United States
Agency
Industry
SECTOR
NOTEBCXDKS
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE ADMINISTRATOR
Message from the Administrator
Over the past 25 years, our nation has made tremendous progress in protecting public health and
our environment while promoting economic prosperity. Businesses as large as iron and steel
plants and businesses as small as the dry cleaner on the corner have worked with EPA to find
ways to operate cleaner, cheaper, and smarter. As a result, we no longer have rivers catching on
fire. Our skies are clearer. American environmental technology and expertise are in demand
throughout the world.
The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.
Within the past two years, the Environmental Protection Agency undertook its Sector Notebook
Project to compile, for a number of key industries, information about environmental problems and
solutions, case studies and tips about complying with regulations. We called on industry leaders,
state regulators, and EPA staff with many years of experience in these industries and with their
unique environmental issues. Together with notebooks for 17 other industries, the notebook you
hold in your hand is the result.
These notebooks will help business managers to better understand their regulatory requirements,
learn more about how others in their industry have undertaken regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.
I encourage you to use this notebook to evaluate and improve the way that together we achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that — in industry after industry, community after community ~
environmental protection and economic prosperity go hand in hand.
Carol M. Brown
Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)
-------
Fabricated Metal Products
Sector Nolebool 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
401 M St., SW (MC 2221-A)
Washington, DC 20460
For sale by the U.S. Government Printing Office
Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
ISBN 0-16-048274-7
SIC Code 34
September 1995
-------
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 at the end of this
document.
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 on the EPA Enviro$en$e
Bulletin Board and via Internet on the Enviro$en$e World Wide Web.
Downloading procedures are described in Appendix A of this document.
Cover photograph by Steve Delaney, U.S. EPA.
Atlantic Finishing, Capitol Heights, Maryland.
Photograph courtesy of Mi'd-
Septemberl995
SIC 34
-------
Sector Notebook Contacts
The Sector Notebooks were developed by the EPA's Office of Compliance. Particular questions regarding the
Sector Notebook Project in general can be directed to:
Seth Heminway, Sector Notebook Project Coordinator
US EPA, Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7017 fax (202) 564-0050
E-mail: heminway.seth@epamail.epa.gov
Questions and comments regarding the individual documents can be directed to the appropriate specialists listed
below.
Document Number
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310
•R-95-001.
R-95-002.
R-95-003.
-R-95-004.
-R-95-005.
-R-95-006.
-R-95-007.
-R-95-008.
-R-95-009.
-R-95-010.
-R-95-011.
-R-95-012.
-R-95-013.
•R-95-014.
-R-95-015.
-R-95-016.
•R-95-017.
-R-95-018.
•R-97-001.
•R-97-002.
•R-97-003.
-R-97-004.
•R-97-005.
-R-97-006.
R-97-007.
•R-97-00.8.
R-97-009.
•R-97-010.
EPA/310-B-96-003.
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
Pharmaceutical 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
Federal Facilities
Contact
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Keith Brown
Suzanne Childress
Jane Engert
Keith Brown
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Maria Eisemann
Maria Malave
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Suzanne Childress
Belinda Breidenbach
Seth Heminway
Jim Edwards
Phone (202)
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-7124
564-7018
564-5021
564-7124
564-7067
564-7003
564-7072
564-7016
564-7027
564-7013
564-7057
564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-7018
564-7022
564-7017
564-2461
*Currently in DRAFT anticipated publication in September 1997
This page updated during June 1997 reprinting
-------
Fabricated Metal Products
Sector Notebool Project
FABRICATED METAL PRODUCTS
(SIC 34)
TABLE OF CONTENTS
Page
EXHIBIT INDEX vn
LIST OF ACRONYMS ix
I. INTRODUCTION OF THE SECTOR NOTEBOOK PROJECT I
LA. Summary of the Sector Notebook Project I
LB. Additional Information 2
n. INTRODUCTION TO THE FABRICATED METAL PRODUCTS INDUSTRY 4
n.A. Introduction, Background, and Scope of the Notebook 4
n.B. Characterization of the Fabricated Metal Products Industry 4
n.B.l. Industry Size and Geographic Distribution 4
n.B.2. Product Characterization 9
H.B.3. Economic Trends 9
m. INDUSTRIAL PROCESS DESCRIPTION 12
EI.A. Industrial Processes in the Fabricated Metal Products
Industry 12
ffi.A.l. Fabricated Metal Products 13
IE.A.2. Surface Preparation 15
IE.A.3. Metal Finishing 16
ITLB. Raw Material Inputs and Pollution Outputs in the
Production Line • 21
m.B.l. Metal Fabrication 24
in.B.2. Surface Preparation 25
m.B.3. Metal Finishing 25
Management of Chemicals in Wastestream 29
SIC Code 34
IV
September 1995
-------
Sector Notebook Project
Fabricated Metal Products
IV.
V.
VI.
FABRICATED METAL PRODUCTS
(SIC 34)
TABLE OF CONTENTS (CONT'D)
Page
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
FV.C. Other Data Sources 53
IV.D. Comparison of Toxic Release Inventory Between Selected
Industries 55
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
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
September 1995
SIC Code 34
-------
Fabricated Metal Products
Sector Notebool Project
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
VTI.C. Review of Major Legal Actions Ill
VII.C.l Review of Major Cases Ill
VH.C.2 Supplemental Environmental Projects 112
VIH. COMPLIANCE ACTIVITIES AND INITIATIVES 116
VIILA. Sector-Related Environmental Programs and Activities 116
Vin.B. EPA Voluntary Programs 122
Vm.C. Trade Association/Industry Sponsored Activity 132
Vm.C.l. Environmental Programs 132
VHLC.2. Summary of Trade Associations 134
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/
BIBLIOGRAPHY AND OTHER REFERENCES 138
SIC Code 34
VI
September 1995
-------
Sector Notebook Project
Fabricated Metal Products
FABRICATED METAL PRODUCTS
(SIC 34)
EXHIBIT INDEX
Page
Exhibit 1 Metal Fabrication Companies 5
Exhibit 2 Number of Employees in Metal Finishing Industry 5
Exhibits 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
September 1995
vn
SIC Code 34
-------
Fabricated Metal Products
Sector Notebool Project
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
SIC Code 34
Vlll
September 1995
-------
Sector Notebook Project
Fabricated Metal Products
FABRICATED METAL PRODUCTS
(SIC 34)
LIST OF ACRONYMS
APS - 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)
September 1995
IX
SIC Code 34
-------
Fabricated Metal Products
Sector Notebool Project
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
SOi- 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
SIC Code 34
September 1995
-------
fabricated Metal Products
Sector Notebook Project
FABRICATED METAL PRODUCTS
(SIC 34)
I. INTRODUCTION OF THE SECTOR NOTEBOOK PROJECT
I.A. 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.
For any given industry, each topic listed above could alone be the
subject of a lengthy volume. However, in order to produce a
September 1995
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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 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
SIC Code 34
September 1995
-------
TJafeiicatecL Metal Products
Sector Notebook Project
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
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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.
H.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
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit!
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 $1 million in
annual gross revenues.
Exhibit 2
Number of Employees in Metal Finishing Industry
SIC 3471
SIC 3479
Total
1988
76,300
47,000
123,300
Source: U.S.
1989
76,600
44,600
121,200
1990
73,200
44,300
117,500
1991
66,600
43,400
110,000
1992
65,400
43,700
109,100
Department of Commerce, 1992 Census of Manufacturers.
September 1995
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 3
Value of Shipments for Metal Finishing Establishments ($ 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, EM
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 timsmng, April
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 fob Shops, Beverly A. Greaves, froaucts finishing, uecemoer
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.
SIC Code 34
September 1995
-------
Patyticated. Metal Piochicts
Sector Notebook Project
Exhibit 6
Metal Finishing Establishments,, by Size
1987
Establishments With
and Average of :
1 to 9 Employees
10 to 49 Employees
50 to 99 Employees
100 to 249 Employees
250 or more Employees
Total
Number of
Companies
2481
2262
365+
137
20
5265
Percent Total
47.1
43.0
6.9
2.6
0.4
100.0
1992
Number of
Companies
2553
2186
381
356
127
5603
Percent
Total
48.7
41.7
6.8
2.4
0.4
100.0
source: census of Manufacturers: LWl, U. b. 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
September 1995
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
constitute 10.2 percent of the total establishments that produce
fabricated structural metal (SIC 3441). In addition, California leads
in the 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.
SIC Code 34
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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 3.42 - 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.
September 1995
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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.
Exhibits
Markets Served by Metal Finishers
Percent of 1992 Market
40% t
35%.
30%-
25%
20%
15%
10%
5% -.
0%
•§
£
o
I
s
1
Spttrce: Surface F*>"!>"'"g Market Resenrrh Board. Metal Finishing Industry Market Survey 1992-19~
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.
SIC Code 34
10
September 1995
-------
Fabricated. Metal Products
Sector Notebook Project
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.
September 1995
11
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
JR. 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.
SIC Code 34
12
September 1995
-------
Fabricated. Metal Products
Sector Notebook Project
HI.A.I. 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.
September 1995
13
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 9
Forming Operations
Punch
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.
Once shearing and forming activities are complete, the material is
machined. Machining refines the shape of a workpiece by
SIC Code 34
14
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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
Scale
Removal
Acid
Pickling "
-
Rinse
*
1
Alkaline
Cleaning
S
a
urface
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 inorganic additives, which promote better cleaning or act
to affect the metal surface in some way; and (3) surfactants.
September 1995
15
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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 title 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.
in.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.
Exhibit 12
Overview of the Metal Finishing Process
Alkaline
Cleaner
->
Rinse
*
Acid Dip
'
Rinse
1
Surface
Preparation
-
Plating
-
Drag-out
Tanks
"*
Rinse
-
Finishing
Treatment
-»
Rinse
1
Surface
Treatment
Source: Sustainable Industrie Promoting Strategic Environmental
Phase 1 Report, U.S. EPA, OERR, June 1994.
SIC Code 34
16
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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
applying predominantly inorganic coatings onto surfaces to provide
September 1995
17
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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
Generator or
Rectifier
4-
Voltmeter
\
Anode Bus Bar
Cathode Bus Bar
Source: McGraw Hill Encyclopedia of Science and lechnolow. Volume b.
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. Sealing and conversion coating may be employed on
the metals after electroplating operations.
SIC Code 34
18
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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
Recovery
Rinse
Neutralizer
I
Cold
Water
Spent
Solution
Hot
Water
Rinse
Water
I
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.
September 1995
19
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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.
SIC Code 34
20
September 1995
-------
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.
September 1995
21
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 15
Process Materials Inputs and Outputs
Bll
Material Input || Air Emission
Process
Wastewater
Solid Waste
Metal Shaping
Metal Cutting and/or
'orming
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,
sulfuric, nitric),
alkaline, and
solvent 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
Surface Finishing
Anodizing
Chemical Conversion
Coating
Electroplating
Plating
Painting
Other Metal
Finishing Techniques
(Including Polishing,
Hot Dip Coating, and
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
Metal chips (e.g.,
scrap steel and
aluminum),
metal-bearing
cutting fluid
sludges, and
solvent still-
bottom wastes
Ignitable wastes,
solvent wastes,
and still bottoms
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
SIC Code 34
22
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 16
Fabricated Metal Products Manufacturing Processes
Metal
Fabrication
Metal
Preparation
(Cleaning)
Emulsifyui
Agents
Metal
Finishit
Cyai
Acids
X
Metals^
Alkalin
Metals
*s
-^ i
Anodizing — ^
Rinsing ^^
* ^<
Sealing
Tides
^"^ \
Electroplating — Q
1 * ^
Rinsing -^^^
t C
Scaling and/or
Conversion Coating
* *x
Rinsing ^^^
Molten
Metal ^^^
Metal
and/or
Pro
Cutting
cess
Rinsing and Bathing'
Alkalines Operations s
Acids
^•^ Metal
g.^, Qeaning
_ Rinsing ai
Oper
Air Emiss to us}
^Wg>
So U$ Wastes*}
^n&J^*}
**— - _ — "^
Jz0w^?>
Waste MSifef ^
Solid' Wastes*}
'4
nd Bathing _
at ions
Metals.^
Metals^
Gomplexing
Agents
^^ocntotete*}
•^ f"
crnpMetaZ^^
^.^-—(''viiaste. Waia**^)
~—~~~i^ ^>*^. ' - , ^
— — — _
- ^x2
- — — — — _
3C£m^^
,
-^ ^
^^^^^1
^•masfeT)
^^^^.(^teW^*}
^^ i r
Chemical
Conversion
Coating
Rinsing ^^^
Acids
^^
^C^ Waste Water J
***(^SolitI Wastes*}
L Alkalis
Plating
{
Rinsing ^^_
—C^SM^T^
— <^^W^>
Solvents i Paints
^^T-*--^
t Acids
^*-
Other Metal
Finishing
Tediniques
Rinsing ^Tl
Waste Water ^}
Painting
Rinsing _
^(^Aa-Bm-ssm^}
^*^^id Wastes*}
—f*^' ^
September 1995
23
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
III.B.l. 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
metalworking fluids (e.g., solvents) used prior to and during the
SIC Code 34
24
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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 (e.g., effluent controls required by the Clean
Water Act may generate sludges which are regulated by the
September 1995
25
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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
Workplace
Vapors/Mist
I Workpiece
Process
Chemicals
Process
Bath
T
Workpiece To Next Step
Rinse
System
Wastewater
Spent Bath Fresh Water
(Waste)
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.
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
SIC Code 34
26
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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
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.
September 1995
27
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Electroless Plating
Painting
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 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.
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.
SIC Code 34
28
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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.
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
September 1995
29
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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
21.31%
22.18%
23.94%
% Energy
Recovery
1.54%
1.53%
1.63%
%
Treated
2.10%
2.32%
2.46%
J
Remaining
Releases
and
Disposal
13.28%
10.84%
11.13%
SIC Code 34
30
September 1995
-------
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
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
September 1995
31
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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. :
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.
SIC Code 34
32
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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.
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.
September 1995
33
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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
differences in transfers and releases over time, categorized by type of
transfer or release.
SIC Code 34
34
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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.
September 1995
35
SIC Code 34
-------
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 Uataoase,
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 Fjnissions
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,
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, Loxics Release Inventory uataoase,
SIC Code 34
36
September 1995
-------
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
ffl
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.
September 1995
37
SIC Code 34
-------
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 Nsnic
Sulluric Acid
lydrochloric Acid
•Jitric Acid
Cylcne (Mixed
Isomers)
Nickel
riiroinium
^anganese
Glycol Ethers
Copper
vlethyl Ethyl Ketone
Zinc Compounds
<-Butyl Alcohol
Toluene
l-Trichloroethane
Triehloroethylene
Chromium Compounds
Phosphoric Acid
Nickel Compounds
Vtcihyl Isobutyl Kelone
Cyanide Compounds
Copper Compounds
Lead
Ammonia
Elhylbcnzene
Hydrogen Fluoride
Zinc (Fume Or Dust)
Acetone
Manganese
Compounds
Dichloromcthanc
4-Trimethylbenzene
Tctroehloroethylene
Mcthanol
Chlorine
McthyIcncbis(Phcnylis
oeyanale)
Naphthalene
Cobalt
Barium Compounds
Ffconll3
Lead Compounds
Styrone
Cadmium
Formaldehyde
Aluminum (Fume Or
Dusrt
Trichlorofluoro-
mcthanc
Cadmium Compounds
Bthvlcnc Glycol
Propylcnc
Cumenc
a-Elhoxyethanol
Cyelohcxane
fsopropyl Alcohol
(Manufacturing
Antimony Compounds
Cobalt Compounds
M-Xylene
# 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
35
I 33
1 28
I 25
19_
19
17
16
16
13
13
11
11
11
c
8_
6
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
2562
57791
1534
3606
282200
961
62
15561
7042
45312
276
37417
25423
10383
14361
611237
22111
4505
898
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
1179
70271
1608
803
102624
184C
6
961S
506
122318
266
160907
771
24238
19390
55929
29351
661
113
1229'
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
22
0
15
0~
cf
755
250
0
38
Q
209
0
0
6~
0
0
0
0
0
260
37
(
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
o
0~
6"
0
c
0
c
o
o"
c
0
0
0~
0
0
(
0
0
0
0
0
(
0
Land
Disposal
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~
b~
500
3114
0
C
o
250"
0
0
250
0
0
0
(
0
0
0
0
Total
Releases
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
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
37855
10858
25386
5147
107
388T
157
20254
150
20
1587
581
12914
18029"
42l9~
SIC Code 34
38
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
39
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
Sulluric Acid
Hydrochloric Acid
Nitric Acid
Xylcne (Mixed
tsomcrs)
Nickel
Chromium
Manganese
Olycol EJhets
Copper
Methyl Ethyl Kctone
Zinc Compounds
N-Butyl Alcohol
Toluene
1-Trichloroethane
Trichloroethylenc
Chromium
Compounds
Phosphoric Acid
Nickel Compounds
Methyl Isobutyl
Kctone
Cyanide Compounds
Copper Compounds
Lead
Ammonia
Ethylbcnzcnc
Hydrogen Fluoride
Zinc (Fume Or
Dust)
Acetone
Manganese
Compounds
Dichloromcthanc
4-Trimethylbcnzene
Tetrachloroethylene
Mcthnnol
Chlorine
MeUiylenebis(Pheny
tisocyanatc)
Naphthalene
Cobalt
Barium Compounds
Freon 1 13
Lead Compounds
Styrene
Cadmium
Formaldehyde
Aluminum (Fume Or
Dust)
Trichlorofluoro-
mcthanc
Cadmium
Compounds
Elhylcnc Glycol
Propylcne
Cumcnc
2-Ethoxyethanol
Cyclohcxanc
# 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
401 1 148
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
40
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
16,352393
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
41
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 Coaler, 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. hi?A, I oxics Release inventory uataoase, ±yyo.
Note: Being included on this list does not mean that the release is associated with non-compliance
with environmental laws.
SIC Code 34
42
September 1995
-------
Fabricated. Metal Products
Sector Notebook Project
TRI
Exhibit 27
Reporting Metal Finishing Facilities (SIC 347) by State
State
AL
AR
AZ
CA
CO
CT
DE
FL
GA
ffl
IA
IL
IN
KS
KY
LA
MA
MD
ME
ME
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
Sulfunc Acid
Hydrochloric Acid
Nitric Acid
Zinc Compounds
Phosphoric Acid
Methyl Ethyl Ketone
Chromium Compounds
Nickel Compounds
Cyanide Compounds
Nickel
Trichloroethylene
JCylene (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
43
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 Kctone
Telraehlorocthylcne
Acetone
Ethylbcnzcne
Naphthalene
Zinc (Fume Or Dust)
1.2.4-Trimclhylbenzene
Diehloro methane
Formaldehyde
Mcthonol
Cadmium
Barium Compounds
Hydrogen Fluoride
Cadmium Compounds
Manganese
Cumcnc
Cobalt
Ficon 113
Lead Compounds
Manganese Compounds
Methylencbis
(Phcnylisocyanate)
Aluminum (Fume Of Dust)
Antimony
Dimethyl Phthalale
Ethylcne Glycol
Pfppylene
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
Plicnol
Selenium
Silver Compounds
Trichloronuoro me thane
1 ,2-Dichlorobcnzcne
2-Ethoxyethanol
2-N'ilropropanc
4.4-lsopropylidenediphenol
# Facilities
Reporting
Chemical
30
25
21
20
20
20
20
IS
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
—
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
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
5
37911
12000
5
500
12005
12000
7250
368
250
—
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
SIC Code 34
44
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
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-Trimethy Ibenzene
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
3thylene Glycol
Propylene
Aluminum Oxide (Fibrous
rform)
Isopropyl Alcohol
Manufacturing)
M-Xylene
Sec-Butyl Alcohol
Silver
2-Methoxyethanol
#
Facilities
Reporting
Chemical
J / /
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
oU4yoo
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
111
690
416
0
12500
45116
0
0
133
4263
September 1995
45
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-Elhylhexyl) Adipale
Ethyl Acrylale
Mercury
O-Xylene
Phenol
Selenium
Silver Compounds
Trichlorofluoromethane
1.2-Diehlorobcnzene
2-Ethoxyethanol
2-Nilropropane
4.4-Isopropylidenediphenol
#
Facilities
Reporting
Chemical
1
—
POTW
Discharges
0
5
5
0
0
5
0
5
250
0
5
0
0
1,810,861
Disposal
0
10
10
250
0
10
-------
UaVticated. Metal Products
Sector Notebook Project
Acetone
information 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.
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.
C arcino genicity. 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.
(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
47
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Degradation by microorganisms will be the primary removal
mechanism.
Acetone is highly volatile, and once it reaches the troposphere
(lower atmosphere), it will react with other gases, contributing to
the formation of ground-level ozone and other air pollutants. EPA
is reevaluating acetone's reactivity in the lower atmosphere to
determine whether this contribution is significant.
Physical Properties. Acetone is a volatile and flammable organic
chemical.
Note: Acetone was removed from the list of TRI chemicals on June
16, 1995 (60 FR 31643) and will not be reported for 1994 or
subsequent years.
Glvcol Ethers
Due to data limitations, data on diethylene glycol (glycol ether) are
used to represent all glycol ethers.
Toxicity. Diethylene glycol is only a hazard to human health if
concentrated vapors are generated through heating or vigorous
agitation or if appreciable skin contact or ingestion occurs over an
extended period of time. Under normal occupational and ambient
exposures, diethylene glycol is low in oral toxicity, is not irritating to
the eyes or skin, is not readily absorbed through the skin, and has a
low vapor pressure so that toxic concentrations of the vapor can not
occur in the air at room temperatures.
At high levels of exposure, diethylene glycol causes central nervous
depression and liver and kidney damage. Symptoms of moderate
diethylene glycol poisoning include nausea, vomiting, headache,
diarrhea, abdominal pain, and damage to the pulmonary and
cardiovascular systems. Sulfanilamide in diethylene glycol was
once used therapeutically against bacterial infection; it was
withdrawn from the market after causing over 100 deaths from
acute kidney failure.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
SIC Code 34
48
September 1995
-------
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
49
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
reported to occur in several cases where DCM was used in the
presence of an open fire.
Populations at special risk from exposure to DCM include obese
people (due to accumulation of DCM in fat), and people with
impaired cardiovascular systems.
Carcinogenicity. DCM is a probable human carcinogen via both oral
and inhalation exposure, based on inadequate human data and
sufficient evidence in animals.
Environmental Fate. When spilled on land, DCM is rapidly lost
from the soil surface through volatilization. The remainder leaches
through the subsoil into the groundwater.
Biodegradation is possible in natural waters but will probably be
very slow compared with evaporation. Little is known about
bioconcentration in aquatic organisms or adsorption to sediments
but these are not likely to be significant processes. Hydrolysis is not
an important process under normal environmental conditions.
DCM released into the atmosphere degrades via contact with other
gases with a half-life of several months. A small fraction of the
chemical diffuses to the stratosphere where it rapidly degrades
through exposure to ultraviolet radiation and contact with chlorine
ions. Being a moderately soluble chemical, DCM is expected to
partially return to earth in rain.
Methvl Ethvl 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.
Carcinogenicitv. 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.
Environmental Fate. Most of the MEK released to the environment
will end up in the atmosphere. MEK can contribute to the
SIC Code 34
50
September 1995
-------
Fabricated Metal Products
.Sector Notebook Protect
Toluene
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.
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.
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,
September 1995
51
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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 hydrplyze in
water, nor does it significantly bioconcentrate in aquatic organisms.
Trichloroethvlene
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.
Carcinogenicitv. 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 organisms. The main removal of trichloroethylene from
water is via rapid evaporation.
SIC Code 34
52
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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 Pate. 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.
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
September 1995
53
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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 (FT), sulfur dioxide (SO2), and volatile organic
compounds (VOCs).
Exhibit 30
Pollutant Releases (Short Tons/Years)
Industry
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
Nonfcrrous Metals
Fabricated Metals
Electronics
Motor Vehicles, Bodies,
Parts, and Accessories
CO
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
NO2
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
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
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
SO2
21,888,000
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
23,312,000
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
54
September 1995
-------
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
55
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
3
(suoi^ira) spunoj JBJOJ,
•5
SIC Code 34
56
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
JU
vV
CO
IS
if!
•S mvo TJ
llsi
60
u
O
CO
in
'O
5
incs
co bs
Sto
58
a
of
VO
co
00
a
I
.
R
S
vo
c
R
ffi
8
,60
s
8
a
September 1995
57
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
V. POLLUTION PREVENTION OPPORTUNITIES
The best way to reduce pollution is to prevent it in the first place.
Some companies have creatively implemented pollution
prevention techniques that improve efficiency and increase profits
while at the same time minimizing environmental impacts. This
can be done in many ways such as reducing material inputs, re-
engineering processes to reuse by-products, improving
management practices, and employing substitution of toxic
chemicals. Some smaller facilities are able to actually get below
regulatory thresholds just by reducing pollutant releases through
aggressive pollution prevention policies.
In order to encourage these approaches, this section provides both
general and company-specific descriptions of some pollution
prevention advances that have been implemented within the
Fabricated Metal Products industry. While the list is not
exhaustive, it does provide core information that can be used as the
starting point for facilities interested in beginning their own
pollution prevention projects. When possible, this section provides
information from real activities that can, or are being implemented
by this sector ~ including a discussion of associated costs, time
frames, and expected rates of return. This section provides
summary information from activities that may be, or are being
implemented by this sector. When possible, information is
provided that gives the context in which the techniques can be
effectively used. Please note that the activities described in this
section do not necessarily apply to all facilities that fall within this
sector. Facility-specific conditions must be carefully considered
when pollution prevention options are evaluated, and the full
impacts of the change must examine how each option affects, air,
land, and water pollutant releases.
V.A. Identification of Pollution Prevention Activities in Use and
Environmental and Economic Benefits of Each Pollution Prevention
Activity
Pollution prevention (sometimes referred to as source reduction) is
the use of materials, processes, or practices that reduce or eliminate
the creation of pollutants or wastes at the source. Pollution
prevention includes practices that reduce the use of hazardous
materials, energy, water or other resources, and practices that protect
natural resources through conservation or more efficient use.
SIC Code 34
58
September 1995
-------
Fabricated Metal Products
Sector Nbfeboofc 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
• Loss prevention and housekeeping
September 1995
59
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
« Waste segregation and separation
• Closed-loop recycling
• Training and supervision.
Each of these categories is discussed briefly below. Refer to Section
V.D. for a list of specific pollution prevention techniques and
associated costs, savings, and other information. It should be kept
in mind that every pollution prevention option may not be
available for each facility.
Production planning and sequencing is used to ensure that only
necessary operations are performed and that no operation is
needlessly reversed or obviated by a following operation. One
example is to sort out substandard parts prior to painting or
electroplating. A second example is to reduce the frequency with
which equipment requires cleaning by painting all products of the
same color at the same time. A third example is to schedule batch
processing in a manner that allows the wastes or residues from one
batch to be used as an input for the subsequent batch (e.g., to
schedule paint formulation from lighter shades to darker) so that
equipment need not be cleaned between batches.
Process or equipment modification is used to reduce the amount of
waste generated. For example, manufacturers can change to a paint
application technique that is more efficient than spray painting,
reduce overspray by reducing the atomizing air pressure, reduce
drag-out by reducing the withdrawal speed of parts from plating
tanks, or improve a plating line by incorporating drag-out recovery
tanks or reactive rinsing.
Raw material substitution or elimination is the replacement of
existing raw materials with other materials that produce less waste,
or a non-toxic waste. Examples include substituting alkali washes
for solvent degreasers, and replacing oil with lime or borax soap as
the drawing agent in cold forming.
Loss prevention and housekeeping is the performance of
preventive maintenance and equipment and materials
management so as to minimize opportunities for leaks, spills,
evaporative losses, and other releases of potentially toxic chemicals.
For example, spray guns can be cleaned in a manner that does not
damage leather packings and cause the guns to leak; or drip pans
can be placed under leaking machinery to allow recovery of the
leaking fluid.
SIC Code 34
60
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Waste segregation and separation involves avoiding the mixture of
different types of wastes and avoiding the mixture of hazardous
wastes with non-hazardous wastes. This makes the recovery of
hazardous wastes easier by minimizing the number of different
hazardous constituents in a given waste stream. It also prevents the
contamination of non-hazardous wastes. Specific examples include
segregating scrap metal by metal type, and segregating different
kinds of used oils.
Closed-loop recycling is the on-site use or reuse of a waste as an
ingredient or feedstock in the production process. For example, in-
plant paper fiber waste can be collected and recycled to make pre-
consumer recycled paper products.
Training and supervision provides employees with the
information and the incentive to minimize waste generation in
their daily duties. This might include ensuring that employees
know and practice proper and efficient use of tools and supplies,
and that they are aware of, understand, and support the company's
pollution prevention goals.
V.B. Possible Pollution Prevention Future Trends
There are numerous pollution prevention trends in the metal
fabrication and finishing industry. These include recycling liquids,
employing better waste control techniques, using mechanical forms
of surface preparation, and/or substituting raw materials. One
major trend is the increased recycling (e.g., reuse) of most process
liquids (e.g., rinse water, acids, alkali cleaning compounds, solvents,
etc.) used during the metal forming and finishing processes. For
instance, instead of discarding liquids, companies are containing
them and reusing them to cut down on the volume of process
liquids that must eventually be disposed of. Also, many companies
are replacing aqueous plating with ion vapor deposition.
Another common approach to reducing pollution is to reduce rinse
contamination via drag-out by slowing and smoothing the removal
of parts (rotating them if necessary), maximizing drip time, using
drainage boards to direct dripping solutions back to process tanks,
and/or installing drag-out recovery tanks to capture dripping
solutions. By slowing down the processes and developing
structures to contain the dripping solutions, a facility can better
control the potential wastes emitted.
September 1995
61
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
To reduce the use of acids when cleaning parts, the industry is using
and encouraging the use of mechanical scraping/scrubbing
techniques to clean and prepare the metal surface. Emphasizing
mechanical approaches would greatly diminish the need for acids,
solvents, and alkalis. In addition to the mechanical technique for
cleaning surfaces, companies are encouraged to substitute acids and
solvents with less harmful liquids (e.g., alcohol). Section V.D. lists
numerous specific pollution prevention techniques that have been
employed in the industry.
V.C. Pollution Prevention Case Studies
Numerous pollution prevention case histories have been
documented for the metal fabricating and finishing industries.
Many of these have dealt primarily with electroplating or general
finishing operations. The Eastside Plating case, presented in this
section, is a classic example of the numerous pollution prevention
techniques that can be implemented at an electroplating company.
For other pollution prevention case studies, see section V.D.
PoUution Prevention Options, and the list of pollution prevention
contacts in section V.E.
Eastside Plating, an Oregon-based company, has made money
complying with new environmental regulations. Under the
direction of its Maintenance and Water Treatment Manager, the
electroplating firm implemented operational changes that save
more than $300,000 annually. Eastside Plating management made
the commitment to implement a hazardous waste reduction
program in 1982. By changing rinsing techniques, substituting
materials, and segregating wastes for treatment, the firm has
become a more cost-effective operation.
By setting priorities and upgrading in phases, the firm was able to
work toward compliance yet meet increased demand for services
during a period of rapid growth. The first operational modification
addressed counterflow and cascade rinsing systems. The changes
decreased water used for rinsing, a process that accounts for 90
percent of all water used in electroplating. In counterflow rinsing,
water is used a number of times, thus dramatically reducing
volume. Cascade rinsing requires only one tank with a center
divider which allows water to spill into the other side. The
filling/draining process is continuous and very slow to reduce the
amount of water used. Both systems cut water bills and wastewater
treatment costs.
SIC Code 34
62
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Management next searched for waste treatment chemicals that
decreased, rather than increased, the production of sludge. Total
chromium and cyanide wastes were cut in half simply by changing
reducing agents. Chromium acid wastes are now oxidized by using
sodium bisulfite and sulfuric acid instead of ferrous sulfate, while
cyanide reduction is now accomplished more efficiently with
gaseous, instead of liquid, chlorine.
Eastside Plating also upgraded its three major waste treatment
components: the cyanide oxidation tank, the chromium reduction
tank, and the acid/alkaline neutralizing tank. The goal was to
separate tank flow, eliminate contamination of the acid/alkaline
neutralizing tank, and increase efficiency. Automated metering
equipment reduced the quantity of costly caustic chemicals needed
to treat acid wastes by 50 percent. To eliminate the risks associated
with pump failure and the equalize flow rate, cyanide and chromic
acid oxidation and reduction tanks were redesigned as gravity flow
systems. Additionally, plumbing was segregated to prevent cross-
contamination. These simple solutions saved Eastside Plating
hundreds of thousands of dollars.
Next, management consulted with suppliers when they modified
the company's mixing sump (sometimes called a reaction tank) and
a flocculent mix tank (sometimes called a neutralizing tank). The
modification to each prohibits 'indigestion1 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 Pollution Prevention Assistance Division (P^AD) strategy,
the Industrial Technology Corporation collaborative effort, and the
Merit Partnership.
September 1995
63
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Georgia Department of Natural Resources
A core strategy of the Pollution Prevention Assistance Division
(P2AD) 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.
1TAC
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 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
SIC Code 34
64
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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
V.D.I.
Technique
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.
Metal Shaping Operations
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
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.
September 1995
65
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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).
Costs and Savings: Capital Investment: $0. Annual Savings: $3,000 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: $1,900,000. Annual
Savings: $156,000. Waste Throughput Information: 2 million gallons per year. Facility
reclaims oil and metal from process water.
SIC Code 34
66
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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: $42,000 (1976). Annual Savings: $33,800 (1980).
Option 4 - Perform on-site purification of hydraulic oils using commercial "off-the-shelf"
cartridge filter systems. Costs and Savings: Capital Investment: $28,000. Annual Savings:
$17,800/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: $465,000. Annual Savings:
$342,000. 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: $26,800 (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: $0.
Annual Savings: $7,200. 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:
$40,000. Payback Period: 2 years. Waste Savings/Reduction: 48,000 gallons of aqueous
waste. Aluminum shot was used to preclean parts.
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.
September 1995
67
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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: $0. Annual
Savings: $12,000. 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 Sayings: Annual Savings: $10,000 in treatment
equipment costs and $2.50/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: $12,000 in equipment costs and
$3.00/lb. of cyanide in treatment chemical costs. Product/Waste Throughput Information:
rinse water flowrate of 2 gallons per minute.
Technique - Recycling
Option 1 - Recycle spent degreasing solvents on site using batch stills. Costs and Savings:
Capital Investment: $2,600-$4,100 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 gaUons 1,1,1-trichloroethane per year.
SIC Code 34
68
September 1995
-------
Fabricated Metal Products
Sector Notebook Prefect
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: $3,250 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:
$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.
September 1995
69
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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.
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.
SIC Code 34
70
September 1995
-------
I? abdicated. Metal Products
Sector Notebook Project
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
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: $75,000 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.
September 1995
71
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Option 4 - Use drip bars to reduce drag-out. Costs and Savings: Capital Investment: $100
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.
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.
SIC Code 34
72
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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: $2,000. 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 sulf ates 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,
PL, (904) 283-2942, Charles Carpenter, Dan Sucia, Penny Wilcoff; and John Beller at EG&G
(108) 526-1149.
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.
September 1995
73
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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: $3,200 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: $40,000 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.
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: $18,000 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.
SIC Code 34
74
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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.
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.
September 1995
75
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Technique - Process or Equipment Modification
Option 1 - Ensure the spray gun ak 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 ak spray to an electrostatic finishing system. Costs
and Savings: $15,000 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: $0.20 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 $0.07 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: $1.5 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
thinners.
Technique - Recycling
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.
SIC Code 34
76
September 1995
-------
Fabricated Metal Products
Sector Notebook
Project
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
Option 1 - Solvent waste streams should be kept segregated and free from water
contamination.
September 1995
77
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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: $1,000 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: $3,600 per year in new thinner savings; $5,400 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.
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
Raw Material Substitution
Recycling
Process or Equipment Modification
Process or Equipment Modification
Recycling
(213) 237-1209
SIC Code 34
78
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Organization
CALFRAN International, Inc.
SAIC (Edward R. Saltzberg)
New Jersey Hazardous Waste Facilities
Siting Commission, Hazardous Waste
Source Reduction and Recycling Task Force
AT&T Bell Laboratories, Princeton, NJ
Tyndall Air Force Base (Charles
Carpenter)
EG&G Idaho (Dan Sucia, Penny Wilcoff,
John Beller)
American Etching and Manufacturing,
Pacoima, CA
Highland Plating Company, Los Angeles,
CA
Control Data Corporation
Minnesota Office of Waste Management
Pioneer Metal Finishing, Inc. (Harry
Desoi)
Digital Equipment Corporation
Lancy International Consulting Firm
(William McLay)
Ionics, Inc., Separations Technology
Division
Technique(s) to Promote Pollution
Prevention Plating Operations
Process or Equipment Modification
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
Telephone
Number
(413) 525-4957
(904) 283-2942
(208) 526-1149
(612) 649-5750
(609) 694-0400
(412) 452-9360
September 1995
79
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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 sources, designated with the code "F") or materials which
SIC Code 34
80
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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 treatment unit, waste pile, or surface impoundment).
Wastes subject to the LDRs include solvents, electroplating
wastes, heavy metals, and acids. Generators of waste subject
September 1995
81
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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.
SIC Code 34
82
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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's RCRA/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 community access to information about
September 1995
83
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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 H 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.
SIC Code 34
84
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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.
September 1995
85
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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.
SIC Code 34
86
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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.
September 1995
87
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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 primary drinking water standards, which are,
SIC Code 34
88
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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 environmental effects. If available data
September 1995
89
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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
SIC Code 34
90
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
industrial 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.
September 1995
91
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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 requirements of the metal finishing standards
SIC Code 34
92
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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)
• Coil Coating (40 CFR Part 465)
• Porcelain Enameling (40 CFR Part 466)
September 1995
93
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
• 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)
• 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)
SIC Code 34
94
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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
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).
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.
September 1995
95
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 33
Hazardous Wastes Relevant to the Metal Finishing Industry
EPA Hazardous
Waste No.
Hazardous Waste
D006 (cadmium)
D007 (chromium)
D008 (lead)
D009 (mercury)
DOW (selenium)
D011 (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, l,l,2-trichloro-l,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.
F005
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
F006
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
nulling of aluminum,
F007
Spent cyanide plating bath solutions from electroplating operations.
F008
•_^IM^HH«^^^^^^^^^^^^^—II II
Plating bath residues from the bottom of plating baths from electroplating
operations where cyanides are used in the process.
SIC Code 34
96
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 33
Hazardous Wastes Relevant to the Metal Finishing Industry
EPA Hazardous
Waste No.
F009
F010
F011
F012
F019
K090
K091
Hazardous Waste
Spent stripping and cleaning bath solutions from electroplating operations
where cyanides are used in the process.
Quenching bath residues from oil baths from metal heat treating operations
where cyanides are used in the process.
Spent cyanide solutions from salt bath pot cleaning from metal heat treating
operations.
Quenching wastewater treatment sludges from metal heat treating operations
where cyanides are used in the process.
Wastewater treatment sludges from the chemical conversion coating of
aluminum from zirconium phosphating is an exclusive conversion coating
process.
Emission control dust or sludge from ferrochromiumsilicon production
(ferroalloy industry).
Emission control dust or sludge from ferrochromium production (ferroalloy
industry).
source: bustmnawe industry: Promoting btratenc bnvironmental 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 forgings and stampings, metal springs,
September 1995
97
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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
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 Decreasing/Cleaning
EPA proposed a NESHAP (58 PR 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 can be shown to achieve the same emission limit as
the equipment and work practice compliance standard.
SIC Code 34
98
September 1995
-------
Pa\>T\cated Metal Products
Sector Notebook Project
Steel Picklinv. HCl
Hydrochloric acid (HCl) 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 HCl
solution and HCl regeneration processes have been identified by the
EPA as potentially significant sources of HCl 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.
September 1995
99
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
VII. COMPLIANCE AND ENFORCEMENT PROFILE
Background
To date, EPA has focused much of its attention on measuring
compliance with specific environmental statutes. This approach
allows the Agency to track compliance with the Clean Air Act, the
Resource Conservation and Recovery Act, the Clean Water Act, and
other environmental statutes. Within the last several years, the
Agency has begun to supplement single-media compliance
indicators with facility-specific, multimedia indicators of
compliance. In doing so, EPA is in a better position to track
compliance with all statutes at the facility level, and within specific
industrial sectors.
A major step in building the capacity to compile multimedia data
for industrial sectors was the creation of EPA's Integrated Data for
Enforcement Analysis (IDEA) system. IDEA has the capacity to
"read into" the Agency's single-media databases, extract compliance
records, and match the records to individual facilities. The IDEA
system can match Air, Water, Waste, Toxics/Pesticides/EPCRA,
TRI, and Enforcement Docket records for a given facility, and
generate a list of historical permit, inspection, and enforcement
activity. IDEA also has the capability to analyze data by geographic
area and corporate holder. As the capacity to generate multimedia
compliance data improves, EPA will make available more in-depth
compliance and enforcement information. Additionally, sector-
specific measures of success for compliance assistance efforts are
under development.
Compliance and Enforcement Profile Description
Using inspection, violation, and enforcement data from the IDEA
system, this section provides information regarding the historical
compliance and enforcement activity of this sector. In order to
mirror the facility universe reported in the Toxic Chemical Profile,
the data reported within this section consists of records only from
the TRI reporting universe. With this decision, the selection
criteria are consistent across sectors with certain exceptions. For the
sectors that do not normally report to the TRI program, data have
been provided from EPA's Facility Indexing System (FINDS) which
tracks facilities in all media databases. Please note, in this section,
EPA does not attempt to define the actual number of facilities that
fall within each sector. Instead, the section portrays the records of a
subset of facilities within the sector that are well defined within
EPA databases.
SIC Code 34
100
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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);
m (DC, DE, MD, PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TO); V (IL, IN, MI, MN, OH,
WI); VI (AR, LA, NM, OK, TX); VII (IA, KS, MO, ME); VHI (CO, MT, ND, SD, UT, WY); IX (AZ,
CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR, WA).
September 1995
101
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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 VH 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 SlC 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.
SIC Code 34
102
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Number of Inspections — measures the total number of inspections
conducted in this sector. An inspection event is counted each time
it is entered into a single media database.
Average Time Between Inspections — provides an average length of
time, expressed in months, that a compliance inspection occurs at a
facility within the defined universe.
Facilities with One or More Enforcement Actions - expresses the
number of facilities that were party to at least one enforcement
action within the defined time period. This category is broken
down further into Federal and State actions. Data are obtained for
administrative, civil/judicial, and criminal enforcement actions.
Administrative actions include Notices of Violation (NOVs). A
facility with multiple enforcement actions is only counted once in
this column (facility with 3 enforcement actions counts as 1). All
percentages that appear are referenced to the number of facilities
inspected.
Total Enforcement Actions — describes the total number of
enforcement actions identified for an industrial sector across all
environmental statutes. A facility with multiple enforcement
actions is counted multiple times (a facility with 3 enforcement
actions counts as 3).
State Lead Actions — shows what percentage of the total
enforcement actions are taken by State and local environmental
agencies. Varying levels of use by States of EPA data systems may
limit the volume of actions accorded State enforcement activity.
Some States extensively report enforcement activities into EPA data
systems, while other States may use their own data systems.
Federal Lead Actions -- shows what percentage of the total
enforcement actions are taken by the U.S. EPA. This value includes
.referrals from State agencies. Many of these actions result from
coordinated or joint State/Federal efforts.
Enforcement to Inspection Rate — expresses how often enforcement
actions result from inspections. This value is a ratio of enforcement
actions to inspections, and is presented for comparative purposes
only. This measure is a rough indicator of the relationship between
inspections and enforcement. This measure simply indicates
historically how many enforcement actions can be attributed to
inspection activity. Related inspections and enforcement actions
under the Clean Water Act (PCS), the Clean Air Act (AFS) and the
Resource Conservation and Recovery Act (RCRA) are included in
September 1995
103
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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 IV's enforcement actions are State-lead.
VII.B. Comparison of Enforcement Activity Between Selected Industries
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
SIC Code 34
104
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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.
September 1995
105
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
I
aj
s
I
>>
si
".
I
O
a>
a>
rt
o
II
.i ^(
§2
I a
J c
ffl'S
2 <
11 a
zf
SIC Code 34
106
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
3
C
O)
•«•)
U
a
S3
,5 c
If
IjJ g
S
«
-4—»
I
S
SS
i)
0
CO
G
^ QJ O
f2 J tj
w
fa
a
e s
"all
5« t3
« s S
SP a S
2 o >S
in
i-H
.-<
o
cn
o
M
-.
JJ'
Je
SI
'S &
• n TO
•S
(2
"S
S
8 8
"~1
-a-
S
g)
•§
o\
September 1995
107
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
•c
•s
"2
&
i
vpco
o
•s
I
I
4)
O
g
o
I.
§G
O
5 ""3
s!
I
s
t
I
GO
•s
6 00
. a
a '3
g'%
and
s?
58
5
8
S
£
S
Re
8
s?
eel
CJ
Ǥ
Co
in
a f
*Per
with
SIC Code 34
108
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
•a
-------
Fabricated Metal Products
Sector Notebook Project
•c
•A«»
3
3
1
-------
Fabricated Metal Products
Sector Notebook Project
VII.C. Review of Major Legal Actions
VII.C.l 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. Tohn 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.
September 1995
111
SIC Code 34
-------
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.
SIC Code 34
112
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
t s
U ;-
*"^ ,
flJ O (a
S * B
w U U
en
o
£
|1 §
S ^'"S
en H <
a
BM '§)
W rS
cu
1
cu
CO
(9
O
8
ON
CN
o
o
o
a
«•
fi 'd
Install and operate a cooling
water and process rinse recycl
system and a metal recovery
system to reduce the water use
and to recover copper and zinc
process waste for recycling.
o
8
Q*
Cx
a*
C C
'•§ S3
II
S
PH
W
T-l
Truex, Inc.
Pawtucket, RI
(metal parts
manufacharing)
|
ID
t-l
iH
S
«•
t- CO S
Implement a system to reclain
and reuse chromic acid rinse
waters. Eliminate the use of
trichloroethane in the
degreasing operation. Install
filtration system which will
extend the life of the
hydrochloric acid strip soluti
CN
oo"
t— t
iff
1
s o c £
•43 C -J3 -g
S g S 3
0 S3 «
PL, PL, PL, Pi!
U
^
B
Walton & Lonsbury
Attleboro, MA
(electroplating facil
K
in
T— 1
o
o
CN
Install a hot-air metal parts
drying unit which eliminates
100 percent of the use of freon.
S '
T-l
CN
as
C
s o
O -O
1 1
ll
^
U
on
T-H
Verilyte Gold, Inc.
Chelsea, MA
(electroplatting
facility)
R
oo
^D
co
co
«•
"s s J «
Donate emergency and/or
computer equipment to the Lo
Emergency Planning Committe
(LEPC) to respond to and/or p
for chemical emergencies.
Participate in LEPC activitie
K
vo"
f—i
«•
H s
I'-g
cri o
a
y
w
T-H
The Torrington Comp
(precision bearings,
assemblies, gears, an<
couplings manufactur
CN
^^
»
CN
o
21
«•
•a § P
Purchase computer hardware
and software for the LEPC an
Attleboro Fire Department
(AFD) to assist the LEPC in
tracking and storing informati
about identity and location of
hazardous chemicals and to
assist the AFD in responding t
accidental releases.
CD
VO
o
oo"
1 c
<= o
11
w Q
S
fc
w
^_!
CO
d ^
f 1
H ^ 5b 3
2 ° ^ 0
hS o ^ 13
« •§ « s
o ^
« co
"0s U
C HH
PI
nj O
lg
11
September 1995
113
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
8 S
°x c
^ c
il ''
g"
{ft
Replace the current vapor
degreasor unit with a closed-
loop degreaser unit to prevent
the use of Freon 113.
II O
F
»
I c o
Pi
(2 £
F
1 0
U
1 -a
« ^ c
1 Texas Instrum
Attleboro, M/i
(metal finishi
§ £
"i c
0 L
ft *
1 !
Eft
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.
Q
o"
O4
p.
c o
I!
0 C
2
g
-
eT
a
o,
6 '*>
o 3
U -2
^ o
**-* 7 O-, H
S rf^-8
H ro .p nj
fill
3
•N,
^
3
3\ II
Eft I)
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.
icy
t^
^1(
fff
U
Ei
s
y
on
^
S
T-l
1
^3 ^
3^|
iiil
SIC Code 34
114
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
o
o
o^
"^
«5-
o!
^
»
Install a closed loop evaporator
system to eliminate the
discharge of copper forming
wastewater to the river.
uf
«3-
S-|
11
•o 2
PH P-i
£
U
-
01
H
3
I e
£ fj
11 ^
CH £*"»
CO
of
tfi-
°
oq^
£
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.
o
8
3?
«•
U
"3 cu
PH &.
I
w
«
EH
§
pP
H
(-* *^
^ O
C/5 C/3
0
oo-
«•
§
t*x
I-H
co
Replace PCB transformers fluid
with non-PCB fluid to eliminate
the potential for uncontrolled
releases of PCBs.
o
1
«•
13 0)
0) U
2.2
^u
0) rf
u q
y o
< U
.^^
-E-1
CO
3
""o
£ ^
3
-------
Fabricated Metal Products
Sector Notebook Project
vni. 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.
VIH.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.
SIC Code 34
116
September 1995
-------
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.
September 1995
117
SIC Code 34
-------
r
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
SIC Code 34
118
September 1995
-------
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
September 1995
119
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
encourage industry 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.
SIC Code 34
120
September 1995
-------
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.
September 1995
121
SIC Code 34
-------
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.
SIC Code 34
122
September 1995
-------
Fabricated Metal Products
Sector Notebook Protect
Exhibit 40
33/50 Program
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.
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
ethlehem
an Francisco
MO
AL
IL
CO
MO
IL
TN
WI
NJ
PA
WI
IL
CA
L
NY
OH
MN
PA
CT
WA
N
OH
CT
L
TX
CT
N
NY
CT
A
A
SIC Codes
3644, 3613, 342
2851, 344
3312,3499,3479
339
2082,3411,344
347
341
3086, 3469, 364
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
#ofParticipafin
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 Release
and Transfer
(Ibs.)
59,90
55,23
157,23
158,79
12,90
930,18
53,74
1,112
2,080,50
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
*** 11
75
20
**
86
*
*#*
50
***
September 1995
123
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 40 (cont'd)
33/50 Program
Parent Facility name
lack & Decker Corporation
laser Die Casting Co.
me Industries Inc.
BtOd & Mcclung-Pace Co.
toofclynParkOilCo.Inc.
umham Corporation
C. A. Dahlin Co.
:ald\vdl Products Inc.
Canon Business Machines Inc.
Cargill Detroit Corporation
Channcllock Inc.
3iart Industries Inc.
Chrysler Corporation
;old Heading Co.
Collis Inc.
Commercial Enameling Co.
'onagra Inc.
Cooper Industries Inc.
Corning Inc.
"renlo Inc.
'jovm City Plating Co.
town Cork & Seal Company
Crown Metal Finishing Co. Inc.
)ana Corporation
3avis St. Hcmphill
Delbar Products Inc.
3elta Engineering & Mfg. Co.
)mton Company
)uo-Fast Corp.
Jynamlc Metal Products Company
saglc-Picher Industries Inc.
•aton Corporation
Huron Industries Inc.
Hectro-Platcrs Of York Inc.
Emerson Electric Co.
snamcicrs & Japanncre Inc.
Ernie Green Industries Inc.
Exccll Polishing & Buffing Co.
Federal-Mogul Corporation
{'eldkircher Wire Fabg Co.
altimore
cattle
Minneapolis
ortland
Minneapolis
Lancaster
Ik Grove
Village
Abilene
Costa Mesa
Clawson
Meadville
Willoughby
Highland Park
Detroit
Clinton
Huntington
Park
Omaha
Houston
Coming
Rochester
El Monte
Philadelphia
Kenilworth
Toledo
Elkridge
Perkasie
Tualatin
Danville
Franklin Park
Manchester
Cincinnati
Cleveland
Aumsville
Wrightsville
Saint Louis
Chicago
Dayton
Wadsworth
Southfield
Nashville
MD
WA
MN
OR
MN
A
L
TX
CA
MI
PA
OH
MI
MI
A
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
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
346
3444
3053, 347
346
347
347
3569, 3541, 3496
344
347
346
347
3365, 3366, 347
3471, 349
Facilities
6
1
1
1
1
1
1
1
1
1
1
2
2t
i
i
i
i
7
1
1
1
20
1
3
1
2
1
1
1
1
3
4
1
1
4
1
3
1
3
1
nd 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
27,00
652,51
25
227,24
450,21
4,35
29,46
2,140,49
40,00
329,82
13,14
255,99
1988 to 1993
50
78
5
13
96
50
95
31
/y
80
jz
100
75
14
j\j
DU
21
50
18
SIC Code 34
124
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 40 (cont'd)
33/50 Program
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
Gefinor (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.
Jrarcnt Oity
Portland
Chicago
Dearborn
Mendota
Heights
New York
Seattle
Clifton Springs
Denver
Springboro
New York
St Louis
Fairfleld
Detroit
Boston
Wichita
Saint Louis
Dallas
Warsaw
New York
Grand Rapids
Camp Hill
Kng Of Prussa
Manitowoc
New Hyde
Park
New York
Dayton
Dallas
South Houston
Armonk
Glenview
South Bend
New York
Si
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
L
N
NY
SIC Codes
347
3462, 3324, 3325
3465, 371
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 Farticipatin
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.)
52
502,31
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
September 1995
125
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 40 (cont'd)
33/50 Program
1 Parent Facility name
IndiU Ltd
|tmlitnhead Plating Inc.
Industrial Hard Chrome Ltd.
IngcrsoII-Rand Company
IJIntcrlakc Corporation
(International Paper Company
JITT Corporation
luaeobson Mfg Co. Inc.
ueffcrson City Mfg. Co. Inc.
Juor-Mac Company Inc.
Jlordan-Edmiston Group Inc.
Kaspar Electroplating Corp
JKclso Asi Partners L P
JKenncdy Mfg, Co.
Kitzinger Cooperage Corp
Lacks Enterprises Inc.
Lawrence Brothers Inc.
|]LCCO Corporation
llutton Industries Inc.
IJLord Corporation
IjLonn Ind.
jjLTV Steel Co. Inc.
jJLukc Engineering & Mfg Corp
iJMacklanburg-Duncan Co.
IjMarmon Group, Inc.
[Martin Marietta Corporation
|]Masco Industries Inc.
JMascotcch
IJMatcc Corporation
IJMeaden Screw Products Company
[[Mechanical Galv-Plating Corp
IJMeco Inc.
IJMclallics Inc.
[[Metromedia Company
[(Midwest Plating Company Inc.
Parent City
Weston,
ntario,
anada
hippewa Falls
eneva
Woodcliff
ake
isle
urchase
New York
Kenilworth
efferson City
Grafton
New York
hiner
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
WI
L
NJ
L
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
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, 347
3471, 3354
347
347
342
345
3769, 3499, 3479
347
3398, 347
346
3479, 2899, 348
345
347
344
347
3451, 349
347
Facilities
3
1
2
4
1
1
3
1
1
1
1
1
1
^
1
3
1
1
1
2
1
1
1
1
5
1
13
1
1
1
1
1
1
1
nd 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
867,354
6,827
6,800
•^ '
1,111,309
25,500
612,924
6,60
23,37
1,092,21
223,28
488,48
3,163,83
21,80
12,86
3,44
51,86
27,72
295,32
1988 to 1993
*
60
37
50
27
43
80
50
27
14
50
1
73
jU
50
SIC Code 34
126
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 40 (cont'd)
33/50 Program
f aient facility Ikclille
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
ackson
Bradford
N Brunswick
SJl
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
L
L
MS
OH
NJ
SIC Codes
347
347
3441, 3443
3443, 3714
3724, 347
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 Participatin
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
September 1995
127
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Exhibit 40 (cont'd)
33/50 Program
Parent Facility name
Protective Coatings Inc.
Providence Metallizing Co. Inc.
uality Rolling & Deburring Co.
R P Adams Company Inc.
Raytheon Company
Rehrig International Inc.
Reilly Plating Co.
Reliance Finishing Co.
teynolds Metals Company
S,K. Williams Co.
Schullcr Corporation
Seneca Foods Corporation
Sicbc Industries Inc.
Skills Inc.
Smith Everett Investment Co.
Smith System Manufacturing Co.
Sommcr Metalcraft Corp
Sonoco Products Company
Southline Metal Products Co.
Spx Corporation
Stanley Works
Sunset Fireplace Fixtures
Super Radiator Coils Ltd
Superior Plating Inc.
Surftcch Finishes Company
Swva Inc.
"awas Plating Company
Tech Industries Inc.
fcchmctals Inc.
Tektronix Inc.
fcnneeo Inc.
Texas Instruments Incorporated
rhcrma-Tru Corp
fhiokol Corporation
fhomas Steel Strip Corp
Trinova Corporation
J T I Corporation
United States Can Company Del
United Technologies Corp
US Can Corporation (Del)
Parent City
Kent
awtucket
Thomaston
Tonawanda
Lexington
Richmond
Nanticoke
Grand Rapids
Richmond
Wauwatosa
Denver
Pittsford
Richmond
Seattle
Milwaukee
Piano
Crawfordsville
Harts ville
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
SI
WA
RI
CT
NY
MA
VA
PA
MI
VA
Wl
CO
NY
VA
WA
WI
TX
N
SC
TX
MI
CT
CA
MN
MN
WA
WV
MI
RI
OH
OK
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
347
3663, 3444
344
3822, 2812, 3356
3471, 3714, 334
3442, 308
345
3471, 331
3451, 349
346
3412, 341
3086, 347
341
Facilities
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
2
i
i
10
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
2
7
nd 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
344,22
17,25
1,001,16
6,83
488,87
473,87
5,29
2,393,25
573,08
1988 to 1993
70
50
2
50
2
1
•^
50
25
27
50
64
50
8
25
41
4U
DU
SIC Code 34
128
September 1995
-------
T?abdicated Metal Products
Sector Notebook Project
Exhibit 40 (cont'd)
33/50 Program
iaircni c siC-ility iimii^
Valley Plating Works
Galley Technologies Inc.
Van Der Horst Usa Corporation
/eba 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
ifork Metal Finishing Co.
Zippo Manufacturing Company
Parent C^ity
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
SJL
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
ata.
** = 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
September 1995
129
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Project XL
Chang, ELP Director, (202) 564-5081 or Robert Fentress, (202) 564-
7023)
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 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
SIC Code 34
130
September 1995
-------
fabricated Metal Products
Sector Notebook Project
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
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)
September 1995
131
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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 (NICE3). 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)
VIH.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.
VTTT.C.l. 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.
Additionally, several organizations have sponsored workshops
focusing on waste minimization and pollution prevention in
several fabricated metal related industries. Three workshops, the
SIC Code 34
132
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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 recovery options, waste
treatment and management, and product substitutions and plating
alternatives. (Contact: the Kansas State University Division of
Continuing Education, (800) 432-8222)
September 1995
133
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
VTTT.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.
SIC Code 34
134
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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.
September 1995
135
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
Metal Fabricating Institute (FMI)
PO Box 1178
Rockford,IL 61105
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:
Staff:
Budget:
Contact:
940
6
$750,000
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.
SIC Code 34
136
September 1995
-------
Fabricated Metal Products
Sector Notebook Project
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: JonE.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.
September 1995
137
SIC Code 34
-------
Fabricated Metal Products
Sector Notebook Project
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,
Handtoolsf 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.
McGraw Hill Encyclopedia of Science and Technology, Volume 6, 1987.
SIC Code 34
138
September 1995
-------
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.
September 1995
139
SIC Code 34
-------
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.
SIC Code 34
140
September 1995
-------
APPENDIX A
INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK
Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web. The EnviroSenSe
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics. The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.
ACCESS THROUGH THE ENVIROSENSE WORLD WIDE WEB
To access this Notebook through the EnviroSenSe World Wide Web, set your World Wide
Web Browser to the following address:
http://eS.inel.gov/OCCa - then select "EPA Sector Notebooks"
Or after 1997, (when EPA plans to have completed a restructuring of its web site) set
your web browser to the following address:
WWW.epa.gOV/OeCa - then select the button labeled Gov't and Business
Sectors and select the appropriate sector from the menu.
The Notebook will be listed.
HOTLINE NUMBER FOR ESWWW: 208-526-6956
EPA ESWWW MANAGERS: Louis Paley 202-564-2613
Myles Morse 202-260-3151
(This page updated June 1997)
Appendix A
-------
-------
United States Government
INFORMATION
PUBLICATIONS * PERIODICALS * ELECTRONIC PRODUCTS
Order Processing Code:
*3212
Charge your order.
It's easy!
Fax your orders (202) 512-2250
Phone your orders (202) 512-1800
»»*•-
Qty.
>r,> ,--&,- omSS^^«im^^;^£^ 'Itfj^S^^&SS^^^S^SS^X^^i&i' 'S! >«'.yfr.?<
Stock Number
055-000-00512-5
055-000-00513-3
055-000-00518-4
055-000-00515-0
055-000-00516-8
055-000-00517-6
055-000-00519-2
055-000-00520-6
055-000-00521-4
055-000-00522-2
055-000-00523-1
055-000-00524-9
055-000-00525-7
055-000-00526-5
055-000-00527-3
055-000-00528-1
055-000-00529-0
055-000-00514-1
Published in 1995 Title
Dry Cleaning Industry, 1 04 pages
Electronics and Computer Industry, 160 pages
Fabricated Metal Products Industry, 164 pages
Inorganic Chemical Industry, ,136 pages
Iron and Steel Industry, 1 28 pages
Lumber and Wood Products Industry, 136 pages
Metal Mining Industry, 148 pages
Motor Vehicle Assembly Industry, 1 56 pages
Nonferrous Metals Industry, 140 pages
Non-Fuel, Non-Metal Mining Industry, 108 pages
Organic Chemical Industry, 1 52 pages
Petroleum Refining Industry, 1 60 pages
Printing Industry, 1 24 pages
Pulp and Paper Industry, 1 56 pages
Rubber and Plastic Industry, 152 pages
Stone, Clay, Glass and Concrete Industry, 124 pages
Transportation Equipment Cleaning Industry, 84 pages
Wood Furniture and Fixtures Industry. 132 oaaes
Price
Each
$ 6.50
11.00
11.00
9.00
8.00
9.00
10.00
11.00
9.00
6.50
11.00
11.00
7.50
11.00
11.00
7.50
5.50
8.00
Total
Price
Qty.
Stock Number
055-000-00570-2
055-000-00571-1
055-000-00572-9
055-000-00573-7
055-000-00574-5
055-000-00575-3
055-000-00576-1
055-000-00577-0
055-000-00578-8
055-000-00579-6
Published in 1997 Title
Air Transportation Industry, 90 pages
Ground Transportation Industry, 1 30 pages
Water Transportation Industry, 90 pages
Metal Casting Industry, 150 pages
Pharmaceutical Manufacturing Industry, 1 47 pages
Plastic Resin & Man-made Fiber Industry, 180 pages
Fossil Fuel Electric Power Generation Industry, 1 60 pages
Shipbuilding and Repair Industry, 1 20 pages
Textile Industry, 1 30 pages
Sector Notebook Data Refresh -1 997, 21 0 pages •
Price
Each
$ 7.50
10.00
7.50
13.00
13.00
15.00
14.00
9.50
10.00
17.00
Total for Publications
Total
Price
The total cost of my order is
Price includes regular shipping and handling and is subject to change.
Company or personal name
(Please type or print)
Additional address/attention line
Street address
City, State, Zip code
Daytime phone including area code
Check method of payment:
Q Check payable to Superintendent of Documents
Q GPO Deposit Account [| I I I I I |-|~|
ID VISA Q MasterCard Q Discover/NOVUS
| (expiration date) Thank you for your order!
7/97
Authorizing signature
Mail to: Superintendent of Documents
P.O. Box 371954, Pittsburgh, PA 15250-7954
Purchase order number (optional)
Important: Please include this completed order form with your remittance.
-------
------- |