U. S. Environmental Protection Agency Office of Water ( 4303T) 1200 Pennsylvania Avenue, NW Washington, DC 20460 EPA 821 B 03 001 Development Document For The Final Effluent Limitations Guidelines and Standards For The Metal Products & Machinery Point Source Category EPA 821 B 03 001 Christine Todd Whitman Administrator G. Tracy Mehan, III Assistant Administrator, Office of Water Geoffrey H. Grubbs Director, Office of Science and Technology Sheila E. Frace Director, Engineering and Analysis Division Marvin Rubin Chief, Energy Branch Shari Z. Barash Technical Coordinator Jan S. Matuszko Technical Coordinator Carey A. Johnston, P. E. Project Manager February 2003 U. S. Environmental Protection Agency Office of Water Washington, DC 20460 ACKNOWLEDGMENTS AND DISCLAIMER The Agency would like to acknowledge the contributions of Shari Barash, Yu Ting Guilaran, Carey Johnston, Jan Matuszko, Marvin Rubin, Marla Smith, and Richard Witt to development of this technical document. In addition, EPA acknowledges the contribution of Eastern Research Group, Westat, Abt Associates, and Science Applications International Corporation.

Neither the United States government nor any of its employees, contractors,

subcontractors, or other employees makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party s use of, or the results of such use of, any information, apparatus, product, or process discussed in this report, or represents that its use by such a third party would not infringe on privately owned rights. References to proprietary technologies are not intended to be an endorsement by the Agency.

Questions or comments regarding this technical document should be addressed to:

Mr. Carey A. Johnston, P. E. Environmental Engineer Engineering and Analysis Division ( 4303T) U. S. Environmental Protection Agency 1200 Pennsylvania Avenue, N. W. Washington, DC 20460 ( 202) 566  1014 johnston. carey@ epa. gov Table of Contents TABLE OF CONTENTS Page 1.0 SUMMARY AND SCOPE OF THE REGULATION ........................... 1 1 1.1 Overview of the MP& M Point Source Category.................. 1 1 1.2 Overlap with Other Effluent Guidelines ........................ 1 5 1.3 Summary of Applicability ................................... 1 7 1.4 Promulgated Effluent Limitations Guidelines and Standards ........ 1 8 1.5 Protection of Confidential Business Information .................. 1 9 2.0 BACKGROUND .................................................. 2 1 2.1 Legal Authority ........................................... 2 1 2.2 Regulatory Background ..................................... 2 1 2.2.1 Clean Water Act..................................... 2 1 2.2.2 Section 304( m) Requirements .......................... 2 5 2.2.3 Pollution Prevention Act .............................. 2 5 2.2.4 Regulatory Flexibility Act ( RFA) as Amended by the Small Business Regulatory Enforcement Fairness Act of 1996 ( SBREFA) ......................................... 2 6 2.2.5 Regulatory History of the Metals Industry................. 2 8 3.0 DATA COLLECTION ACTIVITIES ..................................... 3 1 3.1 Industry Questionnaires ..................................... 3 1 3.1.1 3.1.2 3.1.3 3.1.4 3.1.5 The 1989 Industry Surveys ............................ 3 2 <IP_ADDRESS>89 Screener Survey .......................... 3 2 <IP_ADDRESS>89 Detailed Survey........................... 3 8 The 1996 Industry Surveys ........................... <IP_ADDRESS>96 Screener Survey ......................... <IP_ADDRESS>96 Long Detailed Survey ..................... <IP_ADDRESS>996 Short Detailed Survey ..................... <IP_ADDRESS> 1996 Municipality Detailed Survey ............... <IP_ADDRESS> 1996 Federal Facilities Detailed Survey ........... <IP_ADDRESS>996 POTW Detailed Survey ................... 1997 Iron and Steel Industry Survey Data ................ Data Submitted by the American Association of Railroads ( AAR) ........................................... National Estimates .................................. 3 12 3 13 3 16 3 19 3 21 3 23 3 25 3 26 3 32 3 33 3 34 3 35 3 38 3 38 3 39 3 40 3.2 SiteVisits............................................... 3.2.1 Criteria for Site Selection............................. 3.2.2 Information Collected ............................... 3.3 EPA MP& M Sampling Program ............................. 3.3.1 Criteria for Site Selection............................. 3.3.2 Information Collected ...............................

i Table of Contents TABLE OF CONTENTS ( Continued)

Page 3.3.3 Sample Collection and Analysis ....................... 3.4 Other Sampling Data ...................................... 3.5 Other Industry Supplied Data ............................... 3.6 Other Data Sources ....................................... 3.6.1 3.6.2 3.6.3 3.6.4 3.6.5 3.6.6 EPA/ EAD Databases ................................ Fate of Priority Pollutants in Publicly Owned Treatment Works Database .................................... National Risk Management Research Laboratory ( NRMRL) Treatability Database ................................ The Domestic Sewage Study .......................... Toxics Release Inventory ( TRI) Database ................ Discharge Monitoring Reports from EPA s Permit Compliance System ................................. 3 41 3 46 3 48 3 49 3 50 3 50 3 51 3 51 3 52 3 52 3 53 3.7 References ..............................................

INDUSTRY DESCRIPTION ........................................... 4 1 4.1 Overview of MP& M facilities ................................ 4 1 4.1.1 Number and Size of MP& M Facilities ................... 4 2 4.1.2 Geographic Distribution............................... 4 3 4.1.3 Wastewater Discharging Facilities ...................... 4 4 4.1.4 Non Wastewater Discharging Facilities .................. 4 9 4.2 Proposed MP& M Operations................................ 4 11 4.2.1 Types of Unit Operations............................. 4 12 4.2.2 Description of Proposed MP& M Operations ............. 4 14 <IP_ADDRESS> Description of MP& M Oily Operations ............ 4 17 <IP_ADDRESS> Description of MP& M Metal bearing Operations .... 4 22 4.2.3 Metals Processed ................................... 4 34 4.2.4 Estimated Annual Wastewater Discharge ................ 4 34 4.3 Trends in the Industry ..................................... 4 41 4.4 References .............................................. 4 41 5.0 WASTEWATER CHARACTERISTICS ................................... 5 1 5.1 Process Water and Rinse Water .............................. 5 1 5.2 Influent to Oily Wastewater Treatment Systems ................. 5 13 6.0 INDUSTRY SUBCATEGORIZATION .................................... 6 1 6.1 Methodology and Factors Considered for Basis of Subcategorization . 6 1 6.1.1 Factors Contributing to the Subcategorization Structure Evaluated for the Final Rule ........................... 6 2 6.1.2 Factors That are Not a Basis For MP& M Subcategorization . 6 13 ii 4.0 Table of Contents TABLE OF CONTENTS ( Continued)

Page 6.2 General Description of Facilities in Each Subcategory Evaluated for the Final Rule ......................................... 6 17 6.2.1 General Metals Subcategory Evaluated for the Final Rule ... 6 17 6.2.2 Metal Finishing Job Shops Subcategory Evaluated for the Final Rule ......................................... 6 19 6.2.3 Non Chromium Anodizing Subcategory Evaluated for the Final Rule ......................................... 6 19 6.2.4 Printed Wiring Board Subcategory Evaluated for the Final Rule ............................................. 6 20 6.2.5 Steel Forming and Finishing Subcategory Evaluated for the Final Rule ......................................... 6 20 6.2.6 Oily Wastes Subcategory ............................. 6 20 6.2.7 Railroad Line Maintenance Subcategory Evaluated for the Final Rule ......................................... 6 22 6.2.8 Shipbuilding Dry Dock Subcategory .................... 6 23 SELECTION OF POLLUTANT PARAMETERS ............................. 7 1 7.1 Identification of Pollutants of Concern ......................... 7 1 7.2 Regulated Pollutants ...................................... 7 12 7.3 References .............................................. 7 14 8.0 POLLUTION PREVENTION PRACTICES AND WASTEWATER TREATMENT TECHNOLOGIES ....................................... 8 1 8.1 Flow Reduction Practices ................................... 8 1 8.1.1 Rinse Tank Design and Innovative Configurations .......... 8 2 8.1.2 Additional Design Elements ........................... 8 7 8.1.3 Rinse Water Use Control .............................. 8 8 8.1.4 Pollution Prevention for Process Baths ................... 8 9 8.2 In Process Pollution Prevention Technologies ................... 8 9 8.2.1 8.2.2 8.2.3 8.2.4 8.2.5 8.2.6 8.2.7 8.2.8 Activated Carbon Adsorption ......................... Carbonate   Freezing  ................................ Centrifugation and Pasteurization of Machining Coolants ... Centrifugation and Recycling of Painting Water Curtains ... Electrodialysis ..................................... Electrolytic Recovery ................................ Evaporation ....................................... Filtration .......................................... <IP_ADDRESS>Ion Exchange ( in process) ...................... <IP_ADDRESS>Reverse Osmosis ............................. 8.3 Best Management Practices and Environmental Management Systems for Pollution Prevention ............................. 8 12 8 13 8 13 8 14 8 16 8 17 8 19 8 20 8 21 8 24 8 25 iii 7.0 Table of Contents TABLE OF CONTENTS ( Continued)

Page 8.3.1 Pollution Prevention for Cleaning and Degreasing Operations ........................................ 8 27 8.3.2 Pollution Prevention for Machining Operations ........... 8 28 8.3.3 Painting Operations ................................. 8 29 8.3.4 Pollution Prevention for Printed Wiring Board Manufacturing ..................................... 8 29 8.4 Preliminary Treatment of Segregated Wastewater Streams ......... 8 30 8.4.1 Chromium Bearing Wastewater ....................... 8 31 8.4.2 Concentrated Metal Bearing Wastewater ................ 8 36 8.4.3 Cyanide Bearing Wastewater.......................... 8 36 <IP_ADDRESS>Alkaline Chlorination.......................... 8 37 <IP_ADDRESS>Ozone Oxidation ............................. 8 38 8.4.4 Chelated Metal Bearing Wastewater .................... 8 39 <IP_ADDRESS>Reduction to Elemental Metal ................... 8 39 <IP_ADDRESS> Precipitation as an Insoluble Compound ........... 8 40 <IP_ADDRESS>Physical Separation ........................... 8 41 8.4.5 Oil Bearing Wastewater.............................. 8 41 <IP_ADDRESS>Chemical Emulsion Breaking ................... 8 42 <IP_ADDRESS>Oil Skimming................................ 8 44 <IP_ADDRESS>Flotation of Oils or Solids ...................... 8 46 <IP_ADDRESS>Ultrafiltration ................................ 8 47 8.5 End of Pipe Wastewater Treatment and Sludge Handling Technologies ............................................ 8 48 8.5.1 Chemical Precipitation for Metals Removal .............. 8 48 <IP_ADDRESS> Gravity Clarification for Solids Removal .......... 8 54 <IP_ADDRESS> Microfiltration for Solids Removal ............... 8 55 <IP_ADDRESS> Optimization of Existing Chemical Precipitation Treatment System ............................ 8 56 8.5.2 Oil Removal....................................... 8 57 8.5.3 Polishing Technologies .............................. 8 58 <IP_ADDRESS>Multimedia Filtration.......................... 8 58 <IP_ADDRESS>Activated Carbon Adsorption ................... 8 59 <IP_ADDRESS>Reverse Osmosis ............................. 8 59 <IP_ADDRESS>Ion Exchange ................................ 8 59 8.5.4 Sludge Handling.................................... 8 60 <IP_ADDRESS>Gravity Thickening ........................... 8 60 <IP_ADDRESS>Pressure Filtration ............................ 8 61 <IP_ADDRESS>Vacuum Filtration ............................ 8 62 <IP_ADDRESS>Sludge Drying ............................... 8 63 8.6 References .............................................. 8 63 iv Table of Contents TABLE OF CONTENTS ( Continued)

Page 9.0 TECHNOLOGY OPTIONS ........................................... 9 1 9.1 Technology Evaluation Methods .............................. 9 1 9.2 General Metals Subcategory ................................. 9 2 9.2.1 Best Practicable Control Technology Currently Available ( BPT) ............................................. 9 2 9.2.2 Best Conventional Pollutant Control Technology ( BCT) ..... 9 8 9.2.3 Best Available Technology Economically Achievable ( BAT) . 9 9 9.2.4 New Source Performance Standards ( NSPS) .............. 9 10 9.2.5 Pretreatment Standards for Existing Sources ( PSES) ....... 9 11 9.2.6 Pretreatment Standards for New Sources ( PSNS) .......... 9 13 9.3 Metal Finishing Job Shops Subcategory ....................... 9 14 9.3.1 BPT, BCT, and BAT ................................ 9 14 9.3.2 NSPS ............................................ 9 15 9.3.3 PSES ............................................ 9 16 9.3.4 PSNS ............................................ 9 17 9.4 Non Chromium Anodizing Subcategory ....................... 9 18 9.4.1 BPT, BCT, and BAT ................................ 9 18 9.4.2 NSPS ............................................ 9 19 9.4.3 PSES and PSNS.................................... 9 19 9.5 Printed Wiring Board Subcategory ........................... 9 20 9.5.1 BPT, BCT, and BAT ................................ 9 20 9.5.2 NSPS ............................................ 9 20 9.5.3 PSES ............................................ 9 21 9.5.4 PSNS ............................................ 9 22 9.6 Steel Forming and Finishing Subcategory ...................... 9 23 9.6.1 BPT, BCT, and BAT ................................ 9 23 9.6.2 NSPS ............................................ 9 24 9.6.3 PSES ............................................ 9 24 9.6.4 PSNS ............................................ 9 24 9.7 Oily Wastes Subcategory ................................... 9 25 9.7.1 BPT ............................................. 9 25 9.7.2 BCT ............................................. 9 28 9.7.3 BAT ............................................. 9 28 9.7.4 NSPS ............................................ 9 28 9.7.5 PSES ............................................ 9 29 9.7.6 PSNS ............................................ 9 30 9.8 Railroad Line Maintenance Subcategory....................... 9 31 9.8.1 BPT ............................................. 9 31 9.8.2 BCT ............................................. 9 33 9.8.3 BAT ............................................. 9 34 v Table of Contents TABLE OF CONTENTS ( Continued)

Page 9.8.4 NSPS ............................................ 9 34 9.8.5 PSES and PSNS.................................... 9 34 9.9 Shipbuilding Dry Dock Subcategory .......................... 9 35 9.9.1 BPT ............................................. 9 35 9.9.2 PSES and PSNS.................................... 9 36 9.10 Summary of Technology Options Considered and Selected for the Final MP& M Rule ........................................ 9 36 10.0 LIMITATIONS AND STANDARDS: DATA SELECTION AND CALCULATION .... 10 1 10.1 Overview of Data Selection ................................. 10 1 10.2 Episode and Data Selection ................................. 10 2 10.3 Data Aggregation ......................................... 10 9 10.3.1 Aggregation of Field Duplicates ...................... 10 11 10.3.2 Aggregation of Grab Samples ........................ 10 11 10.4 Overview of Limitations .................................. 10 12 10.4.1 Objective ........................................ 10 12 10.4.2 Selection of Percentiles ............................. 10 13 10.4.3 Compliance with Limitations......................... 10 14 10.5 Calculation of the Limitations .............................. 10 15 10.6 Evaluation of the Limitations............................... 10 16 10.6.1 Comparison to Data ................................ 10 17 10.6.2 Comparison to Proposed and NODA Values ............. 10 21 11.0 COSTS OF TECHNOLOGY BASES FOR REGULATIONS ..................... 11 1 11.1 Summary of Costs ........................................ 11 1 11.2 Development of Cost Model Inputs........................... 11 6 11.2.1 Model Site Development ........................... 11 6 11.2.2 Wastewater Streams and Flow Rates .................. 11 7 11.2.3 Wastewater Pollutant Concentrations .................. 11 9 11.2.4 Technology in Place .............................. 11 10 <IP_ADDRESS> Baseline Model Runs ................... 11 15 <IP_ADDRESS> Post Compliance Model Runs ............ 11 16 <IP_ADDRESS> New Source Model Runs ................ 11 16 11.3 General Methodology for Estimating Costs of Treatment Technologies ........................................... 11 17 11.3.1 Components of Cost .............................. 11 18 <IP_ADDRESS> Total Annualized Costs ................. 11 19 11.3.2 Sources and Standardization of Cost Data ............. 11 20 11.3.3 Development of the Cost Model..................... 11 25 <IP_ADDRESS> Modeling Technology Options ........... 11 26 <IP_ADDRESS> Modeling Flow Reduction ............... 11 30 vi Table of Contents TABLE OF CONTENTS ( Continued)

Page <IP_ADDRESS> Modeling End of Pipe Treatment for Metal Bearing Subcategories .................. 11 30 <IP_ADDRESS> Modeling End of Pipe Treatment for Oily Subcategories ......................... 11 31 <IP_ADDRESS> Model Output......................... 11 31 11.3.4 General Assumptions Made During the Costing Effort ... 11 31 11.4 Specific Methodology and Assumptions Used to Estimate Costs for Treatment Technologies................................... 11 34 11.4.1 NODA Cost Estimates ............................ 11 35 11.4.2 Post NODA Cost Estimates ........................ 11 37 11.5 Costing Methodologies for Direct Discharging Oil Bearing Subcategories ........................................... 11 39 11.5.1 Oily Wastes Costing Methodology................... 11 39 11.5.2 Railroad Line Maintenance Costing Methodology ....... 11 40 11.5.3 Shipbuilding Dry Dock Costing Methodology .......... 11 40 11.6 Design and Costs of Individual Pollution Control Technologies ... 11 40 11.6.1 Countercurrent Cascade Rinsing..................... 11 41 11.6.2 Centrifugation and Pasteurization of Machining Coolant . 11 41 11.6.3 Centrifugation of Painting Water Curtains ............ 11 42 11.6.4 Contracting for Off Site Treatment and Disposal ........ 11 49 11.6.5 Feed Systems and Chemical Dosages................. 11 49 11.6.6 Chemical Emulsion Breaking and Gravity Oil/ Water Separation ...................................... 11 52 11.6.7 Dissolved Air Flotation............................ 11 53 11.6.8 Ultrafiltration System for Oil Removal ............... 11 54 11.6.9 Batch Oil Emulsion Breaking with Gravity Flotation ..... 11 54 11.6.10 Chemical Reduction of Hexavalent Chromium ......... 11 55 11.6.11 Cyanide Destruction .............................. 11 56 11.6.12 Chemical Reduction/ Precipitation of Chelated Metals ... 11 57 11.6.13 Chemical Precipitation ............................ 11 57 11.6.14 Sedimentation by Slant Plate Clarifier ................ 11 58 11.6.15 Multimedia Filtration ............................. 11 59 11.6.16 Microfiltration for Solids Removal ................... 11 59 11.6.17 Sludge Thickening ............................... 11 60 11.6.18 Sludge Pressure Filtration .......................... 11 60 11.7 References ............................................. 11 61 vii Table of Contents TABLE OF CONTENTS ( Continued)

Page 12.0 POLLUTANTLOADING AND REDUCTION ESTIMATES .................... 12.1 Estimation of Unit Operation Wastewater Pollutant Concentrations . 12.1.1 Unit Operation Wastewater Data Collection ............ 12.1.2 Calculation of Pollutant Concentrations for Each Unit Operation for Each Sampling Point from EPA or Industry Supplied Sampling Data ............................ 12.1.3 Estimation of Pollutant Concentrations for Each Subcategory and Unit Operation ...................... <IP_ADDRESS> <IP_ADDRESS> <IP_ADDRESS> <IP_ADDRESS> Identification of Unit Operations Reported in the Detailed Surveys .................... Estimation of Wastewater Pollutant Concentrations for Each Unit Operation/ Subcategory Combination ................ Estimation of Applied Metal Concentrations Using Available Analytical Data ........... Modeling of Pollutant Concentrations for Each Model Site Unit Operation ........... 12.2 Estimation of Industry Baseline Pollutant Loadings .............. 12 1 12 2 12 2 12 3 12 4 12 4 12 5 12 7 12 8 12 9 12.2.1 Estimation of Baseline Pollutant Concentrations from Sites in the Metal Bearing Subcategories .............. 12 10 <IP_ADDRESS> Estimation of Effluent Pollutant Concentrations for Untreated Streams ...... 12 10 <IP_ADDRESS> Estimation of Effluent Pollutant Concentrations for Treated Streams ........ 12 11 <IP_ADDRESS> Estimation of Commingled Effluent Pollutant Concentrations from Sites ............... 12 14 12.2.2 Estimation of Baseline Pollutant Concentrations from Sites in the Oil Bearing Subcategories ................ 12 15 <IP_ADDRESS> Estimation of Baseline Pollutant Concentrations from Sites in the Shipbuilding Dry Dock Subcategory .................. 12 15 <IP_ADDRESS> Estimation of Baseline Pollutant Concentrations from Sites in the Railroad Line Maintenance Subcategory ........... 12 16 <IP_ADDRESS> Estimation of Baseline Pollutant Concentrations from Sites in the Oily Wastes Subcategory .......................... 12 16 12.2.3 Estimation of Model Site Baseline Loadings ........... 12 17 12.2.4 Estimation of Industry Wide Baseline Pollutant Loadings . 12 17 viii Table of Contents TABLE OF CONTENTS ( Continued)

Page 12.3 Estimation of Industry Option Pollutant Loadings .............. 12 18 12.3.1 Estimation of Industry Option Pollutant Loadings for Sites in the Metal Bearing Subcategories.................. 12 18 12.3.2 Estimation of Industry Option Pollutant Loadings for Sites in the Shipbuilding Dry Dock Subcategory ............ 12 19 12.3.3 Estimation of Industry Option Pollutant Loadings for Sites in the Railroad Line Maintenance Subcategory ......... 12 19 12.3.4 Estimation of Industry Option Pollutant Loadings for Sites in the Oily Wastes Subcategory ..................... 12 19 12.4 Estimation of Pollutant Reductions .......................... 12 20 13.0 NON  WATER QUALITY IMPACTS ................................... 13 1 13.1 Energy Requirements...................................... 13 1 13.2 Air Emissions Impacts ..................................... 13 2 13.3 Solid Waste Generation .................................... 13 3 13.4 References .............................................. 13 4 14.0 LONG TERM AVERAGES AND EFFLUENT LIMITATIONS AND STANDARDS .... 14 1 14.1 General Metals Subcategory ................................ 14 1 14.2 Metal Finishing Job Shops Subcategory ....................... 14 2 14.3 Non Chromium Anodizing Subcategory ....................... 14 2 14.4 Printed Wiring Board Subcategory ........................... 14 2 14.5 Steel Forming and Finishing Subcategory ...................... 14 2 14.6 Oily Wastes Subcategory ................................... 14 2 14.6.1 Best Practicable Control Technology ( BPT) ............. 14 2 14.6.2 Best Conventional Pollutant Control Technology ( BCT) ... 14 4 14.6.3 Best Available Technology Economically Achievable ( BAT) .......................................... 14 4 14.6.4 New Source Performance Standards ( NSPS) ............ 14 4 14.6.5 Pretreatment Standards for Existing Sources ( PSES) ...... 14 4 14.6.6 Pretreatment Standards for New Sources ( PSNS) ........ 14 4 14.7 Railroad Line Maintenance Subcategory....................... 14 5 14.8 Shipbuilding Dry Dock Subcategory .......................... 14 5 15.0 IMPLEMENTATION ............................................... 15 1 15.1 Applicability of the MP& M Effluent Guidelines ................ 15 1 15.1.1 MP& M Industrial Sectors ........................... 15 2 15.1.2 Regulated Subcategory in the MP& M Effluent Guidelines . 15 3 15.1.3 Facilities Not Subject to the MP& M Effluent Guidelines .. 15 3 15.2 Compliance Dates ........................................ 15 9 15.3 Limits Development....................................... 15 9 ix Table of Contents TABLE OF CONTENTS ( Continued)

Page 15.4 Compliance Monitoring................................... 15 12 15.5 References ............................................. 15 13 16.0 GLOSSARY OF TERMS ............................................ 16 1 Appendix A  EXAMPLE NAICS AND SIC CODES FOR THE METAL PRODUCTS & MACHINERY FINAL EFFLUENT LIMITATIONS GUIDELINES AND STANDARDS Appendix B  ANALYTICAL METHODS AND BASELINE VALUES FOR THE METAL PRODUCTS AND MACHINERY INDUSTRY Appendix C  WASTEWATER CHARACTERISTICS Appendix D  POLLUTION PREVENTION AND WATER CONSERVATION PRACTICES Appendix E  MODIFIED DELTA LOGNORMAL DISTRIBUTION x List of Tables LIST OF TABLES Page 1 1 Clarification of Coverage by Proposed MP& M Subcategory .............. 1 6 1 2 Technology Bases for Promulgated MP& M Limitations and Standards ...... 1 9 1 3 Effluent Limitations Guidelines for the MP& M Point Source Category ( 40 CFR 438) ................................................... 1 9 2 1 Summary of Regulatory Levels of Control ............................ 2 4 2 2 Summary of Metals Industry Effluent Guidelines ....................... 2 9 3 1 1989 and 1996 MP& M Survey Mailout Results ........................ 3 5 3 2 Summary of 1996 Detailed Survey Information by Question Number ...... 3 18 3 3 Number of Sites Visited Within Each Proposed Industrial Sector ......... 3 35 3 4 Number of Sites Sampled Within Each Proposed Industrial .............. 3 39 3 5 Metal Constituents Measured Under the MP& M Sampling Program ....... 3 42 3 6 Organic Constituents Measured Under the MP& M Sampling Program ..... 3 43 3 7 Additional Parameters Measured Under the MP& M Sampling Program .... 3 47 4 1 Wastewater Discharging MP& M facilities by Sector .................... 4 5 4 2 Types of Proposed MP& M operations .............................. 4 13 4 3 List of MP& M Oily Operations .................................... 4 15 4 4 List of MP& M Metal Bearing Operations............................ 4 16 4 5 Estimated Number of MP& M Facilities Discharging Process Wastewater by Proposed MP& M Operation and Estimated Annual Discharge for Each Proposed MP& M Operation ............................... 4 36 5 1 Number of Process Water and Rinse Water Samples For Oily Operations .... 5 2 5 2 Process Water Pollutant Concentration Data for Oily Operations ........... 5 3 xi List of Tables LIST OF TABLES ( Continued)

Page 5 3 Rinse Water Pollutant Concentration Data for Oily Operations ............ 5 8 5 4 MP& M Pollutant Concentration Data for the Influent to Oily Wastewater Treatment Systems.............................................. 5 14 6 1 Final Subcategories Evaluated in the Final Rule ........................ 6 2 6 2 Oily Operations as Defined by the Final Rule .......................... 6 3 6 3 Metal Bearing Operations as Defined by the Final Rule .................. 6 4 6 4 Percentage of Facilities Performing Proposed MP& M Operations Using Multiple Metal Types by Subcategory........................... 6 6 6 5 Percentage of Facilities Performing Proposed MP& M Operations by Subcategory Using Each Metal Type .............................. 6 8 7 1 Pollutants Not Detected in Any Samples Collected During the Phase I and Phase II MP& M Sampling Programs ....................... 7 4 7 2 Pollutants Detected in Less Than Three Samples Collected During the Phase I and Phase II MP& M Sampling Programs .............. 7 6 7 3 Pollutants Detected at Average Concentrations of Less Than Five Times the Minimum Level During the Phase I and Phase II MP& M Sampling Programs .............................................. 7 7 7 4 Summary of Pollutants of Concern Information ........................ 7 8 7 5 Pollutants Considered for Regulation for Direct Dischargers in the Oily Wastes Subcategory ......................................... 7 15 8 1 MP& M Flow Reduction Technologies ............................... 8 3 8 2 MP& M In Process Pollution Prevention Technologies .................. 8 10 8 3 MP& M Preliminary and End of Pipe Treatment Technologies ........... 8 32 9 1 Technology Options by Subcategory ................................ 9 37 9 2 Summary of Technology Bases for the Final Rule ..................... 9 38 xii List of Tables LIST OF TABLES ( Continued)

Page 10 1 Oily Wastes Subcategory Oil/ Water Separation ....................... 10 3 10 2 Unit Operations at Each Episode ................................... 10 5 10 3 Effluent Data Before Aggregation ................................. 10 10 10 4 Data After Aggregation ( i. e., Daily Values) ......................... 10 11 10 5 Episode Long Term Averages and Daily Variability Factors ............ 10 15 10 6 Option Long Term Averages, Daily Variability Factors, and Limitations .. 10 17 10 7 Daily Maximum Limitations: Proposal, NODA, and Final Rule ......... 10 22 11 1 Incremental Capital and O& M Costs................................ 11 2 11 2 Incremental Annualized Costs ..................................... 11 4 11 3 Information Contained in MSP1 ................................... 11 8 11 4 Information Contained in MSP2 .................................. 11 10 11 5 Treatment Technologies Considered Equivalent to the Option Technologies ................................................. 11 13 11 6 Information Contained in MSP3 .................................. 11 15 11 7 Components of Total Capital Investment ........................... 11 19 11 8 Costs for Contracted Off Site Treatment/ Disposal of Various Waste Types 11 21 11 9 RS Means Building Construction Historical Cost Indexes .............. 11 22 11 10 Monitoring Frequencies Used to Develop Part 438 Limitations Considered for Metal Bearing Subcategories ................................. 11 23 11 11 Wastewater Treatment Technologies and Source Reduction and Recycling Practices for Which EPA Developed Cost Modules ................... 11 26 11 12 List of Unit Operations Feeding Each Treatment Unit or In Process Technology .................................................. 11 27 xiii List of Tables LIST OF TABLES ( Continued)

Page 11 13 MP& M Equipment Cost Equations ................................ 11 43 11 14 Logic Used for Off Site Treatment and Disposal Cost Estimates ......... 11 50 11 15 Treatment Technologies That Use Feed Systems ..................... 11 51 11 16 Treatment Dosage Information ................................... 11 52 12 1 POTW Removal Percentages For Each MP& M Pollutant of Concern .... 12 22 12 2 Summary of Baseline Annual Pollutant Loadings Discharged by Subcategory .................................................. 12 26 12 3 Summary of Selected Option Annual Pollutant Loadings Discharged by Subcategory .................................................. 12 28 12 4 Industry Pollutant Removals in Pounds ( for Direct Dischargers) ......... 12 30 12 5 Industry Pollutant Removals in Pound Equivalents ................... 12 31 13 1 Energy Usage for the Selected Technology Option ..................... 13 1 13 2 Waste Oil Removed by the Selected Option .......................... 13 3 14 1 BPT Effluent Limitations for the Oily Wastes Subcategory .............. 14 3 15 1 Clarification of Coverage by MP& M Subcategory Evaluated for the Final Rule.................................................. 15 5 15 2 Effluent Limitations Guidelines for the MP& M Point Source Category ( 40 CFR 438) ................................................. 15 11 16 1 Priority and Nonconventional Organic Pollutants Comprising the Total Organics Parameter............................................ 16 12 xiv List of Figures LIST OF FIGURES Page 3 1 Percentage of 1989 and 1996 MP& M Surveys Returned and Percentage of Survey Respondents Performing Proposed MP& M Operations ............ 3 6 3 2 Number of Facilities Performing Proposed MP& M Operations Visited and Sampled by Industrial Sector ...................................... 3 36 4 1 Percentage of Wastewater Discharging MP& M facilities and Percentage of Annual Wastewater Discharge by Number of Employees ................. 4 3 4 2 Estimated Number of Wastewater Discharging MP& M facilities by EPA Region.................................................. 4 4 4 3 Percentage of Wastewater Discharging MP& M facilities and Percentage of Total Annual Discharge by Activity ................................. 4 7 4 4 Percentage of Wastewater Discharging MP& M facilities and Percentage of Total Annual Discharge by Discharge Status .......................... 4 8 4 5 Percentage of Wastewater Discharging MP& M facilities and Percentage of Total Annual MP& M Discharge by Flow Rate Range ................... 4 9 4 6 Percentage of Screener Survey Respondents Using Each Zero Discharge Method ....................................................... 4 11 4 7 Percentage of Wastewater Discharging MP& M facilities by Number of Metal Processed ................................................ 4 35 6 1 Percentage of Wastewater  Discharging Facilities Evaluated for the Final Rule by Decade Built ........................................... 6 15 8 1 Countercurrent Cascade Rinsing .................................... 8 5 8 2 Machine Coolant Recycling System ................................ 8 14 8 3 Centrifugation and Recycling of Painting Water Curtains ............... 8 15 8 4 Electrodialysis Cell ............................................. 8 17 8 5 Membrane Filtration Unit ........................................ 8 21 xv List of Figures LIST OF FIGURES ( Continued)

Page 8 6 Ion Exchange .................................................. 8 22 8 7 Chemical Reduction of Hexavalent Chrome .......................... 8 35 8 8 Cyanide Destruction Through Alkaline Chlorination ................... 8 37 8 9 Chemical Reduction / Precipitation of Chelated Metals ................. 8 40 8 10 Continuous Chemical Emulsion Breaking Unit with Coalescing Plates ..... 8 42 8 11a Disk Oil Skimming Unit ......................................... 8 44 8 11b Belt Oil Skimming Unit ......................................... 8 45 8 12 Dissolved Air Flotation Unit ...................................... 8 47 8 13 Continuous Chemical Precipitation System with Lamella Clarifier ........ 8 49 8 14 Effect of pH on Hydroxide and Sulfide Precipitation ................... 8 51 8 15 Center Feed Rim Flow Clarifier ................................... 8 55 8 16 Multimedia Filtration System ..................................... 8 58 8 17 Gravity Thickening ............................................. 8 60 8 18 Plate and Frame Filter Press ...................................... 8 61 8 19 Rotary Vacuum Filter............................................ 8 62 9 1 End of Pipe Treatment Train for Options 1 and 2 Considered for the Following Subcategories: General Metals, Metal Finishing Job Shops, Non Chromium Anodizing, Printed Wiring Board, and Steel Forming and Finishing ..................................................... 9 39 9 2 In Process Water Use Reduction Technologies for Options 2 and 4 Considered for the Following Subcategories: General Metals, Metal Finishing Job Shops, Non Chromium Anodizing, Printed Wiring Board, and Steel Forming and Finishing ................................... 9 40 xvi List of Figures LIST OF FIGURES ( Continued)

Page 9 3 End of Pipe Treatment Train for Options 3 and 4 Considered for the Following Subcategories: General Metals, Metal Finishing Job Shops, Non Chromium Anodizing, Printed Wiring Board, and Steel Forming and Finishing .................................................. 9 41 9 4 End of Pipe Treatment Train for Options 5 and 6 Considered for the Following Subcategories: Oily Wastes and Railroad Line Maintenance ..... 9 42 9 5 End of Pipe Treatment Train for Option 7 and 8 Considered for the Following Subcategories: Oily Wastes, Railroad Line Maintenance, Shipbuilding Dry Dock .......................................... 9 42 9 6 End of Pipe Treatment Train for Options 9 and 10 Considered for the Following Subcategories: Railroad Line Maintenance and Shipbuilding Dry Dock ..................................................... 9 43 11 1 Relationship Between In Process and End of Pipe Technologies and Practices ..................................................... 11 62 11 2 Components of Total Capital Investment ........................... 11 63 11 3 Logic Used to Apply End of Pipe Technologies and Practices for the Following Subcategories: General Metals, Metal Finishing Job Shops, Non Chromium Anodizing, Printed Wiring Board, and Steel Forming and Finishing ................................................. 11 64 11 4 Logic Used to Apply End of Pipe Technologies and Practices for the Following Subcategories30: Oily Wastes, Railroad Line Maintenance, and Shipbuilding Dry Dock ...................................... 11 65 11 5 Example Treatment Facility for General Metals Subcategory Direct Discharger ................................................... 11 66 15 1 MP& M Permitting Process Flow Chart............................. 15 10 xvii 1.0  Summary and Scope of the Regulation 1.0 SUMMARY AND SCOPE OF THE REGULATION This section presents a brief overview of the Metal Products and Machinery ( MP& M) Point Source Category, discusses the applicability of the MP& M effluent limitations guidelines and standards for the category, and presents the applicability interface between the final rule and other regulations for the metals industry. This section also briefly summarizes the final rule and describes the Agency s efforts to protect confidential business information. This section is organized as follows:

&   Section 1.1  Overview of the MP& M Point Source Category;

&   Section 1.2  Overlap with other effluent guidelines;

&   Section 1.3  Summary of applicability;

& Section 1.4  Promulgated effluent limitations guidelines and standards; and &   Section 1.5  Protection of confidential business information.

1.1 Overview of the MP& M Point Source Category The MP& M Point Source Category includes facilities that discharge wastewater from processing metal parts, metal products, and machinery. This processing can be described by two types of activities: manufacturing and rebuilding/ maintenance. Manufacturing is the series of unit operations necessary to produce metal products and is generally performed in a production environment. Rebuilding/ maintenance is the series of unit operations necessary to disassemble used metal products into components, replace the components or subassemblies or restore them to original function, and reassemble the metal product. Rebuilding and maintenance operations are intended to keep metal products in operating condition and can be performed in either a production or a nonproduction environment. The MP& M Point Source Category encompasses manufacturing, rebuilding, or maintenance of metal parts, products, or machines for use in the following industrial sectors:

&   Aerospace;

&   Aircraft;

&   Bus and Truck;

&   Electronic Equipment;

&   Hardware;

&   Household Equipment;

&   Instruments;

&   Mobile Industrial Equipment;

&   Motor Vehicle;

&   Office Machine;

1 1 1.0  Summary and Scope of the Regulation &   Ordnance;

&   Precious Metals and Jewelry;

&   Railroad;

&   Ships and Boats;

&   Stationary Industrial Equipment; and &   Miscellaneous Metal Products.

EPA also evaluated manufacturing, rebuilding, or maintenance of metal parts, products, or machines used in two other industrial sectors ( Job Shops and Printed Wiring Board) but has decided not to regulate them as part of the final rule.

These sectors considered by EPA for regulation manufacture, maintain, and rebuild metal products under more than 200 different Standard Industrial Classification ( SIC) codes. Appendix A includes a list of example SIC codes and North American Industrial Classification System ( NAICS) codes that apply to the above industrial sectors. EPA is not revising limitations and standards for three proposed industrial sectors ( i. e., job shops, printed wiring board, and steel forming and finishing).

The final rule does not apply to maintenance or repair of metal parts, products, or machines that takes place only as ancillary activities at facilities not included in the 16 MP& M industrial sectors. EPA estimates that these ancillary repair and maintenance activities would typically discharge de minimis quantities of process wastewater. For example, wastewater discharges from repair of metal parts at oil and gas extraction facilities ( 40 CFR 435) are not subject to the final rule. The Agency has determined that permit writers are establishing limits using best professional judgment ( BPJ) to regulate wastewater discharges from ancillary waste streams for direct dischargers ( see 66 FR 433).

Facilities in any one of the 16 industrial sectors in the MP& M Point Source Category are subject to the final rule only if they directly discharge process wastewater resulting from one or more of the following   oily operations:

&   Abrasive Blasting;

&   Adhesive Bonding;

&   Alkaline Cleaning for Oil Removal;

&   Alkaline Treatment Without Cyanide;

&   Aqueous Degreasing;

&   Assembly/ Disassembly;

&   Burnishing;

&   Calibration;

&   Corrosion Preventative Coating ( as specified at 40 CFR 438.2( c) and Appendix C of Part 438);

&   Electrical Discharge Machining;

&   Floor Cleaning ( in Process Area);

&   Grinding;

1 2 1.0  Summary and Scope of the Regulation &   Heat Treating;

&   Impact Deformation;

&   Iron Phosphate Conversion Coating;

&   Machining;

&   Painting Spray or Brush ( Including Water Curtains);

&   Polishing;

&   Pressure Deformation;

&   Solvent Degreasing;

&   Steam Cleaning;

&   Testing ( e. g., hydrostatic, dye penetrant, ultrasonic, magnetic flux);

&   Thermal Cutting;

&   Tumbling/ Barrel Finishing/ Mass Finishing/ Vibratory Finishing;

&   Washing ( Finished Products);

&   Welding;

&   Wet Air Pollution Control for Organic Constituents; and &   Suboperations within the operations listed above ( see Section 5.0).

These operations are defined in Appendix B to 40 CFR 438 and also in Section 4.0.

In addition, the final rule covers process wastewater resulting from associated rinses that remove materials that the processes listed above deposit on the surface of the work piece. The final rule does not apply to direct discharges of wastewaters that are otherwise covered by other effluent limitations guidelines.

The final rule also covers direct discharges of process wastewater generated from oily operations related to maintenance and repair of metal products, parts, and machinery at military installations ( i. e., federal facilities) as well as facilities owned or operated by state or local governments. For example, the final rule covers direct discharges of process wastewater generated from oily operations related to maintenance and repair of aircraft, cars, trucks, buses, tanks ( or other armor personnel carriers), and industrial equipment. These operations are commonly performed at military installations and state or local government maintenance facilities. However, the final rule does not apply to wastewater discharges introduced into a federally owned and operated Treatment Works Treating Domestic Sewage ( TWTDS), as defined at 40 CFR 122.2.

The MP& M Point Source Category evaluated for the final rule encompasses more than 41,000 facilities that manufacture, rebuild, or maintain metal parts, products, or machines for use in the 16 MP& M industrial sectors. Approximately 29,000 of these facilities annually discharge 5.02 billion gallons of process wastewater. Of the facilities discharging process wastewater, EPA estimates that 91.6 percent are indirect dischargers, 8.4 percent are direct dischargers, and 0.1 percent discharge both directly and indirectly. The Agency estimates that the remaining facilities ( an estimated 12,000) fall into one of three categories:

1 3 1.0  Summary and Scope of the Regulation & Zero discharge. A zero discharging facility does not discharge pollutants to waters of the United States or to a POTW. Included in this definition are discharge or disposal of pollutants by way of evaporation, deep well injection, off site transfer to a treatment facility, and land application.

& Non water using. A non water using facility does not use process wastewater ( i. e., water that comes into direct contact with or results from the production or use of any raw material, intermediate product, finished product, by product, or waste product) at its oily operation.

& Contract haulers. Contract hauling is the removal of any waste stream from a facility by a company authorized to transport and dispose of the waste, excluding discharges to sewers or surface waters.

The MP& M final rule does not regulate indirect dischargers and discharges to federally owned and operated TWTDS. There are approximately 2,400 direct dischargers regulated by the MP& M final rule.

MP& M sites evaluated for the final rule perform a wide variety of process unit operations on metal parts, products, or machines. In general, MP& M unit operations can be characterized as belonging to one of the following types of unit operations:

&   Assembly/ disassembly operations;

&   Metal shaping operations;

&   Organic chemical deposition operations;

&   Surface finishing operations; and &   Surface preparation operations.

EPA also evaluated the following types of unit operations but has decided not to regulate them as part of the final rule:

&   Dry dock operations; and &   Metal deposition operations.

Specifically, EPA decided not to regulate   metal bearing operations  as defined in 40 CFR 438.2( d) and Appendix C to Part 438. The list of unit operations not regulated by the final rule is also given in Section 4.0.

At a given MP& M facility, the specific unit operations performed and the sequence of those operations depend on many factors, including the activity ( i. e., manufacturing, rebuilding, or maintenance), industrial sector, and type of product processed. The extent to which a facility uses process water for these unit operations also varies from site to site.

1 4 1.0  Summary and Scope of the Regulation The approximately 2,400 sites regulated by the MP& M final rule discharge approximately 267 million gallons of process wastewater per year. This wastewater typically contains total suspended solids, oil and grease, and organic pollutants. MP& M wastewater may also contain some metals ( e. g., zinc, tin, aluminum), often in suspended or particulate phase.

1.2 Overlap with Other Effluent Guidelines EPA has previously established effluent limitations guidelines and standards for 13 industries that may perform unit operations or process parts that are sometimes found at MP& M sites. These effluent guidelines are:

&   Electroplating ( 40 CFR 413);

&   Iron and Steel Manufacturing ( 40 CFR 420);

&   Nonferrous Metals Manufacturing ( 40 CFR 421);

&   Ferroalloy Manufacturing ( 40 CFR 424);

&   Metal Finishing ( 40 CFR 433);

&   Battery Manufacturing ( 40 CFR 461);

&   Metal Molding and Casting ( 40 CFR 464);

&   Coil Coating ( 40 CFR 465);

&   Porcelain Enameling ( 40 CFR 466);

&   Aluminum Forming ( 40 CFR 467);

&   Copper Forming ( 40 CFR 468);

&   Electrical and Electronic Components ( 40 CFR 469); and &   Nonferrous Metals Forming & Metal Powders ( 40 CFR 471).

In 1986, the Agency reviewed coverage of these regulations and identified a significant number of metals processing facilities discharging wastewater that these 13 regulations did not cover. Based on this review, EPA performed a more detailed analysis of these unregulated sites and identified the discharge of significant amounts of pollutants ( see Section 1.1 of the rulemaking record, DCN M432). This analysis resulted in the decision to develop national limitations guidelines and standards for the   Metal Products and Machinery  ( MP& M) Point Source Category ( see Section 2.2.5).

Table 1 1 summarizes the coverage of industrial operations by each MP& M subcategory for which EPA proposed regulations. Additionally, the MP& M final rule does not apply to process wastewaters from metal bearing operations ( as defined at § 438.2( d) and Appendix C of Part 438) or process wastewaters that are subject to the limitations and standards of other effluent limitations guidelines ( e. g., Metal Finishing ( 40 CFR 433) or Iron and Steel Manufacturing ( 40 CFR 420)).

1 5 1.0  Summary and Scope of the Regulation Table 1 1 Clarification of Coverage by Proposed MP& M Subcategory Proposed Subcategory Continue to Cover Under 40 CFR 413 ( Electroplating) Continue to Cover Under 40 CFR 433 ( Metal Finishing) Cover Under 40 CFR 438 ( Metal Products & Machinery)

General Metals ( Including Continuous Electroplaters) Existing indirect dischargers covered by Part 413. New and existing direct and indirect dischargers covered by Part 433. None Metal Finishing Job Shops Existing indirect dischargers covered by Part 413. New and existing direct and indirect dischargers covered by Part 433.

Non Chromium Anodizing Existing indirect dischargers covered by Part 413. New and existing direct and indirect dischargers covered by Part 433.

Printed Wiring Board ( Printed Circuit Board) Existing indirect dischargers covered by Part 413. New and existing direct and indirect dischargers covered by Part 433.

Steel Forming and Finishinga NA NA Oily Wastes NA NA Railroad Line Maintenance NA NA None None None None All new and existing direct dischargers ( see 438.10).

None Shipbuilding Dry Dock NA NA None NA  Not applicable. a These facilities will remain subject to 40 CFR 420.

1 6 1.0  Summary and Scope of the Regulation 1.3 Summary of Applicability The MP& M effluent limitations guidelines and standards regulate process wastewater from oily operations at existing or new direct dischargers engaged in manufacturing, rebuilding, or maintenance of metal parts, products, or machines used in any of the 16 industrial sectors listed in Section 1.1. The guidelines and standards do not apply to wastewater from oily operations in certain circumstances ( e. g., if they are subject to other national effluent limitations or standards). The MP& M regulation does not regulate any of the other subcategories for which it proposed regulations. These subcategories are the General Metals, Metal Finishing Job Shops, Non Chromium Anodizing, Printed Wiring Board, Steel Forming and Finishing, Railroad Line Maintenance, and Shipbuilding Dry Dock. Process wastewater is defined in § 438.2.

EPA defines process wastewater for the final rule to include wastewater discharges from oily operations for the manufacturing, rebuilding, or maintenance of metal parts, products, or machinery for use in any of the 16 MP& M industrial sectors and wastewater from air pollution control devices.

EPA notes that direct discharges resulting from the washing of cars, aircraft, or other vehicles, when performed as a prepatory step prior to one or more successive manufacturing, rebuilding, or maintenance operations, are subject to the MP& M rule.

Nonprocess wastewater discharges are not subject to the final rule. Nonprocess wastewater means sanitary wastewater, noncontact cooling water, water from laundering, and noncontact stormwater. Nonprocess wastewater for this part also includes wastewater discharges from nonindustrial sources such as residential housing, schools, churches, recreational parks, shopping centers as well as wastewater discharges from gas stations, utility plants, and hospitals.

In addition to nonprocess wastewater, the final rule does not apply to wastewater generated from: ( 1) gravure cylinder and metallic platemaking conducted within or for printing and publishing facilities; ( 2) the washing of cars, aircraft or other vehicles when it is performed only for aesthetic/ cosmetic purposes; ( 3) MP& M operations at gasoline stations ( SIC Code 5541) or vehicle rental facilities ( SIC Codes 7514 or 7519); or ( 4) unit operations performed by drum reconditioners/ refurbishers to prepare metal drums for reuse.

As noted, EPA is also not promulgating limitations and standards for facilities in the proposed Shipbuilding Dry Dock Subcategory. The final rule does not cover wastewater generated on board ships and boats when they are afloat ( that is, not in dry docks or similar structures), flooding water, and dry dock ballast water ( see 66 FR 445). For U. S. military ships, EPA is in the process of establishing standards to regulate discharges of wastewater generated on board these ships when they are in U. S. waters and are afloat under the Uniform National Discharge Standards ( UNDS) pursuant to section 312( n) of the Clean Water Act ( CWA) ( see 64 FR 25125, May 10, 1999).

1 7 1.0  Summary and Scope of the Regulation Finally, as previously stated, the final rule does not apply to maintenance or repair of metal parts, products, or machines that takes place only as ancillary activities at facilities not included in the 16 MP& M industrial sectors.

See Section 15.0 for a more detailed discussion regarding applicability.

1.4 Promulgated Effluent Limitations Guidelines and Standards EPA proposed effluent limitations and standards for eight subcategories. However, for reasons discussed in Section 9.0 and Section VI of the preamble to the final rule, the final rule establishes effluent limitations guidelines and standards for new and existing direct dischargers in one subcategory: Oily Wastes.

EPA may divide a point source category ( e. g., MP& M) into groupings called   subcategories  to provide a method for addressing variations between products, raw materials, processes, and other factors that result in distinctly different effluent characteristics. Regulation of a category using subcategories allows each subcategory to have a uniform set of effluent limitations that take into account technological achievability and economic impacts unique to that subcategory. Grouping similar facilities into subcategories increases the likelihood that the regulations are practicable, and diminishes the need to address variations between facilities through a variance process. The CWA requires EPA, in developing effluent limitations guidelines and pretreatment standards, to consider a number of different subcategorization factors. ( See Section 6.0 for a list of the factors considered for the final MP& M rule and a detailed discussion of subcategorization.)

EPA is promulgating concentration based limits and standards for direct dischargers for the Oily Wastes Subcategory. However, the CWA authorizes permit writers to decide when it is most appropriate to implement mass based limits. Guidance for setting limits is included in Section 15.0.

Table 1 2 summarizes the regulatory levels of control and selected technology bases EPA used in promulgating the limitations and standards presented in Table 1 3, Section 14.0, and 40 CFR 438, Subpart A ( Oily Wastes Subcategory). Section 15.0 provides guidance to permit writers.

1 8 1.0  Summary and Scope of the Regulation Table 1 2 Technology Bases for Promulgated MP& M Limitations and Standards Regulatory Level Selected Technology Option Subcategory Oily Wastes BPT/ BCT/ NSPS Pollution prevention; chemical emulsion breaking and oil/ water separation ( Option 6). n 9.7. See Sectio BAT No limitations established under Part 438.

PSES/ PSNS No standards established under Part 438.

Table 1 3 Effluent Limitations Guidelines for the MP& M Point Source Category ( 40 CFR 438)

BPT/ BCT/ NSPS  Oily Wastes Subcategory Regulated Parameter Maximum Daily mg/ L ( ppm)

Total Suspended Solids ( TSS) 62 Oil and Grease ( as HEM) 46 pH a aDischarges must remain within the pH range 6 to 9.

Protection of Confidential Business Information Whenever EPA is required to develop effluent limitations, pretreatment standards, or other standards, Section 308( a) of the CWA authorizes the Agency to require owners or operators of point sources to provide certain information. Various statutes under which EPA operates contain special provisions concerning the entitlement to confidential treatment of certain business information ( CBI). In compliance with these statutes and EPA s implementing regulations, the Agency has withheld CBI from the public record in the Water Docket, but retains CBI in the nonpublic version of the rulemaking record. In addition, the Agency has withheld from disclosure some data not claimed as CBI because the release of these data could indirectly reveal CBI. Furthermore, EPA has aggregated certain data in the public record, masked facility identities, or used other strategies to prevent the disclosure of CBI. The Agency s approach to CBI protection ensures that the data in the public record both explain the basis for the final rule and provide the opportunity for public comment, without compromising data confidentiality.

1 9 1.5 2.0  Background 2.0 BACKGROUND This section presents background information supporting the development of effluent limitations guidelines and standards for the Metal Products and Machinery ( MP& M) Point Source Category. Section 2.1 presents the legal authority to regulate the MP& M industry. Section 2.2 discusses the Clean Water Act, Pollution Prevention Act, Regulatory Flexibility Act ( as amended by the Small Business Regulatory Enforcement Fairness Act of 1996), and prior regulation of the metals industry.

2.1 Legal Authority EPA is promulgating these regulations under the authority of Sections 301, 304, 306, 307, 308, 402, and 501 of the Clean Water Act, 33 U. S. C. 1311, 1314, 1316, 1317, 1318, 1342, and 1361 and under authority of the Pollution Prevention Act of 1990 ( PPA), 42 U. S. C. 13101 et seq., Public Law 101 508, November 5, 1990.

2.2 Regulatory Background 2.2.1 Clean Water Act Congress adopted the Clean Water Act ( CWA) to    restore and maintain the chemical, physical, and biological integrity of the Nation s waters   ( Section 101( a), 33 U. S. C. 1251( a)). To achieve this goal, the CWA prohibits the discharge of pollutants into navigable waters except in compliance with the statute. The CWA confronts the problem of water pollution on a number of different fronts. Its primary reliance, however, is on establishing restrictions on the types and amounts of pollutants discharged from various industrial, commercial, and public sources of wastewater.

Congress recognized that regulating only those sources that discharge effluent directly into the nation s waters would not be sufficient to achieve the CWA s goals. Consequently, the CWA requires EPA to promulgate nationally applicable pretreatment standards that restrict pollutant discharges for those who discharge wastewater indirectly through sewers flowing to publicly owned treatment works ( POTWs) ( Sections 307( b) and ( c), 33 U. S. C. 1317( b) and ( c)). National pretreatment standards are established for those pollutants in wastewater from indirect dischargers that may pass through or interfere with POTW operations. Generally, pretreatment standards are designed to ensure that wastewater from direct and indirect industrial dischargers are subject to similar levels of treatment. In addition, EPA requires POTWs to implement local pretreatment limits applicable to their industrial indirect dischargers to satisfy any local requirements ( 40 CFR 403.5).

Direct dischargers must comply with effluent limitations in National Pollutant Discharge Elimination System (   NPDES  ) permits; indirect dischargers must comply with pretreatment standards. EPA establishes these limitations and standards by regulation for 2 1 2.0  Background categories of industrial dischargers and bases them on the degree of control that can be achieved using various levels of pollution control technology.

1. Best Practicable Control Technology Currently Available ( BPT) ( Section 304( b)( 1) of the CWA)

BPT effluent limitations guidelines are applicable to direct dischargers ( i. e., sites that discharge wastewater to surface water). BPT effluent limitations guidelines are generally based on the average of the best existing performance by facilities of various sizes, ages, unit processes or other common characteristics within the category or subcategory for control of conventional, priority, and nonconventional pollutants. Section 304( a)( 4) designates the following as conventional pollutants: biochemical oxygen demand ( BOD5 ), total suspended solids ( TSS), fecal coliform, pH, and any additional pollutants defined by the Administrator as conventional. The Administrator designated oil and grease as an additional conventional pollutant on July 30, 1979 ( 44 FR 44501). EPA has identified 65 pollutants and classes of pollutants as toxic pollutants, of which 126 specific substances have been designated priority toxic pollutants. See Appendix A to Part 403 ( reprinted after 40 CFR 423.17). All other pollutants are considered to be nonconventional.

In establishing BPT effluent limitations guidelines, EPA first considers the total cost of applying the control technology in relation to the effluent reduction benefits. The Agency also considers the age of the equipment and facilities involved, the processes employed and any required process changes, engineering aspects of the control technologies, non water quality environmental impacts ( including energy requirements), and such other factors as the EPA Administrator deems appropriate ( CWA 304( b)( 1)( B)). Traditionally, EPA establishes BPT effluent limitations based on the average of the best performances of facilities within the industry of various ages, sizes, processes or other common characteristics. Where existing performance is uniformly inadequate, EPA may require higher levels of control than are currently in place in an industrial category if the Agency determines that the technology can be practically applied.

2. Best Conventional Pollutant Control Technology ( BCT) ( Section 304( b)( 4) of the CWA)

The 1977 amendments to the CWA established BCT for discharges of conventional pollutants from existing industrial point sources. BCT effluent limitations guidelines are applicable to direct discharging sites. In addition to other factors specified in Section 304( b)( 4)( B), the CWA requires that EPA establish BCT limitations after consideration of a two

2 2 2.0  Background part " cost reasonableness" test. EPA explained its methodology for the development of BCT limitations in 1986 ( 51 FR 24974; July 9, 1986).

3. Best Available Technology Economically Achievable ( BAT) ( Sections 304( b)( 2) of the CWA)

BAT effluent limitations guidelines are applicable to direct discharging sites. In general, BAT effluent limitations guidelines represent the best available economically achievable performance of plants in the industrial subcategory or category. The CWA establishes BAT as the principal national means of controlling the direct discharge of priority pollutants and nonconventional pollutants to waters of the United States. The factors considered in assessing BAT include the cost of achieving BAT effluent reductions, the age of equipment and facilities involved, the processes employed, potential process changes, non water quality environmental impacts ( including energy requirements), and such factors as the Administrator deems appropriate. The Agency retains considerable discretion in assigning the weight to be accorded to these factors. As with BPT, where existing performance is uniformly inadequate, EPA may base BAT upon technology transferred from a different subcategory within an industry or from another industrial category. In addition, BAT may include process changes or internal controls, even when these technologies are not common industry practice.

4. New Source Performance Standards ( NSPS) ( Section 306 of the CWA)

NSPS are applicable to new direct discharging sites and are based on the best available demonstrated treatment technology. New facilities have the opportunity to install the best and most efficient production processes and wastewater treatment technologies. As a result, NSPS should represent the greatest degree of effluent reduction attainable through the application of the best available demonstrated control technology for all pollutants ( i. e., conventional, nonconventional, and priority pollutants). In establishing NSPS, the CWA directs EPA to take into consideration the cost of achieving the effluent pollutant reduction and any non water quality environmental impacts ( including energy requirements).

5. Pretreatment Standards for Existing Sources ( PSES) ( Section 307( b) of the CWA)

PSES are applicable to indirect discharging sites ( i. e., sites that discharge to a POTW). The CWA requires PSES for pollutants that pass through, interfere with, or are otherwise incompatible with POTW treatment 2 3 2.0  Background processes or sludge disposal methods. The CWA specifies that pretreatment standards are to be technology based and analogous to the BAT effluent limitations guidelines.

The General Pretreatment Standards, which set forth the framework for implementing categorical pretreatment standards, are found at 40 CFR 403.

6. Pretreatment Standards for New Sources ( PSNS) ( Section 307( c) of the CWA)

PSNS are applicable to new indirect discharging sites. Like PSES, PSNS are designed to prevent the discharges of pollutants that pass through, interfere with, or are otherwise incompatible with the operation of POTWs. PSNS are to be issued at the same time as NSPS. New indirect dischargers have the opportunity to incorporate into their plants the best available demonstrated technologies. The Agency considers the same factors in promulgating PSNS that it considers in promulgating NSPS.

The following table summarizes these regulatory levels of control and the pollutants controlled.

Table 2 1 Summary of Regulatory Levels of Control Type of Sites Regulated BPT BCT BAT NSPS PSES PSNS Existing Direct Dischargers New Direct Dischargers Existing Indirect Dischargers New Indirect Dischargers X X X X X X Pollutants Regulated BPT BCT BAT NSPS PSES PSNS Priority Pollutants Nonconventional Pollutants Conventional Pollutants X X X X X X X X X X X X X Source: Clean Water Act.

EPA typically does not establish pretreatment standards for conventional pollutants ( e. g., BOD5 , TSS, oil and grease) since POTWs are designed to treat these pollutants, but EPA has exercised its authority to establish categorical pretreatment standards for conventional pollutants as surrogates for toxic or nonconventional pollutants or to prevent interference. For example, EPA established categorical pretreatment standards for new and existing sources with a one day maximum concentration of 100 mg/ L oil and grease in the 2 4 2.0  Background Petroleum Refining Point Source Category ( 40 CFR 419) to " minimize the possibility of slug loadings of oil and grease being discharged to POTWs" ( see Section 24.4 of the rulemaking record, DCN 17949).

2.2.2 Section 304( m) Requirements Section 304( m) of the CWA, added by the Water Quality Act of 1987, requires EPA to establish schedules for: ( 1) reviewing and revising existing effluent limitations guidelines and standards; and ( 2) promulgating new effluent guidelines. On January 2, 1990, EPA published an Effluent Guidelines Plan ( see 55 FR 80), in which schedules were established for developing new and revised effluent guidelines for several industry categories, including the metal products and machinery industry.

Natural Resources Defense Council, Inc. ( NRDC) and Public Citizen, Inc. challenged the Effluent Guidelines Plan in a suit filed in the U. S. District Court for the District of Columbia, ( NRDC et al v. Browner, Civ. No. 89 2980). On January 31, 1992, the Court entered a consent decree ( the " 304( m) Decree"), which establishes schedules for, among other things, EPA's proposal and promulgation of effluent guidelines for a number of point source categories. The consent decree, as amended, requires EPA to take final action on the Metal Products and Machinery effluent guidelines by February 14, 2003.

2.2.3 Pollution Prevention Act The Pollution Prevention Act of 1990 ( PPA) ( 42 U. S. C. 13101 et seq., Public Law 101 508, November 5, 1990) " declares it to be the national policy of the United States that pollution should be prevented or reduced whenever feasible; pollution that cannot be prevented should be recycled in an environmentally safe manner, whenever feasible; pollution that cannot be prevented or recycled should be treated in an environmentally safe manner whenever feasible; and disposal or release into the environment should be employed only as a last resort..." ( Sec. 6602; 42 U. S. C. 13101 ( b)). In short, preventing pollution before it is created is preferable to trying to manage, treat or dispose of it after it is created. The PPA directs the Agency to, among other things, " review regulations of the Agency prior and subsequent to their proposal to determine their effect on source reduction" ( Sec. 6604; 42 U. S. C. 13103( b)( 2)). EPA reviewed this effluent guideline for its incorporation of pollution prevention.

According to the PPA, source reduction reduces the generation and release of hazardous substances, pollutants, wastes, contaminants, or residuals at the source, usually within a process. The term source reduction " include[ s] equipment or technology modifications, process or procedure modifications, reformulation or redesign of products, substitution of raw materials, and improvements in housekeeping, maintenance, training or inventory control. The term   source reduction' does not include any practice which alters the physical, chemical, or biological characteristics or the volume of a hazardous substance, pollutant, or contaminant through a process or activity which itself is not integral to or necessary for the production of a product or the providing of a service." 42 U. S. C. 13102( 5). In effect, source reduction means reducing the 2 5 2.0  Background amount of a pollutant that enters a waste stream or that is otherwise released into the environment prior to out of process recycling, treatment, or disposal.

EPA gathered information on pollution prevention practices used by the MP& M industry from site visits, survey responses, and other references. Typical pollution prevention practices include reducing water use, extending the life of process bath constituents, or adding recycle or reuse technologies. See Section 8.0 for a detailed discussion of these practices. EPA supports pollution prevention technology by including pollution prevention in its technology bases for the final MP& M effluent limitations and new source performance standards. This includes water conservation and reuse of lubricants and solvents. Technology options considered, as well as selected, as the basis for the MP& M effluent limitations guidelines and standards include pollution prevention practices and are discussed in Section 9.0.

2.2.4 Regulatory Flexibility Act ( RFA) as Amended by the Small Business Regulatory Enforcement Fairness Act of 1996 ( SBREFA)

The RFA generally requires an agency to prepare a regulatory flexibility analysis of any rule subject to notice and comment rulemaking requirements under the Administrative Procedure Act or any other statute unless the agency certifies that the rule will not have a significant economic impact on a substantial number of small entities. Small entities include small businesses, small organizations, and small governmental jurisdictions.

For assessing the impacts of the final rule on small entities, a small entity is defined as: ( 1) a small business according to the Regulations of the Small Business Administration ( SBA) at 13 CFR 121.201, which define small businesses for Standard Industrial Classification ( SIC) codes; ( 2) a small governmental jurisdiction that is a government of a city, county, town, school district or special district with a population of less than 50,000; and ( 3) a small organization that is any not for profit enterprise that is independently owned and operated and is not dominant in its field.

In accordance with Section 603 of the RFA, EPA prepared an initial regulatory flexibility analysis ( IRFA) for the proposed rule and convened a Small Business Advocacy Review Panel to obtain advice and recommendations of representatives of the regulated small entities in accordance with Section 609( b) of the RFA ( see 66 FR 519). The results of IRFA are provided in Chapter 10 of the Economic, Environmental, and Benefits Analysis ( EEBA) ( EPA 821 B 03 002). The January 2001 proposed rule ( see 66 FR 523) presents a summary of the Panel s recommendations and the full Panel Report ( see Section 11.2, DCN 16127) presents a detailed discussion of the Panel s advice and recommendations.

A regulatory flexibility analysis addresses:

  The need for, objectives of, and legal basis for a rule.

2 6 2.0  Background   A description of, and where feasible, an estimate of the number of small entities to which a rule would apply.

  The projected reporting, recordkeeping, and other compliance requirements of a rule, including an estimate of the classes of small entities that would be subject to a rule and the types of professional skills necessary for preparation of the report or record.

  An identification, where practicable, of all relevant federal rules that may duplicate, overlap, or conflict with a rule.

  A description of any significant regulatory alternatives to a rule that accomplish the stated objectives of applicable statutes and that minimize any significant economic impact of a rule on small entities. Consistent with the stated objectives of the CWA, the analysis discusses significant alternatives such as:

 Establishing differing compliance or reporting requirements or timetables that take into account the resources available to small entities.

 Clarifying, consolidating, or simplifying compliance and reporting requirements under the rule for such small entities.

 Using performance rather than design standards.

 Excluding from coverage of a rule, or any part thereof, such small entities. Based on the regulatory flexibility analysis and other factors, EPA considered an exclusion to eliminate disproportionate impacts on small businesses, which reduced the number of small businesses that would be affected by a rule.

The Small Business Advocacy Review Panel comprised representatives from three federal agencies: EPA, the Small Business Administration, and the Office of Management and Budget. The Panel reviewed materials EPA prepared in connection with the proposed rule IRFA, and collected the advice and recommendations of small entity representatives. For the Small Business Advocacy Review Panel, the small entity representatives included nine small MP& M facility owner/ operators, one small municipality, and these six trade associations representing different sectors of the industry:

  National Association of Metal Finishers ( NAMF)/ Association of Electroplaters and Surface Finishers ( AESF)/ MP& M Coalition;

  Association Connecting Electronics Industries ( also known as IPC);

2 7 2.0  Background   Porcelain Enamel Institute;

  American Short Line Railroad Association ( ASLRA);

  Electronics Industry Association ( EIA); and   American Wire Producers Association ( AWPA).

The Panel provided background information and analysis to the small entity representatives and conducted meetings with the representatives. The Panel asked the small entity representatives to submit written comment on the MP& M proposed rule in relation to the elements of the proposal IRFA. The Panel carefully considered these comments when developing their recommendations. The Panel s report summarizes their outreach to small entities and the comments submitted by the small entity representatives. The Panel s report also presented their findings on issues related to the elements of the proposal IRFA and recommendations regarding the rulemaking. Based on this input, EPA made several changes to the January 2001 proposal that reduced the number of small entities regulated and the level of impact to small entities that remain within the scope of the regulation.

In the final rule, EPA excluded direct dischargers in seven of eight proposed subcategories and indirect dischargers in all eight proposed subcategories. Consequently, EPA excluded most small entities from additional regulation ( see Section VI of the MP& M preamble to the final rule and Chapter 10 of the EEBA). To assess the potential economic impact of the final rule on small entities regulated by the final rule, EPA drew on: ( 1) a comparison of compliance costs to revenue; and ( 2) the firm and facility impact analyses discussed in Chapters 9 and 10 of the EEBA.

First, EPA performed an analysis comparing annualized compliance costs to revenue for small entities at the firm level. EPA found that none of the small firms are estimated to incur compliance costs equaling or exceeding one percent of annual revenue. Second, EPA drew on the facility impact analysis, which estimated facility closures and other adverse changes to financial condition ( referred to as   moderate impacts ). See Chapter 5 of the EEBA for details of EPA s analysis of closures and moderate impacts for privately owned businesses. This analysis indicated that the final rule would cause no regulated facilities owned by small entities to close or to incur moderate impacts. From these analyses, EPA determined that the final rule will not have a significant economic impact on a substantial number of small entities. See Chapter 10 of the EEBA for the final rule for a more detailed discussion of the economic impacts on small entities.

2.2.5 Regulatory History of the Metals Industry EPA has promulgated effluent limitations guidelines and standards for 13 metals industries. These regulations cover metal manufacturing, metal forming, and component finishing, as summarized below.

2 8 2.0  Background Table 2 2 Summary of Metals Industry Effluent Guidelines Coverage Area Title CFR Reference Metal and Metal Alloy Manufacturing Iron and Steel Manufacturinga Nonferrous Metals Manufacturing Ferroalloy Manufacturing 40 CFR 420 40 CFR 421 40 CFR 424 Metal Forming Iron and Steel Manufacturinga Metal Molding and Casting Aluminum Forming Copper Forming Nonferrous Metals Forming and Metal Powders 40 CFR 420 40 CFR 464 40 CFR 467 40 CFR 468 40 CFR 471 Component Finishing Electroplating Iron and Steel Manufacturinga Metal Finishing Battery Manufacturing Coil Coating Porcelain Enameling Electrical and Electronic Component Manufacturing 40 CFR 413 40 CFR 420 40 CFR 433 40 CFR 461 40 CFR 465 40 CFR 466 40 CFR 469 Source: Code of Federal Regulations , Part 40. a The Iron and Steel Manufacturing category includes metal manufacturing, metal forming, and component finishing.

In 1986, the Agency reviewed these 13 regulations and identified a significant number of metals processing facilities discharging wastewater that these regulations did not cover. Based on this review, EPA performed a detailed analysis of these unregulated sites and identified the discharge of significant amounts of pollutants. This analysis resulted in a preliminary decision to consider new regulations for a Machinery Manufacturing and Rebuilding ( MM& R) Point Source Category. In 1989, the Agency published a Preliminary Data Summary ( PDS) for the MM& R industry, which is located in the MP& M Public Record ( Section 1.1, DCN M432). The preliminary study of the unregulated MP& M facilities indicated the following:

  The number of facilities, wastewater flow, and toxic and nonconventional pollutant loads were significant;

  The large quantities of toxic pollutants discharged threatened the treatment capability of many POTWs as found by the Domestic Sewage Study;

  There were gaps in federal regulatory coverage in the electroplating, metal finishing, and electrical and electronic components categories;

  Pollutant concentrations were at treatable levels and at levels as high and sometimes higher than concentrations in wastewater from other regulated categories; and 2 9 2.0  Background   Some MP& M operations generate hazardous solid waste and sludge that could impact hazardous waste disposal.

Based on information contained in the PDS, EPA divided the MM& R category into two phases by major industrial groups or sectors. The Agency announced its schedule for the development of effluent guidelines for two separate MM& R phases in EPA s January 2, 1990 Effluent Guidelines Plan ( 55 FR 80). One of the primary reasons for dividing the category into two phases was the large number of facilities ( over 900,000) identified in the PDS as potentially included in the MM& R Point Source Category. On May 7, 1992, EPA changed the category name to Metal Products and Machinery ( MP& M) to clarify the coverage of the category ( 57 FR 19748). Many questionnaire respondents found the MM& R label confusing and interpreted the category to apply only to machinery sites. The Agency believes that the MP& M title more accurately describes the coverage of the category.

As mentioned in Section 2.2.2, NRDC and Public Citizen, Inc. challenged the Effluent Guidelines Plan in a suit filed in U. S. District Court for the District of Columbia ( NRDC et al. v. Browner, Civ. No. 89 2980). Under a consent decree in this litigation, EPA developed a plan to promulgate effluent guidelines for, among others, the MP& M Point Source Category. The 1992 Effluent Guidelines Plan provided for EPA to propose effluent guidelines for the MP& M Phase I Category by November 1994 and take final action by May 1996. Based on a motion filed by EPA on September 28, 1994, the court granted an extension for proposal and promulgation of the final regulation. To make the regulation more manageable, EPA initially divided the industry into two phases based on industrial sectors. The Phase I proposal included the following industry sectors: Aerospace; Aircraft; Electronic Equipment; Hardware; Mobile Industrial Equipment; Ordnance; and Stationary Industrial Equipment. At that time, EPA planned to propose a rule for the Phase II sectors approximately three years after the MP& M Phase I proposal. Phase II sectors included: Bus & Truck, Household Equipment, Instruments, Job Shops, Motor Vehicles, Office Machines, Precious Metals and Jewelry, Printed Wiring Boards, Railroad, Ships and Boats, and Miscellaneous Metal Products.

On May 30, 1995, EPA published the MP& M Phase I proposal ( 60 FR 28210). EPA proposed effluent limitations guidelines, pretreatment standards, and new source performance standards for the seven MP& M Phase I industrial sectors. EPA received over 350 public comments on the Phase I proposal requesting that the Agency combine all MP& M industrial sectors into one effluent guideline. Commentors raised concerns regarding the regulation of similar facilities with different compliance schedules and potentially different limitations solely based on whether they were in a Phase I or Phase II MP& M industrial sector. Furthermore, many facilities performed work in multiple sectors. In such cases, permit writers and control authorities ( e. g., POTWs) would need to decide which MP& M rule ( Phase I or II) applied to a facility.

Based on these comments and after negotiations with NRDC, EPA proposed merging the two phases into one rule ( 61 FR 35042; July 3, 1996). In 1997, EPA obtained approval from the U. S. District Court for the District of Columbia to combine MP& M Phases I 2 10 2.0  Background and II into a single regulation for the 18 MP& M industrial sectors and to extend the effluent guidelines schedule ( 62 FR 8726; February 26, 1997). Extension of the schedule allowed EPA to use POTW survey data to develop more precise estimates of administrative burden and allowed more extensive stakeholder involvement for data collection. Under the Consent Decree as amended, EPA is required to take final action on the MP& M rule by February 14, 2003.

EPA published a new proposal on January 3, 2001 ( 66 FR 424), which completely replaced the 1995 proposal. EPA proposed to establish new effluent limitations and guidelines and standards for 18 MP& M industrial sectors ( without any designation of   Phase I or II ) and divided the industry into eight regulatory subcategories: General Metals, Metal Finishing Job Shops, Printed Wiring Board, Non Chromium Anodizing, Steel Forming and Finishing, Oily Wastes, Railroad Line Maintenance, and Shipbuilding Dry Dock ( see 66 FR 439 for a discussion of the proposal subcategorization scheme).

EPA found two basic types of waste streams in the industry: ( 1) wastewater with high metals content ( metal bearing), and ( 2) wastewater with low concentration of metals and high oil and grease content ( oil bearing). When looking at facilities generating metal bearing wastewater ( with or without oil bearing wastewater), EPA identified five groups of facilities that could potentially be subcategorized by dominant product, raw materials used, and/ or nature of the waste generated ( i. e., General Metals, Metal Finishing Job Shops, Printed Wiring Board, Non Chromium Anodizing, and Steel Forming and Finishing). When evaluating facilities with only oil bearing wastewater for potential further subcategorization, EPA identified two types of facilities ( i. e., Railroad Line Maintenance and Shipbuilding Dry Dock) that were different from the other facilities in the Oily Wastes Subcategory based on size, location, and dominant product or activity. This subcategorization scheme allowed EPA to more accurately assess various technology options in terms of compliance costs, pollutant reductions, benefits, and economic impacts.

EPA proposed new limits and standards for direct dischargers in all eight MP& M subcategories and proposed pretreatment standards for all indirect dischargers in three subcategories ( i. e., Metal Finishing Job Shops, Printed Wiring Board, and Steel Forming and Finishing); pretreatment standards for facilities above a certain wastewater flow volume in two subcategories ( i. e., General Metals and Oily Wastes); and no national pretreatment standards for facilities in three subcategories ( i. e., Non Chromium Anodizing, Railroad Line Maintenance, and Shipbuilding Dry Dock). EPA received over 1,500 comment letters on the 2001 proposal.

On June 5, 2002, EPA published a Notice of Data Availability ( NODA) at 67 FR 38752. In the NODA, EPA discussed major issues raised in comments on the 2001 proposal; suggested revisions to the technical and economic methodologies used to estimate compliance costs, pollutant loadings, and economic and environmental impacts; presented the results of these suggested methodology changes and incorporation of new ( or revised) data; and summarized the Agency s thinking on how these results could affect the Agency s final decisions.

2 11 2.0  Background The NODA also included a discussion of possible alternative options for certain subcategories based on comments, including an Environmental Management System ( EMS) alternative in lieu of Part 438 limitations and standards, and a discussion of   upgrading  sites currently regulated under the Electroplating regulations ( 40 CFR 413) to meet the Metal Finishing regulations ( 40 CFR 433) ( see 67 FR 38797). Finally, the NODA included preliminary revised effluent limitations and pretreatment standards for all eight proposed subcategories. EPA received over 300 comment letters on the NODA. EPA s responses to comments on the May 1995 proposal, January 2001 proposal, and June 2002 NODA can be found in Section 20.3 of the rulemaking record.

2 12 3.0  Data Collection Activities 3.0 DATA COLLECTION ACTIVITIES This section summarizes the Agency s data collection activities for the MP& M rulemaking effort. Section 3.1 summarizes the 1989 and 1996 MP& M industry questionnaires including their purpose, recipient selection process, types of information collected, and uses of data. Sections 3.2 and 3.3 summarize the site visit and field sampling programs, respectively, conducted at facilities performing proposed MP& M operations. 1 Sections 3.4, 3.5, and 3.6 discuss other data sources.

3.1 Industry Questionnaires EPA distributed two screener and six detailed questionnaires ( surveys) as part of the data collection effort for the MP& M rulemaking. As discussed in Section 2.0, EPA initially divided the MP& M Point Source Category into two phases by major industrial sectors. The surveys distributed for the seven Phase I industrial sectors requested data reflecting 1989 operations, and the surveys distributed for the 11 Phase II industrial sectors requested data reflecting 1996 operations. The table below lists the industry surveys and the distribution dates. Sections 3.1.1 and 3.1.2 discuss these questionnaire efforts.

Distribution of the MP& M Industry Surveys Type of Survey Survey Name Distribution Date Screener 1989 Screener Survey 1996 Screener Survey 1996 Benefits Screener 8/ 90 12/ 96 10/ 98 Detailed 1989 Detailed Survey 1996 Long Detailed Survey 1996 Short Detailed Survey 1996 Municipality Detailed Survey 1996 POTW Detailed Survey 1996 Federal Detailed Survey 1/ 91 6/ 97 9/ 97 6/ 97 11/ 97 4/ 98 During the same time that EPA was developing the MP& M Point Source Category rulemaking, EPA was also updating the effluent limitations guidelines and standards for the Iron and Steel Point Source Category. As part of the revised Iron and Steel rulemaking, EPA distributed detailed and short surveys to iron and steel facilities. Following receipt of the 1997 Iron and Steel Surveys, EPA evaluated whether some facilities may be more appropriately covered under the MP& M Point Source Category.

1Note: EPA evaluated a number of unit operations for the May 1995 proposal, January 2001 proposal, and June 2002 NODA ( see Tables 4 3 and 4 4). However, EPA selected a subset of these unit operations for regulation in the final rule ( see Section 1.0). For this Section, the term   proposed MP& M operations  means those operations evaluated for the two proposals, NODA, and final rule. The term   final MP& M operations  means those operations defined as   oily operations  ( see Section 1.0, 40 CFR 438.2( f), and Appendix B to Part 438) and regulated by the final rule.

3 1 3.0  Data Collection Activities EPA included data from 154 iron and steel surveys in the MP& M survey database and proposed to create a new subcategory, the Steel Forming and Finishing Subcategory in the MP& M Point Source Category ( see 66 FR 424). Based on comments on the January 2001 proposal and June 2002 NODA EPA concluded that those operations included in the proposed Steel Forming and Finishing Subcategory should remain subject to effluent guidelines at the Iron and Steel Point Source Category ( 40 CFR 420). See Section 6.0 for further discussion of subcategorization.

For this final rule, EPA also evaluated portions of the iron and steel surveys to determine if continuous electroplaters would be more appropriately covered under the MP& M Point Source Category, as described in the Notice of Data Availability ( NODA) ( 67 FR 38752; June 5, 2002). EPA included these facilities in the General Metals Subcategory for evaluating options for the final rule. See Section 6.0 for further discussion of this determination. EPA has data for 47 continuous electroplating lines at 24 sites. The data for these lines were evaluated in developing the final MP& M effluent limitation guidelines and standards ( see Section 3.1.3 for further discussion). A blank copy of the Iron and Steel Surveys and the relevant data from the 24 surveys are available in Section 5.3.6, DCN 16147 and Section 15.4.3 of the rulemaking record.

3.1.1 The 1989 Industry Surveys EPA distributed a screener and a detailed survey for the Phase I MP& M proposed regulation to manufacturing, rebuilding, and/ or maintenance facilities engaged in the following seven industrial sectors:

  Aerospace;

  Aircraft;

  Electronic Equipment;

  Hardware;

  Mobile Industrial Equipment;

  Ordnance; and   Stationary Industrial Equipment.

The 1989 screener and detailed surveys are discussed below. EPA describes in detail the recipient selection, stratification schemes, and the type and potential use of the requested information in the Information Collection Request ( ICR) for the 1989 screener and detailed MP& M industry surveys. The ICR can be found in Section 3.6.2 of the rulemaking record, DCN M15738.

<IP_ADDRESS> 1989 Screener Survey In August and September 1990, EPA mailed 8,342 screener surveys ( also referred to as the Mini Data Collection Portfolio ( MDCP)) to sites believed to be engaged in manufacturing, rebuilding, or maintenance activities in one of the seven industrial sectors listed above. Mailout of the screener was the preliminary step in an extensive data gathering effort for 3 2 3.0  Data Collection Activities these seven industrial sectors. The purpose of the screener was to identify sites to receive the more detailed survey and to make a preliminary assessment of these seven industrial sectors.

1989 Screener Recipient Selection and Distribution EPA identified potential recipients from a Dun & Bradstreet database using Standard Industrial Classification ( SIC) codes. The Agency identified more than 190 SIC codes applicable to the seven industrial sectors listed in Section 3.1.1. Within each sector, EPA identified between 1 and 40 SIC codes. EPA calculated the number of sites to receive the screener within each SIC code by a coefficient of variation ( CV) minimization procedure, described in the Statistical Summary for the Metal Products & Machinery Industry Surveys ( Section 10.0, DCN 16118). Based on the number of sites selected within each SIC code, the Agency purchased a list of randomly selected names and addresses from the Dun & Bradstreet database for each SIC code. This list included twice the number of sites specified by the CV minimization procedure for each SIC code.

EPA deleted sites from the purchased Dun & Bradstreet list for the following reasons: sites had SIC codes that were inconsistent with company names; sites were corporate headquarters without manufacturing, rebuilding, or maintenance operations; or sites had insufficient mailing addresses. EPA then randomly selected 30 to 60 sites within each SIC code and assigned each site a randomly selected identification number. EPA assigned each site identification number a corresponding barcode to track the distribution and processing of the screeners.

To examine trends and similarities in manufacturing across the industry sectors, EPA also sent screener surveys to some facilities performing manufacturing in the following eight industrial sectors:

  Bus and Truck;

  Household Equipment;

  Instruments;

  Motor Vehicles;

  Office Machines;

  Precious and Nonprecious Metals;

  Railroad; and   Ships and Boats.

The Agency did not send the screener to sites whose SIC codes indicated that they were engaged in only rebuilding or maintenance ( i. e., not manufacturing) operations in the eight industrial sectors listed above.

EPA maintained a toll free helpline from August through October of 1990 to assist screener recipients in completing the survey. This helpline received approximately 900 calls from screener recipients. Additional information about the screener mailing ( e. g., a copy of 3 3 3.0  Data Collection Activities the screener, specific mailing and processing procedures, non CBI screener responses, follow up letters, and notes from helpline telephone conversations) is contained in Sections 3.7, 3.8 and 5.3 of the rulemaking record.

1989 Screener Mailout Results EPA mailed 8,000 screener surveys in August 1990. Based on the number of surveys returned undelivered, EPA mailed an additional 342 in September 1990. In addition, EPA received 22 unsolicited responses to the survey. Of the 8,364 potential respondents to the screener, including those who provided unsolicited responses, 7,846 received the screener. Screeners for the remaining 518 were returned to EPA as undeliverable. EPA assumed these sites to be out of business. Of the total potential respondents, 84 percent ( 6,981) returned the screener to EPA. A blank copy of the screener form and nonconfidential portions of the completed screeners are contained in the rulemaking record ( see Section 3.7.2, DCN 17223, and Sections 3.7.1 and 5.3.7). Table 3 1 and Figure 3 1 summarize the mailout results for the 1989 and 1996 survey efforts.

Information Collected The Agency requested the following site specific information in the 1989 screener:

  Name and address of facility;

  Contact person;

  Parent company;

  Sectors in which the site manufactures, rebuilds, or maintains machines or metal components;

  SIC codes corresponding to products at the site;

  Number of employees;

  Annual revenues;

3 4  3.0  Data Collection Activities Table 3 1 1989 and 1996 MP& M Survey Mailout Results Survey Type Mailed Returned Undelivered Returned (%) Not Returned (%) Respondents Performing Proposed MP& M Operations (%) Respondents Not Performing Proposed MP& M Operations and Respondents Performing only Dry Proposed MP& M Operations (%)

1989 Screener Survey 8,342 518 6,981a ( 84) 865 ( 11) 3,598 ( 52) 3,373 ( 48)

1989 Detailed Survey 1,020 0 998b ( 98) 22 ( 2) 792 ( 79) 199 ( 20) e 1996 Screener Survey 5,325 579 4,248d ( 80) 497 ( 10) 2,424 ( 57) 1,824 ( 43)

1996 Benefits Screener 1,750 155 1,392 ( 80) 161 ( 10) 1,354 ( 97) 38( 3)

1996 Long Detailed Survey 353 1 311b ( 88) 41 ( 12) 303c ( 97) 8 ( 3) e 1996 Short Detailed Survey 101 1 83 ( 82) 17 ( 17) 59 ( 71) 24 ( 29)

1996 Municipality Detailed Survey 150 2 147 ( 98) 1 ( 1) 144 ( 53) f 3 ( 47) f 1996 Federal Detailed Survey 51 () 44 ( 86) 7 ( 14)

3 5 Source: 1989 and 1996 Survey Tracking Systems ( see Section 8.8.1, DCN 16331, and Section 5.3, DCN 16330 of the rulemaking record).

a Includes 22 unsolicited responses.

b Seven of the 1989 detailed surveys and two of the 1996 long detailed surveys were returned too late to be incorporated into the detailed survey database.

c Includes long survey respondents that discharge < 1 mgy.

d Does not include one duplicate survey received.

e Number of respondents also includes sites with classified process information ( 1989 detailed survey), sites with insufficient data ( 1996 long survey), and surveys returned too late to incorporate into the database ( 1996 long survey). The data from these surveys were not incorporated into the survey databases.

f For the municipality survey, these numbers represent the number and percentage of POTWs receiving wastewater from facilities evaluated in the final rule, and the number and percentage of POTWs not receiving wastewater from facilities evaluated in the final rule.

 Not applicable to the survey. 3.0  Data Collection Activities 1996 Federal Detailed 1996 POTW Detailed 1996 Municipality Detailed 1996 Short Detailed 1996 Long Detailed 1996 Benefits Screener 1996 Screener 1989 Detailed 1989 Screener 52% 84%

79% 98%

57% 80% 97%

80% 97%

88%

71% 82%

53% 90% 98%

98%

86%

NA 3 6 Survey Type 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Percentage Surveys Returned Respondents Engaged in MP& M Operations NA  The number of federal surveys distributed is not certain, and the percentage of returned surveys cannot be calculated.

Figure 3 1. Percentage of 1989 and 1996 MP& M Surveys Returned and Percentage of Survey Respondents Performing Proposed MP& M Operations 3.0  Data Collection Activities     Unit operations performed at the site;

  € Whether there is process water use and/ or wastewater discharge for each unit operation performed at the site; and     Base metal( s) on which each unit operation is performed.

The Agency used a computerized database system ( MS Access 97) to store and analyze data received from the screeners. The database dictionary and all nonconfidential screener surveys are located in Section 5.3.7 of the rulemaking record.

EPA determined the number of sites engaged in proposed MP& M operations by responses to the screener. As shown in Table 3 1, approximately 52 percent of the 1989 screener survey respondents reported that their sites were engaged in proposed MP& M operations and approximately 48 percent reported no or only dry proposed MP& M operations at their sites. EPA could not determine the status of 10 of the sites because they returned incomplete screeners and did not respond to follow up efforts.

The Agency contacted a statistically representative sample of the nonrespondent sites ( i. e., sites that did not return the screener) and sites reporting   not engaged  in proposed MP& M operations to determine whether their responses were due to confusion over the scope of the industry. Based on the results of this follow up, EPA adjusted the survey weights for misclassification and incorrect responses. The methodology for calculating the adjustment factors is provided in the Statistical Summary for the Metal Products & Machinery Industry Surveys ( Section 10.0, DCN 16118).

1989 Screener Data Entry, Engineering Coding, and Analysis EPA reviewed all of the screener surveys prior to data entry. As part of this effort, the Agency reviewed all documentation provided by the site, corrected errors and deficiencies, and coded the information for data entry. In some cases, these revisions required telephone contact with site personnel. The Agency contacted more than 1,100 screener recipients to resolve survey deficiencies and code information for data entry. Following preliminary review, EPA entered the scannable data ( i. e., responses to multiple choice, Mark Sense   questions) into the database using a Scantron   reader. EPA scanned each form twice and compared the information using a computer program as a quality control check. The Agency performed double key entry of nonscannable data, resolved any inconsistencies, and converted the data to database files.

Based on the screener mailout results, EPA developed an industry profile for the seven sectors. The screener database report provides estimates of the national population for sites in these industrial sectors with regard to water use characteristics, size, location, sector, unit operations, and metal types. The Statistical Summary for the Metal Products & Machinery 3 7 3.0  Data Collection Activities Industry Surveys ( Section 10.0, DCN 16118) discusses the sample size determination and statistical procedures for developing national estimates for the industry.

<IP_ADDRESS> 1989 Detailed Survey Based on responses to the 1989 screener, EPA sent a more detailed survey to a select group of water using facilities performing proposed MP& M operations. This survey, also referred to as the data collection portfolio ( DCP), was designed to collect detailed technical and financial information reflecting a site s 1989 operations. EPA used this information to characterize these facilities from the seven industrial sectors, develop pollutant loadings and reductions, and develop compliance cost estimates, as discussed later in this document.

EPA mailed 896 detailed surveys in January 1991. Based on the number of detailed surveys returned undelivered, EPA mailed an additional 124 detailed surveys in January and February 1991, for a total of 1,020 detailed surveys mailed. A blank copy of the 1989 detailed survey ( Section 3.7.2, DCN 17224) and copies of the nonconfidential portions of the completed detailed surveys are located in Section 5.3.8 of the rulemaking record.

1989 Detailed Survey Recipient Selection and Distribution EPA selected 1,020 sites to receive detailed surveys from the following three groups of sites:

    Water discharging 1989 screener respondents ( 860 sites);

  € Water using 1989 screener respondents that did not discharge process water ( 74 sites); and   € Water discharging sites from key companies performing proposed MP& M operations that did not receive the 1989 screener ( 86 sites).

The methods used to select sites within each group are described below.

The Agency mailed the 1989 detailed survey to all 860 water discharging screener respondents. EPA s intent in collecting detailed data from all 860 sites was to characterize the potential variations in unit operations performed and water use practices among water discharging sites in these seven industrial sectors.

The Agency mailed the 1989 detailed survey to a probability sample of 50 screener respondents that reported using but not discharging process water. EPA selected these sites to provide information on water use practices at sites that use but do not discharge process water, and to determine if   zero discharge  practices used at those sites could be used at other facilities performing proposed MP& M operations. In addition to the 50 probability sample sites, EPA mailed the 1989 detailed survey to 24 screener respondents that reported using but not 3 8 3.0  Data Collection Activities discharging process water. The Agency selected these sites because they performed unit operations that were not expected to be sufficiently characterized by detailed surveys mailed to other sites. The unit operations that EPA expected at each of the 24 sites are listed in Section 3.8.2 of the rulemaking record.

EPA mailed the 1989 detailed survey to 86 sites that did not receive the 1989 screener. The Agency identified these sites as representing key companies in the industry that EPA did not select as 1989 detailed survey recipients based on the screener mailout. EPA identified key companies from Dun & Bradstreet company lists, the Thomas Register , Fortune Magazine s list of the top 500 U. S. companies, and MP& M site visits at companies with annual revenues of $ 50 million or more that EPA believed to be leading companies in their particular industrial sector. The Agency contacted each of the key companies to identify sites within the company that were performing proposed MP& M operations and used process water to perform these operations. Records of these follow up telephone calls are located in the MP& M rulemaking record ( see Section 3.8.2). EPA did not use these 86 surveys for developing the national estimates because the Agency did not randomly select these facilities.

EPA operated a toll free telephone helpline from January until July 1991 to assist recipients in completing the 1989 detailed survey. The helpline received approximately 1,400 calls from detailed survey recipients. Callers to the 1989 detailed survey helpline typically requested the following:

  € Assistance with the technical sections of the detailed survey ( e. g., technical clarification of unit operation definitions);

    Additional time to complete the survey;

  € Assistance with the financial sections of the detailed survey ( these calls were referred to a separate economics helpline); or   € Clarification of the applicability of the survey ( i. e., did the survey apply to the site?).

Records for nonconfidential telephone calls to the helpline and to EPA personnel are located in Section 5.3.8 of the rulemaking record.

1989 Detailed Survey Mailout Results Table 3 1 summarizes the results of the detailed survey mailout. Of the 1,020 sites that received the detailed survey, 998 responded to the survey and 22 did not. EPA did not include 199 of the 1,020 sites that responded in the detailed survey database for one of the following reasons:

    The site was out of business;

3 9 3.0  Data Collection Activities     The site did not use process water;

    The site was not performing proposed MP& M operations; or   € Process information at the site was Department of Defense or Department of Energy classified information.

Specific reasons for not using data from these sites are documented in Section <IP_ADDRESS> of the rulemaking record.

Upon review of the detailed surveys submitted by these sites, EPA determined 87 sites to be in the other 11 industrial sectors rather than the seven sectors identified in Section 3.1.1. Because the scope of the detailed survey mailout effort included only sites from the seven industrial sectors listed in Section 3.1.1, EPA did not include these 87 sites in the detailed survey database.

Information Collected The Agency designed the 1989 detailed survey to collect information necessary to develop effluent limitations guidelines and standards for the MP& M rulemaking. EPA divided the detailed survey into the following parts:

    Part I  General Information;

    Part II  Process Information;

    Part III  Water Supply;

    Part IV  Wastewater Treatment and Discharge;

    Part V  Process and Hazardous Wastes; and     Part VI  Financial and Economic Information.

The detailed survey instructions and the ICR for this project contain further details on the types of and potential uses for information collected. These documents are located in Section 3.7.2 of the rulemaking record, DCN 17224.

Part I ( questions 1 through 13) requested information necessary to identify the site, to characterize the site by certain variables, and to confirm that the site was performing proposed MP& M operations. This information included: site name, address, contact person, number of employees, facility age, average energy usage, discharge permit status, and MP& M activity ( manufacturing, rebuilding, or maintenance).

Part II ( questions 14 through 21) requested detailed information on products, production levels, unit operations, activity, water use for unit operations, wastewater discharge from unit operations, miscellaneous wastewater sources, waste minimization practices ( e. g., pollution prevention), and air pollution control for unit operations. EPA requested the site to provide detailed technical information ( e. g., water balance, chemical additives, metal type 3 10 3.0  Data Collection Activities processed, disposition of wastewater) for each proposed MP& M operation and air pollution control device using process water. This section also requested information on unique and/ or auxiliary operations. EPA used this information to evaluate raw waste characteristics, water use and discharge practices, and sources of pollutants for each proposed MP& M operation.

Part III ( question 22) requested information on the water supply for the site. EPA requested the site to specify the source water origin, average intake flow, average intake operating hours, and the percentage of water used for proposed MP& M operations. EPA used this information to evaluate overall water use for the site.

Part IV ( questions 23 through 33) requested detailed information on influent and effluent wastewater treatment streams and wastewater treatment operations. The information requested included: the origin of each stream contributing to the site s overall wastewater discharge; a block diagram of the wastewater treatment system; detailed technical information ( e. g., wastewater stream flow rates, treatment chemical additives, system capacity, disposition of treatment sludge) for each wastewater treatment operation; self monitoring data; and capital and operating cost data. EPA collected this information on facilities performing proposed MP& M operations to: ( 1) evaluate treatment in place at these facilities; ( 2) develop and design a cost model to estimate various control options; and ( 3) assess the long term variability of effluent streams.

Part V ( question 34) requested detailed information on the types, amounts, and composition of wastewater and solid/ hazardous wastes generated during production or waste treatment, and the costs of solid waste disposal. EPA collected this information to evaluate the types and amounts of wastes currently discharged, the amount of waste that is contract hauled off site, and the cost of contract hauling wastes.

Part VI requested detailed financial and economic information from the site and the company owning the site. EPA collected this information to calculate the economic impacts of the regulatory options considered for the MP& M rulemaking.

1989 Detailed Survey Review, Coding, and Data Entry The Agency completed an engineering review of the detailed surveys, including coding responses to questions from Parts I through V to facilitate entry of technical data into a database. The MP& M DCP Database Dictionary identifying all database codes developed for this effort and the database dictionary for Section VI of the detailed survey are located in Section <IP_ADDRESS> of the rulemaking record, DCN 17387.

The Agency followed up with telephone calls to all respondents who did not provide: ( 1) information on operations ( manufacturing, rebuilding, or maintenance) or sectors; ( 2) metal type or unit operation descriptions for each water using unit operation; or ( 3) descriptions for each wastewater treatment operation. EPA also made follow up calls to 3 11 3.0  Data Collection Activities clarify incomplete or contradictory technical or economic information. EPA confirmed all information obtained from follow up calls by sending a letter to the site.

EPA developed a database to store all technical data provided in the detailed surveys. After engineering review and coding, the Agency entered data from the detailed surveys into the database using a double key entry and verification procedure. EPA coded and entered data from 792 detailed survey respondents determined to be performing proposed MP& M operations into the detailed survey database. The MP& M DCP Database Dictionary presents the database structure and defines each field in the detailed survey database and the codes that describe data in these fields.

The Economic, Environmental, and Benefits Analysis of the Proposed Metal Products and Machinery Rule , which is located in Section 8.1 of the rulemaking record, DCN 2000, discusses EPA s review of Section VI of the detailed survey.

1989 Detailed Survey Data Analysis EPA used the information collected in the detailed survey to develop an industry profile and to identify the baseline of treatment in place and estimate the amount of pollutant discharges from facilities performing proposed MP& M operations. Section 4.0 of this document provides estimates of the national population of these facilities that discharge water with regard to size, location, sector, unit operations, metal types, and discharge flows, and discusses the statistical procedures for developing national estimates for the industry. Section 11.0 and 12.0 present the methodologies used to estimate pollutant discharges and compliance costs, respectively.

3.1.2 The 1996 Industry Surveys Between 1996 and 1998, EPA distributed one screener and five detailed surveys, requesting data representing the survey recipients  1996 operations. The five detailed surveys included the long, short, municipality, federal, and publicly owned treatment works ( POTW) surveys. The Agency distributed the 1996 surveys to commercial and government ( federal, state, and local) facilities that manufacture, rebuild, or maintain metal products or parts to be used in one of the following 11 industrial sectors:

  Bus and Truck;

  Household Equipment;

  Instruments;

  Job Shops;

  Motor Vehicles;

  Office Machines;

  Precious Metals and Jewelry;

  Printed Wire Boards;

  Railroad;

3 12 3.0  Data Collection Activities   Ships and Boats; and   Miscellaneous Metal Products.

The 1996 screener and detailed surveys are discussed below. Recipient selection, stratification schemes, and the type and potential use of the information requested are described in more detail in the ICR for the 1996 screener ( see Section 3.5.1, DCN 15766).

<IP_ADDRESS> 1996 Screener Survey In December 1996 and February 1997, EPA distributed 5,325 screener surveys to sites believed to be engaged in manufacturing, rebuilding, or maintenance activities in one of the 11 industrial sectors listed in Section 3.1.2. The purpose of the screener surveys was to identify sites to receive the more detailed survey and to make a preliminary assessment of the industry for the 11 industrial sectors. EPA sent an additional 1,750 screeners to facilities located in Ohio ( a state with a high concentration of facilities performing proposed MP& M operations) as part of a benefits study. The Agency used these screeners to collect data to analyze environmental benefits.

1996 Screener Recipient Selection and Distribution As discussed above, EPA sent the 1996 screener survey to 5,325 randomly selected facilities performing proposed MP& M operations ( includes replacement sites). The Agency selected potential recipients from the Dun & Bradstreet database based on the industrial sector ( using the SIC code), activity ( i. e., manufacturing, maintenance, or rebuilding), size as measured by number of employees, and wastewater discharge flow rate.

The Agency identified more than 126 SIC codes applicable to the 11 industrial sectors. Within each sector, EPA identified between 1 and 26 SIC codes. EPA calculated the number of sites to receive the 1996 screener within each SIC code by a coefficient of variation ( CV) minimization procedure described in the Statistical Support Document located in Section 10.0 of the rulemaking record, DCN 16119. Based on the number of sites selected within each SIC code, the Agency obtained a list of randomly selected names and addresses from Dun & Bradstreet. This list included twice the number of sites specified by the CV minimization procedure for each SIC code. EPA randomly selected the initial list of sites from the Dun & Bradstreet database for each SIC code.

After reviewing the potential sites, EPA deleted sites for the following reasons:

  The site was a corporate headquarters without manufacturing, rebuilding, or maintenance operations;

  The site received a 1989 screener or detailed survey;

3 13 3.0  Data Collection Activities   The site was a duplicate of another facility in the list of potential facilities performing proposed MP& M operations;

  The site had an SIC code that was inconsistent with company name; or   The site had an insufficient mailing address.

EPA established a toll free telephone helpline and an electronic mail address to assist screener recipients in completing the survey. EPA received helpline calls and electronic mail inquiries from more than 600 screener recipients. Nonconfidential notes from helpline and review follow up calls are located in Section 5.3.1 of the rulemaking record.

1996 Screener Mailout Results EPA initially mailed 4,900 surveys in December 1996. The Agency distributed surveys to an additional 425 sites to replace surveys that were returned undelivered. EPA assumed the undeliverable survey sites to be out of business. Of the 5,325 surveys mailed, 80 percent ( 4,248) of the recipients returned completed surveys to EPA. A blank copy of the 1996 screener ( see Section 3.7.1, DCN 16367) and nonconfidential portions of the completed screeners are located in the public record for this rulemaking ( see Section <IP_ADDRESS>). Table 3 1 and Figure 3 1 summarize the MP& M survey mailout results.

The Agency contacted a statistically representative sample of nonrespondent sites to determine whether these sites were performing proposed MP& M operations and discharged process wastewater. Only 24 percent of the nonrespondents contacted were performing proposed MP& M operations, and approximately half of these facilities did not discharge process wastewater.

Information Collected The Agency requested the following site specific information in the screener:

  Name and address of facility;

  Contact person;

  Whether process water is used at the site;

  Destination of process wastewater discharged;

  Volume of process wastewater discharged;

  Number of employees;

3 14 3.0  Data Collection Activities   Annual revenue;

  Sectors in which the site manufactures, rebuilds, or maintains machines or metal components; and   Unit operations performed at the site and whether there is water use and/ or wastewater discharge for each unit operation performed at the site.

The Agency used a computerized database system ( MS Access 97) to store and analyze data received from the 1996 screeners. Nonconfidential portions of the screener surveys ( see Section <IP_ADDRESS>) and the database dictionary are located in the public record for this rulemaking ( see Section <IP_ADDRESS>, DCN 15393).

1996 Screener Data Review and Data Entry EPA reviewed the 1996 screener survey responses for accuracy and consistency and formatted the information for data entry. The Agency contacted approximately 1,800 screener respondents to resolve deficient and inconsistent information prior to data entry. Following review, EPA double key entered and compared the data from the formatted screeners, using a computer program, as a quality control check. The Agency then reviewed the database files for deficiencies and inconsistencies, and resolved all issues for the final survey database.

1996 Benefits Screener Survey For an environmental benefits study, EPA sent the 1996 screener survey to 1,750 ( including replacement sites) randomly selected sites in Ohio, a state with a large number of facilities performing proposed MP& M operations. The selection criteria and sampling frame for the benefits screener recipients are described in more detail in memoranda located in Section <IP_ADDRESS> of the rulemaking record, DCN 16333.

The Agency initially mailed the benefits screener to 1,600 facilities in October 1998. EPA mailed screeners to an additional 150 facilities in February 1999 to replace surveys that were returned undelivered. The Agency assumed the undeliverable survey sites to be out of business. Of the 1,750 surveys mailed, 80 percent ( 1,392) of the recipients returned completed screeners to EPA. A blank copy of the 1996 benefits screener ( see Section 3.7.1, DCN 16367) and nonconfidential portions of the completed benefits screeners ( see Section 8.8.1) are located in the public record for this rulemaking. Table 3 1 and Figure 3 1 summarize the MP& M mailout results.

EPA established a toll free telephone helpline and an electronic mail address to assist screener recipients in completing the survey. EPA received helpline calls and electronic mail inquiries from more than 900 benefits screener recipients. Nonconfidential notes from helpline and review follow up calls are located in Section 8.8.1 of the public record for this rulemaking.

3 15 3.0  Data Collection Activities The Agency followed the same review, data entry, and database development procedures used for the original 1996 screener survey. EPA contacted more than 400 screener respondents to resolve deficient and inconsistent information prior to data entry. The benefits screener database is discussed in the Economic, Environmental, and Benefits Analysis of the Proposed Metal Products and Machinery Rule .

<IP_ADDRESS> 1996 Long Detailed Survey EPA distributed the long detailed surveys ( long survey) in June 1997 to 353 wastewater discharging facilities performing proposed MP& M operations. EPA designed this survey to gather detailed technical and economic information required to develop the MP& M effluent limitations guidelines and standards. The long survey is discussed below.

1996 Long Survey Recipient Selection and Distribution In June 1997, EPA sent the long survey to all 353 1996 screener respondents who indicated they performed operations in one of the 11 industry sectors listed in Section 3.1.2 and discharged one million or more gallons of MP& M process wastewater annually. EPA established a toll free telephone helpline and an electronic mail address to assist long survey recipients in completing the survey. EPA received helpline calls and electronic mail inquiries from approximately 200 long survey recipients. Nonconfidential notes from helpline and review follow up calls are located in Section <IP_ADDRESS> of the public record for this rulemaking.

1996 Long Survey Mailout Results Of the 353 surveys mailed, 88 percent ( 311) of the recipients returned completed surveys to EPA. One survey was returned as undelivered and EPA assumed the facility to be out of business. A blank copy of the 1996 long survey ( Section 3.7.1, DCN 713) and nonconfidential portions of the completed long surveys are located in Section <IP_ADDRESS> of the public record for this rulemaking. Table 3 1 and Figure 3 1 summarize the MP& M survey mailout results.

Information Collected EPA divided the long detailed survey into the following sections:

  Section I: General Site Information;

  Section II: General Process Information;

  Section III: Specific Process Information;

3 16 3.0  Data Collection Activities   Section IV: Economic Information; and   Section V: Voluntary Supplemental Information.

Table 3 2 summarizes the information requested in the 1996 long, short, federal, and municipality detailed surveys by question number. EPA designed these surveys to collect similar detailed process information from different audiences, as discussed below for each survey. Further details on the types of information collected and the potential uses of the information are contained in the ICR for this data collection ( see Section 3.5.1, DCN 15766) and in the survey instructions that are located in Section 3.7.1 of the rulemaking record, DCN 713.

Section I requested information to determine if the facility was performing proposed MP& M operations. Question 1 requested the site to identify the industry sector and type of activity ( manufacturing, rebuilding, or maintenance) performed.