Section II requested information to identify the site location and contact person, number of employees, facility age, process wastewater discharge status and destination, and wastewater discharge permits and permitting authority. This section also requested general information about metal types processed, products and production levels, water use for unit operations, and wastewater discharge from unit operations. EPA used the process information to evaluate water use and discharge practices and sources of pollutants for each proposed MP& M operation.

Section III requested detailed information on wet proposed MP& M operations, pollution prevention practices, wastewater treatment technologies, costs for water use and wastewater treatment systems, and wastewater/ sludge disposal costs. EPA also requested the site to provide block diagrams of the production process and the wastewater treatment system. The unit operation information requested included: metal types processed, production rate, operating schedule, chemical additives, volume and destination of process wastewater and rinse waters, in process pollution prevention technologies, and in process flow control technologies. The information requested for each wastewater treatment unit included: operating flow rate, design capacity, operating time, chemical additives, and unit operations discharging to each treatment unit. In addition, EPA requested the site to provide the type of any wastewater sampling data collected. EPA used these data to characterize the industry, to perform subcategorization analyses, to identify best management practices, to evaluate performance of the treatment technology for inclusion in the regulatory options, and to develop regulatory compliance cost estimates.

Section IV requested detailed financial and economic information about the site or the company owning the site. EPA collected this information to calculate the economic impacts of the regulatory options considered for the MP& M rulemaking.

Section V requested supplemental information on other facilities performing proposed MP& M operations owned by the company. EPA included this voluntary section to 3 17

 3.0  Data Collection Activities measure the combined impact of proposed MP& M effluent guidelines on companies with multiple facilities Table 3 2 Summary of 1996 Detailed Survey Information by Question Number Survey Question Number Type of Information Requested Long and Federal Short Municipality Section I 1 Section I 1 Part II 1 Industrial sector activities Section II 2 5 Section II 2 5 2 5 Site location and facility contact 6, 7 6, 7 5, 6 Number of employees and age of site 8, 9 8, 9 7, 8 Discharge status and destination 10 10 9 Permits under miscellaneous categorical effluent guidelines 11 12 10 11 Types of end of pipe wastewater treatment units 11 13 12 Metal types processed 12 15 13 5 major products ( quantity and sector)

13 16 14 Unit operations: water use and associated rinses Section III 14 15 General water use and costs 16 Production process diagram 17 23 Detailed description of wet unit operations performed 24 29 Section II 17 16 In process pollution prevention technologies or practices 30 Wastewater treatment ( WWT) diagram 31 41 Detailed design and operating parameters of WWT units 42 WWT costs by treatment unit 43 44 Section II 14 15 Wastewater sampling and analysis conducted 45 Contract haul and disposal costs Facility comments page Section IV 1 9 Section IV 1 8 Part I 1 3 Financial and economic data Section V 1 Section V 1 Parent firm name and contact, number of other facilities performing proposed MP& M operations 2 2 Number of employees for other facility( ies)

3 3 Industrial and activity 2, 4 2, 4 Discharge status and destination 5 5 Unit operations: water use and discharge status Question is not applicable to this survey.

3 18 3.0  Data Collection Activities performing proposed MP& M operations that discharge process wastewater. This section requested the same information collected in the 1996 MP& M screener survey. Responses to questions in this section provided the size, industrial sector, revenue, unit operations, and water usage of the company s other facilities performing proposed MP& M operations.

1996 Long Survey Data Review and Data Entry EPA completed a detailed engineering review of Sections I through III of the detailed long survey to evaluate the accuracy of technical information provided by the respondents. During the engineering review, EPA coded responses to facilitate entry of technical data into the long survey database. The MP& M 1996 Long Survey Database Dictionary identifies the database codes developed for this project, and is located in Section <IP_ADDRESS> of the rulemaking record, DCN 15773. EPA contacted approximately 240 long survey respondents, by telephone and letter, to clarify incomplete or inconsistent technical information prior to data entry.

The Agency developed a database for the technical information provided by survey respondents. After engineering review and coding, EPA entered data from 303 long surveys into the database using a double key entry and verification procedure. The MP& M 1996 Long Survey Database Dictionary presents the database structure and defines each field in the database files. EPA did not include data from 8 long survey respondents in the database for the following reasons:

  The site was out of business;

  The site did not use process water;

  The site was not performing proposed MP& M operations; or   The site provided insufficient data and the survey was returned too late to enter into the database.

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 IV of the detailed survey.

<IP_ADDRESS> 1996 Short Detailed Survey EPA distributed the short detailed survey ( short survey) in September 1997 to 101 wastewater discharging facilities performing proposed MP& M operations. EPA designed this survey to gather additional technical and economic information required to develop the MP& M effluent limitations guidelines and standards. The short survey is discussed below.

3 19 3.0  Data Collection Activities 1996 Short Survey Recipient Selection and Distribution EPA initially sent 100 short surveys in September 1997 and mailed one additional survey to a site to replace a short survey that was returned undelivered. EPA assumed the undeliverable site to be out of business. The Agency sent the short surveys to randomly selected 1996 screener respondents who performed operations in one of the 11 industry sectors identified in Section 3.1.2 and indicated they discharged less than one million gallons of MP& M process wastewater annually. The selection criteria and sampling frame for short survey recipients are described in more detail in the Statistical Summary for the Metal Products & Machinery Industry Surveys ( Section 10.0, DCN 16118).

EPA established a toll free telephone helpline and an electronic mail address to assist short survey recipients in completing the survey. EPA received helpline calls and electronic mail inquiries from approximately 20 short 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 Short Survey Mailout Results Of the 101 surveys mailed, 82 percent ( 83 surveys) of the recipients returned completed surveys to EPA. A blank copy of the 1996 short survey ( Section 3.7.1, DCN 16368) and nonconfidential portions of the completed short surveys ( Section <IP_ADDRESS>) are located in the public record for this rulemaking. Table 3 1 and Figure 3 1 summarize the MP& M survey mailout results.

Information Collected The information collected in the 1996 short survey included the identical general site and process information and economic information collected in Sections I, II, IV, and V of the long detailed survey ( see Section <IP_ADDRESS>). To minimize the burden on facilities discharging less than one million gallons of process wastewater, EPA did not require these facilities to provide the detailed information on proposed MP& M operations or treatment technologies that EPA requested in Section III of the long survey. The ICR for this data collection and the survey instructions contain further details on the types of information collected and the potential uses of the information.

EPA divided the short survey into the following sections:

  Section I: General Site Information;

  Section II: General Process Information;

  Section IV: Economic Information; and   Section V: Voluntary Supplemental Information.

3 20 3.0  Data Collection Activities Section III, Specific Process Information, consisted of a statement that EPA was not requesting this information to reduce burden on sites discharging less than one million gallons of process wastewater per year. Table 3 2 summarizes the 1996 short survey information by question number.

1996 Short Survey Data Review and Data Entry EPA completed a detailed engineering review of Sections I and II of the short survey to evaluate the accuracy of technical information provided by the respondents. During the engineering review, EPA coded responses to facilitate entry of technical data into the short survey database. The MP& M 1996 Short Survey Database Dictionary identifies the database codes developed for this project and is located in Section <IP_ADDRESS> of the rulemaking record, DCN 15772. EPA contacted more than 60 short survey respondents, by telephone and letter, to clarify incomplete or inconsistent technical information prior to data entry.

The Agency developed a database for the technical information provided by survey respondents. After engineering review and coding, EPA entered data for 75 short surveys into the database using a double key entry and verification procedure. The MP& M 1996 Short Survey Database Dictionary presents the database structure and defines each field in the database files. EPA did not include data from eight short survey respondents in the database for the following reasons:

  The site was out of business;

  The site did not use process water; or   The site was not performing proposed MP& M operations.

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 IV of the short survey.

<IP_ADDRESS> 1996 Municipality Detailed Survey EPA distributed the municipality surveys in June 1997 to 150 city and county facilities that might operate facilities performing proposed MP& M operations. EPA designed this survey to measure the impact of this rule on municipalities and other government entities that perform certain maintenance and rebuilding operations ( e. g., bus and truck, automobiles).

Recipient Selection and Distribution The Agency sent the municipality survey to 150 city and county facilities randomly selected from the Municipality Year Book 1995 based on population and geographic location. EPA allocated 60 percent of the sample to municipalities and 40 percent to counties. The 60/ 40 distribution was approximately proportional to their aggregate populations in the frame. The Agency divided the municipality sample and the county sample into three size 3 21 3.0  Data Collection Activities groupings as measured by population. For municipalities, the population groupings were: less than 10,000 residents, 10,000  50,000 residents, and 50,000 or more residents. For counties, the population groupings were: less than 50,000 residents, 50,000  150,000 residents, and 150,000 or more residents. The geographic stratification conformed to the Census definitions of Northeast, North Central, South, Pacific, and Mountain states.

EPA established a toll free telephone helpline and an electronic mail address to assist municipality survey recipients in completing the survey. EPA received helpline calls and electronic mail inquiries from more than 50 municipality survey recipients. Notes from helpline and review follow up calls are located in Section <IP_ADDRESS> of the rulemaking record.

1996 Municipality Survey Mailout Results Of the 150 municipality surveys mailed, three surveys were returned undelivered and 135 surveys ( 90 percent) of the recipients returned completed surveys to EPA. A blank copy of the 1996 municipality survey ( Section 3.7.1, DCN 16366) and nonconfidential portions of the completed municipality surveys ( Section <IP_ADDRESS>) are located in the public record for this rulemaking. Table 3 1 and Figure 3 1 summarize the MP& M survey mailout results.

Information Collected The 1996 municipality survey collected economic information for the entire municipality and site specific process information for each facility performing proposed MP& M operations operated by the municipality.

EPA divided the municipality detailed survey into the following parts:

  Part I: Economic and Financial Information; and   Part II: General Site Specific Process Information.

Table 3 2 summarizes the 1996 municipality survey information by question number. The ICR for this data collection ( Section 3.5.1, DCN 15766) and the survey instructions ( Section 3.7.1, DCN 15366) contain further details on the types of information collected and the potential uses of the information and are located in the rulemaking record.

Part I requested information on the site location and contact person, number of employees, detailed financial and economic information about the entire municipality, and information necessary to determine if the municipality owned and operated facilities performing proposed MP& M operations in any of the proposed industrial sectors.

Part II requested site specific process information for each facility performing proposed MP& M operations owned and operated by the municipality. Question 1 requested the site to identify the industry sector and type of activity ( manufacturing, rebuilding, or maintenance) performed. The remaining questions were identical to Section II of the short 3 22 3.0  Data Collection Activities detailed survey and requested facility age, process wastewater discharge status and destination, wastewater discharge permits and permitting authority, general information about metal types processed, products and production levels, water use for unit operations, and wastewater discharge from unit operations. The Agency used the process information to evaluate water use and discharge practices and sources of pollutants for each proposed MP& M operation.

1996 Municipality Survey Data Review and Data Entry EPA completed a detailed engineering review of Part II of the municipality survey to evaluate the accuracy of technical information provided by the respondents. During the engineering review, the Agency coded responses to facilitate entry of technical data into the municipality survey database. The MP& M 1996 Municipality Survey Database Dictionary identifies the database codes developed for this project, and is located in Section <IP_ADDRESS> of the rulemaking record, DCN 15771. EPA contacted more than 50 municipality survey respondents by telephone to clarify incomplete or inconsistent technical information prior to data entry.

The Agency developed a database for the technical information provided by survey respondents. After engineering review and coding, EPA entered data from 209 municipality facilities into the database using a double key entry and verification procedure. This number is greater than the number of respondents because some municipalities had more than one facility performing proposed MP& M operations. The MP& M 1996 Municipality Survey Database Dictionary presents the database structure and defines each field in the database files.

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 Part I of the municipality survey.

<IP_ADDRESS> 1996 Federal Facilities Detailed Survey In April 1998, EPA distributed the federal facilities detailed survey ( federal survey) to the following seven federal agencies:

  Department of Energy;

  Department of Defense;

  National Aeronautics and Space Administration ( NASA);

  Department of Transportation ( including the United States Coast Guard);

  Department of Interior;

  Department of Agriculture; and   United States Postal Service.

EPA used this survey to assess the impact of the MP& M effluent limitations guidelines and standards on federal agencies that operate facilities performing proposed MP& M operations.

3 23 3.0  Data Collection Activities Recipient Selection and Distribution There was no specific sampling frame for the federal survey. EPA distributed the survey to federal agencies likely to perform industrial operations on metal products or machinery. EPA requested representatives of seven federal agencies to voluntarily distribute copies of the survey to sites they believed performed proposed MP& M operations. The selection criteria for federal survey recipients are described in more detail in the ICR for the 1996 MP& M industry surveys. Because the sample was not randomly selected, EPA did not use data from these surveys to develop national estimates.

EPA established a toll free telephone helpline and an electronic mail address to assist federal survey recipients in completing the survey. EPA received helpline calls and electronic mail inquiries from approximately 20 federal 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 Federal Survey Distribution Results The Agency received 51 completed federal surveys, 39 from Department of Defense facilities and 12 from NASA facilities. A blank copy of the 1996 federal survey ( Section 3.7.1, DCN 721) and nonconfidential portions of the completed federal surveys are located in Section <IP_ADDRESS> of the public record for this rulemaking.

Information Collected The information requested in Sections I and III of the 1996 federal survey was identical to the long survey ( see Section <IP_ADDRESS>). The financial and economic questions in Section IV were revised to obtain this information for only the MP& M activities on a federal site. The ICR for this data collection and the survey instructions contain further details on the types of information collected and the potential uses of the information. Table 3 2 summarizes the 1996 federal detailed survey information by question number.

Data Review and Data Entry EPA completed a detailed engineering review of Sections I through III of the federal survey to evaluate the accuracy of technical information provided by the respondents. During the engineering review, the Agency coded responses to facilitate entry of technical data into the federal survey database. The MP& M 1996 Federal Survey Database Dictionary identifies the database codes developed for this project and is located in Section <IP_ADDRESS> of the rulemaking record, DCN 15991.

The Agency developed a database for the technical information provided by survey respondents. After engineering review and coding, EPA entered data from 44 federal surveys into the database using a double key entry and verification procedure. The Agency did 3 24 3.0  Data Collection Activities not include data from seven federal survey responses in the database because the sites did not use MP& M process water. The MP& M 1996 Federal Survey Database Dictionary presents the database structure and defines each field in the database files.

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 IV of the federal survey.

<IP_ADDRESS> 1996 POTW Detailed Survey EPA distributed the POTW survey to 150 sites in November 1997. The Agency designed this survey to evaluate benefits associated with the MP& M regulations and to estimate possible costs and burden that POTWs might incur in writing and maintaining MP& M permits or other control mechanisms.

Recipient Selection and Distribution The Agency sent the POTW survey to 150 POTWs with flow rates greater than 0.50 million gallons per day. EPA randomly selected the recipients from the 1992 Needs Survey Review, Update, and Query System Database. EPA divided the POTW sample into two strata by daily flow rates: 0.50 to 2.50 million gallons, and 2.50 million gallons or more. The selection criteria and sampling frame for POTW survey recipients are described in more detail in the ICR for the 1996 surveys.

EPA established a toll free telephone helpline and an electronic mail address to assist POTW survey recipients in completing the survey. EPA received helpline calls and electronic mail inquiries from approximately 50 POTW survey respondents. Nonconfidential notes from helpline and review follow up calls are located in Section 8.7 of the public record for this rulemaking.

1996 POTW Survey Mailout Results Of the 150 POTW surveys mailed, two surveys were returned undelivered and 98 percent ( 147) of the recipients returned completed surveys to EPA. A blank copy of the 1996 POTW survey ( Section 3.7.1, DCN 16369) and nonconfidential portions of the completed POTW survey ( Section 8.7) are located in the public record for this rulemaking. Table 3 1 and Figure 3 1 summarize the MP& M survey mailout results.

Information Collected The POTW survey requested data required to estimate benefits and costs associated with implementation of the MP& M regulations. The ICR for this data collection and the survey instructions contain further details on the types of information collected and the potential uses of the information. EPA divided the POTW survey into the following parts:

3 25 3.0  Data Collection Activities   Part I: Introduction and Basic Information;

  Part II: Administrative Permitting Costs; and   Part III: Sewage Sludge Use or Disposal Costs.

Part I requested site location and contact information and the total volume of wastewater treated at the site. EPA used the wastewater flow information to characterize the size of the POTW.

Part II requested the number of industrial permits written, the cost to write the permits, the permitting fee structure, the percentage of industrial dischargers covered by National Categorical Standards ( i. e., effluent guidelines), and the percentage of permits requiring expensive administrative activities. EPA used this information to estimate administrative burden and costs.

Part III requested information on the use or disposal of sewage sludge generated by the POTW. EPA required only POTWs that received discharges from facilities performing proposed MP& M operations to complete Part III. The sewage sludge information requested included the amount generated, use or disposal method, metal levels, use or disposal costs, and the percentage of total metal loadings at the POTW from facilities performing proposed MP& M operations. The Agency used this information to assess the potential changes in sludge handling resulting from the MP& M rule and to estimate economic benefits to the POTW related to sludge disposal and reduction in upsets/ interference.

Data Review and Data Entry EPA performed a detailed review of the POTW survey to evaluate the accuracy of information provided by the respondents. During the review, the Agency coded responses to facilitate entry of data into the POTW survey database. The database dictionary for the POTW survey identifies the database codes developed for this project, and is located in Section 8.7 of the rulemaking record. EPA contacted more than 95 POTW survey respondents by telephone to clarify incomplete or inconsistent information prior to data entry.

The Agency developed a database for the information provided by survey respondents. After review and coding, EPA entered data from 147 POTW surveys into the database using a double key entry and verification procedure. The database dictionary presents the database structure and defines each field in the database files.

3.1.3 1997 Iron and Steel Industry Survey Data As part of its effort to review and revise effluent limitations guidelines and standards for the Iron and Steel Point Source Category ( 40 CFR 420), EPA distributed, reviewed, and coded the iron and steel industry detailed and short surveys of 402 iron and steel facilities in November 1998.

3 26 3.0  Data Collection Activities EPA included data from 154 iron and steel surveys in the MP& M survey database. EPA used these 154 Iron & Steel surveys to create a new subcategory, Steel Forming and Finishing, in the January 2001 proposal. Based on comments to the January 2001 proposal and June 2002 NODA, EPA concluded that those operations included in the proposed Steel Forming and Finishing Subcategory of the MP& M Point Source Category should remain subject to the effluent guidelines and standards at the Iron and Steel Point Source Category ( 40 CFR 420). See Section 6.0 for further discussion of subcategorization.

As discussed in the June 2002 NODA ( 67 FR 38752), EPA considered establishing a segment of the Steel Forming and Finishing Subcategory for discharges resulting from continuous electroplating of flat steel products ( e. g., strip, sheet, and plate). EPA examined its database for facilities that perform continuous steel electroplating and found that continuous electroplaters do not perform operations similar to facilities in the proposed Steel Forming and Finishing Subcategory. Rather, continuous electroplaters perform operations included in the proposed General Metals Subcategory. Therefore, in evaluating options for the final rule, EPA included continuous electroplaters in the proposed General Metals Subcategory. See Section 6.0 for a detailed discussion of subcategorization. For this reason, EPA incorporated the information on these operations reported in 24 iron and steel surveys into the MP& M database. Operations on the continuous electroplating lines may include:

  Acid cleaning;

  Alkaline cleaning;

  Conversion coating ( e. g., passivation, surface activation/ fluxing);

  Electroplating;

  Rinsing; and   Sealing.

All 24 sites with electroplating lines processing steel flat rolled products discharge process wastewater. The Agency coded and entered process and wastewater treatment information from the 47 lines in the 24 iron and steel surveys into the MP& M cost model. A blank copy of the 1997 iron and steel detailed and short surveys and nonconfidential portions of the 24 completed iron and steel surveys are located in Sections 5.3.6 and 15.1 of the public record for this rulemaking. As discussed in Section 9.0, EPA rejected establishing limitations and standards for the proposed General Metals Subcategory. Continuous electroplaters remain subject to the Metal Finishing Point Source Category ( 40 CFR 433), as applicable.

1997 Iron and Steel Survey Recipient Selection and Distribution The Agency consulted with industry trade associations and visited a number of sites to develop the survey instruments and to ensure an accurate mailing list.

3 27 3.0  Data Collection Activities EPA distributed four industry surveys:

  U. S. EPA Collection of 1997 Iron and Steel Industry Data ( detailed survey);

  U. S. EPA Collection of 1997 Iron and Steel Industry Data ( Short Form) ( short survey);

  U. S. EPA Collection of Iron and Steel Industry Wastewater Treatment Capital Cost Data ( cost survey); and   U. S. EPA Analytical and Production Data Follow Up to the Collection of 1997 Iron and Steel Industry Data ( analytical and production survey).

In October 1998, EPA mailed the detailed survey to 176 iron and steel sites and the short survey to 223 iron and steel sites. EPA designed the detailed survey for those iron and steel sites that perform any iron and steel manufacturing process. Those sites include integrated and non integrated steel mills, as well as sites that were initially identified as stand alone cokemaking plants, stand alone sinter plants, stand alone direct reduced ironmaking plants, stand alone hot forming mills, and stand alone finishing mills. The short survey is an abbreviated version of the detailed survey. It was designed for stand alone iron and steel sites with the exceptions of those that received the detailed survey. EPA mailed the cost survey and the analytical and production survey to subsets of the facilities that received the detailed or short survey to obtain more detailed information on wastewater treatment system costs, analytical data, and facility production. EPA mailed the cost survey to 90 iron and steel sites and the analytical and production survey to 38 iron and steel sites.

EPA mailed the iron and steel industry surveys by mail to facilities that were identified from the following sources:

  Association of Iron and Steel Engineers  1997 and 1998 Directories: Iron and Steel Plants Volume 1, Plants and Facilities ;

  Iron and Steel Works of the World ( 11th and 12th editions) directories;

  Iron and Steel Society s The Steel Industry of Canada, Mexico, and the United States: Plant Locations ;

  Member lists from the following trade associations:  American Coke and Coal Chemicals Institute,  American Galvanizers Association,  American Iron and Steel Institute,  American Wire Producers Association,  Cold Finished Steel Bar Institute,

3 28 3.0  Data Collection Activities  Specialty Steel Industry of North America,  Steel Manufacturers Association,  Steel Tube Institute of North America, and  Wire Association International;

  Dun & Bradstreet Facility Index Database ;

  EPA s Permit Compliance System ( PCS) Database ;

  EPA s Toxic Release Inventory ( TRI) Database ;

  Iron and Steel Society s Iron and Steelmaker   Roundup  editions;

  33 Metalproducing   Roundup  editions ( Reference 3 22);

  33 Metalproducing   Census of the North American Steel Industry ; and   Thomas Register .

The Agency cross referenced these sources with one another to develop a list of individual sites. Based on these sources, EPA identified 822 candidate facilities to receive surveys. To minimize the burden on the respondents, EPA grouped facilities into 12 strata. In general, EPA determined the strata based on its understanding of the manufacturing processes at each facility.

Depending on the amount or type of information EPA required for the rulemaking, EPA either solicited information from all facilities within a stratum ( i. e., a census or   certainty  stratum) or selected a random sample of facilities within a stratum ( i. e., statistically sampled stratum). EPA sent a survey to all facilities in the certainty strata ( strata 5 and 8) because the Agency determined it was necessary to capture the size, complexity, or uniqueness of the steel operations at these sites. EPA also sent surveys to all facilities in strata 1 through 4 ( all cokemaking sites, integrated steelmaking sites, and sintering and direct reduced ironmaking sites) because of the relatively low number of sites in each stratum and because of the size, complexity, and uniqueness of raw material preparation and steel manufacturing operations at these sites. The Agency statistically sampled the remaining sites in strata 6, 7, and 9 through 12. EPA calculated survey weights for each selected facility based on the facility s probability of selection. If the Agency sent a survey to every facility in a stratum, each selected facility represents only itself and has a survey weight of one. For statistically sampled strata, each selected facility represents itself and other facilities within that stratum that were not selected to receive an industry survey. These facilities have survey weights greater than one. See the Development Document for Final Effluent Limitations Guidelines and Standards for the Iron and Steel Manufacturing Point Source Category ( EPA 821 R 02 004) for more details.

3 29 3.0  Data Collection Activities Of the 822 candidate facilities, EPA mailed either a detailed survey or a short survey to 399 facilities. 2 Detailed survey recipients included integrated mills, non integrated mills, stand alone cokemaking sites, stand alone sintering sites, stand alone direct reduced ironmaking sites, stand alone hot forming sites, and stand alone finishing sites. Short survey recipients included stand alone cold forming sites, stand alone pipe and tube sites, stand alone hot dip coating sites, and stand alone wire sites.

Once the Agency completed a review of the detailed and short surveys and defined the technology options, EPA identified survey respondents who had installed wastewater treatment systems in the last 10 years ( since 1990) that were similar to the technology options and mailed them the cost survey. EPA selected 38 facilities to receive the analytical and production survey who had indicated in the detailed or short survey that: ( 1) they had treatment trains similar to the treatment technology options, ( 2) they had collected analytical data for that treatment train, ( 3) they had a treatment train with a dedicated outfall from which EPA could evaluate performance, and ( 4) they did not add excessive dilution water to the outfall before sampling.

1997 Iron and Steel Survey Information Collected The detailed and short surveys were divided into two parts: Part A: Technical Information and Part B: Financial and Economic Information. The   Part A  technical questions in the detailed survey comprised four sections, with Sections 3 and 4 being combined in the short survey, as follows:

  Section 1: General Site Information;

  Section 2: Manufacturing Process Information;

  Section 3: In Process and End of Pipe Wastewater Treatment and Pollution Prevention Information; and   Section 4: Wastewater Outfall Information.

The financial and economic information in Part B of the detailed survey also comprised four sections, as shown below:

  Section 1: Site Identification;

  Section 2: Site Financial Information;

  Section 3: Business Entity Financial Information; and 2Before the surveys were actually mailed, the Agency notified potential survey recipients. One site, randomly selected from stratum 12 and notified that it would be receiving a survey, notified the Agency that it was not engaged in iron and steel activities. The Agency decided not to mail a survey to that site. Therefore, this site was not included in the 399 facilities receiving surveys.

3 30 3.0  Data Collection Activities   Section 4: Corporate Parent Financial Information.

Part B of the short survey contained a single section for site identification and financial information. More detailed descriptions of financial data collection and analysis are included in the Economic Analysis of Final Effluent Limitations Guidelines and Standards for the Iron and Steel Manufacturing Point Source Category ( EPA 821 R 02 006).

The detailed survey requested detailed descriptions of all manufacturing processes and treatment systems on site. The short survey contained manufacturing process questions for only forming and finishing operations. EPA eliminated the cokemaking, ironmaking, and steelmaking questions from the short survey because those processes were not applicable to the facilities that received the short survey. The Agency also reduced the amount of detail requested in the short survey. EPA used the detailed descriptions of hot forming mills from the integrated, non integrated, and stand alone hot forming mills to make assumptions about industry trends.

Part A Section 1 requested site contacts and addresses and general information regarding manufacturing operations, age, and location. The Agency used this information to develop the proposed subcategorization and applicability statements.

Part A Section 2 requested information on products, types of steel produced, production levels, unit operations, chemicals and coatings used, quantity of wastewater discharged from unit operations, miscellaneous wastewater sources, flow rates, pollution prevention activities, and air pollution control. The Agency used these data to evaluate manufacturing processes and wastewater generation, to develop the model production normalized flow rates, and to develop regulatory options. EPA also used these data to develop the proposed subcategorization and applicability and to estimate compliance costs and pollutant removals associated with the regulatory options EPA considered for the final rule.

Part A Section 3 requested detailed information ( including diagrams) on the wastewater treatment systems and discharge flow rates, monitoring analytical data, and operating and maintenance cost data ( including treatment chemical usage). The Agency used these data to identify treatment technologies in place, to determine regulatory options, and to estimate compliance costs and pollutant removals associated with the regulatory options considered for the final rule.

Part A Section 4 requested permit information, discharge locations, wastewater sources to each outfall, flow rates, regulated pollutants and limits, and permit monitoring data. EPA used this information to calculate baseline or current loadings for each facility. The Agency also used this information to calculate the pollutant loadings associated with the regulatory options considered for the final rule.

The cost survey requested detailed capital cost data on selected wastewater treatment systems installed since 1993, including equipment, engineering design, and installation costs. ( EPA chose 1993 because 1997 was the base year for the detailed and short surveys, and 3 31 3.0  Data Collection Activities this provided the Agency with a five year range for collecting cost data on recently installed treatment systems.) EPA incorporated these data into a costing methodology and used them to determine incremental investment costs and incremental operating and maintenance costs associated with the regulatory options considered for the final rule.

The analytical and production survey requested detailed daily analytical and flow rate data for selected sampling points, and monthly production data and operating hours for selected manufacturing operations. The Agency used the analytical data collected to estimate baseline pollutant loadings and pollutant removals from facilities with treatment in place similar to the technology options considered for the final rule, to evaluate the variability associated with iron and steel industry discharges, and to establish effluent limitations guidelines and standards. The Agency used the production data collected to evaluate the production basis for applying the proposal in National Pollutant Discharge Elimination System ( NPDES) permits and pretreatment control mechanisms.

1997 Iron and Steel Surveys Data Review and Data Entry EPA completed a detailed engineering review of the detailed surveys to evaluate the accuracy of technical information provided by the respondents. During the engineering review, EPA coded responses to facilitate entry of technical data into the survey database. EPA contacted survey respondents, by telephone and letter, to clarify incomplete or inconsistent technical information prior to data entry.

The Agency developed a database for the technical information provided by survey respondents. After engineering review and coding, EPA entered data from the surveys into the database using a double key entry and verification procedure. During the engineering review, EPA coded responses to facilitate entry of technical data into the survey database.

3.1.4 Data Submitted by the American Association of Railroads ( AAR)

As noted in the June 2002 NODA ( 67 FR 38752), EPA conducted another review of all railroad line maintenance ( RRLM) facilities in the MP& M questionnaire database to determine the destination of discharged wastewater ( i. e., either directly to surface waters or indirectly to POTWs or both) and the applicability of the final rule to discharged wastewaters. As a result of this review, EPA determined its questionnaire database did not accurately represent direct dischargers in this subcategory. Consequently, EPA used information supplied during the comment period by the American Association of Railroads ( AAR) as a basis for its analyses and conclusions on direct dischargers in this subcategory.

AAR is a trade association which currently represents all facilities in the RRLM Subcategory. As discussed in the NODA ( see 67 FR 38755), for each RRLM direct discharging facility known to them, AAR provided current permit limits, treatment in place, and summarized information on each facility s measured monthly average and daily maximum values. AAR also 3 32 3.0  Data Collection Activities provided a year s worth of long term monitoring data for each facility ( see Section 15.1 of the rulemaking record for the AAR surveys).

AAR provided information on 27 facilities. EPA reviewed the information on each of these facilities to ensure they were direct dischargers, discharged wastewaters resulting from operations subject to this final rule, and discharged " process" wastewaters as defined by the final rule. As a result of this review, EPA concluded 18 of the facilities for which AAR provided information do not directly discharge wastewaters exclusively from oily operations. Therefore, EPA's final database consists of nine direct discharging RRLM facilities.

3.1.5 National Estimates EPA used the data collected in the MP& M and iron and steel industry surveys to: ( 1) calculate national estimates of the number and types of facilities performing proposed MP& M operations; ( 2) develop the industry profile presented in Section 4.0; ( 3) estimate the current pollutant discharges from facilities performing proposed MP& M operations; and ( 4) identify the baseline of treatment in place. The Agency assigned each survey a specific survey weight to use as a multiplier for national estimates.

Sampling Frame To produce a mailing list of facilities for the MP& M and the iron and steel surveys, EPA developed a sampling frame of the industry. A sampling frame is a list of all members ( sampling units) of a population, from which a random sample of members will be drawn for the survey. Therefore, a sample frame is the basis for the development of a sampling plan to select a random sample. A sample frame size ( N) is the total number of members in the frame.

EPA mailed MP& M industry surveys to all of the facilities in the sample. Based on the survey responses, EPA determined that some facilities were   out of scope  or   ineligible  because the regulation would not apply to them. EPA also made a nonrespondent adjustment to the weights ( see below).

Calculation of Sample Weights The next step in developing national estimates is to calculate the base weights, nonresponse adjustments, and the final weights. The base weights and nonresponse adjustments reflect the probability of selection for each facility and adjustments for facility level nonresponses, respectively. Weighting the data allows inferences to be made about all eligible facilities, not just those included in the sample, but also those not included in the sample or those that did not respond to the survey. Also, the weighted estimates have a smaller variance than unweighted estimates. In its analysis, EPA applied sample weights to survey data.

3 33 3.0  Data Collection Activities Calculation of National Estimates For each characteristic of interest ( e. g., number of sites using a particular unit operation or annual discharge flow from a particular unit operation), EPA estimated totals for the entire U. S. industry performing proposed MP& M operations ( i. e., national estimates). Each national estimate, Yst , was calculated as:

( 3 1)

where: h = Survey where h = 1,2, ... T; T = Total number of surveys; FINALWTh = Final weight for survey h; and yhi = ith value from the sample.

The development of survey weights and national estimates for the MP& M surveys are discussed in greater detail in the Statistical Summary for the Metal Products & Machinery Industry Surveys ( Section 10.0, DCN 16118) and DCNs 36086 and 36087, Section 19.5.

Each national estimate for the entire U. S. iron and steel industry,   st , was calculated as:

( 3 2)

where:

h = Stratum and h= 1,2,... 12 since there are 12 strata; FINALWTh = Final weight for the stratum h; and yih = Ith value from the sample in stratum h.

The development of the iron and steel survey weights and national estimates are discussed in greater detail in the Development Document for Final Effluent Limitations Guidelines and Standards for the Iron and Steel Manufacturing Point Source Category ( EPA 821 R 02 004).

3.2 Site Visits The Agency visited 234 facilities performing proposed MP& M operations and iron and steel sites between 1986 and 2001 to collect information about proposed MP& M operations, water use practices, pollution prevention and treatment technologies, and waste disposal methods, and to evaluate sites for potential inclusion in the MP& M sampling program ( described in Section 3.3). In general, the Agency visited sites to encompass the range of sectors, unit operations, and wastewater treatment technologies within the industry ( discussed in Section 3 34 3.0  Data Collection Activities 3.2.1). Table 3 3 lists the number of sites visited within each industrial sector. The total number of site visits presented in this table exceeds 234 because some sites had operations in more than one sector. Figure 3 2 presents the number of facilities visited and sampled by industrial sector. Table 3 3 and Figure 3 2 also include site visits initially conducted as part of the iron and steel rulemaking, the results of which were incorporated into the MP& M rulemaking.

Table 3 3 Number of Sites Visited Within Each Proposed Industrial Sector Industrial Sectors Total Number of Sites Visited Industrial Sectors Total Number of Sites Visited Aerospace Aircraft Bus and Truck Electronic Equipment Hardware Household Equipment Instrument Job Shops Miscellaneous Metal Products Mobile Industrial Equipment Motor Vehicle 13 32 8 23 15 4 4 25 0 7 20 Office Machines Ordnance Precious Metals and Jewelry Printed Wiring Boards Railroad Ships and Boats Stationary Industrial Equipment Steel Continuous Electroplatinga Steel Forming and Finishing: Wire Drawinga 5 15 2 17 10 7 14 15 4 Source: MP& M and Iron and Steel Site Visits.

a The number of sites visited is listed separately for steel forming and finishing and steel continuous electroplating sites instead of by industrial sector.

3.2.1 Criteria for Site Selection The Agency selected sites for visits based on information contained in the MP& M and iron and steel surveys. The Agency also contacted regional EPA personnel, state environmental agency 3 35 3.0  Data Collection Activities 3 36 Industrial Sector Steel Forming and Finishing  Wire Draw ing Steel Continuous Electroplating Stationary Industrial Equipment Ships and Boats Railroad Printed Wiring Boards Precious Metals and Jew elry Ordnance Office Machines Motor Vehicles Mobile Industrial Equipment Miscellaneous Metal Products Job Shop Metal Finishing Instruments Household Equipment Hardware Electronic Equipment Bus and Truck Aircraft Aerospace 13 2 329 84 234 15 4 4 2 4 2 2510 NA 7 2 20 9 5 2 15 3 2 ( both) 17 5 104 73 144 6 2 42 Number of Sites Sampled Number of Sites Visited 0 5 101520253035 Number of Sites Figure 3 2. Number of Facilities Performing Proposed MP& M Operations Visited and Sampled by Industrial Sector 3.0  Data Collection Activities personnel, and local pretreatment coordinators to identify facilities performing proposed MP& M operations believed to be operating in process source reduction and recycling technologies and/ or well operated end of pipe wastewater treatment technologies. For visits to iron and steel sites prior to receipt of any completed survey, EPA used information collected from the sources used to develop the iron and steel survey receipt list ( discussed in Section 3.1.3).

The Agency used the following four general criteria to select sites that encompassed the range of sectors and unit operations within the industry:

1. The site performed proposed MP& M operations in one of the industrial sectors. To assess the variation of unit operations and water use practices across sectors, the Agency visited sites in 18 industrial sectors.

2. The site performed proposed MP& M operations that needed to be characterized for development of the regulation.

3. The site had water use practices that were believed to be representative of the best sites within an industrial sector.

4. The site operated in process source reduction, recycling, or end of pipe treatment technologies EPA was evaluating in developing the MP& M technology options.

The Agency also visited sites of various sizes. EPA visited sites with wastewater flows ranging from less than 200 gallons per day ( gpd) to more than 1,000,000 gpd.

EPA selected iron and steel sites to visit based on the type of site ( steel forming and finishing, integrated, non integrated), the manufacturing operations at each facility, the type of steel produced ( carbon, alloy, stainless), and the wastewater treatment operations. The Agency wanted to visit all types of iron and steel manufacturing operations as well as all types of wastewater treatment operations, including recently installed treatment systems. After EPA evaluated the completed surveys and in response to comments received on the proposed rule, the Agency used information provided by the sites to select additional iron and steel sites to visit.

Site specific selection criteria are discussed in site visit reports ( SVRs) prepared for each site visited by EPA. The SVRs are located in Sections 5.1 and 15.2 of the rulemaking record.

3 37 3.0  Data Collection Activities 3.2.2 Information Collected During the site visits, EPA collected the following types of information:

  Types of unit operations performed at the site and the types of metals processed through these operations;

  Purpose of unit operations performed and purpose of any process water and chemical additions used by the unit operations;

  Types and disposition of wastewater generated at the site;

  Types of in process source reduction and recycling technologies performed at the site;

  Cross media impacts of in process source reduction and recycling technologies;

  Types of end of pipe treatment technologies performed at the site; and   Logistical information required for sampling.

This information is documented in the SVRs for each site. Nonconfidential SVRs can be found in the MP& M rulemaking record ( see Sections 5.1 and 15.2).

EPA MP& M Sampling Program The Agency conducted sampling episodes at 84 sites between 1986 and 2001 to obtain data on the characteristics of wastewater and solid wastes. In addition, EPA performed sampling episodes to assess the following: ( 1) the loading of pollutants to surface waters and POTWs from facilities performing proposed MP& M operations; ( 2) the effectiveness of technologies designed to reduce and remove pollutants from wastewater; and ( 3) the variation of wastewater characteristics across unit operations, metal types processed in each unit operation, and sectors. Table 3 4 indicates the number of sites sampled within each industrial sector. The number of sampled sites presented in the table does not equal 84 because EPA conducted multiple sampling episodes at some sites, and some sites had operations in multiple sectors. Figure 3 2 presents the number of sites visited and sampled by industrial sector. Table 3 4 and Figure 3 2 also include sites initially sampled as part of the iron and steel rulemaking, the results of which were incorporated into the MP& M rulemaking.

3 38 3.3 3.0  Data Collection Activities Table 3 4 Number of Sites Sampled Within Each Proposed Industrial Industrial Sectors Total Number of Sites Sampled Industrial Sectors Total Number of Sites Sampled Aerospace Aircraft Bus and Truck Electronic Equipment Hardware Household Equipment Instruments Job Shops Miscellaneous Metal Products Mobile Industrial Equipment Motor Vehicle 2 9 4 4 4 2 2 10 0 2 9 Office Machines Ordnance Precious Metals and Jewelry Printed Wiring Boards Railroad Ships and Boats Stationary Industrial Equipment Steel Continuous Electroplatinga Steel Forming and Finishing: Wire Drawinga 2 3 2 5 4 3 4 5 2 Source: MP& M and Iron and Steel Sampling Episodes.

a The number of sites sampled is listed separately for steel forming and finishing and steel continuous electroplater sites instead of by industrial sector.

3.3.1 Criteria for Site Selection The Agency used information collected during MP& M site visits to identify candidate sites for sampling. The Agency used the following general criteria to select sites for sampling:

  The site performed proposed MP& M operations EPA was evaluating for the MP& M regulation;

  The site processed metals through proposed MP& M operations for which the metal type/ unit operation combination needed to be characterized for the sampling database;

  The site performed in process source reduction, recycling, or end of pipe treatment technologies that EPA was evaluating for technology option development; and   The site performed unit operations in a sector that EPA was evaluating for the MP& M regulation.

The Agency also sampled at sites of various sizes, with wastewater flows ranging from less than 200 gpd to more than 1,000,000 gpd.

3 39 3.0  Data Collection Activities EPA selected iron and steel sampling sites using the following criteria:

  The site performed operations either currently regulated under 40 CFR 420 or identified in the Preliminary Study or otherwise identified as iron and steel operations;

  The site performed high rate recycling, in process treatment, or end of pipe treatment operations that EPA believed may represent potential model pollutant control technology; and   The site s compliance monitoring data indicated that it was among the better performing pollutant control systems in the industry, based on comparisons of monitoring data from other facilities with limits from the 1982 regulation in their permits.

In response to comments received on the proposed rule, EPA conducted wastewater sampling at four additional sites between November 2000 and April 2001. EPA selected these additional sites for the following reasons:

  As a collaborative effort between the American Iron and Steel Institute and EPA, to supplement the 1997/ 1998 sampling results by further characterizing raw sinter plant wastewater, specifically the amount of dioxins and furans generated by this industry, and to evaluate wastewater treatment system performance; and   To further characterize untreated wastewater generated by continuous casting and hot forming operations at non integrated steel mills.

After it selected a site for sampling, the Agency prepared a detailed sampling and analysis plan ( SAP), based on the information contained in the SVR and follow up correspondence with the site. EPA prepared the SAPs to ensure samples collected would be representative of the sampled waste streams. The SAPs contained the following types of information: site specific selection criteria for sampling; information about site operations; sampling point locations and sample collection, preservation, and transportation procedures; site contacts; and sampling schedules.

3.3.2 Information Collected In addition to wastewater and solid waste samples, the Agency collected the following types of information during each sampling episode:

  Dates and times of sample collection;

  Flow data corresponding to each sample;

3 40 3.0  Data Collection Activities   Production data corresponding to each sample of wastewater from proposed MP& M operations;

  Design and operating parameters for source reduction, recycling, and treatment technologies characterized during sampling;

  Information about site operations that had changed since the site visit or that were not included in the SVR; and   Temperature and pH of the sampled waste streams.

EPA documented all data collected during sampling episodes in the sampling episode report ( SER) for each sampled site. SERs are located in Sections 5.2 and 15.3 of the rulemaking record.

3.3.3 Sample Collection and Analysis The Agency collected, preserved, and transported all samples according to EPA protocols as specified in EPA s Sampling and Analysis Procedures for Screening of Industrial Effluents for Priority Pollutants ( 1) ( Section 4.2, DCN 17334) and the MP& M Quality Assurance Project Plan ( QAPP) ( Section 4.4, DCN 17366). These documents are located in the rulemaking record. Appendix B presents the analytical methods and baseline values.

In general, EPA collected composite samples from wastewater streams with compositions that the Agency expected to vary over the course of a production period ( e. g., overflowing rinse waters, wastewater from continuous recycling and treatment systems). The Agency collected grab samples from unit operation baths or rinses that the facility did not continuously discharge and that the Agency did not expect to vary over the course of a production period. EPA also collected composite samples of wastewater treatment sludge at 11 facilities. EPA collected the required types of quality control samples as described in the MP& M QAPP, such as blanks and duplicate samples, to verify the precision and accuracy of sample analyses.

The Agency shipped samples via overnight air transportation to EPA approved laboratories, where the samples were analyzed for metal and organic pollutants and additional parameters ( including several water quality parameters). EPA analyzed metal pollutants using EPA Method 1620 ( 2), volatile organic pollutants using EPA Method 1624 ( 3), and semivolatile organic pollutants using EPA Method 1625 ( 4). Tables 3 5 and 3 6 list the metal and organic pollutants, respectively, analyzed using these methods. Table 3 5 also lists additional metal pollutants that EPA analyzed in the MP& M sampling program, but, as specified by EPA Method 1620, were not subject to the rigorous quality assurance/ quality control procedures established by the QAPP.

3 41 3.0  Data Collection Activities Table 3 5 Metal Constituents Measured Under the MP& M Sampling Program ( EPA Method 1620)

Metal Constituents ALUMINUM ANTIMONY ARSENIC BARIUM BERYLLIUM BORON CADMIUM CALCIUM CHROMIUM COBALT COPPER IRON LEAD MAGNESIUM MANGANESE MERCURY MOLYBDENUM NICKEL SELENIUM SILVER SODIUM THALLIUM TIN TITANIUM VANADIUM YTTRIUM ZINC Additional Metal Constituentsa Not Subject to Rigorous QA/ QC Procedures Per Method 1620 BISMUTH CERIUM DYSPROSIUM ERBIUM EUROPIUM GADOLINIUM GALLIUM GERMANIUM GOLD HAFNIUM HOLMIUM INDIUM IODINE IRIDIUM LANTHANUM LITHIUM LUTETIUM NEODYMIUM NIOBIUM OSMIUM PALLADIUM PHOSPHORUS PLATINUM POTASSIUM PRASEODYMIUM RHENIUM RHODIUM RUTHENIUM SAMARIUM SCANDIUM SILICON STRONTIUM SULFUR TANTALUM TELLURIUM TERBIUM THORIUM THULIUM TUNGSTEN URANIUM YTTERBIUM ZIRCONIUM Source: EPA Method 1620. a Analyses for these metals were used primarily for screening purposes 3 42 3.0  Data Collection Activities Table 3 6 Organic Constituents Measured Under the MP& M Sampling Program ( EPA Methods 1624 and 1625)

Volatile Organic Constituents ( EPA Method 1624)

ACRYLONITRILE BENZENE BROMODICHLOROMETHANE BROMOMETHANE CARBON DISULFIDE CHLOROACETONITRILE CHLOROBENZENE CHLOROETHANE CHLOROFORM CHLOROMETHANE CIS 1,3 DICHLOROPROPENE CROTONALDEHYDE DIBROMOCHLOROMETHANE DIBROMOMETHANE DIETHYL ETHER ETHYL CYANIDE ETHYL METHACRYLATE ETHYLBENZENE IODOMETHANE ISOBUTYL ALCOHOL M XYLENE METHYL METHACRYLATE METHYLENE CHLORIDE O+ P XYLENE TETRACHLOROETHENE TETRACHLOROMETHANE TOLUENE TRANS 1,2 DICHLOROETHENE TRANS 1,3 DICHLOROPROPENE TRANS 1,4 DICHLORO 2 BUTENE TRIBROMOMETHANE TRICHLOROETHENE TRICHLOROFLUOROMETHANE VINYL ACETATE VINYL CHLORIDE 1,1 DICHLOROETHANE 1,1 DICHLOROETHENE 1,1,1 TRICHLOROETHANE 1,1,1,2 TETRACHLOROETHANE 1,1,2 TRICHLOROETHANE 1,1,2,2 TETRACHLOROETHANE 1,2 DIBROMOETHANE 1,2 DICHLOROETHANE 1,2 DICHLOROPROPANE 1,2,3 TRICHLOROPROPANE 1,3 BUTADIENE, 2 CHLORO 1,3 DICHLOROPROPANE 1,4 DIOXANE 2 BUTANONE 2 CHLOROETHYL VINYL ETHER 2 HEXANONE 2 PROPANONE 2 PROPEN 1 OL 2 PROPENAL 2 PROPENENITRILE, 2 METHYL 3 CHLOROPROPENE 4 METHYL 2 PENTANONE ACROLEIN 3 43 3.0  Data Collection Activities Table 3 6 ( Continued)

Semivolatile Organic Constituents ( EPA Method 1625)

ACENAPHTHENE ACENAPHTHYLENE ACETOPHENONE ALPHA TERPINEOL ANILINE ANILINE, 2,4,5 TRIMETHYL ANTHRACENE ARAMITE BENZANTHRONE BENZENETHIOL BENZIDINE BIS( 2 CHLOROETHOXY) METHANE BIS( 2 CHLOROETHYL) ETHER BIS( 2 CHLOROISOPROPYL) ETHER BIS( 2 ETHYLHEXYL) PHTHALATE BUTYL BENZYL PHTHALATE CARBAZOLE CHRYSENE CIODRIN CROTOXYPHOS DI N BUTYL PHTHALATE DI N OCTYL PHTHALATE DI N PROPYLNITROSAMINE DIBENZO( A, H) ANTHRACENE DIBENZOFURAN DIBENZOTHIOPHENE DIETHYL PHTHALATE DIMETHYL PHTHALATE DIMETHYL SULFONE DIPHENYL ETHER DIPHENYLAMINE DIPHENYLDISULFIDE ETHANE, PENTACHLOROETHYL METHANESULFONATE ETHYLENETHIOUREA FLUORANTHENE FLUORENE HEXACHLOROBENZENE HEXACHLOROBUTADIENE HEXACHLOROCYCLOPENTADIENE HEXACHLOROETHANE HEXACHLOROPROPENE HEXANOIC ACID INDENO( 1,2,3 CD) PYRENE BENZO( A) ANTHRACENE BENZO( A) PYRENE BENZO( B) FLUORANTHENE BENZO( GHI) PERYLENE BENZO( K) FLUORANTHENE BENZOIC ACID BENZONITRILE, 3,5 DIBROMO 4 HYDROXY BENZYL ALCOHOL BETA NAPHTHYLAMINE BIPHENYL BIPHENYL, 4 NITRO N EICOSANE N HEXACOSANE N HEXADECANE N NITROSODI N BUTYLAMINE N NITROSODIETHYLAMINE N NITROSODIMETHYLAMINE N NITROSODIPHENYLAMINE N NITROSOMETHYLETHYLAMINE N NITROSOMETHYLPHENYLAMINE N NITROSOMORPHOLINE N NITROSOPIPERIDINE N OCTACOSANE N OCTADECANE N TETRACOSANE N TETRADECANE N TRIACONTANE N, N DIMETHYLFORMAMIDE NAPHTHALENE NITROBENZENE O ANISIDINE O CRESOL O TOLUIDINE O TOLUIDINE, 5 CHLORO P CHLOROANILINE P CRESOL P CYMENE P DIMETHYLAMINOAZOBENZENE P NITROANILINE PENTACHLOROBENZENE PENTACHLOROPHENOL PENTAMETHYLBENZENE PERYLENE PHENACETIN 3 44 3.0  Data Collection Activities Table 3 6 ( Continued)

Semivolatile Organic Constituents ( EPA Method 1625)

ISOPHORONE ISOSAFROLE LONGIFOLENE MALACHITE GREEN MESTRANOL METHAPYRILENE METHYL METHANESULFONATE N DECANE N DOCOSANE N DODECANE STYRENE THIANAPHTHENE THIOACETAMIDE THIOXANTHE 9 ONE TOLUENE, 2,4 DIAMINO TRIPHENYLENE TRIPROPYLENEGLYCOL METHYL ETHER 1 BROMO 2 CHLOROBENZENE 1 BROMO 3 CHLOROBENZENE 1 CHLORO 3 NITROBENZENE 1 METHYLFLUORENE 1 METHYLPHENANTHRENE 1 NAPHTHYLAMINE 1 PHENYLNAPHTHALENE 1,2 DIBROMO 3 CHLOROPROPANE 1,2 DICHLOROBENZENE 1,2 DIPHENYLHYDRAZINE 1,2,3 TRICHLOROBENZENE 1,2,3 TRIMETHOXYBENZENE 1,2,4 TRICHLOROBENZENE 1,2,4,5 TETRACHLOROBENZENE 1,2: 3,4 DIEPOXYBUTANE 1,3 DICHLORO 2 PROPANOL 1,3 DICHLOROBENZENE 1,3,5 TRITHIANE 1,4 DICHLOROBENZENE 1,4 DINITROBENZENE 1,4 NAPHTHOQUINONE 1,5 NAPHTHALENEDIAMINE 2( METHYLTHIO) BENZOTHIAZOLE 2 CHLORONAPHTHALENE 2 CHLOROPHENOL 2 ISOPROPYLNAPHTHALENE 2 METHYLBENZOTHIOAZOLE 2 METHYLNAPHTHALENE PHENANTHRENE PHENOL PHENOL, 2 METHYL 4,6 DINITRO PHENOTHIAZINE PRONAMIDE PYRENE PYRIDINE RESORCINOL SAFROLE SQUALENE 2 NITROANILINE 2 NITROPHENOL 2 PHENYLNAPHTHALENE 2 PICOLINE 2,3 BENZOFLUORENE 2,3 DICHLOROANILINE 2,3 DICHLORONITROBENZENE 2,3,4,6 TETRACHLOROPHENOL 2,3,6 TRICHLOROPHENOL 2,4  DICHLOROPHENOL 2,4 DIMETHYLPHENOL 2,4 DINITROPHENOL 2,4 DINITROTOLUENE 2,4,5 TRICHLOROPHENOL 2,4,6 TRICHLOROPHENOL 2,6 DI TERT BUTYL P BENZOQUINONE 2,6 DICHLORO 4 NITROANILINE 2,6 DICHLOROPHENOL 2,6 DINITROTOLUENE 3 METHYLCHOLANTHRENE 3 NITROANILINE 3,3' DICHLOROBENZIDINE 3,3' DIMETHOXYBENZIDINE 3,6 DIMETHYLPHENANTHRENE 4 AMINOBIPHENYL 4 BROMOPHENYL PHENYL ETHER 4 CHLORO 2 NITROANILINE 4 CHLORO 3 METHYLPHENOL 4 CHLOROPHENYL PHENYL ETHER 4 NITROPHENOL 4,4' METHYLENEBIS( 2 CHLOROANILINE) 4,5 METHYLENE PHENANTHRENE 5 NITRO O TOLUIDINE 7,12 DIMETHYLBENZ( A) ANTHRACENE N NITRODOSI N PROPYLAMINE Source: EPA Methods 1624 and 1625.

3 45 3.0  Data Collection Activities The Agency used these metals analyses for screening purposes and did not select the metals for regulation in this rulemaking ( see Section 7.0). EPA analyzed additional parameters, including several water quality parameters, using analytical methods contained in EPA s Methods for Chemical Analysis of Water and Wastes ( 5). Table 3 7 lists these parameters, along with the method and technique used to analyze for each parameter. Method descriptions are included in the MP& M QAPP. The specific parameters measured in each sample are listed in the SER for each sampling episode.

Quality control measures used in performing all analyses complied with the guidelines specified in the analytical methods and in the MP& M QAPP. EPA reviewed all analytical data to ensure that these measures were followed and that the resulting data were within the QAPP specified acceptance criteria for accuracy and precision.

As discussed previously, upon receipt and review of the analytical data for each site, EPA prepared an SER to document the data collected during sampling, the analytical results, and the technical analyses of the results. The SAPs and correspondence with site personnel are included as appendices to the SERs.

Other Sampling Data The Association of American Railroads ( AAR), the Hampton Roads Sanitation District ( HRSD), the Los Angeles County Sanitation Districts ( LACSD), and the Association Connecting Electronic Industries ( IPC) proposed potential sampling sites to the Agency, and EPA visited these sites to identify candidates for sampling. After conducting site visits, EPA selected six sites for sampling episodes.

EPA selected the six sites to characterize end of pipe treatment technologies in metal finishing and aircraft parts job shops and the railroad and shipbuilding industrial sectors. AAR sampled a railroad line maintenance that used dissolved air flotation ( DAF) to treat MP& M process wastewater. HRSD sampled a ship manufacturer that uses DAF, chemical precipitation, and cyanide destruction to treat process wastewater. LACSD sampled two metal finishing job shops and one aircraft parts manufacturing job shop. EPA selected the LACSD sites to provide data for cyanide treatment and also conducted effluent variability sampling at one of the metal finishing job shops. The IPC site is a printed wiring board facility that uses chemical precipitation with chelation breaking, cyanide destruction and batch treatment to treat process wastewater.

EPA prepared detailed SAPs based on the information collected during the six site visits, and AAR, HRSD and LACSD collected the wastewater samples. EPA also prepared the sampling episode reports. In addition to the wastewater samples, sampling personnel documented the collection date and time, sample flow data, treatment unit design and operating parameters, and temperature and pH of the sampled waste streams. All data collected during sampling episodes are documented in the SER for each sampled site, which are located in the 3 46 3.4 3.0  Data Collection Activities Table 3 7 Additional Parameters Measured Under the MP& M Sampling Program Parameter EPA Method Acidity 305.1 Alkalinity 310.1 Ammonia as Nitrogen 350.1 BOD 5 Day ( Carbonaceous) 405.1 Chemical Oxygen Demand ( COD) 410.1 410.2 Chloride 325.3 Chromium, Hexavalent 218.4 Cyanide, Amenable 335.1 Cyanide, Total 335.2 Cyanide, Weak Acid Dissociable ( WAD) 1677 Fluoride 340.2 Nitrogen, Total Kjeldahl 351.2 Oil and Grease 413.2 Oil and Grease ( as HEM) 1664 pH 150.1 Phenolics, Total Recoverable 420.2 Phosphorus, Total 365.4 Sulfate 375.4 Sulfide, Total 376.1, 376.2 Total Dissolved Solids ( TDS) 160.1 Total Organic Carbon ( TOC) 415.1 Total Petroleum Hydrocarbons ( as SGT HEM) 1664 Total Suspended Solids ( TSS) 160.2 Ziram ( zinc dimethyldithiocarbamate) 630.1 Source: EPA Methods for Chemical Analysis of Water and Wastes ( 5).

3 47 3.0  Data Collection Activities MP& M rulemaking record ( see Sections 5.2 and 15.3). EPA combined these data with data collected from the MP& M sampling program. For a discussion of sample collection and the sampling protocols for the IPC site, see the SER ( DCN 16684) in Section 15.3.7 of the MP& M rulemaking record.

AAR, HRSD, and LACSD collected, preserved, and transported all samples according to EPA protocols as specified in EPA s Sampling and Analysis Procedures for Screening of Industrial Effluents for Priority Pollutants ( Section 4.2, DCN 17334) and the MP& M QAPP. Procedures for shipping and analysis of the samples were similar to those discussed in Section 3.3 with the exception that some samples were shipped directly to internal sanitation district laboratories for analysis. Pollutant parameters and analytical methods were agreed upon by EPA, AAR, HRSD, and LACSD and were treated as equivalent to those in the EPA MP& M sampling program.

Other Industry Supplied Data EPA evaluated other industry data in developing the MP& M effluent guidelines. The data sources reviewed included:

  Public comments to the May 1995 Proposal, January 2001 proposal, and June 2002 NODA;

  The Metal Finishing F006 Benchmark Study ( 6);

  Data supporting the Final Rule for the F006 Accumulation Time Extension ( 65 FR 12377, March 8, 2000);

  Data provided by the Aluminum Anodizing Council ( AAC), the American Wire Producers Association ( AWPA), and the Aerospace Association; and   Surveys provided by the North Carolina Pretreatment Consortium.

EPA also reviewed data from stormwater pollution prevention plans provided by several shipbuilding sites, dry dock data from a shipbuilding site, and data from periodic compliance monitoring reports/ discharge monitoring reports for 19 sites that were part of the Agency s wastewater sampling program.

The Agency included data submitted with comments on the 1995 MP& M Proposed Rule, the 2001 MP& M Proposed Rule, or the 2002 MP& M NODA in the establishment of effluent limitations and standards if they met the following criteria:

  Measurements of daily effluent concentration were provided;

3 48 3.5 3.0  Data Collection Activities   Data represented effluent from a treatment system equivalent to EPA s BAT options;

  Samples represented fully treated effluent ( as defined by Options 2, 6, or 10 as appropriate); and   Treated pollutants were identified and/ or unit operations contributing pollutants were described.

In addition, the North Carolina Pretreatment Consortium conducted a survey of POTWs in that state. EPA evaluated the results of these surveys and used the results as appropriate to verify and supplement information from the previous MP& M POTW survey on loadings, number of facilities performing proposed MP& M operations served, and administrative costs. The results of EPA s analysis of this data is in the Comment Response Document, Issue Codes 4 and 20G. The AMSA and North Carolina Pretreatment Consortium surveys can be found in Section 17.6 of the rulemaking record.

Other Data Sources In developing the MP& M effluent guidelines, EPA evaluated the following existing data sources:

1. EPA Engineering and Analysis Division ( EAD) databases from development of effluent guidelines for miscellaneous metals industries;

2. The Fate of Priority Pollutants in Publicly Owned Treatment Works ( 50 POTW Study) database;

3. The Office of Research and Development ( ORD) National Risk Management and Research Laboratory ( NRMRL) treatability database;

4. The Domestic Sewage Study;

5. The Toxics Release Inventory ( TRI) database; and 6. Discharge Monitoring Reports ( DMR) from EPA s Permit Compliance System ( PCS).

These data sources and their uses for the development of the MP& M effluent guidelines are discussed below.

3 49 3.6 3.0  Data Collection Activities 3.6.1 EPA/ EAD Databases As discussed in Section 2.0, EPA had earlier promulgated effluent guidelines for 13 metals industries. In developing these past effluent guidelines, EPA collected wastewater samples to characterize the unit operations and treatment systems at sites in these industries. Facilities performing proposed MP& M operations operate many of the same or similar sampled unit operations and treatment systems; therefore, EPA evaluated these data for transfer to the MP& M effluent guidelines development effort.

For the pollutant loading and wastewater characterization efforts, EPA reviewed the data collected for unit operations performed at both facilities performing proposed MP& M operations and at sites in the other metals industries. EPA reviewed the Technical Development Documents ( TDDs), sampling episode reports, and supporting rulemaking record materials for the other metals industries to identify available data. EPA used these data for the preliminary assessment of the industry, but did not use these data to estimate pollutant loadings because EPA obtained sufficient data from the MP& M sampling program to characterize the proposed MP& M operations.

For the MP& M technology effectiveness assessment effort, EPA reviewed sampling data collected to characterize treatment systems for the development of effluent guidelines for miscellaneous metals industries. For several previous effluent guidelines, EPA used treatment data from metals industries to develop the Combined Metals Database ( CMDB), which served as the basis for developing limits for these industries. EPA also developed a separate database used as the basis for limits for the Metal Finishing category. EPA used the CMDB and Metal Finishing data as a guide in identifying well designed and well operated treatment systems. EPA did not use these data in developing the MP& M technology effectiveness concentrations, since the Agency collected sufficient data from facilities performing proposed MP& M operations to develop technology effectiveness concentrations.

3.6.2 Fate of Priority Pollutants in Publicly Owned Treatment Works Database In September 1982, EPA published the Fate of Priority Pollutants in Publicly Owned Treatment Works ( 7), referred to as the 50 POTW Study. The purpose of this study was to generate, compile, and report data on the occurrence and fate of the 129 priority pollutants in 50 POTWs. The report presents all of the data collected, the results of preliminary evaluations of these data, and the results of calculations to determine the following:

  The quantity of priority pollutants in the influent to POTWs;

  The quantity of priority pollutants discharged from the POTWs;

  The quantity of priority pollutants in the effluent from intermediate process streams; and 3 50 3.0  Data Collection Activities   The quantity of priority pollutants in the POTW sludge streams.

EPA used the data from this study to assess removal by POTWs of pollutants of concern ( see Section 7). To provide consistency for data analysis and establishment of removal efficiencies, EPA reviewed the 50 POTW Study and standardized the reported minimum levels of quantitation ( MLs) for use in the MP& M final rule. EPA s review of the 50 POTW Study is described in more detail in the development document for the MP& M proposed regulation located in Section 7.2 of the rulemaking record, DCN 16377, and in memoranda located in Section 6.4 of the rulemaking record.

3.6.3 National Risk Management Research Laboratory ( NRMRL) Treatability Database EPA s ORD developed the NRMRL ( formerly RREL) treatability database to provide data on the removal and destruction of chemicals in various types of media, including water, soil, debris, sludge, and sediment. This database contains treatability data from POTWs as well as industrial facilities for various pollutants. The database includes physical and chemical data for each pollutant, the types of treatment used for specific pollutants, the types of wastewater treated, the size of the POTW or industrial plant, and the treatment concentrations achieved. EPA used the NRMRL database to estimate pollutant reductions achieved by POTWs for MP& M pollutants of concern that were not found in the 50 POTW database. The Agency used these percent removal estimates in calculating the pollutant loads removed by indirect discharging facilities performing proposed MP& M operations. Because the 50 POTW database contained sufficient data, EPA did not use these percent removal estimates in the pass through analysis. EPA used only treatment technologies representative of typical POTW secondary treatment operations ( i. e., activated sludge, activated sludge with filtration, aerated lagoons). The Agency further edited these files to include information pertaining only to domestic or industrial wastewater. EPA used pilot scale and full scale data, and eliminated bench scale data and data from less reliable references.

3.6.4 The Domestic Sewage Study In February 1986, EPA issued the Report to Congress on the Discharge of Hazardous Wastes to Publicly Owned Treatment Works ( 8), referred to as the Domestic Sewage Study ( DSS). This report, which was based in part on the 50 POTW Study, revealed a significant number of sites discharging pollutants to POTWs. These pollutants are a threat to the treatment capability of the POTW. These pollutants were not regulated by national effluent regulations. Some of the major sites identified were in the metals industries, particularly one called equipment manufacturing and assembly. This industry included sites that manufacture such products as office machines, household appliances, scientific equipment, and industrial machine tools and equipment. The DSS estimated that this category discharges 7,715 metric tons per year of priority hazardous organic pollutants, which are presently unregulated. Data on priority hazardous metals discharges were unavailable for this category. Further review of the DSS revealed miscellaneous categories that were related to metals industries, namely the motor 3 51 3.0  Data Collection Activities vehicle category, which includes servicing of new and used cars and engine and parts rebuilding, and the transportation services category, which includes railroad operations, truck service and repair, and aircraft servicing and repair. EPA used the information in the DSS in developing the 1989 Preliminary Data Summary ( PDS) for the MP& M rulemaking.

3.6.5 Toxics Release Inventory ( TRI) Database The TRI database contains specific toxic chemical release and transfer information from manufacturing facilities throughout the United States. This database was established under the Emergency Planning and Community Right to Know Act of 1986 ( EPCRA), which Congress passed to promote planning for chemical emergencies and to provide information to the public about the presence and release of toxic and hazardous chemicals. Each year, manufacturing facilities meeting certain activity thresholds must report the estimated releases and transfers of listed toxic chemicals to EPA and to the state or tribal entity in whose jurisdiction the facility is located. The TRI list includes more than 600 chemicals and 30 chemical categories.

EPA considered using the TRI database in developing the MP& M effluent guidelines. However, EPA did not use TRI data on wastewater discharges from facilities performing proposed MP& M operations because sufficient data were not available for effluent guidelines development. Also, many of the reported discharges are estimates, not based on measurement. For example, in developing the MP& M effluent guidelines, EPA uses wastewater influent concentrations to characterize a facility s wastewater and to calculate treatment efficiency ( i. e., percent removal across the treatment system). The TRI database does not provide concentrations for the influent to a facility s treatment system. EPA also did not use the data on wastewater discharge because many facilities performing proposed MP& M operations do not meet the reporting thresholds for the TRI database.

3.6.6 Discharge Monitoring Reports from EPA s Permit Compliance System The PCS provides information on companies which have been issued permits to discharge wastewater into surface water. Users can review information on when a permit was issued and expires, how much the company is permitted to discharge, and the actual monitoring data showing what the company has discharged. Respondents to MP& M surveys and commentors on the May 1995 proposal, January 2001 proposal, and June 2002 NODA supplied facility specific DMR data. In addition, EPA retrieved facility limits and process wastewater monitoring data from facilities performing proposed MP& M operations for selected pollutant parameters ( e. g., metals, oil and grease). EPA used DMR data to estimate industry baseline pollutant loadings. Section 12.3 discusses the estimation of baseline pollutant loadings using PCS data.

3 52 3.0  Data Collection Activities 3.7 References 1. U. S. Environmental Protection Agency. Sampling and Analysis Procedures for Screening of Industrial Effluents for Priority Pollutants , April 1977.

2. U. S. Environmental Protection Agency. Method 1620 Draft  Metals by Inductively Coupled Plasma Atomic Emission Spectroscopy and Atomic Absorption Spectroscopy , September 1989.

3. U. S. Environmental Protection Agency. Method 1624 Revision C  Volatile Organic Compounds by Isotope Dilution GCMS , June 1989.

4. U. S. Environmental Protection Agency. Method 1625 Revision C  Semivolatile Organic Compounds by Isotope Dilution GCMS , June 1989.

5. U. S. Environmental Protection Agency. Methods for Chemical Analysis of Water and Wastes . EPA 600/ 4 79 020, Washington, DC, March 1979.

6. U. S. Environmental Protection Agency. Metal Finishing F006 Benchmark Study . Washington, DC, September 1998.

7. U. S. Environmental Protection Agency. Fate of Priority Pollutants in Publicly Owned Treatment Works . EPA 440/ 1 82/ 303, Washington, DC, September 1982.

8. U. S. Environmental Protection Agency. Report to Congress on the Discharge of Hazardous Wastes to Publicly Owned Treatment Works . EPA 530 SW 86 004, Washington, DC, February 1986.

9. U. S. Environmental Protection Agency. Development Document for Final Effluent Limitations Guidelines and Standards for the Iron and Steel Manufacturing Point Source Category ( EPA 821 R 02 004).

3 53 4.0  Industry Description 4.0 INDUSTRY DESCRIPTION As discussed in Section 1.0, EPA has promulgated effluent limitations for the MP& M Point Source Category that regulate directly discharged process wastewaters from oily operations at facilities engaged in manufacturing, rebuilding, or maintenance of metal parts, products, or machines for use in one or more of the following 16 industrial sectors:

  Aerospace;

  Aircraft;

  Bus and Truck;

  Electronic Equipment;

  Hardware;

  Household Equipment;

  Instruments;

  Mobile Industrial Equipment;

  Motor Vehicle;

  Office Machine;

  Ordnance;

  Precious Metals and Jewelry;

  Railroad;

  Ships and Boats;

  Stationary Industrial Equipment; and   Miscellaneous Metal Products.

This section describes these facilities. For the final rule, EPA evaluated facilities in the 16 MP& M industrial sectors above and Job Shop, Printed Wiring Board, and Steel Forming and Finishing industrial sectors ( i. e., Iron & Steel Wire Drawers and Steel Electroplaters). For the purposes of this section, EPA is identifying all facilities evaluated for the final rule as   MP& M facilities.  Section 4.1 presents an overview of MP& M facilities; Section 4.2 provides a general discussion of unit operations performed, types of metal processed, and volumes of wastewater discharged at MP& M facilities; Section 4.3 discusses trends at MP& M facilities; and Section 4.4 lists the references used in this section.

4.1 Overview of MP& M facilities This subsection discusses the number and size of MP& M facilities evaluated for regulation, the geographic distribution of these facilities, the number of wastewater discharging MP& M facilities, and the number of MP& M facilities that do not discharge wastewater.

4 1 4.0  Industry Description 4.1.1 Number and Size of MP& M Facilities Based on information in the MP& M survey database, there are an estimated 57,000 MP& M facilities in the United States. 1 Results of the detailed surveys indicate there are an estimated 44,000 MP& M facilities that discharge process wastewater ( i. e., wastewater discharging MP& M facilities). The remaining 13,000 facilities fall into one of three categories: zero dischargers, non water users, or contract haulers. A zero discharger is a facility that does not discharge process wastewater to a treatment system, a non water user is a facility that does not use process water in their unit operations, and a contract hauler is a facility that has all of their process wastewater contract hauled. For the purposes of the evaluating options for the final rule, EPA considers MP& M facilities that discharge wastewater exclusively to privately owned treatment works to be zero dischargers that contract haul their wastewater to centralized wastewater treatment facilities.

Wastewater discharging MP& M facilities range in size from facilities with less than 10 employees to facilities with thousands of employees. As shown in Figure 4 1, 91 percent of the wastewater discharging MP& M facilities have 500 or fewer employees. These facilities discharge 55 percent ( i. e., 43 billion gallons per year) of the total annual wastewater discharge for the MP& M industry. The 9 percent of the wastewater discharging MP& M facilities that have more than 500 employees discharge 35 billion gallons of wastewater annually, or 45 percent of the total annual wastewater discharge for the MP& M category.

1More information on how the MP& M survey database was used to generate national estimates is in the MP& M rulemaking record ( see Section 10.0, DCN 16118 and Section 19.5, DCNs 36086 and 36087).

4 2 4.0  Industry Description 60 47%

1% 17%

7% 9% 8% 18% 39%

8% 9%

2% 22%

< 1% 13%

< 1% 1% Percentage of MP& M Wastewater Discharging Sites Percentage of Total Annual MP& M Discharge Flow 50 40 Percentage 30 20 10 0 <= 10 11 50 51 100 101 500 501 1,000 1,001 5,000 5,001 10,000 > 10,000 Number of Employees Source: MP& M Survey Database. Note: There are 44,000 wastewater discharging MP& M facilities. Total MP& M wastewater flow is 78.2 billion gallons per year.

Figure 4 1. Percentage of Wastewater Discharging MP& M facilities and Percentage of Annual Wastewater Discharge by Number of Employees 4.1.2 Geographic Distribution Wastewater discharging MP& M facilities are located throughout the United States. They are mostly concentrated in industrialized areas, with the highest concentration of facilities in California, Pennsylvania, and Illinois. The following map shows the estimated number of wastewater discharging MP& M facilities located in each EPA region.

4 3 4.0  Industry Description 4 4 Figure 4 2. ated Number of Wastewater Discharging MP& M facilities by EPA Region 4.1.3Wastewater Discharging Facilities EPA evaluated MP& M facilities in 20 industrial sectors for the final rule. Table 4 1 summarizes the number of wastewater discharging MP& M facilities by industrial sector. Because some MP& M facilities perform operations or make products used in more than one sector, the sum of wastewater discharging MP& M facilities by sector exceeds the total number of wastewater discharging MP& M facilities identified in the surveys. As shown in Table 4 1, the ordnance sector has the smallest number of wastewater discharging facilities ( 405) and the job shop sector has the largest number of wastewater discharging facilities ( 14,589). Estim 4.0  Industry Description Table 4 1 Wastewater Discharging MP& M facilities by Sector Sector Estimated Number of MP& M Facilities That Discharge Process Wastewatera Aerospace 712 Aircraft 1,598 Bus and Truck 3,522 Electronic Equipment 2,644 Hardware 6,223 Household Equipment 3,137 Instruments 3,902 Iron and Steel Wire Drawersb , c 153 Job Shop c 14,589 Miscellaneous Metal Products 5,316 Mobile Industrial Equipment 1,079 Motor Vehicle 13,070 Office Machine 1,092 Ordnance 405 Precious Metals and Jewelry 1,860 Printed Circuit Boards c 1,456 Railroad 5,181 Ships and Boats 1,367 Stationary Industrial Equipment 1,724 Steel Electroplatersb , c 28 Source: MP& M Survey Database. a Because some facilities perform unit operations in more than one sector, the sum of facilities by sector exceeds the total number of facilities that discharge wastewater ( 44,000). b Technical surveys for these facilities did not include sector information; therefore, they were listed separately for this table. c These industrial sectors are not included in the final rule.

4 5 4.0  Industry Description In addition to description by industrial sector, MP& M operations2 that were proposed for regulation 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 products. These operations are intended to keep metal products in operating condition and can be performed in either a production or a nonproduction environment.

Figure 4 3 presents the percentage of wastewater discharging MP& M facilities and percentage of the total annual wastewater discharge by activity. Eighty two percent of the annual wastewater discharge is discharged by facilities with only manufacturing operations. These facilities represent 35 percent of the total wastewater discharging MP& M facilities. The highest percentage of the MP& M facilities ( i. e., 50 percent) have only rebuilding and maintenance operations.

2EPA evaluated a number of unit operations for the May 1995 proposal, January 2001 proposal, and June 2002 Notice of Data Availability ( 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.

4 6 4.0  Industry Description 80 70 60 50 15%

12% 35% 82%

50%

6% Percentage of MP& M Wastewater Discharging Sites Percentage of Total Anuual MP& M Discharge Flow Percentage 40 30 20 10 0 Manufacturing and Manufacturing Only Rebuilding/ Maintenance Only Rebuilding/ Maintenance Activity Source: MP& M Survey Database. Note: There are 44,000 wastewater discharging MP& M facilities. Total MP& M wastewater flow is 78.2 billion gallons per year.

Figure 4 3. Percentage of Wastewater Discharging MP& M facilities and Percentage of Total Annual Discharge by Activity Wastewater discharging MP& M facilities include direct dischargers, indirect dischargers, and those that are both direct and indirect dischargers. A direct discharger is a facility that discharges wastewater to a surface water ( e. g., river, lake, ocean). An indirect discharger is a facility that discharges wastewater to a publicly owned treatment works ( POTW). Figure 4 4 presents the percentage of wastewater discharging MP& M facilities and the percentage of the total annual wastewater discharge by discharge status. This figure shows that the highest percentage of wastewater discharging MP& M facilities are indirect dischargers, and those facilities account for 85 percent of the total annual discharge from all MP& M facilities.

4 7 4.0  Industry Description 100 90 80 70 60 Percentage 50 40 30 20 10 0 Direct and Indirect Direct Indirect < 1% < 1% 6% 15% 94%

85% Percentage of MP& M Wastewater Discharging Sites Percentage of Total Annual MP& M Discharge Flow Discharge Destination Source: MP& M Survey Database. Note: There are 44,000 wastewater discharging MP& M facilities. Total MP& M wastewater flow is 78.2 billion gallons per year.

Figure 4 4. Percentage of Wastewater Discharging MP& M facilities and Percentage of Total Annual Discharge by Discharge Status Wastewater discharge flow rates for MP& M facilities range from less than 100 gallons per year to greater than 100 million gallons per year. Figure 4 5 presents the percentage of wastewater discharging MP& M facilities and the percentage of the annual MP& M wastewater discharge by range of wastewater flow rates. As this figure shows, MP& M facilities discharging more than one million gallons per year ( approximately 12 percent of the total facilities) account for approximately 95 percent of the total annual wastewater discharge for all MP& M facilities. In contrast, facilities discharging less than 100,000 gallons per year ( approximately 62 percent of the total facilities) account for less than one percent of the total annual wastewater discharge for all MP& M facilities.

4 8 4.0  Industry Description 50 45 40 35 30 5%

< 1% 30%

< 1% 10%

< 1% 17%

< 1% 25%

5% 9% 18%

3% 47%

< 1% 30% Percentage of MP& M Wastewater Discharging Sites Percentage of Total Annual MP& M Discharge Flow Percentage 25 20 15 10 5 0 0 100 101 1,000 1,001 10,000 10,001 100,001 1,000,001 10,000,001> 100,000,000 100,000 1,000,000 10,000,000 100,000,000 Discharge Flow Range ( GPY)

Source: MP& M Survey Database. Note: There are 44,000 wastewater discharging MP& M facilities. Total MP& M wastewater flow is 78.2 billion gallons per year.

Figure 4 5. Percentage of Wastewater Discharging MP& M facilities and Percentage of Total Annual MP& M Discharge by Flow Rate Range 4.1.4 Non Wastewater Discharging Facilities Based on the results of the detailed MP& M surveys, an estimated 13,000 MP& M facilities either generate process water and do not discharge wastewater ( i. e., zero discharge or contract haulers) or do not use process water ( dry facilities). Information from the MP& M detailed surveys, site visits, and technical literature indicates these facilities achieve zero discharge of process wastewater in one of the following ways:

  Contract haul all process wastewater generated on site;

  Discharge process wastewater to either on site septic systems or deep well injection systems;

4 9 4.0  Industry Description   Perform end of pipe treatment and reuse all process wastewater generated on site;

  Perform either in process or end of pipe evaporation to eliminate wastewater discharges; or   Perform in process recirculation and recycling to eliminate wastewater discharges.

As discussed in Section 3.0, EPA mailed the 1989 detailed survey to a probability sample of 50 screener respondents that reported using but not discharging process water. Based on the survey responses, 5 of these facilities contract hauled all wastewater generated on site, 8 actually discharged process wastewater, 18 had no process wastewater discharges, and 19 were not engaged in proposed MP& M operations. The Agency also mailed the 1989 detailed survey to an additional 24 screener respondents that reported using but not discharging process water. As discussed in Section 3.0, EPA selected these facilities because they performed unit operations that were not expected to be characterized sufficiently by detailed surveys mailed to other facilities. Of the additional 24, 14 actually discharged process wastewater, 2 had no process wastewater discharges, and 8 were not engaged in proposed MP& M operations. Of the 74 screener respondents that received the 1989 detailed survey, only 20 reported no discharge of process water.

In addition to the 20 facilities discussed above that do not discharge process wastewater, 205 of the 1996 screener survey respondents reported eliminating wastewater discharges by in process or end of pipe evaporation, end of pipe treatment and reuse, in process recirculation and recycling, or other unspecified means. Figure 4 6 shows the percentage of the facilities using each type of zero discharge method. Note that Figure 4 6 provides the percentage of survey respondents, not industry percentages, because this information was available for only a subset of the industry. The methods used by the 225 survey facilities to eliminate wastewater discharges are discussed below.

In Process or End Of Pipe Evaporation. Forty one percent of the screener survey respondents ( i. e., 92 respondents) reported discharging wastewater to either evaporators, on site ponds, or lagoons to evaporate process wastewater. None of these facilities reported recovering the process wastewater. Facilities reported contracting for off site disposal of sludge from the evaporation units.

End Of Pipe Treatment and Reuse. Eight percent of the screener survey respondents ( i. e., 18 respondents) reported eliminating wastewater discharges through end of pipe treatment and reuse of all wastewater generated on site.

4 10 4.0  Industry Description U nknow n M ethods  O f Other I n  P ro ce s s o r E n d I n  P ro ce s s 12 %

Pipe Evaporation 16% 41%

End O f Pip e Recirculation and Treatment and Reuse Recy cling 8% 23%

Note: There are 225 survey facilities that have eliminated wastewater discharge.

Figure 4 6. Percentage of Screener Survey Respondents Using Each Zero Discharge Method In Process Recirculation and Recycling. Twenty three percent of the screener survey respondents ( i. e., 52 respondents) reported eliminating wastewater discharges through in process recirculation and recycling. Several facilities used a stagnant bath in their heat treating operations. Some facilities used stagnant baths in their surface finishing operations ( e. g., alkaline cleaning and chemical conversion coating). Make up water is added to the stagnant baths to account for losses of bath water through evaporation.

Other. Sixteen percent of the screener survey respondents ( i. e., 36 respondents) reported eliminating wastewater discharge through a variety of other methods including land application and septic tank systems or contract hauling through a centralized waste treater ( CWT) or privately owned treatment works ( PrOTW).

4.2 Proposed MP& M Operations This subsection discusses the proposed MP& M operations and presents a brief description of each unit operation. It also discusses the metals processed in proposed MP& M operations, and presents an estimate of the annual wastewater discharge for each proposed MP& M operations.

4 11 4.0  Industry Description 4.2.1 Types of Unit Operations MP& M facilities perform several different types of unit operations and associated rinses on metal parts, products, and machines. Section 4.2.2 describes these unit operations.

The types of proposed MP& M operations include:

  Metal shaping;

  Surface preparation;

  Metal deposition;

  Organic material deposition;

  Surface finishing;

  Assembly;

  Dry dock; and   Specialized printed wiring board operations.

Metal shaping is a mechanical operation that alters the form of raw materials into intermediate and final products. Surface preparation includes chemical and mechanical operations that remove unwanted materials from or alter the chemical or physical properties of the part surface prior to subsequent proposed MP& M operations. Metal deposition applies a metal coating to the part surface by chemical or physical means. Organic material deposition applies an organic material to the part by chemical or physical means. Facilities may perform metal and organic material deposition to protect the surface from wear or corrosion, modify the electrical properties of the surface, or alter the appearance of the surface. Surface finishing protects and seals the surface of the treated part from wear or corrosion by chemical means. Facilities also may use surface finishing to alter the appearance of the part surface. Assembly is performed throughout the manufacturing, rebuilding, or maintenance process. Dry dock operations are proposed MP& M operations performed at ship and boat facilities within dry docks or similar structures and incorporate many types of proposed MP& M operations. Printed wiring board unit operations are those specific to the manufacture or rebuilding/ maintenance of wiring boards ( e. g., carbon black deposition, solder flux cleaning, and photo image developing). Specialized printed wiring board operations do not include those performed at assembly only facilities. Table 4 2 lists examples of the different types of proposed MP& M operations.

4 12 4.0  Industry Description Table 4 2 Types of Proposed MP& M operations Type of Unit Operations Example Metal Shaping Machining, Grinding, Deformation Surface Preparation Alkaline Cleaning, Acid Treatment Metal Deposition Electroplating, Vapor Deposition Organic Material Deposition Painting Surface Finishing Chemical Conversion Coating Assembly Testing ( e. g., leak testing), Assembly Dry Dock Welding Specialized Printed Wiring Board Solder Leveling, Photoresist Applications At a given MP& M facility, the specific unit operations and the sequence of operations depend on many factors, including the activity at the facility ( i. e., manufacturing, rebuilding/ maintenance), industrial sector, and type of product processed. As a result, MP& M facilities perform many different combinations and sequences of unit operations. For example, MP& M facilities that repair, rebuild or maintain products often conduct preliminary operations that may not be performed at manufacturing facilities ( e. g., disassembly, cleaning, or degreasing to remove dirt and oil accumulated during use of the product). In general, however, MP& M products are processed in the following order:

  The raw material ( e. g., bar stock, wire, rod, sheet stock, plates) undergoes some type of metal shaping process, such as impact or pressure deformation, machining, or grinding. In these operations, the raw material is shaped into intermediate forms for further processing or into final forms for assembly and shipment to the customer. Facilities typically clean and degrease the parts between some of the shaping operations to remove lubricants, coolants, and metal fines. Facilities also may heat a part between shaping operations to alter its physical characteristics.

  After shaping, the part typically undergoes some type of surface preparation, such as alkaline cleaning, acid treatment ( pickling), or barrel finishing. The specific operation depends on the subsequent unit operations and the final use of the products. For example, prior to electroplating, parts typically go through acid pickling ( i. e., acid cleaning) to prepare the part surface for electroplating. Before assembly, parts typically go through alkaline cleaning or barrel finishing. Parts go through surface preparation at various stages of the production process. Additional cleaning and degreasing steps precede metal deposition, organic material deposition, surface finishing, and assembly.

4 13 4.0  Industry Description   Metal and organic material deposition typically follow shaping and surface preparation, and precede surface finishing and final assembly. For example, electroplating usually follows alkaline and acid treatment, while painting usually follows phosphate conversion coating and alkaline treatment.

  Surface finishing operations typically are performed after shaping and surface preparation. Some surface finishing is performed after metal deposition. For example, chromate conversion coating typically follows acid cleaning, although this operation is sometimes performed as a sealant operation after electroplating ( e. g., chemical conversion coating of cadmium plated parts). Surface finishing also is done prior to applying organic coatings. For example, phosphate conversion coating frequently precedes painting to enhance the paint adhesion.

  Disassembly may be the first step in the rebuilding process. Assembly, on the other hand, is done during many steps of the manufacturing and rebuilding process to prepare the final product. Assembly also may involve some final shaping ( e. g., drilling and grinding) and surface preparation ( e. g., alkaline cleaning). Final assembly usually is the last operation prior to shipment to the customer.

Some MP& M facilities conduct all of these types of unit operations in manufacturing or rebuilding products, while others may perform only some types. For example, a facility that manufactures products used in the hardware sector may start with bar stock and manufacture a final hardware product, performing machining, cleaning, electroplating, conversion coating, painting, degreasing, and assembly. Another hardware product manufacturing facility may only clean and paint the parts. A third hardware product manufacturing facility may only shape the parts, and perform only machining, cleaning, and degreasing operations.

4.2.2 Description of Proposed MP& M Operations EPA described the operations above as either metal bearing operations or oily operations. This section describes each of the MP& M operations for which EPA considered new regulations. Oily operations ( as defined in 40 CFR 438.2( f)) are listed in Table 4 3. Metal bearing operations ( as defined in 40 CFR 438.2( d)) are listed in Table 4 4.

4 14 4.0  Industry Description Table 4 3 List of MP& M Oily Operations   Abrasive Blasting   Iron Phosphate Conversion Coating   Adhesive Bonding   Machining   Alkaline Cleaning for Oil Removal   Painting spray or Brush ( Including Water Curtains)

  Alkaline Treatment Without Cyanide   Polishing   Aqueous Degreasing   Pressure Deformation   Assembly/ Disassembly   Solvent Degreasing   Burnishing   Steam Cleaning   Calibration   Testing ( e. g., Hydrostatic, Dye Penetrant, Ultrasonic, Magnetic   Corrosion Preventive Coating Flux)

  Electrical Discharge Machining   Thermal Cutting   Floor Cleaning ( In Process Area)   Tumbling/ Barrel Finishing/ Mass Finishing/ Vibratory Finishing   Grinding   Washing ( Finished Products)

  Heat Treating   Welding   Impact Deformation   Wet Air Pollution Control for Organic Constituents Note: This list is replicated at 40 CFR 438.2( f) with definitions at Appendix B to Part 438.

4 15 4.0  Industry Description Table 4 4 List of MP& M Metal Bearing Operations   Abrasive Jet Machining   Mechanical and Vapor Plating   Acid Pickling Neutralization   Metallic Fiber Cloth Manufacturing   Acid Treatment With Chromium   Metal Spraying ( including Water Curtain)

  Acid Treatment Without Chromium   Painting immersion ( including Electrophoretic, " E coat")

  Alcohol Cleaning   Photo Imaging   Alkaline Cleaning Neutralization   Photo Image Developing   Alkaline Treatment With Cyanide   Photoresist Application   Anodizing With Chromium   Photoresist Strip   Anodizing Without Chromium   Phosphor Deposition   Carbon Black Deposition   Physical Vapor Deposition   Catalyst Acid Pre dip   Plasma Arc Machining   Chemical Conversion Coating Without Chromium   Plastic Wire Extrusion   Chemical Milling ( or Chemical Machining)   Salt Bath Descaling   Chromate Conversion Coating ( or Chromating)   Shot Tower  Lead Shot Manufacturing   Chromium Drag out Destruction   Soldering   Cyanide Drag out Destruction   Solder Flux Cleaning   Cyaniding Rinse   Solder Fusing   Electrochemical Machining   Solder Masking   Electroless Catalyst Solution   Sputtering   Electroless Plating   Stripping ( paint)

  Electrolytic Cleaning   Stripping ( metallic coating)

  Electroplating With Chromium   Thermal Infusion   Electroplating With Cyanide   Ultrasonic Machining   Electroplating Without Chromium or Cyanide   Vacuum Impregnation   Electropolishing   Vacuum Plating   Galvanizing/ Hot Dip Coating   Water Shedder   Hot Dip Coating   Wet Air Pollution Control   Kerfing   Wire Galvanizing Flux   Laminating Note: This list is replicated at 40 CFR 438.2( d) with definitions at Appendix C to Part 438.

4 16 4.0  Industry Description EPA also evaluated process wastewater from   Bilge Water  and   Dry Dock/ Stormwater  for the final rule. These two processes generate mainly oily or organic wastewater but are not included in the final definition of   oily operations  ( as defined in 40 CFR 438.2( f)) as these unit operations only occur at facilities EPA decided should not be subject to the final rule ( see 40 CFR 438.1( e)( 5)). EPA used the following definitions for   Bilge Water  and   Dry Dock/ Stormwater  for the final rule:

  Bilge Water is water that collects in the inner hull of a ship. When a ship is in a dry dock or similar structure, the bilge water is collected and then treated and disposed of.

  Dry Dock/ Stormwater . Maintenance operations performed on a ship/ boat in a dry dock that either use process water or are exposed to stormwater.

The following descriptions are provided to aid the reader in understanding the described processes and do not supersede regulatory definitions of unit operations in the final MP& M rule. Moreover, the definitions in this section should not be used to differentiate between the six   core  metal finishing operations ( i. e., Electroplating, Electroless Plating, Anodizing, Coating ( chromating, phosphating, and coloring), Chemical Etching and Milling, and Printed Circuit Board Manufacture) and 40   ancillary  process operations listed at 40 CFR 433.10( a).

<IP_ADDRESS> Description of MP& M Oily Operations Abrasive Blasting involves removing surface film from a part by using abrasive directed at high velocity against the part. Abrasive blasting includes bead, grit, shot, and sand blasting, and may be performed either dry or with water. The primary applications of wet abrasive blasting include: removing burrs on precision parts; producing satin or matte finishes; removing fine tool marks; and removing light mill scale, surface oxide, or welding scale. Wet blasting can be used to finish fragile items such as electronic components. Also, some aluminum parts are wet blasted to achieve a fine grained matte finish for decorative purposes. In abrasive blasting, the water and abrasive typically are reused until the particle size diminishes due to impacting and fracture.

Adhesive Bonding involves joining parts using an adhesive material. Typically, an organic bonding compound is used as the adhesive. This operation usually is dry; however, aqueous solutions may be used as bonding agents or to contain residual organic bonding materials.

Alkaline Cleaning for Oil Removal is a general term for the application of an alkaline cleaning agent to a metal part to remove oil and grease during the manufacture, maintenance, or rebuilding of a metal product.

This unit operation does not include washing of the finished products after routine use ( as defined in   Washing ( Finished Products)  in this subsection), or applying an alkaline cleaning 4 17 4.0  Industry Description agent to remove nonoily contaminants such as dirt and scale ( as defined in   Alkaline Treatment Without Cyanide  in this subsection and   Alkaline Treatment With Cyanide  in Section <IP_ADDRESS>). Wastewater generated includes spent cleaning solutions and rinse waters.

  Alkaline cleaning is performed to remove foreign contaminants from parts. This operation usually is done prior to finishing ( e. g., electroplating).

  Emulsion cleaning is an alkaline cleaning operation that uses either complex chemical enzymes or common organic solvents ( e. g., kerosene, mineral oil, glycols, and benzene) dispersed in water with the aid of an emulsifying agent. The pH of the solvent usually is between 7 and 9, and, depending on the solvent used, cleaning is performed at temperatures from room temperature to 82 ° C ( 180 ° F). This operation often is used as a replacement for vapor degreasing.

Alkaline Treatment Without Cyanide is a general term used to describe the application of an alkaline solution not containing cyanide to a metal surface to clean the metal surface or prepare the metal surface for further surface finishing.

Aqueous Degreasing involves cleaning metal parts using aqueous based cleaning chemicals primarily to remove residual oils and greases from the part. Residual oils can be from previous operations ( e. g., machine coolants), oil from product use in a dirty environment, or oil coatings used to inhibit corrosion. Wastewater generated by this operation includes spent cleaning solutions and rinse waters.

Assembly/ Disassembly involves fitting together previously manufactured or rebuilt parts or components into a complete metal product or machine or taking a complete metal product or machine apart. Assembly/ disassembly operations are typically dry; however, special circumstances can require water for cooling or buoyancy. Also, rinsing may be necessary under some conditions.

Burnishing involves finish sizing or smooth finishing a part ( previously machined or ground) by displacing, rather than removing, minute surface irregularities with smooth point or line contact, fixed or rotating tools. Lubricants or soap solutions can be used to cool the tools used in burnishing operations. Wastewater generated during burnishing include process solutions and rinse water.

Calibration is performed to provide reference points for the use of a product. This unit operation typically is dry, although water may be used in some cases ( e. g., pumping water for calibration of a pump). Water used in this unit operation usually does not contain additives.

Corrosion Preventive Coating involves applying removable oily or organic solutions to protect metal surfaces against corrosive environments. Corrosion preventive coatings include, but are not 4 18 4.0  Industry Description limited to: petrolatum compounds, oils, hard dry film compounds, solvent cutback petroleum based compounds, emulsions, water displacing polar compounds, and fingerprint removers and neutralizers. Corrosion preventive coating does not include electroplating or chemical conversion coating operations.

Many corrosion preventive materials also are formulated to function as lubricants or as a base for paint. Typical applications include: assembled machinery or equipment in standby storage; finished parts in stock or spare parts for replacement; tools such as drills, taps, dies, and gauges; and mill products such as sheet, strip, rod and bar.

Wastewater generated during corrosion preventive coating includes spent process solutions and rinses. Process solutions are discharged when they become contaminated with impurities or are depleted of constituents. Corrosion preventive coatings typically do not require an associated rinse, but parts are sometimes rinsed to remove the coating before further processing.

Electrical Discharge Machining involves removing metals by a rapid spark discharge between different polarity electrodes, one the part and the other the tool, separated by a small gap. The gap may be filled with air or a dielectric fluid. This operation is used primarily to cut tool alloys, hard nonferrous alloys, and other hard to machine materials. Most electrical discharge machining processes are operated dry; however, in some cases, the process uses water and generates wastewater containing dielectric fluid.

Floor Cleaning ( in Process Area) removes dirt, debris, and process solution spills from process area floors. Floors can be cleaned using wet or dry methods, such as vacuuming, mopping, dry sweeping, and hose rinsing. Nonprocess area floor cleaning in offices and other similar nonprocess areas is not included in this unit operation.

Grinding involves removing stock from a part by using abrasive grains held by a rigid or semirigid binder. Grinding shapes or deburrs the part. The grinding tool usually is a disk ( the basic shape of grinding wheels), but can also be a cylinder, ring, cup, stick, strip, or belt. The most commonly used abrasives are aluminum oxide, silicon carbide, and diamond. The process may use a grinding fluid to cool the part and remove debris or metal fines.

Wastewater generated during grinding includes spent coolants and rinses. Metal working fluids become spent for a number of reasons, including increased biological activity ( i. e., the fluids become rancid) or decomposition of the coolant additives. Rinse waters typically are assimilated into the working fluid or treated on site.

Heat Treating involves modifying the physical properties of a part by applying controlled heating and cooling cycles. This operation includes tempering, carburizing, cyaniding, nitriding, annealing, aging, normalizing, austenitizing, austempering, siliconizing, martempering, and malleablizing. Parts are heated in furnaces or molten salt baths, and then may be cooled by quenching in aqueous solutions ( e. g., brine solutions), neat oils ( pure oils with little or no impurities), or oil/ water emulsions. Heat treating typically is a dry operation, but is considered a 4 19 4.0  Industry Description wet operation if aqueous quenching solutions are used. Wastewater includes spent quench water and rinse water.

Impact Deformation involves applying impact force to a part to permanently deform or shape it. Impact deformation may include mechanical processes such as hammer forging, shot peening, peening, coining, high energy rate forming, heading, or stamping.

Natural and synthetic oils, light greases, and pigmented lubricants are used in impact deformation operations. Pigmented lubricants include whiting, lithapone, mica, zinc oxide, molybdenum disulfide, bentonite, flour, graphite, white lead, and soap like materials.

These operations typically are dry, but wastewater can be generated from lubricant discharge and from rinsing operations associated with the operation.

Iron Phosphate Conversion Coating is the process of applying a protective coating on the surface of a metal using a bath consisting of a phosphoric acid solution containing no metals ( e. g., manganese, nickel, or zinc) or a phosphate salt solution ( i. e., sodium or potassium salts of phosphoric acid solutions) containing no metals ( e. g., manganese, nickel, or zinc) other than sodium or potassium. Any metal concentrations in the bath are from the substrate.

Machining involves removing stock from a part ( as chips) by forcing a cutting tool against the part. This includes machining processes such as turning, milling, drilling, boring, tapping, planing, broaching, sawing, shaving, shearing, threading, reaming, shaping, slotting, hobbing, and chamfering. Machining processes use various types of metal working fluids, the choice of which depends on the type of machining being performed and the preference of the machine shop. The fluids can be categorized into four groups: straight oil ( neat oils), synthetic, semisynthetic, and water soluble oil.

Machining operations generate wastewater from working fluid or rinse water discharge. Metal working fluids periodically are discarded because of reduced performance or development of a rancid odor. After machining, parts are sometimes rinsed to remove coolant and metal chips. The coolant reservoir is sometimes rinsed, and the rinse water is added to the working fluid.

Painting  Spray or Brush ( Including Water Curtains) involves applying an organic coating to a part. Coatings such as paint, varnish, lacquer, shellac, and plastics are applied by spraying, brushing, roll coating, lithographing, powder coating, and wiping.

Water is used in painting operations as a solvent ( water borne formulations) for rinsing, for cleanup, and for water wash ( or curtain) type spray booths. Paint spray booths typically use most of the water in this unit operation. Spray booths capture overspray ( i. e., paint that misses the product during application), and control the introduction of pollutants into the workplace and environment.

4 20 4.0  Industry Description Polishing involves removing stock from a part using loose or loosely held abrasive grains carried to the part by a flexible support. Usually, the objective is to achieve a desired surface finish or appearance rather than to remove a specified amount of stock. Buffing is included in this unit operation, and usually is performed using a revolving cloth or sisal buffing wheel, which is coated with a suitable compound. Liquid buffing compounds are used extensively for large volume production on semiautomated or automated buffing equipment. Polishing operations typically are dry, although liquid compounds and associated rinses are used in some polishing processes.

Pressure Deformation involves applying force ( other than impact force) to permanently deform or shape a part. Pressure deformation may include rolling, drawing, bending, embossing, sizing, extruding, squeezing, spinning, necking, forming, crimping or flaring.

These operations use natural and synthetic oils, light greases, and pigmented lubricants. Pigmented lubricants include whiting, lithapone, mica, zinc oxide, molybdenum disulfide, bentonite, flour, graphite, white lead, and soap like materials.

Pressure deformation typically is dry, but wastewater is sometimes generated from the discharge of lubricants or from rinsing associated with the process.

Solvent Degreasing removes oils and grease from the surface of a part using organic solvents, including aliphatic petroleum ( e. g., kerosene, naphtha), aromatics ( e. g., benzene, toluene), oxygenated hydrocarbons ( e. g., ketones, alcohol, ether), and halogenated hydrocarbons ( e. g., 1,1,1 trichloroethane, trichloroethylene, methylene chloride).

Solvent cleaning takes place in either the liquid or vapor phase. Solvent vapor degreasing normally is quicker than solvent liquid degreasing. However, ultrasonic vibration is sometimes used with liquid solvents to decrease the required immersion time of complex shapes. Solvent cleaning often is used as a precleaning operation prior to alkaline cleaning, as a final cleaning of precision parts, or as surface preparation for some painting operations. Solvent degreasing operations typically are not followed by rinsing, although rinsing is performed in some cases.

Steam Cleaning removes residual dirt, oil, and grease from parts after processing though other unit operations. Typically, additives are not used in this operation; the hot steam removes the pollutants. Wastewater is generated when the cleaned parts are rinsed.

Testing ( e. g., hydrostatic, dye penetrant, ultrasonic, magnetic flux) involves applying thermal, electrical, mechanical, hydraulic, or other energy to determine the suitability or functionality of a part, assembly, or complete unit. Testing also may include applying surface penetrant dyes to detect surface imperfections. Other examples of tests frequently performed include electrical testing, performance testing, and ultrasonic testing; these tests typically are dry but may generate wastewater under certain circumstances. Testing usually is performed to replicate some aspect of the working environment. Wastewater generated during testing includes spent process solutions and rinses.

4 21 4.0  Industry Description Thermal Cutting involves cutting, slotting, or piercing a part using an oxy acetylene oxygen lance, electric arc cutting tool, or laser. Thermal cutting typically is a dry process, except for the use of contact cooling waters and rinses.

Tumbling/ Barrel Finishing/ Mass Finishing/ Vibratory Finishing involves polishing or deburring a part using a rotating or vibrating container and abrasive media or other polishing materials to achieve a desired surface appearance. Parts to be finished are placed in a rotating barrel or vibrating unit with an abrasive media ( e. g., ceramic chips, pebbles), water, and chemical additives ( e. g., alkaline detergents). As the barrel rotates, the upper layer of the part slides toward the lower side of the barrel, causing the abrading or polishing. Similar results can be achieved in a vibrating unit, where the entire contents of the container are in constant motion, or in a centrifugal unit, which compacts the load of media and parts as the unit spins and generates up to 50 times the force of gravity. Spindle finishing is a similar process, where parts to be finished are mounted on fixtures and exposed to a rapidly moving abrasive slurry.

Wastewater generated during barrel finishing includes spent process solutions and rinses. Following the finishing process, the contents of the barrel are unloaded. Process wastewater is either discharged continuously during the process, discharged after finishing, or collected and reused. The parts are sometimes given a final rinse to remove particles of abrasive media.

Washing ( Finished Products) involves cleaning finished metal products after use or storage using fresh water or water containing a mild cleaning solution. This unit operation applies only to the finished products that do not require maintenance or rebuilding.

Welding involves joining two or more pieces of material by applying heat, pressure, or both, with or without filler material, to produce a metallurgical bond through fusion or recrystallization across the interface. This includes gas welding, resistance welding, arc welding, cold welding, electron beam welding, and laser beam welding. Welding typically is a dry process, except for the occasional use of contact cooling waters or rinses.

Wet Air Pollution Control for Organic Constituents involves using water to remove organic constituents that are entrained in air streams exhausted from process tanks or production areas. Most frequently, wet air pollution control devices are used with cleaning and coating processes. A common type of wet air pollution control is the wet packed scrubber consisting of a spray chamber that is filled with packing material. Water is continuously sprayed onto the packing and the air stream is pulled through the packing by a fan. Pollutants in the air stream are absorbed by the water droplets and the air is released to the atmosphere. A single scrubber often serves numerous process tanks.

<IP_ADDRESS> Description of MP& M Metal bearing Operations Abrasive Jet Machining includes removing stock material from a part by a high speed stream of abrasive particles carried by a liquid or gas from a nozzle. Abrasive jet machining is used for deburring, drilling, and cutting thin sections of metal or composite material. Unlike abrasive 4 22 4.0  Industry Description blasting, this process operates at pressures of thousands of pounds per square inch. The liquid streams typically are alkaline or emulsified oil solutions, although water also can be used.