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 Finishing Point Source Category. The Review 

concerns the effluent limitation guidelines and standards (ELGs) for the metal finishing 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

Phillip Flanders EPA

Ali Ghulam EPA

Julia Anastasio ACWA

Sean Rolland ACWA

Susan Kirsch ACWA

Martha 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 received 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 and 
electroplating 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 guidance issued from EPA 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 policy documents (e.g. guidance) are helpful to address 

issues with implementation but that a rule change is most effective. 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 definitions

of etching and cleaning and whether or not citric acid passivation is regulated under Part 433. 

EPA asked ACWA and its members on the call if they were aware of water-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

issued facilities that do not discharge; 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 

mentioned 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 could 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 Kansas 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 interest 

in “carrying on the family business.” Following the call, Deborah 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 organic 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 mentioned 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 attached. 

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.