United States
Environmental Protection
Agency ,
Office of Water
Mail Code 4303
Washington, DC 20460
EPA-821-R-94-O06
December 1994 .
SERA
Preliminary Data Summary
for the
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Metal Finishing Industry
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PRELIMINARY DATA SUMMARY
'• ' • ' I
of the i
METAL FINISHING INDUSTRY 1
Engineering and Analysis Division j
Office of Water ;
United States Environmental Protection Agency;
401 M Street, SW :|
Washington, DC 20460
October 1994
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. PREFACE
This Preliminary Data Summary was prepared by the
Division of the U.S. Environmental Protection Agency (EPA). This
of EPA under the Consent Decree in NRDC v EPA. No. 89-2980 (D.
Engineering and Analysis
sti dy fulfills an obligation
Cir.).
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ACKNOWLEDGEMENTS ""•_•
Preparation of this Preliminary Data Summary was directed by Baldwin M. Jarrett, Project
Officer, of the Engineering and Analysis Division.
Additional copies of this document may be obtained by writing to the following address:
Engineering and Analysis Division (4303)
U.S. Environmental Protection Agency
, 401 M Street, S.W. ;
Washington, D.C. 20460 ! ,
Telephone (202) 260-0171
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TABLE OF CONTENTS
PAGE
1.0
2.0
3.0
4.0
5.0
FOREWORD . ...... .......... 1-1
SUMMARY . . . . . . . . . ...;.'.. ..j. ..... . .;. ... . 2-1
HISTORY OF THE REGULATIONS ....;.. . .•. . . . . . . . 3-1
3.1
3.2
3.3
Statute and Consent Decrees 3-1
Regulatory Overview , '••-.. • • • 3-2
3.2.1 Electroplating and Metal Finishing Point Source
Categories
3.2.2 Metal Products and Machinery Point Source
Category
Data and Information Gathering
3.3.1 Electroplating and Metal Finishing Point Source
Categories
.... 3-2
.... 3-6
.... 3-8
.'.... 3-9
3.3.2 Metal Products and Machinery Categoiy . . .......: 3-1.1
DEVELOPMENT OF TECHNICAL AND ECONOMIC
ELECTROPLATING AND METAL FINISHING .
4.1 Wastewater Characterization
4.2 Control and Treatment Technology ......
4.3 Economics . .
4.4 . Effluent Limitations in the Effluent Guidelines
Standards for 40 CFR Part 413 Electroplating
CFR Part 433 Metal Finishing ..:...
4.4 1 Electroplating Point Source Category .
4.4.2 Metal Finishing Point Source Category
PRACTICALITY AND USE ......
5.1 Applicability and Use
5.1.1 Electroplating/Metal Finishing Industry
5.1.2 Metal Products and Machinery
5.2 Overlap of Metal Finishing and Metal Products and
Machinery
ASSESSMENT OF
____ ..... . . 4-1
____ : . ____ : 4-1
. ____ . . : .'. : 4-2
and
and 40
4-3
4-3
4-6
5-1
• 5-1
5-1
5-5
5-6
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LIST OF TABLES
PAGE
Table 3-1
Table 3-2
Table 3-3
Table 3-4
Table 4-1
Table 4-2
Table 4-3
Table 4-4
Table 4-5
Point Source Categories Listed in Appendix B of the 1976 Settlement
Agreement . . .............. 3-14
industrial Categories Derived from the Machinery and Mechanical Products
Manufacturing Category .... . 3-15
Metal Finishing Category Unit Operations . . . :.........«. 3-16
MP&M Unit Operations .............. . . .... . ............ 3-1?
Metal Finishing Waste Characteristic Distribution ................. 4-10
Changes hi Minimum Detection Limits for Selected Analytes ........ 4-11
Metal Finishing: BAT Visited Plants . . . ....... . . 4-12
Pretreatment Standards for Existing Sources (PSES) Electroplating
Category 40 CFR 413 ;................. 4-14
s . .
Effluent Guidelines and Standards for the Metal Finishing Category
40 CFR 433 '...'. ...... .... ... . .. 4-15
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1,0 FOREWORD I
, The Engineering and Analysis Division (BAD) of the U.S. Environmental
Protection Agency (EPA) has conducted a preliminary study to determine the applicability, usage,
and utility of the metal finishing regulation. Unlike other studies aind reviews of existing
guidelines and standards, a review of metal finishing must consider the impact of the
promulgation of a new regulation for metal products and machinery which will control
wastewater discharges from the same and similar processes as presently controlled by metal
finishing and electroplating guidelines and standards. This study summarizes the preliminary data
collection for the MP&M rulemaking. This study identifies the interface, potential interference,
and applicability .overlaps and gaps between the Metal Finishing" (40 CFR Part 433),
Electroplating (40 CFR Part 413), and future Metal Products and Machinery (MP&M) guidelines.
EAD reviewed existing data and information from a variety of sources, including
development documents, data summaries, and documents in the rulemaking records for related
categories. EPA also conducted a survey of pretreatment coordinators oil the utility of the metal
finishing effluent guidelines and standards.
This study offers options to accommodate the MP&M rule considering the inherent
overlap between this rule and existing metal finishing rules and how tiie existing rules can be
improved to make them more practicable by permit, authorities. j
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2.0
SUMMARY
The Engineering and Analysis Division (BAD) of the U.S. Environmental
Protection Agency (EPA) conducted a preliminary study/of the metal finishing industry in
response to section 304 (m) of the Water Quality Act of 1987 and an obligation of EPA under
the Consent Decree in NRDC v EPA. No 89-2980 (D.C. Cir).
The study includes a summary of the regulatory authority, history, and background
of two existing regulations, Electroplating (40 CFR Part 413) and Metal Finishing (40 CFR Part
433), and a new to be proposed regulation for Metal Products and Machinery (MP&M). All three
of these regulations limit the discharge of process wastewater pollutants from the same or similar
metal finishing unit operations or processes. The study identifies the applicability of each
regulation and the overlap of 40 GFR Part 433 with the MP&M rule.
The study summarizes the practicability of the existing rules based on comments
by permitting authorities and suggestions by these authorities as to how the rule could be
improved. Suggested options are offered to accommodate the MP&M rule.
The study should provide sufficient information for the Agency to decide if an in
depth study and review of Metal Finishing (40 CFR Part 433) and Electroplating (4.0 CFR Part
413) is warranted. '
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3.0 HISTORY OF THE REGULATIONS
' • -' >.•'"!'
INTRODUCTION
This section presents a summary of regulatory authority and the history and
background of the Metal Finishing, Electroplating, and Metal Products arid Machinery categories.
,3.1 Statute and Consent Decrees
• . - ' - • "-,*'{
The Federal Water Pollution Control Act Amendments; of 1972 established a
comprehensive program to "restore and maintain the chemical, physical, and biological integrity
of the Nation's waters" (Section 101(a)). Under this statute, existing industrial dischargers are
required to achieve compliance with "effluent limitations requiring the application of the best
practicable control technology currently available (BPT)" (Section!30}(b)(l)(A)). These
dischargers were also required to later achieve "effluent limitations requiring the application of
the best available technology economically,achievable (BAT)...which-will-result in reasonable
further progress toward the national goal of eliminating the discharge of-all pollutants" (Section
301(b)(2)(A)). New industrial direct dischargers are required to comply with new source
performance standards (NSPS), based on best available demonstrated technology, and new and
existing dischargers to publicly-owned treatment works (POTWs) are j subject to pretreatment
standards under Sections 307(b) and (c) of the Act. The requirements for direct dischargers are
incorporated into National Pollutant Discharge Elimination System (NPDES) permits issued under
Section 402 of the Act, and pretreatment standards are made enforceable directly against
dischargers to POTWs (indirect dischargers),
," ii . • * ' '
Although Section 402(a)( 1) of the 1972 Act authorized the setting of requirements
for direct dischargers on a case-by-case basis, Congress intended that control requirements be
based on regulations promulgated by the EPA Administrator that consider the degree of effluent
reduction attainable through the application of BPT and BAT. Sections 304(c) and 306 of the
Act required promulgation of regulations for NSPS, and Sections 304(f)5 307(b), and 307(c)
required promulgation of regulations for pretreatment standards. In addition to these regulations
for designated industry categories, Section 307 (a) of the Act required the Administrator to
develop a list of toxic pollutants and promulgate effluent standards applicable to all dischargers
of toxic pollutants. When the effluent regulations were not promulgated by the dates contained
in the 1972 Act, the Natural Resources Defense Council and several other environmental groups
sued the Agency. In settlement of this lawsuit, a consent decree was issued by the Court (June,
1976) which required the development of a program to adhere for promulgating effluent
regulations for 21 point source categories for 65 "priority" pollutants and classes of pollutants
(Natural Resources Defense Council. Inc.. el al v. Train. 8 ERC 2120 (D.D.C. 1976), modified
March 9, 1979). The 1977 amendments to sections 301 and 307 of the CJlean Water Act cpdified
many of these provisions of the consent decree. The 21 point source1 categories listed in the
consent decree (Table 3-1) included two which are relevant to this mejtal finishing study: the
Machinery and Mechanical Products Manufacturing Category (the M«feMP category), and the
Electroplating Category. ;
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When the Settlement Agreement was modified in 1979 by including a specific
promulgation date schedule, ten industrial categories Were separated from M&MP. A detailed
analysis was conducted to separate the M&MP category into individual categories. (Table 3-2)
During the period 1977 to 1984 effluent guidelines and standards were promulgated for these ten
industrial categories from M&MP, and, as discussed below, regulations were promulgated for
electroplating/metal finishing.
Section 304(m); added by the Water Quality Act of 1987, established a new
process for planning the development of limitations guidelines and standards under the Act.
Section 304(m) directs EPA to publish biennial plans for the review and revision of promulgated
effluent guidelines and standards. On May 7, 1992 (57 FR 19748) the Metal Finishing industry
was identified as an industry for which additional information should be collected under the
Section 304 (m) directive (see 55 FR 97).
3.2 Regulatory Overview
This section presents a regulatory overview of the Electroplating, Metal Finishing,
and Metal Products and Machinery point source categories. It includes a description of the
historical background of the categories, a summary of the rulemakings, Settlement Agreements,
and Consent Decrees that affected the development of these categories.
. ' \ '
3.2.1 Electroplating and Metal Finishing Point Source Categories
This section presents an overview of the electroplating/metal finishing industry,
a general description of the structure of the electroplating arid metal finishing regulations, a brief
summary of the rulemakings, Settlement Agreements, and Consent Decrees that affected the
development of these categories, and a discussion of the applicability of each category. Data
collection efforts that led to the development of electroplating and metal finishing standards are
summarized in Section 3.3.1. ,;.'.-
During the regulatory development process, approximately 13,500 plants were
estimated to be in the electroplating/metal finishing industry. Many of these plants discharge
wastewater from several metal finishing operations other than, and in addition to, electroplating.
The electroplating standards (40 CFR Part 413) are concentration-based standards, but hiclude
equivalent production-based alternative standards for facilities that choose to limit wastewater
discharges. The metal finishing standards (40 CFR Part 433) are concentration based standards,
and do not include production-based alternative standards. The electroplating standards (Part 413)
apply to facilities that perform one or more of the following six electroplating unit or core
operations: , '
electroplating, electroless plating, anodizing, coating etching and chemical milling, and printed
circuit board manufacturing, plus related operations (cleaning operations, anodizing, coloring, acid
pickling, stripping, and sealing) when performed at a facility performing one or more of the core
operations if each related operation is followed by a rinse. The metal finishing guidelines and
standards apply to facilities that perform.one or more of the six core electroplating operations
(Part 433) and to any of 40 additional metal finishing operations (Table 3-3) which discharge
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wastewater, i.e. guidelines and standards are applicable to the 40 operations only if the facility
performs one or more core operations. 1
The electroplating point source category standards limits .thjb concentrations or mass
of certain pollutants which interfere with, pass through, or are otherwise incompatible with the
operation of publicly owned treatment works (POTWs). The electroplatiiig regulations (40 CFR
Part 413) apply only to pretreatment standards for existing job shops (facilities which own less
than 50% of the material being finished) and to independent circuit board manufacturers (facilities
which manufacture printed circuit boards principally for sale to other companies). These existing
job shops and circuit board manufacturers are specifically excluded from rketal finishing standards
(40 CFR Part 433). i
' ' • '. • " ' ' • ' • I' • • ;
On March 28,1974, (39 FR 11510) EPA promulgated a final rule adding Part 413
to Chapter 40 of the Code of Federal Regulations. That regulation, (the "Phase I electroplating
regulation") established effluent limitations guidelines for the electroplating subpart of the
electroplating point source category. On April 25, 1975, the Agency amended Part 413 by
revising and expanding the coverage of Subpart A Electroplating arid by adding five new
subcategories (phase II electroplating regulation), thereby forming the core operations for the
electroplating category.
The National Association of Metal Finishers (NAMF) and; others filed petitions in
The Court of Appeals for the Third Circuit.for review of the first electroplating subcategory (Part
413, Subpart A) on June 24, 1974. After review of the petitioners' objections and the technical
record, EPA, on December 3, 1976, suspended implementation of and revoked some provisions
of the first subpart. EPA based this decision on the results of analyses indicating that the
regulation would impose too stringent a standard on small electroplating firms. Similar suits filed
by members of the industry on July 23, 1975 with respect to the five newjsubcategories were also
stayed by stipulation." '
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ii -
On July 12, 1977, EPA promulgated interim final electroplating regulations that
established pretreatment standards for existing sources (PSES) that discharge to POTWs (42 FR
35834). These standards applied to discharges of cyanide and hexavalent chromium, and
controlled effluent pH. OnFebruary 14,1978, EPA published a proposedpretreatment regulation
for these pollutant parameters.and for cadmium, copper,,lead, nickel, silver, and zinc (43 FR
6560). The controls for these additional metals applied only to facilities discharging more than
10,000 gallons of wastewater per day. . il ,
In response to industry petitions for reconsideration of the; interim final standards
for cyanide and chromium, EPA indefinitely suspended all interim final electroplating standards
on May 14,1979 (44 FR 27993). The Agency cited the need to fully review the industry petition
as the primary reason for suspension of these standards. In this saiine notice, the Agency
announced its intention to promulgate final regulations for Part 413 before February 1980.
- ' - - 'L * "* " •]
' Concurrent with the activities discussed above, EPA was involved hi litigation with
the NRDC and several other environmental groups over the promulgatioin of effluent guidelines
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for electroplating and other point source categories. The petitioners contended that EPA did not
promulgate effluent guidelines and standards required by the dates contained hi the 1972 Clean
Water Act as discussed hi Section 3.1. As a result of this lawsuit, EPA entered into a court-
approved Settlement Agreement that required the development of a schedule for promulgating
effluent regulations and standards for 21 point source categories, including electroplating. These
categories are listed hi Table 3-1.
On September 7, 1979 EPA promulgated a final rule establishing PSES for the
electroplating category Part 413 (44 FR 52590). This final rule was subsequently corrected by
notices dated October 1, 1979, March 25, 1980, and August 19,1980. In addition, amendments
to the final rule were proposed on July 3, 1980. After promulgation, petitions to review the final
rule were filed by NAMF and others., On March 7, 1980, EPA entered into a Settlement
Agreement with the petitioners in an effort to resolve the issues without further litigation. The
Agreement provided that EPA would publish proposed amendments arising out of the settlement.
It further provided that if the final amendments did not differ significantly from those proposed,
the petitioners would dismiss their petitions for review.
On January 28, 1981, EPA published amendments to Part 413 regulations. Most
of these amendments arose from the NAMF Settlement Agreement. The major changes
incorporated by the 1981 amendments to Part 413 Electroplating included:
1) Revision of the daily maximum limitation for total cyanide from 0.8 to 1.9
mg/1
2) Revision of 30-day average limits to 4-day average limits
3) . Adoption of the concept of integrated and non-integrated facilities
4) Extension of compliance dates ,
5) Recognition of the development of additional pretreatment standards to be
called "Metal Finishing" which would regulate processes currently falling
under electroplating as well as many other metal finishing processes.
However, EPA stated that hi light of the potentially severe economic
impact of these anticipated regulations on the job shop and the independent
printed circuit board manufacturers, the Agency would not impose more
stringent pretreatment standards for that segment of the industry for several
years.
Facilities were further subdivided, based on discharge status, as
follow:
• Integrated facility: A facility that, prior to treatment,
combines electroplating waste streams with waste streams
not covered by the electroplating category; and
• Non-integrated facility: A facility that has significant
wastewater discharges only from operations addressed by
the electroplating category.
In theory", job shops can be integrated; in actuality, however, approximately 97%
of all job shops are non-integrated shops. -
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As a result of the Settlement Agreement, the applicability of the metal finishing
standards was defined as follows: with the exception of existing j obi shop electroplaters and
independent printed circuit board manufacturers, all facilities that perform at least one of the six
electroplating core operations would be required to comply with the Part 433 metal finishing
standards. Existing (as of August 31, 1982) job shop electroplaters and independent printed
circuit board manufacturers remained in Part 413 the electroplating category. Most Part 413
electroplaters were shifted to the metal finishing category. Facilities that did not perform one of
the six basic electroplating unit operations were not regulated by the | electroplating or metal
finishing standards. Compliance dates for the Part 413 standards were based on the promulgation
date of the final metal finishing regulations and on the discharge staitus (integrated or non-
hitegrated) of the particular facility.
: • , '. ' -.:.••;'' ' -. • : ..}'.••' '. ;
In Part 413, the final electroplating standards require plants discharging more than
10,000 gallons per day of regulated wastewater to meet more stringent standards than plants with
smaller flows. This reduced the projected economic impact of the standards and relaxed controls
on less than 3% of the flow to POTWs. the final Part 413 electroplating regulations limit
discharges of cadmium, chromium, copper, cyanide, lead, nickel, silver, and zinc to POTWs.
Control of copper, nickel, silver, and zinc was less stringent for smaller plants because of the
lower toxicity of these metals. Cadmium, lead, and cyanide were controlled equally for all flows.
After resolution of the applicability of the metal finishing .Land electroplating
standards by the Settlement Agreement, EPA proceeded with development of the metal finishing
regulation for direct and indirect dischargers. On July 15, 1983 EPA promulgated a final rule
adding Part 433, the Metal Finishing Effluent Guidelines and Standards, to Chapter 40 of the
Code of Federal Regulations (48 FR 32462). The metal finishing effluent limitations guidelines
and standards control the concentration of cadmium, copper, lead, nickel, silver, zinc, cyanide,
total suspended solids (TSS), and oil and grease that may be discharged jto waters of the United
States or to POTWs. Operations similar to electroplating/metal finishing processes which are
excluded from the Metal Finishing regulation and the Electroplating regulation are those facilities
which perform metallic platemaking and gravure, cylinder preparation within or for printing and
publishing facilities. '.;!'•'
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Also, another categorical effluent guideline or standard miay also be effective and
applicable to wastewater discharges from metal finishing operations. In these situations, the more
specific limitations apply to those metal finishing wastestreams which appear to be covered by
both standards. The following regulations take precedence over the Metal Finishing regulation:
Nonferrous Smelting and Refining (40i CFR Part 421)
- Coil Coating (40 CFR Part 465)
- Porcelain Enameling (40 CFR Part 466)
- Battery Manufacturing (40 CFR Part 461)
.-- . > Iron and Steel Manufacturing (40 CFR Part 420)
- Metal Casting Foundries (40 CFR Part 464)
Aluminum Forming (40 CFR Part 467)
Copper Forming (40 CFR Part 468)
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Plastic Molding and Forming (4,0 CFR Part 463)
Electrical and Electronic Components (40 GFR Part 469)
Nonferrous Penning (40 CFR Part 471)
For example, if a plant performs a phosphate coating operation (a metal finishing
core process) in preparation for painting and also performs cleaning, pickling, immersion coating,
and chemical coating as part of a porcelain enameling process, .then, the Metal Finishing standards
apply to the discharge from the cleaning and phosphate coating operation, while the Porcelain
Enameling standards apply to the discharge from application of the porcelain enamel and also the
prepatory operations of cleaning, pickling, immersion plating, and chemical coating operations.
Normally, the metal preparation operations (cleaning, pickling, immersion plating, and chemical
coating) would be subject to the Metal Finishing regulation. However, because the Porcelain
Enameling regulation specifically include those operations performed hi preparation for the
porcelain enameling operation, the Porcelain Enameling regulation takes precedence for those
wastestreams.
3.2.2 Metal; Products and Machinery Point Source Category
This section presents an overview and historical background of the Metal Products
and Machinery (MP&M) Point Source Category. The MP&M category, broadly defined, covers
facilities that perform wastewater .generating processes on metal machinery and metal parts,
including manufacture, assembly, rebuilding, repair, and maintenance. Regulatory development
for the MP&M category is an ongoing effort.
The MP&M category resulted from a 1976 Settlement Agreement with the NRDC
discussed hi Section 3.1, and the 1986 report to Congress on the discharge of hazardous wastes
to POTWs. Analysis of these sources revealed a significant gap hi national effluent regulatory
coverage in the metals industries area.
The 1976 Settlement Agreement required the development of a schedule for
promulgating effluent guidelines and standards for 21 point source categories. These categories
are listed in Table 3-1. Two categories are relevant: the Electroplating Point Source Category
as discussed in Section 312 and the Machinery and Mechanical Products (M&MP) Point Source
Category.
In 1979, when the Settlement Agreement was modified to include a specific
promulgation, schedule, M&MP was divided into ten industrial categories based on ^process
operations, water use and economic indicator data, and Standard Industrial Classification (SIC)
codes. These ten categories are listed in Table 3-2. Between 1979 and 1984, these ten categories
were analyzed and regulations were promulgated as appropriate. .
A 1986 analysis of the regulatory coverage of these ten categories concluded that
more than 89,000 facilities performing process operations on metal products were no$ fully
regulated by existing guidelines and standards. The 1986 analysis showed that three regulations
were promulgated for metal manufacturing (iron and steel, nonferrous metals manufacturing, and
ferroalloy metals manufacturing); that five regulations were promulgated for metal forming (iron
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and steel, metal molding and casting, aluminum forming, copper forming, and nonferrous metals
forming categories); and that although four regulations had been promulgated for the component
finishing of mill products (coil coating, porcelain enameling, battery manufacturing, and electrical
and. electronic component manufacturing), the coverage was incompletei. This left a large area
of the metals industry unregulated. .
.Another 1986 analysis, The Report to Congress on the Discharge of Hazardous
Wastes to Publicly Owned Treatment Works (EPA 530-SW-86-004), referred to as the Domestic
Sewage Study or DSS, concluded that a significant number of facilities 'discharging to POTWs
discharge pollutants that threaten the treatment capability of POTWs. The DSS also concluded
that the discharge of these pollutants was not regulated by national effluent guidelines and
standards. Some of the major areas identified by this analysis were in equipment manufacturing
and assembly areas of the metals industry. • ;
• " ' • ' • • i
Based on a review of the regulatory coveragefor metals industries and the findings
of the DSS, the Agency performed a preliminary data survey of the unregulated areas of the
metals industries. The result of this analysis was the recommendation for a new point source
category, Machinery Manufacturing and Rebuilding (MM&R). The category was listed as a study
area to be reviewed for regulation under the directive of Section 304(m) of the 1987 Amendments
to the Clean Water Act.
The Preliminary Data Summary for the Machinery Manufacturing and Rebuilding
Effluent Guidelines Category (MM&R PDS) was completed in September 1989. The MM&R
PDS presented: results of a review of existing information to define the category and to identify
the population of the. category; arid results of a preliminary data collection effort to quantify the
significance of the environmental problems caused by MM&R. I •"'.'••''
The MM&R PDS concluded that the MM&R category should include any facility
that performs one or more of 45 defined major unit operations oik "machinery" that is
manufactured, rebuilt, or maintained. "Machinery" was broadly defined, to include any metal
product or part of a metal product. These unit operations are listed in Table 3-4. The MM&R
PDS estimated that 970,000 facilities are involved in MM&R activities iknd may potentially be
unregulated by national effluent limitations or standards. An estimated 692,000 of these facilities
(71%) are small businesses with fewer than ten employees. Based on preliminary sampling data,
the MM&R PDS estimated that MM&R facilities discharge approximately 186 million pounds
of pollutants per year. Although some of the indirect dischargers were regulated under local
effluent standards and some were regulated in whole or in part by existing effluent limitations
for industrial categories (e.g. metal finishing or electroplating), these categories were not defined
to cover arid did not cover all MM&R facilities. As example, the electroplating and metal
finishing regulations do not apply Jo facilities that do hot perform! one of the six core
electroplating unit operations. Section 3.2.1 provides further information on the applicability of
the metal finishing and electroplating categories. ',
)• , - •
... " ^i
The MM&R PDS recognized that MM&R facilities are highly diversified in terms
of number of employees, type of product, water use, water discharge, operating practices, and
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other parameters. For this reason, the regulatory approach recommended in the MM&R PDS was
based on a common factor in all MM&R facilities: the MM&R unit operations. The preliminary
assumption used for the development of the regulatory approach to MM&R was that every
facility generates the same types of pollutants from a particular unit operation, and that the
pollutants are generated in varying quantities based on me amount of product produced. The
MM&R PDS therefore recommended collection of sufficient technical information to develop a
conventional mass-based effluent regulation. The MM&R PDS also recommended consideration
be given to an alternative regulatory approach of best management practices (BMPs) for facilities
with limited financial and personnel resources. .Data and information collection efforts for the
MM&R project are further discussed in Section 3.3.2.
In 1990, EPA announced its intention to promulgate effluent guidelines for the
MM&R category by 1995 (EPA Effluent Guidelines Plan, Federal Register. Volume 55, No. 1,
January 2, 1990). Because the potential regulated community was extremely large and diverse,
the Agency elected to promulgate effluent guidelines for MM&R hi two phases. MM&R Phase
I includes seven of the 15 industrial sectors covered by MM&R: Aircraft, Aerospace, Electronic
Equipment, Hardware, Ordnance, Mobile Industrial Equipment, and Stationary Industrial
Equipment. The Agency deferred promulgation of effluent guidelines for MM&R Phase II until
1999. MM&R Phase II includes the eight industrial sectors not covered by Phase I: Bus and
Truck, Household Equipment, Instruments, Motor Vehicles, Office Machines, Railroad, Ships and
Boats, and Precious and Nonprecious Metals. The decision to develop Affluent guidelines for the
seven Phase I sectors was based on amounts and types of wastewater discharges, the likely
economic impact of regulations, and the extent to which facilities in each of the two phases is
currently regulated. An estimate of Phase I facilities represents only about 20% of all MM&R
facilities, however they generate an estimated 52% of the total estimated discharges of toxic and
nonconventional pollutants from the category. . .
In the Agency's next effluent guidelines plan (EPA Effluent Guidelines Plan,
Federal Register. Volume 57, No. 89, May 7, 1992) the schedule for, the promulgation of final
effluent guidelines for the MM&R category Phase I was revised to May 1996. In addition, the
title of the MM&R category was changed to Metal Products and Machinery (MP&M). This name
change did not affect the coverage of the category, but was intended to clarify the coverage.
Regulatory development of effluent limitations guidelines and standards for the
MP&M category is ongoing, and the results of further data collection efforts for the category are
summarized in Section 3.3.3.
3.3 Data and Information Gathering
This section summarizes data collection efforts for the electroplating, metal
finishing, and MP&M categories. The section includes descriptions of the literature studies,
federal and state contacts, industry contacts, and trade association contacts that constitute the data
collection effort for the electroplating, metal finishing, and MP&M rulemakings. This section
also includes a brief summary of information made available hi the administrative record for the
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electroplating and metal finishing categories when these guidelines and standards were
promulgated. , ;
3.3.1 Electroplating and Metal Finishing Point Source Categories
Literature Review
jl~ ^ ' -
EPA reviewed published information relevant to electroplating and metal finishmg
manufacturing processes, water use, waste treatment, and pollutant characteristics. This literature
review included more than 200 sources of published information in periodicals, books, reports,
papers, and promotional materials. Detailed bibliographies of the literature sources used can be
found in the Development Document for Existing Source Pretreatment Standards for the
Electroplating Point Source Category and in the Development Document for Effluent Guidelines
and Standards for the Metal Finishing Point Source Category. . • :'
Federal and State Agency Contacts !
' ij '
" EPA contacted all EPA regional offices and more than 10 state and territorial
environmental agencies to obtain permits and monitoring data on plants performing electroplating
and metal finishing unit operations. -
Plating Materials Suppliers and Manufacturers i
EPA visited or contacted at least 40 plating materials manufacturers and suppliers
to collect information on the chemistry of plating baths and the pollutiorial aspects of chemicals
used in the electroplating and metal finishing industry,
•' - ' i
Trade Association Contacts ; *
EPA attended pollution abatement meetings and seminars of several trade
associations. EPA also attended the American Electroplaters' Society Intensive Training Course
hi Electroplating and Surface Finishing and a seminar on advanced wastewater treatment. EPA
jointly sponsored EPA/American Electfoplaters' Society Conferences on Advanced Pollution
Control for the Metal Finishing Industry. In addition, EPA met with several trade associations,
including The Institute of Printed Circuits, The National Association c|f Metal Finishers^ The
Continuous Coil Anodizing Association, The Association of Home Appliance Manufacturers, and
The National Association of Manufacturers, to discuss the objectives and content of the
electroplating standards and the metal finishing guidelines and standards.
1-
Plant Surveys and Evaluations ,
EPA used a number of sources to identify prospective companies to establish
databases for the metal finishing and electroplating categories. Among these sources were prior
environmental studies performed on this industry, state and local agencies, and trade associations.
EPA collected data from electroplating and metal finishing plants througti written questionnaires,
. • " ' • ' . 'i! . ' • ,
: ' . '• •'• 3-9 , ' '.:!•. -' ' -..
-------
telephone surveys, engineering plant visits, and wastewater sampling episodes. Telephone surveys
were generally used to select facilities for written questionnaires, plant visits, or wastewater
sampling episodes.
Under authority of Section 308 of the Clean Water Act, EPA sent several different
questionnaires, or data collection portfolios (dcps), to facilities that perform electroplating/metal
finishing unit operations. In addition, data from the 1975 Printed Circuit Board and Electroless
Plating Study, the 1975 Electroplating Advanced Treatment Study, the 1976 Electroplating
Pretreatment Study, and the 1976 .Surface Treatment and Coating Study contributed to the
databases for the metal finishing and electroplating standards. Selected data from studies of the
copper and copper alloy manufacturing category, the aluminum and aluminum alloy
manufacturing category, and the iron and steel manufacturing category were used to determine
the characteristics of oily wastewater and to evaluate the performance of oily wastewater
treatment technologies.
Beginning hi 1974, EPA collected data from a total of 215 electroplating (Part
413) facilities by sending three separate dcps. These dcps are identified in the electroplating
record by the name of the three EPA contractors: Batelle, Yost/Safranek, and Hamilton Standard.
These dcps contain information about general plant characteristics, unit operations performed,
waste disposal methods, and wastewater treatment methods.
To collect data for the metal finishing guidelines and standards (Part 433), EPA
sent three dcps to various industries within the metal finishing category. The first of these dcps,
sent in 1978, obtained data from 339 of the 1,422 plants. The data included information on raw
materials consumed, specific operations used, composition of effluent streams, and wastewater
treatment processes.. The second dcp, sent in 1978-1979, obtained data from 365 of the 900
plants originally contacted hi the mechanical and electrical products industries. This data
included general plant characteristics, unit operations performed (including specific information
on "plating type" operations), wastewater treatment, and waste transport. The third dcp, the best
available technology (BAT)/electroplating dcp, sent in 1978, obtained data from l,190,.of 1,883
companies believed to be engaged in electroplating operations. This dcp collected information
on general plant characteristics (both technical and economic information), production history,
manufacturing processes, wastewater treatment, and wastewater treatment costs. During the metal
finishing rulemaking, a total of 269 facilities were visited.
Plant Sampling .
EPA collected wastewater samples at more than 200 electroplating/metal finishing
facilities to characterize pollutant loads from process wastewater and to evaluate wastewater
treatment effectiveness. The criteria used to select plants for sampling episodes included:
• A large percentage of the plant's effluent discharge should result from
relevant manufacturing operations; '.
3-10
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• The physical layout of the plant should facilitate sampling of the
wastewater; .
' ".'<.•-. • . - • J .
• The plant must have wastewater treatment and control technology in place;
and . ;i : .
• The mix of plants sampled should be representative of the discharge status
and geographic distribution of plants hi the industry.
Self Monitoring Data ;
EPA requested and received long-term self-monitoring data from more than 50
plants. The data were used to evaluate treatment effectiveness and effluent variability for metal
finishingand electroplating facilities. jj ,
Administrative Record , • :\
As part of the regulatory development process, EPA maintained administrative
records for the electroplating-and metal finishing rulemakings. The electroplating and metal
finishing administrative records include general information regarding the history and
development of the electroplating pretreatment standards and metal finishing guidelines and
standards, the technical and economic information collected, documents supporting the technical
analyses of plant data, -documents supporting the economic and environmental analyses of
regulatory action, and data sources for the electroplating and metal 'finishing development
documents.
3.3.2 Metal Products and Machinery Category
\\
This section presents a summary of the data collection" efforts for the Metal
Products and Machinery (MP&M) Point Source Category. As described in section 3.2.2, this
category was formerly called the Machinery Manufacturing and Rebuilding (MM&R) Category.
This section includes a summary of the data collected through the: preliminary data summary
(PDS), the mini-data collection portfolio (mdcp), the data collection portfolio (dcp), engineering
plant visits, and wastewater sampling episodes for this category. Data collection for the MP&M
category is an ongoing effort. Proposed effluent guidelines and standards for Phase I of the
MP&M category are scheduled for November 1994.
Preliminary Data Summary j
The preliminary data summary for the MP&M category included the review of
existing data relevant to the MM&R category arid the collection of new data.
EPA began data collection for the PDS by reviewing existing databases for the
metals industries areas. This review included data for metal manufacturing categories (the"iron
and steel, nonferrous metals manufacturing, and ferroalloy categories), metal forming categories
* •'•'.'. • .' •' 3-11- ' • r '•'. - •• - . ' '
-------
(the metal molding and casting, aluminum forming, copper forming, and nonferrous forming
categories), and component finishing categories (the. coil coating, porcelain enameling,
• electroplating, metal finishing, and electrical and electronic components categories). Review of
the data was used to estimate analytical, flow, and production data for MP&M unit operations
and to provide process descriptions. In addition, EPA reviewed the domestic sewage study (DSS)
tb estimate pollutant loading and project size. ,
EPA collected new data for the PDS from engineering plant visits, wastewater
sampling episodes, telephone surveys, data collection portfolios (dcps), trade association contacts,
and informal contacts with industry and control authorities. To collect process and water use
information, EPA performed engineering site visits at 21 facilities. To obtain analytical, flow,
and production data, EPA collected wastewater samples at 7 industrial facilities. To estimate the
size of the potential regulated community and the geographic distribution of facilities, EPA
contacted 9 trade associations, conducted voluntary telephone surveys, reviewed Bureau of Census
publications, and consulted various industrial directories.
Data Collection Portfolios
EPA sent two written questionnaires, or data collection portfolios (dcps), to
MP&M facilities. The first of these, the mini data collection portfolio (mdcp), was sent in
August, 1990 to 8,342 facilities believed to be engaged in MP&M operations. EPA used
information purchased from Dun & Bradstreet to identify facilities to receive the mdcp. The
facilities chosen to receive the mdcp were statistically selected to provide a representative sample,
of the category. The mdcp was a short (2 page) questionnaire that collected information on(
business sectors, plant size, unit operations performed, water use and discharge, and metal types
processed. In response to the mdcp, EPA received technical information from 3,597 sites that
are engaged in MP&M operations.
The second questionnaire, the data collection portfolio (dcp), was sent to 1,020
sites hi January 1991. Sites were selected to receive the dcp based on one of four conditions:
10 randomly, selected from a list of sites reporting no. discharge of process wastewater; 2)
specifically selected from no discharge sites because of certain unit operations or wastewater
treatment; 3) randomly selected from known wastewater dischargers with historical data on their
wastewater discharges or (4) a site did not receive an mdcp, but was known, based'on, a telephone
survey, to be a large water-using MP&M facility. The dcp was an in-depth questionnaire that
collected detailed technical.and economic information on business sectors, plant size, process
water use and discharge, metal types processed, wastewater flow, plant production, discharge
status, waste minimization techniques, pollutant generation, wastewater control and treatment, and
air pollution control. In response to the dcp, EPA received technical information from 792
MP&M sites.
Plant Visits and Sampling
As part of the regulatory development process for MP&M, EPA has performed
engineering plant visits at 89 sites. The engineering plant visits were performed to collect further
3-12
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technical information from MP&M sites and to select sites for wastewater sampling. , EPA
sampled 24 MP&M facilities. EPA will use analytical data from these sites to characterize
pollutant loads from MP&.M process wastewater and to evaluate wastewater treatment
effectiveness. The criteria used to select plants for sampling episodes includes:
J - , i' r
• A large percentage of .the plant's effluent dischjirge should result from
relevant manufacturing operations; .
. • - ' ' ... i- ., .."..'''
• The physical layout of the plant should facilitate sampling of the
wastewater; . '.-•'-"•
• The plant must have pollution prevention and/or vyastewater treatment and
control technology in place; and
• The mix: of plants sampled should be representative; of the discharge status
and geographic distribution of plants in the industry.
Self Monitoring and Treatment Cost Data
. " •' • - ' • - . ' i..'..',
EPAhas requested long-term self-monitoring and wastewater treatment cost data
from/several MP&M plants. This data will be used to evaluate treatment cost, treatment
effectiveness and effluent variability for MP&M facilities. . . . . '
3-13
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Table 3-1 : ^
i ' •' - . ' .
Point Source Categories Listed in Appendix B
of the 1976 Settlement Agreement
1. Timber Products Processing
2. Steam Electric Power Plants
3. Leather Tanning and Finishing '
4. Iron and Steel Manufacturing
5. Petroleum Refining . , ,
6. Inorganic Chemicals Manufacturing ; ' • '
7. Textile Mills
8. Organic Chemicals Manufacturing
9. Nonferrous Metals Manufacturing
10. Paying and Roofing Materials (Tars and Asphalt)
11. Paint and Ink Formulation and Printing .
12. Soap and Detergent Manufacturing
13. Auto and Other Laundries
14. Plastic and Synthetic Materials Manufacturing
15. Pulp and Paperboard Mills; and.Converted Paper Products
16. Rubber Processing
17. „ Miscellaneous Chemicals
18. MACHINERY AND MECHANICAL PRODUCTS MANUFACTURING*
19. ELECTROPLATING* • •
20. Ore Mining and Dressing
21. Coal Mining
'Relevant to Metal Finishing Study
3-14
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Table 3-2 ,
Industrial Categories Derived from the
Machinery and Mechanical Products Manufacturing Category
1. Aluminum Forming
2. Battery Manufacturing
3. Coil Coating
4. Copper Forming
5. Foundries (Metal Molding and Casting)
6. Photographic Supplies
7. Plastics Processing
8. , Porcelain Enameling
9. . Mechanical Products
10. Electrical and Electronic Components
3-15
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Table 3-3
Metal Finishing Category Unit Operations
Unit Operations
Unit Operations
1. Electroplating* 29.
2. Electroless Plating* 30.
3. Anodizing* 31.
4. Conversion Coating* . 32.
5. Etching (Chemical Milling)* 33.
6. Printed Circuit Board Mnftng* 34.
7. Cleaning 35.
8. Machining 36.
9. Grinding ' 37.
10. Polishing 38.
11. Barrel Finishing (Tumbling) 39.
12. Burnishing 40.
13. Impact Deformation 41.
14. Pressure Deformation % 42.
15. Shearing ' 43.
16. HeatTreathig 44.
17. Thermal Cutting 45.
18. Welding 46.
19. Brazing
20. Soldering
21. Flame Spraying
22. Sand Blasting
23. Other Abrasive Jet Machining
24, Electric Discharge Machining
25. Electrochemical Machining
26. * Electron Beam Machining
27. Laser Beam Machining
28. Plasma Arc Machining
Ultrasonic Machining
Sintering
Laminating
Hot Dip Coaling
Sputtering
Vapor Plating
Thermal Infusion
Salt Bath Descaling
Solvent Degreasing
Paint Stripping
Painting
Electrostatic Painting
Electropainting
Vacuum Metalizing
Assembly
Calibration
Testing
Mechanical Plating
*Unit operations 1 through 6 are core operations. If a facility does not perform at least
one of these six operations, it is not subject to the Metal Fishing regulation.
3-16
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Table 3r4
MP&M Unit Operations
1. Abrasive Blasting
a. Bead
b. Grit
c. Sand , "
d. Shot
2. Abrasive Jet Machining
(Vapor Blasting)
3. Acid Treatment •
a. Acid .Cleaning
b. Chemical Etching and
Bright Dipping '
c. Pickling
4. Adhesive Bonding • • ' 28.
5. Alkaline Treatment and 29.
Alkaline Cleaning)
6. Anodizing
7. Assembly • . -
8. Barrel Finishing (Tumbling) 30.
9. Brazing • , .
10. Burnishing
11. Calibration
12. 'Chemical Conversion Coating
a. Chromate Conversion Coating -
b. Phosphate Conversion Coating 31.
c. . Complex Oxide-Conversion Coating 32.
d. Coloring 33.
e. Passivating '
13. Chemical Machining (Chemical Milling)
14. Corrosion Preventive Coating (Other than
, conversion coating •
15. Disassembly ' '
16. Electrical Discharge Monitoring
17., Electrochemical Cleaning ,
18. Electrolytic Cleaning -
19. 'Electron Beam Machining 34.
20. Electropolishing . .' •
21. Grinding •
22. Heating Treating
a. Tempering , . " .
b. Carburizing 35.
c. : Cyaniding ,. - . 36.
d. Nitriding 37.
e. Annealing 38.
f. Aging 39.
g. Normalizing
h. . Austenitizing
i. Austempering . ', . 40.
j. Si I iconizing
k. . .Martempering
I. Malleablizing 41.
23. Hot Dip Coating 42.
24. . Impact Deformation ' , . 43.
a. Peening . 44.
b. Shot Peening 45.
c. Forging
d. Coining
ei High Energy Forming
f. Heading
g. Stamping
25. Laminating
26. , Laser Beam Machining
27. Machining
a. Turning
b. Milling
c. Drilling
d. Boring .
e. - Tapping
f.
g-
h.
i.
j-
k.
I.
m.
ti.
o.
P-
q-
Metal
Planing"
Broaching
Sawing
Cutoff i
Shaving
Shearing
Threading
- Reaming
Shaping
Slotting
Nobbing
Chamfering
Spraying ;
Painting
a. Electropainting (Electrophoretic
Painting)
Electrostatic Painting
b.
Plating
a.
b.
c.
d.
e.
Electroplating
Electroless Plating
Immersion Plating
Mechanical Plating
Vapor Plating
Plasma Arc Machining
Polishing :|
Pressure Deformation
Rolling'
Drawing
Bending;
Embossing
Necking!
Forming!
Crimping ,
Flaringi
a.
b.
c.
d.
e.
f.
g.
h.
Rinsing
a.
b.
c.
d.
Countenpurrent Cascade
Stagnant Dip
Recirculating Dip
Spray ,;
Salt Bath Descaling
Soldering i . ' .
Solvent Degreasihg (Solvent Cleaning)
Sputtering i .
Stripping «
a. • Paint Strip
b. Plating[Strip
Testing I . .
a. Dye Penetrant Testing
b. Hydraulic Testing
Thermal Cutting ;
Thermal Infusion1
Ultrasonic Machining
Vacuum Metalizing
Welding j
a. Gas Welding
b. Resistance Welding
c. Arc Welding
d. Cold Welding
e. Electron Beam Welding
f. Laser Beam Welding
3-17
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4.0 DEVELOPMENT OF TECHNICAL AND ECONOMIC ASSESSMENT OF
ELECTROPLATING AND METAL FINISHING
INTRODUCTION i
This section presents a summary of the wastewater characterization, control and treatment
technology, and economic assessment for the electroplating/metal finishing regulations. A
summary of the limitations hi the effluent guidelines and standards are also presented.
4.1 Wastewater Characterization i
The Development Documents and administrative records were reviewed to examine the
technical basis for decisions on wastewater characterization in the electroplating/metal finishing
industry. Wastewater characterization information was reviewed to determine if all wastewater
streams generated at integrated metal finishing plants were characterized; for the Metal Finishing
regulation. ' ..'.'• }.'
. . ••- • . • . .' _ ,f . • .. ...._•
Pollutant Parameter Questionnaire and Wastewater Characterization Distribution.
. • "'"•(•-
Information on the presence of priority pollutants in metal finishing wastewaters was
compiled from the "priority pollutant questionnaire" section of the Electroplating Study dcps
discussed in Section 3-3, and from literature studies. Literature studies virere used to supplement
the data because little.or no information on the 40 "non-electroplating" metal finishing unit
operations (operations 7 to 46 in Table 3-3 and Table 4-1) was included in the Electroplating
Study. The data from the pollutant parameter questionnaire section of the dcps and the literature
study were used to compile the final Waste Characteristic Distribution table in the Metal
Finishing Development Document Table 4-1. The table lists all 46 metal iinishing unit operations
and correlates them to specific wastewater streams. The waste characterization distribution table
may reflect incomplete organic pollutant characterization in wastewater j from several of the 40
non-electroplating operations. For example, machining is shown not to contribute toxic organics
to. the wastewater stream, however recent MP&M. sampling data shows the presence of toxic
organic pollutants hi machining wastewaters. The Metal Finishing Development Document lists
the niinimum detection limits that were used hi the sampling phase of ithe rulemaking. These
detection limits were published hi "US EPA Environmental Monitoring and Support Laboratory.
Methods for Chemical Analysis of Water and Wastes", and "US EPA Guidelines Establishing
Test Procedures for the Analysis of Pollutants, Proposed Regulations;" (1979). During the
wastewater characterization phase of the rulemaking, pollutant parameters measured below the
minimum detectable limit were hot considered for regulation.
• • • ' • . !l ' " '
EPA Method 1620, which was promulgated after the Metal Finishing regulation (1987)
and is currently being used for MP&M, achieves lower detection limits Ithan those used for the
Metal Finishing regulation. Table 4-2 summarizes some of the changes in detection limits hi
EPA approved sampling methods since the promulgation of Metal Finishing. Therefore, were
the electroplating/metal finishing rulemakings to commence today, these lowered, detection limits
could have an impact on the pollutant parameters chosen for regulation;
* - - • • |i
: ' 4-1 . •'•:.' ; -i . :' ...."' •
-------
4.2 Control and Treatment Technology
, Data from the electroplating/metal finishing administrative records and development
documents were reviewed to identify specific data used to analyze treatment effectiveness and
select treatment options. These data were reviewed to determine if all wastewater streams
generated at integrated metal finishing plants were included in the identification of control, and
treatment technologies. ,
For the Metal Finishing regulation, site sampling data and long-term self monitoring data
were used to determine treatment effectiveness and variability factors. As an example for the.
current review of the Metal Finishing regulation, an analysis of control and treatment technology
data for the Metal Finishing BAT - precipitation/sedimentation common metals and total
suspended solids (TSS) was performed.
Visited Plant Data for BAT (Common Metals and TSS). Sampling analytical data from
36 plants were used to calculate mean treatment influent and effluent concentrations for common
metals and TSS. Table 4-3 presents a summary of the sites used to obtain BAT performance data
for common metals.
The sites as listed in Table 4-3 represent a cross section of job shop and integrated plants.
However, the sampling data reveal that 80 to 90% of the samples were collected from wastewater
streams from the six core electroplating operations only. The wastewater streams listed consisted
mostly of wastewater from electroplating with some minor exceptions, i.e. little or no data were
used to calculate treatment effectiveness for integrated plants and the non-electroplating
wastewaters. •_-.',
Long-Term Self Monitoring Data for BAT (Common Metals and TSS). Effluent data
were used from 32 plants to determine effluent variability for common metals. The sites
represent a cross section of job shops, and integrated plants. "
4.3 Economics
A preliminary review of the data used in the EPA report "Economic Impact Analysis of
Effluent Standards and Limitations for the Metal Finishing Industry" (6/83) was performed to
determine what specific data were used from the electroplating/metal finishing database to assess
the economic impact of the regulation on the job shop and captive (not a job shop), sectors.
Job Shop Plant Costing. Cost data from 244 of the 1,190 dcps from the Electroplating
Study were used as a financial and economic database and for costing the regulatory impact on
the job shop sector. The following information was available from the dcps: flow rate, plant
layout, materials finished, hours of operation, finishing processes, amperage, thickness of plate,
equipment in place, tooling, -piping, and laboratory costs.
Captive Plant Costing. The economic database used to cost the regulatory impact on
the job shop sector contained substantial process wastewater flow and economic data for job
4-2
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shops, but little or no information on the captive sector. To cost the captive sector, EPA selected
a sample of 100 indirect discharging captive plants and 100 direct discharging captive plants from
the visited plant database (these plants were called "model" plants in the iilA). Limitations in the
available data from visited captive plants prevented the creation of a functional relationship on
a plant-by-plant basis between visited plant wastewater flow and estimated-'cost impact of the
regulation. This data limitation was resolved by grouping the model plants according to
wastewater flow. These wastewater flow groupings were then matched according-to water usage
with the discharging job shop plants in the Electroplating Study dcp ecoinornic database. Costs
for direct and indirect discharging captive plants are described below. !
Direct Discharging Captives. For direct discharging captive plants, the 100 model plants
were grouped according to wastewater flow and linked to the job shop economic database. This
economic database consisted of 231 direct discharging plant dcps from the Electroplating Study.
The wastewater flow from the 100 direct discharging model plants was focused on the six core
electroplating operations. j
'. - i:
Indirect Discharging Captives. Of the 100 indirect discharging model plants, 26 model
plants had wastewater flow from one or more of the 40 additional; metal finishing (non-
electroplating) operations in addition to electroplating wastewater flow. For these plants, a
baseline cost was determined by grouping sites by wastewater flow rates and Correlating this with
the economic database from the Electroplating Study. The cost of the integrated wastewater flow
was determined by wastewater flow grouping and linking the estimated post with the economic
dcp database. <
• ." ' ' ' • ' • :; . -!!v '. " '
4.4 Effluent Limitations in the Effluent Guidelines and Standards for 40 CFR
Part 413 Electroplating and 40 CFR Part 433 Metal Finishing
4.4.1 Electroplating Point Source Category
This section presents a .summary of the pretreatment standard!!
(PSES) in the Electroplating Point Source Category as discussed in the
ELECTROPLATING 40 CFR Part 413 (PSES)
for existing facilities
preceding sections.
APPLICABILITY
basis
material and related
in conjunction with
This regulation covers
existing
Electroplating operations in which metal is electroplated on any
metal finishing operations, whether the operations are conducted
electroplating, independently, or as part of some other operation.
only job shop electroplaters and independent printed circuit board manufacturers
as of August 31, 1982. Operations excepted from coverage inchide
• Electrowinning and electrbrefining Conducted as a part of nonferrous metal
smelting and refining (40 CFR Part 421).
4-3
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Metal surface preparation and conversion coating conducted as part of coil
coating (40 CFR Part 465).
Metal surface preparation and immersion plating or electroless plating
conducted as a part of porcelain enameling (40 CFR Part 466).
Electrodeposition of active electrode materials, electroimpregnation, and
electroforming conducted as a part of battery manufacturing (40 CFR Part
461).
Metallic platemaking and gravure cylinder reparation conducted within or
for printing and publishing facilities, arid continuous strip electroplating
conducted within iron and steel manufacturing facilities which introduce
pollutants into a POTW. ..'...-
SUBCATEGORIZATION
Electroplating of Common Metals (Cu, Ni, Cr, Zn, Sn, Pb, Cd, Fe, Al or any
combination);
Electroplating of Precious Metals (Ag, Au, Ir, Pd, Pt, Rh, Ru);
Anodizing;
Coatings (chromating, phosphatihg, immersion plating);
Chemical Etching and Milling;
Electroless Plating; and
Printed Circuit Boards. „
REGULATION BASIS
• Concentration-based limitations.
• Optional mass-based limitations for those plants that discharge greater than 3 8,000
liters per day of electroplating wastewater and which recover process materials
and employ water conservation techniques. This limit can be used in place of
concentration- based regulations upon prior agreement with POTW.
UNIT OPERATIONS
Electroplating of Common Metals and Electroplating of Precious Metals
Subcateffories
Solvent Degreasing;
•Alkaline Cleaning;
Electrolytic Cleaning;
Acid Cleaning;
Salt Bath Descaling;
Electroplating; .
Chromate Conversion Coating;
Phosphate Conversion Coating; and
Coloring.
4-4
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Electroless Plating
Anodizing
Coatings
Alkaline Cleaning;
Acid Etching;
Vapor Blasting (plastic surface preparation);
Honing;
Solvent Degreasing; and
Electroless Plating.
Solvent Degreasing;
Alkaline Cleaning; .
Alkaline Etching;
Acid Treatment; and
Anodizing.
Alkaline Cleaning;
Acid Cleaning;
Solvent Degreasing;
Salt Bath Descaling;
Polishing;
Chromate Conversion Coating;
Phosphate Conversion Coating;
Coloring; and
Immersion Plating.
Chemical Milling and Etching
Solvent Degreasing;
Alkaline Cleaning;
Electrolytic Cleaning;
AcidCleaning;
Salt Bath Descaling;
Masking;
Acid Dipping;
Chemical Milling;
Chemical Etching; and
Bright Dipping.
Printed Circuit Boards
4-5
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• Acid Cleaning; ;
• Alkaline Cleaning; ' .
« Electroless Plating; .
• Electroplating; and
• Acid Etching.
TREATMENT EFFECTIVENESS DATA
• On-site sampling; and , .
• Site-provided information and sampling data.
PRETREATMENT STANDARDS FOR EXISTING SOURCES (PSES)
Pretreatment of Complexed Metal Wastes
• Chemical Precipitation; and
• Sedimentation.
Pretreatment of Hexavalent Chromium Wastes
Chemical Chromium Reduction.
Pretreatment of Cyanide Wastes , .
Cyanide Oxidation.
i / •; . • . .
Pretreatment of Oily Wastes ,
• Segregation;
• Gravity Separation;
• Skimming; and
• Emulsion Breaking.
Treatment of Combined Wastestreams
• Chemical Precipitation; ,
* Flocculation/Coagulation; ,
* Clarification; and
• Sludge Dewatering.
Presented in Table 4-4 are effluent limitations in the standards (PSES) for Electroplating
40 CFR Part 312.
4.4.2 Metal Finishing Point Source Category
4-6
-------
This section presents a summary of the effluent guidelines and: standards for the Metal
Finishing Point Source Category as discussed in the preceding sections.
APPLICABILITY
All plants which perform any of the following six metal finis ling operations on any
material:
Electroplating;
Electroless Plating;
Anodizing;
Coating (chromating, phosphating, coloring);
Chemical Etching and Milling; or
Printed Circuit Board Manufacturing..
Except:
Coil
are regulated by:
Coating; 3) Porcelain
Steel; 6) Metal Casting
; 9) Plastic Molding
E ectrical and Electronic
Those plants whose effluent limitations and standards
1) Nonferrous Metal Smelting and Refining; 2)
Enameling; 4) Battery Manufacturing; 5) Iron and
Foundries; 7) Aluminum Forming; 8) Copper Forming
and Forming; 10) Nonferrous Forming; or 11)
Components;
Those plants who conduct metallic platemaking
preparation conducted within or for publishing
Existing indirect discharging job shops and independent
board manufacturers which are covered by
(Electroplating). The term "job shop" is defined a
"more than 50% (annual area basis) of the materials undergoing metal
finishing.
SUBCATEGORIZATION
None. '
REGULATION BASIS
• - - ' / ' " .. '
Concentration-based limitations. ,
UNIT OPERATIONS
• . 40 operations as listed in Table 3-3
SAMPLING
Samples were collected at approximately 100 electroplating/metal finishers sites
4-7
and gravure cylinder
printing facilities; or
printed circuit
40 CFR Part 413
a site which owns not
-------
TREATMENT EFFECTIVENESS DATA
• • Raw and effluent concentration data from EPA sampling visits; and
• Long-term self monitoring effluent data submitted by plants in electroplating/metal
finishing industry.
BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE (BPT)
Treatment of Complexed Metal Wastes
• Chemical Precipitation; and
• ' Sedimentation.
t, , ' . - . ' ' " - • . .
Treatment of Hexavalent Chromium Wastes
' Chemical Chromium Reduction.
•Treatment of Cyanide Wastes ,
Cyanide Oxidation. "
Treatment of Oily Wastes
• Segregation;
• Gravity Separation;
• Skimming; and
• Emulsion Breaking.
Treatment of All Wastes
• Chemical Precipitation;
• Flocculation/Coagulation;
• Clarification; and
• Sludge Dewatering. '
BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE (BAT)
Identical to BPT.
NEW SOURCE PERFORMANCE STANDARDS (NSPS)
• Identical to BPT; and
4-8
-------
• Evaporative Recovery, Ion Exchange, and Recovery Rinsing as used for ^process
cadmium control. !.
-.' " ' " " }
PRETREATMENT STANDARDS FOR EXISTING SOURCES (PSES)
- -• • ' |i ' • , •
Identical to BPT. ;
/• . , ;i
PRETREATMENT STANDARDS FOR NEW SOURCES (PSNS) \
't
Identical to NSPS except oil, grease, and TSS are not regulated parameters.
• • ' - • - . , •)•"."-•
' ' • • - - • • . - V •
Also, presented in Table 4-5 are effluent limitations in the effluent guidelines and
standards for Metal Finishing 40 CFR Part 433. ]
4-9
-------
Table 4-1
Metal Finishing Waste Characteristic Distribution
rfaste Characteristics*/
Unit Operations
1. Electroplating
2. Electroless Plating
3. Anodizing
4. Conversion Coating
5. Etching (Chem.Milling).
S. Cleaning
7. Machining
3. Grinding
9. Polishing
10. Tumbling
11. Burnishing
12. Impact Deformation
13. Pressure Deformation
14. Shearing
15. Heat Treating
16. Thermal Cutting
17. Welding
18. Brazing
19. Soldering
20. Flame Spraying
21. Sand Blasting
22. Other Abr.Jet
Machining
23. Elec. Discharge Mach.
24. Electrochemical Mach.
25. Electron Beam Mach.
26. Laser Beam Mach.
27. Plasma Arc Mach.
28. Ultrasonic Machining
29. Sintering
30. Laminating
31. Hot Dip Coating
32. Sputtering
33. Vapor Plating
34. Thermal Infusion
35. Salt Bath Descaling
36. Solvent Degreasing
37. Paint Stripping
38. Painting
39. Electrostatic Painting
40. Electroplating
41. Vacuum Metalizing
42. Assembly
43. Calibration
44. Testing
45. Mechanical Plating
46. Printed Circuit Board
Manufacturing
Inorganics Organics
Common Precious Complexed Chromium Toxic; Zero
Metals Metals Metals (Hexavalent) Cyanide Oils Organics Discharge
X X X X .
xx xx
x • ' • .x • : , • • . . ;' ' •
X - X XX. '
X X X XX,
X X X '.X • . X' ' ' OC_ X
x • • • x ••-...
x • • • ., x -.•'...
X X X
X XXX
XX , X X
X X
x • • , x
x • x
X . XX
x .' • . •'-,••'
x -...,.-• .."'.'''
X , " .
x '-".-. • . - .
X X
x " . _ , '
x ' - • . . x •"',.-...-
> " • '•
x- • ..'..-' - ; ; x
X X . ' .'. X X
. . x
. '' • ' • ' ' x
•' . ' • • ' x
" • • - • " x
x -
X X .
• • ' x
• • .' ' •' x
X X
X . ', • • . : X X
X XX
x • , . • ,. : • • x • • . , , ;
'X ' , X , X
x x x,
X " ' X X X
." . • X ". .
x • ' ; . • ,'•,•• •'•
X ' X X -
* The raw wastes for the Metal Finishing category were initially subdivided into two
constituent types, inorganic and organic and further subdivided into Seven waste types. The
major constituents of common metals waste streams include cadmium, chromium, copper, cyanide,
lead, nickel, zinc, and tin. The major constituents of precious metals waste stream include
gold, silver, palladium, and rhodiun. Complex metals of copper, nickel, tin, and zinc are often
formed from completing agents, typically cyanide or ammonia during electroless and immersion
plating and cleaning operations with heavily chelated agents. Segregation and separate
treatment for the seven types are part of the'basis for limitations.
4-10
-------
• .'. ' • TABLE 4-2 ' . '}.''-.
CHANGES IN MINIMUM DETECTION LIMITS FOR SELECTED ANALYTES
Parameter
1. Beryllium
2. Cadmium
3. Chromium
4. Copper
5. Lead
6. Nickel
7. Silver
8. Zinc
9. Iron
Detection Limit Used
for Metal Finishing
(mg/1)
0.005
0.005
>0.05
' 0.02
0.10
0.04
0.01
0.005
0.03
EPA Method 1620
(mg/1)
0.0003 ]
0.004 I
0.007 ;
v . '
0.006.
0.042
0.015 j
0.007 i
0.002 i
0.007
% Decrease in
Detection Limit
94%
20%
86%
70%
\
58%
\ 63%
30%
60%
77%
4-11
-------
TABLE 4-3
METAL FINISHING: BAT VISITED PLANTS
SITE
NO.
4065
4069
4071
5020
6051
6074
6083
6087
6101
6731
11477
12061
SIC
3679
3679
3679
3679
3728
3421
3964
3679
3484
3824
3479
3315
Performance Data
_(Common Metals and TSS)
•Cd*
/
/
/
/
/
/
Cr
/
/
/
/
/
/
/
Cu
/
/
/
/
/
/
/
/
.Pb*
/
/
/
/
/
/
/
Ml
/
/
/
/
/
/
Zn
/
/
/
TSS
/
/
/
/
/
/
/
i
/
/
/
/
/
, Treatment
Influent
Contained
Wastewater
Streams from
Six
Electroplating
Operations
Only
/
/
/
/
/
/
/
/
/
COMMENTS
Printed Circuit
Board
Manufacturer
Printed Circuit
Board
Manufacturer "•'
Printed Circuit
Board
Manufacturer
Printed Circuit
Board
Manufacturer
Raw Wastewater
Sample Included
Electroplating,
Machining,
Grinding,
Impact •
Deformation and
Pressure
Deformation
Wastewater.
Raw Wastewater
'Sample Included
Electroplating,
Grinding and
Burnishing
Uastewater.
Raw Uastewater
Sample Included
Tumbling
Uastewater
Only. (50% of
Total
Wastewater - .
Remaining 50%
was
Electroplating
Uastewater -
Which was not
sampled).
Job Shop
4-12 .
-------
TABLE 4-3 . ,
METAL FINISHING: BAT VISITED PLANTS
Continued
14001
15010
15070
19051
19063,
19068
30073
. 20078
20080
20083
20086
21003
23061
27044
31020
33024
33065
33074
33692
36040
36041
36623
40062
44062
3585
3711
3632
3915
3471
3479
3471
3471
3496
3429
3634
3079
3429
3662
3561
3911
3555
3644
3949
3471
3714
3998
3822
3471
3079
3662
3471
3471
3479
3411
% of data from
electroplating
wastes
/
/
/
/
/
/
/
/
/
/
/
82%
/
/
/
/
/
/
/
/
/
/
/
/
/
/
80%
-
/
/
/
/
/
/
/
/
/
/
/
/
/
/
91%
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
87%
/
/
/
/
/
/
/
/
/
/
/
/
/
89%
/
/
/
/
/
/
V
_,
/
/
/
/
/
/
88%
/
/
/
/
V
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
83%
IL
I
1 ,
i .
/ 1 '
/ '.'..'
'• / •• 'i
' /-''I:-
/
/ f
• /• :: j
;|
/ .;•
/ ', -•
-\
' j
• / i
1 / ! .
A ,i "
/ It
' / . ' '
/
1 i
' • ( '
'
]
' "'
•i '
- \-'
/ i: .
/ J
/ '. i!
i
/ :i
/ [
Raw Wastewater
Sample Included
•Painting.
Wastewater
Only.
Job Shop
Job Shop
Raw Wastewater
Sample Included
Deburring
Wastewater
Only. (Not
Electroplating
Operations)
Raw Wastewater
Sample Included
Electroplating,
Machining,
Grinding,
Barrel
Finishing,
Shearing, Heat
Treatment, .and
Testing
Wastewaters.
Job Shop
Job Shop
Job Shop
J • • - . s ,
• )
4-13
-------
TABLE 4-4
PRETREATMENT STANDARDS FOR EXISTING SOURCES (PSES)
ELECTROPLATING CATEGORY
40 CFR Part 413
Facilities Discharging <38.000 liters (10.000 gallons) per day
Pollutant
Cadmium (T)
Lead (T)
Cyanide, A
Total Toxic Organics (TTO)1
Daily Maximum
(me/ft
1.2
0.6
5.0
4.57
Facilities Discharging >3 8.000 liters (10.000 gallons) per day
Pollutant
Cadmium (T)
Chromium (T)
Copper (T)
Lead (T)
Nickel (T)
Zinc (T)
Silver (T)2
Total Metals3
Cyanide, T
Total Toxic Organics (TTO)1
Daily Maximum
(mg/1)
1.2
7.0
4.5
0.6
4.1
4.2
1.2
10.5
1.9
2.13
Cyanide, A = Cyanide, amenable to chlorination
Cyanide (T) = Cyanide, Total
(T) = Total
Maximum
4 Day Average
(me/to
0.7
. 0.4 ,
2.7
Maximum
4 Day Average
(mg/1)
0.7
4.0
2.7
0.4
2.6
2.6
0.7
6.8
1.0
'No regulation of the maximum 4-day average for TTO. :
2The silver pretreatment standard applies only to precious metals plating.
3To.tal metals is defined as the sum of the concentration of copper, nickel, total chromium,
and zinc.
4-14
-------
TABLE'4-5 i
EFFLUENT GUIDELINES AND STANDARDS FOR THE METAL FINISHING CATEGORY
40 CFR Part 433 ' . '•
BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE (BAT) AND
PRETREATMENT STANDARDS FOR EXISTING SOURCES (PSESJ
Pollutant
Cadmium (T)
Chromium (T)
Copper(T)
Lead(T)
Nickel (T)
Silver (T)
Zinc(T)
Cyanide, total
Total Toxic Organics
Alternative to total cyanide:
Cyanide, amenable to chlorination
Daily
Maximum (mg/T)
0,69
2.77
3.38
0.69
3.98
0.43
2.61
120
2.13
0.86
Maximum Monthly
. Averatte fnig/D
0126
1171
2107
0143
2,138
0124
1,148
Oii65 •
0.32
NE\y SOURCE PERFORMANCE STANDARDS (NSPS) AND
PRETREATMENT STANDARDS FOR NEW SOURCES (PSNS)
Pollutant
Cadmium (T)
Chromium (T)
Copper (T)
Lead (T)
Nickel (T)
Silver (T)
Zinc(T)
Cyanide, total
Total Toxic Organics
Oil and Grease
TSS ; ,
Alternative to total cyanide:
Cyanide, amenable to chlorination.
Daily
Maximum
0.11
2.77
3.38
0.69
3.98
0.43
2.61
1.20
2.13
52.0
60.0
Maximum Monthly
Average (mg/1)
0.07
1,71
2.p7
O.J43
2.38
0.24
I.'|t8 >: "
0.65
• '!-.'
26.0
31,00
' •• ,- 0.86 0.32
Note: No maximum monthly average TTO concentration regulated. ;j
(T) = total \ '
Oil and grease and TSS are regulated under NSPS not under PSNS.4
4-15
-------
-------
5.0 PRACTICALITY AND USE
INTRODUCTION
This section presents a summary of the applicability and the practical use of the
regulations by permitting authorities and of the overlap between the Electroplating Point Source
Category Pretreatment Standards, the Metal Finishing Effluent Guidelines and Standards, and
what may be proposed in the future effluent guidelines and standards for the Metal Products and
Machinery Point Source Category. !
5.1 Applicability and Use
.. ^ . , . > • , p_. .
5.1.1 Electroplating/Metal Finishing Industry
The electroplating/metal finishing industry is regulated by two rules, Electroplating (40
CFR Part 413) and Metal Finishing (40 CFR Part 433). Section 3 of this study summarizes the
authority under which these rules were promulgated, the history of the development of the rules,
the data collection efforts supporting the rules, and definitions and general applicability of each
rule. Section 4 of this study summarizes the wastewater characteristics of the- industry, control
and treatment technology, economic assessment of the rules, and the effluent limitations in the
guidelines and standards. - I j
Electroplating (Part 413) regulates only indirect discharges from six electroplating or core
operations and related operations followed by a rinse when performed at a,job shop or
independent circuit board manufacturer. Metal Finishing (Part 433) regulates direct and indirect
discharges from the remaining electroplating/metal finishing industry with effluent guidelines and
standards for discharges from facilities performing any of the core operations. When a facility
performs any of the core operations, any discharge from 40 additional limit operations are also
subject to Part 433. Both Part 413 and Part 433 use concentration based effluent limitations.
Guidance for applicability of Part 433 hi the devebpment document and preamble to the
regulation states, "industries covered by the Metal Finishing Category are generally included in
Standard Industrial Classification (SIC) Major Groups 34 through 39,!.." However, it is also
noted that some industries listed-in these Major Groups are not included in or exclusively
regulated by the Metal Finishing guidelines and standards. An example as Major Group 36
Electrical and Electronic Machinery Equipment and-Supplies which is subject to both the
Electrical and Electronic Component Category and the Metal Finishing Category guidelines and
standards. The Electrical and Electronic Components Category covers processes unique to
electronics, and the Metal Finishing Category covers the remaining processes used to manufacture
the products in Major Group 36. !
As discussed hi Section 3.2.1, 40 CFR Part 433.10 (b) states that eleven other categorical
effluent guidelines and standards with more specific limitations take precedence over the Metal
Finishing regulation. Regardless of the exemptions, exclusions, and precedence for the metal
i • .'i
- h • -•
5-1 •',;!.'•
-------
,
finishing limitations, at promulgation of the Metal Finishing regulation, EPA estimated that there
were approximately 13,500 manufacturing facilities in the United States which would be covered
by the Metal Finishing Category. This estimate was based on EPA mailings and industry journal
lists of facilities and plants engaged in the manufacturing of a variety of products that are
constructed primarily by using metals and perform one of the core unit operations. Also, Permits
Division in the Office of Wastewater Enforcement and Compliance (OWEC) presently estimates
that about 30,000 Significant Industrial Users (SIU) are subject to pretreatment standards. A SIU
is generally an industrial user subject to Categorical Pretreatment Standards or any other industrial
user that discharges an average of 25,000 gallons per day or more of process wastewater. OWEC
also estimates that about 12,000 SIU determinations were made based on the facility being subject
to Categorical Pretreatment Standards.
\ • . ' . '
The use and practicality of the electroplating/metal .finishing regulations has been estimated
from a number of sources, including data and information collected for the Metal Products and
Machinery Point Source Category which is summarized in more detail in the following section.
The initial estimate of 13,500 facilities.of which an estimated 85% are indirect dischargers has
stood through this current review of metal finishing. No hard data or national database exists,
e.g. number of actual permits issued by permitting authorities which incorporate guidelines and
•standards for effluent limitations, because in general, no notation is made on individual permits
as to how or what guidelines and standards were used for the effluent limitations. Extrinsic data
and information has come from inquiries from permitting authorities which indicates that for
.pretreatment standards, the Metal Finishing standards may be the most used and incorporated
standards, hi whole or in part, of any of the existing standards.
The reasons for this assertion include the definition for applicability of Metal Finishing
being related to unit operations performed at a facility and not to SIC codes or other more
specific definitions. By convention, permit writers use Metal Finishing standards in permit
limitations fqr a facility when other guidelines and standards are obviously not applicable, but
the facility has one or more core operations. Even if the core operations are small hi relation to .
the overall operation and size of the total facility, the presence of a core operation will allow the
inclusion of discharges from any of the other 40 unit operations covered by Metal Finishing. The
guidelines and standards for Metal Finishing apply to plants which perform any of the core six
metal finishing operations on any basis material. By convention, the discharges from the other
40 unit operations are covered by Metal Finishing standards even if there is no discharge from
the core operation or operations directly related to the core operation, i.e. cleaning operations,
acid pickling, stripping, and sealing.
An indicator of the utility of the Metal Finishing standard and how this rule for
electroplating/metal finishing has approached one of the stated goals for the rule, a request for
equivalent limits for process lines or unit operations often found together, is an analysis of the
data from the second MP&M data collection portfolio (dcp) for Phase I (January 1991). About
75% of the facilities hi the DCP which are permitted by using existing guidelines and standards
are subject in whole or in part to 40 CF'R Part 433 Metal Finishing. About 60% of the facilities
permitted by existing guidelines and standards are subject only to Metal Finishing, thereby
• • ' . 5-2 -V .
-------
approaching the goal of reducing the need for the combined wastestream formula (CWF) [40 CFR
403.6 (e)]. The CWF is a method to calculate alternative pretreatment discharge limitations for
mixed effluent from different regulated streams or unregulated and dilution streams as discussed
in more detail in Section 5.2. ^ ,
During the study contacts were established with permitting authorities to provide input on
the ^practicability of the electroplating/metal finishing rule. An example is the National
Pretreatment Coordinators Conferences where a voluntary survey was ^distributed. Responses
were received from nine EPA regional offices and 15 state or local pretreatment authorities.
Below are some highlights and comments regarding effluent guidelines and standards in general
and specific comments regarding Electroplating and Metal Finishing.
L, • i
About 70% of the respondents experienced situations in which the applicability and
definitions of the electroplating/metal finishing rules are inadequate.
• Definitions and applicability should be updated to reflect new processes, chemicals
and basic materials; j
Definitions of cleaning, coating and etching hi the guidance and development
documents need to be clarified; ||
. _ • The four-day average and 10,000 gallon per day criteria in Electroplating need to
be .clarified; ;
• Application and qualification for alternate cyanide and total toxic organics (TTO)
need additional explanations.
, ' . ' ' v ii -; • • "
Major difficulties encountered with the implementation of the Electroplating and Metal
Finishing regulations include:
• Vague definitions and applicability allow too much interpretation;
• There is a lack of authority and guidance to limit rinsewater flow.
...... There is difficulty in applying the regulation to new processes and materials;
• There is little guidance for overlap with other regulations and when there is .
precedence to Metal Finishing. I.
-!'' ' "'•'';
Recommendations for changes hi the Electroplating and Metal Finishing regulations
include: ' i;
1 ' . " '•!''"' '
• - Clarify definitions; j.
- average daily flow , i!
- core electroplating operations
- monitoring points of regulated process water, ; ,
- integrated facility, or "significant" quantities of process water from non-
electroplating manufacturing operations;
Change four-day average flow to monthly average flow hi Electroplating
regulations; j
- : ' " •' . ' ; "'. ' 5-3 ' ,-' -" .'.''• "1- •• .'" . .,'•-•' • -: '
-------
• Allow certifications (Toxic Organic Management Plan), instead of .monitoring
requirements, for industrial users that do not use cyanide,.or other regulated
pollutants; . "
• Evaluate TTO listing and remove compounds which have little or no likelihood
of being discharged'by a metal finishing or electroplating facility; .
Add alternate production-based limitations and/or flow restrictions;
• Address new industrial processes and newer wastewater treatment processes;
• Reconsider subcategorization;
Revise standards as appropriate to reflect pollution prevention, recycle, and reuse
measures widely used in industry.
About 70% of the respondents prefer concentration-based limitations rather man
production-based limitations and suggested alternatives to production-based limitations,
• Regulations and/or guidance for acceptable rinsewater rates;
• Concentration-based regulations with flow limitations;
The problems associated with production-based limitations include:
-difficulties in obtaining and verifying accurate production and flow data from
industry,
-production-based limitations need to accommodate wide variations in the type of
products manufactured, and
-fluctuations'in annual production make if difficult to select a representative year
which will be accurate throughout the permit term.
A recent draft report by EPA Region IX, Model IU Performance Study, includes
information on the effectiveness and compliance by.'indirect dischargers including 32 small N
electroplaters, 78 large electroplaters, 104 existing source metal finishers, and 112 new source
metal finishers. Performance measures based on compliance rates were determined for
compliance with daily maximum and either the 4-day or monthly average limitations for metals
and cyanide. A premise of the study is that all categorical industrial users should be able to
perform as well as those who installed and correctly operated the type of model treatment
originally selected by EPA as the basis of the categorical standards. "Model industries" in the
categories were selected based on facilities having treatment equal to or exceeding the technology
base for the standards categorical effluent limitations. Patterns were identified and documented
in the study. In particular, the compliance rates for daily-maximum standards always exceeded
the compliance rates for average standards! This difference in compliance rates for daily-
maximum and monthly average standards results from EPA's policy of applying average
standards against any number of samples in a month no matter how few. In reality, there is
usually only one sample in a month and almost never as many consecutive samples in a month
as were used to define the monthly average standards. >
The study found that most model industries complied with their Federal standards (both
daily-maxunums and averages) 100% of the time. However, the study also recognizes that some
industrial users will not perform well (based on compliance rates) even if they are model
• • , 5-4 .--•-." ". - ' .
-------
industries. Three percent and 15% of the model industries complied leSs than 67% of the, time
with then: daily-maximum and average standards respectively. Thirty percent and 45% of the
model industries complied less than 95% of the time with their dailyi-maximum and average
standards respectively. The principal conclusions hi the study is, that sewer districts should be
able to cause their categorical industrial users to meet these compliance rates.
5.1.? Metal Products and Machinery j
1 ' • • • ' - . ' " : 1
EPA initially estimated in the MP&M PDS that the population of MP&M to be 970,000
sites including both Phase I and Phase IL This estimate has been significantly reduced to the
present for both Phase I and Phase II by removing from coverage in Phase II 253,000 rebuilding
and maintenance facilities (e.g. motor vehicle repair shops). Review of idata. from the collection
portfolios, discussed in Section 3, caused EPA's estimate of the number of facilities in Phase I
and Phase II to be further reduced to slightly over 100,000. However, isome facilities reported
having products or business that fell into industrial sectors in both Phase I and Phase II. An
analysis of "water users" was taken from the dcp response that included facilities that reported
being in both Phase I and Phase II industrial sectors and facilities reporting to b;e only hi Phase
I. To date, the water users reporting to Phase I or Phase I/II have been considered Phase I sites
and these total Phase I sites were reviewed to find approximately 18,500 Phase I sites that
discharge water. Refinements to this estimate were made following an analysis of more detailed
dcp's and identifying additional sites which would not be regulated by.Phase I rules (no process
wastewater discharged, contract haul all liquid and solid waste, not engaged hi MP&M of out of
MP&M business). EPA now estimates that approximately 10,600 sites'will be regulated by
MP&M Phase I regulations. .. i: .
Applicability of MP&M has not totally been defined at this timib and will be subject to
interagency review and concurrence before the proposed regulation is presented to the
Administrator for signature. However, some general statements can jbe made regarding the
current thinking about scope and intent of the regulation (such as the abcive estimate of sites that'
will be regulated by Phase I MP&M). The SIC Major Groups listed in the'dcp's as Phase I and
Phase II industrial sectors are similarly included hi the general guidance for Metal Finishing.
Metal Finishing manufacturing processes are generally included hi SIC Major Groups 34 through
39. MP&M Phase I industrial sectors are found in SIC Major Groups 34 through 37. All of the
; unit operations covered by the Metal Finishing regulations are included in the unit operations to
be covered by MP&M. All of the types of metals finished and processed iby Metal Finishing unit
operations are included in the types of metal in the products and machinery included hi MP&M.
Analysis of the dcp's estimates that about 3300 sites in Phase I MP&M (of the over 10,000 sites
in Phase I) are currently regulated by electroplating/metal finishing regiilations.
The primary coverage of MP&M differs from Metal Finishing because there is NO
requirement that any of the core electroplating operations be performed at a site for the MP&M
rule to be applicable. Therefore, all of the 46 surface treatment operations and wastewater
discharges under Metal Finishing would be regulated by MP&M, This data base for cost of
treatment and treatment effectiveness for the removal of metals includes a number of sources
i1 /
- " " • "• - -• 5-5 . 'j - •" ' . : ''
-------
including the ongoing data collection for MP&M. The specific MP&M study includes
approximately 8000 screener surveys, approximately 1000 detailed questionnaires, 89 site, visits,
and 24 sampling visits with subsequent chemical analysis of unit operations wastewater; raw
wastewater to treatment, treated wastewater, and other process wastewater. The data base for
MP&M includes the data base for electroplating/metal finishing. Also, included is the Combined
Metals Data Base (CMDB) which is generally usable because it shares a fundamental concept
with the rationale used for MP&M: that similar properly designed, operated, and maintained
treatment systems will have the same effectiveness in removing metals from raw wastewater
streams through a wide range of concentrations regardless of the source of the raw wastewater.
The CMDB has been used as the basis for metals removal efficiency for a number of guidelines
and standards including: Coil Coating (40 CFR Part 465), Porcelain Enameling (40 CFR Part
466), Battery Manufacturing (40 CFR Part 461), Aluminum Forming (40 CFR Part 467), Copper
Forming (40 CFR Part 468), Nonferrous Metals Forming (40 CFR Part 471) and Nonferrous
Metals Manufacturing (40 CFR Part 421). Therefore, the treatment effectiveness used for effluent
limitations La the guidelines and standards for MP&M should approach the guidelines and
standards for electroplating/metal finishing and other metalindustries.
The effect of MP&M guidelines and standards should be to close the book on regulations
for the metals industry. Effluent guidelines and standards currently apply to mining and milling
metallic ores, manufacturing of metal from ore and recycled material, forming of metals as semi-
finished or finished products, and with MP&M, closing with major finished metal products.
5.2 Overlap of Metal Finishing and Metal Products and Machinery
NPDES permits for direct discharges and industrial user permits for indirect dischargers
are written using effluent limitations guidelines for NPDES permits and pretreatment, standards
for indirect dischargers. In summary, NPDES permit effluent limitations for a facility with
combined wastewater discharges from categorical point sources mat are subject to guidelines in
two or more subcategories, or two or more, point source categories, are calculated using the
"building block" concept. • Point source categories and subcategories are defined by unit
operations and principal process steps with wastewater flows, pollutant concentrations, or
production-based limitations. By adding together the effluent limitations for a pollutant regulated
hi discharges from unit operations or process steps, specific limitation for the combined
wastewater discharges can be determined. Pollutants not identified in a wastestream from a
category or subcategory and wastestreams from unit operations or processes not identified in the
categorical guidelines may be regulated on a case-by-case basis by the permit writer using Best
Professional Judgement. A permit writer may have to reduce effluent limitations guidelines with
production-based limitations to concentration based limitations to calculate combined waste stream
permit limitations; or production-based limitations for the combined wastestream can be
calculated by determining the flow for the operations and processes subject to concentration-based
limitations' and multiplying it by the concentration limitations to obtain production-based
limitations to use as a building block.
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Indirect dischargers that have combined wastewater discharges aie subject to standards as
specified by the Combined Wastestream Formula (CWF) according
to 40 CFR 403.6 (e).
Guidance Manual for the Use of Production-Based Pretreatment Standards and the Combined
Wastestream Formula offers specific examples of how limitations are developed for combined
wastestreams when a facility has any combination of concentration-based limitations, production-
based limitations, regulated, unregulated, and dilute wastestreams. Under 403.12 (b) (4) of the
General Pretreatment Regulations, a facility must monitor the flow of regulated process streams
and other streams as necessary to allow use of the CWF. j
Presently, the CWF is used to calculate effluent limitations for a number of industrial
users. Data from the dcp's discussed in Section 3 estimated about 3550 facilities in Phase I
MP&M sectors were then regulated in whole or in part .by electroplating/metal finishing and of
these approximately 1380 were regulated by one other rule, 110 were: regulated by two other
rules, 6 were regulated by three other rules and 60 were regulated by 4 or more other rules.
"' '' • ' '! '
The guidelines and standards being developed for MP&M may be inextricable from
electroplating/metal finishing guidelines and standards because of the overlap documented in the
preceding sections, e.g. the same unit operations and processes are covered, present permits for
many facilities that will be subject to MP&M are now subject in whole, or in part to guidelines
and standards for electroplating/metal finishing. However, definitions and applicability for the
Phase I MP&M rule have not been drafted and at least three options appear to be available.
One optibn is to have the present guidelines and standards for electroplating/metal
finishing . i!
remain applicable to facilities where these guidelines and standards are presently used. CWF
would be used to establish permit effluent limitations for combined ^yastestreams containing
process wastewater not covered, e.g., machining and boring, disassembly, and other unit
operations now being considered for inclusion under MP&M. More; unit operation process
wastewater would be subject to regulation from job shop electroplaters if the shops are included
in the industry sectors of MP&M. However, few job shops are in the MP&M sectors. This
option would obviously include all facilities in MP&M not performing one of the six
electroplating core operations, or about 78% of the estimated facilities in Phase I would be
regulated by MP&M and not metal finishing. •
1 • • :! . -
A second option is to have the more specific (stringent) limitations apply to those metal
finishing wastestreams which appear to be covered by both standards las is the case now for
eleven regulations as discussed hi Section 3. This option can not be fully addressed until more
specific guidelines and standards are proposed for MP&M. ;
A third option is to have MP&M Phase I include all facilities engaged in manufacturing
metal products and machinery whose products fall within the industry group and industry sectors
defined as Phase I industry sectors and other facilities that petition to jbe included in Phase I
regardless of how large or small a percentage of the facility's total activity or business income
can be attributed to Phase I. The industry sectors are generally defined in the initial descriptibn
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and definition of the MP&M category and these can be further defined by SIC designation
without changing the descriptive general industry sector, eg aerospace, aircraft, hardware, etc.
The wastewater discharges from any MP&M unit operation or process listed would be subject
to MP&M regulation if the facility is included in Phase I industry sectors, ie the MP&M effluent
limitations would supersede otherwise applicable existing effluent limitations guidelines and
standards. As with the second option, this option can not be fully addressed until more specific
guidelines and standards are proposed for MP&M.
SIC code 3471, Industry Group 347, Coating, Engraving, and Allied Services,
Electroplating, Plating, Polishing, Anodizing, and Coloring is not included in the MP&M industry
sectors, but cover job shops not in Phase I and Phase II industry sectors. This exclusion based
on the original MP&M definitions and applicability may be used to address separately the
Electroplating Category (Part 413) and EPA's commitment in the March 7, 1980 Settlement.
Agreement, discussed in Section 3, to not develop significantly more stringent standards for Part
413 for the next "several" years.
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