAR
surveys
indicated
that
all
direct
discharging
facilities
in
the
RRLM
Subcategory
currently
use
wastewater
treatment
equivalent
to
or
better
than
Option
6.
Additionally,
most
of
the
facilities
have
NPDES
daily
maximum
permit
limitations
for
oil
and
grease
(
as
HEM)
and
TSS
as
15
and
45
mg/
L,
respectively.
Based
on
this
information,
EPA
concluded
that
these
oil
and
grease
(
as
HEM)
and
TSS
daily
maximum
limits
represent
the
average
of
the
best
performances
of
facilities
utilizing
Option
6
technology.

EPA
evaluated
the
compliance
costs
associated
with
establishing
BPT
daily
maximum
limitations
equivalent
to
15
and
45
mg/
L
for
oil
and
grease
(
as
HEM)
and
TSS,
respectively,
and
concluded
all
facilities
currently
meet
a
daily
maximum
oil
and
grease
limit
of
15
mg/
L
and
most
currently
monitor
once
per
month.
With
one
exception,
all
facilities
are
currently
meeting
a
TSS
daily
maximum
limit
of
45
mg/
L.
If
EPA
had
decided
to
develop
Part
438
limitations
for
this
subcategory,
it
would
have
estimated
incremental
costs
associated
with
bringing
this
one
facility
into
compliance
with
the
TSS
limit.

11.5.3
Shipbuilding
Dry
Dock
Costing
Methodology
No
additional
costs
were
estimated
for
this
subcategory.
Following
proposal,
EPA
received
comments
and
supporting
data
indicating
that
its
estimates
of
current
pollutant
discharges
from
this
subcategory
were
overestimated.
In
particular,
commentors
claimed
that
current
discharges
of
oil
and
grease
were
minimal
and
that
national
regulation
was
not
warranted
for
this
subcategory.
EPA
incorporated
the
additional
information
provided
by
commentors
into
its
analysis
and
now
concludes
that
direct
discharges
from
these
facilities
generally
contain
minimal
levels
of
all
pollutants.
In
particular,
current
oil
and
grease
discharges
from
these
facilities
are
not
detectable
(<
5
mg/
L)
or
nearly
not
detectable.
EPA
has
similarly
determined
that
TSS
discharges
are,
on
average,
minimal.
The
data
show
that
TSS
discharges
may
increase
episodically,
particularly
when
the
dry
dock
is
performing
abrasive
blasting
operations.
However,
EPA
has
concluded
that
these
episodic
discharges
from
six
facilities
do
not
warrant
national
regulation.
If
EPA
had
decided
to
develop
Part
438
limitations
for
this
subcategory,
it
would
have
estimated
incremental
costs
associated
with
lowering
and/
or
controlling
the
episodic
TSS
discharges.

11.6
Design
and
Costs
of
Individual
Pollution
Control
Technologies
This
subsection
discusses
in
detail
the
design
and
costing
of
the
individual
technologies
that
compose
the
technology
options.
Table
11­
13
presents
the
capital
and
annual
cost
equations
for
the
specific
equipment
mentioned
in
each
technology
description
below.
When
11­
40
11.0
­
Costs
of
Technology
Bases
for
Regulations
tanks
were
a
component
of
an
option,
EPA
estimated
that
each
wastestream
would
need
only
one
tank,
unless
the
technology
required
a
reserve
tank,
such
as
chemical
emulsion
breaking.
EPA
estimated
the
tank
volume
needed
based
on
Equation
11­
2
in
Section
11.2.4.
The
remainder
of
this
subsection
describes
the
tank
requirements
of
each
individual
technology.
Additional
documentation
is
available
in
Section
24.6.1
of
the
rulemaking
record,
DCN
17885.

11.6.1
Countercurrent
Cascade
Rinsing
The
Agency
estimated
costs
for
countercurrent
cascade
rinses
for
flowing
rinses
at
the
model
sites.
The
countercurrent
cascade
rinse
module
estimates
a
cost
and
flow
reduction
associated
with
the
conversion
to
a
two­
stage
countercurrent
rinse.
Section
15.2.4
gives
more
information
on
countercurrent
cascade
rinsing
flow
reduction
as
related
to
the
site s
existing
rinse
scheme.

EPA
estimated
capital
and
annual
costs
based
on
the
model
site s
current
rinse
schemes.
The
module
included
capital
and
annual
costs
for
the
following
equipment
when
necessary.

 
A
second
rinse
tank
with
a
volume
equal
to
the
volume
of
the
existing
tank;

 
Transfer
pumps
and
piping;
and
 
An
air­
agitation
system.

EPA
assumed
there
would
not
be
additional
O&
M
costs
for
replacing
the
current
rinse
scheme
with
a
two­
stage
countercurrent
cascade
rinse.
Direct
annual
costs
for
this
module
included
increased
energy
costs
but
a
reduced
water
cost
due
to
water­
use
reduction.
EPA
calculated
the
water
savings
obtained
from
converting
the
rinse
to
countercurrent
cascade
and
used
a
water
cost
of
$
2.03
per
1,000
gallons
to
subtract
the
cost
savings
from
the
site s
total
annual
cost.

11.6.2
Centrifugation
and
Pasteurization
of
Machining
Coolant
EPA
estimated
costs
for
centrifugation
and
pasteurization
of
machining
coolant
for
machining
and
grinding
operations
discharging
water­
soluble
or
emulsified
coolant
(
listed
in
Table
11­
13).
EPA
estimated
the
costs
of
a
liquid­
liquid
separation
centrifuge
to
remove
solids
and
tramp
oils
and
a
pasteurization
unit
to
reduce
microbial
growth.
The
costed
systems
included
the
following
equipment
in
Table
11­
13:

 
High­
speed,
liquid­
liquid
separation
centrifuge;

 
Pasteurization
unit;
and
 
Holding
tanks
for
large­
volume
applications.

11­
41
11.0
­
Costs
of
Technology
Bases
for
Regulations
EPA
provided
a
50­
percent
excess
capacity
to
account
for
fluctuations
in
production
resulting
from
flow
rates
greater
than
14
gallons
per
minute.
The
Agency
developed
capital
and
annual
cost
estimates
from
vendor
data
on
packaged
systems
of
different
capacities.
Direct
annual
costs
included
O&
M
labor
and
materials,
energy
costs,
sludge
and
waste
oil
disposal
costs,
and
a
cost
credit
for
water­
and
coolant­
use
reduction.
EPA
estimated
maintenance
labor
at
one
hour
per
week
and
operating
labor
at
one
hour
per
shift.

Based
on
site
visit
and
vendor
information,
EPA
assumed
that
this
technology
can
reduce
coolant
discharge
by
80
percent.
The
Agency
based
the
amount
of
coolant
and
water
saved
on
the
model
site
recycling
80
percent
of
the
coolant
and
discharging
a
20­
percent
blowdown
stream
to
oil
treatment.
From
site
visit
and
vendor
information,
EPA
estimated
the
coolant
solution
to
be
95
percent
water
and
5
percent
coolant.

11.6.3
Centrifugation
of
Painting
Water
Curtains
EPA
estimated
costs
for
centrifugation
of
painting
water
curtains
(
listed
in
Table
11­
13),
which
included
a
centrifuge
and
a
holding
tank
large
enough
to
hold
flow
for
one
hour.
Direct
annual
costs
included
O&
M
labor
and
materials,
energy
costs,
sludge
disposal
costs,
and
a
cost
credit
for
water­
use
reduction.
EPA
estimated
maintenance
labor
at
one
hour
per
week
and
operating
labor
at
one
hour
per
shift.

EPA
assumed
that
a
model
site
reused
all
water
discharged
from
the
centrifugation
system
in
painting
operations,
and
contracted
for
off­
site
disposal
of
the
sludge
from
the
system.
EPA
estimated
off­
site
disposal
costs
using
the
average
paint
sludge
hauling
costs
reported
in
the
1996
MP&
M
Detailed
Survey.
Because
actual
disposal
costs
depend
more
on
site­
specific
conditions
(
e.
g.,
paint
type
and
spray­
gun
cleaner
requirements)
than
RCRA
hazard
classification,
EPA
estimated
costs
by
averaging
the
costs
for
RCRA
hazardous
and
nonhazardous
paint
sludges
together.
(
See
Table
11­
14
for
off­
site
disposal
costs
and
Section
11.6.4
for
more
detailed
information.)

11­
42
11.0
­
Costs
of
Technology
Bases
for
Regulations
11­
43
Table
11­
13
MP&
M
Equipment
Cost
Equationsa
EquipmentEquationRange
of
Validity
Countercurrent
cascade
rinsing
A
=
[(
0.0004
x
TANKVOL
+
0.2243)]
x
DPY
x
HPD
x
0.047
­
[(
Y­
CCFLOW)
x
60
x
HPD
x
DPY
x
0.00203]

C
=
6.047
x
TANKVOL
+
3,784.3;
Tank,
piping,
and
pump
C
=
0.5077
x
TANKVOL
+
1077.8;
Piping
and
pump
C
=
8
x
29.67;
Labor
only
Machine
coolant
regeneration
system
(
including
holding
tanks)
A
=[
18
x
0.047
x
DPY
x
HPD
x
NUM]
+
[(
HPD/
8)
x
DPY
x
29.67
x
NUM]
+
[(
DPY/
5)
x
29.67
x
NUM]
+
[
0.002
x
Y
x
60
x
HPD
x
DPY
x
1.95]+
[
0.05
x
Y
x
60
x
HPD
x
DPY
x
0.86]
­

[
0.05
x
0.80
x
Y
x
60
x
HPD
x
DPY
x
9.03]
­
[
0.95
x
0.8
x
Yx
60
x
HPD
x
DPY
x
0.00203]
Y
 
14
C
=
41,422Y
 
1
C
=
110,2051
<
Y
 
2
C
=
142,8312
<
Y
 
6
C
=
164,0096
<
Y
 
10
C
=
191,33110
<
Y
 
14
Paint
curtain
centrifugeA
=[
0.047
x
KW
x
HPD
x
DPY]
+
[(
HPD/
8)
x
DPY
x
29.67]
+
[(
DPY/
5)
x
29.67]

+
[
TSS
x
3.785/
106
x
2.2/
0.4
x
Y
x
60
x
HPD
x
DPY/
8.5
x
3.7]

­
[(
Y
x
60
x
HPD
x
DPY)
­
(
TSS
x
3.785/
106
x
2.2/
0.4
x
Y
x
60
x
HPD
x
DPY/
8.35)]
x
0.00203
Y
 
53
C
=
7,254
(
kW
=
0.4)
Y
 
8
C
=
10,325
(
kW
=
1.5)
8
<
Y
 
13
C
=
47,104
(
kW
=
2.2)
13
<
Y
 
26
C
=
62,936
(
kW
=
3.7)
26
<
Y
 
53
11­
44
Table
11­
13
(
Continued)
11.0
­
Costs
of
Technology
Bases
for
Regulations
EquipmentEquationRange
of
Validity
Feed
system,
aluminum
sulfate
(
alum)
A
=
0.35
x
0.7456
x
HPD
x
DPY
x
0.047Y
<
10
C
=
6,622
Y
 
1
C
=
142.88
x
Y
+
6,4121
<
Y
<
10
A
=[
1.36
x
HPD
x
DPY
x
0.047]
+
[
0.0006615
x
Y
x
60
x
HPD
x
DPY]
+
[(
HPD/
8)
x
DPY
x
29.67]
+
[(
DPY/
5)
x
29.67]
10
 
Y
<
350
A
=[
1.49
x
HPD
x
DPY
x
0.047]
+
[
0.0006615
x
Y
x
60
x
HPD
x
DPY]
+
[(
HPD/
8)
x
DPY
x
29.67]
+
[(
DPY/
5)
x
29.67]
Y
 
350
C
=
9.7882
x
Y
+
9,718.7
10
 
Y
 
350
Feed
system,
calcium
chloride,
continuous
A
=[[(
0.0061
x
Y)
+
1.1696]
x
HPD
x
DPY
x
0.047]
+
[
0.00125
x
Y
x
60
x
HPD
x
DPY]
Y
 
350
C
=
10,299Y
 
10
C
=
28.805
x
Y
+
10,68310
<
Y
 
350
Feed
system,
calcium
hydroxide
(
lime),

continuous
A
=
0.25
x
0.7456
x
HPD
x
DPY
x
0.047
Y
<
10
C
=
8,489Y
 
1
C
=
47.713
x
Y
+
8,4451
<
Y
<
10
A
=[[(
0.0006
x
Y)
+
1.2961]
x
HPD
x
DPY
x
0.047]
+
[
0.000117
x
Y
x
60
x
HPD
x
DPY]
10
 
Y
 
350
C
=
24.586
x
Y
+
12,830
Feed
system,
ferric
sulfate,
continuous
A
=
0.35
x
0.7456
x
HPD
x
DPY
x
0.047
Y
<
10
C
=
5,200Y
 
1
C
=
52.991
x
Y
+
5,1181
<
Y
<
10
A
=[[(
0.0009
x
Y)+
1.3313]
x
HPD
x
DPY
x
0.047]
+
[
0.0000434
x
Y
x
60
x
HPD
x
DPY]
10
 
Y
 
350
C
=
11.56
x
Y
+
9,762.9
11­
45
Table
11­
13
(
Continued)
11.0
­
Costs
of
Technology
Bases
for
Regulations
EquipmentEquationRange
of
Validity
Feed
system,
polymerA
=[
0.2833
x
HPD
x
DPY
x
0.047]
+
[
0.001
x
Y
x
60
x
HPD
x
DPY]
Y
<
10
C
=
3,686
A
=[[(
0.0034
x
Y)
+
1.4171]
x
HPD
x
DPY
x
0.047]
+
[
0.001
x
Y
x
60
x
HPD
x
DPY]
10
 
Y
 
350
C
=
20.685
x
Y
+
9,822
Feed
system,
sodium
hydroxide,
continuous
(
caustic)
A
=[
0.1864
x
HPD
x
DPY
x
0.047]
+
[
0.0042
x
Y
x
60
x
HPD
x
DPY]
Y
<
10
C
=
4,503
A
=[[(
0.0071
x
Y)
+
1.1584]
x
HPD
x
DPY
x
0.047]
+
[
0.0042
x
Y
x
60
x
HPD
x
DPY]
10
 
Y
 
350
C
=
77.564
x
Y
+
21,506
Feed
system,
sulfuric
acid
A
=[
0.0373
x
HPD
x
DPY
x
0.047]
+
[
0.000222
x
Y
x
60
x
HPD
x
DPY]
Y
<
10
C
=
4,110
A
=[[(
0.0023
x
Y)
+
1.683]
x
HPD
x
DPY
x
0.047]
+
[
0.000222
x
Y
x
60
x
HPD
x
DPY]
10
 
Y
 
350
C
=
56.416
x
Y
+
17,769
Chemical
emulsion
breaking,
coalescent
plate
separator
(
gravity
oil/
water
separator)

[
requires
sulfuric
acid,

alum,
caustic,
and
polymer
feed
systems]
A
=
[(
0.0019
x
Y
+
2.009)
x
0.7456
x
HPD
x
DPY
x
0.047]
x
NUM
+
[
29.67
x
(
HPD/
8)
x
DPY]

+
[(
DPY/
5)
x
29.67]
x
NUM
+
[
3.664
x
Y
x
HPD
x
DPY]
Y
 
8
C
=
42,261Y
 
2
C
=
3,916.2
x
Y
+
30,278
+
2,452
x
Y
+
1,1322
<
Y
 
8
A
=
[(
0.096
x
Y
+
2.039)
x
0.7456
x
HPD
x
DPY
x
0.047]
x
NUM
+
[
29.67
x
(
HPD/
8)
x
DPY]

+
[(
DPY/
5)
x
29.67]
x
NUM
+
[
3.664
x
Y
x
HPD
x
DPY]
8
<
Y
 
200
C
=
86,7208
<
Y
 
15
C
=
845.43
x
Y
+
65,284
+
2,452
x
Y
+
1,13215
<
Y
 
200
Dissolved
air
flotation
[
requires
lime,
ferric
sulfate,
and
polymer
feed
systems]
See
ultrafiltration
for
oil
removal.
Y
<
4.42
A
=[(
0.0728
x
Y
+
3.072)
x
HPD
x
DPY
x
0.047]
+
[
0.0045
x
Y
x
60
x
HPD
x
DPY]
+
[
29.67
x
HPD
x
DPY]
+
[(
DPY/
5)
x
29.67]
+
[
0.86
x
0.0003
x
Y
x
60
x
HPD
x
DPY]
+
[
0.86
x
0.071
x
Y
x
60
x
HPD
x
DPY]
4.42
 
Y
 
350
C
=
1,125.4
x
Y
+
137,936
11­
46
Table
11­
13
(
Continued)
11.0
­
Costs
of
Technology
Bases
for
Regulations
EquipmentEquationRange
of
Validity
Ultrafiltration
for
oil
removal
A
=
[(
0.71
x
Y
+
5.46)
x
HPD
x
DPY
x
0.047]
+
[
0.4
x
Y
+
0.3]
+
[
0.5
x
HPD
x
DPY
x29.67]
+

[(
DPY/
5)
x
29.67]
+
[
65.78
x
Y
+
193.46]
+
[(
27,123
x
Y/(
24
x
365
x
60))
x
0.86
x
60
x
HPD
x
DPY]
Y
 
406
C
=
157,700
Y
 
8
C
=
3,596
x
Y
+
235,1468
<
Y
 
406
Batch
oil­
emulsion
breaking
with
gravity
flotation
[
requires
sulfuric
acid,
alum,
and
polymer
feed
systems]
See
dissolved
air
flotation.
Y
<
100
A
=[(
0.65
x
Y
+
49.7)
x
HPD
x
DPY
x
0.047]
+
[
HPD
x
DPY
x
29.67]
+
[(
DPY/
5)
x
29.67]
+

[
0.022
x
Y
x
60
x
HPD
x
DPY
x
0.86]
100
 
Y
 
300
C
=
17,204
x
Y
+
2,000,000
Chromium
reduction
system,
sodium
metabisulfite
A
=[
2.4225
x
HPD
x
DPY
x
0.047]
+
[
0.002608
x
Y
x
60
x
HPD
x
DPY]
+
[(
HPD/
8)
x
DPY
x
29.67]
+
[(
DPY/
5)
x
29.67]
Y
 
45
C
=
20,892
Y
 
1
C
=
261.7
x
Y
+
24,2491
<
Y
 
45
Alkaline
chlorination
with
hypochlorite
feed
system
(
for
cyanide
destruction)
A
=[
4.845
x
HPD
x
DPY
x
0.047]
+
[
0.012418
x
Y
x
HPD
x
DPY
x
60]
+
[
0.125
x
HPD
x
DPY
x
29.67]
+
[(
DPY/
5)
x
29.67]
Y
 
200
C
=
28,862
Y
 
1
C
=
29,793
x
Y0.191
<
Y
 
200
Chelation
breaking
with
dithiocarbamate
treatment
A
=[
2.4225
x
HPD
x
DPY
x
0.047]
+
[
0.000583
x
Y
x
60
x
HPD
x
DPY]
+
[(
HPD/
8)
x
DPY
x
29.67]
+
[(
DPY/
5)
x
29.67]
Y
 
45
C
=
20,892
Y
 
1
C
=
261.7
x
Y
+
24,2491
<
Y
 
45
11­
47
Table
11­
13
(
Continued)
11.0
­
Costs
of
Technology
Bases
for
Regulations
EquipmentEquationRange
of
Validity
Chemical
precipitation
[
requires
sulfuric
acid,

caustic,
and
polymer
feed
systems]
A
=[
0.932
x
HPD
x
DPY
x
0.047]
+
[(
DPY/
5)
x
29.67]
+
[(
HPD/
8)
x
DPY
x
29.67]
Y
<
5
C
=
8,900
Y
 
0.5
C
=
626.6
x
Y
+
8,5500.5
<
Y
<
5
A
=[[(
0.0571
x
Y)
+
0.0123]
x
HPD
x
DPY
x
0.047]
+
[(
DPY/
5)
x
29.67]
+
[(
HPD/
8)
x
DPY
x
29.67]
5
 
Y
 
350
C
=
784.54
x
Y
+
34,216
Clarifier,
slant­
plate
(
lamella)
A
=
2
x
(
DPY/
5)
x
29.67Y
 
400
C
=
9,740Y
<
2
C
=
15,0572
 
Y
<
10
C
=
74.896
x
Y
+
31,40110
 
Y
 
400
Filtration,
multimediaA
=
[[(
0.0504
x
Y)
+
1.0139]
x
HPD
x
DPY
x
0.047]
+
[(
HPD/
8)
x
DPY
x
29.67]
+
[(
DPY/
5)
x
29.67]
Y
 
800
C
=
35,115
Y
 
15
C
=
240.85
x
Y
+
27,26915
<
Y
 
800
Microfiltration
system
for
metals
removal
A
=[(
0.3
x
Y
+
6.3)
x
HPD
x
DPY
x
0.047]
+
[
3.4
x
Y]
+
[
0.5
x
HPD
x
DPY
x
29.67]
+

[(
DPY/
5)
x
29.67]
+
[
184.2
x
Y
+
155.2]
Y
 
400
C
=
74,081
Y
 
5
C
=
1,728.3
x
Y
+
69,3375
<
Y
 
400
Sludge
thickeningA
=[
0.246
x
HPD
x
DPY
x
0.047]
+
[
2
x
(
DPY/
5)
x
29.67]
Y
<
0.5
C
=
74.306
x
Y
x
60
+
3,746
A
=[
3.7
x
HPD
x
DPY
x
0.047]
+
[
2
x
(
DPY/
5)
x
29.67]
0.5
 
Y
 
45
C
=
2334.8
x
Y
+
77,429
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
13
(
Continued)

Equipment
Equation
Range
of
Validity
Filter
press,
plate­
and­

frame
A
=
[(
60
+
(
30
x
DPY
x
2))
x
NUM]
+
[
FT3
x
DPY
x
7.48
x
1.95]
CFT3
 
6
A
=
[(
60
+
(
60
x
DPY
x
2))
x
NUM]
+
[
FT3
x
DPY
x
7.48
x
1.95]
CFT3
 
12
A
=
[(
60
+
(
90
x
DPY
x
2))
x
NUM]
+
[
FT3
x
DPY
x
7.48
x
1.95]
CFT3
>
12
C
=
[
1,658.8
x
FT3]
+
17,505
0.85
<
T3
 
76.5
F
aAll
costs
are
calculated
in
2001
dollars.

Variable
Definitions:

C
 
Direct
capital
costs
(
1996
dollars).

A
 
Annual
costs
(
1996
dollars).

Y
 
Influent
equipment
flow
(
gallons
per
minute).

HPD
 
Operating
hours
per
day.

DPY
 
Operating
days
per
year.

FT3
 
Daily
cake
volume
(
FT3)
from
all
presses.

IPFLOW
 
GPH
TANKVOL
 
Volume
of
countercurrent
rinsing
tank
(
gallons).

CCFLOW
 
Flow
rate
after
countercurrent
rinsing
is
supplied
(
gallons
per
minute).

kW
 
Kilowatts.

CFT3
 
Cake
volume
(
FT3)
per
cycle
per
press
(
assume
two
cycles
per
day).

NUM
 
Number
of
units.

TSS
 
Influent
TSS
concentration
(
mg/
L).

11­
48
11.0
­
Costs
of
Technology
Bases
for
Regulations
11.6.4
Contracting
for
Off­
Site
Treatment
and
Disposal
The
Agency
estimated
costs
for
off­
site
treatment
and
disposal
of
various
types
of
wastes
generated
on
site.
These
waste
types
include:

 
Painting
and
paint
stripping/
solvent
wastewater;

 
Paint
sludge;

 
Wastewater
containing
oil
and
grease
and
organic
pollutants;

 
Waste
oils/
sludges;

 
Chromium­
bearing
wastewater;

 
Cyanide­
bearing
wastewater;

 
Chelated
metal­
bearing
wastewater;

 
General
metal­
bearing
wastewater;
and
 
Metal­
bearing
sludge.

Except
for
F006
hazardous
waste,
EPA
estimated
costs
for
off­
site
transportation
and
treatment/
disposal
of
each
waste
type
in
dollars
per
gallon
of
waste
using
averages
of
cost
data
provided
in
the
1996
MP&
M
Detailed
Survey
for
off­
site
disposal
of
specific
wastewater
streams.
EPA
applied
these
costs
throughout
the
cost
model
using
the
logic
in
Table
11­
14.

11.6.5
Feed
Systems
and
Chemical
Dosages
Feed
systems
are
components
of
almost
every
option
technology.
EPA
developed
three
types
of
cost
modules
for
feed
systems:
treatment­
specific,
generic,
and
low­
flow.
EPA
determined
dosage,
equipment,
and
other
design
specifics
for
treatment­
specific
feed
systems,
whenever
data
were
available.
For
feed
systems
with
no
specific
information
available,
EPA
developed
a
generic
feed
system
module,
using
literature
or
engineering
judgement
to
select
dosages
and
equipment.
For
feed
systems
with
low­
flow
treatment
systems,
EPA
developed
low­
flow
polymer,
sodium
hydroxide,
sulfuric
acid,
alum,
lime,
and
ferric
sulfate
feed
modules,
with
lower
fixed
capital
and
energy
costs
for
flow
rates
of
less
than
600
gallons
per
hour.
EPA
also
developed
lower
energy
costs
for
alum
feed
systems
with
flow
rates
below
350
gallons
per
minute.
Table
11­
15
lists
the
treatment
technologies
that
use
feed
systems.

11­
49
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
14
Logic
Used
for
Off­
Site
Treatment
and
Disposal
Cost
Estimates
Type
of
Waste
Estimated
Cost
Data
Source
Painting
and
paint
stripping
wastewater
$
2.85
per
gallon
Costs
for
off­
site
disposal
of
solvent­
bearing
wastewater
as
reported
in
the
1996
MP&
M
Detailed
Survey
Paint
sludge
generated
by
the
painting
water
curtain
centrifugation
system
$
3.70
per
gallon
Average
values
reported
in
the
1996
MP&
M
Detailed
Surveys
for
hazardous
and
nonhazardous
waste
Wastewater
bearing
oil
and
grease
or
other
organic
pollutants
$
1.33
per
gallon
Values
reported
in
the
1996
MP&
M
Detailed
Survey
Waste
oil
generated
by
machining
coolant
centrifugation
and
pasteurization,
chemical
emulsion
breaking
and
gravity
oil/
water
separation,
dissolved
air
flotation,
and
ultrafiltration
$
0.86
per
gallon
Values
reported
in
the
1996
MP&
M
Detailed
Survey
Waste
sludge
generated
by
dissolved
air
flotation
$
0.86
per
gallon
Values
reported
in
the
1996
MP&
M
Detailed
Survey
Hexavalent
chromium­
bearing
wastewater
$
3.51
per
gallon
Values
reported
in
the
1996
MP&
M
Detailed
Survey
Cyanide­
bearing
wastewater
$
5.64
per
gallon
Values
reported
in
the
1996
MP&
M
Detailed
Survey
Chelated
metal­
bearing
wastewater
$
1.40
per
gallon
Values
reported
in
the
1996
MP&
M
Detailed
Survey
Metal­
bearing
wastewater
$
2.00
per
gallon
Values
reported
in
the
1996
MP&
M
Detailed
Survey
Metal­
bearing
sludge,
generated
by
the
sludge
pressure
filtration
system
and
the
machining
coolant
centrifugation
and
pasteurization
system
$
1.95
per
gallon
The
value
reported
in
Pollution
Prevention
and
Control
Technology
for
Plating
Operations
(
4)
for
F006
hazardous
wastes
Additional
details
are
provided
in
Section
6.7.1
of
the
rulemaking
record,
DCN
16023.

11­
50
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
15
Treatment
Technologies
That
Use
Feed
Systems
Treatment
Technology
Feed
Systems
Required
Chemical
emulsion
breaking
and
gravity
oil/
water
separation
Sulfuric
acid
Polymer
Alum
Dissolved
air
flotation
Lime
Ferric
sulfate
Polymer
Batch
oil
emulsion
breaking
with
gravity
flotation
Polymer
Sulfuric
acid
Alum
Chemical
reduction
of
hexavalent
chromium
Sulfuric
acid
Sodium
metabisulfite
Cyanide
destruction
Sodium
hydroxide
Sulfuric
acid
Sodium
hypochlorite
Chemical
reduction/
precipitation
of
chelated
metals
Sulfuric
acid
Dithiocarbamate
Chemical
precipitation
Sulfuric
acid
Polymer
Caustic
Sources:
Pollution
Prevention
and
Control
Technology
for
Plating
Operations
(
4)
and
MP&
M
Sampling
Data.

To
determine
the
required
chemical
dosage
for
each
technology,
the
Agency
used
either
the
Pollution
Prevention
and
Control
Technology
for
Plating
Operations
(
4)
or
chemical
usage
data
from
sampled
MP&
M
sites
with
the
option
technology
in
place.
Table
11­
16
lists
the
chemical
dosage
used
to
estimate
costs
and
the
source
from
which
the
dosage
was
derived.

Capital
and
annual
costs
from
feed
systems
were
not
reported
individually
in
cost
model
outputs
but
were
added
into
the
overall
treatment
system
capital
and
annual
costs.
The
cost
model
included
the
capital
and
annual
costs
for
the
following
equipment
in
the
feed
system
capital
costs:

 
Raw
material
storage
tank;

 
Day
storage
tank
with
mixer;

 
Chemical
metering
pumps;

 
pH
controller;
and
 
Supporting
piping
and
valves.

11­
51
11.0
­
Costs
of
Technology
Bases
for
Regulations
Table
11­
16
Treatment
Dosage
Information
Feed
system
Chemical
Concentration
Required
(
mg/
L)
Data
Source
Polymer
feed
system
20
(
4)

Continuous
sodium
hydroxide
feed
system
1,685
(
4)

Continuous
hydrated
lime
feed
system
376
(
4)

Continuous
sulfuric
acid
feed
system
699
(
4)

Continuous
ferric
sulfate
feed
system
74
(
5)

Continuous
aluminum
sulfate
(
alum)
feed
system
648
(
5)

Continuous
calcium
chloride
feed
system
830
(
4)

Sources:
Pollution
Prevention
and
Control
Technology
for
Plating
Operations
(
4)
and
MP&
M
Sampling
Data.

11.6.6
Chemical
Emulsion
Breaking
and
Gravity
Oil/
Water
Separation
EPA
estimated
costs
for
chemical
emulsion
breaking
and
gravity
oil/
water
separation
systems
to
separate
and
remove
oil
and
grease
and
TSS.
The
Agency
assumed
that
model
sites
commingled
all
oil­
bearing
wastewater
streams
prior
to
treatment.
Table
11­
12
lists
the
unit
operations
that
discharge
wastewater
streams
that
feed
oil
removal
treatment
units.

For
chemical
emulsion
breaking
systems,
the
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Flow
equalization
tank;

 
Two
emulsion
breaking
tanks;

 
Two
mixers;

 
Sulfuric
acid
feed
system
(
see
Section
11.6.5);

 
Polymer
feed
system
(
see
Section
11.6.5);

 
Alum
feed
system
(
see
Section
11.6.5);

 
Sodium
hydroxide
feed
system
(
see
Section
11.6.5);
and
 
Wastewater
pumps.

Emulsion
breaking
was
followed
by
oil
removal
using
a
coalescent
plate
separator.
For
oil
removal
systems,
EPA
estimated
capital
and
annual
costs
for
the
following
equipment:

 
Feed
pumps;

 
Belt
skimmer;
and
 
Oil/
water
separator.

11­
52
11.0
­
Costs
of
Technology
Bases
for
Regulations
Direct
annual
costs
included
O&
M
labor
and
materials,
energy
costs,
raw
materials
(
e.
g.,
sulfuric
acid,
alum,
polymer,
sodium
hydroxide),
and
waste
oil
disposal
costs.
EPA
also
included
costs
for
off­
site
reclamation
of
waste
oil.
EPA
also
estimated
waste
oil
generation
to
be
7.1
percent
of
the
influent
flow,
based
on
MP&
M
survey
data.

11.6.7
Dissolved
Air
Flotation
For
the
Shipbuilding
Dry
Dock
Subcategory,
EPA
estimated
costs
for
dissolved
air
flotation
systems
to
separate
and
remove
oil
and
grease,
suspended
solids,
and
organic
pollutants.
The
Agency
assumed
that
shipbuilding
model
sites
commingled
all
oil­
bearing
wastewater
streams
prior
to
treatment.

The
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Flow
equalization
tank;

 
Feed
pumps;

 
Oil/
water
separator;

 
Chemical
treatment
tank;

 
Lime
feed
system
(
see
Section
11.6.5);

 
Ferric
sulfate
feed
system
(
see
Section
11.6.5);

 
Polymer
feed
system
(
see
Section
11.6.5);

 
Dissolved
air
flotation
system
with
pressure
tank
and
programmable
logic
controller
(
PLC);

 
Oil
storage
tank;
and
 
Final
pH
adjustment
tank.

Direct
annual
costs
included
O&
M
labor
and
materials,
energy
costs,
raw
materials
(
e.
g.,
hydrated
lime,
ferric
sulfate,
polymer),
and
waste
oil
and
sludge
disposal
costs.
EPA
also
estimated
costs
for
off­
site
reclamation
of
the
waste
oil
and
sludge.
Hydrated
lime
and
ferric
sulfate
flows
were
added
to
the
discharge
flow,
while
polymer
volume
was
considered
negligible.
EPA
estimated
generation
of
waste
oil
and
sludge
as
7.1
and
0.03
percent
of
the
influent
flow,
respectively,
based
on
the
MP&
M
survey
data.
Because
dissolved
air
flotation
systems
are
not
typically
used
for
flow
rates
of
less
than
265
gallons
per
hour
(
gph),
EPA
estimated
costs
for
ultrafiltration
oil
removal
for
model
sites
with
flows
of
less
than
265
gph.

11­
53
11.0
­
Costs
of
Technology
Bases
for
Regulations
11.6.8
Ultrafiltration
System
for
Oil
Removal
EPA
estimated
costs
for
ultrafiltration
systems
to
separate
and
remove
oil
and
grease,
suspended
solids,
and
organic
pollutants.
This
technology
differs
from
chemical
emulsion
breaking
with
oil/
water
separation,
which
was
used
to
develop
Option
6
costs
(
see
11.6.6).
The
Agency
assumed
that
model
sites
commingled
all
oil­
bearing
wastewater
streams
prior
to
treatment
and
that
flow
rates
greater
than
the
maximum
costed
system
(
406
gallons
per
minute)
required
multiple
systems.

The
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Spiral­
wound
membrane
filtration
modules;

 
Process
and
chemical
tanks;

 
Steel
skid;

 
Recirculation
tank;

 
Recirculation
pump;

 
Bag
filter;

 
Fix­
mounted
cleaning
system;

 
Sludge
pump;
and
 
Electrical
components
(
pH
control/
monitoring,
temperature
control,
flow
meter,
pressure
gauges).

Direct
annual
costs
included
O&
M
labor
and
materials,
energy
costs,
cleaning
chemicals,
membrane
replacement,
and
waste
oil
disposal
costs.
EPA
estimated
costs
for
off­
site
reclamation
of
waste
oil.
EPA
estimated
waste
oil
generation
as
5.2
percent
of
the
influent
flow,
based
on
MP&
M
survey
data.

11.6.9
Batch
Oil
Emulsion
Breaking
with
Gravity
Flotation
EPA
estimated
costs
for
batch
oil
emulsion
breaking
with
gravity
flotation
systems
to
separate
and
remove
oil
and
grease,
suspended
solids,
and
organic
pollutants.
This
technology
differs
from
chemical
emulsion
breaking
with
oil/
water
separation,
which
was
used
to
develop
Option
6
costs
(
see
11.6.6).
Gravity
flotation
uses
a
large
tank,
with
oil
recovered
over
weirs,
and
is
typically
seen
at
large
sites
such
as
automotive
manufacturing.
The
Agency
assumed
that
model
sites
commingled
all
oil­
bearing
wastewater
streams
prior
to
treatment.

11­
54
11.0
­
Costs
of
Technology
Bases
for
Regulations
Although
batch
emulsion
breaking
with
gravity
flotation
is
not
part
of
the
MP&
M
technology
options,
EPA
estimated
baseline
operating
costs
and
pollutant
removals
for
sites
that
had
this
technology
in
place
at
baseline.
The
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Polymer
feed
system
(
see
Section
11.6.5);

 
Sulfuric
acid
feed
system
(
see
Section
11.6.5);

 
Alum
feed
system
(
see
Section
11.6.5);

 
Two
mechanically
cleaning
bar
screens;

 
Three
batch
wastewater
treatment
tanks;

 
Two
segregated
waste
tanks;

 
Three
skim
and
saleable
oil
storage
tanks;

 
Two
oil
cooking
tanks;

 
Pumps;

 
One
air
compressor;

 
Six
mixers
(
segregation,
saleable
oil,
and
oil
cooker
tanks);
and
 
Ancillary
equipment
(
pipes
and
valves,
heat
trace,
controls,
and
programmable
logic
controller
(
PLC)).

Direct
annual
costs
included
O&
M
labor,
energy
costs,
raw
materials
(
e.
g.,
polymer,
sulfuric
acid,
alum),
and
waste
oil
disposal
costs.
EPA
also
estimated
costs
for
off­
site
reclamation
of
waste
oil.
Flows
from
sulfuric
acid
and
alum
were
added
to
the
treatment
flow,
while
the
polymer
volume
was
considered
negligible.
EPA
assumed
the
model
sites
discharged
treatment
effluent
to
the
chemical
precipitation
and
sedimentation
system.
EPA
estimated
generation
of
waste
oil
as
2.2
percent
of
the
influent
flow,
based
on
MP&
M
survey
data.
This
technology
is
typically
used
for
flow
rates
of
greater
than
6,000
gallons
per
hour,
whereas
dissolved
air
flotation
is
used
for
flow
rates
of
between
265
and
6,000
gallons
per
hour
and
ultrafiltration
for
oil
removal
for
flow
rates
of
less
than
265
gallons
per
hour.

11.6.10
Chemical
Reduction
of
Hexavalent
Chromium
EPA
estimated
costs
for
batch
and
continuous
systems
to
reduce
hexavalent
chromium
to
trivalent
chromium
prior
to
chemical
precipitation
and
sedimentation.
Note
that
the
sedimentation
portion
of
this
treatment
is
discussed
in
Section
11.6.14.
The
Agency
assumed
that
model
sites
commingled
all
chromium­
bearing
wastewater
streams
prior
to
treatment
and
that
all
chromium
in
the
wastewater
was
in
the
hexavalent
form.

The
Agency
estimated
costs
for
batch
treatment
for
flow
rates
of
less
than
or
equal
to
600
gallons
per
day
and
continuous
systems
for
flow
rates
of
greater
than
600
gallons
per
day.
The
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Fiberglass
reaction
tank;

 
Mixer;

 
Sulfuric
acid
feed
system;

11­
55
11.0
­
Costs
of
Technology
Bases
for
Regulations
 
Sodium
metabisulfate
feed
system;

 
Flow
equalization
tank;

 
Effluent
pump;
and
 
pH
and
oxidation­
reduction
potential
(
ORP)
meters.

Direct
annual
costs
included
O&
M
labor
and
materials,
energy
costs,
and
raw
materials
(
e.
g.,
sulfuric
acid,
sodium
metabisulfite).
EPA
based
flow­
dependent
costs
on
the
volume
of
wastewater
from
chromium­
bearing
unit
operations
flowing
into
the
system,
before
treatment
chemicals
were
added
to
the
flow.
EPA
assumed
model
sites
discharged
the
treatment
effluent
to
the
chemical
precipitation
and
sedimentation
system.

11.6.11
Cyanide
Destruction
EPA
estimated
costs
for
batch
and
continuous
alkaline
chlorination
systems
to
destroy
cyanide
prior
to
chemical
precipitation
and
sedimentation.
The
Agency
assumed
that
model
sites
commingled
all
cyanide­
bearing
wastewater
streams
prior
to
treatment
and
did
not
send
cyanide­
free
wastewater
streams
to
the
cyanide
destruction
system.

The
Agency
estimated
costs
for
batch
treatment
for
flow
rates
of
less
than
or
equal
to
600
gallons
per
day
and
continuous
systems
for
flow
rates
of
greater
than
600
gallons
per
day.
The
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Two
reaction
tanks
(
batch
treatment
uses
a
single
tank,
with
the
second
tank
operating
as
a
batch­
holding
tank);

 
Mixers;

 
Sodium
hydroxide
feed
system;

 
Sulfuric
acid
feed
system;

 
Sodium
hypochlorite
feed
system;

11­
56
11.0
­
Costs
of
Technology
Bases
for
Regulations
 
Effluent
pumps;
and
 
pH
and
ORP
meters.

Direct
annual
costs
included
O&
M
labor
and
materials,
energy
costs,
and
raw
materials
(
e.
g.,
sodium
hydroxide,
sulfuric
acid,
sodium
hypochlorite).
EPA
based
flow­
dependent
costs
on
the
volume
of
wastewater
from
cyanide­
bearing
unit
operation
flowing
into
the
system,
before
treatment
chemicals
were
added
to
the
flow.
The
Agency
assumed
model
sites
discharged
the
treatment
effluent
to
the
chemical
precipitation
and
sedimentation
system.
EPA
also
assumed
that
all
other
pollutant
concentrations
remained
unchanged
in
this
treatment
unit.

11.6.12
Chemical
Reduction/
Precipitation
of
Chelated
Metals
EPA
estimated
costs
for
batch
and
continuous
chemical
reduction/
precipitation
of
chelated
metal
systems
to
break
and
precipitate
electroless
plating
complexes
(
e.
g.,
copper
or
nickel
complexes)
prior
to
chemical
precipitation
and
sedimentation.
The
Agency
assumed
that
model
sites
commingled
all
chelated
metal­
bearing
wastewater
streams
prior
to
treatment.

The
Agency
estimated
costs
for
batch
treatment
for
flow
rates
of
less
than
or
equal
to
600
gallons
per
day
and
continuous
systems
for
flow
rates
of
greater
than
600
gallons
per
day.
The
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Fiberglass
reaction
tank;

 
Mixer;

 
Sulfuric
acid
feed
system;

 
Dithiocarbamate
feed
system
(
see
Section
8.4.4);

 
Flow
equalization
tank;

 
Effluent
pump;
and
 
pH
and
ORP
meters.

Direct
annual
costs
included
O&
M
labor
and
materials,
energy
costs,
and
raw
materials
(
e.
g.,
sulfuric
acid,
dithiocarbamate).
EPA
based
flow­
dependent
costs
on
the
volume
of
wastewater
from
chelated
metal­
bearing
unit
operations
flowing
into
the
system,
before
treatment
chemicals
were
added
to
the
flow.
The
Agency
assumed
that
model
sites
discharged
treatment
effluent
to
the
chemical
precipitation
and
sedimentation
system.
Based
on
analytical
data
for
the
systems
EPA
sampled,
EPA
assumed
that
concentrations
of
carbon
disulfide
and
dithiocarbamate
increased
across
the
system.

11.6.13
Chemical
Precipitation
The
Agency
estimated
costs
for
continuous
chemical
precipitation
systems.
EPA
estimated
costs
for
low­
flow
systems
for
model
sites
with
influent
flow
rates
of
less
than
or
equal
to
300
gallons
per
hour.
EPA
assumed
that
the
model
sites
commingled
all
MP&
M
wastewater
generated
for
treatment
by
this
technology,
except
for
wastewater
from
the
Oily
Wastes,

11­
57
11.0
­
Costs
of
Technology
Bases
for
Regulations
Shipbuilding
Dry
Dock,
and
Railroad
Line
Maintenance
Subcategories.
In
addition,
EPA
assumed
that
sites
would
contract
for
off­
site
disposal
of
solvent­
bearing
wastewater.

The
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Sulfuric
acid
feed
system
(
see
Section
11.6.5);

 
Polymer
feed
system
(
see
Section
11.6.5);

 
Caustic
feed
system
(
see
Section
11.6.5);

 
Equalization
tank;

 
Rapid­
mix
tank
for
precipitation;

 
Flocculation
tank;

 
Final
pH­
adjustment
tank;

 
System
feed
pumps;
and
 
Rapid
and
flocculation
mixers.

Direct
annual
costs
included
O&
M
labor,
energy
costs,
and
raw
materials
(
e.
g.,
sulfuric
acid,
polymer,
caustic).
The
module
assumed
that
the
amount
of
TSS
leaving
the
chemical
precipitation
system
was
equivalent
to
the
sum
of
influent
TSS
and
the
dissolved
solids
that
are
converted
to
suspended
solids
when
caustic
is
added
to
the
wastewater.
The
approach
for
calculating
suspended
solids
generated
from
dissolved
solids
is
documented
in
Section
6.7.1
of
the
rulemaking
record,
DCN
16363.
EPA
estimated
that
the
effluent
flow
rate
from
this
system
equaled
the
influent
flow
rate
because
additional
flow
from
treatment
chemical
addition
was
negligible.
EPA
designed
the
cost
model
to
include
recycled
water
from
the
sludge
thickener
and
filter
press.
In
addition,
the
Agency
assumed
that
model
sites
discharged
effluent
from
the
chemical
precipitation
system
to
either
clarification
or
microfiltration.

11.6.14
Sedimentation
by
Slant­
Plate
Clarifier
The
Agency
estimated
costs
for
sedimentation
using
slant­
plate
(
lamella)
clarifier
systems.
EPA
estimated
costs
for
low­
flow
systems
for
model
sites
with
influent
flow
rates
of
less
than
or
equal
to
600
gallons
per
hour.
EPA
designed
this
system
to
treat
effluent
from
the
chemical
precipitation
system.

The
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Slant­
plate
clarifier;
and
 
One­
time
training
costs
for
operators
to
meet
MP&
M
clarifier
limits
instead
of
the
baseline
40
CFR
433
Metal
Finishing
effluent
guideline
limits
(
see
Section
24.6.1,
DCN
17906,
of
the
rulemaking
record).

EPA
estimated
costs
associated
with
achieving
long­
term
average
effluent
concentrations
for
all
pollutants
treated
by
chemical
precipitation
with
clarification
(
see
Section
10.3).
EPA
calculated
the
amount
of
sludge
generated
using
model­
calculated
site­
specific
11­
58
11.0
­
Costs
of
Technology
Bases
for
Regulations
influent
pollutant
concentrations
for
the
commingled
wastewater.
The
Agency
assumed
the
sludge
was
3
percent
solids
(
5)
and
was
discharged
to
a
sludge­
thickening
tank
(
see
Section
11.6.17)
and
that
model
sites
discharged
treatment
effluent
to
surface
water
or
a
POTW.
Direct
annual
costs
included
maintenance
labor
and
materials.
EPA
included
costs
for
operating
labor
in
the
chemical
precipitation
module
and
included
costs
for
pumps
in
the
chemical
precipitation
and
the
sludge­
thickening
modules.

11.6.15
Multimedia
Filtration
The
Agency
estimated
costs
for
a
multimedia
filter
to
continuously
remove
filterable
suspended
solids.
The
system
was
designed
as
a
polishing
step
for
effluent
from
the
clarifier.
Although
EPA
did
not
include
this
technology
in
the
MP&
M
technology
options,
it
estimated
baseline
operating
costs
and
pollutant
removals
for
sites
that
had
multimedia
filters
in
place
at
baseline.

The
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Multimedia
filter
skid;

 
Holding
tank
for
clarifier
effluent
(
clear
well);
and
 
Media
filter
feed
pump.

Based
on
data
collected
during
an
MP&
M
sampling
episode,
the
Agency
assumed
filter
backwash
to
be
1.2
percent
of
the
influent
flow
to
the
chemical
precipitation
unit
and
that
model
sites
discharged
filtrate
from
this
system
to
surface
water
or
a
POTW.
Direct
annual
costs
included
O&
M
labor
and
energy
costs.
EPA
incorporated
waste
disposal
costs
for
solids
at
sites
operating
multimedia
filters.

11.6.16
Microfiltration
for
Solids
Removal
The
Agency
estimated
costs
for
microfiltration
for
solids
separation,
assuming
that
flow
rates
of
greater
than
the
maximum
costed
system
(
406
gallons
per
minute)
required
multiple
systems.

The
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Tubular
membrane
filtration
modules;

 
Carbon
steel
skid;

 
Recirculation
tank;

 
Recirculation
pump;

 
Air
back
pulse
system;

 
Cleaning
system;

11­
59
11.0
­
Costs
of
Technology
Bases
for
Regulations
 
Sludge
pump;
and
 
All
associated
instruments
and
controls.

EPA
calculated
the
amount
of
sludge
generated
by
this
system
using
model­
calculated
site­
specific
influent
pollutant
concentrations
for
the
commingled
wastewater.
Based
on
data
collected
during
an
MP&
M
sampling
episode,
the
Agency
assumed
the
sludge
was
3.2
percent
solids
and
was
discharged
to
a
sludge­
thickening
tank
(
see
Section
11.6.17).
EPA
assumed
model
sites
discharged
microfiltration
effluent
to
surface
water
or
a
POTW.
Direct
annual
costs
included
O&
M
labor
and
materials
(
e.
g.,
replacement
membranes,
cleaning
chemicals)
and
energy
costs.

11.6.17
Sludge
Thickening
The
Agency
estimated
costs
for
sludge
thickening
by
gravity
settling
for
the
sludge
discharged
from
slant­
plate
clarifiers
and
microfilters.
EPA
assumed
the
sludge­
thickening
system
discharged
60
percent
of
influent
flow
as
sludge,
thus
increasing
the
solids
content
of
the
sludge
from
3
to
5
percent
for
clarifier
sludges
and
from
3.2
to
5.3
percent
for
microfiltration
sludges
(
6).
EPA
assumed
that
the
model
sites
discharge
thickened
sludge
to
a
pressure
filter
for
further
dewatering
(
see
Section
11.6.18),
and
that
they
returned
the
remaining
40
percent
of
influent
flow
(
supernatant)
to
the
chemical
precipitation
system.
The
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Sludge­
thickening
unit
(
package
system);
and
 
Clarified
water
return
pump.

Direct
annual
costs
included
O&
M
labor
and
energy
costs.

11.6.18
Sludge
Pressure
Filtration
The
Agency
estimated
costs
for
the
plate­
and­
frame
filter
presses,
estimating
the
number
needed
to
increase
the
solids
content
of
the
sludge
from
approximately
5
to
35
percent
(
5).
The
module
included
capital
and
annual
costs
for
the
following
equipment:

 
Recessed
plate
or
plate­
and­
frame
filter
press;
and
 
Two
double­
diaphragm
sludge
pumps.

Direct
annual
costs
included
O&
M
labor
and
sludge
disposal
costs.
EPA
assumed
model
sites
contracted
for
off­
site
disposal
of
the
denatured
sludge
(
see
Section
11.3.2
and
Table
11­
4).
EPA
also
assumed
these
sites
discharged
the
filtrate
from
this
system
to
the
chemical
precipitation
and
sedimentation
system.

11­
60
11.0
­
Costs
of
Technology
Bases
for
Regulations
11.7
References
1.
RS
Means
Building
Construction
Cost
Data
,
56th
Annual
Edition.
1998,
page
594.
Historical
Cost
Indexes.

2.
Chemical
Marketing
Reporter.
December
1997.

3.
U.
S.
Bureau
of
Labor
Statistics.
Monthly
Labor
Review
.
1997.

4.
Cushnie,
George
C.,
CAI
Engineering
(
prepared
for
NCMS/
NAMF).
Pollution
Prevention
and
Control
Technology
for
Plating
Operations
.

5.
Cherry,
Kenneth
F.
Plating
Waste
Treatment
.
Chapter
3.
Ann
Arbor
Sciences
Publishers,
Inc.,
Ann
Arbor,
MI,
1982.

6.
Eckenfelder,
W.
Wesley.
Principals
of
Water
Quality
Management
.
Chapter
11.
CBI
Publishing
Company,
1980.

11­
61
11.0
­
Costs
of
Technology
Bases
for
Regulations
11­
62
Figure
11­
1.
Relationship
Between
In­
Process
and
End­
of­
Pipe
Technologies
and
Practices
11.0
­
Costs
of
Technology
Bases
for
Regulations
11­
63
Figure
11.2.
ponents
of
Total
Capital
InvestmentsCom
11.0
­
Costs
of
Technology
Bases
for
Regulations
11­
64
Figure
11­
3.
pply
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
Logic
Used
to
A
11.0
­
Costs
of
Technology
Bases
for
Regulations
11­
65
Figure
11­
4.
pply
End­
of­
Pipe
Technologies
and
Practices
for
the
Following
Subcategories:
Oily
Wastes,
Railroad
Line
Maintenance,
and
Shipbuilding
Dry
Dock
Logic
Used
to
A
11.0
­
Costs
of
Technology
Bases
for
Regulations
11­

66
Figure
11­
5.
Example
Treatment
Facility
for
General
Metals
Subcategory
Direct
Discharger
12.0
­
Pollutant
Loading
and
Reduction
Estimates
12.0
POLLUTANT
LOADING
AND
REDUCTION
ESTIMATES
This
section
describes
EPA s
approach
for
modeling
the
MP&
M
industry
annual
pollutant
loadings
and
removals
for
each
technology
option
described
in
Section
9.0.
In
general,
this
approach
consists
of
three
major
steps:

1.
Estimate
baseline
pollutant
loading
from
each
MP&
M
model
site.
Wastewater
discharged
from
MP&
M
unit
operations
goes
to
either
on­
site
treatment,
publicly
owned
treatment
works
(
POTWs),
or
directly
to
surface
waters.
EPA
used
survey
data
from
each
model
site
to
determine
the
destination
of
each
waste
stream.
EPA
estimated
discharged
pollutant
concentrations
from:
EPA
sampling
data,
industry­
supplied
data,
and
existing
limitations.
EPA
estimated
loadings
by
multiplying
the
discharged
pollutant
concentrations
by
the
discharged
flow.
The
baseline
pollutant
loading
refers
to
the
total
amount
of
pollutants
discharged
from
the
model
site
to
surface
waters
or
POTWs
for
the
base
year
of
the
survey.

2.
Estimate
baseline
pollutant
loadings
for
the
MP&
M
industry.
EPA
multiplied
the
site­
specific
baseline
wastewater
loadings
by
the
corresponding
statistically
derived
weighting
factors
(
see
Section
3.0)
for
each
model
site.
EPA
summed
the
weighted
loadings
across
all
sites
to
estimate
industry­
wide
baseline
wastewater
pollutant
loadings.

3.
Estimate
option­
specific
pollutant
loadings
and
removals
for
the
MP&
M
industry.
The
option­
specific
pollutant
loadings
represent
the
total
industry
pollutant
loadings
in
MP&
M
wastewater
that
would
be
discharged
to
surface
water
or
POTWs
after
complying
with
a
particular
regulatory
option.

Key
terms
for
pollutant
loadings
and
removals
are
defined
below:

 
Model
sites
­
Facilities
used
in
the
EPA
Costs
&
Loadings
Model
to
represent
the
industry
nationally.
These
facilities
responded
in
the
MP&
M
detailed
survey
that
they
discharge
MP&
M
wastewater.

 
Long­
term
average
­
Average
pollutant
concentrations
achieved
over
a
period
of
time
by
a
facility,
subcategory,
or
technology
option.

 
Baseline
concentration
­
Pollutant
concentration
(
milligrams
per
liter
(
mg/
L))
in
wastewater
currently
discharged
to
surface
water
or
a
POTW.
If
the
facility
has
wastewater
treatment
in
place,
the
baseline
concentration
is
the
pollutant
concentration
in
wastewater
discharged
from
final
treatment.
If
the
facility
does
not
have
treatment
in
place,
the
baseline
concentration
is
the
commingled
concentration
of
all
unit
operation
wastewater
discharged.

12­
1
12.0
­
Pollutant
Loading
and
Reduction
Estimates
 
Baseline
loadings
­
Modeled
pollutant
loadings,
in
pounds
per
year
(
lbs/
yr),
in
MP&
M
wastewater
currently
being
discharged
to
surface
water
or
to
POTWs
for
the
base
year
of
the
model
site s
survey.
These
loadings
reflect
wastewater
treatment
in
place
at
model
sites
in
the
year
1996.

 
Option
loadings
­
Also
referred
to
as
post­
compliance
loadings.
Pollutant
loadings,
in
lbs/
yr,
in
MP&
M
wastewater
that
would
be
discharged
to
surface
water
or
to
POTWs
after
complying
with
a
regulatory
option.
EPA
calculated
the
loadings
assuming
that
all
MP&
M
facilities
would
achieve
long­
term
average
effluent
pollutant
concentrations
associated
with
the
technology
options.

 
Pollutant
reductions
­
The
difference
between
baseline
loadings
and
option
loadings
for
each
regulatory
option.

 
Weighting
factor
­
Statistically
derived
values
for
each
model
site
used
to
reflect
all
facilities
in
the
MP&
M
industry.
(
See
Section
10.0,
DCN
16118
of
the
rulemaking
record).
EPA
multiplied
the
baseline
or
option
loadings
for
each
model
site
by
its
corresponding
weighting
factor
to
estimate
industry­
wide
baseline
or
option
loadings.

 
Toxic
pound­
equivalents
­
Pollutant
loadings,
in
pound­
equivalents
per
year
(
PE/
yr),
in
MP&
M
wastewater.
A
pound­
equivalent
(
PE)
is
a
pound
of
pollutant
weighted
for
its
toxicity
to
human
and
aquatic
life.

Unless
specified
otherwise,
EPA
estimated
baseline
pollutant
loadings
and
reductions
for
all
pollutants
identified
in
Section
7.0
as
pollutants
of
concern.
EPA
used
data
from
several
sources
to
estimate
pollutant
loadings
and
reductions,
including
data
from
EPA
sampling
episodes,
the
existing
40
CFR
413
and
433
regulations,
EPA s
Permit
Compliance
System
(
PCS)
database,
pretreatment
coordinators,
states,
and
industry.
See
Section
3.0
for
additional
discussion
on
EPA s
data
collection
efforts.

Note
that
all
tables
appear
at
the
end
of
this
section.

12.1
Estimation
of
Unit
Operation
Wastewater
Pollutant
Concentrations
EPA
used
sampling
data
and
industry­
supplied
data
(
included
in
Sections
5.0
and
15.0
in
the
rulemaking
record)
to
estimate
subcategory­
specific
wastewater
pollutant
concentrations
for
each
of
the
MP&
M
unit
operations
that
generate
wastewater
at
MP&
M
model
sites.

12.1.1
Unit
Operation
Wastewater
Data
Collection
EPA s
 
unit
operations
database 
comprises
EPA
sampling
data
and
industry­
supplied
data.
EPA
collected
unit
operations
wastewater
discharged
from
56
sites
for
96
unit
12­
2
12.0
­
Pollutant
Loading
and
Reduction
Estimates
operations.
Industry
supplied
EPA
with
wastewater
data
for
15
unit
operations.
Throughout
this
section,
the
terms
 
sampling
point 
and
 
sample 
refer
to
the
following:

 
Sampling
point
­
The
physical
location
at
which
samples
are
collected.
Example
sampling
points
include
a
wastewater
treatment
influent
stream,
an
electroplating
bath,
or
a
cleaning
rinse.
A
sampling
point
captures
the
wastewater
characteristics
of
a
specific
unit
operation
or
a
group
of
unit
operations.

 
Sample
­
The
unique
volume
of
wastewater
collected
for
analysis
at
a
sampling
point.
A
sample
can
include
several
different
aliquots
collected
for
analysis
of
multiple
parameters.
Each
sample
represents
a
unique
period
of
time.
EPA
typically
collected
multiple
samples
from
sampling
points
that
represented
flowing
waste
streams
(
e.
g.,
wastewater
treatment
systems,
rinses).

12.1.2
Calculation
of
Pollutant
Concentrations
for
Each
Unit
Operation
for
Each
Sampling
Point
from
EPA
or
Industry­
Supplied
Sampling
Data
EPA
collected
both
grab
and
composite
samples
to
characterize
MP&
M
unit
operations.
EPA
generally
collected
grab
samples
for
nonflowing
streams
where
the
pollutant
concentrations
were
not
expected
to
vary
significantly
over
the
sampling
period.
EPA
generally
collected
composite
samples
(
typically
24­
hour
composites)
for
flowing
streams.
For
oil
and
grease,
EPA
collected
a
series
of
grab
samples
as
specified
by
the
analytical
method.
In
some
cases,
EPA
had
to
mathematically
aggregate
two
or
more
samples
to
obtain
a
single
value
that
could
be
used
in
calculations
to
represent
a
single
waste
stream.
This
occurred
with
field
duplicates
and
grab
samples
collected
over
time.
For
each
sample
point,
EPA
aggregated
field
duplicates
first,
grab
samples
second,
and
multiple­
day
samples
third.
In
cases
where
the
sampled
pollutants
were
not
detected
in
the
wastewater,
EPA
used
the
sample­
specific
detection
limit
as
the
pollutant
concentration.
EPA
calculated
pollutant
concentrations
for
each
sampling
point
using
the
following
approach:

 
Average
the
duplicate
sample
concentrations.
As
discussed
in
Section
3.0,
EPA
collected
duplicate
samples
at
many
sampling
points
as
a
quality
control
measure.
Industry­
supplied
data
submitted
with
comments
on
the
MP&
M
proposal
also
contained
duplicate
samples.
Where
duplicate
samples
were
collected
at
a
sampling
point,
EPA
averaged
the
concentrations
of
the
two
samples
to
develop
a
single
pollutant
profile
for
the
sampling
point
for
that
24­
hour
period.

 
Average
the
grab
sample
aliquot
concentrations.
EPA
averaged
the
concentrations
of
all
grab
sample
aliquot
fractions
(
i.
e.,
for
oil
and
grease)
collected
during
a
24­
hour
period
in
order
to
estimate
a
representative
24­
hour
composite
for
that
parameter.

12­
3
12.0
­
Pollutant
Loading
and
Reduction
Estimates
 
Average
multiple
sample
concentrations
for
each
sampling
point.
For
flowing
wastewater
streams
(
e.
g.,
rinses),
EPA
and
industry
typically
collected
multiple
samples
at
a
single
sample
point
to
account
for
variability
over
time
of
the
discharges
from
these
streams.
EPA
averaged
the
concentrations
of
the
composite
or
grab
samples
collected
on
each
day
at
the
same
sampling
point.
For
example,
if
EPA
collected
three
one­
day
composite
samples
of
an
acid
treatment
rinse
at
the
same
sampling
point,
it
averaged
the
concentrations
of
each
pollutant
on
each
of
the
three
days
to
develop
a
single
pollutant
profile
for
the
sampling
point
for
that
episode.

12.1.3
Estimation
of
Pollutant
Concentrations
for
Each
Subcategory
and
Unit
Operation
EPA
estimated
pollutant
concentrations
for
each
unit
operation
performed
in
a
given
subcategory
(
as
reported
in
the
MP&
M
detailed
surveys).
For
example,
EPA
estimated
pollutant
concentrations
for
UP­
4
(
acid
treatment
without
chromium)
separately
for
sites
in
the
General
Metals
Subcategory
and
for
sites
in
the
Metal
Finishing
Job
Shops
Subcategory.
For
electroplating
and
electroless
plating
operations,
EPA
estimated
the
pollutant
concentration(
s)
of
the
applied
metal(
s)
separately
from
other
bath
constituents
to
account
for
the
dependancy
of
these
operations
on
high
concentrations
of
the
applied
metal(
s).
EPA
used
the
following
steps
to
estimate
the
subcategory­
specific
unit
operation
wastewater
pollutant
concentrations
at
model
MP&
M
sites:

1.
Identified,
for
each
subcategory,
all
unit
operations
reported
in
the
detailed
surveys
(
see
Section
12.1.3.1);

2.
Estimated
pollutant
concentrations
for
each
unit
operation
in
a
given
subcategory
(
see
Section
12.1.3.2);

3.
Estimated
an
applied
metal
concentration
in
the
bath
and
in
the
rinse
for
each
electroplating
and
electroless
plating
operation
for
each
subcategory
(
see
Section
12.1.3.3);
and
4.
Modeled
pollutant
concentrations
for
each
model
site
unit
operation
(
see
Section
12.1.3.4).

These
steps
are
described
in
the
following
subsections.

12.1.3.1
Identification
of
Unit
Operations
Reported
in
the
Detailed
Surveys
EPA
queried
the
MP&
M
detailed
survey
database
to
identify
all
unit
operations
discharging
wastewater,
as
well
as
all
types
of
electroplating
and
electroless
plating
operations
(
defined
by
applied
metal).

12­
4
12.0
­
Pollutant
Loading
and
Reduction
Estimates
12.1.3.2
Estimation
of
Wastewater
Pollutant
Concentrations
for
Each
Unit
Operation/
Subcategory
Combination
For
each
subcategory,
EPA
calculated
the
average
wastewater
pollutant
concentrations
for
each
unit
operation.
For
example,
EPA
averaged
the
wastewater
pollutant
concentrations
for
all
acid
cleaning
operations
(
using
the
wastewater
pollutant
concentrations
calculated
at
each
sampling
point)
at
facilities
in
the
General
Metals
Subcategory.
EPA
also
separately
estimated
wastewater
pollutant
concentrations
for
unit
operations
for
the
 
zinc
plater 
segments
of
the
Metal
Finishing
Job
Shops
and
General
Metals
Subcategories.

Additionally,
EPA
combined
the
sampling
data
for
all
metal­
bearing
subcategories
(
with
the
exception
of
data
from
printed
wiring
board
facilities1
)
and
calculated
the
average
wastewater
pollutant
concentrations
for
each
unit
operation.
EPA
did
the
same
for
all
oil­
bearing
subcategories.
EPA
used
the
average
unit
operation
concentrations
calculated
for
metal­
bearing
subcategories
and
oil­
bearing
subcategories
to
estimate
pollutant
concentrations
from
unit
operations
in
subcategories
with
no
unit
operation
concentration
data.

Based
on
comments
received
on
the
MP&
M
proposed
rule,
EPA
modified
the
calculation
of
unit
operation
wastewater
pollutant
concentrations
for
the
following
pollutants:

 
Cyanide.
EPA
set
the
cyanide
pollutant
concentration
equal
to
zero
for
all
non­
cyanide­
bearing
unit
operation
wastewaters.
(
EPA
sampling
data
included
incidental
cyanide
concentrations
for
non­
cyanide­
bearing
unit
operations
due
to
drag­
out
or
unspecified
sources.)

 
Total
Sulfide.
EPA
estimated
wastewater
pollutant
concentrations
for
total
sulfide
using
all
results
from
Phase
I
and
II
sampling
(
Method
376.1)
and
an
average
of
the
results
from
Methods
376.2
and
4500­
S2E
from
Phase
III
sampling.
EPA
used
all
three
analytical
methods
(
376.1,
376.2,
and
4500­
S2E)
to
measure
total
sulfide
in
Phase
III
sampling
(
i.
e.,
post­
proposal
sampling);
however,
EPA
did
not
use
sampling
data
from
Method
376.1
from
Phase
III
due
to
possible
interferences.

 
Oil
and
Grease.
EPA
estimated
wastewater
pollutant
concentrations
for
oil
and
grease
using
all
Phase
II
and
III
data,
but
included
Phase
I
data
only
in
cases
where
no
Phase
II
or
III
data
were
available
for
that
unit
operation
in
the
Oily
Wastes,
Railroad
Line
Maintenance,
and
Shipbuilding
Dry
Dock
Subcategories.
EPA
used
a
different
analytical
method
to
measure
for
oil
and
grease
during
Phase
I
sampling
than
during
Phase
II
and
III
sampling.
EPA
used
Method
413.2
during
Phase
I
sampling
(
a
freonextractable
method).
EPA
used
Method
1664
during
Phase
II
and
Phase
III
sampling
(
measures
oil
and
grease
as
hexane
extractable
material).

1EPA
omitted
data
from
the
Printed
Wiring
Board
Subcategory
due
to
the
high
concentration
of
specific
metals
(
i.
e.,
copper)
common
to
primarily
the
printed
wiring
board
industry.

12­
5
12.0
­
Pollutant
Loading
and
Reduction
Estimates
 
Sodium,
Calcium,
and
Total
Dissolved
Solids.
EPA
set
the
wastewater
pollutant
concentrations
for
these
pollutants
equal
to
zero
for
all
unit
operation
wastewaters
in
all
subcategories.
EPA
set
the
pollutant
removals
for
sodium
and
calcium
equal
to
zero
in
response
to
Phase
I
comments
on
the
wide
use
of
these
two
treatment
chemicals,
which
results
in
elevated
removals
estimates.
EPA
set
the
loads
removals
for
total
dissolved
solids
(
TDS)
equal
to
zero
because
many
treatment
chemicals
also
elevate
TDS
concentrations.

Based
on
comments
received
on
the
MP&
M
proposed
rule,
EPA
modified
the
calculation
of
unit
operation
wastewater
pollutant
concentrations
for
the
following
specific
cases:

 
Testing.
EPA
used
data
from
radiator
pressure
testing
operations
to
estimate
unit
operation
wastewater
pollutant
concentrations
for
all
testing
unit
operations
at
model
sites
in
the
oil­
bearing
wastewater
subcategories
and
hydraulic
testing
unit
operations
in
the
metal­
bearing
wastewater
subcategories.
EPA
used
dye
penetrant
testing
data
to
estimate
wastewater
pollutant
concentrations
in
all
other
types
of
testing
in
the
metal­
bearing
wastewater
subcategories.
EPA
did
not
include
the
other
EPA­
sampled
testing
data
(
from
alpha­
case
detection
testing
and
engine
performance
testing
coolant
operations)
based
on
the
unique
composition
of
wastewater
for
these
site­
specific
operations.

 
Unit
Operations
with
a
Greater
Rinse
Concentration
than
Bath
Concentration.
After
averaging
sampling
data
across
samples
for
a
particular
sampling
point,
EPA
found
instances
where
the
modeled
bath
had
a
lower
concentration
than
for
the
same
pollutant
in
the
associated
rinse.
In
these
cases,
EPA
set
the
bath
wastewater
pollutant
concentration
equal
to
the
rinse
wastewater
pollutant
concentration.

Based
on
comments
received
on
the
MP&
M
proposed
rule,
EPA
modified
the
calculation
of
unit
operation
wastewater
pollutant
concentrations
for
certain
pollutants
in
the
Non­
Chromium
Anodizing
Subcategory:

 
Chromium,
Hexavalent
Chromium,
Lead,
and
Cadmium.
EPA
set
the
wastewater
pollutant
concentrations
for
these
pollutants
equal
to
zero
for
all
unit
operation
wastewaters
in
the
Non­
Chromium
Anodizing
Subcategory.
EPA
defined
the
Non­
Chromium
Anodizing
Subcategory
as
sites
that
have
no
chromium
present
in
any
operation
on
site.
Therefore,
EPA
did
not
expect
chromium
or
hexavalent
chromium
to
be
present
at
non­
chromium
anodizing
facilities.
EPA
also
did
not
expect
lead
or
cadmium
to
be
used
in
unit
operations
at
non­
chromium
anodizing
facilities
based
on
the
metal
types
processed
by
this
subcategory.

12­
6
12.0
­
Pollutant
Loading
and
Reduction
Estimates
For
further
details,
refer
to
the
memorandum
entitled
 
MP&
M
Pollutant
Loadings
Methodology
Changes
from
Proposal 
located
in
the
rulemaking
record
(
Section
16.7,
DCN
16764).

12.1.3.3
Estimation
of
Applied
Metal
Concentrations
Using
Available
Analytical
Data
While
the
pollutant
concentrations
in
many
MP&
M
unit
operations
are
somewhat
dependent
on
the
type
of
metal
processed,
pollutant
concentrations
are
heavily
dependent
on
the
applied
metal
in
the
electroplating
and
electroless
plating
operations.
For
example,
chromium
electroplating
operations
and
rinses
contain
higher
concentrations
of
chromium
than
other
metals,
while
electroless
nickel
plating
operations
and
rinses
contain
higher
concentrations
of
nickel
than
other
metals.
EPA
estimated
the
pollutant
concentrations
of
the
plated
metal(
s),
referred
to
as
 
applied 
metals,
separately
from
other
constituents
in
the
bath
and
rinse
to
account
for
the
dependency
of
the
pollutant
concentrations
in
these
operations
and
rinses
on
these
metal(
s).
When
developing
the
model
pollutant
concentrations
for
these
two
unit
operations,
EPA
designated
the
metal(
s)
applied
to
the
surface
of
the
product
as
the
 
applied
metals 
to
distinguish
them
from
other
nonplated
metals
in
the
process
bath.
EPA
also
designated
these
metals
that
wash
off
the
product
during
the
process
rinse
as
the
 
applied
metals 
in
the
rinse.

To
more
adequately
represent
the
metals
concentrations
in
the
wastewater
from
electroplating
and
electroless
plating
operations,
EPA
used
a
different
approach
for
applied
metals
and
other
plating
bath
constituents
in
these
operations.
Due
to
budget
constraints,
EPA
did
not
obtain
sampling
data
for
every
type
of
plating
solution
and
rinse
reported
in
the
detailed
surveys
and
was
therefore
unable
to
estimate
separately
the
pollutant
concentrations
for
each
type
of
plating.
EPA
modeled
the
pollutant
concentrations
in
electroplating
and
electroless
plating
solutions
using
the
following
approach:

1.
EPA
calculated
the
total
applied
metal
concentrations
for
each
plating
bath
for
which
EPA
had
collected
data.
If
a
sampling
point
had
two
applied
metals
(
e.
g.,
zinc
and
cobalt),
the
two
pollutant
concentrations
were
summed
to
get
a
total
applied
metal
concentration.
If
a
sampling
point
had
one
applied
metal,
the
concentration
for
that
metal
was
the
total
applied
metal
concentration.

2.
For
each
subcategory,
EPA
calculated
the
median
total
applied
metal
concentration
for
all
plating
baths
for
which
EPA
had
sampling
data.
EPA
calculated
these
median
concentrations
separately
for
electroplating
and
electroless
plating
baths.
EPA
then
modeled
the
total
metal
concentration
in
the
bath
at
the
model
site
as
the
median
concentration
of
total
metals
for
which
EPA
had
data.
Note
that
the
Agency
had
sufficient
data
to
estimate
the
total
applied
metal
concentration
on
a
subcategory­
specific
basis,
but
not
on
a
pollutant­
specific
basis.
For
subcategories
with
no
available
applied
metal
data,
EPA
used
the
median
of
all
total
applied
metal
concentration
data
across
all
subcategories.

12­
7
12.0
­
Pollutant
Loading
and
Reduction
Estimates
3.
EPA
calculated
the
average
concentration
for
all
nonapplied
pollutants
across
the
plating
baths
(
separating
electroplating
from
electroless
plating
baths).
For
example,
EPA
calculated
the
cadmium
concentration
in
all
baths
other
than
cadmium
electroplating
baths.
EPA
then
modeled
the
concentration
of
the
nonapplied
pollutants
as
the
average
concentration
for
the
pollutant
across
the
plating
baths.

EPA
followed
the
same
approach
for
estimating
pollutant
concentrations
in
electroplating
and
electroless
plating
unit
operation
rinses.
For
further
detail,
refer
to
the
memorandum
entitled
 
MP&
M
Pollutant
Loadings
Data
Transfer
for
Base/
Applied
Metals 
located
in
the
rulemaking
record
(
Section
16.7,
DCN
16763).

12.1.3.4
Modeling
of
Pollutant
Concentrations
for
Each
Model
Site
Unit
Operation
To
estimate
the
pollutant
concentrations
for
each
model
site
unit
operation,
EPA
first
identified
the
unit
operations
performed
by
the
model
sites
in
each
subcategory.
For
unit
operations
for
which
it
had
collected
pollutant
concentration
data,
EPA
modeled
the
wastewater
pollutant
concentrations
using
the
corresponding
unit
operation
average
wastewater
pollutant
concentrations
calculated
from
sampling
data
for
that
unit
operation
in
the
same
subcategory.
For
example,
EPA
calculated
the
average
concentrations
for
all
pollutants
of
concern
identified
in
alkaline
cleaning
operations
in
the
General
Metals
Subcategory,
and
applied
these
average
concentrations
to
all
alkaline
cleaning
operations
reported
in
the
surveys
for
this
subcategory.

When
EPA
did
not
have
pollutant
concentration
data
for
a
unit
operation
within
a
subcategory,
EPA
transferred
pollutant
concentrations
from
unit
operations
expected
to
have
similar
wastewater
characteristics,
based
on
process
considerations.
Process
considerations
include
the
following:
the
purpose
of
the
unit
operation
(
e.
g.,
metal
removal,
contaminant
removal);
the
purpose
of
the
process
water
use
(
e.
g.,
contact
cooling
water,
cleaning
solution,
rinse
water);
and
typical
bath
additives
(
e.
g.,
acids,
organic
solvents,
metal
salts).
EPA
transferred
available
pollutant
concentration
data
to
the
model
sites
using
the
following
hierarchy:

1.
If
EPA
sampled
the
same
unit
operation
bath
(
or
rinse)
at
facilities
in
more
than
one
subcategory,
including
the
same
subcategory
as
the
model
site,
the
Agency
used
available
analytical
data
for
the
same
operation
in
the
same
subcategory
to
estimate
wastewater
pollutant
concentrations
for
the
model
site
unit
operation.
For
example,
if
available
analytical
data
for
a
unit
operation
exist
for
both
the
General
Metals
and
the
Metal
Finishing
Job
Shops
Subcategories,
EPA
transferred
data
from
only
the
General
Metals
Subcategory
to
model
the
wastewater
pollutant
concentrations
for
the
same
unit
operation
at
a
model
site
in
the
General
Metals
Subcategory.

2.
If
EPA
sampled
the
same
unit
operation
bath
(
or
rinse)
at
facilities
in
only
one
MP&
M
subcategory,
even
if
it
is
a
different
subcategory
than
that
of
the
model
site,
the
Agency
transferred
these
data
to
the
same
unit
12­
8
12.0
­
Pollutant
Loading
and
Reduction
Estimates
operation
bath
(
or
rinse)
at
model
sites.
For
example,
if
available
analytical
data
for
a
unit
operation
exist
only
for
the
General
Metals
Subcategory,
EPA
transferred
these
data
to
model
the
wastewater
pollutant
concentrations
for
the
same
unit
operation
at
a
model
site
in
any
other
subcategory.

3.
If
EPA
did
not
have
unit
operation
sampling
data
from
a
site
in
Subcategory
A,
then
EPA
used
unit
operation
sampling
data
from
a
site
in
a
similar
subcategory
(
e.
g.,
if
Subcategory
A
is
a
metal­
bearing
subcategory,
data
from
another
metal­
bearing
subcategory
was
used).
The
Agency
used
available
analytical
data
for
the
same
operation
in
similar
subcategories
to
estimate
wastewater
pollutant
concentrations
for
the
model
site
unit
operation.
For
example,
if
available
analytical
data
for
a
unit
operation
bath
(
or
rinse)
exist
from
both
metal­
bearing
wastewater
facilities
and
oil­
bearing
wastewater
facilities,
EPA
used
the
following
approach.
If
the
model
site
is
designated
as
one
of
the
metal­
bearing
wastewater
subcategories,
only
available
analytical
data
from
other
metal­
bearing
wastewater
subcategorized
facilities
were
used
to
estimate
wastewater
pollutant
concentrations.
EPA
used
the
same
approach
for
oil­
bearing
wastewater
subcategories.

4.
If
EPA
did
not
sample
a
unit
operation
bath
(
or
rinse)
that
is
the
same
as
the
unit
operation
at
a
model
site,
the
Agency
used
the
available
analytical
data
for
a
unit
operation
bath
(
or
rinse)
that
has
similar
wastewater
characteristics,
but
are
within
the
same
subcategory,
to
estimate
wastewater
pollutant
concentrations
for
the
model
site
unit
operation.
Due
to
budget
constraints,
EPA
did
not
collect
data
for
22
baths
and
24
rinses,
representing
approximately
8.3
percent
of
the
total
MP&
M
discharge
flow
rate.
The
basis
for
these
estimates
are
discussed
in
the
memorandum
entitled
 
Data
Transfers
Between
Unit
Operations 
located
in
the
rulemaking
record
(
Section
16.7,
DCN
17767).

Supporting
documentation
for
all
data
transfers
of
unit
operation
pollutant
concentrations
is
contained
in
Section
16.7
of
the
MP&
M
rulemaking
record.

12.2
Estimation
of
Industry
Baseline
Pollutant
Loadings
Industry
baseline
wastewater
pollutant
loadings
are
modeled
pollutant
loadings
in
MP&
M
wastewater
discharged
to
surface
waters
or
to
POTWs
for
the
base
year
of
the
detailed
surveys,
supplemented
by
additional
site
information
provided
to
EPA.
These
loadings
reflect
wastewater
treatment
in
place
at
model
sites
in
the
year
1996.
EPA
estimated
baseline
pollutant
loadings
using
the
effluent
pollutant
concentrations,
unit
operation
flows
provided
in
the
questionnaire
(
as
described
in
Section
11.2.2),
and
effluent
flows
from
treatment
(
estimated
by
the
EPA
Costs
&
Loadings
Model
as
described
in
Section
11.3.3).
EPA
estimated
the
baseline
pollutant
loadings
using
the
approaches
described
in
this
subsection.

12­
9
12.0
­
Pollutant
Loading
and
Reduction
Estimates
12.2.1
Estimation
of
Baseline
Pollutant
Concentrations
from
Sites
in
the
Metal­
Bearing
Subcategories
For
the
final
rule,
EPA
revised
its
methodology
for
estimating
baseline
pollutant
concentrations
in
metal­
bearing
subcategories.
The
final
methodology
varies
depending
on
whether
or
not
the
stream
is
treated
or
untreated
and
also
by
its
current
regulatory
status.

12.2.1.1
Estimation
of
Effluent
Pollutant
Concentrations
for
Untreated
Streams
EPA
used
the
following
steps
to
estimate
the
wastewater
pollutant
concentrations
for
each
pollutant
of
concern
(
POC)
in
wastewater
discharged
from
model
sites
without
treatment:

1.
Estimated
wastewater
pollutant
concentrations
for
each
unit
operation
that
discharges
wastewater
from
the
site
without
treatment.
EPA
estimated
unit
operation
wastewater
pollutant
concentrations
using
the
methodology
described
in
Section
12.1.
EPA
notes
that
the
unit
operations
data
were
significantly
revised
between
the
proposal
and
the
Notice
of
Data
Availability
(
NODA),
and
have
been
revised
further
based
on
comments
on
the
NODA
(
see
DCN
16764
in
Section
16.7
of
the
rulemaking
record).

2.
Incorporated
limits
on
wastewater
discharged
from
sites
regulated
by
40
CFR
413
only
(
Baseline
for
the
413
to
433
Upgrade
Analysis).
For
the
final
rule,
in
response
to
comments,
EPA
accounted
for
sites
that
are
currently
regulated
by
and
complying
with
Part
413.
For
streams
not
currently
receiving
treatment
at
model
sites
subject
to
Part
413,
but
not
Part
433,
EPA
assumed
the
sites
achieved
the
monthly
average
limitation
for
Part
413
regulated
parameters
(
i.
e.,
set
the
wastewater
pollutant
concentrations
equal
to
the
Part
413
limits
(
as
opposed
to
achieving
the
long­
term
average
(
LTA)
concentration)).
EPA
noted
that
the
Part
413
limit
for
cyanide
is
different
for
small
platers
than
for
large
platers.
For
parameters
not
regulated
by
Part
413,
EPA
estimated
wastewater
pollutant
concentrations
from
the
unit
operations
data.
MP&
M
facilities
covered
under
Part
413
only
include
some,
but
not
all,
indirect
dischargers
in
the
Printed
Wiring
Board,
Metal
Finishing
Job
Shops,
and
General
Metals
Subcategories.
EPA
conducted
a
unique
analysis
to
determine
the
costs
and
loads
associated
with
the
upgrade
of
facilities
regulated
under
Part
413
to
meet
the
Part
433
limits.
EPA
used
the
methodology
described
in
this
section
to
estimate
baseline
pollutant
concentrations
of
untreated
streams
for
this
analysis.

3.
Incorporated
limits
on
wastewater
discharged
from
sites
regulated
by
40
CFR
433
(
or
Parts
413
and
433).
For
the
final
rule,
in
response
to
comments,
EPA
accounted
for
sites
that
are
currently
regulated
by
and
12­
10
12.0
­
Pollutant
Loading
and
Reduction
Estimates
complying
with
40
CFR
413
and
433,
or
433
only.
EPA
assumed
the
untreated
streams
achieved
the
monthly
average
limitation
for
Part
433
regulated
parameters
(
i.
e.,
set
the
wastewater
pollutant
concentrations
equal
to
the
Part
433
limits
(
as
opposed
to
achieving
the
LTA
concentration)).
For
parameters
not
regulated
by
Part
433,
EPA
estimated
wastewater
pollutant
concentrations
from
the
unit
operations
data.
MP&
M
facilities
covered
under
Part
433
include
all
direct
and
some
indirect
dischargers
in
the
Printed
Wiring
Board
and
Metal
Finishing
Job
Shops
Subcategories,
and
some
direct
and
indirect
dischargers
in
the
General
Metals
and
Non­
Chromium
Anodizing
Subcategories.

4.
Incorporated
limits
on
wastewater
discharged
from
sites
not
regulated
by
40
CFR
413
or
433
(
Baseline
for
the
Local
Limits
to
433
Upgrade
Analysis).
For
the
final
rule,
in
response
to
comments,
EPA
also
incorporated
changes
to
take
into
account
the
compliance
of
indirect
dischargers
in
the
General
Metals
Subcategory,
not
currently
regulated
by
Parts
413
or
433,
with
local
limits.
Although
EPA
could
not
obtain
actual
local
limits
for
all
facilities,
EPA
gathered
local
limits
data
from
213
POTWs
in
seven
EPA
Regions
to
develop
national
median
local
limit
values.
(
see
DCN
17844
of
the
rulemaking
record
for
a
list
of
the
data
and
the
median
value
for
each
parameter).
EPA
assumed
the
untreated
streams
achieved
the
national
median
local
limit
for
all
parameters
regulated
by
Part
433
in
untreated
streams.
For
parameters
not
regulated
by
Part
433,
EPA
estimated
wastewater
pollutant
concentrations
from
the
unit
operations
data.
EPA
conducted
a
unique
analysis
to
determine
the
costs
and
loads
associated
with
the
upgrade
of
facilities
not
regulated
under
Parts
413
or
433
to
meet
the
Part
433
limits.
EPA
used
the
methodology
described
in
this
section
to
estimate
baseline
pollutant
concentrations
of
untreated
streams
for
this
analysis.

5.
Estimated
commingled
wastewater
concentrations
for
all
untreated
streams.
EPA
combined
the
wastewater
from
all
unit
operation
discharges
that
are
not
sent
through
treatment.
EPA
calculated
the
commingled
concentration
of
each
POC
in
the
combined
MP&
M
wastewater
based
on
pollutant
concentrations
and
flow
rates
of
each
stream.

12.2.1.2
Estimation
of
Effluent
Pollutant
Concentrations
for
Treated
Streams
EPA
used
the
Costs
&
Loadings
Model
(
see
Section
11.0)
to
estimate
the
pollutant
concentrations
in
wastewater
discharged
from
the
treatment
technology
at
each
model
site.
EPA
used
the
following
steps
to
estimate
the
wastewater
pollutant
concentrations
for
each
POC
in
treated
discharged
wastewater:

1.
Estimated
wastewater
pollutant
concentrations
for
each
unit
operation
that
discharges
wastewater
to
treatment.
EPA
estimated
unit
operation
12­
11
12.0
­
Pollutant
Loading
and
Reduction
Estimates
wastewater
pollutant
concentrations
using
the
methodology
described
in
Section
12.1.
EPA
notes
that
the
unit
operations
data
were
significantly
revised
between
the
proposal
and
the
NODA,
and
have
been
revised
further
based
on
comments
on
the
NODA
(
see
DCN
16764
in
Section
16.7
of
the
rulemaking
record).

2.
Estimated
wastewater
concentrations
in
influent
to
treatment
(
commingled
wastewater
concentrations
for
all
treated
streams).
EPA
combined
the
wastewater
from
all
unit
operations
that
discharge
to
treatment.
EPA
calculated
the
commingled
(
treatment
influent)
concentration
of
each
POC
in
the
combined
MP&
M
wastewater,
based
on
pollutant
concentrations
and
flow
rates
of
each
stream.
The
treatment
influent
concentrations
are
required
to
estimate
baseline
costs
(
see
Section
11.0).

3.
Estimated
wastewater
concentrations
in
effluent
from
treatment.
EPA
used
the
Costs
&
Loadings
Model
(
see
Section
11.0)
to
estimate
the
pollutant
concentrations
in
wastewater
discharged
from
each
model
site
wastewater
treatment
unit.
The
following
summarizes
the
pollutant
concentrations
for
the
various
treatment
technologies
reported
for
the
metal­
bearing
subcategories.

 

Treatment
Equivalent
to
the
Metal
Finishing
(
40
CFR
433)
Best
Available
Treatment
(
BAT).
EPA
assumed
that
all
streams
that
undergo
treatment
equivalent2
to
the
Metal
Finishing
(
40
CFR
433)
BAT
technology
basis
are
treated
to
achieve
the
LTAs
promulgated
at
40
CFR
433
for
those
parameters
regulated
under
Part
433
(
433
parameters).
EPA
assumed
that
parameters
not
regulated
under
Part
433
(
non­
433
parameters)
are
treated
to
achieve
the
LTAs
based
on
MP&
M
BAT
(
Option
2)
sampled
sites.

 

Microfiltration
for
Solids
Removal
Technology.
For
streams
treated
by
a
membrane
system,
EPA
assumed
that
the
membrane
technology
could
treat
to
a
lower
concentration
than
the
433
LTAs.
Therefore,
EPA
assumed
the
membrane
technology
could
achieve
the
lower
of
the
LTAs
calculated
based
on
MP&
M
sampled
sites
using
membrane
technology
or
the
433
LTAs.

 

Chemical
Reduction
of
Chelated
Metals.
For
streams
treated
by
a
chelation
breaking
system,
EPA
assumed
the
reduction
of
chelated
metals
to
the
elemental
state.
The
concentrations
of
carbon
disulfide
and
dithiocarbamate
(
DTC)
increase
in
the
chelation
breaking
module
to
account
for
addition
of
treatment
chemicals.

2Refer
to
Table
11­
5
for
treatment
technologies
considered
equivalent
to
chemical
precipitation
and
sedimentation.

12­
12
12.0
­
Pollutant
Loading
and
Reduction
Estimates
 

Oil
Treatment
(
Chemical
Emulsion
Breaking
and
Oil/
Water
Separation)
and
Batch
Oil
Emulsion
Breaking
with
Gravity
Flotation.
EPA
assumed
oil
treatment
and
batch
oil
emulsion
breaking
technologies
could
achieve
the
LTAs
calculated
based
on
MP&
M
sampled
sites
using
chemical
emulsion
breaking
with
gravity
oil/
water
separation.

 

Ultrafiltration
(
for
Oil
Removal).
EPA
assumed
ultrafiltration
technologies
could
achieve
the
LTAs
calculated
based
on
MP&
M
sampled
sites
using
ultrafiltration
(
for
oil
removal).

 

Dissolved
Air
Flotation
(
DAF).
EPA
assumed
DAF
technology
could
achieve
the
433
limits
for
all
433
parameters.
For
non­
433
parameters,
EPA
assumed
DAF
technology
could
achieve
the
LTAs
calculated
based
on
MP&
M
sampled
sites
using
DAF
technology.

 

Cyanide
Destruction
and
Ion
Exchange.
EPA
assumed
cyanide
destruction
and
ion
exchange
technologies
could
reduce
the
amount
of
cyanide
in
cyanide­
bearing
wastewater.
EPA
assumed
total
cyanide,
amenable
cyanide,
and
weak­
acid
dissociable
cyanide
are
reduced
to
the
LTAs
calculated
based
on
MP&
M
sampled
sites
using
cyanide
destruction.
The
concentration
of
chloroform
increases
in
the
cyanide
destruction
module
to
account
for
the
reduction
process.

 

Chemical
Reduction
of
Hexavalent
Chromium.
EPA
assumed
hexavalent
chromium
reduction
could
reduce
the
amount
of
hexavalent
chromium
to
achieve
the
LTA
calculated
based
on
MP&
M
sampled
sites
using
hexavalent
chromium
reduction.
The
concentration
of
trivalent
chromium
increases
in
the
hexavalent
chromium
reduction
module
to
account
for
the
conversion
process.

Note
that
if
the
treated
effluent
concentration
for
a
pollutant
was
more
than
its
corresponding
treatment
influent
concentration
(
obtained
in
step
2
above),
EPA
retained
the
treatment
influent
concentration
to
estimate
the
baseline
concentration
for
that
pollutant.

4.
Incorporated
limits
on
wastewater
discharged
from
sites
regulated
by
40
CFR
413
only
(
Baseline
for
the
413
to
433
Upgrade
Analysis).
For
the
final
rule,
in
response
to
comments,
EPA
accounted
for
sites
that
are
currently
regulated
by
and
complying
with
Part
413
only.
For
streams
receiving
treatment
at
model
sites
subject
to
Part
413,
but
not
Part
433,
EPA
assumed
the
sites
achieved
the
LTAs
for
Part
413
regulated
parameters
(
i.
e.,
set
the
wastewater
pollutant
concentrations
equal
to
the
12­
13
12.0
­
Pollutant
Loading
and
Reduction
Estimates
Part
413
LTA
concentration).
EPA
noted
that
40
CFR
413
only
sets
limitations
on
lead,
cadmium,
and
cyanide
for
small
platers.
EPA
assumed
small
platers
achieved
the
monthly
limit
average
for
those
additional
parameters
regulated
by
Part
413
for
large
platers.
For
parameters
not
regulated
by
Part
413,
EPA
assumed
sites
achieve
the
baseline
pollutant
concentrations
for
the
treatment
technology.
MP&
M
facilities
covered
under
Part
413
only
include
some
indirect
dischargers
in
the
Printed
Wiring
Board,
Metal
Finishing
Job
Shops,
and
General
Metals
Subcategories.
EPA
conducted
a
unique
analysis
to
determine
the
costs
and
loads
associated
with
the
upgrade
of
facilities
regulated
under
Part
413
to
meet
the
Part
433
limits.
EPA
used
the
methodology
described
in
this
section
to
estimate
baseline
pollutant
concentrations
of
treated
streams
for
this
analysis.

5.
Incorporated
limits
on
wastewater
discharged
from
sites
not
regulated
by
40
CFR
413
or
433
(
Baseline
for
the
Local
Limits
to
433
Upgrade
Analysis).
For
the
final
rule,
in
response
to
comments,
EPA
also
incorporated
changes
to
take
into
account
the
compliance
of
indirect
dischargers
in
the
General
Metals
Subcategory,
not
currently
regulated
by
Parts
413
or
433,
with
local
limits.
Although
EPA
could
not
obtain
actual
local
limits
for
all
facilities,
EPA
gathered
local
limits
data
from
213
POTWs
in
seven
EPA
Regions
to
develop
national
median
local
limit
values.
(
see
DCN
17844
of
the
rulemaking
record
for
a
list
of
the
data
and
the
median
value
for
each
parameter).
EPA
assumed
the
treated
streams
achieved
one­
half
of
the
national
median
local
limit
values3
for
all
parameters
regulated
by
Part
433.
For
parameters
not
regulated
by
Part
433,
EPA
assumed
the
treated
streams
achieved
the
national
median
local
limit
values.
EPA
conducted
a
unique
analysis
to
determine
the
costs
and
loads
associated
with
the
upgrade
of
facilities
not
regulated
under
Parts
413
or
433
to
meet
the
Part
433
limits.
EPA
used
the
methodology
described
in
this
section
to
estimate
baseline
pollutant
concentrations
of
treated
streams
for
this
analysis.

12.2.1.3
Estimation
of
Commingled
Effluent
Pollutant
Concentrations
from
Sites
EPA
combined
the
wastewater
from
treated
and
untreated
streams.
EPA
calculated
the
commingled
baseline
effluent
pollutant
concentration
of
each
POC
in
the
combined
MP&
M
wastewater
based
on
pollutant
concentrations
and
flow
rates
of
each
stream
(
treated
and
untreated).

EPA
received
comments
that,
although
the
concentration
of
chemical
oxygen
demand
(
COD)
in
discharged
wastewater
is
not
regulated
by
Parts
413
or
433
(
unlike
oil
and
3EPA
used
½
the
median
value
to
take
into
account
that
facilities
do
not
operate
treatment
systems
to
achieve
the
limit,
but
some
value
below
the
limit
to
account
for
variability.

12­
14
12.0
­
Pollutant
Loading
and
Reduction
Estimates
grease
and
total
suspended
solids),
it
is
typically
regulated
by
local
limits.
EPA
reviewed
data
from
the
Permit
Compliance
System
(
PCS)
and
found
that,
while
COD
is
not
generally
regulated
by
local
limitations,
a
small
number
of
facilities
do
have
COD
restrictions.
EPA
found
similar
results
for
total
kjeldahl
nitrogen
(
TKN)
and
ammonia
as
nitrogen
(
NH)
4
.
Since
EPA
could
not
identify
which
sites
in
PCS
may
have
been
subject
to
MP&
M,
EPA
conducted
its
analysis
using
information
from
process
wastewater
dischargers
from
facilities
in
the
3000
series
SIC
codes.
Using
information
from
those
sites
with
COD,
TKN,
and
NH
limitations,
EPA
calculated
a
single
local
limit
value
for
each
parameter.
These
values
are
175,
35.67,
and
19.3
mg/
L
for
COD,
TKN,
and
NH,
respectively.
EPA
compared
the
baseline
pollutant
concentrations
it
predicted
for
these
pollutants
at
each
site.
If
these
concentrations
were
in
excess
of
the
local
limit
value,
then
EPA
set
the
concentration
for
the
commingled
MP&
M
wastewater
discharged
from
each
model
site
in
metal­
bearing
wastewater
subcategories
equal
to
the
local
limit
value.
Details
are
provided
in
the
memorandum
 
Loadings
Methodology
for
Cost
Model
Run
4 
(
DCN
17846
in
Section
24.7
of
the
rulemaking
record).

12.2.2
Estimation
of
Baseline
Pollutant
Concentrations
from
Sites
in
the
Oil­
Bearing
Subcategories
For
the
proposal
and
the
NODA,
EPA s
methodology
to
estimate
baseline
pollutant
concentrations
for
facilities
in
oil­
bearing
wastewater
subcategories
was
similar
to
the
one
used
at
that
time
for
metal­
bearing
wastewater
subcategories.
EPA
received
comment
on
the
proposal
and
NODA
that
this
methodology
overestimated
baseline
pollutant
concentrations
for
Shipbuilding
Dry
Dock,
Railroad
Line
Maintenance,
and
Oily
Waste
sites.
In
response
to
these
comments,
EPA
significantly
revised
its
methodology
for
estimating
baseline
pollutant
concentrations
in
the
oil­
bearing
wastewater
subcategories.
Because
EPA
has
different
types
of
information
in
its
database
for
each
oil­
bearing
wastewater
subcategory,
it
used
different
methods
to
represent
baseline
pollutant
concentrations
for
each
oil­
bearing
wastewater
subcategory.
The
final
methodologies
used
for
each
oil­
bearing
wastewater
subcategory
are
described
individually
below.

12.2.2.1
Estimation
of
Baseline
Pollutant
Concentrations
from
Sites
in
the
Shipbuilding
Dry
Dock
Subcategory
For
the
final
rule,
EPA
used
its
sampling
data
and
industry
supplied
long­
term
monitoring
data
to
estimate
baseline
pollutant
concentrations
for
this
subcategory.
This
data
includes
pollutant
concentrations
measured
at
two
EPA
sampling
episodes
and
those
reported
in
three
years
of
Detailed
Monitoring
Reports
(
DMR)
covering
numerous
dry
dock
discharges
from
a
single
shipbuilding
dry
dock
facility.
In
estimating
baseline
pollutant
concentrations
in
this
manner,
EPA
looked
at
the
individual
data
points
as
well
as
averages
for
its
conclusions.
See
DCNs
17859
and
17860
in
Sections
24.6.1
and
24.5.1
of
the
final
rulemaking
record
for
additional
information.
Note
that
for
the
final
rule,
EPA
only
estimated
baseline
concentrations
for
total
suspended
solids
(
TSS)
and
oil
and
grease
because
EPA
had
previously
determined
that
4EPA
reviewed
these
parameters
because
they
were
important
in
estimating
benefits
(
see
the
Economic,
Environmental,
and
Benefits
Analysis
for
the
Final
MP&
M
Rule
(
EEBA)).

12­
15
12.0
­
Pollutant
Loading
and
Reduction
Estimates
discharges
from
these
facilities
contain
minimal
concentrations
of
toxic
organic
and
metal
pollutants.

12.2.2.2
Estimation
of
Baseline
Pollutant
Concentrations
from
Sites
in
the
Railroad
Line
Maintenance
Subcategory
In
response
to
proposal
and
NODA
comments,
EPA
revisited
its
database
of
direct
discharging
Railroad
Line
Maintenance
facilities.
EPA
found
that
many
of
the
facilities
in
its
database
would
not
be
subject
to
this
rule
because
they
discharged
only
noncontaminated
stormwater
or
wastewater
resulting
from
refueling
operations
(
neither
of
which
is
subject
to
the
final
rule).
As
a
result
of
this
review,
EPA
concluded
its
database
was
insufficient
to
make
any
regulatory
decisions
on
direct
discharging
Railroad
Line
Maintenance
facilities.

However,
as
part
of
its
comments
on
the
proposed
rule
and
as
discussed
more
fully
in
the
NODA
(
67
FR
38755),
the
American
Association
of
Railroads
(
AAR)
provided
a
census
listing
of
each
Railroad
Line
Maintenance
direct
discharging
facility
known
to
them.
For
each
facility,
AAR
provided
a
description
of
treatment
technologies,
a
summary
of
effluent
data,
including
flow
rates,
permit
limits,
and
a
process
flow
diagram
or
description
of
the
operations.
For
the
final
rule,
EPA
used
this
information
to
create
a
new
database
representing
direct
discharging
Railroad
Line
Maintenance
facilities.

EPA s
final
database
consists
of
nine
direct
discharging
Railroad
Line
Maintenance
facilities.
Six
of
the
nine
facilities
use
technologies
consistent
with
the
Option
6
technology
basis,
two
use
technologies
consistent
with
the
Option
10
technology
basis,
and
one
uses
biological
treatment.

For
the
final
rule,
EPA
did
not
need
to
model
effluent
pollutant
concentrations
for
each
of
the
final
database
facilities.
Rather,
EPA
used
the
summary
effluent
data
provided
for
each
facility
to
represent
baseline
oil
and
grease
and
TSS
concentrations
in
the
Railroad
Line
Maintenance
Subcategory.
For
additional
information,
see
DCN
17861
in
Section
24.6.1
of
the
rulemaking
record.
Note
that
EPA
considered
only
TSS
and
oil
and
grease
because
it
had
previously
determined
that
discharges
in
this
subcategory
contain
few
pounds
of
toxic
pollutants.

12.2.2.3
Estimation
of
Baseline
Pollutant
Concentrations
from
Sites
in
the
Oily
Wastes
Subcategory
For
the
final
rule,
EPA
estimated
baseline
pollutant
concentrations
using
a
different
methodology
for
treated
and
untreated
streams
in
the
oily
waste
subcategory.

Treated
Streams:
Where
EPA
had
survey
information
(
DMR
data)
for
a
particular
site
with
treatment,
EPA
used
that
information
as
the
baseline
pollutant
concentration.
For
half
of
the
oily
waste
subcategory
facilities
with
treatment,
however,
EPA
had
to
estimate
baseline
pollutant
concentrations.
In
all
of
these
cases,
EPA
determined
the
treatment
currently
in
place
would
achieve
equivalent
or
greater
removals
to
the
12­
16
12.0
­
Pollutant
Loading
and
Reduction
Estimates
treatment
technology
considered
as
the
technology
basis
for
limitations
in
this
subcategory
(
Option
6).
Therefore,
where
EPA
did
not
have
DMR
data
for
a
facility
with
treatment
in
place,
EPA
estimated
its
baseline
pollutant
concentrations
as
the
median
effluent
concentrations
of
the
DMR
data
from
facilities
with
the
option
6
technology.

Untreated
Streams:
EPA
had
DMR
data
for
one
site
that
indicated
no
treatment.
Therefore,
EPA
used
this
data
as
the
baseline
pollutant
concentrations
for
this
facility.
For
the
remaining
sites
without
treatment,
EPA
had
to
estimate
baseline
pollutant
concentrations.
For
these
sites,
EPA
estimated
unit
operation
wastewater
pollutant
concentrations
using
the
methodology
described
in
Section
12.1.
EPA
notes
that
it
significantly
revised
the
unit
operations
data
between
the
proposal
and
the
NODA,
and
between
the
NODA
and
final
rule
based
on
comments
on
the
NODA
(
see
DCN
16764,
in
Section
16.7
of
the
rulemaking
record).
EPA
combined
the
wastewater
from
all
unit
operation
discharges
that
are
not
sent
through
treatment.
EPA
calculated
the
commingled
concentration
of
each
POC
in
the
combined
MP&
M
wastewater
based
on
pollutant
concentrations
and
flow
rates
of
each
stream.

12.2.3
Estimation
of
Model
Site
Baseline
Loadings
EPA
estimated
the
pollutant
loadings
(
lbs/
yr)
in
effluent
wastewater
(
treated
or
untreated)
discharged
from
each
MP&
M
model
site.
EPA
estimated
pollutant­
specific
baseline
loadings
by
multiplying
the
effluent
pollutant
concentration
of
the
pollutant
by
the
corresponding
effluent
wastewater
flow
rate.
To
determine
site­
specific
pollutant
baseline
loadings
for
sites
that
have
both
treated
and
untreated
streams,
EPA
summed
the
estimated
pollutant­
specific
baseline
loading
from
the
untreated
effluent
and
the
treated
effluent.
EPA
estimated
site­
specific
baseline
loadings
by
summing
site­
specific
pollutant
baseline
loadings
for
all
pollutants
considered.

For
direct
dischargers
in
the
General
Metals
Subcategory,
EPA
additionally
compared
the
baseline
pollutant
loadings
from
EPA s
Costs
&
Loadings
Model
to
available
DMR
data.
EPA
obtained
DMR
data
for
18
of
the
model
sites.
The
MP&
M
model
did
not
overestimate
baseline
loadings
for
12
of
these
18
model
direct
discharging
facilities
(
or
approximately
two­
thirds
of
these
facilities).
The
relative
percent
difference
(
in
pound­
equivalents)
of
the
model
baseline
loadings
and
those
estimated
using
DMR
data
is
14
percent.
Based
on
this
analysis,
EPA
concluded
that
the
MP&
M
model
estimates
of
baseline
pollutant
loadings
are
reasonable
and
appropriate.

12.2.4
Estimation
of
Industry­
Wide
Baseline
Pollutant
Loadings
EPA
multiplied
the
site­
specific
baseline
wastewater
loadings
by
the
corresponding
statistically
derived
weighting
factors
(
see
Section
3.0)
for
each
model
site.
EPA
summed
the
weighted
loadings
across
all
sites
in
each
subcategory
to
estimate
subcategory­
specific
baseline
wastewater
pollutant
loadings.
EPA
also
summed
the
weighted
12­
17
12.0
­
Pollutant
Loading
and
Reduction
Estimates
loadings
across
all
sites
to
estimate
industry­
wide
baseline
wastewater
pollutant
loadings.
Table
12­
2
presents
the
estimated
baseline
pollutant
loadings
by
subcategory
for
direct
and
indirect
dischargers.

12.3
Estimation
of
Industry
Option
Pollutant
Loadings
Industry
option
pollutant
loadings
(
i.
e.,
post­
compliance
pollutant
loadings
for
the
technology
option)
represent
the
total
loadings
of
pollutants
in
all
MP&
M
wastewater
that
would
be
discharged
to
surface
waters
or
POTWs
after
complying
with
the
regulatory
option.
The
estimation
of
industry
option
pollutant
loadings
for
each
subcategory
is
described
in
the
following
subsections.

12.3.1
Estimation
of
Industry
Option
Pollutant
Loadings
for
Sites
in
the
Metal­
Bearing
Subcategories
Direct
Dischargers
(
General
Metals
Subcategory).
EPA
estimated
option
effluent
concentrations
assuming
that
all
direct
discharging
MP&
M
facilities
in
the
General
Metals
Subcategory
would
achieve
long­
term
average
effluent
pollutant
concentrations
associated
with
the
MP&
M
sampled
sites
performing
BAT
(
Option
2,
including
chemical
precipitation
with
clarification).
EPA
estimated
effluent
concentrations
for
all
pollutants
of
concern
(
listed
in
Section
7.0).
Note
that
if
the
long­
term
average
effluent
concentration
for
a
pollutant
was
more
than
its
corresponding
treatment
influent
concentration
(
based
on
unit
operation
wastewater
concentrations),
EPA
retained
the
treatment
influent
concentration
to
estimate
the
option
effluent
concentration
for
that
pollutant.

Indirect
Dischargers
­
413
to
433
Upgrade
Analysis
for
sites
regulated
by
40
CFR
413
only
(
General
Metals,
Printed
Wiring
Board,
and
Metal
Finishing
Job
Shop
Subcategories).
EPA
estimated
option
effluent
concentrations
assuming
all
indirect
discharging
MP&
M
facilities
in
metal­
bearing
subcategories,
currently
regulated
by
40
CFR
413
only,
would
achieve
long­
term
average
effluent
pollutant
concentrations
associated
with
the
BAT
sites
sampled
under
development
of
40
CFR
433
(
at
the
option).
EPA
estimated
effluent
concentrations
only
for
pollutants
regulated
under
40
CFR
433.

Indirect
Dischargers
­
Local
Limits
to
433
Upgrade
Analysis
for
sites
regulated
by
local
limits
(
General
Metals
Subcategory).
EPA
estimated
option
effluent
concentrations
assuming
all
indirect
discharging
facilities
in
the
General
Metals
Subcategory,
not
currently
regulated
by
40
CFR
413
or
433,
would
achieve
long­
term
average
effluent
pollutant
concentrations
associated
with
the
BAT
sites
sampled
under
development
of
40
CFR
433
(
at
the
option).
For
pollutants
regulated
under
local
limits,
but
not
regulated
under
Part
433,
EPA
assumed
the
facilities
would
achieve
the
national
median
local
limit
values.
EPA
estimated
effluent
concentrations
only
for
pollutants
regulated
under
local
limits.

EPA
then
estimated
post­
compliance
pollutant
loadings
for
each
model
facility
by
multiplying
the
treated
effluent
concentration
by
its
wastewater
flow
rate
to
obtain
a
mass
loading
(
in
pounds)
for
each
pollutant.
Finally,
EPA
estimated
site­
specific
option
loadings.

12­
18
12.0
­
Pollutant
Loading
and
Reduction
Estimates
EPA
summed
the
mass
loadings
for
all
pollutants
in
the
final
effluent
discharged
from
the
model
site.

12.3.2
Estimation
of
Industry
Option
Pollutant
Loadings
for
Sites
in
the
Shipbuilding
Dry
Dock
Subcategory
Because
EPA
concluded
that
national
regulation
of
discharges
from
the
Shipbuilding
Dry
Dock
Subcategory
is
unwarranted5
,
EPA
did
not
assess
option
pollutant
loadings
for
this
subcategory.

12.3.3
Estimation
of
Industry
Option
Pollutant
Loadings
for
Sites
in
the
Railroad
Line
Maintenance
Subcategory
For
this
subcategory,
EPA
used
information
in
its
database
on
current
permit
limitations
for
facilities
operating
the
Option
6
technology
to
estimate
post­
compliance
pollutant
loadings.
All
of
the
facilities
that
operate
the
Option
6
technology
have
a
daily
maximum
oil
and
grease
limit
of
15
mg/
L.
For
TSS,
half
of
the
facilities
have
a
daily
maximum
limit
of
45
mg/
L
while
the
other
half
have
no
limit.
Based
on
this
information,
the
oil
and
grease
and
TSS
daily
maximum
limits
representing
the
average
of
the
best
performing
Option
6
facilities
would
be
15
mg/
L
and
45
mg/
L,
respectively.
To
estimate
pollutant
loadings
for
each
model
facility,
EPA
multiplied
these
maximum
limits
by
the
wastewater
flow
(
provided
in
the
survey)
to
obtain
a
mass
loading
(
in
pounds)
for
TSS.

12.3.4
Estimation
of
Industry
Option
Pollutant
Loadings
for
Sites
in
the
Oily
Wastes
Subcategory
EPA
calculated
the
loadings
assuming
that
all
Oily
Wastes
sites
would
achieve
long­
term
average
effluent
pollutant
concentrations
associated
with
the
MP&
M
sampled
sites
performing
BAT
(
Option
6,
including
chemical
emulsion
breaking
with
gravity
oil/
water
separation).

First,
EPA
estimated
the
pollutant
concentrations
in
the
effluent
from
treatment
at
each
model
site,
using
the
LTAs
calculated
from
MP&
M
BAT
sampled
sites.
The
calculated
LTAs
for
oil
and
grease
and
TSS
are
18.89
mg/
L
and
44
mg/
L,
respectively.
Note
that
if
the
long­
term
average
effluent
concentration
for
a
pollutant
was
more
than
its
corresponding
treatment
influent
concentration
(
based
on
unit
operation
wastewater
concentrations),
EPA
retained
the
treatment
influent
concentration
to
estimate
the
option
concentration
for
that
pollutant.

Second,
EPA
estimated
site­
specific
pollutant
loadings.
EPA
multiplied
the
pollutant
concentrations
in
the
final
effluent
(
discharged
from
the
model
site)
by
the
wastewater
5See
Section
VI.
H
of
the
final
preamble
for
additional
discussion.

12­
19
12.0
­
Pollutant
Loading
and
Reduction
Estimates
flow
rate
(
calculated
in
the
EPA
Costs
&
Loadings
Model,
or
provided
in
the
DMR)
to
obtain
a
mass
loading
(
in
pounds)
for
each
pollutant.

Finally,
EPA
estimated
site­
specific
option
loadings.
EPA
summed
the
mass
loadings
for
all
pollutants
in
the
final
effluent
discharged
from
the
model
site.

12.4
Estimation
of
Pollutant
Reductions
Option
pollutant
reductions
represent
the
incremental
amount
of
pollutants
removed
by
each
technology
option
with
respect
to
EPA s
estimated
baseline
pollutant
loadings.
EPA
estimated
baseline
pollutant
loadings
as
explained
in
Section
12.2.
EPA
estimated
option
pollutant
loadings
as
explained
in
Section
12.3.
EPA
estimated
pollutant
reductions
as
follows:

1.
Estimated
site­
specific,
pollutant­
specific
option
removals.
EPA
calculated
the
difference
between
the
model
site s
baseline
pollutant
loadings
and
option
pollutant
loadings.
For
direct
dischargers,
EPA
considered
all
pollutants
of
concern,
with
the
exception
of
boron,
sodium,
calcium,
and
total
dissolved
solids.
For
indirect
dischargers,
EPA
considered
only
pollutants
regulated
under
40
CFR
433.
EPA
further
reduced
the
model
site s
option­
specific
pollutant
removals
for
indirect
dischargers
by
their
corresponding
POTW
percent
removal
(
listed
in
Table
12­
1)
to
account
for
treatment
that
will
occur
at
the
POTW.
A
detailed
discussion
of
how
EPA
developed
pollutant­
specific
POTW
percent
removals
is
provided
in
Section
7.3.1
of
the
Technical
Development
Document
for
the
Proposed
Effluent
Limitations
Guidelines
and
Standards
for
the
Metal
Products
and
Machinery
Point
Source
Category
.

2.
Modified
site­
specific,
pollutant­
specific
option
removals.
First,
if
the
option­
specific
concentration
for
certain
pollutant(
s)
was
greater
than
the
estimated
baseline
concentration
for
a
model
site,
EPA
set
option­
specific
loadings
for
the
pollutant(
s)
equal
to
the
baseline
loadings
at
those
sites
(
EPA
set
the
option­
specific
pollutant
removal
for
that
model
site
equal
to
zero).
This
was
the
case
if
the
pollutant
long­
term
average
concentration
for
the
treatment
currently
in
place
at
the
site
was
lower
than
that
for
EPA s
treatment
technology
option
(
i.
e.,
a
model
facility
uses
membrane
technology,
but
EPA s
option
technology
is
chemical
precipitation).
Second,
EPA
set
all
removals
of
boron
equal
to
zero.
EPA
determined
that
boron
is
not
removed
by
most
of
the
selected
option
treatment
technologies,
as
discussed
in
the
NODA.
For
additional
details,
refer
to
the
memorandum
entitled
 
Treatment
System
Removal
of
Boron
from
MP&
M
Wastewaters 
in
Section
16.7,
DCN
16758
of
the
rulemaking
record.

3.
Estimated
toxic
site­
specific,
pollutant­
specific
option
removals.
EPA
also
calculated
the
site­
specific,
pollutant
specific
removals
in
toxic
12­
20
12.0
­
Pollutant
Loading
and
Reduction
Estimates
pound­
equivalents.
A
pound­
equivalent
(
PE)
is
a
pound
of
pollutant
weighted
for
its
toxicity
to
human
and
aquatic
life.
EPA
multiplied
the
site­
specific
option
pollutant
removals
(
in
pounds)
by
the
corresponding
toxic­
weighting
factor
(
TWF).

4.
Estimated
site­
specific
option
removals.
EPA
summed
the
pollutant
removals
for
all
pollutants
at
the
model
site.

5.
Estimated
industry­
wide
option
loadings
and
removals.
For
each
option,
EPA
multiplied
the
site­
specific
option
loadings
and
removals
(
accounting
for
POTW
removals
for
indirect
dischargers)
by
the
corresponding
statistically
derived
weighting
factors
for
each
model
site.
EPA
summed
the
weighted
loadings
and
removals
across
all
sites
in
each
subcategory
to
estimate
subcategory­
specific
option
loadings
and
removals
for
each
option.
EPA
also
summed
the
weighted
loadings
and
removals
across
all
sites
to
estimate
industry­
wide
option
loadings
and
removals.

Table
12­
3
presents
the
estimated
selected
option
pollutant
loadings
by
subcategory
for
direct
and
indirect
dischargers.
Tables
12­
4
and
12­
5
present
the
estimated
pollutant
removals
by
the
selected
option
in
pounds
(
for
direct
dischargers
only)
and
pound­
equivalents
(
for
both
direct
and
indirect
dischargers),
respectively.

Note
that,
for
the
final
rule,
EPA
did
not
provide
option
pollutant
loadings
or
reductions
for
the
Shipbuilding
Dry
Dock
or
Railroad
Line
Maintenance
Subcategories.
EPA
concluded
that
pollutant
removals
associated
with
national
regulation
of
these
subcategories
would
be
negligible.
See
DCNs
17859
and
17861
in
Section
24.6.1
of
the
rulemaking
record
for
more
detailed
discussion
of
the
Shipbuilding
Dry
Dock
and
Railroad
Line
Maintenance
Subcategories,
respectively.

12­
21
12.0
­
Pollutant
Loading
and
Reduction
Estimates
Table
12­
1
POTW
Removal
Percentages
For
Each
MP&
M
Pollutant
of
Concern
Chemical
Name
POTW
Percent
Removal
Source
1,1,1­
Trichloroethane
90.45
a
1,1­
Dichloroethane
70
a
1,1­
Dichloroethene
77.51
c
1,4­
Dioxane
45.8
b
1­
Bromo­
2­
Chlorobenzene
77.32
c
1­
Bromo­
3­
Chlorobenzene
77.32
c
1­
Methylfluorene
84.55
b
1­
Methylphenanthrene
84.55
b
2,4­
Dimethylphenol
77.51
c
2,4­
Dinitrophenol
77.51
c
2,6­
Dinitrotoluene
77.51
c
2­
Butanone
96.6
b
2­
Hexanone
77.32
c
2­
Isopropylnaphthalene
77.32
c
2­
Methylnaphthalene
28
b
2­
Nitrophenol
26.83
a
2­
Propanone
83.75
b
3,6­
Dimethylphenanthrene
84.55
b
4­
Chloro­
3­
Methylphenol
63
b
4­
Methyl­
2­
Pentanone
87.87
b
4­
Nitrophenol
77.51
c
Acenaphthene
98.29
a
Acetophenone
95.34
b
Acrolein
77.51
c
Alpha­
Terpineol
94.4
b
Aluminum
91.36
a
Amenable
Cyanide
57.41
c
Ammonia
As
Nitrogen
38.94
a
Aniline
93.41
b
Anthracene
77.51
c
Antimony
66.78
a
Arsenic
65.77
a
Barium
15.98
a
Benzoic
Acid
80.5
b
Benzyl
Alcohol
78
b
12­
22
12.0
­
Pollutant
Loading
and
Reduction
Estimates
Table
12­
1
(
Continued)

Chemical
Name
POTW
Percent
Removal
Source
Beryllium
71.66
c
Biphenyl
96.28
b
Bis(
2­
Ethylhexyl)
Phthalate
59.78
a
BOD
5­
Day
(
Carbonaceous)
89.12
a
Boron
30.42
a
Butyl
Benzyl
Phthalate
81.65
a
Cadmium
90.05
a
Calcium
8.54
a
Carbon
Disulfide
84
b
Chemical
Oxygen
Demand
(
COD)
81.3
a
Chloride
57.41
c
Chlorobenzene
96.37
a
Chloroethane
77.51
c
Chloroform
73.44
a
Chromium
80.33
a
Cobalt
6.11
a
Copper
84.2
a
Cyanide
70.44
a
Di­
N­
Butyl
Phthalate
84.66
a
Di­
N­
Octyl
Phthalate
68.43
a
Dibenzofuran
77.32
c
Dibenzothiophene
84.68
b
Dimethyl
Phthalate
77.51
c
Diphenyl
Ether
77.32
c
Diphenylamine
77.32
c
Ethylbenzene
93.79
a
Fluoranthene
42.46
a
Fluorene
69.85
a
Fluoride
61.35
Gold
32.52
c
Hexanoic
Acid
84
b
Hexavalent
Chromium
57.41
c
Iron
81.99
a
Isobutyl
Alcohol
28
b
Isophorone
77.51
c
Lead
77.45
a
m+
p
Xylene
77.32
c
12­
23
12.0
­
Pollutant
Loading
and
Reduction
Estimates
Table
12­
1
(
Continued)

Chemical
Name
POTW
Percent
Removal
Source
m­
Xylene
95.07
b
Magnesium
14.14
a
Manganese
35.51
a
Mercury
71.66
c
Methyl
Methacrylate
99.96
b
Methylene
Chloride
54.28
a
Molybdenum
18.93
a
n,
n­
Dimethylformamide
87
b
n­
Decane
9
b
n­
Docosane
88
b
n­
Dodecane
95.05
b
n­
Eicosane
92.4
b
n­
Hexacosane
71.11
b
n­
Hexadecane
71.11
b
n­
Nitrosodimethylamine
77.51
c
n­
Nitrosodiphenylamine
90.11
b
n­
Nitrosopiperidine
77.32
c
n­
Octacosane
71.11
b
n­
Octadecane
71.11
b
n­
Tetracosane
71.11
b
n­
Tetradecane
71.11
b
n­
Triacontane
77.32
c
Naphthalene
94.69
a
Nickel
51.44
a
o+
p
Xylene
65.4
b
o­
Cresol
52.5
b
o­
Xylene
77.32
c
Oil
and
Grease
(
as
HEM)
86.08
a
p­
Cresol
71.67
b
p­
Cymene
99.79
b
Phenanthrene
94.89
a
Phenol
95.25
a
Phosphorus
32.52
c
Pyrene
83.9
b
Pyridine
95.4
b
Selenium
34.33
b
Silver
88.28
a
12­
24
12.0
­
Pollutant
Loading
and
Reduction
Estimates
Table
12­
1
(
Continued)

Chemical
Name
POTW
Percent
Removal
Source
Sodium
2.69
a
Styrene
93.65
b
Sulfate
84.61
b
Tetrachloroethene
84.61
a
Thallium
71.66
c
Tin
42
a
Titanium
91.82
a
Toluene
96.18
a
Total
Dissolved
Solids
8
b
Total
Kjeldahl
Nitrogen
57.41
c
Total
Organic
Carbon
(
TOC)
70.28
a
Total
Petroleum
Hydrocarbons
(
as
SGT­
HEM)
57.41
c
Total
Phosphorus
57.41
c
Total
Recoverable
Phenolics
57.41
c
Total
Sulfide
57.41
c
Total
Suspended
Solids
89.55
a
Trichloroethene
77.51
c
Trichlorofluoromethane
77.32
c
Tripropyleneglycol
Methyl
Ether
52.4
b
Vanadium
9.51
a
Weak­
Acid
Dissociable
Cyanide
57.41
c
Yttrium
32.52
c
Zinc
79.14
a
Note:
See
the
rulemaking
record
for
further
detail
for
the
sources.
a
­
November
5,
1999
Updated
50­
POTW
Study.
Influent
Concentration
10xML,
5xML,
then
20
ppb.
b
­
RREL
Database.
Compiled
for
the
CWT
effluent
guideline
or
the
1995
Phase
I
Proposal.
c
­
Average
POTW
removals
calculated
by
classification
code
from
sources
a
and
b.

12­
25
12.0
­
Pollutant
Loading
and
Reduction
Estimates
12­
26
Table
12­
2
Summary
of
Baseline
Annual
Pollutant
Loadings
Discharged
by
Subcategorya
Subcategory
Discharge
Status
Options
Evaluated
Since
Proposal
NODA
Final
Rule
Number
of
Sites
Pound
Equivalents
(
PE/
yr)
b
Pounds
(
lbs/
yr)
Number
of
Sites
Pound
Equivalents
(
PE/
yr)
b
Pounds
(
lbs/
yr)

Totalb
TSS/
Oil
and
Grease
(
as
HEM)
Totalb
TSS/
Oil
and
Grease
(
as
HEM)

General
Metals
Direct
Option
2
1,521
2,009,351
174,459,398
7,322,917
228
270,336
13,555,899
1,297,831
Indirect
Option
2,
1
MGY
cutoff
2,354
6,234,209
1,106,541,984
41,557,113
NA
Upgrade
Option
NA
429
391,340
369,856
NA
50%
Local
Limits
NA
628
236,171
222,457,659
13,512,840
Metal
Finishing
Job
Shops
Direct
Option
2
24
3,358
950,820
21,111
NA
Indirect
Option
2
1,270
438,866
63,845,074
2,002,275
NA
Upgrade
Option
NA
314
82,633
146,194
NA
Non­
Chromium
Anodizing
Directc
Option
2
(
model
site)
35
2,405,434
219,633,506
4,665,748
19
3,924
1,444,780
29,944
Indirect
Not
Proposed
NA
Printed
Wiring
Board
Direct
Option
2
4
527
70,681
1,584
NA
Indirect
Option
2
840
923,431
82,596,963
4,040,990
NA
Upgrade
Option
NA
354
73,624
130,639
NA
Steel
Forming
and
Finishing
Direct
Option
2
Not
Covered
by
MP&
M
Indirect
Option
2
Oily
Wastes
Direct
Option
6
2,749
11,149
30,585,116
5,709,823
2,382
3,351
6,454,146
588,817
Indirect
Option
6,
2
MGY
cutoff
288
78,247
189,374,738
46,336,329
NA
12.0
­
Pollutant
Loading
and
Reduction
Estimates
Table
12­
2
(
Continued)

Subcategory
Discharge
Status
Options
Evaluated
Since
Proposal
NODA
Final
Rule
Number
of
Sites
Pound
Equivalents
(
PE/
yr)
b
Pounds
(
lbs/
yr)
Number
of
Sites
Pound
Equivalents
(
PE/
yr)
b
Pounds
(
lbs/
yr)

Totalb
TSS/
Oil
and
Grease
(
as
HEM)
Totalb
TSS/
Oil
and
Grease
(
as
HEM)

Railroad
Line
Maintenance
Direct
Option
10
31
865
300,188
17,531
NA
Option
6
NA
9
NA
Indirect
Not
Proposed
NA
Shipbuilding
Dry
Dock
Direct
Direct
6
1,925
10,762,301
8,523,580
6
NA
Indirect
Not
Proposed
NA
Source:
EPA
Costs
&
Loadings
Model.

a
Baseline
loads
reflect
the
load
after
treatment,
or
raw
loads
if
there
is
no
treatment
in
place.

b
Does
not
include
sodium,
calcium,
total
dissolved
solids,
and
boron.

c
EPA s
data
collection
efforts
did
not
identify
any
direct
discharging
non­
chromium
anodizing
facilities.

NA
­
Not
applicable.

12­
27
12.0
­
Pollutant
Loading
and
Reduction
Estimates
12­
28
Table
12­
3
Summary
of
Selected
Option
Annual
Pollutant
Loadings
Discharged
by
Subcategorya
Subcategory
Discharge
Status
Options
Evaluated
Since
Proposal
NODA
Final
Rule
Number
of
Sites
Pound
Equivalents
(
PE/
yr)
b
Pounds
(
lbs/
yr)
Number
of
Sites
Pound
Equivalents
(
PE/
yr)
b
Pounds
(
lbs/
yr)

Totalb
TSS/
Oil
and
Grease
(
as
HEM)
Totalb
TSS/
Oil
and
Grease
(
as
HEM)

General
Metals
Direct
Option
2
1,521
1,011,672
43,517,771
1,508,435
228
263,433
11,733,086
1,007,624
Indirect
Option
2,
1
MGY
cutoff
2,354
508,173
158,758,380
3,957,147
NA
Upgrade
Option
NA
429
89,012
112,968
NA
50%
Local
Limits
NA
628
99,666
89,456,128
820,566
Metal
Finishing
Job
Shops
Direct
Option
2
24
1,707
292,154
5,618
NA
Indirect
Option
2
1,270
139,820
33,732,992
705,244
NA
Upgrade
Option
NA
314
42,945
61,831
NA
Non­
Chromium
Anodizing
Directc
Option
2
(
model
site)
35
12,698
6,263,130
449,851
19
1,879
1,193,263
19,297
Indirect
Not
Proposed
NA
Printed
Wiring
Board
Direct
Option
2
4
341
45,733
1,055
NA
Indirect
Option
2
840
114,167
38,526,836
1,100,894
NA
Upgrade
Option
NA
354
42,068
61,041
NA
Steel
Forming
and
Finishing
Direct
Option
2
Not
Covered
by
MP&
M
Indirect
Option
2
Oily
Wastes
Direct
Option
6
2,749
5,781
3,483,987
191,913
2,382
667
943,466
102,722
Indirect
Option
6,
2
MGY
cutoff
288
33,064
38,007,435
1,679,345
NA
12.0
­
Pollutant
Loading
and
Reduction
Estimates
Table
12­
3
(
Continued)

Subcategory
Discharge
Status
Options
Evaluated
Since
Proposal
NODA
Final
Rule
Number
of
Sites
Pound
Equivalents
(
PE/
yr)
b
Pounds
(
lbs/
yr)
Number
of
Sites
Pound
Equivalents
(
PE/
yr)
b
Pounds
(
lbs/
yr)

Totalb
TSS/
Oil
and
Grease
(
as
HEM)
Totalb
TSS/
Oil
and
Grease
(
as
HEM)

Railroad
Line
Maintenance
Direct
Option
10
31
832
228,830
12,674
NA
Option
6
NA
9
NA
Indirect
Not
Proposed
NA
Shipbuilding
Dry
Dock
Direct
Direct
6
1,869
502,953
34,786
6
NA
Indirect
Not
Proposed
NA
Source:
EPA
Costs
&
Loadings
Model.

a
Option
loads
reflect
the
load
after
the
implementation
of
the
MP&
M
technology
basis
for
each
subcategory.

b
Does
not
include
sodium,
calcium,
total
dissolved
solids,
and
boron.

c
EPA s
data
collection
efforts
did
not
identify
any
direct
discharging
non­
chromium
anodizing
facilities.

NA
­
Not
applicable.

12­
29
12.0
­
Pollutant
Loading
and
Reduction
Estimates
Table
12­
4
Industry
Pollutant
Removals
in
Pounds
(
for
Direct
Dischargers)

Subcategory
Options
Evaluated
Since
Proposal
NODA
Removals
(
lbs)
Final
Rule
Removals
(
lbs)
Option
Promulgated?

Total
TSS/
Oil
and
Grease
(
as
HEM)
Priority
and
Nonconventional
Metals/
Organics
Total
TSS/
Oil
and
Grease
(
as
HEM)
Priority
and
Nonconventional
Metals/
Organics
General
Metals
Option
2
130,941,626
5,814,481
5,693,724
1,822,813
290,207
56,320
No
Metal
Finishing
Job
Shops
Option
2
658,666
15,492
35,661
NA
No
Non­
Chromium
Anodizing
Option
2
(
model
site)
213,370,375
4,215,897
37,401,639
251,517
10,646
16,159
No
Printed
Wiring
Board
Option
2
24,949
530
1,078
NA
No
Steel
Forming
and
Finishing
Option
2
Not
Covered
by
MP&
M
No
Oily
Wastes
Option
6
27,101,129
5,517,909
108,748
5,510,680
486,094
11,271
Yes
Railroad
Line
Maintenance
Option
10
71,358
4,857
482
NA
No
Option
6
NA
NA
No
Shipbuilding
Dry
Dock
Option
10
10,259,349
8,488,793
1,796
NA
No
12­
30
Source:
EPA
Costs
&
Loadings
Model.

Note:
Loadings
estimates
presented
in
this
table
will
not
equal
those
presented
in
the
EEBA.
EEBA
estimates
do
not
include
loadings
for
facilities
that
are
projected
to
close
in
the
baseline.

NA­
Not
applicable.
12.0
­
Pollutant
Loading
and
Reduction
Estimates
12­
31
Table
12­
5
Industry
Pollutant
Removals
in
Pound­
Equivalents
Subcategory
Discharge
Status
Options
Evaluated
Since
Proposal
NODA
Final
Rule
Option
Promulgated?

Number
of
Sites
Pollutant
Removals
(
PE)
Number
of
Sites
Pollutant
Removals
(
PE)

General
Metals
Direct
Option
2
1,521
997,678
228
6,903
No
Indirect
Option
2,
1
MGY
cutoff
2,354
1,360,332
NA
No
Upgrade
Option
NA
429
39,734
No
50%
Local
Limits
NA
628
39,630
No
Metal
Finishing
Job
Shops
Direct
Option
2
24
1,652
NA
No
Indirect
Option
2
1,270
95,149
NA
No
Upgrade
Option
NA
314
6,034
No
Non­
Chromium
Anodizing
Direct
Option
2
(
model
site)
35
2,392,735
19
2,045
No
Indirect
Not
Proposed
NA
No
Printed
Wiring
Board
Direct
Option
2
4
186
NA
No
Indirect
Option
2
840
153,653
NA
No
Upgrade
Option
NA
354
5,157
No
Steel
Forming
and
Finishing
Direct
Option
2
Not
Covered
by
MP&
M
No
Indirect
Option
2
Not
Covered
by
MP&
M
No
Oily
Wastes
Direct
Option
6
2,749
5,367
2,382
2,684
Yes
Indirect
Option
6,
2
MGY
cutoff
288
14,385
NA
No
Railroad
Line
Maintenance
Direct
Option
10
31
34
NA
No
Option
6
NA
9
NA
No
Indirect
Not
Proposed
NA
No
Shipbuilding
Dry
Dock
Direct
Option
10
6
56
6
NA
No
Indirect
Not
Proposed
NA
No
Source:
EPA
Costs
&
Loadings
Model.

Note:
Loadings
estimates
presented
in
this
table
will
not
equal
those
presented
in
the
EEBA.
EEBA
estimates
do
not
include
loadings
for
facilities
that
are
projected
to
close
in
the
baseline.

NA
­
Not
applicable.
