Sector Notebook Project Fabricated Metal Products
This report is one in a series of volumes published by the U.S. Environmental
Protection Agency (EPA) to provide information of general interest regarding
environmental issues associated with specific industrial sectors. The documents
were developed under contract by Abt Associates (Cambridge, MA), and Booz-
Allen & Hamilton, Inc. (McLean, VA). This publication may be purchased from the
Superintendent of Documents, U.S. Government Printing Office. A listing of
available Sector Notebooks and document numbers is included on the following
page.
All telephone orders should be directed to:
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
(202) 512-1800
FAX (202) 512-2250
8:00 a.m. to 4:30 p.m., EST, M-F
Using the form provided at the end of this document, all mail orders should be
directed to:
U.S. Government Printing Office
P.O. Box 371954
Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as
public and academic libraries, Federal, State, local, and foreign governments, and
the media. For further information, and for answers to questions pertaining to these
documents, please refer to the contact names and numbers provided within this
volume.
Electronic versions of all Sector Notebooks are available free of charge at the
following web address: www.epa.gov/oeca/sector. Direct technical questions to the
"Feedback" button at the bottom of the web page.
Cover photograph by Steve Delaney, U.S. EPA. Photograph courtesy of Mid-Atlantic
Finishing, Capitol Heights, Maryland.
September 1995 SIC 34
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Fabricated Metal Products Sector Notebool Project
EPA/310-R-95-007
EPA Office of Compliance Sector Notebook Project
Profile of the Fabricated
Metal Products Industry
September 1995
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401MSt.,SW(MC2221-A)
Washington, DC 20460
SIC Code 34 ii September 1995
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Sector Notebook Project
Fabricated Metal Products
Sector Notebook Contacts
The Sector Notebooks were developed by the EPA's Office of Compliance.
Questions relating to the Sector Notebook Project can be directed to:
Seth Heminway, Coordinator, Sector Notebook Project
US EPA Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7017
Questions and comments regarding the individual documents can be directed to the
appropriate specialists listed below.
Document Number
EPA/310-R-95-001.
EPA/310-R-95-002.
EPA/310-R-95-003.
EPA/310-R-95-004.
EPA/310-R-95-005.
EPA/310-R-95-006.
EPA/310-R-95-007.
EPA/310-R-95-008.
EPA/310-R-95-009.
EPA/310-R-95-010.
EPA/310-R-95-011.
EPA/310-R-95-012.
EPA/310-R-95-013.
EPA/310-R-95-014.
EPA/310-R-95-015.
EPA/310-R-95-016.
EPA/310-R-95-017.
EPA/310-R-95-018.
EPA/310-R-97-001.
EPA/310-R-97-002.
EPA/310-R-97-003.
EPA/310-R-97-004.
EPA/310-R-97-005.
EPA/310-R-97-006.
EPA/310-R-97-007.
EPA/310-R-97-008.
EPA/310-R-97-009.
EPA/310-R-97-010.
EPA/310-R-98-001.
EPA/310-R-98-002.
EPA/310-R-98-003.
EPA/310-R-98-004.
EPA/310-R-98-005.
Industry
Dry Cleaning Industry
Electronics and Computer Industry*
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry*
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry*
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry*
Petroleum Refining Industry
Printing Industry
Pulp and Paper Industry
Rubber and Plastic Industry
Stone, Clay, Glass, and Concrete Industry
Transportation Equipment Cleaning Ind.
Air Transportation Industry
Ground Transportation Industry
Water Transportation Industry
Metal Casting Industry
Pharmaceuticals Industry
Plastic Resin and Man-made Fiber Ind.
Fossil Fuel Electric Power Generation Ind.
Shipbuilding and Repair Industry
Textile Industry
Sector Notebook Data Refresh-1997
Aerospace Industry
Agricultural Chemical, Pesticide, and
Fertilizer Industry
Agricultural Crop Production Industry
Agricultural Livestock Production Ind.
Oil and Gas Exploration and Production
Industry
Contact
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Jane Engert
Anthony Raia
Jane Engert
Rob Lischinsky
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Seth Heminway
Maria Malave
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Anthony Raia
Belinda Breidenbach
Seth Heminway
Anthony Raia
Amy Porter
Phone (202)
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-5021
564-6045
564-5021
564-2628
564-7067
564-7003
564-7072
564-7017
564-7027
564-7013
564-7057
564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-6045
564-7022
564-7017
564-6045
564-4149
Ginah Mortensen (913)551-7864
Ginah Mortensen (913)551-7864
Dan Chadwick 564-7054
September 1995
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SIC Code 34
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Fabricated Metal Products Sector Notebool Project
EPA/310-R-98-008. Local Government Operations John Dombrowski 564-7036
*Spanish translations available.
SIC Code 34 iv September 1995
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Sector Notebook Project Fabricated Metal Products
FABRICATED METAL PRODUCTS
(SIC 34)
TABLE OF CONTENTS
Page
EXHIBIT INDEX vn
LIST OF ACRONYMS ix
I. INTRODUCTION OF THE SECTOR NOTEBOOK PROJECT 1
LA. Summary of the Sector Notebook Project 1
I.E. Additional Information 2
II. INTRODUCTION TO THE FABRICATED METAL PRODUCTS INDUSTRY 4
II. A. Introduction, Background, and Scope of the Notebook 4
II. B. Characterization of the Fabricated Metal Products Industry 4
II.B.I. Industry Size and Geographic Distribution 4
II.B.2. Product Characterization 9
II.B.3. Economic Trends 9
III. INDUSTRIAL PROCESS DESCRIPTION 12
III.A. Industrial Processes in the Fabricated Metal Products
Industry 12
III.A.l. Fabricated Metal Products 13
III.A.2. Surface Preparation 15
III.A.3. Metal Finishing 16
III.B. Raw Material Inputs and Pollution Outputs in the
Production Line 21
III.B.l. Metal Fabrication 24
III.B.2. Surface Preparation 25
III.B.3. Metal Finishing 25
III.C. Management of Chemicals in Wastestream 29
September 1995 v SIC Code 34
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Fabricated Metal Products Sector Notebool Project
FABRICATED METAL PRODUCTS
(SIC 34)
TABLE OF CONTENTS (CONT'D)
Page
IV. CHEMICAL RELEASE AND TRANSFER PROFILE 31
IV.A. EPA Toxic Release Inventory for the Fabricated Metal
Products Industry 34
IV.B. Summary of the Selected Chemicals Released 46
IV.C. Other Data Sources 53
IV.D. Comparison of Toxic Release Inventory Between Selected Industries
55
V. POLLUTION PREVENTION OPPORTUNITIES 58
V. A. Identification of Pollution Prevention Activities in Use and
Environmental and Economic Benefits of Each Pollution Prevention
Activity 58
V.B. Possible Pollution Prevention Future Trends 61
V.C. Pollution Prevention Case Studies 62
V.D. Pollution Prevention Options 65
V.D.I. Metal Shaping Operations 65
V.D.2. Surface Preparation Operations 67
V.D.3. Plating Operations 71
V.D.4. Other Finishing Operations 75
V.E. Pollution Prevention Contacts 78
VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS 80
VI. A. General Description of Major Statutes 80
VLB. Industry Specific Regulations 92
VI.C. Pending and Proposed Regulatory Requirements 97
SIC Code 34 vi September 1995
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Sector Notebook Project Fabricated Metal Products
FABRICATED METAL PRODUCTS
(SIC 34)
TABLE OF CONTENTS (CONT'D)
Page
VII. COMPLIANCE AND ENFORCEMENT PROFILE 100
VILA. Fabricated Metal Products Industry Compliance History 104
VII.B. Comparison of Enforcement Activity Between
Selected Industries 104
VII.C. Review of Major Legal Actions Ill
VII.C.I Review of Major Cases Ill
VII.C.2 Supplemental Environmental Projects 112
VIII. COMPLIANCE ACTIVITIES AND INITIATIVES 116
VIII.A. Sector-Related Environmental Programs and Activities 116
VIII.B. EPA Voluntary Programs 122
VIII.C. Trade Association/Industry Sponsored Activity 132
VIII.C.I. Environmental Programs 132
VIII.C.2. Summary of Trade Associations 134
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/
BIBLIOGRAPHY AND OTHER REFERENCES 138
September 1995 vii SIC Code 34
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Sector Notebool Project
FABRICATED METAL PRODUCTS (SIC 34)
EXHIBIT INDEX
Page
Exhibit 1 Metal Fabrication Companies 5
Exhibit 2 Number of Employees in Metal Finishing Industry 5
Exhibit 3 Value of Shipments for Metal Finishing Establishments 6
Exhibit 4 Inorganic Coating Job Shops 6
Exhibit 5 Organic Coating Job Shops 6
Exhibit 6 Metal Finishing Establishments, by Size 7
Exhibit 7 Geographic Distribution of Fabricated Metal Products Industry 7
Exhibit 8 Markets Served by Metal Finishers 10
Exhibit 9 Forming Operations 14
Exhibit 10 Rolling 14
Exhibit 11 Process for Preparing Metal for Electroplating 15
Exhibit 12 Overview of the Metal Finishing Process 16
Exhibit 13 Typical Electroplating Equipment 18
Exhibit 14 Electroless Plating Process 19
Exhibit 15 Process Materials Inputs and Outputs 22
Exhibit 16 Fabricated Metal Products Manufacturing Processes 23
Exhibit 17 Typical Metal Finishing Process Step 26
Exhibit 18 Source Reduction and Recycling Activity for SIC 34 30
Exhibit 19 Top 10 TRI Releasing Fabricated Metal Products Facilities 35
Exhibit 20 Top 10 TRI Releasing Metal Fabricating & Finishing
Facilities (SIC 34) 36
Exhibit 21 Reductions in TRI Releases, 1988-1993 (SIC 34) 36
Exhibit 22 Reductions in TRI Transfers, 1988-1993 (SIC 34) 36
Exhibit 23 TRI Reporting Metal Fabricating & Finishing Facilities
(SIC 34) by State 37
Exhibit 24 Releases for Metal Fabricating & Finishing Facilities (SIC 34)
in TRI, by Number of Facilities (Releases
reported in pounds/year) 38, 39
Exhibit 25 Transfers for Metal Fabricating & Finishing Facilities (SIC 34) in TRI,
by Number of Facilities (Transfers reported
in pounds/year) 40, 41
Exhibit 26 Top 10 TRI Releasing Metal Finishing Facilities (SIC 347) 42
Exhibit 27 TRI Reporting Metal Finishing Facilities (SIC 347) by State 43
Exhibit 28 Releases for Metal Finishing (SIC 347) in TRI, by Number of Facilities
(Releases reported in pounds/year) 43, 44
SIC Code 34
Vlll
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Fabricated Metal Products
FABRICATED METAL PRODUCTS (SIC 34)
EXHIBIT INDEX (CONT'D)
Page
Exhibit 29 Transfers for Metal Finishing (SIC 347) in TRI, by Number of Facilities
(Transfers reported in pounds/year) 45, 46
Exhibit 30 Pollutant Releases (Short Tons/Year) 54
Exhibit 31 Summary of 1993 TRI Data 56
Exhibit 32 Toxic Releases Inventory for Selected Industries 57
Exhibit 33 Hazardous Wastes Relevant to the Metal
Finishing Industry 96, 97
Exhibit 34 Five Year Enforcement and Compliance Summary
for Fabricated Metal Products Industry 106
Exhibit 35 Five Year Enforcement and Compliance Summary for
Selected Industries 107
Exhibit 36 One Year Enforcement and Compliance Summary for
Selected Industries 108
Exhibit 37 Five Year Inspection and Enforcement Summary by Statute
for Selected Industries 109
Exhibit 38 One Year Inspection and Enforcement Summary by Statute
for Selected Industries 110
Exhibit 39 Supplemental Environmental Projects 113, 114, 115
Exhibit 40 Fabricated Metal Producers Participating in the
33/50 Program 123 - 129
September 1995
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SIC Code 34
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Fabricated Metal Products
Sector Notebool Project
FABRICATED METAL PRODUCTS
(SIC 34)
LIST OF ACRONYMS
AFS - AIRS Facility Subsystem (CAA database)
AIRS - Aerometric Information Retrieval System (CAA database)
BIFs - Boilers and Industrial Furnaces (RCRA)
BOD - Biochemical Oxygen Demand
CAA - Clean Air Act
CAAA - Clean Air Act Amendments of 1990
CERCLA - Comprehensive Environmental Response, Compensation and
Liability Act
CERCLIS - CERCLA Information System
CFCs - Chlorofluorocarbons
CO - Carbon Monoxide
COD - Chemical Oxygen Demand
CSI - Common Sense Initiative
CWA - Clean Water Act
D&B - Dun and Bradstreet Marketing Index
ELP - Environmental Leadership Program
EPA - United States Environmental Protection Agency
EPCRA - Emergency Planning and Community Right-to-Know Act
FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act
FINDS - Facility Indexing System
HAPs - Hazardous Air Pollutants (CAA)
HSDB - Hazardous Substances Data Bank
IDEA - Integrated Data for Enforcement Analysis
LDR - Land Disposal Restrictions (RCRA)
LEPCs - Local Emergency Planning Committees
MACT - Maximum Achievable Control Technology (CAA)
MCLGs - Maximum Contaminant Level Goals
MCLs - Maximum Contaminant Levels
MEK - Methyl Ethyl Ketone
MSDSs - Material Safety Data Sheets
NAAQS - National Ambient Air Quality Standards (CAA)
NAFTA - North American Free Trade Agreement
NCDB - National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP - National Oil and Hazardous Substances Pollution Contingency Plan
NEIC - National Enforcement Investigation Center
NESHAP - National Emission Standards for Hazardous Air Pollutants
NO2 - Nitrogen Dioxide
NOV - Notice of Violation
NOX - Nitrogen Oxide
NPDES - National Pollution Discharge Elimination System (CWA)
SIC Code 34
September 1995
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Sector Notebook Project
Fabricated Metal Products
FABRICATED METAL PRODUCTS
(SIC 34)
LIST OF ACRONYMS (CONT'D)
NPL - National Priorities List
NRC - National Response Center
NSPS - New Source Performance Standards (CAA)
OAR - Office of Air and Radiation
OECA - Office of Enforcement and Compliance Assurance
OPA - Oil Pollution Act
OPPTS - Office of Prevention, Pesticides, and Toxic Substances
OSHA - Occupational Safety and Health Administration
OSW - Office of Solid Waste
OSWER - Office of Solid Waste and Emergency Response
OW - Office of Water
P2 - Pollution Prevention
PCS - Permit Compliance System (CWA Database)
POTW - Publicly Owned Treatments Works
RCRA - Resource Conservation and Recovery Act
RCRIS - RCRA Information System
SARA - Superfund Amendments and Reauthorization Act
SDWA - Safe Drinking Water Act
SEPs - Supplementary Environmental Projects
SERCs - State Emergency Response Commissions
SIC - Standard Industrial Classification
SO2 - Sulfur Dioxide
TOC - Total Organic Carbon
TRI - Toxic Release Inventory
TRIS - Toxic Release Inventory System
TCRIS - Toxic Chemical Release Inventory System
TSCA - Toxic Substances Control Act
TSS - Total Suspended Solids
UIC - Underground Injection Control (SDWA)
UST - Underground Storage Tanks (RCRA)
VOCs - Volatile Organic Compounds
September 1995
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Fabricated Metal Products Sector Notebook Project
FABRICATED METAL PRODUCTS
(SIC 34)
I. INTRODUCTION OF THE SECTOR NOTEBOOK PROJECT
LA. Summary of the Sector Notebook Project
Environmental policies based upon comprehensive analysis of air,
water, and land pollution are an inevitable and logical supplement to
traditional single-media approaches to environmental protection.
Environmental regulatory agencies are beginning to embrace
comprehensive, multi-statute solutions to facility permitting,
enforcement and compliance assurance, education/outreach, research,
and regulatory development issues. The central concepts driving the
new policy direction are that pollutant releases to each environmental
medium (air, water, and land) affect each other, and that
environmental strategies must actively identify and address these
inter-relationships by designing policies for the "whole" facility. One
way to achieve a whole facility focus is to design environmental
policies for similar industrial facilities. By doing so, environmental
concerns that are common to the manufacturing of similar products
can be addressed in a comprehensive manner. Recognition of the need
to develop the industrial "sector-based" approach within the EPA
Office of Compliance led to the creation of this document.
The Sector Notebook Project was initiated by the Office of Compliance
within the Office of Enforcement and Compliance Assurance (OECA)
to provide its staff and managers with summary information for
eighteen specific industrial sectors. As other EPA offices, States, the
regulated community, environmental groups, and the public became
interested in this project, the scope of the original project was
expanded. The ability to design comprehensive, common sense
environmental protection measures for specific industries is
dependent on knowledge of several inter-related topics. For the
purposes of this project, the key elements chosen for inclusion are:
general industry information (economic and geographic); a description
of industrial processes; pollution outputs; pollution prevention
opportunities; Federal statutory and regulatory framework;
compliance history; and a description of partnerships that have been
formed between regulatory agencies, the regulated community, and
the public.
September 1995 1 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
For any given industry, each topic listed above could alone be the
subject of a lengthy volume. However, in order to produce a
manageable document, this project focuses on providing summary
information for each topic. This format provides the reader with a
synopsis of each issue, and references where more in-depth
information is available. Text within each profile was researched from
a variety of sources, and was usually condensed from more detailed
sources pertaining to specific topics. This approach allows for a wide
coverage of activities that can be further explored based upon the
citations and references listed at the end of this profile. As a check on
the information included, each notebook went through an external
review process. The Office of Compliance appreciates the efforts of all
those that participated in this process and enabled us to develop more
complete, accurate, and up-to-date summaries. Many of those who
reviewed this notebook are listed as contacts in Section IX and may be
sources of additional information. The individuals and groups on this
list do not necessarily concur with all statements within this notebook.
I.E. Additional Information
Providing Comments
OECA's Office of Compliance plans to periodically review and update
the notebooks and will make these updates available both in hard
copy and electronically. If you have any comments on the existing
notebook, or if you would like to provide additional information,
please send a hard copy and computer disk to the EPA Office of
Compliance, Sector Notebook Project, 401 M St., SW (2223-A),
Washington, DC 20460. Comments can also be uploaded to the
Enviro$en$e Bulletin Board or the Enviro$en$e World Wide Web for
general access to all users of the system. Follow instructions in
Appendix A for accessing these data systems. Once you have logged
in, procedures for uploading text are available from the on-line
Enviro$en$e Help System.
Adapting Notebooks to Particular Needs
The scope of the existing notebooks reflect an approximation of the
relative national occurrence of facility types that occur within each
sector. In many instances, industries within specific geographic
regions or States may have unique characteristics that are not fully
captured in these profiles. For this reason, the Office of Compliance
encourages State and local environmental agencies and other groups
SIC Code 34 2 September 1995
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Fabricated Metal Products Sector Notebook Project
to supplement or re-package the information included in this notebook
to include more specific industrial and regulatory information that
may be available. Additionally, interested States may want to
supplement the "Summary of Applicable Federal Statutes and
Regulations" section with State and local requirements. Compliance or
technical assistance providers may also want to develop the "Pollution
Prevention" section in more detail. Please contact the appropriate
specialist listed on the opening page of this notebook if your office is
interested in assisting us in the further development of the information
or policies addressed within this volume.
If you are interested in assisting in the development of new notebooks
for sectors not covered in the original eighteen, please contact the
Office of Compliance at 202-564-2395.
September 1995 3 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
II. INTRODUCTION TO THE FABRICATED METAL PRODUCTS INDUSTRY
This section provides background information on the size, geographic
distribution, employment, production, sales, and economic condition
of the Fabricated Metal Products industry. The types of facilities
described within the document are also described in terms of their
Standard Industrial Classification (SIC) codes. Additionally, this
section contains a list of the largest companies in terms of sales.
II. A. Introduction, Background, and Scope of the Notebook
The fabricated metal products industry comprises facilities that
generally perform two functions: forming metal shapes and
performing metal finishing operations, including surface preparation.
The Standard Industrial Classification (SIC) code 34 is composed of
establishments that fabricate ferrous and nonferrous metal products
and those that perform electroplating, plating, polishing, anodizing,
coloring, and coating operations on metals. Since the main processes
associated with this industry can be divided into three types of
operations (i.e., metal fabrication, metal preparation, and metal
finishing), this profile is organized by the techniques that fall within
these three groups.
II.B. Characterization of the Fabricated Metal Products Industry
To provide a general understanding of this industry, information
pertaining to the industry size and distribution, product
characterization, and economic health and outlook is presented below.
This information should provide a basic understanding of the facilities
developing the products, the products themselves, and the economic
condition of the industry.
II.B.I. Industry Size and Geographic Distribution
Variation in facility counts occur across data sources due to many
factors, including reporting and definitional differences. This
document does not attempt to reconcile these differences, but rather
reports the data as they are maintained by each source.
The U.S. fabricated metal products industry comprises approximately
34,000 companies. Exhibit 1 lists the largest companies in selected
metal fabricating industries. Companies are ranked by sales figures.
SIC Code 34 4 September 1995
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Fabricated Metal Products
Sector Notebook Project
Exhibit 1
Metal Fabrication Companies
Company
Sales
($ Millions)
Number of
Employees
SIC 3444 - Sheet Metal Work
Stolle Corp., Sidney, OH
Alcan Alum. Corp., Warren, OH
Nytronics, Inc., Pitman, NJ
Hart and Cooley Inc., Holland, MI
Syro Steel Co., Girard, OH
Consolidated Systems, Inc., Columbia, SC
480
120
110
100
100
100
4,600
1,200
2,000
1,200
400
300
SIC 3465 -- Automotive Stampings
Budd Co., Troy, MI
Douglas and Lomason Co., Farmington Hts.,
MI
Northern Engraving Corp., Sparta, WI
Randall Textron Inc., Cincinnati, OH
1,000
391
280
210
9,000
5,800
3,000
2,000
SIC 3469 - Metal Stampings
Hexcel Corp., Pleasanton, CA
JSJ Corp., Grand Haven, MI
Mirro-Foley Co., Manitowoc, WI
Tempel Steel Co., Niles, IL
386
260
210
210
2,900
2,500
2,000
1,100
SIC 3499 - Fabricated Metal Products
Steel Technologies, Louisville, KY
R.D. Werner Company, Inc., Greenville, PA
BW/IP Int., Inc., Seal Div., Long Beach, CA
LeFebure Corp., Cedar Rapids, IA
Dura Mech. Components, Inc., Troy, MI
155
150
104
100
100
500
1,600
400
1,100
1,000
Source: Fabricators & Manufacturers Association, Intl.
Exhibits 2 and 3 show the distribution of employees and the total
shipments for the metal finishing industry. A typical "job shop" (i.e.,
small, independently owned metal finishing company) employs 15 to
20 people and generates $800,000 to $1 million in annual gross
revenues.
Exhibit 2
Number of Employees in Metal Finishing Industry
SIC 3471
SIC 3479
Total
1988
76,300
47,000
123,300
1989
76,600
44,600
121,200
1990
73,200
44,300
117,500
1991
66,600
43,400
110,000
1992
65,400
43,700
109,100
Source: U.S. Department of Commerce, 1992 Census of Manufacturers.
September 1995
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Fabricated Metal Products
Sector Notebook Project
Exhibit 3
Value of Shipments for Metal Finishing Establishments ($ Millions)
SIC 3471
SIC 3479
Total
1988
4,324
4,867
9,191
1989
4,452
4,756
9,208
1990
4,513
4,929
9,442
1991
4,124
4,634
8,758
1992
4,726
5,161
9,887
Source: U.S. Department of Commerce, 1992 Census of Manufacturers.
Exhibits 4 and 5 list the largest companies in selected metal finishing
industries. Companies are ranked by sales figures.
Exhibit 4
Inorganic Coating Job Shops
Company
Windsor Plastics, Evansville, IN
Crown City Plating, El Monte, CA
Pioneer Metal Finishing, Minneapolis, MN
Metal Surfaces, Bell Gardens, CA
Victory Finishing Technologies, Inc., Providence,
RI
State Plating, Inc., Elwood, IN
Sales
($ Millions)
50
25
20-30
15-25
15-25
15-20
Number of
Employees
600
425
380
310
245
400
Source: "Large Plating Job Shops," Beverly A. Greaves, Products Finishing, April 1994.
Exhibit 5
Organic Coating Job Shops
Company
Metokote Corp., Lima, OH
The Crown Group, Warren, MI
Industrial Powder Coatings, Inc., Norwalk, OH
PreFinish Metals, Chicago, IL
E/M Corp., West Lafayette, IN
Chicago Finished Metals, Bridgeview, IL
Linetec Co., Wausau, WI
B.L. Downey Co., Inc., Broadview, IL
Sales
($ Millions)
25+
25+
25+
25+
15-25
25+
10-15
10-15
Number of
Employees
800
659
620
600
300
250
200
175
Source: "Large Coating Job Shops," Beverly A. Greaves, Products Finishing, December 1994.
Between 1982 and 1987, the total number of independent metal
finishers employing less than 20 employees declined slightly, while
those employing more than 20 employees increased by a
corresponding amount. Exhibit 6 shows the number and percent of
metal finishers of various sizes.
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Fabricated Metal Products
Sector Notebook Project
Exhibit 6
Metal Finishing Establishments, by Size
1987
Establishments With
and Average of :
1 to 9 Employees
10 to 49 Employees
50 to 99 Employees
100 to 249 Employees
250 or more Employees
Total
Number of
Companies
2481
2262
365+
137
20
5265
Percent Total
47.1
43.0
6.9
2.6
0.4
100.0
1992
Number of
Companies
2553
2186
381
356
127
5603
Percent
Total
48.7
41.7
6.8
2.4
0.4
100.0
Source: Census of Manufacturers: 1992, U. S. Department of Commerce, Bureau of the Census.
Although the metal finishing industry is geographically diverse, the
industry is concentrated in what are usually considered the most
heavily industrialized regions in the United States (See Exhibit 7).
This geographic concentration occurs in part because it is cost-effective
for small metal finishing facilities to be located near their customer
base.
Exhibit 7
Geographic Distribution of Fabricated Metal Products Industry
Source: Census of Manufacturers: 1987.
California has more establishments that produce metal-related
products than any other State. California's establishments constitute
10.2 percent of the total establishments that produce fabricated
structural metal (SIC 3441). In addition, California leads in the
September 1995
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number of establishments of other related industries: 15.6 percent of
the sheet metal work establishments (SIC 3444); 13 percent of the metal
doors, sash, and trim establishments (SIC 3442); and 13.7 percent of the
architectural metal work establishments (SIC 3446). California also
has the majority of plating and polishing (SIC 3471) and metal coating
and allied services (SIC 3479) establishments at 17.3 and 16.1 percent,
respectively.
Michigan, Illinois, and Ohio have large numbers of various metal-
related industries. Michigan has the largest number of companies in
the screw machine products (SIC 3451) and automotive stampings
(SIC 3465) industries, at 14 and 46.7 percent of the total companies in
the United States, respectively. Illinois is home to 14.1 percent of
companies that produce bolts, nuts, rivets, and washers (SIC 3452) and
Ohio contains 12.6 percent of companies that produce iron and steel
forgings (SIC 3462).
Establishments engaged primarily in metal finishing tend to be small,
independently owned job shops, also are referred to as independent
metal finishers. Establishments that conduct metal finishing
operations as part of a larger manufacturing operation are referred to
as "captive" metal finishers. Captive metal finishing facilities are
approximately three times more numerous than independent metal
finishers. Numerous similarities exist between the independent and
captive facilities; for the purposes of this profile, they are considered
part of one industry. In addition, the two segments have parallel ties
with suppliers and customers. Captive operations may be more
specialized in their operations, however, because they often work on a
limited number of products and/or employ a limited number of
processes. Independent metal finishers, on the other hand, tend to be
less specialized in their operations because they may have many
customers, often with different requirements.
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II.B.2. Product Characterization
The Department of Commerce classification codes divide this industry
by product and services. SIC code 34 is further divided as follows:
SIC 341 - Metal Cans and Shipping Containers
SIC 342 - Cutlery, Handtools, and General Hardware
SIC 343 - Heating Equipment, Except Electric and Warm
Air, and Plumbing Fixtures
SIC 344 - Fabricated Structural Metal Products
SIC 345 - Screw Machine Products, and Bolts, Nuts, Screws,
Rivets, and Washers
SIC 346 - Metal Forgings and Stampings
SIC 347 - Coating, Engraving, and Allied Services
SIC 348 - Ordnance and Accessories, Except Vehicles and
Guided Missiles
SIC 349 - Miscellaneous Fabricated Metal Products.
II.B.3. Economic Trends
Most industries in SIC 34 are largely dependent upon the demands of
other industries. For example, the success of the commercial
construction industry is fundamental to the success of the fabricated
structural metal industry; 95 percent of the output from the latter is
consumed by the former. The general component-producing
industries (e.g., screw machine products, industrial fasteners, etc.)
display the same demand structure; the demand for such products is
directly related to the demand for automobiles and public works
construction.
Fabricated structural metal output declined two percent in 1993 due to
a decrease in construction of office buildings, commercial structures,
manufacturing facilities, and multi-family housing. Ninety-five
percent of structural metal output is consumed by the construction
industry. Low demand for structural metal is expected to continue,
attributable to the recent overbuilding of commercial space and high
levels of vacant office space. A slight increase in demand from the
public sector (e.g., highway construction) is expected, however, which
will positively influence demand for structural metal products. An
increased demand for plumbing products is also likely, as the
residential construction industry continues to grow.
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Total shipments of general components (e.g., screw machine products,
industrial fasteners, valves, and pipe fittings) increased by about 3.1
percent in 1993. Strong demand from the automotive sector, combined
with increased demand from equipment and machinery
manufacturers, were the major factors causing the increased
shipments.
The two primary markets for metal finishing services are the
automotive and electronics industries. As illustrated in Exhibit 8,
consumer durables, aerospace, and the government also are large
segments served by metal finishers.
Exhibit 8
Markets Served by Metal Finishers
Percent of 1992 Market
25%
20%
15% • •
Source: Surface Finishing Market Research Board, Metal Finishing Industry Market Survey 1992-1993.
NOTE: Data includes both job and captive shops.
The sale of metal finishing services is also essentially a derived
demand (i.e., sales depend entirely upon the production of other
industries). However, sales by the metal finishing industry have not
kept up with sales of the industries served.
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In the last several years, many U.S. fastener (nuts, screws, bolts, rivets)
companies have become more competitive in the global market by
incorporating new technology into production lines to improve
efficiency and quality. In 1993, U.S. exports of industrial fasteners
edged up about 0.6 percent; Canada and Mexico were the largest
importers. U.S. imports of industrial fasteners also increased 11
percent over the last several years. This is because demand in the U.S.
out-paced production. The expansion of the U.S. automotive and
residential construction sectors was a major factor in the increase in
fastener imports.
Exports of U.S. valve and pipe fittings are also expected to grow. 1993
industry exports increased six percent compared with 1992 figures.
Although Canada remains the principal foreign market, exports to
Chile and the Philippines almost tripled, and exports to developing
countries increased dramatically.
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III. INDUSTRIAL PROCESS DESCRIPTION
This section describes the major industrial processes within the
Fabricated Metal Products industry, including the materials and
equipment used and the processes employed. The section is designed
for those interested in gaining a general understanding of the
industry, and for those interested in the inter-relationship between the
industrial process and the topics described in subsequent sections of
this profile: pollutant outputs, pollution prevention opportunities,
and Federal regulations. This section does not attempt to replicate
published engineering information that is available for this industry.
Refer to Section IX for a list of reference documents that are available.
Specifically, this section contains a description of commonly used
production processes, the associated raw materials, the byproducts
produced or released, and the materials either recycled or transferred
off-site. This discussion, coupled with schematic drawings of the
identified processes, provides a concise description of where wastes
may be produced in the process. This section also describes the
potential fate (air, water, land) of these waste products.
III.A. Industrial Processes in the Fabricated Metal Products Industry
In view of the high cost of most new equipment and the relatively long
lead time necessary to bring new equipment into operation, changes in
production methods and products are made only gradually; even new
process technologies that fundamentally change the industry are only
adopted over long periods of time. In addition, the recent financial
performance of the Fabricated Metal Products industry combined with
the difficulty of raising funds in the bond market, have left many
establishments with a limited ability to raise the capital necessary to
purchase new equipment.
For the purposes of this profile, the industrial processes associated
with the Fabricated Metal Products industry will be grouped into
three categories: fabricated metal products; surface preparation; and
metal finishing. Each category is discussed in greater depth in the
following subsections.
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III.A.l. Fabricated Metal Products
Once molten metal (ferrous or nonferrous) containing the correct
metallurgical properties has been produced (see SIC 33, which
comprises activities associated with the nonferrous metals industry), it
is cast into a form that can enter various shaping processes. Recently,
manufacturers have been using continuous casting techniques that
allow the molten metal to be formed directly into sheets, eliminating
interim forming stages. This section identifies some of the many
forming and shaping methods used by the metal fabrication industry.
In general, the metal may be heat treated or remain cold. Heat
treating is the modification of the physical properties of a workpiece
through the application of controlled heating and cooling cycles. Cold
metal is formed by applying direct physical pressure to the metal.
Regardless of the forming method used, the metal fabricating process
usually employs the use of cutting oils (e.g., ethylene glycol),
degreasing and cleaning solvents, acids, alkalis, and heavy metals.
The oils are typically used when forming and cutting the metal. The
solvents (e.g., trichloroethane, methyl ethyl ketone), alkalines, and
acids (e.g., hydrochloric, sulfuric) are used to clean the surface of the
metals. The current trend in the industry is to use aqueous non-VOCs
to clean the metals, whenever possible. The use of 1,1,1-
trichloroethane and methyl ethyl ketone is declining.
Once molten metal is formed into a workable shape, shearing and
forming operations are usually performed. Shearing operations cut
materials into a desired shape and size, while forming operations
bend or conform materials into specific shapes. Cutting or shearing
operations include punching, piercing, blanking, cutoff, parting,
shearing, and trimming. Basically, these operations produce holes or
openings, or produce blanks or parts. The most common hole-making
operation is punching. Cutoff, parting, and shearing are similar
operations with different applications. The rate of production is
highest in hot forging operations and lowest in simple bending and
spinning operations.
Forming operations, as illustrated in Exhibit 9, shape parts by
bending, forming, extruding, drawing, rolling, spinning, coining, and
forging the metal into a specific configuration. Bending is the simplest
forming operation; the part is simply bent to a specific angle or shape.
Other types of forming operations produces both two- and three-
dimensional shapes.
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Exhibit 9
Forming Operations
Punch
Die
Workpiece
Extruding is the process of forming a specific shape from a solid blank
by forcing the blank through a die of the desired shape. Extruding can
produce complicated and intricate cross-sectional shapes. In rolling
the metal passes through a set or series of rollers that bend and form
the part into the desired shape (See Exhibit 10). Coining is a process
that alters the form of the part by changing its thickness to produce a
three-dimensional relief on one or both sides of the part, like a coin.
Exhibit 10
Rolling
Die Rollers
Workpiece
In drawing, a punch forces sheet stock into a die, where the desired
shape is formed in the space between the punch and die. In spinning,
pressure is applied to the sheet while it spins on a rotating form,
forcing the sheet to acquire the shape of the form. Forging operations
produce a specific shape by applying external pressure that either
strikes or squeezes a heated blank into a die of the desired shape.
Forging operations may be conducted on hot or cold metal using
either single- or multi-stage dies.
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Once shearing and forming activities are complete, the material is
machined. Machining refines the shape of a workpiece by removing
material from pieces of raw stock with machine tools. The principal
processes involved in machining are drilling, milling, turning,
shaping/planing, broaching, sawing, and grinding.
III.A.2.
Surface Preparation
The surface of the metal may require preparation prior to applying a
finish. Surface preparation, cleanliness, and proper chemical
conditions are essential to ensuring that finishes perform properly.
Without a properly cleaned surface, even the most expensive coatings
will fail to adhere or prevent corrosion. Surface preparation
techniques range from simple abrasive blasting to acid washes to
complex, multi-stage chemical cleaning processes. Exhibit 11 provides
a flow chart of a representative process used when preparing metal for
electroplating. Various surface preparation methods are discussed
below.
Exhibit 11
Process for Preparing Metal for Electroplating
Acid
Pickling
-
Rinse
-
1
Alkaline
Cleaning
Si
Cl
jrface
eaning
Rinse
-
1
Alkaline
Cleaning
-^- Rinse
Source: Metals Handbook, Ninth Edition: Volume 5, Surface Cleaning, Finishing, and Coating, 1982, American Society
for Metals.
Some cleaning techniques involve the application of organic solvents
to degrease the surface of the metal. Other techniques, emulsion
cleaning, for example, use common organic solvents (e.g., kerosene,
mineral oil, and glycols) dispersed in an aqueous medium with the aid
of an emulsifying agent. Emulsion cleaning uses less chemical than
solvent degreasing because the concentration of solvent is lower.
Alkaline cleaning may also be utilized for the removal of organic soils.
Most alkaline cleaning solutions are comprised of three major types of
components: (1) builders, such as alkali hydroxides and carbonates,
which make up the largest portion of the cleaner; (2) organic or
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Fabricated Metal Products Sector Notebook Project
inorganic additives, which promote better cleaning or act to affect the
metal surface in some way; and (3) surfactants. Alkaline cleaning is
often assisted by mechanical action, ultrasonics, or by electrical
potential (e.g., electrolytic cleaning).
Acid cleaning, or pickling, can also be used to prepare the surface of
metal products by chemically removing oxides and scale from the
surface of the metal. For instance, most carbon steel is pickled with
sulfuric or hydrochloric acid, while stainless steel is pickled with
hydrochloric or hydrofluoric acids, although hydrochloric acid may
embrittle certain types of steel and is rarely used. The metal generally
passes from the pickling bath through a series of rinses. Acid pickling
is similar to acid cleaning, but is usually used to remove the scale from
semi-finished mill products, whereas acid cleaning is usually used for
near-final preparation of metal surfaces before electroplating, painting,
and other finishing processes.
III.A.3. Metal Finishing
Surface finishing usually involves a combination of metal deposition
operations and numerous finishing operations. A diagram depicting
the general metal finishing process, including surface preparation, is
provided in Exhibit 12. Wastes typically generated during these
operations are associated with the solvents and cleansers applied to
the surface and the metal-ion-bearing aqueous solutions used in the
plating tanks. Metal-ion-bearing solutions are commonly based on
hexavalent chrome, trivalent chrome, copper, gold, silver, cadmium,
zinc, and nickel. Many other metals and alloys are also used, although
less frequently. The cleaners (e.g., acids) may appear in process
wastewater; the solvents may be emitted into the air, released in
wastewater, or disposed of in solid form; and other wastes, including
paints, metal-bearing sludges, and still bottom wastes, may be
generated in solid form. Several of the many metal finishing
operations are described below.
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Fabricated Metal Products
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Exhibit 12
Overview of the Metal Finishing Process
Alkaline Rinse
Cleaner
t
Acid Dip
'
Rinse
-
_., Drag-out
Plating -* Ja*ks H
1
Surface
Preparation
Fini
» Rinse -» Trea
1
Surface
Treatment
shing -» Rinse
tment
Source: Sustainable Industry: Promoting Strategic Environmental Protection in the Industrial Sector,
Phase 1 Report, U.S. EPA, OERR, June 1994.
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Anodizing
Anodizing is an electrolytic process which converts the metal surface
to an insoluble oxide coating. Anodized coatings provide corrosion
protection, decorative surfaces, a base for painting and other coating
processes, and special electrical and mechanical properties.
Aluminum is the most frequently anodized material. Common
aluminum anodizing processes include: chromic acid anodizing,
sulfuric acid anodizing, and boric-sulfuric anodizing. The sulfuric
acid process is the most common method.
Following anodizing, parts are typically rinsed, then proceed through
a sealing operation that improves the corrosion resistance of the
coating. Common sealants include chromic acid, nickel acetate, nickel-
cobalt acetate, and hot water.
Chemical Conversion Coating
Chemical conversion coating includes chromating, phosphating, metal
coloring, and passivating operations. Chromate conversion coatings
are produced on various metals by chemical or electrochemical
treatment. Solutions, usually containing hexavalent chromium and
other compounds, react with the metal surface to form a layer
containing a complex mixture of compounds consisting of chromium,
other constituents, and base metal. Phosphate coatings may be formed
by the immersion of steel, iron, or zinc-plated steel in a dilute solution
of phosphate salts, phosphoric acid, and other reagents to condition
the surfaces for further processing. They are used to provide a good
base for paints and other organic coatings, to condition the surfaces for
cold forming operations by providing a base for drawing compounds
and lubricants, and to impart corrosion resistance to the metal surface.
Metal coloring involves chemically converting the metal surface into
an oxide or similar metallic compound to produce a decorative finish
such as a green or blue patina on copper or steel, respectively.
Passivating is the process of forming a protective film on metals by
immersion into an acid solution, usually nitric acid or nitric acid with
sodium dichromate. Stainless steel products are often passivated to
prevent corrosion and extend the life of the product.
Electroplating
Electroplating is the production of a surface coating of one metal upon
another by electrodeposition. Electroplating activities involve
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applying predominantly inorganic coatings onto surfaces to provide
corrosion resistance, hardness, wear resistance, anti-frictional
characteristics, electrical or thermal conductivity, or decoration.
Exhibit 13 illustrates the important parts of typical electroplating
equipment. The most commonly electroplated metals and alloys
include: brass (copper-zinc), cadmium, chromium, copper, gold,
nickel, silver, tin, and zinc.
In electroplating, metal ions in either acid, alkaline, or neutral
solutions are reduced on the workpieces being plated. The metal ions
in the solution are usually replenished by the dissolution of metal
from solid metal anodes fabricated of the same metal being plated, or
by direct replenishment of the solution with metal salts or oxides.
Cyanide, usually in the form of sodium or potassium cyanide, is
usually used as a complexing agent for cadmium and precious metals
electroplating, and to a lesser degree, for other solutions such as
copper and zinc baths.
Exhibit 13
Typical Electroplating Equipment
c
Generator or
Rectifier
Voltmeter
k s
Ammeter
Anodes
^yv^
+ rf tf o fr b "b
•^> '
r ^ijiijijm
— : : 'r::::1^: F™rr: : : '::/::J : :^™ : :
\\ //
Cathodes
Anode Bus Bar
Cathode Bus Bar
Source: McGraw Hill Encyclopedia of Science and Technology, Volume 6, 1987.
The sequence of steps in an electroplating includes: cleaning, often
using alkaline and acid solutions; stripping of old plating or paint;
electroplating; and rinsing between and after each of these operations.
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Sealing and conversion coating may be employed on the metals after
electroplating operations.
Electroless Plating
Electroless plating is the chemical deposition of a metal coating onto a
plastic object, by immersion of the object in a plating solution. Copper
and nickel electroless plating is commonly used for printed circuit
boards. The basic ingredients in an electroless plating solution are: a
source of metal (usually a salt); a reducer; a complexing agent to hold
the metal in solution; and various buffers and other chemicals
designed to maintain bath stability and increase bath life. Immersion
plating produces a thin metal deposit, commonly zinc or silver, by
chemical displacement. Immersion plating baths are usually
formulations of metal salts, alkalis, and complexing agents (e.g., lactic,
glycolic, malic acid salts). Electroless plating and immersion plating
commonly generate more waste than other plating techniques, but
individual facilities vary significantly in efficiency. Exhibit 13
illustrates a typical plating process.
Exhibit 14
Electroless Plating Process
Drag-out
Drag-out
Drag-out
Drag-out
Drag-out
Plate
Tanks
n
Recovery
Rinse
Neutralizer
1
Cold
Water
Spent
Solution
Hot
Water
Rinse
Water
Other
Processes
Discharge
Source: Pollution Prevention and Control Technology for Plating Operations, First Edition, National Center for
Manufacturing Sciences and National Association of Metal Finishers, 1994.
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Painting
Painting involves the application of predominantly organic coatings to
a workpiece for protective and/or decorative purposes. It is applied
in various forms, including dry powder, solvent-diluted formulations,
and water-borne formulations. Various methods of application are
used, the most common being spray painting and electrodeposition.
Spray painting is a process by which paint is placed into a pressurized
cup or pot and is atomized into a spray pattern when it is released
from the vessel and forced through an orifice. Electrodeposition is the
process of coating a workpiece by either making it anodic or cathodic
in a bath that is generally an aqueous emulsion of the coating material.
When applying the paint as a dry powder, some form of heating or
baking is necessary to ensure that the powder adheres to the metal.
These processes may result in solvent waste (and associated still
bottom wastes generated during solvent distillation), paint sludge
wastes, paint-bearing wastewaters, and paint solvent emissions.
Other Metal Finishing Techniques
Polishing, hot dip coating, and etching are processes that are also used
to finish metal. Polishing is an abrading operation used to remove or
smooth out surface defects (scratches, pits, or tool marks) that
adversely affect the appearance or function of a part. Following
polishing operations, area cleaning and washdown can produce metal-
bearing wastewaters. Hot dip coating is the coating of a metallic
workpiece with another metal to provide a protective film by
immersion into a molten bath. Galvanizing (hot dip zinc) is a common
form of hot dip coating. Water is used for rinses following
precleaning and sometimes for quenching after coating. Wastewaters
generated by these operations often contain metals. Etching produces
specific designs or surface appearances on parts by controlled
dissolution with chemical reagents or etchants. Etching solutions
commonly comprise strong acids or bases with spent etchants
containing high concentrations of spent metal. The solutions include
ferric chloride, nitric acid, ammonium persulfate, chromic acid, cupric
chloride, and hydrochloric acid.
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III.B. Raw Material Inputs and Pollution Outputs in the Production Line
The material inputs and pollution outputs resulting from metal
fabrication, surface preparation, and metal finishing processes are
presented by media in Exhibit 15. Exhibit 16 illustrates the general
processes associated with this industry, the pollutants generated, and
the point in the process at which the pollutants are produced.
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Fabricated Metal Products
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Exhibit 15
Process Materials Inputs and Outputs
Process
Material Input || Air Emission
Process
Wastewater
Solid Waste
Metal Shaping
Metal Cutting and/or
Forming
Cutting oils,
degreasing and
cleaning solvents,
acids, alkalis, and
heavy metals
Solvent wastes
(e.g., 1,1,1-
trichloroethane,
acetone, xylene,
toluene, etc. )
Waste oils (e.g.,
ethylene glycol)
and acid (e.g.,
hydrochloric,
sulfur ic, nitric),
alkaline, and
solvent wastes
Metal chips (e.g.,
scrap steel and
aluminum) ,
metal-bearing
cutting fluid
sludges, and
solvent still-
bottom wastes
Surface Preparation
Solvent Degreasing
and Emulsion,
Alkaline, and Acid
Cleaning
Solvents, emulsifying
agents, alkalis, and
acids
Solvents
(associated with
solvent
degreasing and
emulsion cleaning
only)
Solvent, alkaline,
and acid wastes
Ignitable wastes,
solvent wastes,
and still bottoms
Surface Finishing
Anodizing
Chemical Conversion
Coating
Electroplating
Plating
Painting
Other Metal Finishing
Techniques (Including
Polishing, Hot Dip
Coating, and Etching)
Acids
Metals and acids
Acid/alkaline
solutions, heavy
metal bearing
solutions, and
cyanide bearing
solutions
Metals (e.g., salts),
complexing agents,
and alkalis
Solvents and paints
Metals and acids
Metal-ion-bearing
mists and acid
mists
Metal-ion-bearing
mists and acid
mists
Metal-ion-bearing
mists and acid
mists
Metal-ion-bearing
mists
Solvents
Metal fumes and
acid fumes
Acid wastes
Metal salts, acid,
and base wastes
Acid/alkaline,
cyanide, and
metal wastes
Cyanide and
metal wastes
Solvent wastes
Metal and acid
wastes
Spent solutions,
wastewater
treatment
sludges, and base
metals
Spent solutions,
wastewater
treatment
sludges, and base
metals
Metal and
reactive wastes
Cyanide and
metal wastes
Still bottoms,
sludges, paint
solvents, and
metals
Polishing sludges,
hot dip tank
dross, and etching
sludges
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Exhibit 16
Fabricated Metal Products Manufacturing Processes
Metal
Fabrication
Metal
Preparation
(Cleaning)
Emulsify it]
Agents
Metal
Finishing
AcUls
Cyai
Acids
X
Metals^
X^
Alkalin
Metals
"•^. W
Anodizing — (^
* ^
Rinsing ,.
Solid W&stes )
*~- H j-*"^
Air Emissions^
**** "^^*^
**^ ,,i^^^
*'"""' ~v
Solid Wastes )
•«~_ —^^
Waste Water~~^
Solid Wastes )
* Acids
<*^
Other Metal
Finishing
Techniques
Rinsing (^
Waste Wa^
mng ^^
->lid Wastes^)
^ ^Waste Water^
d Bathing ^ ""
itions
Metals^ ,, ^
Chemical
Conversion
Coating
I .
Rinsing ^^^
Metals 1 ^^^A1
,, , . Plating
Complexmg &
Agents
Rinsing
Solvents 1 fair
Painting
Rinsing
Acids
X^eWa^>
^^"Solid Wastes"^)
kalis
C^ Sludges ^
f Waste Water )
its
X^r^/ssJoJ)
^^tolid Wastes"^)
C^steWa^)
SIC Code 34
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III.B.I.Metal Fabrication
Each of the metal shaping processes can result in wastes containing
chemicals of concern. For example, the application of solvents to
metal and machinery results in air emissions. Additionally,
wastewater containing acidic or alkaline wastes and waste oils, and
solid wastes, such as metals and solvents, are usually generated
during this process.
Metal fabrication facilities are major users of solvents for degreasing.
In cases where solvents are used solely in degreasing (not used in any
other plant operations), records of the amount and frequency of
purchases provide enough information to estimate emission rates,
based on the assumption that all solvent purchased is eventually
emitted. Section V.D., Pollution Prevention Options, illustrates
techniques that may be used to reduce the loss of solvents to the
atmosphere.
Metalworking fluids are applied to either the tool or the metal being
tooled to facilitate the shaping operation. Metalworking fluid is used
to:
• Control and reduce the temperature of tools and aid lubrication,
• Control and reduce the temperature of workpieces and aid
lubrication,
• Provide a good finish,
• Wash away chips and metal debris, and
• Inhibit corrosion or surface oxidation.
Fluids resulting from this process typically become spoiled or
contaminated with extended use and reuse. In general, metal working
fluids can be petroleum-based, oil-water emulsions, and synthetic
emulsions. When disposed, these fluids may contain high levels of
metals (e.g., iron, aluminum, and copper). Additional contaminants
present in fluids resulting from these processes include acids and
alkalis (e.g., hydrochloric, sulfuric, nitric), waste oils, and solvent
wastes.
Scrap metal may consist of metal removed from the original piece
(e.g., steel), and may be combined with small amounts of
September 1995 25 SIC Code 34
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metalworking fluids (e.g., solvents) used prior to and during the metal
shaping operation that generates the scrap. Quite often, this scrap is
reintroduced into the process as a feedstock. The scrap and
metalworking fluids, however, should be tracked since they may be
regulated as solid wastes.
III.B.2.Surface Preparation
Surface preparation activities usually result in air emissions,
contaminated wastewater, and solid wastes. The primary air
emissions from cleaning are due to the evaporation of chemicals from
solvent degreasing and emulsion cleaning processes. These emissions
may result through volatilization of solvents during storage, fugitive
losses during use, and direct ventilation of fumes.
Wastewaters generated from cleaning are primarily rinse waters,
which are usually combined with other metal finishing wastewaters
(e.g., electroplating) and treated on-site by conventional hydroxide
precipitation. Solid wastes (e.g., wastewater treatment sludges, still
bottoms, cleaning tank residues, machining fluid residues, etc.) may
also be generated by the cleaning operations. For example, solid
wastes are generated when cleaning solutions become ineffective and
are replaced. Solvent-bearing wastes are typically pre-treated to
comply with any applicable National Pollutant Discharge System
(NPDES) permits and then sent off-site, while aqueous wastes from
alkaline and acid cleaning , which do not contain solvents, are often
treated on-site.
III.B.3. Metal Finishing
Many metal finishing operations are typically performed in baths
(tanks) and are then followed by rinsing cycles. Exhibit 17 illustrates a
typical chemical or electrochemical process step in which a workpiece
enters the process bath containing process chemicals that are carried to
the rinse water (drag-out). Metal plating and related waste account
for the largest volumes of metal- (e.g., cadmium, chromium, copper,
lead, and nickel) and cyanide-bearing wastes. Painting operations
account for the generation of solvent-bearing wastes and the direct
release of solvents (including benzene, methyl ethyl ketone, methyl
isobutyl ketone, toluene, and xylene). Paint cleanup operations may
contribute to the release of chlorinated solvents (including carbon
tetrachloride, methylene chloride, 1,1,1-trichloroethane, and
perchloroethylene). Compliance with one law through emission or
effluent controls may generate waste regulated under another statute
SIC Code 34 26 September 1995
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Fabricated Metal Products
Sector Notebook Project
(e.g., effluent controls required by the Clean Water Act may generate
sludges which are regulated by the Resource Conservation and
Recovery Act). The nature of the wastes produced by these processes
is discussed further below.
Exhibit 17
Typical Metal Finishing Process Step
Vapors/Mist
Workpiece
Process
Chemicals
Workpiece
Workpiece To Next Step
Process
Bath
T
Rinse
System
Wastewater
Spent Bath
(Waste)
Fresh Water
Source: Guides to Pollution Prevention: The Metal Finishing Industry, U.S. EPA, ORD, October 1992.
Anodizing
Anodizing operations produce air emissions, contaminated
wastewaters, and solid wastes. Mists and gas bubbles arising from
heated fluids are a source of air emissions, which may contain metals
or other substances present in the bath. When dyeing of anodized
coatings occurs, wastewaters produced may contain nickel acetate,
non-nickel sealers, or substitutes from the dye. Other potential
pollutants include complexers and metals from dyes and sealers.
Wastewaters generated from anodizing are usually combined with
other metal finishing wastewaters and treated on-site by conventional
hydroxide precipitation. Wastewaters containing chromium must be
pretreated to reduce hexavalent chromium to its trivalent state. The
conventional treatment process generates a sludge that is usually sent
off-site for metals reclamation and/or disposal.
September 1995
27
SIC Code 34
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Fabricated Metal Products Sector Notebook Project
Solid wastes generated from anodizing include spent solutions and
wastewater treatment sludges. Anodizing solutions may be
contaminated with the base metal being processed due to the anodic
nature of the process. These solutions eventually reach an intolerable
concentration of dissolved metal and require processing to remove the
dissolved metal to a tolerable level or treatment/disposal.
Chemical Conversion Coating
Chemical conversion coating generally produces contaminated
wastewaters and solid waste. Pollutants associated with these
processes enter the wastestream through rinsing and batch dumping
of process baths. The process baths usually contain metal salts, acids,
bases, and dissolved basis materials. Wastewaters containing
chromium are usually pretreated to reduce hexavalent chromium to its
trivalent state. The conventional treatment process generates a sludge
that is sent off-site for metals reclamation and/or disposal. Solid
wastes generated from these processes include spent solutions and
wastewater treatment sludges. Conversion coating solutions may also
be contaminated with the base metal being processed. These solutions
will eventually reach an intolerable concentration of dissolved metal
and require processing to remove the dissolved metal to a tolerable
level.
Electroplating
Electroplating operations produce air emissions, contaminated
wastewaters and solid wastes. Mists arising from electroplating fluids
and process gases can be a source of air emissions, which may contain
metals or other substances present in the bath. The industry has
recently begun adding fume suppressants to electroplating baths to
reduce air emissions of chromium, one of the most frequently
electroplated metals. The fume suppressants lower the surface tension
of the bath, which prevents hydrogen bubbles in the bath from
bursting and producing a chromium-laden mist. The fume
suppressants are highly effective when used in decorative plating, but
less effective when used in hard-chromium plating. Contaminated
wastewaters result from workpiece rinsing and process cleanup
waters. Rinse waters from electroplating are usually combined with
other metal finishing wastewaters and treated on-site by conventional
hydroxide precipitation. Wastewaters containing chromium must be
pretreated to reduce hexavalent chromium to its trivalent state. These
wastewater treatment techniques can result in solid-phase wastewater
treatment sludges. Other wastes generated from electroplating
SIC Code 34 28 September 1995
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Fabricated Metal Products Sector Notebook Project
include spent solutions which become contaminated during use, and
therefore, diminish performance of the process. In addition to these
wastes, spent process solutions and quench bathes may be discarded
periodically when the concentrations of contaminants inhibit proper
function of the solution or bath.
Electroless Plating
Electroless plating produces contaminated wastewater and solid
wastes. The spent plating solution and rinse water are usually treated
chemically to precipitate out the toxic metals and to destroy the
cyanide. Electroless plating solutions can be difficult to treat; settling
and simple chemical precipitation are not effective at removing the
chelated metals used in the plating bath. The extent to which plating
solution carry-over adds to the wastewater and enters the sludge
depends on the type of article being plated and the specific plating
method employed. However, most sludges may contain significant
concentrations of toxic metals, and may also contain complex cyanides
in high concentrations if cyanides are not properly isolated during the
treatment process.
Painting
Painting operations result in emissions, contaminated wastewaters,
and the generation of liquid and solid wastes. Atmospheric emissions
consist primarily of the organic solvents used as carriers for the paint.
Emissions also result from paint storage, mixing, application, and
drying. In addition, cleanup processes can result in the release of
organic solvents used to clean equipment and painting areas.
Wastewaters are often generated from painting processes due
primarily to the discharge of water from water curtain booths. On-site
treatment processes to treat contaminated wastewater generate a
sludge that is sent off-site for disposal. Sources of solid- and liquid-
phase wastes include:
• Paint application emissions control devices (e.g., paint booth
collection systems, ventilation filters, etc.)
• Equipment washing
• Disposal materials used to contain paint and overspray
• Excess paints discarded upon completion of a painting
operation or after expiration of the paint shelf-life.
September 1995 29 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
These solid and liquid wastes may contain metals from paint pigments
and organic solvents, such as paint solvents and cleaning solvents.
Still bottoms also contain solvent wastes. The cleaning solvents used
on painting equipment and spray booths may also contribute organic
solid waste to the wastes removed from the painting areas.
Other Metal Finishing Techniques
Wastewaters are often generated during other metal finishing
processes. For example, following polishing operations, area cleaning
and washdown can produce metal-bearing wastewaters. Hot dip
coating techniques, such as galvanizing, use water for rinses following
pre-cleaning and sometimes for quenching after coating. Hot dip
coatings also generate solid waste, anoxide dross, that is periodically
skimmed off the heated tank. These operations generate metal-
bearing wastewaters. Etching solutions are comprised of strong acids
(e.g., ferric chloride, nitric acid, ammonium persulfate) or bases.
Resulting spent etchant solutions may contain metals and acids.
III.C. Management of Chemicals in Wastestream
The Pollution Prevention Act of 1990 (EPA) requires facilities to report
information about the management of TRI chemicals in waste and
efforts made to eliminate or reduce those quantities. These data have
been collected annually in Section 8 of the TRI reporting Form R
beginning with the 1991 reporting year. The data summarized below
cover the years 1992-1995 and is meant to provide a basic
understanding of the quantities of waste handled by the industry, the
methods typically used to manage this waste, and recent trends in
these methods. TRI waste management data can be used to assess
trends in source reduction within individual industries and facilities,
and for specific TRI chemicals. This information could then be used as
a tool in identifying opportunities for pollution prevention compliance
assistance activities.
While the quantities reported for 1992 and 1993 are estimates of
quantities already managed, the quantities reported for 1994 and 1995
are projections only. The EPA requires these projections to encourage
facilities to consider future waste generation and source reduction of
those quantities as well as movement up the waste management
hierarchy. Future-year estimates are not commitments that facilities
reporting under TRI are required to meet.
SIC Code 34 30 September 1995
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Fabricated Metal Products
Sector Notebook Project
Exhibit 18 shows that the fabricated metals industry managed about
798 million pounds of production-related waste (total quantity of TRI
chemicals in the waste from routine production operations) in 1993
(column B). Column C reveals that of this production-related waste,
34 percent was either transferred off-site or released to the
environment. Column C is calculated by dividing the total TRI
transfers and releases by the total quantity of production-related
waste. In other words, about 62 percent of the industry's TRI wastes
were managed on-site through recycling, energy recovery, or
treatment as shown in columns D, E and F, respectively. The majority
of waste that is released or transferred off-site can be divided into
portions that are recycled off-site, recovered for energy off-site, or
treated off-site as shown in columns G, H, and I, respectively. The
remaining portion of the production-related wastes (13.2 percent),
shown in column J, is either released to the environment through
direct discharges to air, land, water, and underground injection, or it
is disposed off-site.
From the yearly data presented below it is apparent that the portion of
TRI wastes reported as recycled on-site is projected to decrease and
the portions treated or managed through energy recovery on-site have
increased between 1992 and 1995 (projected).
Exhibit 18
Source Reduction and Recycling Activity for SIC 34
A
Year
1992
1993
1994
1995
B
Production
Related
Waste
Volume
(106lbs.)*
750
798
735
697
C
% Reported
as Released
and
Transferred
38%
34%
—
—
D
E
F
On- Site
%
Recycled
23.22%
26.48%
27.91%
19.20%
% Energy
Recovery
12.24%
11.04%
8.90%
13.86%
%
Treated
23.11%
24.24%
26.33%
27.78%
G
H
I
Off-Site
%
Recycled
26.03%
21.31%
22.18%
23.94%
% Energy
Recovery
1.57%
1.54%
1.53%
1.63%
%
Treated
2.02%
2.10%
2.32%
2.46%
J
Remaining
Releases
and
Disposal
12.05%
13.28%
10.84%
11.13%
September 1995
31
SIC Code 34
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Fabricated Metal Products Sector Notebook Project
IV. CHEMICAL RELEASE AND TRANSFER PROFILE
This section is designed to provide background information on the
pollutant releases that are reported by this industry. The best source
of comparative pollutant release information is the Toxic Release
Inventory System (TRI). Pursuant to the Emergency Planning and
Community Right-to-Know Act, TRI includes self-reported facility
release and transfer data for over 600 toxic chemicals. Facilities within
SIC Codes 20-39 (manufacturing industries) that have more than 10
employees, and that are above weight-based reporting thresholds are
required to report TRI on-site releases and off-site transfers. The
information presented within the sector notebooks is derived from the
most recently available (1993) TRI reporting year (which then included
316 chemicals), and focuses primarily on the on-site releases reported
by each sector. Because TRI requires consistent reporting regardless of
sector, it is an excellent tool for drawing comparisons across
industries.
Although this sector notebook does not present historical information
regarding TRI chemical releases over time, please note that in general,
toxic chemical releases have been declining. In fact, according to the
1993 Toxic Release Inventory Data Book, reported releases dropped by
42.7 percent between 1988 and 1993. Although on-site releases have
decreased, the total amount of reported toxic waste has not declined
because the amount of toxic chemicals transferred off-site has
increased. Transfers have increased from 3.7 billion pounds in 1991 to
4.7 billion pounds in 1993. Better management practices have led to
increases in off-site transfers of toxic chemicals for recycling. More
detailed information can be obtained from EPA's annual Toxics
Release Inventory Public Data Release book (which is available
through the EPCRA Hotline at 1-800-535-0202), or directly from the
Toxic Release Inventory System database (for user support call 202-
260-1531).
Wherever possible, the sector notebooks present TRI data as the
primary indicator of chemical release within each industrial category.
TRI data provide the type, amount, and media receptor of each
chemical released or transferred. When other sources of pollutant
release data have been obtained, these data have been included to
augment the TRI information.
TRI Data Limitations
SIC Code 34 32 September 1995
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Fabricated Metal Products Sector Notebook Project
The reader should keep in mind the following limitations regarding
TRI data. Within some sectors, the majority of facilities are not subject
to TRI reporting because they are not considered manufacturing
industries, or because they are below TRI reporting thresholds.
Examples are the mining, dry cleaning, printing, and transportation
equipment cleaning sectors. For these sectors, release information
from other sources has been included.
The reader should also be aware that TRI "pounds released" data
presented within the notebooks is not equivalent to a "risk" ranking for
each industry. Weighting each pound of release equally does not
factor in the relative toxicity of each chemical that is released. The
Agency is in the process of developing an approach to assign
toxicological weightings to each chemical released so that one can
differentiate between pollutants with significant differences in toxicity.
As a preliminary indicator of the environmental impact of the
industry's most commonly released chemicals, the notebook briefly
summarizes the toxicological properties of the top five chemicals (by
weight) reported by each industry.
Definitions Associated With Section IV Data Tables
General Definitions
SIC Code -- the Standard Industrial Classification (SIC) is a statistical
classification standard used for all establishment-based Federal
economic statistics. The SIC codes facilitate comparisons between
facility and industry data.
TRI Facilities -- are manufacturing facilities that have 10 or more full-
time employees and are above established chemical throughput
thresholds. Manufacturing facilities are defined as facilities in
Standard Industrial Classification primary codes 20-39. Facilities must
submit estimates for all chemicals that are on the EPA's defined list
and are above throughput thresholds.
Data Table Column Heading Definitions
The following definitions are based upon standard definitions
developed by EPA's Toxic Release Inventory Program. The categories
below represent the possible pollutant destinations that can be
reported.
September 1995 33 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
RELEASES -- are an on-site discharge of a toxic chemical to the
environment. This includes emissions to the air, discharges to bodies
of water, releases at the facility to land, as well as contained disposal
into underground injection wells.
Releases to Air (Point and Fugitive Air Emissions) -- Include all air
emissions from industry activity. Point emissions occur through
confined air streams as found in stacks, ducts, or pipes. Fugitive
emissions include losses from equipment leaks, or evaporative losses
from impoundments, spills, or leaks.
Releases to Water (Surface Water Discharges) - encompass any
releases going directly to streams, rivers, lakes, oceans, or other bodies
of water. Any estimates for stormwater runoff and non-point losses
must also be included.
Releases to Land -- includes disposal of waste to on-site landfills,
waste that is land treated or incorporated into soil, surface
impoundments, spills, leaks, or waste piles. These activities must
occur within the facility's boundaries for inclusion in this category.
Underground Injection — is a contained release of a fluid into a
subsurface well for the purpose of waste disposal.
TRANSFERS — is a transfer of toxic chemicals in wastes to a facility
that is geographically or physically separate from the facility reporting
under TRI. The quantities reported represent a movement of the
chemical away from the reporting facility. Except for off-site transfers
for disposal, these quantities do not necessarily represent entry of the
chemical into the environment.
Transfers to POTWs — are wastewaters transferred through pipes or
sewers to a publicly owned treatments works (POTW). Treatment and
chemical removal depend on the chemical's nature and treatment
methods used. Chemicals not treated or destroyed by the POTW are
generally released to surface waters or landfilled within the sludge.
Transfers to Recycling — are sent off-site for the purposes of
regenerating or recovering still valuable materials. Once these
chemicals have been recycled, they may be returned to the originating
facility or sold commercially.
SIC Code 34 34 September 1995
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Fabricated Metal Products Sector Notebook Project
Transfers to Energy Recovery -- are wastes combusted off-site in
industrial furnaces for energy recovery. Treatment of a chemical by
incineration is not considered to be energy recovery.
Transfers to Treatment -- are wastes moved off-site for either
neutralization, incineration, biological destruction, or physical
separation. In some cases, the chemicals are not destroyed but
prepared for further waste management.
Transfers to Disposal — are wastes taken to another facility for
disposal generally as a release to land or as an injection underground.
IV.A. EPA Toxic Release Inventory for the Fabricated Metal Products
Industry
TRI release amounts listed below are not associated with non-
compliance with environmental laws. These facilities appear based on
self-reported data submitted to the Toxic Release Inventory program.
The TRI database contains a detailed compilation of self-reported,
facility-specific chemical releases. The top reporting facilities for this
sector are listed below. Facilities that have reported only the SIC
codes covered under this notebook appear in Exhibit 19. Exhibit 20
contains additional facilities that have reported the SIC code covered
within this report, and one or more SIC codes that are not within the
scope of this notebook. Therefore, Exhibit 20 includes facilities that
conduct multiple operations — some that are under the scope of this
notebook, and some that are not. Currently, the facility-level data do
not allow pollutant releases to be broken apart by industrial process.
Exhibits 21-24 illustrate the TRI releases and transfers for the
Fabricated Metal Products industry (SIC 34). For the industry as a
whole, solvents comprise the largest number of TRI releases. This
reflects the fact that solvents are used during numerous metal shaping,
surface preparation, and surface finishing operations. For example,
during metal shaping and surface preparation operations, solvents are
used primarily to degrease metal. Solvents are also used during
painting operations. All of the processes which use solvents generally
result in air emissions, contaminated wastewater, and solid wastes.
Between 1988 and 1993, the Fabricated Metals Products industry
substantially reduced its TRI transfers and releases (see section V.
Pollution Prevention Opportunities). Exhibits 21 and 22 show the
September 1995 35 SIC Code 34
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Fabricated Metal Products
Sector Notebook Project
differences in transfers and releases over time, categorized by type of
transfer or release.
Exhibit 19 lists the ten facilities with the highest total TRI releases,
most of which are continuous coil manufacturers (e.g., facilities that
manufacture aluminum cans from long strips of metal). The wastes
generated by these manufacturers are not necessarily representative of
the wastes generated by the metal fabricating and finishing industries
as a whole.
Exhibit 19
Top 10 TRI Releasing Fabricated Metal Products Facilities
SIC Codes
3411
3411
3710,3714,
3465
3471
3731,3441,
3443
3411
3411
3479
3714,3471
3341, 3479,
3355
Total TRI
Releases in
Pounds
946,923
880,500
822,902
708,285
688,540
636,126
624,250
619,436
618,359
570,622
Facility Name
U.S. Can Co., Plant 20
Weirton
Metal Container Corp., NWB
CMC NAO Flint OPS., BOC
Flint Automotive Div.
Plastene Supply Co.
Ingalls Shipbuilding, Inc.
American National Can Co.,
Winston Salem Plant
Metal Container Corp. FTA
Ken-Koat, Inc.
Keeler Brass Automotive,
Kentwood Plant
Commonwealth Aluminum
Corp.
City
Weirton
New Windsor
Flint
Portageville
Pascagoula
Winston-Salem
Fort Atkinson
Huntington
Grand Rapids
Lewisport
State
WV
NY
MI
MO
MS
NC
WI
IN
MI
KY
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
Note: Being included on this list does not mean that the release is associated with non-compliance with
environmental laws.
SIC Code 34
36
September 1995
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Fabricated Metal Products
Sector Notebook Project
Exhibit 20
Top 10 TRI Releasing Metal Fabricating & Finishing Facilities (SIC 34)
Rank
1
2
3
4
5
6
7
8
9
10
Total TRI
Releases in
Pounds
946,923
880,500
708,285
636,126
624,250
619,436
545,505
541,654
524,346
492,872
Facility Name
U.S. Can Co., Plant 20, Weirton
Metal Container Corp., NWB
Plastene Supply Co.
American National Can Co.,
Winston Salem Plant
Metal Container Corp.
Ken-Koat, Inc.
Metal Container Corp.
Reynolds Metals Co.
Hickory Springs Mfg. Co.
Tennessee Electroplating, Inc.
City
Weirton
New Windsor
Portageville
Winston- Salem
Fort Atkinson
Huntington
Columbus
Houston
Fort Smith
Ripley
State
WV
NY
MO
NC
WI
IN
OH
TX
AR
TN
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
Note: Being included on this list does not mean that the release is associated with non-compliance with
environmental laws.
Exhibit 21
Reductions in TRI Releases, 1988-1993 (SIC 34)
Releases
Total Air Emissions
Surface Water Discharges
Underground Injection
Releases to Land
1988
131,296,827
1,516,905
386,120
4,202,919
1993
90,380,667
101,928
1,490
660,072
Percent
Reduction
31.2
93.3
99.6
84.4
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
Exhibit 22
Reductions in TRI Transfers, 1988-1993 (SIC 34)
Transfers
Recycling
Energy
Treatment
POTWs
Disposal
Other Off-Site Transfers
1988
213,214,641
12,331,653
34,313,199
17,149,495
43,529,628
8,303,148
1993
244,278,696
13,812,271
18,561,504
3,809,715
19,736,496
369,491
Percent Reduction
-14.6
-12.0
45.9
77.8
54.7
95.5
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
September 1995
37
SIC Code 34
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Fabricated Metal Products
Sector Notebook Project
Exhibit 23
TRI Reporting Metal Fabricating & Finishing Facilities (SIC 34) by State
State
AL
AR
AS
AZ
CA
CO
CT
DE
FL
GA
HI
IA
ID
IL
IN
KS
KY
LA
MA
MD
ME
MI
MN
MO
Number of
Facilities
54
25
1
17
208
19
83
2
36
42
2
30
1
230
111
16
41
12
76
17
5
159
59
54
State
MS
NC
NE
NH
NJ
NV
NY
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VA
WA
WI
WV
WY
Number of
Facilities
29
35
9
5
60
3
101
225
29
20
123
10
30
37
3
47
107
15
30
24
103
16
2
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
SIC Code 34
38
September 1995
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Fabricated Metal Products
Sector Notebook Project
Exhibit 24
Releases for Metal Fabricating & Finishing Facilities (SIC 34) in TRI, by Number
of Facilities (Releases reported in pounds/year)
Chemical Name
Sulfuric Acid
Hydrochloric Acid
Nitric Acid
Xylene (Mixed
Isomers)
Nickel
Chromium
Manganese
Glycol Ethers
Copper
Methyl Ethyl Ketone
Zinc Compounds
N-Butyl Alcohol
Toluene
1 -Trichloroethane
Trichloroethylene
Chromium Compounds
Phosphoric Acid
Nickel Compounds
Methyl Isobutyl Ketone
Cyanide Compounds
Copper Compounds
Lead
Ammonia
Ethylbenzene
Hydrogen Fluoride
Zinc (Fume Or Dust)
Acetone
Manganese
Compounds
Dichloromethane
4-Trimethylbenzene
Tetrachloroethylene
Methanol
Chlorine
Methylenebis(Phenylis
ocyanate)
Naphthalene
Cobalt
Barium Compounds
Freon 113
Lead Compounds
Styrene
Cadmium
Formaldehyde
Aluminum (Fume Or
Dust)
Trichlorofluoro-
methane
Cadmium Compounds
Ethylene Glycol
Propylene
Cumene
2-Ethoxyethanol
Cyclohexane
Isopropyl Alcohol
(Manufacturing
Antimony Compounds
Cobalt Compounds
M-Xylene
Antimony
# Facilities
Reporting
Chemical
861
652
390
336
311
287
271
269
267
254
228
215
205
189
185
176
175
158
114
103
93
83
79
74
74
70
61
58
57
53
49
48
40
35
33
28
25
19
19
17
16
16
13
13
11
11
11
9
8
7
6
5
5
5
4
Fugitive
Air
186135
264628
81650
2982600
23285
25150
29884
4990228
19231
2134002
87045
3209678
1366663
2046210
2410195
7039
49587
7538
501363
7686
4912
5758
87916
234540
12924
100770
407417
2197
991302
255913
809152
64182
9181
2562
57791
1534
3606
282200
967
154377
62
15561
7042
45312
276
37417
25423
10383
14361
611237
22111
4505
2
898
0
Point Air
149329
265452
216384
5985667
8126
6072
9536
13281181
20632
4511723
55641
7372875
3325311
2727842
2903856
13687
32213
9311
1156914
8960
6028
4400
412960
308927
27671
41693
1090972
795
1159594
319541
434749
182883
1021
1179
70271
1608
803
102624
1840
25726
6
9618
506
122318
266
160907
771
24238
19390
55929
29351
661
113
12297
423
Water
Discharges
41032
505
1510
25
3558
2162
834
5
2795
555
13561
0
7
10
51
1035
0
876
5
298
1398
809
250
5
0
290
0
0
5
5
22
0
15
0
0
755
250
0
38
0
5
209
0
0
0
0
0
5
0
0
0
260
37
0
0
Under-
ground
Injection
547
250
76
0
0
0
250
0
0
0
0
0
0
0
0
0
319
48
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
54700
255
0
553
6121
30345
30994
5
763
71335
95457
5
300
133
6600
15574
0
1530
5
283
256
254
0
0
0
10146
0
12785
6829
0
0
0
0
0
0
500
3114
0
0
0
250
0
0
250
0
0
0
0
0
0
0
0
9
0
0
Total
Releases
431743
531090
299620
8968845
41090
63729
71498
18271419
43421
6717615
251704
10582558
4692281
4774195
5320702
37335
82119
19303
1658287
17227
12594
11221
501126
543472
40595
152899
1498389
15777
2157730
575459
1243923
247065
10217
3741
128062
4397
7773
384824
2845
180103
323
25388
7548
167880
542
198324
26194
34626
33751
667166
51462
5426
161
13195
423
Average
Releases
per Facility
501
815
768
26693
132
222
264
67923
163
26447
1104
49221
22889
25260
28761
212
469
122
14546
167
135
135
6343
7344
549
2184
24564
272
37855
10858
25386
5147
255
107
3881
157
311
20254
150
10594
20
1587
581
12914
49
18029
2381
3847
4219
95309
8577
1085
32
2639
106
September 1995
39
SIC Code 34
-------
Fabricated Metal Products Sector Notebook Project
SIC Code 34 40 September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 24 (cont'd)
Releases for Metal Fabricating & Finishing Facilities (SIC 34) in TRI, by Number
of Facilities (Releases reported in pounds/year)
Chemical Name
Bis(2-Ethylhexyl)
Adipate
Dimethyl Phthalate
Phenol
Sec-Butyl Alcohol
Aluminum Oxide
(Fibrous Form)
Di(2-Ethylhexyl)
Phthalate
Dichlorodifluoro-
methane
Silver
Asbestos (Friable)
Barium
Butyl Benzyl Phthalate
Diethyl Phthalate
Molybdenum Trioxide
O-Xylene
Phosphorus (Yellow Or
White)
Toluenediisocyanate
(Mixed Isomers)
2-Methoxyethanol
Ammonium Nitrate
(Solution)
Ammonium Sulfate
(Solution)
Arsenic
Benzene
Diethanolamine
Ethyl Acrylate
Mercury
P-Xylene
Polychlorinated
Biphenyls
Propane Sultone
Selenium
Silver Compounds
2-Dichlorobenzene
2-Nitropropane
4'-
Isopropylidenediphenol
Totals
# Facilities
Reporting
Chemical
4
4
4
4
3
3
3
3
2
2
2
2
2
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
—
Fugitive
Air
8850
2407
12922
6350
250
250
7406
5
10
5
0
255
250
0
10
5
255
0
0
5
3122
0
0
5
0
0
250
5
250
12000
186
0
24,768,891
Point Air
14000
6387
0
19600
250
3000
16443
0
0
0
0
250
0
37928
5
148
24825
0
0
0
836
0
2578
0
22
0
0
0
250
0
182
250
46,819,995
Water
Discharges
0
0
3
0
0
0
0
5
0
0
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
73,195
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,490
Land
Disposal
0
0
0
0
0
5
0
0
0
0
0
0
2000
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
351,356
Total
Releases
22850
8794
12925
25950
500
3255
23849
10
10
5
0
505
2250
37928
20
153
25080
0
0
5
3958
0
2578
5
22
0
250
5
500
12000
368
250
72,014,927
Average
Releases
per Facility
5713
2199
3231
6488
167
1085
7950
3
5
3
0
253
1125
18964
10
77
12540
0
0
5
3958
0
2578
5
22
0
250
5
500
12000
368
250
—
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
September 1995
41
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 25
Transfers for Metal Fabricating & Finishing Facilities (SIC 34) in TRI, by
Number of Facilities (Transfers reported in pounds/year)
Chemical Name
Sulfuric Acid
Hydrochloric Acid
Nitric Acid
Xylene (Mixed
Isomers)
Nickel
Chromium
Manganese
Glycol Ethers
Copper
Methyl Ethyl Ketone
Zinc Compounds
N-Butyl Alcohol
Toluene
1 -Trichloroethane
Trichloroethylene
Chromium
Compounds
Phosphoric Acid
Nickel Compounds
Methyl Isobutyl
Ketone
Cyanide Compounds
Copper Compounds
Lead
Ammonia
Ethylbenzene
Hydrogen Fluoride
Zinc (Fume Or Dust)
Acetone
Manganese
Compounds
Dichloromethane
4-Trimethylbenzene
Tetrachloroethylene
Methanol
Chlorine
Methylenebis(Pheny
lisocyanate)
Naphthalene
Cobalt
Barium Compounds
Freon 113
Lead Compounds
Styrene
Cadmium
Formaldehyde
Aluminum (Fume Or
Dust)
Trichlorofluoro-
methane
Cadmium
Compounds
Ethylene Glycol
Propylene
Cumene
2-Ethoxyethanol
Cyclohexane
# Facilities
Reporting
Chemical
861
652
390
336
311
287
271
269
267
254
228
215
205
189
185
176
175
158
114
103
93
83
79
74
74
70
61
58
57
53
49
48
40
35
33
28
25
19
19
17
16
16
13
13
11
11
11
9
8
7
POTW
Discharges
1132535
446440
37256
51
17355
30170
5093
385087
8784
141
31969
13302
93
65
1083
18099
268375
21635
5
19581
13826
1160
31527
5
382
75982
5
302
647
5
65
29686
4470
0
0
319
12
0
797
0
1829
41510
500
0
1288
22685
0
5
5
0
Disposal
2871580
2768870
309134
10852
367278
465237
834964
55411
653024
32971
4797726
9306
31782
34508
34070
721452
300139
463522
1407
17461
341003
78382
1030
2
2581
219289
19917
221084
5
5
6344
0
750
25420
70
10978
56251
0
198398
12000
8006
5
250
7374
65324
86000
0
0
0
750
Recycling
4011148
1472808
946756
1661765
8848547
10143210
8774505
824664
53401212
2787367
23980836
100928
603704
1342465
1045702
1222505
5805346
1839379
813193
12188
11781033
2392024
750
170492
0
666508
705690
1243001
289636
23532
555166
35726
250
250
34926
405387
2079
93230
798893
1180
9432
0
157757
0
27000
17100
0
2020
516
0
Treatment
4636541
3169967
623265
332850
464008
422090
8299
142591
60924
268783
2004640
43711
277628
128708
371432
500300
280512
549790
30029
140767
205196
10184
260
14164
16618
120336
173168
1299
73238
10506
129891
34952
6226
7014
14821
753
20823
21794
1590
750
31506
1611
5460
4263
42512
19170
0
441
0
1250
Energy
Recovery
0
0
0
2139660
0
10
0
2295807
667
4002200
3249
306263
1892116
101194
102092
2981
0
6
471629
0
7
281
0
227471
0
61242
134723
0
26737
58127
6692
80494
0
500
39431
0
0
1917
501
250
0
7202
0
0
0
3110
0
5618
2600
255
Total
Transfers
12651804
7935080
1916411
4151607
9727271
11121986
9623861
3746528
54124861
7107644
30847198
497761
2805323
1606940
1554379
2490098
6669606
2879204
1316263
190497
12341065
2482031
33567
412134
19581
1143857
1033503
1465686
390263
92175
698158
180858
11696
33184
89248
440451
79165
116941
1000179
14180
50773
50328
163967
11637
136124
148065
0
8084
3121
2255
Average
Transfers
per Facility
14694
12170
4914
12356
31277
38753
35512
13928
202715
27983
135295
2315
13685
8502
8402
14148
38112
18223
11546
1849
132700
29904
425
5569
265
16341
16943
25270
6847
1739
14248
3768
292
948
2704
15730
3167
6155
52641
834
3173
3146
12613
895
12375
13460
0
898
390
322
SIC Code 34
42
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 25 (cont'd)
Transfers for Metal Fabricating & Finishing Facilities (SIC 34) in TRI, by
Number of Facilities (Transfers reported in pounds/year)
Chemical Name
Isopropyl Alcohol
(Manufacturing
Antimony
Compounds
Cobalt Compounds
M-Xylene
Antimony
Bis(2-Ethylhexyl)
Adipate
Dimethyl Phthalate
Phenol
Sec-Butyl Alcohol
Aluminum Oxide
(Fibrous Form)
Di(2-Ethylhexyl)
Phthalate
Dichlorodifluoromet
hane
Silver
Asbestos (Friable)
Barium
Butyl Benzyl
Phthalate
Diethyl Phthalate
Molybdenum
Trioxide
O-Xylene
Phosphorus (Yellow
Or White)
Toluenediisocyanate
(Mixed Isomers)
2-Methoxyethanol
Ammonium Nitrate
(Solution)
Ammonium Sulfate
(Solution)
Arsenic
Benzene
Diethanolamine
Ethyl Acrylate
Mercury
P-Xylene
Polychlorinated
Biphenyls
Propane Sultone
Selenium
Silver Compounds
2-Dichlorobenzene
2-Nitropropane
4'-Isopropylidene-
diphenol
Totals
# Facilities
Reporting
Chemical
6
5
5
5
4
4
4
4
4
3
3
3
3
2
2
2
2
2
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
—
POTW
Discharges
0
10
15
0
0
6400
0
250
0
0
5
0
10
0
5
0
500
0
0
0
0
5
0
128241
5
0
0
0
5
0
0
0
5
250
0
0
0
2,800,087
Disposal
613
104158
18403
0
0
3145
0
1176
0
0
8440
0
15
73822
10
0
0
419
0
0
0
0
0
0
10
0
0
0
10
0
0
0
10
0
0
0
250
16,352,393
Recycling
97513
0
41566
0
3187
0
0
0
0
25000
0
0
250
0
0
0
2052
3900
0
12250
0
0
0
0
0
0
440
0
0
0
0
0
0
4000
0
0
0
149,241,964
Treatment
15
1104
5
109
375
0
269
0
840
0
0
0
0
0
0
0
2061
0
61
0
0
0
0
0
0
0
0
0
0
51
2286
0
0
0
0
95
0
15,433,902
Energy
Recovery
5688
0
1
3819
0
0
1802
0
250
0
0
0
0
0
0
0
0
0
0
0
1374
8520
0
0
0
0
0
0
0
0
0
0
0
0
0
103
0
12,002,720
Total
Transfers
103829
105272
59990
3928
3562
9545
2071
1426
1090
25000
8445
0
275
73822
15
0
4613
4319
61
12250
1374
8525
0
128241
15
0
440
0
15
51
2286
0
15
4250
0
198
250
196,188,152
Average
Transfers
per Facility
17305
21054
11998
786
891
2386
518
357
273
8333
2815
0
92
36911
8
0
2307
2160
31
6125
687
4263
0
128241
15
0
440
0
15
51
2286
0
15
4250
0
198
250
—
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
September 1995
43
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibits 26 - 29 illustrate the TRI releases and transfers for the coating,
engraving, and allied services portion (SIC 347) of the fabricated metal
products industry. For these activities, solvents, as well as acids,
constitute the largest number of TRI releases. Solvents are primarily
used during painting operations, while acids are used during most
finishing operations (e.g., anodizing, chemical conversion coating,
electroplating). The solvents usually produce air emissions,
contaminated wastewater, and solid-phase wastes, while the acids
generally result in contaminated wastewater. Because NPDES permits
do not allow low PH levels, the wastewater is pretreated to reduce the
acidity prior to being discharged from the facility.
Exhibit 26
Top 10 TRI Releasing Metal Finishing Facilities (SIC 347)
Rank
1
2
3
4
5
6
7
8
9
10
Total TRI
Releases in
Pounds
"708,285
"619,436
"492,872
"430,781
"418,912
"408,628
"406,419
"381,788
"368,014
"344,572
Facility Name
Plastene Supply Co.
Ken-Koat, Inc.
Tennessee Electroplating, Inc.
SR of Tennessee
Ken-Koat of Tennessee, Inc., Plant
1
Anomatic Corp.
Roll Coater, Inc.
Reynolds Metals Co., Sheffield
Plant
Roll Coater, Inc.
Mottley Foils, Inc.
City
Portageville
Huntington
Ripley
Ripley
Lewisburg
Newark
Greenfield
Sheffield
Kingsbury
Farmville
State
MO
IN
TN
TN
TN
OH
IN
AL
IN
VA
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
Note: Being included on this list does not mean that the release is associated with non-compliance with
environmental laws.
SIC Code 34
44
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 27
TRI Reporting Metal Finishing Facilities (SIC 347) by State
State
AL
AR
AZ
CA
CO
CT
DE
FL
GA
HI
IA
IL
IN
KS
KY
LA
MA
MD
ME
MI
MN
Number of
Facilities
19
4
9
117
11
36
1
14
14
1
6
121
49
7
13
5
39
7
1
109
36
State
MO
MS
NC
NE
NH
NJ
NY
OH
OK
OR
PA
PR
RI
SC
TN
TX
UT
VA
WA
WI
WV
Number of
Facilities
23
6
11
1
1
27
43
112
9
11
41
4
23
9
17
48
4
7
14
35
4
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
Exhibit 28
Releases for Metal Finishing (SIC 347) in TRI, by Number of Facilities
(Releases reported in pounds/year)
Chemical Name
Sulfuric Acid
Hydrochloric Acid
Nitric Acid
Zinc Compounds
Phosphoric Acid
Methyl Ethyl Ketone
Chromium Compounds
Nickel Compounds
Cyanide Compounds
Nickel
Trichloroethylene
Xylene (Mixed Isomers)
1,1,1 -Trichloroethane
Toluene
Glycol Ethers
Copper
Chromium
N-Butyl Alcohol
Copper Compounds
Ammonia
Chlorine
Lead
# Facilities
Reporting
Chemical
577
490
290
158
120
103
101
95
87
87
81
79
73
69
59
54
48
44
43
35
32
31
Fugitive
Air
159575
229596
51229
75329
24772
945484
4572
5821
6759
4685
844061
395089
763993
375222
344040
880
2517
114102
2874
75738
5828
89
Point Air
103935
186461
140639
23316
26993
2251059
10765
4572
4098
3257
847701
1226943
817417
1566048
1463579
3508
2372
188305
1955
11644
1011
1715
Water
Discharges
38232
505
1510
12202
0
555
625
564
224
1433
20
5
5
5
0
1646
131
0
207
0
5
536
Under-
ground
Injection
0
250
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
54450
255
0
93054
0
71335
15
0
283
500
0
0
0
300
0
0
255
0
0
0
0
0
Total
Releases
356192
417067
193378
203901
51765
3268433
15977
10957
11364
9875
1691782
1622037
1581415
1941575
1807619
6034
5275
302407
5036
87382
6844
2340
Average
Releases
per Facility
617
851
667
1291
431
31732
158
115
131
114
20886
20532
21663
28139
30638
112
110
6873
117
2497
214
75
September 1995
45
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 28 (cont'd)
Releases for Metal Finishing (SIC 347) in TRI, by Number of Facilities
(Releases reported in pounds/year)
Chemical Name
Methyl Isobutyl Ketone
Tetrachloroethylene
Acetone
Ethylbenzene
Naphthalene
Zinc (Fume Or Dust)
1 ,2,4-Trimethylbenzene
Dichloromethane
Formaldehyde
Methanol
Cadmium
Barium Compounds
Hydrogen Fluoride
Cadmium Compounds
Manganese
Cumene
Cobalt
Freon 113
Lead Compounds
Manganese Compounds
Methylenebis
(Phenylisocyanate)
Aluminum (Fume Or Dust)
Antimony
Dimethyl Phthalate
Ethylene Glycol
Propylene
Aluminum Oxide (Fibrous
Form)
Isopropyl Alcohol
(Manufacturing)
M-Xylene
Sec-Butyl Alcohol
Silver
2-Methoxyethanol
Ammonium Nitrate
(Solution)
Arsenic
Barium
Bis(2-Ethylhexyl) Adipate
Ethyl Acrylate
Mercury
O-Xylene
Phenol
Selenium
Silver Compounds
Trichlorofluoromethane
1 ,2-Dichlorobenzene
2-Ethoxyethanol
2-Nitropropane
4,4-Isopropylidenediphenol
Total
# Facilities
Reporting
Chemical
30
25
21
20
20
20
20
15
15
15
13
12
10
9
8
7
6
6
5
4
4
3
3
3
3
3
2
2
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
—
Fugitive
Air
127088
401718
166232
46499
25677
14713
87617
420391
14409
53243
57
1601
6216
266
21
9178
12
93785
255
15
5
250
0
2407
1160
503
0
250
0
1000
5
255
0
5
0
0
0
5
0
12000
5
250
5
12000
250
186
0
5,931,789
Point Air
269586
211664
250318
68675
52326
405
118935
395882
8992
138202
6
482
3208
11
69
18933
542
0
500
5
150
250
418
5438
18552
516
0
15000
6109
3000
0
24825
0
0
0
0
2578
0
37911
0
0
250
12000
0
7000
182
250
10,560,463
Water
Discharges
0
0
0
0
0
0
0
5
209
0
0
0
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
58,629
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
250
Land
Disposal
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
220,447
Total
Releases
396674
613382
416550
115174
78003
15118
206552
816278
23610
191445
63
2083
9424
277
90
28111
559
93785
755
20
155
500
418
7845
19712
1019
0
15250
6109
4000
5
25080
0
5
0
0
2578
5
37911
12000
5
500
12005
12000
7250
368
250
16,771,578
Average
Releases
per Facility
13222
24535
19836
5759
3900
756
10328
54419
1574
12763
5
174
942
31
11
4016
93
15631
151
5
39
167
139
2615
6571
340
0
7625
3055
2000
3
12540
0
5
0
0
2578
5
37911
12000
5
500
12005
12000
7250
368
250
—
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
SIC Code 34
46
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 29
Transfers for Metal Finishing (SIC 347) in TRI, by Number of Facilities
(Transfers reported in pounds/year)
Chemical Name
Sulfuric Acid
Hydrochloric Acid
Nitric Acid
Zinc Compounds
Phosphoric Acid
Methyl Ethyl Ketone
Chromium Compounds
Nickel Compounds
Cyanide Compounds
Nickel
Trichloroethylene
Xylene (Mixed Isomers)
1,1,1 -Trichloroethane
Toluene
Glycol Ethers
Copper
Chromium
N-Butyl Alcohol
Copper Compounds
Ammonia
Chlorine
Lead
Methyl Isobutyl Ketone
Tetrachloroethylene
Acetone
Ethylbenzene
Naphthalene
Zinc (Fume Or Dust)
1 ,2,4-Trimethylbenzene
Dichloromethane
Formaldehyde
Methanol
Cadmium
Barium Compounds
Hydrogen Fluoride
Cadmium Compounds
Manganese
Cumene
Cobalt
Freon 113
Lead Compounds
Manganese Compounds
Methylenebis
(Phenylisocyanate)
Aluminum (Fume Or Dust)
Antimony
Dimethyl Phthalate
Ethylene Glycol
Propylene
Aluminum Oxide (Fibrous
Form)
Isopropyl Alcohol
(Manufacturing)
M-Xylene
Sec-Butyl Alcohol
Silver
2-Methoxyethanol
#
Facilities
Reporting
Chemical
577
490
290
158
120
103
101
95
87
87
81
79
73
69
59
54
48
44
43
35
32
31
30
25
21
20
20
20
20
15
15
15
13
12
10
9
8
7
6
6
5
4
4
3
3
3
3
3
2
2
2
2
2
2
POTW
Discharges
804908
382255
32756
25225
160428
10
14423
17937
18577
12239
353
10
45
6
206381
3810
4297
13300
8404
19727
4210
61
0
20
5
0
0
4580
0
377
41510
29686
1814
5
0
1287
889
0
30
0
751
5
0
250
0
0
5
0
0
0
0
0
5
5
Disposal
1947304
2691567
274177
4286331
296366
0
594848
375149
16451
255282
4873
2465
1090
3248
4168
215903
253964
1615
109090
260
750
10814
0
0
0
0
0
9250
0
0
5
0
6186
26665
2581
65319
851
0
7590
0
1520
22024
0
0
0
0
0
0
0
0
0
0
10
0
Recycling
3112900
1467208
822830
16726872
5126632
2060497
249365
1171327
12127
777750
214013
373083
359456
323174
209411
4247604
245168
19334
3397732
0
250
428225
467583
198381
482911
95670
1000
181479
12825
92499
0
1513
9432
29
0
27000
113
2020
1431
3900
42677
87789
0
0
1955
0
0
0
25000
87932
0
0
250
0
Treatment
2266082
3058084
562997
1865137
120242
110831
364291
501971
126143
399252
103537
110740
30856
212714
44590
14524
402593
19951
118222
255
6221
7169
8208
10999
134524
2795
7046
75065
8538
22453
1588
34930
31256
7756
16618
250
1751
400
193
0
319
0
0
5460
375
269
250
0
0
0
0
0
0
0
Energy
Recovery
0
0
0
2994
0
1994068
2980
0
0
0
63712
499378
25528
912937
530166
0
0
68165
0
0
0
0
70164
4542
37649
67994
23833
0
37488
15138
7202
56354
0
0
0
0
0
5618
0
0
0
0
0
0
0
1802
994
0
0
2300
0
0
0
8520
Total
Transfers
8131194
7676109
1692760
22906591
5718883
4181588
1244457
2066384
173798
1445523
386488
985676
416975
1452079
994966
4481841
923657
122365
3633448
20242
11431
446269
545955
213942
655089
166459
31879
270624
58851
130467
50305
122483
48688
34455
19199
93856
3604
8038
9244
3900
45267
109818
0
5710
2330
2071
1249
0
25000
90232
0
0
265
8525
Average
Transfers
per
Facility
14092
15666
5837
144978
47657
40598
12321
21751
1998
16615
4771
12477
5712
21045
16864
82997
19243
2781
84499
578
357
14396
18199
8558
31195
8323
1594
13531
2943
8698
3354
8166
3745
2871
1920
10428
451
1148
1541
650
9053
27455
0
1903
777
690
416
0
12500
45116
0
0
133
4263
September 1995
47
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 29 (cont'd)
Transfers for Metal Finishing (SIC 347) in TRI, by Number of Facilities
(Transfers reported in pounds/year)
Chemical Name
Ammonium Nitrate
(Solution)
Arsenic
Barium
Bis(2-Ethylhexyl) Adipate
Ethyl Acrylate
Mercury
O-Xylene
Phenol
Selenium
Silver Compounds
Trichlorofluoromethane
1 ,2-Dichlorobenzene
2-Ethoxyethanol
2-Nitropropane
4,4-Isopropylidenediphenol
Totals
#
Facilities
Reporting
Chemical
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
—
POTW
Discharges
0
5
5
0
0
5
0
0
5
250
0
0
5
0
0
1,810,861
Disposal
0
10
10
250
0
10
0
0
10
0
3400
0
0
0
250
11,491,656
Recycling
0
0
0
0
0
0
0
0
0
4000
0
0
0
0
0
43,172,347
Treatment
0
0
0
0
0
0
20
0
0
0
0
0
0
95
0
10,817,560
Energy
Recovery
0
0
0
0
0
0
0
0
0
0
0
0
750
103
0
4,440,379
Total
Transfers
0
15
15
250
0
15
20
0
15
4250
3400
0
755
198
250
71,879,412
Average
Transfers
per
Facility
0
15
15
250
0
15
20
0
15
4250
3400
0
755
198
250
—
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
IV.B. Summary of the Selected Chemicals Released
The following is a synopsis of current scientific toxicity and fate
information for the top chemicals (by weight) that facilities within this
sector self-reported as released to the environment based upon 1993
TRI data. Because this section is based upon self-reported release
data, it does not attempt to provide information on management
practices employed by the sector to reduce the release of these
chemicals. Information regarding pollutant release reductions over
time may be available from EPA's TRI and 33/50 programs, or directly
from the industrial trade associations that are listed in Section IX of
this document. Since these descriptions are cursory, please consult the
sources referenced below for a more detailed description of both the
chemicals described in this section, and the chemicals that appear on
the full list of TRI chemicals appearing in Section IV. A.
The brief descriptions provided below were taken from the 1993 Toxics
Release Inventory Public Data Release (EPA, 1994), the Hazardous
Substances Data Bank (HSDB), and the Integrated Risk Information
System (IRIS), both accessed via TOXNET1. The information
1 TOXNET is a computer system run by the National Library of Medicine that includes a number of
toxicological databases managed by EPA, National Cancer Institute, and the National Institute for
Occupational Safety and Health. For more information on TOXNET, contact the TOXNET help line
at 1-800-231-3766. Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research
SIC Code 34
48
September 1995
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Fabricated Metal Products Sector Notebook Project
contained below is based upon exposure assumptions that have been
conducted using standard scientific procedures. The effects listed
below must be taken in context of these exposure assumptions that are
more fully explained within the full chemical profiles in HSDB.
The top ten TRI releases for the Fabricated Metal Products industry
(SIC 34) as a whole include: glycol ethers, n-butyl, xylene, methyl
ethyl ketone, trichloroethylene, toluene-1, dichloromethane, methyl
isobutyl ketone, acetone, and tetrachloroethylene. The top ten TRI
releases for the coating, engraving, and allied services portion of the
fabricated metal products industry (SIC 347) include: methyl ethyl
ketone, toluene, glycol ethers, trichloroethylene, xylene (mixed
isomers), 1,1,1-trichloroethane, dichloromethane, tetrachloroethylene,
hydrochloric acid, and methyl isobutyl ketone. Summaries of most of
these chemicals follow.
Acetone
Toxicity. Acetone is irritating to the eyes, nose, and throat. Symptoms
of exposure to large quantities of acetone may include headache,
unsteadiness, confusion, lassitude, drowsiness, vomiting, and
respiratory depression.
Reactions of acetone (see environmental fate) in the lower atmosphere
contribute to the formation of ground-level ozone. Ozone (a major
component of urban smog) can affect the respiratory system,
especially in sensitive individuals such as asthmatics or allergy
sufferers.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. If released into water, acetone will be degraded
by microorganisms or will evaporate into the atmosphere.
Information System), DART (Developmental and Reproductive Toxicity Database), DBIR (Directory
of Biotechnology Information Resources), EMICBACK (Environmental Mutagen Information Center
Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous Substances Data Bank), IRIS
(Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical Substances),
and TRI (Toxic Chemical Release Inventory). HSDB contains chemical-specific information on
manufacturing and use, chemical and physical properties, safety and handling, toxicity and
biomedical effects, pharmacology, environmental fate and exposure potential, exposure standards
and regulations, monitoring and analysis methods, and additional references.
September 1995 49 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
Degradation by microorganisms will be the primary removal
mechanism.
Acetone is highly volatile, and once it reaches the troposphere (lower
atmosphere), it will react with other gases, contributing to the
formation of ground-level ozone and other air pollutants. EPA is
reevaluating acetone's reactivity in the lower atmosphere to determine
whether this contribution is significant.
Physical Properties. Acetone is a volatile and flammable organic
chemical.
Note; Acetone was removed from the list of TRI chemicals on June 16, 1995
(60 FR 31643) and will not be reported for 1994 or subsequent years.
Glvcol Ethers
Due to data limitations, data on diethylene glycol (glycol ether) are
used to represent all glycol ethers.
Toxicity. Diethylene glycol is only a hazard to human health if
concentrated vapors are generated through heating or vigorous
agitation or if appreciable skin contact or ingestion occurs over an
extended period of time. Under normal occupational and ambient
exposures, diethylene glycol is low in oral toxicity, is not irritating to
the eyes or skin, is not readily absorbed through the skin, and has a
low vapor pressure so that toxic concentrations of the vapor can not
occur in the air at room temperatures.
At high levels of exposure, diethylene glycol causes central nervous
depression and liver and kidney damage. Symptoms of moderate
diethylene glycol poisoning include nausea, vomiting, headache,
diarrhea, abdominal pain, and damage to the pulmonary and
cardiovascular systems. Sulfanilamide in diethylene glycol was once
used therapeutically against bacterial infection; it was withdrawn
from the market after causing over 100 deaths from acute kidney
failure.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
SIC Code 34 50 September 1995
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Fabricated Metal Products Sector Notebook Project
Environmental Fate. Diethylene glycol is a water-soluble, volatile
organic chemical. It may enter the environment in liquid form via
petrochemical plant effluents or as an unburned gas from combustion
sources. Diethylene glycol typically does not occur in sufficient
concentrations to pose a hazard to human health.
Hydrochloric Acid
Toxicity. Hydrochloric acid is primarily a concern in its aerosol form.
Acid aerosols have been implicated in causing and exacerbating a
variety of respiratory ailments. Dermal exposure and ingestion of
highly concentrated hydrochloric acid can result in corrosivity.
Ecologically, accidental releases of solution forms of hydrochloric acid
may adversely affect aquatic life by including a transient lowering of
the pH (i.e., increasing the acidity) of surface waters.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. Releases of hydrochloric acid to surface waters
and soils will be neutralized to an extent due to the buffering
capacities of both systems. The extent of these reactions will depend
on the characteristics of the specific environment.
Physical Properties. Concentrated hydrochloric acid is highly
corrosive.
Methylene Chloride (Dichloromethane)
Toxicity. Short-term exposure to dichloromethane (DCM) is
associated with central nervous system effects, including headache,
giddiness, stupor, irritability, and numbness and tingling in the limbs.
More severe neurological effects are reported from longer-term
exposure, apparently due to increased carbon monoxide in the blood
from the break down of DCM. Contact with DCM causes irritation of
the eyes, skin, and respiratory tract.
Occupational exposure to DCM has also been linked to increased
incidence of spontaneous abortions in women. Acute damage to the
eyes and upper respiratory tract, unconsciousness, and death were
reported in workers exposed to high concentrations of DCM.
Phosgene (a degradation product of DCM) poisoning has been
September 1995 51 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
reported to occur in several cases where DCM was used in the
presence of an open fire.
Populations at special risk from exposure to DCM include obese
people (due to accumulation of DCM in fat), and people with
impaired cardiovascular systems.
Carcinogenicity. DCM is a probable human carcinogen via both oral
and inhalation exposure, based on inadequate human data and
sufficient evidence in animals.
Environmental Fate. When spilled on land, DCM is rapidly lost from
the soil surface through volatilization. The remainder leaches through
the subsoil into the groundwater.
Biodegradation is possible in natural waters but will probably be very
slow compared with evaporation. Little is known about
bioconcentration in aquatic organisms or adsorption to sediments but
these are not likely to be significant processes. Hydrolysis is not an
important process under normal environmental conditions.
DCM released into the atmosphere degrades via contact with other
gases with a half-life of several months. A small fraction of the
chemical diffuses to the stratosphere where it rapidly degrades
through exposure to ultraviolet radiation and contact with chlorine
ions. Being a moderately soluble chemical, DCM is expected to
partially return to earth in rain.
Methyl Ethyl Ketone
Toxicity. Breathing moderate amounts of methyl ethyl ketone (MEK)
for short periods of time can cause adverse effects on the nervous
system ranging from headaches, dizziness, nausea, and numbness in
the fingers and toes to unconsciousness. Its vapors are irritating to the
skin, eyes, nose, and throat and can damage the eyes. Repeated
exposure to moderate to high amounts may cause liver and kidney
effects.
Carcinogenicity. No agreement exists over the carcinogenicity of
MEK. One source believes MEK is a possible carcinogen in humans
based on limited animal evidence. Other sources believe that there is
insufficient evidence to make any statements about possible
carcinogenicity.
SIC Code 34 52 September 1995
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Fabricated Metal Products Sector Notebook Project
Environmental Fate. Most of the MEK released to the environment
will end up in the atmosphere. MEK can contribute to the formation
of air pollutants in the lower atmosphere. It can be degraded by
microorganisms living in water and soil.
Physical Properties. Methyl ethyl ketone is a flammable liquid.
Toluene
Toxicity. Inhalation or ingestion of toluene can cause headaches,
confusion, weakness, and memory loss. Toluene may also affect the
way the kidneys and liver function.
Reactions of toluene (see environmental fate) in the atmosphere
contribute to the formation of ozone in the lower atmosphere. Ozone
can affect the respiratory system, especially in sensitive individuals
such as asthma or allergy sufferers.
Some studies have shown that unborn animals were harmed when
high levels of toluene were inhaled by their mothers, although the
same effects were not seen when the mothers were fed large quantities
of toluene. Note that these results may reflect similar difficulties in
humans.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. The majority of releases of toluene to land and
water will evaporate. Toluene may also be degraded by
microorganisms. Once volatized, toluene in the lower atmosphere will
react with other atmospheric components contributing to the
formation of ground-level ozone and other air pollutants.
Physical Properties. Toluene is a volatile organic chemical.
1.1.1 -Trichloroethane
Toxicity. Repeated contact of 1,1,1-trichloroethane (TCE) with skin
may cause serious skin cracking and infection. Vapors cause a slight
smarting of the eyes or respiratory system if present in high
concentrations.
September 1995 53 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
Exposure to high concentrations of TCE causes reversible mild liver
and kidney dysfunction, central nervous system depression, gait
disturbances, stupor, coma, respiratory depression, and even death.
Exposure to lower concentrations of TCE leads to light-headedness,
throat irritation, headache, disequilibrium, impaired coordination,
drowsiness, convulsions and mild changes in perception.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. Releases of TCE to surface water or land will
almost entirely volatilize. Releases to air may be transported long
distances and may partially return to earth in rain. In the lower
atmosphere, TCE degrades very slowly by photooxidation and slowly
diffuses to the upper atmosphere where photodegradation is rapid.
Any TCE that does not evaporate from soils leaches to groundwater.
Degradation in soils and water is slow. TCE does not hydrolyze in
water, nor does it significantly bioconcentrate in aquatic organisms.
Trichloroethylene
Toxicity. Trichloroethylene was once used as an anesthetic, though its
use caused several fatalities due to liver failure. Short term inhalation
exposure to high levels of trichloroethylene may cause rapid coma
followed by eventual death from liver, kidney, or heart failure. Short-
term exposure to lower concentrations of trichloroethylene causes eye,
skin, and respiratory tract irritation. Ingestion causes a burning
sensation in the mouth, nausea, vomiting and abdominal pain.
Delayed effects from short-term trichloroethylene poisoning include
liver and kidney lesions, reversible nerve degeneration, and psychic
disturbances. Long-term exposure can produce headache, dizziness,
weight loss, nerve damage, heart damage, nausea, fatigue, insomnia,
visual impairment, mood perturbation, sexual problems, dermatitis,
and rarely jaundice. Degradation products of trichloroethylene
(particularly phosgene) may cause rapid death due to respiratory
collapse.
Carcinogenicity. Trichloroethylene is a probable human carcinogen
via both oral and inhalation exposure, based on limited human
evidence and sufficient animal evidence.
Environmental Fate. Trichloroethylene breaks down slowly in water
in the presence of sunlight and bioconcentrates moderately in aquatic
SIC Code 34 54 September 1995
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Fabricated Metal Products Sector Notebook Project
organisms. The main removal of trichloroethylene from water is via
rapid evaporation.
Trichloroethylene does not photodegrade in the atmosphere, though it
breaks down quickly under smog conditions, forming other pollutants
such as phosgene, dichloroacetyl chloride, and formyl chloride. In
addition, trichloroethylene vapors may be decomposed to toxic levels
of phosgene in the presence of an intense heat source such as an open
arc welder.
When spilled on the land, trichloroethylene rapidly volatilizes from
surface soils. The remaining chemical leaches through the soil to
groundwater.
Xylene (Mixed Isomers)
Toxicity. Xylenes are rapidly absorbed into the body after inhalation,
ingestion, or skin contact. Short-term exposure of humans to high
levels of xylenes can cause irritation of the skin, eyes, nose, and throat,
difficulty in breathing, impaired lung function, impaired memory, and
possible changes in the liver and kidneys. Both short- and long-term
exposure to high concentrations can cause effects such as headaches,
dizziness, confusion, and lack of muscle coordination. Reactions of
xylenes (see environmental fate) in the atmosphere contribute to the
formation of ozone in the lower atmosphere. Ozone can affect the
respiratory system, especially in sensitive individuals such as asthma
or allergy sufferers.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. The majority of releases to land and water will
quickly evaporate, although some degradation by microorganisms
will occur.
Xylenes are moderately mobile in soils and may leach into
groundwater, where they may persist for several years.
Xylenes are volatile organic chemicals. As such, xylenes in the lower
atmosphere will react with other atmospheric components,
contributing to the formation of ground-level ozone and other air
pollutants.
September 1995 55 SIC Code 34
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Fabricated Metal Products
Sector Notebook Project
IV.C. Other Data Sources
The Aerometric Information Retrieval System (AIRS) contains a wide
range of information related to stationary sources of air pollution,
including the emissions of a number of air pollutants which may be of
concern within a particular industry. With the exception of volatile
organic compounds (VOCs), there is little overlap with the TRI
chemicals reported above. Exhibit 30 summarizes annual releases of
carbon monoxide (CO), nitrogen dioxide (NO2), particulate matter of
10 microns or less (PM10), total particulates (PT), sulfur dioxide (SO2),
and volatile organic compounds (VOCs).
Exhibit 30
Pollutant Releases (Short Tons/Years)
Industry
U.S. Total
Metal Mining
Nonmetal Mining
Lumber and Wood Products
Wood Furniture and
Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc. Plastic
Products
Stone, Clay, Glass, and
Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Electronics
Motor Vehicles, Bodies,
Parts, and Accessories
Dry Cleaning
CO
97,208,000
5,391
4,525
123,756
2,069
624,291
8,463
166,147
146,947
419,311
2,090
58,043
1,518,642
448,758
3,851
367
35,303
101
N02
23,402,000
28,583
28,804
42,658
2,981
394,448
4,915
108,575
236,826
380,641
11,914
338,482
138,985
55,658
16,424
1,129
23,725
179
PMio
45,489,000
39,359
59,305
14,135
2,165
35,579
399
4,107
26,493
18,787
2,407
74,623
42,368
20,074
1,185
207
2,406
3
PT
7,836,000
140,052
167,948
63,761
3,178
113,571
1,031
39,082
44,860
36,877
5,355
171,853
83,017
22,490
3,136
293
12,853
28
S02
21,888,000
84,222
24,129
9,149
1,606
341,002
1,728
182,189
132,459
648,153
29,364
339,216
238,268
373,007
4,019
453
25,462
152
voc
23,312,000
1,283
1,736
41,423
59,426
96,875
101,537
52,091
201,888
309,058
140,741
30,262
82,292
27,375
102,186
4,854
101,275
7,310
Source U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.
SIC Code 34
56
September 1995
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Fabricated Metal Products Sector Notebook Project
IV.D. Comparison of Toxic Release Inventory Between Selected Industries
The following information is presented as a comparison of pollutant
release and transfer data across industrial categories. It is provided to
give a general sense as to the relative scale of releases and transfers
within each sector profiled under this project. Please note that the
following table does not contain releases and transfers for industrial
categories that are not included in this project, and thus cannot be
used to draw conclusions regarding the total release and transfer
amounts that are reported to TRI. Similar information is available
within the annual TRI Public Data Release book.
Exhibit 31 is a graphical representation of a summary of the 1993 TRI
data for the Fabricated Metals Products industry and the other sectors
profiled in separate notebooks. The bar graph presents the total TRI
releases and total transfers on the left axis and the triangle points show
the average releases per facility on the right axis. Industry sectors are
presented in the order of increasing total TRI releases. The graph is
based on the data shown in Exhibit 32 and is meant to facilitate
comparisons between the relative amounts of releases, transfers, and
releases per facility both within and between these sectors. The reader
should note, however, that differences in the proportion of facilities
captured by TRI exist between industry sectors. This can be a factor of
poor SIC matching and relative differences in the number of facilities
reporting to TRI from the various sectors. In the case of Fabricated
Metal Products industry, the 1993 TRI data presented here covers 2,363
facilities. These facilities listed SIC 34 (Fabricated Metal Products
industry) as a primary SIC code.
September 1995 57 SIC Code 34
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Fabricated Metal Products
Sector Notebook Project
Exhibit 31 Bar graph
Summary of 1993 TRI Data
Total Pounds (millions)
""DO
600 -
500 -
400 -
300 -
200 -
100 -
1 nnn nnn
._, T
i
v- -T- --
JLxJjjJ
r
1
r
36 32 25 34
24 27 2911
Total Releases | | Total
i
r-i
f
371
i
I
r
331
V
T
1 1 HI
286 281
30 26 333, 33
-800,000 j§
1
'o
•600,000 PH
^H
CD
PH
00
CD
00
-400,000 g
^5
Pi
CD
M)
S
-200,000 fc
3
.n
\
Transfers V Avg. Releases/Facility
SIC
Range
36
24
32
27
25
Industry Sector
Electronic Equipment and
Components
Lumber and Wood
Products
Stone, Clay, and Concrete
Printing
Wood Furniture and
Fixtures
SIC
Range
2911
34
371
331
30
Industry Sector
Petroleum Refining
Fabricated Metals
Motor Vehicles, Bodies,
Parts, and Accessories
Iron and Steel
Rubber and Misc.
Plastics
SIC
Range
286
26
281
333,334
Industry Sector
Organic Chemical Mfg.
Pulp and Paper
Inorganic Chemical Mfg.
Nonferrous Metals
SIC Code 34
58
September 1995
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Fabricated Metal Products
Sector Notebook Project
Exhibit 32
Toxic Release Inventory Data for Selected Industries
Industry Sector
Stone, Clay, and
Concrete
Lumber and
Wood Products
Furniture and
Fixtures
Printing
Electronics/Comp
uters
Rubber and Misc.
Plastics
Motor Vehicle,
Bodies, Parts and
Accessories
Pulp and paper
Inorganic Chem.
Mfg.
Petroleum
Refining
Fabricated Metals
Iron and Steel
Nonferrous
Metals
Organic Chemical
Mfg.
Metal Mining
Nonmetal Mining
Dry Cleaning
SIC
Range
32
24
25
2711-
2789
36
30
371
2611-
2631
2812-
2819
2911
34
3312-
3313
3321-
3325
333, 334
2861-
2869
10
14
7215,
7216,
7218
#TRI
Facilities
634
491
313
318
406
1,579
609
309
555
156
2,363
381
208
417
Releases
Total Releases
(106 pounds)
26.6
8.4
42.2
36.5
6.7
118.4
79.3
169.7
179.6
64.3
72.0
85.8
182.5
151.6
Average
Releases per
Facility
(pounds)
41,895
17,036
134,883
115,000
16,520
74,986
130,158
549,000
324,000
412,000
30,476
225,000
877,269
364,000
Transfers
1993 Total (106
pounds)
2.2
3.5
4.2
10.2
47.1
45.0
145.5
48.4
70.0
417.5
195.7
609.5
98.2
286.7
Average Transfers
per Facility
(pounds)
3,500
7,228
13,455
732,000
115,917
28,537
238,938
157,080
126,000
2,676,000
82,802
1,600,000
472,335
688,000
Total
Releases +
Transfers
(106 pounds)
28.2
11.9
46.4
46.7
53.7
163.4
224.8
218.1
249.7
481.9
267.7
695.3
280.7
438.4
Average
Release+
Transfers per
Facility
(pounds)
46,000
24,000
148,000
147,000
133,000
104,000
369,000
706,000
450,000
3,088,000
123,000
1,825,000
1,349,000
1,052,000
Industry sector not subject to TR1 reporting
Industry sector not subject to TR1 reporting
Industry sector not subject to TR1 reporting
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
September 1995
59
SIC Code 34
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Fabricated Metal Products Sector Notebook Project
V. POLLUTION PREVENTION OPPORTUNITIES
The best way to reduce pollution is to prevent it in the first place.
Some companies have creatively implemented pollution prevention
techniques that improve efficiency and increase profits while at the
same time minimizing environmental impacts. This can be done in
many ways such as reducing material inputs, re-engineering processes
to reuse by-products, improving management practices, and
employing substitution of toxic chemicals. Some smaller facilities are
able to actually get below regulatory thresholds just by reducing
pollutant releases through aggressive pollution prevention policies.
In order to encourage these approaches, this section provides both
general and company-specific descriptions of some pollution
prevention advances that have been implemented within the
Fabricated Metal Products industry. While the list is not exhaustive, it
does provide core information that can be used as the starting point
for facilities interested in beginning their own pollution prevention
projects. When possible, this section provides information from real
activities that can, or are being implemented by this sector — including
a discussion of associated costs, time frames, and expected rates of
return. This section provides summary information from activities
that may be, or are being implemented by this sector. When possible,
information is provided that gives the context in which the techniques
can be effectively used. Please note that the activities described in this
section do not necessarily apply to all facilities that fall within this
sector. Facility-specific conditions must be carefully considered when
pollution prevention options are evaluated, and the full impacts of the
change must examine how each option affects, air, land, and water
pollutant releases.
V. A. Identification of Pollution Prevention Activities in Use and Environmental
and Economic Benefits of Each Pollution Prevention Activity
Pollution prevention (sometimes referred to as source reduction) is the
use of materials, processes, or practices that reduce or eliminate the
creation of pollutants or wastes at the source. Pollution prevention
includes practices that reduce the use of hazardous materials, energy,
water or other resources, and practices that protect natural resources
through conservation or more efficient use.
SIC Code 34 60 September 1995
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Fabricated Metal Products Sector Notebook Project
EPA and the Fabricated Metal Products industry are working together
to promote pollution prevention because it is often the most cost-
effective way to reduce pollution and the associated risks to human
health and the environment. Pollution prevention is often cost
effective because it may reduce raw material losses; reduce reliance on
expensive "end-of-pipe" treatment technologies and disposal practices;
conserve energy, water, chemicals, and other inputs; and mitigate the
potential liability associated with waste generation and disposal.
Pollution prevention often involves complex re-engineering however,
and companies must balance the desired savings in materials and
benefits to the environment against the cost of changing operating
practices.
All companies in the Fabricated Metal Products industry, regardless of
their size, must comply with environmental regulations related to
metal fabricating and/or metal finishing processes. Therefore, all
companies benefit from the knowledge of pollution prevention
techniques which, if implemented, may increase a company's ability to
meet these requirements. Many large companies have been successful
in identifying and implementing pollution prevention and other
techniques allowing them to operate in an efficient and
environmentally protective manner. This capability may be due in
part because large companies often have resources to devote to
tracking and implementing pollution prevention techniques, and
maintaining an awareness and understanding of regulations that
apply to their facilities.
Smaller companies may have limited resources to devote to these
activities, which may make monitoring and understanding regulations
more difficult and may result in limited pollution prevention
participation. Increased awareness and publication of pollution
prevention techniques improve the ability of companies to comply
with regulations. Pollution prevention techniques also permit
industrial processes to be more efficient and less costly, providing all
companies with an opportunity to maximize the efficiency of their
operations and reduce their costs while protecting the environment.
Pollution Prevention techniques and processes currently used by the
metal fabricating and finishing industry can be grouped into seven
general categories:
• Production planning and sequencing
• Process or equipment modification
• Raw material substitution or elimination
September 1995 61 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
• Loss prevention and housekeeping
• Waste segregation and separation
• Closed-loop recycling
• Training and supervision.
Each of these categories is discussed briefly below. Refer to Section
V.D. for a list of specific pollution prevention techniques and
associated costs, savings, and other information. It should be kept in
mind that every pollution prevention option may not be available for
each facility.
Production planning and sequencing is used to ensure that only necessary
operations are performed and that no operation is needlessly reversed
or obviated by a following operation. One example is to sort out
substandard parts prior to painting or electroplating. A second
example is to reduce the frequency with which equipment requires
cleaning by painting all products of the same color at the same time.
A third example is to schedule batch processing in a manner that
allows the wastes or residues from one batch to be used as an input for
the subsequent batch (e.g., to schedule paint formulation from lighter
shades to darker) so that equipment need not be cleaned between
batches.
Process or equipment modification is used to reduce the amount of waste
generated. For example, manufacturers can change to a paint
application technique that is more efficient than spray painting, reduce
overspray by reducing the atomizing air pressure, reduce drag-out by
reducing the withdrawal speed of parts from plating tanks, or
improve a plating line by incorporating drag-out recovery tanks or
reactive rinsing.
Raw material substitution or elimination is the replacement of existing
raw materials with other materials that produce less waste, or a non-
toxic waste. Examples include substituting alkali washes for solvent
degreasers, and replacing oil with lime or borax soap as the drawing
agent in cold forming.
Loss prevention and housekeeping is the performance of preventive
maintenance and equipment and materials management so as to
minimize opportunities for leaks, spills, evaporative losses, and other
releases of potentially toxic chemicals. For example, spray guns can be
cleaned in a manner that does not damage leather packings and cause
the guns to leak; or drip pans can be placed under leaking machinery
to allow recovery of the leaking fluid.
SIC Code 34 62 September 1995
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Fabricated Metal Products Sector Notebook Project
Waste segregation and separation involves avoiding the mixture of
different types of wastes and avoiding the mixture of hazardous
wastes with non-hazardous wastes. This makes the recovery of
hazardous wastes easier by minimizing the number of different
hazardous constituents in a given waste stream. It also prevents the
contamination of non-hazardous wastes. Specific examples include
segregating scrap metal by metal type, and segregating different kinds
of used oils.
Closed-loop recycling is the on-site use or reuse of a waste as an
ingredient or feedstock in the production process. For example, in-
plant paper fiber waste can be collected and recycled to make pre-
consumer recycled paper products.
Training and supervision provides employees with the information and
the incentive to minimize waste generation in their daily duties. This
might include ensuring that employees know and practice proper and
efficient use of tools and supplies, and that they are aware of,
understand, and support the company's pollution prevention goals.
V.B. Possible Pollution Prevention Future Trends
There are numerous pollution prevention trends in the metal
fabrication and finishing industry. These include recycling liquids,
employing better waste control techniques, using mechanical forms of
surface preparation, and/or substituting raw materials. One major
trend is the increased recycling (e.g., reuse) of most process liquids
(e.g., rinse water, acids, alkali cleaning compounds, solvents, etc.)
used during the metal forming and finishing processes. For instance,
instead of discarding liquids, companies are containing them and
reusing them to cut down on the volume of process liquids that must
eventually be disposed of. Also, many companies are replacing
aqueous plating with ion vapor deposition.
Another common approach to reducing pollution is to reduce rinse
contamination via drag-out by slowing and smoothing the removal of
parts (rotating them if necessary), maximizing drip time, using
drainage boards to direct dripping solutions back to process tanks,
and/or installing drag-out recovery tanks to capture dripping
solutions. By slowing down the processes and developing structures
to contain the dripping solutions, a facility can better control the
potential wastes emitted.
September 1995 63 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
To reduce the use of acids when cleaning parts, the industry is using
and encouraging the use of mechanical scraping/scrubbing techniques
to clean and prepare the metal surface. Emphasizing mechanical
approaches would greatly diminish the need for acids, solvents, and
alkalis. In addition to the mechanical technique for cleaning surfaces,
companies are encouraged to substitute acids and solvents with less
harmful liquids (e.g., alcohol). Section V.D. lists numerous specific
pollution prevention techniques that have been employed in the
industry.
V.C. Pollution Prevention Case Studies
Numerous pollution prevention case histories have been documented
for the metal fabricating and finishing industries. Many of these have
dealt primarily with electroplating or general finishing operations.
The Eastside Plating case, presented in this section, is a classic example
of the numerous pollution prevention techniques that can be
implemented at an electroplating company. For other pollution
prevention case studies, see section V.D. Pollution Prevention Options,
and the list of pollution prevention contacts in section V.E.
Eastside Plating, an Oregon-based company, has made money
complying with new environmental regulations. Under the direction
of its Maintenance and Water Treatment Manager, the electroplating
firm implemented operational changes that save more than $300,000
annually. Eastside Plating management made the commitment to
implement a hazardous waste reduction program in 1982. By
changing rinsing techniques, substituting materials, and segregating
wastes for treatment, the firm has become a more cost-effective
operation.
By setting priorities and upgrading in phases, the firm was able to
work toward compliance yet meet increased demand for services
during a period of rapid growth. The first operational modification
addressed counterflow and cascade rinsing systems. The changes
decreased water used for rinsing, a process that accounts for 90
percent of all water used in electroplating. In counterflow rinsing,
water is used a number of times, thus dramatically reducing volume.
Cascade rinsing requires only one tank with a center divider which
allows water to spill into the other side. The filling/draining process
is continuous and very slow to reduce the amount of water used. Both
systems cut water bills and wastewater treatment costs.
SIC Code 34 64 September 1995
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Fabricated Metal Products Sector Notebook Project
Management next searched for waste treatment chemicals that
decreased, rather than increased, the production of sludge. Total
chromium and cyanide wastes were cut in half simply by changing
reducing agents. Chromium acid wastes are now oxidized by using
sodium bisulfite and sulfuric acid instead of ferrous sulfate, while
cyanide reduction is now accomplished more efficiently with gaseous,
instead of liquid, chlorine.
Eastside Plating also upgraded its three major waste treatment
components: the cyanide oxidation tank, the chromium reduction
tank, and the acid/alkaline neutralizing tank. The goal was to
separate tank flow, eliminate contamination of the acid/alkaline
neutralizing tank, and increase efficiency. Automated metering
equipment reduced the quantity of costly caustic chemicals needed to
treat acid wastes by 50 percent. To eliminate the risks associated with
pump failure and the equalize flow rate, cyanide and chromic acid
oxidation and reduction tanks were redesigned as gravity flow
systems. Additionally, plumbing was segregated to prevent cross-
contamination. These simple solutions saved Eastside Plating
hundreds of thousands of dollars.
Next, management consulted with suppliers when they modified the
company's mixing sump (sometimes called a reaction tank) and a
flocculent mix tank (sometimes called a neutralizing tank). The
modification to each prohibits 'indigestion' in the mixing sump
interfering with the neutralization process. The suppliers helped
resolve the problems of inadequate mixing by baffling the
neutralization tank.
Since employees can make or break the best anti-pollution plan,
Eastside Plating offers an extensive employee education program. The
company says "it's a matter of changing how we do business." In
addition, Eastside Plating's Safety Committee helps all employees
work together more safely. Additionally, the company reported that
working with regulators helped the company make the move toward
compliance: "The City of Portland and the Department of
Environmental Quality were more interested in helping us solve our
problems than in blaming us."
Industry Pollution Prevention Activities
Several pollution prevention initiatives focus on the fabricated metal
products industry. As identified below, some efforts include Georgia's
September 1995 65 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
Pollution Prevention Assistance Division (P^AD) strategy, the
Industrial Technology Corporation collaborative effort, and the Merit
Partnership.
Georgia Department of Natural Resources
A core strategy of the Pollution Prevention Assistance Division (P^AD)
of the Georgia Department of Natural Resources (DNR) is to focus
technical assistance efforts on Georgia manufacturers that release
chemicals posing the greatest risk to the public and the environment.
After reviewing those industries which provide significant
opportunities for pollution prevention, various strategies will be
developed, including on-site technical assistance, financial assistance,
fact sheets, workshops, and other outreach activities that will help
manufacturers reduce their generation of toxic chemicals. The first
phase is an on-going targeting effort, which evaluates waste
generation characteristics of Georgia manufacturers producing toxic
and hazardous wastes. The fabricated metal products industry was
selected as a high priority manufacturing sector, along with the paper
and paper products industry, chemical and allied products industry,
transportation equipment industry, rubber and plastic products, and
printing and publishing.
ITAC
The Industrial Technology Assistance Corporation (ITAC), in
collaboration with the New York Branch of the AESF, the New York
Masters Association of Metal Finishers, Utility Metal Research
Corporation, and ten electroplating companies applied for and
received funding to deliver a program coordinated and written by the
Wastewater Technology Center of Canada. This is an industry-specific
hands on 24 hour training session that integrates the assessment and
incorporation of pollution prevention techniques into all types of
electroplating and metal finishing operations. The training also
includes an economic evaluation of the benefits of resource recovery
on a multi-media basis.
Merit Partnership
The Merit Partnership brings industry and government
representatives together to identify pollution prevention needs and
accelerate pollution prevention technology diffusion. Merit partners
and participants include EPA Region 9, The Metal Finishing
SIC Code 34 66 September 1995
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Fabricated Metal Products Sector Notebook Project
Association of Southern California (MFASC), the National Institute of
Standards and Testing/California Manufacturing Technology Center,
EPA's Office of Research and Development/Risk Reduction
Engineering Lab, large companies processing pollution prevention
technologies applicable to the metal finishing industry, local
regulatory agencies, and participating companies. The Merit
Partnership is working closely with its members to develop metal
finishing projects that are transferable to small businesses. There is an
emphasis on having large companies that are involved with metal
finishing share their proven metal finishing methods with smaller
companies. The Merit Partnership and MFASC have already begun to
identify programmatic areas for metal plating pollution prevention
opportunities, from which potential projects will be chosen.
V.D. Pollution Prevention Options
The following sections list numerous pollution prevention techniques
that may be useful to companies specializing in metal fabrication and
finishing operations. These are options available to facilities, but are
not to be construed as requirements. The information is organized by
metal shaping, surface preparation, plating, and other finishing
operations.
V.D.I. Metal Shaping Operations
Technique - Production Planning and Sequencing
Option 1 - Improve scheduling of processes that require use of varying oil types in order to
reduce the number of cleanouts.
Technique - Process or Equipment Modification
Option 1 - Standardize the oil types used for machining, turning, lathing, etc. This reduces
the number of equipment cleanouts, and the amount of leftovers and mixed wastes.
Option 2 - Use specific pipes and lines for each set of metals or processes that require a
specific oil in order to reduce the amount of cleanouts.
Option 3 - Save on coolant costs by extending machine coolant life through the use of a
centrifuge and the addition of biocides. Costs and Savings: Waste Savings/Reductions: 25
percent reduction in plant-wide waste coolant generation. Product/Waste Throughput
Information: based on handling 20,600 gallons of coolant per year.
Option 4 - Install a second high speed centrifuge on a system already operating with a
single centrifuge to improve recovery efficiency even more. Costs and Savings: Capital
September 1995 67 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
Investment: $126,000. Payback Period: 3.1 years. Product/Waste Throughput Information:
based on handling 20,600 gallons of coolant per year.
Option 5 - Install a chip wringer to recover excess coolant on aluminum chips. Costs and
Savings: Capital Investment: $11,000 to $23,000 (chip wringer and centrifuge
system).Payback Period: 0.9 years. Product/Waste Throughput Information: based on
handling 20,600 gallons of coolant per year.
Option 6 - Install a coolant recovery system and collection vehicle for machines not on a
central coolant sump. Costs and Savings: Capital Investment: $104,000. Payback Period:
1.9 years. Product/Waste Throughput Information: based on handling 20,600 gallons of
coolant per year.
Option 7 - Use a coolant analyzer to allow better control of coolant quality. Costs and
Savings: Capital Investment: $5,000. Payback Period: 0.7 years. Product/Waste
Throughput Information: based on handling 20,600 gallons of coolant per year.
Option 8 - Use an ultrafiltration system to remove soluble oils from wastewater streams.
Costs and Savings: Annual Savings: $200,000 (in disposal costs). Product/Waste
Throughput Information: based on a wastewater flow rate of 860 to 1,800 gallons per day.
Option 9 - Use disk or belt skimmers to remove oil from machine coolants and prolong
coolant life. Also, design sumps for ease of cleaning. Costs and Savings: Waste
Savings/Reduction: coolant is now disposed once per year rather than 3-6 times per year.
Technique - Raw Material Substitution
Option 1 - In cold forming or other processes where oil is used only as a lubricant,
substitute a hot lime bath or borax soap for oil.
Option 2 - Use a stamping lubricant that can remain on the piece until the annealing
process, where it is burned off. This eliminates the need for hazardous degreasing solvents
and alkali cleaners. Costs and Savings: Annual Savings: $12,000 (results from reduced
disposal, raw material, and labor costs). Waste Throughput Information: The amount of
waste solvents and cleaners was reduced from 30,000 pounds in 1982 to 13,000 pounds in
1986. Employee working conditions were also improved by removing vapors associated
with the old cleaners.
Technique - Waste Segregation and Separation
Option 1 - If filtration or reclamation of oil is required before reuse, segregate the used oils
in order to prevent mixing wastes.
Option 2 - Segregation of metal dust or scrap by type often increases the value of metal for
resale (e.g., sell metallic dust to a zinc smelter instead of disposing of it in a landfill). Costs
and Savings: Capital Investment: $0. Annual Savings: $130,000. Payback Period:
immediate. Waste Savings/Reduction: 2,700 tons per year. (Savings will vary with metal
type and market conditions.)
Option 3 - Improve housekeeping techniques and segregate waste streams (e.g., use care
when cleaning cutting equipment to prevent the mixture of cutting oil and cleaning solvent).
SIC Code 34 68 September 1995
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Fabricated Metal Products Sector Notebook Project
Costs and Savings: Capital Investment: SO. Annual Savings: S3,000 in disposal costs.
Waste Savings/Reduction: 66 percent (30 tons reduced to 10 tons).
Technique - Recycling
Option 1 - Where possible, recycle oil from cutting/machining operations. Often oils need
no treatment before recycling. Costs and Savings: Capital Investment: SI,900,000. Annual
Savings: SI56,000. Waste Throughput Information: 2 million gallons per year. Facility
reclaims oil and metal from process water.
Option 2 - Oil scrap mixtures can be centrifuged to recover the bulk of the oil for reuse.
Option 3 - Follow-up magnetic and paper filtration of cutting fluids with ultrafiltration. By
so doing, a much larger percentage of cutting fluids can be reused. Costs and Savings:
Capital Investment: 542,000(1976). Annual Savings: 533,800(1980).
Option 4 - Perform on-site purification of hydraulic oils using commercial "off-the-shelf"
cartridge filter systems. Costs and Savings: Capital Investment: S28,000. Annual Savings:
S17,800/year based on operating costs, avoided new oil purchase, and lost resale revenues.
Payback Period: less than 2 years. Product/Waste Throughput Information: example
facility handles 12,300 gallons/year of waste hydraulic oil.
Option 5 - Use a continues flow treatment system to regenerate and reuse aluminum
chemical milling solutions. Costs and Savings: Capital Investment: S465,000. Annual
Savings: S342,000. Payback Period: less than 2 years. Waste Savings/Reduction: 90
percent
Option 6 - Use a settling tank (to remove solids) and a coalescing unit (to remove tramp
oils) to recover metal-working fluids. Costs and Savings: Annual Savings: S26,800
(resulting from reduced material, labor, and disposal costs).
V.D.2. Surface Preparation Operations
SOLVENT CLEANING
Technique - Training and Supervision
Option 1 - Improve solvent management by requiring employees to obtain solvent through
their shop foreman. Also, reuse "waste" solvents from cleaner up-stream operations in
down-stream, machines shop-type processes. Costs and Savings: Capital Investment: SO.
Annual Savings: S7,200. Waste Savings/Reduction 49 percent (310 tons reduced to 152
tons). Product/Waste Throughput Information: original waste stream history: reactive
anions (6,100 gallons/year), waste oils (1,250 gallons/year), halogenated solvents (500
gallons/year).
Technique - Production Planning and Sequencing
Option 1 - Pre-cleaning will extent the life of the aqueous or vapor degreasing solvent
(wipe, squeeze, or blow part with air, shot, etc.). Costs and Savings: Annual Savings:
S40,000. Payback Period: 2 years. Waste Savings/Reduction: 48,000 gallons of aqueous
waste. Aluminum shot was used to preclean parts.
September 1995 69 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
Option 2 - Use countercurrent solvent cleaning (i.e., rinse initially in previously used
solvent and progress to new, clean solvent).
Options 3 - Cold clean with a recycled mineral spirits stream to remove the bulk of oil
before final vapor degreasing.
Option 4 - Only degrease parts that must be cleaned. Do not routinely degrease all parts.
Technique - Process or Equipment Modification
Option 1 - The loss of solvent to the atmosphere from vapor degreasing equipment can be
reduced by:
• increasing the freeboard height above the vapor level to 100 percent of tank width;
• covering the degreasing unit (automatic covers are available);
• installing refrigerator coils (or additional coils) above the vapor zone;
• rotating parts before removal from the vapor degreaser to allow all condensed solvent
to return to degreasing unit;
• controlling the speed at which parts are removed (10 feet or less per minute is desirable)
so as not to disturb the vapor line;
• installing thermostatic heating controls on solvent tanks; and
• adding in-line filters to prevent particulate buildup in the degreaser.
Option 2 - Reduce grease accumulation by adding automatic oilers to avoid excess oil
applications.
Option 3 - Use plastic blast media for paint stripping rather than conventional solvent
stripping techniques. Costs and Savings: Waste Savings/Reduction: volume of waste
sludge is reduced by as much as 99 percent over chemical solvents; wastewater fees are
eliminated.
Technique - Raw Material Substitution
Option 1 - Use less hazardous degreasing agents such as petroleum solvents or alkali
washes. For example, replace halogenated solvents (e.g., trichloroethylene) with liquid
alkali cleaning compounds. (Note that compatibility of aqueous cleaners with wastewater
treatment systems should be ensured.) Costs and Savings: Capital Investment: SO.
Annual Savings: S12,000. Payback Period: immediate. Waste Savings/Reduction: 30
percent of 1,1,1-trichloroethane replaced with an aqueous cleaner.
Option 2 - Substitute chromic acid cleaner with non-fuming cleaners such as sulfuric acid
and hydrogen peroxide. Costs and Savings: Annual Savings: SI0,000 in treatment
equipment costs and S2.50/lb. of chromium in treatment chemical costs. Product/Waste
Throughput Information: rinse water flowrate of 2 gallons per minute.
Option 3 - Substitute less polluting cleaners such as trisodium phosphate or ammonia for
cyanide cleaners. Costs and Savings: Annual Savings: SI2,000 in equipment costs and
S3.00/lb. of cyanide in treatment chemical costs. Product/Waste Throughput Information:
rinse water flowrate of 2 gallons per minute.
Technique - Recycling
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Fabricated Metal Products Sector Notebook Project
Option 1 - Recycle spent degreasing solvents on site using batch stills. Costs and Savings:
Capital Investment: $2,600-34,100 and $4,200-$ 17,000. Product Throughput Information:
35-60 gallons per hour and 0.6-20 gallons per hour, respectively. Two cost and throughput
estimates for distillation units from two vendors.
Option 2 - Use simple batch distillation to extend the life of 1,1,1-trichloroethane. Costs and
Savings: Capital Investment: $3,500 (1978). Annual Savings: $50,400. Product/Waste
Throughput Information: facility handles 40,450 gallons 1,1,1-trichloroethane per year.
Option 3 - When on-site recycling is not possible, agreements can be made with supply
companies to remove old solvents. Costs and Savings: Capital Investment: S3,250 for a
temporary storage building. Annual Savings: $8,260. Payback Period: less than 6 months.
Waste Savings/Reduction: 38,000 pounds per year of solvent sent off site for recycling.
Option 4 - Arrange a cooperative agreement with other small companies to centrally recycle
solvent.
CHEMICAL TREATMENT
Technique - Process or Equipment Modification
Option 1- Increase the number of rinses after each process bath and keep the rinsing
counter-current in order to reduce drag-out losses.
Option 2 - Recover unmixed acids in the wastewater by evaporation.
Option 3 - Reduce rinse contamination via drag-out by:
• slowing and smoothing removal of parts, rotating them if necessary;
• using surfactants and other wetting agents;
• maximizing drip time;
• using drainage boards to direct dripping solutions back to process tanks;
• installing drag-out recovery tanks to capture dripping solutions;
• using a fog spray rinsing technique above process tanks;
• using techniques such as air knives or squeegees to wipe bath solutions off of the part;
and
• changing bath temperature or concentrations to reduce the solution surface tension.
Option 4 - Instead of pickling brass parts in nitric acid, place them in a vibrating apparatus
with abrasive glass marbles or steel balls. A slightly acidic additive is used with the glass
marbles, and a slightly basic additive is used with the steel balls. Costs and Savings:
Capital Investment: $62,300 (1979); 50 percent less than conventional nitric acid pickling.
Option 5 - Use mechanical scraping instead of acid solution to remove oxides of titanium.
Costs and Savings: Annual Savings: $0; cost of mechanical stripping equals cost of
chemical disposal. Waste Savings/Reduction: 100 percent. Waste Throughput Information:
previously disposed 15 tons/year of acid with metals.
Option 6 - For cleaning nickel and titanium alloy, replace alkaline etching bath with a
mechanical abrasive system that uses a silk and carbide pad and pressure to clean or
"brighten" the metal. Costs and Savings: Capital Investment: $3,250. Annual Savings:
September 1995 71 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
$7,500. Waste Savings/Reduction: 100 percent. Waste Throughput Information: previous
etching bath waste total was 12,000 gallons/year.
Option 7 - Clean copper sheeting mechanically with a rotating brush machine that scrubs
with pumice, instead of cleaning with ammonium persulfate, phosphoric acid, or sulfuric
acid; may generate non-hazardous waste sludge. Costs and Savings: Capital Investment:
$59,000. Annual Savings: more than $15,000. Payback Period: 3 years. Waste
Savings/Reduction: 40,000 pounds of copper etching waste reduced to zero.
Option 8- Reduce molybdenum concentration in wastewaters by using a reverse
osmosis/precipitation system. Costs and Savings: Capital Investment: $320,000. Waste
Throughput Information: permeate capacity of 18,000 gallons per day. Savings Relative to
an Evaporative System: installed capital cost savings: $150,000; annual operating cost
savings: $90,000.
Option 9 - When refining precious metals, reduce the acid/metals waste stream by
maximizing reaction time in the gold and silver extraction process. Costs and Savings:
Capital Investment: $0. Annual Savings: $9,000. Waste Savings/Reduction: 70 percent
(waste total reduced from 50 tons to 15 tons).
Technique - Raw Material Substitution
Option 1 - Change copper bright-dipping process from a cyanide dip and chromic acid dip
to a sulfuric acid/hydrogen peroxide dip. The new bath is less toxic and copper can be
recovered.
Option 2 - Use alcohol instead of sulfuric acid to clean copper wire. One ton of wire
requires 4 liters of alcohol solution, versus 2 kilograms of sulfuric acid. Costs and Savings:
Capital Investment: $0.
Option 3 - Replace caustic wire cleaner with a biodegradable detergent.
Option 4 - Replace chromated desmutting solutions with nonchromated solutions for
alkaline etch cleaning of wrought aluminum. Costs and Savings: Annual Savings: $44,541.
Waste Savings/Reduction: sludge disposal costs reduced by 50 percent.
Option 5 - Replace barium and cyanide salt heat treating with a carbonate/chloride carbon
mixture, or with furnace heat treating.
Option 6 - Replace thermal treatment of metals with condensation of saturated chlorite
vapors on the surface to be heated. Costs and Savings: Waste Savings/Reduction: this
process is fast, nonoxidizing, and uniform; pickling is no longer necessary.
Technique - Recycling
Option 1 - Sell waste pickling acids as feedstock for fertilizer manufacture or
neutralization/precipitation.
Option 2 - Recover metals from solutions for resale. Costs and Savings: Annual Savings:
$22,000. Payback Period: 14 months. Company sells copper recovered from a bright-dip
bath regeneration process employing ion exchange and electrolytic recovery.
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Fabricated Metal Products Sector Notebook Project
Option 3 - Send used copper pickling baths to a continuous electrolysis process for
regeneration and copper recovery. Costs and Savings: Capital Investment: $28,500(1977).
Product Throughput Information: pickling 12,000 tons of copper; copper recovery is at the
rate of 200 gallons/ton of processed copper.
Option 4 - Recover copper from brass bright dipping solutions using a commercially
available ion exchange system. Costs and Savings: Annual Savings: $17,047; based on
labor savings, coppers sulfate elimination, sludge reduction, copper metal savings, and
bright dip chemicals savings. Product Throughput Information: example facility processes
approximately 225,000 pounds of brass per month.
Option 5 - Treat industrial wastewater high in soluble iron and heavy metals by chemical
precipitation. Costs and Savings: Annual Savings: $28,000; based on reduced water and
sewer rates. Waste Throughput Information: wastewater flow from facility's "patening"
line is 100 gallons per minute.
Option 6 - Oil quench baths may be recycled on site by filtering out the metals.
Option 7 - Alkaline wash life can be extended by skimming the layer of oil (the skimmed oil
may be reclaimed).
V.D.3. Plating Operations
Technique - Training and Supervision
Option 1 - Educate plating shop personnel in the conservation of water during processing
and in material segregation.
Technique - Production Planning and Sequencing
Option 1 - Preinspect parts to prevent processing of obvious rejects.
Technique - Process or Equipment Modification
Option 1 - Modify rinsing methods to control drag-out by:
• Increasing bath temperature
• Decreasing withdrawal rate of parts from plating bath
• Increasing drip time over solution tanks; racking parts to avoid cupping solution within
part cavities
• Shaking, vibrating, or passing the parts through an air knife, angling drain boards
between tanks
• Using wetting agents to decrease surface tension in tank.
Contact: Braun Intertec Environmental, Inc., and MN Office of Waste Management
(612) 649-5750.
Option 2 - Utilize water conservation methods including:
• Flow restrictors on flowing rinses
• Counter current rinsing systems
• Fog or spray rinsing
• Reactive rinsing
• Purified or softened water
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Fabricated Metal Products Sector Notebook Project
• Dead rinses
• Conductivity controllers
• Agitation to assure adequate rinsing and homogeneity in rinse tank
• Flow control valves.
Contact: Braun Intertec Environmental, Inc., and MN Office of Waste Management
(612) 649-5750.
Option 3 - Implement counter flow rinsing and cascade rinsing systems to conserve
consumption of water. Costs and Savings: Costs: S75,000 to upgrade existing equipment
and purchasing new and used equipment. Waste Savings/Reduction: reduce water use
and wastewater treatment costs. Contact: Eastside Plating and OR Department of
Environmental Quality (800)452-4011.
Option 4 - Use drip bars to reduce drag-out. Costs and Savings: Capital Investment: SI00
per tank. Savings: $600. Contact: NC Department of Natural Resources & Community
Development, Gary Hunt (919) 733-7015.
Option 5 - Use drain boards between tanks to reduce generations of drag-out. Costs and
Savings: Capital Investment: $25 per tank. Savings: $450. Contact: NC Department of
Natural Resources & Community Development, Gary Hunt (919) 733-7015.
Option 6 - Install racking to reduce generations of drag-out. Costs and Savings: Capital
Investment: zero dollars. Operating Costs: minimal. Savings: $600. Contact: NC
Department of Natural Resources & Community Development, Gary Hunt (919) 733-7015.
Option 7 - Employ drag out recovery tanks to reduce generations of drag-out. Costs and
Savings: Capital Investment: $500 per tank. Savings: $4,700. Contact: NC Department of
Natural Resources & Community Development, Gary Hunt (919) 733-7015.
Option 8 - Install counter-current rinsing operation to reduce water consumption. Costs
and Savings: Capital Investment: $1,800-2,300. Savings: $1,350 per year. Waste
Savings/Reductions: reduce water use by 90-99 percent. Contact: NC Department of
Natural Resources & Community Development, Gary Hunt (919) 733-7015.
Option 9 - Redesign rinse tank to reduce water conservation. Costs and Savings: Capital
Investment: $100. Savings: $750 per year. Contact: NC Department of Natural Resources
& Community Development, Gary Hunt (919) 733-7015.
Option 10 - Increase parts drainage time to reduce drag-out. Contact: City of Los Angeles
Hazardous and Toxic Material Project, Board of Public Works (213) 237-1209.
Option 11 - Regenerate plating bath by activated carbon filtration to remove built up
organic contaminants. Costs and Savings: Capital Investment: $9,192. Costs: $7,973.
Savings: $122,420. Waste Savings/Reduction: 10,800 gallons. Reduce volume of plating
baths disposed and requirements for virgin chemicals. Contact: EPA Hazardous Waste
Engineering Research Laboratory, Cincinnati, OH, Harry Freeman.
Option 12 - Install pH controller to reduce the alkaline and acid concentrations in tanks.
Contact: Securus, Inc., and DBA Hubbard Enterprises.
Option 13 - Install atmospheric evaporator to reduce metal concentrations. Contact:
Securus, Inc., and DBA Hubbard Enterprises.
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Fabricated Metal Products Sector Notebook Project
Option 14 - Install process (e.g., CALFRAN) to reduce pressure to vaporize water at cooler
temperatures and recycle water by condensing the vapors in another container, thus
concentrating and precipitating solutes out. Costs and Savings: Waste Savings/Reduction:
reduce volume and quantity of aqueous waste solutions by recovering pure water. Contact:
CALFRAN International, Inc., (413) 525-4957.
Option 15 - Use reactive rinsing and multiple drag-out baths. Costs and Savings: Savings:
Reduce cost of treating spent process baths and rinse waters. Waste Savings/Reduction:
increase lifetime of process baths and reduce the quantity or rinse water requiring
treatment. Contact: SAIC, Edward R. Saltzberg.
Option 16 - Improve control of water level in rinse tanks, improve sludge separation, and
enhance recycling of supernatant to the process by aerating the sludge. Costs and Savings:
Savings: S2,000. Waste Savings/Reduction: reduce sludge generation by 32 percent.
Contact: NJ Hazardous Waste Facilities Siting Commission, Hazardous Waste Source
Reduction and Recycling Task Force.
Option 17 - Install system (e.g., Low Solids Fluxer) that applies flux to printed wiring
boards, leaving little residue and eliminates the need for cleaning CFCs. Costs and Savings:
Waste Savings/Reduction: reduce CFC emissions over 50 percent. Contact: AT&T Bell
Laboratories, Princeton, NJ.
Technique - Raw Material Substitution
Option 1 - Substitute cyanide plating solutions with alkaline zinc, acid zinc, acid sulfate
copper, pyrophosphate copper, alkaline copper, copper fluoborate, electroless nickel,
ammonium silver, halide silver, methanesulfonate-potassium iodide silver, amino or thio
complex silver, no free cyanide silver, cadmium chloride, cadmium sulfate, cadmium
fluoborate, cadmium perchlorate, gold sulfite, and cobalt harden gold. Contact: Braun
Intertec Environmental Inc., and MN Office of Waste Management (612) 649-5750.
Option 2 - Substitute sodium bisulfite and sulfuric acid for ferrous sulfate in order to
oxidize chromic acid wastes, and substitute gaseous chlorine for liquid chlorine in order to
reduce cyanide reduction. Costs and Savings: Savings: $300,000 per year. Waste
Savings/Reduction: reduces feedstock by 50 percent. Contact: Eastside Plating and OR
Department of Environmental Quality (800) 452-4011.
Option 3 - Replace hexavalent chromium with trivalent chromium plating systems.
Contact: City of Los Angeles Hazardous and Toxic Material Project. Board of Public Works
(213) 237-1209.
Option 4 - Replace cyanide with non-cyanide baths. Contact: City of Los Angeles
Hazardous and Toxic Material Project, Board of Public Works (213) 237-1209.
Option 5 - Replace conventional chelating agents such as tartarates, phosphates, EDTA, and
ammonia with sodium sulfides and iron sulfates in removing metal from rinse water which
reduces the amount of waste generated from precipitation of metals from aqueous
wastestreams. Costs and Savings: Costs: $178,830 per year. Savings: $382,995 per year.
Waste Savings/Reduction: 496 tons of sludge per year. Contact: Tyndall Air Force Base,
FL, (904) 283-2942, Charles Carpenter, Dan Sucia, Penny Wilcoff; and John Beller at EG&G
(108) 526-1149.
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Fabricated Metal Products Sector Notebook Project
Option 6 - Replace methylene chloride, 1,1,1-trichloroethane, and perchloroethylene
(solvent-based photochemical coatings) with aqueous base coating of 1 percent sodium
carbonate. Costs and Savings: Waste Savings/Reduction: reduce solvent use by 60 tons
per year. Contact: American Etching and Manufacturing, Pacoima, CA.
Option 7 - Replace methanol with nonflammable alkaline cleaners. Costs and Savings:
Waste Savings/Reduction: eliminate 32 tons per year of flammable methyl alcohol.
Contact: American Etching and Manufacturing, Pacoima, CA.
Option 8 - Substitute a non-cyanide for a sodium cyanide solution used in copper plating
baths. Costs and Savings: Waste Savings/Reduction: reduce 7,630 pounds per year.
Contact: Highland Plating Company, Los Angeles, CA.
Technique - Waste Segregation and Separation
Option 1 - Wastewaters containing recoverable metals should be segregated from other
wastewater streams.
Technique - Recycling
Option 1 - Install ion exchange system to reduce generation of drag-out. Costs and
Savings: Capital Investment: $78,000. Operating Costs: S3,200 per year. Contact: NC
Department of Natural Resources & Community Development; Gary Hunt (919) 733-7015.
Option 2 - Employ reverse osmosis system to reduce generation of drag-out. Costs and
Savings: Savings: S40,000 per year. Capital Investment: $62,000. Contact: NC
Department of Natural Resources & Community Development; Gary Hunt (919) 733-7015.
Option 3 - Use electrolytic metal recovery to reduce generation of drag-out. Costs and
Savings: Capital Investment: $1,000. Contact: NC Department of Natural Resources &
Community Development; Gary Hunt (919) 733-7015.
Option 4 - Utilize electrodialysis to reduce generation of drag-out. Costs and Savings:
Capital Investment: $50,000. Contact: NC Department of Natural Resources & Community
Development; Pollution Prevention Pays Program Gary Hunt (919) 733-7015.
Option 5 - Implement evaporative recovery to reduce generation of drag-out. Costs and
Savings: Capital Investment: $2,500. Contact: NC Department of Natural Resources &
Community Development; Gary Hunt (919) 733-7015.
Option 6-Reuse rinse water. Costs and Savings: Savings: $1,500 per year. Capital
Investment: $340 per tank. No direct costs. Contact: NC Department of Natural Resources
& Community Development; Gary Hunt (919) 733-7015.
Option 7- Reuse drag-out waste back into process tank. Contact: NC Department of
Natural Resources & Community Development; Gary Hunt (919) 733-7015.
Option 8- Recover process chemicals with fog rinsing parts over plating bath. Contact:
City of Los Angeles Hazardous and Toxic Material Project, Board of Public Works (213) 237-
1209.
Option 9- Evaporate and concentrate rinse baths for recycling. Contact: City of Los
Angeles Hazardous and Toxic Material Project, Board of Public Works (213) 237-1209.
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Fabricated Metal Products Sector Notebook Project
Option 10 - Use ion exchange and electrowinning, reverse osmosis, and thermal bonding
when possible. Contact: City of Los Angeles Hazardous and Toxic Material Project, Board
of Public Works (213) 237-1209.
Option 11 - Use sludge slagging techniques to extract and recycle metals. Costs and
Savings: Capital Investment: $80,000 for 80 tons/year and $400,000 for 1,000 tons/year.
Operating Costs: SI8,000 per year for an 80 ton facility. Waste Savings/Reduction: reduces
volume of waste by 94 percent. Contact: City of Los Angeles Hazardous and Toxic
Material Project, Board of Public Works (213) 237-1209.
Option 12 - Use hydrometallurgical processes to extract metals from sludge. Contact: City
of Los Angeles Hazardous and Toxic Material Project, Board of Public Works (213) 237-1209.
Option 13- Convert sludge to smelter feed. Contact: City of Los Angeles Hazardous and
Toxic Material Project, Board of Public Works (213) 237-1209.
Option 14- Remove and recover lead and tin from boards by electrolysis or chemical
precipitation. Contact: Control Data Corporation and MN Office of Waste Management
(612) 649-5750.
Option 15 - Install a closed loop batch treatment system for rinse water to reduce water use
and waste volume. Costs and Savings: Savings: $58,460 per year. Capital Investment:
$210,000. Waste Savings/Reduction: 40,000 gallons per year (40 percent). Contact: Pioneer
Metal Finishing, Inc., Harry Desoi (609) 694-0400.
Option 16 - Install an electrolytic cell which recovers 92 percent of dissolved copper in drag-
out rinses and atmospheric evaporator to recover 95 percent of chromatic acid drag-out, and
recycle it into chromic acid etch line. Contact: Digital Equipment Corporation and Lancy
International Consulting Firm, William McLay (412) 452-9360.
Option 17 - Implement the electrodialysis reversal process for metal salts in wastewater.
Costs and Savings: Savings: $40,100 per year in operating costs. Contact: Ionics, Inc.,
Separations Technology Division.
Option 18 - Oxidize cyanide and remove metallic copper to reduce metal concentrations.
Contact: Securus, Inc. and DBA Hubbard Enterprises.
V.D.4. Other Finishing Operations
FINISHING OPERATIONS
Technique - Training and Supervision
Option 1 - Always use proper spraying techniques.
Option 2 - Improved paint quality, work efficiency, and lower vapor emissions can be
attained by formal training of operators.
Option 3 - Avoid buying excess finishing material at one time due to its short shelf-life.
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Technique - Production Planing and Sequencing
Option 1 - Use the correct spray gun for particular applications:
• conventional air spray gun for thin-film-build requirements
• airless gun for heavy film application
• air assisted airless spray gun for a wide range of fluid output.
Option 2 - Preinspect parts to prevent painting of obvious rejects.
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Fabricated Metal Products Sector Notebook Project
Technique - Process or Equipment Modification
Option 1 - Ensure the spray gun air supply is free of water, oil, and dirt.
Option 2 - Replace galvanizing processes requiring high temperature and flux with one that
is low temperature and does not require flux. Costs and Savings: Capital Investment:
$900,000. Annual Savings: 50 percent ( as compared to conventional galvanizing). Product
Throughput Information: 1,000 kg/h.
Option 3 - Investigate use of transfer methods that reduce material loss such as:
• dip and flow coating
• electrostatic spraying
• electrodeposition.
Option 4 - Change from conventional air spray to an electrostatic finishing system. Costs
and Savings: SI5,000 per year. Payback Period: less than 2 years.
Option 5 - Use solvent recovery or incineration to reduce the emissions of volatile organics
from curing ovens. Costs and Savings: Annual Savings: $400,000.
Option 6 - Regenerate anodizing and alkaline silking baths with contemporary recuperation
of aluminum salts. Costs and Savings: SO.20 per meter of aluminum treated per year.
Waste Throughput Information: based on an example plant that previously disposed
180,000 liters of acid solution per year at SO.07 per litre.
Technique - Raw Material Substitution
Option 1 - Use alternative coatings for solvent based paints to reduce volatile organic
materials use and emissions, such as:
• high solids coatings (this may require modifying the painting process; including high
speed/high pressure equipment, a paint distributing system, and paint heaters); Costs
and Savings: Waste Savings/Reduction: 30 percent net savings in applied costs per
square foot.
• water based coatings - Costs and Savings: Waste Savings/Reduction: 87 percent drop
in solvent emissions and decreased hazardous waste production;
• powder coatings - Costs and Savings: Capital Investment: SI.5 million. Payback
Period: 2 years. Example is for a large, wrought iron patio furniture company.
Technique - Waste Segregation and Separation
Option 1 - Segregate non-hazardous paint solids from hazardous paint solvents and
thinner s.
Technique - Recycling
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Fabricated Metal Products Sector Notebook Project
Option 1 - Do not dispose of extended shelf life items that do not meet your facility's
specifications. They may be returned to the manufacturer, or sold or donated as a raw
material.
Option 2 - Recycle metal sludges through metal recovery vendors.
Option 3 - Use activated carbon to recover solvent vapors, then recover the solvent from the
carbon by steam stripping, and distill the resulting water/solvent mixture. Costs and
Savings: Capital Investment: $817,000(1978). Waste Savings/Reduction: releases of
solvent to the atmosphere were reduced from 700 kg/ton of solvent used to 20 kg/ton.
Option 4 - Regenerate caustic soda etch solution for aluminum by using hydrolysis of
sodium aluminate to liberate free sodium hydroxide and produce a dry, crystalline hydrate
alumina byproduct. Costs and Savings: Capital Investment: $260,000. Savings: $169,282
per year; from reduced caustic soda use, income from the sale of the byproduct, and a
reduction in the cost of solid waste disposal. Payback Period: 1.54 years. Product/Waste
Throughput Information: anodizing operation for which the surface area is processed at a
rate of 200 M2/hour.
PAINT CLEANUP
Technique - Production Planning and Sequencing
Option 1 - Reduce equipment cleaning by painting with lighter colors before darker ones.
Option 2 - Reuse cleaning solvents for the same resin system by first allowing solids to settle
out of solution.
Option 3 - Flush equipment first with dirty solvent before final cleaning with virgin solvent.
Costs and Savings: Waste Savings/Reduction: 98 percent; from 25,000 gallons of paint
cleanup solvents to 400 gallons. Company uses cleanup solvents in formulation of
subsequent batches.
Option 4 - Use virgin solvents for final equipment cleaning, then as paint thinner.
Option 5 - Use pressurized air mixed with a mist of solvent to clean equipment.
Technique - Raw Material Substitution
Option 1 - Replace water-based paint booth filters with dry filters. Dry filters will double
paint booth life and allow more efficient treatment of wastewater. Costs and Savings:
Savings per year: $1,500. Waste Savings/Reduction: 3,000 gallons/year.
Technique - Loss Prevention and Housekeeping
Option 1 - To prevent spray gun leakage, submerge only the front end (or fluid control) of
the gun into the cleaning solvent.
Technique - Waste Segregation and Separation
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Fabricated Metal Products Sector Notebook Project
Option 1 - Solvent waste streams should be kept segregated and free from water
contamination.
Technique - Recycling
Option 1 - Solvent recovery units can be used to recycle spent solvents generated in flushing
operations.
• Install a recovery system for solvents contained in air emissions. Costs and Savings:
Savings: SI,000 per year.
• Use batch distillation to recover isopropyl acetate generated during equipment
cleanup. Costs and Savings: Payback Period: 2 years.
• Use batch distillation to recover xylene from paint equipment cleanup. Costs and
Savings: Payback Period: 13 months. Savings: $5,000 per year.
• Use a small solvent recovery still to recover spent paint thinner from spray gun
cleanups and excess paint batches. Costs and Savings: Capital Investment: $6,000 for
a 15 gallons capacity still. Savings: S3,600 per year in new thinner savings; S5,400 in
disposal savings. Payback Period: less than 1 year. Waste Savings/Reduction: 75
percent (745 gallons of thinner recovered from 1,003 gallons). Product/Waste
Throughput Information: 1,500 gallons of spent thinner processed per year.
• Install a methyl ethyl ketone solvent recovery system to recover and reuse waste
solvents. Costs and Savings: Savings: $43,000 per year; MEK recovery rate: 20
gallons per day, reflecting a 90 percent reduction in waste.
Option 2 - Arrange an agreement with other small companies to jointly recycle cleaning
wastes.
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Sector Notebook Project
V.E. Pollution Prevention Contacts
Organization
Braun Intertec Environmental, Inc.
Minnesota Office of Waste Management
Eastside Plating
Oregon Department of Environmental
Quality
North Carolina Department of Natural
Resources & Community Development
(Gary Hunt)
City of Los Angeles Hazardous and Toxic
Material Project, Board of Public Works
EPA Hazardous Waste Engineering
Research Laboratory, Cincinnati, OH
(Harry Freeman)
Securus, Inc.
DBA Hubbard Enterprises
Technique (s) to Promote Pollution Telephone
Prevention Plating Operations Number
Process or Equipment Modification (612) 649-5750
Raw Material Substitution
Process or Equipment Modification (800) 452-4011
Raw Material Substitution
Process or Equipment Modification (919) 733-7015
Recycling
Process or Equipment Modification (213) 237-1209
Raw Material Substitution
Recycling
Process or Equipment Modification
Process or Equipment Modification
Recycling
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September 1995
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Sector Notebook Project
Organization
CALFRAN International, Inc.
SAIC (Edward R. Saltzberg)
New Jersey Hazardous Waste Facilities
Siting Commission, Hazardous Waste
Source Reduction and Recycling Task
Force
AT&T Bell Laboratories, Princeton, NJ
Tyndall Air Force Base (Charles Carpenter)
EG&G Idaho (Dan Sucia, Penny Wilcoff,
John Beller)
American Etching and Manufacturing,
Pacoima, CA
Highland Plating Company, Los Angeles,
CA
Control Data Corporation
Minnesota Office of Waste Management
Pioneer Metal Finishing, Inc. (Harry Desoi)
Digital Equipment Corporation
Lancy International Consulting Firm
(William McLay)
Ionics, Inc., Separations Technology
Division
Technique (s) to Promote Pollution Telephone
Prevention Plating Operations Number
Process or Equipment Modification (413) 525-4957
Process or Equipment Modification
Process or Equipment Modification
Process or Equipment Modification
Raw Material Substitution
Raw Material Substitution
Raw Material Substitution
Recycling
Recycling
Recycling
Recycling
(904) 283-2942
(208) 526-1149
(612) 649-5750
(609) 694-0400
(412) 452-9360
September 1995
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VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS
This section discusses the Federal statutes and regulations that may
apply to this sector. The purpose of this section is to highlight, and
briefly describe the applicable Federal requirements, and to provide
citations for more detailed information. The three following sections
are included.
• Section IV. A contains a general overview of major statutes
• Section IV.B contains a list of regulations specific to this
industry
• Section IV.C contains a list of pending and proposed
regulations
The descriptions within Section IV are intended solely for general
information. Depending upon the nature or scope of the activities at a
particular facility, these summaries may or may not necessarily
describe all applicable environmental requirements. Moreover, they
do not constitute formal interpretations or clarifications of the statutes
and regulations. For further information, readers should consult the
Code of Federal Regulations and other state or local regulatory
agencies. EPA Hotline contacts are also provided for each major
statute.
VI.A. General Description of Major Statutes
Resource Conservation And Recovery Act
The Resource Conservation And Recovery Act (RCRA) of 1976 which
amended the Solid Waste Disposal Act, addresses solid (Subtitle D)
and hazardous (Subtitle C) waste management activities. The
Hazardous and Solid Waste Amendments (HSWA) of 1984
strengthened RCRA's waste management provisions and added
Subtitle I, which governs underground storage tanks (USTs).
Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR
Parts 260-299) establish a "cradle-to-grave" system governing
hazardous waste from the point of generation to disposal. RCRA
hazardous wastes include the specific materials listed in the
regulations (commercial chemical products, designated with the code
"P" or "U"; hazardous wastes from specific industries/sources,
designated with the code "K"; or hazardous wastes from non-specific
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Fabricated Metal Products Sector Notebook Project
sources, designated with the code "F") or materials which exhibit a
hazardous waste characteristic (ignitibility, corrosivity, reactivity, or
toxicity and designated with the code "D").
Regulated entities that generate hazardous waste are subject to waste
accumulation, manifesting, and recordkeeping standards. Facilities
that treat, store, or dispose of hazardous waste must obtain a permit,
either from EPA or from a State agency which EPA has authorized to
implement the permitting program. Subtitle C permits contain general
facility standards such as contingency plans, emergency procedures,
recordkeeping and reporting requirements, financial assurance
mechanisms, and unit-specific standards. RCRA also contains
provisions (40 CFR Part 264 Subpart S and §264.10) for conducting
corrective actions which govern the cleanup of releases of hazardous
waste or constituents from solid waste management units at RCRA-
regulated facilities.
Although RCRA is a Federal statute, many States implement the
RCRA program. Currently, EPA has delegated its authority to
implement various provisions of RCRA to 46 of the 50 States.
Most RCRA requirements are not industry specific but apply to any
company that transports, treats, stores, or disposes of hazardous
waste. Here are some important RCRA regulatory requirements:
• Identification of Solid and Hazardous Wastes (40 CFR Part
261) lays out the procedure every generator should follow to
determine whether the material created is considered a
hazardous waste, solid waste, or is exempted from regulation.
• Standards for Generators of Hazardous Waste (40 CFR Part
262) establishes the responsibilities of hazardous waste
generators including obtaining an ID number, preparing a
manifest, ensuring proper packaging and labeling, meeting
standards for waste accumulation units, and recordkeeping and
reporting requirements. Generators can accumulate hazardous
waste for up to 90 days (or 180 days depending on the amount
of waste generated) without obtaining a permit.
• Land Disposal Restrictions (LDRs) are regulations prohibiting
the disposal of hazardous waste on land without prior
treatment. Under the LDRs (40 CFR 268), materials must meet
land disposal restriction (LDR) treatment standards prior to
placement in a RCRA land disposal unit (landfill, land
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treatment unit, waste pile, or surface impoundment). Wastes
subject to the LDRs include solvents, electroplating wastes,
heavy metals, and acids. Generators of waste subject to the
LDRs must provide notification of such to the designated TSD
facility to ensure proper treatment prior to disposal.
• Used Oil Management Standards (40 CFR Part 279) impose
management requirements affecting the storage, transportation,
burning, processing, and re-refining of the used oil. For parties
that merely generate used oil, regulations establish storage
standards. For a party considered a used oil marketer (one who
generates and sells off-specification used oil directly to a used
oil burner), additional tracking and paperwork requirements
must be satisfied.
• Tanks and Containers used to store hazardous waste with a
high volatile organic concentration must meet emission
standards under RCRA. Regulations (40 CFR Part 264-265,
Subpart CC) require generators to test the waste to determine
the concentration of the waste, to satisfy tank and container
emissions standards, and to inspect and monitor regulated
units. These regulations apply to all facilities who store such
waste, including generators operating under the 90-day
accumulation rule.
• Underground Storage Tanks (USTs) containing petroleum and
hazardous substance are regulated under Subtitle I of RCRA.
Subtitle I regulations (40 CFR Part 280) contain tank design and
release detection requirements, as well as financial
responsibility and corrective action standards for USTs. The
UST program also establishes increasingly stringent standards,
including upgrade requirements for existing tanks, that must be
met by 1998.
• Boilers and Industrial Furnaces (BIFs) that use or burn fuel
containing hazardous waste must comply with strict design and
operating standards. BIF regulations (40 CFR Part 266, Subpart
H) address unit design, provide performance standards, require
emissions monitoring, and restrict the type of waste that may be
burned.
EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds to
questions and distributes guidance regarding all RCRA regulations. The
RCRA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., EST,
excluding Federal holidays.
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Comprehensive Environmental Response, Compensation, And Liability Act
The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), a 1980 law commonly known as Superfund,
authorizes EPA to respond to releases, or threatened releases, of
hazardous substances that may endanger public health, welfare, or the
environment. CERCLA also enables EPA to force parties responsible
for environmental contamination to clean it up or to reimburse the
Superfund for response costs incurred by EPA. The Superfund
Amendments and Reauthorization Act (SARA) of 1986 revised various
sections of CERCLA, extended the taxing authority for the Superfund,
and created a free-standing law, SARA Title III, also known as the
Emergency Planning and Community Right-to-Know Act (EPCRA).
The CERCLA hazardous substance release reporting regulations (40
CFR Part 302) direct the person in charge of a facility to report to the
National Response Center (NRC) any environmental release of a
hazardous substance which exceeds a reportable quantity. Reportable
quantities are defined and listed in 40 CFR § 302.4. A release report
may trigger a response by EPA, or by one or more Federal or State
emergency response authorities.
EPA implements hazardous substance responses according to
procedures outlined in the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) (40 CFR Part 300). The NCP
includes provisions for permanent cleanups, known as remedial
actions, and other cleanups referred to as "removals." EPA generally
takes remedial actions only at sites on the National Priorities List
(NPL), which currently includes approximately 1300 sites. Both EPA
and states can act at other sites; however, EPA provides responsible
parties the opportunity to conduct removal and remedial actions and
encourages community involvement throughout the Superfund
response process.
EPA 'sRCRA/Superfund/UST Hotline, at (800) 424-9346, answers questions
and references guidance pertaining to the Superfund program. The CERCLA
Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., EST, excluding
Federal holidays.
Emergency Planning And Community Right-To-Know Act
The Superfund Amendments and Reauthorization Act (SARA) of 1986
created the Emergency Planning and Community Right-to-Know Act
(EPCRA, also known as SARA Title III), a statute designed to improve
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community access to information about chemical hazards and to
facilitate the development of chemical emergency response plans by
State and local governments. EPCRA required the establishment of
State emergency response commissions (SERCs), responsible for
coordinating certain emergency response activities and for appointing
local emergency planning committees (LEPCs).
EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish
four types of reporting obligations for facilities which store or manage
specified chemicals:
EPCRA §302 requires facilities to notify the SERC and LEPC of
the presence of any "extremely hazardous substance" (the list of
such substances is in 40 CFR Part 355, Appendices A and B) if it
has such substance in excess of the substance's threshold
planning quantity, and directs the facility to appoint an
emergency response coordinator.
EPCRA §304 requires the facility to notify the SERC and the
LEPC in the event of a release exceeding the reportable quantity
of a CERCLA hazardous substance or an EPCRA extremely
hazardous substance.
• EPCRA §§311 and 312 require a facility at which a hazardous
chemical, as defined by the Occupational Safety and Health Act,
is present in an amount exceeding a specified threshold to
submit to the SERC, LEPC, and local fire department material
safety data sheets (MSDSs) or lists of MSDSs and hazardous
chemical inventory forms (also known as Tier I and II forms).
This information helps the local government respond in the
event of a spill or release of the chemical.
• EPCRA §313 requires manufacturing facilities included in SIC
codes 20 through 39, which have ten or more employees, and
which manufacture, process, or use specified chemicals in
amounts greater than threshold quantities, to submit an annual
toxic chemical release report. This report, commonly known as
the Form R, covers releases and transfers of toxic chemicals to
various facilities and environmental media, and allows EPA to
compile the national Toxic Release Inventory (TRI) database.
All information submitted pursuant to EPCRA regulations is publicly
accessible, unless protected by a trade secret claim.
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EPA's EPCRA Hotline, at (800) 535-0202, answers questions and distributes
guidance regarding the emergency planning and community right-to-know
regulations. The EPCRA Hotline operates weekdays from 8:30 a.m. to 7:30
p.m., EST, excluding Federal holidays.
Clean Water Act
The primary objective of the Federal Water Pollution Control Act,
commonly referred to as the Clean Water Act (CWA), is to restore and
maintain the chemical, physical, and biological integrity of the nation's
surface waters. Pollutants regulated under the CWA include
"priority" pollutants, including various toxic pollutants; "conventional"
pollutants, such as biochemical oxygen demand (BOD), total
suspended solids (TSS), fecal coliform, oil and grease, and pH; and
"non-conventional" pollutants, including any pollutant not identified
as either conventional or priority.
The CWA regulates both direct and indirect discharges. The National
Pollutant Discharge Elimination System (NPDES) program (CWA
§402) controls direct discharges into navigable waters. Direct
discharges or "point source" discharges are from sources such as pipes
and sewers. NPDES permits, issued by either EPA or an authorized
State (EPA has presently authorized forty States to administer the
NPDES program), contain industry-specific, technology-based and/or
water quality-based limits, and establish pollutant monitoring and
reporting requirements. A facility that intends to discharge into the
nation's waters must obtain a permit prior to initiating its discharge.
A permit applicant must provide quantitative analytical data
identifying the types of pollutants present in the facility's effluent.
The permit will then set forth the conditions and effluent limitations
under which a facility may make a discharge.
A NPDES permit may also include discharge limits based on Federal
or State water quality criteria or standards, that were designed to
protect designated uses of surface waters, such as supporting aquatic
life or recreation. These standards, unlike the technological standards,
generally do not take into account technological feasibility or costs.
Water quality criteria and standards vary from State to State, and site
to site, depending on the use classification of the receiving body of
water. Most States follow EPA guidelines which propose aquatic life
and human health criteria for many of the 126 priority pollutants.
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Storm Water Discharges
In 1987 the CWA was amended to require EPA to establish a program
to address storm water discharges. In response, EPA promulgated the
NPDES storm water permit application regulations. Storm water
discharge associated with industrial activity means the discharge from
any conveyance which is used for collecting and conveying storm
water and which is directly related to manufacturing, processing or
raw materials storage areas at an industrial plant (40 CFR
122.26(b)(14)). These regulations require that facilities with the
following storm water discharges apply for a NPDES permit: (1) a
discharge associated with industrial activity; (2) a discharge from a
large or medium municipal storm sewer system; or (3) a discharge
which EPA or the State determines to contribute to a violation of a
water quality standard or is a significant contributor of pollutants to
waters of the United States.
The term "storm water discharge associated with industrial activity"
means a storm water discharge from one of 11 categories of industrial
activity defined at 40 CFR 122.26. Six of the categories are defined by
SIC codes while the other five are identified through narrative
descriptions of the regulated industrial activity. If the primary SIC
code of the facility is one of those identified in the regulations, the
facility is subject to the storm water permit application requirements.
If any activity at a facility is covered by one of the five narrative
categories, storm water discharges from those areas where the
activities occur are subject to storm water discharge permit application
requirements.
Those facilities/activities that are subject to storm water discharge
permit application requirements are identified below. To determine
whether a particular facility falls within one of these categories, the
regulation should be consulted.
Category i: Facilities subject to storm water effluent guidelines, new
source performance standards, or toxic pollutant effluent standards.
Category ii: Facilities classified as SIC 24-lumber and wood products
(except wood kitchen cabinets); SIC 26-paper and allied products
(except paperboard containers and products); SIC 28-chemicals and
allied products (except drugs and paints); SIC 29-petroleum refining;
and SIC 311-leather tanning and finishing.
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Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal
mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral
mining.
Category iv: Hazardous waste treatment, storage, or disposal
facilities.
Category v: Landfills, land application sites, and open dumps that
receive or have received industrial wastes.
Category vi: Facilities classified as SIC 5015-used motor vehicle parts;
and SIC 5093-automotive scrap and waste material recycling facilities.
Category vii: Steam electric power generating facilities.
Category viii: Facilities classified as SIC 40-railroad transportation;
SIC 41-local passenger transportation; SIC 42-trucking and
warehousing (except public warehousing and storage); SIC 43-U.S.
Postal Service; SIC 44-water transportation; SIC 45-transportation by
air; and SIC 5171-petroleum bulk storage stations and terminals.
Category ix: Sewage treatment works.
Category x: Construction activities except operations that result in the
disturbance of less than five acres of total land area.
Category xi: Facilities classified as SIC 20-food and kindred products;
SIC 21-tobacco products; SIC 22-textile mill products; SIC 23-apparel
related products; SIC 2434-wood kitchen cabinets manufacturing; SIC
25-furniture and fixtures; SIC 265-paperboard containers and boxes;
SIC 267-converted paper and paperboard products; SIC 27-printing,
publishing, and allied industries; SIC 283-drugs; SIC 285-paints,
varnishes, lacquer, enamels, and allied products; SIC 30-rubber and
plastics; SIC 31-leather and leather products (except leather and
tanning and finishing); SIC 323-glass products; SIC 34-fabricated metal
products (except fabricated structural metal); SIC 35-industrial and
commercial machinery and computer equipment; SIC 36-electronic
and other electrical equipment and components; SIC 37-transportation
equipment (except ship and boat building and repairing); SIC 38-
measuring, analyzing, and controlling instruments; SIC 39-
miscellaneous manufacturing industries; and SIC 4221-4225-public
warehousing and storage.
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Pretreatment Program
Another type of discharge that is regulated by the CWA is one that
goes to a publicly-owned treatment works (POTWs). The national
pretreatment program (CWA §307(b)) controls the indirect discharge
of pollutants to POTWs by "industrial users." Facilities regulated
under §307 (b) must meet certain pretreatment standards. The goal of
the pretreatment program is to protect municipal wastewater
treatment plants from damage that may occur when hazardous, toxic,
or other wastes are discharged into a sewer system and to protect the
quality of sludge generated by these plants. Discharges to a POTW
are regulated primarily by the POTW itself, rather than the State or
EPA.
EPA has developed technology-based standards for industrial users of
POTWs. Different standards apply to existing and new sources within
each category. "Categorical" pretreatment standards applicable to an
industry on a nationwide basis are developed by EPA. In addition,
another kind of pretreatment standard, "local limits," are developed by
the POTW in order to assist the POTW in achieving the effluent
limitations in its NPDES permit.
Regardless of whether a State is authorized to implement either the
NPDES or the pretreatment program, if it develops its own program, it
may enforce requirements more stringent than Federal standards.
EPA's Office of Water, at (202) 260-5700, will direct callers with questions
about the CWA to the appropriate EPA office. EPA also maintains a
bibliographic database of Office of Water publications which can be accessed
through the Ground Water and Drinking Water resource center, at (202) 260-
7786.
Safe Drinking Water Act
The Safe Drinking Water Act (SDWA) mandates that EPA establish
regulations to protect human health from contaminants in drinking
water. The law authorizes EPA to develop national drinking water
standards and to create a joint Federal-State system to ensure
compliance with these standards. The SDWA also directs EPA to
protect underground sources of drinking water through the control of
underground injection of liquid wastes.
EPA has developed primary and secondary drinking water standards
under its SDWA authority. EPA and authorized States enforce the
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primary drinking water standards, which are, contaminant-specific
concentration limits that apply to certain public drinking water
supplies. Primary drinking water standards consist of maximum
contaminant level goals (MCLGs), which are non-enforceable health-
based goals, and maximum contaminant levels (MCLs), which are
enforceable limits set as close to MCLGs as possible, considering cost
and feasibility of attainment.
The SDWA Underground Injection Control (UIC) program (40 CFR
Parts 144-148) is a permit program which protects underground
sources of drinking water by regulating five classes of injection wells.
UIC permits include design, operating, inspection, and monitoring
requirements. Wells used to inject hazardous wastes must also
comply with RCRA corrective action standards in order to be granted
a RCRA permit, and must meet applicable RCRA land disposal
restrictions standards. The UIC permit program is primarily State-
enforced, since EPA has authorized all but a few States to administer
the program.
The SDWA also provides for a Federally-implemented Sole Source
Aquifer program, which prohibits Federal funds from being expended
on projects that may contaminate the sole or principal source of
drinking water for a given area, and for a State-implemented
Wellhead Protection program, designed to protect drinking water
wells and drinking water recharge areas.
EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers questions
and distributes guidance pertaining to SDWA standards. The Hotline
operates from 9:00 a.m. through 5:30 p.m., EST, excluding Federal holidays.
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) granted EPA authority to
create a regulatory framework to collect data on chemicals in order to
evaluate, assess, mitigate, and control risks which may be posed by
their manufacture, processing, and use. TSCA provides a variety of
control methods to prevent chemicals from posing unreasonable risk.
TSCA standards may apply at any point during a chemical's life cycle.
Under TSCA §5, EPA has established an inventory of chemical
substances. If a chemical is not already on the inventory, and has not
been excluded by TSCA, a premanufacture notice (PMN) must be
submitted to EPA prior to manufacture or import. The PMN must
identify the chemical and provide available information on health and
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environmental effects. If available data are not sufficient to evaluate
the chemical's effects, EPA can impose restrictions pending the
development of information on its health and environmental effects.
EPA can also restrict significant new uses of chemicals based upon
factors such as the projected volume and use of the chemical.
Under TSCA §6, EPA can ban the manufacture or distribution in
commerce, limit the use, require labeling, or place other restrictions on
chemicals that pose unreasonable risks. Among the chemicals EPA
regulates under §6 authority are asbestos, chlorofluorocarbons (CFCs),
and polychlorinated biphenyls (PCBs).
EPA's TSCA Assistance Information Service, at (202) 554-1404, answers
questions and distributes guidance pertaining to Toxic Substances Control
Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., EST,
excluding Federal holidays.
Clean Air Act
The Clean Air Act (CAA) and its amendments, including the Clean Air
Act Amendments (CAAA) of 1990, are designed to "protect and
enhance the nation's air resources so as to promote the public health
and welfare and the productive capacity of the population." The CAA
consists of six sections, known as Titles, which direct EPA to establish
national standards for ambient air quality and for EPA and the States
to implement, maintain, and enforce these standards through a variety
of mechanisms. Under the CAAA, many facilities will be required to
obtain permits for the first time. State and local governments oversee,
manage, and enforce many of the requirements of the CAAA. CAA
regulations appear at 40 CFR Parts 50-99.
Pursuant to Title I of the CAA, EPA has established national ambient
air quality standards (NAAQSs) to limit levels of "criteria pollutants,"
including carbon monoxide, lead, nitrogen dioxide, particulate matter,
ozone, and sulfur dioxide. Geographic areas that meet NAAQSs for a
given pollutant are classified as attainment areas; those that do not
meet NAAQSs are classified as non-attainment areas. Under §110 of
the CAA, each State must develop a State Implementation Plan (SIP) to
identify sources of air pollution and to determine what reductions are
required to meet Federal air quality standards.
Title I also authorizes EPA to establish New Source Performance
Standards (NSPSs), which are nationally uniform emission standards
for new stationary sources falling within particular industrial
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categories. NSPSs are based on the pollution control technology
available to that category of industrial source but allow the affected
industries the flexibility to devise a cost-effective means of reducing
emissions.
Under Title I, EPA establishes and enforces National Emission
Standards for Hazardous Air Pollutants (NESHAPs), nationally
uniform standards oriented towards controlling particular hazardous
air pollutants (HAPs). Title III of the CAAA further directed EPA to
develop a list of sources that emit any of 189 HAPs, and to develop
regulations for these categories of sources. To date EPA has listed 174
categories and developed a schedule for the establishment of emission
standards. The emission standards will be developed for both new
and existing sources based on "maximum achievable control
technology" (MACT). The MACT is defined as the control technology
achieving the maximum degree of reduction in the emission of the
HAPs, taking into account cost and other factors.
Title II of the CAA pertains to mobile sources, such as cars, trucks,
buses, and planes. Reformulated gasoline, automobile pollution
control devices, and vapor recovery nozzles on gas pumps are a few of
the mechanisms EPA uses to regulate mobile air emission sources.
Title IV establishes a sulfur dioxide emissions program designed to
reduce the formation of acid rain. Reduction of sulfur dioxide releases
will be obtained by granting to certain sources limited emissions
allowances, which, beginning in 1995, will be set below previous
levels of sulfur dioxide releases.
Title V of the CAAA of 1990 created a permit program for all "major
sources" (and certain other sources) regulated under the CAA. One
purpose of the operating permit is to include in a single document all
air emissions requirements that apply to a given facility. States are
developing the permit programs in accordance with guidance and
regulations from EPA. Once a State program is approved by EPA,
permits will be issued and monitored by that State.
Title VI is intended to protect stratospheric ozone by phasing out the
manufacture of ozone-depleting chemicals and restrict their use and
distribution. Production of Class I substances, including 15 kinds of
chlorofluorocarbons (CFCs), will be phased out entirely by the year
2000, while certain hydrochlorofluorocarbons (HCFCs) will be phased
out by 2030.
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EPA's Control Technology Center, at (919) 541-0800, provides general
assistance and information on CAA standards. The Stratospheric Ozone
Information Hotline, at (800) 296-1996, provides general information about
regulations promulgated under Title VI of the CAA, and EPA's EPCRA
Hotline, at (800) 535-0202, answers questions about accidental release
prevention under CAA §112(r). In addition, the Technology Transfer
Network Bulletin Board System (modem access (919) 541-5742)) includes
recent CAA rules, EPA guidance documents, and updates of EPA activities.
This section discusses the Federal regulations that may apply to this
sector. The purpose of this section is to highlight, and briefly describe
the applicable Federal requirements so that the reader is aware of
these requirements. The section provides a summary of each major
environmental statute, and a description of regulations that may
specifically apply to the profiled industry. Some profiles also provide
information regarding current rulemaking activity that might
specifically impact this sector. The descriptions within Section VI are
intended solely for guidance. No statutory or regulatory requirements
are in any way altered by any statement(s) contained herein. For more
in-depth information, readers should consult the United States Code
and the Code of Federal Regulations as well as State or local
regulatory agencies. EPA Hotline contacts are also provided for each
major statute.
VLB. Industry Specific Regulations
A number of statutes and regulations affect the metal fabrication and
finishing industry. The electroplating and metal finishing
pretreatment standards promulgated under the Clean Water Act
regulate the chemicals in wastewater, the Clean Air Act regulates air
emissions, and the Resource Conservation and Recovery Act regulates
hazardous waste generation, transportation, treatment, storage, and
disposal. Each is discussed briefly below.
Clean Water Act (CWA)
Two Clean Water Act regulations affect the fabricated metal products
industry (SIC 34): the Effluent Guidelines and Standards for Metal
Finishing (40 CFR Part 433) and the Effluent Guidelines and Standards
for Electroplating (40 CFR Part 413). The regulations targeting the
electroplating industry were issued before those targeting the metal
finishing industry as a whole. Companies regulated by the
electroplating standards (40 CFR Part 413) before the metal finishing
standards (40 CFR Part 433) were promulgated, become subject to the
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requirements of the metal finishing standards when (or if) they make
modifications to their facility's operating functions (e.g., facility,
equipment, process modifications). If companies made no such
modifications, they remain regulated by the electroplating standards.
All new facilities are subject to the standards set forth in 40 CFR
Part 433.
The Effluent Guidelines and Standards for Metal Finishing (40 CFR
Part 433) are applicable to wastewater generated by any of these
operations:
• Electroplating
• Electroless Plating
• Anodizing
• Coating
• Chemical Etching and Milling
• Printed Circuit Board Manufacturing.
If any of the above processes are performed, the metal finishing
standards will also apply to discharges from 40 additional processes,
including: cleaning, polishing, shearing, hot dip coating, solvent
degreasing, painting, etc.
The standards include daily maximums and maximum monthly
average concentration limitations. The standards are based on
milligrams per square meter of operation and determine the amount of
wastewater pollutants from various operations that may be
discharged. The uniformity in standards meets industry requests for
equivalent limits for process lines often found together. The metal
finishing standards also reduce the need to use the Combined
Wastestream Formula.
Specific pretreatment standards may also apply to wastewater
discharges from other metal finishing operations. The more specific
standards will apply to those metal finishing wastestreams which
appear to be covered by both standards. The requirements in the
following regulations take precedence over those contained in the
general metal finishing regulation:
Iron and Steel Manufacturing (40 CFR Part 420)
Battery Manufacturing (40 CFR Part 461)
Plastic Molding and Forming (40 CFR Part 463)
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Coil Coating (40 CFR Part 465)
Porcelain Enameling (40 CFR Part 466)
Aluminum Forming (40 CFR Part 467)
Copper Forming (40 CFR Part 468)
• Electrical and Electronic Components (40 CFR Part 469)
Nonferrous Forming (40 CFR Part 471)
• Lead-Tin-Bismuth Forming Category (40 CFR Part 471,
Subpart A)
• Zinc Forming Subcategory (40 CFR Part 471, Subpart H).
The Effluent Guidelines and Standards for Electroplating (40 CFR
Part 413) cover wastewater dischargers from electroplating operations,
in which metal is electroplated on any basis material, and to related
metal finishing operations. As stated previously, facilities regulated
by the electroplating standards may become subject to the metal
finishing standards if they make modifications to their facility's
operating functions (e.g., facility, equipment, process modifications).
Independent printed circuit board manufacturers are defined as
facilities which manufacture printed circuit boards principally for sale
to other companies. These facilities remain subject only to the
electroplating standards (40 CFR Part 413), primarily to minimize the
economic impact to these relatively small facilities. Also excluded
from the metal finishing regulations are facilities which perform
metallic platemaking and gravure cylinder preparation conducted
within printing and publishing facilities.
Operations similar to electroplating which are specifically exempt
from coverage under the electroplating standards include:
• Continuous strip electroplating conducted within iron and steel
manufacturing facilities (40 CFR Part 420)
• Electrowinning and electrorefining conducted as part of
nonferrous metal smelting and refining (40 CFR Part 421)
• Electrodeposition of active electrode materials,
electroimpregnation, and electroforming conducted as part of
battery manufacturing (40 CFR Part 461)
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• Metal surface preparation and conversion coating conducted as
part of coil coating (40 CFR Part 465)
• Metal surface preparation and immersion plating or electroless
plating conducted as a part of porcelain enameling (40 CFR
Part 466)
• Metallic platemaking and gravure cylinder preparation
conducted within printing and publishing facilities
• Surface treatment including anodizing and conversion coating
conducted as part of aluminum forming (40 CFR Part 467).
Clean Air Act (CAA)
The following standards and requirements promulgated under the
CAA apply to metal finishing processes:
• National Emission Standards for Chromium Emissions From
Hard and Decorative Chromium Electroplating and Chromium
Anodizing Tanks (40 CFR Parts 9 and 63, Subpart N, 60 FR 498,
January 1995)
• Standards of Performance for Surface Coating of Metal
Furniture (40 CFR Part 60, Subpart EE)
• Standards of Performance for Automobile and Light-Duty
Truck Surface Coating Operations (40 CFR Part 60, Subpart
MM)
• Standards of Performance for Industrial Surface Coatings:
Large Appliances (40 CFR Part 60, Subpart SS)
• Standards of Performance for Metal Coil Surface Coating (40
CFR Part 60, Subpart TT)
• Standards of Performance for the Beverage Can Surface Coating
Industry (40 CFR Part 60, Subpart WW)
• Standards of Performance for Industrial Surface Coating:
Surface Coating of Plastic Parts for Business Machines (40 CFR
Part 60, Subpart TTT).
These standards and requirements, although to varying degrees,
regulate the discharge of volatile organic chemicals (VOCs).
September 1995 99 SIC Code 34
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Sector Notebook Project
Resource Conservation and Recovery Act (RCRA)
The greatest quantities of RCRA listed waste and characteristic
hazardous waste present in the fabricated metal products industry are
identified in Exhibit 33. For more information on RCRA hazardous
waste, refer to 40 CFR Part 261.
Exhibit 33
Hazardous Wastes Relevant to the Metal Finishing Industry
EPA Hazardous
Waste No.
Hazardous Waste
D006 (cadmium)
D007 (chromium)
D008 (lead)
D009 (mercury)
DO 10 (selenium)
DO 11 (silver)
Wastes which are hazardous due to the characteristic of toxicity for each of the
constituents.
F001
Halogenated solvents used in degreasing: tetrachloroethylene, methylene
chloride, 1,1,1-trichloroethane, carbon tetrachloride, and chlorinated
fluorocarbons; all spent solvent mixtures/blends used in degreasing
containing, before use, a total of 10 percent or more (by volume) of one or more
of the above halogenated solvents or those solvents listed in F002, F004, and
F005; and still bottoms from the recovery of these spent solvents and spent
solvent mixtures.
F002
Spent halogenated solvents; tetrachloroethylene, methylene chloride,
trichlorethylene, 1,1,1-trichloroethane chlorobenzene, 1,1,2-trichloro-1,2,2-
trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2-
trichloroethane; all spent solvent mixtures/blends containing, before use, one
or more of the above halogenated solvents or those listed in F001, F004, F005;
and still bottoms from the recovery of these spent solvents and spent solvent
mixtures.
F003
Spent non-halogenated solvents: xylene, acetone, ethyl acetate, ethyl benzene,
ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and
methanol; all spent solvent mixtures/blends containing, before use, only the
above spent non-halogenated solvents; and all spent solvent mixtures/blends
containing, before use, one or more of the above non-halogenated solvents,
and, a total of 10 percent or more (by volume) of one of those solvents listed in
F001, F002, F004, F005; and still bottoms from the recovery of these spent
solvents and spent solvent mixtures.
F004
Spent non-halogenated solvents: cresols and cresylic acid, and nitrobenzene; all
spent solvent mixtures/blends containing, before use, a total of 10 percent or
more (by volume) of one or more of the above non-halogenated solvents or
those solvents listed in F001, F002, and F005; and still bottoms from the
recovery of these spent solvents and spent solvent mixtures.
SIC Code 34
100
September 1995
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Fabricated Metal Products
Sector Notebook Project
F005
F006
F007
F008
Spent non-halogenated solvents: toluene, methy ethyl ketone, carbon disulfide,
isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent
solvent mixtures /blends containing, before use, a total of 10 percent or more
(by volume) of one or more of the above non-halogenated solvents or those
solvents listed in F001, F002, or F004; and still bottoms from the recovery of
these spent solvents and spent solvents mixtures.
Wastewater treatment sludges from electroplating operations except from the
following processes: (1) sulfuric acid anodizing of aluminum; (2) tin plating on
carbon steel; (3) zinc plating (segregated basis) on carbon steel; (4) aluminum or
zinc-aluminum plating on carbon steel; (5) cleaning/stripping associated with
tin, zinc, and aluminum plating on carbon steel; and (6) chemical etching and
milling of aluminum.
Spent cyanide plating bath solutions from electroplating operations.
Plating bath residues from the bottom of plating baths from electroplating
operations where cyanides are used in the process.
September 1995
101
SIC Code 34
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Fabricated Metal Products Sector Notebook Project
Exhibit 33
Hazardous Wastes Relevant to the Metal Finishing Industry
EPA Hazardous
Waste No.
F009
F010
F011
F012
F019
K090
K091
Hazardous Waste
Spent stripping and cleaning bath solutions from electroplating operations
where cyanides are used in the process.
Quenching bath residues from oil baths from metal heat treating operations
where cyanides are used in the process.
Spent cyanide solutions from salt bath pot cleaning from metal heat treating
operations.
Quenching wastewater treatment sludges from metal heat treating operations
where cyanides are used in the process.
Wastewater treatment sludges from the chemical conversion coating of
aluminum from zirconium phosphating is an exclusive conversion coating
process.
Emission control dust or sludge from ferrochromiumsilicon production
(ferroalloy industry) .
Emission control dust or sludge from ferrochromium production (ferroalloy
industry) .
Source: Sustainable Industry: Promoting Strategic Environmental Protection in the Industrial Sector, Phase 1 Report,
U.S. EPA, OERR, June 1994.
VI.C. Pending and Proposed Regulatory Requirements
Clean Water Act (CWA)
The effluent guidelines and standards for Electroplaters (40 CFR Part
413) and Metal Finishers (40 CFR Part 433) are currently under review.
EPA is also currently developing effluent guidelines and standards for
the metal products and machinery industry (40 CFR Part 438), which
are due by May 1996. It appears that EPA will integrate new
regulatory options for the metal finishing industry into this new
guideline. Under the anticipated scenario, effluent guidelines for
electroplaters and metal finishers would most likely reference
appropriate sections of the guideline for the metal products and
machinery industry. In is unclear, however, how "job shop"
operations, which are not part of the metal products and machinery
industry, would be covered under this scenario.
For Phase I of the regulation, EPA will propose effluent limitation
guidelines for facilities that generate wastewater while processing
metal parts, metal products, and machinery, including: manufacture,
assembly, rebuilding, repair, and maintenance. The Phase I regulation
will cover seven major industrial groups, including: aircraft,
aerospace, hardware (including machine tools, screw machines, metal
SIC Code 34 102 September 1995
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Fabricated Metal Products Sector Notebook Project
forgings and stampings, metal springs, heating equipment, and
fabricated structural metal, ordinance, stationary industrial equipment
(including electrical equipment), mobile industrial equipment, and
electronic equipment (including communication equipment). The
legal deadline is May 1996.
Phase II, EPA will propose effluent limitation guidelines for facilities
that generate wastewater while processing metal parts, metal products
and machinery, including: manufacture, assembly, rebuilding, repair,
and maintenance. The Phase II regulation will cover eight major
industrial groups, including: motor vehicles, buses and trucks,
household equipment, business equipment, instruments, precious and
nonprecious metals, shipbuilding, and railroads. The legal deadline is
December 31, 1997.
Clean Air Act (CAA)
In addition to the CAA requirements discussed above, EPA is
currently working on several regulations that will directly affect the
metal finishing industry. Many proposed standards will limit the air
emissions from various industries by proposing Maximum Achievable
Control Technology (MACT) based performance standards that will
set limits on emissions based upon concentrations in the waste stream.
Various potential standards are described below.
Organic Solvent Degreasing/Cleaning
EPA proposed a NESHAP (58 FR 62566, November 19, 1993) for the
source category of halogenated solvent degreasing/cleaning that will
directly affect the metal finishing industry. This will apply to new
and existing organic halogenated solvent emissions to a MACT-
equivalent level, and will apply to new and existing organic
halogenated solvent cleaners (degreasers) using any of the HAPs listed
in the CAA Amendments. EPA is specifically targeting vapor
degreasers that use the following HAPs: methylene chloride,
perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon
tetrachloride, and chloroform.
This NESHAP proposes to implement a MACT-based equipment and
work practice compliance standard. This would require that a facility
use a designated type of pollution prevention technology along with
proper operating procedures. However, EPA has also provided an
alternative compliance standard. Existing operations, which utilize
performance-based standards, can continue to do so if such standards
September 1995 103 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
can be shown to achieve the same emission limit as the equipment and
work practice compliance standard.
Steel Pickling, HC1
Hydrochloric acid (HC1) and chlorine are among the pollutants listed
as hazardous air pollutants in Section 112 of the Clean Air Act
Amendments of 1990. Steel pickling processes that use HC1 solution
and HC1 regeneration processes have been identified by the EPA as
potentially significant sources of HC1 and chlorine air emissions and,
as such, a source category for which national emission standards may
be warranted. EPA is required to promulgate national emission
standards for 50 percent of the source categories listed in Section
112(e) by November 15, 1997.
Other Future Regulatory Actions
EPA is developing MACT standards for several industries, including:
miscellaneous metal parts and products (surface coating), asphalt/coal
tar application-metal pipes, metal can (surface coating), metal coil
(surface coating), and metal furniture (surface coating). The legal
deadline for these rulemakings is November 15, 2000.
SIC Code 34 104 September 1995
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Fabricated Metal Products Sector Notebook Project
VII. COMPLIANCE AND ENFORCEMENT PROFILE
Background
To date, EPA has focused much of its attention on measuring
compliance with specific environmental statutes. This approach
allows the Agency to track compliance with the Clean Air Act, the
Resource Conservation and Recovery Act, the Clean Water Act, and
other environmental statutes. Within the last several years, the
Agency has begun to supplement single-media compliance indicators
with facility-specific, multimedia indicators of compliance. In doing
so, EPA is in a better position to track compliance with all statutes at
the facility level, and within specific industrial sectors.
A major step in building the capacity to compile multimedia data for
industrial sectors was the creation of EPA's Integrated Data for
Enforcement Analysis (IDEA) system. IDEA has the capacity to "read
into" the Agency's single-media databases, extract compliance records,
and match the records to individual facilities. The IDEA system can
match Air, Water, Waste, Toxics/Pesticides/EPCRA, TRI, and
Enforcement Docket records for a given facility, and generate a list of
historical permit, inspection, and enforcement activity. IDEA also has
the capability to analyze data by geographic area and corporate
holder. As the capacity to generate multimedia compliance data
improves, EPA will make available more in-depth compliance and
enforcement information. Additionally, sector-specific measures of
success for compliance assistance efforts are under development.
Compliance and Enforcement Profile Description
Using inspection, violation, and enforcement data from the IDEA
system, this section provides information regarding the historical
compliance and enforcement activity of this sector. In order to mirror
the facility universe reported in the Toxic Chemical Profile, the data
reported within this section consists of records only from the TRI
reporting universe. With this decision, the selection criteria are
consistent across sectors with certain exceptions. For the sectors that
do not normally report to the TRI program, data have been provided
from EPA's Facility Indexing System (FINDS) which tracks facilities in
all media databases. Please note, in this section, EPA does not attempt
to define the actual number of facilities that fall within each sector.
Instead, the section portrays the records of a subset of facilities within
the sector that are well defined within EPA databases.
September 1995 105 SIC Code 34
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As a check on the relative size of the full sector universe, most
notebooks contain an estimated number of facilities within the sector
according to the Bureau of Census (See Section II). With sectors
dominated by small businesses, such as metal finishers and printers,
the reporting universe within the EPA databases may be small in
comparison to Census data. However, the group selected for inclusion
in this data analysis section should be consistent with this sector's
general make-up.
Following this introduction is a list defining each data column
presented within this section. These values represent a retrospective
summary of inspections and enforcement actions, and solely reflect
EPA, State, and local compliance assurance activities that have been
entered into EPA databases. To identify any changes in trends, the
EPA ran two data queries, one for the past five calendar years (August
10, 1990 to August 9, 1995) and the other for the most recent twelve-
month period (August 10, 1994 to August 9, 1995). The five-year
analysis gives an average level of activity for that period for
comparison to the more recent activity.
Because most inspections focus on single-media requirements, the data
queries presented in this section are taken from single media
databases. These databases do not provide data on whether
inspections are State/local or EPA-led. However, the table breaking
down the universe of violations does give the reader a crude
measurement of the EPA's and States' efforts within each media
program. The presented data illustrate the variations across regions
for certain sectors.2 This variation may be attributable to State/local
data entry variations, specific geographic concentrations, proximity to
population centers, sensitive ecosystems, highly toxic chemicals used
in production, or historical noncompliance. Hence, the exhibited data
do not rank regional performance or necessarily reflect which regions
may have the most compliance problems.
2 EPA Regions include the following States: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR,
VI); III (DC, DE, MD, PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI,
MN, OH, WI); VI (AR, LA, NM, OK, TX); VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT,
WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR, WA).
SIC Code 34 106 September 1995
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Compliance and Enforcement Data Definitions
General Definitions
Facilities Indexing System (FINDS) — this system assigns a common
facility number to EPA single-media permit records. The FINDS
identification number allows EPA to compile and review all permit,
compliance, enforcement, and pollutant release data for any given
regulated facility.
Integrated Data for Enforcement Analysis (IDEA) -- is a data
integration system that can retrieve information from the major EPA
program office databases. IDEA uses the FINDS identification
number to "glue together" separate data records from EPA's databases.
This is done to create a "master list" of data records for any given
facility. Some of the data systems accessible through IDEA are: AIRS
(Air Facility Indexing and Retrieval System, Office of Air and
Radiation), PCS (Permit Compliance System, Office of Water), RCRIS
(Resource Conservation and Recovery Information System, Office of
Solid Waste), NCDB (National Compliance Data Base, Office of
Prevention, Pesticides, and Toxic Substances), CERCLIS
(Comprehensive Environmental and Liability Information System,
Superfund), and TRIS (Toxic Release Inventory System). IDEA also
contains information from outside sources such as Dun and Bradstreet
and the Occupational Safety and Health Administration (OSHA).
Most data queries displayed in notebook Sections IV and VII were
conducted using IDEA.
Data Table Column Heading Definitions
Facilities in Search -- are based on the universe of TRI reporters
within the listed SIC code range. For industries not covered under TRI
reporting requirements, the notebook uses the FINDS universe for
executing data queries. The SIC code range selected for each search is
defined by each notebook's selected SIC code coverage described in
Section II.
Facilities Inspected — indicates the level of EPA and State agency
facility inspections for the facilities in this data search. These values
show what percentage of the facility universe is inspected in a 12 or 60
month period. This column does not count non-inspectional
compliance activities such as the review of facility-reported discharge
reports.
September 1995 107 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
Number of Inspections -- measures the total number of inspections
conducted in this sector. An inspection event is counted each time it is
entered into a single media database.
Average Time Between Inspections -- provides an average length of
time, expressed in months, that a compliance inspection occurs at a
facility within the defined universe.
Facilities with One or More Enforcement Actions — expresses the
number of facilities that were party to at least one enforcement action
within the defined time period. This category is broken down further
into Federal and State actions. Data are obtained for administrative,
civil/judicial, and criminal enforcement actions. Administrative
actions include Notices of Violation (NOVs). A facility with multiple
enforcement actions is only counted once in this column (facility with
3 enforcement actions counts as 1). All percentages that appear are
referenced to the number of facilities inspected.
Total Enforcement Actions -- describes the total number of
enforcement actions identified for an industrial sector across all
environmental statutes. A facility with multiple enforcement actions is
counted multiple times (a facility with 3 enforcement actions counts as
3).
State Lead Actions -- shows what percentage of the total enforcement
actions are taken by State and local environmental agencies. Varying
levels of use by States of EPA data systems may limit the volume of
actions accorded State enforcement activity. Some States extensively
report enforcement activities into EPA data systems, while other States
may use their own data systems.
Federal Lead Actions -- shows what percentage of the total
enforcement actions are taken by the U.S. EPA. This value includes
referrals from State agencies. Many of these actions result from
coordinated or joint State/Federal efforts.
Enforcement to Inspection Rate -- expresses how often enforcement
actions result from inspections. This value is a ratio of enforcement
actions to inspections, and is presented for comparative purposes only.
This measure is a rough indicator of the relationship between
inspections and enforcement. This measure simply indicates
historically how many enforcement actions can be attributed to
inspection activity. Related inspections and enforcement actions
under the Clean Water Act (PCS), the Clean Air Act (AFS) and the
SIC Code 34 108 September 1995
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Fabricated Metal Products Sector Notebook Project
Resource Conservation and Recovery Act (RCRA) are included in this
ratio. Inspections and actions from the TSCA/FIFRA/EPCRA
database are not factored into this ratio because most of the actions
taken under these programs are not the result of facility inspections.
This ratio does not account for enforcement actions arising from non-
inspection compliance monitoring activities (e.g., self-reported water
discharges) that can result in enforcement action within the CAA,
CWA and RCRA.
Facilities with One or More Violations Identified — indicates the
number and percentage of inspected facilities having a violation
identified in one of the following data categories: In Violation or
Significant Violation Status (CAA); Reportable Noncompliance,
Current Year Noncompliance, Significant Noncompliance (CWA);
Noncompliance and Significant Noncompliance (FIFRA, TSCA, and
EPCRA); Unresolved Violation and Unresolved High Priority
Violation (RCRA). The values presented for this column reflect the
extent of noncompliance within the measured time frame, but do not
distinguish between the severity of the noncompliance. Percentages
within this column can exceed 100 percent because facilities can be in
violation status without being inspected. Violation status may be a
precursor to an enforcement action, but does not necessarily indicate
that an enforcement action will occur.
Media Breakdown of Enforcement Actions and Inspections — four
columns identify the proportion of total inspections and enforcement
actions within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA
databases. Each column is a percentage of either the "Total
Inspections," or the "Total Actions" column.
VILA. Fabricated Metal Products Industry Compliance History
Exhibit 34 presents enforcement and compliance information specific
to the fabricated metal products industry. As indicated in this exhibit,
Regions IV, V, and IX conduct the largest number of inspections in this
industry. This is consistent with the fact that the fabricated metal
products industry is geographically concentrated near industrial areas.
The data also indicates that nearly all of Region IVs enforcement
actions are State-lead.
VII.B. Comparison of Enforcement Activity Between Selected Industries
September 1995 109 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
Exhibits 35 - 38 provide enforcement and compliance information for
selected industries. The fabricated metal products industry comprises
the largest number of facilities tracked by EPA across the selected
industries. Likewise, it has the largest number of inspections and
enforcement actions. For this industry, RCRA inspections comprise
over half of all inspections conducted, while CWA inspections account
for 15 percent of these inspections. The low CWA inspection rate is in
conflict with the large number of water discharges that are generated
by this industry.
SIC Code 34 110 September 1995
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Fabricated Metal Products
Sector Notebook Project
Exhibit 34
Fab. Metal Product-Specific
Five Year Enforcement and Compliance Summary for the Fabricated Metal Industry
A
Fabricated Metal
SIC 34
Region I
Region II
Region III
Region IV
Region V
Region VI
Region VII
Region VIII
Region IX
Region X
Total/Average
B
Facilities in
Search
199
171
186
320
880
171
109
36
228
46
2,346
C
Facilities
Inspected
139
127
130
220
466
85
71
14
65
23
1,340
D
Number of
Inspections
585
515
626
1480
1549
268
238
50
125
73
5,509
E
Average
Number of
Months
Between
Inspections
20
20
18
13
34
38
27
43
109
38
26
F
Facilities
w/one or
more
Enforcement
Actions
40
39
43
48
54
17
13
7
7
12
280
G
Total
Enforcement
Actions
99
139
156
178
128
54
31
8
20
27
840
H
State Lead
Actions
66%
78%
86%
94%
75%
89%
71%
38%
65%
63%
80%
I
Federal Lead
Actions
34%
22%
14%
6%
25%
11%
29%
63%
35%
37%
20%
J
Enforcement
to Inspection
Rate
0.17
0.27
0.25
0.12
0.08
0.20
0.13
0.16
0.16
0.37
0.15
September 1995
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SIC Code 34
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Fabricated Metal Products
Sector Notebook Project
Exhibits 35
Five Year Enforcement and Compliance Summary for Selected Industries
A
Industry Sector
Metal Mining
Non-metallic Mineral
Mining
Lumber and Wood
Furniture
Rubber and Plastic
Stone, Clay, and Glass
Nonferrous Metals
Fabricated Metal
Electronics/Computers
Motor Vehicle
Assembly
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Iron and Steel
Dry Cleaning
B
Facilities in
Search
873
1,143
464
293
1,665
468
844
2,346
405
598
306
4,106
548
412
156
374
933
C
Facilities
Inspected
339
631
301
213
739
268
474
1,340
222
390
265
1,035
298
316
145
275
245
D
Number
of
Inspections
1,519
3,422
1,891
1,534
3,386
2,475
3,097
5,509
777
2,216
3,766
4,723
3,034
3,864
3,257
3,555
633
E
Average
Number of
Months
Between
Inspections
34
20
15
11
30
11
16
26
31
16
5
52
11
6
3
6
88
F
Facilities
w/One or
More
Enforcement
Actions
67
84
78
34
146
73
145
280
68
81
115
176
99
152
110
115
29
G
Total
Enforcement
Actions
155
192
232
91
391
301
470
840
212
240
502
514
402
726
797
499
103
H
State
Lead
Actions
47%
76%
79%
91%
78%
70%
76%
80%
79%
80%
78%
85%
76%
66%
66%
72%
99%
I
Federal
Lead
Actions
53%
24%
21%
9%
22%
30%
24%
20%
21%
20%
22%
15%
24%
34%
34%
28%
1%
J
Enforcement
to Inspection
Rate
0.10
0.06
0.12
0.06
0.12
0.12
0.15
0.15
0.27
0.11
0.13
0.11
0.13
0.19
0.25
0.14
0.16
SIC Code 34
112
September 1995
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Fabricated Metal Products
Sector Notebook Project
Exhibits 36
One Year Enforcement and Compliance Summary for Selected Industries
A
Industry Sector
Metal Mining
Non-metallic Mineral
Mining
Lumber and Wood
Furniture
Rubber and Plastic
Stone, Clay, and Glass
Nonferrous Metals
Fabricated Metal
Electronics/Computers
Motor Vehicle
Assembly
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Iron and Steel
Dry Cleaning
B
Facilities in
Search
873
1,143
464
293
1,665
468
844
2,346
405
598
306
4,106
548
412
156
374
933
C
Facilities
Inspected
114
253
142
160
271
146
202
477
60
169
189
397
158
195
109
167
80
D
Number of
Inspections
194
425
268
113
435
330
402
746
87
284
576
676
427
545
437
488
111
E
Facilities w/One or More
Violations
Number
82
75
109
66
289
116
282
525
80
162
162
251
167
197
109
165
21
Percent*
72%
30%
77%
41%
107%
79%
140%
110%
133%
96%
86%
63%
106%
101%
100%
99%
26%
F
Facilities w/One or More
Enforcement Actions
Number
16
28
18
3
19
20
22
46
8
14
28
25
19
39
39
20
5
Percent*
14%
11%
13%
2%
7%
14%
11%
10%
13%
8%
15%
6%
12%
20%
36%
12%
6%
G
Total
Enforcement
Actions
24
54
42
5
59
66
72
114
21
28
88
72
49
118
114
46
11
H
Enforcement
to Inspection
Rate
0.13
0.13
0.58
0.55
0.14
0.20
0.18
0.15
0.24
0.10
0.15
0.11
0.12
0.22
0.26
0.09
0.10
* Percentages in Columns E and F are based on the number of facilities inspected (Column C). Percentages can exceed 100% because violations and actions can occur
without a facility inspection.
September 1995
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SIC Code 34
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Fabricated Metal Products
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Exhibits 37
Five Year Inspection and Enforcement Summary by Statute for Selected
Industries
Industry Sector
Metal Mining
Non-metallic
Mineral Mining
Lumber and
Wood
Furniture
Rubber and
Plastic
Stone, Clay and
Glass
Nonferrous
Metals
Fabricated Metal
Electronics/
Computers
Motor Vehicle
Assembly
Pulp and Paper
Printing
Inorganic
Chemicals
Organic
Chemicals
Petroleum
Refining
Iron and Steel
Dry Cleaning
Number of
Facilities
Inspected
339
631
301
293
739
268
474
1,340
222
390
265
1,035
302
316
145
275
245
Total
Inspections
1,519
3,422
1,891
1,534
3,386
2,475
3,097
5,509
777
2,216
3,766
4,723
3,034
3,864
3,237
3,555
633
Enforcement
Actions
155
192
232
91
391
301
470
840
212
240
502
514
402
726
797
499
103
Clean Air Act
% of Total
Inspections
35%
65%
31%
52%
39%
45%
36%
25%
16%
35%
51%
49%
29%
33%
44%
32%
15%
% of Total
Actions
17%
46%
21%
27%
15%
39%
22%
11%
2%
15%
48%
31%
26%
30%
32%
20%
1%
Clean Water Act
% of Total
Inspections
57%
31%
8%
1%
13%
15%
22%
15%
14%
9%
38%
6%
29%
16%
19%
30%
3%
% of Total
Actions
60%
24%
7%
1%
7%
5%
13%
6%
3%
4%
30%
3%
17%
21%
12%
18%
4%
Resource Conservation
and Recovery Act
% of Total
Inspections
6%
3%
59%
45%
44%
39%
38%
56%
66%
54%
9%
43%
39%
46%
35%
37%
83%
% of Total
Actions
14%
27%
67%
64%
68%
51%
54%
76%
90%
75%
18%
62%
53%
44%
52%
58%
93%
FIFRA/TSCA/
EPCRA/Other*
% of Total
Inspections
1%
<1%
2%
1%
3%
2%
4%
4%
3%
2%
2%
2%
3%
5%
2%
2%
<1%
% of Total
Actions
9%
4%
5%
8%
10%
5%
10%
7%
5%
6%
3%
4%
4%
5%
5%
5%
1%
Actions taken to enforce the Federal Insecticide, Fungicide, and Rodenticide Act;
the Toxic Substances and Control Act, and the Emergency Planning and
Community Right-to-Know Act as well as other Federal environmental laws.
SIC Code 34
114
September 1995
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Fabricated Metal Products
Sector Notebook Project
Exhibits 38
One Year Inspection and Enforcement Summary by Statute for Selected Industries
Industry Sector
Metal Mining
Non-metallic
Mineral Mining
Lumber and
Wood
Furniture
Rubber and
Plastic
Stone, Clay, and
Glass
Nonferrous
Metals
Fabricated Metal
Electronics/
Computers
Motor Vehicle
Assembly
Pulp and Paper
Printing
Inorganic
Chemicals
Organic
Chemicals
Petroleum
Refining
Iron and Steel
Dry Cleaning
Number of
Facilities
Inspected
114
253
142
293
271
146
202
477
60
169
189
397
158
195
109
167
80
Total
Inspections
194
425
268
160
435
330
402
746
87
284
576
676
427
545
439
488
111
Enforcement
Actions
24
54
42
5
59
66
72
114
21
28
88
72
49
118
114
46
11
Clean Air Act
% of Total
Inspections
47%
69%
29%
58%
39%
45%
33%
25%
17%
34%
56%
50%
26%
36%
50%
29%
21%
% of
Total
Actions
42%
58%
20%
67%
14%
52%
24%
14%
2%
16%
69%
27%
38%
34%
31%
18%
4%
Clean Water Act
% of Total
Inspections
43%
26%
8%
1%
14%
18%
21%
14%
14%
10%
35%
5%
29%
13%
19%
35%
1%
%of
Total
Actions
34%
16%
13%
10%
4%
8%
3%
8%
7%
9%
21%
3%
21%
16%
16%
26%
22%
Resource Conservation
and Recovery Act
% of Total
Inspections
10%
5%
63%
41%
46%
38%
44%
61%
69%
56%
10%
44%
45%
50%
30%
36%
78%
% of
Total
Actions
6%
16%
61%
10%
71%
37%
69%
77%
87%
69%
7%
66%
36%
49%
47%
50%
67%
FIFRA/TSCA/
EPCRA/Other
% of Total
Inspections
<1%
<1%
<1%
<1%
1%
<1%
1%
<1%
<1%
1%
<1%
<1%
<1%
1%
1%
<1%
<1%
%of
Total
Actions
19%
11%
6%
13%
11%
3%
4%
2%
4%
6%
3%
4%
6%
1%
6%
6%
7%
Actions taken to enforce the Federal Insecticide, Fungicide, and Rodenticide Act; the
Toxic Substances and Control Act, and the Emergency Planning and Community
Right-to-Know Act as well as other Federal environmental laws.
September 1995
115
SIC Code 34
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Fabricated Metal Products Sector Notebook Project
VII.C. Review of Major Legal Actions
VII.C.I Review of Major Cases
This section provides summary information about major cases that
have affected this sector. As indicated in EPA's Enforcement
Accomplishments Report, FY 1991, FY 1992, FY 1993 publications, 15
significant enforcement actions were resolved between 1991 and 1993
for the metal finishing industry. CWA violations comprised eight of
these actions, the most of any statute. Following CWA violations were
five actions involving RCRA violations, three involving CERCLA
violations, one with a CAA violation, and one with a SDWA violation.
The companies against which the cases were brought are primarily
metal finishers, including those that provide electroplating, coating,
and plating services. Two of the companies perform metal forming
and fabrication functions.
Twelve of the fifteen cases resulted in the assessment of a penalty.
Penalties ranged from $15,000 to $500,000, and in four cases,
additional money was spent by the defendant to improve the
processes or technologies and to increase future compliance. For
example, in U.S. v. North American Philips Corp. (1992), the company
paid a $500,000 penalty and spent approximately $583,000 to eliminate
wastewater discharges from some of its non-federally regulated
processes. The average penalty per case was approximately $322,000.
Supplemental Environmental Projects (SEPs) were required in two of
the cases. Texas Instruments, Inc. (1993), for example, was required to
pay a penalty and replace a vapor degreaser unit with a more
environmentally-protective unit.
Although many cases involved civil penalties, four of the cases
involved criminal convictions, resulting in penalties and/or jail
sentences for the owners and/or operators of the facilities. For
example, the case of U.S. v. John Borowski and Borjohn Optical
Technology, Inc., resulted in the first criminal endangerment
conviction under CWA; the company president was sentenced to 26
months in prison, folloshwed by two years of supervised release.
SIC Code 34 116 September 1995
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Fabricated Metal Products Sector Notebook Project
VII.C.2 Supplemental Environmental Projects
Supplementary Environmental Projects (SEPs) are compliance
agreements that reduce a facility's stipulated penalty in return for an
environmental project that exceeds the value of the reduction. Often,
these projects fund pollution prevention activities that can
significantly reduce the future pollutant loadings of a facility.
In December, 1993, the Regions were asked by EPA's Office of
Enforcement and Compliance Assurance to provide information on
the number and type of SEPs entered into by the Regions. The
following exhibit contains a representative sample of the Regional
responses addressing the fabricated metal products industry. The
information contained in the exhibit is not comprehensive and
provides only a sample of the types of SEPs developed for the
fabricated metal products industry. Please note that the projects
describes in this section do not necessarily apply to all facilities in this
sector. Facility-specific conditions must be considered carefully when
evaluating potential supplemental environmental projects.
September 1995 117 SIC Code 34
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Fabricated Metal Products
Sector Notebook Project
Exhibit 39
Supplemental Environmental Projects
Fabrication of Metal Products (SIC 34)
Case Name
Truex, Inc.
Pawtucket, Rl
(metal parts
manufacturing)
Walton & Lonsbury
Attleboro, MA
(electroplating facility)
Verilyte Gold, Inc.
Chelsea, MA
(electroplatting facility)
The Torrington
Company (precision
bearings, assemblies,
gears, and couplings
manufacture)
Texas Instruments, Inc.
Attleboro, MA
(metallurgic materials
manufacture)
EPA
Region
1
1
1
1
1
Statute/
Type of
Action
EPCRA
RCRA
RCRA
EPCRA
EPCRA
Type of SEP
Pollution
Reduction
Pollution
Prevention and
Pollution
Reduction
Pollution
Prevention
Equipment
Donation
Equipment
Donation
Estimated
Cost to
Company
S 70,000
S 18,270
S 21,450
S 16,792
S 8,063
Expected Environmental Benefits
Install and operate a cooling water and
process rinse recycling system and a
metal recovery system to reduce the
water used and to recover copper and
zinc process waste for recycling.
Implement a system to reclaim and
reuse chromic acid rinse waters.
Eliminate the use of trichloroethane in
the degreasing operation. Install a
filtration system which will extend the
life of the hydrochloric acid strip
solution.
Install a hot-air metal parts drying unit
which eliminates 100 percent of the use
of freon.
Donate emergency and/or computer
equipment to the Local Emergency
Planning Committee (LEPC) to
respond to and/or plan for chemical
emergencies. Participate in LEPC
activities.
Purchase computer hardware and
software for the LEPC and Attleboro
Fire Department (AFD) to assist the
LEPC in tracking and storing
information about identity and location
of hazardous chemicals and to assist the
AFD in responding to accidental
releases.
Final
Assessed
Penalty
S 54,000
S 15,100
S 26,400
S 35,364
S 14,025
Final Penalty After
Mitigation
S 29,000
S 15,100
S 15,675
S 18,572
S 5,962
SIC Code 34
118
September 1995
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Fabricated Metal Products
Sector Notebook Project
Exhibit 39
Supplemental Environmental Projects
Fabrication of Metal Products (SIC 34)
Case Name
Texas Instruments, Inc.
Attleboro, MA
(metal finishing)
L.S. Starrlett Company,
Inc.
Athol, MA
(tool manufacture)
Teradyne, Inc
Nashua, NH
(soldering products
manufacture)
M.W. Dunton Company
West Warwick, RI
(soldering products
manufacture)
EPA
Region
1
1
1
1
Statute/
Type of
Action
CAA
EPCRA
RCRA
EPCRA
Type of SEP
Pollution
Prevention
Pollution
Prevention
Pollution
Prevention
SERC/LERC
Estimated
Cost to
Company
S 170,000
S 290,000
S 800,000
S 4,754
Expected Environmental Benefits
Replace the current vapor degreasor
unit with a closed-loop degreaser unit to
prevent the use of Freon 113.
Install three alkaline-based aqueous
agitation wash systems, replace Freon
cleaning units in two departments, and a
methylene chloride cleaning unit in a
third department to reduce Freon and
methylene chloride by 100 percent.
Purchase and install solvent
replacement units for two facilities.
Stop using Freon 113 in manufacturing
operations at one facility and stop using
1,1,1 -trichloroethane (except in water
sensitive assemblies) at another facility.
Donate emergency response equipment
to the volunteer fire department to
assist the LEPC in tracking and storing
information about identity and location
of hazardous chemicals and to assist the
fire department in responding to
accidental releases.
Final
Assessed
Penalty
S 90,000
S 176,800
S 120,000
S 9,500
Final Penalty After
Mitigation
S 49,900
S 83,200
S 50,000
S 4,745
September 1995
119
SIC Code 34
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Fabricated Metal Products
Sector Notebook Project
Exhibit 39
Supplemental Environmental Projects
Fabrication of Metal Products (SIC 34)
Case Name
The Drawn Metal Tube
Company
Thomaston, CT
Pioneer Metal Finishing
Elken Metals Company
Alloy, WV
Southern Foundry
Supply
Cerro Metal Products,
Inc.
Bellefonte, PA
EPA
Region
1
2
3
4
3
Statute/
Type of
Action
CWA
EPCRA
xxxx
EPCRA
TSCA
Type of SEP
Pollution
Prevention
Pollution
Prevention
Pollution
Reduction
Pollution
Reduction
Accelerated
Compliance
Estimated
Cost to
Company
S 145,000
S 13,128
S 449,000
S 34,000
S 40,000
Expected Environmental Benefits
Install a closed loop evaporator system
to eliminate the discharge of copper
forming wastewater to the river.
Pretreat used nickel bags and used filter
bags from nickel filters to recover waste
nickel, thus minimizing the disposal of
hazardous nickel waste.
Remove PCB transforers, PCB
capapcitors, and retrofilling PCB-
contaminated transformers to reduce the
amount of PCBs which may be
released.
Assess the feasibility of a process to
recover pure nickel from plant
wastestreams and construct a pilot plant
to perform the recovery to reduce the
quantity of heavy metals entering the
environment.
Replace PCB transformers fluid with
non-PCB fluid to eliminate the
potential for uncontrolled releases of
PCBs.
Final
Assessed
Penalty
S 77,624
S 280,000
S 15,840
531,700
Final Penalty After
Mitigation
S 45,000
S 5,000
S 17,250
S 2,376
S 18,450
SIC Code 34
120
September 1995
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Fabricated Metal Products Sector Notebook Project
VIII. COMPLIANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry sector
and public agencies to voluntarily improve the sector's environmental
performance. These activities include those independently initiated by
industrial trade associations. In this section, the notebook also
contains a listing and description of national and regional trade
associations.
VIII.A. Sector-Related Environmental Programs and Activities
Numerous compliance activities and initiatives are occurring
throughout the fabricated metal products industry. Many companies
are conducting private research on developing new alloys and
experimenting with the use of citric acid oils or terpenes instead of the
more toxic degreasers (e.g., 1,1,1-trichloroethane).
Several projects currently underway are sponsored by Federal, State,
and county governments; universities; and trade associations. Several
of these initiatives are described below.
Common Sense Initiative
The Common Sense Initiative (CSI), a partnership between EPA and
private industry, aims to create environmental protection strategies
that are cleaner for the environment and cheaper for industry and
taxpayers. As part of CSI, representatives from Federal, State, and
local governments; industry; community-based and national
environmental organizations; environmental justice groups; and labor
organizations, come together to examine the full range of
environmental requirements affecting the following six selected
industries: automobile manufacturing; computers and electronics,
iron and steel, metal finishing, petroleum refining; and printing.
CSI participants are looking for solutions that:
• Focus on the industry as a whole rather than one pollutant
• Seek consensus-based solutions
• Focus on pollution prevention rather than end-of-pipe controls
• Are industry-specific.
September 1995 121 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
The Common Sense Initiative Council (CSIC), chaired by EPA
Administrator Browner, consists of a parent council and six
subcommittees (one per industry sector). Each of the subcommittees
have met and identified issues and project areas for emphasis, and
workgroups have been established to analyze and make
recommendation on these issues. (Contact: Greg Waldrip at (202) 564-
7024)
Design for the Environment (DfE)
DfE is an EPA program operated by the Office of Pollution Prevention
and Toxics. DfE is a voluntary program which promotes the use of
safer chemicals, processes, and technologies in the earliest product
design stages. The DfE program assists industry in making informed,
environmentally responsible design choices by providing
standardized analytical tools for industry application and providing
information on the comparative environmental and human health risk,
cost, and performance of chemicals, processes, and technologies. DfE
also helps small businesses by analyzing pollution prevention
alternatives and disseminating the information to industry and the
public. By helping to translate pollution prevention into meaningful
terms, DfE contributes to building the institutional structure in
corporations to support pollution prevention. DfE activities fall into
two broad categories: (1) the industry-specific projects which
encourage businesses to incorporate pollution prevention into their
designs; and (2) long-term projects that translate pollution prevention
into terms that make sense to professions such as chemistry, chemical
engineering, marketing, accounting, and insurance.
One DfE effort (in partnership with the Manufacturing Extension
Partnership) is the development of a benchmarking database and
accompanying questionnaire to serve as an incentive mechanism for
companies. Metal fabricators are encouraged to complete a company-
specific questionnaire and return it to the Manufacturing Extension
Partnership for analysis. The company will then receive a report
comparing its data to that of other companies. Based on the results,
companies are encouraged to voluntarily implement mechanisms that
will minimize environmental damage resulting from the
manufacturing processes. Subjects included in the questionnaire,
database, and report range from the use of automation and monitoring
technologies to the volumes of wastes generated, treated, and recycled.
SIC Code 34 122 September 1995
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Fabricated Metal Products Sector Notebook Project
Minnesota Technical Assistance Program (MnTAP)
In the State of Minnesota, waste reduction is receiving increased
attention as an alternative to waste disposal. To help companies
reduce waste, Minnesota developed MnTAP, a program that helps
facilities identify waste reduction opportunities. MnTAP recognizes
that each company's operations are unique and has, therefore,
developed a series of checklists to help identify waste reduction
possibilities. The checklists are designed to assist each facility
evaluate wastestreams and identify waste reduction opportunities.
The checklists cover several areas relevant to this profile, including
operating procedures, cleaning, machining, plating/metal finishing,
coating/painting, and formulating.
To ensure effective use of MnTAP's checklists, staff is available to
answer questions over the phone or on-site once checklists have been
completed. MnTAP has also gathered vendor and technical
information for many of the options listed which may be useful in
assessing a facility's waste reduction opportunities. In addition,
MnTAP has developed lists of vendors who provide recycling services
on a contract basis if it is not feasible to implement the options listed
on the checklists. MnTAP staff can be reached at (612) 625-4949.
Pollution Prevention and Waste Minimization in the Metal Finishing Industry Workshop
The University of Nebraska-Lincoln sponsored a Pollution Prevention
and Waste Minimization in the Metal Finishing Industry workshop in
1993. The workshop was designed for managers and operators of
electroplating and galvanizing operations; engineers; environmental
consultants; waste management consultants; Federal, State, and local
government officials; and individuals responsible for training in the
area of metal finishing waste management. Topics covered included:
• Saving money and reducing risk through pollution prevention
and waste minimization
• Incorporating pollution prevention into planning electroplating
and galvanizing operations
• Conducting waste minimization audits
• Developing and analyzing options for pollution
prevention/waste minimization
September 1995 123 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
• Innovative techniques for implementing a pollution
prevention/waste minimization program.
For more information concerning this workshop, contact David
Montage of the University of Nebraska at W348 Nebraska Hall,
Lincoln, NE 68588-0531.
Pollution Prevention Opportunities Checklists
The County Sanitation Districts of Los Angeles County developed a
detailed pollution prevention opportunities checklist to help
companies identify and implement pollution prevention methods
where possible. The County Sanitation Districts has identified specific
opportunities for the metal fabricators and metal finishing industries.
Southeast Michigan Initiative (SEMI)
EPA and the Michigan Department of Natural Resources (MDNR)
have launched a geographic initiative in the Southeast Michigan area
because of the magnitude of contaminant releases and human
population in the area. Eight counties within the Initiative have been
identified as having major environmental problems. Several rivers in
the area suffer from impaired uses, polluted airsheds, combined sewer
overflows, contaminated sediments, and major toxic pollutant releases.
A Steering Committee, composed of senior managers of MDNR and
EPA, meet quarterly and are responsible for making decisions
concerning the overall direction of the Initiative. There are also four
working committees, including: public participation; remedial action
plans/sediments; pollution prevention; and compliance and
enforcement.
For more information regarding SEMI contact Rufus Anderson,
Assistant Deputy Director, MDNR Region 5 at (313) 953-1444 or Mardi
Klevs, EPA SEMI Coordinator at (312) 353-5490.
The Blackstone Project
The Blackstone Project, a joint initiative by the Massachusetts
Department of Environmental Protection (DEP) and the Department of
Environmental Management (DEM), is intended to make
environmental protection more efficient and less costly to companies.
As Doug Fine, the Compliance and Enforcement Coordinator,
explains, the Blackstone Project's two goals are to encourage industry
SIC Code 34 124 September 1995
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Fabricated Metal Products Sector Notebook Project
to use less toxic material in manufacturing, and to increase the
efficiency of DEP's industrial inspections by conducting one-stop,
facility-wide inspections. The project focused first on fabricated metal
products facilities near the Blackstone River Valley and later expanded
to all types of manufacturers in that region. The State of
Massachusetts now conducts facility-wide inspections in a continuous
effort to reduce pollution.
The NCMS/NAMF Pollution Control Assessment Project
The National Center for Manufacturing Sciences (NCMS) and the
National Association of Metal Finishers (NAMF) worked jointly to
develop the Pollution Prevention and Control Technology for Plating
Operations publication which documents pollution prevention
techniques and pollution control equipment used in plating
operations. To develop this document and the associated database,
NCMS and NAMF collected pollution prevention information through
surveys, literature searches, and interviews with industry experts. The
resulting publication illustrates pollution prevention techniques and
equipment used, assesses the effectiveness of these techniques as
illustrated by historical data, and indicates the types of facilities in
which these techniques were employed.
The Sustainable Industry Project
The EPA Office of Policy, Planning, and Evaluation's Sustainable
Industry Project represents a new approach to the development of
environmental policy for industry. The primary goal of the
Sustainable Industry Project is to develop, test, and implement
industry-specific policy recommendations that will remove barriers to
innovation and promote strategic environmental protection in the
selected industries (i.e., photoimaging, metal finishing, and thermoset
plastics). To do this, EPA gained a thorough understanding of the
relevant characteristics of the industries—the industry-specific
economic, institutional, cultural, technical, life-cycle, and regulatory
factors that may promote or hinder environmental improvements.
Further, EPA identified driving factors and barriers that influence
corporate decision-making and environmental performance.
Understanding the factors that influence environmental performance
in a given industry provides the basis for designing policies that will
encourage improved performance. Working with industries, States,
non-government organizations (NGOs), and other interested parties,
EPA intends to design policies that will protect the environment and
human health while fostering competitive and sustainable industries.
September 1995 125 SIC Code 34
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Fabricated Metal Products Sector Notebook Project
U.S. Bureau of Mines (USBM)
The U.S. Bureau of Mines has developed a technique to regenerate
chromium bearing solutions such as those used in chromate
conversion aluminum electroplating. The process is in commercial use
and a company is preparing to license the technology to manufacture
and market solution treatment equipment. In related work, the
Bureau worked with the specialty steel industry to reduce waste
generated by pickling operations. Other USBM research includes the
dewatering of sludges, extraction of metals from a variety of liquid
and solid wastes, recycling of metals, and development of lead-free
free-machining copper alloys.
Wastewater Technology Center
The Wastewater Technology Center (WTC) is an organization of
scientists, chemists, technologists, and support staff dedicated to the
research and development of technologies to control industrial and
municipal discharges. Conducting bench-scale, pilot plant, and full-
scale studies for 25 years, over 100 WTC staff have assisted industry in
solving a wide variety of environmental concerns. Recently, WTC has
worked closely with the Metal Finishing Task Force, a committee of
Federal government, provincial government, and metal finishing
industry representatives to develop a pollution prevention guide. The
document is designed to assist metal finishers in establishing a
pollution prevention planning process. WTC also provides assistance
in interpreting and using this guide and facilitates other pollution
prevention planning programs that metal finishers have or are
anticipating establishing. In addition, to help metal finishers better
understand and use the pollution prevention planning, WTC, in
conjunction with Sheridan College, has prepared an extensive training
course in pollution prevention planning in metal finishing.
SIC Code 34 126 September 1995
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Fabricated Metal Products Sector Notebook Project
Other Initiatives
The metal finishers and platers industry is being considered by EPA
for several upcoming initiatives. Work has already begun by the
NPDES and the RCRA programs. The NPDES Branch began an
Industrial User initiative in May 1993 that targeted metal finishers
who failed to report their compliance status with categorical
pretreatment effluent standards (40 CFR 433). In addition, the RCRA
program has an initiative that applies to iron and steel and metal
plating/finishing industries. The State of Utah plans to inspect each of
the iron and steel and metal plating/finishing industries in the State.
VIII.B. EPA Voluntary Programs
33/50 Program
The "33/50 Program" is EPA's voluntary program to reduce toxic
chemical releases and transfers of 17 chemicals from manufacturing
facilities. Participating companies pledge to reduce their toxic
chemical releases and transfers by 33 percent as of 1992 and by 50
percent as of 1995 from the 1988 baseline year. Certificates of
Appreciation have been given to participants who meet their 1992
goals. The list of chemicals includes 17 high-use chemicals reported in
the Toxics Release Inventory.
The number of companies that use 33/50 chemicals per industry sector
ranged from a low of six in the tobacco industry to a high of 1,803 in
the fabricated metal products industry. Of these companies, 187
participate in the 33/50 program. Some 33/50 chemicals that are
particularly relevant to this industry include: lead and lead
compounds, methyl ethyl ketone, nickel and nickel compounds,
tetrachloroethylene, toluene, trichloroethane, trichlorethylene, and
xylenes.
Exhibit 40 lists those companies participating in the 33/50 program
that reported under SIC code 34 to TRI. Many of the participating
companies listed multiple SIC codes (in no particular order), and are
therefore likely to conduct operations in addition to Fabricated Metal
Products industry. The table shows the number of facilities within
each company that are participating in the 33/50 program; each
company's total 1993 releases and transfers of 33/50 chemicals; and the
percent reduction in these chemicals since 1988.
September 1995 127 SIC Code 34
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Fabricated Metal Products
Sector Notebook Project
Exhibit 40
33/50 Program
Parent Facility name
A B Chance Co.
ABC Holdings Inc.
Acme Metals Inc.
Adolph Coors Company
Aero Metal Finishing Inc.
Akzo Nobel Inc.
Aladdin Industries Inc.
All Metal Stamping Inc.
Allied-Signal Inc.
Aluminum Company Of America
America's Best Quality
American National Can Company
Ameron Inc. Delaware
Amsted Industries Incorporated
Anderson Screw Products Inc.
Anomatic Corporation
Apogee Enterprises Inc.
Armco Inc.
Asea Brown Boveri Inc.
Asko Processing Inc.
Atlas Die Inc.
Atlas Plating Inc.
Automatic Pltg Of Bridgeport
B. L. Downey Co. Inc.
Baker Hughes Incorporated
Ball And Socket Mfg. Co. Inc.
Ball Corporation
Bausch & Lomb Incorporated
Bead Industries Inc.
Bethlehem Steel Corporation
BHP Holdings (USA) Inc.
Parent City
Centralia
Eufaula
Riverdale
Golden
Fenton
Chicago
Nashville
Abbotsford
Morristown
Pittsburgh
Milwaukee
Chicago
Pasadena
Chicago
Jamestown
Newark
Minneapolis
Pittsburgh
Stamford
Seattle
Elkhart
Cleveland
Bridgeport
Broadview
Houston
Cheshire
Muncie
Rochester
Bridgeport
Bethlehem
San Francisco
ST
MO
AL
IL
CO
MO
IL
TN
WI
NJ
PA
WI
IL
CA
IL
NY
OH
MN
PA
CT
WA
IN
OH
CT
IL
TX
CT
IN
NY
CT
PA
CA
SIC Codes
3644,3613,3423
2851,3449
3312,3499,
3479,3398
2082,3411,3443
3471
3412
3086,3469,3648
3429, 3469, 3499
3728,3471,3724
3463
3471
3411
3272,3317,
3443, 3479
3315,3496,3471
3451
3471
3479
3446
3443
3479
3479
3471
3471
3479
3533,3471
3965,3469,3471
3411
3471,3851,3827
3499,3679,3432
3312,3462
3479
# of Participating
Facilities
1
4
5
1
1
1
1
1
2
5
1
9
1
1
1
1
1
2
2
2
1
1
1
1
1
1
7
1
1
1
1
1993 Releases
and Transfers
(Ibs.)
59,907
55,230
157,232
158,792
12,900
930,189
53,741
1,112
2,080,501
2,403,017
1,025
2,303,898
184,882
1,834,493
7,860
403,270
423,862
1,849,709
501,017
36,991
26,400
505
635
250
193,116
9,820
721,859
51,706
107,143
792,550
64,365
% Reduction
1988 to 1993
**
38
59
43
13
91
50
50
51
74
50
**
66
100
50
15
4
50
50
100
33
***
75
20
**
86
*
***
50
***
SIC Code 34
128
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 40 (cont'd)
33/50 Program
Parent Facility name
Black & Decker Corporation
Blaser Die Casting Co.
Bmc Industries Inc.
Brod & Mcclung-Pace Co.
Brooklyn Park Oil Co. Inc.
Burnham Corporation
C. A. Dahlin Co.
Caldwell Products Inc.
Canon Business Machines Inc.
Cargill Detroit Corporation
Channellock Inc.
Chart Industries Inc.
Chrysler Corporation
Cold Heading Co.
Collis Inc.
Commercial Enameling Co.
Conagra Inc.
Cooper Industries Inc.
Corning Inc.
Crenlo Inc.
Crown City Plating Co.
Crown Cork & Seal Company
Crown Metal Finishing Co. Inc.
Dana Corporation
Davis & Hemphill
Delbar Products Inc.
Delta Engineering & Mfg. Co.
Disston Company
Duo-Fast Corp.
Dynamic Metal Products Company
Eagle-Picher Industries Inc.
Eaton Corporation
Ektron Industries Inc.
Electro-Platers Of York Inc.
Emerson Electric Co.
Enamelers & Japanners Inc.
Ernie Green Industries Inc.
Excell Polishing & Buffing Co.
Federal-Mogul Corporation
Feldkircher Wire Fabg Co.
Parent City
Baltimore
Seattle
Minneapolis
Portland
Minneapolis
Lancaster
Elk Grove
Village
Abilene
Costa Mesa
Clawson
Meadville
Willoughby
Highland Park
Detroit
Clinton
Huntington
Park
Omaha
Houston
Corning
Rochester
El Monte
Philadelphia
Kenilworth
Toledo
Elkridge
Perkasie
Tualatin
Danville
Franklin Park
Manchester
Cincinnati
Cleveland
Aumsville
Wrightsville
Saint Louis
Chicago
Dayton
Wadsworth
Southfield
Nashville
ST
MD
WA
MN
OR
MN
PA
IL
TX
CA
MI
PA
OH
MI
MI
IA
CA
NE
TX
NY
MN
CA
PA
NJ
OH
MD
PA
OR
VA
IL
CT
OH
OH
OR
PA
MO
IL
OH
OH
MI
TN
SIC Codes
3429
3471
3479
3433,3564,3585
3364,3471
3433
3469
3471
3479
3462
3423
3443
3465
3471
3496,3471,3499
3431
3411
3462,3317
3469,3471
3444
3471
2752,3479
3479
3451,3492
3451
3089,3465
3444
3425
3469
3444
3053,3479
3462
3471
3471
3569,3541,
3496, 3449
3479
3465
3471
3365,3366,3471
3471,3496
# of Participating
Facilities
6
1
1
1
1
1
1
1
1
1
1
2
2
1
1
1
1
7
1
1
1
20
1
3
1
2
1
1
1
1
3
4
1
1
4
1
3
1
3
1
1993 Releases
and Transfers
(Ibs.)
487,188
38,900
207,147
20,300
12,606
34,149
12,900
11,880
5
717,558
118,913
8,260
3,623,717
16,021
63,010
250
39,588
1,048,465
1,521,528
66,945
151,509
1,236,689
50,282
1,652,123
13,365
102,983
8,239
27,000
652,519
255
227,242
450,211
4,354
29,462
2,140,497
40,000
329,828
13,149
255,996
750
% Reduction
1988 to 1993
50
78
5
**
13
96
***
50
95
31
***
79
80
52
60
100
8
75
14
***
30
50
21
**
*
50
***
*
45
***
50
50
50
***
50
*
*
***
50
18
September 1995
129
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 40 (cont'd)
33/50 Program
Parent Facility name
Fleet Design Inc.
Fmc Corporation
Ford Motor Company
Foto Mark Inc.
Fulcrum II Limited Partnership
G M Nameplate Inc.
G. W. Lisk Co. Inc.
Gates Corporation
Gayston Corporation
Gefmor (USA) Inc.
General Dynamics Corporation
General Electric Company
General Motors Corporation
Gillette Company
Globe Engineering Company Inc.
Hager Hinge Company
Halliburton Company
Hand Industries Inc.
Handy & Harman
Harrow Industries Inc.
Harsco Corporation
Henkel Corporation
Heresite Protective Coatings
Hi-Shear Industries Inc.
HM Anglo-American Ltd
Hohman Plating & Mfg. Inc.
Hoover Sys. Inc.
Houston Plating Co.
IBM
Illinois Tool Works Inc.
Imagineering Enterprises Inc.
Inco United States Inc.
Parent City
Portland
Chicago
Dearborn
Mendota
Heights
New York
Seattle
Clifton Springs
Denver
Springboro
New York
St Louis
Fairfield
Detroit
Boston
Wichita
Saint Louis
Dallas
Warsaw
New York
Grand Rapids
Camp Hill
KngOfPrussa
Manitowoc
New Hyde Park
New York
Dayton
Dallas
South Houston
Armonk
Glenview
South Bend
New York
ST
TN
IL
MI
MN
NY
WA
NY
CO
OH
NY
MO
CT
MI
MA
KS
MO
TX
IN
NY
MI
PA
PA
WI
NY
NY
OH
TX
TX
NY
IL
IN
NY
SIC Codes
3471
3462,3324,3325
3465,3711
3479
3462
2759,2752,
3679,3993,
3471,3479
3499,3451,
3471,3491
3429,3451
3483,3463
3471,3951
3441,3621
3444, 3724
3651,3694,
3679,3672,3471
3421
3728,3724,
3444, 3599
3429
3443
3471
3471,3469
3429
3469, 3449
3479
3479,2851,2821
3452,3471,
3451,3479
3423
3471,2851,3479
2542,3444,3441
3471
3672,3579,3471
3469
3471
3462, 3463
# of Participating
Facilities
3
1
5
1
1
1
1
1
1
1
1
7
15
1
1
2
1
1
3
1
8
1
1
1
4
1
1
1
1
3
1
1
1993 Releases
and Transfers
(Ibs.)
522
502,318
15,368,032
73,325
77,680
15,405
15,548
478,941
33,355
9,088
588,246
5,010,856
16,751,198
21,497
18,678
97,121
16,884
37,000
477,150
128,355
415,574
164,363
367
8,226
1,265,741
13,293
510
997
1,411,304
673,128
11,282
346,594
% Reduction
1988 to 1993
80
50
15
5
24
50
*
***
56
50
84
50
*
99
*
64
**
***
50
*
**
55
50
50
2
**
27
*
1
***
***
26
SIC Code 34
130
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 40 (cont'd)
33/50 Program
Parent Facility name
Indal Ltd
Indianhead Plating Inc.
Industrial Hard Chrome Ltd.
Ingersoll-Rand Company
Interlake Corporation
International Paper Company
ITT Corporation
Jacobson Mfg Co. Inc.
Jefferson City Mfg. Co. Inc.
Jor-Mac Company Inc.
Jordan-Edmiston Group Inc.
Kaspar Electroplating Corp
Kelso Asi Partners L P
Kennedy Mfg. Co.
Kitzinger Cooperage Corp
Lacks Enterprises Inc.
Lawrence Brothers Inc.
Leco Corporation
Litton Industries Inc.
Lord Corporation
Lorin Ind.
LTV Steel Co. Inc.
Luke Engineering & Mfg Corp
Macklanburg-Duncan Co.
Marmon Group, Inc.
Martin Marietta Corporation
Masco Industries Inc.
Masco tech
Matec Corporation
Meaden Screw Products Company
Mechanical Galv-Plating Corp
Meco Inc.
Metallics Inc.
Metromedia Company
Midwest Plating Company Inc.
Parent City
Weston,
Ontario,
Canada
Chippewa Falls
Geneva
WoodcliffLake
Lisle
Purchase
New York
Kenilworth
Jefferson City
Grafton
New York
Shiner
New York
Van Wert
Saint Francis
Grand Rapids
Sterling
Saint Joseph
Beverly Hills
Erie
Muskegon
Cleveland
Wadsworth
Oklahoma City
Chicago
Bethesda
Taylor
Taylor
Hopkinton
Burr Ridge
Sidney
Paris
Onalaska
E Rutherford
Grand Rapids
ST
WI
IL
NJ
IL
NY
NY
NJ
MO
WI
NY
TX
NY
OH
WI
MI
IL
MI
CA
PA
MI
OH
OH
OK
IL
MD
MI
MI
MA
IL
OH
IL
WI
NJ
MI
SIC Codes
3442
3471
3471
3429
3441
8731,3471,3544
3471,3479,3498
3452
3363,3451,3469
3499, 3479
3421
3471
3585,3433,3564
3469
3412,5085,5805
3089,3471
3429
3826,3471,3229
3731,3441,3443
3069,3471
3471,3354
3471
3471
3429
3451
3769,3499,
3479,3471
3398,3471
3465
3479,2899,3489
3451
3479
3443
3479
3451,3499
3471
# of Participating
Facilities
3
1
2
4
1
1
3
1
1
1
1
1
1
2
1
3
1
1
1
2
1
1
1
1
5
1
13
9
1
1
1
1
1
1
1
1993 Releases
and Transfers
(Ibs.)
303,909
14,005
13,213
96,553
159,932
2,784,831
735,332
12
4,850
4,995
332,930
56
355,557
69,756
84
867,354
6,827
6,800
332,264
1,111,309
25,500
612,924
6,600
23,376
1,092,218
223,286
488,484
3,163,830
21,800
12,860
3,448
51,864
27,720
295,322
520
% Reduction
1988 to 1993
*
***
*
60
37
50
7
*
**
***
27
*
43
80
50
27
50
14
**
58
50
60
**
***
1
73
***
35
*
40
***
***
50
*
50
September 1995
131
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 40 (cont'd)
33/50 Program
Parent Facility name
Miller Smith Mfg. Co.
Modern Metal Products Co.
Modern Welding Company
Modine Manufacturing Company
Morgan Stanley Leveraged Fund
Napco Inc.
Nashua Corp.
National Forge Company
National Semiconductor Corp.
New Dimension Plating Inc.
Newell Co.
Norandal USA
North American Investment Prop
Northland Stainless Inc.
Norton Company
Oak Industries Inc.
Oberg Industries Inc.
Oregon Sand Blasting & Coating
Owens-Illinois Inc.
Pace Industries Inc.
Parker Hannifin Corporation
Pechiney Corporation
Penn Engineering & Mfg
Philip Morris Companies Inc.
Photocircuits Corporation
PMF Ind. Inc.
Precision Plating Inc.
Precision Products Group Inc.
Premark International Inc.
Process Engineering Co. Inc.
Production Paint Finishers
Prospect Purchasing Co. Inc.
Parent City
Spring Lake
Loves Park
Owensboro
Racine
New York
Valencia
Nashua
Irvine
Santa Clara
Hutchinson
Freeport
Brentwood
Hawthorne
Tomahawk
Worcester
Waltham
Freeport
Tualatin
Toledo
New York
Cleveland
Greenwich
Danboro
New York
Glen Cove
Williamsport
Minneapolis
Rockford
Deerfield
Jackson
Bradford
N Brunswick
ST
MI
IL
KY
WI
NY
PA
NH
PA
CA
MN
IL
TN
NY
WI
MA
MA
PA
OR
OH
NY
OH
CT
PA
NY
NY
PA
MN
IL
IL
MS
OH
NJ
SIC Codes
3471
3471
3441,3443
3443,3714
3724,3471
3499, 3444,
3446, 3442, 3479
2672,3572,
3577,2869,
2821,3479
3462
3679,3674,3471
3471
3471,3496
3353,3479
3443
3443
3425
3451,3471,3398
3469,3471,3089
3479
3469
3639, 3444, 3469
3451,3492,3494
3479,3724
3452
3479,3468
3672,3471
3499,3471
3471
3398,3469,
3495,3493,3499
3556,3325,3444
3471
3479
3412
# of Participating
Facilities
1
1
1
4
2
1
2
1
1
1
5
1
1
1
1
1
1
1
2
1
9
1
1
1
1
1
1
1
2
1
1
1
1993 Releases
and Transfers
(Ibs.)
17,247
163
5
488,996
2,166,420
41,037
1,818,504
3,100
23,173
17,300
324,283
627,740
11,755
7,570
40,831
34,128
18,435
14,660
412,573
14,530
244,966
216,177
111,897
259,053
292,178
13,015
10,155
149,834
140,313
10,305
11,584
47,275
% Reduction
1988 to 1993
***
71
*
50
13
60
**
*
6
35
23
6
70
***
63
16
85
*
***
**
50
***
100
**
92
34
***
***
***
50
60
50
SIC Code 34
132
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 40 (cont'd)
33/50 Program
Parent Facility name
Protective Coatings Inc.
Providence Metallizing Co. Inc.
Quality Rolling & Deburring Co.
R P Adams Company Inc.
Raytheon Company
Rehrig International Inc.
Reilly Plating Co.
Reliance Finishing Co.
Reynolds Metals Company
S. K. Williams Co.
Schuller Corporation
Seneca Foods Corporation
Siebe Industries Inc.
Skills Inc.
Smith Everett Investment Co.
Smith System Manufacturing Co.
Sommer Metalcraft Corp
Sonoco Products Company
Southline Metal Products Co.
Spx Corporation
Stanley Works
Sunset Fireplace Fixtures
Super Radiator Coils Ltd
Superior Plating Inc.
Surftech Finishes Company
Swva Inc.
Tawas Plating Company
Tech Industries Inc.
Techmetals Inc.
Tektronix Inc.
Tenneco Inc.
Texas Instruments Incorporated
Therma-Tru Corp
Thiokol Corporation
Thomas Steel Strip Corp
Trinova Corporation
U T I Corporation
United States Can Company Del
United Technologies Corp
US Can Corporation (Del)
Parent City
Kent
Pawtucket
Thomaston
Tonawanda
Lexington
Richmond
Nanticoke
Grand Rapids
Richmond
Wauwatosa
Denver
Pittsford
Richmond
Seattle
Milwaukee
Piano
Crawfordsville
Hartsville
Houston
Muskegon
New Britain
City Of
Industry
Minneapolis
Minneapolis
Kent
Huntington
Tawas City
Woonsocket
Dayton
Beaverton
Houston
Dallas
Sylvania
Ogden
Warren
Maumee
Collegeville
Hinsdale
Hartford
Oak Brook
ST
WA
RI
CT
NY
MA
VA
PA
MI
VA
WI
CO
NY
VA
WA
WI
TX
IN
SC
TX
MI
CT
CA
MN
MN
WA
WV
MI
RI
OH
OR
TX
TX
OH
UT
OH
OH
PA
IL
CT
IL
SIC Codes
3471,3479
3479,3471
3471
3469
3672,3471,3674
3471
3471
3479
3479
3471
3444
3411
3400,3471
3479
3444
3444,2531
3471
2655,3469
3412
3479
3471
3429
3400
3471
3471
3441
3471
3089,3471
3471
3663, 3444
3441
3822,2812,
3356,3471,
3714,3341
3442,3089
3452
3471,3316
3451,3498
3469
3412,3411
3086,3471
3411
# of Participating
Facilities
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
2
1
1
10
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
2
7
1993 Releases
and Transfers
(Ibs.)
41,137
35,347
287,324
20
706,045
2,261
750
11,400
2,055,294
126
24,694
19,717
849,335
7,650
240,445
499
1,500
621,380
77,552
554,822
508,199
12,800
139,235
39,406
20,270
43,405
3,265
27,003
10,645
12,393
1,272,423
344,225
17,255
1,001,162
6,839
488,879
473,872
5,299
2,393,252
573,088
% Reduction
1988 to 1993
***
70
***
***
50
***
2
**
38
*
***
50
2
***
89
*
*
i
***
2
50
25
82
***
*
27
50
64
50
*
8
25
41
40
50
50
50
*
50
37
September 1995
133
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 40 (cont'd)
33/50 Program
Parent Facility name
Valley Plating Works
Valley Technologies Inc.
Van Der Horst Usa Corporation
Veba Corporation
W W Custom Clad Inc.
W. J. Roscoe Co.
Walter Industries Inc.
Warner-Lambert Company
Weiss-Aug Co. Inc.
Wheeling-Pittsburgh Corp
Whirlpool Corporation
Whyco Chromium Company Inc.
Winona Corporation
Wisconsin Tool & Stamping Co.
WNA Inc.
Worldwide Cryogenics Holdings
Wright Products Corp
York Metal Finishing Co.
Zippo Manufacturing Company
Parent City
Los Angeles
Valley Park
Terrell
Houston
Canajoharie
Akron
Tampa
Morris Plains
East Hanover
Wheeling
Benton Harbor
Thomaston
Winona Lake
Schiller Park
Wilmington
Minneapolis
Minneapolis
Philadelphia
Bradford
ST
CA
MO
TX
TX
NY
OH
FL
NJ
NJ
WV
MI
CT
IN
IL
DE
MN
MN
PA
PA
SIC Codes
3471
3398,3463
3471
3471,3599
3471
2851,2891,
2517,3479
3321,3479
3421
3465,3469
3479
3450,3471,3490
3471
3479
3469
3449
3443
3429
3471
3421
# of Participating
Facilities
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
2
1993 Releases
and Transfers
(Ibs.)
130
0
20,623
24,254
8,595
40,051
859,751
146,333
15,834
560,055
1,540,866
88,737
47,260
42,000
248,148
133,810
45,287
5
189,929
% Reduction
1988 to 1993
75
**
**
10
50
50
***
40
**
66
50
50
50
**
***
*
***
*
50
* = not quantifiable against 1988
data.
** = use reduction goal only.
*** = no numerical goal.
Environmental Leadership Program
The Environmental Leadership Program (ELP) is a national initiative
piloted by EPA and State agencies in which facilities have volunteered
to demonstrate innovative approaches to environmental management
and compliance. EPA has selected 12 pilot projects at industrial
facilities and Federal installations which will demonstrate the
principles of the ELP program. These principles include:
environmental management systems, multimedia compliance
assurance, third-party verification of compliance, public measures of
accountability, community involvement, and mentoring programs. In
return for participating, pilot participants receive public recognition
and are given a period of time to correct any violations discovered
during these experimental projects. At present, no metal finishing or
fabricating facilities are carrying out ELP pilot projects. (Contact: Tai-
ming Chang, ELP Director, (202) 564-5081 or Robert Fentress, (202)
564-7023)
SIC Code 34
134
September 1995
-------
Fabricated Metal Products Sector Notebook Project
Gillette ELP Project
The objective of the Gillette Environmental Leadership Program is the
development and implementation of a third party compliance and
management systems audit and verification process. The project will
involve the development of environmental compliance and
environmental management systems audit protocol criteria that can be
adopted and easily implemented by other facilities to assess
compliance with relevant regulations. The three Gillette facilities that
are participating are: South Boston Manufacturing Center, blade and
razor manufacturing; North Chicago Manufacturing Center, batch
chemical manufacturing; and Santa Monica, CA, stationary products
manufacturing. (Contact: Scott Throwe, (202) 564-7013).
Project XL
Project XL was initiated in March 1995 as a part of President Clinton's
Reinventing Environmental Regulation initiative. The projects seek to
achieve cost effective environmental benefits by allowing participants
to replace or modify existing regulatory requirements on the condition
that they produce greater environmental benefits. EPA and program
participants will negotiate and sign a Final Project Agreement,
detailing specific objectives that the regulated entity shall satisfy. In
exchange, EPA will allow the participant a certain degree of
regulatory flexibility and may seek changes in underlying regulations
or statutes. Participants are encouraged to seek stakeholder support
from local governments, businesses, and environmental groups. EPA
hopes to implement fifty pilot projects in four categories including
facilities, sectors, communities, and government agencies regulated by
EPA. Applications will be accepted on a rolling basis and projects will
move to implementation within six months of their selection. For
additional information regarding XL Projects, including application
procedures and criteria, see the May 23, 1995 Federal Register Notice.
Contact Jon Kessler, Office of Policy Analysis, (202) 260-4034.
Green Lights Program
EPA's Green Lights program was initiated in 1991 and has the goal of
preventing pollution by encouraging U.S. institutions to use energy-
efficient lighting technologies. The program has over 1,500
participants which include major corporations; small and medium
sized businesses; Federal, State and local governments; non-profit
groups; schools; universities; and health care facilities. Each
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participant is required to survey their facilities and upgrade lighting
wherever it is profitable. EPA provides technical assistance to the
participants through a decision support software package, workshops
and manuals, and a financing registry. EPA's Office of Air and
Radiation is responsible for operating the Green Lights Program.
(Contact: Susan Bullard, (202) 233-9065 or the Green Light/Energy
Star Hotline at (202) 775-6650)
WasteWi$e Program
The WasteWi$e Program was started in 1994 by EPA's Office of Solid
Waste and Emergency Response. The program is aimed at reducing
municipal solid wastes by promoting waste minimization, recycling
collection, and the manufacturing and purchase of recycled products.
As of 1994, the program had about 300 companies as members,
including a number of major corporations. Members agree to identify
and implement actions to reduce their solid wastes and must provide
EPA with their waste reduction goals along with yearly progress
reports. EPA in turn provides technical assistance to member
companies and allows the use of the WasteWi$e logo for promotional
purposes. (Contact: Lynda Wynn, (202) 260-0700 or the WasteWi$e
Hotline at (800) 372-9473)
Climate Wise Recognition Program
The Climate Change Action Plan was initiated in response to the U.S.
commitment to reduce greenhouse gas emissions in accordance with
the Climate Change Convention of the 1990 Earth Summit. As part of
the Climate Change Action Plan, the Climate Wise Recognition
Program is a partnership initiative run jointly by EPA and the
Department of Energy. The program is designed to reduce
greenhouse gas emissions by encouraging reductions across all sectors
of the economy, encouraging participation in the full range of Climate
Change Action Plan initiatives, and fostering innovation. Participants
in the program are required to identify and commit to actions that
reduce greenhouse gas emissions. The program, in turn, gives
organizations early recognition for their reduction commitments;
provides technical assistance through consulting services, workshops,
and guides; and provides access to the program's centralized
information system. At EPA, the program is operated by the Air and
Energy Policy Division within the Office of Policy Planning and
Evaluation. (Contact: Pamela Herman, (202) 260-4407)
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NICE3
The U.S. Department of Energy and EPA's Office of Pollution
Prevention are jointly administering a grant program called The
National Industrial Competitiveness through Energy, Environment,
and Economics (NICE^). By providing grants of up to 50 percent of
the total project cost, the program encourages industry to reduce
industrial waste at its source and become more energy-efficient and
cost-competitive through waste minimization efforts. Grants are used
by industry to design, test, demonstrate, and assess the feasibility of
new processes and/or equipment with the potential to reduce
pollution and increase energy efficiency. The program is open to all
industries; however, priority is given to proposals from participants in
the pulp and paper, chemicals, primary metals, and petroleum and
coal products sectors. (Contact: DOE's Golden Field Office, (303) 275-
4729)
VIII.C. Trade Association/Industry Sponsored Activity
Associations, universities, and the industry are currently working with
EPA to make the Agency aware of issues that relate to metal
fabricating and finishing industries. As a result of these relationships
and overall interest in achieving compliance and reducing pollution,
additional research relating to process techniques and pollution
prevention alternatives is being conducted. Various workshops and
training opportunities have resulted from these efforts. A summary of
some trade association and industry activities is presented below,
along with some associations related to this industry.
VIII.C.I. Environmental Programs
Several trade and professional associations are working with EPA to
make the Agency aware of issues that relate to metal fabricating
industries. For example, the Copper and Brass Fabricators Council
(CBFC) has been assisting EPA's Office of Solid Waste regarding
recycling issues as it develops or redrafts RCRA regulations. CBFC is
communicating its experiences with metal fabricating to EPA, in terms
of materials used and possible recycling options, in hopes that future
regulations might complement the industry's processes.
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Additionally, several organizations have sponsored workshops
focusing on waste minimization and pollution prevention in several
fabricated metal related industries. Three workshops, the Hazardous
Waste Management for Small Business Workshop, the
Environmentally Conscious Painting Workshop, and the Pollution
Prevention Workshop for the Electroplating Industry, are discussed
below.
Hazardous Waste Management for Small Business Workshop
The University of Northern Iowa, with support from EPA, Des Moines
Area Community College, Northeast Iowa Community College, Scott
Community College, and Indiana Hills Community College,
sponsored a Hazardous Waste Management for Small Business workshop.
This workshop was geared towards small businesses and was
intended to provide practical answers to environmental regulatory
questions. Small businesses covered by the workshop include:
manufacturers, vehicle maintenance and repair shops, printers,
machine shops, and other businesses that generate potentially
hazardous waste. Topics covered include: hazardous waste
determination, waste generator categories, management of specific
common waste streams, including used oil and solvents, and pollution
prevention. (Contact: Duane McDonald, (319) 273-6899)
Environmentally Conscious Painting Workshop
Kansas State University, NIST/Mid-America Manufacturing
Technology Center, Kansas Department of Health & Environment,
EPA Region 7, Allied Signal, Inc., Kansas City Plant, and the U.S.
Department of Energy sponsored the Environmentally Conscious
Painting workshop. This workshop covered topics such as upcoming
regulations and the current regulatory climate, methods to cost-
effectively reduce painting wastes and emissions, and alternative
painting processes. (Contact: the Kansas State University Division of
Continuing Education, (913) 532-5566)
Pollution Prevention Workshop for the Electroplating Industry
Kansas State University Engineering Extension, EPA Region 7, Kansas
Department of Health and Environment, and the University of Kansas
sponsored the Pollution Prevention Workshop for the Electroplating
Industry. The workshop described simple techniques for waste
reduction in the electroplating industry, including: plating, rinsing
processes and wastewater, wastewater management options, metals
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recovery options, waste treatment and management, and product
substitutions and plating alternatives. (Contact: the Kansas State
University Division of Continuing Education, (800) 432-8222)
VIII.C.2. Summary of Trade Associations
Various trade associations represent the interests of metal fabricator
workers and the industry itself. Some of these organizations are
discussed in greater detail below.
American Electroplaters and Surface Finishers
Society (AESF)
12644 Research Parkway
Orlando, FL 32826
Phone: (407) 281-6441
Fax: (407) 281-6446
Members:
Staff:
Budget:
Contact:
10,000
21
2,000,000
Ted Witt, Executive
Director
Founded in 1909, AESF is an international professional society of
scientists, technicians, job shop operators, and others interested in
research in electroplating, surface finishing, and allied arts. AESF
offers classroom training courses, home study courses, cooperative
programs, and a voluntary certification program. In addition, it
bestows awards, conducts research programs, and provides an
insurance program for job shop owners. AESF also publishes Plating
and Surface Finishing (monthly), AESF Shop Guide, books, symposia
proceedings, research reports, and training booklets with slide
presentations; and makes available films and videotapes.
ASM International (ASM)
9639 Kinsman
Materials Park, OH 44073
Phone: (216) 338-5151
Members: 54,000
Staff: 145
Budget: $19,500,000
Contact: Edward L. Langer
Founded in 1920, ASM represents metallurgists; materials engineers;
executives in materials producing and consuming industries; and
teachers and students. This association disseminates technical
information about the manufacture, use, and treatment of engineered
materials. It offers in-plant, home study, and intensive courses
through the Materials Engineering Institute; conducts conferences,
seminars, and lectures; presents awards to teachers of materials
science and for achievements in the field; and grants scholarships and
fellowships. Additionally, it maintains a library of 10,000 volumes on
metals and other materials.
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Copper and Brass Fabricators Council (CBFC)
1050 17th Street, NW, Suite 440
Washington, DC 20036
Phone: (202) 833-8575
Contact: Joseph L. Mayer
Founded in 1966, CBFC represents copper and brass fabricators. Its
activities involve foreign trade in copper and brass fabricated
products, and Federal regulatory matters including legislation,
regulations, rules, controls, stockpiling, and other similar measures
affecting domestic fabricators of copper and brass products. CBFC
holds an annual convention.
Metal Construction Association (MCA)
1101 14th Street, NW, Suite 1100
Washington, DC 20005
Phone: (202) 371-1243
Fax: (202) 371-1090
Members: 100
Staff: 5
Contact: David W. Barrack
Founded in 1983, MCA represents individuals engaged in the
manufacture, design, engineering, sale, or installation of metal used in
construction, and others interested in the metal construction industry.
It promotes the use of metal in all construction applications.
Additionally, MCA represents all sectors of the metal construction
industry; fosters better trade practices and improved communication
within the industry; serves as liaison between members and other
industry organizations. The association collects and disseminates
information; maintains the Merit Award Program to acknowledge
outstanding buildings, products, and systems in the industry; plans
programs in institutional advertising, voluntary standards, and
statistics; proposed educational programs including structure erection,
estimating, and bookkeeping; compiles statistics; and bestows
scholarships. MCA also prepares and distributes two publications:
the Metal Construction Association-Membership Directory (annually) and
the Metal Construction Association-Newsletter (quarterly). Its newsletter
includes technical articles, meeting reviews, committee reports,
minutes, and a calendar of events. MCA holds a semiannual meeting
and Metalcon International Trade Show and an annual meeting.
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Metal Fabricating Institute (FMI)
PO Box 1178
Rockford, IL61105
Phone: (815) 965-4031
Staff: 4
Contact: Ronald L. Fowler
Founded in 1968, MFI conducts technical seminars for structural and
sheet metal fabricators to update management on the latest
manufacturing techniques. MFI also presents a Fabricating Engineer
of the Year Award. In addition, it publishes Metal Fabricating News
(bimonthly), which contains a calendar of events, new products and
literature, book reviews, and a buyers guide. The association also
holds a semiannual conference in West Lafayette, Indiana.
Metal Finishers Suppliers Association (MFSA)
801 North Cass, Ste. 300
Westmont, IL 60559
Phone: (708) 887-0797
Members: 180 Companies
Staff: 2-4
Budget: $400,000
Contact: Richard Grain
Incorporated in 1951, MFSA is the only trade association representing
companies that supply chemicals and equipment to the metal finishing
industry. MFSA works closely with organizations that represent the
metal finishing industry, such as AESF (see above) and the National
Association of Metal Finishers (see below), and is involved in several
joint programs, including an annual conference. In addition, MFSA
publishes a monthly newsletter and has published a dozen technical
papers to inform and assist its members.
National Association of Metal Finishers
(NAMF)
401 N. Michigan Avenue
Chicago, IL 60611-4267
Phone: (312) 644-6610
Members: 940
Staff: 6
Budget: $750,000
Contact: Brad Parcells
Founded in 1955, NAMF represents management executives of firms
engaged in plating, hard chroming, galvanizing, electroforming,
metalizing, organic coating, phosphating, rust proofing, polishing,
buffing, anodizing, and other forms of metal finishing. NAMF is
concerned primarily with management education, development of
finishing standards, and legislative issues. In addition, it publishes
Finishers' Management, a trade magazine of the plating and finishing
industry. NAMF also produces Finishing Line (monthly), Legislative
Line (bi-monthly), and NAMF Regulatory Compliance Manual. NAMF
holds an annual trade show.
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Precision Metalforming Association (PMA)
27027 Chardon Road
Richmond Heights, OH 44143
Phone: (216) 585-8800
Fax: (216) 585-3126
Members: 1,000
Staff: 20
Budget: $3,000,000
Contact: Jon E. Jenson
Founded in 1942, PMA represents manufacturers of metal stampings,
precision metal fabrications, and metal spinnings, and their suppliers.
PMA provides information and technical services to members. It also
presents numerous awards and publishes Metalforming, a monthly
magazine that addresses: materials and equipment, electronics in
metal forming and assembly, taxes, legal issues, and management.
Society for Mining, Metallurgy, and
Exploration, Inc. (SME)
PO Box 625005
Littleton, CO 80162
Phone: (303) 973-9550
Members: 20,000
Staff: 31
Budget: $3,700,000
Contact: Gary D. Howell
Founded in 1871, SME represents individuals engaged in the finding,
exploitation, treatment, and marketing of all classes of minerals (metal
ores, industrial minerals, and solid fuel) except petroleum.
Additionally, it offers specialized education programs; and compiles
enrollment and graduation statistics from schools offering engineering
degrees in mining, mineral, mineral processing/metallurgical,
geological, geophysical technology.
United Steelworkers of America (USWA)
5 Gateway Center
Pittsburgh, PA 15222
Phone: (412) 562-2400
Fax: (412) 562-2445
Members: 675,000
Staff: 475
Contact: George Becker
Founded in 1936, this association has absorbed numerous associations
for steel workers. Currently, this agency publishes Steelabor ten times
a year. This news magazine reports on legislation and regulation
affecting the union, union activities at the national and chapter levels,
economic developments, pension news, and information on safety and
health. USWA also publishes the Steelworker Old Time, quarterly; and
holds a biennial convention.
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IX. Contacts/Acknowledgments/Resource Materials/Bibliography and Other
References
General Profile
Construction Materials, DOC, U.S. Industrial Outlook 1994.
Industry Profile for the Metal Finishing Industry, Meridian Research Inc., U.S.
EPA/OPPT, June 24, 1994.
1987 Census of Manufacturers Industry Series 34A: Metal Cans, Cutlery, Handtools, U.S.
Department of Commerce, Bureau of the Census, April 1990. (MC87-I-34A)
1987 Census of Manufacturers Industry Series 34B: Heating Apparatus and Plumbing
Fixtures, Bureau of the Census, April 1990. (MC87-I-34B)
1987 Census of Manufacturers Industry Series 34C: Fabricated Structural Metal Products,
Bureau of the Census, April 1990. (MC87-I-34C)
1987 Census of Manufacturers Industry Series 34D: Screw Machine Products, Bureau of
the Census, April 1990. (MC87-I-34D)
Process Description
Emissions From Metal Finishing Operations, Draft Report, U.S. EPA, Office of Research
and Development, March 31, 1995.
Hot Dip Galvanized Coatings, American Society for Metals Committee on Hot Dip
Galvanized Coatings, Metals Handbook, 9th Edition, Volume 5.
Machining, American Society for Metals, Metals Handbook: 9th Edition, Volume
16, 1989.
McGrawHill Encyclopedia of Science and Technology, Volume 6, 1987.
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Metals Handbook, Ninth Edition; Volume 5, Surface Cleaning, Finishing, and Coating,
1982, American Society for Metals.
Properties and Selection: Stainless Steels, Tool Materials and Special Purpose Materials,
American Society for Metals, Metals Handbook, 9th Edition, Volume 3, 1980.
Selection of Cleaning Process Metals, American Society for Metals Committee on
Selection of Cleaning Process, Handbook, 9th Edition.
Surface Cleaning, Finishing, and Coating, American Society for Metals, Metals
Handbook: 9th Edition, Volume 5, 1982.
Regulatory Profile
U.S. EPA OPPTS Title III Section 313 Release Reporting Guidance: Estimating Chemical
Releases from Electroplating Operations, 1988.
Guidance Manual for Electroplating and Metal Finishing Pretreatment Standards, U.S.
EPA/Effluent Guidelines Division and Permits Division, 1984.
Listing of Hazardous Waste (40 CFR 261.31 and 261.32): Identification and Listing of
Hazardous Waste Under RCRA, Subtitle C, Section 3001, U.S. EPA, May 1980.
Pollution Prevention
Guides to Pollution Prevention: The Metal Finishing Industry, U.S. EPA, ORD, October
1992.
Minnesota Technical Assistance Program Checklists for Identifying Waste Reduction
Opportunities.
Pollution Prevention In Metal Manufacturing: Saving Money Through Pollution
Prevention, U.S. EPA, OSW, October 1989.
Pollution Prevention Options In Metal Fabricated Products Industries: A Bibliographic
Report, U.S. EPA, OPPT, January 1992.
Sustainable Industry: Promoting Strategic Environmental Protection in the Industrial
Sector, Phase 1 Report, U.S. EPA, OPPE, June 1994.
Toxic Chemical Release Inventory: Clarification and Guidance for the Metal Fabrication
Industry, U.S. EPA, OTS, 1990.
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Contacts*
Name
Paul Beatty
Bob Benson
Marty Borruso
Jim Callier
Doug Fine
Marilyn Goode
Kris Goschen
Mardi Klevs
Larry Lins
John Robison
William Saas
Paul Shapiro
William Sonntag
Organization
U.S. EPA Region VII
U.S. EPA, Office of Policy,
Planning and Evaluation
American Electroplaters and
Surface Finishers Society
U.S. EPA Region VII
Massachusetts Department of
Environmental Protection
U.S. EPA Office of Solid Waste
U.S. EPA Region VII, Southeast
Michigan Initiative
U.S. EPA SEMI Coordinator
U.S. EPA Region V
U.S. EPA, Office of Pollution
Prevention and Toxics
Taskem, Inc., Metal Finishers
Suppliers' Association
U.S. EPA, Office of Research and
Development
National Association of Metal
Finishers, American Electroplaters
and Surface Finishers Society
Telephone
(913) 551-5089
(202) 260-8668
(718) 720-6646
(913) 551-7646
(617) 556-1049
(202) 260-6299
(913) 551-5078
(312) 353-5490
(216) 835-5200
(202) 260-3590
(216) 351-1500
(202) 260-4969
(202) 965-5190
Many of the contacts listed above provided valuable information and comments during the
development of this doucment. EPA appreciated this support and acknowledges that the
indivduals listed do not necessarily endorse all statements made within this notebook.
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