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
                      iii
                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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Fabricated Metal Products
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
      September 1995

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Sector Notebook Project
                  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
IX
                            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
xi
SIC Code 34

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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
          SIC Code 34

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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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                                    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
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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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             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
                    Sector Notebook Project
                                    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.
SIC Code 34
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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.
September 1995                            21                           SIC Code 34

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Fabricated Metal Products	Sector Notebook Project
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.
SIC Code 34                               22                         September 1995

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Fabricated Metal Products
                    Sector Notebook Project
                                    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
September 1995
23
SIC Code 34

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Fabricated Metal Products
                    Sector Notebook Project
                                    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
24
September 1995

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Fabricated Metal Products	Sector Notebook Project


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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Fabricated Metal Products	Sector Notebook Project


             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.
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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
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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
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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.
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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

-------
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

-------
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

-------
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

-------
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

-------
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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            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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            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.
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            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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            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.
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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.
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             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.
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            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.
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            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
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             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
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             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
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       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).
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       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.
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       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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       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:
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       $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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       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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        •   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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       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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       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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       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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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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       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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       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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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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              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
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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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            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
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                                  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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            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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            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.
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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.
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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.
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            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
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            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
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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
111
SIC Code 34

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Fabricated Metal Products
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                                  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
113
SIC Code 34

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Fabricated Metal Products
                      Sector Notebook Project
                                      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

-------
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

-------
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

-------
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
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                              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)
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             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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Fabricated Metal Products	Sector Notebook Project


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.
SIC Code 34                               144                         September 1995

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Fabricated Metal Products
                                  Sector Notebook Project
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.
September 1995
               145
       SIC Code 34

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