Data collected under the AWPA's Member Facility Questionnaire indicates that a large percentage of the Association's members discharge process wastewater to Publicly Owned Pretreatment Works. These discharges are regulated under the Effluent Limitations Guidelines which set forth minimum pretreatment standards for a number of industry categories including the Iron and Steel Industry Point Source Category (40 CFR Part 420). During the data review process, we have noticed that a significant number of the respondents' discharges to their POTWs are regulated under the Metal Finishing Point Source Category (40 CFR Part 433).
The Metal Finishing Category is applicable if you conduct one of the following six operations: electroplating, electroless plating, anodizing, chromating/phosphating/coloring, chemical etching and milling, and printed circuit board manufacturing. However, the regulation also states that although a facility may perform one of the above operations, if it is included in another pretreatment category the standards of that category apply, and not the standards associated with the Metal Finishing category. The Iron and Steel Point-Source Categories is one of those categories which supercedes the Metal Finishing Category. According to Patrick Bradley, EPA Industrial Pretreatment Program Coordinator, any facility pickling or cleaning a steel product in acid should be included under the Iron and Steel Point Source Category. He also stated that the legal responsibility falls to the industrial discharger to ensure that they are regulated under the appropriate pretreatment category. He further added that the EPA could fine violators, but, that private citizen groups could bring civil suits against the company for not discharging under the appropriate pretreatment category.
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American Wire Producers Association
801 North Fairfax Street, Suite 211
Alexandria, VA 22314-1757
Tel (703) 299-4434 | Fax (703) 299-9233 | E-mail info@awpa.org | Web: www.awpa.org
