Preliminary Review of the Metal Finishing Category; April 2018

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U.S. Environmental Protection Agency
Office of Water (4303T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
EPA 821-R-18-003
www.epa.gov/eg/metal-finishing-effluent-guidelines
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Table of Contents
TABLE OF CONTENTS
Page
1. Introduction 1-1
2. Summary of 2015 Status Report 2-1
2.1 Existing Metal Finishing ELGs 2-1
2.2 2015 Status Report Summary of Findings 2-3
3. Recent Study Activities 3-1
3.1 Site Visits to Metal Finishing Facilities 3-1
3.2 Discharge Monitoring Report (DMR) and Toxics Release Inventory (TRI)
Data Analysis 3-1
3.3 Pollution Prevention (P2) Review 3-5
3.4 Metal Products and Machinery (MP&M) Rulemaking 3-6
3.5 Technical Conferences 3-7
3.6 Stakeholder Outreach 3-8
3.6.1 Pretreatment Coordinators 3-9
3.6.2 Industry and Trade Organizations 3-9
3.6.3 Other Stakehol ders 3-9
3.7 Other Regul ati on Revi ew 3-9
4. Recent Study Findings 4-1
4.1 Site Visits to Metal Finishing Facilities 4-1
4.2 DMR/TRI Data Analysis 4-4
4.2.1 Industries under the Metal Finishing Category Contributing Top
Pollutant Discharges in 2014 4-4
4.2.2 Pollutant Analyses 4-6
4.2.3 Unregulated Pollutant Analysis 4-7
4.2.4 Regulated Pollutant Analysis 4-8
4.2.5 Summary of Results and Conclusions 4-9
4.3 Pollution Prevention (P2) Review 4-10
4.3.1 Process Technology Controls and Alternatives 4-10
4.3.2 Alternative Process Chemistries 4-11
4.3.3 Wastewater Recycling, Materials Recovery, and Treatment
Alternatives 4-11
4.3.4 P2 Initiatives and Resources for the Metal Finishing Industry 4-12
4.4 Metal Products and Machinery (MP&M) Rulemaking 4-16
4.4.1 Subcategories Containing Metal Finishers 4-16
4.4.2 Pollutants of Concern 4-18
in
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Table of Contents
TABLE OF CONTENTS (Continued)
Page
4.4.3 P2 Practices and Wastewater Treatment Technologies Identified
Between the Metal Finishing and MP&M Rulemakings 4-19
4.4.4 Technology Bases and Proposed ELGs 4-20
4.4.5 Key MP&M Findings for the Metal Finishing Industry 4-26
4.5 Technical Conferences 4-26
4.5.1 NASF SUR/FIN® Conference 4-27
4.5.2 NACWA Conferences 4-28
4.6 Stakeholder Outreach 4-28
4.6.1 Local Control Authorities and EPA Regional Pretreatment
Coordinators 4-28
4.6.2 Industry and Trade Organizations 4-29
4.6.3 Other Stakeholders 4-30
4.7 Other Regulations and Initiatives Affecting the Metal Finishing Industry 4-30
4.7.1 Federal Regulations 4-30
4.7.2 Other Environmental Directives 4-32
4.7.3 Customer Specifications and Certifications 4-34
5. Preliminary Review Conclusions 5-1
6. Quality Assurance 6-1
6.1 Project Objectives 6-1
6.2 Data Sources 6-1
6.3 Data Quality Objectives and Criteria 6-1
6.4 Data Quality Evaluation 6-3
6.4.1 Site Visits to Metal Finishing Facilities 6-4
6.4.2 Government Databases with Discharge Data (DMR and TRI) 6-4
6.4.3 Conference Proceedings, Peer-Reviewed Journal Articles, Other
Academic Literature 6-4
6.4.4 Existing Government Publications and Supporting Information 6-5
6.4.5 Information Obtained from Industry, Vendors, and Trade
Associations 6-5
7. References 7-1
Appendix A: SIC and NAICS Codes for the Metal Finishing Industry
Appendix B: Pollution Prevention (P2) Practices Identified in EPA's P2 Review
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List of Tables
LIST OF TABLES
Page
Table 2-1. Unit Operations Regulated by ELGs for the Metal Finishing Category 2-1
Table 2-2. Regulated Pollutants and ELG Limits for the Metal Finishing Category 2-2
Table 3-1. Summary of Analyses of the DMR and TRI Data Presented in this Report 3-4
Table 3-2. Keywords Used for Identifying Metal Finishing TRI P2 Practices 3-5
Table 3-3. Keywords Used for Literature Search of Metal Finishing P2 Practices 3-6
Table 4-1. List of Metal Finishing Site Visits 4-1
Table 4-2. Top Metal Finishing Dischargers by SIC and NAICS Codes Identified from
2014 DMR and TRI Data 4-5
Table 4-3. Top Pollutants by TWPE Based on Reported DMR Data, 2010 - 2014 4-6
Table 4-4. Top Pollutants by TWPE Based on Reported TRI Data, 2010 - 2014 4-7
Table 4-5. Summary of DMR and TRI Concentration Data for Unregulated Pollutants
Compared to Baseline Values 4-8
Table 4-6. Summary of DMR and TRI Concentration Data for Regulated Pollutants
Compared to Metal Finishing ELGs and Relevant LTAs 4-9
Table 4-7. Major Regional P2 Technical Assistance Websites 4-14
Table 4-8. Pollutants Considered for the Proposed MP&M Regulation for Metal-Bearing
Subcategories 4-18
Table 4-9. Practices and Technologies Identified in the 2001 MP&M TDD and Not
Discussed in the 1983 Metal Finishing TDD 4-20
Table 4-10. Proposed MP&M BPT/BAT Limits and Promulgated Metal Finishing BPT
and BAT Limits 4-22
Table 4-11. Proposed P2 Alternatives for Metal Finishing Job Shop Subcategory 4-23
Table 6-1. Data Quality Criteria Summary 6-3
Table 6-2. Data Acceptance Criteria for the Preliminary Study of the Metal Finishing
Category 6-6
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Abbreviations
ABBREVIATIONS
Acronym
Definition
ACPEIP
Administration on the Control of Pollution Caused by Electronic Information

Products
BAT
Best Available Technology Economically Achievable
BBP
Benzyl butyl phthalate
BCT
Best Conventional Pollutant Control Technology
BOE
Basis of Estimate
BPT
Best Practicable Control Technology Currently Available
CBI
Confidential Business Information
CFR
Code of Federal Regulations
CRD
Comment Response Document
CWA
Clean Water Act
CWT
Centralized Waste Treatment
DBP
Dibutyl phthalate
DCN
Document Control Number
DIBP
Diisobutyl phthalate
DMR
Discharge Monitoring Report
DTC
Dithiocarbonate
E3
Economy - Energy - Environment
ECHA
European Chemicals Agency
ELGs
Effluent Limitations Guidelines and Standards
EPA
Environmental Protection Agency
ERG
Eastern Research Group, Inc.
ESRC
Environmental Sustainability Resource Center
EU
European Union
FR
Federal Register
GACT
Generally Available Control Technology
GLRPPR
Great Lakes Regional Pollution Prevention Roundtable
HAP
Hazardous Air Pollutant
HEM
n-hexane extractable material
HVOF
High Velocity Oxygen Fuel
IWC
International Water Conference
KTBP
Known to be Present
LTA
Long-term Average
MFDF
Metal Finishers Defense Fund
MMSD
Milwaukee Metropolitan Sewerage District
mg/L
milligrams per Liter
MP&M
Metal Products and Machinery
NACWA
National Association of Clean Water Agencies
Nadcap
National Aerospace and Defense Contractors Accreditation Program
NAICS
North American Industry Classification System
NASF
National Association for Surface Finishing
vi
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Abbreviations
ABBREVIATIONS
Acronym
Definition
NCMS
National Center for Manufacturing Sciences
NESHAP
National Emission Standards for Hazardous Air Pollutants
NSPS
New Source Performance Standards
ORCR
Office of Resource Conservation and Recovery
OW
Office of Water
P2
Pollution Prevention
P2RIC
Pollution Prevention Regional Information Center
P2Rx
Pollution Prevention Resource Exchange
PBB
Polybrominated biphenyls
PBDE
Polybrominated diphenyl ethers
PFOS
Perfluorooctane sulfonate
POC
Pollutant of Concern
PoHS
Prohibition on Certain Hazardous Substance in Customer Products
POTW
Publicly Owned Treatment Works
PPE
Personal Protective Equipment
PPRC
Pollution Prevention Resource Center
PQAPP
Programmatic Quality Assurance Project Plan
PSES
Pretreatment Standards for Existing Sources
PSNS
Pretreatment Standards for New Sources
QA
Quality Assurance
RBE
River's Bend Engineering
RCRA
Resource Conservation and Recovery Act
REACH
Registration, Evaluation, Authorization and Restriction of Chemical substances
RO
Reverse Osmosis
RoHS
Restriction of Hazardous Substances
SGP
Strategic Goals Program
SIC
Standard Industrial Classification
TDD
Technical Development Document
TOC
Total Organic Compound
TOP
Total Organics Parameter
TRI
Toxics Release Inventory
TSS
Total Suspended Solids
TTO
Total Toxic Organics
TWF
Toxic Weighted Factor
TWPE
Toxic Weighted Pound Equivalent
VOC
Volatile Organic Compounds
WA/FS
Wetting Agents/Fume Suppressants
WEFTEC
Water Environment Federation's Annual Technical Exhibition and Conference
WSPPN
Western Sustainability and Pollution Prevention Network
vii
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Section 1—Introduction
1. Introduction
The Clean Water Act (CWA) directs EPA to review the existing effluent guidelines
annually, and revise them if appropriate, as well as to identify categories of sources for which
ELGs have not been developed. The statute also requires annual review of existing pretreatment
standards, and revision, if appropriate. EPA promulgated Effluent Limitations Guidelines and
Standards (ELGs) for the Metal Finishing Category (Metal Finishing ELGs), codified at 40 Code
of Federal Regulations (CFR) Part 433, in 1983. EPA reevaluated the Metal Finishing ELGs
during the development of the Metal Products and Machinery (MP&M) rulemaking in the late
1990s and early 2000s.
In the Final 2014 Effluent Guidelines Program Plan, EPA announced plans to conduct a
preliminary study of the Metal Finishing Category to assess the current state of the industry,
including an updated industry profile, descriptions of new and traditional process technologies
and techniques, potential new pollutants of concern, advances in wastewater treatment
technologies, and strategies used to achieve zero liquid discharge (U.S. EPA, 2015a, 2015b). As
part of the public docket for the Preliminary 2016 Effluent Guidelines Program Plan, EPA
included a 2015 Status Report for this effort. In this report, EPA noted that it planned to collect
additional information to further assess the current state of the industry, including changes in
process operations and wastewater characteristics, availability of improved technologies for
pollution prevention and wastewater treatment, and challenges facilities face in applying the
Metal Finishing ELGs. This 2017 status report builds on the previous report and describes study
activities conducted since the 2015 Status Report.
The remainder of this report is organized as follows:
• Section 2 summarizes the existing metal finishing regulations and describes the
findings from the 2015 Status Report.
• Section 3 generally describes the methodology for activities that EPA has conducted
since the 2015 Status Report.
• Section 4 provides further details on EPA's study findings for activities EPA has
conducted since the 2015 Status Report, including site visits, analysis of available
discharge data, pollution prevention (P2) literature and data review, detailed review
of select MP&M rulemaking documentation, technical conferences, stakeholder
outreach, and review of other existing regulations that may impact metal finishing
operations and wastewater generation.
• Section 5 summarizes EPA's conclusions for the study.
• Section 6 summarizes EPA's quality assurance (QA) procedures for reviewing
existing information presented in this report.
• Section 7 is the list of references cited in the report.
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Section 2—Summary of 2015 Status Report
2. Summary of 2015 Status Report
As described above, EPA previously published a report on its study of the Metal
Finishing ELGs: Preliminary Study of the Metal Finishing Category: 2015 Status Report (2015
Status Report) (U.S. EPA, 2016a). This section provides an overview of the existing Metal
Finishing ELGs (regulated unit operations and pollutants, treatment technology basis), as
detailed in Section 2 of the 2015 Status Report and summarizes the activities and findings of the
2015 Status Report.
2.1 Existing Metal Finishing ELGs
Wastewater discharges from metal finishing operations are regulated primarily under
ELGs for the Metal Finishing Category (40 CFR Part 433).1,2 The Metal Finishing ELGs
regulate wastewater discharges from six primary metal finishing operations. Additionally, at
facilities where at least one of these primary operations is being conducted, the ELGs also cover
wastewater discharges resulting from 40 additional metal finishing operations. If a facility does
not perform any of the six primary metal finishing operations, it is not subject to the Metal
Finishing ELGs (U.S. EPA, 1984). Table 2-1 lists the six primary metal finishing operations and
40 additional metal finishing operations. Detailed descriptions of these operations can be found
in Section 2.2 of the 2015 Status Report (U.S. EPA, 2016a).
Table 2-1. Unit Operations Regulated by ELGs for the Metal Finishing Category
Six Priniiin Oporn I ions
40 Additional Moliil l inishinii I nil Opci'iilions
• Electroplating
• Cleaning
• Laser beam machining
• Electroless plating
• Machining
• Plasma arc machining
• Anodizing
• Grinding
• Ultrasonic machining
• Coating
• Polishing
• Sintering
• Etching and chemical milling
• Barrel finishing
• Laminating
• Printed circuit board manufacturing
• Burnishing
• Hot dip coating

• Impact deformation
• Sputtering

• Pressure deformation
• Vapor plating

• Shearing
• Thermal infusion

• Heat treating
• Salt bath descaling

• Thermal cutting
• Solvent degreasing

• Welding
• Paint stripping

• Brazing
• Painting

• Soldering
• Electrostatic painting

• Flame spraying
• Electropainting

• Sand blasting
• Vacuum metalizing

• Abrasive jet machining
• Assembly

• Electrical discharge machining
• Calibration

• Electrochemical machining
• Testing

• Electron beam machining
• Mechanical plating
Source: 40 CFR Part 433.
1 Discharges from facilities performing metal finishing operations may also be regulated under other ELGs (e.g.,
Aluminum Forming, Iron and Steel) that take precedence over the Metal Finishing ELGs.
2 Certain electroplating and metal finishing facilities that began operation before July 15, 1983 and discharge wastes
to POTWs are covered under the Electroplating Category (40 CFR Part 413).
2-1
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Section 2—Summary of 2015 Status Report
At promulgation, 78 percent of facilities indirectly discharged metal finishing wastewater
to receiving water via POTWs, and 22 percent directly discharged to surface waters (U.S. EPA,
1984). The Metal Finishing ELGs established one set of concentration-based discharge limits
that apply across a single subpart (Subpart A: Metal Finishing), summarized in Table 2-2. Direct
dischargers comply with best practicable control technology currently available (BPT)/best
available technology economically achievable (BAT) discharge limitations and new source
performance standards (NSPS), whereas indirect dischargers comply with pretreatment standards
for existing sources (PSES) and pretreatment standards for new sources (PSNS). As the table
shows, the limitations and standards are the same for new and existing sources of metal finishing
wastewater discharges, except for cadmium, which has a lower NSPS and PSNS discharge
standard (U.S. EPA, 1983).
Table 2-2. Regulated Pollutants and ELG Limits for the Metal Finishing Category
I nil Opoi'iilions ( »\eml
Polliiliini
lil'l/liAI/l'SIS
l);iil\ M;i\
(Mnn(hl\ A\er;iiie)
(inii/l.)
NSPS/I'SNS
l);iil\ M;i\
(Mon(hl\ A\cr;i^i')
(mji/l.)
See Table 2-1, for the list of 46 unit operations.3
Cadmium (T)
0.69 (0.26)
0.11 (0.07)
Chromium (T)
2.77(1.71)
2.77(1.71)
Copper(T)
3.38 (2.07)
3.38 (2.07)
Lead (T)
0.69 (0.43)
0.69 (0.43)
Nickel (T)
3.98 (2.38)
3.98 (2.38)
Silver (T)
0.43 (0.24)
0.43 (0.24)
Zinc (T)
2.61 (1.48)
2.61 (1.48)
Cyanide (T)b
1.20 (0.65)
1.20 (0.65)
Total Toxic
Organics (TTO)°
2.13
2.13
Oil and Greased
52 (26)
52 (26)
Total Suspended
Solids (TSS)d
60 (31)
60 (31)
pHd
Within 6.0 to 9.0
Within 6.0 to 9.0
For industrial facilities with cyanide treatment, and
upon agreement between a source subject to those
limits and the pollution control authority, the
following amenable cyanide limit may apply in
place of the total cyanide limit.
Cyanide
amenable to
alkaline
chlorination
0.86 (0.32)
0.86 (0.32)
Source: 40 CFRPart 433.
(T): Total
a The provisions of this subpart apply to discharges from six electroplating operations on any basis material:
electroplating, electroless plating, anodizing, coating (chromating, phosphating, and coloring), chemical etching
and milling, and printed circuit board manufacturing. If any of these six operations are present, the provisions of
this subpart also apply to discharges from 40 additional metal finishing operations, listed in Table 2-1. These
limits do not apply to (1) metallic platemaking and gravure cylinder preparation conducted within or for printing
and publishing facilities or (2) existing indirect discharging job shops and independent printed circuit board
manufacturers, which are covered by 40 CFR Part 413.
b Anti-dilution provisions are stipulated in 40 CFR Part 433, which require self-monitoring for cyanide after
cyanide treatment and before dilution with other waste streams. In general, the practice of diluting rinse water as a
partial or total substitute for adequate treatment to achieve compliance with discharge limits is in violation of the
National pretreatment standards: Categorical standards (40 CFR Part 403.6(d)).
0 No monthly average TTO limitation.
d Parameter is regulated for BPT and NSPS only.
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Section 2—Summary of 2015 Status Report
EPA based BPT, BAT, and PSES on the treatment of metal finishing wastewater using
hydroxide precipitation, clarification, and sludge dewatering for common metals treatment, with
pretreatment steps for chromium reduction, cyanide oxidation, complexed metals removal, and
oil and grease removal, where the wastewater contains these components. EPA based NSPS and
PSNS on the BPT/BAT/PSES technology, adding in-process treatment modifications for
controlling the discharge of cadmium. The modifications for controlling cadmium employ
evaporative recovery or ion exchange on cadmium-bearing wastewater before it mixes with other
wastewater (U.S. EPA, 1983). Section 2.3 of the 2015 Status Report discusses in detail the
technology bases for BPT/BAT/PSES andNSPS/PSNS (U.S. EPA, 2016a).
2.2 2015 Status Report Summary of Findings
As described in the 2015 Status Report, EPA initiated a review of the industry by
examining existing information that EPA collected through technical conferences, discussions
with industry experts and stakeholders, and a literature review. From these activities, EPA found
(U.S. EPA, 2016a):
• Some facilities are implementing pollution prevention practices to minimize the
volume of wastewater discharged, including countercurrent rinsing systems and
replacing evaporative losses in plating baths with both untreated and treated
rinsewater.
• Primary sources of wastewater have not changed since promulgation of the Metal
Finishing ELGs. Most of the wastewater generated continues to originate from rinsing
and cleaning operations. Improvements to coating and plating processes have not
been shown to generate additional waste streams and generally aim to minimize
process losses associated with the technology.
• Chemical recovery operations are performed by metal finishing facilities that use
valuable plating chemicals such as gold and silver.
• At most metal finishing facilities, wastewater management and solid waste disposal
are significant components of overall operating costs.
• Most metal finishing facilities continue to use conventional chemical precipitation
technologies, although, some facilities have added a polishing step, such as
membrane filtration or sorption technologies. EPA also learned that industry has been
slow to develop or adopt advanced wastewater treatment technologies, most likely
due to the costs of installation and operation. However, EPA has not fully evaluated
the extent to which the metal finishing industry is applying technologies beyond the
BPT technology basis.
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Section 3—Recent Study Activities
3. Recent Study Activities
This section describes EPA's activities for the preliminary study of the Metal Finishing
Category, undertaken since the publication of the 2015 Status Report (U.S. EPA, 2016a),
including site visits, analysis of available discharge data, P2 literature and data review, detailed
review of select MP&M rulemaking documentation, technical conferences, stakeholder outreach,
and review of other existing regulations that may impact metal finishing operations and
wastewater generation. Section 4 of this report details EPA's findings from these activities.
These findings (in addition to those described in the 2015 Status Report) will inform EPA's
decisions on how to proceed with the study.
3.1 Site Visits to Metal Finishing Facilities
EPA conducted site visits at 18 facilities to observe metal finishing operations and
wastewater management practices. During these visits, EPA collected information on current
metal finishing operations and associated wastewater generation; wastewater management
including pollution prevention and/or wastewater reduction and associated costs; and historical
data on raw and treated wastewater samples. EPA visited facilities near Los Angeles, CA; Salt
Lake City, UT; Detroit, MI; and Chicago, IL. These facilities served the following markets:
• Aircraft/aerospace
• Automotive
• Medical devices
• Military
• Electronics (including semiconductors)
• Jewelry and miscellaneous awards (medals, trophies, etc.)
• General, non-specific
EPA also visited one vendor in Indiana that developed an environmentally friendly
alternative to hexavalent chromium plating baths. Further details on information gathered during
site visits are provided in Section 4.1.
3.2 Discharge Monitoring Report (DMR) and Toxics Release Inventory (TRI) Data
Analysis
EPA reviewed DMR and TRI data and conducted follow-up conversations with facilities
that reported the data. The objectives of the review were to:
• Determine the types of industries that are subject to Metal Finishing ELGs by
Standard Industrial Classification (SIC) and North American Industry Classification
System (NAICS) code.3
• Gain more knowledge about pollutants discharged from metal finishing operations,
with a focus on those that are not regulated by the 1983 Metal Finishing ELGs.
3 DMR data classifies facilities by SIC code, while TRI data classifies facilities by NAICS code.
3-1
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Section 3—Recent Study Activities
• Identify potential changes in wastewater and pollutant discharges from the metal
finishing industry since the 1983 ELGs.
EPA reviewed DMR and TRI data in two phases. EPA first analyzed 2014 DMR and TRI
data for the 178 SIC codes and 203 NAICS codes with facilities likely to perform operations
under the Metal Finishing Category (see Appendix A) and identified four SIC codes and six
NAICS codes for further review. Second, EPA reviewed multi-year (2010 through 2014)
analyses of DMR and TRI data for the four SIC and six NAICS codes to confirm industries with
metal finishing operations and to evaluate whether any regulated or unregulated pollutants
warrant additional control.
EPA then compared the TRI and DMR data to the following:
• Metal Finishing ELGs and Long-Term Average (LTA) Concentrations. EPA
compared DMR and underlying TRI concentration data to the 1983 Metal Finishing
ELGs and long-term average concentrations4 (hereafter "MF ELG LTA"). EPA
performed this analysis to understand how current discharges compare to the
limitations and limitation bases for the existing ELGs.
• Metal Products and Machinery (MP&M) Proposed LTA Concentrations. EPA
compared DMR and underlying TRI concentrations to the 2001 MP&M ELGs lowest
pollutant LTA (hereafter "MP&M LTA") across all MP&M proposed subcategories
that cover metal finishing facilities (Metal Finishing Job Shops, Printed Wiring
Boards, Non-Chromium Anodizing, and General Metals Subcategories).5 EPA used
this comparison to gauge how facility discharges have changed and to understand
their current treatability.
• Analytical Baseline Value. The Development Document for the Effluent Limitations
Guidelines and Standards for the Centralized Waste Treatment (CWT) Industry -
Final established analytical baseline values for various pollutants under the metals
subcategory for CWT wastewater. In general, the baseline values are equal to the
nominal quantitation limit identified for the specified pollutant's analytical methods
(U.S. EPA, 2000a). When looking at a pollutant's concentration in a wastewater, EPA
often compares that concentration to five or ten times the baseline value to gauge its
treatability. For unregulated pollutants identified, EPA compared DMR and
underlying TRI concentrations to the respective baseline values. For this analysis,
EPA considered DMR and underlying TRI concentrations detected above five times
the baseline value as treatable.
Table 3-1 summarizes the analyses EPA performed and the scope of those analyses
presented in this report. For background information about the methodology for obtaining the
DMR/TRI data for this analysis, including a methodology process flow diagram, see the Metal
4 Long term averages are not typically the same as the limitations (or standards). Facilities are required to meet the
limitations (or standards) which include variability factors. EPA often compares pollutant concentrations to the
LTAs instead of the limitations (or standards) because the LTAs represent the level at which treatment technologies
should be targeted to ensure compliance with the limitations (or standards).
5 Refer to Section 3.4 and 4.4 for more information about the MP&M rulemaking.
3-2
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Section 3—Recent Study Activities
Finishing Preliminary Study: Summary of Phase I and Phase II Review of DMR and TRI Data
(ERG, 2017a). Section 4.2 of this report presents the results from this analysis.
3-3
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Section 3—Recent Study Activities
Table 3-1. Summary of Analyses of the DMR and TRI Data Presented in this Report
Diilii Source
SIC /\.\l( S ('ink's ImoNliiiiik'd
An;il\scs Performed
2014 DMR and
TRI Pollutant
TWPE Data
All Metal Finishing SIC and NAICS Codes (see
Appendix A)
• Evaluated pollutant discharge loads (in pounds per year and toxic weighted
pound equivalents (TWPE)), facility counts, and percent unregulated
pollutants by SIC/NAICS industry to recommend a subset of SIC/NAICS
industries for further review.
Facility Contacts
Corresponding NAICS
SIC Codes: Codes:
• 3731 - Ship Building • 332813 -Electroplating
• 3479 - Metal Coating • 336350; 336340; and
• 3471 - Electroplating 336330 - Motor Vehicle
• 3714 - Motor Vehicle • 336611 - Ship Building
• 3624 - Carbon • 332812 - Metal Coating
Graphite • 335991 - Carbon
Graphite
• Contacted facilities with the largest TWPE contribution from the subset of
SIC/NAICS industries identified in the previous step to confirm that the
facility conducts metal finishing operations and discharges metal finishing
wastewater. EPA did not pursue further review of Carbon and Graphite
Manufacturing facilities (SIC 3624; NAICS 335991) because they do not
perform metal finishing operations, as defined in the 1983 regulations.
2010-2014
DMR and TRI
Pollutant TWPE
and
Concentration
Data0
• 3471 - Electroplating
• 3714 - Motor Vehicle
• 3731 - Ship Building
• 3479 - Metal Coating
• Identified for further review a subset of toxic pollutants that contribute greater
than 95 percent of the multi-year (2010-2014) TWPE across the industries
identified from the step above.
• Gathered available outfall and monitoring period concentration data for all
facilities within the identified industries discharging the top toxic pollutants.
• Unregulated Pollutants a Compared the concentrations for each of the top
unregulated pollutants to five times their respective baseline values to assess
their general treatability.
• Regulated Pollutants.b Compared the concentrations of each of the top
regulated pollutants to the MF ELGs, MF ELG LTAs and MP&M LTAs to
understand how current discharges compare to the ELGs and the most
recently evaluated technology performance.
a "Unregulated Pollutants" are considered any pollutants that do not have limits under the Metal Finishing ELGs (U.S. EPA, 1983).
b "Regulated Pollutants" are considered any pollutants with limits under the Metal Finishing ELGs or proposed MP&M ELGs (U.S. EPA, 1983, 2000b).
0 Because EPA lacks pollutant discharge concentration data for indirect discharges in the DMR and TRI data, EPA contacted facilities that indirectly discharge
metal finishing wastewater and report to TRI a basis of estimate (BOE) of Ml or M2 to obtain underlying concentration data. For further information on
facility contacts, see Section3.4 of the Metal Finishing Preliminary Study: Summary of Phase I and Phase II Review of DMR and TRI Data (ERG, 2017a).
3-4
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Section 3—Recent Study Activities
3.3 Pollution Prevention (P2) Review
EPA reviewed several publicly available data sources to identify P2 practices performed
by Metal Finishing facilities and the prevalence of these practices across the industry. The data
sources used in this review included:
• TRIP2 Data. TRIP2 data are reported voluntarily by facilities to the TRI Program
each year. EPA analyzed 2011 through 2015 TRI P2 data for NAICS codes that fall
under the Metal Finishing Category and performed a targeted keyword search of P2
descriptions to understand the P2 practices metal finishing facilities are currently
implementing. EPA used the keywords provided in Table 3-2 to flag relevant records
for further review (U.S. EPA, 2017).
Table 3-2. Keywords Used for Identifying Metal Finishing TRI P2 Practices
l"l;iii 1 > |>e
kow orris
Metal Finishing/Electroplating
Metal finish*
Electroplat*
Recycle
recover*
re eye*
reus*
Alternative
alternative
replac*
Zero Liquid Discharge
zero discharge
zero liquid discharge
no discharge
complete recycle
Wastewater Treatment
treatment

Pilot-Scale
pilot

Secondary Keywords
coat*
chromat*
phosphat*
color*
printed circuit*
anodiz*
electroless*
etch*
Note: An asterisk within a keyword searches for all forms of the word containing the portion of the word or
phrase prior to the asterisk.
• Targeted literature search. EPA performed a targeted literature review to identify in-
process and resource recovery P2 technologies, either emerging or prevalent in the
metal finishing industry, and to determine the purpose of the identified technologies.
This literature search builds on previous EPA literature reviews, described in the
2015 Status Report, that focused on recent technological advances in removing metals
in metal finishing wastewater. EPA searched for peer-reviewed journal articles using
keywords listed in Table 3-3. EPA identified and reviewed eight journal articles in the
targeted search.
3-5
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Section 3—Recent Study Activities
Table 3-3. Keywords Used for Literature Search of Metal Finishing P2 Practices
Priniiin keywords
Socdiuhir\ ko\weirds
Tcrli.in ko\ words
Metal finish*
Electroplat*
Pollution Prevention
P2
Recover*
Recyc*
Reduc*
Reuse
BMP
Zero discharge
Wastewater treatment
Hazardous waste
Pilot scale
Full scale
Electroless
Coat*
Chromat*
Phosphat*
Color*
Printed circuit*
Cadmium
Chromium
(hexavalent/trivalent)
Lead
Nickel
Copper
Cyanide
Toxic Organics
Fluoride
Search Engine: Google Scholar
Note: An asterisk within a keyword searches for all forms of the word containing the portion of the word
or phrase prior to the asterisk.
• Response to Comments for the Final Effluent Limitations Guidelines and Standards
for the Metal Products and Machinery Point Source Category (MP&M CRD) (U.S.
EPA, 2003a). As part of the MP&M rulemaking, EPA solicited comments on the
proposed MP&M ELGs, which included proposed limitations and guidelines for
facilities covered under the Metal Finishing Point Source Category. EPA searched the
MP&M CRD (U.S. EPA, 2003a) for comments that used the term "pollution
prevention" and reviewed comments relevant to metal finishing facilities to identify
P2 practices and technologies they were using at the time of the MP&M rulemaking.
• Economy - Energy - Environment (E3). E3 is a federal technical assistance
framework comprising six federal government agencies, including EPA. The
technical assessments strive to reduce energy consumption, minimize carbon
footprints, prevent pollution, increase productivity, and drive innovation. Typically,
E3 projects are financed by sources such as federal grants, sustainability funds, and
manufacturer's investments. EPA reviewed E3 success stories to identify any
innovative P2 practices implemented at metal finishing facilities under this initiative.
• RegionalP2 contacts. EPA reviewed regional EPA websites to identify any recently
active P2 initiatives that targeted the metal finishing industry, as well as resources
available to metal finishers looking to implement P2 practices (e.g., guidance
documents).
Section 4.3 of this report presents the results of these reviews, including a summary of P2
practices common in the metal finishing industry and resources available to metal finishers.
3.4 Metal Products and Machinery (MP&M) Rulemaking
EPA reviewed supporting documentation from the 2001 MP&M proposed rulemaking,
which evaluated facilities covered under the Metal Finishing Category. While EPA decided not
to promulgate limits or standards for any metal-bearing wastewater discharges under MP&M,
including discharges from metal finishing processes, the MP&M Rulemaking documentation
contains information and data related to the Metal Finishing Category that may be useful for the
current study. More specifically, EPA reviewed the metal finishing industry profile, metal
3-6
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Section 3—Recent Study Activities
finishing process and wastewater technology improvements, and metal finishing wastewater
characteristics. EPA also reviewed supporting materials, including correspondence with trade
organizations, treatment technology studies, site visit and sampling reports, and databases
containing data from information gathering activities, such as questionnaires and sampling
episodes.
EPA reviewed the MP&M Rulemaking documentation in two phases: an initial screening
review followed by a more detailed review and extraction of information. EPA initially screened
more than 1,000 documents associated with the rulemaking to gain perspective on the type of
information and data collected and the challenges EPA may have previously encountered in
revisiting ELGs applicable to metal finishing facilities. For more information on the initial
screening and approach, see Approach for the Review of Metal Products and Machinery
(MP&M) Rulemaking Documentation (ERG, 2016a) and Metal Products and Machinery
(MP&M) Rulemaking Documentation: Screening Review Results and Proposed Approach for
Detailed Review (ERG, 2016b).
Ultimately, EPA reviewed the Technical Development Document for the 2001 Proposed
Rule (MP&M TDD) (U.S. EPA, 2000b), the Preamble to the 2001 proposed rule (U.S. EPA,
2001), and the Preamble for the 2003 final rule (U.S. EPA, 2003b), in addition to the targeted
review of the MP&M CRD discussed in Section 3.3 (U.S. EPA, 2003a). EPA reviewed
information in the MP&M TDD to identify changes in the metal finishing industry that occurred
from the development of the 1983 Metal Finishing ELGs up to the development of the 2001
proposed MP&M ELGs, including pollutants of concern (POCs), metal-bearing wastewater
generation (e.g., operations and rinses), and P2 practices. EPA also compared the proposed
technology options for metal-bearing wastewater subcategories in the MP&M proposed rule to
wastewater treatment operations identified during the development of the Metal Finishing ELGs.
EPA reviewed the 2001 proposed rule Preamble and 2003 final rule Preamble to identify
information relevant to the metal finishing industry, including major comments from
stakeholders and rationale for EPA's decision not to revise the ELGs for the Metal Finishing
Category (40 CFR Part 433) in the final MP&M ELGs. For additional information on the
detailed reviews of the MP&M documentation, s ee Metal Products and Machinery (MP&M)
Rulemaking Preamble: Summary of Industry Comments and EPA Decisions Related to the Metal
Finishing Category (ERG, 2017b) and Metal Products and Machinery (MP&M) Rulemaking
TDD: Review and Comparison of Wastewater Technologies, Pollutants of Concern, and
Pollution Prevention (P2) Practices Considered in the MP&M and Metal Finishing Rulemakings
(ERG, 2017c).
Section 4.4 of this report summarizes the results of the review of the MP&M
Rulemaking.
3.5 Technical Conferences
EPA attended the following industry-specific and general wastewater treatment technical
conferences to further inform the Agency on current industry practices:
• National Association for Surface Finishing (NASF) SUR/FIN® Manufacturing &
Technology Trade Show & Conference.
3-7
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Section 3—Recent Study Activities
• National Association of Clean Water Agencies (NACWA) 2016 and 2017
Pretreatment & Pollution Prevention Workshops.
• Water Environment Federation's Annual Technical Exhibition and Conference
(WEFTEC).
• Engineers' Society of Western Pennsylvania's International Water Conference
(IWC).
EPA attended the 2016 NASF SUR/FIN® Manufacturing & Technology Trade Show &
Conference from June 6-8, 2016, specifically to gather information for the preliminary study of
the Metal Finishing Category. This event included vendor booths, paper presentations, and
keynote presentations on surface finishing process advancements, novel technologies, and waste
management. Presenters and attendees include vendors, engineers, business executives,
regulators, and trade association leaders.
EPA attended the NACWA 2016 Pretreatment & Pollution Prevention Workshop from
May 17-20, 2016, and the 2017 Pretreatment & Pollution Prevention Workshop from May 16-19,
2017, specifically to gather information for the preliminary study of the Metal Finishing
Category. The conference gathers pretreatment professionals, regulators, and vendors to attend
workshops and participate in roundtable discussions.
EPA attended WEFTEC on September 24-28, 2016, as part of its annual effluent
guideline review process. WEFTEC provides water quality education and training by offering
technical sessions and workshops on a variety of topics and provides access to information from
exhibitors on water management technologies and services. EPA attended presentations and
obtained papers from proceedings relevant to process technologies, alternative chemistries, and
wastewater treatment technologies. For the preliminary study of the Metal Finishing Category,
EPA reviewed publications from WEFTEC to identify those regarding the treatment of metal
finishing wastewater.
EPA also attended the Engineers' Society of Western Pennsylvania's IWC on November
7-9, 2016, as part of its annual effluent guideline review process. IWC discusses the most recent
scientific advances and practical applications for treatment, use, and reuse of water for
engineering purposes, industry, or otherwise. Presenters and attendees of the IWC include
researchers, practicing engineers, managers, educators, suppliers, contractors, government
workers, and end users. Most of the publications presented at the conference pertained to the
steam electric generating industry; however, EPA also reviewed the publications and identified
those relevant to treatment of metal finishing wastewater.
Section 4.5 provides a summary of the conference presentations and topics most relevant
to the preliminary study of the Metal Finishing Category.
3.6 Stakeholder Outreach
EPA contacted a variety of stakeholders to improve its understanding of the metal
finishing industry and to gain different perspectives on the implementation of the 1983
regulations and current industry operations, discussed below. Further information on the findings
of EPA's stakeholder outreach is presented in Section 4.6.
3-8
-------
Section 3—Recent Study Activities
3.6.1 Pretreatment Coordinators
As discussed in Section 2, most metal finishing facilities are indirect dischargers subject
to pretreatment standards under the Metal Finishing ELGs. As part of its annual effluent
guideline review, EPA continued its conversations with its regional pretreatment coordinators
who have direct experience with metal finishing wastewater issues at POTWs. As the scope of
the Metal Finishing ELGs is specific to "operations" such as electroplating, etching, and cleaning
rather than a specific type of manufacturing, the primary issue raised by the pretreatment
coordinators regarded the applicability of this rule, particularly at facilities for which metal
finishing operations are ancillary. The pretreatment coordinators also assisted EPA in further
understanding the industry's current profile and identifying metal finishing scenarios for which
the applicability of the regulations is unclear.
3.6.2 Industry and Trade Organizations
EPA continued discussions with the NASF, a trade association representing the interests
of metal finishers (among others). At their invitation, EPA spoke at the NASF Washington
Forum in April 2016, to discuss the Agency's metal finishing industry study. EPA also met with
NASF in February 2016, November 2016, and April 2017 to discuss the preliminary study of the
Metal Finishing Category and information collection requirements. In addition to these meetings,
EPA attended a project kickoff meeting for the P2 Research and Implementation for Michigan
Metal Finishers and reviewed the "NASF Milwaukee Area Surface Finishing Industry Metal
Loadings Study," provided by NASF.
3.6.3 Other Stakeholders
EPA met with the NACWA in November 2016 to understand their perspective on the
implementation of the 1983 regulations. EPA also met with NACWA members (Control
Authorities) at the 2016 and 2017 national pretreatment conference. NACWA members indicated
that the regulations are sufficient but noted that in some cases applicability determinations
continue to be challenging. They noted inconsistent determinations and, like the EPA
pretreatment coordinators, raised questions concerning the applicability of the regulations
particularly at facilities where the metal finishing operations are ancillary.
3.7 Other Regulation Review
EPA performed a comprehensive search of federal regulations which potentially affect
the Metal Finishing Category. This search included reviewing environmental regulations on
government websites and environmental compliance information on metal finishing trade
organization websites. A summary of other regulations most relevant to the preliminary study of
the Metal Finishing Category appears in Section 4.7.
3-9
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Section 4—Recent Study Findings
4. Recent Study Findings
This section describes the findings of EPA's analyses of the data and information
gathered during the 2016 and 2017 activities described in Section 3, including:
• Site Visits to Metal Finishing Facilities (Section 4.1)
• DMR and TRI Data Analysis (Section 4.2)
• P2 Review (Section 4.3)
• MP&M Rulemaking (Section 4.4)
• Technical Conferences (Section 4.5)
• Stakeholder Outreach (Section 4.6)
• Other Regulation Review (Section 4.7)
The findings discussed in this section focus on the following topics:
• Changes to the scope of facilities, including geographic distribution, facility size,
distribution of captive and job shop operations, discharge practice, and downstream
markets.
• Advances in process technologies.
• Use of alternative process chemicals and formulations.
• Use of pollution prevention and wastewater treatment technologies.
• Existing regulatory issues and industry standards for consideration.
4.1 Site Visits to Metal Finishing Facilities
In 2016, EPA conducted site visits at 18 facilities to observe and collect information on
metal finishing operations and wastewater management practices. EPA selected the facilities by
reviewing publicly available discharge data, wastewater treatment processes, TRI P2 data, and
through recommendations from Control Authorities. During these visits, EPA received
information on general process design, typical operating conditions, wastewater treatment and/or
management technologies and approaches, data on raw and treated wastewater samples, and
plating metal usage rates. EPA also visited one vendor in Indiana that had developed (at lab
scale) an environmentally friendly alternative to hexavalent chromium plating baths, using
trivalent chromium and an ionic liquid chemistry. EPA prepared individual site visit reports
documenting each visit and providing detailed, facility-specific information. Table 4-1 lists the
metal finishing facilities where EPA conducted site visits and cites the Document Control
Numbers (DCNs) of all the site visit reports in the docket.
Table 4-1. List of Metal Finishing Site Visits
l-';icilil\ Nsinio
l-';ioilil>
locution
40 ( I K
413/433
\\ ohsilo
Silo \ isil
D.ilo
Silo \ isil
Kopoi'i IK V
Carlisle
Interconnect
El Segundo,
CA
433
htto://www.carlisleit.com/
May 16,
2016
MF00111CBI,
MF00161
PB Fasteners
Gardena, CA
433
htto://www.Dccfasteners.com/com
Danies/Dcc-fasteners/Db-
fasteners.html
May 17,
2016
MF00113CBI,
MF00158
4-1
-------
Section 4—Recent Study Findings
Table 4-1. List of Metal Finishing Site Visits
l-';icilil\ Niimc
locution
40 (TR
413/433
\\ I'hsiic
Silo \ isil
Diilo
Silo \ isil
Report DCN-1
Northrop
Grumman
Redondo
Beach, CA
433
http://www.northropgrumman.com
May 19,
2016
MF00114
Hill Air Force
Base
Ogden, UT
433
htto: //www .liilLaf.mil/
July 11,
2016
MF00119CBI,
MF00184
Williams
International
Ogden, UT
433
fatto://www.williams-int.cGm/
July 12,
2016
MF00120CBI,
MF00185
Blanchard
Metal
Processing
Salt Lake
City, UT
413
hUD://www.bniDroc.com/
July 13,
2016
MF00121CBI,
MF00186
Pilkington
Metal Finishing
LLC
Salt Lake
City, UT
433
http^lkingtomnetalfinishing.oo^
July 13,
2016
MF00122CBI,
MF00187
O.C. Tanner
Manufacturing
Company
Salt Lake
City, UT
433
lit to://www.octa nner. co m/about-
us/ma nufacturi ng-excelle nee. lit nil
July 14,
2016
MF00123CBI,
MF00188
Varian Metal
Systems X-Ray
Products
Salt Lake
City, UT
433
lit tDs://www.vari an.com/about-
va ria n/vari a n- techno lo eie s
July 14,
2016
MF00124
Plymouth
Plating Works
Plymouth, MI
413
lit to://www.Dlv nioiitliDlatine.com/
August 15,
2016
MF00126
KC Jones
Hazel Park,
MI
433
fatto://www.kciola ting.com/
August 15,
2016
MF00127CBI,
MF00189
AJAX Metal
Processing
Detroit, MI
413
fattes://www.aiaxnietal.com/
August 16,
2016
MF00128CBI,
MF00190
Ford Flat Rock
Flat Rock, MI
433
lit! os ://co ido rate.fo rd. co tn/co nroa
nv/Dlant-detail-Daees/flat-rock-
a sse mb ly -d lan t. lit ml
August 16,
2016
MF00129CBI,
MF00191
Elm Plating
Jackson, MI
433
lit to: //www .elmplating.com/
August 17,
2016
MF00130
Trion Coatings,
LLC (vendor)
South Bend,
IN
NA
htto://www. trioncoatings.com/
August 17,
2016
MF00131
Methode
Electronics, Inc.
Rolling
Meadows, IL
433
htto://www. niethode.com/
August 18,
2016
MF00132
Eagle
Electronics
Schaumburg,
IL
433
littD://www.eagle-elec.com/
August 18,
2016
MF00133
Metal Impact
LLC
Elk Grove
Village, IL
433
lit tD://nietali niDact.com/
August 19,
2016
MF00134CBI,
MF00196
Magnetic
Inspection
Laboratory
Elk Grove
Village, IL
433
http://www.milinc.com/
August 19,
2016
MF00135CBI,
MF00195
DCN: Document Control Number; NA: Not Applicable.
" Some facilities have a Confidential Business Information (CBI) version of the site visit report, listed as its own
DCN, separate from the sanitized version of the site visit report.
The remainder of this section provides a general summary of EPA's findings from the
site visits to protect Confidential Business Information (CBI) claims made by facilities.
4-2
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Section 4—Recent Study Findings
As described in the 2015 Status Report, during the promulgation of the Metal Finishing
ELGs, EPA categorized facilities as captive facilities or job shops, as defined in the 1983 Metal
Finishing ELGs and described below (U.S. EPA, 1984):
• Captive facility. A facility that in a calendar year owns more than 50 percent (by
surface area) of the materials undergoing metal finishing. Captive facilities were
categorized as integrated or non-integrated to characterize the wastewater discharges
generated. Integrated facilities are those which, prior to treatment, combine
electroplating waste streams with significant process waste streams not covered by
the Electroplating Category (40 CFR Part 413). Non-integrated facilities are those
which have significant wastewater discharges only from operations addressed by the
Electroplating Category.
• Job shop. A facility that in a calendar year owns less than 50 percent (by surface area)
of the materials undergoing metal finishing. During development of the regulation,
approximately 97 percent of job shops were found to be non-integrated.
Of the 18 facilities visited in the 2016 site visits, nine are integrated, captive facilities and
one facility is a non-integrated captive facility; two facilities are integrated job shops, and the
remaining six facilities are non-integrated job shops. All facilities discharged indirectly to
POTWs.
The site visit facilities ranged in size from less than 10 employees to over 10,000
employees, with most facilities having between 100 and 500 employees. The facilities serve a
broad range of markets, including:
• Aircraft/aerospace
• Automotive
• Medical devices
• Military
• Electronics (including semiconductors)
• Jewelry and miscellaneous awards (medals, trophies, etc.)
• General, non-specific
EPA observed several facilities that operated multiple surface cleaning and preparation
steps (such as etching, pickling, bright dipping, media blasting, and passivation), plating, hot and
cold rinsing, and post-treatment steps (such as coloring, heat treatment, and parts finishing).
Additionally, EPA observed that most of the metal finishing facilities listed in Table 4-1 perform
single or multi-layer plating processes using a barrel or rack line.6 Some facilities automated
their operations to perform a series of steps based on desired product specifications, while others
manually operated their plating lines for more versatility. EPA observed other common surface
finishing operations during the site visits, including aluminum anodizing, chromating,
6 On a barrel line, facilities place parts inside a slowly-rotating barrel immersed in a plating solution, causing the
parts to tumble and coating them uniformly. On a rack line, facilities place parts on stationary metal racks that are
then immersed in a plating solution, thus protecting delicate parts from damage.
4-3
-------
Section 4—Recent Study Findings
phosphating, and powder coating. A few facilities performed more specialized operations, such
as ion vapor deposition, high velocity oxygenated fuel (HVOF) spray coating, or zirconization.
The facilities used a range of different base materials, including brass, copper, aluminum,
stainless steel, carbon steel, and Inconel. They also plated a variety of metals, including:
From the site visits, EPA confirmed that most metal finishing facilities performed pre-
treatment of segregated waste streams before combining the pretreated wastewaters for primary
wastewater treatment. These pre-treatment steps typically include cyanide destruction and
hexavalent chromium reduction. Facilities also generally have similar wastewater treatment steps
such as equalization, neutralization, metals precipitation, flocculation, clarification, and sludge
thickening. Facilities sent the solids from the sludge thickening and filter press offsite for
disposal as hazardous waste. A few metal finishing facilities also employ ion exchange or
microfiltration to treat rinsewater for reuse.
Facility-specific site visit reports (CBI and sanitized versions) with further details on
facility processes and wastewater treatment can be found in EPA's docket for the study (EPA-
HQ-OW-2015-0665).
4.2 DMR/TRI Data Analysis
Section 3.2 provides the methodology for this DMR/TRI analysis, including an
explanation of EPA's comparisons of observed pollutant concentrations to the analytical baseline
value (baseline values established in the Development Document for the Effluent Limitations
Guidelines and Standards for the Centralized Waste Treatment (CWT) Industry (U.S. EPA,
2000a), 1983 Metal Finishing ELGs and long-term average concentrations (MF ELG LTA), and
2001 MP&M ELGs lowest pollutant LTA (MP&M LTA). This section presents the results and
conclusions of these analyses.
4.2.1 Industries under the Metal Finishing Category Contributing Top Pollutant Discharges
EPA analyzed 2014 pollutant discharge data reported to TRI and on DMRs for facilities
within SIC/NAICS codes that it had previously determined fall within the Metal Finishing
Category (listed in Appendix A). EPA calculated an aggregated toxic weighted pound
equivalents (TWPE) for each facility based on the reported pollutant discharges and previously
established toxic weighting factors (TWFs) (U.S. EPA, 2016b). EPA summed the TWPE across
facilities in each SIC/NAICS code to identify the top industries by SIC/NAICS code contributing
toxic pollutant discharges within the Metal Finishing Category. Table 4-2 lists the top five
industries by SIC code and corresponding NAICS code. These five SIC codes represent 67
percent of the total direct discharge load by TWPE in the 2014 DMR data. The seven
• Bronze
• Cadmium
• Chromium
• Copper
• Gold
• Nickel
• Rhodium
• Silver
• Tin
• Titanium
• Zinc
• Zinc-nickel
in 2014
4-4
-------
Section 4—Recent Study Findings
corresponding NAICS codes represent 81 percent of the total direct discharge load and 27
percent of the total indirect discharge load by TWPE in 2014 TRI data (ERG, 2016c).
EPA then contacted facilities that discharged the largest percentage of TWPE within the
SIC/NAICS codes to confirm that the facilities conduct metal finishing operations and discharge
metal finishing wastewater. From the facility contacts, EPA determined that four of the five SIC
codes have facilities that generate metal finishing wastewater; therefore, EPA reviewed these
industries further. EPA did not further review of the fifth SIC Code, Carbon and Graphite
Manufacturing facilities (SIC: 3624 - Carbon and Graphite Products; NAICS: 335991 - Carbon
and Graphite Product Manufacturing), because the top pollutant dischargers within this industry
(comprising 99 percent of total industry-specific TWPE for 2014 DMR data and 72 percent of
total industry-specific TWPE for 2014 TRI data) do not perform metal finishing operations as
defined in the 1983 regulations.
Table 4-2. Top Metal Finishing Dischargers by SIC and NAICS Codes Identified from
2014 DMR and TRI Data
SIC Cock-
SIC Cock-
Description
NAICS Cock-
NAICS Cock-
Ik-scriplion
I'l-iTorm Mi-i;il l inishinii
()|H-r;ilions lluil Ci-ni-r;ili-
Mel.il l inishinii \\ ;isk'\\
3471
EleuU'uplallllg,
Plating, Polishing,
Anodizing, and
Coloring
332813
Eleuliuplallllg,
Plating, Polishing,
Anodizing, and
Coloring
Yes
3714
Motor Vehicle
Parts and
Accessories
336350
Motor Vehicle
Transmission and
Power Train Parts
Manufacturing
Yes
336340
Motor Vehicle Brake
System
Manufacturing
336330
Motor Vehicle
Steering and
Suspension
Components (except
Spring)
Manufacturing
3731
Ship Building and
Repairing
336611
Ship Building and
Repairing
Yes
3624
Carbon and
Graphite Products
335991
Carbon and Graphite
Product
Manufacturing
No
3479
Coating,
Engraving, and
Allied Services,
Not Elsewhere
Classified
332812
Metal Coating,
Engraving (except
Jewelry and
Silverware), and
Allied Services to
Manufacturers
Yes
4-5
-------
Section 4—Recent Study Findings
4.2.2 Pollutant Analyses
For the SIC and NAICS codes listed in Table 4-2 that perform metal finishing operations
that generate metal finishing wastewater, EPA evaluated 2010 through 2014 DMR and TRI
pollutant discharge data to identify the top pollutants discharged, in terms of aggregate 2010
through 2014 TWPE. EPA further analyzed reported concentrations of the top pollutants across
the DMR and TRI data sets, depending on whether the Metal Finishing ELGs have established
limitations for the pollutants. As described in Section 3.2, EPA downloaded DMR concentration
data for the top pollutants from the Water Pollutant Loading Tool. Because facilities do not
report concentration or flow data to TRI, EPA contacted a small subset of facilities reporting
releases of the pollutants to TRI to obtain underlying concentration data as described in Section
3.4 of the Metal Finishing Preliminary Study: Summary of Phase I and Phase II Review of DMR
and TRI Data (ERG, 2017a).
4.2.2.1 Top DMR Pollutants
Table 4-3 presents the pollutants contributing greater than 95 percent of the cumulative
DMR TWPE for the targeted SIC codes for reporting years 2010 through 2014 (ERG, 2018). The
table also indicates whether the pollutants are regulated under the Metal Finishing ELGs.
EPA also ranked the DMR pollutants discharged by facilities in the targeted SIC codes by
pounds for reporting years 2010 through 2014. EPA found that over 80 percent of the cumulative
pounds discharged are attributed to conventional pollutants including total suspended solids
(TSS), total dissolved solids (TDS), chemical oxygen demand (COD), and biochemical oxygen
demand (BOD); therefore, EPA continued to focus its analyses on pollutants listed in Table 4-3
that contribute a majority of the toxic discharges.
Table 4-3. Top Pollutants by TWPE Based on Reported DMR Data, 2010 - 2014
Polliilanl
Tolal DMKIWPI lor
All l"i\o Years (lh/c«|)
Percent of lolal DMR
I WI'i: lor All li\c Years
Regulated
Pollutant?
Silver
732,000
66.9%
Yes
Lead
127,000
11.6%
Yes
Nickel
87,500
8.0%
Yes
Copper
39,700
3.6%
Yes
Total Residual Chlorine
25,500
2.3%
No
Chromium
24,000
2.2%
Yes
Mercury
18,400
1.7%
No
All Other Pollutants
40,200
3.7%
-
Total Across All Pollutants
1,090,000
100%
-
Source: (ERG, 2018)
4.2.2.2 Top TRI Pollutants
Table 4-4 presents the pollutants contributing greater than 95 percent of the cumulative
TRI TWPE for the targeted NAICS codes for reporting years 2010 through 2014 (ERG, 2018).
The table also indicates whether the pollutants are regulated under the Metal Finishing ELGs.
Several of the pollutants are also top pollutants from the DMR analysis shown above.
4-6
-------
Section 4—Recent Study Findings
Table 4-4. Top Pollutants by TWPE Based on Reported TRI Data, 2010 - 2014
Polliilanl
Tolal TRI I WI'l. lor All
Years (ll)/o(|)
IVrcenl oi l Rl TWIM. lor
all l"i\o \ cars'1
Ki'UiilaU'ri
Pollii lant ?
Copper
16,100
32.9%
Yes
Lead
9,350
19.1%
Yes
Zinc
5,280
10.8%
Yes
Nitrate
5,190
10.6%
No
Nickel
4,580
9.4%
Yes
Manganese
4,140
8.5%
No
Cadmium
2,370
4.8%
Yes
All Other Pollutants
1,880
3.8%

Total Across All Pollutants
48,900
100%
-
Source: (ERG, 2018)
From the collective analysis of the top pollutants reported to DMR and TRI for 2010-
2014, EPA identified for further review the following list of pollutants that contribute greater
than 95 percent of the toxic discharges within the targeted SIC/NAICS codes. For each of the
pollutants listed below, EPA downloaded from the Water Pollutant Loading Tool all available
outfall and monitoring period concentration data reported on DMRs for facilities within the four
targeted SIC codes. EPA obtained underlying concentration data from a subset of facilities in the
targeted NACIS codes that reported the pollutants to TRI (see Section 3.4 of (ERG, 2017a) for
information on EPA's methodology for obtaining pollutant concentration data). As described in
Section 4.2.4 and 4.2.3 below, EPA performed comparisons of concentrations of the pollutants to
various benchmarks to further understand the potential significance and treatability of their
discharge.
Top Regulated Pollutants
• Cadmium
• Chromium
• Copper
• Lead
• Nickel
• Silver
• Zinc
Top Unregulated Pollutants
• Manganese
• Mercury
• Nitrate
• Total Residual Chlorine
4.2.3 Unregulated Pollutant Analysis
When looking at a pollutant's concentration in wastewater, EPA often compares that
concentration to a threshold of five or ten times the analytical baseline value to gauge its
treatability. For this analysis, EPA considered DMR and underlying TRI concentrations detected
above five times the baseline value as treatable. Table 4-5 presents the range and median
concentrations for each pollutant across the targeted SIC/NAICS codes as well as the pollutants'
respective baseline values (ERG, 2018). As shown, the median concentrations for mercury and
total residual chlorine are below five times the baseline value, suggesting that these pollutants
4-7
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Section 4—Recent Study Findings
are not generally present in the wastewater at treatable levels. However, EPA notes that the data
for unregulated pollutants is limited because many facilities do not have permit limits or
monitoring requirements for these pollutants. Although the median concentration for nitrate is
above five times the baseline value, the data represent only five facilities and may not be an
indication of nitrate discharges across the metal finishing industry. Similarly, the median
concentration for manganese from the TRI data set is above five times the baseline value,
however, the TRI data represent only one facility.
Table 4-5. Summary of DMR and TRI Concentration Data for Unregulated Pollutants
Compared to Baseline Values
M ol ric
Manganese1'
Mi'rain
Nil rale1'
l olal Residual Chlorine1
DMR Data
Minimum Concentration (mg/L)
0.005
1 x 1011
0.305
0.000018
Median Concentration (mg/L)
0.005
6.0 x 10"6
23.43
0.05
Maximum Concentration (mg/L)
0.005
0.0008
386
8.3
Number of Data Points
60
471
138
908
TRI Data
Minimum Concentration (mg/L)
0.005
-
-
-
Median Concentration (mg/L)
0.24
-
-
-
Maximum Concentration (mg/L)
1
-
-
-
Number of Data Points
29
0
0
0
Analytical Baseline Value
(mg/L)
0.015
0.0002
0.05
1
5x Analytical Baseline Value
(mg/L)
0.075
0.001
0.25
5
Source: (ERG, 2018)
a All DMR manganese concentrations are from one facility and all concentrations are equal.
b DMR nitrate concentrations are from 5 facilities, all in the Electroplating, Plating, Polishing, Anodizing, and
Coloring SIC Code (SIC 3471).
0 EPA used the analytical baseline value for chloride to compare to the total residual chlorine concentrations.
4.2.4 Regulated Pollutant Analysis
For the regulated pollutants, EPA compared the concentration data to the Metal Finishing
(MF) limitations as well as the MF LTAs and the MP&M LTAs. As shown in Table 4-6, the
median of the concentrations for each of the regulated pollutants are an order of magnitude or
more lower than the comparable limitations and LTAs relevant to the metal finishing industry,
including the LTAs identified for metal finishing processes during the development of the
MP&M ELGs (ERG, 2018). As described further in Section 4.4, EPA ultimately decided not to
promulgate limitations and standards for any metal-bearing wastewater discharges under the
final MP&M rule. 7
7 As described in Section 4.4, during development of the MP&M rulemaking EPA evaluated additional controls for
five metal-bearing wastewater subcategories, four of which included metal finishing facilities.
4-8
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Section 4—Recent Study Findings
Table 4-6. Summary of DMR and TRI Concentration Data for Regulated Pollutants
Compared to Metal Finishing ELGs and Relevant LTAs
\le( ric
Cadmium
Chromium
Copper
lead
Niekel
Sil\er
Zine
DMR Diilii
Minimum Concentration
(mg/L)
0.000002
0.0002
0.000001
0.00007
0.00004
0.00001
0.00003
Median Concentration
(mg/L)
0.001
0.01
0.0245
0.0079
0.06
0.004
0.0869
Maximum Concentration
(mg/L)
0.065
1.00
100.5
1.00
37.2
12.5
95.1
Number of Data Points
702
1,032
2,889
944
1,371
757
2,746
TRI Data
Minimum Concentration
(mg/L)
0.00005
0.0025
0.0025
0.0002
0.0025
0.001
0
Median Concentration
(mg/L)
0.0005
0.025
0.005
0.025
0.005
0.001
0.129
Maximum Concentration
(mg/L)
0.004
0.025
0.687
0.085
0.014
0.002
3.73
Number of Data Points
21
50
332
50
50
21
285
ELG Monthly Average
(mg/L)
0.26a
1.71
2.07
0.43
2.38
0.24
1.48
ELG Daily Maximum
(mg/L)
0.69a
2.77
3.38
0.69
3.98
0.43
2.61
MF LTA (mg/L)
0.13
0.572
0.815
0.2
0.942
0.096
0.549
MP&M LTA (mg/L)
0.05
0.1
0.17
0.02
0.08
0.04
0.11
Source: (ERG, 2018)
" ELG monthly average and daily maximum values shown for cadmium are for BPT. NSPS/PSES limitations are
0.07 mg/L monthly average and 0.11 mg/L daily maximum.
4.2.5 Summary of Results and Conclusions
For the DMR/TRI data analysis, EPA identified and focused its evaluation on discharges
from a subset of the metal finishing industry that falls within four SIC and six corresponding
NAICS codes. These top industry sectors, which EPA confirmed perform metal finishing
operations and discharge wastewater, contribute a majority of the toxic pollutant discharges
within the Metal Finishing Category, based on 2014 DMR and TRI data.
Across the top industry sectors, EPA identified four unregulated and seven regulated
pollutants that collectively account for greater than 95 percent of the TWPE. For these top 11
toxic pollutants EPA obtained and evaluated reported facility outfall and monitoring period
concentration data to understand the significance and potential treatability of their discharge. For
the four unregulated pollutants, EPA compared the range and median of the concentrations to the
respective baseline values and found that only the median nitrate concentration exceeded five
times the baseline value, suggesting that most of the unregulated pollutants may not generally be
present in the wastewater at treatable levels. However, EPA notes that the available data for
unregulated pollutants are limited. Specific to nitrate and manganese, though the data suggest the
concentrations may be present at treatable levels, the data represent only a few facilities and may
not represent discharges across the metal finishing industry. For the seven regulated pollutants,
EPA compared the median of the concentrations to the Metal Finishing ELGs as well as the MF
4-9
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Section 4—Recent Study Findings
LTA and the MP&M LTA concentrations and found that the concentrations for each of the
regulated pollutants are an order of magnitude or more lower than the comparable limitations and
LTAs, suggesting that the discharges of these pollutants are adequately controlled. As described
further in Section 4.4, EPA ultimately decided not to promulgate limitations and standards for
any metal-bearing wastewater discharges under the final MP&M rule due to technological or
economic achievability concerns and changes to datasets and methodologies in response to
public comments.
4.3 Pollution Prevention (P2) Review
EPA identified P2 practices and their prevalence at metal finishing facilities through the
review of the following data sources (detailed in Section 3.3):
• TRIP2 data8
• Literature review9
• MP&M Comment Response Document (CRD)10
• Economy - Energy - Environment (E3) Success Stories13
• Regional P2 contacts11
This section summarizes the P2 practices for metal finishing facilities, including process
technology controls and alternatives, alternative process chemistries, wastewater recycling and
materials recovery, and other resources available to metal finishers. Refer to Appendix B for a
full listing of P2 practices found during EPA's review.
4.3.1 Process Technology Controls and Alternatives
EPA identified metal finishing facilities implementing process controls or altering
existing process operations to minimize waste generation, including:
• Water conservation practices. Facilities frequently reported using alternative rinsing
and control practices to conserve in-process water. Metal finishing facilities reported
using countercurrent rinsing, an alternative rinse-tank configuration in which
rinsewater flows opposite the direction of finished parts, with the cleanest rinsewater
used as the final rinse. Facilities also reported using spray rinses in place of dip rinses
to reduce the volume of water used per rinse. In addition, EPA identified conductivity
and flow controls used to conserve rinsewater at metal finishing facilities mentioned
in P2 data sources.
8 For full results from the TRI P2 data review, see memorandum Toxic Release Inventory (TRI) Pollution Prevention
(P2) Data Summary (ERG, 2017g).
9 For full results from the literature review, see memorandum Results of the Pollution Prevention Targeted
Literature Review for the Metal Finishing Industry (ERG, 2017f).
10 For Ml results from the MP&M CRD review, see memorandum Results of the Targeted Review of the MP&M
Comment Response Document: Pollution Prevention and Wastewater Treatment Practices (ERG, 2017h).
11 For Ml results from the E3 success stories review and regional P2 contacts review, see the memorandum Results
of the Pollution Prevention Data Collection using E3 Sources and Regional Contacts in the Metal Finishing
Industry (ERG, 2017d).
4-10
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Section 4—Recent Study Findings
• Process changes. EPA identified practices that involve altering existing metal
finishing process operations to reduce waste generation, including installing in-tank
filtration of process fluids, installing air emissions controls, and optimizing process
tank volumes. Although less frequently reported than water conservation practices
EPA identified greener alternative operations that can replace existing processes, such
as replacing liquid coatings with powder coatings, and implementing more advanced
plating technologies, such as HVOF12 spray application for chromium plating.
• Recycle scrap materials. Metal finishing facilities reported recycling materials, such
as defective parts and solder, to reduce facility waste generation.
• Methods to reduce dragout.13 EPA identified methods to reduce the amount of
dragout transferred from process tanks to rinse tanks. These include methods that
remove dragout from parts, such as sponge rollers or air knives that use a sponge or
air, respectively, to force dragout off the part, or techniques to capture dragout so it
may be directed back into process tanks.
• Methods to increase throughput efficiency. Metal finishing facilities also reduce
pollution generation and discharge by increasing efficiency in their manufacturing
processes. Reported examples include modifying process schedules and tank layouts.
Increasing throughput efficiency may also add the benefit of cost savings.
4.3.2 Alternative Process Chemistries
EPA found that some facilities have modified process chemistries for their metal
finishing operations and have considered chemical alternatives that are more environmentally
friendly for solvents/cleaners, plating solutions, and anodes. Facilities reported replacing
chemical solvents with water-based coatings or cleaners, converting to lead-free electroplating
anodes, replacing processes that produce cyanide-bearing wastewater, and adopting low-volatile
organic compound (VOC) coating chemical alternatives. Facilities are also currently
investigating replacements for cadmium and hexavalent chromium plating baths that are less
toxic but can achieve equivalent plating specifications. EPA identified alternative process
chemistries as an active area of P2 innovation through review of TRIP2, literature review, and
regional P2 data (see Appendix B).
4.3.3 Wastewater Recycling, Materials Recovery, and Treatment Alternatives
Metal finishing facilities can reduce wastewater discharge and reduce water costs by
implementing practices such as segregating metal finishing wastewater for reuse, metals
recovery, and near zero liquid discharge treatment systems, as described below.
• Segregation of wastewater for recycle/reuse. Metal finishing facilities reported
segregating wastewater during collection and treatment for recycle and reuse. For
12 HVOF is a type of thermal spray coating that can replace hard chrome plating for certain parts. Refer to the
Preliminary Study of the Metal Finishing Category: 2015 Status Report for additional information on this
technology (U.S. EPA, 2016a).
13 Dragout is the water carried out of the plating bath with a part and into succeeding tanks.
4-11
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Section 4—Recent Study Findings
example, metal finishing facilities reported the capture and segregated treatment of
chromium-bearing wastewater for reuse in chromium electroplating baths.
• Recycle/reuse spent cleaners and solvent. Facilities reported recycling cleaners and
solvents, such as ethylene glycol, hydraulic oil, and coolants, with recovery systems
prior to reuse. The treatment technology used is dependent on the type of the solution;
however, EPA identified filtration systems as a common treatment method for solvent
recycling at metal finishing facilities.
• Recover materials from wastewater. EPA identified the recovery of metals from spent
plating baths and metal finishing process solutions using advanced technologies, such
as electrowinning, and the recovery of metals from metal finishing sludge as potential
metal finishing P2 practices. Gold and silver are candidates for recovery via
electrodialysis (McLay, 2001).
• Regenerate spent plating baths. P2 data sources identify the regeneration of spent
plating baths using advanced treatments such as electrowinning, crystallization,
evaporation, and/or microfiltration for metal finishers (see Appendix B). However,
bath regeneration is not frequently used because chemical suppliers and customers
require strict specifications for bath plating formulas.
• Use alternative wastewater treatment chemicals. Facilities reported using alternative
chemicals (e.g., ferrous sulfate, caustic soda) to reduce the volume of sludge
generated during metal finishing wastewater treatment by chemical precipitation.
• Additional wastewater treatment beyond the metal finishing BAT. Metal finishing
facilities reported implementing wastewater treatment technologies more advanced
than the Metal Finishing BAT to treat metal finishing process wastewater. These
technologies include ion exchange, ultrafiltration, dissolved air flotation, reverse
osmosis, evaporation/distillation, and electrowinning. EPA also identified zero
discharge or near-zero liquid treatment technologies for metal finishers in the
literature (see Appendix B).
4.3.4 P2 Initiatives and Resources for the Metal Finishing Industry
EPA reviewed the regional P2 and E3 data sources described in Section 3.3, as well as
additional state, regional, and federal websites, to identify active P2 initiatives and P2 resources,
such as guidance documents, available to the metal finishing industry. From this review, EPA
identified the Pollution Prevention Resource Exchange (P2Rx), a national partnership of eight
regional pollution prevention information centers funded in part through grants from EPA, and
searched programs within P2Rx for more information about regional activities. Table 4-7
provides the name, a summary of the program, a reference for each regional program and the
respective EPA region it targets. The P2Rx website does not offer guidance materials specific to
metal finishing, but general P2 information, as well as links to regional resources.
EPA also identified the National Metal Finishers Strategic Goals Program (SGP) as an
inactive metal finishing P2 program. SGP, which stemmed from EPA's Common Sense
Initiative, was a voluntary, performance-based program that committed industry participants to
reducing discharges from process operations beyond that required by law. SGP committed other
4-12
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Section 4—Recent Study Findings
stakeholders to aiding industry in meeting their environmental goals.14 The program ended in
2002.
EPA performed a cursory review of state websites and determined that many individual
state governments or a collaboration of state governments maintain P2 programs that offer some
level of technical assistance to manufacturers, including metal finishers, to voluntarily
implement P2 practices. This assistance may include technology fact sheets, P2 manuals, links to
available EPA P2 funding sources, workshops, or non-regulatory walk-through audits. EPA also
determined that some states offer minimal or no technical assistance for P2 implementation.
Additionally, metal finishers can take advantage of E3 programs and services to reduce
energy usage, decrease carbon footprint, prevent pollution, and increase efficiency and cost
savings at their facilities.15 Metal finishers may use several E3 programs and resources to
support customized technical assessments designed to identify practical, sustainable procedures
that can be integrated throughout a facility or group of facilities. For more information about E3
and regional P2 support see Results of the Pollution Prevention Data Collection using E3
Sources and Regional Contacts in the Metal Finishing Industry (ERG, 2017d).
14 The Metal Finishing Strategic Goals Program and P2 alternative were detailed in the MP&M 2001 Proposed Rule
(EP A-HQ-0 W -2002-0033-0001).
15 Refer to Section 3.3 for an overview of E3.
4-13
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Section 4—Recent Study Findings
Table 4-7. Major Regional P2 Technical Assistance Websites
Vimc
r.PA
Rciiionls)
Son od In
I'ro^riiin
Suiiimiin
KiTciyiiit
Northeast States
Pollution Prevention
Roundtable/
P2 Information Center
1,2
Sen es Male and local cm ii'oiimciilal assislaiicc programs In maiiaging a regional
roundtable of state and local environmental programs, managing a resource
center for information, conducting training sessions for state officials, researching
innovative and source reduction strategies and techniques, coordinating joint
policy, and supporting program development. Includes resources associated with
the National Metal Finishers Strategic Goals Program.3 This site links to P2Rx
resources and the New York State Dept. of Environmental Conservation P2 Unit
outreach program for the metal finishing industry.
(\i:\v\i<)\, :un;
Environmental
Sustainability Resource
Center (ESRC)
3,4
Provides comprehensive online resources, news, and information about pollution
prevention to state environmental agencies, businesses, technical assistance
providers, and the public. Does not include guidance P2 documents or programs
specific to the metal finishing industry. This site links to P2Rx site and EPA E3
program information.
(ESRC, 2017)
Great Lakes Regional
Pollution Prevention
Roundtable (GLRPPR)
2, 3, 5
Promotes information exchange and networking to P2 professionals in the Great
Lakes region. Includes resources for many industry sectors, including metal
finishing, and provides various technical guidance documents. This site links to
resources on Ohio, Illinois, Massachusetts, and Washington state websites,
federal websites, and vendor websites. Resource network serves Illinois, Indiana,
Michigan, Minnesota, New York, Ohio, Pennsylvania, Wisconsin, and Ontario.
(GLRPPR, 2017)
Zero Waste Network
6
Provides tools and resources to help industry identify money-saving options to
reduce pollution. P2 resources include workshops and guidance for general P2
planning. Also included are common alternatives or P2 practices for process
operations, including those often performed at metal finishing facilities (e.g., acid
pickle, dragout rinsing).
(ZWN, 2017)
Pollution Prevention
Regional Information
Center (P2RIC)
7
Enhances resource sharing among programs, businesses, and agencies that
provide waste reduction services and expertise to business and industry in the
region. Does not provide current P2 resources specific to metal finishing. Site
links to Iowa, Kansas, Missouri, and Nebraska state P2 programs. This site also
links to P2Rx resources.
(P2RIC, 2017)
4-14
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Section 4—Recent Study Findings
Table 4-7. Major Regional P2 Technical Assistance Websites
Vimc
r.PA
Rciiionls)
Son od In
Pmiinuii
Siimniiin
Reference'
Peak to Prairies
Pollution Prevention
Information Center
8
1 iucouiages adoption of l'2 practices In businesses and works w illi technical
assistance providers to promote P2 and environmental management. Offers
access to current P2 information and contacts, encourages collaboration and
leveraging of resources between states and programs, and distributes P2
information through websites and presentations. This site links to P2 programs in
Colorado, Montana, North Dakota, South Dakota, Utah, and Wyoming and P2Rx
resources. Website does not provide P2 technical guidance specific to metal
finishers.
O'eak lo h'airies, 2
-------
Section 4—Recent Study Findings
4.4 Metal Products and Machinery (MP&M) Rulemaking
EPA conducted a review of materials generated during the development of the 2003
MP&M ELGs (40 CFR Part 438) to identify information relevant to facilities covered under the
Metal Finishing Category, as described in Section 3.4. Although EPA decided not to promulgate
limits or standards for any metal-bearing wastewater discharges under MP&M for the final rule,
including discharges from metal finishing processes, the MP&M Rulemaking documentation
contains useful information and data relevant to the Metal Finishing Category. This section
summarizes the findings of detailed MP&M documentation reviews and includes:
• Descriptions of MP&M subcategories containing metal finishing facilities.
• Pollutants of concern.
• P2 and wastewater treatment technologies identified between the development of the
1983 Metal Finishing ELGs and the 2001 MP&M proposed ELGs.
• Technology bases considered for the MP&M ELGs.
• Key MP&M findings regarding the metal finishing industry.
4.4.1 Subcategories Containing Metal Finishers
In 2001, EPA published the MP&M proposed ELGs which would have established more
stringent limitations and standards for the MP&M industry (facilities that manufacture, rebuild,
or maintain finished metal products, parts, or machines that fall within sixteen identified
industrial sectors), which included facilities covered by the Metal Finishing ELGs. The 2001
proposed ELGs divided MP&M facilities into eight subcategories grouped by manufacturing,
maintenance, or rebuilding operations, as follows:
• Metal-bearing wastewater subcategories:
— General Metals
— Metal Finishing Job Shops
— Printed Wiring Board
— Non-Chromium Anodizing
— Steel Forming and Finishing
• Oil-bearing wastewater subcategories:
— Oily Wastes
— Railroad Line Maintenance
— Shipbuilding Dry Docks
Ultimately, EPA decided not to promulgate ELGs for seven of the eight subcategories.
This was largely due to technological or economic achievability concerns and changes to
datasets and methodologies in response to public comments. The remaining subcategory, Oily
Wastes, did not include any metal finishers; therefore, no metal finishing facilities were subject
to the final MP&M ELGs (U.S. EPA, 2003b).
Of the five proposed metal-bearing wastewater subcategories, four included metal
finishing facilities. The four proposed MP&M subcategories that contain metal finishing
4-16
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Section 4—Recent Study Findings
facilities (Metal Finishing Job Shops, Printed Wiring Board, Non-Chromium Anodizing, and
General Metal) and the additional proposed metal-bearing wastewater subcategory (Steel
Forming and Finishing) are further described below (U.S. EPA, 2000b).
• Metal Finishing Job Shops. Facilities in the proposed Metal Finishing Job Shops
Subcategory perform at least one of the six core metal finishing operations
(electroplating; electroless plating; anodizing; coating, including chromating,
phosphating, passivation, and coloring; chemical etching and milling; and printed
circuit board manufacturing) and own not more than 50 percent (on an annual basis)
of the materials undergoing metal finishing. All facilities in this subcategory are
regulated under the Metal Finishing ELGs or Electroplating ELGs. EPA estimated
that the proposed Metal Finishing Job Shops Subcategory consisted of approximately
1,500 indirect dischargers and 15 direct dischargers.
• Printed Wiring Board. Facilities in this proposed subcategory discharge wastewater
from the manufacture or repair of printed wiring boards (i.e., circuit boards). All
facilities in the Printed Wiring Board Subcategory are regulated under the Metal
Finishing or Electroplating ELGs. EPA estimated that approximately 620 indirect
dischargers and 11 direct dischargers were in the Printed Wiring Board Subcategory.
Facilities in this subcategory were unique in that they generally worked with
copper-clad laminate material, allowing them to target copper for removal in their
wastewater treatment systems or recover the copper using in-process ion
exchange. Printed Wiring Board facilities apply, develop, and strip photo resist, a
set of unit operations that is unique to this subcategory and generate higher
concentrations of a more consistent group of organic constituents than other
facilities. The nature of the wastewater generated by these facilities may also be
different because these facilities perform more lead-bearing operations (e.g.,
lead/tin electroplating wave soldering) than other MP&M facilities (U.S. EPA,
2000b).
• Non-Chromium Anodizing. Facilities in this proposed subcategory perform aluminum
anodizing without using chromic acid or dichromate sealants. EPA estimated that this
subcategory consisted of approximately 190 indirect dischargers and did not identify
any direct dischargers that would fall under this subcategory. The Development
Document for the Proposed Effluent Limitations Guidelines and Standards for the
Metal Products & Machinery Point Source Category (proposed MP&M TDD) (U.S.
EPA, 2000b) did not include an estimate of the number of facilities in this
subcategory that were regulated by the Metal Finishing ELGs; however, since the
Metal Finishing ELGs include facilities that anodize and does not include an
exclusion for non-chromium anodizers, all facilities in this subcategory were likely
regulated by the Metal Finishing ELGs.
• Steel Forming and Finishing. Facilities in the proposed Steel Forming and Finishing
Subcategory perform MP&M operations on steel. All facilities in this subcategory
had permits or other control mechanisms under the Iron and Steel Manufacturing
ELGs (40 CFR Part 420). Therefore, none of these facilities were subject to Metal
Finishing ELGs.
4-17
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Section 4—Recent Study Findings
• General Metals. EPA referred to this proposed subcategory as a "catch-all" for
remaining facilities that discharge metal-bearing wastewater and do not fall within the
other four metal-bearing wastewater subcategories described above. EPA estimated
about 26,000 indirect and 3,800 direct dischargers were in this subcategory at the
time of the proposed MP&M rulemaking. EPA also estimated that 16 percent of the
facilities in this subcategory were covered under the Metal Finishing ELGs at the
time of the proposed MP&M rulemaking.
4.4.2 Pollutants of Concern
During development of the 2001 proposed MP&M ELGs development, EPA considered
limitations for all 64 pollutants listed in Table 4-8 for the metal-bearing wastewater
subcategories. EPA proposed limitations for all 64 pollutants for the Metal Finishing Job Shops
and General Metals Subcategories and a subset of these pollutants for the Printed Wiring Board
Subcategory (all except cadmium, molybdenum, and silver).16 For the Non-Chromium
Anodizing Subcategory, EPA proposed limits only for total suspended solids (TSS), oil and
grease, aluminum, manganese, zinc, and nickel. The proposed MP&M ELGs for subcategories
that included metal finishers expanded on the list of pollutants regulated by the Metal Finishing
ELGs by including limitations and standards for additional organics,17 metals (aluminum,
molybdenum, zinc), and nonconventional pollutants (sulfide, amendable cyanide) (U.S. EPA,
2000b).
Table 4-8. Pollutants Considered for the Proposed MP&M Regulation for Metal-
Bearing Subcategories
Prioriit Moliils
Cadmium
Cyanide
Silver
Chromium
Lead
Zinc
Copper
Nickel

NoiK'on\i'iilioii;il Melsils
Manganese
Molybdenum
Tin
( nn\cn(ion;il Ptilliil;uils
()il and (u'casc (as 1IIA1)
1 olal Suspended Solids < 1 SS)

Oilier Noncon\cnlion;il Polliiliinls
Amenable Cyanide
Total Organic Carbon
Total Sulfide
16 Not all the wastewater generated by these subcategories is generated by metal finishing facilities. EPA
determines pollutants of concern based on the characteristics of the wastewater for the overall subcategory, not only
the metal finishing wastewater component. Refer to the memorandum Meted Products and Machinery (MP&M)
Rulemaking Preamble: Summary of Industry Comments and EPA Decisions Related to the Metal Finishing
Category for a list of MP&M process operations that generate wastewater considered for regulation (ERG, 2017b).
17 The proposed MP&M ELGs included limitations for a Total Organics Parameter (TOP). EPA determined the
value of this limitation based on the contribution of the organic pollutants listed in Table 4-8 (U.S. EPA, 2000b).
The Metal Finishing ELGs include a limitation for TTO, but do not regulate the discharge of TOP or any of the
specific organic pollutants listed in Table 4-8 (U.S. EPA, 1983).
4-18
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Section 4—Recent Study Findings
Table 4-8. Pollutants Considered for the Proposed MP&M Regulation for Metal-
Bearing Subcategories
Priority Oriiiinic Polliiliinls
1,1,1 -Tncliloroelliaiie
Cliloiolviizene
Mollis lene Chloride
1,1 -Dichloroethane
Chloroethane
n-Nitrosodimethylamine
1,1 -Dichloroethy lene
Chloroform
n-Nitrosodiphenylamine
2,4-Dimethylphenol
1 -Methy lfluorene
Naphthalene
2,4-Dinitrophenol
1 -Methy lphenanthrene
Phenanthrene
2,6-Dinitrotoluene
2-Isopropylnaphthalene
Phenol
2-Nitrophenol
2-Methylnaphthalene
Pyrene
4-Chloro-m-cresol
Di-n-Butyl Phthalate
T etrachloroethene
4-Nitrophenol
Di-n-Octyl Phthalate
Toluene
Acenaphthene
Dimethyl Phthalate
Trichloroethylene
Acrolein
Ethylbenzene
Biphenyl
Anthracene
Fluoranthene
Carbon Disulfide
Benzyl Butyl Phthalate
Fluorene
Dibenzofuran
Bis(2-Ethylhexyl) Phthalate
Isophorone
Dibenzothiophene
Noncon\cnlioiiiil Organic Polliiliinls
3,6-Dimethylphenanthrene
Benzoic Acid
n-Tetradecane
Aniline
n-Hexadecane
p-Cymene
Source: (U.S. EPA, 2000b)
As discussed in Section 4.6, during this preliminary study of the Metal Finishing
Category, pretreatment coordinators raised concerns to EPA about two pollutants on the MP&M
pollutant of concern (POC) list that are currently discharged by metal finishing facilities: 1,4-
dioxane and N-nitrosodimethylamine (U.S. EPA, 2000b, 2018d). EPA did not consider 1,4-
dioxane for proposed regulation as part of the MP&M ELGs because it is controlled through the
regulation of Total Organics Parameter (TOP), a total organics control parameter. However, EPA
proposed to regulate N-nitrosodimethylamine under the proposed MP&M ELGs (see Table 4-8).
The Development Document for Effluent Limitations Guidelines New Source Performance
Standards for the Metal Finishing Point Source Category (Metal Finishing TDD) identified N-
nitrosodimethylamine as a known to be present (KTBP) pollutant but did not note the presence
of 1,4-dioxane in metal finishing process wastewater (U.S. EPA, 1983).
4.4.3 P2 Practices and Wastewater Treatment Technologies Identified Between the Metal
Finishing and MP&M Rulemakings
From review of the proposed MP&M TDD (U.S. EPA, 2000b) and the Metal Finishing
TDD (U.S. EPA, 1983), EPA identified wastewater treatment technologies and P2 practices,
including flow reduction practices and in-process P2 technologies, that were described in the
MP&M rulemaking, but were not discussed in the Metal Finishing Rulemaking documentation.
Table 4-9 describes these technologies. Refer to the memorandum Metal Products and
Machinery (MP&M) Rulemaking TDD: Review and Comparison of Wastewater Technologies,
Pollutants of Concern, and Pollution Prevention (P2) Practices Considered in the MP&M and
4-19
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Section 4—Recent Study Findings
Metal Finishing Rulemakings for additional details on these technologies, as described in the
MP&M TDD (ERG, 2017c).
Table 4-9. Practices and Technologies Identified in the 2001 MP&M TDD and Not
Discussed in the 1983 Metal Finishing TDD
TechnoloiiWIViiclice T\ |>o
Tcchnoloi^ Descriptions
Flow Reduction Practices
• Air knives use forced air to remove dragout from part.
• Drip shields capture dragout and direct it back to process tanks.
• Rinse timers reduce unnecessary rinsewater generation by turning off flow of
fresh rinsewater after a set time.
• Bath concentrations can be lowered, when feasible, to lower viscosity and
reduce the volume of rinsewater required to adequately rinse a part.
In-Process P2 Technologies
• Recycle/reuse process solutions by removing impurities by carbon adsorption,
filtration, or reverse osmosis (RO).
• Carbonate "freezing" removes carbonates that build up in some process
chemicals by lowering the operating temperature to 26°F. Crystallized
hydrated salts can then be removed via filtration or decanting.
• Recycle machine coolant following regeneration by a centrifugal separator
and pasteurization.
Wastewater Treatment
• Treatment of chelated wastewater; electrolytic recovery; sodium borohydride,
hydrazine, and sodium hydrosulfide reduction; dithiocarbonate (DTC)
precipitation.
• Sodium borohydride precipitation for metals removal.
4.4.4 Technology Bases and Proposed ELGs
In support of the preliminary study of the Metal Finishing Category, EPA reviewed the
regulatory options considered for the proposed MP&M ELGs and compared the technology
bases and associated limitations with the Metal Finishing ELGs. EPA also reviewed a
compliance alternative considered for indirect dischargers in the proposed Metal Finishing Jobs
Shops Subcategory as part of the MP&M proposed ELGs.
4.4.4.1 Technology Options
EPA considered four technology options for the MP&M metal-bearing wastewater
subcategories, and ultimately selected regulatory Options 2 and 4 as the basis for the proposed
rule, described below.
• Option 1 includes the pretreatment of segregated waste streams followed by chemical
precipitation and gravity clarification for metal hydroxide removal. EPA specified
pretreatment of the following segregated waste streams: oil-bearing wastewater
(emulsion breaking and gravity separation), cyanide-bearing wastewater (alkaline
chlorination), hexavalent chromium-bearing wastewater (reduction), chelated metal-
bearing wastewater (reduction/precipitation), an organic solvent-bearing wastewater
(contract hauling).
• Option 2 built on Option 1 by adding in-process P2. Option 2 P2 methods include
countercurrent cascade rinsing for all flowing rinses, centrifugation and recycling of
4-20
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Section 4—Recent Study Findings
painting water curtains, and centrifugation and pasteurization to extend the life of
water-soluble machining coolants. EPA selected Option 2 as the basis for:
— BPT, Best Conventional Pollutant Control Technology (BCT), BAT, and
PSES for the five metal-bearing wastewater subcategories.
— NSPS for the Non-Chromium Anodizing Subcategory.
• Option 3 replaced gravity clarification for metal hydroxide removal and emulsion
breaking for oil removal in Option 1 with microfiltration for metal hydroxide removal
and ultrafiltration for oil removal. Option 3 did not include the in-process P2 controls
proposed for Option 2.
• Option 4 combined the wastewater treatment technologies of Option 3 with the in-
process flow controls and P2 practices included in Option 2. EPA selected Option 4
as the basis for:
— NSPS for the General Metals, Metal Finishing Job Shops, Printed Wiring
Board, and Steel Forming and Finishing Subcategories; and
— PSNS for the General Metals, Metal Finishing Job Shops, Printed Wiring
Board, and Steel Forming and Finishing Subcategories.
The technology that forms the basis for Metal Finishing BAT, BPT, and PSES is similar
to MP&M technology Option 1 and includes chemical precipitation, clarification, and sludge
dewatering for the treatment of common metals. The Metal Finishing technology basis also
includes the pretreatment of segregated wastes, such as chromium reduction, cyanide oxidation,
complexed metals removal by high pH precipitation, and emulsion breaking for oil and grease
removal. The Metal Finishing NSPS/PSNS technology basis also includes additional cadmium
reduction. None of the technology bases for the Metal Finishing ELGs incorporate in-process
flow control or P2 or advanced filtration (U.S. EPA, 1983).
4.4.4.2 Proposed Limits for Existing Direct Dischargers
Table 4-10 compares the proposed BPT/BAT limits for the MP&M subcategories that
contained metal finishing facilities to the metal finishing limitations under 40 CFR Part 433. In
general, the limitations for TSS and n-hexane extractable material (HEM) are comparable, while
the proposed MP&M limitations for metals and cyanide are lower than those of the Metal
Finishing ELGs.
4-21
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Section 4—Recent Study Findings
Table 4-10. Proposed MP&M BPT/BAT Limits and Promulgated Metal Finishing BPT and BAT Limits

MI'Wl Proposed BPT/BAT l imit
s (inti/h •'

\on-( hromiiim

Mi'liil l inishinii Job
(idler.
il Molals
Printed \\ irin«
Aiiodi/ina
Pai l 433 BPT/BAT

Shops Siihciileiion
Siihciilqion
Board Siihcalciiort
Suhcalcsiort
l imits (inii/l)''

l);iil\
Monlhlt
l);iil\
Monlhlt
Dailt
Moii(hl\
Dailt
Monlhlt
Dailt
Monlhlt
Pollutant
Max.
At a.
Max.
At Si.
Max.
At a.
Max
At».
Max.
At a.
Tolal Suspended Solids (TSS)
60
31
34
18
60
31
60
'1
60
'i
Oil and Grease (as HEM)
52
26
15
12
52
26
52
2(1
52
2(1
Total Organic Carbon (TOC)
78
59
87
50
101
67

Total Organics Parameter (TOP)
9
4 ^
9
4 ^
9
4 ^

Total Toxic Organics (TTO)

2.13
NA
Aluminum

8.2
4

Cadmium
0.21
mi';
0.14
DO';

0.69
0 26
Chromium
1.3
0.55
0.25
0.14
0.25
0.14

2.77
1 "1
Copper
1.3
0.57
0.55
0.28
0.55
() 28

3.38
: o-
Total Cyanide
0.21
0.13
0.21
0.13
0.21
u 1 ^

1.2
o (.5
Amenable Cyanide
0.14
0.07
0.14
0.07
0.14
0.07

0.86
o ^2
Lead
0.12
0.09
0.04
0.03
o 04
O O 1

0.69
o4'
Manganese
0.25
0.1
0.13
0.09
1 ^
(K.4
0.13
oo';

Molybdenum
0.79
0.49
0.79
0.49

Nickel
1.5
0.64
0.5
0.31
0.3
o 14
0.5
o
3.98
: ^8
Silver
0.15
0.06
0.22
0.09

0.43
o 24
Sulfide, Total
31
13
^1
1^
31
n

Tin
1.8
1.4
1 4
<)(.-
0.3 1
o 14

Zinc
0.35
0.17
0.38
u::
0.38
o::
0.38
o::
2.61
1.48
PH

6.0 - 9.0
<1.0 K) 0
Source: (U.S. EPA, 1983, 2000b)
a Gray shaded cells with numeric values indicate that a BPT-only limitation applies (i.e., no BAT limitation). Gray shaded cells without numeric values indicate
no BAT or BPT limitation applies. All other cells indicate applicable BAT/BPT limitations.
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Section 4—Recent Study Findings
4.4.4.3 Proposed P2 Alternative for Metal Finishing Job Shops Subcategory
As part of the proposed MP&M rulemaking, EPA considered a P2 alternative for existing
indirect dischargers in the Metal Finishing Job Shops Subcategory. Under this alternative,
participating facilities could choose to meet Metal Finishing limitations and standards in lieu of
MP&M ELGs by implementing P2 and water conservation practices in ten P2 practice
categories, described in Table 4-11. Many of the operations listed in the P2 alternative for the
Metal Finishing Job Shops Subcategory were also discussed during the development of the Metal
Finishing ELGs but were not incorporated.
The participation of many metal finishing job shops in the National Metal Finishing SGP
by 2001, described in Section 4.3.4, formed the basis for the proposed alternative PSES
compliance option for the Metal Finishing Job Shops Subcategory. EPA noted in the preamble to
the final MP&M ELGs that many metal finishing job shops were already employing best
management practices outlined in the proposed P2 alternative as part of the SGP initiative.
Ultimately, the P2 alternative was not included in the final MP&M ELGs because EPA did not
promulgate new limits for Metal Finishing Job Shops Subcategory.
Table 4-11. Proposed P2 Alternatives for Metal Finishing Job Shop Subcategory
( alexin
Kc(|iiircmcnl
Tcchnolo*^ Options
Caleuon 1. Mubi ii^c
practices that reduce
and/or recover drag-
out
To bulibl'} lliib lequiienieiil,
facilities must implement three
or more drag-out reduction
practices or use at least one
drag-out recovery technology
option {i.e., chemical
recovery) listed under
technology options on all
electroplating or surface
finishing lines.
Dniii-oul Reduction Practices:
• Lower process solution viscosity and/or surface
tension by lowering chemical concentration,
increasing bath temperature, or use wetting
agents.
• Reduce drag-out volume by modifying
rack/barrel design and performing rack
maintenance to avoid solution trapping under
insulation.
• Position parts on racks in a manner that avoids
trapping solution.
• Reduce speed of rack/barrel withdraw from
process solution and/or increase dwell time over
process tank.
• Rotate barrels over process tank to improve
drainage.
• Use spray/fog rinsing over the process tank
(limited applicability).
• Use drip boards and return process solution to the
process tank.
• Use dragout tanks, where applicable, and return
process solution to the process tank.
• Work with customers to ensure that part design
maximizes drainage.
Dras-out Recovery Technology ODtions:
• Evaporators
• Ion exchange
• Electrowinning
• Electrodialysis
• Reverse osmosis
4-23
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Section 4—Recent Study Findings
Table 4-11. Proposed P2 Alternatives for Metal Finishing Job Shop Subcategory
( iiU'jion
Ke(|iiiremenl
Technolo*^ Options
Category 2. Must use
good rinse system
design for water
conservation
To satisfy this requirement,
facilities must implement three
or more elements
of good rinse system design
listed under technology
options on all electroplating or
surface finishing lines.
Good Rinse System Design Elements:
• Select the minimum size rinse tank in which the
parts can be rinsed and use the same size for the
entire plating line, where practical.
• Locate the water inlet and discharge points of the
tank at opposite positions in the tank to avoid
short-circuiting or use a flow distributor to feed
the rinsewater evenly.
• Use air agitation, mechanical mixing or other
means of turbulence.
• Use spray/fog rinsing (less effective with hidden
surfaces).
• Use multiple rinse tanks in a counter-flow
configuration (i.e., counter-current cascade
rinsing).
• Reuse rinsewater multiple times in different rinse
tanks for succeeding less critical rinsing.
Category 3. Must use
water flow control for
water conservation
To satisfy this requirement,
facilities must implement at
least one effective method of
water use control on all
electroplating or surface
finishing lines. Effective water
use controls include but are not
limited to those listed under
technology options.
Water Use Control Methods:
• Flow restrictors (Flow restrictors as a stand-alone
method of rinsewater control are only effective
with plating lines that have constant production
rates, such as automatic plating machines. For
other operations, there must also be a mechanism
or procedure for stopping water flow during idle
periods.)
• Conductivity controls
• Timer rinse controls
• Production activated control (e.g., spray systems
activated when a rack or barrel enters/exits a rinse
station)
Category 4. Must
segregate non-process
water from process
water
To satisfy this requirement,
facilities must not combine
non-process water such as
non-contact cooling water with
process wastewater prior to
wastewater treatment.
NA
Category 5. Must use
water conservation
practices with air
pollution control
devices
To satisfy this requirement,
facilities operating air
pollution control devices with
wet scrubbers must recirculate
the scrubber water as
appropriate (periodic
blowdown is allowed, as
needed). Where feasible, reuse
scrubber water in process
baths.
NA
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Section 4—Recent Study Findings
Table 4-11. Proposed P2 Alternatives for Metal Finishing Job Shop Subcategory
( iiU'jion
Ke(|iiiremenl
Tcchnolo*^ Options
Category 6. Must
practice good
housekeeping
To satisfy this requirement,
facilities must demonstrate
compliance with each of the
requirements listed under
technology options.
Good HousekeeDing Practices:
• Perform preventative maintenance on all valves
and fittings (i.e., check for leaks and damage) and
repair leak valves and fittings in a timely manner.
• Inspect tanks and liners and repair or replace
equipment as necessary to prevent ruptures and
leaks. Use tank and liner materials that are
appropriate for associated process solutions.
• Perform quick cleanup of leaks and spills in
chemical storage and process areas.
• Remove metal buildup from racks and fixtures.
Category 7. Minimize
the entry of oil into
rinse systems
To satisfy this requirement,
facilities must do at least one
of the practices listed under
technology options.
Oil Entry Minimization into Rinse Systems:
• Minimize the entry of oil into cleaning baths or
use oil skimmers or other oil removal devices in
cleaning baths when needed to prevent oil from
entering rinse tanks.
• Work with customers to degrease parts prior to
shipment to the plating facility to minimize the
amount of oils on incoming materials.
Category 8. Must
sweep or vacuum dry
production areas prior
to rinsing with water
To satisfy this requirement,
facilities must sweep or
vacuum dry production area
floors prior to rinsing with
water.
NA
Category 9. Must
reuse drum/shipping
container rinsate
directly in process
tanks
To satisfy this requirement,
when performing rinsing of
raw material drums, storage
drums, and/or shipping
containers that contain
pollutants regulated under the
MP&M regulation, facilities
must reuse the rinsate directly
into process tanks or save for
use in future production.
NA
Category 10. Must
implement
environmental
management and
record
keeping system
To satisfy this requirement,
facilities must meet the
requirements listed under
technology options.
Environmental Management Program Elements:
• Pollution prevention policy statement
• Environmental performance goals
• Pollution prevention assessment
• Pollution prevention plan
• Environmental tracking and record keeping
system
• Procedures to optimize control parameter settings
(e.g., oxidation-reduction potential (ORP) set
point in cyanide destruction systems, optimum
pH for chemical precipitation systems, etc.)
• Statement delineating minimum training levels
for wastewater treatment operators
Source: (U.S. EPA, 2000b)
NA: Not Applicable.
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Section 4—Recent Study Findings
4.4.5 Key MP&M Findings for the Metal Finishing Industry
EPA ultimately decided not to promulgate limitations and standards for the MP&M
subcategories that would have incorporated facilities covered under the Metal Finishing ELGs.
In response to public comments on the proposed rule, EPA re-evaluated in-place treatment
technologies and adjusted the datasets and methodology used to conduct the incremental cost and
loadings analyses. Due to these changes, EPA determined that the newly calculated limits for
metal-bearing wastewater subcategories were not technologically achievable, not economically
achievable, or the costs to achieve the limits were disproportionate to the estimated toxic
pollutant removals (U.S. EPA, 2003b). Refer to the memorandum Metal Products and
Machinery (MP&M) Rulemaking Preamble: Summary of Industry Comments and EPA Decisions
Related to the Metal Finishing Category for additional details on the changes made to EPA's
datasets and methodologies and summaries of stakeholder comments relevant to the Metal
Finishing Category (ERG, 2017b).
EPA's key findings for metal bearing wastewater subcategories (including the four
MP&M subcategories containing metal finishing facilities: General Metals, Metal Finishing Job
Shops, Non-chromium Anodizing, and Printed Wiring Board) are summarized below.
• Overall, the cost of achieving limits under Option 2 was considered disproportionate
to the estimated toxic pollutant removals for the subcategories.
• EPA determined that limitations based on the Option 4 technology were not proven to
be technologically achievable based on EPA's dataset. EPA also considered
establishing the Option 2 technology as the bases for PSES and NSPS, but determined
the limitations and standards created a barrier to entry for new dischargers.
• EPA determined that Option 2 created high closure rates for existing direct and
indirect dischargers (50 and 46 percent, respectively) in the proposed Metal Finishing
Job Shops Subcategory, which consisted entirely of facilities covered under the Metal
Finishing and Electroplating ELGs.
EPA considered incorporating PSES low-flow exclusions for the Metal Finishing Job
Shops, Printed Wiring Board, and General Metals Subcategories, and considered upgrading all
facilities in these subcategories covered under 40 CFR Part 413 to the PSES of 40 CFR Part 433.
Ultimately, EPA determined the closure rates for these two PSES options would be greater than
10 percent for existing dischargers not covered by 40 CFR Part 433 (U.S. EPA, 2003b).
4.5 Technical Conferences
As discussed in Section 3.5, EPA attended the NASF SUR/FIN® conference in 2016 and
the NACWA National Pretreatment and Pollution Prevention Workshop in 2016 and 2017,
which are further discussed in the following subsections. EPA also attended WEFTEC and
Engineer's Society of Western Pennsylvania's IWC conferences in 2016; however, EPA did not
identify any information from those conference proceedings relevant to the preliminary study of
the Metal Finishing Category.
4-26
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Section 4—Recent Study Findings
4.5.1 NASF SUR/FIN® Conference
Since the NASF SUR/FIN® conference was focused on the surface finishing industry,
there were several presentations, vendor booths, and papers relevant to the preliminary study of
the Metal Finishing Category. Major industries presenting at the conference included the
aerospace/defense, automotive, and electronics industries. There were multiple vendors
advertising wastewater treatment technologies and metal finishing technologies.
The aerospace/defense industry presented several advances in metal finishing processes,
waste reduction strategies, chemical alternatives, and wastewater treatment technologies. For
example, several presentations discussed the National Aerospace and Defense Contractors
Accreditation Program (Nadcap) as a driver for process changes and metal finishing
improvements. Nadcap specifications are required by many customers and increase product
uniformity in the aerospace/defense industry. In addition, the aerospace/defense industry reduced
the amount of chromium used in etching and plating process steps and identified several process
chemical alternatives, such as zirconium, manganese, phosphate, titanium, and cold-spray
surface finishing processes. Other aerospace/defense industry research indicates that zinc-nickel
plating is a more effective coating than cadmium and anticipates that the industry will move
away from cadmium plating. Finally, Water Innovations, Inc. presented an ion exchange
recycling system that has been implemented at several aerospace metal finishing facilities. The
treatment technology costs about $8-$ 16 per 1,000 gallons of wastewater and saves facilities
money on treatment chemicals and sludge disposal. This system is also designed to maximize the
amount of recyclable rinsewater.
NASF SUR/FIN® presentations about the automotive industry mostly discussed methods
to improve surface finishing. For example, several presentations talked about different software
models and simulations that shorten and improve the design of coating processes to optimize
product uniformity (e.g., tray design, coating thickness). Other presentations discussed
replacements for traditional coating chemistries, include one-coat systems (to replace two-coat
systems), tungsten/iron, iron/phosphorus, and silver/zinc chemistries.
Representatives from the electronics industry presented several chemical alternatives in
surface finishing. Traditionally, electroless nickel solutions are blended with additives containing
regulated heavy metals to stabilize and brighten the metal coating. However, a new process using
an organo-metallic complex as the additive provides a Restriction of Hazardous Substances
Directive (RoHS)-compliant chemical that improves metal coating brightness, leveling, surface
roughness, porosity, deposit stress, and corrosion resistance. Also, substitutes for lead alloys (due
to environmental lead restrictions) have been developed (e.g., Sn-Ag-Cu alloy).
EPA also visited vendor booths on the NASF SUR/FIN® show floor. There was a booth
operated by Precious Metals Processing Consultants, Inc. (PMPC) that demonstrated the removal
potential of their electro-winning system, which is in full operation at several sites to remove
precious metals. More research needs to be performed to determine whether this wastewater
treatment technology is applicable to other heavy metals.
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Section 4—Recent Study Findings
4.5.2 NACWA Conferences
At the 2016 and 2017 NACWA conference, EPA attended roundtable discussions on
concerns and problems facing Control Authorities pertaining to categorical dischargers.
Attendees expressed concern over the applicability of metal finishing regulations. One area of
discussion involved the confusion surrounding process operations that use weak acids. Some
states interpret weak acids, such as citric acid, as not covered under the Metal Finishing ELGs.
Citric acid is often used for cleaning and to satisfy customers who desire a greener process.
Attendees urged EPA to look at the intent of the metal finishing regulation regarding weak acids.
Some attendees also asked for clarification on the applicability of the Metal Finishing ELGs to
specific manufacturing industries and process operations, such as the manufacture of germanium
crystals for night vision goggles. Another area of discussion involved the appropriateness of
applying the Metal Finishing ELGs to wastewater generated at facilities primarily engaged in
other industrial activities.
Members also expressed the desire to consolidate the metal finishing (40 CFR Part 433)
and electroplating (40 CFR Part 413) regulations. Certain electroplating and metal finishing
facilities that began operation before July 15, 1983 are covered under the Electroplating
Category and, therefore, must comply with the less stringent Electroplating ELGs. All other
facilities performing electroplating or metal finishing operations are subject to regulations under
the Metal Finishing Category.
4.6 Stakeholder Outreach
EPA contacted stakeholders to better understand the metal finishing industry and to gain
different perspectives on the implementation of the 1983 regulations and current industry
operations. The following sections discuss EPA's conversations with pretreatment coordinators,
industry and trade organizations, and other stakeholders.
4.6.1 Local Control Authorities and EPA Regional Pretreatment Coordinators
EPA continued discussions with local Control Authorities and EPA Regional
pretreatment coordinators who have direct experience with metal finishing wastewater issues at
POTWs to identify metal finishing scenarios for which the applicability of the regulations is
unclear, and to further their understanding of the metal finishing industry profile. Specifically,
EPA met with local Control Authorities from POTWs receiving metal finishing wastewater from
facilities EPA visited in Utah. From this discussion, EPA learned that the POTWs generally have
not had issues with receiving metal finishing wastewater streams. While the region is not a
water-stressed area, local Control Authorities may encourage smaller metal finishers to consider
zero discharge practices (i.e., collect and evaporate wastewater) because the generated
wastewater volumes are more easily managed through evaporation ponds or tanks than
pretreatment to send to a POTW. Of the regulated pollutants, the local Control Authorities noted
that TTO is the costliest to manage and monitor for both the facilities and the POTWs. Lastly,
local Control Authorities indicated gray areas of applicability related to transportation polishing
and brightening, and cleaning activities involving acids and metals (ERG, 2017e).
Additionally, EPA held a meeting with EPA Regional pretreatment coordinators in
December 2016 and asked about the number of electroplating and metal finishing facilities in
4-28
-------
Section 4—Recent Study Findings
each Region, and whether brightening and tank cleaning operations performed at wineries,
dairies, breweries, and truck stops were being considered as metal finishing operations. EPA also
asked about applicability issues with cleaning vs. etching, citric acid, or new chemicals and
processes (U.S. EPA, 2018a). From this discussion, EPA learned that the number of
electroplating and metal finishing facilities varies widely (from 4 to over 1,300) between
Regions (that specifically track the number of electroplating or metal finishing facilities). For
facility classification, regions may classify a winery, dairy, or brewery as a metal finishing
facility if it performs passivation, but this practice is uncommon. Regions may classify a truck
stop as a metal finishing facility if it has brightening operations, but this practice is also
uncommon (U.S. EPA, 2018a).
EPA also learned that Regions have defined a cleaning step as etching or coating if an
acid is used in the process; however, this is an area where additional clarification would be
useful for all Regions. Regions differ in handling the classification of citric acid operations.
Some Regions consider any process that is removing the metal basis material, regardless of the
acid used, as a metal finishing process. Others consider a process strictly of citric acid cleaning a
non-metal finishing process because citric acid is a very light acid (U.S. EPA, 2018a).
4.6.2 Industry and Trade Organizations
EPA continued discussions with the NASF, a trade association representing the interests
of the North American surface finishing industry, including metal finishing. EPA spoke at the
NASF Washington Forum in 2016 and met with NASF in February 2016, November 2016, and
April 2017 to discuss the preliminary study of the Metal Finishing Category (U.S. EPA, 2018b).
In addition to the meetings above, EPA also attended the project kickoff meeting on
November 29, 2016 for the P2 Research and Implementation for Michigan Metal Finishers, a
joint project with NASF, the National Center for Manufacturing Sciences (NCMS), and other
stakeholders. The project objective is to demonstrate how to reduce pollution from metal
finishing facilities through new and innovative source reduction P2 methods and technologies.
The phases of the project include researching P2 technologies for metal finishers, surveying the
metal finishers located in Region 5, auditing select Detroit area metal finishing facilities (four to
six facilities), implementing agreed-to P2 initiatives at these metal finishing facilities, and
developing case studies based on the implemented technologies (U.S. EPA, 2016c).
EPA also reviewed the "NASF Milwaukee Area Surface Finishing Industry Metal
Loadings Study," published in March 2017. From 1989 through 1992, the Metal Finishers
Defense Fund (MFDF) conducted a study to calculate the percentage of influent loadings from
metal finishing facility wastewater discharges (categorical industrial users) to the Milwaukee
Metropolitan Sewerage District (MMSD), which consists of two water reclamation facilities
(Jones Island and South Shore). The pollutants of concern were cadmium, chromium, copper,
cyanide, lead, nickel, silver, and zinc. NASF with contractor River's Bend Engineering (RBE)
conducted a similar study evaluating MMSD influent characteristics from 2014 through 2016.
NASF compared the results of its study with the study conducted by MFDF and showed a
decrease in influent loadings from metal finishing facility wastewater discharges sent to the
MMSD over the years (NASF, 2017).
4-29
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Section 4—Recent Study Findings
4.6.3 Other Stakeholders
EPA held meetings with the NACWA in 2016 and in 2017 to understand their
perspective on the implementation of the 1983 regulations (U.S. EPA, 2018). Additionally, EPA
attended the NACWA 2016 and 2017 Pretreatment & Pollution Prevention Workshops,
discussed in Section 4.5.
4.7 Other Regulations and Initiatives Affecting the Metal Finishing Industry
In the 2015 Status Report (U.S. EPA, 2016a), EPA discussed environmental regulations
outside of the Metal Finishing ELGs that may impact the industry. As part of continuing efforts,
EPA performed an in-depth review of available online resources, including government and
trade organization websites, to identify additional environmental regulations, international
environmental initiatives, and customer certifications that may impact metal finishing facility
process operations, process chemistries, and wastewater treatment operations.
4.7.1 Federal Regulations
Metal finishing facilities are subject to multiple federal environmental air emissions and
hazardous waste disposal regulations. Plating tanks and other process operations that emit metals
and toxic materials into the air are regulated by the U.S. EPA Office of Air and Radiation. Air
emission controls installed by metal finishing facilities to comply with air regulations impact
wastewater characteristics at those facilities. Additionally, metal finishing process solutions and
wastewater are highly toxic in nature, requiring facilities to consider hazardous waste regulations
when disposing of spent solutions and wastewater treatment wastes (e.g., sludge, filter cake). The
subsections below describe U.S. air and hazardous waste regulations that may cover metal
finishing facilities.
4.7.1.1 National Emission Standards for Hazardous Air Pollutants (NESHAPs), U.S. EPA
Office of Air and Radiation
EPA explored NESHAPs that may require metal finishing facilities to incorporate air
control technologies to mitigate air emissions, such as wet scrubbers, to understand if the
resulting generated wastewater can impact metal finishing wastewater discharges. Several
NESHAPs (listed below) apply to metal finishing operations.
• NESHAPs for Chromium Emissions from Hard and Decorative Chromium
Electroplating and Chromium Anodizing (40 CFRPart 63, Subpart N), 2012. EPA
promulgated the original NESHAP in 1995 affecting all facilities using chromium
electroplating tanks. In 2012, EPA amended the rule to tighten emission standards for
chromium electroplating and anodizing operations, which included revised emission
and surface tension limits for hard chrome electroplating, decorative chrome
electroplating, and anodizing tanks, and a ban on the use of perfluorooctane sulfonate
(PFOS)-based fume suppressants in air pollution control devices (40 CFR Part 63,
Subpart N). Based on discussions with some metal finishing facilities, EPA learned
that wastewater generated from emission control devices used to control chromium
emissions are typically combined with other metal finishing wastewater for
wastewater treatment because their wastewater characteristics make them amenable
to the same treatment steps.
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Section 4—Recent Study Findings
• NESHAP for Plating and Polishing Operations (40 CFR Part 63, Subpart
WWWWWW), 2008. EPA's 2008 NESHAP required use of generally available control
technology (GACT) standards at facilities with plating, polishing or thermal spray
processes that contain cadmium, nickel, lead, manganese and/or chromium (excluding
chromium electroplating and anodizing operations). The rule does not establish
emission limits for these operations but requires platers to implement management
practices that reduce the generation of airborne chemicals. Facilities have several
compliance alternatives, including the use of wetting agents/fume suppressants
(WA/FS), air pollution control devices, or tank covers. At the time of the rule, EPA
determined that the regulation would not interfere with the ability of facilities in the
plating and polishing area source category to comply with the Clean Water Act
requirements (e.g., Metal Finishing Effluent Guidelines, 40 CFR Part 433) (73 FR
37728).
• NESHAP for Metal Fabrication and Finishing Area Source (40 CFR Part 63, Subpart
XXXXXX), 2008. In 2008, EPA promulgated requirements to reduce air pollution of
compounds of metals such as cadmium, chromium, lead, manganese, and nickel in
nine metal fabrication and finishing source categories. This rule applies to facilities
"primarily engaged" in one of these nine source categories. The rule covers the
following operations: dry abrasive blasting, dry grinding and dry polishing with
machines, dry machining, spray painting, and welding. At the time of the rule, EPA
determined that none of the control measures considered for the final rule generate a
wastewater stream (73 FR 42978).
4.7.1.2 Resource Conservation and Recovery Act (RCRA) Hazardous Waste Regulations,
Office of Resource Conservation and Recovery (ORCR)
Metal finishing facilities generate hazardous waste, including spent process solutions
(e.g., alkaline cleaners, plating baths) and metal finishing wastewater treatment residuals (e.g.,
sludge and filter cake). The handling and disposal of these hazardous wastes is regulated under
RCRA. EPA identified RCRA regulations that may impact how facilities in the metal finishing
industry handle hazardous waste and treat process wastewater.
As defined under RCRA, wastewater treatment sludge from electroplating operations18 is
a F006 hazardous waste and, therefore, costlier for waste generators to dispose of than
nonhazardous wastes. In the 2015 Status Report, EPA described discussions with wastewater
treatment vendors, during which EPA learned that this hazardous waste regulation can inhibit
industry advances in wastewater treatment technologies. Specifically, vendors noted the
difficulty of applying more advanced technologies, such as ion exchange or RO, due to the costs
of offsite resin or membrane reclamation and/or disposal. The resins and membranes may be
classified as hazardous waste, most commonly under F006. Technologies such as ion exchange
and RO can treat wastewaters to a quality enabling their reuse in metal finishing processes,
thereby significantly reducing the amount of wastewater discharged. However, the added cost of
18 Wastewater treatment sludges from the following processes are not F006 hazardous wastes under RCRA: (1)
sulfuric acid anodizing of aluminum; (2) tin plating on carbon steel; (3) zinc plating (segregated basis) on carbon
steel; (4) aluminum or zinc-aluminum plating on carbon steel; (5) cleaning/stripping associated with tin, zinc, and
aluminum plating on carbon steel; and (6) chemical etching and milling of aluminum (40 CFR Part 261).
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Section 4—Recent Study Findings
managing the hazardous wastes generated by these technologies may render them economically
infeasible for many metal finishing facilities (particularly job shops). EPA visited at least one
metal finishing facility in 2016 that noted the higher cost of disposing sludge and filter cake
classified as hazardous (versus non-hazardous) waste.
In addition to F006 hazardous wastes, corrosive wastes generated by metal finishing
facilities, such as spent acid or alkaline cleaning baths, are considered "characteristic wastes"
due to corrosivity (RCRA waste codes D002) and must be managed as hazardous waste. Other
common metal finishing hazardous wastes include spent process solutions containing lead
(RCRA waste code D008) and spent solvents (F001, F002, F003, F004, F005). On January 13,
2015, EPA published in the Federal Register a revised definition of solid waste under RCRA (80
FR 1694). The objective was to encourage reclamation of hazardous secondary materials,
without increasing the risk to human health and the environment posed by improperly discarded
hazardous secondary material. The revised solid waste definition excludes high-value solvents
transferred from one manufacturer to another for the purpose of extending the useful life of the
solvents by remanufacturing the solvent back to the commercial grade solvent (remanufacturing
exclusion). Regulators believed this exclusion would encourage waste generators, such as metal
finishers, to recycle high-value solvents rather than pay a RCRA permitted waste handler a
considerable fee for waste disposal. This new definition may help advance adoption of P2 in the
metal finishing industry (U.S. EPA, 2015c).
On November 28, 2016, EPA published the Hazardous Waste Generator Improvements
Rule (81 FR 85808) to revise the Resource Conservation and Recovery Act (RCRA) hazardous
waste regulatory program. EPA revised the existing regulatory program to make hazardous waste
generator regulations easier to understand, facilitate better compliance, provide greater flexibility
in managing hazardous waste, and close important gaps in the regulations. Updates to the
regulatory program may further facilitate the disposal of wastewater treatment wastes for metal
finishers by:
• Allowing hazardous waste generators to avoid the increased burden of high generator
status when generating episodic waste, provided the hazardous waste generator
properly manages the episodic waste. These facilities are generally limited to one
episodic waste event per year.
• Allowing a very small quantity generator to send its hazardous waste to a large
quantity generator under control of the same person (81 FR 85808).
4.7.2 Other Environmental Directives
Metal Finishing facilities looking to sell their products throughout the U.S. and abroad
need to comply with state and international environmental directives specific to those markets.
The European Union (EU), additional countries, and at least one U.S. state (California) have
developed environmental initiatives to limit the quantity and concentration of certain chemicals
that are manufactured in or imported to their regions. For example, in 2000, the EU published the
End of Life Vehicles Directive to address the recycling and/or disposal of automobiles at the end
of their useful lives to reduce waste containing lead, mercury, cadmium, and hexavalent
chromium. The directive bans lead, mercury, and cadmium, and limits hexavalent chromium to
minimal amounts for corrosion protection only.
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Section 4—Recent Study Findings
In 2007, the European Community Regulation (EC 1907/2006) Registration, Evaluation,
Authorization and Restriction of Chemical substances (REACH), became effective and was most
recently revised in 2017. REACH requires special registration for all substances manufactured or
imported to the EU at certain threshold quantities. Special registration is also required for
substances incorporated into certain articles (e.g., automobiles, electronic chips, jewelry, etc.).
Metal finishers importing to the EU must notify the European Chemicals Agency (ECHA) if the
imported article contains concentrations above 0.1 percent by weight of a chemical on the
REACH candidate list or if the chemical exceeds a total one metric tonne per year in articles
imported by the facility. REACH candidate list chemicals include substances common in metal
finishing operations, such as cadmium, chromium, and lead compounds (ECHA, 2017).
In 2002, the Restriction of Hazardous Substances (RoHS) directive was established in the
EU and set maximum levels for six restricted materials used in electronic and electrical products,
including cadmium, hexavalent chromium, mercury, lead, polybrominated biphenyls (PBB), and
polybrominated diphenyl ethers (PBDE). The EU RoHS was updated in 2015 to include
restrictions on four different phthalates bis(2-ethylhexyl) phthalate (DEHP), benzyl butyl
phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP)). Metal finishing
facilities that import products or finish parts into the EU for customers covered by RoHS must
meet these requirements (NASF, 2012). The RoHS requirement most relevant to the metal
finishing industry is the limit on the percentage of chromium and chromate in any material or
coating (0.1 percent and 0.01 percent by weight, respectively). Efforts in the metal finishing
industry are underway to find replacements for cadmium and chrome in plating due to the
European REACH and RoHS regulations (NASF, 2012).
EPA identified the following additional environmental directives similar to RoHS that
may impact how metal finishers importing to these markets select plating and coating
constituents:
• The California Electronics Recycling Act (2003) (SB 20 as amended by SB 50) limits
the use of hazardous substances in certain electronic products sold in California
(CalRecycle, 2017).
• China Administration on the Control of Pollution Caused by Electronic Information
Products (ACPEIP) (2006) establishes product-marking requirements for the original
six EU RoHS chemicals.
• Korea Act of Resources Recycling of Electrical and Electronic Equipment and
Vehicles (2007) promotes improvement in product design and recycling technology
as they become technologically and economically feasible. The regulation established
chemical concentration standards for lead, mercury, hexavalent chromium, and
cadmium in electrical and electronic equipment and vehicles.
• Norway Prohibition on Certain Hazardous Substance in Customer Products (PoHS)
(2008) prohibits the use of 18 substances, including lead and cadmium, in consumer
goods.
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Section 4—Recent Study Findings
4.7.3 Customer Specifications and Certifications
Customers in the automotive, aerospace, and defense industries often require strict
manufacturing and product specifications for their plated parts. Metal finishing facilities may be
restricted to certain chemicals and plating processes to meet these customer specifications. For
example, job shops that finish parts for certain automotive companies may be required to meet
strict customer specifications for these parts. EPA also identified two industry-specific programs
that affect how facilities operate their plating processes, described below.
The National Aerospace and Defense Contractors Accreditation Program (Nadcap) is a
cooperative program managed by companies in the aerospace and defense industries. The
program was designed to establish cost-effective, standardized approaches for process operations
and products and aims to provide continual improvement within the aerospace and defense
industries. Metal finishing facilities that supply parts to these companies become Nadcap
accredited for certain processes (e.g., electroplating, anodizing, coating, and stripping), which
can dictate aspects of finishing procedures.
In addition to meeting Nadcap criteria, metal finishing facilities that supply parts for the
U.S. military must finish parts in accordance with strict military specifications. These
specifications dictate the temperatures, plating times, plating thickness, hardness, plating bath
concentrations, and other specifications during metal finishing process operations, leaving little
room for manufacturing variation. Some military specifications allow for alternative coatings for
traditional cadmium plating, including pure aluminum, zinc-nickel, and nickel fluorocarbon.
However, military specifications for some parts require the use of cadmium plating (NASF,
2012).
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Section 5—Preliminary Review Conclusions
5. Preliminary Review Conclusions
Our preliminary review indicates that processes that generate wastewater in metal
finishing operations have not changed substantially since EPA first promulgated the Metal
Finishing ELGs. Additionally, most metal finishing facilities continue to use conventional
chemical precipitation and clarification wastewater treatment technologies (the technology basis
for the existing ELGs); however, some facilities have installed advanced treatment technologies,
such as a membrane filtration polishing step.
At this time, EPA does not have, nor have stakeholders provided, any data to demonstrate
that pollutants in metal finishing discharges are leading to environmental problems or causing
issues for POTWs. As the scope of the Metal Finishing ELGs is specific to "operations" such as
electroplating, etching, and cleaning, rather than to a specific type of manufacturing, some
stakeholders continue to have questions regarding the applicability of this rule, particularly at
facilities for which metal finishing operations are ancillary. The main applicability issues
identified include:
• Misapplication of the metal finishing ELGs when a facility's operations do not fall
under SIC and NAICS codes for the Metal Finishing Category (e.g., assigning the
metal finishing ELGs to a facility that is not performing metal finishing operations or
not assigning the metal finishing ELGs to a facility that is performing metal finishing
operations).
• Applicability of the metal finishing ELGs to specific scenarios (e.g., transportation
polishing and brightening).
• Definitions of the 46 metal finishing unit operations, leading to misapplication of
permit limits (e.g., cleaning vs. etching).
Therefore, EPA plans to focus its future efforts on the resolution of applicability
questions. As noted in Sections 3.6.2 and 3.6.3, EPA will continue discussions with outside
stakeholders, such as the NASF and NACWA, as it resolves these applicability questions.
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Section 6—Quality Assurance
6. Quality Assurance
In gathering information to support EPA's preliminary study of the Metal Finishing
Category, EPA evaluated and documented the usefulness and quality of the data collected to date
in accordance with the criteria specified in the Environmental Engineering Support for Clean
Water Regulations Programmatic Quality Assurance Project Plan (PQAPP) (ERG, 2013). EPA
also applied specific criteria discussed below in Section 6.3. This section describes the data
sources used and data quality evaluations performed for EPA's 2016-2017 study activities.
6.1 Project Objectives
As discussed in Section 1, one of EPA's primary objectives for the preliminary study of
the Metal Finishing Category was to assess the current state of the industry to better understand
how metal finishing operations, wastewater characteristics, and wastewater treatment
technologies have changed since EPA promulgated the 1983 ELGs. This assessment will help
EPA to determine whether additional data collection efforts are needed and how best to address
the 1983 Metal Finishing ELGs. Specifically, the study seeks to answer the key questions listed
in Section 1 of this report.
6.2 Data Sources
To support its preliminary study of the Metal Finishing Category, in 2016 - 2017 EPA
collected information from the following activities and data sources:
• Site visits to metal finishing facilities.
• Government databases containing discharge data, specifically, DMR and TRI data.
• Conference proceedings, peer-reviewed journals, and other literature.
• Government publications and supporting information.
• Interviews with industry personnel, vendors, trade association representatives, and
pretreatment coordinators.
6.3 Data Quality Objectives and Criteria
As described in the PQAPP, EPA ensured that the data collection, processing, and
analyses performed for the preliminary study met the data quality standards of objectivity,
integrity, utility, and transparency, as described below:
• Objectivity. The information must be accurate, reliable, and unbiased, and the manner
in which the information is presented must be accurate, clear, complete, and unbiased.
• Integrity. The information may not be compromised through corruption or
falsification, either by accident or by unauthorized access or revision.
• Utility. The information must be useful for the intended users.
• Transparency. The sources of the data used must also have been made transparent.
EPA describes the various assumptions made, analytical methods used, and statistical
procedures applied throughout the study report.
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Section 6—Quality Assurance
EPA prioritized the review of the data sources described in Section 6.2 to address the key
study questions listed in Section 1 of this report. EPA evaluated the quality of data using the
criteria of accuracy, relevance, reliability, and representativeness. These criteria are described in
Section 4.3.1 and in Table 4-2 of the PQAPP (ERG, 2013), and summarized below:
Accuracy. EPA assumed that the underlying data and information contained in state and
federal reports, peer-reviewed journal articles, and industry publications are accurate. Although
industry publications are not usually peer-reviewed, this resource provides useful information for
understanding metal finishing processes and wastes generated. EPA considered data from
industry, including discussions with trade associations and correspondence with individual
facilities, to be sufficiently accurate to characterize the metal finishing industry, its process
operations, and anticipated waste streams.
Relevance. Selected data sources must describe process operations, pollutants, or waste
streams that are representative of the metal finishing industry. Data sources that most closely
provide answers to the key questions listed in Section 1 are the most relevant.
Reliability. EPA considered the following factors when evaluating the reliability of data
sources used to support the study: (1) data that have been generated by government agencies or
are otherwise subject to peer review and assessment are considered to be the most reliable and
useful for understanding industry process operations, quantitatively characterizing wastewater
discharges, and demonstrating treatment system performance; (2) data from entities with
established knowledge in the topic area (e.g., studies conducted by industry experts, academic
researchers, data generated by an industrial facility using documented and approved methods)
are also considered to be reliable and useful for understanding industry process operations,
quantitatively characterizing wastewater discharges, demonstrating treatment system
performance, and understanding applicability of the regulations; and (3) data from sources that
use unknown collection and data review procedures are less reliable, but may be generally useful
for qualitative understanding of industry process operations and waste streams. In general, EPA
evaluated reliability based on the degree to which sources met the following criteria:
• Scientific work was clearly written, with all assumptions and methodologies
identified.
• Variability and uncertainty (quantitative and qualitative) in the information or in the
procedures, measures, methods, or models were evaluated and characterized.
• Assumptions and methodologies were consistently applied throughout the analysis as
reported in the source.
• Waste streams, parameters, units, and detection limits (when appropriate) were
clearly characterized.
• The governmental or facility contact was reputable and had knowledge of the
industry, facility, process operation, or waste streams of interest.
Representativeness. EPA evaluated whether data sources described process operations,
pollutants, or waste streams that were representative of the metal finishing industry. For the
purposes of this study, EPA expanded upon the general criteria set forth in the PQAPP by
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Section 6—Quality Assurance
establishing data quality acceptance criteria related to the geographic scope and age of the data
(described below):
• Geographic scope. Data sources must describe the wastewater characteristics for the
metal finishing industry in the United States. EPA also collected information from
data sources that described how the data were produced, such as the source of the
wastewater, sample collection procedures, analytical methods, units, and relevant data
qualifiers, to further evaluate the data's usefulness in future analyses. EPA included
some international data sources that were relevant for their descriptions of other
potential wastewater treatment technologies or chemical processes used in metal
finishing.
• Age. EPA prioritized data sources published in 2000 or later, as they reflect more
recent industry changes. However, information published before 2000 (e.g., 1983
Metal Finishing Technical Development Document, supporting documentation for the
MP&M rulemaking) can provide useful qualitative information regarding the
temporal status of the industry. In addition, EPA noted the year of the data source
referenced in the preliminary study to clearly document the time period.
Table 6-1 summarizes the data quality criteria discussed above.
Table 6-1. Data Quality Criteria Summary
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Accuracy
Underlying data in state and federal reports, peer-reviewed journal articles,
and industry publications are assumed accurate. Data collected from industry
representatives are assumed sufficiently accurate.
Relevance
Describe process operations, pollutants, or waste streams that are
representative of the metal finishing industry.
Reliability
Clearly written; assumptions and methodologies identified.
Variability and uncertainty in the information are evaluated and characterized.
Assumptions and methodologies are consistently applied.
Representativeness
Process operations, pollutants, or waste streams that are representative of the
metal finishing industry are described.
Wastewater characteristics of the U.S. metal finishing industry are described.
Data sources addressing industry outside of the United States were also
included for descriptions of potentially applicable wastewater treatment
technologies or chemical processes.
Data sources published in 2000 or later are prioritized; data sources prior to
2000 were used qualitatively.
6.4 Data Quality Evaluation
This section describes the data sources EPA used and how they met the evaluation
criteria listed in Section 6.3. Table 6-2, at the end of this section, summarizes the data sources
and acceptance criteria EPA evaluated for each type of data set reviewed during 2016-2017 study
activities.
6-3
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Section 6—Quality Assurance
6.4.1 Site Visits to Metal Finishing Facilities
EPA conducted site visits to 18 facilities covered under the Metal Finishing ELGs (see
Section 4.1). EPA selected facilities for site visits and data collection in accordance with
procedures outlined in the Environmental Engineering Support for Clean Water Regulations
PQAPP (ERG, 2013) and the Quality Assurance Activities for the Selection of the Metal
Finishing Sites and Existing Data Collection During Site Visits - Revision 1 ("Site Visit QA
Memo") (ERG, 2016d).
EPA focused on geographic areas where many metal finishing facilities are located,
specifically California, Utah, and EPA Region 5, to develop a prioritized list of facilities of
varying size, location, industries, process water usage, and treatment practices. EPA collected
DMR and TRI discharge data and pretreatment reports for metal finishing facilities in these
regions and ranked sites of interest based on uniform criteria including discharge type, location,
process operations performed, wastewater treatment technologies, and P2 practices in place. EPA
also contacted pretreatment coordinators in these regions to request recommendations of
facilities covered under the Metal Finishing ELGs for site visits.
Before each site visit, EPA documented facility background information obtained from
sources such as past facility contacts, DMR or TRI discharge data, and the facility website. EPA
identified key elements about each facility, including specific operations or permit limits of
interest, and contacted the facility to verify personal protective equipment (PPE) and obtain any
additional information needed before the visit. EPA also requested facility discharge permits.
After each site visit, EPA prepared a site visit report that documented observations of process
chemistries, process operations, and wastewater treatment, as well as conversations about
regulatory applicability, technology costs, and other information. If EPA used site visit
information to develop profiles, characterize wastewater, or evaluate treatment technologies,
EPA applied the site visit data acceptance criteria (outlined in the Site Visit QA Memo, (ERG,
2016d)) to evaluate the acceptability of the information.
6.4.2 Government Databases with Discharge Data (DMR and TRI)
EPA downloaded DMR and TRI data in accordance with the Environmental Engineering
Support for Clean Water Regulations PQAPP. Specifically, EPA performed quality assurance
and quality control (QA/QC) procedures to verify data downloads, check query logic in data
analyses, and review data transcriptions between Excel spreadsheets, Access databases, and
summary tables presented in memoranda and reports. EPA detailed QA/QC activities on its
multi-phase reviews of the DMR and TRI data in the following approach memoranda:
• Metal Finishing Preliminary Study: Proposed Approach for Phase I Review of DMR
and TRI Data (ERG, 2015).
• Metal Finishing Preliminary Study: Phase I Review Results and Proposed Approach
for Phase II Review of DMR and TRI Data (ERG, 2016c).
6.4.3 Conference Proceedings, Peer-Reviewed Journal Articles, Other Academic Literature
EPA reviewed conference proceedings, peer-reviewed journal articles, and other
academic literature in support of its preliminary study of the Metal Finishing Category. As
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Section 6—Quality Assurance
described in the 2015 Status Report, EPA identified over 130 documents from peer-reviewed
journals and other academic literature. To build on this search, EPA used a second list of key
words (see Section 3.3) to perform a targeted literature search to identify P2 practices relevant to
the metal finishing industry. As part of the P2 literature search and review, EPA collected 22
relevant peer-reviewed journal articles, recorded them on a quality evaluation tracking
spreadsheet, and documented how each data source met (or did not meet) the quality criteria
(ERG, 2017f). EPA applied the data quality criteria established in the Environmental
Engineering Support for Clean Water Regulations PQAPP (ERG, 2013) and determined that the
data and information obtained from conference proceedings, peer-reviewed journals, and other
academic literature were sufficiently accurate, reliable, and relevant for characterizing metal
finishing process operations, chemistries, wastewater, treatment technology performance, and P2
practices relevant to the industry. Refer to the Quality Assurance Activities for the Collection of
Existing Data to Support the Metal Finishing Preliminary Study - Revision 1 (ERG, 2016e) for
addition quality assurance procedures applied to the literature search.
6.4.4 Existing Government Publications and Supporting Information
EPA obtained information from government publications and supporting documents,
specifically documents supporting the Metal Finishing ELGs and the MP&M proposed
rulemaking. During the MP&M proposed rulemaking, EPA evaluated facilities covered under
the Metal Finishing ELGs in the 1980s and 1990s. EPA applied the criteria established in the
Environmental Engineering Support for Clean Water Regulations PQAPP (ERG, 2013) and
determined that this information was sufficiently accurate and reliable for characterizing metal
finishing process operations, chemistries, wastewater characteristics, and wastewater treatment
technologies. However, due to the age of the data, EPA determined that the information may not
be representative of current industry practices, and only used the information qualitatively to
establish a timeline for changes within the industry. EPA recorded QA determinations for
identified MP&M documents in an Excel workbook, which is included as an attachment to the
memorandum titled Metal Products and Machinery (MP&M) Rulemaking Documentation:
Screening Review Results and Proposed Approach for Detailed Review (ERG, 2016b).
6.4.5 Information Obtained from Industry, Vendors, and Trade Associations
EPA contacted personnel at specific facilities, wastewater treatment technology vendors,
and trade associations and obtained first-hand information regarding facility-specific process
operations and waste streams, treatment technologies, and P2 practices used by the industry.
EPA also obtained information from the websites of metal finishing facilities, vendors, and trade
associations, including descriptions of process operations, types of products, and services
performed. EPA applied the criteria established in the Environmental Engineering Support for
Clean Water Regulations PQAPP (ERG, 2013) and determined that this information was
sufficiently accurate, reliable, and representative of the facilities of interest for use in
characterizing industry sector trends and for providing a qualitative understanding of process
operations and treatment technologies used.
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Section 6—Quality Assurance
Table 6-2. Data Acceptance Criteria for the Preliminary Study of the Metal Finishing Category
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facilities
Metal finishing process
operations clearly
described. Metal finishing
wastewater treatment
operations clearly
described.
Metal finishing
waste stream
identified, and
analytes, units,
analytical methods,
and detection limits
identified.
(1) Represents full-scale system
operated at applicable metal
finishing facility.
(2) Influent and effluent data show
that treatment system is well
designed and operated.
(3) Detailed description of the
treatment system and operating
conditions.
(4) Analytes identified; units,
analytical methods and detection
limits included.
(1) Information describing
wastewater not generated by or
comingled with wastewater
covered by the Metal Finishing
ELGs.
Government databases
containing DMR and TRI
discharge data
Metal finishing process
operations clearly
described.
Metal finishing
waste stream
identified, and
analytes, units,
analytical methods,
and detection limits
identified.
(1) Represents full-scale system
operated at applicable metal
finishing facility.
(2) Influent and effluent data show
that treatment system is well
designed and operated.
(3) Detailed description of the
treatment system and operating
conditions.
(4) Analytes identified; units,
analytical methods and detection
limits included.
(1) Data collected by an unknown
method or units
undefined.
(2) Data collected during upset
conditions.
(3) Data represents a process that is
not of interest (e.g.,
sanitary wastewater).
Conference proceedings,
peer-reviewed j ournal
articles, other academic
literature
Data are current and
relevant to the metal
finishing facility/industry
operations of interest.
Metal finishing
waste stream
identified, and
analytes, units,
analytical methods,
and detection limits
identified.
Geographic scope is
(1) Represents full-scale system
operated at applicable metal
finishing facility.
(2) Influent and effluent data show
that treatment system is well
designed and operated.
(3) Detailed description of the
treatment system and operating
conditions.
Article/paper not peer-reviewed or
otherwise deemed sufficient for
limited purposes such as
identifying incidental and
qualitative data.
6-6
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Section 6—Quality Assurance
Table 6-2. Data Acceptance Criteria for the Preliminary Study of the Metal Finishing Category
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within the United
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(4) Analytes identified; units,
analytical methods and detection
limits included.

Government publications
and supporting information
(e.g., documents supporting
the Metal Finishing ELGs,
data collected during the
MP&M rulemaking)
Metal finishing process
operations clearly
described.
Metal finishing
waste stream
identified, and
analytes, units,
analytical methods,
and detection limits
identified.
(1) Represents full-scale system
operated at applicable metal
finishing facility.
(2) Influent and effluent data show
that treatment system is well
designed and operated.
(3) Detailed description of the
treatment system and operating
conditions.
(4) Analytes identified; units,
analytical methods and detection
limits included.
(1) Data collected by an unknown
method or units
undefined.
(2) Data collected during upset
conditions.
(3) Represents a process that is not
of interest (e.g.,
sanitary wastewater).
Data and information
obtained by directly
contacting personnel in
industry, vendors, and trade
associations
Metal finishing process
operations clearly
described.
Metal finishing
waste stream
identified, and
analytes, units,
analytical methods,
and detection limits
identified.
(1) Represent full-scale system
operated at applicable metal
finishing facility.
(2) Influent and effluent data or
percent removal identified and
show that treatment system is well
designed and operated.
(3) Detailed description of the
treatment system and operating
conditions.
(4) Analytes identified; units,
analytical methods and detection
limits included.
(1) The plant has since changed
operations (e.g., no longer
performing metal finishing
operations) since the data were
collected.
(2) Data collected during upset
conditions.
(3) Represents a process that is not
of interest (e.g., sanitary
wastewater).
6-7
-------
Section 7—References
7. References
1. CalRecycle. (2017). California Environmental Protection Agency, Department of
Resources Recycling and Recovery (CalRecycle). Retrieved from
http://www.calrecvcle.ca.gov/electronics/act2003/. Accessed: September 5, 2017.
EPA-HQ-OW-2015-0665. MF00251.
2. ECHA. (2017). European Union Chemicals Agency. Retrieved from
https://echa.eiiropa.eii/reeulations/reach/imderstandine-reach. Accessed:
September 5, 2017. EPA-HQ-OW-2015-0665. MF00252.
3. ERG. (2013). Eastern Research Group, Inc. Environmental Engineering Support
for Clean Water Regulations Programmatic Quality Assurance Project Plan
(PQAPP). Chantilly, VA. (October). EPA-HQ-OW-2010-0824-0229.
4. ERG. (2015). Memorandum to Phillip Flanders, U.S. EPA, from Kim Bartell,
ERG. Re: Metal Finishing Preliminary Study: Proposed Approach for Phase I
Review of DMR and TRI Data. (November 6). EPA-HQ-OW-2015-0665.
MF00136.
5. ERG. (2016a). Memrandum to Phillip Flanders, U.S. EPA, and Ryan Novak &
Dan-Tam Nguyen, ERG. Re: Approach for the Review of Metal Products and
Machinery (MP&M) Rulemaking Documentation. (February 22). EPA-HQ-OW-
2015-0665. MF00116.
6. ERG. (2016b). Memorandum to Ahmar Siddiqui, U.S. EPA, and Molly McEvoy
& Dan-Tam Nguyen, ERG. Re: Metal Products and Machinery (MP&M)
Rulemaking Documentation: Screening Review Results and Proposed Approach
for Detailed Review. (September 19). EPA-HQ-OW-2015-0665. MF00117.
7. ERG. (2016c). Memorandum to Phillip Flanders, U.S. EPA, from Anna Dimling
and Kim Bartell, Eastern Reserach Group, Inc. Re: Metal Finishing Preliminary
Study: Phase I Results and Proposed Approach for Phase II Review of DMR and
TRI Data. (January 15). EPA-HQ-OW-2015-0665. MF00137.
8. ERG. (2016d). Memorandum to Phillip Flanders, U.S. EPA, from Dan-Tam
Nguyen, ERG. Re: Quality Assurance Activities for the Selection of the Metal
Finishing Sites and Existing Data Collection During Site Visits-Revision 1.
(February 1). EPA-HQ-OW-2015-0665. MF00287.
9. ERG. (2016e). Memorandum to Phillip Flanders, U.S. EPA, from Dan-Tam
Nguyen, ERG. Re: Quality Assurance Activities for the Collection of Existing
Data to Support the Metal Finishing Preliminary Study - Revision 1. (January 19).
EPA-HQ-OW-2015-0665. MF00115.
10. ERG. (2017a). Memorandum to Ahmar Siddiqui, U.S. EPA, and Anna Dimling,
ERG. Re: Metal Finishing Preliminary Study: Summary of Phase I and Phase II
Review of DMR and TRI Data. (April 7). EPA-HQ-OW-2015-0665. MF00138.
7-1
-------
Section 7—References
11. ERG. (2017b). Memorandum to Ahmar Siddiqui, U.S. EPA, and Molly McEvoy
& Dan-Tarn Nguyen, ERG. Re: Metal Products and Machinery (MP&M)
Rulemaking Preamble: Summary of Industry Comments and EPA Decisions
Related to the Metal Finishing Category. (March 20). EPA-HQ-OW-2015-0665.
MF00162.
12. ERG. (2017c). Memorandum to Ahmar Siddiqui, U.S. EPA, and Molly McEvoy
& Dan-Tam Nguyen, ERG. Re: Metal Products and Machinery (MP&M)
Rulemaking TDD: Review and Comparison of Wastewater Technologies,
Pollutants of Concern, and Pollution Prevention (P2) Practices Considered in the
MP&M and Metal Finishing Rulemakings. (March 10). EPA-HQ-OW-2015-
0665. MF00163.
13. ERG. (2017d). Memorandum to Ahmar Siddiqui, U.S. EPA, and Anna Dimling &
Molly McEvoy, ERG. Re: Results of the Pollution Prevention Data Collection
using E3 Sources and Regional Contacts in the Metal Finishing Industry. (April
21). EPA-HQ-OW-2015-0665. MF00166.
14. ERG. (2017e). Memorandum to Ahmar Siddiqui, U.S. EPA, and Dan-Tam
Nguyen, ERG. Re: Summary of Discussions with Local POTW Pretreatment
Coordinators. (March 7). EPA-HQ-OW-2015-0665. MF00157.
15. ERG. (2017f). Memorandum to Ahmar Siddqui, U.S. EPA, from Adam Orndorff
and Dan-Tam Nguyen, Eastern Research Group, Inc. Re: Results of the Pollution
Prevention Targeted Literature Review for the Metal Finishing Industry (March
22). EPA-HQ-OW-2015-0665. MF00165.
16. ERG. (2017g). Memorandum to Ahmar Siddiqui, U.S. EPA, from Anna Dimling
& Molly McEvoy, ERG. Re: Toxic Release Inventory (TRI) Pollution Prevention
(P2) Data Summary. (March 29). EPA-HQ-OW-2015-0665. MF00125.
17. ERG. (2017h). Memorandum to Ahmar Siddiqui, U.S. EPA, from Molly
McEvoy, ERG. Re: Results of the Targeted Review of the MP&M Comment
Response Document: Pollution Prevention and Wastewater Treatment Practices.
(March 21). EPA-HQ-OW-2015-0665. MF00164.
18. ERG. (2018). Eastern Research Group, Inc. AdditionalDMR/TRIAnalyses
Spreadsheet Supporting the Metal Finishing Preliminary Study. Chantilly, VA.
(April). EPA-HQ-OW-2015-0665. DCNMF00291.
19. ESRC. (2017). Environmental Sustainability Resource Center. Retrieved from
http://esrconline.org/. Accessed: September 5, 2017. EPA-HQ-OW-2015-0665.
MF00253.
20. GLRPPR. (2017). Great Lakes Regional Pollution Prevention Roundtable.
Promoting Pollution Prevention Through Information Exchange. Retrieved from
http ://www. glrppr. org/. Accessed: September 5, 2017. EPA-HQ-OW-2015-0665.
MF00254.
7-2
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21
22
23
24
25
26
27
28
29
30
31
32
Section 7—References
McLay, W. J. (2001). Waste Minimization and Recovery Technologies Metal
Finishing, 99(1): 808-841. (January). EPA-HQ-OW-2015-0665. MF00255.
NASF. (2012). National Association for Surface Finishing Technology Report:
Quarterly Issue Highlights: REACH, Cd, Chromates. (January). EPA-HQ-OW-
2015-0665. MF00256.
NASF. (2017). National Association for Surface Finishing Milwaukee Area
Surface Finishing Industry Metal Loadings Study. (March). EPA-HQ-OW-2015-
0665. MF00257.
NEWMOA. (2013). Northeast States Pollution Prevention Roundtable. P2 and
Sustainability Program Webpage. Retrieved from
http://www.newmoa.ore/prevention/about.cfm. Accessed: September 5, 2017.
EPA-HQ-OW-2015-0665. MF00258.
P2RIC. (2017). Pollution Prevention Regional Information Center. P2RIC
Webpage Resources. Retrieved from https://p2ric.ore/. Accessed: September 5,
2017. EPA-HQ-OW-2015-0665. MF00259.
Peak to Prairies. (2017). Pollution Prevention Information Center for EPA Region
8. Retrieved from http://peaktoprairies.ore/. Accessed: September 5, 2017. EPA-
HQ-OW-2015-0665. MF00260.
PPRC. (2017). Pacific Northwest Pollution Prevention Resource Center.
Retrieved from http://pprc.ore/. Accessed: September 5, 2017. EPA-HQ-OW-
2015-0665. MF00261.
U.S. EPA. (1983). Development Document for Effluent Limitations Guidelines
and New Source Performance Standards for the Metal Finishing Point Source
Category. Washington, D.C. EPA-HQ-OW-2004-0032-0110.
U.S. EPA. (1984). Guidance Manual for Electroplating and Metal Finishing
Pretreatment Standards. Washington, D.C. EPA-HQ-OW-2014-0170-0139.
U.S. EPA. (2000a). Development Document for the Final Effluent Limitations
Guidelines and Standards for the Centralized Waste Treatment Industry - Final.
Washington, D.C. (August). EPA-821-R-00-020. EPA-HQ-OW-2004-0032-
2223.
U.S. EPA. (2000b). Development Document for the Proposed Effluent Limitations
Guidelines and Standards for the Metal Products & Machinery Point Source
Category. Washington, D.C. (December). EPA-HQ-OW-2014-0170-0005.
U.S. EPA. (2001). Federal Register Notice for the Effluent Limitations
Guidelines, Pretreatment Standards, and New Source Performance Standards for
the Metal Products and Machinery Point Source Category; Proposed Rule.
Washington, D.C. (January 3). EPA-HQ-OW-2015-0665. MF00262.
7-3
-------
Section 7—References
33. U.S. EPA. (2003 a). Response to Comments for the Final Effluent Limitations
Guidelines and Standards for the Metal Products & Machinery Point Source
Category. Washington, D.C. (February). EPA-HQ-OW-2015-0665. MF00263.
34. U. S. EPA. (2003b). Federal Register Notice for the Effluent Limitations
Guidelines and New Source Performance Standards for the Metal Products and
Machinery Point Source Category; Final Rule. Washington, D.C. (May 13).
EPA-HQ-OW-2015-0665. MF00264.
35. U.S. EPA. (2015a). The 2014 Annual Effluent Guidelines Review Report.
Washington, D.C. (July). EPA-821-R-15-001. EPA-HQ-OW-2014-0170-0209.
36. U.S. EPA. (2015b). Final 2014 Effluent Guidelines Program Plan. Washington,
D.C. (July). EPA-821 -R-15-002. EPA-HQ-OW-2014-0170-0210.
37. U.S. EPA. (2015c). Fact Sheet: 2015: Definition of Solid Waste (DSW) Final
Rule. Washington, D.C. EPA-HQ-OW-2015-0665. MF00265.
38. U.S. EPA. (2016a). Preliminary Study of the Metal Finishing Category: 2015
Status Report. Washington, D.C. (June). EPA-821-R-16-004. EPA-HQ-OW-
2015-0665-0303.
39. U.S. EPA. (2016b). DMR Parameter and TRI Chemical Toxic Weighting Factors.
Washington, D.C. (September). EPA-HQ-OW-2015-0665. MF00266.
40. U.S. EPA. (2016c). Memorandum to the Record, from U.S. EPA. Re: Pollution
Prevention Research and Implementation for Michigan Metal Finishers Project
Kickoff Meeting Summary. (November 29). EPA-HQ-OW-2015-0665. MF00269.
41. U.S. EPA. (2017). Pollution Prevention (P2) and TRI Webpage. Retrieved from
https://www.epa.gov/toxics-release-inventorv-tri-program/pollution-prevention-
p2-and-tri. Accessed: August 15, 2017. EPA-HQ-OW-2015-0665. MF00271.
42. U.S. EPA. (2018a). Memorandum to the Record, from U.S. EPA. Re:
Conversation with EPA Regional Pretreatment Coordinators on December 7,
2016 regarding the Metal Finishing Study. (April 10). EPA-HQ-OW-2015-0665.
MF00267.
43. U.S. EPA. (2018b). Memorandum to the Record, from U.S. EPA. Re:
Conversations with NASF regarding the Metal Finishing Study. (March 12).
EPA-HQ-OW-2015-0665. MF00268.
44. U.S. EPA. (2018c). Memorandum to the Record, from U.S. EPA. Re:
Conversations with NACWA on March 8, 2016 regarding the Metal Finishing
Study. (March 14). EPA-HQ-OW-2015-0665. MF00270.
45. U.S. EPA. (2018d). Response to Comment for the Preliminary 2016 Effluent
Guidelines Program Plan. Washington, D.C. (April). EPA-HQ-OW-2015-0665.
DCN 08521.
7-4
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Section 7—References
46. WSPPN. (2017). Western Sustainability and Pollution Prevention Network.
Pollution Prevention Information by Sector. Retrieved from http://wsppn.org/p2-
training/pollution-prevention-infonnation-bv-sector/. Accessed: September 5,
2017. EPA-HQ-OW-2015-0665. MF00272.
47. ZWN. (2017). Zero Waste Network. Center for Environmental Excellence.
Retrieved from http://www.zerowastenetwork.org/. Accessed: September 5, 2017.
EPA-HQ-OW-2015-0665. MF00273.
7-5
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Appendix A
Appendix A:
SIC and NAICS Codes for the Metal Finishing Industry
Table A-l. List of SIC Codes Assigned to the Metal Finishing Category by the 304(m) Annual
Review
Table A-2. List of NAICS Codes Assigned to the Metal Finishing Category by the 304(m)
Annual Review
-------
THIS PAGE INTENTIONALLY LEFT BLANK.
-------
Appendix A
Table A-l. List of SIC Codes Assigned to the Metal Finishing Category by the 304(m)
Annual Review
SIC Code
SIC" Cock- Description
2514
METAL HOUSEHOLD FURNITURE
2522
METAL OFFICE FURNITURE
2531
PUBLIC BUILDING/RELATED FURNIT
2542
METAL PARTI, SHELF. LOCKERS
2591
DRAPE HARDWARE/WINDOW BLINDS
2599
FURNITURE AND FIXTURES, NEC
2796
PLATEMAKING SERVICES
3398
METAL HEAT TREATING
3412
METAL BARRELS, DRUMS AND PAILS
3421
CUTLERY
3423
HAND AND EDGE TOOLS, NEC
3425
HAND SAWS AND SAW BLADES
3429
HARDWARE, NEC
3431
METAL SANITARY WARE
3432
PLUMB FIXTURE FITTINGS & TRIM
3433
HEATING EQUIP, EXCEPT ELECTRIC
3441
FABRICATED STRUCTURAL METAL
3442
METAL DOORS, SASH, AND TRIM
3443
FAB PLATE WORK (BOILER SHOPS)
3444
SHEET METAL WORK
3446
ARCHITECTURAL METAL WORK
3448
PREFABRICATED METAL BUILDINGS
3449
MISC. STRUCTUAL METAL WORK
3451
SCREW MACHINE PRODUCTS
3452
BOLTS, NUTS, RIVETS & WASHERS
3462
IRON AND STEEL FORGINGS
3465
AUTOMOTIVE STAMPINGS
3466
CROWNS AND CLOSURES
3479
METAL COATING & ALLIED SERVIC
3482
SMALL ARMS AMMUNITION
3483
AMMUNIT., EXC. FOR SMALL ARMS
3484
SMALL ARMS
3489
ORDNANCE AND ACCESSORIES, NEC
3491
INDUSTRIAL VALVES
3492
FLUID POWER VALVES & HOSE FITT
3493
STEEL SPRINGS, EXCEPT WIRE
3494
VALVES AND PIPE FITTINGS, NEC
3495
WIRE SPRINGS
3496
MISC. FABRICATED WIRE PRODUCTS
3497
METAL FOIL AND LEAF
3498
FABRICATED PIPE AND FITTINGS
3499
FABRICATED METAL PRODUCTS NEC
3511
TURBINES & TURBINE GENERATOR
3519
INTERNAL COMBUSTION ENGINES,
3523
FARM MACHINERY AND EQUIPMENT
3524
LAWN AND GARDEN EQUIPMENT
3531
CONSTRUCTION MACHINERY
3532
MINING MACHINERY
3533
OIL FIELD MACHINERY
A-l
-------
Appendix A
Table A-l. List of SIC Codes Assigned to the Metal Finishing Category by the 304(m)
Annual Review
Sl( ( ode
SIC" Cock- Description
3534
ELEVATORS AND MOVING STAIRWAYS
3535
CONVEYORS & CONVEYING EQUIPMEN
3536
CRANES/HOISTS/MONORAIL SYSTEMS
3537
INDUSTRIAL TRUCKS AND TRACTORS
3541
MACHINE TOOLS, METAL CUTTING
3542
MACHINE TOOLS, METAL FORMING
3543
INDUSTRIAL PATTERNS
3544
SPECIAL DIES/TOOLS/JIGS & FIXT
3545
MACHINE TOOL ACCESSORIES
3546
POWER DRIVEN HAND TOOLS
3547
ROLLING MILL MACHINERY
3548
WELDING APPARATUS
3549
METAL WORKING MACHINERY, NEC
3552
TEXTILE MACHINERY
3553
WOODWORKING MACHINERY
3554
PAPER INDUSTRIES MACHINERY
3555
PRINTING TRADES MACHINERY
3556
FOOD PRODUCTS MACHINERY
3559
SPECIAL INDUSTRY MACHINERY, NEC
3561
PUMPS AND PUMPING EQUIPMENT
3562
BALL AND ROLLER BEARINGS
3563
AIR AND GAS COMPRESSORS
3564
BLOWER AND FANS
3565
PACKAGING MACHINERY
3566
SPEED CHANGERS, DRIVES & GEARS
3567
INDUSTRIAL FURNACES AND OVENS
3568
POWER TRANSMISSION EQUIPMENT
3569
GENERAL INDUSTRIAL MACHINERY
3571
ELECTRONIC COMPUTERS
3572
COMPUTER STORAGE DEVICES
3575
COMPUTER TERMINALS
3577
COMPUTER PERIPHERAL EQUIP,NEC
3578
CALC & ACCOUNTING EQUIPMENT
3579
OFFICE MACHINES
3581
AUTOMATIC MERCHANDISING MACHIN
3582
COMMERCIAL LAUNDRY EQUIPMENT
3585
REFRIGERATION & HEATING EQUIP
3586
MEASURING & DISPENSING PUMPS
3589
SERVICE INDUSTRY MACHINERY
3592
CARBURETORS, PISTONS, RINGS, VALV
3593
FLUID POWER CYLINDERS & ACTUAT
3594
FLUID POWER PUMPS AND MOTORS
3596
SCALES AND BALANCES, EXC. LAB
3599
INDUSTRIAL MACHINERY, NEC
3612
TRANSFORMERS
3613
SWITCHGEAR & SWITCHBOARD APPAR
3621
MOTORS AND GENERATORS
3624
CARBON AND GRAPHITE PRODUCTS
3625
RELAYS AND INDUSTRIAL CONTROLS
A-2
-------
Appendix A
Table A-l. List of SIC Codes Assigned to the Metal Finishing Category by the 304(m)
Annual Review
Sl( ( ode
SIC" Cock- Description
3629
ELECTRICAL INDUSTRIAL APPARATS
3632
HOUSEHOLD REFRIG. & FREEZERS
3633
HOUSEHOLD LAUNDRY EQUIPMENT
3634
ELECTRIC HOUSEWARES AND FANS
3635
HOUSEHOLD VACUUM CLEANERS
3639
HOUSEHOLD APPLIANCES, NEC
3641
ELECTRIC LAMPS
3643
CURRENT-CARRYING WIRING DEVICE
3644
NONCURRENT-CARRYING WIRING DEV
3645
RESIDENTIAL LIGHTING FIXTURES
3646
COMMERCIAL LIGHTING FIXTURES
3647
VEHICULAR LIGHTING EQUIPMENT
3648
LIGHTING EQUIPMENT, NEC
3651
RADIO AND TV RECEIVING SETS
3652
PHONOGRAPH RECORDS
3661
TELEPHONE/TELEGRAPH APPARATUS
3663
RADIO & TV COMMUNICATION EQUIP
3669
COMMUNICATIONS EQUIPMENT, NEC.
3672
PRINTED CIRCUT BOARD
3675
ELECTRONIC CAPACITORS
3676
RESISTORS FOR ELEC APPLICATION
3677
ELEC COILS, TRANSF. & INDUCTOR
3678
CONNECTORS FOR ELEC APPLICATIO
3679
ELECTRONIC COMPONENTS, NEC
3694
ELEC EQUIP FOR INT COMBUS ENGI
3695
MAG & OPTICAL RECORDING MEDIA
3699
ELEC MACHINERY, EQUIP & SUPPLIE
3711
MOTOR VEHICLES & CAR BODIES
3713
TRUCK & BUS BODIES
3714
MOTOR VEHICLE PARTS & ACCESSOR
3715
TRUCK TRAILERS
3716
MOTOR HOMES
3721
AIRCRAFT
3724
AIRCRAFT ENGINES & ENGINE PART
3728
AIRCRAFT PARTS AND EQUIP, NEC
3731
SHIP BUILDING AND REPAIRING
3732
BOAT BUILDING AND REPAIRING
3743
RAILROAD EQUIPMENT
3751
MOTORCYCLES, BICYCLES AND PART
3761
GUIDED MISSILES & SPACE VEHICL
3764
SPACE PROPULSION UNITS & PARTS
3769
SPACE VEHICLE EQUIPMENT, NEC
3792
TRAVEL TRAILERS AND CAMPERS
3795
TANKS AND TANK COMPONENTS
3799
TRANSPORTATION EQUIPMENT, NEC
3812
SEARCH & NAVIGATION EQUIPMENT
3821
LAB APPARATUS & FURNITURE
3822
ENVIRONMENTAL CONTROLS
3823
PROCESS CONTROL INSTRUMENTS
A-3
-------
Appendix A
Table A-l. List of SIC Codes Assigned to the Metal Finishing Category by the 304(m)
Annual Review
Sl( ( ode
SIC" Cock- Description
3824
FLUID METERS & COUNTING DEVICE
3825
INSTRUMENTS TO MEASURE ELECTRI
3826
ANALYTICAL INSTRUMENTS
3827
OPTICAL INSTRUMENTS AND LENSES
3829
MEASURING & CONTROLLING DEVICE
3841
SURGICAL & MEDICAL INSTRUMENTS
3842
SURGICAL APPLIANCES & SUPPLIES
3843
DENTAL EQUIPMENT AND SUPPLIES
3844
X-RAY APPARATUS AND TUBES
3845
ELECTROMEDICAL EQUIPMENT
3851
OPHTHALMIC GOODS
3861
PHOTOGRAPHIC EQUIP & SUPPLIES
3873
WATCHES, CLOCKS & WATCHCASES
3911
JEWELRY, PRECIOUS METAL
3914
SILVERWARE AND PLATED WARE
3915
JEWELERS' MATERIALS & LAPIDARY
3931
MUSICAL INSTRUMENTS
3944
GAMES, TOYS & CHILDREN'S VEHIC
3949
SPORTING & ATHLETIC GOODS, NEC
3951
PENS & MECHANICAL PENCILS
3953
MARKING DEVICES
3961
COSTUME JEWELRY
3965
FASTENERS, BUTTONS, NEEDLES
3993
SIGNS AND ADVERTISING DISPLAYS
3995
BURIAL CASKETS
3999
MANUFACTURING INDUSTRIES, NEC
4011
RAILROADS, LINE HAUL OPERATING
4013
RAILROAD SWTCHING & TERM ESTAB
7692
WELDING REPAIR
3469
METAL STAMPINGS, NEC
3471
PLATING AND POLISHING
A-4
-------
Appendix A
Table A-2. List of NAICS Codes Assigned to the Metal Finishing Category by the 304(m)
Annual Review
NAICS Cock-
NAICS Cock- Ik-scriplicin
3 3 y 114
Denial Equipment and Supplier Manufacturing
339115
Ophthalmic Goods Manufacturing
339911
Jewelry (except Costume) Manufacturing
339912
Silverware and Hollowware Manufacturing
339913
Jewelers' Material and Lapidary Work Manufacturing
339914
Costume Jewelry and Novelty Manufacturing
339920
Sporting and Athletic Goods Manufacturing
339941
Pen and Mechanical Pencil Manufacturing
339943
Marking Device Manufacturing
339950
Sign Manufacturing
339992
Musical Instrument Manufacturing
339993
Fastener, Button, Needle, and Pin Manufacturing
339995
Burial Casket Manufacturing
339999
All Other Miscellaneous Manufacturing
482111
Line-Haul Railroads
482112
Short Line Railroads
332112MF
Nonferrous Forging (Metal Finishing)
332993MF
Small Arms Ammunition Manufacturing (Metal Finishing)
332999DC
All Other Miscellaneous Fabricated Metal Product Manufacturing (DC)
811310
Commercial and Industrial Machinery and Equipment (except Automotive and Electronic)
Repair and Maintenance
512220
Integrated Record Production/Distribution
325510ELEC
Paint and Coating Manufacturing (Electroplating)
326199ELEC
All Other Plastics Product Manufacturing (Electroplating)
331221ELEC
Rolled Steel Shape Manufacturing (Electroplating)
336340ELEC
Motor Vehicle Brake System Manufacturing (Electroplating)
331111MF
Iron and Steel Mills (Metal Finishing)
331314MF
Secondary Smelting and Alloying of Aluminum (Metal Finishing)
331491MF
Nonferrous Metal (except Copper and Aluminum) Rolling, Drawing, and Extruding (Metal
Finishing)
322225
Laminated Aluminum Foil Manufacturing for Flexible Packaging Uses
323122
Prepress Services
325992
Photographic Film, Paper, Plate, and Chemical Manufacturing
325998MF
All Other Miscellaneous Chemical Product and Preparation Manufacturing (Metal Finishing)
326199MF
All Other Plastics Product Manufacturing (Metal Finishing)
332111
Iron and Steel Forging
332114
Custom Roll Forming
332115
Crown and Closure Manufacturing
332116
Metal Stamping
332117
Powder Metallurgy Part Manufacturing
332211
Cutlery and Flatware (except Precious) Manufacturing
332212
Hand and Edge Tool Manufacturing
332213
Saw Blade and Handsaw Manufacturing
332214
Kitchen Utensil, Pot, and Pan Manufacturing
332311
Prefabricated Metal Building and Component Manufacturing
332312
Fabricated Structural Metal Manufacturing
332313
Plate Work Manufacturing
332321
Metal Window and Door Manufacturing
332322
Sheet Metal Work Manufacturing
A-5
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Appendix A
Table A-2. List of NAICS Codes Assigned to the Metal Finishing Category by the 304(m)
Annual Review
NAICS Code
NAICS ( ode Deseriplion
^ ^ ^ ^
Ornamental and Ai'dukvlural \lclal Work Maiiul'aclunng
332410
Power Boiler and Heat Exchanger Manufacturing
332420
Metal Tank (Heavy Gauge) Manufacturing
332439
Other Metal Container Manufacturing
332510
Hardware Manufacturing
332611
Spring (Heavy Gauge) Manufacturing
332612
Spring (Light Gauge) Manufacturing
332618
Other Fabricated Wire Product Manufacturing
332710
Machine Shops
332721
Precision Turned Product Manufacturing
332722
Bolt, Nut, Screw, Rivet, and Washer Manufacturing
332811
Metal Heat Treating
332812
Metal Coating, Engraving (except Jewelry and Silverware), and Allied Services to
Manufacturers
332813
Electroplating, Plating, Polishing, Anodizing, and Coloring
332813MF
Electroplating, Plating, Polishing, Anodizing, and Coloring (Metal Finishing)
332911
Industrial Valve Manufacturing
332912
Fluid Power Valve and Hose Fitting Manufacturing
332913
Plumbing Fixture Fitting and Trim Manufacturing
332919
Other Metal Valve and Pipe Fitting Manufacturing
332991
Ball and Roller Bearing Manufacturing
332992
Small Arms Ammunition Manufacturing
332993
Ammunition (except Small Arms) Manufacturing
332994
Small Arms Manufacturing
332995
Other Ordnance and Accessories Manufacturing
332996
Fabricated Pipe and Pipe Fitting Manufacturing
332998
Enameled Iron and Metal Sanitary Ware Manufacturing
332999
All Other Miscellaneous Fabricated Metal Product Manufacturing
333111
Farm Machinery and Equipment Manufacturing
333112
Lawn and Garden Tractor and Home Lawn and Garden Equipment Manufacturing
333120
Construction Machinery Manufacturing
333131
Mining Machinery and Equipment Manufacturing
333132
Oil and Gas Field Machinery and Equipment Manufacturing
333210
Sawmill and Woodworking Machinery Manufacturing
333220
Plastics and Rubber Industry Machinery Manufacturing
333291
Paper Industry Machinery Manufacturing
333292
Textile Machinery Manufacturing
333293
Printing Machinery and Equipment Manufacturing
333294
Food Product Machinery Manufacturing
333295
Semiconductor Machinery Manufacturing
333298
All Other Industrial Machinery Manufacturing
333311
Automatic Vending Machine Manufacturing
333312
Commercial Laundry, Drycleaning, and Pressing Machine Manufacturing
333313
Office Machinery Manufacturing
333314
Optical Instrument and Lens Manufacturing
333315
Photographic and Photocopying Equipment Manufacturing
333319
Other Commercial and Service Industry Machinery Manufacturing
333411
Air Purification Equipment Manufacturing
333412
Industrial and Commercial Fan and Blower Manufacturing
A-6
-------
Appendix A
Table A-2. List of NAICS Codes Assigned to the Metal Finishing Category by the 304(m)
Annual Review
NAICS Code
NAICS ( ode Deseriplion
333414
Healing Equipment (c\cepi Warm Air I'uriuiccsj Muiiulucluiiiig
333415
Air-Conditioning and Warm Air Heating Equipment and Commercial and Industrial
Refrigeration Equipment Manufacturing
333511
Industrial Mold Manufacturing
333512
Machine Tool (Metal Cutting Types) Manufacturing
333513
Machine Tool (Metal Forming Types) Manufacturing
333514
Special Die and Tool, Die Set, Jig, and Fixture Manufacturing
333515
Cutting Tool and Machine Tool Accessory Manufacturing
333516
Rolling Mill Machinery and Equipment Manufacturing
333518
Other Metalworking Machinery Manufacturing
333611
Turbine and Turbine Generator Set Units Manufacturing
333612
Speed Changer, Industrial High-Speed Drive, and Gear Manufacturing
333613
Mechanical Power Transmission Equipment Manufacturing
333618
Other Engine Equipment Manufacturing
333911
Pump and Pumping Equipment Manufacturing
333912
Air and Gas Compressor Manufacturing
333913
Measuring and Dispensing Pump Manufacturing
333921
Elevator and Moving Stairway Manufacturing
333922
Conveyor and Conveying Equipment Manufacturing
333923
Overhead Traveling Crane, Hoist, and Monorail System Manufacturing
333924
Industrial Truck, Tractor, Trailer, and Stacker Machinery Manufacturing
333991
Power-Driven Handtool Manufacturing
333992
Welding and Soldering Equipment Manufacturing
333993
Packaging Machinery Manufacturing
333994
Industrial Process Furnace and Oven Manufacturing
333995
Fluid Power Cylinder and Actuator Manufacturing
333996
Fluid Power Pump and Motor Manufacturing
333997
Scale and Balance Manufacturing
333999
All Other Miscellaneous General Purpose Machinery Manufacturing
334111
Electronic Computer Manufacturing
334112
Computer Storage Device Manufacturing
334119
Other Computer Peripheral Equipment Manufacturing
334210
Telephone Apparatus Manufacturing
334220
Radio and Television Broadcasting and Wireless Communications Equipment Manufacturing
334290
Other Communications Equipment Manufacturing
334310
Audio and Video Equipment Manufacturing
334412
Bare Printed Circuit Board Manufacturing
334414
Electronic Capacitor Manufacturing
334415
Electronic Resistor Manufacturing
334416
Electronic Coil, Transformer, and Other Inductor Manufacturing
334417
Electronic Connector Manufacturing
334418
Printed Circuit Assembly (Electronic Assembly) Manufacturing
334419
Other Electronic Component Manufacturing
334510
Electromedical and Electrotherapeutic Apparatus Manufacturing
334511
Search, Detection, Navigation, Guidance, Aeronautical, and Nautical System and Instrument
Manufacturing
334512
Automatic Environmental Control Manufacturing for Residential, Commercial, and Appliance
Use
A-7
-------
Appendix A
Table A-2. List of NAICS Codes Assigned to the Metal Finishing Category by the 304(m)
Annual Review
NAICS Code
NAICS ( ode Deseriplion
334513
Illsll'lllllCllls and Related I'l'odllCls Manufacturing lor Measuring, Displacing, Mild ( \illlrolllllg
Industrial Process Variables
334514
Totalizing Fluid Meter and Counting Device Manufacturing
334515
Instrument Manufacturing for Measuring and Testing Electricity and Electrical Signals
334516
Analytical Laboratory Instrument Manufacturing
334517
Irradiation Apparatus Manufacturing
334518
Watch, Clock, and Part Manufacturing
334519
Other Measuring and Controlling Device Manufacturing
334612
Prerecorded Compact Disc (except Software), Tape, and Record Reproducing
334613
Magnetic and Optical Recording Media Manufacturing
335110
Electric Lamp Bulb and Part Manufacturing
335121
Residential Electric Lighting Fixture Manufacturing
335122
Commercial, Industrial, and Institutional Electric Lighting Fixture Manufacturing
335129
Other Lighting Equipment Manufacturing
335211
Electric Housewares and Household Fan Manufacturing
335212
Household Vacuum Cleaner Manufacturing
335222
Household Refrigerator and Home Freezer Manufacturing
335224
Household Laundry Equipment Manufacturing
335228
Other Major Household Appliance Manufacturing
335311
Power, Distribution, and Specialty Transformer Manufacturing
335312
Motor and Generator Manufacturing
335313
Switchgear and Switchboard Apparatus Manufacturing
335314
Relay and Industrial Control Manufacturing
335931
Current-Carrying Wiring Device Manufacturing
335932
Noncurrent-Carrying Wiring Device Manufacturing
335991
Carbon and Graphite Product Manufacturing
335999
All Other Miscellaneous Electrical Equipment and Component Manufacturing
336111
Automobile Manufacturing
336112
Light Truck and Utility Vehicle Manufacturing
336120
Heavy Duty Truck Manufacturing
336211
Motor Vehicle Body Manufacturing
336212
Truck Trailer Manufacturing
336213
Motor Home Manufacturing
336214
Travel Trailer and Camper Manufacturing
336311
Carburetor, Piston, Piston Ring, and Valve Manufacturing
336312
Gasoline Engine and Engine Parts Manufacturing
336321
Vehicular Lighting Equipment Manufacturing
336322
Other Motor Vehicle Electrical and Electronic Equipment Manufacturing
336330
Motor Vehicle Steering and Suspension Components (except Spring) Manufacturing
336340
Motor Vehicle Brake System Manufacturing
336350
Motor Vehicle Transmission and Power Train Parts Manufacturing
336360MF
Motor Vehicle Seating and Interior Trim Manufacturing (Metal Finishing)
336370
Motor Vehicle Metal Stamping
336391
Motor Vehicle Air-Conditioning Manufacturing
336399
All Other Motor Vehicle Parts Manufacturing
336411
Aircraft Manufacturing
336412
Aircraft Engine and Engine Parts Manufacturing
336413
Other Aircraft Parts and Auxiliary Equipment Manufacturing
336414
Guided Missile and Space Vehicle Manufacturing
A-8
-------
Appendix A
Table A-2. List of NAICS Codes Assigned to the Metal Finishing Category by the 304(m)
Annual Review
NAICS Cock-
NAICS Cock- Ik-scriplicin
-<415
Guided Missile ;ind Space \'eliicle h'opulsion L ml ;ind h'opulsion L ml Purls MniiulMclui'iiig
336510
Railroad Rolling Stock Manufacturing
336611
Ship Building and Repairing
336612
Boat Building
336991
Motorcycle, Bicycle, and Parts Manufacturing
336992
Military Armored Vehicle, Tank, and Tank Component Manufacturing
336999
All Other Transportation Equipment Manufacturing
337124
Metal Household Furniture Manufacturing
337127
Institutional Furniture Manufacturing
337214
Office Furniture (except Wood) Manufacturing
337215
Showcase, Partition, Shelving, and Locker Manufacturing
337920
Blind and Shade Manufacturing
339111
Laboratory apparatus and furniture manufacturing
339112
Surgical and Medical Instrument Manufacturing
339113
Surgical Appliance and Supplies Manufacturing
A-9
-------
Appendix B
Appendix B:
Pollution Prevention (P2) Practices Identified in EPA's P2 Review
-------
THIS PAGE INTENTIONALLY LEFT BLANK.
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Appendix B
Table B-l. Pollution Prevention (P2) Practices Identified from EPA's P2 Review
P2 Practice
Dcscriplion/I- rcipicnlh
Reported r.xamplcs
Dala Source
TRI Data 1
l.ilcralurc
Search h
MPJsM
CUD''
1.3/ Ueuional P2
Resources'"
Process Tcchnolom Controls iiiul Allcrnali\cs
Water conservation practices
Reduce the volume of water required to
clean or rinse parts (e.g., countercurrent
rinses, conductivity controls, reduced
flow processes, in-process flow controls).
V
V
V
V
Process changes
Alter existing process operations to
reduce waste generation (e.g., in-tank
filtration of process fluids, conversion of
liquid coatings to powder coatings,
chromium emission controls).
V
V
V
V
Recycle scrap materials
Recycle defective parts and solder.
V

Methods to reduce dragout
Remove dragout from parts (e.g., air
knives, pinch/sponge rollers) or direct
dragout back to process tanks (e.g., drip
shields) to prevent transfer of dragout to
rinse tanks.
V
V
V

Methods to increase throughput
efficiency
Modify process scheduling or tank layout.
V
V

V
Alternative Process Chemistries
Replace solvent-based coating with
water-based coatings
Water-based coatings generally generate
less hazardous waste and are more easily
treated.
V

V
V
Conversion to lead-free solvents and
lead-free anodes
Lead-free solder (e.g., tin, silver/tin),
lead-free zinc for galvanizing, lead-free
tape (e.g., aluminum), and lead-free
finishes.
V

Replace cyanide-bearing processes
with non-cyanide processes
Convert cyanide base to alkaline base in
zinc processing tanks.
V

V
V
Replace hexavalent chromium-bearing
process solutions with alternatives
Replace hexavalent chromium plating
with trivalent chromium plating, metallic
electroplating, or alloy electroplating.
V
V

V
B-l
-------
Appendix B
Table B-l. Pollution Prevention (P2) Practices Identified from EPA's P2 Review
P2 l»r;ic(icc
Description/I- rc(|ucu(l\
Reported l.\;unplcs
Diilii Source
TUI Diilii '
l.ilcmlurc
Sciirch h
MIViM
CUD''
1.3/ Ucuioiiiil l>2
Resources •'
Replace coating chemicals with low or
non-VOC products
Replace coatings containing xylene with
low VOC products. Replace methanol in
coatings with non-VOC chemicals.
V

\\;is(c\\;Mcr Uooclc. M;ilcri;ils Ucco\cn :iikI 1 rc;i(mcii( Al(cru;ili\cs
Segregation of wastewater and
treatment for recycling/reuse.
Capture chromium-containing wastewater
for use in chromium electroplating baths.
V
V
V

Recycle/reuse spent cleaners and
solvent
Recycle/reuse ethylene glycol, methyl
isobutyl ketone, isopropyl alcohol,
methanol, hydraulic oil, coolant (via
centrifuge or ultrafiltration), xylene, and
vapor degreasing solvents (containing
trichloroethylene).
V
V

V
Recover materials from wastewater
Recycle non-process cooling water,
recover precious metals from
electro winning, recover metals from
sludge byproducts, and recover copper or
chrome in recovery units.
V
V
V
V
Regenerate spent plating baths
Regenerate spent plating baths using
electrowinning systems, crystallization of
salts, evaporation, and/or microfiltration.
Bath regeneration is infrequent because
chemical suppliers and customers require
strict specifications for bath plating
formulations.

V
V
V
Use of alternative treatment chemicals
Replace ferrous sulfate/caustic soda with
sodium bisulfite, which reduces amount
of sludge generated. Incorporate clay-
based products that absorb oils,
surfactants, and many organic compounds
from metal finishing wastewater.
V
V

B-2
-------
Appendix B
Table B-l. Pollution Prevention (P2) Practices Identified from EPA's P2 Review
P2 l»r;ic(icc
Description/I- rc(|ucu(l\
Reported l.\;unplcs
Diilii Source
TRI Diilii '
l.ilcmlurc
Sciirch h
MP&M
CUD''
1.3/ Ucuioiiiil l>2
Resources •'
Additional wastewater treatment
beyond the Metal Finishing BAT
Process water recycle, ion exchange,
ultrafiltration, dissolved air flotation, sand
filtration, reverse osmosis, evaporation/
distillation, electrodialysis, and
electrowinning.

V
Zero discharge through a multi-step
approach to wastewater treatment
Evaporation, segregated waste stream
treatment, reverse osmosis, ion exchange,
carbon filtration, and/or distillation.

BAT: Best Available Technology Economically Achievable
CRD: Comment Response Document
E3: Economy - Energy - Environment
MP&M: Metal Products & Machinery
TRI: Toxic Release Inventory
VOC: Volatile Organic Compound
a Reference: U.S. EPA. (2017). Pollution Prevention (P2) and TRI Webpage. Retrieved from https://www.epa.gov/toxics-release-inventory-tri-
program/pollution-prevention-p2-and-tri. Accessed: August 15, 2017. EPA-HQ-OW-2015-0665. MF00271.
b References:
• Andrus, M. E. (2000). A Review of Metal Precipitation Chemicals for Metal-finishing Applications. Metal Finishing, 9H( 11): 20-23. (November). EPA-
HQ-0W-2015-0665. MF00274.
• Baral, A., & Engelken, R. D. (2002). Chromium-based Regulations and Greening in Metal Finishing Industries in the USA. Environmental Science &
Policy, 5(2): 121-133. (April). EPA-HQ-OW-2015-0665. MF00275.
• McLay, W. J. (2001). Waste Minimization and Recovery Technologies Metal Finishing, 99(1): 808-841. (January). EPA-HQ-OW-2015-0665.
MF00255.
• Park, E., et al. (2002). Pollution Prevention in a Zinc Die Casting Company: a 10-year Case Study. Journal of Cleaner Production, 10(1): 93-99.
(February). EPA-HQ-OW-2015-0665. MF00280.
• Petrinic I., et al. (2015). A Feasibility Study of Ultrafiltration/Reverse Osmosis (UF/RO)-Based Wastewater Treatment and Reuse in the Metal Finishing
Industry. Journal of Cleaner Production, 101(15): 292-300. (August). EPA-HQ-OW-2015-0665. MF00281.
• Sharma, V. K., et al. (2008). Ferrate(VI) and Ferrate(V) Oxidation of Cyanide, Thiocyanate, and Copper(I) Cyanide. Radiation Physics and Chemistry,
77(6): 761-767. (June). EPA-HQ-OW-2015-0665. MF00282.
• Xiao, J., & Huang, Y. (2012). Technology Integration for Sustainable Manufacturing: An Applied Study on Integrated Profitable Pollution Prevention in
Surface Finishing Systems. Industrial & Engineering Chemistry Research, 51(35): 11,434-411,444. (August). EPA-HQ-OW-2015-0665. MF00285.
• Yngard, R., et al. (2007). Ferrate(VI) Oxidation of Zinc-Cyanide Complex. Chemosphere, 69(5): 729-735. (October). EPA-HQ-OW-2015-0665.
MF00286.
B-3
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Appendix B
0 Reference: U.S. EPA. (2003). Response to Comments for the Final Effluent Limitations Guidelines and Standards for the Metal Products & Machinery Point
Source Category. Washington, D.C. (February). EPA-HQ-OW-2015-0665. MF00263.
d References:
• NYSP2i. (2010). New York State Pollution Prevention Institute Metal Finishing Workshop. (March 4). EPA-HQ-OW-2015-0665. MF00276.
• NYSP2i. (201 la). New York State Pollution Prevention Institute Metal Finishing Workshop. (February 9). EPA-HQ-OW-2015-0665. MF00277.
• NYSP2i. (201 lb). New York State Pollution Prevention Institute Metal Finishing Presentation: How to Save on Alkaline Cleaners, Acids, and Rinse
Water. (May 10). EPA-HQ-OW-2015-0665. MF00278.
• NYSP2i. (2014). Metal Finishing Webinar presented by The New York State Pollution Prevention Institute P2 Webinar (NYSP2i) and the Toxic Use
Reduction Institute (TUTI): The Business Value of Improved Environmental Performance in Metal Finishing. Retrieved from
https://www.youtube.com/watch?v=AiezsJ9wn_c. Accessed: August 16, 2017. EPA-HQ-OW-2015-0665. MF00279.
• U.S. EPA. (2017a). E3 Success Stories. Retrieved from https://www.epa.gov/e3/e3-success-stories. Accessed: August 15, 2017. EPA-HQ-OW-2015-
0665. MF00283.
• U.S. EPA. (2017b). EPA Region 9, Metal Finishing Pollution Prevention. Retrieved from https://www3.epa.gov/region9/waste/p2/projects/metal.html.
Accessed: September 5, 2017. EPA-HQ-OW-2015-0665. MF00284.
B-4
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