MEMORANDUM

TO: Metal Finishing Preliminary Category Review Record

FROM: Phillip Flanders, EAD

DATE: January 5, 2016

EPA held a conference call with the Association of Clean Water Administrators ( ACWA ) and some state pretreatment coordinators on November 9 , 2015 to discuss the Agency’s Preliminary Category Review of the Metal Fi nishing Point Source Category. The Review concerns the effluent limitation guidelines and standards (ELGs) for the metal finish ing point source category (40 CFR Part 433) and the ELGs for the electroplating category (40 CFR Part 413). The attendees are listed along with their affiliation in the table below.

Attendee Organization (State)

Jan Goodwin EPA

Jan Pickrel EPA

Philli p Flanders EPA

Ali Ghulam EPA

Julia Anastasio ACWA

Sean Rolland ACWA

Susan Kirsch ACWA

Marth a Clark Mettler IDEM (IN) Natalie Maupin IDEM (IN) Scott Ramsey ADEM (AL)

Allen Gilliam ADEQ (AR)

Deborah Gore NCDEQ (NC)

Sarah Holcomb NMED (NM)

Roshini Nambiar ODEQ (OK)

Grace Scott MDEQ (MI) Santiago Velez

- Garcia TCEQ (TX)

Rebecca Villalba TCEQ (TX) Steve Caspers KDHE (KS)

Jen Robinson UDEQ (UT)

Bob Zimmerman NDEQ (NE) Dave Knight WSDE (WA)

Deborah DiBiasi VDEQ (VA) Tina McFarling SDDENR (SD)

EPA sent a list of question which ACWA edited and distributed to its State employee members (attached). EPA explained that it is conducting a study of the metal finishing industry based on its statutory requirements under the Clean Water Act. EPA had re ceived comments regarding metal finishing on its Effluent Guidelines Program Plan from ACWA and the National

Association of Surface Finishers and reached out to both organizations for additional information. EPA is interested in applicability issues with the existing metal finishing andelectroplating ELGs , changes in metal finishing industry practices and processes, and modern

metal finishing wastewater treatment technology.

EPA first asked ACWA members about their experiences applying the existing metal finishing regulation and how EPA could act to help resolve some of the outstanding issues.

Alan Gilliam suggested that states would like gu idance issued from E PA that would explain the policies that they are required to implement. He suggested writing a guidance document on the use of citric acid based chemistries. He also suggested that it may be time to update the metal finishing guidance manual (which was published in 1984).

Dave Knight suggested that it may be time to sunset 40 CFR Part 413, the Electroplating Category, as it was meant to be replaced by 40 CFR Part 433 the Metal Finishing Category.

Rebecca Villalba suggested the poli cy documents (e.g. guidan ce) are helpful to address

issue s with implementation but that a rule change is most eff ective. She mentioned that TCEQ

has had issues with truck washing stations that use brighteners and whether or not these facilities

should be regulated as metal finishing facilities. She also mentioned issues with the definition s of etching and cleaning and whether or not citric acid passivation is regulated under Part 433.

EPA asked ACWA and its members on the c all if they were aware of wate r

- use reduction

or zero

- liquid discharge (ZLD) efforts conducted by the metal finishing industry. Alan Gilliam mentioned that most facilities achieve ZLD by using evaporation, but those systems tend to be high cost and have issues handling the evaporator solid waste which is a listed hazardous waste. Other issues with ZLD issues include cost, and buildup of salts and other contaminants in

recirculated wastewater. EPA asked which states have programs where ZLD permits can be

issue d facilities that do not d ischarge; the following states were mentioned: AL, WA, VT, IN, KS, TX. Rebecca Villalba suggested that EPA could provide guidance on how to calculate

mass

- based limits for metal finishers to encourage reduction in water use at these facilities. She

menti oned that in Texas 5% of metal finishers use evaporation to treat wastewater, 5% haul their wastewater to a treatment facility and 90% have wastewater treatment equipment installed on

site as pretreatment before discharge to a POTW

. It was mentioned that facilities likely have

means available to reduce their use of rinse water such as counter

- current rinsing and spray rinsing. It was suggested the EPA could develop BMPs for metal finishing facilities that would

direct them to use less water. Those BMPs c ould either be suggested for permit writers to include as narrative criteria in permits via guidance or they could be included in the effluent guideline through rulemaking (and implemented as narrative criteria in permits). Steve Caspers

mentioned that Ka nsas metal finishers reduced their water use when there were asked to install flow meters to measure how much water they were actually using.

EPA asked about the best way to find a list of metal finishing facilities to help EPA

determine the current size and demographics of the industry. There was general agreement that

the number of facilities in the U.S. has decreased. Grace Scott mentioned that small facilities in Michigan have mostly been dissolved partly due to economics and partly due to lack of i nterest
in “ carrying on the family business. ” Following the call, Deb o ra h DiBiasi sent a list of facilities in Virginia. It was mentioned that Alaska maintains a list on its pretreatment website.EPA asked ACWA and its members if there were pollutants discharged by metal

finishers that are of concern to them. Rebecca Villalba listed phosphorous (because of limits imposed on POTWs in their NPDES permits) and total dissolved solids (TDS). Additives, as a category, were mentioned because there is little or no monitoring required for these chemicals. It was mentioned that the overall outcome, i.e. a toxicity endpoint, may be more useful than focusing on individual chemicals. It was suggested the EPA could provide more guidance on toxic organi c management plans ( TOMPs ) . Region 6 has developed some guidance for total toxic organic limits. Similar to water

- use reduction, EPA could suggest BMPs for toxic chemicals or it could include them in new rulemaking.

EPA asked if there was any information or monitoring data on phosphorous discharges from metal finishing facilities. It was noted that, in general , monitoring data for phosphorous exists where there is a total maximum daily load (TMDL) in place for phosphorous in the receiving water. It was m entioned that this information exists in some parts of Kansas and in

northwestern Arkansas.

Lastly, EPA requested site visit candidates and welcomed any additional comments or suggestions from ACWA members via email. Responses received by EPA are attach ed. Deborah DiBiasi responded with a list of metal finishers in Virginia. Grace Scott replied with suggestions of site visit candidates in Michigan. Steve Caspers and Dave Knight provided

further comments.