MEMORANDUM 

TO: Steam Electric Rulemaking Record 

FROM: TJ Finseth, ERG 

DATE: April 19, 2013 

SUBJECT: Nonchemical Metal Cleaning Waste Permit Review 

ERG is providing technical support to the U.S. Environmental Protection Agency’s Office of 

Water, Engineering and Analysis Division (EAD) for development of effluent limitations 

guidelines and standards (ELGs) for the Steam Electric Power Generating Industry. As part of 

this technical support, ERG supported EPA with coordinating a permit review to evaluate how 

nonchemical metal cleaning wastes discharges from power plants are currently being regulated in 

NPDES permits. ERG used data from the Questionnaire for the Steam Electric Power 

Generating Effluent Guidelines (Steam Electric Survey) to identify those plants that reported 

generating nonchemical and chemical metal cleaning wastes.1

 EPA then provided the listing of 

these plants, included in Attachment 1 to this memorandum (spreadsheet titled “Survey MCW 

Plant Listing”), to the EPA Regional offices and asked them to review permits contained within 

their region and provide answers to the following questions for each permit reviewed: 

1. How is the metal cleaning waste handled at the plant? Is there any distinction 

between chemical cleaning waste and nonchemical cleaning waste? If so, what are 

the limits for each? 

2. How is the nonchemical cleaning waste handled at the plant, as metal cleaning 

waste or low-volume waste? What is the limit used? 

3. If the non-chemical cleaning waste is handled as low-volume waste, what is the 

basis for this assumption? Does the factsheet make any specific reference to the 

1975 EPA “Jordan Memo” or provide other justification? 

EPA’s Regional offices completed reviews for 56 permits. ERG compiled the responses from 

each of the regions and entered the information into a spreadsheet, included in Attachment 1 to 

this memorandum (spreadsheet titled “Permit Review Information”). Because EPA’s Regional 

offices provided varying levels of detail in their responses, ERG used best professional judgment 

to classify the information provided by the regions. In some cases, ERG determined there was 

insufficient detail to classify the responses and the plant was excluded from the analysis. 

Attachment 1 to this memorandum is a Microsoft® Excel Workbook that contains two 

spreadsheets. The first spreadsheet, “Survey MCW Plant Listing,” is the plant listing provided to 

the EPA Regional offices identifying those plants that reported generating chemical or 

nonchemical metal cleaning wastes in response to the Steam Electric Survey. The second 

 

1

 Because only a subset of steam electric power plants were required to respond to Part E: Wastes from Cleaning 

Metal Process Equipment, the list of plants generating these wastes is not a complete listing for the industry. 
Memorandum 

April 19, 2013 

Page 2 

spreadsheet, “Permit Review Information,” is the compiled results from the permit review. Table 

1 includes descriptions for each field in the spreadsheet and how ERG populated the field based 

on the information provided by the EPA Regional offices. 

Table 1. Nonchemical Metal Cleaning Waste Permit Review Compiled Spreadsheet 

Description

Field Name Field Description and Population Methodology 

Region Region in which the plant is located. 

State State in which the plant is located. 

NPDES Permit NPDES Permit Identification Number. 

Plant Name Name of the plant reviewed. 

Metal Cleaning Waste Type Identifies the type of metal cleaning waste generated at the plant (i.e., “chemical,” 

“nonchemical,” or “chemical and nonchemical”). This field was generally 

populated based on the responses to the Steam Electric Survey; however, it was 

updated based on the permit review responses, if discrepancies were identified. 

Is there a distinction between 

chemical and nonchemical 

cleaning waste? 

Identifies if the permit makes any type of distinction between chemical and 

nonchemical metal cleaning wastes, or if the two wastes are regulated similarly. In 

certain cases, additional information may be provided in this column (e.g., “NA; 

CMCW is trucked off site. There is no discharge to surface waters.”) to expand on 

the response. 

Is nonchemical cleaning waste 

permitted with limits for metal 

cleaning waste or low volume 

waste? 

Identifies whether the nonchemical cleaning wastes are permitted based on the 

metal cleaning waste BPT limits or the low volume wastes BPT limits. In general, 

this column was populated based on whether the permit review identified if the 

plant had copper and iron limits for the nonchemical metal cleaning waste 

discharges. ERG assumed the wastes were permitted based on metal cleaning waste 

BTP limits if the plant was required to meet copper and iron limits. 

If nonchemical cleaning waste 

is handled as low volume 

waste, what is the basis? 

Identifies the basis for the nonchemical metal cleaning waste limits if they are 

based on low volume waste limits (i.e., no copper and iron limits). The main 

purpose of this column was to identify if the “Jordan Memo” was used as a basis 

for low volume waste limits. 

Limits and Other Comments Contains additional information provided by the EPA Regional offices based on the 

permit review, such as the specific limits for metal cleaning waste discharges or 

additional information about the basis for the limits. 

Evaluation of the Permit Review Results: The following fields were populated based on ERG’s assessment of the 

information provided by the EPA Regional offices. 

Can’t Evaluate Cleaning Type ERG concluded that there was not enough information provided to include this 

plant in the analysis (indicated by a “1”). 

Reason For those plants for which ERG “Can’t Evaluate Cleaning Type,” this field 

provides additional information as to why the plant was not included in the 

analysis. 

Chemical Cleaning Wastes 

Only 

ERG concluded that the plant only generates chemical metal cleaning wastes and 

does not have nonchemical metal cleaning wastes (indicated by a “1”). 

Zero Discharge ERG concluded that the plant does not discharge any chemical or nonchemical 

metal cleaning wastes (indicated by a “1”). 

Chemical plus Nonchemical 

Metal Cleaning Wastes? 

ERG concluded that the plant generates both chemical and nonchemical metal 

cleaning wastes (indicated by a “1”). 

Nonchemical Metal Cleaning 

Wastes? 

ERG concluded that the plant generates only nonchemical metal cleaning wastes 

(indicated by a “1”). 
Memorandum 

April 19, 2013 

Page 3 

Table 1. Nonchemical Metal Cleaning Waste Permit Review Compiled Spreadsheet 

Description

Field Name Field Description and Population Methodology 

Low-Volume Waste Limits? ERG concluded that the plant’s metal cleaning waste discharges are regulated 

based on the low volume waste BPT requirements (indicated by a “1”). 

Metal Cleaning Waste Limits? ERG concluded that the plant’s metal cleaning waste discharges are regulated 

based on the metal cleaning waste BPT requirements (indicated by a “1”). 

Chemical Metal Cleaning 

Waste Limits? 

ERG concluded that the plant’s metal cleaning waste discharges are regulated 

based on the chemical metal cleaning waste BAT requirements (indicated by a 

“1”). 

Notes Additional notes regarding the evaluation of the permit review information.